NCG030317_Emails RE Cu Zn Benchmarks_20180828

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Tuesday, August 28, 2018 12:48 PM
To: 'Richard B Caldwell'
Cc: Reed, Isaiah L; 'Edward L Ferguson'; Lucas, Annette; Morman, Alaina
Subject: RE: [External] North Carolina Benchmarks for Zinc and Copper
Dickie,
I wanted to follow up on the information below to clarify the remaining questions in your email. You'd asked for
confirmation about the benchmarks changing in the revised NCG030000 General Permit. As I verified below, the
proposed draft NCG030000 General Permit will have revised benchmarks (The public notice period for that begins
September 4t". You can view the draft permit )
You asked whether you can "stay off Tier 2 if our last two samplings are below the new benchmark." The current permit
still has different benchmark values, and so until the permit is re -issued with different values, the current benchmarks in
NCG030000 still dictate Tier actions. Compliance with the permit requires following the tiers on those triggers. I see
that Darlene Kucken's Inspection Report noted the benchmarks would change, but I do not see where she relieved the
company of Tier actions or monthly monitoring. Did she send a letter that relieved the facility from that? To request a
relief from monthly Tier monitoring, the permittee can submit a request in writing to the regional office. DEQ staff
would review the data and actions the company took to respond under the Tiers, as well as evaluate the upcoming
changes to benchmarks, in determining if the facility can drop back to less frequent monitoring.
The revised permit is worded so that the permittee continues monthly monitoring if in Tier 2 from the previous term,
but that monitoring can drop to semi-annual upon 3 consecutive values below the benchmark (see the proposed draft
, p. 8 of 30, and Tier 2 language). If this language stays in the final permit (and it has in others), effective October
15Y the facility will be close to achieving the number of zinc values below benchmark because samples are being collected
monthly. Again, if the site has been monitoring per Tier 2 requirements already, the alternative is to go ahead and
submit a request to the Asheville Regional Office for relief from monthly monitoring. However, if the company has been
out of compliance because there was never any monthly monitoring or record of a Tier 2 response, a "relief request"
may not be appropriate.
I hope this helps answer your questions.
Best regards,
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
bethany.geor ouliaskncdenr.gov
512 N. Salisbury Street, Raleigh, NC 27604 (location)
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
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: Georgoulias, Bethany
Sent: Friday, August 24, 2018 3:33 PM
To: 'Richard B Caldwell' <[e-mail]>
Cc: Reed, Isaiah L <[e-mail]>; Edward L Ferguson <Edward.Ferguson @southwire.com>
Subject: RE: [External] North Carolina Benchmarks for Zinc and Copper
Dickie,
The proposed draft NCG03 permit that will be going to public notice next month should have the benchmarks for Zn and
Cu cited in Darlene's inspection report (0.126 and 0.010, respectively). The draft NCG03 general permit currently
undergoing EPA's review has those revised benchmark values, which are based on current WQ standards for acute
toxicity. There could be changes prior to public notice, but you will be able to review it when the draft is posted on our
website for public comment. Please be sure to check for that notice early next month to verify. The values would have
been incorporated last year, but limited staff resources necessitated a year-long re -issuance of the general permit as it
had been the previous five years.
Best regards,
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
bethanygeor oulias e ncdenr.gov
512 N. Salisbury Street, Raleigh, NC 27604 (location)
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
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: Richard B Caldwell [mailto:[e-mail]]
Sent: Friday, August 24, 2018 2:26 PM
To: Georgoulias, Bethany<[e-mail]>
Cc: Reed, Isaiah L <[e-mail]>; Edward L Ferguson <Edward.Ferguson @southwire.com>
Subject: [External] North Carolina Benchmarks for Zinc and Copper
Bethany,
Nice talking to you today. See attached report from Darlene Kucken. Glad to hear the numbers are going up. We tested
over benchmark for Zinc of .067 mg/L our last two samplings. (.10 mg/L April 2018, and .0701 mg/L November 2017).
Can you verify what the new bench marks will be and when they go into effect?? Any way we can stay off Tier 2 if our
last two samplings are below the new benchmark??
Our storm water permit was due to be renewed October 2017.
As always, thanks for your help.
Dickie