4117_A1SandrockCDLF__final PTC-Phase 2_DIN24958_20150225

From:Garrett, David
To:Chao, Ming-tai
Subject:Re: comment on revisions for A-1 Sandrock Phase 2A Application
Date:Wednesday, February 25, 2015 3:15:34 PM
Attachments:A1 Facility Plan Rev 1.2 Page 4.pdf
I beg your pardon. Please see the attached.
G. David Garrett, PG, PE
Senior Engineer/Geologist
SCS Engineers, PC
322 Chapanoke Road, Suite 101
Raleigh, North Carolina 27603-3415
Office: (919) 662 - 3015
Fax: (919) 662 - 3017
Mobile: (919) 418 - 4375 (preferred)
[e-mail]
From: Chao, Ming-tai <[e-mail]>
Sent: Wednesday, February 25, 2015 2:34 PM
To: Garrett, David
Subject: RE: comment on revisions for A-1 Sandrock Phase 2A Application

David:
I am sorry if I confused you. I got your two e-mail messages and attached LFG and WQMP
and Design Hydro responses. Today I am requesting the status of my comment which wassent to you on 02/18/15, which was also attached to the previous e-mail sent out today (red
line). To avoid any confusion I copy and paste my comment over below:
I have completed the review of the engineering portion of the revised PTC application andhave a comment below:
The proposed interim elevations up to 846 feet amsl for Cell 2 B is not consistent thecontours (ranging from 810 to 820 feet amsl) on Drawing No. E3C/Sheet 4 of 8. Please
clarify.
Thanks.
Ming
From: Garrett, David [mailto:[e-mail]] Sent: Wednesday, February 25, 2015 2:08 PMTo: Chao, Ming-tai; Ritter, ChristineSubject: Re: comment on revisions for A-1 Sandrock Phase 2A Application Hello. I sent two messages with large attachments yesterday. These are in response to
Christine's comments. Please notify me if you did not receive them.
David Garrett PG PESCS Engineers Raleigh
Tel. [phone]

A-1 Sandrock CDLF and Processing Facility Phase 2 PTC (Rev. 1.2.1) 2/6/2015
Permit to Operate Renewal (Permit 41-17) CDLF Facility Plan Page 4
CAPACITY PROJECTIONS A-1 Sandrock, Inc., CDLF (Permit #41-17)
Solid Waste Units Present C&D Recycling Facility, CDLF
Other Activities/Infrastructure Scales/Office, Permitted Mining, LCID Processing
CDLF Unit Footprint Acreage .................................................................................. 21.89 acres
Built Built Built
CDLF Phases/Sub-Phases 1 1A 1B 1C
New Ground Footprint Acreage 1 2.54 ac 3.18 ac 2.46 ac
Interim Capacities (Sub-Phases) 2 62,370 cy 186,242 cy 221,720 cy
Interim Elevations (Sub-Phases) EL. 810 EL. 830 EL. 830
Volumetric Capacity (Phase 1) 2 .............................................................................. 470,332 cy
Final Elevations (Phase 1) 2 ...................................................................................... EL. 840
Maximum Waste Thickness 2 ................................................................................... 60 feet 5
Permitted Side Slope Ratios ..................................................................................... 3H:1V
Permitted Footprint Acreage ................................................................................... 8.18 ac
Facility Boundary Acreage ....................................................................................... 75 acres
Total Permitted Capacity 2 ........................................................................................ 478,484 cy
Operational Life Expectancy .................................................................................... 4.74 years 7

