SWC-11-12 081811 Audit

11
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
I
YW
Transfer
Compost
X
SLAS
COUNTY: BUNCOMBE
MSWLF
Lg III
PERMIT NO.: 11-12
Closed
HI-fW
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspections: 8/12/11 & 8/18/11
FACILITY NAME AND ADDRESS:
Crowell Farms, Inc.
523 Pond Road
Asheville, NC 28806
Date of Last Comprehensive Inspection: 08/06/10
GPS COORDINATES: N: 35.538967 E:-82.618917
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Mike Crowell
Telephone: [phone]
Cell: [phone]
PARTICIPANTS:
Andrea Keller, NCDENR Solid Waste Section (SWS)
Bev Price, NCDENR — DWQ (8/12/11, 8/18/11)
Michael Crowell, Crowell Farms, Inc.
STATUS OF PERMIT:
Initial PTO - January 19, 2007
Permit is expired (in renewal process)
Large Type III Compost
PURPOSE OF SITE VISIT:
Comprehensive site inspection
STATUS OF PAST NOTED VIOLATIONS:
None
OBSERVED VIOLATIONS:
15A NCAC 13B .1406 Operational Requirements for Solid Waste Compost Facilities
Any person who maintains or operates a solid waste compost facility shall maintain and operate the site to
conform with the following practices:
(6) A site shall only accept those solid wastes that it is permitted to receive.
On August 12, 2011, bovine bone matter was observed within composting process. It was stated by Mr.
Crowell that more than one carcass from his cattle farm operations (adjacent to the Solid Waste Compost
Facility) had been disposed of in this manner.
2090 US Highway 70, Swannanoa, North Carolina 28778
Phone: [phone] \ FAX: [phone] \ Internet: http://portal.ncdenr.o[g/web/wm/sw One
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An Equal Opportunity \ Affirmative Action Employer Aq t""" all

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 8
Crowell Farms is a Large Type III Compost Facility permitted to receive the following: grease trap waste,
manure and bedding, food waste (pre and post -consumer), cardboard, and ground land clearing debris, yard
waste, sawdust, and wood wastes. The disposal of the bovine carcasses constitutes a violation of 15A NCAC
13B .1406 (6).
2. 15A NCAC 13B .1406 Operational Requirements for Solid Waste Compost Facilities
(14)(A) The finished product shall meet the classification and distribution requirements outlined in Rule
.1407 of this Section.
On September 20, 2010 and March 7, 2011, analytical results for pathogen reduction requirements failed to
meet 15A NCAS 13B .1407 requirements for Grade A compost. The results of the failed tests were not
communicated to the Section and Crowell Farms did not halt distribution of the failed compost product. This
constitutes a violation of the classification and distribution requirements required by Rule.
Additionally, 15A NCAC 13B .1407 requires that the compost meet the 15A NCAC 13B .1408 Methods for
Testing and Reporting Requirements which require testing for foreign matter, pathogen reduction, and select
metals which in the case of the Crowell Farms Large Type III facility include: Cadmium, Copper, Lead,
Nickel, and Zinc. A review of the analytical sampling results submitted to the Section indicated discrepancies
between the required versus the submitted results for regulated metals. Specifically, Crowell Farms did not
report analytical results for Cadmium, Lead, and Nickel.
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 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.
ADDITONAL COMMENTS
1. Odor Complaint Investigations
Multiple site inspections were conducted over a two -month period (October through December 2010) in
response for complaints of odors leaving the facility property boundary. While "objectionable" odors were
noted on -site, no odors were noted above a 2.5 during these inspections (on a scale of 1-5, with 4 being
"objectionable" per Air Quality standards and procedures).
The communities surrounding the facility continue to submit odor data to the Section via email. Complaints
continue to be recorded and investigated during site inspections. Odor management practices will be
discussed further.
2. May 25, 2011— Site Inspection
Partial inspection conducted as follow-up to continued odor complaints from neighboring properties.
a. Odors at the cattle feed area (vegetable culls) seemed to have decreased compared to "high odor"
months of record. Mr. Crowell was managing the culls more aggressively (moving the vegetable
liquids mixed with wood chips to the compost bins more frequently, grating the discharge point in
order to keep whole vegetables from reaching the upper slurry pond, etc.).

