7703T_RichmondCoTransferStation_Appli_extension_approval-FID1453125_20200930

From:Chao, Ming-tai
To:"Bryan K. Leggett"
Cc:Stanley, Sherri; Powell, David C
Subject:RE: [External] RE: Comments (FID 1452781) on Richmond County Transfer Station Permit # 77-03TDate:Wednesday, September 30, 2020 10:32:00 AMAttachments:image003.png
Dear Mr. Leggett: The Solid Waste Section approves your request of a ninety (90)-day extension to properly respond the comments (FID 1452781) and to provideadditional information to the life-of-site permit application for the Richmond County Transfer Station, Permit No. 7703T-TRANSFER-1994. Please submit the revised permit application by January 03, 2021. Regards,

From: Bryan K. Leggett <[e-mail]>
Sent: Wednesday, September 30, 2020 10:17 AM
To: Chao, Ming-tai <[e-mail]>
Cc: Stanley, Sherri <[e-mail]>; Powell, David C <[e-mail]>
Subject: Re: [External] RE: Comments (FID 1452781) on Richmond County Transfer Station Permit # 77-03T

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That should work.
Bryan K. Leggett
Assistant Public Works Director
Richmond County Government
P.O. Box 368
191 Walter Kelly Rd
Rockingham NC 28380
Office: 910-997-8338
Mobile: [phone]
Fax: [phone]
[e-mail]

Sent from my iPhone
On Sep 30, 2020, at 9:50 AM, Chao, Ming-tai <[e-mail]> wrote:

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and confirm you trust the following information: "Chao, Ming-tai" / [e-mail] / mail-bl2gcc02on2044.outbound.protection.outlook.com.
Hi Bryan:

How long do you request for this extension past 10/05/2020? 90 days will be ok to you.

Ming

From: Bryan K. Leggett <[e-mail]>
Sent: Wednesday, September 30, 2020 9:31 AM
To: Chao, Ming-tai <[e-mail]>
Cc: Stanley, Sherri <[e-mail]>; Powell, David C <[e-mail]>
Subject: RE: [External] RE: Comments (FID 1452781) on Richmond County Transfer Station Permit # 77-03T

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Ming,

Thank you for the quick response and I am in the process of working on the changes you have requested in the operating plans, closure plan,
post-closure plan, and financial assurance conditions for limited review. Is there a way you can grant an extension past October 5, 2020?

Thanks for your consideration.

Bryan

Bryan K. Leggett
Assistant Public Works Director
Richmond County Government
191 Walter Kelly Rd
Rockingham NC 28380
Office: 910-997-8338
Fax: [phone]
[e-mail]