FUTURE CONDITIONS Phases 2 through 4 are contiguous with Phase 1
Current
New CDLF Phases/Sub-Phases 1 2A 2B 3 4
New Ground Footprint Acreage 1, ac 4.40 3.42 5.89 0 5
Interim Capacities (Sub-Phases) 2, 6, cy 304,097 304,096 647,787 505,536
Interim Elevations (Sub-Phases) EL. 820 EL. 820 EL. 854 EL. 904
Permitted Disposal Acreage 4 (through Phase 2A) .................................................. 12.58 acres
Permitted Capacity 4 ................................................................................................ 782,581 cy
Permitted Disposal Acreage 4 (through Phase 2) .................................................... 16.00 acres
Permitted Capacity 4 ................................................................................................ 1,086,677 cy
Final Elevations (Entire Unit) 2 ................................................................................ EL. 904
Maximum Waste Thickness 2 ................................................................................... 110 feet
Permitted Side Slope Ratios .................................................................................... 3H:1V
Total CDLF Footprint Acreage ............................................................................... 21.89 acres
Total Planned Capacity 6 .......................................................................................... 2,240,000 cy
Operational Life Expectancy .................................................................................... 25 - 30 years
1 Corresponding to 5-year Operating Capacity
2 Includes Final Cap System and Operational Cover – Phase 1C volume was adjusted to match the permit issue
3 Covered by current Permit to Construct application
4 Add Phase 1 and Phase 2 areas and volumes
5 Vertical Expansion – not actual ground disturbance (does not add to total footprint area)
6 Consistent with the February 2004 Permit to Construct – Phase 4 volume was adjusted to match permit issue
7 Original preliminary estimate (in 2009); Phase 1 is now projected to last nearly 6 years (as of 2013) due to
variable waste intake and recycling efficiency; future waste intake may vary
"Garrett, David" <[e-mail]> wrote:I just submitted my response to Christine yesterday. I thought I copied you. We're all good
on your comments, right?
David Garrett PG PESCS Engineers Raleigh
Tel. [phone]
"Chao, Ming-tai" <[e-mail]> wrote:
Hi David:

Have you got a chance to complete the response to the comment in the email message dated
02/18/15?

Thanks.

Ming

From: Chao, Ming-tai Sent: Wednesday, February 18, 2015 8:53 AMTo: 'Garrett, David'Cc: Ritter, Christine; [e-mail]: comment on revisions for A-1 Sandrock Phase 2A Application
Hi David:
I have completed the review of the engineering portion of the revised PTC application andhave a comment below: The proposed interim elevations up to 846 feet amsl for Cell 2 B is not consistent thecontours (ranging from 810 to 820 feet amsl) on Drawing No. E3C/Sheet 4 of 8. Pleaseclarify.According to your previous e-mail message that you would respond Christin’s comments on
last Friday (02/13/15), but as of today, she has not received anything from you yet. Pleasesend Christine the requested info related to the design hydro of Phase 2 this week, so we can
wrap up this permit review and issue PTC- Phase 2.
Have a wonderful day & keep warm – the record-breaking cold (both low & high) is likelyhitting us tonight or Friday.
Ming Chao
Ming-Tai Chao, P.E. Environmental Engineer
Permitting Branch, Solid Waste Section Division of Waste Management (Mailing Address)1646 Mail Service Center Raleigh, NC 27699-1646
(Street Address)Green Square, 217 West Jones Street
Raleigh, NC 27603Tel. [phone]
[e-mail]
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: Garrett, David [mailto:[e-mail]] Sent: Friday, February 13, 2015 11:06 AMTo: Chao, Ming-taiSubject: Re: Revisions for A-1 Sandrock Phase 2A Application
Thank you. Please check your drawing set, there should be 8 drawings in the most recent
submittal. If you are OK with reviewing the electronic copies, I will bring you hard copies
once we're all finished. If you prefer a hard copy for review, please so advise. Thanks.

