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Home My WebLink About20090329 Ver 1_More Info Received_20090605Alcoa Corporate Center 201 Isabella Street at 7t' Street Bridge PA 15212-5858 USA Pittsburgh, O Tel: 1412 ax: 1 21553 910538 ALCOA F June 2, 2009 Ms. Cyndi Karoly North Carolina Department of Environment and Natural Resources Division of Water Quality Systel Building, Suite 714 225 Green Street Fayetteville, NC 28301-5043 RE: Request for additional information 401 Certification Application - Narrows Dam Cove Remediation - Alcoa Power Generating Inc. - Narrows Powerhouse Montgomery County, NC Dear Ms. Karoly: UPS Next Day Air R @ [R-30W[i @ JUN ' S 2009 DEW • WATER QUALITY WETLANDS MID STORMWATER BRANCH Alcoa Power and Generating Inc. (APGI) is in receipt of your May 19, 2009 letter requesting additional information in support of our 401 Certification Application, dated March 26, 2009. Your letter requests information concerning the statement made in the Remediation Work Pan - Narrow's Dam Cove, dated March 17, 2009 that: "Alcoa will obtain an Administrative Agreement with either EPA or the State of North Carolina that requires Alcoa meet the substantial requirements of the various permit provisions of the NPDES General Storm Water Permit No. NCG010000, without having to actually obtain the NPDES Permit. " As you know, APGI obtained an Administrative Agreement, dated October 6, 2008 (the Administrative Agreement), pursuant to N.C.G.S § 130A-310.9(b) and other provisions of the Inactive Hazardous Sites Response Act, as codified as Part 3 of Article 9 of Chapter 130A of the General Statutes (IHSR Act). The Administrative Agreement attaches and incorporates by reference a Remediation Work Plan (the Remediation Work Plan). Together, the Administrative Agreement and Remediation Work Plan specify the terms and conditions under which APGI will implement the remedial work to be performed at the Narrows Dam Cove. By way of explanation, the word "substantial" as used in the submittal was intended to convey that any land disturbing activities and associated storm water and sediment control devices would be managed in compliance with the substantive terms and requirements Ms. Cyndi Karoly June 2, 2009 Page 2 contained in NPDES General Storm Water Permit No. NCGO10000. There was no intent to imply or connote less than full compliance with those requirements, as contemplated by the Administrative Agreement and N.C.G.S § 130A-310.3(e). Nevertheless, the issue of storm water control appears to have now been mooted, in any event. Originally, the Remediation Work Plan contemplated the possible need to construct an access road and staging area on the Narrows Powerhouse peninsula, in the event that either or both or those elements might be needed for the remediation contractors to remove impacted soils and sediments. Although the land disturbing activities that would have been associated with this road and staging area would have affected less than an acre, storm water control devices and structures were required under the Remediation Work Plan. However, the actual remedial approach to be used by the remediation contractor chosen by APGI to implement the Remediation Work Plan eliminates the need for this access road and staging area on the Narrows Powerhouse peninsula. Thus, the change in remedial approach eliminates the need for a general storm water permit. APGI will be working the NCDNR Division of Waste Management to document the current remedial approach. Any incidental land disturbing activities associated with the current implementation of the Remediation Work Plan would still meet the substantive terms and requirements contained in NPDES General Storm Water Permit No. NCGO10000. Should you have any questions concerning APGI's remedial efforts at the Narrows Dam Cove, please call Robert Prezbindowski at 865-977-3811 or Ms. Cheryl Marks of NCDNR Division of Waste Management at 919-508-8465. Sincerely, Kirk J. Grib en K t'o Manager Remediation Services Alcoa Inc. CC: Mike Lawyer, DWQ Fayetteville Regional Office Ms. Cheryl Marks of NCDNR Division of Waste Management Robert Prezbindowski, Alcoa Inc.