NCG140000_Response to Comments_20220823

NCG14O00O: Response to Comments on Draft Permit (2022 Renewal)
1. If any monitoring parameters appear to demonstrate substantial industry compliance, CRMCA will be
requesting that these parameters be removed as monitoring parameters from the next version of
NCG14.
RESPONSE: We currently do not anticipate removing any parameters from monitoring. All listed
monitoring parameters in the NCG140000 General Permit are necessary for preserving NC Water
Quality standards.
2. Although not specifically part of NCG14, CRMCA will be requesting a review of the requirements for
closed -loop recycle wastewater treatment system (i.e., non -discharging concrete washout basin
systems), since the requirements for a system which does not discharge to surface water (which
should be encouraged, and include streamlined requirements) are far more onerous and costly
(through the Division of Water Resource's Aquifer Protection Section) than those for systems that do
discharge through NCG14, which do not require the same level of requirements. We will request that
the requirements for non -discharging systems be streamlined and made more equivalent to the
accessible and reasonable requirements contained for discharging systems present in NCG14.
RESPONSE: Our requirements for closed loop recycle systems following the guidelines set for by NC
Administrative Code15A NCAC 02T .1000.
3. With regards to wastewater treatment systems covered by this permit, it would likely be helpful if
they can be included within the definitions section of NCG14. CRMCA would be happy to assist in the
definition of these systems as they exist at covered facilities.
RESPONSE: Our General Permit NCG140000 Section F specifically states what types of wastewaters
are covered under NCG140000. The Definitions Section also includes Allowable Non-Stormwater
Discharges.
4. Given the tiered response nature of NCG14, CRMCA would like to request that future versions of this
permit consider the potential of reduction of monitoring after repeated "passing tests" (particularly
for stormwater discharges), such as an elimination of passing parameters or a reduction in testing
frequency, which is available to permittees covered by the Federal MSGP or NPDES stormwater
permits in other states. This would provide a tangible incentive to better performance under NCG14
by permittees as well as a cost savings.
RESPONSE: Our Program is confident in the Tier Response process we have implemented. It is
important for record -keeping purposes and to preserve water quality standards. When a sample
exceeds a stormwater benchmark, it is not a violation of the permit, and the Division wants to assist
the permittee in moving back under benchmark. When a sample exceeds a wastewater limit, it is a
violation of wastewater effluent limitations, and we cannot modify the response process for
wastewater discharges.
NC DEQ
August 23, 2022

NCG14O00O: Response to Comments on Draft Permit (2022 Renewal)
5. Remove the monitoring requirement for daily for rate being captured by a continuous flow
measurement device.
RESPONSE: The requirement for reporting daily flow rate is a requirement set forth in NC
Administrative Code 15A NCAC 02B .0505. Daily flow rate calculations are key for knowing how to
treat pH for a volume of water. There are limits set forth for wastewater discharged to High Quality
Waters or outstanding Resources Waters.
6. Recommend that monitoring be explicitly restricted in this permit only to periods of active, normal
operating hours for permitted facilities. This would eliminate the potential for having to take samples
after hours, during extreme weather, on holidays, etc., and would certainly promote on -site safety for
permitted facility personnel.
RESPONSE: Our General Permits already require sampling only during a facility's normal business
hours and non -adverse weather conditions.
NC DEQ
August 23, 2022