NCG240012_Email Correspondance_20221003

Valentine, Thad
From: Valentine, Thad
Sent: Thursday, November 3, 2022 10:27 AM
To: [e-mail]; [e-mail];
[e-mail]
Subject: Site Visit Comments
Dan
I wanted to thank you and the other staff for their assistance at the site inspection with the City of Raleigh back on
October 12'h and to provide a couple additional comments for what I saw when I walked the site and that I will review
when I come back out for a stomwater inspection by the state. Please let me know if you have any questions
We did note in our walk through that outfall #1 is buried almost completely in the hill side where it outlets and one of
the parameters that has an exceedance is TSS. The fact that it's buried should easily identify that has a probable major
contributor to the exceedance and that should be noted in your SWPPP and as part of your Tier three response
investigative inspections. I suggest a close review of the Tier response requirements to get a clear recognition of where
you are in your Tier response duties for that and all the other sample point outfalls. I believe it's clear you're in Tier
three and you should respond accordingly to the State.
In our walk through we noted that outfall #5 was not being sampled in the correct place and that there where to
drainage areas that needed to be captured. One sample point was a pipe that drain an unknown portion of the site and
an overland drainage area that drained to the same area. We decided to pick up both drainage points (from the pipe and
the aboveground flow) from one area below the pipe, and that would be the new sample point. Please initiate that
change to the sample requirements at your next sample event.
Sample point #2 has a number of exceedances and is an issue that need to be addressed. It appears that sample point
has been plugged since our inspection, which is something I have reservations about its effectiveness and feasibility, but
I will review at my next inspection.
Finally, I noticed that there is sheet flow at an access road between the scrap metal facility and the facility below that is
also owned by the same company. That area will need to be added as a sample point by finding an area at that point
between the two properties to take a sample. The lower property has the same address and is listed as an LLC, but
onsite personnel indicated that it was owned by the same people. That property will need to apply for a stormwater
permit according to the industrial code it has and submit a notice of intent(NOI) for that facility as well. It's possible the
sample needed for that access area between the sites can be sampled from the lower facility owned by 2126 Garner
Road., LLC.
Please review my comment and respond with any questions you may have. I will inspect the scrap yard again in the near
future and look to see that the SWPPP has been updated correctly and that the tier response is being followed as
required. I will look for the NOI to be submitted within the next 30 days for the lower site and that my other
recommendations are being addressed.
Thanks for your courteous response to our site visit and I look forward to working with you to accomplish the goals for a
complaint facility
Thad Valentine
Environmental Senior Specialist — RRO
Division of Energy, Mineral, and Land Resources — Land Quality Section

Department of Environmental Quality
919 791 4220 office
thad.valentine(&ncdenr.ciov
1628 Mail Service Center, Raleigh, North Carolina 27699

Valentine, Thad
From: Valentine, Thad
Sent: Tuesday, November 1, 2022 2:52 PM
To: Jeltema, Stephen; Tosches, Meagan
Cc: Harcum, Justin; Poole, Zachary
Subject: RE: [External] NCG240012 - Yard Waste Center - Industrial NPDES Inspection
Meagan
I'm following up after the fact for our site visit and I wanted to comment from the State's point of view. I concur with
the City of Raleigh with the SWPPP recommendations and I will follow-up with a State inspection in he near future, but I
do have a couple additional comments from our visit.
We did note in our walk through that outfall #1 is buried almost completely in the hill side where it outlets and one of
the parameters that has an exceedance is TSS. The fact that it's buried should easily identify that has a probable major
contributor to the exceedance and that should be noted in your SWPPP and as part of your Tier three response
investigative inspections. I suggest a close review of the Tier response requirements to get a clear recognition of where
you are in your Tier response duties for that and all the other sample point outfalls. I believe its clear your in Tier three
and you should respond accordingly to the State.
In our walk through we noted that outfall #5 was not being sampled in the correct place and that there where to
drainage areas that needed to be captured. One sample point was a pipe that drain an unknown portion of the site and
an overland drainage area that drained to the same area. We decided to pick up both drainage points (from the pipe and
the aboveground flow) from one area below the pipe, and that would be the new sample point. Please initiate that
change to the sample requirements at your next sample event.
Sample point #2 has a number of exceedances and is an issue that need to be addressed. It appears that sample point
has been plugged since our inspection, which is something I have reservations about its effectiveness and feasibility, but
I will review at my next inspection.
Finally, I noticed that there is sheet flow at an access road between the scrap metal facility and the facility below that is
also owned by the same company. That area will need to be added as a sample point by finding an area at that point
between the two properties to take a sample. The lower property has the same address and is listed as an LLC, but
onsite personnel indicated that it was owned by the same people. That property will need to apply for a stormwater
permit according to the industrial code it has and submit a notice of intent(NOI) for that facility as well. Its possible the
sample needed for that access area between the sites can be sampled from the lower facility owned by 2126 Garner
Road., I.I.C.
Please review my comment and respond with any questions you may have. I will inspect the scrap yard again in the near
future and look to see that the SWPPP has been updated correctly and that the tier response is being followed as
required. I will look for the NOI to be submitted within the next 30 days for the lower site and that my other
recommendations are being addressed.
Thanks for your courteous response to our site visit and I look forward to working with you to accomplish the goals for a
complaint facility
Thad Valentine
Environmental Senior Specialist — RRO
Division of Energy, Mineral, and Land Resources — Land Quality Section
Department of Environmental Quality

919 791 4220 office
thad.valentine = ncdenr.gov
1628 Mail Service Center, Raleigh, North Carolina 27699
From: Jeltema, Stephen <[e-mail]>
Sent: Wednesday, October 26, 2022 3:56 PM
To: Tosches, Meagan <[e-mail]>
Cc: Harcum, Justin <[e-mail]>; Poole, Zachary <[e-mail]>; Valentine, Thad
<[e-mail]>
Subject: [External] NCG240012 - Yard Waste Center - Industrial NPDES Inpsection
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
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Meagan,
Thanks for meeting us to review the SWPPP and complete the site walk at the Yard Waste Center. We have compiled a
summary list of items discussed and recommendations on moving forward with your SWPPP and site management.
SWPPP
1. The SWPPP needs to be certified with a signature by Stan Joseph.
2. Please update the qualitative inspection language to reflect the required quarterly frequency requirement at all
outfalls.
3. Recommend updating training module to include all topics listed in Section B-12 of the permit.
4. Recommend adding a section to the permit to address the Solvent Management Plan requirement if Section 13-
10 if applicable.
S. Upon development, recommend adding a copy of your Tier II response or Tier III Action Plan to the SWPPP as
required.
Site Walk
1. Move all stored chemicals under cover and provide secondary containment for the storage area.
2. Move any scrap metal under cover.
3. Locate and clear the path to access outfalls for ponds along the east side of the site. These outfalls were
overgrown and difficult to locate during this site visit.
4. Recommend additional measures and groundcover on all denuded slopes upstream of YW-2A.
Lastly, due to the fact that there have been multiple exceedances over the past few sampling efforts, it would appear
that this facility is in either Tier 11 or Tier III status. I have copied NCDEQ on this email and understand that you will be
working with your consultant to develop an Action Plan to be submitted for their review. Please see the Tier II and Tier
III response requirements in Sections E-6 and E-7 of the permit and let us know if we can further assist as you move
forward with addressing these exceedances.
Stephen Jeltema
Engineer I
City of Raleigh
Engineering Services Department
Stormwater Management
127 West Hargett Street 18t" Floor
Raleigh, NC 27601
(p) 919-996-3961
(m) 984-265-9809
raleighnc.Qov