7606_GoldHillRdCDLF_comm_Compost_App_FID1257553_20181102

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Chao, Ming-tai
From:Chao, Ming-tai
Sent:Friday, November 02, 2018 2:38 PM
To:'Al Morton'
Cc:'Garrett, David'; Aja, Deborah
Subject:RE: [External] RE: comments on Gold Hill CDLF Final Cover Certification Report
Attachments:DIN 28803_20180405 comment.pdf
Dear Mr. Morton:

FID 1257553

The Solid Waste Section reviews the revised Application for Type 1 Large Compost Facility Plan for Gold Hill
Road C&DLF (FID 1256889) which was received on 10/18/2018. Please provide proper responses to the
following comments:
1. Per Rule 15 NCAC 13B. 1404(a)(7), all portions of any compost facility (including the proposed Type 1
Large unit at Gold Hill Road C&DLF) located over a closed-out disposal area (the closed LCIDLF,
Permit # 76C-LCID-1999) shall be designed with a pad adequate to protect the disposal area cap from
being disturbed, as defined in Part (a)(10)(E) of this Rule, and there shall be no runoff from the pad onto
the cap or side slopes of the closed out area.

Per Rule 15 NCAC 13B. 1404(a)(10)(E), the linear coefficient of permeability of pads required in
accordance with this Rule shall not be greater than 1 x 10(-7) centimeters per second. If natural soils are
used, the liner must be at least 18 inches thick.

According to Facility Audit Report (08/10//2018), the mining activities at the closed LCIDLF, Permit #
76C-LCID-1999 is not commenced, but piles of wastes or likely processed products are stockpiled on
the footprint of this closed LCIDLF.

The Solid Waste Section requires the rule-required liner/pad to be constructed for separating the
proposed compost unit and the final cover of the closed LCIDLF. The CQA plan and technical
specification to construct this pad must be submitted with the revised permit application for a review and
approval. Operation of compost activities at this Type 1, Large Compost Unit shall not be permitted
until the required CQA report including CQA testing is approved.

2. (Section 8.9) The paragraph 5 of the section states an application for coverage under the NPDES
General Permit NCG24000 is in preparation. Has the permit been approved by NCDEQ yet? Please
provide a copy of this permit to cover land disturbances and compost operations at the closed LCIDLF.

3. The responses to the 04/05/2018 comments (see attachment) on the “Operations Plan Update” for the
CDLF facility dated 11/29/2017 have not been received by the Solid Waste Section yet. Please submit
the revised Operations Plan. The original comments are reiterated below:
i. (Section 10.9) Please add the following sentence back to the section – “The selection of
maximum size of stockpile needs to incorporate the factors of safety operation, storage, and fire
prevention.”
ii. Is there any reason why the Section 16 – Special Material Handling, Mining the LCID which
was presented in the Operations Plan Update dated October 12, 2017 (DIN 28541) being
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removed from the November 29, 2017 Operations Plan Update? According to the Type 1
Compost Facility Plan, the waste mining activities are conducting at the inactive LCIDLF unit
(future Phase 1B); therefore, please add a section to describe the mining activities. The existing
Permit Condition Nos. 30 through 36, Part VII, Attachment 3 of the Permit Approval to Operate
(DIN 28583) should be included in the new section as well.
Please contact myself if you have any questions on the comments.

From: Garrett, David [mailto:[e-mail]]
Sent: Friday, November 02, 2018 10:23 AM
To: Chao, Ming-tai <[e-mail]>
Subject: RE: [External] RE: comments on Gold Hill CDLF Final Cover Certification Report

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That works. Thank you.

From: Chao, Ming-tai <[e-mail]>
Sent: Friday, November 2, 2018 10:21 AM
To: Garrett, David <[e-mail]>
Subject: RE: [External] RE: comments on Gold Hill CDLF Final Cover Certification Report

Hi David:

I am working on the review of A-1 Sandrock PTC-Phase 3 right now, and the compost unit for Gold Hill Road will be the
next one.

Ming

From: Garrett, David [mailto:[e-mail]]
Sent: Friday, November 02, 2018 10:15 AM
To: Chao, Ming-tai <[e-mail]>
Cc: Al Morton <[e-mail]>; Raup, Michael <[e-mail]>
Subject: RE: [External] RE: comments on Gold Hill CDLF Final Cover Certification Report

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Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]
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We said in that conversation there would be no additional submittal on the final closure until Al gets another area ready
to have certified closed. I am inquiring in regards to the operations plan, composting application, and anything impeding
the issuance of the permit to operate within the allowed 6.1 acres. We would like to get the paperwork in order before
the next SWS inspection. Thank you.

