NCG080455_Emails RE NCG08 Coverage Applicability_20181012

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Friday, October 12, 2018 9:47 AM
To: 'Robert Wagner'
Cc: Dwayne Yates; White, Sue; Lucas, Annette; John Hennessy
[e-mail])
Subject: RE: [External] RE: PJF Southeast LLC - NCG080455
Robert,
These non-stormwater discharges are not authorized under General Permit NCG080000. That NPDES general permit
only covers stormwater discharges — not any other sources, even if it is potable water. These discharges should be
routed to the sanitary sewer, or the facility needs to obtain an alternative wastewater permit. Please see the excerpt
from the front section of our general permit below. Please contact the DWR Wastewater Program for further direction
if the site will pursue a wastewater discharge permit. I've copied John Hennessy on this email, who can provide
further guidance.
I realize the situation at hand has been thoroughly confusing. However, the fundamental issue here is that the
discharges from this O/W separator are not entirely from stormwater, and therefore they must be permitted and/or
disposed of differently. The NPDES stormwater permit COC this site currently holds does not apply to the discharges you
describe.
Permit No. NCG080000
SECTION B. PERMITTED ACTIVITIES
Until coverage under tliis permit expires or is modified or nevokcd. the permittee is authorized to
discharge stoninvater to the ski rface waters of North Carolina or separate storm sewer system
Which has been adequately treated and managed in accordance with the terins and conditions of
this General Permit_
Any other point source discharge to surface waters of the state is prohibited unless itis an
ailowable non-stormwater discharge or is covered by another permit, authorization or approval.
The stormwater discharges allowed by this General Perinit shall not cause or contribute to
violations of Water Quality Standards,
This permit does not relieve the permittee's ivsponsibility for compliance with any other applicable
federal, state. or local law, rule, standard, ordinance, orderr or decree.
Please let me know if you have any further questions.
Best regards,
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
bethany.geor oulias �,ncdenr.gov

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.
From: Robert Wagner <[e-mail]>
Sent: Tuesday, October 09, 2018 11:05 AM
To: Georgoulias, Bethany <[e-mail]>
Cc: Dwayne Yates <[e-mail]>; White, Sue <[e-mail]>; Lucas, Annette
<[e-mail]>; Grzyb, Julie <[e-mail]>
Subject: RE: [External] RE: PJF Southeast LLC
IN"_� , . ternal email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
Normal site activities that can cause a discharge are frost proof spigot use at each island which would be potable water,
pressure washing of the diesel island concrete to reduce slip, trip and fall hazards using the potable water from spigots,
and typical small drips from diesel fuel nozzles.
As always during rain events there would be some stormwater influence from surrounding pavement areas at islands
and if the UST fuel drop basin has a stormwater drop inlet connected to the OWS, then it would be influenced by rain
events.
Hope this helps.
Let me know if you need anything else.
Thanks
Robert Wagner
Program Manager
7724 Garland Cir
Roanoke, VA 24019
0)540-563-4920 x4451 M)540-798-1494
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From: Georgoulias, Bethany <[e-mail]>
Sent: Tuesday, October 9, 2018 10:15 AM
To: Robert Wagner <[e-mail]>
Cc: Dwayne Yates <[e-mail]>; White, Sue <[e-mail]>; Lucas, Annette
<[e-mail]>; Grzyb, Julie <[e-mail]>
Subject: Re: [External] RE: PJF Southeast LLC

Robert,
The question here is clarification about the types of discharges flowing to the OWS here. Your previous email stated
"While there is some minimal influence from stormwater to the OWS at these facilities, the majority of the discharge
from the OWS is from normal site activities at the diesel fuel islands. Thus the OWS will discharge during non -rain
events. "
This does not sound like stormwater-driven discharge and may not be covered under NCG08. What types of discharges
are "normal site activities"?
Thanks,
Bethany
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: Robert Wagner <[e-mail]>
Sent: Tuesday, October 9, 2018 10:05:11 AM
To: Georgoulias, Bethany
Cc: Dwayne Yates; White, Sue; Lucas, Annette; Grzyb, Julie
Subject: RE: [External] RE: PJF Southeast LLC
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Bethany
Sorry about the late reply as I incorrectly thought I had replied a ways back.
