NCS000009_Email RE ARO Follow Up Inspection_20190408

Georgoulias, Bethany
From:
Reed, Isaiah L
Sent:
Monday, April 08, 2019 11:20 AM
To:
Wiggs, Linda; Georgoulias, Bethany
Subject:
SGL Carbon
Linda/Bethany,
I am wrapping up my report from the inspection at SGL on March 28. 1 wanted to let you guys know what I found.
So, the wording in the permit confused me on the analytical side, but in the end it appears that the "Monitoring
Schedule" in the permit breaks the year up in terms of Mar -Aug and Sep -Feb. Now, they were (it seems to me) just not
being honest when they claimed to have no rain event between March and August last year, but the permit only
requires "semi-annual monitoring" while the permit is being renewed. And they did in fact have a sample from January
and one from October last year... So, I feel like that part of the requirement is met... Kind of...
They did not sample all of the outfalls, but they did sample one additional outfall. They just didn't send Linda the data.
They thought she only needed it for outfall 1. Their consultant also granted them ROS for outfall 3. 1 informed him that a
consultant cannot do that. He said that they will be using a different consultant from now on.
They built a huge roof over the used oil area and a secondary containment wall around it, in response to my previous
report. This was actually pretty impressive.

The tar pitch area remains a concern for me, but they do have a case. The pitch turn solid at ambient temps, and that
raises a question for the need of secondary containment. The main issue for me was the condensation liquid running
down the side. To address this, they made a concrete berm directing that condensate into the trench drain, and
eventually to their oil/water tanks. I am fairly happy with what they have done there.
z

Isaiah 1. Reed. Me, WSKE11. CEPSCI
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Division of Enercry. Mineral and band Ilewirem
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Laud Qualily Sedion. Adevdie Regional Office
Phone; [phone] Email: lsdiah.reedQNCDENR.uxw 2090 US Hwy 70. 5wannanaa, North Carolina 26778
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