NCG120076_DMR_20210723

MUNICIPAL ENGINEERING
SERVICES COMPANY, P .A .
GARNER, NC AND C"It Of
;vironmenta, Quality
Received
J U L 1 3 2321 July 22,2021
Ms.Tamera Eplin r
Regional Engineer
450 West Hanes Mill Rd.Ste 300 {`;' „tonal Giiice
Winston Salem,NC 27105
Re: Stormwater NPDES Permit Exceedance Notification and Alternative Source Demonstration
for Fecal Coliform at SDO-3,SDO-4
Surry County Landfill
Permit No.NCG I20076
Permit Period Benchmark Exceeded:2021 Period 1
Dear Ms.Eplin:
The analytical results of stormwater samples collected on June 10,2021 contained levels of fecal coliform(FC)in samples SDO-
3 and SDO-4 at 12,000 colonies per 100ML. These FC concentrations were above the benchmark outlined in NCG120000
(1,000 colonies per 100 ml) (see attached DMR form). Tiered responses and corrective action measures have previously been
implemented in response to the elevated FC levels. NCDMLR permitted the facility in a letter dated September 12, 2016 to
remain in Tier 1 unless three consecutive samples contain FC above benchmarks and then the issue will be"revisited". The
sample collected on June 10,2021 was the third reported exceedance hence Surry County is notifying NCDMLR via this letter.
Jonathan Pfohl of Municipal Engineering Services(MESCO)inspected the SDO-3 and SDO-4 drainage areas in June 2021. At
the time of sampling SDO-3 and SDO-4 received stormwater originating from south of the lined MSWLF Phase 1 and Phase 2.
SDO-3 and SDO-4 drainage areas were identified to only contain"non-contaminated stormwater". The term"non-contaminated
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)6 Phase 2 is inactive
with no waste exposed,no erosion features or other nonconformities in the cover,permanent vegetation is established,no signs of
past leachate breakouts leading towards either outfall. The working face for the last several months and for the next several years
has/will be the far west side of Phase 1 and it's drainage area consists entirely of newly constructed lined landfill Phase 4
therefore, all storm-water that is exposed to precipitation will be contained and piped to the wastewater treatment plant. In
summary,the landfill cover,condition,maintenance,and erosion controls are considered acceptable therefore the source of FC as
found in sample SDO-3 and SDO-4 is very likely not attributed to industrial activities.
Elevated FC levels as identified in this and previous stormwater samples is very likely product of wildlife excrement. Evidence
of several species of wildlife such as deer,birds and varmint are consistently observed during the inspection of the drainage area
(Figure 1). Voluntary supplemental raw leachate samples have been collected from the leachate lagoon to empirically determine
highest levels of fecal coliform to be expected in stormwater samples. Levels of FC in the raw leachate samples in colonies per
100 ml were(26 on October 13,2013,26 on April 17,2014,300 on May 15,2014,440 December 2,2015 and 20 June 10,2011)
which are much lower than those detected in stormwater samples. Low levels of FC in raw leachate samples indicates that
leachate is likely not a significant enough source to contribute to the levels identified in stormwater samples. Concentrations of
FC in raw leachate samples at other lined facilities has also been consistently lower in relation to stormwater outfall samples and
the benchmark.
Surry County remains committed to safe-guarding the environment. Unless NCDMLR instructs otherwise Surry County does not
intend to initiate a Tier 2 or 3 response associated with FC benchmark exceedances. Please contact Ms.Jessica Montgomery,P.E
(permit owner)or Jonathan Pfohl(consultant)if you would like to revisit this issue.
Sincerely,
MUNICIPAL ENGINEERING SERVICES CO.,P.A.
Jonathan Pfohl
Environmental Specialist
[phone]
[e-mail]
cc:Jessica Montgomery,P.E-Surry County(336)401-8376 [e-mail]
co.surry.nc.us
Ricky Hawks-Surry County
Attachments
,U S Environmental)41,1mt.mAgemv"Foul Reirrmnee of National Pollutant TSod,,a P.Itnu atinn System(NPDES)Storm Mkt Multi•Sxdu Genaal Permit for lrdurinol Aotutnea"
68 Shipwash Drive• Gamer,NC 27529• ph:919-772-5393 • fx:919-772-1176 • www.mesco.com
LICENSE NUMBER:C-0281