From: Chao, Ming-tai <[e-mail]>
Sent: Friday, November 2, 2018 10:09 AM
To: Garrett, David <[e-mail]>
Subject: RE: [External] RE: comments on Gold Hill CDLF Final Cover Certification Report

Hi Dave:

After the phone conservations with you and Michael in 10/05/18 regarding how to fix the problem of the test
pits dug through the constructed final cover system, I have not hearing from you or received any document from
you. So I don’t know how to respond your request of “ Have you received a satisfactory response on this
issue?”

From: Garrett, David [mailto:[e-mail]]
Sent: Friday, November 02, 2018 9:55 AM
To: Chao, Ming-tai <[e-mail]>
Subject: [External] RE: comments on Gold Hill CDLF Final Cover Certification Report

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Report Spam.

Ming, good morning. Have you received a satisfactory response on this issue? Please advise. DG

From: Chao, Ming-tai <[e-mail]>
Sent: Wednesday, September 26, 2018 3:32 PM
To: Al Morton <[e-mail]>
Cc: Garrett, David <[e-mail]>; Patrone, John <[e-mail]>; Raup, Michael
<[e-mail]>; Stanley, Sherri <[e-mail]>
Subject: comments on Gold Hill CDLF Final Cover Certification Report

Dear Mr. Morton:

FID 1254852
The Solid Waste Section completes a review of the Construction Quality Assurance (CQA) Report dated
September 18, 2018 (FID 1254647), which is, on your behalf, prepared by Wood Environmental &
Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]
4
Infrastructure Solutions, Plc. Below are the comments on the CQA Report, your proper responses to the
comments will expedite the permit reviewing processes and the issuance of a new permit.

1. To avoid confusion and to be consistent with the previous submittal (DIN 28479), please provide a
separate drawing (without any contour lines and sample points but the boundaries of each phase)
showing the closed Phase 2A (5 acres), Phase 2B (1.3 acres) and to-be-closed Phase 2 of 2.03 acres and
the active Phase 1A-1 and the constructed Phase 1A-2 and the future Phase 1B (7.6 acres).

2. According to AOC (DIN 20575 & 28246) the landfill can only operate 6.1-acre-constructed landfill area
for waste disposal. Since the active disposal area of 1.3-acre is closed, the remaining area for waste
disposal at the landfill will be 4.5 acres. The landfill owner can request an approval to use the portions
of the constructed 1.89-acre Phase 1A-2, up to 1.6 acres, for receiving permitted wastes for disposal per
Permit Condition No. 4, Part III of Attachment 3 of the permit (DIN 28583) dated November 06,
2017. To obtain a new Permit Approval To Operate (PTO) for using the additional disposal area at the
landfill, please submit the following documents:
i. A new Facility Plan drawing to show remaining disposal area of 6.1 acres of the CDLF including
remaining Phase 2 area (2.03 acres), Phase 1A-1 (2.47 acres), the portion of Phase 1A-2 (1.6
acres), and remaining Phase1A area (0.29 acres).

ii. A drawing contains two cross sections over the new Facility Plan drawing to show the landfill
grades – the landfill base grades, the latest fill grades, and the approved interim final grades.

iii. The operating capacity of each above-mentioned phase which will be incorporated into the new
permit - PTO.

iv. The physical markers must be established/surveyed which will be used to physically separate
Phase 1A-2 (approved disposal area) and remining Phase 1A area of 0.29 acres (constructed area
not for waste disposal yet). The established markers will be subject to the future facility
audit/inspection.

3. According to the CQA Report, the test pits were used to measure the thickness of compacted soil layer
and vegetative soil layer (VSL) for the constructed final cover system. The approaches are NOT
APPROVED by the Solid Waste Section and deviated from the approved CQA Plan (DIN 26596, Page
1 & Table C).
i. Who approved this deviation from the approved CQA Plan (DIN 26596)? Should the decision-
making processes be documented in the CQA Report?

ii. How the test-pit areas were restored? Specifically, the compacted soil barrier layer (CSB) was
initially constructed and tested for classification, compaction effort, and permeability, then the
CSB was excavated for measuring the layer thickness by several huge holes as shown in the
photos in Appendix C of the CQA report; have the required in-placed density and permeability
tests for the restored layer be tested in the restored layer? Where are the re-tested data?

iii. If the testing data (mentioned in Comment No. 3.ii) on the restored areas are not available, why
the constructed final cover system can be considered as satisfying the requirements set forth in
Rule 15A NCAC 13B .0543.

iv. The Section- Responsibilities and Documentation stated that the local surveying company –
Charlie Morgan Surveying, PLLC was contracted for survey work of the described closure
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activities. In another landfill construction meeting in 2018 at Randolph County, the Solid Waste
Section was informed that Charlie Morgan Surveying, PLLC, who has conducted survey work
for previous phased developments at this landfill did not contract for the similar project this time
due to the retirement of the owner. For the sake of clarification, please provide the specific
descriptions of the work that Charlie Morgan Surveying, PLLC was contracted to do and provide
the original survey data signed and sealed by the licensed surveyor.

