3507_INSP_20191206

NORTH CARnLINAD_E Q�/��
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: FRANKLIN
MSWLF
PERMIT NO.: 3507-TIRETP-2016
Closed
HHW
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
Tire T&P/
X
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: December 6, 2019
FACILITY NAME AND ADDRESS:
PRTI, Inc.
2105 US Highway 1
Franklinton, NC 27525
GPS COORDINATES: 36.06473°,-78.48715'
Date of Last Inspection: August 7, 2019
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Scott Clagett; Ben Machon; Brent Burger
Telephone: [phone] Scott; [phone] Ben; [phone] Brent
Email address: sclagett&prtitech.com; bmachonkprtitech.com; bburger&prtitech.com
FACILITY CONTACT ADDRESS:
Same as above
PARTICIPANTS:
Davy Conners, NC DEQ — Solid Waste Section
Chris Hare, PRTI, Inc.
Compton Donohue, PRTI, Inc.
STATUS OF PERMIT:
Permit to Operate was issued on February 22, 2016 and will expire on December 31, 2019. Renewal for the permit
has been submitted to the Permitting Branch of the Solid Waste Section and is under review.
PURPOSE OF SITE VISIT:
Follow up inspection to the August 7, 2019 compliance inspection.
STATUS OF PAST NOTED VIOLATIONS:
A. RESOLVED: 15A NCAC 13B .0106 GENERATOR OF SOLID WASTE
(a) A solid waste generator shall be responsible for the satisfactory storage, collection and disposal of solid waste.
And, (b) The solid waste generator shall ensure that his waste is disposed of at a site or facility which is permitted to
receive the waste.
According to Mr. Chris Hare, PRTI, Inc. has begun shipping all tire char waste to Sampson County Landfill.
B. UNRESOLVED: 15A NCAC 13B .0203 PERMIT APPROVAL OR DENIAL
(d) By receiving solid waste at a permitted facility, the permittee(s) shall be considered to have accepted the
conditions of the permit and shall comply with the conditions of the permit.
And, PERMIT TO CONSTRUCT AND OPERATE, ISSUED FEBRUARY 22, 2016, ATTACHMENT 4,
PART I, NUMBER 4
(g) control measures and practices must be employed to prevent any pollutants from contaminating surface
water, groundwater, and soil.
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FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"' t0E­!�'m"""°"""' Solid Waste Section
PRTI, Inc. remains in violation of 1 SA NCAC 13B . 0203 and Permit Condition Attachment 4, Part I, 4(g) by failing
to excavate and sample tire char that was observed during the August 7, 2019 inspection contaminating surface
water and soil. During the December 6, 2019 inspection, Davy Conners observed a trail of tire char from the
sedimentation basin at the back of the facility to a ditch alongside a service road (the service road is owned by
neighboring Capital Materials/Dan Wall). The tire char diverted from the ditch into the forest and passed under
the service road into another ditch. The tire char was in the water in the ditch and stained the soil in the ditch and
the soil/leaves in the forested area (Figure 1). Control measures, such as booms, berms and gravel, have been
implemented however it is not possible to tell if these measures are sufficient at preventing contamination since
previous contamination has not been remediated.
Figure 1: Contamination of soil and water with tire char beyond sediment basin.
STATUS OF PAST NOTED COMPLIANCE ISSUES:
A. CORRECTIVE ACTIONS ONGOING: During the August 7, 2019 inspection, tire char was found on the
ground throughout the facility but was thickest around/near the grinder. The grinding operation was not under
cover. During the December 6, 2019 inspection, the amount of tire char on the ground was reduced (Figure 2).
PRTI, Inc. has implemented management practices to better contain and clean up the tire char such as limiting
the grinding space, covering the steel post -grinding, creating berms and other containment structures. In
addition, PRTI, Inc, has enlisted the help of Smith and Gardener to design and install a new sedimentation and
erosion control plan/system. This system is to be installed within the next few months. Additional practices
may be necessary to keep tire char from leaving the site.
Figure 2: Some tire char still on the ground but greatly reduced since last inspection and amount of supersacks with tire char also reduced.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
B. PARTIALLY RESOLVED: 15A NCAC 13B .1110 SCRAP TIRE PROCESSING FACILITIES
(a)... At least 75% of both the scrap tires and processed tires that are delivered to or maintained on the
site of the scrap tire processing facility site shall be processed and removed for recycling or disposal at a
permitted solid waste management facility within one year of their receipt.
C.
