NCG030698_Emails RE Outfall Monitoring_20200727

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Monday, July 27, 2020 3:45 PM
To: Cody Butcher
Subject: RE: [External] Stormwater Questions
Attachments: NCG030698_permit-info.pdf
Hi, Cody,
Our BIMS permit system only shows two outfalls for this facility. See attached. Are these actually 2 & 3 you reference
below, or do you think one of them is from the adjacent facility?
The outfall 1 you describe as draining an adjacent facility is excluded from the scope of your NPDES permit if it is entirely
outside your facility area and absent of any industrial activities or materials from your facility. The specific outfalls are
not anywhere except in this database, so we don't need to modify any permit documents. You really just need to stop
monitoring, revise any relevant SPPP information to exclude it (document why), and make sure we have the correct
information in our permit system. Only outfalls that drain stormwater associated with your facility's industrial activities
are subject to NCG030000 permit monitoring. We are preparing to on -board stormwater permit -holders into eDMR
next year, so we do want to get it straight before then.
If monitoring this outfall does not serve its initial intended purpose (to establish background concentrations for the
outfall that mixes with your facility, maybe?), then I recommend that you stop monitoring there.
Regards,
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
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. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. 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: Cody Butcher [mailto:[e-mail]]
Sent: Monday, July 27, 2020 9:55 AM
To: Georgoulias, Bethany <[e-mail]>
Subject: RE: [External] Stormwater Questions
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Hi Bethany,
I hope you had an awesome weekend!
I wanted to reach out to ask a few questions about potentially removing a stormwater outfall from one of our newer
facilities. The COC No. for our stormwater permit at that facility is NCG030698.
The facility is a smaller one and it contains 3 outfalls. I will outline what each outfall is monitoring below because each
one is slightly different.
1. Outfall 1 is monitoring the stormwater runoff of an adjacent facility.
2. Outfall 2 is monitoring runoff from our facility, but does include runoff from the adjacent facility.
3. Outfall 3 is monitoring runoff from only our facility.
To my understanding, outfall 1 was established simply as an `insurance policy' to have proof of the other facility causing
an exceedance on our benchmarks. My question is, assuming that it is possible to remove an outfall, do you suggest
keeping Outfall #1? The process of gathering grab samples from this outfall location is quite labor intensive and would
require some construction costs to improve. Also, TTO tests must be performed at each outfall making stormwater lab
expenses pretty high. I would love to remove this outfall from our permit if it is possible.
Please let me know if you have any questions or need clarification. Thank you!
Cody Butcher
EHS Associate
Building Construction Products Division
5000 Womack Road Sanford, NC 27330
Office: [phone]
Cell: [phone]
butcher cods [e-mail]
Caterpillar: Confidential Green
From: Georgoulias, Bethany <[e-mail]>
Sent: Thursday, July 9, 2020 9:12 AM
To: Cody Butcher <Butcher Cody [e-mail]>
Subject: RE: [External] Stormwater Questions

NC Division of Energy, Mineral and Land Resources
NPDES Stormwater Permit Summary
NC DEMLR has the following information in our Permit Database for your permit as of 7/27/2020.
Permit Number: NCG030698
Permit Type: Metal Fabrication Stormwater Discharge COC
Facility Name: Caterpillar Inc.
Facility Addressl: 2018 Boone Trail Rd
Facility Address2:
City, State & Zip: Sanford, NC 27330
Owner Information Details:
MUST submit a Change of Name/Ownership form to DEMLR to make any changes to this Owner information.
(Click Here for "Change of Name/Ownershka"Form)
Owner Name: Caterpillar Inc
Owner Type: Non -Government Owner Type Group: Organization
*** Legally Responsible for Permit ***
(Responsible corporate officer/principle executive officer or ranking elected official/general partner or proprietor;
or any other person with delegated signatory authority from the legally responsible person.)
Owner Affiliation: Kevin Staubus Title:
Addressl: 5000 Womack Rd
Address2:
City, State & Zip: Sanford, NC 27330
Work Phone: [phone] Fax:
Email Address: staubus [e-mail]
*** Permit Annual Fee Billing ***
Billing Month: July
Invoice Number Invoice Date Invoice Due Date Invoice Amount Invoice Status
2020PR004733 6/2/2020 7/2/2020 $100.00 Overdue
Owner Contact Person(s)
Contact Name Title Address Phone Fax Email
Brad Crace 5000 Womack Rd, Sanford, NC 27330 919-777-2274
Facility Contact Person(s)
Contact Name Title Address Phone Fax Email
Kevin Staubus 2018 Boone Trail Rd, Sanford, NC 27330 919-777-2274 staubus_kevin@cat.
com
Permit Contact Person(s)
Contact Name Title Address Phone Fax Email
Kevin Staubus 2018 Boone Trail Rd, Sanford, NC 27330 919-777-2274 staubus_kevin@cat.
7/27/2020 Page 1

NC Division of Energy, Mineral and Land Resources
NPDES Stormwater Permit Summary
NC DEMLR has the following information in our Permit Database for vour Dermit as of 7/27/2020.
Permit Billing Contact(s)
Contact Name Title Address Phone
Fax Email
Kevin Staubus 2018 Boone Trail Rd, Sanford, NC 27330 919-777-2274 staubus_kevin@cat.
Corn
Person(s) with Delegated Signatory Authority
Type Contact Name Title Address Phone
Fax Email
Person(s) with Electronic Signature Authority
Type Contact Name Title Address Phone
Fax Email
Outfalls
Outfall #: 001 Outfall Description: Stormwater outfall 1
Outfall Lattitude: 35.523890 Outfall Longitude:-79.220280
Represented by Outfall:
% Stormwater: 100 % Industrial:
Stream Waterbody
Basin Waterbody Name
Index Number Classification
Cape Fear Big Buffalo Creek
17-40 C
Outfall #: 002 Outfall Description: stromwater outfall 2
Outfall Lattitude: 35.524440 Outfall Longitude:-79.220280
Represented by Outfall:
% Stormwater: 100 % Industrial:
Stream Waterbody
Basin Waterbody Name
Index Number Classification
Cape Fear Big Buffalo Creek
17-40 C
7/27/2020 Page 2

