4117_A1SandrockCDLF_Response_to_comments_CQAPhase2B_DIN28444_20170905

1
Chao, Ming-tai
From:Garrett, David <[e-mail]>
Sent:Tuesday, September 05, 2017 2:51 PM
To:Chao, Ming-tai; Raup, Michael; '[e-mail]'
Cc:Mussler, Ed; Rice, Sarah M
Subject:RE: A-1 Sandrock CQCD Report
Attachments:Response to SWS emails 9-5-2017.pdf
Please see the attached Financial Assurance calculations. Thank you.

Please take note:
After Sept 11, my corporate email address will change: [e-mail]
All other contact info will remain the same. Thank you.

G. David Garrett, P.G., P.E.
Senior Engineer
Amec Foster Wheeler Environment & Infrastructure, Inc.
4021 Stirrup Creek Drive – Suite 100
Durham, North Carolina 27703
[e-mail]

Phone: [phone]
Direct line: 919-765-0070
Cell: 919-418-4375

From: Chao, Ming-tai [mailto:[e-mail]]
Sent: Wednesday, August 16, 2017 1:03 PM
To: Garrett, David <[e-mail]>; Raup, Michael <[e-mail]>;
'[e-mail]' <[e-mail]>
Cc: Mussler, Ed <[e-mail]>; Rice, Sarah M <[e-mail]>
Subject: RE: A-1 Sandrock CQCD Report

Gentlemen:

After conducting a quick research of the financial assurance/cost estimates for closure and post closure in the
approved PTC -Phases 2 Application (DIN 24958) for A-1 Sandrock CDLF, I found out the PTC application
only covered required costs for Phase 1 & Phase 2A, approximately 12.58 acres. The costs for closure and post-
closure cares of Phase 2B (with waste footprint about 3.42 acres) is not included in the approved PTC
document. Please prepare and submit the update Closure & Post-Closure Plan including cost estimates plus
annual inflation adjustment & 1 million dollar PACA. The new FA mechanism to cover the costs over 16-acre
Phases1 & 2 must be submitted to the Solid Waste Section for a review and approval prior to issuance of new
PTO for Phases 2B.

Thank you for your cooperation on this matter.

Ming Chao
2
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.

From: Chao, Ming-tai
Sent: Wednesday, August 16, 2017 12:12 PM
To: 'Garrett, David' <[e-mail]>; Raup, Michael <[e-mail]>
Cc: Mussler, Ed <[e-mail]>; Ritter, Christine <[e-mail]>
Subject: RE: A-1 Sandrock CQCD Report

Gentlemen:

The Solid Waste Section (SWS) received the CQA report for A-1 Sandrock CDLF – Phase 2B; this document
was scanned and uploaded to the Laserfiche with a DIN 28401. The SWS will review the document shortly.

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.

3

From: Mussler, Ed
Sent: Wednesday, August 16, 2017 11:24 AM
To: Chao, Ming-tai <[e-mail]>
Subject: FW: A-1 Sandrock CQCD Report

From: Raup, Michael [mailto:[e-mail]]
Sent: Monday, August 07, 2017 12:21 PM
To: Mussler, Ed <[e-mail]>
Cc: Garrett, David <[e-mail]>
Subject: A-1 Sandrock CQCD Report

Mr. Mussler,

Please find the attached CQCD Report for A-1 Sandrock Inc., CDLF.

Michael Raup, P.E.
Geotechnical Engineer, Amec Foster Wheeler Environment & Infrastructure
4021 Stirrup Creek Drive – Suite 100, Durham, North Carolina 27703, USA
T +01 919 381 9343 M +01 423 943 1038
[e-mail] amecfw.com

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MSE Wall PTC and Facility Plan Rev 2.0 Amec Foster Wheeler Project No. 6468-17-7032
A-1 Sandrock C&D Landfill (4117-CDLF) Phase 2 September 5, 2017

