NCG081015_RO Recommendation_20211028

Carson, Brittany
From: Hiatt, Levi
Sent: Thursday, October 28, 2021 8:55 AM
To: Carson, Brittany
Subject: NCG08 for H&E Equipment Services (MGX Equipment Services): 3760 N Liberty Street,
Winston-Salem, NC 27105
Follow Up Flag: Follow up
Flag Status: Flagged
Good morning Brittany,
Please see the emails below for some insight on the subject facility.
The SIC code for this facility is not listed for any of our permits, but they will need to be covered under NCG08.
They should submit their application soon.
Let me know if you have any questions.
Levi Hiatt, EIT
Assistant Regional Engineer
Land Quality Section, Winston-Salem Regional Office
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
[phone] (main)
[phone] (office)
[e-mail]
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105-7407
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Email correspondence to and from this a is su4ect to the
North Carolina Public Records Law and ay be disclosed to third parties.
From: Ben Conlon <[e-mail]>
Sent: Thursday, October 28, 2021 8:26 AM
To: Hiatt, Levi <[e-mail]>
Cc: Flanagan, Jonathan T <[e-mail]>
Subject: Re: [External] Sw Permitting questions - NCG08

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Hi Levi,
Thanks for the response. Can you provide a bit more detail around what you observed that required them to obtain
permit coverage under NCG08? Also, are there any special instructions to include your inspection/observations, given
that the primary SIC is not a covered code?
Thanks for any and all information.
Regards,
Ben
From: Hiatt, Levi <[e-mail]>
Sent: Thursday, October 28, 2021, 06:11
To: Ben Conlon
Cc: Flanagan, Jonathan T
Subject: RE: [External] Sw Permitting questions - NCG08
Hello John,
The site visit went well. They definitely need permit coverage under NCG08.
My apologies for just now getting back to you on this.
Thank you,
Levi Hiatt, EIT
Assistant Regional Engineer
Land Quality Section, Winston-Salem Regional Office
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
[phone] (main)
[phone] (office)
[e-mail]
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105-7407
Lr,- ��D E
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4�rNl�rt 11 OIMIr
Email surraspondence to and from this address is tr f to the
North Carolina Public RecordsLew and may be disclosed to third parties_

From: Ben Conlon <[e-mail]>
Sent: Wednesday, October 27, 2021 1:34 PM
To: Hiatt, Levi <[e-mail]>
Cc: Flanagan, Jonathan T <[e-mail]>
Subject: RE: [External] Sw Permitting questions - NCG08
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Hi Levi,
How did things go at the Winston Salem facility? Would you be able to provide a site visit summary and your
determination on whether or not a permit would be required?
Thanks!
Ben Conlon
Senior Consultant
M [phone]
[e-mail]
From: Ben Conlon
Sent: Friday, October 8, 2021 10:49 AM
To: Hiatt, Levi <[e-mail]>
Cc: Flanagan, Jonathan T <[e-mail]>
Subject: RE: [External] Sw Permitting questions - NCG08
Hi Levi, thanks for reaching out. We did discuss Wednesday 10/13/2021 and that should work just fine. Jonathan
Flanagan (cc'ed) will be there to meet you.
Jonathan, can you confirm that this day/time will still work for you?
Thanks!
Ben Conlon
Senior Consultant
M [phone]
bconlon@ram boll. corn
From: Hiatt, Levi <[e-mail]>
Sent: Friday, October 8, 2021 10:33 AM
To: Ben Conlon <[e-mail]>
Subject: RE: [External] Sw Permitting questions - NCG08
Ben,
I can't remember if I follow-up with you or not.
Tyler and I can visit this facility next Wednesday (10/13/2021) at 8:00am.
Thank you,
Levi Hiatt, EIT
Assistant Regional Engineer
Land Quality Section, Winston-Salem Regional Office

Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
[phone] (main)
[phone] (office)
[e-mail]
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105-7407
4spMmMIM of km�e�17� OY�q
Ented conasporidence Co sort from this address is sathectto the
North Corsboo Public Records Law on may be disclosedto third pathos,
From: Ben Conlon <[e-mail]>
Sent: Monday, September 27, 2021 2:56 PM
To: Hiatt, Levi <[e-mail]>
Cc: Pearson, Tyler B <[e-mail]>
Subject: RE: [External] Sw Permitting questions - NCG08
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
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Hi Levi, were you and Tyler able to connect about a potential date(s) to visit?
Thanks!
Ben Conlon
Senior Consultant
M [phone]
[e-mail]
From: Hiatt, Levi <[e-mail]>
Sent: Friday, September 24, 2021 6:59 AM
To: Ben Conlon <[e-mail]>; Eplin, Tamera <[e-mail]>; Pearson, Tyler B
<[e-mail]>
Cc: Denise McCoy <Denise.McCoy@ram boll.com>; Carson, Brittany <[e-mail]>; Katie Cooper
<[e-mail]>
Subject: RE: [External] Sw Permitting questions - NCG08
Good morning Ben,
Thank you for reaching out to us concerning this matter.
Tyler Pearson and I should be able to come out there within the next few weeks. I will need to coordinate with him and
get back to you.

Thank you,
Levi Hiatt, EIT
Assistant Regional Engineer
Land Quality Section, Winston-Salem Regional Office
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
[phone] (main)
[phone] (office)
[e-mail]
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105-7407
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Email consasondence to and from this address is subject to the
North Carolina Publice Law and e disclosed to third parties.
From: Ben Conlon <[e-mail]>
Sent: Thursday, September 23, 2021 3:13 PM
To: Eplin, Tamera <[e-mail]>; Hiatt, Levi <[e-mail]>
Cc: Denise McCoy <Denise.McCoy@ram boll.com>; Carson, Brittany <[e-mail]>; Katie Cooper
<[e-mail]>
Subject: RE: [External] Sw Permitting questions - NCG08
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Report Spam.
Hello Levi and Tamera,
I hope you both are doing well. I'm requesting a site visit be performed at my client's facility in Winston-Salem, NC.
We are looking for a determination on whether stormwater permit coverage is needed at the facility. Currently, the
SIC code to describe site operations is not a covered SIC code that requires stormwater permitting. However, there
are outdoor industrial activities at the site. Our client wants to be responsible and make sure although they aren't a
operating under a covered SIC code, that they are operating with all appropriate permits.
They would like a regional inspector to review their outdoor activities and determine if these activities pose a
substantial threat stormwater and if a permit would be needed.
Here is the facility location information:
H&E Equipment Services (soon to be MGX Equipment Services)
Address: 3760 N Liberty St, Winston-Salem, NC 27105
Any idea what sort of timeframe we would be looking at for a regional inspector to perform a site visit/inspection?

Thank you,
Ben Conlon
Senior Consultant
M [phone]
[e-mail]
From: Georgoulias, Bethany<[e-mail]>
Sent: Thursday, September 23, 2021 12:17 PM
To: Ben Conlon <[e-mail]>; Eplin, Tamera <[e-mail]>; Hiatt, Levi
<[e-mail]>
Cc: Denise McCoy <Denise.McCoy@ram boll.com>; Carson, Brittany <[e-mail]>; Katie Cooper
<[e-mail]>; Morman, Alaina <[e-mail]>; Lucas, Annette
<[e-mail]>; Brian Whiting <[e-mail]>
Subject: RE: [External] Sw Permitting questions - NCG08
Ben,
Please contact the Winston-Salem regional office to arrange an inspection and discuss timeframe. I've copied our
primary stormwater contact there, Levi Hiatt, and the Regional supervisor Tamer Eplin.
Bethany Georgoulias (she/her)
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
[e-mail]
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 correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging
time.
From: Ben Conlon [mailto:BCONLON(@rambolLcom
Sent: Wednesday, September 22, 2021 5:20 PM
To: Georgoulias, Bethany<[e-mail]>
Cc: Denise McCoy <Denise.McCoy@ram boll.com>; Carson, Brittany <[e-mail]>; Katie Cooper
<[e-mail]>; Morman, Alaina <[e-mail]>; Lucas, Annette

