0303T_INSP_20240220

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined
MSWLF LCID YW Transfer X Compost X SLAS COUNTY: Alleghany
Closed
MSWLF HHW White
goods X Incin T&P FIRM PERMIT NO.: 0303T-TRANSFER-1994
CDLF Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: February 20, 2024 Date of Last Inspection: April 6, 2023

FACILITY NAME AND ADDRESS:
Alleghany County Transfer Facility
431 Osborne Road
Sparta, North Carolina 28675

GPS COORDINATES (decimal degrees): Lat.: 36.49343 Long.: -81.14980

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: David Spicer, Public Works Director
Telephone: [phone]
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
Post Office Box 366
Sparta, North Carolina 28675

PARTICIPANTS:
Andy Harris, Facility Supervisor – Alleghany County
Charles Gerstell, NCDEQ – Solid Waste Section – Alleghany County

STATUS OF PERMIT:
A Permit Approval to Operate “0303T-TRANSFER-1994 Alleghany County Transfer Station” was issued to Alleghany
County on November 13, 2023.

PURPOSE OF SITE VISIT:
Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
Resolved Violation - 15A North Carolina Administrative Code 13B .0405(a)(10) states in part: “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.”

During an inspection on January 27, 2023, a large amount of windblown waste was observed along the eastern edge of
the closed landfill. Severe windblown waste was also observed south of the transfer station building along the wood
line. The volume of windblown waste indicated it had accumulated over a period of multiple days.

Allegany County was found in violation of 15A NCAC 13B .0405(a)(10) in that windblown waste was not picked up
and containerized for disposal by the end of each operating day.

Inspection of the facility on April 6, 2023 found windblown waste along the eastern edge of the closed landfill.
Although not as severe previously observed, this inspection was performed upon opening of the facility. Therefore, all
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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windblown waste observed on site was generated prior to that day’s operation. Windblown waste was also observed at
the toe of the beneficial fill area near the trailer parking area and along the southern perimeter of the transfer station
building.

Inspection of the facility on February 20, 2024 found windblown waste well controlled. Therefore, this violation is
considered resolved.

Resolved Violation - 15A North Carolina Administrative Code 13B .0203(d) states: “By receiving solid waste at a
permitted facility, the permittee shall be considered by the Department to have accepted the conditions of the permit and
shall comply with the conditions of the permit.”

x General Permit Condition #6 states: “Construction and operation of this solid waste management facility must
be in accordance with the 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.”
x The approved Operations Plan (Doc. ID No. 1357289) is included in the List of Documents for the Approved
Plan. Item #6A of approved Site and Operation Plan states: “In accordance with rule 15A NCAC 13B .0562,
the Facility receives beneficial fill material consisting of only inert debris strictly limited to clean concrete, brick,
concrete block, uncontaminated soil, rock, and gravel.”

During an inspection on April 6, 2023, multiple pieces of painted block were observed within the beneficial fill area just
south of the tire trailer. Painted block does not constitute “clean concrete” as detailed in the approved Site and
Operation Plan. Therefore, Alleghany County was found in violation of 15A NCAC 13B .0203(d).

During the inspection on February 20, 2024, no unacceptable waste streams were observed in the active beneficial fill
area on site. Therefore, this violation is considered resolved.

OBSERVED VIOLATIONS:
No new violations observed.

ADDITIONAL COMMENTS

1. The facility consists of a transfer facility, a used oil collection area, white goods collection area, tire collection
area, metal collection area, and a Small Type-1 Compost Facility.
2. The facility is permitted to receive municipal solid waste generated within areas consistent with the service area of
the receiving landfill. Waste must be transported for disposal to an appropriately permitted sanitary landfill.
Currently, all waste generated by the facility is disposed at Foothills Environmental Landfill (Permit #: 14-03).
3. A recycling center is located within a steel building located adjacent to the transfer station.
4. A gate was located at the entrance to the facility to prevent unauthorized access.
5. The facility had proper signage.
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:

