1906_INSP_20191211

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: Chatham
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 19-06
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: December 11, 2019 Date of Last Inspection: January 19, 2018
FACILITY NAME AND ADDRESS:
McGill Environmental Systems of North Carolina, Inc. – Merry Oaks Large Type 4 SWC Facility 634 Christian Chapel Church Road New Hill, NC 27562
GPS COORDINATES: Lat.: 35.63591 Long.: -79.00802 FACILITY CONTACT NAME AND PHONE NUMBER:
McGill Environmental Systems of North Carolina, Inc. – Merry Oaks Facility Nick Kranz, Site Manager
w. 919-362-1161 c. 919-817-6655 f. 919-362-1141 [e-mail]
FACILITY CONTACT ADDRESS:
McGill Environmental Systems of North Carolina, Inc. – Merry Oaks Large Type 4 SWC Facility
Nick Kranz, Site Manager 634 Christian Chapel Church Road
New Hill, NC 27562
PARTICIPANTS: Chuck Kirchner, Environmental Senior Specialist – Solid Waste Section (SWS) Misti Benchabbat, Compliance Manager - McGill Environmental Systems of North Carolina, Inc. Nick Kranz, Site Manager - McGill Environmental Systems of North Carolina, Inc. STATUS OF PERMIT:
Permit to Operate (PTO) issued June 29, 2016 PTO expiration date December 8, 2020
PURPOSE OF SITE VISIT: Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS: None OBSERVED VIOLATIONS:
None
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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ADDITIONAL COMMENTS
On December 11, 2018, Chuck Kirchner met with Misti Benchabbat and Nick Kranz to conduct a comprehensive inspection of the McGill Environmental Systems of North Carolina, Inc. – Merry Oaks Large Type 4 SWC Facility on Christian Chapel Church Road in New Hill, Chatham County.
1. The facility is a Large Type 4 Solid Waste Compost (SWC) Facility. It produces compost from industrial and municipal residuals and sludges, grease trap waste, and food and agribusiness wastes and from a variety
of bulking agents: wood ash, yard waste, wood mulch, tobacco waste, sawdust, etc. (see Operations Plan pg 13) and additional materials as approved by the Solid Waste Section (SWS). 2. Material is received from counties within North Carolina and from Virginia.
3. The facility is in operation Monday through Friday 8:00 am to 5:00 pm and Saturday 8:00 am to noon. 4. The facility permit, site plan, and operations plan were discussed. 5. Compost is sold in bulk to landscape supply businesses, grading companies, and to the agribusiness community. 6. The facility building is ~ 112,500 ft2.
7. Composting is conducted within the facility building. Feedstocks are off-loaded into a pit at the south end
of the building. High carbon bulking material, stored outside, is brought into the pit through a side door. The feedstocks and bulking materials are mixed. The mixed material is stockpiled within the pit area until enough is available to fill an active compost bay.
8. The mixed material is placed in positive aeration bays to meet process to further reduce pathogens (PFRP). Each active compost bay is enclosed on three sides and has a reinforced polyethylene laminate tarp that remains in- place across the open portion of the bay. 9. When the material has met PFRP it is screened by a dedicated screener located within the building and placed in bays to meet vector attraction reduction (VAR). 10. Material removed from the active compost bays, that is awaiting VAR and has not been screened, is stockpiled in one of two bays in the building. The area also contains the dedicated screener and an additional VAR bay. 11. Approximately 50 percent of the material that has met VAR is returned to the active compost process (as a cover layer) and to the mixing and bulking pit (to include overs from the screening process) to aid in attaining PFRP.
12. Material is considered cured after meeting VAR. Cured product is screened by a dedicated screener. The screener and feed-hopper are located within the building at the north end. The screened material deposits outside of the building onto a concrete pad.
13. At certain times of the year material that has met VAR and has not been screened is stockpiled outside in operational areas until screened. 14. Screened compost is considered finished product. Finished product is stockpiled outside and commonly
sold at a dedicated storage area. 15. The facility has 10 individual active compost bays (Nos. 1, 3, 5, 7, 9, 11, 13, 15, 17, and 19) and a triple-wide bay/curing area (constituting what would be bay Nos. 21, 23, and 25) and two additional curing bays – No. 18 and 20. 16. Each bay has a positive aeration fan (three fans in the triple-wide bay curing area).

