3424_INSP_20170404

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 9

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: April 4, 2017 Date of Last Inspection: January 26 and February 7, 2017

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: [phone] or 336-962-0353 (mobile)
Email address: [e-mail]

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
Ming-Tai Chao, Permitting Engineer – Solid Waste Section
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:
Partial Inspection

STATUS OF PAST NOTED VIOLATIONS:

1. CORRECTIVE MEASURES IN PROGRESS: 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.” The storm drain,
located between the covered tipping floor and the picking line, had been capped and cemented over, thus
eliminating one route of leachate leaving the facility. Mr. Baker explained that water that had been draining to this
spot was now being pushed onto the covered tipping floor and directed to the trench drain that runs into the public
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 9

sewer line. Because waste comes into contact with water along the rest of the cement pad between the covered
tipping floor and the picking line, leachate is still being produced that does not flow to the trench drain. A plan to
collect or eliminate the leachate produced in this area is required. Mr. Chao provided Mr. Baker with some
options to consider. As stated in the previous inspection report and Notice of Violation, dated March 21, 2017, the
deadline for compliance is April 21, 2017.

2. RESOLVED: 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.” The recovered materials container stalls that
are staged below the picking line were observed to be free from accumulated waste. Mr. Baker stated that,
following the previous inspection, the containers had been removed and the entire area cleaned. He added that a
procedure had been instituted that, when a container is removed, the stall and surrounding area are cleaned of all
debris prior to the replacement container being set.

3. RESOLVED: 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.” No waste was observed to have exceeded the covered limits of the tipping floor or picking line, except
the waste that was positioned next to the conveyor ready to load. Mr. Baker stated that any waste in this loading
area is stored in the covered tipping area at the end of each work day. The pile of processed waste that had been
observed outside the covered area at the north end of the picking line had been removed. Mr. Baker stated that, as
it accumulates, waste that will not be processed further is loaded directly into a transfer trailer; and, the transfer
trailers are tarped at the end of every working day. The unprocessed waste pile had been removed from the inert
debris/LCID area. Mr. Baker stated that this area is now used as tipping area only for clean loads of inerts that
will be stockpiled for crushing. The waste drywall had been removed from the area to the east of the inert debris
stockpile. Mr. Baker stated that it had been processed and stored in the tarped gypsum stockpile, located to the
west of the inert debris stockpile.

4. RESOLVED: 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.” Mr. Baker stated that operating procedures had been implemented to
secure transfer trailers containing waste with a watertight tarp at the end of every working day, and to ensure that
only trailers that are intact and free from leaks are used to store and transport waste.

5. RESOLVED: 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.” No fugitive dust emissions were observed
at the facility during this inspection. Mr. Baker stated that procedures are now in place to halt operations when
wind causes fugitive dust. He added that operating procedures now include adding water to waste prior to loading
it onto the conveyor or into the trommel as required to limit dust emissions. Mr. Baker also stated that any water
used for the purpose of moistening the waste would be directed to the trench drain for proper disposal.

6. CORRECTIVE MEASURES IN PROGRESS: 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.” Mr. Baker stated
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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that all staff had received training about the requirement for cleaning up trash and litter throughout the facility
prior to the end of every working day. The fence lines, access roadways and trailer loading ramp area were
observed to have been cleaned of windblown litter. Vegetation that had been allowed to grow up in these areas
had been mown, providing easy access for removing litter daily, as required. The roadside ditch in the area of the
South Site had been cleaned of windblown trash as well. However, an accumulation of windblown litter was
observed in the trees surrounding the South Site and along the toe of the side slopes of the debris piles on the
South Site.

7. CORRECTIVE MEASURES IN PROGRESS: 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.” Mr. Baker stated that
Abbey Green, Inc. will ensure that all material on the South Site is processed and removed by the June 30, 2017
deadline specified in the Notice of Violation dated March 21, 2017.

8. CORRECTIVE MEASURES IN PROGRESS: 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 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. Mr. Baker stated that Abbey Green, Inc. will ensure that all material on the South Site is processed
and removed by the June 30, 2017 deadline specified in the Notice of Violation dated March 21, 2017.

OBSERVED VIOLATIONS:

1. 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
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 Leased Area
will be used only for mixing and curing and product storage.

Abbey Green, Inc. and Hans Holdings LLC are in violation of 15A NCAC 13B .0203(d) for conducting
grinding operations on the Leased Area.

During the inspection on April 4, 2017, wood waste grinding operations were observed to be underway on the
Leased Area. Immediately cease operations on the Leased Area until such time as a permit modification
that includes this activity has been approved by the Solid Waste Section.

