9503T_INSP_20230629

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 6

UNIT TYPE:
Lined
MSWLF LCID YW Transfer X Compost SLAS COUNTY: Watauga
Closed
MSWLF HHW X White
goods X Incin T&P FIRM PERMIT NO.: 95-03
CDLF Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: June 29, 2023 & July 20, 2023 Date of Last Inspection: June 22, 2022

FACILITY NAME AND ADDRESS:
Watauga County Transfer Facility
336 Landfill Road
Boone, North Carolina 28607

Watauga County Permanent HHW
336 Landfill Road
Boone, North Carolina 28607

GPS COORDINATES (decimal degrees): Lat.: 36.22032 Long.: -81.63165

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Rex Buck, Operations Services Director
Telephone: [phone]
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
Same as above

PARTICIPANTS:
Rex Buck, Operations Services Director – Watauga County
Phillip Harrison, Operations Services Manager – Watauga County
Charles Gerstell, NCDEQ – Solid Waste Section

STATUS OF PERMIT:
Permit to Operate 9503T-TRANSFER-1996 Watauga County Transfer Station and 9503-HHW-2015 Watauga
County Permanent HHW was issued to Watauga County on July 21, 2020. The Permit for the Transfer Station is for
the life-of-site of the facility. The permit for the Permanent HHW expires on August 26, 2025.

PURPOSE OF SITE VISIT:
Comprehensive and Partial Inspections

STATUS OF PAST NOTED VIOLATIONS:
Unresolved Violation - 15A North Carolina Administrative Code 13B .0203(d) states: “By receiving solid waste at a
permitted facility, the permittee shall be considered by the Department to have accepted the conditions of the permit and
shall comply with the conditions of the permit.”

General Facility Condition #19(a) states: “The leachate control system, such as floor drains, leachate collection
devices, sanitary sewer connections and leachate storage tanks, must be operational during facility operations.”

During a previous inspection performed on June 22, 2023, facility staff stated the leachate system within the tailer
loading bay was not operational. Instead of leachate being transported to the sanitary sewer system as designed, it is
currently pumped out by a septage management firm when needed.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 6

Watauga County was found in violation of 15A NCAC 13B .0203(d) and General Facility Condition #19(a) in that the
leachate control system within the trailer loading bay was not operational as required.

To achieve compliance, Watauga County was required to repair the leachate collection system to original design within
60-days of issuance of the previous inspection report. Any changes to the original design were required to be submitted
to the Solid Waste Section for review.

Inspection of the facility on June 29, 2023 found that the leachate system within the trailer loading bay was still
inoperable. Mr. Buck explained repair options were still being considered which includes installation of a new leachate
pipe leading from the trailer loading bay to a new 2,500-gallon tank located at the new trailer parking area currently
under construction. However, no information has been submitted to the Solid Waste Section to address the leachate
system concerns as required in last inspection report issued on July 1, 2022. Therefore, this violation is considered
unresolved.

To achieve compliance, within 30-days of receipt of the Notice of Violation, Watauga County must submit a
repair plan for the leachate collection and conveyance system. This plan must include a description of the
current status of the leachate system, a description of how the system will be repaired, and a timeline for
implementation of repairs. All information must be submitted electronically to:

Allen Gaither, Permitting Engineer
NCDEQ – Solid Waste Section
[e-mail]

OBSERVED VIOLATIONS:

15A North Carolina Administrative Code 13B .0201(c) states in part: “No solid waste management facility shall be
established, operated, maintained, constructed, expanded, or modified without a valid permit issued by the Division for
the specified type of activity.”

During the June 29, 2023 inspection, construction of a new trailer parking area adjacent to the transfer station building
was observed. Design plans for the parking area were submitted to the Solid Waste Section. However, construction
started prior to approval of the plans and issuance of a new Permit to Operate. Watauga County is in violation of 15A
NCAC 13B .0201(c) for modifying the solid waste management facility without a valid permit.

6/29/23: View of trailer storage area under construction.
(photo by C. Gerstell)

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 6

To achieve compliance, within 30-days of receipt of the Notice of Violation, Watauga County must obtain approval
for construction of the trailer loading area from the Solid Waste Section. Please contact Allen Gaither, Permitting
Engineer for approval. Should approval not be granted as designed, additional measures may be needed to achieve
compliance.

