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HomeMy WebLinkAbout3416_INSP_20190813oepamnem a� enmmnmemai a�ai FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section UNIT TYPE: Lined LCID YW Transfer X Compost SLAS COUNTY: Forsyth MSWLF PERMIT NO.: 3416T-TRANSFER- Closed HHW White Incin T&P FIRM MSWLF goods FILE TYPE: COMPLIANCE CDLF TireT&P/ Tire Industrial DEMO SDTF Collection Monofill Landfill Date of Site Inspection: August 13, 2019 Date of Last Inspection: September 11, 2018 FACILITY NAME AND ADDRESS: Overdale Road Transfer Station 5000 Overdale Road Winston-Salem, NC 27101 GPS COORDINATES: Lat.: 36.033263 ° Long.:-80.231984 ° FACILITY CONTACT NAME AND PHONE NUMBER: Name: Mark Tabaczynski, Division Manager — Republic Services Telephone: 336-408-6779 (mobile); 336-724-0842 (office) Email address: tabaczynskim@republicservices.com FACILITY CONTACT ADDRESS: Republic Services 2875 Lowry Street Winston-Salem, NC 27101 PARTICIPANTS: Sandra Lucas, Scale House Operator — Republic Services Ron Goins — Republic Services Chuck Kirchner, Environmental Senior Specialist — Solid Waste Section Susan Heim, Environmental Senior Specialist — Solid Waste Section STATUS OF PERMIT: Permit to Operate MSW Transfer Facility issued: January 6, 2003; Permit Amendment and Renewal issued: September 13, 2007; Permit Amendment and Renewal issued: September 17, 2012 Life of Site Permit to Operate issued: May 3, 2017. PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: None. OBSERVED VIOLATIONS: 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." Facility Permit No. 3416T-TRANSFER, Overdale Road Transfer Station, ATTACHMENT 1, General Permit Conditions Information, General Facility Permit Condition 7 states, in part, "This permit is issued based on the documents submitted in support of the application for permitting the facility including those identified in Attachment 1, "List of Documents for Approved Plan," and which constitute the approved plan for the facility." Page 1 of 11 D_E FACILITY COMPLIANCE INSPECTION REPORT NOFTH CAaOLiNA Division of Waste Management OepaNnent d Envimmenlal Oualiry Solid Waste Section Operation Plan for Overdale Road Transfer Station, Winston-Salem, North Carolina, prepared for Republic Services by HHNT, dated March 13, 2017 and revised April 19, 2017, is included in the List of Documents for the Approved Plan in ATTACHMENT 1, Part VI: Transfer Station/Treatment and Processing Unit. Operation Plan for Overdale Road Transfer Station, Winston-Salem, North Carolina (revised April 19, 2017) Section 9.0, TRANSFER STATION INSPECTIONS, states, in part, "There will be regular inspections conducted at the transfer station. Items that will be inspected monthly will include, but not be limited to, the following: 1) Transfer trailers; 2) Push walls; 3) Fire extinguishers; 4) Electrical controls; 5) Trench drain, floor drains, and yard hydrant; 6) Washdown water collection sump and pump; and 7) Oil/Water Separator. Records of all transfer station inspections will be maintained in the scalehouse." Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0203(d) for failure to maintain records of transfer station monthly inspections of transfer trailers; push walls; fire extinguishers; electrical controls; trench drain, floor drains, and yard hydrant; washdown water collection sump and pump; and oil/water separator at the scale house. During this inspection, Mr. Goins brought copies of missing facility inspection reports to the scale house for review. However, these inspection reports did not include the items listed in the approved Operation Plan, as noted above. Mr. Goins stated that he believed these specific inspection points are covered under a different monthly inspection procedure, adding that he did not have the paperwork for those inspections at the transfer station. Since the August 13, 2019 inspection of the facility, no additional inspection records have been provided. B. 15A NCAC 13B .0203(d) states, `By receiving solid waste at a permitted facility, the permittee shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the permit." Permit to Operate No. 3416T-TRANSFER-, ATTACHMENT 3, PART VI, Transfer Station/Treatment and Processing Unit Condition #7(a) 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." Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0203(d) for failing to maintain the tipping floor and transfer trailer loading area in a clean, sanitary condition. During this inspection, a build-up of waste was observed on the steel beams and sheet metal that make up the transfer station walls, on the deflector panels above the loading bay, on the push walls, and in and around the roll - off containers and drums of oil in the maintenance area along the southeast interior wall of the building. In addition, several separations and rips in the panels of sheet metal on the outside wall of the loading bay were noted. These openings in the building wall were large enough to allow waste to leave the transfer station. C. 15A NCAC 13B .0402(6) states, "Equipment shall be provided in the storage and charging areas and elsewhere as needed or as may be required in order to maintain the facility in a sanitary condition." Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0402(6) for failure to maintain the facility in a sanitary condition. A build-up of waste was observed on the steel beams and sheet metal that make up the transfer station walls, on the deflector panels above the loading bay, on the push walls, and in and around the roll -off containers and drums of oil in the maintenance area along the southeast interior wall of the building. Several separations and rips in the panels of sheet metal on the outside wall of the loading bay, large enough to allow waste to leave the transfer station, were also observed. D. 15A NCAC 13B .0105(c)(4) states: "The vehicle or container body, waste holding area, and hopper, if so equipped, shall be free of holes, cracks, rusting, corrosion, or other evidence of damage or weakness that may allow the escape of solid, semi -solid, or liquid waste." Page 2 of 11 D_E FACILITY COMPLIANCE INSPECTION REPORT NOFTH CAaOLiNA Q�� Division of Waste Management U.paN td—im-1 Quality Solid Waste Section Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0105(c)(4) for failing to ensure that waste transport trailers are maintained in a leak -resistant condition, free from holes, cracks, rusting, corrosion, or other evidence of damage or weakness that may allow the escape of solid, semi -solid, or liquid waste. During this inspection, trailers T-396 and T-301 were observed to be loaded with waste and parked in the trailer and container storage area located to the rear (northeast) of the transfer station and outside of the leachate collection system. T-396 was observed actively leaking leachate from a large crack in a seam on the floor of the trailer onto the asphalt parking area. T-396 was driven off the site while leaking was occurring. Trailer T-301 was observed to have several holes in the floor of the trailer; no leachate was observed actively leaking from the trailer during the inspection.T-301 was also driven off the site, allowing the potential for leachate and/or solid waste to be released from the trailer into the environment. Republic Services of North Carolina, LLC shall immediately implement procedures to inspect each trailer for cracks, holes, rusting, corrosion or other evidence of damage or weakness that may allow the escape of solid, semi -solid or liquid waste. Facility staff shall be trained to perform these trailer inspections and ensure that any trailers found to be out of compliance with 15A NCAC 13B .0105 are not used to store or transport waste. (Please note that a repair log covering the repair of both T-396 and T-301 was provided to the Solid Waste Section via email following the inspection on August 13, 2019.) E. 15A NCAC 13B .0105(c)(6) states: "The vehicle or container shall be loaded, transported, operated, and maintained to prevent the escape of solid, semi -solid, or liquid waste to the environment." Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0105(c)(6) for failing to ensure that waste transport trailers are loaded, transported, operated, and maintained to prevent the escape of solid, semi -solid, or liquid waste. During this inspection, trailers T-396 and T-301 were observed to be loaded with waste and parked in the trailer and container storage area located to the rear (northeast) of the transfer station and outside of the leachate collection system. T-396 was observed actively leaking leachate from a large crack in a seam on the floor of the trailer onto the asphalt parking area. T-396 was driven off the site while leaking was occurring. Trailer T-301 was observed to have several holes in the floor of the trailer; no leachate was observed actively leaking from the trailer during the inspection.T-301 was also driven off the site, allowing the potential for leachate and/or solid waste to be released from the trailer into the environment. F. 15A NCAC 13B .0203(d) states, in part: `By receiving solid waste at a permitted facility, the permittee shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the permit." Permit to Operate No. 3416T-TRANSFER-, ATTACHMENT 3, PART VI, Transfer Station/Treatment and Processing Unit Condition #7(c) 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 of 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." Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0203(d) for storing waste on - site in vehicles or containers that are not constructed, operated and maintained to be leak resistant. During this inspection, trailers T-396 and T-301 were observed to be loaded with waste and parked in the trailer and container storage area located to the rear (northeast) of the transfer station and outside of the leachate collection system. T-396 was observed actively leaking leachate from a large crack in a seam on the floor of the trailer onto the asphalt parking area. Trailer T-301 was observed to have several holes in the floor of the trailer. Page 3 of 11 FACILITY COMPLIANCE INSPECTION REPORT D_E Q�� Division of Waste Management DO Ctd—iA OepaNnen� e� Envimmenlal Oualiry Solid Waste Section CORRECTIVE ACTIONS REQUIRED: 1. Immediately implement procedures to inspect each trailer before loading to ensure that it has been maintained to prevent the escape of solid, semi -solid or liquid waste, and train facility staff to effectively implement these procedures so that trailers found to be out of compliance with 15A NCAC 13B .0105 are not used to transport waste or to store waste on -site. 2. By September 6, 2019, provide copies of all monthly facility inspection reports that include inspection of transfer trailers; push walls; fire extinguishers; electrical controls; trench drain, floor drains, and yard hydrant; washdown water collection sump and pump; and oil/water separator for the period October 2018 through August 2019. Reports shall be submitted to Susan Heim via email at susan.heim@ncdenr.gov. 3. By September 20, 2019, clean the entire interior of the transfer station building of waste, including the sheet metal/steel beam superstructure and concrete walls, the tipping floor, the maintenance area, the push walls, the deflector panels, and the loading bay. 4. By September 20, 2019, repair holes in the sheet metal on the outside loading bay wall of the transfer station building. Roll -off container located in the southeastern corner of the tipping floor. A build-up of waste can be seen under and around the container. (Photo taken by S. Heim 8-13- 19.) Page 4 of 11 oepamnem a� enmranmemai a�ai Another portion of the maintenance area on the southeast side of the tipping floor. The floor is covered by a build-up of waste, and trash can be seen strewn throughout the equipment and materials stored there. (Photo taken by S. Heim 8-13- 19. ) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section View of a portion of the maintenance area after the inspection. (Photo taken by M. Tabaczynski on August 13, 2019.) Page 5 of 11 oepamnem a� enmranmemai a�ai FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section This view of one of the deflector panels clearly shows the build up of waste that is evident throughout the facility. (Photo taken by S. Heim 8-13-19.) A view of the loading bay from the tipping floor shows the waste build-up on the walls and on the interior curbing. This portion of the loading bay had been cleaned by the small skid steer before the photo was taken and the empty trailer moved into the bay. (Photo taken by S. Heim 8-13-19.) Page 6 of 11 oepamnem a� enmranmemai a�ai A view of the northern exterior wall of the transfer station. Note the gash in one panel of sheet metal and a patch that has separated from the sheet metal wall. Both allow waste to escape the transfer station building. (Photo taken by S. Heim 8-13- 19. ) a ,AVMPI FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section A view of the underside of T-396. The leaking seam is clearly visible at the center of the photo. (Photo taken by C. Kirchner 8113119.) Page 7 of 11 oepamnem a� enmranmemai a�ai FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section 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. ADDITIONAL COMMENTS: 1. The facility is permitted as an MSW transfer station, designed to accept between 600 and 1500 tons of waste per day. No ancillary operations are conducted at the facility. 2. The facility is owned by and the permit issued to Republic Services of North Carolina, LLC. Republic Services contracts with K. R. Drenth Trucking, Inc. to operate the transfer facility and to transport waste to the Uwharrie Environmental Landfill (permit No. 6204) and the Great Oak Landfill (permit no. 7607) for proper disposal. Records Review: 3. The facility annual report for 2018-19 was reviewed and indicated that 127,184 tons of MSW was accepted at the facility for disposal during the previous fiscal year. 4. Scale House Operator Sandra Lucas, and employee of Republic Services, provided facility records for review. The life -of -site permit and the approved Operation Plan (revised March 2017) were available, along with the facility's Emergency Response Plan. 5. Ms. Lucas provided her calendar listing daily tonnage for July 2019 and August 2019 to date. The data recorded on the calendar amounted to 11,268.43 tons of MSW waste received by the facility in July 2019, and 3,611.97 tons of MSW waste received from August 1 through August 12, 2019. This averages out to approximately 490 tons of waste per day. 6. Training records for facility staff were also available for review, and included Republic Services' required training for PPE, Blood -borne Pathogens, Confined Spaces, and several other safety training programs. In addition, NCSWANA Transfer Station Operations Specialist certifications were on file for the following staff: • Sandra Lucas — expires 7/15/21; • Mark Tabaczynski —expires 1/1/21; • Ethan Bicking —expires 11/15/21; • Brian Bizzell — expires 11/15/21; • Joseph Prestandrea — expires 4/5/20; • Lamard D. Crawford — expires 6/13/20. 