4118_INSP_20230418

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF LCID YW Transfer X Compost SLAS COUNTY: Guilford
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 41-18T
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: April 18, 2023 Date of Last Inspection: May 12, 2022
FACILITY NAME AND ADDRESS:
Republic Services of North Carolina, LLC Bishop Road Transfer Station 2140 Bishop Road
Greensboro, NC 27406 GPS COORDINATES: Lat.: 35.99294 Long.: -79.85348 FACILITY CONTACT NAME AND PHONE NUMBER:
James Reyburn, Operations Manager – Republic Services of North Carolina, LLC
336-294-9431
[e-mail]
FACILITY CONTACT ADDRESS:
Republic Services of North Carolina,
LLC Bishop Road Transfer Station
2140 Bishop Road Greensboro, NC 27406
PARTICIPANTS:
Chuck Kirchner, Environmental Senior Specialist – Solid Waste Section (SWS) Deb Aja, Western District Supervisor – SWS James Reyburn, Operations Manager - Republic Services of North Carolina, LLC STATUS OF PERMIT:
Permit To Operate (PTO) issued August 18, 2014 PTO expiration date October 12, 2024
PURPOSE OF SITE VISIT: Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS:
A. Status: Unresolved: 15A NCAC 13B .0405(a)(10) states: “Windblown waste: Site staff shall conduct daily
inspections for windblown waste on the site property. Windblown litter from site operations discovered during the daily inspections or observed on adjacent properties shall be picked up and containerized for disposal by the end of each operating day, unless the landowner of the adjacent property denies access to site staff. The site shall prevent
waste from being blown outside the waste handling areas by the wind, using methods such as: (A) requiring that vehicles entering and leaving the site keep waste covered; (B) providing skirts, such as rubber belting or brushes, around the top of chutes to minimize the space between the chute and the hauling trailer at sites with chutes and
hoppers; or (C) preventing waste from leaving the site using methods such as fencing, netting, or diking.”
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 8
On May 12, 2022, Republic Services of North Carolina, LLC was in violation of 15A NCAC 13B .0405(a)(10) in that windblown litter resulting from site operations was observed on the site property. The windblown litter was not being picked up or properly disposed of at the conclusion of each day of operation. During the inspection an accumulation of windblown waste was observed throughout the facility property and was observed off-property beyond the perimeter boundary along the northwestern side of the facility.
B. Status: Unresolved: 15A NCAC 13B .0405(a)(11) states in part: “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.”
On May 12, 2022, Republic Services of North Carolina, LLC was in violation of 15A NCAC 13B .0405(a)(11) in that a buildup of waste was observed in the loading bay. During the inspection an accumulation of waste was observed along the tipping floor walls and in the transfer station loading bay area, indicating that these areas are not being cleaned at
least daily.

