20160326 Ver 1_Deemed Permitted Status_20170329

Strickland, Bev
From: Scarbraugh, Anthony
Sent: Wednesday, March 29, 2017 12:47 PM
To: '[e-mail]'
Subject: Elite Management Group, LLC
Attachments: Deemed Permitted Status - Boat Washing Operations- 2014 02 07- Final.docx;
Technical Bulletin for NCG1900000.pdf
Mr. Goodman,
Per our discussion this morning, please find attached the checklist for deemed permitted status of boat washing facilities
with closed loop recycle systems. In addition, you will also find attached the Technical Bulletin for NCGS 1900000. If
you have any further questions, please feel free to contact me.
Regards,
Anthony Scarbraugh
Environmental Senior Specialist
Division of Water Resources — Water Quality Regional Operations
Department of Environmental Quality
252 948 3924 office
[e-mail]
943 Washington Square Mall
Washington, NC 27889
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

DWR State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources Division of Water Resources
CHECKLIST FOR DEEMED PERMITTED STATUS
BOAT WASHING FACILITIES WITH CLOSED-LOOP RECYCLE SYSTEM
General Applicability
Marinas with boat washing facilities are required to maintain a boat wash waste management system that complies with State
Administrative Code for the protection of the States water resources. There are a number of different strategies available for
managing boat wash wastewater. It is important that each boat wash facility considers each available option to determine which
provides the best alternative for their particular site. Facilities proposing to use closed loop recycle systems with no discharges to
surface waters may be eligible for deemed permitted status for their boat wash wastewater management system, and therefore not need
to maintain an individual permit with the Division. The following checklist is designed to assure that the boat wash facility has
considered available options and has proper documentation in place to demonstrate compliance with the deemed permit requirements.
For assistance with this checklist, or for a determination of deemed permitted status please contact the appropriate DWR Regional
Office:
bap://portal.ncdenr.org/web/wg/home/ro
Boat wash facilities using closed loop recycle systems are applicable for deemed permitted status provided that:
- No steam cleaning of exterior, bilge cleaning, or engine compartment cleaning occurs (see Design Criteria below)
- Wastewater can be managed or production can be stopped during power interruption (see Design Criteria below)
- The wash area is protected from stormwater inflow (structural controls or via management actions — see Design Criteria
below )
- The wash area is protected from 100 -year flood (see Floodway Regulation Compliance below)
Consideration of Alternative
Please indicate which of the following boat wash disposal alternatives have been considered. For your convenience, the applicable
administrative rule reference for each alternative and instructions on how to pursue the listed option is included.
❑ Connection to an area -wide wastewater collection system
1. Contact the Pre-treatment Unit of the closest Public Utility Authority for an evaluation and acceptance of the wastewater
generated from the boat washing activities.
❑ Closed-loop recycle systems (15A NCAC 02T .1000)
1. Facilities seeking deemed permitted status; should continue filling in this checklist.
2. Facilities not eligible for deemed permit status must apply for an individual permit and complete form CLRS 08-11)
(15A NCAC 02T.1000).
❑ Industrial wastewater pump and haul system (15A NCAC 02T.0202)
1. Submit a notification to the appropriate Division Regional Office in writing advising of the type of operation, type and
quantity of wastewater generated, location, and the receiving wastewater treatment facility. The facility should have
been designed and permitted to accept the type of wastewater being pumped and hauled.
2. Include a letter from the facility accepting the boat wash water specifically agreeing to accept wastewater from the
applicant. Include the terms of the acceptance.
❑ Onsite Treatment with subsurface discharge
1. Contact the On-site Wastewater Branch of the Division of Environmental Health
httD://www.deh.enr.state.nc.us/osww new/newl/.
CHECKLIST FOR DEEMED PERMITTED STATUS
FOR BOAT WASHING FACILITIES WITH
CLOSED-LOOP RECYCLE SYSTEM (FEBRUARY 2014)
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CHECKLIST FOR DEEMED PERMITTED STATUS
FOR BOAT WASHING FACILITIES WITH
CLOSED-LOOP RECYCLE SYSTEM (February 2014)
Deemed Permit Status Checklist
Marinas with boat washing facilities are eligible for permit by regulation coverage for a closed loop recycle system under 15A NCAC
02T .1003(3):
(3) Recycling of wash and rinse water at vehicle wash facilities provided the wastewater is contained within
concrete, steel or synthetic structures (i.e. not including earthen basins), all vehicle washing is conducted under
roof and there are no precipitation inputs (direct or indirect), and the facility develops and maintains a spill
control plan in the event of a wastewater release.
