NCG120034_COMPLETE FILE - HISTORICAL_20151229

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO. /v
DOC TYPE HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE ❑ jo) 5 ) a a
YYYYMMDD

Winston-Salem t Forsyth County
City/County
/Coun
Water t Server + Solid Waste Disposal
Hanes Mill Road
Solid Waste Facility'
City of Winsron Salcm
325 fir- 1 lanes Mill Road
W immn-Salcm, NC 27105
Gi Link 311 (336.727.Woo)
Fax 336.6C,1A,)05
1[7 wdj)GflflS.Prx
December 11; 20153
REGENOD
Division of Water Resources
Attn: DWQ Central Files
1617 Mail Service Center CENTRAL FILES
Raleigh, North Carolina 27699-1617 pWR SECTION
Re: Year 3, Period 2 Analytical Storm water Monitoring Results for Old Salisbury Road
Landfill (Certificate of Coverage No NCG 120034)
Dear Sirs:
Enclosed, please find the analytical data for continued monitoring for Year 3 Period 2 for the
above referenced storm water general permit.
Samples taken as part of the analytical requirement were taken during a representative storm event
and analyzed by a NC certified lab. Please accept this information on behalf of the City of
Winston-Salem/Forsyth County Utilities Solid Waste Administration. if you need any additional
information, please contact me at�336) 971-9697,
Sincerely,
Adam W. Rickett
Project Supervisor
cc: Jan McHargue
City CauaciL• M:ybr Allrn Jnines: rivian H. Eiurke. Msyar f'r�'lempare, Nord,cast Ward; lkniu 1l. hdatm, i inrsh V�'arxi; 1)an Kesi, SnnrEz�esr Wani; Itohen C_ Clah, Wexo V('ard;
MAY Leight. South Ward; Wanda Nlerschd...Nonhwx Wand; Dcmin L Mnmgomen•. F.au Bard; James Taylor. Jr., Suucha,t Rind; City Managa: lxe 1). Garrity
3MZM Foesyah County V---iaintsers: Ri.-hard V. Linville; (airman; Deb a ratnrad, Vi- Chtiq Wdrer MarshAl; David R. L%,L•r, Glonx 11. Whi—hung Bill Whi,dh n; Ewwre
Call 311 or 336-727-8000 Withrn,�­ n; County Manager: DAcy Ran,, Jr.
}.�lE� CI}��Of1N5.or CkylGounoy lhiliry C mission: landCh Neil. xisnnn; Jam- K LF r. \ rcc Chairman; •k"ko `l'ur` lkmn , Harold R. Hnlm� ; GuulJ 1). Je vff. I1;Jammn izlik; Paul S. MrCdh
C I
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RESEARCh & ArgA1YTiCAI
UboRATORiES, INC.
Report of Analysis
11 /18/2015
Client Sample ID: Lab Sample ID:
Site: Collection Date: 11:05
parameterMethod fiesult;` Units Ren'Limit Analys#.Anahtsis_DateiT_ime
Fec Coli-MF
SM 9222 D-1997
1670
col/100 ml 1
SK 11/9/2015 1614
Total Suspended Solids (TSS)
SM 2540 D-1997
26.2
mg/L
5
JB 11/11/2015
Client Sample ID: Old Salsbury Landfill Outfall 5
Lab Sample ID,
11364-05
Site: City of Winston-Salem
-N Main St
Collection Date:
11/9/2015 10:30
[PaLrameter
Method.
-Result, ,
Units
Rep Limit Analyst`Analysis Date/Time
COD
EPA 410.4
52
mg/L
5
KN 11/10/2015
Fec Coli-MF
SM 9222 D-1997
1830
C01/100 ml 1
SK 11/9/2015 1635
Total Suspended Solids (TSS)
SM 2540 0-1997
15.2
mg/L
5
JB 11/11/2015
Client Sample ID.
Site:
Old Salsbury Landfill Outfall 6
City of Winston-Salem -N Main St
Lab Sample ID:
Collection Date:
11364-06
11/9/2015 10:20
Parameter
Method
'Result-
'; Units Rep Limit Analysf A:nzihisiiDateffftne
COD
EPA 410.4
50
Tmg/L 5
KN 11/10/2015
Fec Coli-MF
SM 9222 D-1997
2830
col/100 ml 1
SK 11/9/2015 1640
Total Suspended Solids (TSS) SM 2540 D-1997
23.4
mg/L 5
JB 11/11/2015
Client Sample ID:
Old Salsbury Landfill Outfall 7
Lab Sample ID:
11364-07
Site:
City of Winston-Salem -N Main St
Collection Date:
11/9/2015 10:12
I-pkrameter, '°. '
.,
_. Method •
gRe suit
Units
Rep;Limtt An._ aiyst Analysis Date/Time
COD
EPA 410.4
23
mg/L
5
KN 11/10/2015
Fec Coli-MF
SM 9222 D-1997
580
coi/100 mi 1
SK 11/9/2015 1642
Total Suspended Solids (fSS) SM 2540 D-1997
76.5
mg/L
5
JB 11111/2015
Client Sample ID:
Old Salsbury Landfill Outfall 9
Lab Sample ID:
11364-08
Site:
City of Winston-Salem -N Main St
Collection Date:
11/9/2015 10:07
Parameter
Method`
'ResUlf
Units
Re .Limit Anawst Analysis DatelTime
COD
EPA 410.4
27
mg/L
5
KN 1i/10/20i5
P.O. Box 473 106 Short Street Kernersville, North Carolina 27284
Tel: [phone]
Fax: [phone] www.randalabs.com Page 2
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RESEARCh & ANA1yTICA[
LA ORA►T®RIES, INC.
For: City of Winston-Salem - N. Main
101 N. Main Street
Winston-Salem, NC 27101
Attn: John Spainhour
Report of Analysis
11/18/2015
' cp NC #34 0; N
' NC #37701 i
�`'�ihF1E0
Client Sample ID: Old Salsbury Landfill Outfall 1 Lab Sample ID: 11364-01
Site: City of Winston-Salem -N Main St Collection Date: 11/9/2015 11:31
Parameter=• ;$ '• x..
Method _ IZ�suit :.;Urnt§ Rep.L'i6i Analyst Anal sis Date/Time
COD EPA 410.4 63 mg/L 5 KN 11/1012015
Fec Colii-MF SM 9222 D-1997
Total Suspended Solids (TSS) SM 2540 0-1997
2160 col/100 ml 1 SK 11/912015 1603
23.4 mg/L 5 JB 11/11/2015
Client Sample ID: Old Salsbury Landfill Outfall 2 Lab Sample iD: 11364-02
Site: City of Winston-Salem -N Main St Collection Date: 11/9/2015 11:20
-Method` t _ 'Result" Units. Re_ _p L•imit Analyst Analysis_DatelTime
COD EPA 410.4 ill mg/L 5 KN 11110/2015
Fec Coli-MF SM 9222 D-1997 12000 col/100 ml 1 SK 11/9/2015 1608
Total Suspended Solids (fSS) SM 2540 D-1997 37.2 mg/L 5 JB 11/11/2015
i
Client Sample ID: Old Salsbury Landfill Outfall 3 Lab Sample ID: 11364-03
Site: City of Winston-Salem -N Main St Collection Date: 11/9/2015 11:24
Parameter�c,�� 5L 1-Method"}'Result aUnits R_e�imtt- nai st`AnalysisDate/Time
COD EPA 410.4 48 mg/L 5 KN 11/10/2015
Fec Coil-MF SM 9222 D-1997 136 c011100 ml 1 SK 1119/2015 1610
Total Suspended Solids (TSS) SM 2540 0.1997 25.6 mg/L 5 JB 11/11/2015
Client Sample ID: Old Salsbury Landfill Outfall 4 Lab Sample ID: 11364-04
Site: City of Winston-Salem -N Main St Collection Date: 11/9/2015 11:05
Parameter;' Method Result ', Urnts" Rea Limif` An. _ alyst Analysts�Date/Tifiw
;,.
COD EPA 410.4 28 mg1L 5 KN 11110/2015
P.O. Box 473 106 Short Street Kemersville• North Carolina 27284 Tel: [phone] Fax: [phone] �www.randalebs.com Page 1
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0
RESEARCh & ANACYTICA[ Report of Analysis
LAbo tAYORiES, INC. 11/18/2015
Client Sample ID: Lab Sample ID:
Site: Collection Date: 10:07
Parameter Method - 'Result` Units Rep Limit Analyst Analysis DatelTime
Fec Coli-MF SM.9222 D-1997 375 col/100 ml 1 SK 11/9/2015 1645
Total Suspended Solids (TSS) SM 2540 D-1997 <5 . mg/L 5 J8 11/1112015
Client Sample ID: Old Salsbury Landfill Outfall 10 Lab Sample lD: 11364-09
Site: City of Winston-Salem -N Main St Collection Date: 11/9/2015 10:50
Parameter, ' { Method R Result. - Units ReR Limit, Anaiyst:Analysis Daterrime
COD EPA 410.4 53 mg/L 5 KIN 11/1012015
Fec Coli-MF SM 9222 0-1997 1670 001/100 ml 1 SK 11/9/2015 1650
Total Suspended. Solids (rSS) SM 2540 D-1997 12.4 mg/L 5 JB 11/11/2015
NA = not c7notyzed
P.O. Box 473 106 Short Street Kernersville, North Carolina 27284 Tel: [phone] Fax: [phone] www.randalabs-com Page 3
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Research & Analytical
Laboratories, Inc.
Analytical /Process Consultations
Phone [phone]
CHAIN OF CUSTODY RECORD
Water / Wastewater
M&C.
Company
Job No.
city of Winston-Salem
Street Address
Project
101 N. Main St.
Old Salsbury Landfill
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City, State, Zip
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Winston-Salem, NC 27101
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Remarks: Analyze Fecal Coliform sample up to 60,000 cfu/100ml,
Analyti milling Old Salsbury Landfill. All Crabs
Relinquish By —F—_DatefThne
Rec v d By
on ice
Sample Temperature at receipt i °C

q
North Carolina
Beverly Eaves Perdue
Governor
���
,sM-
NCDENR
Department of Environment and
Division of Water Quality
Jan McHargue
City of Winston-Salem
PO Box 2511
Winston Salem, NC 27107-9998
Dear Permittee:
Charles Wakild, P. E.
Director
December 4, 2012
Natural Resources
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Winston Salem - Hanes Mill Rd Sanitary Landfill
COC Number NCG120034
Forsyth County
In response to your renewal application for continued coverage under stormwater General Permit NCG120000
the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is
reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October
15, 2007 (or as subsequently amended).
The following information is included with your permit package:
• A new Certificate of Coverage (COC)
• A copy of General Permit NCG120000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current SPPP to reflect all new permit requirements.
The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances.
The more significant changes in the General Permit since your last COC was issued are noted either in the
Draft Permit Fact Sheet that accompanied the public notice (http://portal.ncdenr.org/web/­wq/ws/­su/current-
notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are
posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit
http://Portal.ncdenr.org/web/wq/ws/su/npdessw (click on 'General Permits' tab) to review that information
for your specific General Permit carefully.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: 919-811; -63001 FAX: [phone].�
Intemet: ww ... cwaterguality.org
An Equal pppor„, •4 , L Affim..4ve Action Bmpl or
Noi-thC-l: a
(xwu&i;��

Jan McHargue
Cacember 4, 2012
Page 2 of 2
Some of the changes include:
Part II:
• Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated
to the most current language of our permits. Additional conditions for specific industry sectors have
been added to the SPPP requirements in some cases.
• Sections B, C: Failure to perform analytical stormwater monitoring may result in the Division requiring
that the permittee begin a monthly sampling scheme.
• Sections B, C: A lower TSS benchmark of 50 mg1I for HQW, ORW, PNA and Tr Waters applies to these
more sensitive waters.
• Sections 8, C: The monitoring parameter Oil & Grease (O&G) has been replaced by the parameter
Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other
analytical monitoring requirements.
• Sections B, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in
separate on -site records if your General Permit does not require an SPPP. Adverse weather is defined
in the "Definitions" section of the permit.
• Sections B, C. The term "Representative Storm Event" has been replaced by "Measurable Storm
Event." A measurable storm event is defined in the permit.
• Section D: If the permittee fails to respond effectively to problems identified by qualitative
monitoring, DWQ may require the permittee to perform corrective action.
Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit,
including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and
Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms
of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on
the Stormwater Permitting Unit's website above. DMR forms must be delivered to the Division no later than
30 days from the date the facility receives the sampling results from the laboratory. Also note that existing
permittees do not need to submit a renewal request prior to expiration unless directed by the Division.
Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit
does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it
relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit
package, please contact the Division's Stormwater Permitting Unit at [phone].
Sincerely,
for Charles Wakild, P.E.
cc: DWQ Central Files
Stormwater Permitting Unit Files
Winston-Salem Regional Office

3rr111x6)a►0]Mill: 910MGnRM
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG120000
CERTIFICATE OF COVERAGE No. NCG120034
STORMWATER
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
City of Winston-Salem
is hereby authorized to discharge stormwater from a facility located at:
Winston Salem - Hanes Mill Rd Sanitary Landfill
325 Hanes Mill Rd
Winston Salem
Forsyth County
to receiving waters designated as Grassy Creek, a class C waterbody in the Yadkin River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set
forth in Parts 1, 11, 111, and IV of General Permit No. NCG120000 as attached.
This certificate of coverage shall become effective December 4, 2012,
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 41h day of December, 2012.
tj .'t_C%/'�1
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

RC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Chuck Wakild, P.E. Dee Freeman
Governor Director Secretary
November 27, 2012
Winston Salem/Forsyth County Utilities
Attn: Mr. Edward Gibson, P.E.
325 West Hanes Mill Road
Winston-Salem, NC 27105
Subject: Compliance Evaluation Inspection
NPDES General Stormwater Permit NCG1200000
Certificate of Coverage NCG120034
Hanes Mill Road Landfill
Forsyth County
Dear Mr. Gibson:
Ron Boone of the Winston-Salem Regional Office of the NC Division of Water Quality (DWQ),
conducted a compliance evaluation inspection (CEI) at the subject facility on November 19, 2012. Your
assistance and cooperation during the inspection was greatly appreciated. An inspection checklist is attached
for your records and the inspection findings are summarized below.
The facility is located at 325 West Hanes Mill Road, in Winston-Salem, Forsyth County, North Carolina,
at approximate coordinates 36.187806 °,-80.286353°. Stormwater related to industrial activity is discharged
from the site to Grassy Creek, which is currently classified as a Class C water located in the Yadkin Pee Dee
River Basin.
Documentation & Monitoring Review
All required Land Quality and Waste Management permits are current and there are no known
outstanding violations of these permits.
All required analytical and qualitative monitoring (AM & QM) has been accomplished. The City received
correspondence from the Division in March, 2009, granting them an exemption from performing the tiered AM
requirements, in part due to the. inability to meet Fecal Coliform benchmarks due to wildlife conditions at the
site that are well beyond the City's control. There is no reason at this point to revoke this exemption and the
City's exemption status is hereby extended until another review of the conditions and status is performed (next
inspection).
Additionally, by way of the same correspondence mentioned above, the City was granted
Representative Outfall Status (ROS). As the granted ROS status specifies, the City currently monitors
Stormwater Discharge Outfall (SDO) F for SDOs 1, E, D, C, and B; SDO A2 for SDO Al, and SDO 3 for SDOs
1, 2, 4, and 5. The City is reminded that QM must still be performed at all SDOs as specified in the permit
regardless of ROS status.
North Carolina Division of Water Quality, Winston-Salem Regional Office
Location: H5 Waughtown St. Winston-Salem, North Carolina 27107
Phone: [phone] FAX: [phone] Customer Service: 1-S77-623-6748
Internet: www.ncwaterquality.org
NorthCarolina
An Equal Opportunity 1 Affirmative Action Employer

Winston Salem/Forsyth County utilities
Attn: Mr. Edward Gibson, F.E.
Compliance Evaluation Inspection, NCG120034
11/27/2012, Page 2 of 2
RI
Site Review
Mr. Boone noted no issues or violations during the site inspection.
The City is reminded that violations of the NCG120000 general stormwater permit are subject to civil
penalty assessments not to exceed $25,000 per day, per violation. Should you have any questions regarding
the permit, this letter, or the inspection, please do not hesitate to contact Mr. Boone or me at [phone].
Attachments:
1. BIMS Inspection Checklist
cc:rSWP — WSRO
Central Files
Stormwater Permitting Unit
'J
Sincerely,
i
W. Corey Basinger .
Water Quality Regional Supervisor
Winston-Salem Region
Division of Water Quality

Permit: NCG120034
SOC:
County: Forsyth
Region: Winston-Salem
Compliance Inspection Report
Effective: 11/01/07 Expiration: 10/31/12 Owner: City of Winston-Salem
Effective: Expiration: Facility: Winston Salem - Hanes Mill Rd Sanitary
Landfill
325 Hanes Mill Rd
Contact Person: Edward Gibson Title:
Directions to Facility:
On U.S. Highway 52 between Hanes Mill Road and Ziglar Road.
System Classifications:
Primary ORC: Certification:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Winston Salem NC 27105
Phone: [phone]
Phone:
Inspection Date. 11/19/2012 Entry Time: 10:30 AM Exit Time: 12:00 PM
Primary Inspector: Ron Boone % Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Landfill Stormwater Discharge COC
Facility Status: O Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG120034 Owner - Facility: City of Winston-Salem
Inspection Date: 1111912012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Please refer to the attached inspection summary letter for more information.
Page: 2

Permit: NCG120034 Owner - Facility: City of Winston-Salem
Inspection Date: 11/19/2012 Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
Cl
❑
■
D
# Does the Plan include a General Location (USGS) map?
Q
Q
■
D
# Does the Plan include a "Narrative Description of Practices"?
D
D
®
Q
# Does the Plan include a detailed site map including outfall locations and drainage areas?
❑
D
®
Q
# Does the Plan include a list of significant spills occurring during the past 3 years?
D
D
■
❑
# Has the facility evaluated feasible alternatives to current practices?
D
D
!
0
# Does the facility provide all necessary secondary containment?
i
❑
D
n
# Does the Plan include a BMP summary?
D
D
[1
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
❑
❑
■
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
Q
❑
■
D
# Does the facility provide and document Employee Training?
D
D
D
# Does the Plan include a list of Responsible Party(s)?
D
D
■
D
# Is the Plan reviewed and updated annually?
D
D
s
Cl
# Does the Plan include a Stormwater Facility Inspection Program?
D
D
®
D
Has the Stormwater Pollution Prevention Plan been implemented?
❑
❑
0
Comment: The Stormwater Pollution Prevention Plan is not a requirement of the
NCG120000 general permit.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ■ D D D
Comment: Conducted as required. No significant issues noted.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? D D D
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ® Q D ❑
Comment: Per Division correspondence dated March 18, 2009, the City has a waiver
from performing tiered analytical monitoring requirements due to an inability to meet
Fecal Coliform benchmarks due to reasons beyond the reasonable control of the City
(i.e. bird population). Also, the City has been granted Representative Outfall Status via
the same correspondence. All analytical monitoring has been accomplished as required.
Permit and Outfalls
Yes No
NA
NE
# is a copy of the Permit and the Certificate of Coverage available at the site?
i D
D
D
# Were all outfalls observed during the inspection?
M 0
Q
Page: 3

Permit: NCG120034 Owner • Facility: City of Winston-Salem
Inspection Date: 11/19/2012 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
# If the facility has'representative outfall status, is it properly docurnented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: Please refer to the attached inspection summary letter for more information.
■ ❑ ❑ Q
D D M 0
Page: 4

Winston-Salem • Forsyth County
12ty/county Utilities
ater - Sewer - Solid Waste Disposal
Hanes Mill Road Landfill • 325 W. Hanes Mill Road - Winston-Salem, NC 27105 - Tel [phone] - Fax 336.661_4905
September 24, 2010
Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: NPDES Stormwater Semi -Annual Monitoring for Hanes Mill Road Sanitary
Landfill. (Certificate of Coverage No NCG 120034)
To whom it may concern:
The City/County Utilities Division operates a -Municipal Solid Waste Landfill located at
325 Hanes Mill Road, Winston-Salem, NC which received a renewed certificate of
coverage (No NCG 120034) effective November 1, 2007. This permit requires analytical
monitoring requirements on a semi-annual basis, with monitoring to be conducted during
a representative storm event which measures 0.1 inches of rainfall and is preceded by at
least 72 hours in which no storm event measuring greater than 0.1 inches has occurred.
The City/County Utilities Solid Waste Administration has been and is currently working
with the City of Winston-Salem Stormwater Division to conduct the semi-annual
analytical sampling for Year 3, Period 1 of the Hanes Mill Road Landfill (January 1,
2010 to June 30, 2010) required under the above referenced Permit. However, to date we
have not been able to obtain analytical samples for this period due to following reason:
The representative storm events that did occur during this period occurred on the
weekends, or after hours/late in the day. The certified laboratory is not open to
receive collected samples during holidays, weekends, and late evenings, so staff
needs to coordinate sample collections with laboratory hours of operation as to
not violate holding times of sample parameters.
Notwithstanding the above, the City/County Utilities Solid Waste Administration remains
committed to collecting the required analytical samples and submitting reports to DENR
when a representative storm event occurs.

