8004T_EastSpencerTransfer_Comments_OpsPlan_DIN28740_20180206

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Chao, Ming-tai
From:Chao, Ming-tai
Sent:Tuesday, February 06, 2018 10:29 AM
To:'Moore, Daniel'
Cc:Sue, Kim; 'Becker, Larry'; 'Wakefield, Keith (Eric)'; 'Harrison, Susan'; 'Carroll, Shawn'
Subject:Comments (DIN 28740) on LOS Application, East Spencer Transfer Station, 80-04T
Attachments:Pages from signature pages_application.pdf
Hi Dan:

The Solid Waste Section (SWS) completes a review of the Life-of-site permit application (DIN 28731) for East
Spencer Waste Transfer Facility, Permit No. 8004T-TRANSFER-1995 and has several comments on the
application stated below:

DIN 28740
1. (Section 1.0, Facility Overview) Please provide a copy of the permit or approval letter, either issued by
the local government or NC Land Quality Section, allowing the discharge of stormwater from the
facility via the described two detention ponds. The requested copy of the permit or approval letter is not
available in the SWS file.

2. (Section 1.0, Waste Acceptance) Please address the following concerns:
i. The municipal solid waste is defined in NCGS 130A 290(a)(18). Please provide the correct
reference in the application.

ii. The facility collects scrap tire; therefore, please state in the application that the tire collection and
temporary storage area shall be operated in compliance with Rule 15A NCAC 13B. 1107. The
facility to receive the scrap tires from the transfer station must be permitted to treat or dispose of
the tires.

iii. The refenced rule in the beginning of the last paragraph is not applicable for a transfer station,
please remove the rule reference from this paragraph.

3. (Section 4.0 Recyclable Material) Please provide clarifications to the following concerns:
i. Will recyclable/recovered material be removed from the tipping area to a designated waste
container or containers inside the transfer station at the end of each normal operating day?

ii. Please provide the detailed procedures and approaches to prevent the temporarily stored
recyclable or recovered material from being contaminated by leachate or other MSW waste
stream inside the tipping area. Is there an impermeable physical barrier to separate the storage
bay from the waste operation bay in the tipping area? Is there a water-resistant container (s) to
temporarily store recyclable/recovered material in the tipping area?

iii. Please describe the implemented approaches to assure the recycling activities will not interfere
routine waste operations in the tipping area.
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iv. The tipping area must be cleaned prior to temporarily storing recyclable/recovered
material. Please add this requirement to the section.

4. (Section 6.0) The SWS has a standard form for reporting fire occurrence. If the facility intends to use
the form, please attach the form to the application. The form can be downloaded from the following
weblink:
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Forms/FireOccurrenceReport.pdf

5. Please add the tire collection area or other recyclable staging area (s) to the Site Plan drawing.

6. Please provide the procedures for the site closure which should include the time-frame for the
notification for ceasing waste operation, closure requirements, closure inspection, financial assurance
(FA) for closure according to NCGS 130A-294 (b2). The cost estimates for hiring the third party to
close the site should be attached to the application for a view and approval. The SWS accepts the costs
which assumes 5-day accumulated wastes subjected to removal. According to the latest Facility
Compliance Inspection Report, the facility accepts an average of 80 tons of wastes at each working day.

7. The web site (https://www.wmsolutions.com/locations/details/id/677) of the transfer station states yard
waste is an acceptable waste stream. If it is a fact, please add the operation of yard waste to the
application according to Rule 15A NCAC 13B .1402(g)(3).

8. Please complete and sign the attached application form.

Please contact myself if you have any questions regarding these comments and have a wonderful day.

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

Applicant Signature Page

Name of Facility

I certify that I have read and understand this application and that the information provided is
true, accurate, and complete to the best of my knowledge.

I understand that North Carolina General Statute 130A-22 provides for administrative penalties
of up to fifteen thousand dollars ($15,000.00) per day per each violation of the Solid Waste
Management Rules. I further understand that the Solid Waste Management Rules may be
revised or amended in the future and that the facility siting and operations of this solid waste
management facility will be required to comply with all such revisions or amendments.

