3424_CORR_20170323

PO Box 12339 Telephone: [phone]
Winston-Salem, NC 27117 www.abbeygreen.com Fax: [phone]

March 23, 2017

Susan Heim
NC DEQ
450 West Hanes Mill Road
Suite 300
Winston Salem, NC 27105-9667

Copy attached to email

RE: Acknowledgement of receipt of the NOV and Inspection Reports dated March 21, 2017.
Statement regarding leased site activities

Dear Ms. Heim:

We are in receipt of both documents and will respond in writing in the coming days. Thank you
for a very productive conversation today on next steps. It has always been our intent to work
cooperatively with DEQ in addressing DEQ concerns regarding our organization. We have an
eight year history of doing so. We appreciate your attitude and trust that we will resolve these
issues highlighted in these documents in that same spirit.

All but two of the “Immediately” items 1. a) through n) in your letter were addressed by Abbey
Green directly after your inspection. We have taken steps in areas of concern that go beyond
your findings in some cases. Rather than document those now, we would ask that we review
these in a follow up visit from you now tentatively scheduled for my site on April 4, 2017. During
this meeting we intend to present our progress on all the “immediate” items, and, with your
support, agree on a course of action as required within 30 days of receipt of the inspection
report and NOV.

We believe it is important that we address one item in this letter. Regarding your request that
we adjoin our lease site land holders to our permit in a permit modification, we have the
following response:

The activities which will happen on leased sites specifically owned by 2M Associates LLC and
Hans Holdings LLC are related only to post processing of recovered recyclable materials and
storage of end product, specifically soil mixing and storage, concrete crushing and product
storage, wood grinding and product storage.

First, the permit and operations plan clearly states these activities will happen on the leased
sites. The Section has already agreed to these activities under the current permit without
adjoining these land owners as part of the permit.

Second, since there are no activities related to waste handling, transfer station activities, or
composting, we see no legal requirement to add these land owners to our permit under current
state regulations or guidance.

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PO Box 12339 Telephone: [phone]
Winston-Salem, NC 27117 www.abbeygreen.com Fax: [phone]
Very soon, in accordance with our permit, we will be moving our soil production to the North
Site, our wood processing and concrete crushing to the Hans Holding Leased site. This is
critical in the process of addressing DEQ concerns in other areas stated in your documents.

Please let me know if you need additional information. Thank you for your assistance, and we
are looking forward to the progress during and before your visit on April 4th, 2017.

Sincerely,

Randall Baker
Vice President and General Manager