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HomeMy WebLinkAbout3416_INSP_20201019NORTH CAROLINAD_E Q�� OepeNnenf of Envlronmmbl 0uel� FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section UNIT TYPE: Lined LCID YW Transfer X Compost SLAS COUNTY: Forsyth MSWLF PERMIT NO.: 3416T-TRANSFER- Closed HHW 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 19 and November 17, 2020 Date of Last Inspection: October 10, 2019 FACILITY NAME AND ADDRESS: Overdale Road Transfer Station 5000 Overdale Road Winston-Salem, NC 27101 GPS COORDINATES: Lat.: 36.033263 ° Long.:-80.231984 ° FACILITY CONTACT NAME AND PHONE NUMBER: Name: Jorge Fernandez, General Manager — Republic Services Telephone: 480-217-9380 (mobile) Email address: jemandez&republicservices.com FACILITY CONTACT ADDRESS: Republic Services 2875 Lowry Street Winston-Salem, NC 27101 PARTICIPANTS: Catherine Hernandez, Operations Manager — Republic Services (October 19 and November 17, 2020) Jorge Fernandez, General Manager — Republic Services (October 19 and November 17, 2020) Derek Bouchard, Environmental Manager — Republic Services (November 17, 2020 only) Susan Heim, Environmental Senior Specialist — Solid Waste Section (October 19 and November 17, 2020) STATUS OF PERMIT: Permit to Operate MSW Transfer Facility issued: January 6, 2003; Permit Amendment and Renewal issued: September 13, 2007; Permit Amendment and Renewal issued: September 17, 2012 Life of Site Permit to Operate issued: May 3, 2017. PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: A. RESOLVED: 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." Ms. Hernandez stated that all required facility inspections are now conducted by facility staff, as specified in the approved Operations Plan; and, all records of these required inspections are now being stored in the scale house at the transfer station so that they are available for review upon request. Random portions of these records were provided via email and were reviewed and verified. Therefore, this violation is considered to be resolved. B. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .0203(d) states, `By receiving solid waste at a Page 1 of 5 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management NORTH CAROLINA Solid Waste Section 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." New cleaning procedures have been implemented, and temporary repairs are being undertaken to achieve and maintain compliance until permanent solutions can be implemented. C. CORRECTIVE MEASURES IN PROGRESS: 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." See Violation B above for additional information about corrective actions being undertaken to achieve compliance. D. RESOLVED: 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." On November 17, 2020, all trailers at the facility were inspected and found to be free from holes and damage that could allow solid, semi -solid and liquid waste to escape the trailer. Therefore, this violation is considered to be resolved. E. RESOLVED: 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." See Violation D above for information about the corrective actions taken to resolve this violation. F. RESOLVED: 15A NCAC 13B .0203(d) states, in part: `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." See Violation D above for information about the corrective actions taken to resolve this violation. OBSERVED VIOLATIONS: No additional violations were observed. 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. ADDITIONAL COMMENTS: 1. The facility is owned by and the permit issued to Republic Services of North Carolina, LLC. Republic Services contracts with K. R. Drenth Trucking, Inc. to operate the transfer facility and to transport waste to the Uwharrie Environmental Landfill (permit No. 6204) and the Great Oak Landfill (permit no. 7607) for proper disposal. 2. Modifications to the approved Operations Plan had previously been submitted to the Solid Waste Section for review. Those modifications included the addition of the Great Oak Landfill (Permit # 7607) as an approved disposal facility. Mr. Bouchard stated that staff are now finalizing procedural modifications for the Operations Plan that would address the concerns expressed in September 2019 review comments Page 2 of 5 NORTH CAROLINAD_E Q�� OepeNnenf of Envlronmmbl 0w1� FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section provided by Ming-Tai Chao, Permit Engineer, Solid Waste Section. He added that these modifications cover the new facility and trailer inspections, and any changes or additions to the housekeeping procedures that will be required of the operations staff onsite. Mr. Bouchard advised that these additional modifications to the Operations Plan should be ready to submit to the Solid Waste Section within the next two weeks. 3. New checklists have been designed by Republic Services staff to ensure that the facility and trailer inspections required by the approved Operations Plan are implemented and incorporated into daily operations. Ms. Hernandez provided copies of completed trailer inspection and facility inspection logs via email on October 9 and October 14, 2020. These records cover the period July through October 2020 and, upon review, were verified and found to be complete. 4. A review of the 2019-20 facility annual report indicated that 128,793.45 tons of waste were accepted at the facility from July 1, 2019 through June 30, 2020. Tonnage records for July, August and September 2020 were provided by Ms. Hernandez via email and reviewed. 5. As requested, Ms. Hernandez provided randomly chosen waste screening forms via email from the period July 1 through September 30, 2020. These forms were reviewed and found to be complete. Facility Inspection: 6. The facility is surrounded by chain link fencing and secured with locking gates located at the entrance on the southwest side of the site and trailer entrance on the southeast side of the site. 7. Proper signage was observed at the facility entrance. 8. The entire facility is paved. Ms. Hernandez pointed out several areas where the asphalt has become damaged. She stated that repairs were planned during the next several months. 9. The site was observed to be clean and well -maintained. Windblown litter was well -managed on October 19 and November 17, 2020. 10. The site is sloped so that surface water is directed to a series of stormwater inlets located along the curbing on the north side of the facility. These inlets were observed to be functional and free from windblown waste. 