3608_INSP_20161205

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 12

UNIT TYPE:
Lined
MSWLF LCID YW Transfer X Compost SLAS COUNTY: Gaston
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: 36-08-Transfer-1993
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: 12-5-16 Date of Last Inspection: 10-12-16

FACILITY NAME AND ADDRESS:
Waste Management Transfer Station, Ranlo Facility
2712 Lowell Road
Gastonia, NC 28054

GPS COORDINATES: N: 35.27943 W: -81.12120

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Jeffrey Edwards, District Manager
Telephone: [phone]
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
Same as above

PARTICIPANTS:
Jeffrey Edwards, District Manager
Steven Edwards, Commercial RM
Daniel Moore, P.G., Environmental Protection Manager
Kim Sue, NCDEQ - Environmental Senior Specialist - Solid Waste Section

STATUS OF PERMIT:
Current – Approved May 12, 2016 (DIN 26093) expires May 10, 2021
Operations Plan – Approved May 12, 2016 (DIN 25637)

PURPOSE OF SITE VISIT:
Operational Inspection

STATUS OF PAST NOTED VIOLATIONS:

1. RESOLVED: 15A NCAC 13B .0203(d): cited for failure to perform the required random inspections for waste
screening as required by General Permit Condition Number 19. The facility provided waste screening records for
random inspections on December 2, 2016. A review of these records showed that:
 October - 15 random inspection were performed from October 13, 2016 to October 13, 2016.
 November - 17 random inspection were performed from November 1, 2016 to November 30, 2016.
Therefore, this violation is considered resolved.

2. RESOLVED: 15A NCAC 13B .0402(1) cited for failure to perform the required random inspections for waste
screening in accordance with the operations plan. The facility provided waste screening records for random
inspections on December 2, 2016. A review of these records showed that:
 October - 15 random inspection were performed from October 13, 2016 to October 13, 2016.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 12

 November - 17 random inspection were performed from November 1, 2016 to November 30, 2016.
Therefore, this violation is considered resolved.

3. RESOLVED: 15A NCAC 13B .0203(d) cited for failure to comply with General Permit Condition Number 20(c).
An inspection of all loaded trailers being used at Waste Management Transfer Facility revealed the measures Waste
Management had implemented to ensure leachate would not leak out of the loaded trailers. All leaking trailers from
the prior inspection on October 12, 2016 have been replaced and/or repaired. All trailers are staged with the
open/doored ends facing up-gradient, so that potential leakage will be minimized in the event of faulty containment.
Lateral cross-door chains are being used on all trailers to ratchet tight, drawing the doors tightly together. This action
tightens the door seals. Troughs were placed underneath the back end of all trailers as a protective measure. During
the inspection leachate was observed actively leaking from loaded trailer #3856. The leak was pointed out to staff and
immediately a trough was moved under the leak. Facility staff had identified a leak towards the front end of the trailer
and moved a trough underneath. Facility staff noted the leak and stated the trailer will be taken out of service to make
all necessary repairs. No leachate was observed flowing across the gravel parking lot and no objectionable odors
were detected in the vegetated area to the south of the facility. Therefore, this violation is considered resolved.

Lateral cross-door chain. Photo taken
by: Kim Sue 12-5-16.
Trough underneath back end of trailer.
Photo taken by: Kim Sue 12-5-16.
Troughs underneath back end of
trailers. Photo taken by: Kim Sue
12-5-16.
Trailer identified with several leaks.
Photo taken by: Kim Sue 12-5-16.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 12

4. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .0402(1) cited for failure to comply with the
Facility Operations Plan.

The approved Facility Operations Plan Waste Management of Carolina, Inc., dated May 12, 2016 (DIN
25637, Page 4) “Waste Acceptance & Storage” states: “If the waste is to remain on site for more than seven
days after collection from the generator, a refrigerated type trailer will be utilized. The loaded or partially
loaded trailers will primarily be staged on a concrete pad outside the facility. If necessary, the trailers may be
staged on the yard as identified on the facility diagram. The staged trailers will be inspected during loading,
prior to staging outside, and prior to transfer to identify leaks or spills. If leaks or spill are identified, clean up
and decontamination procedures will be implemented as outlined in the transportation vehicle’s contingency
plan”.

