4116_WIHighPoint_PH3PTCResponsetoComments_DIN26855_20161014.pdf

October 14, 2016

Mr. Allen Gaither
Environmental Engineer
NC DEQ, Division of Waste Management
1646 Mail Service Center
Raleigh, NC 27699-1646

RE: WI High Point C&D Landfill --- Phase 3 (SWS Permit No. 41-16)
Response to Comments --- Permit Renewal, Engineering Technical Review
High Point, North Carolina

Dear Mr. Gaither:

Smith Gardner Inc. (S+G) is pleased to respond to your October 5, 2016 comments (Attached) on
behalf of WI High Point Landfill. Please find our responses (bold) corresponding to your comments
presented in italics.

Facility and Engineering Plan

Comment 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.

Response: With the exception of an existing stockpile south of Phase 1, all stockpiles and/or
borrow shall occur within proposed waste limits.

Comment 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.

Response: There are no floodplains, unstable and/or cultural resource areas within the facility
boundary. FEMA has designated this facility as Zone X, areas determined to be outside 0.2%
annual chance floodplain. A note has been added to Drawing S1 (Existing Conditions) to reflect
this.

Comment 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.

Response: Reference to Tables 2.3, 2.4, and 2.5 have been revised to reference Table 2.2.

Comment 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
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Mr. Allen Gaither
October 14, 2016
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apparent in the drawings provided.

Response: Drawings X1 and X2 (Engineering Cross Sections) have been included to include base
grades and final cover grades for the facility.

Comment 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 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.

Response: Drawings X1 and X2 (Engineering Cross Sections) have been included to provide
boring locations, long term seasonal high groundwater surface, bedrock surface, base grades,
and a minimum 4’ separation note.

Comment 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.

Response: Drawings X1 and X2 (Engineering Cross Sections) have been included to provide
boring locations, long term seasonal high groundwater surface, bedrock surface, base grades,
and a minimum 4’ separation note.

Comment 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.

Response: Reference to Section 6.2 has been replaced to reference Section 2.5.2.

Operations Plan

Comment 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.

Response: With the exception of an existing stockpile south of Phase 1, all stockpiles and/or
borrow shall occur within proposed waste limits.

Comment 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.

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Mr. Allen Gaither
October 14, 2016
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Response: Western District Supervisor contact information has been updated for Deborah Aja.

Comment 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.

Response: General Statute 130A-309.10(f) has been referenced in Section 2.2, Prohibited Wastes
as stated: ‘‘Wastes as described within NC General Statute §130A-309.10(f) shall not be
accepted; except wooden pallets which may be disposed in construction and demolition debris
per §130A-309.10(f)(12).’’

Comment 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.

Response: Section 3.1.4 now reads as: ‘‘When the waste disposal area exceeds one-half acre and
at the completion of waste placement each week or sooner, a 6-inch layer of earthen material
will be placed over the exposed waste. This periodic cover is intended to control vectors, fire,
odors, and blowing debris.’’

Comment 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.

Response: The facilities recycling plan is discussed under Section 4.0 ‘‘Recovery Area
Operations’’ of the submitted Operation Plan.

The following paragraph has been added to Section 2.3.1: ‘‘The removal of solid waste from any
landfill unit is prohibited except upon notification of the DWM (see Section 1.2.3). Regardless,
the general public is prohibited from any waste removal activities from any landfill unit.’’

Comment 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.

Response: Section 5.1.1 now reads as: ‘‘In accordance with 15A NCAC 13B .0542(l) surface water
shall be diverted from the operational area or not be impounded over or in waste and waste
shall not be placed in standing water. Collected stormwater within the cell shall be removed by
pumping low areas.

Particular care is required to ensure that surface water coming from the active face, e.g. having
potential contact with the waste is allowed to percolate into the underlying waste. Only run-off
from waste surfaces that have received adequate cover is not considered leachate and should be
directed to the stormwater drainage system, where practical. ’’

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Mr. Allen Gaither
October 14, 2016
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Please contact us with comments of questions at 919-828-0577 or by email below.

Sincerely,
SMITH GARDNER, INC.

Madeline German, P.G. Stacey A. Smith, P.E.
Project Geologist Senior Engineer
[e-mail] [e-mail]

Attachments: Revised Facility and Engineering Report Text
Revised Operations Plan Text
Revised Permit to Construct Drawings

cc: Seth Heath, Waste Industries
David Pepper, Waste Industries
Ed Mussler, NCDEQ
File
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10/14/2016
10/14/2016

Facility and Engineering Plan

WI High Point C&D Landfill
Jamestown, North Carolina

Prepared for:

WI High Point Landfill, LLC
Jamestown, North Carolina

May 2016

Prepared by:

© 2016 Smith Gardner, Inc.
This document is intended for the sole use of the client for which it was prepared and
for the purpose agreed upon by the client and Smith Gardner, Inc.

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Facility and Engineering Plan

WI High Point C&D Landfill
Jamestown, North Carolina

Prepared For:
WI High Point Landfill, LLC
Jamestown, North Carolina

S+G Project No. WIHIGHPOINT-16-1

May 2016

John R. Fearrington, E.I.
Staff Engineer

Stacey A. Smith, P.E.
Senior Engineer
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WI High Point C&D Landfill Facility and Engineering Plan
May 2016 Table of Contents Page i
WI High Point C&D Landfill
Jamestown, North Carolina

Facility and Engineering Plan

Table of Contents
Page

1.0 SITE DESCRIPTION .................................................................................................... 1
2.0 FACILITY REPORT ...................................................................................................... 1
2.1 Facility Services and Waste Stream ....................................................................... 1
2.1.1 Facility Services .......................................................................................... 1
2.1.2 Types of Waste ............................................................................................ 1
2.1.3 Disposal Rates and Estimated Variances ................................................... 1
2.1.4 Service Area ................................................................................................ 2
2.1.5 Procedures for Waste Segregation ............................................................. 2
2.1.6 Equipment Requirements ........................................................................... 2
2.2 Landfill Capacity...................................................................................................... 2
2.2.1 Total Operating Capacity and Life Expectancy ............................................ 2
2.2.2 Airspace Utilization Factor and Percentage of Periodic Cover Soil ........... 2
2.3 Available Soil Resources and Required Soil Quantities.......................................... 3
2.3.1 Earthwork Quantities .................................................................................. 3
2.3.2 Daily and Intermediate Cover ..................................................................... 3
2.3.3 Vegetative Soil Layer ................................................................................... 3
2.3.4 Soil Summary .............................................................................................. 3
2.4 Facility Design Criteria ........................................................................................... 3
2.4.1 Horizontal Separation Requirements ......................................................... 3
2.4.2 Vertical Separation Requirements.............................................................. 4
2.5 Containment and Environmental Control Systems ................................................ 4
2.5.1 Landfill Subgrade and Perimeter Berms ................................................... 4
2.5.2 Final Cover System ..................................................................................... 4
2.5.3 Erosion and Sedimentation Control ............................................................ 5
2.5.4 Access and Roadways ................................................................................. 5
2.6 Slope Stability, Settlement, and Bearing Capacity ................................................. 6
2.7 Special Engineering Features ................................................................................. 6
2.7.1 Buffer Variance ........................................................................................... 6
2.7.2 Wetlands Mitigation .................................................................................... 6
2.7.3 Underdrain .................................................................................................. 7
3.0 FINAL COVER SYSTEM DESIGN ................................................................................. 9
3.1 Alternative Final Cover System Design .................................................................. 9
3.1.1 Final Cover Infiltration Analysis .................................................................. 9
3.1.1 Slope Stability ............................................................................................10
3.1.2 Drainage Layer Analysis ............................................................................10
3.1.3 Filter Geotextile Analysis ...........................................................................10
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TABLES
Table 2.1 Total Operating Capacity and Life Expectancy - -- CDLF Units ..................... 7
Table 2.2 Soil Summary .............................................................................................. 8

APPENDIX
Appendix A Landfill Design Calculations

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1.0 SITE DESCRIPTION
The Phase 3 unit is a lateral expansion to the east and has a waste footprint of approximately
6.5 acres. The unit lies within the City of High Point Randleman Lake Water Supply Watershed
and has requested a variance from the City allowing landfill activities to take place within the
riparian buffers. There are wetland areas in the southern portion of the proposed footprint with
mitigation plans in review by the Army Corps of Engineers.

2.0 FACILITY REPORT
This section presents an updated plan for the development of the Phase 3 C&D landfill unit of
the WI High Point C&D Landfill facility. This report has been prepared in accordance with the
requirements of Rule .0531 and .0547 of the North Carolina Solid Waste Management Rules.

2.1 Facility Services and Waste Stream
2.1.1 Facility Services
Currently, the following activities or services are provided at the WI High Point
C&D Landfill facility as shown on Drawing S1 (Attachment O):

• Scales and scale house facilities
• Administrative offices and maintenance building
• C&D landfill
• Waste Reclamation Pad

2.1.2 Types of Waste
The High Point C&D Landfill facility accepts construction and demolition debris
(C&D) waste, land clearing and inert debris waste, and other wastes (i.e. asphalt
and asbestos). Trained personnel screen waste received at the scale house
entrance and direct loads to the working face or reclamation pad.

2.1.3 Disposal Rates and Estimated Variances
Based on the 2015-2016 Solid Waste Management Annual Report information
provided by Waste Industries, the landfill accepted 43,053 tons of C&D waste
from 1/13/15 to 1/2/16 (average 3,587 tons per month or 151 tons per day based
on 285 operating days per year). This tonnage has been typical for the facility in
recent years. A conservative disposal rate of 45,000 tons per year was used in
calculating phase life expectancy (Appendix A). As documented during the
previous permit approval process, the maximum disposal rate for the landfill is
98,600 tons per year (average of 7,480 tons/month or 315 tons/day based on 285
operating days per year).
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2.1.4 Service Area
The landfill facility currently serves the Counties of Guilford, Surry, Stokes,
Rockingham, Caswell, Yadkin, Forsyth, Alamance, Orange, Davie, Rowan,
Davidson, Cabarrus, and Randolph.

2.1.5 Procedures for Waste Segregation
Procedures for waste segregation at the proposed landfill will be similar to
existing operations in Phases 1 and 2 including requirements for waste
screening and contingency plans for managing any identified hazardous and
liquid wastes. Refer to the Operations Manual (Attachment I) for more
information.

2.1.6 Equipment Requirements
WIHP will maintain on-site equipment required to perform the necessary landfill
activities. Periodic maintenance of all landfilling equipment, and minor and
major repair work will be performed at designated maintenance zones.

2.2 Landfill Capacity
2.2.1 Total Operating Capacity and Life Expectancy
Drawing S2 (Site Development Plan - Base Grades) and Drawing S3 (Site
Development Plan - Final Cover Grades), show conceptual subgrade and final
cover grades for the development of Phase 3, respectively. The final cover side
slopes will be at a 3H to 1V slope, then transition at flatter slopes (5 to 8%) to the
peak elevations.

The estimated gross and net operating capacities, life expectancies, and areas of
existing and planned C&D landfill units are shown in Table 2.1. The net capacity
for waste and corresponding life expectancy of each landfill unit accounts for
daily and intermediate cover and/or final cover. As noted in Section 2.1.3, life
expectancies were calculated based on a disposal rate of 45,000 tons per year.

