4205TWeldon TS- Sampling Plan_101718

October 17, 2018
Mr. Andrew Hammonds
Eastern District Supervisor
North Carolina Department of Environmental Quality
Division of Waste Management – Solid Waste Section
225 Green Street Suite 714
Fayetteville, North Carolina 28301
RE: Proposed Sampling Plan
Weldon Transfer Station – 4205T-TRANSFER-1997
Halifax, NC
Dear Mr. Hammonds:
Smith Gardner, Inc. (S+G) is submitting this Leachate Release Sampling (Plan) on behalf of
Waste Industries’ Weldon Transfer Station in response to the Notice of Violation (NOV)
related to violations observed during the inspection performed by the North Carolina
Department of Environmental Quality – Division of Waste Management – Solid Waste
Section (Section) on September 5, 2018 (copy attached). The NOV was received via e-mail
by Waste Industries who acknowledged the receipt by email reply to the Section on
September 21, 2018.
The NOV cited leachate flowing from the transfer trailer parking area (eastern portion of the
property along the fence) through the fence line and into a stormwater ditch flowing north.
Corrective actions required by the NOV include the following:
1. Repairs to transfer trailers need to be made in order for them to be leak resistant;
2. Measures to prevent future releases of leachate from trailers need to be implemented
and carried out; and
3. Soil samples must be taken according to an approved Sampling Plan and analyzed at
a NC certified laboratory. Conclusion and recommendations must be submitted, as
well as, a written certification (with supporting documentation) confirming that the
compliance schedule has been completed. This certification MUST include any
actions taken to prevent these violations from occurring in the future.
During the Section’s inspection, other operational deficiencies related to the site’s Operation
Manual were observed by the Section and will be addressed during the NOV response
process. These additional items consisted of:
1. Waste was observed being accepted outside of operating hours;
2. A trailer full of waste was observed being left uncovered (potentially leading to
windblown waste etc.);
3. Waste accumulation on the sides of the tipping floor and “wet muck” was observed on
the tipping floor ramp; and
4. Trained personnel certified by NC SWANA as a Transfer Station Operations
Specialist will be on duty during all hours of operation. At the time of the inspection,
the facility had one operator; when he refueled or took a break there was no one
supervising the tipping floor and trucks continued to dump.
Mr. Hammonds
October 17, 2018
Page 2 of 4
On September 28, 2018, S+G submitted a Request for Compliance Timeline Extension to the
NCDEQ requesting a 60-day extension for the full completion and certification of the required
corrective actions. On October 4, 2018, the Section issued an email response, effectively
extending the required compliance completion and certification date until December 21,
2018, pending Sampling Plan and revised Operations Manual submittal. This request and
subsequent response are attached.
The following proposed Plan has been prepared in accordance with requirements stated in
the NOV including submittal to the Section for approval prior to implementation.
Work Completed To-Date
On-Site Reconnaissance
On September 25, 2018, S+G met with Waste Industries representatives at the site to
discuss the inspection that led to the NOV, current site practices, and to observe the flow
path of potential contaminants, as reported in the NOV. Notable observations are listed
below:
· Waste Industries is currently evaluating options as it pertains to the current hauler;
several attempts have been made (since February 2018) to assure that the current
hauler provides properly sealed trailers for use on this site. These attempts have
been unsuccessful. During this review of options, Waste Industries has deployed
trough collectors under the rears of the trailers kept on-site to temporarily collect
any liquids escaping. The use of booms/absorbents were discussed as potential
additional measures. Waste Industries and S+G are reviewing and revising the
current Operations Manual for submittal to the Section; this is discussed below.
· Soil staining was noted in the gravel lot extending east into the grassy area in the
observable path of the of the leachate flow. The staining appeared to be localized
(not traveling off-site), however, this will be confirmed by sampling and analysis.
The sampling methodology is discussed below.
· Waste Industries stated that a previous revision of the site’s Operations Manual
incorrectly updated the facilities operation hours. This section of the Operations
Manual is under review for accuracy and will be revised.
· Waste Industries stated that the site does not typically store waste on the tipping
floor. The Section’s inspection occurred during active operations while waste was
being accepted. This is one area of revision/review currently underway concerning
the Operation Manual.
· Waste Industries stated that manpower at the transfer station is sometimes limited
resulting in only one operator in the immediate area. This is an area of
revision/review currently underway concerning the Operation Manual.
Operations Manual Revisions
Waste Industries and S+G are currently reviewing and revising the site’s Operations Manual
to make provisions for operational adjustments to maintain compliance long-term. This
revised Operations Manual will be submitted to the Section for review upon completion.
Mr. Hammonds
October 17, 2018
Page 3 of 4
Sampling Methodology
S+G proposes the following scope of work to evaluate the extent of environmental impact
resulting from the leachate release referred to in the issued NOV. Immediately following
Sampling Plan approval by the Section, Waste Industries will schedule a 3rd party to remove
visually impacted soils.
S+G personnel will be on-site to direct the excavation prior to sample collection. It is our
intent that sampling will take place on the same day as the soil removal from the visually
impacted areas. Additionally, S+G will utilize a photoionization detector (PID) to prescreen
soils at the bottom of the excavation for Volatile Organic compounds (VOCs). If PID
readings are consistent with background readings, and no odors nor discoloration are
present at 4” below grade, excavation will be halted, otherwise S+G will advise Waste
Industries to continue the soil excavation process. All excavated soils will be disposed of
properly. The approximate location of the visually impacted soils and the approximate
proposed sample locations are shown on the attached Figure 1.
Soil Sample Collection and Analysis
To evaluate soil quality within the flow path, S+G proposes to collect two (2) discrete grab
samples (approximately 4” and 9” below grade) from 16 locations (SS-1 through SS-16).
Due to the naturally occurring inorganic metals commonly seen in North Carolina soils, S+G
will also collect two (2) discrete background samples (approximately 4” and 9” below grade)
at two locations (BG-1 and BG-2).
Background sample results will be compared with samples collected in the observed flow
path to evaluate the naturally occurring constituent concentrations. Per the NOV directives,
soil samples will be analyzed for the Appendix I list of constituents (40 CFR 258 Appendix I
[VOCs and Total Metals] and pH) by a North Carolina certified laboratory.
Surface Water Sample Collection and Analysis
Preliminary discussions with the Section point to no water samples being required to be
collected due to the lack of run-off from the site.
Reporting
In accordance with the NOV directive, S+G will submit a letter report to the Section
summarizing sample collection techniques and laboratory analytical data results within 10
business days of receiving the laboratory analytical data. Analytical data will be compared to
site background conditions (soil analysis) and relevant standards (NC Soil Preliminary Soil
Remediation Goals). This report will also include a sampling location map, conclusions and
recommendations.
FIGURES

