NCG140410_Emails RE Burke County SCM_20200318

Georgoulias, Bethany
From: Reed, Isaiah L
Sent: Thursday, March 18, 2021 11:37 AM
To: Jeff Lamm
Cc: Georgoulias, Bethany; Aiken, Stan E; [e-mail];
[e-mail]
Subject: Burke County SCM
Attachments: IMG_3936jpg; IMG_3933.JPG
Mr. Lamm,
The basin on site was not filled to capacity during the inspection and was observed discharging while I was there. This
may be due to damage to the piping or discharge structure. But as such, this basin would still be subject to analytical
monitoring and would not meet requirements to be considered secondary containment. It was also observed that a
large area of the site (including the areas dirrecly beneath the add/mix storage area, at least partially bypasses the pit
and drains directly to a diversion ditch on the South side of the site.
This diversion also appeared to occasionally allow water to overtop and discharge from the south side of the facillity (see
attached pics).
For your proposed approach to secondary containment and analyical discharge:
The permittee will need to modify the current infrastructure at the facility and demonstrate that the basin does not
have a constant discharge to provide all required secondary containment.
The permittee will need to demonstrate that the basin does not have a constant discharge to be exempt from Analytical
Monitoring.
washwater flowing to the south end of the site.

Overview showing the direction of flow. A spill would follow the same path as the washwater and could potentially end
up in the basin and become a release due to the basins constant discharge.

Photo showing how full the basin was during the visit.

Below is an image of the oulet pipe from the basin discharging and flowing out from the bottom right corner of the
image.

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Isaiah L. Reed, El, CPSWQ, MS4C'EC;I
Environmental Specialist
Division of Enei • I n-ei•al & Land Resources
1 : Department of Environmental Quality
Land Quality Section, Asheville Regional Office
Phone- (828) 29B 4614 Email_ 9saeah.reed 4ZNCOENR.pav 20M US Hwy 76. Swarmanoa, Norih 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.
Isaiah,
I received a copy of the report for the inspection that you did at our Morganton Plant (COC NCG140410) on February 2,
2021. 1 subsequently met onsite with Robert Canipe and Tim Glazebrooks on February 25t" to review your findings.
It is our opinion that this site is exempt from analytical monitoring requirements per Part IV, page 1 of NCG140000
because the detention pond that captures all flow from this site was designed to contain a 25-year, 24-hour storm
event. This engineering design and documentation was submitted with the original permit application. We also believe
that secondary containment of chemical admixtures beyond the present sea containers is unnecessary since any spillage
would drain to the wash pits and any overflow from there would be captured in the detention pond.
All other documentation including training and qualitative monitoring was discussed with Tim and Robert will be current
going forward. If you have any questions or would like to meet with me or Robert onsite on or after April 6t", please let
me know.
Respectfully,
tqe � Lamm
Yaadiewa Calwv-etc /�atewia�s
82.9253-6427
SOUTHERN
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MATERIALS