Facility Plan Page 5
PERMITTED CAPACITY A-1 Sandrock, Inc., CDLF (Permit #41-17)
CDLF Phases/Sub-Phases 1 1A (Built) 1B (Built) 1C (Built)
Approved Footprint Acreage 1 2.54 ac 3.18 ac 2.46 ac >>> 8.18 ac
Interim Capacities (Sub-Phases) 2 62,370 cy 186,242 cy 221,720 cy >>> 470,332 cy
Interim Elevations (Sub-Phases) EL. 810 EL. 830 EL. 840
New CDLF Phases/Sub-Phases 1 2A (Built) 2B (Pending) 3 4
Approved Footprint Acreage, 1 ac 4.40 3.42 5.89 0
Interim Capacities (Sub-Phases), 2 cy 250,383 357,810 647,787 505,536
Interim Elevations (Sub-Phases) EL. 846 EL. 846 EL. 854 EL. 904
Volumetric Capacity (Phase 2 only) ........................................................................ 608,193 cy
Permitted Disposal Acreage (Phases 1&2) .............................................................. 16.00 acres
Permitted Capacity (Phases 1&2) 3 .......................................................................... 1,078,524 cy
Original Approved CDLF Footprint Acreage ......................................................... 21.89 acres
Original Approved Total Capacity (Phases 1-4) 2 .................................................... 2,240,000 cy
Operational Life Expectancy .................................................................................... 20 - 25 years
1 Corresponding to 5-year Operating Capacity
2 Includes Final Cap System and Operational Cover
3 This is what is now permitted pending approval of the Phase 2B PTO

REVISED CAPACITY A-1 Sandrock, Inc., CDLF (Permit #41-17)
CDLF Phases/Sub-Phases 1 1 (Built) 2 (Pending) 3 (Future) 4 4
Approved Footprint Acreage 1 8.18 ac 7.82 ac 5.89 0 3
Interim Capacities (Sub-Phases) 2 470,332 cy 608,192 cy 647,787 <505,536>
Interim Elevations (Sub-Phases) EL. 840 EL. 846 EL. 854 EL. 904
Vertical Expansion/Sub-Phases 1 Stage 1 (under Review)
New Ground Footprint Acreage, 1 ac 0 3
Interim Capacities (Sub-Phases), 2 cy 446,200 cy
Interim Elevations (Sub-Phases) EL. 930
Permitted Disposal Acreage (Phases 1 – 2 Expansion) ........................................... 16.00 acres
Estimated Capacity (Phases 1&2 + Stage 1 Expansion) ......................................... 1,524,727 cy
Estimated Capacity (Phases 1-3 + Stage 1 Expansion) ........................................... 2,172,511
Approved CDLF Footprint Acreage ........................................................................ 21.89 acres
Approved Total Capacity (Phases 1-4) 2 .................................................................. 2,240,000 cy
Operational Life Expectancy .................................................................................... 25 - 30 years 5
1 Corresponding to 5-year Operating Capacity
2 Includes Final Cap System and Operational Cover
3 Vertical Expansion – not actual ground disturbance (does not add to total footprint area)
4 Subtract this volume to keep the total volume with the Stage 1 Expansion within the original permit volume
5 Time counted from beginning of the facility in 2009; the Stage 1 Expansion is projected to add 5 years
MSE Wall PTC and Facility Plan Rev 2.0 Amec Foster Wheeler Project No. 6468-17-7032
A-1 Sandrock C&D Landfill (4117-CDLF) Phase 2 September 5, 2017

Closure/Post-Closure Page 77
require excelsior or turf-reinforcement mat (TRM), as specified in the Channel Schedule.
Alternative erosion control products may be substituted with the engineer’s consent.
Rolled erosion control materials should be installed according to the generalized layout
and staking plan found in the Construction Plans or the manufacturer’s recommendations.

Irrigation for landfill covers is not a typical procedure, but consideration to temporary
irrigation may be considered if dry weather conditions prevail during or after the planting.
Care should be taken not to over-irrigate in order to prevent erosion. Collected storm water
will be suitable for irrigation water. Maintenance of the final cover vegetation, described
in the Post-Closure Plan (see below), is critical to the overall performance of the cover.

