9705_INSP_20240821

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost X SLAS COUNTY: Wilkes
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: 9705-COMPOST-2023
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill
DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: August 21, 2024 Date of Last Inspection: Initial Inspection

FACILITY NAME AND ADDRESS:
Wilkes Abattoir Compost
259 Brewer Road
Hays, North Carolina 28635

GPS COORDINATES (decimal degrees): Lat.: 36.24809 Long.: -81.12494

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Seth Church, Owner
Telephone: [phone]
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
257 Brewer Road
Hays, North Carolina 28635

PARTICIPANTS:
Seth Church, Owner Wilkes Abattoir, LLC
Chris Ferguson, Site Attendant Wilkes Abattoir, LLC
Charles Gerstell, NCDEQ Solid Waste Section
Lee Hill, NCDEQ Solid Waste Section

STATUS OF PERMIT:
A Permit To Operate Wilkes Abattoir Compost was issued to Wilkes Abattoir, LLC on June 28, 2023. This permit will
expire on June 28, 2033.

PURPOSE OF SITE VISIT:
Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
N/A

OBSERVED VIOLATIONS:
A. 15A North Carolina Administrative Code 13B .1406(12) states: Vector Attraction Reduction (VAR). Types 2, 3
and 4 facilities shall maintain the compost process at a temperature above 40 degrees Celsius (104 degrees F) for 14

B. 15A North Carolina Administrative Code 13B .1406(13)(b)(ii) states: (13)
Pathogens (PFRP). The composting process shall qualify as a process to further reduce pathogens for all Type 3 and
Type 4 facilities. The following shall be acceptable methods: (b) the static aerated pile composting method, in which
the following requirements apply: (ii) the temperature of compost pile shall be maintained at 131 degrees F (55
degrees Celsius) or greater for at least 3 days.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 3

C. 15A North Carolina Administrative Code 13B .1408(a)(1) states: (a) Record Keeping: Facility owners or
operators shall maintain records for no less than five years. The following records shall be available for inspection
by Division personnel during the facility's normal business hours and shall be sent to the Division upon request: (1)
daily operational records that include temperature data (length of the composting period) and quantity of material

Temperature records were not being recorded as required. No temperature data was available beyond
October 5, 2023. Wilkes Abattoir, LLC is in violation of 15A NCAC 13B .1406(12), .1406(13)(b)(ii), and
.1408(a)(1) as temperature records were not being documented as required.

In order to achieve compliance, temperature records must be recorded and made available for inspection by
Division personnel. A follow-up inspection will be performed at a later date to confirm compliance. No
compost on site may be land applied until temperature data has been documented showing pathogen
reduction criteria have been met.

ADDITIONAL COMMENTS

1. The facility consists of a small Type 3 compost operation approved for the acceptance of wastes listed in the
approved application, which include animal processing waste, such as offal, hides, and bones; chicken litter; clean
wood, such as yard waste, wood chips and sawdust; and other farm carbon sources such as hay, for composting.
2. A gate was provided at the entrance to the facility to prevent unauthorized access.
3. Proper signage was provided at the entrance to the facility.
4. The facility utilizes the static aerated compost method.
Initially, wet material is mixed with material from the carbon and dry material bin. Once mixed, the
material is moved to a slotted floor where it is aerated using air compressors.
Mr. Church and Mr. Fergusson stated that compost is kept in the aerated piles for 14 days (stage 1). Once
stage 1 is complete, the compost is moved to stage 2 curing. The compost is kept in stage 2 for 14 days.
Once stage 2 is complete, the compost is moved to a finished storage pile adjacent to the curing area.
5. The aerated floor area measures 15 feet by 70 feet and is separated into 14 bins (7 on each side) designated by
painted lines on the floor and numbered signs on the interior walls of the facility.
Section 4 of the approved Operation Plan states that piles of compost will be maintained to 6 feet tall and will not exceed the 10 feet by 15 feet bin size including angle of repose. During the inspection,
there was no separation between individual compost piles. Compost had been placed in a continuous
pile measuring 15 feet by 70 feet. Mr. Church and Mr. Fergusson stated that they could distinguish
between compost piles by the level of breakdown in each pile. However, the compost pile
construction on site was not consistent to what was approved in the Operation Plan. Please contact
Ms. Donna Wilson, Engineering Project Manager to obtain approval in changes to the compost pile
construction.
Donna Wilson, Engineering Project Manager
[phone]
[e-mail]

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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6. All interior roadways were of all-weather construction and well maintained.
7. No leachate was observed on site at the time of the inspection.
8. No offensive odors were observed.
9. All compost operations were maintained within the designated building.
10. No unacceptable waste streams were observed.
11. No dust was observed on site.
12. Temperature records were submitted to the Solid Waste Section during the facility annual reporting period for July
11, 2023 through October 5, 2023. However, no temperature records were available at the time of inspection
beyond October 5th. Please see above for compliance requirements.
13. Testing results for fecal coliform and heavy metals were submitted to the Solid Waste Section during the facility
annual reporting period. Please continue to ensure the subject testing is performed at the required frequency of per
20,000 tons of compost produced or every six months, whichever comes first.
14. During the inspection, a small amount of compost material was observed on the concrete footers and on the ground
adjacent to the footers on the exterior sides of the building. It appeared that this material was deposited when
compost was removed from the aerated compost bins and spilled over the top of the interior wall made of 2 x 6
boards. Please remove this material and return it to the compost area. Efforts must be made to inspect the exterior
of the building upon conclusion of loading and unloading of the aerated compost bins. Any material deposited on
the exterior of the building must be removed immediately.
15. Permit Condition #5 of the Permit to Operate states:
with 15A NCAC 13B .1406(19) within 18 months of permit issuance. A responsible individual trained in facility
operations must be onsite during all operating hours of the facility. A list of approved training courses are listed
here- https://www.deq.nc.gov/about/divisions/waste-management/solid-waste-section/special-wastes-and-
alternative-handling/composting#CompostOperatorTraining-3819
The facility must ensure the requirements of Permit Condition #5 and 15A NCAC 13B .1406(19) are
met.

Please contact me if you have any questions or concerns regarding this inspection report.

________________________________________ Phone: [phone]
Charles T. Gerstell
Environmental Senior Specialist
Regional Representative

Sent on: 9/6/24 X Email Hand delivery US Mail Certified No. [ _]

Copies: Deb Aja, Western District Supervisor - Solid Waste Section