NCG240012_COMPLETE FILE - HISTORICAL_20160801

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/v C& o%y OD
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ ��I � J ��
YYYYMMDD

Division of Energy, Mineral and Land Resources
iA
�� Land Quality Section / Stormwater Permitting Program
A
NCDENR National Pollutant Discharge Elimination System (NPDES)
i ihl CA7O A EPAfi DT- OF
PERMIT OWNER AFFILIATION DESIGNATION FORM
(Individual Legally Responsible for Permit)
Use this form if there has been:
rOR AGENCY USE ONLY
Date Received
Year
Rtomh
Da
NO CHANGE in facility ownership or facility name, but the individual
who is legally responsible for the permit has changed.
If the name of the facility has changed, or if the ownership of the facility has changed,
do NOT use this form. Instead, you must fill out a Name -Ownership Change Form
and submit the completed form with all required documentation.
What does "legally responsible individual" mean? RECEIVED GD .
The person is either: �U�IS ��
• the responsible corporate officer (for a corporation);
• the principle executive officer or ranking elected official (for a municipality, state. E ederal t� cath&pl�lic
agency); 3�E4�r�7��#� Ll
R#��11TTiNQ
• the general partner or proprietor (for a partnership or sole proprietorship),
• or, the duly authorized representative of one of the above.
1) Enter the permit number for which this change in Legally Responsible Individual ("Owner Affiliation")
applies:
Indi�idual Permit
N- S 1 2 4 0 0 1 2
2) Facility Information:
Facility name:
Company/Owner Organization
Facility address:
(01) Certificate of Coverage
N I C I Gjgj�kjoQ
Yard Waste Center
City of Raleigh
900 New Hope Road
Address
Raleigh NC 27602
City State Zip
To find the current legally responsible person associated with your permit, go to this website:
htt :11 ortal.nedenr.or webllr/sw- ermit-contacts and run the Permit Contact Summary Report.
3) OLD OWNER AFFILIATION that should be removed:
Previous legally responsible individual: Russell J Allen
First N11 last
4) NEW OWNER AFFILIATION (legally responsible for the permit):
Person legally responsible for this permit:
Ruffin L. Hall
First h11 Last
Page t of 2
SW U-OWNERAFF I L-25July2014

N
NPDES Stormwater Permit OWNER AFFILATION DESIGNATION Form
(if no Facility Name/Ownership Change)
City Manager
Title L ' S
nn n uL con
Mailing Address
Raleigh NC 27602
City State Zip
[phone] [e-mail]
Telephone E-mail Address
Fax Number
5) Reason for this change:
© Employee or management change
A result of: ❑ Inappropriate or incorrect designation before
?< ❑ Other
If other please explaitr.
The certification below must be completed and signed by the permit holder.
PERMITTEE CERTIFICATION:
I, Ruffin ,Hall attest that this application for this change in Owner Affiliation
(person legally re'spotisible-for the permit) has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this form are not completed, this change may not be
processed.
;�7- 4-11:e� —
Signature 6ate
PLEASE SEND THE COMPLETED FORM TO:
Division of Energy, Mineral and Land Resources
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
For more information or staff contacts, please call 919-707-9220 or visit the website at:
http:llportal ncdenr.or,Wweb/ir/stormwater
Page 2 of 2
SW U-OWNERAFFI L-2Uuly2014

f
PLEASE PRINT CLEARLY OR TYPE
STATE OF NORTH CAROLINA IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
COUNTY OF WAKE
CITY OF RALEIGH
117
)
PETITION
FOR A
+ + :. ,,,+.'+ i(- �,D CONTESTED CASE HEARING
NORTH CAROLINA DIVISION OF WATER QUALITY; COLEEN )
SULLINS. DIRECTOR OF THE DIVISION OF WATER QUALITY;
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
PETITIONER,
V.
RESPONDENTS.
I hereby ask for a contested case hearing as provided for by North Carolina General Statute § 15OB-23 because the Respondent
Coleen Sullins, in her capacity as Director of the Division of Water Quality, issued General Permit NCO240000, National Discharge Elimination
System Permit, on September 21. 2011 in violation of law and the protections afforded to the City of Raleigh on behalf of the Respondents Divison
of Water Quality and the NC Department of Environment and Natural Resources. General Permit NCG240000 applies to certain compost facilities,
including a facility operated by the City of Raleigh. The DWQ Director's authority to issue General Permits is established by t5A NCAC 2H .0127.
(Continued on Attached pages 2 and 3)
Because of these facts, the State agency or board has: (check at least one from each column)
deprived me of property; _x____cxceeded its authority or jurisdiction; Q®
ordered me to pay a fine or civil penalty; or x_acted erroneously; d
_x_otherwise substantially prejudiced my rights; AND _x_failed to use proper procedure; z
_x acted arbitrarily or capriciously;orz®
_x—failed to act as required by law or rule
Date: November 14, 2011
Print your full address: P.O. Box 590 Raleigh, NC 27602
Print your name: Daniel F. McLawhorn
i
Your signature:
Your phone number. [phone]
You muit mail or deliver a COPY of this Petition to the State agency or board named on line (3) of this form. You should contact the agency or
board to determine the name of the person to be served.
CERTIFICATE OF SERVICE
I certify that this Petition has been served on the State agency or board named below by depositing n copy of it with the United States Postal Service
with sufficient postage affixed OR by delivering it to the named agency or board:
Mary Penny Thompson, General Counsel, North Carolina Department of Environment and Natural Resources
1601 Mail Service Center, Raleigh, N,C. 27600-1601
`!'his the 14th da �,embv,20111
(your signature)
When you have completed this form, you MUST mail or delivvr the ORIGINAL AND ONE COPY to the Office of Administrative Hearings, 6714
Mail Service Center, Raleigh, NC 27699-6714.

2
Director Sullins was also limited in her authority by Section 7 of Session Law 2011-394, which
modified and limited the power previously established in N.C. Gen. Stat. § 143-214.7A(b). Director
Sullins and the Department of Environment and Natural Resources (hereinafter "DENR") exceeded its
statutory authority when it required a water quality permit for Type 1 solid waste compost facilities as
DENR was not requir� eec "to impose the permit requirement by federal law.
r1\I6e� 24d 606 ;
Director Sullins, DWQ, and DENR acted erroneously, failed to use proper procedure and failed to act as
required by law and rule when it issued NPDES General Permit NC24000. The enabling legislation
authorized DENR, inter alia, to establish revised water quality permitting procedures for the composting
industry. Director Sullins, DWQ, and DENR attempt, unlawfully to establish standards regulating the
composting industry and otherwise comply with the requirements set forth in N.C. Gen. Stat. § 143-
214.7A through the General Permit, its accompanying Fact Sheet, and response to Comments in
violation of Article 2 of Chapter 150B of the N.C. General Statutes. The standards and other provisions
set forth by Director Sullins, DWQ, and DENR in the General Permit and Fact Sheet are standards or
statement of general applicability that implement an enactment of the General Assembly. Accordingly,
the standards and other provisions set forth by Director Sullins, DWQ, and DENR in the General Permit
and Fact Sheet are void and unenforceable unless established as rules in compliance with the procedures
set forth in the Administrative Procedure Act
? Director Collins, DWQ, and D�NR acted arbitrarily and capriciously in the adoption and issuance of
NPDES General Permit NC24000 and its accompanying Fact Sheet when it adopted a policy of a strong
(a) preference to exclude from eligibility for coverage all facilities loca0ain basins subject to special water
quality management strategies established in 15A NCAC 2B .0200. This limitation excludes, or NO r so
severely limits, so much of the State for General Permit coverage that the General Permit violates 15A r
NCAC 2H .0127. Raleigh is located entirely in the Neuse River Basin, a basin regulated to reduce the
impact of nitrogen loading on the Neuse Estuary, a part of the Neuse River more than 100 miles from
Raleigh. The receiving stream for the discharges from Raleigh's compost facility is not listed as
impaired on the 303(d) list for nitrogen and it has not been determined to be in violation of nitrogen
loadinglimits. The detei�rnination that Raleigh should bear the additional costs and burdens associated �'AOr
g ,4 0v171 o #4,
with an individual permit application is arbitrary and capricious and in excess of the statutory authority c o-sfs 2
of Director Sullins, DWQ and DENR.
a E T-{,C'MitlgTiv
Director Collins, DWQ, and DENR acted arbitrarily and capriciously, failed to use proper procedure,
® and exceeded its authority when in the Fact Sheet and Response to Comments for NPDES General
Permit NC240000, they adopted a policy regarding mulching operations that are co -located at
composting facilities without defining co -located. Raleigh's composting facility is on the same parcel of
land as its mulching operations and the parcel of land has a streambed, or hydraulic divide, that can be
used to separate the two operations and keep the stormwater and wastewater separated. The policy
? adopted by Director Collins, DWQ, and DENR is a rule, as that termed is defined by the Administrative
Procedure Act, and was not adopted using APA procedures for rulemaking. Finally, the policy is
arbitrary and capricious as com=ownership of thetwo facilities does not establish a water quality
protection basis for the policy.t M /'+ O n in�GST tes % C�Gli✓ �'S / aL� ts.a i
DWQ and DENR previously identified the City of Raleigh as a municipality with a Type 1 Composting
facility which would be included in the scope of the General Permit's coverage. The City of Raleigh has
not been served, pursuant to N.C. Gen. Stat. § 143-215.1(c), with the decision by DWQ regarding the
General Permit nor has it been served pursuant to N.C. Gen. Stat. § 150B-23(f) with notice of its rights
to bring a contested case to challenge the General Permit by Director Sullins, DWQ or DENR. The first ! n�
-2-
r-a.lFi

notice to any representative of the City came in an email sent on October 11, 2011 to the undersigned
by Ken Pickle, Environmental Engineer, DWQ. This Contested Case Petition is timely filed.
-3-

4
Amount Paid S
t] Cash — receipt number
❑ Money Order ❑ CenifiedCheck ❑ Attorney Trust Account
Check number
t nts Box for VA use oniv.
-4-
Ll Indigent (must complete form HOI )
€1 Mandated federal cause of action
Received by:

4 0�
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Energy, Mineral, and Land Resources
Land Quality Section
Tracy E. Davis, PE, CPM
Director
November 4, 2013
Mr. Mike Santowasso
Hazen and Sawyer, P.C.
4011 WestChase Blvd., Suite 500
Raleigh, NC 27616
Pat McCrory, Governor
John E. Skvarla,111, Secretary
Subject: NPDES Stormwater Permit COC *NCG240012
Raleigh Yardwaste Center
Advance comments on H&S permit compliance plan
Dear Mr. Santowasso:
We appreciate the time you made available to us at the Yardwaste Center on Wednesday, October
23, 2013, Thank you for asking for our advance comments on your in -progress stormwater control
plan for the City of Raleigh Yardwaste Center. Raleigh is ultimately required to submit a finished
plan in accordance with our stormwater General Permit, NCG240000.
We have considered the elements of the stormwater control plan that have been presented to us in
several ways, so far:
• The October 23, 2013 H&S Technical Memorandum, stamped "DRAFT", and verbally
indicated to be an in -progress document, and handed to us during our site visit at the
Yardwaste Center;
• Five half-size drawings of the proposed construction at the Yardwaste Center, dated
September 2013, but not yet stamped, approved, nor issued, and also acknowledged as
still preliminary at this point; also handed to us during our site visit;
Our recollection of our verbal conversations on site on October 23, 2013, and later follow-
up conversations and emails between us;
• Your minutes of the on -site meeting, received the following day on October 24, 2013;
• In addition, we have considered the provisions of our General Permit, NCG240000 for
composting activities.
Thank you for being clear that the H&S Technical Memorandum and drawings are preliminary and
incomplete. Consequently, we view our comments here not as a DEMLR review of final documents,
but instead as a technical assistance consultation on the general direction for improved stormwater
pollution control at the site. The General Permit ultimately requires the City to present a finished
plan to the DEMLR Raleigh Regional Office (John Holley's group) for their approval. However, for
this present technical assistance consultation, I have gathered comments from John and other
NCDENR folks to respond to your request for comments. Our comments are based on what we
understand of the currently incomplete description of the plan of action for the Yardwaste Center.
Comments
1. I am able to report to you that at some point along its run, the central north -to -south
drainage feature on the site becomes a surface water of the state, and it is not a ditch.
Danny Smith has shown me both a USGS topo map, and an SCS Wake County soils map
1612 Mail Service Center, Raleigh, North Carolina 27699-1612 - Telephone [phone] FAX: [phone]
512 North Salisbury Street, Raleigh, North Carolina 27604 • Internet: htty:Nportal.ncdenr.orq%weblldland-qualit
y
An Equal Opportunity 1 A(finnative Action Employer- 50% Recycled 110% Post Consumer Paper

Mr. Mike Santowasso
Page 2 of 4
November 4, 2013
that indicate that the feature is a stream. The significance of this determination is that the
sampling required under NCG24 must be conducted on the stormwater discharges from the
site (for example, from the stormwater pond discharge), not from the creek itself near the
lower drive crossing.
a. Whether the creek is a zero -flow stream per the regulatory definition or not, it is still
a North Carolina surface water, and samples from it may not be used to characterize
the NPDFS stormwater discharge from the composting activity.
b. As you suggested previously, this brings up the question of how Raleigh will address
runoff from the eastern half of the site. We should talk more about that, after we
both have had a chance to consider it more closely.
2. Despite where past monitoring samples were taken, Raleigh's submittal to RRO should
provide all the water sampling data that has been accumulated on this site, and should
clarify for us where the samples were taken.
a. For example, samples of flow: leaving the composting pad; in the vegetated ditch;
entering the pond and forebay; contents of the pond; discharge from the pond;
contents of the beaver pond; and of course at the previous in -stream sampling
location. Whatever data there are, let's take a look at it together. I am not
suggesting that you now generate new sampling results, just give us what already
exists.
b. Raleigh's current obligation under NCG24 is to take quarterly samples beginning
February 1, 2013. Raleigh should switch immediately to retrieving samples from the
flow from the pond, not the creek.
c. The second paragraph on the first page of the draft Technical Memorandum
references some amount of sampling conducted prior to issuance of the Certificate of
Coverage. The ultimate submittal to RRO should include those data as well, along
with a clarification of where the samples were taken.
d. Our interest in the sampling data all goes'to the point of whether Raleigh has
characterized the polluted flow, and whether the proposed measures will likely
achieve the numerical benchmarks shown in the permit.
e. In addition to our interest in the data as related to the Raleigh Yardwaste Center, we
are interested in the data from a programmatic standpoint. The Stormwater
Permitting Program is engaged in a protracted roll -out of stormwater permitting for
the composting industry. There is wide variability in the reported pollutant
characterizations of treated and untreated discharges in the readily available
composting literature. These data from the Raleigh Yardwaste Center represent
another, closer to home, bit of information about the character of the flow from yard
waste composting sites.
3. The first paragraph of the Technical Memorandum notes that an NOI has been submitted,
but a Certificate of Coverage has not been issued. This is no longer correct. The Certificate
of Coverage was effective February 1, 2013.
4. As we discussed during the joint site visit, Raleigh's ultimate submittal should include more
specific information on a schedule for Phase 1 and, if necessary, Phase 2 actions. The
submittal should also propose start dates, finish dates if possible, and triggering conditions
if possible.
5. Technical Memorandum Phase 1 item 1 proposes to dewater the existing pond, and Drawing
C-1 notes that the dewatering flow can be discharged into a filter sock, and into the storm
drainage system. I'm unclear on what that means on this site, and where exactly the

Mr. Mike 5antowasso
Page 3 of 4
November 4, 2013
discharge from the filter sock will go. Please clarify that for our review in the ultimate
submittal to RRO.
6. Technical Memorandum Phase 1 item 2: I'm unclear on the reference to assuring that "the
low flow discharge pipe is functioning." On the drawing detail I see the riser, the low flow
orifice indicated on the riser, and the main 24" discharge pipe from the riser. Is the
reference to a 'low flow discharge pipe' a reference to the emergency drain line also shown
on Drawing C-3? Please clarify for us the intended operating mode, and that the emergency
drain line will not be used in a normal, or even low -flow, operating mode.
7. Technical Memorandum Phase 1: You may want to consider whether it makes sense to
remove the beavers as part of Phase 1 activities.
8. Technical Memorandum Phase 2: Channel realignment is noted in item 1, and on Drawing
C-1 Phase II note 1 requires the contractor to clear the vegetation and re -grade the channel
leading up to the stormwater pond. I may need to understand this better, but it's not clear
to me that clearing out the vegetation is a beneficial approach on this particular site. Please
explain this in the ultimate submittal.
9. Technical Memorandum Phase 2: General comment: I think we should consider together
whether the parties want our ultimate agreement between the City of Raleigh and RRO to
reflect that the City will come back to RRO with individual proposals for each succeeding
step after Phase 1. Even if we go one step at a time, there still may be reasons now to at
least outline the anticipated major elements of a Phase 2. For the moment in these
advance comments, I'll defer further comments on the Phase 2 Improvements.
10.John Holley's comments to me emphasized maintaining and expanding where possible the
use of vegetated stabilization and cover. Proposed construction activities should disturb as
little as possible of the vegetated areas. Where indicated by small erosion features, the
site should consider using level spreaders to ensure that flow entering the vegetated areas
remains diffuse and does not re -constitute into concentrated flow. Where feasible,
expansion of the vegetated flat areas should be considered, if operating space can be made
available through adjustment of the composting activity footprint.
11. John also commented that the access road should be maintained as a grassed surface, if at
all possible. I note that Drawing C-3 calls for a substantial amount of stone paving. This
seems contrary to best stormwater control practices. Please address this in the ultimate
submittal.
12. JH comment: Construction should include establishing safe access to the new sampling
point.
13. JH comment: Drawing D-1 Detail 5 Stone Check Dam calls for a 12" height of Class A
stone. John advises that the check dam should be constructed approximately 18" high of
riprap (Class B or 1) and faced with a layer of #5 or #57 washed stone on the upstream
side.
14.JH comment: The SPPP should be updated to designate the recycling and emergency
operation areas as well as the established and proposed BMPs.
15.JH comment: Although the operator has indicated that sufficient resources are available for
this project, John recommends that Solid Waste Services explore a partnership with the

Mr. Mike Santowasso
Page 4 of 4
November 4, 2013
city's stormwater utility as a potential advocate for additional resources, and because their
activities should naturally overlap and complement the city's stormwater management
strategies.
16. My comments on the meeting notes from October 23, 2013.
a. As recorded in your notes, please send me all past water monitoring data for the
site. Just the results and clarification of the sampling locations are all that are
necessary for my interest at this time. I mean, it's not necessary for you to
construct an interpretation of the results at this point in time.
b. Are you still interested in following up on questions concerning the lab method for
monitoring for bacteriological pollution? Please contact Bethany or me if we can
help.
c. I withdraw any on -site comments indicating my request for submittal of a funding
schedule for site improvements. In retrospect my perhaps poorly expressed, but
now more sharply focused, intent was to emphasize that the City should be aware
that follow up expenditures may be required beyond just Phase 1, depending on the
performance of the proposed construction.
d. We acknowledge that the current in -progress Phase 1 proposal from the City of
Raleigh is not based on engineering calculations that predict numerical results below
benchmark values for the several pollutant parameters in the permit. Additionally,
the Division is committed to allowing the Yardwaste Center to approach stormwater
control in a phased manner to control their costs. However, please note that along
with the provision for a phased approach, the text of the permit requires that the
permittee eventually achieve effective control of his polluted discharges.
Mike, I hope these comments are helpful for your work. We look forward to working with you and
to receiving the City's fully developed compliance plan, at least through Phase 1.
Sincerely,
Ken Pickle
DEMLR Stormwater Permitting Program
cc: Mr. Ed Wright, City of Raleigh Solid Waste Services
Mr. Fred Battle, City of Raleigh Solid Waste Services
John Holley, DEMLR RRO
Dave Parnell, DEMLR RRO
Danny Smith, DWR RRO
Bethany Georgoulias, Stormwater Permitting Program
Bradley Bennett, Stormwater Permitting Program

