47A-LCID-1996_INSP_20230829

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF LCID X YW X Transfer Compost SLAS COUNTY: HOKE
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 47A-LCID-1996
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: August 29, 2023 Date of Last Inspection: November 4, 2022
FACILITY NAME AND ADDRESS: Hoke County LCID Landfill 700 C.C. Steel Rd., Raeford, NC 28376
GPS COORDINATES: Lat: 35.00726 Long: -79.21806 FACILITY CONTACT NAME AND PHONE NUMBER: April King Locklear, Solid Waste Director Hoke County Solid Waste
[e-mail] 910-705-2514
FACILITY CONTACT ADDRESS:
Same as above
PARTICIPANTS: David Powell – NC DEQ, Solid Waste Section April King Locklear, Hoke County Solid Waste Director
Helen Adams, Hoke County Supervisor STATUS OF PERMIT:
47A-LCID-1996 – Last permit was Issued July 11, 2018, and Expired July 11, 2023. Permit modifications were approved 11/02/2020. County submitted application for renewal currently waiting new permit. Continue to operate under previous permit until new permit is issued.
PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: NA OBSERVED VIOLATIONS: NA

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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ADDITIONAL COMMENTS
1. David Powell with the Section visited Hoke County facilities for routine inspection. Mr. Powell met with April
King Locklear, Hoke County Solid Waste Director, and Supervisor Helen Adams. Ms. Locklear and Ms. Adams assisted Section staff during inspection. The site has an LCID, 2-acre YW staging and processing area and an animal burial unit. County should contact NCDA Vets office for rules/guidance for animal burial. YW to
be mulched week after inspection will be conducted by Farmers Mulch out of Dobson, NC. The possibility of an Air Curtain Incinerator (ACI) was discussed during inspection as an alternative to YW processing, mulching and composting. Hoke County should discuss, research ACI operations in surrounding counties, and review with Section Permitting if interested. 2. Signage was close to correct to meet new rules. However, contact number needs to be added. Additional signs direct the flow of traffic and indicate waste types.
15A NCAC 13B .0566 (14) - A sign shall be posted at the site entrance showing the site contact's name and phone number, the permit number, emergency contact information, and the waste types accepted for disposal at the site.

Current signage at entrance to Hoke County Solid Waste facilities.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 12
3. The road from the Transfer Station to the LCID/YW processing had serious erosion and needs to be fixed.
However, the roads between the YW processing area and surrounding the LCID were in good shape and all-weather construction. 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 and equipment. 4. The current YW processing operations are separated by the center road through the 2-acre area, in which one side takes new yard waste (W) and the other side (E) is where the mulch is windrowed after grinding. Currently, only one side has waste and it’s going to be ground very soon. Ms. Locklear indicated that the following day a crew was coming to mark the limits of processing yard waste of two acres. In previous inspections, it was stated that Edge of Waste (EOW) markers were needed to mark the 2-acre limits of the YW area. This
area should also be in the correct positioning to meet the 2-acre limits, with respect to the property line buffer of 100 feet. Ms. Locklear has previously had a surveyor come and mark this area, along the property buffer, but this didn’t match up with current operations, current approved maps or where any future operations
were to occur. The 2-acre area EOW markers needed to be installed to align with the current YW storage and processing area, which according to Ms. Locklear, is the future area as well. The area EOW markers were put in place by the surveyor, were further NE than the actual area being used and didn’t align with the approved 2020
map or current map submitted with permit renewal application. Records show an approved map, “Sheet 3” (FID1472960), dated November 2, 2020, that indicates a general area for the YW and the active areas/limits of the LCID. The renewal application submitted 6/27/2023 didn’t include the 10/2/2020 map but another which
shows the YW processing area on the southwest part of the 2020 map only. Based on the previous inspections, records review, discussion onsite with Ms. Locklear, and Section Permitting, the YW area needs to align with approved plans and any changes should be submitted to Section permitting for approval. The four corners should be marked, all YW processing should take place inside this area, align with approved map, and align more closely with current operations onsite and how the County wishes to operate, with respect to buffers and 2-acre limits. This updated map should be kept with Hoke Counties records and operations plan. This should alleviate any misunderstandings onsite as to the proper area, clear up any confusion and properly mark the correct approved area. Refer to an engineering firm/consultant/surveyor if needed for
this task. See two photos of maps referenced in this discussion for better understanding.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Partial image of Map dated 10/2/2020 (FID1472960). Red outlined area is YW area currently approved and represents onsite operations.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 12
Partial image of map submitted with renewal application, received by Section 7/12/2023. Arrow points to YW
processing area in above map. Indicates part of same area as previous map. (FID 1811081)

