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HomeMy WebLinkAboutNCG020916_Emails RE Mine Dewatering Discharges_20200917Georgoulias, Bethany From: Georgoulias, Bethany Sent: Thursday, September 17, 2020 2:05 PM To: arwarren68@gmail.com Cc: 'Marc Cox'; 'Larry Anderson'; Morman, Alaina; Lucas, Annette Subject: RE: [External] Boardman Mine - NCG020916 DMR Attachments: General Permit Section D.PDF Ms. Taylor, Yes, that information is correct. Dewatering discharges without potential to discharge to surface waters may be deemed permitted by that 2T rule, if no chemicals are added in the mining process. I checked the original application information in our Laserfiche Repository for NCG020916, and the original NOI application was submitted by you on the permittee's behalf in January 2017. The NOI indicates one mine dewatering outfall (p 6 of 12). On p. 7, the answers to question 23 asking about mine dewatering discharging to surface waters or wetlands were also answered affirmatively. Also, the site plan attachment provided showed an outlet from the dewatering basin not far from a flood zone that appears to spread outside the wetlands boundary (see the screen shots below). The basin outlet was the appropriate outfall point to identify. A wastewater discharge in proximity of a flood zone constitutes a potential point source discharge to surface waters and requires an NPDES discharge permit. A deemed permitted discharge under the 2T rules cannot have the potential to enter surface waters. Mine dewatering discharges currently covered by NCG020916 are subject to the monitoring requirements under NCG020000. If there is still a question about the discharges from this mine, or if something has changed since the original submittal and you feel an NPDES discharge permit does not apply here, please contact the Wilmington Regional Office DEMLR staff to verify. If there is in fact no potential discharge to surface water, an NPDES permit does not apply at all — but the information we have in hand suggests otherwise. If the inspector concurs, the owner can submit a permit rescission request for this COC. The contact there is Brian Lambe, or brian.lambe@ncdenr.gov. NCG0 O0OQ N-01 23) Help us understand what will happen to the dewatnring water at this mine site: ❑ ITA — this mine is not dewatering at al I and wil I not dewaler in the future. a) Will this mine bn dewatering and dlacharging to waters of the state? (Answ&r aMy Wdewafofrng) ❑ No — Yes If yes, where to? X—Surface Waters andfur VVelland5 (oat ke of off -site) ❑ Other fan -site or off-sile� Describe: b1 Will this mina he dowatering but not discharging to waters of the state? (Answer orgy if dewatering) No 0 Yes If yes, expfain how you ale dewaler ng. and where that water unll be directed: i snoUM e F ia■ a� �#sr. 0 EL YiYPat wF4■i 74lLi yliME 00 7!L!i mum 5Llr ..� w f!!1 *Ran ;!lllk 4+rrrr ti ■al► ialir Ll!■ ■Makw■ �lrlN 7!il7L. �!!■ Ail0LYt Mw■A■r MrM► ■!lYr. ■!!L00 .lrwyjy \ Y#!* �lLriM. ■LiRL O�lR ■lL 4*FMr. �Frf ���L7�y ■LIA��or Mlr�. JLll� � ■r■#rr#7ri■!!!EL■ =r■ R ONE '��r "+IY*a!■ ■al�r1rl� 4 I hope this information is helpful. 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 bethany.georgoulias@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 D, E Q Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your Permit No. NCG020000 SECTION D: WASTEWATER DISCHARGES — ANALYTICAL MONITORING REQUIREMENTS AND EFFLUENT LIMITATIONS This General Permit authorizes the discharge of process wastewater associated with two distinct activities: 1) mine dewatering and 2) process wastewater associated with mining operations as described below in 1.4. of this Section. The authorization to discharge wastewater is specifically identified on each permittee's COC. Process wastewater discharges generated by any other activity are not authorized under this permit, except allowable non-stormwater discharges permitted by 15A NCAC 2H .0106(f). Mine dewatering or other wastewaters commingled with stormwater shall be considered wastewater. 1. MINE DEWATERING WASTEWATER During the period beginning on the effective date of the permit and lasting until expiration, the permittee is authorized to discharge mine dewatering wastewater controlled in accordance with the conditions of this permit. Mine dewatering requirements apply to all mines that dewater from pits including quarries, clay brick, sand and gravel, borrow pits, and refractory mining, as well as mines with similar discharges. See Part VI (Definitions) and federal regulations in 40 CFR §436 for definitions of the terms "mine dewatering" and "mine" specific to industry sub -sectors. For Construction Sand and Gravel or Industrial Sand mines, "mine dewatering" wastewater includes wet pit overflows caused solely by direct rainfall and groundwater seepage. Permittees conducting mine dewatering activities that have the potential to drain wetlands or other surface waters must have developed and implemented a Pumping Operation and Monitoring (POM) Plan approved by the Division. Approval may be coordinated with other Divisions in NC DEQ, such as the Division of Water Resources. POM Plans shall include, but are not limited to: • Groundwater monitoring