4117_A1SandrockCDLF_ResponsetoComments_PTC_Phase3_FID1277341_20190116

1
Chao, Ming-tai
From:Chao, Ming-tai
Sent:Monday, January 14, 2019 10:19 AM
To:Garrett, David
Cc:Stanley, Sherri; Watkins, Jason; Kirchner, Chuck; Ritter, Christine;
'[e-mail]'
Subject:RE: [External] A-1 Facility Plan
Hi David:

Good morning. I just quick scanned through the submitted two drawings that you sent in last Friday evening. It
looks to me the soil stockpiles on the west side of the Phase 3 have been revised from two rectangular shapes to
several circular shapes. I don’t think it is the corrected stockpile configuration based on 01/07/2019 site
observation. On 01/09/19 e-mail, Ronnie complained that removing/relocating soil and waste stockpiles around
to allow the gas well installation and monitoring on the west side of Phase 3 is an unreasonable request, now the
revised drawing shows the stockpiles will be relocated or reshaped. I need to know if it is final decision.

Are you ready to respond the comments/clarifications stated in my e-mail 01/09/2019? I also mentioned in
01/07/19 meeting that the copy of a complete permit application is required, not piece-wise document. To do
so, I can dedicate my time focus on the application review without distraction from locating other permit
application document. Thanks.

From: david garrett <[e-mail]>
Sent: Friday, January 11, 2019 4:58 PM
To: Chao, Ming-tai <[e-mail]>; Ritter, Christine <[e-mail]>; Garrett, David
<[e-mail]>
Subject: [External] A-1 Facility Plan

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Per our discussions.

--
G. David Garrett, PG, PE

Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]
78 FT (VARIES)32 FT (TYP.)SEAL25462102030TENTHSINCHES123DWG SIZEREVISIONFORDRAWING NO.TITLEFILENAME:DWG TYPE:JOB NO:DATE:SCALE:DES:CHKD:ENGR:APPD:AFEDCB234578645789106AFCB22"x34"ANSI DSEALREVDATEJOB NO.PROJECT TYPEDESDFTRCHKDENGRAPPDDESCRIPTIONDWG6468-17-7032AS NOTEDASAGDGGDGA7/20/20176468-17-7032FACILITY PLANGDGASAGDGGDGISSUED FOR PERMIT REVIEWBSEPTEMBER 8, 2017A-1 SANDROCK MASTER DRAWINGDFTR:A-1 SANDROCK, INC., CDLFPHASE 3 PERMIT TO CONSTRUCT MODIFICATIONSOLID WASTE PERMIT 4117-CDLF-2008GUILFORD COUNTY, NCPERMIT REVIEWB8/20/20186468-17-7032FACILITY PLANGDGASAGDGGDGUPDATED PER PERMIT REVIEW4021 STIRRUP CREEK DRIVE, SUITE 100DURHAM, NC 27703 TEL: [phone]LICENSURE:NC ENG: F-1253 NC GEOLOGY: C-247Environment & Infrastructure SolutionsS1 - FACILITY PLANCDLF PHASE AREAS AND VOLUMESPHASEAREA (AC)ïVOLUME (CY)ð111.38470,33226.52608,19237.60641,72640.00519,750TOTAL25.502,240,0001 AREA IS CONSISTENT W/ ORIGINAL PERMITTING2 VOLUMES VARY BY <10% FROM ORIGINAL PERMITTEMPORARY STOCKPILE AREASIDENTIFIERAREA (AC.)PURPOSEVOLUME (C.Y.)3A1.74CONCRETE12,000B1.12LCID PILE6,000C1.95WNDROWS6,000D1.54OPS. SOIL10,000E1.80OS. SOIL12,0003 REFER TO GENERALIZED PILE DIMENSIONS TABLE
2
"You're never too old to have a happy childhood."
Bruce Meyer, automobile collector
1
Chao, Ming-tai
From:Garrett, David <[e-mail]>
Sent:Wednesday, January 16, 2019 2:49 PM
To:Chao, Ming-tai; Ritter, Christine
Cc:Ronnie Petty
Subject:[External] A-1 Sandrock Facility and Operations Plan
Attachments:Response to Draft Comments and Emails.pdf; A1 Facility Plan Phase 3 FINAL.pdf;
Historical Exhibit 1 Drawings.pdf; Historical Exhibit 2 Photos.pdf
CAUTION: External email. Do not click links or open attachments unless you verified. Send all suspicious email as an attachment to
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Please find attached a response to comments recently received and a revised text addressing these issues. Drawings are
scheduled for delivery to your office today. A full updated application submittal will be forwarded as a “package”
download later today. Thank you for your input – and patience.

Please note our @AmecFW email addresses are being replaced with @woodplc addresses.

David Garrett, PG, PE
919-418-4375 (mobile)
919-765-0070 (direct office)

Environment & Infrastructure Solutions
4021 Stirrup Creek Drive, Suite 100
Durham, NC 27703 TEL: [phone]

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A-1 Sandrock Phase PTC January 11, 2019
Response to Comments Page 1
RESPONSE TO DRAFT COMMENTS RECEIVED 1-4-2019

1. (Section 1.1.1) This subsection mentioned A-1 Sandrock, Inc. is renegotiating the Franchise
Agreement with the Guilford County. What is the status of this agreement? Please provide the
SWS a copy of new or amended Franchise Agreement.

Response: This is addressed in Comment 3 under Response to Email Comments of 1-9-2019.

2. (Sections 1.4, 5.4, 6.4.5) Regarding the proposed processing and temporary storage areas -
labeled as Areas A through E on Drawing S1, please provide additional information and address
the following concerns:
i. The processing and storage areas are treatment and processing (T&P) facilities, as defined in
Rule 15A NCAC 13B. 0101(49), which are not qualified to obtain a life-of-site permit as
defined in NCGS 130A-294(a2); therefore, the SWS may determine that A-1 Sandrock, Inc. is
required to operate the T&P areas according to Rule 15A NCAC 13B.0302; a 5-year permit
approval to operate for operating these T&P units may be granted to A-1 Sandrock, Inc.

Response: As stated in the 01/07/2019 Memo (email from D Garrett to M Chao), Treatment and
Processing Areas A – C and Storage Areas D and E shall be labeled on mapping to identify
what types of activities and materials will occur. Please note that the facility operation is a
dynamic process, prone to changes as market conditions dictate. As presently understood,
the designated uses are as follows:

• Area A will be the concrete T&P area, with storage of up to 12,000 c.y. of unprocessed
material and periodic crushing/grinding taking place;
• Area B will be the unprocessed LCID area, with temporary storage of approximately
6,000 c.y. subject to annual processing (grinding) or relocation of materials and access
requirements for firefighting;
• Area C will be the used for curing mulch in windrows (observed on 1-7-2019), subject to
access requirements for firefighting, whereas the cured materials may be screened prior
to relocation in finished bin storage located in a sales area outside the Facility Boundary;
• Areas D and E will be used for temporary storage of soil and aggregates in stockpiles to
support landfill operations (estimated maximum quantities of 35,426 c.y. and 54,572
c.y., respectively, based on current estimated volume of soil), subject to six-month
relocation of materials and maintaining access for monitoring and emergency
operations (~50 feet from groundwater wells, ~40 feet from LFG wells).

Please note changes to Drawings S1 and EC5. Please also note that soil stockpiles observed
on 1-7-2019 are not “mining refuse” or any type of waste product; these soils are the
overburden from Phase 3A rough grading. The stockpiled soils will be used for cover or
future construction activities. Appropriate E&S measures shall be implemented ASAP.

A-1 Sandrock Phase PTC January 11, 2019
Response to Comments Page 2
ii. The existing erosion and sediment control plan (E&SCP) is a part of the mining permit
(Permit #41-22) which expired in November 25, 2012. The termination of the mining permit
will not relieve the responsibility of A-1 Sandrock, Inc. to conduct approved E&SCP for the
activities related to mining reclamation; but the proposed T&P areas (Areas A through E)
including storage and processing are not included in the originally approved E&SCP. A
permit modification to the existing permit may be required, and the BMPs and related
hydraulic/hydrology calculations must be submitted to NC LQS for a review and approval.

Response: This is addressed in Comment 1a under Response to Email Comments of 1-9-2019.

iii. The Permit Application states that “inert concrete debris, aggregate, soil will be stored for
longer periods without limitation.” The stated waste streams are considered as recovered
material from the approved waste recovery at the existing treatment and procession facility;
therefore, the statement of storage period violates the requirement set forth in NCGS 130A
309.05(c)(1) - 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.

Response: This is an unfortunate choice of words. As stated in the 01/07/2019 Memo (email from D
Garrett to M Chao), the reference to “unlimited use” pertaining to the stockpiles was
clarified to mean the sizes of the stockpiles; earlier permits stemming from the original 2-
acre notification had placed a 6,000 c.y. limit on material storage. That language will be
removed from the Operations Plan and clarified with A-1’s understanding that material-
dependent limitations will apply, driven by the financial assurance requirements as may be
necessary for the type of material and the need for moving 75% of the materials within a
calendar year.

iv. The locations of the proposed T&P areas must not interfere rule-required environmental
media monitoring networks and buffer requirements.
a. Please show the buffer distance between proposed T&P locations (Areas A, B, & C) and
nearby drainage features and the facility property lines per the City of Greensboro Land
Development Ordinance and Sedimentation Control Act N.C.G.S. 113A-50, et seq.

Response: Based on recent online research, the following information was gathered:

“The [Guilford County] Watershed Protection/Stormwater Management Section is
responsible for the Watershed Protection for Guilford County’s nine (9) drinking water supply
watersheds. In addition to Watershed Protection duties the Section is charged with the
enforcement of the Jordan Lake Rules and National Pollutant Discharge Elimination System
(NPDES) Phase 2 rules for the County (which includes non-watershed areas), public education
A-1 Sandrock Phase PTC January 11, 2019
Response to Comments Page 3
of stormwater issues, detection and elimination of illicit stormwater discharges, Floodplain
Management and permitting, State mandated annual inspections of water quality devices,
and staffing the Environmental Review Board, a citizen environmental group. “

https://www.guilfordcountync.gov/our-county/planning-development/watershed-
protection-stormwater-management
and
https://www.guilfordcountync.gov/our-county/planning-development/watershed-
protection-stormwater-management/watershed-protection/manuals

According to the documents, “. . . the North Carolina Division of Water Quality Stormwater
Best Management Practices Manual, http://h2o.enr.state.nc.us/su/bmp_forms.htm

and the GUILFORD COUNTY ADDENDA,
https://www.guilfordcountync.gov/home/showdocument?id=6406

both will further be known as the latest addition of the
Guilford County Water Quality Protection Manual . . . “
as referenced in the
Development Ordinance for County of Guilford, North Carolina
https://www.guilfordcountync.gov/home/showdocument?id=6420

This clarifies jurisdiction as Guilford County, not the City of Greensboro. The referenced
information stipulates a 50-foot riparian buffer on jurisdictional streams within the
Randleman Reservoir watershed, along with protective measures along the buffers. The
riparian buffers are shown on the Facility Drawings.

b. The proposed T&P areas will be seated in the C&DLF buffer zones. Please explain why
this proposal will not be negatively impacting or interfering the C&DLF operation such as
windblown waste collection, dust mitigation, the site-wide environmental media
monitoring network (Areas D & E will be seated at the following gas well locations - LG-
1, LG-2, LG-3, and LG-12).
G
Response: This is addressed in Comment 1b under Response to Email Comments of 1-9-2019. Setbacks
from future landfill gas monitoring wells of ~40 feet shall be observed and ~50 feet from the
existing or future groundwater monitoring wells. Please note changes to Drawings S1 and
EC5. Soil stockpiles will require E&S measures, typically including covering the stockpiles
with vegetation, mulch or rain sheets, will serve a dual-purpose by limiting fugitive emissions
(dust and debris) originating from the stockpiles; the height and side slopes of the stockpiles
will be kept such that they may be accessed for litter collection.
A-1 Sandrock Phase PTC January 11, 2019
Response to Comments Page 4

v. Paragraph 4 of the Section 5.4 states that “Areas A-E are not to be used for permanent
storage or disposal of material, except for clean soil and natural rocks.” The SWS determines
this practice is a waste stockpile/storage which does not meet a use for beneficial fill as
required in Rule 15A NCAC 13B .0562(3) - the purpose of the fill activity is to improve land
use potential or other approved beneficial reuses. A-1 Sandrock, Inc. must demonstrate the
fill activities satisfactory to the rule requirement. Additionally, unknown quantities of mining
refuse or spoil that are generated from the long-term mining activities at this facility and
likely stockpiled in the future C&DLF-Phase 3 area must be properly managed through the
approved Reclamation Plan in the mining permit for this facility per the North Carolina
Mining Act, NCGS 74-53.

Inert debris including clean concrete, soil, rock, and mining refuse or spoil may be
considered as:
a. “recovered material,” if the material can be meet the requirements stated in NCGS 130A
309.05(c).
b. “beneficial fill,” if the material can meet all requirements stated in Rule 15A NCAC 13B
.0562. Provide drawings to show the detail topographic contours, in a minimum of two
cross-sections, one each along each major axis, per beneficial fill area showing: (i)
original elevations. (ii) proposed final elevations and side slopes.

Response: Please refer to the response for Comment 2i; Areas A – E shall be used for temporary storage
only and T&P activities as described above. The indicated section of the Operations Plan is
so-amended.

vi. The Section 6.4.5 describes the proposed processing and storage units. Per Rule 15A NCAC
13B .0537(b), the specific name (waste streams)/function of each of the five proposed T&P
units must show on the Drawing S1.

Response: The requested amendments are made within the indicated section of the Operations Plan
and Drawing S1.

3. (Table 6A) Since the waste stream – sludges of any kind are added to the prohibited waste list,
the waste stream – all sludges except sludge from wastewater treatment plants should be
removed from this Table 6A to eliminate any confusion.

Response: The requested amendments are made within the indicated section of the Operations Plan.

4. (Section 8.1.2 & Drawing EC5) The typical details of the proposed passive gas venting system as
described in Section 8.1.2 should add to the Drawing EC5.
A-1 Sandrock Phase PTC January 11, 2019
Response to Comments Page 5

Response: The requested amendments are made within the indicated section of the Operations Plan
and Drawing S1.

5. (Drawing S1)
i. Please show the access/path to reach the proposed T&P areas – Areas B & C. If the stream
crossings are required, please provide the approved designs from a regulatory agency.

Response: The access path to Areas B and C were vestiges of earlier site use, i.e., silviculture in this
portion of the site. E&S measures and the stream crossings were approved and have been in
place for years. To fulfill this request, A-1 is commissioning an upgrade of the Facility Erosion
and Sedimentation Control Plan, which will be presented to either DEMLR LQS or Guilford
County Planning Department. As stated in Item 6 of the 01/07/2019 Memo (email from D
Garrett to M Chao), a determination of jurisdiction is being studied with these agencies.

ii. The proposed T&P Area C is immediately adjacent to an industrial facility and a residential
setting. Is there a physical security measure (such as fencing) to prevent/deter any illegal
waste dumping at this Area C per the City of Greensboro Land Development Ordinance?

Response: A-1 Sandrock is located on property zoned HI, with a land use classification for the T&P site
as 4. According to Guilford County GIS tax records, the property east of T&P Area C is zoned
HI (asphalt plant) with a land use classification of 5. The group of lots between A-1 Sandrock
and the Bishop Road are now/formerly zoned R, but all are owned by A-1 Sandrock except
the landlocked parcel (vacant); the lot with road frontage between A-1 Sandrock and the
asphalt plant is vacant and heavily wooded (current owners are not likely to allow a
residence to be built there). Guilford County setback and planting yard requirements for the
T&P site adjacent to the asphalt plant is 5 feet. A-1 believes the setback is compliant. No
development on the other sites is involved with this permit application. Natural barriers
preclude any feasible access by automobiles to A-1’s properties via the adjacent properties.

RESPONSE TO EMAIL COMMENTS RECEIVED 1-9-2019

1. Non-disposal waste management units - Areas A through E
a. The existing E&S plan are associated with the mining operations (Permit # 41-22), which
expired according the permit application and the CDLF operations permitted as reclamation plan
through the Solid Waste Section (SWS). The non-disposal units (Area A through E) are not
included in the originally approved E&S plan (DIN 20125) as stated in the 01/04/2019 draft
comment No. 2.ii. A-1 Sandrock, Inc. as the permittee has the responsibility to obtain an
approval of modification to the E&S plan by incorporating the required BMPS for the non-
disposal units.
A-1 Sandrock Phase PTC January 11, 2019
Response to Comments Page 6

Action item: Discussions in Memo No. 6 will serve as the notification of intent but a revised E&S
plan and final approval must be expeditely obtained from either NC Land Quality Section or
Guilford County without further delay because the so-call “proposed” non-disposal units have
been constructed and operated without any approval from the SWS and the modified E&S plan
approved by the NC LQS or Guilford County.

Response: As a point of clarification, the non-disposal units A-E may not be called out as such in all
earlier permitting documents; however, the original permitting drawings, including solid
waste and mining, show the E&S measures that were originally designed, permitted and
built to the satisfaction of the DEMLR, Land Quality Section, under the mining permit. Please
refer to Exhibits 1 and 2, which respectively document continuity of the measures as shown
on the plan sets over the years and the original construction.

The concrete stockpile (Area A) was shown in drawing set sealed August 12, 2013 for a PTO
renewal (during Phase 1 operation) and was present for multiple SWS inspections. Recent
SWS inspections acknowledged (even complimented) the relocation of the LCID Treatment
and Processing operations to Areas B and C as a matter of public safety.

As follow up to the Action Item, A-1 will initiate a permit application for either updating the
E&S permit with DEMLR or establishing a new E&S permit with Guilford County. This effort
will commence as soon as practical and is expected to be completed in time for making
application for the PTO. As a matter of record, A-1 has maintained a NPDES permit since the
facility opened.

b. Stockpiles of earthen material (a quite amount of earthen material) located on the east side
of CDLF Phase 3 were observed during the site walk on 01/07/2019; the stockpiles are located at
the proposed locations of LFG gas wells. The 01/07/2019 Memo does not mention the solution
of how to prevent the stockpile of soil/mining spoil from interfering rule-required monitoring of
environmental media such as groundwater and landfill gas.

Action item: A-1 Sandrock, Inc. must revise the LFG Monitoring Plan to place the proposed
landfill gas wells around the Areas D & E (as mentioned in the draft comment No 2.iv. a & b) so
that the gas monitoring activities will not be interfered by the waste management activities. Or
any protection measure or physical structure to protect the monitoring network and access
toward monitoring points should be provided in the plan/drawings. A-1 Sandrock, Inc. must
inform the SWS when the protection device/structure is completed constructed which will be
subjected to a site inspection.

A-1 Sandrock Phase PTC January 11, 2019
Response to Comments Page 7
Response: Per the discussion of January 7, 2019, A-1 intends to locate the LFG wells approximately 10
feet inside the Facility Boundary. This provides a minimum separation between soil stockpile
activities and the LFG monitoring wells (LFG-12, LFG-1 and LFG-2) of 40 feet and at least 50
feet from the groundwater monitoring well (MW-1). Only access drives to the wells will be
allowed within these setbacks. The wells shall be protected with bollards or large rocks
placed as barriers. This monitoring location map (Drawing M1) has been amended to show
the approximate limits of the temporary soil stockpiles (Areas D and E) along with required
setbacks to protect the wells. For the record the 01/07/2019 Memo (email from D Garrett to
M Chao) was intended to serve as a reminder for what was discussed at the meeting, not a
response to the Draft Comments received 1-4-2019.

2. Financial assurance
The SWS may conditionally approve the FA reduction as mentioned in Memo No. 5 and e-mail
requests dated 12/21/2018 & 01/02/2019at this time, which consists of
- Costs for closure of Phases 1, 2, 3, & 4 of the CDLF, 25.5 acres, in the amount of
$1,567,363.00.
- Costs for 30-yr post closure cares of Phases 1, 2, 3, & 4 of the CDLF, 25.5 acres, in the
amount of $668,490.00. LFG monitoring via gas wells.
- PACA in the amount of $1,128,666.00.
The total FA amount in 2018-dollar value is $1,797,156.00.

But should A-1 Sandrock fail to complete the installations of 12 gas wells by April 2019, the SWS
will rescind/revoke this agreement of FA reduction. And the total FA amount must be increased
to $2,416,356.00, which consists of
- Costs for closure of Phases 1, 2, 3, & 4 of the CDLF, 25.5 acres, in the amount of
$1,567,363.00.
- Costs for 30-yr post closure cares of Phases 1, 2, 3, & 4 of the CDLF, 25.5 acres, in the
amount of $1,128,666.00. LFG monitoring via the bar-hole punch method.
- PACA in the amount of $1,128,666.00.

Action item: A-1 Sandrock, Inc. must agree the conditional approval term which should be
added to the Section 10. – Financial Assurance of the PTC application for Phase 3 of the C&DLF.

Response: A-1 Sandrock will agree to these terms; Section 10 of the Application has been revised. The
correct amount for closure, post-closure and PACA is $3,364,519.

3. Regarding the status of Franchise Agreement as stated in draft Comment No. 1, the SWS
understood the agreement will expire on 10/03/2023 as stated in the Memo No. 7, and A-1
Sandrock Inc. is negotiating with Guilford County on the new amended agreement. The life-of-
site (LOS) permit for the C&DLF - Phases 1, 2, & 3A, if issued this year, will expire on 10/03/2023.
A-1 Sandrock Phase PTC January 11, 2019
Response to Comments Page 8
Should amended Franchise Agreement is denied for any reason, A-1 Sandrock, Inc. must provide
the SWS a copy of the County’s decision. The SWS may issue a 60-yr LOS permit according to
NCGS 130A-294(a4).
No further action is required by A-1 Sandrock, Inc. at this time.

4. The draft Comment Nos. 2.i., 2.iii & 2.v. are considered responded by Memo No. 3.

Action item: A-1 Sandrock, Inc. must revise the Operations Plan by incorporating the
requirements stated in NCGS 130A-309.05(c) into the operations of each non-disposal waste
management unit at this landfill facility.

Response: A-1 believes the responses for Draft Comments 2i, 2iii, and 2vi have provided the appropriate
clarification of uses; the Operations Plan has been revised for clarification.

5. The draft Comment No. 2.vi has responded by Memo No. 2.

Action item: A-1 Sandrock, Inc. must incorporate the response into the Operations Plan and
drawings.

Response: The Operations Plan has been revised.

6. A-1 Sandrock, Inc. must respond the draft Comment No. 3 and correct the typos in Table 6A of
the permit application.

Response: The Operations Plan has been revised.

7. The SWS withdraws the draft Comment No. 4. The typical drawing of a passive gas venting and
trench is on Drawing EC2.

Response: Drawing EC5 has been revised to reference the detail on Drawing EC2.

8. A-1 Sandrock, Inc. must respond the draft Comment No. 5i. by revising the drawings accordingly.

Response: Drawing EC5 has been revised.

9. The Memo No. 1 is considered as a response to the draft Comment No. 5ii.

No further action is required by A-1 Sandrock, Inc. at this time.