G. David Garrett, PG, PE
Senior Engineer/Geologist
SCS Engineers, PC
322 Chapanoke Road, Suite 101
Raleigh, North Carolina 27603-3415
Office: (919) 662 - 3015
Fax: (919) 662 - 3017
Mobile: (919) 418 - 4375 (preferred)
[e-mail]
From: Chao, Ming-tai <[e-mail]>
Sent: Friday, February 13, 2015 10:23 AM
To: Garrett, David
Cc: Ronnie Petty; Ritter, Christine
Subject: RE: Revisions for A-1 Sandrock Phase 2A Application

Dave:

The documents that you sent in via e-mails are scanned and logged into document tracking system.
The documents are

One set of drawing (Sheet 1 of 6 to Sheet 6 of 6), received on 01/26/15, DIN 23116. (The hard copy
of the drawings was mentioned to be delivered to this office in the 01/26/15 e-mail, but the SWS
has not received them yet.)

Written responses to DWM Comments dated 01/26/15 (DIN 23093) which are incorporated into the
revised application including drawings, received 02/11/15, DIN 23583.

I will review the documents shortly. Have a wonderful weekend.

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
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: Garrett, David [mailto:[e-mail]] Sent: Wednesday, February 11, 2015 8:47 PMTo: Chao, Ming-taiCc: Ronnie Petty; Ritter, ChristineSubject: Revisions for A-1 Sandrock Phase 2A Application
Ming, please see attached my edits to the drawings and text of the PTO application, made in
response to your comments provided to me in your email dated 1-26-204. All of your
review comments have been addressed with text corrections or minor plan revisions made
in red or blue type.

I have received comments from Christine Ritter regarding the hydrogeology work performed
ca. 2002. I will reply to her by this Friday, although I would point out that the bedrock
separation and groundwater separation maps, based on the prior approved work and newly
adjusted base grades, are included in the drawing set.

Within this submittal is the Financial Assurance calculation, which reflects the minor
revisions to footprint areas and soil volumes made per your review. Once you have given
your approval, I will submit a final text in electronic format and paper copies. Please let me
know if you require anything further. Thanks.

G. David Garrett, PG, PE
Senior Engineer/Geologist
SCS Engineers, PC
322 Chapanoke Road, Suite 101
Raleigh, North Carolina 27603-3415
Office: (919) 662 - 3015
Fax: (919) 662 - 3017
Mobile: (919) 418 - 4375 (preferred)
[e-mail]
SCS Engineers, P.C.
Environmental Consultants 322 Chapanoke Road 919 662-3015
and Contractors Suite 101 FAX [phone]
Raleigh, NC 27603-3415 www.scsengineers.com

Offices Nationwide
February 6, 2015
File No. 022114704.00 Task 1

Mr. Ed Mussler, PE.
Permitting Branch, Solid Waste Section
NCDENR Division of Waste Management
Green Square, 217 West Jones Street
Raleigh, North Carolina 27603

Subject: Permit to Construct Application
A-1 Sandrock, Inc., CDLF Phase 2
NC Solid Waste Permit #41-17 (Guilford County)

Dear Ed:

On behalf of A-1 Sandrock, Inc., SCS Engineers, PC (SCS) has prepared the enclosed revisions
to the Permit to Construct application, submitted on January 13, 2015. This work revises the
September 2013 Permit to Operate application for Phase 1, submitted by David Garrett &
Associates, which was approved by the Solid Waste Section in December 2013. The Owner
requests a continuation of the 5-year PTO and a PTC for Phase 2A. The phase expansion will
occur within a previously approved footprint and does not affect the permitted capacity or daily
intake. The enclosed revisions were prepared in response to comments from Ming-tai Chao, PE.

We appreciate the opportunity to be of service on this project. If you have any questions about
this work, or if we may be of further service, please contact us at your earliest convenience.

