3005Compost_INSP_20160816

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost X SLAS COUNTY: Davie
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: 3005-Compost
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: 8-16-16 Date of Last Inspection: Initial Inspection

FACILITY NAME AND ADDRESS:
Gallins Family Farm Compost Facility
222 Rocky Dale Lane
Mocksville, NC 27028

GPS COORDINATES: N: 35.97512 W: 80.54014

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Peter M. Gallins, General Manager
Telephone: [phone]
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
Same as above

PARTICIPANTS:
Peter Gallins, General Manager
Lyndsy Gallins, Contracts Manager
Kim Sue, NCDEQ - Environmental Senior Specialist - Solid Waste Section
Deb Aja, NCDEQ – Western District Supervisor – Solid Waste Section
Susan Heim, NCDEQ - Environmental Senior Specialist - Solid Waste Section

STATUS OF PERMIT:
The Permit to Operate a Small Type 3 Solid Waste Compost Facility was issued on September 4, 2015 and shall expire
on September 4, 2020.

PURPOSE OF SITE VISIT:
Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
N/A

OBSERVED VIOLATIONS:
1. 15A North Carolina Administrative Code 13B .0203(d) states: “By receiving solid waste at a permitted facility,
the permittee(s) shall be considered to have accepted the conditions of the permit and shall comply with the
conditions of the permit.”

General Permit Condition Number 5 of Permit to Operate 3005 -Compost states: “This permit is issued
based on the documents submitted in support of the application for permitting the facility identified in
Attachment 1, “List of Documents for Approved Plan,” which constitutes the approved plan for the facility.
Where discrepancies exist, the most recent submittals and the Conditions of Permit shall govern.”
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 6

The approved Gallins Family Farm Compost Facility application for a permit to operate a
proposed small type 3 solid waste compost facility, dated September 4, 2015 (Attachment 1, DIN
22584, Page 12) states: “Leachate”, “GFF has constructed an impermeable concrete pad with
concrete catch basin, all underneath a roof system. All wastewater leachate from composting activities
on the concrete pad is redistributed onto actively composting windrows, any excess is sent to waste
water treatment. Leachate is not added to piles after PFRP, eliminating the risk of inoculating
pathogens. Leachate is collected in a 2,000-gallon holding tank under roof, on a concrete pad with
secondary containment. Secondary containment storage capacity is 750-Gallons.

To maintain zero-discharge of leachate from the composting site a 250-foot vegetative filter strips
consisting of fescue and orchard grass is down slope from the site. Storm water is controlled to flow
away from composting activities and avoid interception with compost material. The storage area is
prepared in such a manner that water does not collect around the base of the stored material.”

Item 4 of Attachment 3 of the “Permit to Operate” dated September 4, 2015 (DIN 22583) states:
“An appropriate Division of Energy, Mineral and Land Resources permit for managing any stormwater
or wastewater at the facility must be maintained as required. Any leachate generated at the facility and
any runoff from the facility must be managed in such a manner that ground or surface water quality
will not be adversely affected. The facility must be maintained to prevent the accumulation of
stormwater and leachate on composting areas, storage areas, and roads.”

During the inspection leachate was observed ponded on the ground next to the concrete pad. Gallins Family
Farm Compost Facility is in violation of 15A NCAC 13B .0203(d) by not containing and managing leachate in
accordance with the approved Permit to Operate and application. Please contact Tony Gallagher, Composting
and Land Application Branch Supervisor to revise any operational changes regarding leachate management.

2. 15A North Carolina Administrative Code 13B .1406(4) states, “Leachate shall be contained on site treated
to meet the standards of the off-site disposal method.”

During the inspection leachate was observed ponded on the ground next to the concrete pad. Gallins Family
Farm Compost Facility is in violation of 15A NCAC 13B .1406(4) in that leachate was not being treated on site
to meet the off-site disposal method.

