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Home My WebLink AboutNCG030000_Email to EPA RE Final GP Issuance_20181205Georgoulias, Bethany From: Georgoulias, Bethany Sent: Wednesday, December 05, 2018 12:41 PM To: 'Wahlstrom-Ramler, Meghan' Cc: Jones, Erica; Sampath, Sam; Davis, Molly; Lucas, Annette; Morman, Alaina; Anen, Steven C; Riddle, Rick L Subject: RE: [External] Summary of phone call regarding 6 general permits Meghan, We wanted to let EPA know that the six NPDES General Permits we discussed earlier this fall have been issued and became effective on November 1, 2018. 1 am including links to each of them in this email. 1. NCG030000 Metals Fabrication ........................................................ 2. NCG060000 Food and Kindred ........................................................ 3. NCG080000 Vehicle Maintenance 4. NCG000000 Paints Varnishes Lacquers, Enamels, Allied Products 5. NCGl00000 Used Motor Vehicles 6. NCG120000 Landfills Our staff are still working on the Response to Comments document for these, but that will be available can o..u_r w..e to as soon as it's finalized (we will post it under each specific GP). That document will address comments from you all below; however, I did want to touch on the NCG120000 Landfills permit briefly: NCG120000 only covers non -contaminated stormwater and does not authorize discharges considered to be contaminated stormwater, as defined in the Federal Regulations and MSGP. This has always been the case for this stormwater permit in our program; however, we added clarification on th_eJro t..pa.ge cf..t_he N_CG12 G_P that Contaminated Stormwater (as defined in Part IV of the permit) is excluded from coverage. For this reason, the ELGs have never been in this general permit and were not introduced at this renewal. Please let us know if you have any questions. Best regards, The NC DEMLR Stormwater Program Bethany Georgoulias Environmental Engineer Stormwater Program, Division of Energy, Mineral, and Land Resources N.C. Department of Environmental (duality 919 707 3641 office bethany.geor oulias _,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 corre,spomYence to amY from this �Y�Yrs,s,s is ,subiect to the Nodh Carolina Public Recants Law amY n7 .y be �Yisclose�Y to thinY padie,s. From: Wahlstrom-Ramler, Meghan <Wahlstrom-Ramler.Meghan@epa.gov> Sent: Monday, October 22, 2018 10:09 AM To: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov>; Lucas, Annette <annette.lucas@ncdenr.gov> Cc: Jones, Erica <Jones.Erica@epa.gov>; Sampath, Sam <Sampath.Sam@epa.gov>; Davis, Molly <Davis.Molly@epa.gov> Subject: [External] Summary of phone call regarding 6 general permits Thank you for taking the time on Tuesday to answer our permits regarding the six general permits: 1. NCG030000 Metals Fabrication 2. NCG060000 Food and Kindred 3. NCG080000 Vehicle Maintenance 4. NCG090000 Paints, Varnishes, Lacquers, Enamels, Allied Products 5. NCG100000 Used Motor Vehicles 6. NCG120000 Landfills (pII:: ase Inote Il.airndfillll I I Cs) Below is a summary of our call. I believe that most of the questions were resolved but I've highlighted any outstanding question/comments in Il llUe and any agreed upon changes will be in gra: ein. Please let me know if I you believe I have not summarized a topic correctly or if you disagree with a proposed change/action. General Notes: Part 1 Section B: Wetlands provision. Thank you for pointing out that the wetlands language is actually in all the permits Part 2 Section A.2.b: In some of the permits the "Secondary Containment Requirements" are in paragraph form and in others they are listed. EPA feels that these are important requirements and are easiest to read in list form. II I°ire our llniQrst,ancA I� � that °Qagrees Q�rl� Q� those II� paragraph QYIY"n to Hsts. Part 2: Most of the permits have the benchmark values in Table 1, unlike the previous versions of the permits that had them in a separate table. EPA likes the change that was made to put them all in one table as we think it makes the permit easier to read. There were one or two draft permits that still had them separated. III°ire our NC rrislYQ".Q?i"sto chainisQ;;'". It so aHI the CrQ;!i".IrIY'IrnII-ts have the hQ.''".InchIY'IrnrgIY ks cointagIIInQ!; d IIIn i.drqUQ!'". 