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From: Chao, Ming-tai [mailto:[e-mail]] Sent: Tuesday, September 29, 2020 5:46 PMTo: Bryan K. LeggettCc: Stanley, Sherri; Powell, David CSubject: RE: [External] RE: Comments (FID 1452781) on Richmond County Transfer Station Permit # 77-03T
CAUTION: Sender is in Richmond County's List for Quick Release. Do not click links or open attachments unless verified. Review the email content closely for suspicious activity
and confirm you trust the following information: "Chao, Ming-tai" / [e-mail] / mail-dm3gcc02on2045.outbound.protection.outlook.com.
Hi Bryan: In a nutshell, all chaotic situations that we all are facing right now is because the legislature requirements – RULE READOPTION forall state rules per NCGS 150B-21.3A. We will suffer every 10-yr cycle until the retirement day reaches. I think the comment No. 17 is what you are concerning about. The closure requirements of a transfer station is stating in the “draft”rule .0406 (see attachment; the contents of a closure plan are mentioned in the rule) which is currently under rule-readoption processesand is expecting to be effective in 2021. If you don’t care to redo the application in the near future, you can ignore this draft-rulerequirement at this time. However, should the rule effect in next year, the County will be requested by rule to submit a permitapplication to update/incorporate all new requirements within a specific time period. On the flip side, the draft rule may not beacceptable in the final rule process. So you have to decide how you want to handle this “awkward” situation. The Yard Waste Unit at the landfill facility is another your concern. The unit will be regulated by new Section rule .1400 effectiveNovember 1, 2019. If the unit is less than two-acre operation area [as defined in .1401(e)] with max. capacity of 6,000 cubic yards(CY) at any given day [.1402(e)(6)], the unit is not required a permit to operate if wastes are removed to an off-site permitted facilityfor further treatment or used on site per NCGS 130A-309.05(c). But since the waste at this unit will be scheduled to be ground formulch per Operation Plan, the unit is considered as a Treatment and Process (T&P) Unit which is regulated by Rule .0302 and a 5-year-cycle permit to operate. The Solid Waste Section will assigned a unique Permit Number for this unit. The unit is exempt fromthe financial assurance requirement per .1801(a)(4). The T&P unit closure is required in the draft rule .0302 (see attachment). Again,you have the option to ignore the draft rule requirements at this time and to fix them later. If the unit has an operation area greater than two acres in size or volume more than 6,000 CY, then this unit will be regulated as thesame rules as a Large Type 1 compost unit except rules .1407 & .1409. It will have a 10-year permit cycle [.1401(c)] with a uniquePermit Number. The unit is exempt from the financial assurance requirement per .1801(a)(4) but must comply with the closurerequirements per .1410. Regardless of the size or waste volume stated above, the County must conduct routinely temperature monitoring according to rulerequirements. This is because several fire incidents were reported in the SWS records. The new section rule .1400 (Yard waste & compost) can be downloaded from the linkhttps://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Rules/2017_Readoption/15ANCAC13B.1400_CompostRuleChanges_2019.pdf The draft rules for T&P and Transfer Station can be downloaded from the linkhttps://files.nc.gov/ncdeq/documents/files/15ANCAC13B_.0100-.0700%2C.1300_NoticeAndRuleText.pdf Other recycling units described in the Operations Plan do not have closure requirements except that these units must meet therequirements in NCGS 130A-309.05(c). § 130A-309.05. Regulated wastes(c) Recovered material is not subject to regulation as solid waste under this Article. In order for a material that would otherwise beregulated as solid waste to qualify as a recovered material, the Department may require any person who owns or has control over thematerial to demonstrate that the material meets the requirements of this subsection. In order to protect public health and theenvironment, the Commission may adopt rules to implement this subsection. Materials that are accumulated speculatively, as thatterm is defined under 40 Code of Federal Regulations § 261 (July 1, 2014 Edition), shall not qualify as a recovered material, andshall be subject to regulation as solid waste. In order to qualify as a recovered material, the material shall be managed as a valuablecommodity 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 material stored at a facility at the beginning of acalendar year commencing January 1, shall be removed from the facility through sale, use, or reuse by December31 of the same year.
(2) The recovered material or the products or by-products of operations that process recovered material shall not bedischarged, deposited, injected, dumped, spilled, leaked, or placed into or upon any land or water so that theproducts or by-products or any constituent thereof may enter other lands or be emitted into the air or dischargedinto any waters including groundwaters, or otherwise enter the environment or pose a threat to public health andsafety. Facilities that process recovered material shall be operated in a manner to ensure compliance with thissubdivision.
(3) The recovered material shall not be a hazardous waste or have been recovered from a hazardous waste.
(4) The recovered material shall not contain significant concentrations of foreign constituents that render itunserviceable or inadequate for sale, or its intended use or reuse. (1989, c. 784, s. 2; 1995 (Reg. Sess., 1996), c.594, s. 9; 2015-1, s. 2(b).) I hope your concerns have been properly addressed in this e-mail message. Please feel free to contact me if you have any otherconcerns. Have a wonderful evening. Regards,
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From: Bryan K. Leggett <[e-mail]>
Sent: Tuesday, September 29, 2020 4:14 PM
To: Chao, Ming-tai <[e-mail]>
Subject: [External] RE: Comments (FID 1452781) on Richmond County Transfer Station Permit # 77-03T

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to [e-mail]

Ming,

Thank you for your time in reviewing this permit. I am in the process of updating the operating plans but wanted further information on
information required. What exactly does a closure plan consist of? What will we be closing? The general statue refers to landfills, we are a
Transfer Station. No Waste is stored on Site with the exception of our Yard Waste. Can you please help me understand.

