3415_INSP_20191029

oepamnem a� enmmnmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: Forsyth
MSWLF
PERMIT NO.: 3415-HHW-2010
Closed
HHW
X
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P/
Tire
industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: October 29, 2019 Date of Last Inspection: November 13, 2018
FACILITY NAME AND ADDRESS:
Resource Recycling and Reduction Company, LLC (3RC)
1401 South Martin Luther King, Jr. Drive
Winston-Salem, NC 27107
GPS COORDINATES: Lat.: 36.080422' Long.:-80.220221 °
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Michele E. Sakwa, President
Telephone: [phone] — office; [phone] — mobile.
Email address: [e-mail]
FACILITY CONTACT ADDRESS:
1401 South Martin Luther King, Jr. Drive
Winston-Salem, NC 27107
PARTICIPANTS:
LaKeisha Roper — 3RC
Chuck Kirchner, Environmental Senior Specialist — Solid Waste Section
Susan Heim, Environmental Senior Specialist — Solid Waste Section
STATUS OF PERMIT:
Permit to Construct/Operate issued December 3, 1999
Current Permit to Operate issued September 2, 2015
Permit to Operate Expires: April 5, 2020 - renewal request due October 5, 2019 — renewal request in progress.
PURPOSE OF SITE VISIT:
Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS:
N/A
OBSERVED VIOLATIONS:
None
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.
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D_E FACILITY COMPLIANCE INSPECTION REPORT
DO Ctd—iA Q�� Division of Waste Management
OepaNnen� e� Envimmenlal Oualiry
Solid Waste Section
ADDITIONAL COMMENTS:
1. All photos included in this report were taken by Susan Heim during the inspection on October 29, 2019.
2. The facility functions as a permanent household hazardous waste collection facility and operates Monday
through Saturday. The facility is open to the public from 9 am to 3 pm, Wednesday through Saturday, and is
permitted to accept waste generated only by households and conditionally exempt small quantity generators.
3. The current Permit to Operate and approved Operational Plan, Contingency Plan, Spill Prevention Plan and
Safety Plan were available at the facility office and reviewed. The SOP Manual was also available for review,
and is updated as needed to include revised or enhanced methods for processing and managing specific waste
materials received at the facility. The facility SOP Manual states that Ms. Sakwa or Ms. Roper are required to
be present when the facility is operating.
4. The facility Permit to Operate will expire on April 5, 2020. Please ensure that an application for permit
renewal is submitted to the Solid Waste Section as soon as possible. You may contact your permitting
engineer, Ming-Tai Chao, directly for assistance at 919-707-8251 or via email at minL,.chao@ncdenr.2ov.
5. The facility manages permanent HHW programs for Forsyth and Davidson Counties and provides disposal
services for Buncombe County's in-house HHW program. Facility employees staff and manage collection
events for Henderson, Madison, Onslow and Harnett Counties. The facility also accepts waste from other
customers that meet the permit restrictions and charges these customers for the waste they drop off for disposal.
As a convenience, the facility accepts televisions and electronics from Forsyth County residential customers.
6. All waste accepted at the facility is documented as it arrives. Facility staff complete a waste identification form
for every load received. The form includes the source of the load, the date and time received, and an inventory
of material received by weight. Completed waste identification forms are stored in file boxes by month. Three
years of records are maintained in the facility and are available for review. During this inspection, waste
identification forms for the month of May 2019 were reviewed and found to be complete.
7. The facility maintains an annual file containing waste manifests for all materials picked up for disposal by
contracted vendors. Current contracted vendors are as follows:
• Fluorescent bulbs and tubes — Southeastern Recycling (Johnson City, TN);
• Metals — OmniSource;
• Mixed chemicals and petroleum products — Shamrock Environmental.
8. Televisions and electronics are currently being disposed of through certified companies on a load by load basis.
Ms. Sakwa explained via telephone that E-Cycle Secure services became undependable, so she is currently
looking for a new vendor to take over the contractual relationship for this waste stream.
9. The facility operating record is maintained at the facility and includes daily and monthly totals of all waste
received at and removed from the facility.
10. A review of the 2018-19 facility annual report indicated that a total of 1,653,007.35 pounds of household
hazardous waste was received at the facility for disposal.
11. In Ms. Sakwa's absence, a comprehensive record of staff training was not available. However, Ms. Roper
explained that all employees are required to complete an annual 8-hour HAZWOPER refresher course and to
participate in all staff meetings and trainings at the facility. She then provided a copy of her own training
record for review, as well as digital versions of each employee's certificate for the successful completion of
HAZWOPER training. A review of this information confirmed that the following employees have completed
their 8-hour HAZWOPER refresher training: LaKeisha Roper, Christopher Jones, Elijah Jones, Roberto
Gonzalez and Kedric Barber. Ms. Roper explained that training routinely occurs at the facility, sometimes on a
daily basis but at least once a week, to ensure that staff have the most current information to enable them to
operate safely and effectively.
Facility Inspection:
12. The facility is surrounded by a chain link fence and secured with a locking gate at the street entrance. The gate
is kept locked when the facility is closed to the public. Proper signage was observed at the entry gate.
