NCG200335_Monitoring Info_20101004

Pickle, Ken
From:
Sent:
To:
Cc:
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Attachments:
Pickle, Ken
Wednesday, July 02, 2014 4:37 PM
Bennett, Bradley; Georgoulias, Bethany
Ventaloro, Julie
RE: Raleigh Metals Recyclers > (7ic.9co i¢c8v�ss�iefl ZS
stormwater review.xlsx
My interpretation based on a quick look:
• Yes, for this too -small data set the numbers do seem to generally be dropping on outfalls 001, 002, and
006. That is, you could observe that the last two results are lower than the previous three results. However, 3
data points vs 2 data points is a pretty difficult data set to make any conclusions about, I think. I can't imagine
what action we would take based on this data set: there's not enough data to support any action, imo.
• Outfalls 003, 004, and 005 generally do not show improvement over time. Again, similar limitations make this
conclusion really just a guess. 3 data points vs 2 data points is just not enough in either case.
• Consider that one gross interpretation could be that we have 3 outfalls possibly better, and 3 seemingly worse
or unimproved. Similar to my earlier assessment, I think 3 outfalls vs. 3 outfalls is really inconclusive as far as
supporting any site -wide conclusions or action, imo.
Further:
• pH is not a problem
• Interpretation of the iron results is hampered by not having a benchmark. But 93, 56, 53, 72, and 44 mg/L are
suspicious to me.
• O&G: only 3 exceedances out of 29 measurements. Focus on other parameters, expect that measures
addressing those will address O&G exceedances.
• I suspect that the natures of the exposures are different in the different sub -drainage areas.
• All the subdrainage areas have problems with metals. Note that we have reason to be somewhat receptive to
arguments about copper and zinc being present in the natural soils of NC. But, when the data sets for Cd and Pb
are similarly present, I think we should initially discount any consideration that the Cu and Zn contributions are
presumptively natural background, and re -interpret that the presence of Cd and Pb suggest that industrial
activity may be the source for all the metals, including Cu and Zn. Not a difficult interpretation at a scrap metal
site, I think.
• Outfalls 003 and 005 seem to have less issues with TSS and COD (only one exceedance each.)
• Considering the monitoring results of the four metals with benchmarks: we have 106 exceedances out of 116
measurements since November 2013. Not encouraging.
I've highlighted in yellow the benchmark exceedances in the attached spread sheet so you don't have to.
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: [e-mail]
Website: http://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: Bennett, Bradley
Sent: Wednesday, July 02, 2014 10:09 AM
To: Georgoulias, Bethany; Pickle, Ken
Cc: Ventaloro, Julie
Subject: FW: Raleigh Metals Recyclers
Hey Guys,
Please take a look at the sampling results from Raleigh Metals. This is the project that we are working with Danny on
and that the City of Raleigh has been concerned with. Give me your thoughts on the numbers we are seeing here over
the last year. They have put some measures in place and it does look like some of the numbers have dropped in the last
two monitoring events.
F-11
Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1612 Mail Service Center Email: bradley.bennett(cDncdenr.gov
Ralelgh, NC 27699-1612 Web: http://Portal.ncdenr.org/web/Ir/stormwater
Email correspondence to and from this address may be subject to public records laws
From: Parnell, David
Sent: Wednesday, July 02, 2014 9:36 AM
To: Smith, Danny; Holley, John; Bolich, Rick
Cc: Bennett, Bradley
Subject: FW: Raleigh Metals Recyclers
Monitoring Lab Results came in yesterday from RMR.
Dave
From: Dan Nielsen[mailto:dnielsen(abmaaonline.com]
Sent: Tuesday, July 01, 2014 3:35 PM
To: Parnell, David
Cc: Bennett, Bradley
Subject: Raleigh Metals Recyclers
David,
The folks over at Raleigh Metals Recyclers forwarded me this summary of their stormwater monitoring laboratory
results. I believe you requested this during our meeting on Wednesday. I assume the DMRs were sent to NCDENR via the
'normal' submittal process. If that is not the case, please let me know and I will inquire with the site manager to
determine where they are.
Dan