Thanks

Bryan

Bryan K. Legget
Assistant Public Works Director
Richmond County Government
191 Walter Kelly Rd
Rockingham NC 28380
Office: 910-997-8338
Fax: [phone]
[e-mail]

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From: Chao, Ming-tai [mailto:[e-mail]] Sent: Friday, September 25, 2020 12:53 PMTo: Bryan K. LeggettCc: Powell, David C; Stanley, Sherri; Hammonds, Andrew; Reynolds, Joe <[e-mail]> ([e-mail])Subject: Comments (FID 1452781) on Richmond County Transfer Station Permit # 77-03T

CAUTION: Sender is in Richmond County's List for Quick Release. Do not click links or open attachments unless verified. Review the email content closely for suspicious activity
and confirm you trust the following information: "Chao, Ming-tai" / [e-mail] / mail-dm3gcc02on2078.outbound.protection.outlook.com.
Dear Mr. Leggett: On Tuesday, 09/22/2020, the Solid Waste Section (SWS) received the life-of-site (LOS) permit application of the Richmond CountyTransfer Station, Permit No.7703T-TRANSFER-1994. The application was uploaded to the Laserfiche with an FID 1452610.
After conducting a review of the application, the SWS has several comments below:
1. Per Rule 15A NCAC 13B .0202(a), the application shall be prepared by a professional engineer. The plans shall bear an imprintof the registration seal of the engineer and geological studies shall bear the seal of a licensed professional geologist, in
accordance with N.C.G.S. Chapter 89E. Please have a PE or PG signed, stamped, and dated the permit application documents.
2. (Section 14) Please add the following requirements to this Section:The waste collected at this transfer facility must be transported to a sanitary landfill facility for disposal that is
a.permitted to receive the type of waste specified, and
b.whose service area includes the origin of the waste.
3. (Section 18) Please add the requested info this Section:i. What are the dimensions of the building and tipping floor (length & width)? ii. What is the footprint (in acreage) of the waste transfer facility?
4. (Section 19) An attendant shall always be on duty at the site while it is open for public use to ensure compliance with
operational requirements. Please add this requirement to this Section.
5. (Section 21) The personnel shall be trained in compliance with the requirements in NCGS 130A-309.25. Documentation of thetraining shall be placed in the operating record (Section 31) and provided to the SWS upon request.
6. (Section 22) Please state the following requirement to the Section:i. Processing of materials (such as shredding or grinding) must not take place at the facility unless approval has beengranted under a special use permit and a revised operations plan has been submitted to the Section. ii. Conducting routinely waste recovery/recycling at the tipping floor is prohibited except for removal of non-conformanceor prohibited wastes.
7. (Section 24)i. Please use NCDEQ throughout the entire application. ii. The owner or operator shall notify the SWS within 24 hours of attempted disposal of any waste the transfer station isnot permitted to receive, including waste from outside the area the landfill is permitted to serve. iii. The County may consider to include the following wastes as prohibited wastes, which are difficult to handle/manage ata transfer station – regulated medical wastes, infectious wastes, animal carcass, radioactive wastes, septage, wastewatertreatment sludge, coal ash. If the County intends to handle/manage the above-mentioned waste stream at the transferstation, please detail the special waste handling procedures from the waste notification/approval prior to receivingwastes, the truck arriving at the site, through all particular/unique steps of the transfer station operation, to the point ofwaste removal; the procedures shall ensure the waste operations will maintain the facility in a sanitary conditionaccording to Rule 15A NCAC 13B .0402. iv. This section shall also include the wastes banned for landfill disposal which include:a. Liquid waste as defined in Rule 15A NCAC 13B .1626(9)(c).b. Hazardous waste as defined in NCGS 130A 290(a)(8)&(8a).c. Polychlorinated biphenyls (PCB) waste as defined in 40 CFR 761.d. Special wastes as defined in G.S. 130A-290(a)(40).e. Asbestos waste unless the waste is received and handled in compliance with the requirements of 40 CFR 61.150,which is incorporated by reference, including subsequent amendments and editions. Bags shall be no less than sixmil thick and shall be labeled with the warning required by 40 CFR 61.150(a)(1)(iv) that they contain asbestos-containing materials. Sites shall provide notice to the landfill facility receiving the asbestos waste prior to disposal.The personnel handle asbestos wastes may have to be properly trained according to the State and Countyregulations.f. Wastes banned from landfill disposal in accordance with NCGS 130A-309.10(f).g. Wastes banned by local law or ordinance at the disposal destination.h. Wastes banned from disposal by a local law or an ordinance at the place of waste origin.
8. (Section 25) Please add the following requirements to this Section:i. The facility shall prevent the release of leachate and contaminants to groundwater and surface water. The Countyshall conduct routine inspection and maintenance of structural integrity of the existing concrete tipping floor toensure that no leachate seeps through the cracks. ii. The facility shall comply with 15A NCAC 02L and the surface water quality standards in 15A NCAC 02B.

