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HomeMy WebLinkAbout8004T_EastSpenecrTransfer_Final_LOSPermitApp_OpsPlan_DIN28794_20180320 0 FACILITY OPERATIONS PLAN Waste Management of Carolinas, Inc. East Spencer Solid Waste Transfer Station NCDEQ Permit No. 8004T-TRANSFER-1995 Original Document: March 1995 Previous Revisions: May 2002, February 2007, and February 2013 Current Document: March 20, 2018 Prepared for: Waste Management of Carolinas, Inc. East Spencer Transfer Station 1000 North Long Street Town of East Spencer, Rowan County, North Carolina, 28054 Attn: Larry Becker, District Operations Manager Phone: 980-722-5620 Prepared by: Waste Management Environmental Protection Attn: Daniel R. Moore, PG Phone: 336-253-0091 1 TABLE OF CONTENTS 1.0 FACILITY LOCATION AND DESCRIPTION 2 Facility Overview 2 Facility Contacts 2 Service Area & Disposal Locations 3 Waste Acceptance 3 2.0 HOURS OF OPERATION 4 3.0 EQUIPMENT 4 4.0 OPERATIONAL PROCEDURES 5 Housekeeping & Vector Control 5 Recyclable Materials 6 Record Keeping & Reporting 7 5.0 RANDOM INSPECTIONS, AND EMPLOYEE TRAINING AND CERTIFICATION 7 Random Inspections 7 Employee Training 8 Employee Certification 8 6.0 EMERGENCY RESPONSE PROCEDURE AND EQUIPMENT 8 7.0 FINANCIAL ASSURANCE/CLOSURE COST ESTIMATE 9 LIST OF ATTACHMENTS Attachment 1 - Property Deed & Associated Parcel Identification Data Attachment 2 - Facility Location Map & Site Plan Attachment 3 - Random Load Inspection Form Attachment 4 - Solid Waste Section Fire Occurrence Notification Form Attachment 5 - Financial Assurance/Closure Cost Estimate 2 1.0 FACILITY DESCRIPTION AND LOCATION Facility Overview: East Spencer Transfer Station operates under NC Department of Environmental Quality (DEQ), Division of Waste Management, Permit to Operate No. 8004T- TRANSFER-1995, issued to Waste Management of Carolinas, Inc. The current Permit shall expire September 2, 2018; and in accordance with Part I (12) of the permit, no later than February 2, 2018, the owner or operator must submit a request for permit renewal and must update pertinent facility plans including, but not limited to, the facility operation, and waste screening plans. Waste Management of Carolinas, Inc. is therefore submitting this document to meet the requirements of this general permit condition. The Transfer Station is located at 1000 North Long Street at the intersection of North Long Street (S. R. 2100) and Robinson Road (S.R. 2116) within the town of East Spencer, NC in Rowan County. The property deed and associated parcel identifying information are provided as Attachment 1 to this Plan. A facility location map is provided on Attachment 2. The facility includes approximately 3.5 acres of land within a 7-acre property which is encompassed by a perimeter fence. Existing buildings at the site include the transfer station, and an office building/scale house complex. A site plan with the facility layout is provided on Attachment 2. Water and sewer service is provided by Salisbury-Rowan Utilities. The waste water connection is directly into the sewer on-site. All process water, leachate or contaminated stormwater is collected in floor drains at the front interior of the transfer station tipping floor and at interior front and rear floor drains in the transfer trailer loading bay. The process water flows through an oil water separator prior to discharge to the sewer system. No storage other than the collection system and the separator is present at the facility. Stormwater is routed around the facility and away from transfer station bay doors to prevent contamination. The water flows via the conveyance system and on-site ditches to two separate detention ponds prior to discharge. Facility Contacts: The following individuals are the primary and secondary facility contacts: Primary Contact: Larry Becker District Operations Manager Waste Management of Carolinas, Inc. 204 Balfour Quarry Road Granite Quarry, North Carolina 28072 Phone: 980-722-5620 Email: lbecker@wm.com 3 Secondary Contact: Dan Moore Environmental Protection Manager Waste Management of Carolinas, Inc. 3303 North Glenn Avenue Winston-Salem, NC 27105 Phone: 336-253-0091 Email: dmoore36@wm.com Service Area & Disposal Locations: This facility is permitted to receive municipal solid waste generated within Rowan, Iredell, Mecklenburg, Davie, Davidson, Randolph, Montgomery, Stanley, and Cabarrus Counties. The facility will ensure that the origin of the waste deposited at the transfer station is consistent with the permitted service area of the landfill facility ultimately receiving the waste for disposal. Municipal waste is consolidated at the transfer station for transport to and disposal at state- permitted municipal solid waste landfills. Waste must be transported for disposal