3004Compost2014_INSP_20170614

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: Davie
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: 3004-Compost-2014
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: 6-14-17 Date of Last Inspection: 6-24-16

FACILITY NAME AND ADDRESS:
Davie County Compost Facility
End of Lee Jackson Drive
Advance, NC 27006

GPS COORDINATES: N: 35.584354 W: 80.300392

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Eric Wallace, President
Telephone: [phone]
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
Same as above

PARTICIPANTS:
Dean Lentz, Director of Operations, Wallace Farm, Inc.
Michelle Lambert, Office Manager, Wallace Farm, Inc.
Kim Sue, NCDEQ - Environmental Senior Specialist - Solid Waste Section
Deb Aja, NCDEQ – Western District Supervisor – Solid Waste Section

STATUS OF PERMIT:
The Permit to Operate a Large Type 3 Solid Waste Compost Facility was issued on November 24, 2015 and shall
expire on November 17, 2019.

PURPOSE OF SITE VISIT:
Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
On February 21, 2017, a Notice of Deficiency was issued to the Wallace Farms -Davie Compost Facility for a
violation of 15A NCAC 13B .0203(d) and a violation of 15A NCAC 13B .0402(1) for failure to minimize odors at the
facility boundary on February 9, 2017. To correct the violations the facility was required to immediately take any
actions necessary to ensure any odor generated by the facility be minimized before leaving the property, and, within
14 days of receipt of the NOD provide a detailed report summarizing any actions taken since February 9th as well as
all specific actions proposed by the facility for addressing odorous emissions from the facility. The report was
required to include but not be limited to the removal of additional potential odorous feedstock material, operational,
mechanical, chemical or biological measures that have occurred and/or would be proposed as maximum feasible
controls for the reduction control of odorous emissions from the facility. Chemical measures proposed were required
to include a summary of the proposed effectiveness, a Safety Data Sheet, if available, a list of contents, and the
potential impact on facility generated leachate and groundwater.

On February 28, 2017, Eric Wallace, President – Wallace Farm, Inc. submitted a report to the Section in response to
the NOD with actions taken to minimize odors prior to February 9, 2017 when the violations were noted and a
proposal to experiment with wood ash or to consider a forced air/bin composting system. No additional plans were
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 2

proposed. On March 29, 2017, a meeting was held in Raleigh with Mr. Wallace, Dean Lentz, and NCDEQ Division
of Waste Management and Division of Environmental Assistance and Customer Service staff to discuss the report and
actions going forward. During the meeting an updated plan was requested to be submitted with details to address
odors (which were not included in the February 28, 2017 report) as required by the NOD. On April 10, 2017 Mr.
Wallace submitted an updated plan to the Section. The updated plan restated items previously submitted, included a
proposal to hire Dr. Bob Rubin, with A.R Rubin and Associates, to conduct an evaluation and report findings and
make recommendations on how to further minimize compost smells, to hold a meeting on April 14, 2017, with Steve
Diddy, Business Development Director at ECS – Engineered Compost Systems about alternative methods of
composting that ECS has to offer, and to invite other NC composters to visit the facility to provide feedback.

Corrective measures are in progress to resolve the violations noted in the February 21, 2017 NOD. The submittals do
not fully provide detailed information requested in the NOD and in the meeting to minimize odors at the facility going
forward. Within 30 days of this report, please provided the information itemized below. Additional measures may be
required.

1. Wood ash was stockpiled at the facility and in use on top of compost rows. Provide a summary of the
proposed effectiveness, a Safety Data Sheet, if available, a list of contents, and the potential impact on facility
generated leachate and groundwater. As requested by Donna Wilson on October 23, 2015, the generator
source(s) of the wood ash should be identified and an analytical analysis (total metals) from at least four
sampling events must be provided for each source. The storage of the ash and methods to prevent/limit
surface water run-on and run-off must be provided. Samples collected for routine compost analytical testing
must be collected after the ash is added. Please contact Donna Wilson at [phone] with any questions.

2. Provide the report by Dr. Rubin and actions taken or planned by the facility based on his recommendations
and findings. Please provide the report as soon as it is available if not received by Wallace Farm, Inc. within
30 days.
3. Provide actions taken or planned by the facility based on the conference call with Mr. Diddy.
4. Provide actions taken or planned by the facility based on recommendations and feedback from any
composters that responded to the invitation to visit the Davie County Compost Facility.

OBSERVED VIOLATIONS:
None

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.
Wood ash stockpile. Close-up of wood ash.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 3

ADDITIONAL COMMENTS
1. Proper signage was observed at the entrance to the facility.
2. The access roads to the facility, office/scale house and roadway to the mixing pit were in good condition.
3. It appears windrows were being maintained at/near the approved size as stated in the approved operations
plan.

4. Due to recent rainfall, rutting from heavy equipment was observed in between several windrows.
5. Leachate and/or surface water was observed in ruts between several windrows and along one roadway.
Ensure that leachate does not run off with storm water by constructing berms or by implementing other
measures to capture run off. Roadways in between windrows may need to be regraded after heavy rain
events. Sawdust or other carbonaceous material may need to be utilized to prevent leachate from flowing
from windrows during and after heavy rain events.
6. The facility was actively receiving feed stock during the inspection. No unacceptable waste was observed in
the pit area for incoming materials.
7. Mr. Lentz stated that facility staff continue to cover windrows with carbonaceous materials and mature
compost within 30 minutes of turning.
8. Water was being pumped out of the storm water pond and being applied to windrows during the inspection to
control dust and minimize airborne emissions.
9. A slight odor was detected in between active windrows and at a windrow under construction. A stronger odor
was noted at the mixing pit. (Grease trap waste was being delivered at the time of the inspection.) No odor
was detected at the gate, office or storm water pond.

Active windrow.
Delivery of grease trap waste.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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10. The facility utilizes a meter that captures both temperature and oxygen levels in the compost windrows as
required in the approved operations plan.
11. Dr. Bob Rubin, with A.R Rubin and Associates, was on-site the week of May 22, 2017 observing the daily
operations of the facility. At the time of the inspection, facility staff had not received the report of his
findings and recommendations of how to further minimize compost smells. Mr. Lentz stated the facility
would forward the report to the Section and as of the date of this inspection report, July 14, 2017, the Section
has not received a copy of the report. Please see the status of past noted violations section of this report.
12. The bagged and bulk compost for sale is from the facility located in Huntersville. Finished material produced
at this facility is utilized for daily operation.

Records Reviewed:
13. A copy of the current permit and operations plan are maintained in the office.
14. Composite sampling records were reviewed. The most recent report was 1-12-17.
15. Temperature logs dated 5-1-17 to present were reviewed. Temperatures appeared to be maintained at or
above the required temperature.
16. Tonnage records were reviewed. The facility received 15,326.02 tons in May.

Other:
17. On July 11, 2017, an odor investigation was conducted at several locations surrounding the facility. Upon
arrival at Raylen Winery a slight compost odor was detected lasting approximately half a second and was not
detected again. No odors were detected at other locations surrounding the facility.

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

________________________________________ Phone: [phone]
Kim Sue
Environmental Senior Specialist
Regional Representative

Sent to: Eric Wallace on
7-14-17
X Email Hand delivery US Mail Certified No. [ _]

Copies: Ellen Lorscheider, Section Chief – Solid Waste Section
Jason Watkins, Field Operations Branch Head – Solid Waste Section
Deb Aja, Western District Supervisor - Solid Waste Section
Jessica Montie, Compliance Officer – Solid Waste Section
Donna Wilson, Permitting Engineer Solid Waste Section
Dean Lentz, Wallace Farms - Davie