iii. Should the SWS deem it necessary, ground water or surface water monitoring, or both, may be required as providedfor under Rules 15A NCAC 13B .0601 and .0602.
9. (Section 26) Please provide the requested info below regarding the leachate management at the transfer station.i. Are there floor drains or sumps at the tipping floor and or loading bay? Please describe the floor drain & sump locations& dimensions (piping or trench alignment/layout) which lead to the on-site holding tank; the requested info should alsobe shown on the Site Plan Drawing(s). ii. Has the tipping floor been built with a grade/slope to facilitate drain aqueous wastes, leachate, wash-down liquid and toprevent any leachate from leaving the building footprint? iii. Info about the leachate holding tank:a. The volume/capacity (in gallons) of each tank.
b. How many holding tanks are used to collect leachate/wash-down liquid for the waste transfer activities?c. The location of the leachate holding tank, piping, sump, or floor drain relative to the transfer building should beshown on the Site Plan Drawing(s)?d. Does the tank is equipped any overflow alarming or early warning device? How does the operator know ordetermine the liquid inside the tank is ready to be pumped? Is there a fixed schedule or random inspection to beused?e. How often would the leachate and sludge in the tank have been removed? f. The descriptions of the routine inspection and maintenance of the leachate holding tank.g. The operator or owner shall report to the SWS verbally or in writing within 24 hours from the time the owner oroperator becomes aware of the circumstances of any release or discharge of leachate or contaminants outside theleachate collection system or other containment component at the site.
10. (Section 27) Please add the following requirements to this Section.i. The Section states that “any waste that is loaded onto tractor trailers and is not delivered to the landfill for disposal onthe same day, will be covered / tarped and delivered immediately the next working business day.”
a.Describe the waste-laden vehicle staging area (paved area?) which shall be noted on the Site Plandrawing(s).
b.The tractor trailer or waste containers shall meet the leak-resistance requirements per Rule 15A NCAC13B .0105(c). If any leachate release from the staged waste vehicle, the leachate must be collected and stored in theon-site leachate holding tank. ii. The tipping floor, push walls, and truck loading bays shall be cleaned with a pressure washer no less than once permonth. iii. The remaining areas of the site building including side walls and any material storage areas outside of the building shallbe cleaned with a pressure washer no less than twice per year. iv. Cleaning and maintenance records shall be maintained in the facility operating record (Section 31) and made availableto the SWS upon request. v. Provide a copy of the approval document issued by a WWTP to accept the wastewater generated from the facility.
11. (Section 28) Per Rule 15A NCAC 13B .0402(7), at the conclusion of each day of operation, the operator/owner shall collect allwindblown material resulting from the operation for proper disposal. Please add the rule-requirement to this Section.
12. (Section 29) Please add the specific requirements to recycling or misc. waste management units:i. The location of each described unit should be shown/noted on the site plan drawing(s). ii. All recyclables must be operated at the facility according to NCGS 130A-305.09(c). iii. Scrap tire. At the scrap/used tire collection area the collected tires must be placed in cover trailer(s) or container(s) perRule 15A NCAC 13B. 1105(d). Otherwise the rules .1101 thru .1109 are applicable to the unit. iv. White goods.a. Will the white goods containing freon be removed prior to placing in the 40-CY containers? Who is responsible forremoving of the freon? Where is the on-site location to store the collected freon?b. If the white goods containing freon will not be removed prior to temporary on-site storage, these white goods mustbe separately stored from other scrap metals or white goods without freon. v. E-wastes. The collected e-wastes should be placed in the cover container or a roofed structure to prevent any hazardousmaterial/substance leaching out onto the nearby environment. vi. Yard waste/pallets. Add the