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Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/AirbusDS, USDA, USGS, AeroGRID, IGN, and the GIS User Community
DRAWN:APPROVED:SCALE:FIGURE NO.:PROJECT NO.:DATE:
DMM JMG FIG 1AS SHOWN Oct. 2018
Background Sample
Location (BG-1)
WELDON TRANSFER FACILITY
HALIFAX, NORTH CAROLINA
0 50 100 150 200Feet F
Visually
Impacted
Area
REFERENCE INFO:
Proposed
Approximate
Sample
Locations
(Typ.)
SS-1
Fence Line
WIWeldon 18-1
Background Sample
Location (BG-2)
SS-2
SS-3
SS-4
SS-5
SS-6
SS-7
SS-8SS-9
SS-16
SS-10SS-11SS-12
SS-13
SS-14
SS-15

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EMAILED NOTICE OF VIOLATION (NOV)
AND INSPECTION REPORT

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North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646
919.707.8200

September 18, 2018

CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7013 0600 0001 7442 3640

Christopher Williams, General Manager
Waste Industries, LLC
2211 Highway 301
Halifax, NC 27839

SUBJECT: Notice of Violation
Compliance Inspection Report
Town of Weldon Transfer Facility
4205T-TRANSFER-1997
Halifax County

Dear Mr. Williams,

On September 5, 2018, Davy Conners and Andrew Hammonds, 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. Christopher
Williams were present and represented Waste Industries, LLC during this inspection. The
following violation(s) were noted:

A. 15A NCAC 13B .0402(3) “Water that comes into contact with solid waste will be contained
on-site or properly treated prior to discharge from the site.”

