1905_INSP_20180111

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.: 19-05
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: January 11, 2018 Date of Last Inspection: January 13, 2017

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
w. 919-837-5914
f. 919-837-5097
c. 919-842-6063
[e-mail]
www.brookscontractor.com

FACILITY CONTACT ADDRESS:
Brooks Contractor
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
Alan Brooks, Site Manager - Brooks Contractor

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 4

ADDITIONAL COMMENTS
On January 11, 2018, 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 pages 6 and 7) 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. Compost produced is primarily sold to construction and landscape contractors, farmers, and landscape supply
businesses.
5. Compost produced may be mixed with sand, pine bark fines, PermaTill, or per individual custom blend formula.
6. Material is received from counties within North Carolina.
7. Upon receipt, liquid material is dumped into a mixing and bulking pit. Bulking agents are added to the liquid
material and the material is mixed.
8. The mixture is then placed on an 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 adjacent 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 upon receipt. It is mixed with bulking materials as the windrow
is constructed. A layer of uncured compost is placed atop the windrow during its construction.
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 43 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 the process to further reduce
pathogens (PFRP) is met. Windrows that have met 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 April
27, 2017.
25. A vehicle scale test was conducted by Central Carolina Scale, Inc. on January 11, 2018, October 3, 2017, and July
25, 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 4

26. The facility annual report (FAR) dated July 26, 2017 was received by the SWS. Material received for July 2016
through June 2017 is 58,012.97 tons. The amount of compost created is 32,982.79 tons, the amount sold/given-
away is 28,439 tons, and the amount stockpiled on site is 4,543.79 tons.
27. The facility maintains records of the quantity, type, and source of material received for processing. The amount of
material received from July 2017 through January 10, 2018 is 33,273 tons. The amount of compost sold/given-
away during the same time is 10,204.3 tons. The amount of curing material/compost on site as of January 10, 2018
is 93,887.7 tons. The amount of leaves stockpiled on site as of January 10, 2018 is 2,807.54 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. The temperature probes are calibrated monthly. Temperature probe
calibration records for 2017 were observed.
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 observed for July 5, 2017 through December 27,2017. Records for temperature, turning
intervals, moisture level, bulk density, and C:N calculation are maintained. Records were examined for windrows
meeting PFRP that were taken-up and added to the curing pile(s) on July 5, 2017 (food waste – row #3), October
19, 2017 (food waste – row #23), August 29, 2017 (eggshell/hatchery waste – row #15), and December 20, 2017
(eggshell/hatchery waste – row #13).
32. Windrow moisture level is measured by hand per the method outlined in the facility operations & maintenance
manual page 13.
33. Compost analysis records were observed for nutrients, concentration of metals, manmade inerts, fecal coliform, and
salmonella for samples taken February 22, 2017 identified as BR-1LNOP, June 27, 2017 identified as BR-1F, and
September 27, 2017 identified as BR-1NE. The compost samples were analyzed by Soil Control Lab, Watsonville,
CA. Compost sample analysis appeared compliant with Solid Waste Section rules. Ms. Brooks stated that compost
analysis will be conducted ~ every four months.
34. Ms. Brooks stated that compost samples are also analyzed by the North Carolina Department of Agriculture &
Consumer Services – Agronomic Services Division.
35. The facility has one water truck for dust control and one for windrow irrigation.
36. There was no odor detected at the facility boundary.
37. 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.
38. The facility has a clay-lined stormwater pond. Stormwater can be pumped-out for use on windrows/in the active
compost process.
39. The facility does not discharge stormwater from the containment pond.
40. Mr. Brooks stated that during the inspection the stormwater pond freeboard was at ~ 7 feet.
41. Mr. Brooks stated that the stormwater pond will likely be cleaned-out in the coming months.
42. It is suggested that the three stormwater pond sediment basins are rebuilt as necessary.
43. 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.
44. The stormwater (captured by the facility’s non-discharge stormwater pond) 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 2018.
45. The Goldston Fire Department can be contacted to address and emergency at the facility.
46. 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.
47. Access roads are of all-weather construction.
48. The facility has proper signage.
49. The PTO expiration date is January 22, 2020
50. 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 16, 2018 X Email Hand delivery US Mail Certified No. [ _]

Copies: Deb Aja, Western District Supervisor - SWS
Adam Ulishney, Environmental Compliance Branch Head - SWS
Alan Brooks, Site Manager - Brooks Contractor (c. 919-842-0010, [e-mail])