Sincerely,

G. David Garrett, PG, PE H. James Law, PE, BCEE
Project Manager Project Director
SCS ENGINEERS SCS ENGINEERS

gdg/hjl

Enclosures

C:\Users\3921gdg\Documents\Projects\A1 Sandrock\Phase 2A PTC\Phase 2 PTC report.docx

A -1 Sandrock, Inc. CDLF (Permit 41-17) February 6, 2015
Phase 2A Permit to Construct Application Page 1
Project Narrative
This application was prepared for A-1 Sandrock, Inc., in pursuit of a Permit to Construct (PTC)
for Phase 2 of their CDLF. Phase 2 is a five-year contiguous phase covering 7.82 acres, located
within the west and south portions of the approved CDLF footprint. Phase 2 will provide
608,193 cubic yards of disposal volume to be constructed in two cells, 2A and 2B, beginning
with Cell 2A nearest to Cell 1C. Phase 2A is expected to last approximately 2 years. The
facility permit was last renewed in December 2013 with a Permit to Operate (PTO) for Phase 1.
As with Phase 1, the rough grading for Phase 2 has been initiated under NCDENR mining permit
#41-22. Upon completing the excavation of Phase 1 in stages, a CQA report was prepared to
address any anomalies in subsurface conditions, followed by three individual PTO’s issued for
three cells, 1A, 1B, and 1C. Discussions with the Section in mid-2014 indicated the likelihood
that a similar permitting process would be applicable for Phase 2.
On an historic note, Site Suitability and Design Hydro reports, prepared ca. 2002 in accordance
with 15A NCAC 13B .0504, applied to the entire 21.9 acre footprint permitted for the CDLF,
including Phase 2. The test boring density was one per acre, supplemented by test pits and
observation of the excavation. Figure 1, excerpted from the 2002 PTC application, shows the
Phase 2 area was originally designated as Phase 1. The original PTC was approved in 2004 with
this layout; but prior to opening the CDLF, the Owner requested a reconfiguration of the phases
in 2006, which is reflected in the current facility plan.
Enclosed Revisions
This application updates the Facility Plan text and drawings, along with the Financial Assurance
calculations. Base grades and final grades are the same as originally permitted. No changes to
the Operations Plan or Monitoring Plan are planned. The Closure/Post Closure Plans will apply
as approved to both Phases 1 and 2. The revised Financial Assurance calculation includes Phase
2A and Phase 1, in addition to Potential Assessment and Corrective Action (PACA). The
Sedimentation and Erosion Control (S&EC) Plan, approved by the Land Quality Section and
Guilford County Planning, has been implemented.
Specific pages of the PTO application, approved in December 2013, are included with this
application as substitutes for corresponding pages in the current PTO. Substitute pages are
labeled Revision 1.2.1, with a January 2015 date, and are listed as follows:
Section 1.3.2 Page 4 Current and Future Volumes and Capacities (table)
Table 8A Page 77 Estimated Final Closure Costs for Phases 1 and 2A

A -1 Sandrock, Inc. CDLF (Permit 41-17) February 6, 2015
Phase 2A Permit to Construct Application Page 2
Table 8B Page 81 Estimated Post-closure Costs for Phases 1 and 2A
Section 10 Page 87 Financial Assurance Calculation (Phases 1 and 2A)
And the following drawings from the approved Facility Plan Drawings have been modified
(these sheet numbers reflect this grouping, not the original set):
Sheet Drawing Title
1 C Cover Sheet
2 E1A Existing Conditions
3 E3A Approved Phase 2 Base Grades
4 E3B Phase 2A Interim Fill Grades
5 E3C Phase 1 and 2 Interim Fill Grades
6 S1 Phase 2 and 3 Ground Water Separation
7 S2 Phase 2 and 3 Bedrock Separation
8 X1 Phase 2A Cross Sections