During the Jan -June 2018 period we sampled on behalf of Pilot and submitted the DMRs appropriately under the
stormwater permit and believe we should continue as such during the July -Dec 2018 period and under any permit
renewals.
Please let me know if you have any additional questions.
Thanks,
Robert

Robert Wagner
Program Manager
7724 Garland Cir
Roanoke, VA 24019
0)540-563-4920 x4451 M)540-798-1494
FlAdd me to your contact list!
ENRTop 30 All -Environmental Firm
We've moved! Our new address is 7724 Garland Cir, Roanoke, VA 24019. Please update your contact list.
Thanks.
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From: Georgoulias, Bethany <[e-mail]>
Sent: Thursday, September 27, 2018 9:52 AM
To: Robert Wagner <[e-mail]>
Cc: Dwayne Yates <[e-mail]>; White, Sue <[e-mail]>; Lucas, Annette
<[e-mail]>; Grzyb, Julie <[e-mail]>
Subject: RE: [External] RE: PJF Southeast LLC
Robert,
We never heard back on any clarification about the types of discharges flowing to the OWS here. This general permit is
queued up to renew later this year, and we need to understand if this facility should remain under a stormwater permit,
or if these discharges belong under a wastewater permit.
Thanks,
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
bethany.geor ouliaskncdenr.gov
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.
From: Georgoulias, Bethany
Sent: Thursday, March 15, 2018 1:40 PM
To: 'Robert Wagner' <[e-mail]>
Cc: Dwayne Yates <[e-mail]>; White, Sue <[e-mail]>; Lucas, Annette

<[e-mail]>; Grzyb, Julie <[e-mail]>
Subject: RE: [External] RE: PJF Southeast LLC
Robert,
The first important question is what non-stormwater discharges are flowing to the OWS from activities at the diesel fuel
islands? If the water flowing to the OWS is not from stormwater runoff that contacts these areas but something else,
then there is a wastewater discharge here. Wastewater discharges through OWS's are not covered by NCG08 — only
stormwater discharges treated by OWS's can be.
If the OWS simply doesn't discharge in response to every event because of the size and volume (i.e., it takes several
rainfalls to fill it up, and flow through the OWS chambers takes time), then we understand there is a delayed discharge
of the stormwater that was routed through the system. This happens with detention ponds as well, and we just advise
permittees to sample the discharge when it occurs. Recording the amount of the preceding rain event is fine.
Before I answer the other questions about the pipe and qualitative monitoring, we need to sort out what kind of
discharge is happening here. If this is a wastewater discharge, then it needs an NPDES wastewater permit from DWR, or
needs to go somewhere else, like the sanitary sewer or pumped and hauled. Our program only permits stormwater
discharges through OWS's under the NCG08.
Thanks,
Bethany
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethany.geor oulias �,ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
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.
From: Robert Wagner [mailto:[e-mail]]
Sent: Tuesday, March 13, 2018 1:54 PM
To: Georgoulias, Bethany<[e-mail]>
Cc: Dwayne Yates <[e-mail]>; White, Sue <[e-mail]>; Lucas, Annette
<[e-mail]>; White, Glen <[e-mail]>; Grzyb, Julie <[e-mail]>
Subject: RE: [External] RE: PJF Southeast LLC
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Bethany I am sorry again for my delay in responding.
I have ordered the sampling coolers for the sites under permit so as to get on the semi-annual schedule of sampling
prior to June 30, 2018.
I do still have a couple questions since we are sampling OWS discharges as opposed to stormwater discharges.

While there is some minimal influence from stormwater to the OWS at these facilities, the majority of the discharge
from the OWS is from normal site activities at the diesel fuel islands.
Thus the OWS will discharge during non -rain events. A qualifying rain event may not have as much an influence on the
discharge as normal site activities.
The permit does state to sample during a measurable storm event, just wanted to be clear that that was necessary for
an OWS discharge not associated with stormwater.
