NRT_TireDerivedAggregate_Response_20180511

May 11, 2018
Sent via email: [e-mail]

Ben Bryant
New River Tire Recycling LLC
312 East Hwy 52 Bypass
Pilot Mountain, NC 27041

Subject: Use of Tire Derived Aggregate in North Carolina

Mr. Bryant:

This letter is in response to your request for the regulatory position of the Solid Waste Section (Section)
on the use of tire derived aggregate (TDA) resulting from your scrap tire processing facility in Pilot
Mountain, North Carolina.

The Section acknowledges that there are long standing civil engineering practices using both whole and
scrap tires as a substitute for other construction materials, as noted in the ASTM standard submitted
with your request. Both the Section and our counterparts in the Division of Environmental Assistance &
Customer Service have studied this practice in the past and believe it can be beneficial to both industry
and the environment through the reuse of scrap tires, when utilized under the oversight of a licensed
professional (engineer, geologist, architect, etc.) for the design, construction, monitoring and/or
maintenance of these projects.

As such, the Section has no issue with New River Tire Recycling generating and marketing TDA material
for the following civil engineering applications:

• Roadway/Railway Subgrade Fill and Embankments
• Backfill for Retaining Walls and/or Bridge Abutments
• Roadway/Railway Subgrade Insulation
• Landfill projects
• Septic System Drainage Fields

Engineers and/or designers of other proposed applications should contact the Section in advance of the
project to determine if additional information is required to be submitted and approved. Tire Derived
Aggregate cannot be used as fill material in other beneficial fill projects codified in 15A NCAC 13B .0562.
There is currently no solid waste permitting requirement specific to the use of TDA unless it’s being used
in a landfill construction project. Nothing in this letter shall be construed to exempt the use of TDA in
these type projects from regulation or permitting by any other local, state, and/or federal agency.

It should be noted that the production of TDA material at your facility falls within the total tonnage
(unprocessed and processed tire) restrictions under your approved permit. Any additional tonnage from
this new process, not offset by reductions in other operational areas, will require modification of your
current financial assurance levels. You may also be required to modify your operational plans and site
drawings to reflect this activity.

Should you have any questions, please contact me at [phone] or [e-mail] .

Sincerely,

Jason M. Watkins, CPM
Field Operations Branch Head
Solid Waste Section

Copies (via email): Ed Mussler, Solid Waste Section Chief
Wendy Worley, Recycling Programs Section Chief – DEACS
Ellen Lorscheider, Deputy Director – Div. Waste Management
Allen Gaither, Permitting Engineer – SWS
Charles Gerstell, Environmental Sr. Specialist – SWS
Deb Aja, Western District Supervisor – SWS
Sarah Rice, Compliance Officer - SWS