92V_INSP_20230608

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF LCID X YW Transfer Compost SLAS COUNTY: WAKE
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 92V-LCID-
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: June 8, 2023
FACILITY NAME AND ADDRESS: Carolina Tree Debris 1417 Old Watkins Road Raleigh, NC 27616 GPS COORDINATES: Lat.: 35.86386 Long.: 78.50665 FACILITY CONTACT NAME AND PHONE NUMBER: Marvin Butler, Landfill Manager, 919-271-1562, [e-mail]
FACILITY CONTACT ADDRESS: Same as above

PARTICIPANTS: Tim Davis, NCDEQ – Solid Waste Section
Drew Hammonds, NCDEQ – Solid Waste Section Marvin Butler, Carolina Tree Debris STATUS OF PERMIT:
PTO expired on May 26, 2022. A permit renewal application was received on 1/7/2022 and is under review. PURPOSE OF SITE VISIT:
Comprehensive Compliance Inspection STATUS OF PAST NOTED VIOLATIONS:
None

OBSERVED VIOLATIONS:
A. 15A NCAC 13B .0566 (3), “All waste shall be covered with no less than six inches of soil monthly, or when the working face reaches one acre in size, whichever occurs first.” At the time of this inspection, the amount of uncovered waste exceeded one acre in size. In addition to the active disposal area in the northeast corner of the landfill, large amounts of uncovered land clearing (LC) and some inert debris waste were observed on top of landfill and on the southern side slope adjacent to the access road. Yard
waste had been dumped on the western side slope and remained uncovered. Mr. Butler stated that Enviva has expressed interest in grinding the LC waste, removing it, and utilizing it for their wood pellet production. Ensure waste is kept to the smallest possible space and covered with a minimum of 6-inches of soil every 30 days or as often as necessary to achieve a working face of no larger than 1 acre in size. The top of the landfill is not currently designated as a storage and processing area for LC debris. Existing LC waste on top of the landfill needs to be ground and/or removed within 30 days, or else disposed of in the landfill. See comment #1 and #2 for more information. B. 15A NCAC 13B .0566 (2), “Solid waste in the landfill shall be compacted. Slopes shall not exceed a ratio of
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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three horizontal to one vertical at any time.” At the time of this inspection, the western and northern side slopes, which include the current working face, were observed to be steeper than a ratio of three horizontal to one vertical. Uncovered land clearing waste within the active disposal area was uncompacted and appeared to be unstable. Ensure side slopes are regraded to achieve a 3:1 ratio. Waste within the active disposal area shall be properly compacted, sloped, and covered with
adequate soil cover. C. 15A NCAC 13B .0201 (g), “Disposal area boundaries for landfills permitted in accordance with Section .0500 or .1600 of this Subchapter shall be delineated with stationary markers affixed to the ground. The markers shall be of height and spacing so that they are distinguishable from the surrounding landscape, and so that the adjacent markers are visible when standing at a marker.” Edge of waste (EOW) markers were not visible during this inspection. Ensure that permanent, clearly visible edge of waste markers delineating the disposal area boundaries are installed at this facility. Each marker shall be visible from one to the next.
D. 15A NCAC 13B .0566 (5), “Erosion control measures, structures, or devices shall be utilized to prevent silt from leaving the site and to prevent on-site erosion and shall comply with 15A NCAC 04.” Erosion control measures, structures, or devices were not visible during this inspection. Sediment ponds #1 and #2 may have been covered over or are overgrown with vegetation. Sediment was observed migrating off-site in the northeast corner of the landfill property. Ensure erosion and control measures, structures, or devices referenced in the Operations Manual and the Sediment and Erosion Control Plan are constructed and maintained in accordance to plan design.
ADDITIONAL COMMENTS The facility is a land clearing and inert debris (LCID) landfill that may receive land clearing waste, inert debris, yard trash, and asphalt waste generated within Wake County. 1. A renewal application including the Operations Manual dated January 7, 2022, was submitted to Permitting for review and approval with modifications to processing areas. The current Operations Manuel dated October 11, 2016, page #145 designates the area along the southern property boundary for this purpose. The top of the landfill is not currently an approved area for storage and processing of LC debris. Any additional changes to the location of LC debris storage and processing areas must be submitted to Permitting for approval.
2. Mr. Hammonds recommended that Mr. Butler contact local wood processing and/or composting facilities as a way to deal with excessive LC waste and logs. The Division of Environmental Assistance and Customer Service (DEACS) is a resource which could help with this endeavor and can be reached at 1-877-623-6748.
3. The facility is properly secured with a locking gate. Personnel are onsite during operating hours, which are Monday through Friday from 8:00 am to 5:00 pm. 4. Permit to Operate, Attachment 3, Part I #9, “Signs must be posted at the entrance to the facility that state that no hazardous waste or liquid waste can be received at the facility; and that provide information on dumping procedures, the hours of operation, the permit number, and other pertinent information. Traffic signs or markers must be provided as necessary to promote an orderly traffic pattern to and from the discharge area and to maintain efficient operating conditions.” Ensure posted entrance signs contain all required information including the correct emergency contact name and telephone number.
