7903_INSP_20210819

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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: Rockingham
MSWLF
PERMIT NO.: 7903T-TRANSFER-1991,
Closed
HEW
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: August 19, 2020
FACILITY NAME AND ADDRESS:
Date of Last Inspection: October 15, 2020
City of Eden MSW Transfer and HHW Collection Facility
123 Mebane Bridge Road
Eden, NC 27288
GPS COORDINATES (decimal degrees): Lat.: 36.476696'
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Dusty Curry, City of Eden Solid Waste Superintendent
Telephone: [phone] (mobile)
Email address: dcurrykedennc.us
FACILITY CONTACT ADDRESS:
City of Eden
Municipal Services Department
Solid Waste Division
1050 Klyce Street
Eden, NC 27288
Long.:-79.740287'
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)
Permit renewal: July 20, 2015.
Transfer Station Life of Site Permit issued: August 26, 2020.
HHW Permit Renewal issued: August 26, 2020; expires: August 22,2025.
PURPOSE OF SITE VISIT:
Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS:
N/A
OBSERVED VIOLATIONS:
April 3, 2013.
15A NCAC 13B .0405(e)(4) states: "Signs shall be posted at the site entrances unless otherwise stated in
the site permit. The signs shall be constructed of a durable, weather -resistant material. The signs shall
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
be clear and legible to the public. The signs shall state the name of the operator of the site, emergency
contact information, the operating hours of the site, the permit number of the current permit
authorizing operations at the site, the types of waste that can be accepted under the permit, and that
hazardous waste and liquid waste cannot be accepted at the site. " The City of Eden is in violation of
15A NCAC 13B .0405(e)(4) for failing to post required signage at the site entrances.
To come into compliance, the City of Eden must post proper signage at the transfer station site entrances
by September 15, 2021.
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. Photos included in this report were taken by Susan Heim on August 19, 2021, during the inspection unless
otherwise noted.
2. 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 is not open to the public and only
receives waste from city trucks that collect household trash and bulky waste curbside. The HHW collection
program accepts only paint and is only open to city residents.
3. 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 and used cooking oil. Televisions and computer equipment are no
longer accepted at the site, and residents are directed to take electronics to the Rockingham County Landfill
(permit # 7904) for recycling.
Records Review:
4. The life of site Permit to Operate (dated August 26, 2020) and approved Operation Manual (revised August 20,
2020) are available for review at the Municipal Services Office. Mr. Curry had the expired permit and old
Operations Plan available at the transfer station for review. Links were provided to him after the inspection, and
Mr. Curry stated that he had printed copies of the current permit and operations plan and added them to the
records at the transfer station office. Ensure that a copy of the current Permit to Operate and current
approved Operation Manual are maintained at the transfer station as required by 15A NCAC 13B
.0405(d).
5. A review of the 2020-2021 facility annual report indicated that a total of 7,739.75 tons of MSW were received
at the transfer station during the previous fiscal year. In addition, the facility collected a total of 68.76 tons of
source -separated recyclables during that same time frame.
6. The facility tracks tonnage by logging each transfer truckload taken to the landfill and correlating that
information with the weight tickets received from the landfill. Truck logs are available at the transfer station for
review as required.
7. Waste screening records from April 20, 2020 through August 12, 2021 were reviewed and found to be
complete, including the disposition of any unacceptable waste found in the load. Based on tonnage received
during the previous fiscal year, it appears that, by performing one waste screening per operating day, the facility
is inspecting more than 5% of the incoming waste as required by 15A NCAC 13B .0405(a (8Z )(A) — the rule may
be accessed by clicking on this link. Please ensure that waste screening records are maintained by the City
of Eden for a period of at least 5 years, as specified in the new rule adopted January 1, 2021.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
8. White goods and scrap metals are collected and marketed to a metal recycler after refrigerants are removed.
White goods program records are available for review at the Solid Waste office.
9. The following city staff are currently certified by NCSWANA as Transfer Station Operations Specialists:
• Elmer Curry — expires 4/14/2024;
• Mark Boyer — expires 11/15/2024;
• Kris Long —expires 11/15/2024;
• Ivan Cabiness —expires 11/3/2024.
