8607_NewRiverTireTP_DebrisTCLPResponse_DIN27128_20161208

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary

MICHAEL SCOTT
Director
State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T

December 8, 2016

Mr. Ben Bryant
New River Tire Recycling, LLC
Post Office Box 1752
Pilot Mountain, NC 27041

Re: Bulk Materials Sampling for TCLP
New River Tire Recycling, LLC
Permit ID # 8607-TIRETP-2013
Surry County

Dear Mr. Bryant:

The Solid Waste Section (Section) has reviewed the Bulk Materials Sampling for TCLP report for the New
River Tire Recycling facility prepared by Pilot Environmental Inc. (PEI). New River Tire received a Notice
of Violation from the Section on November 4, 2016 due to improper disposal of solid waste. Three piles
of debris material consisting of cinder block, brick, and concrete were identified on-site during facility
inspections on August 3, 2016 and October 12, 2016. The material originated from dilapidated on-site
buildings and was proposed to be used as fill within the property. In order to determine if the material
would be suitable as on-site fill, PEI collected discreet samples within each individual pile to create three
composite samples. The samples were identified as S-1 through S-3 and were analyzed for Toxicity
Characteristic Leachate Procedure (TCLP) of the eight Resource Conservation and Recovery Act (RCRA)
metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver).

The Section determines if material is suitable for beneficial fill by comparing the TCLP analytical results
to the standards established in 15A NCAC 02L .0202 (2L Standards) thereby, ensuring the protection of
groundwater. Based on the TCLP analytical results, arsenic was the only RCRA metal reported at a
concentration above the 2L Standards. The arsenic 2L Standard was exceeded in the S-1 sample, so the
debris in the S-1 sample location must be removed from the site. The material where S-2 and S-3 were
collected can remain on-site as fill since constituent concentrations were not reported above the 2L
Standards at those locations.

Please contact me at [phone] or by e-mail at [e-mail] if you have any questions or
concerns regarding this letter. Thank you in advance for your cooperation in this matter.

Sincerely,

Ervin Lane
Compliance Hydrogeologist
Solid Waste Section

State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T

cc: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Charles T. Gerstell, Environmental Senior Specialist