3419_LowderRecycling_DisposalLLCFinalPermit Application_FID1377267_20191120

From:Chao, Ming-tai
To:Matt Alspaugh
Cc:Gene Lowder; Sheri Moissonnier; Stanley, Sherri; Heim, Susan A
Subject:RE: [External] RE: Permit Renewal Request for Lowder Recycling & Disposal, LLC
Date:Wednesday, August 14, 2019 10:49:00 AM
Attachments:image009.emzimage010.pngimage011.pngimage012.pngimage016.png
Dear Mr. Alspaugh: After completing a review of the permit application document/ Operations Plan (FID 1339168) dated August 09, 2019,the Solid Waste Section (SWS) has following comments on the application document: 1. Per North Carolina Solid Waste Management Rule (Rule) 15A NCAC 13B .0301(2) - An approval letter from theunit of local government having zoning authority over the area where the facility is to be located, stating that theproposed facility meets all of the requirements of the local zoning ordinance, or that the site is not zoned. Therule-required zoning approval letter for the waste operations at your facility is not available in the Solid WasteSection records/files. Please provide a copy of the zoning approval letter from the City of Winston-Salem/ForsythCounty.

(A. Introduction) Please provide the descriptions of the following establishments at the facility:
i. Security. The facility installed adequately secured by means of gates, chains, berms, fences, or otheracceptable means to prevent unauthorized entry for illegal dumping.
ii. Signage. A sign is posted and maintained at the site entrance providing information on the types ofacceptable wastes, permit number, and emergency phone number.
iii. Interior service road. Interior roadway must be of all-weather construction and maintained in goodcondition.
iv. A site location map. The map clearly shows the facility and surrounding drainage features, water bodies,surrounding establishments, buildings, roadways, etc.
3. (B. Material Received) The “Fill Dirt”a. must be an un-contamination earthen material and meet the “unrestricted use standards" - meaning contaminantconcentrations for each environmental medium that are acceptable for all uses per NCGS 130A-310.65; And b. shall have any contaminant with a concentration less than or equal to that in the NC Residential Health BasePreliminary Soil Remediation Goal (NC PSRG) which can be found in the web link:https://files.nc.gov/ncdeq/Waste%20Management/DWM/risk_based_remediation/PSRGs_May2019_FINAL.pdfPlease add the requirements to the Paragraph B. The copy of NC PSRG (Residential Health Base) must beappended to the Operations Plan. 4. (C. Handling and Storage of Materials – Item 5) Please use the correct agency title – North Carolina Department ofEnvironmental Quality.
5. (E. Processing of Materials) Please add the following requirement to this Paragraph E.
i. Open burning of solid waste is prohibited at this facility.
ii. Composting and curing are not permitted at the facility.
iii. Windblown materials must be collected by the end of each operating day, and no windblown material maybe allowed to leave the unit boundary according to Rule 15A NCAC 13B .0302(7).
6. (F. Standing Water) Please add the following operation requirements to this paragraph.
i. Please provide the latest site layout drawing with erosion and sediment control measures. The site layoutdrawing, which was dated May 13, 2003, revised May 25, 2006, and revised October 13, 2009 can beused if no revision is required.
ii. Surface water must be diverted from all operational and storage units to prevent standing water in and
around stockpiles. Water that comes in contact with solid waste is leachate as defined in N.C.G.S 130A-290(a)(16a); any leachate generated at the units must be managed to prevent contamination ofgroundwater and surface water.
7. (I. Daily Intake) Please also provide the maximum volume (including both raw material/unground waste) that thefacility will store at any time.
8. Per Rule 15A NCAC 13B. 0302(5), the Operations Plan must describe the procedures and measures to effectivelyimplement vector control measures that shall be applied to control flies, rodents, and other insects or vermin.
9. Operating Record. Copies of the valid permit, the approved plans, and all records required to be maintained by thefacility owner/operator must be maintained at the facility and made available to the SWS upon request duringnormal business hours. Please add this requirement to the Operations Plan.
Please provide the requested data/document and responses to the comments in the revised permit application document. If you have any question or request a further explanation/clarification to the comment, please feel free to contact myself. Thanks and have a wonderful day.

