7903_INSP_20190919

oepamnem 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: Rockingham
MSWLF
PERMIT NO.: 7903T-TRANSFER-1991,
Closed
HHW
X
White
Incin
T&P
FIRM
MSWLF
goods
7903-HHW-2013
FILE TYPE: COMPLIANCE
CDLF
TireT&P
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: September 19, 2019
FACILITY NAME AND ADDRESS:
City of Eden MSW Transfer and HHW Collection Facility
123 Mebane Bridge Road
Eden, NC 27288
Date of Last Inspection: November 29, 2018
GPS COORDINATES: Lat.: 36.476696' Long.:-79.740287'
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Dusty Curry, City of Eden Solid Waste Superintendent
Telephone: [phone] (mobile)
Email address: [e-mail]
FACILITY CONTACT ADDRESS:
City of Eden
Municipal Services Department
Solid Waste Division
1050 Klyce Street
Eden, NC 27288
PARTICIPANTS:
Dusty Curry, Solid Waste Superintendent — City of Eden
Susan Heim, Environmental Senior Specialist — Solid Waste Section
STATUS OF PERMIT:
Permit to Construct Operate MSW Transfer Facility Issued: November 2, 1995
Permit Renewal: December 27, 2000
Permit Renewal: June 6, 2006
Permit Renewal, Operations Plan Modification (to separate HHW from TS permit): April 3, 2013
Permit Renewal: July 20, 2015
Permit to Operate expiration date: August 22, 2020
Submit Permit Renewal Application no later than February 22, 2020.
PURPOSE OF SITE VISIT:
Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS:
1. RESOLVED: 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." Permit to Operate No. 7903, ATTACHMENT 1, PART I, General Permit Condition
#6 states, "Operation of this solid waste management facility must be in accordance with the Solid Waste
Management Rules, 15A NCAC 13B, Article 9 of the Chapter 130A of the North Carolina General Statutes, the
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Solid Waste Section
conditions contained in this permit, and the approved plan." Permit to Operate No. 7903, PART I, General
Permit Condition #7 states, "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." Permit to Operate No. 7903,
ATTACHMENT 1, Part VI, Item 7 lists Transfer Station Operations Plan for the City of Eden Transfer Station
(includes operation plan for the household hazardous waste facility) as one of the documents for the Approved
Plan. Item a, Oil Based Paints, of Section VIII — Facility Operation of the Operation Manual, City of Eden
Household Hazardous Waste Facility, Permit No. 7903-HHW-2013 (approved July 20, 2015), states, in part,
"The accumulation time for oil base paint is six months or when four hundred (400) gallons have been
collected, whichever comes first. The paint is removed from the facility by a qualified company
contracted by the City of Eden to dispose or use the waste as fuel."
Mr. Curry provided an invoice from the city's HHW contractor, Ecoflo, Inc., indicating that 2 55-gallon drums
of oil -based paint were removed from the facility for disposal on December 18, 2018. Therefore, this violation
is considered to be resolved.
OBSERVED VIOLATIONS:
No violations were observed during this inspection.
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 consists of a transfer station (permit # 7903T-TRANSFER- 199 1) and permanent HHW collection
facility (permit # 7903-HHW-2013) for the City of Eden. The transfer station only receives waste from city
trucks, and the HHW collection program is only available to city residents.
2. A recycling convenience center is also located at the site, allowing city residents to drop off separated
residential recyclable materials, including cardboard, plastic bottles, aluminum and steel cans, mixed paper,
plastic bags, used motor oil and oil filters, used cooking oil, televisions and electronics.
3. A new hopper and compactor system were installed in the transfer station in July 2018 and put into operation on
August 1, 2018.
Records Review:
4. The current Permit to Operate (dated July 20, 2015) and approved Operation Manual (dated April 18, 2015)
were available for review at both the Municipal Services Office and the transfer station office. Please note that
the current Permit to Operate will expire August 22, 2020, and a permit renewal application must be
submitted to the Solid Waste Section by February 22, 2020.
5. The facility annual report was reviewed and indicated that a total of 4,869.95 tons of MSW were received at the
transfer station during the period from July 1, 2018 through June 30, 2019.
