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Home My WebLink About3608_INSP_20161012FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 13 UNIT TYPE: Lined MSWLF LCID YW Transfer X Compost SLAS COUNTY: Gaston Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 36-08-Transfer-1993 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: 10-12-16 Date of Last Inspection: 1-13-15 FACILITY NAME AND ADDRESS: Waste Management Transfer Station, Ranlo Facility 2712 Lowell Road Gastonia, NC 28054 GPS COORDINATES: N: 35.27943 W: -81.12120 FACILITY CONTACT NAME AND PHONE NUMBER: Name: Jeffrey Edwards, District Manager Telephone: (704) 869-7663 Email address: jedwards3@wm.com FACILITY CONTACT ADDRESS: Same as above PARTICIPANTS: Jeffrey Edwards, District Manager Steven Edwards, Commercial RM Kim Sue, NCDEQ - Environmental Senior Specialist - Solid Waste Section Deb Aja, NCDEQ – Western District Supervisor – Solid Waste Section Kris Riddle, NCDEQ - Environmental Senior Specialist - Solid Waste Section STATUS OF PERMIT: Current – Approved May 12, 2016 (DIN 26093) expires May 10, 2021 Operations Plan – Approved May 12, 2016 (DIN 25637) PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: None OBSERVED VIOLATIONS: 1. 15A NCAC 13B .0203(d) states: “By receiving solid waste at a permitted facility, the permittee(s) shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the permit.” General Permit Condition Number 19 of Permit to Operate 3608-Transfer-1993 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, liquids and other excluded waste types”. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 13 An inspection of the waste screening records for random inspections revealed deficiencies in the number of waste screenings performed and/or documented. There were only four waste screenings documented in 2015 and no random inspections or documentation for 2016. The dates of random inspections documented in 2015 were January 5, 2015, February 26, 2015, September 1, 2015, October 9, 2015. Waste Management of Carolinas is in violation of 15A NCAC 13B .0203(d) in that they did not conduct random inspections of incoming loads and have records of all inspections in 2016 and were deficient in conducting the screening program in 2015. To achieve compliance, Waste Management of Carolinas must immediately begin to perform the required number of random waste screenings and maintain required records of same. 2. 15A NCAC 13B .0402(1) states: “Operational plans shall be approved and followed as specified for the facility”. The approved Facility Operations Plan Waste Management of Carolina, Inc., dated May 12, 2016 (DIN 25637, Page 6) states: “Random Inspections, and Employee Training and Certifications”, “Random inspections will be conducted and documented on a random basis per Waste Management procedures (see Attachment 1). Random inspections will be performed on front-end loaders, commercial rear-end loaders and roll-offs. There will be no less than four (4) random inspections conducted monthly. The random dates shall be no closer than one (1) day apart. The drivers/vehicles will be randomly inspected and not inspected consecutively”. An inspection of the waste screening records for random inspections revealed deficiencies in the number of waste screenings performed and/or documented. There were only four waste screenings documented in 2015 and no random inspections or documentation for 2016. The dates of random inspections documented in 2015 were January 5, 2015, February 26, 2015, September 1, 2015, October 9, 2015. Waste Management of Carolinas is in violation of 15A NCAC 13B .0402(1) in that they did not perform the required number of random inspections. To achieve compliance, Waste Management of Carolinas must immediately begin to perform the required number of random inspections and maintain required records of same. 3. 15A NCAC 13B .0203(d) states: “By receiving solid waste at a permitted facility, the permittee(s) shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the permit.” General Permit Condition Number 20 (c) of Permit to Operate 3608-Transfer-1993 states: “Waste may be stored on-site, in leak proof transfer trailers, with watertight covers, a maximum of 5 working days. Storage of the waste must not cause any nuisance, such as odor or attraction of vectors”. During the inspection leachate was observed actively leaking from loaded trailers being used at Waste Management Transfer Facility to collect and transport solid waste. Leachate was observed flowing across the gravel parking lot and leaking out of trailers #2226, #16370, #3926 and #1285. Objectionable odors were detected in the vegetated area to the south of the facility. Waste Management of Carolinas is in violation of 15A NCAC 13B .0203(d) in that they stored waste in leaking trailers and in that the storage of the waste caused odors. To achieve compliance, Waste Management of Carolina must perform repairs to all trailers to insure they are leak-resistant. 4. 