Signature Print Name Date
Title
Business or Organization Name

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E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.

From: Chao, Ming-tai
Sent: Tuesday, January 30, 2018 10:32 AM
To: Moore, Daniel <[e-mail]>
Cc: Sue, Kim <[e-mail]>; Becker, Larry <[e-mail]>; Wakefield, Keith (Eric) <[e-mail]>;
Harrison, Susan <[e-mail]>; Carroll, Shawn <[e-mail]>
Subject: RE: East Spencer Transfer Station - Permit Renewal, 80-04T

Hi Dan:

Good morning. I received the life-of-site application for the above-referenced facility, the document was
uploaded to Laserfiche with a DIN 28731. I will conduct the permit review shortly. After briefly reviewing the
cover letter, I have to remind you that your request for 100-yr life-of-site (LOS) permit may be out of the
question according to the attached NCGS 130A-294(a2) in the Session Law 2017-211/SB 16 which read as:

“Permits for sanitary landfills and transfer station shall be issued for the life-of-site of the facility unless
revoked. For purposes of this section, “life-of-site” means the period from the initial receipt of solid waste at
the facility until the facility reaches the final permitted elevations, which period shall not exceed 60 years…”

Waste Management Carolinas, Inc. (WM) begins operating East Spencer Waste Transfer Facility in
1995. Should the new permit be issued for the facility, the period or duration of the LOS permit would end in
2055. I will/can not predict the changes of the law or the rule in the near future, but pursuant to the Session
Law 2017-211, the new LOS permit, if issued, shall expire in 2055.

Best regards,

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.

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From: Moore, Daniel [mailto:[e-mail]]
Sent: Tuesday, January 30, 2018 9:43 AM
To: Chao, Ming-tai <[e-mail]>
Cc: Sue, Kim <[e-mail]>; Becker, Larry <[e-mail]>; Wakefield, Keith (Eric) <[e-mail]>;
Harrison, Susan <[e-mail]>; Carroll, Shawn <[e-mail]>
Subject: [External] RE: East Spencer Transfer Station - Permit Renewal, 80-04T

CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
[e-mail].

Ming,

Please see the attached permit renewal request cover letter and revised Operations Plan for East Spencer
Transfer Station, and do not hesitate to contact me if you have any questions or concerns related to this
submittal. As always, we appreciate your assistance and regulatory guidance.

Dan Moore
Environmental Protection Manager
[e-mail]

Waste Management – North Carolina/South Carolina
3303 N Glenn Ave
Winston-Salem, NC 27105
Cell [phone]

From: Chao, Ming-tai [mailto:[e-mail]]
Sent: Monday, January 29, 2018 2:28 PM
To: Moore, Daniel <[e-mail]>
Cc: Sue, Kim <[e-mail]>; Moore, Daniel <[e-mail]>
Subject: [EXTERNAL] East Spencer Transfer Station - Permit Renewal, 80-04T

Hi Dan:

When you have the permit application ready (one electronic copy with site layout drawings), please send it to
me for a review.

Thanks and have a wonderful day.

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
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http://portal.ncdenr.org/web/wm/sw

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.

From: Mussler, Ed
Sent: Monday, January 29, 2018 2:23 PM
To: Moore, Daniel <[e-mail]>
Cc: Sue, Kim <[e-mail]>; Chao, Ming-tai <[e-mail]>
Subject: RE: [External] East Spencer Transfer Station - Permit Renewal

You can send it to Ming, its in his territory

From: Moore, Daniel [mailto:[e-mail]]
Sent: Monday, January 29, 2018 2:21 PM
To: Mussler, Ed <[e-mail]>
Cc: Sue, Kim <[e-mail]>
Subject: [External] East Spencer Transfer Station - Permit Renewal

CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
[e-mail].

Ed, I have a permit renewal request ready to go for the referenced site. Should I submit this to your
attention? Ming’s? Other?

Many thanks,

Dan Moore
Environmental Protection Manager
[e-mail]

Waste Management – North Carolina/South Carolina
3303 N Glenn Ave
Winston-Salem, NC 27105
Cell [phone]

Recycling is a good thing. Please recycle any printed emails.