4116_WIHighPoint_CDLF_InspectionResponsetoComments_DIN27070_20161128

November 28, 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 – Inspection Meeting Follow-up
High Point, North Carolina

Dear Mr. Gaither:

Smith Gardner Inc. (S+G) is pleased to respond to your comments from the November 9, 2016 on-site
inspection (Attached) on behalf of WI High Point Landfill. Please find our responses (bold)
corresponding to your comments presented in italics.

Comment 1:
Clarify in the Ops plan how material yet to be sorted will be stored overnight, specifically is it to be
containerized and covered to prevent litter and possible leaching if it rains. Also specify if we would
tarp the containers or place them under the sorting roof.

Response: The following paragraph has been added to Section 4.5:

If unsorted materials remain on the sorting pad at the end of the day, they will be placed in
containers for storage overnight and covered with tarps or placed under the sorting roof to
prevent litter or possible leaching if it rains.

Comment 2:
If agreeable, keep the 10 year permit for another year or so until the life of site situation is figured out
within the DWM

Response: It is acceptable to retain the 10 year permit for an additional year or so while the
DWM finalizes the details regarding life of site permitting, provided there are no onerous or
costly changes.

Comment 3:
Processing Permit expires in 2019 and can be renewed until 2021 at this time.

Response: Please also renew the Processing Permit at this time.

DocuSign Envelope ID: 77BEA259-3A61-4246-AA4B-168DE4C09AF0
Mr. Allen Gaither
November 28, 2016
Page 2 of 3
Comment 4:
Christine Ritter is waiting for approval from the Corps of Engineers and the updated monitoring plan
including the new wells.

Response: We anticipate receiving the permit from the Corps of Engineers in early December.
Updates, including new monitoring well locations, to the LFG Plan and the WQM Plan are
provided with this response to comments.

Comment 5:
Please update our Asbestos plan for the sorting pad. Demonstrate, from an inspection standpoint that
there is an approved plan for the sorting pad and are identifying possible asbestos like material that
may mistakenly come to the pad for sorting.

Response: A new Asbestos Operations Plan for the Recycling of C&D Building Materials has
been developed and submitted to the Health Hazards group for approval. A draft plan is
included as Appendix D to the Operations Manual.

Comment 6:
Update the Ops plan to include all of the ADC options used at the site.

Response: Section 2.4 Periodic Cover has been expanded to address alternate daily cover
options.

Comment 7:
Remove the text that requires the facility to retain records of where recycled materials are
transported.

Response: Reference to maintaining records for recycled material transportation locations has
been removed from the Ops Plan, Section 4.10.

Comment 8:
Reflect in the Ops Plan that the site is allowed to recycle material at the workface when feasible.

Response: The following sentence has been added to Section 4.0.

In the event a load is tipped on the working face that was intended for the recovery area, the
operator and Waste Industries reserve the right to retrieve recyclable materials from that load.

DocuSign Envelope ID: 77BEA259-3A61-4246-AA4B-168DE4C09AF0
Mr. Allen Gaither
November 28, 2016
Page 3 of 3

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 Operations Plan Text
Revised Water Quality Monitoring Plan
Revised Landfill Gas Plan

cc: Seth Heath, Waste Industries
David Pepper, Waste Industries
Christine Ritter, NCDEQ
John Patrone, NCDEQ
Ed Mussler, NCDEQ
File
DocuSign Envelope ID: 77BEA259-3A61-4246-AA4B-168DE4C09AF0
11/28/2016
11/28/2016