0106_CarolinaResourceRecovery_responsestocomments_DIN28806_20180425

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Chao, Ming-tai
From:Kimberly Ho <[e-mail]>
Sent:Wednesday, April 25, 2018 2:33 PM
To:Chao, Ming-tai
Cc:Linda Scott
Subject:[External] RE: Comments on the permit application, Carolina Resource Recovery, T&P,
0106-TP-2012
Attachments:Permit renewal letter rev Apr.docx; application - Operating Plan.docx; application -
Facility overview.docx
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Report Spam.

Good afternoon Mr. Chao,

Thank you so much for taking our calls and answering some of our questions on the below. I have inserted some
answers below (in blue) and have attached our amended application narrative, the Operation Plan, and the Facility
overview with the changes you advised marked in blue as well.

Please review and let me know if this is acceptable or if you have further questions or concerns. If application in now
correct, I will remove highlights and re-send complete package including fire form.

We want to make sure we meet all NCDEQ requirements.

Thank you,

Kimberly L. Ho

Credit Manager & Accounting
Scott Stone, Inc.
P: [phone] x313
F: [phone]

From: Chao, Ming-tai [mailto:[e-mail]]
Sent: Thursday, February 15, 2018 3:49 PM
To: Linda Scott <[e-mail]>
Cc: Kimberly Ho <[e-mail]>; Patrone, John <[e-mail]>
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:
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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. Materials are picked up from pre-qualified undeveloped/uncontaminated
land-clearing sites, home building sites/woods. Previously developed properties are considered
unqualified and materials are not accepted. Any soil or earthen materials are incidental to the land
clearing debris (tree limbs) that are hauled to the site. Soil is not independently collected, stored, or
treated at this time.

b. Have the operator or employee(s) been trained through a creditable training program to identify if
the earthen material is free of contamination? We have not felt the need to address adequate training
of on-site staff as we have guidelines in place indicating no man-made/contaminated sites should be
allowed access to the facilities.

c. Will the soil/earthen material be stockpiled at other treatment & processing areas or product storage
area described in the permit application? Soil/earthen materials are not currently being
accepted. Any of these incidental materials coming to the site will be stored as described in 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. We are currently no longer passive composting for sale or
other. We are not currently accepting any loads of soil/earthen material. Should we look to change
that we will address procedures with NCDEQ prior to starting a screening process to make sure we
are in compliance.

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. The majority location for sorting is the
2.8 acres.

3. What is the maximum capacity of the unprocessed/untreated wastes including inert debris at the facility
at any time? We have never reached capacity, as such we are unsure how to clarify this answer. All
materials will be stored as outlined in our permit #5. If at any point capacity is reached, it will be based
on no further area to store per permit specifications. We roughly estimate about 6,000 cyds.

4. What is the maximum capacity of the finished products including processed inert debris at the facility at
any time? A rough estimate could possibly be around 6,000 cyds at a given time. We have never
reached capacity for processed materials, as such we are unsure how to clarify. Any processed materials
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will likewise be stored as outlined in our permit #5. Should there not be area available, processing will
cease until there is room to follow the permit storage specifications.

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: Having processed all of the compost in 2017, passive composting is
not currently employed. At this time we are not planning a return to that method. The land clearing
debris brought in is now stored per permit, ground and sold by Mebane Wood Recyling.
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.” 13. In operating plan

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? The only products stored at this location will be land clearing debris, wood,
ground wood, mulch. We are not currently screening soil/earthen materials and will consult with
NCDEQ if started again.

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. added
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. separated

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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. Removed same month.
ii. Note the stockpile area on the drawing of the application. Noted on 7.7 acres on map
iii. How to disposal of or reuse the inert debris - brick or stone, if the market no longer exists? Will
remain in designated storage per map.

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. Disaster debris dimensions have been
separated out from standard dimensions.

11. (Item 5) Please provide the maximum capacity of the screening and load-out area in the third paragraph
of this subsection. We have not met a maximum capacity for this area.

12. (Item 6) Please identify the facility or facilities will receive the non-conforming wastes temporarily
stored at the facility. Scott Stone, Coble Land Fill, Mebane Wood Recycling responsible for removing
all non-conforming wastes to appropriate facilities.

13. (Item 10) Please note the BMP types and add the locations of the described BMPs to the site plan
drawing. FIGURE 2 drawing lists the locations (permanent/channel/sediment trap), is this sufficient?

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. No longer composting, no
composting stockpiles remain on site.
b. Open burning of solid waste is prohibited at the facility. added
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. Language added and form printed.

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
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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.

