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HomeMy WebLinkAboutNCS000562_Emails RE AZP Stormwater Requirements_20190505Georgoulias, Bethany From: Aiken, Stan E Sent: Sunday, May 05, 2019 5:33 PM To: Vinson, Toby; Lucas, Annette; Georgoulias, Bethany; Morman, Alaina Cc: Reed, Isaiah L Subject: FW: [External] RE: AZP Stormwater Requirements Attachments: TT-01-116_AZP Fire -Sample Locations.pdf, 1904V15_REPORT.pdf fyi From: Davidson, Landon Sent: Sunday, May 05, 2019 3:41 PM To: Rhame.Kenneth@epa.gov Cc: Aiken, Stan E <stan.aiken@ncdenr.gov>; Smith, Danny <danny.smith@ncdenr.gov>; Gregson, Jim <jim.gregson@ncdenr.gov>; Culpepper, Linda <linda.culpepper@ncdenr.gov>; Price, Zan (George) <Zan.Price@ncdenr.gov>; Menzel, Jeff <jeff.menzel@ncdenr.gov> Subject: FW: [External] RE: AZP Stormwater Requirements Ken, Per our earlier discussion today, please see the email chain below that outlines DEMLR's requirements and AZP's response. DWM provided an email response Saturday morning to AZP (see email below) and I talked with AZP earlier today about the issue of discharge. Based on that conversation, it seemed probable they may not have to discharge today as the rain has ceased. Ms. Spearmen (AZP) indicated more pump trucks would be onsite tomorrow to remove water from the lower SW ponds to put into storage onsite with later incorporation into their processing. I've included a photo from the earlier EPA testing for those not familiar with the SW pond structure. Additional questions regarding the SW ponds and requirements should be directed to Stan Aiken of DEMLR as his agency has jurisdiction over the ponds and has set forth monitoring and remediation requirements. If AZP reports a discharge, we will perform our normal notification process. Please call me if you have any questions. Landon G. Landon Davidson, P.G. Regional Supervisor -Asheville Regional Office Water Quality Regional Operations Section NCDEQ - Division of Water Resources 828 296 4680 office 828 230 4057 mobile Landon. Davidson a-ncdenr.gov 2090 U.S. Hwy. 70 Swannanoa, N.C. 28711 Subscribe to Collection System & Sewer Permitting Updates NC DEQ permits handbook Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Menzel, Jeff Sent: Saturday, May 04, 2019 10:51 AM To: Davidson, Landon <landon.davidson@ncdenr.gov> Subject: FW: [External] RE: AZP Stormwater Requirements Landon, I spoke with Tim last evening after he sent his email, their approach to a storm event this weekend will be to hold as much as they can until the basin can no longer safely hold water. If a discharge occurs it will be in a manner to achieve a safe freeboard and not to completely empty the basin. Any discharge will also be characterized by sampling and an attempt at pH neutralization. I asked that he notify us if storm retention becomes questionable. I can be reached at 828- 279-1241 or 919270-1967 anytime this weekend if we need to discuss further. Thanks Jeff Menzel Western Region Environmental Specialist Hazardous Waste Section Division of Waste Management 828 419 5034 office 919 270 1967 cell Jeff. menzel @ ncden r.gov PO Box 117 Black Mountain, NC 28711 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Timothy Basilone [mailto:tbasilone@azr.com] Sent: Friday, May 3, 2019 7:04 PM To: Aiken, Stan E <stan.aiken@ncdenr.gov> Cc: Smith, Danny <danny.smith@ncdenr.gov>; Vinson, Toby <toby.vinson@ncdenr.gov>; Lucas, Annette <annette.lucas@ncdenr.gov>; Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov>; Morman, Alaina <alaina.morman@ncdenr.gov>; Davidson, Landon <landon.davidson@ncdenr.gov>; Burch, Brent <brent.burch@ncdenr.gov>; Menzel, Jeff <jeff.menzel@ncdenr.gov>; Morris, Sean <sean.morris@ncdenr.goy>; Reed, Isaiah L <isaiah.reed@ncdenr.gov>; Robert Williamson <rwilliamson@azr.com>; Aili Spearman <aspearman@azr.com>; Bart Cassidy <BCassidv@mankogold.com>; Holman, Sheila <sheila.holman@ncdenr.gov> Subject: [External] RE: AZP Stormwater Requirements O External email. Do not click links or open attachments unless you verify. Send Al suspic' Dear Mr. Aiken, American Zinc Products ("AZP") has appreciated the Department's assistance as we have worked cooperatively to address the consequences of the accidental fire on April 28 that has affected our facility in Mooresboro, North Carolina (the "Facility"). We also believe that the Department has observed the significant commitment of resources and