2.2.2 Airspace Utilization Factor and Percentage of Periodic Cover Soil
The capacities obtained were based on gross capacities (which includes waste,
daily, and intermediate cover) and an assumed airspace utilization factor (AUF)
(tons of waste disposed/volume filled) of 0.50 tons/cubic yard (tons/cy). AUF
values are based on values calculated for actual historical filling conditions at the
landfill.
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Note that AUF values are anticipated to be lower during initial filling of landfill
units and increase over time due to the additional thickness of the waste mass
and the degradation of organic wastes. Note also that changes in landfill
operations (i.e. changes in the use of alternative daily cover and/or compaction
equipment/methods) may affect the values assumed above and, thus, alter the
life of the various landfill units.

2.3 Available Soil Resources and Required Soil Quantities
2.3.1 Earthwork Quantities
The soils required to construct and operate the existing and planned C&D landfill
units will be removed from on-site borrow sources. The soils removed during
excavation of landfill units may be used for structural fill, soil liner, periodic
cover, final cover, and general fill. These excavation (cut) and structural fill (fill)
volumes are shown in Table 2.2.

2.3.2 Daily and Intermediate Cover
Assuming the previously mentioned periodic cover ratios, the required in-place
volume for use as daily and intermediate cover during operations of the Phase 3
unit is shown in Table 2.2.

2.3.3 Vegetative Soil Layer
On the basis of the 1.5 foot thick vegetative soil layer required for the landfill final
cover, the in-place volume required for each landfill unit is shown in Table 2.2.

2.3.4 Soil Summary
The above on-site soil quantities are summarized in Table 2.2.

2.4 Facility Design Criteria
Existing and proposed C&D landfill units were and will be constructed in accordance
with Section .0540 and .0542 of the North Carolina Administrative Code, Title 15A,
Chapter 13, Subchapter 13B including the following requirements:

2.4.1 Horizontal Separation Requirements
The horizontal separation requirement between the disposal boundary (edge of
waste) and the property lines is a minimum of 200 feet; the minimum buffer
between private residences and wells and the disposal boundary is 500 feet; and
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the minimum buffer between any surface water (wetland, stream, river, creek)
and the disposal boundary is 50 feet. The proposed design satisfies all buffer
requirements.

2.4.2 Vertical Separation Requirements
The post-settlement bottom elevation of the liner system will meet the minimum
requirement of four (4) feet above the seasonal high groundwater table and
bedrock.

2.5 Containment and Environmental Control Systems
The following systems and elements are the basic containment and environmental
controls for the Phase 3 unit. Technical specifications and construction quality
assurance requirements can be found in Attachments G and H, respectively.

2.5.1 Landfill Subgrade and Perimeter Berms
The subgrade elevations will be achieved by excavation or placement of
compacted structural fill (embankment). During excavation, a determination of
unsuitable soils (i.e. soils which are too soft, wet, or organic) will be made.
Where unsuitable soils are found, the soils will be undercut and backfilled with
structural fill. The two (2) foot prepared subgrade will consist of in-situ or
modified soils consisting of types SC, SM, ML, CL, MH, or CH.

Structural fill will be used for berm and roadway construction. Structural fill will
consist of on-site soils removed during excavation of the landfill units or
imported borrow soils, except that no CH, OL, or OH soils will be allowed.

2.5.2 Final Cover System
The final cover system for Phase 3 will consist of the following components (top-
down):

Regulatory Final Cover System (.0543(c)(2))

• an 18-inch thick vegetative soil layer;
• an 18-inch thick soil liner with a hydraulic conductivity (k) of no more
than 1.0 x 10-5 cm/sec (‘‘compacted soil barrier’’); and
• a 12-inch thick intermediate cover layer.

OR

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Alternative Final Cover System

Top Slopes (5 to 8%)
• a 24-inch thick vegetative soil layer;
• a drainage geocomposite (with drainage breaks);
• a 40-mil textured LLDPE geomembrane; and
• a 12-inch think intermediate cover layer

Side Slopes (3H:1V)
• a 24-inch thick vegetative soil layer

The final cover system will be placed on prepared intermediate cover at a
maximum slope of 3H:1V. Surface water control devices vents will also be
incorporated into the final cover system. The final cover surface will be
vegetated upon completion of the final cover installation according to the project
seeding specifications.

Analysis of the alternate final cover system is presented in Section 3.1.

2.5.3 Erosion and Sedimentation Control
Erosion and sedimentation control devices/measures will be designed and
maintained to manage the run-off generated by the 25-year 24-hour storm event
and conform to the requirements of the North Carolina Sedimentation Pollution
Control Law (15A, NCAC, 4).

An Erosion and Sedimentation Control Plan designed to meet City of High Point
stormwater design requirements1 for the entire site will be provided as a
separate submittal from the PTC application.

2.5.4 Access and Roadways
The facility is accessed from Riverdale Drive. A scale and a scale house are
located near this entrance. Drawing S2 (Site Development Plan - Base Grades)
shows this infrastructure.

All-weather access to active areas as well as areas under intermediate cover will
be provided. Access ramps into the landfill units will be provided where
necessary.

1 City of High Point Engineering Services Department (2009 Update), City of High Point Stormwater Best
Management Practices Design Manual, High Point, NC.
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2.6 Slope Stability, Settlement, and Bearing Capacity
An evaluation of the slope stability of the overall waste mass of the Phase 3 unit is
addressed in Appendix A. These analyses indicate that the proposed landfill
configuration will be stable, even with the conservative approach of not reducing the
peak ground acceleration for seismic runs, typical for landfill design. A summary of
these results can be found below.

Cross
Section
Analyzed
Failure Type Method of
Analysis
Factor of Safety
Static
(FS ≥ 1.5)
Seismic
(FS ≥ 1.1)
A-A
Block Along
Subgrade
Simplified Janbu 2.95 2.28
Spencer’s 3.21 2.49
Circular Simplified Bishop 2.73 2.07
B-B
Block Along
Subgrade
Simplified Janbu 2.94 2.22
Spencer’s 3.18 2.41
Circular Simplified Bishop 2.98 2.26

2.7 Special Engineering Features
Special engineering features proposed for Phase 3 include riparian buffer variances and
wetlands mitigation.

2.7.1 Buffer Variance
Phase 3 will impact riparian buffers set forth by the Randleman Lake Buffer
Rule. A submittal was made to the City to allow impact within these buffer areas
and was approved in November 2015. The submittal was also issued to the North
Carolina Environmental Management Commission (EMC) and is currently under
review.

2.7.2 Wetlands Mitigation
A Clean Water Act (CWA) permit application has been submitted to the Army
Corps of Engineers to allow fill material to be placed within the stream channel
and wetlands located in Phase 3.

The TRC watershed plan application and major variance request and related
documents are provided in Attachment F.

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2.7.3 Underdrain
The development of Phase 3 includes impact to a non-functioning stream
pending approval of the aforementioned CWA permit application. The underdrain
system has been proposed to assist in drainage of any base seepage remaining
from the impacted stream and to maintain vertical separation of groundwater
from the waste. Refer to Appendix A for underdrain analysis.

Table 2.1 Total Operating Capacity and Life Expectancy -- CDLF Units
Landfill Unit Area
(Acres)
Gross Capacity
(CY)
Net (Waste) Capacity
(CY)
Life Expectancy
(Years)1
C&D Landfill Units
Phase 1 12.5 788,083 - Filled
Phase 2A 4.3 240,140 - Filled
Phase 2B-1 3.6 481,397 95,155 1.1
Phase 2B-2 1.5 213,136 176,844 2.0
Phase 3 6.5 744,681 723,708 8.0
Phase 4 5.6 728,676 710,607 7.9
Phase 5 8.5 757,216 729,789 8.1
Phase 6 3.6 820,639 809,023 9.0
Total: 46.1 4,773,968 3,245,126 36.1

Notes:
1. Life expectancy for the active Phase 2B-1 unit shown above is from 1/2/16. Life expectancies are
based on a disposal rate of 45,000 tons/year and a placement rate of 0.5 tons per cubic yard
(TCY).

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Table 2.2 Soil Summary
Material Quantity (CY)
On-Site:
Excavation 31,113
Structural Fill (92,159)
Daily/Intermediate Cover (72,371)
Vegetative Soil Layer1 (21,812)
On-Site Total2: (155,229)

Notes:
1. The quantities shown above assume a thickness of 24 inches.
2. On-site material refers to materials available and used within the landfill
footprint (and related development areas) only.
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3.0 FINAL COVER SYSTEM DESIGN
This section addresses the design of the final cover system for Phase 3. Technical
specifications and construction quality assurance requirements for final cover system
components can be found in Attachments G and H, respectively. A facility Closure and Post-
Closure Plan, including cost analyses, is provided as Attachment J. Also refer to the Permit to
Construct Drawings (Attachment O) for final cover system details.

3.1 Alternative Final Cover System Design
An alternative final cover system as described in Section 2.5.2 is proposed to eliminate
the soil barrier component

3.1.1 Final Cover Infiltration Analysis
A final cover infiltration analysis was performed to demonstrate that the
alternate cover system allows less infiltration than the regulatory final cover
system (see Appendix A). An analysis of the alternate final cover drainage layer
(drainage geocomposite) is provided in Appendix A. This analysis focused on
determining the required transmissivity to maintain the peak head within the
drainage geocomposite. An analysis is also provided in Appendix A which shows
that the upper geotextile of the drainage geocomposite will perform acceptably
as a filter when covered with typical site soils.

The Hydrologic Evaluation of Landfill Performance (HELP) Model (Version 3.95)
was used to evaluate the effectiveness of the alternative final cover at minimizing
infiltration on both the flatter top slopes and the steeper side slopes. For both
the top and side slopes, the infiltration analysis demonstrates that the addition of
a drainage geocomposite over the geomembrane significantly reduces the head
on the barrier and, thereby, significantly reduces the calculated infiltration as
compared to the regulatory minimum cover (see Appendix A).

Condition
Alternate Final Cover
System
Regulatory Minimum
Final Cover System
Average Annual Infiltration (inches)
Top Slopes (5%): 0.006 14.5
Side Slopes (3H:1V): 14.4 14.4

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3.1.1 Slope Stability
An evaluation of the veneer stability of the landfill final cover is provided in
Appendix A. The evaluation indicates that the final cover system will satisfy
design criteria (FSstatic = 1.5; FSseismic = 1.1) if the minimum peak interface shear
strength for the weakest interface is defined by the following values:

Normal Loads </= 200 psf (Based on Veneer Stability):

Cohesion = 0 psf
Phi = 30.0 degrees

3.1.2 Drainage Layer Analysis
The analysis of the alternative final cover drainage layer (drainage geocomposite
is provided in Appendix A. This analysis focused on determining the required
value of transmissivity to maintain peak heads within the drainage geocomposite.

The analysis was performed based on a worst case condition of 3H:1V (18.4
degrees) slopes and a maximum 200 foot flow length (horizontal projection) to
drainage breaks in the drainage geocomposite (coincides with the maximum side
slope length between side slope swales). This condition represents the worst
case in that adequate transmissivity is required along the steeper side slopes to
maintain flow within the geocomposite and, thus, minimize seepage forces in the
vegetative soil layer which could affect stability. Calculations were carried out
assuming the maximum permeability of the vegetative soil layer is 1 x 10-4
cm/sec. The calculations, which include an overall reduction factor of 6
(accounts for a factor of safety of 2 plus a combined reduction factor of 3 for
long-term intrusion, creep, and clogging concerns), indicate that a minimum
transmissivity of 6.6 x 10-4 m3/m/sec is required for the drainage geocomposite;
however, material specifications shall require a minimum transmissivity of 1 x
10-3 m3/m/sec. Transmissivity tests should be conducted based on anticipated
field conditions (maximum normal load, boundary conditions, and gradient).

