NCS000508_Email_20191209

Garcia, Lauren V
From: Darling, Richard <[e-mail]>
Sent: Monday, December 09, 2019 11:29 AM
To: Garcia, Lauren V
Cc: rossera; elmorel; Lorin Akins; hodgesk; bishopc; Howard Keville ([e-mail]);
kuhnm; blineback
Subject: RE: [External] RE: EXTERNAL: NCS000508 Permit Renewal
Ul"r."rExternal email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
ort.s am nc. ov
Thanks Lauren — I will get back with you tomorrow with any additional PTAA comments on the draft permit. Thanks.
Richard
From: Garcia, Lauren V <[e-mail]>
Sent: Monday, December 9, 2019 9:50 AM
To: Darling, Richard <[e-mail]>
Cc: rossera <[e-mail]>; elmorel <elmorel @gsoair.org>; Lorin Akins <[e-mail]>; hodgesk
<[e-mail]>; bishopc <[e-mail]>; Howard Keville ([e-mail]) <[e-mail]>;
kuhnm <[e-mail]>; blineback <[e-mail]>
Subject: RE: [External] RE: EXTERNAL: NCS000508 Permit Renewal
Hi Richard,
I got approval today for PTI to continue submitting its own version of the DMRs and to keep representative storm events
in the permit. Let me know what you think about the amended draft I sent last week. Once I hear back, I can get it to my
supervisor's desk for a signature.
Thanks,
Lauren
From: Garcia, Lauren V
Sent: Thursday, December 05, 2019 10:56 AM
To: Darling, Richard <[e-mail]>
Cc: rossera <[e-mail]>; elmorel <elmorel @gsoair.org>; Lorin Akins <[e-mail]>; hodgesk
<[e-mail]>; bishopc <[e-mail]>; Howard Keville ([e-mail]) <[e-mail]>;
kuhnm <[e-mail]>; blineback <[e-mail]>
Subject: RE: [External] RE: EXTERNAL: NCS000508 Permit Renewal
Hi Richard,
I am fast tracking getting your permit ready before January. I addressed your comments in the attached draft. Do you
have time to review it and see if additional changes are needed? I highlighted changes (comments and template
changes) in yellow.
I am waiting on the approval to keep sampling under representative storm event in the permit, but I went ahead and put
it in the permit. Also, thank you for pointing out the address in the DMR form. We will correct this on the website.

Thanks,
Lauren
From: Darling, Richard <[e-mail]>
Sent: Friday, November 15, 2019 4:05 PM
To: Garcia, Lauren V <[e-mail]>
Cc: rossera <[e-mail]>; elmorel <elmorel @gsoair.org>; Lorin Akins <[e-mail]>; hodgesk
<[e-mail]>; bishopc <[e-mail]>; Howard Keville ([e-mail]) <[e-mail]>;
kuhnm <[e-mail]>; blineback <[e-mail]>
Subject: RE: [External] RE: EXTERNAL: NCS000508 Permit Renewal
External email. Do not click links or open attachments unless yoi
[e-mail]
Thanks Lauren — that helps us a lot.
From: Garcia, Lauren V <[e-mail]>
Sent: Friday, November 15, 2019 3:48 PM
To: Darling, Richard <[e-mail]>
Cc: rossera <[e-mail]>; elmorel <elmorel @gsoair.org>; Lorin Akins <[e-mail]>; hodgesk
<[e-mail]>; bishopc <[e-mail]>; Howard Keville ([e-mail]) <[e-mail]>;
kuhnm <[e-mail]>
Subject: RE: [External] RE: EXTERNAL: NCS000508 Permit Renewal
Good afternoon Richard,
I am sorry for the wait, we have gotten delayed with inspections and public hearings. I received your voicemail. I have
not had the time to find answers/address all of the comments on the draft permit; however, I can address the questions
below:
1) Will the new permit become effective beginning next year (1/1/2020)?
1 am expecting to have the final permit on my supervisor's desk for signature in December, so we are expecting the new
permit to be active January 1, 2020.
2) Will deicing event monitoring for the new permit be required quarterly or maintained at the current four times
per year?
I did not mean to format the draft permit so that it seemed the schedule for deicing would change with the new permit.
The deicing monitoring schedule was not supposed to change and will remain the same as the current 4 times per year.
The permit will be updated to reflect this change.
I have been in and out of the office quite a lot in the past few weeks, but I should be mostly at my desk Monday,
Tuesday, and Friday next week, or I can be reached by email.
Thanks!
Laruen
From: Darling, Richard <[e-mail]>
Sent: Wednesday, October 30, 2019 3:14 PM

