9005T_UnionCo_FARequirements_FID1804119_20230615

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MICHAEL SCOTT
Director
NORTH CAROLINA
Environmental Quality
June 15, 2023
Emailed: Beverly. [e-mail]
Ms. Beverly Liles
Finance Director
Union County
500 N. Main Street, Suite 700
Monroe, NC 28112
RE: Financial Assurance Requirements for Union County
Transfer Station, Permit Number 9005T-TRANSFER-1999
Annual Financial Assurance Requirements and Electronic Submittal
Dear Ms. Liles,
The Division of Waste Management — Solid Waste Section (Section) has identified Union County
as falling under the requirement of the Section's financial assurance program. Effective January
1, 2021, Solid Waste Transfer Station Rules in 15A NCAC 13B .0401 were readopted. Since then,
the Section has been working with active transfer station facilities on coming into compliance with
the readopted Rules. Once closure cost estimates are received and approved by the Section, the
permittee will receive a closure cost approval to use as the baseline environmental liability to use
for their fiscal year financial statement and completing either a local government test or capital
reserve. Union County's initial closure cost for the transfer station was approved on June 8,
2023 for the amount of $190,700.00. The approval notice can be found on our Laserfiche
document repository at FID 1802371.
The table below represents a timeline of when Union County would incorporate their transfer
station cost into either a local government test or capital reserve.
Transfer Stations — Public Entities
Closure cost approved
Closure cost approved
Closure cost approved
between July 1, 2021 and
between July 1, 2022 and
between July 1, 2023 and
June 30th, 2022
June 30th, 2023
June 30th, 2024
Submit financial assurance
Submit financial assurance
Submit financial assurance
test due by December 31st,
test due by December 31st,
test due by December 31st,
2022. Financial Strength is
2023. Financial Strength
2024. Financial Strength
based on Union County's
based on Union County's
based on Union County's
FYEND 2022 Financial Audit
FYEND 2023 Financial Audit
FYEND 2024 Financial Audit
D E Q�� North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
NORTH CAROLINA
Depam.mmEnam.m.maouafty /� 919.707.8200

Financial Assurance Requirements for Union County Owned Transfer Station,
Permit Number 9005T-TRANSFER-1999
Annual Financial Assurance Requirements and Electronic Submittal
June 15, 2023
Page 2 of 4
When Union County becomes required to start submitting their annual financial assurance test,
regulations, templates, additional information, and inflation multipliers can be found at
http://www.deq.nc.ciov/swsfa.
Local Government and Municipality Mechanisms
Union County can choose either a local government test based on Union County's ratios of
financial strength or bond ratio financial strength. The financial information entered into this test
is based on Union County, not the transfer station's financial strength. That is why the local
government test is due after Union County's financial audit is complete for the fiscal year. If
Union County's financial audit is not completed by December 315t, the Section would request
Union County submit a request for an extension for the mechanism submittal.
Union County can also choose to use a capital reserve. This is where Union County would put the
money into a local fund that can only be used to close the transfer station. The annual due dates
of the capital reserve would be based on the initial local commission approval of the fund.
Templates for either mechanism can be found at the following link: http://www.deq.nc.gov/swsfa.
Local government tests and capital reserve documentation can be submitted electronically to the
Section by using the following link: https://edocs.deg.nc.gov/Forms/FA FinAssurance .
Annual Requirements
On an annual basis until the transfer station has received a closure permit from the Section, Union
County will be required to submit their mechanism of choice with the following updates.
• Update closure cost for inflation
o The inflation multiplier is posted on the Section's website at
http://www.deg.nc.aov/swsfa. This inflation multiplier should be applied to the
previous year's closure cost shown within Union County's chosen mechanism.
• Should Union County need to revise their closure cost estimate at any time, the following
would need to take place.
o A cost estimate and a written justification for the reduction to the Division for
approval no less than 180 calendar days prior to December 31st. No reduction of
the cost or the amount of financial assurance shall be allowed without written
approval from the Division.
o The owner and operator shall increase the closure cost estimate and the amount
of financial assurance and submit the revised closure cost estimate to the Division
if changes to the closure plan or facility conditions increase the maximum cost of
closure at any time during the remaining active life of the facility.

Financial Assurance Requirements for Union County Owned Transfer Station,
Permit Number 9005T-TRANSFER-1999
Annual Financial Assurance Requirements and Electronic Submittal
June 15, 2023
Page 3 of 4
Should Union County already be submitting a financial assurance mechanism for sanitary landfills
to the Section, you may include your transfer station costs on the same mechanism.
If Union County has any additional questions or concerns regarding their financial assurance
obligations, feel free to reach out to me at 919-707-8287 or Sarah. [e-mail] . Should
Union County have any questions or concerns regarding Transfer Station Rule requirements,
please reach out to Deana Yitbarek, Permitting Engineer, at Diana.Yitbarek(a)deq.nc.gov or
919.707.8234.
Regards,
Digitally signed by Sarah Moutos
DN: cn=Sarah Moutos, o=DW M - Solid
Waste Section, ou=NC Department of
Environmental Quality,
mail=[e-mail], c=US
Date: 2023 06.15 16M:16-04'00'
Sarah Moutos
Environmental Program Consultant
Division of Waste Management — Solid Waste Section
ec: Ron Gilkerson, Solid Waste Division Director
Mark Watson, County Manager
Sherri Stanley, SWS
Deana Yitbarek, SWS