CONTENTS

A-1 Sandrock CDLF and Processing Facility Phase 3 PTC 1/15/2019
Permit 4117-CDLF-2008 Facility Plan Update Page i

OVERVIEW ................................................................................................................................. vii
OWNER/OPERATOR INFORMATION .................................................................................... viii
SITE LOCATION DATA ............................................................................................................ viii

1.0 FACILITY PLAN
1.1 Regulatory Summary ........................................................................................................ 10
1.2 Facility Drawings ............................................................................................................. 10
1.2.1 Facility Layout .................................................................................................... 10
1.2.2 Operational Sequence .......................................................................................... 10
1.3 Facility Report .................................................................................................................. 11
1.3.1 Waste Stream ....................................................................................................... 11
1.3.2 Landfill Capacity ................................................................................................. 11
1.3.3 Special Engineering Features .............................................................................. 14
1.3.4 Soil Volume Analysis .......................................................................................... 14
1.4 Processing and Temporary Storage Areas ........................................................................ 15

2.0 ENGINEERING REPORT
2.1 Engineering Report ........................................................................................................... 16
2.1.1 Analytical Methods ............................................................................................. 16
2.1.2 Identified Critical Conditions .............................................................................. 16
2.1.3 Technical References .......................................................................................... 18
2.1.4 Location Restriction Demonstrations .................................................................. 18
2.2 Construction Materials and Practices ............................................................................... 18
2.3 Design Hydrogeologic Report .......................................................................................... 19
2.4 Engineering Drawings ...................................................................................................... 19
2.4.1 Existing Conditions ............................................................................................. 19
2.4.2 Grading Plan ........................................................................................................ 19
2.4.3 Stormwater Segregation ..................................................................................... 19
2.4.4 Final Cap System ................................................................................................ 19
2.4.5 Temporary and Permanent E&SC ....................................................................... 19
2.4.6 Vertical Separation .............................................................................................. 20
2.4.7 Other Features ..................................................................................................... 20
2.5 Specific Engineering Calculations ................................................................................... 20
2.5.1 Settlement ............................................................................................................ 20
2.5.2 Slope Stability ..................................................................................................... 21
2.5.2.1 Deep-seated stability ........................................................................... 22
2.5.2.2 Veneer Stability................................................................................... 23
2.5.3 Final Slope Ratios ............................................................................................... 25

3.0 CONTRUCTION PLAN
3.1 Horizontal Separation ....................................................................................................... 26
3.1.1 Property Lines ..................................................................................................... 26
3.1.2 Residences and Wells .......................................................................................... 26
3.1.3 Surface Waters .................................................................................................... 26
3.1.4 Existing Landfill Units ........................................................................................ 26
3.2 Vertical Separation ........................................................................................................... 26
3.2.1 Settlement ............................................................................................................ 26
3.2.2 Soil Consistency .................................................................................................. 26
3.3 Survey Control Benchmarks ............................................................................................ 27
3.4 Location Coordinates ....................................................................................................... 27
3.5 Landfill Subgrade ............................................................................................................. 27
CONTENTS

A-1 Sandrock CDLF and Processing Facility Phase 3 PTC 1/15/2019
Permit 4117-CDLF-2008 Facility Plan Update Page ii
3.5.1 Subgrade Inspection Requirement ....................................................................... 27
3.5.2 Division Notification ........................................................................................... 28
3.5.3 Vertical Separation Compliance .......................................................................... 28
3.6 Special Engineering Features ........................................................................................... 28
3.7 Sedimentation and Erosion Control.................................................................................. 28

4.0 CONTRUCTION QUALITY ASSURANCE PLAN
4.1 General Provisions ........................................................................................................... 29
4.1.1 Definitions ........................................................................................................... 29
4.1.1.1 Construction Quality Assurance (CQA) ............................................. 29
4.1.1.2 Construction Quality Control (CQC) .................................................. 29
4.1.1.3 CQA Certification Document ............................................................. 30
4.1.1.4 Discrepancies Between Documents .................................................... 30
4.1.2 Responsibilities and Authorities .......................................................................... 30
4.1.2.1 Owner .................................................................................................. 30
4.1.2.2 Engineer .............................................................................................. 30
4.1.2.3 Contractor ........................................................................................... 31
4.1.2.4 CQA Testing Firm .............................................................................. 31
4.1.3 Control vs. Records Testing ................................................................................ 31
4.1.3.1 Control Testing ................................................................................... 31
4.1.3.2 Record Testing .................................................................................... 31
4.1.4 Modifications and Amendment ........................................................................... 32
4.1.5 Miscellaneous ...................................................................................................... 32
4.1.5.1 Units .................................................................................................... 32
4.1.5.2 References ........................................................................................... 32
4.2 CQA Plan ......................................................................................................................... 32
4.2.1 Responsibilities and Authorities .......................................................................... 32
4.2.1.1 Compaction Criteria ............................................................................ 32
4.2.1.2 Testing Criteria ................................................................................... 33
4.2.1.3 Material Evaluation ............................................................................. 33
4.2.1.4 Subgrade Approval ............................................................................. 33
4.2.2 General Earthwork Construction ......................................................................... 34
4.2.2.1 Construction Monitoring ..................................................................... 34
4.2.2.2 Control Tests ....................................................................................... 34
4.2.2.3 Record Tests ........................................................................................ 34
4.2.2.4 Record Test Failure ............................................................................. 34
4.2.2.5 Judgment Testing ................................................................................ 35
4.2.2.6 Deficiencies ......................................................................................... 35
4.2.3 Inspection Activities ............................................................................................ 35
4.2.3.1 Material Approval ............................................................................... 35
4.2.3.2 Final Cover Systems Installation ........................................................ 37
4.2.3.3 Deficiencies ......................................................................................... 37
4.3 CQA Meetings .................................................................................................................. 37
4.3.1 Project Initiation CQA Meeting .......................................................................... 37
4.3.2 CQA Progress Meetings ...................................................................................... 38
4.3.3 Problem or Work Deficiency Meetings ............................................................... 38
4.4 Documentation and Reporting .......................................................................................... 38
4.4.1 Periodic CQA Reports ......................................................................................... 39
4.4.2 CQA Progress Reports ........................................................................................ 40
4.4.3 CQA Photographic Reporting ............................................................................. 40
4.4.4 Documentation of Deficiencies ........................................................................... 41
4.4.5 Design or Specification Changes ........................................................................ 41
CONTENTS

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Permit 4117-CDLF-2008 Facility Plan Update Page iii
4.5 Final CQA Report ............................................................................................................ 41
4.6 Storage of Records ........................................................................................................... 42
4.7 Protection of Finished Surfaces ........................................................................................ 43

5.0 GENERAL FACILITY OPERATIONS PLAN
5.1 General Conditions ........................................................................................................... 48
5.1.1 Facility Description ............................................................................................. 48
5.1.2 Location and Surroundings ................................................................................. 48
5.1.3 Geographic Service Area ..................................................................................... 48
5.1.4 Hours of Operation .............................................................................................. 49
5.1.5 Hours of Operation .............................................................................................. 49
5.2 Contact Information ......................................................................................................... 49
5.2.1 Emergencies ........................................................................................................ 49
5.2.2 A-1 Sandrock Administrative Offices ................................................................. 49
5.2.3 North Carolina DEQ (Winston-Salem Regional Office) ...................................... 49
5.3 Permitted Activities .......................................................................................................... 50
5.4 Description of Facilities ................................................................................................... 51
5.4.1 Processing Facility .............................................................................................. 51
5.4.2 CDLF (Phase 1) ................................................................................................... 52
5.5 Facility Drawings ............................................................................................................. 52
5.6 Staff Responsibilities ........................................................................................................ 53
5.7 Inspections and Maintenance ........................................................................................... 53
5.8 Access Control ................................................................................................................. 54
5.8.1 Physical Restraints .............................................................................................. 54
5.8.2 Security................................................................................................................ 55
5.8.3 All-Weather Access ............................................................................................. 55
5.8.4 Traffic .................................................................................................................. 55
5.8.5 Anti-Scavenging Policy ....................................................................................... 55
5.8.6 Signage ................................................................................................................ 55
5.8.7 Communications .................................................................................................. 55
5.9 Fire and Safety.................................................................................................................. 55
5.9.1 Fire Control ......................................................................................................... 56
5.9.2 Personal Safety .................................................................................................... 56
5.10 Other Regulatory Requirements ....................................................................................... 57
5.10.1 Sedimentation and Erosion Control .................................................................... 57
5.10.2 Water Quality (Storm Water) Protection ............................................................. 57
5.11 Miscellaneous Requirements ............................................................................................ 58
5.11.1 Minimizing Surface Water Contact ..................................................................... 58
5.11.2 Processing Facility Operation over the CDLF .................................................... 58
5.11.3 Equipment Maintenance ...................................................................................... 59
5.11.4 Utilities ................................................................................................................ 59
5.11.5 Vector Control ..................................................................................................... 59
5.11.6 Air Quality Criteria ............................................................................................. 59
5.11.7 Litter Control ....................................................................................................... 60
5.12 Operating Record ............................................................................................................. 60
5.13 Annual Report .................................................................................................................. 62
5.14 Contingency Plan ............................................................................................................. 62
5.14.1 Hot Loads Contingency ....................................................................................... 62
5.14.2 Hazardous Waste Contingency ........................................................................... 62
5.14.3 Severe Weather Contingency .............................................................................. 63
5.14.3.1 Ice Storms ........................................................................................... 63
5.14.3.2 Heavy Rains ........................................................................................ 63
CONTENTS

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Permit 4117-CDLF-2008 Facility Plan Update Page iv
5.14.3.3 Electrical Storms ................................................................................. 64
5.14.3.4 Windy Conditions ............................................................................... 64
5.14.3.5 Violent Storms .................................................................................... 64

6.0 PROCESING FACILITY OPERATIONS PLAN
6.1 Overview .......................................................................................................................... 65
6.2 Acceptable Wastes ........................................................................................................... 65
6.3 Prohibited Wastes ............................................................................................................. 65
6.4 Waste Processing .............................................................................................................. 66
6.4.1 Waste Receiving and Screening .......................................................................... 66
6.4.2 LCID Processing ................................................................................................. 67
6.4.3 C&D Processing .................................................................................................. 67
6.4.4 Stockpile Guidance.............................................................................................. 68
6.4.5 Processing of Finished Goods ............................................................................. 68
6.4.6 Non-Processed Material Storage ......................................................................... 69
6.4.7 Processed Material Storage ................................................................................. 69
6.4.8 Asphalt Shingling Storage for Recycling ............................................................ 69
6.5 Contingency Plan ............................................................................................................. 70
6.6 Annual Reporting ............................................................................................................. 70

7.0 C&D LANDFILL OPERATIONS PLAN
7.1 Waste Acceptance Criteria ............................................................................................... 72
7.1.1 Permitted Wastes ................................................................................................. 72
7.1.2 Asbestos .............................................................................................................. 72
7.1.3 Wastewater Treatment Sludge ............................................................................. 72
7.2 Waste Exclusions ............................................................................................................. 72
7.3 Waste Handling Procedures ............................................................................................. 73
7.3.1 Waste Receiving and Inspection ......................................................................... 73
7.3.2 Disposal of Rejected Wastes ............................................................................... 74
7.3.3 Waste Disposal Procedures ................................................................................. 74
7.3.4 Spreading and Compaction ................................................................................. 75
7.3.5 Special Wastes: Asbestos Management ............................................................. 76
7.4 Cover Material .................................................................................................................. 76
7.4.1 Periodic Cover ..................................................................................................... 76
7.4.2 Interim Cover ...................................................................................................... 77
7.4.3 Final Cover .......................................................................................................... 77
7.5 Survey for Compliance ..................................................................................................... 78
7.5.1 Height Monitoring ............................................................................................... 78
7.5.2 Annual Survey ..................................................................................................... 79
7.6 Contingency Plan ............................................................................................................. 79
7.7 Annual Reporting ............................................................................................................. 79

8.0 CLOSURE AND POST-CLOSURE PLAN
8.1 Summary of Regulatory Requirements ............................................................................ 82
8.1.1 Final Cap ............................................................................................................. 82
8.1.2 Construction Requirements ................................................................................. 82
8.1.3 Alternative Cap Design ....................................................................................... 82
8.1.4 Division Notifications ......................................................................................... 82
8.1.5 Required Closure Schedule ................................................................................. 83
8.1.6 Recordation ......................................................................................................... 83
8.2 Closure Plan ..................................................................................................................... 83
8.2.1 Final Cap Installation .......................................................................................... 83
CONTENTS

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Permit 4117-CDLF-2008 Facility Plan Update Page v
8.2.1.1 Final Elevations................................................................................... 83
8.2.1.2 Final Slope Ratios ............................................................................... 83
8.2.1.3 Final Cover Section ............................................................................. 84
8.2.1.4 Final Cover Installation ....................................................................... 84
8.2.1.5 Final Cover Vegetation ....................................................................... 85
8.2.1.6 Documentation .................................................................................... 86
8.2.2 Maximum Area/Volume Subject to Closure ....................................................... 86
8.2.3 Closure Schedule ................................................................................................. 86
8.2.4 Closure Cost Estimate ......................................................................................... 86
8.3 Post-Closure Plan ............................................................................................................. 88
8.3.1 Monitoring and Maintenance .............................................................................. 88
8.3.1.1 Term of Post-Closure Care ................................................................. 88
8.3.1.2 Maintenance of Closure Systems ........................................................ 88
8.3.1.3 Landfill Gas Monitoring ..................................................................... 88
8.3.1.4 Ground Water Monitoring .................................................................. 89
8.3.1.5 Record Keeping................................................................................... 89
8.3.1.6 Certification of Completion ................................................................ 89
8.3.2 Responsible Party Contact................................................................................... 91
8.3.3 Planned Uses of Property .................................................................................... 91
8.3.4 Post-Closure Cost Estimate ................................................................................. 91

9.0 FACILITY MONITORING PLAN
9.1 Summary of Regulatory Requirements ............................................................................ 92
9.2 Ground Water Monitoring ................................................................................................ 92
9.2.1 Monitoring System Requirements ....................................................................... 93
9.2.2 Background Water Quality .................................................................................. 94
9.2.3 Point of Compliance Water Quality .................................................................... 94
9.2.4 Sampling and Analysis Procedures ..................................................................... 94
9.2.5 Detection-phase Monitoring Parameters ............................................................. 94
9.2.6 Sampling Frequency ............................................................................................ 94
9.2.7 Water Level Elevations ....................................................................................... 94
9.2.8 Reporting ............................................................................................................. 94
9.2.9 Source Demonstration ......................................................................................... 95
9.2.10 Monitoring Well Design ...................................................................................... 95
9.2.11 Monitoring Well Layout ...................................................................................... 95
9.2.12 Alternative Monitoring Systems ......................................................................... 95
9.2.13 Assessment Monitoring ....................................................................................... 95
9.3 Surface Water Monitoring ................................................................................................ 96
9.4 Landfill Gas Monitoring and Control Plan ....................................................................... 96
9.5 Adherence to Waste Acceptance ...................................................................................... 96
9.6 Plan Preparation and Certification .................................................................................... 96

10.0 FINANCIAL ASSURANCE ......................................................................................................... 92

11.0 CERTIFICATION ......................................................................................................................... 92

CONTENTS

A-1 Sandrock CDLF and Processing Facility Phase 3 PTC 1/15/2019
Permit 4117-CDLF-2008 Facility Plan Update Page vi
TABLES Refer to the in-text tables referenced by page number
1A Waste Density Calculations ............................................................................................... 12
1B Capacity Projections .......................................................................................................... 13
1C Borrow Soil Resources ...................................................................................................... 14
1D Soil Volume Analysis ........................................................................................................ 14
2A Design Soil Properties ....................................................................................................... 23
2B Seismic Analysis ............................................................................................................... 23
3A Benchmark Data ................................................................................................................ 27
3B Site Center Coordinates ..................................................................................................... 27
4A CQA Testing Schedule for General Earthwork ................................................................. 44
4B CQA Testing Schedule for Drainage and Final Cover ..................................................... 45
4C CQA Testing Schedule for Compacted Soil Barrier ........................................................ 46
4D Reference List of ASTM Test Methods ........................................................................... 47
6A Prohibited Waste at the Processing Facility ..................................................................... 71
7A Prohibited Waste at the CDLF Unit ................................................................................. 80
8A.1 Estimated Final Closure Costs for Phase 1 – 4 ................................................................. 87
8A.2 Annual Inflation Multipliers .............................................................................................. 87
8B Post-Closure Monitoring and Maintenance Schedule ...................................................... 90
8C Estimated Post-Closure Costs for Phase 1 – 4 ................................................................... 91
10 Summary of Closure and Post-Closure Costs ................................................................... 97

DRAWINGS Refer to tabbed section

APPENDICES
1 Property Description, Title and Franchise Amendment (Guilford County records)
2 Stability, Settlement and Volume Calculations
3 Sedimentation and Erosion Control Calculations
4 Operation Plan Information
4A Waste Screening Form
4B Fire Notification Form
4C Hazardous Waste Responders
4D Asphalt Shingles Recycling
5 Ground Water Monitoring Plan
6 Landfill Gas Monitoring Plan
7 Design Hydrogeologic Investigation
OVERVIEW
A-1 Sandrock CDLF and Processing Facility Phase 3 PTC 1/15/2019
Permit 4117-CDLF-2008 Facility Plan Update Page vii
On a historical note, recycling activities originally were conducted within the CDLF
footprint, i.e., adjacent to the working face or in future (unbuilt) cell areas. Soils left over
from incremental cell construction were also temporarily stockpiled within the future cell
areas. Over time, the recycling has taken on new characteristics, requiring more room
dedicated to these activities and relocation from within the CDLF footprint for safety
concerns and to make way for construction of the final two cells (Phase 3). Three new
Treatment and Processing (T&P) areas have been designated for concrete and LCID,
labeled Areas A, B and C on facility plan Drawing S1. The facility plan also shows new
Areas D and E, designated for temporary storage of operational soil.

This Facility Plan update was prepared in accordance with North Carolina Solid Waste
Rules 15A NCAC 13B .0531, et seq., in support of a Permit to Construct (PTC) application
for Phase 3 of Permit 4117-CDLF-2008. This work modifies the existing permit, which
was renewed in August 2015 (Phase 2A) and August 2017 (Phase 2B). Phases 1 and 2 are
now approaching interim bench grades. Side slopes are covered with a vegetated interim
soil cover. No areas have yet received final cover and been certified closed.

The Facility requires additional disposal capacity and desires to construct and operate
Phase 3 within the contiguous permitted footprint. Phase 3 will be developed in two stages,
Phase 3A to the north and Phase 3B to the south. Phase 3A is rough graded under the
provision of the mining permit and is ready for fine grading and certification, akin to the
sequencing used for Phases 1 and 2. A stockpile of soil presently occupies the Phase 3B
footprint. The Owner/Operator currently desires a Permit to Construct (PTC) for Phase 3,
soon followed by a request for a Permit to Operate (PTO) for Phase 3A.

A Design Hydrogeologic evaluation of Phase 3 was performed in 2018. Earlier studies
include a Site Suitability study and Design Hydrogeologic evaluations for Phases 1 and 2.
NCDEQ-approved Erosion and Sedimentation (E&S) control measures are in place and are
functioning as planned. The Water Quality Monitoring Plan and Landfill Gas Monitoring
Plans have been updated to incorporate new regulatory requirements. There are no known
adverse conditions attributable to the landfill indicated by the monitoring programs.

The C&D Landfill is the reclamation stage of a former mining operation (North Carolina
Mining Permit #41-22). Mining activities have now ended, and the reclamation is
underway. The facility was developed in three contiguous stages (Phases 1, 2 and 3) that
correspond to the three ground disturbing phases of the CDLF footprint, with targeted base
grades that meet the regulatory minimum vertical buffer requirements. A permitted fourth
phase of the CDLF (Phase 4) is a vertical expansion over the first three phases.

OVERVIEW
A-1 Sandrock CDLF and Processing Facility Phase 3 PTC 1/15/2019
Permit 4117-CDLF-2008 Facility Plan Update Page viii
The facility is permitted to accept up to 300 tons per day of C&D and LCID debris as
defined in the solid waste rules. Recycling of certain portions of the waste stream are
conducted at the working face and inactive areas within the footprint. Waste intake has
been variable due to regional economic conditions. The service area is defined as all
counties within and touching a 50-mile radius. The Franchise Agreement with Guilford
County requires recycling a minimum 10 percent of the waste stream.

This document includes an updated Closure/Post-Closure Plan and Financial Assurance
calculations, which have been updated from that submitted in 2017 to reflect the increased
footprint and the 2018 inflation factor of 1.018 furnished by NCDEQ Division of Waste
Management (the “Division”), Solid Waste Section (the “Section”). Within this document
are the following updates, prepared in accordance with Rule 15A NCAC 13B .0535:

• A Facility Plan prepared in accordance with Rule .0537
• An Engineering Plan prepared in accordance with Rule .0539
• An Operation Plan prepared in accordance with Rule .0542
• A Closure and Post-Closure Plan prepared in accordance with Rule
.0543, which incorporates a Construction Quality Assurance Plan as
required by Rules .0543 and .0541
• A Monitoring Plan prepared in accordance with Rule .0544.

OWNER/OPERATOR INFORMATION

Mr. R.E. ‘Gene’ Petty, Sr. – Owner/Operator
Mr. Ronnie E. Petty, III – Operator/Operator
A-1 Sandrock, Inc.
2091 Bishop Road
Greensboro, NC 27406 Tel. [phone]

SITE LOCATION DATA

LATITUDE 35.98745 N
LONGITUDE -79.84639 E
PARCEL NUMBER 12-03-0185-0-0739-W-007
Deed Date 1/17/1996 Guilford County, NC
Deed Book 4378 Deed Page 0198
Plat Book 149 Plat Page 93

OVERVIEW
A-1 Sandrock CDLF and Processing Facility Phase 3 PTC 1/15/2019
Permit 4117-CDLF-2008 Facility Plan Update Page ix

Figure 1 – Surrounding Properties (Guilford County GIS)

1.0 CDLF FACILITY PLAN
(15A NCAC 13B .0537)

A-1 Sandrock CDLF and Processing Facility Phase 3 PTC 10/15/2018
Permit 4117-CDLF-2008 Facility Plan Update Page 10
1.1 Regulatory Summary
15A NCAC 13B .0531 et seq. require a comprehensive facility plan that identifies future
development in phases and sub-phases that correspond approximately to 5-year operational
capacities. The facility plan must identify and show all relevant permitted Solid Waste units
and activities conducted (or proposed) at the site. The grading plan requirements emphasize
vertical separation and minimum subgrade soil type requirements.
The Phase 3 base grades meet or exceed the 4-foot minimum vertical separation requirement to
groundwater and bedrock; thus, no liner or leachate collection system is required under these
rules. Subgrade soil types that will be exposed via excavation and used in the compacted fill
sections are anticipated to exhibit a mix of finer soil types, e.g., ML, MH, CL, CH, SM and
mixed SM-ML classifications. Because of this, subgrade permeability is expected to be
relatively low providing the soils are reworked and compacted (see Section 3.2.2).
1.2 Facility Drawings
1.2.1 Facility Layout
Drawing S1 shows the Facility Plan with approved phasing and updated volume estimates. The
C&D recycling activities take place within the approved CDLF footprint, which are moved
around as needed to remain near the working face. Current temporary storage areas outside the
CDLF footprint are shown near the scale house, north of an unnamed tributary. Temporary
storage areas will be developed to the southeast of the footprint.
Drawings E1 and E2 depict current conditions and base grades for Phase 3. Drawings E3
through E5 show interim operational grades (top of waste) for Phase 3, which were used in
volume calculations. Drawing E6 show permitted final grades (top of waste) for Phase 4,
consistent with the original permitting. Drawing EC1 shows erosion control measures for the
final cover, also consistent with the original permitting. Construction details are depicted in
Drawings EC2 through EC5. Hydrogeologic cross sections are presented in Drawings X1
and X2. Locations for groundwater and landfill gas monitoring are depicted in Drawing M1.
1.2.2 Operational Sequence
Phase 3 is being developed in the western third (approximately) of the CDLF footprint. Grading
for this phase involves removing stockpiled fill soil (remnant from earlier construction) and
making grade cuts in the range of 10 to 15 feet (±) in depth, to reach the approved base grades.
The operational sequence for Phase 3 is shown as three sub-phases, 3A to the north, 3B to the
1.0 CDLF FACILITY PLAN
(15A NCAC 13B .0537)

A-1 Sandrock CDLF and Processing Facility Phase 3 PTC 1/15/2019
Permit 4117-CDLF-2008 Facility Plan Update Page 11
south, and 3C as an overlay to bring the upper surfaces to approximately El. 840. A center berm
and ditches will be used to separate drainage from north to south. Fill operations will progress
from north to south, i.e. from high ground toward low ground, to maintain the drainage pattern.
Operational cover will be used to minimize water from contacting the waste.
Interim side slopes will be maintained at 3H:1V while upper surfaces will be graded at
approximately 2% to 5% slopes. Exterior slopes will be closed in increments as the slopes come
to grade. Interim cover will be placed on exterior slopes until approximately 10 acres of slope
is reached, followed by final cover. Operational procedures are discussed in Sections 5.0 – 7.0.
1.3 Facility Report
1.3.1 Waste Stream
The following data is updated from the original (2002) Facility Report with data furnished to
Guilford County in 2018 renegotiation of the Franchise Agreement and the (2017) Facility
Report. Supporting data, e.g., population and growth projection, are presented in Appendix 1.
The geographic area to be served by the franchisee may include the following counties
within (and touching) a fifty-mile radius from the site: Guilford, Randolph,
Rockingham, Alamance, Forsyth, Davidson, Stokes, Surry, Yadkin, Caswell, Person,
Orange, Durham, Chatham, Moore, Montgomery, Stanley, Rowan, Cabarrus, Lee and
Davie. The bulk of the wastes are expected to be derived from an 8-county region
bordering Guilford County. The annual waste intake is anticipated to vary from 60,000
to 80,000 tons per year – a daily intake up to 300 tons per day – 10% of the waste stream
will be recycled. The facility will accept C&D and LCID waste (see Section 7.1).
1.3.2 Landfill Capacity
A volumetric analysis originally performed in 2002 using an AutoCAD Digital Terrain Model
(DTM) was recently confirmed using the method of slices. Based on the grading plan and final
waste contours (Drawing E6), the landfill has a volumetric capacity of 2,240,000 cubic yards.
Subtracting the final cover (132,677 cy) and assuming 10% of the airspace is lost due to periodic
cover (consuming 224,000 c.y.), the net disposal capacity is 1,883,323 c.y., or approximately
1,280,660 tons based on 0.68 ton/cy (see Table 1A). The landfill receives an average of 300
tpd and operates 5.5 days per week, 280 working days per year. The estimated annual airspace
consumption is 100,800 cubic yards.1 Based on the current volume projections and
operational history, the landfill has an estimated 12 to 15 years of remaining capacity.
1 An average waste density of 0.5 tcy was used in original estimates of landfill capacity and service life.
1.0 CDLF FACILITY PLAN
(15A NCAC 13B .0537)

A-1 Sandrock CDLF and Processing Facility Phase 3 PTC 1/15/2019
Permit 4117-CDLF-2008 Facility Plan Update Page 12
Following the first six months of operations, during late 2009, the tonnage and density was
recorded as 3,237 tons and 0.61 tons/c.y., respectively (for 5,396 c.y.). Later, after the first four
years of operation, an in-situ density of 0.68 tons/c.y. was calculated, shown below:
Table 1A
WASTE DENSITY CALCULATIONS

Year ending June 30 Tonnage Volume

2010 30,555.25 tons 44,934 cubic yards

2011 32,847.70 48,305

2012 40,479.24 59,528

2013 94,618.71 139,145

Phase 1 in-situ data 198,500.90 tons 291,912 cubic yards
Calculated in-situ density = 0.68 tcy
The higher in-situ density over time is attributed to compression of the wastes.
A tabulation of the disposal capacity and life expectancy by phase follows.

