NCS000348_Emails RE Creosote Results Reporting_20200819

Georgoulias, Bethany
From: Lambe, Brian
Sent: Wednesday, August 19, 2020 8:35 AM
To: Joshua Jones
Cc: Georgoulias, Bethany
Subject: RE: [External] FW: CPI SOUTHPORT STORMWATER Permit # NCS000348
I do not know the number for the benchmark offhand. I spoke to Ray Porter of Environmental Chemists this morning for
clarification (ranther dumbing down) the report. Since all the SW 846 Method 8270 were lower than detectable limits,
you should report <5ppb. I understand that a few components have higher detection limits, but to summarize will
suffice. Porter also indicated that all the components on the test are not directly related to creosote. He also said that if
we narrowed it down to the specific compounds, the cost would be the same. I will not pretend to know Porter's job, he
is the expert, so we need to follow his lead on the best way to tackle this.
Thank you for your diligence.
Brian Lambe
Environmental Specialist
910-796-7313
919-268-1678 cell
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
127 Cardinal Drive Extension I Wilmington, NC 28405
910 796 7215 T 1910 350 2004 F I httpJ/portal.ncdenr.org/web/ir/
From: Joshua Jones [mailto:[e-mail]]
Sent: Tuesday, August 18, 2020 3:29 PM
To: Lambe, Brian <[e-mail]>
Cc: Ray Porter <[e-mail]>; Ginny Grace <[e-mail]>; Joshua Jones
<[e-mail]>; Francis Hayward <[e-mail]>
Subject: FW: [External] FW: CPI SOUTHPORT STORMWATER Permit # NCS000348
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Brian,
Attached above you'll find the July stormwater results that include Creosote. Since there were so many different
Creosote compounds, I was not sure which value to compare to our stormwater permit benchmark value. Please advise.
Thanks,
Josh Jones
From: Ray Porter <[e-mail]>
Sent: Wednesday, July 1, 2020 4:02 PM

To: Joshua Jones <anlones@caPita 1power.com>
Subject: RE: [External] FW: CPI SOUTHPORT STORMWATER Permit # NCS000348
Notice: External Email. Please do not click links, open attachments, or take any other action on this email unless
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Brian,
We are capable of analyzing SW846 8270D which includes phenols and PAHs. The cresols are phenols also.
I had suggested 625 as it is specifically written for waste water. However, 8270 applies to about any matrix.
625 and 8270 are very similar methods and we are certified for both.
The target list and reporting limits listed in the attached table are all on our target list and limits are reasonable.
Ray Porter
910-392-0223
From: Joshua Jones <[e-mail]>
Sent: Wednesday, July 01, 2020 3:51 PM
To: Ray Porter <[e-mail]>
Cc: Ginny Grace <[e-mail]>; Joshua Jones <[e-mail]>
Subject: FW: [External] FW: CPI SOUTHPORT STORMWATER Permit # NCS000348
Ray,
Does this make sense to you? Are you capable of doing the test method mentioned, below? Please, let us know.
Thank you,
Josh
From: Lambe, Brian <[e-mail]>
Sent: Tuesday, June 30, 2020 3:52 PM
To: Ginny Grace <[e-mail]>; Joshua Jones <[e-mail]>
Cc: Francis Hayward <[e-mail]>
Subject: FW: [External] FW: CPI SOUTHPORT STORMWATER Permit # NCS000348
Notice: External Email. Please do not click links, open attachments, or take any other action on this email unless
you recognize the source of this email and know the content is safe.
I think this is a good solution to start. If the benchmark is busted immediately, refining the testing method may be
needed.
Brian Lambe
Environmental Specialist
910-796-7313
919-268-1678 cell
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
127 Cardinal Drive Extension I Wilmington, NC 28405
910 796 7215 T 1910 350 2004 F I htto: oortal.ncdenr.orgi�Nebilri
From: Georgoulias, Bethany
Sent: Tuesday, June 30, 2020 3:26 PM

To: Lambe, Brian <[e-mail]>
Cc: Lucas, Annette <[e-mail]>
Subject: RE: [External] FW: CPI SOUTHPORT STORMWATER Permit # NCS000348
Brian,
Here's some guidance on this. Chris Ventaloro reminded us that he got the value (0.009) from an ECOTOX database
calculation for saltwater (which won't necessarily tell you testing method), and Connie Brower tapped a former
colleague in Waste Management for guidance on what method to use for testing:
Method 8270 (Semi -volatile Organic Compounds analysis)
Creosote is classified as U051(some kind of waste classification). The primary chemicals of concern in creosote with
harmful health effects are PAHs, phenols, and cresols. Method 8270 will pick up all three types of
compounds. Attached is the PQL list from the lab; the SVOA Method 8270 list of compounds is included here. I'm not
sure which ones to exclude, but if the total is below the creosote benchmark, we know levels are acceptable. If the total
is above the benchmark, we would need to figure out whether the levels are compounds that are not part of
creosote. So, if total SVO from 8270 comes back above 0.009 mg/I, we'll need to look into it further.
Hope this helps as at least a beginning point.
Bg
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
[e-mail]
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
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time.
From: Lambe, Brian
Sent: Monday, June 29, 2020 4:32 PM
To: Georgoulias, Bethany<[e-mail]>
Subject: FW: [External] FW: CPI SOUTHPORT STORMWATER Permit # NCS000348

