0105_CobleCDLF_3rdcomment_permitApp_FID1360681_20191101

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Chao, Ming-tai
To:Kemppinen, Hannu
Cc:Deanna Martin ([e-mail]); [e-mail]; Joyce, Leonard; Davis, Amy;
Bertolet, Larry; Stanley, Sherri; Sugg, William P
Subject:Comments on 10/24/19 submittal, Coble CDLF, 01-05, FID
Hi Hannu:

The Solid Waste Section completed a review of the 10/24/2019 submittal (FID 1360316) and have comments
stated below:

1. The additional comment on 10/15/2019 Response No. 2. There are two LCIDLF units shown on
Drawing No. EP-01 in the Permit Application dated August 23, 29 and received by the SWS on August
29, 2019 (FID 1357327), and there are no notes on EP-01 to indicate which LCIDLF is ALAMA-2002-
028 and which one was mined for the past several years described in the permit application. The permit
application should provide the following info:
i. On Drawing No. EP-01, note which LCIDLF unit is ALAMA-2002-028 and the notification or
permit number of the second LCIDLF unit.

ii. For the LCIDLF unit which permit number was unbeknown previously, the Facility Plan should
provide the landfill status, the waste footprint, the permit or notification number. If this landfill
unit is located future Phase 4 area and was previously mined for soil and woody material for
permitted use, what the status of the landfill – not just said “the LCID IS CLOSED.” Is there a
big hole left in the ground? How the site is restored?

2. The additional comment on 10/15/2019 Response No. 3ii. The SWS requires the demonstration by a
model, acknowledged by the waste industries such as HELP Model or an equivalent one, that the
proposed alternative final cover system can substantially reduce the amount of infiltration than that from
the prescribed final cover system. The amount of leachates generated from the prescribed cover system
and the alternative cover system should be calculated by the model and represented in the application.

3. (Closure Plan) Regarding the closure cost estimates for the alternative cover system, please address the
following concerns:

i. Please add the costs for material and installation of the specified geosynthetic drainage
composite material or the drainage tube.

ii. The unit cost for GCL (material & installation) is lower than two others recently closure projects
in the nearby counties in NC - Davidson County CDLF and Granville County CDLF. Please
clarify why the lower price is acceptable.

4. CQA Plan and Specifications
i. The specifications for survey & project record document and erosion and sediment control are
not available (See 09/10/2019 Comment No. 6.i) in the new submittal. In a minimum the
specification for survey & project record document should include the credential/registration of
surveyor, the survey methods (chess-grid pattern, topo variations, & accuracy to confirm the
specified thickness of each component of the final cover system – top surfaces of subgrade/
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wastes, intermediate layer, CCL, and the final grade, and as-built / record drawing format,
preparations, and final submittal.

ii. (Section 02100 – Site Preparation & Restoration - Part 3.05D) Regarding the open burning of
land clearing debris generated on-site for a site construction, in addition to being approved by
local ordinance and the fire marshal, the open burning at the landfill must also follow the
requirements in Rule 15A NCAC 13B .0542(i)(2).

iii. (Section 02224 – Intermediate Soil Layer, Part 2)
a. According to Table 1 of the CQA plan, the soil layer shall have the minimum shear strength,
in term of the friction angle of 26 degrees. Please add this passing criterium to this section. 
b. The GCL layer, if used, will intimately contact the intermediate soil layer; therefore, the
maximum soil grain size of the intermediate soil layer must be specified to prevent the GCL
from puncture damage (See Part 3.03B of Section 13315-6). The earthen material used for
this layer must be tested. Please specify the testing method, frequency and passing criterium
in this section and the Table 1 of the CQA plan should be revised accordingly.

iv. (Section 02224 –Soil Protective Layer, Part 2)
a. According to Table 1 of the CQA plan, the soil layer shall have the minimum shear strength,
in term of the friction angle of 26 degrees. Please add this passing criterium to this section.
b. The geocomposite drainage material (GD), if used, will intimately contact the soil protective
layer; therefore, the grain size of earthen material/vegetative support layer (matching AOS of
GD) must be specified to prevent the GD from clogging. The earthen material used for this
layer must be tested. Please specify the testing method, frequency and passing criterium in
this section and Table 1 of the CQA plan should be revised accordingly.

