NCG120023_Compliance Evaluation Inspection Response 20201130

CDM
Smith
5400 Glenwood Ave, Suite 400
Raleigh, North Carolina 27612
tel: [phone]
fax: [phone]
November 30, 2020
Mr. Brian Lamb
North Carolina Department of
Environment and Natural Resources
Division of Energy, Mineral and Land Resources
127 Cardinal Drive Extension
Wilmington, North Carolina 28405
Subject: Compliance Evaluation Inspection
NPDES General Stormwater Permit NCG120000
Certificate of Coverage NCG120023
Onslow County Solid Waste Facility
Dear Mr. Lamb:
CDM Smith Inc. (CDM Smith), on behalf of Onslow County (County), is submitting this letter in response
to the stormwater compliance inspection that was completed at the Onslow County Solid Waste Facility
(Facility) on June 4, 2020, and the Compliance Inspection Report and letter that was provided on June
25, 2020. Stormwater discharge and outfall monitoring at the Facility is performed in accordance with
the National Pollutant Discharge Elimination System (NPDES) and General Permit Number NCG12000
(Certificate of Coverage Number: NCG120023). The General Permit was issued on November 1, 2018,
and expires on May 31, 2021. A summary of the stormwater monitoring program, Tier One and Two
response actions, stormwater improvement plan, and a request to consolidate active erosion control
permits is provided below.
Background
The Facility includes two closed unlined landfills (Permit Number 67-05), an active Subtitle D landfill
(Permit Number 67-09), land clearing and inert debris (LCID) landfill (Permit Number 67-05), a materials
recycling facility, administrative office, and vehicle and equipment maintenance buildings. Analytical and
qualitative monitoring is performed for stormwater runoff from the Subtitle D landfill and vehicle
maintenance facility (VMF). Stormwater runoff from the Subtitle D landfill is captured in a perimeter
drainage ditch and channeled to three sedimentation basins located on the east and west sides of the
landfill. Stormwater in the sedimentation basins is discharged through Outfalls 1 through 3 where it
flows to an unnamed tributary of Southwest Creek (Outfalls 1 and 2) or is discharged to a former borrow
pit (outfall 3).
A VMF outfall was added to the stormwater monitoring program in the fall of 2015 following
construction of the VMF. Stormwater from the VMF outfall is discharged to a perimeter ditch around the
WATER+ENVIRONMENT+TRANSPORTATION+ENERGY+FACILITIES ,

csmith
Mr. Brian Lamb
November 30, 2020
Page 2
southern closed landfill where it is ultimately discharged to an unnamed tributary of Southwest Creek. A
site map showing the outfall locations is provided on Figure 1.
Representative Outfall Status
A compliance inspection was conducted by the Division of Water Quality (DWQ) on January 23, 2013, to
evaluate the County's request to remove Outfall 1 from the monitoring program and to ensure