<[e-mail]>; Brian Whiting <[e-mail]>
Subject: RE: [External] Sw Permitting questions - NCG08
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Hi, Bethany,
Thank you so much for the response, and apologies for jumping into the conversation. I'm working alongside Denise
on this and while she is out until early next week I can be the point person on this.
The facility in question is located in Forsyth County/Winston-Salem Region. Our client is interested in setting up a site
visit by a regional inspector to help determine if stormwater permitting is required/applicable for this facility.
Here is the facility location information:
H&E Equipment Services (soon to be MGX Equipment Services)
Address: 3760 N Liberty St, Winston-Salem, NC 27105
Any idea what sort of timeframe we would be looking at for a regional inspector to perform a site visit/inspection?
Thank you!
Ben Conlon
Senior Consultant
M [phone]
[e-mail]
From: Georgoulias, Bethany<[e-mail]>
Sent: Monday, September 20, 2021 9:13 AM
To: Denise McCoy <Denise.McCoy@ram boll.com>
Cc: Carson, Brittany <[e-mail]>; Katie Cooper <[e-mail]>; Morman, Alaina
<[e-mail]>; Lucas, Annette <[e-mail]>
Subject: RE: [External] Sw Permitting questions - NCG08
Hi, Denise,
It was Alaina that you spoke with, and we discussed the topic on Friday. To clarify, if the activities at the site do not
carry an SIC code or activity that is "categorically captured" by the NPDES stormwater regulations (listed on that sheet I
sent a link to), the vehicle maintenance associated with them is not necessarily subject to a permit either. Any vehicle
maintenance activities by itself is not a categorically captured activity, but vehicle maintenance that falls in the captured
categories (like Category viii Transportation) — or those that are co -located with other captured categories — are subject
to a stormwater NPDES permit.
If the site's primary SIC code (typically) that will drive this. There are others that are described in 40 CFR Subchapter N
(e.g., rubber manufacturing or metal finishing) rather than identified by SIC, but most of the categories go back to SIC
code associated with the facility's activity. And, in all cases, if vehicle maintenance activities post a potential impact to
water quality (no matter what the SIC), the site can be designated by the state (for example, we have some large truck
stops in the state that created significant potential to impact water quality and were brought under the NCG08 general
permit several years ago.)
From your description, SIC 7353 is not categorically captured and would not require a permit. This is the most I can
advise over the phone without having seen the site. In this case, I think the best thing to do is to have a regional
inspector from DEQ make a site visit. Then the types of activities can be evaluated (to verify SIC), along with an

evaluation the potential stormwater discharges from vehicle maintenance areas and receiving stream conditions. What
county/DEQ region is this facility located in?
Bethany Georgoulias (she/her)
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
From: Denise McCoy[mailto:[e-mail]
Sent: Friday, September 17, 2021 9:45 AM
To: Georgoulias, Bethany<[e-mail]>
Cc: Carson, Brittany <[e-mail]>; Katie Cooper <[e-mail]>
Subject: RE: [External] Sw Permitting questions
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Report Spam.
Thank you for getting back with me. I spoke with someone (apologies, I misplaced my notes so I don't have their
name - I think it may have been Brianna Young or Aliana Morman) on August 23rd via telephone, and she stated that
if a facility has "significant" vehicle maintenance activities they will need to obtain a permit (NCG080000) regardless
of their primary SIC code. It sounds as if you are saying the same thing (unless designated and brought under that
particular general permit). When I spoke with NCDEQ previously I was not able to provide any details regarding the
site so I was only able to give a general summary of their activities.
My client is very interested in complying with the regulations and has released us to disclose information that would
be needed for compliance. Would you be available so we could discuss whether or not the maintenance activities at
this facility might still fall under the requirement for permitting? This seems to be a bit of a gray area.
Thanks!
Denise
From: Georgoulias, Bethany<[e-mail]>
Sent: Friday, September 17, 2021 8:13 AM
To: Denise McCoy <Denise.McCoy@ram boll.com>
Cc: Carson, Brittany <[e-mail]>
Subject: RE: [External] Sw Permitting questions
Denise,
If the activities at the site do not carry an SIC code that is subject to the regulations, the vehicle maintenance associated
with them is not necessarily subject to a permit either (but again, could be designated if there are potential water
quality issues). Although NCG08 typically only applies to the vehicle maintenance areas of the captured categories, it
does not apply to vehicle maintenance areas associated with different SICs that are not captured (unless designated and
brought under that particular general permit.)
Bethany
From: Denise McCoy[mailto:[e-mail]]
Sent: Thursday, September 16, 2021 12:17 PM
To: Georgoulias, Bethany<[e-mail]>
Cc: Carson, Brittany <[e-mail]>
Subject: RE: [External] Sw Permitting questions

