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CT Corporation System, Registered Agent for .........
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Republic Services of North
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150 Fayetteville Street
Box 1011
Raleigh, NC 27601
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D. Is delivery address different from item 1? U Yes
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If YES, enter delivery address below: ❑ No
CT Corporation System, Registered Agent for.i
.I Republic Services of North Carolina, LLC -I
150 Fayetteville street -
i 3. Service Type
Certified Mail ❑ Express Mail
NOV 2009 ❑ Registered Return Receipt for Merchand
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
MUD WASTEF - -- --
-2ASMEW EGIONAI OFFIC-E -- 7�08 �1to2sss-o2-M•t
52 0000 7473 4424
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T. PS Form 3811, February 2004 Domestic Return Rec-Apt - -

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Mr. Nathan Bennett County
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Yancey county
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Burnsville, NC 28714
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Mr. Nathan Bennett, County M1�w
Yancey County ;
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110 TRE
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3. Service Type
NOV 4 I 1 8 2009
Certified Mail ❑ Express Mail
❑ Registered Return Receipt for Merchandi
❑ Insured Mail ❑ C.O.D.
SOLID WASTE SECTION
4. Restricted Delivery? (Extra Fee) ❑ Yes
2. 4HN&&1(WAJPA EGIO vz — -- -
- -- - -- -- -- — - - -
(fransfer from service label) 7008
015 0 0000 7473 440,0
PS Form 3811, February 2004. Domestic Return Receipt 102595-02-M-1

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Mr. Charles Vines, County Manager ---- ---------
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Mitchell County
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P.O. Box 409M
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Bakersville, NC 28705
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item 4 if Restricted Delivery is desired.
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so that we can return the card to you.
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or on the front if space permits.
1. Article Addressed to:
Mr. Charles Vines, County Manager
Mitchell County
P.O. Box 409M
Bakersville, NC 28705
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'V- Certified Mail ❑ Express Mail
NOV 13 2009 ❑ Registered Return Receipt for Merchandi
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2. Article Nu `
R I ICE I NAL OFFICE
(Trans' �� Ice a e� 7008 0150 0000 7473 4431
PS Form 3811, February 2004 Domestic Return Receipt 102595 o2-M-1;

KRD Trucking • 20340 Stoney Island • Lynwood, IL 60411 • [phone] - Fax [phone]
11-17-2009
Don Phelps
Republic Services — Yancey County
Dear Don,
Per Republic Service's request, KRD Trucking, Inc. has ordered new trailer seals and will have them installed
no later than Monday, November 23, 2009.
If you have any additional questions or concerns, please feel free to contact us.
Respectfully,
John McGee, VP of Operations [phone]
Ken Andresen, Financial Officer [phone]

1
November 20, 2009
Mr. Bill Wagner
Environmental Senior Specialist
NCDENR — Solid Waste
2090-US-Highway 70
Swannanoa, NC 28778
NOV 2 3 2009
SOLID WASTE SECTION
ASHEVILLE REGIONAL OFFICE
Re: Yancey — Mitchell Transfer Station, Permit #100-03-T
Mr. Wagner,
ARV REPUBLIC
406 SERVICES
On November 13, 2009, we received your Facility Compliance Audit Report, dated 10/01/2009, which
included Notice of Violations (NOV). This letter will serve as our response and to update you on the
status of corrective measures being taken at the facility. Our General Manager has met with the County
Manager to discuss this situation and has assured them that Republic will implement the corrective
measures noted. For clarity, the NOV is shown below with our response in bold.
1. Yancey County, Mitchell County and Republic Services of North Carolina, LLC are in violation
of 15A NCAC 13B .0105(c) by failing to ensure that three semi -trailers filled with solid waste
from the Yancey -Mitchell transfer station were leak proof. Each of these three semi -trailers was
leaking.
To correct this violation and be in compliance with 15A NCAC 13B .0105 (c), within 7 days from
receipt of this notice, Yancey County, Mitchell County and Republic Services of North Carolina,
LLC must ensure that all vehicles or containers used for the collection and transportation of garbage,
or refuse containing garbage are leak proof.
Republic Services of NC, LLC notified our subcontracted hauling company, KRD Trucking, on
November 13, 2009, of these violations and that immediate attention and corrective measures
are required. KRD Trucking has responded with the attached letter, stating that new trailer
seals have been ordered and will be installed no later than November 23, 2009.
2. Yancey County, Mitchell County and Republic Services of North Carolina, LLC are in violation
of 15A NCAC 13B .0203(d) by failing to comply with condition 7(c) in Part I of Attachment 3 of
their permit. There were three semi -trailers on site that were filled with solid waste, but did not
have watertight covers. All three trailers were leaking leachate.
To correct this violation and be in compliance with 15A NCAC 13B .0203(d) within 7 days from
receipt of this notice, Yancey County, Mitchell County and Republic Services of North Carolina,
LLC must ensure that all on -site trailers that contain waste, are leak proof and have watertight covers.
Republic Services of NC, LLC notified our subcontracted hauling company, KRD Trucking, on
November 13, 2009, of these violations and that immediate attention and corrective measures
PO Box 2943
Hickory, NC 28603
828.464.2414 • Fax [phone]
Toll Free 866.473.7778
www.republicservices.com

