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HomeMy WebLinkAbout3424_INSP_20170126FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 13 UNIT TYPE: Lined MSWLF LCID X YW Transfer X Compost SLAS COUNTY: Forsyth Closed MSWLF HHW White goods Incin T&P X FIRM PERMIT NO.: 3424 & N1044 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: January 26 and February 7, 2017 Date of Last Inspection: May 7, 2014 FACILITY NAME AND ADDRESS: Abbey Green, Inc. and Overdale Holdings, Inc. Transfer, Recycle, Resource Recovery and Processing Facility 5030 Overdale Road Winston-Salem, NC 27107 GPS COORDINATES: N: 36.03203° W: -80.23395° FACILITY CONTACT NAME AND PHONE NUMBER: Name: Randall Baker, General Manager Telephone: 336-785-2130 or 336-962-0353 (mobile) Email address: rbaker@abbeygreen.com FACILITY CONTACT ADDRESS: Abbey Green, Inc. 5030 Overdale Road Winston-Salem, NC 27107 PARTICIPANTS: Randall Baker, General Manager – Abbey Green Ray Livermore, Operations Manager – Abbey Green Deb Aja, Western District Supervisor – Solid Waste Section (2/7/2017 only) Ming-Tai Chao, Permitting Engineer – Solid Waste Section (2/7/2017 only) Susan Heim, Environmental Senior Specialist - Solid Waste Section STATUS OF PERMIT: LCID Landfill Notification recorded in Forsyth County November 24, 2009 Permit to Construct/Permit to Operate issued July 30, 2010 Revised Permit to Construct/Permit to Operate issued November 2, 2010 Permit to Operate – Modification issued April 27, 2011 Permit to Operate – Modification issued November 9, 2011 Current Permit to Operate issued April 13, 2016 Permit to Operate expires July 30, 2025 PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: None OBSERVED VIOLATIONS: 1. 15A NCAC 13B .0302(3) states: “Water that comes into contact with solid waste will be contained on-site or properly treated prior to discharge from the site.” FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 13 Abbey Green, Inc. is in violation of 15A NCAC 13B .0302(3) for failing to contain leachate on-site and direct it to the public sewer. On February 7, 2017, water was observed ponding in and around unprocessed waste in the main operations area between the picking line and the covered tipping area. Water that comes into contact with waste is considered to be leachate. This leachate was being directed to a storm drain located in the same area. 2. 15A NCAC 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.” Permit to Operate No. 3424, Attachment 3, PART VI: Transfer Station/Treatment & Processing Unit permit condition 20.a. states, “The tipping floor and loading area must be maintained in a clean, sanitary condition at all times and must be cleaned at least daily.” Abbey Green, Inc. is in violation of 15A NCAC 13B .0203(d) for failing to maintain the tipping floor and loading area in a clean, sanitary condition at all times. An inspection of the facility on January 26 and February 7, 2017 revealed accumulated waste and debris accumulated in and around the recovered materials container stalls that are staged below the picking line. On February 7, 2017, several containers were observed being pulled and replaced without collecting and removing the accumulated debris. 3. 15A NCAC 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.” Permit to Operate No. 3424, Attachment 3, PART VI: Transfer Station/Treatment & Processing Unit permit condition 20.b. states in part, “Waste must only be deposited on a “tipping floor” or directly into a transfer container.” Abbey Green, Inc. is in violation of 15A NCAC 13B .0203(d) by depositing drywall waste on-site in an open area rather than on a tipping floor or in a transfer container; by allowing unprocessed waste to exceed the limits of the covered tipping floor and the covered picking line; by allowing processed residual waste to exceed the limits of the covered picking line; and by depositing unprocessed waste on an open area adjacent to what appeared to be the working face of the LCID landfill. On January 26 and February 7, 2017, a large stockpile of palletized drywall waste was observed in an area located beside the access roadway just southeast of the inert debris area. The drywall was uncovered and exposed to the elements. On February 7, 2017, unprocessed waste was observed to have been deposited outside the limits of the covered tipping floor, outside the limits of the covered picking line and in an open area south of the covered tipping floor adjacent to the slope leading to the inert debris area. Also on February 7, 2017, processed residual waste was observed to have exceeded the limits of the covered picking area. 4. 15A NCAC 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.” Permit to Operate No. 3424, Attachment 3, PART VI: Transfer Station/Treatment & Processing Unit permit condition 20.c. states in part, “Waste may be stored on-site, in leak proof transfer trailers, with watertight covers, a maximum of 5 working days.” Abbey Green, Inc. is in violation of 15A NCAC 13B .0203(d) by storing waste on-site in an uncovered transfer trailer. On January 26 and February 7, 2017, the open-top transfer trailer in which processed residual waste was stored had no cover. