9213_INSP_20201021

NORTH CARnLINAD_E Q�/��
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
X
SLAS
COUNTY: WAKE
MSWLF
PERMIT NO.: 9213-COMPOST- 1991
Closed
HHW
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P/
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: October 21, 2020
FACILITY NAME AND ADDRESS:
City of Raleigh, Yard Waste and Recycling Facility
Large Type 1 Solid Waste Compost Facility
900 N. New Hope Road, Raleigh, NC 27610
GPS COORDINATES: 35.78656,-78.55885
Date of Last Inspection: June 19, 2020
FACILITY CONTACT NAME AND PHONE NUMBER:
Tim Gainer, Superintendent
O: 919-250-2728 C: 919-625-3175; Timothy.Gainer(cr�,raleighnc.gov
FACILITY CONTACT ADDRESS:
City of Raleigh
PO Box 590
630 Beacon Lake Drive
Raleigh, NC 27602
PARTICIPANTS:
Davy Conners, NC DEQ — Solid Waste Section
Tim Gainer, City of Raleigh
STATUS OF PERMIT:
Permit to Operate was issued on October 18, 2012 and expired on October 18, 2017. Permit Renewal Application was
received on September 19, 2017 and is currently under review.
PURPOSE OF SITE VISIT:
Follow up inspection to view progress towards resolving issues noted in the January 13, 2020 inspection report and
inspection of the disaster debris site deactivation (DS92-001).
STATUS OF PAST NOTED VIOLATIONS:
See historical information below.
OBSERVED VIOLATIONS:
G.S. 130A-309.05.(c)(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."
The Legacy Stockpile, Leaf Stockpile and Additional Stockpile remain on site in violation of G.S. 130A-309.05.(c)(1).
The City of Raleigh has issued an RFP to secure a contractor to remove the material in these stockpiles. The City is in
the final stages of negotiations with a contractor who intends to use the material for mining reclamation. Once the
contractor has been secured, submit a revised Solid Waste Inspection Mitigation Plan with an updated
timeframe for compliance. Include milestones and deadlines for removal of the material (either by stockpile or
volume or tonnage).
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NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl W.I�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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.
ADDITIONAL COMMENTS
Historical Information:
• On August 30, 2017, Liz Patterson and Drew Hammonds inspected City of Raleigh Yard Waste and Recycling
Facility and found the following Observed Violation, noted in the inspection report:
Permit to Operate, Attachment 3; Conditions of Operating Permit number 14 states that "Windrow dimensions
for active composting shall not exceed 8 feet in height x 15 feet in width unless approved by the Division.
Stockpiling of all feedstocks and finished product must be limited to a maximum of 30 feet in height by 50 feet
in width.
The storage area where feedstock is being stored at the time of this inspection was one big storage pile that
covered approximately 8 acres. The leaf storage area did not have any discernable windrows at the time of the
inspection either and appeared to be over one acre in size. Feedstock and finished product should be managed
in accordance with the permit to operate for this facility.
• October 2017 The City of Raleigh submitted the Solid Waste Inspection Mitigation Plan to address the observed
violations of the August 30, 2017 inspection.
• On January 19, 2018, The City of Raleigh submitted the revised Solid Waste Inspection Mitigation Plan
(Revision 1) to address the observations stated in the facility compliance inspection reports.
• On March 36, 2020, The City of Raleigh submitted the revised Solid Waste Inspection Mitigation Plan
(Revision 2) to address the additional comments and past noted observed violations in the inspection reports.
Inspection Comments:
1. As of October 21, 2020, the Legacy Stockpile, Leaf Stockpile and Additional Stockpile remain on site in
violation of G.S. 130A-309.05.(c)(1), which states "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."
The City of Raleigh has put out an RFP to secure a contractor to remove the material in these stockpiles. The
City is in the final stages of negotiations with a contractor who intends to use the material for mining
reclamation. Once the contractor has been secured, submit a revised Solid Waste Inspection Mitigation
Plan with an updated timeframe for compliance. Include milestones and deadlines for removal of the
material (either by stockpile or volume or tonnage).
2. The City of Raleigh has removed a large amount of the "Additional Stockpile" to use as stabilizing material on
Wilders Grove Closed MSWLF. New material is not being added to the Additional Stockpile. Incoming
material is ground and then moved to windrows for composting.
3. The "Leaf Stockpile" has not had temperature readings taken on it to confirm that it meets pathogen reduction
and had in some locations failed a fecal coliform test. The City of Raleigh Yard Waste Center Operations Plan,
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FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"'­ t0 E'!� """°"""' Solid Waste Section
Rev 6, May 2018, Section 2.5 Pre-processing: Receiving/Inspection of Waste states, "Leaves must be
stockpiled and allowed to reach a temperature of at least 131 degrees F for at least three days before this
material can be removed from the site and used as mulch." This material should not be distributed to the
public unless it has passed a fecal coliform test. Currently the City is not accepting leaves at this location,
however, should the City resume leaf collection, the leaf stockpiles will either need to be allowed to reach a
temperature of at least 131 degrees F for at least three days or mixed into the mulched yard waste to form
compost.
4. During the January 13, 2020 inspection, hardwood logs were being stored on top of the LCID landfill. Davy
Conners noted in the Inspection Report that the LCID landfill could not be used for storing and/or operating.
Tim Gainer was under the impression that the area had been approved for operations at some point in time.
Donna Wilson conducted a thorough permit history review and discovered that Mr. Gainer was correct, the
LCID landfill had been approved as an operational area. Ms. Wilson informed Mr. Gainer of this during the
June 19, 2020 inspection. During the October 21, 2020 inspection, the hardwood logs that had been stored on
the closed LCID landfill had been removed (Figure 1). Preserving the landfill cap is necessary if the City
decide to use this area for operations in the future.
During the January 13, 2020 inspection, the access roads were impassable in some locations. During the
October 21, 2020 inspections the roads throughout the facility were passable despite recent rains. Good job.
6. The sediment basins were being mucked out at the time of the inspection (Figure 2).
7. Some areas of erosion were observed in the facility, especially on the slopes near the creek (Figure 3).
Repair erosion rills and stabilize the slopes with mulch or vegetative cover as soon as possible to avoid
further erosion.
8. Water ponding around the leaf stockpile remains an ongoing issue. According to 15A NCAC 13B .1406 (3)
"Stormwater shall be diverted from operations area." As soon as these areas are dry enough to work in
them, regrade to create positive drainage.
9. A permit renewal application has been submitted to the Solid Waste Section and is currently under review.
10. All material from the disaster debris site (DS92-001) has been processed and removed and the site has been
deactivated (Figure 4).
Please see Attachment 1 for photos taken during this inspection.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Davy Conners
DN: cn=Davy Conners, o=Division of
Waste Management, ou=Solid Waste
Section,
email=[e-mail], c=US
Date: 2020.11.13 15:08:54-05'00'
Davy Conners
Environmental Senior Specialist
Regional Representative
Email: [e-mail]
Phone: [phone]
Sent on: November 13, 2020 X Email Hand delivery US Mail Certified No. r I
Copies: Andrew Hammonds, Eastern District Supervisor — Solid Waste Section
Stan Joseph, Department Director, City of Raleigh
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NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Attachment l: Inspection Photos
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Fi ure 1: Hardwood logs removed from LCID landfill.
Figure 2: Sediment basin being mucked out.
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Figure 3: Erosion rills on slope.
Figure 4: Disaster debris site has been deactivated.
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