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HomeMy WebLinkAboutNCG190028_COMPLETE FILE - HISTORICAL_20110304STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. Iv U&) � v o a DOC TYPE "ISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ l� ID_3 oq YYYYM M D D AC "� -� _ I p').ttl NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor Duck Creek Small Boat Harbor Attn.: Mr. Frank Benton PO Box 248 Bridgeton, NC 28519 Dear Mr. Benton: Division of Water Quality Coleen H. Sullins Director March 4, 2011 Subject: Duck Creek Small Boat Harbor Permit No. NCG190028 Craven County Dee Freeman Secretary On January 29, 2011 the Washington Regional Office of the Division of Water Quality (DWQ) received a written response from your consultant, SwSG Stormwater Services Group, LLC regarding the stormwater inspection conducted on December 9, 2010 for the subject project. Your Facility is implementing several good best management practices to address the solid waste issue, however as a general reminder and useful information, we would like to emphasize that the industrial activities such as hull maintenance and hull cleaning generate solid and liquid industrial wastes that contain metals. There are high concentrations of metals, particularly copper and lead, that are present in the anti -fouling paints used on boat hulls. It is important to keep this in mind when you are pressure washing, sanding and scraping the boat hulls at your facility so close to surface waters. The mixing of stormwater with industrial waste material does result in a wastewater. You should make a conscientious effort to reduce the exposure of the wastes to stormwater by segregating the two. By segregating wastes from stormwater, you are minimizing the volume of wastewater draining off your site. Remember, the NPDES NCG 190000 only authorizes stormwater-only discharges to surface waters. Please note that boat wash water is a wastewater regardless of whether it discharges to the ground or directly to surface waters. In either case the wastewater must be properly treated and properly disposed. You may need to contact a certified waste hauler to dispose of your wastes. If the wastewater is infiltrated into the ground, a permit may be required from the Aquifer Protection Section within the Division of Water Quality. Groundwater contamination could be occurring by allowing washwater, known to be highly concentrated with metals, to infiltrate into the ground. In an effort to minimize exposure of industrial waste to stormwater runoff, some of the BMP actions you suggested are satisfactory to DWQ. Please note that BMP No. 11-5, to discharge wash water into either new French drain or existing on -site evaporation basin may need permitting from the Aquifer Protection Section within the Division of Water Quality. DWQ recommends considering other methods in the future, such as the collection and containment of wash water. Collection and containment methods work towards eliminating rather than minimizing the discharge of wastewater to surface waters. One of our goals in revamping our NCG190000 NPDES inspections on the coast, is to provide education and outreach to marina owners and operators on compliance of the NPDES program. Due to the close proximity of your industrial activities to surface waters, the potential to impact those waters with harmful pollutants increases. Therefore, North Carolina Division of Water Quality Internet www.ncwateroualitv.oro 943 Washington Square Mall Phone: 252-946-6481 Washington, NC 27889 FAX 252-946-9215 An Equal Opportunity/Affirmative Action Employer - 50% Recycled110% Post Consumer Paper No rthCarolina Naturally we are making you aware of some of the things you can do to minimize the impact your industrial activities have on the environment. We are hopeful that we have provided you with a better understanding of the types of discharges we found during our inspection. We did not conduct a thorough check of your marina's SPPP plan during the inspection. Since Washington Regional Office does not have a copy of this plan, some information in the previous inspection report may be inconsistent with the SPPP plan. It would help to have a copy of this plan in our Office to avoid future misinterpretations. Please forward a current copy of the SPPP to this Office. We do not disagree with your statement that USEPA's drinking water standard for copper is 1.3 mg/L. USEPA's water quality standard for SA, SC, and SB waters is 3 ug/L (or .003 mg/L). Your facility is located in SB waters. You cannot compare drinking water standards to surface water standards. Drinking water is tested for the safety of human consumption. Surface water is tested primarily for the safety of benthic organisms since that is their natural habitat. Benthic organisms absorb metals into their tissues from the water column and from contaminated sediments. These organisms are unable to metabolize the metals in their tissues as humans can. Therefore, continuous exposure of high metal concentrations in their natural environment leads to unhealthy concentrations of metals in their tissues. Shellfish are