3416_NOD_20190830

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
NORTH CAROLINA
Environmental Quality
August 30, 2019
CERTIFIED MAIL NO. 7007 1490 0004 9565 2409
RETURN RECEIPT REQUESTED
Mr. Mark Tabaczynski, Division Manager
Republic Services of North Carolina, LLC
2875 Lowry Street
Winston-Salem, NC 27101
CERTIFIED MAIL NO. 7007 1490 0004 9565 2416
RETURN RECEIPT REQUESTED
CT Corporation System, Registered Agent
Republic Services of North Carolina, LLC
160 Mine Lake Court, Suite 200
Raleigh, NC 27615
SUBJECT: Notice of Deficiency
Compliance Inspection Report
Overdale Road Transfer Station
Permit ID Number 3416T-TRANSFER-
Forsyth County
Dear Mr. Tabaczynski and Registered Agent:
On August 13, 2019, Susan Heim and Chuck Kirchner, representing the State of North Carolina,
Division of Waste Management Solid Waste Section (Section), inspected the above referenced
facility for compliance with North Carolina solid waste statutes and rules. Ronald Goins, Republic
Services of North Carolina, LLC, was present and represented the Overdale Road Transfer Station
during this inspection. The following violations were noted:
A. 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." Facility Permit No. 3416T-TRANSFER, Overdale Road
Transfer Station, ATTACHMENT 1, General Permit Conditions Information, General Facility
NORTH CAROL INAD_E QWA)
Oepartmenl pt Enviranmanta113Mity
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Overdale Road Transfer Station
Notice of Deficiency
Page 2 of 5
August 30, 2019
Permit Condition 7 states, in part, "This permit is issued based on the documents submitted in
support of the application for permitting the facility including those identified in Attachment
1, "List of Documents for Approved Plan," and which constitute the approved plan for the
facility." Operation Plan for Overdale Road Transfer Station, Winston-Salem, North Carolina,
prepared for Republic Services by HHNT, dated March 13, 2017 and revised April 19, 2017, is
included in the List of Documents for the Approved Plan in ATTACHMENT 1, Part VI: Transfer
Station/Treatment and Processing Unit. Operation Plan for Overdale Road Transfer Station,
Winston-Salem, North Carolina (revised April 19, 2017) Section 9.0, TRANSFER STATION
INSPECTIONS, states, in part, "There will be regular inspections conducted at the transfer station.
Items that will be inspected monthly will include, but not be limited to, the following: 1) Transfer
trailers; 2) Push walls; 3) Fire extinguishers; 4) Electrical controls; 5) Trench drain, floor drains,
and yard hydrant; 6) Washdown water collection sump and pump; and 7) Oil/Water Separator.
Records of all transfer station inspections will be maintained in the scalehouse."
Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0203(d) for failure to
maintain records of transfer station monthly inspections of transfer trailers; push walls; fire
extinguishers; electrical controls; trench drain, floor drains, and yard hydrant; washdown water
collection sump and pump; and oil/water separator at the scale house.
B. 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." Permit to Operate No. 3416T-TRANSFER-, ATTACHMENT 3,
PART VI, Transfer Station/Treatment and Processing Unit Condition #7(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."
Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0203(d) for failing to
maintain the tipping floor and transfer trailer loading area in a clean, sanitary condition. A build-
up of waste was observed on the steel beams and sheet metal that make up the transfer station
walls, on the deflector panels above the loading bay, on the push walls, and in and around the
roll -off containers and drums of oil in the maintenance area along the southeast interior wall of
the building. Several separations and rips in the panels of sheet metal on the outside wall of the
loading bay, large enough to allow waste to leave the transfer station, were also observed.
C. 15A NCAC 13B .0402(6) states, "Equipment shall be provided in the storage and charging
areas and elsewhere as needed or as may be required in order to maintain the facility in a
sanitary condition."
I �
NORTH ARa N D_E IW Aj
oeaanmem of 1 auar\
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Overdale Road Transfer Station
Notice of Deficiency
Page 3 of 5
August 30, 2019
Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0402(6) for failure to
maintain the facility in a sanitary condition. A build-up of waste was observed on the steel beams
and sheet metal that make up the transfer station walls, on the deflector panels above the
loading bay, on the push walls, and in and around the roll -off containers and drums of oil in the
maintenance area along the southeast interior wall of the building. Several separations and rips
in the panels of sheet metal on the outside wall of the loading bay, large enough to allow waste
to leave the transfer station, were also observed.
D. 15A NCAC 13B .0105(c)(4) states: "The vehicle or container body, waste holding area,
and hopper, if so equipped, shall be free of holes, cracks, rusting, corrosion, or other evidence
of damage or weakness that may allow the escape of solid, semi -solid, or liquid waste."
Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0105(c)(4) for failing to
ensure that waste transport trailers are maintained in a leak -resistant condition, free from holes,
cracks, rusting, corrosion, or other evidence of damage or weakness that may allow the escape
of solid, semi -solid, or liquid waste. During this inspection, trailers T-396 and T-301 were
observed to be loaded with waste and parked in the trailer and container storage area located to
the rear (northeast) of the transfer station and outside of the leachate collection system. T-396
was observed actively leaking leachate from a large crack in a seam on the floor of the trailer
onto the asphalt parking area. T-396 was driven off the site while leaking was occurring. Trailer
T-301 was observed to have several holes in the floor of the trailer; no leachate was observed
actively leaking from the trailer during the inspection.T-301 was also driven off the site, allowing
the potential for leachate and/or solid waste to be released from the trailer into the environment.
E. 15A NCAC 13B .0105(c)(6) states: "The vehicle or container shall be loaded, transported,
operated, and maintained to prevent the escape of solid, semi -solid, or liquid waste to the
environment."
Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0105(c)(6) for failing to
ensure that waste transport trailers are loaded, transported, operated, and maintained to
prevent the escape of solid, semi -solid, or liquid waste. During this inspection, trailers T-396
and T-301 were observed to be loaded with waste and parked in the trailer and container
storage area located to the rear (northeast) of the transfer station and outside of the leachate
collection system. T-396 was observed actively leaking leachate from a large crack in a seam on
the floor of the trailer onto the asphalt parking area. T-396 was driven off the site while leaking
was occurring. Trailer T-301 was observed to have several holes in the floor of the trailer; no
leachate was observed actively leaking from the trailer during the inspection.T-301 was also
driven off the site, allowing the potential for leachate and/or solid waste to be released from
the trailer into the environment.
I �
NORTH ARa N D_E IW Aj
oeaanmem of 1 auar\
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Overdale Road Transfer Station
Notice of Deficiency
Page 4 of 5
August 30, 2019
F. 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." Permit to Operate No. 3416T-TRANSFER-, ATTACHMENT 3,
PART VI, Transfer Station/Treatment and Processing Unit Condition #7(c) states: "Waste may be
stored on -site, in vehicles or containers that are constructed, operated, and maintained to be
leak resistant in order to prevent the creation of a nuisance to the public health from the escape
of solid, semi -solid, or liquid waste a maximum of 72 hours when the facility is closed during a
weekend or holiday."
Republic Services of North Carolina, LLC is in violation of 15A NCAC 13B .0203(d) for storing
waste on -site in vehicles or containers that are not constructed, operated and maintained to be
leak resistant. During this inspection, trailers T-396 and T-301 were observed to be loaded with
waste and parked in the trailer and container storage area located to the rear (northeast) of the
transfer station and outside of the leachate collection system. T-396 was observed actively
leaking leachate from a large crack in a seam on the floor of the trailer onto the asphalt parking
area. Trailer T-301 was observed to have several holes in the floor of the trailer.
The above violations may have or can compromise the facility's ability to ensure protection of
the public health and the environment and thus require remedial action on behalf of the facility
in order to maintain compliance with 15A NCAC 13B. In order to resolve these issues, Overdale
Road Transfer Station must take the following actions:
1. Immediately implement procedures to inspect each trailer before loading to ensure that
it has been maintained to prevent the escape of solid, semi -solid or liquid waste, and
train facility staff to effectively implement these procedures so that trailers found to be
out of compliance with 15A NCAC 13B .0105 are not used transport waste or to store
waste on -site.
2. By September 6, 2019, provide copies of all monthly facility inspection reports that
include inspection of transfer trailers; push walls; fire extinguishers; electrical controls;
trench drain, floor drains, and yard hydrant; washdown water collection sump and
pump; and oil/water separator for the period October 2018 through August 2019.
Reports shall be submitted to Susan Heim via email at [e-mail].
3. By September 20, 2019, clean the entire interior of the transfer station building of waste,
including the sheet metal/steel beam superstructure and concrete walls, the tipping
floor, the maintenance area, the push walls, the deflector panels, and the loading bay.
4. By September 20, 2019, repair holes in the sheet metal on the outside loading bay wall
of the transfer station building.
NORTH CAR(X IMA E QW/-)
oeaanmem m ee���eemee�1 oear�
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Overdale Road Transfer Station
Notice of Deficiency
Page 5 of 5
August 30, 2019
The violations 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.
Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct
follow-up inspections to verify that the facility has completed the requirements of this Notice of
Deficiency.
If you have any questions, please contact me at 336-776-9672 or e-mail [e-mail].
Sincerely,
Digitally signed by Susan
Heim
WasteSSusan Hm-Fiel Solid
Waste Section, ou=Field
Operations Branch,
email susa n.heim@ncdenr.g
=US
Date 2019.08.30 08:26:43
-04'00'
Susan Heim
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section
copies: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Jessica Montie, Compliance Officer
Chuck Kirchner, Environmental Senior Specialist
I �
NORTH ARa IN D_E IW Aj
oenanmem m e-mm�meeta1 0..1ity
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200