NCG080881_Emails RE Drainage Areas under NCG08_20220729

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Friday, July 29, 2022 12:12 PM
To: Lindsay Fletcher
Cc: Carson, Brittany; Smith, Danny; Reed, Isaiah L
Subject: RE: [External] Question about Outfalls at NCCU
Attachments: Figure 2-NCCU ICP.pdf
Lindsay,
Apologies for the delay on responding! I am going to offer some thoughts and also copy some other coworkers on
this. I have been ill this week and just catching up, but I'm also away all next week on vacation.
Does NCCU hold an MS4 Stormwater permit by any chance, or just the NCG08?
#1- NCG08 is one of more unusual permits. It has a section for oil/water separators that enforce monitoring limits, but
those only apply to special situations. Most permittees are only subject to the stormwater discharge section of that
permit. Can you tell me what SIC the activity here is under, and the reason for the NCG08 permit coverage? Is it some
sort of vehicle maintenance operation at the university? Or was the O/W separator designated specifically because of
an issue? [We need to understand which part of the permit applies, also to make sure the monitoring in our system is
set up correctly]
#2 - For NPDES stormwater permits in general, drainage areas without any kind of captured industrial activities in the
program (like employee parking lots, etc.) are outside the scope of the permit and do not need to be
sampled. HOWEVER, outfalls that receive runoff from activities that are captured in another NPDES category (different
than NCG08 but maybe under another kind of permit) that happen to be at the some location are considered "co -
located" and would just be part of this one permit coverage. I am not sure that's the case here, but I wanted to make
the distinction. It sounds like it's probably the first scenario and not considered industrial activity at all.
#3 - For NCG08 (standard stormwater, not a designated oil/water separator), only the areas associated with vehicle
maintenance are captured I believe. That probably rules out the other areas from applicability unless there's any sort of
fueling or vehicle maintenance happening there.
It really hinges on whether what's happening in those other drainage areas is considered to be "stormwater associated
with industrial activity'. The best place to start is helping us understand why the university needed an NCG08 permit for
this area in the first place (what SIC code triggered the requirement).
I hope this helps you all get your questions answered. Brittany Carson and others should be available to help further
next week.
Best regards,
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
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From: Lindsay Fletcher <[e-mail]>
Sent: Wednesday, July 20, 2022 1:43 PM
To: Georgoulias, Bethany <[e-mail]>
Subject: [External] Question about Outfalls at NCCU
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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Bethany,
I am working with NCCU to update their SWPPP. They are currently covered under general permit NCG08000 since they
have an oil water separator onsite. They are currently permitted to discharge at one outfall located on the southeast
corner of their property. This outfall drains into Third Fork Creek. (See attached draft map). The site historically assumed
that all of their stormwater flow would drain and be discharge via this one outfall. Due to a recent internal inspection,
we realized that drainage on the western portion of campus (to the left of the red line drawn north to south) will drain
to the west into a variety of unnamed creeks. We have identified 4 additional discharge points on this portion of
campus. The western portion of campus doesn't have any industrial activity except for emergency generators located
near some of the academic buildings and dorms. Since the activities in these areas do not fall into the SIC codes covered
by NCG08000 do these outfalls need to be added to the permit? If so, would they require routine sampling? If not, could
I just include a discussion in the SWPPP about the drainage patterns in this half of the campus?
Please advise on the best path forward that will ensure that the site follows the permit.
Thanks,
Lindsay L. Fletcher, PE*
Project Professional
3200 Gateway Centre Blvd, Suite 100
Morrisville, NC 27560
*Licensed in NC, TN, TX, VA and MD
d 919.653.7023
o 919.755.5011
m 1713.299.0304

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