To: Garcia, Lauren V <[e-mail]>
Cc: rossera <[e-mail]>; elmorel <elmorel @gsoair.org>; Lorin Akins <[e-mail]>; hodgesk
<[e-mail]>; bishopc <[e-mail]>; Howard Keville ([e-mail]) <[e-mail]>;
kuhnm <[e-mail]>
Subject: RE: [External] RE: EXTERNAL: NCS000508 Permit Renewal
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Hello Lauren:
Just wanted to see if you had any questions regarding our comments (below) on the draft permit or needed anything
additional from us for the permit renewal? In order to assist our planning for next year, would you be able to respond to
a few questions:
• Will the new permit become effective beginning next year (1/1/2020)?
Will deicing event monitoring for the new permit be required quarterly or maintained at the current four times
per year?
Thanks again for your assistance and please do not hesitate to call me at any time.
Richard
Richard Darling I Project Manager - Environmental
0 ,o��o.o��m�uum;o mss�sn�Fo;;9�so°�os�.,o.���,oF�.o 200 Centreport Drive, Suite 350 1 Greensboro, NC 27409 1 [O] 919-481-5740 1 [M] 808-
366-1971
[e-mail] I www.mbakerintl.com
From: Darling, Richard
Sent: Friday, September 27, 2019 4:45 PM
To: Garcia, Lauren V <[e-mail]>
Cc: Alex Rosser <[e-mail]>; Lisa Elmore <[e-mail]>; Lorin Akins <[e-mail]>; Kimberly
Hodges <[e-mail]>; Chris Bishop <[e-mail]>; Howard Keville ([e-mail])
<[e-mail]>; Michael Kuhn <[e-mail]>
Subject: RE: [External] RE: EXTERNAL: NCS000508 Permit Renewal
Thank -you Lauren:
The Piedmont Triad Airport Authority (PTAA) reviewed the subject draft permit e-mailed on August 27, 2019 and have
the following comments regarding changes from the facility's (Piedmont Triad International Airport, GSO) current
permit:
1. You are required to collect analytical and qualitative monitoring samples during "measurable storm events" as
defined in Part II, Section B. This term is different from the "representative storm event" in earlier permits.
Based on the logistic difficulty of viewing all SDOs at every rainfall required to determine a "measurable storm event" at
each location, PTAA requests that a "representative storm event" of 0.1 inch be continued to determine collection of
analytical and qualitative monitoring samples.
2. Requirements for the Stormwater Pollution Plan (SPPP) have been updated in Part II, Section A.
Item 8(d), annual review and comparison of sample analytical data to benchmark values, will be added to the SPPP.
3. Changes have been made to several monitoring parameters, including a change to two benchmarks. Stormwater
benchmarks are not permit limits, but rather guidelines for implementing the Stormwater Pollution Prevention
Plan (SPPP). A benchmark exceedance is not a permit violation; however, the permittee must respond to
exceedances as directed in the Tiers.

