2908_INSP_20210518

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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: Davidson
MSWLF
PERMIT NO.: 2908-TRANSFER-2013 and
Closed
HHW
White
Incin
T&P
X
FIRM
MSWLF
goods
2908-TP-
FILE TYPE: COMPLIANCE
CDLF
TireT&P
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: May 18, 2021
FACILITY NAME AND ADDRESS:
Todco, Inc. Wood Recycling Facility
1123 Roy Lopp Road
Lexington, NC 27292
Date of Last Inspection: August 11, 2020
GPS COORDINATES (decimal degrees): Lat.: 35.82872 ° Long.:-80.17377 °
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Todd Warfford, President
Telephone: [phone] (office); [phone] (mobile)
Email address: todd(ikodcoinc.com
FACILITY CONTACT ADDRESS:
Same as above
PARTICIPANTS:
Todd Warfford, President — Todco, Inc.
Dalton Warfford — Todco, Inc.
Susan Heim, Environmental Senior Specialist — Solid Waste Section
STATUS OF PERMIT:
Transfer Station Life of Site Permit to Operate: issued October 4, 2018; expires June 10, 2073.
Treatment & Processing Permit to Operate: issued October 4, 2018; expires June 10, 2023.
PURPOSE OF SITE VISIT:
Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS:
None.
OBSERVED VIOLATIONS:
None.
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.
Page 1 of 6

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
ADDITIONAL COMMENTS:
1. The facility is permitted as a C&D transfer station and wood waste treatment and processing facility.
2. The facility operates under two separate permits. The transfer station permit (2908-TRANSFER-2013) has been
issued as a life of site permit; the treatment and processing permit (2908-TP) must be renewed in 2023.
3. Todd Warfford stated that he is working on plans to enlarge the facility office and the equipment maintenance
shop. He explained that these plans would not impact the permitted operations or the configuration of the
existing transfer station and treatment and processing facility.
4. The transfer station has been inactive since 2019, due to market fluctuations, and the staffing and space required
to separate the recyclable materials from the C&D waste. Please contact Susan Heim at 336-776-9672, or via
email at susan.heim(&ncdenr.gov, to schedule an inspection prior to resuming operations at the transfer
station.
5. Todd Warfford stated that he is considering a plan to reconfigure the transfer station so that all operations would
occur in an enclosed space, thus allowing manual sorting to take place as waste is received and in all weather
conditions. He discussed extending the existing transfer structure straight out to the west on the existing
concrete pad to allow C&D waste to be unloaded directly onto an enclosed tipping floor.
6. Please note that any changes to the facility or to facility operations may require a modification of the
facility's permit to operate. Contact Jordan Russ, Permit Engineer, at 919-707-8229, or via email at
9ordan.russ(&ncdenr.2ov, to discuss any possible changes and the permitting requirements and timelines
they may involve.
Records Review:
7. The permitted service area for the facility consists of Cabarrus, Davie, Forsyth, Guilford, Montgomery,
Randolph, Rowan, Stanley, and Davidson Counties.
8. The facility's Permit to Operate and approved Operations Manual (revised May 31, 2018) are maintained at the
facility office/scale house and are available for review upon request.
9. Todd Warfford stated that no C&D waste had been received at the transfer station during the current fiscal year.
10. Tonnage records were provided via email following the inspection, as requested. A review of these records
yielded the following information: 16,309.70 tons of wood waste has been received at the facility during the
period July 1, 2020 through April 30, 2021, averaging 1,631 tons per month. This volume is consistent with the
average monthly tonnage rate of 1,592 tons per month received at the facility during FY 2019-20.
11. Training records indicated that three facility staff are currently certified by NCSWANA as Transfer Station
Specialists;
• Brian Warfford — Certification Number TS-2016019 — expires March 23, 2022;
• Dalton Warfford— Certification Number TS-2013032 —expires April 16, 2022;
• Todd Warfford — Certification Number TS-2013033 — expires April 16, 2022.
12. No waste screenings were performed at the transfer facility because the facility did not operate in FY 2020-21.
Field Inspection:
13. The entire facility was observed to be clean and well -maintained.
14. Access roadways are of all-weather construction, made up of compacted soil and gravel. All roadways were
found to be maintained in good condition. No equipment ruts or ponding water were visible during the
inspection.
15. The facility appeared to conform with buffer requirements.
16. The facility is protected from unauthorized entry by two sets of locking gates. Wooded areas and natural terrain
prevent entry from other points around the property.
17. Proper signage, including facility permit number and contact information, was observed at the entrance. A sign
listing acceptable and prohibited wastes was posted at the scale house, where incoming loads of wood waste are
screened, weighed, and directed to the appropriate unloading area.
Page 2 of 6

