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HomeMy WebLinkAboutNCG020005_Email RE Sampling_20180921Georgoulias, Bethany From: Georgoulias, Bethany Sent: Friday, September 21, 2018 8:06 AM To: 'Brian North' Cc: Phillip Pressley; Lucas, Annette; jay@ncaggregates.org Subject: RE: [External] Martin Marietta Flooded Quarries Brian, The answer is simply that we cannot grant this variance ahead of time for the sampling period. You may document the conditions and record on your DMR reports that you are unable to sample during the entire required sample period, if conditions resulting from adverse weather make it too unsafe or impractical to do so. The expectation is that the operator/permittee all will fulfill the responsibility to determine if such conditions exist for these sites and prevent sampling throughout the entire period. It is reasonable to expect this to be the case for some time, given the severity of flooding, but we cannot say up front, "Okay, it's all right not to sample for the next three months." Please contact my supervisor Annette Lucas if there are any further questions. Best regards, Bethany 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: Brian North<brian.north@martinmarietta.com> Sent: Thursday, September 20, 2018 8:59 PM To: Georgoulias, Bethany <bethany.georgoulias@ncdenr.gov> Cc: Phillip Pressley <PhiIli p.Pressley@ martinmarietta.com>; Lucas, Annette <annette.lucas@ncdenr.gov>; jay@ncaggregates.org Subject: Re: [External] Martin Marietta Flooded Quarries rt Bethany, I plan on calling you in the morning to discuss so that I fully understand your response. I will say that in years past, DWR has granted variances in the past for similar situations and extreme weather conditions that we have just experienced. I also understand that NCDOT will likely suspend completion dates and liquidated damages on NCDOT projects within the impacted areas and request all contractors to perform repair work under emergency contracts. Thus the need for me to understand your expectations. Thanks Brian K. North, PE Director, Environmental Services Martin Marietta 413 S. Chimney Rock Road Greensboro, NC 27409 Office 336-389-6616 Mobile 980-721-1212 On Sep 20, 2018, at 10:00 AM, Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> wrote: EXTERNAL MAIL Phillip, If the permittee is unable to sample because of these conditions, it should be documented. I've included the relevant sections from the NCG020000 General Permit below. We cannot grant a "sampling variance" ahead of these circumstances for an entire sampling period, but documenting any flooding or other dangers that prevent sampling until conditions are safe is acceptable. Part IV, Section A (Stormwater Discharges) Failure to monitor and report per the permit terms may result in the Division requiring monthly monitoring and reporting for all parameters for a specified time period. Lack of a discharge from an outfall for the monitoring period, or inability to collect a sample because of adverse weather conditions during a monitoring period will not constitute failure to monitor, as long as those conditions are reported on the monitoring period DMR and noted in the SPPP. (See Adverse Weather in Definitions.) Similarly, sampling is not required outside of the facility's normal operating hours (unless the mine is inactive). There is no mention of adverse weather conditions in the Wastewater Discharges section of the permit, but the Division is receptive to the some accommodation if adverse weather conditions prevent safe sampling. Part VI, Definitions Adverse Weather Adverse conditions are those that are dangerous or create inaccessibility for personnel, such as local flooding, high winds, or electrical storms, or situations that otherwise make sampling impractical. When adverse weather conditions prevent the collection of samples during the sample period, the permittee must take a substitute sample or perform a visual assessment during the next qualifying storm event. Documentation of an adverse event (with date, time and written narrative) and the rationale must be included with your SPPP records. Adverse weather does not exempt the permittee from having to file a monitoring report in accordance with the sampling schedule. Adverse events and failures to monitor must also be explained and reported on the relevant DMR. I hope this answers 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: Phillip Pressley <Phillip.Pressley@martinmarietta.com> Sent: Tuesday, September 18, 2018 2:31 PM To: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Cc: Brian North <brian.north@ martinmarietta.com>; Lucas, Annette <annette.lucas@ncdenr.gov> Subject: RE: [External] Martin Marietta Flooded Quarries Hi Bethany, Thanks for the quick response. We do have one major concern. At Belgrade, Castle Hayne, and likely Rocky Point (it has not yet been observed), the adjacent rivers have flooded the pits. It is expected to take months to lower these water levels back to those of typical operation. Because this discharge is the result on adverse weather, we would like to request a sampling variance at these three sites to stop sampling until the water is pumped to the typical operating level, where it only fills the sump in the bottom of the pit. Is that possible? Thanks, Phillip From: Georgoulias, Bethany[mailto:bethany.georgoulias@ncdenr.gov] Sent: Tuesday, September 18, 2018 12:52 PM To: Phillip Pressley <PhiIIip.Pressley@ martinmarietta.com> Cc: Brian North <brian.north@ martinmarietta.com>; Lucas, Annette <annette.lucas@ncdenr.gov> Subject: RE: [External] Martin Marietta Flooded Quarries EXTERNAL MAIL Phillip, Thank you for sending this information and advising DEQ of the need to discharge from these quarries. These sites may proceed with dewatering but must follow the conditions and sampling requirements for dewatering WW required under the NCG020000 General Permit. These conditions include not allowing discharges to cause or contribute to Water Quality Standard violations. If you have any further questions, please let us know. 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: Phillip Pressley <Phillip.Pressley@martinmarietta.com> Sent: Tuesday, September 18, 2018 11:05 AM To: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Cc: Brian North<brian.north@martinmarietta.com> Subject: [External] Martin Marietta Flooded Quarries Hi Bethany, Thank you for calling me back. As of now, we have significant water in the following quarries: • Belgrade (NCG020005, White Oak River) • Benson (NCG020123, Stony Fork) • Castle Hayne (NCG020010, Northeast Cape Fear River) • Clarks (NCG020171, Caswell Branch) • Cumberland (NCG020676, Lower Little River) • Lemon Springs (NCG020094, Mullatto Branch) • Onslow (NCG020255, unnamed tributary to the New River) • Rocky Point (NCG020166, Northeast Cape Fear River) We are working to find additional pumps to lower the water level, but we do not yet have pumping rates or expected commencement of increased pumping. Please let me know what else you need from us. Thanks for helping us get this taken care of, Phillip Phillip N. Pressley, PE Sr. Environmental Engineer I NC East District Martin Marietta 2700 Wycliff Road Suite 104, Raleigh, NC 27607 t. (919) 783-4505 m. (919) 649-9143 f. (919) 787-9577 e. phillip.pressley@martinmarietta.com www.martinmarietta.com