92N_INSP_20240508

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
MSWLF X COUNTY: WAKE
X PERMIT NO.: 92N-LCID-2021
Collection Monofill Landfill FILE TYPE: COMPLIANCE

Date of Site Inspection: May 8, 2024
FACILITY NAME AND ADDRESS: Triangle Forest Products, Inc. 4525 Sunset Lake Road Apex, NC 27539
GPS COORDINATES: Lat.: 35.684494 Long.: 78.816179 FACILITY CONTACT NAME AND PHONE NUMBER: Clayton Horne, Landfill Manager, (o) 919-469-2620, (c) 919-961-4807, [e-mail]
FACILITY CONTACT ADDRESS:
Teresa Phillips, Corporate Secretary Triangle Forest Products, Inc 7151 O’Kelly Chapel Rd
Suite 278 Cary, NC 27519-6849 PARTICIPANTS:
Tim Davis, NCDEQ Drew Hammonds, NCDEQ Clayton Horne, Triangle Forest Products, Inc
STATUS OF PERMIT:
PTO Phases 1, 2 & 3 issued October 6, 2021; expires September 22, 2025. PURPOSE OF SITE VISIT: Comprehensive Compliance Inspection STATUS OF PAST NOTED VIOLATIONS:
None OBSERVED VIOLATIONS:
None
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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ADDITIONAL COMMENTS
The facility is an LCID landfill and T&P facility permitted to receive for disposal land clearing waste; yard trash, untreated and unpainted wood, uncontaminated soil, inert debris such as unpainted rock, brick, concrete,
concrete block, and asphalt in accordance with N.C.G.S. 130A-294(m). The current Permit to Operate (PTO) expires September 22, 2025. Please submit a permit renewal application prepared in accordance with 15A NCAC 13B .0565 and .0566 to the Section no later than March 22, 2025. 1. The “Existing Conditions” map within the approved Operations Manuel does not accurately reflect the current operations taking place at this facility. It is understood that a property easement dispute is ongoing with Wake County Schools that will impact current property boundaries or establish new ones. However, once the dispute is resolved, the facility must operate within the NC Solid Waste Management Rules governing the various activities. Please provide the Section with an updated, detailed facility map
depicting all current waste processing, storage, and disposal areas as soon as possible. The new facility map should also delineate any new buffers that may be necessary to maintain the required distance between potentially new property boundaries and waste processing and disposal areas. 2. The facility has proper signage and is secured by a locking gate when not in operation. Personnel are on site during operating hours, which are 7:00am to 4:30pm Monday to Friday.
3. The facility permit and site plan were available and reviewed with facility staff. Ensure that the facility
operations plan is updated with correct NCDEQ contact information. 4. Interior roadways are of all-weather construction and are maintained in fair condition. 5. Permit to Operate, Attachment 3, Part V #13, “All waste shall be covered with no less than six inches of soil monthly or when the active area reaches one (1) acre in size, whichever occurs first.” At the time
of this inspection, multiple areas of the facility contained uncovered and/or stockpiled waste which far exceeds
1 acre in size. Exposed woody waste and root mat was observed on the southern and western side slopes of the log storage and processing area within Phase 1 and falling into the surrounding tree line. Tree debris and unprocessed decaying logs were stacked in piles 15 feet high in some instances and stockpiled in an area approximately 1 acre in size in the western portion of Phase 2. An uncovered one-half acre sized “spoils” pile
of unusable waste left over from mining/screening operations is being dumped in the western end of Phase 2
and is falling into the tree line and encroaching on the adjacent wetland. Ensure that solid waste is restricted to the smallest area feasible, and that total exposed waste does not exceed one acre in size. The approved Operations Manuel, Page 13, Section 2.5.1 states that the exposed waste will be covered when it exceeds one-half acre in size. Side slopes in Phase 1 should be pulled back from the tree line, graded to 3:1, and covered.
Exposed waste in the “spoils” pile in Phase 2 should also be pulled back, graded to 3:1 and covered.
Unprocessed tree debris and logs in Phase 2 need to be either disposed of and covered onsite or processed and moved offsite. 6. Permit to Operate, Attachment 3, Part V #9, “Solid waste in the landfill shall be compacted. Slopes shall not exceed a ratio of three horizontal to one vertical (3:1) at any time.” As stated in #4 above,
