NCG020279_Response to NOD_20180904

Incorporated 1933
SOUTHERN PRODUCTS & SILICA COMPANY, INC.
Post Office Drawer 189 - Hoffman, N.C. 28347-0189
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Dear Mr. LaBounty, September 4, 2018
DEQ -WE L� i!_ ` 'iOP�AL OFFICE
On September 4, 2018, we received your letter via certified mail containing the notice of
deficiency concerning our plant, Southern Products & Silica Company Inc., which will be
referred to as SP&S throughout the rest of this letter. Since the inspection by Mike Lawyer on
August 22, 2018, we have taken several steps to ensure our Water Quality Program, which
encompasses the discharge of stormwater, mine dewatering, and/or the process of waste water
from the facility to receiving waters, meets the requirements outlined in our permit. Per your
letter, here is our detailed response to the actions we have taken to ensure compliance:
Analytical Monitoring
Previously, SP&S Program Manager, Steve Mills, only collected quarterly samples from the
Upstream, Downstream, and Discharge points to be sent to Microbac Testing Laboratory for
testing only if he could collect samples from all three locations, but Mr. Mills was unable to
obtain the Upstream sample due to a closed bridge, so he did not collect samples during the
first half of 2018. Mr. Mills was taught this by the previous Program Manager, which is not
regulatory guidance according to NPDES Permit NCG020000 under Certificate of Coverage
MCG020279, which states that the stormwater discharge outfall (SDO) shall be tested
semiannually during a measurable storm event if the discharge characteristics remain in
operable limits.
Way Ahead — After meeting with Mr. Laywer and going over the NPDES Permit NCG020000
under Certificate of Coverage MCG020279, SP&S will conduct testing of the SDO semiannually,
maintain all testing records in an orderly manner, and ensure all reports are submitted on time to
the proper receiving agency. Of note, SP&S also reviewed, reorganized, revived their Water
Quality program as well as changed the Program Manager to Eric Hartman.
We would like to thank Mr. Lawyer for his guidance and assistance. If you have any
questions regarding our response, please contact Scott Bradsher, Vice President / Operations
Officer, or Eric Hartman, Assistant Operations Officer at 910-281-3189.
Sincerely,
Robert L. Bradsher
President
Southern Products ,& Silica Company, Inc.
FILTER GRAVEL 9 FILTER SAND - BLASTING SAND - CAROLINA DECORATIVE AGGREGATE