Pickle, Ken
From: Pickle, Ken
Sent: Wednesday, October 30, 2013 9:17 AM
To: Holley, John
Cc: Parnell, David; Bennett, Bradley; Georgoulias, Bethany
Subject: RE: City of Raleigh Yard Waste stormwater pond comments/response
Thanks, John,
I'll compose the letter including my comments and your ideas below for our 'courtesy review'.
Hi Dove,
These folks are our permittee under stormwater General Permit NCG24, for compost site surface discharges. They owe
RRO a plan to address the conditions of the permit, and we agreed to give their in -progress plan a courtesy review. I'll
send out the review letter over my signature.
Call me if you want to chat about this. I've been on the site several times, and I feel like I have a pretty good memory of
site conditions. Let me know if you have further comments for our courtesy review of their preliminary submittal. If you
have the time to look at the materials, I'd like to send out the letter nit this Friday.
think we are committed to allowing a phased or stepped approach to their efforts to control stormwater pollution. I
mean, our comments on the in -progress plan will not presume that this is the only or final step in their efforts to control
the polluted discharge from their site. But, I think we should hold them to proposing steps that are real progress in
reducing the pollution content of their discharge. This is a pretty gray area for me at the moment, and 'BPJ' seems to be
what we will have to rely on as to the acceptability of their proposals.
Hi Bethany,
If you have the time, I'll ask you to review my draft letter later this week when it's ready.
Thanks,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: htto://portal.ncdenr.org/web/Ir/stormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Holley, John
Sent: Tuesday, October 29, 2013 4:20 PM
To: Pickle, Ken; Parnell, David
Subject: FW: City of Raleigh Yard Waste stormwater pond comments/response

I offer the following comments for consideration in our coordinated response to the city:
(1) The overall management of the facility appears to be satisfactory and consistent with expected BMP application
for this type of existing site�he restoration of byff<rrs along the central stormwater collection system seems to
—6e working reasonablysnrell, and the application and maintenance of vegetation throughout the site on inactive
areas appears to be restraining erosion very well. The current composting, recycling and emergency operations X
areas associated with the site appear to be well established and appropriately segregated. _
(2)_ TF dam and-surrouriding area around the stormwater pond are welkestablished in vegetation and should not
be disturbed, in my opinion, during phase one of the proposal! -They should only disturb the area necessary for_
removal/handling of solids romthe pond and-reconstruction•ortFie'forebay: I would also recommend that the—?
access road remain in vegetative -cover if at all possible. Gravel should only be used where absolutely necessary
to make the access usable by heavy equipment.
(3) The area at the primary spillway outlet serving the pond should be cleared and prepared, as necessary, to
establish n appropnate sampling site. The existing sampling site should be eliminated.
(4) here feasi 1'ef the composting area should continue to be pulled back from the central stormwater collection
leav
ehind for enhanced tr
the buffers where runoff tends to concentrate so
ent of runoff. Level spreaders should be installed
at diffuse flow is maintained into the buffer. ,I
(5)- Although the operator has indicated that sufficient resources are available for this project, I recommend that
they explore a partnership with the city's stormwater utility as a potential advocate for additional resources, and
because their conservation activities should naturally overlap and compliment the city's stormwater
? management strategies.
(6) The SWPPP should be updated to specifically designate the recycling and emergency operation areas as well as
established and proposed BMPs.
�r
Ccan support continued operation of the facility, as proposed, with these issues addressed] Once data has been
collected and reviewed over the next quarter, we should know whether additional BMPs will be necessary. By copy of
this email, I am requesting that Dave Parnell add any observations he may have after reviewing the submitted
documents and emails I have forwarded to him. If there are any questions, please advise.
From: Pickle, Ken
Sent: Thursday, October 24, 2013 5:45 PM
To: Holley, John
Subject: FW: Partial progress, not yet done, Raleigh Yardwaste Center and 7Q10
Ken Pickle
Environmental Engineer
NCDENR I DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken, pickleCa ncdenr.gov
Website: http:Llportal.ncdenr.orq web/ir/stormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

From: Pickle, Ken
Sent: Thursday, October 24, 2013 4:21 PM
To: 'Santowasso, Michael'
Cc: Georgoulias, Bethany; Bennett, Bradley; Smith, Danny
Subject: Partial progress, not yet done, Raleigh Yardwaste Center and 7Q10
Hi Mike,
Thanks for your questions this morning on the zero -flow stream centrally located on the site. I'm making my way
through the relevant regs, and contacting others in DWR/DEMLR for additional input on how we have applied the zero -
flow stream regs in the past in other circumstances.
Here is where I think I'm headed on the question of the central drainage feature at the site:
• Based on our conversation this morning, I agree that the City's original permit application documents report that
the central drainage feature is a zero -flow stream.
• Identifying the feature as a zero flow stream per 15A NCA 2B .0206(d) means:
o That it is not a ditch;
o That it is not an effluent channel, per 15A NCAC 213 .0228;
o That it is some sort of surface water of the state. (I'm still looking into whether there are special
regulatory provisions for zero flow streams beyond those in .0206(d) and the prohibition against new
discharges of oxygen consuming wastes.)
The term "zero -flow stream" is jargon that does not appear verbatim in the regs, but the jargon does have
meaning. The meaning is presented in .0206(d) for the case where the 7Q10 of any particular stream is zero.
o Note that we would expect under most circumstances that the stream may very well have flow at other
times outside of the times when the 7Q10 is zero (i.e. once in ten years, the stream experiences no flow
for 7 days, the generalized definition of a ZFS), and that we have this rule .0206(d)specificaliy regulating
new discharges into ZFS.
o- Note that all the provisions surrounding a zero -flow stream in .0206(d) suggest stricter than normal
limitations on the new discharge.
o As I reported in our phone conversation, we have worked our way around the prohibition on the new
discharge of oxygen consuming wastes by noting that the compost facility discharge is not a new
discharge, but instead it is an already existing discharge. And by noting that .0206(d)(1), (2), and (3) all
provide that the agency can determine the requirements for existing discharges into ZFS on a case -by -
case basis.
So, pending feedback from my co-workers on how we have applied the ZFS regs in other circumstances, my
tentative conclusion is as I indicated to you initially, and grows out of the following logic string:
o A ZFS is a water of the state, as attested to by the regulations that place more stringent requirements
for the protection of these waters;
o The NPDES stormwater program is an'end-of-pipe' program, meaning that the permittee is required to
sample and control the content of pollutants in his discharge flow. While there may be provisions in
other programs for considering the dilution effect of the receiving water, we have not used them in the
NPDES stormwater program, and have remained focused on an end -of -pipe approach.
o For the moment, my conclusion is still that the sampling should be conducted on the stormwater
discharge from the pond, not on the in -stream flow from the zero -flow stream.
o Danny Smith was on site yesterday, and he is due back in his office Monday. I've left a message for him,
as he is one of our staff that are most experienced in stream identifications and the application of our
rules to stream identifications. The questions I'll discuss with Danny will include, "Is this really a zero -
flow stream?", and "Is my suggested analysis of the rules correctly applied in these circumstances?"

I'll be back in touch on Monday.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. gickle(cDncdenr gov
Website: http://portal.ncdenr.ora/weblirlstormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

Meeting Minutes -October 24, 2013, 1:00 PM
City of Raleigh Solid Waste Services, Landfill, and Yard Waste Facilities Discussion
Attendees: Tim Heath, Ed Wright - City of Raleigh (COR) Solid Waste Services Department
Danny Smith - NCDENR Division of Water Resources, Raleigh Regional Office
John Holley -NCDENR Land Quality Section Supervisor
Ken Pickle, Bethany Georgoulias, Larry Wade - NCDENR DEMLR Stormwater
Permitting Unit
Mike Santowasso, Corinne Wilson - Hazen and Sawyer
Introductions
+ Mike explained the purpose of the meeting, to begin process for approval of modifications to
the existing pond with the goal of meeting requirements of NCG240000.
• Overview of project status. The site is currently covered under NCG240000, and stormwater
sampling has been conducted. Hazen and Sawyer has prepared a draft memo and
preliminary drawings for NCDENR to outline the proposed approach to restoring the
existing pond and reaching the stormwater discharge permit requirements.
+ Mike explained the approach Hazen and Sawyer proposes, using phased modifications to
existing facilities.
• Ken agreed NCDENR believes a progressive approach with phasing is appropriate.
+ Ken explained that though he will be reviewing this plan, the ultimate decision falls with the
regional office (Dave Parnell and John Holley).
• Ken asked if any monitoring has been completed on -site. Mike will send monitoring results
to date to Ken.
• Mike mentioned a water quality testing procedure specified in the permit. Bethany said
there is no testing procedure specified. Mike will find where the testing procedure
information was found.
Site Walkthrough
• Mike went through an overview of the various phases that Hazen and Sawyer will
implement: (1) restore pond to original condition, restore forebay, install check dams
upstream of forebay; (2) implement further changes if necessary.
9
• John mentioned that Hazen and Sawyer may need to revisit pond design and meet
requirements of the BM P manual if monitoring shows to improvement after phases. V O
(ENGINEER'S NOTE. It should be stated again the plan at this time is to not modify the '
existing pond or forebay - which has never been permitted as a stormwater pond - only
restore the features to original condition for improved stormwater control and
pollutant reduction, and monitor the results.)

• Mike handed out plan sets and a memo explaining the design. Ken would like to see a
schedule in the final submission, but will review this as a preliminary review.
Ken asked about funding of secondary phases if the first phase shows no improvements.
Tim said that he would need to inquire with the City for further funding.Ken would like to
see a funding schedule so that NCDENR can allow the City to wait on funding for phases 2, 3,
etc. if it isn't there yet.
• In the final submission, Ken would like to see design calculations and reasoning behind (D
different phases.
(ENGINEER'S NOTE. As noted previously, no design calculations are proposed at this
time in Phase 1 - the plan is only to restore existing features to original condition.)
• Ken mentioned that the City needs to change the water sampling point to the outlet of the
pond to meet permit requirements. Mike noted the current sampling location is also
included in the SWPPP.
(ENGINEER'S NOTE, Hazen and Sawyer would like clarification on the need to relocate
the sampling point from the previously agreed location. Reference was found in the (01
permit application noting the drainage feature east of the pond discharge is considered
a "Zero Flow Stream. During a post -meeting phone call with Ken Pickle, Ken has agreed
to look into what, if any, implication this status for the feature has with regard to the
location of the sampling point. It should be noted the current sampling location is the
point the majority of drainage, from both the east and west sides of the drainage
feature, exits the Yard Waste site.)
• Mike stated the need to discuss budget, schedule, and resources for the project with the
City, and get this information to NCDENR for review. John mentioned that Hazen and
Sawyer should talk with the City of Raleigh Stormwater Unit to discuss forming a
partnership for monitoring the City's facilities.
Conclusions
• Ken and John will go through preliminary review of the drawings and memo and give
feedback to Mike.
• Danny said that nothing was needed from him in this process regarding buffer compliance.