compliance with the General Permit. Outfall 1 discharges stormwater runoff from the partially closed
portion of the Subtitle D landfill. The partial closure, from bottom to top, consists of a minimum 12-inch
thick intermediate soil cover layer (also serving as the cap liner system subgrade), gas venting
geocomposite drainage net (CDN), textured 40-mil linear low density polyethylene geomembrane,
stormwater management CDN, a minimum 18-inch thick protective soil cover layer, and a minimum
6-inch vegetative soil cover layer. Based on the inspection results, the County was determined to be in
compliance with the General Permit and granted representative outfall status for Outfall 1, which
eliminated collecting stormwater samples semi-annually. Qualitative monitoring is currently performed
at all outfalls in accordance with the permit conditions.
Per the June 25, 2020, Compliance Inspection Letter, the following was requested: responsible party for
the General Permit to be updated with the information for the new Solid Waste Director, a
Representative Outfall Status Request Form for Outfall 1, and communication with the DWQ regarding
sediment loss during Hurricane Dorian. The responsible party information has been updated through the
online NPDES SW Permit Affiliation Change Request Form to reflect the current Solid Waste Director,
Ms. Melissa Moore. The Representative Outfall Status Request Form for Outfall 1 is provided in
Appendix A. An email sent by the Solid Waste Director on September 25, 2019, to Ms. Holly Snider with
the DWQ regarding sediment loss was provided in an email dated June 23, 2020.
Stormwater Monitoring
Stormwater samples are collected from Outfalls 2 and 3 and the VMF outfall in accordance with the
General Permit following a measurable storm event. The precipitation received from storm events is
measured by a rain gauge located near the administration building and recorded. Samples from Outfalls
2 and 3 are analyzed for chemical oxygen demand (COD), fecal coliform, and total suspended solids
(TSS). Samples from the VMF Outfall are analyzed for non -polar oil and grease and TSS. Stormwater pH
is measured and recorded at all outfalls when samples are collected.
Outfalls 2 and 3 are sampled monthly per Tier Two response action requirements due to consecutive
exceedances above the benchmark values. Samples from the VMF outfall are collected semi-annually.
Tier Two monitoring at Outfall 2 is required due to consecutive exceedances of COD, fecal coliform, and
TSS in semi-annual samples collected in May and July 2018. Samples collected from Outfall 3 during the
2014 semi-annual sampling events had detections of fecal coliform and COD above their respective
benchmark value. Sampling results for all outfalls since 2018 are summarized in Table 1.
c1