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 13 5. 15A NCAC 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.” Permit to Operate No. 3424, Attachment 3, PART VI: Transfer Station/Treatment & Processing Unit permit condition 20.e.i. states, “Fugitive dust emissions are prohibited.” Abbey Green, Inc. is in violation of 15A NCAC 13B .0203(d) for generating fugitive dust emissions from its main operations area, picking line and trommel. On January 26 and February 7, 2017, heavy dust emissions were observed at the facility. The dust was being generated from both the picking line and the trommel operations. Strong winds occurred during both inspections and, on both dates, facility operations continued for several minutes while dust emissions were carried beyond the facility boundary. On both January 26 and February 7, 2017, after observing the conditions at the facility from the area of the office, Solid Waste Section staff advised facility staff that operations could not continue. On both dates after receiving this advice, Mr. Livermore shut down operations. Note that Section 1.12.3 of the approved Operations Manual states, “Facility operations during a particularly windy period may require that the active tipping area and sorting operations be temporarily suspended.” 6. 15A NCAC 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.” Permit to Operate No. 3424, Attachment 3, PART VI: Transfer Station/Treatment & Processing Unit permit condition 20.e.ii. states, “Windblown materials must be collected by the end of the day and no windblown material may be allowed to leave the facility boundary.” Abbey Green, Inc. is in violation of 15A NCAC 13B .0203(d) for allowing windblown materials to leave the facility boundary. On January 26 and February 7, 2017, a large amount of windblown trash was observed throughout the facility, on adjoining roadways and outside the facility fence. The windblown trash appeared to be generated from both the unprocessed waste stockpile and the picking line operations. During the ensuing winds events on both of these dates, windblown trash was observed being carried throughout the facility and beyond the facility boundary. 7. 15A NCAC 13B .0201(c) states, in part: “No solid waste management facility shall be established, operated, maintained, constructed, expanded, or modified without a currently valid permit issued by the Division for the specified type of disposal activity.” Abbey Green, Inc. is in violation of 15A NCAC 13B .0201(c) for establishing a disposal site for C&D waste without a currently valid permit issued by the Division for this specific type of disposal activity. On February 7, 2017, a large stockpile of C&D waste was observed in the area identified on the approved site plan as the South Site. Mr. Baker described this stockpile as being made up of “trommel overs,” materials defined in the approved Operations Manual (December 2015) as, “mostly consisting of small pieces of wood, cellulose materials, and inerts.” The Operations Manual further states, “Trommel overs are generated from the processing line with two screening activities. Most of the material making up trommel overs ranges in size from ½” to 2 ½”.” The material making up the stockpile was observed to have a significant percentage of plastics, metals and other wastes that are larger than the ½” to 2 ½” size range specified for trommel overs. 8. 15A NCAC 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.” Permit to Operate No. 3424, ATTACHMENT 1, PART I: GENERAL PERMIT, general permit condition 6 states, in part, “Operation of this solid waste management facility shall be in accordance with the 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.” Permit to Operate No. 3424, ATTACHMENT 1, PART VI, TRANSFER STATION/TREATMENT & PROCESSING UNIT(S), List of FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 13 Documents for Approved Plan, includes the Operations Manual, December 31, 2015 (DIN 25646). Section 2.8 of the approved Operations Manual (December 31, 2015), Processing Area Legend, indicates that the preferred location for aging trommel-overs is the South Site. Abbey Green, Inc. is in violation of 15A NCAC 13B .0203(d) for storing material other than trommel-overs on the South Site. On February 7, 2017, the material observed on the South Site did not meet the definition of trommel-overs, specified in the approved Operations Manual as “mostly consisting of small pieces of wood, cellulose materials, and inerts.” The material was observed to contain large amounts of plastics, metals and other wastes. CORRECTIVE ACTIONS REQUIRED 1. Immediately, Abbey Green, Inc. must: a. Take steps to collect all leachate in the main operations area and direct