to Great Oak Landfill located in Randolph County (Permit #7607-MSWLF-2015), BFI Charlotte Motor Speedway Landfill V located in Cabarrus County (Permit No. 1304-MSWLF-1992), Uwharrie Environmental Landfill located in Montgomery County (Permit No. 6204-MSWLF-1995), and/or Rowan County Landfill (Permit No. 8003-MSWLF-1988). Proposed changes to the service area and/or the disposal facility must be approved by the Division of Waste Management. Signs at the entrance of the site note “Municipal Solid Waste Only. No Hazardous Wastes Accepted. Non-hazardous special wastes (drums, sludges, liquids, etc.) will be refused or returned at the haulers’ expense.” Waste Management approved special wastes suitable for transfer station handing and transport may be accepted upon prior approval of the WM District Operations Manager. The sign also states the hours of operation, permit number, and emergency contact number. The transfer station accepts municipal solid waste from residential, commercial, medical, and industrial sources. No sludges, or hazardous waste are accepted for disposal. Waste Acceptance: The facility will only accept municipal solid waste (MSW) (i.e., residential, commercial, and industrial waste) as defined in NCGS 130A-290 (a)(18) . The following wastes, at a minimum, will not be accepted at the facility; hazardous waste, liquid wastes, sharps not properly packaged, regulated-asbestos containing material as defined in 40 CFR 61, and PCB waste as defined in 40 CFR 761. Loads that fail to meet the MSW requirements will be rejected, documented and reported in accordance with Division of Waste Management procedures. The 4 operational procedures for receipt, storage and transport of recyclable materials are outlined in Section 4 (Operational Conditions) of this Plan. Used tires that occasionally get collected in waste will be stored in an enclosed container for periodic pick up and processing by a tire recycler. The location of the tire storage area is shown on the site plan, Attachment 2. 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 and/or dispose of the tires. East Spencer Transfer has posted signs at the facility entrance indicating operational procedures, hours of operation and the permit number. Posted signs clearly state that no hazardous or liquid waste can be received. Traffic signs and markers are provided as necessary to promote an orderly traffic pattern to and from the discharge area and to maintain efficient operating conditions. 2.0 HOURS OF OPERATION The transfer station may operate 10-12 hours per day, 5.5 days a week. The operating hours may fluctuate based on the needs of the facility, however it is anticipated that the transfer station will be operated an average of 50-60 hours per week. The hours stated are for the receipt of waste; other activities pertaining to the transfer station may be conducted beyond these hours. 3.0 EQUIPMENT Collection vehicles, transfer vehicles, bucket loaders, and/or other equipment will be utilized at the facility for loading, hauling, and managing solid waste. Collection vehicles including front load, side load, rear load, and roll-off trucks, will transport waste to the transfer facility. Following offload, refuse will be consolidated on the tipping floor where it will be loaded into open top transfer trailers. The loading of waste and transfer trucking operation is currently performed by a third-party contractor to Waste Management. A rubber-tired bucket loader will be used to load the trucks and tamp down waste. Transfer vehicles will typically consist of a tractor and a 53-foot open top aluminum body trailer. Transfer trailers will be tarped for over-the-road transport. No fewer than two transfer trailers will be utilized at the transfer station. If equipment failure causes the facility to be unable to transport the entire day's receipts of MSW to the approved disposal location, waste will be tarped and stored in the transfer trailers. Waste may be stored on-site, in leak proof transfer trailers, with 5 watertight covers, a maximum of 24 hours except that a minimal amount of waste may be stored for a maximum of 72 hours when the facility is closed during a weekend or holiday. In the event of inclement winter weather, the facility will utilize the front-end loader to keep the entrance and turn around area clear of ice or snow. If conditions warrant, the facility will be closed to incoming traffic. An onsite back-up generator will be available in the event of loss of power; however, natural light is sufficient for normal operations, so if there is a loss of power during the day, work does not stop. 4.0 OPERATIONAL PROCEDURES An operator will always be present at the transfer station during operational hours. The operator is responsible for directing