NCG190078_Lrt re Monitoring_20210608

John Deaton
PRESIDENT
Oriental, 8th of June 2021
Ms. Annette Lucas, PE
Stormwater Permitting Unit
NCDEQ/ DEMLR
Mail Service Center 1617
Raleigh NC 27699-1617
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ORIENTAL
NORTH CAROLINA
Karen Deaton
VICE-PRESIDENT
DENR-LAND QUALITY
STORNlWATER PERMITTING
RE: Petition to Reduce Frequency of Stormwater Discharge Analytical Monitoring
DEATON YACHT SERVICE, INC.
NPDES General Permit NCG190078
Dear Ms. Lucas:
We are submitting this request for a waiver from the Tier Two 4 monthly
analytical monitoring at the subject facility.
Since 2008, 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 BMW, there are no additional feasible BMPs that can be implemented to
consistently reduce Copper below the Benchmark Value.
I object to the low Benchmark Value set for Copper. Almost no facility can meet the
Fresh Water BMV of 0.010 mg/L (much less 0.006 mg/L for salt water) for Copper,
especially for those within an urban area. Boatyards cannot meet this BMV due to legacy
usage of copper -based bottom paint. The Copper BMV is unreasonable and nearly
impossible to obtain without expensive stormwater treatment systems. I suggest that the
BMV for Copper be set at 1.3 mg/L which is the USEPA's Action Level for drinking
water.
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.
1306 Neuse Drive Oriental, North Carolina 28571 [phone]

BMPs currently installed include placing ground tarps under boats undergoing hull repair
work. Additional we installed in April 2021 a new Powerwash Wash Water Recycle
System with a concrete pad.
Other implemented BMP's include maintaining a vegetative buffer along the on -site
perimeter, swales, 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 through the end of the current 2020-2025 Permit term.
If you need to discuss this petition, you may contact me at the Deaton Yacht Service
facility (phone [phone] or 252-571-5030). If we do not receive any response from
NCDEQ/DEMLR within 45 days from the date of this letter, we will assume our request
h en approved.
Sinc rely
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John eat n