following requirements to this Section.a. Aisle space (at least 25 feet) between stockpiles (for both processed products and unprocessed wastes) shall beconstantly maintained to allow access for firefighting or emergency vehicles.b. Wooden pallets must be clean ones without any paint or contamination.c. Is this unit seated on top of the closed-out unlined MSWLF unit (see the attached drawing)? Please providesupporting document(s) to demonstrate this yard waste unit is located outside the close-out disposal unit.d. Please describe the maximum dimensions of a stockpile (base width & height) which shall be approved by the localfire marshal.e. A small Type 1/ yard waste collection unit shall be operated according to Rules 15A NCAC 13B .1406(1) through(11) & (16) [Rule 15A NCAC 13B .1402(g)(1)].f. To prevent a fire, the routine temperature monitoring of the waste piles must be conducted according to Rules 15ANCAC 13B .1406(10) and (11) and documented in the facility operating record per Rule 15A NCAC 13B .1408(a).g. Griding and processing yard waste/pallet will be conducted at this unit; therefore, operating this unit shall also be incompliance with Rule 15A NCAC .0302. No griding/processing shall be conducted in raining or windy days tominimize leachate generation or nuisance dust.h. No composting (neither active nor static pile composting) shall be allowed at this unit.i. The closure requirements per draft Rule .0302(b) may be incorporated into this Section. vii. Used Oil. The unit is a public used oil collection center per NCGS 130A-290(b)(1) to temporary collect used oil asdefined in NCGS 130A-290(b)(5).a. What is the maximum volume/capacity (in gallon) of the used oil container?b. The used oil storage container must be constantly maintained to be in good condition (no severe rusting, apparentstructural defects, or deterioration) and not leaking (no visible leaks).c. The used oil storage container must be labeled or marked clearly with the words “Used Oil.”d. The storage container(s) should be placed inside a secondary containment system which must be sufficiently
impervious to used oil to prevent any used oil released into the containment system from migrating out of thesystem to the soil, groundwater, or surface water.e. Response spill or release must be included in the Contingency Plan (Section 32)which should include, but notlimited to, the reporting requirements (verbal & written), investigation of releases and assessment of impact, andfollow-up actions including the immediate actions after a release - (1) stop the release; (2) Contain the released used
oil; (3) Clean up and manage properly the released used oil and other materials; and (4) If necessary, repair or
replace any leaking used oil storage containers or tanks prior to returning them to service. viii. Recycling Units. The SWS records show that the MRF (Mount Gilead, NC) owned and operated by UwharrieEnvironmental, Permit No. 6202-MRF-MWP has been inactive since July 1, 2013. Please provide the facility withcontact info which is and will receive the collected recyclables.
13. (Section 31) The following records must be retained in the facility operating record:i. Records of waste inspections, monitoring results, certifications of training, and training procedures.ii. Amounts by weight of solid waste received at the site including county and state of generation, in accordance with G.S.130A-309.09D.iii. Demonstrations, certifications, findings, monitoring, testing, or analytical data.iv. Closure or post-closure care monitoring, testing, or analytical data.v. Site audit records, compliance records, maintenance records, and inspection reports.vi. A copy of the current Permit to Construct and Permit to Operate.vii. A copy of the approved operations & closure plans that have been incorporated into the permit.