traffic into and out of the transfer station and is also responsible for the movement of waste from the tipping floor into the transfer trailers. Housekeeping & Vector Control: In order to avoid nuisance conditions the tipping floor and transfer trailer loading area will be maintained in a clean, sanitary condition at all times. The tipping floor and loading bay will be cleaned at least daily in accordance with this Plan. Wastes will only be deposited on the facility’s tipping floor, or deposited directly into a waste transfer container; and no waste will be stored on the tipping floor after operating hours. Waste may be stored on-site overnight as outlined above in Section 3.0 – Equipment; however, in no case will the storage of the waste cause a nuisance, such as odor or attraction of vectors. Effective vector control measures will be applied at all times to control for potential vectors including flies, rodents, insects, and other vermin. At the end of each working day the facility tipping floor, area behind associated push walls, and loading bay shall be cleared of extraneous waste. The tipping floor and loading bay shall be broom swept, raked, and washed down as necessary each day to remove accumulated waste and/or leachate. The facility’s tipping floor is designed so that liquids (e.g., wash water and leachate) drain to a series of wastewater drainage grates at the front of the tipping floor. Additional drainage ports are located at the base of the push wall above the loading bay. These ports must be cleaned at the end of each working day, or as necessary, in order to maintain positive drainage into the loading bay. Liquids entering the loading bay flow to either the central exterior wall drainage pit, or are captured by the floor drains located at both ends of the loading bay. All wastewater drainage is 6 piped to an exterior oil-water-separator located adjacent to the long exterior wall of the loading bay, prior to piped discharge to an off-site pump station maintained by Salisbury-Rowan Utilities. These loading bay drains must be cleaned at the end of each working day, or as necessary, in order to maintain positive drainage into the oil-water-separator. The oil-water-separator consists of three chambers in series which are checked for accumulation of separated liquids and sediment on a weekly basis. Pumping of the unit is currently performed on a semiannual basis, but is subject to change based upon actual conditions observed during weekly inspections. Control measures will be utilized to minimize and eliminate visible dust emissions and blowing litter. Windblown materials will be collected by the end of the day and no windblown material will be allowed to leave the facility boundary. Recyclable Materials: When necessary due to weekends and/or holidays, storage of recoverable/recyclable materials may be up to three days. Recyclables will be stored in a segregated area of the transfer station on a clean tipping floor where they are not commingled in any way with the municipal solid waste (MSW) stream. The materials will be removed from the active tipping area to a designated waste container or containers inside the transfer station at the end of each normal operating day so as not to interfere with facility housekeeping. Water- resistant containers will be used when necessary to facilitate the daily wash down and cleaning of the working floor. Recovered, reclaimed, or recycled material including but not limited to cardboard, metal, plastics, etc., may be separated and removed from the waste stream. During operational periods where recyclable material is removed from the waste stream, a transfer trailer or other appropriate containers will be staged in one bay of the transfer station to only receive the recovered material. One bay of the station will be isolated and will only receive the desired material. This single stream or potentially commingled recyclable material will be loaded into the trailer using a process specific loader, primarily of a skid steer or bobcat style machine. The material loaded into the recyclable trailer will not be contaminated by putrescible waste and will either be stored in the transfer station or inside an enclosed covered trailer. Recyclable material will not be stored onsite for a time greater than the permit allows. Cardboard material may be compacted or bailed to decrease volume prior to shipping to an end user. If a bailer or compactor is located outside of the transfer station bay, the site plan and/or diagram will be amended to reflect the location. 