The URL can be used to link to this page

Home My WebLink AboutNCS000009_Email CC to ARO RE Final Permit_20190729Georgoulias, Bethany From: Georgoulias, Bethany Sent: Monday, July 29, 2019 11:45 AM To: Wiggs, Linda; Reed, Isaiah L Subject: RE: SGL Carbon - Final NPDES Stormwater Permit Attachments: NCS000009_FINAL Permit with Cover Letter_20190726.pdf Linda and Isaiah, Please see the attached SGL Carbon's final permit. I removed the proposed special condition and revised monitoring (both analytical and qualitative) to quarterly. When I send this to the permit contact, I'll let him know they can request a modification to reduce monitoring frequency after the first year if levels are below benchmarks. Thanks again for all the help with this one. Bethany Bethany Georgoulias Environmental Engineer Stormwater Program, Division of Energy, Mineral, and Land Resources N.C. Department of Environmental Quality 919 707 3641 office bethany.geor oulias(Da ncdenr.gov 512 N. Salisbury Street, Raleigh, NC 27604 (location) 1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing) Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Wiggs, Linda Sent: Wednesday, July 03, 2019 4:30 PM To: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov>; Reed, Isaiah L <isaiah.reed@ncdenr.gov> Subject: RE: [External] RE: SGL Carbon - NPDES Stormwater Permit Hi Bethany and Isaiah, I have to say I agree with his assessment; I recall fretting over the same concerns when I first visited this site. So my input would be to remove Part 11, Section D, A (2). But, perhaps we should consider increasing the Analytical Monitoring Requirement to Quarterly. Or if Quarterly is too stringent, then perhaps we could do a footnote with Quarterly the first year and if Benchmarks are met they can do Semi -Annual for the remaining years? Regardless, how it looks I think some form of Quarterly is warranted. I looked at the Wastewater Permit data since it was issued (3/2018). 1 did some comparing of parameters with your parameters and benchmark numbers. Those parameters were TSS, Cu and Oil and Grease. Our permit has O/G, not Non Polar O/G and it does not have Zn. They had 1 O/G at 14, the rest were very low. No TSS was elevated. They had 3 Cu basically at the 0.010 or slightly over (0.10, 0.011, 0.012). 1 did do a quick check and it appears they are doing their wastewater sampling without rainfall as instructed. Bottomline is I think they may have issues meeting the benchmark for Cu, Zn and Non -Polar O/G and will end up in Tiered Response. Regardless, I say remove Part 11, Section D, A (2) and do Quarterly instead. Happy to discuss when you pick this Permit back up. -c 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(o)ncdenr.gov 2090 U.S. Hwy. 70 Swannanoa, N.C. 28778 NU -5�*�Nothlnq 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: Wednesday, July 03, 2019 1:23 PM To: Reed, Isaiah L <isaiah.reed@ncdenr.gov>; Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: RE: [External] RE: SGL Carbon - NPDES Stormwater Permit Isaiah and Linda, I am out of the office until 7/22 and had even finalized this permit since it's set to issue that day!! Mr. Ahrens only called late yesterday asking about this proposed requirement, and I advised him to provide written comments before the public comment deadline (Friday) for consideration, so here they are. If you have suggestions for revisions or reasons for dispute, let me know. He told me on the phone it was hard to remove the heavy metal manhole covers and then get a representative sample because of how it fills up and then discharges so as to prevent oils, etc. from going into the combined stream, but I don't remember it being all that impossible when we were there on that site visit. I'd like to know your thoughts. Thanks, and happy Fourth of July! Bg Bethany Georgoulias Environmental Engineer Stormwater Program, Division of Energy, Mineral, and Land Resources N.C. Department of Environmental Quality 919 707 3641 office bethanygeor oulias e ncdenr.gov 512 N. Salisbury Street, Raleigh, NC 27604 (location) 1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing) Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Ahrens, Dean <Jerry.Ahrens@sglcarbon.com> Sent: Wednesday, July 03, 2019 1:06 PM To: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Cc: Reed, Isaiah L <isaiah.reed@ncdenr.gov>; Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: RE: [External] RE: SGL Carbon - NPDES Stormwater Permit External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Mrs. Georgoulias, Thank you for the electronic copies of the draft permit. Please find below my comments in regards to the addition of "internal" or upstream sampling locations. Part II, Section D, A (2.)