4116_WI_HighPointCDLF_comment_Phase3A_PTC_FID1319798_20190422

1
Chao, Ming-tai
To:Mike Brinchek
Cc:Stacey Smith; David Pepper; Bryan Wuester; Seth Heath; Homewood, Sue; Stanley,
Sherri; Drummond, Jaclynne; Kirchner, Chuck
Subject:WI High Point C&D Landfill, Phase 3A construction, Permit # 41-16
Attachments: WI High Point C&DLF, Permit #4116-CDLF-2012
Hi Mike:

FID
Thanks to inform the Solid Waste Section (SWS) the progress of approval of wetlands impacts and mitigation
measures due to the construction of Phase 3A at WI Hight Point C&DLF, Permit No. 4116-CDLF-2012. After
reviewing the forwarded document (401 certification) and a set of construction drawings, the SWS would like
to make the following comments/requests for additional documents for the Phase 3A project.
1. Please provide a copy of the Section 404/US Army Corps of Engineers Permit to Discharge Fill, Permit
No. SAW-2014-01568 dated November 10, 2016 (Reference No. 5 on Drawing No. S1/Sheet No. 2).

2. On Drawing No. S1/Sheet No. 2, an unknown length of underdrain, connecting Wetlands No. 2 inside
Phase 3A to the drainage features inside the future Phase 3B is proposed. This section of underdrain is
new addition to the approved Permit To Construct Application, WI High Point C&D Landfill – Phase 3
dated May 2016 and approved on January 9, 2017 (DIN 27230). Therefore, please provide the
following information, construction specification, and associated drawings, as needed:
a. The detailed hydraulic design of this proposed underdrain should be provided to the revised
Engineering Plan.
b. A set of drawing (a plan view with stations covering the entire planned underdrain and the
profile/cross-section at each station) should show the flow gradient, dimensions of each component
of the underdrain, long-term seasonal groundwater elevation/ base rock stratum, and other pertinent
information concluded from the requested hydraulic design.
c. The Technical Specifications should be revised accordingly (Referring Drawing Nos. 3 & 5/Sheet
Nos. S2 & EC1).
i. The soil testing of the NCDOT # 57 stone – gradation and hydraulic conductivity which must
be consistent with those used in underdrain hydraulic design. Testing method and frequency for
each test parameter should be described in the specification.
ii. Please specify the fill material that is placed above and below GCL.
iii. Please specify the geotextile (Type GT-S).
iv. The as-built survey and submittal requirement of the underdrain.

3. The surface water monitoring plan must be revised by adding at least a monitoring point, immediately
adjacent to the daylight (the exit end) of the underdrain to detect if any contaminant is releasing to the
water features downstream of the landfill Phase 3A due to the waste operations. Jackie might have
additional request on this surface water monitoring requirement.
Above-mentioned requests/comments are additional request to those in 04/11/2019 email (see attachment) to
the modification to the PTC-Phase 3 Application which is scheduled for submittal on April 24, 2019 according
to the Phase 3 Pre-construction meeting minutes. Please contact me if you have any question of the requested
documents. Thanks.

2

From: Mike Brinchek <[e-mail]>
Sent: Monday, April 22, 2019 11:10 AM
To: Homewood, Sue <[e-mail]>
Cc: [e-mail]; Stacey Smith <[e-mail]>; Chao, Ming-tai
<[e-mail]>; David Pepper <[e-mail]>; Bryan Wuester
<[e-mail]>; Seth Heath <[e-mail]>
Subject: [External] WI High Point C&D Landfill

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]

Sue,

As you discussed with Phil May earlier, attached are the Construction Drawings for Phase 3A of the WI High Point C&D
Landfill. S+G is submitting the attached drawings to satisfy Condition 5 of the August 5, 2016 Approval of Individual 401
Water Quality Certification with Additional Conditions (also attached). We request that you review the attached
construction drawings and provide a response to us noting that the conditions of the August 5, 2016 correspondence
have been met and that no further action is required, prior to us beginning construction, which is scheduled for May 6,
2019.

Should you have any questions or need any additional information, please contact me at your earliest convenience.

