3420_OmniSource_ResponsetoClosurePlanComments_FID1404182_20200427

2233 Wal-Pat Rd
Smithfield, NC 27577

Via Electronic Submittal

April 27, 2020

Mr. Ming- Tai Chao, P.E.
NCDEQ, Solid Waste Section
1646 Mail Service Center
Raleigh, NC 27699-1646

Re: Response to March 13, 2020 Comments
Kernersville Landfill Reclamation Project
Forsyth County, North Carolina
Permit No. 3420-INDUS-2005

Dear Mr. Chao:

OmniSource has deferred all responses to your previous comments concerning the
Kernersville Landfill (3420) Permit Closure and Post-Closure Plan (Plan) to our
engineering firm (LaBella), while this letter outlines OmniSource’s proposed actions to
your latest comments (March 13, 2020). Once all issues have been resolved to the
satisfaction of OmniSource and DEQ, LaBella will be requested to amend the Plan for
submittal. Hopefully, this approach will expedite the approval process and clarify
communication issues.

OmniSource’s Proposed Actions

Written and Notarized Schedule
At no time does OmniSource plan to enter into a written closure schedule agreement. As
with our first estimated closure schedule (submitted June 2018), any schedule is totally
dependent on when DEQ approves the Plan, not including weather conditions and the
current COVID-19 situation. In fact, OmniSource has been ready to complete both
grading of waste and application of intermediate cover for over two years, but have yet to
receive approval of final grade from DEQ. Therefore, OmniSource feels that Section 3.2
(Closure Schedule) adequately covers this issue – starting installation of cap within 30
days of completion of reclamation project (final grading & intermediate cover), and
completing cap within 180 days of start.
Mr. Chao, NCDEQ Page 2 of 4 April 27, 2020

Intermediate Cover
It is our interpretation that placement of intermediate cover is part of landfill operations,
and the 12 inch intermediate cover is planned as part of the reclamation process.
Therefore, OmniSource proposes to request that LaBella remove all references to
intermediate cover for the closure.

Soil Quality
We understand your concern as to the quality of soil used in the closure project, however
regulations intended for Land Clearing and Inert Debris Landfills (15A NCAC 13B
.0562) and remediation projects (NCGS 130A-310.65) do not apply to our industrial
landfill. If needed, OmniSource proposes to have LaBella amend Section 2.1 of the Plan
so as to prohibit the use of any cover soils obtained from sites with active remediation
and/or known contamination – therefore, testing program is not required.

Erosion & Sediment Control
As all closure activities will only involve continued disturbance within the active landfill
area and sediment/erosion control measures have been provided with the Plan to meet
requirements established in the Solid Waste Management regulation, it is our
understanding that approval documentation of an E&S Plan by the Land Quality Section
in not a required component of a Closure Plan.

Edge of Waste
As discussed in the March 4th meeting, the Edge of Waste (EOW) for the landfill was
initially determined through geophysical testing at the time of active mining and
processing and assumed that the entire footprint area of the landfill would be mined.
Since this time the following occurrences have taken place: eastern slope was never
minded, which DEQ would not require capping; repair work on the northern berm and
installation of the western access road, which made it possible to accurately determine the
northern and western borders; while it was determined that the allowable extent of the
southern border is limited by current operations. Therefore, OmniSource proposes that
the EOW, at the time of final closure, will be targeted to match that depicted in CP-02
(similar to a greenfield application) and that all waste outside of this boundary will be
placed within the proposed limits, as per permit 3420-INDUS-2005. As these changes
result in an actual decrease in size of the landfill’s 2015 footprint by approximately 4.1
acres (estimated) versus the 0.5 acres referenced in the 2020 Closure Plan, OmniSource
proposes to request LaBella to modify effected text (Section 2.3 of the Plan) and
associated Cost Estimates).

Cost Estimates
OmniSource proposes to request that LaBella amend the Cost Estimates (Closure & Post-
Closure) as follows: verifying/accounting for the full acreage of cap vs. landfill footprint
(see EOW discussion); verifying/account for length of access roads for Financial
Assurance purposes; and verify/account for existing silt fencing Financial Assurance
purposes.

Mr. Chao, NCDEQ Page 3 of 4 April 27, 2020
As for comments/questions which OmniSource deems no action is required: Cost of
intermediate cover – as stated earlier, the intermediate cover is part of reclamation
process and should not be included in estimating closure costs; and Quantity of Diversion
Berms – as depicted in Drawing CP-02, diversion berms on the western edge have been
shortened, while the diversion berms on the south slope side where removed as a result of
the proposed the southern perimeter drainage channel and the relatively flat slope (2.5%
as proposed).

