NCG190108_Tier Relief Request_20230320

Services G
March 17, 2023
Brain Lambe
Stormwater Permitting Unit
NCDEQ/DEMLR
127 Cardinal Drive Ext.
Wilmington, NC 28405
8916 Oregon Inlet Court
Raleigh, North Carolina 27603
Phone: [phone]
Fax: [phone]
MA;, J zQz3
RE: Petition to Reduce Frequency of Stormwater Discharge Analytical Monitoring
Coral Bay Marina — Morehead City
NPDES General Permit NCG190108
Dear Mr. Lambe
We are submitting this request for a waiver from the Tier Two monthly analytical monitoring at
the subject facility's representative outfalls SDO-001 (see Figure 1) and SDO-004 (see Figure 2).
For several years, this facility has been collecting stormwater samples for analysis This facility
has not been able to consistently reduce Copper, Zinc, and Total Suspended Solids below the
Benchmark Values (DMRs on file at NCDEQ/ DWR Central Files and at Wilmington Regional
Office). While the metal concentrations' have been up and down over the past years, and almost
never below the BMV, there are no feasible BMPs that can be implemented to consistently
reduce metals below the Benchmark Value.
There are several reasons why Copper measurements will probably never be below the
benchmark value at the Coral Bay boatyard:
• The BMV of 0.006 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 than Copper level than
another discharge (stormwater). Its 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 Garber2(htti)s://forestemetwork.com/stormwater-
industrial-facility-seattlen has indicated that urban air deposition may account for a
significant load exceeding 0.006 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
Copper has never been below the BMV of 0.006 ppm.
z Bentsen, Stephen and Kelly Garber (2017 Nov -Dee) Evaluating Urban Air Deposition on an Industrial Facility in
Seattle. Stormwater, Vol. 18, No. 8.

Coral Bay Marina— Waiver Request `��((�
March 17, 2023 S n t7 V
Page 2
environment for many decades. Zinc has many sources including galvanized metal
buildings, roofs, fencing, anodes, and galvanized boat trailers.
• Another source for Copper is from automotive tires and brake pads
(htti)s:Hfortress wa eov/ecy/publications/documents/1110087 pdfl. This facility is bound
to the north by Arendell St (US 70) which has a high volume of traffic.
We believe our funds would be better spent maintaining BMPs instead of on expensive analytical
monitoring costs. Monthly monitoring will not improve water quality.
BMPs currently implemented include:
• Placing ground tarps under boats undergoing hull repair work which should trap bottom
paint particles.
• Rinsing boats (w/ potable water and w/o the use of detergents) over the water so less salt
and hull residue is deposited within the SDO drainage areas.
• Maintaining a grass buffer along the bulkhead to trap sediment in sheet flow runoff.
Proposed BMPs include:
• Improve and maintain sediment -trapping buffers closer to the sampling points.
• Weekly cleaning (using dry methods) of the concrete ramp and small trench drain
upstream of the SDO-001 sampling point with sediment collected into plastic bags then
disposed off -site.
We are requesting a waiver from the monthly Tier Two monitoring effective immediately. We
will continue with the quarterly 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 or Ed Bailey at Coral Bay Marina
(Phone [phone]). If we do not receive a response from NCDEQ/ DEMLR within 45 days
from the date of this letter, we will assume our request has been approved.
Since
S ORM ATER RVICES GROUP, LLC
ames D. Frei
Senior Project Manager
Enclosures.
cc: Ed Bailey, Coral Bay Marina
File
' Department of Ecology, State of Washington, 2011 December, Copper and Zinc Loading Associated with
Automotive Brake -Pad and Tire Wear. Publication No. 11-10-087.