multiple areas of the landfill contained slopes which exceeded a ratio of 3:1 and either terminated within the
tree line or had waste which had fallen into the tree line. Ensure all side slopes are pulled back from the surrounding trees, graded to 3:1, and covered properly. 7. 15A NCAC 13B .0301, (6)(D), Buffer Requirements: Unless otherwise stated in the site permit or local zoning requires larger buffers, the waste handling, treatment, processing, and storage areas shall be:
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
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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(D) surrounded by an unused and cleared area of no less than 25 feet to allow access for fire or emergency response vehicles.” And Permit to Operate, Attachment 3, Part VII #26, “Wood waste and processed material must be maintained with adequate fire breaks and lanes in accordance with approved operations plans and pertinent rules.” And Operations Manuel, pg. 17, Section 2.10.2.3, “The minimum buffer between stockpiles and all operations equipment is 20 feet.” At the time of this
inspection, piles of ground wood material in the Phase 2 wood processing and grinding area contained little
to no fire breaks between piles and no unused and cleared lanes surrounded the processing area. Ground wood material was observed to be falling down the adjacent side slope and into the tree line. Ensure adequate fire breaks and lanes are established and maintained between and around all sides of the ground wood material piles. It is recommended that sediment fencing, or some other type of barrier, is installed to prevent ground
material from leaving the processing and storage area.
8. Permit to Operate, Attachment 3, Part V #10, “Permanent markers that accurately delineate the waste disposal boundary must be maintained.” And Operations Manuel, Section 1.4.1 states, “During construction or closure of landfill units, waste limit markers will be used to identify the permitted limits of waste. The waste markers will be constructed of non-degradable material and will state “Waste
Limits” in bold lettering.” Permanent edge of waste (EOW) markers were not visible during this inspection.
A combination of mature trees and overgrown vegetation cover the side slopes and interior areas on top of the landfill, preventing an effective visual inspection of the landfill. EOW markers that accurately delineate the waste boundary must be maintained and should be placed at a frequency in which they are visible from one to the next. Vegetation on the side slopes and the top of the landfill should be mown or rough cut to allow
visual inspection of the landfill.
9. 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.” No access road around the waste boundary had been established at the time of this inspection. 10. Painted brick and concrete, countertop waste, metal, plastic, and particle board were observed within both the
ground inert debris pile and the inert debris stockpile. These materials do not meet the definition of inert
debris. Also, municipal solid waste (MSW) was identified within the “spoils” pile in Phase 2. Ensure all non-conforming waste is removed from incoming loads and prior to grinding, placed in a container, and disposed of offsite at a permitted facility. Any MSW uncovered during mining operations or screening needs to also be placed in a container and disposed of offsite at a permitted facility.
11. Dust was an issue during this inspection and should be managed in accordance to part 3.4 of the approved Operations Manuel. 12. Corrective actions are necessary as a result of this inspection. 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

Sent on: June 10, 2024 X Email Hand delivery US Mail Certified No. [ _]

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Copies (email): Drew Hammonds, Field Operations Branch Head – Solid Waste Section James Wallace, Permitting Engineer – Solid Waste Section Stacy Smith, President/Senior Engineer – Smith Gardner, Inc
View of uncovered woody waste on overly steep slope View #1 of tree debris & decaying log stockpile in Phase

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 5

View of ground wood waste piles lacking fire breaks & View of ground wood waste spilling into tree line in Phase

View of inert debris stockpile spilling into tree line and Close-up view of inert stockpile containing countertop