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

8.2.2 Maximum Area/Volume Subject to Closure
The largest anticipated area that will require final closure at any one time within the next
5-year period – including all of Phase 1 and half of Phase 2 is 11.6 acres. Intermediate
cover shall be used on areas that have achieved final elevations until the final cover is
installed. An annual adjustment is required by the Division for the open area (and the bond
requirement). Based on the volumetric analysis (Appendix 1), the volume of Phase 1 and
half of Phase 2 is 782,580 cubic yards (Section 1.3).

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

8.2.4 Closure Cost Estimate
The following cost estimate is considered suitable for the Financial Assurance
requirements (see Section 10.0). The Owner intends to build the second half of Phase 2,
designated as Phase 2B (Cell 2B), which adds 3.42 acres to the previously permitted 12.58
acre footprint, for a total of 16.00 acres permitted within an approved 22-acre footprint.
No area currently has a certified final cover in place.

MSE Wall PTC and Facility Plan Rev 2.0 Amec Foster Wheeler Project No. 6468-17-7032
A-1 Sandrock C&D Landfill (4117-CDLF) Phase 2 September 5, 2017

Closure/Post-Closure Page 78
TABLE 8A
ESTIMATED FINAL CLOSURE COSTS FOR PHASES 1 and 2 (2017 dollars) 1

VSL (topsoil)2 – 16.0 ac 38720 c.y. @ $4 / cubic yard $ 154,880
CSB (barrier)2 – 16.0 ac 44,528 c.y. @ $8 / cubic yard $ 356,224
Establish Vegetation 16.0 acres @ $1,500 per acre $ 24,000
Storm Water Piping 3 400 LF @ $35.00 / LF $ 14,000
Erosion Control Stone 3 18 tons @ $40.00 / ton $ 720
Cap Gas Vents (3/acre) 48 @ $100 ea $ 4,800
Testing and Surveying 4 Estimated 20 percent of above $ 110,925
Contingency Estimated 15 percent of above $ 83,194
Total Construction Cost (if contracted out) $ 748,743

Notes:
1 The calculation is intended to represent likely third-party construction costs for a hired contractor, not the
Owner/Operator, based on knowledge of local construction costs for similar projects. These estimates meet
NCDEQ Division of Waste Management financial assurance requirements; actual costs may be lower for
construction by the Owner/Operator. Final closure work will be performed incrementally, spreading out the
costs over the life of the project.
2 Includes soil work for regulatory requirements of 15A NCAC 13B .0543, i.e., a minimum of 18 inches of
compacted soil barrier (max. permeability of 1 x 10-5 cm/sec) and 18 inches of topsoil (total soil thickness is
36 inches). For the compacted soil barrier, use a shrinkage factor of 15%; costs include surface preparation,
soil procurement and transport costs, soil placement and compaction, machine/equipment costs, fuel costs
3 Conservative estimate based on similar project history; includes materials and installation
4 Includes Construction document and bidding, construction administrative fee, CQA field monitoring and lab
testing, CQA reporting and certification, final survey for as-built drawings, recordation/notation fee

MSE Wall PTC and Facility Plan Rev 2.0 Amec Foster Wheeler Project No. 6468-17-7032
A-1 Sandrock C&D Landfill (4117-CDLF) Phase 2 September 5, 2017

Closure/Post-Closure Page 81
TABLE 8B
POST-CLOSURE MONITORING AND MAINTENANCE SCHEDULE

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

Notes:
1. Inspect after every major storm event, i.e., 25-year 24-hour design storm
2. Dependent on vegetation type, periodic mowing may be required
3. The Solid Waste Section may be petitioned for discontinuation of gas monitoring if no detections occur in gas
sampling locations or on-site buildings
4. See current Ground Water Sampling and Analysis Plan
MSE Wall PTC and Facility Plan Rev 2.0 Amec Foster Wheeler Project No. 6468-17-7032
A-1 Sandrock C&D Landfill (4117-CDLF) Phase 2 September 5, 2017

