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Stormwater Permit (NCG19xxxxx) Process Requires Attention Now

For All Marinas, Boatyards and Boat Builders

If your company is a marina (anywhere in the state – not just on the coast) and provides any type of repair service on the landside of the facility; a boatyard; or a boat builder or boat restoration facility of any kind, you will need to re-permit if you have a NCG19 Stormwater permit now, or apply for one if you do not.

Excluded are in-water only marinas with fuel sales, basic retail, but no upland repair or cleaning. Boat builders can get a waiver if you meet certain “all under a roof” criteria, but you have to apply. And, to avoid confusion, it now appears that every company using a powerwash system will have to be permitted.

According to the NCDENR | DWQ | Stormwater Permitting division, the Stormwater Permit for Marinas & Boat Builders is set to expire August 31, 2009. Existing permitees were notified in their renewal packages and DWQ provided public notice of the draft renewal in papers and online.  The draft permit and fact sheet can be found at the following link:  http://h2o.enr.state.nc.us/su/publicnotice.htm located under the May 15, 2009 date label along with the other pending renewals.

There are two components to review: The 27 page permit draft that will lose its draft status soon and become law [found also on our NCwaterways site here: GENERAL PERMIT NO. NCG190000 and a 13 page Fact Sheet needed to better understand the requirements of the permit also found here: FACT SHEET for NCG19 [again, Angie, we will need the URL for his document]

It is highly probable that a consultant will be needed in order to fill out all required components of this permit. It includes sections that require site testing to incorporate monitoring parameters such as pH, Oil and Grease (O&G) and Total Suspended Solids (TSS). It also includes recording New Motor Oil Usage. DWQ is proposing to introduce additional analytical monitoring for certain metals (Copper*, Aluminum*, Iron*, Lead*, and Zinc*) in this general permit (*total recoverable).

In addition, DWQ is proposing a new response obligation based on qualitative monitoring results for this entire general permit. If there are indications of failure to maintain an adequate Stormwater Pollution Prevention Plan (SPPP) and/or water quality standard violations, a facility can be directed to seek coverage under an individual permit that could include additional analytical monitoring. This revision should help address facilities where regional inspections have observed problems (for example, sites that have boat washing facilities (wastewater) that drain directly to stormwater outfalls).

Components include a (1) a Site Plan with five criteria; (2) a Stormwater Management Plan with record keeping and a Best Management Practices Summary; (3) a Spill Prevention and Response Plan (SPRP);  (4) a Solvent Management Plan (new);  (5) a Preventative Maintenance and Good Housekeeping Program; (6) an Employee Training program; (7) a Responsible Party component where position(s) responsible for the overall coordination, development, implementation, and revision to the Plan are identified; (8) a Plan Amendment component to identify whenever there is a change in design, construction, operation, or maintenance which has a significant effect on the potential for the discharge of pollutants to surface waters; (9) provisions for Facility Inspections at a minimum on a semi-annual schedule, once during the first half of the year (January to June), and once during the second half of the year (July to December), with at least 60 days separating inspection dates; (10) Plan Implementation component where documentation of all monitoring, measurements, inspections, maintenance activities, and training provided to employees is kept on-site for a period of five years.