4. (Figure 1) Please address the following concerns:
i. There are two locations named as 2B-4; please correct the likely typo.

ii. Add the sample location 2B-5.

5. (Appendix B) Please provide the required info or data.
i. Per the approved CQA Plan (DIN 26596), the Sections – Responsibilities and Documentation &
Laboratory Testing and Observations stated that in-place density of CSB were tested at the
frequency of four (4) tests per acre per lift. Appendix B only contains testing results of 15
samples, rather than 24 samples. Please provide the required testing results of the other sample
locations.

ii. Please provide the lab testing results used to establish the relationship between soil density and
moisture content (Standard Proctor Compaction Test) of the earthen material used for this final
cover construction.

iii. The Section – Laboratory Testing and Observations stated that the strength properties of the soil
for constructing final cover system had the friction angle of 29 degrees and the cohesion of 180
psf. Please provide the lab testing results and the sample location/identification (sample location
must be shown on the drawing).

iv. In addition to testing in-place soil density on the CSB, the approved CQA Plan (DIN 26596)
specifies the testing of moisture content on the CSB, at the frequency of four (4) tests per acre
per lift. Please provide the testing results.

6. (Appendix C) Please correct the likely typos in the photo logs:
i. What is VSB? Should the correct term be VSL as described in the Section of Responsibilities
and Documentation.

ii. The location identification shall be consistent to that shown on the drawing Figure 1. The
location identifications stated in the Photo Log are misleading.

7. According to available soil testing results, the in-place dry soil densities of the 18-inch CSB range from
82.7 psf to 106.1 psf; nine (9) of the 15 tested samples fail to pass the required 95% compaction effort
specified in the approved CQA plan (DIN 26596). Additionally, veneer slope stability analyses in the
approved PTC Application (DIN 26596) specifies the minimum friction angle of the compacted soil
liner is 31 degrees. The Solid Waste Section can’t accept the conclusion for the low compaction effort
of CSB due to the presence of mica content and/or small rock; additionally, the reported friction angle of
the compacted soil liner is 29 degrees, which is less than the specified value of 31 degrees. The slope
stability shall be re-analyzed by using the collected data - field density and shear strength to demonstrate
the constructed 3 to 1 side slope is reasonable stable.

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Please contact myself if you need further clarification on the above-mentioned comments.

From: Chao, Ming-tai
Sent: Wednesday, September 19, 2018 10:07 AM
To: Al Morton <[e-mail]>
Cc: Garrett, David <[e-mail]>; Patrone, John <[e-mail]>; 'Raup, Michael'
<[e-mail]>; Stanley, Sherri <[e-mail]>; Rice, Sarah M <[e-mail]>;
Kramer, Renee P <[e-mail]>
Subject: RE: Gold Hill CDLF Final Cover Certification Report

Dear Mr. Morton:

The Solid Waste Section received the certified CQA report for construction of final cover of Phase 2B,
approximately 1.3 acres at Gold Hill Road CDLF, Permit # 76-06. This document was scanned to the
Laserfiche with a FID 1254647 and will be reviewed shortly. In the meantime, please direct your consultant to
complete the following tasks:
1. The cost estimates for the CDLF must be revised to reflect the new costs for closing active landfill areas
and for post-closure cares at the final closure area. The required financial assurance document (both
hard copy and electronic copy) must be sent to Sarah Rice at 919-707-8287 or
[e-mail]. Her mailing address is 1646 Mail Service Center, Raleigh, NC 27699-1646.
2. To maintain the active disposal area of 6.1 acres, please submit the written request and the revised
Facility Plan drawings to show the 6.1-acre disposal area according to AOC (DIN 20575 & DIN
28246). The document will be used as the supporting document for issuing a new Permit Approval To
Operate the new 6.1-acre CDLF disposal area at the landfill facility.
3. The completed application for operating the Type-1 Compost Unit at the landfill facility.
To complete the above-mentioned tasks will expedite the permit reviewing process and the issuance of a new
permit allowing you to operate the new landfill cell (whole or portions of the constructed Phase 1A-2) for waste
disposal & the new compost unit at the landfill facility. If you have any questions please contact myself. Have
a wonderful day.

Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]
Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]
7

From: Raup, Michael <[e-mail]>
Sent: Tuesday, September 18, 2018 4:35 PM
To: Chao, Ming-tai <[e-mail]>; Al Morton <[e-mail]>
Cc: Garrett, David <[e-mail]>
Subject: [External] RE: Gold Hill CDLF Final Cover Certification Report

CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
Report Spam.

Mr. Chao,

Please find the attached Final Cover Certification Report for Gold Hill CDLF. The previous emailed report wasn’t sealed.

Apologies,

Michael C. Raup, PE
Geotechnical Engineer
Direct: [phone]
Mobile: [phone]
www.woodplc.com

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