11. The storage area for both loaded and empty transfer trailers is located on the northeast end of the site. Any leachate escaping the trailers parked in this area would be directed to the stormwater collection system instead of the leachate collection system. Ms. Hernandez stated that she was looking into temporary measures that would capture the leachate into some sort of trough or vessel that could then be emptied into the drains in the loading bay. Mr. Bouchard added that he would be seeking other permanent alternatives that would capture and direct leachate from the trailer parking area to the leachate collection system. 12. On October 19, 2020, two loaded transfer trailers (# 240 and #365) parked in the trailer staging area were observed to be leaking. Ms. Hernandez stated that she would pull the leaking trailers from service until they were repaired. Workorders showing the completed repair of trailers 240 and 365 were provided via email following the October 19, 2020 inspection. During the November 17, 2020 inspection, all trailers were inspected and found to be in good condition with no apparent holes or leaks. (See Status of Previously Noted Violations section of this report for additional information.) 13. On October 19, 2020, an inspection of the tipping floor revealed a lack of daily cleaning and maintenance procedures. The southern side of the tipping floor is not used as much as the northern side, which abuts the loading bay. Although the southern portion of the floor appeared to have been cleaned as required, a buildup of waste was visible along the southern wall of the transfer building, which included a dead rat. The remainder of the tipping floor was covered with a thick, gummy waste residue, indicating that additional cleaning procedures are necessary to ensure that sanitary operating conditions are maintained. 14. On November 17, 2020, the southern side of the tipping floor appeared to have been cleaned properly. No residual waste was observed along the southern wall inside the transfer building. However, the thick, gummy coating of waste was still apparent on the remainder of the tipping floor. Ms. Hernandez stated that she had been meeting with K. R. Drenth facility staff to convey the expectations for daily cleaning and maintenance of the facility. She added that she would be monitoring the facility to ensure that these expectations are being met daily, as required. (See Status of Past Noted Violations section of this report for additional information.) Page 3 of 5 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management NORTH CAROLINA Solid Waste Section 15. Seams in the concrete, especially near the center and rear of the floor, are showing signs of wear and separation. Ensure that the integrity of the tipping floor is maintained so that leachate is not allowed to leave the collection system. 16. On October 19, 2020, the loading bay was observed to contain an unacceptable buildup of waste. Dented and damaged deflector panels allow excessive waste to miss the trailer and accumulate on the structural beams and loading bay floor. When the loaded trailer was pulled out of the bay, Ms. Hernandez directed facility staff to collect and remove the accumulated waste prior to parking an empty trailer in the bay. 17. On November 17, 2020, facility staff were observed clearing waste from the bay as trailers were being switched out. However, a build up of waste was still evident in the loading bay. Ensure that all waste is removed and that the loading bay is thoroughly cleaned at the end of every operating day. (See Status of Past Noted Violations section of this report for additional information) 18. Trench drains in the loading bay appear to have been covered with solid steel plates that allow waste to collect and prevent the flow of leachate into the collection system. During the October 19 and November 17, 2020 inspections, Ms. Hernandez and facility staff were unable to remove the plates so that the drains could be inspected. In addition, Mr. Bouchard is working with consulting engineers to determine the original design of the trench drains so that they can be restored to that approved design and function as approved. In the interim, facility staff will be using a hose to wash out the trench drains and collect and remove accumulated waste from the loading bay at the end of every operating day. (See Status of Past Noted Violations section of this report for additional information.) 19. Please provide documentation of the pressure washing of the transfer building and loading bay that was to have taken place in November 2020. 20. During both the October 19 and November 17, 2020 inspections, waste was observed to have escaped the transfer building through corroded and missing metal siding on the outside wall of the loading bay. No patches or repairs had been made, and Mr. Fernandez stated that he was reviewing quotes to replace the entire metal wall. In a conversation following the November 17, 2020 inspection, Mr. Bouchard stated that temporary metal patches would be installed immediately to prevent waste from escaping the facility, and that plans would continue for replacement of the entire wall to achieve a permanent solution. One of the trench drains in the loading bay is permanently covered with a solid metal plate that allows waste to accumulate and become imbedded in the drain. (Photo provided by Catherine Hernandez on 11/17120) Page 4 of 5 NORTH CAROLINAD_E Q�� OepeNnenf of Envlronmmbl 0w1� FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Accumulated waste is evident in all areas of the loading bay. (Photo provided by Catherine Hernandez on 11/17120) Please contact me if you have any questions or concerns regarding this inspection report. Digitally signed by Susan Heim DN: cn=Susan Heim, o=Solid g[ Waste Section, ou=Field d Operations Branch, email=susan.heim@ncdenr.g ov,c=US Date: 2020.11.25 14:24:47 -05'00' Susan Heim Environmental Senior Specialist Regional Representative Phone: 336-776-9672 Sent on: November 24, 2020 X Email Hand delivery US Mail Certified No. to Jorge Fernandez. Copies: Deb Aja, Western District Supervisor — Solid Waste Section Ming-Tai Chao, Permit Engineer — Solid Waste Section Derek Bouchard, Environmental Manager — Republic Services Catherine Hernandez, Operations Manager — Republic Services Page 5 of 5