A-1 Sandrock CDLF and Processing Facility Phase 2 PTC (Rev. 1.2.1) 2/6/2015
Permit to Operate Renewal (Permit 41-17) CDLF Facility Plan Page 4
CAPACITY PROJECTIONS A-1 Sandrock, Inc., CDLF (Permit #41-17)
Solid Waste Units Present C&D Recycling Facility, CDLF
Other Activities/Infrastructure Scales/Office, Permitted Mining, LCID Processing
CDLF Unit Footprint Acreage .................................................................................. 21.89 acres
Built Built Built
CDLF Phases/Sub-Phases 1 1A 1B 1C
New Ground Footprint Acreage 1 2.54 ac 3.18 ac 2.46 ac
Interim Capacities (Sub-Phases) 2 62,370 cy 186,242 cy 221,720 cy
Interim Elevations (Sub-Phases) EL. 810 EL. 830 EL. 830
Volumetric Capacity (Phase 1) 2 .............................................................................. 470,332 cy
Final Elevations (Phase 1) 2 ...................................................................................... EL. 840
Maximum Waste Thickness 2 ................................................................................... 60 feet 5
Permitted Side Slope Ratios ..................................................................................... 3H:1V
Permitted Footprint Acreage ................................................................................... 8.18 ac
Facility Boundary Acreage ....................................................................................... 75 acres
Total Permitted Capacity 2 ........................................................................................ 478,484 cy
Operational Life Expectancy .................................................................................... 4.74 years 7

FUTURE CONDITIONS Phases 2 through 4 are contiguous with Phase 1
Current
New CDLF Phases/Sub-Phases 1 2A 2B 3 4
New Ground Footprint Acreage 1, ac 4.40 3.42 5.89 0 5
Interim Capacities (Sub-Phases) 2, 6, cy 304,097 304,096 647,787 505,536
Interim Elevations (Sub-Phases) EL. 820 EL. 846 EL. 854 EL. 904
Permitted Disposal Acreage 4 (through Phase 2A) .................................................. 12.58 acres
Permitted Capacity 4 ................................................................................................ 782,581 cy
Permitted Disposal Acreage 4 (through Phase 2) .................................................... 16.00 acres
Permitted Capacity 4 ................................................................................................ 1,086,677 cy
Final Elevations (Entire Unit) 2 ................................................................................ EL. 904
Maximum Waste Thickness 2 ................................................................................... 110 feet
Permitted Side Slope Ratios .................................................................................... 3H:1V
Total CDLF Footprint Acreage ............................................................................... 21.89 acres
Total Planned Capacity 6 .......................................................................................... 2,240,000 cy
Operational Life Expectancy .................................................................................... 25 - 30 years
1 Corresponding to 5-year Operating Capacity
2 Includes Final Cap System and Operational Cover – Phase 1C volume was adjusted to match the permit issue
3 Covered by current Permit to Construct application
4 Add Phase 1 and Phase 2 areas and volumes
5 Vertical Expansion – not actual ground disturbance (does not add to total footprint area)
6 Consistent with the February 2004 Permit to Construct – Phase 4 volume was adjusted to match permit issue
7 Original preliminary estimate (in 2009); Phase 1 is now projected to last nearly 6 years (as of 2013) due to
variable waste intake and recycling efficiency; future waste intake may vary

A-1 Sandrock CDLF and Processing Facility Phase 2 PTC (Rev. 1.2.1) 2/6/2015
Permit to Operate Renewal (Permit 41-17) Closure/Post-Closure Page 77
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 half of Phase 2, designated
as Phase 2A (Cell 2A), which adds 4.40 acres to the previously permitted 8.18 acre
footprint, for 12.58 acres permitted. No area has a certified final cover in place.

TABLE 8A
ESTIMATED FINAL CLOSURE COSTS FOR PHASES 1 and 2A (2015 dollars) 1

VSL (topsoil)2 – 12.58 ac 30,444 c.y. @ $4 / cubic yard $ 121,776
CSB (barrier)2 – 12.58 ac 35,010 c.y. @ $8 / cubic yard $ 280,080
Establish Vegetation 12.58 acres @ $1,500 per acre $ 18,870
Storm Water Piping 3 300 LF @ $35.00 / LF $ 10,500
Erosion Control Stone 3 15 tons @ $40.00 / ton $ 600
Cap Gas Vents (3/acre) 35 @ $100 ea $ 3,500
Testing and Surveying 4 Estimated 20 percent of above $ 87,065
Contingency Estimated 15 percent of above $ 65,300
Total Construction Cost (if contracted out) $ 587,691