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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17. An active compost bay is constructed with a layer of wood chip, seven feet of mixed material to be composted, and one foot of material that has met VAR along the front of the pile, facing the open end of the bay.
18. A front-end loader combines materials in the mixing and bulking pit and transfers it to the active compost bays. When material has met PFRP, a second front end loader transfers it to be screened and places it in curing bays to meet VAR. When material has met VAR, a third front end loader transfers it to be screened and manages the
compost on site.
19. Ms. Benchabbat stated that each front-end loader is dedicated to a prescribed operation and that if secondary use is required the front end loader’s bucket will be decontaminated. 20. The mixing and bulking pit and the active compost bays exhaust fans route to a biofilter [unit] located outside, adjacent to the building. 21. There used to be five biofilters which have been combined into three biofilters. The biofilters have maintained the same capacity through this change. The biofilters are constructed atop a pad consisting of soil-cement [clay, fly ash, lime, and concrete]. 22. The biofilters consist of a layer of wood chip, perforated pipe, a layer of compost, and a second layer of wood chip. 23. Ms. Benchabbat stated that the biofilter media was replaced in August 2019. 24. A maintenance pathway (an area that does not contain filter media) abuts each biofilter. Each biofilter is ~ 80’ x 80’ x 5’. 25. Active compost bay groups Nos.: 1, 3 and 5, Nos.: 7 and 9, Nos.: 11 and 13, and Nos.: 15, 17, and 19 each
exhausts through a manifold to one of four biofilters and the mixing and bulking pit exhausts to a dedicated biofilter. The VAR bays do not exhaust to a biofilter. 26. There is a total of 19 fans serving the compost process: 14 positive aeration and 5 negative aeration (mixing
and bulking pit, PFRP, and VAR).
27. The facility has three positive aeration fans serving the material that has met PFRP screening process (prior
to VAR) and the adjacent open area. The open area constitutes what would be the even numbered bays.
28. High carbon nitrogen ratio bulking material is stored outside behind the building. Clean wood and yard
waste is ground ~ every 4 to 6 weeks. A portable grinder is brought on site to grind the material. Ms. Benchabbat stated that there is ~ 2,500 tons of bulking material on site. 29. Stockpiling of high carbon ratio feedstocks and finished product shall be limited to 50’ in width x 30’ in height. 30. Sludge is off-loaded directly into the mixing and bulking pit. 31. The facility 120,000-gallon sludge aboveground storage tank (AST) has been decommissioned and emptied of any liquids. Mr. Kranz stated that the tank will be disassembled and any remaining
sediment/sludge remaining at the bottom of the tank will be re-incorporated into the compost mix. 32. The facility maintains throughput records. The amount and type of material received from January 2, 2019 through December 11, 2019 is 70,271.07 tons of feedstocks and bulking materials. 33. The amount of finished compost on site as of December 11, 2019 is 14,000 yd3. 34. The facility annual report (FAR) was received by the SWS dated July 23, 2019. Facility material received for July 1, 2018 through June 30, 2019 is 89,787.68 tons. The amount of compost produced and used internally or not sold to the public is 29,441.78 tons. The amount given away is 1,387.91 tons.
35. The facility produces Grade A compost. An information pamphlet is provided for customers in the office and on- line material is available at the facility website: www.mcgillcompost.com. The customer product manifest has a caution note for proper use. 36. The facility uses a program from the University of Maine to monitor bulk density, C:N ratio, and moisture content. Moisture content is verified by hand. 37. Compost bay temperature records for PFRP and VAR were observed for 2019.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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38. Temperature probe calibration records were observed from December 18, 2018 through December 23, 2019. Six manual temperature probes are calibrated then compared to 16 active compost bay electronic temperature probes.
39. Mr. Kranz stated that the facility obtains samples for analysis from screened cured compost. The material sampled is kept separate from compost stored for sale.
40. The facility had total metals analysis conducted by A&L Great Lakes Laboratories, Inc. in Fort Wayne, IN and is no longer using Pace Analytical Services, Inc. in Eden, NC for this purpose. Records were observed for January 2, 2018 through November 6, 2019. No exceedances were noted.
41. The facility had total metals, pathogens (fecal coliform and salmonella), total nitrogen, and manmade inerts analysis also conducted by A&L Great Lakes Laboratories, Inc. in Fort Wayne, IN. Records were observed for January 2, 2018 through November 6, 2019. No exceedances were noted. In June of 2019 the laboratory stopped testing for fecal coliform and only tested for salmonella. Samples may be tested for both but are only required to test for either fecal coliform or salmonella under the permit.
42. The facility has a 20,000-gallon water tank available for yard maintenance and fire prevention. 43. The facility has a water tank trailer used for dust control. 44. Twice a day the facility applies ACF 32 odor treatment directly to the mixing and bulking pit using the water tank trailer. 45. The facility has a BAT odor control system that will be activated if there is significant odor and if other control methods have been unsuccessful. 46. The facility maintains an odor management log. No additional complaints have been received since October 7, 2017.
47. During the inspection, there was no odor detected at the facility boundary. 48. The facility has a stormwater discharge National Pollutant Discharge Elimination System (NPDES) General Permit NCG240000, Certificate of Coverage NCG240005, effective: 11/01/19 – expiration: duration of general permit. 49. Effective November 1, 2019 15A NCAC 13B .1406 (19) (a) states in part that this facility “shall have an operator, supervisor or manager trained in accordance with the requirements in G.S. 130A-309.25.” Training requirements must be achieved and maintained by the US Composting Council Certification Commission or equivalent and this training shall be required every five years. 50. Per 15A NCAC 13B .1406 (19) (d) The above requirement shall be met by this facility within three years of the readopted rule date of November 1, 2019. 51. Certificate of Completion for the Compost Operations Training Course, conducted by the Composting Council Research and Education Foundation, was observed for Nick Kranz dated September 12-16, 2016. This is satisfactory for the above requirements. 52. 15A NCAC 13B .1406 (19) (b) & (c) states “Owners or operators shall provide annual training for facility staff, including a review of the operations plan and permit documents. Documentation of training required in Sub-items (a) and (b) of this Item shall be maintained at the facility and made available to the Division upon request.” 53. The facility has three stormwater retention ponds.
54. The facility is required to prevent the accumulation of stormwater on storage areas, processing areas, and
access roads. No accumulation of stormwater was observed this inspection. 55. There was no indication of erosion or runoff.
56. Leachate from the compost process shall remain in the building. 57. The Moncure Fire Department can be contacted to address an emergency at the facility.
58. Access roads are of all-weather construction. 59. The facility is secured by a locked gate. 60. The facility has proper signage.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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61. The PTO expiration date is December 8, 2020. 62. The PTO renewal application shall be submitted to the SWS by August 8, 2020. Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: [phone] _ Chuck Kirchner Environmental Senior Specialist Regional Representative
Sent on: December 23, 2019 X Email Hand delivery US Mail Certified No. [ _]

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