Mid Atlar�i�c
h •erc.in i Yirx �:. �, r�neat lutrafit
Daniel H. Nielsen, PE, RSM, LEED-AP
Vice -President, Principal Engineer
MID -ATLANTIC ASSOCIATES, INC.
409 Rogers View Court I Raleigh, NC 27610
919-250-9918 1 919-250-9950 (Facsimile) 1 919-614-3988 (Mobile)
www.MAAONLINE.com 120-Years of service 1993 - 2013
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RALEIGH METALS RECYCLING
2 SID Car -nor e—oci
—lULEIGH, NORTH CAROLINA
STORMWATER MANAGEMENT PLAN
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PROJECT NUMBER:
DESIGNED BY:
DATE:
SPEC-13290
TON ALDRIDGE, PE
DECEMBER 2013
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MC..DAMS
2905 MERIDIAN PARKWAY
DURHAM, NORTH CAROLINA 27713
NC Lic. # C-0293

STORMWATER MANAGEMENT PLAN
UBACKGROUND INFORMATION
The Raleigh Metals Recycling site is located along Garner Road, approximately 0.70 miles north of
the intersection with Rush Street and Garner Road in Raleigh, North Carolina. The facility provides
services that include the collection, sorting, and exchange of scrap metal. As such, the facility is
covered by General Permit Number NCG200000. As a condition of this permit, a Stormwater
Pollution Prevention Plan (SWPPP) was developed by Golder Associates dated April 2013. In
summary, this plan provides a description of processes onsite and discusses implementation of
measures to be taken to minimize contaminants in runoff from the site. One component of the
SWPPP is a Stormwater Management Plan that addresses practices to be taken onsite to minimize
exposure of contaminated materials with stormwater runoff. These practices include storage
procedures and good housekeeping policies. On September 12, 2013, a Notice of Deficiency (NOD)
was issued by the North Carolina Division of Environmental and Natural Resources (DENR). Upon
review of further testing results, it was noted that additional exceedances of several other
benchmarks existed for Cadmium, Chemical Oxygen Demand (COD), Copper, Iron, Lead, Oil and
Grease, Total Suspended Solids (TSS), and Zinc. Noted in the NOD was that secondary containment
and general housekeeping appeared adequate. The exceedances are most likely a result of
uncontrolled sedimentation from the site. This report discusses measures taken since the NOD was
issued and further details stormwater measures that should be put into place to help control
sedimentary runoff.
The drainage patterns onsite as identified in the SWPPP, include six stormwater outfalls. These
outfalls are referenced throughout this report and are the same as those identified in the SWPPP.
Also provided is a brief explanation of the contributing drainage area to each of these outfalls. Please
reference the included maps that indicate each of these outfalls. For each outfall, the nine parameters
mentioned above were tested, each with a benchmark value that they are required to meet. The
facility currently does not exceed any pH or Oil and Grease benchmarks. However, many of the
other parameters are exceeded at each outfall. Both COD and TSS can be treated by incorporating
practices that allow for controlling sedimentation through the use of barriers, mats, settling, and
dispersion. Similar methods can be used to remove heavy metals and PCBs from the runoff since
most of these contaminants attach themselves to particles and are transported by the particles in
suspension. Thus, the most appropriate BMPs to control pollutants onsite will be those that minimize
release of contaminant laden. sediment.
It should be noted that at this time a Remedial Action Plan (RAP) has been submitted to the
Environmental Protection Agency for review. This RAP will provide measures that limit exposure of
surface runoff with the contaminated soils. These measures include amending the top layers of the
soil and installation of a protective barrier covering roughly half of the 17-acre site consisting of
geotextile fabric overlain by recycled concrete processed to resemble aggregate stone. The RAP also
calls for construction of a stormwater detention pond on the north side of the property. This plan
dated June 21, 2012 was prepared by Mid -Atlantic Associates, Inc. Implementation of these
measures is awaiting federal approval of this plan.
Raleigh Metal Recycling December 23, 2013
1111 Mc D M 1