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 8
b. Standing leachate was observed outside of the bin location on the upper concrete shelf. It was
communicated to Mr. Crowell that this needed additional management and could contribute to odor
c. At the bin location: bin #5 was cleared of material, bin #1 was accepting post -consumer food wastes,
and bin #s 2-4 were accepting grease wastes and cardboard.
d. Upper Slurry Pond — exhibited low odors. Minimal/no vegetable waste was visible. No sludge had
been removed to -date.
e. Erosion was noted on the bank across from the slurry pond and below the concrete shelf outside of
the storage bin. Cracking was visible on the concrete shelf outside the storage bin.
Erosion

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 8
3. August 4, 2011— Site Visit/Analytical Data Review
A site visit was conducted to notify M. Crowell that all distribution of compost must stop due to analytical
results for the pathogen reduction requirements. The facility analytical results were received by the Section
during the annual reporting period. The initial submittal did not include the Mutliple Tube Fermentation
Procedure (MTFP) results. M. Crowell contacted the lab (ETS) in order for them to submit the full test
results directly to the Section. Upon review of the complete data results, the following was noted:
a. The September 20, 2010 analytical MTFP results indicated a level of 133,000 MPN (limit is 1000
MPN) for the compost sample and 130,000 MPN for the sludge sample (no limit for this sample). M.
Crowell did not note the exceedance or notify the Section upon receiving the test results. While there
was the potential that the sample was run incorrectly (the result of the compost sample was very
close to the sludge sample, which is not typical), the issue was not resolved correctly at the time of
the exceedance and the product was distributed without meeting the 15A NCAC 13B .1407
Classification/Distribution of Solid Waste Compost Products requirements.
b. The March 7, 2011 analytical MTFP results indicated a level of 1118 MPN for the "compost+dirt"
sample. M. Crowell did not note the exceedance or notify the Section upon receiving the test results.
The issue was not resolved correctly at the time of the exceedance and the product was distributed
without meeting the above -referenced Section requirements.
c. M. Crowell stated that he would test his current compost product pile on August 8, 2011 and would
not distribute any material until the compost product met Section requirements.
Additionally, during the site inspection it was noted that a pearlite material had been added to a grease
compost bin (to prevent ponding of grease leachate on top of the bin solids). Mr. Crowell was told that this
was not an approved feed stock for the facility composting process. However, the material is considered inert
(siliceous rock), and can be added to the final product to increase porosity.
4. August 12, 2011— Comprehensive Inspection
A comprehensive site inspection was conducted (present: Bev Price, Division of Water Quality, Aquifer
Protection). Prior to arrival on site an odor evaluation round was conducted in the vicinity of the facility. No
odors were noted greater than —1.5 off -property and no odors were noted on properties located north of the
facility. Odors on site (at the source) were relatively improved compared to the 2010 time frame. Weather
conditions: mid-80's, partly cloudy, winds variable 0-1 mph.
a. The August 8, 2011 analytical MTFP results indicated a level of <95 MPN for the compost grab
sample. This satisfied the 15A NCAC 13B .1407(a) Table 2 requirements for pathogen reduction.
b. The cattle feed area appeared to be operated in accordance with odor management practices (as
previously described).
c. Strongest odors on site were located at the "cure pile" silo region of the facility. Some wastewater
was noted in this region. M. Crowell stated that he would add more cover (wood chips, finished
product) to this region to manage the odors/seepage.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 8
d. A "double -dam" system was in operation at the bin storage location —two "walls" of mostly fresh
chipped material or finished product were in place to retain liquids/grease from the bin system.
e. Behind the open-air shed near the bin locations, several waste (food waste) storage bins had been
staged. Water/wastewater generated from these containers appeared to have collected on the
concrete surface. Vectors (flies, wasps) were present and there was odor to the water/wastewater.
M. Crowell stated that he would immediately clean this area up (Danny's Dumpsters containers)
utilizing mulched wood waste.
f. The storage area outside of the bin system, on the concrete shelf, had been addressed since the
previous audit (see item 2b above). Soil material had been utilized around the perimeter of the
compost piles and additional cover/mulch had been used to bridge between windrows to avoid
standing leachate.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 6 of 8
g. Active cure compost pile: temperature records were available and appeared in order. The
calibration of M. Crowell's temperature gauge was discussed and he stated that he was going to
recalibrate the gauge as it appeared to be reading low.
h.
A jaw bone (bovine) was observed on the ground, comingled with compost/mulch, in the vicinity of
the active cure pile. Mr. Crowell stated that it was a cow jaw, most likely left over from when he
composted a carcass (from his cattle operations adjacent to the facility). During the discussion it was
also stated (M. Crowell) that a calf had been composted in this manner as well. A. Keller stated that
this was not approved in his permit or by Rule, and B. Price stated that this was most likely in
violation of the mortality management plan included in his active permit with Aquifer Protection.
5. August 18, 2011— Site Inspection
A follow-up site inspection was conducted to discuss the Rule violations (previously noted) and potential
Notice of Violation, and to inspect the following items:
a. The ARO office temperature gauge was utilized in conjunction with Mr. Crowell's temperature
gauge to verify results [item 4(g)]. Three locations were checked and the results were within 1° F of
each other.
b. In the vicinity of the bin storage location [item 4(e)] it was apparent that work at been done to