The soils proposed for use as the vegetative soil layer should be confirmed prior
to construction to ensure compatibility with all the design assumptions stated
herein.

3.1.3 Filter Geotextile Analysis
A filter geotextile analysis was performed to determine the apparent opening
size (AOS) and permittivity required to ensure the proper performance of the
upper geotextile component of the drainage geocomposite as a filter. The
analysis (see Appendix A) assumes that the vegetative soil layer will be silts or
clays (based on the typical grain size curves evaluated) and non-dispersive.
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Based on the filter geotextile analysis, recommended AOS and permittivity of the
upper geotextile component of the drainage composite are as follows:

AOS (upper geotextile) (ASTM D 4751): 60+ (U.S. Sieve)
Permittivity (upper geotextile) (ASTM D 4491): 1.0 sec-1

AOS and permittivity were determined based on typical values for a 6 oz./SY
nonwoven geotextile.

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OPERATIONS MANUAL

WI High Point C&D Landfill
Jamestown, North Carolina
NC Solid Waste Permit No. 41-16

Prepared for:

WI High Point, LLC
(a Waste Industries Company)
Jamestown, North Carolina

May 2016
Revised: October 2016

Prepared by:

© 2016 Smith Gardner, Inc.
This document is intended for the sole use of the client for which it was prepared and
for the purpose agreed on by the client and Smith Gardner, Inc.
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OPERATIONS MANUAL

WI High Point C&D Landfill
NC Solid Waste Permit No. 41-16
Jamestown, North Carolina

Prepared For:

WI High Point, LLC
Jamestown, North Carolina

S+G Project No. WI High Point 16-1

May 2016
Revised: October 2016

© 2016 Smith Gardner, Inc.
This document is intended for the sole use of the client for which it was prepared and
for the purpose agreed on by the client and Smith Gardner, Inc.

Madeline German, P.G.
Project Geologist

Stacey A. Smith, P.E.
Senior Engineer
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10/14/2016
10/14/2016

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WI High Point C&D Landfill
NC Solid Waste Permit No. 41-16

Operations Manual

Table of Contents
Page

1.0 GENERAL FACILITY OPERATION ............................................................................... 1
1.1 Overview ...................................................................................................................1
1.2 Contact Information .................................................................................................1
1.2.1 WI High Point, LLC ...................................................................................... 1
1.2.2 Waste Industries USA, Inc. .......................................................................... 2
1.2.3 North Carolina Department of Environmental Quality ............................... 2
1.3 Facility Operations ...................................................................................................3
1.3.1 Facility Operating Hours ............................................................................. 3
1.3.2 Operating Capacity ...................................................................................... 3
1.3.3 Service Area ................................................................................................ 3
1.4 Access Control .........................................................................................................3
1.4.1 Physical Restraints ..................................................................................... 3
1.4.2 Security ....................................................................................................... 4
1.5 Signage ....................................................................................................................4
1.5.1 Waste Limit Markers................................................................................... 4
1.6 Communications ......................................................................................................4
1.7 Fire Control ..............................................................................................................4
1.7.1 Open Burning .............................................................................................. 5
1.7.2 Fire Tetrahedron ......................................................................................... 5
1.7.3 Equipment ................................................................................................... 5
1.7.4 General Fire Management Strategies ........................................................ 5
1.7.5 Fires Within Disposal Areas ........................................................................ 6
1.7.6 Notification .................................................................................................. 6
1.7.7 Coordination With Local Fire Department .................................................. 6
1.8 Severe Weather Conditions .....................................................................................6
1.8.1 Ice Storms ................................................................................................... 7
1.8.2 Heavy Rains ................................................................................................. 7
1.8.3 Electrical Storms ........................................................................................ 7
1.8.4 Windy Conditions ......................................................................................... 7
1.8.5 Violent Storms............................................................................................. 7
1.9 Equipment Requirements ........................................................................................7
1.10 Personnel Requirements .........................................................................................8
1.11 Health and Safety .....................................................................................................8
1.11.1 Personal Hygiene ....................................................................................... 9
1.11.2 Personal Protective Equipment ................................................................. 9
1.11.3 Mechanical Equipment Hazard Prevention ..............................................10
1.11.4 Employee Health and Safety .....................................................................10
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1.11.5 Physical Exposure.....................................................................................10
1.11.6 Safety Data Sheets ....................................................................................10
1.12 Utilities ................................................................................................................... 10
1.13 Recordkeeping Program ........................................................................................ 11
2.0 WASTE HANDLING OPERATIONS ............................................................................ 12
2.1 Acceptable Waste ................................................................................................... 12
2.2 Prohibited Wastes .................................................................................................. 12
2.3 Waste Screening Programs ................................................................................... 13
2.3.1 Waste Receiving and Inspection ................................................................13
3.0 HAZARDOUS WASTE CONTINGENCY PLAN ............................................................. 15
3.1 Waste Disposal....................................................................................................... 15
3.1.1 Access ........................................................................................................15
3.1.2 General Procedures ...................................................................................15
3.1.3 Special Waste Management.......................................................................16
3.1.3.1 Asbestos Management ............................................................................................ 16
3.1.4 Periodic Cover ............................................................................................18
3.2 Height Monitoring .................................................................................................. 18
3.3 Recordkeeping ....................................................................................................... 18
4.0 RECOVERY AREA OPERATIONS ............................................................................... 19
4.1 Access .................................................................................................................... 19
4.2 Recovered Material Management .......................................................................... 19
4.3 General Procedures ............................................................................................... 19
4.4 Shingles Management ........................................................................................... 20
4.4.1 Asbestos Management...............................................................................21
4.4.2 Air Quality ...................................................................................................21
4.5 Recovered Material Storage .................................................................................. 21
4.6 Recovered Materials and End Uses ....................................................................... 21
4.7 Safety ..................................................................................................................... 22
4.8 Equipment .............................................................................................................. 23
4.9 Personnel ............................................................................................................... 23
4.10 Recordkeeping ....................................................................................................... 23
5.0 ENVIRONMENTAL MANAGEMENT ........................................................................... 24
5.1 Erosion and Sedimentation Control ....................................................................... 24
5.1.1 Stormwater Diversion in Constructed Cells ..............................................24
5.2 Groundwater Monitoring ........................................................................................ 25
5.3 Landfill Gas Control ............................................................................................... 25
5.4 Litter Control ......................................................................................................... 25
5.5 Vector Control ........................................................................................................ 25
5.6 Odor Control........................................................................................................... 25
5.7 Dust Control ........................................................................................................... 25
5.8 Interim Cover ......................................................................................................... 25
5.8.1 Interim Cover Monitoring ...........................................................................26

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TABLES (within text)
Table 1 Equipment Requirements
Table 2 Personnel Requirements
Table 3 Recovered Materials and End Uses

FIGURES
Figure 1 Site Location Map
Figure 2 Facility Map
Figure 3 Service Area Map
Figure 4 Waste Placement Grid
Figure 5 Reclamation Facility Site Map
Figure 6 Facility Operations Flow Chart

APPENDICES
Appendix A Fire Occurrence Notification Form
Appendix B Waste Screening Form
Appendix C Paint Filter Liquids Test – EPA Method 9095
Appendix D Shingle Supplier Certification Form

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1.0 GENERAL FACILITY OPERATION
1.1 Overview
This Operations Manual was prepared for the WI High Point Landfill Facility, which
operates as a construction and demolition debris (C&D) landfill (Permit No. 41-16) and is
owned by WI High Point, LLC (a subsidiary of Waste Industries USA, Inc.). The WI High
Point LF is located at 5830 Riverdale Road in Jamestown, North Carolina; as shown on
the Site Vicinity Map, included as Figure 1. This document discusses C&D landfill unit
operations and other solid waste management activities:

• Scales and scale house facilities;
• Construction and Demolition Debris (C&D) landfill;
• Reclamation Activities.

Figure 2 presents existing and proposed landfill units and other solid waste
management activity locations.

The information contained herein was prepared to provide facility with a clear
understanding of how the Design Engineer assumed that the completed facility would be
operated. While deviations from the operations outlined here may be acceptable, they
should be reviewed and approved by the Design Engineer. Please refer to the
appropriate permit application for a detailed discussion and calculations for the
individual components of each landfill unit, including phasing plans.
1.2 Contact Information
Correspondence and questions concerning the operation of the WI High Point LF facility
should be directed to the appropriate Operator and State personnel listed below. WI
High Point, LLC is a wholly owned subsidiary of Waste Industries USA, Inc. For fire or
police emergencies, dial 911.
1.2.1 WI High Point, LLC
Address: 5830 Riverdale Drive
Jamestown, North Carolina 27282
Scale House Phone: [phone]
Fax: [phone]

General Manager: Seth Heath
Email: [e-mail]
Phone: [phone]

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1.2.2 Waste Industries USA, Inc.
Address: 3301 Benson Drive, Suite 600
Raleigh, North Carolina 27609
Region Manager: Ben Habets
Email: [e-mail]
Phone: [phone]
Fax: [phone]
1.2.3 North Carolina Department of Environmental Quality
North Carolina DEQ - Raleigh Central Office (RCO)
Address: 217 West Jones Street
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Phone: [phone]
Fax: [phone]

North Carolina DEQ – Winston Salem Regional Office
Address: 585 Waughtown Street
Winston Salem, North Carolina 27107
Phone: [phone]
Fax: [phone]

Division of Waste Management (DWM) - Solid Waste Section:
Field Operations Branch Head: Jason Watkins (WSRO)
Email: [e-mail]
Western District Supervisor: Deborah Aja (FBO)
Email: [e-mail]
Environmental Senior Specialist: John Patrone
Email: [e-mail]

Division of Energy, Mineral and Land Resources- Land Quality Section
Address: 585 Waughtown Street
Winston Salem, North Carolina
Phone: [phone]
Fax: [phone]

Regional Engineer: Matthew Gantt, P.E. (WSRO)
Email: [e-mail]
Environmental Engineer I: Shannon Leonard (WSRO)
Email: [e-mail]

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1.3 Facility Operations
1.3.1 Facility Operating Hours
Normal hours of operation will be 7:00 A.M. to 4:00 P.M. Monday through Friday
and occasionally on Saturdays as needed. The facility will be closed on holidays
as designated by the Owner. The Owner may elect to modify these hours from
time to time.
1.3.2 Operating Capacity
The WI High Point LF is approved to accept approximately 315 tons per day,
assuming 285 operational days per year, or 98,600 tons per year, per the
franchise amendment granted by the High Point City Council on May 18, 2009.1
1.3.3 Service Area
The WI High Point facility is permitted to receive solid waste generated within the
following Counties of the State of North Carolina (Figure 3) consistent with the
franchise amendment approved by the City of High Point: Guilford, Randolph,
Davidson, Forsyth, Rockingham, Caswell, Alamance, Orange, Cabarrus, Rowan,
Davie, Yadkin, Surry, and Stokes.
1.4 Access Control
Limiting access to the WI High Point LF facility is important for the following reasons:

• Unauthorized and illegal dumping of waste materials is prevented.
• Trespassing, and injury resulting therefrom, is discouraged.
• The risk of vandalism is greatly reduced.

Access to active areas of the landfill will be controlled by a combination of fences and
natural barriers, and strictly enforced operating hours through the landfill entrance off
of Riverdale Road. A scalehouse attendant will be on duty at all times when the landfill
facility is open for public use to enforce access restrictions.
1.4.1 Physical Restraints
The site is accessed by an entrance road that intersects Riverdale Road on the
eastern edge of the property. Scales and a scale house are provided along the
entrance road where all refuse trucks entering the facility are weighed when
entering and exiting the facility.