7 Record Keeping & Reporting: Reconciliations reports are created daily, and summarized into monthly reports, to show the disposal of materials received at the transfer facility site. These reports are maintained in the Fastlane® records system at the corporate level and a hard copy is maintained at the site. A copy of the facility permit, operations plan, site drawings, and random waste load inspections (see Section 5.0 below) are available at the transfer facility site. On or before August 1 of each year, the facility will submit an annual facility report to the Solid Waste Section, on forms prescribed by the Section. The reporting period will be for the previous year beginning July 1 and ending June 30; and the report will list the amount of waste received in tons: i) on a monthly basis, ii) by county or city of origin, iii) by specific waste type, iv) by receiving disposal facility, and v) by diversion to alternative management facilities. The completed report will be forwarded to the Regional Environmental Specialist for the facility by the date due on the prescribed annual facility report form; and a copy of the completed report will be forwarded to each county manager for each county from which waste was received at the facility. Documentation that a copy of the report has been forwarded to the county managers must be sent to the Regional Environmental Specialist by the date due on the prescribed annual facility report form. 5.0 RANDOM INSPECTIONS, EMPLOYEE TRAINING, AND OPERATOR CERTIFICATION Random Inspections: Random inspections will be conducted and documented on a random basis utilizing the form provided as Attachment 3. Random inspections will be performed on commercial front-end loaders, residential rear-end loaders and roll-offs. There will be no less than four (4) random inspections conducted monthly. The random dates shall be no closer than one (1) day apart and no further than ten (10) days apart. The drivers/vehicles will be randomly inspected and not inspected consecutively. Each load to be inspected will be spread on the floor of a cleared tipping bay so that all items on the Random Load Inspection Form (Attachment 3) can be identified and documented, if present. All additional information required for the inspection form will be gathered and documented at this time. In the event that unacceptable wastes are identified, the “Rejected Waste Record” portion of the inspection form will be completed. All completed inspection forms shall be retained by the facility and stored in the facility office or the scale house. Should a hauler consistently deliver unacceptable material, he will be denied further access to the transfer station, and the regional office of NCDEQ will be notified so that appropriate investigations can be conducted, if necessary. 8 If hazardous or prohibited waste is detected after being dumped at the tipping floor, it shall be segregated (as appropriate) to assure that it does not mix with the surrounding waste material. If for any reason the rejected wastes cannot be segregated (e.g., spilled liquids) the Transfer Station will be closed until the unacceptable material is removed. If the material can be segregated and protected, the station will continue to operate. If the segregated material cannot be reloaded on the delivering vehicle, a qualified contractor (see Emergency Contacts – Section 6.0) shall be called to perform removal and disposal. Employee Training: Appropriate transfer station and operation personnel will be trained at least annually in a control program for detecting and preventing unauthorized waste from being accepted at the facility. The training will include procedures for performing and recording the random inspections; and the recognition of hazardous, liquid, and other excluded wastes. Records documenting the training will be kept at the facility. Operator Certification: Appropriate operators will attend NCDEQ recognized certification classes and become certified in facility operations in accordance with G.S. 130A-309.25. A certified operator must always be present at the transfer station during operating hours. The operator will be responsible for directing all traffic into and out of the transfer station and will also be responsible for the movement of waste from the tipping floor into the trailers. 