1.. Part 2: Some of the tables have the vehicle maintenance benchmarks separated, while some have them combined. It it's EPA's recommendation to follow the format in for Table 1 in NCG090000 where there is a heading in the table for "Additional parameters for vehicle or equipment maintenance...". III °ire our ullna~ ers-tai cflll g that NC agra: es Ian Irn'nalke IJNs Part 3: All permits are missing the Upset provision. There may be upset language in other general permits but not in these. One possibility is that upset language was removed from the general permits because the water being permitted here is stormwater and the values in the permit are benchmarks and not limits; however, it is not clear that that is actually the reason upset is absent. We discussed the Upset Il lrovisioin with other Il people iln our office aind the gelnerell cou seinsus is flliat the upset II Irovisioll s sllhoulld be illnclluded Part 2 Section B: Thank you for explaining to us how the metals limits were developed. It is our understanding that you used the metals formula to calculate the limits and assumed a hardness of 25 mg/L and a TSS value of 10 mg/L. NCG030000 Metals Fabrication Section B: Thank you for explaining the change in the copper, lead, and zinc benchmarks. It is our understanding that the values changed due to the adoption of the new metals criteria, which were calculated as described in the General Notes section. It is also our understanding that the values are the acute threshold with no dilution assumed. Part 2, Table 1: Thank you for confirming that the Non -Polar Oil and Grease/TPH parameter is for vehicle or equipment maintenance areas. III °is our uunders-tai cfli g that NC wI°illll Iput that under the "Adcfl-tk)lm ll Irparairn'ne-ters for va^hk;le or n^a~ja,ol°ipirn'nein Irn'nal°lint inaince_,.". NCG060000 Food and Kindred Section B: Comparing the SIC codes provide for the NC GP and the EPA MSGP, there are some parameters that are in the EPA permit that are not in the NC permit. For reference: SIC 20 corresponds with Sectors U1, U2, and U3 in the EPA MSGP; SIC 21 corresponds with U3; SIC 284 corresponds with C3, SIC 283 with C5; I could not find 4221-4225 in the MSGP. Il1,6o °is a tabI le showhnE the ad'&doi nail IlDaraurneteirs Ilan the II:II"A V"\A" &�C '. II "A SUM'St that theseIIDair"�urr�eteirs II I: cvunsl°ideired d'U111' g ths IlDeinrnt Irei newa�: Subsector Parameter Benchmark Subsector C3 (SIC 2841-2844) Subsector U2 (SIC 2074-2079) Nitrate + Nitrite Nitrogen 0.68 mg/L Subsector C3 (SIC 2841-2844) Total Zinc Hardness Dependent Subsector U2 (SIC 2074-2079) COD 120 mg/L NCG080000 Vehicle Maintenance No sector specific comments/questions NCG090000 Paints, Varnishes, Lacquers, Enamels, Allied Products 09 — Part 2 Section , footnote 1. Language is different for this footnote when compared to the other draft general permits. Provisions about continuing Tiers 2 and 3 are missing. ��Ill�er footlrn tes r�ICrlCrear o Ire c llfferein as a:^.IIII t I°ire our uIrnn»rlleIrs-ta nc,IIII n�y tIliar"fit IIWC wII I I add tIliae r"qI ngur"qge III nto tIliae footI notQns wIliaQ',;".IrQ". I necQ".ssaIry. NCG100000 Used Motor Vehicles Section B: Comparing the SIC codes provide for the NC GP and the EPA MSGP, there are some parameters that are in the EPA permit that are not in the NC permit. For reference: SIC 5093 corresponds with SectorsN1 in the EPA MSGP. Ill,6owl is a tabI le shv dung the ad&doi nail IlDaraurneteirs Ilan the II II'A V\A I II'. II "A SnwsM'St that these IlDairairnn tears Il e coo nsl°ideired d'nwu111' g CIO ths IlDeirurnt Ire"unewa�: Subsector Parameter Benchmark Subsector N1 (SIC 5093) COD 120 mg/L Subsector N1 (SIC 5093) Total Recoverable Iron 1.0 mg/L Section B: Thank you for explaining the metals benchmark changes NCG120000 Landfills It is EPA's understanding that there are no SPPP requirements in this permit because many of the SPPP requirements are covered under other plans. Those parts of the SPPP not covered under other plans are included in this permit. Section B: Comparing the SIC codes provide for the NC GP and the EPA MSGP, there are some parameters that are in the EPA permit that are not in the NC permit. For reference: We are assuming that landfills corresponds with Sector L— Landfills, Land Application Sites, and Open dumps in the EPA MSGP. Il,6o °is a tabI Ie showhnE the ad'&doinall IlDairairneteirs lun the II ILIA II "I II" that are IlDas nd oin III ffllueinf III it nifafiours Guldelllunef As these are II II Cs, i°it i°is II I!"A opiluni°loin that they SIhOL lld IDe fiondUded lion the IIDeinrrnfit: Subsector Parameter Benchmark Sector L BOD 140 mg/L, daily max 37 mg/L, monthly avg Sector L TSS (benchmarks 88 mg/L, daily max are different) 27 mg/L, monthly avg Sector L Ammonia 10 mg/L, daily max 4.9 mg/L, monthly avg Sector L Alpha Terpineol 0.033 mg/L, daily max 0.016 mg/L, monthly avg Sector L Benzoic Acid 0.12 mg/L, daily max 0.071 mg/L, monthly avg Sector L p-Cresol 0.025 mg/L, daily max 0.014 mg/L, monthly avg Sector L Phenol 0.026 mg/L, daily max 0.015 mg/L, monthly avg Sector L Total Zinc 0.20 mg/L, daily max 0.015 mg/L, monthly avg Please reach out to either myself, Erica (copied on this email), or Sam (also copied on this email) if you have any additional questions. Thank you, Meghan Meghan Wahlstrom I Environmental Engineer I Water Protection Division I USEPA Region 4 Special Emphasis Program Manager for the Federal Women's Employment Program (FWP) Atlanta Federal Center 1 61 Forsyth Street SW I Atlanta, GA 30303-8960 (404) 562-9672 1 Wahlstrom-ramler.meghan@epa,_gov