15A North Carolina Administrative Code 13B .0403(b)(1) states: “Sites shall be designed and constructed so that all
solid waste receiving, handling, transfer, and storage occurs on an impervious surface, such as concrete or asphalt,
unless otherwise stated in the site permit.”

During the June 29, 2023 inspection, a portion of the tipping floor was observed to be damaged. It appeared that the
concrete floor had eroded away leaving rebar exposed. Little effort was needed to dig into the remaining material which
had the consistency of gravel or soil. Watauga County is in violation of 15A NCAC 13B .0403(b)(1) for failure to manage
solid waste on an impervious surface.

6/29/23: View of damaged portion of tipping floor 6/29/23: View of damaged portion of tipping floor
Note change in thickness compared to concrete on with exposed rebar in center of photo.
right side of photo. (photo by C. Gerstell) (photo by C. Gerstell)

6/29/23: View of damaged tipping floor. Note area
in center of photo excavated with heel of a boot.
(photo by C. Gerstell)

To achieve compliance, within 30-days of receipt of the Notice of Violation, Watauga County must submit a repair
floor for the damaged tipping floor. This plan must include a description of how the tipping floor will be repaired,
and a timeline for implementation of repairs. All information must be submitted to Allen Gaither, Permitting
Engineer.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 6

15A North Carolina Administrative Code 13B .0405(10) states in part: “Windblown waste: Site staff shall conduct
daily inspections for windblown waste on the site property. Windblown litter from site operations discovered during the
daily inspections or observed on adjacent properties shall be picked up and containerized for disposal by the end of each
operating day, unless the landowner of the adjacent property denies access to site staff.”

During the June 29, 2023 inspection, windblown waste was observed at the base of the retaining wall on the north side of
the facility near the exit from the trailer loading area. Much of the waste was covered with residues indicating it had been
generated prior to that day’s operation. Some waste had been deposited over a storm drain which could result in waste
entering the storm drain. Windblown waste was also observed under the guardrail located on the east side of the facility
at the edge of the pavement and inside a storm drain located within the grassed area adjacent to the transfer station office.
The volume of material also appeared to indicate the waste was deposited prior that day’s operation as the inspection was
performed approximately 2-hours after the facility opened.

A partial inspection on July 20, 2023 found windblown waste well controlled. All waste previously observed on June 29,
2023 in the above mentioned areas of concern had been removed. Therefore, this violation is considered resolved.
Thank you for your cooperation.

ADDITIONAL COMMENTS

1. The facility is permitted to receive municipal solid waste generated within areas consistent with the service area of
the receiving facility.
2. A gate was provided at the entrance to the facility to prevent unauthorized access.
3. The Permit to Operate and Operations Plan were current and available upon request.
4. Tonnage reports for June 2022 – May 2023 were verified. The facility received approximately 170-tons of waste
each operating day during this time.
5. Certified Transfer Station Operations Specialist Certifications:
x Jim Fink (expires 7/19/24)
x Dale Miller (expires 5/19/24)
x David Miller (expires 3/12/25)
x Terry Scott (expires 11/16/25)
x Ryan Woodring (expires 7/19/24)
6. Waste screenings for January 2023 to present were verified. Screenings appeared to have been performed with
adequate frequency and provided good detail of observed unacceptable waste streams and final disposition of those
wastes. Facility staff were documenting the weight of each load screened to ensure the proper frequency of
screenings was being performed.
7. A comprehensive inspection was performed on June 29, 2023. All comments and violations documented on this
report were observed during the June 29th inspection. A partial inspection was performed on July 20, 2023 to look
at previous windblown waste concerns and the leachate trench drain only. Comments and violations were updated
where needed to provide current status of the these previously documented concerns.

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 5 of 6

Operations Inspection of the Transfer Station (9503T-TRANFER-1996)

