0107_INSP_20231207

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: Alamance
Closed MSWLF HHW White goods Incin T&P X FIRM PERMIT NO.: 01-07
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: December 6, 2023 Date of Last Inspection: December 7, 2021
FACILITY NAME AND ADDRESS:
Key Properties LCID Landfill and Treatment and Processing Operation
2380 Sandy Cross Road
Burlington, NC 27217 GPS COORDINATES: N: 36.14365 W: -79.35972 FACILITY CONTACT NAME AND PHONE NUMBER:
David Moody, Owner - Key Properties LCID Landfill and Processing Facility
w. 336-380-3142 [e-mail]
FACILITY CONTACT ADDRESS:
Sandy Cross, Inc.
David Moody, President
1535 East Webb Ave., Suite 101 Burlington, NC 27217 w. 336-380-3142
[e-mail]
PARTICIPANTS: Chuck Kirchner, Environmental Senior Specialist – Solid Waste Section (SWS)
Geno Taylor, Yard Supervisor - Key Properties LCID Landfill and Processing Facility
STATUS OF PERMIT:
Permit To Operate (PTO) issued August 10, 2017
Permit To Construct (PTC) issued in conjunction with PTO PTO renewal submitted on January 31, 2022 Permit under review
PURPOSE OF SITE VISIT:
Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: None OBSERVED VIOLATIONS:
A. 15A NCAC 13B .0203(d) states: By receiving solid waste at a permitted facility, the permittee shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the permit.”

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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1. Permit to Operate No. 0107-LCID-2014 ATTACHMENT I, PART IV, General Facility Permit Condition # 6 states: “Construction or operation of this solid waste management facility shall be in accordance with the North Carolina Solid Waste Management Rules, 15A NCAC 13B; Article 9 of the Chapter 130A of the North Carolina General Statutes (NCGS 130A-290, et seq.); the conditions contained in this permit; and the
approved plan. Should the approved plan and the rules conflict, the Solid Waste Management Rules shall take precedence unless specifically addressed by permit condition. Failure to comply may result in compliance action or permit revocation.” a. Permit to Operate No. 0107-LCID-2014 ATTACHMENT III, General Facility Permit Condition # 7
states in part: “The facility is permitted to grind land clearing debris waste and stockpile the
resulting processed wood chips within the LCID landfill facility, and for improvement of existing service and entrance roads. a. Land-clearing debris must not be stockpiled onsite for greater than 6 months; is restricted to less than 1 acre in size and 10 feet in height; and no more than 6000 cubic yards can be
onsite at any one time. b. Processed wood chips must not be stockpiled for greater than 3 months and is restricted to less than 1 acre in size and 10 feet in height.
On December 6, 2023, an accumulation of LCID waste was observed in the southern cell of the facility. Several of the LCID stockpiles were observed to be at least 15 feet in height. In addition, the quantity of LCID observed on site appeared to be more than the permitted 6,000 cubic yards. Mr. Moody stated via email sent on 12/12/2023 that there are currently 11,499 cubic yards of LCID material on site. Of this 11,499 cubic yards of LCID material on site, 2,874 cubic yards of mulch and 8,625 cubic yards of LCID waste are currently on site. Therefore, Key Properties Is in violation of 15A NCAC 13B .0203(d). To achieve compliance, the quantity and management of land clearing debris, both
processed and unprocessed, must conform to the requirements of this permit. A follow-up inspection will be conducted to determine compliance with this Rule.

ADDITIONAL COMMENTS
On December 6, 2023, Chuck Kirchner met with Geno Taylor to conduct a comprehensive inspection of the Key
Properties LCID Landfill and Treatment and Processing Operation on Sandy Cross Road in Burlington, Alamance County.
1. The facility is a land clearing and inert debris (LCID) landfill. The permitted LCID landfill area consists of a North Cell, a South Cell, and a 1.99-acre area (previously, notified LCID landfill# N0705) with an additional 1.2- acre expansion area.
2. The facility permit includes a yard waste treatment and processing (T&P) operation and a concrete crushing operation that is conducted atop a notified LCID landfill area (# N0475). The notified LCID landfill is covered with soil and is no longer active. 3. The facility is also a Temporary Debris Storage and Recovery site (TDSR). The TDSR number is DS01-012. 4. The facility has constructed the North Cell and is operating the 1.99-acre area with additional 1.2-acre area. The area allotted for the South Cell is being used as the Treatment and Processing area.
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

