NCGNE0648_NOD Response_20210312

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Synergy
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Electronics
ND De
Environ Partment of
cyc I i n Rene vt'7ent ity
MAR122021
320 S Gibson Dr, Madison, NC 27025. 336-548-7014 w►nston. alem
Regional Office
Wednesday, March 10, 2021
Tamera Eplin, PE, CPESC
Regional Engineer
Land Quality Section
Synergy Recycling received Notice of Deficiency (NOD-2021-PC-0024) in the mail on February 16. As a
response to the noted deficiency, we are submitting the attached plan of action.
We process any violations,deficiencies or non-conformances that occur at our facility through an internal
corrective action procedure called Improvement Opportunities Tracking. This process requires the
company to determine a root cause for the item needing correction and also to establish a resolution
(including an action plan)for it.
We intend to have the four items closed out by April 16, 2021. Some of the items we will be able to take
care of more quickly than others. One item in particular, the deficiency related to material pushing out
the walls of the facility, is going to require us to clean out a good bit of our warehouse to be able to repair
the walls and lay angle iron on the floor.That will be the most time consuming.
I will be the lead person on this corrective action, so if you have any follow up items you contact me
directly. My information is below.
Thanks!
Megan Tabb
Director of Sales and Compliance
[e-mail]
336-949-9760

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Synergy Document Name: Improvement Opportunities Tracking
�� Electronics Sheet
Recycling Document Number: F 08 v.2
Improvement Opportunities Tracking Sheet
OFI Number 21-01-SER
Corrective Action or Preventative Action Corrective
Date Reported 02/16/2021
Event of Report The facility(SER) has not adequately maintained conditions
required by the no exposure certification. The following four
noncompliance's were noted:
1. No self-re-certification documents for 2019 and 2020
could be located on-site
2. External siding of the building was in disrepair and
electronic debris were discharging from the building
3. The outside parking area, weight station, and loading
dock were observed to be littered with electronic debris
4. A mulch stockpile and scrap metal were observed in the
outside parking lot area
Names of Persons Involved Megan Tabb, Tyler Anzelone, Jacob Lester, the overall
Compliance and Operations Department and designees
Date of Event 01/14/2021
Nonconformance Type (Q, E, or H&S) Environmental
Person to Evaluate Root Cause Tyler Anzelone
Root Cause Analysis There are two root causes:
1) The new compliance coordinator was not trained
properly on completing the annual recertification form
2) The facility was using an outdated annual self-
recertification form, so some DEQ requirements were
not reviewed.
Proposed Completion Date April 16, 2021
Proposed Resolution The EHS Compliance Coordinator will familiarize themselves
with DEQ requirements for maintaining a no exposure
certification.
1. Self-re-certification documents will be added to a
schedule to ensure completion annually
2. The damaged siding of the building will be repaired and
electronic debris cleaned up.Angle iron will be laid
down inside the building 3'from the wall to prevent
material from being pushed up against the walls.
3. The outside parking area, weight station, and loading
dock will be added to a regular cleaning regiment to
prevent accumulation of electronic debris.
4. Any remaining scrap metal and the mulch pile will be
sent to the appropriate disposal site.
This document is for informational purposes only, and may not be reproduced or used for purposes
other than which it was obtained. Any printed copies are for reference and will not be considered a
controlled document.
Revision date: 12/17/2018 BUSINESS CONFIDENTIAL Page 1 of 2

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Synergy Improvement Opportunities Tracking
Document Name: Sheet
` Electronics
Recycling Document Number: F 08 v.2
Date Hazard Analysis Performed On 02/17/2021
Proposed Resolution
Date Approved/By Whom 02/17/2021 —Megan Tabb /Jacob Lester
Implementer The Compliance Department
Date Implementation Completed
Implementation Details
Resolution Effectiveness
Date:
7 Days:
Date:
30 Days:
Document Revision History
Rev. Description of Change Revised By Approved By Date
1 New Document Megan Benham Benham 4/25/2013 •
Updated numbering, logo, and company Gayle Blizzard Tracey Blaszak 10/10/2013
references. Updated Resolution Effectiveness
to 7 days(Administrative only, no change to
content)
2 Removed "Location"section since there is no Megan Tabb Megan Tabb 4/5/2018
longer an Atlanta location. Updated logo.
Changed Format to Word, no change to content Tyler Anzelone Megan Tabb 12/17/2018
This document is for informational purposes only, and may not be reproduced or used for purposes
other than which it was obtained. Any printed copies are for reference and will not be considered a
controlled document.
Revision date: 12/17/2018 BUSINESS CONFIDENTIAL Page 2 of 2

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