9 EXISTING CONDITIONS
At the time of our site visit on October 18, 2013, several measures had already been taken by the
tenant to control contaminated sediment/oil from leaving the site. These measures included the
expansion of a small basin on the north side of the property, the construction of a small basin on the
west side of the site, and placement of booms. Additional handling and processing policies have
been put into place to avoid spills and contamination of the ground surface. Below is a brief synopsis
of the measures currently installed for each outfall along with testing data. Please reference the
attached map (EC-1).
Testing data for each outfall is provided below. This information is from testing by both
Environmental Conservation Laboratories, Inc. (ENCO) and Highlands Environmental Solutions,
Inc. (HES). The benchmark values shown below are from the SWPP and the North Carolina General
NPDES Permit # NCG 200000.
OUTFALL #1
The area draining to this outfall appears to be minimized to the parking lot at the northeast corner of
the properly and some roof drainage. Booms have been added to the outflow.
ENCO 6/7/2013 7.5 130 490 8.1 3.03 269 147 948
ENCO 11/1/2013 7.0 300 480 8.76 3.59 443 325 1250
Benchmark 6.0-9.0 120 100 30 1 7 30 67
OuTFALL #2
The drainage to this point is comprised of areas draining to the North Basin and some bypass along
the most northern portion of the site. It is estimated that about a third of the site drains to the North
Basin. The North Basin drainage includes runoff from the Fueling Area, Vehicle Processing Area,
Bailer, Non -Ferrous Area, and portions of the Ferrous Yard. This drainage is collected in a piped
system that discharges to a channel and ultimately enters the North Basin. Check dams have been
placed in the channel to help minimize sediment entering the basin. A turn -down elbow has been
recently installed on the upstream side of the outfall to minimize the amount of oil or floating debris
from being conveyed offsite. At the time of our inspection, it was noted that this basin had been
expanded and cleaned out. Several housekeeping improvements relating to storage and containment
of materials were made upstream that should help in minimizing pollutants coming into contact with
stormwater runoff. One such improvement was a relocation of storage from outside to inside for
electric motors and sealed units. Improvements to the bypass areas discharging to Outfall #2 were
made as well. These include the addition of gravel in high traffic areas to minimize the amount of
sediment runoff, removal of petroleum laden sediment, placement of booms upstream and
downstream of the outflow, and modifications to the gutter system of the maintenance building to
Raleigh Metal Recycling December 23, 2013
U S 2

avoid water flowing into and out of the building during storm events, adding to pollutant loads in
runoff.
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Sample ID
ENCO 6/7/2013
7.7
52
53
4.09
0.693
66.8
76.5
293
HES 10/10/2013
7.7
156
323
503
340
1100
ENCO 11/1/2013
8.1
270
850
10.1
8.62
994
785
2040
HES 11/27/2013
6.0
174
170
3.25
326
215
868
Benchmark
60-9.0
120
100
30
1
7
30 .
67
OuTFALL #3
The area draining to this outfall consists of primarily brush and grasses away from areas containing
metals. It. is unclear as to the extents of this drainage area, as the site subsurface drainage system is
undefined at this point. It may include a portion of the Ferrous Yard. A small channel discharges
water to the adjacent railroad at the northwest corner of the site. Small booms were added to the
outflows in this area.
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ENCO 6/7/2013 7.6 130 13 3.95 1.99 62.7 16.1 681
Benchmark 6.0-9.0 120 100 30 1 7 30 67
OUTFALL #4
The drainage area to this point is comprised of areas draining to the West Basin and some bypass to
the adjacent railroad. It is unclear as to the limits of the drainage area going to the West Basin, but it
is believed to mostly consist of the Shearing Unit, Metal Torching Area, and the Ferrous Yard. This
basin is lined with stone and discharges to the adjacent railroad. It also includes a turn -down elbow
to minimize the oil or debris from being conveyed offsite. It appeared that this basin discharged to
the adjacent railroad in the direction of Outfall #5. It is unclear as to the extent of this drainage area
(due to the same undefined drainage system), but as shown on the attached aerial map, there is a
limited amount of Wake County GIS information available for this outfall. The pipe exiting the
property discharges stormwater runoff to the adjacent railroad along the western portion of the site.
Booms have been installed on the pipe coming from the yard into the basin and on the pipe exiting
the property.
Raleigh Metal Recycling December 23, 2013
T D 3