Page 3 of 4
5. LCID material is currently being recycled into mulch and not being added to the LCID landfill according to Mr. Taylor. 6. Mr. Taylor stated that LCID material previously landfilled is currently being removed from the North Cell and being recycled into mulch in the T&P area located in the South Cell. 7. Ensure edge of waste markers are maintained around the North Cell until all waste is removed from the landfill. 8. A significant amount of LCID material was observed around the South Cell. 9. Mr. Taylor stated that dyed mulch and natural mulch are produced on site and other mulch material is purchased for re-sale. 10. Dyed mulch and purchased mulch, sand and stone are kept in concrete loading bays near the site office. 11. The facility is permitted to receive land clearing waste, yard trash, untreated and unpainted wood, uncontaminated soil, inert debris, and (used) asphalt. 12. The facility is permitted to receive LCID generated within: Alamance, Caswell, Chatham, Durham Forsyth, Guilford, Orange, Person, Randolph, Rockingham, and Wake Counties. 13. Solid waste shall be restricted to the smallest area feasible and compacted as densely as practical into cells.
14. Solid waste shall be covered with 1 foot of soil cover at least once per month, or when the active area
reaches one acre in size, whichever occurs first per Permit to Operate No. 0107-LCID-2014 Attachment III, General Facility Permit Condition #15. 15. A ready supply of soil is available for cover material.
16. Excavation, grading and fill material side slopes must not exceed a ratio of three horizontal feet to one vertical feet (3:1). 17. The LCID landfill facility annual report (FAR) was received by the SWS dated August 1, 2023.
Estimated facility throughput for July 2022 through June 2023 1,010 yd3 per week and the facility was in operation for 52 weeks during that timeframe. 18. Records were observed for waste received from July 1, 2023 through November 30, 2023. In that time 21,026 yd3 of brush, 3,208 yd3 of concrete/asphalt and 11,065 yd3 of dirt and rock were received at this facility. In that time 20,890 yd3 of mulch, 338 yd3 of dirt 535 yd3 of crushed concrete were sold. 19. LCID material on site more than permitted quantities can pose a significant fire hazard. 20. If a fire occurs, the permittee must provide oral notification to the Section within 24 hours of the occurrence followed by a written report of the details of the fire within 15 working days of the occurrence. 21. The facility shall not compost or grind high nitrogen-to-carbon ratio material.
22. Land-clearing debris (LCD) must not be stockpiled onsite for greater than 6 months.
23. Processed wood chips must not be stockpiled for more than 3 months and is restricted to less than 1 acre in size and 10 feet in height. See violation above.
24. Permissible grinding and storage areas include the existing area near the facility office and within the approved landfill footprint above the ground water table. 25. The facility shall not compost material. 26. Open burning of land clearing waste is prohibited. 27. The facility is operating under an Erosion and Sediment Control Plan, ALAMA-2014-028. 28. Sedimentation and erosion controls appeared adequate. There was no indication observed of erosion or runoff.
29. The facility commonly stores gravel, asphalt, and/or mulch adjacent to the office for sale and use on site.
30. The Pleasant Grove Volunteer Fire Department, Faucette Fire Department, or the Haw River Fire Department can be contacted to respond to an emergency at the facility. 31. Access roads are of all-weather construction.
32. An attendant is on duty when the facility is in operation.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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33. The facility is secured by a locked gate. 34. The facility has proper signage.
Please contact me if you have any questions or concerns regarding this inspection report.

Phone [phone] Chuck Kirchner Environmental Senior Specialist
Regional Representative
Sent on: December 18, 2023 X Email Hand delivery US Mail Certified No. [ _]
Copies: Deb Aja, Western District Supervisor - Solid Waste Section Sarah Moutos, Environmental Program Consultant – Solid Waste Section