Footnote #3 for Table 4 states the sample should be collected at each stormwater discharge outfall (SDO). I am
assuming in this case this location applies to the OWS discharge pipe?
Most of these sites have separate OWS discharges from site stormwater discharge thus sampling from the OWS pipe
should not be an issue, just wanted to verify that was the intended sample location.
Last question applies to Part II Section D.
Are qualitative inspections required of the OWS discharge? Do we need to complete the forms semi-annually as well?
Thanks for all the help on this,
Robert
Robert Wagner
o,...e.. Program Manager
Apex Companies, LLC
7724 Garland Cir
Roanoke, VA 24019
0) 540-563-4920 x4451 M) 540-798-1494
® Add me to your contact list!
We've moved! 7724 Garland Cir, Roanoke, VA 24019. Please update your contact list. Thanks.
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From: Georgoulias, Bethany<[e-mail]>
Sent: Tuesday, February 20, 2018 2:22 PM
To: Robert Wagner <[e-mail]>
Cc: Dwayne Yates <[e-mail]>; White, Sue <[e-mail]>; Lucas, Annette
<[e-mail]>; White, Glen <[e-mail]>; Grzyb, Julie <[e-mail]>
Subject: RE: [External] RE: PJF Southeast LLC
Robert,
Pardon the delay in my follow up on this. I have since spoken to Sue White about her site visit, and late Friday I talked
with Julie Gryzb, one of the supervisors in the NPDES Wastewater Program.
As we've discussed, SIC 5541 is not categorically captured by the NPDES Stormwater regulations in the
Transit/Transportation category. At categorically -captured sites under NCG08, vehicle maintenance activities (including
fueling) are subject to analytical stormwater monitoring when the motor oil usage threshold is triggered. But with no
maintenance shops at the Pilot Flying J sites with permits, last April I advised you to only perform qualitative
monitoring of stormwater discharges. That's because the current permit refers to O/W separators and secondary
containment discharges designated by the Division as subject to specific monitoring requirements in the permit that
include discharge limitations. I'm afraid I steered you wrong on that advice.

What now?
The short answer: Facilities like Pilot Flying J's that are under the NCG08 permit should be monitoring oil/water
separator discharges in accordance with Part II, Section C of the NCG080000 General Permit. In your case, the O/W
separator discharges are the reason for permit coverage (not the SIC), and they are subject to monitoring—specifically
in Section C. We acknowledge that we incorrectly guided you, and we apologize for the confusion—please begin
monitoring in accordance with Part II, Section C on a semi-annual schedule. We need to do a better iob with the
language in the permit when we renew it this year.
The longer answer includes some history, which I've tried to explain below:
Development files for the NCG08 General Permit suggest that oil/water separators at fueling stations like these were
intentionally captured in a different way under this permit. They were not part of the "default" SIC codes in the
Transit/Transportation Stormwater category. Because O/W separators are considered water pollution control facilities
or treatment works (GS 143-213), they were incorporated into this general permit with the same effluent discharge
limits as oil/water separators at larger facilities permitted through the NPDES wastewater program. Discharges from
smaller facilities with O/W separators could be handled under the NCG08 general permit instead of under an individual
wastewater permit, and that's most likely how the provision entered our permit.
Why do O/W separators require a discharge permit? The NC General Statutes (GS 143-215.1) require a permit to make
an outlet to waters of the state, and to operate treatment works. NC Rules 15A NCAC 02H .0127 include "Oil terminal
storage facilities" as a category for which the Division may develop a General NPDES Discharge Permit. The Definitions
for this rule section explain that this term includes "Oil/water separators such as those at maintenance garages, gas
stations, and National Guard and military reserve facilities." Basically, it comes down to the Division's authority to
address discharges from point sources of possible petroleum -contaminated stormwater that are treated by water
pollution control devices, which require a permit per NC's rules.
