NCS000571_Emails RE Tier Guidance for Renewal Permit_20221219

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Monday, December 19, 2022 8:30 AM
To: Young, Brianna A; Glenn, Elizabeth
Cc: Khan, Zahid
Subject: RE: [External] ISW Tier Responses
Elizabeth,
This is consistent with my interpretation as well. The only thing to clarify is that the permit instructs the permittee to
continue any Tier 3 monthly monitoring into renewal, as stated below. The Action Plan is a new requirement, and as
Brianna explained, the count towards triggering that formal plan in Tier 3 starts over. I can see how this is a bit
confusing, but essentially it means the outfall is considered 'Tier 1 but with monthly monitoring' at the start of the new
permit. It also makes sense to continue any measures implemented under the older permit as part of elevated tier
responses to reduce potential for benchmark exceedances.
Pennit NS000571
Footnotes:
1. MCasurcment frcqucnc:y: Quartcrly during a mcaxurahle storm event. Ifthe facility is monitoring
monthly due to Tier Two or Tier Three response actions, the facility shall continue a monthly
monitoring and reporting schedule in Tier Two or Tier Three status cuuil relief is granted.
2_ For each nampIM mc:aturahlc storm uvf� Tit. Ebc total prmipi[ation rnu_wt be rci:ordc:d_ An on -site
rain gauge is required. Where isolated sites are unmanned for extended periods of time, a local
rain gauge reading may be substitute for an on -site reading.
3_ Monitor only if coal or coal ash is transported through the drainage area, of these nutfalIs during
the quarter,
4. Mercury shall be measured by EPA Method 1631 E.
5_ Hardness sampling should be performed in conjunction with testing for hardness dependent
me is (cadmium, copper, l-ad. nickc1, siIvCr, and zinc),
6. If pH values outside this range are recorded in sampled stormwater discharges, but ambient
precipitation pll levels are lower, then the lower threshold of this benchmark range is the pll of
the prc:c:ipitation (within instrument accuracy) instead of 6 s_u__ Rcadinp from an ern -site; or local
rain gauge (or local precipitation data) must be documented to demonstrate background
concentrations were below the benchmark pH range.
I hope this is helpful.
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
D E
NORTH CAROLINA
Department of Environmental quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Young, Brianna A <[e-mail]>
Sent: Thursday, December 15, 2022 3:16 PM
To: Glenn, Elizabeth <[e-mail]>; Georgoulias, Bethany <[e-mail]>
Cc: Khan, Zahid <[e-mail]>
Subject: RE: [External] ISW Tier Responses
Hello Elizabeth,
Thank you for your patience. Please see below for responses.
For example, we have an outfall at Cliffside that was T3 before the new permit was issued. A sample just came back
demonstrating a benchmark exceedance. Would this require creation of the action plan under the new permit,
despite the fact that the outfall was already in T3 under the old permit?
Tier response resets at permit reissuance. Therefore, the count towards required Tiered Response would begin at Tier 1,
and not a continuation of Tier 3, with the new permit.
A sampling event in November produced a benchmark exceedance and we are currently addressing it. The sampling
event in December repeated the same findings. Since the exceedance in November is under an Action Plan, can this
December exceedance reference that it is currently being addressed?
I am assuming this means you are addressing a Tier III response? If you are already working on an Action Plan for the
same exceedance at the same outfall for consecutive months, then the December report can reference an Action Plan is
being developed. However, please make sure to follow the requirements of your current permit to ensure compliance.
Bethany or Zahid, please correct if any of this information is wrong.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting 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. 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: Glenn, Elizabeth <[e-mail]>
Sent: Thursday, December 15, 2022 3:07 PM
To: Young, Brianna A <[e-mail]>; Georgoulias, Bethany <[e-mail]>
Cc: Khan, Zahid <[e-mail]>
Subject: RE: [External] ISW Tier Responses
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Hi Brianna —
No answers yet. I know it's a busy time for everyone.
Thanks for following up!
J. Elizabeth Glenn
Permitting & Compliance
Duke Energy, Environmental Services
Office: [phone]
From: Young, Brianna A <[e-mail]>
Sent: Thursday, December 15, 2022 2:00 PM
To: Glenn, Elizabeth <[e-mail]>; Georgoulias, Bethany <[e-mail]>
Cc: Khan, Zahid <[e-mail]>
Subject: RE: [External] ISW Tier Responses
Hello Elizabeth,
I apologize for the delay in responding. Have you received answers to your questions? If not, please let me know and I
will get you what you need.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting 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. 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: Glenn, Elizabeth <[e-mail]>
Sent: Monday, December 12, 2022 2:58 PM
To: Georgoulias, Bethany<[e-mail]>; Young, Brianna A <[e-mail]>
Cc: Khan, Zahid <[e-mail]>
Subject: [External] ISW Tier Responses
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Good afternoon —
I would like some clarification on Tier responses and action plans.
For example, we have an outfall at Cliffside that was T3 before the new permit was issued. A sample just came
back demonstrating a benchmark exceedance. Would this require creation of the action plan under the new
permit, despite the fact that the outfall was already in T3 under the old permit?
A sampling event in November produced a benchmark exceedance and we are currently addressing it. The
sampling event in December repeated the same findings. Since the exceedance in November is under an Action
Plan, can this December exceedance reference that it is currently being addressed?
Thankyou!
J. Elizabeth Glenn
Permitting & Compliance
Duke Energy, Environmental Services
Office: [phone]