Regards,

Mike

W. Michael Brinchek, PE
Senior Project Manager

SMITH + GARDNER

14 N. Boylan Avenue
Raleigh, NC 27603

P [phone], Ext. 128
F [phone]
C [phone]

Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]
From:Chao, Ming-tai
To:[e-mail]
Cc:Kirchner, Chuck; Drummond, Jaclynne; Stanley, Sherri; [e-mail]; David Pepper
Subject:WI High Point C&DLF, Permit #4116-CDLF-2012
Date:Thursday, April 11, 2019 10:29:06 AM
Hi Mike:
The Permit to Construct (PTC) for Waste Industrious High Point C&DLF – Phase 3 (DIN26907) expired per Permit Condition No. 7, Part I Attachment 2 of the PTC, which was issued
on January 09, 2017. The Solid Waste Section (SWS) have previously contacted you severaltimes about permit status and understood the beginning of Phase 3 construction will be in May
2019. The Smith Gardner, Inc., on behalf of the landfill permit holder, should submit anofficial request for an approval of the PTC - Phase 3 extension by this Friday, April 12, 2019.
So the SWS may approve the extension of PTC - Phase 3 prior to the scheduled pre-construction meeting on April 17, 2019.
Additionally, according to the phone conversations this Monday, Waste Industrious High
Point Landfill, LLC (the landfill permit holder) plans to change the construction sequence ofPhase 3. Instead of construction the whole phase at one time, the Phase 3 will be constructed
by two sub-phases –North Portion and South Portion at two different time. Construction of theNorth Portion will start in May 2019, and there is no definite time for constructing Southern
Portion at this moment. To assist Smith Gardner, Inc., on behalf of the permit holder, tosubmit the SWS the proper documents for construction and operation of the planned Phase 3
of the C&DLF, the SWS suggests Smith Gardner, Inc. to revise/update the PTC Application –Phase 3 (DIN 27230 & 27231) to reflect the latest planning/decision made by the permit
holder. Below are the plans in the application, but no limited to, that may be subject tomodify/update/revise:
1. Facility Plan – Phase 3 will be divided into two sub-phases; therefore, the gross capacity
and waste footprint of each sub-phase should be described / tabulated. The Facility Plan
Drawing (s) should be revised accordingly. This revision should change the approved
total gross capacity of the C&DLF.
2. Engineering Plan - the temporary BMPs associated with the landfill construction and
operation may be subjected to modification. Smith Gardner, Inc. should contact Land
Quality Section for the any permit modification requirements.
3. Operations Plan/Manual – The waste filling sequences for phase 3 may need to be
modified due to the phasing changes and the schedule for construction of South Portion
of Phase 3. Operation Plan Drawing (s) should be modified accordingly.
4. Closure & Post-Closure Plan – the final/interim cover system and grades for the
Northern Portion of Phase 3 should be added to the Closure Plan drawing(s). The cost
estimates for the closure and post-closure should be modified to reflect the phasing
change so the annual financial assurance (FA) can be calculated and adjusted by
inflation factors. The FA should be revised according to the facility current status
including the partial closure areas.
5. Water Quality Monitoring Plans. The revision of the monitoring plan is contingent on
how soon the Southern Portion of the C&DLF will be constructed and operated. The
SWS intends to demand the monitoring network be established in the areas that can
provide detection of imminent groundwater contamination resulting from waste
operations, even if the areas will be a future landfill cell/phase. Please submit the
revised schedule of Phase 3 construction so that the SWS can decide if the modification
of the existing monitoring network is necessary.
The SWS recommends that Smith Gardner, Inc. submits the above-mentioned permit
modification documents in a timely manner, so that the issuance of PTO for Phase 3 northernportion will not be delayed. Please contact myself if you have any questions of the requested
permit modification.

Ming-Tai Chao, P.E.
Environmental Engineer Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management (Mailing Address)
1646 Mail Service Center Raleigh, NC 27699-1646
(Street Address)Green Square, 217 West Jones Street
Raleigh, NC 27603Tel. [phone]
[e-mail]://portal.ncdenr.org/web/wm/sw
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties unless the content is exempt by statute orother regulations.

From: Chao, Ming-tai
Sent: Wednesday, April 10, 2019 11:28 AM
To: [e-mail]
Cc: Kirchner, Chuck; Drummond, Jaclynne; Stanley, Sherri
Subject: RE: [External] WI High Point

Hi Mike:

Please also send the invitation to the following persons in the SWS:
Kirchner, Chuck [e-mail]
Drummond, Jaclynne [e-mail]
Stanley, Sherri [e-mail]

Thanks.

Ming

-----Original Appointment-----
From: [e-mail] <[e-mail]>
Sent: Wednesday, April 10, 2019 11:22 AM
To: 'Bryan Wuester'; 'Seth Heath'; 'David Pepper'; John Fearrington; Stacey Smith; 'Brady
Johnson'; 'Brad Murray'; Chao, Ming-tai
Cc: 'SCOTT FORD'; '[e-mail]'
Subject: [External] WI High Point
When: Wednesday, April 17, 2019 10:00 AM-12:00 PM (UTC-05:00) Eastern Time (US &
Canada).
Where: High Point C&D Landifll - Phase 3 Pre-Construction Meeting

All,
We will be having a pre-construction meeting for Phase 3 of the WI High Point C&D landfill
Wednesday, April 17, 2019 at 10:00 am at the WI High Point C&D Landfill Office.
If you have any questions or need any additional information please contact me at (919-815-
0813).

Regards.

Mike