10003_ROSCANS_2010

FACILITY COMPLIANCE AUDIT REPORT,
Division of Waste Management
Solid Waste Section
Page 10 of 10
8. The receiving bay was littered with loose trash. This needs to be cleaned daily. (This has been an on -going
problem.)
9. On September 25, 2009, there were small amounts of waste on the tipping floor that was left from the previous
day's operations - Permit condition # 13 requires: The "tipping floor" and "transfer trailer loading area"
shall be maintained in a clean, sanitary condition after operating hours in accordance with the approved
Operations Plan and shall be cleaned at least daily.
10. The "upper" leachate underground storage holding tank appeared to be less than half full. On January 28, 2010 a
total of 4,000-gallons of liquid was removed from all three tanks and disposed of by STAT, Inc of Lenoir, NC. On
March 25, 2010 a total of 4,500-gallons of liquid was removed from all three tanks and disposed of by STAT.
11. The individual capacity of each of the three leachate holding tanks must be determined and documented.
12. There was very little windblown trash at the transfer station.
13. Waste from the transfer station is hauled to the Foothills Landfill in Lenoir, NC by a trucking company under
contract to GDS.
WHITE GOODS COLLECTION AREA
1. Scrap metal and white goods are picked up by Tri-State Metal of Asheville.
2. There was one semi -trailer filled with scrap metal, waiting to be removed from the site. Loose scrap
metal littered the area under and around this semi -trailer. (This has been an on -going problem.)
3. Liquid Propane (LP) tanks are separated for recycling.
4. Automobile gasoline tanks are separated for recycling. (These tanks should be perforated, or otherwise
rendered unusable, to ensure that they do not contain any liquids.)
Please contact me if you
have any questi s r oncerns regarding this audit report.
Phone: [phone]
Bill Wagner, Environmental Senior Specialist
Regional Representative
Second Mailing - October 13, 2010
Certified Mail - 7009 1680 0000 7614 8192
on: 10/06/10 by
hand delivery
--[Delivered
US Mail
X
Certified No. 7008 0150 0000 7473 4776
c: Charles Vines, Mitchell Co. Manager
C7 Carporati ni System — R� gistered Agent far Republic Services of NC, LLC
ec: Brandon Randolph, Yancey Co. - Solid Waste Director
Donald Miller, GDS
Ray Hoffman, Republic Services of NC, LLC
Drew Isenhour, Republic Services of NC, LLC
Mark Poindexter, Field Operations Branch Head — Solid Waste Section
Deb Aj a, Western District Supervisor — Solid Waste Section
Donald Herndon, Compliance Officer — Solid Waste Section

Division of Waste Management
Solid Waste Section
Page 10 of 10
8. The receiving bay was littered with loose trash. This needs to be cleaned daily. (This has been an on -going
problem.)
9. On September 25, 2009, there were small amounts of waste on the tipping floor that was left from the previous
day's operations - Permit condition # 13 requires: The "tipping floor" and "transfer trailer loading area"
shall be maintained in a clean, sanitary condition after operating hours in accordance with the approved
Operations Plan and shall be cleaned at least daily.
10. The "upper" leachate underground storage holding tank appeared to be less than half full. On January 28, 2010 a
total of 4,000-gallons of liquid was removed from all three tanks and disposed of by STAT, Inc of Lenoir, NC. On
Mar -eh 23—,2040-a-total-of-4;500-gallons-of liquid-was-r-er-neved-from-all-three—tags-and-di-sposed-of—by-S-T-AT.
11. The individual capacity of each of the three leachate holding tanks must be determined and documented.
12. There was very little windblown trash at the transfer station.
13. Waste from the transfer station is hauled to the Foothills Landfill in Lenoir, NC by a trucking company under
contract to GDS.
WHITE GOODS COLLECTION AREA
1. Scrap metal and white goods are picked up by Tri-State Metal of Asheville.
2. There was one semi -trailer filled with scrap metal, waiting to be removed from the site. Loose scrap
metal littered the area under and around this semi -trailer. (This has been an i on -going problem.)
3. Liquid Propane (LP) tanks are separated for recycling.
4. Automobile gasoline tanks are separated for recycling. (These tanks should be perforated, or otherwise
rendered unusable, to ensure that they do not contain any liquids.)
Please contact me if you have any qu s 'ons or concerns regarding this audit report.
Phone: [phone]
Bill Wagner, Environmental Senior Specialist
Regional Representative
Delivered on : 10/06/10 by
hand delivery
US Mail
X
Certified No. 7008 0150 0000 7473 4783
To: CT Corporation System
c: Charles Vines, Mitchell Co. Manager
CT Corporation System — Registered Agent for Republic Services of NC, LLC
ec: Brandon Randolph, Yancey Co. - Solid Waste Director
Donald Miller, GDS
Ray Hoffman, Republic Services of NC, LLC
Drew Isenhour, Republic Services of NC, LLC
Mark Poindexter, Field Operations Branch Head — Solid Waste Section
Deb Aja, Western District Supervisor — Solid Waste Section
Donald Herndon, Compliance Officer — Solid Waste Section

