CoastalServices_APHIS_TransportApproval_20140128

North Carolina Department of Environment and Natural Resources
Division of Waste Management
Pat McCrory Dexter R. Matthews John E. Skvarla, III
Governor Director Secretary

1646 Mail Service Center, Raleigh, North Carolina 27699-1646 Phone: [phone] Internet: http://portal.ncdenr.org/web/wm/sw

An Equal Opportunity \ Affirmative Action Employer

January 28, 2014

Mr. Clayton W. Eley IV
Coastal Services
805 Ford Drive
Norfolk, VA 23523

RE: Acknowledgement of transport of APHIS regulated waste through North Carolina.

Dear Mr. Eley,

Coastal Services has requested a written response of the notification that you are seeking approval to
transport APHIS waste through North Carolina per the instructions codified at Title 7 CFR 330.401(e) and
Title 9 Code CFR Part 94.5 ©(4)(iv). You are a cartage firm approved to transport regulated "APHIS" in
approved areas as specified by a Compliance Agreement with Customs Boarder Protection (CBP) and
USDA.

You have reported that the CBP continually inspects, monitors and approves of all your equipment,
locations, training and documentation. Additionally, CBP is notified of all activities prior to any
movement and are provided a monthly description of activity. You are a small transporter and currently
receive APIS waste from vessels in NC approximately once every other week and anticipate the same
volume form SC and GA.

In email correspondence you reported that your Standard Operation Procedure (SOP) for transporting
APHIS to and from Wallace, NC will be as follows:

“Truck and/or truck and trailer departs yard in Wallace, NC to Vessel in NC, SC or GA Driver
arrives to location and ensure APHIS is in 3MIL liners. APHIS is weighed, placed in our .5 Cubic
Meter sealed bins, secured and manifested. The bins are loaded back onto our truck or truck
and trailer and is locked, The load is returned back to our secure yard in Wallace, NC. Once back
to our yard the APHIS stays in the secure bins until it is transported to the processing/transfer
facility at Stericycle Concord Plant, 4403 Republic Court, Concord, NC 28027. As per our
Compliance Agreement with CBP/USDA the APHIS must be delivered from our yard in Wallace,
NC to the processing/Transfer within 72-hours.”

The State of North Carolina does not regulate the transportation of solid waste. While this waste is a
solid waste, the activity as described does not constitute a transfer station activity, unless waste is
accepted from other companies than Coastal. We have determined that at this time no state permits are
required and we acknowledge notification per the federal requirements.

Thank you for your inquiry and please contact us if we can be of further assistance.

Sincerely,

Edward Mussler
Permitting Branch Supervisor
Solid Waste Section

Cc: Michael Scott, DWM
Ellen Lorscheider, DWM
BillPatrakis, DWM
Dennis Shakelford, DWM
Ray Williams, DWM