No, there is no exemption for previous levels below the threshold. Only for having the solvent management plan.
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
bethany.georgoulias@ncdenngov
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
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. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. 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: Cody Butcher [mailto:Butcher Cody [e-mail]]
Sent: Thursday, July 9, 2020 9:10 AM
To: Georgoulias, Bethany <[e-mail]>
Subject: RE: [External] Stormwater Questions
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Bethany,
TTO has been analyzed a few times at the facility. I've attached the two latest TTO lab reports for reference. If our TTO
levels are low for a certain number of sampling periods, is it possible to become exempt from the test?
Thank you,
Cody Butcher
EHS Associate
Building Construction Products Division
5000 Womack Road Sanford, NC 27330
Office: [phone]
Cell: [phone]
butcher cods [e-mail]

Caterpillar: Confidential Green
From: Georgoulias, Bethany<[e-mail]>
Sent: Wednesday, July 8, 2020 2:43 PM
To: Cody Butcher <Butcher Cody [e-mail]>
Subject: RE: [External] Stormwater Questions
Cody, I don't think the solvent management plan needs to be certified, but check the permit SPPP to be sure of the
details. I am not aware of a definitive list for this permit, but that list of chemicals is 40 CFR 433.11 is a good reference
point; it's where I would start. Whether or not you have time to develop a solvent management plan before the
sampling period ends will dictate whether your sample/analyze for TTO, yes. Do you know whether TTO has been
analyzed for this permit before now, or is this a new permit?
Bethany
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
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. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. 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: Cody Butcher [mailto:Butcher Cody [e-mail]]
Sent: Wednesday, July 8, 2020 9:20 AM
To: Georgoulias, Bethany<[e-mail]>
Subject: RE: [External] Stormwater Questions
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Bethany,
Thank you for this information!

Is there anything that needs to be done to certify a solvent management plan? Also, is there a list of the solvents that
must be included in the plan, or is itjust any chemical that contains any percentage of the toxins outlined in 40 CFR
433.11 fecfr.govl?
And assuming that a solvent management plan takes time to implement, does our facility need to test TTO at each
outfall?
Thank you!
Cody Butcher
EHS Associate
Building Construction Products Division
5000 Womack Road Sanford, NC 27330
Office: [phone]
Cell: [phone]
butcher cods [e-mail]
Caterpillar: Confidential Green
From: Georgoulias, Bethany <[e-mail]>
Sent: Wednesday, July 8, 2020 8:13 AM
To: Valentine, Thad <[e-mail]>; Cody Butcher <Butcher Cody [e-mail]>
Subject: RE: [External] Stormwater Questions
Cody,
Keep in mind that TTO testing is waived if the facility puts a Solvent Management Plan in place.
all==Zed representative UMnedlateipupan request
10. Solvent Management Plan. Faaiities that implement a Solvent Management Plan may so
certify, and the requirement for Total Toxic Organics (TTO) monitoring in Fart IL Section E
may be wailed, The Solvent Management Plan shall include:
(a) an annually updated and quantified inventory of the totalto:Fdc organic compounds
present on site during the previou3 three }-ears;
(b) anarrative desniption oFthe in-plantlocations and uses ofthe tondc organic
compounds, the method of disposal including quantities disposed on- and off -site;
(c) the managementprocedures and engineering measures for assuring that to do
organics do not spill or leak into stormwater.
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
D, E Q
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. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. 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: Valentine, Thad
Sent: Wednesday, July 8, 2020 8:02 AM
To: Cody Butcher <Butcher Cody [e-mail]>
Cc: Georgoulias, Bethany<[e-mail]>
Subject: RE: [External] Stormwater Questions
Cody
Bethany Georgoulias at the Central office can probably answer that question for you. Please contact her
From: Cody Butcher <Butcher Cody [e-mail]>
Sent: Tuesday, July 07, 2020 4:05 PM
To: Valentine, Thad <[e-mail]>
Subject: [External] Stormwater Questions
off • r External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
ort.s am nc. ov
Hi Thad!
My name is Cody Butcher and I am the EHS associate at Caterpillar Inc. in Sanford, NC.
I had a few questions about the analytical monitoring requirements for our Stormwater permits, COC: NCG030447 and
COC: NCG030698
1. In talking with local labs for stormwater sampling, the topic has come up of whether or not to test Total Toxic
Organics. The permit states in Footnote #6 that TTO is only applicable for "facilities which perform metal
finishing operations, manufacture semiconductors, manufacture electronic crystals, or manufacture cathode ray
tubes". I believe that our facility would be considered a 'metal finishing operation', but in order to prevent
unnecessary spending, I'd like to make sure that we do in fact need to be testing for it. Is there any way for me
to confirm that our site does in fact meet the requirements to test for TTO?
2. Assuming that our facilities do need to be tested for TTO, does that mean that we must test for it at each
outfall? Our smaller facility has 3 outfalls and the TTO test is an expensive one. Does the permit require TTO to
be tested at each outfall?
Thank you in advance for your help and I hope you are staying safe and healthy!

Cody Butcher
EHS Associate
Building Construction Products Division
5000 Womack Road Sanford, NC 27330
Office: [phone]
Cell: [phone]
butcher cods [e-mail]
Caterpillar: Confidential Green