NCG120104_GWS-Hwy 49 C&D LF-SW Action Plan_20230622

STORMWATER TIER III
ACTION PLAN
Prepared For:
GREENWAY WASTE SOLUTIONS OF HARRISBURG, LLC
HIGHWAY 49 C&D LANDFILL
2105 SPEEDRAIL CT
HARRISBURG, NC 28025
Prepared By:
CIVIL & ENVIRONMENTAL CONSULTANTS, INC.
CHARLOTTE, NC 28273
CEC Project 326-441
JUNE 2023
I
i ,'i'__ _
Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive, Suite 400 1 Charlotte, NC 28273 1 p: 980-237-0373 f: 980-237-0372 1 www.cecinc.com

TABLE OF CONTENTS
1.0 INTRODUCTION.............................................................................................................. I
2.0 TIER III STATUS.............................................................................................................2
2.1 Benchmark Exceedances........................................................................................ 2
3.0 STORMWATER MANAGEMENT INSPECTION.......................................................3
3.1 Identification of the Source(s) of Exceedances...................................................... 3
4.0 STORMWATER MANAGEMENT ACTIONS.............................................................5
4.1 Actions and Schedule.............................................................................................. 5
4.1.1 Stormwater BMP Maintenance Schedule................................................5
4.1.2 Immediate Actions.....................................................................................6
4.1.3 Current and Future Actions.....................................................................6
4.1.4 Monitoring Plan.........................................................................................7
FIGURES
Figure 1 Hwy 49 Stormwater Drainage Area Plan
APPENDICES
Appendix A Stormwater BMP Maintenance Schedule
Civil & Environmental Consultants, Inc. -i- GWSH—SW Action Plan
June 2023

1.0 INTRODUCTION
The following characterizes Tier III and details the associated requirements for facilities that have
reached this status.
a) Facilities with Tier III status have had four consecutive sampling results above the
benchmark values or outside of the benchmark range as detailed in the stormwater permit.
Facilities remain in Tier III status until three consecutive samples are below the benchmark
values or within the benchmark ranges.
b) If any four sampling results within the permit term for any single parameter are above the
benchmark value at a sampled outfall, then the permittee shall respond in accordance with
Table 5 of the general stormwater permit to identify and address the source of exceedances
for that parameter at that outfall.
c) The permittee shall prepare a written Action Plan and submit to the Division's Regional
Office for review and approval within thirty days of receipt of the fourth analytic
monitoring data point that exceeds the benchmark value. At a minimum, the Action Plan
shall include:
i. Documentation of the four benchmark exceedances,
ii. An inspection report that covers the industrial activities within the drainage area of
the outfall with the exceedances (including the date of the inspection and the
personnel conducting the inspection),
iii. An evaluation of standard operating procedures and good housekeeping procedures,
iv. Identification of the source(s) of exceedances,
V. Specific actions that will be taken to remedy the identified source(s) with a schedule
for completing those actions, and
vi. A monitoring plan to verify that the Action Plan has addressed the source(s).
d) The permittee shall keep the Action Plan in the SWPPP and document when each specific
action was carried out and by whom.
e) The permittee shall contact the Division's Regional Office when all actions in the Action
Plan are completed.
Civil & Environmental Consultants, Inc.
-1-
GWSH — SW Action Plan
June 2023

2.0 TIER III STATUS
2.1 BENCHMARK EXCEEDANCES
The following table details the benchmark exceedances as compared to the General Stormwater
Permits, NCG120000 covering general landfill operations and NCG240000 covering composting
operations as they have occurred.
Tier III: Dates of Exceedance and Concentrations Per Basi
Pollutant
BMV
2
3
4 (Compost)
COD
120
12/23/19:185
(NCG12)
mg/L
12/16/20:198
12/22/22: 138
1,000
-Am
12/16/20: 6,000
ColFecal
rm
/100
12/22/22:1,700
FC)
(FC)
mL
3/10/23: >6,000
(NCG12)
12/16/20: 208
12/23/19: 284
TSS
100
12/22/22: 360
12/16/20: 523
(NCG12)
ug/L
2/17/23:449
12/22/22:185
3/10/23: 290
12/23/19: 76.7
Cu
7 ugh
12/16/20: 112
(NCG24)
12/22/22: 53.1
2/17/23: 10.3
Pb
30 ug/L
(NCG24)
Zn
67 ug/L
(NCG24)
Civil & Environmental Consultants, Inc.
-2-
GWSH — SW Action Plan
June 2023