1.0 CDLF FACILITY PLAN
(15A NCAC 13B .0537)

A-1 Sandrock CDLF and Processing Facility Phase 3 PTC 1/15/2019
Permit 4117-CDLF-2008 Facility Plan Update Page 13
Table 1B
CAPACITY PROJECTIONS
PHASE 1 Status: Completed 1A 1B 1C
New Ground Footprint Acreage, ac 2.63 4.77 3.98
Interim Capacities (Sub-Phases) 2 62,370 cy 186,242 cy 221,720 cy
Interim Elevations (Sub-Phases) EL. 830 EL. 820 EL. 812
Surveyed Volume (Phase 1 only) 2, 3 ........................................................................ 470,332 cy
Cumulative Footprint ............................................................................................... 11.38 acres 1
PHASE 2 Status: Completed 2A 2B
New Ground Footprint Acreage, ac 4.27 2.25
Interim Capacities (Sub-Phases), cy 2 250,383 357,809
Interim Elevations (Sub-Phases) 4 EL. 820 EL. 820
Projected Volume (Phase 2 only) ............................................................................. 608,192 cy
Cumulative Capacity 2 .............................................................................................. 1,078,524 cy
Cumulative Footprint (through Phase 2) .................................................................. 17.90 acres
PHASE 3 Status: Current PTC 3A (Int. 1) 3B (Int. 2) 3C (Int. 3)
New Ground Footprint Acreage, ac 3.77 3.83 05
Interim Capacities (Sub-Phases), cy 2 210,910 152,184 278,632
Interim Elevations (Sub-Phases) 4 EL. 830 EL. 810 EL. 840
Projected Volume (Phase 3 only) ............................................................................. 641,726 cy
Cumulative Capacity 2 .............................................................................................. 1,720,250 cy
Cumulative Footprint (through Phase 3) .................................................................. 25.50 acres
PHASE 4 Status: Future
Permit Footprint (All Phases) ................................................................................... 25.50 acres 1
Interim Capacity (Phase 4) 2, 5 .................................................................................. 519,750 cy
Cumulative Capacity 2, 6 ........................................................................................... 2,240,000 cy
Final Elevation ......................................................................................................... El. 904
Remaining Life Expectancy7 .................................................................................... 12 to 15 years

1 Footprint shown in Franchise Drawings and original permitting is 25.50 acres. The “As-Built” drawing for Phases
1A – C and supporting calculations presented to the SWS per letter dated 2-14-2005 states the footprint is 11 acres.
The permit issued in 2006 showed 8.18 acres, which is erroneous but carried through to the present. Volumes are
by survey and are represented as accurate.
2 Includes Final Cap System and Operational Cover.
3 Includes documented losses due to base grade adjustments to accommodate rock encountered during grading.
4 As shown on drawings for estimation purposes, operational elevations may vary.
5 Vertical Expansion – not actual ground disturbance (does not add to total footprint area).
6 Consistent with the February 2004 Permit to Construct – Phase 4 volume was adjusted to match permit issue.
7 Based on Phase 3 and Phase 4 airspace (1,161,476 cy) and an annual airspace consumption of 100,800 cy per year,
giving 11.5 years. Remaining volume in Phases 1 and 2 are undetermined.
1.0 CDLF FACILITY PLAN
(15A NCAC 13B .0537)

A-1 Sandrock CDLF and Processing Facility Phase 3 PTC 1/15/2019
Permit 4117-CDLF-2008 Facility Plan Update Page 14
1.3.3 Special Engineering Features
No seeps, springs, soft ground or other deleterious conditions were identified in the site
characterization studies. As such, no special engineering features are required.
1.3.4 Soil Volume Analysis
The following soil data was developed using the airspace calculations (discussed above) and
the permitted grading plan. Demonstrated below, the Total Available Borrow (438,955 cy)
shown in Table 1C exceeds the remaining Total Required Soil (248,825 cy) shown in Table 1D.
Thus, there is sufficient soil available to complete Phases 1 through 4.
Table 1C
BORROW SOIL RESOURCES1
Area (acres) Borrow volume (yd3)
Stockpile --- 125,000
Adjacent Sites 13.9 313,955
Total Available Borrow 438,955

1 The borrow site consists of lots adjacent to the facility, not within the facility boundary, but directly accessible
with off-road equipment. This estimate includes the following properties: 2103 Bishop Rd, 2097 Bishop Rd, 2095
Bishop Rd, 2093 Bishop Rd, 2085 Bishop Rd, 2087 Bishop Rd, 2111 Bishop Rd, Greensboro, NC 27406. These
properties are wholly owned by A-1 Sandrock, Inc. but are not planned to be added to the facility.
Table 1D
SOIL VOLUME ANALYSIS
Breakout soil quantities for all Phases (included above) are follows:
Phase 1 Proposed Airspace 470,332 cy
Final Cover Required* (3' x 11.38 ac) 59,211 cy
Intermediate Cover (10% Volume) 47,033 cy
Phase 2 Proposed Airspace 608,192 cy
Final Cover Required* (3' x 6.52 ac) 33,923 cy
Intermediate Cover (10% Volume) 60,819 cy
Phase 3 Proposed Airspace 641,726 cy
Final Cover Required* (3' x 7.6 ac) 39,543 cy
Intermediate Cover (10% Volume) 64,173 cy
Phase 4 Proposed Airspace 519,750 cy
Final Cover Required** (3' x 0.0 ac) 0 cy
Intermediate Cover (10% Volume) 51,975 cy
Continued
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Summary Total Proposed Airspace 2,240,000 cy
Required Final Cover (25.5 acres)* 132,677 cy
Required Intermediate Cover (10% Volume) 224,000 cy

Total Required Soil (for entire landfill) 356,677 cy
*Includes 15% shrinkage on compacted clay layer **Cover volume included in Phases 1-3

Whereas Phases 1 and 2 are operationally complete, the intermediate cover volumes of soil need
not be included in an estimate of the remaining soil requirements for operation of Phases 3 and
4, and final closure of the entire footprint. Considering this aspect, the remaining soil needs are
as follows:

Phase 1 Final Cover (11.38 ac) 59,211 cy
Phase 2 Final Cover (6.52 ac) 33,923 cy
Phase 3 Final Cover (7.6 ac) 39,543 cy
Phase 3 Intermediate Cover 64,173 cy
Phase 4 Intermediate Cover 51,975 cy

Total Required Soil (remaining activities) 248,825 cy

1.4 Processing and Temporary Storage Areas

Five material processing and storage areas are labeled A – E on Drawing S1. Relevant acreage
and maximum volumes as T&P operations (Areas A – C) and/or soil stockpiles (Areas D – E)
are listed on the drawing. These areas are designated for temporary storage and recycling of
concrete debris, wood waste, soil and finished products, e.g., aggregate, mulch, topsoil and fill
dirt. A more detailed description of these areas is provided in Section 5.4.

Drawing EC5 shows BMP’s that are already in place for managing runoff in Areas A – E.
These measures are scheduled for a permit update and appropriate steps are being pursued. The
measures were originally approved and installed under the mining permit for a “bare-earth”
condition, i.e., maximum runoff. Recovered metals shall be stored roll-off boxes, not in the
stockpiles, and equipment may be parked and fueled in these areas.

Statutory requirements and provisions for fire protection (see Section 5.9 and Section 6.4) limit
the storage capacity of Areas A – E. Estimated quantities for each of these areas, in accordance
with designated uses is shown on Drawing S1. Maximum anticipated storage times for wood
wastes and recycled wood products is 3 months, such that composting will not occur. Inert
concrete debris, aggregates and soil may be stored for longer periods, subject to the statutory
requirement that 75% of each material quantity is removed within one calendar year.
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2.1 Engineering Report

This section of the report describes the physical aspects of the facility design, with
emphasis on waste containment and environmental control systems, based on the
hydrogeologic data discussed in earlier studies. The design was prepared by a qualified
Professional Engineer, who is licensed to practice in North Carolina and is familiar with
the requirements of the North Carolina Division of Waste Management (Division) rules.
Phase 3 is set to provide approximately 5 years of capacity, in keeping with rules.

Also, in keeping with the intent of 15A NCAC 13B .0531 - .0547, there is no liner or
leachate collection system for this facility, since the site meets the rule requirements for
soil types present within two feet below planned base grades, and there is at least 4 feet of
vertical separation between the waste and seasonal high ground water and/or bedrock. The
planned base grades and outer slopes will have maximum slope ratios of 3H:1V, which
have been demonstrated to be stable.

2.1.1 Analytical Methods

The facility design incorporates elements that are consistent with Division rules and
guidelines, as well as sound engineering practice. Various analyses used in the design of
the facility include evaluations of soil conditions, i.e., the consistency of subgrade soils and
the availability of suitable soils for constructing stable embankments and other earthen
structures (discussed below), and ground water characteristics, i.e., flow directions and
seasonal water depth fluctuations. Soil properties testing used to facilitate these
evaluations included grain size analysis, shear strength, consolidation, and compaction
characteristics. Stability and settlement of foundation soils were considered in setting base
grades, as was the outer slope stability for the final cover system, presented in Appendix
2. Other analyses including an evaluation of Erosion and Sedimentation Control (E&SC)
and storm water management systems that are permitted by the predecessor agency to
NCDEQ Division of Energy, Minerals and Land Resources, are presented in Appendix 3.

2.1.2 Identified Critical Conditions

Based on the nature of the soils within Phase 3 (and the entire CDLF footprint), along with
an understanding of geologic conditions within the region, no inherent foundation stability
or long-term settlement problems are anticipated. Some considerations that are both
generic to landfills and specific to the on-site soils, learned through practical experience
with the construction of other landfills in the region, are discussed below.
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• Subsurface conditions consist of weathered granite saprolite, i.e., “sandrock,”
which can vary in density within short lateral and horizontal distances. Conditions
that produce “auger refusal” can be localized and not apparent during open
excavations. The grading plan is based on auger refusal and may not reflect the
actual excavation characteristics.

• Groundwater is typically deeper than bedrock within the eastern portions of the site,
shallower than bedrock within the western portion of the site. Groundwater depths
govern the vertical separation requirements for the base grading plan within the
western half of the site (approximately) while bedrock elevations govern within the
eastern portion of the site.

• Minor veins or “knots” of rock-like materials may be encountered above the
permitted grades, which may require ripping for removal.

• Required soil types for the upper two (2) feet of base grades include SM, SC, ML,
MH, CL, and CH classifications. These soils are abundant on the site.

• Required lower permeability soils for final cover construction, which require a
permeability no greater than 1 x 10-5 cm/sec are also available in sufficient
quantities, but the operator will need to segregate and reserve these soils.

• Borrow site selection and a field evaluation of the soils during construction (see
Section 4) will be critical to assure the subgrade construction complies with the
rule requirements.

• Soil compaction is dependent on both compaction effort (i.e., the right equipment)
and working within the correct range of near-optimum moisture (Section 4.2.1).

• Properly compacted embankments are expected to be stable due to high soil
strength and stable foundation conditions. Outer slope stability (relative to final
cover) will also rely on adequate compaction and observation of proper slope ratios,
due to the strength considerations.

• Soil erosivity is a consideration that can be counteracted with good cover
construction practices and vegetative cover. The on-site soils have moderate field
capacity and poor nutrient value, which may require additional effort to establish
vegetation. These conditions pose operational considerations but require no special
design accommodations.
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2.1.3 Technical References

Calculations found in Appendix 2 are referenced within the various analyses. All
calculations and analyses were performed in accordance with accepted engineering
standards of practice.

2.1.4 Location Restriction Demonstrations

The site was granted a Site Suitability determination in accordance with 15A NCAC 13B
.0531 et seq. based on work completed in 2002-04, (the site characteristics were determined
suitable for a C&D landfill). Relative to Rule .0536 pertaining to C&D landfills, the site
has no disqualifying conditions with respect to zoning, setbacks from residences or potable
wells, historic or cultural sites, state or nature preserves, 100-year floodplains, wetlands,
water supply critical areas, or endangered species. Documentation pertaining to these site
selection criteria is found in the 2002 Site Suitability Report.

2.2 Construction Materials and Practices

Based on the 2002 Design Hydrogeologic Report (found in the original Permit to
Construct application) investigation and the 2015 Design Hydrologic Report, on-site
soils available for embankment and subgrade construction consist chiefly of variably silty
sand exhibiting Unified Soil Classification System classifications of SM and SM-ML, with
silty clay (CL) and clayey silt (ML). These soils meet the requirements for the upper two
feet beneath the landfill subgrade referenced in 15A NCAC 13B .0540 (2). The soils
exhibit adequate compaction characteristics and shear strength (when properly compacted)
to build stable embankments and subgrade that will not undergo excessive settlement.
Some selective use of soils and/or field evaluation will be required to place the correct soil
types within the upper two (2) feet beneath the subgrade elevations.

Good construction practices for embankments and subgrade include compaction using
steel-wheel rollers, sheep foot rollers, and/or smooth-drum rollers of sufficient weight –
not dozers – with a minimum number of passes (typically three to five passes) in two
perpendicular directions to achieve the desired strength properties for stability. Experience
at the site indicates that material selection (i.e., avoiding soils that are excessively wet or
exhibit excess organic debris content) and/or blending soils to negate the effects of wet or
slick soils will produce satisfactory results. The targeted compaction criterion is 95% of
standard Proctor maximum dry density (ASTM D-698). Critical embankment and
subgrade areas should be tested to ensure proper compaction in accordance with the criteria
outlined in the CQA Plan (Section 4.0).
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2.3 Design Hydrogeologic Report

A Design Hydrogeologic Report for Phase 3, dated April 2018, has been prepared and is
included in this report as Appendix 7.

2.4 Engineering Drawings

Refer to the rolled plan set that accompanies this report. All relevant criteria required by
the rules (except as noted) are depicted on the plans.
2.4.1 Existing Conditions
See Drawings E1 in the Construction Drawings.
2.4.2 Grading Plan
See Drawing E2.
2.4.3 Storm water Segregation

Drawings E3 – E6 depict operational stages that include measures to separate storm water
runoff from contacting the waste, hence reducing the generation of leachate. Good
practices for water management include maintaining slopes with positive drainage directed
toward approved E&S measures, proper use of soil cover and orderly waste placement.

2.4.4 Final Cap System

Drawings E6 and EC4 depict final cover contours and the layout of the E&S best
management practices (BMPs). See Drawings EC1 and EC2 for the E&S details and
Drawing EC3 for schedules of pile and ditch sizes. See Drawing EC5 for a tentative LFG
vent layout.

2.4.5 Temporary and Permanent E&SC

Drawings E1 – E5 and EC5 depict temporary erosion and sedimentation (E&S) control
measures required at various stages of CDLF and T&P operations. Drawings EC1 – EC3
provide construction details for these measures. The E&SC plan approved by the NC
DENR Division of Land Resources, Land Quality Section (now NC DEQ Division of
Energy, Minerals and Land Resources) included all operational areas now in use and final
closure conditions. Relevant calculations are presented in Appendix 3.
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2.4.6 Vertical Separation

The rules require a minimum vertical separation of 4 feet between the CDLF base grades
and bedrock and/or the estimated maximum seasonal water levels. Vertical separation for
Phase 3 was established based on the 2018 Design Hydrogeologic report, drawing on data
from the Phase 1 (2002) and Phase 2 (2013) reports. For groundwater, historic monitoring
well data were used to estimate the maxima, which occur approximately 2 feet higher than
the 2002 data and within a few inches higher than the 2018 observations. It should be
noted that a portion of the Phase 3B footprint is inaccessible due a large soil stockpile, thus
a test pit investigation is planned to confirm these estimates during construction, as was
done for the earlier phases. Vertical separation to groundwater based on these criteria are
depicted in Drawings S2 – S4 (map view) and in Drawings X1 and X2 (cross sections).

2.4.7 Other Features

The rule governing Section 2.4.6 pertains to liners and leachate collection systems, if
proposed (none are).

2.5 Specific Engineering Calculations and Results

Calculations for settlement and slope stability were performed using site specific data. The
calculations can be found in Appendix 2. Supporting geotechnical lab data is found in
Appendix 2 and Table 1. The following is a brief description of the analyses.

2.5.1 Settlement

Settlement is a concern for maintaining vertical separation between the bottom of the waste
(or base liner) and the maximum long-term seasonal high-water table. Settlements of the
foundation soils result from time-dependent strain, i.e., a change in thickness within the
various soil layers due to the vertical stress (weight of the landfill) applied at the surface,
accompanied by drainage of the various soil layers. Vertical stresses beneath landfills
gradually increase as the waste becomes thicker over long periods of time. Strain-induced
settlements within sands and/or well drained silts and clays are relatively short-term, thus
long-term settlements are not typically a concern unless thick uniform clay deposits are
present (which tend to drain slowly) – such is not the case at the subject landfill. This
landfill site is excavated into residual saprolite, derived from the underlying bedrock,
thus settlement is not expected to be a concern.

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Settlements were calculated using elastic methods adapted from the US Federal Highway
Administration (FHWA) for highway embankments. Ostensibly, a landfill is a large
flexible embankment with the highest stresses impinging on the foundation soils near the
center. The FHWA settlement calculation is based on the work of Hough (1959) and
others, which considers both the material type and overburden depth for determining a
“correction factor” for standard penetration test (SPT) values, from which the
compressibility and load-induced strain of each soil layer can be evaluated. For sandy soils
conventional sampling via Shelby tubes and laboratory consolidation testing is infeasible.
No Shelby tube samples were acquired for laboratory consolidation tests, because the soils
were too sandy and dense.

A spreadsheet facilitates the settlement calculation (see Appendix 2). The maximum
vertical stress increase which was calculated using the maximum embankment height of
110 feet and an average unit weight of 1000 pounds per cubic yard (37 pcf), then applying
a depth-related “influence factor” based on elastic stress distribution theory. Next a
subsurface stress distribution was developed for original and post-construction (final
height) conditions, based on the depth and average unit weight of the soil layers, plus the
added vertical stresses. The SPT correction factor was applied to determine the
compressibility factor and strain within each layer, differentiating between sand and clay
layers based on empirical data. Strain in the individual layers was summed up to estimate
the total settlement. Time-dependent settlement was not considered due to the well-drained
conditions indicated by the subsurface data.

Assuming uniform subsurface conditions within the footprint – as confirmed by the test
borings – a representative subsurface profile was used to estimate the maximum
settlements beneath the center of the landfill. Settlements along the edges of the landfill
are negligible, and settlements beneath the slopes fall in between the maximum and
minimum values. The calculations confirm that the base grade design, which typically
provides more than the minimum required 4 feet of separation, is sufficient to
accommodate the anticipated settlement. Differential settlement within the footprint is not
a concern. The maximum estimated foundation settlement is 0.36 feet.

2.5.2 Slope Stability

Two primary concerns exist for landfills with respect to slope stability: deep-seated/global
stability or veneer stability. Deep-seated/global instability involves instability in a deep
layer in the foundation or along the base of the landfill (which could potentially result in
catastrophic slope failure). Veneer stability (sliding of the cover) can expose the waste but
is typically more of a maintenance issue relative to the effort of exacting repairs.
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Subsurface conditions identified at this site are relatively sandy (high strength soils) with
interspersed clay pockets and sand seams that are expected to drain readily under the
applied embankment loads – only “effective” stresses (i.e., drained conditions) were
considered. The site is not earthquake prone, thus liquefaction is not a concern. No
extremely soft layers that would pose stability concerns were identified by the SPT testing,
but the foundation is expected to undergo a strain-hardening strength increase as settlement
occurs. This means the foundation soils will become even more stable with time.

2.5.2.1 Deep-seated stability – Limit-equilibrium methods, STABL-5M was the model
used for this project, evaluate the balance of forces driving a slide (weight of the porous
material and contained water) against the forces resisting a slide (shear strength, expressed
as cohesion and friction) along a theoretical failure surface, which can be either a circular
surface or a series of intersecting planar surfaces. A “static” analysis considers just the
weight of the materials and the shear strength (tie-back loads may be considered for
reinforced embankments); a “dynamic” analysis might consider external loads, such as
linear loads at the top of the embankment (i.e., traffic forces) or additional horizontal loads
to represent earthquakes (expressed as a fraction of the normal gravity field, specific to the
region of interest).

In more advanced routines, the mass above the failure surface is divided into many slices,
and the driving and resisting forces for each of which are calculated and summed up.
Variations on the “method of slices” involve planar block failure surfaces – typically the
more conservative analysis – and classic circular failure surfaces, both of which represent
the loci of movement at the base of a sliding mass above the failure surface. The balance
of forces – the sum of the resisting forces divided by the sum of the driving forces – is
expressed as a ratio, e.g., 1.5:1, or simply 1.5, which is called the “safety factor.” Ratios
less than unity (safety factor <1) indicate unstable conditions. Typical minimum safety
factors for maintaining stable embankment conditions throughout the life of a project are
1.5 for static conditions, 1.2 for seismic conditions.

Shear strength inputs to the STABL-5M model were developed from the drilling and
laboratory data (see the 2002 Design Hydrogeologic Report). A circular failure surface
and a block analysis were analyzed with the Janbu method of slices. A representative soil
profile was developed from the drilling data. A side slope ratio of 3H:1V was modeled.
Shear strength parameters were derived empirically from the standard penetration
resistance values, based on familiarity with local soils and decades of engineering
experience. Typically, the in-situ sandrock exhibits a high shear strength value, expressed
in engineering terms as the cohesion (in units of force/area) and the internal friction angle
(expressed in degrees).
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The following table shows a summary of the soil strength input values, representative of
pre-excavation conditions at the project site, i.e., along the edges of the mine and landfill.

Table 2A
DESIGN SOIL PROPERTIES

Soil
Layer
Layer
Thickness
(feet)
Soil Layer Description
Saturated
Unit Weight
(pcf)
Drained
Cohesion
(psf)*
Drained
Friction
Angle (deg)
1 110 Waste 64 100 25
2 10 Silty sand
N = 17 110 100 35
3 25 Silt-Clay
N = 20-50 135 300 34
4 40 Silty sand
N = 100 130 40 35
5 40 Bedrock 145 5000 45

*Apparent cohesion for silty sands and waste is based on retrogression analysis from other projects (based
on experience). The water table was modeled at a depth of 5 feet below ground surface, i.e., the base of the
waste, which reflects seasonal high conditions.

Based on the analysis presented in Appendix 2, the minimum safety factors calculated for
this project are summarized below:
Table 2B
SEISMIC ANALYSIS

Failure Analysis Seismic* Non-Seismic
Block 1.56 1.85
Circular 2.15 2.15
*A horizontal static load of 0.04g was applied to represent regional seismicity, consistent with the
protocols of the STABL5M computer program – the region is not within a seismic impact zone as
defined by NC DENR Solid Waste Rules

2.5.2.2 Veneer Stability – Sliding of the final cover (or veneer failure) is dependent on
the slope angle, the degree of saturation, and the material strength, (i.e. the interface friction
angle and cohesion within the soils and between the soils and synthetic components, if
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any). Veneer failure occurs when the pore pressures build up along a critical interface
exceeding available shear strength. The severity of failure can range from minor sloughing
of small areas (maintenance nuisances) to large-scale slides requiring complete
replacement of large sections – this type of failure is expensive to repair, especially when
synthetic components are involved. The analysis is typically performed for preliminary
design conditions to anticipate (and try to avoid) the large-scale failures.

A worse-case scenario involves little (or no) cohesion, as in a geotextile-geomembrane
interface, and complete saturation of the soils overlying that interface. Good engineering
practice requires a drainage layer (typically a synthetic geonet) whenever a flexible
membrane barrier is used, e.g., an alternative final cover that might be considered. The
regulatory minimum cover includes 18 inches of vegetative support soil overlying a
compacted soil barrier. Given the regional soil types, the upper 18 inches could include a
high permeability sand layer near the base, and ample soil resources are available for the
compacted soil barrier (maximum 1 x 10-5 cm/sec permeability). North Carolina Solid
Waste regulations allow alternative final covers, subject to approval by the Solid Waste
Section, but specific interface testing will be required to verify future designs.

Even when native soil covers are used, drainage is still important relative to veneer
stability, so a final cover section should include higher permeability sand layer next to the
barrier to prevent the soils above the barrier from becoming saturated. Assuming a
regulatory minimum cover soil profile is used, the critical interface for veneer stability
exists within a low-cohesion sand layer overlying the compacted soil barrier at full
saturation on a 3H:1V slope (i.e., the angle measured from the horizontal is 18 degrees).
While a minimum cohesion could be assumed along the sand layer and the compacted soil
barrier, the stresses near the base of the sand layer would control stability.

A veneer stability analysis (Appendix 2) adapted from Matasovic (1991)1 was performed
to evaluate four conditions: static unsaturated and saturated conditions (with a required
safety factor of 1.5) and seismic unsaturated and saturated conditions (with a safety factor
of 1.1). For this site, the static (non-seismic) saturated case is the critical condition for
design because of the higher required safety factor. The calculations start with the given
slope geometry and saturation state, then for a given safety factor the required friction (with
or without cohesion) is back-calculated to provide the desired safety factor.

1 Geotechnical and Stability Analyses for Ohio Waste Containment Facilities, Geotechnical Resource Group,
Ohio Environmental Protection Agency, Columbus, Ohio, September 2004, pg. 9-12.

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The analysis assumed full saturation of the vegetation support layer (upper cover soil is at
field capacity) with a 1-year, 60-minute design storm impinging, resulting in a head of just
over 12 inches acting on the base of the upper soil layer. Assuming the deeper compacted
soil layer is stronger (due to cohesion) a minimum friction angle of 31 degrees is required
within the upper soil layer. Select soils available in the region (including the borrow sites
on the premises) will provide this minimum friction angle, combined with the required
high permeability for drainage. The CQA program for the final closure should verify the
available friction angles for the actual cover components (including alternative cover
designs if these are to be used).

2.5.3 Final Slope Ratios

Both the deep-seated stability analysis (Section 2.5.2.1) and the veneer stability analysis
(Section 2.5.2.2) assumed a 3H:1V slope ratio. These analyses demonstrate that stability
safety factors meet the minimum acceptable requirement of 1.5 for static (non-seismic)
conditions. The use of 3H:1V slope ratios will result in stable slopes, providing that the
drainage requirements are accommodated and assuming proper vegetation is maintained.

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The following sections demonstrate compliance of the facility design for CDLF Phase 3
with the requirements of the C&D Rules, 15A NCAC 13B .0537 - .0540.

3.1 Horizontal Separation

The following regulatory criteria are addressed in project drawings specified below. Refer
to the rolled plan set that accompanies this report.

3.1.1 Property Lines

The minimum setback to property lines is 200 feet (Drawings E1 – E5).

3.1.2 Residences and Wells

The minimum setback to residences and wells is 500 feet (Drawings E1 – E5).

3.1.3 Surface Waters

The minimum setback to surface waters is 50 feet (Drawings E1 – E5).

3.1.4 Existing Landfill Units

There are no other landfill units present on the site.

3.2 Vertical Separation

3.2.1 Settlement

Maximum waste thickness is approximately 110 feet; the waste density is approximately
0.5 tons/cubic yard. Foundation soils are very dense residual silty sand and gravelly sand
and silt (all saprolite). Settlement calculations (see Appendix 2) indicate maximum post-
construction settlements on the order of 0.36 feet (4 inches), or less. Discussion of the
assumptions and procedures behind the calculations is presented in Section 2.5.

3.2.2 Soil Consistency

Based on the laboratory data summary table (see Appendix 2), most of the on-site soils
generally classify as silty sands (SM), silt (ML) or dual classify as sand-silt (SM-ML). A
relatively small fraction of the near surface soils consists of low plasticity silty clay (CL),
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and very minor quantities of high plasticity silty clay (MH-CH) soil types are present.
Based on the data, these soil types are prevalent and will be present – either in-situ or
within compacted subgrade – to meet the requirements of Rule .0540 (2) (b) for the upper
two feet beneath the subgrade. No modification of the soils, i.e., admixtures, will be
required to meet this rule requirement, but reworking to blend the soils to a more uniform
consistency and proper compaction may be required to mitigate isolated pockets of highly
granular soils. For new base grade fill sections, proper soil selection will be required. The
soil types shall be documented in the CQA program.