Vehicle maintenance (Tables 5,6) monitoring parameters have been revised as follows:
• Non -Polar Oil & Grease [EPA Method 1664 (SGT-HEM)] replaces Oil & Grease/TPH. The benchmark for
Non -polar Oil & Grease using this method is 15 mg/L. This requirement appears in all individual
stormwater permits; however, it only applies to facilities that perform onsite vehicle maintenance
activities. If the facility begins vehicle maintenance during the permit cycle, the requirements shall
apply.
• pH monitoring is no longer required for discharges only associated with vehicle maintenance activities
Change of ethylene glycol benchmark from 14,000 mg/L to 8,000 mg/L is noted.
PTAA will monitor Non -Polar Oil & Grease [EPA Method 1664 (SGT-HEM)] at SDOs for those GSO facilities performing
vehicle maintenance.
4. Tiered responses have been added to this permit. Exceedances of benchmark values require the permittee to
increase monitoring, increase management actions, increase record keeping, and/or install stormwater Best
Management Practices (BMPs) in a tiered program in accordance with Part II, Section B of this permit.
PTAA has been applying the tiered response protocols specified in our current permit. Tier Two response will be revised
to include monthly monitoring of all parameters or DEMLR Regional Engineer notification per Tier Three.
5. A new section on Special Conditions has been added in Part II, Section E to comply with federal regulations
requiring electronic submittal of discharge monitoring reports.
PTAA's current report format and qualitative monitoring form include the information requested for the Discharge
Monitoring Reports (DMRs). This comprises a cover sheet summarizing salient sample collection conditions with the
field and laboratory results attached. PTAA is requesting continued use of the current format until notified that the
eDMR is ready to accept stormwater monitoring data. The DMR format online specifies submittal of the original and
one copy to Central Files whereas the draft permit specifies one signed copy to the Regional Office.
6. Civil and administrative penalty amounts have been updated to reflect current federal law in Part III, Section A,
2(b) and (g).
Updated penalty amounts are noted. Part III, Section A, 2(a) is not identified in the draft permit.
Additional comments are provided in the attached draft permit pages with comments and summarized as follows:
• Correct permittee and facility address is 1000A Ted Johnson Parkway.
• Due to monitoring contract obligations under the existing permit, PTAA requests the renewed permit and
discharge monitoring become effective January 1, 2020.
• Please confirm that Deicing Event Monitoring is now required quarterly rather than four times per season
(current). Quarterly monitoring would likely result in a maximum of two deicing monitoring events per year due
to the seasonality of deicing activities.
• Current stormwater discharge outfall (SDO) locations and representative outfall status were provided in the
2014 renewal application, but do not appear correctly included on the draft permit map or applicable tables.
• Co-Permittees (based on industrial activities) are currently listed as follows:
1. American Airlines
2. Avis/Budget RAC
3. Delta Airlines
4. Delta Global Services (Delta Airlines)
5. Enterprise/Alamo/National RAC
6. Fed Ex
7. GAT (United Airlines)
8. HAECO Americas
9. Hertz RAC
10. Honda Aircraft Company, Inc.
11. J BT
12. Jetstream Air, LLC (American Airlines)
13. Koury Aviation FBO, LLC
14. Piedmont Triad Airport Authority Maintenance
15. Quantem Aviation Services, Inc. (DHL, Spirit, Allegiant Airlines)
16. Samaritan's Purse

17. Signature Flight Support
18. Snider Tire
19. Swift
20. Textron Aviation (Cessna Citation)
21. United Airlines
22. United Parcel Service
Table 10 appears to be mislabeled as well as the second footnote thereto.
• It is understood that the Annual Summary Data Monitoring Reports required under Part III, Section E, Items 1
and 2 of the current permit have been replaced by the annual review and comparison of sample analytical data
to benchmark values to be added to the SPPP under Part II, Section A, Item 8(d).
We appreciate your time at our facility on September 18 and consideration of our comments on the draft permit. Please
feel free to contact me or Alex Rosser with questions or comments.
Sincerely
Richard
Richard Darling I Project Manager - Environmental
,00.o�m�uum;o mss�sn�Fo;;9�so°�os.,o.�,oF.o 200 Centreport Drive, Suite 350 1 Greensboro, NC 27409 1 [O] 919-481-5740 1 [M] 808-
366-1971
[e-mail] I www.mbakerintl.com
From: Garcia, Lauren V <[e-mail]>
Sent: Tuesday, August 27, 2019 10:00 AM
To: Darling, Richard <[e-mail]>
Cc: Alex Rosser <[e-mail]>; Lisa Elmore <[e-mail]>; Lorin Akins <[e-mail]>; Kimberly
Hodges <[e-mail]>; Chris Bishop <[e-mail]>; Howard Keville ([e-mail])
<[e-mail]>; Michael Kuhn <[e-mail]>
Subject: RE: [External] RE: EXTERNAL: NCS000508 Permit Renewal
Greetings Richard,
Thank you for all of this information! I have your draft permit ready for a 30-day comment period. Any concerns or
questions you have can be addressed during this time. The draft has also been sent to the Winston-Salem Regional
Office Contact for review and to another Central Office Contact. I will update you with their comments if there are any.
Thanks,
Lauren
From: Darling, Richard <[e-mail]>
Sent: Friday, August 23, 2019 1:53 PM
To: Garcia, Lauren V <[e-mail]>
Cc: Alex Rosser <[e-mail]>; Lisa Elmore <[e-mail]>; Lorin Akins <[e-mail]>; Kimberly
Hodges <[e-mail]>; Chris Bishop <[e-mail]>; Howard Keville ([e-mail])
<[e-mail]>; Michael Kuhn <[e-mail]>
Subject: [External] RE: EXTERNAL: NCS000508 Permit Renewal
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment ton
[e-mail]