From: Chao, Ming-tai
Sent: Friday, August 09, 2019 2:45 PM
To: Matt Alspaugh <[e-mail]>
Cc: Gene Lowder <[e-mail]>; Sheri Moissonnier <[e-mail]>; Stanley, Sherri
<[e-mail]>; Heim, Susan A <[e-mail]>; Johnson, Mary H <[e-mail]>
Subject: RE: [External] RE: Permit Renewal Request for Lowder Recycling & Disposal, LLC

Dear Mr. Alspaugh:

Today the Solid Waste Section (SWS) received an Operations Plan (a total of 4 pages) for Lowder Recycling &Disposal, LLC, Permit # 3419-TP, dated August 11, 2019, and the SWS will review the document shortly. Have awonderful weekend.

From: Matt Alspaugh <[e-mail]>
Sent: Friday, August 09, 2019 2:33 PM
To: Chao, Ming-tai <[e-mail]>
Cc: Gene Lowder <[e-mail]>; Sheri Moissonnier <[e-mail]>; Stanley, Sherri
<[e-mail]>; Heim, Susan A <[e-mail]>; Johnson, Mary H <[e-mail]>
Subject: [External] RE: Permit Renewal Request for Lowder Recycling & Disposal, LLC

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]

Ming-Tai,

Please see the 2019 Operation Plan for Lowder Recycling and Disposal, LLC. Please confirm receipt.

This email and attached operation plan conclude all the requested information for our permit renewal. You have now received
all of the following:

Permit Application Page signed by Gene Lowder (owner)
$500.00 Annual Fee
Facility Annual Report for the period ending June 30, 2019 and it’s been approved
Operation Plan (attached)

Thank you for your help in this process and I would appreciate an email confirmation confirming Lowder Recycling & Disposal,
LLC has now submitted all appropriate parts to the permit application. Have a good Friday afternoon and enjoy your weekend!

Thank you,

Matt Alspaugh
Controller
Charles D. Lowder, Inc.GC License # 229362810 Griffith Road
Winston Salem, NC 27103336-760-0477

From: Chao, Ming-tai <[e-mail]>
Sent: Tuesday, June 11, 2019 3:36 PM
To: Matt Alspaugh <[e-mail]>
Cc: Gene Lowder <[e-mail]>; Sheri Moissonnier <[e-mail]>; Stanley, Sherri
<[e-mail]>; Heim, Susan A <[e-mail]>; Johnson, Mary H <[e-mail]>
Subject: RE: [External] RE: Permit Renewal Request for Lowder Recycling & Disposal, LLC

Dear Mr. Alspaugh:

The Solid Waste Section (SWS) received the completed application signature form which is a portion of the permitrenewal application. Although the SWS understood that you and Mr. Lowder are working on the rule-requiredsubmittals – annual fee payment and revised operations plan at this time. Until the completed permit renewal applicationis received, the SWS determines the received applicant signature form 1) is an incomplete permit renewal application 2)can’t be consider as a warranty for securing the facility permit renewal in the future. The SWS is looking forward toreceiving the complete permit renewal application by or before August 11, 2019 as required by the current permit. Thank you for your cooperation on this matter. Have a wonderful evening.

From: Matt Alspaugh <[e-mail]>
Sent: Monday, June 10, 2019 11:52 AM
To: Chao, Ming-tai <[e-mail]>
Cc: Gene Lowder <[e-mail]>; Sheri Moissonnier <[e-mail]>; Stanley, Sherri
<[e-mail]>; Heim, Susan A <[e-mail]>; Johnson, Mary H <[e-mail]>; Matt
Alspaugh <[e-mail]>
Subject: [External] RE: Permit Renewal Request for Lowder Recycling & Disposal, LLC
Importance: High

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[e-mail]

Please confirm receipt of the attached signed permit renewal application signature page for Lowder Recycling & Disposal. Please
confirm this is all that is immediately required to secure our permit renewal request.

We will be working to finalize our annual report and have it submitted in July along with the $500 annual fee.

We will also have our revised Operations Plan submitted this fall well in advance of the December 11 deadline.

If there is anything else needed at this time please let us know. Thanks!