examples of benthic organisms. Please keep in mind that by not minimizing your exposure of waste to stormwater, you are contributing pollution to surface waters that are adjacent to your facility. If you have any questions please contact Samir Dumpor at the Washington Regional Office, telephone number (252) 946-6481. Sincerely, AI Hodge Regional Supervisor Washington Regional Office AH/sd: K:/NPDES Stormwater/Marinas/NCG 190028 James Frei. SwSG Stormwater Services Group, LLC cc: Katie Merritt— WBS Compliance & Permits Unit David May/APS WaRO Files SWSG Stormwater Services Group, LLC 8916 Oregon Inlet Ct. Raleigh, North Carolina 27603 Phone: 919.661.9954 Fax: 919:661.8108 January 29 2011 HE C. 1 2F11 Mr. Samir Dumpor NC Division of Water Quality (WRO) 943 Washington Square Mall Washington NC 27889 RE: Duck Creek Small Boat Harbor NPDES General Permit NCG190028 Notice of Inspection Dear Mr. Dumpor: In response to your letter dated December 14 2010, we offer the following response: This Permittee is committed to reducing hull cleaning and repair residuals to the maximum extent practical by implementing best management practices. For example, all hull sanding operations are supposed to occur over a tarp and/ or use a vacuum sander to collect particulates and dust. The Permittee has instructed all employees, boat owners, and sub -contractors (hired directly by boat owners) to implement these practices to control dust and residue. The Permittee has considered the installation of a closed -loop wash system, but has deemed it to be too expensive. For example, the Clean Marine Solutions machine costs about $15,000 plus operating expenses. This cost does not include the cost of constructing a concrete wash containment pad. The Permittee will study three options for the control of boat washwater: 1. Discharge the washwater to a french drain / infiltration system 2. Discharge the washwater to an existing on -site evaporation basin. 3. Discharge the washwater to the local municipal sanitary sewer system The SWPPP will be amended to indicate the selected option. In the meantime, the Permittee will place geotextile filter fabric over the existing concrete pad and catch basin in the designated wash area. Boats will be power washed over this fabric, which will capture most of the particles that may be knocked off the hull during this operation. After drying, the fabric will be swept with the residue bagged and placed into a dumpster for disposal in a lined landfill. r- Letter to NCDENR/ DWQ January 29, 2011 Page 2 SwSG On page 3, you have indicated a "No" for several items. We will address each of these negative findings: Does the Plan include a list ofsignificant spills occurring during the past 3 years? Section 1.4.5 of the SWPPP states that there were no significant spills in the 3 years prior 1 c�ci to the effective date (12/30/09) of the SWPPP. Each semi-annual inspection report since December 2009 states "there have been no significant spills since the previous report". L� i This information was available to your field inspectors. i ; oold i e A list and a report will be created if and when a significant spill occurs.�� Has the facility evaluated feasible alternatives to current practices? All of the BMPs indicated in the SWPPP and subsequent semi-annual inspection reports were deemed feasible. While a full-blown cost/ benefit analysis was not performed — this in itself is not feasible — common sense and experience dictated the BMPs written into the SWPPP and implemented to date. Tables 4 and 5, and Appendix C in the SWPPP describe the BMPS deemed feasible. This information was available to your field inspectors. Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Checked NA. Vehicle Maintenance occurs within the SDO-001 drainage area. This facility collected stormwater samples at SDO-001 in March and September 2010. The DMRs were submitted to Central Files prior to your inspection. Copies of DMRs and the lab analysis reports are inserted into the SWPPP at Appendix F. All required DMRs to date were provided to your field inspectors for review. !VG 2 Your letter states that Copper and Lead exceeded the benchmark values. Lead has not exceeded He I' the BMVs as the analysis indicated Lead at 0.009 mg/L in March 2010 and 0.010 mg/L in r; ,wf September 2010; the BMV for Lead is 0.030 mg/L. Copper did exceed the BMV in both 2010 samples. The BMV for Copper is 0.007 mg/L which is an extremely low value to achieve. Considering that the USEPA's drinking water MCLG for Copper is 1.3 mg/L (ref. htty://water.el)a.aov/drink/contaminants/index.cfm#List), is it reasonable for NCDENR to expect any Permittee to meet a value in stormwater that is 185 times less than an acceptable level in drinking water? There may be background sources of Copper for which the Permittee has no control. For example, Copper in the potable water used for boat rinsing may exceed the BMV. Copper concentration is also dependant on water hardness; the Permit does not require an analysis for water hardness. We would also like to point out that our NC -certified laboratory, TriTest, can only report Copper aslow as 0.010 mg/L. This RL is greater than the BMV. Letter to NCDENR/ DWQ January 29, 2011 Page 3 SWSG On page 4 of your report, you give a negative finding for the statement "ff the facility has representative outfall status, is it properly documented by the Division?" The Permittee submitted a petition letter to the Director in April 2007 in accordance with the directions stated in the General Permit effective in 2007. This petition requested ROS for only SDO-001. Since the Permittee never received denial of this request, it was assumed that ROS was granted to SDO-001. f_(o rt�_C�. 