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HomeMy WebLinkAbout9242_INSP_20221012FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 6 UNIT TYPE: Lined MSWLF LCID YW Transfer X Compost SLAS COUNTY: WAKE Closed MSWLF HHW White goods Incin T&P X FIRM PERMIT NO.: 9242-TRANSFER-2020 9242-MWP-2020 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: October 12, 2022 Date of Last Inspection: June 30, 2022 FACILITY NAME AND ADDRESS: Wall Recycling – Garner Road 2126 Garner Road Raleigh, NC 27610 GPS COORDINATES: Lat.: 35.750541° Long.: -78.633386° FACILITY CONTACT NAME AND PHONE NUMBER: Dan McGowan, President, Wall Recycling, 732-423-1604, dmcgowen@wallrecycling.com Dan Wall, CEO Wall Recycling, 919-650-8353, dan@wallrecycling.com Dan Jarboe, Wall Recycling, 919-906-2747, djarboe@wallrecycling.com FACILITY CONTACT ADDRESS: Wall Recycling, LLC 2310 Garner Road Raleigh, NC 27610 PARTICIPANTS: Tim Davis, NCDEQ, Solid Waste Section Drew Hammonds, NCDEQ, Solid Waste Section Dan McGowen, Wall Recycling Dan Jarboe, Wall Recycling Dustin Hill, Wall Recycling Dan Wall, Wall Recycling STATUS OF PERMIT: Permit to Construct and Permit to Operate issued August 17, 2020. Life of Site Permit issued for 9242-Transfer-2020 and will expire on August 17, 2080. Permit to Operate for 9242-MWP-2020 will expire on August 17, 2025. The Permit renewal paperwork should be submitted by February 17, 2025. PURPOSE OF SITE VISIT: Follow Up Partial Compliance Inspection STATUS OF PAST NOTED VIOLATIONS: MSW Transfer Station A. Permit Approval to Operate, Attachment 3, Part VI, (20) (a) & (b), “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. The leachate control system, such as floor drains, leachate collection devices, sanitary sewer connections, and leachate storage tanks, must be operational during facility operations. The tipping floor must drain away from the building entrance and into the leachate collection system.” During this inspection, leachate was observed draining from the transfer trailer loading bay floor into an FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 6 unlined trench drain. There are no berms or containment measures within the transfer trailer bay and the trench drain does not appear to be connected to a leachate collection system. This unlined drain allows leachate to come into direct contact with the ground and flow along the property line and potentially onto the adjacent property. All water that comes in contact with waste is considered leachate and should be collected and disposed of as leachate. Ensure that the trench drain is connected to the leachate collection system so that the water is collected and properly disposed of. The impacted soils in this area must be removed and disposed of properly and subsurface soils evaluated for contaminants. RESOLVED: Concrete berms were installed at the transfer trailer loading bay entry and exit points to redirect leachate back into the leachate collection system. The unlined trench drain has been filled and sealed with concrete, preventing leachate to come into direct contact with the ground. A sampling plan and supporting documentation was submitted to and approved by the Section, and sampling was satisfactorily conducted. Mixed Waste Processing Area B. The operations plan approved by the Section states: “C&D and MSW operations will occur inside the metal building or under roof and will be unaffected during rain events. Some C&D processing operations may occur outside the building for inert debris materials such as concrete, asphalt and clean soils.” During this inspection it was noted that all C&D waste was continuing to be dumped and processed outside of the building and without cover. Ensure C&D waste other than some inert debris as approved is processed inside the metal building or under roof and that all facility operations are being conducted according to the Section approved operations plan. UNRESOLVED: C&D waste is continuing to be dumped and processed outside of the building and without cover. OBSERVED VIOLATIONS: Mixed Waste Processing Area A. Permit Approval to Operate, Attachment 3, Part VII (25) (f), “Control measures must be utilized to minimize and eliminate visible dust emissions and blowing litter. During this inspection, as in the previous 5/3/2022 and 6/30/2022 inspections, large amounts of dust were observed in the area where the unapproved mixed waste was being processed and loaded into trailers. A water truck was not in use or located at the site during this inspection. Ensure that a water truck or other method of water application is utilized to reduce the dust emissions from the facility. ADDITIONAL COMMENTS: MSW Transfer Station 1. 15A NCAC 13B .0405 (a) (11), “Site Cleaning and Maintenance: Unless otherwise stated in the site permit, all waste shall be removed from the tipping floor, the truck loading bays, and from behind push walls by the end of each day of operation and disposed of in accordance with this Subchapter. The tipping floor, push walls, and truck loading bays shall be cleaned with a pressure washer no less than once per month. The remaining areas of the site building include side walls and any material storage areas outside of the building shall be cleaned with a pressure washer no less than twice per year. Wash water generated from cleaning waste handling areas shall be contained and treated as leachate.” The tipping floor and the floor and walls of the transfer trailer loading bay were covered in dirt and grime. Waste was observed behind the push walls. Waste was also observed along the supporting beams and wall ledges within the transfer trailer loading bay. 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. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 6 Ensure that the tipping floor and the transfer trailer loading bay is pressured washed in accordance with the rules or more frequently as necessary. Ensure all waste behind the push walls and within the transfer trailer loading bay is picked up and disposed of at the end of the operating day. Mixed Waste Processing Area 1. 15A NCAC 13B .0402 (a) The owner or operator of a transfer station (site) shall comply with the conditions of the permit issued by the Division. 2. 15A NCAC 13B .0402 (d) The owner or operator may submit an application for a permit amendment or modification in accordance with G.S. 130A-294 (a3). The filing for a permit modification or amendment, or a notification of a significant change in accordance with G.S. 130A-295.2(g), does not stay any existing permit condition. The facility operator submitted an application for a permit modification on August 12, 2022. However, the modification has not been approved at this time. The owner/operator must follow the current permit and approved operations plan. 3. The operator has expanded a concrete storage and processing area to the west of the approved area. This facility must operate in accordance with permit and approved operations plan. Unapproved changes to the operational area and footprint of the facility will require approval. Please follow the Permit and approved operations plan for this facility. Any changes to the design or operations of this facility should be submitted to permitting for review and approval before going forward. 4. Permit Approval to Operate, Attachment 3, Part VII (25) (c), “Waste must not be stored on the “tipping floor” after operating hours.” During this inspection, as in the previous 5/3/2022 and 6/30/2022 inspections, the excavator was observed sitting on top of a pile of comingled fine and large construction and demolition (C&D) waste outside of the designated MWP area. This pile is waste and must be removed from by the end of the operating day. The operator is not permitted to dump C&D waste outside of the building and should cease doing so. Please provide photos showing waste has been removed from this area. 5. 15A NCAC 13B .0301 (i)(2), “Sites that received a permit from the Division prior to the readopted effective date of this Rule shall comply with the rules of this Section with the following exceptions: (2) if a building, structure, or waste handling area was constructed prior to the readopted effective date of this Rule, and is expanded beyond the existing permitted operational boundary after the readopted effective date of this Rule, the permitted operational boundary that was existing on the readopted effective date of this Rule shall not be required to comply with Paragraph (a) of this Rule, but the expansion areas shall comply with these requirements.” During this inspection, a large pile of commingled waste, which included concrete debris, metal, wood, plastic, and other miscellaneous wastes, was being stockpiled southwest of the C&D waste processing area and within 100 feet of the western and southern property lines. This pile of comingled waste is not surrounded by an unused and cleared area of no less than 25 feet. Concrete processing and storage areas have increased in size since the previous inspection. The stockpiling or storage of waste is prohibited within 100 feet of property lines and any stored waste must be surrounded by a cleared area of no less than 25 feet. Ensure all commingled waste including the crushed mixed waste in this area is removed and disposed of properly at a permitted landfill. 6. During this inspection, a large pile of segregated cardboard was located adjacent to the MSW processing area. Leachate was observed seeping from this pile and pooling next to a concrete berm. Mr. Wall stated that the cardboard pile would be moved under roof by the end of the operating day. Various end products or Recyclables should be loaded into open top containers and or dump trucks for shipment off site. This includes the cardboard, metal or any additional materials pulled from the waste stream. 7. Corrective measures are necessary as a result of this inspection and should be underway. 8. Failure to bring the site into compliance will result in additional enforcement actions. 9. Digital photographs were taken during the inspection. Please contact me if you have any questions or concerns regarding this inspection report. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 6 ________________________________________ Phone: (919) 707-8290_______ Tim Davis timothy.davis@ncdenr.gov Environmental Senior Specialist Regional Representative Sent on: October 21, 2022 X Email Hand delivery US Mail X Certified No. [ _] Copies (email): Jason Watkins, Field Operations Branch Head – Solid Waste Section Drew Hammonds, Eastern District Supervisor – Solid Waste Section Sherri Stanley, Permitting Branch Head – Solid Waste Section Dan Wall – Wall Recycling Dan Jarboe – Wall Recycling Photographs taken by Tim Davis during the October 12, 2022 inspection. View of concrete berm with filled & sealed trench drain. View of filled & sealed trench drain. View of waste along wall ledges in transfer trailer loading bay. View of waste behind push walls. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 6 View of C&D waste operations occuring outside with visable dust emmissions. View #2 of C&D waste operations occuring outside without cover. View of excavator on top of C&D waste pile. View of concrete and commingled waste stockpile along rear and side property lines. View #1 of commingled waste within concrete stockpile. View #2 of commingled waste within concrete stockpile. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 6 View #3 of commingled waste within concrete stockpile. View of the south side of commingled waste pile. View of segregated cardboard pile.