effort that AZP has expended to both evaluate the impacts of the fire and ensure that any adverse impact to the environment resulting from the accidental fire is minimized and does not create any undue risk to human health or the environment. AZP's response actions have extended to the careful management and evaluation of the water used to extinguish the fire, which has been collected in the stormwater retention pond at the Facility. Sampling has revealed that the accumulated fire water has exhibited lower pH, likely due to the sulfuric acid present in the area of the Facility directly affected by the fire. As you know, the Company has taken appropriate action to neutralize the lower pH in the accumulated water. We are in receipt of your email sent this afternoon, directing AZP to take specific actions to further analyze the accumulated water in the retention pond, and to evaluate those analyses relative to the benchmark levels identified in the Facility's current discharge permit. At your earliest convenience, we request the opportunity to discuss the specific aspects of your email that relate to these benchmark levels and their application to the Facility's discharge, recognizing the efforts that AZP has already put in place (in coordination with the Department) in accordance with its approved plan to further manage the concentrations of specific constituents for which benchmarks have been established. Although we wish to address the issues otherwise implicated by your email, of immediate importance is the statement in your e-mail that appears to direct the Company not to discharge water from the pond without further response from the Department, following its review of several additional water sampling results. Although, as stated above, it is our intention to work closely with the Department to address its objectives relative to the relationship of further sampling to the circumstances governing the Facility's discharge, we believe that it may not be possible to satisfy a "no discharge" directive in the context of a significant rain event. As you are aware, the forecast for the weekend predicts significant rain. Based upon that forecast, it is possible that the hydraulic capacity of the pond cannot contain the accumulated fire water and all collected stormwater flow without overflowing the controlled discharge structure. AZP believes that it is critical to manage flow so as to ensure that any discharge from the pond occurs in a manner consistent with designed discharge conditions, and not unintended and uncontrolled overflow. In an effort to manage the hydraulic capacity of the retention pond, AZP has commenced a program to pump and transport accumulated fire water from the pond. We will continue to implement this program to the extent that it is safe for the relevant personnel to engage in that effort; however, those actions will not be practical nor protective of personnel under adverse weather conditions or otherwise when visibility is inadequate. If rainfall amounts are significant this weekend, our pump -and -transport measures may not allow AZP to avoid the need to discharge from the pond in order to preserve the system for continued stormwater management, because the pond provides a critical role as a proper and effective stormwater retention and management feature. Based on the results already obtained from our current sampling program, knowledge of the conditions at the Facility (including after the fire), and in recognition of the fact that significant additional stormwater flow would further reduce the concentration of any constituents in the discharge, AZP believes that any discharge from the pond resulting from significant stormwater flow would not be materially different from the established ranges for prior discharges of the relevant parameters identified in the benchmark listing. We are available to discuss these issues further with you or other representatives of the Department at your convenience. Consistent with AZP's commitment to open and transparent communication with the Department in all matters related to environmental protection, including with respect to all response actions following the fire, we are raising this issue as soon as possible to explain the circumstances that the Facility may confront this weekend as a result of predicted storm events, because those circumstances may preclude