7603T_RandolphCoTransfer_commentsonApplication_DIN28451_20170908

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Chao, Ming-tai
From:Chao, Ming-tai
Sent:Friday, September 08, 2017 11:48 AM
To:'Moore, Daniel'
Cc:'Arthurs, Paxton G.'; Patrone, John; 'McFeeley, Michael'; 'Workman, John'; 'Carroll,
Shawn'; Aja, Deborah
Subject:Comments on Permit Renewal - Randolph County Transfer Station – Permit No. 7603T-
TRANSFER-1997
Hi Dan:

DIN 28451
I have completed a review of the Permit Application (Application) for Randolph County Transfer Station;
below are the comments on the application. John Patron may send out his comment, if any.

1. (Section 1- Facility Location and Description) Please provide the following info to the section:
i. Please provide the contact info of the land owner [Randolph County (the County)] and operator
[Waste Management of Carolinas, Inc. (WM)] of the facility; the requested info includes name,
mailing address, e-mail address, and phone number.

ii. Please append the land property deed info to the permit application.

iii. The facility collects scrap tire; therefore, please state in the Application that the tire collection
and temporary storage area shall be operated in compliance with Rule 15A NCAC 13B. 1107.

2. (Section 4 – Operational Procedures)
i. (Housekeeping & Vector Control) Please describe the daily cleaning method(s) – broom sweep,
power pressure washing, etc. Please special attention waste removal and daily cleaning behind
the push wall, floor drain/trench, a sump (or pit strainer on Site Plan drawing).

ii. (Housekeeping & Vector Control, third paragraph on Page 4)
a. The Facility Compliance Inspection Report for the facility dated April 25, 2017 indicated that
there is no floor drain in the tipping floor and loading bay. Please detail the leachate removal
and management in this sub-section: how are the pump station and pit strainer on the Site
Plan drawing relating to the leachate management of the facility?

b. Please describe the function of the pump station (as shown the Site Plan drawing) related to
the leachate management at the facility.

c. If there is a holding tank associated with the pump station, please describe the size of the tank
and frequency for inspection and maintenance (sludge removal) of the leachate tank and the
sump (pit strainer).

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iii. (Recyclable Materials) The Facility Compliance Inspection Report for the facility dated April 25,
2017 indicated that the facility received and temporarily stored used oil/oil filter, antifreeze,
battery, white goods, electronic wastes (this is also posting on the County’s website), etc. Please
provide the waste operation & management procedures for the recyclable including the
maximum storage volume and duration at the facility. For white goods contain
chlorofluorocarbons (Freon), the plan must describe the Freon removal and handling.

iv. (Treatment & Processing – Wood Grinding) please provide the information of this unit.
a. The description of the unit size (in acreage), the maximum volume (both processed/ground
material and unprocessed waste) will be stored on site at any time. For operating a yard
waste unit without a permit or being a port of the life-of-site permit issued to the transfer
station, the unit must be classified as a Yard Waste Notification Site which has he maximum
two (2)-acre in size, and a volume of storage up to 6,000 cubic yards (both processed/ground
material and unprocessed waste) per quarter (three-month period).

b. A stockpile or windrow (both processed/ground material and unprocessed waste) must
maintain 25-feet minimum clearance between the other stockpile or windrow and swales or
berms to allow access for firefighting equipment.

c. Operation of the yard waste unit without composting must comply Rule 15A NCAC 13B
.1402(g)(3).

d. Operation of the yard waste unit with composting which is not distributed to general public
must comply Rules 15A NCAC 13B .1402(g)(3) & 1406(10).

e. If the unit has size or volume exceed those stated above, the County and WM must apply for
a separate solid waste treatment and processing permit to operate the Yard Waste Unit which
must be renewal every 5 years.

3. (Section 5 – Random Inspections) This paragraph must describe the procedures and actions (including
the reporting requirements) to be taken for handling and managing the non-conformance or prohibited
wastes.

4. (Section 6 – Emergency Response Procedure and Equipment) Please describe the procedures to
handle/manage “hot load” in the following scenario – approaching the gate/scale house, inside the
facility, inside the transfer building/on tipping floor.

5. (Site Plan) Please indicate/note the requested info on the drawing.
i. The locations of the miscellanea waste management/recycling units; the units include scrap tire,
white goods, electronic wastes, wood waste treatment & processing area, etc.

ii. The leachate piping run inside the facility and the location (or manhole) where the leachate line
drains to the City-owned sewer system.
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Please send the Solid Waste Section a copy (one hard copy and one electronic copy) of the written responses
and the final Permit Application. If you have any questions of the above-mentioned comments, please contact
myself. Have a wonderful weekend.

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.

