3507_INSP_20190807

NORTH CARnLINAD_E Q�/��
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: FRANKLIN
MSWLF
PERMIT NO.: 3507-TIRETP-2016
Closed
HHW
White
Incin
T&F
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
Tire T&F/
x
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: August 7, 2019
FACILITY NAME AND ADDRESS:
PRTI, Inc.
2105 US Highway 1
Franklinton, NC 27525
GPS COORDINATES: 36.06473°,-78.48715'
Date of Last Inspection: March 4, 2019
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Scott Clagett; Ben Machon; Brent Burger
Telephone: [phone] Scott; [phone] Ben; [phone] Brent
Email address: sclagett&prtitech.com; bmachonkprtitech.com; bburger&prtitech.com
FACILITY CONTACT ADDRESS:
Same as above
PARTICIPANTS:
Davy Conners, NC DEQ — Solid Waste Section
Ethan Caldwell, NC DEQ — Solid Waste Section
Scott Clagett, PRTI
Ben Machon, PRTI
Brent Burger, PRTI
STATUS OF PERMIT:
Permit to Operate was issued on February 22, 2016 and will expire on December 31, 2019.
PURPOSE OF SITE VISIT:
Complaint investigation and partial compliance inspection.
STATUS OF PAST NOTED VIOLATIONS:
N/a
OBSERVED VIOLATIONS:
A. 15A NCAC 13B .0106 GENERATOR OF SOLID WASTE
(a) A solid waste generator shall be responsible for the satisfactory storage, collection and disposal of solid
waste.
And, (b) The solid waste generator shall ensure that his waste is disposed of at a site or facility which is
permitted to receive the waste.
PRTI, Inc. is in violation of 15A NCAC 13B .0106 (a and b) by failing to ensure waste (carbon black) generated at
this facility is properly disposed at a site that is permitted to receive the waste. During the inspection, Mr. Clagett
said their carbon black is transported to various locations including a petroleum landfarm in Bear Creek, NC,
called Earthtec. Earthtec Environmental, Inc. is a permitted Petroleum Containment and Treatment facility that is
Page 1 of 6

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"-t0E'"�m"""°"""' Solid Waste Section
NOT permitted to receive carbon black.
B. 15A NCAC 13B .0203 PERMIT APPROVAL OR DENIAL
(d) By receiving solid waste at a permitted facility, the permittee(s) shall be considered to have accepted the
conditions of the permit and shall comply with the conditions of the permit.
And, PERMIT TO CONSTRUCT AND OPERATE, ISSUED FEBRUARY 22, 2016, ATTACHMENT 4,
PART I, NUMBER 4
(g) control measures and practices must be employed to prevent any pollutants from contaminating surface
water, groundwater, and soil.
PRTI, Inc. is in violation of 15A NCAC 13B .0203 and Permit Condition Attachment 4, Part I, 4(g) by failing to
prevent a pollutant from contaminating surface water and soil. During the inspection, Davy Conners and Ethan
Caldwell observed a trail of carbon black from the facility to the sedimentation pond at the back of the facility, then
to a ditch alongside a service road (the service road is owned by neighboring Capital Materials). The carbon black
diverted from the ditch into the forest and then ended. The carbon black was in the water in the ditch and stained
the soil in the ditch and the forested area.
The item(s) listed above were observed by Section staff and require action on behalf of the facility in order to come into or maintain compliance
with the Statutes, Rules, and/or other regulatory requirements applicable to this facility. Be advised that pursuant to N.C.G.S. 130A-22, an
administrative penalty of up to $15,000 per day may be assessed for each violation of the Solid Waste Laws, Regulations, Conditions of a Permit,
or Order under Article 9 of Chapter 130A of the N.C. General Statutes. Further, the facility and/or all responsible parties may also be subject to
enforcement actions including penalties, injunction from operation of a solid waste management facility or a solid waste collection service and any
such further relief as may be necessary to achieve compliance with the North Carolina Solid Waste Management Act and Rules.
ADDITIONAL COMMENTS
The facility is permitted to receive scrap tires. This facility is permitted to receive scrap tires from North Carolina,
Virginia, Tennessee, and South Carolina. The facility processes tires through six pyrolysis units. The result is an oil
and a carbon, steel and rubber solid mix. The solid mix is then ground, and the steel is separated from the carbon black.
The inspection was the result of a complaint of carbon black entering a nearby creak. In addition to the Observed
Violations listed above, the following compliance issues were observed:
C. Carbon black was found on the ground throughout the facility but was thickest around/near the grinder. The
grinding operation was not under cover. Mr. Machon said PRTI is looking into getting the area covered but
want to make some changes to the grinding operations first. Getting the grinding operations under cover would
reduce the amount of carbon black in the runoff.
There were also piles of carbon black that were uncovered. Mr. Clagett had them covered with tarps before the
storm came through, while we were on site.
Mr. Burger said that PRTI has enlisted Smith + Gardner to engineer a better sedimentation and erosion control
plan for the facility to help alleviate the carbon black issue.
D. 15A NCAC 13B .1110 SCRAP TIRE PROCESSING FACILITIES
(a)... At least 75% of both the scrap tires and processed tires that are delivered to or maintained on the site of
the scrap tire processing facility site shall be processed and removed for recycling or disposal at a permitted
solid waste management facility within one year of their receipt.
AND, THE PERMIT TO OPERATE ATTACHMENT 4, PART I, NUMBER 2
The scrap tire processing facility is permitted to collect, store, process and maintain on site, not more than
Page 2 of 6

