9503_INSP_20240516

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: Watauga
Closed
MSWLF HHW X White
goods X Incin T&P FIRM PERMIT NO.: 95-03
CDLF Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE
Date of Site Inspection: May 16, 2024 Date of Last Inspection: July 20, 2023
FACILITY NAME AND ADDRESS:
Watauga County Transfer Facility
336 Landfill Road
Boone, North Carolina 28607
Watauga County Permanent HHW
336 Landfill Road
Boone, North Carolina 28607
GPS COORDINATES (decimal degrees): Lat.: 36.22032 Long.: -81.63165
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Rex Buck, Operations Services Director
Telephone: [phone]
Email address: [e-mail]
FACILITY CONTACT ADDRESS:
Same as above
PARTICIPANTS:
Phillip Harrison, Operations Services Manager Watauga County
Charles Gerstell, NCDEQ Solid Waste Section
STATUS OF PERMIT:
Permit to Operate 9503T-TRANSFER-1996 Watauga County Transfer Station and 9503-HHW-2015 Watauga
County Permanent HHW was issued to Watauga County on October 31, 2023. The Permit for the Transfer Station is for
the life-of-site of the facility. The permit for the Permanent HHW expires on August 26, 2025.
PURPOSE OF SITE VISIT:
Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS:
Corrective Measures in Progress - 15A North Carolina Administrative Code 13B .0203(d) states:
solid waste at a permitted facility, the permittee shall be considered by the Department to have accepted the conditions

General Facility Condition #19(a) states:

During a previous inspection performed on June 22, 2022, facility staff stated the leachate system within the tailer
loading bay was not operational. Instead of leachate being transported to the sanitary sewer system as designed, it is
currently pumped out by a septage management firm when needed.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 7
Watauga County was found in violation of 15A NCAC 13B .0203(d) and General Facility Condition #19(a) in that the
leachate control system within the trailer loading bay was not operational as required.
Inspection of the facility on June 29, 2023 found that the leachate system within the trailer loading bay was still
inoperable. Mr. Buck explained repair options were still being considered, which included installation of a new leachate
pipe leading from the trailer loading bay to a new 2,500-gallon tank located at the new trailer parking area currently
under construction. However, no information has been submitted to the Solid Waste Section to address the leachate
system concerns as required in an inspection report issued on July 1, 2022.
A and a were submitted to the Solid Waste
Section (Section) on August 22, 2023 and October 12, 2023 respectively. These documents detailed the intended plan
of action to repair the leachate system and the transfer station tipping floor.
A was issued by the Solid Waste Section on October 31, 2023 on the condition that
the facility provide written confirmation to the Section once the leachate collection system and tipping floor repairs
were complete.
During the May 16, 2024 inspection, Mr. Phillip Harrison stated the leachate collection system had been repaired.
However, no written confirmation has been submitted to the Section for approval certifying the repairs. Therefore, this
violation cannot be resolved until written confirmation is submitted to the Section for approval.
Resolved Violation - 15A North Carolina Administrative Code 13B .0201(c) states in part: No solid waste
management facility shall be established, operated, maintained, constructed, expanded, or modified without a valid

During a previous inspection on June 29, 2023, construction of a new trailer parking area adjacent to the transfer station
building was observed. Design plans for the parking area were submitted to the Solid Waste Section. However,
construction started prior to approval of the plans and issuance of a new Permit to Operate. Watauga County was found
in violation of 15A NCAC 13B .0201(c) for modifying the solid waste management facility without a valid permit.

for the Trailer Storage Area. A Trailer Storage Area Improvements Approval was issued by the Solid Waste Section
on May 15, 2024. Therefore, this violation is considered resolved.
Corrective Measures in Progress - 15A North Carolina Administrative Code 13B .0403(b)(1) states:
be designed and constructed so that all solid waste receiving, handling, transfer, and storage occurs on an impervious

During a previous inspection on June 29, 2023, a portion of the tipping floor was observed to be damaged. It appeared
that the concrete floor had eroded away leaving rebar exposed. Little effort was needed to dig into the remaining
material which had the consistency of gravel or soil. Watauga County is in violation of 15A NCAC 13B .0403(b)(1) for
failure to manage solid waste on an impervious surface.
As previously noted, a was issued by the Solid Waste Section on October 31, 2023
on the condition that the facility provide written confirmation to the Section once the leachate collection system and
tipping floor repairs were complete.
Upon arrival on May 16, 2024, Mr. Harrison explained that the tipping floor had been repaired, and facility staff were
currently in the process of placing three-quarter inch steel plating on the floor. Subsequent inspection of the floor found
approximately half of the tipping floor had been covered with steel plating to include the area of concern observed on
June 29, 2023. However, no written confirmation has been submitted to the Section for approval certifying the repairs.
Therefore, this violation cannot be resolved until written confirmation is submitted to the Section for approval.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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OBSERVED VIOLATIONS:
15A North Carolina Administrative Code 13B .0405(b) states in part: Water that comes into contact with solid waste
is leachate and shall be collected from the site for disposal to an approved facility or discharged directly from the site into