4!5 On page 4 of your report, you give a negative finding for the statement "Ha.ts the facility evaluated all illicit (non stormnater) discharges?" lllk } _wayewai�r We are not sure of the meaning of "evaluated". Does this term mean to analyze non- stormwater discharges, or to determine the existence of non-stormwater discharges? During the development of the current SWPPP and the previous SWPPP, the site was inspected and one non-stormwater discharge was present. We also look for illicit discharges during the semi-annual site inspections; only one has been found. The only non-stormwater discharge present at this facility is the discharge of boat washwater from a small pipe upstream of the SDO-001 monitoring point. This non-stormwater discharge has been noted in the SWPPP at Section 1.4.6 and in every semi-annual inspection report conducted in compliance with General Permit NCG 190000. If there are non-stormwater discharges, General Permit NCG190000 does not require that samples be analyzed. On page 4 of your letter, you state "II is required that the permittee follow the tiered sampling guidance.... " Tiered actions are not required until the third year of Permit coverage. The third O year commences October 1 2011. With the second sample of the third year not due until September 2012, tiered sampling may not start until October 2012. This Permittee is following the sampling schedule indicated in the Permit. In the meantime, this Permittee is trying to determine the source(s) of pollutants in its stormwater discharges and will implement appropriate BMPs. Letter to NCDENR/ DWQ January 29, 2011 Page 4 SWSG In regards to your 60-day request for a schedule of steps to achieve compliance, we offer the following only as BMPs that will help reduce any pollution that may be found in the stormwater runoff from this marina: BMP No. Action Target Date 11-1 A filter fabric will be laid on top of the concrete pad and catch basin at 02/25/11 the designated boat wash area. After washing and once the fabric is dry, the residue will be swept off the tarp, bagged, and disposed in a lined landfill. 11-2 Ensure that tarps or filter fabrics are placed under all boats during hull 03/15/11 sanding and hull repair operations. 11-3 Ensure that ground tarps and side curtains are in place when painting 03/15/11 boats outside. 11-4 Enforce policy that all workers will use a vacuum sanding system for 04/15/11 all hull repair/ restoration. Permittee will rent vacuum sanders. No outside sanders will be allowed. 11-5 Discharge boat washwater into either new french drain or existing on- 06/30/12 site eva oration basin. 11-6 Research alternate methods for washwater disposal or recycling if 11/30/12 infiltration is disallowed. 11-7 Connect wash pad sump to NCDWQ-approved method for washwater 06/25/13 disposal We hope this letter and our planned actions satisfy your concerns with the operations at this marina. Please do not hesitate to call Frank Benton at 252-637-2045 or the signatory below if you have any questions. Sincerely, 7 S WATER SERVICES GROUP, LLC mes D. Frei Senior Project Manager CC. Frank Benton, Duck Creek File RMA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary December 14, 2010 Duck Creek.Small Boat Harbor Attn.: Mr./Frank Benton PO 6q 248 Brideeton, NC 28519 Subject: NOTICE OF INSPECTION Duck Creek Small Boat Harbor Permit No. NCG190028 Craven County Dear Mr. Benton: On December 9, 2010 Samir Dumpor of the Washington Regional Office of the Division of Water Quality (DWQ) inspected Duck Creek Small Boat Harbor in Craven County to determine compliance with Federal NPDES general Stormwater Management Permit Number NCG190028 issued on October 01, 2009. DWQ file review and site inspection revealed that the site is not compliant with the terms and conditions of this permit. Please find a copy of the completed form entitled "Compliance Inspection Report" attached to this letter. It is important to mention that since last inspection (performed on December 14, 2006), this marina has implemented some positive steps in order to be compliant with the Federal NPDES general Stormwater Management Permit Number NCG190028, like developing Stormwater Pollution Prevention Plan, use of vacuum sanders and tarps to collect waste materials. The main issue with this Marina still remains the wastewater (from washing) discharge and waste material generated by boat maintenance. The NPDES general Stormwater Permit for Marinas and the General Statute of North Carolina 143-215.1 prohibits wastewater discharges into