NCG190097 Request For Relief Tier2

TRITON MARINE SERVICES, INC.
Ms. Annette Lucas, PE
Stormwater Permitting Unit
NCDEQ/DEMLR
Mail Service Center 1617
Raleigh, NC 27699-1617
March 13, 2018
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mAR 1 5 2018
D90 -WATER RE S
401 8 BUFFERP
RE: Petition to Reduce Frequency of Stormwater Discharge Analytical
Monitoring
Triton Marine Services, Inc.
NPDES General Permit NC6190000, COC #NCG190097
Dear Ms. Lucas:
We are submitting this request for a waiver from the Tier Two monthly analytical
monitoring at the subject facility.
Since 2015, this facility has been collecting semi-annual Stormwater samples and
analyzing for metals. This facility has not been able to concurrently and/or
consistently reduce Copper below the Benchmark Values (C)MRs on file at
NCDEQ/CWR Central Files). While the metal concentrations have been up and
down over the past several years, and almost never below the BMV, there are no
additional feasible BMPs that can be implemented to consistently reduce Copper
below the Benchmark Value.
There are several reasons why Copper measurements will probably never be below
the benchmark value at our boatyard:
The BMV of 0.005 plant 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 can have a much higher Copper level
than another. It is not reasonable to expect any permitee to treat
stormwater to a level cleaner than potable water with available and feasible
technology.
• Research performed by Bentsen and Garber [Bentsen, Stephen and Kelly
Garber (2017 Nov -Dec) Evaluating Urban Air Deposition on an Industrial
1050 Sensation Weigh . PO Box 486 . Beaufort . NC 28516
Tel: [phone] . Fax: [phone]

TRITON MARINE SERVICES, INC.
Facility in Seattle. Stormwater, Vol. 18, No. 8.1
htt s.//foresternetwork.com/stormwater-ma azine/sw-wager/sw-
stormwater-management/evaluating-urban-air-deposition-industrial-facility-
seattle/) has indicated that urban air deposition may account for a
significant load exceeding 0.005 ppm by a factor of 5 to 10 into stormwater
discharges.
• The Triton Marine facility is located in a Marine Industrial Park 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 environment
for many years. Zinc has many sources including galvanized metal buildings,
roofs, fencing, anodes, and galvanized boat trailers.
We believe our funds would be better spent maintaining the implemented BMPs
instead of on expensive analytical monitoring costs. Monthly monitoring will not
alter or improve water quality.
BMPs currently in place include placing ground mats (Chemtex Ground Guard or
comparable) or ground tarps under boats undergoing hull work. Vacuum systems
must be used with all sanders/power equipment. Plastic sheeting must shroud the
boat when any paint preparation, repair work or painting takes place.
Other implemented BMPs include maintaining a vegetative buffer along the on-site
ditches and bulkheads,
We are requesting a waiver from the monthly Tier Two monitoring effective
immediately. We will continue the semi-annual and qualitative monitoring through
the end of the current Permit term.
If you need to discuss this petition, you may contact me at the Triton Marine
facility (phone [phone], or via email at [e-mail]). If we
do not receive a response from NCDEQA)EMLR within 45 days from the date of
this letter, we will assume our request has been approved.
Sincerely
rV G4C ^
Angela McMahon
1050 Sensation Weigh • PO Box 486 • Beaufort . NC 28516
Tel: [phone] . Fax; 866 8715230