3420_Omnisource_ILF_comments_revisedC&PC_FID1394198_20200313

ROY COOPER
Governor

MICHAEL S. REGAN
Secretary

MICHAEL SCOTT
Director
Solid Waste Section

##, 2020
Sent via an e-mail message
Mr. James B. Winegar
Environmental Manager
OmniSource Southeast, LLC
1426 W. mountain Street
Kernersville, NC 27284

Re: Comments on Permit Closure and Post-Closure Plan
Kernersville Landfill Reclamation Project
Forsyth County, North Carolina
Permit No.3420-INDUS-2005, File Identification No. (FID) XXX

Dear Mr. Winegar:

The Division of Waste Management (DWM), Solid Waste Section (the SWS) completes a
review of the following documents:
• Permit Renewal Response to Comments, OmniSource – Kernersville Landfill
Reclamation Project. Prepared by Labella. Dated March 2020 and received by the SWS
on March 12, 2020. (FID1394191). This submittal includes the revised Closure and Post-
Closure Plans.

Based on the reviews, the SWS has comments on the Permit Application which are stated below.
1. (Sections 1.2 & 2.5) The Solid Waste Section does not agree the statement in the last
paragraph in this Section because the mining/reclamation project at this site has been
terminated in March 2018 (Refer to Facility Compliance Inspection Report on July 18,
2018). Since then, OmniSource reports the landfill under regarding, and two years later
the site regrading is still incomplete. OmniSource should provide
i. The firm date of the completion of the landfill site regrading which is considered
as the official closure notification date.
ii. The firm date of beginning the landfill closure activities.
iii. The firm date to complete the landfill closure activities and submit a certified
CQA report for closure. And
iv. The signed, dated, and notarized a written agreement with the above-mentioned
closure schedule.
Please be advised that the closure schedule MUST BE REASONABLE; otherwise, the
Solid Waste Section will take action in a manner as stated in Section 2.5 – “Final closure
of the landfill will commence … as directed by the North Carolina Department of
Ms. Jan McHargue, PE
##, 2020
FID XXX
Page 2 of 40

Environmental Quality (NCDEQ) Division of Waste Management – Solid Waste Section
(the Division).

2. (Section 2.1 & the CQA Plan – Section 2 - Earth Material & Technical Specification –
Section 02200 -Earthwork, Part 3.11) According to the quantity of soil in the cost
estimate for the closure activities, construction of the proposed final cover system
requires approximately 70,000 cubic yards (CY) soil material consisting of 27,749 CY of
12-inch-thick intermediate cover, 27,749 CY of 12-inch-thick vegetative support/erosion
layer, and 13,875 CY of 6-inch-thick topsoil layer. Because there is no sufficient on-site
borrow to supply the required soil for the site closure, the off-site borrow is required. The
off-site soil source(s) shall be satisfactory the following requirements which should be
added to the Specification – Section 02200 & the CQA Plan:
A. The borrow source has the NC mining permit. The permit info (facility name and
permit number) and shipping documents including material type & quantity of each
borrow shall be included in the CQA report. Or
B. If the off-site soil that is from an unpermitted source, then
i. The earthen material may be considered as the beneficial fill as defined in
Rule 15A NCAC 13B .0562. Prior to accepting the fill material to the project
site, Omnisource shall
a. Obtain a zoning approval per Rule 15A NCAC 13B .0562(4). A copy of
the zoning approval letter shall be appended to the CQA Plan.
b. Test soil/fill material for chemical analyses by a NC certified laboratory to
demonstrate that the soil/fill meet the “unrestricted use standards" -
meaning concentration of a contaminant, if any, for each borrow that is
acceptable for all uses per NCGS 130A-310.65. Analytical test results
must show any contaminant of concern with a concentration less than or
equal to that in the NC Industrial/Commercial Health Base Preliminary
Soil Remediation Goal (NC PSRG) which can be found in the web link:
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SF/RiskBasedRe
mediation/updates-december-2019/1.-2019-Dec-PSRG-Table.pdf. The
testing program should be included in the CQA Plan and the Specification
– Section 02200 (Parts 3.11 & 3.12). The testing results should be
available for review and approval by the Engineer in the pre-construction
meeting (Section 1.4 of the CQA Plan)

3. (Section 2.1)
i. What is the proposed side slope of the final cover system?
ii. Should the GCL and Geocomposite Drainage material be anchored down in the
designed anchor trenches at the designated locations? The anchor trench design is
not available in the Closure Plan.