6.0 EMERGENCY RESPONSE PROCEDURE AND EQUIPMENT The East Spencer Transfer Station operation includes routine emergency equipment such as phones, spill kits, first aid kits and fire extinguishers. The following emergency contact list will be maintained in the facility scale house. The emergency contacts are listed below: EMERGENCY CONTACTS Contact Telephone Number National Environmental Response Center 800.424.8802 NC DEQ - Environmental Emergency 919.541.2258 NC DEQ - Mooresville Regional Office 704.663.1699 NC DEQ - Regional Solid Waste Specialist – Kim Sue 704.235.2163 NC DEQ - Division of Waste Management - Raleigh 919.707.8200 Local Fire Department 911 Local Police Department 911 9 WM District Operations Manager – Larry Becker 704.279.4890 WM Environmental Protection Manager - Dan Moore 336.253.0091 (mobile) Salisbury-Rowan Utilities 704.638.5300 A&D Environmental - Emergency Spill/Cleanup Service Provider 336.434.7750 The Town of East Spencer will provide first response for any fire situations that occur at the transfer station facility. As a secondary measure, and based on the severity of the incident, fire extinguishers are located in the office, in the tipping floor area, in the storage area and in the transfer trailer loading area. Operators will be trained in the use of fire extinguishers. A 100‐foot long, single jacket fire hose is located just outside the tipping floor; and standard garden type hose connections are in the tipping floor area, in the storage area, and in the transfer trailer loading area. In the event that “hot loads” (burning or smoldering waste loads) are discovered while on site, either in the area of the scale house, or transfer station, they should be directed to the paved apron area in front of the transfer station tipping floor. Under no circumstances should they be allowed to enter the enclosed tipping floor or loading bay. In general, the local fire department will be notified immediately upon discovery, as it is often difficult if not imposable to determine the extent and severity of combustion taking place in waste containers and/or collection vehicles. In the event that a hot load is discharged onto the tipping floor, prior to recognition, the local fire department will be notified prior to attempting to extinguish the burning material with on-site fire extinguishers and/or the fire hose used in daily wash-down operations. In accordance with the facility permit, fires must be reported to the NCDEQ-Division of Waste Management, Regional Waste Management Specialist within twenty-four (24) hours of the occurrence with a written notification to be submitted within fifteen (15) calendar days of the occurrence. The Solid Waste Section Fire Occurrence Notification Form provided as Attachment 4 shall be used to make the required notification. 7.0 FINANCIAL ASSURANCE/CLOSURE COST ESTIMATE The Solid Waste Section will be notified within 30 days of a Waste Management of Carolinas, Inc. decision to permanently close the East Spencer facility; if this should occur prior to the permit expiration date. Within 30 days of this notification the facility will be cleaned and Salisbury Rowan Utilities will be notified so that appropriate actions can be taken to terminate wastewater collection services. 10 As requested by the Solid Waste Section, a cost estimate to hire a third party to remove, cleanup, haul and dispose of five days accumulated volume of waste is included as Attachment 5. The estimate is based upon the facilities current, average daily intake of 80 tons. (End) Rev. 00 - December 12, 2016 - DRM Source of Waste (As Stated by Driver): Waste Generator: Contact: Address:Telephone: Is the material: Unauthorized Solid Waste (Yes or No): ______________ Regulated Hazardous Waste (Yes or No): ____________ NOTE: If the rejected waste is identified as Regulated Hazardous Waste , or if there is uncertainty, NCDEQ must be notified within 24 hours of the discovery. Rejected Waste Record Driver's Name: Vehicle Type (Roll Off, Transfer Trailer, Residential, etc.): Date:Time: Hauling Company: Licensee Plate No. (if accessible): WASTE MANAGEMENT OF CAROLINAS, INC. - EAST SPENCER TRANSFER STATION Random Waste Load Inspection Record Was Unauthorized Waste Returned to Hauler for Proper Disposal (Yes or No)? If NCDEQ notification was made, provide the following: Contact:_________________________________ Date and Time of Contact:____________________________________ Is Unauthorized Waste Present in Load (Y or N)? (If Yes to any, complete Rejected Waste Record Below): Liquids_____ Yard Waste_____ Medical Waste_____ White Goods_____ Tires_____ Lead-Acid Batteries_____ Wooden Pallets_____ TVs_____ Computers/Monitors_____ Other_______________________________________ Document actions taken and location of the rejected waste: Detailed Description of Unauthorized Waste: Additional Observations: Signature of Driver: Signature of Inspector: Title: Date and Time Contacted (if applicable): SOLID WASTE MANAGEMENT FACILITY FIRE OCCURRENCE NOTIFICATION NCDEQ Division of Waste Management Solid Waste Section Notify the Section verbally within 24 hours and submit written notification within 15 days of the occurrence. (If additional space is needed, use back of this form.) NAME OF FACILITY:PERMIT # DATE AND TIME OF FIRE:@ HOW WAS THE FIRE REPORTED AND BY WHOM: LIST ACTIONS TAKEN: WHAT WAS THE CAUSE OF THE FIRE: DESCRIBE AREA, TYPE, AND AMOUNT OF WASTE INVOLVED: WHAT COULD HAVE BEEN DONE TO PREVENT THIS FIRE: DESCRIBE PLAN OF ACTIONS TO PREVENT FUTURE INCIDENTS: NAME:TITLE:DATE: *********************************************************************************************************** THIS SECTION TO BE COMPLETED BY SOLID WASTE SECTION REGIONAL STAFF DATE RECEIVED _________________________________ List any factors not listed that might have contributed to the fire or that might prevent occurrence of future fires: ___________________________________________________________________________________________________________ FOLLOW-UP REQUIRED: NO PHONE CALL SUBMITTAL MEETING RETURN VISIT BY:____________________ (DATE) ACTIONS TAKEN OR REQUIRED: Revised 6/15/2016 COST ESTIMATE WORKSHEET FOR CLOSURE OF WM OF CAROLINAS, INC. – EAST SPENCER TRANSFER STATION 1. General Conditions/ Mobilization/ Demobilization - Backhoe and bulldozer $5,000.00 2. Transfer station cleaning (pressure wash) - Labor; 40 hours @ 15.00/hour $600.00 - Cleaning Materials $300.00 3. Abandon 1 wastewater collection sump - Labor; 40 hours @ $15.00/ hour $600.00 - Materials (Concrete, 4 cu. yds.) $180.00 - Equipment Rental $250.00 5. Signage (2 metal signs fixed to fence) $200.00 6. Waste disposal (400 tons) - Mobilization/ demobilization of front end loader $400.00 - Loading; Front end loader w/ operator (40 hrs @110.00/hr) $4,400.00 - Hauling; 400 tons or 20 hauls x 1 hour @ $600.00/ hr $12,000.00 - Disposal; 400 tons @ $41/ ton = $16,400.00 7. Leachate Disposal (Salisbury Rowan Utilities WWTP) - 3,150 gallons generated from cleaning facility - Wastewater disposal @ $0.05/gallon $158.00 Subtotal $40,488.00 10 % Contingency $4,049.00 5% Administrative $2,024.00 TOTAL $46,561.00 • The total tonnage estimate is derived from averaging the current daily tonnage (approximately 80 TPD) multiplied by 5 days. March 20, 2018 Mr. Ming-Tai Chao, P.E. Permitting Engineer North Carolina Department of Environmental Quality Division of Waste Management – Solid Waste Section Permitting Branch 1646 Mail Service Center Raleigh, NC 27699-1646 Transmitted via email: ming.chao@ncdenr.gov RE: Waste Management of Carolinas, Inc. - East Spencer Transfer Station Permit No. 8004T-TRANSFER-1995 Request for Life-of-Site Permit Renewal Dear Mr. Chao, As you are aware, we initially submitted a permit renewal request for the referenced facility on January 30, 2018, as the current permit is due to expire on September 2, 2018. In your review of the previous submittal you requested several clarifications and revisions to the Operations Plan accompanying the initial request. Your review comments have been transcribed in Attachment 1 to this letter along with our responses. Further, the responses are consistent with the content of the enclosed/revised Operations Plan. Attachment 2 to this letter is a copy of the Applicant Signature Page provided in your earlier correspondence. The page has been signed by our Area Director of Collections Operations, K. Eric Wakefield. Pursuant to NCGS 130A-294 (a2), Waste Management of Carolinas, Inc. is requesting a life-of-site permit renewal. Based upon your email dated January 30, 2018, we understand that the duration of our life-of-site permit will be limited to a period of 60 years from the facility’s first acceptance of waste. Given that the initial permit was issued on May 11, 1995, we are requesting a life of site permit to expire no earlier than May 11, 2055. As part of this permit renewal we are also requesting that Rowan County Landfill (Permit No. 8003-MSWLF-1988) located in Woodruff, NC, approximately 13 miles from East Spencer, be added as an additional back-up disposal location for the transfer station. East Spencer Transfer Station 1000 North Long Street East Spencer, NC 28054 (336) 253-0091 WASTE MANAGEMENT OF CAROLINAS, INC. Mr. Ming-Tai Chao, P.E. March 20, 2018 Page 2 of 2 In closing we would like to thank you for your assistance in review and processing of this request. Please contact me by phone at 336.253.0091, or email dmoore36@wm.com if I can provide any additional information related to this permit renewal application. Sincerely, Waste Management of Carolinas, Inc. Daniel R. Moore, PG Environmental Protection Manager Enclosure – Revised Operations Plan Email copy: Keith (Eric) Wakefield, WM Area Director Collection Operations Larry Becker, WM District Operations Manager Shawn Carroll, WM Area Environmental Protection Manager Susan Harrison, WM Area Engineer Kim Sue, Environmental Senior Specialist, DWM-Solid Waste Section LETTER ATTACHMENT NO. 1 The paragraphs below provide DEQ’s Comments on Waste Management of the Carolinas, Inc. (Waste Management’s) original, January 30, 20178, submittal of a permit renewal request for the East Spencer Transfer Station. Comments were transcribed from an email dated February 6, 2018, to Dan Moore from Ming-tai Chao, RE: Comments (DIN 28740) on LOS Application, East Spencer Transfer Station, 80-04T. Waste Management’s responses to the comments are provided in red/italicized font. 