What about discharges from fueling areas here that are not routed through O/W separators at these Pilot Flying J sites
with SIC5541? These stormwater discharges are not categorically -captured and not necessarily subject to monitoring—
unless there was reason for DEQ to designate them (significant water quality impacts or problem wastes exposed in
those areas, for example). At your sites, it is prudent to observe them periodically, but not mandated (barring
designation). At a minimum, Stormwater Pollution Prevention Plan components should address the O/W separator
discharge and associated drainage areas. Obviously, it's a good idea to implement a comprehensive SPPP for the entire
site, but I'm not sure the permit as written applies that broadly. Again, we need to do a better job with permit language
to clarify obligations in these scenarios, and we'll be working on that this year.
I hope this clarifies the next steps for your sites in North Carolina. If you have any questions, please let us know. Also, I
encourage you to comment on our draft NCG080000 General Permit when it is available for public notice later this
year. We will send out correspondence to permittees with updates on the status of that proposed draft.
Best regards,
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethany.geor oulias(Da
ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
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.
From: Robert Wagner [mailto:[e-mail]]
Sent: Wednesday, January 31, 2018 9:52 AM
To: Georgoulias, Bethany<[e-mail]>
Cc: Dwayne Yates <[e-mail]>; White, Sue <[e-mail]>; Lucas, Annette
<[e-mail]>; White, Glen <[e-mail]>
Subject: RE: [External] RE: PJF Southeast LLC
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[e-mail].
Bethany again sorry for the delay been traveling and in the field again.
I have provided some responses in red below with some attachments.
Thanks,
Robert
Robert Wagner
o,...e.. Program Manager
Apex Companies, LLC
7724 Garland Cir
Roanoke, VA 24019
0) 540-563-4920 x4451 M) 540-798-1494
® Add me to your contact list!
We've moved! 7724 Garland Cir, Roanoke, VA 24019. Please update your contact list. Thanks.
Follow Apex on ®and Like us on
Privacy Notice: This message and any attachment(s) hereto are intended solely for the individual(s) listed in the masthead. This message may contain information
that is privileged or otherwise protected from disclosure. Any review, dissemination or use of this message or its contents by persons other than the addressee(s) is
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From: Georgoulias, Bethany[mailto:[e-mail]]
Sent: Monday, January 29, 2018 3:09 PM
To: Robert Wagner <[e-mail]>
Cc: Dwayne Yates <[e-mail]>; White, Sue <[e-mail]>; Lucas, Annette
<[e-mail]>; White, Glen <[e-mail]>
Subject: RE: [External] RE: PJF Southeast LLC
Robert,
Thank you for your patience as we try to reconstruct the history on this Pilot site. I spoke with Sue today. I will be out of
the office until Friday, so if any other questions arise as a result of the site visit this week, I can follow up when I return if
needed.
Here is a summary of what I've found so far:
As you noted, SIC 5541 (gas stations/truck station retail) is not part of the group that is categorically captured by
the NPDES Stormwater Regulations.

• Sites with this industrial activity that are not already permitted do not need an NPDES Stormwater Permit based
on standard requirements, unless there is a water quality impact issue that would prompt designation under the
program. Please identify the water quality issue at this or any other site if this is the case.
• The NCG08 permit primarily addresses Transportation facilities with vehicle maintenance operations, but a
special section of this general permit specifically addresses discharges from oil/water separators. Yes, As we
have determined previously the sites do not have vehicle maintenance facilities. The DMR indicates OWS and
secondary containment discharge at Petroleum Bulk Stations and Terminals, which this and other sites are not.
• The permitted site in question (NCG080455) has had a permit since 1996, and I found the attached DMR in the
facility's file from 2016. It appears the site had been monitoring oil/water separator discharges in the past. Yes
the previous owner's consultant was collecting samples and submitting DMRs, but when we were provided the
documentation and sampling locations from the previous owners, they were sampling the facilities stormwater
outfalls and not the OWS outfall (see attached aerial they provided us). At this site and many others the
stormwater and OWS outfalls are different locations. Once we saw this I began our conversation last spring as
to why Pilot was required to sample stormwater when the facility was not a vehicle maintenance facility or a
bulk station or terminal as the DMRs stated that were being submitted.