CAROLINA RESOURCE RECOVERY, INC.
Carolina Resource Recovery, Inc.
3285 Jones Drive
Mebane, NC 27302

Phone: [phone]
Fax: [phone]

April 25, 2018

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

RE: Renewal of Permit to Operate (Permit No. 0106-TP-2012)

Dear Mr. Chao:

I offer this permit renewal application for Carolina Resource Recovery, an organic waste management facility.
We wish to renew our Permit to Operate as an LCID Treatment and Processing Facility.

Per your email instruction and in compliance with the requirements outlined in NCGS 130A-309.5(c) and
current guidance for treatment and processing facilities, the prior approved permit is being provided as outlined
below.

(1) Permit renewal application narrative
(2) Site and operation plans for a treatment and processing facility;
(3) Figures 1 through 3 to illustrate site utilization;
(1) Copy of the deed;
(2) Copy of zoning letter from the Alamance County Planning Dept.; and
(3) Copy of Certificate of Coverage under NPDES General Permit No. NCG210000.
(4) Copy of NC Solid Waste Management Facility Fire Occurrence Notification

Please note the following 2 revisions in the Operating plan:

(5) Operating plan number 3: vehicles entering the facility will be directed to Mebane Wood Recycling in
place of Scott Stone, Inc.
(6) Operating plan number 7: Removal of the Fiat Allis 345-B Loader as the equipment is no longer owned
or available to use.

If there are any questions regarding this letter or the enclosures, please contact me at [phone].

Respectfully submitted,

Steven S. Scott
Carolina Resource Recovery

FACILITY OVERVIEW
Name of Facility: Carolina Resource Recovery
Address: 3285 Jones Drive, Mebane, NC 27302
Landowner and FRP: Steven S. Scott, Owner and General Manager
Phone Numbers: [phone] (Ofc) [phone] (Cell)

The Carolina Resource Recovery facility (“the facility”) is a land clearing and inert debris
(LCID) treatment and processing operation. The overall operational goal of the facility is to
continue to complement the integrated landscape products production and distribution
operations of Scott Stone, Inc. The recycled products produced by the facility include high
quality mulch and screened topsoil for bulk sale to landscapers and contractors.
It is the intent of the facility to accept land-clearing debris (stumps, trees, limbs), untreated
and unpainted wood waste (excluding dimension lumber), uncontaminated pallets (owner-
generated only), uncontaminated soil, and storm debris in compliance with NCGS 130A-
309.5(c). Yard trash, leaves and other high nitrogen wastes will not be accepted.

LAND USE AND REGULATORY COMPLIANCE
Zoning The site is unzoned; refer to the attached letter from Libby
Hodges Planning Manager, Alamance County Planning
Department, dated October 17,2017.
Watersheds The site is not located in a water supply watershed. Refer to the
attached letter from Jason Martin, Planning Manager, Alamance
County Planning department, dated October 28, 2011.

CRR Application for Renewal of Permit to Operate
October 2017 rev Apr 2018 1

Storm water Storm water leaving the site in existing ephemeral and
intermittent streams discharges into an unnamed tributary to
Haw Creek (WS-V NSW classification). NCDENR’s Division of
Water Quality issued a Certificate of Coverage under NPDES
General Permit No. NCG210000 (Timber Products Storm water
Discharge) to Carolina Resource Recovery effective February
1, 2012. The Certificate of Coverage number is NCG210421
and a copy is attached.

SITE DESIGN AND OPERATIONS

The LCID Treatment and processing (T&P) area is located in the central portion of the site
and occupies about 10.5 acres (see Site Plan and Figure 1). Access to the facility is
provided by an all-weather road, which has a secure, gated entrance at Jones Drive.

The facility is situated on the south side of the 59-acre site, opposite low-density
residential development to the north. The land to the south of the site (125 acres) is
owned and occupied by Scott Stone, Inc., a landscape materials supplier owned by the
facility’s owner. Land to the east and west is mostly wooded and/or cultivated, i.e.,
undeveloped. Buffers have been provided as follows: 50 feet from property lines, 1000
feet from the nearest residence, 1000 feet from the nearest well, and 50 feet from streams.

