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Home My WebLink AboutNCS000009_Email from ARO_20171025Georgoulias, Bethany From: Wiggs, Linda Sent: Tuesday, October 24, 2017 1:15 PM To: Georgoulias, Bethany Cc: Lucas, Annette Subject: RE: Proposed NPDES permit renewal draft fro SGL Carbon NC0005258 Attachments: Overviewjpg; GoogleEarth_Imagejpg; DSCF3163.JPG Hi Bethany, Metals and hardness in their SW permit may be worth considering. This is a unique site and since Ron has drafted the WW permit, I think considering the SW draft at this time is a good idea. Their WW draft permit will go to notice November 1. I don't want the industry blindsided with their drafted permits. I believe they will do what is needed of them, but they will need time and guidance. They knew the Chlorine (TRC) limits were coming in their WW permit and are in the process of working on a de -chlorination system for that parameter. They have never been inspected for SW and given their WW/SW comingles, I think we would be doing them a service to work on these permits in concert and also do a SW inspection so we know what we are working with here. Whoever picks this one up, I'd encourage they visit the industry prior. I'd like to be a part of that visit if it does take place. I have attached a map I created of this facility that may assist you. I also included a map showing all of the other adjacent facilities with SW permits as an FYI (the one with the ?? probably should have a SW permit, but I am not sure which one). Anyhow, not having done a SW inspection at SGL I have go to with what SGL staff have told me, which is that all of their SW drains to inlet boxes and is piped under their site to one main pipe that discharges to Silver Creek. That pipe is also where all of their WW flows discharge. SGL staff does not believe there's any access points in this old buried drainage system which would allow them to separate the WW from the SW. The main pipe that receives everything (WW/SW) is labeled "discharge pipe to Silver Creek" on the map. I included a picture of their discharge pipe at Silver Creek as well. This pipe apparently travels in a straight line from their site, under the RR, under three other properties before discharging to Silver Crk. This industry averages — 1-2 MGD of WW and it is a continuous flow. The 1-2 MGD is if there cooling tower is operating properly, if they have issues with their towers then their flows are 3-4 MGD. This WW is contact and non -contact cooling water, hence why they are under an Individual Permit with us instead of a General Permit. There are no treatment units for their WW, although as I mentioned they are currently in the process of installing a de -chlorination system for us. So when they sample for their SW permit they will also always have WW comingled with that SW. Their SW will be diluted by their WW. What I need to dictate to them is when they do their WW sampling they should NOT do it when it is raining. Granted there may be months where they cannot avoid sampling with rain, but for the most part in order to get a representative WW sample they need to avoid the SW comingling. Now I do not know what they presented in their SW NOI, apparently it is a very old one given this permit is 99, but there is a lot of "carbon" (?) dust at this facility. I have not evaluated their SW sample results more than at a glance in conjunction with their WW DMRs and I don't recall seeing exceedances. But representative sampling at this site is a challenge. I have to go back to this site sometime this winter (probably after the Holidays) for a follow up inspection, if you guys want to do a joint inspection I can go whenever you'd like. P.S. Annette, congrats on the new job. I imagine Darlene has mentioned Low and Bonar to you. Low and Bonar (NCS000179) is another complex comingled industry that I am working with regarding WW (and SW). Perhaps whoever picks up SGL can also pick up Low and Bonar and we can do both facilities over a couple of days. Just a thought, I am glad to assist. -G c� Environmental Senior Specialist — Asheville Regional Office Water Quality Regional Operations Section NCDEQ — Division of Water Resources 828 296 4500 office 828 299 7043 fax Email: linda.wiggs(a)ncdenr.gov 2090 U.S. Hwy. 70 Swannanoa, N.C. 28778 -5-'��'Nothinq Compares.] Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Georgoulias, Bethany Sent: Friday, October 20, 2017 8:50 AM To: Wiggs, Linda <linda.wiggs@ncdenr.gov>; Berry, Ron <ron.berry@ncdenr.gov> Cc: Heim, Tim <Tim.Heim@ncdenr.gov> Subject: Re: Proposed NPDES permit renewal draft fro SGL Carbon NC0005258 Linda, I can't remember if I got back to you on this or not. If there is a reason to monitor metals in the NCS permit, we will be revising it to include metals benchmarks. We don't usually include hardness in SW sampling because the benchmark is set at an acute level that makes assumptions about boundary TSS and hardness values in the translation from dissolved to total... but if there's a good reason to include that parameter, we can (like with those special mine permits). I doubt anyone has picked this renewal up yet ... we are so behind and barely keeping up with General Permit renewals (we are about to reissue six of them unchanged for a year). But I will make sure this gets into the file for the permit reviewer. And yes, that language you proposed to Ron sounds okay to me. Is there a reason we need to put a priority on this one? When you say it "commingles," do you mean the same site has stormwater, or is there an outfall that discharges wastewater + stormwater, or wastewater sometimes and stormwater sometimes? I'm out of the office most of today, but if we need to talk more I'll be around all next week. Thanks, Bg 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 / 807-6372 (phone); 919 / 807-6494 (fax) Website: htW:Hdeg.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: Wiggs, Linda Sent: Friday, October 13, 2017 5:35:16 PM To: Berry, Ron; Georgoulias, Bethany Cc: Heim, Tim Subject: RE: Proposed NPDES permit renewal draft fro SGL Carbon NC0005258 Ron, I'd like to see the language "Samples shall accurately represent the physical and chemical character of the effluent" added with the "There shall be no discharge of floating solids or visible foam in other than trace amounts". What do you think about that? Bethany, Here is our draft of the SGL Carbon WW permit that "comingles" with your SW Permit NCS000009. Do you think the next SW draft permit will include metals and hardness? .0 6� Environmental Senior Specialist — Asheville Regional Office Water Quality Regional Operations Section NCDEQ — Division of Water Resources 828 296 4500 office 828 299 7043 fax Email: linda.wiggs(cDncdenr.gov 2090 U.S. Hwy. 70 Swannanoa, N.C. 28778 t �Addmbkl' 0 7U -55"Nothing Compares.,-, t Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Berry, Ron Sent: Friday, October 13, 2017 4:09 PM To: Wiggs, Linda <linda.wiggs@ncdenr.gov>; Heim, Tim <Tim.Heim@ncdenr Qn%/> Subject: Proposed NPDES permit renewal draft fro SGL Carbon NC0005258 Linda & Tim, Attached is the proposed draft permit for SGL Carbon, I also include support does. Once we issue to public notice you will also a draft to review. Ron Ron Berry Engineer Division of Water Resources/Complex Permitting North Carolina Department of Environmental Quality 919 807 6396 office ron.berrya-ncdenr.gov 512 N. Salisbury Street 1617 Mail Service Center Raleigh, NC 27699-1617 email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.