csmith
Mr. Brian Lamb
November 30, 2020
Page 3
Tier Response Actions
Tier One and Two responses have been implemented and documented after receiving sampling results
above the benchmark values. The DWQ was also notified once the benchmark values were exceeded on
four occasions as required under the previous General Permit.
COD benchmark value exceedances at Outfalls 2 and 3 are due to leachate that has migrated to the
sedimentation basins via seeps discharging to the perimeter drainage ditch or stormwater eroding the
slopes of the Subtitle D landfill and contacting waste. TSS benchmark value exceedances at Outfalls 2
and 3 are from excess sediment in the sedimentation basins that is deposited from slope erosion. The
TSS benchmark value exceedance at the VMF outfall in samples collected during the January to June
2018 semi-annual sampling event was due to erosion from a high intensity storm but has not been an
issue since.
Fecal coliform benchmark value exceedances at Outfalls 2 and 3 are likely from wildlife instead of a
release from the landfill. Most of the fecal coliform sampling results since 2018 for both outfalls have
been reported at 6,000 colonies per milliliter or less as shown in Table 1. The facility is in the migratory
pathway and home to multiple bird species. Birds are always present at the Subtitle D landfill and are
routinely seen in the sedimentation basins along with turtles. Increased fecal coliform concentrations
when COD is detected above the benchmark value coincide with larger bird populations observed by the
County.
The Facility is inspected following rain events to identify erosion rills and leachate seeps that may result
in a benchmark value exceedance. Response actions to benchmark value exceedances have included
backfilling washouts and erosion rills that expose waste with compacted clean fill, repairing leachate
seeps, reseeding to stabilize slopes, installing a soil berm at the toe of slope to keep leachate from
entering the perimeter Subtitle D landfill drainage ditch, removing soils potentially impacted with
leachate from the perimeter ditch and sedimentation basins, and pumping stormwater from the
sedimentation basins to the leachate containment system to prevent outfall discharge. Note that the
soil berm that was installed at the toe of slope was recently removed in preparation of regrading the
slopes and installing new stormwater controls. Erosion rills and leachate seeps are repaired as quickly as
possible, but oftentimes the area needs to dry to make the repairs safely and properly. Preemptive
actions related to waste disposal operations include placing waste materials that can potentially cause
leachate seeps away from the slopes (e.g., shingles, plastic sheeting, or mattresses), grading the plateau
area of the active portion of the Subtitle D landfill to drain away from the slopes, and installing a Posi-
Shell® or soil cover above the active waste disposal area prior to a storm event.
Stormwater Improvement Plan
The County recently hired a new Operations Manager and plans to install additional stormwater controls
to prevent leachate from migrating to the perimeter ditch. The County is also in the process of obtaining
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csmith
Mr. Brian Lamb
November 30, 2020
Page 4
preliminary quotes from contractors to determine if the County or a contractor will install the new
stormwater controls. The additional stormwater controls include the following:
• Soil berms that will be installed at the top of the plateau of the active disposal area to channel
stormwater to slope drains;
• Slope drains constructed with high -density polyethylene pipe that will tie-in to the soil berms at
the top of the plateau of the active disposal area and the perimeter drainage ditch;
• Wattles that will be installed on the slopes to slow stormwater flow; and
• A new North Carolina Department of Transportation seed mix that was selected based on soil
analyses to establish consistent grass growth on the slopes.
The County collected multiple soil samples from the slopes of the Subtitle D landfill in August 2020 that
were analyzed by the North Carolina Department of Agriculture & Consumer Services to determine if the
appropriate seed mix and amendments were being used to promote and sustain grass growth. The seed
mix and amendments were adjusted based on the sampling results. A new Posi-Shell® machine that is
capable of hydroseeding with mulch and tackifier was purchased and will be used to apply the new seed
mix and amendments to the landfill slopes. Until the slopes of the landfill are stabilized with grass, silt
socks may be installed around two open -throat catch basins and drop inlets that are located in the
perimeter ditch of the Subtitle D landfill to filter stormwater prior to entering the sedimentation basins.
The soils used from the County's older borrow pit to cover waste on the slopes or to backfill washouts
and erosion rills have primarily consisted of sandy soils and tend to erode during high intensity storm
events. The County is close to depleting the available soils from the older borrow pit and will likely be
transitioning to the new borrow pit by the end of the year or early 2021. Test pits completed in the new
borrow pit have identified cohesive soils (e.g., clay, silty clay, and sandy clay) that will be used for future
erosion or seep repairs on the slopes or for stormwater controls (e.g., berms) to reduce erosion from
high intensity storms.
Erosion Control Permits
The County has four active erosion control permits and per this letter are requesting that the permits be
consolidated into one active permit. Please provide guidance on what information is required to be
submitted to consolidate the permits. A list of the active erosion control permits is provided below.
• ONSLO-2018-007 Onslow County LCID Reclamation & Borrow Pit Expansion
• ONSLO-2016-010 Onslow County Subtitle D Landfill Phase 4
• Onslow-2003-260 Onslow County Landfill Borrow Pit Expansion
• Onslow-2008-302 Onslow County Subtitle D Landfill Phase III & Borrow Area Expansion
0

