NCS000586_Email_20190925

Garcia, Lauren V
From: Reed, Isaiah L
Sent: Wednesday, September 25, 2019 8:38 AM
To: Garcia, Lauren V; Lucas, Annette; Georgoulias, Bethany
Subject: RE: [External] FW: NCS000586 Finalized Permit Dissatisfied Customer
Good for me!
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Isaiah L lie-ed. CPSWQ, HSAEU. LEPSCI
Environmental Speciafisl
Division of inert}-.11ineral and land Hesiourm
lorlIL UrnliPut Deparlwent of EnvirolumPit 1aI QuAty
Land Qualilti- SKIlort. ksheri11PL Regional Office
Phase, (M) 296 4614 Email: Isaiah. reedQNCDENR&gv 2094 US Hwy 70. Swannanoa, North Carolina 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Garcia, Lauren V
Sent: Wednesday, September 25, 2019 8:38 AM
To: Reed, Isaiah L <[e-mail]>; Lucas, Annette <[e-mail]>; Georgoulias, Bethany
<[e-mail]>
Subject: RE: [External] FW: NCS000586 Finalized Permit Dissatisfied Customer
Does a 9am call on Monday work for everyone?
From: Reed, Isaiah L
Sent: Wednesday, September 25, 2019 8:34 AM
To: Lucas, Annette <[e-mail]>; Garcia, Lauren V <[e-mail]>; Georgoulias, Bethany
<[e-mail]>
Subject: RE: [External] FW: NCS000586 Finalized Permit Dissatisfied Customer
Annette,
I am OK with that if that is what you guys want to do. If you want me on the call, I am available this coming Monday and
Tuesday.
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jsaink L lie-ed. CPSM'Q. HSAEU. LEPSCI
En►-irowillpittal pe-ekdiicl
Division of Enerv, 11 ine ral and laud Hpsiourees
lorllk Utrolitut Deparlitient of Envirountental Quality
Land Qualih- Seciiom ksherlllPL Regional Office
Phone: (828} 296 4614 Email: isaiah.reedQNCDENR.sgov 2090 US H" 70. Swannanoa, North Carolina 29778

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Lucas, Annette
Sent: Wednesday, September 25, 2019 8:31 AM
To: Garcia, Lauren V <[e-mail]>; Georgoulias, Bethany <[e-mail]>; Reed,
Isaiah L <[e-mail]>
Subject: RE: [External] FW: NCS000586 Finalized Permit Dissatisfied Customer
Would it be a good idea to have a brief call to discuss this? I think it would only take 30 minutes.
From: Garcia, Lauren V
Sent: Tuesday, September 24, 2019 3:38 PM
To: Georgoulias, Bethany <[e-mail]>; Reed, Isaiah L <[e-mail]>; Lucas, Annette
<[e-mail]>
Subject: RE: [External] FW: NCS000586 Finalized Permit Dissatisfied Customer
Which of the permittees comments should we consider?
From: Georgoulias, Bethany
Sent: Tuesday, September 24, 2019 1:12 PM
To: Garcia, Lauren V <[e-mail]>; Reed, Isaiah L <[e-mail]>; Lucas, Annette
<annette.lucas(@ncdenr.iRov>
Subject: RE: [External] FW: NCS000586 Finalized Permit Dissatisfied Customer
I think you all are headed in the right direction, based on Isaiah's assessment and photos. The point of regular
inspections and minding rainfall events smaller than 25-year, 24 hour is to prevent problems before overflows.
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Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
bethany.georgoulias@ncdenngov
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
From: Garcia, Lauren V
Sent: Tuesday, September 24, 2019 10:11 AM
To: Reed, Isaiah L <[e-mail]>; Georgoulias, Bethany <[e-mail]>; Lucas, Annette
<[e-mail]>
Subject: RE: [External] FW: NCS000586 Finalized Permit Dissatisfied Customer
Looking at photo 1, the basin appears to be quite full. Those berms also look like loose piles of dirt. Additionally, why are
the extra berms only along the western and southern sides of the basin?
I think we were more than fair. Especially considering how much lime slurry leaves the basin, as documented by Isaiah.

(d) Conditions for Lime Slurry Management
The permittee shall develop, malritain and Imple merit a Lime Slurry Management
Plan to specifically address preventative maintenance and good housekeeping for all
areas of the facility where lime slurry handling, storage, ciewatering and hauling
occur within 6 months of permit issuance. The perm ittee shall submit tie Lime
Slurry Management Plan to tape DEMLk Asheville Regi-anal Othcc For approval within
-months of the effective date of the permit; The Lime Slurry Management Plan
shall, at a minimum, include:
i. Inspection of the slurry basin once per seven (7) calendar days and
within 24-hours of a rainfall event equal to or greater than 1.0-inch per
24-hour period.
ii. Response plan for rainfall events equal to or greater than 3.0-inches per
24-hour period.
HL The permittee shall design SCMs f 13MPs to prevent any discharge from
the sludge basin in response to any rain events less than the 25-}year,
24-hour storms event The approved SCMs/3Ws sha]I be implemented
within 6-months of the date of the approval of the Lime Slurry
Management Plan by the Division.
iv, The permittee shall design SCMsfBMPs to prevent, remove, dispose of
and manage ground residuals from hauling activities. The approved
SCMs/BMPs shall be implemented within 6 months efthe date of I1)��
approval of the Lime Slurry Management Plan by the Division,
I would like to know what standard their basin was constructed to be sure it can hold as much as they say it can. We also
have no monitoring data to consider yet. I think we will see troubling pH values and maybe other benchmark
exceedances.
From: Reed, Isaiah L
Sent: Tuesday, September 24, 2019 9:54 AM
To: Garcia, Lauren V <[e-mail]>; Georgoulias, Bethany<[e-mail]>; Lucas,
Annette <[e-mail]>
Subject: RE: [External] FW: NCS000586 Finalized Permit Dissatisfied Customer
All,
Just a few things to think about... If he is referring to the condition in which I observed the site, I would point out that
the "earthen berms" he is referring to are made of the lime sludge resulting from his process (photo 1) and that a great
deal of lime sludge is carried and tracked off site by hauling activity (Photo 2).
]saialk L Beed. EPSIA- .11iSKE11. ELPSCI
En►-irownpiktal Specialisl
Division of Energy. Mineral and Land Resources
lorllk Carli�r;� De�r:�rli�riEti Enviroifi�itenlalu:rllit
Land Quality SKIM. Asheville, Regional Office
Phone- {828) 296 4614 Email: Isaiah, reed 02N DENR&i3v 2094 US I-h4y 70. Swannanoa, North Carolina 28778
Email correspondence to and from this address is subject to the

