NCS000255_Applicationl acknowledgement_20220608

Young, Brianna A
From: Young, Brianna A
Sent: Wednesday, June 8, 2022 10:06 AM
To: Jeffrey E. Willoughby (WAI)
Cc: Amandeep Brar; Georgoulias, Bethany; Mark Ferrell (WAI); Brett Bushee
Subject: RE: [External] RE: NCS00255 Permit Renewal Application
Jeff,
We have received the EPA application forms in our office. As I previously stated, due to the current backlog and staff
shortages, review of this permit renewal is not scheduled until 2024, however this schedule is subject to change. In the
interim, please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater
permit. Please let me know if you have any questions.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail] (e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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.
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: Jeffrey E. Willoughby (WAI) <[e-mail]>
Sent: Wednesday, June 1, 2022 2:08 PM
To: Young, Brianna A <[e-mail]>
Cc: Amandeep Brar <Amandeep.Bra [e-mail]>; Georgoulias, Bethany<[e-mail]>; Mark
Ferrell (WAI) <[e-mail]>; Brett Bushee <[e-mail]>
Subject: RE: [External] RE: NCS00255 Permit Renewal Application
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Brianna —
Good afternoon. I hope you are well.

As requested in your 05/13/2022 email below, EPA Form 1 and EPA Form 2F are submitted to your office. The original
forms will be submitted to your attention today via USPS first-class delivery.
If additional information is required, or questions arise upon review, please send me an email or give me a call.
Jeff
Jeffrey E. Willoughby
President
Willoughby & Associates, Inc. EHS
Office: 434.534.9834
Mobile: [phone]
Fax: [phone]
From: Jeffrey E. Willoughby (WAI)
Sent: Wednesday, May 18, 2022 9:25 AM
To: 'Young, Brianna A' <[e-mail]>
Cc: Amandeep Brar <[e-mail]>; Georgoulias, Bethany <[e-mail]>; Mark
Ferrell (WAI) <[e-mail]>
Subject: RE: [External] RE: NCS00255 Permit Renewal Application
Brianna —
Thank you very much for the getting back with me!
Direction received and will be incorporated into the Form 2F accordingly.
Jeff
Jeffrey E. Willoughby
President
Willoughby & Associates, Inc. EHS
Office: 434.534.9834
Mobile: [phone]
Fax: [phone]
From: Young, Brianna A <[e-mail]>
Sent: Wednesday, May 18, 2022 8:50 AM
To: Jeffrey E. Willoughby (WAI) <[e-mail]>
Cc: Amandeep Brar <[e-mail]>; Georgoulias, Bethany <[e-mail]>; Mark
Ferrell (WAI) <[e-mail]>
Subject: RE: [External] RE: NCS00255 Permit Renewal Application
Good morning Jeff,
I apologize for the delay in responding. Please see below for answers to your questions.
1. Table A Monitoring Parameters —A summary of facility monitoring results was provided with the original
04/01/2022 permit application package submission. October 2017 permit monitoring parameters include all
Table A parameters, except BOD5, total phosphorus, TKN and total nitrogen (as N). Is the facility required to

include monitoring results for Table A listed BODS, total phosphorus, TKN and total nitrogen (as N)? If yes, is a
waiver request acceptable to NCDEQ?
You are only required to provide monitoring data for parameters that were included in your permit. If BOD, TP, TKN, and
TN were not in your permit, then you do not need to provide data on the renewal application for these.
2. Grab and Flow -Weighted Composite Samples — Tables A, B & C require grab and flow -weighted composite
sampling data. All historical facility monitoring has been conducted via grab sampling. Is the facility required to
submit flow -weighted composite sampling results? If yes, is a waiver request acceptable to NCDEQ?
Grab sampling is appropriate. You do not need to submit flow -weighted composite samples unless your permit
specifically required that.
3. Representative Outfall Status — NCDEQ approved representative outfall status to facility Outfall 001 on
09/24/2019 (approval letter attached). Due to substantially identical outfalls, any required Form 2F sampling will
be conducted at Outfall 001 and subsequent analysis results will be submitted for Outfalls 001, 002 and 003.
Thank you for this notification. I will make sure to note this during my review.
Please let me know if you have any other questions.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail] (e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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.
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: Jeffrey E. Willoughby (WAI) <[e-mail]>
Sent: Monday, May 16, 2022 1:07 PM
To: Young, Brianna A <[e-mail]>
Cc: Amandeep Brar <[e-mail]>; Georgoulias, Bethany<[e-mail]>; Mark
Ferrell (WAI) <[e-mail]>
Subject: RE: [External] RE: NCS00255 Permit Renewal Application
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.