3.0 STORMWATER MANAGEMENT INSPECTION
Civil and Environmental Consultants, Inc. (CEC) was contracted by Greenway Waste Solutions,
LLC to perform a stormwater management inspection of the landfill property and its operations in
order to assist in the development of actions to address the pollutants impacting specific outfalls
leading to Tier III status.
CEC performed a stormwater inspection on May 30, 2023 and was accompanied by Mr. Brandt
Kayser of Greenway Waste Solutions. The following table presents the details and observations
made during the inspection.
Location
Observations
MU
2
3
4
Basin
in Relation
BMPs
to Landfill
1
Western-
Channels/
Stormwater
Stormwater
Most
Ditches,
Overgrown
velocity
Evidence
control
2
SSW
Rip -Rap
vegetation,
reduction,
of
measures
3
South
Check
Dams, Rip-
standing
water, and
energy
dissipation,
significant
wildlife
at mulch
storage
4
NW
5
WNW
Rap Pond
Check
Dams,
stormwater
control
measure
filtration,
and retention
features can
populations
habituating
the entire
piles and
composting
windrows
6
SE
7
NE
Vegetative
impact.
be enhanced.
property.
can be
Buffers
enhanced.
3.1 IDENTIFICATION OF THE SOURCE(S) OF EXCEEDANCES
This section addresses what are believed to be the sources of the benchmark exceedances at the
landfill property as follows.
1. The soils at the site are silt -like and are highly erodible. These soils impact the stormwater
basins and create challenges where maintenance is concerned. Due to the soil type and
constant maintenance requirements to control the soils, all of the stormwater basins are
impacted and it takes time to address the soil that migrates around the site. As routine
maintenance activities address the soils, the basins have exhibited periods of significant
Civil & Environmental Consultants, Inc. -3- GWSH—SW Action Plan
June 2023

vegetative growth, standing water, and settling feature impacts. At first glance, it appears
that the stormwater drainage areas and basins as observed require maintenance. Upon
closer inspection, it is believed that a revision in the site's approach to routine maintenance
activities is needed and should address the issues as they occur at the site. In addition and
as part of revised maintenance activities, some minor changes to the basins' inlet and outlet
structures will increase their ability to work more efficiently and effectively through
enhancement of energy dissipation, filtration, and retention features.
2. Wildlife populations are present in abundance as evidenced by tracks and scat. Wildlife is
most certainly contributing to fecal coliform issues along with stagnation of stormwater
and vegetative growth within the basins, all of which can contribute to elevated
concentrations of fecal coliform within the basins.
3. This property's surface soil type is characterized as highly erodible and was observed
throughout the base area of the landfill site with considerable build up within site drainage
features and the stormwater basins. The slope erosion measures and drainage channels
appeared to be ineffective and in need of maintenance. It appeared that there is a stormwater
velocity issue that, when combined with the soil type/characteristics, is contributing to
erosion and ultimately to elevated TSS concentrations in the site's stormwater discharge.
4. It was observed that mulch storage piles and composting operations were being performed
in the open windrows. Changes similar in nature as those stated in number 1 above,
regarding changes to the routine maintenance that is performed on stormwater control
measures in this area to increase the effectiveness of these features that are in place. The
practice is potentially impacting the Tier III status at select outfalls.
Civil & Environmental Consultants, Inc.
-4-
GWSH — SW Action Plan
June 2023