are required. KRD Trucking has responded with the attached letter, stating that new trailer
seals have been ordered and will be installed no later than November 23, 2009.
The local manager for KRD trucking has requested that his home office, look into the purchase
of the solid, watertight covers. Solid covers are not typically used in the solid waste hauling
business due to the extra weight and associated difficulty with covering the waste. These tarps
generally will require that someone get on top of the load and physically pull the tarp to cover
the waste. This practice puts personnel in danger of falling as well as puncture wounds from
walking on th trash. In addition to the personnel protective measures, -solid -tarps will -trap -
heat and can increase the risk of spontaneous combustion.
For these reasons, we will request that the County and their engineering consultant, revise the
current operations plan to remove the watertight cover requirement. The trailer seals should
be sufficient to prevent leaks.
3. Yancey County, Mitchell County and Republic Services of North Carolina, LLC are in violation
of 15A NCAC 13B .0402(3) by failing to contain water that came into contact with solid waste
(leachate) in three open semi -trailers. Two of these semi -trailers were leaking leachate in an
uncontrolled manner onto bare ground. The third semi -trailer was leaking leachate in an un-
controlled manner onto the asphalt road outside of the transfer station receiving bay and this
leachate was running into a storm water ditch.
To correct this violation and be in compliance with 15A NCAC 13B .0402(3) within 7 days from
receipt of this notice, Yancey County, Mitchell County and Republic Services of North Carolina,
LLC must ensure that all leachate (any water that comes into contact with solid waste is considered to
be leachate) is properly contained on site.
A site investigation will be conducted to determine where and if any leachate washed off -site.
In conclusion, Republic Services of NC, LLC will implement and complete the requested corrective
measures within the next 7-10 days. We will provide a follow-up letter when all items have been
completed.
Sincerely,
n ? -
Ra mond Hoffman P.E.
Y
Republic Services of NC, LLC
Area Engineer
Cc: Drew Isenhour, Area President
Don Phelps, General Manager
Nathan Bennett, Yancey County Manager
Charles Vines, Mitchell County Manager
PO Box 2943
Hickory, NC 28603
828.464.2414 * Fax [phone]
Toll Free 866.473.7778
www.repubhcservices.com