The item(s) listed above were observed by Section staff and require action on behalf of the facility in order to come into or maintain compliance with the Statutes, Rules, and/or other regulatory requirements applicable to this facility. Be advised that pursuant to N.C.G.S. 130A-22, an administrative penalty of up to $15,000 per day may be assessed for each violation of the Solid Waste Laws, Regulations, Conditions of a Permit, or Order under Article 9 of Chapter 130A of the N.C. General Statutes. Further, the facility and/or all responsible parties may also be subject to enforcement actions including penalties, injunction from operation of a solid waste management facility or a solid waste collection service and any such further relief as may be necessary to achieve compliance with the North Carolina Solid Waste Management Act and Rules.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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5. Permit to Operate, Attachment 3, Part I #3, “Copies of this permit, the approved plans, and all records required to be maintained in the operating record by the permittee must be maintained at the facility, unless otherwise approved by the Section, and made available to the Section upon request during normal business hours.” During this inspection, records could not be reviewed as Mr. Butler was unable to provide copies of the permit and approved plans. Ensure up to date copies of all pertinent documents are kept onsite and are accessible to all facility personnel. NCDEQ representative contact info needs to be updated.
6. Permit to Operate, Attachment 3, Part I #5, “Open burning of solid waste is prohibited.” At the time of this inspection, smoke was observed rising from the southern side slope adjacent to the base of the access road which leads to the top of the landfill. Mr. Butler stated that he had partially excavated this area to cool down a “hot spot”. The presence of smoke indicates that conditions are favorable for fire ignition. Any disposal areas of the landfill which emit smoke should be excavated, flooded with water to reduce heat, and/or smothered with excess soil to reduce oxygen. Ensure all newly disposed waste is properly covered with at least 6 inches of soil weekly or as needed
to limit the occurrence of fires within the landfill. In the event of a fire, the owner will verbally notify the Section within 24 hours of discovery of a fire and provide written documentation within 15 days following any such occurrence using the ‘Solid Waste Management Facility Fire Occurrence Notification’ form. 7. 15A NCAC 13B .0567 (c)(1)(B), “Post Closure Requirements…Maintenance of the vegetative cover of the cap, and ensuring that trees and other woody vegetation do not become established on the cap.” At the time of this inspection, the side slopes of the landfill were overgrown with a combination of tall grassy and woody vegetation so
that the cap was not visible. Mature trees were identified on the western and northern side slopes. Ensure any trees or woody vegetation is removed or rough cut to maintain the vegetative cover of the landfill, prevent damage to the landfill cap, and to allow for visual inspection of the cap/slopes. Vegetation with a trunk or stem larger than 6 inches in diameter should be removed completely and the cap repaired. Landfill vegetative cover should be mowed at least twice per year or as often as necessary to allow for visual inspection of the landfill. 8. 15A NCAC 13B .0564 (7), “The site shall establish and maintain an access road around the waste boundary for access by emergency or fire fighting vehicles or equipment.” A partial access road was identified around the waste boundary but remained incomplete at the time of this inspection. Ensure an access road around the
waste boundary is established and maintained. The operator should maintain the required 100’ buffer to the adjacent property lines. 9. At the time of this inspection, several areas of standing water were observed on top of the landfill. Surface water
needs to be diverted from the landfill and cannot be impounded over waste. Ensure any low-lying areas are graded to promote positive drainage of surface water away from the top of the landfill. 10. Mr. Butler stated that the facility staff consisted of only himself and one part-time employee. It is recommended that
additional personnel are hired to help achieve and maintain compliance at this facility. 11. Within 30 days receipt of this report, please provide the Section a corrective action plan to address the observed violations. The plan should include methods and a reasonable timeline to bring the facility into compliance. 12. Corrective measures are necessary at this facility and should be under way. The Solid Waste Section will conduct a follow-up inspection in 30 days to ensure notable progress has been made toward compliance. 13. Digital photographs were taken during this inspection. Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: [phone] Tim Davis [e-mail]
Environmental Senior Specialist Regional Representative
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Sent on: June 21, 2023 X Email Hand delivery US Mail Certified No. [ _]
Copies (email): Drew Hammonds, Eastern District Supervisor – SWS Elizabeth Werner, Hydrogeologist – SWS
Digital photographs taken by Tim Davis on 6/8/2023.
View of uncovered waste on top of landfill. View #2 of uncovered waste on top of landfill.
View of current working face. View of sediment migrating off-site in northeast corner.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 5
View of uncovered waste on southern side slope emitting smoke.
View of western side slope with woody vegetation, mature trees, and uncovered yard waste.
View of northern side slope with woody vegetation. View of uncovered waste on top of landfill with standing water.