2908_Todco_Comments_PermitApp_DIN 28791_20180319

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Chao, Ming-tai
From:Chao, Ming-tai
Sent:Monday, March 19, 2018 10:58 AM
To:'Warfford, Todd'
Cc:Heim, Susan A; 'Jeff Gerlock'
Subject:Comments on Permit Renewal Application - Todco, Inc. Wood Recycling Facility, Permit
No. 2908T-Transfer-2013
Dear Mr. Warfford:

The Solid Waste Section completes a review of the permit renewal application and has some comments stated
below:

DIN 28791
Application for Permit Review and Renewal
1. (Section 2.0 – Site Study) Please address the following concerns throughout the section:
i. Change of the facility property ownership results the change of Parcel Identification Numbers in
the section according to attached property deed documents. Please revise the section
accordingly.

ii. The acreage of each parcel in this section must be consistent with that in the property deed
document.

iii. The total site acreage is approximately 52.07 acres according to the deeds. Please verify.

iv. Because the land ownership is changed, please complete the attached application forms by the
legal entities of the land owner – Avery Dawn, LLC and the operator -Todco, Inc., respectively.

v. Two on-site water wells are capped according to the Section 2.1,
a. why are the wells not subject to plug and abandon according NC 2L?
b. where is the water source for sanitary, dust mitigation (referring to Section 4.5), and
firefighting?

vi Since two petroleum above-storage tanks (ASTs) and a motor fleet maintenance shop are inside
the facility, should the facility have a Spill Prevention, Control, and Countermeasure (SPCC)
plan prepared according to 40 CFR Part 112? Please clarify.

2. (Section 3.2.1) This section describes that small amounts of wood wastes received are treated lumber,
painted lumber or chipboard. Will the described wastes be considered as unacceptable or prohibited
wastes at this facility as stated in Section 4.3? Please clarify.

3. (Section 3.2.1) Please delete the statement – The capacity of the facility is approximately 200 tons per
day (all waste types). The statement is inconsistent with the estimated waste amount in the same
paragraph of Section 3.2.1 and in the Section 1.14 - Financial Assurance of the Operations Manual.

4. (Section 3.2.1) This section states that “Todco receives wastes from site within a 50-miles radius of the
subject facility.” Please clear define the service areas or counties within a 50-miles radius of the facility.
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5. (Section 3.2.2) Please provide additional info to the section:
i. What is maximum storage/ capacity of each processed material and product (including the
products purchased from other facilities) at the facility: boiler fuel landscaping mulch, and
recovered C&D material.

ii. What is the specific/threshold pile temperature stated in Section 3.2.2?

iii. Does the facility employee conducts routine temperature monitoring? If so, how often? Is there
any monitoring log/record available in the facility operating record?

iv. Should the facility operations (recycling, wood waste grinding/stockpile/storage, and vehicle
fleet maintenance and petroleum ASTs) follow the applicable North Carolina Fire Codes –
Section 1908 & Section 3406?

v. What is minimum aisle distance between waste piles or windrows?

6. (Section 3.2.3) Should the water truck mentioned in Section 4.5 be listed in the equipment list.

7. (Section 3.3) Please provide additional info of the roadway crossing the unnamed creek as shown on
Figure 3.
i. The dimensions of the roadway and material.

ii. If culvert pipe is using for crossing, please describe the pipe material, size, and loading capacity.

iii. What measure(s) is implemented to prevent wastes/finished products from falling out of the
loading vehicles into the creek?

8. (Section 4.0) According to Rules 15A NCAC 13B .0302 and .0402 add the following requirements
pertaining leachate management plan to the Section. Leachate as defined in NCGS 130A-290(a)(16a) is
a liquid passing through or emerged from solid waste and contains soluble, suspended, or miscible
materials removed from such waste.
i. Describe how to collect, temporarily store, and treat/dispose of leachate generated from at the
waste (both C&D and wood wastes) sorting & processing units. The leachate management
devices/measures/structures/storages must be added to the Site Plan drawing.

ii. If the collected leachate will be directly drained to a sewer system, please provide a copy of the
permit or approval letter. The sewer line manhole to receive on-site leachate must be added to
the Site Plan drawing.

iii. If the collected leachate will be temporarily stored in an on-site storage tank and pumped and
hauled by a hauler to a waste water treatment plant (WWTP). Please provide the following info:
a. The WWTP name, contact info, and a copy of approval letter of accepting on-site leachate.
b. The description of the leachate lines and the storage tank – locations (must show on the
drawing) dimensions, material and capacity and of the inspection and maintenance
requirements.

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9. (Section 4.2) Please add the following conditions to determines if the waste streams are acceptable at the
facility:
i. The facility is permitted to receive (waste types) generated within areas consistent with the
service area of the receiving permitted landfill.

ii. Waste must only be transported to facilities that are properly permitted to receive the waste.

iii. Pursuant to N.C.G.S. 130A-309.09A(g), the facility operator must not knowingly dispose of, or
accept for transfer for subsequent disposal, solid waste that is generated within the boundaries of
a unit of local government that by ordinance:
a. Prohibits generators or collectors of solid waste from disposing of that type or form of solid
waste.
b. Requires generators or collectors of solid waste to recycle that type or form of solid waste.