Central Files
September 24, 2010
Page 2
If you have any questions or need additional information please contact me at 336-661-
4903.
Sincerely,
Edward L. Gibson P.E.
City/County Utilities Solid Waste Administration
cc: Steve Mauney (Division of Water Quality/Winston-Salem Regional Office)
Keith Huff (City of Winston-Salem Stormwater Department)
Jan McHargue (Solid Waste Administrator, City -County Utilities)

NC®ENR
North Carolina Department of Environment and Natural
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March 18, 2009
Mr. Edward Gibson, PE
Winston Salem/Forsyth County Utilities
Hanes Mill Road Landfill r
325 W Hanes Mill Rd
Winston Salem, NC 27105
Resources
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit NCG120034
Representative Outfall Status Request
Tiered Response Requirements
Hanes Mill Landfill -Forsyth County
Dear Mr. Gibson:
The Winston Salem Regional Office staff gave reviewed your request for a determination that stormwater discharge
outfall (SDO) F be granted representative outfall status for Stormwater outfalls I, E, D, C, and B; SDO A2 be granted
representative outfall status for stormwater outfall AI; and SDO 3 be granted representative outfall status for stormwater
outfalls 1, 2, 4, and 5. 13ased on the information and maps provided and a site visit byRosePruitt and Steve Tedder of the
Winston Salem Regional Office on March 18, 2009, we are approving this request. In accordance with 40 CFR
5122.21(g)(7), you are authorized to sample outfalls F, Al and 3 as representative outfalls. This approval is effective with
the next sampling event. We also want to remind you that the permit still requires Qualitative Monitoring be performed at
all SDOs, regardless of representative status.
In addition, the Winston Salem Regional Office has reviewed the analytical data you submitted in response to permit
requirements for benchmark exceedences and tiered response levels. At this time the Division concurs that more frequent
monitoring at this site would be ineffective. The Division relieves you of the additional monitoring frequencies required
in the Tiered Response section of the permit. You must continue to monitor semi-annually as required by the permit in
Section B. Analytical Monitoring Requirements, but you will not be required to move up to the more frequent monitoring
required in the Tiered Responses.
Please append this letter to your Stormwater Pollution Prevention Plan (SPPP) or permit to document that representative.
outfall status has been approved. If changes in drainage areas, structures, processes, storage practices, or other activities
occur that significantly alter the basis of this approval, representative outfall status may no longer bealid. You should
either resume sampling at all SDOs, or reapply to this office for representative outfall status based on updated
information. If you have any questions or comments concerning this letter, please contact Rose Pruitt or meat (336) 771-
5 000.
Sincerely,
Steve W. Tedder
Winston Salem Regional Supervisor
cc: Winston Salem Regional Office
Central Files
Stormwater Permitting Unit
Ronald DiFrancesco, Golder Assoc., 3719 Saunders Ave, Richmond Va, 23227
North Carolina Division of Water Quality, Winston-Salem Regional Office
Location; 585 Waughtown St. Winston-Salem, North Carolina 27107
Phone: [phone] i FAX: [phone] Customer Service: 1-877-623,6748
Internet: www,ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
O
NorthCarolina
;Vatura!!y

NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
March 18, 2009
Mr. Edward Gibson, PE
Winston Salem/Forsyth County Utilities
Hanes Mill Road Landfill
325 W Hanes Mill Rd
Winston Salem, NC 27105
Subject: INPDES Stormwater Permit NCG120034
Representative Orrtfall Stators Request
Tiered Response Requirements
Hanes Mill Landfill -Forsyth County
Dear Mr. Gibson:
The Winston Salem Regional Office staff have reviewed your request for a determination that stormwater discharge
outfall (SDO) F be granted representative outfall status for stormwater outfalls 1, E, D, C, and B;.SDO A2 be granted
representative outfall status for stor nwater outfall Al; and SDO 3 be granted representative outfall status for storm"eater
outfalls 1, 2, 4, and 5. Based on the information and maps provided and a site visit by Rose Pruitt and Steve Tedder of the
Winston Salem Regional Office on March 18, 2009, we are approving this request. In accordance with 40 CFR
§ 122.2 l(g)(7), you are authorized to sample outfalls F, Al and 3 as representative outfalls. This approval is effective with
the next sampling event. We also want to remind you that the permit still requires Qualitative Monitoring be performed at
all SDOs, regardless of representative status -
In addition, the Winston Salem Regional Office has reviewed the analytical data you submitted in response to permit
requirements for benchmark exceedences and tiered response levels. At this time the Division concurs that more frequent
monitoring at this site would be ineffective. The Division relieves you of the additional monitoring frequencies required
in the Tiered Response section of the permit. You must continue to monitor semi-annually as required by the permit in
Section B. Analytical Monitoring Requirements, but you will not be required to move up to the more frequent monitoring
required in the Tiered Responses.
Please append this letter to your Stormwater Pollution Prevention Plan (SPPP) or permit to document that representative
outfall status has been approved. If changes in drainage areas, structures, processes, storage practices, other activities
occur that significantly alter the basis of this approval, representative outfall status may no longer be,valid. You should
either resume sampling at all SDOs, or reapply to this office for representative outfall status based on updated
information. If you have any questions or comments concerning this letter, please contact Rose Pruitt or meat (336) 771-
5000.
Sincerely, o
Steve
Winston Salem Regional Supervisor
cc: Winston Salem Regional Office
Central Piles o ,
Storrnwater Permitting Unit �
Ronald DiFrancesco, Golder Assoc., 3719 Saunders Ave, Richmond Va, 23227 �L ULII!
North Carolina Division of Water Quality, Winston-Salem Regional Office
Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 One
Phone: [phone] FAX: [phone] Customer Service: 1.877-623-6748 NorthCarolina
Internet: www.nrwaterquality.org Naturally
j1 oats ly
An Equal Opportunity 1 Affirmative Action Employer �/ j' `i "

R
Winston-Salem • Forsyth County REcEfvEfl
City/County UtilitiesDeot. of ENR
Water •Sewer •Solid Waste Disposal [JAN 2 3 2009
Reglenai Office
Hanes Mill Road Landfill • 325 W. Hanes Mill Road • Winston-Salem, NC 27105 • Tel [phone] • Fax [phone]
January 15, 2009
North Carolina Department of Environment and Natural Resources
Division of Water Quality — Surface Water Protection
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, North Carolina 27107
Attention: Rose Pruitt, Environmental Specialist 11
Re: Request for Elimination of Permitted Outfalls (No Exposure)
Hanes Mill Landfill, Forsyth County, North Carolina
Permit No. NCG120000
Dear Ms. Pruitt:
Ref. No. 0839-6460
As you are aware, the Winston-Salem/Forsyth County City / County Utilities Commission
(Commission) is monitoring stormwater under Permit No. NCG120000 at the Hanes Mill
Landfill. The Hanes Mill Landfill is currently divided into two main areas, as follows:
• A capped and vegetated, inactive portion of the landfill located to the east of the railroad
tracks and Grassy Creek; and
• An active portion of the landfill which currently receives waste, located to the west of the
railroad tracks and Grassy Creek.
Eight permitted outfalls (Outfalls Al, A2, B, C, D, E, F, and 1) are located within the closed,
eastern portion of the landfill. One outfall, Outfall F, receives stormwater from the facility
entrance, convenience center, and scalehouse, located near Hanes Mill Road. Monitoring of
Outfall F is, appropriately, expected to continue during the future use of the current facility
entrance, convenience center, and scalehouse. However, the Commission requests the North
Carolina Department of Environment and Natural Resources — Division of Water Quality's
(NCDENR-DWQ's) evaluation of five outfalls (Outfalls B, C, D, E, and 1) for consideration of
elimination from the facility permit on the basis of a Conditional No Exposure Exclusion for
Industrial Activity. Additionally, an evaluation of potential no exposure is being requested for
the catchment areas of Outfalls Al and A2. Outfalls Al and A2 are located within the closed
portion of the landfill, but maintenance activities and the collection and recycling of white goods
occurs within their.stormwater catchment areas. The Commission also requests an evaluation of
Conditional IVO' Exposure Exclusion for Industrial Activity for these outfalls for. potential
elimination from the facility permit.
To facilitate an appropriate evaluation and discussion, the Conunission would like to accept the
DWQ's previous offer to conduct an on -site evaluation and meeting regarding the requested

NCDENR — DWQ January 15, 2009
Attn: Ms. Pruitt -2- Ref. No. 0839-6460
elimination of outfall locations from the discharge permit. The Commission would like to
schedule an on -site meeting and site walk at your convenience. We appreciate your assistance
with this project, and look forward to your verbal or written response.
Sincerely,
Ed Gibson, P.E.
Solid Waste Engineer
Attachment: Figure 1
C: Keith Huff, Stormwater Division Director, City of Winston-Salem, Suite 232, City Hall,
101 N. Main Street, Winston-Salem, NC, 27101
Ron DiFrancesco, Golder Associates Inc., 3719 Saunders Avenue, Richmond, Virginia,
23227, rdifrancescongolder, com
Rachel P. Kirkman, P.G., Golder Associates NC, Inc., 4900 Koger Boulevard, Suite 140,
Greensboro, NC, 27047, rkirkmanQgolder.com

CWinston-Salem • Forsyth County
ity/County Utilities
Water • Sewer • Solid Waste Disposal
Hates Mill Road landfill • 325 W Hanes Mill Road • Winston-Salem, NC 27105 • Tel 336,661.4900 • Fax 336,661.4905
January 15, 2009 Ref. No. 0839-6460
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Stormwater Permitting Division
1617 Mail Service Center
��.--
Raleigh, NC 27699-1617
z
Attention: Bradley Bennett, Stornnvater Permitting Unit Supervisor
t_
Re: Stormwater Compliance Update and Additional Work Plan
j
ca
Hanes Mill Landfill, Forsyth County, North Carolina
A
o
Permit No. NCG120000
o
w
7�
Dear Mr. Bennett:
-
As you are aware, the Winston-Salem/Forsyth County City/County Utilities Commission
(Commission) is monitoring stormwater under Permit No. NCG120000 at the Hanes Mill
Landfill. The stormwater samples for the first semi-annual compliance period were collected on
July 31, 2008, Due to exceedances of benchmark values during the first semi-annual compliance
period, the Commission submitted to the North Carolina Department of Environment and
Natural Resources - Division of Water Quality (NCDENR — DWQ) a Work Plan dated October
1, 2008. The purpose of the work plan was to "identify and evaluate possible causes of the
benclunark value exceedance(s)" and "identify potential, and select the specific improvements to
reduce concentrations of the parameters of concern, or to bring concentrations within the
benchmark range." This letter presents the results of the evaluation and presents a second Work
Plan for limited additional investigation activities and proposed modifications to stormwater
management structures for mitigation of benchmark value exceedances.
Evaluation Results
An illustrative site sketch, including tabulated analytical results for samples, is attached as
Figure 1. As presented in Figure 1, areas of interest for the storm water quality investigation
have been identified (Areas 1-5) to aid in the interpretation and discussion of potential
stormwater issues at the landfill. A description of each area of investigation, associated
permitted outfalls, and voluntary sampling efforts are presented in the following table:

NCDENR — DWQ January 15, 2009
Attn: Mr. Bennett -2- Ref. No. 0839-6460
Hanes Hill Landfill Stornnvater Investigation Areas
Sampled
Area ID
Area Description
Permitted
Voluntary Samples and T}7pe
Outfall
Area 1
Southern Tributary
Outfall 1
0 SW-3 = Upgradient Stream
— Closed Landfill
Portion at Highway 52
• SW-4 = Downgradient Stream
Portion
Area. 2
Landfill Scalehouse
Outfall F
• CC-1 = Overland flow at the
and Convenience
convenience center area roll -
Center
offs
• CC-2 = Overland flow on
Hanes Mill Road near the
facility entrance
0 Scalehouse = Overland flow at
the residential traffic side of
the scalehouse
Area 3
Northern Tributary
Outfall Al and
. NBC-1 = Upgradient Stream
— Closed Landfill
Outfall A2
Portion at Highway 52
• NBC-2 = Downgradient
Stream Portion
Area 4
Sediment Pond B —
Outfall B
• Sediment Pond B = Pond
Closed Landfill
sample under non -storm
conditions
Area 5
Sediment Pond 2 —
Outfall 2
• Sediment Pond 2 = Pond
Active Landfill
sample under non -storm
conditions
The following sections present a discussion of analytical results and proposed actions, by area:
Area 1
Discussion of Investigation Results: Area 1 contains a stream, South Branch Creek, that
originates on the northeastern, offsite side of Highway 52. Analytical results from voluntary
surface water sample SW-3 indicate background concentrations of both total suspended solids
(TSS) and fecal coliform in excess of benchmark values prior to traversing through the site.
Analytical results from voluntary sLirface water sample SW-4 indicate a decline in both TSS and
fecal coliform as the stream progresses adjacent to the closed portion of the landfill. These
voluntary surface water analytical results indicate an existing elevated background concentration
of TSS and fecal coliform in the tributary at concentrations in excess of benchmark values,
presumably from off -site sources.
No flow was observed at any permitted outfall within Area 1 during the first semi-annual
sampling event. One permitted outfall within Area 1, Outfall I, had flow present during the

NCDENR — DWQ January 15, 2009
Attn: Mr. Bennett -3- Ref. No. 0839-6460
second semi-annual sampling event. The laboratory analytical result for fecal coliform at
Outfall I was in excess of the benchmark value.
Proposed Actions: Outfall I is the discharge outfall from sediment pond 1, located within the
closed portion of the landfill. Only fecal coliform has been detected at a concentration in excess
of a benchmark value at Outfall 1. Background fecal coliform concentrations in excess of the
benchmark value are present within the stream located in Area 1. Furthermore, observed heavy
geese activity within the southeastern portion of the closed landfill and landfill entrance areas
very likely provides a natural, on -site source of fecal coliform that is not related to past or
present landfill activities. Therefore, the Commission proposes no corrective actions related to
fecal coliform concentrations at Outfall I at this time.
Area 2
Discussion of Investigalion Results: Area 2 includes the facility entrance, scalehouse, and
convenience center for residential drop-off of waste. As presented on Figure 1, analytical results
for voluntary samples collected from over -land stormwater flow within Area 2 identified
elevated concentrations of TSS and fecal coliform within these areas of relatively high activity.
Geese grazing within the convenience center and scalehouse area, as presented in the following
photograph, likely provides a source of both fecal coliform and TSS (please note the goose
droppings on the ground):
Geese Activity and Droppings in Area 2
The first and second semi-annual analytical results for Outfall F, the permitted outfall for Area 2,
indicated compliance with the benchmark value for TSS and exceedances of the benchmark
value for fecal coliform for both sampling events. Stormwater originating in Area 2 is directed
through broad, grassy swales to the west of Area 2 prior to discharge into South Branch Creek,
as presented in the following photograph:

NCDENR — DWQ January 15, 2009
Attn: Mr. Bennett 4- Ref No. 0839-6460
Area 2 Stormwater BMPs
As indicated by a large drop in both TSS and fecal coliform between the facility entrance /
scalehouse / convenience center and Outfall F, the stormwater BMPs located within Area 2
(shown above) appear to be effective and provide significant benefits to stormwater quality.
Although a large reduction of fecal coliform concentrations is attained through Area 2 BMPs,
fecal coliform concentrations at Outfall F remained slightly above the benchmark value. The
fecal coliform values at Outfall F may be attributed to naturally re -occurring wildlife activity
within the stormwater drainages and BMPs of Area 2, as shown in the following photograph:
Area 2 Geese Acti4ty (December 2008)
One may not expect to achieve compliance with the fecal coliform benchmark value if geese are
depositing a source of fecal coliform in the BW structures directly above Outfall F, as presented
in the above photograph.

NCDENR—DWQ January 15,2009
Attn: Mr. Bennett -5- Ref. No. 0839-6460
Proposed Actions: Due to the prolific presence of geese within the stormwater drainages and
BMPs of Area 2, the Commission proposes no corrective actions at this time. Continued
quantitative evaluations of water quality at Outfall F, as required by the permit, may exhibit a
correlation between geese activity (i.e., migration times) and reduced fecal coliform
concentrations.
Area 3
Discussion of Investigation Results: Area 3 contains a stream, North Branch Creek, that
originates on the northeastern, offsite side of Highway 52. The TSS analytical result for the
voluntary surface water sample NBC-1, located at the upgradient, onsite extent of the stream,
indicates a background concentration of TSS (84 mg/L) prior to traversing through the site. The
TSS analytical result for the voluntary surface water sample NBC-2, located at the downstream
extent of Area 3, indicates an increase in TSS concentration as the stream flows adjacent to the
closed portion of the landfill. These voluntary surface water analytical results indicate an
existing background concentration of TSS in the tributary, presumably from off -site sources,
with an increase in TSS in surface water in the downstream direction. Horse grazing activities,
located on an adjacent property to the north of Area 3, including horse trails leading up to the
edge North Branch Creek near sample NBC-1, is likely a source of suspended solids in this
stream and Area 3 stormwater runoff.
Two permitted outfalls, Outfalls A] and A2, are located within Area 3. Outfalls Al and A2
require sampling for TSS, pH, and oil and grease due to the presence of maintenance facilities
within the stormwater catchment. Stormwater pH values for the first semi-annual monitoring
event were below the benchmark values (6-9 Standard Units) due to laboratory measurement of
pH, rather than field measurement. Collection of field pH measurements during the subsequent
sampling event demonstrated acceptable pH values. Field measurement of pH during future
sampling events for each permitted outfall will be performed and is expected to mitigate the
occurrence of pH values outside of the benchmark values. Oil and grease concentrations for the
second semi-annual monitoring event were below benchmark values for both Outfalls Al and
A2. Therefore, the remaining exceedance of benchmark values for Area 3 is for TSS.
Proposed Actions: The Commission will continue to inspect for potential run-on of stormwater
containing elevated TSS concentrations from off -site land to the north of Area 3, observed to
contain agricultural and/or animal grazing activities. Similarly, the Commission will also
continue to inspect for potential on -site sources of TSS in stormwater within the catchments for
Outfalls Al and A2. If necessary, modifications to and/or additions of BMPs (e.g., silt fence,
rock check dams, additional vegetative cover, etc.) upgradient of Outfalls Al and A2 will be
performed to address any observed areas of concern.
Areas 4 and 5
Discussion of Investigation Results: Areas 4 and 5 represent sediment basins B (closed area of
landfill) and 2 (active area of landfill), respectively. Analytical results from voluntary surface
water samples collected from within the basins during non -storm conditions indicate an existing