Hazen and Sawyer, P.C.
HAZEN AND SVVER 4011 WestChase Blvd., Suite 500
Environmental Engineers & Scientists Raleigh, NC 27616
919-833-7152
Technical Memorandum
{`rocjrZ...
PREPARED FOR: Ken Pickle, NCDENR Stormwater Permitting -Unit-
Danny Smith, NCDENR Surface Water Supervisor
John Holley, NCDENR Land Quality Section Supervisor
CC: Fred Battle, City of Raleigh Solid Waste Services
Ed Wright, City of Raleigh Solid Waste Services 10M
.S .
FROM: Hazen and Sawyer, PC
PREPARED BY: Mike Santowasso, Matthew Jones
DATE: October 23, 2013
SUBJECT: Raleigh Yard waste Center
Proposed Stormwater Pond Improvements
H&S Project 30336-011
Assessment of Exis ing Conditions
On October 18( 2012,1Hazen and Sawyer staff conducted a walkthrough of the City of Raleigh
Yardwaste Center, located off of N. New Hope Road. The purpose of the walkthrough was to
examine existing stormwater conveyance and treatment mechanisms and identify opportunities
to improve on -site stormwater control to support stormwater permitting under the new NP_DES
General Permit NCG240000. A Notice of Intent been {NOI) has besubmitted to NCDENR DWQ, X
ba Ce ut rtificate of Coverage' has not been issued fo
r the facility. Under NCG240000,
stormwater sampling is required and hreshold discharge standards have been established. A
., schedule for compliance must be established in conjunction with NCDENR DWQ. It is
anticipated that the City will have as long as two years to comply with discharge standards: X
Proposed improvements are intended to provide•the-Cityrtun with;the-best-oppoity'to meet`the
discharge standards while maximizing cost effectiveness and minimizing impacts to facility
operations. ,�� _- _._ -Z
Proposed Stormwater Improvements
Hazen and Sawyer has identified several potential mechanisms to improve stormwater
management at the site, and these items are discussed below. The following improvements are
presented in phases as a proposed schedule for. compliance, for review and app_rgval by
NCDENR staff. It should be noted that the existing stormwater festing program, which was n` %
place prior to the Certificate of Coverage for the General Permit being issued, must continue
throughout the period of permit coveragefStormwater"monitoring data will assist in the
evaluation of the ee ff ce tiveness of the proposed improvements, and in determining what, if any,
further improvements may need to be implemented.
Page 1 of 4

Phase 1 Improvements ?
r�
Hazen and Sawyer recommends the Phase 1 improvements be implemented immediately
upon NCDENR approval of the compliance schedule and all necessary permitting for the site.
1. Restore Original Grades to Detention Basin — The basin will be dewatered and
accumulated sediment and debris will be removed. All sediment removed shall be
disposed of and stabilized in a location such that further sediment transport does not
occur_ The basin will be restored to original design grades, and identified berm
deficiencies or problems will be addressed. Exterior and interior berm slopes, above the
n'orrrial pool elevation, will be re -seeded as necessary to insure adequate stabilization.
2. Clear and Repair Detention Basin Riser - Debris from the wet detention basin riser
will be reviewed, and the riser will be inspected to determine if any repairs are
�n necessary to the riser structure, trash rack, overflow drain, etc. to ensure the overflow
and low -flow drawdown are both functioning as designed Once cleared; and repaired,
bay, if req0if&d7the riser shall'be inspected on a regular basis to assure the outlet is clear +�
and the low flow discharge pipe is functioning.
3. Improve the Existing Pond Forebay — The pond forebay is critical in the removal of
sediment and other pollutants from runoff leaving the facility,. The forebay shall be ✓
�e In arged and impr d eluding lining with-Class.B.Erosion Control Stone. The berm
separating the forebay frorrithe body of the pond shall be re -constructed., and also lined ✓
with Class B stone.
4. Upstream Channel Improvements - Basic improvements to the swale immediately {
upstream of the forebay shall address bank stabilization and channel dimensions. Stone
check dams shall be installed in the channel to slow incoming flow and provide
additional impoundment area for sediment deposition and nutrient removal.
Phase 2 Improvements
If water quality data collected following repairs to the basin, forebay, and immediate
upstream channel indicates additional water quality improvements are necessary, a number of
additional measures can be considered in a second phase of improvements.
1. Evaluate Swale Improvements Upstream of the Forebay — Improvements could
include additional check dams, improved vegetation, channel or bank stabilization, or
channel re -alignment. Existing culverts should be inspected routinely and new culverts
with stabilized outfalls installed in areas where equipment crosses the swales on a
routine basis.
2. Provide Localized Detention — Additional localized detention adjacent to the compost
and possibly leaf storage areas may be considered to reduce sediment and nutrient
loading. The nature of the detention would need to be determined based upon the
Page 2 of

location of the areas served, the discharge data, and operational modifications
available.
3. Operational Improvements — Modifications to the facility operations can improve water
quality. The need for such modifications should be established after review of
stormwater discharge quality data once structural repairs outlined above are in place. It
is anticipated that the compost areas and the leaf storage areas have greater potential
impact on water quality than yardwaste storage and processing areas and operational
modifications should be focused on these areas. Potential modifications and
improvements include:
a. Relocating the compost area closest to the detention pond,
b. Expanding the pavement beneath compost areas to allow for more efficient
composting,
c. Delay further development of leaf storage or any compost areas on the east side
of the facility that do not drain to the existing detention pond,
d. Establish vegetation in all inactive areas east of the stream, and consider
restoring the sedimentation basins on that side of the creek if turbid runoff is
observed,
e. Increase setbacks from compost and leaf storage areas to swales and the pond
and establishing vegetation to filter runoff in the setback areas.
In conjunction with these improvements, compost windrows should be aligned to prevent
trapping stormwater runoff. Areas adjacent to leaf storage areas and finished compost
piles should be graded to prevent ponding of runoff beneath or adjacent to the piles. On
the day of our visit, we observed that the compost windrows were properly aligned.
Areas adjacent to the leaf storage area located on the east portion of the site showed
signs of recent ponding of surface water runoff.
Conclusions
While there is inherent uncertainty in the nature of activities at the site and associated
water quality impacts, it is our opinion that implementation of the Phase 1 improvements
outlined above can improve water quality and support compliance with the discharge criteria
established in NCG240000. NCDENR DWQ has indicated they would provide some
compliance flexibility to the City as the Yardwaste Center is an "existing" facility, so there is an
opportunity to make improvements and evaluate their impact. At a minimum, the Phase 1
improvements discussed above will be required, in our opinion, to consistently meet discharge
limits.
Additional improvements, including construction of BMP's as outlined in Phase 2, may
be required based upon long-term discharge sampling data. Modifications to the facility
operations, including consolidating active compost areas, may also be utilized to accomplish the
Page 3 r,F 4

required stormwater discharge improvements, especially when combined with site specific
improvements to the stormwater conveyance system.
The City of Raleigh, with technical support from Hazen and Sawyer looks forward to
working with NCDENR staff to reach an agreement on the approach for improving stormwater
discharge quality as outlined above and determining a schedule for the site to reach compliance
with the requirements of NCG240000. Should you have any questions or need additional
information regarding the proposed plan, please feel free to contact us.
Pace 4 of 4

*�A
AW . .
NCDE R
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E.
Governor Director
January 15, 2013
Mr. J Russell Allen, City Manager
City of Raleigh
630 Beacon Lake Drive
Raleigh, NC 27610
Subject: General Permit No. NCG240000
City of. Raleigh Yardwaste Center
COC NCG240012
Wake County
Dear Mr. Allen:
Dee Freeman
Secretary
In accordance with your application for an NPDES stormwater discharge permit received on September
17, 2012, 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 October 15, 2007 (or as subsequently amended).
Based on your representation in the permit application that the Raleigh Yardwaste Center is a Type I
compost facility, the provisions of the recently enacted Session Law 2012-200 pertain to the facility.
Consistent with the provisions of SL 2012-200, DWQ will permit all the composting discharges from
your Type 1 facility under the stormwater discharge provisions of the permit, and the General Permit
requirements related to process wastewater discharges do not apply to the composting discharges from
your Type.1 facility.
As an information item, and not as a condition of the General Permit, we call to your attention the
requirements of the Neuse Riparian Buffer Rule that all stormwater drainage to stream buffers, from
portions of this site that have been constructed after July 22, 1997, must be discharged through a
correctly designed level spreader or another device that meets diffuse flow requirements per 15A NCAC
2B .0233. Diffuse flow requirements are described in Chapter 8 of the North Carolina Stormwater BMP
Manual, available at: httpa/portal.ncdenr.or�lweb/wq/ws/su/bmp-nianualportal.ncdenr.or�/web/wq/ws/su/bmp-manual.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Water Quality or permits required by the Division of Land Resources, Coastal Area
Management Act or any other federal or local govermnental permit that may be required.
Please note that this certificate of coverage is not transferable except upon the specific action of the
Division of Water Quality.
Wetlands and Stounwater Branch
1617 Mail Service Center, Ralegh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] FAX: 91 M07-6494 North C a ro li n a
Internet: www.ncwaterquality.org Aaht yally
An Equal opportunity 1 Affirmative Action Employer l `J

Mr, J Russell Allen
City of Raleigh—NCG240012
January 15. 2013
If you have any questions concerning this permit, please contact Ken Pickle at telephone'number (919)
807-6376, or at [e-mail].
Sincerely,
ORIGINAL SIGNED M
KEN PICKLE
for Charles Wakild, P.E.
cc: DWQ Raleigh Regional Office, Danny Smith
DWQ Central Files
DWQ Stormwater Permitting Unit Files
Wake County Environmental Services, Attn: Eric Green, P.O. Box 550, Raleigh, NC 27602
Enclosures
Certificate of Coverage NCG240012
Copy of General Permit NCG2400000, permittee only
4, Quarterly stormwater monitoring forms, permittee only
4, Visual monitoring forms, permittee only
Page 2 of 2

