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LIQUID ENVIRONMENTAL SOLUTIONS
7651 Esters Blvd., Suite 200, Irving, TX 75063
214-524-6050/ Customer Service 866-694-7327
February 20, 2017
Mr. Tony Gallagher, Branch Head
Composting and Land Application Branch
1646 Mail Service Road
Raleigh, NC 27699‐1646
RE: Notice of Violation Response for Liquid Environmental Solutions Winston Salem Facility
Mr. Gallagher,
Please accept this letter as our formal response to the Notice of Violation that we received from
the Division of Waste Management‐ Solid Waste Section dated February 16, 2017. As discussed
in our previous meeting in November with Forsyth County, and mentioned in the follow‐up
response letter from LES to the Department on November 16, 2016, LES was aware of the
facilities past odor complaints when the facility was purchased in October 2016. In order to
correct this issue, LES has worked with several consultants over the past few months to develop
a plan to mitigate odor emissions from the facility. The following action items have been
identified below. Pending a timely approval from the department, the following corrective
action schedule is proposed below:
1. LES operates several grease recovery plants around the country. The last stage in our
other operations requires the use of a Tricanter to separate grease from the incoming
material. The Winston Salem Plant was designed to have a Cooker after the Tricanter to
help polish grease recovery. This requires additional heating of the product, which leads
to increased odor production. The plant is currently under minor modification to bring
the processing of grease more in line with our other plants, which will eliminate the
need of the cooker. Materials to complete this process have already been procured and
have started to arrive at the site. Installation of the modifications are expected to be
done by the end of March 2017, at this time we would expect to be able to shut down
the Cooker. The modifications to the plant do not fundamentally change the function of
the plant, but rather gives us better process control.
2. Currently (1) scrubber is installed at the facility and is rated at 5,000 scfm. While this is
a useful and correct piece of equipment for treating odors, the current scrubber is
undersized to handle all odor production in the facility. LES will be procuring and
installing an additional 8,000 scfm scrubber. The additional scrubber capacity will pull a
negative pressure on the building, thus drawing fresh air in, treating all air being
expelled, and not allowing odors to seep from the building and off the property. The
completion of this project is schedule to be completed by the end of May 2017.
3. The Odor and Vector Control plan will be updated to include the utilization of the 8,000
scfm scrubber for odor controls.
LIQUID ENVIRONMENTAL SOLUTIONS
7651 Esters Blvd., Suite 200, Irving, TX 75063
214-524-6050/ Customer Service 866-694-7327
LES is committed to resolving this issue and is allocating significant resources to be
environmentally responsible. Please do not hesitate to contact me if you have any questions or
concerns.
Best Regards,
Josh Hanlon
Regional Processing Manager
Liquid Environmental Solutions
Mobile: 508‐577‐8347
Cc: Troy Harrison‐ Division of Waste Management‐ Solid Waste Division
Corrine Law‐ Composting and Land Application Branch
Connie Wylie‐ Composting and Land Application Branch
Sarah Rice‐ Compliance Officer, NC Solid Waste Section
Michael Settle‐ Forsyth County
Stephen Berry‐ Forsyth County
Daniel Seagraves‐ Forsyth County