NCDENR — DWQ January 15, 2009
Attn: Mr. Bennett -6- Ref. No. 0839-6460
background concentration of fecal coliform in excess of the benchmark value in Sediment Pond
2, but not in Sediment fond B (Figure 1). Samples collected from the permitted outfalls of both
basins exhibit concentrations of TSS and fecal coliform in excess of benchmark values during
storm events, indicating influx of stormwater containing elevated concentrations of fecal
coliform, presumably from re -occurring wildlife activity.
Proposed Actions. The Commission proposes sediment pond outlet structure inspection and
modifications to facilitate a reduction in both TSS and fecal coliform concentrations at the
permitted outfalls during storm events, as follows:
An initial evaluation of sediment ponds B and 2 will include an inspection of the physical
condition of the riser pipe and outlet barrel for each pond, as well as the general condition of the
pond and inlet areas. Both pond outlet structures are constructed of corrugated metal pipe
(CMP). They will be inspected for possible leaks due to corrosion, physical damage, or
structural failure. If flow is observed from the outfall pipe when the observed water level in the
pond would suggest there should be no flow, a leak in the outlet structure is likely indicated.
Leaks in the riser/outfall pipe structure allow unsettled water to bypass the intended flow path
through the outlet structure and may be a source of elevated TSS levels in the discharge water. If
leaks or structural problems are found, they will be repaired, if possible. If repair is not possible,
replacement of the riser and/or outlet barrel will be evaluated.
Assuming the existing riser pipes and outlet barrels are intact, or in need of only minor repairs,
modifications to the existing structures are proposed to increase the pond's sediment trapping
ability and facilitate a reduction in TSS and fecal coliform concentrations at the associated
permitted outfalls. The intent is to use the existing structure, with minor modifications, to reduce
the construction disturbance in the pond and implement a cost-effective solution quickly.
Sediment ponds B and 2 currently have perforated riser structures surrounded by a collar of
coarse gravel. After verification of the integrity of the riser and outlet barrel, these outlet
structures will be modified in -place by placement of a layered filter system around the risers.
This modification will be subject to the approval of the NCDENR Division of Land Resources,
Land Quality Section. The existing coarse gravel around the riser structures will be removed,
and a nonwoven filter geotextile will be wrapped around the vertical portion of the risers to cover
the perforations. This filter fabric will serve to keep the next layer, sand, from entering the
perforations. The sand layer will be clean sand or washed manufactured sand, at least 18 inches
thick to provide adequate filtration capacity for the risers. A second layer of nonwoven
geotextile will be applied, and then a six -inch -thick protective layer of gravel will be placed as
the outer layer. A conceptual sketch of the system is presented below:

NCDENR — DWQ January 15, 2009
Attn: Mr. Bennett -7- Ref. No. 0839-6460
NON -WOVEN GEOTEXTILL
NCDOT #57 STONE
TRASH RACK
I I
I
L ---- J t
Proposed Modification of Perforated Riser Structure in Sedintent Pond 2
Furthermore, the Commission will continue to seek out other improvements within and around
the sediment ponds, including maintenance of the slopes of the pond and inlet areas to correct
potential soil erosion by water entering the pond. These ,areas may be graded and seeded, as
needed, to promote vegetative growth. Temporary soil matting will be placed, if needed, to
assist with establishing vegetation. The ponds will be evaluated to determine if sediment
removal is necessary to reestablish the frill permanent pool volume. The ponds will also be
evaluated to determine if placement of porous baffles (Spec 6.65) to reduce the velocity and
turbulence of the water flowing through the basin may provide an additional, effective measure
for the reduction of TSS and fecal coliform concentrations in the pond effluent.
Upon implementation of the proposed modifications to sediment ponds B and 2, the Commission
will evaluate the effectiveness of the modification through routine stormwater quality monitoring
under the permit.
Closing
Based on the analytical results, three pennitted outfalls have reached Tier Two criteria, as
follows: Outfall F (Area 2), Outfall A2 (Area 3), and Outfall B (Area 4). Tier Two qualitative
and quantitative evaluations will proceed on a monthly basis at these selected outfalls, as
required by the permit. Outfalls F and A2 have moved —into Ti_erT_wo status due—to—two
consecutive exceedances of benchmark values for fecal coliform concentrations. As presented in
the above ev" al ations, naturally occurring^ so es of fecal coliform (e.g., wildlife and horse
grazing) have been identified within Areas 2 and 3. Therefore, the Commission requests your
consideration of a return to Tier One status for Outfalls F and A2 based on these findings.
Furthermore, the Commission is hopeful that the proposed inspection and potential modifications
to sediment pond B will also allow the return of Outfall B to Tier One status.

NCDENR — DWQ January 15, 2009
Attn: Mr. Bennett -8- Ref. No. 0839-6460
Finally, the Commission is requesting, in a separate letter to the Winston-Salem Regional Office,
NCDENR-DWQ's consideration of elimination several permitted outfalls from the facility
permit. Elimination from the permit is requested based on the location of the outfalls within the
closed portion of the landfill. To facilitate an appropriate evaluation and discussion, the
Commission would like to accept the DWQ's previous offer to conduct an on -site evaluation and
meeting regarding the requested elimination of outfall locations form the discharge permit.
The Commission is interested in continuing a productive dialogue with NCDENR-DWQ regarding
our evaluations and proposed BMPs for the attainment and maintenance of stormwater quality
compliance. If you have any questions or require any additional information regarding the
stormwater quality evaluation results and interpretations presented, please call me. If you have any
suggestions or recommendations to this Work Plan, please let us know soon, as we plan to proceed
with proposed actions in the near future. We appreciate your assistance with this project, and look
forward to your verbal or written response.
Sincerely,
Ed Gibson, P.E.
Solid Waste Engineer
Attachment: Figure I
C: Keith Huff, Stormwater Division Director, City of Winston-Salem, Suite 232, City Hall,
101 N. Main Street, Winston-Salem, NC, 27101
Ron DiFrancesco, Golder Associates Inc., 3719 Saunders Avenue, Richmond, Virginia,
23227, rdifrancesco as golder,com
Rachel P. Kirkman, P.G., Golder Associates NC, Inc., 4900 Koger Boulevard, Suite 140,
Greensboro, NC, 27047, rkirkman golder.com
Rose Pruitt, North Carolina Dept of Environment and Natural Resources
Division of Water Quality, Winston-Salem Regional Office, 585 Waughtown St,
Winston-Salem, NC 27107

Outfall A2
7131/08
11/13/00
5.83 (lab) 121
7.02 (field) 113
=ME
NBC-2
10/17/08 7.29 140
TSS Fecal
Wliforni'' �•_
Sediment
Pond 2
10/17/08 6.25 41 s6AM Area 5
Guiiaii 2
/ -
7/31/08 5,000
Active Area
Of I-andfill - u
Notes:
-pH is presented in Standard Units
•TSS = Total Suspended Solids (mg/L)
-fecal Coliform = colonies / 100 mL
-Permitted Sample locations are
labeled "Outfall," all other samples are
non -permitted evaluation samples of
surface water or overland flow.
-Sample results in red are in
exceedance of regulatory limits for
permitted outfalls
-Figure is not to scale and is used for
illustrative/sketch purposes only
- - - ;lt
\A
------------
Outfall Al 0
7/31/08 5.90(lab) 90 NBC-1
11/13/08 5.90 (field) 330 10/17/01
Area 3°`
Sediment
Pond B &17 6.G
"Y
Area 4
Outfall B
7/31/08 8,000
11/13/08 512,000
Closed Area
Of Landfill
J
SW-4
10/17/08 7.47 42 11,000
7.31 84
am
SW 3
IN17/00 7.45
outfall I
13/13/08
110 18;000
s4.7 7,800
CC-1
Area 1
)Convenience
Center)
10/17/08 7.99
Area 2
r
CC-2
5400
(Convenience
1,200
Center)
10/17/08 8.08
Scalehouse
10/17/08
8.01 12 43,000
560 >60,000
410 >60,000
Approximate
North
Figure 1- Site Sketch with Analytical Results
Stormwater Quality Evaluation for the Hanes Mill Road Landfill
Hanes Mill Landfill, Forsythe County, North Carolina

AW A
RECEIVED
Winston-Salem • Forsyth County N.C. Deot. of ENR
City/County Utilities fAN 2 3 20
09
1 Regional
0fld
Water • Sewer •Solid Waste Disposal Reg;on,E �e4
Hanes Mill Road Landfill • 325 W. Hanes Mill Road • Winston-Salem, NC 27105 • Tel [phone] • Fax 336,661.4905
January 15, 2009 Ref. No. 0839-6460
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Stormwater Permitting Division
1617 Mail Service Center
Raleigh, NC 27699-1617
Attention: Bradley Bennett, Stormwater Permitting, Unit Supervisor
Re: Stormwater Compliance Update and Additional Work Plan
Hanes Mill Landfill, Forsyth County, North Carolina
Permit No. NCG120000
Dear Mr. Bennett:
As you are aware, the Winston-Salem/Forsyth County City/County Utilities Commission
(Commission) is monitoring Stormwater under Permit No. NCG120000 at the 1-lanes Mill
Landfill. The stormwater samples for the first semi-annual compliance period were collected on
July 31, 2008. Due to exceedanccs of benchmark values during the first semi-annual compliance
period, the Commission submitted to the North Carolina Department of Environment and
Natural Resources - Division of Water Quality (NCDENR — DWQ) a Work Plan dated October
1, 2008. The purpose of the work plan was to `'identify and evaluate possible causes of the
benchmark value exceedance(s)" and "identify potential, and select the specific improvements to
reduce concentrations of the parameters of concern, or to bring concentrations within the
benchmark range." This letter presents the results of the evaluation and presents a second Work
Plan for limited additional investigation activities and proposed modifications to stormwater
management structures for mitigation of benchmark value exceedances.
Evaluation Results
An illustrative site sketch, including tabulated analytical results for samples, is attached as
Figure 1. As presented in Figure 1, areas of interest for the storm water quality investigation
have been identified (Areas 1-5) to aid in the interpretation and discussion of potential
stormwater issues at the landfill. A description of each area of investigation, associated
permitted outfalls, and voluntary sampling efforts are presented in the following table:

NCDENR — DWQ January 15, 2009
Attn: Mr. Bennett -2- Ref. No. 0839-6460
Hanes Mill Landfill Stornrwater lnvestigation Areas
'I Sampled
Area ID Area Description Permitted Voluntary Samples and Type
outfall
Area 1 Southern Tributary
Outfall I
• SW-3 = Upgradient Stream
— Closed Landfill
Portion at Highway 52
• SW-4 = Downgradient Stream
Portion
Area 2 Landfill Scalehouse
Outfall F
• CC-1 = Overland flow at the
and Convenience
convenience center area roll -
Center
offs
• CC-2 = Overland flow on
Hanes Mill Road near the
facility entrance
• Scalehouse = Overland flow at
the residential traffic side of
the Scalehouse
Area 3 Northern Tributary
Outfall Al and
• NBC-1 = Upgradient Stream
— Closed Landfill
Outfall A2
Portion at Highway 52
NBC-2 = Downgradient
Stream Portion
Area 4 Sediment Pond B — Outfall B
• Sediment
Pond
B = Pond
Closed Landfill
sample
under
non -storm
conditions
Area 5 Sediment Pond 2 — Outfall 2
• Sediment
Pond
2 = Pond
Active Landfill
sample
under
non -storm
conditions
The following sections present a discussion of analytical results and proposed actions, by area:
Area I
Discussion of Investigation Results: Area 1 contains a stream, South Branch Creek, that
originates on the northeastern, offsite side of Highway 52. Analytical results from voluntary
surface water sample SW-3 indicate background concentrations of both total suspended solids
{TSS} and fecal coliform in excess of benchmark values prior to traversing through the site.
Analytical results from voluntary surface water sample SW-4 indicate a decline in both TSS and
fecal coliform as the stream progresses adjacent to the closed portion of the landfill. These
voluntary surface water analytical results indicate an existing elevated background concentration
of TSS and fecal coliform in the tributary at concentrations in excess of benchmark values,
presumably from off -site sources.
No flow was observed at any permitted outfall within Area 1 during the first semi-annual
sampling event. One permitted outfall within Area 1, Outfall I, had flow present during the

NCDENR — DWQ January 15, 2009
Attn: Mr. Bennett -3- Ref No. 0839-6460
second semi-annual sampling event. The laboratory analytical result for fecal coliform at
Outfall I was in excess of the benchmark value.
Proposed Actions: Outfall I is the discharge outfall from sediment pond I, located within the
closed portion of the landfill. Only fecal coliform has been detected at a concentration in excess
of a benchmark value at Outfall I. Background fecal coliform concentrations in excess of the
benchmark value are present within the stream located in Area 1. Furthermore, observed heavy
geese activity within the southeastern portion of the closed landfill and landfill entrance areas
very likely provides a natural, on -site source of fecal coliform that is not related to past or
present landfill activities. Therefore, the Commission proposes no corrective actions related to
fecal coliform concentrations at Outfall I at this time.
Area 2
Discussion of Investigation Results: Area 2 includes the facility entrance, scalehouse, and
convenience center for residential drop-off of waste. As presented on Figure 1, analyticaI results
for voluntary samples collected from over -land stormwater flow within Area 2 identified
elevated concentrations of TSS and fecal coliform within these areas of relatively high activity.
Geese grazing within the convenience center and scalehouse area, as presented in the following
photograph, likely provides a source of both fecal coliform and TSS (please note the goose
droppings on the ground):
Geese Activity and Droppings in Area 2
The first and second semi-annual analytical results for Outfall F, the permitted outfall for Area 2,
indicated compliance with the benchmark value for TSS and exceedances of the benchmark
value for fecal coliform for both sampling events. Stormwater originating in Area 2 is directed
through broad, grassy swales to the west of Area 2 prior to discharge into South Branch Creek,
as presented in the following photograph:

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NCDENR — DWQ January 15, 2009
Attn: Mr. Bennett 4- Ref. No. 0839-6460
Area 2 Stormwater BMPs
As indicated by a large drop in both TSS and fecal coliform between the facility entrance /
scalehouse / convenience center and Outfall F, the stormwater BMPs located within Area 2
(shown above) appear to be effective and provide significant benefits to stormwater quality.
Although a large reduction of fecal coliform concentrations is attained through Area 2 BMWs,
fecal coliform concentrations at Outfall F remained slightly above the benchmark value. The
fecal coliform values at Outfall F may be attributed to naturally re -occurring wildlife activity
within the stormwater drainages and BMWs of Area 2, as shown in the following photograph:
Area 2 Geese Activity (December 2008)
One may not expect to achieve compliance with the fecal coliform benchmark value if geese are
depositing a source of fecal coliform in the BMP structures directly above Outfall F, as presented
in the above photograph.

V11
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it /A Y-
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NCDENR — DWQ January 15, 2009
Attn: Mr. Bennett -5- Ref No. 0839-6460
Proposed Actions: Due to the prolific presence of geese within the stormwater drainages and
BMPs of Area 2, the Commission proposes no corrective actions at this time. Continued
quantitative evaluations of water quality at Outfall F, as required by the permit, may exhibit a
correlation between geese activity (i.e., migration times) and reduced fecal coliform
concentrations.
Area 3
Discussion of Investigation Results: Area 3 contains a stream, North Branch Creek, that
originates on the northeastern, offsite side of Highway 52. The TSS analytical result for the
voluntary surface water sample NBC-1, located at the upgradient, onsite extent of the stream,
indicates a background concentration of TSS (84 mg/L) prior to traversing through the site. The
TSS analytical result for the voluntary surface water sample NBC-2, located at the downstream
extent of Area 3, indicates an increase in TSS concentration as the stream flows adjacent to the
closed portion of the landfill. These voluntary surface water analytical results indicate an
existing background concentration of TSS in the tributary, presumably from off -site sources,
with an increase in TSS in surface water in the downstream direction. Horse grazing activities,
located on an adjacent property to the north of Area 3, including horse trails leading up to the
edge North Branch Creek near sample NBC-1, is likely a source of suspended solids in this
stream and Area 3 stormwater runoff.
Two permitted outfalls, Outfalls Al and A2, are located within Area 3. Outfalls Al and A2
require sampling for TSS, pH, and oil and grease due to the presence of maintenance facilities
within the stormwater catchment. Stormwater pH values for the first semi-annual monitoring
event were below the benchmark values (6-9 Standard Units) due to laboratory measurement of
pH, rather than field measurement. Collection of field pH measurements during the subsequent
sampling event demonstrated acceptable pH values. Field measurement of pH during future
sampling events for each permitted outfall will be performed and is expected to mitigate the
occurrence of pH values outside of the benchmark values. Oil and grease concentrations for the
second semi-annual monitoring event were below benchmark values for both Outfalls Al and
A2. Therefore, the remaining exceedance of benchmark values for Area 3 is for TSS.
Proposed Actions: The Commission will continue to inspect for potential run-on of stormwater
containing elevated TSS concentrations from off -site land to the north of Area 3, observed to
contain agricultural and/or animal grazing activities. Similarly, the Commission will also
continue to inspect for potential on -site sources of TSS in stormwater within the catchments for
Outfalls Al and A2. If necessary, modifications to and/or additions of BMPs (e.g., silt fence,
rock check dams, additional vegetative cover, etc.) upgradient of Outfalls Al and A2 will be
performed to address any observed areas of concern.
Areas 4 and S
Discussion of Investigation Results: Areas 4 and 5 represent sediment basins B. (closed area of
landfill) and 2 (active area of landfill), respectively. Analytical results from voluntary surface
water samples collected from within the basins during non -storm conditions indicate an existing

NCDENR — DWQ January 15, 2009
Attn: Mr. Bennett -6- Ref. No. 0839-6460
background concentration of fecal coliform in excess of the benchmark value in Sediment Pond
2, but not in Sediment Pond B (Figure 1). Samples collected from the permitted outfalls of both
basins exhibit concentrations of TSS and fecal coliform in excess of benchmark values during
storm events, indicating influx of stormwater containing elevated concentrations of fecal
coliform, presumably from re -occurring wildlife activity.
Proposed Actions: The Commission proposes sediment pond outlet structure inspection and
modifications to facilitate a reduction in both TSS and fecal coliform concentrations at the
permitted outfalls during storm events, as follows:
An initial evaluation of sediment ponds B and 2 will include an inspection of the physical
condition of the riser pipe and outlet barrel for each pond, as well as the general condition of the
pond and inlet areas. Both pond outlet structures are constructed of corrugated metal pipe
(CMP). They will be inspected for possible leaks due to corrosion, physical damage, or
structural failure. If flow is observed from the outfall pipe when the observed water level in the
pond would suggest there should be no flow, a leak in the outlet structure is likely indicated.
Leaks in the riser/outfall pipe structure allow unsettled water to bypass the intended flow path
through the outlet structure and may be a source of elevated TSS levels in the discharge water. If
leaks or structural problems are found, they will be repaired, if possible. If repair is not possible,
replacement of the riser and/or outlet barrel will be evaluated.
Assuming the existing riser pipes and outlet barrels are intact, or in need of only minor repairs,
modifications to the existing structures are proposed to increase the pond's sediment trapping
ability and facilitate a reduction in TSS and fecal coliform concentrations at the associated
permitted outfalls. The intent is to use the existing structure, with minor modifications, to reduce
the construction disturbance in the pond and implement a cost-effective solution quickly.
Sediment ponds B and 2 currently have perforated riser structures surrounded by a collar of
coarse gravel. After verification of the integrity of the riser and outlet barrel, these outlet
structures will be modified in -place by placement of a layered filter system around the risers.
This modification will be subject to the approval of the NCDENR Division of Land Resources,
Land Quality Section. The existing coarse gravel around the riser structures will be removed,
and a nonwoven filter geotextile will be wrapped around the vertical portion of the risers to cover
the perforations. This filter fabric will serve to keep the next layer, sand, from entering the
perforations. The sand layer will be clean sand or washed manufactured sand, at least 18 inches
thick to provide adequate filtration capacity for the risers. A second layer of nonwoven
geotextile will be applied, and then a six -inch -thick protective layer of gravel will be placed as
the outer layer. A conceptual sketch of the system is presented below:

NCDENR—DWQ January 15, 2009
Attn: Mr. Bennett -7- Ref. No. 0839-6460
NCDOT #57 STONE
TRASH RACK
f �
I I �
L- ---- 1
Proposed Mod�f tication of Perforated Riser Stritcttire in Sediment Pond 2
Furthermore; the Commission will continue to seek out other improvements within and around
the sediment ponds, including maintenance of the slopes of the pond and inlet areas to correct
potential soil erosion by water entering the pond. These areas may be graded and seeded, as
needed, to promote vegetative growth. Temporary soil matting will be placed, if needed, to
assist with establishing vegetation. The ponds will be evaluated to determine if sediment
removal is necessary to reestablish the frill permanent pool volume. The ponds will also be
evaluated to determine if placement of porous baffles (Spec 6.65) to reduce the velocity and
turbulence of the water flowing through the basin may provide an additional, effective measure
for the reduction of TSS and fecal coliform concentrations in the pond effluent.
Upon implementation of the proposed modifications to sediment ponds B and 2, the Commission
will evaluate the effectiveness of the modification through routine stormwater quality monitoring
under the permit.
Closing
Based on the analytical results, three permitted outfalls have reached Tier Two criteria, as
follows: Outfall F (Area 2), Outfall A2 (Area 3), and Outfall B (Area 4). Tier Two qualitative
and quantitative evaluations will proceed on a monthly basis at these selected outfalls, as
required by the permit. Outfalls F and A2 have moved into Tier Two status due to two
consecutive exceedances of benchmark values for fecal coliform concentrations. As presented in
the above evaluations, naturally occurring sources of fecal coliform (e.g., wildlife and horse
grazing) have been identified within Areas 2 and 3. Therefore, the Commission requests your
consideration of a return to Tier One status for Outfalls F and A2 based on these findings.
Furthermore, the Commission is hopeful that the proposed inspection and potential modifications
to sediment pond B will also allow the return of Outfall B to Tier One status.