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
CERTIFICATE OF COVERAGE No. NCG240012: authorizing SURFACE WATER DISCHARGES
under the National Pollutant Discharge Elimination System (NPDES) program.
In compliance with the provision of North Carolina General Statute 143-215.1 as amended by North
Carolina Session Law 2012-200, 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 Raleigh Department of Solid Waste Services
is hereby authorized to discharge from a Type 1 composting facility (as defined in 15A NCAC 13B
.1400) located at
City of Raleigh Yardwaste Center
900 New Hope Road
Raleigh
Wake County
to receiving waters designated as an unnamed tributary to Crabtree Creek, a class C, NSW water in the
Neuse River Basin.
Pursuant to the provisions of Session Lain 2012-200, a Type 1 composting facility is not required to
have a NPDES permit for discharge of process wastewater. Notwithstanding any contrary provisions
in the General Permit, all discharges of stormwater, including stormwater which comes into direct
contact with or results from the production or use of any raw material, intermediate product, finished
product, byproduct, or waste product are authorized which comply with the stormwater pollution
management requirements, monitoring requirements, reporting requirements, and other conditions set
forth in Part I Part 11 A - D, Part IV, Part V, Part VI, and Part VII of General Permit No. NCG240000.
In accordance with the provisions of Session Law 2012-200, the process wastewater management
requirements do not apply to the composting discharges from this Type I facility, and all composting
operation discharges are authorized when the facility complies only with the stormwater provisions of
the General Permit. To the extent any provisions may be read to impose the process wastewater
standards in the General Permit to discharges from the permittee's facility, the provisions are
suspended and do not apply.
This Certificate of Coverage is an enforceable part of General Permit NCG240000, and shall become
effective for the permittee on February 1, 2013.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day, January 15, 2013.
ORIGINAL SIGNED W
KEN PICKLE
for Charles Wakild, P.E., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

LOCATION MAP: ,
Latitude: 35"47'13" N NCG240012 Facility
Longitude: 78"33'31" W a�
County: Wake Cowity City of Raleigh Location
Stream Class: C, NSW Yardwaste Center
Receiving Stream: UT to Crabtree Ck Sub -basin: 03-04-02 (Neuse 16ver Basin) rffatfA, Not to Scale

STATE OF NORTH CAROL1NA 2013 ; [f' , 5 ,1 � 3� IN THE OFFICE OF
I.- - _ OF ADMINISTRATIVEHEA.RINGS
COUNTY OF WAKE n6)i�l�i1�_.I,,NINGS CASE NO. 11 EHR 13427
CITY OF R ALEIGH
Petitioner,
vs.
NORTH CAROLINA DIVISION OF WATER
QUALITY; COLEEN SULLINS, DIRECTOR
OF THE DIVISION OF WATER QUALITY;
NOR1'H CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL
RESOURCES,
Respondents.
NOTICE OF VOLUNTARY DISMISSAL
WITH PRE, TUDICE
J
case
Th "f 494e& c dse :,r o I&r e"
TO: The Hon. Beecher R. Gray, Administrative Law Judge presiding: Se r&s4�rz�c,
The Petitioner, City of Raleigh, pursuant to Rule 41(a) of the North Carolina Rules of
Civil Procedure, does hereby take a voluntary dismissal of the above -captioned action as to the
Defendants, with prejudice.
0.
Tkus'the day of February, 2013.
CITY OF RALEIGH, Petitioner
Thomas A. McCormick, City Attorney
By:
DANIEL F. McLAWHORN,
Associate City Attorney
NC State Bar No. 6273
One Exchange Plaza, Suite 1020
Raleigh, North Carolina 27602
Telephone: [phone]
Facsimile: [phone]
Entail: dan.mclawhorn ralei hnc. ov

CERTIFICATE OF SERVICE
This is to certify that the undersigned has this day served the attached NOTICE OF
VOLUNTARY DISMISSAL, WITH PREJUDICE on all of the parties to this cause as required
under the North Carolina Rules of Civil Procedure, addressed to each of the said parties as
follows:
BRENDA MENARD,
Ms. Vicky Bullock
Assistant Attorney General
ALJ Assistant
NC Department of Justice
9QQ1 Mail Service Center
Office ofAdjrtinisli atit�e Hearings
Nortlz Carolina 27699
6714 Mail Service CenterRaleigh,
Telephone: [phone]
Raleigh, NC 27699-6714
Facsimile: [phone]
Telephone: [phone]
Email: DMenard ncdo'. ov
Facsimile: [phone]
[e-mail]
This February 13, 2013.
CITY OF RALEIGH, Petitioner
Thomas A. McCormick, City Attorney
ley:
D 1BL F. McLAWHORN,
Associate City Attorney
NC State Bar No. 6273
One Exchange Plaza, Suite 1020
Raleigh, North Carolina 27602
Telephone: [phone]
Facsimile: [phone]
Email:. dan.mclawhorn [e-mail]
2 of 2

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Pickle, Ken
From: McLawhorn, Dan [Dan,[e-mail]]
Sent: Wednesday, January 02, 2013 10:37 AM
To: Pickle, Ken; Cooper, Kathy
Cc: Bennett, Bradley; Bachl, Carolyn; Bove, John A.; Battle, Frederick
Subject: RE: Raleigh Yardwaste Facility revised COC
Ken,
I see the SIC language as a key issue. Raleigh needs to be exempted, or federal regulations will apply and
make the runoff from the raw material and intermediate products areas be "process wastewater." The
legislation was written expressly.to overcome that problem created by DWQ's decision that this activity is
covered by the SIC.
In my drafting, I am not sure that I preserved Raleigh's opportunity to treat and discharge stormwater that
does not meet the criteria for stormwater discharges. Of course, I would agree that more contaminated runoff
has to meet the process wastewater standards in the GP. Does DWQ agree that Raleigh can use the process
wastewater part of the GP if it needs to treat some part of the runoff to the higher standards before
discharge?
Dan McLawhorn
Associate City Attorney
PO Box 590 Raleigh, NC 27602
[phone] NEW [office] [phone] [fax]
Email [e-mail]
From: Pickle, Ken [mailto:[e-mail]]
Sent: Wednesday, January 02, 2013 10:21 AM
To: McLawhorn, Dan; Cooper, Kathy
Cc: Bennett, Bradley; Bachl, Carolyn; Bove, John A.; Battle, Frederick
Subject: RE: Raleigh Yardwaste Facility revised COC
Hi Dan,
See attached Word copy of NCG24, per your request.
Thanks for the review, Just to re -iterate my perspective at the moment:
• 1 view our back and forth now as just a matter -of getting the language crisp enough so that you feel Raleigh has
the protection from third parties that the Session Law intended.
• We remain committed to implementing the Session Law fully, and to the essence of the agreement that Raleigh
and DWQ reached together in our last face-to-face meeting.
• For administrative efficiency reasons, we would much prefer even an awkwardly large revised COC, rather than
revising the General Permit itself, as revising the General Permit would involve another public notice, another
loop through EPA, and the extra staff time and other costs (newspaper ads across the state). It would also delay
the implementation of our program for other composting facilities as the new permit version is developed. For
these reasons we are most interested in trying to implement the Session Law provisions and our agreement via
the COC, if it can be made sufficient for both our purposes.
• I like most of your language in the mock COC that you offer as an example. Could you live with your example
language, minus the statement that the Raleigh facility is not captured by the SIC category? I'd rather just

remain silent on the SIC question, since I think it's an argument we can avoid. The language you offer is
otherwise fine with us, pending your further reflection on it to be sure it covers all the bases for Raleigh.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(c'bncdenr.qov
Website: http://portal.ncdenr.org/web/­wq/wslsu
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: McLawhorn, Dan(mailto: Dan. [e-mail]]
Sent: Monday, December 31, 2012 4:52 PM
To: Pickle, Ken; Cooper, Kathy
Cc: Bennett, Bradley; Bachl, Carolyn; Bove, John A.; Battle, Frederick
Subject: RE: Raleigh Yardwaste Facility revised COC
Ken,
Can you send me the final GP in word instead of as a pdf? I need to show the places that we have problems
with the final GP so we can see if there are solutions. It is very cumbersome to have to do so from the pdf
version.
My problems begin on the cover page of the permit where the large Type 1s are classified as falling under the
SIC. As a matter of federal law, that makes the process runoff water wastewater and it cannot be Stormwater.
This in effect undoes the state legislation and makes the GP in excess of DWQ's authority.
Coverage under this General Permit is applicable to:
❑ Stormwater point source discharges associated with composting operations (Standard Industrial
Classification 2875) classified as: large Type 1, Type 2, and small Type 3 Facilities as described in
regulations administered by the Division of Waste Management and found at 15A NCAC 1313.14b2(f);
and associated vehicle and equipment maintenance activities;
All of Part I is made applicable to the City. In Part 1, the separation into stormwater and process water is
created. As written, the CoC will only allow us to discharge stormwater and not to discharge process
wastewater in accordance with the stormwater provisions.
This General Permit covers composting operations that discharge stormwater that has come in
contact with qualifying finished compost, and site stormwater which has not come in contact with
any raw materials, intermediate products, final products, by-products, or waste products during
the compost manufacturing process; and stormwater runoff from vehicle and equipment
maintenance activities.
This General Permit also covers composting operations with discharges of process wastewater
arising from raw materials, intermediate products, final products not qualifying as finished
compost, by-products, or waste products.