ADDITIONAL CORRECTIVE ACTIONS REQUIRED:

By April 21, 2017, as specified in the Notice of Violation dated March 21, 2017, Abbey Green, Inc. must
submit a plan to Ming-Tai Chao, Permit Engineer, Solid Waste Section that includes:
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 9

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;
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, 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. At the outset of this inspection, Mr. Baker provided a letter, addressed to Susan Heim and dated April 3, 2017,
in response to the inspections of January and February 2017 and to the Notice of Violations dated March 21,
2017. Mr. Baker’s letter was reviewed and discussed during this inspection, and the points made in it addressed
in this inspection report.
2. Only one employee currently holds a SWANA Transfer Station Operations Specialist certification: Ray M.
Livermore. Mr. Baker provided copies of documentation that indicated Heather Varner had attended a Transfer
Station Operations Specialist course in Albemarle on March 23-24, 2017; and, that he had attended a Landfill
Operations Specialist course in Waynesville on March 8-9, 2017. Certificates had not yet been received for
either individual.
3. No waste screening records were reviewed during this inspection. However, Mr. Baker stated that he had
redesigned the waste screening forms and had a process in place to ensure they were kept in order and up to
date, and that they included the disposition of any unacceptable wastes presented for disposal.
4. Facility access roads are of all-weather construction and observed during this inspection to be well maintained.
5. The area surrounding the retention basin, situated to the northwest of the scale house, had been bush-hogged
and cleared of windblown trash and debris, and trash had been removed from the basin as well. Mr. Baker stated
that windblown trash is now collected from this area at the end of every working day, as required.
6. The covered tipping floor was not inspected due to time constraints. At a future inspection, waste will 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
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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removed so that the tipping floor can be inspected for damage and pervious areas.
7. The trench drain located, on the western side of the covered tipping floor had been cleared of sediment and
debris. However, the drain itself has been modified from the original design. A request for review of the
modified trench drain included in the leachate collection system must be submitted to Ming-Tai Chao by
April 21, 2017, as specified in the Notice of Violation dated March 21, 2017.
8. Ensure that the trench drain is cleaned as often as necessary to ensure that it functions properly, but at
least daily.
9. Permanent edge of waste markers had been installed at the four corners of the LCID landfill. Side slopes of the
LCID were too steep to walk on or to operate equipment on, and had no vegetative cover established on them.
Mr. Baker stated that the working face of the LCID is covered at least every 30 days.
10. Mr. Baker stated that his research into the closed LCID landfill indicated that the fill material had been
generated on the property and occupied less than ½ acre. This would suggest that the old landfill was closed in
accordance with NC General Statute 130A-301.1.
11. Inert debris is collected and crushed on the LCID landfill area.
12. No unacceptable waste was observed in the inert debris stockpile during this inspection. Mr. Baker stated that
his staff was more thoroughly screening inert debris loads to ensure that unacceptable waste was removed prior
to adding the inerts to the stockpile.
13. Crushing operations had been completed following the previous inspection. A stockpile of crushed concrete was
observed to the west of the inert debris collection area.
14. The material being stockpiled on the South Site, described by Mr. Baker as being composed mainly of soil,
sand, rock and gypsum, had been mostly covered with what appeared to be soil. Some of the tall piles of
material had either been removed or spread out on the site. Mr. Baker stated that none of the material had been
removed at this point, but that it would all be processed and removed by the June 30, 2017 deadline specified in
the Notice of Violation dated March 21, 2017. At the time of this inspection, 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 30’ at the eastern edge. The northern, eastern and southern side slopes of this stockpiled material were
uncovered and too steep to walk on or to allow the use of equipment on, thus rendering the outside perimeter of
the stockpile area inaccessible. The uncovered material was observed to contain substantial amounts of plastics,
metals and other wastes. Large amounts of what appeared to be MSW and windblown litter were observed all
along the toes of these slopes, and windblown litter was observed in the trees that occupy the area directly north
and east of the South Site.
15. Mr. Baker stated that a granite outcrop exists under the material stockpiled on the South Site. He expressed his
intention to survey that outcrop after having brought the site back to its natural topography by removing all of
the stockpiled material. Please discuss this granite feature with Ming-Tai Chao, Permit Engineer, to
address any environmental impact that could result from waste and the leachate it produces having a
direct conduit to the aquifer through the granite.
16. The operations occurring on the South Site do not appear to be covered in the facility Permit to Operate.
17. The large stockpile of wood pallets and other clean wood waste observed on the concrete pad north of the
covered tipping floor during the previous inspection had been removed.
18. The parcel directly to the north of the main operations area (PIN 6833-53-3585.00), identified as the North Site
in the Operations Manual, is dedicated to wood waste stockpiling and processing. Mr. Baker stated that grinding
operations had taken place twice since the previous inspection. Stockpiles of processed wood waste were
observed to be smaller and spread out across the North Site, thus providing access to all areas.
19. The North Site is situated above a creek. The creek is protected by means of a berm, constructed along the south
side of the site that is designed to keep the unprocessed and processed wood wastes confined. Mr. Baker stated
that this berm had been repaired. However, no real change in the berm was observed and wood waste was still
present on the slope leading to the sediment trap and riparian area.
20. Mr. Baker explained that the North Site had been filled and leveled with beneficial fill in order to accommodate
the wood waste operations. The uncovered portion of the slope of this fill area was very steep and appeared to
contain materials other than those permitted as beneficial fill, including plastics, metals and wood.
21. Roll-off containers owned by various customers are stored directly to the west of the wood waste area, until
retrieved and removed. This area was observed to have been cleared of windblown litter. Mr. Baker pointed out
a container that was being used to store scrap tires removed from a customer’s loads. The container held several
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 6 of 9

