3424_CORR_ soils_response_20180329

March 29, 2018
Sent via email: [e-mail]

Randall Baker, General Manager
Abbey Green, Inc. and Overdale Holdings, Inc.
5030 Overdale Road
Winston-Salem, NC 27107

Subject: Sampling Analysis of “engineered soils”
Permit # 3424-TRANSFER-2010, Forsyth County

Mr. Baker:

On March 21, 2017, the Solid Waste Section (Section) issued Abbey Green a Notice of Violation (NOV)
letter resulting from violations observed during January 26, 2017 and February 7, 2017 inspections of the
facility. One of those violations arose from the management of stockpiled material on the South Site,
specifically the concept of “trommel overs” as described in the approved permit, and Section staff’s
observations of C&D waste materials, both in type and quantity, beyond the scope of what was detailed in
that approved permit. The material in question is derived from screened waste piles resulting from C&D
waste being bypassed on the picking line that the facility cannot or chooses to not recycle. C&D waste
materials larger than the existing screens are removed and taken to a permitted landfill for disposal while
smaller C&D materials mixed with soils and other residuals have been stockpiled on the South site. Since
that initial NOV, Section staff and facility management have participated in several meetings along with
various correspondence and submittals to resolve this issue in a manner that addresses both facility
operational and business needs and the Section’s statutory duty to ensure proper protection of human health
and the environment. A screening and sampling procedure that would provide the Section with analytical
data to further evaluate the material, provide compliance related feedback, and provide technical assistance
to Abbey Green related to the future management of the material was implemented by the facility and was
submitted in a report entitled “Product Test Report” (DIN 28793) on February 28, 2018.

The Section has completed its review of the sampling analysis. The following response does not address
other on-going discussions and submittals related to permitting and compliance between the Section and
Abbey Green related to this facility.

In the report, Arsenic was reported at concentrations exceeding the Inactive Hazardous Sites Branch (IHSB)
Preliminary Soil Remediation Goal (residential) of 0.68 mg/kg in 11 samples ranging in concentrations
from 1.86 mg/kg to 4.76 mg/kg. A TCLP analysis also indicated the presence of Lead at concentrations
above the 2L standard of 15 ug/l in two samples. In further evaluating those exceedances, EnviroTrac
completed a Health Risk Evaluation using the highest concentration of each metal detected from the
samples as data input for the DEQ Risk Calculator. The results of the Risk Calculator indicated the
constituents of concern were below the carcinogenic risk limit of 1.0E-4 (Table on Page 2 of 2/22/18 letter)
for all three receptor types (resident-child, non-residential worker, and construction worker).

Abbey Green
C&D Fines Response
Page 2 of 2
March 29, 2018

Based on our review of the information submitted, the Section conditionally approves the beneficial reuse
of the material as follows:

1. The material may be used as alternative daily cover at both C&D and Municipal Solid Waste
(MSW) landfills as an alternative to disposal. Criteria for acceptance and use of this material for
cover can be found in the Section’s alternative daily cover guidance document.

2. The material can be used as for beneficial fill as codified in 15A NCAC 13B .0562, provide that
Abbey Green provide notice to the Section of the proposed location and volume of material,
and the proposed use at least 7 days in advance. The Section reserve the right to request that the
receiving property be tested for concentrations of metals and may deny the request based on the
information submitted/collected.

This approval is not in perpetuity and is only for the existing stockpile of material located on the south site.
It does not apply to current and/or future generated soils material at this facility. We remain open to the
original idea of “trommel overs” at the South site and the ability to produce a material that could have other
alternative uses such as the production of engineered soils and/or compost. The Section believes getting
there starts at the gate and requires enhancements in strategy, process, and equipment as we’ve discussed.
Such enhancement may include, but are not limited to increased segregation at the picking line to cut down
on the cross contamination of the piles prior to screening, installation of equipment capable of screening to
a smaller size material and/or a secondary screening process, containerizing segregated materials, etc. The
reduction of C&D waste material(s) from the screening process on the front end can only help in removing
the contaminants of concern in this most recent report.

The Section remains committed to working with Abbey Green on the growth and success of your recycling
business, including management options for this material and others being produced at the facility currently
and in the future, as an alternative to landfill disposal. As such, we anticipate near term discussions and/or
submittals detailing operational changes being undertaken and/or planned to address the issue moving
forward.

Please let me know if you have questions.

Sincerely,

Jason M. Watkins, Branch Head
Solid Waste Section – Field Operations

Copies (via email): Ed Mussler, Solid Waste Section Chief
Roger Nielsen, Owner - Abbey Green
Susan Heim, Environmental Sr. Specialist – SWS
Deb Aja, Western District Supervisor – SWS
Ervin Lane, Hydrogeologist – SWS
Adam Ulishney, Environmental Compliance Branch Head - SWS