csmith
Mr. Brian Lamb
November 30, 2020
Page 5
These active permits are for the older borrow pit expansions, new borrow pit, the Phase 3 and 4 Subtitle
D landfill expansion construction projects, and the pending LCID landfill reclamation project. The active
permits listed above are requested to be consolidated under the ONSLO-2018-007 Onslow County LCID
Reclamation & Borrow Pit Expansion permit. The County will perform the necessary self -inspections and
maintain the appropriate records for the borrow pits and Subtitle D landfill. Inspections will also be
completed and documented for the LCID reclamation project once land -disturbance activities begin and
erosion control measures are installed.
If you have any questions or require additional information, please do not hesitate to contact me at
[phone] or by email at [e-mail].
Sincerely,
Daniel H. Forbes, PMP
CDM Smith Inc.
cc: Melissa Moore, Onslow County
Michael Russell, Onslow County
Aaron Weispfenning, CDM Smith
Martin Sanford, CDM Smith
is

Figures

North Closed Unlined
,�. Category 1 Landfill „
p
y�-
.t
South Closed
Unlined.Landfili.
I Legend
Outfall Location
I®
Notes:
1. VMF - Vehicle Maintenance Facility
Scale In Feet Figure 1: Outfall Location Map
CDM mmmmmmm:::= Onslow County Landfill
Smith 0 500 1000 Jacksonville, Onslow County, North Carolina

Tables

Table 1
Outfall Sampling Summary
Onslow County Solid Waste Facility
Outfall Code
Monitoring Period
BenchmarkValue
January -June 2018
Oxygen
Sample Date .
. Coliform Solids
,r,
r rr
30-May-18 339 6,000 414
July 2018
24-Jul-18 280 60,000
349 --
August 2018
No Discharge
September 2018
No Discharge
October 2018
No Discharge
November 2018
13-Nov-18 L 130 1 6,000 160 --
December 2018
No Discharge
January 2019
No Discharge
February 2019
13-Feb-19
7,100
6,000
120
-
March 2019
21-Mar-19
2,700
1 6,000
350
-
April 2019
No Discharge
May 2019
No Discharge
June 2019
No Discharge
July 2019
No Discharge
OutfaI1 2
August 2019
19-Aug-19 290NEF 6,000 76
September 2019
No Discharge
October 2019
No Discharge
November 2019
7-Nov-19
190
6,000
71
--
December 2019
9-Dec-19
150
6,000
26
January 2020
6-Jan-20
170
2,900
23
--
February 2020
10-Feb-20
970
>6,000
150
--
March 2020
26-Mar-20
1,300
-(7)
57
--
April 2020
No Discharge
May 2020
7-May-20
"0
600
22
--
June 2020
16-Jun-20
1,900
6,000
100
July 2020
16-Jul-20
810
3,000
32
--
August 2020
5-Aug-20
410
60,000
91
September 2020
10-Sep-20
250
267
5.8
--
October 2020
26-Oct-20
630
21,000
39
January 2018
12-Jan-18
434
>120,000
307
--
February 2018
No Discharge
March 2018
7-Mar-18 393 1 6,000 1 61.8 --
April 2018
No Discharge
May 2018
30-May-18 265 6,000 1 330 --
June 2018
No Discharge
July 2018
24-Jul-18 146 60,000 1 184 -
August 2018
No Discharge
September 2018
No Discharge
October 2018
No Discharge
November 2018
13-Nov-18 PE 170 J& 1 6,000 M 1 270 -
December 2018
No Discharge
January 2019
No Discharge
February 2019
13-Feb-19
0 36.0
1 18
-
March 2019
21-Mar-19
330 56.0
1 120
-
April 2019
No Discharge
May 2019
No Discharge
OutfaI1 3
June 2019
No Discharge
July 2019
No Discharge
August 2019
No Discharge
September 2019
No Discharge
October 2019
No Discharge
November 2019
18-Nov-19
220
6,000
120
-
December 2019
9-Dec-19
180
6,000
36
January 2020
6-Jan-20
190
1,800
47
--
February 2020
10-Feb-20
220
>6,000
190
--
March 2020
26-Mar-20
310
-(7)
160
--
April 2020
No Discharge
May 2020
7-May-20
140
267
19
--
June 2020
16-Jun-20
870
6,000
88
July 2020
16-Jul-20
450
4,000
56
--
August 2020
5-Aug-20
470
60,000
74
--
September 2020
21-Sep-20
600
60,000
94
--
October 2020
26-Oct-20
300
22,000
40
--
Smith Page 1 of 2

Table 1
Outfall Sampling Summary
Onslow County Solid Waste Facility
Notes:
1. mg/I - Milligrams per liter
2. ml - Milliliters
3. Outfalls 2 and 3 are sampled monthly for chemical oxygen demand, fecal coliform, and total suspended solids.
4. The Vehicle Maintenance Facility (VMF) Outfall is sampled semi-annually for oil and grease and total suspended solids.
S. (--) - Not analyzed
6. ND - Non -Detect
7. i)i - Samples were not analyzd for fecal coliform because the laboratory was not accepting fecal coliform at the time the samples were received.
0- Concentration exceeds the Benchmark Value
Smith Page 2 of 2