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
Solid Waste Section
13,000 tires or the equivalent in shredded tire or by-products.
A large stockpile of supersacks full of carbon black were observed on site. Mr. Clagett said they had been there
for a year and a half or more. Since getting the grinder, they no longer use the supersacks to store the carbon
black.
E. One of the scrape tire storage bays had some tires and rubber outside of the covered area. All tires must be
under cover.
PRTI must take the following corrective action measures within the timeframes specified in order to achieve
compliance:
1. Immediately cease sending carbon black or any other waste to any properties that are not permitted to receive
that waste. Ensure that the property or facility PRTI is sending its waste to is permitted to receive that waste by
asking for a copy of the permit and verifying that the permit is not expired. Retain records of all waste disposal.
2. Immediately take measures to prevent carbon black and any other pollutants from contaminating surface water,
groundwater, and soil.
3. Within 30 days of receipt of this notice, submit a corrective action measures plan (Plan) for Section
approval. The proposed Plan shall be submitted in electronic format sent via email and meet the
following requirements:
a. Include a map/aerial photo depicting the extent of carbon black impacted areas and proposed
excavation/removal methods. The Section requires the removal of all carbon black and at least 2 inches
of un-stained soil from the ditch and forested area behind the facility;
b. Include a description of proposed characterization, management, and disposal of excavated material;
c. Include a map/aerial photo depicting the proposed confirmation sampling locations;
d. Provide a description of the proposed sampling methodology;
e. Describe proposed soil sampling and surface water sampling (if applicable) at specific
locations, including background soil and upstream water locations;
f. Surface confirmation soil samples shall be collected between zero and one foot below ground
surface;
g. All samples shall be collected as discrete samples for all constituents. Composite samples will
not be accepted;
h. All excavated material, confirmation soil samples, and surface water samples shall be analyzed
by a NC certified laboratory for the following constituents: polycyclic aromatic hydrocarbons
(PAHs), copper, zinc, cadmium, lead, nickel, and chromium (chromium speciation for trivalent
chromium and hexavalent chromium is needed). Test method for PAHs is 8270 and for metals
use total metals 3050 Or 3051 prep with Method 6010.or other equivalent approved methods
recommended by the laboratory.
Page 3 of 6

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"'—t0r-!�'m"""°"""' Solid Waste Section
i. After Section approval of the sampling plan, the plan shall be implemented within seven (7)
days. Within 10 business days after receiving the analytical results from the laboratory, submit
documentation regarding the sampling event which shall include the following:
i. A summary of the carbon black release, the extent of the release, and the corrective
action measures taken to address the release;
ii. A map/aerial photo depicting the extent of excavation and all sampling locations;
iii. Documentation of proper disposal of excavated material;
iv. A table of the surface water analytical results compared to the NCDWR Surface Water
Quality Standards (15A NCAC 02B & EPA National Recommended Water Quality
Criteria Standards (EPA NRWQC);
v. A table of the subsurface soil analytical results compared to the NCDEQ Preliminary
Soil Remediation Goals (PSRGs). Both the Residential Health Based and the
Protection of Groundwater PSRGs must be met;
vi. The associated laboratory reports from the NC certified laboratory including the chain
of custody and QA/QC results;
vii. The sampling methodology, if different from the proposed plan; and
viii. Conclusions and recommendations.
4. Immediately begin to implement best management practices to contain waste including carbon black dust.
5. Within 30 days, properly dispose of the backlog of carbon black supersacks onsite. Manage tire byproducts in
accordance with PRTI's Permit to Operate.
6. Within 30 days, move all tires and rubber to a covered area.
Please contact me if you have any questions or concerns regarding this inspection report. See Attachment 1 for photos
taken during the inspection.
V
Digitally signed by Davy Conners
DN: cn=Davy Conners, o=Division of
Waste Management, ou=Solid Waste
Section,
email=[e-mail], c=US
Date: 2019.08.28 15:51:48-04'00'
Davy Conners
Environmental Senior Specialist
Regional Representative
Email: [e-mail]
Phone: [phone]
Sent on: August 28, 2019
Email
Hand delivery
US Mail
x
Certified No.
000813000000805616871
Copies: Andrew Hammonds, Solid Waste Section
Ethan Caldwell, Solid Waste Section
John Patrone, Solid Waste Section
Page 4 of 6

NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Attachment 1: Inspection Photos
Sediment basin at the back of the property.
Black water in ditch
from sediment basin.
Black water/substance flowing towards the service road. I Black staining in ditch alongside of service road.
Page 5 of 6

NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
t ` r
n Si
1 Y
.
Black staining in forest beside service road.
Tires and rubber beyond covered area.
e �
Sediment basin near just downhill from storage of
Uncovered carbon black and supersacks.
su ersacks/carbon black.
^onsite
Supersacks with carbon black that have been stored
Grinding operations uncovered.
fora year and a half.
Page 6 of 6