strategies to demonstrate the effect of pumping. • Detailed plans to maintain the surrounding hydrology that protects the affected streams and wetlands and the respective monitoring to demonstrate compliance. • The pumping regime deemed necessary to protect affected streams and wetlands. Alternative site specific pumping and monitoring regimes may be approved by the Division on a case -by -case basis. At the Division's discretion, approval of the POM Plan may be required prior to coverage under this General Permit. Mine dewatering discharges to land surfaces (without the potential to discharge directly to surface waters), where no chemicals are used in the mining process, may be permitted by regulation under 15A NCAC 02T .0113(a)(16) and therefore not subject to the provisions of this permit. 2. PROCESS WASTEWATER During the period beginning on the effective date of the permit and lasting until expiration, the permittee is authorized to discharge treated process wastewater from mining operations. Process wastewater from mining operations includes, but may not be limited to, the water involved in: the slurry transport, washing, or sawing of mined material; air emissions control or processing exclusive of mining of sand, gravel, and stone washing operations; dimension stone cutting operations; and air scrubbing and dust control operations. See Part VI (Definitions) and federal regulations for definitions of the terms "process wastewater" in 40 CFR §122.2 and "process generated wastewater" specific to mining industry sub -sectors in 40 CFR §436. Treatment may involve conveyance through erosion and sedimentation control (E&SC) structures and/or other engineered treatment systems. Part IV Page 9 of 12 Pages requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Renee Taylor [mailto:arwarren68@gmail.com] Sent: Wednesday, September 16, 2020 4:59 PM To: Georgoulias, Bethany <bethany.georgoulias@ncdenr.gov> Cc: 'Marc Cox' <marc@herrteam.com>; 'Larry Anderson' <andersonengineeringpa@gmail.com> Subject: RE: [External] Boardman Mine - NCG020916 DMR • External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to am nc. ov Ms. Georgoulias, Thank you for the link below. After reading through the General Permit, I found Section D Wastewater Discharges — Analytical Monitoring Requirements and Effluent Limitations, Item 1 Mine Dewatering Wastewater, that states "mine dewatering discharges to land surfaces (without the potential to discharge directly to surface waters), where no chemicals are used in the mining process, may be permitted by regulation under 15A NCAC 02T .0113(a)(16) and therefore not subject to the provisions of this permit." (See highlighted section of attached sheet.) We are not discharging directly to surface waters. We are discharging onto land surface. The dewatering outlet is approximately 2351f from the wetland delineation survey line and approximately 8001f from Rough Horn Branch. (See link to site: https://arcg.is/OgH546. I understand this statement to mean that since we are NOT DIRECTLY discharging to surface waters but are discharging to a land surface and NO CHEMICALS are being used, we are not subject to the monitoring/sampling requirements of the General Permit. Do I understand this correctly? If not, please let me know why this does not pertain to my situation. Should you have any questions, please feel free to contact me. Renee Taylor, Engineer Technician Anderson Engineering & Associates, P.A. 305 N. Chippewa Street Lumberton, NC 28358 Office: 910.671.9530 Fax: 910.618.0838 Email: arwarren68k/gmail.com From: Georgoulias, Bethany[maiIto: bethanyaeoraouliasCa)ncdenr.clov] Sent: Wednesday, September 16, 2020 1:57 PM To: arwarren68(a�gmail.com Subject: RE: [External] Boardman Mine - NCG020916 DMR Ms. Taylor, Yes, analytical monitoring is required for discharges under the NCG020000 General Permit. Please refer to a copy of the General Permit on-line for the specific monitoring requirements. You can find that here: https://deg. nc.gov/about/divisions/energy-mi neral-land-resources/npdes-stormwater-gps#ncgO20000:-mini ng- activities,-effective-10-1-2015,-expi res-9-30-2020 Regards, 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@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 D, E Q 1� Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Renee Taylor [mailto:arwarren68@gmail.com] Sent: Wednesday, September 16, 2020 12:35 PM To: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Subject: [External] Boardman Mine - NCG020916 DMR 0 rnal email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to o nc. ov My client received a NPDES General Permit Renewal and Electronic Reporting Requirements letter for Boardman Mine (COC Number: NCG020916). I'm not sure I understand the DMR requirements. Is my client required to take water samples where he is discharging from the mine (dewatering basin)? If so, when should he do this and who tests the samples? Is this something he should be doing at certain intervals throughout the year? Renee Taylor, Engineer Technician Anderson Engineering & Associates, P.A. 305 N. Chippewa Street Lumberton, NC 28358 Office: 910.671.9530 Fax: 910.618.0838 Email: arwarren68(agmail.com