HomeMy WebLinkAbout3215_INSP_20230712FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 1 of 4
UNIT TYPE:
Lined MSWLF LCID YW Transfer X Compost SLAS COUNTY: DURHAM
Closed MSWLF HHW White goods Incin T&P X FIRM PERMIT NO.: 3215-TRANSFER-2020 3215-MWP-2020 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE
Date of Site Inspection: July 12, 2023
FACILITY NAME AND ADDRESS:
Wall Recycling – Hoover Road 1017 S Hoover Road Durham, NC 27703 GPS COORDINATES: Lat.: 35.97843° Long.: -78.86421° FACILITY CONTACT NAME AND PHONE NUMBER: Dustin Hill, COO, (919) 896-1829, dustin@wallrecycling.com Gary Getty, Site Manager, (919) 452-3740, gary@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
Jason Watkins, NCDEQ, Solid Waste Section Jordan Russ, NCDEQ, Solid Waste Section Dustin Hill, Wall Recycling, LLC
Rusty Norris, ELM Site Solutions Kreg Shephard, ELM Site Solutions STATUS OF PERMIT:
3215-TRANSFER-2020 Permit to Operate issued March 22, 2021; expires March 22, 2081. 3215-MWP-2020 Permit to
Operate issued March 2021; expires March 22, 2026. A revised Operations and Facility Plan was submitted to the Section on August 11, 2022.
PURPOSE OF SITE VISIT: Partial Compliance Inspection & Technical Assistance
STATUS OF PAST NOTED VIOLATIONS: None.
OBSERVED VIOLATIONS: None.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 4
ADDITIONAL COMMENTS The facility is a C&D and MSW Transfer Station as well as a Mixed Waste Processing Facility. The facility is currently not accepting MSW due to infrastructure constraints.
1. The facility operating hours are Monday through Friday from 6:30 am to 7:30 pm, and on Saturday 8:00 am to 4:00 pm. The hours may be adjusted based on facility demand.
2. Signs stating emergency information, facility name, permit number, and other required information are installed at the facility entrance gate. 3. This facility is secured by fences with locking gates.
4. The permit, operations plan, training records, and waste screening logs were not reviewed during this inspection. 5. Permit to Operate, Attachment 3, Part I (11), “Shredding, or grinding must not take place at the facility unless approval has been granted under the special use permit and a revised operations plan has been submitted to the Solid Waste Section.” The grinding of wood waste, land clearing debris, and inert debris which is taking place at this facility is not approved under the current permit. Neither the original nor revised operations plans submitted in 2022 include details as to how those recycling activities were to be implemented and managed, though the general locations were shown on revised site drawings. Please submit a revised operations plan to Permitting which includes all the current and intended waste processing activity. 6. 15A NCAC 13B .0301 (a) (6), “Buffer Requirements: Unless otherwise stated in the site permit or local zoning requires larger buffers, the waste handling, treatment, processing, and storage areas shall be: (D) surrounded by an unused and cleared area of no less than 25 feet to allow access for fire or emergency response vehicles.
