NCG190098_Request to Relieve Monthly Monitoring_20180730

BRIDGETON BOATWORKS
Ms. Annette Lucas, PE
Stormwater Permitting Unit
NCDEQ/ DEMLR
Mail Service Center 1617
Raleigh NC 27699-1617
July 25, 2018
'I - n D
JUL n 0 2018
RE: Petition to Reduce Frequency of Stormwater Discharge Analytical Monitoring
Bridgeton Boatworks
NPDES General Permit NCG190098
Dear Ms. Lucas:
We are submitting this request for a waiver from the Tier Two monthly analytical
monitoring at the subject facility.
Since our permit was issued in 2017, this facility has been collecting semi-annual
stormwater samples and analyzing for metals. This facility has not been able to
consistently reduce Copper and Zinc below the Benchmark Values (DMRs on file at
NCDEQ/ DWR Central Files). While the metal concentrations have fluctuated, they are
above the BMV.
We have installed a metal absorption boom (from CleanwayUSA) across the outfall flow.
Zinc anodes are stored in a covered container inside the shop. At this time, we have no
additional feasible BMPs that can be implemented to consistently reduce Copper or Zinc
below the Benchmark Value.
103 N D St PHONE [phone]
New Bern, NC FAX [phone]
28560 EMAIL [e-mail]
�__� USA WEBSITE www.bridgetonboatworks.com

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 (potable water) can have a much higher than Copper level than
another discharge (stormwater). 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
(https:Hforesternetwork.com/stormwater-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 Copper usage
in the form of boat bottom paint. Bottom paint residue has been in the nearby and on-
site environment for many decades. Zinc has many sources including galvanized metal
buildings, roofs, fencing, and galvanized boat trailers.
• This facility is located on the site of a former truck garage which probably
contributed Copper and Zinc into the on-site soils.
• Another source for Copper is from automotive brake pads
(https://fortress.wa.gov/ecy/publications/documents/1110087.pdf). While this facility is
not bound by major roadways (US 17 HWY is about 200 yards east), significant delivery
truck traffic occurs at and near our facility. This facility is adjacent to the former US 17
Hwy right-of-way.
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 performing all bottom paint over ground tarps, and all
hull prep work (e.g., grinding, sanding) is collected and contained by vacuum. We
require the use of vacuum sanders when doing any hull work that creates dust.
103 N D St I PHONE [phone]
New Bern, NC FAX [phone]
/ 28560 EMAIL [e-mail]
USA WEBSITE www.bridgetonboatworks.com
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We have also installed a Cleanway USA metal absorption boom across the SDO-001
swale.
Other implemented BMPs include maintaining a vegetative buffer along the site
perimeter 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 and maintenance of BMPs through the end of the current Permit term.
If you need to discuss this petition, you may contact me at the Bridgeton Boatworks
facility (phone [phone]). We would like to receive a response from NCDEQ/
DEMLR within 30 days from the date of this letter so that we may plan our upcoming
Permit compliance activities.
Sincerely,
Bridgeton Boatworks
Ginny Webber
cc: Samir Dumpor, NCDENR/ DEMLR
Jim Frei, Stormwater Services Group LLC
File
103 N D St PHONE [phone]
New Bern, NC FAX [phone]
/ 28560 EMAIL [e-mail]
USA WEBSITE www.bridgetonboatworks.com
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