2908_INSP_20180809

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 5

UNIT TYPE:
Lined
MSWLF LCID YW Transfer X Compost SLAS COUNTY: Davidson
Closed
MSWLF HHW White
goods Incin T&P X FIRM PERMIT NO.: 2908
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: August 9, 2018 Date of Last Inspection: August 25,2017

FACILITY NAME AND ADDRESS:
Todco, Inc. Wood Recycling Facility
1123 Roy Lopp Road
Lexington, NC 27292

GPS COORDINATES: N: 35.82872 ° W: -80.17377 °

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Todd Warfford, President
Telephone: [phone] (office); [phone] (mobile)
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
Same as above

PARTICIPANTS:
Todd Warfford, President – Todco, Inc.
Dalton Warfford – Todco, Inc.
Brian Warfford, Operations Manager – Todco, Inc.
Susan Heim, Environmental Senior Specialist – Solid Waste Section

STATUS OF PERMIT:
Permit expired: June 10, 2018;
Permit renewal application currently under review by the Permitting Branch.

PURPOSE OF SITE VISIT:
Partial Inspection

STATUS OF PAST NOTED VIOLATIONS:
None.

OBSERVED VIOLATIONS:
None.

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 2 of 5

ADDITIONAL COMMENTS

1. The facility is permitted as a C&D transfer station and wood waste treatment and processing facility.
2. The facility Permit to Operate expired on June 10, 2018; however, the permit renewal application is currently
under review by the Permitting Branch.

Records Review:

3. The permitted service area for the facility consists of Cabarrus, Davie, Forsyth, Guilford, Montgomery,
Randolph, Rowan, Stanley and Davidson Counties. A review of the 2017-18 Facility Annual Report found that
waste is currently being accepted only from Davidson and Guilford Counties.
4. The Facility Annual Report also indicated that only 209 tons of C&D waste had been received during the
reporting period. Mr. Warfford explained that the few loads that had been accepted at the facility for processing
had been inspected and approved prior to being brought to the facility. He stated that he had hand-selected these
C&D loads to ensure they contained only clean, separated materials that could be handled manually on the
tipping floor without the use of the picking line and the extra staffing required to man it.
5. By contrast, the Facility Annual Report indicated that 11,633 tons of wood waste had been accepted.
6. Mr. Warfford also stated that he does not intend to re-open the transfer station until there is a recovery in the
commodities markets sufficient to make processing the C&D waste worthwhile. He added that he is
investigating the possibility of re-locating the C&D operations, including the transfer station, covered tipping
floor and picking line, to the expansion area, located south of the mulch storage area across the creek. Mr.
Warfford also stated that he had identified this property in the permit renewal application, and that he didn’t
wish to add it to the permit at this time.
7. The facility permit and operations plan were available and reviewed. A copy of the revised operations plan,
which had been submitted with the permit renewal application, was also reviewed and compared to the
previously approved version.
8. Tonnage records were reviewed for the month of July 2018. These records indicated a total of 1,148.35 tons of
wood waste were received; and, a total of 976.21 tons of processed wood waste were sold as boiler fuel and
removed from the facility. Mr. Warfford reiterated that the only additional material currently being accepted at
the facility is inert debris – primarily clean concrete – intended for use as beneficial fill onsite.
9. Financial assurance for the facility is still being finalized, due to the additional calculation of an inflation factor.
Mr. Warfford stated that he expected the matter would be complete by week’s end.
10. A review of employee training records established that the following NCSWANA Transfer Station Operations
Specialist certificates were current: Todd A. Warfford – expires 4-16-19; Brian Warfford – expires 3-12-19;
Dalton Avery Warfford – expires 4-16-19; and, Becki A. Smith – expires 6-19-19.
11. Because transfer operations had not resumed at the facility, there had been no waste screenings performed
during the previous fiscal year.