OBSERVED VIOLATIONS:
A. 15A NCAC 13B .0203(d) states: By receiving solid waste at a permitted facility, the permittee shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the permit.” 1. Permit to Operate No. 41-18T ATTACHMENT I, PART I, General Facility Permit Condition # 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 (NCGS 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.”
a. Permit to Operate No. 41-18T approved Operation Plan, Section 3.1 states in part: “Throughout the day and at the end of each day, facility personnel will police the building and surrounding areas for any windblown litter.”, and “Any windblown litter discovered at the end of an operating day will be collected and stored in a transfer trailer vehicle, or an on-site trash bin for proper disposal.”
b. Permit to Operate No. 41-18T approved Operation Plan, Section 3.3 states in part: “Additionally, the facility shall randomly select two vehicles per week for random waste screening. The material from this load shall be spread, and a list of items in that load should be listed. This form shall be retained
by the facility.” 2. Permit to Operate No. 41-18T, ATTACHMENT 3, PART VI, Transfer Station/Treatment and Processing
Unit Condition #9 states, “The permittee must develop, and use, a training and screening program at the facility for detecting and preventing unauthorized wastes from being accepted at the facility. At a minimum, the program must include:
a. Random inspections of incoming loads or other comparable procedures. b. Records of all inspections. c. Training of personnel to recognize hazardous, liquid and other excluded waste types. d. Development of a contingency plan to properly manage any identified hazardous, liquid, or other excluded or unauthorized wastes. The plan must address identification, removal, storage and final disposition of these wastes.”
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 8
3. Permit to Operate No. 41-18T, ATTACHMENT 3, PART VI, Transfer Station/Treatment and Processing Unit Condition #10(a) states: “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 Operational Plan.” 4. Permit to Operate No. 41-18T, ATTACHMENT 3, PART VI, Transfer Station/Treatment and Processing Unit
Condition #10(e)(ii) states, “Windblown materials must be collected by the end of the day and no windblown material may be allowed to leave the facility boundary.” 5. Permit to Operate No. 41-18T, ATTACHMENT 3, PART VI, Transfer Station/Treatment and Processing Unit Condition #11 states in part, “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.” Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0203(d) in that:
• During the inspection the last recorded inspection of incoming loads was on October 8, 2021. Facility staff confirmed that random inspections of incoming loads were not being done at this transfer station.
• During the inspection an accumulation of waste was observed along the tipping floor walls and in the
transfer station loading bay area, indicating that these areas are not being maintained in a clean, sanitary condition and are not being cleaned at least daily.
• During the inspection an accumulation of windblown waste was observed throughout the facility property and was observed off-property beyond the perimeter boundary along the northwestern side of the facility.
• During the inspection a loaded transfer trailer was observed leaking leachate onto the ground from holes in the bottom of the transfer trailer. B. 15A NCAC 13B .0403(b)(2) states in part: “Tipping floors shall be located within an enclosed building or covered area to prevent precipitation from coming into contact with waste, and all waste shall be managed on the tipping floors unless otherwise stated in the site permit. For the purpose of the rules of this Section, "tipping floor"
means the area where waste is offloaded from residential or commercial vehicles and staged and consolidated for transport to its intended disposal location.” Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0403(b)(2) for failing to manage all waste on the tipping floor. During the inspection, the outer wall metal panels on the north side of the facility transfer trailer loading area were missing, and several panels were torn and partly detached from building, allowing waste to escape the building.
A view of the north side of the transfer station below the transfer trailers. Photographs taken by Deb Aja during the
April 18, 2023 inspection.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 8
C. 15A NCAC 13B .0405(a)(8)(A) states: “Waste Screening. Sites shall comply with the following waste screening requirements: (A) Site personnel shall screen incoming loads weekly at a rate of no less than five percent of the average daily waste tonnage reported in the site's annual report for the previous year. Site personnel shall be trained annually to identify liquid waste, hazardous waste, polychlorinated biphenyl (PCB) wastes, special wastes
as defined in G.S. 130A290(a)(40), wastes banned from landfill disposal in accordance with G.S. 130A-309.10(f) if the site receiving the waste for disposal is a landfill, and wastes that the intended final disposal site is not permitted by the Division to accept. The screening shall be conducted as described in the approved operations plan prepared in accordance with Rule .0404(i) of this Section. Waste screening and rejected wastes shall be recorded in writing, and the records shall be kept on site for no less than five years and shall be made available to the Division during a site inspection or upon request.”
Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0405(a)(8)(A) for failing to perform random inspections of incoming loads and record the inspections. During the inspection the last recorded inspection of incoming loads was on October 8, 2021. Facility staff confirmed that random inspections of incoming loads were not being done at this transfer station.
D. 15A NCAC 13B .0405(a)(10) states: “Windblown waste: Site staff shall conduct daily inspections for windblown waste on the site property. Windblown litter from site operations discovered during the daily inspections or observed
on adjacent properties shall be picked up and containerized for disposal by the end of each operating day, unless the landowner of the adjacent property denies access to site staff. The site shall prevent waste from being blown outside the waste handling areas by the wind, using methods such as:
(A) requiring that vehicles entering and leaving the site keep waste covered; (B) providing skirts, such as rubber belting or brushes, around the top of chutes to minimize the space between the chute and the hauling trailer at sites with chutes and hoppers; or (C) preventing waste from leaving the site using methods such as fencing, netting, or diking.” Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0405(a)(10) for failing to pick up and containerize windblown waste for disposal by the end of each operating day and failing to prevent waste from being blown outside the waste handling areas by the wind. During the inspection an accumulation of windblown waste was observed throughout the facility property and was observed off-property beyond the perimeter boundary along the northwestern side of the facility. Transfer station loading by deflector plates were broken and missing, allowing waste to be directed into the loading bay when loading transfer trailers.
View of windblown waste on the north side of the facility and windblown waste in the storm drain on site. Photographs taken by Chuck Kirchner during the April 18, 2023 inspection.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 8
Views of windblown waste on the east side of the facility. Photographs taken by Deb Aja during the April 18, 2023 inspection.
E. 15A NCAC 13B .0405(a)(11) states in part: “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.” Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0405(a)(11) for failing to remove all waste from the transfer trailer loading bay by the end of each day of operation for proper disposal.
A view of waste accumulated in the load out bay of the facility. Photographs taken by Deb Aja during the April 18,
2023 inspection. F. 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.” Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0405(c) for failing to maintain a vehicle used for the temporary storage of solid waste to be leak resistant in accordance with Rule .0105 of this
Subchapter and for failing to collect and prevent the release of leachate to the environment from the vehicle. During the inspection a loaded transfer trailer was observed leaking leachate onto the ground from holes on the bottom of the transfer trailer.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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View of holes observed in the bottom of transfer trailers. Photographs taken by Chuck Kirchner
during the April 18, 2023 inspection.

