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