13. In general, the facility was observed to be clean and well -maintained. No unacceptable waste was found at the
site. Material storage areas were observed to be neat and appeared to be well -organized, with waste sorted by
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D_E FACILITY COMPLIANCE INSPECTION REPORT
NOFTH CAaOLiNA Division of Waste Management
OepaNnent d EnvimmenUl Oualiry
Solid Waste Section
type. Waste containers generally appeared to be in good condition, properly labeled and dated. All wastes in the
operations area of the building were stored on pallets, and no leaks or spills were observed.
14. Fluorescent bulbs and tubes are stored in cardboard barrels in a spare office rather than in the operations area.
This strategy serves to protect them from breakage as much as possible prior to their pick-up and removal by
Southeastern Recycling.
15. Incoming waste is unloaded outside of the building on a concrete pad, edged with curbing, that slopes toward a
closed sump. The unloading area is located on the south side of the facility and was observed to be clean and
well -maintained. During this inspection, Derek Bell and other staff of NC Department of Agriculture and
Consumer Services were working in the unloading area to collect the facility's pesticide waste for disposal.
16. The operations building has an overhead door that opens onto the unloading area. Inside the doorway, waste is
recorded, sorted and weighed as it is received. The receiving area appeared to be well -organized.
17. A pesticide area is located in the southwestern corner of the building, and the chemical collection and sorting
area is located adjacent to the receiving area. Both areas appeared to be neat and organized, with materials
sorted by type.
18. Paint collection and processing takes place near the center of the operations building, surrounded by a
secondary containment berm that is approximately 18" high. A number of pallets holding 1-gallon and 5-gallon
containers of paint were stored in this area, and a facility staff member was observed consolidating the latex
paint within the berm.
19. Acids are also stored and bulked within the central secondary containment area.
20. The entire area within the containment berm appeared to be well -organized, and all drums were observed to be
labeled and dated, as required.
21. Overhead doors on the eastern wall of the building, adjacent to the paint collection area, serve as a loading area
for non-flammable materials being removed for disposal or further processing. At the time of this inspection, a
number of palletized drums were staged in this loading area. Ms. Roper stated that a load of waste was being
assembled for pick up by Shamrock Environmental.
22. A flammables room is closed off from the rest of the facility by means of a heavy metal door that remains
locked at all times. The flammables room occupies the northeast corner of the building. Before opening the
room for inspection, Ms. Roper ensured that all cell phones and electronic key fobs were left in the main
operations area. The room was full of materials, most stored in the containers in which they were received,
waiting to be consolidated. Ms. Roper explained that the bulking of flammables must take place when
temperatures are lower to reduce the risk of fire. Flammables were stored on top of pallets and organized in
rows with aisles surrounding them to ensure easy access in the event of an emergency.
23. Some water was observed on the floor of the flammables room, and Ms. Roper stated that heavy rain or rain
accompanied by a brisk wind sometimes results in water entering the building through the exterior overhead
door. She added that the room is protected by closed sumps in each corner that would collect any waste that
leaked or mixed with the storm water.
24. The overhead door of the flammables room opens onto a covered gravel area that is used for consolidating the
flammables. Empty drums were stored in this area along with several drums that had already been filled.
25. Much of the eastern side of the property serves as an acceptance, sorting and processing area for televisions and
electronics. Ms. Roper stated that these materials are sorted, palletized and prepared for transport as they arrive
at the facility. Several dozen pallets of televisions and monitors were shrink-wrapped and staged for loading.
Ms. Roper explained that the facility currently schedules weekly pick-up of electronics. The electronics area
appeared to be clean and well -organized, and no electronic waste was stored on the ground.
26. A roll -off container full of scrap metal (including microwaves and small metal appliances and tools) was
located next to the palletized televisions. Ms. Roper stated that the scrap metal container is picked up as needed.
27. A roll -off container was staged in the gravel area on the east side of the building and is used to store non-
hazardous trash. During this inspection, the container was observed to be full. Ms. Roper stated that the trash
container was awaiting pick-up.
28. High concentrations of methane gas had been detected at the facility. Apparently, the gas had migrated from an
old closed landfill site on the adjoining property. Ms. Roper stated that corrective measures had been
undertaken and test results indicated that methane was no longer an issue.
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D_E FACILITY COMPLIANCE INSPECTION REPORT
DO Ctd—iA Q�� Division of Waste Management
OepaNnen� e� Envimmenlal Oualiry
Solid Waste Section
Right. A view of the eastern portion
of the operations area. The
chemical sorting and bulking area
can be seen in the right forefront,
and the large totes used for
collecting waste oil are visible on
the wall next to the open doorway.
n
40
f: Empty drums line the edge of
secondary containment area for
ex paints. Pallets of waste paint
be consolidated can be seen in
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Susan
Heim
Susan Heim, l Solid
Waste Section, ou=Field Operations Branch,
email=susan.heim@ncdenr.g
ov, c=US
Date: 2019.10.30 16:47:13
-04'00'
Susan Heim
Environmental Senior Specialist
Regional Representative
Phone: [phone]
background.
Sent on October 30, 2019 to
X
Email
Hand delivery
US Mail
Certified No. j__l
Michele Sakwa via:
Copies: Deb Aja, Western District Supervisor — Solid Waste Section
Chuck Kirchner, Environmental Senior Specialist — Solid Waste Section
Ming-Tai Chao, Permitting Engineer — Solid Waste Section
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