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:
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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