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Thanks Georgina - the listed SIC is not in one of the categories so we would be looking exclusively at the vehicle
maintenance areas.
Denise
From: Georgoulias, Bethany<[e-mail]>
Sent: Thursday, September 16, 2021 12:02 PM
To: Denise McCoy <Denise.McCoy@ram boll.com>
Cc: Carson, Brittany <[e-mail]>
Subject: RE: [External] Sw Permitting questions
Denise,
I will be out for the rest of the day and will not be able to investigate further until tomorrow or next week, but in the
meantime I'll give you a resource that can help. This summary of industrial activities subject to NPDES stormwater
permits is on our website. The determining factor for a permit is typically the SIC code or 40 CFR category (not just that
the activity matches a description on one of our permits) AND a potential point source discharge of
stormwater. However, the state does have authority to designate sites as subject to an NPDES permit if there is the
potential to cause or contribute to water quality impacts.
I am not sure that the SIC you list is in one of the categories. It is not in the standard list of NCG08 transit and
transportation categories. If there is a secondary SIC for other activities, there, it should be considered as well, though.
Brittany Carson is our new General Permits coordinator, and she may be able to assist in the meantime as well.
Best,
Bethany Georgoulias (she/her)
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
[e-mail]
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
E
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your

requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging
time.
From: Denise McCoy[mailto:[e-mail]]
Sent: Thursday, September 16, 2021 11:32 AM
To: Georgoulias, Bethany<[e-mail]>
Subject: [External] Sw Permitting questions
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Hello Bethany,
I have a client that is purchasing a facility in NC that currently does not have a sw permit. Operations at the facility
include service, rental, and sales of light and heavy construction equipment and crane parts. There is a covered wash
area (OWS discharges to sanitary) and covered maintenance area, but there may be maintenance conducted outside
on the larger cranes that can't fit into the repair shop and it also appears that there may be fueling and maintenance
chemical storage outside. Based on the language on the NOI (The following activities are also included: other industrial
actives where the vehicle maintenance area(s) are the only area requiring permitting) it appears to me that they would
be required to obtain coverage under NCG080000. My client has posed some detailed questions that I am not sure of
the answers and was trying to reach you via phone to discuss. But perhaps we can address via email:
1. Can you confirm that based on these activities that they would be required to obtain a permit? Their primary
SIC code is 7353 Heavy Construction Rental and Leasing so we want to be sure that NCDEQ would consider
this facility as subject to the regulation.
2. They are wanting clarification if repair on cranes and other construction equipment would be considered
vehicle repair. Permit NCG080000 is specific to vehicle repair so they want to make sure these activities fall
under that definition.
3. Is the SWPPP required to be completed prior to submittal of the NOI, or can they go ahead and submit the NOI
and complete the SWPPP subsequently? If that is the case, how long do they have to complete and implement
the SWPPP?
Let me know if you would prefer to discuss via phone or if I should direct my question somewhere else. Thanks for
your help!
Denise McCoy
PROJECT MANAGER-1
081-E&H SE RESOURCES
M 912-604-7515
[e-mail]
Ramboll
PO Box 60728
Savannah, GA 31420-0728
USA
https://ramboll.com
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