• General Permit development files going back to 1992 mention that the NPDES Wastewater Program had been
reviewing discharge limitations for oil/water separators from truck stops. However, there are no records on
specifically which sites were given coverage under the NCG08 stormwater permit at that time. Pilot is willing to
do whatever is required of them under the program based on their site activities.
• Given that the PFJ facility under COC NCG080455 would not otherwise be captured in the NPDES stormwater
program (because of the different SIC), it is more logical that this site is under the NCG08 permit because of the
oil/water separator discharges and should be monitoring discharges from that device accordingly. This is helpful
in determining Pilot's requirements moving forward.
• Past inspection records suggest DWQ inspected this site's oil/water separator and assumed the same. Can I get
a copy of the inspection records for Pilot 6955?
• Robert, there is a good chance I misdirected you last spring on your question about whether to monitor, now
that I'm digging deeper into specific history here. Could you forward me that exchange between us? I
apologize for confusion about this I may have caused, and as we strive to better connect the dots here. We will
certainly work with you if the site ceased analytical monitoring in response to that advice and now needs to
revise monitoring strategy under the permit for this site. I have attached the email chain from last Spring and
greatly appreciate your willingness to work with us through this confusion and am glad we are figuring this out
now so we can ensure all sites are in compliance for the entirety of 2018.
Bethany
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethanygeor oulias e ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
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.
From: Robert Wagner [mailto:[e-mail]]
Sent: Friday, January 26, 2018 2:03 PM

To: Georgoulias, Bethany<[e-mail]>
Cc: Dwayne Yates <[e-mail]>; White, Sue <[e-mail]>; Lucas, Annette
<[e-mail]>
Subject: RE: [External] RE: PJF Southeast LLC
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
[e-mail].
Bethany
Sorry for the delay in getting back to you as I have been traveling.
I am inserting your questions below so that I can answer efficiently.
Did this company initiate submittal of NOls for the NCG08 permit, and when was that?
Wilco Hess submitted the initial NOls.
Speedway actually purchased Wilco and operated these sites for a little bit of time, but I do not think that the permits
were ever transferred over to Speedway, thus they do not have any of the original Wilco submittals.
If it was a previous company, did the current company initiate a transfer of ownership for the NCG08 COCs held
by these operations?
All the sites are currently owned by PFJ Southeast.
The old Wilco/Speedways were changed over to PFJ Southeast in 2017 when the purchase was complete.
One example of a revised COC is attached, which is the site that we are meeting Sue at next week.
Do any of these sites specifically follow requirements for O/W separator discharges in the NCG08 permit that
include limits, or have they just been sampling discharges under storm water (with benchmark) provisions? Or
do they really know what they were supposed to sample for?
All these sites do have O/W separators to contain any fuel spills as the diesel fueling islands; however, they are
not classified as petroleum bulk stations or terminals.
As you and I discussed via email in the Spring of last year, since these facilities do not have maintenance
operations, they are not required to perform any quantitative sampling, just qualitative has been completed
since PFJ Southeast assumed control of the sites per our communication.
Are any of the original COC issuance letters or other documentation in the company's possession?
PFJ does not have any older COCs since the sites changed hands several times from the initial COC holder before Pilot
assumed control of site.
Hope the above helps with some background and what we have to date.
Obviously we all want to get this straight and make sure we are complying with the existing permits and determine if a
permit is required at a site such as FJ 682 that is across from 6955.
Thanks and talk with you soon,
Robert
10

Robert Wagner
o,�..e.. Program Manager
Apex Companies, LLC
7724 Garland Cir
Roanoke, VA 24019
0) 540-563-4920 x4451 M) 540-798-1494
® Add me to your contact list!
We've moved! 7724 Garland Cir, Roanoke, VA 24019. Please update your contact list. Thanks.
Follow Apex on ®and Like us on
Privacy Notice: This message and any attachment(s) hereto are intended solely for the individual(s) listed in the masthead. This message may contain information
that is privileged or otherwise protected from disclosure. Any review, dissemination or use of this message or its contents by persons other than the addressee(s) is
strictly prohibited and may be unlawful. If you have received this message in error, please notify the sender by return e-mail and delete the message from your
system. Thank you.
