41J_HerritageFarmLCIDLF_Comment_PermitMod_App_FID1254638_20180912

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Chao, Ming-tai
From:Chao, Ming-tai
Sent:Tuesday, September 18, 2018 4:36 PM
To:'Mark Doggett'
Cc:Gary Swing; 'Gene Mustin'; 'Tim Benbow'; Patrone, John
Subject:Comments on Heritage Farm Properties, LLC, MAJOR LCID PERMIT 41J-LCID-2010
PHASE 2 REVISED
Dear Mr. Doggett:

FID 1254638

On September 12, 2018, the Solid Waste Section (the SWS) received an e-mail message, prepared on your
behalf by Tim Benbow, Borum, Wade, and Associates, P.A. (BWA), regarding the revision of phasing plan at
Heritage Farm Properties LLC LCID Landfill, Permit No. 41J-LCID-2010. A set of drawing drawings – Cover
Sheet & Sheet 1 through Sheet 6 of Sediment and Erosion Control Plan approved by Guilford County Planning
and Development Department on January 11, 2018 is attached to the September 12, 2018 email message. Per
NCGS 130A-294(a3)(3), this e-mail message and attached drawings are considered as a permit application (FID
1254610) for requesting an approval of the permit modification to the Permit To Construct and Operate (DIN
25336) dated December 10, 2015.

After conducting a review of the permit application, the SWS has some comments on the application; your
proper responses to the comments and providing the requested information will assist the SWS in processing of
the permit review in an effective and efficient manner.
1. Please provide the extent (in acreage) of the permit LCID Landfill as shown on Plan Sheet No. 1.

2. Please provide the requested info below which will be incorporated into the new permit if the permit
application is approved.
The waste capacity and waste footprint of each landfill phase.
Phase Gross Capacity (Cubic yard) Waste Footprint (Acre)
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Notes:
a. Gross capacity for each phase is defined as the volume of the landfill calculated from the
elevation of the initial waste placement through the top of the final cover, including any
periodic cover.
b. The waste footprint of Phase 2 shall exclude the required stream buffer areas and skimmer
basins as shown on Plan Sheet Nos. 2 & 3.

3. As shown Plan Sheet Nos 2 & 3, there is landfill titled as T.B. Doggett Construction Company Doggett
Demolition Landfill, Permit Number 654. Please provide the following information of this landfill:
i. The status of this above-mentioned landfill including the ownership, the operation history (date
for started receiving permitted waste for disposal and date for final closure), the acreage of the
waste disposal unit, the in-place waste volume (in cubic yard), the minimum lateral distance
from this disposal unit to the active LCID landfill.

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ii. Is this the demolition landfill located on Tax Map 1-37, block 850, parcel 24 and permitted by
Guilford County?

iii. The waste boundary of this landfill must be shown the Site Plan drawing.

iv. The copy of this landfill permit.

4. Per Rules 15A NCAC 13B .0564(8)(d) & .0565(1)(c), wastes in the landfill shall be placed a minimum
of four feet above the seasonal high-water table. Please provide the following info or report (s) in
addition to providing the descriptions/conclusions of how to determine the proposed landfill base
grades/elevations at Phase 2 as shown on cross-sections on Plan Sheet No. 6.
i. A copy of the soil boring logs for Borehole B-1 through Borehole B-6 as shown on Plan Sheet
No. 6.

ii. What is the highest water level in the unnamed tributary that is excluded from the proposed
landfill unit- Phase 2? Please provide the copy of the referenced document(s).

iii. What is the emergency spillway elevation of the lake (Existing Lake Permanent Detention Lake)
as shown on Plan Sheet No. 1?

5. Per Rule 15A NCAC 13B .0565(3)(k), please show the soil borrow locations for the landfill operations
and final cover construction on the site plan drawing.

6. Per Rules 15A NCAC 13B .0566(14) & .0565(3)(l), the operation plan must address how to
eliminate/prevent the wetlands/unnamed drainage features/tributary draining to the Haw River,
immediately adjacent to the disposal unit as shown on Plan Sheet Nos. 2 & 3, from contaminations -
such as leachate or windblown debris in the courses of the waste operations. Per NCGS 130A-
290(a)(16a), "leachate" means a liquid that has passed through or emerged from solid waste and contains
soluble, suspended, or miscible materials removed from such waste. If the drainage swale, earthen berm
or other BMPs will be used to comply with Rules 15A NCAC 13B .0566(10), (11) & (14), each BMP
location must be properly depicted and shown on the site plan or drawing sheet.

7. Per Rule 15A NCAC 13B .0564(6), a landfill shall not be located in any wetlands as defined in the
Clean Water Act, Section 404(b). Wetlands are identified and shown on drawing Plan Sheet No.
2. Please provide the approved document or documents with drawings to demonstrate the identified
wetlands are delineated by the U.S. Army Corps of Engineers (USACE).