CQA Plan
It is our understanding that LaBella typically uses a generic set of in-house specifications
for all of their CQA plans, which have been approved by DEQ for years. As these plans
are not site specific, items that are not applicable to a particular site are simply to be
ignored.

Considering the above, OmniSource proposes to request that LaBella amend the CQA
Plan as follows: Table 1 to include shear testing; Section 4 to address geosynthetics;
Section 4.2 to detail Record Drawings via listing or reference to Technical Specification
Section 01730; remove mention of Test Pad, as this will not be used for this project; and
to consider any Engineering Best Practice documentation recommending additional
testing frequency provided by DEQ – OmniSource does not feel that the statement
“comparing with other landfill closure projects in the state” alone justifies doubling
testing efforts and costs.

Technical Specifications
As with the CQA Plan, it is our understanding that LaBella typically uses a generic set of
in-house specifications for all of their Technical Specs, which have been approved by
DEQ for years. As these plans are not site specific, items that are not applicable to a
particular site are simply to be ignored.

Considering the above, OmniSource proposes to request that LaBella amend the
Technical Specifications as follows: change reference of ASTM D 422 to read ASTM D
6913 in Section 02200 – 1.02B, Section 02500 – 1.02, and Section 13400 – 3.01; add to
Section 13315 – 3.03 (Earthwork) requirement that contractor verify adequate depth (12
inches) of intermediate cover via bore samples (4 per acre – leave to discretion of
LaBella) prior to installing GCL; removal of Anchor Trench requirements and Section
02500 (stone surfacing), as not applicable to this project.

As for comments/questions which OmniSource deems no action is required: Section
01720 – Top of Waste drawings are not required as Closure does not begin until
intermediate cover has been completed, and although Edge of Waste drawings will be
part of LaBella’s final submittal to DEQ they will not be the responsibility of the
contractor; Section 02100 – requirement that all waste be placed within the footprint of
the landfill, which is adequately covered under ‘Removal and Disposal of Debris’ (3.05);
Section 02200 – appears that current section adequately describes Earth Work
requirements, including the requirements of the top most intermediate cover layer in both
Mr. Chao, NCDEQ Page 4 of 4 April 27, 2020
3.13 and Section 13315-3.03. Section 13302 – Daylighting is specified in drawings and
will defer to LaBella’s professional opinion as to thickness testing and seating time.

Drawings
OmniSource proposes to request that LaBella amend the drawings as follows: correct
Note 1 in CP-03A from 120 ft to 130 ft; add geotextile under riprap at inlet protection in
CP-03A & F; and add existing western and northern silt fencing to CP-02.

As for comments/questions which OmniSource deems no action is required: anchor
trenches not required with this project; CP-03 – all slopes are 3.5:1, therefore there is no
need to provide detail per Section 13315; and CP-03A, Detail A – details explaining
thicker line (matting) found in CP-03 can be found in Detail B.

In conclusion, OmniSource respectfully requests that DEQ supply us with written
comments identifying any regulatory and/or technical deficiencies associated with our
proposed actions and/or any other item identified in the Plan not previously brought to
our attention within fifteen (15) days. We would also respectfully request that any
questions and/or differences in professional opinion be handled informal through direct
communications (via phone or email) with LaBella.

Thanks again for your patience and assistance in this matter.

Sincerely,

James B. Winegar
Environmental Manager

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

From:Winegar, James
To:Chao, Ming-tai
Cc:Stanley, Sherri; Heim, Susan A; Michael A. Hofmeister; Aja, Deborah; Ritter, Christine
Subject:[External] RE: Comments on Closure and Post-Closure Plan, OmniSources ILF, 3420
Date:Monday, April 27, 2020 3:02:18 PM
Attachments:image002.png2020-04-27 OmniSource Response to DEQ Closure Plan Comments 3420-IND-2005.pdf
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In response to your March 13th comments concerning the Closure and Post-Closure Plan for our
Kernersville landfill (3420-IND-2005), I respectfully submit the attached document for your
consideration.

Once we have resolved all issues, I will request that LaBella submit an amended final Plan.
Hopefully, this will approach will speed up the process and clarify past communication issues.

Let me know if there are any questions…

Thanks,

James Winegar
Environmental Manager
919.989.3102 - work
919.796.3023 - cell

From: Chao, Ming-tai [mailto:[e-mail]] Sent: Friday, March 13, 2020 5:50 PMTo: Winegar, JamesCc: Stanley, Sherri; Heim, Susan A; Michael A. Hofmeister; Aja, Deborah; Ritter, ChristineSubject: [External] Comments on Closure and Post-Closure Plan, OmniSources ILF, 3420

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Dear Mr. Winegar:
Please review the attached comment letters. If you have any questions of the comments on theClosure and Post-Closure Plan for your facility, please contact me. Thanks and have a
wonderful weekend.