the waters of the State. Please halt the unpermitted discharge of waste water and amend your Stormwater Pollution Prevention Plan to include the permanent measures for wastewater collection and disposal method. The collection of waste material generated by boat maintenance shall be addressed also. Currently marina requires the individual boat owners to use tarps and vacuum sanders, however care and measures should be taken to implement these practices at all times. Please be advised that you are required to comply with the terms, conditions and limitations of your Federal NPDES general Stormwater Management Permit under North Carolina General Statute 143-214.7 and 143-215.1, including operation and maintenance of your permitted stormwater system. Please respond in writing within 60 days of receipt of this letter with a schedule to come into compliance, including those specific steps planned and a time table of when they shall occur. If the project has changed name, ownership or mailing address, a formal change of name/ownership form must be submitted to DWQ within 30 calendar days detailing the change. Please provide the name, mailing address and phone number of the person or entity that is now responsible for this permit. North Carolina Division of Water Quality Internet: www.ncwaterquality.orq 943 Washington Square Mall Phone: 252-946-6481 Washington, NC 27889 FAX 252-946-9215 An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper NorthCarolina Naturally Please be advised that violations of your Stormwater Management Permit may be subject to the assessment of civil penalties of up to $25,000 per day per violation. If you have any questions please contact the Samir Dumper at the Washington Regional Office, telephone number (252) 946-6481. Sincerely, Samir Dumpor Environmental Engineer Washington Regional Office Enclosure: Compliance Inspection Report cc: John Hennessy-NPS-ACOU ✓WaRO Files DWQ Central Files Q�� r NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor Mr. Tom McCary, Manager Wayfarers Cove Marina 1107 Bennett Road Arapahoe, NC 28510 Dear Mr. McCary: Division of Water Quality Coleen H. Sullins Director December 14, 2010 Dee Freeman Secretary Subject: Wayfarers Cove Marina (Minnessott Beach Yacht) Permit No. NCG190027 Pamlico County On January 28, 2011 the Washington Regional Office of the Division of Water Quality (DWQ) received a written response from your consultant, SwSG Stormwater Services Group, LLC regarding the stormwater inspection conduction on December 2, 2010 for the subject project. Solid wastes created during any industrial activities such as power washing, sanding, scraping, etc. which are allowed to remain on or in the ground should not be allowed to mix with rain water and either infiltrate or wash off through stormwater runoff. The natural mixing of stormwater with industrial waste material does result in a wastewater. Please note that boat wash water is a wastewater regardless of whether it discharges to the ground or directly to surface waters. In either case the wastewater must be properly treated and the disposal of the wastewater is required to be permitted under GS 143-215.1. If the wastewater is infiltrated into the ground, a permit would be required from the Aquifer Protection Section within the Division of Water Quality. In order to avoid unnecessarily spending resources on geotextile filter fabric that would still allow the discharges of wastewater, thereby not meeting minimum wastewater requirements, please consider other collection and treatment alternatives which would keep wastewater out of both surface and ground waters. These marina inspections were more of an educational nature for both DWQ inspectors and marina owners and a thorough check of your marina's SPPP plan was not conducted during the inspection. Since Washington Regional Office does not have a copy of this plan, some information in the previous inspection report may be inconsistent with the SPPP plan. It would help to have a copy of this plan in our Office to avoid future misinterpretations. Most of our time was spent during the inspections explaining the difference between stormwater and wastewater and possible options to eliminate wastewater discharges. If you have any questions please contact Scott Vinson at the Washington Regional Office, telephone number (252) 946-6481. Sincerely, Scott Vinson Environmental Engineer North Carolina Division of Water Quality Internet: www.ncwatergualitv.org 943 Washington Square Mall Phone: 252-946-6481 Washington, NC 27889 FAX 252-946-9215 An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper NorthCarolina ;Vatura!!y A�� OUR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary Deeember 2444february 23 2011 Mr. Tom McCary, Manager Wayfarers Cove Marina 1107 Bennett Road Arapahoe, NC 28510 Subject: Wayfarers Cove Marina (Minnessott Beach Yacht) Permit No. NCG190027 Pamlico County Dcar Mr. McCary: On January 28, 2011 the Washington Regional Office of the Division of Water Quality (DWQ) received a written response from your consultant, SwSG Stormwaler Services Group, LLC regarding the stormwater