HomeMy WebLinkAbout18018_Singer Furniture_HWSA Permit Renewal Application_19991005Mr. Qualls
Page2
October 5, 1999
is an outlin1; of what the FMB expects to be in Singer's HSWA-only permit renewal application.
This outline is provided as a guide for Singer to follow in preparing a revised pe.nnit application.
Th~ outline consists of "Parts" A, B, J, K, L, and N rrom a typical RCRA hazardous waste permit
application. In addition, attached to this letter are checklists for the "Parts" listed below that are
required to be in Singer's HSWA-only pennit application.
HSWA-ONL Y PERMIT APPLICATION OUTLINE
Part A
EPA Form 8700-23 (Rev. 10/09/98). See Checklist
PartB
Facility Description. See Checklist.
In addition to the checklist, Singer Furniture must include in Part B:
PartJ
PartK
Part L
PartN
The former and current nature of business at the Singer Facility.
Complete and detailed listing of hazardous wastes Singer generated, treated,
stored, or disposed at the facility
Brief summary of the regulatory history for the facility.
Other Federal Laws. See Checklist.
Certification. See Chr;cklist.
Information Requirements for Solid Waste Management Units. See checklist.
This part must include a brief swnmary of all sampling and laboratory analysis of ground
water, land surface and subsurface strata, surface water, sediment, and air that has been
conducted to date at each SWMU. The swnmary should include tables showing only the
contaminants detected (including flagged data) at each SWMU. In addition, a brief
summary must be provided that discusses the lateral and vertical e>..ient of all
contaminants detected in ground water, land surface and subsurface strata, surface wate.r,
sediment, and air at each SWMU.
Substantial Compliance and Financial Qualification. See ch~cklist.
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Mr. Qualls
Page 3
October 5, 1999
SPECIFIC COMMENTS
Part A -Application
[40 CFR 270 as adopted in l5A NCAC 13A .0113]
Section XI
1. Singer must include the current.nature of business at the facility. Singer may indicate the
past nature of business as well. (40 CFR 270.13 (m)]
Sectio1~ XII, XIII, and XIV
2. These sections should be left blank since Singer Furniture no longer treats, stores, or
disposes of hazardous waste at the site. [40 CFR 270.13 (a), (i), (j), (n)]
Section XVII
3. Singer must provide a date for the aerial photograph presented in Figure 5. [40 CFR
270.13 (h) (2)]
Part B -Facility Description
(40 CFR 270 as adopted in 15A NCAC l3A .0113]
General Description
4. This section in Part B must include the full facility name and the name of the owner. (40
CFR 270.14 (b) (1))
Topographic Map
5. A legend must be included that clearly shows what the different symbols and lines on the
map represent. For instance, the property boundary should be clearly marked and
labelled. On Figure 3 the property boundary for the Singer facility is shown with a line
of the same width and color as lines used to show other features and property boundaries.
[40 CFR 270.14 (b) (19) (vii))
6. The exact location of SWMUs 3 and 9 are not clearly shown on the map. If possible, the
outline of the SWMUs should be shown to illustrate the size' of each SWMU. Additional
or inset maps showing a "blow-up" of these two areas would be helpful in depicting the
exact location of the SWMUs and their relationship to the sampling locations. (40 CFR
270.14 (d) (I) (i)J
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Mr. Qualls
Page 4
October 5, 1999
Floodplain Standard
7. Singer must provide background infonnation on the Universal Soil Loss Equation
(USLE) and must discuss why it is applicable for this facility. The USLE must be
provided and the calculations must be presented in the application. At this time it is
unclear what all the factors are in the USLE. In addition, it is unclear where the numbers
used in the USLE came from, how they were derived, and why they '1.re applicable. [ 40
CFR270.14(b)(l9)(ii)] · ..
PART J -Other Federal Laws
[40 Cffi. 270 as adopted in 15A NCAC 13A .0113]
8. Singer must supply the sources of the infOIBlation presented in the application concerning
other federal laws. [40 CFR 270.1 and 270.14 (b) (20)]
The above information as well as that in the attached checklists is required to be in the
application resubmittal. All information contained in Singer's February 3, 1998 submittal that
does not apply to the "Parts" listed in the "HSWA-Only Permit Application Outline" section
above, must be removed from the revised application. If Singer believes chat additional
infonnation is needed to provide a more complete application or has any questions concerning
this letter, please feel free to contact Craig Ehde at (919) 733·2178, extension 211 to discuss your
concerns. Singer must resubmit eight copies of the HS WA-only permit application, following
the above outline, by November 8, 1999. Once the resubmittal has been received by the FMB, it
will be reviewed in its entirety.
Sincerely, c?t~ i~i;~ement Branch
Attaclunent
cc:
re:
Narindar Kumar, US EPA, Region 4
Jesse Wells, Asheville Regional Office
·r.P.eter~l1fill>,o:cw:r;j K~tli·i;~'n'.'Z:'tawson !j~
Robert GlasJ? {y
Surabhi K. sh"ah
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