Leachate, brown in color, was observed flowing from the transfer trailers parking area
(the eastern part of the property along the fence) through the fence-line and into the
ditch flowing north. White liquid was observed underneath a transfer trailer parked in
the same area. Additionally, a transfer trailer parked in this area was actively leaking a
small amount of leachate from the back gate.

North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646
919.707.8200
Town of Weldon Transfer Facility
Notice of Violation
Page 2 of 4
September 11, 2018

B. 15A NCAC 13B .0203(d) “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.”

And 15A NCAC 13B .0402(1) “Any person who maintains or operates a transfer facility
shall maintain and operate the facility in conformance with the following practices unless
otherwise specified in the permit. (1) Operational plans shall be approved and followed as
specified for the facility.”

The 2017 Facility Permit, Attachment 3 Conditions Of Permit Approval To Operate, Part
VI, Number 17c states “Waste may be stored on-site, in vehicles or containers that are
constructed, operated, and maintained to be leak resistant in order to prevent the creation
a nuisance to the public health from the escape of solid, semi-solid, or liquid waste a
maximum of 72 hours when the facility is closed during a weekend or holiday.”

And, the Operations Plan dated October 2016, Section 2.7.2, Number 12 states
“Personnel shall continuously monitor trailers provided for hauling to ensure they remain
leak resistant. Leachate leaks shall be immediately reported and remediated.”

Out of the five hauling trailers observed during the inspection, four had holes in the walls
and/or ill-fitting back gates and therefore were not leak resistant. This issue was also
noted in the February 13, 2018 inspection report.

Based upon the foregoing, Waste Industries, LLC shall come into compliance within 30 days of
receipt of this notice with all requirements of the regulations in 15A NCAC 13B .0203(d)
and .0402(1, 3) by completing the following:

Corrective Actions:

1. Repairs to transfer trailers need to be made in order for them to be leak resistant.

2. Measures to prevent future releases of leachate from trailers need to be implemented and
carried out.

3. Soil and water samples must be taken according to the Sampling Requirements listed below.
Submit the results to Christine Ritter, 1646 Mail Service Center, Raleigh, NC 27699-1646, for
determination as to the depth and extent of soil removal in the impacted areas.

North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646
919.707.8200
Town of Weldon Transfer Facility
Notice of Violation
Page 3 of 4
September 11, 2018

Samples must be taken in the areas that have been impacted by leachate. The areas along the
facility fence-line, the ditch behind the fence and the gravel areas where trailers park. When
sampling, go the full length of the channelized ditch area and any areas below where the photos
noted discoloration of soils and/or pooling of wastewater mixture.

Leachate Releases– Sampling Requirements
1. Submit a sampling plan using the guidance below in electronic format sent via email for
Solid Waste Section approval prior to sampling.
x Conduct subsurface soil sampling and water sampling at specific locations including
background soil and upstream water locations to evaluate the extent of the potential
environmental impacts from the release(s) at the facility.
x Subsurface soil samples should be collected between one to two feet below ground
surface.
x Discrete soil samples should be collected. Composite samples will not be accepted.
x All soil and water samples should be analyzed by a NC certified laboratory for
Appendix I of 40 CFR Part 258 parameters (VOCs and Total Metals) and pH.
x Please include the proposed sampling methodology and a map/aerial depicting the
proposed sampling locations.

2. After Solid Waste Section approval of the sampling plan, please implement the plan within
seven days. Within 10 days after the analytical results are received from the laboratory,
please submit documentation regarding the sampling event which should include the
following:
x A table of the surface water analytical results should be compared to the NC 2B
Standards.
x The subsurface soil analytical results should be compared to the Preliminary Soil
Remediation Goals (PSRGs). Both the Residential Health Based and the Protection of
Groundwater PSRGs must be met.
x The associated laboratory reports from the NC certified laboratory.
x The chain of custody.
x QA/QC results.
x The sampling methodology.
x Conclusions and recommendations.
x A map/aerial photo depicting the sampling locations.