NCDENR — DWQ January 15, 2009
Attn: Mr. Bennett -$- Ref. No. 0839-6460
Finally, the Commission is requesting, in a separate letter to the Winston-Salem Regional Office,
NCDENR-DWQ's consideration of elimination several permitted outfalls from the facility
permit. Elimination from the permit is requested based on the location of the outfalls within the
closed portion of the landfill. To facilitate an appropriate evaluation and discussion, the
Commission would like to accept the DWQ's previous offer to conduct an on -site evaluation and
meeting regarding the requested elimination of outfall locations form the discharge permit.
The Conunission is interested in continuing a productive dialogue with NCDENR-DWQ regarding
our evaluations and proposed BMPs for the attainment and maintenance of stormwater quality
compliance. If you have any questions or require any additional information regarding the
stormwater quality evaluation results and interpretations presented, please call me. If you have any
suggestions or recommendations to this Work Plan, please let us know soon, as we plan to proceed
with proposed actions in the near future. We appreciate your assistance with this project, and look
forward to your verbal or written response.
Sincerely,
Ed Gibson, P.E.
Solid Waste Engineer
Attachment: Figure 1
C: Keith Huff, Stormwater Division Director, City of Winston-Salem, Suite 232, City Hall,
101 N. Main Street, Winston-Salem, NC, 27101
Ron DiFrancesco, Golder Associates Inc., 3719 Saunders Avenue, Richmond, Virginia,
23227, rdifrancesco-ac,golder.com
Rachel P. Kirkman, P.G., Golder Associates NC, Inc., 4900 Koger Boulevard, Suite 140,
Greensboro, NC, 27047, [e-mail]
Rose Pruitt, North Carolina Dept of Environment and Natural Resources
Division of Water Quality, Winston-Salem Regional Office, 585 Waughtown St,
Winston-Salem, NC 27107

Outfall A2
7/31/08 5 83(labj 121
11/13/08 7.02 (field) 113
Sedkm
Paid 2
10/17/08 6.25 41
=®
outfaN 2
7/31M 283
Notes:
-pH is presented in Standard Units
•TSS = Total Suspended Solids (mg/L)
•Fecal Coliform = colonies / 100 mL
*Permitted Sample locations are
labeled "Outfall," all other samples are
non -permitted evaluation samples of
surface water or overland flow.
*Sample results in red are in
exceedance of regulatory limits for
permitted outfalls
•Figure is not to scale and is used for
illustrative/sketch purposes only
NBC-2
10/17/09 7,29 140
Area 5
r'
s0W
Active Area
Of Landfill
s
Outfall Al
7/31108 5.90 (lab) 90
11/13/08 6-901field) 330
Area 3' �.
sediment
POW B & 17 &6
Area 4®
outfaN a
7/3LU slo 8,000
F,r 11/13/08 242 ?12,000
Closed Area
Of Landfill
SW-4
10/17/M 7.47 42
NBC-1
10/17/08 7.31 84
am
SIN-3
10/17/08 7.45 110 1E.000
MME.
OWA I
` IIA3108 54.7 7,800
MI
Area
(Convenience
Center)
10/27/08 7.99 560
2
_
_
f
Outfall F
CC-2
7/31/08 8.8 5,400
(Convenience
11/13/08 67.0 1,200
10/17/08 8.08 410
>60,000
>60,0w
Scalehouse
10/17/08 &M 12 43AW
Approximate
11.0W N o rth
Figure 1- Site Sketch with Analytical Results
Stormwater Quality Evaluation for the Hanes Mill Road Landfill
Hanes Mill Landfill, Forsythe County, North Carolina

' Winston-Salem • Forsyth County
Y/CountyUtilities
_ Water • Sewer • Solid Waste Disposal
RE^C:7 o
n
JAN 0 8 2009
Winston'salsa;
Re9�`nalOffice
Hanes Mill Road Landfill • 325 W. Hanes Mill Road • Winston-Salem, NC 27105 • Tel [phone] • Fax 336,661.4905
January 6, 2009
Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Revised Analytical Stormwater Monitoring Results for Hanes Mill Road
Sanitary Landfill (Certificate of Coverage No NCG 120034)
Dear Sirs:
In a cover letter dated December 15, 2008, the City County Utilities submitted the
analytical data for all of the parameters required from the Year I- Period 2 analytical
monitoring results. We have since found an error in that data, and are resubmitting the
correct information.
The December 15, 2008 submittal contains the following error: the analytical
data submitted for Outfall "I" should have been identified as Outfall "1".
Enclosed please find the revised data and forms.
Accordingly, Outfall I is now in a Tier 1 level response. The City of Winston-
Salem/Forsyth County Utilities Solid Waste Administration is moving forward with the
appropriate Tier 1 response. Please accept this information on behalf of the City of
Winston-Salem/Forsyth County Utilities Solid Waste Administration. If you need any
additional information, please contact me at [phone].
Sincerely,
Edward L. Gibson P.E.
Solid Waste Engineer
cc: Adam Rickett
-osePrt�u*P 7.
�os/
Ro 1 rancesco

12f?2/2008 `�18'�23 , 335-S96F�3?6 _ R
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ar.
s . kORATO-RI , Imo:
Analytical/Pmcu ass Consultations
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ip
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City of winston-Salem Date Sa:n})3e Collected ; :1.1/13/08
101 N. Main Street irate Sample P,aceifed 11/13/06
WInsrcn-Salem, FCC 27101 ]late Sample r-I'a-yzed 11/15/06
Attn: Ochn Spainhou-- Dare of report
Analyses Performed by KP -X3 -SJ'
Lab Sample Number
--------------------
:632039
Parameter Sroret Results
COD-H-TGH (00340) 41, "0 mgf1
TSS {QS34j 54.7 me/7
':e-C Cali=MF {.316?6) 7,606 CO1/1100 ml
Client& sample Source
:Number
'rime Co]_lected (Hrs)
OU'TFALL I ` - -
• 1�50
70- Box 473 • 7GE Sh6?+.StrQgt• fternorsville, North Caroline 27284:• 336 996=284:1 �'Fex �:8-936-C3�6
www.rend&labs.cprri

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STORMWA'aR DISC14A RG E OLJTFALL (00)
MONi-fORIING REPORT
GENERAL,i,l,.izmrr NO. NCC120000 SAMPLES COLLECTED DURING CALENDAR vr,,AR.- 2CO52,
CERTIFICA'a" OF COVERAGE NO. NCC, 12 (This monitoring report is due at the DiAsion no later than 30 dayi from the (late
the facility receives the sampling results frorn the lahoratnry-)
FACHATV NAMU If -�
—5 A'1 C06IN-6 F,5­5,4-r
PERSON COLLECTING SANIPLES PHONE NO. (3,3. 7?-7-
CERTIFIED LABORATORY 34-
La 14P 9 PLEASE, SIGN ONTHE REVU-SE 4
Part A: Specific Monitoring Requirements
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Note: If you report:a sampled -value in excess OT the bendfroark, Value', you must VI I In i rciliell .. t -ilier llor-Tier 2,i-60mises. Sue Genera fjwmit'text.
Does this Facility perform Vch..icl& Maintenance Activities using more than 55 gallons of new motor oil per month.) _ yes _no
(if yes, Colnplete Part 13)
Part 11: Vehicle Maintenance Activity Monftorin%t Requirements
0 o s s 6
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Note: If you report a 96'inpl6d vahi6 in excess of the bekhrb2rk'val6e', or­butsi& the benchu'lark range for pH, you must implement Tier I or Tier 2 responses:
See Genera[ Perrnit text.
STORM EVENT CHARACTERISTICS:
Dale 11 - 15
(first event sampled)
Tonal Event Precipitation (inrhes):---Q-5s
Dale (list each additional event sampled this reporting peri6d;,3nd rainfall amount)
Total Evelit"Precipitition (inches):
Mail Orighial:and one copy to:
Attn: DWQ Central Pi les
NLCDENItj DWQ
1617 Mail Service Center
Raleigh, NC 27/699-16t7
SVVU -2� 8-102107
Page 1, of'2

STORMWA'1 ER'DISCHARG OUTUALL (Slid)
NION TORINC Rk:YOWI'
"I certify, under penalty of law, that this ducum,cnt and. all attachments were prepared under any direction or
supervision in accorilunce witha system designed to assure that qualifies}°personnel properly gather and evaluate the
information submitted. [lased on my inquiry of the person or persons who manage the systeni; or those persons
directly responsible for gathering the information, the inform-,itioti submitted is,.to the. hest of nay knowledge and bi lief,
true, aceurate;.and complete. I am.Mvare that there are significant'penalfies for submitting false information, including
the possibility of fines and iinprisonnient for knowing violations."
(Signature of Pormiitee) (Date)
S WIJ-2 d 8-102107
Pap 2 of 2

S'1.ORMWATEER DISCHARGE OUTFALL (SDO)
MONI'rowNG REVORT
GENERAL PERMIT NO. NCC120000
CERTIFICATE' OEM COVLRAGE NO. NCG12
F ACH'[TY NA1V1r AA;- Gs5 .r1j.1 �� �� ii/C -�i ti
PERSON COE LIXTIING SAI PLE S R66--e—r 2r j C-1,
CERTIFIED D LABOIZATORY /- fr A .� Qwc4y�;I:ah #
La t} #
Part A: Specirtte l'vil}nit"oring Requirements
SAMPLES COLLECTED DURINC CALENDAR YEAR: ZaDe
(This monitoring reliort is flue ut the Division tit)later (hart 30 dales frortrthe date
the facility reeeives'the samplingresnlrs frpm.thc laboratory.)
COUNTY"
141064E t`O..(' ��7Z'7"
PLEiASL SIGN ON THE REVEIRSE 4
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Does this 661ity perlorm Vehicle IM-ninienancc Activities rising ninre limn 55 n,allons. n' new motor oil per month? yes _no
(if yes, complete. Part B)
fart 13;, Vehicle Maintenance Activity Mouitt;rinL Roguiretmems
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Note: If ; oiii report a siiinpled vidtle iii excess of the benchmark' vahie, of odtside ti}elbenchmark range Tor pH, yati must implenieht Tier 1 or'Cier 2 responses.
See General'Pe'iTfiit tent:
STORM EVI ,%I'I' CHA'I2ACTERIS-l'ICS:
Date (first event sampled)
Total Event Precipitation (inches):
Ditc (list each additional event sninpled this reporting period, and rainfiill anumut)
Total Event preeipitatinn (inches):
Mill Original and one copy to,:
Arnir DWQ.Central,Files
NCDI NR/DWQ
1617 Mail Sci-vice i;:entcr
Raleigh, NC. 27699- 16 17
SWU3 248-102107
Poge 1 of 2

S"TOR1< WA'f EA DISCHARCE OUTFALL (SDO)
POONI-TOR11C RRIVORT
"] cerfify, under penalty of la.r, that this document and all attachments were prepared under my direction or -
supervision in accordance with a system designed to assure that qualified personnel properly gather- and evaluate the
information submitted. Bas[ul oil my inciniq of the person or persbns who manatee the system, or thos'c pet -sons
directly responsif)le far gathering; the information., the information submitted is, to the. best of my' hnowledge and Relief,
d true, accurate, ancomi.flcic. I any aware that there are significant penalties for subil it#ing false information, including
the possibility of fines and impflsoninwit for knowing. viola Iinns."
(Signature of 'erniittce) ()ate)
S%VU-2-18-102107
Cabe 2 of 2

Re: [Fwd: Re: [Fwd: Re: Landfills and fecal coliform]]
Subject: Re: [Fwd: Re: [Fwd: Re: Landfills and fecal coliform]]
From: Bethany Georgoulias<[e-mail]>
Date: Thu, 18 Dec 2008 10:04:01 -0500
To: [e-mail]
CC: [e-mail], Ken Pickle <[e-mail]>, Bradley Bennett
<Bradley,[e-mail]>, Jennifer Jones <Jennifer. Jone s@nc mail. net>
Steve,
I'm so glad to hear you say that we need to pull together that monitoring because
that will hopefully be one of our tools for improving this permit the next time
around. We agree that there needs to be a strategy in the interim for dealing with
facilities that now have increased monitoring and may be coming to the ROs looking
for what the next step is. Our group plans to visit some of these after the New
Year, and addressing situations that recur with this new permit structure (like
fecal at landfills in NCG12) is something we know we need to go over at future
consistency meetings. -BG
Steve Tedder wrote:
Just a couple comments. The problem may not be the landfill but may be the way
the permit is written. We need to remember that the issue is not a standards
violation or even a permit violation but rather a cut off concentration
exceedence that ramps up the monitoring (for all outfalls). Probably the
increased monitoring should only be for the outfalls where the exceedences
occurred.
I do not think anyone has made an effort to pull together the available
monitoring that has been accomplished at the various landfills we have permitted.
That might be a good starting point. The coliform issue with seagulls is real
and treatment /landfill design is probably not the way to approach it. We've
seen similar problems in small water supplies from ducks and geese and best
treatment so far for those are DOGS. Seriously.
Since the permit is good till 2012 1 do not see it changing. This might be a
situation where, until the Division looks at the available data that has been
collected from the permitted facilities and set a course of action to'respond to
such situations, we have a policy from the director that will exempt anyone from
jumping to phase II monitoring just based on coliform data alone.
Redesigning layouts for landfills, bio-retention cells, etc is probably not the
way to go till we have made the effort to evaluate the data we have available.
Tedder
--------- Original Message --------
Subject: Re: [Fwd: Re: Landfills and fecal coliform]
Date: Wed, 17 Dec 2008 11:06:43 -0500
From: Rose Pruitt <[e-mail]>
Reply -To: [e-mail]
Organization: NC DENR - Winston-Salem Regional Office
To: [e-mail]
CC: Ken Pickle <ken.pickle_@ncm_ail.net>, Bethany Georgoulias
<[e-mail]>, Bradley Bennett <[e-mail]>,
Bill Diuguid <[e-mail]>, Mike Randall <[e-mail]>,
'Robert Patterson' <[e-mail]>, [e-mail],
"[e-mail]" <[e-mail]>, [e-mail],
[e-mail], Kelly Johnson <[e-mail]>, Annette
Lucas <[e-mail]>, Steve Tedder <[e-mail]>
References: <[e-mail]> <[e-mail]>
<[e-mail]>
There are locations at a landfill that I can see bioretention cells as viable
options for fecal removal, primarily /vegetated/ capped areas and /stabilized/
1 of 7 12/18/2008 10:49 AM

Re: [Fwd: Re: Landfills and fecal coliform]
Subject: Re: [Fwd: Re: Landfills and fecal coliform]
From: Ken Pickle <ken.pickle@ncmailnet>
Date: Wed, 17 Dec 2008 16:35:02 -0500
To: [e-mail]
CC: Jennifer. Jones @ncmaiLnet, Bethany Georgoulias <Bethany.Georgoulias@ncmaiLnet>, Bradley
Bennett <bradley.bennett@ncmaiLnet>, Bill Diuguid <Bill.Diuguid@ncmailnet>, Mike Randall
<mike.randall@ncmaiLnet>, 'Robert Patterson' <robert.patterson@ncmailnet>,
bridget.munger@ncmailnet, "brian.lowther@ncmaiLnet" <brian.lowther@ncmaiLnet>,
cory.larsen@ncmailnet, linda.willis@ncmaiLnet, Kelly Johnson <Kelly.P.Johnson@ncmailnet>,
Annette Lucas <annette.lucas@ncmailnet>, Steve Tedder <Steve.Tedder@ncmaiLnet>
Thanks Rose, I like your point about the generation of sediment from the active
areas of a landfill and the problems likely in a bioretention area from sediment
laden runoff. I agree with your observation that bioretention might be an ok BMP
for stabilized areas that show high fecals, but it's going to be a high maintenance
item (and probably -a system failure item) if installed by itself on the flow from
disturbed areas.
Ken
Rose Pruitt wrote:
There are locations at a landfill that I can see bioretention cells as viable
options for fecal removal, primarily /vegetated/ capped areas and /stabilized/
collection sites. Bioretention cells will probably not be feasible alternatives
for the entire landfill site especially the active areas. They are easily
clogged by sediment which essentially turns them into sediment basins/detention
ponds shortly after the first sediment laden stormwater hits them. Bioretention
cells need to drain within 12 hours to be effective but the sediment/detention
basins I've seen retain water much longer, some may only dry out during
droughts. My take on this research and standard rules of biology are that
pathogen reduction is achieved by 1) drying out the pathogens, and 2) exposure to
UV light. Neither of which are going to occur in sediment basins/detention ponds
containing standing water most of the time.
Active landfills are like permanent construction sites in that they are always
operating with exposed soils. Sediment removal from runoff is the primary design
function of their sediment basins and again I will point out that Land Resources
and Solid Waste require these basins to be designed to /contain/ stormwater up to
a 24hr/25yr storm event to settle out sediment. Anytime a properly maintained
sediment basin discharges it has already exceeded it's design capacity. Also
worth noting is that pathogens will adsorb to sediment particles and settle to
the bottom with them. During routine maintenance this contaminated sediment is
usually removed from the basin and returned to the active lined landfill as cap
material.
Again I strongly recommend the permit language that exempted testing for outfalls
that only discharge during a storm event that exceeds their design capacity be
returned to the permit language. It's doubtful that the discharge from a
sediment/detention basin that occurs as a result of a 24hr/25yr storm event is
truly representative of conditions at the site. It already exceeds design
capacity at that point. I'll share the monitoring results from investigations by
Forsyth Co when they come in, but additionally I expect we may see that shallow
standing water in these basins may be incubating pathogens at certain times of
the year. So it may come down to the lesser of 2 evils, bacteria or sediment?
until technology advances another system. At this time I don't think requiring
bioretention cells (that will require constant and costly reconstruction after
almost every storm event) as a blanket solution for high fecal counts at
landfills is a good idea.
Rose Pruitt
1 of 12/18/2008 10:50 AM

Re: [Fwd: Re: Landfills and fecal coliform]
Subject: Re: [Fwd: Re: Landfills and fecal coliform]
From: Jennifer Jones <Jennifer.Jones@ncmaiLnet>
Date: Wed, 17 Dec 2008 08:55:11 -0500
To: Ken Pickle <ken.pickIe@ncmaiLnet>
CC: Bethany Georgoulias <Bethany.Georgoulias@ncmaiLnet>, Bradley Bennett
<bradley.bennett@ncmaiLnet>, Bill Diuguid <Bill.Diuguid@ncmailnet>, Mike Randall
<mike.randall@ncmailnet>, 'Robert Patterson' <robert.patterson@ncmaiLnet>,
[e-mail], "brian.lowther@ncmaiLnet" <brian.lowther@ncmaiLnet>,
cory.larsen@ncmailnet, linda.willis@ncmailnet, Rose Pruitt <Rose.Pruitt@ncmailnet>, Kelly
Johnson <Ke1ly.P.Johnson@ncmailnet>, Annette Lucas <annette.lucas@ncmaiLnet>
All,
am not prepared to comment on landfills as such but I think it we need to get together to talk about them.
Bethany and I were going to talk to some Microbiologists about this issue. I think that this would be a
good first step to getting some good background information - we need this to make a decision about this.
I have some reservations about his research on BMPs suggesting that the upturned elbow is the way to
go for fecal coliforms. Bacteriallenvironmental interactions are extremely complex and it is very difficult to
tease out the relationships as John Hathaway pointed out. A lot of microbiologists spend their whole
careers trying to do this - it is definitely not an easy thing.
I think we need to proceed with a lot of caution in accepting an promoting the upturned elbows in
bioretention cells for all drainage areas - especially for in -situ soils with low permeability where the water
may sit for a long time'(which may mimic what is happening in landfill basins below), ones draining to 5A
and ORW waters, and because Bill only has 1 or a few cells' data to back this up. Additionally, I wasn't
satisfied with his answer about why soggy dry detention basins are not like soggy bioretention cells - his
answer conflicted with what they had previously stated about them and about UV in shallow wet ponds.
think we need to think carefully about this before we apply it across the state - I have strong reservations
about it. We need to see more data and we need to get some other opinions about this before we apply it
broadly.
Thanks,
Jeri
Ken Pickle wrote:
Friends,
I'd like to add perhaps new information to this discussion.
1 of 6 12/18/2008 10:52 AM

