NC0005258_NOD2023OC0002_resp_20231206

iC 3� sgl carbon
Stephen Richards
828-925-0572 Direct
[e-mail]
December 6, 2023
Via E Mail
Ms. Melanie Kemp, Environmental Specialist
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
RE: Notice of Deficiency
NOD-2023-OC-0001
Discharge Without a Valid Permit
NPDES Permit No. NC0005258
Burke County
Dear Ms. Kemp:
As Environmental Health and Safety Manager for SGL Carbon, LLC ("SGL"), we respectfully
submit this letter in response to the Notice of Deficiency ("NOD") issued by North Carolina Department
of Environmental Quality ("NCDEQ") dated November 29, 2023.
As described herein, the NOD relates to discharging approximately one gallon of oil into silver
creek. This response describes, based on a review of the events in question, how and why the incident
occurred, the estimated amount of material released, and SGL response and actions to the upset event.
Description of Release Incident and Amount and Duration of Release
On November 14, 2023, SGL unknowingly released one gallon of oil into silver creek. Upon
discovering the oil in the storm lines SGL activated the Spill Prevention, Control and Countermeasure
Plan ("SPCC"). November 14, 2023, an environmental response team responded and remediated the
storm lines.
Cause of Release Incident
At the time the release occurred, SGL maintenance team along with contract plumbing company
were jetting 180 feet of storm line. The release of the clog within the storm line allowed oily debris and
pitch to migrate from a malfunction pitch trap. The maintenance team and contractor were unaware
that the clogged storm line was the cause of the malfunction pitch trap.
Corrective Action
SGL is committed to prevent or abate the emissions of harmful pollutants from company
operations. As noted above, the maintenance team and contractor where unaware of the malfunction
pitch trap. SGL has taken corrective measure to prevent incidents like the one that occurred on
November 14, 2023, from reoccurring. A review of any storm line work will be conducted prior to
working on storm lines.
DCO public - (RICHARDSST)

If you have any questions or request additional information, please contact me.
Sincerely,
r
Stephen Richards
DCO public - (RICHARDSST)