Ms. Jan McHargue, PE
##, 2020
FID XXX
Page 3 of 40

4. (Section 2.2 & Erosion & Sediment Control Calculations) Has the closure activities
involving land disturbance to the extent over 17.2-acre area received an approval or
permit from the NC Land Quality Section, as stated in Part 3 of Specification Section
01568? The approval document shall be appended to the Closure Plan.

5. (Section 2.3) The Closure Plan in the permit applications dated 2014 and 2017 stated that
the landfill encompasses 19.5-acre waste footprint with a 2.3-acre disposal area never
being subject to disturbance [referring July 31, 2015 Responses (DIN 24839) to
Comment No 5]. Now the Closure Plan dated 2020 reports the landfill has 19-acre waste
footprint with 1.8-acre closed area was never disturbed.
i. Why is the landfill waste footprint changed? Has there been a new study or
investigation of identifying landfill waste footprint being conducted after 2017?
ii. Facility Compliance Inspection Reports (from July 18, 2018 through February 27,
2020) stated that the auto shred fluff wastes/residuals (ASR) were observed in the
sediment pond/basin and forebay, drainage ditches, on the side slope of earthen
berm, dirt road, and outside the landfill disposal cells. The observations are
summarized below:
Report Date Observation Page No./Item No.
February 27, 2020 The roadway appeared to have ASR waste
from the landfill incorporated into it.
2 of 10/ item 5
February 27, 2020 The portion of the new section of swale
that had not been rip-rapped contained
deposits of sediment and what appeared to
be waste.
3 of 10/ item 8
February 27, 2020 The forebay itself was observed to be full
of sediment and waste, and ponding water
was evident on the southeastern end.
3 of 10/ item 11
March 19, 2019 The western perimeter roadway is
constructed of ASR waste from the landfill.
2 of 8/Item 6
March 19, 2019 The rock bin still appeared to be buried
under the mixture of sediment and waste
that had been observed during the October
2018 inspections.
3 of 8/Item 12
March 19, 2019 It is estimated that an additional 39,000
cu. yds. of waste remains stored on the
ground in the area of the former processing
plant that must also be reincorporated into
the landfill footprint.
3 of 8/Item 14
October 5, 2018 it was evident that the forebay had been
overrun with sediment, waste from the
landfill, and soil.
2 of 12/ Item 4
Ms. Jan McHargue, PE
##, 2020
FID XXX
Page 4 of 40

October 5, 2018 The flow of water had deposited waste and
sediment across the toe of the landfill and
the forebay, overwhelming the slope drains
leading to the sediment basin below.

2 of 12/ Item 5
October 5, 2018 Some waste was observed throughout
material strewn downhill by the failed
slope.
2 of 12/ Item 6
October 5, 2018 The sediment basin had been filled and the
curtain boom appeared to be holding back
the majority of the sediment and waste that
had accumulated in it.
2 of 12/ Item 7
October 5, 2018 This lower area had also been covered over
with a mixture of sediment and waste.
Liquid was observed flowing downhill
from this flat, clear area toward the stream
below.
2 of 12/ Item 8
Omnisource must remove all wastes from the sediment pond/forebay after
dewatering and wastes from the previous waste reclamation/processing area,
roads, and earthen berms. The collected/removed waste must be placed back into
the landfill cell prior to placing a final cover system over the landfill. The
Technical Specification – Section 02100 should include the requirement of
removing wastes from areas outside the landfill cell and the written certification
to confirm that all wastes from areas outside the landfill cell have been clean
up/removed according to the specification. This written certification must be
signed by the representative of Omnisource and the Engineer.
iii. Drawing CP-02 notes that “LIMITS AS INDICATED TO BE FIELD VERIFIED
PRIOR TO CONSTRUCTIN FINAL COVER.” The Closure Plan does not
provide any protocol or measure to identify the waste boundaries. Please provide
a working plan to field verify the waste boundaries prior to constructing a final
cover system. The waste boundary confirmation must be incorporated into the
final as-built drawings appended to the certified CQA Report.

