0303T_INSP_20191211

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 5

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

Date of Site Inspection: December 11, 2019 Date of Last Inspection: April 25, 2019

FACILITY NAME AND ADDRESS:
Alleghany County Transfer Facility
419 Osbourne Road
Sparta, North Carolina 28675

GPS COORDINATES: Lat.: 36.49343 Long.: -81.14980

FACILITY CONTACT NAME AND PHONE NUMBER:
Name:
Telephone: [phone]
Email address:

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

PARTICIPANTS:
Josh Greene, Public Works Director – Alleghany County
Brandon Harris – Alleghany County
Charles Gerstell, NCDEQ – Solid Waste Section
Kim Sue, NCDEQ – Solid Waste Section

STATUS OF PERMIT:
A Permit Approval To Operate the Alleghany County Transfer Facility was issued to Alleghany County on October 11,
2019. This permit was for the life-of-site of the facility.

PURPOSE OF SITE VISIT:
Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
N/A

OBSERVED VIOLATIONS:
A. 15A North Carolina Administrative Code 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.”

15 North Carolina Administrative Code 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.”

x General Facility Permit Condition #17(e)(ii) states: “Windblown materials must be collected by the end of
the day and no windblown material may be allowed to leave the facility boundary.”
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 5

During the inspection, a large amount of windblown waste was observed in multiple locations. Areas of most concern
include the eastern perimeter of the closed MSWLF landfill (0302-MSWLF-1981), and areas immediately
surrounding the transfer facility building. Waste was also observed outside of the facility boundary on the opposite
side of Osbourne Road near the entrance to the facility. The volume of windblown waste indicated it had
accumulated over a period of multiple days.

Alleghany County is in violation of 15A NCAC 13B .0402(7) and .0203(d) in that windblown waste had not been
collected at the conclusion of each day of operation.

12/11/19: View of windblown waste on opposite side 12/11/19: View of windblown waste on eastern
of Osbourne Road. (photo by C. Gerstell) perimeter of closed MSWLF. (photo by C. Gerstell)

12/11/19: View of windblown waste on south side
of facility building. (photo by C. Gerstell)

To achieve compliance, Alleghany County must pick up all windblown waste and return it to the transfer
station for proper disposal with 15-days of receipt of the Notice of Deficiency.

B. 15 North Carolina Administrative Code 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.”

x General Facility Permit Condition #17(b) states in part: “Waste must only be deposited on the “tipping
floor” or directly into a transfer container.”

During the inspection, two bags of waste (one containing pillows and cushions and one of unknown contents were
observed in the grassed area on the south side of the transfer station building.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 5

Alleghany County is in violation of 15A NCAC 13B .0203(d) in that waste was not deposited on the tipping floor as
required by permit.

12/11/19: View of bagged waste in grassed area on
south side of transfer station facility.

To achieve compliance, all waste received at the facility must be deposited on the “tipping floor” only. All
waste observed during the inspection must be collected and properly disposed.

ADDITIONAL COMMENTS

1. The facility consists of a transfer facility, a convenience area for the collection of recyclables, 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.
3. A recycling center is located in a building adjacent to the transfer station. The recycling center is used for the
collection of cardboard, paper, glass bottles, steel and aluminum cans, and plastic containers.
4. A gate was located at the entrance to the facility to prevent unauthorized access.

Records Review:

5. The Permit and Operations Plan were discussed. A copy of the current permit was current and available upon
request. Facility staff could not present a copy of the approved Operations Plan. It is required that copies of the
permit, the approved plans and all records required to be maintained by the permittee must be maintained at the
facility, unless otherwise approved by the Section, and made available to the Section upon request during normal
business hours. Please ensure that a copy of the Operations Plan is maintained at the facility in the future.
6. Tonnage records for January 2019 to present were verified. Records indicated that the facility received 9,357.86-
tons during this time.
7. No temperature records were available for review as compost of vegetative debris has not yet commenced since the
last comprehensive inspection.
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

Page 4 of 5

8. Transfer Station Operations Specialist Certification:
x Roger Halsey (expires 2/11/21)
x Steven Harris (expires 10/19/22)
x Joseph McGraw (expires 2/11/21)
x Bill Saltz (expires 9/15/22)
9. Waste screening reports were verified for January 2019 to present. One screening was performed each week from
January through June 2019. However, no screenings were performed between June 19th and November 2nd. Only
two screenings were performed in November and one in December. Please ensure that waste screenings are
performed to capture 1% of the waste stream as detailed in the approved Operations Plan. Frequency of screenings
need to be increased. Please be sure screenings detail any unacceptable waste streams observed and steps taken to
properly dispose of those wastes.

