HomeMy WebLinkAboutNCS000255_Tier Three Notification_20190416Lawyer, Mike
From: Lawyer, Mike
Sent: Tuesday, April 16, 2019 12:25 PM
To: Robert Woolwine (WAI)
Cc: LaBounty, Tim L
Subject: RE: [External] Regional engineer for Montgomery county
Attachments: NPDES-ROS Request-20171026-DEMLR-SW.pdf
Bobby,
Pleasure speaking with you today regarding the Tier Three notification for your client AAM Grede in Biscoe, NC, which is
covered under stormwater permit NCS000255 as re -issued with an effective date of October 1, 2017. As discussed, we
will accept your e-mail as written notification on behalf of the permittee.
To summarize our telephone conversation detailing the facility's Tier Two/Tier Three status:
-semi-annual analytical monitoring results from May 2018 and December 2018 indicated consecutive exceedances of the
benchmark values for copper (0.010 mg/L) and TSS (100 mg/L) at outfall 001 and outfall 003
-facility commenced Tier Two monthly monitoring beginning in January 2019
-in response to the benchmark value exceedances the facility has installed concrete barriers around their waste sand pile
and cleaned out the retention pond (outfall 001), facility is also investigating the possibility of landfill disposal of the
waste sand in order to reduce the amount of onsite accumulation
-most recent monitoring results indicate lower values for both outfall 001 and 003 with outfall 003 having no
exceedances for the last two monitoring events in March and April 2019 (please note that three consecutive monitoring
events with no exceedances of any parameter allow return to semi-annual frequency for the associated outfall,
otherwise monthly monitoring shall continue)
-facility has now had four exceedances of a benchmark value for the same parameter at the same outfall, hence the Tier
Three notification
In response to the Tier Three notification and based on the aforementioned response actions already taken by the
facility, I will plan to conduct a compliance inspection at the facility to review the facility's SPPP, current monitoring
records, site conditions, etc. in order to determine any additional actions/requirements. During the inspection, we can
also discuss the option of the facility requesting Representative Outfall Status (see attached form).
I appreciate your time and assistance. If there are any questions or concerns, please contact me.
Mike
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
910 433-3394 office
mike.lawyer(cancdenr.gov
225 Green Street, Suite 714
Fayetteville, NC 28301
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NO Tf CAROLINANjlllllwo'�'
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Robert Woolwine (WAI) <robert.woolwine@waehs.com>
Sent: Tuesday, April 16, 2019 8:13 AM
To: La Bounty, Tim L <tim.labounty@ncdenr.gov>
Cc: Lawyer, Mike <mike.lawyer@ncdenr.gov>
Subject: RE: [External] Regional engineer for Montgomery county
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
11port.spam@nc.gov
Ti m,
I am a consultant with Willoughby and Associates and our client AAM Grede is located in Biscoe NC. They were
issued storm water permit NCS000255 effective 10/1/17 and I pulled out the portion of the permit (see below) that is
the reason for my email yesterday. My understanding is we are required to contact the DEMLR Regional Engineer after 4
consecutive exceedances of the benchmarks. Grede is now pulling monthly samples and the results have dropped
dramatically so we are making progress to get the storm water to an acceptable quality. The last two analytical results
we were only out on copper at Outfall 001 by .04 mg/I. All other parameters were met at 001 and there were no
exceedances at 003 per last two results.
I have attached the last monitoring results with this email. I am unsure what further information you need as
this is the first and hopefully last time we have to document this procedure. I have done inspections at the facility after
each monitoring event and was at the facility last week performing VEE observations with Greg Reeves of the DEQ
observing as well.
I look forward to your response and let me know what other information is needed. Again we are trending in a
positive direction with our results, the facility dredged the retention pond a few months back which helped the results.
Please feel free to contact me through email and my cell number is at the bottom of this email if needed. Thanks and
have a great day.
Tier Three
If: The valid sampling results required for the permit monitoring periods exceed the benchmark value, or
are outside the benchmark range, for any specific parameter at any specific outfall on four occasions, the
permittee shall notify the DEMLR Regional Engineer in writing within 30 days of receipt of the fourth
analytical results;
Then: The Division may but is not limited to:
• require that the permittee revise, increase, or decrease the monitoring and reporting frequency for
some or all of the parameters herein;
• require sampling of additional or substitute parameters;
• require the permittee to install structural stormwater controls;
• require the permittee to implement other stormwater control measures;
• require the permittee to perform upstream and downstream monitoring to characterize impacts on
receiving waters; or
• require the permittee implement site modifications to qualify for a No Exposure Exclusion;
Thanks
Bobby Woolwine
EHS Specialist
540-353-6399 - cell
From: La Bounty, Tim L[mailto:tim.labounty@ncdenr.gov]
Sent: Monday, April 15, 2019 5:12 PM
To: Robert Woolwine (WAI) <robert.woolwine@waehs.com>
Cc: Lawyer, Mike <mike.lawyer@ncdenr.gov>
Subject: FW: [External] Regional engineer for Montgomery county
Hi Robert,
I should have some availability tomorrow pm. If this involves industrial SW permitting you may also contact Mike
Lawyer with our office. Any specific information you can forward would also be helpful?
Respectfully,
From: Pace, Jodi
Sent: Monday, April 15, 2019 5:03 PM
To: La Bounty, Tim L <tim.labounty@ncdenr.gov>
Subject: FW: [External] Regional engineer for Montgomery county
From: Robert Woolwine (WAI) <robert.woolwine@waehs.com>
Sent: Monday, April 15, 2019 1:54 PM
To: Baker, Chris <chris.baker@ncdenr.gov>
Cc: Pace, Jodi <jodi.pace@ncdenr.gov>
Subject: [External] Regional engineer for Montgomery county
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
report.spam@nc.gov
To whom it may concern,
I am in need of getting in touch with the DEMLR regional engineer for Montgomery county specifically AAM
Casting Biscoe Manufacturing Facility concerning storm water. If it is either of you I would appreciate a return email and
if not could you forward this to the appropriate individual. I have a time sensitive matter that I need to communicate
with to someone in your office this week. Thanks for your time and I hope you have a great day.
Thanks
Bobby Woolwine
EHS Specialist
540-353-6399 - cell