SECTION B: PERMITTED ACTIVITIES
Until coverage under this permit expires or is modified or revoked, the permittee is authorized to
discharge stormwater and process wastewater to the surface waters of North Carolina, or to a
separate storm sewer system, which has been adequately treated and managed in accordance with
Permit No. NCG240000
Part I Page 2 of 3
the terms and conditions of this General Permit. The types of authorized discharges are
dependent upon DWQ approval and are detailed in the permittee's individual Certificate of
Coverage (COC); where applicable, the COC also details DWQ's Authorization to Construct
(ATC) and authorization to operate process wastewater treatment facilities.
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. If
composting operations will expand or change such that the types of discharges are affected, the
permittee shall contact DWQ in advance to determine if modifications to the COC are necessary.
(d) For wastewater discharges, the quarterly monitoring and reporting actions required
in Part II Section E remain in effect under this compliance schedule. The
requirement to comply with the effluent limitations is stayed until a date set in the
approved plan for full compliance.
Part Ill B is made applicable, so the City can only discharge process wastewater per the permit limits.
SECTION B: REQUIREMENTS FOR OPERATION OF A PROCESS WASTEWATER
TREATMENT FACILITY
1. For both existing and new composting facilities: For composting sites with a process
wastewater treatment facility, the permittee shall operate and maintain the process
wastewater treatment facility in accordance with the requirements of this General Permit.
2. The diversion or bypass of untreated process wastewater from the process wastewater
treatment facility is prohibited except under provisions of this permit in Part IV, Section CA
and Part IV, Section E.7.
Part VII, definitions is key to amending the GP to comport with the new statute. That is not done and thus the
problems are unavoidable. To the extent there is any new language of comfort, it is in the cover letter which is
not part of the permit and thus no help at all.
22. Process Wastewater
Process wastewater is defined in 40CFR122.2 as, "Process wastewater means any water which,
during manufacturing or processing, comes into direct contact with or results from the production or
use of any raw material, intermediate product, finished product, byproduct, or waste product."
31. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall
or as a result of snowmelt. _
32. Stormwater Associates# with Industrial Activity
The discharge from any point source which is used for collecting and conveying stormwater and
which is directly, related to manufacturing, processing or raw material storage areas at an industrial
site. Facilities considered to be engaged in "industrial activities" include those activities defined in
Permit No. NCG240000
Part VII Page 5 of 5
40 CFR 122.26(1 )(14). The term does not include discharges from facilities or activities excluded
from the NPDES program.

am sure this list is not exhaustive, but it shows the huge changes that must be made via the CofC unless there
is a revised GP for large Type 1s. A revised CofC would have to look something like the following:
In compliance with the provision of North Carolina General Statute 143-215.1 as amended by North Carolina
Session Law 2012-200. 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 Raleigh Department of Solid Waste Services
is hereby authorized to discharge from a Type i composting facility (as defined in 15A NCAC 13B .1400)
located at
City of Raleigh Yardwaste Center
900 New Hope Road
w Raleigh
Wake County
to receiving waters designated as an unnamed tributary to Crabtree Creek, a class C.. NSW water in the Neuse
River Basin. The City of Raleigh Composting Facility is not included within any Standard. Industrial
Classification. Notwithstanding any contrary provisions in the General Permit, all discharges of stormwater,
including, stormwater which comes into direct contact with or results from the production or
use of any raw material, intermediate product, finished product, byproduct, or waste product; are authorized A-4
merges shall be in aceeF anee which comply with the stormwater pollution management requirements,
monitoring requirements, reporting requirements, and other conditions set forth in Part 1, Part II A - D, Part III
A5 and B, Part IV, Part V, Part V1, and Part VI1 of General Permit No. NCG240000. In accordance with the
provisions of Session Law 2012-200, the wastewater management requirements
do not apply to the composting discharges from this Type I facility, and all composting
operation discharges are authorized when the Facility complies only with will be subjeet to only the stormwater
provisions of the General Permit. To the extent the following provisions may be read to impose the process
wastewater standards in the General Permit to discharges from the City of Raleigh Yardwaste Center, the
provision are suspended and do not apply: Part 1. Section B: Part III. Section 13.2.; Part VII, definitions 22.. 31..
and 32.
I need to reflect to be sure that I have covered the appropriate bases. I have copied Fred Battle and John Bove
as they know more than I about the appropriate way to consider the two types of discharges in the context of
our facility.
I offer this as a starting point, and look forward to hearing from you soon.
Happy New Year,
Dan McLawhorn
Associate City Attorney
PO Box 590 Raleigh, NC 27602
919 996-6623 NEW [office] [phone] (fax]
Email dan.mclawhorn(c-braleighnc.gov
From: Pickle, Ken [mailt%ken. [e-mail]]
Sent: Monday, December 31, 2012 1:41 PM
To: McLawhorn, Dan; Cooper, Kathy
Cc: Bennett, Bradley
Subject: Raleigh Yardwaste Facility revised COC

Hi Dan, Hi Kathy,
COC: Can you all take a look at the attached Certificate of Coverage to see if it is satisfactory, please?
Transmittal letter: I've re -read my December 13, 2012 letter to J Russell Allen. Since we are no longer relying on the
transmittal letter, but instead have put the heart of the matter now in the COC, I believe I can just change the date on
the December 13 letter and re -issue it with no other changes. Please advise.
Let me know if this falls short of what's needed.
Thanks for your: help in getting this right.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: http:l/i)ortal.ncdenr.org/web/wo/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
"E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and may be disclosed to third parties by an authorized City or Law
Enforcement official."
"E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and may be disclosed to third parties by an authorized City or Law
Enforcement official."
(1

HAZEN AND SAWYER
Environmental Engineers & Scientists
September 13, 2012
Stormwater Permitting Unit
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Notice of Intent — NCG240000
City of Raleigh Yardwaste Facility
H&S No. 30336-011
To Whom it May Concern:
Hazen and Sawyer, ll
4011 WestChase Blvd.
Suite 500
Raleigh, NC 27607
[phone]
[phone] (Fax)
On behalf of the City of Raleigh, Hazen and Sawyer is transmitting an original and one
copy of the Notice of Intent (NO[) for NPDES application for coverage under General Permit
NCG240000 for the City's Yardwaste Facility (yardwaste processing and composting) located
on 900New Hope Road, Raleigh, NC. Attached to the NOI are the following:
• Check for $100 made payable to NCDENR,
• A Site Plan.
• General Narrative, including a facility Location Map.
If you have any questions or require additional information, please contact us.
Very truly yours,
HAZE NZSA YER, P.C.
Gv�
Jon . Bove, P.E.
Associate
Attachments
cc: Fred Battle, City of Raleigh
Dan McLawhorn, City of Raleigh
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II .
�� ' • Division of Water Quality / Surface Water Protection
NCDENRNational Pollutant Discharge Elimination System
P4 R C ROUNA 0�T�of
ES+ 011C� win NA RIL RESCWCE{
NCG240000
NOTICE OF INTENT
FOR AGENCY USE ONLY
Date Received
Year Month
Da
Certificate of Coverage
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Check #
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Permit Assigned to
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National Pollutant Discharge Elimination System application for coverage under General Permit
NCG240000 for
STORMWATER AND PROCESS WASTEWATER DISCHARGES associated with activities classified as:
SIC Code (Standard Industrial Classification Code) 2875 Compost facilities, and like activities.
For questions, please contact the DWQ Central Office or Regional Office for your area. (See page SJ
1) Mailing address of owner/operator (official address to which all permit correspondence will be
mailed): (Please print or type all entries in this application form.)
Legal Owner Name City of Raleigh Department of Solid Waste Services, J. Russell Allen, City Manager
(Please attach the most recent Annual Report to the NC Secretary of State showing the current legal name.)
Street Address 630 Beacon Lake Drive
City Raleigh State NC ZIP Code 27610
Telephone No. 919-996-6890 Email [e-mail]
Alternate Contact Name Frederick D. Battle Email (if different) Frederick. [e-mail]
Alternate Contact Telephone (if different) 919-996-4281
2) Location of facility producing discharge:
Facility Name City of Raleigh Yardwaste Center
Facility Contact Frederick D. Battle
Street Address 900 New Hope Road
City Raleigh State NC ZIP Code 27602
County Wake
Telephone No. 919-250-2728 Email Frederick. [e-mail]
3) Physical location information:
Please provide narrative directions to the facility (use street names, state road numbers, and distance and
direction from a roadway intersection). 1440 Exit US 64 Business East. 1.2 Mi. Right turn onto New Hope
Rd. Facility is 0.8 Mi on left
(A copy of a county map or USGS quad sheet with the facility clearly located on the map is a required part of this application.)
4) Latitude N0350 47' 12.84" Longitude W0780 33' 31.29" (deg, min, sec)
5) This NPDES Permit Application applies to the following (check appropriate box):
❑ New or Proposed Facility Date operation is to begin
x Existing Facility DWQ Permit # 92-13
6) Consulting Engineer's (or other qualified design staff's) application information:
Consulting Engineer: John A. Bove, P.E.
Consulting Firm: Hazen and Sawyer, P.C.
Mailing Address: 4011 Westchase Blvd. Suite 500
City: Raleigh
State: NC Zip Code: 27607
Phone: [phone] Fax: [phone]
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(Optional)
Staple Business Card Here:
SW U-NCG24NOI-12082011
Page 1 of 6

NCG240000 N.Q.I.
Email: [e-mail]
7) Provide the 4 digit SIC Code that describes the primary industrial activity at this facility:
SIC Code: 2 8 7 5
8) Provide a brief description of the types of industrial activities and products produced at this facility,
including the DWM compost facility classification:
Large Type i Solid Waste Compost Facility processes yard waste, land clearing debris, unpainted wood
waste, and silvicultural waste as specified in 15A NCAC 13B .1402. Processing activities includes stockpiling,
grinding, screening, and composting pursuant to 15A NCAC 13B .1406. Mulch, leaves and compost is sold to
the public and used by the City of Raleigh in public works.
Receiving waters
q) XDischarge points / Receiving waters:
IPI
Number of discharge points (ditches, pipes, channels, etc.) that convey stormwater and/or process
wastewater off the property:
Stormwater only` X Process wastewater only. Both commingled:
What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the stormwater and/or
process wastewater discharges first enter? Un-named zero -discharge stream which discharges into Crabtree
Creek on the facility property.
Receiving water classification(s), if known: Crabtree Creek - Class C
If the site stormwater discharges to a separate storm sewer system, name the operator of the separate storm
sewer system (e.g. City of Raleigh municipal storm sewer). N/A
Will this facility discharge to:
Shellfishing waters (Classified SA)?
❑ Yes
X No
Trout waters (Classified Tr)?
❑ Yes
X No
High Quality Waters (Classified HQW)?
❑ Yes
X No
Outstanding Resource Waters (Classified ORW)?
❑ Yes
X No
Primary Nursery Area waters (Classified PNA)?
❑ Yes
X No
Nutrient Sensitive Waters (Classified NSW)?
X Yes
❑ No
Water Supply Watershed Waters (Classified WS I — WS V)?
❑ Yes
X No
'Zero -flow' streams (as described in 15A NCAC 213 .0206)?
X Yes
❑ No
Note: Discharge of process wastewater to receiving waters classified as public water supply WS-II
to WS-V must be approved by the Public Water Supply Section of the Division of Water
Resources. If DWR does not approve, coverage under NCG240000 cannot be granted. No new
discharges of process wastewater are permitted in receiving waters classified as WS-1 or
freshwater ORW. Similarly, the Division of Environmental Health Shellfish Sanitation Program
must approve process wastewater discharges to SA shellfish waters.
*X1 Does the facility use any of the following on site?
Page 2 of 6
SWU-NCG24NOI-12082011