Operations Inspection of the Transfer Facility:

10. No unacceptable waste streams were observed.
11. During the inspection, several pieces of plywood at the top of the push walls had been displaced on both sides of
the transfer facility tipping floor. This condition must be repaired to prevent waste from being deposited behind
the push walls. Any waste trapped behind the push walls must be removed.
12. During the inspection, two bags of garbage and some and some insulation were observed to have been dumped on
the asphalt just outside of the transfer station building. A large amount of waste was on the tipping floor at his
time as Mr. Saltz was removing waste from the transfer trailer loading bay in order to pull an empty trailer into the
bay. The bags were collected and properly disposed prior to the end of the inspection. Please ensure that all waste
is deposited on the tipping floor as required by the approved permit.
x It is recommended that facility operations be examined to determine if alternative practices can be
provided to ensure adequate space is provided on the tipping floor at all times so that waste is deposited
only on the tipping floor.
13. It is recommended that steps be taken to prevent collection of waste on the transfer station tipping floor such
reinstallation of the deflector located above the transfer trailer loading bay.
14. A portion of the steel above the small office area in the transfer facility had been pulled back allowing waste to be
caught between the steel and the top of the push wall. Please ensure that any waste in this area is collected and
properly disposed. The steel should be repaired to prevent additional waste from being caught.
15. A heavy buildup of residues was observed on the walls of the facility and were in need of pressure washing.

Operations Inspection of the White Goods Area:

16. White goods are collected on a covered concrete pad south of the transfer station building.
17. Multiple white goods containing chlorofluorocarbons (CFCs) were observed lying on their sides at the time of
inspection. Please ensure that all white goods containing CFCs are maintained in an upright condition to maintain
the integrity of the device.
18. During the inspection, food wastes such as packs of chicken, salad dressing, and a pack of hotdogs was observed
on the concrete floor. It appeared that this waste was removed from a refrigerator. Facility staff could not provide
information as to how long this waste had been left on the concrete floor. Any food waste from white goods
should be immediately taken to the transfer station for proper disposal.
19. Efforts need to be taken to improve the condition of this area to prevent the creation of a nuisance.

Operations Inspection of the Type 1 Compost Area:

20. Multiple pieces of plywood were observed within the grinding area at the time of inspection. Engineered wood
products are not acceptable waste streams for the compost operations. Please ensure all engineered wood products
such as plywood are removed for proper disposal. Any such material observed during grinding operations must
also be removed.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 5

21. Mr. Greene explained that the contractor was recently on site to grind the wood waste, but the grinder had broken
down. The grinder was on site during the inspection, but the engine had been removed for repairs.
22. A pile of unground material was observed on the western edge of the closed MSWLF. This material must be
removed, and steps taken to ensure that no material is stored or deposited on top of the closed landfill.

Supporting Comments:

23. A covered trailer is provided adjacent to the transfer station for the collection of electronics. A roll-off container is
also provided for the collection of metal.
24. The collection tank designated for the collection of used oil had been relocated to the recessed area adjacent to the
electronics trailer. A secondary containment area constructed of concrete blocks had been provided around the
tank. Mr. Greene explained that plans are to build a roof over the secondary containment area to prevent rainfall
from collecting in the collection area.
25. A high wall had been installed at the collection trailers designated for collection of tires and empty pesticide
containers. Please continue to ensure that all tires and containers are maintained in the designated trailers.
26. A beneficial fill area is located west of the transfer station building. During the inspection, multiple pieces of
dimension lumber, PVC pipe, and plywood were observed in this area. All unacceptable waste steams must be
removed for proper disposal. As noted on the previous inspection report, it is recommended that this area be
evaluated for unacceptable materials by facility staff at the end of each working day.
27. During the inspection, it appeared that much of the windblown waste originated from recycling activities on site.
When asked, Mr. Greene stated that none of the doors on the recycling building were able to close.
x It is recommended that all recycling activities be evaluated to determine how recyclables subject to being
windblown can be maintained to the designated collection area. Any necessary repairs needed to the
recycling building should be completed as soon as possible.
28. Effort must be made to improve the operating conditions of this facility to ensure compliance with the Solid
Waste General Statues and Administrative Rules.
x General Facility Permit Condition #8 states: “The permittee must 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 the permit. Proper
operation and maintenance include effective performance, adequate funding, adequate operator
staffing and training, and adequate laboratory and process controls, including appropriate quality
assurance procedures.”
x It is recommended that the County evaluate all facility activities to ensure that General Facility
Permit Condition #8 is being met.

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: 12/19/19 Email Hand delivery X US Mail (w/
NOD)
Certified No. 7018 0360
0002 20992 922

Copies: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor - Solid Waste Section
Digitally signed by Charles T. Gerstell
DN: cn=Charles T. Gerstell, o=Divsion of
Waste Management, ou=Solid Waste
Section,
email=[e-mail], c=US
Date: 2019.12.19 10:01:13 -05'00'