Lauren — I did not update the permittee contact information online because neither the ownership, facility name, or
legally responsible person have changed. Attached is PDF of current permit contact information with updated
information provided as "comments". Please let me know any questions/comments. Thanks.
Richard
From: Darling, Richard
Sent: Thursday, August 22, 2019 2:15 PM
To: Garcia, Lauren V <[e-mail]>
Cc: Alex Rosser <[e-mail]>; Lisa Elmore <[e-mail]>; Lorin Akins <[e-mail]>; Kimberly
Hodges <[e-mail]>; Chris Bishop <[e-mail]>; Howard Keville ([e-mail])
<[e-mail]>; Michael Kuhn <[e-mail]>
Subject: RE: EXTERNAL: NCS000508 Permit Renewal
Lauren
Attached is an Excel spreadsheet with the discharge monitoring results since the effective date of the current
permit. Aside from this data update and potential changes to the list of co-permittees (Airport industrial tenants), our
renewal application of December 11, 2014 remains correct. Additional changes since the 2014 application include:
• Haeco Facility Improvements — new BMP (High Flow Rate Bioretention Pond) replaced old pond per DWR 401
Individual Water Quality Certification 4054 (SDO 006 replaced by SDO 06A). IS#08 moved to IS#8A per DEMLR
approval of March 9, 2016.
List of suggested co-permittees revised (to be updated pending tenant re -survey this month):
1. Avis/Budget RAC
2. Delta Global Services (Delta Airlines)
3. Enterprise/Alamo/National RAC
4. FedEx
5. Haeco
6. Hertz RAC
7. Honda
8. JBT
9. Jetstream (American Airlines)
10. Koury
11. Piedmont Triad Airport Authority Maintenance
12. Quantem (DHL, Spirit, A llegian t Airlines)
13. Samaritan's Purse
14. Signature Flight Services
15. Snider Tire
16. Swift
17. Textron (Cessna Citation)
18. GAT (United Airlines)
19. UPS
20. VF
Please note that the twenty potential co-permittees listed above are currently part of a re -survey of all Airport tenants
conducted every five years to determine industrial activity. This is in addition to the annual and semi-annual surveys
required by NCS000508. I will forward the results (Airport industrial tenants) of this survey once it has been completed
early next month. Please do not hesitate to contact me or Alex Rosser regarding NPDES compliance and renewal at
Piedmont Triad International Airport (GSO). Thanks.
Richard

Richard Darling I Project Manager - Environmental
200 Centreport Drive, Suite 350 1 Greensboro, NC 27409 1 [O] 919-481-5740 1 [M] 808-
366-1971
[e-mail] I www.mbakerintl.com
From: Garcia, Lauren V <[e-mail]>
Sent: Tuesday, August 6, 2019 8:24 AM
To: Darling, Richard <[e-mail]>
Subject: EXTERNAL: NCS000508 Permit Renewal
Greetings Richard,
I got your voicemail! Thank you for returning my call. I am working on renewing your facility's individual stormwater
permit (Permit No. NCS000508). There is some information I am required to ask you for to (1.) confirm that the
information I have is correct and (2.) make sure the permit adequality serves the needs of the facility.
What I need from you:
• A spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the
current permit;
• A verification that the information in the renewal application is still is still complete and correct; and
An explanation of any operational changes since the renewal application was submitted.
The following link will take you to an online search box where you will be able to enter your permit number and review
the facilities information to make sure it is correct:
https://reports.ncdenr.org/BOE/Open Document/1703191515/CrystalReports/viewrpt.cwr?id=25212&apsuser=BIMS U
&apspassword=blOMs cr%28ddnri59%29&apsauthtype=secEnterprise&cmd=EXPORT&EXPORT FMT=U2FPDF%3AO.
Information can be updated using the links provided below, where applicable:
Owner Update: https://edocs.deg.nc.gov/Forms/SW-Name-Change
Owner Affiliation (i.e., someone with the company who is designated to represent the company per signatory
requirements in the permit (e.g., CEO) or another authorized representative): https://edocs.deg.nc.gov/Forms/SW-
Owner-Affiliation
Company of Facility Name: https://edocs.deg.nc.gov/Forms/SW-Name-Change
What happens next:
• Once I have the above listed information, I will verify the draft permit information is correct;
• You will receive the draft for a 30-day comment period. During this time we will be able to address any
comments or concerns you have.
• During the same 30-day period, the draft will be sent to a Winston-Salem Regional Office staff member for
review and the permit draft will be published for Public Notice.
• Once all comments and concerns are addressed, you will be issued the final permit.
Feel free to contact me with any questions as well.
Thanks,
Lauren
Lauren Garcia
Environmental Specialist 11

Stormwater Program
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
919-707-3648 (0)
[e-mail]
DEMLR Stormwater Program
512 N. Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699-1612
1�-�-,��Nothing Compares]
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.