6. (Cost Estimate for Closure & Drawing CP-02)
i. The costs associated with installing the 12-inch-thick intermediate soil cover is
not available.
ii. The quantities for Diversion Berms – Construction & E&S Matting are
significantly reduced than those in 2017 cost estimates as shown below:
Cost item Quantity (linear feet)
2017 2020
Ms. Jan McHargue, PE
##, 2020
FID XXX
Page 5 of 40

Construction 6,800 4,745
E&S Matting 6,800 2,840
Please explain why the adjustment of the quantity of the berm is warrant.

iii. The silt fence will be used as a BMP for the erosion and sediment control during
the course of the closure activities; but the amount of silt fence is 135 linear feet
in the cost estimate. Is it a typo? The 2017 cost estimate shown the quantity of
silt fence to be used is 3,000 linear feet. Please justify the amount reduction if the
stated amount of 135 linear feet is not a typo.

7. (Post Closure Cost Estimate)
i. Cost for the Cost Item - Erosion Control Features Maintenance bases on the
construction cost of Closure. If the Closure Cost is revised, this cost shall be
revised accordingly.
ii. Cost of $3,750 for All-Weather Access Roads Maintenance is incorrect. (2500
linear feet X $3 per linear feet = $7,500)

8. (CQA Plan)
i. (Section 2.33) Is a teat pad for compacted clay liner required for this proposed
final cover system? Please clarify.
ii. (Table 1) The following test frequencies are not acceptable or not available.
a. In comparing with other landfill closure project in the state, the testing
frequency for “in-place density by Sand Cone ASTM D1556 or Drive
Cylinder ASTM D2937)” and “In-place Density & Water Content by Nuclear
Method ASTM D5084” for this landfill closure project are far too lower than
those used in other project (1/lift/acre or 5/lift/acre).
b. The Solid Waste Section disagrees the Response to 07/09/2018 Comment No.
20 which defers the CQA testing requirements to CQC testing in the
Specification Section 13400. The CQA testing on earthen material from
borrow source is a must. Table 1 should have listed soil shear strength tests –
test frequency and testing method; the tested strength shall be equal to or
exceed the design parameter used in the slope stability analysis – both global
and veneer slope stability analyses.
c. (Section 4.0) Replace “Geomembrane” to geosynthetic material in the entire
Section.
d. (Section 4.2) The Record Drawings stated in this Section is irrelevant to the
proposed final cover system. In a minimum, the as-built drawings must
include: i) the top elevations of the waste, ii) complete grades of the 12-inch-
thick intermediate soil layer, iii) panel layout of GCL, iv) the final grades of
the 18-inch-thick vegetative support & topsoil layer. The items i) ii) & iv)
shall demonstrate the specified thicknesses are achieved.
Ms. Jan McHargue, PE
##, 2020
FID XXX
Page 6 of 40

9. (Technical Specification - Section 01720)
i. (Part 3.08B) The as-built drawings and survey data must demonstrate that the
specified minimum thickness of each soil/earthen layer of final cover system is
achieved.
a. In a minimum, the as-built drawings must include: i) the top elevations of the
waste, ii) complete grades of the 12-inch-thick intermediate soil layer, iii) the
final grades of the 12-inch-thick vegetative support & iv) the top elevations of
topsoil layer.
b. Special attention to the measurement of thickness at sloped area must be
specified.
ii. (Part 3.08) The as-built drawing of the landfill waste footprint after the limits
have been identified and confirmed in the course of final cover construction – ref.
note on Drawing CP-02.

10. (Technical Specification - Section 02100)
i. (Part 3.03) The wastes observed and documented in Comment No. 5ii shall be
removed and placed back into the landfill cell. The requirement shall be included
in the Specification.
ii. (Part 3.05) Identification and confirmation of the landfill waste limits must be
specified in this Section.