10. (Section 4.5) Please add the fire reporting & fire-fighting requirements to the section including, but not
limited to:
i. Please provide the protocols to manage/handle “hot loads” under the following scenarios –
approaching the scale house or unloading to the processing area.

ii. Open burning of solid waste is prohibited at the facility.

iii. Fires must be reported to the Regional Environmental Specialist according to Section 1.8 of the
Operations Manual. The fire occurrence report can be found at the following web link, if the
facility intends to use:
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Forms/FireOccurrenceReport.pdf.

iv. Fire lanes for piles of unprocessed waste and stockpiles of finished products or recyclables or
recovered materials must be maintained and passable at all times. Dimensions of the fire lanes
must be coordinated with the Fire Marshall having jurisdiction over the site.

11. (Section 4.5) Please add the operating requirements to handle wind-blown wastes:
i. At the conclusion of each day of operation, all windblown material resulting from the operation
shall be collected and returned to the designated area by the owner or operator according to
Rules 15A NCAC 13B .0302 & .0402.

ii. The waste operations should be temporarily ceased in the high wind days or raining days under
discretion of the operator in compliance with permit conditions and the applicable NC Solid
Waste Management Rules 15a NCAC 13B.

12. (Sections 4.7 & 5.1) Please provide the copy of approval letter or permit of the Erosion and Sediment
Control Plan or the SWPPP plan issued by the NC Land Quality Section which incorporates the new
expanded area – the 13.73-acre parcel into the existing permitted area. The approved best management
practices (BMPs) must add to the Site Plan Drawing (s).

13. The facility shall comply the requirements for anti-speculation storage in NCGS 130A-
309.05(c). Please add the requirements to Operations Plan:
i. Seventy-five percent (75%), by weight or volume, of the recovered material stored at a facility at
the beginning of a calendar year commencing January 1, shall be removed from the facility through
sale, use, or reuse by December 31 of the same year.
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ii. The recovered material or the products or by-products of operations that process recovered
material shall not be discharged, deposited, injected, dumped, spilled, leaked, or placed into or
upon any land or water so that the products or by-products or any constituent thereof may enter
other lands or be emitted into the air or discharged into any waters including groundwaters, or
otherwise enter the environment or pose a threat to public health and safety. Facilities that process
recovered material shall be operated in a manner to ensure compliance with this subdivision.

iii. The recovered material shall not be a hazardous waste or have been recovered from a hazardous
waste.

iv. The recovered material shall not contain significant concentrations of foreign constituents that
render it unserviceable or inadequate for sale, or its intended use or reuse.

Operations Manual
14. (Section 1.6) Please assign the personnel to conduct inspection and maintenance of BMPs pertaining on-
site leachate management system.
15. (Section 1.11) Please show the locations of water sources or fire hydrants on the Site Plant drawing.

Figures
16. (Figure 2, Tax Map) The Parcel IDs shown on the map are different from those in property
deeds. Please update the info on the map.

17. (Figure 3, Site Plan) The drawing shall add the following info:
i. The proposed storage/processing area.

ii. The buffer requirements (referring to Section 3.4) including the stream buffer for the proposed
storage/processing area.

Please contact myself or Susan Heim if you have any questions or further clarifications on the above-mentioned
comments. 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

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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: Thursday, February 08, 2018 3:12 PM
To: Jeff Gerlock <[e-mail]>
Cc: Heim, Susan A <[e-mail]>; Warfford, Todd <[e-mail]>
Subject: RE: [External] Re: Permit Renewal Request / Application - Todco, Inc. Wood Recycling Facility, Permit No. 2908T-
Transfer-2013

Hi Mr. Gerlock:

Yesterday the Solid Waste Section received the permit renewal applications for Todco, Inc. Transfer Station
and Solid Waste Treatment and Processing Facility, permit No. 2908T-Transfer-2013. I also found the facility
has another unit – Todco, Inc. Wood Recycling, Permit No. 2908-TP. Is the operations plan & pertaining info
of Wood Recycling unit incorporated into the new permit application? If not, please submit the operations plan
and related drawings for this Wood Recycling Unit, 2908-TP. So I can issue a permit to cover both units of this
facility. Thanks.

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.

From: Jeff Gerlock [mailto:[e-mail]]
Sent: Thursday, February 08, 2018 2:14 PM
To: Chao, Ming-tai <[e-mail]>
Cc: Heim, Susan A <[e-mail]>; Warfford, Todd <[e-mail]>
Subject: [External] Re: Permit Renewal Request / Application - Todco, Inc. Wood Recycling Facility, Permit No. 2908T-
Transfer-2013

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CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
Report Spam.

good afternoon Mr. Chao and Ms. Heim. did you receive our email yesterday with the permit application / request for
renewal of Todco's permit?

Virus-free. www.avg.com

On Wed, Feb 7, 2018 at 10:29 AM, Jeff Gerlock <[e-mail]> wrote:
Good morning, attached is a request for renewal of the permit for the subject site. please review and contact us if you
have any questions or need additional information. we appreciate your review of this document!
we will send the revised Operations Manual in a separate email (due to size and Todco is still obtaining a new Letter of
Credit from the bank).

Note - please respond to let us know you received the email and its attachments.

--
Jeff Gerlock, P.G.
Blue Ridge Geological Services
7356 Belmont Drive
Trinity, North Carolina 27370
336-382-6849 mobile
www.blueridgegeo.com

--
Jeff Gerlock, P.G.
Blue Ridge Geological Services
7356 Belmont Drive
Trinity, North Carolina 27370
336-382-6849 mobile
www.blueridgegeo.com