3416_INSP_20191010

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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: October 10, 2019
FACILITY NAME AND ADDRESS:
Overdale Road Transfer Station
5000 Overdale Road
Winston-Salem, NC 27101
Date of Last Inspection: August 13, 2019
GPS COORDINATES: Lat.: 36.033263 ° Long.:-80.231984 °
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Carldell "Pat" Patrick, Operations Manager — Republic Services
Telephone: [phone] (mobile); 336-714-4301 (office)
Email address: [e-mail]
FACILITY CONTACT ADDRESS:
Republic Services
2875 Lowry Street
Winston-Salem, NC 27101
PARTICIPANTS:
Sandra Lucas, Scale House Operator — Republic Services
Pat Patrick, Operations Manager — Republic Services
Derek Bouchard, Environmental Manager — Republic Services
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:
Partial Inspection
STATUS OF PAST NOTED VIOLATIONS:
A. CORRECTIVE MEASURES IN PROGRESS: 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." 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
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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
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."
Mr. Patrick explained that a new inspection report form has been developed that includes all of these
inspection items except the transfer trailers. He further stated that this new monthly inspection procedure
had been implemented in September, and he provided the facility inspection book containing the signed
September inspection sheet for review. The new checklist covered all of these inspection points, excluding
the transfer trailers. Mr. Patrick stated that the transfer station operator, Joseph Prestandrea with K R
Drenth Trucking, had begun inspecting all trailers prior to their use; individual trailer inspections are
logged on individual inspection checklists. He explained that trailer inspections had been implemented in
September. Ms. Lucas stated that the trailer inspection records were not being maintained at the scale
house, and that Mr. Prestandrea was keeping them in his truck. Copies of the trailer inspection records
were provided by email following the inspection and appeared to be complete, beginning on September 30,
2019. To achieve compliance, Republic Services must maintain records of all inspections at the scale house.
B. CORRECTIVE MEASURES IN PROGRESS: 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."
Significant progress had been made in cleaning up the facility since the previous inspection on August 13,
2019. The sheet metal walls and deflector panels in the loading bay appeared to have been pressure washed,
and the buildup of waste was minimal. However, the walls on the opposite (left) side of the transfer station
were much dirtier, giving the appearance that they had not been cleaned in the same manner as the loading
bay. Sheet metal patches had been fitted to the outside of the loading bay wall, covering the large openings
that had been observed during the previous inspection. Mr. Patrick and Mr. Bouchard noted that there
were portions of the sheet metal wall, especially near the bottom, that are corroded and torn, indicating
that additional repair and maintenance are needed. Mr. Bouchard stated that replacement of the entire
sheet metal wall was under consideration, adding that he would provide additional information as decisions
were finalized.
Excluding the maintenance area, the right side of the tipping floor appeared to have been cleaned
thoroughly. There was no thick, gummy buildup on this part of the floor, allowing a much more thorough
inspection. Although the concrete floor was found to be worn and chipped, and some separation was
observed at the joints, no holes or deep gouges were evident. However, the portion of the tipping floor
closest to the loading bay had not been thoroughly cleaned, based on the thick coating of muck that was
observed there. The maintenance area had been neatened, but trash could be seen trapped throughout the
spare parts and clinging to the equipment stored there.
To achieve compliance, Republic Services must make additional repairs to the walls of the loading bay to
prevent waste from leaving the building; clear the tipping floor by removing all equipment and supplies
that are stored on the tipping floor that are not part of transfer operations, including the Conex container,
the trailer holding the pressure washing equipment, the oil drums and miscellaneous tools and maintenance
supplies; thoroughly clean the entire interior of the transfer building; and, implement procedures to ensure
that thorough daily cleaning of the transfer station takes place, so that the facility is maintained in a clean,
sanitary condition as required.
