NCG190108_Response to Tier Request_20230321

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
DOUGLAS R. ANSEL
Interim Director
NORTH CAROLINA
Environmental Quality
March 21, 2023
Coral Bay Marina Yachts Sales and Service, Inc.
Attn Edwin Bailey
4531 Arendell St.
Morehead City, NC 28557
RE: Petition to Reduce Frequency of Stormwater Discharge Analytical Monitoring
Coral Bay Marina Morehead City
NPDES General Permit NCG190108
Dear Mr. Bailey:
The request for a waiver form the Tier Two monthly analytical monitoring at the Coral Bay Marina Morehead
City, NCG 190108 is denied. To be relieved of the tier two protocols, you must implement monthly monitoring at
every outfall where a sampling result exceeded the benchmark value for two consecutive samples for all
parameters until three samples in a row are below the benchmark value, per permit.
The facility has not provided adequate evidence to support the waiver request. Please provide a sampling
summary for the permit duration. You may go back to the previous permit term prior to July 1, 2021 if you would
like to provide additional information. If the benchmarks are consistently over the benchmark values, please
review the tier responses required for each tier.
Provide stormwater management inspections relevant to the waiver request. You state that the current BMPs
include ground tarps, maintaining a grass buffer, and Rinsing boats over the water. If those PMPs are not
effective, you should look for additional BMPs to implement. You proposed improving sediment trapping buffers
closer to the sampling points and weekly cleaning of the concrete ramp. Additional BMPs should be implemented
to reduce pollution from the site.
Furthermore, you should not be washing boats over the water. This is not considered a BMP and may contribute
to water quality violations.
As far as the list of reasons why the copper will never be below the BMV, I do not think that this is the
appropriate venue for this debate. Rather, this would be more appropriate during the permit renewal process. The
BMV are established by the EPA. If you have evidence of air deposition in your area, you may present that
specific to your site. You may also present site specific evidence of other contamination issues such as brake pads
and blaming other boatyards for the exceedances.
At the end of your letter, you stated that if NCDEQ does not respond within 45 days, you will assume approval.
Please do not assume approval of any request.
You may contact me by email Brian.Lambe acncdennizov or by phone [phone] to request an inspection of
the facility or to discuss permit conditions.
Lcialist
II
Cc: NCDEMLR Central Office, Mike Lawyer
el D_E Q'� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Wilmington Regional Office 1127 Cardinal Drive Extension I Wilmington, North Carolina 28405
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9I0.796.72I5