Waste Industries, LLC shall provide a written certification with supporting documentation on
company letterhead confirming the noted compliance schedule has been completed. Include in
this certification any actions taken to prevent these violations from occurring in the future. Mail
North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646
919.707.8200
Town of Weldon Transfer Facility
Notice of Violation
Page 4 of 4
September 11, 2018

this certification to Davy Conners, 1646 Mail Service Center, Raleigh, NC 27699-1646, by the
noted compliance date.

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(s) to verify that the facility has completed the requirements of this Notice
of Violation.

If you have any questions, please contact me at 919-707-8290 or e-mail
[e-mail].

Sincerely,

Davy Conners
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section

copies: Andrew Hammonds, Eastern Field Operations Supervisor
Jason Watkins, Field Operations Branch Head
Jessica Montie, Compliance Officer
Christine Ritter, Hydrogeologist
Digitally signed by Davy Conners
DN: cn=Davy Conners, o=Division of Waste
Management, ou=Solid Waste Section,
email=[e-mail], c=US
Date: 2018.09.18 10:32:19 -04'00'
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: Halifax
Closed
MSWLF
HHW White
goods
Incin T&P FIRM PERMIT NO.: 4205T-TRANSFER-1997
CDLF Tire T&P / Collection Tire Monofill IndustrialLandfill DEMO SDTF FILE TYPE: COMPLIANCE
Date of Site Inspection:September 5, 2018 Date of Last Inspection:February 13, 2018
FACILITY NAME AND ADDRESS:
Town of Weldon Transfer Facility
2211 Highway 301 North
Weldon, NC 27839
GPS COORDINATES:N: 36.40094° W: 77.59826°
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Christopher Williams, General Manager
Telephone: [phone]
Email address: [e-mail]
FACILITY CONTACT ADDRESS:
Same as above
PARTICIPANTS:
Davy Conners, NCDEQ Solid Waste Section
Drew Hammonds, NCDEQ Solid Waste Section
Chris Williams, Waste Industries
STATUS OF PERMIT:
Permit issued June 28, 2017
PURPOSE OF SITE VISIT:
Partial inspection, follow-up from February 13, 2018 inspection and citizen complaint follow-up
STATUS OF PAST NOTED VIOLATIONS:
OBSERVED VIOLATIONS:
x 15A NCAC 13B .0402(3) states,“Water that comes into contact with solid waste will be contained on-site or
properly treated prior to discharge from the site.”
x 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.”
x 15A NCAC 13B .0402(1)“Any person who maintains or operates a transfer facility shall maintain and operate
the facility in conformance with the following practices unless otherwise specified in the permit. (1) Operational
plans shall be approved and followed as specified for the facility.”
x The 2017 Facility Permit, Attachment 3 Conditions Of Permit Approval To Operate, Part VI, Number 17c
states “Waste may be stored on-site, in vehicles or containers that are constructed, operated, and maintained to
be leak resistant in order to prevent the creation a nuisance to the public health from the escape of solid, semi-
solid, or liquid waste a maximum of 72 hours when the facility is closed during a weekend or holiday.”
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 5
x The Operations Plan dated October 2016, Section 2.7.2, Number 12 states “Personnel shall continuously
monitor trailers provided for hauling to ensure they remain leak resistant. Leachate leaks shall be immediately
reported and remediated.”
Leachate, brown in color, was observed flowing from the transfer trailers parking area (the eastern part of the property along the
fence), through the fence-line and into the ditch flowing north. White liquid was observed underneath a transfer trailer parked
in the same area. Additionally, a transfer trailer parked in this area was actively leaking a small amount of leachate from the
back gate.
Four out of the five trailer observed onsite had holes in the walls and/or ill-fitting back gates and therefore were not leak
resistant. This issue was also noted in the February 13, 2018 inspection report.
Figure 1: White substance under trailer
Figure 2: Leachate flowing into ditch
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 5
Figure 3: Transfer trailer with holes
ADDITIONAL COMMENTS
The facility is a municipal solid waste (MSW) transfer station owned by the Waste Industries, LLC. The facility is
permitted to receive municipal solid waste (MSW) from Bertie, Edgecombe, Franklin, Halifax, Hertford, Martin, Nash,
Northampton, Vance, and Warren Counties in North Carolina, and Brunswick, Greensville, Southampton, and Sussex
Counties in Virginia. Waste is transported to East Carolina Environmental Regional Landfill (Permit 08-03) in Bertie
County, NC; the Brunswick Waste Facility (Sanitary Landfill Permit #583) in Lawrenceville, VA; or the Sampson
County Landfill (Permit 82-02) in Sampson County, NC for disposal. Transfer station operations are contracted out to
Custom Ecology Inc. (CEI).
1. The current permit was issued June 28, 2017 and expires March 31, 2027.
2. The following are facility certified personnel:
x Brittany Holt, Certified Transfer Station Operations Specialist, TS2012079; expires 12/2/18
x Willie Hargrove, Certified Transfer Station Operations Specialist, TS2006083; expires 12/8/18
x George Mayo, Certified Transfer Station Operations Specialist
x Michael Arwood, Certified Transfer Station Operations Specialist
3. The inspection was the result of an odor complaint and follow up from a previous inspection. No noticeable
odors were observed outside the property boundary and odor-cancelling spray was being used. Good job.
4. It was noted during the inspection that the facility has been accepting waste outside of hours of operation and
then pushing the waste into transfer trailers once they open for business. Do not accept waste outside of
operating hours:
a. Operation of this solid waste management facility shall be in accordance with the Solid Waste
Management Rules, 15A NCAC 13B, Article 9 of the Chapter 130A of the North Carolina
General Statutes (NCGS 130A-290, et seq.), the conditions contained in the permit; and the
approved plan.
b. According to the approved operations plan, “the operating hours are Monday through Friday 8:00
AM until 4:30 PM, closed Saturday and Sunday. An attendant shall be on duty at all times when
the facility is open to enforce access restrictions.”
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 4 of 5
c. Waste must not be stored on the “tipping floor” after operating hours.
d. If you wish to change your operating hours, modifications or revisions of the approved documents
or changes during facility construction or operations must be submitted to the Section for review
and approval prior to implementing the modifications or revisions.
5.There was a trailer full of waste left uncovered, which could lead to windblown and birds carrying the
waste and dropping it. Make sure that loaded trucks are tarped and that all tarps are in good repair.
Figure 4: Trailer full of waste without tarp covering and not leak resistant
6.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. Waste had
accumulated on the ramp and along the sides of the tipping floor. The ramp leaving the tipping floor was slick
with wet muck.When wets loads are brought in, cleaning of the tipping floor should be done on a more
frequent basis to prevent leachate from being tracked off site on wheels of vehicles.
Figure 5: Waste accumulation near tipping floor
7.In order to assure that prohibited wastes are not entering the facility, screening programs have
been implemented. Trained personnel certified by NC SWANA as a Transfer Station Operations
Specialist will be on duty during all hours of operation.Make sure the facility has adequate trained
personnel on duty to supervise the dumping of waste. At the time of the inspection, the facility had one
operator; when he refueled or took a break there was no one supervising the tipping floor and trucks
continued to dump.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 5
8.Windblown waste noted on the previous inspection, however, during this inspection windblown waste
was not an issue.
Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: _

