3424_CORR_20170623

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

June 23, 2017

North Carolina Department of Environmental Quality
Winston Salem Regional Office
450 West Hanes Mill Rd.
Suite 300
Winston Salem, NC 27105

Originals to SH by mail with attachments. CCs by email only.

Attention: Susan Heim

Subject: Response to May 1st letter and progress toward unresolved NOVs

Dear Ms. Heim,

Addressing your letter of May 1, 2017 giving a status of corrective measures in progress toward
resolving Notice of Violations

NOV 1 (March 22, 2017) Abbey Green is in violation of 15A NCAC 13B .0302(3) for failing
to contain leachate on site and direct it to the public sewer.

Addressing your statement regarding our tipping floor trench drain: Abbey has, as part of our
standard operating procedures, a daily inspection of the tipping floor trench drain. We also
document the location of Unprocessed Mixed Debris on the floor that this is well below the drip
edge of the tipping floor cover. These conditions are documented in writing daily.

Regarding your request for Abbey Green to define “waste types such as Processed Residual
and Engineered Soil”, the Operations Manual does define these terms in Section 2.1.

Specifically addressing Processed Residual. Processed Residual is defined in our Operations
Manual 2.1 Overview and Definitions point 2.1.6 Processed Residual. It is a definition accepted
by the state as part of our permit.

Our Operations Manual Page 10 point 8) says:

“During Recycling Operations Processed Residual will be stored on the concrete
pad and open to the weather. Processed Residual must be loaded into transfer
trailers and tarped by the end of the day or moved to the covered tipping floor for
storage overnight. Processed Residual must be removed within a maximum of 5
days.”

So therefore, respectfully, Abbey Green does not agree with your finding.

However in the spirit of cooperation we will entertain the suggestion of incurring capital
improvement that will attempt to address your concerns. This will be a significant cost burden
for design and engineering services. If the Section is amenable we will start that process.
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PO Box 12339 Telephone: [phone]
Winston-Salem, NC 27117 www.abbeygreen.com Fax: [phone]

NOV 2 (March 22, 2017) Abbey Green is in violation of 15 NCAC 13B .0203(d) for failing to
maintain the tipping floor and loading area in a clean, and sanitary condition at all times.
[Inspections] revealed that accumulated debris in and around recovered materials stalls that are
staged below the picking line. . several container s were pulled and replaced without collecting
and removing the accumulated debris.

Your Facility Compliance Inspection Report April 4th lists this item as RESOLVED.

Your May 1st letter requests additional procedures to be included in the Operations Manual.
The Operations Manual already addresses the tipping floor under 2.6 Recycling Operations.
Abbey Green documents the condition of the floor and the trench drain in writing daily.

NOV 3 (March 22, 2017) Abbey Green is in violation of 15A NCAC 13B .0203(d) by:
- depositing drywall on site in an open area rather than on the tipping floor.
- allowing Unprocessed Mixed Debris to exceed the limits of the tipping floor.
- allowing Processed Residual to exceed the limits of the covered picking line
- depositing waste on an open area adjacent to what appeared to be the working
face of the LCID landfill.

Your Facility Compliance Inspection Report April 4th lists this item as RESOLVED.

Your May 1st letter requests that the Operations Manual list Tipping Locations in one area. The
Operations Manual has under 2.4 Debris Screening Program and Tipping Locations a
comprehensive set of instructions on how and where loads are received, screened, and tipped.
This procedure is in one place in the Operations Manual as you request.

NOV 4 (March 22, 2017) Abbey Green is in violation of 15A NCAC 13B .0203 (d) by storing
waste on-site in an uncovered transfer trailer.

Your Facility Compliance Inspection Report April 4th lists this item as RESOLVED.

Your May 1st letter requests that our Operations Plan requires that transfer trailers be leak-proof
while on site. The permit issued April 13th, 2016 includes this language under Point 20 in the
description of transfer trailers.

