NCS000543_Permittee Comments_20230131

Young, Brianna A
From: Young, Brianna A
Sent: Wednesday, February 1, 2023 8:29 AM
To: Jeff Gerlock
Cc: [e-mail]; Miller, Kellie
Subject: RE: [External] Re: Carus, LLC draft stormwater permit NCS000543
Jeff,
Unfortunately it is too late to submit comments on the draft permit. I have already submitted the permit to senior staff
for review and signature. However, I will try to address your questions here.
1) COD was added to sampling parameters in the permit. can we get a higher benchmark for our permit?
Stormwater benchmarks are determined by the DEQ Classifications and Standards Branch, and are the same for
all permittees. Therefore, the benchmark cannot be changed.
2) The benchmark for zinc was increased to 126 ug/L. we greatly appreciated that. however, we have performed
additional sampling and shown that there are numerous influents to increase the zinc in our area / outfall (such
as high zinc in water flowing onto the property, high zinc in tap water inside the building, high zinc in water from
onsite gutters, etc - zinc has been detected in these sources at concentrations ranging from 0.1 to 0.4
mg/Q. Therefore, we would request that the zinc benchmark be increased in the permit.
Please see explanation in #1. If zinc exceedances are causing you to enter Tier Response, then you can provide
additional information during that time.
3) The new permit increases the sampling frequency from semi-annually to quarterly. based on the current site
configuration and the fact that the onsite stormwater pond has to fill up in order to have a discharge, it will be
very hard to get quarterly samples collected (unless there is heavy rainfall). also due to the high levels of zinc
from outside sources it is likely that sampling the outfall will result in benchmark exceedances of zinc from
outside sources. therefore we request that the site attempt to collect quarterly samples and report no flows if
that is the case. we would like to eliminate the Tier II and III etc conditions from the permit due to the items
mentioned above (outside sources of zinc, hard if not impossible to perform additional sampling events from the
outfall, etc).
If no discharge occurs from permitted outfalls during a quarter, then you may report "No Flow" on the eDMR
report. Tier Response is standard for all stormwater permits and a program requirement. This cannot be
removed.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail] (e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612

Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public
during this challenging time.
From: Jeff Gerlock <[e-mail]>
Sent: Tuesday, January 31, 2023 12:06 PM
To: Young, Brianna A <[e-mail]>
Cc: [e-mail]; Miller, Kellie <[e-mail]>
Subject: [External] Re: Carus, LLC draft stormwater permit NCS000543
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
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good morning. I apologize for the delay with our comments on the draft permit. I met with Carus personnel at their
facility on December 16th and we discussed the revised draft permit. is it too late for us to submit questions / request
for changes? if not, here is a summary of our concerns / requests for changes:
1) COD was added to sampling parameters in the permit. can we get a higher benchmark for our permit?
2) the benchmark for zinc was increased to 126 ug/L. we greatly appreciated that. however, we have performed
additional sampling and shown that there are numerous influents to increase the zinc in our area / outfall (such as high
zinc in water flowing onto the property, high zinc in tap water inside the building, high zinc in water from onsite gutters,
etc - zinc has been detected in these sources at concentrations ranging from 0.1 to 0.4 mg/L). Therefore, we would
reauest that the zinc benchmark be increased in the permit.
3) the new permit increases the sampling frequency from semi-annually to quarterly. based on the current site
configuration and the fact that the onsite stormwater pond has to fill up in order to have a discharge, it will be very hard
to get quarterly samples collected (unless there is heavy rainfall). also due to the high levels of zinc from outside
sources it is likely that sampling the outfall will result in benchmark exceedances of zinc from outside sources. therefore
we request that the site attempt to collect quarterly samples and report no flows if that is the case. we would like to
eliminate the Tier II and III etc conditions from the permit due to the items mentioned above (outside sources of zinc,
hard if not impossible to perform additional sampling events from the outfall, etc).
we will be glad to formalize these questions / requests in a letter from Carus personnel, if needed. please let us know.
we appreciate your consideration.
On Mon, Nov 14, 2022 at 8:35 AM Young, Brianna A <[e-mail]> wrote:
Good morning,
Please find attached the draft permit and factsheet for the Carus, LLC stormwater permit NCS000543. A hard copy of
this draft will be placed in the mail to Mack Cochran. Please provide any comments by December 14, 2022.

Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail] (e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
zz,,,,,,�D E
NORTH CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our
offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the
public during this challenging time.
Jeff Gerlock, P.G.
Blue Ridge Geological Services
7356 Belmont Drive
Trinity, North Carolina 27370
336-382-6849 mobile

www.blueridgegeo.com