15A NCAC 13B .0402(1) states: “Operational plans shall be approved and followed as specified for the facility”. The approved Facility Operations Plan Waste Management of Carolina, Inc., dated May 12, 2016 (DIN 25637, Page 4) “Waste Acceptance & Storage” states: “If the waste is to remain on site for more than seven days after collection from the generator, a refrigerated type trailer will be utilized. The loaded or partially loaded trailers will primarily be staged on a concrete pad outside the facility. If necessary, the trailers may be staged on the yard as identified on the facility diagram. The staged trailers will be inspected during loading, prior to staging outside, and prior to transfer to identify leaks or spills. If leaks or spill are identified, clean up FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 13 and decontamination procedures will be implemented as outlined in the transportation vehicle’s contingency plan”. During the inspection leachate was observed actively leaking from loaded trailers being used at Waste Management Transfer Facility to collect and transport solid waste. Leachate was observed flowing across the gravel parking lot and leaking out of trailers #2226, #16370, #3926 and #1285. Waste Management of Carolinas is in violation of 15A NCAC 13B .0402(1) in that leachate was observed actively leaking from loaded trailers to collect and transport solid waste. Leaks were not identified in accordance with the inspection protocol and clean up procedures were not implemented in accordance with the approved Operations Plan. To achieve compliance, Waste Management of Carolina must perform repairs to all trailers to insure they are leak-resistant. Contact Ervin Lane, Compliance Hydrogeologist, to determine the requirements for a soil sampling plan in order to determine the impact of the leachate released. Further actions to remediate leachate releases may be required. Ervin Lane, Compliance Hydrogeologist Division of Waste Management/Solid Waste Section 1646 Mail Service Center Raleigh, North Carolina 27699-1646 (919) 707-8288 Leachate release in the loaded trailer parking lot. Photo taken by: Kim Sue 10/12/16 Leachate release in the loaded trailer parking lot. Photo taken by: Deb Aja 10/12/16 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 13 5. SL2013-413, Section 59.2(c), in amending 15A NCAC 13B .0105 states: “Requires that vehicles or containers used for the collection and transportation of solid waste to “be designed and maintained to be leak-resistant in accordance with industry standards”. During the inspection leachate was observed actively leaking from loaded trailers being used at Waste Management Transfer Facility to collect and transport solid waste. Leachate was observed flowing across the gravel parking lot and leaking out of trailers #2226, #16370, #3926 and #1285. Waste Management of Carolinas is in violation of SL2013-413, Section 59.2(c), in amending 15A NCAC 13B .0105 in that leachate was observed actively leaking from the loaded trailers. To achieve compliance, Waste Management of Carolina must perform repairs to all trailers to insure they are leak-resistant. Leachate release in the loaded trailer parking lot. Photo taken by: Deb Aja 10/12/16 Leachate flowing to the vegetated area from the loaded trailer parking lot. Photo taken by: Deb Aja 10/12/16 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 13 6. 15A NCAC 13B .0203(d) states: “By receiving solid waste at a permitted facility, the permittee(s) shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the permit.” General Permit Condition Number 21(a) and (b) of Permit to Operate 3608-Transfer-1993 states: “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. a. The leachate control system, such as floor drains, leachate collection devices, sanitary sewer connections and leachate storage tanks, must be operational during facility operations. b. The tipping floor must drain away from the building entrance and into the leachate collection system”. Leachate leaking below trailer. Photo taken by: Kim Sue 10/12/16 Corroded area underneath trailer. Photo taken by: Kim Sue 10/12/16 Leachate on pavement underneath trailer. Photo taken by: Kim Sue 10/12/16 Leachate leaking down back of trailer underneath trailer. Photo taken by: Kim Sue 10/12/16 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 13 During the inspection leachate was leaving the confines of the transfer building and flowing north across the paved parking lot to the straw bales located along the edge of the parking lot up against the guard rail and northeast to the gravel parking lot where the loaded trailers are parked. The trench drain across the entrance to the transfer station was inundated with residue at the time of inspection. Facility staff began removing residue during the inspection. Waste Management of Carolinas is in violation of 15A NCAC 13B .0203(d) in that the leachate control system was not operational during facility operations and that the leachate did not drain into the leachate collection system. To achieve compliance, Waste Management of Carolina must perform regular maintenance to all leachate collection devices to ensure free flow of leachate into the collection system. 7. 15A NCAC 13B .0402(3) states: “Water that comes into contact with solid waste will be contained on-site or properly treated prior to discharge from the site. An NPDES permit may be required prior to discharge to surface waters.” During the inspection leachate was observed leaving the confines of the transfer building and flowing north across the paved parking lot to the straw bales located along the edge of the parking lot up against the guard rail and northeast to the gravel parking lot where the loaded trailers are parked. In another area of the facility leachate flowed from the loaded trailers staged at the gravel parking area to a downgradient vegetated area. Waste Management of Carolinas is in violation of 15A NCAC 13B .0402(3) in that water that came into contact with solid waste was not contained onsite or properly treated prior to discharge from the site. To achieve compliance, Waste Management of Carolina must immediately contain leachate within the leachate collection system. Leachate flowing across parking lot. Photo taken by: Kim Sue 10/12/16 Leachate flowing across parking lot to straw bales. Photo taken by: Kim Sue 10/12/16 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 13 8. 