3.3 Survey Control Benchmarks

A permanent benchmark is located long Bishop Road (see facility drawings), with the
following information:
Table 3A
BENCHMARK DATA

NAD 83 Coordinates N 817,233.63456
E 1,749,238.54876
NGVD 29 El. 783.30
3.4 Site Location Coordinates

The latitude and longitude coordinates of the center of the site (determined from Google
Earth) are approximately:
Table 3B
SITE CENTER COORDINATES

LATTITUDE 35.98745 N
LONGITUDE -79.84639 E

3.5 Landfill Subgrade

3.5.1 Subgrade Inspection Requirement

The Owner/Operator shall have the subgrade inspected by a qualified engineer or geologist,
accompanied by a SWS Hydrologist, upon completion of the excavation, in accordance
with Rule .0534 (b) and Rule .0539. Said inspection is required by the Division to verify
that subgrade conditions are consistent with expected conditions based on the Design
Hydrogeologic Report.
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3.5.2 Division Notification

The Owner/Operator shall notify the Division at least 24 hours in advance of the subgrade
inspection.

3.5.3 Vertical Separation Compliance

The subgrade inspection shall verify to the Division that the minimum vertical separation
requirements are met and that required subgrade soil types are present.

3.6 Special Engineering Features

This section of the rules generally pertains to liners and leachate collection systems, if any
are present. There are no liners and leachate collection systems in this project.

3.7 Sedimentation and Erosion Control

The sedimentation and erosion control structures were permitted by the now NCDEQ
Division of Energy, Minerals and Land Resources, Land Quality Section and have been
designed to accommodate the 25-year, 24-hour storm event, per the North Carolina
Sedimentation Pollution Control Law (15A NCAC 04). Required measures are depicted
throughout in the construction plan set (see Drawings E1 – E6 and EC1 – EC5). Existing
sediment traps shall be cleaned out and upgraded as needed; other measures shall be
maintained throughout the life of the facility.

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4.1 General Provisions

This Construction Quality Assurance (CQA) Plan has been prepared to provide the Owner,
Engineer, and CQA Testing Firm – operating as a coordinated team – the means to govern
the construction quality and to satisfy landfill certification requirements. The CQA program
includes both a quantitative testing program (by a third-party) and qualitative evaluations (by
all parties) to assure that the construction meets the desired criteria for long-term
performance. Variations in material properties and working conditions may require minor
modification of handling and placement techniques throughout the project. Close
communication between the various parties is paramount. It is anticipated that the early
stages of the construction activities will require more attention by the CQA team, i.e., the
Contractor, Engineer, Owner and CQA Testing Firm.

The requirements of the CQA program (construction oversight and testing) apply to the
preparation of the base grades, embankments, and engineered subgrade, as well as the final
cover installation. All lines, grades, and layer thicknesses shall be confirmed by topographic
surveys performed under the supervision of the Engineer of Record or the CQA Testing Firm,
and as built drawings of the base grades and final cover shall be made part of the construction
records. Once the base grade and final cover construction is completed, the Engineer shall
verify that all surfaces are vegetated within 20 days following completion of final grades.
The Engineer shall also verify that interior slopes and base grades of new cells are protected
until waste is placed.

4.1.1 Definitions

4.1.1.1 Construction Quality Assurance (CQA) – In the context of this CQA Plan,
Construction Quality Assurance is defined as a planned and systematic program employed
by the Owner to assure conformity of base grade and embankment construction and the final
cover system installation with the project drawings and specifications. CQA is provided by
the CQA Testing Firm as a representative of the Owner and is independent from the
Contractor and all manufacturers. The CQA program is designed to provide confidence that
the items or services brought to the job meet contractual and regulatory requirements and
that the final cover will perform satisfactorily in service.

4.1.1.2 Construction Quality Control (CQC) – Construction Quality Control refers to
actions taken by manufacturers, fabricators, installers, and/or the Contractor to ensure that
the materials and the workmanship meet the requirements of the project drawings and the
project specifications. The manufacturer's specifications and quality control (QC)
requirements are included in this CQA Manual by reference only. A complete updated
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version of each manufacturer's QC Plan for any Contractor-supplied components shall be
incorporated as part of the Contractor's CQC submittal. The Owner and/or the Engineer shall
approve the Contractor’s QC submittal prior to initial construction. Contractor submittals
may be (but are not required to be) incorporated into the final CQA certification document
at the Owner’s discretion.

4.1.1.3 CQA Certification Document – The Owner and/or the Engineer will prepare a
certification document upon completion of construction, or phases of construction. The
Owner will submit these documents to the NC DENR Division of Waste Management Solid
Waste Section. The CQA certification report will include relevant testing performed by the
CQA Testing Firm, including field testing used to verify preliminary test results and/or
design assumptions, records of field observations, and documentation of any modifications
to the design and/or testing program. An “as-built” drawing (prepared by/for the Owner),
showing competed contours, shall be included. The Certification Document may be
completed in increments, i.e., as several documents, as respective portions of the final cover
are completed. Section 2 discusses the documentation requirements.

4.1.1.4 Discrepancies Between Documents – The Contractor shall be instructed to bring
discrepancies to the attention of the CQA Testing Firm who shall then notify the Owner for
resolution. The Owner has the sole authority to determine resolution of discrepancies
existing within the Contract Documents (this may also require the approval of State Solid
Waste Regulators). Unless otherwise determined by the Owner, the more stringent
requirement shall be the controlling resolution.

4.1.2 Responsibilities and Authorities

The parties to Construction Quality Assurance and Quality Control include the Owner,
Engineer, Contractor, CQA Testing Firm (i.e., a qualified Soils Laboratory).

4.1.2.1 Owner – The Owner is A-1 Sandrock, Inc., who operates and is responsible for the
facility. The Owner or his designee is responsible for the project and will serve as liaison
between the various parties.

4.1.2.2 Engineer – The Engineer (a.k.a. the “Engineer of Record”) is responsible for the
engineering design, drawings, and project specifications, regulatory affairs, and
communications coordinator for the construction of the base grades, embankments,
engineered subgrade, drainage and final cover systems. The Engineer represents the Owner
and coordinates communications and meetings as outlined in Section 4.3.
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The Engineer shall also be responsible for proper resolution of all quality issues that arise
during construction. The Engineer shall prepare the CQA certification documents, with input
from the Owner, the CQA Testing Firm and the Owner’s Surveyor. The Engineer shall be
registered in the State of North Carolina.

4.1.2.3 Contractor – The Contractor is responsible for the construction of the subgrade,
earthwork, and final cover system. The Contractor is responsible for the overall CQC on the
project and coordination of submittals to the Engineer. Additional responsibilities of the
Contractor include compliance with 15A NCAC 4, i.e., the North Carolina Sedimentation
and Erosion Control rules.

Qualifications – The Contractor qualifications are specific to the construction
contract documents and are independent of this CQA Manual. The Owner may serve
as the contractor, as long as the specifications are met.

4.1.2.4 CQA Testing Firm – The CQA Testing Firm (a.k.a. Soils Laboratory) is a
representative of the Owner, independent from the Contractor, and is responsible for
conducting geotechnical tests on conformance samples of soils and aggregates used in
structural fills and the final cover system. Periodic site visits shall be coordinated with the
Engineer of Record and the Contractor.

Qualifications – The CQA Testing Firm shall have experience in the CQA aspects
of landfill construction and be familiar with ASTM and other related industry
standards. The Soils CQA Laboratory will can provide test results within 24 hours
or a reasonable time after receipt of samples, depending on the test(s) to be
conducted, as agreed to at the outset of the project by affected parties, and will
maintain that standard throughout the construction.

4.1.3 Control vs. Records Testing

4.1.3.1 Control Testing – In the context of this CQA plan, Control Tests are those tests
performed on a material prior to its actual use in construction to demonstrate that it can meet
the requirements of the project plans and specifications. Control Test data may be used by
the Engineer as the basis for approving alternative material sources.

4.1.3.2 Record Testing – Record Tests are those tests performed during or after the actual
placement of a material to demonstrate that its in-place properties meet or exceed the
requirements of the project drawings and specifications.

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4.1.4 Modifications and Amendment

This document was prepared by the Engineer to communicate the basic intentions and
expectations regarding the quality of materials and workmanship. Certain articles in this
document may be revised with input from all parties, if so warranted based on project specific
conditions. No modifications will be made without the Division’s approval.

4.1.5 Miscellaneous

4.1.5.1 Units – In this CQA Plan, and through the plans and specifications for this project,
all properties and dimensions are expressed in U.S. units.

4.1.5.2 References – This CQA Plan includes references to the most recent version of the
test procedures of the American Society of Testing and Materials (ASTM). Table 4D at the
end of this text contains a list of these procedures.

4.2 Inspection, Sampling and Testing

The requirements of the General Earthwork (perimeter embankments and subgrade) and
Final Cover Systems (soil barrier, vegetative cover, and storm water management devices)
differ with respect to continuous or intermittent testing and oversight. The following two
sections are devoted to the specific requirements of each work task.

4.2.1 General Earthwork

This section outlines the CQA program for structural fill associated with perimeter
embankments, including sedimentation basins, and general grading of the subgrade. Issues
to be addressed include material approval, subgrade approval, field control and record tests,
if any, and resolution of problems.

4.2.1.1 Compaction Criteria – All material to be used as compacted embankment shall be
compacted to a minimum of 95% of the Standard Proctor Maximum Dry Density (ASTM
D-698), or as approved by the Engineer or designated QC/QA personnel. Specifically, field
observation of the response of soils beneath equipment and the use of a probe rod and/or a
penetrometer are other means of determining the adequacy of compaction. Skilled soil
technicians working under the supervision of an engineer may make this determination,
subject to concurrence by the engineer. Approval is based on visual evaluation for
consistency with project specification and objectives. Such material evaluations may be
performed either during material handling, i.e., delivery to or upon receipt at the landfill, or
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from existing stockpiles and/or the soil borrow site. Borrow soils shall be evaluated by the
Engineer and QC/QA personnel prior to placement on the work site. All visual inspection
and testing shall be documented for the CQA Report.

Where permeability is the key parameter of interest, field and/or lab tests will be used.

4.2.1.2 Testing Criteria – Periodic compaction (moisture-density) testing requirements are
imposed on the structural fill, although compaction and testing requirements may not be as
stringent as that required for the final cover construction. Initial compaction testing shall be
in accordance with the project specifications. The Engineer may recommend alternative
compaction testing requirements based on field performance. Additional qualitative
evaluations shall be made by the Contractor Superintendent and the Engineer to satisfy the
performance criteria for placement of these materials.

CQA monitoring and testing will not be “full-time” on this project. Rather, the CQA Testing
Firm will test completed portions of the work at the Contractor’s or Owner’s request. The
CQA Testing Firm may be called upon to test final cover and/or compacted structural fill at
any time, ideally scheduling site visits to optimize his efforts. The Engineer will make an
inspection at least monthly, more often as needed (anticipated more often in the initial stages
of new construction).

4.2.1.3 Material Evaluation – Each load of soil will be examined either at the source, at
the stockpile area, or on the working face prior to placement and compaction. Any unsuitable
material, i.e., that which contains excess moisture, insufficient moisture, debris or other
deleterious material, will be rejected from the working face and routed to another disposal
area consistent with its end use. Materials that are either too dry or too wet, may be
stockpiled temporarily near the working face for further evaluation by designated QC/QA
personnel. The Contractor may blend such materials with other materials (in the event of
dryness) or dry the materials (in the event of excess moisture). Soils designated for the upper
2 feet of subgrade within the cell shall consist of ML, MH, CL, CH, SM and mixed SM-ML
classifications – this shall be confirmed with lab testing.

4.2.1.4 Subgrade Approval – Designated QC/QA personnel shall verify that the
compacted embankment and/or subgrade are constructed in accordance with the project
specifications prior to placing subsequent or overlying materials. These activities include an
inspection of the subgrade by a qualified engineer, geologist, or soil technician working
under the supervision of an engineer, which will examine and classify the soils within the
upper two feet beneath the finished subgrade. This may consist of continual observation
during placement with confirmatory sampling and laboratory gradation testing at specified
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intervals, or there may be an exploratory sampling program with confirmatory testing at
specified intervals at some time near the completion of the subgrade. The frequency of visual
inspection and testing shall conform to Table 4A.

4.2.2 General Earthwork Construction

4.2.2.1 Construction Monitoring – The following criteria apply:
A. Earthwork shall be performed as described in the project specifications. The
Construction Superintendent has the responsibility of assuring that only select
materials are used in the construction, discussed above.
B. Only materials previously approved by the Engineer or his designee shall be
used in construction of the compacted embankment. Unsuitable material will
be removed and replaced followed by re-evaluation to the satisfaction of the
Engineer and retesting, as may be required.
C. All required field density and moisture content tests shall be completed before
the overlying lift of soil is placed – as applicable. The surface preparation (e.g.
wetting, drying, scarification, compaction etc.) shall be completed before the
Engineer (or his designate) will allow placement of subsequent lifts.
D. The CQA Testing Firm and/or the Engineer shall monitor protection of the
earthwork, i.e., from erosion or desiccation during and after construction.

4.2.2.2 Control Tests – The control tests, as shown on Table 4A, will be performed by the
CQA Testing Firm prior to placement of additional compacted embankment.

4.2.2.3 Record Tests – The record tests, as shown on Table 4A, will be performed by the
CQA Testing Firm during placement of compacted embankment. The CQA Testing Firm
may propose and the Engineer may approve an alternative testing frequency. Alternatively,
the Engineer may amend the testing frequency, without further approval from the regulatory
agency, based on consistent and satisfactory field performance of the materials and the
construction techniques.

4.2.2.4 Record Test Failure – Failed tests shall be noted in the construction report, followed
by documentation of mitigation. Soils with failing tests shall be evaluated by the Engineer
(or his designee), and the soils shall either be recompacted or replaced, based on the
Engineer’s judgment. Recompaction of the failed area shall be performed and retested until
the area meets or exceeds requirements outlined in the specifications.

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4.2.2.5 Judgment Testing – During construction, the frequency of control and/or record
testing may be increased at the discretion of the CQA Testing Firm when visual observations
of construction performance indicate a potential problem. Additional testing for suspected
areas will be considered when:

• Rollers slip during rolling operation;
• Lift thickness is greater than specified;
• Fill material is at an improper moisture content;
• Fewer than the specified number of roller passes is made;
• Dirt-clogged rollers are used to compact the material;
• Rollers may not have used optimum ballast;
• Fill materials differ substantially from those specified;
• Degree of compaction is doubtful.

4.2.2.6 Deficiencies – The CQA Testing Firm will immediately determine the extent and
nature of all defects and deficiencies and report them to the Owner and Engineer. The CQA
Testing Firm shall properly document all defects and deficiencies – this shall be more critical
on the final cover construction, although this applies to structural fill as well. The Contractor
will correct defects and deficiencies to the satisfaction of the Owner and Engineer. The CQA
Testing Firm shall perform retests on repaired defects.

4.2.3 Final Cover Systems

This section outlines the CQA program for piping, drainage aggregate, geotextiles,
compacted soil barrier layer, and the vegetative soil layer of the final cover system, as well
as the related erosion and sedimentation control activities. Issues to be addressed include
material approval, subgrade approval, field control and record tests, if any, and resolution of
problems.

4.2.3.1 Material Approval – The Engineer and/or the CQA Testing Firm shall verify that
the following materials (as applicable) are provided and installed in accordance with the
project drawings, specifications, and this CQA Manual. In general, the Contractor shall
furnished material specification sheets to the Engineer for review and approval. In certain
cases, materials furnished by the Contractor may need to meet the Owner’s requirements, in
which case the Owner shall approve of the materials with the Engineer’s concurrence. The
materials approval process may involve the submittals furnished by the Owner, (for
documentation purposes) in the event that the Owner decides to furnish certain materials.
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A. High Density Polyethylene (HDPE) Pipe

(1) Receipt of Contractor's submittals on HDPE pipe.

(2) Review manufacturer’s submittals for conformity with project specs.

B. Corrugated Polyethylene (CPE) Pipe

(1) Receipt of Contractor's submittals on CPE pipe.

(2) Review manufacturer’s submittals for conformity with project specs.

C. Aggregates (Verify for each type of aggregate)

(1) Receipt of Contractor's submittals on aggregates.

(2) Review manufacturer’s submittals for conformity with project specs.

(3) Verify aggregates in stockpiles or borrow sources conform to project
specifications. Certifications from a quarry will be sufficient.

(4) Perform material evaluations in accordance with Table 4B.

D. Vegetative Soil Layer and Drainage Layer

(1) Review manufacturer’s submittals for conformity with project specs.

(2) Review contractor’s submittals on seed specifications.

(3) Perform material evaluations in accordance with Table 4C.

E. Compacted Barrier Layer

(1) Review manufacturer’s submittals for conformity with project specs.

(2) Conduct material control tests in accordance with Table 4C.

F. Erosion and Sedimentation Control

(1) Review Contractor's submittals on erosion and sedimentation control items
(including rolled erosion control products and silt fence).

(2) Review of submittals for erosion and sedimentation control items for
conformity to the project specifications.

(3) Perform visual examination of materials for signs of age or deterioration.
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4.2.3.2 Final Cover Systems Installation – The CQA Testing Firm, in conjunction with
the Engineer, will monitor and document the construction of all final cover system
components for compliance with the project specifications. Monitoring for the components
of the final cover system includes the following:

• Verify location of all piping;
• Assuring sufficient vertical buffer between field equipment and piping;
• Monitoring thickness and moisture-density of the final cover layers and
verification that equipment does not damage the compacted barrier layer or
other components; and
• Assuring proper installation of sedimentation and erosion control measures.

4.2.3.3 Deficiencies – The CQA Testing Firm and/or the Engineer will immediately
determine the extent and nature of all defects and deficiencies and report them to the Owner.
The CQA Testing Firm and/or the Engineer shall properly document all defects and
deficiencies. The Contractor will correct defects and deficiencies to the satisfaction of the
Engineer. The CQA Testing Firm and/or the Engineer shall observe all retests.

4.3 CQA Meetings

Effective communication is critical toward all parties’ understanding of the objectives of the
CQA program and in resolving problems that may arise that could compromise the ability to
meet those objectives. To that end, meetings are essential to establish clear open channels
of communication. The frequency of meetings will be dictated by site conditions and the
effectiveness of communication between the parties.

4.3.1 Project Initiation CQA Meeting

A CQA Meeting will be held at the site prior to placement of the compacted barrier layer.
At a minimum, the Engineer, the Contractor, and representatives of the CQA Testing Firm
and of the Owner will attend the meeting. The purpose of this meeting is to begin planning
for coordination of tasks, anticipate any problems that might cause difficulties and delays in
construction, and, above all, review the CQA Manual to all of the parties involved.

During this meeting, the results of a prior compaction test pad will be reviewed, and the
project specific moisture-density relationships and it is very important that the rules
regarding testing, repair, etc., be known and accepted by all. This meeting should include
all of the activities referenced in the project specifications. The Engineer shall document
the meeting and minutes will be transmitted to all parties.
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4.3.2 CQA Progress Meetings

Progress meetings will be held between the Engineer, the Contractor, a representative of the
CQA Testing Firm, and representatives from any other involved parties. Meeting frequency
will be, at a minimum, once per month during active construction or more often if necessary
during critical stages of construction (i.e., initial stages of final cover). These meetings will
discuss current progress, planned activities for the next week, and any new business or
revisions to the work.

The Engineer will log any problems, decisions, or questions arising at this meeting in his
periodic reports. Any matter requiring action, which is raised in this meeting, will be
reported to the appropriate parties. The Engineer will document these meetings and minutes
will be transmitted to interested parties and to a record file.

4.3.3 Problem or Work Deficiency Meetings

A special meeting will be held when and if a problem or deficiency is present or likely to
occur. At a minimum, the Engineer, the Contractor, the CQA Testing Firm, and
representatives will attend the meeting from any other involved parties. The purpose of the
meeting is to define and resolve the problem or work deficiency as follows:
• Define and discuss the problem or deficiency;
• Review alternative solutions; and
• Implement an action plan to resolve the problem or deficiency.
The Engineer will document these meetings and minutes will be transmitted to interested
parties and to a record file.

4.4 Documentation and Reporting

An effective CQA plan depends largely on recognition of which construction activities
should be monitored and on assigning responsibilities for the monitoring of each required
activity. This is most effectively accomplished and verified by the documentation of quality
assurance activities. The CQA Testing Firm will provide documentation to address quality
assurance requirements. Monitoring will not be continuous and full-time, although the CQA
Testing Firm representative (typically this is a Soil Technician) and the Engineer will make
frequent and periodic visits to inspect and/or test the work. Both parties shall keep records
of their visits and observations.
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The Soils Technician will visit the site periodically (e.g., once per week) to document
activities during placement of the structural fill and during final cover construction. Site
visits by the CQA Testing Firm shall be coordinated between the Contractor and the CQA
Testing Firm. The Engineer will make monthly site visits during these critical stages to
review the work.

The Construction Superintendent or his representative shall be present on-site daily and shall
keep a record of the general construction progress, noting specifically any problems or
inconsistencies that need to be brought to the Owner’s attention. The specifics of the
Contractor’s records will not be spelled out, but at a minimum, daily or weekly progress
records shall be kept and made available to the Owner upon request.

The CQA Testing Firm will provide the Owner (or his designee) with periodic progress
reports including signed descriptive remarks, data sheets, and logs to verify that required
CQA activities have been carried out. These reports shall also identify potential quality
assurance problems. The CQA Testing Firm will also maintain at the job site a complete file
of project drawings, reports, project specifications, the CQA Plan, periodic reports, test
results and other pertinent documents. The Owner shall keep this record file.

4.4.1 Periodic CQA Reports

The CQA Testing Firm representative's reporting procedures will include preparation of a
periodic report that will include the following information, where applicable:
• A unique sheet number for cross referencing and document control;
• Date, project name, location, and other identification;
• Data on weather conditions;
• A Site Plan showing all proposed work areas and test locations;
• Descriptions and locations of ongoing construction;
• Descriptions and specific locations of areas, or units, of work being tested
and/or observed and documented;
• Locations where tests and samples were taken;
• A summary of test results (as they become available, in the case of laboratory
tests);
• Calibration or recalibration of test equipment, and actions taken as a result of
recalibration;
• Off-site materials received, including quality verification documentation;
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• Decisions made regarding acceptance of units of work, and/or corrective
actions to be taken in instances of substandard quality;
• Summaries of pertinent discussions with the Contractor and/or Engineer;
• The Technician's signature.
The periodic report must be completed by the end of each Technician's visit, prior to leaving
the site. This information will keep at the Contractor’s office and reviewed periodically by
the Owner and Engineer. The CQA Testing Firm on a weekly basis should forward copies
of the Periodic CQA Reports electronically to the Engineer. Periodic CQA Reports shall be
due to the Engineer no later than noon on the next working day (typically Monday) following
the end of a work week (typically Friday). If a periodic visit is postponed or cancelled, that
fact should be documented by the CQA Testing Firm and noted in the next periodic report.

4.4.2 CQA Progress Reports

The Engineer will prepare a summary progress report each month, or at time intervals
established at the pre-construction meeting. As a minimum, this report will include the
following information, where applicable:
• Date, project name, location, and other information;
• A summary of work activities during the progress reporting period;
• A summary of construction situations, deficiencies, and/or defects
occurring during the progress reporting period;
• A summary of all test results, failures and retests, and
• The signature of the Engineer.

The Engineer's progress reports must summarize the major events that occurred during that
week. This report shall include input from the Contractor and the CQA Testing Firm.
Critical problems that occur shall be communicated verbally to the Engineer immediately (or
as appropriate, depending on the nature of the concern) as well as being included in the
Periodic CQA Reports.

4.4.3 CQA Photographic Reporting

Photographs shall be taken by the CQA Testing Firm at regular intervals during the
construction process and in all areas deemed critical by the CQA Testing Firm. These
photographs will serve as a pictorial record of work progress, problems, and mitigation
activities. These records will be presented to the Engineer upon completion of the project.
Electronic photographs are preferred; in which case the electronic photos should be
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forwarded to the Engineer (the CQA Testing Firm shall keep copies, as well). In lieu of
photographic documentation, videotaping may be used to record work progress, problems,
and mitigation activities. The Engineer may require that a portion of the documentation be
recorded by photographic means in conjunction with videotaping.

4.4.4 Documentation of Deficiencies

The Owner and Engineer will be made aware of any significant recurring nonconformance
with the project specifications. The Engineer will then determine the cause of the non-
conformance and recommend appropriate changes in procedures or specification. When this
type of evaluation is made, the results will be documented, and the Owner and Engineer will
approve any revision to procedures or specifications.

4.4.5 Design or Specification Changes

Design and/or project specification changes may be required during construction. In such
cases, the Contractor will notify the Engineer and/or the Owner. The Owner will then notify
the appropriate agency, if necessary. Design and/or project specification changes will be
made only with the written agreement of the Engineer and the Owner and will take the form
of an addendum to the project specifications. All design changes shall include a detail (if
necessary) and state which detail it replaces in the plans.

4.5 Final CQA Report

At the completion of each major construction activity at the landfill unit, or at periodic
intervals, the CQA Testing Firm will provide final copies of all required forms, observation
logs, field and laboratory testing data sheets, sample location plans, etc., in a certified report.
Said report shall include summaries of all the data listed above. The Engineer will provide
one or more final reports, pertinent to each portion of completed work, which will certify
that the work has been performed in compliance with the plans and project technical
specifications, and that the supporting documents provide the necessary information.

The Engineer will provide Record Drawings, prepared with input from the Owner’s
Surveyor, which will include scale drawings depicting the location of the construction and
details pertaining to the extent of construction (e.g., depths, plan dimensions, elevations, soil
component thicknesses, etc.). All final surveying required for the Record Drawings will be
performed by the Owner’s Surveyor. The following is a suggested outline for the Final CQA
Report(s). Note that some items may not be applicable to all stages of the project.