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1. Article Addressed to:
CT Cc,patatioi System, Re,tatered Agent fe!
Repabii: Se"ices of Nakiii Carolina, LLC.
P.O. Bar, 1011
Raleigh, PIC 77502-101.1
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1. Article Addressed to:
I Nathan eennett, County hfanager
Yancey County
119 TOV-19 Square, Room 11
Burnsvflfe, NC 2871
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2. Article Number I 7008 0150 0000 7473 4806
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S Form 3811, February 2004 Domestic Return Receipt 102595.02-M

Wagner, Bill
From: Nathan Bennett [[e-mail]]
Sent: Friday, October 15, 2010 4:55 PM
To: Wagner, Bill
Subject: Yancey -Mitchell Transfer Station - NOV Response 9 24/25/2010 Audit
Attachments: LETTER - DENR- Solid Waste Section- Letter to Bill Wagner - NOV Response from
0924-252010 Audit - 10142010.pdf; Transfer Station - Republic Response to 0924252010
NOV.pdf
ase see a ache— a ers one from the counties and t e other from Republic Services in response to your Facility Compliance
Audit Report of 9/24 and 9/25/2010 for the Yancey -Mitchell Transfer Station. Original placed in US First Class Mail today.
Thanks,
Nathan
Nathan R. Bennett
Yancey County Manager
110 Town Square, Room 11
Burnsville, NC 28714
Phone: [phone]
Fax: [phone]
E-Mail: [e-mail]

Al 1M REPUBLIC ►
SERVICES OF NC, UC '�
October 11, 2010
Department of Environment and Natural Resources
Division of Waste Management
Solid Waste Section
2090 US Highway 70
Swannanoa, North Carolina 28778
Attention: Mr. Bill Wagner
Environmental Specialist
Re. Facility Compliance Audit Report, Yancey Mitchell Transfer Station, dated 9124ZI0 & W25/10
Dear Mr. Wagner,
Republic Services of North Carolina, LLC (Republic) is submitting our response to your Notice of
Violations, #1, 92 a-e and #3 from your September 24 and 25, 2010 site audits at the Yancey -Mitchell
Transfer Station. In addition, this letter will provide information on actions that were taken as a result of
past noted violations from your October 1, 2009 site audit.
Violation #1
In response to the violation of 15A NCAC 13B .0105(c), pertaining to the leaking trailers:
Republic has directed our 3d party hauler to maintain and replace trailer seals and to tighten these seals as
needed to prevent these leaks. In addition, the contractor is supposed to clean up and remove any spilled
materials on a daily basis. As a secondary measure, Republic has purchased and will install by the end of
this month, portable catch basins. These catch basins will be positioned behind and underneath the
tailgate of all loaded and parked trailers to prevent any leaks from reaching the ground surface. These
basins will be emptied into the leachate storage tank on a daily basis. Liquids may be solidified prior to
disposal using a bentonite, kitty litter or soil mix.
Violation #2
1n response to the violation of 15A NCAC 13B .0203(d), pertaining to failure to abide by the following
permit conditions:
a. "...ensure that the transfer station is operated in accordance with the Solid Waste Management
Rules... conditions contained in the permit, and the approved plan."
Republic will review the Solid Waste Management Rules (specific to transfer stations and leachate
management), the Operating Permit and the approved Operations Plan with Site Management and
Facility staff.
PO Box 2943 • Hickory, NC 28603 . 828.464-2414 • 866-473-7778 Toll Free • 828.464-2433 Fax
www.ropublicservicesofne.com

