NCS000009_Email RE Final Permit to SGL Carbon_20190729

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Monday, July 29, 2019 12:08 PM
To: 'Ahrens, Dean'
Cc: Wiggs, Linda; Reed, Isaiah L
Subject: SGL Carbon - Final NPDES Stormwater Permit
Attachments: NCS000009_Final-Permit.pdf, NPDES-NCS-Generic-DMR-20180507-DEMLR-SW.pdf;
NPDES-Generic-Annual-DMR-20180507-DEMLR-SW.pdf
Mr. Ahrens:
Please see the finalized NPDES Stormwater Permit for SGL Carbon attached. It was issued on Friday and becomes
effective August 1, 2019.
The DEMLR Stormwater program considered your comments on the draft permit and removed the proposed special
condition. (Note that the Division could consider the requirement to identify internal sampling points as part of Tier 3
response actions, if it determines that is feasible.) Instead of that special condition, the permit incorporates quarterly
monitoring for parameters at each outfall. If results in the first year are below stormwater benchmarks, SGL Carbon
might consider requesting a minor modification of this permit to reduce monitoring to a semi-annual schedule.
Please let me know if you have any questions. I have also included copies of a Data Monitoring Report (DMR) form, and
the Annual DMR Review form (annual form is for SPPP purposes only). An original signed copy of the permit will be sent
out to you this week.
Best regards,
Bethany Georgoulias
From: Ahrens, Dean <[e-mail]>
Sent: Wednesday, July 03, 2019 1:06 PM
To: Georgoulias, Bethany <[e-mail]>
Cc: Reed, Isaiah L <[e-mail]>; Wiggs, Linda <[e-mail]>
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 [phone]
Mobile [phone]
jerry.ahrensa-sglcarbon.com
SGL CARBON, LLC
307 Jamestown Road
28655 Morganton/NC/United States of America
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From: Georgoulias, Bethany<[e-mail]>
Sent: Tuesday, June 4, 2019 12:05 PM
To: Ahrens, Dean <[e-mail]>; Lundblad, Mark <[e-mail]>
Cc: Reed, Isaiah L <[e-mail]>; Wiggs, Linda <[e-mail]>
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.