CPI and I have been wrestling around with what to do with the Creosote requirement. They, we, don't know what to test
for. I asked Lauren for clarification, you were copied, she gave me a parameter number and a benchmark. The
parameter really didn't tell the lab what to test for. The benchmark is 0.009mg/L of WHAT? My reading lead me to
testing for PAH's, but I don't know. What do you think?
Brian Lambe
Environmental Specialist
910-796-7313
919-268-1678 cell
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
127 Cardinal Drive Extension I Wilmington, NC 28405
910 796 7215 T 1910 350 2004 F I htto: oortal.ncdenr.orgiweb ilri
From: Joshua Jones [mailto:[e-mail]]
Sent: Monday, June 29, 2020 4:01 PM
To: Lambe, Brian <[e-mail]>
Cc: Ginny Grace <[e-mail]>; Francis Hayward <[e-mail]>; Joshua Jones
<anlones@caPita 1power.com>
Subject: [External] FW: CPI SOUTHPORT STORMWATER Permit # NCS000348
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[e-mail]
Brian,
FYI... See proposed analytical method for creosote, below. This is from our lab. We understand this is an approved
method. Are you ok with this?
Thanks,
Josh Jones
From: Ray Porter <[e-mail]>
Sent: Monday, June 29, 2020 3:51 PM
To: Joshua Jones <jnlones@caPita 1power.com>
Subject: RE: CPI SOUTHPORT STORMWATER Permit # NCS000348
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Josh,
After reviewing the attachments you sent and your storm water permit, I make the following analytical suggestions for
the measurement of creosote in your storm water.
1) The term creosote is not specific in the target list required. Creosote is defined in some chemistry sources as "an
oily mixture of phenolic compounds.
2) The phenolic compounds I have seen referred to as creosote are three phenols: 2-Methylphenol, 3-
Methylphenol and 4-Methylphenol. These are all phenolic and aromatic chemicals. There are other phenolic
and aromatic compounds however,

3) We were discussing PAHs also or polynuclear aromatic hydrocarbons. I do not know if the permit writer's
intention was to include these instead or in addition to the phenols. Phenols and PAHs, while both are aromatic
as both contain benzene rings, are different classes of compounds.
4) Method EPA 625 is a method for measuring both phenols and PAHs in waste water. Phenols are referred to as
acids as they extract into methylene chloride from water under acidic conditions. BN, or base neutrals, are
extracted under basic conditions.
I think the permit writer's intention is analyze for the methylphenols listed in bullet 1.
However, clarification for DWQ may be needed to make sure other analytes such as PAHs are required.
Ray Porter
910-392-0223
From: Joshua Jones <[e-mail]>
Sent: Friday, June 26, 2020 12:08 PM
To: Tammy Duran<[e-mail]>; Bonnie Sanders <bonnie@environ mentalchemists.com>; Ray
Porter <[e-mail]>
Cc: Francis Hayward <[e-mail]>; Ginny Grace <[e-mail]>; Joshua Jones
<an*ones@capita Ipower. com>
Subject: CPI SOUTHPORT STORMWATER Permit # NCS000348
Please see attachment and read the below, said correspondence with our state inspector, Brian Lambe. Starting in July
we will have to submit results for Creosote. We will need for you to provide us with the sample collection bottles, early
next week. Please let us know if there is any additional information that you may need from us.
Thank you,
Josh Jones
Subject: RE: [External] RE: CPI SOUTHPORT STORMWATER SDO (NCS000348)
Notice: External Email. Please do not click links, open attachments, or take any other action on this email unless
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The best I can figure for the creosote testing is to test for PAHs. You will need to consult with the lab for which methods
to use. The parameter that should be used for creosote is 39140. The benchmark is 0.009 mg/L. I attached some fun
reading on the subject. https://www.atsdr.cdc.gov/ToxProfiles/TP.asp?id=66&tid=18#bookmarkll
Brian Lambe
Environmental Specialist
910-796-7313
919-268-1678 cell
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
127 Cardinal Drive Extension I Wilmington, NC 28405
910 796 7215 T 1910 350 2004 F I htto: oortal.ncdenr.orgi�Nebilri
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