To achieve compliance with 15A NCAC 13B .0203(d) and .1406(4), maintain and operate the facility so that leachate is
collected and contained as approved in the Permit to Operate. Grade around the concrete pad to allow stormwater to
discharge into the vegetative filter consisting of fescue and orchard grass.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 6

3. 15A North Carolina Administrative Code 13B .1406(8)(A) Operational Requirements for Solid Waste Compost
Facilities states, “Signs providing information on waste that can be received, dumping procedures, the hours during
which the site is open for public use, the permit number and other pertinent information shall be posted at the site
entrance”.

During the inspection it was observed proper signage was not posted on the property identifying permit number,
prohibited materials and emergency contact information. Gallins Family Farm Compost Facility is in violation
of 15A NCAC 13B .1406(8)(A) by not posting the required signage. Mr. Gallins has acquired a quote for proper
signage. A proof of the signage was provided after the inspection. The Gallins stated that once the proof is
approved the turnaround time for the sign is 3-4 days.

4. 15A North Carolina Administrative Code 13B .1406(8)(C) Operational Requirements for Solid Waste Compost
Facilities states, “Signs shall be posted stating that no hazardous waste, asbestos containing waste, or medical waste
can be received at the site”.

During the inspection it was observed proper signage is not posted on the property identifying permit number,
prohibited materials and emergency contact information. Gallins Family Farm Compost Facility is in violation
Ponding leachate at the NW corner of concrete pad.
Sign Proof
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 6

of 15A NCAC 13B .1406(8)(C) by not posting the required signage.

To achieve compliance with 15A North Carolina Administrative Code 13B .1406(8)(A) and 15A North Carolina
Administrative Code 13B .1406 (8)(C), install the sign once delivered.

5. 15A North Carolina Administrative Code 13B .0203(d) states, “By receiving solid waste at a permitted facility,
the permittee(s) shall be considered to have accepted the conditions of the permit and shall comply with the
conditions of the permit.”

General Permit Condition Number 5 of Permit to Operate 3005 -Compost states: “This permit is issued
based on the documents submitted in support of the application for permitting the facility identified in
Attachment 1, “List of Documents for Approved Plan,” which constitutes the approved plan for the facility.
Where discrepancies exist, the most recent submittals and the Conditions of Permit shall govern.”

The approved Gallins Family Farm Compost Facility application for a permit to operate a proposed
small type 3 solid waste compost facility dated September 4, 2015 (Attachment 1, DIN 22584, Page 9) Site
Security states: “Fences will be utilized to exclude pests, animals, and thieves”.

At the time of the inspection no fences had been installed. Mr. Gallins stated that they have future plans to
install fencing. To achieve compliance either update or revise the application to remove this requirement or
installing fencing by November 30, 2016.

6. 15A North Carolina Administrative Code 13B .0203(d) states, “By receiving solid waste at a permitted facility,
the permittee(s) shall be considered to have accepted the conditions of the permit and shall comply with the
conditions of the permit.”

General Permit Condition Number 5 of Permit to Operate 3005 -Compost states: “This permit is issued
based on the documents submitted in support of the application for permitting the facility identified in
Attachment 1, “List of Documents for Approved Plan,” which constitutes the approved plan for the facility.
Where discrepancies exist, the most recent submittals and the Conditions of Permit shall govern.”

The approved Gallins Family Farm Compost Facility application for a permit to operate a proposed small
type 3 solid waste compost facility dated September 4, 2015 (Attachment 1, DIN 22584, Page 10) states:
“Environmental (Vectors, Weather, Odors, Etc.)”, “GFF composting operation dedicated time and resources to
minimize undesirable environmental conditions on site. Undesirable conditions include dust, vectors, and odors.
In the event of dust problems, Gallins will wet roads, windrows, staging areas, trucks, and any other areas or
equipment. Water is available on site and throughout the property. Pest related problems will be addressed by
utilizing IPM, integrated pest management. IPM strategies include eliminating pests by preventing entry with
fences and other means, eliminating food sources, and disrupting life cycles (insects) mechanically and effective
chemical controls.

