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Home My WebLink AboutNCS000171_Email RE Benchmarks and NCGNE1327 Status_20190506Georgoulias, Bethany From: Georgoulias, Bethany Sent: Monday, May 06, 2019 7:25 AM To: David Kannianen Cc: Denton, Bill; Valentine, Thad Subject: RE: Questions about Permit #NCS000171/ NCGNE1327 Status David, If this facility meets No Exposure conditions, then the regional office should be reviewing that request. Was that submitted in February? I see a request from your company for Application No. NCGNE1327 that went to the Raleigh Regional Office (to the attention of Bill Denton, Regional Supervisor) for review. If the sample results over benchmark are the result of contribution of neighbors' runoff, then a No Exposure Certification will eliminate your having to sample in the future anyway. Also, note that the NCG030000 Permit was renewed effective November 1, 2018 with revised benchmark values for copper, lead, and zinc (see screen shot below). It depends on how representative the sample at the back of your property was for runoff from your site (isolated from other influences), but those results are under the current benchmarks. I don't see the sample point for that noted, and I'd need to see drainage areas to understand it better. However, the regional office should work with you on these details. Table 1. Analytical Monitoring Requirements for Outfails with Industrial Activities' Parameter Code Discharge CharaeterLvdcs units Measurement FreqllerICY2 Sample IWO Sample Location4 Bench - mark 00400 pH7 standard semi-annual Grab SDO 6-9 C0530 TotalSus pen dedSob ds(TS5} nig/L semi-annual Grab SDO 100 C0530 Total Suspended Solids (TSS) HQW OW. Tr and PNA mg/L semi-aftnual Grab SDO 5o 01119 Copper. Total Recoverable mg/L semi-annual Grab SDO 0.010 01051 Lead. Total (as Pb) mg/L semi-annual Grab SDO 0.075 01094 Zinc, Total Recoverable mg/L semi-annual Grab SDO 0.126 78141 Total Toxic Organics (1`1'O)6 nag/L semi-annual Grab SDO 1 pane 7 of 31 Permit No. NCG03000D Parameter Discharge Units Measurement Sample Sample Bench - Code Characteristics Frequency2 iYpe3 Location4 mark 46S29 Total Ramfall5 inches semi-annual Rain gauge 00552 Non -Polar Oil & Grease/TPH by mg/L semi-annual Grab SDO 15 EPA Method 1664 (SGT-HEM) Additional parameter forvehirle or equipment maiutenattce areas in which more than 55 gallons ofmotor oil and/or hydraulic oil are used per month: NCOIL New Motor Oil or Hydraulic Oil gaI/month semi-annual Estimate Usage It sounds like you are at the stage of working with the Raleigh Regional Office on next steps. The Stormwater contact at RRO is Thad Valentine, and the Regional Supervisor is Bill Denton. 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 bethany.geor ouliasgncdenr.gov 512 N. Salisbury Street, Raleigh, NC 27604 (location) 1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing) Website: httn://dea.nc.aov/about/divisions/enerav-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: David Kannianen<David.Kannianen@Kennametal.com> Sent: Friday, May 03, 2019 1:19 PM To: Georgoulias, Bethany <bethany.georgoulias@ncdenr.gov> Cc: David Kannianen <David.Kan nianen@KennametaLcom> Subject: RE: [External] Questions about Permit #NCS000171 External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attac0MV report.spam@nc.gov Thank you for the quick response. I have a more lengthy question for you about my other facility in Weldon (Permit # NCG030151). I have a question about who to contact for assistance in reference to our Stormwater permit #NCG030151, for our facility located and 100 Kennametal Rd., Weldon NC 27890. We have had 3 sampling event since December 2017 where we have exceeded one or more of our benchmark limits. As per general permit NCG030000 we have reported and complied with sampling and reporting to the Tier Two level of sampling. Within the Tier Two guidelines, line 4, states: "Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances, exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier Three. The Regional Engineer may direct the response actions on the part of the permittee as provided in Tier Three, including reduced or additional sampling parameters or frequency." We have communicated with the Stormwater divisions office our concerns related to other area facilities storm water flowing onto our property and their activities that we feel are contributing to our benchmark exceedances (copper and zinc). Here are some of our previous notes: We have external contributing factors, I feel are impacting our sampling points. • Our neighbor across the street to the right is a metals fabricator and distributor. We continually see them grinding and sandblasting metal I -Beams and other metal parts in their gravel lot. Their storm water flows onto our property • To the right of us is a rubber manufacturer (Patch Rubber) and their storm water flows towards our property and into the same stream that flows along the back property line. • We are also less than a % mile from the interstate and subject to whatever debris may get washed off of those roads. Recent sampling results: Permit limits: Copper — 0.007 mg/L Lead — 0.033 mg/L Zinc — 0.067 mg/L Sampling from front of property (runoff from metals fabricator): Roads Copper — 0.044 mg/L Lead — 0.063 mg/L Zinc — 1.49 mg/L 3 Ourout Sampling from our outfall at back of property: Copper — 0.007 mg/L Lead - <0.010 mg/L Zinc — 0.089 mg/L Other key points: 410 Stre a m 1. We do not perform any manufacturing activities outside. 