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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5. The YW processing accepts, land clearing, yard waste and yard trash in one long windrow and every year mulches
the waste. In the process, a windrow of mulch, on the E side of the access road, and temperatures are taken. Fire breaks should be kept every so often to the mulch and raw waste. Please be sure mulch operators do this when they come. Be sure they keep the waste inside the 2-acre approved area with respect to the buffers, mainly SE from this site to property line. 15A NCAC 13B .0564 (6) - Buffer Requirements: A site shall maintain the following buffer requirements: (a) 50 feet from the waste boundary to waters of the State as defined in G.S. 143-212. (b) 100 feet from the waste boundary to property lines, residential dwellings, commercial or public buildings, and potable wells. The Division may establish alternative site-specific buffers in the permit conditions if it is necessary for the preservation of public health and the environment.

Raw waste awaiting mulching.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 12
Access road and area where will be used for windrowing mulched waste. Raw waste is windrowed on left (W) of the
road and when mulched it will be windrowed on the right of the road. 6. YW looked fairly clean during inspection. This previous mulch, now removed by 401 Sand for mining side
slopes, has met time and temperatures. Good job. Those records were reviewed during inspection. Many places try and mulch their waste, compost it, then try and make a marketable product. This is a difficult task. However, all the waste must be very clean of all trash and be a very completely composted product. This takes equipment, staff onsite to always stop unapproved items, and time to allow for lots of turning and adding moisture, as needed, to encourage a completely composted product. Once meeting time and temperatures of 15A NCAC 13B .1406, 131 degrees F for three consecutive days, this composted material can be used in flower beds around county etc. This is the minimum to meet rule and further composting is needed for a quality product. Otherwise, avenues for compost mulch can be possibly taken to boilers, or landfills to mix with soil to use for an alternative daily cover.
Since Hoke Counties waste has yard trash comingled with land clearing and yard waste, it must meet 15A NCAC 13B .1406 time and temperatures before it can leave or go to the public. Before any changes onsite, operational changes or deviations to what’s approved in operations plan and permit, a modification may
be needed, and the county should discuss with Section Permitting beforehand. The current size was measured by laser range finder and was approximately 130 yards long by 20-40 feet wide. This is within the two-acre size currently, but when mulching begins, and raw waste is still accepted then the size could grow to 2 acres or beyond if not marked and managed appropriately.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 12
Raw vegetative waste windrow awaiting to be mulched.

Partial view of YW temp records.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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7. The LCID was recently mowed and had EOW markers in place visible from one to the next. Good job. Please keep older cells mowed and trees and shrubs from growing. Must maintain side slopes and inside limits of disposal.
NW corner EOW marker of LCID.
View is looking SW along edge of LCID and access road.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 10 of 12
8. LCID working face has been covered and sloped appropriately. Be sure and always cover waste within 30 days of waste acceptance or when waste reaches one acre in size, whichever occurs first.
EOW marker at corner of open cell/working face. Some soil was staged. Good job.

Open cell, working face, covered and sloped.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Close up view of previous photo. Working face. 9. An attendant should be on duty at all times while the landfill/YW area is open for public use to assure compliance with operational requirements and to prevent acceptance of unauthorized waste. It is recommended that facility staff accompany customers to the LCID and YW areas when dumping to better screen waste to ensure only acceptable waste is received. This would limit unapproved waste and add more control of where waste is placed onsite. 10. Ms. Locklear/County has made many improvements onsite, thank you and good job. YW area maps/documents should be adjusted to fit the onsite operations or site should meet currently submitted documents once, and if, approved. Any additional documents that are needed should be submitted ASAP. The YW processing area should be marked on the correct four corners and then operations should be kept in this area. Please be sure and keep good windows with fire breaks. The access road should be fixed and maintained for firefighting and Section vehicle access. Signage needs a small amount of information added to meet requirements. Any additional signage that may be beneficial should be added as needed to help maintain compliance and understanding of waste acceptance, flow of traffic, dumping procedures etc. 11. Corrective actions are necessary as result of this inspection. Corrective actions should be completed within 60 days from the date of this inspection report sent. Failure to resolve these matters may result in further enforcement action. Requested documents should be submitted to Sherri Stanely, Section Permitting Branch Head at [e-mail] or [phone] and David Powell. A follow-up may be conducted after the given time frame or shortly after.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: [phone] _ David Powell Environmental Senior Specialist Regional Representative
Sent on: 9/13/2023 X Email Hand delivery US Mail Certified No. [ _]

Copies: Drew Hammonds, Eastern District Supervisor - Solid Waste Section Sherri Stanley, Permitting Branch Head – Solid Waste Section Allen Gaither, Environmental Engineer – Solid Waste Section