Re: [Fwd: Re: Landfills and fecal coliform]
Subject: Re: [Fwd: Re: Landfills and fecal coliform]
From: Ken Pickle <[e-mail]>
Date: Tue, 16 Dec 2008 14:25:47 -0500
To: Bethany Georgoulias<[e-mail]>
CC: Bradley Bennett <brad I ey. bennett@ncmai 1. net>, Bill Diuguid <[e-mail]>, Mike
Randall <[e-mail]>, 'Robert Patterson' <robert.Patterson @ncmail.net>, Jennifer Jones
<[e-mail]>, [e-mail], "brian.lowther@ncmail:net"
<[e-mail]>, [e-mail], [e-mail], Rose Pruitt
<[e-mail]>, Kelly Johnson <[e-mail]>
Friends,
I'd like to add perhaps new information to this discussion.
Last Friday several of us went to Sill Hunt's annual (or semi-annual?).update on his
BMP research at NCState. This year he had new information pertaining to pathogen
removal from stormwater by specific BMPs. His grad student Jon Hathaway worked with
Charlotte -Mecklenburg Stormwater Services testing percent removal efficiencies for
the indicator organism, fecal coliform. Their results do not really provide a solid
base for definitive DWQ action - - only six or more samples from nine BMPs - - but
they do suggest that it's not unreasonable to hope for fecal coliform reduction in
stormwater discharges through currently available BMPs. Additional research is
on -going.
Jon published in October of this year in the Urban Waterways Series from NC
Cooperative Extension, "Removal of Pathogens'in Stormwater." You can check out this
publication on their website. My summary of their preliminary findings is:
- Dry detention basins do absolutely nothing for pathogen reduction, and sometimes
make it worse;
- As a category of BMPs, wet ponds and wetlands are inconsistent performers;
Bioretention holds some promise for fecal reduction.
Gratifyingly, and as Jon's article points out, DWQ's BMP manual already suggests a
similar hierarchy of performance between BMPs.
That's the end of my report on new information. I have some opinions on how we
might move forward with fecal testing at landfills. I'm offering these thoughts for
your comment:
a) Consider that landfills typically have lots of land available, unless they are
approaching the end of the design life of the fill. I mean, standard landfill
design includes lots of land for expansions into Phase III, Phase IV, Phase V, etc.
My expectation is that at most sites, the addition of stormwater BMPs is not
constrained by land availability. And further, that the expansion into the next
Phase is typically a fairly large earthmoving operation. Against this background of
available land, and large earthmoving operations, the additional surface grading to
direct runoff to a designed BMP does not seem to me to be a big deal in the context
of a fill expansion.
b) I don't have a good idea of how high the fecal numbers might be in landfill
runoff. But, especially if the numbers are high, I'm not inclined to 'excuse' the
presence of fecal in landfill runoff because there are seagulls present. It is my
impression that if someone is in the landfill business, he will have seagulls. Lots
of them. Concentrated numbers of them. I think that's just part of a landfill
operation. I think the presence of seagulls at a landfill is different in magnitude
from, say, a furniture manufacturing facility with an amenity pond out front and a
1 of 4 12/17/2008 8:30 AM

Re: [Fwd: Re: Landfills and fecal coliform]
few resident ducks.
c) And further, if the presence of birds causes a significant concentration of
runoff fecals, then it seems to me that we should protect the receiving waters by
requiring our permittee to go through Tier 1, and maybe (?) Tier 2 response actions
in an attempt at an easy fix without DWQ intervention. Failing an easy fix (ie,
Tier 1 and Tier 2 response actions produced insufficient improvement), then.......
d) As provided for in the permit text, DWQ should consider investigating the
circumstances via site visit, site plan review, Phasing plan review, available land,
configuration of existing ponds and stormwater outfalls, etc. After such a review,
at the very least we might require that the permittee revise his Phasing plan so
that the next expansion incorporates a bioretention area for fecal reduction.
e) We will be called on to be very flexible in this approach, because no facility
wants to change the plans that they are already operating under. But it seems to me
that this is exactly the kind of game plan that we intended with the new stormwater
permit templates. And it seems that we can actually get some improvement in
stormwater runoff pollution from these sites.
f) As Rose suggests, perhaps part of our flexibility should be to allow the facility
to skip Tier 2 testing. But again, I don't think we can excuse high fecals at a
landfill. My preference would be to say, "OK, if you wish you can skip Tier 2
testing, and go straight to implementing a fecal control BMP (bioretention,
perhaps)."
These are just beginning thoughts, and without the benefit of point -counterpoint.
So, what do you think will work on the ground, in the regions?
Ken
Bethany Georgoulias wrote:
Everyone, this is an FYI -
We have been getting a lot of calls from landfills whose sampling results are
above the fecal coliform benchmark, and the regions will likely be dealing with
more of them getting into tier 2 (monthly) sampling requirements...and ultimately
the question of what to do about it next. Seagull populations may be a big
contributor (and not very controllable), but there are several issues to
consider. Rose has this follow-up from one they've been dealing with in
Winston-Salem, and T wanted to disseminate the info. -BG
-------- Original Message --------
Subject: Re: NCG120
Date: Thu,. 09 Oct 2008 10:45:50 -0400
From: Rose Pruitt <[e-mail]>
Reply -To: [e-mail]
Organization: NC DENR - Winston-Salem Regional Office
To: Linda Willis <[e-mail]>
CC: Bethany Georgoulias <[e-mail]>, Steve Tedder
<[e-mail]>
References: <[e-mail]> <[e-mail]>
<[e-mail]>
2 of 12/17/2008 8:30 AM

Re: [Fwd: Re: Landfills and fecal coliform]
O
The municipal landfill that I inspected here in Winston Salem has just submitted
their first tier response to busting the fecal barrier after some long discussion
with us. The landfill plans to do some comparative sampling in sediment ponds at
times _/other than/ storm events to compare incubating fecal counts to storm
discharge. Also upstream/downstream sampling for background comparison. They
are considering covering an area designated as customer drop off that drains to a
stream. Also we will be establishing representative outfall status for some
outfalls, particularly in a closed and capped area of the landfill. At the end
of the day if I don't see that they can control the fecal counts, I will
recommend to CO that they not advance to tier two testing because it's a waste of
time and resources. Also I highly recommend that the language exempting testing
for 25 yr storm basins be put back into the permit. No point in monitoring flow
that exceeds design capacity deemed adequate by our sister agency.
I recently learned about a study that analyzed garbage truck leachate on city
streets for fecal contamination and found some pretty significant impacts. I'm
always wary of offending any large bird populations after seeing that Alfred
Hitchcock movie. I inquired about truck cleaning operations for the local
municipality and found that essentially there aren't any. This is probably worth
another look as a contamination source. I did suggest the municipality consider
a regular washout of their vehicles as a possible control. Of course for every
vehicle they have some control over there will be 50 that they don't.
Rose Pruitt
NCDENR-DWQ Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
On 10/9/2008 9:22 AM, Linda Willis wrote:
S000. . 11d like to pursue the stormwater ponds with the capability of storing
the 25 year 24 hour storm event and ensure that if that is a criterion for
DWM, that we reinforce that. . . first. ? How did Rose handle hers after all
was said and done?
LW
Bethany Georgoulias wrote:
Linda,
We've gotten this question before...we're hearing it more and more. In
fact, it's an issue we will revisit when the General Permit is renewed for
these sites.
A couple of things -
1) our understanding is that the stormwater ponds at these landfills should
be designed for the 25-year, 24-hour storm event because of the Division of
Solid Waste requirements. If the ponds are discharging because .the storm
event is beyond the design capacity (which we wouldn't expect to happen
often at all), it's conceivable that high fecal coliform will come with it
(particularly with healthy populations of seagulls around there to "seed
it"). We're even wondering if the ponds actually promote the incubation of
fecal bacteria, but that's a discussion we haven't completely explored.
Anyway, we are maybe not as concerned about high fecal coming out of ponds
that only discharge in such large events... so the first question is, do
they expect to even have a discharge on a monthly basis? (I guess
regardless, if they are in that 'Fier 2, they will have to submit DMR forms
even when there is no discharge, so maybe they're concerned about reporting
requirement burden at the very least.) So, bottom line here is: we
3 of . 12/17/2008 8:30 AM

Re: [Fwd: Re: Landfills and fecal coliform]
probably should have considered exempting discharges from those ponds in
some fashion in the NCG12 permit, or at least reconsidered how the tiers
were triggered with fecal numbers. Rose Pruitt in Winston-Salem dealt with
the issue most recently, and she clued us in to the 25-year design
criterion from DWM.
2) If the issue is not discharge from big stormwater ponds blowing a 25-yr
design capacity in rare events, and other stormwater discharges from the
landfill site are exceeding the fecal benchmark, the landfill has a
responsibility to ensure they've eliminated all other sources to the extent
possible and practical. If the problem really is the seagulls (and it's
not unlikely that it is), DWQ RO has a few.options -- they can agree it's
an issue that has no resolution and agree to a decrease in monitoring back
to semi-annual (or anything the RO chooses). However, I'd encourage the
region to remind them that whether it's beyond their control or not, we do
have a responsibility to assess how it is impacting the surface waters to
which they discharge. If there's a problem there, it is possible we would
consider moving them to an individual permit, requiring other BMP measures,
or something else (but no, I'm not sure at all what those might be -- and I
think we'd have to have a very good reason for making them do something
since landfills do hoards of seagulls and probably can't control it very
well.)
Not sure if that helps too much, but maybe a little. I've gotten a few
calls on this in the past year, and I've been instructing people to go
ahead and touch base with the RO Supervisor so that the region was aware of
the problem -- and potentially the inability of the landfill to control
seagull populations (and the poop that comes with them!).
--BG
Linda Willis wrote:
Greetings,
Got a good one for you. City of Jville, landfill. . rec'd a call from
the permittee'and he said that they busted fecal in the stormwater due
to seagulls. Wanted to know how to get the exclusion from the monthly
monitoring for a source they cannot control. How would you all suggest
I handle this? Have you been approached by any other landfill operators
who have the same concerns?
Linda
4 of 12/17/2008 8:30 AM

October 28, 2008
Mr. Edward Gibson, P.E.
Winston-Salem • Forsyth County
City/County Utilities
Hanes Mill Road Landfill
325 W. Hanes Mill Road
Winston-Salem, NC 27105
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
RECEIVED
N.C. Oeot of ENR
OCT 30
winown-Salem
Reglonal Offlca
Subject: General Permit No. NCO120000
Hanes Mill Landfill
COC No. NCG120034
Forsyth County
Dear Mr. Gibson:
We received your letter regarding Stormwater Permit Work Plan actions on October b,
2008. You asked us for recommendations to address.elevated TSS and fecal colifann levels, and
pH values outside the benchmark range. Your letter describes an appropriate response for
verifying pH with field measurements. You also propose other sampling efforts that should help
evaluate current conditions and potential areas of BMP improvement.
When assessing non -storm conditions in the sediment ponds, DWQ recommends that the
Landfill performs fecal sampling when the ambient outdoor temperature does not inhibit
bacterial growth (i.e., not in the middle of winter, but rather during more mild climate
conditions). In addition, the city could consider regular washout of trash collection vehicles as a
BMP measure, especially if you suspect runoff from truck traffic as a major source of
contaminants. (Please remember that truck washing should be performed where the wash water,
which is a wastewater, is captured and properly treated. Unlawful discharges of wastewater are
not authorized by the stormwater permit.)
Your letter also requests sampling requirements be waived in a couple of different
respects. First, if a representative storm event does not occur before the end of the current
compliance period, you asked that requirements to complete the second semi-annual sampling
event be waived for 2008. In response, if a qualifying Storm event (or discharge associated with
such an event) does not occur in the compliance period, you only need to report to DWQ "No
Flow" on the monitoring form to comply with reporting requirements; no waiver is necessary.
This reporting requirement is detailed in Part III, Section E (L) and is in the second footnote of
Table 2 in Part II.
rna
mrall
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 'Phone [phone] Customer Service
Internet: www.ncwatcrquality.ore Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recydedll0% Post Consumer Paper

Mr.' Ed Gibson
Hanes Mill Landfill
NCG 120034
October 28, 2008
Second; you asked DWQ to eliminate sampling requirements for outfalls that drain
closed parts of the landfill and do not receive stormwater runoff from industrial activities
(specifically, Outfalls B, C, D, and E). Under the NPDES Program, those drainage areas may
not be subject to sampling requirements of General Permit NCG120000. However, before
suspending monitoring, please have the Winston-Salem Regional Office verify that conditions
for exemption of hese outfalls from the permit are satisfied. Areas of the landfill may not be
exempt simply because they are closed, especially if vehicles still cross that property to access
active areas, for example.
You do have the option to request Representative Outfall Status (ROS) for some of the
outfalls that discharge stormwater associated with landfill operations. ROS would reduce
analytical monitoring obligation (although qualitative monitoring is still required). For your
convenience, we have enclosed an ROS request form, which you may send directly to the
Winston-Salem Regional Office. For future reference, you can find this form on our website, in
the Miscellaneous Forms section:
http:/ih2o.enr.-state.ne.us/su/Fonns Documents. htm#miscforms
If sampling results prompt Tier 2 response actions, which include monthly sampling, you
may work with the Regional Office to find and implement an alternative response strategy. That
alternative might include decreased monitoring, should regional staff agree it is appropriate. We
advise that you continue working with the Region on this matter. If you have any questions
about this letter, please Bethany Georgoulias at telephone number [phone].
Sincerely,
Bradley Bennett
Stormwater Permitting Unit Supervisor
cc: Winston-Salem Regional Office/Attn: Rose Pruitt
Central Files
Stormwater Permitting Unit Files
Enclosure

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
October 28, 2008
Mr. Edward Gibson, P.E.
Winston-Salem • Forsyth County
City/County Utilities
Hanes Mill Road Landfill
325 W. Hanes Mill Road
Winston-Salem, NC 27105
Subject: General Permit No. NCG 120000
Hanes Mill Landfill
COC No. NCG120034
Forsyth County
Dear Mr. Gibson:
We received your letter regarding Stormwater Permit Work Plan actions on October 6,
2008. You asked us for recommendations to address elevated TSS and fecal coliform levels, and
pH values outside the benchmark range. Your letter describes an appropriate response for
verifying pH with field measurements. You also propose other sampling efforts that should help
evaluate current conditions and potential areas of BMP improvement.
When assessing non -storm conditions in the sediment ponds, DWQ recommends that the
Landfill performs fecal sampling when the ambient outdoor temperature does not inhibit
bacterial growth (i.e., not in the middle of winter, but rather during more mild climate
conditions). In addition, the city could consider regular washout of trash collection vehicles as a
BMP measure, especially if you suspect runoff from truck traffic as a major source of
contaminants. (Please remember that truck washing should be performed where the wash water,
which is a wastewater, is captured and properly treated. Unlawful discharges of wastewater are
not authorized by the stormwater permit.)
Your letter also requests sampling requirements be waived in a couple of different
respects. First, if a representative storm event does not occur before the end of the current
compliance period, you asked that requirements to complete the second semi-annual sampling
event be waived for 2008. -In response, if a qualifying storm event (or discharge associated with
such an event) does not occur in the compliance period, you only need to report to DWQ "No
Flow" on the monitoring form to comply with reporting requirements; no waiver is necessary.
This reporting requirement is detailed in Part III, Section E (L) and is in the second footnote of
Table 2 in PartII.
N,AhCarolina
,lVaturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) W7-6300 Customer Service
Internet: www.ncwaterguality.ore Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/l0% Post Consumer Paper

Mr. Ed Gibson
Hanes Mill Landfill
NCG 120034
October 28, 2008
Second, you asked DWQ to eliminate sampling requirements for outfalls that drain
closed parts of the landfill and do not receive stormwater runoff from industrial activities
(specifically, Outfalls B, C, D, and E). Under the NPDES Program, those drainage areas may
not be subject to sampling requirements of General Permit NCG120000. However, before
suspending monitoring, please have the Winston-Salem Regional Office verify that conditions
for exemption of these outfalls from the permit are satisfied. Areas of the landfill may not be
exempt simply because they are closed, especially if vehicles still cross that property to access
active areas, for example.
You do have the option to request Representative Outfall Status (ROS) for some of the
outfalls that discharge stormwater associated with landfill operations. ROS would reduce
analytical monitoring obligation (although qualitative monitoring is still required). For your
convenience, we have enclosed an ROS request form, which you may send directly to the
Winston-Salem Regional Office. For future reference, you can find this form on our website, in
the Miscellaneous Forms section:
http://h2o_enr.state.nc.us/su/Foims Documents.htm#miscforms
If sampling results prompt Tier 2 response actions, which include monthly sampling, you
may work with the Regional Office to find and implement an alternative response strategy. That
alternative might include decreased monitoring, should regional staff agree it is appropriate. We
advise that you continue working with the Region on this matter. If you have any questions
about this letter, please Bethany Georgoulias at telephone number [phone].
Sincerely,
Bradley Bennett
Stormwater Permitting Unit Supervisor
cc: Winston-Salem Regional Office/Attu: Rose Pruitt
Central Files
Stormwater Permitting Unit Files
Enclosure

Re: Hanes Mill Landfill
Subject: Re: Hanes Mill Landfill
From: Bethany Georgoulias <Bethany.GeorgouIias@ncmaiLnet>
Date: Tue, 28 Oct 2008 15:53:25 -0400
To: "Kirkman, Rachel" <[e-mail]>
CC: Rose. [e-mail], "DiFrancesco, Ron" <Ron_DiFrancesco agolder.com>
Rachel,
Attached is the letter we're putting in the mail to Mr. Gibson today; it will probably
go out tomorrow. If you have any questions, let me know, but Rose is probably the
best point of contact. A direct link to the form for requesting representative
outfall status is here:
htto://h2o.enr.state.nc.us/su/documents/ROS Application SWU-ROS-090508.pdf
Regards,
Bethany Georgoulias
Kirkman, Rachel wrote:
f Good morning.
Thank you -for your response. Please call us if you have any questions
or need clarification. We completed the sampling recently and are
awaiting analytical results. We appreciate your assistance on this
project.
Rachel
Rachel Kirkman, P.G. I Senior Project Geologist I Golder Associates SIC,
Inc.
The Wingate Building, 4900 Koger Boulevard, Suite 140, Greensboro, North
Carolina, USA 27407-2710
T: [phone] D: [phone] F: [phone] C:
[phone] E: Rachel [e-mail] l www.golder.com
Work Safe, Home Safe
This email transmission is confidential and may contain proprietary
information for the exclusive use of the intended recipient. Any use,
distribution or copying of this transmission, other than by the intended
recipient, is strictly prohibited. If you are not the intended
recipient, please notify the sender and delete all copies. Electronic
media is susceptible to unauthorized modification, deterioration, and
incompatibility. Accordingly, the electronic media version of any work
Product may not be relied upon.
Please consider the environment before printing this email.
-----Original Message -----
From: Bethany Georgoulias [mailto:3ethan .Geor [e-mail]] Sent: Tuesday,
October 28, 2008 8:55 AM
To: Kirkman, Rachel
Cc: Bradley Bennett; DiFrancesco, Ron; Rose.PruittGNCmail.net
Subject: Re: [Fwd: RE: phone message]
Ms. Kirkman,
I wanted to let you know that we are working on a response letter to Hanes Mill
Landfill in coordination with the Winston-Salem Regional Office and hope to get it
out very soon.
Regards,
Bethany Georgoulias
1 of 2 10/28/2008 3:55 i'M