b. "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 in accordance with the approved
Operation Plan."
Republic will clean the tipping floor and trailer loading area at the end of each day. The daily
cleaning will include the complete removal of all waste from the floors, walls, ledges and drains for
proper disposal. On a quarterly basis or more frequently if needed, floors and walls will be pressure
washed and documented -This work will -be completed -I y October 1-6;-201-0 after alI drains are —
determined to be functioning properly and tanks have been pumped down.
c, "Waste may be stored on -site, in leak proof transfer trailers, with watertight covers, a maximum
of 24 hours except that a minimal amount of waste may be stored for a maximum of 72 hour,
when the facility is closed during a weekend or holiday..."
"...semi -trailer leaking on the 24" and same trailer leaking on the 25"'..."
This does not appear to be a violation of the 24-hour or 72-hour allowance as approved. The
issue with the leaking trailer has already been identified and address under Violation #1.
"...two roll -off boxes, uncovered, overnight..."
Both roll -off boxes will be removed and replaced with two front load boxes, The front load
boxes are covered and will beemptied at the transfer station as needed. This will be
completed by the end of the month.
d. "Effective vector control measures must be applied at all times..."
Republic will implement the attached, Vector Control Program (Attachment A), for this facility.
e. "The leachate control system...must be operational during facility operations... drains appeared to
be restricted..."
Republic will clean the floor drains and flush the leachate collection lines after both tanks are pumped
down. This will be completed by October 16t'.
Violation #3
In response to the violation of 15A NCAC 13B .0402(3), pertaining to water contacting solid waste
being contained on -site or properly treated prior to discharge from the site:
"One semi -trailer was leaking leachate in an uncontrolled manner onto bare ground."
The issue with the leaking trailer has already been identified and addressed under Violation #1. The
leachate that leaked from the parked transfer trailer wasl contained on-site�and did not discha from
the site.
Republic has directed our Yd party hauler to maintain and replace trailer seals and to tighten these
seals as needed to prevent these leaks. In addition, the contractor is supposed to clean up and remove
any spilled materials on a daily basis. As a secondary measure, Republic has purchased and will
install by the end of this month, portable catch basins. These catch basins will be positioned behind
PO Box 2943 • Hickory, NC 28603 • 828-464.2414. 866.473.7778 Toll Free • 828.464.2433 Fax
www.eepublieservicesofne.cam

and underneath the tailgate of all loaded and parked trailers to prevent any leaks from reaching the
ground surface. These basins will be emptied into the leachate storage tank on a daily basis. Liquids
may be solidified prior to disposal using a bentonite, kitty litter or soil mix.
October 1, 2009
As noted in the most current audit on page 3 of 10, no response to the October 1, 2009 audit was
- required—For-clar-i-fication—R€publie-will-respond now to-the-V-iolations-*17# -2-and-#3-of-what-actions
were taken.
Violation #1
"...failing to ensure that three semi -trailers... were leak proof..."
Republic took immediate action by notifying the Yd party hauler of this infraction and informed them
of their contractual obligation to maintain and replace trailer seals and to tighten these seals as needed
to prevent these leaks and to stay in compliance with State and Federal rules. The contractor was also
required to install solid tarps to comply with the conditions of the approved Operations Plan,
Violation 42
"...failing to ensure that three semi-trailers...were leak proof ...and fitted with watertight covers..."
Republic took immediate action by notifying the Yd party hauler of this infraction and informed them
of their contractual obligation to maintain and replace trailer seals and to tighten these seals as needed
to prevent these leaks and to stay in compliance with State and Federal rules. The contractor was also
required to install solid tarps to comply with the conditions of the approved Operations Plan.
Violation #3
"...three semi -trailers leaking leachate onto bare ground and/or asphalt ... must be contained on -site or
properly treated prior to discharge from the site."
Republic took immediate action by notifying the P party hauler of this infraction and informed them
of their contractual obligation to maintain and replace trailer seals and to tighten these seals as needed
to prevent these leaks and to stay in compliance with State and Federal rules. The contractor was also
required to install solid tarps to comply with the conditions of the approved Operations Plan.
The leachate that leaked from the three, parked transfer trailers was contained on -site and did not
discharge from the site.
Conclusion
Republic understands the importance of eliminating the release of leachate into the environment and
will continue to work towards solutions to prevent these events from occurring. As noted from your
two audits, we have successfully reduced the problem from three trailers down to one. We believe
that our continued vigilance on cleaning, replacing and maintaining trailer seals, along with the use of
solid tarps to reduce moisture into the loads and with the addition of the catch basins, that we can
eliminate any future events.
PO Box 2943 • Hickory, NC 28603 • 828.464.2414 • 866-473.7778 Toll Free • 828.464.2433 Fax
www.ropublicsorvicesofne.com