1 May 18, 2009- Ordinance Amending and Expanding A Solid Waste Franchise to WCA of High Point, LLC.
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1.4.2 Security
The entrance, on Riverdale Road, has a gate that is securely locked during non-
operating hours. Frequent gate and fence inspections will be performed by
landfill personnel. Evidence of trespassing, vandalism, or illegal operation will
be reported to the Owner.
1.5 Signage
A prominent sign(s) containing the information required by the DWM is located
immediately inside the main entrance to the facility. This sign(s) will provide information
on operating hours, operating procedures, acceptable wastes and/or information as
required under the facility permit. Additional signage will be provided as necessary
within the waste disposal complex to distinguish the roadways to the active waste
disposal areas, manage and direct traffic, regulate speed limits, identify groundwater
monitoring wells, and define waste boundaries. Service and maintenance roads for use
by operations personnel will be clearly marked and barriers (e.g., traffic cones, barrels,
etc.) will be provided as required. Landfill personnel will routinely inspect the conditions
of the posted signage to ensure that they are clearly visible and intact. Damaged or
missing signage will be replaced.
1.5.1 Waste Limit Markers
During construction of new phases, expansion of the facility, or following closure
of areas, waste limit markers will be used to identify the permitted limits of
waste. The waste markers will be constructed of non-degradable material and
will clearly state “waste limit” or “edge of liner” in bold lettering. Offsets are
acceptable such that all wording is clear to DWM and operational staff. The waste
markers will be maintained and replaced when damaged.
1.6 Communications
Two way radio communications is maintained between the landfill and reclamation
operations, the landfill manager, and the scale house and office. The scale house and
site office have telephones in case of emergency and for the conduct of day-to-day
business. Emergency telephone numbers are displayed in these locations. Cellular
phones are available for key operating staff (i.e. managers, operators).
1.7 Fire Control
Although no open burning of waste is allowed at the facility, the possibility of fire within
the processing and storage areas, the landfill, or a piece of equipment must be
anticipated in the daily operation of the facility. Potential fire hazards include both
surface conditions and subsurface conditions. Surface conditions include equipment
operations and newly placed waste. Subsurface conditions include existing waste
previously landfilled.
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1.7.1 Open Burning
With the exception of the controlled burning of land clearing debris generated
on-site or from emergency clean-up operations, no open burning is allowed at
the facility. Controlled burning will occur only if permitted or approval by the
DWM, the Division of Air Quality (DAQ), and the local fire department.
1.7.2 Fire Tetrahedron2
To better understand the properties of fire we can
examine the fundamental methods to extinguish it.
The fire “tetrahedron” illustrates the rule that to
ignite and burn, each component represents a
property of flaming fire; fuel, oxygen, heat, and
chemical chain reaction. A fire is prevented or
extinguished by removing any one of them. A fire naturally occurs when the
elements are combined in the right mixture (e.g., more heat needed for igniting
some fuels, unless there is concentrated oxygen). The fire tetrahedron is a more
modern adaptation of the traditional fire “triangle” recognizing the chemical
reactions that may occur as a component – “the uninhibited chain reaction”. This
chain reaction is the feedback of heat to the fuel to produce the gaseous fuel
used in the flame. In other words, the chain reaction provides the heat necessary
to maintain the fire. These principles are integral in the prevention and
management of potential fire situations. Please note this information is
considered as a basis of understanding and may be superseded by the direction
and skill of the local Fire Marshall.
1.7.3 Equipment
A combination of factory installed fire suppression systems and/or portable fire
extinguishers will be operational on heavy equipment at all times. Potential fire
hazards are created from the build-up of fine, dry dust particles on and around
operational motors and control panels. The presence of these build-ups can
cause overheating and potential fire if periodic equipment cleaning and
maintenance are not practiced. Portable fire extinguishers should be maintained
in a state of readiness on each piece of moving equipment and equipment should
be cleaned periodically.
1.7.4 General Fire Management Strategies
Each fire situation is site specific; however, general strategies for active fire
management include the following (in no particular order):

2 National Fire Protection Association (www.nfpa.org)
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• Accelerated high temperature combustion (displacing fuel);
• Covering of the landfill burn area with soil (reduce oxygen);
• Covering of the burn area with foams (reduce oxygen);
• Flooding the burn area with water (reduce heat);
• Injecting an inert gas such as CO2 (reduce oxygen);
• Excavating the burning material (displacing fuel) and then extinguishing it
in small controlled areas; and
• Applying extinguishing agents that will interfere with and inhibit the
combustion process at the molecular level (break the chemical reaction).
1.7.5 Fires Within Disposal Areas
Fires within the landfill disposal areas will be limited by the use of periodic cover
as a fire break and control of "hot" loads entering the landfill. Trained personnel
at the scale house will turn away trucks containing waste that is suspected to be
hot. If a hot load is placed on the working face, then the load will be spread as
thin as possible and cover soil will be immediately placed on the waste to
extinguish the fire.

In general, fires that break out close to the surface of the disposal area should be
excavated and smothered with cover material. Deep fires should be smothered
out by placing moist soil on the surface and by constructing soil barriers around
the fire. Where the smothering technique fails, the burning material must be
excavated and smothered or quenched with water once the burning material is
brought to the surface. Water is usually not effective unless it can be directly
applied to the burning material.
1.7.6 Notification
The Operator will verbally notify the DWM (Section 1.2.3) within 24 hours of
discovery of a fire within any landfill disposal area. In addition, written
documentation describing the fire, the actions carried out to extinguish the fire,
and a strategy for preventing future occurrences will be provided to the DWM
within 15 days following any such occurrence on the Fire Occurrence
Notification Form included in Appendix A.
1.7.7 Coordination With Local Fire Department
A copy of this Operations Manual will be filed with the local fire department
including all contact information for the facility.
1.8 Severe Weather Conditions
Unusual weather conditions can directly affect the operation of the facility. Some of
these weather conditions and recommended operational responses are as follows.
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1.8.1 Ice Storms
An ice storm can make access to the facility dangerous, prevent movement or
placement of cover soil, thus, may require closure of the landfill and reclamation
area until the ice is removed or has melted. The determination to discontinue
activities due to inclement weather conditions will be made by the Landfill
Manager.
1.8.2 Heavy Rains
Exposed soil surfaces can create a muddy situation in some portions of the
facility during rainy periods. The control of drainage and use of crushed stone on
unpaved roads should provide all-weather access for the site and promote
drainage away from critical areas. In areas where the aggregate surface is
washed away or otherwise damaged, new aggregate should be used for repair.

Intense rains can affect newly constructed drainage structures such as swales,
diversions, cover soils, and vegetation. After such a rain event, inspection by
facility personnel will be initiated and corrective measures implemented to
repair any damage found before the next rainfall.
1.8.3 Electrical Storms
The open area of a landfill is susceptible to the hazards of an electrical storm. If
necessary, facility activities will be temporarily suspended during such an event.
Refuge will be sought as necessary in on-site buildings or in rubber-tired
vehicles.
1.8.4 Windy Conditions
Facility operations during a particularly windy period may require that the
working face be temporarily shifted to a more sheltered area. When this is done,
the previously exposed face will be immediately covered with cover materials.
1.8.5 Violent Storms
In the event of hurricane, tornado, or severe winter storm warning issued by the
National Weather Service, facility operations may be temporarily suspended until
the warning is lifted. Equipment will be properly secured. A radio capable of
tuning to NOAA Weather Radio-Providence shall be periodically monitored by
landfill personnel.
1.9 Equipment Requirements
The Operator will make available the equipment required to perform the necessary
facility activities. Periodic equipment maintenance and minor and major repair work will
be performed at designated maintenance zones.
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The anticipated equipment requirements for operation and maintenance of the site are
listed in the following table. These may vary based on volume coming into the facility for
recovery or disposal.

Table 1: Equipment Requirements

Description Primary Function (Allocation)
1) Compactors (1) Waste placement and compaction
2) Dozers (1) Stripping and grading of borrow areas, fine grading,
slope work, and site cleanup
3) Water Truck (1) Dust control
4) Excavator (1) General site work, loading and placement of cover
material, sediment control cleanup
5.) Articulated Dump Truck (1) Hauling soils and other materials
6) Other Equipment As needed.
1.10 Personnel Requirements
At least one responsible individual trained and certified in facility operations will be
present at all times during all operating hours of the facility. An attendant will be
present to oversee the loading and unloading of waste. Annually, a supervisor, certified
as a Manager of Landfill Operations (MOLO) by the Solid Waste Association of North
America (SWANA) will train each facility employee. As part of this training, personnel
learn to recognize loads which may contain prohibited wastes.

The anticipated personnel requirements for operation and maintenance of the site are
listed in the following table. The numbers of site personnel can be adjusted based on
volume of waste received for disposal.

Table 2: Personnel Requirements

Description Primary Function (Allocation)
1) General Manager (1) Overall management of the facility
2) Operations Manager (1) Manage facility operations
3) Scalehouse Attendant (1) Receiving and weight for incoming loads
4) Operators (4) Management of workface, inspect cover, cover
placement
5) Temp Labor (as needed) General labor and operational staff around the site
1.11 Health and Safety
Facility operations were developed with the health and safety of the operating staff,
customers, and neighbors in mind. Prior to commencement of operations of the facility,
a member of the operating staff will be designated site safety officer. This individual,
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together with the facility's management will modify the site safety and emergency
response program to remain consistent with SWANA and Occupational Safety and
Health Administration (OSHA) guidance.

Safety equipment provided includes equipment rollover protective cabs, seat belts,
audible reverse warning devices, hard hats, safety shoes, and first aid kits. Facility
personnel will be encouraged to complete the American Red Cross Basic First Aid
Course. Other safety requirements may also be implemented as designated by the
Owner and Operator.

Facility employees training in health and safety by supervisory staff will be documented.
All on-the-job injuries are required to be reviewed by a doctor.

The following are some general recommendations for the health and safety of workers:
1.11.1 Personal Hygiene
The following items are recommended as a minimum of practice:

• Wash hands before eating, drinking, or smoking.
• Wear personal protective equipment as described in Section 1.11.2.
• Wash, disinfect, and bandage ANY cut, no matter how small. Any break in
the skin can become a source of infection.
• Keep fingernails closely trimmed and clean (dirty nails can harbor
pathogens).
1.11.2 Personal Protective Equipment
Personal Protective Equipment (PPE) must be evaluated as to the level of
protection necessary for particular operating conditions and then made available
to facility employees. The list below includes the PPE typically used and/or
required in a solid waste management facility workplace.

• Safety shoes with steel toes.
• Noise reduction protection should be used in areas where extended
exposure to continuous high decibel levels is expected.
• Disposable rubber latex or chemical resistant gloves for handling and/or
sampling of waste materials.
• Dust filter masks.
• Hard hats (in designated areas)
• Portable eyewash.
• Safety goggles.
• Safety vests.

Following use, PPE’s should be disposed of or adequately cleaned, dried, or
readied for reuse.
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1.11.3 Mechanical Equipment Hazard Prevention
Equipment should be operated with care and caution. Safety equipment such as
horns, backup alarms, and lights should be functional. A Lockout-Tagout
program will be used to identify equipment in-need-of or under repair and insure
that operation is “off-limits” prior to maintenance or repair. Operators will be
trained in proper equipment operation.
1.11.4 Employee Health and Safety
Some general safety rules are:

• Consider safety first when planning and conducting activities.
• Review the equipment O&M manual(s) prior to attempting
repairs/changes.
• Remember the buddy system for repair of mechanical equipment.
• Post emergency contact phone numbers.
• Provide easy and visible access to the Right to Know materials.
• Provide easy and visible access to first aid kits and fire extinguishers.
1.11.5 Physical Exposure
Facility personnel may come in contact with the fluids, solids, and airborne
constituents found at the facility. Routine training should be conducted
regarding the individual and collective materials used at the facility and their
associated hazards. Training concerning safe work practices around these
potential exposures should cover the use of equipment and proper disposal
procedures.
1.11.6 Safety Data Sheets
Safety Data Sheets (SDS) will be collected on every waste (if available and
appropriate) that enters the facility. Information will also be made available for
all chemicals stored on site for use at the facility. SDS sheets will be stored in a
location with the other Right to Know information for the site.

