NCS000304_Email from Jill_20180917

9/17/2018
Mail - brad [e-mail]
RE: [External] FW: Stormwater Permit Renewal Information
Jill Gee <[e-mail]>
Mon 9/17/2018 11:01 AM
To:Bennett, Bradley <[e-mail]>;
cc -Bob Churchill <[e-mail]>;
9 2 attachments (1 MB)
Outfall Narrative.pdf; Topographical Map.pdf;
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Good catches Bradley— I've updated the narrative to reflect the items below. I'm also sending you an updated topographical map.
We decided we want to include some wording explaining the relationship between the south outfall and the south stormwater
collection pond.
If you have any further questions please let us know.
Thanks,
Jill
From: Bennett, Bradley [mailto:[e-mail]]
Sent: Monday, September 17, 2018 7:37 AM
To: Jill Gee <[e-mail]>
Cc: Bob Churchill <[e-mail]>
Subject: RE: [External] FW: Stormwater Permit Renewal Information
Hey Jill,
Thanks for the information. After looking through it real quickly I had a couple of questions.
1. On the Outfall Narrative under South Stormwater Collection Pond it indicates that overflow from the south pond eventually
"..makes its way to Outfall 2." But the Map of the Water Systems indicates that overflow from the South Pond would go to
the west outfall (Outfall 4). It appears that the narrative should say it flows to Outfall 4? Is that correct? CORRECT, OUTFALL
4.
2. Just making sure about the overflow from the West Pond. Neither the narrative or the water system map indicate anything
about overflow from the west pond but I'm guessing that there is overflow at times from the west pond and it goes out
Outfall 4. Is that correct? We do have a pumping system in the west stormwater collection pond which runs off of a level
indicator. When the water level raises, it pumps over to the south stormwater collection pond. In the event that the pumps
were to fail, or if we had an extreme weather event, water from the west stormwater collection pond would overflow and
make its way to the west outfall (outfall 4). This has happened in the past.
3. The Outfall Narrative document seems to indicate that Outfall 4 takes drainage from the overflow from the south pond and
runoff from the top of the landfill. But, the topographic map shows a larger area draining to outfall 4 including much of the
actual plant facility? Could you verify the areas draining to outfall 4? The topographical map is accurate. The rainfall from
almost the entire mill as indicated on the map is all collected through drainage and basins and is then piped over to the south
stormwater collection pond where it then follows the narrative for the south stormwater collection pond (i.e. goes to outfall
4 if it overflows). All of this rainfall capture being sent to the south pond was purposely set up to allow us to capture this
water for re -use purposes.
Thanks for your help!
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9/17/2018
Mail - brad [e-mail]
From: Jill Gee <[e-mail]>
Sent: Friday, September 14, 2018 2:20 PM
To: Bennett, Bradley <[e-mail]>
Cc: Bob Churchill <[e-mail]>
Subject: [External] FW: Stormwater Permit Renewal Information
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Bradley,
Below you will find answers and clarifications to your questions. I have attached the requested documents/maps/narrative. Please
don't hesitate to reach out if you need further clarification or have additional questions.
Attachments:
1. Outfall Topographical Map for flow direction
2. Water Systems Diagram
3. Outfall Narrative
4. Sample DMR Data
Thank you,
Jill Gee
Environmental Specialist
Gerdau Charlotte Mill
C: 980-308-1046
0: 704-596-0361 x3035
From: Bennett, Bradley[mailto:[e-mail]]
Sent: Thursday, September 06, 2018 8:47 PM
To: Bob Churchill <[e-mail]>; Jill Gee <[e-mail]>
Subject: Stormwater Permit Renewal InforMation
Bob, Jill,
Thanks for taking the time yesterday for the conference call to discuss this permit renewal. The talk was helpful in the
process. As I indicated I am sending this email to hopefully touch on the points we discussed and highlight (underlined)
the areas where you were going to try and provide additional information.
• Contact updates — you indicated that there where a number of changes that need to be made from the report that
I forwarded previously. Please send me the needed changes and we will get them updated in our database.