Thank you, 
Matt Alspaugh
Controller
Charles D. Lowder, Inc.GC License # 229362810 Griffith RoadWinston Salem, NC 27103
336-760-0477

From: Chao, Ming-tai <[e-mail]>
Sent: Friday, May 31, 2019 9:40 AM
To: Matt Alspaugh <[e-mail]>
Cc: Gene Lowder <[e-mail]>; Sheri Moissonnier <[e-mail]>; Stanley, Sherri
<[e-mail]>; Heim, Susan A <[e-mail]>; Johnson, Mary H <[e-mail]>
Subject: RE: [External] Permit Renewal Request for Lowder Recycling & Disposal, LLC

Dear Mr. Alspaugh: The current permit to operate (DIN 22911) for Lowder Recycling & Disposal, LLC , Permit No. 3419-TP will expireon December 11, 2019; the Permit Condition No. 1, Attachment 3 of the permit requires the permit holder to submit apermit renewal application on or before August 11, 2019. It is the permit holder’s responsibility to comply with thepermit conditions without an official permit renewal notification, and there is no law or rule requiring the Solid WasteSection (SWS) to send out a reminder letter to the permit holder for renewing a permit. You request to receive a form or web site to direct you or your colleagues to prepare the permit renewal application.Attached please find the forms of permit application signature page; the completed form is considered as a portion of thepermit application document. The Solid Waste Section is no longer providing a permit applicant an official application guidance for applying a permitto operate a solid waste management facility because the guidance document does not have legal authority and can’tlegally stand in the court. The permit application must be prepared according to the State Laws and Rules. LowderRecycling & Disposal, LLC , Permit No. 3419-TP is a permitted treatment and process (T&P) facility, operating theexisting T&P facility, in a minimum, must follow the NC Solid Waste Management Rules 15A NCAC 13B .0301 &.0302. The rules for a treatment and process facility can be found in the web link: http://reports.oah.state.nc.us/ncac.asp?folderName=\Title%2015A%20-%20Environmental%20Quality\Chapter%2013%20-%20Solid%20Waste%20Management. Additionally, the NC General Statue (NCGS) 130A -309.05(c) must be followedto manage and handle recycled or recovered material. The statute can be found at the following weblink: https://www.ncleg.net/EnactedLegislation/Statutes/HTML/ByArticle/Chapter_130A/Article_9.html
Because Lowder Recycling & Disposal, LLC, Permit No. 3419-TP is a permitted facility, many rule-required documentsassociated siting and zoning are recorded and stored in the SWS. If there is no outstanding violation and/or the facility will and has not adding a new waste operating unit/activity tothe previously permitted waste operations and activities, the approved operation plan (DIN 22910) can be submitted as apermit renewal application. If there is operating violation in the past five years and/or the facility plans to add or correct one or more new wasteoperating unit/activity, you may use the previously approved operations plan as a template to incorporatemodifications/corrections to the existing waste operation and/or activities into a permit renewal application. For examplein June 2018, the permit holder designee requested a change of frequency to record/document waste amount received atthe facility; the request was approved on June 28, 2018 by the SWS (DIN 28818). I conducted a quick review of the pervious operations plan and found out several areas required additional informationprovided in the renewal application.
1. The facility accepted fill material. The earthen material must be properly defined. For example fill material is
clean, uncontaminated (see the definition below) soil or rock. Unpainted & uncontaminated concrete, concrete
products, concrete block. No liquid-form (or flowable) concrete is allowed. The un-contamination means that the
received earthen material shall have any contaminant with a concentration less than or equal to that in the NC
Residential Health Base Preliminary Soil Remediation Goal (NC PSRG) which can be found in the web link:
https://files.nc.gov/ncdeq/Waste%20Management/DWM/risk_based_remediation/Feb2018_PSRGs.pdf.
2. The fire occurrence report requirement. The standardized report form can be found in the web link:
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Forms/FireOccurrenceReport.pdf
3. Operating screening and grinding waste shall be prohibited in a raining or windy day.
4. According to the flood map – Map No. 3710681300J dated 01/02/2009, the facility is likely located inside 100 and
500-yr flood zones. The map can be found in the following link:
https://fris.nc.gov/fris_hardfiles/nc/hardfiles/DFIRM/067/DFIRM_NC_3710681300J.pdf. Although the rule is not
prohibit the facility operated in a flood zone, you have to address the requirement of Rule 15A NCAC 13B.0302(3) - Water that comes in contact with solid waste will be contained on-site or
properly treated prior to discharge from the site. A NPDES permit may be required
prior to discharge to surface waters in the flood event or the hurricane season.
Please be advised that the request of additional info shall not be considered as commencing an officially permitreviewing processes, and the SWS has not yet received any permit renewal application from Lowder Recycling &Disposal, LLC. Please also double check your accounting records for the past five years to ensure that the rule-required annual fee of$500.0, per NCGS 130A-295.8 has been paid to the Solid Waste Section. Upon receiving the permit renewal application, pursuant to NCGS 130A-295.3 the SWS will send you a compliancehistory review (CHR) forms which must be completed and returned to my attention. Failure to provide the correctcomplete information on the CHR forms may result in permit revocation.

