HomeMy WebLinkAboutNCS000009_Email RE Permittee Comments on Draft_20190703Georgoulias, Bethany
From: Ahrens, Dean <Jerry.Ahrens@sglcarbon.com>
Sent: Wednesday, July 03, 2019 1:06 PM
To: Georgoulias, Bethany
Cc: Reed, Isaiah L; Wiggs, Linda
Subject: RE: [External] RE: SGL Carbon - NPDES Stormwater Permit
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Mrs. Georgoulias,
Thank you for the electronic copies of the draft permit. Please find below my comments in regards to the addition of
"internal" or upstream sampling locations.
Part II, Section D, A (2.)(1) REQUIREMENT TO EVALUATE SAMPLING POINTS FOR STORMWATER PRIOR
TO WASTEWATER COMMINGLING AND MONITOR FOR PARAMETERS
The permittee shall:
(1) identify at least three potential "internal" sampling points at the plant site where stormwater sampling
prior to commingling with cooling water discharge could be feasible;
Comments:
There is no guidance from EPA (EPA-B-09-003 Industrial Stormwater and Sampling Guide, 2009) for sampling
"internal" or upstream locations. The EPA Guidance states that "Stormwater samples are collected from a site's
discharge points (or outfalls) for laboratory analysis and the results are compared with benchmark pollutant
concentrations as an indicator of the performance of stormwater control measures".
Rainfall in the facility is generally sheet flow into drains with either round or rectangular metal grating covers.
These drainage catchments are designed with a discharge pipe elbowed down and submerged. Any floating
material is kept from being discharged. Any solid material falls to the bottom of the catchment. These drain
catchments are inspected and cleaned periodically as per the Stormwater Pollution Prevention Plan (SWPPP).
Sampling these locations would require removal of the drain covers, which are constructed of heavy steel grating
and require forklifts and chains. Due to safety concerns, It is not feasible to conduct this activity during a storm
event. Furthermore, attempting to collect a sample in a catchment basin may result in samples that are not
representative of water that is actually discharged off -site due to turbulence in the basin created by runoff as well
as from taking the sample itself.
Please contact me if you have any questions.
Sincerely,
Dean Ahrens
Environmental Manager
Phone +1 828-432-5774
Mobile +1 828 334 8195
jerry.ahrensa-sglcarbon.com
SGL CARBON, LLC
307 Jamestown Road
28655 Morganton/NC/United States of America
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From: Georgoulias, Bethany <bethany.georgoulias@ncdenr.gov>
Sent: Tuesday, June 4, 2019 12:05 PM
To: Ahrens, Dean <Jerry.Ahrens@sglcarbon.com>; Lundblad, Mark <Mark.Lundblad@sglcarbon.com>
Cc: Reed, Isaiah L <isaiah.reed@ncdenr.gov>; Wiggs, Linda <linda.wiggs@ncdenr.gov>
Subject: RE: [External] RE: SGL Carbon - NPDES Stormwater Permit
Mr. Ahrens,
The draft renewal permit for SGL Carbon should have gone out to you last week. I wanted to email you a copy. It is out
for public notice until July 5t", and then we will move forward with finalizing the permit.
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: Ahrens, Dean <Jerry.Ahrens@sglcarbon.com>
Sent: Friday, February 01, 2019 10:31 AM
To: Lundblad, Mark <Mark.Lundblad@sglcarbon.com>; Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov>
Subject: [External] RE: SGL Carbon - NPDES Stormwater Permit
Wm(cDnc.go
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Bethany, Below is my contact info. You can address the acknowledgment letter to this address and to my attention.
Best Regards,
J. Dean Ahrens
Environmental Manager
Phone +1 828-432-5774
jerry.ahrens(a)sglcarbon.com
SGL CARBON, LLC
307 Jamestown Road
28655 Morganton/NC/United States of America
Discover the new SGL >>> sqlcarbon.com Facebook Linkedln Twitter
From: Lundblad, Mark
Sent: Friday, February 1, 2019 10:22 AM
To: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov>
Cc: Ahrens, Dean <Jerry.Ahrens@sgicarbon.com>
Subject: RE: SGL Carbon - NPDES Stormwater Permit
Hi Bethany,
Your new contact is my Site Environmental Manager, Dean Ahrens. (copied on this e-mail)
Charlie Conner needs to be removed for billing. You can bill to Dean and he will get it processed with accounting.
Jeff Woodruff is still here and is our Lab Manager, Billy Thompson is no longer with the company.
The address is the same and it should be to Dean's attention.
BR,
Mark
From: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov>
Sent: Friday, February 1, 2019 10:01 AM
To: Lundblad, Mark <Mark.Lundblad@sglcarbon.com>
Subject: SGL Carbon - NPDES Stormwater Permit
Mr. Lundblad:
I am working on the draft renewal stormwater permit for SGL Carbon, and I know there's been a lot of turnover of staff
in the last few years since we received the original application. I wanted to get updated contacts for this permit so that
we can send the draft to the right place when it's ready and make sure our database is current. I was on site with Linda
Wiggs of DWR and Isaiah Reed of DEMLR last spring, and I think we met with Jeff Woodruff and Billy Thompson, maybe
(?) Could you please review the attached summary report and let me know contact information that should be
updated? Please be sure to include phone numbers and email addresses, and let me know who the best Permit Contact
is for future questions.
Also, we owe you all an acknowledgement letter for the renewal application received back in 2013, and I want to verify
the address to which I should send that. Would it be to your attention at the Jamestown Road address?
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.