From: Georgoulias, Bethany[mailto:[e-mail]]
Sent: Thursday, January 18, 2018 9:57 AM
To: Robert Wagner <[e-mail]>
Cc: Dwayne Yates <[e-mail]>; White, Sue <[e-mail]>; Lucas, Annette
<[e-mail]>
Subject: Re: [External] RE: PJF Southeast LLC
Robert,
It is likely I'll be out of the office the rest of the week because of school closures. I spoke with Sue White this
week, but I'll have to pick up the research next week.
As we look for the history of why these particular operations were covered under the NCG08 general permit,
we have some questions for you all as well. Did this company initiate submittal of NOIs for the NCG08 permit,
and when was that? If it was a previous company, did the current company initiate a transfer of ownership for
the NCG08 COCs held by these operations? You mentioned these used to owned by Speedway I think. Do any
of these sites specifically follow requirements for O/W separator discharges in the NCG08 permit that include
limits, or have they just been sampling discharges under stormwater (with benchmark) provisions? Or do they
really know what they were supposed to sample for? Are any of the original COC issuance letters or other
documentation in the company's possession?
It is possible that coverage began with a wastewater permit in the NPDES WW Program under the Division of
Water Quality many years ago, and ultimately was carried forward under the special provisions of NCG08 for
O/W separators. I understand the general permit was developed in 1992, when NPDES industrial stormwater
was beginning in the federal program. I'd like to look for permits these sites might have had prior to that -- it
could explain why they hold this coverage today.
11

States who are delegated NPDES programs have authority to designate stormwater discharges that would not
otherwise be categorically captured, so it's possible this is a case of designation early -on in our program
because of water quality impacts. We have lost a lot of DWQ staff to retirement who would remember that
far back, so I'm having to make some calls around to see what I can find out. I also have to review the permit
development files.
It would be helpful if the company can also provide any history on when NOls were submitted for coverage
under the NCG08, and/or any original documentation of that coverage. If NOls were simply voluntarily
submitted in the past, our program may have issued the COC as requested, and the permit obligation has now
stood for many years. Rescinding a permit on SW program eligibility basis could get complicated if we
determine any of these sites were/are supposed to be subject to discharge limits because of anti -backsliding
provisions in federal law.
I'll continue looking into this at my first opportunity.
Best regards,
Bethany
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 / 807-6372 (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 mar be suUtect to the Forth Carolina Public Records lain and mUr be disclosed to third parties.
From: Robert Wagner <[e-mail]>
Sent: Thursday, January 18, 2018 9:23:04 AM
To: Georgoulias, Bethany
Cc: Dwayne Yates
Subject: FW: [External] RE: PJF Southeast LLC
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
[e-mail].
Bethany
Hope you have enjoyed the snow as we have.
Just wanted to follow up on our conversation last week and see if you have had a chance to track down any of the
history on these truck stop sites.
We had to move our site meeting with Sue to the 31St due to weather.
We would like to discuss this further with you and others as needed prior to the 31St
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Thanks for any update you can provide.
Robert
Robert Wagner
o,...e.. Program Manager
Apex Companies, LLC
7724 Garland Cir
Roanoke, VA 24019
0)540-563-4920x4451 M)540-798-1494
® Add me to your contact list!
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From: White, Sue [mailto:[e-mail]]
Sent: Tuesday, January 16, 2018 9:31 AM
To: Dwayne Yates <[e-mail]>; Robert Wagner <[e-mail]>; White, Glen
<[e-mail]>
Subject: RE: [External] RE: PJF Southeast LLC
Hi Dwayne:
Thanks for checking. Due to the snow possibility, let's reschedule for week after next. Are you available on the 31St at
10:00? If not, what day that week would work for you?
Thanks!