15A NCAC 13B .0203(d) states: “By receiving solid waste at a permitted facility, the permittee(s) shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the permit.” General Permit Condition Number 20(a) of Permit to Operate 3608-Transfer-1993 states: “The tipping floor and loading area must be maintained in a clean, sanitary condition at all times and must be cleaned at least daily”. During the inspection the trench drain was clogged with debris and the tipping floor had a heavy layer of debris. Facility staff stated that the trench drain and tipping floor were not cleaned daily. Waste was observed deposited on the I beams in the trailer loading bays. Waste Management of Carolinas is in violation of 15A NCAC 13B .0203(d) in that the tipping floor and loading area was not maintained in a clean, sanitary condition at all times and was not cleaned at least daily. 9. 15A NCAC 13B .0402(1) states: “Operational plans shall be approved and followed as specified for the facility”. The approved Facility Operations Plan Waste Management of Carolina, Inc., dated May 12, 2016 (DIN 25637, Page 4) “Housekeeping & Vector Control” states: “The operator is responsible for the operations, maintenance, and general housekeeping of the facility. All extraneous solid waste will be swept and removed by broom and/or shovel during the operations day. Any extremely wet material will be removed by washing the area down with water. This wastewater will be routed to the sanitary sewer”. During the inspection waste was observed deposited on the I beams in the trailer loading bays. A section of the deflector was missing. Waste was observed behind the east push wall. The insulation on the rear wall of the transfer station was deteriorating. Dust and dirt was observed on the walls and exhaust fans in the transfer station. Waste Management of Carolinas is in violation of 15A NCAC 13B .0402(1) in that daily housekeeping is not being performed. To achieve compliance, Waste Management of Carolina must immediately perform the required repairs to the deflector, remove waste on the I beams on a daily basis and perform daily housecleaning in and around the transfer station building. Residue in trench drain. Photo taken by: Kim Sue 10/12/16 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 13 Waste build-up on I beams in trailer loading bay. Photo taken by: Kim Sue 10/12/16 Missing section in deflector. Photo taken by: Kim Sue 10/12/16 Dust and dirt on west wall of transfer station. Photo taken by: Kim Sue 10/12/16 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 13 9. 15A NCAC 13B .0203(d) states: “By receiving solid waste at a permitted facility, the permittee(s) shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the permit.” General Permit Condition Number 20 (e) (ii) of Permit to Operate 3608-Transfer-1993 states: “Control measures must be utilized to minimize and eliminate visible dust emissions and blowing liter. Windblown materials must be collected by the end of the day and no windblown material may be allowed to leave the facility boundary. During the inspection windblown material was observed around the trailer loading bays and tarping scaffolding. Waste Management of Carolinas is in violation of 15A NCAC 13B .0203(d) in that windblown material is not being controlled and collected by the end of each day. To achieve compliance, Waste Management of Carolina must collect all windblown material before the end of each operating day. 10. 15A NCAC 13B .0402(7) states: “Appropriate method shall be provided to confine material subject to be blown by the wind within the area. At the conclusion of each day of operation, all windblown material resulting from the operation shall be collected and returned to the area by the owner or operator”. During the inspection windblown material was observed around the trailer loading bays and tarping scaffolding. Waste Management of Carolinas is in violation of 15A NCAC 13B .0402(7) in that windblown material resulting from the operation is not being collected at the conclusion of each day. To achieve compliance, Waste Management of Carolina must collect all windblown material before the end of each operating day. Deteriorating insulation on rear wall of transfer station. Photo taken by: Kim Sue 10/12/16 Waste behind east push wall. Photo taken by: Kim Sue 10/12/16 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 10 of 13 11. 