(1) REQUIREMENT TO EVALUATE SAMPLING POINTS FOR STORMWATER PRIOR TO WASTEWATER COMMINGLING AND MONITOR FOR PARAMETERS The permittee shall: (1) identify at least three potential "internal" sampling points at the plant site where stormwater sampling prior to commingling with cooling water discharge could be feasible; Comments: There is no guidance from EPA (EPA-B-09-003 Industrial Stormwater and Sampling Guide, 2009) for sampling "internal" or upstream locations. The EPA Guidance states that "Stormwater samples are collected from a site's discharge points (or outfalls) for laboratory analysis and the results are compared with benchmark pollutant concentrations as an indicator of the performance of stormwater control measures". Rainfall in the facility is generally sheet flow into drains with either round or rectangular metal grating covers. These drainage catchments are designed with a discharge pipe elbowed down and submerged. Any floating material is kept from being discharged. Any solid material falls to the bottom of the catchment. These drain catchments are inspected and cleaned periodically as per the Stormwater Pollution Prevention Plan (SWPPP). Sampling these locations would require removal of the drain covers, which are constructed of heavy steel grating and require forklifts and chains. Due to safety concerns, It is not feasible to conduct this activity during a storm event. Furthermore, attempting to collect a sample in a catchment basin may result in samples that are not representative of water that is actually discharged off -site due to turbulence in the basin created by runoff as well as from taking the sample itself. Please contact me if you have any questions. Sincerely, Dean Ahrens Environmental Manager Phone +1 828-432-5774 Mobile +1 828 334 8195 jerry.ahrensa-sglcarbon.com SGL CARBON, LLC 307 Jamestown Road 28655 Morganton/NC/United States of America Discover the new SGL >>> sqlcarbon.com Facebook Linkedln Twitter From: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Sent: Tuesday, June 4, 2019 12:05 PM To: Ahrens, Dean <Jerry.Ahrens@sglcarbon.com>; Lundblad, Mark <Mark.Lundblad@sglcarbon.com> Cc: Reed, Isaiah L <isaiah.reed@ncdenr.gov>; Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: RE: [External] RE: SGL Carbon - NPDES Stormwater Permit Mr. Ahrens, The draft renewal permit for SGL Carbon should have gone out to you last week. I wanted to email you a copy. It is out for public notice until July 5t", and then we will move forward with finalizing the permit. Best regards, Bethany Georgoulias Environmental Engineer Stormwater Program, Division of Energy, Mineral, and Land Resources N.C. Department of Environmental Quality 919 707 3641 office bethanygeor oulias e ncdenr.gov 512 N. Salisbury Street, Raleigh, NC 27604 (location) 1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing) Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Ahrens, Dean <Jerry.Ahrens@sglcarbon.com> Sent: Friday, February 01, 2019 10:31 AM To: Lundblad, Mark <Mark.Lundblad@sglcarbon.com>; Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Subject: [External] RE: SGL Carbon - NPDES Stormwater Permit External email ents unless you verify. S report.spam@nc.gov Bethany, Below is my contact info. You can address the acknowledgment letter to this address and to my attention. Best Regards, J. Dean Ahrens Environmental Manager Phone +1 828-432-5774 0erry.ahrens(a-)sglcarbon.com SGL CARBON, LLC 307 Jamestown Road 28655 Morganton/NC/United States of America Discover the new SGL >>> sqlcarbon.com Facebook Linkedln Twitter From: Lundblad, Mark Sent: Friday, February 1, 2019 10:22 AM To: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Cc: Ahrens, Dean <Jerry.Ahrens@sglcarbon.com> Subject: RE: SGL Carbon - NPDES Stormwater Permit Hi Bethany, Your new contact is my Site Environmental Manager, Dean Ahrens. (copied on this e-mail) Charlie Conner needs to be removed for billing. You can bill to Dean and he will get it processed with accounting. Jeff Woodruff is still here and is our Lab Manager, Billy Thompson is no longer with the company. The address is the same and it should be to Dean's attention. BR, Mark From: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Sent: Friday, February 1, 2019 10:01 AM To: Lundblad, Mark <Mark.Lundblad@sglcarbon.com> Subject: SGL Carbon - NPDES Stormwater Permit Mr. Lundblad: I am working on the draft renewal stormwater permit for SGL Carbon, and I know there's been a lot of turnover of staff in the last few years since we received the original application. I wanted to get updated contacts for this permit so that we can send the draft to the right place when it's ready and make sure our database is current. I was on site with Linda Wiggs of DWR and Isaiah Reed of DEMLR last spring, and I think we met with Jeff Woodruff and Billy Thompson, maybe (?) Could you please review the attached summary report and let me know contact information that should be updated? Please be sure to include phone numbers and email addresses, and let me know who the best Permit Contact is for future questions. Also, we owe you all an acknowledgement letter for the renewal application received back in 2013, and I want to verify the address to which I should send that. Would it be to your attention at the Jamestown Road address? Best regards, Bethany Georgoulias Environmental Engineer Stormwater Program, Division of Energy, Mineral, and Land Resources N.C. Department of Environmental Quality 919 707 3641 office bethanygeor oulias e ncdenr.gov 512 N. Salisbury Street, Raleigh, NC 27604 (location) 1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing) Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.