NCG020922_Email DEQ Response RE Renewal Inquiry_20171215

Georgoulias, Bethany
From:Georgoulias, Bethany
Sent:Friday, December 15, 2017 10:18 AM
To:'Dave Gambardella'
Cc:Lambe, Brian
Subject:RE: \[External\] RE: NCG020922 Renewal Inquiry
Dave,

Thank you for the additional information – this is helpful. We still need answers c) (2) and (3) on the NOI page,
though. They do not need to be long, but the section does need to be completed.

You referred to an another NOI or permit, but this is an application for a new NPDES permit. I don’t see any record of
existing NCG02 permit coverage for this mine. If there had been an application in the past but a permit never issued, we
would not be using any other documents or plans previously submitted. The Mining and Capacity Use permits are
completely separate from the NPDES permit.

Because of the dewatering and the wetlands indicated nearby and dewatering taking place, a pumping operation &
monitoring plan will be necessary. The nearest receiving waters appear to be Wading Creek, a class SA;HQW
waters. Because these are shellfishing waters, we also need approval by DMF’s Shellfish Sanitation section before
issuing an NPDES permit (standard procedure and also required by our rules). I’ve included a screen shot below. We
will include a request to them during our review once we have all additional information.

You will need to work with the Wilmington Regional Office to develop and submit a Pumping O&M Plan. I’ve copied
Brian Lambe at WiRO so you can get in touch for more information, but the items required for that are listed on the back
page of the NOI. The WiRO will have to approve that before operation can begin.

I have a meeting this morning, but I’ll be in later today until 2:30 pm, and also next week Monday – Wednesday if you
would like to talk more.

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Best regards,

Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality

919 807 6372 office
[e-mail]

1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater

Email correspondence to and from this address is subject to the North Carolina Public Records
Law and may be disclosed to third parties.

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From: Dave Gambardella \[mailto:[e-mail]\]
Sent: Wednesday, December 13, 2017 4:22 PM
To: Georgoulias, Bethany <[e-mail]>
Subject: RE: \[External\] RE: NCG020922 Renewal Inquiry

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Bethany,

Please see the attached documentation on the North River Club permit and the Simpson mine permit info

I have attached a siteplan showing what we would like to do.

The north River Club received an NOI in 2012 before it went bankrupt which preceded my entry into this project.

The only change we would like to make is dewatering the mine to the south instead of the north.

I do not know if there was ever an official wetlands delimitation done on the site again due to the property switching
hands in bankruptcy, and I do not know if there was a pumping O& M plan done during the original review.

I will call Thursday or Friday to go over this if you will be available.

Thanks

Dave Gambardella, PM
Thomas Simpson Construction
2401 Arendell St
Morehead City, NC 28557
252-247-4401 – Office
252-247-0184 – Fax
252-723-9949 – Cell

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From: Georgoulias, Bethany \[mailto:[e-mail]\]
Sent: Wednesday, December 13, 2017 2:45 PM
To: Dave Gambardella <[e-mail]>
Subject: RE: \[External\] RE: NCG020922 Renewal Inquiry

Dave,

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Yes, there is a need for a dewatering NPDES permit in this case. Any potential to discharge of wastewater, even if it
would be rare, triggers the requirement for an NPDES permit. In this case there is also dewatering near wetlands, which
needs to be addressed in a Pumping Operation Monitoring Plan.

We will need additional information for this application:
 On the last page of the NOI, there is a check next to “2 copies of large scale (minimum 24” x 36”) site plan with
topographic lines with all outfalls…”; however, no site plans were included. Please provide a site plan, and
include the location where overflows would occur from the pond in a very large event – this will be the most
appropriate outfall point for mine dewatering water.
Please review the attached marked up aerial plan and let me know if this will suffice
 A line drawing water flow through the facility or block flow diagram. (No drawing was included, and this item
was not checked). This information can be included on the site plan.
Please review the marked up aerial site plan
 The Wastewater Treatment Alternatives section of the NOI (Question 38) needs to be completed for mine
dewatering discharges. Please revise this section of the NOI application.
I have attached the revised pages
 The NOI application indicates that wetlands are 320’ from the mine pit. However, the last page of the NOI only
has a check next to the statement that indicates the operation will not impact any nearby wetlands, instead of
any information about a Pumping O&M Plan. Did you verify with the Wilmington Regional Office that a
Pumping O&M Plan was not necessary? Who was the RO contact? I will request input from the WiRO
specifically on this item before issuing the permit, so please be aware that if it is required, the POM Plan must be
approved by the RO before operation can begin. See answer above.

Please let me know if you have any questions.

Thank you,

Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality

919 807 6372 office
[e-mail]

1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater

Email correspondence to and from this address is subject to the North Carolina Public Records
Law and may be disclosed to third parties.

