5106_NOV_20210127

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
NORTH CAROLINA
Environmental Quality
January 27, 2021
CERTIFIED MAIL 7019 0700 0000 3643 1762
RETURN RECEIPT REQUESTED
Blackwood Associates, LLC
Mr. Ryan Conrad
699 West Dillman Road
Bloomington, IN 47401
RE: Notice of Violation
West Farms Wood Products
Permit #5106-TP-2019
1683 Barefoot Road
Newton Grove, NC 28366
Dear Mr. Conrad,
On January 12, 2021, Amanda Thompson and Drew Hammonds, representing the State of North
Carolina, Division of Waste Management Solid Waste Section (Section), inspected the above
referenced facility for compliance with North Carolina solid waste statutes and rules. The
following violation(s) were noted:
A. March 11, 2019 Permit to Operate Application, Site Design (Page 4, Paragraph 1), "The
West Farms Wood Produces wood material treatment and processing facility is in the
east central portion of the site and occupies about 6.0 acres (see Total Property Layout
& Staging Area — Drawing 2)."
Blackwood Associates, LLC is in violation of March 11, 2019 Permit to Operate Application,
Site Design (Page 4, Paragraph 1) in that operations are currently taking place outside the
permit approved six (6) acres. Current operations are taking place to the north of the
approved area without approval from permitting.
B. 15A NCAC 13B .0302 (2) "A facility shall only accept waste which it is permitted to
receive.", August 2, 2019 Permit to Operate, Attachment 3 (3), "The facility is permitted
to receive land clearing debris, untreated and unpainted clean wood material, and
D_EWAj
NORTH CAROLINA
ileparlment o� EnviranmanGl puaiity
North Carolina Department of Environmental Quality I Division of Waste Management
Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, North Carolina 28301-5095
910.433.3300

Blackwood Associates, LLC
Notice of Violation
Page 2of4
January 27, 2021
creosote treated utility poles.", and August 2, 2019 Permit to Operate, Attachment 3
(9), "Unacceptable waste received at the site must be stored in containers and promptly
removed from the site for proper disposal."
Blackwood Associates, LLC is in violation of 15A NCAC 13B .0302 (2) and August 2, 2019
Permit to Operate Attachment 3 (3 and 9) in that a large pile of blue painted broken pallets
and 30-40 tractor trailer tires have been accepted at the facility. The painted broken
pallets and tractor trailer tires were not stored in containers or promptly removed from
the facility.
C. August 2, 2019 Permit to Operate, Attachment 3 (13), "Fire lanes must be maintained
between piles, 20 feet wide, as specified in the approved operating plan." and March
11, 2019 Permit to Operate Application, Site Design (Page 4, Paragraph 6), "The design
layout calls for 20-foot fire lanes around and between the stockpiles."
Blackwood Associates, LLC is in violation of August 2, 2019 Permit to Operate, Attachment
3 (13) and March 11, 2019 Permit to Operate Application, Site Design (Page 4, Paragraph
6) in that the northern edge of the northern most stockpile was inaccessible by a
firefighting vehicle.
D. March 11, 2019 Permit to Operate Application, Operating Plan (Page 9, Paragraph 3),
"Stormwater best management practices are utilized to prevent soil and other
pollutants from accessing surface waters and to prevent excessive on -site erosion. Silt
fences are presently in place to prevent silt from leaving the site."
Blackwood Associates, LLC is in violation of March 11, 2019 Permit to Operate Application,
Operating Plan (Page 9, Paragraph 3) in that the silt fence located along the southern
portion of the unapproved operating area has become inundated with silt. The silt has
flowed around the silt fence and into the adjacent forested lands.
Based upon the foregoing, upon receipt of this Notice of Violations, Blackwood Associates, LLC
shall come into compliance with all applicable requirements of the regulations in 15A NCAC 13B,
the Permit to Operate and the Operations Plan by completing the following:
1. Immediately stop accepting waste in the unapproved operating area. Processing of
waste in this unapproved area may continue in an effort to bring this site into
compliance with the storage and removal requirements of the permit and approved
operations plan. The site owner/operator should contact Donna Wilson, Permitting
Branch Engineer at [phone] or [e-mail] to discuss the
NORTH GAROIINAD_ E QU
)ep.dt tofFmirenme. 10—Ifty
North Carolina Department of Environmental Quality I Division of Waste Management
Fayetteville Regional Office 1225 Green Street, Suite 714 1 Fayetteville, North Carolina 28301-5095
910.433.3300

Blackwood Associates, LLC
Notice of Violation
Page 3of4
January 27, 2021
permitting approval for the current operating area.
2. Within 30 days of receipt of this report, remove and dispose of unacceptable wastes at
a properly permitted facility. Including scrap tires, treated and/or painted wood, the
mixed waste used for road base and the concrete/slag waste observed on site. Disposal
receipts for the unacceptable wastes must be maintained copies provided to:
Amanda Thompson
Environmental Senior Specialist
Division of Waste Management, Solid Waste Section
225 Green Street, Suite 714
Fayetteville, NC 28301
3. Within 30 days of receipt of this report, the location of the northern most stockpile
should be adjusted so that there is a 20-foot fire lane around all sides of the stockpile.
4. Within 30 days of the receipt of this report, clean out and repair the silt fence so that
the silt will no longer flow into the adjacent forested land. Additional measures to
prevent further migration of sediment must be taken as necessary.
All corrective measures must be completed within 30 days' receipt of this notice of violations,
unless otherwise noted. A follow up site inspection will be conducted after 30 days have passed
to ensure that the corrective measures have been completed to bring this facility into compliance.
The violation(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 such further relief as may be necessary to achieve
compliance with the North Carolina Solid Waste Management Act and Rules.
Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct
a follow-up inspection to verify that the facility has completed the requirements of this Notice of
Violation.
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NORTH GAROIINAD_E QU
)ep.dt tofFmirenme. 10—Ifty
North Carolina Department of Environmental Quality I Division of Waste Management
Fayetteville Regional Office 1225 Green Street, Suite 714 1 Fayetteville, North Carolina 28301-5095
910.433.3300

Blackwood Associates, LLC
Notice of Violation
Page 4 of 4
January 27, 2021
If you have any questions or concerns, please contact me at [phone] (office) or
[e-mail].
Sincerely,
Digitally signed by Amanda
Thompson
Date: 2021.01.27 08:40:53
-05'00'
Amanda Thompson
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section
copies: Jason Watkins, Field Operations Branch Head
Andrew Hammonds, Eastern District Supervisor
Jessica Montie, Environmental Program Consultant
Donna Wilson, Engineering Project Manager
1-D_E Q >
NORTH CAROLINA
pepadmed of E—impn .tal quality
Nr—
North Carolina Department of Environmental Quality I Division of Waste Management
Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, North Carolina 28301-5095
910.433.3300