10. The facility accepts only latex and oil -based paints in the HHW program. Facility staff solidify latex paints as
they are received. The solidified paint is placed directly in the transfer trailer for disposal at the Rockingham
County Landfill. 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. A review of
the HHW program records indicated that the oil -based paints had been collected by EcoFo for disposal on
August 10, 2020, and May 31, 2021. Mr. Curry explained that, based on EcoFlo's COVID-19 staffing
constraints, materials were not collected within the normal 6-month window.
11. Facility staff are required to participate in a monthly safety training that relates specifically to HHW and
transfer station operations. Training records for the period of September 2020 through August 2021 were
reviewed and verified.
Facility Inspection:
12. Unauthorized access is prevented by the chain link fencing which surrounds the facility, and the facility is
secured by two locking gates. The eastern gate provides residents access to the convenience area where they can
drop off household recyclables and HHW materials. The western gate is used only by facility staff to access the
transfer station.
13. The entire site is paved, and traffic flow is designed to ensure the safe maneuvering of both residential vehicles
and city trucks.
14. The facility was observed to be clean and well -maintained. Windblown litter was well -managed, and all facility
roadways, parking, and storage areas were free of debris.
15. Grassy areas are mowed and trimmed regularly, and the fence line was found to be free of weeds and
windblown litter.
16. The entire convenience area was found to be clean and well -organized.
17. The HHW collection area is located within the recycling convenience center so that facility staff can assist
residents and monitor the incoming materials to ensure that no unacceptable wastes are dropped off.
18. HHW collection takes place on a covered gravel pad where used oil and oil filters are also collected. A lined
containment area, located on the north side of the pad, is filled with sand so that any material spilled is easily
confined and removed. Incoming latex paints are stored on pallets within the containment area prior to bulking
or solidification. Two containers that held paint being solidified were found outside of the containment area.
Mr. Curry provided photos via email following the inspection confirming that all HHW containers and materials
had been stored within the containment area. Ensure that all HHW materials are always stored within the
containment area.
19. Used motor oil and oil filters are collected in the front portion of the containment area. A plastic oil tank and
plastic drum for filters are accessible for residents dropping off these materials. Both the tank and drum
appeared to be in good condition with no leaks visible. However, the tank had a build up of oil and dirt around
the fill port, and some oil had been spilled onto the gravel outside of the containment area. Mr. Curry provided
photos via email following the inspection confirming that the oil tank had been cleaned and the contaminated
gravel surrounding it had been removed for proper disposal and replaced. Ensure that the oil tank and
surrounding area are maintained so that any spilled oil is cleaned up as it occurs.
20. Facility staff take oil -based paint and paint products directly to a trailer beside the pad and pour them into 55-
gallon drums for storage until they are removed by the facility's disposal contractor, EcoFo, Inc., for proper
disposal. The drums were properly closed and appeared to be clean and intact, with no leaks evident. Containers
and bags filled with separated recyclable materials are also housed in the trailer while awaiting sale. The trailer
was observed to be clean, and containers were neatly stored to prevent damage. Fire extinguishers are located
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NORTH CAROLINAD_E Q��
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
just inside the trailer entrance, and the tag attached indicated the last annual inspection date was October 2020.
The trailer is locked when the facility is not operating.
21. Source separated recyclable materials are collected in toters on another covered gravel pad. In addition, a
collection vehicle, provided by the JCR Recycling, is parked in the convenience area and is used to collect clean
cardboard for recycling. Mr. Curry stated that the cardboard recycler has been dependable, removing and
replacing the truck when it fills without delay.
22. The transfer station building is located on the high point of the site, west of the convenience area. 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. From the hopper, leachate drains onto the concrete loading area below. A small
amount of debris was noted at the tipping point, directly in front of the hopper; the remainder of the tipping
floor was clean and free of waste. Mr. Curry stated that the entire tipping area is washed down throughout the
day as needed, and at the end of every operating day.
23. The tipping floor was found to be intact. No large holes or cracks were observed that could allow leachate to be
released from the collection system.