Re: Hanes Mill Landfill
Bethany Georgoulias
Environmental Engineer
NC DENR Division of Water Quality
Stormwater Permitting Unit
tel. [phone]
fax [phone]
i Content -Type; application/pH
H anesMiilLandfill_Response.pdf
Content -Encoding: base64
2 of 2 10/28/2008 3:55 PM

Michaei F. Easley, Governor
William G. Ross Jr., Secretan
North Carolina Department of Environment and Natural Resources
Coleen H, Sullins, Director
Division of Water Quality
October 28, 2008 - DRAFT
Mr. Edward Gibson, P.E.
Winston-Salem • Forsyth County
City/County Utilities
Hanes Mill Road Landfill
325 W. Hanes Mill Road
Winston-Salem, NC 27105
Subject: General Permit No. NCG120000
Hanes Mill Landfill
COC No. NCG120034
Forsyth County
Dear Mr. Gibson:
We received your letter regarding Stormwater Permit Work Plan actions on October 6,
2008. You asked us for recommendations to address elevated TSS and fecal coliform levels, and
pH values outside the benchmark range. Your letter describes an appropriate response for
verifying pH with field measurements. You also propose other sampling efforts that should help
evaluate current conditions and potential areas of BMP improvement.
When assessing non -storm conditions in the sediment ponds, DWQ recommends that the
Landfill performs fecal sampling when the ambient outdoor temperature does not inhibit
bacterial growth (i.e., not in the middle of winter, but rather during more mild climate
conditions). In addition, the city could consider regular washout of trash collection vehicles as a
BMP measure, especially if you suspect runoff from truck traffic as a major source of
contaminants.
Your letter also requests sampling requirements be waived in a couple of different
respects. First, if a representative storm event does not occur before the end of the current
compliance period, you asked that requirements to complete the second semi-annual sampling
event be waived for 2008. In response, if a qualifying storm event (or discharge associated with
such an event) does not occur in the compliance period, you only need to report to DWQ "No
Flow" on the monitoring form to comply with reporting requirements; no waiver is necessary.
This reporting requirement is detailed in Part III, Section E (E) and is in the second footnote of
Table 2 in Part II.
Wo hCarohna
I/vat
mallil
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
internet: wwwncwaterqu lity,org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycledl30% Post Consumer Paper

tr•r
Mr. Ed Gibson
Hanes Mill Landfill
NCG 3 20034
October 28, 2008
Second. you asked DWQ to eliminate sampling requirements for outfalls that drain
closed parts of the landfill and do not receive stormwater runoff from industrial activities
(specifically; Outfalls B, C, D, and E). Under the NPDES Program, those drainage areas may
not be subject to sampling requirements of General Permit NCG120000. However, before
suspending monitoring, please have the Winston-Salem Regional Office verify that conditions
for exemption of these outfalls from the permit are satisfied. Areas of the landfill may not be
exempt simply because they are closed, especially if vehicles still cross that property to access
active areas, for example.
You do have the option to request Representative Outfall Status (ROS) for some of the
outfalls that discharge stormwater associated with landfill operations. ROS would reduce
analytical monitoring obligation (although qualitative monitoring is still required). For your
convenience, we have enclosed an ROS request form, which you may send directly to the
Winston-Salem Regional Office. For future reference, you can find this form on our website, in
the Miscellaneous Forms section:
http://h2o.enr.state.nc.us/sulFortns_Docum ents.htrn#miscforms
-If sampling results prompt Tier 2 response actions, which include monthly sampling, you
may work with the Regional Office to find and implement an alternative response strategy. That
alternative might include decreased monitoring, should regional staff agree it is appropriate. We
advise that you continue working.with the Region on this matter. If you have any questions
about this letter, please Bethany Georgoulias at telephone number [phone].
Sincerely,
Bradley Bennett
Stormwater Permitting Unit Supervisor
cc: Winston-Salem Regional Office/Attn: Rose Pruitt
Central Files
Stormwater Permitting Unit Files
Enclosure

RE: [Fwd: RE: phone message]
Subject: RE: [Fwd: RE: phone message]
From. "Kirkman, Rachel" <[e-mail]>
Date: Tue, 28 Oct 2008 09:04:58 -0400
To: "Bethany Georgoulias" <Bethany.Georgoulias a ncmail.net>
CC: "Bradley Bennett" <[e-mail]>, "DiFrancesco, Ron"
<[e-mail]>, <[e-mail]>, <[e-mail]>
Good morning.
Thank you for your response. Please call us if you have any questions
or need clarification. We completed the sampling recently and are
awaiting analytical results. We appreciate your assistance on this
project.
Rachel
Rachel Kirkman, P.G. I Senior Project Geologist I Golder Associates NC,
Inc.
The Wingate Building, 4900 Koger Boulevard, Suite 140, Greensboro, North
Carolina, USA 27407-2710
T: [phone] D: +l [phone] 1 F: [phone] I C:
[phone] E: Rachel [e-mail] I www.golder.com
Work Safe, Home Safe
This email transmission is confidential and may contain proprietary
information for the exclusive use of the intended recipient. Any use,
distribution or copying of this transmission, other than by the intended
recipient, is strictly prohibited. If you are not the intended
recipient, please notify the sender and delete all copies. Electronic
media is susceptible to unauthorized modification, deterioration, and
incompatibility. Accordingly, the electronic media version of any work
product may not be relied upon.
Please consider the environment before printing this email.
-----Original Message -----
From: Bethany Georgoulias[mailto:[e-mail]
Sent: Tuesday, October 28, 2008 6:55 AM
To: Kirkman, Rachel
Cc: Bradley Bennett; DiFrancesco, Ron; [e-mail]
Subject: Re: [Fwd: RE: phone message]
Ms. Kirkman,
I wanted to let you know that we are working on a response letter to
Hanes Mill Landfill in coordination with the Winston-Salem Regional
Office and hope to get it out very soon.
Regards,
Bethany Georgoulias
Bethany Georgoulias
Environmental Engineer
NC DENR Division of Water Quality
Stormwater Permitting Unit
tel. [phone]
fax [phone]
1 of 3 10/28/2008 9:06 AM

RE: [Fwd: RE: phone message]
Bradley Bennett wrote:
-------- Original Message --------
Subject: RE: phone message
Date: Mon, 27 Oct 2008 15:40:34 -0400
From: Kirkman, Rachel <Rachel [e-mail]>
To: Bradley Bennett <[e-mail]>
CC: DiFrancesco, Ron <Ron [e-mail]>
References:
<[e-mail]>
Good afternoon.
I wanted to follow up with you regarding the emails/voice mails below.
We have completed some investigative.sampling at the Hanes Mill
Landfill to comply with the Tier 1 permit requirements, and as
described in the Work Plan submitted by the Commission on Oct. I.
Please let me know if we should follow up with you and/or with Rose
Pruitt (in Winston) regarding our findings. Also, I have copied Ron
DiFrancesco as I will be out on maternity leave in the near future if
you can please copy him on your reply.
Thanks for your assistance.
Rachel
------------------------------------------------------------------------
I*Rachel Kirkman, P.G.* � Senior Project Geologist I *Golder Associates
NC,
*The Wingate Building, 4900 Koger Boulevard, Suite 140, Greensboro,
North Carolina, USA 27407-2710
*T: *[phone] *D: *[phone] *F: *+1 (336)
852-4904 1 #C: *[phone] *E: *Rachel_ [e-mail]
<mailto:Rachel [e-mail]> I *www.golder.com*
<http://www.golder.com/>*
VWork Safe, Home Safe/**/
/This email transmission is confidential and may contain proprietary
information for the exclusive use of the intended recipient. Any use,
distribution or copying of this transmission, other than by the
intended recipient, is strictly prohibited. If you are not the
intended recipient, please notify the sender and delete all copies.
Electronic media is susceptible to unauthorized modification,
deterioration, and incompatibility. Accordingly, the electronic media
version of any work product may not be relied upon./
*Please consider the environment before printing this email.*
*From:* Kirkman, Rachel
*Sent:* Wednesday, October 15, 2008 10:12 AM
*To:* Bradley Bennett
*Subject:* phone message
Good morning Mr. Bennett.
2 of 3 10/28/2008 9:06 AM

RE: [Fwd: RE: phone message]
I left you a voice mail last week regarding the City of
Winston/Forsyth County Utilities Commission's letter to you dated
October 1, 2006. Please call when you can to discuss or if I need to
discuss with Rose Pruitt instead, please let me know. Thank you for
your assistance on this project.
Rachel
------------------------------------------------------------------------
f *Rachel Kirkman, P.G.* I Senior Project Geologist I *Golder Associates
NC, Inc.**
*The Wingate Building, 4900 Koger Boulevard, Suite 140, Greensboro,
North Carolina, USA 27407-2710
*T: *[phone] f *D: *[phone] *F: *+1 (336)
852-4904 1 *C: *[phone] *E: *Rachel_ [e-mail]
<mailto:[e-mail]> I *www.golder.com*
<http://www.golder.com/>*
*
*/Work Safe, Home Safe/**/
/This email transmission is confidential and may contain proprietary
information for the exclusive use of the intended recipient. Any use,
distribution or copying of this transmiss.ion, other than by the
intended recipient, is strictly prohibited. if you are not the
intended recipient, please notify the sender and delete all copies.
Electronic media is susceptible to unauthorized modification,
deterioration, and incompatibility. Accordingly, the electronic media
version of any work product may not be relied upon./
*Please consider the environment before printing this email.*
--------------------------------------------------------
Bradley Bennett
N.G. Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Fax: [phone]
email: [e-mail]
Website: http://h2o.enr.state.nc.us/su/stormwater.html
3 of 3 10/28/2008 9:06 AM

Hanes Mill landfill - Draft Response Letter
P
Subject: Hanes Mill Landfill - Draft Response Letter
From: Bethany Georgoulias<[e-mail]>
Date: Mon, 27 Oct 2008 13:20:57 -0400
To: Rose.Pruitt@\TCmall.net
CC: Bradley Bennett <[e-mail]>
Rose,
Attached is my stab at a response letter to these guys. Please let me know what you
think. If you're around this afternoon or tomorrow, I can give a call to talk more
about it -- there's probably a lot of room for improvement. I'll be in a meeting
until 3 or 3:30 today.
One issue we have to work out with this is whether they have outfalls that are
exempt from NPDES permit monitoring, or whether they should be under the permit, but
might be eligible for ROS. I talked to Bradley not long about about what areas of
closed landfills we don't cover under the program, and I've tried to explain the
answer here. Rose, I'm not sure if you're in agreement (or maybe it's just too
tough for this landfill layout to prevent activities from really crossing boundaries
to these drainage areas), but I remember you were uncomfortable with landfills not
having to monitor some of their outfalls because they thought they were "exempt
because of no industrial activities." If memory serves, you called it
cherry -picking
We can talk more. I guess it's possible to keep them monitoring if the RO feels
it's a potential stormwater problem -- similar to the way we can always pull someone
under an NPDES permit even when they're.not automatically in one of the categories.
We may just have to spell that out in this letter (i.e., make their only option the
ROS route to reduce monitoring burden). I think we'll just have to be clear about
what the concerns.are.
Thanks,
BG
Rose Pruitt wrote:
I'll send you a copy by courier
Rose Pruitt
NCDENR-DWQ Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
On 10/9/2008 11:26 AM, Bethany Georgoulias wrote:
f Rose,
I'm not sure I know which letter that is. I'm definitely not aware of a
response. Was it an ROS request? I don't have it as one I handled and
forwarded to the WSRO. Bradley?
Rose Pruitt wrote:
Bethany
I got a copy of the letter Ed Gibson sent to Bradley about that WS
Landfill. Is there any response by your group yet? I think they might
need a reminder that the fecal sampling of the ponds should be done at a
time when the ambient outdoor temperature doesn't inhibit bacterial growth
- like the middle of winter. The truck wash out might be worth a mention
1 of 4 10/28/2008 9:06 AM

Hanes Mj11 Landfill - Draft Response Letter
in writing. I don't think it was Ed that I discussed that with. Let me
know if I need to take a look at the outfalls up for ROS.
Rose Pruitt
NCDENR-DWQ Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
On 10/9/2008 10:53 AM, Bethany Georgoulias wrote:
Linda,
I let Rose respond because I wasn't sure what the actions had been since
she asked us about it. Rose, this is great info. and I've shared it
with the rest of our staff to be aware of because we ate occasionally
getting calls from landfills about this issue. We're also making sure
we consider these issues for the next NCG12 renewal; I hadn't even
thought about regular vehicle washing.
Oh, and I'm scared of all those birds in that movie, too...
-BG
Rose Pruitt wrote:
The municipal landfill that I inspected here in Winston Salem has
just submitted their first tier response to busting the fecal barrier
after some long discussion with us. The landfill plans to do some
comparative sampling in sediment ponds at times _/other than/_ storm
events to compare incubating fecal counts to storm discharge. Also
upstream/downstream sampling for background comparison. They are
considering covering an area designated as customer drop off that
drains to a stream. Also we will be establishing representative
outfall status for some outfalls, particularly in a closed and capped
area of the landfill. At the end of the day if I don't see that they
can control the fecal counts, I will recommend to CO that they not
advance to tier two testing because it's a waste of time and
resources. Also I highly recommend that the language exempting
testing for 25 yr storm basins be put back into the permit. No point
in monitoring flow that exceeds design capacity deemed adequate by
our sister agency.
I recently learned about a study that analyzed garbage truck leachate
on city streets for fecal contamination and found some pretty
significant impacts. I'm always wary of offending any large bird
populations after seeing that Alfred Hitchcock movie. I inquired
about truck cleaning operations for the local municipality and found
that essentially there aren't any. This is probably worth another
look as a contamination source. I did suggest the municipality
consider a regular washout of their vehicles as a possible control.
Of course for every vehicle they have some control over there will be
50 that they don't.
Rose Pruitt
NCDENR-DWQ Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
On 10/9/2008 9:22 AM, Linda Willis wrote:
IS000. . I'd like to pursue the stormwater ponds with the
2 of 4 10/28/2008 9:06 AM

Hanes Mill Landfill - Draft Response Letter
capability of storing the 25 year 24 hour storm event and ensure
that if that is a criterion for DWM, that we reinforce that. . .
first. ? How did Rose handle hers after all was said and done?
LW
Bethany Georgoulias wrote:
Linda,
We've gotten this question before ... we're hearing it more and
more. In fact, it's an issue we will revisit when the General
Permit is renewed for these sites.
A couple of things -
1) Our understanding is that the stormwater ponds at these
landfills should be designed for the 25-year, 24-hour storm
event because of the Division of Solid Waste requirements. If
the ponds are discharging because the storm event is beyond the
design capacity (which we wouldn't expect to happen often at
all), it's conceivable that high fecal coliform will come with
it (particularly with healthy populations of seagulls around
there to "seed it"). We're even wondering if the ponds
actually promote the incubation of fecal bacteria, but that's a
discussion we haven't completely explored. Anyway, we are
maybe not as concerned about high fecal coming out of ponds
that only discharge in such large events... so the first
question is, do they expect to even have a discharge on a
monthly basis? (I guess regardless, if they are in that.Tier
2, they will have to submit DMR forms even when there is no
discharge, so maybe they're concerned about reporting
requirement burden at the very least.) So, bottom line here
is: we probably should have considered exempting discharges
from those ponds in some fashion in the NCG12 permit, or at
least reconsidered how the tiers were triggered with fecal
numbers. Rose Pruitt in Winston-Salem dealt with the issue
most recently, and she clued us in to the 25-year design
criterion from DWM.
2) If the issue is not discharge from -big storm:ater ponds
blowing a 25-yr design capacity in rare events, and other
stormwater discharges from the landfill site are exceeding the
fecal benchmark, the landfill has a responsibility to ensure
they've eliminated all other sources to the extent possible and
practical. If the problem really is the seagulls (and it's not
unlikely that it is), DWQ RO has a few options -- they can
agree it's an issue that has no resolution and agree to a
decrease in monitoring back to semi-annual (or anything the RO
chooses). However, I'd encourage the region to remind them
that whether it's beyond their control or not, we do have a
responsibility to assess how it is impacting the surface waters
to which they discharge. If there's a problem there, it is
possible we would consider moving them to an individual permit,
requiring other BMP measures, or something else (but no, I'm
not sure at all what those might be -- and I think we'd have to
have a very good reason for making them do something since
landfills do hoards of seagulls and probably can't control it
very well.)
Not sure if that helps too much, but maybe a little. I've
gotten a few calls on this in the past year, and I've been
instructing people to go ahead and touch base with the RO
Supervisor so that the region was aware of the problem -- and
potentially the inability of the landfill to control seagull
3 of 4 10/28/2008 9:06 AM

Hanes Mill Landfill - Draft Response Letter
populations (and the poop that comes with them!).
-BG
Linda Willis wrote:
Greetings,
Got a good one for you. City of Jville, landfill. . rec'd a
call from the permittee and he said that they busted fecal
in the stormwater due to seagulls. Wanted to ;snow how to
get the exclusion from the monthly monitoring for a source
they cannot control. How would you all suggest I handle
this? Have you been approached by any other landfill
operators who have the same concerns?
Linda
Bethany Georgoulias
Environmental Engineer
NC DENR Division of Water Quality
Stormwater Permitting Unit
tel. [phone]
fax (9
L9) 807-6494 _
Content -Type: application/pdf
NCG120034_HaneMillLandfill_Request.pdfl �
Content-Encoding:'base64
— Content -Type: application/msword ]
HanesiMillLandfill �Response.doe
Content -Encoding: base64
4 of 4 10/28/2008 9:06 AM

i
Re: Qualitative Monitoring Reports
t Subject: Re: Qualitative Monitoring Reports
From: Rose Pruitt <[e-mail]>
Date: Fri, 24 Oct 2008 10:41:36 -0400
To: Jolui Spainhour <JO [e-mail]>
John
The form you submitted appears to have all of the information required by the permit
for Qualitative monitoring. The Division has no problem with permittees using their
own forms as long as all of the required monitoring information is presented. This
policy also applies to the sample form for analytical monitoring. When a site has
many more outfalls than would fit on the sample form it is both common and allowable
for the permittee to submit the data on a form of their own design. Some facilities
simply alter the sample form by adding rows, others design another form. The permit
requires that certain data be recorded but does not require that our form be used.
Rose Pruitt
NCDENR-DWQ Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
On 10/22/2008 9:19 AM, John Spainhour wrote:
Rose,
As per our phone conservation, attached is the spreadsheet in question used
at Hanes Mill Landfill for stormwater discharge data collection. This document
would reduce the use of parer and time. Upon approval, Ed Gibson would like from
you in writing that this is an acceptable document for transposing data. Intern
the Stormwater Division would like in writing From Mr. Gibson stating his
approval of this document.
John R. Spainhour
Environmental Control Supervisor Stormwater Division
Ph: 336 747-6965
Fx: 336 748-3173
[e-mail]
I of 1 10/24/2008 10A5 AM

Stormwater Discharge Outfall (SDO) Qualitative Monitoring Report
Certii%,ate of Coverage No, NCG 120034
facility Name: Hanes Mill Road Landfill (Solid Waste Disposal Facility) County: Forsyth
Phone Number: [phone]
Inspector: Date of Inspection:
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
Rainfall:
4
_, Cif►'a►f11�i�astr�n-Salem
�- S�or a�
❑hisi01i
Color Floating Suspended Oil Deposition Erosion
Describe the industrial activities (basic colors Clarity Solids Solids Foam Sheen at Outfall at Outfall Other Obvious Indicators
Outfall Structure Receiving Stream that occur wrn outfall drainage area & tint) Odor (1-10) (1-10) (1-10) (Y or N) (Y or N) (Y or N) (Y or N) of stormwater Pollution
1
36" Conc.
Mill Creek
Landfill Activities
Pipe
Al
18" Conc.
Mill Creek
Landfill Activities
Pipe
A2
18" Conc.
Mill Creek
Landfill Activities
Pipe
1
18" Conc.
Mill Creek
Landfill Activities
Pipe
2
18" Conc.
Mill Creek
Landfill Activities
Pipe
3
18" Conc.
Mill Creek
Landfill Activities
Pipe
4
24" Conc,
Mill Creek
Landfill Activities
Pipe
5
18" Conc.
Mill Creek
Landfill Activities
Pipe
B
24" Metal
Mill Creek
Landfill Activities
Pipe
C
24" Conc.
Mill Creek
Landfill Activities
Pipe
D
24" Plastic
Mill Creek
Landfill Activities
Pipe
E
36" Conc.
Mill Creek
Landfill Activities
Pipe
F
24" Plastic
Mill Creek
Landfill Activities
Pipe
NOTE: Low clarity, high solids, and/or the presence of foam or oil sheens may be indicative of pollutant exposure. These conditions may warrant further investigation.