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Sample ID
ENCO 6/7/2013
7.8
100
2.8
3.28
2.32
32.9
6.3
843
HES 11/27/2013
5.5
177
13
3.33
66
38
1240
Benchmark
6.0-9.0
120
100
30
1"
7
30
67
OUTFALL #5
The area draining to this outfall mostly consists of the Metal Torching Area and Ferrous Yard. At the
time of initial testing, turnings soaked with petroleum were stored in the southwest corner of the site.
These have since been removed. Booms have been installed in the outflow.
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Sample ID
ENCO 6/7/2013 8
43
3.2
2.05
65.1
7.1
189
Benchmark 6.0-9.0
120
100
30
1
7
30
67
OuTFALL #6
It is unclear as to the extents of this drainage area. It is believed to include a portion of the Ferrous
Yard, Scales, and parking area at the southeast corner of the site. This outfall is also identified on the
Wake County GIS information provided on the aerial map. The pipe exiting the property discharges
stormwater runoff into the existing storm drainage system in Garner Road. A channel lined with
stone has been constructed to minimize sediment transport. Additionally, small booms have been
placed around the inlet draining into this system.
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Sample ID
ENCO 6/7/2013
8.2
200
680
8.74
5.96
932
571
1740
ENCO 11/1/2013
8.6
350
1400
3.67
0.36
1730
1230
3650
Benchmark
6.0-9.0
120
100
30
1
7
30
67
Raleigh Metal Recycling December 23, 2013
N MCADAMS 4

9 STORMWATER MANAGEMENT PLAN — PHASE I
This initial phase of stormwater management onsite is intended to expand upon measures already
taken to improve sediment capture onsite. These measures are intended to be implemented quickly
and are also considered temporary until the final stormwater management plan for the site is
approved and/or developed. Once these measures are in place, additional testing will be completed to
monitor how the Phase I practices are working. At that time review of the testing data may show that
additional measures are necessary (i.e. Phase II). Please reference the included Phase I map (SW-1)
for additional information. One of the main goals of Phase I is to determine conclusively the
drainage areas to each of the outfalls, and locating all subsurface drainage and inlets. Once the
drainage boundaries are known conclusively to each outfall, it will be possible to tailor the
stormwater management to the drainage area of the outfall.
OUTFALL #1
The extents of this drainage area as shown on the attached map are believed to be fairly accurate.
Where possible, inlet protection should be placed around each inlet in accordance with the North
Carolina Erosion and Sedimentation Control Manual. This will help to minimize the COD and TSS
loading to the benchmark values. To address the heavy metal pollutants, the placement of a
polyacrylamide (Floc Logs® by Applied Polymer Systems or an approved equivalent) is
recommended at each inlet. A data sheet for the Floc Log product is provided at the end of this
report. It is also recommended that silt fence be installed on the north side of the parking lot to
minimize any sediment laden water from flowing to downstream properties.
OUTFALL #2
As part of Phase I, it is recommended that further exploration into the exact drainage area for this
outfall be provided. Based on the testing results it appears that the North Basin is providing adequate
COD and TSS removal. To address the heavy metal pollutants, the placement of a couple Floc
Logs® is recommended in each of the ditches draining to the basin. It is also recommended that silt
fence be installed on the north side of the site to minimize any sediment laden water from flowing to
downstream properties.
OUTFALL #3
As part of Phase I, it is recommended that further exploration into the exact drainage area for this
outfall be provided. To aide in the removal of COD and TSS, check dams or waddles are
recommended in the existing ditch. To address the heavy metal pollutants, the placement of a couple
Floc Logs® is recommended in the ditch draining to the outfall. It is also recommended that silt
fence be installed on the west side of the site to minimize any sediment laden water from flowing to
downstream properties.
OUTFALL #4
As part of Phase I, it is recommended that further exploration into the exact drainage area for this
outfall be provided. Where possible, inlet protection should be placed around each inlet draining to
this outfall. This will help to minimize the COD and TSS loading to the benchmark values. To
address the heavy metal pollutants, the placement of a Floc Log® is recommended at each inlet. It is
Raleigh Metal Recycling December 23, 2013
E[ DM 5