Appendix A

Division of Energy, Mineral & Land Resources
Stormwater Program
M National Pollutant Discharge Elimination System
Environmental REPRESENTATIVE OUTFALL STATUS (ROS)
nunlifii
FOR AGENCY USE ONLY
Date Received
Year
Month
Day
`.------- I IKEVU :a1 rvxlvl
If a facility is required to sample multiple discharge locations with very similar stormwater discharges, the
permittee may petition the Director for Representative Outfall Status (ROS). DEQ may grant Representative
Outfall Status if stormwater discharges from a single outfall are representative of discharges from multiple
outfalls. Approved ROS will reduce the number of outfalls where analytical sampling requirements apply.
If Representative Outfall Status is granted, ALL outfalls are still subject to the qualitative monitoring
requirements of the facility's permit —unless otherwise allowed by the permit (such as NCG020000) and DEQ
approval. The approval letter from DEQ must be kept on site with the facility's Storm water Pollution
Prevention Plan. The facility must notify DEQ in writing if any changes affect representative status.
For questions, please contact the DEQ Regional Office for your area (see page 3).
(Please print or type)
1) Enter the permit number to which this ROS request applies:
Individual Permit (or) Certificate of Coverage
N I C S I I I � ] I N I c G 11 2 0 0 2
2) Facility Information:
Owner/Facility Name OnslowCounty/Solid Waste Facility
Facility Contact
Street Address
City
County
Telephone No.
Melissa Moore
415 Meadowview Road
Jacksonville
Onslow
910 989-2107
State "C
E-mail Address
Fax:
ZIP Code 28540
[e-mail]
3) List the representative outfall(s) information (attach additional sheets if necessary):
Outfall(s) 1 is representative of Outfall(s) 2 and 3
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
Outfall(s) is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
Outfall(s) is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No ❑ No data*
❑ Yes
❑ No
❑ Yes
❑ No
❑ Yes
❑ No ❑ No data*
❑ Yes
❑ No
❑ Yes
❑ No
❑ Yes
❑ No ❑ No data*
*Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific
circumstances will be considered by the Regional Office responsible for review.
Page 1 of 3
SWU-ROS-2009 Last revised 12/30/2009

Representative Outfall Status Request
4) Detailed explanation about why the outfalls above should be granted Representative Status:
(Or, attach a letter or narrative to discuss this information.) For example, describe how activities and/or
materials are similar.
A compliance inspection was conducted by the Division of Water Quality on January 23, 2013, to evaluate the County'a request to remove Outfall 1 from the monitoring program and to ensure compliance with the General Permit.
Outfall 1 discharges stormwater runoff from the partially closed podian of the Subtitle D landfill. The partial closure, from bottom to top, consists of a minimum 12-inch thick intermediate ,it cover layer (,I,, serving as the cap liner system
subgrade), gas venting geocomposite drainage net (CDN), textured 40-mil linear low density polyethylene geomembrane, stormwater management CDN, a minimum 18-inch thick protacto. soil cover layer, and a mirlmum 6-Inch vegetative sail cover
layer. Based on the inspection results, the County was determined to be in compliance with the General Permit and granted representative ..Hall status for Outfall 1, which eliminated collecting stormwater samples semi-annually.
5) Certification:
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 Representative Outfall Status for my NPDES Permit. I understand that ALL outfalls are still
subject to the qualitative monitoring requirements of the permit, unless otherwise allowed by the permit
and regional office approval. I must notify DEQ in writing if any changes to the facility or its operations
take place after ROS is granted that may affect this status. If ROS no longer applies, I understand I must
resume monitoring of all outfalls as specified in my NPDES 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: Melissa Moore
Title: Solid Waste Director
(Signature of Applicant)
(Date Signed)
Please note: This application for Representative Outfall Status is subject to
approval by the NCDEQ Regional Office. The Regional Office may inspect your
facility for compliance with the conditions of the permit prior to that approval.
Final Checklist for ROS Request
This application should include the following items:
❑ This completed form.
❑ Letter or narrative elaborating on the reasons why specified outfalls should be granted representative
status, unless all information can be included in Question 4.
❑ Two (2) copies of a site map of the facility with the location of all outfalls clearly marked, including the
drainage areas, industrial activities, and raw materials/finished products within each drainage area.
❑ Summary of results from monitoring conducted at the outfalls listed in Question 3.
❑ Any other supporting documentation.
Page 2 of 3
SWU-ROS-2009 Last revised 12/30/2009

