NCG020354_Email RE Monitoring Conditions_20170313

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Monday, March 13, 2017 11:31 AM
To: 'Kyle Hoover, P.E., P.G., PMP'; Adams, Diane
Cc: Norman Divers; Valentine, Thad; Vinson, Toby
Subject: RE: Follow -Up on Call I Brickhaven Drying Bed Design
Kyle,
Thank you for your follow up call. As we discussed this morning, the modification the company is proposing would
require monitoring be modified to comply with wastewater monitoring and effluent limit conditions. In other words,
the discharge from the stormwater ponds where this effluent flows would no longer be considered stormwater
only. The company should also modify its Stormwater Pollution Prevention Plan, site overview maps, and related
documents to show the new wastewater outfall(s). Keep in mind that effluent limit exceedances are violations of permit
conditions, unlike benchmark exceedances that receive the appropriate tiered responses under the permit. These
discharges would flow to the same receiving waters as the mining operation was permitted under its original COC (which
authorizes both stormwater and wastewater discharges). Also remember that the permittee must adhere to all
conditions of Part II of General Permit NCG020000 (Operation of a Treatment Facility).
We also understand that the beneficial reuse of CCR in structural fill being employed at this site, has leachate that is
collected and contained elsewhere, and that leachate would not be routed through the ponds in the modifications you
are describing here. You explained that the drying beds will be for clays being removed from the mine lake only.
Our Program would appreciate a letter describing the finalized treatment configuration and revised site map that
includes all new wastewater outfalls for the Central Office permit file, so that future permit reviewers and inspectors
have these modification details for reference.
I understand Diane Adams will be out at the site later this month for a site visit. If you have any other questions, please
let her or me know.
Regards,
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethany.georgouliaskncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://deq.ne.gov/about/divisions/energy-mineral-land-resources/stonnwater
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