7. Ms. Lucas stated that pest control is now contracted through Copesan, Inc. The pest control contractor was onsite during the inspection and indicated that she treats the facility monthly for insects and vermin. 8. Ms. Lucas stated that the current Fire Marshal's inspection was not available at the facility for review. A copy of the Fire Marshal's report covering the December 28, 2018 fire safety inspection was provided via email following the inspection by Mr. Tabaczynski. The report indicated that there were no violations observed. 9. Copies of monthly facility inspections for the period of January through April 2019 were available at the scale house for review. Mr. Goins arrived during the inspection and provided copies of the May, June and July 2019 reports. 10. Monthly inspections of the facility leachate collection system are undertaken separately. Mr. Goins was unable to provide copies of any of these reports for 2019 during the inspection. Ensure that copies of all required records are maintained at the scale house, as stipulated in the approved Operation Plan (revised April 2017). (See Observed Violations section of this report for additional information.) The facility conducts at least one waste screening per operating day, and the forms detailing these waste screenings for the period January 2 through August 9, 2019 were reviewed. Most forms appeared to be Page 8 of 11 D_E FACILITY COMPLIANCE INSPECTION REPORT DO Ctd—iA Q�� Division of Waste Management OepaNnen� e� Envimmenlal Oualiry Solid Waste Section complete, although several were found to be blank except for the date and person conducting the screening. None of the forms indicated that any unacceptable waste had been found. Ensure that all waste screening forms are filled out completely. Please note that the form being used for random waste screenings is illegible. Ensure that a legible form is used to record future waste screenings. Field Inspection: 11. The grounds appeared to be clean and well -maintained. Windblown litter was well -managed outside of the transfer station building, along fence lines and throughout the site. 12. The entire site is paved with asphalt, and storm sewer drains are located along the northwestern fence line to collect the surface water runoff. These drains were inspected and found to be clean and free of windblown trash. 13. Access to the facility is restricted by a chain link fence that surrounds the site and is secured by means of locking gates at the entrance and at the Overdale Road access behind the transfer station building. 14. Proper signage was observed at the entrance to the facility. 15. A fire extinguisher and water hose were observed at the entrance to the tipping floor at the southern corner of the building and outside the entrance to the loading bay. 16. A number of incoming loads and outgoing trucks were observed during the inspection. Trucks entering the facility pass over the scales, then proceed to the tipping floor where they are directed by the equipment operators on duty. Each load is tipped in a separate spot so that any unacceptable waste can be identified and either returned to the customer that dropped it off or segregated and placed in a roll -off container for proper disposal at a later time. 17. No unacceptable waste was observed on the tipping floor or in the open transport trailer parked in the loading bay. 18. The tipping floor was difficult to inspect closely due to the layer of sludge -like waste that covered it. However, the floor generally appeared to be in good condition, with no deep cracks or holes visible in the concrete. 