8607TIRETP2013_INSP_20200915

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 3

UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost SLAS COUNTY: Surry
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: 8607-TIRETP-2013
CDLF Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: September 15, 2020 Date of Last Inspection: November 6, 2019

FACILITY NAME AND ADDRESS:
New River Tire Recycling, LLC
312 East 52 Bypass
Pilot Mountain, North Carolina 27041

GPS COORDINATES (decimal degrees): Lat.: 36.38591 Long.: -80.46101

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Ben Bryant, Owner
Telephone: [phone]
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
Same as above

PARTICIPANTS:
Ben Bryant, Owner – New River Tire Recycling, LLC
Charles Gerstell, NCDEQ – Solid Waste Section

STATUS OF PERMIT:
A Permit Approval to Operate A Scrap Tire Collection and Processing Facility was issued to Ben Bryant and New
River Tire Recycling, LLC on February 4, 2019. The permit shall expire at the close of business December 20, 2024.

PURPOSE OF SITE VISIT:
Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
N/A

OBSERVED VIOLATIONS:
None

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.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 3

ADDITIONAL COMMENTS

1. The facility consists of a Scrap Tire Collection and Processing Facility for the collection and processing of scrap
tires.
2. The facility is permitted to receive tires from all states within the United States.
3. The facility had proper signage.
4. Gates were provided at both entrances to the facility to prevent unauthorized access.
5. A chain-length fence is provided around the entire perimeter of the facility to prevent unauthorized access.
6. Phone service is maintained at the facility to assure contact with local fire protection authorities in case of fire.
7. A small amount of standing water was observed on the outdoor portion of the concrete floor adjacent to the
stockpile of tires on rims and along the eastern edge of the stockpile of tire fluff. Mr. Bryant stated that the facility
last received rain on September 12, 2020.
x All standing water was maintained to the concrete floor.
x Standing water should be avoided around stockpiles to prevent nuisance conditions. Please ensure that
proper steps are taken to address standing water as outlined in the Operations Plan for the facility.
8. An Emergency Preparedness Manual is provided under Appendix L of the approved facility application.
9. The indoor processing area and maintenance/storage areas were protected by an overhead sprinkler system and fire
extinguishers.
10. All scrap tire storage areas were greater that 50-feet from all property lines.
11. It appeared that scrap tire piles were within the permissible size limit of 5,000-square feet or 50,000-cubic feet.
12. Please ensure that a 50-foot fire lane is maintained around the perimeter of scrap tire piles. During the inspection,
a pile of scrap tires with rims did not have a 50-foot fire lane around the entire perimeter of the pile. A proper fire
lane was also not provided around the entire perimeter of a stockpile of rough shred whitewall material adjacent to
the large stockpile of tire fluff.
13. Three piles of demolition waste associated to demolition of the existing building on the east side of the facility
were observed.
x Majority of waste was maintained under the roofed area and away from tire processing activities. Please
ensure that all demolition debris is removed as quickly as possible to prevent the creation of nuisance
conditions.
14. Section 3.9 of the approved facility application states: “New River Tire does not store or process tires outside the
concrete pad thus negating the need for grass, underbrush, and vegetation control.”
x During the inspection, multiple scrap tires and some rubber tracks were observed on the ground on the
south side of the building at the location of the former truck loading bay. These items were observed
beyond the footprint of the concrete floor. Please ensure that this material is returned to the concrete floor
for processing or disposal.
15. Inspection found that the former truck loading bay located on the south side of the concrete footprint of the
operation had been filled with soil to prevent this area from holding water during rains. Please ensure that fill in
this area consists of only clean fill material.
16. During the inspection, a pile of miscellaneous waste was observed on the east side of the building, just under the
roofed area that consisted of cardboard, a wooden pallet, scrap metal, a toy truck, dimension lumber, and what
appeared to be a bag of household trash. Mr. Bryant stated that this waste had been removed from tire shipments
that were received at the facility. Mr. Bryant stated that this material is generally loaded into a dumpster on site.
However, the dumpster had been moved to another area of the building prior to the inspection.
x Please ensure any such waste immediately loaded into a dumpster for proper disposal to prevent the
creation of nuisance conditions.
x It is recommended that New River Tire Recycling, LLC communicate with customers the need to prevent
wastes from being mixed with loads of scrap tires.
17. Filter rings were in place around all storm drains located on the south side of the facility to prevent residuals from
deposing into the storm drain system. Mr. Bryant stated that the catch filters previously used would not stay in
place and were replaced by the filter rings.
18. The facility has initiated a new recycling process in which crumb rubber is used to make large rolls of rubber
which are then used to produce rubber matting.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 3

19. During the inspection, a large stockpile of processed tire fluff was observed within the truck loading area/bulk chip
storage area. Mr. Bryant explained that this material was previously being shipped off site for boiler fuel, but it is
now being landfilled. Per G.S. 130A-309.05(c), materials cannot be speculatively accumulated. Seventy-five
percent (75%) of the material present on January 1st must be removed by December 31st of the same year.
20. Records detailing the amount of scrap tires received and processed by the facility were submitted by electronic
correspondence on September 25, 2020. This information was reviewed in combination with the tonnage
information provided on the 2019-2020 Facility Annual Report which is submitted to the Solid Waste Section by
August 1st of each year. Records appeared to show that the facility had exceeded the facility’s permissible on-site
storage limit of 130,000-tires or the equivalent in shredded tire or by-products (1,300-tons x 100 tires per ton). In
the transition to landfilling fluff materials rather than sending off-site for boiler fuel, and with the increased on-site
recycling to produce mats, a better understanding of materials stockpiled on-site and throughput numbers are
needed. Please provide an accounting of the production of fluff materials, stockpiled fluff, and schedule for
disposal. Regarding the recycling of tires to produce mats, please provide an accounting of processed tires
diverted for recycling and throughput in the production of rolls. If the number of on-site tires or equivalent
tonnages remain at an increased level into 2021 then it will be necessary for a modification and revision of
financial assurance to reflect the increased tonnages over the current allowable limit.

Please contact me if you have any questions or concerns regarding this inspection report.

________________________________________ Phone: [phone]
Charles T. Gerstell
Environmental Senior Specialist
Regional Representative

Sent on: 10/1/20 X Email Hand delivery US Mail Certified No. [ _]

Copies: Deb Aja, Western District Supervisor - Solid Waste Section
Digitally signed by Charles T. Gerstell
DN: cn=Charles T. Gerstell, o=Divsion of
Waste Management, ou=Solid Waste
Section,
email=[e-mail], c=US
Date: 2020.10.01 13:49:39 -04'00'