Notes:
1 Intended to represent likely third-party construction costs (hired contractor, not the Owner/Operator), based
on knowledge of local construction costs for similar projects – these estimates provided to meet NC DENR
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

A-1 Sandrock CDLF and Processing Facility Phase 2 PTC (Rev. 1.2.1) 2/6/2015
Permit to Operate Renewal (Permit 41-17) Closure/Post-Closure Page 81
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 2A, totaling 12.58 acres.
TABLE 8C
ESTIMATED POST-CLOSURE COSTS FOR PHASES 1 and 2A (in 2015 dollars)

Annual Events Units Unit
Cost
Cost/
Event
Annual
Costs
Reseeding/mulching and erosion repair
(Assume 5% of 12.6 ac., once per year)
0.63 ac. $1,600 $1,008.00 $1,008.00
Mow final cap (twice per year) 12.6 ac. $25 $315.00 $630.00
Ground Water (semi-annual, 5 wells)* 5 ea. $400 $2000.00 $4000.00
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 $17,938.00

30 years * $17,938 = $538,140 (See Section 10)
10.0 FINANCIAL ASSURANCE
(15A NCAC 13B .0546)
A-1 Sandrock CDLF and Processing Facility Phase 2 PTC (Rev. 1.2.1) 2/6/2015
Permit to Operate Renewal (Permit 41-17) Financial Assurance Page 87

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 2A 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 2009 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 (2015 dollars)