Item 10 of Attachment 3 of the “Permit to Operate” dated September 4, 2015 (DIN 22583) states: “The
facility must be operated in a manner that reduces the potential for vector attraction.”

During the inspection an abundance of vectors were observed consisting of various insects and birds attracted to
the active windrows. By not managing vectors in accordance with the approved application Gallins Family Farm
Compost Facility is in violation with 15A North Carolina Administrative Code 13B .0203(d).

To achieve compliance with 15A North Carolina Administrative Code 13B .0203(d), ensure that sufficient carbonaceous
material is available on site for composting processes and utilize the approved IPM, integrated pest management plan as
detailed in the approved “Operations Plan” dated September 4, 2015 (DIN 22584) page 10 Section “Environmental
(Vectors, Weather, Odors, Etc.).
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 6

ADDITIONAL COMMENTS
1. The facility is permitted as a small, Type 3 Solid Waste Compost Facility. The facility operated as a
demonstration project prior to the issuance of the permit. This is the first inspection of the facility.

2. All access roads were in good operational condition.

3. The 100-foot buffer is being maintained between the onsite well and compost areas.

4. The facility is being operated and maintained with sufficient dust control measures to minimize airborne
emissions to prevent dust from becoming a nuisance or safety hazard.

5. Two windrows were in process on the concrete pad during the inspection. Three windrows had met PFRP and
were curing in the field. A pile of finished product was on the concrete pad for purpose of capping in-process
windrows.

6. The two windrows in-process had visible waste and flies. Finished compost was placed on the tops of these
windrows as a “cap” to control odors. During the inspection odors were not detected at the property boundary,
however, odors were detected around the compost piles in process and the leachate containment system. To be
effective in controlling odors and to assist in the control of flies the cap should be extended to one-third of the
height of the windrows and should be at least 4” to 6” thick.

7. The windrows appeared to be maintained in accordance with the size requirements of less than 12-feet high and
16-feet wide. The finished product was less than 30-feet high and 50-feet wide.

8. A waste distribution letter was issued by Tony Gallagher, Composting and Land Application Branch Supervisor
on January 12, 2012.

9. Records Reviewed:
 The current permit and approved operations plan are readily available for review.
 Man made inert tests were performed on 9-15-15, 3-5-16 and 8-1-16. Compost was screened to ¼”
size and smaller which resulted in 1% man made inerts. Please insure composite samples are taken at
a depth of two to six feet into the pile from the outside surface of the pile.
 Temperature logs reviewed from 7-1-16 to 8-15-16. Temperatures appeared to be maintained at or
above the required temperature. Ensure documentation of temperatures, moisture levels, and aeration
intervals are maintained.
 Volume records were reviewed. The facility is operating within the volume limit of 1000 cubic yards
per quarter and less than 2,000 tons per year.
o 1st Quarter – 509.4 cubic yards
o 2nd Quarter – 575.6 cubic yards
o FY 2015-2016 – 964.80 tons
 The complaint investigation form was reviewed. Documentation was provided for an investigation
on an odor complaint received on August 8, 2016. No mixing or turning actions were taking place
at the facility. No odors were not detected at the complaint site. The temperature was 85 degrees
with predominate NE wind 0-10 MPH. Mr. Gallins will ensure turning or mixing is not taking place
when the wind direction is out of the NW.
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 6 of 6

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

_____________________________________ Phone: [phone]

Kim Sue
Environmental Senior Specialist
Regional Representative

E-mailed on: Peter and
Lyndsy Gallins on August 26,
2016 by: Kim Sue
X Email Hand delivery US Mail Certified No. [ _]

Copies:
Tony Gallagher, Composting & Land Application Branch Supervisor – Solid Waste Section
Jason Watkins, Field Operations Branch Supervisor – Solid Waste Section
Deb Aja, Western District Supervisor - Solid Waste Section
Jessica Montie, Compliance Officer – Solid Waste Section
Susan Heim, Environmental Senior Specialist – Solid Waste Section