1.12 Utilities
Electrical power, water, telephone, and restrooms will be provided at the scale house
and site office.

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1.13 Recordkeeping Program
The Operator will maintain the following records in an operating record at the landfill:

A. Current permit(s) (Permit to Construct, Permit to Operate, etc.);
B. Current operations manual/plan and engineering plan;
C. Inspection reports;
D. Audit and compliance records;
E. Annual landfill reports (including survey and other documentation related to
airspace usage);
F. Waste inspection records (Section 2.4.1);
G. Daily tonnage records and disposal records maintained at the scale house -
including source of generation;
H. Waste determination records;
I. Quantity, disposal location, generator, and special handling procedures for all
special wastes disposed of at the site (if applicable);
J. List of generators and haulers that have attempted to dispose of restricted
wastes;
K. Employee training procedures and records of training completed;
L. Groundwater monitoring and surface water quality information (See the current
Water Quality Monitoring Plan) including:
1. Monitoring well construction records;
2. Sampling dates and results;
3. Statistical analyses; and
4. Results of inspections, repairs, etc.
M. LFG monitoring results and remedial measures as required (see the current LFG
Monitoring Plan);
N. Closure and post-closure information, where applicable, including:
1. Notification of intent to close;
2. Testing;
3. Certification; and
4. Recording.
O. Cost estimates or financial assurance documentation;
P. A notation of the date and time of final cover placement;
Q. OSHA 300 logs;
R. Asbestos disposal records;
S. Concrete Grinding Logs
T. Laboratory Testing identifying soil or mulch properties such as density and
gradation (if performed)
The operating record will be kept up to date by the Operator or his designee. It will be
presented on request to the DWM for inspection. A copy of this Operations Manual will
be kept at the facility and will be available for use at all times.
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2.0 WASTE HANDLING OPERATIONS
This section describes the required waste handling operations for the WI High Point LF.
2.1 Acceptable Waste
The WI High Point LF will only accept waste that is generated from the approved service
areas (Figure 3) and is consistent with the North Carolina solid waste regulations and
general conditions established in the operating permit. The acceptance of waste
materials must satisfy the following definitions:

• Construction and Demolition Debris Waste: as defined in G.S. 130A-290 (a)(4)
means solid waste resulting solely from construction, remodeling, repair or
demolition operations on pavement, buildings, or other structures, but does not
include inert debris, land-clearing debris or yard waste.
• Inert Debris Waste: as defined in G.S. 130A-290 (a)(14) means solid waste which
consists solely of material that is virtually inert and that is likely to retain its
physical and chemical structure under expected conditions of disposal, materials
such as unpainted rock, brick, concrete, concrete block, uncontaminated soil,
rock, and gravel.
• Land Clearing and Inert Debris Waste: as defined in G.S. 130A-290 (a)(15) means
solid waste that is generated solely from land-clearing activities, such as yard
trash, stumps, and tree trunks.
• Asphalt: in accordance with G.S. 130-294 (m).
• Asbestos: as defined by 40 CFR 61.
• Other Waste: other solid waste as approved by the Solid Waste Section of the
Division of Waste Management.

In addition, the special wastes described in Section 2.4.3 may also be accepted at this
facility.
2.2 Prohibited Wastes
In accordance with 15A NCAC 13B .0542(e), municipal solid waste (MSW), liquid or
industrial waste and yard trash will not be accepted at the facility. Shingles identified as
asbestos containing materials (ACMs) as defined by 40 CFR 61 will not be processed at
the reclamation pad. Shingles will be managed in accordance with the procedures
described in Section 3.4. Hazardous waste as defined by 15A NCAC 13A including
hazardous waste from conditionally exempt small quantity generators will not be
accepted at the facility. Wastes as described within NC General Statute §130A-309.10(f)
shall not be accepted, except wooden pallets which may be disposed in construction and
demolition debris per §130A-309.10(f)(12). Barrels and drums shall not be accepted
unless they are empty and perforated with no materials or wastes contained within. No
polychlorinated biphenyl (PCB) waste will be accepted. WI High Point Landfill, LLC will
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implement a waste screening program described in Section 2.3, to prohibit these types
of waste.

WI High Point Landfill, LLC will not knowingly dispose of C&D waste from areas by which
local government ordinances prohibit the disposal of C&D waste.

Asbestos waste may be accepted by the facility if handled according to Section 2.4.3.1.
2.3 Waste Screening Programs
To assure prohibited wastes are not entering the landfill facility, screening programs
have been implemented. Waste received at the scale house entrance and directed to the
working face or reclamation area is inspected by trained personnel. These individuals
have been trained to spot indications of unacceptable and suspicious wastes, including:
hazardous placarding 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 are an ongoing
part of the facility operation.
2.3.1 Waste Receiving and Inspection
Vehicles must stop at the scale house located near the entrance of the facility
and visitors are required to sign-in. Waste transportation vehicles are weighed
and the content of the load assessed. The scale attendant(s) requests a waste
description from the vehicle driver to ensure that unacceptable waste is not
allowed into the landfill. The attendant(s) then visually checks the vehicle as it
crosses the scale. Signs informing users of the acceptable and unacceptable
waste types are posted at the scale house or in the vicinity of the entrance to the
site. Once passing the scales, the vehicles containing recyclable materials are
routed to the recovery area and vehicles containing C&D wastes are routed to the
landfill.

Vehicles are randomly selected for screening on a regular basis, depending on
personnel availability. At least one vehicle per week, but not less than 1% by
weight of the waste stream entering the facility (based on the previous week’s
total), will be randomly selected by inspection personnel. A random truck
number and time will be selected (e.g., the tenth load after 10:00 a.m.) on the day
of inspections. However, if something looks suspicious is spotted in any waste
load, that load is inspected further.

Selected vehicles are directed to an area of intermediate cover adjacent to the
working face where the vehicle will be unloaded. Waste is carefully spread using
suitable equipment. An attendant trained to identify wastes that are
unacceptable at the landfill inspects the waste discharged at the screening site.
If unacceptable waste is found, the load will be isolated and secured by flagging,
barrels, cones or flags around the area. All random waste inspections will be
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documented by landfill staff using the waste screening form provided in
Appendix B.

Unacceptable wastes that are nonhazardous will be removed from the C&D area
and removed from the facility. For unacceptable wastes that are hazardous, the
Hazardous Waste Contingency Plan outlined in Section 2.3.2 will be followed.
Written notification will be provided to DWM within 15 days following the incident.
To determine the liquid content of the waste, a liquid determination will be
performed by the paint filter test (see Appendix C for apparatus and
procedures). The hauler is responsible for removing unacceptable waste from
the landfill property. If no unacceptable waste is found, the load will be pushed
to the working face and incorporated into the daily waste cell.

The removal of solid waste from any landfill unit is prohibited except upon
notification of the DWM (see Section 1.2.3). Regardless, the general public is
prohibited from any waste removal activities from any landfill unit.
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3.0 HAZARDOUS WASTE CONTINGENCY PLAN
In the event that identifiable hazardous waste or waste of questionable character
is detected at the recovery center or landfill, appropriate equipment, protective
equipment, personnel, and materials as necessary will be employed to isolate
the wastes. DWM will be notified immediately (see Section 1.2.3) that an
attempt was made to dispose of hazardous waste at the facility. If the vehicle
attempting disposal of such waste is known, all attempts will be made to prevent
that vehicle from leaving the site or, if the vehicle has left 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 facility.

The facility staff will assist the DWM as necessary and appropriate in the removal
and disposition of the hazardous waste and in the prosecution of responsible
parties. If needed, the hazardous waste will be covered with either on-site soils
or other tarping material 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 using the landfill.

Should an incident where hazardous waste is found at the landfill occur, the
event will be documented by landfill staff using the waste screening form
provided in Appendix B.

Records of information gathered as part of the waste screening programs will be
maintained at the landfill site during its active life and as long as required by WI
High Point, LLC and DWM.
3.1 Waste Disposal
3.1.1 Access
Access road location during waste placement will be determined by operations
personnel to reflect waste placement strategy.
3.1.2 General Procedures
Waste transportation vehicles will arrive at the working face at random intervals.
There may be a number of vehicles unloading waste at the same time, while
other vehicles are waiting. To maintain control over the unloading of waste, a
certain number of vehicles will be allowed on the working face at a time. The
actual number will be determined by the truck spotter or equipment operator.
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
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conducted in a manner which will encourage the efficient movement of
transportation vehicles to and from the working face, and to expedite waste
unloading.

The approach 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. Following completion of the unloading
operation, the transportation vehicles will immediately leave the working face
area. Personnel will direct traffic 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 maintain the appearance of the site, control windblown waste, and
minimize the amount of cover required each day. Normally, only one working
face will be active on any given day, with deposited waste in other areas covered
by either periodic or final cover, as appropriate.

Solid waste placement and compaction procedures include: vehicle unloading,
waste spreading into adequately sized lifts, and compaction on relatively flat
slopes (i.e. 5H:1V max.), in two-foot intervals, using a minimum number of three
full passes.

The use of portable signs with directional arrows and portable traffic barricades
will facilitate waste unloading to the designated disposal locations. These signs
and barricades will be placed along the access route to the landfill working face
or other designated disposal areas which may be established.
3.1.3 Special Waste Management
3.1.3.1 Asbestos Management
WI High Point, LLC may dispose of regulated asbestos containing
materials (RACM) within the C&D landfill. RACM means:

(a) Friable asbestos material;
(b) Category I nonfriable asbestos-containing material (ACM) that has
become friable;
(c) Category I nonfriable ACM that will be or has been subjected to
sanding, grinding, cutting, or abrading; or
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(d) Category II nonfriable ACM that has a high probability of becoming
or has become crumbled, pulverized, or reduced to powder by the
forces expected to act on the material in the course of demolition
or renovation operations regulated by this subpart.

Asbestos containing materials are further defined as:
• Category I nonfriable asbestos-containing material (ACM) means
asbestos-containing packings, gaskets, resilient floor covering, and
asphalt roofing products containing more than 1 percent asbestos
as determined using the method specified in appendix E, subpart E,
40 CFR part 763, section 1, Polarized Light Microscopy.
• Category II ACM means any material, excluding Category I
nonfriable ACM, containing more than 1 percent asbestos as
determined using the methods specified in appendix E, subpart E,
40 CFR part 763, section 1, Polarized Light Microscopy that, when
dry, cannot be crumbled, pulverized, or reduced to powder by hand
pressure.
• Nonfriable Asbestos-containing material means any material
containing more than 1 percent asbestos as determined using the
method specified in appendix E, subpart E, 40 CFR part 763, section
1, Polarized Light Microscopy that, when dry, cannot be crumbled,
pulverized, or reduced to powder by hand pressure. This material is
non-regulated.

Asbestos will only be accepted if it has been processed and packaged in
accordance with State and Federal (40 CFR 61) regulations. Disposal of
asbestos waste must be in accordance with 15A NCAC 13B .0542(c).
Asbestos will arrive at the site in vehicles that contain only the asbestos
waste and only after advance notification by the generator.

