1905_INSP_20170113

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 5

UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost X SLAS COUNTY: Chatham
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: 19-05
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: January 13, 2017 Date of Last Inspection: January 26, 2016

FACILITY NAME AND ADDRESS:
Brooks Compost Facility – Large Type 3 Solid Waste Compost Facility
1195 Beal Road
Goldston, NC 27252

GPS COORDINATES:
N: 35.54431 W: -79.36780

FACILITY CONTACT NAME AND PHONE NUMBER:
Amy Brooks, Assistant Site Manager - Brooks Contractor, Inc.
w. 919-837-5914
f. 919-837-5097
c. 919-842-6063
[e-mail]
www.brookscontractor.com

FACILITY CONTACT ADDRESS:
Brooks Contractor, Inc.
Amy Brooks, Assistant Site Manager
1195 Beal Road
Goldston, NC 27252

PARTICIPANTS:
John Patrone, Environmental Senior Specialist - Solid Waste Section (SWS)
Amy Brooks, Assistant Site Manager - Brooks Contractor, Inc.
Alan Brooks, Site Manager - Brooks Contractor, Inc.

STATUS OF PERMIT:
Permit To Operate (PTO) issued August 20, 2015
PTO expiration date January 22, 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

Page 2 of 5

ADDITIONAL COMMENTS
On January 13, 2017, John Patrone met with Amy Brooks and Alan Brooks to conduct a comprehensive inspection of the
Brooks Compost Facility – Large Type 3 Solid Waste Compost Facility on Beal Road in Goldston, Chatham County.

1. The facility is a Large Type 3 Solid Waste Compost (SWC) Facility. It produces compost from eggshell/hatchery
waste, food waste (pre-consumer and post-consumer), yard waste (primarily leaves), wood mulch, animal
bedding, grease trap waste, etc. (see facility operations & maintenance manual page 6) and additional materials
as approved by the Solid Waste Section (SWS).
2. The facility is in operation Monday through Friday 7:00 am to 5:00 pm and Saturday 8:00 am to 12:00 pm (March
through November).
3. The facility permit, site plan, and operations plan were discussed.
4. Material is received from counties within North Carolina.
5. Compost produced is primarily sold to construction and landscape contractors, farmers, and landscape supply
businesses.
6. Compost may be mixed with sand, pine bark fines, PermaTill, or per individual custom blend formula.
7. Upon receipt, liquid material is dumped into the mixing and bulking pit.
8. Bulking agents are added and the material is mixed. The mixture is placed on the adjacent concrete pad to drain.
9. Solids with a high concentration of liquids are placed directly on the adjacent concrete pad [to drain].
10. The concrete pad contains two leachate drain grates. Leachate can be directed to the mixing and bulking pit or to
two 3,500-gallon concrete storage tanks.
11. The concrete storage tanks are used to settle-out sludge and particulate material. A 20,000-gallon steel storage
tank is used to store leachate that has drained from the concrete tanks. The leachate is pumped-out and used to
irrigate active windrows.
12. Food waste is placed on the concrete pad, mixed with bulking material, and placed in windrows.
13. Eggshell/hatchery waste is placed in windrows shortly after receipt. It is mixed with bulking materials as the
windrow is constructed. A layer of uncured compost is placed atop the windrow.
14. The facility commonly uses leaves, cardboard, mulch, animal bedding, and yard waste as bulking material.
15. The facility receives leaves during the leaf collection season from the Town of Cary and the Town of Siler City.
16. Active windrows are organized into two separate operational areas: eggshell/hatchery waste and food waste.
17. Active windrows appeared to be within required dimensions.
18. During the inspection the facility had 41 active windrows.
19. The facility uses a windrow-turning machine to turn the active windrows. Windrows are constructed with a front
end loader.
20. Active windrows are commonly maintained for 2 to 5 months during which time process to further reduce
pathogens (PFRP) is met. Windrows meeting PFRP are combined into a curing pile. Material is generally cured
for an additional 4 to 12 months.
21. The facility maintains three curing piles. Material to be cured is placed at one end and cured material/compost is
removed from the other.
22. Stockpiled curing material/compost is limited to a height of 60 feet.
23. Compost is screened prior to sale.
24. A vehicle scale test was conducted by the North Carolina Department of Agriculture & Consumer Services on
January 16, 2016.
25. A vehicle scale test was conducted by Central Carolina Scale, Inc. on January 13, 2017.