Ci
Winston-Salem • Forsyth County
y/County Utilities
Water • Sewer • Solid Waste Disposal
Hanes Mill Road Landfill • 325 W Hanes Mill Road • Winton -Salem, NC 27105 • Tel [phone] • Fax [phone]
October 1, 2008
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Stormwater Permitting Division `tam p
1617 Mail Service Center�p
Raleigh, North Carolina 27699-1617
oAttention: _Bradley Bennett, Stormwater Permitting Unit Supervisor o
Re: Stormwater Compliance Update and Work Plan
Hanes Mill Landfill, Forsyth County, North Carolina
Permit No. NCG120000 (NC(qMe003-4)
Dear Mr. Bennett:
As you are aware., the Winston-Salem/Forsyth County City/County Utilities Commission is
monitoring stormwater under Permit No. NCG120000 at the Hanes Mill Landfill. The
stormwater samples for the first semi-annual compliance period were collected on July 31, 2008.
Of the 13 outfalls at the facility, five had available flow to sample on this date. Based on the
analytical data, the permit benclunark value for Total Suspended Solids (TSS) was exceeded at
Outfall A2, Outfall B, and Outfall 2. The permit benchmark range for pH was exceeded at
Outfall Al and Outfall A2. The permit benchmark value for fecal coliform was exceeded at
Outfall A1, Outfall A2, Outfall B, Outfall F, and Outfall 2.
The Commission has completed the first requirement of Tier One of Permit No. NCG120000:
"Conduct a stormwater management inspection of the facility within two weeks of receiving
sampling results." We have prepared this Work Plan to address these benchmark value
exceedances in accordance with the additional Tier One requirements. Specifically, the purpose
of the Work Plan is to "identify and evaluate possible causes of the benchmark value
exceedance(s)" and "identify potential, and select the specific improvements to reduce
concentrations of the parameters of concern, or to bring concentrations within the benchmark
range."
The Work Plan is also designed to meet the Tier One requirements to "Implement the selected
actions within two months of the inspection." The implementation of the Work Plan is
dependent upon the occurrence of a qualifying storm event during hours that a laboratory can
receive samples within holding times, which may not occur within the required two -month
period. The Commission will strive to complete these assessment activities in a timely manner
prior to the second semi-annual compliance sampling event. If such -a -'storm -event -does -not
occcur-b:efore-the..endrof-the_current-compliance period, he -request -that -theme

requirem entswto,complete-•the second�mi annual.: compIia{ nce_event-be .-waived-for-2008'The
details of the Work Plan are presented below.
Work Plait
The Commission will obtain additional non-compliance samples and conduct analysis for the
constituents of concern from several sampling locations in an effort to isolate the potential
source(s) of constituents of concern. This Work Plan was developed based on our discussions
with the North Carolina (NC) Division of Water Quality (DWQ) and the City of Winston-Salem
Stormwater Division.
To address the TSS and fecal coliform issues, the following samples will be collected. We
propose to sample the sediment ponds associated with Outfall B and Outfall 2 for analysis of
TSS and fecal coliform at a time that does not coincide with a stormwater event, to help evaluate
the effects of standing water in the ponds during non -storm periods. Several samples will also be
collected during a stormwater event. We propose to collect samples from three stormwater drain
locations upgradient of Outfall F, near the scalehouse entrance and customer convenience drop-
off area for analysis of TSS and fecal coliform. These samples will help determine the effects of
runoff from truck traffic and the waste containers near this outfall. If flowing stormwater is
observed upgradient of Outfall Al and Outfall A2 during the sampling event, at least one sample
will be collected near the maintenance facility for analysis of TSS and fecal coliform. The
purpose of this sample is to determine the potential effects of activities associated with the
maintenance area. Finally, upstream and downstream samples will be collected along Grassy
Creek, and its two on -site tributaries (North Branch Creek and South Branch Creek) for analysis
of TSS and fecal coliform (for a total of six samples). These samples will be used to help
determine the background concentrations in surface water features and evaluate the potential
contributions of the on -site outfalls to the concentrations of constituents of concern.
The Commission will also collect f�aen -pH-mesuremts�farithe sampling points listed above.
Field pH measurements will also be collected — from Outfall Al and Outfall A2, as well as from a
rain water sample collected from the facility's rain gauge. It is likely that the pH values that
were outside of benchmark range for Outfall Al and Outfall A2 are biased due to the fact that
they were measured in the laboratory, rather than the field. Field_ pling oof-pHYshouldr•h le p.77::7
r••
vernfy-tliis-assumptioiy .
Sample Collection Procedures
Every attempt will be made to sample the three storm drains and the sample upgradient of
Outfall Al/Outfall A2 within the first 30 minutes of discharge. The stream locations will be
sampled as soon as possible during the storm event.
Quality Assurance/Quality Control
Golder Associates NC, Inc. (Golder) will conduct the field sampling and Environmental
Conservation Laboratories, Inc. (ENCO) will perform the required analytical services. Golder
has the required NC Laboratory Certification for measurement of field pH, and ENCO has all
pertinent certifications for the required analyses.

Schedule
The Commission will collect samples from the sediment basins associated with Outfall B and
Outfall 2 as soon as possible (and not during a rain event). The Commission will attempt to
collect all other stormwater samples as soon as a qualifying event occurs during hours that a
certified laboratory can receive samples, and as soon as possible so that sampling can hopefully
be completed prior to the second semi-annual compliance event for 2008.
Other Action Items
The Commission will evaluate the existing Erosion and Sediment Control Plan and stormwater
features at the facility and evaluate specific structural Best t -ManagemenC,-Practice—(
impro�vem.,ents-tnhat may help reducconcentrations for parameters of concern. The Commission
is also requesting that the DWQ-constder-eliinitiating,some_of:the_outfalls-for future-sainplin�
Kyents=.,based-on-the7_fact th`at7several-outfalls:are —assoc iated-with=the-closed=landf 11-and=do_not7
receive-stormwater from"areas,with-pettinenfindustria]-actiVities-2These outfalls are: Outfall
O tfall C, Outfall D, and Outfall E. We request that the DWQ advise us on how to proceed with
removing these outfalls from the sampling program for future events.
Closing
If you have any questions or require any additional information, please contact me. If you have
any suggestions or recommendations to this Work Plan, please let us know soon, as we plan to
proceed as soon as possible. We appreciate your assistance with this project.
Sincerely,
Edward Gibson, P.E.
Solid Waste Engineer
C: Rose Pruitt, North Carolina Department of Environment and Natural Resources
Division of Water Quality, Winston-Salem Regional Office, 585 Waughtown Street, Winston-
Salem, North Carolina 27107
Keith Huff, Stormwater Division Director, City of Winston-Salem, Suite 232, City Hall,
101 N. Main Street, Winston-Salem, NC, 27101
Ron DiFrancesco, Golder Associates Inc., 3719 Saunders Avenue, Richmond, Virginia, 23227,
[e-mail]
Rachel P. Kirkman, P.G., Golder Associates NC, Inc., 4900 Koger Boulevard, Suite 140,
Greensboro, NC, 27047, [e-mail]

•-' Winston-Salem • Forsyth County
.'Cty/County Utilities
Water • Sewer Solid Waste Disposal
REC1V p
h',C. deDt of ENR
OCT o 3 2008
Winston -Sal em
Regional pfl'ace
Hanes Mill Road Landfill • 325 W. Hanes Mill Road • Winston-Salem, NC 27105 • Tel [phone]
Fax [phone]
October 1, 2008
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Stormwater Permitting Division
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Attention: Bradley Bennett. Stormwater Permitting Unit Supervisor
Re: Stormwater Compliance Update and Work Plan
Hanes Mill Landfill, Forsyth County, North Carolina
Permit No. NCG120000
Dear Mr. Bennett:
As you are aware, the Winston-Salem/Forsyth County City/County Utilities Commission is
monitoring stormwater under Permit No. NCG120000 at the Hanes Mill Landfill. The
stormwater samples for the first semi-annual compliance period were collected on July 31, 2008.
Of the I') outfalls at the facility, five had available flow to sample on this date. Based on the
analytical data, the permit benchmark value for Total Suspended Solids (TSS) was exceeded at
Outfall A2, Outfall B, and Outfall 2. The permit benchmark range for.pH was exceeded at
Outfall Al and Outfall A2. The permit benchmark value for fecal coliform was exceeded at
Outfall A1, Outfall A2, Outfall B, Outfall F, and Outfall 2.
The Conunission has completed the first requirement of Tier One of Permit No. NCG120000:
"Conduct a stormwater management inspection of the facility within two weeks of receivins7
sampling results." We have prepared this Work Plan to address these benchmark value
exceedances in accordance with the additional Tier One requirements. Specifically, the purpose
of the Work Plan is to "identify and evaluate possible causes of the benchmark value
exceedance(s)" and "identify potential, and select the specific improvements to reduce
concentrations of the parameters of concern, or to bring concentrations within the benchmark
range."
The Work Plan is also designed to meet the Tier One requirements to "implement the selected
actions within two months of the inspection." The implementation of the Work Plan is
dependent upon the occurrence of a qualifying storm event during hours that a laboratory can
receive samples within holding times, which may not occur within the required two -month
period. The Commission will strive to complete these assessment activities in a timely manner
prior to the second semi-annual compliance sampling event. If such a storm event does not
occur before the end of the current compliance period, the Commission may request that the

i
-2-
requirements to complete the second semi-annual compliance event be waived for 2008. The
details of the Work Plan are presented below.
Wank Plan
The Commission will obtain additional non-compliance samples and conduct analysis for the
constituents of concern from several sampling locations in an effort to isolate the potential
source(s) of constituents of concern. This Work Plan was developed based on our discussions
with the North Carolina (NC) Division of Water Quality (DWQ) and the City of Winston-Salem
Stormwater Division.
To address the TSS and fecal coliform issues, the following samples will be collected. We
propose to sample the sediment ponds associated with Outfall B and Outfall 2 for analysis of
TSS and fecal coliform at a time that does not coincide with a stormwater event, to help evaluate
the effects of standing water in the ponds during non -storm periods. Several samples will also be
collected during a stormwater event. We propose to collect samples from three stormwater drain
locations upgradient of Outfall F, near the scalehouse entrance and customer convenience drop-
off area for analysis of TSS and fecal coliform. These samples will help determine the effects of
runoff from truck traffic and the waste containers near this outfall. If flowing stormwater is
observed upgradient of Outfall Al and Outfall A2 during the sampling event, at least one sample
will be collected near the maintenance facility for analysis of TSS and fecal coliform. The
purpose of this sample is to determine the potential effects of activities associated with the
maintenance area. Finally, upstream and downstream samples will be collected along Grassy
Creek, and its two on -site tributaries (North Branch Creek and South Branch Creek) for analysis
of TSS and fecal coliform (for a total of six samples). These samples will be used to help
determine the background concentrations in surface water features and evaluate the potential
contributions of the on -site outfalls to the concentrations of constituents of concern.
The Commission will also collect field pH measurements for the sampling points listed above.
Field pH measurements will also be collected from Outfall Al and Outfall A2, as well as from a
rain water sample collected from the facility's rain gauge. It is likely that the pH values that
were outside of benclimark range for Outfall Al and Outfall_ A2 are biased due to the fact that
they were measured in the laboratory, rather than the field. Field sampling of .pH should help
verify this assumption.
Sample Collection Procedures
Every attempt will be made to sample the three storm drains and the sample upgradient of
Outfall Al/Outfall A2 within the first 30 minutes of discharge. The stream locations will be
sampled as soon as possible during the storm event.
Quality Assurance/Quality Control
Golder Associates NC, Inc. (Golder) will conduct the field sampling and Environmental
Conservation Laboratories, Inc. (ENCO) will perform the required analytical services. Golder
has the required NC Laboratory Certification for measurement of field pH, and ENCO has all
pertinent certifications for the required analyses.

Schedule
The Commission will collect samples from the sediment basins associated with Outfall B and
Outfall 2 as soon as possible (and not during a rain event). The Commission will attempt to
collect all other stormwater samples as soon as a qualifying event occurs during hours that a
certified laboratory can receive samples, and as soon as possible so that sampling can hopefully
be completed prior to the second semi-annual compliance event for 2008.
Other Action Items
The Commission will evaluate the existing Erosion and Sediment Control Plan and stormwater
features at the facility and evaluate specific structural Best Management Practice (BMP)
improvements that may help reduce concentrations for parameters of concern. The Commission
is also requesting that the DWQ consider eliminating some of the outfalls for future sampling
events, based on the fact that several outfalls are associated with the closed landfill and do not
receive stormwater from areas with pertinent industrial activities. These outfalls are: Outfall B,
Outfall C, Outfall D, and Outfall E. We request that the DWQ advise us on how to proceed with
removing these outfalls from the sampling program for future events.
Closing
If you have any questions or require any additional information, please contact me. If you have
an_v suggestions or recommendations to this Work Plan, please let us know soon, as we plan to
proceed as soon as possible. We appreciate your assistance with this project.
Sincerely,
Edward Gibson, P.E.
Solid Waste Engineer
C: Rose Pruitt, North Carolina Department of Environment and Natural Resources
Division of Water Quality, Winston-Salem Regional Office, 585 Waughtown Street, Winston-
Salem, North Carolina 27107
Keith Huff, Stormwater Division Director, City of Winston-Salem, Suite 232, City Hall,
101 N. Main Street, Winston-Salem, NC, 27101
Ron DiFrancesco, Golder Associates Inc., 3719 Saunders Avenue, Richmond, Virginia, 23227,
[e-mail]
Rachel P. Kirkman, P.G., Golder Associates NC, Inc., 4900 Koger Boulevard, Suite 140,
Greensboro, NC, 27047, [e-mail]

RE: General ;-.unit NCG120000 coverage
. r,.
Subject: RE: General Permit NCG 120000 coverage
From: "Kirkman, Rachel" <[e-mail]>
Date: Fri, 15 Aug 2008 09:58:45 -0400
To: "Bradley Bennett" <[e-mail]>
CC: "Rose Pruitt" <[e-mail]>, "Bethany Georgoulias"
<[e-mail]>, "Ken Pickle" <[e-mail]>
Good morning Mr. Bennett.
I appreciate the information and your timely response. You mentioned LCID (Land Clearing Inert Debris)
landfills; but not C&D (Construction and Demolition) landfills. My question was really if NCG 120000 covered
C&D landfills once operational (post -construction). Please clarity if you can and feel free to call if you need
further explanation or information.
Thanks again for your help.
Rachel
From: Bradley Bennett[mailto:[e-mail]]
Sent: Friday, August 15, 2008 9:37 AM
To: Kirkman, Rachel
Cc: Rose Pruitt; Bethany Georgoulias; Ken Pickle
Subject: Re: General Permit NCG120000 coverage
Ms. Kirkman,
As we discussed yesterday, for typical LCID landfills we have not required coverage under our NPDES
Stormwater Permit (NCG120000). However, in addition to Solid Waste permits for these facilities,
most will also be covered by erosion and sedimentation control plans. Any facility disturbing an acre or
more of land (subject to erosion and sedimentation control plan approval) also receives coverage under
our NPDES Construction Stormwater permit (NCG010000). So, these facilities will still end up with
this NPDES stormwater permit coverage.
The largest fraction of those facilities required to have a stormwater NPDES landfill permit are
identified in 40CFR 122.26(b)(14). In addition, the NPDES regulations do allow the Division to
designate a stormwater point source discharge under the NPDES program where water quality impacts
are occurring, or have the potential to occur.
So, while the NCG120000 permit coverage may not automatically be applicable to these facilities, other
permit measures may apply.
I hope this answers your questions.
::
Kirkman, Rachel wrote:
Good afternoon Mr. Bennett.
Please clarify whether or not construction and demolition landfill facilities require general permit
1 of 2 8/18/2008 11:26 AM

RE: Genera l.?etmit NCG 120000 coverage
coverage under NCG120000, revised November 1, 2007. If a facility accepts only construction and
demolition waste (and not industrial) and there are no other applicable SIC's requiring general
stormwater permit coverage, it is our understanding that these facilities do not require permit coverage.
Please call if you need further clarification. 1 appreciate your assistance.
Rachel
Rachel Kirkman (P.G.) I Senior Project Geologist I Golder Associates NC, Inc.
The Wingate Building, 4900 Koger Boulevard, Suite 140, Greensboro, North Carolina, USA 27407-2710
T: [phone] D: [phone] F: [phone] C: [phone] E:
Rachel Kirkman(cD_golder.com I www.golder.com
This email transmission is confidential and may contain proprietary information for the exclusive use of the intended recipient. Any use, distribution or
copying of this transmission, other than by the intended recipient, is strictly prohibited, if you are not the intended recipient, please notify the sender and
delete all copies. Electronic media is susceptible to unauthorized modification, deterioration, and incompatibility. Accordingly, the electronic media
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Please consider the environment before printing this email.
2 of 2 8/18/2008 11:26 AM

Mail Only, No Insurance Coverage
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crt Winston-Salem, NC 27102

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AUG 2 0 20
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Regional
Office

Michael F. Easley, Governor
William G. Ross Sr., Secretary
North Carolina Department of Environment and Natural Resources
y
August 13, 2008
CERTIFIED MAIL 7008 0.150 0002 8342 1498
RETURN RECEIPT REQUESTED
City of Winston Salem
Edward Gibson
PO Box 2511
Winston Salem, NC 27102
Coleen H. Sullins, Director
Division of Water Quality
SUBJECT: Compliance Evaluation Inspection
City of Winston Salem- Hanes Mill Rd Sanitary Landfill
Permit No: NCG120034
Forsyth County
Dear Mr. Gibson:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection
conducted on August 6, 2008. The Compliance Evaluation Inspection was conducted by Rose
Pruitt of the Winston-Salem Regional Office. Ed Gibson, Adam Rickett and Raleigh Scales all
with the City of Winston Salem were present for the inspection. The inspection consisted of two
parts: an on -site inspection of the treatment facility and a file review. The following are the
findings from the subject inspection.
The facility was found to be in Compliance with permit NCG120034.
I. Permit
The Certificate of Coverage NCGO120034 for the Hanes Mill Rd Sanitary Landfill facility became
effective November 1, 2007 and expires on October 31, 2012. The permitted facility is authorized
to discharge stormwater from a facility located at 325 Hanes Mill Rd in Winston Salem, North
Carolina in accordance with the effluent limitations, monitoring requirements, and other conditions
set forth in General Permit No. NCG120034.
The permittee is authorized to discharge stormwater to the surface waters of North Carolina or
separate storm sewer system which has been adequately treated and managed in accordance with
the terms and conditions of this general permit. All discharges shall be in accordance with the
conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization or approval.
The permit identifies the three monitoring requirements that apply to this facility:
Analytical Monitoring for Stormwater Discharge Outfalls per Part II, Section B.
Qualitative Monitoring for Stormwater Discharge Outfalls per Part II, Section B.
Analytical Monitoring for On Site Vehicle Maintenance per Part 11, Section B.
Copies of the NCG120000 general permit documents can be accessed from the following web
page: htt_pa/h2o.enr.state.nc.us/su/Forms_ Doc urnents.htm#StormwaterGP VAT
N76
585 Waughtown Street Winston-Salem, NC 27107 Phone [phone] Fax [phone]

City of Winston Salem
Page 2
August 13, 2008
II. Records/Reports
The following records are required at this site per the NPDES permit:
An approved Sedimentation and Erosion Control Plan as specified per Part II, Section A.
Stormwater-Discharge Outfalls (SDO) shall have analytical monitoring performed as described in
Part II, Section B, and Tables 1 and 2.
Stormwater Discharge Outfalls (SDO) shall have qualitative monitoring performed as described in
Part II, Section C, and Table 4.
Stormwater Discharge Outfalls (SDO) shall be inspected and analytical monitoring for On Site
Vehicle Maintenance Areas performed as required in Part II, Section D and Tables 5 & 6.
A review of the available records and reports for the RMC Carolina Materials Inc. facility for the
period 2006 through July 2008 revealed that the facility had completed Analytical and Qualitative
Monitoring requirements for that period. The approved Sedimentation and Erosion Control Plan
was available for review.
Thant: you for your compliance.
III. Facilitv Site Review
At the.time of the inspection the facility appeared to be operating efficiently and was well
maintained. The facility was composed of both a closed and an active site.
The facility site review indicated that thirteen stormwater outfalls had been mapped, and were
being monitored. The sediment and erosion control basins at this site are designed to meet 25 year
storm flows. Access to all outfalls was maintained.
IV. Effluent 1 Receiving Stream
The facility stormwater discharges to receiving waters designated as Grassy Creek, a class C
stream in the Yadkin River Basin. On the date of the inspection the receiving stream was clear and
free of sediment or debris.
V. Flow Measurement
Not evaluated during this inspection.
VI. Self -Monitoring Program
Analytical monitoring was performed as described in Part II, Section B, and Tables 1 and 2.
Results included monitoring at outfalls during storm events that exceeded design capacity. During
those storm events there was some exceedance of cut off limits.
The qualitative monitoring as required in Part 11, Section C, and Table 4 was recorded on a semi-
annual basis as required by the permit.

f . City of Winston Salem
'Page 3
August 13, 2008
Analytical monitoring for On Site Vehicle Maintenance Areas was performed as required in Part
II, Section D and Tables 5 R b.
VII. Compliance Schedules
No compliance schedules to evaluate.
VIIL Laboratory
The contract laboratory was not reviewed at the time of the subject inspection.
IX. Operation and Maintenance
Part III, Section C (1) regulates for the Proper Operation and Maintenance of the facility: The
permittee shall at all times properly operate and maintain all facilities and systems of treatment and
control (and related appurtenances) which are installed or used by the permittee to achieve
compliance with the conditions of this general permit.
There are thirteen (13) stormwater discharge outfalls for this facility. Access to all outfalls is
maintained. The facility appeared to be well maintained at the time of the inspection.
X. Siud2e Utilization/Disposal
Not evaluated during this inspection.
XI. Pretreatment
Not evaluated during this inspection.
XII. Stormwater
Minimal stormwater impact to surface waters was observed during the inspection.
XIV. Se-,ver Overflow
None to report.
XV. Pollution Prevention
This facility is required to have an approved erosion and sedimentation plan on site which was
available during the inspection.
XVI. Multimedia
Not evaluated during this inspection.