8. Two separate entrances are provided for waste acceptance. The public enter on the south side of the building while
commercial vehicles and larger public vehicles enter on the east side of the building.
9. No unacceptable waste streams were observed.
10. During the June 29, 2023 inspection, a heavy buildup of residues was observed on grates covering the leachate
trench drain at the east entrance of the transfer station. A partial inspection on July 20, 2023 found new grates had
been installed over the leachate trench drain, and the grates were free of residues. Please continue to maintain the
trench drain to ensure proper function of the device.
11. During the June 29, 2023 inspection, it was discovered that the leachate conveyance system leading from the
trench drain located on the tipping floor was also inoperable requiring leachate being pumped out when needed.
During the partial inspection on July 20, 2023, Mr. Harrison stated the leachate drain had been repaired.
Inspection found no evidence the device was not functioning property. Thank you for your efforts to address this
concern.
12. The interior walls within the trailer loading bay were in need of pressure washing. This condition was noted on the
previous inspection report.
13. During the inspection, a large amount of waste was on site covering the majority of the tipping floor. Facility staff
stated the facility received an abnormal amount of waste the previous operating day. A fire also occurred at the
receiving landfill which prevented Watauga County from sending or receiving additional waste trailers. Staff
stated waste was left on the floor overnight as a result. However, staff remained on site throughout the night to
monitor the tipping floor.
x 15A NCAC 13B .0405 requires all waste be removed from the tipping floor, the truck loading bays,
and from behind push walls by the end of each day of operation and disposed of. Waste may not be
left on the tipping floor overnight. Should an emergency situation exist that must result in waste
remaining on the tipping floor after closing, the Solid Waste Section shall first be notified and a
request made showing no other options are available to the facility to manage the waste at that time.
14. During the inspection, the metal plate located at the transition from the concrete tipping floor to the trailer loading
bay had been pulled up allowing waste to be trapped below the metal plate. Mr. Buck and Mr. Harrison stated the
County was evaluating how to repair the metal plate. Please continue efforts to repair the plate to original
design. Until the plate is repaired, facility staff must ensure all waste and residues are removed from under
the plate at the conclusion of each operating day.

Operations Inspection of the White Goods Area:

15. White goods containing chlorofluorocarbon refrigerants (CFCs) are collected at the northwest corner of the
bailing/recycling building.
16. All white goods on site were maintained in an upright manner at the time of the inspection.
17. This area was well managed.

Operations Inspection of the Tire Collection Area:

18. Tires are collected into multiple covered trailers at the loading dock on the west side of the bailing/recycling
building. All tires were maintained within the designated trailers at the time of inspection.
19. This area was well managed.

Supporting Comments:

20. A convenience area for disposal of wastes and recyclables is provided on the north side of the access road across
from the scale house.
21. Electronics are collected within the bailing/recycling building and then placed on wooden pallets and shrink
wrapped or placed within gaylord boxes for shipment to the electronics vendor.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 6

22. Florescent bulbs and batteries are collected at the bailing/recycling facility. Bulbs are placed in cardboard
containers prior to shipment to the designated vendor.
23. During the inspection, significant staining was observed on the asphalt near the recycling building leading
from an area where garbage collection trucks are parked. Leachate was observed leaking from the rear
door of one truck having a license tag number of “24151-W”. Leachate from this truck was not leaving the
asphalt area.
x 15A North Carolina Administrative Code 13B .0105(c) requires vehicles used for the collection of
solid waste be constructed, operated, and maintained to be leak resistant in order to prevent the
creation of a nuisance to public health from the escape of solid, semi-solid, or liquid waste.
x Please ensure the truck is repaired as discussed during the inspection to sure it is leak resistant.
x The facility should have equipment on site to contain any leachate that may leak from vehicles to
prevent nuisance conditions.

Operations Inspection of the HHW Facility (9503-HHW-2015)

24. The Permit to Operate and Operations Plan for the facility were current and available upon request.
25. The facility consists of a steel building with three separate compartments for collection of HHW.
26. The facility operates on designated collection days starting in April and ending in October. During collection
events, wastes are collected ad immediately transferred from the site via the facility’s HHW collection vendor. In
most cases, no waste is maintained within the compartments unless a small amount is received by the general
public between collection events. A small amount of material was on site at the time of inspection.
27. All compartments were closed and locked upon arrival.
28. Secondary containment was provided for each compartment and was well maintained. The secondary containment
had not outlet.
29. A fire suppression system was provided to control fires at the facility. The system was last serviced in February of
2023.
30. Tall grass was observed on the back side of the building. Please mow all grass to provide a clear, unobstructed
path around the structure.

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: 7/21/23 Email Hand delivery X US Mail (with
NOV)
Certified No. [ _]

Copies: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Chris Hollinger, Compliance Officer
Digitally signed by Charles T. Gerstell
DN: cn=Charles T. Gerstell, o=Division of Waste
Management, ou=Solid Waste Section,
email=[e-mail], c=US
Date: 2023.07.21 09:46:56 -04'00'