8607_NewRiverTire_TP_TechnicalReview_DIN27309_20170213

February 13, 2017

Sent Via Email – [e-mail]
Mr. Ben Bryant
Owner
312 East Highway 52 Bypass
Pilot Mountain, North Carolina 27041

Subject: Technical Review Letter
New River Tire Recycling Facility
Surry County, Permit # 8607‐TIRETP‐2013, Document ID 27309

Mr. Bryant,

The Division of Waste Management, Solid Waste Section (Section) has completed the
technical review your application submittal titled Application for Permit for a Scrap Tire
Collection and Processing Facility (DIN 27013). The application was submitted to the Section
on November 10, 2016 and received in the Asheville Regional Office on November 16, 2016.

Based on this review, the Section requires clarification or additional information in order to
complete the permitting activity. Please provide a response to each of the items listed below:
1. Section 1.0 states New River Tire Recycling LLC has operated a scrap tire processing
facility in Hillsville VA for 4 years under a VA DEQ Permit by Rule. Due to market demand
New River Tire Recycling LLC has decided to relocate the entire operation to North
Carolina, and apply for a permit through the North Carolina Department of Environment
and Natural Resources. Given New River Tire Recycling LLC has been permitted and
operating in North Carolina for three years, we recommend changing this language to
reflect a permit renewal versus a new permit.
2. Sections 1.1 and 1.2 show the facility address as 312 E Hwy 52. However, the Surry
County GIS website shows the address is 312 E Hwy 52 Bypass. Please verify the proper
street address and revise as necessary.
3. Section 1.4 discuss the operations regarding the management of scrap tires and processed
rubber. However, previous inspections have noted significant amounts of comingled
municipal waste on site as well as demolition debris from the removal of the roof. As it is
understood the municipal wastes come into the facility with the scrap tires and the building
demolition is to continue for some unspecified time, management of both of these wastes
must be added to the discussion of facility operations.
4. Section 1.5, in providing information to satisfy NCAC 13B.1106(d)(6), states New River
Tire Recycling receives around 1,000 tons of waste tires per month. Most tires received
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Technical Review Letter
February 13, 2017
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are from North Carolina, but some of the tires received are from Virginia, Tennessee or
South Carolina. However, the Rule also requires the quantity of tires to be stored on-site
and quantity of tires to be shipped off-site per month to be included. This section must be
updated to include the required quantities.
5. Section 1.7 states New River Tire Recycling LLC anticipates starting the collection and
processing operation on October 23, 2013, pending receiving the permit from DENR.
Given the facility was initially issued a Permit to Construct and Operate on December 20,
2013, this information should either be updated or deleted.
6. Section 1.8 appears to have some error in the address for the disposal site. The street
number, some punctuation and the first letter in the state abbreviation all appear as empty
squares. Please ensure this is information displayed correctly in the electronic copy.
7. Section 2.5, in providing information to satisfy NCAC 13B.1106(c)(5), states All drainage
will fall under Storm Water Permit # NCG050416. However, the Rule requires drainage
to be effective in preventing standing water on-site and previous inspections have noted
significant standing water on-site. This section must be updated to include contingency
plans for managing standing water on-site.
8. Section 2.9 states After the drains are bermed, there is sufficient surface area that is below
grade to encapsulate extremely high volumes of liquid that could be pumped or skimmed
and treated if necessary. The below grade surface area needs to be explained in greater
detail including the original purpose, number of inlets, number of outlets, material
construction, estimated volume and a contingency plan in case the storage gets full.
9. Section 3.2 accurately states the Solid Waste Rule size limitation on outdoor scrap tire piles
as no greater than 200 feet in length, 50 feet in width and 15 feet in height. However,
Section 2505.1 of the North Carolina Fire Code requires that outdoor storage tire piles not
exceed 5,000 square feet of continuous area or 50,000 cubic feet in volume or 10 feet in
height.
10. Section 3.3, in providing information to satisfy 15A NCAC13B.1107(2)(b), states Fire
lanes will be established according to conditions that meet those in "The Standard for
Storage of Rubber Tires", NFPA 231D-1986 edition, published by the National Fire
Protection Association, Batterymarch Park, Quincy, Massachusetts, which has been
adopted in accordance with G.S. 150B-14(c). However, the Rule requires a 50-foot wide
fire lane be placed around the perimeter of each scrap tire pile. This section must be
updated to include the 50-foot wide fire lane. Additionally, given the scrap tire storage is
managed within the walls of an old building, a site plan, drawn to scale, must be added to
the application to clearly delineate the scrap tire storage piles, the 50-foot wide fire lane
around the perimeter of each scrap tire pile and the building walls.
11. Section 3.4, in providing information to satisfy 15A NCAC13B.1107(2)(c), states New
River Tire Recycling LLC will control mosquitoes and rodents so as to protect the public
health and welfare. Whole and sliced scrap tires, and other scrap tires capable of holding
water will be covered upon receipt with a water shedding material or disposed of,
processed or removed from the site within ten days of receipt. However, previous
inspections have noted significant mosquito activity on-site and the August 19, 2016
inspection report requested the development of an abatement program. This section must
be updated to include the mosquito abatement program.
12. Section 3.10 merely restates the requirements of 15A NCAC13B.1107(2)(i). However,
there is an Emergency Preparedness Manual included in the Appendix that includes the
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Technical Review Letter
February 13, 2017
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required information. Section 3.10 should either refer to the Appendix or be updated to
include the required information. Additionally, please verify the Maintenance and Plant
Manager Phone numbers in the Manual as they appear to be very similar.
13. Section 3.14 merely restates the requirements of 15A NCAC13B.1107(3). This section
must be updated to include a discussion on how the temperature of processed material is
monitored and the steps to be taken if the temperature exceeds the limit specified in the
Rule. Additionally, the Rule requires tire residuals to be maintained on site and previous
inspections have noted significant amounts of residuals on the ground on the south side of
the building in close proximity to storm drain inlets. This section must also be updated to
include a discussion on how the facility will prevent residuals from leaving the site in an
uncontrolled manner.
14. Multiple sections in the application reference information in the appendices by letter.
However, none of the information in the appendices is marked with the corresponding
letter. For clarity, all attachments in the appendices should be identified with the
appropriate letter.

If you should have any questions regarding this matter please contact me at (828) 296‐
4703, or by email at [e-mail] .

Sincerely,
Allen Gaither
Environmental Engineer

CC: Mr. Charles Gerstell – SWS/MRO