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Home My WebLink About18018_Singer Furniture_HWSA Permit Renewal Application_19991005Mr. Qualls Page2 October 5, 1999 is an outlin1; of what the FMB expects to be in Singer's HSWA-only permit renewal application. This outline is provided as a guide for Singer to follow in preparing a revised pe.nnit application. Th~ outline consists of "Parts" A, B, J, K, L, and N rrom a typical RCRA hazardous waste permit application. In addition, attached to this letter are checklists for the "Parts" listed below that are required to be in Singer's HSWA-only pennit application. HSWA-ONL Y PERMIT APPLICATION OUTLINE Part A EPA Form 8700-23 (Rev. 10/09/98). See Checklist PartB Facility Description. See Checklist. In addition to the checklist, Singer Furniture must include in Part B: PartJ PartK Part L PartN The former and current nature of business at the Singer Facility. Complete and detailed listing of hazardous wastes Singer generated, treated, stored, or disposed at the facility Brief summary of the regulatory history for the facility. Other Federal Laws. See Checklist. Certification. See Chr;cklist. Information Requirements for Solid Waste Management Units. See checklist. This part must include a brief swnmary of all sampling and laboratory analysis of ground water, land surface and subsurface strata, surface water, sediment, and air that has been conducted to date at each SWMU. The swnmary should include tables showing only the contaminants detected (including flagged data) at each SWMU. In addition, a brief summary must be provided that discusses the lateral and vertical e>..ient of all contaminants detected in ground water, land surface and subsurface strata, surface wate.r, sediment, and air at each SWMU. Substantial Compliance and Financial Qualification. See ch~cklist. ., I I r Mr. Qualls Page 3 October 5, 1999 SPECIFIC COMMENTS Part A -Application [40 CFR 270 as adopted in l5A NCAC 13A .0113] Section XI 1. Singer must include the current.nature of business at the facility. Singer may indicate the past nature of business as well. (40 CFR 270.13 (m)] Sectio1~ XII, XIII, and XIV 2. These sections should be left blank since Singer Furniture no longer treats, stores, or disposes of hazardous waste at the site. [40 CFR 270.13 (a), (i), (j), (n)] Section XVII 3. Singer must provide a date for the aerial photograph presented in Figure 5. [40 CFR 270.13 (h) (2)] Part B -Facility Description (40 CFR 270 as adopted in 15A NCAC l3A .0113] General Description 4. This section in Part B must include the full facility name and the name of the owner. (40 CFR 270.14 (b) (1)) Topographic Map 5. A legend must be included that clearly shows what the different symbols and lines on the map represent. For instance, the property boundary should be clearly marked and labelled. On Figure 3 the property boundary for the Singer facility is shown with a line of the same width and color as lines used to show other features and property boundaries. [40 CFR 270.14 (b) (19) (vii)) 6. The exact location of SWMUs 3 and 9 are not clearly shown on the map. If possible, the outline of the SWMUs should be shown to illustrate the size' of each SWMU. Additional or inset maps showing a "blow-up" of these two areas would be helpful in depicting the exact location of the SWMUs and their relationship to the sampling locations. (40 CFR 270.14 (d) (I) (i)J r ... " Mr. Qualls Page 4 October 5, 1999 Floodplain Standard 7. Singer must provide background infonnation on the Universal Soil Loss Equation (USLE) and must discuss why it is applicable for this facility. The USLE must be provided and the calculations must be presented in the application. At this time it is unclear what all the factors are in the USLE. In addition, it is unclear where the numbers used in the USLE came from, how they were derived, and why they '1.re applicable. [ 40 CFR270.14(b)(l9)(ii)] · .. PART J -Other Federal Laws [40 Cffi. 270 as adopted in 15A NCAC 13A .0113] 8. Singer must supply the sources of the infOIBlation presented in the application concerning other federal laws. [40 CFR 270.1 and 270.14 (b) (20)] The above information as well as that in the attached checklists is required to be in the application resubmittal. All information contained in Singer's February 3, 1998 submittal that does not apply to the "Parts" listed in the "HSWA-Only Permit Application Outline" section above, must be removed from the revised application. If Singer believes chat additional infonnation is needed to provide a more complete application or has any questions concerning this letter, please feel free to contact Craig Ehde at (919) 733·2178, extension 211 to discuss your concerns. Singer must resubmit eight copies of the HS WA-only permit application, following the above outline, by November 8, 1999. Once the resubmittal has been received by the FMB, it will be reviewed in its entirety. Sincerely, c?t~ i~i;~ement Branch Attaclunent cc: re: Narindar Kumar, US EPA, Region 4 Jesse Wells, Asheville Regional Office ·r.P.eter~l1fill>,o:cw:r;j K~tli·i;~'n'.'Z:'tawson !j~ Robert GlasJ? {y Surabhi K. sh"ah d:\wpfiles\mo;lodi\cme\singpcrt. wpd