NCG240000 N.O.I.
❑ Liquid, granular, or other materials added for their concentrated phosphorus compounds content?
❑ Liquid, granular, or other materials added for their concentrated nitrogen compounds content?
Process wastewater (Process wastewaters are defined in Part H Section E of the General Permit text.)
Will your facility discharge process wastewaters to surface waters?
❑ Yes X No
f J Are wastewater treatment facilities planned within the 100-year flood plain?
'J ❑ Yes X No
j :5' Consideration of alternatives to surface water discharge for process wastewaters
a) Land Surface or Subsurface Disposal System (e.g., spray irrigation):
i) Is a land surface or subsurface disposal technologically feasible (possible)?.......... ❑ Yes ❑ No
Why or Why not? NIA
ii) Is a land surface or subsurface disposal system feasible to implement?*_............. 0 Yes ❑ No
Why or Why not? NIA
iii) What is the feasibility of employing a subsurface or land surface discharge as compared to a direct
discharge to surface waters?* NIA
b) Connection to a Municipal or Regional Sewer Collection System:
i) Are there existing sewer lines within a one -mile radius? ........... ........... ❑ Yes ❑ No
(1) If Yes, will the wastewater treatment plant (WWTP) accept the discharge? ....... ❑ Yes ❑ No
(a) If No, please attach a letter documenting that the WWTP will not accept the discharge.
(b) If Yes, is it feasible to connect to the WWTP? Why or why not?* NIA_
c) Closed -loop Recycle System meeting the design requirements of 16A NCAC 2T .1000:
i) Are you already proposing a closed -loop recycle system (CLRS)? ............................. ❑ Yes ❑ No
(1) if Yes, contact DWQ's Aquifer Protection Section's Land Application Unit for permitting
alternatives.
(2) If No, is this option technologically feasible (possible)? Why or why not?* NIA
(3) If No, is it feasible to build a CLRS on your site? Why or why not?* NIA
(4) What is the feasibility of building a CLRS compared to direct surface water discharge?* N/A
Page 3 of 6
SW U-NCG24NOI-12082011

NCG240000 N.O.I.
'KA
d) Direct Discharge to Surface Waters: Is discharge to surface waters the most environmentally sound
alternative of all reasonably cost-effective options being considered?*,. ............................ 0 Yes ❑ No
i) If No, you may not be eligible for coverage under NCG240000, please contact DWQ's Stormwater
Permitting Unit for guidance.
ii) If No, contact DWQ's Land Application Unit to determine alternative permitting requirements.
"Per NC rules at 15A NCAC 2H .0105(c)(2). You maybe asked to provide further information to support your
answers to these questions after the initial review. Feasibility should consider initial and recurring costs.
Process wastewater treatment system performance
You are applying for coverage under NCG240000 which enforces process wastewater effluent limitations on
the pollutants BOD, TSS, pH, and fecal coliform. Except as specifically provided in the General Permit text,
or DWQ compliance schedule, any exceedances of the process wastewater effluent limitations are a violation
of the terms and conditions of the permit, and may be the basis for DWQ enforcement action.
Also please note: NC rule 15A NCAC 2H .0939 requires that wastewater treatment system design be
accomplished by a North Carolina Professional Engineer.
Stormwater
*Does this facility employ any best management practices for stormwater control?
❑ No X Yes
If Yes, please describe briefly: Existing Stormwater Detention Pond See Narrative, Attachment B of this
NOI.
IS) % Does this facility have a Stormwater Pollution Prevention Plan?
X No ❑ Yes
If Yes, when was it implemented? Implementation expected October 2012
14}, Are vehicle maintenance activities (VMA) occurring or planned at this facility?
X No ❑ Yes
Other required information; other permitting
�J A complete application must include two 24"x36" site plans drawn to scale with the following
information: bar scale, north arrow, property lines, topographic contour lines, fence lines, roads, paved
areas, location of the various composting activities with identifying labels, site buildings, surface water
drainage features and wetlands, wells, stormwater and wastewater conveyances, process wastewater
treatment facilities, stormwater BMPs, location of discharge points for both stormwater and process
wastewater discharges, delineation of drainage divides between the various subdrainage areas feeding each
discharge point, delineation of the 100-yr floodplain if present, and a notation of the water quality classification
of the receiving water that site waters eventually discharge to.
/&) A complete application trust include: A general and brief narrative description of the compost
manufacturing sequence at the applicant's site, the general feedstocks, the determination of whether the
site's final product qualifies as 'finished compost' as referenced in the General Permit text (NCG240000) and
as determined by the DWM permitting process, identification of the stormwater BMPs employed, and the
general nature of the wastewater treatment system utilized to meet process wastewater discharge limits.
Page 4 of 6
SW U-NCG24N01-12082011

N6G240000 N.O.I.
9� Is the facility the subject of any current NCDENR Notice of Violation, consent order, compliance
/ schedule, or other enforcement action?
X No ❑ Yes
If Yes, provide a brief explanation:
Does this facility have any other NIPDES permits?
X No ❑ Yes
If Yes, list them:
a1� ` Does this facility have any Non -Discharge permits (ex: recycle permits)?
fJ X No ❑ Yes
If Yes, list them:
29 OmffDoes this facility have a Division of Waste Management permit?
❑ No X Yes
If Yes, Permit number(s): 92-13 Large, Type I Solid Waste Compost Facility
G Hazardous Waste:
/ a) Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
X No ❑ Yes
b) Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month)
of hazardous waste?
X No ❑ Yes
c) Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of
hazardous waste?
X No ❑ Yes
d) Type(s) of waste:
How is material stored? NIA
Where is material stored? NIA
How many disposal shipments per year? NIA
Name of transport / disposal vendor: NIA
Vendor address: NIA
KzlFinalChecklist
This application will be returned as incomplete unless all of the following items have been included:
X One check for $100 made payable to NCDENR.
�/ X al and one copy of this completed and signed application.
O '� Tw�coiles
f the most recent Annual Report to the Secretary of State showing, the current legal name.
A Two copies of the site plan.
X Two site location maps (county map or USGS quad sheet) with the location of the facility clearly marked.
Page 5 of 6
5W U-N CG24 N01-12082011

1Certification:
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other
document filed or required to be maintained under this Article or a rule implementing this Article: or who knowingly makes a false
statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the
[Environmental Management[ Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thousand dollars ($10,000).
I hereby request coverage under the referenced General Permit. I understand that coverage under this
permit will constitute the permit requirements for the discharge(s) and is enforceable in the same manner as
an individual permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Name of Person Signing: J. Russell Allen
Title: City Manger, City of Raleigh (Please mote federal rule signatory requirements at 40CFR122.22)
'l c7)17. Jr z
(Signaturdeof Applicant) (Date Signed)
Notice of Intent must be accompanied by a check or money order for $100.00 made payable to NCDENR
1
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of an NPDES permit.
For questions, please contact the DWQ Central Office or Regional Office for your area.
DWQ Regional Office Contact Information
Asheville.........
Fayetteville ......
Mooresville ......
Raleigh ...........
Washington......
Wilmington.......
Winston-Salem.
Central Office ...
[phone]
[phone]
[phone]
.. (919) 7914200
.. [phone]
[phone]
[phone]
.. [phone]
Page 6 of 6
SWU-NCG24NOi-12082011

ATTACHMENT A — LOCATION MAP
NOTICE OF INTENT
National Pollutant Discharge Elimination System application for coverage under
General Permit NCG240000
CITY OF RALEIGH YARDWASTE FACILITY
SEPTEMBER 12, 2012

04
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LOCATION MAP
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HAZEN AND SAWYER
Environmental Engineers B Scientists
CITY OF RALEIGH
YARDWASTE CENTER
LOCATION MAP

ATTACHMENT B — GENERAL NARRATIVE
NOTICE OF INTENT
National Pollutant Discharge Elimination System application for coverage under
General Permit NCG240000
CITY OF RALEIGH YARDWASTE FACILITY
SEPTEMBER 12, 2012

GENERAL NARRATIVE FOR:
NOTICE OF INTENT
National Pollutant Discharge Elimination System application for coverage under
General Permit NCG240000
City of Raleigh Solid Waste Services Department Yardwaste Center (Large Type I
Compost Facility)
1.1 Facility Description
The City of Raleigh Yard waste Center was opened in November 1991. The facility is
located on the east side of New Hope Road south of the closed Wilders Grove Landfill.
A facility location map is provided on Figure 1.1. The Facility address is:
900 New Hope Road
Raleigh, NC 27602
[phone]
This facility is an active Large, Type I Solid Waste Compost Facility permitted under the
Division of Waste Management under 15A NCAC 13 B Section.1400 — Composting
(Permit Number 92-13). It is an "existing discharger" under the DWQ General Permit
No. NCG240000. The Facility is permitted to receive and process yard waste, land
clearing debris, unpainted wood waste, and silvacultural waste in any combination.
'2 Materials are accepted for and processing or composting only No disposal is
' conducted at the Yard Was a Center. Processing includes stockpiling, grinding and
mechanical screening. A portion of the incoming waste is composted after processing.
No liquids are added for purposes of increasing nitrogen or phosphorus content of the
compost.
Portions of the Facility are occasionally used to process storm debris fromsuhurricanes, d iv,�,t►s
ice storms, etc. Such debris may be processed by City staff or by a US Army Corps of
Engineers contractor. These activities are generally confined to the permitted
processing areas.
Sources of materials processed at the facility include businesses and residents in the
City of Raleigh and throughout Wake County. Most of the waste is hauled to the site by
the City of Raleigh Division of Solid Waste Services through its curbside collection
program. The City Parks and Recreation and Street Maintenance Division (leaf
collection) also haul material to the Facility. City and County residents, landscapers,
and businesses can drop off yard waste at the site.
City of Raleigh Yardwaste Center — Attachment B Page 1 of 6
N01 - NCG240000