E N G I N E E R I N G } i Y D R O G E O L O G f
L-,-----__._............ ._._ ---................. 1
231 HAYWOOD STREET, ASI'IEVILLE, NC 28801
TEL.[phone] FAC.828.281.3351
WWW.A LTA MONTENVI RON MENTAL.COM
November 23, 2009
Mr. Bill Wagner
North Carolina Department of Environment and Natural Resources
Solid Waste Section
2090 US Highway 70
Swannanoa, North Carolina 28778
Subject: Response to Facility Compliance Audit Report
Yancey -Mitchell Counties Transfer Station
Permit No.: 100-03_ f
[rear Mr. Wagner,
You and Mr. Paul Crissman with the North Carolina Department of Environment and
Natural Resources (NC DENR) Division of Waste Management Solid Waste Section visited
and observed the transfer station on October 1, 2009. You completed a Facility
Compliance Audit Report dated November 12, 2009. The Facility Compliance Audit Report
was received at the Yancey County Manager's office on November 16, 2009.
You cited three "violations" and several "areas of concern and comments" in the Facility
Compliance Audit Report. You requested that Yancey County, Mitchell County, and
Republic Services of North Carolina, LL.0 (Republic) correct the cited violations within 7
days of receipt of the Facility Compliance Audit Report.
Republic responded to your Facility Compliance Audit Report in a letter from there to you
dated November 20, 2009. On behalf of Yancey and Mitchell Counties, Altamont
Environmental, Inc. (Aitamont) has prepared this letter in response to your Facility
Compliance Audit Report. The following sections of this letter include lists of the violations
and areas of concern and comments you cited with responses.
VIOLATIONS
?. _15A JI't."riC 1.39.0105(c) requires that "vehicles or containers used for the collection
and transportation by whatever means, including .but not limited to, highway, rail,
and navigable waterway, of garbage, or refuse containing garbage, shall be
covered, leaf: proof, durable, and of easily cleanable construction. "
Yancey County, Mitchell County and Republic .5ervices of North Carolina, L LIE- are in
violation of 15,E N ,4C 1.3B . 0105(c) by failing to ensure that three semi -trailers, filled
with solid waste from the Yancey-tvritchell transfer station were leak proof: Each of
these three semi -trailers was leaking.
P:\Yancey-Solid Waste\Correspondence\Ltr_Wagner_NOV Response-1.1_23_09.Docx

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Mr. till Wagner
November 23, 2009
Page 2 of 4
To correct this violation and be in compliance with 15,E NCAC 1313.0105(c), within 7
days from receipt of this /Votice, Yancey County, Mitchell County and Republic
Services oflltort-h Carolina, LLC must ensure that all vehicles or containers used for
the collection and transportation of garbage, or refuse containing garbage are leak
Republic and its subcontract hauling company have assured Yancey and Mitchell Counties
that: trailer seals are to be installed no later than today (November 23, 2009). Republic
and its subcontract hauling company indicated that the trailer seals will correct this
violation. See the attached letters.
2, 15A IVIC,4C l3R . 020..3(d) rc-quires that "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. " Item 7(c) in Part / of
,attachment 3 of the " lncey and Mitchell Counties Transfer Station Permit to
Operate (#Z00-03T)" dated.June !, 3009 states: "Waste may be stored on -site, in
leak proof transfer trailers, with watertight covers, a maximum of14 hours except
that a minimal amour7t of waste may be stared for 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. "
Yancey County, Mitchell County and Republic Services of North Carolina, LLC" are in
violation of .15,a NCAC 1315, 0203(d) by failing to comply with condition 7(c) in Part I
ofA1tachment 3 of their permit. There were three semitrailers 0/7 site that were
filled with solid waste, but did not have watertight covers. ; t 11 three trailers were
leaking leachate.
To correct this violation and be in compliance with 15A JVCAC 13C3.203(d) within 7
days from receipt of thls Alotire, Yancey County, Mitchell County and Republic
Services of North Carolina, LLC must ensure that all on -site trailers that contain
waste, are leakproof and have watertight co vers.
You observed that the transfer trailers were not equipped with watertight covers. You
cited Condition 7(c) in Part I of Attachment 3 of the Transfer Station Permit to Operate
entitled "Conditions of Operating Permit" states "Waste may be stored on -site, in leak
proof transfer trailers, with watertight covers..."
The regulation in 15A NCAC 13B .0105 requires that "...containers used for the collection...
stf garbage, or refuse containing garbage, shall be covered, leak proof, durable, and of
easily cleanable construction." This regulation does not require "watertight" covers on the
containers. Furthermore, as noted in the enclosed letter dated November 20, 2009 from
Republic, the installation of watertight covers creates a safety concern as well as the
increased possibility of spontaneous combustion.
Yancey County respectfully requests that Condition 7(c) in Part I of Attachment 3 of the
"Fransfer Station Permit to Operate be revised to remove the watertight container cover
requirement and replace it with a requirement: that the containers be leak proof and that
any water that collects within the containers be disposed in compliance with local, state,
and federal rules, laws, and regulations.
PAYancey-solid waste\Correspondence\Ltr_wagner_NOV Response_12_23_09.Docx