it to the public sewer; b. Cease operations during any weather event where storm water will come into contact with waste until such time as a permanent leachate collection system is in place; c. Enact procedures specifically for cleaning the recycled materials container stalls as debris accumulates and during container removal and replacement; d. Maintain the entire main operations area in a clean and sanitary condition at all times; e. Move the palletized drywall waste to the covered tipping floor or into watertight containers and process it within 14 days, as stated in the approved Operations Manual; f. Move all processed and unprocessed waste in the main operations area to the covered tipping floor or into covered, watertight trailers or containers; g. Store waste in transfer trailers with watertight covers (Please note that waste may only be stored onsite for a maximum of 5 working days, as specified in the approved Operations Manual.); h. Implement operating procedures that will prevent dust emissions beyond the facility boundary; i. Collect and properly dispose of all windblown trash and develop and implement operating procedures that will minimize windblown trash and prevent it from leaving the facility; j. Clean out the trench drain and ensure that it is cleaned as often as necessary to ensure that it functions properly, but at least daily; k. Ensure that waste is removed from the uncovered concrete pad to a transfer trailer as it accumulates, and that transfer trailers holding waste are secured with watertight covers and maintained to ensure they are leak-proof; l. Move the stockpile of wooden pallets from the main operations area to the wood waste storage and processing area; m. Collect and properly dispose of all waste and windblown trash accumulated in and around the South Site and establish a procedure to ensure that no waste or windblown trash accumulates in these areas in the future; and, n. Repair the berm that protects the creek from the incursion of material from the wood waste area and ensure that regular preventive maintenance occurs in this area to keep wood wastes confined to the designated storage and processing area; 2. Within 30 days of receipt of this notice, Abbey Green, Inc. must submit a plan to Ming-Tai Chao, Permit Engineer, Solid Waste Section that includes: a. A request for permit modification to include the handling of the material currently being stored on the South Site, the use of an additional and currently unapproved leased property for permitted operations, and all of the changes in operation described in 1.a. through n. above; b. Either confirmation that future activities as required in the Permit to Operate and approved Operations Manual will not occur outside of the existing footprint of the covered tipping areas, the picking line and the permanent leachate collection system, or, an engineered plan for capital improvements to expand the footprint along with a construction timeline for completion once approved; FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 13 c. a request for the review of the changes made to the leachate collection system that had replaced the metal grates covering the trench drain with plywood planks; d. measures and implementation schedule to provide cover over all operational areas where waste is tipped, processed and stored; e. a procedure to ensure that containers and trailers used to store waste are leak resistant and secured with watertight covers; f. a delineation of the waste boundary for both the closed and active LCID landfills, and the timeframe for the installation of permanent edge of waste markers around both; g. a plan for the removal of the C&D waste, currently located on the South Site as described in Observed Violation #7, for further processing or proper disposal no later than June 30, 2017; h. a delineation of the area to be used for storage of the trommel overs to be stockpiled on the South Site, including information as to the amount of material to be stored (volume and tonnage), how these amounts will be calculated, and the duration for which it will be stored in this location; i. an inventory of all processed and unprocessed waste and all recovered materials currently stored at the facility; and j. an updated Operations Manual that includes the required changes to the permit and the operational procedures. Based on review of the submittal, additional actions may be required. ADDITIONAL COMMENTS 1. The facility is a C&D transfer, recycling, resource recovery and processing facility that also includes a land clearing and inert debris (LCID) landfill. 2. The facility Permit to Operate and approved Operations Manual were available and reviewed. 3. A contingency/emergency response plan for handling emergency situations and hazardous materials was posted on the office bulletin board. 