3419_INSP_20180605

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 5

UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost SLAS COUNTY: Forsyth
Closed
MSWLF HHW White
goods Incin T&P X FIRM PERMIT NO.: 34-19TP
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: June 5, 2018 Date of Last Inspection: June 6, 2017

FACILITY NAME AND ADDRESS:
Lowder Recycling & Disposal Facility
2840 Griffith Road
Winston-Salem, NC 27103

GPS COORDINATES: N: 36.036906° W: -80.313346°

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Gene Lowder, Owner
Telephone: [phone] (office)
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
Lowder Recycling & Disposal, LLC
2810 Griffith Road
Winston-Salem, NC 27103

PARTICIPANTS:
David Teague, Yard Foreman – Lowder Recycling & Disposal
Roger Mayhew – Lowder Recycling & Disposal
Susan Heim, Environmental Senior Specialist – Solid Waste Section

STATUS OF PERMIT:
Permit to Construct and Operate Solid Waste Treatment and Processing Facility Issued: December 11, 2004
Permit Renewal, Operations Plan Modification: December 11, 2009
Permit Renewal, Operations Plan Modification: December 11, 2014
Permit expires December 11, 2019 – submit permit renewal request by June 10, 2019

PURPOSE OF SITE VISIT:
Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
None

OBSERVED VIOLATIONS:

1. 15A NCAC 13B .0302(2) states: “A facility shall only accept wastes which it is permitted to receive.”

Lowder Recycling and Disposal, LLC is in violation of 15A NCNC 13B .0302(2) for receiving animal waste,
which is not listed as a permitted waste in the facility permit to operate (Permit # 3419-TP).

During the inspection of the facility on June 5, 2018, a large stockpile of horse manure was observed on the site,
adjacent to a pile of rock screenings.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 5

By June 15, 2018, Lowder Recycling and Disposal, LLC will properly dispose of the animal waste (horse
manure) and provide proof of proper disposal to the Solid Waste Section (send to the attention of Susan
Heim, Division of Waste Management, Winston-Salem Regional Office, 450 W. Hanes Mill Road, 3rd Floor,
Winston-Salem, NC 27105) in order to come into compliance.

ADDITIONAL COMMENTS

1. The facility is permitted as an LCID treatment and processing facility. Acceptable wastes are limited to land
clearing debris, untreated and unpainted wood waste, uncontaminated pallets and uncontaminated soil. Animal
waste is not acceptable. Ensure that animal waste (horse manure) is removed from the site for proper
disposal by June 15, 2018. (See Observed Violation section of this report for additional information.)
2. The facility’s Permit to Operate and approved Operations Plan (dated December 1, 2014) were available for
review onsite.
3. A review of the 2016-17 Facility Annual Report indicated that 2,304.2 tons of wood waste were accepted
during the reporting period, all which was generated in Forsyth County.
4. The facility produces five products for sale. Sales records for the period June 1, 2017 through May 31, 2018
were reviewed and indicated the following material output: field dirt – 5,639 cu. yds.; mulch – 2,976 cu. yds.;
topsoil – 2,432 cu. yds.; soil amendment – 152 cu. yds.; biomix – 784 cu. yds.
5. A waste ticket is produced for every load that arrives at the facility. Tickets list each type of material accepted
in the load and the volume of each in cubic yards. Tonnage is calculated for incoming waste on an annual basis
from these tickets using an average weight per cubic yard of 0.5 tons/cu.yd. for land clearing waste and 0.2
tons/cu.yd. for yard waste. Section L of the approved Operations Plan states that both inflow and outflow
will be recorded in tons weekly. Ensure that records are maintained as specified in the approved
Operations Plan, or request a modification of the Operations Plan.
6. The facility appeared to be clean and well maintained in most areas.
7. Weeds and brush had grown up in several places, including the areas surrounding both sediment traps and ditch
lines. The sediment trap on the southern end of the property appeared to be completely full of rain water. Mr.
Teague stated that the continual heavy rain events had kept the traps full for most of the past month. He added
that all of the erosion control and stormwater management devices are inspected after every measurable rain to
make sure the system is functioning properly. Ensure that drainage ditches, check dams, sediment traps and
berms are cleaned and maintained regularly so that they conform to the design shown on the approved
facility site plan (dated October 13, 2009).
8. Access roadways are of all-weather construction and adequately sized to allow customers and staff to maneuver
safely.
9. Entrance to the site is limited to one gate, which is kept locked when the facility is not in operation, thus
prohibiting unauthorized access. At the time of the previous inspection on June 6, 2017, the site could be
accessed from the adjoining office entrance. This access point was eliminated by the installation of a concrete
block barrier.
10. Proper signage was posted at the entry gate.
11. Mr. Teague stated that any trash found in loads is given back to the customer for proper disposal. He added that
very little unacceptable material is received at the facility.
12. Unacceptable material, in the form of several pieces of metal and a piece of treated lumber, were noted in a pile
of unscreened soil. Remove all unacceptable waste from material stockpiles. Trash and unacceptable
waste must be stored in a water-resistant covered container until it is removed from the site for proper
disposal.
The item(s) listed above were observed by Section staff and require action on behalf of the facility in order to come into or maintain compliance
with the Statutes, Rules, and/or other regulatory requirements applicable to this facility. Be advised that pursuant to N.C.G.S. 130A-22, an
administrative penalty of up to $15,000 per day may be assessed for each violation of the Solid Waste Laws, Regulations, Conditions of a Permit,
or Order under Article 9 of Chapter 130A of the N.C. General Statutes. Further, the facility and/or all responsible parties may also be subject to
enforcement actions including penalties, injunction from operation of a solid waste management facility or a solid waste collection service and any
such further relief as may be necessary to achieve compliance with the North Carolina Solid Waste Management Act and Rules.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 5