6. The Permit to Operate and Operations Plan were verified. Both documents were current and available upon
request.
7. Transfer Station Operations Specialist Certifications:
x Dympsey Bowlin (expires 3/9/24)
x Justin Hall (expires 3/9/24)
x Steven Harris (expires 10/19/25)
x David Triplett (expires 10/25/26)
8. Waste screenings were verified for February 2023 to present. Screens appeared to have been performed with
adequate frequency and provided good documentation of observed unacceptable waste streams and final
disposition of those wastes.
9. Maintenance records documenting pressure washing of the push walls, tipping floor, and trailer loading bay were
being maintained as required and were available for review.
10. Temperature records for compost operations were verified.
x Grinding operations were taking place on site during the inspection. Only a small amount of compost was
on site which Mr. Harris had begun recording temperatures. The records documented the number of days
and temperatures taken at multiple locations along the compost pile. Please ensure the actual date is
recorded in the temperature records.

Operations Inspection of the Transfer Station:

11. Gravel has been placed over the asphalt leading to the tipping floor.
12. No unacceptable waste streams were observed.
13. Very little waste was on the tipping floor at the time of inspection.
14. Push walls and side walls were free of heavy residues at the time of inspection.
15. As noted on the previous inspection report, multiple broken welds continued to be observed within the steel tipping
floor. Four plates had been welded to the floor since the previous inspection in an effort to repair some damaged
portions. However, it was observed that a section of the steel had risen on the right side of the tipping floor as you
enter the transfer station building. As a result, leachate generated from waste could flow toward the entrance of the
tipping floor. Leachate was also observed seeping from the voids at failed anchor points when the front-end loader
was traversing the steel floor. It is understood that a concrete floor is located beneath the steel tipping floor.
x Previously, the County had planned to repair and continue to use the existing transfer station floor.
Repairs were to include replacement of the steel floor with concrete and adding a 30-foot covered
expansion to the tipping floor among additional work. However, Mr. Harris explained the County is now
exploring the option to construct a new transfer station.
x Continued degradation of the tipping floor could prevent leachate from flowing to the leachate
system as required. Leachate that is captured beneath the steel tipping floor could lead to odors and
vector attraction and has the potential to be released into the environment. As no timetable has yet
been established for replacement of the transfer station. Repairs to the damaged portions of the
exiting tipping floor should be implemented. It is recommended that a repair plan be developed for
the damaged tipping floor and the plan be submitted to the Solid Waste Section. This plan should
include a description of how the tipping floor will be repaired, and a timeline for implementation of
repairs. Please submit the repair plan electronically to Allen Gaither, Permitting Engineer at:
[e-mail].

16. During the inspection, a small pool of leachate was observed at the edge of the tipping floor resulting in some
leachate depositing onto the gravel located at the entrance to the tipping floor. As discussed on site, please ensure
any gravel impacted by leachate is removed and disposed of at the transfer station.
17. No waste was observed on the floor of the transfer trailer loading bay at the time of inspection.
18. A heavy buildup of residues was observed on one of the grates covering a leachate drain within the floor of the
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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trailer loading bay, and a grate was missing from the additional leachate drain. As discussed on site, please ensure
residues are removed regularly from the leachate drains and replace the missing grate.
19. Windblown waste was well managed.

Operations Inspection of the White Goods Area:

20. White goods are now stored on the gravel area adjacent to the secondary containment area for the used oil
collection tank. Mr. Harris explained that chlorofluorocarbons (CFCs) are no longer removed on site but are now
loaded into a trailer and removed at the metal vendor location. Please ensure that steps are taken to maintain the
integrity of all appliances containing CFCs during storage and shipping to ensure the integrity of the device prior to
removal of CFCs.
21. Two appliances were onsite at the time of the inspection which were stored in an upright manner.

