NCMA Comments on 2023 GP Renewal

- NCMA
NORTH CAROLINA MANUFACTURERS ALLIANCE
17 May 2023
Via Email [[e-mail]]
Brittany Cook
Stormwater Program
NCDEQ-DEMLR
1612 Mail Service Center
Raleigh, NC 27699-1612
RE: North Carolina Manufacturers Alliance (NCMA) comments to draft Stormwater Industrial General
Permits
Dear Ms. Cook:
The North Carolina Manufacturers Alliance (NCMA) appreciates the opportunity to provide comments on
the draft Stormwater Industrial General Permits that are to be revised and re-issued. NCMA members,
along with our business partners, represent hundreds of manufacturers in North Carolina and we
therefore offer comments on the five draft permits:
• NCGO50000 permit for Apparel, Printing, Leather, Rubber(EPA SECTORS V,X,Y&Z)
• NCG070000 permit for Stone, Clay,Glass (EPA SECTOR E)
• NCG110000 permit for Treatment Works (EPA SECTOR T)
• NCG130000 permit for Nonmetal Waste and Scrap (EPA SECTOR N)
• NCG210000 permit for Timber Products (EPA SECTOR A)
Comment 1—Required Baseline Sampling: Quarterly sampling is not justified
The sampling frequency in these general permits has covered a wide spectrum over the years, in some
cases going from semi-annual to quarterly and then back to semi-annual. Now, DEQ proposes another
universal change to quarterly sampling frequency. There are several problems with this proposed
increase in sampling frequency:
• Quarterly sampling frequency will not improve water quality—The current semi-annual sampling
frequency provides adequate protection for the environment and provides for corrective actions
should there be concerns.
THE VOICE OF NORTH CAROLINA MANUFACTURERS
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• Quarterly sampling is burdensome for the regulated community.The level of effort and
associated costs to double the amount of annual sampling events significantly impacts
manufacturers. These facilities often have more than one outfall. Attempts to collect samples
are often difficult. Additional sampling also requires increased laboratory and shipping costs.
• Increased sampling frequency is burdensome for DEQ. DEQ staffing challenges have been well
publicized. The increase in DMR submissions will further exasperate the situation and challenge
the allocation of additional DEQ staff time for records review.
• The proposed monitoring requirements are not consistent with other states and EPA guidance.
• Implementing these monitoring requirements on permittees that have never conducted
analytical monitoring,with an expectation that monitoring becomes required immediately,
would be very impractical.
• Based on schedule projections,these sampling frequency requirements could become effective
during the driest part of the year.
• Issuance of these permits,as written, could set up some permittees for non-compliance simply
because they would not have sufficient time to develop and implement the proper procedures
and processes to ensure compliance.
Comment 2—Required Baseline Sampling: Sampling for O&G not justified
The required baseline parameter monitoring requirements proposed in the draft permits appear to
reflect EP's Multi-Sector General Permit(MSGP). However,for the EPA Sectors represented by these five
draft permits,the MSPG does not include a baseline parameter monitoring requirement for oil and
grease.
Further, in many current permits,oil and grease monitoring is associated with vehicle maintenance
activities;therefore,sampling for this parameter should not be broadly applied to all industrial general
permits nor to every outfall associated with an industrial facility.
Comment 3—Baseline Sampling Benchmarks: Benchmark values should not be universally applied
The MSGP does not propose benchmark monitoring thresholds for Sectors E, N,T,V,X,Y, &2,therefore
benchmark thresholds are not justified in draft permits NCG050000, NCG070000, NCGI10000,and
NCG130000.
Comment 4—BMP Inspections: For NCG210000,7-day inspection of BMPs is not correct
This 7-day inspection appears to be a carryover from the construction general permit and should be
corrected to reflect other manufacturing general permits. In the MSGP,this requirement is only
associated with performing earth moving activities and it is not mentioned in the DEQ fact sheet.

Given these comments, it would be inappropriate for these draft permits to become effective on June 1.
NCMA requests that DEQ delay publishing the final permits until such time that DEQ has a reasonable
opportunity to confer with North Carolina manufacturers and other commentors.
We appreciate the opportunity to provide these comments and look forward to working with you on
their resolution.
Sincerely,
Ross M. Smith
President
North Carolina Manufacturers Alliance(NCMA)
Mobile:252.916,3061
ross.smithOmvncma oro
NCMA