NCS000598_Email Permittee Comments_20190820

Garcia, Lauren V
From: Garcia, Lauren V
Sent: Tuesday, August 20, 2019 10:57 AM
To: Stephen Kim
Cc: Rodney St. John
Subject: RE: [External] Application for Individual NPDES Permit for Industrial Stormwater
Discharges - Airgas Mebane ASU
Attachments: DRAFTw.Comments_NCS000598_Airgas USA LLC_July 2019.pdf
Good morning Stephen,
Yes, emailed comments are more than sufficient. I have attached an updated draft of the permit reflecting the changes.
All are highlighted.
Comment 1) Dates have been updated.
Comment 2) Longitude has been corrected.
Comment 3) We agree that monitoring only for nitrogen and phosphorous will be sufficient for the permit term.
Monitoring data for these parameters will be reviewed during the renewal in 2024 and it will be determined if the
parameters can be removed from the permit altogether. It should be noted that fertilizer can contribute to higher
nitrogen levels in stormwater discharge. We would consider this a cause to add a benchmark requirement during the
renewal.
The Non -Polar Oil and Grease parameter is only required for outfalls that discharge runoff from vehicle/equipment
maintenance areas in which more than 55-gallons of new motor oil/month is used when averaged over the calendar
year. The 15 mg/L is used as the benchmark for only petroleum -based hydrocarbons. We use the regular oil and grease
benchmark of 30 mg/L for animal fats and greases.
It is not typical for facilities to have trouble staying under the 15 mg/L benchmark. A value as high as 8 mg/L would be
indicative of an issue at the facility.
Questions) eDMR will not be ready to accept stormwater data by the time this permit is finalized, but is expected to be
ready during the permit term. The facility will be notified when eDMR is up and running. Until then, the facility will just
need to submit the paper forms.
The permit is on track to be finalized before the facility opens.
Let me know if you have any more questions/comments!
Lauren
From: Stephen Kim<[e-mail]>
Sent: Friday, August 09, 2019 3:46 PM
To: Garcia, Lauren V <[e-mail]>
Cc: Rodney St. John <[e-mail]>
Subject: RE: [External] Application for Individual NPDES Permit for Industrial Stormwater Discharges - Airgas Mebane
ASU

External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
report.spamLa)nc.xc
Hi Lauren,
We have reviewed the draft permit and have comments and questions. On behalf of Airgas, I submit comments on the
draft permit and questions to your attention via this email.
Comment #1: Permit Effective and Expiration Dates in the cover sheet
There is a slight delay in construction and in obtaining the Certificate of Occupancy by approximately one month. The
permit effective and expiration dates proposed in the draft permit are September 1, 2019 and August 31, 2024,
respectively. We propose that the permit effective date be October 1, 2019 and the permit expiration date September
30, 2024.
Comment #2: Part I. Section C: Location. Paee 2 of 29
The Longitude shown in the location map in the draft permit is 36' 05' 29"W. It should be changed to 790 17'
57"W. This location would be the Outfall 001 location.
Comment #3: Table 1 Analytical Monitoring Requirements, Page 7 and 8 of 29
We agree to the list of the parameters and we also agree to the benchmark values for TSS, COD and pH. The proposed
operation at the facility is air separation and final products are liquid nitrogen, liquid oxygen and liquid argon, which are
not pollutants. Since it is not anticipated that chemicals would be used outdoors in a way that would cause Total
Nitrogen and Total Phosphorus in the runoff, we suggest that the benchmark values for Total Nitrogen and Total
Phosphorus not be included in the final permit. It is our opinion that monitoring only would be sufficient. In addition,
we believe that the benchmark value of 15 mg/I for oil & grease in the draft permit can be higher and suggest that the
benchmark value for oil and grease be 30 mg/I.
Comments #4: Part IV.7. Certificate of Coverage, Page 25 of 29
It states that "the Certificate of Coverage (COC) is the cover sheet which accompanies a General Permit upon issuance
and lists the facility name... under any General Permit and is signed by the Director." We comment that the reference for
"a General permit" should be removed and replaced by "an Individual Permit."
Questions:
In accordance with Section D of Part II, when Airgas conducts the analytical monitoring from January 1, 2020, it will need
to report the stormwater monitoring data on eDMRs. The Division may have been implementing the eDMR system. The
question is: Will eDMR be ready to accept stormwater monitoring data for Airgas by that time or will Airgas need to wait
for the Division's notification as stated in Section D.1 in page 12 of 29?
I trust that submitting comments via this email is sufficient. If comments and questions should be in the letter form,
please let us know and we can follow up accordingly.
If you have any questions about out comments and questions, please let me know. I copy this email to Mr. Rodney St.
John for our communication purpose. Thanks.