Once the hauler brings the ACM to the landfill, the hauler will be directed
to the designated asbestos disposal area by operations personnel. The
designated disposal area will be prepared by operations personnel 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.
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The landfill staff will use the Waste Placement Grid (Figure 4) to record
the approximate location and elevation of the asbestos waste once cover
is in-place. The Landfill Manager or other supervisory staff will review
pertinent disposal and location information to assure compliance with
regulatory requirements and enter the information into the Operating
Record.

Once disposal and recording for asbestos waste is completed, the
disposal area may be covered with waste. No excavation into designated
asbestos disposal areas will be permitted.
3.1.4 Periodic Cover
When the waste disposal area exceeds one-half acre or at the completion of
waste placement each week or sooner, a 6 inch layer of earthen material will be
placed over the exposed waste. This periodic cover is intended to control vectors,
fire, odors, and blowing debris.
3.2 Height Monitoring
The landfill staff will monitor landfill top and side slope elevations. When such
elevations approach the grades shown in the facility Permit Drawings- S3 (Phase 3 -
Final Grading Plan), the final top of waste grades will be staked to limit over placement
of waste.
3.3 Recordkeeping
The facility will maintain an accurate record of the amount of solid waste received at the
landfill. On or before August 1 annually, the operator will submit a facility report to the
DWM and to each county from which waste was received. Minimally, the facility report
will document the waste in tons received on a monthly basis, the waste origin, the waste
type received, the tons diverted, and the tons disposed. A measurement of the volume
utilized in the landfill cells must be performed during the first and second quarter of
each calendar year.

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4.0 RECOVERY AREA OPERATIONS
The facility’s material recovery operation is intended to segregate co-mingled recyclable
and/or reusable materials from the site’s waste stream and temporarily store these
materials within the permitted facility. The material recovery operation will occur within
the reclamation area and recovered materials will be relocated within this area due to
space constraints from time to time. Material recovery operations will only occur within
the permitted waste limits (Figure 5). Temporary material storage (prior to the end use)
may be necessary in adjacent areas where waste processing has not yet begun, but still
within the permitted limits of active area.
4.1 Access
Traffic will be clearly directed to the appropriate processing or recovery area. The
traffic speed on the site should be less than 10 MPH. Rutting of gravel roadway surfaces
must be repaired by the placement of additional gravel on the roadway and not solely by
grading the rut. This will maintain the separator geotextile placed below most gravel
roadway surfaces.
4.2 Recovered Material Management
Only waste loads which are predominantly recyclable materials will be diverted to the
sorting area. It is anticipated that up to 20% of the C&D waste stream (by weight)
delivered to the site will be segregated, recovered, recycled and/or reused. Recovered
materials that are removed from the waste stream for re-use on-site (i.e., processed
wood waste/mulch, crushed concrete, etc.) will be re-weighed on the site’s scales prior
to being used on-site. Materials that are not recoverable, but which were received
within the sorting area, will be reloaded and hauled to the landfill for proper disposal.
4.3 General Procedures
The processing and recovery operations will be conducted in accordance with the
approved Operation Plan and conditions of the Solid Waste Permit issued by the DWM.

Refer to Figure 6 for a flowchart outlining overall facility operations.

Facility operations are anticipated as follows:

1. Collection vehicles delivering waste to the facility will enter through the main
entrance on Riverdale Drive;
2. Vehicle will pass over the scales, be weighed, and inspected;
3. Vehicles will be directed to the tipping area or storage area;
4. Source separated wood pallets and cardboard from non-C&D waste sources
must not be unloaded onto the tipping floor. Wood pallets must be unloaded
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onto the sorted clean wood pile or into a container. Cardboard must be
unloaded into a storage container.
5. By-pass materials directed to the storage area will include untreated wood,
brick/block, shingles, metal, and other miscellaneous materials. With the
exception of shingles, by-pass materials will not be subjected to secondary
screening at the tipping floor or the pick line. Shingles will not be processed
until asbestos-free testing verification results are received.
6. Clean wood materials will be sold off-site or stockpiled for on-site wood
grinding. Ground wood will be stockpiled on-site for offsite sales.
7. The attendant will direct vehicles to a designated area of the tipping floor.
8. Once the vehicle is in position, the waste load will be discharged directly onto
the tipping floor. A spotter will inspect the discharged waste. If no
unacceptable materials are identified in the load, the materials will be
processed as recyclable materials.
9. Heavy equipment will load the materials onto the screener where metals, fine
materials, and unacceptable content can be removed. Unacceptable materials
and fines recovered by the screening equipment will be transported to the onsite
landfill. Recovered metals will be sold off-site.
10. Recoverable materials will be conveyed to the pick line. Hand separation of
materials will occur, as needed. Sorted recoverable materials will be
transferred to the storage areas or directly into trailers for off-site sales.
11. Discarded materials will be segregated and stockpiled for re-loading and
hauling to the on-site landfill.
4.4 Shingles Management
WI High Point Landfill, LLC accepts source separated shingles at the recycling facility.
No grinding or physical manipulation of shingles other than sorting and reclaiming
metals from these materials occurs at the facility.

Each transportation vehicle delivering shingles for recycling is weighed and inspected at
the scale house. A secondary screening occurs at the processing area. Vehicles
containing source-separated shingles are directed to the shingles storage area. Testing
for ACM is provided by S.T. Wooten. WI High Point Landfill, LLC does not process any
loads containing shingles until the ACM content is known and verification from S.T.
Wooten is received confirming that the shingles do not contain asbestos. Shingles that
cannot be processed due to possible ACM content are reloaded and transported to the
landfill for disposal.

Tested and asbestos-free shingles delivered to the storage area are reloaded and
transported to the screener and conveyor. Metals and fines are removed from the
shingles as the material is conveyed to the pick line. A water line is available to control
dust and keep the shingles moist, as needed. The shingles are sorted and placed into
containers or stockpiled for off-site sales. The recovered metal materials are placed
into containers for off-site sales. The fines are reloaded into containers and transported
to the on-site landfill for disposal.
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A shingle supplier certification form is included as Appendix D.
4.4.1 Asbestos Management
WI High Point Landfill, LLC does not process any known or recognized shingles
containing asbestos materials. For unacceptable waste that is discovered, the
Hazardous Waste Contingency Plan outlined in Section 2.3.2 will be followed.

At least one individual trained in the provisions of the National Emission
Standards for Hazardous Air Pollutants (NESHAP) as an Asbestos Abatement
Contractor/Supervisor will be present during facility operating hours. This
individual will receive annual refresher training with respect to Asbestos
Hazardous Emergency Response Act (AHERA). In addition, site employees will
receive annual training on asbestos awareness and the identification of ACMs.
4.4.2 Air Quality
Air quality and dust control for the materials processing operation are controlled
by a water line located near the conveyor system. This water line will be utilized
as needed to adequately dampen the material to control air borne particles.

A water truck will be used to control the generated dust and overall site
appearance.
4.5 Recovered Material Storage
Except for wood, concrete, and inert material, recovered materials must be placed in
containers by the end of each operating day unless covered by a tarp to prevent leaching
by rainfall. Recovered materials placed in containers must be removed from the site
once the container is full.

Non-recoverable materials must be placed in storage containers or in trucks at the end
of each operating day. Windblown materials must be collected at the end of the day and
no material may be allowed to leave the facility boundary. Storage containers containing
non-recoverable materials must be disposed in the on-site landfill at the end of the
operating day.
4.6 Recovered Materials and End Uses
The recovered materials will generally be removed by hand. Heavy equipment and
screeners will assist with materials separation, as needed. Materials will be placed into
containers or stockpiles, processed, transported for disposal, and either re-used on-site
or sold. Recovered materials will not be stored speculatively. The anticipated wastes to
be recovered and their anticipated end uses include the following:

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Table 3: Recovered Materials and End Uses

RECOVERED WASTE

GENERAL OPERATION

ANTICIPATED END USES
Corrugated Cardboard
Source separated delivery or
segregated by hand; and placed
into closed (covered) roll-off box
(not baled).

Sold off-site.

Clean Wood Waste (no
painted, stained, or
otherwise contaminated
wood)
Source separated or segregated
with heavy equipment; metal
separated (magnets); and
placed into roll-off box or
stockpiled; wood will be chipped
and/or ground on-site or
shipped off-site for grinding.
Sold off-site, or used for on-
site mulching, erosion control.

Removed metal will be sold off-
site.

Scrap Metals
Source separated or segregated
by hand and/or heavy equipment
and placed into roll-off box.

Removed metal sold off-site.

Gypsum Wallboard
Segregated by hand and/or
heavy equipment and placed
into roll-off box.

Sold off-site.

Clean Concrete

Source separated or segregated
with heavy equipment; rebar
separated (magnets); directly
delivered to landfill or
stockpiled on-site.

Used for on-site road
aggregate, delivered to landfill,
or sold off-site.

Removed metal sold off-site.

Shingles
Materials received as
segregated loads or separated
with heavy equipment; metal
separated (magnets); and
placed into roll-off box or
stockpiled

Shingles sold off-site.

Removed metal sold off-site.

4.7 Safety
Equipment operating in the recycling area will be equipped with back-up alarms.
Appropriate Personal Protective Equipment will be worn by workers in the recycling
area, including two-way radios between the workers and equipment operators.

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Asbestos Containing Waste (ACW) or suspected ACW will not be hauled to, or dumped
into, the sorting area. ACW will be buried in accordance with applicable North Carolina
and NESHAP requirements.
4.8 Equipment
Anticipated equipment to be used in and around the recycling area will include:

• one small rubber-tired loader, skid-steer, or bobcat
• one small excavator.

Other equipment may be added as needed. Containers will generally consist of steel
roll-off boxes, both covered and open, depending on the contents, and will be stored in
proximity to the reclamation area. Cardboard and wallboard containers will be covered.
Containers will generally be removed from the site as they are filled.
4.9 Personnel
Based on permitted site tonnage, up to 3 site personnel, including equipment operators,
are anticipated for operations within the reclamation area of the site.
4.10 Recordkeeping
The facility will maintain accurate records of daily waste and recovered material
activities. Daily records will document the weight of waste received and recovered and
the origins of the loads. Additionally, the operator will maintain monthly records of the
amount of recovered materials sold or used on-site and the amount of waste
transported for disposal. Documentation of end-users/processors/recyclers of the
recovered materials will be maintained on-site.

On or before August 1 annually, the operator will submit a facility report to the DWM and
to each county from which waste was received. Minimally, the facility report will
document the tons of waste received on a monthly basis, the origin of the waste, the type
of waste received, the tons diverted, and the tons

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5.0 ENVIRONMENTAL MANAGEMENT
This section reviews the overall environmental management tasks required for the successful
operation of WI High Point LLC.
5.1 Erosion and Sedimentation Control
A separate erosion and sedimentation control plan is provided in the Erosion and
Sedimentation Control Plan (Attachment E) of the Permit Application. This plan
describes the engineered features and practices for preventing erosion and controlling
sedimentation at this site. The erosion and sediment control system consists of the
following major components:

1. Drainage Channels,
2. Diversion Berms (Side Slope Swales and Cap Diversion Berm),
3. Down Pipes, and
4. Sediment Basins/Traps.

The landfill side slopes are designed with 3H:1V slopes and diversion berms placed
along the slope. The berms are designed to keep water volumes and velocities low
enough to minimize erosion of the landfill cover. Maintenance of the cover system will
involve periodic mowing and repair of any erosion problems and bare spots. These
items will be inspected at least once a month and after any significant rainfall events.