24. A new gate had been installed so that the tipping point at the hopper could be better secured between loads. Mr.
Curry also pointed out a steel truck barrier that had been constructed in front of the hopper that is designed to
stop truck tires and prevent vehicles from backing up too far.
25. The second bay within the transfer building is now used to store white goods units that contain refrigerants.
These units were found to be stored upright to prevent damage to coils and compressor systems during storage.
Non -refrigerant -containing white goods, white goods that have had refrigerant removed, and scrap metal are
stored in a roll -off container onsite prior to being marketed for sale.
26. The leachate collection system is contained in the trailer loading and storage area and is paved with concrete.
Elevated curbing at both ends effectively contains the leachate and directs it to a curb drain on the south side of
the loading area. Leachate is pumped from the collection system to the city's wastewater treatment plant,
located across the street from the transfer station, for proper disposal. At the time of this inspection, the wire
mesh covering the curb drain had solids accumulated on it but appeared to be functioning properly. Mr. Curry
stated that the drain is hosed down at the end of each workday, and more frequently if necessary.
27. Three transfer trailers were observed at the facility. One trailer was hooked to the compactor unit and was
partially filled with waste. A second trailer was empty and ready to be moved into position at the compactor,
and the third trailer was empty and parked on the south side of the western access road. All three trailers were
found to be clean and in good condition, with no holes or leaks evident. Mr. Curry stated that the third trailer is
not used at this time and is scheduled to be replaced in the new budget year.
28. The area around the compactor was wet, and Mr. Curry stated that the rails and structural parts of the compactor
are hosed off after each full trailer is removed and before a new trailer is pulled into position to load.
29. The entire loading/leachate collection area was observed to be clean and well -maintained.
30. As noted in the report covering the previous inspection on October 15, 2020, the sign at the entrance to the
facility does not currently include the facility permit number or emergency contact information. Mr. Curry
explained that new signs had been ordered after the previous inspection, but that the staffing shortages resulting
from the pandemic had prevented the signage from being prepared. Please consult the Life of Site Permit to
Operate general facility permit condition #7 and 15A NCAC 13B .0405(e)(4) for specific sign
requirements and ensure that proper signage is installed at the transfer station on or before September
15, 2021. (See Observed Violations section of this report for additional information)
31. Site cleaning and pressure washing requirements specified in 15A NCAC 13B .0405(a)(11) were discussed. Mr.
Curry stated that he would adopt procedures for meeting the requirements and keep a log of pressure washing
activities in the transfer station office. He explained that the facility has pressure washing equipment, and that
staff would be handling the new cleaning requirements. Following the inspection, Mr. Curry supervised the
pressure washing of the facility and noted the date in a new maintenance and cleaning log for the transfer
station. He also provided photos of the pressure washed building via email. Cleaning and pressure washing
requirements can be found by clicking on this link: 15A NCAC 13B .0405(a)(11).
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NORTH CAROLINAD_E Q��
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Curb drain with accumulated debris observed during the
inspection.
A view of the compactor and
loading area. The elevated
curbing that encloses the
leachate collection system is
visible in the foreground.
Curb drain at the end of the workday. (Photo provided
by A Curry 8119121.)
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NORTH CAROLINAD_E Q��
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
A view of the HHW and oil collection area. The lined
containment area is filled with sand to absorb any spills.
Note the containers stored outside of the containment area,
and the spilled oil on the tank and the gravel in front of it.
The HHW and oil collection area after cleaning. (Photo
provided by C. Curry 8125121.)
A view of the inside of the transfer station building
following pressure washing. The walls, floors and
hopper are free from waste and debris. (Photo
provided by D. Curry 8125121.)
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NORTH CAROLINAD_E Q��
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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.
gov,c=US
Date: 2021.08.26 08:42:22
-04'00'
Susan Heim
Environmental Senior Specialist
Regional Representative
Phone: [phone]
Sent on: August 26, 2021, to
X
Email
Hand delivery
US Mail
Certified No. [ ]
Dusty Curry.
Copies: Deb Aja, Western District Supervisor — Solid Waste Section
Paul Dishmon, Public Works Director — City of Eden
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