6. The facility tracks tonnage by keeping a log of transfer trucks taken to the landfill and correlating that log with
the weight tickets received from the landfill for each truck unloaded by city trucks. Truck logs for July and
August 2019 were available at the transfer station office and reviewed.
7. Monthly tonnage reports for the current fiscal year were available for review at the Municipal Services Office.
The report for the month of July 2019 indicated that 600.94 tons of MSW were received at the transfer station;
and, the August 2019 tonnage report indicated that 419.92 tons of MSW were received.
8. Random waste screening records were available onsite at the transfer station office. Mr. Curry stated that
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Solid Waste Section
random inspections are conducted on at least every 10' load as it enters the transfer station. Records for the
period January through July 2019 were reviewed and found to be complete.
9. Mr. Curry stated that waste screening is also conducted by route drivers during curbside collection because
unacceptable wastes found in residential curbside containers is increasing. He displayed some photos that
drivers had taken over the past month or two, and stated that the city's garbage trucks are being outfitted with
cameras to help identify unacceptable materials before they are picked up in the collection vehicle.
10. Facility staff training records were available at the Municipal Services Office. A review of these records found
that the following city staff are currently certified by NCSWANA as Transfer Station Operations Specialists:
Elmer Curry — expires 4/14/2021;
Ivan M. Cabiness — expires 11/3/2019;
Mark Boyer —expires 11/15/2021;
Kris Long —expires 11/15/2021.
Mr. Curry stated that Mr. Cabiness had been registered for transfer station operations specialist class in order to
renew his certification.
11. The facility accepts only latex and oil -based paints in the HHW program. Latex paints are solidified and placed
in the transfer trailer for disposal as they are received. Oil -based paints are disposed of through the city's HHW
contractor, Ecoflo, Inc. The facility's operations plan requires that paint be removed from the facility for
disposal at least every 6 months. HHW program records indicated that oil -based paints were collected by Ecoflo
and removed from the facility on December 18, 2018 and on May 17, 2019.
Field Inspection:
12. The entire facility was observed to be clean and well -maintained. Windblown litter was well -managed. Mr.
Curry stated that convenience area staff police the facility throughout the day, as time permits, to ensure that
windblown litter is collected and returned to the transfer station.
13. Grass had been mown at the facility and the fence line was free from weeds and windblown litter.
14. The site is enclosed by chain link fencing and secured by two locking gates to prevent unauthorized access.
15. The entire site is paved, and sufficient space is provided for the safe maneuvering of both residential vehicles
and city trucks.
16. A new hopper and compactor system had been installed in July 2018. The integrity of the new equipment helps
to prevent windblown litter at the facility.
17. The recycling convenience area had been redesigned and now includes the HHW collection area, which was
relocated. These improvements make the site easier for attendants to manage; provide safer, easier access for
residents; and, afford a new, reliable containment system for containers of paint that are stored before being
poured up into drums or mixed with sand for solidification.
18. The entire convenience area was observed to be clean and well -organized.
19. In addition, a new office building had been positioned inside the gate, allowing site attendants to see all
incoming vehicles as they enter the site.
20. The HHW collection area is covered and was observed to be well -maintained, with new, lined containment
areas on which paint could be stored prior to bulking or solidification. Only a few cans of oil -based paint were
stored in this area at the time of the inspection.
21. A trailer, located next to the covered HHW storage area, contained two 55-gallon drums into which oil -based
paint had been poured. The drums were properly closed and appeared to be clean and intact, with no leaks
evident. The trailer also contained a drum used for the solidification of latex paint, and bagged cans that had
been accumulated from the recycling program.
22. The tipping floor occupies one bay of the transfer station building and is bordered by concrete curbing that
confines leachate and directs it into the hopper, which drains onto the concrete loading area below.
23. The tipping floor was found to be clean and in fair condition. Some cracking and eroding of the concrete were
evident, but the damage was not extensive enough to allow leachate to reach the ground below the concrete pad.
24. The other bay within the transfer building was being used to store equipment and curbside toters. Mr. Curry
stated that this area was being converted into a white goods storage area. He explained that the white goods
containing refrigerants would be staged in the building so that they were upright and spaced so that the gas
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U.paN td—im-1 Quality
Solid Waste Section
could be efficiently extracted by the city's contractor.