From: Matt Alspaugh <[e-mail]>
Sent: Thursday, May 30, 2019 6:58 PM
To: Chao, Ming-tai <[e-mail]>
Cc: Gene Lowder <[e-mail]>; Sheri Moissonnier <[e-mail]>
Subject: [External] Permit Renewal Request for Lowder Recycling & Disposal, LLC

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]

Ming-Tai,

Based on the email received today from Susan Heim, we need to request a permit renewal for Lowder Recycling & Disposal, LLC
and have it submitted by June 10th. We have not received any paper or electronic correspondence regarding this renewal
process. Please email both me and Sheri (copied) the required form and/or the website with instructions as to what we need to
fill out and return. I will be out of the office tomorrow, but if you can send the information to both of us by EOB Friday, we can
work to get this renewal request properly filled out and returned next week.

Thanks so much for your help with this request! Have a good rest of your week and enjoy the weekend!

Thank you,

Matt Alspaugh
Controller
Charles D. Lowder, Inc.GC License # 229362810 Griffith RoadWinston Salem, NC 27103
336-760-0477

LOWDER RECYCLING & DISPOSAL, LLC

OPERATIONS PLAN

August 11, 2019

A. Introduction

Lowder Recycling & Disposal, LLC is located at 2840 Griffith Road Winston-Salem, North
Carolina. It operates on a 10.8 acre site that was resurveyed and recorded with Forsyth
County Register of Deeds on August 5, 2009 in plot book 56 page 152 (Attachment 1).
The deed for this property was recorded with the Forsyth County Register of Deeds on
May 31, 2000, prior to it being resurveyed. It can be found in deed book 2118 page 4543
(Attachment 2). Both the plot book and the deed list Lowder Recycling & Disposal, LLC
as the owner/grantee. Therefore, Lowder Recycling & Disposal, LLC is both the property
owner and operator of this facility.

Lowder Recycling & Disposal, LLC is a 10.8 acre site zoned GI (General Industrial) per
zoning letter # 149189 (Attachment 3). The facility is secured by a gate, a fence,
concrete barriers and natural boundaries to prevent unauthorized entry for illegal
dumping. A sign is posted at the entry gate that lists the types of acceptable wastes, the
facility’s permit number along with a contact phone number. The interior service roadway
is gravel and is maintained in good condition. Lowder Recycling & Disposal, LLC’s site
location map is an areal map that clearly shows all buildings, drainage features, bodies of
water and roads (Attachment 4).

Lowder Recycling & Disposal, LLC contact information:
Mailing Address: 2810 Griffith Road Winston-Salem, NC 27103
Office Phone: [phone] Office Fax: [phone]
Gene Lowder [e-mail]
Matt Alspaugh [e-mail]

B. Materials Received

Lowder Recycling & Disposal, LLC receives land-clearing waste and fill dirt. “Land
clearing waste” means solid waste which is generated solely from land clearing activities
such as stumps, trees, limbs, brush, grass, and other naturally occurring vegetative
material. “Fill dirt” must be an un-contaminated earthen material and met the
“unrestricted use standards.” Those standards mean contaminant concentrations for
each environmental medium that are acceptable for all uses per NCGS 130A-310.65 and
it shall have any contaminant with a concentration less than or equal to that in the NC
Residential Health Base Preliminary Soil Remediation Goal (NC PSRG) (Attachment 5).
Also, untreated and unpainted wood waste including pallets and other construction wood
waste will also be received. Yard waste is also permitted, but it must have a high C:N
ratio. Bulk grass clippings, bulk leaves, and bulk bush trimmings are not allowed.

C. Handling and Storage of Materials

1. Lowder Recycling & Disposal, LLC has controlled access and operating hours which are
7:00 a.m. to 5:00 p.m., Monday through Friday. The Yard Foreman’s mobile phone
number has been posted at the yard entrance gate to allow customer contact with him.
Upon arrival, all customer vehicles will be inspected prior to off-load. The customer will
be instructed on which area to off-load. Stumps may be stored in an area separate from
smaller debris. Likewise, debris with a minimum or no amount of dirt will be unloaded in
a different area of the stockpile. Although the stockpile will be continuous, areas within
the stockpile may be of different consistencies. (More dirt and less brush, clean brush
with no dirt, and stumps, etc.). This will allow Lowder Recycling & Disposal, LLC to
extract soil and stockpile the soils separately for future screening. By stockpiling large
stumps in a specific location, we will be more successful in separating the dirt ball from
the wood product.