2. All containers, i.e., dumpsters, barrel storage areas, etc., are covered and not exposed to runoff. 3. We do not process any materials that contain copper or zinc. 4. Our parking lots in the front and rear of building do not show any excessive or abnormal signs of leaking vehicles. Because of these facts we have applied for a Non -Exposure Self Certifying Permit. So finally to my question, what do we need to do now, contact your engineering personnel, continue monthly sampling, etc.? David Kannianen EHS Lead Henderson/Roanoke Rapids david.kannianen@kennametal.com T +1 252 430 3367 M +1 317 965 3776 F +1 252 430 3315 Kennametal Inc. 1 139 Warehouse Road I Henderson, NC 27537 1 www.kennametaI.com THIS COMMUNICATION IS INTENDED FOR THE SOLE USE OF THE PERSON TO WHOM IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. ANY DISSEMINATION, DISTRIBUTION OR DUPLICATION OF THIS COMMUNICATION BY SOMEONE OTHER THAN THE INTENDED RECIPIENT IS STRICTLY PROHIBITED. IF YOUR RECEIPT OF THIS COMMUNICATION IS IN ERROR, PLEASE NOTIFY THE SENDER AND DELETE THIS COMMUNICATION. Select the following link to view the Disclaimer in an alternate language. http://www.kennametal.com/en/about-us/disclaimer.html From: Georgoulias, Bethany <bethany.georgoulias@ncdenr.gov> Sent: Friday, May 3, 2019 12:42 PM To: David Kannianen <David.Kan nianen@KennametaLcom> Cc: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Subject: RE: [External] Questions about Permit #NCS000171 David, Our group has quite a back log of individual permits to be renewed, and this one is in that batch. We did receive the application on 2/2/2015, so the site should continue to operate under the expired permit. Lauren Garcia in our group is working through the renewal permits right now, but I'm not sure this one will come up in her queue. If you need to reference the current permit, it is here in our Laserfiche Repository. (The permit itself is here.) The benchmark concentrations (not the same as limits) are on p. 8 of 10 in Part 11. 1 hope this is helpful. 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: David Kannianen<David.Kannianen@Kennametal.com> Sent: Friday, May 03, 2019 12:22 PM To: Georgoulias, Bethany <bethany.georgoulias@ncdenr.gov> Subject: [External] Questions about Permit #NCS000171 External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Good Afternoon Bethany, I have a question for you about the status of our permit #NCS000171 for my Henderson facility. In the system it shows as being expired since 2016. 1 have heard from the previous EHS manager that our old permit was still in effect but just wanted to follow up with you to verify. If not what do I need to do? One more question about this permit, what are the bench mark limits for this permit? The benchmarks for my Roanoke Rapids facility change in November of 2018. David Kannianen EHS Lead Henderson/Roanoke Rapids david.kannianen@kennametal.com T +1 252 430 3367 M +1 317 965 3776 F +1 252 430 3315 Kennametal Inc. 1 139 Warehouse Road I Henderson, NC 27537 1 www.kennametaI.com THIS COMMUNICATION IS INTENDED FOR THE SOLE USE OF THE PERSON TO WHOM IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. ANY DISSEMINATION, DISTRIBUTION OR DUPLICATION OF THIS COMMUNICATION BY SOMEONE OTHER THAN THE INTENDED RECIPIENT IS STRICTLY PROHIBITED. IF YOUR RECEIPT OF THIS COMMUNICATION IS IN ERROR, PLEASE NOTIFY THE SENDER AND DELETE THIS COMMUNICATION. Select the following link to view the Disclaimer in an alternate language. http://www.kennametal.com/en/about-us/disclaimer.html THIS COMMUNICATION IS INTENDED FOR THE SOLE USE OF THE PERSON TO WHOM IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. ANY DISSEMINATION, DISTRIBUTION OR DUPLICATION OF THIS COMMUNICATION BY SOMEONE OTHER THAN THE INTENDED RECIPIENT IS STRICTLY PROHIBITED. IF YOUR RECEIPT OF THIS Wei 15115LEI ►LL illILai ►0171►0a M-i NJ Film J4Ri'm; k"Lem IIWMIF. IRMa►PA Will ►I■1■Ja4awIF. IFx 1.JLTuLYAP1►IlolaIl.J►N Select the following link to view the Disclaimer in an alternate language. http://www.kennametal.com/en/about-us/disclaimer.html