19. The leachate collection system is based on a tipping floor that slopes toward a drain hole in the push wall on the northwestern side of the building that overlooks the loading bay. The drain hole opens onto the upper wall of the loading bay. Leachate flows down the wall and is then directed toward a floor drain located near the center of the loading bay. The drain line enters a pipe that takes the leachate through an oil/water separator that removes solids, then out of the transfer station and directly into the City of Winston-Salem sewage collection system. Mr. Tabaczynski stated that leachate testing is not required by the city. Some accumulation of waste was evident in the grate over the floor drain. However, the floor drain appeared to be open and functioning properly, and leachate was observed flowing to the loading bay from the tipping floor drain above. No leachate was observed outside the loading bay or on the approach to the tipping floor. Please ensure that all waste is cleaned from the grate and inside the floor drain in the loading bay at the end of every working day. 20. The walls on the inside of the transfer station had accumulated a thick layer of dirt and dust, and waste was visible on the steel beams that make up the superstructure of the building. Mr. Goins was not able to provide information as to the last time the building had been pressure washed. (See Observed Violations section of this report for additional information.) 21. A maintenance area had been created on the left inside wall of the transfer station building, along the southeast side of the tipping floor. Two roll -off containers, a number of what appeared to be oil drums, several truck tires and various tools and pieces of equipment were stored along the wall in this area. Waste was observed under and around the containers, drums and equipment. (See Observed Violations section of this report for additional information.) 22. Following the inspection, Mr. Tabaczynski provided photos that indicated the maintenance area had been swept to remove much of the waste that had been observed there, and also neatened. Please note that the "maintenance area" is a part of the tipping floor and must be cleaned daily. Page 9 of 11 D_E FACILITY COMPLIANCE INSPECTION REPORT DO Ctd—iA Q�� Division of Waste Management OepaNnen� e� Envimmenlal Oualiry Solid Waste Section 23. Upon arrival at the facility, the loading bay was in the process of being cleared of waste before pulling an empty trailer in for loading. Facility staff were using a small skid steer to scoop up the trash that had accumulated between the walls and the trailer and place it into the bucket of the loader so that it could be placed into the new trailer. The clean-up by the skid steer left waste piled on the curbing next to the loading bay walls. (See photo in Observed Violations section of this report to view the loading bay after clean-up.) 24. The trailer that had been pulled into the loading bay was inspected and appeared to be intact. No cracks or holes were evident. 25. A large paved area behind the transfer station building serves as a staging area for extra roll -off containers and compactors, empty trailers, and loaded trailers waiting to be transported to the disposal facility. 26. Four empty trailers were parked in the staging area at the time of this inspection. Each of these trailers was inspected and appeared to be intact, with no cracks or holes visible. 27. Two fully loaded trailers were also observed in this staging area. Both were properly tarped, and the side walls of these trailers appeared to be in good condition. Holes were visible in the floor of trailer T301; no leachate was observed to be leaking from this trailer. An inspection of the underside of trailer T-396 revealed leachate leaking from a seam in the metal that was split open across the width of the trailer floor. Both trailers were observed leaving the facility with these structural deficiencies. (See Observed Violations section of this report for additional information.) Future violations may result in tiered enforcement action against both Republic Services of North Carolina, LLC and K. R. Drenth Trucking, Inc. A view of the tipping floor. Loads are dumped in separate piles so that they can be easily inspected for unacceptable wastes. The accumulation of dirt coating the concrete made inspection of the tipping floor difficult. (Photo taken by S. Heim 8-13-19.) Page 10 of 11 oepamnem a� enmranmemai a�ai FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section A view of the scale house and facility entrance from the transfer station. The grounds are clean and well -maintained. (Photo taken by S. Heim 8113119.) Please contact me if you have any questions or concerns regarding this inspection report. Digitally signed by Susan Heim DN: cn=Susan Heim, o=Solid Waste Section, ou=Field Operations Branch, email=susan.heim@ncdenr.go v, c=US Date: 2019.08.30 08:21:13 -04'00' Susan Heim Environmental Senior Specialist Regional Representative Phone: 336-776-9672 Sent on: August 30, 2019 to X Email Hand delivery US Mail X Certified No. Mark Tabaczynski, via: 7007 1490 0004 9565 2409 Sent on: August 30, 2019 to X Certified No. CT Corporation System, 7007 1490 0004 9565 2416 Registered Agent for Republic Services of North Carolina, LLC, via: Copies: Deb Aja, Western District Supervisor — Solid Waste Section Ming-Tai Chao, Permit Engineer — Solid Waste Section Ron Goins — Republic Services Sue Parks — K. R. Drenth Trucking, Inc. Page 11 of 11