2. Prior to dumping, should trash such as cups, bottles, plant containers and plastic, etc. be
observed, the driver will remove these items and place within one of the several trash
cans Lowder Recycling & Disposal, LLC will have available. Should metals be present,
the driver will remove them from his load and place in a large metal dumpster can. This
can is furnished by Atlantic Scrap Metal of Kernersville and is emptied on a will call basis.
The trash cans will be emptied into a trash dumpster located on the adjacent property
and will be picked up weekly by Waste Industries. In general, all materials received
which are not of land clearing debris nature will be disposed of or recycled; depending
upon the material. Should a load enter Lowder Recycling & Disposal, LLC and be heavily
contaminated with foreign materials, the load will be rejected and the driver turned away.

3. After off-loading, the load will again be inspected by our on-site Foreman. Should any
foreign material be present, the items will be picked up and properly disposed of as
previously described.

4. For recording purposes, an individual ticket is given to the customer for each load. This
serves two purposes. The first is for customer invoicing and for internal accounting.
Second is to record and maintain a detailed quantity of each type of material disposed at
this facility. Lowder Recycling & Disposal, LLC is currently converting land clearing
debris as 1000 pounds (0.5 ton) per cubic yard and clean yard waste as 400 pounds (0.2
tons) per cubic yard.

5. Truck loads are being monitored daily. All reporting to North Carolina Department of
Environmental Quality will be in tons. Business activity at Lowder Recycling & Disposal,
LLC is directly a function of weather and economic activities. We are expecting 40 cubic
yards (8 tons) on a slow day and 200 cubic yards (100 tons) of stumps and brush on our
busier days. Average daily intake is estimated at 20 tons per day. As previously
discussed, materials received will be stockpiled according to the amount of soils included
and size of stumps, etc. Most of the soil will be removed to minimize wear on the grinder.

D. Siting Criteria

The following setbacks shall be maintained at all times:
a) 50' to property lines (includes all materials)
b) 50' to surface waters
c) 200' to residential dwellings or commercial buildings not occupied by Lowder.
d) 100' from wells

The facility maintains structural control measures (berms, sediment basins, etc.) for
managing stormwater and erosion control on the site.
E. Processing of Material

Lowder Recycling & Disposal, LLC subcontracts the grinding of the land clearing debris.
Actual grinding takes place once or twice a year depending on supply and will not occur
on rainy or windy days. The grinding equipment will be set up at the northwest corner of
the stockpile and as the grinding progresses; the equipment (grinder, track loader with
rake, excavator with grapple) moves parallel to the stockpile in a southeastern direction.
A pile of “first grinds” (mulch) continue to be windrowed by a wheel loader (Deere 624K)
behind the grinding equipment. When the grinding starts, there are several machines
working with the actual grinder. Typically, a track loader with a root rake assists along
with a large excavator with a grapple. The two machines feed the grinder with debris free
of foreign materials including soils. Once the wood has been ground, the grindings exit
the machine via a conveyor. The grindings are then relocated to windrows using a
rubber tire wheel loader. If site conditions are somewhat wet, this relocation of grindings
may be accomplished using a track loader (CAT 953). The CAT 953 causes less rutting
of the grade and therefore is more favorable in wet conditions. The windrows, 10 feet
high with a base of 20 feet wide, are placed parallel to each other. An eight (8) foot drive
lane is always maintained.

Dependent upon the screener and grate sizes and the type of wood grinder, the wood
product may need to be ground twice. The “first grinds” after being placed in the
windrows will be periodically rotated. Rotation of the “first grinds” is a function of
moisture and temperature. When rotation time occurs, typically 2 to 3 times every six
months, the Deere 624K or CAT 953 are used. Should a “second grind” be necessary,
the grinding equipment is remobilized and progresses parallel to the existing windrows.
The “second grinds” are again windrowed approximately 10 feet high by 20 feet wide
(conical). Rotating of the windrows over the next six months will result in a uniform
product. These “second grinds” are now marketable mulch. The mulch is once again
moved from the back windrow to the closed windrow along Griffith Road for marketing.
This entire process requires twenty months. This includes the first grinding, windrowing,
rotating, the second grindings, windrowing, and selling.

