NCG081012_Permit Requirement Clarification and Consideration_20230331

Chandler, Jeffrey A
From:Kate Fleming <[e-mail]>
Sent:Friday, March 31, 2023 11:28 AM
To:Eplin, Jerry W; Josh Brooks
Cc:Khan, Zahid; Chandler, Jeffrey A
Subject:RE: \[External\] Permit Requirement; Clarification and Consideration
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Mr. Eplin,
Thank you for the clarification and response. We will look into the options you indicated in regards to the
representative outfall status. ~Kate Fleming

From: Eplin, Jerry W \[mailto:[e-mail]\]
Sent: Friday, March 31, 2023 11:20 AM
To: Kate Fleming <[e-mail]>; Josh Brooks <[e-mail]>
Cc: Khan, Zahid <[e-mail]>; Chandler, Jeffrey A <[e-mail]>
Subject: RE: \[External\] Permit Requirement; Clarification and Consideration

Ms. Fleming:

I was forwarded your email concerning clarification and consideration related to NCG080000.

Your email indicates that your monitoring activities do not indicate exceedances of the benchmark values listed in
NCG080000 and that you do not believe the monitoring requirements apply for the reasons you listed in your email.

We disagree with your arguments against monitoring.

1) The goal for all benchmark monitoring is to have results that are below the benchmark. We cannot grant relief
from monitoring because of results that are below the benchmark.

2) It is true the monitoring requirements in Section E of the referenced permit apply when new oil usage is more
than 55 gallons per month. However, Section F of the referenced permit applies to discharges from oil/water
separators and secondary containment areas. The monitoring requirements in Section F do not refer to the 55
gallon / month trigger, thus they are applicable regardless of oil usage.

If qualitative and quantitative monitoring are not conducted according to the referenced permit, you would be in
violation of that permit.

However, you may want to review your site and determine 1) whether Section F from your permit applies to both
outfalls or just one, and/or 2) whether you should request representative outfall status so that you could reduce your
monitoring requirements to just one outfall.

Let me know if you have additional questions.

Regards,

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Jerry W. Eplin, PE
Assistant Regional Engineer

North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources

Office: [phone] x2147
Email: [e-mail]

Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties

From: Kate Fleming <[e-mail]>
Sent: Tuesday, March 28, 2023 12:52 PM
To: Khan, Zahid <[e-mail]>
Cc: Josh Brooks <[e-mail]>
Subject: \[External\] Permit Requirement; Clarification and Consideration

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Report Spam.

Mr. Khan,

As a follow-up to the voicemails left between you & I earlier today, Union County Water is requesting
clarification from DEMLR in regards to the current quantitative monitoring that we are conducting at our Operations
Center facility. The Union County Water Operations Center was issued a General Stormwater Permit NCG080000; COC #
NCG081012 on July 1, 2021. After reaching out to the State for clarification on sampling requirements it was verbally
indicated from DEMLR staff that sampling for pH, TSS & SGT-HEM should be conducted on a quarterly basis due to an oil
water separator onsite and bulk fuel containment. The Union County Operations Center does not have vehicle or
equipment maintenance activities occurring onsite that use more than 55 gallons of new motor oil and/or hydraulic oil
per month. The vehicle wash area activities are contained under a roof and all wash water is directed to the sanitary
sewer. Opportunity for wash water to contact Stormwater is negligible. The bulk fuel containment consist of a double
walled 5,000 gal diesel fuel AST and a 1,000 gal unleaded gasoline bulk tank. Union County Water has contracted with
Hazen & Sawyer and they have conducted inspections of our site and have prepared a SWPPP for this facility. At this
time Hazen is in agreeance that the quantitative requirement should not pertain to this facility based on the information
listed above in conjunction with excellent on site housekeeping and minimal opportunity for Stormwater impact from
the Union County Water Operations Center.
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In addition, we have conducted quantitative and qualitative monitoring for the past year with the most recent
sampling occurring on 3/22/23. All quantitative results with the exception of the data from 3/22/23 is attached for your
review. We will be submitting the SWPPP for review to Brian Wrenn and will be copying you on the submittal once the
final formatting edits have been made. After submittal of the SWPPP it is Union County Waters’ intent to no longer
conduct quantitative monitoring at this site based on the rationale above. Once we have submitted the SWPPP and
DEMLR has had the opportunity to review the document, please respond and indicate if you find this approach to be
correct and adequate going forward. Thank you.

Kate Fleming
Industrial Pretreatment Program Manager

O 704.296.4286
C 980.425.0735
[e-mail]
www.unioncountync.gov

Union County Government
Public Works – Water & Wastewater
8299 Kensington Drive
Waxhaw, NC 28173

E-mail correspondence to and from this sender may be subject to the North Carolina
Public Records law and may be disclosed to third parties. If you are not the intended
recipient of this e-mail, please contact the sender immediately.

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