complete satisfaction of the terms in your e-mail. In addition to the circumstances that we may face this weekend (as described above), we are hopeful that we can discuss with you as soon as possible the details of the water sampling and discharge considerations otherwise addressed in your email. As stated above, I am available to discuss these issues with you at any time. You can reach me by email or at my cell phone number ((412) 287-9871). Thank you, and have a good weekend, Tim TIMOTHY R. BASILONE Vice President - Environmental Affairs American Zinc Recycling 3000 GSK Drive I Suite 201 1 Moon Township, PA 15108 P: 724-773-2223 1 F: 412-788-4526 1 C: 412-287-9871 tbasilone@azr.com From: Aiken, Stan E <stan.aiken@ncdenr.Rov> Sent: Friday, May 3, 2019 2:12 PM To: Timothy Basilone <tbasilone@azr.com>; Aili Spearman <aspearman@azr.com> Cc: Smith, Danny <danny.smith@ncdenr.Rov>; Vinson, Toby <toby.vinson@ncdenr.Rov>; Lucas, Annette <annette.lucas@ncdenr.Rov>; Georgoulias, Bethany<bethany.ReorRoulias@ncdenr.Rov>; Morman, Alaina <alaina.morman@ncdenr.Rov>; Davidson, Landon <landon.davidson@ncdenr.Rov>; Burch, Brent <brent.burch@ncdenr.Rov>; Menzel, Jeff <jeff.menzel@ncdenr.Rov>; Morris, Sean <sean.morris@ncdenr.Roy>; Reed, Isaiah L <isaiah.reed@ncdenr.eov> Subject: AZP Stormwater Requirements Dear Mr. Basilone and Ms. Spearman, This email is in response to the emergency your facility experienced on Sunday April 28 and subsequent days. Your efforts to protect the Broad River are noted and appreciated. Stormwater releases for your facility are currently regulated by NPDES Individual Permit Number NCS0000562 and established for normal industrial operations. However the facility has been impacted by the emergency situation you are experiencing, and therefore any runoff from the facility would not likely consist of the same potential pollutants. As such you are directed to proceed as follows: • Provide a written course of action which shall include at a minimum o Measures to maintain no stormwater release, which is not allowed at your facility until DEMLR approval ■ Provide your proposed minimum freeboard to DEMLR for review and approval o Increased testing frequency for all parameters: ■ After each rain event or once per week (whichever is shorter). The sampling points shall be inside Basin 1 near the normal point of discharge and a sample both upstream and immediately downstream of the discharge point in the Broad River. ■ The parameters and benchmark requirements are listed below. o Provide in writing the receiving facilities for all stormwater runoff and any removed material associated with stormwater as well as any treatment process of the stormwater and related materials. o Written notification of whether or not firefighting foam was used in the emergency response. This procedure will continue until three consecutive Basin sample results are below the benchmark values or within benchmark range as listed below and the soils in the basin are tested. The tests must demonstrate that the soil will not contribute significant pollutants to the stormwater in the basin prior to resuming stormwater discharges. The facility must provide results to DEMLR and Division of Waste Management Hazardous Waste for review and approval. Testing Parameters and Benchmarks: Discharge Units Benchmark Sample Sample Characteristics Type Location Total Suspended Solids (TSS) m /L 100 Grab SDO Nitrogen, Total m /L 30 Grab SDO Phosphorous, Total m /L 2 Grab SDO Zinc, Total Recoverable m /L 0.126 Grab SDO Lead, Total Recoverable m /L 0.075 Grab SDO Cadmium m /L 0.003 Grab SDO Chloride m /L 860 Grab SDO Non -polar Oil and Grease/TPH EPA Method 1664 (SGT-HEM) m /L 15 Grab SDO H standard 6-9 Grab SDO Total Rainfall Inches - - Rain Gauge The following additional parameters which EPA has shown to be present in this week's sample shall also tested and evaluated: Arsenic, Barium, Beryllium, Calcium, Chromium, Cobalt, Copper, Iron, Magnesium, Manganese, Nickel, Potassium, Selenium, Silver, Sodium, Thallium, Vanadium Should you have any questions or require additional information, please advise. Thank You, Stanley E Aiken Regional Engineer Land Quality Section North Carolina Department of Environmental Quality 828 296-4500 main 828 296-4610 office stan.aiken(a)ncdenr.gov 2090 US70 Highway Swannanoa, NC 28778-8211 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.