Abbey Green is and always has been aware that all transfer trailers, whether provided by a sub-
contractor or under the ownership of Abbey Green, be leak-proof. We inspect each trailer at the
end of the day to assure each trailer is tarped. We inspect each loaded trailer after loading for
leaks. Both conditions are documented in writing daily.

NOV 5 (March 22, 2017) Abbey Green is in violation of 15A NCAC 13B .0203 (d) for
generating fugitive dust emission from its main operations area, picking line, and
trommel.

Your Facility Compliance Inspection Report April 4th lists this item as RESOLVED.

Your May 1st letter requests that our Operations Plan specify the handling of leachate produced
when moistening Unprocessed Mixed Debris to reduce dust emissions. Abbey Green pushes
any water ponding in the area of the sealed storm water drain to tipping floor where it is
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PO Box 12339 Telephone: [phone]
Winston-Salem, NC 27117 www.abbeygreen.com Fax: [phone]
captured in the trench drain which is directed to the sanitary sewer. This condition is
documented in writing daily.

NOV 6 (March 22, 2017) Abbey Green is in violation of 15A NCAC 13B .0203 (d) for
allowing windblown materials to leave the facility boundary

This item is unresolved because of wind-blow on the South Site. The windblown material found
in the trees on April 4th has been removed and the wind-blown material along the stockpiled
Trommel Overs has been covered.

Your May 1st letter states that this item cannot be resolved until the South Site is resolved.
Therefore see Abbey Green’s comments and progress on NOVs 7 & 8.

NOVs 7 & 8 (March 22, 2017) Abbey Green is in violation of 15A NCAC 13B .0201 and
0203 for establishing a disposal site without a currently valid permit. Paraphrased the site
is storing material that does not meet the definition of Trommel Overs by both size and
definition.

We did commit in our April 21st letter to a goal of screening all Trommel Overs on the South Site
by June 28th. In the meeting at the Section Regional Offices in Winston Salem we stated that
the Sections opposition to activities on the Leased Site made it difficult for us to meet this goal.
Additionally we have experienced many days of rain in mid-April until present allowing screening
on just a few days. Therefore we will continue to screen daily as conditions permit and will
advise the Section of our progress.

Regarding your comments, I think it important that we repeat our response from our April 23rd
letter. Respectfully, at no time did we claim in writing or verbally that the contamination is “de
minimus” and we are not in agreement with the Section’s finding that the material on the South
Site does not meet the definition of Trommel Overs in Section 2.1.7 of the Operations Manual.

Quoting our response

“Abbey Green has processed Trommel Overs on this site since opening. The Section
was well aware of the character of this material at each previous inspection, and in
numerous on-site meetings the material seen is exactly the same as it has been since
Abbey Green opened. At no time did Abbey Green ever represent that no material
would be larger than 2 1/2 inches or that the material would not have some
contamination. The Section participated in the definition of Trommel Overs in the latest
permit issuance after these meetings.”

NOV 1 (April 4, 2017) Abbey Green is in violation of 15A NCAC 13B .0203 (d) for
conduction grinding operations on the Leased Site

Per your letter we have stored clean wood on this site in anticipation of the next grind cycle.

As requested we have attached the finalized site plan which will accompany the hard copy of
this letter. We had previously submitted a hand sketch with the same information.

We had previously stated in our April 21st letter that all engineered or glued woods would be
removed from this site by April 28th. Abbey reports this was accomplished as promised.

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PO Box 12339 Telephone: [phone]
Winston-Salem, NC 27117 www.abbeygreen.com Fax: [phone]
We respectfully have a different position on whether clean wood can be ground on the Leased
Site. However in the spirit of cooperation to resolve the Section’s concerns, we will execute one
wood grind cycle on this site that will only include clean wood.

We will then move wood grinding back to the North Site.

This will open the Leased site for Soil Processing.

Sincerely,

Randall Baker
Vice President and General Manager