4. Training records for facility staff were reviewed. Safety meetings take place monthly, and include hazardous waste recognition and waste screening procedures. Employees are required to sign training rosters at each meeting. 5. Only one employee currently holds a SWANA Transfer Station Operations Specialist certification: Ray M. Livermore. The certification expires March 25, 2018. Mr. Baker stated that he’d been unaware of this lapse, and would ensure that Mr. Livermore would be present whenever the facility was in operation until such time as other staff could reinstate their certifications. 6. Tonnage records for the period July 1, 2015 through January 26, 2017 were reviewed. Tonnage fluctuates seasonally, however records indicated that the facility averages between 115 and 130 tons per day. Mr. Baker explained the breakdown of different categories of C&D waste accounted for in the reports. 7. Approximately 9000 tons of boiler fuel are produced at the facility annually. Mr. Baker stated that this product accounts for approximately 20% of all material generated. 8. Waste screening logs were reviewed for 2016. It appeared that random inspections were being conducted frequently enough to meet the 1% minimum required. However, logs were out of order, so it was difficult to closely examine the record. It is recommended that waste screening logs be maintained in a file or binder so that order by date is ensured. 9. The site is secured by means of a gate which is locked when the facility is not in operation. 10. Proper signage was observed at the entry gate and instructional signs were posted at the scales and throughout the facility to control and direct traffic. 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 13 11. The January 26, 2017 inspection began in the facility office, located on the southeast corner of the property. The office and parking areas appeared to be neat and free from windblown litter. During the review of facility records, high winds developed. Several minutes passed while fugitive dust and windblown trash became severe. Solid Waste Section staff advised Mr. Livermore shut down the C&D recovery and processing operations in order to stop dust emissions and to prevent windblown trash throughout the site and outside the facility fence. Mr. Livermore then shut down the operations and unprocessed C&D waste was moved to the covered tipping floor for temporary storage. 12. During the February 7, 2017 inspection, a similar wind event occurred and, again, Solid Waste Section staff advised that operations had to be shut down. Mr. Livermore again shut down operations at the facility. 13. During the field portion of both the January 26 and February 7, 2017 inspections, windblown trash was evident in every area of the facility and in the office area and access roadway outside the fence. Ensure that all windblown trash is collected at the facility and properly disposed or stored prior to the end of each working day. (see Observed Violations in this report for additional information.) 14. Facility access roads are of all-weather construction and, for the most part, well maintained. However, On January 26, 2017 ponding water was observed on and around the roadway leading to the wood waste processing and storage area. On February 7, 2017, this section of roadway was observed to have been regraded to eliminate tire ruts where water had accumulated. Ensure that regular maintenance of this access roadway is performed to prevent ponding in these areas in the future. 15. The facility operates under three erosion control permits. All erosion control and water quality inspections are performed under a delegated program by Forsyth County staff. Erosion control inspections are performed monthly and water quality inspections are conducted annually. 16. A retention basin is situated to the northwest of the scale house. The basin serves as a collection point where storm water is monitored prior to being released from the site. Some trash was observed in the basin during the inspection. Ensure that trash is removed from the retention pond as part of the daily site clean-up procedure. 17. Mr. Baker stated that some processes included in the facility’s Permit to Operate are not currently being performed, including mobile home deconstruction, composting and asphalt shingle grinding. Asphalt shingles are still accepted and separated at the facility, but are currently being transported to A-1 Sandrock C&D landfill in Guilford County for further processing. 18. Trucks enter the facility and proceed directly to the scales where each load is visually examined using an overhead camera system. The scale house operator then directs the truck to a dumping location based on the contents of the load. 19. During this inspection, no trucks were observed unloading at the facility. However, unprocessed waste was observed in several locations: the covered tipping floor, the concrete pad outside the covered tipping floor, the feeding end of the picking line and adjacent to an area which appeared to be the working face of the LCID landfill. In addition, processed residual waste was observed on the concrete pad outside the limits of the covered picking line at the discharge end. (See Observed Violations in this report for additional information.) 