3416T_OverdaleRoadTransferStation_Comment_OP_FID1358002_20190913

From:Chao, Ming-tai
To:Tabaczynski, Mark
Cc:Moriarty, Dennis; Patrick, Carldelle; Bouchard, Derek; Heim, Susan A; Sandra Cubelli-Chrabuszcz; Matt Cheek
<[e-mail]> ([e-mail]); Stanley, Sherri
Subject:Comment on OP, Overdale Road Transfer Station, 3416T - Transfer
Date:Friday, September 13, 2019 9:03:00 AM
Attachments:image001.pngRE_ [External] RE_ 3416T - Overdale Road Transfer Station Notice of Deficiency.pdfimage004.emzimage005.pngimage006.pngimage007.png
Dear Mr. Tabaczynski:
The Solid Waste Section conducts a review of the Operation Plan dated September 2019
(FID1357738) according to Rules 15A NCAC 13B .0401 & .0402 and the FacilityCompliance Inspection Reports from 2017 to present, the following contents should be revised
or included in the revised Operation Plan for Overdale Road Transfer Station, Permit No.3416T-Transfer-:
1. (Section 1.3) According to the Notice of Deficiency dated August 30, 2019, the transferstation building fails to meet the requirements to maintain the facility in a sanitary
condition stated in Rule 15A NCAC 13B .0402(6). Please add action items such asinspection, maintenance, and/or repair, responding time for repair if required, and
record keeping requirements.
2. (Section 2.0) Please delete the statement in the second paragraph of this section becauseit is not acceptable. The approved service area for Overdale Road Transfer Station isthe counties fall within a 50-mile radius of the City of Winston-Salem as stated inAppendix of the Operation Plan. The listed disposal landfill facilities in Section 3.0 ofthe Operation Plan have the approved service area of the State of North Carolina. ThePermit Condition No. 4, Part IV of Attachment 3 Permit Approval to Operate(DIN27670) dated May 03, 2017 stipulates that
The waste collected at this transfer facility must be transported to a sanitarylandfill facility that isa. Permitted to receive the type of waste specified, andb. Whose service area includes the origin of the waste.
It is evident that wastes collected at this transfer station from the approved service area– counties listed in Appendix – can be transported and disposed of at the proposedlandfill facilities listed in Section 3.0. But the Overdale Road Transfer Station CANNOT accept wastes generated from counties that are not included within the servicearea in Appendix of the Operation Plan.
3. (Section 9.0)i. Per requirement of the inspection report dated September 11, 2018, please
append a typical monthly inspection form used for recording/documenting theinspection activities which are consistent with listed items in this section to the
Operation Plan.ii. Per NC Session Law 2013-413 (House Bill 74) & Rules15A NCAC 13B
.0105(c)(4) & (6), the permittee must conduct proper inspection andmaintenance of the waste loaded containers/trailers that come into and go out of
the transfer facility to ensure the containers/trailers are leak-resistant to preventsolid, semisolid, liquid waste/leachate inside the waste container from leaking
/spilling /spewing to the surrounding environment. According to September 05,2019 e-mail correspondence (attached to this email message), daily inspection
of all trailers will be conducted at the transfer facility by on-site personnel. Atrailer that fails to meet these law & rule requirements must be taken out of
service and repaired prior to being used to load and transport waste. Inspectionand repair actions must be documented in the routine inspection report. Please
add the above-mentioned actions to the operation plan; the typical inspectionform should be appended to the Operation Plan.
Please contact me or Susan Heim if you have any questions or requests for clarification of theabove-mentioned comments. Thank you and have a wonderful weekend.

From: Heim, Susan A <[e-mail]>
Sent: Wednesday, September 11, 2019 9:08 PM
To: Tabaczynski, Mark <[e-mail]>
Cc: Moriarty, Dennis <[e-mail]>; Patrick, Carldelle
<[e-mail]>; Bouchard, Derek <[e-mail]>; Chao,
Ming-tai <[e-mail]>
Subject: RE: [External] RE: 3416T - Overdale Road Transfer Station Notice of Deficiency

Thank you for providing the inspection records and other documentation. I’ll be back in touch when
I’ve had an opportunity to review everything.

Susan

From: Tabaczynski, Mark <[e-mail]>
Sent: Thursday, September 5, 2019 9:37 AM
To: Heim, Susan A <[e-mail]>
Cc: Moriarty, Dennis <[e-mail]>; Patrick, Carldelle
<[e-mail]>; Bouchard, Derek <[e-mail]>
Subject: [External] RE: 3416T - Overdale Road Transfer Station Notice of Deficiency

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This is the form we will be using starting Friday 9/6/2019 at overdale …each day all the trailers on
site will be inspected ….KR Drenth has brought in 7 brand new trailers since the inspection….both
trailers t 396 and t 301 were taken out of service the day on the inspection and repaired….the repair
orders or attached

From: Heim, Susan A <[e-mail]>
Sent: Friday, August 30, 2019 9:23 AM
To: Tabaczynski, Mark <[e-mail]>
Cc: Watkins, Jason <[e-mail]>; Aja, Deborah <[e-mail]>;
Kirchner, Chuck <[e-mail]>; Chao, Ming-tai <[e-mail]>; Montie,
Jessica <[e-mail]>
Subject: 3416T - Overdale Road Transfer Station Notice of Deficiency

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Good morning, Mark –

I’ve included a link to the Notice of Deficiency issued following my inspection of the Overdale
Road Transfer Station on August 13, 2019. You may click on this link to access the notice:

3416T - Notice of Deficiency - 8-30-19

An original signed document will be sent to you via US Mail.

Please read the notice carefully and contact me if you have questions or concerns.

Thank you,

Susan