As for the cleaning requirements and operational changes needed at this facility, everything is being
implemented as quickly as possible with planned completion by the end of this month, A refresher
operator's training will be conducted on October 14`h at the site, We will update you on our progress
as items are completed. If you have any questions or comments, please contact me at 828-695-2055.
Sincerely,
REPUBLIC SERVICES of NC. LLC
Mr. Raymond J. Hoffman, P.E.
Area Engineer
Cc: Drew Isenhour, Republic
j Don Phelps, Republic
Jeff McCree, Republic
i
PO Box 2943 Hickory, NC 28603 • 828-464.2414. 866.473.7778 Toll Free • 828.464-2433 Fax
www.ropublieservicesofne.com

REPJBLIC
t,!► SERVICES
ATTACHMENT A
VECTOR CONTROL PLAN — TRANSFER STATIONS
1. Remove all trash from transfer station floor and loading pit area daily,
2. Clean boors and walls as needed to reduce available food sources.
3. Install and maintain rodent traps.
4. Hire a licensed exterminator to spray inside and around the transfer station building on a quarterly
basis.
PO Box 2943
Hickory, NC 28643
828,464.2414 9 Fax [phone]
Toll Free 866.473.7778
www.republicservices.com

Nathan Bennett, C,outrty Manager
Walter Savage, Chairman
YANCEY COUNTY Johnny
nyRddle,C:ommissioner
11.0 Town Square, Room 11 • Burnsville, North Carolina 28714
PHONE: [phone] • FAX: (828) 682,4.301
Mr. Bill Wagner
NCDENR — Solid Waste Section
2090 US Highway 70
Swannanoa, NC 28778
Dear Mr. Wagner:
SENT VIA FIRST CLASS MAIL
and ELECTRONIC MAIL
to: bill.waguer(�nedenr.gov
I am in receipt of the NCDENR Facility Compliance Audit Report for the Yancey -Mitchell Transfer
Station from an audit dated September 24 and 25, 2010. This report was received in my office by certified
mail delivery on October 7, 2010. Let me state clearly, the Counties and Republic Services take these
alleged issues seriously and are working to correct them to the satisfaction of the NCDENR.
I have been in discussion with the management of Republic Services, the contracted operator of the
Yancey -Mitchell Transfer Station, since receipt of this notice and have worked diligently with them to
develop a course of action. Additionally, the Counties continue to employ the services of Altamont
Environmental to assist and directly address these issues on our behalf. Furthermore, I am in receipt of the
written response of Republic Services to NCDENR dated October 1 1, 2010 and find that it fully and
adequately addresses each issue noted in your audit. `i'herefore, I will not address these corrective actions
again but will direct you to the Republic response on behalf of the Counties.
Earlier today, I met with Republic Services senior management and engineers, as well as their local
operations staff, together with Mr. Paul Dow from Altamont Environmental at the transfer station. Republic
officials reviewed each identified violation and their response with Mr. Dow and me. I am satisfied that the
corrective actions taken will ensure that the transfer station is continued to operate within all state rules and
regulations.
Please let me know if I can provide further information or assistance.
Sincerely,
NATHAN R. BENNETT,
Yancey County Manager
Enclosure: Republic Services Response Letter
dated October 1], 2010
CC: Charles Vines, Mitchell County Manager
Paul Dow, Altamont Environmental
Don Phelps, Republic Services