During the May 16, 2024 inspection, leachate was observed leaking from a transfer trailer and then flowing along the
concrete wheel stop barrier into a rip rap lined swale on the south side of the trailer storage area. Leachate-stained soil
was also observed on the hillside beyond the rip rap swale. Leachate was also observed within the PVC pipe leading from
the storm water inlets within the leachate collection flume of the trailer storage area. Soil below this pipe was stained and
bare of vegetation. Storm water conveying inlets are to be plugged. However, two of the inlets were not plugged at the
time of inspection. Leachate was observed leaking from a transfer trailer and into the stormwater inlet within the middle
section of the leachate collection flume of the trailer storage area.
Watauga County is in violation of 15A NCAC 13B .0405(b) for failure to collect leachate for disposal to an approved
facility or discharge the leachate directly from the site into a sanitary sewer line.
To achieve compliance, within ten (10) days of receipt of the Notice of Violations, Watauga County must follow the
Division of Waste Management Solid Waste Section Leachate Release Sampling & Analysis Guidelines for
leachate releases. This information can be found at the following link: Leachate Release Sampling& Analysis
Guidelines. Watauga County shall also contact Elizabeth Werner, Hydrogeologist, to determine the requirements
for a soil sampling plan to determine the impact of the leachate release. Pending the laboratory analytical results,
additional measures may be required.
Elizabeth Werner, Hydrogeologist
NCDEQ Division of Waste Management
[e-mail]
[phone]

5/21/24: View of staining in concrete flume leading to 5/16/24: Closer view of leachate leaking from trailer
leachate drain inlet and storm drain inlet. Trailer was into leachate and stormwater inlets of concrete flume.
actively leaking leachate at time of inspection. (photo
by C. Gerstell)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 7
5/16/24: View of leachate flowing along concrete wheel 5/16/24: View of leachate flowing into rip rap lined swale.
stop barrier south toward rip rap swale. (photo by C. (photo by C. Gerstell)
Gerstell)
5/16/24: Photo of standing liquid with staining below 5/16/24: Bare soil and staining below storm water pipe
rip rap lined swale. (photo by C. Gerstell) leading from concrete flume of trailer storage area. (photo
by C. Gerstell)

