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HomeMy WebLinkAboutNCS000304_Email RE Gerdau Al Sample Results_20181112Georgoulias, Bethany From: Jill Gee <jill.gee@gerdau.com> Sent: Monday, November 12, 2018 8:55 AM To: Georgoulias, Bethany; Moore, James; Lee, Angela Y Cc: Bob Churchill Subject: RE: [External] Gerdau Sample Results External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to ' James, Angela, We submitted a DMR for our storm water sample from 10/10/18 with reported aluminum concentrations of 1090 ug/L. Upon receiving the results, we asked the lab to re -run the sample to ensure the results were not in error as these results are much higher than we are accustomed to seeing. While awaiting the re -run results, we began a Tier I response. We received notification from the lab late last week that the re -run sample results did not support the original result and that the aluminum concentration is now reported to be 740 ug/L (our current Al benchmark value is 750 ug/L). We asked Bethany for some advice on whether we should resubmit the DMR with the new result as the original was in error. We also asked if we could leave the Tier I response out of the SWPPP since the original result was not `valid'. Bethany has advised us that she agrees with our decision. Since the actual concentrations are still much higher than we would like to see them, we did continue our investigation into the matter and believe we have found the culprit. We will be installing some drain catches to help prevent these higher concentrations in the future. Bethany has advised us to record these BMP improvements in our SWPPP. We will also be watching our Aluminum concentrations to ensure that the catches are helping to reduce the higher aluminum concentrations at our outfalls. Please let us know if you have any other suggestions for us. Thank you, Jill Gee From: Jill Gee Sent: Monday, November 12, 2018 8:13 AM To: 'Georgoulias, Bethany' <bethany.georgoulias@ncdenr.gov> Cc: Bob Churchill <Bob.Churchill@gerdau.com> Subject: RE: [External] Gerdau Sample Results Hi Bethany, I've attached our current active permit (NCS000304). We received a new permit from the state but it doesn't go into effect until Dec 1 this year, so we need to go from what our 2009 permit says. I agree with your statement below about the first `valid' sample, so we are going to go ahead and re -submit with an explanation. I'm glad you mentioned documenting our corrective actions in the SPPP — it makes sense to keep the record there explaining what we are doing and why. Thanks, Jill From: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Sent: Saturday, November 10, 2018 3:45 PM To: Jill Gee <iill.gee@gerdau.com> Cc: Bob Churchill <Bob.Churchill@gerdau.com> Subject: Re: [External] Gerdau Sample Results Hi, Jill, What is your permit number? I'd like to keep the record of what I've advised you with the permit file. I also want to refer to the exact Tier language of your permit since the templates have gone through some iterations over the years. The tiers in our permits usually reference the first "valid" sample taken for the monitoring period, which means if the lab discovered a problem with the original results and re -ran the sample, then the re -test results (if valid) are the ones to report. So, yes, I agree with your decision to re -submit a corrected DMR (with a letter to explain what it's replacing), and not needing to document a Tier 1 response if the re -test results supported a value below benchmark. I would encourage you to document efforts to eliminate potential sources of aluminum contamination in the SPPP records. I am glad to hear the investigation was successful in finding a likely source and the sampling has been a useful guide. Our goal in the NPDES Stormwater Program is for sampling to compliment stormwater pollution prevention efforts. Please let me know the permit number, and I'll verify the Tier language. Best regards, Bethany Georgoulias, Environmental Engineer NCDEQ / DEMLR / Stormwater Permitting Program 1612 Mail Service Center, Raleigh, NC 27699-1612 512 N. Salisbury Street, Raleigh, NC 27604 919 / 707-3641 (phone); 919 / 807-6494 (fax) Website: http://deg.nc.gov/about/divisions/energy-mineral-land-resources/stormwater E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be disclosed to third parties. From: Jill Gee <Oill.gee@gerdau.com> Sent: Friday, November 9, 2018 5:06:03 PM To: Georgoulias, Bethany Cc: Bob Churchill Subject: [External] Gerdau Sample Results CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamLa�nc.gov> Bethany, Our Q3 stormwater sample results taken on 10/10/18 showed that we exceeded our benchmark value for aluminum. We responded by beginning to work through the Tier 1 response. Our first action was to ask the lab to re -run the sample to ensure that the results were accurate. While we awaited those results we continued our investigation. Earlier this week the lab reported to us that the re -run sample results did not support the original results and that our aluminum this time came back under the benchmark value. We are going to resubmit an updated DMR explaining the new lab results. The new reported result for aluminum concentrations, while under the benchmark value, is still higher than we are accustomed to seeing. We therefore have continued, unofficially, working through the Tier 1 response and using it as a tool to help us determine the cause of the higher results. We believe we have found the cause of the high results and are implementing a solution on Monday. Since the new results are below the benchmark value we have decided not to document the Tier 1 response in our SWPPP. Do you agree with this decision and with the decision to resubmit a new DMR? Thank you, Jill Gee Environmental Specialists Gerdau Charlotte Mill Sent from my iPhone This message may include restricted, legally privileged, and/or confidential information. If you received this message by mistake please delete it immediately and inform us about it. This message will be considered as originated from Gerdau or its subsidiaries only when formally confirmed by its officers authorized for that. Este mensaje puede contener informaciones de use restringido y/o legalmente protegido. Si usted ha recibido este mensaje por error, por favor eliminelo e informe de tal situacion al remitente. Este mensaje solamente sera considerado como proveniente de Gerdau o de sus subsidiarias cuando sea confirmado formalmente a traves de los representantes legales debidamente autorizados para tal fin. This message may include restricted, legally privileged, and/or confidential information. If you received this message by mistake please delete it immediately and inform us about it. This message will be considered as originated from Gerdau or its subsidiaries only when formally confirmed by its officers authorized for that. Este mensaje puede contener informaciones de use restringido y/o legalmente protegido. Si usted ha recibido este mensaje por error, por favor eliminelo e informe de tal situacion al remitente. Este mensaje solamente sera considerado como proveniente de Gerdau o de sus subsidiarias cuando sea confirmado formalmente a traves de los representantes legales debidamente autorizados para tal fin.