• Rodrigo Canova, VP/GM (Replacing Mr Anthony S Read)
• Rodrigq.ca [e-mail]
• 704-596-0361 x 3047
• Bob Churchill, Safety Health and Environmental Manager
• [e-mail]
• 704-596-0361 x 3128
• Jill Gee, Environmental Specialist
• [e-mail]
• 704-596-0361 x 3035
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9/17/2018 Mail - brad [e-mail]
• Please remove any other contacts that you may have listed
Electronic reporting — EPA regulation do now require electronic reporting of data and some other reports. At this
point our database is not yet ready to support electronic entry of stormwater DMR data. This will happen during
the permit cycle so the language will be in the permit, but at first you will continue to submit DMR data in hard
copy form. When electronic submittal is ready all permitees will be notified. We do still need to gather accurate
latitude/longitude for outfall points.
• SOUTH OUTFALL (35`20'22"N/80"49'39"W)
• NORTH OUTFALL (35'20'35"N/80'50'21"W)
• WEST OUTFALL (35"20'16"N/80`49'41"W)
• SOUTHEAST OUFALL (N/A —REMOVING BC NONINDUSTRIAL ACTIVITY)
Outfalls - We discussed the outfalls at the facility. It was noted that the facility is set up to capture stormwater and
reuse stormwater in the production process. Actual "process water" is handled in a non -discharge closed loop
recycle system that does not over flow to the stormwater ponds. This system is covered by a DWR Recycle System
permit (WQ0006060). - Correct
Please verify this information and provide narrative information and possibly site drainage info to verify to confirm
the characterization of the outfalls. In our discussions we noted that there are some questions about your outfalls
that would be best addressed as part of the site visit with our regional office staff.
*Some of the narrative provided in your email was incorrect mainly in that it intertwined our outfalls and ponds —
the attached narrative should help clear things up. We have 3 outfalls and 3 stormwater collection ponds. Though
they are named similarly, they are very different entities. Please reference the attached map and narrative of our
water systems to more clearly understand the flow.
• Monitoring — As I noted in our call, we have a summary of your monitoring data for 2010-2013 as part of your
renewal application submitted in 2013. Our records show only a few DMR submittals since that time. Can you
please provide a summary of your available data from 2014 -the present?
Please see the attached DMR results pdf. All results from 2017 and on were taken by either Bob or myself. Periods
where there is no sample data indicate a period during which there was no discharge.
You asked about monitoring schedule and if this could be placed on an annual cycle. All of our current permits are
set up this way and your renewed permit will required semi-annual monitoring with the first sampling period
January -June and the second July- December.
Sounds good to us—thanks!
In a 2013 inspection report to your facility it was noted that inspection staff had observed dry weather flow that
potentially came from your capped landfill. The report asked for a response on this issue, but we don't have any
record of a response. In our call you indicated that you had a copy of this report and would review the findings
and provide a response on this issue.
Bob and I started working at the Charlotte Mill in 2017 and were not present for this inspection. We therefore are
not familiar with the specific circumstances of the area at the time of the inspection. To provide an explanation,
we have done some investigation into this situation. We believe the investigation may have seen the very
common dry weather flow that occurs at our landfill after a rain event. Due to the large surface area of the
landfill, it may take several days for all of the surface runoff to make its way to the outfall. We have also done a
review of our landfill inspections and found there to be no indication of any wet or seeping areas. Today, the
landfill and outfall are performing well.
Oil -Water Separator — It appears that the O/W Separator is no longer in place.
Correct, this oil water separator is out of commission. There are discussions about pulling the equipment out but
for now it has been idled.
• It doesn't appear that there have been any major operational, process or site changes since the renewal
application that would impact the potential sources of stormwater pollution. Correct.
• If there is an updated site map that would help with characterizing drainage areas and outfalls, an electronic copy
would be helpful.
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9/17/2018 Mail - brad [e-mail]
Attached topographical map as well as a water flow map.
You can provide any of the above additional information directly to my attention. There is no need for a formal
application modification submittal. As I mentioned, once we have a draft permit we will forward toy you for your
comment. Our regional office will also contact you to set up a site visit and it is likely that the Charlotte -Mecklenburg
Stormwater Services staff will participate as well.
Please review this information and let me know if you have any questions.
Bradley Bennett Note New Office Phone
Stormwater Program Phone: [phone]
NC Division of Energy, Mineral & Land Resources Fax: [phone]
1612 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1612
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its subsidiaries only when formally confirmed by its officers authorized for that.
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por error, por favor eliminelo e informe de tal situacion al remitente. Este mensaje solamente sera considerado como
proveniente de Gerdau o de sus subsidiarias cuando sea confirmado formalmente a traves de los representantes legales
debidamente autorizados para tal fin.
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