7605T_CityAsheboroTransferCommentPermitApplicationLOS_DIN26042_20160510.pdf

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary

MICHAEL SCOTT
Director
Solid Waste Section

May 11, 2016

Mr. David Hutchins, Director
Division of Public works
City of Asheboro
P.O. BOX 1106
Asheboro, NC 27204-1106

Re: Comments on the Permit Application for A Life of Site Permit
City of Asheboro Recycling and Solid Waste Transfer Station
Randolph County, North Carolina
Permit No. 7605T-Transfer-2002, Document ID No. (DIN) 26042

Dear Mr. Hutchins:

On May 02, 2016 the Division Waste Management (DWM), Solid Waste Section (SWS)
received the electronic copy of multiple components of the Permit Application for a Life of Site
Permit (the permit application) which are prepared by the City of Asheboro (the City). For the
sake of record keeping, the received documents are combined into a single document and placed
in the DWM document tracking system with a document identification number (DIN 26030).

After reviewing the permit application, the SWS has several comments on the permit application
which stated below. Your timely responses to the comments will expedite the completion of the
permit reviewing processes.

Section II General Information
1. Please provide the following information of the Transfer Station Facility:
i. The total acreage of the property that encloses the waste transfer facility.
ii. The size/extent of the transfer building including the covered and uncover areas;
the tipping floor; temporary waste storage area including tires, e-wastes, and other
recyclables.

2. Please describe the site security features such as the installation of fencing and gates to
restrict unauthorized persons to access the facility.

Section III. Source, Types, and Quantities of Waste
3. The Facility Compliance Inspection Reports state that the facility is not open to the
general public to drop small quality household garbage or recyclable. Please add this
restriction to this Section.

Mr. David Hutchins
May 11, 2016
DIN 26042
Page 2 of 6

4. Please add the permit number: 76-07 next to the new Great Oak Landfill.

Section V. Waste Transfer
5. Please use North Carolina Department of Environmental Quality (NCDEQ) in lieu of
NCDEHNR.

6. The waste collection and transfer at the facility must be operated according to the NC
Solid Waste Management Rules 15A NCAC 13B .0105, .0401 and .0402. Please add the
requirements to the Section.

Section VI. Hazard and Nuisance Control
7. Please address the following concerns or include additional information associated with
Prohibited or Undesirable Waste:
i. The first sentence of this Section lists the animal waste or carcasses as the
prohibited wastes which is inconsistent with the statement in the first paragraph of
Section III. Please clarify.
ii. If the facility is accepting asbestos containing material (ACM) for transporting to
a final disposal facility, please state the ACM management plan appended to the
Operation Plan. This ACM management plan shall be approved by the NC
Department of Health and Human Services (NCDHHS). The approved plan and
the NCDHHS approval letter must be appended to the permit application.
Otherwise, please list the ACM as the prohibit waste.
iii. Is the facility accepting sludge or bio-solid generated from a waste water
treatment plant? If not, please include the sludge or bio-solid to the prohibit
waste lists. Otherwise, please provide a specific plan for handling and managing
the sludge or bio-solid.
iv. Please add the PCB waste into the prohibit waste lists.
v. Please add the following reporting requirement to this Section. If the prohibit or
non-conformance wastes are found at the tipping floor in the course of waste
screening, the City shall notify the Solid Waste Section within 24 hours of
attempted disposal of any waste the landfill is not permitted to receive. The
points of contact of the Solid Waste Section (SWS) are:
 John Patrone, Senior Environmental Specialist
Phone # [phone]
E-mail: [e-mail]

 Deb Aja, Western District Supervisor
Phone # [phone]
e-mail: [e-mail]

8. Please address the following concerns associated with Fire Prevention:
Mr. David Hutchins
May 11, 2016
DIN 26042
Page 3 of 6

i. Please describe the measures or approaches to handle “hot load” at three different
scenarios: (a) The waste-loading truck is approaching the scale house. (b) The
waste-loading truck is inside the facility. (c) The hot load is found on the tipping
floor.
ii. Should a fire break out inside the facility, the City shall provide the SWS a verbal
notification within 24 hours and a written notification within 15 days. Written
notification must include the suspected cause of fire or explosion, the response
taken to manage the incident, and the action(s) to be taken to prevent the future
occurrence of fire or explosion. The standard fire occurrence report can be
downloaded from the SWS website at https://deq.nc.gov/about/divisions/waste-
management/solid-waste-section/solid-waste-forms. Please add the requirements
to this Section and append a hard copy of the standard fire occurrence report to the
Operations Plan.
iii. Please add the following requirement to the subsection: “Open burning of received
solid waste at the facility is prohibited.”

9. (Odors and Vectors) In addition to routinely cleaning and washing the tipping floor, the
daily or more frequent wash and cleaning of the trailer staging area is also required.
Please add the requirement to this subsection.

Section VII. Wastewater Treatment
10. Where is the described “pit area”? Is this “pit area” located at the load-out pad at a lower
elevation of the transfer station building? Please clarify.

11. Please describe the installed measures, structures, and/or devices at or around transfer
building to mitigate or minimize rain (precipitation) or stormwater run-on contacting
solid wastes resulting in the generation of excessive amount of leachate/wastewater at the
tipping floor.