v. (Section 02229 – Low-Permeability Soil Layer)
a. (Part 3.01H.) Please specify the acceptable moisture content range, said +/- 2% of the
optimum moisture content according to ASTM D698.
b. (Part 3.05D) The specified test by ASTM D 1140 does not include in Table 1 of the CQA
Plan. Please add the testing item & frequency to Table 1.

vi. (Section 13302 – Geocomposite)
a. (Part 3.02) Please specify the orientation of a geocomposite deployed on sloped areas, as
needed.

vii. (Section 13315 – GCL)
b. (Part 1.04 – Submittals) Should the material be warranted by the manufacturer for a period of
time, said 5 years?
c. (Part 2.02 – Material) Please specify which selected GCL is reinforced GCL to be used on 3
to 1 side-slope areas and which one is non-reinforced GCL for the deck/flat areas.
d. (Part 3.03 - Earthwork) Please specify the maximum grain/particle size that the subgrade/
earthen material shall contain.
e. (Part 3.04 – GCL Placement) For a GCL has woven and non-woven sides, please specify
which side shall directly contact geocomposite drainage material/ drain-tube drainage
geocomposite.
f. (Part 3.05 – Anchorage) The anchor trench must be in dry condition before GCL installation
and shall be maintained in dry condition prior to backfilling soil. Please add this requirement
to the specification.
g. (Part 3.09 – Cover Placement) This Part shall specify the deployment requirements of both
geosynthetic drainage material and soil layer over the in-place GCL.
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Please submit the responses to the above-mentioned comments and the electronic copy of the final permit
application.

From: Chao, Ming‐tai  
Sent: Thursday, October 24, 2019 11:58 AM 
To: Kemppinen, Hannu <[e-mail]>; Stanley, Sherri <[e-mail]>; Sugg, William P 
<[e-mail]> 
Cc: Deanna Martin ([e-mail]) <[e-mail]>; [e-mail]; Joyce, Leonard 
<[e-mail]>; Davis, Amy <[e-mail]>; Bertolet, Larry <[e-mail]> 
Subject: RE: [External] 2019‐10‐24 0105‐CDLF1998‐RTC2 

Hi Hannu: Today the Solid Waste Section (SWS) received the responses to the 08/29/19 comments (FID
1320279), and this new submittal is uploaded to Laserfiche with a FID 1360316. The SWS will review the
document shortly.

By the way, the SWS is still waiting for responses to concerns about the permit related info (see the attached
email dated 09/12/2019)
1. Landfill property ownership - Coble’s LLC & Ken & Brenda Coble.
2. Financial relationship between Coble’s LLC and Coble’s Sandrock, Inc.

The SWS is looking forward to receiving the requested info.

From: Kemppinen, Hannu <[e-mail]>  
Sent: Thursday, October 24, 2019 11:10 AM 
To: Chao, Ming‐tai <[e-mail]>; Stanley, Sherri <[e-mail]>; Sugg, William P 
<[e-mail]> 
Cc: Deanna Martin ([e-mail]) <[e-mail]>; [e-mail]; Joyce, Leonard 
<[e-mail]>; Davis, Amy <[e-mail]>; Bertolet, Larry <[e-mail]> 
Subject: [External] 2019‐10‐24 0105‐CDLF1998‐RTC2 
 Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]
 Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]
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[e-mail] 

Dear Ming,

On behalf of Coble’s CDLF, LaBella submits to the Section review Response to Comments 2 (RTC2) for the landfill
permit renewal and Life of Site permit application. This submittal includes the landfill engineering plan revised
drawings and updated Plan sections as addressed in the comment letter. The Section hydrogeologist has reviewed
the water quality and landfill gas monitoring plans and approved them for the permit renewal.

Thank you for your assistance in this permit renewal review process, and on behalf of Coble’s, we look forward to the
permit to operate (PTO) and Life of Site (LOS) approval.

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