•
NCDEQ Division of Energy, Mineral and Land Resources
Stormwater Discharge Monitoring Report(DMR) Form for NCG120000
Landfills
Click here for instructions
Complete,sign,scan and submit the DMR via the Stormwater NPDES Permit Data Monitoring Report(DMR)Upload form within
30 days of receiving sampling results. Mail the original,signed hard copy of the DMR to the appropriate DEMLR Regional Office.
Certificate of Coverage No. NCG12 0076 Person Collecting Samples: Ricky Hawks
Facility Name: Surry Co. Landfill Laboratory Name: Pace Analytical Services
Facility County:Surry Co Landfill Laboratory Cert. No.:40&633
Discharge during this period:El Yes ❑ No (if no,skip to signature and date)
Has your facility implemented mandatory Tier response actions this sample period for any benchmark exceedances?❑✓ Yes ❑ No
If so,which Tier(I, II,or III)? II
A copy of this DMR has been uploaded electronically via https://edocs.deq.nc.gov/Forms/SW-DMR ❑ Yes ❑✓ No
Date Uploaded:
Analytical Monitoring Requirements for Outfalls with Industrial Activities—Benchmarks in(Red)
Parameter Parameter Outfall Outfall SDO3 Outfall SDO4 Outfall LnoUa,el"a.(
Code Outfall
N/A Receiving Stream Class C C Not released
N/A Date Sample Collected MM/DD/YYYY 06/10/2021 06/10/2021 06/10/2021
46529 24-Hour Rainfall in inches 0.24 0.24 0.24
C0530 TSS in mg/L(100 or 50*) 60.5 12.7
00400 pH in standard units(6.0-9.0) 6.9 6.8
00340 Chemical Oxygen Demand in mg/L 82.3 96.2
(120)
31616 Fecal Coliform in#per 100 ml(1000) 12,000 ,42;000 20
Additional parameters for outfalls in drainage areas that use>55 gallons per month of new hydraulic oil on average
00552 Non-Polar Oil&Grease in mg/L(15)
NCOIL Estimated New Motor/Hydraulic Oil
Usage in gal/month
* Outfalls to Outstanding Resource Waters(ORW),High Quality Waters(HQW),Trout Waters(Tr)and Primary Nursery Areas(PNA)
have a benchmark TSS limit of 50 mg/L.All other water classifications have a benchmark of 100 mg/L
Notes(optional):Fecal coeform(FC)voluntanly tested from raw leachete colected from lagoon.Low concentratan relal:ve to samples and benchmarks ts evdence that source of FC found In outfall samples is likely not enthropenic
"I certify by my signature below,under penalty of law,that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.Based on my
inquiry of the person or persons who manage the system,or those persons directly responsible for gathering the information,the information
submitted is,to the best of my knowledge and belief,true,accurate,and complete.I am aware that there are significant penalties for submitting
false information,including the possibility of fines and imprisonment for knowing violations."
L G.c -
Signat a of Permittee or elegated thorized Individual Date
Email Address Phone Number
Mo,,.let,e1)ecu.Somy.nc.v$ 32(0- (4t( �3��

f
0
FIGURE 1
Evidence of Various Wildlife in Stormwater Conveyance Features
lotlibt
^e ��L� `C•/T•`
I"A
•
--' . o-.- - ,,. _ A • tel: 'i .1. . ._- i•
;. ` itn= y ., s , a i.. r /
11
i� \ k. t FF
SDO-4 BASIN SDO-3 DRAINAGE AREA
Surry County Lined Landfill