8607_NewRiverTire_TP_2ndTechnicalReview_DIN27676_20170505

ROY COOPER
Governor
MICHAEL S. REGAN
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

May 5, 2017

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

Subject: Second Technical Review Letter
New River Tire Recycling Facility
Surry County, Permit # 8607-TIRETP-2013, Document ID 27676

Mr. Bryant,

The Division of Waste Management, Solid Waste Section (Section) has completed the technical
review of your revised application submittal titled Application for Permit for a Scrap Tire
Collection and Processing Facility (DIN 27525). The revised application was submitted by email
and was received in the Asheville Regional Office on March 15, 2017.

Unfortunately, the revised application did not provide all the information identified in the first
Technical Review Letter (DIN 27309) as necessary for completing the permitting activity. As a
result, we request you provide a response to each of the items listed below or update the application
as necessary:
1. We recommend adding a revision date to the front page of the application to easily
distinguish subsequent revisions from the original.
2. Section 1.5, in providing information to satisfy NCAC 13B.1106(d)(6), states New River
Tire Recycling receives around 1250 tons/month of waste tires from North Carolina,
Virginia, Tennessee, and South Carolina. The maximum amount of waste tires and/or
processed tires allowed onsite at one time is 1300 tons. However, the Rule also requires
the quantity of tires to be shipped off-site per month to be included. This section must be
updated to include the quantity of tires to be shipped off-site per month.
3. Section 2.9 states The below grade area is noted on the site map (appendix K). It is a
loading area and dock areas that are cut out of the natural land and paved with concrete
or asphalt. The area is estimated to hold 300,000 gallons in which it would be pumped if
it were to get full. The area indicated on the site map (Appendix K) shows one drain within
the temporary water storage area. However, previous inspections have noted drains in the
curb that may fall within the noted area. Please verify the location of these curb drains and
update the drawing if they are within the noted area.
4. Section 3.3, in providing information to satisfy 15A NCAC13B.1107(2)(b), states Fire
lanes measuring 50 feet in width will be established around the perimeter of scrap tire
piles 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,
Mr. Ben Bryant 
Second Technical Review Letter 
May 5, 2017 
Page 2 of 2 
Batterymarch Park, Quincy, Massachusetts, which has been adopted in accordance with
G.S. 150B-14(c). See appendix M.
a. NFPA 231D is specific to the storage of tires indoors, but all of the tire storage piles
shown on the Appendix M drawing are outdoors. If this is the case, the NFPA
231D reference does not apply;
b. No scale is provided on the Appendix M drawing;
c. As previously stated, the Rule requires a 50-foot wide fire lane be placed around
the perimeter of each scrap tire pile and this requirement is now stated in Section
3.3. However, many of the storage piles shown on the Appendix M drawing are
shown being placed directly against a wall or walls. Additionally, the given
dimension between many of these piles is a minimum of 40-feet. The placement
of the piles against walls, and the separation distance of 40-feet, is in conflict with
the Rule required 50-foot wide fire lane around the perimeter of the pile;
d. There is a note on the drawing stating SEPARATION DISTANCE BETWEEN
GROUPS OF 150,000 CUBIC FOOT PILE AREAS is a minimum of 75-feet.
However, there is another note stating MAXIMUM 50,000 CUBIC FOOT PILE
SIZE WITH HEIGHT NO GREATER THAN 10-FEET (TYPICAL OF OUTDOOR
STORAGE PILES). The note referencing 150,000-cubic foot pile areas seems to
be in conflict with the 50,000-cubic foot pile area note and the limit stated in Section
3.2.
5. 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.

If you should have any questions regarding this matter please contact me at [phone], or
by email at [e-mail] .

Sincerely,
Allen Gaither
Environmental Engineer

CC: Mr. Charles Gerstell – SWS/MRO