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

Page 3 of 5

26. The facility annual report (FAR) dated July 26, 2016 was received by the SWS. Material received for July 2015
through June 2016 is 63,940.00 tons. The amount of compost created is 36,075.92 tons, the amount sold/given-
away is 25,319 tons, and the amount stockpiled on site is 10,756.92 tons.
27. The facility maintains records of the quantity, type, and source of material received for processing. The amount of
material received from July 2016 through January 11, 2017 is 34,565.10 tons. The amount of compost sold/given-
away from July 2016 through January 11, 2017 is 15,276.70 tons. The amount of curing material/compost on site
as of January 12, 2017 is ~ 85,015.80 tons. The amount of leaves stockpiled on site as of January 12, 2017 is
3,328.555 tons.
28. The facility produces Grade A compost and offers an information pamphlet for customers and maintains a website
containing user information.
29. The facility has three temperature probes. Temperature probe calibration records for 2016 were verified.
30. The facility uses Green Mountain Technologies, Inc. windrow manager software. The program allows the facility
to electronically maintain active windrow data.
31. Windrow records were verified. Records for temperature, turning intervals, moisture level, bulk density, and C:N
calculation are maintained. Records were observed for windrows finished on July 11, 2016 (food waste),
November 25, 2016 (food waste), October 31, 2016 (food waste), November 21, 2016 (eggshell/hatchery waste),
and December 14, 2016 (eggshell/hatchery waste).
32. Records for material meeting PFRP that have been added to the curing piles were verified for July 2016 through
January 10, 2017.
33. The records document that the facility turns windrows at least five times during the high temperature period.
34. Windrow moisture level is measured by hand per the method outlined in the facility operations & maintenance
manual page 13.
35. Compost analysis records were verified for nutrients, concentration of metals, manmade inerts, fecal coliform, and
salmonella for samples taken February 23, 2016 identified as BR-1 (three samples taken), June 21, 2016 identified
as BR-1 (three samples taken), and October 5, 2016 identified as BR-1 (two samples taken). The samples were
analyzed by Soil Control Lab, Watsonville, CA. Ms. Brooks stated that compost analysis will be conducted ~ every
four months.
36. Ms. Brooks stated that additional compost analysis is routinely conducted by the North Carolina Department of
Agriculture & Consumer Services – Agronomic Services Division.
37. The facility has a water truck for dust control and one for windrow irrigation.
38. There was no odor detected at the facility boundary.
39. Mr. Brooks stated that the facility has not received an odor complaint. Eggshell/hatchery waste is incorporated into
windrows upon receipt, covered with a layer of compost, and commonly turned when winds are favorable.
40. The facility has a clay-lined stormwater pond. Stormwater can be pumped-out for use on windrows/in the active
compost process.
41. The facility does not discharge stormwater from the containment pond.
42. Mr. Brooks stated that the stormwater pond freeboard is 8 – 10 feet.
43. It is suggested that the facility clean-out the three stormwater pond sediment basins.
44. Mr. Brooks stated that stormwater pond sediment basin number 2 will be repaired as soon as possible.
45. The facility has been issued a Division of Water Resources Land Application (Irrigation) of Industrial By Product
Compost Leachate and Stormwater Runoff permit, No. WQ0036333, issued: 11/17/14 - expiration: 09/30/18.
46. Stormwater will be used for the irrigation of a nearby 20-acre field. The irrigation system has not been
constructed to date but is planned to be completed during summer 2017.
47. The Goldston Fire Department can be contacted to address and emergency at the facility.
48. The facility is secured by a metal gate with lock (the Brooks’ residence is located at the entrance drive to the
facility). Facility personnel are on site during operating hours.
49. Access roads are of all-weather construction.
50. The facility has proper signage.
51. The PTO expiration date is January 22, 2020
52. The PTO renewal application shall be submitted to the SWS by September 22, 2019.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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

Phone: [phone]

John Patrone
Environmental Senior Specialist
Regional Representative

Sent on: January 19, 2017 X Email Hand delivery US Mail Certified No. [ _]

Copies: Deb Aja, Western District Supervisor - SWS
Jessica Montie, Compliance Officer - SWS
Tony Gallagher, Composting & Land Application Branch Head - SWS
Corinne Law, Environmental Technician – SWS
Alan Brooks, Brooks Contractor, Inc. (c. 919-842-0010, [e-mail])

Digital pictures taken on January 13, 2017
by John Patrone, DWM – SWS

Mixing and bulking pit and adjacent concrete (drain) pad Eggshell/hatchery waste – windrow being formed

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 5

Active compost windrows – representative Stockpiled curing material/compost pile No. 3

Compost screener (1 of 2) Stormwater sediment basin number 2 – repair required