North Carolina Public Records Law and may be disclosed to third parties.
From: Garcia, Lauren V
Sent: Tuesday, September 24, 2019 9:37 AM
To: Georgoulias, Bethany<[e-mail]>; Lucas, Annette <[e-mail]>; Reed,
Isaiah L <[e-mail]>
Subject: FW: [External] FW: NCS000586 Finalized Permit Dissatisfied Customer
Hey Bethany,
This is the response we received from Andy Oxy Company regarding the permit we just finalized. This lime slurry
management was written jointly by Jeanette, Isaiah, yourself, and myself. Corey Anen, Taylor Young, and Robert
Patterson were also consulted as well for ESC standards, NCDOT settling basin standards, and slurry basin standards.
What is our typical response for something like this?
Thanks a bunch,
Lauren
From: Britt Lovin <[e-mail]>
Sent: Tuesday, September 24, 2019 9:22 AM
To: Lucas, Annette <[e-mail]>; Garcia, Lauren V <[e-mail]>
Cc: Reed, Isaiah L <[e-mail]>; 'Jeff Anderson' <[e-mail]>; 'Bill Anderson'
<[e-mail]>; 'Wallace, Matthew E' <[e-mail]>
Subject: [External] FW: NCS000586 Finalized Permit
• External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
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Ms. Annette Lucas and Ms. Lauren Garcia,
Andy Oxy has received the e mail and the physical copy of our NPDES Individual Stormwater Permit No. NCS000586. The
final permit included the addition of a Lime Slurry Management Plan that was not mentioned in the draft permit.
In a 2015 assessment completed by Wood Environment and Infrastructure Solutions (then Amec Foster Wheeler), soil,
groundwater, and surface water sampling was performed in the area downgradient of the lime basin. The results of the
assessment indicated that the lime basins are not impacting the area. Despite the evidence indicating the lime basin is
not impacting the surrounding environment, Andy Oxy constructed an additional earthen berm around the perimeter of
the western and southern sides of the basins. The earthen berms were constructed such that the basins can provide
adequate volume for the 25-year, 24-hour rainfall event (4.4 inches). Overall, the basin is constructed and operated with
a minimum 12-inch freeboard, and does not accept rainfall runoff from areas outside the basin. Therefore, there is no
discharge of the basin for well over a 25-year, 24-hour storm event. Additionally, the lime is considered a product and is
often removed and sold, providing ample storage space for rainfall in the basin.
Based on this information, Andy Oxy requests the following modifications to the major change in the final permit
requiring the development and implementation of a Lime Slurry Management Plan:
1. Request that the inspection frequency be modified from once per seven days to once per thirty days (or
quarterly) and within 24 hours of a rainfall event exceeding 3.0 inches in 24 hours. Frequent inspections of the
basin, or inspections of the basin for 24-hour rain events less than 3.0 inches, is not warranted because of the
excessive capacity of the basin.

2. As stated, the basin is constructed to provide ample volume to contain at least the 25-year, 24-hour rainfall
event (4.4 inches). We request to modify section ii (Response Plan) of the Lime Slurry Management Plan to be
applicable for rainfall events over the 24-hour, 25-year rainfall event (4.4 inches).
3. We request the Lime Slurry Management Plan deadline for submittal be extended to 12 months to be in keeping
with the SPPP compliance schedule (Part III, Section A.I. Compliance Schedule).
We will proceed to develop our SPPP in accordance with the permit requirements and compliance schedule, and will
develop and submit the Lime Slurry Management Plan to the DEMLR Asheville Regional Office pending the resolution of
item #3 above.
Thank you;
N. Britt Lovin
Andy Oxy Co., Inc.
P. O. Box 6389
Asheville, NC 28816-6389
[e-mail]
ph:828-398-6103
fx: 828-254-4208
c:828-243-2454
From: Garcia, Lauren V <[e-mail]>
Sent: Monday, September 9, 2019 2:27 PM
To: Britt Lovin <[e-mail]>
Subject: NCS000586 Finalized Permit
Good afternoon Britt,
The Andy Oxy Company finalized permit was sent in the mail today. It should arrive at the facility this week. In the
meantime, I wanted to go ahead and email you this copy. Thank you for your patience!
Lauren
Lauren Garcia
Environmental Specialist II
Stormwater Program
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
919-707-3648 (0)
[e-mail]
DEMLR Stormwater Program
512 N. Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699-1612

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Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.