Operations Inspection of the Tire Collection Area:

22. Tires are now collected on the covered concrete pad where white goods were once collected south of the transfer
station building.
23. Tires are placed on the concrete pad and then loaded into a 40-yard roll-off container. Once full, facility staff
deliver the tire container to the County’s tire vendor.
24. All tires were maintained to the designated area at the time of inspection.

Operations of the Type-1 Compost Area:

25. Land clearing debris was being ground at the time of inspection.
26. One small windrow of ground compost was on site. Please ensure adequate access is provided around the entire
footprint of the windrow to allow access by firefighting equipment. The windrow on site needed to be moved
slightly east to allow for adequate access.
27. No unacceptable waste streams were observed.
28. Grinding operations were taking place on the north side of the covered concrete pad used for the collection of
whole scrap tires. Please ensure all ground material is relocated to the designated compost area south of the
concrete pad during and upon conclusion of griding operations.

Supporting Comments:

29. A 500-gallon above ground storage tank is provided adjacent to the entrance of the transfer facility building for
collection of used oil. A fuel tank is located adjacent to the used oil tank.
x Both tanks were contained within a concrete secondary device with no outlet.
30. All roads were of all-weather construction and well maintained.
31. During the previous inspection, a 30-yard roll-off container had been provided adjacent to the former tire trailer for
the disposal of household trash. Mr. Harris explained at that time that customers were being directed to dispose of
waste in the container during periods of heavy volume. At the time of the previous inspection, waste was observed in
the container from the previous day’s operation.
x The previous inspection report issued on April 21, 2023, recommended that waste be removed from the
container for proper disposal at the conclusion of each working day or the container be covered with a rain
shedding device. It was also requested that the Operations Plan for the facility be updated detailing the use
of the container to include how the requirements of 15A NCAC 13B .0104(d) would be met.
x Inspection of the facility on February 20, 2024 found no container being used on site. Please be advised,
the Solid Waste Section has no concerns with changing facility operations to provide a more efficient
manner for disposal of solid waste such as the use of roll-off containers as previously noted as long as
those items mentioned in the above bullet point are addressed.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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32. The previous inspection report issued on April 21, 2023 notified Alleghany County that it had failed to submit the
information requested in the February 25, 2022 letter as it related to a revised operations plan as well as a closure
plan with closure cost estimates to include all information now required by 15A NCAC 13B .0404, .0405, and .0406.
x Since the previous inspection, all required information has been submitted to the Solid Waste Section and
approved. Thank you for your cooperation in this matter.
33. As noted on the previous inspection report, major construction activities to improve the condition of the transfer
station building were planned by Alleghany County. An Assessment Repair Request Response was issued by the
Solid Waste section on March 21, 2022.
x Facility improvements were to include extending the transfer station building 30-feet to the north, replacing
the tipping floor and adding new push walls, installing chutes at the tipping floor edge to direct waste into
the trailer, and replacing the inoperable rollup doors.
x As previously noted above, the County now exploring the option to build a new transfer station building.
x The potential location of a new transfer station building to include required setbacks were discussed during
this inspection.
34. Since the previous inspection, improvements to the loading dock located south of the transfer station building had
been completed as previously approved by the Solid Waste Section. Improvements included installation of a new
concrete pad, leachate collection drain, and leachate holding tank. New chain-length-fencing was also installed on
three sides of the new concrete floor.

Please contact me if you have any questions or concerns regarding this inspection report.

________________________________________ Phone: [phone]
Charles T. Gerstell
Environmental Senior Specialist
Regional Representative

Sent on: 3/8/24 X Email Hand delivery US Mail Certified No. [ _]

Copies: Deb Aja, Western District Supervisor - Solid Waste Section
Allen Gaither, Permitting Engineer – Solid Waste Section
Digitally signed by Charles T. Gerstell
DN: cn=Charles T. Gerstell, o=Division of Waste
Management, ou=Solid Waste Section,
email=[e-mail], c=US
Date: 2024.03.08 12:57:10 -05'00'