Representative Outfall Status Request
4) Detailed explanation about why the outfalls above should be granted Representative Status:
(Or, attach a letter or narrative to discuss this information,) For example, describe how activities and/or
materials are similar,
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5) Certification:
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 Representative Outfall Status for my NPDES Permit. I understand that ALL outfalls are still
subject to the qualitative monitoring requirements of the permit, unless otherwise allowed by the permit
and regional office approval. I must notify DEQ in writing if any changes to the facility or its operations
take place after ROS is granted that may affect this status, If ROS no longer applies, I understand I must
resume monitoring of all outfalls as specified in my NPDES 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: Matisse Moore
Title• solo roasts oo-e�tor
ar
(Signaltu—re of Applicant) (Date Signed)
Please note: This application for Representative Outfall Status is subject to
approval by the NCDEQ Regional Office. The Regional Office may inspect your
facility for compliance with the conditions of the permit prior to that approval
Final Checklist for ROS Request
This application should include the following items:
pd This completed form.
yQ Letter or narrative elaborating on the reasons why specified outfalls should be granted representative
status, unless all information can be included in Question 4.
X Two (2) copies of a site map of the facility with the location of all outfalls clearly marked, including the
drainage areas, industrial activities, and raw materials/finished products within each drainage area.
X Summary of results from monitoring conducted at the outfalls listed in Question 3,
X Any other supporting documentation.
Page 2 of 3
SWU-ROS-2009 Last revised 12/30l2009

Representative Outfall Status Request
Mail the entire package to:
NCDEQ DEMLR at the appropriate Regional Office (See map and
addresses below)
Notes
The submission of this document does not guarantee Representative Outfall Status (ROS) will be granted as
requested. Analytical monitoring as per your current permit must be continued, at all outfalls, until written
approval of this request is granted by DEQ. Non-compliance with analytical monitoring prior to this request
may prevent ROS approval. Specific circumstances will be considered by the Regional Office responsible for
review.
For questions, please contact the DEQ Regional Office for your area.
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
Washington Regional Office
943 Washington Square Mall
Phone [phone]
Washington, NC 27889
FAX [phone]
Phone [phone]
Fayetteville Regional Office
FAX [phone]
Systel Building,
225 Green St., Suite 714
Wilmington Regional Office
Fayetteville, NC 28301-5094
127 Cardinal Drive Extension
Wilmington, NC 28405
Phone [phone]
FAX [phone]
Phone [phone]
FAX [phone]
Mooresville Regional Office
610 East Center Ave.
Winston-Salem Regional Office
Mooresville, NC 28115
585 Waughtown Street
Winston-Salem, NC 27107
Phone [phone]
Phone [phone]
FAX [phone]
Water Quality Main FAX [phone]
Raleigh Regional Office
Central Office
1628 Mail Service Center
1612 Mail Service Center
Raleigh, NC 27699-1628
Raleigh, NC 27699-1612
Phone [phone]
Phone [phone]
FAX [phone]
FAX [phone]
Page 3 of 3
SWU-ROS-2009 Last revised 12/30/2009