Environmental Senior Specialist
Regional Representative
Sent on: September 18, 2018 X Email Hand delivery US Mail X Certified No.
[7013 0600 0001 7442 3640]
Copies: Drew Hammonds, Eastern District Supervisor - Solid Waste Section
Jason Watkins, Field Operations Branch Head
Jessica Montie, Environmental Program Consultant
Christine Ritter, Hydrogeologist
Digitally signed by Davy Conners
DN: cn=Davy Conners, o=Division of Waste
Management, ou=Solid Waste Section,
email=[e-mail], c=US
Date: 2018.09.18 10:34:20 -04'00'

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REQUEST FOR COMPLIANCE TIMELINE EXTENSION
AND SECTION RESPONSE

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September 28, 2018 e-mail only

Mr. Andrew Hammonds
Eastern District Supervisor
North Carolina Department of Environmental Quality
Division of Waste Management – Solid Waste Section
225 Green Street Suite 714
Fayetteville, North Carolina 28301

RE: Extension Request – Notice of Violation (September 18, 2018)
Waste Industries -Weldon Transfer Station – 4205T-TRANSFER-1997
Halifax, North Carolina

Dear Mr. Hammonds:

As a follow-up to our telephone conversation yesterday, and on behalf of Waste Industries’
Weldon Transfer Station, Smith Gardner, Inc. (S+G) is formally requesting an extension for the
completion and certification of the corrective actions required by the Notice of Violation (NOV)
issued by the North Carolina Department of Environmental Quality (NCDEQ) on September
18, 2018 (copy attached).

