9014T_NOD_20180621

State of North Carolina | Environmental Quality | Waste Management 610 East Center Avenue, Suite 301 | Mooresville, North Carolina 28115 919 663 1699
ROY COOPER
Governor MICHAEL S. REGAN
Secretary MICHAEL SCOTT
Director

June 21, 2018

CERTIFIED MAIL 7015 1520 0002 6879 8821
RETURN RECEIPT REQUESTED

Mr. Mark Pergolese, District Manger
Waste Connections, Inc.
3405 Westwood Industrial Park Drive
Monroe, North Carolina 28110

SUBJECT: Notice of Deficiency
Compliance Inspection Report
God Bless the USA Transfer Station
9014-TRANSFER-2014
Union County

Dear Mr. Pergolese,

On May 25, 2018, Teresa Bradford, 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. You were present and represented Waste Connection, Inc.
- God Bless the USA Transfer Station during this inspection. The following violations were noted:

A. 15A NCAC 13B .0203(d) states, “By receiving solid waste at a permitted facility, the
permittee(s) shall be considered to have accepted the conditions of the permit and shall
comply with the conditions of the permit.”
• General Permit Condition Number 16 (a) of the Permit to Operate 9014-TRANSFER-2014
states: “The tipping floor and transfer trailer loading area must be maintained in a clean
sanitary condition at all times and must be cleaned at least daily in accordance with the
approved Operational Plan.”
• Section 2.6.3 Building Maintenance of the approved Operations Manual (DOC ID 22254)
dated September 18, 2014 states: “The Operator will maintain the building by completing
the following: Sweep loose waste off the tipping floor daily, Sweep loose waste off of the
loading tunnel floor daily, Wash the tipping floor with the wash down hoses weekly, Wash
the loading tunnel floor with the wash down hose weekly, Pressure wash the entire
interior of the building every two years.”

During the inspection, a built-up layer of residual dirt and waste was observed on the tipping floor at
entrance of the transfer building and on the I-beams of the transfer building. Recyclable materials,
which is managed on the left side of the building, was observed behind the push wall.

God Bless the USA Transfer Station
Notice of Deficiency
Page 2 of 3
June 21, 2018

God Bless the USA, Inc., a wholly owned subsidiary of Waste Connections, Inc. is in violation of 15A
NCAC 13B .0203(d) in that the transfer building and tipping floor were not being maintained in a clean,
sanitary condition at all times.

B. 15A NCAC 13B .0203(d) states, “By receiving solid waste at a permitted facility, the
permittee(s) shall be considered to have accepted the conditions of the permit and shall
comply with the conditions of the permit.”
• Section 2.6.4 Site Maintenance of the approved Operations Manual (DOC ID 22254) dated
September 18, 2014 states in part: “The operator will maintain the site as follows: Pick up
errant litter daily.”

During the inspection, waste that appeared to have been from the previous operational work days was
observed on the ground outside of the entrance to the building. According to facility staff, the transfer
trailer is pulled out of the trailer loading bay to allow staff the ability to pull the tarp over the trailer to
cover the waste. When the tarp is pulled over the trailer, waste is being dragged off the top of the
trailer and deposited on the ground. Waste from previous operational days was also observed on the
ground outside of the trailer loading bay.

God Bless the USA, Inc., a wholly owned subsidiary of Waste Connections, Inc. is in violation of 15A
NCAC 13B .0203(d) in that waste is not being picked up daily as required by the approved operations
plan.

C. 15A NCAC 13B .0203(d) states, “By receiving solid waste at a permitted facility, the
permittee(s) shall be considered to have accepted the conditions of the permit and shall
comply with the conditions of the permit.”
• General Permit Condition Number 7 of the Permit to Operate 9014-TRANSFER-2014 states:
“A responsible individual trained and certified in facility operations must be on-site at all
times during all operating hours of the facility, in accordance with NCGS 130A-309.25. An
attendant must be present to oversee the loading and unloading of waste.

During the inspection, an individual trained and certified in facility operations in accordance with NCGS
130A-309.5 was not on-site during operating hours.

God Bless the USA, Inc., a wholly owned subsidiary of Waste Connections, Inc. is in violation of 15A
NCAC 13B .0203(d) in that an individual trained and certified in facility operations in accordance with
NCGS 130A-309.25 was not on-site during all operating hours of the facility.

The above violations may have or can compromise the facility’s ability to ensure protection of the public
health and the environment and thus require remedial action on behalf of the facility in order to
maintain compliance with 15A NCAC 13B .0203(d). In order to resolve these issues, God Bless the USA,
Inc., a wholly owned subsidiary of Waste Connections, Inc. must take the following actions:

1. Immediately implement the procedures set forth in General Permit Condition 16 (a) of the
Permit to Operate 9014-TRANSFER-2014 and the Facility Operations Plan (DOC ID 22254)
dated September 18, 2014, by performing the daily and weekly cleaning.
God Bless the USA Transfer Station
Notice of Deficiency
Page 3 of 3
June 21, 2018

2. Immediately implement the procedures set forth in Section 2.6.4 Site Maintenance of the
Facility Operations Plan (DOC ID 22254) dated September 18, 2014 by collecting all waste
deposited on the ground daily. Also, waste deposited on the ground from the tarp
placement must be immediately collected after each truck.
3. An individual trained and certified in facility operations in accordance with NCGS 130A-
309.25 on-site at all times during operating hours of the facility.

The violations 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.

Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct a follow-
up inspection within 10 days of receipt of this Notice of Deficiency to verify that the facility has completed
the requirements of this Notice of Deficiency.

If you have any questions please contact me at [phone] or [e-mail].

Sincerely,

Teresa N. Bradford
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section

copies: Jason Watkins - Field Operations Head
Deb Aja, Western District Supervisor