4120_NOD_20220413

April 22, 2022

CERTIFIED MAIL 7020 1810 0001 2074 5057 RETURN RECEIPT REQUESTED

City of Greensboro Transfer Station
6310 Burnt Poplar Road Greensboro, NC 27409

SUBJECT: Notice of Deficiency Compliance Inspection Report
City of Greensboro Transfer Station
41-20T Guilford County

Dear Mr. Hennis:

On April 13, 2022, Chuck Kirchner, representing the State of North Carolina, Division of Waste Management
Solid Waste Section (Section), inspected the above referenced facility for compliance with North Carolina solid waste statutes and rules. Mark Hennis was present and represented the City of Greensboro during this
inspection. The following violations were noted:

A. 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 – Part I, Number 6 states “Operation of this solid waste management facility shall be in accordance with the North Carolina Solid Waste Management Rules, 15A NCAC 13B; Article 9 of the Chapter
130A of the North Carolina General Statutes (N.C.G.S. 130A-290, et seq.); the conditions contained in this
permit; and the approved plan. Should the approved plan and the rules conflict, the Solid Waste Management Rules shall take precedence unless specifically addressed by permit condition. Failure to comply may result in
compliance action or permit revocation.” Permit to Operate - Attachment 3, Part II, Number 8 states “All water
that comes in contact with solid waste, including vehicle wash-down water, is leachate and must be captured
and properly treated before release to the environment.” Permit to Operate Operations Plan dated November
28, 2018 (DIN 27044) Section 4.2 states in part “Leaking trailers will have drip pans placed beneath the trailer
to contain leaks. Leachate, collected in the drip pans, is disposed through the sanitary sewer system.”
B. 15A NCAC 13B .0405(c) states: “All vehicles and containers being used for the temporary storage of
solid waste shall be maintained to be leak resistant in accordance with Rule .0105 of this Subchapter, or shall
be stored so that any leachate from the vehicles or containers will be collected to prevent the release of leachate
to the environment.”

On April 13, 2022, leachate was observed leaking from two transfer trailers onto the ground at the City of
Greensboro Transfer Station. There were no drip pans in place to capture the leachate leaking from the transfer
trailers. Any leachate that leaked out of the trailers was not captured or properly treated before being released
to the environment. The vehicles were not maintained to be leak resistant or stored so that any leachate from
the vehicles or containers were collected to prevent the release of leachate to the environment.

City of Greensboro
Notice of Deficiency
Page 2 of 2
April 22, 2022

The above violations may have or can compromise the facility’s ability to ensure protection of the public health
and the environment and thus require remedial action on behalf of the facility in order to maintain compliance
with 15A NCAC 13B .0203(d) and 15A NCAC 13B .0405(c). Based upon the foregoing, the City of Greensboro
shall come into compliance immediately with all requirements of the regulations in 15A NCAC 13B .0203(d) and 15A NCAC 13B .0405(c) by completing the following at the City of Greensboro Transfer Station:

1. Leachate must be captured or properly treated before being released to the environment.
2. Vehicles must be maintained to be leak resistant or stored so that any leachate from the vehicles or
containers will be collected to prevent the release of leachate to the environment.
The violations 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.
Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct a follow-up
inspection to verify that the operator has completed the requirements of this Notice of Deficiency.

If you have any questions, please contact me at 336-776-9633 or e-mail [e-mail].
Sincerely,

Chuck Kirchner
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section

copies: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Chris Hollinger, Compliance Officer