AND, THE PERMIT TO OPERATE ATTACHMENT 4, PART I, NUMBER 2
The scrap tire processing facility is permitted to collect, store, process and maintain on site, not more
than 13,000 tires or the equivalent in shredded tire or by-products.
Most of the large stockpile of supersacks full of tire char, observed in the August 7, 2019 inspection, have been
removed from the site. Mr. Hare said they have been disposed of at the Sampson County MSWLF. However,
some supersacks remain (Figure 2).
RESOLVED: During the August 7, 2019 inspection, one of the scrape tire storage bays had some tires and
rubber outside of the covered area. During the December 6, 2019 inspection all tires and rubber were stored
under cover, with the exception of tires that had just been delivered (Figure 3).
Figure 3: Rubber and tires stored under bays.
The item(s) listed above were observed by Section staff and require action on behalf of the facility in order to come into or maintain compliance
with the Statutes, Rules, and/or other regulatory requirements applicable to this facility. Be advised that pursuant to N.C.G.S. 130A-22, an
administrative penalty of up to $15,000 per day may be assessed for each violation of the Solid Waste Laws, Regulations, Conditions of a Permit,
or Order under Article 9 of Chapter 130A of the N.C. General Statutes. Further, the facility and/or all responsible parties may also be subject to
enforcement actions including penalties, injunction from operation of a solid waste management facility or a solid waste collection service and any
such further relief as may be necessary to achieve compliance with the North Carolina Solid Waste Management Act and Rules.
ADDITIONAL COMMENTS
During the inspection and formally via email on December 6, 2019 Mr. Hare asked for an extension of the deadline
given in the August 28, 2019 Notice of Violation. The Section grants an extension with a new compliance deadline of
January 30, 2020. PRTI must take the following corrective action measures by January 30, 2020 in order to
achieve compliance:
1. Excavate all areas of tire char that have migrated beyond PRTI, Inc.'s sediment basin. If you wish to
test/sample nrior to excavation. you may. however removal of all migrated tire char and at least 2 inches of un
stained soil is still necessary and soil sampling post excavation is also needed. Excavated tire char and soil
must be disposed of in an MSWLF permitted to receive that waste.
a. Surface confirmation soil samples shall be collected between zero and one foot below ground surface.
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FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"'—t0r-!�'m"""°"""' Solid Waste Section
All samples shall be collected as discrete samples for all constituents. Composite samples will not be
accepted.
b. Sampling constituents include: zinc, chromium (total, hexavalent and trivalent) and PA -Hs:
Benz [a] anthracene, Benzoo)fluoranthene, Benzo[a]pyrene, Benzo[b]fluoranthene,
Benzo[k]fluoranthene, Dibenz[a,h]anthracene, Dibenzo(a,e)pyrene, Dimethylbenz(a)anthracene, 7,12-,
Indeno[ 1,2,3 -cd]pyrene, Methylnaphthalene, 1-, Methylnaphthalene, 2-, Naphthalene, and Nitropyrene,
4-.
c. Please submit to me the following:
i. a map of the areas excavated and sampled,
ii. documentation of proper disposal of excavated material,
iii. a table of the subsurface soil analytical results compared to the NCDEQ Preliminary Soil
Remediation Goals (PSRGs) (both the Residential Health Based and the Protection of
Groundwater PSRGs must be met),
iv. and the associated laboratory reports from the NC certified laboratory including the
chain of custody and QA/QC results.
2. Properly dispose of all remaining supersacks of tire char to an MSWLF permitted to receive that waste. Please
submit to me documentation of proper disposal of this material.
3. Continue to ensure the facility PRTI is sending its waste to is permitted to receive that waste by asking for a
copy of the permit and verifying that the permit is not expired. Retain records of all waste disposal.
4. Continue to take measures to prevent tire char and any other pollutants from contaminating surface water,
groundwater, and soil. Additional measures may be necessary.
5. Continue to implement best management practices to contain waste including carbon black dust. Additional
measures may be necessary.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Davy Conners
DN: cn=Davy Conners, o=Division of
Waste Management, ou=Solid Waste
Section,
email=[e-mail], c=US
Date: 2019.12.17 15:49:40-05'00'
Davy Conners
Environmental Senior Specialist
Regional Representative
Email: [e-mail]
Phone: [phone]
Sent on: December 17, 2019 X Email Hand delivery US Mail Certified No.
Copies: Andrew Hammonds, NC DEQ
Jason Watkins, NC DEQ
Sherri Stanley, NC DEQ
Ethan Caldwell, NC DEQ
Jason Williams, PRTI, Inc.
Compton Donohue, PRTI, Inc.
John Patrone, NC DEQ
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