NCG090023_Emails RE 72 Hr Interval Sampling Exception_20230621

Georgoulias, Bethany
From: Dillon D Wilkie <[e-mail]>
Sent: Wednesday, June 21, 2023 12:16 PM
To: Georgoulias, Bethany
Cc: Barry J Sparks; Lawyer, Mike; Khan, Zahid; Cook, Brittany
Subject: RE: [External] Authorization Needed To Sample Outside of 72 Hour Storm Interval
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Bethany,
This makes sense. We will work to pull the samples as we are able and ensure we document the situation in a cover
letter.
From: Georgoulias, Bethany <[e-mail]>
Sent: Wednesday, June 21, 2023 12:06 PM
To: Dillon D Wilkie <[e-mail]>
Cc: Barry J Sparks <[e-mail]>; Lawyer, Mike <[e-mail]>; Khan, Zahid
<[e-mail]>; Cook, Brittany <[e-mail]>
Subject: RE: [External] Authorization Needed To Sample Outside of 72 Hour Storm Interval
Dillon,
I think this section only applies when a 72-hour period was not representative of the events during the entire sampling
period. If you think that was the case for the entire quarter since April 1(and not just this last month), then it's
appropriate to ask for approval from the Regional Office (I'm copying Zahid Khan, who is the Regional Supervisor at the
Mooresville Regional Office) for modifying the sample protocol.
If earlier opportunities were missed, and this last weather pattern has made it challenging to meet the quarter's
deadline, I would take the samples as you can and just document in a cover letter why you couldn't adhere to the 72-hr
interval (flash flooding conditions prevented safe sampling conditions). We certainly would also want you get that
sample instead of no sample. This type of written approval is intended for a quarter where the typical rain pattern
during that whole period just didn't conform to a more typical one where a 72-hr interval is more likely to happen.

E-3. Methodology for Collecting Samples
(a) OutfalI monitoring efforts shall begin with the first measurable storm event in the
monitoringperiod that meets all the following conditions:
i. Occurs at least 72 hours after the previous measurable storm event
unless E-3 (b) applies,
ii. Occurs during the facility's normal operating hours,
iii. Does not coincide with adverse weather conditionsand
iv. Is characteristic of the volume and nature of the permitted discharge.
(b) The 72-hour storm interval may not apply iE
i. The permittee is able to document that a shorte r i nterval is representative far
local storm events during the sampling period, and
ii. The permittee obtains approval from the Division's Regional Office.
iii. After authorization by the Division's Regional OMce, a written approval letter
must be kept on site in the permittee's SWPPP.
Page 12 of 34
I hope this information helps.
Best regards,
Bethany Georgoulias (she/her)
Environmental Engineer, Stormwater Program
DEMLR Laserfiche Administrator
Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
[e-mail]
Permit No. MCG090000
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses
may look different, but email performance will not be impacted.
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/stormwatgr
From: Dillon D Wilkie <[e-mail]>
Sent: Wednesday, June 21, 2023 9:30 AM
To: Georgoulias, Bethany<bethany.georgoulias@deg. nc.gov>

Cc: Barry J Sparks <bsparks@vaIspar. com>; Lawyer, Mike <mike.Iawyer@deg. nc.gov>
Subject: RE: [External] Authorization Needed To Sample Outside of 72 Hour Storm Interval
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Awesome, thanks for the quick responses!
We will plan to take samples as we are able. We believe some samples will be better than none.
From: Georgoulias, Bethany<[e-mail]>
Sent: Wednesday, June 21, 2023 9:29 AM
To: Dillon D Wilkie <[e-mail]>
Cc: Barry J Sparks <[e-mail]>; Lawyer, Mike <[e-mail]>
Subject: RE: [External] Authorization Needed To Sample Outside of 72 Hour Storm Interval
Our GP coordinator is out, but I will take a look this afternoon when my meeting schedule opens up. It may be approval
that comes from the regional office. In the meantime, I would plan to take samples as you are able.
Best regards,
Bethany Georgoulias (she/her)
Environmental Engineer, Stormwater Program
DEMLR Laserfiche Administrator
Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
[e-mail]
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses
may look different, but email performance will not be impacted.
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
From: Dillon D Wilkie <[e-mail]>
Sent: Wednesday, June 21, 2023 9:25 AM
To: Georgoulias, Bethany<[e-mail]>
Cc: Barry J Sparks <[e-mail]>
Subject: RE: [External] Authorization Needed To Sample Outside of 72 Hour Storm Interval
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
GENERAL PERMIT NO. NCG090000 — Section E-3 (b) ii-iii.

From: Georgoulias, Bethany<[e-mail]>
Sent: Wednesday, June 21, 2023 9:22 AM
To: Dillon D Wilkie <[e-mail]>
Cc: Barry J Sparks <[e-mail]>
Subject: RE: [External] Authorization Needed To Sample Outside of 72 Hour Storm Interval
Dillon,
That's understandable. What permit are you under, and what section requires Division approval so I can take a look at
it?
Bethany Georgoulias (she/her)
Environmental Engineer, Stormwater Program
DEMLR Laserfiche Administrator
Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
[e-mail]
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses
may look different, but email performance will not be impacted.
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
From: Dillon D Wilkie <[e-mail]>
Sent: Wednesday, June 21, 2023 9:13 AM
To: Georgoulias, Bethany<[e-mail]>
Cc: Barry J Sparks <[e-mail]>
Subject: [External] Authorization Needed To Sample Outside of 72 Hour Storm Interval
Importance: High
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
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Bethany,
I hope this email finds you well.
I am writing this to inform you that due to not having measurable storm events thus far during the sampling period, we
will need to pull our samples today to be sure we can deliver on our deadline of 6/30 for the end of the sampling period.
We would have grabbed our samples yesterday to meet the 72 hour requirement, however due to flash flood warnings,
we were not able to do so safely. We'd like to be able to pull samples this period, and the 10 day forecast shows no 72
hour break between events.
Per our stormwater permit, we will need a written approval letter from the division office to do this — are you able to
provide?
Thank you!

Dillon Wilkie
Environmental, Health and Safety Specialist
The Sherwin Williams Company
Office: 704-808-4023
Mobile: [phone]
Email: [e-mail]
188 Side Track Drive, Statesville, NC, 28625
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.