7504T_CORR_20160120

JAN252016
SOLID WASTE SECTION
ASHEVUE REGIONAL OFFICE
KRD Tucking • 20340 Roney Island • Lynwood, IL 60411 • [phone] • Fox [phone]
January 20, 2016
Mr. Lee Hill
NCDENR — Solid Waste Section
2090 US Highway 70
Swannanoa, NC 28778
Subject: Notice of Deficiency
Location: Polk County Transfer Station
75-04T-Transfer-2005
Polk County
Dear Mr. Hill,
KRD Trucking is in receipt of the NCDENR — NOD dated January 11, 2016.
KRD Trucking understands and accepts the responsibility to comply with the Polk Transfer Station
permit.
Section 59.2(c) of Session Law 2013-413 requires containers used to collect and transport solid
waste to "be designed and maintained to be leak -resistant in accordance with industry standards."
KRD Trucking does recognize where it had a problem containing leachate on site in a trailer and
deeply regrets the deficiency. KRD is committed to compliance in this situation and does not want
to compromise the facility's ability to ensure protection of the public health and the environment.
As stated in the NOD, KRD Trucking is required to take corrective action within 10 days of the
issue date of: January 11, 2016.

The following corrective action plan outlines action already taken as well as proposed action to
ensure continued and effective compliance with section 59.2(c) of Session Law 2013-413.
Immediately after being informed of the initial results of the inspection KRD assessed the
condition of the trailers located at Polk County for additional deficiencies. No other issues
were found at the time.
• Trailer #T-243 was brought to the KRD Piedmont shop and repaired on same day on
January 05, 2016. See Exhibit 1.0 KRD Repair order
• A meeting was held at Polk County Transfer Station on January 19, 2016 to discuss the
current status of operations and proposed waste transfer operations to ensure compliance
of permit conditions and the operations plan of Waste Management Facility 75-04T-
Transfer-2005. All items in this plan were discussed and mutually agreed upon during this
meeting. In attendance for the County was Larry Walker, and for KRD was Jim Woods.
KRD realizes that our industry is harsh on equipment. The loading of MSW into open top
trailers will cause damage to the trailer that ultimately can cause leachate to escape. We
have designed and are proposing for experimental use a Leachate Wagon to be available to
place under any given trailer found to have developed a leak. This Wagon can be placed
under a trailer that has developed a leak and then rolled over to the loading pit to be drained
in an area where leachate is designed to be collected. The wagon is designed with baffles
to reduce spillage when being moved and also has a drain on the underside to allow for
controlled release into designated areas. This Wagon has been ordered and is being
specially made for the Polk County Transfer Station. It will be delivered upon completion,
anticipated completion date will be before Feb 15, 2015 Exhibit 2.0
All trailers will be inspected daily by the driver— deficient trailers that pose a leak hazard will
be removed from the site same day and repairs completed in a timely fashion. Any leaking
trailer will not be returned to Polk County before necessary repairs are completed.
KRD recognizes that proper training of its personnel is essential to the success of any
program. All KRD employees at the Piedmont facility will be trained on this action plan for
Polk County and will be shared with Polk County employees. The training will include the
communication of Polk County's expectation of KRD to comply with the permit requirements
regarding leak -resistant containers. The training will also include all parts of this plan
regardless of the assigned duties of employee so the total scope of KBD's requirements is
understood by all. Training for employees assigned to Polk County will be completed
immediately and all other employees by January 29th 2016. Exhibit 3.0

Also, KRD Trucking will make every effort to keep the following trailers at the Polk County Transfer
for easy identification:
• 473
• 294
243
• 345
• 245
If you have any questions or concerns, please contact me.
Sincerely, ,� n
John McGee
KRD Trucking
708.774.9917
Copies: Jason Watkins, Field Operations Branch Head
Deb Aja, District Supervisor
Jessica Montie, Compliance Officer
Attached List of Exhibits
3

List of Exhibits
KRD Response to
NOD Dated 01-11-2016
Polk County NC
REC,'E
JAN252016
S -' !D viASTE SECTION
f-,,EViLLE REGIONAL OFFICE

KRD Polk County Response Exhibit 1.0
Repair Order Detail
K.R. DrenthTnrckirig, Inc
Repair Order:
SC-ODD014636
Status:
OPEN
Shop:
PIEDMONT
Unit:
T243
20D4 East Tipper Trailer
Domicile:
PIEDMONT
Make:
EASTX
Cost Cntr
COSTCENTER
Model:
TIPPER
License:
540753ST
Year
2004
VIN:
1E1E2Y28-84RG33626
In Service: 8/1/2003
Repair Class: NONSCHEDULED
Repair Site: FACILITY
Opened: 1/5/2016
Closed
Completed:
Section: 1 Complaint: LEAKING Comments:
Priority: 5 Rep Reason: DRIVERREPORT traibrwassentinfron Polk county for hole in the floor leaking
Component: 071 Unit War None
Body
War. Type: NOWARRANTY
Comments
Date: Comlent Text
0120116 patched holes in floor of trailer to prevent lealuig t0391i
Labor
Date: Mechanic Description
012Ni6 MI
Body, LEAKING, VALD
Totals Repair Order SC4)00014636
Total Parts Issued:
0.00
Total Labor Hours:
4,17
Total Part Charges: $
0.00
Total Labor Charges:
134.69
Total Tax Charges:
0.00
Total Fee Charges:
0.00
Total Service Charges: $
0.00
Repair Total:
134.69
Generated by: DVO824
Version: 15.50.1
TRAMM4N by TMr Software
5
Fours Rate Total
4,17 $32.30 $134.69
Page:i
1/20201610:04:16 AM

KRD Polk County Response Exhibit 2.0
N

KRD Polk County Response Exhibit 3.0
KRD Procedures for Leaking Trailers
Polk County, NC
• KRD Driver will do a walk around inspection of every trailer on site on a daily basis to ensure there no leaks. If
a trailer has been identified to have a leak the leachate wagon or other containment device must be placed
under the leak to contain the Leachate until it can be removed from the site for repair.
• The driver then needs to communicate with the KRD Division manager and Polk County personnel that there
is a leaking trailer and that it will be removed and brought in for repair.
• Necessary repairs shall be completed to ensure compliance and Polk County personnel shall be notified of
said repair.
• Under no circumstances shall a trailer with known leaks be returned to Polk County for use.
• Polk County has committed to cooperating with KRD in our efforts to identify deficiencies and maintain leak
resistant trailers. They will also look for leaks on the trailers that are on site and utilize the Leachate Wagon
or other containment devices to ensure compliance. Polk County will communicate with KRD Management to
ensure immediate and efficient repair of deficient trailers.