Field Inspection:

12. The entire facility was clean and well-maintained.
13. Proper signage, including facility permit number and contact information, was posted at the entrance. A sign
listing acceptable and prohibited wastes was posted at the scale house, where incoming loads are screened and
sent to the appropriate unloading area where facility staff is waiting. Mr. Warfford stated that loads are spread
out and inspected prior to being pushed into the stockpile, and that any trash is removed and taken to the
facility’s waste roll-off for storage prior to proper disposal at the Davidson County Landfill (permit #2906).
This minimal amount of waste is included in the treatment and processing facility annual report.
14. Access roadways were of all-weather construction and in good condition.
15. Heavy rains and storms had resulted in rainfall totals exceeding 12” over the previous 10 days. The facility’s
drainage structures and stormwater devices were inspected and found to be in good condition. Little erosion was
evident on the sloped areas of the property, and drainage ditches and sediment traps contained some mud but
were also intact. Mr. Warfford stated that sediment would be cleaned out of the ditches and basins when the
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 5

area dried out so that equipment could be used effectively.
16. Mulch/vegetative waste and boiler fuel operations area staged in separate areas to preclude cross contamination.
17. Brush and land clearing debris are ground for mulch and, after processing, the material is stored on the north
end of the property in neat windrows. Some pieces of trash were observed in the vegetative debris stockpile, and
Mr. Warfford stated that this material is removed throughout the work day, before the wood waste is pushed up
into the stockpile. He added that the same process is used with the clean wood waste received in the boiler fuel
operations area.
18. No unacceptable waste was observed in the clean wood stockpile.
19. Adequate access was found to be well maintained between unprocessed and processed wood waste piles. Hose
bibs and fire extinguishers are stationed in key locations around the facility in case of fire.
20. Wood grinding operations were taking place in both the boiler fuel and vegetative wood areas. A new horizontal
grinder had been purchased and was in use during this inspection. Tub grinders are outfitted with nozzles that
spray water onto the wood as it is being processed.
21. No dust was observed outside of the processing areas, and dust emissions from the grinding equipment were
minimal.
22. The C&D treatment and processing area was being used for storage of clean soil. The picking line was idle and
clean, with no accumulated waste visible. The portion of the covered tipping floor that was visible outside of the
areas where the soil stockpile was staged on the northern end, appeared to be in good condition. The fabric
canopy was intact and appeared to be well maintained.
23. The leachate drain at the back of the tipping floor had been improved with a cap and valve, designed to allow
clean storm water to flow through to the storm drain, located just outside of the covered tipping area to the east.
Mr. Warfford explained that the drain could be closed should waste be present on the tipping floor and storm
water had come into contact with that waste. He added that, should this situation arise, a leachate hauler would
be hired to pump out the tipping floor, using the drain valve, and transport it for proper disposal. Mr. Warfford
stated that there had not yet been a situation where C&D waste had come into contact with storm water at the
facility. He stated that this is due to careful planning and constant monitoring of the weather.
24. Mr. Warfford stated that the facility purchases mulch and brings it to the site for sale to the public. He added
that a portion of this purchased mulch is run through the color injection equipment and offered for sale in
several different shades. The mulch colorizer is located next to the product storage bins, to the west of the C&D
processing area.
25. The additional acreage south of the permitted facility was observed. A small stockpile of inert debris was
located on the western side of this area. A few pieces of lumber were visible at the corner of the stockpile. Mr.
Warfford stated that this portion of the site would be cleaned up before the close of the operating day, as part of
the facility’s daily operating procedures.

A view of the center of
the facility. The covered
tipping floor can be
seen in the center
background, wish clean
wood grinding
operations taking place
in front. The facility is
clean and well-
maintained; no ponding
water is evident.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 5

A view of the vegetative
wood waste operations
area. Operators are
pushing up the brush
that had just been
received from residents.
The area is clean and
well-maintained. Note
the horizontal grinder
seen behind the loader
on the left.
A view of the product
storage area from the
entry drive. Note the
storm drain near the
center of the photo. All
drains were clean and
functional; roadways
were in good condition.
The tipping floor drain with valve installed to prevent
leachate form reaching the storm drain, seen in the
foreground.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 5

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

________________________________________ Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative

Sent on: August 16, 2018 to
Todd Warfford, Todco, Inc.
X Email Hand delivery US Mail Certified No. [ _]

Copies: Deb Aja, Western District Supervisor – Solid Waste Section
Ming-Tai Chao, Permitting Engineer – Solid Waste Section

Clean wood waste
operations area: ample,
well-maintained fire
lanes; no fugitive dust
emissions from grinder;
no ponding water.