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FINAL CQA REPORT GENERAL OUTLINE (FINAL COVER SYSTEM)

1.0 Introduction
2.0 Project Description
3.0 CQA Program
3.1 Scope of Services
3.2 Personnel
4.0 Earthwork CQA
5.0 Final Cover System CQA
6.0 Summary and Conclusions
7.0 Project Certification

Appendices
A Design Clarifications/Modifications
B Photographic Documentation
C CQA Reporting
C1. CQA Reports
C2. CQA Meeting Minutes
D Earthwork CQA Data
D1. CQA Test Results - Control Tests
D2. CQA Test Results - Record Tests
E Final Cover System CQA Data
E1. Manufacturer’s Product Data and QC Certificates
E2. Test Results - Drainage Aggregate
E3. Test Results - Vegetative Soil Layer
E4. Test Results - Pressure Testing of HDPE Piping (Manufacturer data)
E5. Test results on final cover compacted soil barrier/low permeability layer
F Record Drawings
F1. Subgrade As-Built
F2. Compacted soil barrier/low permeability layer as-built drawing
F3. Vegetative Soil Layer As-Built

Each CQA report shall bear the signature and seal of the Engineer (or multiple Engineers as
applicable), attesting that the construction was completed in accordance with the CQA plan,
the conditions of the permit to construct, the requirements of the North Carolina Solid Waste
Rules, and acceptable engineering practice.

4.6 Storage of Records

All approved drawings and data sheets shall be stored in electronic format and as paper
copies in a secure location on site. These documents will become the property of the Owner.
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4.7 Protection of Finished Surfaces

The only relevant systems exposed after construction will be the finished slopes, including
both interior and exterior slopes, various drainage systems, and the subgrade. Ground cover
shall be established on all finished surfaces shall to prevent erosion, i.e., seeding of the
finished surfaces within 20 days, per NC DEQ Division of Land Quality rules, or other
measures for preventing erosion (e.g., mulch, rain sheets). Maintenance of finished slopes
and subgrade until waste is placed is required. Exterior slopes shall be vegetated in
accordance with application sediment and erosion control regulations. The Engineer shall
document that the finished surfaces are adequately protected upon completion and said
documentation shall be recorded in the CQA report.

The Owner/Operator shall be responsible for maintaining the finished surfaces, including
exterior slope vegetation and drainage conveyances, along with the interior slopes and
subgrade. If finished surfaces within the waste disposal area are required to sit completed
for more than 30 days following completion, the Engineer shall examine the finished surfaces
prior to waste disposal and the Owner shall be responsible for any necessary repairs, e.g.,
erosion that might affect embankment integrity or vertical separation with a subgrade. The
Engineer shall document any required maintenance or repairs prior to commencing disposal
activities and place said documentation into the Operating Record.
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Table 4A
CQA TESTING SCHEDULE FOR GENERAL EARTHWORK

PROPERTY TEST METHOD MINIMUM TEST
FREQUENCY
CONTROL TESTS:
Consistency Evaluation ASTM D 2488
(visual)1
Each Material
RECORD TESTS:
Lift Thickness Direct Measure Each compacted lift
In-Place Density ASTM D 29222 20,000 ft2 per lift
Moisture Content ASTM D 30173 20,000 ft2 per lift
Subgrade Consistency within the
upper 24 inches4
Visual 4 tests per acre
Subgrade Consistency within the
upper 24 inches4
ASTM D 4318
ASTM D 7928
ASTM WK 39106
1 test per acre

Notes:

1. To be performed by Contractor Superintendent, Engineer, or CQA Testing Firm. Direct measure shall be
facilitated with hand auger borings.
2. Optionally use ASTM D 1556, ASTM D 2167, or ASTM D 2937. For every 10 nuclear density tests perform
at least 1 density test by ASTM D 1556, ASTM D 2167, or ASTM D 2937 as a verification of the accuracy of
the nuclear testing device. Minimum required soil density is 95 percent of the standard proctor maximum dry
density, which is dependent on the moisture-density characteristic developed for the specific soil during
initial construction; soils which result in a failed test and the lift must reworked and retested.
2a. If “beneficial fill” materials are used to construct embankments or structural fill, the Contractor shall spread
large particles evenly and fill all voids with finer soil – this is referred to as “choking off” the voids; density
testing shall be suspended at the discretion of the Engineer, but judgment testing shall be applied and the use
of these materials and evaluation thereof shall be documented as would any other soil placement activity
3. Optionally use ASTM D 2216, ASTM D 4643, or ASTM D 4959. For every ten (10) nuclear density-
moisture tests, perform at least 1 moisture test by ASTM D 2216, ASTM D 4643, or ASTM D 4959 as a
verification of the accuracy of the nuclear testing device.
4. Subgrade evaluation shall be conducted via continuous inspection with the indicated testing frequency, in
order to evaluate the full 24-inch depth, of an intrusive investigation (e.g., hand auger borings) may be
performed after portions of the subgrade are completed with the indicated testing frequency – all testing
locations, testing types and test results shall be recorded on a site map and made part of the construction
record
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Table 4B
CQA TESTING SCHEDULE FOR DRAINAGE AND FINAL COVER MATERIALS

COMPONENT PROPERTY TEST METHOD

MINIMUM TEST
FREQUENCY
RECORD TESTS:
Gas Vent Pipes and
Stone
Correct type, grade and
placement for pipes;
correct gradation and
trench dimensions for
collection stone*
Visual Each Vent
Coarse Aggregate: Confirm Gradation Visual 5,000 CY1
Vegetative Soil Layer:
(In-Situ Verification)
Visual Classification ASTM D 2488 1 per acre
Layer Thickness Direct measure Survey4

Notes:

1. A quarry certification is acceptable for aggregate from a commercial quarry. If on-site derived stone or a
byproduct is used, i.e., crushed concrete aggregate, the gradation test frequency may be adjusted based on
project specific conditions. The Engineer shall approve all materials and alternative test frequencies.
Materials that do not meet relevant ASTM or AASHTO standard gradation specifications (either may be used
at the discretion of the Engineer) shall be rejected.

* Relative to Detail G on Drawing EC2.

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Table 4C
CQA TESTING SCHEDULE FOR FINAL COVER COMPACTED SOIL BARRIER

PROPERTY TEST METHOD MINIMUM TEST
FREQUENCY
RECORD TESTS:
Lift Thickness Direct measure Survey4
Permeability ASTM D50841 1 per acre per lift
In-Place Density ASTM D 29222 4 per acre per lift
Moisture Content ASTM D 30173 4 per acre per lift
Direct Shear Friction Test ASTM D 53215 1 per acre

Notes:

1. Optionally use ASTM D6391. Maximum allowable confining pressure for laboratory testing under ASTM
D5084 is 20 psi; maximum gradient is 10; actual confining pressure and gradient values shall be at the
discretion of the engineer in charge of the CQA program.

Maximum allowable soil permeability is 1 x 10-5 cm/sec; higher permeability results in a failed test and the
lift must be reworked and retested.

2. Optionally use ASTM D 1556, ASTM D 2167, or ASTM D 2937. For every 10 nuclear density tests perform
at least 1 density test by ASTM D 1556, ASTM D 2167, or ASTM D 2937 as a verification of the accuracy of
the nuclear device. Minimum required density is dependent on the moisture-density-permeability
characteristic developed for the specific soil during initial construction; lower density or incorrect moisture
may result in higher permeability. Permeability criteria shall govern the determination of a passing test.

3. Optionally use ASTM D 2216, ASTM D 4643, or ASTM D 4959. For every ten nuclear-moisture tests,
perform at least 1 moisture test by ASTM D 2216, ASTM D 4643, or ASTM D 4959 as a verification of the
accuracy of the nuclear testing device.

4. Topographic survey to be performed by licensed surveyor, observing the following technical specifications to
confirm that the minimum thickness of each proposed final cover component is constructed according to the
Rule 15 NCAC 13B .0543. Each of the following layers shall be documented with individual surveys:
a) The top elevations of the final intermediate soil cover layer.
b) The top elevations of the final compacted soil liner layer.
c) The top elevations of the final vegetation cover layer.

The survey shall be performed on a regular grid or triangular grid layout – ideally the same point locations
would be used for each layer based on the original construction grid; locations of each data point shall be
measured to a minimum accuracy of 0.01 feet on the horizontal and vertical; any stakes placed on the slopes
shall be removed and the holes backfilled with soil that is similar to the layer of interest; the backfill soil shall
be placed in maximum 9 inch thick loose lifts and compacted to approximately 6 inches thickness with a hand
tamp; lifts shall be measured directly down-hole with a stick or tape measure; the as-built drawings for each
layer shall be drawn as layer thickness contours paralleling the slopes, i.e., an thickness isopach map, with the
same 0.01 foot vertical accuracy. Digital data acquisition will be assumed.

5. These tests may be altered at the Engineer’s discretion, providing minimum standards of practice are
observed and the minimum project requirements are met.
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Table 4D
REFERENCE LIST OF ASTM TEST METHODS

ASTM C 136 Standard Test Method for Sieve Analysis of Fine and Coarse Aggregates.

ASTM D 698 Test Method for Laboratory Compaction Characteristics of Soil Using Standard Effort
(12,400 ft-lb/ft3).

ASTM D 1556 Standard Test Method for Density and Unit Weight of Soil in Place by the Sand-Cone
Method.

ASTM D 2167 Standard Test Method for Density and Unit Weight of Soil in Place by the Rubber
Balloon Method.

ASTM D 2216 Standard Test Method for Laboratory Determination of Water (Moisture) Content of Soil
and Rock by Mass.

ASTM D 2488 Standard Practice for Description and Identification of Soils (Visual-Manual Procedure).

ASTM D 2922 Standard Test Methods for Density of Soil and Soil-Aggregate in Place by Nuclear
Methods (Shallow Depth).

ASTM D 2937 Standard Test Method for Density of Soil in Place by the Drive Cylinder Method.

ASTM D 3017 Standard Test Method for Water Content of Soil and Rock in Place by Nuclear Methods
(Shallow Depth).

ASTM D 4318 Standard Test Method for Liquid Limit, Plastic Limit, and Plasticity Index of Soils.

ASTM D 4643 Standard Test Method for Determination of Water (Moisture) Content of Soil by the
Microwave Oven Method.

ASTM D 4959 Standard Test Method for Determination of Water (Moisture) Content of Soil by Direct
Heating Method.

ASTM D5084 Standard Test Methods for Measurement of Hydraulic Conductivity of Saturated Porous
Materials Using a Flexible Wall Permeameter

ASTM D 5993 Standard Test Method for Measuring Mass per Unit of Geosynthetic Clay Liners.

ASTM D6391 Standard Test Method for Field Measurement of Hydraulic Conductivity Limits of
Porous Materials Using Two Stages of Infiltration from a Borehole

ASTM D 6768 Standard Test Method for Tensile Strength of Geosynthetic Clay Liners.

ASTM D 5321 Standard Test Method for Determining the Coefficient of Soil and Geosynthetic or
Geosynthetic and Geosynthetic Friction by the Direct Shear Method

ASTM D 7928 Standard Test Method for Particle-Size Distribution (Gradation) of Fine-Grained Soils
Using the Sedimentation (Hydrometer) Analysis

ASTM WK38106 New Test Method for Particle Size Analysis for Soils Combining the Sieve and
Sedimentation Techniques

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5.1 General Conditions
This Operation Plan was prepared for the A-1 Sandrock Recycling (Processing) facility
and C&D landfill (CDLF) to provide the facility staff with an understanding of relevant
rules and how the Engineer assumes that the facility will be operated. While deviations
from the operation plan may be acceptable, changes should be reviewed by the and
approved by SWS.
5.1.1 Facility Description
The facility consists of CDLF and related activities located on a 75-acre tract, which is
isolated by natural barriers such as creeks and wooded tracts. The site originally comprised
a surface mine (borrow site) for “sandrock” (weathered granite) and other soils. Adequate
on-site soil resources are available to meet the operational needs of the CDLF. The landfill
is a permitted reclamation activity for the former mine that will restore the property to a
usable condition for future development. Recycling activities are required as a condition
of the Franchise Agreement with local government. The facility contains a CDLF
processing and disposal area, with recycling activities taking place near the working face,
a separate LCID processing area (no disposal) and a concrete processing area and stockpile.
5.1.2 Location and Surroundings
The facility entrance is located at 2091 Bishop Road, accessible from I-85 Business via
Holden Road or Groomtown Road. Bishop Road is paved and has a 45-mph posted speed
limit. The entrance to the facility was enhanced with turn lanes and a widening of Bishop
Road to improve visibility for traffic. Nearby facilities include an asphalt plant, other
mines and landfills, a trucking terminal, a MSW transfer station, and other businesses
which put heavy truck traffic on the road. The scales and office are located near the front
gate, which is the only means of accessing the site by the public. A few residences exist
within a mile of the facility on Bishop Road, which rely on ground water wells. The site
is located in the Deep River Reservoir watershed – protection of water quality is an
important issue in the permitting and operation of the facility. A regional fire department
is located one-mile to the west on Bishop Road.
5.1.3 Geographic Service Area
The service area authorized by the Guilford County Commissioners includes the entire
political boundaries of all counties within or touching a 50-mile radius from the facility.
The operator is responsible for knowing his customer base and waste stream characteristics,
such that the approved service area is observed.
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5.1.4 Waste Stream and Intake
The facility receives C&D and LCID debris from commercial haulers, contractors, and
private individuals. All materials are inert and meet the NC DENR Division of Waste
Management definitions. The facility expects to receive approximately 150 tons per day
(4000 tpm) of combined C&D wastes and LCID. The franchise allows up to 300 tons per
day. Much of the daily C&D intake will come from an affiliated waste hauling service.
The intake will be source-sorted with putrescible MSW excluded to the extent possible.
5.1.5 Hours of Operation
The facility is open to the public from 7 AM to 5 PM on Monday – Friday and 7 AM to 12
PM on Saturday. All current operations for the facility are within those hours.
5.2 Contact Information
5.2.1 Emergencies
For fire, police, or medical/accident emergencies dial 911.

5.2.2 A-1 Sandrock, Inc., Administrative Offices

Mr. R.E. ‘Gene’ Petty, Sr. – Owner/Operator
Mr. Ronnie E. Petty, III – Owner/Operator
A-1 Sandrock, Inc.
2091 Bishop Road
Greensboro, NC 27406

Tel. [phone]
5.2.3 North Carolina Department of Environment Quality (NCDEQ)

Division of Waste Management - Solid Waste Section

Division of Energy, Minerals and Land Resources - Land Quality Section

450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105

Phone: [phone]

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5.3 Permitted Activities
This document was prepared in pursuit of a Permit to Operate from the NC DEQ Division
of Waste Management, Solid Waste Section, for construction of Phase 3 within the
permitted footprint and continued operation of Phases 1 – 3 (and future Phase 4) over a 5-
year operating cycle. The following is a comprehensive summary of the permitted solid
waste activities within the 75-acre facility, shown on Drawings E1 – E6:
Activities conducted under Permit #41-17 (Processing Facility):
• Receipt of wood wastes and inert debris (C&D and LCID)
• Sorting recyclables, shredding or grinding the wastes1
• Removal of incidental non-compliant wastes2
• Production of mulch, boiler fuel, aggregates3
• Temporary storage of products in roll off boxes4
Activities conducted under Permit #41-17 (CDLF disposal unit):
• Disposal of construction and demolition debris
• Disposal of asbestos wastes in a designated area
1 Primary recyclables include aggregates, wood wastes, and metals; aggregates derived from the two sources
may be combined, wood wastes derived from the two sources may be blended for fuel; typically, the C&D
wastes are better suited for boiler fuel, LCID wastes are better suited for mulching, thus the two waste streams
are typically not blended; no other blending shall occur
2 Includes MSW and other non-C&D wastes that inadvertently enter the C&D waste stream at construction
sites – these materials will be placed in roll-off boxes and taken to the nearby MSW transfer station on a
weekly basis; no MSW disposal shall occur at this facility
3 Materials typically will be distributed off-site, but some on-site use of mulch outside of the active C&D
unit will occur (with limitations on application rates), and aggregates may be used on-site; all non-fuel wood
wastes processed at the facility will be considered as mulch – not compost – with no nutrient value
4 Products typically include, metals, cardboard, and plastic containers.
Sorting and grinding activities will take place within the approved T&P and Storage areas,
located within the Facility Boundary but outside the CDLF footprint. Finished goods will
be stored outside the CDLF footprint. All these areas have been approved for disturbance
and have drainage control measures. No processing or storage activities shall occur within
designated stream buffers, wetlands, or the 100-year floodplain. All activities and areas
are accessible via a single gate, which is secured after hours. Each permitted activity is
described in brief detail in Section 5.4.
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5.4 Description of Facilities
5.4.1 Processing Facility
The Owners of the facility intend to accept appropriate C&D and LCID wastes for
recycling. All incoming materials shall be accurately weighed, classified and recorded to
account for material flow. Intake materials shall be processed within the approved T&P
areas. Recycling activities may continue within the CDLF footprint at the Owner’s
discretion, including materials culled from the working face by the Operator. The
relocation of the T&P areas away from the CDLF is for public safety.

Tipping and processing areas – both inside and outside the CDLF – have runoff control
measures that can be isolated in the event of a spill of fuel, oil, or hazardous materials.
Operations shall be scheduled around the weather to minimize contact between the waste
and water – no grinding of C&D wastes shall take place in the rain. The Operator shall
manage stockpiles or storage containers in accordance with applicable fire protection and
runoff control measures. Section 6.4.4 provides further guidance on stockpiles.

The CDLF working face and processing area is restricted to trained personnel, i.e., staff
and commercial drivers. C&D unloading, processing and disposal areas must be separated
by a minimum of 50 feet. Non-processed materials scheduled for recycling shall be sorted
and placed in temporary stockpiles or containers. Recyclables may be processed and stored
within the CDLF footprint the Phase 1 footprint, subject to periodic cover requirements.

Areas A – E are designated for T&P activities and/or temporary soil storage described
below. All activities are subject to statutory timeframes for processing and relocation of
materials, as well as access requirements for firefighting:

• Area A is for Treatment and Processing of recycled concrete; storage up to
12,000 c.y. of unprocessed material; periodic crushing/grinding.
• Area B is for Treatment and Processing of LCID; temporary storage of up to
6,000 c.y. of unprocessed material; periodic grinding operations.
• Area C is for Treatment and Processing of LCID and wood waste, i.e, curing of
up to 6,000 c.y. of mulch in windrows (no composting); the cured materials may
be screened prior to relocation to finished bins located in a sales area outside the
Facility Boundary.
• Areas D and E are for temporary storage of operational soil and aggregates, with
estimated maximum quantities of 35,426 c.y. and 54,572 c.y., respectively;
subject to maintaining setbacks of ~50 feet from groundwater monitoring wells
and ~40 feet from LFG monitoring wells.
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Recyclable C&D materials shall be shipped to established markets or used on the premises
in a beneficial manner within the statutory timeframes. Non-recyclable C&D wastes shall
be disposed within the on-site C&D disposal facility. One or more roll-off boxes shall be
kept on-hand for inadvertent MSW that might come into the T&P facility, which shall be
removed on a weekly basis. Finished materials shall be removed (or turned) at least
quarterly to prevent composting, except for aggregates and soil (see Section 5.7).
5.4.2 CDLF (Phases 1 – 4)
The CDLF is an unlined landfill encompassing 25.5 acres, approved circa February 2004.
Phases are sized to last approximately 5 years, coinciding with the 5-year Permit to Operate
cycle. All phases drain toward large perimeter channels, which in turn lead to the main
sedimentation basin.
• All E&S measures were designed in accordance with 15A NCAC 4 and were
approved by the (now) NCDEQ Division of Energy, Minerals and Land Resources.
• The edge of waste is clearly staked with permanent markers.
• Closure of various phases will be incremental, conducted in accordance with the
approved Closure/Post-Closure Plan.
• Financial Assurance requirements will be adjusted on a yearly basis to account for
new areas opening and those being closed.
• Operation of the C&D Landfill will be in strict accordance with Solid Waste rules,
including groundwater and landfill gas monitoring programs.
• Other applicable permits include the E&S program and a storm water certificate.
5.5 Facility Drawings
A copy of the approved Facility Plan and construction drawings must be kept on-site
always. Several sets of drawings submitted to various agencies exist, e.g., local
government site plan approval, the original mine permit application and solid waste
applications; revisions have occurred over time. The Engineer should be consulted to
resolve conflicts between drawings.
The Owner/Operator shall note the location of the active working face on the facility plan,
noting areas that have come to final grade and areas that are closed – the map shall be
updated continuously and filed with the Operating Record (Section 5.12). The drawings
show the locations of special waste disposal areas (i.e., asbestos), soil borrow and stockpile
areas.

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5.6 Staff Responsibilities
It is essential that every staff member understand the requirements of not only their
assigned tasks but of the regulatory and safety requirements for the entire facility. Each
worker should understand that the overall compliance of the facility affects not only their
position at the facility but the future ability to continue operations beyond the next 5-year
permit review. All staff should be vigilant about enforcing the waste acceptance policy
and to make sure that all aspects of the operation, from mowing the grass to the daily
transfer or disposal of waste, are conducted in an environmentally sound manner.
Every staff member shall receive instruction on “preventative maintenance” pertaining to
ground water and surface water quality, and how to protect these features, in addition to
waste acceptance criteria and operational requirements that pertain to each individual’s
specific duties. The critical importance of preserving environmental quality and
maintaining operational compliance should be a topic for discussion at regular staff
meetings, along with issues concerning safety and efficient operation of the facility.
In accordance with Rule .0542(j)(2), a trained operator must be on duty at all times when
the facility is open to the public and/or when operations are being conducted. All training
shall be documented, and Operator’s certifications shall be kept current.

5.7 Inspections and Maintenance
The following O&M schedule highlights some, but not all, of the major the requirements
for routine facility inspection and maintenance at both the recycling facility and the CDLF.
This schedule is intended to serve as a guide for the Owner/Operator for addressing short-
term and long-term issues, but the O&M schedule does not alleviate the Owner/Operator
of key rule requirements, whether they are covered here. Particular emphasis shall be paid
to the following:
• Collect trash and windblown debris around the scale, buildings, and areas outside
the working face daily in compliance with Rule 15 NCAC 13B .0542(g)(3).
• Note the date and time of cover placement (periodic and interim covers) in the
operating record in compliance with Rule .0542(f)(2).
The following tabulated summary for normal operations (see Sections 6.0 and 7.0) hereby
replaces the O&M Checklist presented in the 2009 permit application:
Daily
• Remove any Trash or Debris at Facility Entrance, Scales, Driveways, Ditches
• Remove any Trash or Debris around CDLF and Processing Areas, including Trees
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• Check for Windblown Debris Escaping CDLF Working Face
• Verify All Waste Intake Processed and/or Disposed within 48 hours
• Verify Working Face under One-Half Acre (200 x 200 feet)
• Check Finished Goods Stockpiles for Foreign Materials or Trash
• File Waste Inspection Forms (Minimum 3 per Week)

Weekly
• Verify Working Face is Covered Weekly
• Verify Access Roads are Passable
• Check for Spills or Leaks on Roads, Processing and Storage Areas, Working Face
• Verify that Inactive Disposal Areas are Covered per Solid Waste Rules
• Check for Proper Drainage Conditions, Erosion, Sediment Buildup
• Inspect Gates, Locks, Fences, Signs
• Check Communication and Surveillance Equipment
• Check Mulch Stockpile Size (should be under 6000 cy)

Monthly
• Check for Excess Erosion on Slopes or Benches and Ditches
• Verify Vegetation is Healthy on Slopes, Ditches and Shoulders
• Verify that Sediment Basin Primary Outlet is Draining within 5 Days

Semi-Annually
• CDLF Slope Vegetation Mowed (Minimum Twice per Year)
• Inspect for CDLF Slopes Cracking, Sloughing, Bulging, Excess Erosion
• Turn or Remove Finished Mulch Stockpiles (Minimum Twice per Year)
• Mow Clear Access Paths to Monitoring Wells

Annually
• Staff Training Certifications Up to Date
• Annual Topographic Survey of CDLF

5.8 Access Control

5.8.1 Physical Restraints – The site is accessible by the single entrance gate. All
customers and visitors shall check-in upon arrival; all incoming waste-hauling vehicles
shall cross the scales. The entrance gates will be securely locked during non-operating
hours.

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5.8.2 Security – Frequent inspections of gates and fences will be performed by landfill
personnel. Evidence of trespassing, vandalism, or illegal operation will be reported to the
Owner. Attention shall be paid to the eastern Facility Boundary, where no fences exist and
only topography and vegetation are the physical barriers.

5.8.3 All-Weather Access – The on-site roads will be paved or otherwise hardened and
maintained for all-weather access.

5.8.4 Traffic – The Operator shall direct traffic to a waiting area, if needed, and onto the
working face with safe access to an unloading site is available. Once a load is emptied, the
delivery vehicle will leave the working face immediately.

5.8.5 Anti-Scavenging Policy – The removal of previously deposited waste by members
of the public (or the landfill staff) is strictly prohibited by the Division for safety reasons.
The Operator shall enforce this mandate and discourage loitering after a vehicle is
unloaded. No persons that are not affiliated with the landfill or having business at the
facility (i.e., customers) shall be allowed onto or near the working face.

5.8.6 Signage – A prominent sign containing the information required by the Division
shall be placed just inside the main gate. This sign will provide information on operating
hours, operating procedures, and acceptable wastes. Additional signage will be provided
within the landfill complex to distinctly distinguish access routes. Restricted access areas
will be clearly marked and barriers (e.g., traffic cones, barrels, etc.) will be used.

5.8.7 Communications – Visual and radio communications will be maintained between
the C&D landfill and the landfill scale house and field operators. The scale house has
telephones in case of emergency and for the conduct of day-to-day business. Emergency
telephone numbers (Fire and Rescue) are displayed in the scale house.

5.9 Fire and Safety

5.9.1 Fire Prevention – Stockpiles in the processing facility shall take measures to
prevent fires in the raw materials and finished goods. Stockpiles (and the disposal area)
shall be inspected daily for signs of smoke or combustion. All stockpiles shall be separated
by a minimum distance of 25 feet for access. Any single pile of combustible materials
shall be limited to 6,000 cy in size and turned on a quarterly basis or when dictated by
temperature. If a stockpile is in place for more than six months, it shall be monitored for
dryness and temperature. A maximum allowable temperature shall be 120℉.

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Landfills shall be inspected daily for signs of smoke or combustion. Signs to look for
include cracks that are venting smoke or excessive steam and have elevated temperatures.
Mitigation of excess temperatures in landfills largely depends on the depth that the
temperatures occur. At lower depths, the level of oxygen is low enough that fire is less
likely to occur; access is limited. Elevated temperatures at shallow depths may require
mitigation, e.g., spreading the waste or sprinkling with water to cool the “hot spot.” Care
should be taken when excavating into waste to avoid ignition or flareups.

