NCG190106_Email_20180906

Morman, Alaina
From:Lambe, Brian
Sent:Thursday, September 6, 2018 11:31 AM
To:Morman, Alaina
Cc:Alexander, Laura
Subject:RE: NOI for USACE Engineering Repair Yard
Attachments:20180904.pdf
A major portion of this yard is a machine shop. Dredge equipment is kept outside. They were spray painting a boat
crane while inspecting. They built a temporary 20 x 20 x 20 enclosure to keep the sand blasting and overspray
contained (example of thoroughness).

Brian Lambe
Environmental Specialist
910-796-7313
State of North Carolina | Environmental Quality | Energy, Mineral and Land Resources
127 Cardinal Drive Extension | Wilmington, NC 28405
910 796 7215 T | 910 350 2004 F | http://portal.ncdenr.org/web/lr/

From: Morman, Alaina
Sent: Friday, August 24, 2018 4:49 PM
To: Lambe, Brian <[e-mail]>
Cc: Sams, Dan <[e-mail]>
Subject: RE: NOI for USACE Engineering Repair Yard

Thanks for taking the lead on this, Brian.

I’m curious to hear your report and whether or not you think they need to contain their wash water (I know, not our issue,
but I’m still interested because they should/do know better). Thanks for sharing your professional experience/opinion – I
think I would handle it the same way.

Have a good weekend.

-Alaina

Alaina Morman
Environmental Specialist
Stormwater Program
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality

919-707-9236 (O)

DEMLR Stormwater Program
512 N. Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699-1612

Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
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From: Lambe, Brian
Sent: Friday, August 24, 2018 11:50 AM
To: Morman, Alaina <[e-mail]>
Cc: Sams, Dan <[e-mail]>
Subject: RE: NOI for USACE Engineering Repair Yard

We missed the Laura Alexander email, probably from IBEAM data entry time period. I will arrange a site visit next week.

As far as the boat wash issue, (deep breath), I typically try to judge on quantity of boats. A larger yard (Jarrett Bay in
Morehead) necessitates a recycle system. They are a boat maintenance facility. A smaller yard, a typical storage rack
marina, does not usually power wash, just hose wash, I do not inform DWR or mention the rules. I know the rules do
not allow for it, but it is more of a case of how much attention to detail can we (or I) pursue.

This case differs in that the yard has even fewer boats, hand washed, but is a government entity that should make every
effort to be compliant. Belhart Marine recently permitted the adjacent site and do have a recycle system. I do not know
if it is deemed permitted or not by DWR. The ACE could contain the wash water, pump into a storage tank, dispose of
properly, no discharge of wastewater. Belhart does that on his other permit on the intracoastal waterway.

I will update you next week after the site visit.

Brian Lambe
Environmental Specialist
910-796-7313
State of North Carolina | Environmental Quality | Energy, Mineral and Land Resources
127 Cardinal Drive Extension | Wilmington, NC 28405
910 796 7215 T | 910 350 2004 F | http://portal.ncdenr.org/web/lr/

From: Morman, Alaina
Sent: Thursday, August 23, 2018 3:06 PM
To: Scott, Georgette <[e-mail]>
Cc: Lambe, Brian <[e-mail]>
Subject: RE: NOI for USACE Engineering Repair Yard

From the photos attached to the NOI, it looks like the wash water drains into the Cape Fear River via the boat ramp. And
no, I haven’t sent anything to Water Resources. I felt that should be initiated by the DWR regional staff.

Brian: have you dealt with any similar situations before? Do you have any concerns about this site?

Thanks,
Alaina

Alaina Morman
Environmental Specialist
Stormwater Program
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality

919-707-9236 (O)

DEMLR Stormwater Program
512 N. Salisbury Street
1612 Mail Service Center
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Raleigh, NC 27699-1612

Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties.

From: Scott, Georgette
Sent: Thursday, August 23, 2018 2:32 PM
To: Morman, Alaina <[e-mail]>
Subject: RE: NOI for USACE Engineering Repair Yard

Thanks Alaina,
I will let the inspectors here know that. Is the unpermitted discharge going into a water body or just discharged out
onto the ground? Did you also send this info to Water Resources?

Georgette Scott
State Stormwater Program Supervisor
Department of Environmental Quality
Office [phone]
Fax [phone]
[e-mail]

127 Cardinal Drive Ext.
Wilmington, NC 28405

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Morman, Alaina
Sent: Thursday, August 23, 2018 2:05 PM
To: Scott, Georgette <[e-mail]>
Subject: NOI for USACE Engineering Repair Yard

Hi Georgette,

I wasn’t sure if anyone from your team had looked at the NOI application for the Army Corps’ Engineering Repair Yard,
but there are some important things to highlight. In their NOI, the facility acknowledges that they have an untreated
wastewater discharge, but they do not have a wastewater permit. The wastewater discharge is water from washing their
boats. In the attached “discussion,” they breeze over the fact that this is a wastewater and try to justify it by saying they
use an “environmentally friendly cleaner.” Also, the facility doesn’t have a stormwater pollution prevention plan or a
solvent management plan. I will make it clear in the cover letter that boat washing activities are not covered under our
stormwater permit. Just wanted you all to be in the know.

The NOI application can be found here: https://edocs.deq.nc.gov/Stormwater/Browse.aspx?dbid=0&startid=702260

Thanks,
Alaina

Alaina Morman
Environmental Specialist
Stormwater Program
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Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality

919-707-9236 (O)
919-807-6494 (F)
[e-mail]

DEMLR Stormwater Program
512 N. Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699-1612

Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties.

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