9233T_WC NOV Response for EWTS_20221020

Environmental
Services
TO:Tim Davis, Environmental Senior Specialist, NCDEQ, Solid Waste Section
FROM:Roy Baldwin, Solid Waste Facilities Manager-Projects, Wake County Solid Waste
DATE:October 20, 2022
SUBJECT:East Wake Transfer Station Facility Notice of Violation Follow Up
This memo is in response to the Notice of Violationreceived on September 20, 2022. Wake County values our partnership with NCDEQ and is working diligently to ensure that we are in full
compliance with NCDEQ rules and regulations. All issues aside from those waiting for lab results fromsoil samples or are part of the planned Capital Improvement Project have been remedied
as instructed by your office. As discussed during the site inspection and on other occasions throughout this fiscal year, the County has a Capital Improvement Plan for the East Wake
Transfer Station (EWTS). The latest bid submittal received was still significantly over budget however, the County is still pressing for an early Winter start date for this project.The
vendor selected for this project, Leak and Associates,is currently developing a time schedule, and this will be shared with NCDEQ as soon as we receive it. In accordance with the requested
30-day response, please see below the responses and actions taken by the Wake County Solid Waste Management Division (WC) and Stafford Transport of NC (CEI) to address the items identified
in the Report.
1. Ensure that all windblown waste throughout the facility, including (but not limited to) the employee parking area and exterior fencing, the entry and exit areas of the transfer trailer
loading bay and surrounding grounds, and under and around the plastic sheeting in the riprap along the eastern wall of the transfer station is collected and disposed of properly.
These areas have been cleaned and are now being monitored throughout the day instead of just during the closure process. A full-time staff member is assigned to litter control efforts
only. Switch-out personnel is now conducting twice-daily cleanups in the bays at 9 am and 1 pm while switching trailers to avoid build-up and to prevent the trash from being pulled onto
access roads. At the end of the day, staff will sign a new daily checklistdeveloped by WC staff which will be available in the main office to provide proof of this process. WC staff
will review the daily forms each week to make sure they are completed.
2. Clear waste and dirt from all leachate drains to maintain free-flowing conditions.
The drains have been extensively cleaned. Cleaning of the drains is part of the nightly closure process and is part of the daily checklist that is available in the main office providing
proof of this process.
3. Scrape all accumulated sludge from the access roads and tipping floor apron and dispose of it properly.
CEI has scraped and cleaned off the built-up sludge from the access road hill and tipping floor apron using a skid steer and two squeegee brushes. This initial cleaning took place on
9/23/22 after hours and the second round of cleaning took place after hours on 10/1/22.
4. Install physical measures or implement operational procedures to stop, catch, and/or contain leachate leaking from collection vehicles waiting to dump waste on the tipping floor.
Trucks observed leaking may need to be moved into the WTS or another area within the leachate collection system.
Since haulers are responsible for maintaining their equipment by state laws, WC decided to send an official email to all licensed haulers on 9/26/22 reminding them of state laws and
the County’s ordinance regarding maintaining leak-resistant vehicles and containers. Starting 10/1/22, any violators spotted by CEI staff, arebeing reported to WC staff for follow-up
investigation. Additionally, WC and CEI are discussing a plan to queue all incoming vehicles at the base of the hill during rainy days to help prevent leaking while stationary on a hill.
A sand pile has been procured by CEI to deal with any egregious spillage.
5. Remove all plastic rolling garbage bins being stored adjacent to the facility access road to the south of the transfer building and dispose of their contents properly. Remove all
remaining waste, remove and dispose of all stained soils in this area, and evaluate subsurface soils for contamination.
This process is being handled by the City of Raleigh with coordination by WC staff to maintain a proper timeline of completion. An initial email to Perry Sugg with DEQ was sent with
Tim, Stan, Sadel, and Nathaniel from the COR all copied on 9/21/22. A follow-up Teams Meeting was coordinated by WC staff and included DEQ, COR, and CEI representatives on 9/26/22 to
discuss testing procedures for the contaminated soils. DEQ agreed to allow WC/CEI and COR to hire their own consultants to perform the soil testing. A follow-up meeting was scheduled
by WC staff on behalf of the COR to attend an on-site walk-through with DEQ on 9/28/22 to discuss the contaminated areas in question by COR staff. The walkthrough took place on 9/28/22
with representatives from DEQ, COR, and WC. Instructions were provided to COR at this meeting on expectations for remediation. As of 10/14/22 dirt had been excavated from the site and
samples were being collected.
6. All stained soils located in the transfer truck parking and repair areas and adjacent to the transfer trailer cover area must be removed and disposed of properly. Subsurface soils
in this area need to be evaluated for contamination.
An on-site inspection by CEI & WC staff on 9/23/22 verified the areas of concern noted in the NOV by the DEQ inspectors. Mat Cologne with CDM Smith has been acquired to handle the testing
on behalf of both parties. An overhead aerial Google map was created by WC staff to highlight the areas of concern and this map was shared with DEQ personnel at the 9/26/22 joint meeting.
DEQ staff agreed with the highlighted areas on the map and gave the go-ahead for CDM Smith to submit their preliminary action site plan to Jackie Drummond with DEQ. This plan was submitted
to DEQ on Thursday, 9/29/22. On 10/4/22, DEQ responded that the plan was approved and on 10/6 soil samples were taken, and the remediation of the contaminated soils was completed. The
soil samples were submitted to the lab on 10/7/22 and results are pending.
7. A plan must be submitted to the Section for the soil removal and sampling of the areas impacted by the leachate from leaking containers and garbage accumulation. Within 5 days of
receipt of this report, please contact Perry Sugg at [e-mail] for guidance on the plan requirements and sampling protocols.
WC staff sent an initial email to Mr. Sugg on 9/21/22 asking for his guidance. Mr. Sugg replied on 9/22/22 and directed WC staff to work with Jackie Drummond at DEQ. A joint task force
meeting was scheduled and coordinated by WC staff with Ms. Drummond on 9/26/22. Ms. Drummond and DEQ Inspector Tim Davis agreed that the preliminary plan can be delivered by EOB on Friday,
9/30/22. This plan was submitted on 9/29/22 in accordance with the timeframe set forth by DEQ.
CC: Jason Watkins, Field Operations Branch Head – Solid Waste Section
Andrew Hammonds, Eastern District Supervisor – Solid Waste Section
Chris Hollinger, Compliance Officer – Solid Waste Section
Diana Felix, Permitting Engineer - Solid Waste Section
Stan Joseph, Solid Waste Director – City of Raleigh
John Roberson, Solid Waste Management Director – Wake County Solid Waste
Wendy Allred, Terminal Manager – CEI