Sue White, EI
Assistant Regional Engineer
Department of Energy, Minerals and Land Resources
336-776-9661 office
sue.whitea-ncdenr.gov
Winston Salem Regional Office
450 W. Hanes Mill Road
Winston Salem, NC 27106
0
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Dwayne Yates[mailto:[e-mail]]
Sent: Tuesday, January 16, 2018 8:14 AM
To: Robert Wagner <[e-mail]>; White, Sue <[e-mail]>; White, Glen
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<[e-mail]>
Subject: [External] RE: PJF Southeast LLC
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
[e-mail].
Good Morning,
I just wanted to confirm that the inspection was still scheduled for tomorrow. Thank you
Dwayne Yates
e
o,..... Project Manager
Apex Companies, LLC
7724 Garland Cir
Roanoke, VA 24019
0)540-563-4920 x4456 M)540-315-5650
® Add me to your contact list!
We've moved! 7724 Garland Cir, Roanoke, VA 24019. Please update your contact list. Thanks.
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that is privileged or otherwise protected from disclosure. Any review, dissemination or use of this message or its contents by persons other than the addressee(s) is
strictly prohibited and may be unlawful. If you have received this message in error, please notify the sender by return e-mail and delete the message from your
system. Thank you.
From: Robert Wagner
Sent: Thursday, January 11, 2018 11:37 AM
To: White, Sue <[e-mail]>; White, Glen <[e-mail]>
Cc: Dwayne Yates <[e-mail]>
Subject: RE: PJF Southeast LLC
Thank you for the email.
Yes we have you down for the 17th at 6955.
Dwayne Yates will be meeting with you.
His cell is 540-315-5650 should something come up that day.
I will forward the information to pilot and we will work on obtaining the permit and addressing the issues in the pictures.
We will assess 682 next week as well after our meeting at 6955.
Robert Wagner
endo o....e.. Program Manager
Apex Companies, LLC
7724 Garland Cir
Roanoke, VA 24019
0) 540-563-4920 x4451 M) 540-798-1494
® Add me to your contact list!
We've moved! 7724 Garland Cir, Roanoke, VA 24019. Please update your contact list. Thanks.
Follow Apex on Eland Like us on El
Privacy Notice: This message and any attachment(s) hereto are intended solely for the individual(s) listed in the masthead. This message may contain information
that is privileged or otherwise protected from disclosure. Any review, dissemination or use of this message or its contents by persons other than the addressee(s) is
strictly prohibited and may be unlawful. If you have received this message in error, please notify the sender by return e-mail and delete the message from your
system. Thank you.
14

From: White, Sue [mailto:[e-mail]]
Sent: Thursday, January 11, 2018 11:26 AM
To: White, Glen <[e-mail]>; Robert Wagner <[e-mail]>
Subject: PJF Southeast LLC
Mr. Wagner:
Here is the link needed to apply for coverage under the NCG080000: Transit and Transportation permit for the 1043
Jimmie Kerr location. Scroll down the page until you come to the correct permit number and click on it.
https://deg.nc.gov/about/divisions/energy-mineral-land-resources/npdes-stormwater-gps#ncg080000:-transit-and-
tra nsportation,-effective-11-1-2012,-expi res -10-31-2017
Also, I'm sending the compressed photos from the Flying J inspection in a separate email. You can use the NCG080000
permit as guidance to clean this site up. It needs accessible spill kits, the grease containers need to be cleaned and
moved from the storm drain (which drains to streams) and there are several oil spills, probably from leaking trucks, in
the parking area behind. As you can tell from the photos, there are general housekeeping issues as well. While this site
is not covered under a permit at this time, it must be. It's now under violation of Division of Water Resources
regulations which can lead to assessment of fines if not remedied.
We have a scheduled inspection for the Pilot Station #6955 at the 1044 Jimmy Kerr location (NCG080455) on January
17th at 10:30.
Please contact me with any questions or comments.
Thanks!
Sue White, EI
Assistant Regional Engineer
Department of Energy, Minerals and Land Resources
336-776-9661 office
sue.whitea-ncdenr.gov
Winston Salem Regional Office
450 W. Hanes Mill Road
Winston Salem, NC 27106
-"I',I'ls," 1,u,.. I.. ....
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Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
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