There are wastewater management systems and closed loop treatment systems available that have demonstrated the ability to control
storm water inputs without having the washing conducted under roof. Deemed permitted status has been granted to such facilities
once it has been demonstrated that the wastewater and storm water are kept separate.
To demonstrate compliance with the requirements to be eligible for deemed permitted status as described in 15A NCAC 02T .1003,
Facilities should be prepared to supply the Division Regional Office with the following:
❑ Property Ownership Documentation: per 15A NCAC 02T .1004(d), the facility owner can demonstrate they are the owner
of all property containing the wastewater treatment and recycle facilities by providing one of the following:
❑ Legal documentation of ownership (i.e., GIS, deed or article of incorporation),
❑ Written notarized intent to purchase agreement signed by both parties, accompanied by a plat or survey map;
❑ Written notarized lease agreement signed by both parties, specifically indicating the intended use of the property, as well
as a plat or survey map. Lease agreements shall adhere to the requirements of 15A NCAC 02L .0107
❑ Design Criteria: per 15A NCAC 02T .1005 Proposed Closed —loop recycle system meets all of the following criteria:
❑ The closed loop systems does not treat wastewater generated by steam cleaning of exterior, bilge cleaning, or engine
compartment cleaning.
❑ The closed-loop system contains the boat wash wastewater within concrete, steel or synthetic structures (i.e. not
including earthen basins),
❑ All boat washing is conducted under roof and there are no precipitation inputs (direct or indirect), or a portable
closed-loop collection and treatment system is used that has the ability to be removed and contained during rainfall
events or provides other means to ensure that storm water does not contribute to the wastewater flow.
For portable systems, and systems that are not under roof, the following must be provided.
❑ Site Map: The facility owner can supply a site map including at a minimum:
❑ A scaled map of the site showing all facility -related structures within the boat wash area including
the wastewater treatment, storage and recycle areas.
❑ Property boundaries
❑ Description of operation: Detailed description of how the system will be operated to ensure that storm
water and rainwater will not contribute to the wastewater flow.
❑ A detailed explanation of how generated residuals (including trash, sediment and grit) will be collected, handled,
processed, stored, treated, and disposed.
❑ The facility has the ability to stop production of effluent, return the effluent back to the treatment facility, store the
effluent, or discharge the effluent to another permitted wastewater treatment facility when recycling cannot be
conducted.
❑ A list with contact information for plant personnel, emergency responders and regulatory agencies must be
displayed on site.
❑ The facility must demonstrate that safety measures are in place, including: (1) contingencies in case of system
failure (2) restriction of access to the site and equipment; (3) spill prevention provisions such as response to upsets
and bypasses, including how to control, contain and remediate.
❑ There is no public access to the wastewater treatment equipment, wastewater storage structures or to the wastewater
within a closed-loop recycle facility.
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CHECKLIST FOR DEEMED PERMITTED STATUS
FOR BOAT WASHING FACILITIES WITH
CLOSED-LOOP RECYCLE SYSTEM (February 2014)
❑ An automatically activated standby power source, system shutdown, or other means shall be employed to prevent
improperly treated wastewater from entering a treated waste water storage structure or from being recycled where
loss of power would create an unsafe condition.
❑ Where potable water is used to supplement a closed-loop recycle water system, there is an air gap separation
between the potable water and closed-loop recycle water systems.
❑ A water tight seal on all treatment/storage units or a minimum of two feet protection from the 100 -year flood is
provided. Portable recycle facilities with the ability to be removed and contained during flood events are exempt
from this requirement provided that management practices include protection to the system during flood events.
❑ Floodway Regulation Compliance. Per 15A NCAC 02T .0105(c)(8), all facilities with any portion of the wastewater
treatment, storage and recycle system is located within the 100 -year floodplain must have written documentation from all
local governing entities that the facility is in compliance with all local ordinances regarding construction or operation of
wastewater treatment and/or recycle facilities within the floodplain.
Additional Considerations and Owner Responsibilities:
Please check each of the following boxes to indicate that you have read and acknowledge the following conditions applicable to
deemed permitted facilities (15A NCAC 02T .0113).
❑ Acknowledgement from DWR that the closed-loop recycle system is deemed permitted does not allow the violation of any
assigned surface water, groundwater, or air quality standards, and in addition any such violation shall be considered a
violation of the conditions of the deemed permit. Further, the deemed permitted closed loop system does not apply to or
permit disposal systems for which a state NPDES permit is otherwise required.
❑ Any discharge to surface waters from the deemed permitted boat wash system shall be reported to the DWR Regional Office.
❑ Closed loop recycle systems deemed permitted remain deemed permitted, notwithstanding any violations of surface water or
groundwater standards or violations until such time as the Director determines that they should not be deemed permitted.
