NCG190078_Tier Relief Request_20180316

Oriental, 13th of March 2018
Ms. Annette Lucas, PE
Stormwater Permitting Unit
NCDEQ/DEMLR
Mail Service Center 1617
Raleigh NC 27699-1617
RE: Petition to Reduce Frequency of Stormwater Discharge Analytical Monitoring
DEATON YACHT SERVICE, INC.
NPDES General Permit NCG190078
Dear Ms. Lucas:
We are submitting this request for a waiver from the Tier Two monthly analytical
monitoring at the subject facility.
Since 2008, this facility has been collecting semi-annual stormwater samples and
analyzing for metals. This facility has not been able to consistently reduce Copper below
the Benchmark Values (DMRs on file at NCDEQ/ DWR Central Files). While the metal
concentrations have been up and down over the past several years, and almost never
below the BMW, there are no additional feasible BMPs tht 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 ppm 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 than Copper level than
another. Its not reasonable to expect any permittee to treat stormwater to a level
cleaner than potable water with available and feasible technology.
• Research performed by Bentsen and Garber
(http s :ll forestemetwork. com/stonnwater-magazine/sw-water/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.
• This facility is located near other boatyards that have a legacy of Cooper usage in
the form of boat bottom paint. Bottom paint residue has been in the nearby and
on -side environment for many decades. Zinc has many sources including
galvanized metal buildings, r fs, fencing, anodes, and galvanized boat trailers.
• Another source for Coppe s from automotive brake pads
http://fortress.wa.gov/e /publications/documents/I I I0087.pdf). While this

facility is not bound by major roadways, Hwy 55/Oriental Road pass directly over
the side via Oriental Bridge.
We believe our funds would be better spent maintaining the implemented BMPs instead
of on expensive analytical monitoring costs. Monthly monitoring will not improve water
quality.
BMPs currently installed include placing ground tarps under boats undergoing hull repair
work.
Other implemented BMP's 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 with the semi-annual analytical and qualitative
monitoring through the end of the current Permit term.
if you need to discuss this petition, you may contact me at the Deaton Yacht Service
facility ( phone [phone] ). if we do not receive any response from NCDEQ/DEMLR
within 45 days from the date of this letter, we will assume our request has been approved.