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D_E FACILITY COMPLIANCE INSPECTION REPORT
DO Ctd—iA Q�� Division of Waste Management
OepaNnen� e� Envimmemal Oualiry
Solid Waste Section
C. CORRECTIVE MEASURES IN PROGRESS: 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."
See Violation B above for corrective actions required to achieve compliance.
D. CORRECTIVE MEASURES IN PROGRESS: 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."
All of the trailers found at the facility, both empty and loaded, were inspected for damage to the walls and
floors that would allow waste and/or leachate to leak out. No such damage was identified, and none of the
trailers were observed to be leaking. In addition, procedures have been put into place to ensure that each
trailer will be inspected prior to being loaded. Mr. Bouchard pointed out that K. R. Drenth had brought
several new trailers to the facility to replace those that were in need of repair. Two of these new trailers
were onsite during the inspection and were observed to be designed differently, so that the area between
the rear and front axles was lower than the rest of the trailer floor, with less than a foot of clearance from
the ground, making inspection from the outside difficult. Mr. Bouchard mentioned the possibility of
obtaining a telescoping mirror that would allow facility staff to inspect the underside of the trailer floor. An
alternative would be inspection of the interior of these trailers.
To achieve compliance, Republic Services must develop and implement procedures that will allow complete
inspection of each trailer prior to loading and prevent the release of waste to the environment.
E. CORRECTIVE MEASURES IN PROGRESS: 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."
See Violation D above for corrective actions required to achieve compliance.
F. CORRECTIVE MEASURES IN PROGRESS: 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."
See Violation D above for corrective actions required to achieve compliance.
OBSERVED VIOLATIONS:
No additional violations were observed.
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.
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D_E FACILITY COMPLIANCE INSPECTION REPORT
NOFTH CAaOLiNA Q�� Division of Waste Management
U.paN tof—im-1 Quality
Solid Waste Section
ADDITIONAL COMMENTS:
1. 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 Uwhanie Environmental Landfill (permit No. 6204) and the Great Oak Landfill (permit no. 7607) for
proper disposal.
2. Modifications to the approved Operations Plan have been submitted to the Solid Waste Section for review.
The modifications include the addition of the Great Oak Landfill (Permit # 7607) as an approved disposal
facility. Procedural modifications will also be added to the revised Operations Plan to cover the new facility
and trailer inspections, and any changes to the housekeeping procedures that will be required of the
operations staff onsite.
3. New checklists have been designed by Republic Services staff to ensure that the facility and trailer
inspections required by the approved Operations Plan are implemented and incorporated into daily
operations. Ensure that copies of these and all facility inspection records are maintained at the scale
house and are available there for review upon request. (See Status of Past Noted Violations section of
this report for additional information.)
4. The tipping floor was inspected and the right (southeast) side, except in the "maintenance area," appeared to
have been thoroughly cleaned since the previous inspection on August 13, 2019. No thick, gummy buildup
was apparent in this area, making it possible to more closely inspect the integrity of the floor itself.
5. The left side (northwest) side of the tipping floor was still covered with the thick, gummy buildup that had
been observed during the previous inspection.
6. The far -right side of the tipping floor is currently being used by K. R. Drenth staff as a maintenance area. A
Conex container is staged against the right wall of the building, near the entrance to the tipping floor. Mr.
Patrick stated that the company stores tools and spare parts in the container, and conducts equipment
maintenance at the facility using these materials. At least 9 drums containing oil were stored behind the
container along the wall. Several of the drums were stored on plastic pallets; two were stored horizontally
on a rack with taps installed to afford easy access to the oil; one was sitting on top of a plastic milk crate
and the remaining drums were standing on the tipping floor. In addition, a small trailer, parked behind the
Conex container, held a pressure washer and large tote containing a liquid cleaning agent. Other
miscellaneous items in the maintenance area included what appeared to be a gasoline or diesel can, several
5-gallon plastic buckets (contents unknown), lengths of metal piping, various hand tools, plastic funnels,
and a number of plastic containers that apparently are used to hold and pour oil or fuel. Waste was trapped
in and around all of these items, resulting in unsanitary conditions. Ensure that the entire tipping floor is
cleaned daily, and that the facility is maintained in a clean, sanitary condition as required. (See Status
of Past Noted Violations section of this report for additional information.)
