NCG190052_Request to Reduce Monitoring Letter_20180521

B O A T W O R K S
V14,,Id—Clan Performance C ""I" a Flare.
May 17, 2018
530 Sensation Weigh
Beaufort, NC 28516
252.728.2690
www.jarrettbay.com
Ms. Annette Lucas, PE
Stormwater Permitting Unit
NCDEQ/DEMLR
Mail Service Center 1617
Raleigh NC 27699-116117/
RECEIVED
MAY 21 2013
DENR-LAND QUALITY
STORMWATER PERMITTING
RE: Petition to Reduce Frequency of Stormwater Discharge Analytical Monitoring
Jarrett Bay Boatworks
NPDES General Permit NCG190052
Dear Ms. Lucas:
We are submitting this request for a waiver from the Tier Two monthly analytical monitoring at
the subject facility.
Since 2007, 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 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 (https://forestemetwork.com/stormwater-
magazine/sw-water/sw-stormwater-management/evaluating-urban-air-depo 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.
• This facility is located near other boatyards that have a legacy of Copper usage in the
form of boat bottom paint. Bottom paint residue has been in the nearby and on-site
environment for many decades. Zinc has many sources including galvanized metal
buildings, roofs, fencing, anodes, and galvanized boat trailers.
Bentsen, Stephen and Kelly Garber (2017 Nov -Dec) Evaluating Urban Air Deposition on an Industrial Facility in
Seattle. Stormwater, Vol. 18, No. 8.

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Beaufort, NC 28516
B O A T W O R K 252.728.2690
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not bound by major roadways,
facility.
Copper is from automotive brake pads2
plications/documents/1110087.pdf). While this facility is
significant delivery truck traffic occurs at and around our
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 sanding work
on the yard. We require the use of vacuum sanders when doing any hull work that creates dust.
We have also installed Filtrexx Envirosoxx in several locations. Our experience is that these
devices are not as effective or practical as the vendor claims.
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 Jarrett Bay Boatworks facility
(phone [phone]). We would like to receive a response from NCDEQ/ DEMLR within 30
days from the date of this letter so that we may plan our upcoming Permit compliance activities.
Sincerely,
Jarrett Bay Boatworks
Dylan Cox
cc: J. Frei, Stormwater Services Group LLC
File
z Department of Ecology, State of Washington, 2011 December, Copper and Zinc Loading Associated with
Automotive Brake -Pad and Tire Wear. Publication No. 1 1-10-087.