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Home My WebLink AboutNCG120013_Email RE NCG24 NOI Question and NCG12 COC_20190424Georgoulias, Bethany From: Georgoulias, Bethany Sent: Wednesday, April 24, 2019 12:04 PM To: Stoddard, Anna Cc: Strickland, Shane; Lucas, Annette Subject: RE: [RE: NCG24 General Permit Question and NCG120013 Attachments: Session Law 2012-200 Yard Waste No WW Provision.pdf That's fine. Remember that Type 1 will only have stormwater discharges, so the engineering alternatives analysis for wastewater discharges will not apply. That may abbreviate the effort somewhat. Please see Part V of that attached Session Law 2012-200 for that basis. 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 bethanygeor oulias e ncdenr.gov 512 N. Salisbury Street, Raleigh, NC 27604 (location) 1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing) Website: httD:Hdea.nc.Lyov/about/divisions/enerLv-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: Stoddard, Anna <Anna.Stoddard@greensboro-nc.gov> Sent: Wednesday, April 24, 2019 10:43 AM To: Georgoulias, Bethany <bethany.georgoulias@ncdenr.gov> Subject: [External] RE: NCG24 General Permit Question and NCG120013 External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to wamoA&amam(@nc.gov Okay, thank you. The NOI for the NCG24 permit requires a very large amount of information. It may take me some time but I will try to complete it as soon as possible. &e5toaaa4Z, Environmental Compliance Specialist Field Operations City of Greensboro Office: 336-373-2495 Mobile: 336-215-8609 401 Patton Avenue, Greensboro, NC 27406 Anna. Stoddard (cDgreensboro-nc.gov From: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Sent: Wednesday, April 24, 2019 10:06 AM To: Stoddard, Anna <Anna.Stoddard@greensboro-nc.gov> Cc: Wise, Brandon L <brandon.wise@ncdenr.gov>; Lucas, Annette <annette.lucas@ncdenr.gov>; Strickland, Shane <shane.strickland@ncdenr.gov> Subject: RE: NCG24 General Permit Question and NCG120013 Hi, Anna, It's absolutely terrific that the city has taken that initiative. My advice here would be yes, the site should apply for a separate NCG24 because it is a composting operation. The NOI should note that the discharge points have runoff from the landfill area (and that it is currently under NCG120013), and it should include past sampling data. We will work with the Winston-Salem Regional Office to evaluate the best next steps. I am not sure if that will be consolidating it with a new NCG12 that has augmented monitoring, or just a separate NCG24, but we will consider the options during review. Most likely the NOI will go to Shane Strickland in our office, so I've copied him for future reference. 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 bethanygeor oulias e 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: Stoddard, Anna <Anna.Stoddard@greensboro-nc.gov> Sent: Tuesday, April 23, 2019 12:55 PM To: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Subject: RE: [External] NCG24 General Permit Question External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to aaaaatagamPnc.goy Oh and to answer your question at the end, yes the runoff from the compost operations and the landfill come together before discharging from the site. From: Stoddard, Anna <Anna.Stoddard@greensboro-nc.gov> Sent: Tuesday, April 23, 2019 12:53 PM To: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Subject: RE: [External] NCG24 General Permit Question • sternal email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to JJJJJJJ&mLa)nc.gt, Currently I sample under the NCG12 general permit. COC NCG120013. I have been sampling for parameters required by NCG24 upon supervisor request as a City initiative. The two outfalls that are associated with composting activity are also sampled for general landfill activities. I guess I am trying to figure out if I even need a NCG24 permit for the site, which involves sampling for extra parameters, or if I need to just follow the requirements of the NCG12 permit currently issued to the site. Thanks for your help! lea Sinaaa4Z, Environmental Compliance Specialist Field Operations City of Greensboro Office: 336-373-2495 Mobile: 336-215-8609 401 Patton Avenue, Greensboro, NC 27406 Anna.Stoddard(cD-greensboro-nc.gov From: Georgoulias, Bethany<bethany.georgoulias@ncdenr.gov> Sent: Tuesday, April 23, 2019 10:42 AM To: Stoddard, Anna <Anna.Stoddard@greensboro-nc.gov> Cc: Lucas, Annette <annette.lucas@ncdenr.gov>; Patterson, Robert D <robert.patterson@ncdenr.gov> Subject: RE: [External] NCG24 General Permit Question