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HomeMy WebLinkAboutNCG190074_Response_20200110Resource Management RMAAssociates SENT VIA CERTIFIED, RETURN RECEIPT MAIL January 10, 2020 Morella Sanchez -King, Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office 127 Cardinal Drive Extension Wilmington NC 28405 Re: MarineMax - Wrightsville Beach New Hanover County, NC Dear Ms. King: 888-RMA-0230 info@rmagreen.com www.rmagreen.com In response to your Compliance Inspection — Notice of Deficiency dated December 11t", 2019 concerning the MarineMax facility located in Wrightsville Beach, New Hanover County NC, and on behalf of MarineMax, we offer the following comments regarding the Closed -Loop Recycle System ("system"): 1. After careful inspection, the prior system in use at this facility has been determined to be generally inoperable due to its general nature as well as the damage it incurred during Hurricane Dorian (the prior "capture tarp system" which would be located on ground surface to capture non- stormwater), and a replacement system is in progress. 2. The water treatment / recycling portion of the system (not the damaged "tarp") was taken off -site in December for repairs, and the vendor in question significantly damaged it during the repair process, rendering the need for extensive repair, or more likely, a complete replacement (the unit fell off of a transport trailer while being moved to the vendor's location). At this time, MarineMax is awaiting the replacement treatment system. 3. The entirely new system to be emplaced is not planned on as a "ground tarp" type capture system, but instead a permanent capture trench (with piping to the treatment unit) to be used during times of boat washing, which will be more permanent, should be more effective, more easily maintained, not capable of being damaged by "relocation" during future storm events such as Hurricane Dorian (it will be a permanent fixture system), and will continue to utilize the prior treatment unit in a closed -loop recycling manner. The system is under construction and has yet to be installed, but it is our intent to notify the Department prior to construction with further details (after construction plans are finalized) to confirm the Department's approval of said system along with anticipated continued conformance with the requirements for a Deemed Permitted Status Closed Loop Recycling System. We would anticipate that the replacement system will be finalized within approximately 60 days from date of this correspondence but will keep you advised of any advancements or delays in that schedule. 4. In the meantime, all other aspects of permit compliance are continuing. The facility has recently begun additional training, including stormwater sampling methods, and their SWPPP will be updated shortly when plans for the new recycling system are complete. Recent stormwater samples taken by the facility yielded good results, although one sample taken by their former consultant yielded poor results (all results were reported by DMR by this office as required. Environmental Compliance & Due Diligence Services I trust that this addresses the issues raised by your letter. Should you have any questions, please do not hesitate to contact me. Sincerely, -0 =/�- I'll Douglas E. Ruhlin Principal Environmental Consultant DER/dr PC: Cary Smart, MarineMax (via email) Matt Rienks, MarineMax (via email) Jay Wissman, MarineMax (via email) Sam Lowrey, MarineMax (via email) TJ Rose, MarineMax (via email) Brenda Shirer, MarineMax (via email) Manny Alvare, MarineMax (via email) Robb Mairs, NC Dept. Environmental Quality (via email to robb.mairs@ncdenr.gov) Brian Lambe, NC Dept. Environmental Quality (via email to brian.lambe@ncdenr.gov) Re: MarineMax Wrightsville Beach New Hanover County, NC Page 2 of 2