Brianna —
Good day.
EPA Forms 1 and 2F are under development. Three questions related to Form 2F completion are presented below:
Table A Monitoring Parameters — A summary of facility monitoring results was provided with the original
04/01/2022 permit application package submission. October 2017 permit monitoring parameters include all
Table A parameters, except BOD5, total phosphorus, TKN and total nitrogen (as N). Is the facility required to
include monitoring results for Table A listed BOD5, total phosphorus, TKN and total nitrogen (as N)? If yes, is a
waiver request acceptable to NCDEQ?
Grab and Flow -Weighted Composite Samples — Tables A, B & C require grab and flow -weighted composite
sampling data. All historical facility monitoring has been conducted via grab sampling. Is the facility required to
submit flow -weighted composite sampling results? If yes, is a waiver request acceptable to NCDEQ?
Representative Outfall Status — NCDEQ approved representative outfall status to facility Outfall 001 on
09/24/2019 (approval letter attached). Due to substantially identical outfalls, any required Form 2F sampling will
be conducted at Outfall 001 and subsequent analysis results will be submitted for Outfalls 001, 002 and 003.
Thank you.
Jeffrey E. Willoughby
President
Willoughby & Associates, Inc. EHS
Office: 434.534.9834
Mobile: [phone]
Fax: [phone]
From: Young, Brianna A <[e-mail]>
Sent: Friday, May 13, 2022 11:31 AM
To: Jeffrey E. Willoughby (WAI) <[e-mail]>
Cc: Tyler Carrico (WAI) <[e-mail]>; Mark Ferrell (WAI) <[e-mail]>; Emory Willoughby
(WAI) <[e-mail]>; Amandeep Brar <[e-mail]>; Brett Bushee
<[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: RE: [External] RE: NCS00255 Permit Renewal Application
Good morning Jeff,
Thank you for providing this information after our call. Did you find these websites previously using an internet search?
The only thing I can think of as to why you saw an old application form and old 180-day language is that somehow an
inactive site (that is now archived/deleted) popped up in the search results. The active website has informed permittees
to use EPA Forms 1 and 2F since September 2021. 1 apologize for the confusion; however, we do require permittees to
now submit EPA Forms 1 and 2F.
Please let me know if I can be of further assistance.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)

[e-mail] (e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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.
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: Jeffrey E. Willoughby (WAI) <[e-mail]>
Sent: Friday, May 13, 2022 11:06 AM
To: Young, Brianna A <[e-mail]>
Cc: Tyler Carrico (WAI) <[e-mail]>; Mark Ferrell (WAI) <[e-mail]>; Emory Willoughby
(WAI) <[e-mail]>; Amandeep Brar <[e-mail]>; Brett Bushee
<Brett. [e-mail]>
Subject: [External] RE: NCS00255 Permit Renewal Application
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Brianna —
NCDEQ websites accessed 01/19/2022 to obtain the attached renewal application package are below:
Stormwater Program I NC DEQ
NPDES Industrial Program I NC DEQ
Note: The file name is unchanged from that downloaded from the NCDEQ website. The only change is my file name
extension ("-Downloaded NCDEQ Website-011922).
Finally, specific guidance copied from the website on 01/19/2022 indicated:
(For Individual permits, complete the NCS Renewal Forms Package, no later than 180 days prior to expiration of your
current permit)
Thank you.
Jeffrey E. Willoughby
President
Willoughby & Associates, Inc. EHS
Office: 434.534.9834
Mobile: [phone]
Fax: [phone]
From: Amandeep Brar <Amandeep.Bra [e-mail]>
Sent: Friday, May 13, 2022 10:33 AM
To: Jeffrey E. Willoughby (WAI) <[e-mail]>; Brett Bushee <[e-mail]>
Cc: Tyler Carrico (WAI) <[e-mail]>; Mark Ferrell (WAI) <[e-mail]>; Emory Willoughby

(WAI) <[e-mail]>
Subject: FW: NCS00255 Permit Renewal Application
Importance: High
Please see below and provide us information when can this be resolved?
From: Young, Brianna A <[e-mail]>
Sent: Friday, May 13, 2022 9:56 AM
To: Steve McKenzie <[e-mail]>; Amandeep Brar <Amandeep.Bra [e-mail]>
Subject: NCS00255 Permit Renewal Application
Caution: This is an external email and it could have a suspicious subject or malicious content. Please take care when
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Good afternoon,
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000255.
Please note that the incorrect permit application form was submitted. In order to log the application as
received complete, please fill out and mail hard copies of EPA Form 1 and EPA Form 2F to our office.
In the interim, please continue to comply with all conditions and monitoring requirements in your current
NPDES stormwater permit. As long as you have submitted a complete renewal request package and maintain
compliance with those permit conditions, stormwater discharges from this facility are authorized by that permit
until the Division issues a renewal permit or notifies you of an alternative action. Please note that due to the
current backlog and staff shortages, review of this permit renewal is not scheduled until 2024, however this
schedule is subject to change. Please let me know if you have any questions in the interim.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail] (e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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.
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.

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