scrap tires, some on rims, and had a tarp strapped over a portion of the top. However, the tarp did not prevent
rain from entering the container or make the container watertight, as required. Ensure that all scrap tires are
stored in covered, watertight containers.
22. The parcel (PIN 6833-43-5224.00) identified in the Operations Manual as the Leased Area is located to the west
of the container storage area and is being leased by Abbey Green from Hans Holding LLC. Engineered wood
waste grinding operations were observed to be taking place on the Leased Area, and several stockpiles of
processed wood waste were located on this site as well. Mr. Baker estimated that 6,000 cu. yds. of processed
and unprocessed wood waste had been relocated to this leased parcel from the North Site. This is not
consistent with the current Operations Manual.
23. In a letter addressed to Susan Heim, dated March 28, 2017, Mr. Baker presented his plans to move wood waste
operations to the Leased Area, and stated that the material on the Leased Area meets the statutory requirements
of a recovered material. In response, the letter does not clearly demonstrate how these statutory requirements
will be met. Approval of these activities by the Solid Waste Section is required.
24. Mr. Baker stated his intention to move the inert debris stockpile and crushing operations to the Leased Area by
October 2017. This is not consistent with the current Operations Manual.
25. A plan that includes the 10 elements specified in the Notice of Violation dated March 21, 2017, must be
submitted to Permit Engineer Ming-Tai Chao by April 21, 2017.

Concrete pad and covered picking line with roll-off containers
staged underneath for collecting sorted recyclable materials.
(4-4-17 photo)
Roll-off container stall under covered picking line. (4/4/17
photo)
Trench drain on covered tipping floor cleaned of sediment
and debris. Note design modifications.
Storm drain, located between covered tipping floor and
covered picking line, capped and cemented over.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 7 of 9

Slope of North Site fill area adjacent to sediment trap and
riparian area. Some wood waste has been removed from the
slope, but the berm appears to be unchanged. (4/4/17 photo)
View of the slope of North Site fill area. (1/26/17 photo)
View of the inert debris stockpile with the crushed concrete
stockpile visible in the background.
Properly tarped gypsum stockpile in background. Foreground
is the area that formerly contained the palletized waste
drywall.
Entrance to South Site with waste piles on either side covered. Waste visible at the toe of the eastern slope of the South Site -
note windblown trash in trees.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 8 of 9

Loading area for picking line seen at right. Note the raised area on which waste is placed for loading. Per Mr. Baker,
water from this area is pushed to the covered tipping floor's trench drain. Water on the lower area is currently directed
to the storm drains.

Eastern slope of south site - note waste visible along entire toe of slope.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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Please contact me if you have any questions or concerns regarding this inspection report.

______________________________________ Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative

Sent on April 10, 2017 to
Randall Baker – Abbey
Green, Inc. and Overdale
Holdings, Inc.

X Email Hand delivery US Mail Certified No.
[ ]

Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section
Deb Aja, Western District Supervisor - Solid Waste Section
Jaclynne Drummond, Compliance Hydrogeologist – Solid Waste Section
Jessica Montie, Compliance Officer – Solid Waste Section
Ming-Tai Chao, Permitting Engineer – Solid Waste Section