4.0 STORMWATER MANAGEMENT ACTIONS
This section details the specific actions that will be taken to remedy the identified sources of the
benchmark exceedances along with a schedule for completing the actions.
4.1 ACTIONS AND SCHEDULE
The observations made during the stormwater management inspection were similar for all of the
stormwater basins and outfalls. CEC's recommendation was to address the issues from a site -wide
perspective through key changes to the routine maintenance activities that are performed at the
site. All of the observed issues appeared such that modifications to the routine maintenance
activities should increase and enhance the efficiency and effectiveness of the site's stormwater
control features. To address this, the site's Stormwater (SW) Best Management Practice (BMP)
Maintenance Schedule has been modified to assist in enhancing the site's stormwater control
features that are ultimately related to the identified sources of stormwater issues. The modified
maintenance schedule should ensure that ongoing routine maintenance of SW BMPs is efficient
and effective.
4.1.1 Stormwater BMP Maintenance Schedule
The SW BMP Maintenance Schedule is broken into five frequency categories as follows:
• Constant: Applies to BMP features that require constant maintenance for BMP
effectiveness.
• Every 2 Weeks: Applies to BMPs where landfill operations and stormwater impacts the
BMPs requiring frequent attention.
• Monthly: Applies to BMPs that require moderate maintenance activity for effectiveness.
• Quarterly: Applies to those BMPs that require less frequent maintenance activities for
effectiveness.
Civil & Environmental Consultants, Inc.
-5-
GWSH — SW Action Plan
June 2023

• Every 6 Months: Applies to BMPs that either don't require frequent maintenance activities
for effectiveness or the scale of the maintenance activities is such that there is a significant
effort involved to repair and/or return the BMP to its fully functioning form once again.
The Stormwater BMP Maintenance Schedule is included as Appendix A.
4.1.2 Immediate Actions
The following actions are established to identify and address those actions requiring immediate
attention.
1. Per permit NCG120000 and NCG240000 terms and conditions, implementation of
monthly stormwater monitoring shall be implemented immediately and continue until three
consecutive results are below the benchmark values or within the benchmark range.
2. Per the permit terms and conditions, notification in writing is required to be made to the
NCDEQ Regional Office within two weeks of Tier III attainment. The due date of the
notification was inadvertently overlooked. Greenway Waste Solutions, LLC recognizes the
importance of managing the stormwater in relation to their activities and is thereby,
submitting this Stormwater Action Plan simultaneously with written notification to the
NCDEQ Regional Office of the attainment of Tier III status to rectify the situation. Many
of the actions cited in this Plan are either already completed or are underway.
4.1.3 Current and Future Actions
The following table presents the current and future actions and associated schedule for completion.
Issue
Action
Schedule
Property stormwater control
Modify and implement
features general maintenance
modified SW BMP
Completed.
can be enhanced.
Maintenance Schedule.
Civil & Environmental Consultants, Inc.
-6-
GWSH — SW Action Plan
June 2023

Issue
Action
Schedule
Overgrown vegetation,
Mow the perimeters of the
standing water, and
basins and remove vegetation
Complete within one month
stormwater control measure
from within the basins where
of 6/15/2023.
maintenance activities can be
not included in original basin
enhanced.
design.
Modified BMP maintenance
schedule includes more
Stormwater velocity
dynamic repair/ replacement
reduction, energy dissipation,
of rip -rap check dams
Complete within two months
filtration, and retention
throughout the property.
of 6/15/2023.
features can be enhanced.
Install check dams in
locations where it is evident
that changing site conditions
require their construction.
Per the modified maintenance
schedule, mow the perimeters
of the basins and remove
vegetation from within the
Evidence of significant
basins where not included in
wildlife populations
original basin design. This
Complete within one month
habituating the entire
won't solve issues
of 6/15/2023.
property.
attributable to wildlife but
should aid in decreasing the
populations' residence time
within the immediate basin
areas.
Per the modified maintenance
Stormwater control measures
schedule, modify controls to
at mulch storage piles and
include barriers and filtration
Complete within one month
composting windrow
BMPs around the mulch piles
of 6/15/2023.
operations can be enhanced.
and composting windrows to
separate the organic materials
from stormwater.
4.1.4 Monitoring Plan
The following table presents Greenway Waste Solutions' monitoring plan for verification that this
Action Plan has addressed the stormwater management issues.
Civil & Environmental Consultants, Inc.
-7-
GWSH — SW Action Plan
June 2023

Issue
Action
Schedule
Perform Stormwater
All — Monitoring Plan
Management Inspections to
Monthly, beginning one
gauge effectiveness of this
month from 6/15/2023.
Action Plan.
Revisit SW BMP
Maintenance Schedule and
revise in accordance with the
Monthly, beginning one
All — Monitoring Plan
effectiveness of each
month from 6/15/2023.
maintenance activity and
monthly stormwater sample
analytical results.
Civil & Environmental Consultants, Inc. _g_ GWSH—SW Action Plan
June 2023

