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Home My WebLink AboutDEP - Annual Report - Correspondence - 210 HOLT ROAD 6/10/2021 Commonwealth of Massachusetts Executive Office of Energy &Environmental Affairs Department of Environmental Protection One Winter Street Boston, MA 02108.617-292-5500 Charles D.Baker Kathleen A.Theoharides Governor Secretary Karyn E.Polito Martin Suuberg Lieutenant Governor Commissioner VIA EMAIL June 10, 2021 TBI, Inc. 210 Holt Road North Andover, MA 01845 Attn: Mr. Jeff Thomson, President Re: NORTH ANDOVER, CDLG TBI Recycling Facility 210 Holt Road North Andover, MA 01845 NERO R.O.#291858 Dear Mr. Thompson: The Massachusetts Department of Environmental Protection(MassDEP) is in receipt of the CY2020 C&D Annual Report for the TBI Recycling Facility C&D Processing Facility located at 210 Holt Road in North Andover, Massachusetts (dated 2/12/2021). This correspondence will serve as a preliminary status report of compliance with the MassDEP C&D Minimum Performance Standard(MPS) for CY2020. If you question the accuracy of the preliminary MPS status report,please contact Mike Elliott(michael.elliott@mass.gov) as soon as possible,but no later than Thursday(7/08/2021) so we can reconcile any differences. Please recall that one of the fundamental tenets of the MassDEP C&D Minimum Performance Standard(MPS) is to ensure that all C&D Waste materials are processed effectively at C&D handling facilities where all Waste Ban Materials are diverted from disposal. In so doing,we expect that the C&D processing industry will attain several program objectives including: leveling the playing field for all facilities; recovering maximum value from recyclable/re-usable materials; separating all Waste Ban Materials to the greatest extent possible; and, minimizing tonnage sent for disposal. To attain these objectives,the C&D MPS specifies two performance criteria: 1. Achieve a 15%Process Separation Rate (PSR)minimum threshold; and 2. Separate all banned materials to the greatest extent possible This information is available in alternate format.Call Michelle Waters-Ekanem,Diversity Director,at 617-292-5751.TTY#MassRelay Service 1-800439-2370 MassDEP Website:www.mass.gov/dep Printed on Recycled Paper TBI Recycling Facility CY2020 Preliminary MPS Status A C&D Handling Facility that fails to meet either performance criterion may not dispose or arrange disposal of any unprocessed or partially processed C&D materials. In that case, it can only continue operating by either accepting C&D residuals from MPS-compliant facilities for disposal, or by transferring all unprocessed or partially processed C&D waste materials to an MPS-compliant facility for further processing. Based on the information that you provided for CY2020, the TBI Recycling Facility(TBI) did not meet the MPS performance criteria as follows: Criterion No. 1: TBI operated at a 7.41%PSR' for CY2020,which is less than the 15% minimum threshold. Criterion No. 2: TBI reported separating metal, and wood; which are only two of the four regulated C&D waste ban materials (ABC, metal, wood and clean gypsum wallboard 2). MassDEP recognizes that CY2020 was a very challenging year for the solid waste industry. To address any potential COVID-19 impacts at C&D Handling Facilities, MassDEP evaluated the PSR for each facility in two ways: 1. calculated the PSR based on the full year 2020 data as normal; and 2. calculated the PSR for the full year less tonnages during the most severely impacted months of the pandemic, i.e. April,May and June of 2020. MassDEP then used whichever PSR calculation was the most favorable for the facility in determining MPS status.3 For C&D Facilities that are not MPS-compliant, this will serve as another reminder to contact your MassDEP regional office Solid Waste Section Chief as soon as possible to discuss the best pathway forward to achieve MPS compliance. By July 15, 2021 MassDEP must receive a written plan with measurable milestones on how the facility intends to achieve operational compliance with the MPS by year-end. (Refer to the contact information in the margin of the MassDEP Solid Waste Forms Webpage for the appropriate regional section chief https://www.mass.gov/service-details/massdg-solid-waste-forms. There's also a tool to help you find-your-region if you're not sure.) MassDEP intends to issue final MPS Status Report letters by the end of July 2021. C&D Facilities that are not MPS-compliant and have not submitted and obtained approval of a written plan to achieve MPS compliance by year-end, may be subject to compliance inspections and enforcement. More information on the C&D MPS is available on the MassDEP"Managing C&D Wastes" webnage(https://www.mass.gov/lists/managing-construction-demolition-cd-wastes)under the heading"Guidance: Other Materials&Activities". Please direct any questions about MPS status to 1 Used modified PSR calculation,see May-2021 C&D Subcommittee Meeting materials for explanation (https://www.mass.gov/lists/cd-subcommittee-meeting-archive#virtual-meetin -of-may-20,-2021-) 2 Clean gypsum wallboard must be separated upon arrival before further handling or transfer of loads,see Clean Gypsum Wallboard Guidance(https://www.mass. ovg /doc/gypsum-wallboard-waste-ban-miidance-cd-handling- facilities/downloadl s The quantity of inbound materials reported by TBI in response to RFI letter(9/02/2020)for the 1H2O20 monthly operational data exceeded the total inbound materials reported for the entire year in the CY2020 C&D Annual Report(2/12/2021),which of course is illogical;therefore,MassDEP could not evaluate the COVID-19 impact on operations in 2020. 2 TBI Recycling Facility CY2020 Preliminary MPS Status Mike Elliott via email at michael.elliott@mass.gov or by phone at 617-292-5575 (office) or 508- 243-9087 (cell). Sincerely, John Fischer Deputy Division Director Solid Waste Management cc: Mr. Brian J. LaGrasse, Director of Public Health, Town of North Andover Mr. Mark Fairbrother, SWM Section Chief, MassDEP-NERO Mr. Michael Elliott, Environmental Analyst, MassDEP 3