From: Dave Gambardella \[mailto:[e-mail]\]
Sent: Thursday, December 07, 2017 2:26 PM
To: Georgoulias, Bethany <[e-mail]>; Lucas, Annette <[e-mail]>
Cc: Sams, Dan <[e-mail]>
Subject: \[External\] RE: NCG020922 Renewal Inquiry

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[e-mail].

Hey Bethany
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Please see below answers to questions in red.

From: Georgoulias, Bethany \[mailto:[e-mail]\]
Sent: Thursday, December 07, 2017 1:26 PM
To: Lucas, Annette <[e-mail]>
Cc: Dave Gambardella <[e-mail]>; Sams, Dan <[e-mail]>
Subject: RE: NCG020922 Renewal Inquiry

Thanks, Annette. I just issued two COCs ahead of this one yesterday, and I am working on this and another one this
st
week. The request to the region for comments went out Nov 1, so their 30 day window for input just concluded. To
date I’ve not received any feedback from the Wilmington Regional Office on the proposed North River Club mine.

I do notice that no outfall locations were submitted on the NOI application, and it said that dewatering would be
directed to the adjacent property’s mine basin. There will still be an outfall point where samples are taken, however,
and we’ll need to know that (and latitude/longitude coordinates). Dave, can you please provide that information? The
application indicates that the mine settling pond will overflow in events exceeding the 10-year, 24-hour event, so there
appears to be a potential for wastewater discharge. The previous permit directed all discharge north via a culvert to the
Beaufort Club/North River club golf course irrigation ponds, which would then be used to irrigate the golf course.
Ultimately the goal is to dewater south into the adjacent Simpson mine basin by pump, but we would leave the culvert
in place in case a 10 year, 24 hour event occurred which would then direct water north into the existing irrigation ponds
for the golf course.

Also, where will stormwater be discharged? Or will it all drain to the pit that will then be dewatered? There is only a
topo map and a picture of the property with mine acreage marked. There is no diagram of where treatment devices or
outfall points are located. The stormwater will drain to the pit which will then be dewatered.

If the situation here results in no discharge at all (is that what discharge to the neighboring basin attempts to achieve?),
then we need a better understanding of what the discharge permit is for. Typically we would require sampling at the
point it leaves the mine property to report parameters. If the actual outfall is beyond the property (this is occasionally
the case), then we need to understand exactly where, and where the surface waters are. The goal is not to have any
discharge at all, but I understand that based upon the a sizeable rain event this may not be the case. The Simpson Family
Properties Permit plans showed a potential discharge point that was never used (the mine basin was sectioned off and
dewatered into each section as mining occurred). Would I specify this as the discharge or the culvert draining north to
the golf course irrigation ponds. Or should I specify both discharge points.

Also, I note the application checks “Yes” next to the dewatering being near wetlands or other waterbodies, but there is
no delineation on any site plan of where those are. And, the wastewater treatment alternatives review has been left
uncompleted with a note that says “NO DISCHARGE.” We cannot issue a discharge permit without this review (it is
required by our rules), and I am also unclear about the need for an NPDES discharge permit if the application is asserting
no discharge. This is a point of confusion I need to understand better. I was told by one engineer that based upon the
amount of dewatering needed to dig the Beaufort Club mine that we would need a dewatering permit, regardless of
there being no discharge. But if we do not need the permit renewed then I would be fine with that. Its been about 10
years since I permitted a sand mine.

Dave, please follow up with me on this when you are able to.

Thanks,

Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
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N.C. Department of Environmental Quality

919 807 6372 office
[e-mail]

1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater

Email correspondence to and from this address is subject to the North Carolina Public Records
Law and may be disclosed to third parties.

From: Lucas, Annette
Sent: Thursday, December 07, 2017 10:28 AM
To: Georgoulias, Bethany <[e-mail]>
Cc: Dave Gambardella <[e-mail]>
Subject: NCG020922 Renewal Inquiry

Georgoulias Bethany Mining Activities Stormwater Discharge COC New Project NCG020922 North River Club 09-29-2017 Wilmington

Hi Bethany,

I just got a call from Mr. Gambardella inquiring as to the status of his application for the above project. I explained
about our backlog and agreed to send you an email and copy him so that you two would have each other’s contact
information in case you need to talk with him during the review. Thanks so much!

Annette

Annette Lucas, PE
Stormwater Program Supervisor
Division of Energy, Mineral and Land Resources
Department of Environmental Quality

919 807-6381 office
[e-mail]

https://deq.nc.gov/sw-bmp-manual

512 N. Salisbury Street, Office 942-V, Raleigh, NC 27604
1612 Mail Service Center, Raleigh, NC 27699-1612

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