9808_BlackCreekTS_asssessmentletter_20220711

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MICHAEL SCOTT NORTH CAROLINA
Director Environmental Quality
July 11, 2022
Sent via email: [e-mail]
Mr. Michael Lee, Operations Supervisor
Black Creek Transfer Station
3031 Black Creek Road
Wilson, North Carolina 27893
SUBJECT: Transfer Station Assessment Report, Revised Operating Plan, Closure Plan, and
Closure Cost Estimates
Black Creek Transfer Station, Permit 9808T-TRANSFER-2000, Wilson County
Waste Industries, LLC, subsidiary of GFL
Dear Mr. Lee,
The State of North Carolina, Division of Waste Management, Solid Waste Section (Section) has
completed the review of the Transfer Station Assessment Report (report) for the above
referenced facility. The report was submitted by Smith Gardner Engineers on June 18, 2021, in
accordance with 15A North Carolina Administrative Code 13B .0401(b).
The intent of the report was to self -assess and demonstrate compliance with the rules in 15A
NCAC 13B .0400, readopted effective January 1, 2021, with a primary focus of vital
infrastructure at the facility as part of transitioning under the new rules and other life of site
permit requirements.
The findings of the report, based on an inspection, included: clogged leachate floor drains that
were cleared during the inspection, outside wall damage to two sides that were being repaired
during the inspection, and minor cracks in pavement.
In summary, the report recommended that the facility continue to monitor the concrete pad
pavement and outside panel walls for wear and damage, and repair as needed, and continue to
monitor the leachate drains to clear clogs.
Based upon our review, the Section agrees with the recommendation for continuing to monitor
and repair the pavement and outside panel wall damage, as needed.
However, the Section disagrees with the recommendation to continue to monitor the leachate
system for clogging and clear as needed. A review of inspection reports over the last 10 years
shows that clogging of the leachate drains is a continual problem. Copies of inspection reports
D E Q�� North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
NORTH CAROLINA -
gepartmem of EnvimnmeM l quay /`� 919.707.8200

are attached. Operational maintenance alone has not shown to be an acceptable method of
compliance with leachate drainage and collection for this site. Inspection reports in 2013
indicated that replaced leachate piping in 2012 may have been too small. Based on these
findings and history, the Section finds the condition of the leachate collection drain system is
not as originally designed or constructed.
The Section requests that you provide a response to the leachate collection drain system issues
noted above.
Also, per the report recommendations, please submit a revised Operations Plan, Closure Plan,
and closure cost estimates to include all information now required by 15A NCAC
13B .0404, .0405 and .0406.
The requested leachate collection response, revised Operations Plan and Closure Plan, and cost
estimates should be submitted to the Section within 90 days of receiat of this letter.
The Section has established an electronic form for the submittal of Transfer Station closure cost
estimates and requests you submit the cost estimates in this manner using the following link:
https://edocs.deg.nc.gov/Forms/TransferStation FA.
The .0401 to .0406 Transfer Station Rules can be viewed at the link below, beginning on pdf
page 17:
http://reports.oah.state.nc.us/ncac/title%2015a%20-%20environmental%20guaIity/chapter%2013%20-
%20solid%20waste%20management/subchapter%20b/subchapter%20b%20rules.pdf
If you have any questions, please contact me at 919-707-8255 or [e-mail].
Sincerely,
Donna J. Wilson
Environmental Engineer
Solid Waste Section
Attachment
Email copy:
Crystal Slone, GFL
Lou J. Krasuski, Smith Gardner
Michael Brinchek, Smith Gardner
John College, SWS
Drew Hammonds, SWS
Sarah Moutos - SWS-ARO