Fire Control – Fires in landfills and stockpiles (especially LCID facilities) have been a
regulatory concern in recent times. The possibility of fire within the landfill or a piece of
equipment must be anticipated. A combination of factory installed fire suppression systems
and/or portable fire extinguishers shall be kept operational on all heavy equipment. Brush
fires of within the waste may be smothered with soil, if combating the fire poses no danger
to the staff. The use of water to combat the fire is allowable, but soil is preferable. For
larger or more serious fire outbreaks, the local fire department will respond. In the event
of any size fire at the facility, the Owner shall contact NCDEQ Division Waste
Management personnel within 24 hours and complete a Fire Notification Form
(Appendix 4B) within 15 days, which will be placed in the Operating Record.

5.9.2 Personal Safety – Safety is a key concern with the operation of this facility. All
aspects of operation were planned with the health and safety of the landfill's operating staff,
customers, and neighbors in mind. Prior to commencing operations, a member of the
management staff will be designated as Site Safety Officer. This individual, together with
the Facility's management will modify the site safety and emergency response program as
needed to comply with National Solid Waste Management Association and Occupational
Safety and Health Administration (OSHA) guidance. Staff safety meetings (minimum one
per month) shall be conducted. Safety equipment to be provided includes (at a minimum)
equipment rollover protective cabs, seat belts, audible reverse warning devices, hard hats,
safety shoes, and first aid kits.

The working face of a landfill is an inherently dangerous place due to the movement of
heavy equipment, steep slopes, obstacles to pedestrian movement and sometimes poor
visibility (such as equipment backing up). These considerations are also a concern for the
sorting and grinding operations, as well as the concern for flying debris that can be ejected
from a tub grinder. Safety for customers will be promoted by the Operator and his staff by
always knowing where the equipment and customer vehicles are moving. Radio
communications between the scale house and the field staff will help keep track of the
location and movement of customers.

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The processing areas (C&D and/or LCID) and public access areas shall be located no
closer than 50 feet to the working face of the CDLF disposal unit. Signs, fences and/or
physical barriers will be used to separate public access areas from the working face of the
CDLF and the waste processing areas (sorting, grinding, etc.). Activities that could
endanger the public shall not be conducted when non-employees are present. Vehicles
transporting waste to the facility and/or the public shall not have access to the working
face. Children under the age of 16 shall not be allowed in the facility. No waste unloading,
grinding or disposal activities shall be conducted after dark.

5.10 Other Regulatory Requirements
5.10.1 Sedimentation and Erosion Control – All aspects of the facility operation are
subject to the requirements of 15A NCAC 4, the Sedimentation and Erosion Control rules.
Runoff measures for this facility were designed in accordance with this rule and approved
by the now NCDEQ Division of Energy, Minerals and Land Resources, Land Quality
Section. Approved S&EC measures shall be installed and maintained throughout the
operational life of the facility and into the post-closure period (see Closure/Post Closure
Plan, Section 7.0). Measures to curtail erosion include vegetative cover and woody mulch
as ground cover. Measures to control sedimentation include stone check dams in surface
ditches, sediment traps and basins. As of March 2013, all exposed soils, regardless of
whether they are inside or outside the disposal area, shall be vegetated or otherwise
stabilized within 15 days after any given area is brought to final grade.
5.10.2 Water Quality (Storm Water) Protection – Due to the mining permit, this facility
is covered by NC DEQ Division of Water Quality Storm Water General Permit,
NCG020000 – Certification No. NCG020633. Compliance with the provisions of the
permit – and the monitoring requirements – is required. A Storm Water Pollution
Prevention Plan was prepared for the facility, in accordance with the General Permit,
which shall be observed and incorporated into the daily operation of the facility.
Steps to protect water quality include diverting surface water (“run-on”) away from the
disposal area, allowing no impounded water inside the disposal area, and avoiding the
placement of solid waste into standing water. The facility is obligated by law not to
discharge pollutants into the waters of the United States (i.e. surface streams and wetlands).
Any conditions the Operator suspects might constitute a discharge should be mitigated
immediately – appropriate agencies and the Engineer should be contacted.

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5.11 Miscellaneous Requirements

5.11.1 Minimizing Surface Water Contact – Protection of water quality is a key interest
in the operation of this facility. Although C&D wastes are typically inert, there can be
chemical residues present in the C&D (e.g., solvents) that can mobilize upon contact with
water – i.e., leachate generation – and which can enter the environment via storm water
runoff. This tends to be more prevalent when the wastes are processed (sorted and ground)
due to increased surface area available to contact the water source and increased exposure
to ambient conditions.

Whereas the tipping and processing areas will be uncovered, the C&D processing facility
shall not be operated during rain events to minimize contact between the waste and
surface water, thus minimizing leachate generation. Activities pertaining to the
processing facility should be scheduled to accommodate the weather forecast. During
periods of light rain unloading may occur and sorting operations may occur if no runoff is
visible, but no grinding shall occur. During heavy rain (with visible runoff) or periods of
high wind the incoming (unprocessed) materials shall be stockpiled and covered with tarps
(secured against wind) or incorporated into the working face to minimize contact with
water. Processed materials (including source-sorted loads) shall be placed in appropriate
(covered) containers – i.e., transport trailers or roll-off boxes.

5.11.2 Processing Facility Operation over the CDLF – The Processing Facility
(tipping, sorting, loading) activities will move within the C&D footprint to be near the
working face of the CDLF unit, albeit a safe distance (minimum of 50 feet) shall be
maintained, to promote safety of workers and the public (Section 5.9.2). The Processing
Facility may be located atop an inactive portion of the CDLF unit.

When the Processing Facility is to be operated over an inactive portion of the CDLF, a
soil pad with a minimum thickness of 2 feet shall be placed beneath the processing
facility operational area (including the tipping and grinding areas), in addition to the
interim soil cover that might already be present (see Section 7.4.2).

The purpose of the supplemental operating soil pad is to protect the underlying wastes –
and water quality – against possible spills, leaks and/or the introduction of non-compliant
materials (liquids) that might escape detection in the preliminary screening. The soil pad
serves as a sorbent layer that can be removed in the case of an incident, minimizing the
chance of the incident affecting the ground water or surface water monitoring system, and
maintaining adequate coverage for the underlying wastes. The soil pad may be removed
at the end of the processing operation and/or prior to placement of final cover.
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5.11.3 Equipment Maintenance – Facility equipment consists of a variety of
excavators, loaders, dozers, dump trucks, and specialized equipment, e.g., a tub grinder for
LCID and a separate grinder with power screens for aggregates. Most of the equipment is
used in the normal course of mining operations. The Owner represents that he has
sufficient resources to provide and maintain the needed equipment to operate the facility.
A maintenance schedule for the facility equipment is beyond the scope of this Operations
Plan. The Operator (or their designee) should develop a routine equipment maintenance
program to lessen the likelihood of fluid spills or leaks. Fuel and lubricants shall be stored
always under covers and/or with secondary containment systems that are separate from the
principle storm water drainage systems. Care shall be taken when servicing or fueling
equipment to prevent spills.

Driveways, shop areas and all operations areas where heavy equipment is working shall be
inspected daily for signs of spills and leaks. Equipment should be parked overnight and
serviced in areas that will not contaminate the facility storm water management systems.
Care shall be taken not to allow any hazardous substance to enter the surface water or
ground water, including (but not limited to) fuel, oil, hydraulic fluid, pesticides, and
herbicides. The Storm Water Pollution Prevention Plan and NC DEQ Storm Water
General Permit requirements shall be observed.

5.11.4 Utilities – Electrical power, water, telephone, and restrooms will be provided at
the scale house. Other sanitary facilities shall be provided for the field staff, as needed.
Two-way radios or cell phones shall be provided to the field staff for communication with
the scale house. Portable light plants may be required to promote safe operation of the
processing facility in the late afternoon or evening.

5.11.5 Vector Control – Steps shall be employed to minimize the risk of disease carrying
vectors associated with the landfill (e.g., birds, rodents, dogs, mosquitoes). The C&D
wastes should be mostly inert (subject to the waste screening procedures) and not attractive
to animals. Pools of standing water should be avoided.

5.11.6 Air Quality Criteria

Dust Control – Measures shall be taken to control dust from the operations. Dusty wastes
shall be covered immediately with soil and water shall be sprinkled on roads and other
exposed surfaces (including operational cover and/or the working face, as needed) to
control dust. Disposal activities may need to be suspended during high winds.

Open Burning – No open burning of any waste shall be allowed.
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State Implementation Plan – Compliance with the State Implementation Plan (SIP) for
air quality under Section 110 of the Clean Air Act, as required by 15A NCAC 13B .0531 et
seq., is demonstrated with the following discussion. Typically, the SIP focuses on
industries that require air permits and activities that have regulated emissions that
contribute to unhealthy levels of ozone (NOx, SO4, VOC’s), particularly coal combustion
(electric power plants) and other “smokestack” industries. Compliance with the spirit of
the SIP is demonstrated by the prohibition of combustion of solid waste, the fact that the
wastes are generally inert and do not emit sufficient quantities of landfill gas to require
active controls (such as flaring), and the status of the regional attainment. The facility is
not located in a designated area of non-attainment for ozone and/or fine particle emissions.

Nonetheless, proactive steps that can be taken at the facility include dust control measures
(see below) to minimize airborne particle emissions: minimizing the idling time on trucks
and equipment, keeping mechanized equipment in good operating condition, and the use
of low-sulfur fuels, subject to availability. Adherence to the waste acceptance criteria will
minimize VOC emissions. Regular application of periodic cover will reduce the risk of
fires and curtail wind-blown debris. The proper use of vegetative cover will further
minimize fugitive emissions of dust and particulates.

5.11.7 Litter Control – Appropriate measures will be taken to control trash and
windblown debris within and around the facility, including litter on Bishop Road. The site
and entrance will be policed for litter on a weekly basis and such materials will be collected
and disposed of properly.

5.12 Operating Record

The Operating Record shall consist of one or more files, notebooks, or computerized
records and associated maps that document the day-to-day facility operations, including
the waste intake and sources, transfer records, routine waste placement, cover, and closure
activities (for the CDLF), and routine or special maintenance requirements and follow up
activities. The following records shall be maintained:
A Daily intake tonnage records - including source of generation
B Tonnage and type of recycled materials shipped offsite
C The locations and date of waste placement, interim cover placement, and
final cover placement shall be recorded on the facility map as these
activities are performed.
D Waste inspection records (on designated forms); fire notification forms;
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E Quantity, location of disposal, generator, and special handling procedures
employed for all special wastes disposed of at the site
F Generators or haulers that have attempted to dispose of restricted wastes
G Employee training procedures and records of training completed
H Ground water quality monitoring information including:
1. Copy of the current Sampling and Analysis Plan (Monitoring Plan)
2. Monitoring well construction records
3. Sampling reports
4. Records of inspections, repairs, etc.
I Notation of the date and time of the cover placement (both periodic and
interim covers) must be recorded in the operating recorded in compliance
with Rule .0542(f)(2).
J Closure and post-closure information, where applicable, including:
1. Testing
2. Certification
3. Completion records
K Cost estimates for financial assurance documentation
L Annual topographic survey of the active disposal phase
M Records of operational problems or repairs needed at the facility, e.g., slope
maintenance, upkeep of SE&C measures, other structures
N Equipment maintenance records
O Daily rainfall records (via on-site rain gauge)
P Landfill gas monitoring information:
1. Quarterly methane monitoring records
2. Landfill Gas Monitoring and Control Plan
Q Updated Financial Assurance Documentation
R Compliance Audit Records (by the Solid Waste Section) and
documentation of follow up measures to ensure compliance
S Copies of the Operation Plan, Closure and Post Closure Plan,
Sediment and Erosion Control Plan, Construction Drawings,
Storm Water Pollution Prevention Plan, Storm Water General Permit
Certificate of Coverage, and Solid Waste Permit

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The Owner or their designee will keep the Operating Record up to date. Records shall be
presented upon request to DWM for inspection. A copy of this Operations Plan, along
with the Closure/Post-Closure Plan, the Monitoring Plan, and Monitoring Records
shall be on-premises and always available.

5.13 Annual Report

The facility shall file an annual report with the NC DEQ Division of Waste Management
by August 1 of each year, detailing the activities for the preceding July 1 through June 30.
Records shall include types and amounts of wastes received, reused, recycled, and
distributed. Material quantities shall be reported annually in tons.

The C&D landfill rules require an annual survey to determine slope, height, and volume
(see Section 7.5). The reporting requirements include an annual topographic map prepared
by a licensed surveyor. The map shall show areas that are stabilized with vegetation. The
Storm Water General Permit, issued by NC DEQ Division of Waste Quality, has an annual
sampling and reporting requirement.

5.14 Contingency Plan

5.14.1 Hot Loads Contingency – In the event of a "hot" load attempting to enter the
landfill, the scale house staff will turn away all trucks containing waste that is suspected to
be hot, unless there is imminent danger to the driver. The vehicle will be isolated away
from structures and other traffic and the fire department will be called. The vehicle will
not be allowed to unload until the fire is out. If a hot load is detected on the working face,
then the load will be treated as a fire condition (see Section 5.9), whereas the load will be
spread as thin as possible and cover soil will be immediately placed on the waste to
extinguish the fire. Other traffic will be redirected to another tipping area (away from the
fire), or other waste deliveries may be suspended until the fire is out. The fire will be
monitored to ensure it does not spread. If the fire cannot be controlled, the fire department
will be notified, and the area cleared of non-essential personnel.

5.14.2 Hazardous Waste Contingency – In the event identifiable hazardous waste or
waste of questionable character is detected at the scales or in the landfill, appropriate
protective equipment, personnel, and materials shall be employed to protect the staff and
public. Hazardous waste identification may be based on (but not limited to) strong odors,
fumes or vapors, unusual colors or appearance (e.g., liquids), smoke, flame, or excess dust.
The fire department will be called immediately if a hazardous material is detected.

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An attempt will be made to isolate the wastes in a designated area where runoff is
controlled, preferably prior to unloading, and the vicinity will be cleared of personnel until
trained emergency personnel (fire or haz-mat) take control of the scene. Staff will act
prudently to protect personnel, but no attempt will be made to remove the material until
trained personnel arrive. A partial listing of regional Hazardous Waste Responders and
disposal firms is found in Appendix 4C.

The Operator will notify the Division (see Section 5.2.3) that an attempt was made to
dispose of hazardous waste at the landfill. If the vehicle attempting disposal of such waste
is known, attempts will be made to prevent that vehicle from leaving the site until it is
identified (license tag, truck number driver and/or company information) or, if the vehicle
leaves the site, immediate notice will be served on the owner of the vehicle that hazardous
waste, for which they have responsibility, has been disposed of at the landfill.

The landfill staff will assist the Division as necessary and appropriate in the removal and
disposition of the hazardous waste (acting under qualified supervision) and in the
prosecution of responsible parties. If needed, the hazardous waste will be covered with on-
site soils, tarps, or other covering until such time when an appropriate method can be
implemented to properly handle the waste. The cost of the removal and disposing of the
hazardous waste will be charged to the owner of the vehicle involved. Any vehicle owner
or operator who knowingly dumps hazardous waste in the landfill may be barred from
using the landfill or reported to law enforcement authorities.

Any hazardous waste found at the scales or in the landfill that requires mitigation under
this plan shall be documented by staff using the Waste Screening Form provided in
Appendix 4A. Records of information gathered as part of the waste screening programs
will be placed in the Operating Record and maintained throughout the facility operation.

5.14.3 Severe Weather Contingency – Inclement weather can affect the operation of the
landfill. Some anticipated conditions and recommended responses are as follows.

5.14.3.1 Ice Storms – An ice storm can hinder access to the landfill, prevent
movement or placement of periodic cover, and, thus, may require closure of the
landfill until the ice is removed or has melted and the access roads are passable
without risk to personnel of the side slopes cover.

5.14.3.2 Heavy Rains – Exposed soil surfaces can create a muddy situation in
some portions of the landfill during rainy periods. The control of drainage and use
of crushed stone (or recycled aggregates) on unpaved roads should provide all-
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weather access for the site and promote drainage away from critical areas. In areas
where the aggregate surface is washed away or otherwise damaged, aggregate
should be replaced. Intense rains can affect newly constructed drainage structures
such as swales, diversions, cover soils, and vegetation. After such a rain event,
inspection by landfill personnel will be initiated and corrective measures taken to
repair any damage found before the next rainfall.

Processing activities should be planned to avoid sorting and grinding during
periods of rain. Ideally, waste deliveries should be suspended until the rain
passes, but if unloading in the rain cannot be avoided, the debris piles should be
kept small as possible and covered with tarps. Sorting should be completed as
soon as practical and all materials cleared from the tipping area to avoid contact
with rain or runoff.

5.14.3.3 Electrical Storms – The open area of a landfill is susceptible to the
hazards of an electrical storm. If necessary, landfill activities will be temporarily
suspended during such an event. To promote the safety of field personnel, refuge
will be taken in buildings or in rubber-tire vehicles.
5.14.3.4 Windy Conditions – High winds can create windblown wastes, typically
paper and plastic, but larger objects have been known to blow in extreme
circumstances. Operations should be suspended if blowing debris becomes a
danger to staff, after the working face is secured. The proposed operational
sequence minimizes the occurrence of unsheltered operations relative to prevailing
winds. If this is not adequate during a particularly windy period, work will be
temporarily shifted to a more sheltered area.

When this is done, the previously exposed face will be immediately covered with
periodic cover. Soil cover shall be applied whenever windblown wastes become a
problem. Staff shall patrol the perimeter of the landfill periodically, especially on
windy days, to remove windblown litter from tress and adjacent areas.
Windscreens of various sorts have been used with mixed success at other facilities
in the region. Proper planning for windy conditions is essential.

5.14.3.5 Violent Storms – In the event of a hurricane, tornado, or severe winter
storm warning issued by the National Weather Service, landfill operations shall be
suspended temporarily until the warning is lifted. Periodic cover will be placed on
exposed waste and buildings and equipment will be properly secured. In the event
of eminent danger to staff or the public, personal safety shall take precedence over
other concerns.
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6.1 Overview

This section describes the general waste intake and handling operations for the Treatment
and Processing (Recycling) facility. These protocols shall be followed, regardless of
whether the material is source-sorted and delivered by affiliated waste transport vehicles
or brought to the facility by private contractors or the public. These protocols are
applicable to recycling activities conducted near the working face of the CDLF and within
T&P Areas A – E (used for concrete, LCID, wood waste, soil and aggregates). No C&D
wastes described below shall be placed in the T&P Areas A – E.

6.2 Acceptable Wastes

The Facility shall only accept these waste types generated within approved service area:

• Construction Debris: Unpainted and untreated wood, plywood, particle board,
hardboard, gypsum board, siding, flooring, asphalt shingles, etc., from new residential
or commercial construction; acceptable only within the CDLF footprint.

• Demolition Debris: Concrete, brick, block and asphalt will be accepted; unpainted and
untreated wood, roofing, insulation, piping, wallboard, siding, etc., from residential and
commercial remodeling, repair, or demolition operations, will be accepted after the
Facility produces certificates of training for the staff pertaining to the identification
and safe handling of hazardous materials (e.g., asbestos, lead paint); acceptable only
within the CDLF footprint.

• Land Clearing and Inert Debris: Stumps, trees, limbs, brush, other vegetation,
concrete, brick, concrete block, clean soils and rock, untreated/unpainted wood, etc.;
acceptable within T&P Areas A – E.

6.3 Prohibited Wastes

No municipal solid waste (MSW), hazardous waste as defined by 15A NCAC 13A .0102,
including hazardous waste from conditionally exempt small quantity generators (CESQG
waste), or liquid waste will be accepted at this facility. In addition, no tires, batteries,
polychlorinated biphenyl (PCB) waste, electronic devices (computer monitors), or mercury
switches and fluorescent lamps will be accepted. Animal carcasses will not be accepted.
No oils, grease, solvents, or fluids of any kind will be accepted, nor will bagged wastes or
any putrescible or household wastes. A partial listing of prohibited wastes is presented on
Table 6A following this section.
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6.4 Waste Processing

To assure that no prohibited waste enters the Facility, a waste screening program will be
implemented (see Section 6.4.1). Waste received at the scale house will be inspected by
trained personnel. These individuals will be trained to spot indications of suspicious
wastes, including: hazardous material placards or markings, liquids, powders or dusts,
sludges, bright or unusual colors, drums or commercial size containers, and "chemical"
odors. Screening programs for visual and olfactory characteristics of prohibited wastes will
be an ongoing part of the Facility operation.

6.4.1 Waste Receiving and Screening

All incoming vehicles must stop at the scale house located near the entrance of the facility
and visitors are required to sign-in. All waste transportation vehicles shall be uncovered
prior to entering the scales to facilitate inspection. All incoming loads shall be weighed,
and the content of the load assessed. The attendant shall request from the driver of the
vehicle a description of the waste it is carrying to ensure that unacceptable waste is not
allowed into the Facility. Signs informing users of acceptable and unacceptable types of
waste shall be posted near the facility entrance. The attendant shall visually check the
vehicle as it crosses the scale. Suspicious loads will be pulled aside for inspection prior to
leaving the scale area. Loads with unacceptable materials or wastes generated from outside
of the service area will be directed to the nearby Transfer Station.
Once passing the scales, incoming transport vehicles will be routed to the tipping area for
unloading, inspection, sorting and appropriate processing, depending on the nature of the
load – C&D and LCID materials will go to separate areas (Sections 6.4.2 and 6.4.3).
Incoming vehicles shall be selected at random for screening a minimum of three times
per week. The selection of vehicles for screening might be based on unfamiliarity with the
vehicle/driver or based on the driver’s responses to interrogation about the load content.
Vehicles selected for inspection shall be directed to an isolated area away from the
stockpile of materials, where the vehicle will be unloaded, and the waste shall be carefully
spread using suitable equipment. An attendant trained to identify unacceptable wastes shall
inspect the waste, using the Waste Screening Form (Appendix 4A) to document the waste
screening activity. After the waste screening inspection of a load, one of the following
activities will occur:
• If no unacceptable waste is found, the load will be pushed to the active recycling
area and processed with the remainder of the day’s intake;
• If unacceptable materials are found, the entire load will be isolated and secured via
barricades, then loaded into roll-off boxes for disposal at a permitted facility;
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• Non-hazardous materials will be reloaded onto the delivery vehicle for removal
from the facility, the hauler will be escorted to the nearby MSW Transfer Station;
• If hazardous materials are detected, the Hazardous Waste Contingency Plan
outlined in Section 5.14 will be followed.
The hauler will be responsible for removing unacceptable waste from the Facility. The
rejection of the load shall be noted on the Waste Screening Form, along with the
identification of the driver and vehicle. A responsible party to the load generator or hauler
shall be notified that the load was rejected. The generator or hauler may be targeted for
more frequent waste screening and/or banished from delivering to the facility, depending
on the nature of the violation of the waste acceptance policy. State and County authorities
may be notified of severe or repeat offenders.

Facility staff at the tipping area and on the working face may detect unacceptable waste
after it is unloaded, and the delivery vehicle has departed. One or more roll-off boxes will
be kept on-site for keeping materials that require disposal in a MSWLF. Such “rejects”
will be placed into the roll-off boxes and removed from the site for disposal at an approved
facility, e.g. the nearby Transfer Station on Bishop Road or another approved MSW
facility. The roll-off boxes will be removed on a weekly basis.

6.4.2 LCID Processing

The Facility may recycle LCID to make mulch, boiler fuel, and aggregates. LCID wastes
generally consist of brush, limbs, tree trunks, stumps, leaves, dirt, inert debris, and other
materials defined by the NC DENR Solid Waste rules. LCID materials may be stockpiled
and shredded or ground within a designated area (in a future CDLF phase) but separated
from the CDLF working face. Some LCID materials may be combined with similar C&D
materials post-processing – e.g., wood wastes that can be ground into boiler fuel or mulch
and inert debris that can be processed into aggregates. LCID materials shall not be
commingled with other materials prior to processing, except for concrete debris.

6.4.3 C&D Processing

The Facility may recycle C&D wastes aggregates, boiler fuel, mulch, and beneficial fill.
C&D materials may arrive source-sorted, having been transported by an affiliated hauler;
other recyclable material may be culled from the working face. Sorting will take place at
least 50 feet from the active CDLF tipping area and/or working face, with appropriate
runoff controls and S&EC measures in place. The sorted materials will be redirected to
appropriate stockpiles and/or roll-off boxes and temporarily stored for further processing
(see below). Non-recyclable C&D materials will be pushed into the CDLF working face
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(see Section 7.0). Co-mingling of pre-process or interim stage processed materials from
the C&D and LCID waste streams will NOT be allowed (except for concrete debris).
Separate stockpiles or containers shall be maintained.

6.4.4 Stockpile Guidance

Temporary storage areas A – E provide considerable space for managing bulky materials,
intended to enhance the recycling capabilities and safety of the Facility. The volume of
non-processed and finished recyclable materials which the Facility may have on premises
will be limited by the availability of space needed to conduct compliant operations.

NCGS 130A 309.05(c)(1) requires 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.

Placement and sizing of stockpiles need to incorporate factors of safe operation, required
storage time, and fire prevention. Stockpiles must be separated by at least 25 feet of clear
space to allow access by fire-fighting equipment. Stockpiles should be easily reached with
equipment and exhibit maximum 2H:1V side slope ratios for stability. The following table
provides height and base dimensions for certain stockpile volumes at various heights.