Stephen H. Kim, P.E.
Genesis Environmental Technologies, Inc.
[phone]
On July 19, 2019 at 1:57 PM Stephen Kim<[e-mail]> wrote:
Thanks Lauren!
Stephen H. Kim, P.E.
Genesis Environmental Technologies, Inc.
[phone]
On July 19, 2019 at 1:44 PM "Garcia, Lauren V" <[e-mail]> wrote:
Stephen,
Ok great, then here is the draft!
Lauren
From: Stephen Kim <[e-mail]>
Sent: Friday, July 19, 2019 1:43 PM
To: Garcia, Lauren V <[e-mail]>
Subject: RE: [External] Application for Individual NPDES Permit for Industrial Stormwater
Discharges - Airgas Mebane ASU
External email. Do not click links or open attachments unless you verify. Send all
s an attachment to [e-mail]
Hi Lauren,
Thank you for the update. Rodney is the contact person and has other
responsibilities for the entire construction project. Anyway I follow up with folks
to ensure that the permitting process goes well and provide necessary
information. I will plan to review the draft permit as their consultant and we will
provide comments on the draft permit as needed in time. Thanks again. Have a
great weekend!
Stephen H. Kim, P.E.
Genesis Environmental Technologies, Inc.
[phone]

On July 19, 2019 at 1:06 PM "Garcia, Lauren V"
<[e-mail]> wrote:
Hello Stephen,
I am the permit writer. Are you acting as the permit contact for the
facility or should the draft permit go to Rodney St. John? Rodney St.
John is listed currently listed in our system as the permit contact.
The permit has been drafted and is ready for a 30-day comment period.
During this time, the permit contact has the opportunity to review the
draft and address any issues or concerns. The draft has also been
published for a 30-day public comment period:
https://deg.nc.gov/news/events/public-comment-period-draft-npdes-
stormwater-permit-airgas-usa-Ilc-0. The 30-day comment period is
scheduled to end August 31.
Thanks,
Lauren
From: McCoy, Suzanne
Sent: Friday, July 19, 2019 9:07 AM
To: Garcia, Lauren V <[e-mail]>
Cc: Stephen Kim<[e-mail]>
Subject: FW: [External] Application for Individual NPDES Permit for
Industrial Stormwater Discharges - Airgas Mebane ASU
Good morning Lauren.
This is NCS000598.
Can you contact Stephen Kim to give him a status update.
Thank you.

Suzanne McCoy
Stormwater Program Administrative Specialist
Division of Energy, Mineral and Land Resources
Department of Environmental Quality
512 N. Salisbury Street, Office 640K, Raleigh, NC 27604
1612 Mail Service Center, Raleigh, NC 27699-1612
919-707-3640
Website: http://deg.nc.gov/about/divisions/energy-mineral-land-
resou rces/stormwater
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North Carolina Public Records Law and may be disclosed to third parties.
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environment.
From: Stephen Kim[mailto:[e-mail]]
Sent: Thursday, July 18, 2019 7:50 PM
To: McCoy, Suzanne <[e-mail]>
Cc: Rodney St. John <[e-mail]>
Subject: Re: [External] Application for Individual NPDES Permit for
Industrial Stormwater Discharges - Airgas Mebane ASU
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verify. Send all suspicious email as an attachment to i � I ci i I t i i i ,

Hi Suzanne,
Just checking in. Hope that the application has been assigned to a
permit writer and is in the permitting process. Would you be able
to tell us who is working on this permit application so that we can
be in contact with the permit writer? Again, if anyone has any
question about the application, we will be glad to answer
them. Thank you!
Stephen H. Kim, P.E.
Genesis Environmental Technologies, Inc.
[phone]
On June 25, 2019 at 5:19 PM Stephen Kim
<[e-mail]> wrote:
Great! Thank you for letting us know that you have
received it. Again, if anyone has any questions about
the application, please let me or Rodney know and we
will answer them.
Stephen Kim, P.E.
Genesis Environmental Technologies, Inc.
[phone]
On Jun 25, 2019, at 2:53 PM, McCoy, Suzanne <
[e-mail]> wrote:
I received the package.
Someone will contact you soon.
Suzanne McCoy
Stormwater Program Administrative
Specialist
Division of Energy, Mineral and Land
Resources
Department of Environmental Quality
512 N. Salisbury Street, Office 640K,
Raleigh, NC 27604
1612 Mail Service Center, Raleigh, NC
27699-1612

919-707-3640
Website: http://deg.nc.gov/about/divisions
/energy-mineral-land-
resou rces/stormwater
<i mage001.j pg>
Email correspondence to and from this
address is subject to the
North Carolina Public Records Law and
may be disclosed to third parties.
Before printing this email, please
consider your budget and the
environment.
From: Stephen Kim
[mailto:genesisenvironmental@comcas
t. net]
Sent: Monday, June 24, 2019 11:24 AM
To: McCoy, Suzanne
<[e-mail]>
Cc: Rodney St. John
<Rodney.St.John@Ai rgas.com>
Subject: [External] Application for
Individual NPDES Permit for Industrial
Stormwater Discharges - Airgas Mebane
ASU
External email. Do not click links
or open attachments unless you verify.
Send all suspicious email as an attachment
to I1! 1 � I I I
Good morning Ms. McCoy,
On behalf of Airgas USA, LLC, I am
submitting the attached application for

an individual NPDES permit for
industrial stormwater discharges as
instructed. Airgas has mailed out to
your attention one hard copy of the
application package including the check
(the permit fee) in the amount of $860
payable to NCDEQ. If you do not
receive it by mid this week, please let
me know we will track it down.
This facility is a new
construction. Airgas plans to complete
the construction and operate the
constructed facility by September 30,
2019. Airgas would like to receive the
permit by then.
As you may know, I have consulted with
Ms. Lauren Garcia in your office when
this application was prepared. If you,
Ms. Garcia or someone else has any
questions, please contact me or Mr.
Rodney St. John at your convenience. I
copy this email to Mr. St.
John. Thanks!
Stephen H. Kim, P.E.
Genesis Environmental
Technologies, Inc.
PO Box 497, Dresher, PA 19025-2015
[phone]