NCG140000_Mark Cramer Comments_20220608

Carson, Brittany
From:
Mark Cramer <[e-mail]>
Sent:
Tuesday, June 7, 2022 11:28 AM
To:
Smith, Danny
Cc:
Carson, Brittany
Subject:
[External] Comments Regarding Draft General Permit NCG140000
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Danny — In addition to deletion of the Section B-8 BMP inspections at least every seven (7) calendar days that Brittany
Carson indicated was mistakenly added to the draft permit for NCG140000 (see email below), I would request that the
DEQ consider not adding the new Part G monitoring requirement of G-2(e) stating, "Daily flow rate shall be recorded by
a continuous flow measurement instrument. Alternatively, pump curves and pump logs may be used to calculate the
daily flow rate." Many concrete plants are designed such that ditches/ponds and other BMPs contain comingled
stormwater and the allowed process wastewaters (vehicle and equipment cleaning, wetting raw material stockpiles,
mixing drum cleanout) onsite and only discharge intermittently. Installing continuous flow meters creates a significant
expense and challenge to collect flow data that will not improve water quality ($16K capital quote I am aware of for a
single discharge point at one facility). This flow data will not facilitate stormwater meeting benchmarks or process
wastewaters meeting discharge limits.
Mark Cramer, P.E. - Senior Engineer
The El Group, Inc.
Environmental, Health and Safety Solutions. TM
Direct: 919.459.5229
Mobile: [phone]
www.eil.com
From: Carson, Brittany <[e-mail]>
Sent: Wednesday, May 18, 2022 10:23 AM
To: Mark Cramer <[e-mail]>
Subject: RE: [External] NCG140000 Inspections
Good morning Mark,
Thank you for pointing that out. That section (B-8) was mistakenly pulled into the draft NCG14. The 7 day BMP
inspections exist in the newly renewed NCG020000 (mining). The NCG02 and NCG14 share many similar aspects but that
one should not have been transferred. The BMP inspection requirements do not substantially change with the NCG14
renewal.
I will ensure it is removed from the NCG14 permit, thank you again for your comments.
Brittany Carson
General Industrial Stormwater Permit Coordinator
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality

Phone: [phone]
From: Mark Cramer <[e-mail]>
Sent: Wednesday, May 18, 2022 6:53 AM
To: Carson, Brittany <[e-mail]>
Cc: Mike Walker <[e-mail]>
Subject: [External] NCG140000 Inspections
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In reviewing the Draft General Permit NCG140000 NPDES Permit to Discharge Stormwater from Concrete Plants, I see
there is a new BMP Inspection requirement for BMPs to be inspected and documented every seven (7) calendar days
(Section B-8). However, Section B-12 still also has the requirement for quarterly inspections. Although they read a little
different, they are basically looking at the same things, and this does not make sense to me. If the DEQ desires to
increase the frequency of these facility inspections to every seven days from the previous semi-annual, I can understand
that, but wouldn't this basically cover the quarterly. Is this a carry-over from using the template from other General
Permits, or does the DEQ really intend for these to be separate inspections documented separately? If separate, can the
DEQ please provide additional guidance for what the differences are that applicants should be checking and
documenting?
Your assistance is greatly appreciated.
Mark Cramer, P.E. - Senior Engineer
The El Group, Inc.
Environmental, Health and Safety Solutions. TM
Direct: 919.459.5229
Mobile: [phone]
www.eil.com
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