15A NCAC 13B .0402(1) states: “Operational plans shall be approved and followed as specified for the facility”. The approved Facility Operations Plan Waste Management of Carolina, Inc., dated May 12, 2016 (DIN 25637, Page 4) states: “Windblown litter is controlled at the transfer station by using covered transfer and collection vehicles, confining waste transfer activities to the inside of the building, and controlling vehicle access to the transfer building. Litter that escapes the transfer building will be picked up daily and managed to minimize contact with stormwater”. During the inspection windblown material was observed around the trailer loading bays and tarping scaffolding. The trench drain across the front of the trailer loading bays discharges to an open ditch which flows to the retention pond. Waste was washing to the open ditch and eventually to the retention pond. Waste Management of Carolinas is in violation of 15A NCAC 13B .0402(1) in that liter that escaped the transfer building was not picked up daily and managed to minimize contact with stormwater. To achieve compliance, Waste Management of Carolina must collect all windblown material before the end of each operating day. Windblown litter behind guard rail NW of Transfer Station. Photo taken by: Kim Sue 10/12/16 Windblown litter around scaffolding. Photo taken by: Kim Sue 10/12/16 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 11 of 13 Windblown litter against retaining wall along access road to trailer loading bays. Photo taken by: Kim Sue 10/12/16 Windblown litter against retaining wall along access road to trailer loading bays. Photo taken by: Kim Sue 10/12/16 Windblown litter along access road to trailer loading bays. Photo taken by: Deb Aja 10/12/16 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 12 of 13 ADDITIONAL COMMENTS 1. The facility is owned by Waste Management of Carolinas and operated by Custom Ecology Inc. (CEI). 2. The required signage is posted at the entrance of the facility to prevent unauthorized access. 3. The facility is secured by an automatic gate at the entrance of the facility. 4. The facility is permitted to receive solid waste from Cabarrus, Cleveland, Gaston, Iredell, Lincoln, Mecklenburg and Union Counties. 5. Waste can be transported for final disposal to the Palmetto Landfill, Spartanburg, SC; Richland County Landfill, Elgin, SC or BFI-Charlotte Motor Speedway Landfill V, Cabarrus County, NC. Currently all waste is transported to Richland County Landfill, Elgin, SC. 6. The facility is currently accepting approximately 133 tons per day. 7. The facility was actively accepting waste during the inspection. 8. On the tipping floor a very small amount of leaves and limbs were observed, however, it was unclear how the material was generated and if it would be considered yard trash. Please adhere to the approved permit and operations plan for waste screening. 9. The aggregate had become exposed in the surface of the tipping floor. Please maintain the integrity of the tipping floor to prevent future deterioration of the surface and plan for any future repairs. 10. The trench drains feed into an underground storage tank (UST) located on the NW side of the transfer station. This UST serves as a “grit chamber” to settle out any solids before the liquids flow into an adjacent underground oil- water separator. The outfall from the oil-water separator is direct piped to the Town of Ranlo for final treatment and disposal. The “grit chamber” UST is pumped as needed by Safety-Kleen Systems, Inc. The “grit chamber” and oil-water separator were last pumped out on 10-23-15. 11. Sewer clean-outs were cracked and in need of repair. 12. The vent for the oil-water separator was severed. 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. Trash washing down trench drain in front of loading bays to storm drainage ditch. Photo taken by: Kim Sue 10/12/16 Trash washing down storm drainage ditch to storm retention pond. Photo taken by: Kim Sue 10/12/16 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 13 of 13 13. During the inspection, a number of concerns, including improper management of waste screening and housekeeping at the facility and lack of required maintenance in numerous areas of operation, were explained by facility staff as being due to insufficient personnel to manage and undertake these activities. Please note that 15A NCAC 13B .1604(2)(I) states: “Proper Operation and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance procedures”. 14. The facility staff could not readily produce the current operations plan. Please ensure that the permit, approved plans, and all records required to be maintained are available for review upon request. 15. Certified Operators: Tony Blake Cantrell - Transfer Station Operations Specialist expires November 16, 2016 Steven J. Edwards - Transfer Station Operations Specialist expires April 3, 2018 Teresa Barrett - Transfer Station Operations Specialist expires March 5, 2018 Greg Woodberry – Transfer Station Operations Specialist expires April 6, 2019 Mary I Elliott - Transfer Station Operations Specialist expires October 19, 2019 Jesus Rameriz - Transfer Station Operations Specialist expired April 3, 2015, was not renewed Scrap Tires 16. Scrap tires are collected in an enclosed trailer. No tires were observed outside the trailer. 17. Scrap tire hauler records were not reviewed during the inspection. Medical Waste 18. The facility is permitted to accept medical waste. They do not currently accept medical waste. Scrap Metal 19. Scrap metal is collected in an enclosed trailer. Please contact me if you have any questions or concerns regarding this inspection report. __________ ___________________________ Phone: (704) 235-2163 _ Environmental Senior Specialist Regional Representative E-mailed to: Jeffrey Edwards on 11/1/2016 by: X Email Hand delivery US Mail X Certified No. 70151520000269847634 Copies: Jason Watkins, Field Operations Branch Head Deb Aja, Western District Supervisor - Solid Waste Section Jessica Montie, Compliance Officer - Solid Waste Section Ervin Lane, Compliance Hydrogeologists – Solid Waste Section Shawn Carroll, Waste Management, scarrol3@wm.com Dan Moore, Waste Management, dmoore36@wm.com