1. Final Closure Construction (see Table 8A) $ 587,691

2. Projected Post-Closure Costs (see Table 8C)* $ 538,140

TOTAL CLOSURE/POST-CLOSURE COST $1,125,831

3. PACA** $1,000,000

TOTAL REQUIRED FINANCIAL ASSURANCE $2,125,831

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.
0
Scale 1" = 200'
EXISTING
- 2 FOOT ELEVATION CONTOUR
- 10 FOOT ELEVATION CONTOUR
FACILITY BOUNDARY
SANITARY SEWER
WATERCOURSE BUFFER ZONE
PROPERTY BUFFER ZONE
100 YR FLOODPLAIN
WATERCOURSE
LEGEND
PROPOSED
- 2 FOOT ELEVATION CONTOUR
- 10 FOOT ELEVATION CONTOUR
CELL AND WASTE LIMITS
NOTE:
CONTOURS SHOWN FOR CELLS 1A / 1B, 2A AND 2B
REPRESENT FINAL TOP OF WASTE GRADES
DATE:
SCALE:
DRAWING NO.
RText (RText)
X1
8
AS SHOWN
2/10/2015 02214704.00 T3GDGGDGSCLA-1 SANDROCK, INC.PERMIT NO. 41-17-CDLF-20082091 BISHOP ROADGREENSBORO, NC 27406PHASE 2 INTERIM GRADESPERMIT RENEWAL APPLICATIONPHASE 2 PERMIT TO CONSTRUCT 8
Bar is 1" on original drawing
3000200010001000
FACILITY MAP
TOP OF BEDROCK
COLONIAL PIPELINE
BISHOP ROAD
HICKORY CREEK
SANITARY SEWER
SCALE HOUSE
FACILITY BOUNDARY
MAX SEASONAL HIGH GROUNDWATER
INTERIM SLOPE
TOP OF BEDROCK
MAX SEASONAL HIGH GROUNDWATER
EXTERIOR SLOPE
PERMITTED
BASE GRADE
EDGE OF CELL
EDGE OF CELL
PERMITTED
BASE GRADE
EXISTING BERM
PHASE 2A
PHASE 2B PHASE 1C
PHASE 2A
PHASE 1A
A'
A
B'
B
EXISTING
BERM
From:Garrett, David
To:Chao, Ming-tai
Cc:Ronnie Petty; Ritter, Christine
Subject:Revisions for A-1 Sandrock Phase 2A Application
Date:Wednesday, February 11, 2015 8:48:40 PM
Attachments:A1 Updated Facility Plan Revisions 1.2.1.pdf02214704.00 A-1 PHASE 2-3 GRADING PLAN.pdf
Ming, please see attached my edits to the drawings and text of the PTO application, made in
response to your comments provided to me in your email dated 1-26-204. All of your
review comments have been addressed with text corrections or minor plan revisions made
in red or blue type.
I have received comments from Christine Ritter regarding the hydrogeology work performed
ca. 2002. I will reply to her by this Friday, although I would point out that the bedrock
separation and groundwater separation maps, based on the prior approved work and newly
adjusted base grades, are included in the drawing set.
Within this submittal is the Financial Assurance calculation, which reflects the minor
revisions to footprint areas and soil volumes made per your review. Once you have given
your approval, I will submit a final text in electronic format and paper copies. Please let me
know if you require anything further. Thanks.
G. David Garrett, PG, PE
Senior Engineer/Geologist
SCS Engineers, PC
322 Chapanoke Road, Suite 101
Raleigh, North Carolina 27603-3415
Office: (919) 662 - 3015
Fax: (919) 662 - 3017
Mobile: (919) 418 - 4375 (preferred)
[e-mail]
From:Chao, Ming-tai
To:"Garrett, David"
Cc:Aja, Deborah; Jernigan, Hugh; Ritter, Christine
Subject:Comments on A-1 Sandrock CDLF Phase 2 PTC, 41-17; DIN 23093
Date:Monday, January 26, 2015 12:52:00 PM
Hi Dave:
On January 15, 2015 the Solid Waste Section (the SWS), the Division of Waste Management(DWM) received an electronic copy of the Permit to Construct (PTC) Application for Phase
2 lateral expansion at the above-referenced landfill. According to the cover letter datedJanuary 13, 2015, the PTC Application is a supplemental document to the approved Permit to
Operate (PTO) Application for Phase 1 of the above-referenced landfill, which is titled:Facility and Operations Plan Update, A-1 Sandrock, Inc. C&DLF (Phase 1) andProcessing Facility, Gilford County North Carolina, Solid Waste Permit No. 41-17. Prepared by: David Garrett, P.G., P.E. Received September 05, 2013 and approved by
the SWS on November 05, 2013 (DIN 20125).
The received PTC Application (DIN 22964) includes one-page cover letter, two pages ofproject narrative, and revised portions to the approved PTO Application (DIN 20125). By
this means, A-1 Sandrock Inc. requests the SWS approval for a continuation of the 5-yearPermit to Operate for Phase 1 and a Permit to Construct for Phase 2 at A-1 Sandrock
C&DLF.After completing a review of the PTC Application (DIN 22964), the SWS has several
comments, they are:1. Please provide the revised drawings mentioned on the “Revised Sections) which are
missing from the PTC Application.
2. Based on previous experience on processing the permits for this facility, the SWS mayissue A-1 Sandrock C&DLF one PTC for Phase 2 & two PTOs (one PTO for Phase 2
A and one for entire Phase 2 including 2A & 2B). Therefore, the info related capacitycalculations for Cell 2A & 2B (acreage, waste volume/capacity, life expectance, &
closure elevations of intermediated cover for each cell) must be clearly described in theFacility Plan section, just like the way for Phase 1 – Cells A through C. The drawings
(including cross sections) must clearly delineate the extents for each cell as well [15ANCAC 13B .0537(d) & (e)].
3. (Section 1.3.2, Page 4) The proposed “Permitted Capacity” of 1,086,677 cubic yard
(CY) is likely incorrect. The correct one is 1,078,525 CY which sums up Phase 1capacity (470,332 CY) and Phase 2 capacity (608,193 CY). Please make a necessary
correction.
4. The Section 1.3.4 -Soil Volume Analysis, Page 5 of the approved PTO Application(DIN 20125) needs to be revised by including the volume of the periodical/weekly soil
cover for operating waste disposal at Phase 2 [15A NCAC 13B .0537(e)(2)].
5. (Table 8A) The CSB quality of 31,218 CY is likely incorrect. According to the Note 2of the Table 8 A the CSB volume is the sum of VSL volume (29,258 CY) and the
volume multiplying a shrinkage factor of 15% (29,258 * 0.15= 4388.7 CY). Pleaseverify and revise the cost estimate for closure and summary in Section 10.
6. (Table 8C) The landfill gas monitoring shall be conducted at quarterly basis [15A
NCAC 13B .0544(d)(2)(B)]. Please revise the description.
7. Section 10, Page 87) Phase 2 mentioned in the first sentence of the second paragraph islikely a typo. Please make a necessary correction.
Please send me the required info and respond the comments. I don’t know Christine’s
schedule yet. If she doesn’t have any concerns about the Design Hydro Report dated in 2002,we might wrap up the permit review in February. Have a wonderful day.