An inspection of all loaded trailers being used at Waste Management Transfer Facility revealed the measures Waste
Management had implemented to ensure leachate would not leak out of the loaded trailers. All leaking trailers from the
prior inspection on October 12, 2016 have been replaced and/or repaired. All trailers are staged with the open/doored
ends facing up-gradient, so that potential leakage will be minimized in the event of faulty containment. Lateral cross-door
chains are being used on all trailers to ratchet tight, drawing the doors tightly together. This action tightens the door seals.
Troughs were placed underneath the back end of all trailers as a protective measure. During the inspection leachate was
observed actively leaking from loaded trailer #3856. The leak was pointed out to staff and immediately a trough was
moved under the leak. Facility staff had identified a leak towards the front end of the trailer and moved a trough
underneath. Facility staff noted the leak and stated the trailer will be taken out of service to make all necessary repairs.
Facility staff contacted Ervin Lane, Compliance Hydrogeologist, and the required soil sampling plan was prepared by
Golder Associates NC, Inc. and submitted to DEQ on November 17, 2016. The plan was approved by Mr. Lane on
November 21, 2016 and implemented by Golder on November 22, 2016. Waste Management’s consultant is awaiting the
soil sampling analytical results, necessary for completion of the assessment report. Waste Management is waiting to
gravel the staging area till after the completion of the assessment report in case further actions to remediate leachate
releases is required. The standing water is the result of recent rain events.

Leachate leaking below trailer #3856.
Photo taken by: Kim Sue 12-5-16.
Trough moved immediately to capture
leachate. Photo taken by: Kim Sue
12-5-16.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 12

5. RESOLVED: SL2013-413, Section 59.2(c), in amending 15A NCAC 13B .0105 cited for failing to maintain
vehicles used for the collection and transportation of solid waste to be leak-resistant in accordance with industry
standards.

Documentation was provided on December 2, 2016 confirming that Waste Management’s contracted facility operator and
waste transfer company had replaced and/or repaired all of the identified transfer trailers that were on site during the
October 12, 2016 inspection. An inspection of all loaded trailers being used at Waste Management Transfer Facility
revealed the measures Waste Management had implemented to ensure leachate would not leak out of the loaded trailers.
All trailers are staged with the open/doored ends facing up-gradient, so that potential leakage will be minimized in the
event of faulty containment. Lateral cross-door chains are being used on all trailers to ratchet tight, drawing the doors
tightly together. This action tightens the door seals. Troughs were placed underneath the back end of all trailers as a
protective measure. Therefore, this violation is considered resolved.

6. RESOLVED: 15A NCAC 13B .0203(d) cited for failing to properly capture leachate in the collection system in
accordance with General Permit Condition Number 21(a) and (b).

During the inspection no leachate was leaving the confines of the transfer building and flowing north across the paved
parking lot. The straw bales located along the edge of the parking lot up against the guard rail have been permanently
removed. The facility’s wash-down water faucet has been repaired reducing the amount of leachate generated. The trench
drain across the entrance to the transfer station was clean and free of waste. Tipping floor and loading bay floor drains
are, on a daily basis, being removed and accumulated trash is being removed. The drainage ways are washed down to
assure free flow of wastewater/leachate to the oil-water separator. Therefore, this violation is considered resolved.

7. RESOLVED: 15A NCAC 13B .0402(3) cited for leachate leaving the confines of the transfer building and flowing
across the parking lot.

During the inspection all leachate was being collected in the leachate collection system. The straw bales located along the
edge of the parking lot up against the guard rail have been permanently removed. The facility’s wash-down water faucet
has been repaired reducing the amount of leachate generated. The trench drain across the entrance to the transfer station
was clean and free of waste. Tipping floor and loading bay floor drains are, on a daily basis, being removed and
BEFORE Leachate release in the loaded trailer
parking lot. Photo taken by: Kim Sue 10/12/16.
AFTER No leachate observed flowing to the
vegetated area from the loaded trailer parking lot.
Photo taken by: Kim Sue 12-5-16.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 12

accumulated trash is being removed. The drainage ways are washed down to assure free flow of wastewater/leachate to
the oil-water separator. Therefore, this violation is considered resolved.

BEFORE Leachate flowing across parking lot. Photo
taken by: Kim Sue 10/12/16
BEFORE Leachate flowing across parking lot to
straw bales. Photo taken by: Kim Sue 10/12/16
AFTER No leachate flowing across parking lot.
Photo taken by: Kim Sue 12/5/16
AFTER No leachate flowing across parking lot and
straw bales removed. Photo taken by: Kim Sue
12/5/16.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 12

8. RESOLVED: 15A NCAC 13B .0203(d) cited to maintain the tipping floor in a clean and sanitary condition in
accordance with General Permit Condition Number 20(a).

The trench drain across the entrance to the transfer station was clean and free of waste. Tipping floor and loading bay
floor drains are, on a daily basis, being removed and accumulated trash is being removed. The drainage ways are washed
down to assure free flow of wastewater/leachate to the oil-water separator. Therefore, this violation is considered
resolved.

9. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .0402(1) cited for failure to follow the Facility
Operations Plan.

The approved Facility Operations Plan Waste Management of Carolina, Inc., dated May 12, 2016 (DIN 25637,
Page 4) “Housekeeping & Vector Control” states: “The operator is responsible for the operations, maintenance,
and general housekeeping of the facility. All extraneous solid waste will be swept and removed by broom and/or
shovel during the operations day. Any extremely wet material will be removed by washing the area down with water.
This wastewater will be routed to the sanitary sewer”.

