NCG190064_Request For Relief Tier2_20180418

B�BY
BENNETT BRAS YACHTS
• ESTABLISHED 1986
March 12, 2018
Ms. Annette Lucas, PE
Stormwater Permitting Unit
NCDEQ/DEMLR
Mail Service Center 1617
Raleigh NC 27699-1617
Cape Fear Marina 34° 15.3't4 • 77° 56.9'w
1701 J.E.L. Wade Drive Wilmington, NC 28401
P 910.772.9277 F 910.772.1642 E [e-mail]
www.bbyachts.com
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RE: Petition. to Reduce Frequency of Stormwater Discharge Analytical Monitoring
BENNETT BROTHERS YACHTS
NPDES General Permit NCG190064
Dear Ms. Lucas:
We are submitting this request for a waiver from the Tier Two monthly analytical monitoring at
the subject facility.
Since 2004, this facility has been collecting semi-annual stormwater samples and analyzing for
metals. This facility has not been able to consistently reduce Copper below the Benchmark
Values (DMRs on file at NCDEQ/ DWR Central Files). While the metal concentrations have
been up and down over the past several years, and almost never below the BMV, there are no
additional feasible BMPs that can be implemented to consistently reduce Copper below the
Benchmark Value.
There are several reasons why Copper measurements will probably never be below the
benchmark value at our boatyard:
• The BMV of 0.005 ppm for Copper in stormwater discharges into saltwater bodies is
extremely low.
• The General Permit allows discharges of potable water. The USEPA has set an action
level of 1.3 ppm for Copper in potable water. It does not seem reasonable that one
allowable discharge (potable water) can have a much higher than Copper level than
another discharge (stormwater). It s not reasonable to expect any permittee to treat
stormwater to a level cleaner than potable water with available and feasible technology.
• Research performed by Bentsen and Garber (I ftp .:r 1 rc.5tt:rztetr car _coin stornwN.ater-
n�:��arinc___�s�����atcr%s��-:;toi��n���at�:r-n����az�<�;enlznt iva?.talitazt{urban-ai�'�„__._.cic�s�stiorr-
I Bentsen, Stephen and Kelly Garber (2017 Nov -Dec) Evaluating Urban Air Deposition on an Industrial Facility in
Seattle. Stormwater, Vol. 18, No. 8.

AJ
/ Cape Fear Marina 34° 15.3'N • 77° 56.9'w
1 �
B �` 1 - 1701 J.E.L. Wade Drive Wilmington, NC 28401
P 910.772.9277 E 910.772.1642 E [e-mail]
BENNETT BRoS YACHTS wwwbbyachts.com
. Es:AB esearcTi 6 performed b Bentsen and Garber htips://forestemetwork.com/storniwater-
P Y (_
magazine/sw-water/sw-stormwater-mana gement/evaluating-urban-air-dep_o_sition-
industrial-facility-seattle/ has indicated that urban air deposition may account for a
significant load exceeding 0.005 ppm by a factor of 5 to 10 into stormwater discharges.
• Bennett Brothers Yachts is located near downtown Wilmington, an area that has a legacy
of boatyards with Copper usage in the form of boat bottom paint. Bottom paint residue
has been in the nearby environment for many decades. Zinc has many sources including
galvanized metal buildings, roofs, fencing, anodes, and galvanized boat trailers.
• Another source for Copper is from automotive brake pads2
(hitps://fortress.wa.gov/ecy/publications/documents/1110087.pdf). This facility is bound
by a major roadway, Hwy 74, and the Isabel Holmes Bridge which passes at the south
end of the property.
We believe our funds would be better spent maintaining the implemented BMPs instead of on
expensive analytical monitoring costs. Monthly monitoring will not improve water quality.
BMPs currently installed include placing ground tarps under boats undergoing hull repair work.
Other implemented BMPs include maintaining a vegetative buffer along the on-site ditches and
bulkheads.
We are requesting a waiver from the monthly Tier Two monitoring effective immediately. We
will continue with the semi-annual analytical and qualitative monitoring and maintenance of
BMPs through the end of the current Permit term.
If you need to discuss this petition, you may contact me at the Bennett Brothers Yachts facility
(phone [phone]). If we do not receive a response from NCDEQ/ DEMLR within 45 days
from the date of this letter, we will assume our request has been approved.
' Bentsen, Stephen and Kelly Garber (2017 Nov -Dec) Evaluating Urban Air Deposition on an Industrial Facility in
Seattle. Stormwater, Vol. 18, No. 8.
2 Department of Ecology, State of Washington, 2011 December, Copper and Zinc Loading Associated with
Automotive Brake -Pad and Tire Wear. Publication No. l E-10-087.