HomeMy WebLinkAbout4602T_HertfordCo_FARequirements_FID1804122_20230615ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MICHAEL SCOTT
Director
NORTH CAROLINA
Environmental Quality
June 15, 2023
Emailed: leslie.edwards(a)hertfordcountync.gov
MS. Leslie Edwards
Finance Director
Hertford County
115 Justice Drive, Suite 1
Winton, NC 27986
RE: Financial Assurance Requirements for Hertford County
Transfer Station, permit number 4602T-TRANSFER-1995
Annual Financial Assurance Requirements and Electronic Submittal
Dear MS. Edwards,
The Division of Waste Management — Solid Waste Section (Section) has identified Hertford
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. Hertford County's initial closure cost for the transfer station was approved
on June 2, 2023 for the amount of $89,300.00. The approval notice can be found on our
Laserfiche document repository at FID 1801845 .
The table below represents a timeline of when Hertford 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 Hertford County's
based on Hertford County's
based on Hertford 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.mmEnamnm.maouafty /� 919.707.8200
Financial Assurance Requirements for Hertford County Owned Transfer Station,
Permit Number 4602 T- TRA NSFER-1 995
Annual Financial Assurance Requirements and Electronic Submittal
June 15, 2023
Page 2 of 4
When Hertford 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.gov/swsfa.
Local Government and Municipality Mechanisms
Hertford County can choose either a local government test based on Hertford County's ratios of
financial strength or bond ratio financial strength. The financial information entered into this test
is based on Hertford County, not the transfer station's financial strength. That is why the local
government test is due after Hertford County 's financial audit is complete for the fiscal year. If
Hertford County's financial audit is not completed by December 315t, the Section would request
Hertford County submit a request for an extension for the mechanism submittal.
Hertford County can also choose to use a capital reserve. This is where Hertford 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.deq.nc.gov/Forms/FA FinAssurance .
Annual Requirements
On an annual basis until the transfer station has received a closure permit from the Section,
Hertford 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.deq.nc.gov/swsfa. This inflation multiplier should be applied to the
previous year's closure cost shown within Hertford County's chosen mechanism.
• Should Hertford 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 Hertford County Owned Transfer Station,
Permit Number 4602T-TRANSFER-1995
Annual Financial Assurance Requirements and Electronic Submittal
June 15, 2023
Page 3 of 4
Should Hertford 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 Hertford 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.gov . Should
Hertford 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 Mouton
DN
f E 5-,——NC
Mouton, o=DWMSolid Waste
Section, NC Department nvironmental
Qu,hty,email--h.moutos@ncdenr.go c=US
Date: 2023.06.151557'.56-04'00'
Sarah Moutos
Environmental Program Consultant
Division of Waste Management — Solid Waste Section
ec: Ashley Jilcott, Public Works Director
David Cotton, County Manager
Sherri Stanley, SWS
Deana Yitbarek, SWS