11. (Technical Specification - Section 02200)
i. (Part 1.01) The earthwork should specify the tasks regarding the construction,
backfilling, and grading of intermediate soil cover, vegetative protective and
topsoil layer.
ii. (Part 1.02B) The ASTM D 422 shall be replaced by new ASTM designation.
iii. (Part 2.01) This subpart specifies that fill material shall have a minimum internal
friction angle of 26 degrees. Is this angle equivalent to or exceeding the design
parameter used in the slope stability analyses both Global & Veneer Slope
Stability Analyses?

iv. (Part 3.10A) The landfill has not placed any intermediate soil cover over the ASR
ever, the stripping vegetation over the soil cover is no needed. Instead,
a. Specify the spreading, compaction, and grading the fill to construct 12-inch-
thick intermediate soil cover in this subpart.
b. The top intermediate soil cover will intimately contact the GCL, the maximum
grain size shall be specified and consistent with that in Section 13315 – Part
3.03B.

12. (Technical Specification - Section 02500)
Ms. Jan McHargue, PE
##, 2020
FID XXX
Page 7 of 40

i. Please specify and identify where the “Stone Surfacing” is constructed on the
drawings.
ii. (Part 3.04 A) The Section 01410 is not available in the Technical Specification.

13. (Technical Specification - Section 13302, Table 1)
i. (Part 3) According to the appended design of “Minimum Transmissivity of
Geocomposite,” the drainage geocomposite will daylight every 130 feet along the
sloped area as shown Detail A of Drawing CP-03A. Please add this requirement
to this Part.
ii. The thickness of Geonet should be tested. The testing method, frequency, and the
minimum value of 275 mil (ref the closure cost estimate) shall be include in the
Table 1.
iii. What is the minimum seating hour prior to conducting transmissivity test?

14. (Technical Specification - Section 13400, Part 3.01B) The ASTM D 422 shall be
replaced by new ASTM designation.

15. The anchor trench design is not available.

16. Drawings
i. The discrepancy of the landfill waste footprint (on the southside of the landfill) is
shown on Drawing CP-01 & CP-02.
ii. (Drawing CP-02)
a. Is there reason why the stormwater division berms on the south side slope
areas being removed from this revision? The slope lengths are more than apex
point to the perimeter draining ditch are more than 300 feet; Is this design
satisfactory to the requirements in NC Erosion and Sediment Planning and
Design Manual?
b. Why silt fence is not required to be installed around the perimeters outside the
landfill cover construction area? If disturbance due to waste removal in the
former waste reclamation area is required, the silt fence may shall enclose the
disturbance area as well.
iii. (Drawings CP-02 & CP-03) The anchor trench details and locations on the
layout/plan drawings are not available.
iv. (CP-03)
a. Should there be a layer of geotextile under the riprap of the inlet protection
shown in Detail F (Specification Section 02274)?
b. According to Specification - Section 13315, two type of GCLs – reinforced
and non-reinforced GCL will be deployed. The CP-02 and Detail A shall
provide a clarification of which areas will be used reinforced GCL and non-
reinforced GCL, respectively.
v. (CP-03A)
Ms. Jan McHargue, PE
##, 2020
FID XXX
Page 8 of 40

a. (Detail A) Is the Diversion Berm downstream of the geocomposite
outlet/daylight lined/protected by any device? The drawing detail shows
thicker line inside the V ditch. Please clarify.
b. (Detail A) Add a note that the drainage geocomposite will daylight every 130
feet along the slope.
c. Should there be a layer of geotextile under the riprap of the inlet protection
shown in Detail C (Specification Section 02274)?
vi. The erosion control matting & silt fence are specified in the Specification Section
– 01568 & the quantities are estimated in the Closure Cost Estimate, but the
drawing does not show areas that is required to use the matting or silt fence. No
detail of matting installation is available on the drawings, either.

If you have any questions you may contact me at 919-707-8251 [e-mail].

Sincerely,

Ming-Tai Chao, P.E.
Environmental Engineer
Division of Waste Management, NCDEQ

cc:
Michael Hofmeister, LaBella Sherri Stanley, Permitting Branch Supervisor
Susan Heim, DWM Deb Aja, DWM
Christine Ritter, DWM Central Files