From: Chao, Ming-tai
Sent: Tuesday, September 05, 2017 10:59 AM
To: 'Moore, Daniel' <[e-mail]>
Cc: Arthurs, Paxton G. <[e-mail]>; Patrone, John <[e-mail]>; McFeeley,
Michael <[e-mail]>; Workman, John <[e-mail]>; Carroll, Shawn <[e-mail]>
Subject: RE: Request for Permit Renewal - Randolph County Transfer Station – Permit No. 7603T-TRANSFER-1997

Hi Dan:

I got your email and an electronic copy of the submittal (Operations Plan) for a 10-yr permit renewal for the
above-referenced transfer station. The document is uploaded to the tracking system with a Document
Identification Number (DIN 28441). After quick scan of the submittal and the cover letter, I have to inform you
several things about transfer station permit renewal requirements. They are:

1. No permit application fee is required; the fee is incorporating into the annual fee (NCGS 130A-
295.8(d1)). So the Solid Waste Section will not issue Waste Management of Carolinas, Inc. (WM) the
fee invoice for this permit application review.

2. Pursuant to NCGS 130A -294.(a2), the Solid Waste Section must issue a life-of-site permit to a permit
applicant when the existing permit is subject to a renewal and if the permit application meet the
applicable requirements stated in the regulations, rules and statutes. The referenced statute states below:

§ 130A-294. Solid waste management program
(a2) Permits for sanitary landfills and transfer stations shall be issued for the life-of-site of the
facility unless revoked as otherwise provided under this Article or upon the expiration of any local
government franchise required for the facility pursuant to subsection (b1) of this section. For purposes
of this section, "life-of-site" means the period from the initial receipt of solid waste at the facility until
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the Department approves final closure of the facility. Permits issued pursuant to this subsection shall
take into account the duration of any permits previously issued for the facility and the remaining
capacity at the facility.

3. Pursuant to Solid Waste Management Rule (Rule) 15A NCAC 13B .0207(a), (e), & (f), WM must
submit the life-of-site permit application which shall include the minimum requirements stated in the
rules. For your reference, the excerpts of the Rule are stated below:

15A NCAC 13B .0207 LIFE-OF-SITE PERMIT ISSUED FOR A SANITARY LANDFILL OR
TRANSFER STATION
(a) A new or existing sanitary landfill or transfer station permit shall be subject to Section .0400, .0500,
or .1600 of this Subchapter and shall be for the life-of-site as defined in G.S. 130A-294(a2).
(e) A life-of-site permit application for a new transfer station shall conform to the requirements of Section
.0400 of this Subchapter and shall contain a site plan for the life of the site. A specification of the life-of-
site of a transfer station shall be quantified in the site plan prepared in accordance with Section .0400 of
this Subchapter.
(f) A transfer facility that has an existing permit as of July 1, 2016 shall be approved for a life-of-site
permit upon submittal of a written request that shall include a specification of the quantified life-of-site.
History Note: Authority G.S. 130A-294; S.L. 2015-286, s. 4.9;
Eff. March 16, 2017.

4. Please submit a copy of the current franchise agreement between Randolph County and WM. The
NCGS 130A-295.4(a2) defines the term/expiration date of the life-of-site permit (see the red line above).
The permit expiration date of the new permit for your transfer station is the same date as the expiration
date of the current Franchise Agreement. Prior to reaching the expiration date of the franchise
agreement, WM can always request a new life-of-site permit if the new franchise agreement is obtained.

Since the life-of-site permit will be issued to WM and Randolph County, the Solid Waste Section (SWS) will
request more documents which were or might be submitted to the SWS previously but not available in the SWS
file/record/document system. These documents may include the property deed, the recorded permit, the zoning
approval document, the leachate draining system (floor drain, piping layout, leachate sump/pump, and/or
discharge point to the City/County-owned sewer system), etc. To complete the file/document pertaining to the
permit application will assist the permit reviewer to conduct the future permit reviewing processes, when the
new-term (30-yr or 60-yr) franchise agreement is required.

Best regards,

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
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http://portal.ncdenr.org/web/wm/sw

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.

From: Moore, Daniel [mailto:[e-mail]]
Sent: Friday, September 01, 2017 4:45 PM
To: Chao, Ming-tai <[e-mail]>
Cc: Arthurs, Paxton G. <[e-mail]>; Patrone, John <[e-mail]>; McFeeley,
Michael <[e-mail]>; Workman, John <[e-mail]>; Carroll, Shawn <[e-mail]>
Subject: Request for Permit Renewal - Randolph County Transfer Station – Permit No. 7603T-TRANSFER-1997

Ming,

Good afternoon. Please see the attached request for a Randolph County Transfer Station permit
renewal. According to our (Randolph County-Owner/Waste Management-Operator) current permit, a
renewal application must be submitted on or before September 10, 2017, for the permit which is due to
expire in March 2018. A hard copy of this request with the original signatures is being sent to your attention
by certified mail.

As you and/or your staff review this request, please do not hesitate to contact me with any questions or
concerns that you may have.

Thank you,

Dan Moore, PG
Environmental Protection Manager
[e-mail]

Waste Management – North Carolina/South Carolina
3303 N Glenn Ave
Winston-Salem, NC 27105
Cell [phone]

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