0106_CarolinaResourceRecovery_LCID_T&P_Comment_onApp_DIN28751_20180215

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Chao, Ming-tai
From:Chao, Ming-tai
Sent:Thursday, February 15, 2018 3:49 PM
To:'[e-mail]'
Cc:'[e-mail]'; Patrone, John
Subject:Comments on the permit application, Carolina Resource Recovery, T&P, 0106-TP-2012
Dear Mr. Scott:

DIN 28751

The Solid Waste Section completes a review of the permit amendment application for the above -referenced
facility (DIN 8741) and have some comments on the application stated below:

Site Design and Operations
1. Please clarify the following concerns regarding receipt of uncontaminated soil at the facility.
a. Please describe the waste screening program to identify/characterize the received soil/earthen
material is not contaminated by low concentration solvents or chemicals. For example, how do you
know the earthen material is not coming from environmental remedial programs – UST removal or
Brown Field Projects.

b. Have the operator or employee(s) been trained through a creditable training program to identify if
the earthen material is free of contamination?

c. Will the soil/earthen material be stockpiled at other treatment & processing areas or product storage
area described in the permit application?

d. How to use the screened soil/earthen material? Sale to public and or use for a component for passive
compost at the facility, please clarify.

2. The third paragraph states that “The majority of the area is used to segregate incoming wastes prior to
processing…” The treatment and processing area on Figure 1 consists of two tracts of land - 7.7 acres
and 2.8 acres. Where is the majority area located? Please clarify.

3. What is the maximum capacity of the unprocessed/untreated wastes including inert debris at the facility
at any time?

4. What is the maximum capacity of the finished products including processed inert debris at the facility at
any time?
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The finished products is not subject to North Carolina Solid Waste Management Rule 15A NCAC 13B
only if the facility complies with NCGS 130A-309.5(c) [which can be found at the following web link:
https://www.ncleg.net/EnactedLegislation/Statutes/HTML/ByArticle/Chapter_130A/Article_9.html]. If
the permittee doesn’t want a permit condition or conditions to regulate the finished products at the
facility through the new permit, please add the requirements in the statute to the permit application.

5. According to February 2, 2017 Facility Compliance Inspection Report of the facility, material received
is formed into piles allowing vegetation to grow atop and left to compost in-place. Evidently, the
facility is conducting a unique approach or approaches for passive compost at the designated
areas. Please describe the maximum time to cure the waste becoming marketable final products. If the
required time is more than a year, the permittee shall request the SWS for an approval. Please also
respond the following questions:
i. Descriptions and protocols of the unique passive compost.
ii. The required curing time to generate the finished product for sale.
iii. If the facility can’t annually remove seventy-five percent (75%), by weight or volume, of the
stored finished products from the facility through sale, use, or reuse according to the NCGS
130A-309.05(c), the permittee must propose the maximum storage period at the facility for
approval. Please add the following statement to the operating plan – “Failure to comply this
requirement, the owner and operator of the facility will to take compliance action or permit
revocation.”

6. (The Fifth Paragraph) Screening and load-out area are mentioned in this paragraph and shown on Figure
3. Please describe the screening activities at this location. What kind wastes or products will be treated
or stored at this location?

7. (The Six Paragraph) Because the area for waste treating and processing are surrounded by on-site
drainage features, pursuant to Rule 15A NCAC 13B .0302(3), the waste grinding and soil screening
processes should not be conducted in the rain. Please add this requirement to this section.
Operating Plan
8. Storm debris operations are stated in the plan. In fact, the conditional approved Temporary Disaster
Debris Staging Site (TDDSS), DS01-001 is only allowed to receive permitted waste stream - vegetative
storm debris after the site is activated during an emergency event. Activation must be requested and
received from the Regional Environmental Senior Specialist for the facility. During the normal days, the TDDSS
shall not be operational. To avoid confusion, please move operations regarding storm debris to a
designated section in the plan.

9. (Item 3) The plan states “Reusable inert materials such as brick or stone may be transported to
neighboring Scott Stone, Inc., if a market for such material exists.” Please address the following
concerns:
i. How long will the marketable inert debris in Item 3 be stored/stockpiled at the facility prior to
transporting to the off-site facility.
ii. Note the stockpile area on the drawing of the application.
iii. How to disposal of or reuse the inert debris - brick or stone, if the market no longer exists?
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10. (Item 5) The stockpile dimensions and aisle distance of “storm debris” piles specify in begining sentence
of this subsection are different from those in the item 5 and in the fifth paragraph of “Site Design And
Operations.” Please clarify and make necessary correction.

11. (Item 5) Please provide the maximum capacity of the screening and load-out area in the third paragraph
of this subsection.

12. (Item 6) Please identify the facility or facilities will receive the non-conforming wastes temporarily
stored at the facility.

13. (Item 10) Please note the BMP types and add the locations of the described BMPs to the site plan
drawing.

14. (Item 12) Please add the following requirements for the fire prevention and reporting a fire incident:
a. If the passive compost is conducting at the facility, please describe the temperature monitoring
program including the designated person to take on this task, the frequency and measurement
protocol, actions to prevent spontaneous combustion from stockpiles in the event of elevated
temperature observed, and requirements of documentations/records.
b. Open burning of solid waste is prohibited at the facility.
c. Fires must be reported to the regional Environmental Senior Specialist with 24 hours or the
occurrence, followed by a written notification within 15 calendar days of the occurrence. The Solid
Waste Section has the standard form can be used for reporting a fire; the form can be downloaded
from the following web link
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Forms/FireOccurrenceReport.pdf.
Please download the form and append to the permit application.
Please contact myself if you have any questions or require further clarification of the above-mentioned
comments. Thank you and have a wonderful day.

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
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