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HomeMy WebLinkAboutNCS000312 Draft Permit Cover Ltr_signedEnergy, Mineral and Land Resources ENVIRONMENTAL QUALITY ROY COOPER Governor MICHAEL S. REGAN Secretary WILLIAM E. (TOBY) VINSON, JR. lnterin Dlrecrar June 11, 2018 Scott Madix DART Acquisitions, LLC 4132 Pompano Road Charlotte, NC 28216 Subject: Draft NPDES Stormwater Permit Permit No. NCS000312 DART Acquisitions, LLC Mecklenburg County Dear Mr. Madix: Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review the draft carefully to ensure thorough understanding of the conditions and requirements it contains. The draft permit contains the following significant changes from the facility's current permit: 1. You are required to collect analytical and qualitative monitoring samples during "measurable storm events" as defined in Part II, Section B. This term is different from the "representative storm event" in earlier permits. 2. Requirements for the Stormwater Pollution Plan (SPPP) have been updated in Part II, Section A. 3. Monitoring requirements in the draft permit have not changed from the previous permit. Monitoring is maintained for Total Suspended Solids (TSS), Chemical Oxygen Demand (COD), and PH. Comments from our regional office staff or other information may result in adjustments to these requirements if it is apparent that your activities in some way may have the potential to release other parameters. Stormwater benchmarks remain in the permit as before. Keep in mind that benchmarks are not permit limits, but rather guidelines for implementing the Stormwater Pollution Prevention Plan (SPPP). A benchmark exceedance is not a permit violation; however, the permittee must respond to exceedances. The draft permit has modified the tiered response process for benchmark exceedances consistent with other permits in our program. Please become familiar with the tiered process as proper response under the tiers may be enforceable items under your permit. Response to the tiered process may include review of onsite conditions, installation of BMPs or requirements for more frequent monitoring. 4. Vehicle maintenance (Tables 4 & 5) monitoring parameters have been revised. Non -Polar Oil & Grease [EPA Method 1664 (SGT -HEM)] replaces Oil & Grease/TPH. The benchmark for Non -polar Oil & Grease using this method is 15 mg/L. This requirement appears in all individual stormwater State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources 1612 Mail Service Center 1 512 North Salisbury Street I Raleigh, NC 27699-1612 919 707 9200 T NCS000312 Draft Permit Page 2 permits; however, it only applies to facilities that perform onsite vehicle maintenance activities. If the facility begins vehicle maintenance during the permit cycle, the requirements shall apply. Also, pH monitoring is no longer required for discharges only associated with vehicle maintenance activities. The vehicle maintenance language in the permit has also been modified to clarify that these activities include not just vehicles, but also other similar equipment maintenance activities that may be exposed to stormwater. This has always been the Division's implementation of this requirement, but hopefully the adjusted language is a little clearer about this process. 5. Language has been added under Part II Section D to address potential responses to qualitative monitoring issues. 6. A new section on Special Conditions has been added in Part II, Section E to comply with federal regulations requiring electronic submittal of discharge monitoring reports. Our electronic submittal process is not available for use at this time, but we will continue to provide feedback on when this process will be available. 7. Civil and administrative penalty amounts have been updated to reflect current federal law in Part III, Section A, 2(b) and (g). 8. The definition of Bulk Storage of Liquid Materials was revised in Part IV Definitions to omit the language "located in close proximity to each other" as it applies to multiple above ground storage containers having a combined storage of 1,320 gallons. Please review the draft permit and submit any comments to me no later than 30 days following your receipt of the draft. Comments maybe emailed tome at bradlev.bennett@ncdenr.gov or mailed to my attention at NC DEMLR, Stormwater Permitting Program, 1612 Mail Service Center, Raleigh, NC 27699- 1612. With this notification the Division will solicit comment on this draft by publishing a notice in a local newspaper. Following the 30 day public comment period, the Division will review comments and take appropriate action prior to issuance of the final permit. If you have any questions, please email me or call me at (919) 807-6392. Sincerely, 1 1 / Bradley Bennett Stormwater Permitting Program Attachment: Draft Permit NCS000312 cc: Zahid Khan, DEMLR Mooresville Regional Office — via email Chad Broadway, Charlotte -Mecklenburg Stormwater Services —via email Stormwater Permitting Program Files