Coral Bay Marina — Waiver Request
March 17, 2023
Page 3
SDC 601 Sample
_ Collection Point
Trench Drain
Figure 1 - View at SDO-001
Figure 2 - View at SDO-004
SwSG
Figure 1 shows the SDO-001
sample collection point at a small
catch basin. This catch basin
discharges via a small pipe that
passes through the bulkhead into
the marina basin.
One proposed BMP is to improve
the ground cover adjacent to the
concrete ramp to reduce sediment
in the runoff.
Another proposed BMP is to
sweep the concrete ramp and
clean out the trench drain of
sediment using dry methods,
collect the sediment into plastic
bags, and dispose into a
dumpster.. This BMP will occur
on a weekly basis.
Figure 2 shows the SDO-004
sample collection point at a small
catch basin. This catch basin
discharges via a small pipe that
passes through the bulkhead into
the marina basin.
One proposed BMP is to sweep
the pavement within 10 feet of
the catch basin, collect the
sediment into plastic bags, and
dispose into a dumpster. This
BMP will occur on a weekly
basis.

NCDEQ Division of Energy, Mineral and Land Resources
Stormwater Discharge Monitoring Report (DMR) Form for NCG190000
Marinas and Shipbuilding
Click here for instructions
Complete, sign, scan and submit the DMR via the Stormwater NPDES Permit Data Monitoring Report (DMR) Upload form within
30 days of receiving sampling results. Mail the original, signed hard copy of the DMR to the appropriate DEMLR Regional Office.
Certificate of Coverage No. NCG19 0108
Person Collecting Samples: J Frei/ SwSG
Facility Name: Coral Bay Marna Yachts Sales & Service
Laboratory Name: Pace Analytical/ SwSG
Facility County: Carteret
Laboratory Cert. No.: 12, 40, 633, 5054
Discharge during this period:
+
Yes
No (if no, skip to signature and date)
Has your facility implemented mandatory Tier response actions this sample period for any benchmark exceedances? + Yes _ No
If so, which Tier (I, 11, or III)? 1
A copy of this DMR has been uploaded electronically via https://edocs.de0.nc.gov/Forms/SW-DMR El Yes [—]No
Date Uploaded: 03/16/2023
Analytical Monitoring Requirements for Outfalls with Industrial Activities —Benchmarks in (Red)
Parameter
Code
Parameter
Outfall001
Outfall004
Outfall
Outfall
Outfall
N/A
Receiving Stream Class
SB
SB
N/A
Date Sample Collected MM/DO/YYYY
02/25/2023
02/25/2023
46529
24-Hour Rainfall in inches
0.26
0.26
C0530
TSS in mg/L (100 or 50*)
53.8
79.6
NCOIL
Estimated New Motor/Hydraulic Oil
usage in al/month
+/_ 105
+/- 105
00340
Chemical Oxygen Demand in mg/L (120)
158
249
00400
pH in standard units (6.0 — 9.0 FW, 6.8—
844
8.30
8.5 SW)
01105
Aluminum, total recoverable in mg/ L
(0.75 FW, 0.24 SW)
1 240
1.910
01119
Copper, total recoverable in mg/L
0.125
0.130
(0.010 FW, 0.006 SW)
01051
Lead, total recoverable (as Ph)in mg/ L
(0.075 FW, 0.22 SIN)
1 0.0112
0.0148
01094
Zinc, total recoverable in mg/L (0.126
1 220
0.522
FW, 0.095 SW)
Additional parameters for outfalls in drainage areas that use>55 gallons per month of new hydraulic oil on average
00552
Non -Polar Oil & Grease in mg/L (15)
< 5.0
< 5.0
*Outfalls to Outstanding Resource Waters (ORW), High Quality Waters (HOW), Trout Waters (Tr) and Primary Nursery Areas (PNA)
have a benchmark TSS limit of 50 mg/L. All other water classifications have a benchmark of 100 mg/L
FW (Freshwater) SW (Saltwater)
Notes (optional): Outialls SDO-002, 003, and 005 represented by SDO-001 and SDO-004.
"I certify by my signature below, under penalty of law, that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
Inquiry of the person or persons who manage the system, or those persons directly responsible forgathering the information, the information
submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting
false information, including the possibility of fines and imprisonment for knowing violations."
M
Signature of Permittee or
Authorized Individual
03/16/2023
Date
[e-mail] 252-247-4231
Email Address Phone Number