CAUTION: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Report suspicious emails by clicking the "Phishing Alert" button. Good morning, Anna, Robert Patterson passed your questions along. I have some follow up questions for you to see if I can give you the best guidance. Why is the site sampling for additional parameters per NCG24 if the site is only covered under NCG12? Was this a specific directive or condition of the COC, or is this just an initiative by the City? I agree this is prudent given the source, but this is not typical. I can look into the specific COC files if you give me the COC number. Some COCs are "augmented" with additional monitoring, so perhaps it is a case like that? What is the COC number? Type 1 Compost facilities generally monitor for stormwater parameters only under NCG24 per past legislation and are not necessarily subject to wastewater monitoring/limits. In other cases, discharges may be considered wastewater, and the site would be required to obtain a separate NPDES permit — that is because NCG12 authorizes stormwater discharges only. The question then becomes whether the site ought to have a separate stormwater permit for a different activity at the same site. Normally it is issued the permit that addresses the majority of the industrial activity, but compost sites are typically permitted separately under NCG24. If the compost operation is segregated from the other landfill activities, it should be under an NCG24 so that the monitoring requirements are consistent with other compost operations and their discharges across the state. In that case, yes, the city should submit a separate NCI for NCG24 (unless for some reason this was already addressed with a special NCG12 COC previously). The alternative would be for the site to apply for an individual permit where we would address this special activity of the landfill, but this would be a much lengthier process. Is the runoff from the compost operation and the landfill combined before discharge? 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 bethanygeor oulias e 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: Patterson, Robert D Sent: Tuesday, April 23, 2019 7:14 AM To: Georgoulias, Bethany <bethany.georgoulias@ncdenr.gov> Subject: FW: [External] NCG24 General Permit Question NPDES question... Robert D. Patterson, P.E. Stormwater Engineer 919-707-3880 1 Robert. Patterson@ncdenr.gov https://deg.nc.gov/about/divisions/water-resources/water-quality-permitting/transportation-permitting NC Dept. of Environmental Quality I DWR 1 401 & Buffer Transportation Permitting Branch 512 N. Salisbury St., 12t^ floor 1 1617 Mail Service Center I Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Stoddard, Anna [mailto:Anna.Stoddard@greensboro-nc.gov] Sent: Monday, April 22, 2019 4:00 PM To: Patterson, Robert D <robert.patterson@ncdenr.gov> Subject: [External] NCG24 General Permit Question External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to La-sioam nc. ov Good Afternoon, I have recently come into the position of Environmental Compliance Specialist for the City of Greensboro and I have a couple of questions regarding the NCG24 General Permit for Compost Facilities. I sample stormwater at the White Street Landfill in Greensboro, NC under the NCG 120000 general permit. The landfill also has a permit to operate a Large Type 1 Composting Facility. Under the NCG120000 permit I have to sample three outfalls, two of which are associated with composting activities (these are the only two on site that are associated with composting activities). For the past 6 months I have been sampling those two outfalls as required under the NCG240000 general permit as well as the NCG120000 permit. Here is my question, since the compost facility is a part of the landfill, do I need to file an NOI to attain a NCG240000 general permit or can I continue to sample the two associated outfalls as required by that permit, in addition to the other outfall I sample under the NCG120000 permit? The NOI for NCG240000 requires a lot of information that has already been given to attain the NCG120000 general permit, so I am trying to see what I can do to make this a bit more efficient. Please advise and feel free to contact me with any questions or direct me to anyone else I may need to speak to. Thanks, &i.a &aaaa4a, Environmental Compliance Specialist Field Operations City of Greensboro Office: 336-373-2495 Mobile: 336-215-8609 401 Patton Avenue, Greensboro, NC 27406 Anna. Stoddard a-greensboro-nc.gov Please note that email sent to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.