4308_CentralCarolinaTireTP_ApplReview_DIN27100_20161206

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary

MICHAEL SCOTT
Director

December 6, 2016

Mr. Tom Frye
General Manager
Cental Carolina Holdings, LLC
1606 McKoy Town Road
Cameron, NC 28236

Subject: Permit Application Review
Central Carolina Tire Processing
Permit No. 4308-TIRETP-, Harnett County, Document ID No. 27100

Dear Mr. Frye:

The Division of Waste Management, Solid Waste Section, received and has reviewed the permit renewal
application for the Central Carolina Tire Processing (DIN 26378). The following comments and
questions are based on that review.

1. The application was submitted on September 15, 2015, to Mr. Geof Little. In the text and on the
drawings, a Rasper Building No. 2 was indicated. In Section 1.17, it was projected that the Rasper
Building No. 2 would being operations in the first quarter of 2014.

Based on emails of June 23, 2016, and November 11, 2016, from Vance Moore, it appears that a
decision was made to install a new larger unit in Rasper Building No. 1 rather than the second Rasper
unit/building. Therefore, Section 1.17 in the application is incorrect and should be revised.

If you still plan to add the second Rasper unit/building, you should provide a new date for when it
will be added. The plan should also address whether or not an increase in the storage limit will be
required based on the change. The permit renewal will need conditions addressing a pre-operation
inspection and possible increase in financial assurance if you still wish to include the addition of the
second unit. If you do not want to include the second Rasper unit/building, you should remove
references to the second unit from the text and drawings so that they accurately reflect your operation.

2. In Section 2.13, an allowable storage limit of 300,000 tires is requested. The calculation of financial
responsibility for site closure should be based on 15A NCAC 13B .1111 (c)(1) and not the
spreadsheet provided in Appendix C.

15A NCAC 13B .1111 (c) Owners and operators of scrap tire collection sites shall demonstrate the
following minimum amounts of financial responsibility:

(1) For site closure: one dollar and fifty cents ($1.50) per tire for the maximum number of tires
permitted to be stored on the site at any one time.
(2) For property damage and bodily injury to third parties and public property: two thousand five
hundred dollars ($2,500) worth of coverage per occurrence for each 1,000 tires permitted to be
Mr. Tom Frye
Permit Application Review - Central Carolina Tire Processing - DIN 27100
Page 2 of 2

stored on-site, with an annual aggregate of five thousand dollars ($5,000) worth of coverage for each
1,000 tires permitted to be stored on-site.

It is my understanding that the current financial assurance is in the amount of $352,500. Using the
rule, storage is limited to 235,000 tires. Therefore, the allowable storage limit requested in Section
2.13 does not match the financial responsibility established using Rule. 1111. This should be
corrected.

Please make the needed changes to the application and resubmit.

If you have any questions regarding this matter, please contact me at [phone] or by email at
[e-mail].

Sincerely,

Patricia Backus, P.E., Environmental Engineer
Division of Waste Management, NCDEQ

cc: Gene Helton, Liberty Tire
Vance Moore, P.E., Garrett & Moore
Ed Mussler, P.E., Permitting Branch Head
Drew Hammonds, Eastern District Supervisor
Liz Patterson, Environmental Senior Specialist
Sarah Rice, Environmental Senior Specialist