Mark Cramer_ Draft NCG050000 Comments

Cook, Brittany
From: Mark Cramer <[e-mail]>
Sent: Thursday, April 20, 2023 11:45 AM
To: Cook, Brittany
Subject: [External] Draft NCG050000 Questions
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
I see the draft NCG050000 is now available for review, and have taken a quick look. I have a couple of questions:
1. Inspections—Section B-7 describes Facility Inspections that need to occur "at a minimum of semi-annually' and
Section B-11 discusses inspections that need to occur"at a minimum on a quarterly schedule." Are these
different inspections, or should both say quarterly? What is the difference?
2. The Part D Qualitative Monitoring of Stormwater Discharges D-1.(b) states that, "Visual inspections shall be
performed concurrent with required analytical monitoring." However,the analytical monitoring is only required
if more than 55-gallons of new motor oil and/or hydraulic oil per month are used. What if a facility never
exceeds this threshold and is not required to do analytical monitoring. Are they then never required to do the
visual qualitative evaluation of stormwater discharges at outfalls, or is this always required at least quarterly or
semi-annually?
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
1