The down pipes are designed to carry concentrated flows of surface water off of the
landfill. The down pipes will be inspected at least once a month and after any significant
rainfall event.

Additional erosion control measures have been implemented within the drainage
channels and at points of stormwater discharge. Final cover should be inspected
regularly for erosion damage and promptly repaired.

Stormwater run-off from the C&D landfill is conveyed to sediment basins and traps.
These structures should be inspected regularly for sediment build-up or erosion
damage and should be cleaned out, at a minimum, when sediments fill the lower half of
each structure.
5.1.1 Stormwater Diversion in Constructed Cells
In accordance with 15A NCAC 13B .0542(l) surface water shall be diverted from
the operational area or not be impounded over or in waste and waste shall not be
placed in standing water. Collected stormwater within the cell shall be removed
by pumping low areas.

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Particular care is required to ensure that surface water coming from the active
face, e.g. having potential contact with the waste is allowed to percolate into the
underlying waste. Only run-off from waste surfaces that have received adequate
cover is not considered leachate and should be directed to the stormwater
drainage system, where practical.
5.2 Groundwater Monitoring
A separate water quality management plan has been prepared for the site under a
separate cover (Attachment L). Groundwater monitoring and regulatory reporting will
be completed in accordance with this plan.
5.3 Landfill Gas Control
A landfill gas control and monitoring plan has been prepared for the site and is
presented in Landfill Gas Management Plan (Attachment M). Landfill gas monitoring
and regulatory reporting will be completed in accordance with this plan.
5.4 Litter Control
The vegetative trees/brushes act as a barrier to keep litter contained within the site and
a litter control crew will pick up litter around the site and on access roads routinely as
required.
5.5 Vector Control
Due to the nature of the waste disposed in this landfill, vector control is not expected to
be of concern.
5.6 Odor Control
Due to the nature of the waste disposed in this landfill, odor is not expected to be of
concern.
5.7 Dust Control
Dust related to waste hauler traffic on the access roads will be minimized by using a
water truck to limit dust on the gravel portion of the road. Dust generated by excavation
of cover soil will be limited by watering the cut soil areas if accessible to the water truck.
5.8 Interim Cover
In addition to the occasional placement of the 6 inches of earthen material over the
exposed waste, an additional 12 inches of earthen cover should be placed on waste
surfaces that have not received waste in 30 days but are below final elevation. This
intermediate cover should be graded and seeded such that precipitation run-off is
channeled to the stormwater collection system.
DocuSign Envelope ID: 3FCB3572-B017-4254-82D2-BC5574429A81

WI High Point C&D Landfill Operations Manual
May 2016 Page 26
5.8.1 Interim Cover Monitoring
Routine inspections of the entire site will include monitoring the interim cover to
ensure the adequacy of the vegetative protective cover and to identify potential
erosion concerns. Corrective actions will be implemented to address identified
areas of concern.

DocuSign Envelope ID: 3FCB3572-B017-4254-82D2-BC5574429A81
SITE LOCATION MAP
NOT TO SCALE
STANDARD DETAIL CALLOUT
SECTION REFERENCED
SHEET WHERE SECTION IS PRESENTED
SHEET SET REVISION NUMBER
STANDARD DETAIL LABEL AND CALLOUT
DETAIL REFERENCED
STANDARD SECTION LOCATION
CALLOUT (SHEET AND DETAIL)
STANDARD REVISION
CALLOUT (SHEET AND DETAIL)
SHEET WHERE DETAIL
IS PRESENTED
SHEET WHERE DETAIL
IS PRESENTED
DETAIL REFERENCED
SITE LOCATION
WI HIGH POINT LANDFILL, LLC
HIGH POINT, NORTH CAROLINA
HIGH POINT C&D LANDFILL PHASE 3
PERMIT TO CONSTRUCT DRAWINGS
MAY 2016
A WASTE INDUSTRIES COMPANY
SEAL
SEAL
Electronic files are instruments of service provided by Smith
Gardner, Inc. for the convenience of the intended recipient(s), and
no warranty is either expressed or implied.  Any reuse or
redistribution of this document in whole or part without the
written authorization of Smith Gardner, Inc., will be at the sole
risk of the recipient.  If there is a discrepancy between the
electronic files and the signed and sealed hard copies, the hard
copies shall govern.  Use of  any electronic files generated or
provided by Smith Gardner, Inc., constitutes an acceptance of
these terms and conditions.
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SMITH
14 N. Boylan Avenue, Raleigh NC 27603
NC LIC. NO. C-0828 (ENGINEERING)
919.828.0577
GARDNER+
REV.DATE DESCRIPTION
© 2016 Smith Gardner, Inc.
1 10/16 RESPONSE TO NCDEQ
  COMMENTS DATED 10/5/16

NOT FOR CONSTRUCTION
PERMIT ISSUE
SHEET NO.DRAWING NO.DRAWING TITLE REVISION
1 -TITLE - COVER SHEET
2 S1 EXISTING CONDITIONS
3 S2 PHASE 3 SUBGRADE GRADING AND DRAINAGE PLAN
4 S3 PHASE 3 FINAL COVER GRADING AND DRAINAGE PLAN
5 EC1 EROSION AND SEDIMENTATION CONTROL DETAILS (SHEET 1 OF 3)
6 EC2 EROSION AND SEDIMENTATION CONTROL DETAILS (SHEET 2 OF 3)
7 EC3 EROSION AND SEDIMENTATION CONTROL DETAILS (SHEET 3 OF 3)
8 FC1 FINAL COVER DETAILS
9 X1 ENGINEERING CROSS SECTIONS (SHEET 1 OF 2)
10 X2 ENGINEERING CROSS SECTIONS (SHEET 2 OF 2)
11 P1 PHASING PLAN
DocuSign Envelope ID: 3FCB3572-B017-4254-82D2-BC5574429A81
10/14/2016
PROJECT TITLE:
DRAWING TITLE:
REV.DATE DESCRIPTION
DESIGNED:
DRAWN:
APPROVED:
PROJECT NO:
SCALE:
FILENAME:
PREPARED BY:
PREPARED FOR:
SHEET NUMBER:DRAWING NUMBER:
DATE:
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SEAL
SEAL
SMITHGARDNER
ENGINEERS
+
14 N. Boylan Avenue, Raleigh NC 27603
NC LIC. NO. C-0828 (ENGINEERING)
919.828.0577
Electronic files are instruments of service provided by Smith
Gardner, Inc. for the convenience of the intended recipient(s), and
no warranty is either expressed or implied.  Any reuse or
redistribution of this document in whole or part without the
written authorization of Smith Gardner, Inc., will be at the sole
risk of the recipient.  If there is a discrepancy between the
electronic files and the signed and sealed hard copies, the hard
copies shall govern.  Use of  any electronic files generated or
provided by Smith Gardner, Inc., constitutes an acceptance of
these terms and conditions.
© 2016 Smith Gardner, Inc.

WI HIGH POINT
LANDFILL, LLC
(A WASTE INDUSTRIES COMPANY)

HIGH POINT C&D LANDILL
PHASE 3
PERMIT TO CONSTRUCT
PERMIT DRAWINGS

EXISTING CONDITIONS

C.T.S.
C.T.J.
WIHIGHPOINT 16-1
AS SHOWN
MAY 2016
WI-D1138
2 S1
1 10/16 RESPONSE TO NCDEQ
  COMMENTS DATED 10/5/16

NOT FOR CONSTRUCTION
PERMIT ISSUE
DocuSign Envelope ID: 3FCB3572-B017-4254-82D2-BC5574429A81
10/14/2016
PROJECT TITLE:
DRAWING TITLE:
REV.DATE DESCRIPTION
DESIGNED:
DRAWN:
APPROVED:
PROJECT NO:
SCALE:
FILENAME:
PREPARED BY:
PREPARED FOR:
SHEET NUMBER:DRAWING NUMBER:
DATE:
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SEAL
SEAL
SMITHGARDNER
ENGINEERS
+
14 N. Boylan Avenue, Raleigh NC 27603
NC LIC. NO. C-0828 (ENGINEERING)
919.828.0577
Electronic files are instruments of service provided by Smith
Gardner, Inc. for the convenience of the intended recipient(s), and
no warranty is either expressed or implied.  Any reuse or
redistribution of this document in whole or part without the
written authorization of Smith Gardner, Inc., will be at the sole
risk of the recipient.  If there is a discrepancy between the
electronic files and the signed and sealed hard copies, the hard
copies shall govern.  Use of  any electronic files generated or
provided by Smith Gardner, Inc., constitutes an acceptance of
these terms and conditions.
© 2016 Smith Gardner, Inc.

WI HIGH POINT
LANDFILL, LLC
(A WASTE INDUSTRIES COMPANY)

HIGH POINT C&D LANDILL
PHASE 3
PERMIT TO CONSTRUCT
PERMIT DRAWINGS

PHASE 3
SUBGRADE GRADING
AND DRAINAGE PLAN

C.T.S.
C.T.J.
WIHIGHPOINT 16-1
AS SHOWN
MAY 2016
WI-D1140
3 S2
1 10/16 RESPONSE TO NCDEQ
  COMMENTS DATE 10/5/16

NOT FOR CONSTRUCTION
PERMIT ISSUE
DocuSign Envelope ID: 3FCB3572-B017-4254-82D2-BC5574429A81
10/14/2016
PROJECT TITLE:
DRAWING TITLE:
REV.DATE DESCRIPTION
DESIGNED:
DRAWN:
APPROVED:
PROJECT NO:
SCALE:
FILENAME:
PREPARED BY:
PREPARED FOR:
SHEET NUMBER:DRAWING NUMBER:
DATE:
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SEAL
SEAL
SMITHGARDNER
ENGINEERS
+
14 N. Boylan Avenue, Raleigh NC 27603
NC LIC. NO. C-0828 (ENGINEERING)
919.828.0577
Electronic files are instruments of service provided by Smith
Gardner, Inc. for the convenience of the intended recipient(s), and
no warranty is either expressed or implied.  Any reuse or
redistribution of this document in whole or part without the
written authorization of Smith Gardner, Inc., will be at the sole
risk of the recipient.  If there is a discrepancy between the
electronic files and the signed and sealed hard copies, the hard
copies shall govern.  Use of  any electronic files generated or
provided by Smith Gardner, Inc., constitutes an acceptance of
these terms and conditions.
© 2016 Smith Gardner, Inc.

WI HIGH POINT
LANDFILL, LLC
(A WASTE INDUSTRIES COMPANY)

HIGH POINT C&D LANDILL
PHASE 3
PERMIT TO CONSTRUCT
PERMIT DRAWINGS

PHASE 3
FINAL COVER GRADING
AND DRAINAGE PLAN

C.T.S.
C.T.J.
WIHIGHPOINT 16-1
AS SHOWN
MAY 2016
WI-D1140
4 S3
1 10/16 RESPONSE TO NCDEQ
  COMMENTS DATED 10/5/16

NOT FOR CONSTRUCTION
PERMIT ISSUE
DocuSign Envelope ID: 3FCB3572-B017-4254-82D2-BC5574429A81
10/14/2016
PROJECT TITLE:
DRAWING TITLE:
REV.DATE DESCRIPTION
DESIGNED:
DRAWN:
APPROVED:
PROJECT NO:
SCALE:
FILENAME:
PREPARED BY:
PREPARED FOR:
SHEET NUMBER:DRAWING NUMBER:
DATE:
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SEAL
SEAL
SMITHGARDNER
ENGINEERS
+
14 N. Boylan Avenue, Raleigh NC 27603
NC LIC. NO. C-0828 (ENGINEERING)
919.828.0577
Electronic files are instruments of service provided by Smith
Gardner, Inc. for the convenience of the intended recipient(s), and
no warranty is either expressed or implied.  Any reuse or
redistribution of this document in whole or part without the
written authorization of Smith Gardner, Inc., will be at the sole
risk of the recipient.  If there is a discrepancy between the
electronic files and the signed and sealed hard copies, the hard
copies shall govern.  Use of  any electronic files generated or
provided by Smith Gardner, Inc., constitutes an acceptance of
these terms and conditions.
© 2016 Smith Gardner, Inc.