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
18. Each incoming load is spread out and inspected prior to being pushed into one of the wood waste stockpiles.
Todd Warfford explained that any trash or contamination is removed and stored in the facility's waste
receptacle prior to being transported to the Davidson County Landfill (permit #2906-MSWLF-2008) for proper
disposal.
19. Mulch/vegetative waste operations and boiler fuel operations are staged in separate areas to prevent cross -
contamination.
20. Brush, land clearing debris and clean wood waste are ground for mulch. Material may be ground several times
to produce the specific grade of mulch needed. The processed material is then stored in piles on the north end of
the property. No composting takes place at this facility. Instead, mulch piles are turned regularly to prevent
temperatures from rising.
21. Only a small inventory of mulch was stored in the designated area. The few remaining mulch piles were
observed to be of a manageable size, and the storage area was found to be neatly maintained. Fire lanes and
perimeter roadways had been designed to provide adequate access to facility staff and emergency equipment.
No ponding water was observed in the mulch storage area.
22. Vegetative wood waste specifically selected for coloring is separated after grinding and moved to the covered
tipping floor formerly used by the transfer station operation. Todd Warfford stated that color processing
requires the mulch to be kept dry, so storage in a weatherproof area is a key element in successful colorizing.
Colored mulch is then stored in the concrete storage bins as product.
23. A tipping area for incoming loads of vegetative wood waste is located straight ahead and southeast of the scale
house. The area is well -maintained to prevent mud from becoming an issue for vehicles entering and exiting the
area. Grinding of vegetative waste was taking place in this area during the inspection. A small pile of wood
waste had been separated from the rest of the pile and set to the side. Dalton Warfford stated that this separated
material would be incorporated into the stockpile that would later be ground for boiler fuel. No unacceptable
waste was observed in this area.
24. Clean wood pallets were stockpiled on the large cement pad south of the tipping area, along with several piles
of processed wood waste. No grinding operations were taking place in this area at the time of the inspection.
The area was found to be clean and well -maintained.
25. The color processing unit was in operation during the inspection. An equipment operator was observed moving
ground material from the covered tipping floor to the color processing line, where liquid color is added to the
mulch and the finished product is directed to an open spot in the product storage area. From there, the colored
mulch is moved to one of the concrete bunkers that serve as product storage areas.
26. Due to the dry conditions at the site, some dust was observed both from the grinding area and from the
conveyor system that feeds the color processing equipment. However, no fugitive dust was observed outside of
these immediate operations areas.
27. Processed wood waste to be sold as boiler fuel is stockpiled on the southern portion of the site along with bark
that is brought to the facility as finished product and offered for sale to customers. Piles were found to be of
manageable size with fire lanes designed to provide easy access for facility or emergency equipment.
28. Hose bibs and fire extinguishers are located in key spots around the facility in case of fire and also for use in
controlling dust generated from grinding operations when necessary.
29. In addition to the mulch identified for color processing, the C&D transfer station tipping floor was being used to
store a large inventory of lumber that had been acquired from a customer going out of business. The lumber was
palletized and elevated off the tipping floor. The fabric canopy of the transfer building appeared to be intact and
in good condition. The picking line was idle and clean, with no accumulated waste visible.
30. The product storage area is located immediately south of the scale house and consists of a series of concrete
bunkers that hold various sizes and types of stone, sand, and mulch. This area is paved and well -maintained so
that it is easily accessed by customers and facility equipment operators.
31. A cleared area south of the permitted facility was visible from the transfer station. The area appeared to serve as
a storage location for roll -off containers and dumpsters. Todd Warfford stated that this acreage is currently
being leased to Best Disposal, and that no facility operations or product storage take place there.
32. The management of surface water at the site is accomplished through a series of drainage swales, inlets and
drainpipes that direct the water into permanent sediment traps or to rock spillway outlets from which it can
sheet flow away from the facility. These erosion control devices were observed to be clear and functioning
Page 3 of 6

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
properly. No ponding water was observed on the site, and no evidence of erosion was noted.
A view from the facility entrance with the approach to the scales on the left and the road to the product
storage/sales area on the right. The facility is clean and well -maintained.
The mulch storage area has only a small amount of inventory remaining. The stockpile on the right is unprocessed
wood waste that will be ground for boiler fuel.
The land clearing and yard waste area provides adequate space for loads to be dropped off and spread out to be
screened for unacceptable materialprior to beingprocessed. Note the grinding operations takingplace at left.
Page 4 of 6

NORTH CAROLINAD_E Q��
OepeNnenf of Envlronmmbl 0w1�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
The covered tipping floor of the inactive transfer station currently serves as a storage location for waste lumber
waiting to be processed and for mulch that will be run through the color processing unit.
Processed wood waste being colored. Product storage bunkers are located adjacent; the end of the row of bunkers can
be seen at left.
Page 5 of 6

NORTH CAROLINAD_E Q��
OepeNnenf of Envlronmmbl 0w1�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Clean woodpallets andprocessed wood waste stockpiles are staged on the concrete pad of the main operations area.
The covered tipping floor of the transfer station is visible in the center background.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Susan
Heim
DN: cn=Susan Heim,
L y J o=Solid Waste Section,
ou=Field Operations
Branch,
email=susan.heim@ncdenr.
gov,c=US
Date: 2021.05.20 16:00:28
-04'00'
Susan Heim
Environmental Senior Specialist
Regional Representative
Phone: [phone]
Sent on: May 20, 2021 to Todd
X
Email
Hand delivery
US Mail
Certified No. [ ]
Warfford.
Copies: Deb Aja, Western District Supervisor — Solid Waste Section
Jordan Russ, Permit Engineer — Solid Waste Section
Page 6 of 6