20. The covered tipping floor could not be fully inspected on January 26, 2017 or on February 7, 2017 due to a large waste pile situated on a significant portion of the space. The area of the concrete pad that was visible showed no obvious cracks or breaches. However residual debris and sediment were observed on the floor and in the adjacent loading areas. (See Observed Violations in this report for additional information.) 21. The leachate collection system includes a trench drain located on the western side of the covered tipping floor. The drain has been completely covered with plywood planks in lieu of metal grates. Mr. Baker stated that the metal grates broke repeatedly as a result of the truck traffic on the tipping floor, and that this was the best solution for keeping the drain covered. The inspection report dated April 17 and May 7, 2014, directed Abbey Green to submit any proposed changes to the leachate collection system to the Permitting Branch for approval. The Solid Waste Section has no record of having received proposed changes to the leachate collection system from Abbey Green. 22. The trench drain which collects leachate from the covered tipping floor and directs it to the sanitary sewer was observed to be filled with sediment and debris at the time of this inspection. Clean out the trench drain and ensure that it is cleaned as often as necessary to ensure that it functions properly, but at least daily. 23. Upon arrival on both inspections dates, the picking line was operating. Quantities of waste are placed into a pile, located near the southeast end of the covered tipping floor, from which it is fed onto a conveyor belt and FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 13 into the picking operation. Stored unprocessed waste was also observed to have exceeded the limits of the covered tipping area. Waste in these areas is not covered. Liquid was present in and around the waste on the concrete pad, and leachate from these piles was observed to be flowing directly into a storm drain. 24. Containers are staged under the picking line for the purpose of collecting the segregated recyclable materials. Waste and debris were observed around the containers in the container stalls. (See Observed Violations in this report for additional information.) 25. Processed residual waste drops from the northern end of the picking line onto the uncovered concrete pad below. Waste is then moved from the concrete pad to an open-top transfer trailer staged at a loading area immediately south of the entrance gate. 26. Immediately southwest of the covered tipping floor is the area where inert debris is stored and collected and processed. On January 26, 2017 and February 7, 2017, concrete crushing operations were underway. Between the crushing operations and the covered tipping floor was an area that appeared to be an LCID landfill. A mixture of materials, including brush, soil, concrete, brick, scrap metals, Styrofoam and plastics were observed on what appeared to be the working face of the landfill. Mr. Baker explained that all of this area was the inert debris stockpile, and not a fill area. He added that, when loads are received at this location, they are required to be immediately screened for unacceptable materials before being pushed into the stockpile below. He stated that, based on the waste he was seeing in the pile, this procedure was not being followed by facility staff. a. Remove all unacceptable waste from the inert debris stockpile area and properly dispose of it. b. Ensure that any unacceptable waste is removed from inert debris loads as they are received at the inert debris stockpile area. c. Ensure that all incoming loads designated as inert debris are adequately screened at the scale house to limit the amount of unacceptable material, and that any incidental waste found is immediately removed to a container with a watertight cover. 27. A pile of residual waste was observed near the inert debris processing area on January 26, 2017. On February 7, 2017, this waste had been removed. However, on this date a residual waste pile was observed beside the crushing equipment. Ensure that residual waste produced during facility operations is collected and properly disposed of at the end of each working day. 28. An area where stockpiles of various processed materials, including crushed concrete, crushed concrete and brick, gypsum and soil, is located immediately to the northwest of the inert debris stockpile/crushing area. During the January 26, 2017 inspection, the tarp on the gypsum stockpile had been damaged by the wind. The tarp was observed to be in place as required during the February 7, 2017 inspection. 