WI HIGH POINT
LANDFILL, LLC
(A WASTE INDUSTRIES COMPANY)

HIGH POINT C&D LANDILL
PHASE 3
PERMIT TO CONSTRUCT
PERMIT DRAWINGS

EROSION AND SEDIMENTATION
CONTROL DETAILS
(SHEET 1 OF 3)

C.T.S.
T.R.S.
WIHIGHPOINT 16-1
AS SHOWN
MAY 2016
WI-D1141
5 EC1

NOT FOR CONSTRUCTION
PERMIT ISSUE
DocuSign Envelope ID: 3FCB3572-B017-4254-82D2-BC5574429A81
10/14/2016
PROJECT TITLE:
DRAWING TITLE:
REV.DATE DESCRIPTION
DESIGNED:
DRAWN:
APPROVED:
PROJECT NO:
SCALE:
FILENAME:
PREPARED BY:
PREPARED FOR:
SHEET NUMBER:DRAWING NUMBER:
DATE:
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SEAL
SEAL
SMITHGARDNER
ENGINEERS
+
14 N. Boylan Avenue, Raleigh NC 27603
NC LIC. NO. C-0828 (ENGINEERING)
919.828.0577
Electronic files are instruments of service provided by Smith
Gardner, Inc. for the convenience of the intended recipient(s), and
no warranty is either expressed or implied.  Any reuse or
redistribution of this document in whole or part without the
written authorization of Smith Gardner, Inc., will be at the sole
risk of the recipient.  If there is a discrepancy between the
electronic files and the signed and sealed hard copies, the hard
copies shall govern.  Use of  any electronic files generated or
provided by Smith Gardner, Inc., constitutes an acceptance of
these terms and conditions.
© 2016 Smith Gardner, Inc.

WI HIGH POINT
LANDFILL, LLC
(A WASTE INDUSTRIES COMPANY)

HIGH POINT C&D LANDILL
PHASE 3
PERMIT TO CONSTRUCT
PERMIT DRAWINGS

EROSION AND SEDIMENTATION
CONTROL DETAILS
(SHEET 2 OF 3)

C.T.S.
T.R.S.
WIHIGHPOINT 16-1
AS SHOWN
MAY 2016
WI-D1141
6 EC2

NOT FOR CONSTRUCTION
PERMIT ISSUE
DocuSign Envelope ID: 3FCB3572-B017-4254-82D2-BC5574429A81
10/14/2016
PROJECT TITLE:
DRAWING TITLE:
REV.DATE DESCRIPTION
DESIGNED:
DRAWN:
APPROVED:
PROJECT NO:
SCALE:
FILENAME:
PREPARED BY:
PREPARED FOR:
SHEET NUMBER:DRAWING NUMBER:
DATE:
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SEAL
SEAL
SMITHGARDNER
ENGINEERS
+
14 N. Boylan Avenue, Raleigh NC 27603
NC LIC. NO. C-0828 (ENGINEERING)
919.828.0577
Electronic files are instruments of service provided by Smith
Gardner, Inc. for the convenience of the intended recipient(s), and
no warranty is either expressed or implied.  Any reuse or
redistribution of this document in whole or part without the
written authorization of Smith Gardner, Inc., will be at the sole
risk of the recipient.  If there is a discrepancy between the
electronic files and the signed and sealed hard copies, the hard
copies shall govern.  Use of  any electronic files generated or
provided by Smith Gardner, Inc., constitutes an acceptance of
these terms and conditions.
© 2016 Smith Gardner, Inc.

WI HIGH POINT
LANDFILL, LLC
(A WASTE INDUSTRIES COMPANY)

HIGH POINT C&D LANDILL
PHASE 3
PERMIT TO CONSTRUCT
PERMIT DRAWINGS

EROSION AND SEDIMENTATION
CONTROL DETAILS
(SHEET 3 OF 3)

C.T.S.
T.R.S.
WIHIGHPOINT 16-1
AS SHOWN
MAY 2016
WI-D1141
7 EC3

NOT FOR CONSTRUCTION
PERMIT ISSUE
DocuSign Envelope ID: 3FCB3572-B017-4254-82D2-BC5574429A81
10/14/2016
PROJECT TITLE:
DRAWING TITLE:
REV.DATE DESCRIPTION
DESIGNED:
DRAWN:
APPROVED:
PROJECT NO:
SCALE:
FILENAME:
PREPARED BY:
PREPARED FOR:
SHEET NUMBER:DRAWING NUMBER:
DATE:
G:
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P
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SEAL
SEAL
SMITHGARDNER
ENGINEERS
+
14 N. Boylan Avenue, Raleigh NC 27603
NC LIC. NO. C-0828 (ENGINEERING)
919.828.0577
Electronic files are instruments of service provided by Smith
Gardner, Inc. for the convenience of the intended recipient(s), and
no warranty is either expressed or implied.  Any reuse or
redistribution of this document in whole or part without the
written authorization of Smith Gardner, Inc., will be at the sole
risk of the recipient.  If there is a discrepancy between the
electronic files and the signed and sealed hard copies, the hard
copies shall govern.  Use of  any electronic files generated or
provided by Smith Gardner, Inc., constitutes an acceptance of
these terms and conditions.
© 2016 Smith Gardner, Inc.

WI HIGH POINT
LANDFILL, LLC
(A WASTE INDUSTRIES COMPANY)

HIGH POINT C&D LANDILL
PHASE 3
PERMIT TO CONSTRUCT
PERMIT DRAWINGS

FINAL COVER
DETAILS

C.T.S.
T.R.S.
WIHIGHPOINT 16-1
AS SHOWN
MAY 2016
WI-D1141
8 FC1

NOT FOR CONSTRUCTION
PERMIT ISSUE
DocuSign Envelope ID: 3FCB3572-B017-4254-82D2-BC5574429A81
10/14/2016
SECTIONAA
PROJECT TITLE:
DRAWING TITLE:
REV.DATE DESCRIPTION
DESIGNED:
DRAWN:
APPROVED:
PROJECT NO:
SCALE:
FILENAME:
PREPARED BY:
PREPARED FOR:
SHEET NUMBER:DRAWING NUMBER:
DATE:
G:
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P
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SEAL
SEAL
SMITHGARDNER
ENGINEERS
+
14 N. Boylan Avenue, Raleigh NC 27603
NC LIC. NO. C-0828 (ENGINEERING)
919.828.0577
Electronic files are instruments of service provided by Smith
Gardner, Inc. for the convenience of the intended recipient(s), and
no warranty is either expressed or implied.  Any reuse or
redistribution of this document in whole or part without the
written authorization of Smith Gardner, Inc., will be at the sole
risk of the recipient.  If there is a discrepancy between the
electronic files and the signed and sealed hard copies, the hard
copies shall govern.  Use of  any electronic files generated or
provided by Smith Gardner, Inc., constitutes an acceptance of
these terms and conditions.
© 2016 Smith Gardner, Inc.

WI HIGH POINT
LANDFILL, LLC
(A WASTE INDUSTRIES COMPANY)

HIGH POINT C&D LANDILL
PHASE 3
PERMIT TO CONSTRUCT
PERMIT DRAWINGS

ENGINEERING
CROSS SECTIONS
(SHEET 1 OF 2)

C.T.S.
C.T.J.
WIHIGHPOINT 16-1
AS SHOWN
MAY 2016
WI-D1140
9 X1
1 10/16 RESPONSE TO NCDEQ
  COMMENTS DATED 10/5/16

NOT FOR CONSTRUCTION
PERMIT ISSUE
DocuSign Envelope ID: 3FCB3572-B017-4254-82D2-BC5574429A81
10/14/2016
SECTIONBB
PROJECT TITLE:
DRAWING TITLE:
REV.DATE DESCRIPTION
DESIGNED:
DRAWN:
APPROVED:
PROJECT NO:
SCALE:
FILENAME:
PREPARED BY:
PREPARED FOR:
SHEET NUMBER:DRAWING NUMBER:
DATE:
G:
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4
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1
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P
M
SEAL
SEAL
SMITHGARDNER
ENGINEERS
+
14 N. Boylan Avenue, Raleigh NC 27603
NC LIC. NO. C-0828 (ENGINEERING)
919.828.0577
Electronic files are instruments of service provided by Smith
Gardner, Inc. for the convenience of the intended recipient(s), and
no warranty is either expressed or implied.  Any reuse or
redistribution of this document in whole or part without the
written authorization of Smith Gardner, Inc., will be at the sole
risk of the recipient.  If there is a discrepancy between the
electronic files and the signed and sealed hard copies, the hard
copies shall govern.  Use of  any electronic files generated or
provided by Smith Gardner, Inc., constitutes an acceptance of
these terms and conditions.
© 2016 Smith Gardner, Inc.

WI HIGH POINT
LANDFILL, LLC
(A WASTE INDUSTRIES COMPANY)

HIGH POINT C&D LANDILL
PHASE 3
PERMIT TO CONSTRUCT
PERMIT DRAWINGS

ENGINEERING
CROSS SECTIONS
(SHEET 2 OF 2)

C.T.S.
C.T.J.
WIHIGHPOINT 16-1
AS SHOWN
MAY 2016
WI-D1140
10 X2
1 10/16 RESPONSE TO NCDEQ
  COMMENTS DATE 10/5/16

NOT FOR CONSTRUCTION
PERMIT ISSUE
DocuSign Envelope ID: 3FCB3572-B017-4254-82D2-BC5574429A81
10/14/2016
PROJECT TITLE:
DRAWING TITLE:
REV.DATE DESCRIPTION
DESIGNED:
DRAWN:
APPROVED:
PROJECT NO:
SCALE:
FILENAME:
PREPARED BY:
PREPARED FOR:
SHEET NUMBER:DRAWING NUMBER:
DATE:
G:
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3
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5
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P
M
SEAL
SEAL
SMITHGARDNER
ENGINEERS
+
14 N. Boylan Avenue, Raleigh NC 27603
NC LIC. NO. C-0828 (ENGINEERING)
919.828.0577
Electronic files are instruments of service provided by Smith
Gardner, Inc. for the convenience of the intended recipient(s), and
no warranty is either expressed or implied.  Any reuse or
redistribution of this document in whole or part without the
written authorization of Smith Gardner, Inc., will be at the sole
risk of the recipient.  If there is a discrepancy between the
electronic files and the signed and sealed hard copies, the hard
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© 2016 Smith Gardner, Inc.

WI HIGH POINT
LANDFILL, LLC
(A WASTE INDUSTRIES COMPANY)

HIGH POINT C&D LANDILL
PHASE 3
PERMIT TO CONSTRUCT
PERMIT DRAWINGS

PHASING PLAN

S.A.S.
C.T.J.
WIHIGHPOINT 16-1
AS SHOWN
MAY 2016
WI-D1170
11 P1

PHASE 3 PHASE 4
PHASE 6PHASE 5
NOT FOR CONSTRUCTION
PERMIT ISSUE
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10/14/2016