During the inspection minimal waste was observed deposited on the I beams in the trailer loading bays. The missing
deflector sections are to be replaced by a contractor in the next few months. Additional deflectors across the I beams are
to be installed allowing waste to fall more freely into the trailers. Facility staff perform daily removal of waste which can
be reached in a safe manner from the I beams. Daily housekeeping checklist forms were reviewed. The section where the
deflector was missing is clogged with waste and will be removed safely by the contractor and a new deflector installed.
All waste was removed behind the east push wall and this area is checked on a daily basis. The insulation on the rear wall
of the transfer station will be removed by the contractor. A complete wash down of the walls will be conducted after all
repairs are completed by the contractor.

BEFORE Residue in trench drain. Photo taken by:
Kim Sue 10/12/16
AFTER Trench drain free of residue and debris.
Photo taken by: Kim Sue 12/5/16.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 12

BEFORE Waste build-up on I beams in trailer
loading bay. Photo taken by: Kim Sue 10/12/16
Solid waste and missing section in deflector to be
replaced by contractor. Photo taken by: Kim Sue
12/5/16
AFTER Waste is picked up by facility staff during
daily housekeeping duties. Photo taken by: Kim Sue
12/5/16.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 12

9. RESOLVED: 15A NCAC 13B .0203(d) cited for failure to pick up windblown litter at the end of each day in
accordance with General Permit Condition Number 20 (e) (ii).

During the inspection no windblown material was observed. Windblown material is picked up throughout the day and
documented on daily housekeeping checklists. Therefore, this violation is considered resolved.

10. RESOLVED: 15A NCAC 13B .0402(7) cited for failure to pick up windblown litter at the conclusion of each day.

During the inspection no windblown material was observed. Windblown material is picked up throughout the day and
documented on daily housekeeping checklists. Therefore, this violation is considered resolved.

10. RESOLVED: 15A NCAC 13B .0402(1) cited for failure to follow the Facility Operations Plan.

The approved Facility Operations Plan Waste Management of Carolina, Inc., dated May 12, 2016 (DIN
25637, Page 4) states: “Windblown litter is controlled at the transfer station by using covered transfer and
collection vehicles, confining waste transfer activities to the inside of the building, and controlling vehicle access
to the transfer building. Litter that escapes the transfer building will be picked up daily and managed to minimize
contact with stormwater”.

During the inspection no windblown material was observed. Windblown material is picked up throughout the day and
documented on daily housekeeping checklists. The stormwater trench drains and wastewater trench drains are
monitored, cleaned several times a day and documented on the daily housekeeping checklists. No waste was observed
washing to the open ditch and retention pond. Therefore, this violation is considered resolved.
BEFORE Waste behind east push wall. Photo
taken by: Kim Sue 10/12/16
AFTER Waste removed daily behind east push wall.
Photo taken by: Kim Sue 12/5/16.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 9 of 12

BEFORE Windblown litter around scaffolding. Photo
taken by: Kim Sue 10/12/16
BEFORE Windblown litter along access
road to trailer loading bays. Photo taken by:
Deb Aja 10/12/16
AFTER No windblown material observed. Staff placed
a roll out waste container at this location. Photo taken
by: Kim Sue 12/5/16.
AFTER No windblown material observed. Photo
taken by: Kim Sue 12/5/16.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 10 of 12

BEFORE Windblown litter against retaining wall
along access road to trailer loading bays. Photo taken
by: Kim Sue 10/12/16
BEFORE Trash washing down trench drain in front of
loading bays to storm drainage ditch. Photo taken by:
Kim Sue 10/12/16
AFTER No windblown litter against retaining wall
along access road to trailer loading bays. Photo taken
by: Kim Sue 12/5/16.
AFTER No trash washing down trench drain in front
of loading bays to storm drainage ditch. Photo taken
by: Kim Sue 12/5/16.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 11 of 12

ADDITIONAL COMMENTS
1. All cracked sewer clean-outs have been repaired.

2. The severed vent for the oil-water separator has been repaired.

3. During the inspection facility staff was actively picking up windblown waste.

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

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Please contact me if you have any questions or concerns regarding this inspection report.

__________ ___________________________ Phone: [phone] _

Kim Sue
Environmental Senior Specialist
Regional Representative

E-mailed to: Jeffrey Edwards
on 12/20/2016
X Email Hand delivery US Mail Certified No.

Copies: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor - Solid Waste Section
Jessica Montie, Compliance Officer - Solid Waste Section
Ervin Lane, Compliance Hydrogeologists – Solid Waste Section
Shawn Carroll, Waste Management, [e-mail]
Dan Moore, Waste Management, [e-mail]