Per NCDEQ’s NOV, the Weldon Transfer Station was found in violation in the following areas:

A. 15A NCAC 13B .0402(3) “Water that comes into contact with solid waste will be
contained on-site or properly treated prior to discharge from the site.”

B. 15A NCAC 13B .0203(d) “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.” And,

15A NCAC 13B .0402(1) “Any person who maintains or operates a transfer facility shall
maintain and operate the facility in conformance with the following practices unless
otherwise specified in the permit. (1) Operational plans shall be approved and followed
as specified for the facility.”

Waste Industries understands the NCDEQ’s reasoning and urgency associated with the above
violations and has engaged S+G to work with them to fully address the NOV and assist in
bringing the site back into compliance as soon as practical.

ON-GOING EFFORTS TO DATE

 On-Site Contingency Implementation: Waste Industries has identified and
implemented preliminary measures (trough collection) to address the liquids draining
from trailers stored on the site. Additional measures have been identified and will be
implemented (absorbent booms, etc.) as needed. This contingency will be monitored
and updated throughout the on-going NOV response process.

 On-Site Reconnaissance: S+G has met with Waste Industries at the site to discuss
the inspection that led to the NOV, review current site practices, and to observe the
areas of concern, as reported in the NOV.
1
Don Misenheimer
From:Hammonds, Andrew
Sent:Thursday, October 4, 2018 4:30 PM
To:Don Misenheimer
Cc:Watkins, Jason; Conners, Davis; [e-mail]; John
Gardner
Subject:Re: Weldon Transfer Station (4205T-Transfer-1997) - NOV - Request for Extension
Disregard the “draft” in the subject line of the previous email. Juggling to many knives at one time.
Drew
From: Hammonds, Andrew
Sent: Thursday, October 04, 2018 4:15 PM
To: 'Don Misenheimer' <[e-mail]>
Cc: Watkins, Jason <[e-mail]>; Conners, Davis <[e-mail]>;
'[e-mail]' <[e-mail]>; John Gardner
<[e-mail]>
Subject: RE: Weldon Transfer Station (4205T-Transfer-1997) - NOV - Request for Extension
Don,
We have reviewed the request for an extension submitted on behalf of Waste Industries. In the document under
“proposed corrective action compliance schedule”, you are requesting a 60-day extension for the full completion and
certification of the required corrective actions, per the proposed Corrective Action Schedule. The NOV states that
measures to resolve the violations and bring the site into compliance must be completed within 30 days receipt of the
notice. Davy received a reply to the emailed NOV on September 21, 2018 from Chris Williams, Waste Industries,
therefore the date to resolve the NOVs would be October 22, 2018. An extension of 60-days would be nearer to
December 21, 2018 which we are more agreeable to depending on what is defined in the updated operations plan and
sampling plan. Which per the request should be sent out the week of October 8, 2018.
We look forward to receiving the information for review and will follow up with any additional questions at that time.
Best Regards,
2
From: Don Misenheimer <[e-mail]>
Sent: Friday, September 28, 2018 8:19 AM
To: Hammonds, Andrew <[e-mail]>; Conners, Davis <[e-mail]>
Cc:
Subject: [External] Weldon Transfer Station (4205T-Transfer-1997) - NOV - Request for Extension
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
Report Spam.
Drew/Davy:
Per our conversations, please find the attached formal Extension Request pertaining to the NOV issued to the Weldon
Transfer Station on September 18, 2018.
Please let us know any questions or comments. We appreciate your time.
Best regards-
Don M. Misenheimer
Project Scientist
SMITH +GARDNER
14 N. Boylan Avenue
Raleigh, NC 27603
P [phone]
C [phone]
www.smithgardnerinc.com