also recommended that silt fence be installed on the west side of the site to minimize any sediment
laden water from flowing to downstream properties.
OuTFALL #5
As part of Phase I, it is recommended that further exploration into the exact drainage area for this
outfall be provided. Based on the testing results it appears that the West Basin is providing adequate
COD and TSS removal. To address the heavy metal pollutants, the placement of a Floc Log® is
recommended at each inlet contributing to the drainage to the basin. It is also recommended that silt
fence be installed on the west side of the site to minimize any sediment laden water from flowing to
downstream properties.
OUTFALL #6
As part of Phase I, it is recommended that further exploration into the exact drainage area for this
outfall be provided. Where possible, inlet protection should be placed around each inlet draining to
this outfall. This will help to minimize the COD and TSS loading to the benchmark values. To
address the heavy metal pollutants, the placement of a Floc Log® is recommended at each inlet. For
Outfall #6, we suggest that this phase of the study determine whether or not to redirect discharge to a
different location, one that is better suited for installation of a BMP.
In addition to the data sheet for the Floc Logs®, details for the silt fence, inlet protection, and check
dams are provided.
A key component in the functionality of all of the stormwater measures mentioned above is
maintenance. It is recommended that each of the practices provided be inspected monthly or after
each significant rainfall. Sediment shall be removed in each of the basins routinely and disposed of
properly.
The facility shall continue monitoring at each outfall as outlined in the NPDES General Permit
Number NCG200000. This additional testing shall be provided to the civil engineer to determine
how the data is trending and will be helpful in determining what BMPs and measures taken onsite
are working to control the contaminated runoff.
Raleigh Metal Recycling December 23, 2013
UMCADAMS 6

STORMWATER MANAGEMENT PLAN — PHASE II
This phase of stormwater management is intended to serve as an ultimate/final remediation plan.
Once additional drainage area and testing data are received as part of the Phase I plan and approval
of the RAP is received, modification or additions. to the stormwater management plan will be
evaluated. We anticipate this might include expansion/addition of larger traditional stormwater
facilities (i.e. dry detention basins or wet ponds). The extent of Phase II cannot be clearly defined
until the drainage boundaries to each of the outfalls are determined and installation of measures
proposed in the RAP are complete, since the stormwater treatment facilities will be designed
specifically for each drainage area.
Raleigh Metal Recycling December 23, 2013
E�

9 STORMWATER MANAGEMENT PLAN SCHEDULE
The suggested plan of action by the client is as follows:
• Installation of perimeter silt fence, check dams, inlet protection, and Floc Logs as detailed on the
provided Phase I plan. Upon receipt of the draft of this document on December 10, 2013, the
client began installation of several of these measures.
Estimated completion — 21112014
• Determination of onsite drainage systemsiboundaries by survey, smoke testing, video camera, or
other means.
Estimated completion — 21112014
Continued monitoring at each outfall to determine whether further modifications to the proposed
stormwater management plan is required. If the site is not reaching compliance as required in the
NPDES General Permit, additional measures may need to be taken.
Estimated completion — Ongoing
• Installation of protective barrier and stormwater management pond as outlined in the RAP.
Estimated completion —12 months after final approvals by USEPA and NCDENR
• Evaluation of effectiveness of protective barrier and stormwater management pond.
Estimated completion — 6 months after completion of installation
Raleigh Metal Recycling December 23, 2013
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S 700 Series Floc Logs°
Polyacrylamide Sediment and Turbidity Control Applicator Logs
APS 700 Series Floc Logs are a group of soil -specific tailored log -blocks that contain blends
of water treatment components and polyacrylamide co -polymer for water clarification. They reduce and
prevent fine particles and colloidal clays from suspension in stormwater. There are several types of Floc
Logs designed to treat most water and soil types. Contact Applied Polymer Systems, Inc. or your local
distributor for free testing and site -specific application information.
Primary Applications
• Mine tailings and waste pile ditches
• Stormwater drainage from construction and building sites
• Road and highway construction runoff ditches
• Ditch and treatment system placement for all forms of highly turbid waters (less than 4% solids)
• Dredging operations as a flocculent
Features and Benefits
• Removes solubilized soils and clay from water
• Prevents colloidal solutions in water within ditch systems
• Binds cationic metals within water, reducing solubilization
• Binds pesticides and fertilizers within runoff water
• Reduces operational and cleanup costs
• Reduces environmental risks and helps meet compliance
Specifications / Compliances
• ANSI/NSF Standard 60 Drinking water treatment chemical additives
• 48h or 96h Acute Toxicity Tests (D. magna or O. mykiss)
• 7 Day Chronic Toxicity Tests (P. promealas or C. dubia
APS 700 Series Floc Logs are packaged in boxes of four (4)
Technical Information
Appearance - semi -solid block
Biodegradable internal coconut skeleton
Percent Moisture - 40% maximum
pH 0.5% Solution - 6-8
Shelf Life — up to 5 years when stored out of UV rays

11 �i , ijiii
Placement
Floc Logs are designed for placement within ditches averaging three feet wide by two feet deep. Floc log
placement is based on gallon per minute flow rates. Note: actual GPM or dosage will vary based on site
criteria and soil/water testing.
Directions for Use
(Water and Floc Log Mixing is Very Important!)
APS 700 Series Floc Logs should be placed within the upper quarter to half of a stabilized ditch system or
as close as possible to active earth moving activities. Floc Logs have built in ropes with attachment loops
which can be looped over stakes to ensure they remain where placed. Mixing is key! If the flow rate is
too slow, adding sand bags, cinder blocks, etc., can create the turbulence required for proper mixing.
Floc Logs are designed to treat dirty water, not liquid mud; when the water contains heavy solids
(exceeding 4%), it will be necessary to create a sediment or grit pit to let [lie heavy solids settle before
treating the water.
Floc Logs must not be placed in areas where heavy erosion would result in the Floc Logs becoming
buried. Where there is heavy sedimentation, maintenance will be required.
APS 700 Series Floc Logs can easily be moved to different locations as site conditions change. Water
quality will be improved with the addition of a dispersion field or soft armor covered ditch checks below
the Floc Log(s) to collect flocculated particulate. Construction of mixing weirs may be required in areas
where short ditch lines, swelling clays, heavy particle concentrations, or steep slopes may be
encountered.
Latex or rubber gloves are recommended for handling during usage. Use soap and water to wash hands
after handling.
Precautions / Limitations
• APS 700 Series Floc Logs are extremely slippery when wet.
• Clean up spills quickly. Do not use water unless necessary as extremely slippery conditions will
result and if water is necessary, use pressure washer.
• APS Floc Log will remain viable for up to 5 years when stored out of UV rays.
• APS 700 Series Floc Logs have been specifically tailored to specific water and soil types and
samples must be tested. Testing is necessary and is free.
• For product information, treatment system design assistance, or performance issues, contact Applied
Polymer Systems.