NCG120057_Tier 1 Notification_20231207

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MUNICIPAL ENGINEERING ? INC .
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vi 68 SHIPWASH DRIVE, GARNER, NO 27529 - PHONE: [phone]
P.O. Box 349, B❑❑NE, NO 28607 - PHONE: [phone]
C�h/ E E� LICENSE NUMBERS: F-081 2 & 0-586
December 7,2023
Ms.Tamera Eplin
Regional Engineer
450 West Hanes Mill Rd.Ste 300
Winston Salem,NC 27105
Re: Stormwater Permit Exceedance Notification and Tier One Documentation(FC at SDO-1 and TSS at SDO-3)
Ashe County Landfill
Permit No.NCG120057
Permit Period Benchmark Exceeded:2023 Period 4
Dear Ms.Eplin:
The analytical results of stormwater samples collected at the Ashe County Landfill on November 21, 2023 contained levels of fecal
coliform(FC)in sample SDO-1 at>6,000 colonies per 100ML which is above the benchmark outlined in NCG120000(1,000 colonies
per 100 ml). TSS was also found in sample SDO-3 at 53.6 mg/L which is above the benchmark value applicable to ORW surface
water(50 mg/L)(eDMR form will be filed separately). In response to these exceedances a Tier 1 response was initiated.This Tier 1
response documents findings of a site inspection and fulfills the requirement to notify the NCDEMLR Winston Salem Regional office
of the exceedances.
The laboratory results were reported on November 28,2023 and a Tier One response was initiated within two weeks in fulfillment of
the permit requirements. Mr.Scott Hurley,Ashe County Solid Waste Director,reported that he and his staff immediately(November
29, 2023)performed a comprehensive stormwater management field inspection of the drainage area leading to SDO-1 and SDO-3.
During the inspection,possible causes of the exceedances were evaluated.
Fecal Coliform in SDO-1
The suspected source of FC as found in sample SDO-1 is believed to originate from animal excrement,which was plainly visible in
large quantities in and around the largest stormwater basin,and not industrial activities. Eradication of indigenous animals and birds
would be the most effective corrective action which is not feasible,practical or lawful per Ashe County Code of Ordinance§ 32.13
(A). Fecal coliform was not detected in a raw leachate sample collected from the invert to the lined lagoon on October 21, 2021
which strengthens the ascertain the observed FC did not originate from a leachate release. This document will serve as the record
keeping component of the Tier One requirement. Specific courses of action to reduce FC levels were discussed by MESCO staff.
Since evidence suggests that the source of FC is not industrial activities corrective actions are largely unwarranted,hence will not be
implemented at this time.
TSS in SDO-3
At the time of sampling SDO-3 received stormwater originating from inactive lined landfill phase 2, active lined Phase 4, closed
unlined landfill,and an animal shelter. During the inspection SDO-3 drainage area was identified to only contain"non-contaminated
stormwater". The term "noncontaminated stormwater" is defined in 40 CFR 445.2 as "stormwater which does not come in direct
contact with landfilled waste,the waste handling and treatment areas,or landfill wastewater."Non-contaminated stormwater includes
stormwater which"flows off the cap, cover, intermediate cover, daily cover, and/or final cover of the landfill."(Reference:40 CFR
445.2.). No waste was exposed,no erosion features or other nonconformities in the cover,permanent vegetation is established and
no signs of past leachate breakouts leading towards either outfall were observed. The majority of stormwater that drains to SDO-3
originates from the drainage area south of the landfill which has not accepted waste in several years. Stormwater in this area is
controlled by a riser/skimmer basin which is temporary and will be removed with the development of the next landfill(Phase 3)which
is planned within the next year. The basin was closely evaluated and although it appears clear water is discharging through the barrel
Ashe County has elected to perform maintenance on the basin in an effort to improve stormwater clarity.
Ashe County remains committed to safe-guarding the environment and will continuously evaluate storm-water conditions and respond
accordingly.Please contact Mr.Scott Hurley(permit owner)or Jonathan Pfohl(consultant)with any questions or comments.
Sincerely,
MUNICIPAL ENGINEERING,INC.
Jonathan Pfohl
[phone]
[e-mail]
cc: Scott Hurley-Ashe County(336)846-3721 [e-mail],Kathy Weaver-Ashe County
X.S.Environmental Protection Agency."Final Reissuance of National Pollutant Discharge Elimination System(NPDES)Storm Water Multi-Sector General Permit for Industrial Activities."
68 Shipwash Drive • Garner,NC 27529 •ph: 919-772-5393 • fx: 919-772-1176 •www.mesco.com
LICENSE NUMBER: C-0281