13. Wood waste is screened daily when possible. Mr. Teague explained that operations had been very sporadic over
the past month due to continual heavy rain events. No processing operations were taking place at the facility
during this inspection.
14. Piles and windrows in the processed wood storage areas were well defined and appeared to meet the size
restrictions set forth in the approved Operations Plan (dated December 1, 2014) of 10’ high and 20’ wide at the
base. Windrows are placed parallel to each other in the southern portion of the facility with 8’ fire lanes, as
indicated in the Operations Plan, thus allowing easy access to all areas. Mr. Teague explained that piles are
turned at a rate that ensures no composting takes place at the site. No hot spots or steam were observed in the
piles.
15. A temperature log is maintained for each windrow and includes monthly temperature readings from the top and
bottom of each windrow. Temperature records for the period June 1, 2017 through May 31, 2018 were
reviewed. No instances of temperatures above 100° F were recorded during this time period.
16. Some ponded water was observed between the pile of animal waste (horse manure) and the stockpile of rock
screenings. Mr. Teague stated that ponding water had been a problem in various areas of the site due to the
continual heavy rain events that have occurred over the past month. He stated that he would ensure the area was
regraded and repaired to prevent water from accumulating there. Please perform maintenance in this area to
ensure that ponding is eliminated, as specified in Section F of the Operations Plan.
17. Stockpiles of unprocessed soils were found throughout the site. Mr. Teague stated that the facility takes in clean
dirt from construction projects, then screens to dirt to remove plant material and rocks. The screened soil is then
sold as is or mixed with processed wood waste to produce a soil amendment product that is then also solid to
the public.
18. The required buffers appeared to have been met in all areas of the facility. A sign is posted on the southern end
of the property, adjacent to Griffith Road, that marks the 50’ buffer line to assist facility staff in maintaining the
required setback for the processed and unprocessed wood waste stored on the site.
19. A follow-up inspection will take place to ensure that the required maintenance tasks listed above are
performed in a timely manner.

View of the sediment
trap located at the
southern end of the site
adjacent to Griffith
Road. Note the
vegetation growing in
and around the basin
and the green scum
covering the top of the
water.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 5

Windrows of processed wood
waste are of a manageable
size with the 8' lanes between
piles as required.
Water can be seen ponding in between a pile of animal waste (left) and rock screenings (right).
Animal waste (horse manure) is not permitted to be accepted at this facility.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 5

Please contact me if you have any questions or concerns regarding this inspection report.

_______________________________________ Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative

Sent on: June 8, 2018 to Gene
Lowder.
X Email Hand delivery US Mail Certified No. [ ]

Copies: Deb Aja, Western District Supervisor – Solid Waste Section
Ming-Tai Chao, Permitting Engineer – Solid Waste Section