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. It is our understanding that this facility is exempt from the state and local stormwater permitting requirements. Most solid waste/transportation related activities fall under the NPDES General Permit NCG080000 for Transit and Transportation; however, as specified in various DEQ guidance documents, the site is exempt if no vehicle maintenance activities are taking place which is the case at East Spencer Transfer. 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. The reference has been corrected. 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. The requested language has been added to the Operations Plan on page 4, in Section 1.0. 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. The reference has been deleted. 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? The referenced materials will be handled as stated above. This is clarified on page 6 in Section 4.0 of the Operations Plan. 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? When recyclable and/or recoverable materials are handled at the site they will be managed in a manner to assure that they do not become contaminated by leachate or other undesirable MSW elements. End markets dictate the necessity for such practices. There are currently no plans to construct an “impermeable physical barrier” for separation of MSW and recyclable and/or recoverable materials. In the event that such a barrier becomes necessary in order to properly manage the materials, proper approval for the modification will be requested from DEQ. The Operations Plan (page 6, Section 4.0) has been modified to stipulate the use of water-resistant containers when necessary to temporarily store recyclable/recovered material in the tipping area, and to facilitate the daily wash down and cleaning of the working floor. iii. Please describe the implemented approaches to assure the recycling activities will not interfere routine waste operations in the tipping area. As stated above, end markets for recyclables and recoverable materials dictate the necessity for uncontaminated products. Further, if such activities interfere with the safe and environmentally sound practice of MSW waste handling, the amount of the respective materials being handled will be adjusted. This is necessitated by current permit conditions. iv. The tipping area must be cleaned prior to temporarily storing recyclable/recovered material. Please add this requirement to the section. This requirement has been added to the Operations Plan on page 6, Section 4.0. 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/FireOccurren ceReport.pdf Use of the referenced form has been stipulated in Section 6.0 and it has been added as Attachment 4 to the Operations Plan. 5. Please add the tire collection area or other recyclable staging area (s) to the Site Plan drawing. The tire collection area has been added to the Site Plan. 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. The requested information has been added to the Operations Plan on page 9, in a new Section 7.0, titled Financial Assurance/Closure Cost Estimate. 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). The web site is incorrect; East Spencer Transfer does not accept yard waste. 8. Please complete and sign the attached application form. The application form, signed by our Area Director of Collections Operations, is provided as an attachment to the cover letter. 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 Tel. 919-707-8251 ming.chao@ncdenr.gov http://portal.ncdenr.org/web/wm/sw (End) 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 1 Chao, Ming-tai From:Moore, Daniel <dmoore36@wm.com> Sent:Tuesday, March 20, 2018 4:08 PM To:Chao, Ming-tai Cc:Sue, Kim; Wakefield, Keith (Eric); Becker, Larry; Carroll, Shawn; Harrison, Susan Subject:[External] East Spencer Transfer - Request for Life of Site Permit Renewal - 8004T- TRANSFER-1995 Attachments:East Spencer Transfer - Permit Renewal Request Letter - March 2018 - Final -Signed.pdf; East Spenecr Transfer - Ops Plan - March 2018 - Final.pdf CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to Report Spam. Ming, Please see the attached permit renewal request cover letter and revised Operations Plan for East Spencer Transfer Station. Please 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 dmoore36@wm.com Waste Management – North Carolina/South Carolina 3303 N Glenn Ave Winston-Salem, NC 27105 Cell (336) 253-0091 Recycling is a good thing. Please recycle any printed emails.