12. Please describe if the ground surface of the trailer staging area is paved or unpaved one
which is graded for facilitating drain to the existing trench drain.

Section VIII. Waste Screening
13. Please append a typical waste screening form/log to the Operations Plan.

Section VIIII. White Goods, Metal, Electronics and Other Recyclables
14. Regarding the handling and managing recyclables at the Transfer Station Facility, please
clarify the following concerns:
i. To avoid the confusion, please delete “recycle” affront Transfer Station in this
Section.
ii. The Facility Compliance Inspection Reports states the City routinely cease
transferring ordinary trash to the designated landfill for final disposal twice a
week, and during the periods the City will sort and separate collected recyclables
Mr. David Hutchins
May 11, 2016
DIN 26042
Page 4 of 6

at the tipping floor, then move the sorted recyclable to the designated storage
units inside the Transfer Station Facility. If the City plans to continue this
operation, please describe the practice to this Section.

iii. Please describe the maximum storage duration at each recyclable unit inside the
Transfer Station Facility.

iv. The Freon (refrigerant)-contained white goods must be separated from non-Freon-
contained white goods at the temporary storage area/unit. Please also specify
when the Freon will be removed from the white goods and by who – a trained
contractor or a trained City employee?

v. The Facility Compliance Inspection Reports states the facility collects and
temporarily stores scrap tires from city owned vehicles. Please describe the scrap
tire collection unit in this Section.

vi. Please provide the contact info of the companies or contractors that will transport
and treat/process/dispose of the white goods/scrap metals, scrap tires, electronic
wastes or other recyclables. The latest contact info must be placed in the facility
operating record.

Section X. Litter Contaminated Debris Storage
15. The litter contaminated debris is considered as a municipal solid waste; therefore, please
provide additional info of handling and managing this waste at the temporary storage
unit:
i. According to the descriptions in this Section, there is no structure above this
temporary storage unit to prevent rain from contacting the stored waste. Please
describe leachate management for this unit such as adding a covering structure
over the unit (separation leachate from rain), installing berm or modifying surface
grading to prevent stormwater/run-in from contacting waste, describing the
frequency for routine wash or clean the unit, piping leachate or diverting
stormwater to the existing drainage trenches or sewer lines, and etc.
ii. What is the maximum storage duration of the collected debris at this unit?
Because the collected debris is considered as a municipal solid waste, the City
should manage this waste in the same way as an ordinary trash on the tipping
floor inside the Transfer Station e.g. waste shall not be stored on the tipping floor
after the operating hours. Except for the unforeseeable situation approved in the
permit, the wastes may be temporarily stored in the covered trailer overnight.
iii. Add the temporary storage unit and/or new leachate lines to the site layout
drawing (also see Comment No. 18).

Mr. David Hutchins
May 11, 2016
DIN 26042
Page 5 of 6

16. The Operation Plan should include the contingency plan to management potential
situations (such as equipment breakdown, long-term power outage due to natural disaster,
and other unforeseeable incidents) which results in ceasing the waste activities /
operations at the facility. Please add the contingency plan to the Operations Plan.

17. The SWS suggests the City to add a Section XI. Record Keeping in the Operations Plan
which lists all documents that should be placed in the facility. The documents, in a
minimum that requires to be retained at facility include:
 The approved documents – Operations Plan and drawings, zoning approval letter,
and others.
 Permits including the Solid Waste Permit – Permit To Construct and Permit to
Operate, Erosion and Sediment Control Permits, and etc.
 The certifications and training records of each personnel/operator.
 The waste screening records, facility annual reports, audit / inspection /
compliance reports, amount of waste received (including recyclables) at the
facility, and etc.
 Monitoring data, if applicable.

18. Please provide a scaled Site Layout Drawing to show and note/identify the following
contents:
 Existing and proposed contours.
 Property boundaries.
 Gates/fences or other access control features.
 Utilities (including wastewater system and stormwater drains)
 Existing and proposed roads
 Sedimentation basin details,
 Existing surface water features (ditches, ponds, streams, wetlands, etc.),
 Tipping floor and loading area.
 Any recyclable storage areas indicating types and sizes of containers.
 Any special waste handling areas, such as litter contaminated debris storage/open
bin, white goods/scrap metal collection area, tire collection area, e-wastes
collection area etc.
 Locations of leachate/sewer lines, sumps, drain trenches and/or runoff collection
details.
 Buildings or structures (existing and proposed) and scales/scale house.
 Concrete foundations/pads and identification of all other ground cover for the site
operation – asphalt, gravel, grass, etc.
 Distances to wells, residences, wetlands, and water bodies, and other physical
characteristics of the site.

Mr. David Hutchins
May 11, 2016
DIN 26042
Page 6 of 6

Please provide a hard copy and an electronic copy of the responses to the above-mentioned
comments which should be incorporated into the revised permit application. If you have any
questions of the comments please contact myself at 919-707-8251 [e-mail].

Sincerely,

Ming-Tai Chao, P.E.
Division of Waste Management, NCDEQ

cc:
Rusty Turner, City of Asheboro
Ed Mussler, P.E, Permitting Branch Supervisor
John Patrone, DWM
Deb Aja, DWM
Central Files