Mr. Bill Wagner
November 23, 2009
Page 3 of 4
3. 1 A lliC;I C 1.3B . 0402(3) requires that „water that comes into contact with solid
waste will be contained on -site or properly treated prior to discharge from the site:,. "
Yancey County, Mitchell County and Republic Services of North Carolina, LLC are in
violation of 15A NCAC' 13R .0402(3) by failing to contain water that came into
contact with solid waste (leachate) in three open sari -trailers. Two of these term -
trailers were leaking leachate in an un-controlled manner onto bard ground. The
third semi -trailer was leaking leachate in an un-controlled manner onto the asphalt
road outside of the transfer. station receiving bay and this leachate was running into
a storm water ditch. (See photo #4 below.)
To correct this violation and be It? compliance with 1514 IV,, -'-AC 13B .0402(3), within
days from receipt of this Notice, Yancey County, Mitchell C:"ounl.-y and Republic
Servlres of North Carolina, LLC' must ensure that a# le-achate (any water that corne.s
into contact with solid waste is considered to be leachate) is properly contained on
site.
You observed that the waste containers were not leak proof, thereby leaking water in all
un-controlled manner onto bare ground. As stated in a previous response, seals have
been installed in the waste containers as of the date of this letter (November 23, 2009).
Recording to Republic and its subcontract waste hauler these seals will contain water that
comes into contact: with solid waste so that it may be properly disposed from the site.
AREAS OF CONCERN AND COMMENTS
s, leery little wino' blown trash around the transfer station.
No Response.
2. The transfer station was receiving waste-' during the audit.
No Response.
3. LIV17 to good's with C'i:l_:s (refrigerant) should be stored upricrht to prevent any release
of the C =C.S. (See photo -11- below.)
Yancey County has instructed the Transfer Station staff to store the white goods in
an upright manner to reduce the risk of a release of CFCs (refrigerant).
4. Wastes are screened daily and the records are kept in the office at the transfer
.station.
No Response.
. The tipping floor was clean and well maintained`
No Response.
6. The drain trench at the entrance to the transfer station was clear of debris.
No Response,
P:\Yancey-solid Waste\Correspondence\l.tr Wagiier_NOV Response_17._23-09.aocx

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Mr, Gill Magner
November 23, 2009
Page 4 of 4
7. T17e floor drain in the receiving bay mush be cleaned and tested to ensure that any
leaclfate in tlfe bay is collected and diverted to the '%wer" leachate tanks.
Yancey and Mitchell Counties Will work with Republic to ensure that Water collection
and diversion to the Ieachate tanks is occurring.
uklp(-r 1tWL11CUU LCdnK JUr Me arafn I.rencn at the entlance to tine transfel-
station appeared to be approximately less than half full.
No Response.
9. -Propane cylinders and acrtomotive gas tanks are segregated for recycling in
separate roll -off containers.
No Response.
.s (I,.51rfff Certifications (listed in table forrn).
No Response.
On bohalf of Yancey and Mitchell Counties, AAltarnont hopes this information is responsive
to your needs. Please feel free to call me at (828) 281-3 350 with any questions or
comments.
Sincerely,
AL.TAMONT ENVIRONMENTAL, INC.
Fla u,I Dow, P.E.
Enclosures; Letter from Republic Services, dated November 20, 2009
Letter from KRl9 Trucking, dated November 17, 2009
PAYancey-Solid Waste\Correspondence\Ltr_Wagner_NOV Response_11_23_09.Docx