29. A large quantity of palletized waste drywall was observed in the area immediately to the southeast of the LCID/inert debris area. The stockpile is uncovered and exposed to the weather. (See Observed Violations in this report for additional information.) 30. The adjacent parcel (PIN 6833-52-3269.00), designated as the South Site on the existing site plan and located across the access road to the southeast of the main operations area, was approved for the stockpiling of trommel-overs, as described in the approved Operations Manual. Mr. Baker stated that the material being stockpiled is primarily composed of soil, sand, rock and gypsum, and will be screened to create a component of the engineered soil produced at the facility. He added that the material had been accumulating on the site for approximately six months. On February 7, 2017, the stockpile of this waste appeared to cover at least ½ an acre, beginning at grade of the access road and increasing in thickness to well over 10’ at the eastern edge. 31. Based on comparison of the current stockpile with photos of the stockpile area from the previous inspection on April 17 and May 7, 2014, it appears that the stockpile has increased in size substantially. This stockpile is highly likely to be greater than 2,000 tons, which is the maximum specified for storage of trommel-overs in the approved Operations Manual. Several large, distinct piles were located toward the southern end of the property where stray dogs were observed to be scavenging. The waste contained substantial amounts of plastics, metals and other trash. This operation does not appear to be covered in the facility Permit to Operate. 32. Please be aware that the Solid Waste Section may take action regarding materials accumulated on site. The NC General Statute 130A-309.05(c), states, in part: “In order to qualify as a recovered material, the material shall be managed as a valuable commodity in a manner consistent with the desired use or end use, and all of the following conditions shall be met: FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 13 (1) Seventy-five percent (75%), by weight or volume, of the recovered material stored at a facility at the beginning of a calendar year commencing January 1, shall be removed from the facility through sale, use, or reuse by December 31 of the same year. (2) The recovered material or the products or by-products of operations that process recovered material shall not be discharged, deposited, injected, dumped, spilled, leaked, or placed into or upon any land or water so that the products or by-products or any constituent thereof may enter other lands or be emitted into the air or discharged into any waters including groundwaters, or otherwise enter the environment or pose a threat to public health and safety. Facilities that process recovered material shall be operated in a manner to ensure compliance with this subdivision. (3) The recovered material shall not be a hazardous waste or have been recovered from a hazardous waste. (4) The recovered material shall not contain significant concentrations of foreign constituents that render it unserviceable or inadequate for sale, or its intended use or reuse. (1989, c. 784, s. 2; 1995 (Reg. Sess., 1996), c. 594, s. 9; 2015-1, s. 2(b).) 33. The roadway and ditch leading to the South Site had an accumulation of plastics, paper and other trash, as did the open area along the wood line to the north of the site. Collect and properly dispose of all waste and windblown trash accumulated in and around the South Site and establish a procedure to ensure that no waste or windblown trash is allowed to accumulate in these areas in the future. 34. A large stockpile of wood pallets and other clean wood waste was situated on the concrete pad north of the covered tipping floor. Move this stockpile to the wood waste storage and processing area. 35. The parcel directly to the north of the main operations area (PIN 6833-53-3585.00) is dedicated to wood waste stockpiling and processing. Mr. Baker stated that no composting is taking place at this time. Large stockpiles of both unprocessed and processed wood waste were observed in this area. On January 26, 2017, large areas of ponding water were observed in several locations throughout the wood waste storage area. On February 7, 2017, maintenance had been performed to the wood waste area and no ponding water was observed. a. Ensure that stockpiles are designed with access lanes and fire breaks to provide adequate access to all areas for facility staff and emergency personnel in the event of fire. b. Ensure that regular maintenance occurs in the wood waste storage and processing area that prevents water from ponding. 