Treatment and processing operations consist of sorting and segregating incoming wastes
by type, stockpiling organic waste until enough is on hand for cost-effective grinding by
contract, separating soil from stumps, grinding and screening organic wastes, and
screening topsoil. The majority of the 2.8 acre area is used to segregate incoming wastes
prior to processing and to stockpile topsoil and organic wastes prior to grinding.
Stockpiles averaging 14 feet high by 30 feet wide at the base are utilized. The design
layout calls for 20-foot fire lanes around and between the stockpiles (see Figure 1). An
area about 100 square is provided in the T&P area for optional organic waste grinding
and screening operations.
CRR Application for Renewal of Permit to Operate
October 2017 rev Apr 2018 2

Though inflow of waste materials to the facility cannot be accurately predicted due to the
commercial nature of the operation and the cyclical nature of land development, inflow
documented and reported of the last five years suggests that an average inflow for organic
wastes of 72 cubic yards per week (the equivalent of 6 tandem axle dump trucks) is
reasonable. Land clearing normally experiences seasonal peaks from about March 15
through June 30 and again from about September 1 through November 15. Somewhat
less activity occurs during July and August, and very little activity occurs during the winter
(November 15 through March 15).
A storage area (about 4.8 acres) is provided in the western portion of the site for processed
mulch and/or disaster debris (see Site Plan and Figure 2). The design layout allows for
20-foot fire lanes around and between groupings of windrows (see Figure 2). The
processed mulch windrows will be 10 feet wide at the base with 15-foot wide aisles
between the windrows.
Disaster debris (TDDSS) windrows will average 12 feet high by 25 feet wide at the base
with 15-foot wide aisles between the windrows. Screening and load-out takes place in a
designated area in the eastern portion of the site (about 1.9 acres) near the site entrance.
Storm water runoff in all operational areas is directed to permanent ditches and diversions
that direct it to storm water BMP’s and/or forested riparian buffers.
The facility is operated to minimize dust, noise, and vectors. Dust is controlled by the
application of water spray on facility roads during hot, dry weather. Waste processing
may be postponed during periods of high wind to reduce dusting. Waste grinding and soil
screening do not take place in the rain. Noise is not a problem given the intermittent nature
of the operation and the relative isolation of the site. Only a few pieces of conventional
heavy equipment operate at the facility, with the exception of a tub grinder that operates
2 or 3 times a year on average. Regarding vectors, the facility staff can facilitate drainage
and minimize standing water to reduce the potential for mosquito breeding. The wastes
being processed are not likely to attract other vectors since they are not putrescible.

CRR Application for Renewal of Permit to Operate
October 2017 rev Apr 2018 3

Site personnel consist of the following:
Site Operator: Supervises site operations and site personnel under the
direction of the General Manager. Also controls access
and directs vehicles.
Equipment Operators: Operate equipment associated with processing
operations.
A more detailed discussion of facility operations can be found in the attached Operating
Plan.
RECORD KEEPING AND REPORTING
Records are kept at the site regarding wastes received and wastes processed and sold
(mulch, screened topsoil, etc.). Records include customer or vendor name and address,
type and volume of material received and sold, and date of transaction. Copies of all
applicable permits (with supporting documentation form approved permit applications) and
of approved operating plans will be kept on site.
An annual report is prepared each year for the period July 1 through June 30 and submitted
to the Division of Waste Management by August 1. The annual report will document the
total quantity and types of waste received, including waste received from local
governments, and the quantities of mulch and other products produced and sold. For
reporting of volume-based transaction on a weight basis, processed volumes will be
converted using a factor of 400 pounds per cubic yard (0.2 tons/CY). The annual report will
be submitted on the reporting form provided by the Division of Waste Management for
treatment and processing facilities.

CRR Application for Renewal of Permit to Operate
October 2017 rev April 2018 3

OPERATING PLAN
CAROLINA RESOURCE RECOVERY
LCID TREATMENT & PROCESSING FACILITY
Mebane, NC
Steven S. Scott, Owner 919-563-3469 Office
336-214-7229 Cell
[e-mail] email
[e-mail] email
Steven S. Scott, Site Operator 336-214-7229 Cell
Emergency Contact (24 Hours) Steven S. Scott, Owner
Swepsonville Fire Department 336-578-1500 (Fire Station)
FIRE/RESCUE EMERGENCIES 911 Fire/EMS
Physical Address: 3285 Jones Drive
Mebane, NC 27302
Operating Hours: Monday –Friday: 8:00am – 5:00pm
Saturday: 7:00am – 12:00pm by appointment
In compliance with NCGS 130A-309.5(c):
1. The facility accepts on the following solid wastes:
Land-clearing debris (stumps, trees, limbs), untreated and unpainted wood waste
(excluding dimension lumber), uncontaminated pallets (owner-generated only),
uncontaminated soil, and storm debris. Yard trash, leaves and other high nitrogen
wastes will not be accepted.
2. The average inflow of organic wastes is 72 cubic yards per week (the equivalent
of 6 tandem axle dump trucks) based on historical usage.

