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Home My WebLink About0105_CobleC&DLF_permitdecision_FID1387209_202001081 Chao, Ming-tai From:Chao, Ming-tai Sent:Wednesday, January 08, 2020 11:36 AM To:Deanna Martin (deanna@coblesinc.com) Cc:Davis, Amy; Hofmeister, Mike; Joyce, Leonard; Kemppinen, Hannu; 'brendalcoble@bellsouth.net'; Stanley, Sherri; Rice, Sarah M; Kirchner, Chuck; Aja, Deborah Subject:Permit application for Coble C&DLF, 0105-CDLF-1998 Attachments:RE: [External] FW: Cobles Sandrock, permit 0105-CDLF-1998 - Financial Assurance Hey Deanna: Happy New Year. The Solid Waste Section (SWS) has completed reviews of the permit application for a continued operation of the Coble’s C&DLF – Phases 1, 2, 3A and the PTC application for Phase 3B; please inform your consultant to submit the SWS a complete permit application document – an electronic copy only. Two remain major issues prohibit the new life-of-site permit being issued to Coble’ Sandrock Inc. (Operator) & Coble’s LLC & Ken & Brenda Coble (Landowner). The two major issues are: 1. Correct property deed information and landfill property survey map. The deed info appended to the Operations Plan is out of date. The deed info obtained from Alamance County Register of Deed Office shows Coble’s LLC owns the major portions of the landfill property. The SWS made requests to your attention to provide correct deed info in October 2019, and as of today, the SWS has not received the requested info. 2. Financial assurance. You bonding agent was informed (see attachment) the FA for closure and post- closure costs are increased because the permit application requests to operate 9.13 acres instead of the originally approved 4-acre disposal area. As of today, I have not get an official approval of FA from the SWS compliance officer. The landfill permit has expired on September 02, 2019. To avoid permit being revoked by September 02, 2020 per NCGS 130A-295.8(e), please resolve the above-mentioned issues in a timely manner. If you need any assistance in the permitting processes, please feel free to contact me. From: Kemppinen, Hannu <HKemppinen@LaBellaPC.com> Sent: Tuesday, December 10, 2019 10:57 AM To: Chao, Ming‐tai <ming.chao@ncdenr.gov> Cc: Deanna Martin (deanna@coblesinc.com) <deanna@coblesinc.com>; Davis, Amy <ADavis@LaBellaPC.com>; 2 Hofmeister, Mike <MHofmeister@LaBellaPC.com>; Joyce, Leonard <LJoyce@LaBellaPC.com> Subject: [External] 0105‐CDLF‐1998_20191210 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Dear Ming, On behalf of Coble’s CD landfill Labella is submitting the attached document for responses to the Section comments dated November 1, 2019 (FID1357327). This submittal includes the responses to comments letter with pertinent attachments. Following your review, if you require further clarification, we are available to help and please feel free to contact us. Hannu Kemppinen, PG LaBella Associates | Senior Project Manager 336-790-2252 direct 336-323-0092 office 336-209-7156 mobile 2211 West Meadowview Road, Suite 101 Greensboro, NC 27407 labellapc.com | Your Joyce Engineering Team Under a New Name 1 Chao, Ming-tai From:Chao, Ming-tai Sent:Thursday, December 19, 2019 11:40 AM To:Tom Smith Cc:Mussler, Ed; Stanley, Sherri; Rice, Sarah M Subject:RE: [External] FW: Cobles Sandrock, permit 0105-CDLF-1998 - Financial Assurance Dear Mr. Smith: According to the Closure/Post-Closure Plan for the Coble’s C&DLF in the latest permit application dated December 10, 2019 (FID 1378626), the area that subject to final closure is 9.3 acres of 18.3-acre permitted disposal boundary. The area that has been permanently closed and certified for substantially closed in the closure CQA report (DIN 24357) is 9.13 acres. So in short, - The cost for closure of 9.3 acres is approximately $464,446 dollars for closure Option 1 – prescribed cover system or $803,632 dollars for closure Option 2 – alternative cover system. Cobles must decide which option will be selected. - The cost for a minimum of 30-year post-closure cares of 18.3 acres is $2,488,064.04 dollars. According to the permit application that Coble ‘s C&DLF has permanently closed portion of Phase 3A area; but the rule-required closure CQA report is not received by the Solid Waste Section (SWS) yet. Therefore, the SWS can not confirm if the closure activities are occurred at all. Consequently, the SWS shall not allow decreasing the closure cost stated above. If the Phase 3A closure CQA report (including as-built closure survey drawing(s) signed/sealed by a NC licensed surveyor) that is certified by a NC Professional Engineer is received and approved by the SWS after a review, then the closure cost will be reduced accordingly. A site walk and the closure inspection are only portions of permit reviewing processes. There is NO reduction of the post-closure care cost. Please contact me if you have any question of the costs of landfill closure and post-closure cares. Regards, From: Rice, Sarah M <sarah.rice@ncdenr.gov> Sent: Thursday, December 19, 2019 10:07 AM To: Tom Smith <TSmith@smithmanus.com>; Chao, Ming‐tai <ming.chao@ncdenr.gov> Cc: Mussler, Ed <ed.mussler@ncdenr.gov>; Stanley, Sherri <Sherri.Stanley@ncdenr.gov> Subject: RE: [External] FW: Cobles Sandrock, permit 0105‐CDLF‐1998 ‐ Financial Assurance Ming-Tai, Chao Environmental Engineer, Solid Waste Section Division of Waste Management North Carolina Department of Environmental Quality 919.707-8251 (Office) Ming.Chao@ncdenr.gov 2 Good morning Tom, Portions of the landfill that are closed are still considered in the financial assurance if the units are not certified closed. I will defer to Ming Chao, the Solid Waste Section permitting engineer for the facility. He would be able to answer your question. Ming, We would greatly appreciate your assistance on clarifying Tom’s question: Cobles Sandrock initially had a permit covering 4 acres and now is increasing their acreage to 9.3 acres. I’m told the initial 4 acres is closed except for approximately 1 acre. Does the State make any sort of inspection on the initial acreage and if found to be suitable closed thereby allow the State to process a partial reduction in the bond limit required. With the additional acreage the bonding requirement for Cobles Sandrock is increasing form $1,093,901 to a new limit of $2,970,851 – a significant increase and as you can imagine the underwriting by the bonding company increases correspondingly. Just trying to see if there is any potential reduction in order. Appreciate your comments. Regards, Sarah Sarah Rice Environmental Program Consultant Division of Waste Management – Solid Waste Section North Carolina Department of Environmental Quality 919‐707‐8287 (phone and fax) Sarah.Rice@ncdenr.gov 217 West Jones Street 1646 Mail Service Center Raleigh, NC 27699 NC DEQ: Solid Waste Section NC DEQ: Financial Assurance Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Tom Smith [mailto:TSmith@smithmanus.com] Sent: Wednesday, December 18, 2019 3:55 PM To: Rice, Sarah M <sarah.rice@ncdenr.gov> Subject: [External] FW: Cobles Sandrock, permit 0105‐CDLF‐1998 ‐ Financial Assurance CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Sarah: We continue to work on providing the increase in the bond limit required by Cobles Sandrock. We’ve actually received authorization from the bonding company, however in view of the increase the bonding company has included the need for added security. 3 Cobles Sandrock initially had a permit covering 4 acres and now is increasing their acreage to 9.3 acres. I’m told the initial 4 acres is closed except for approximately 1 acre. Does the State make any sort of inspection on the initial acreage and if found to be suitable closed thereby allow the State to process a partial reduction in the bond limit required. With the additional acreage the bonding requirement for Cobles Sandrock is increasing form $1,093,901 to a new limit of $2,970,851 – a significant increase and as you can imagine the underwriting by the bonding company increases correspondingly. Just trying to see if there is any potential reduction in order. Appreciate your comments. Tom Smith Smith Manus 2307 River Road, Suite 200 Louisville, KY 40206 502-238-1208 (phone) 502-238-1209 (fax) 502-548-7483 (mobile) 800-235-9347 (toll free) tsmith@smithmanus.com www.smithmanus.com From: Tom Smith Sent: Friday, November 15, 2019 4:28 PM To: Rice, Sarah M <sarah.rice@ncdenr.gov> Subject: RE: Cobles Sandrock, permit 0105‐CDLF‐1998 ‐ Financial Assurance Sarah: Thanks for your response. Your comments and the information you forwarded is exactly what we were trying to develop. Thanks for your quick response. Tom Smith Smith Manus 2307 River Road, Suite 200 Louisville, KY 40206 502-238-1208 (phone) 502-238-1209 (fax) 502-548-7483 (mobile) 800-235-9347 (toll free) tsmith@smithmanus.com www.smithmanus.com From: Rice, Sarah M <sarah.rice@ncdenr.gov> Sent: Friday, November 15, 2019 11:45 AM To: Tom Smith <TSmith@smithmanus.com> Subject: Cobles Sandrock, permit 0105‐CDLF‐1998 ‐ Financial Assurance Good morning Tom, 4 I received your voice mail regarding the question of the Coble’s financial assurance increase. The facility requested to increase their operating acreage to 9.3 acres from 4 acres in their permit renewal application. I have included their consultants 2019 Financial Assurance estimate. I have also included the facility’s 2016 Permit To Operate, which only allows the permittee to operate no more than 4 acres for landfill disposal at any time. The 2016 permit acreage restrictions is why they have only had a steady inflation increase over the years. Hopefully this information assists with the question of the significant increase of the facility’s bond amount. Regards, Sarah Sarah Rice Environmental Program Consultant Division of Waste Management – Solid Waste Section North Carolina Department of Environmental Quality 919‐707‐8287 (phone and fax) Sarah.Rice@ncdenr.gov 217 West Jones Street 1646 Mail Service Center Raleigh, NC 27699 NC DEQ: Solid Waste Section NC DEQ: Financial Assurance Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.