ADDITIONAL COMMENTS
On April 18, 2023, Chuck Kirchner and Deb Aja met with Jay Reyburn to conduct a comprehensive inspection of the Republic Services of North Carolina, LLC – Bishop Road Transfer Station located on Bishop Road in Greensboro City, Guilford County.
Facility Information:
1. The facility is a municipal solid waste (MSW) transfer station. 2. The facility is owned by Republic Services of North Carolina, LLC. 3. KR Drench Trucking, Inc. (KRD) was bought out by Endurance Trucking who now operates the
transfer station and hauls MSW to the Uwharrie Environmental Regional Landfill, Permit Number 62-04, MSW landfill in Montgomery County for disposal. The facility is permitted to haul MSW to four other landfills as listed in the permit. 4. The facility is open for receipt of MSW Monday through Friday 6:00am to 5:00pm and this facility is closed on Saturday and Sunday. 5. The facility is not open to the public. Republic services residential, commercial and industrial sites. 6. The facility is permitted to receive MSW generated within a 50-mile radius of Guilford County. The service area includes 26 counties listed in the permit. Most of the waste received comes from Guilford County. Other waste is typically received from Randolph, Alamance, Davidson and Orange County.

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

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Records Review:
7. The facility permit, site plan and operations plan were discussed.
8. A NPDES Stormwater Permit was issued by NCDEQ Division of Energy, Mineral and Land Resources on November 1, 2018. General Permit number NCG080000, Certificate of Coverage Number NCG080805. The Certificate of Coverage shall remain in effect for the duration of the
General Permit.
9. The only certified personnel on site was Johnny Titus, who is a Certified Transfer Station Operations
Specialist, TS-2020089, Exp. 11/19/2023. Permit to Operate, Attachment III, Part I, Number 4 states:
“A responsible individual trained and certified in facility operations must be on-site at all times during all operating hours of the facility, in accordance with NCGS 130A-309.25. An attendant must be present to oversee the loading and unloading of waste.”
10. The facility maintains records of the amount of material received. Throughput records were observed for January 1, 2023 through March 31, 2023. Municipal Solid Waste (MSW) received was 45,457.00 tons.
11. The Facility Annual Report (FAR) dated July 22, 2022 was received by the Solid Waste Section. A total of 154,263.24 tons MSW was received in July 2021 through June 2022. No comingled recyclables were received during that timeframe.
12. Waste screening reports were last conducted on October 08, 2021. The facility is required to conduct at least two waste screenings per week. Previously one waste screening per day was observed in the records during this inspection. See under Observed Violations ‘A.’ above.

Facility Inspection: 13. The facility no longer accepts recyclable materials. All recyclable material now goes to Re- Community at 706 Patton Avenue in Greensboro since Republic Services of North Carolina, LLC
acquired Re-community. 14. Three empty and five full transfer trailers were observed during the inspection. Transfer Trailer T-297 observed leaking leachate directly onto the ground. Transfer trailer T-429 was also observed to have
holes in the bottom and T-594 observed with significant holes in the side. See Observed Violations section of this report. Ensure all trailers are maintained in a leak resistant condition as required. 15. The Transfer Station Engineering Assessment Report was submitted to the Section on June 22, 2021. Please note that the Permitting Branch has requested a response and submittal by June 12, 2023. Please contact Deana Yitbarek at [e-mail] for more information. 16. During the May 12, 2022 inspection facility staff stated that they were in the process of obtaining bids to move forward with the repairs noted in the Assessment Report. To date these repairs have not been made. 17. Mr. Reyburn stated that approximately 700 tons are received daily. The facility is permitted to receive up to 1500 tons per day. 18. Mr. Reyburn stated that full transfer trailers of MSW are generally not stored on site overnight. 19. The transfer station was experiencing heavy traffic during the inspection. 20. The deflector plates were in poor condition allowing waste to be directed into the loading bay instead of the transfer trailer. The poor condition of the deflector plates is contributing to the ongoing damage to
the transfer station building walls. Repair and maintain deflector plates. See Observed Violation section of this report. 21. During the inspection, the outer wall metal panels on the north side of the facility transfer trailer loading
area were missing, and several panels were torn and partly detached from building, allowing waste to escape the building. Repair and maintain transfer station walls. Immediate measures must be taken to ensure waste does not escape the building. See Observed Violation section of this report.
22. Mr. Reyburn stated that the transfer station building walls are washed down approximately monthly by Triad Industrial Group.
23. The transfer station tipping floor is sloped to allow leachate to drain to the load out bay.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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24. Leachate drains along the length of the scale in the load out bay to the oil/water separator tank. It is then piped directly to the City of Greensboro sanitary sewer system. 25. The transfer station oil/water separator tank was pumped-out by Noble Oil Services, Inc. The separator tank was last pumped out on March 7, 2023. 26. One fire extinguisher was observed on the ground near the tipping floor. No legible tags were observed on the fire extinguisher.
27. The facility does not accept scrap tires or white goods.
28. Any incidental tires or white goods received are taken to the Guilford County Recycling Center located next to this facility.
29. The Pinecroft-Sedgefield Fire Department can be contacted to address an emergency at the facility. 30. The facility is secured by a locked gate. Personnel are on site during operating hours.
31. Access roads are of all-weather construction. 32. The facility has proper signage. Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: [phone] _ Chuck Kirchner Environmental Senior Specialist Regional Representative
Sent on: May 8, 2023 X Email Hand delivery US Mail Certified No. [ _]
Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Deb Aja, Western District Supervisor - Solid Waste Section Chris Hollinger, Compliance Officer – Solid Waste Section