NCG140000_CRMCA Comments on NCG14 Renewal_20220520

Comments to NCG14 Development 2022
1. On behalf of the industry, we are in the process of reviewing available monitoring data from the
microfiche file, and 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.
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.
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.
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.
5. CRMCA would 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.