3. All unscheduled vehicles entering the facility are directed to contact Mebane
Wood Recycling, where pertinent information is recorded on a ticket and/or
customer log, with the hauler name, vehicle type and size, and type of waste
materials noted. The office attendant then directs the vehicle driver to the site,
where the Site Operator directs the vehicle to the appropriate off-loading area.
CRR Application for Renewal of Permit to Operate
October 2017 rev April 2018 3

The site operator selects vehicles on a random or targeted basis and conducts an
inspection of materials as they are being off-loaded. The visual inspection helps
assure that received materials are compatible with the intent and goals of the
facility. Reusable inert materials such as brick or stone may be transported to
neighboring Scott Stone, Inc. if a market for such materials exists.

4. Treatment and processing operations consist of sorting and segregating incoming
wastes by type, stockpiling organic waste until enough is on hand for cost-effective
grinding by contract, separating soil from stumps, grinding and screening organic
wastes, and screening topsoil. Because the area for waste treating and
processing is surrounded by on-site drainage features, pursuant to Rule 15A
NCAC 13B.0302(3), the waste grinding and soil screening processes will not be
conducted in the rain.

5. Land clearing and storm debris are piled in linear stockpiles averaging 14 feet
high by 30 feet wide at the base in the treatment and processing areas (see Figure
1). The design layout calls for 20-foot fire lanes around and between the stockpiles
(see Figure1). Some variation in the alignment of stockpiles is expected, but the
piles are oriented to provide drainage so water won’t pond on the site.
Occasionally, the piles are relocated a short distance for the purpose of separating
and harvesting topsoil from the partially decomposed wood.

Periodically, when prompted by customer demand, advancing decomposition,
and/or site space considerations, all or part of the stockpiled woody debris is
ground to create mulch for sale. If necessary, excess processed mulch is
transferred to the storage area (see Figure 2). The design layout calls for 20-foot
fire lanes around and between groupings of windrows (see Figure 2). The
processed mulch windrows will be 10 feet wide at the base with 15-foot wide aisles
between the windrows.

Screening and load-out takes place in a designated area in the eastern portion of
the site near the site entrance (see Figure 3). If the facility reaches or has reached
capacity, waste receipt will be halted until space is available to resume normal
operations.

6. The site is a conditional approved Temporary Disaster Debris Staging Site
(TDDSS), DS01-001 and receives permitted waste stream – vegetative storm
debris after the site is activated during an emergency event. Activation is
requested and received from the Regional Environmental Senior Specialist for the
facility. Apart from activation TDDSS will not be operational. When operational,
disaster debris windrows will average 12 feet high by 25 feet wide at the base with
15 foot wide aisles between the windrows.

7. All non-conforming waste and non-recyclable material is stored on site in a
designated (small) area, then transferred to a roll-off container when sufficient
CRR Application for Renewal of Permit to Operate
October 2017 rev April 2018 3

volume accumulates. Any household garbage or other putrescible wastes will be
containerized daily and properly disposed of at least weekly. Facility personnel
are responsible for transporting all non-conforming wastes to an appropriate and
properly permitted solid waste disposal facility.

8. The following equipment is available for use at the facility. Additional equipment
and vehicles are available at Scott Stone (contiguous site) for use at the facility
as needed.

1999 Extec Screener with vibrating grid and stacking conveyor

Ford 555-B Loader

2007 Case Wheel Loader

1997 John Deere 5300 Tractor with 540 Loader

9. The facility entrance is secured by a locked gate to prevent access except when
scheduled or when an attendant is on duty, and to prevent unauthorized access
at all times. An attendant is on duty at all times the facility is open for public use
to prevent acceptance of unauthorized wastes.

10. Access roads are of all-weather construction and are well maintained.

11. Surface water is diverted from the working area at all times. Storm water BMP’s
retention structures, and/or other approved measures are utilized to prevent soil
and other pollutants from accessing surface waters and to prevent excessive on-
site erosion.

12. A sign is posted at the facility entrance showing the contact name and telephone
number in case of an emergency, acceptable wastes and permit number.

13. Fire, ambulance, and police telephone numbers are posted in a place that is
readily accessible. The facility personnel are trained in basic on-site fire response
procedures and have access to heavy equipment, water and extinguishers to aid
in the early suppression of fire. Fire suppression may include isolation and
spreading burning material, application of water or chemical suppressant, and/or
covering with soil. Open burning of solid waste is prohibited at the facility. Fires
are reported to the Regional Environmental Senior Specialist within 24 hours of
CRR Application for Renewal of Permit to Operate
October 2017 rev April 2018 3

the occurrence using the NC Solid Waste Management Fire Occurrence
Notification form.

14. If at any point seventy-five percent (75%), by weight or volume, of the stored
finished products are not removed annually by sale, use, or reuse according to
the NCGS 130A-309.05(c), the facility will submit the maximum storage period for
approval. Failure to comply with this requirement, the owner and operator will
take compliance action, or face permit revocation.