❑ Coverage as a deemed permitted Closed Loop Recycle System does not exempt the facility from other applicable permits or
certifications (e.g. CAMA approval, Stormwater management, 401 certification, Sediment and Erosion Control)
❑ The Director may determine that the closed-loop recycle system should not be deemed to be permitted and require the
disposal system to obtain an individual permit or a certificate of coverage under a general permit. This determination shall be
made based on existing or projected environmental impacts, compliance with the provisions of Rule, and the compliance
history of the facility owner.
❑ The Division may require that the boat wash facility submit an Annual Report to the Regional Office. The report may
include: facility name, address, name of facility manager or person who signed application, rated treatment facility
classification, name of operator and backup operator (if applicable), copy of hauling records (wastewater or residuals)
indicating hauler name, date and quantity of transfer, receiving facility of liquids/residuals. Any reporting or monitoring
requirements will be established by the DWR in writing.
❑ In the event that the Water Pollution Control System Operators Certification Commission's (WPCSOCC) classifies the
closed-loop recycle facilities, the Permittee shall designate and employ a certified operator in responsible charge (ORC) and
one or more certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in accordance with
15A NCAC 08G.0200, and shall comply with all other conditions specified in the previously cited rules.
❑ Should a facility receive deemed permitted status, the subject facility must be able to demonstrate that the wastewater
treatment system is being properly operated and maintained. Records shall be maintained of boat washing activities,
wastewater treatment system maintenance, management and transfer of liquids and sludges generated during operation of the
wastewater treatment system including hauling records. Such records shall be made available during any subsequent on-site
facility inspection conducted by the Division of Water Resources to evaluate general wastewater treatment system
performance.
❑ Provide an explanation for any item listed as part of this checklist that cannot be provided or are not applicable for the site-
specific conditions of the boat wash facility and the justification as to why they are not applicable.
For more information, visit the Division of Water Resources website at: http://portal.ncdenr.or/web/wg/aps/lau
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North Carolina Department of Environment and Natural Resources
Technical Bulletin for N.C. General Stormwater
Permit N CG 190000
Technical Bulletin for NCG 190000 Revised 6/04/2015
What activities are covered by this general permit?
NCG190000 allows stormwater discharges associated with activities classified as establishments primarily en-
gaged in: Operating Marinas [standard industrial classification (SIC) 4493] that provide vehicle maintenance
activities, and Ship and Boat Building and Repairing [SIC 373]; and like activities deemed by the Division of
Energy, Mineral, and Land Resources (DEMLR) to be similar in the process and/or the exposure of raw materials,
products, by-products, or waste materials.
• This general permit does not authorize discharges at the facility containing waste streams including, but not lim-
ited to, bilge and ballast water, cooling water, sanitary wastes, power and hand washing, blasting, sanding, and
fish cleaning stations. A separate wastewater permit may be required for these and other similar wastewater dis-
charges.
What are the key permit requirements?
• Implement a Stormwater Pollution Prevention Plan (SPPP) (Part II, Section A).
• Provide secondary containment for all bulk storage of liquid materials (Part II, Section A, 2.(b)).
• Perform, document, and report analytical and qualitative monitoring during a measurable storm event twice
each year. At the same time perform and document visual monitoring twice each year (Part II, Section B & Q.
What has changed since the last renewal?
• Made it easier to sample during a measureable storm event (new term), rather than a representative storm event
(previous permit) (Part IV Definitions).
• Replaced Oil and Grease with a more specific Non -polar Oil & Grease test with a lower benchmark of 15 mg/L.
• Twice per year monitoring of pH is no longer required.
• Refinements and clarifications to the SPPP requirements (refer to Part II, Section A).
• The permit allows forgoing sampling if adverse weather conditions prevent collection (Part IV Definitions).
• Permittee is not required to obtain runoff samples outside of normal operating hours.
• A lower TSS benchmark of 50 mg/L for stormwater discharges into especially protected waters.
• New provisions for e -reporting (eDMR), once DEMLR capabilities for eDMR are established.
What are BMPs and why are they important?
A facility's Stormwater Pollution Prevention Plan should include Best Management Practices (BMPs) to control the
discharge of pollutants from all stormwater outfalls. BMPs include a variety of measures that help minimize the
potential for pollutants to enter stormwater that drains from a facility. There are different types of BMPs:
Non-structural (practices or activities) BMPs include:
• Eliminating exposure of materials and equipment whenever possible by moving them to indoor locations.
• Practicing good housekeeping on-site. Handle and store materials at the facility in an orderly fashion.
• Exchanging hazardous materials for non -hazardous ones wherever possible.
• Establishing routine leak and maintenance checks to minimize any chance of spills occurring. Clean up all spills
immediately.
• Establishing bulk storage tank protocols that minimize the risk of spills during loading and unloading.