8. The SWS record showed that Homer Wade with Borum and Associates, Inc. made a request to the
USACE of approval of installing a pipe underneath a landfill, owned by Mark Doggett, over an 800-
foot-long, 2 to 6-foot-wide portion of the unnamed tributary to the Haw River. The Nationwide Permit
No. 26 was issued on November 25, 1987 with permit conditions for this project. Please describe the
project location and status. The as-built information of this pipe including pipe size & material,
location, and profile (relative to the landfill base elevations) must be provided to the SWS.

9. According to the approved Operation Plan (DIN 25394) and the August 24, 2018 Facility Compliance
Inspection Report, several Miscellaneous Waste Management Units (MWMUs) are operating at the
landfill facility; these MWMUs are units for stockpiling waste concrete/concrete products and used
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asphalt, and a unit for conducting passive compost. Please provide the following info of above-
mentioned MWMUs:
i. The extent (in acreage) of each unit; the location of each unit must be shown on the drawing/site
plan.

ii. The maximum size (volume or tonnage) of each unit (both unprocessed and processed wastes) at
any time.

iii. For operating the passive compost unit, the following requirements must be added to the
operating plan.
a. High nitrogen vegetative wastes/yard trash (such as brush, leaves or grass cuttings) shall not
be composted at this unit. Only low nitrogen vegetative wastes/land cleaning debris (LCD) –
such as tree trucks and limbs can be permitted stockpiled at this unit.
b. The size of stockpiles or windrows must be approved by the Summerfield Fire
Department. The minimum fire isles between stockpiles or windrows must be 25 feet or the
clear distance approved by the Summerfield Fire Department.
c. The unit must have a minimum buffer of 25 feet away the property lines, the landfill disposal
units, or any drainage features.

iv. The narratives adding to the Operation Plan specify that operations at these MWMUs must
follow NCGS 130A-309.05 (c):
In order to qualify as a “recovered material” as defined in NCGS 130A-290(a)(24), the material
shall be managed as a valuable commodity in a manner consistent with the desired use or end use,
and all of the following conditions shall be met:
a. Seventy-five percent (75%), by weight or volume, of the recovered material stored at a facility
at the beginning of a calendar year commencing January 1, shall be removed from the facility
through sale, use, or reuse by December 31 of the same year.
b. The recovered material or the products or by-products of operations that process recovered
material shall not be discharged, deposited, injected, dumped, spilled, leaked, or placed into or
upon any land or water so that the products or by-products or any constituent thereof may enter
other lands or be emitted into the air or discharged into any waters including groundwaters, or
otherwise enter the environment or pose a threat to public health and safety. Facilities that
process recovered material shall be operated in a manner to ensure compliance with this
subdivision.
c. The recovered material shall not be a hazardous waste or have been recovered from a hazardous
waste.
d. The recovered material shall not contain significant concentrations of foreign constituents that
render it unserviceable or inadequate for sale, or its intended use or reuse.

10. The Closure Requirements of a LCID Landfill described on Plan Sheet No. 5 are not adequate. Please
add the additional rule requirements to the note field of “The Closure Requirements of a LCID
Landfill”:
i. Rule 15A NCAC 13B .0566(5) - 120 calendar days after completion of any phase of disposal
operations, or upon revocation of a permit, the disposal area shall be covered with a minimum of
one foot of suitable soil cover sloped to allow surface water runoff in a controlled manner. The
Division may require further action to correct any condition which is or may become injurious to
the public health, or a nuisance to the community.

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ii. Rule 15A NCAC 13B .0566(7) - Provisions for a ground cover sufficient to restrain erosion must
be accomplished within 30 working days or 120 calendar days upon completion of any phase of
landfill development.

Please contact myself if you have any question of the above-mentioned comments.

From: Tim Benbow <[e-mail]>
Sent: Wednesday, September 12, 2018 10:50 AM
To: Chao, Ming-tai <[e-mail]>
Cc: 'Mark Doggett' <[e-mail]>; Gary Swing <[e-mail]>; 'Gene Mustin'
<[e-mail]>
Subject: [External] Heritage Farm Properties, LLC, MAJOR LCID PERMIT 41J-LCID-2010 PHASE 2 REVISED

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Hello Ming-Tia, Please see attached plans for the above mentioned project. We have revised the plans and combined
Phase 2 and 3 from the original plans. There will now be only 2 Phases to this site. This plan has been approved by
Guilford County and The Town of Summerfield as far as site plan and erosion control. Please contact me with any
questions or any further information that you may need in order for us to proceed into Phase 2. Phase 1 will be
completed within the next 25 to 30 days.
Thank you,

Tim Benbow

Tim Benbow
Borum, Wade and Associates, P.A.
621 Eugene Court, Suite 100
Greensboro, NC 27401
Phone: [phone] x 113
Fax: [phone]
Email: [e-mail]
Website: borum-wade.com
Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]
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