At the time of this inspection, an unused and cleared area did not exist behind and between the mixed wood waste and the land clearing debris stockpiles. Separation between these material storage and processing areas is needed not only for fire and safety purposes, but to also ensure that wood waste being ground for boiler fuel and land
clearing debris being ground for mulch do not intermix. Ensure that an unused and cleared area of at least 25 feet surrounds the individual wood waste and land clearing debris stockpiles. 7. 15A NCAC 13B .0101 (28), “’Inert debris waste’ means inert debris that consists solely of asphalt, cured concrete, brick, concrete block, gravel, and rock. Inert debris waste shall not contain chemical adhesives or sealants, or lead-based paint.” During this inspection the inert debris stockpile and processing area contained commingled waste including metal, plastic sheeting and buckets, wood, scrap tires, countertop waste with adhesive backing, and painted concrete, some of which had fallen or had been pushed down the adjacent northeastern and eastern embankments and into the tree line. A pile of C&D waste emitting a strong chemical odor was also identified in the inert debris processing area. Commingled C&D waste, scrap tires, countertop waste, and painted concrete do
not meet the definition of inert debris as defined in 15A NCAC 13B .0101 (28). Mr. Hill stated that all this material will be excavated and removed. Ensure all commingled C&D waste and prohibited material is removed and disposed of at a permitted facility within 30 days of receipt of this report It is recommended that more vigorous initial pre-screening of every incoming load take place to avoid unacceptable material within the inert debris stockpile and processing area as well as barriers to prevent dumping in areas behind stockpiles or otherwise out of view of facility staff. In addition, staff should be assigned to observe dumping of all waste loads in all areas not located at the transfer station building. 8. 15A NCAC 13B .0301 (a) (6), “Buffer Requirements: Unless otherwise stated in the site permit or local zoning
requires larger buffers, the waste handling, treatment, processing, and storage areas shall be: (B) no less than 100 feet from the property lines.” The inert debris storage and processing area appears to be encroaching on the northeastern adjacent property line and within the required 100-foot buffer. Ensure the inert debris waste in this area is pulled back to maintain a 100-foot buffer from the property line. 9. Permit to Operate, Attachment 3, Part VI (19)(f) “Control measures must be utilized to minimize and eliminate visible dust emissions and blowing litter.” During this inspection, large amounts of dust were observed
emanating from the facility access roads leading into the trailer loading bay and transfer station building. A water
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 4
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. 10. Permit to Operate, Attachment 3, Part I (6), “All sedimentation and erosion control activities must be conducted in accordance with the Sedimentation Control Act, NCGS 113A-50 et seq., and rules promulgated under 15A NCAC 4.” Significant erosion was identified along the eastern facility boundary embankment and sediment was present within the adjacent tree line. It is recommended that the eastern facility boundary embankment
is regraded and seeded to prevent erosion and that sediment fencing is installed to prevent sediment from leaving the site. 11. During this inspection, several trucks carrying loads of MSW, including mattresses, furniture, children’s toys, and cardboard, dumped their loads onto the C&D tipping floor as inspectors looked on. This type of waste does not meet the definition of C&D waste as defined in 15A NCAC 13B .0101 (14). Any incoming loads of MSW waste need to be rejected at the scale house until the facility establishes an MSW tipping floor/building designed to accept such waste. 12. C&D waste was being dumped and loaded into trailers bound for the landfill in the area originally designated as the MSW transfer station. The facility currently is not accepting and managing MSW waste, except as noted in #11 above. Repairs and additional construction are currently taking place on the leachate collection and containment system, including installation of additional floor drains, lowering elevation of previously installed storage tank, etc. Any leachate pooling within the transfer station must be collected and transported for proper disposal.
13. As was discussed onsite, consideration should be given to management, consolidation, and relocation of items such as scrap metal to limit the distance that material is moving, the number and location of material piles, and the number of times waste/recyclables are being handled. An increase in the amount and locations of material piles increases the exposure to the elements, and thus increases environmental risk and compliance concerns as it relates to stormwater, runoff, etc. 14. Corrective measures are necessary and should be completed within 30 days receipt of this report to avoid violation notices. Should you complete these items prior to 30 days, please notify the Section to accelerate the re-inspection.
15. Digital photographs were taken during the inspection. Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: (919-707-8290
Tim Davis timothy.davis@deq.nc.gov Environmental Senior Specialist Regional Representative
Sent on: July 24, 2023 X Email Hand delivery US Mail Certified No. [ _]
Copies (email): Jason Watkins, Field Operations Branch Head – Solid Waste Section Drew Hammonds, Eastern District Supervisor – Solid Waste Section Jordan Russ, Permitting Engineer – Solid Waste Section Rusty Norris, ELM Site Solutions
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 4
Photographs taken by Tim Davis on July 12, 2023.
View of wood waste and LC debris stockpiles. View of commingled waste fallen/pushed down northeastern embankment.
View of C&D waste load within inert debris processing area emitting chemical odor.
View of inert debris within tree line and encroaching on northeastern adjacent property line.
View of erosion along eastern facility boundary with sediment in tree line.
View of C&D tipping floor with pooling leachate.