• Maintaining wash pads and keeping them clear of paint chips, debris, and particles.
Structural (equipment or devices) BMPs include:
• Containment dikes around the loading areas of bulk liquid storage containers.
• Roofs and secondary containment around materials so that they are not exposed to stormwater.
• Collection systems around boat wash areas to direct wash water to a holding tank or sanitary sewer.
• Converting from a liquid operation to a dry operation for hull maintenance and cleaning.
• Collection of debris from paint chips in boat maintenance areas to minimize contamination of stormwater.
• Hull maintenance practices that are performed on dry land as far away from the water as possible.

PAGE TECHNICAL BULLETIN FOR N.C. GENERAL STORMWATER REVISED 6/04/2015 I
Frequently Asked Questions
Could I be exempt from a
NPDES stormwater permit?
Possibly. Facilities with industrial
activities subject to NPDES storm -
water regulations that eliminate
all potential stormwater exposure
may be eligible for a No Exposure
Exclusion from a permit. Facili-
ties that meet this condition may
apply by submitting a No Exposure
Certification application (see link
below). Facilities must re -certify
"No Exposure" status every five
years.
What if I sell my business, or
the name changes?
This is a minor modification that
requires approval of DEMLR's di-
rector before a permittee is ab-
solved of responsibility for the per-
mit. To request this change, com-
plete and submit a Name/
Ownership Change Form SWU-
239.
Do I have to monitor all the
outfalls?
Yes. However, you may request
Representative Outfall Status
(ROS). If approved, this status
allows analytical monitoring at
fewer outfalls. To make this re-
quest, submit a ROS Request
Form.
Does a certified lab need to
analyze my samples?
Monitoring under NPDES per-
mits must be conducted in accord-
ance with test procedures ap-
proved in federal regulations in
40 CFR §136. All labs certified by
North Carolina perform analysis
in accordance with those proce-
dures. While N.C. certification
requirements do not apply to test-
ing stormwater-only discharges,
data gathered under an NPDES
permit must still conform to fed-
eral requirements. Using a North
Carolina certified lab is one way
to ensure compliance. A list of
certified labs is available from:
http://portal.nedenr.org/web/wq/
lab/cert/cerlablists
Can my boat wash water be
discharged to or with my
stormwater?
No. Boat wash water, whether
from hand washing or power wash-
ing, is considered wastewater.
This stormwater permit does not
authorize wastewater discharges.
Wastewater is not allowed to mix,
or be "diluted", with stormwater
for discharge at a stormwater out-
let unless permitted by a separate
wastewater permit. Once storm -
water commingles with
wastewater, it is all considered
wastewater and must be handled
as such.
A separate wastewater permit
is required in order to dis-
charge wastewater. Some possi-
ble alternatives (which may re-
quire an additional separate per-
mit) for minimizing wastewater
discharge to surface waters in-
clude: discharge to a municipal
wastewater treatment plant, water
recycling, conversion of activities
to dry processes which allow for
easy clean-up and maintenance
and proper disposal of waste gen-
erated from industrial activities.
The NCG190000 permit is applica-
ble to a marina that offers vehicle
maintenance service, which in-
cludes boat cleaning. It is not ap-
plicable for an individual washing
their own boat at a marina. How-
ever, it is highly encouraged that
facilities educate and monitor the
use of appropriate BMPs by boat
owners when washing their boats
to minimize potential impacts to
surface water.
Who inspects my site, and for what?
DEMLR regional office staff may visit the site to see if you have the permit, an acceptable SPPP, and that you
are following your SPPP. These inspections may be routine or they may be the result of public complaints.
Please take compliance seriously! Facilities that violate stormwater permit conditions may be subject to fines.
Civil penalties of up to $25,000 per day may be assessed for each violation.
Other resources
In addition to the DEMLR Storm -
water Permitting Program's web-
site below, the DEACS (Division
of Environmental Assistance and
Customer Service) is a valuable
resource. The DEACS has specific
information about how to mini-
mize pollutants at various indus-
tries. Call [phone] or visit:
http://ncdenr.org/web/deao/
Who can help me with questions?
Your questions about stormwater permit requirements can be
addressed to the DEMLR Offices:
Asheville Office........
Fayetteville Office.....
Mooresville Office.....
Raleigh Office..........
df L
[phone]
Washington Office.....
[phone]
Wilmington Office.....
[phone]
Winston-Salem Office.
[phone]
Central Office...........
Helpful Links:
DEMLR Stormwater Permitting Program:
http://PortaLncdenr.org/web/lr/stonnwater
Orhttp://PortaLncdenr.org/web/lr/npdes-stormwater
[phone]
[phone]
[phone]
[phone]