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Home My WebLink About6903T_PamlicCo_FARequirements_FID1804121_20230615ROY COOPER Governor ELIZABETH S. BISER Secretary MICHAEL SCOTT Director NORTH CAROLINA Environmental Quality June 15, 2023 Emailed: bill.fentress@pamlicocounty.org Mr. Bill Fentress Finance Director Pamlico County PO Box 776 Bayboro, NC 28515 RE: Financial Assurance Requirements for Pamlico County Transfer Station, Permit Number 6903T-TRANSFER-1993 Annual Financial Assurance Requirements and Electronic Submittal Dear Mr. Fentress, The Division of Waste Management — Solid Waste Section (Section) has identified Pamlico 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. Pamlico County's initial closure cost for the transfer station was approved on June 5, 2023 for the amount of $66,206.00. The approval notice can be found on our Laserfiche document repository at FID 1801844. The table below represents a timeline of when Pamlico 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 Pamlico County's based on Pamlico County's based on Pamlico 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 Pamlico County Owned Transfer Station, Permit Number 6903T-TRANSFER-1993 Annual Financial Assurance Requirements and Electronic Submittal June 15, 2023 Page 2 of 4 When Pamlico 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 Pamlico County can choose either a local government test based on Pamlico County's ratios of financial strength or bond ratio financial strength. The financial information entered into this test is based on Pamlico County, not the transfer station's financial strength. That is why the local government test is due after Pamlico County 's financial audit is complete for the fiscal year. If Pamlico County's financial audit is not completed by December 315t, the Section would request Pamlico County submit a request for an extension for the mechanism submittal. Pamlico County can also choose to use a capital reserve. This is where Pamlico 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, Pamlico 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 Pamlico County's chosen mechanism. • Should Pamlico 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 Pamlico County Owned Transfer Station, Permit Number 6903T-TRANSFER-1993 Annual Financial Assurance Requirements and Electronic Submittal June 15, 2023 Page 3 of 4 Should Pamlico 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 Pamlico 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. Moutos@deq.nc.aov . Should Pamlico 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 , 0=DWM - Solid Waste Section,ou=NC Department of Environmental Quality, email=sarah.moutos@ncdenr.gov, -US Date: 2023.06.15 16:01:57-04'00' Sarah Moutos Environmental Program Consultant Division of Waste Management — Solid Waste Section ec: Bobby Darden, Solid Waste Director Tim Buck, County Manager Sherri Stanley, SWS Deana Yitbarek, SWS