Height of
Pile, ft
Top of Pile
Diameter, ft
Bottom of Pile
Diameter, ft
Average Cross
Section Area, sf
Volume,
cy
20 20 100 60 2,093
20 40 80 80 3,721
25 20 120 70 3,562
25 40 140 90 5,887
30 20 140 80 5,582

6.4.5 Processing to Finishing Goods

Processing activities shall be limited to grinding, shredding, or chipping land clearing
debris, unpainted/untreated wood waste (including pallets and new construction waste),
and certain engineered wood products (plywood, particle board), to make boiler fuel or
mulch (but not compost). Inert materials will be processed and recycled into aggregates.
The operation of the Processing Facility will include the following:

• Pre-processed sorted C&D (raw materials) will be stockpiled temporarily in the
designated processing areas, either adjacent to the working face or in Areas A – C.
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• Woody materials suitable for making mulch and/or boiler fuel (including pallets)
will be ground or shredded on a monthly schedule and stockpiled in designated
areas (on the ground) and/or shipping containers.
• Earthen inert materials (dirt, rocks, concrete debris) suitable for “beneficial fill”
(defined by Rule 15A NCAC 13B .0562) and/or processing into aggregates will be
ground or shredded and stockpiled in designated areas.
• Metals will be placed in roll-off boxes and kept clean and ready to haul to off-site
recycling operations until a full load is reached.
• NC DEQ guidelines apply for storing and processing asphalt shingles intended for
recycling (see Section 6.4.8). Source-sorted, new (non-asbestos), tear-off asphalt
shingles may be stored for recycling. Shingles accepted for disposal only should
be sent to the working face. No grinding of shingles shall be conducted onsite.
6.4.6 Non-Processed Material Storage

Individual stockpiles of non-unprocessed materials (not stored in roll-off boxes) shall be
kept to 6,000 c.y. per stockpile. Wood wastes should not be stored more than 3 months
unless temperatures are monitored. If the intake of wood waste exceeds the ability for
timely processing and sales, the intake of wood waste may be curtailed or diverted to the
CDLF. Inert materials (concrete, soil) must be stabilized to minimize runoff and erosion.
6.4.7 Processed Material Storage
Finished combustible materials, e.g., boiler fuel and mulch (see Sections 6.4.2 and 6.4.3)
may be stored for no more than 3 months in stockpiles not exceeding 6,000 c.y. per pile.
If stockpiles of finished products must remain on site longer, the stockpiles shall be wetted
as needed and turned quarterly to prevent composting and/or fires (see Section 5.5). Non-
combustible materials do not pose a fire hazard and may be stockpiled for no more than
one year, providing fire prevention and erosion control requirements are observed.
6.4.8 Asphalt Shingle Storage for Recycling
The Owner/Operator shall only accept new tear-off asphalt shingles for storage, typically
from contractors they know. No grinding of shingles shall be conducted at the facility.
Source-sorted shingles shall be placed into roll off boxes or temporary stockpiles as
separate loads. Documentation for the source for each load shall be retained. A detailed
plan for documenting the intake and distribution (i.e., to a licensed recycler) of asphalt
shingles is found in Appendix 4D. Post-consumer asphalt shingles (PCAS), i.e. old
shingles, may contain asbestos and shall not be stored or processed at this facility.
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Asphalt shingles arriving without documentation or in mixed loads may be accepted for
disposal, but these materials shall not go through the processing line and should be sent to
the working face. Acceptance and storage of documented asphalt shingles for off-site
recycling may take place within the current T&P area on top of the CDLF, at least 50 feet
away from the working face alongside other recycling activities. The facility is only
authorized to receive and store asphalt shingles at present. The facility must adhere to
NCDEQ’s documentation requirements outlined in Appendix 4D to maintain operational
compliance. Should the facility opt to grind shingles into a recycled byproduct in the
future, an additional Solid Waste Processor permit application and an asbestos screening
plan will be prepared to supplement this operational.

6.5 Contingency Plan
Refer to Section 5.14
6.6 Annual Reporting
Refer to Sections 5.12 and 5.13

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Table 6A
PROHIBITED WASTES AT THE PROCESSING FACILITY*

• Putrescible wastes (garbage and/or food wastes)
• Sludges of any kind
• Hazardous wastes: Pesticides
Herbicides
Used motor oil
Antifreeze
Solvents
Paint thinners
• Hazardous materials as defined by 15A NCAC 13A
• Radioactive materials
• Lead acid batteries
• Regulated medical wastes
• Polychlorinated biphenyls (PCB) wastes
• White Goods
• Liquid wastes
• Animal carcasses
• Asbestos wastes
• Yard Wastes
• Tires
• Electronic equipment
• Mercury switches or lamps
*References: 15A NCAC 13B .0103
15A NCAC 13B .1626

All materials must dry enough to pass a paint-filter test.
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7.1 Waste Acceptance Criteria

7.1.1 Permitted Wastes

The C&D Landfill shall only accept (for disposal) the following wastes generated within
approved areas of service:

• Construction and Demolition Debris Waste: (Waste or debris derived from
construction, remodeling, repair, or demolition operations on pavement or
other structures);
• Land Clearing and Inert Debris Waste: (yard waste, stumps, trees, limbs,
brush, grass, concrete, brick, concrete block, uncontaminated soils and rock,
untreated and unpainted wood, etc.);
• Other Wastes as approved by the NC DENR Solid Waste Section.

7.1.2 Asbestos

A-1 Sandrock may dispose of asbestos containing materials (ACM) within the C&D
landfill, or within a special designated area, only if the asbestos has been processed and
packaged in accordance with State and Federal (40 CFR 61) regulations. Handling
asbestos requires advance arrangements between the hauler and the landfill and special
placement techniques (see (Section 7.3.5). Locations and dates of ACM burial sites shall
be recorded on the facility map.

7.1.3 Wastewater Treatment Sludge

Sludges of any kind shall not be disposed in the C&D Landfill, per Division rules. Waste
Water Treatment Plant sludge may be used as a soil conditioner to enhance the final cover,
upon receipt of permission from the Division, to be applied at agronomic rates.

7.2 Waste Exclusions

No municipal solid waste (MSW), hazardous waste as defined by 15A NCAC 13A .0102,
or hazardous waste from conditionally exempt small quantity generators (CESQG waste),
sludges or liquid wastes will be accepted. No drums or industrial wastes shall be accepted.
No tires, batteries, polychlorinated biphenyl (PCB), electronic devices (computer
monitors), medical wastes, radioactive wastes, septage, white goods, yard trash, fluorescent
lamps, mercury switches, lead roofing materials, transformers, or CCA treated wood shall
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be accepted. No pulverized or shredded C&D wastes may be accepted – except those
materials received and inspected in a whole condition and shredded on-site. The Facility
will implement a waste-screening program, described in Section 7.3 below, to control these
types of waste. Solid Waste Rule .0542 (e) contains further exclusions (see Table 7.1 at
the end of this section).

7.3 Waste Handling Procedures

To assure that prohibited wastes are not entering the landfill facility, screening programs
have been implemented at the landfill. Waste received at both the scale house entrance
and waste taken to the working face is inspected by trained personnel. These individuals
have been trained to spot indications of suspicious wastes, including: hazardous placards
or markings, liquids, powders or dusts, sludges, bright or unusual colors, drums or
commercial size containers, and "chemical" odors. Screening programs for visual and
olfactory characteristics are an ongoing part of the landfill operation.

7.3.1 Waste Receiving and Inspection

All incoming vehicles must stop at the scale house located near the entrance of the facility,
and visitors are required to sign-in. All waste transportation vehicles shall be uncovered
prior to entering the scales to facilitate inspection; all incoming loads shall be weighed, and
the content of the load assessed. The scale attendant shall request from the driver of the
vehicle a description of the waste it is carrying to ensure that unacceptable waste is not
allowed into the landfill.

Signs informing users of the acceptable and unacceptable types of waste shall be posted at
the entrance near the scale house. The scales attendant shall visually check the vehicle as
it crosses the scale. Any suspicious loads will be pulled aside for a more detailed inspection
prior to leaving the scale house area. Loads with unacceptable materials will be required
to be covered (with a tarp) and turned away from the facility. Wastes from outside of the
service area will be rejected.

Once passing the scales, the vehicles containing C&D wastes are routed to the working
face. Vehicles shall be selected for random screening a minimum of three times per
week. The selection of vehicles for screening might be based on unfamiliarity with the
vehicle/driver or based on the driver’s responses to interrogation about the load content.
The Operator shall use the Waste Screening Form (see Appendix 4A) to document the
waste screening activities. Documentation of three random waste screenings shall be
placed in the Operational Record (see Section 5.12).
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Selected vehicles shall be directed to an area of intermediate cover adjacent to the working
face where the vehicle will be unloaded, and the waste shall be carefully spread using
suitable equipment. An attendant trained to identify wastes that are unacceptable at the
landfill shall inspect the waste discharged at the screening site. If no unacceptable waste
is found, the load will be pushed to the working face and incorporated into the waste cell.

• If unacceptable wastes that are non-hazardous are found, the load will be
reloaded onto the delivery vehicle and directed to the Transfer Station.

• For unacceptable wastes that are hazardous, the Hazardous Waste
Contingency Plan outlined in Section 5.14 will be followed.

The hauler is responsible for removing unacceptable waste from the landfill property. The
rejection of the load shall be noted on the Waste Screening Form, along with the
identification of the driver and vehicle. A responsible party to the load generator or hauler
shall be notified that the load was rejected. The generator or hauler may be targeted for
more frequent waste screening and/or banished from delivering to the facility, depending
on the nature of the violation of the waste acceptance policy. If the violation is repetitive
or severe enough, State and/or County authorities may be notified.

7.3.2 Disposal of Rejected Wastes

Attempts will be made to inspect waste as soon as it arrives in order to identify the waste
hauler; ideally, the hauler can be stopped from leaving the site and the rejected materials
reloaded onto the delivery vehicle. Non-allowed materials that are found in the waste
during sorting or placement, i.e., after the delivery vehicle has left the site, shall be taken
to the on-site Transfer Station.

Small quantities of garbage (chiefly food containers) will inevitably wind up in the C&D
waste stream from job sites. These may be disposed with the C&D wastes providing the
materials are non-liquid and non-hazardous. If large quantities of garbage, “black bags”
or any prohibited wastes are detected, the Operator shall be responsible for removing these
materials and placing them into the Transfer Station at the earliest practical time.

7.3.3 C&D Disposal Procedures

Waste transportation vehicles will arrive at the working face at random intervals. There
may be many vehicles unloading waste at the same time, while other vehicles are waiting.
To maintain control over the unloading of waste, only a certain number of vehicles will be
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allowed on the working face at a time. The superintendent and/or equipment operator(s),
who will serve as ‘spotters’, will determine the actual number. This procedure will be used
to minimize the potential of unloading unacceptable waste and to control disposal activity.

Operations at the working face will be conducted in a manner that will promote the efficient
movement of vehicles to and from the working face, and to expedite the unloading of waste.
At no time during normal business hours will the working face be left unattended. Scale
house and field staff shall be in constant communication regarding incoming loads and the
movement of vehicles on the site, irrespective of facility vehicles or private vehicles. It is
the responsibility of the working face superintendent to know always where each vehicle
in the facility is located and what they are doing.

Portable signs with directional arrows and barricades will be used to direct traffic to the
correct unloading area. The approaches to the working face will be maintained such that
two or more vehicles may safely unload side by side. A vehicle turn-around area large
enough to enable vehicles to arrive and turn around safely with reasonable speed will be
provided adjacent to the unloading area. The vehicles will back to a vacant area near the
working face to unload. Upon completion of the unloading operation, the transportation
vehicles will immediately leave the working face. Personnel will direct traffic as necessary
to expedite safe movement of vehicles.

Waste unloading at the landfill will be controlled to prevent disposal in locations other than
those specified by site management. Such control will also be used to confine the working
face to a minimum width yet allow safe and efficient operations. The width and length of
the working face will be maintained as small as practical to control windblown waste,
preserve aesthetics, and minimize the amount of required periodic cover.

Normally, only one working face will be active on any given day, with all deposited waste
in other areas covered by either periodic or final cover, as appropriate. The procedures for
placement and compaction of solid waste include: unloading of vehicles, spreading of
waste into 10-foot lifts, and compaction on relatively flat slopes (i.e., 5H: IV max.) using
a minimum number of three full passes. Depending on the nature of the wastes and long-
term volume analysis of in-situ density, the waste placement geometry and compaction
procedures may require adjustment to optimize airspace.

7.3.4 Spreading and Compaction

The working face shall be restricted to the smallest possible area; ideally, the maximum
working face area with exposed waste shall be one-quarter to one-half acre. Wastes shall
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be compacted as densely as practical. Appropriate methods shall be employed to reduced
wind-blown debris including (but not limited to) the use of wind fences, screens, temporary
soil berms, and periodic cover. Any wind-blown debris shall be recovered and placed back
in the landfill and covered at the end of each working day.

7.3.5 Special Wastes: Asbestos Management

Any asbestos handling and disposal will follow specific NC DENR regulations with proper
shipping manifests and documentation of disposal. Asbestos shall arrive at the site in
vehicles that contain only the asbestos waste and only after advance notification by the
generator and if accompanied by a proper NC DMV transport manifest. Once the hauler
brings the asbestos to the landfill, operations personnel will direct the hauler to the
designated asbestos disposal area. Operations personnel will prepare the designated
disposal area by leveling a small area using a dozer or loader. Prior to disposal, the landfill
operators will stockpile cover soil near the designated asbestos disposal area. The volume
of soil stockpiled will be sufficient to cover the waste and to provide any berms, etc. to
maintain temporary separation from other landfill traffic.

Once placed in the prepared area, the asbestos waste will be covered with a minimum of
18 inches of daily cover soil placed in a single lift. The surface of the cover soil will be
compacted and graded using a tracked dozer or loader. The landfill compactor will be
prohibited from operating over asbestos disposal areas until at least 18 inches of cover are
in-place. The landfill staff shall record the location and elevation of the asbestos waste
once cover is in-place. Records of the disposal activity shall be entered into the Operating
Record. Once disposal and recording for asbestos waste is completed, the disposal area
may be covered with C&D waste. No further excavation into recorded asbestos disposal
areas will be permitted.

7.4 Cover Material

7.4.1 Periodic Cover

The working face of the CDLF shall be covered on a weekly basis, or sooner if the area
of exposed waste exceeds one-half acre in size. Periodic cover shall consist of a 6-inch
layer of earthen material that completely covers the waste to control vectors, fire, odors,
and blowing debris. Alternative periodic cover may be considered, subject to a
demonstration project with prior approval from the Division. Placement of periodic cover
shall be documented in the Operating Record (see Section 5.12) and on a copy of the
facility map.
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7.4.2 Interim Soil Cover

An interim soil cover (at least 24 inches in thickness) shall be placed on inactive slopes,
subject to the following conditions:

• Interior slopes adjacent to future expansion (such as a cell or phase boundary) no
later than 30 days following the last waste receipt, providing that further waste
disposal will occur within one year of the last waste receipt*

• Exterior slopes that have attained final grade are to be left for no more than 15
working days without temporary vegetation, until an area of no more than 10 acres
is ready to be closed simultaneously. **

*North Carolina Solid Waste Rule 15A NCAC 13B .0543 requires final cover to be placed
if the slope shall remain inactive for more than one year

**Typically, it is advantageous to close the final slopes in 2 to 3-acre increments, observing
the placement of erosion control benches; 10 acres is the regulatory maximum

Interim cover soils shall be vegetated in accordance with the Seeding Schedule presented
in the Facility Drawing EC5. Either temporary or permanent vegetation may be required
– and alternate ground cover may be considered – depending on the time duration of
inactivity. Placement of interim cover shall be documented in the Operating Record.

7.4.3 Final Cover

Exterior slopes shall be closed upon reaching final grades in increments throughout the
operation of the facility. Placement of final cover shall conform to the design and CQA
requirements presented in the Closure and Post-Closure Plan (Section 8.0) and shall be
documented in the Operating Record and on a copy of the facility map.

The permitted final cover consists of a minimum of 18 inches of compacted soil cover
(maximum 10-5 cm/sec permeability requirement), overlain by 18 inches of vegetation
support soil. In general, the final soil cover shall be spread in three uniform lifts (maximum
of 9 inches before compaction, 6 inches after compaction), and soils shall be compacted by
“tracking” with dozers or other equipment. North Carolina Solid Waste regulations require
a maximum permeability, achieved through proper material selection and compaction
criteria, confirmed by the testing program outlined in the CQA section of the Closure and
Post-Closure Plan.
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Sedimentation and Erosion Control Rule 15A NCAC 04B .0107, MANDATORY
STANDARDS FOR LAND-DISTURBING ACTIVITY, states as follows: “Pursuant to
G.S. 113A-57(3), provisions for a ground cover sufficient to restrain erosion must be
accomplished within 15 working days or 90 calendar days following completion of
construction or development, whichever period is shorter.” Prior to May 2013 the rule
required that all disturbed soils shall be stabilized within 20 days following completion of
the grading. The facility’s interpretation is that all slopes must be vegetated with a seed
mix that is suitable to climatic conditions (see construction plans) within 15 days. All
seeded areas should be provided with lime, fertilizer and straw mulch. An emulsified tack
may be required to prevent wind damage. Other stabilization treatments, e.g., curled wood
matting of synthetic slope stabilization blankets may be employed.

At the operator’s discretion, wood mulch may be spread evenly over the final surfaces – at
a maximum thickness of 2 inches – to help retain moisture and retard erosion while the
vegetation develops. By SWS definition this material is not recognized to provide nutrient
value but the partial decomposition of the wood mulch over time does introduce organic
content to the soils, which were typically derived from deep within the borrow pit.
Typically, the mulch takes about a year to break down and does benefit the effort of
establishing vegetation, as long as the mulch is not applied too thick. This allows the
operator some flexibility is establishing vegetation at optimum times. A nurse crop of
seasonal vegetation can be sown at the time the slopes are finished and a permanent crop
can be sown later, typically requiring manual sowing to prevent damaging the existing
vegetation. All protective measures must be maintained until permanent ground cover
is established and is sufficient to restrain erosion on the site.

If settlement occurs after the cover is placed, the cover shall be fortified with additional
soil. In the case of extreme settlement (unlikely), the old cover can be stripped and the
affected area built up with waste prior to replacing the cover. The sedimentation and
erosion control criteria governing the final closure of this facility are performance-based;
some trial and error may be required, but the goal is to protect the adjacent water bodies
and buffers throughout the operational and post-closure periods.

7.5 Survey for Compliance

7.5.1 Height Monitoring

The landfill staff will monitor landfill top and side slope elevations on a weekly basis or as
needed to ensure proper slope ratios, in accordance with the approved grading plan, and to
ensure the facility is not over-filled. This shall be accomplished by use of a surveyor’s
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level and a grade rod. When such elevations approach the grades shown on the Final Cover
Grading Plan, the final top-of-waste grades will be staked by a licensed surveyor to limit
over-placement of waste.

7.5.2 Annual Survey

The working face shall be surveyed on an annual basis to verify slope grades and to track
the fill progression. In the event of problems (slope stability, suspected over-filling), more
frequent surveys may be required at the request of the Division.

7.6 Contingency Plan

Refer to Section 5.14

7.7 Annual Reporting

Refer to Sections 5.12 and 5.13

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Table 7A
PROHIBITED WASTES IN THE CDLF UNIT**
(1) Containers such as tubes, drums, barrels, tanks, cans, and bottles unless they are
empty and perforated to ensure that no liquid, hazardous or municipal solid waste
is contained therein,
(2) Garbage as defined in G.S. 130A-290(a) (7),
(3) Hazardous waste as defined in G.S. 130A-290(a) (8), to also include hazardous
waste from conditionally exempt small quantity generators,
(4) Industrial solid waste unless a demonstration has been made and approved by
the Division that the landfill meets the requirements of Rule .0503(2) (d) (ii) (A),
(5) Liquid wastes,
(6) Medical waste as defined in G.S. 130A-290(a) (18),
(7) Municipal solid waste as defined in G.S. 130A-290(a) (18a),
(8) Polychlorinated biphenyls (PCB) wastes as defined in 40 CFR 761,
(9) Radioactive waste as defined in G.S. 104E-5(14),
(10) Septage as defined in G.S. 130A-290(a) (32),
(11) Sludge as defined in G.S. 130A-290(a) (34),
(12) Special wastes as defined in G.S. 130A-290(a) (40),
(13) White goods as defined in G.S. 130A-290(a) (44), and
(14) Yard trash as defined in G.S. 130A-290(a) (45),
(15) The following wastes cannot be received if separate from C&DLF waste:
• lamps or bulbs, e.g., halogen, incandescent, neon or fluorescent;
• lighting ballast or fixtures;
• thermostats and light switches;
• batteries, e.g., those from exit and emergency lights and smoke detectors;
• lead pipes;
• lead roof flashing;
• transformers;
• capacitors; and
• copper chrome arsenate (CCA) and creosote treated woods.
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(16) Waste accepted for disposal in a C&DLF unit must be readily identifiable as
C&D waste and must not have been shredded, pulverized, or processed to such an
extent that the composition of the original waste cannot be readily ascertained
except as specified in Subparagraph (17) of this Paragraph.
(17) C&D waste that has been shredded, pulverized or otherwise processed may be
accepted for disposal from a facility that has received a permit from an authorized
regulatory authority which specifies such activities are inspected by the authority,
and whose primary purpose is recycling and reuse of the C&D material. A waste
screening plan and waste acceptance plan must be made available to the Division
upon request.
(18) Waste that is generated outside the boundaries of a unit of local government
ordinance (i.e., areas not approved by County Commissioners).
**Reference: 15A NCAC 13B .0542

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8.1 Summary of Regulatory Requirements

8.1.1 Final Cap

The final cap design for all phases of the CDLF shall conform to the minimum
requirements of the Solid Waste Rules, i.e., the compacted soil barrier layer shall exhibit a
thickness of 18 inches and a field permeability of not more than 1.0 x 10-5 cm/sec. The
overlying vegetative support layer shall be 18 inches thick. Drawing E6 shows final
contours and Drawings EC1 – EC3 show final cover cross-section and details.

8.1.2 Construction Requirements

Final cap installation shall conform to the approved plans (see accompanying plan set),
inclusive of the approved Sedimentation and Erosion Control Plan. The CQA plan must
be followed (see Section 4.0) and all CQA documentation must be submitted to the
Division. Post-settlement surface slopes must not be flatter than 5% on the upper cap and
not steeper than 33% (3H:1V) on the side slopes. Per Rule 15 NCAC 13B .0543, a gas
venting system is required for the cap. A passive venting system will be specified, which
will consist of a perforated pipe in crushed stone-filled trench – installed just below the
final cap soil barrier layer – with a tentative minimum vent spacing of three vents per
acre. Drawing EC2 shows the gas vent system details.

8.1.3 Alternative Cap Design

Rule 15 NCAC 13B .0543 make a provision for an alternative cap design, to be used in
the event the permeability requirements for the compacted soil barrier layer cannot be met.
Experience indicates that on-site soils may not meet the required field permeability of not
more than 1.0 x 10-5 cm/sec, as supported by the laboratory data for the soils discussed in
Section 4.0. Tentative final closure plans have assumed that on-site soils will be used for
the compacted barrier layer – alternative cap designs may be researched and submitted for
Division approval at a future time. Plans and specifications shall be provided to the Solid
Waste Section for an alternative final cover design, if used, at least 60 days before any
closure or partial closure activities (see Section 8.1.5).

8.1.4 Division Notifications

The Operator shall notify the Division prior to beginning closure of any final closure
activities. The Operator shall place documentation in the Operating Record pertaining to
the closure, including the CQA requirements and location and date of cover placement.
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8.1.5 Required Closure Schedule

The Operator shall close the landfill in increments as various areas are brought to final
grade. The final cap shall be placed on such areas subject to the following:

• No later than 30 days following last receipt of waste;
• No later than 30 days following the date that an area of 10 acres or greater
is within 15 feet of final grades;
• No later than one year following the most recent receipt of waste if there is
remaining capacity.

Final closure activities shall be completed within 180 days following commencement of
the closure, unless the Division grants extensions. Upon completion of closure activities
for each area (or unit) the Owner shall notify the Division in writing with a certification
by the Engineer that the closure has been completed in accordance with the approved
closure plan and that said documentation has been placed in the operating record.

8.1.6 Recordation

The Owner shall record on the title deed to the subject property that a CDLF has been
operated on the property and file said documentation with the Register of Deeds. Said
recordation shall include a notation that the future use of the property is restricted under
the provision of the approved closure plan.

8.2 Closure Plan

The following is a tentative closure plan for Phases 1 through 4 of the CDLF, based on the
prescribed operational sequence and anticipated conditions at the time of closure.

8.2.1 Final Cap Installation

8.2.1.1 Final Elevations – Final elevation of the landfill shall not exceed those depicted
on Drawing E6 when it is closed, subject to approval of this closure plan. Drawing E5
shows the Phase 3 intermediate cover contours. The elevations shown include the final
cover. A periodic topographic survey shall be performed to verify elevations.

8.2.1.2 Final Slope Ratios – Side slope ratios shall not exceed 3H:1V and upper surfaces
shall have a 5 to 10 percent slope. The cover shall be graded to promote positive drainage.
Topographic surveys shall be performed to verify slope ratios.
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8.2.1.3 Final Cover Section – The terms “final cap” and “final cover” both apply. The
final cover will subscribe to the minimum regulatory requirement for C&D landfills:

• An 18-inch thick compacted soil barrier layer (CSB), i.e., the “infiltration
layer,” with a hydraulic conductivity not exceeding 1 x 10-5 cm/sec,
overlain by
• An 18-inch thick “topsoil” or vegetated surface layer (VSL),
i.e., the “erosion layer.”

8.2.1.4 Final Cover Installation – All soils shall be graded to provide positive drainage
away from the landfill area and compacted to meet applicable permeability requirements
(see Section 4.0). Suitable materials for final cover soil shall meet the requirements
defined above. Care shall be taken to exclude rocks and debris that would hinder
compaction efforts. The surface will then be seeded in order to establish vegetation.

Test Pad – Whereas the lab data indicate that the required permeability is
attainable, the ability to compact the materials in the field to achieve the required
strength and permeability values shall be verified with a field trial involving a test
pad, to be sampled with drive tubes and laboratory density and/or permeability
testing, prior to full-scale construction. The materials, equipment, and testing
procedures should be representative of the anticipated actual final cover
construction. The test pad may be strategically located such that the test pad may
be incorporated into the final cover.

