NCG080936_Emails RE DMR Question_20200616

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Tuesday, June 16, 2020 7:41 AM
To: Stephanie (Annie) Rock -Rogers
Subject: Re: [External] NCG080936 - DMR question
Stephanie,
Thanks for reaching out about these questions. To answer your first one, if the facility did monitoring anyway,
it actually does need to report results. The standard conditions in the back of the permit have a requirement
to report any monitoring (Part III, Section Q:
If the permittee inonitors any pollutant niore frequently than rewired by this general pernut using
test procedures approved under 40 CFR Pait 136 and at a sanipling location specified in this general
perm t or Dther apprDpriate instruinent governing the discharge, the results of slick monitor ng sliall
be included in the data subinitted on the DMR. [40 CFR § 12 ZA1(1)]
The perinittee shall record the required qualitative monitoring observations oa the S DQ Qualitative
Monitoring Report form provided by the Divisions and shall retain the conipleted forms on site.
Qualitative nion[to ring results should not be submitted to the Division, except upon D EM LR's specific
requirement to do so. Qualitative Monitoring Report forms are available at the website above.
Part ID Page 8 of 10
However (and to answer your second question), no -- technically that monitoring does not count toward a Tier
2 or Tier 3 status, as I interpret the tier language. The text qualifies results as those "required for the permit
monitoring period," and the intent there was to exclude any "extra" monitoring the facility might perform
above and beyond what the permit requires.
I've never had the question in the context of the 55 gal of motor oil threshold context before, though. I would
make sure records are maintained to support the oil usage threshold was not surpassed (and note it on the
DMR when reporting -- that the requirement wasn't triggered, but the site monitored anyway). Also, if any
benchmark exceedances from that monitoring suggest there's a possible problem, the facility should still try to
identify and rectify it. No matter the monitoring status, the permit does not allow discharges to cause or
contribute to water quality standard violations in the receiving stream.
I hope this helps. Let me know if you have any other questions.
Regards,
Bethany Georgoulias, Environmental Engineer
NCDEQ / DEMLR / Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612

512 N. Salisbury Street, Raleigh, NC 27604
919 / 707-3641 (phone); 919 / 807-6494 (fax)
Website: http://deg.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be disclosed to third parties.
From: Stephanie (Annie) Rock -Rogers <[e-mail]>
Sent: Monday, June 15, 2020 12:31 PM
To: Georgoulias, Bethany <[e-mail]>
Subject: [External] NCG080936 - DMR question
External email. Do not click links or open attachments unless ou veri
[e-mail]
Bethany,
I'm working on the DMR for one of our facilities and have a question about the form. If the facility did not use
55 gallons or more of new oil for the monitoring period, do we have to report the monitoring results? The form
says to only complete Part A (monitoring results) if we checked the " yes" box for >55 gallons of oil usage.
I also need to know if we performed the monitoring but don't have to report the analysis results, do those results
get counted toward 92 of the Tier Two conditions or towards moving into a Tier Three range....
2. Immediately institute monthly monitoring and reporting for all parameters. The permittee shall conduct
monthly monitoring at every outfall where a sampling result exceeded the benchmark value For two
consecutive samples. Monthly (analytical and qualitative) monitoring shall continue until three
consecutive sample results are below the benchmark values or +,+within benchmark range.
Tier Three
If- The valid sampling results required for the permit mar ing perk ds exceed the benchmark value, or are outsi
the benchmark range, for any specific parameter at any specific outfall on four occasions, the permittee shall not
the DEMLR Regional Engineer in writing within 30days of receipt of the Fourth analytical results;
Respectfully,
Stephanie (Annie) Rock -Rogers
Property and Environmental Coordinator
sro ers e trimac.com
Office:470-737-2740 Fax: [phone]
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