Ming Chao
Ming-Tai Chao, P.E. Environmental Engineer
Permitting Branch, Solid Waste Section Division of Waste Management
(Mailing Address)1646 Mail Service Center
Raleigh, NC 27699-1646(Street Address)
Green Square, 217 West Jones StreetRaleigh, 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 PublicRecords Law and may be disclosed to third parties.

From: Garrett, David [mailto:[e-mail]] Sent: Wednesday, January 21, 2015 3:55 PMTo: Chao, Ming-taiSubject: Re: A-1 Sandrock CDLF Phase 2 PTC Thanks. I'm glad to hear from you.
David Garrett PG PESCS Engineers RaleighTel. 919-418-4375
"Chao, Ming-tai" <[e-mail]> wrote:
Hi Dave:
I will be the Engineer to review the PTC-Phase 2A for A-1 Sandrock CDLF, which was
logged and scanned to the document tracking system with a DIN 22964. I can’t speak forChristine, but it is evidently the design hydro report & environmental media
sampling/monitoring plan are not included in this PTC application. You will have to dealwith her later.
There is no review fee for this PTC- Phase 2A application because the permit amendment fee
-$9,000 (for one 5-yr PTO-Phase 1 & PTC for a future phase) has been paid in 12/14/2013. But A-1 Sandrock has to pay the permit modification fee in the amount of $1,500 when the
PTO-Phase 2A is requested.
Please contact me if you have any question of the permit processes. Have a wonderful day.
Ming Chao
Ming-Tai Chao, P.E. Environmental Engineer
Permitting Branch, Solid Waste Section Division of Waste Management
(Mailing Address)1646 Mail Service Center
Raleigh, NC 27699-1646(Street Address)
Green Square, 217 West Jones StreetRaleigh, 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 PublicRecords Law and may be disclosed to third parties.

From: Mussler, Ed Sent: Wednesday, January 21, 2015 1:04 PMTo: Chao, Ming-taiSubject: FW: A-1 Sandrock CDLF Phase 2 PTC
I believe A-1 is yours?
Ed

From: Garrett, David [mailto:[e-mail]] Sent: Thursday, January 15, 2015 8:46 AMTo: Mussler, EdSubject: A-1 Sandrock CDLF Phase 2 PTC
Ed, please see the attached application per earlier discussions.  Please contact me with any
questions or concerns. 

Thank you, in advance.

G. David Garrett, PG, PE
Senior Engineer/Geologist
SCS Engineers, PC
322 Chapanoke Road, Suite 101
Raleigh, North Carolina 27603-3415
Office:  (919) 662 - 3015
Fax: (919) 662 - 3017
Mobile:  (919) 418 - 4375 (preferred)
[e-mail]