14. (Section 32)i. The NCDEQ phone number to report an environmental emergency including an oil spill incident is 1-800- 858-0368. Mr. Dennis Shackelford retired. ii. Hot ashes, hot loads, or cinders shall not be accepted at a site. Additionally, describe the approaches to manage “hotload” under the three different conditions. A. a waste-laden vehicle is approaching the scale house. B. a waste-ladenvehicle is inside the facility at location between the scale house and the transfer building. C. a waste-laden vehicle isinside the tipping floor. iii. Open burning of solid waste is prohibited at the landfill facility where the transfer station and other non-disposal solidwaste management units are located. iv. Provide the list of on-site firefighting equipment including a portable fire extinguisher shall be equipped in every on-sitemachinery and vehicle. v. Provide the procedures and timeline to reactivate/resume the waste operations after the facility is restored after an incidentor an emergency. The plan, at a minimum, should provide the pre-operational notification of inspection in writing (said 15business days) prior to resuming the operations. The participants of the post-incident inspection. The criteria to be satisfiedprior to resuming the operations.
15. The following components that have been incorporated into the previously approved permit application should be included inthe life-of-site permit application; they are
i. Transfer facility inspections.ii. Random waste screening/load inspection form.iii. Standardized form to report a fire – Fire Occurrence Notification which can be downloaded from the web link https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Forms/FireOccurrenceReport.pdfiv. Facility Washdown Demonstration Form.v. Transfer Station Daily Startup and shutdown checklist.vi. Site Plan drawing (s).
16. The attached certification forms for landowner (Richmond County) and the Operator (Republic Services) must be properlycompleted and notarized.
17. There are major components are not available in the received permit application:i. Closure requirements. The draft transfer station rule 15A NCAC 13B .0401(b) will request the owner/operator of theexisting permitted transfer station to submit the SWS an assessment report demonstrating that the waste operations arein compliance with the readopted Section Rule .0400 – Transfer Station. The draft rule is attached for your reference toprepare the facility Closure Plan.
a. Provide a closure plan to properly conduct facility closure activities.
b. Provide the closure cost estimate which shall be prepared according to Rule 15A NCAC 13B .1802(a)(1). ii. Financial assurance. Section Rule 15A NCAC 13B .1800, effective July 1, 2020 shall be complied accordingly. Thereadopted rule can be found in the web link:http://reports.oah.state.nc.us/ncac.asp?folderName=/Title%2015A%20-%20Environmental%20Quality/Chapter%2013%20-%20Solid%20Waste%20Management
18. The Operations Plan states that all recyclables have been, are, and will be sent to the MRF owned and operated by UwharrieEnvironmental. The DWM records show the MRF inside the Uwharrie Landfill in Mount Gilead, Montgomery County, permit# 6202MRF-MWP is inactive since 2013. Please provide the detailed contact info of the facility that will receive therecyclables collected at the transfer station. The NC Solid Waste Management Rules is in the readoption processes. The Section Rule .1400 for yard waste and compost operation is effective in November 1, 2019. The web link of the rule can befound
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Rules/2017_Readoption/15ANCAC13B.1400_CompostRuleChanges_2019.pdf. The Section Rules .0300 (for treatment and process unit/facility) and .0400 (for waste transfer station) are in the process of readoptionwhich are expected to be effective in 2021. The web link of the draft rule can be foundhttps://files.nc.gov/ncdeq/documents/files/15ANCAC13B_.0100-.0700%2C.1300_NoticeAndRuleText.pdf. The SWS encourages theCounty to review the draft rule requirements and incorporate the new requirements into the LOS permit application at this time. Please contact me if you have any question of the comments. Regards,
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From: Bryan K. Leggett <[e-mail]>
Sent: Tuesday, September 22, 2020 3:45 PM
To: Chao, Ming-tai <[e-mail]>
Cc: Powell, David C <[e-mail]>; Freeman, Amanda <[e-mail]>
Subject: [External] Richmond County Transfer Station Permit # 77-03T

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to [e-mail]

Please see attached request for section permit review.

If you have any questions please do not hesitate to contact me.

Thanks

Bryan

Bryan K. Leggett
Assistant Public Works Director
Richmond County Government
191 Walter Kelly Rd
Rockingham NC 28380
Office: 910-997-8338
Fax: [phone]
[e-mail]

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