5/16/24: View of leachate and waste within
water pipe leading from concrete flume. (photo
by C. Gerstell)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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ADDITIONAL COMMENTS
1. The facility is permitted to receive municipal solid waste generated within areas consistent with the service area of
the receiving facility.
2. A gate was provided at the entrance to the facility to prevent unauthorized access.
3. The Permit to Operate was current and available upon request. A copy of the currently approved Operations Plan
was not on site at the time of inspection. Ms. Donna Watson notified the Solid Waste Section by e-mail on 5/16/24
that she was able to obtain a copy of the Operations Plan
database. Please ensure a copy of the Operations Plan remains on site in the future.
4. Tonnage reports for July 2023 to present were verified. The facility received 46,394.29-tons of waste during this
time.
5. Certified Transfer Station Operations Specialist Certifications:
Marshall Boudreaux (expires 7/20/26)
Jim Fink (expires 7/19/24)
Phillip Harrison (expires 7/20/26)
Dale Miller (expires 5/19/24)
David Miller (expires 3/12/35)
Rusty Rhines (expires 7/20/26)
6. Waste screening reports for June 2, 2023 to present were verified. Screenings provided good detail of observed
unacceptable waste streams and final disposition of those wastes. During the previous inspection, facility staff
were performing two screenings each day and documenting the weight of each load screened to ensure the proper
frequency of screenings was being performed. However, the May 16, 2024 inspection found that inspections were
now being performed at a rate of two each week and weights were not being tracked as of February 2024.
Please be reminded, 15A North Carolina Administrative Code 13B .0405(a)(8)(B) requires site
personnel to screen incoming loads weekly at a rate of no less than five percent of the average daily
Records must be kept in a
manner to ensure the facility can verify that the proper frequency of inspections is being performed
such as documenting the weight of each waste load screened.
Operations Inspection of the Transfer Station (9503T-TRANSFER-1996)
7. Two separate entrances are provided for waste acceptance. The public enter on the south side of the building while
commercial vehicles and larger public vehicles enter on the east side of the building.
8. No unacceptable waste streams were observed.
9. Grates located over the leachate trench drain at the east facing entrance were free of a heavy buildup of residues at
the time of inspection. The trench appeared to have good storage capacity.
10. The push walls were free of a heavy buildup of residues at the time of inspection. Mr. Harrison stated the push
walls are cleaned every day with a firehose. Please note that 15A NCAC 13B .0405(a)(11) requires that the push
walls be cleaned with a pressure washer no less than once per month. Remaining areas of the site building
including side walls and any material storage areas outside of the building shall be cleaned with a pressure washer
no less than twice per year. Please ensure the proper equipment, to include a pressure washer, is available on site
to ensure the requirements of 15A NCAC 13B .0405(a)(11) are met.
11. Windblown waste was well controlled.
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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12. A small amount of waste was observed on the floor of the trailer loading bay at the time of inspection. Please
ensure all waste is removed from the area at the conclusion of each operating day. Give special attention to the
area under the grates on the left side as you exit the loading bay.
13. The walls and I-beams of the trailer loading bay were clean and free of residue buildup at the time of inspection.
14. As previously noted, three-quarter inch steel plating is being placed over the concrete floor. Please ensure any
leachate collected at anchor points is removed prior to the anchor points being welded shut.
15. During the inspection, a transfer trailer was observed leaking from the rear door of the trailer onto the asphalt drive
leading to the trailer loading bay. Mr. Harrison immediately contacted a staff who pulled the trailer forward over
the leachate containment system and placed a quick drying compound on the asphalt.
Please ensure the contractor for waste hauling is notified about the damaged trailer to ensure it is removed
from service for repairs.
Proper disposal of the drying compounds used to absorb the spilled leachate was discussed during the
inspection.
Operations Inspection of the White Goods Area:
16. White goods containing chlorofluorocarbon refrigerants (CFCs) are collected at the northwest corner of the
bailing/recycling building.
17. All appliances containing CFCs were stored upright to maintain the integrity of the device prior to collection of
CFCs.
18. This area was well managed.
Operations Inspection of the Tire Collection Area:
19. Whole scrap tires are collected into one of three covered trailers at the loading dock on the west side of the
baling/recycling building.
20. All tires were maintained in the designated trailers at the time of inspection.
21. This area was well managed.
Supporting Comments:
22. A convenience area for disposal of waste and recyclables is provided on the north side of the access road across
from the scale house.
23. Electronics are collected within the baling/recycling building and then placed on wooden pallets and shrink
wrapped or placed within gaylord boxes for shipment to the electronics vendor.
24. Florescent bulbs and batteries are collected at the baling/recycling facility. Bulbs are placed in cardboard
containers prior to shipment to the designated vendor.
25. During the inspection, leachate was observed leaking from the rear door and cleanout port of a garbage
collection truck marked as truck no. 2. Leachate from this truck was not leaving the asphalt area.
15A North Carolina Administrative Code 13B .0105(c) requires vehicles used for the collection of
solid waste be constructed, operated, and maintained to be leak resistant in order to prevent the
creation of a nuisance to public health from the escape of solid, semi-solid, or liquid waste.
Please ensure the truck is repaired as discussed during the inspection to sure it is leak resistant.
The facility should have equipment on site to contain any leachate that may leak from vehicles to
prevent nuisance conditions.
Operations Inspection of the HHW Facility (9503-HHW-2015):
26. The facility consists of a steel building with three separate compartments for the collection of HHW.
27. The Permit to Operate was current and available upon request.
28. The facility operates on designated collection days in April and ending in October. During collection events, waste
is collected and immediately
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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waste is maintained within the compartments unless a small amount is received by the general public between
collection events. A small amount of material was on site at the time of inspection.
29. All compartments were closed and locked upon inspection.
30. Secondary containment was provided for each compartment which was well maintained. The secondary
containment has no outlet.
31. A fire suppression system was provided to control fires at the facility. The system was last serviced in February of
2024.
32. Grass on the back side of the building had been mowed as requested on the previous inspection report.
33. A clear, unobstructed path had been provided around the building and HHW areas.
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: 5/24/24 Email Hand delivery X US Mail (with
NOV)
Certified No. [ _]
Copies: Jason Watkins, Solid Waste Section Chief
Deb Aja, Western District Supervisor
Chris Hollinger, Compliance Officer
Elizabeth Werner, Hydrogeologist