4116_WIHighPoint_PH3PTCEngTechReview_DIN26812_20161005.pdf

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary

MICHAEL SCOTT
Director
State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T

October 5, 2016

Sent Via Email – [e-mail]
Mr. Seth Heath
General Manager
5830 Riverdale Road
Jamestown, North Carolina 27282

Subject: Engineering Technical Review
High Point C&D Debris Landfill
Guilford County, Permit # 4116-CDLF-2012, Document ID 26812

Mr. Heath,

The Division of Waste Management, Solid Waste Section (Section) has completed the technical
review of your application submittal titled Permit to Construct Application, WI High Point C&D
Landfill – Phase 3 (DIN 26270). The application was submitted on your behalf by Smith Gardner,
Inc. and was received in the Central Office on May 31, 2016. The application was forwarded to
the Asheville Regional Office on September 19, 2016.

Based on this review, the Section requires clarification or additional information in order to
complete the permitting activity. Please provide a response to each of the items listed below:
Facility and Engineering Plan
1. Rule .0537(d)(1)(C) requires site development drawings which delineate the areal limits of
grading, including borrow and stockpile areas. There were no borrow or stockpile areas
indicated on the drawings.
2. Rule .0537(d)(1)(F) requires site development drawings which delineate physical features
including floodplains, wetlands, unstable areas and cultural resource areas as defined in Rule
.0536. There were no floodplain, unstable or cultural resource areas indicated on the
drawings.
3. Sections 2.3.2, 2.3.3 and 2.3.4 reference Tables 2.3, 2.4 and 2.5, respectively. However,
these tables are not referenced in the Table of Contents and could not be found in the Facility
and Engineering Plan.
4. Rule .0539(e)(4) requires engineering drawings to illustrate the cap system including base
and top elevations, landfill gas devices, infiltration barrier, surface water removal, protective
and vegetative cover, and details. Base elevations and cross-section cap details were not
apparent in the drawings provided.
5. Rule .0539(e)(6)(A) requires engineering drawings to illustrate vertical separation
requirement estimates including cross- sections showing borings, which indicate existing
ground surface elevations, base grades, seasonal high ground-water level, estimated long-
term seasonal high ground-water level in accordance with Part (b)(2)(E) of Rule .0538 of
Mr. Seth Heath 
Engineering Technical Review 
October 5, 2016 
Page 2 of 3 

this Section, and bedrock level in accordance with Part (b)(2)(F) of Rule .0538 of this
Section. There were no cross-sections in the drawings provided.
6. Rule .0539(e)(6)(B) requires an engineering drawings to illustrate vertical separation
requirement estimates including a map showing the existing ground surface elevation and
base grades. The map must include labeled boring locations which indicate seasonal high
ground-water level, estimated long term high ground-water level in accordance with
Part(b)(2)(E) of Rule .0538 of this Section, and bedrock level in accordance with Part
(b)(2)(F) of Rule .0538 of this Section. The required map was not in the drawings provided.
7. Section 3.1, Alternative Final Cover System Design, states an alternative final cover system
as described in Section 6.2 is proposed to eliminate the soil barrier component. However,
the Table of Contents indicates Section 3.0 is the last Section in the Facility and Engineering
Plan and the Alternative Final Cover System is described in Section 2.5.2.
Operations Plan
8. Rule .0542(b)(1)(F) requires operation drawings to illustrate stockpile and borrow
operations. There were no stockpile or borrow areas indicated on the drawings.
9. Section 1.2.3 lists Dennis Shackelford as the Eastern District Supervisor. Mr. Shackelford
has retired from the state. Additionally, the Field Operations Branch has been reorganized
and Guilford County is now within the Western District which is supervised by Ms. Deb Aja.
10. Section 2.2, Prohibited Wastes, lists some of the wastes excluded by Rule .0542(e), but not
all. I would recommend referencing Rule .0542(e) as well as General Statute 130A-309.10(f)
to ensure all prohibited wastes are included.
11. Rule .0542(f)(1) requires solid waste be covered with six inches of earthen material when
the waste disposal area exceeds one-half acre and at least once weekly. Section 3.1.4,
Periodic Cover, only states each week or sooner, excluding the ½-acre requirement.
12. Rule .0542(j)(8) prohibits the removal of solid waste from the landfill unit unless a recycling
plan is included in the Operational Plan and approved by the Division. Additionally, the
general public is prohibited from removing waste at the working face. These prohibitions
were not mentioned in the Operations Manual.
13. Rule .0542(l) requires surface water to be diverted from the operational area, prohibits
surface water from being impounded over or in waste and prohibits waste from being
disposed of in water. Section 5.1.1, Stormwater Diversion in Constructed Cells, only states
waste shall not be placed in standing water.

If you should have any questions regarding this matter please contact me at [phone], or
by email at [e-mail] .

Sincerely,
Allen Gaither
Environmental Engineer

CC: Ms. Madeline German – Smith Gardner, Inc.
Ms. Christine Ritter – SWS/RCO