25. A pile of white goods and scrap metal was observed on the grassy area outside the transfer building. Mr. Curry
stated that the white goods container had been removed and the replacement had not yet arrived. He added that
staff would be moving the CFC-containing white goods into the building over the next few days, and only the
remaining scrap metals would be stored in the roll -off container. Mr. Curry also pointed out a vacant spot at the
northern end of the recycling convenience area where a scrap metal container would be staged.
26. The covered area to the northwest of the transfer building was serving as another storage area for curbside
containers. This area had previously been used to accumulate aluminum and steel cans for recycling. Can
recycling containers had been incorporated into the new recycling convenience area on the southeast side of the
facility, eliminating the need for residents to drive to the transfer area for drop-off.
27. A trench drain is located directly under the trailer loading space. The drain was found to be clear and
functioning properly. Leachate from the hopper flows into this drain and then to a separating pit. Mr. Curry
stated that city staff inspect the pit regularly and ensure that it is pumped out as needed to ensure uninterrupted
flow in the leachate collection system. He added that the trench drain is cleaned out daily, and more often if
needed.
28. The leachate collection system is contained in the trailer loading and storage area and is paved with concrete.
Elevated concrete at both ends serves to corral liquid and direct it to a curb drain that is part of the leachate
collection system as well. Leachate is pumped from the facility's collection system to the city's wastewater
treatment plant, located across the street from the transfer station, for proper disposal.
29. At the time of this inspection, one trailer was fully loaded and ready to be transported to the landfill for
disposal. This trailer was found to be in good condition, with no holes or leaks evident. However, the area on
the outside front of the trailer had accumulated some waste — several pieces of plywood and some
miscellaneous trash. Mr. Curry stated that this waste would be cleaned out and the waste returned to the tipping
floor prior to the trailer leaving the facility. The hitch area of the trailer, used to connect with the compactor for
loading, was clean and free of loose trash. (See photos below.)
30. An additional trailer was seen pulling into the facility as it returned from unloading at the landfill. This trailer
was also found to be in good condition, with no visible leaks or holes visible.
31. Some waste had accumulated in the area around the compactor and on the outside of the hopper. Mr. Curry
pointed out a toter and shovel located next to the compactor and explained that this waste is collected and
placed in the toter prior to an empty trailer being hooked up to accept waste.
32. A small pile of litter was observed in the loading dock area of the former residential recycling drop-off. Mr.
Curry stated that the entire site is inspected and cleaned daily. Please ensure that all waste is collected and
returned to the transfer station or transfer trailer at the close of every operating day. (See photo below.)
LeLt: View of the
front of a transfer
trailer with waste
accumulation.
(Photo taken by S.
Heim 9-19-19.)
Right. View of the
same trailer clean,
with waste
removed. (Photo
provided by facility
staff following the
inspection.)
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OepaNnen� e� Envimmenlal Oualiry
Solid Waste Section
White goods containing 1
refrigerants have been moved to a
staging area in the spare bay of the
transfer building. (Photo taken by
facility staff following the
inspection.)
Scrap metal and white goods were
staged outside the transfer station
awaiting a replacement roll -off
container. (Photo taken by S. Heim
9-19-19.)
-flow -An—
The new, covered HHW/electronics
collection area. (Photo taken by S.
Heim 9-19-19.)
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
oepamnem a� enmranmemai a�ai
The new, covered, residential recycling
drop-off area provides clear directions and
easy access for customers. (Photo taken by
S. Heim 9-19-19.)
Solid Waste Section
Waste accumulation at the loading
dock of the former residential
recycling area. (Photo taken by S.
Heim 9-19-19.)
Please contact me if you have any questions or concerns regarding this inspection report.
-i Digitally signed by Susan Heim
DN: cn=Susan Heim, o=Solid
Waste Section, ou=Field
Operations Branch,
email=[e-mail]
,c=US
Date: 2019.09.26 13:30:28
-04'00'
Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative
Sent on: September 26, 2019 to
X
Email
Hand delivery
US Mail
Certified No. [ 1
Dusty Curry.
Copies: Deb Aja, Western District Supervisor — Solid Waste Section
David Giachini, Permitting Engineer — Solid Waste Section
Paul Dishmon, Municipal Services Director — City of Eden
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