City of Winston Salem
Page 4
August 13, 2008
f
This Office congratulates you for having met your permit conditions and monitoring
requirements. Your continued oversight in this area is very important.
Please refer to the enclosed inspection report for additional observations and comments. If you or
your staff have any questions, please call Rose Pruitt at 336-771-5000.
Sincerely,
Steve W. Tedder
Water Quality Regional Supervisor
Winston-Salern Regional Office
Division of Water Quality
Attachment
cc: Central Files w/ attachment
WSRO w/ attachment

Compliance Inspection Report
Permit: NCG120034
SOC:
County: Forsyth
Region: Winston-Salem
Effective: 11/01/07 Expiration: 10/31/12 Owner: City of Winston-Salem
Effective: Expiration: Facility: Winston Salem - Hanes Mill Rd Sanitary
Landfill
325 Hanes Mill Rd
Contact Person: Edward Gibson Title:
Directions to Facility:
On U.S. Highway 52 between Hanes Mill Road and Ziglar Road.
System Classifications:
Primary ORC: Certification:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/06/2008 Entry Time: 08:30 AM
Primary Inspector: Rose Pruitt
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Landfill Stormwater Discharge COC
Facility Status: ® Compliant fl Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Winston Salem NC 27105
Phone: [phone]
Exit Time: 12:00 PM
Phone:
Phone: [phone]
Inspection Type: Compliance Evaluation
11
Page: 1

Permit: NGG120034 Owner - Facility: City of Winston-Salem
Inspection Date: 08/06/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspector was met at the facility by Ed Gibson, Adam rickett and raleigh Scales all with the City of Winston Salem. During
the inspection it was noted that usually only 3-5 of 13 basins discharge during large storm events. Basins may be
designed for 25 yr rainfall, Significant bird and wildlife populations are present at this site and may be major contributors
to high fecal coliform counts. The site appeared well maintained at the time of the inspection.
Monitoring results for fecal coliform and some suspended solids were noted to exceed cutoff limits. in discussion with
central office and Ed Gibson about possible causes and additional information now.
Page: 2

r • ..t
i•,
Permit: NCG120034 Owner - Facility: City of Winston-Salem
Inspection Date: 08/06/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
D
D
®
D
# Does the Plan include a General Location (USGS) map?
D
D
®
D
# Does the Plan include a "Narrative Description of Practices"?
D
D
®
D
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
D
D
D
# Does the Plan include a list of significant spills occurring during the past 3 years?
D
D
®
D
# Has the facility evaluated feasible alternatives to current practices?
D
D
®
D
# Does the facility provide all necessary secondary containment?
■
D
D
D
# Does the Plan include a BMP summary?
®
D
D
D
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
D
D
®
D
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
D
D
®
D
# Does the facility provide and document Employee Training?
D
D
®
D
# Does the Plan include a list of Responsible Party(s)?
D
D
®
D
# is the Plan reviewed and updated annually?
E)
D
®
D
# Does the Plan include a Stormwater Facility Inspection Program?
D
D
®
D
Has the Stormwater Pollution Prevention Plan been implemented?
D
D
®
D
Comment: Stormwater BMP plan provided, approved S&B plan
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
o
D
D
D
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
■
D
D
D
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
■
D
D
D
Comment:
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
®
D
D
D
# Were all outfalls observed during the inspection?
®
D
D
D
# If the facility has representative outfall status, is it properly documented by the Division?
D
D
®
D
# Has the facility evaluated all illicit (non stormwater) discharges?
D
D
®
D
Comment:
Page: 3

Aug 6, 2008 001
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Aug 6. 2008 037

CcWinston-Salem • Forsyth County
Utilities
ater • Sewer • Solid Waste Disposal
Hanes Mill Road Landfill • 325 W. Hanes Mill Road • Winton -Salem, NC 27105 • Tel [phone] • Fax [phone]
August 4, 2008
Ms. Rose Pruitt
Environmental Specialist
North Carolina Dept of Environment and Natural Resources
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Re: Hanes Mill Road Landfill NPDES Stormwater Permit dated November 1, 2007; COC
Number NCG 120034
Dear Ms Pruitt,
Referenced the above, enclosed please find the following:
• Copies of all Qualitative Monitoring Reports for all 13 discharge points
• Site map showing the locations of the discharge points
Letter to Mr. Mike Randall of the DWQ dated July 3, 2008 regarding the status of the first
semi-annual monitoring event for this Permit. For your information, samples were taken
from 5 discharge locations (the other points were not discharging) on July 31, 2208, and the
water is presently being analyzed by R&A Laboratories. We expect the results shortly.
You also requested a copy of the SWPP for this facility. As I understand the NPDES Stormwater
permit for landfills, a SWPP is not required. See enclosed copy ofthe Permit cover letter.
See you Wednesday morning at 8:30 AM. If you have any questions please do not hesitate to call
me at 399- 5051.
Sincerely
,
Edward Gibson, P.E.
Solid Waste Engineering Supervisor

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Analyses Performed by TJ -YJ -IA -SJ
Lab Sample Number
-----------------
623311
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Parameter Storet # Results
COD -HIGH (00340). 39.0 mg/1
TSS (00530) =M9/.,
Fec Coli-MF (31616--) _8,000 cal/100 MI.
Clients Sample Source
Number
Time Collected Mrs)
OUTFALL B.
1534
P.O. Box 473 • 106 Short Street,* Kernersville; North Carolina 27264 • 336-995-2841 • Fax 336=996-0326
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101 N. Main Street
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07/31/08
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Date of Report
08/05/08
Analyses Performed by
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Lab Sample Number
--------------------
623312
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Parameter Storet # Results
COD -HIGH (00340)
6.00 mg/1
TSS (00530)
8.8 mg/l OK
Fec Coli-MF (31616)
/100 ml
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Clients Sample Source OiJiFALL F
Number
Time Collected (Hrs) 1546
P.O, Box 473 - 106 Short Street Kernersville. North Carolina 27284. 336-996-2841 • Fax'336-996-0326
www.randalabs.com

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City of Winston-Salem Date Sample Collected 07/31/08
101 N. Main Street Date'Sample Received 07/31/08
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Attn: John Spainhour Date,of Report 08/05/08
Analyses Performed by TJ -YJ -IA -SJ
Lab Sample Number
--------------------
623313
.-.=s=aa==s¢aa�cvca.-ca=ac.=aaaa=acascW=ccaaxcsa=a=ac=====_===-�aG=e=cacsac=a.a=mac
Parameter Strret # Results
COD -HIGH (00340) 11.0 mg/1 OK
TSS (00530) 283 mg/l.
Fec Coli-MF (31616) 5,000 col/100 ml
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P.O. Box 473. 106 Short Street- Kerners%,ille. North Carolina 272B4 - 336-996-2841 • Fax [phone]
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Date Sample Analyzed
07/31/08
Attn: John Spainhour
Date of Report
08/05/08
Analyses Performed by
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Lab Sample Number
---------------------
623309
Parameter Storet #
Results
pH (00400)
5.90 Std.' Units
TSS (00530)
90.0 mg/1 OK
Oil & Grease (00556)
<5.0 mg/l OAC
Fec Coli-MF (31616)
9,200 col/100 ml
Clients Sample Source
Number
Time Collected (Hrs)
VEHICLE MAINTENANCE
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1454
P.O. Box 473 • 106 Short Street • Kernersville, North Caraline.272B4 • 336-996-2841 • Fax [phone]
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City of Winston-Salem
Date Sample Collected
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101 N. Main Street
Date"Sample Received
07/31/08
Winston-Salem, NC 27101
Date Sample Analyzed
:.07/31/08-
Attn: John Spainhour
Date of Report
08/05/08
Analyses Performed by
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Lab'Sample Number
--------------------
623310
aaa=accccacaaac=sx sssaaccca==ua=cscaaaaaaaaaccaaa=aaaaaa==caaacaaaaccsaa====aac==
Parameter Storet # Results
PH (00400)
5.83 Std. Units
TSS (00530)
121 mg 1
Oil &•Grease (00556)
6.4 mg/1 Q"
Fec Coli-MF (31616)
11,400 col/100 ml
-----------------
Clients Sample Source VEHICLE MAINTENANCE
Number OUT A2
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Time Collected (Hrs) 1511
P.O. Box 473 • 106 Short Straet • Kernersville, Nortti.Carolina 27264 • 336-996-284.1 - Fax [phone]
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Forsyth County
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t4Winston-Salem
County Utilities13
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ater • Sewer • Solid Waste Disposal
W,nsion•seiam
ReBlvnal Q4ftce
Flans Mill Road Landfill • 325 W. Hanes Mill Rvad • Winston-Salem, NC 27105 • Tel [phone] • Faz 336.661.4905
July 3, 2008
Mr. Mike Randall
North Carolina Dept of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: NPDES Stormwater Semi -Annual Monitoring Requirement Action Plan for
Hanes Mill Road Landfill. (Certificate of Coverage No NCG 120034)
Dear Mr. Randall,
Per your request, I am waiting to explain the issues surrounding the analytical monitoring
requirements for the Hanes Mill Road Landfill and the City -County Utilities Solid Waste
Administration's action plan to collect, analyze, and submit the required analytical
monitoring parameters stated in the permit.
The City/County Utilities Solid Waste Administration operates a Municipal Solid Waste
Landfill (aka a "Subtitle D" landfill) located on 325 Hanes Mill Road. This landfill
received a renewed certificate of coverage (No NCG 120034) effective November 1,
2207. With this new permit, analytical monitoring requirements were changed to a semi-
annual basis with the first monitoring period to be conducted within the time frame of
January1, 2008 thru June 30, 2008. This monitoring is to be conducted during a
representative storm event which measures 0.1 inches of rainfall and is preceded by at
least 72 hours in which no storm event measuring greater than 0.1 inches has occurred.
The City/County Utilities Solid Waste Administration has been'and is currently working
with the City of Winston-Salem's Stormwater Division to conduct analytical sampling
for the January 1, 2008 to June 30, 2008 monitoring period. However, to date we have
not been able to obtain analytical samples for the first period due to several factors:
The Piedmont region of the state is still under drought conditions and we have
received few representative rainfall events and the representative storm events
that have occurred have been outside of normal business hours.

Mr. Mike Randall
July 3, 2008
Page 2
• The few representative events which have occurred under normal business hours
have come in the form of short term high intensity scattered thunder storms which
allow little time for mobilization.
• Although the City/County Utilities Solid Waste Administration staff authorized
overtime for City Stormwater Staff to collect analytical monitoring samples, the
certified laboratory is not open to receive collected samples during holidays,
weekends and late evenings, so std'needs to coordinate sample collections with
laboratory hours of operation as to not violate holding times of sample
parameters.
The above notwithstanding, the City/County Utilities Solid Waste Administration
remains committed to collecting the required analytical samples and submitting reports to
DENR when a representative storm event occurs. To ensure that this occurs as soon as
possible, the City's Stormwater Division is discussing options with their certified
laboratory to allow acceptance of samples collected outside of normal business hours in
order to expedite the process.
If you have any questions or need additional information please contact me at (336) 399-
5051.
Sincerely,
I
Edward L. Gibson, P.E.
City/County Utilities Solid Waste Administration
cc: Steve Tedder (Division of Water Quality/Winston-Salem Regional Office)
Keith Huff (City of Winston-Salem Stormwater Division)
Jan McHargue
Adam Rickett

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"OFW A
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y
Michael F. Easley
Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
July 31, 2003
Edward Gibson
City of Winston-Salem
PO Box 251.1
Winston Salem, NC 27102
Subject: NPDES COC # NCG 120034
Winston Salem - Hanes Mill Rd Sanitary Landfill
Compliance Schedule Correction
Forsyth
Dear Edward Gibson:
It recently came to the Division's attention that the compliance schedule in the NCG120000 permit is
incorrect. The compliance refers to requiring a Stormwater Pollution Prevention Plan which is not a
requirement of this permit. The corrected compliance language that should go under Part III, Section A: 1. is
shown below. We have also attached a new page reflecting this change for your permit file (Part III page I of
11). This new page should replace the current page in your permit.
SECTION A: COMPLIANCE AND LIABILITY
Compliance Schedule
The permittee shall comply with the permit in accordance with the following schedule:
Existing Facilities: Upon the effective date of the Certificate of Coverage the permittee shall comply
with all of the conditions detailed in Part II, Section A: Final Limitations and Controls for Stormwater
Discharges.
New Facilities: Upon the beginning of discharges from the operation of the industrial activity the
permittee shall comply with all conditions detailed in Part II, Section A: Final Limitations and Controls
for Stormwater Discharges.
If you have any questions concerning this matter please contact Aisha Lau at
[phone], ext. 578.
cc: Stormwater and General Permits Unit
Winston-Salem Regional Office
Central Files
ern _
NCDENR
Customer Service
1 800 623-7748
Sincerely,
C)RIGINAL �1GiVFD t�Y
tf=v
Alan W. khridk, T7
Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]

\NArc9Q Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
C!J
Alan W. Klimek, P.E., Director
"I Division of Water Quality
f3 'C
August 23, 2002
EDWARD GIBSON .
WINSTON SALEM - HANES MILL RD SANITARY LANDFILL
PO BOX 2511
WINSTON SALEM, NC 27102
Subject: NPDES Stormwater Permit Renewal
WINSTON SALEM - HANES MILL RD SANITARY
LANDFILL
COC Number NCG120034
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG 120000, the Division of
Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983.
The following information is included with your permit package:
* A new Certificate of Coverage
* A copy of General Stormwater Permit NCG 120000
* A copy of the Analytical Monitoring Form (DMR)
* A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility
for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
If you have any questions regarding this permit package please contact Aisha Lau of the Central Office Stormwater
and General Permits Unit at [phone], ext. 578
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Winston-Salem Regional Office
eo'A
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1-800-623-7748

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
IrDWARD GIBSON
WINSTON SALEM CITY OF
PO BOX 2511
WINSTON SAL1 N1, NC 27102
Dear Pcrmittee:
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
December 27, 2001
Subject: NUDES Stormwater Permit Renewal
WINSTON SALEN9 CITY OF
COC Number NCG 120034
Forsvili County
Your facility is currently covered for storrnwater discharge under General Permit NCG 120000. This permit expires
on August 31, 2002. The Division staff is currently in the process of rewriting this pernut and is scheduled to have
the permit reissued by late summer of 20{ 2. Once the permit is reissued, your facility would he cli,,ihlc for
continued coverage under the reissued permit.
In order to assure your continued covera c under the general permit, you rust apply to the Division of Water
t )uality (DWQ) for renewal of your permit cover.12C. To make this renewal process easier. we are intormin'-- you in
advance that your permit will he expirin-. 13nclased you will find a General Permit Coverage Renewal
Application Norm, The applic.nion must he completed :Ind returned by March 4, 2002 in order io assure continued
covera-e under the «eneral perrnit.
Failure to request renewal within this tine period Ina), result in a civil assessment of at least S250.00. Langer
penalties May he; assessed depending on the delinquency of the request. Discharge ol'stormwater from your facility
without Covcra�,e under a valid storrnwaler NPDES perrnit would Conslftute a violation of NCGS 143-215.1 and
could result in assessments op'Civil penalties of up to S 10.000 per day.
Please note that recent federal legislation has extended the "no exposure exclusion" to all operators of industrial
facilities in any of the 1 1 cate"ories of "storm water discharges associalecl with industrial activity," (excepl
construction activities). [f you feel your facility can cCrtify a condition III' "no exposure". i.e. 111C facilty industrial
materials and operations are not exposed to storrnwater. you can apply for the no exposure c.rclusiort. For addilional
irlfnrnlation contact the Central Off ice Stormwater Slal'I' member listed below or check the Stornnwater &, General
Permits Unit Weh Site at ltttpa/h2o.caraatC.nc.us/sul�tormwater.html
II- the subject storrnwater clischarge to waters of the state has heen ternlinatccl, please complete the enclosed
Rescission Request Form. Mailing instructions are listed on the bottom of the form. You will he notified when the
rescission process has been completed.
f you have ally questions rc�sarding the permit renewal procCom-es please contact Corcy Basin-cr nl' the
Winston-Salem Rcuional Office at >36-771-46{)U or Aisha L.ru of the Central Office Stormwater Unit at (919)
73 ;-5053. ext. 578
Sincerely.
h '
Bradley Bennett, Supervisor
Stormwater and General Permits Unfl
cc: Central Files
Winston-Salem RgIional Office
e�a
NCDENR
N. C. Division of Water Quality 1617 {Nail Service Center Raleigh, NC 27699-1647 [phone] Customer Service
1-800-623-7748

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Sweet • Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
April 30, 1993
Daniel D. Miles
City of Winston-Salem
P O Box 2511
Winston-Salem, NC 27102
A. Preston Howard, Jr., P. E.
Director
Subject: General Permit No. NCG120000
Hanes Mill Road_Sanitary Landfill
COC NCG 120034
Forsyth County
Dear Mr. Miles:
In accordance with your application for discharge permit received on September 22, 1992, we are
forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general
permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated
December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit
application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the Division
of Environmental Management. The Division of Environmental Management may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area
Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Mr. Steve Ulmer at telephone number 9191733-
5083.
cc
Sincerely,
original Signed BY
Coleen H. Sullins
A. Preston Howard, Jr., P.E.
Winston-Salem Regional Office
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

STATE OF NORT I'CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
' ►! , I I II
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELLN INATIQN SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
City of Winston-Salem
is hereby authorized to discharge stormwater from a facility located at
Hanes Mill Road Sanitary Landfill
325 Hanes Mill Road
Winston-Salem
Forsyth County
to receiving waters designated as Grassy Creek in the Yadkin -Pee Dee River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, Ill
and IV of General Permit No. NCG 120000 as attached.
This certificate of coverage shall become effective April 30, 1993.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
r
Signed this day April 30, 1993.
ongina� H.SoYms
C1alee
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

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