Windblown materials must be collected by the end of each operating day and no
windblown material may be allowed to leave the unit boundary according to Rule 15A
NCAC 13B.0302(7).

Lowder Recycling & Disposal, LLC does not permit composting and curing at the facility.

Lowder Recycling & Disposal, LLC prohibits open burning of solid waste at the facility.

Temperatures are taken once a month using a 3-foot probe thermometer. The
thermometer is inserted into the top and bottom of the mulch pile every 50 linear feet
along the windrow. When temperatures reach 105°F, the windrow is rotated to avoid
combustion. Temperatures are recorded and placed in a book stored in the shop and
front office.

Should a fire occur within any stockpiles of material, NCDEQ Division of Waste
Management will be verbally notified within 24 hours of the occurrence. A written
notification will be properly submitted within 15 days of the occurrence.

F. Standing Water

Should sub grade rutting occur due to daily operations or stock piling of materials, the
area shall be back bladed and leveled to prevent vectors. Recent site improvements
shall assure positive drainage and water that comes in contact with solid waste will be
contained on-site. Surface water must be diverted from all operational and storage units
to prevent standing water in and around stockpiles. Water that comes in contact with
solid waste is leachate as defined in NCGS 130A-290(a)(16a); any leachate generated at
the units must be managed to prevent contamination of ground water and surface water.
A revised site layout drawing is included in the Operations Plan (Attachment 6).

G. Products from Grinding Process

The grinding process generates two products and will not occur on rainy or windy days.
First, with the initial grinding, there remains a large amount of soil and organic mixture.
This mixture is transported to the Power Screen 620 Trommell via a tandem/triaxle dump
truck and a Deere 624K loader. The mixture is then loaded into the Trommell using the
CAT 953 to separate the organic material from the soil. The resulting soil is a high-grade
topsoil. Secondly, the actual rotating of the windrows and “decomposition” of the mulch
results in a high-organic soil mixture. The mixture contains a high content of organics.
This mixture is transported via a dump truck and/or loader to the Trommell Screen. At
that time, the CAT 953 loads the Trommell and the Trommell separates most of the
organics from the soil. The material generated is a soil amendment. The soil
amendment can be used for planting.

H. Screener

The Power Screen Trommell is a mobile unit and is often moved within the facility.
Because of the area needed to operate the Trommell efficiently, the Trommell remains in
proximity to the western entrance. This is the same area used to “spread out” materials
for drying. As soil materials dry, they are screened to become a marketable product as
topsoil or soil amendment.

I. Daily Intake

We estimate a daily intake of twenty (20) tons of land clearing debris. Grinding will
occur one or two times a year, will not occur on rainy or windy days and should generate
approximately 1,800 tons per year. Based on economic conditions, daily tonnage
received will fluctuate/vary.

The maximum volume that Lowder Recycling & Disposal, LLC will store at any time is:

5,000 tons of land clearing debris (raw product)
7,500 tons of mulch (finish product)

J. Equipment to be Utilized

A list of all equipment to be utilized is as follows:

Tub grinder
CAT 953 loader with rake
CAT 325 excavator
John Deere 624K wheel loader
CAT 953 track loader
Komatsu WA 200-6 wheel loader
Ford tandem dump trucks
Mack triaxle dump trucks
Power Screen 620 Trommell
Ford F750 dump truck
Isuzu 5500 dump truck

K. Contingency Plans

1. Gene Lowder owns Lowder Recycling & Disposal, LLC as well as the adjoining
business, Lowder, Inc. Should any equipment fail, Lowder Recycling & Disposal,
LLC could obtain machines from Lowder, Inc. to aid in the processing of materials.
Should poor product market conditions persist, Lowder Recycling & Disposal, LLC
would stop receiving materials and increase advertising. We would offer specials to
promote sales of the mulch product.

2. A fire department is within 1.5 miles and Forsyth Medical Center is within 4.0 miles of
our facility. Should a fire or medical emergency occur, we would call 911.

3. Effective vector control measures shall be applied to control flies, rodents and other
insects or vermin.

L. Records for Inflow and Outflow

Record keeping will be established to show cubic yards of yard waste and land
clearing debris received. We will use the conversion of 0.2 tons per cubic yard for yard
waste and 0.5 tons per cubic yard for land clearing waste. This inflow and outflow will be
recorded in tons annually.

Copies of the valid permit, approved plans and all records required to be maintained by
Lowder Recycling & Disposal, LLC will be maintained at the facility and made available to
the Solid Waste Section upon request during normal business hours.