4702_HokeCoTransfer_Comment_LOSApplication_FID 1261107_20181205

1
Chao, Ming-tai
From:Chao, Ming-tai
Sent:Wednesday, December 05, 2018 4:12 PM
To:'[e-mail]'
Cc:Freeman, Amanda; Hammonds, Andrew; Wilson, Donna
Subject:Comments on the Life-of-site Permit Application, Hoke County Transfer, 47-02
Dear Mr. Russell:

FID 1261107

The Solid Wastes Section completes a review of the received life-of-site permit application for the Hoke County
Transfer Station, Permit No. 4702-Transfer-1994. Please address/respond the comments below:

1. Throughout the Operation Plan, please use the correct agency title of North Carolina Department of
Environmental Quality (NCDEQ) instead of using NCDENR.

2. (Section 1.3)
i. What are dimensions of the transfer station building including both roofed and uncover (if has
one) areas?

ii. Figure 2 showing the detailed layout of the Hoke County Transfer Station is not available in the
Operation Plan. Please provide the figure.

iii. Please describe the spill prevention procedures for the underground storage tanks. For example,
an alarm system is installed inside each storage tank which can provide the operator overspill
warning. Or other prevention measures have been used such as pumping liquid out of tanks per
week. Please clarify.

iv. How often have the storage tanks been cleaned? Please provide the routine cleaning frequency
or schedule in this subsection.

3. (Section 2.0) Please define the waste service area – Hoke County only. Per Permit Condition No. 28,
Part V of Attachment 3 - Permit to Approval of Operate (PTO) for Hoke County LCIDLF, Permit No.
47A-LCID-1996, dated July 11, 2018 (FID1223758), the active LCIDLF can receive the permitted solid
wastes generated from Hoke County. Because the transfer facility and the LCIDLF receive permitted
wastes through the same gate and the scale house, the acceptable waste stream must come from the same
service area – Hoke County only.

4. (Section 2.1) Please add the following requirements set forth in NCGS §130A 309.05(c) to this
subsection.
A recovered material and/or recyclable material shall be managed as a valuable commodity in a manner
consistent with the desired use or end use, and all of the following conditions shall be met:
(1) Seventy-five percent (75%), by weight or volume, of the recovered/recyclable 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.
(2) The recovered/recyclable material or the products or by-products of operations that process
recovered material shall not be discharged, deposited, injected, dumped, spilled, leaked, or
2
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.
(3) The recovered/recyclable material shall not be a hazardous waste or have been recovered
from a hazardous waste.
(4) The recovered/recyclable material shall not contain significant concentrations of foreign
constituents that render it unserviceable or inadequate for sale, or its intended use or reuse.

5. (Section 2.3)
i. The subsection describes that “all refrigerants are removed from white goods before they leave
the transfer station.” Please provide additional info for the waste operations.
a. Who is responsible to remove the refrigerant from a white good containing with
chlorofluorocarbons (CFC)? A county employee or the contractor who removes the white
goods from the transfer station to an off-site facility. Does this person have a NC
certification/license?

b. Where is the on-site refrigerant storage unit located? Please show the location on the site
plan figure in Appendix B.

c. Where is the off-site facility to receive the collected refrigerant located? Contact info of the
recycling facility must be placed in the facility operating record. Please add this requirement
to the Section 10.0 – Record Keeping.

ii. For the on-site scrap tire storage, please provide the additional info to the Operation Plan.
a. Where is the storage unit located? Inside a building or the covered trailer(s). Please show the
location on the site plan drawing in Appendix B.

b. The operation of the scrap tire collection area must comply with Rule 15A NCAC 13B
.1107(2). Please add the requirement to this subsection.

c. What will the maximum number of scrap tires be stored on-site at any given day?

d. The record keeping requirement set forth in Rule 15A NCAC 13B .1107(2)(k) must be added
to Section 10.0 of the Operation Plan.

iii. For e-waste storage unit, please show the location of this storage unit on the site plan drawing in
Appendix B.

6. (Section 3.0) Please describe the permitted disposal facility which receives and disposes of the permitted
wastes transferred from this transfer station or add the following paragraphs to the section:

The waste collected at this transfer facility must be transported to a sanitary landfill facility that is
a. permitted to receive the type of waste specified, and
b. whose service area includes the origin of the waste (See Comment No. 3).

7. (Section 3.2) Please delete the second, third and fourth paragraphs related to the operating “Yard Waste
Collection Area” which has been incorporated into the permit for the Hoke County LCIDLF, Permit No.
47A-LCID-1996 dated July 11, 2018 (FID 1223758).

3
8. (Sections 2.2 & 3.3) The operator shall notify the SWS within 24 hours of attempted disposal of any
prohibited waste at the transfer station or any waste from outside the area the landfill being permitted to
serve. Please add the reporting time to the subsections.

9. (Section 3.3)
i. This subsection states “a visual inspection of all waste deposited on the tipping floor is
required.” Should a random waste inspection to be conducted prior to unloading wastes to the
tipping floor? What is the frequency for random waste inspection? Since the average daily
tonnage at the facility is about 120 tons/day, in a minimum of 1% of the average number of
waste trucks per day or per week should be considered. Please clarify.

ii. Please append a copy of the typical waste screen/ inspection form to the Operation Plan.

10. (Section 3.5) Per requirement of Rule 15A NCAC 13B .0402(7), any observed wind-blown litter shall be
picked up at the conclusion of each operating day. Please add this requirement to this subsection.

11. (Section 3.9)
i. In the fourth paragraph, please correct the typo. The contingency plan should relate to the Hoke
County Transfer Station, not the adjacent landfill units.

ii. Please provide the procedures to manage “hot load” at the following scenarios: a “hot-loaded”
truck approaching to the gate, at scale house, by/at the tipping floor.

iii. Should the waste-loaded transfer station be staging at the transfer station for any acceptable
reason, please add this operation requirement below to the Section 3.0.

Waste may be stored on-site, in vehicles or containers that are constructed, operated, and maintained to
be leak resistant in order to prevent the creation a nuisance to the public health from the escape of solid,
semi-solid, or liquid waste a maximum of 72 hours when the facility is closed during a weekend or
holiday. Storage of the waste must not cause any nuisance, such as odor or attraction of vectors.

12. (Section 7.4) The standard form – the Solid Waste Management Facility Fire Occurrence Notification
Form is not available in the Application. This form, however, can be downloaded from the following
web link:
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Forms/FireOccurrenceReport.pdf

13. (Section 9.0) Section 1.3 states two 1200-gallon storage tanks are storing wash-down liquid and leachate
generated from waste operations at the transfer station. The tank inspection muse be added to this
Section. Additionally, this sludge inside tanks must be periodically removed and disposal at an off-site
permitted facility. The tank cleaning activities must be documented; the documentation of this activity
must be placed in the facility operating record and added to Item O in the Section 10.0.

14. (Section 10.0)
i. The following items that are not related to the operations at the transfer station may be removed
from this section:
Items G; H; I; J; L; & M

ii. Annual reports for the landfill should be removed from Item K.

iii. Please add the following items to the operating record:
4
a. Contact info of waste disposal facility including permit number & waste tonnage which
received wastes from the transfer station (see Comment No. 6)
b. Contact info & waste tonnage of a contractor to receive recyclable or recovered material
from the transfer station (see Comment No. 5.i.c.)
c. Temperature monitoring and follow-up activity as needed (see Comment No. 7.v.)
d. Leachate removal, inspection, & cleaning record (revise Item O & see (see Comment No. 13)

Please contact myself if you have any question or require further clarification to the above-mentioned
comments. Have a wonderful evening.

Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]