FIGURE
HWY 49 STORMWATER DRAINAGE AREA PLAN

h
0
N
0
0
E

APPENDIX A
STORMWATER BMP MAINTENANCE SCHEDULE

Greenway Waste Solutions, LLC
C&D Landfill and Composting Operations
Stormwater BMP Maintenance Schedule
Pond
Dry Detention Ponds
Wet Ponds
Other Feature
Place rip -rap around and under inlet structures to ponds.
Place rip -rap around and under inlet structures to ponds.
NA
Constant
Place rip -rap around and under pond skimmer arms.
NA
NA
Install rip -rap check dams on pond bottoms (min. 2/pond).
install rip -rap check dams (min. 2/pond) on pond bottoms.
Construct rip -rap check dams along swales and ditches.
NA
Inspect and repair swales/ditches impacted by erosion. Install rip -rap, etc. where
required.
Every 2 Weeks
Debris shall be removed from blocking inlet and outlet structures and from
s shall be removed from blocking inlet and outlet structures and from areas
Lofpotential
Remove debris from swales and ditches to prevent from washing into ponds or
areas of potential clogging.
clogging.
clogging ditches.
Check and clear all inlet and outlet orifices of any obstructions.
Check and clear all inlet and outlet orifices of any obstructions.
Check and clear all inlet and outlet orifices of any obstructions.
Check the side slopes; remove trash, repair eroded areas before the next
Check the side slopes; remove trash, repair eroded areas before the next rainfall
Check the side slopes; remove trash, repair eroded areas before the next rainfall
rainfall event and reseed if necessary.
event and reseed if necessary.
event and reseed if necessary.
Clean and replace rip -rap check dams in drainage swales/ditches around the
Clean and replace rip -rap check dams in drainage swales/ditches around the
Inspect and repair ditch/channel/swale erosion. Add rip -rap where necessary.
ponds.
ponds.
Monthly
Clean and replace rip -rap check dams at pond inlets and on pond bottoms.
Clean and replace rip -rap check dams at pond inlets and on pond bottoms.
Clean and replace rip -rap check dams in drainage swales/ditches.
No woody vegetation shall be allowed to grow on the embankment without
No woody vegetation shall be allowed to grow on the embankment without
No woody vegetation shall be allowed to grow on the embankment without special
special design provisions.
special design provisions.
design provisions.
Vegetation shall be maintained at a height of 4" - 8" unless part of planned
Vegetation in and around the basin shall be maintained to a distance of 16 feet
Vegetation shall be maintained to a distance of 6 feet and to a height of 4" - 8"
landscaping, special design provisions.
and to a height of approximately 8" to 16".
unless part of planned landscaping, special design provisions.
Periodic removal of dead vegetation shall be accomplished.
Periodic removal of dead vegetation shall be accomplished.
NA
Ensure features are structually sound, free from erosion, and functioning as
Ensure features are structually sound, free from erosion, and functioning as
Ensure features are structually sound, free from erosion, and functioning as
designed. Inspect the collection system (ponds, piping, grassed swales) for
designed. Inspect the collection system (ponds, piping, grassed swales) for
designed. Inspect the collection system (grassed swales, ditches) for proper
Quarterly
proper function.
proper function.
function.
Repair pond inlet pipes due to undercutting, replace rip -rap, and repair
Repair pond inlet pipes due to undercutting, replace rip -rap, and repair broken
Repair under -road culvert pipes due to undercutting, replace rip -rap, and repair
broken pipes.
pipes.
broken pipes.
Reseed grass swales twice a year as necessary Reseed grass swales twice a year as necessary
Reseed grass swales twice a year as necessary
Check the pond depth at various points in the pond. If the depth is reduced
Check the pond depth at various points in the pond. If the depth is reduced to
Check the swales and ditches depth at various points in the swales and ditches. If
to 50% of original design depth, sediment will be removed to at least design
50% of original design depth, sediment will be removed to at least design depth.
the depth is reduced to 25 % of original design depth, sediment will be removed to
Every 6 Months
depth.
at least design depth.
Sediment to be removed when 50% of forbay volume is filled and/or when
Sediment to be removed when 50% of forbay volume is filled and/or when 20%
Sediment to be removed from swales and ditches when —20% of original design
20% of the permanent pool volume is filled.
of the permanent pool volume is filled.
depth is filled.