36. The wood waste area is located directly to the north of the main operations area and is situated above a creek. The creek is protected by means of a berm, constructed along the south side of the wood waste area that is designed to keep the unprocessed and processed wood wastes confined. On both January 26 and February 7, 2017, wood wastes were observed on the slope leading down to the sediment trap and the creek. Repair the berm and ensure that regular preventive maintenance occurs in this area to keep wood wastes confined to the designated storage and processing area. 37. Roll-off containers owned by various customers are stored directly to the west of the wood waste area, until retrieved and removed. Several of these roll-off containers were being used to store tires. Mr. Baker explained that when tires are found in customers’ loads, they are separated and stored for the customer to remove and dispose of properly. He stated that he didn’t know exactly how long tires had been accumulating in these uncovered containers, but that his customers remove the containers during their regular trips to the facility. Ensure that all scrap tires are stored in covered, watertight containers. 38. A parcel (PIN 6833-43-5224.00) located to the west of the container storage area is being leased by Abbey Green for future use as a wood and gypsum processing and storage area. Ensure that a permit modification request is submitted to the Solid Waste Section for review and approval prior to engaging in any facility operations on this parcel. 39. Operations at the facility have increased since the previous inspection in 2014. In order to fully understand the operations at the facility, the Solid Waste Section needs additional information. Provide an inventory of all processed and unprocessed waste and all recovered materials currently stored at the facility. 40. Post-inspection research was conducted to better understand the facility and its processes and waste stream. Research included a review of the facility file, previous inspection reports, annual facility reports, permitting records, correspondence and memos, available site plan drawings, tax records and best management practices for C&D recovery operations. This research was concluded on March 1, 2017. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 13 Looking west from the south end of picking line to unprocessed waste stored on and exceeding the limits of the covered tipping floor - leachate ponding on and around the blocked storm drain. Inset at upper left shows close-up of drain. Looking south between picking line and covered tipping area. Unprocessed waste can be seen adjacent to the picking line and exceeding the limits of the covered tipping floor. Water can be seen ponding in and around these two waste piles in the vicinity of the blocked storm drain. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 10 of 13 Sediment-filled trench drain on northwestern side of covered tipping floor. Plywood covers have replaced metal grates on the trench drain. Looking west from the office to the main operations area. Note processed waste pile accumulated outside of picking line roof. Large stockpile of pallets and other wood waste adjacent to covered tipping area. Uncovered waste trailer and loading dock located to the northeast of the wood waste. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 11 of 13 Recovered material container below picking line. Note condition of container and debris accumulation in and around container stall. Dust generated from the trommel and picking line on February 7, 2017. Dust and windblown trash in waste trailer loading area on February 7, 2017. View from main operations area looking east toward office and employee parking. Note windblown trash accumulated, especially on bank and fencing. Scrap tires stored in open roll-off containers. Slope leading from wood waste area to sediment trap and creek below. Wood waste has breached berm and migrated down the slope. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 12 of 13 View of South Site and stockpiled processed material from the access roadway. Dogs are scavenging on the large pile in the middle background. Debris and windblown trash between the processed material stored on the South Site and the wood line to the north. Uncovered drywall waste stockpiled adjacent to the inert debris area. Note accumulated waste and windblown trash. Crushing equipment in inert debris area with trash pile adjacent. Inert debris stockpile with brush, lumber, scrap metal and plastics. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 13 of 13 Please contact me if you have any questions or concerns regarding this inspection report. ______________________________________ Phone: 336-776-9672 Susan Heim Environmental Senior Specialist Regional Representative Sent on March 21, 2017 to Randall Baker – Abbey Green, Inc. and Overdale Holdings, Inc. X Email Hand delivery US Mail X Certified No. [7011 1570 0001 8545 5943] Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Deb Aja, Western District Supervisor - Solid Waste Section Jessica Montie, Compliance Officer – Solid Waste Section Ming-Tai Chao, Permitting Engineer – Solid Waste Section