WQ0015487_Wastewater Pond Closure Response_20180814

828.669.3929 • 828.669.5289
24 Lookout Terrace Road • PO Box 1023 • Black Mountain, NC 28711

MARTIN&SLAGLE
Robert L. Martin, LG Principal Geologist Christine E. Slagle Principal Scientist
GeoSciences, PA

August 14, 2018

Mr. Brett Laverty
Water Quality Regional Operations
Asheville Regional Office
N.C. Dept. of Environmental Quality
2090 US Highway 70
Swannanoa, NC 28778

SUBJECT: Industrial Wastewater Closure Plan
Powell Industries, Inc.
Suncrest Chip Mill
Haywood County, North Carolina
Closed-Loop Recycle Permit No. WQ 0015487
________________________________________________________________________

Dear Mr. Laverty,

In accordance with your letter of April 3, 2017, Powell Industries, Inc. has prepared the
attached closure plan for its Industrial Wastewater Pond (Permit No. WQ 0015487) for
your review and approval. Powell Industries also provides the following responses to NC
Department of Environmental Quality, Division of Water Resources’ (DWR) comments
received on June 4, 2018 following DWR’s review of the Draft Wastewater Closure Plan
submitted on April 2, 2018. DWR’s comments are preceded by bullet points and
responses are in italics.

Preliminary Site Survey

 The list of analytes on page 4 should include COD. COD is a performance
measure contained in Powell Industries general stormwater permit.

The analyte list will be modified to include COD.

 DWR would like the option of splitting samples during the preliminary site
survey. Please coordinate the sampling schedule with the Asheville Regional
Office.

MSGS will coordinate sampling schedules with NCDEQ DWR to facilitate splitting
samples.

August 14, 2018
Page 2
MSGS
Temporary Stormwater Management

 If Powell Industries is going to actively use the lower pond for stormwater
management during the pond closure period then a stormwater outfall will have
to be installed on the lower pond. The general stormwater permit requires
biannual monitoring for COD and TSS and the installation of an onsite rain gauge.
DWR will require quarterly monitoring at this outfall during the closure period to
ensure that the stormwater discharge will not exceed 2B surface water
standards. The current contaminants of concern in clude BOD, COD, TSS,
turbidity, nitrite, toluene, and total phenolic compounds. Results should be
reported to both DWR and DEMLR. The regional stormwater inspector for this
site is Isaiah Reed.

The Closure Plan will be modified to include installation of an outfall to allow
discharge of stormwater from the Lower Pond to Jonathan Creek. During closure
activities stormwater samples will be collected on a quarterly basis and analyzed
for BOD, COD, TSS, turbidity, nitrite, toluene, and total phenolic compoun ds.
Results will be reported to DWR and DEMLR.

 DWR would like the option of splitting samples during the temporary stormwater
management period. Please coordinate the sampling schedule with the Asheville
Regional Office.

MSGS will coordinate sampling schedules with NCDEQ DWR to facilitate splitting
samples.

 Are the (SWPP) BMP recommendations in place presently or will they be
identified/implemented after the closure of the closed -loop wastewater pond? If
they are not in place currently then what measures will be taken to improve
stormwater quality prior to the pond closure period? Please provide a copy of
the 2003 SWPP for Powell Industries.

BMPs involving housekeeping issues have been addressed by Powell Industries at
the site. Debris, drums, scrap metal and tires have been removed. Covers over
above ground oil tanks to shed rainwater have been installed over all but one
tank containment structure. Rain water collected in the one uncovered
containment will be managed to prevent discharges to the ground.

The remaining proposed BMPs will be selected and implemented following
stormwater sampling and evaluation of data and prior to beginning wastewater
pond closure.

August 14, 2018
Page 3
MSGS
A copy of the 2003 SWPP will be forwarded to DWR and DEMLR.

Wastewater Pond Closure

 In the table (Page 2) outlining the pond closure sequence, you indicate water
may be directly discharged to Jonathon Creek if water quality meets discharges
limits. Until the close-loop wastewater permit is rescinded, no water in the
upper wastewater pond may be discharged to surface waters.

The wording in Task Description No. 3 under Work Sequence Summary will be
modified to clarify that no water from the upper wastewater pond will be
discharged to Jonathan Creek. Only site stormwater that by-passes through the
wastewater pond will be discharged from the newly installed stormwater outfall
into Jonathan Creek.

 DWR would like the option of splitting samples during the wastewater residuals
and soil investigation. Please coordinate the sampling schedule with the
Asheville Regional Office.

MSGS will coordinate sampling schedules with NCDEQ DWR to facilitate splitting
samples.

If you have any questions or comments please feel free the contact Carl Powell, Powell
Industries, Inc. [phone], or me at [phone]. My email address is
[e-mail].

Sincerely,
Martin & Slagle GeoSciences, P.A.

Robert L. Martin, LG, RSM
Principal Geologist

Cc: Carl Powell
Billy Clarke

Attachments