NCS000509_Draft Permit Cover Letter_20201106

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
BRIAN WRENN
Director
Charles E. Smith
TriEst Ag Group, Inc.
Post Office Box 448
Greenville, NC 27835
SENT ELECTRONICALLY
Mr. Smith:
NORTH CAROLINA
Environmental Quality
November 6, 2020
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000509
TriEst Ag Group, Inc.
Pitt County
The Division of Energy, Mineral, and Land Resources' Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit
No. NCS000509 on April 7, 2014. Enclosed with this letter is a copy of the DRAFT
stormwater permit for your facility. Please review the draft carefully to ensure
thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from the facility's current
permit:
1. You are required to collect analytical and qualitative monitoring samples
during "measurable storm events" as defined in Part II, Section B. This
term is different from the "representative storm event" in earlier permits.
2. Requirements for the Stormwater Pollution Plan (SPPP) have been updated
in Part II, Section A.
3. Changes have been made to monitoring parameters, including a change to
two benchmarks. Stormwater benchmarks are not permit limits, but rather
guidelines for implementing the SPPP. A benchmark exceedance is not a
permit violation; however, the permittee must respond to exceedances as
directed in the tiered responses.
• Vehicle maintenance (Tables 5,6) monitoring parameters have been
revised as follows:
D E Q North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
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o Non -Polar Oil & Grease [EPA Method 1664 (SGT-HEM)]
replaces Oil & Grease/TPH. The benchmark for Non -polar Oil
& Grease using this method is 15 mg/L. This requirement
appears in all individual stormwater permits; however, it only
applies to facilities that perform onsite vehicle maintenance
activities. If the facility begins vehicle maintenance during the
permit cycle, the requirements shall apply.
o pH monitoring is no longer required for discharges only
associated with vehicle maintenance activities.
4. Tiered responses have been added to this permit. Exceedances of
benchmark values require the permittee to increase monitoring, increase
management actions, increase record keeping, and/or install stormwater
Best Management Practices (BMPs) in a tiered program in accordance with
Part II, Section B of this permit.
S. A new section on Special Conditions has been added in Part II, Section E to
comply with federal regulations requiring electronic submittal of discharge
monitoring reports.
6. Civil and administrative penalty amounts have been updated to reflect
current federal law in Part III, Section A, 2 (b) and (g).
Please review the draft permit and submit any comments to me no later than 30 days
following your receipt of the draft. Comments may be emailed to me at
[e-mail] or mailed to my attention at NC DEMLR, Stormwater Permitting
Program, 1612 Mail Service Center, Raleigh, NC 27699-1612. If you have any questions,
please email me or call me at [phone].
Sincerely,
Aana Gamble
DEMLR Stormwater Division
Attachment: Draft Permit NCS000S09
cc: Charles E. Smith, TriEst Ag Group, Inc., cesmithgtriestag.com
Samir Dumpor, DEMLR Washington Regional Office, Samindumpor@ncdenngov
Bill Moore, DEMLR Washington Regional Office, bill.mooreOncdenr.gov