7. No barriers or walls separate the operations on the tipping floor from the maintenance area, creating the
potential for serious accidents, spills and other major safety concerns. In addition, no provisions for a
maintenance area are included in the facility Permit to Operate; and, no procedures or policies are
incorporated into the Operations Plan that describe or regulate this maintenance area. Remove all
equipment and supplies that are not part of transfer operations from the tipping floor. (See Status of
Past Noted Violations section of this report for additional information.)
8. Seams in the concrete, especially near the center and rear of the floor, were showing signs of wear and
separation. Mr. Bouchard indicated that bids for repairs to the floor would be requested, and a decision
made as to how to proceed based on the recommendations of the successful bidder. Ensure that the
integrity of the tipping floor is maintained so that leachate is not allowed to leave the collection
system.
9. Yard waste was observed in the waste on the tipping floor. Mr. Patrick stated that he would have facility
staff separate the yard waste from the MSW waste on the tipping floor and take it to the nearby Overdale
Yard Waste Facility (Permit # 3409) for proper disposal. Please provide a copy of the disposal receipt for
the yard waste observed on the tipping floor during the inspection to verify that this unacceptable
material was disposed of properly at a facility that is permitted to accept it. The receipt copy should
be emailed to: [e-mail].
Page 4 of 7

D_E FACILITY COMPLIANCE INSPECTION REPORT
DO Ctd—iA Q�� Division of Waste Management
OepaNnen� e� Envimmenlal Oualiry
Solid Waste Section
10. The loading bay appeared to be much cleaner than during the previous inspection on August 13, 2019. No
significant buildup of waste was observed on the walls and steel beams, and the floor drains appeared to be
clear and functioning properly.
11. The drain hole near the top of the inside loading bay wall allows leachate to flow from the tipping floor
down the wall into the floor drain that directs it to the oil/water separator and then into the line that connects
to the public sewer. The section of wall where leachate flows down to the floor drain was observed to be
coated with leachate residue, and the concrete appeared to be damaged from the corrosive properties of the
leachate. Mr. Bouchard commented that this area should be washed down on a frequent basis as part of
normal housekeeping procedures to maintain clean and sanitary conditions and to preserve the integrity of
the wall itself. Ensure that the inside loading bay wall beneath the tipping floor leachate drain is
cleaned frequently to prevent leachate buildup and unsanitary conditions.
Page 5 of 7

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oepamnem a� enmranmemai ouai�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Above: the bottom of the outside loading bay wall.
L: inside loading bay wall with leachate drain.
Conex container, miscellaneous equipment and supplies stored on the tipping floor in the "maintenance area. "
Waste can be seen around these items and built up on the exterior of the Conex container.
Page 6 of 7

NORTH CAROLINAD_E Q��
Oeparfinenf of EnvlrcnmeMal0aal�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Above: Oil drums, equipment,
miscellaneous tools and supplies
are lined up on the tipping floor
behind the Conex container.
LeLt: Waste is trapped in and
around metal pipe and rail
stored in the "maintenance
area. "
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.g
ov, c=US
Date: 2019.10.17 14:40:05
-04'00' Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative
Sent on: October 17, 2019 to
X
Email
Hand delivery
US Mail
Certified No.
Dennis Moriarty.
Copies: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor — Solid Waste Section
Ming-Tai Chao, Permit Engineer — Solid Waste Section
Derek Bouchard, Environmental Manager — Republic Services
Carldelle Patrick, Operations Manager — Republic Services
Sue Parks — K. R. Drenth Trucking, Inc.
Page 7 of 7