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 7 of 8
remove the standing water/potential leachate. Please ensure that these storage bins are managed
such that all waste and leachate is controlled and that odors and vectors are minimized.
c. The silo regions (cure piles) of the compost facility had been managed such that no standing liquids
were visible and odors had been mitigated [item 4(c) above]
It is understood that at this time, the facility is in the process of submitting for a permit renewal with the Solid Waste
Section (for the compost operation). This submittal will contain an Odor Management Plan to address several of the
issues noted (items 1 and 2). Please continue to keep the Section informed as to the status of the Aquifer Protection
and Division of Water Quality permits required as part of the Solid Waste Section permit approval process.
Based on the facility's request for clarification of testing and reporting requirements for Grade A compost, historical
governing documents for the facility and associated Rule requirements (.1406, .1407, and .1408) were reviewed and
are outlined below:
Test Requirements
Test Description/MethodologyDescription/Methodology
Allowable Limits
A dried, weighed sample of compost product is passed through
Foreign Matter Test
a'/a inch screen. The material remaining on the screen is
(also known as the Manmade
inspected and the foreign matter that can be clearly identified
is separated and weighed. The weight of the foreign matter
<6 %
Inerts %dry wet inerts, per
divided by the weight of the total sample is determined and
1407 Table 2)
multiplied by 100 to calculate the percent dry weight of the
foreign matter content.
Pathogen Reduction
Fecal Coliform
<1000 MPN/g
(PFRP test)
(*more than one option for PFRP testing, Appendix B)
Cd < 39 mg/kg
Metal Concentration
Cadmium (Cd), Copper (Cu), Lead (Pb), Nickel
Cu < 1500 mg/kg
(.1407 Table 1 and .1408
(Ni), and Zinc (Zn)
Pb < 300 mg�c
Table 3)
Ni < 420 mg/kc
Zn < 2800 mg/kg
4ttp://Dortal.ncdenr.org/web/wm/sw/rules/rulelist

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 8 of 8
Please contact me if you have any questions or concerns regarding this inspection report.
Phone:[phone]
Andrea Keller
Environmental Senior Specialist
Regional Representative
Sent on:
Email:
Hand
US
Certified No.
September 2, 2011
delivery:
Mail
by
AKeller
ec: Michael Scott, Section Chief — Solid Waste Section
Linda Culpepper, Acting Field Operations Branch Head — Solid Waste Section
Jason Watkins, Western District Supervisor — Solid Waste Section
Shawn McKee, Compliance Officer — Solid Waste Section
Bev Price, Division of Water Quality — Aquifer Protection Section
Dr. David Marshall, DVM, State Veterinarian [e-mail]