NCG080000_NC PMA COMMENTS ON DRAFT_19970822

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary ID FE !_s
A. Preston Howard, Jr., P.E., Director
August 22, 1997
Mr. Tim Laughlin, P.E.
Executive Director
North Carolina Petroleum Marketers Association
P.O. Box 30519
Raleigh, North Carolina 27622
Subject: Draft NPDES General Stormwater Permit
NCGO80000
Dear Mr. Laughlin
In response to the draft general NPDES permit, No. NCG080000, for stormwater dischargers,
you submitted comments and proposed revisions to the draft permit in your letter of May 23, 1997.
Your comments and proposal are very much appreciated.
The wording changes that you propose is helpful in expressing the intent of the permit and has
been incorporated into the final permit. A copy of the issued permit is attached for your
information and use.
Thank you for reviewing the draft permit and suggestions for rewording the language. If you have
any questions concerning this matter or the permit requirements, please contact Mr. Bill Mills,
Stormwater Group, 919-733-5083, ext. 548.
Sincerely, i
A. Preston Howard, Jr., P.E
r__
cc: Coleen Sullins
Bradley Bennett
Attachment
P.O. Box 29535, Raleigh, North Carolina 27626.0535 Telephone [phone] FAX [phone]
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Gary F. Harris
o rth .ca ro n a Executive Vice President
Petroleum Marketers Association
P.O. Box 30519 • Raleigh, NC 27622. 919-782-4411 • FAX [phone]
Timothy L. Laughlin Willie S. Feather Douglas E. Howey, P.G.
Technical Trade Show Environmental
Director Coordinator Specialist
Mr. Bill Mills
N.C. Division of Water Quality
Water Quality Section
Stormwater Group
P.O. Box 29535
Raleigh, NC 27626-0535
RE: NPDES General Permit No. NCG080000
Dear Bill:
May 23, 1997
Thank you for sending the fact sheet regarding the public notice on the intent
to issue General NPDES Permits. The fact sheet is very helpful in understanding the
stormwater permitting requirements for oil water separators and discharges from
secondary containment structures for SIC Code 5171 facilities.
The fact sheet makes it clear that SIC Code 5171 facilities without vehicle
maintenance activity, but with an oil water separator are not categorically required to
have stormwater discharge permits. Although they will be decided on a case -by -case
basis by the DWQ.
What is still unclear to NCPMA is the statement on the cover sheet of the
General permit, second paragraph, last sentence beginning with, 'Other activities'. We
would like the wording to be revised to reflect a clearer understanding of the oil water
separator and secondary containment case -by -case exemption. The new wording
should read, 'Other activities, not categorically required to be permited, such .as iioint
source dischar es from oil water separators, seconda containment structures at
petroleum storage facilities with total petroleum storage capacity of less than 1 million
gallons, and/or vehicle maintenance areas at any facilities .other than those listed
above, may be designated on_a case -by -case basis as being required to be permited."
We would like a final copy of the general permit. Thank you for your time and
consideration. Please call us If more information is needed.
Sincere!
Tim Laughlin, PE
Technical Director
Fueling North Carolina's Future