NCG03_Email RE GENERAL PERMIT NO NCG030000_20180920

Georgoulias, Bethany
From:
Morman, Alaina
Sent:
Tuesday, September 18, 2018 3:15 PM
To:
Sease, Barbara
Cc:
Hoelbling, Stephanie; Georgoulias, Bethany; Riddle, Rick L; Powell, Jeanette; Bennett,
Bradley
Subject:
RE: GENERAL PERMIT NO. NCG030000
Hi Barbara,
Thank you for your detailed inquiry. After reviewing the information, we recommend applying for coverage under
NCG03. Bakers Powders (BPO) and Bakers EIGA can be considered for an augmented Certificate of Coverage. As you
stated in your email, the current NCG03 does not require monitoring for nickel or titanium. However, there is an
established benchmark concentration for nickel, and so additional analytical monitoring requirements beyond what is in
NCG03 are likely. Within the NOI, please explicitly state what is manufactured at both operations and note the presence
of these metals. If you have questions when filling out the NOI, or about coverage in general, please don't hesitate to
email or call. Thank you.
Best,
Alaina
Alaina Morman
Environmental Specialist
Stormwater Program
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
919-707-9236 (0)
DEMLR Stormwater Program
512 N. Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699-1612
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
From: Sease, Barbara [mailto:[e-mail]]
Sent: Wednesday, September 12, 2018 2:47 PM
To: Georgoulias, Bethany<[e-mail]>; Powell, Jeanette <[e-mail]>;
Morman, Alaina <[e-mail]>; Riddle, Rick L <[e-mail]>; Bennett, Bradley
<bradley. ben [e-mail]>
Cc: Hoelbling, Stephanie <[e-mail]>
Subject: [External] GENERAL PERMIT NO. NCG030000
ME

I apologize for the multiple recipients, but I wasn't sure which of you might want to address this question.
CEC's client ATI in Monroe has an individual stormwater permit for their Bakers facility (Permit No. NCS000329) for
discharge of stormwater and non -contact cooling water. As permitted, the Bakers facility consisted of two individual
"operations" — Bakers North (BNO) and Bakers South (BSO) — which share a single outfall from a pond at the northeast
boundary. Two additional operations have been added to the facility— Bakers Powders (BPO) and Bakers
EIGA. Stormwater from these new operations does not share the same outfall with BNO and BSO, and no con -contact
cooling water or any other process water is discharged with stormwater. Stormwater discharges from these new
operations are along the southern and southeastern boundaries.
No raw materials or products from BPO and Bakers EIGA are expected to be exposed to stormwater. We initially
suggested no -exposure certification for the BPO and Bakers EIGA sites, but ATI EHS personnel opted to apply for
coverage instead.
Assuming we do not certify non -exposure, we are considering whether we can/should request coverage under General
Permit No. NCG030000 instead of modifying the current individual permit. We believe the SIC code for BPO and Bakers
EIGA (the two new operations) is 3399 (Primary Metal products, not elsewhere classified). NCG030000 does not
specifically cover this SIC code, but is applicable to "stormwater point source discharges from like industrial activities
deemed by DWQto be similar to these operations in the process, or the discharges, or the exposure of raw materials,
intermediate products, by-products, products, or waste products."
BPO manufactures nickel powder, and Bakers EIGA will manufacture titanium powder. NCG030000 does not require
monitoring for either of these metals, but as we explained above, we do not expect any of these metals to be exposed to
stormwater, either in raw material or product form.
Please advise if NC is willing to allow coverage under NCG030000 or if ATI must instead request modification of its
individual permit.
Thank you —
Barbara
Barbara J. Sease, P.E. / Project Manager
Civil & Environmental Consultants, Inc.
530 Howell Road, Suite 203 • Greenville, SC 29615
Phone: [phone] Fax: [phone]
Mobile: [phone] http://www.cecinc.com
Senior Leadership • Integrated Services • Personal Business Relationships
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