Finished compost, wood chips, mulch and leaves are sold directly to the public after
processing. City departments use finished product at no charge for various
applications.
The office is the only building at the Yardwaste Center. The office is modular structure
which houses the scale house operator, individual offices, a kitchen/break room, a
meeting area, and restrooms. The office is served by City water and sewer.
A public recycling area, consisting of roll -off containers for mixed recyclables, is located
to the east of the entrance road. The City of Raleigh periodically services these
containers. Full containers are hauled to the recycling facility. No processing of
recyclables (bailing, packing, etc.) is conducted at the facility.
1.2 Solid Waste Processing
Waste is weighed at the scales and the haulers are directed to the proper location for
dumping. Waste includes yardwaste collected curbside by City crews, leaves collected
from City roads in the fall by the City, yardwaste and silvacultural wastes hauled by
citizens or commercial landscapers, storm debris, and unpainted and untreated pallets.
Materials hauled to the site are segregated into separate stockpiles to the extent
practical. General yardwaste is hauled to processing areas as directed by Yardwaste
Center staff. Leaves (generally hauled by City Public Works vehicles) are stockpiled
separately from yardwaste. Pallets may be stored in dedicated stockpiles.
Yardwaste is processed into mulch by grinding using portable tub grinders. The
equipment can be set up adjacent to the yardwaste set for processing, or the yardwaste
scan be hauled to the location where the tub grinder is set up. Mulch is hauled to
ma(A designated mulch stockpiles and is sold to the public or is further processed by
�tI, screening or composting. Screening is accomplished by portable Trommel screens
P 03h which are set up near the yardwaste, mulch or compost to be screened. Several screen
&oA sizes are used to produce the desired finished product. Select mulch is colored using
A Ivf� powdered iron oxide and water and sold to the public.
Composting, as described in 15A NCAC 13B .1406, is conducted by Yardwaste Center
staff in designated compost areas. Composting is accomplished by placing the material
into windrows. Under the DWM Permit to Operate, no additives to enhance the nitrogen
or phosphorus are used in the compost operations. Water may be added to raise the
material to the required moisture content. Of the approximately 8.5-acres presently
dedicated as compost areas, approximately 1-acre is asphalt paved. The remainder of
the compost areas has an earthen surface at this time.
Finished compost is stockpiled separately for distribution to the public.
City of Raleigh Yardwaste Center — Attachment B Page 2 of 6
NOI - NCG240000

In accordance with North Carolina Solid Waste Regulations, a material may be
considered as "finished compost" once the requirements of the following Regulations
are met, monitored and reported by City staff:
.1406 OPERATIONAL REQUIREMENTS FOR SOLID WASTE COMPOST
FACILITIES
Specifically:
(10) Compost process at Type 1 facilities shall be maintained at or above
55 degrees Celsius (131 degrees F) 3 days and aerated to maintain
elevated temperatures.
.1407 CLASSIFICATION/DISTRIBUTION OF SOLID WASTE COMPOST PRODUCTS
Specifically the classification and distribution requirements for compost
produced at Type I Facilities:
d (3) Compost or mulch that is produced at a Type 1 facility and that
contains minimal pathogenic organisms, is free from offensive odor, and
contains no sharp particles that would cause injury to persons handling
the compost, shall have unrestricted applications and distributions if
directions are provided with the compost product.
Other activities that are conducted at the facility include:
• Stockpiling and cutting of larger trees for the purpose of distribution of firewood to
underprivileged Wake County residents,
• Trucks from the City's Public Works Department are parked on the facility away
from active yardwaste processing and composting operations,
• Bulk storage of crushed stone aggregate, pipe materials for the City's Public
Works Department is periodically conducted on the facility away from active
yardwaste processing and composting operations,
• The City operates a "Swap Shop" where residents can drop off or pick up used
items. No liquids such as paint or other hazardous wastes are accepted,
• Public education, outreach and staff training are conducted periodically.
No fuel is stored at the facility. Fueling of Yardwaste Center operations equipment is
conducted from service vehicles owned and operated by the City. No vehicle
maintenance is conducted at the facility, only routine maintenance of processing
equipment such as replacement of cutting Bads for grinders, etc. Vehicles that need
scheduled or emergency maintenance are brought to the City's Heavy Equipment Shop
on New Bern Avenue.
� ^ ' IC6rel-1 VP A, G� Me' mn ene, e
City of Raleigh Yardwaste Center — Attachment B Page 3 of 6
NOI - NCG240000

1.3 Existing Stormwater BMP's
An unnamed zero flow stream bisects the permitted processing area in a roughly north -
south direction. This stream discharges into Crabtree Creek at the southern facility
boundary. Surface water runoff from existing yardwaste stockpiles, processing and
composting areas located to the west of the stream is controlled by a series of grass
lined or rip -rap lined swales. These swales convey stormwater to a wet detention basin
located at the southern end of the permitted processing area. Existing processing areas
do not drain directly to the stream.
The wet detention basin is approximately 0.35-acres in area (not including the forebay).
It is controlled using a conventional riser and barrel principal spillway. A rip -rap lined
emergency spillway is designed to convey flows in excess of the 10-year design storm.
1.4 Planned Modifications to the Processing Areas
All runoff from stockpiles, processing areas and support areas is considered to be
stormwater. No wastewater treatment is proposed as no industrial activity that results in
wastewater generation occurs at the Raleigh Yardwaste Center.
It is anticipated that stormwater runoff from the permitted areas will be conducted to the
existing detention pond to the degree practical.
A review of the current operations related to the locations of stockpiles, the duration
stockpiles are in place, and the fate of materials in each stockpile will be conducted as
the first step. This will include stockpiles for yardwaste, mulch, leaves and finished
compost. This information will be used to verify that runoff from these areas is
effectively collected by swales and conveyed to the detention pond. New swales will be
installed in stockpile and processing areas not adequate served by the existing swales.
Swales and culverts will be inspected and improved as required. New culverts will be
installed in areas where access by operations vehicles is required.
The stockpile areas are generally upgradient of the compost areas and the stormwater
pond. In an effort to enhance water quality, means to reduce sediment load to the
existing stormwater pond, including grass lined swales, in -line detention, and armoring
of existing swales will be evaluated. Functional and maintenance considerations will be
applied to this evaluation.
Existing roadways separating the permitted processing and composting areas from the
stream in the center of the site will be evaluated to make sure that runoff from these
areas does not enter the stream untreated.
Regulatory buffers of 200-ft exists between the stream centerline and the limits of
yardwaste processing or composting areas. These buffer areas are used, in part, to
collect and convey surface water runoff to the existing pond or to future ponds added as
City of Raleigh Yardwaste Center — Attachment B Page 4 of 6
NOI - NCG240000

the facility expands. Access roadways and adjacent swales and diversion berms are
located in portions of these buffer areas. Existing vegetation will not be disturbed within _
50-ft of the stream.
Regulatory buffers of 200-ft also existing between the limits of the permitted yardwaste
processing areas and the facility boundary. Existing vegetation will be maintained
within these buffer areas to the degree practical to minimize channelization of runoff
from the permitted areas. It should be noted that the area of the permitted yardwaste
areas where surface water runoff flows to the facility boundary are very limited in size.
Additional BMP's to manage runoff from these areas are not anticipated.
Progress Energy easements with active overhead power lines are located to the east
and south of the permitted area within the facility boundary. The easement to the east
is upgradient to the permitted area and therefore no stormwater controls are required.
The easement located to the south of the pond is downgradient of the permitted area.
Minor stormwater controls, such as swales and culverts, can be constructed within the
easement (with permission of Progress Energy), but no BMP's that require significant
grading will be considered.
Improvements are required to the existing stormwater pond to re-establish the design
capacity. These improvements will be completed in the first phase of work as soon as
the COC is issued. The improvements include:
• Re -construction of the forebay and separating berm,
• Stabilization of the inlet channel,
• Inspection of and repairs to the inlet structure and trash rack,
• Inspection of and repairs to the outlet pipe and discharge channel,
• Inspection of 'and repairs to drain,
• Evaluation of a low level outlet, and,
• Restoration of vegetation on slopes as required.
Special consideration will be given to the compost areas (windrows) and their impact on
water quality at the facility discharge. At a minimum, the following improvements will be
evaluated and implemented in the compost areas:
• Evaluate current operations to establish minimum required size and best
locations for existing and future composting windrows,
• Evaluate paving windrow areas, ?
• Grade "pads" containing windrows to promote efficient runoff,
• Divert run-on away from and around compost pads to the degree
practical,
• Provide dedicated "hardened" access points for operations equipment to
minimize development of preferential flow channels for run-on or runoff,
• Improved maintenance activities and schedules.
City of Raleigh Yardwaste Center - Attachment B Page 5 of 6
NOI - NCG240000

a4,,5.
If discharge sampling data indicates that required stormwate limits are not being
attained, or if a trend in concentrations of benchmark constituen s indicates that the
discharge will not meet permit requirements, additional improvements to compost areas
may be implemented to improve water quality prior to discharge of runoff into the pond.
The purpose of such improvements would be to settle out or remove solids and
nutrients contained in the runoff from compost areas. Since the locations and duration
7 of composting operations, and the resulting runoff from these areas are highly variable,
�----� traditional BMP's may not be suitable for implementation. Temporary devices such as
sediment traps, wood chip filters, compost filter socks can be added to ditches or
swales to slow and filter runoff.
The presence of vegetation in the permitted areas is very limited due to the nature of
the operations, placement of stockpiles, vehicle access, etc. Planting of grass or hardy
ground cover will be evaluated near swales or at the downstream boundaries of the
permitted areas to serve as a filter for runoff.
In addition to the structural BMP's discussed above, non-structural BMP's will be
implemented to minimize impact to surface water. Staff training is a key element in the
implementation of pollution prevention. Good housekeeping practices, proper material
storage, spill controls and proper maintenance are all addressed in the facility's
Stormwater Pollution Prevention Plan (SWPPP).
It should be noted that the areas used for yardwaste, leaves, mulch and compost
stockpiles vary with the season, with the demand for products and as the number of
Solid Waste Services customers grows. For this reason, the establishment of
stormwater control facilities, as well as their inspection and maintenance, will need to be
adjusted to site conditions on a routine basis. Routine inspection and maintenance is
necessary to both maintain the function of the existing structures and devices, and to
identify where additional structures and devices are required.
City of Raleigh Yardwaste Center —Attachment B Page 6 of 6
NOI - NCG240000