Compacted Barrier – Materials shall be blended to a uniform consistency and
placed in three loose lifts no thicker than 9 inches and compacted by tamping,
rolling, or other suitable method to a thickness of 6 inches – the targeted minimum
thickness of the soil barrier is 18 inches. The cover shall be constructed in
sufficiently small areas that can be completed in a single day (to avoid desiccation,
erosion, or other damage), but large enough to allow ample time for testing without
hindering production. The Contractor shall take care not to over-roll the cover such
that the underlying waste materials would pump or rut, causing the overlying soil
layers to crack – adequate subgrade compaction within the upper 36 inches of waste
materials and/or the intermediate cover soil underlying the final cover is critical.
All final cover soils shall be thoroughly compacted through the full depth to achieve
the required maximum permeability required by Division regulations of 1.0 x 10-5
cm/sec, based on site-specific test criteria (see below). Compaction moisture
control is essential for achieving adequate strength and permeability.
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Vegetated Surface Layer – Also known as “vegetation support layer” or simply
“topsoil.” Materials shall be blended and placed in two loose lifts no thicker than
12 inches and lightly compacted by tamping, rolling, or other suitable method – the
targeted minimum layer thickness is 18 inches. A relatively high organic content
is desirable, thus decayed wood mulch, compost or WWTP sludge (with advance
permission from the Division) may be incorporated to provide nutrient value and
enhanced field capacity. These soils are not subject to a permeability requirement
(no testing). Care should be taken to not over-compact the soil such that vegetation
would be hindered. Following placement and inspection of the surface layer, seed
bed preparation, seeding, and mulching should follow immediately. The work
should be scheduled to optimize weather conditions, if possible.

Inspection and Testing – Soils for the barrier layer are subject to the testing
schedule outlined in the Construction Quality Assurance plan (see Section 4.0).
The proposed testing program includes a minimum of one permeability test per lift
per acre and four nuclear density gauge tests per lift per acre, to verify compaction
of the compacted barrier layer. The moisture-density-permeability relationship of
the materials shall be established by the laboratory testing. The Contractor shall
proof roll the intermediate soil cover to assure that these materials will support the
final cover. If necessary, the Engineer will make recommendations for repairs.

8.2.1.5 Final Cover Vegetation – Seedbed preparation, seeding, and mulching shall be
performed in accordance with specifications in the Construction Plans (see Drawing EC5),
unless approved otherwise by the Engineer. In areas to be seeded, fertilizer and lime
typically should be distributed uniformly at a rate of 1,000 pounds per acre for fertilizer
and 2,000 pounds per acre for lime and incorporated into the soil to a depth of at least 3
inches by disking and harrowing. The incorporation of the fertilizer and lime may be a part
of the cover placement operation specified above. Seed distribution by means of a seed
drill or hydro seeder (some are equipped to distribute lime and fertilizer at the same time)
will be acceptable. Please note that the seeding schedule varies by season.

All vegetated surfaces shall be mulched with wheat straw and a bituminous tack. Areas
identified as prone to erosion may be secured with curled-wood excelsior, installed and
pinned in accordance with the manufacturer’s recommendations. Certain perimeter
channels will require excelsior or turf-reinforcement mat (TRM), as specified in the
Channel Schedule. Alternative erosion control products may be substituted with the project
engineer’s prior consent. All rolled erosion control materials should be installed according
to the generalized layout and staking plan found in the Construction Plans or the
manufacturer’s recommendations.
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Irrigation for landfill covers is not a typical procedure, but consideration of temporary
irrigation may be considered if dry weather conditions prevail during or after the planting.
Care should be taken not to over-irrigate to prevent erosion. Collected storm water will be
suitable for irrigation water. Maintenance of the final cover vegetation, described in the
Post-Closure Plan (see below), is critical to the overall performance of the landfill cover
system.

8.2.1.6 Documentation – The Owner shall complete an “as-built” survey to depict final
elevations of each final cover layer (the top of the intermediate cover layer, top of the
compacted soil barrier, and top of the vegetated soil layer) along with construction
narrative to document any problems, amendments or deviations from the plan drawings.
Records of all testing, including maps with test locations, shall be prepared by the third-
party CQA testing firm. All materials pertaining to the closure shall be placed in the
Operational Record for the facility. Whereas the closure will be incremental, special
attention shall be given to keeping the closure records separate from the normal operational
records.

8.2.2 Maximum Area/Volume Subject to Closure

The largest anticipated area that will require final closure at any one time within the life of
the landfill – including all of Phases 1, 2, 3 and 4 – is 25.5 acres. Intermediate cover shall
be used on areas that have achieved final elevations until the final cover is installed. The
volume of Phases 1 – 4 is 2,240,000 cubic yards (Section 1.3).

8.2.3 Closure Schedule

Refer to the requirements outlined in Section 8.1.5 (above).

8.2.4 Closure Cost Estimate

The following cost estimate is considered suitable for the Financial Assurance
requirements (see Section 10.0). The Owner intends to build all of Phase 3, which adds
7.6 acres to the previously permitted 17.9-acre footprint, for 25.5 acres permitted. No area
has a certified final cover in place.

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Table 8A.1
ESTIMATED FINAL CLOSURE COSTS FOR PHASES 1 – 4 (2018 dollars) 1, 5

VSL (topsoil)2 – 25.5 ac 61,710 c.y. @ $4.50 / cubic yard $ 277,695
CSB (barrier)2 – 25.5 ac 70,967 c.y. @ $11 / cubic yard $ 780,637
Establish Vegetation 25.5 acres @ $1,965 per acre $ 50,108
Storm Water Piping 3 530 LF @ $35.00 / LF $ 18,550
Erosion Control Stone 3 27 tons @ $40.00 / ton $ 1,080
Cap Gas Vents (3/acre) 77 @ $100 ea. $ 7,700
Testing and Surveying 4 Estimated 20 percent of above $ 227,154
Contingency Estimated 15 percent of above $ 204,439
Total Construction Cost (if contracted out) $ 1,567,363

Notes:
1 Intended to represent likely third-party construction costs (hired contractor, not the Owner/Operator), based on
knowledge of local construction costs for similar projects – these estimates provided to meet NC DEQ financial
assurance requirements; actual costs may be lower for construction by the Owner/Operator; actual final closure
work will be performed incrementally, spreading out the costs over the life of the project.

2 Includes soil work for regulatory requirements of 15A NCAC 13B .0543, i.e., a minimum of 18 inches of
compacted soil barrier (max. permeability of 1 x 10-5 cm/sec) and 18 inches of topsoil (total soil thickness is
36 inches). For the compacted soil barrier, use a shrinkage factor of 15%; costs include surface preparation,
soil procurement and transport costs, soil placement and compaction, machine/equipment costs, fuel costs.

3 Conservative estimates are based on similar project history; includes materials and installation.

4 Includes Construction document and bidding, construction administrative fee, CQA field monitoring and lab
testing, CQA reporting and certification, final survey for as-built drawings, recordation/notation fee.

5 Inflation has been adjusted for using the inflation rates listed on Table 8A.2. For example, the VSL (topsoil)
had a unit rate of $4.00/cy in 2012. In 2018, this unit rate is now $4.50/cy which is calculated by:

$4/cy * (1.018) * (1.015) * (1.014) * (1.010) * (1.013) * (1.018).

The inflation multiplier applies to closure, post-closure, current corrective action, and potential assessment of
corrective action (PACA) per the above example.

Table 8A.2
ANNUAL INFLATION MULTIPLIERS

2011 year - 1.013 multiplier
2012 year - 1.021 multiplier
2013 year - 1.018 multiplier
2014 year - 1.015 multiplier
2015 year - 1.014 multiplier
2016 year - 1.010 multiplier
2017 year - 1.013 multiplier
2018 year - 1.018 multiplier
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8.3 Post-Closure Plan

8.3.1 Monitoring and Maintenance

8.3.1.1 Term of Post-Closure Care – The facility shall conduct post-closure care for a
minimum of 30 years after final closure of the landfill, unless justification is provided for
a reduced post-closure care period. The post-closure care period may be extended by the
Division if necessary to protect human health and the environment.

8.3.1.2 Maintenance of Closure Systems – Inspections of the final cover systems and
sediment and erosion control (S&EC) measures shall be conducted quarterly. Maintenance
will be provided during post-closure care as needed to protect the integrity and
effectiveness of the final cover. The cover will be repaired as necessary to correct the
effects of settlement, subsidence, erosion, or other events. Refer to the Post Closure
Monitoring and Maintenance Schedule (below).

8.3.1.3 Landfill Gas Monitoring – Quarterly landfill gas (LFG) monitoring will be
conducted during the operational period and for at least 30 years following closure. Post
closure monitoring will be a continuation of the operational monitoring program (see
Section 9.4), subject to amendment as might be required by the Solid Waste Section (SWS)
resulting from rule changes or conditions indicated by the data. The primary concern is
the potential for migration of explosive gas (chiefly methane), although the potential is
relatively low for this facility.

The regulations require that LFG levels remain below 100 percent of the lower Explosive
Level (LEL) – approximately 5 percent methane by volume in air or soil gas – at the facility
boundary and below 25 percent of the LEL within on-site structures. The regulation also
requires that hydrogen sulfide concentrations are maintained below the chronic 24-hour
acceptable ambient level of 0.12 mg/m3 based on nasal toxicity in animal studies
(Recommendations for Twenty North Carolina Toxic Air Pollutants 2015). A
monitoring plan prepared in accordance with the current SWS guidance document can be
found in Appendix 6. The plan includes monitoring requirements and procedures, as well
as contingency activities to be implemented if regulatory thresholds are exceeded.

Locations for the initial detection monitoring of methane were based on site conditions
(physical barriers to gas migration, i.e. surface streams), the presence of man-made
conduits for potential gas migration (i.e., pipelines), and experience with numerous gas
monitoring and remediation programs at other facilities. The bar-hole punch tests are
intended to provide early indication of gas migration outside the waste unit boundary,
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accomplished by monitoring the backfill zones of the pipelines and other locations,
including the up-gradient soils where the porous saprolite and groundwater are deep. The
original LFG monitoring locations are shown on Drawing M-1.

If the data so warrant, future consideration will be given to permanent gas sampling
probes, using the bar hole punch data as a guide for selecting the probe locations.

8.3.1.4 Ground Water Monitoring – Groundwater monitoring will be conducted under
the current version of the approved Sampling and Analysis Plan (see Appendix 5). This
plan will be reviewed periodically and may change in the future. Approximately one year
prior to the landfill reaching permitted capacity, the facility will submit post-closure
monitoring and maintenance schedules, specific to the ground water monitoring.
Procedures, methods, and frequencies will be included in this plan. This future plan, and
all subsequent amendments, will be incorporated by reference to this document.

8.3.1.5 Record Keeping – During the post closure period, maintenance and inspection
records, i.e., a Post Closure Record, shall be kept as a continuation of the Operating
Record that was kept during the operational period. The Post Closure Record shall include
future inspection and engineering reports, as well as documentation of all routine and non-
routine maintenance and/or amendments. The Post Closure Record shall include the
ground water and gas monitoring records collected for the facility.

8.3.1.6 Certification of Completion – At the end of the post-closure care period the
facility manager shall contact the Division to schedule an inspection. The facility manager
shall make the Post Closure Record available for inspection. A certification that the post-
closure plan has been completed, signed by a North Carolina registered professional
engineer, shall be placed in the operating/post closure record. C&D Landfill, Inc. shall
maintain these records indefinitely.
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Table 8B
POST-CLOSURE MONITORING AND MAINTENANCE SCHEDULE

Activity Frequency
Yrs. 1 - 5
Frequency
Yrs. 6-15
Frequency
Yrs. 16-30
General - Inspect access gates, locks, fences, signs,
site security
Quarterly Quarterly Quarterly
Maintain access roads, monitoring well access As needed As needed As needed
Final Cover Systems/Stability - Inspect cap and
slope cover for erosion, sloughing, bare spots in
vegetation, make corrections as needed (1)
Quarterly Semi-
Annually
Annually
Storm Water/Erosion Control Systems - Inspect
drainage swales and sediment basin for erosion,
excess sedimentation (1)
Quarterly Semi-
Annually
Annually
Mow cover vegetation and remove thatch Semi-Annually Annually None (2)
Inspect vegetation cover and remove trees Annually Annually Annually
Landfill Gas Monitoring Quarterly (3) Quarterly (3) Quarterly (3)
Ground Water Monitoring System - Check well
head security, visibility
Semi-Annually Semi-
Annually
Semi-
Annually
Ground Water Monitoring (4) Semi-Annually Semi-
Annually
Semi-
Annually

Notes:
1. Inspect after every major storm event, i.e., 25-year 24-hour design storm

2. Dependent on vegetation type, periodic mowing may be required

3. The Solid Waste Section may be petitioned for discontinuation of gas monitoring if no detections occur in gas
sampling locations or on-site buildings

4. See current Ground Water Sampling and Analysis Plan
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8.3.2 Responsible Party Contact
Mr. R.E. ‘Gene’ Petty, Sr. – Owner
Mr. Ronnie E. Petty, III – Operator
A-1 Sandrock, Inc.
2091 Bishop Road
Greensboro, NC 27406 Tel. [phone]
8.3.3 Planned Uses of Property
Currently, there is no planned use for the landfill area following closure. The closed facility
will be seeded with grass to prevent erosion. Any post-closure uses of the property
considered in the future will not disturb the integrity of the final cover or the function of
the monitoring systems unless necessary (and to be accompanied by repairs or upgrades).
Future uses shall not increase the potential threat to human health and the environment.
8.3.4 Post-Closure Cost Estimate
The following cost estimate is considered representative of post-closure care costs for the
Financial Assurance (see Section 10.0). This calculation includes all of Phase 1, 2, 3 and
4, totaling 25.5 acres.

Table 8C
ESTIMATED POST-CLOSURE COSTS FOR PHASES 1 – 4 (2018 dollars)

Annual Events Units Unit
Cost
Cost/
Event Annual Costs
Reseeding/mulching and erosion repair
(Assume 5% of 25.5 ac., once per year)
1.28 ac. $1,600 $2,048.00 $2,048.00
Mow final cap (twice per year) 25.5 ac. $25 $637.50 $1,275.00
Ground Water (semi-annual, 6 wells) * 6 ea. $400 $2400.00 $4,800.00
Surface Water (semi-annual, 4 locations) * 4 ea. $350 $1400.00 $2,800.00
Water quality analysis and reporting 2 ea. $2250 $4500.00 $4,500.00
Landfill Gas Monitoring (quarterly)** 1 ea. $840 $840.00 $3,360.00
Engineering inspection (annual basis) 1 ea. $1,500 $1,500.00 $1,500.00
Maintain storm water conveyances 1 ea. $1,000 $1,000.00 $1,000.00
Maintain access roads, gates, buildings 1 ea. $1,000 $1,000.00 $1,000.00
*Appendix I Detection Monitoring (Section 9.0) Total Estimated Annual Cost $22,283.00
**Monitor 12 permanent wells, 8 hr @ $80 = $640 + $200 equipment rental = $840 per quarter

30 years x $22,283 = $668,490 (See Section 10)
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9.1 Summary of Regulatory Requirements

Detection phase monitoring for ground water and surface water is required of all C&D
landfills. Typical monitoring programs include one or more up gradient background wells
and several down-gradient (or cross gradient) compliance wells, along with several
strategically placed surface water sampling locations (with up gradient and down gradient
coverage). Well placement is based on the site’s hydraulic and topographic characteristics.
Compliance wells are located at a regulatory “review boundary” which are approximately
half the distance to the “compliance boundary,” established 50 feet inside the facility
boundary or approximately 150 feet from the waste boundary at a C&D landfill.

Detection phase monitoring for all landfills includes semi-annual sampling and analysis
for ensuring compliance with North Carolina ground water standards, i.e., 15A NCAC 2L
.0300 (the “2L rules”). The detection phase sampling list includes organic constituents on
the Appendix 1 list2 (i.e., volatiles and semi-volatiles that are analyzed by US-EPA Method
8260 and the eight RCRA metals), key indicator parameters (measured in the field), and
several additional constituents (mercury, manganese, sulfate, iron, alkalinity, and total
dissolved solids). Assuming no detection of ground water constituents that exceed a 2L
standard, the term of detection phase monitoring runs for the operational life of the facility
plus the post-closure period (minimum of 30 years beyond closure). Should one or more
detected constituents exceed a 2L standard, the facility must undergo an assessment
monitoring program to determine the source, extent, and rate of contaminant migration,
plus an evaluation of potential human receptors and/or other environmental impacts.

The Groundwater Sampling and Analysis Plan (discussed below, see Appendix 5), is
the definitive document governing detection and assessment monitoring programs, with
respect to sampling procedures and strategic placement of monitoring wells. This narrative
describes the monitoring program from a regulatory compliance standpoint.

9.2 Ground Water Monitoring

The following discusses the rationale behind planned amendments to the detection phase
monitoring program for the C&D landfill, reflected in the Groundwater Sampling and
Analysis Plan (Appendix 5). As of this writing, recent regulatory emphasis has been
placed on metals concentrations at CDLF’s, which has required this facility to enter an
assessment program. A description of the assessment within the SAP (Appendix 5) is
beyond the scope of this report, except to acknowledge the assessment is in progress.

2 40 CFR Part 258
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9.2.1 Monitoring System Requirements

The monitoring system must provide effective monitoring of the site, focusing on the
“uppermost aquifer.” Site studies have indicated a radial ground water flow pattern toward
the west, southwest, and northwest, reflecting surface topography along a pronounced
ridge, surrounded on three sides by surface streams. The predominant groundwater flow
direction is westward toward Hickory Creek. A two-aquifer system characterized as
medium dense to very dense sandy saprolite (Unit 1) transitions with depth to bedrock
(Unit 2). The transition zone is variably thick and typically is very dense, called “partially
weathered rock” in local engineering parlance. Upper reaches of the transition zone are
porous; deeper reaches exhibit discreet fractures and partial confinement, where water
levels in sealed piezometers are typically observed higher than the actual water bearing
zone. The density varies both vertically and laterally, with isolated rock-like zones and
softer layers throughout. The transition zone has been identified as the primary water
bearing zone and serves as the uppermost aquifer due to its nearly ubiquitous presence.

Wells screened within the lower portion of Unit 1 (in the transition zone) have a high
probability of intersecting ground water flow zones for effective monitoring of the facility.
However, many of the original piezometers completed just above “auger refusal” were dry
or did not produce sufficient yield for adequate purging and sampling. Advancing the
borings below “auger refusal” with rotary coring techniques typically encountered low
RQD values (indicative of a high degree of weathering) within the upper 5 feet of the cores.
Thus, it can be concluded the transition zone (the “uppermost” aquifer) extends below
auger refusal, and well screens may need to be constructed across the “auger refusal”
imaginary boundary to consistently produce enough water for sampling. This places the
well screens typically beneath the static water levels. Otherwise, the wells are prone to
high turbidity and low yield. This characteristic is prevalent in the higher elevations of the
site, where rock was encountered at typically shallower depths. Within the lower
elevations, the aquifer exhibits more conventional, unconfined porous flow behavior.

The site studies indicate the streams that surround the site serve as the discharge points for
a relatively confined, closed-loop aquifer system that is essentially defined by the streams.
Unit 1 and the transition zone exhibit higher porosity than Unit 2, and with on-site
discharge features, the movement of groundwater is limited to the relatively shallow depths
of the saprolite. The radial flow pattern and distinct topographic features – reflective of
regional jointing – makes the selection of monitoring well sites and screen depths relatively
straightforward. With the streams as on-site discharge points, the ground water flow
regime is well defined, thus the monitoring system can be effective with fewer wells.
Drawing M1 depicts well and stream locations appropriate for monitoring Phases 1 – 4.
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9.2.2 Background Water Quality

Low concentrations of metals have been detected at the background well and in baseline
sampling of the compliance wells. No concentrations of inorganic constituents that affect
the ability to monitor the site were detected.

9.2.3 Point of Compliance Water Quality

The 15A NCAC 2L ground water standards are applicable for the compliance boundary,
tempered with background water quality data. For constituents that do not have
promulgated 2L standards, the Division will consider alternative limits for compliance.

9.2.4 Sampling and Analysis Procedures

Industry accepted protocols (consistent with Division guidelines)3 are discussed in the
standalone document, Sampling and Analysis Plan presented in Appendix 5.

9.2.5 Detection-phase Monitoring Parameters

The sampling parameters consist of the EPA Appendix I list of organic constituents and
metals, modified by 15A NCAC 13B .0544. The prescribed sampling list includes CDLF-
specific constituents and field parameters required by NC DEQ (see Appendix 5).

9.2.6 Sampling Frequency

The sampling frequency shall be semi-annually.

9.2.7 Water Level Elevations

Water levels shall be measured and recorded by referencing the top-of-casing at each
monitoring well during each sampling event.

9.2.8 Reporting

Data analysis and reporting, consistent with Division requirements, are described in the
Sampling and Analysis Plan (see Appendix 5).

3 NC DENR Division of Waste Management Guidance Document, Ground Water Sampling for
Construction and Demolition, Closed or Industrial Landfills,
http://www.wastenotnc.org/swhome/enviro_monitoring.asp
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9.2.9 Source Demonstration

In the event of the detection of a ground water constituent that exceeds a 2L standard, an
evaluation may be made in accordance with Division policy to determine the source, e.g.,
sampling error, laboratory contamination, extenuating circumstances (improper repairs to
a well or incidental spill near a well). Typically, such evaluations are accompanied by re-
sampling and, if appropriate, correction of conditions that may have led to the detection.
If such demonstrations cannot be made, the landfill might be considered as the source.

9.2.10 Monitoring Well Design

Wells shall be (and currently are) designed in accordance with 15A NCAC 2C.

9.2.11 Monitoring Well Layout

The layout takes into consideration the topographic features, saprolite thickness,
groundwater depths, regional flow conditions and access within the generally hilly terrain.

9.2.12 Alternative Monitoring Systems

None are proposed at present.

9.2.13 Assessment Monitoring

Requirements of assessment monitoring, if required, are outlined in Rule 15A NCAC 13B
.0545. Recent attention to metals concentrations by the regulatory community has forced
this Facility into an assessment monitoring program. This requirement is triggered in part
by the lowering of detection limits and standards for certain constituents and statistical
analysis of previously acquired data sets. This short-term evaluation involves a more
extensive list of parameters based on the Appendix II list with a handful of CDLF-specific
constituents required by NC DEQ. Pending the results of the next few sampling events, it
is likely the Facility will return to detection monitoring.

In response to the requirement, a facility-specific monitoring plan has been prepared and
approved by the Division. Changes to the sampling and analysis protocols to accommodate
the requirements of the assessment are covered in Appendix 5, some of which will become
permanent. For instance, based on early data evaluation the influence of turbidity in the
groundwater samples has been recognized. Thus a permanent change to the monitoring
program for this Facility will be implementation of “low-flow” sampling techniques.
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9.3 Surface Water Monitoring

Surface water monitoring focuses on the streams shown to be shallow ground water
discharge features to the north, west, and south of the CDLF footprint. Upstream
monitoring on these water bodies, which converge at the site margins, and monitoring of
the larger stream at the point it leaves the property provides effective monitoring of the
Facility. The surface water sampling locations are shown on Drawing M1. North Carolina
2L ground water standards apply. A separate storm water sampling program focuses on
turbidity and sediment, with sampling conducted under the purview of the NC DEQ
Division of Water Quality and in accordance with a NPDES General Storm Water Permit.

9.4 Landfill Gas Monitoring and Control Plan

A landfill gas (LFG) monitoring plan was approved with the original permitting and has
been conducted since the facility opened, with no known detects within compliance zones.
The Solid Waste Section published the document, “Landfill Gas Monitoring Guidance,” in
November 2010. A standalone LFG monitoring plan prepared in accordance with the
guidance document is presented in Appendix 6. One significant change upcoming will be
the installation of permanent LFG monitoring wells, replacing the soil-gas probes.

9.5 Adherence to Waste Acceptance Criteria

Monitoring of the waste intake is addressed in the Operations Plan (see Section 5.0). The
plan calls for routine waste screening and record keeping with respect to waste types,
sources, and haulers. Maintaining strict adherence to the waste acceptance criteria is the
sure way to maintain compliance with ground water quality criteria.

9.6 Plan Preparation and Certification

This monitoring plan for the C&D Landfill, Inc., disposal units has been prepared by, or
under the responsible charge of, one or more North Carolina Licensed Geologists or
Professional Engineers. The individual signature and seal below attests to compliance with
this rule requirement.

Signed _____________________
Printed G. David Garrett
Date January 15, 2019
Not valid unless this document bears the seal of the above-named licensed professional.
10.0 FINANCIAL ASSURANCE
(15A NCAC 13B .0546)

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Permit 4117-CDLF-2008 Facility Plan Update Page 97
15A NCAC 13B .0546 requires that Owners/Operators demonstrate financial assurance
for closure and post-closure activities. Typically, for local government-owned facilities,
said demonstration is based on a local government test. For private facilities, the posting
of a performance bond or insurance policy is typically acceptable to the Division.

Cost estimates for closure and post-closure of CDLF Phases 1 – 4 are presented in Sections
8.2.4 and 8.3.4, respectively. The following is a detailed analysis of the closure and post
closure costs, projected over the anticipated life of the landfill and 30 years of post-closure
care. The Financial Assurance obligation should be recalculated for future years to account
for inflation using annual multipliers furnished by NC DEQ.

The bond requirement is for the whole landfill that has a Permit to Operate – the liabilities
both increase and decrease with time as phases are opened and others are closed. Thus, the
amount of the post-closure instrument should be adjusted on an annual basis, consistent
with Division policy. Acceptable financial assurance instruments include performance
bonds, insurance policies, cash deposits and irrevocable letters of credit.

Table 10
SUMMARY OF CLOSURE AND POST-CLOSURE COSTS (2018 dollars)

1. Final Closure Construction (see Table 8A) $1,567,363

2. Projected Post-Closure Costs (see Table 8C) * $ 668,490

TOTAL CLOSURE/POST-CLOSURE COST $2,235,853

3. PACA** $1,128,666

TOTAL REQUIRED FINANCIAL ASSURANCE $3,364,519

Per Division rules, Owners/Operators must furnish an acceptable financial assurance
instrument (e.g., performance bond, irrevocable letter of credit, insurance policy, other
fiduciary instrument) within 30 days of notification of approval.

*Assumes 30 years
** Potential Assessment and Corrective Action (PACA), a separate bond required by statutory changes ca.
2008, revised ca. 2010. The minimum bond amount is $1M, subject to annual inflation multiplier (see Table
8A.2).
11.0 CERTIFICATION
A-1 Sandrock CDLF and Processing Facility Phase 3 PTC 1/15/2019
Permit 4117-CDLF-2008 Facility Plan Update Page 98
This engineering plan for the A-1 Sandrock, Inc., C&D Landfill Phases 1 – 4 disposal unit
has been prepared by, or under the responsible charge of, a North Carolina Licensed
Professional Engineer to meet the requirements of 15A NCAC 13B .0539. The individual
signature and seal below attests to compliance with this rule requirement.

Signed _____________________

Printed G. David Garrett

Date January 15, 2019

Not valid unless this document bears the seal of the above-named licensed professional.