Closure/Post-Closure Page 82
8.3.2 Responsible Party Contact
Mr. R.E. ‘Gene’ Petty, Sr. – Owner
Mr. Ronnie E. Petty, III – Operator
A-1 Sandrock, Inc.
2091 Bishop Road
Greensboro, NC 27406 Tel. [phone]
8.3.3 Planned Uses of Property
Currently, there is no planned use for the landfill area following closure. The closed facility
will be seeded with grass to prevent erosion. Any post-closure use of the property
considered in the future will not disturb the integrity of the final cover or the function of
the monitoring systems unless necessary (and to be accompanied by repairs or upgrades).
Future uses shall not increase the potential threat to human health and the environment.
8.3.4 Post-Closure Cost Estimate
The following cost estimate is considered representative of post-closure care costs for the
Financial Assurance (see Section 10.0). This calculation includes all of Phase 1 and
Phase 2, totaling 16.0 acres.
TABLE 8C
ESTIMATED POST-CLOSURE COSTS FOR PHASES 1 and 2 (in 2017 dollars)

Annual Events Units Unit
Cost
Cost/
Event
Annual
Costs
Reseeding/mulching and erosion repair
(Assume 5% of 16.0 ac., once per year)
0.80 ac. $1,600 $1,280.00 $1,280.00
Mow final cap (twice per year) 16.0 ac. $25 $400.00 $800.00
Ground Water (semi-annual, 5 wells)* 6 ea. $400 $2400.00 $4800.00
Surface Water (semi-annual, 4 locations)* 4 ea. $350 $1400.00 $2800.00
Water quality analysis and reporting 2 ea. $2250 $4500.00 $4500.00
Landfill Gas Monitoring (quarterly) 4 ea. $500 $2000.00 $2000.00
Engineering inspection (annual basis) 1 ea. $1,500 $1,500.00 $1,500.00
Maintain storm water conveyances 1 ea. $1,000 $1,000.00 $1,000.00
Maintain access roads, gates, buildings 1 ea. $500 $500.00 $500.00
*Appendix I Detection Monitoring
(Section 9.0)
Total Estimated Annual Cost $19,180.00
30 years * $19,180.00 = $575,400.00 (See Section 10)
MSE Wall PTC and Facility Plan Rev 2.0 Amec Foster Wheeler Project No. 6468-17-7032
A-1 Sandrock C&D Landfill (4117-CDLF) Phase 2 September 5, 2017

Financial Assurance Page 87
10.0 FINANCIAL ASSURANCE (15A NCAC 13B .0546)

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

Cost estimates for closure and post-closure of CDLF Phases 1 and 2 are presented in
Sections 8.2.4 and 8.3.4, respectively. The following is a detailed analysis of the closure
and post closure costs, based on the preceding, all in 2017 dollars, projected over the
anticipated life of the landfill and 30 years of post-closure care. The Financial Assurance
obligation should be recalculated for future years to account for inflation using annual
multipliers furnished by NCDENR.

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

SUMMARY OF CLOSURE AND POST-CLOSURE COST (2017 dollars)

1. Final Closure Construction (see Table 8A) $ 748,743.00

2. Projected Post-Closure Costs (see Table 8C)* $ 575,400

TOTAL CLOSURE/POST-CLOSURE COST $1,324,143.00

3. PACA** $1,000,000

TOTAL REQUIRED FINANCIAL ASSURANCE $2,324,143.00

Per Division rules, Owners/Operators must furnish an acceptable financial assurance
instrument (e.g., performance bond, irrevocable letter of credit, insurance policy, other
fiduciary instrument) within 30 days of notification of approval.
*Assumes 30 years
*Statutory changes enacted ca. 2008 and revised ca. 2010 require a separate bond for Potential Assessment
and Corrective Action, also referred to as PACA. The minimum bond amount is currently $1M.
MSE Wall PTC and Facility Plan Rev 2.0 Amec Foster Wheeler Project No. 6468-17-7032
A-1 Sandrock C&D Landfill (4117-CDLF) Phase 2 September 5, 2017

Plan Certification Page 88
11.0 CERTIFICATION
This engineering plan for the A-1 Sandrock, Inc., C&D Landfill Phases 1 and 2 disposal
unit has been prepared by, or under the responsible charge of, a North Carolina Licensed
Professional Engineer to meet the requirements of 15A NCAC 13B .0539. The individual
signature and seal below attests to compliance with this rule requirement.

Signed ______________________
Printed G. David Garrett .
Date September 5, 2017 .

Not valid without the seal of the above-named licensed professional.