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.
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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.
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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.
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