inspection eeadaetia conducted on December 2, 2010 for the subject project. Solid --wastesIndustrial activities -such as hull maintenance and hull cleaning a •rned during say ralusiml nelivilies-s !,generate solid and liquid industrial wastes that contain metals. There are high concentrations of metals particularly Copper and Lead, that are present in the anti -fouling paints used on boat hulls. Vehicle wash water typically seen at car washes wouldn't contain the same concentrations of metals as the wash water venerated from pressure washing boat hulls. It is inmormnt to keep this in mind when you are pressure washing, sanding and scraping the boat hulls at your facility so close to surface waters. Your SP3 plan should address- - Ways to reduce the exposure of these solid and liquid wastes to stormwater runoff. Wh elt Ore allowed to lease The mamer4-mmixing of stormwater with industrial waste material does result in a wastewater. You should make a conscientious effort to reduce the exposure of the wastes to stormwater by segregating the two: By segregating wastes from stormwater, you are minimizing the volume of wastewater draining off your site and therefore increasing the volume of stormwater. Remember. the NPDHS NCG 190000 oniv allows stormwater to discharge to surface waters. Your SP3 Ian addresses BMPs to treat stormwater, not wastewater Please note that boat wash water is a wastewater regardless of whether it discharges to the ground or directly to surface waters. In either case the wastewater must be properly treated and -and property disposed. You may need to contact a certified waste hauler to dispose of your wastes. !he disposal arthe %raSile%ulff L' HqUiFed to be Venal code Gs i43 2is.l. if the wastewater is infiltrated into the ground, a permit would may be required from the Aquifer Protection Section within the Division of Water Quality. Groundwater contamination could be occurring by allowing washwater known to be highly concentrated with metals to infiltrate into the ground. In an effort to minimize exposure of industrial waste to smrmw ter runoff- some of the 13MP actions you suggested are satisfactory to DWO. BMP No. 11-5 may not be an option due to the chemical nature of the was'hwmer. In Eff(Iff it) avoid unnecessarily Spend Rg resources on gemex! le filter fahn, that , ould still 110 wastewater-thereby--not-meeting-minimam-wnstewntet-requirrmefu DWO recommends-pleuse-considcring more permanent methods in the future such as collection and containment of wash water: Collection and containment methods work towards eliminating rather than minimizing the discharge of wastewater to surface waters. o.,,.-r-�-e,ra kemmem-al'a,:;: al;;:.�`,-wmrldkeep-wastewmer-em . Nora, Carolina Division of Water Duality Inlemet w agasateroualitv.oro 943 Washington Square Mall Phone: 252-94 81 one Washington, NC 27889 FAX 252-9w-9215 Nortt1hiCaro/f/ina An Equal DppnWhtylMimaOve Assn Empbyer- 50% Recyc"10% Pon Coewmer Payer �%1/µ{�{ rally Ptese-One of our goals in revamping our NCG190000 NPDES inspections on the coast is to provide education and outreach to marina owners and operators on compliance of the NPDES program Due to the close proximity of your industrial activities to surface waters, the potential to impact those waters with harmful pollutants increases. Therefore, we are making you aware of some of the things you can do to minimize the impact your industrial activities have on the environment. We are hopeful that we have provided you with a better understanding of the types of discharges we found UlIpK our InspeCllW. :::.:. :.: .....p......... .. ................: a.-. BWfleFs HHd-B We did not conduct a thorough check of your marina's SPIT plan ....._ -..a, t --during the inspection. Since Washington Regional Office does not have a copy of this plan, some infomunion in the previous inspection report may be inconsistent with the SPPP plan. It would help to have a copy of this plan in our Office to avoid future misinterpretations. MOSt Of Our time was spent during the inspeiniens & filaming !he diff�Fenee between Shuff)"uteF Had WEISteWHIe Formatted: nlahllaht 13enlhic organisms absorb metals in their tissues that are absorbed from the water column and in contaminated sediments These organisms are unable to metabolize the metals in their tissues as humans can Therefore, continuous exposure of high metal concentrations in their natural environment leads to unhealthy concentrations of metals in their tissues Shellfish are examples of benthic organisms. Please keep in mind that by not minimizing your exposure of waste to stormwater, you are contributing pollution to surface waters that are adjacent to your facility, If you have any questions please contact Scott Vinson at the Washington Regional Office, telephone number (252)946-6481. Scott Vinson Environmental Engineer Washington Regional Office xxx NITS A 2 JU atic Merritt - W 13S Comrdiance & Permits Unit Formatted: Font: 11 pt WaRO piles DWQ Central Files Compliance Inspection Report Permit: NCG190028 Effective: 10/01/09 Expiration: 09/30/14 Owner: Duck Creek Small Boat Harbor SOC: Effective: Expiration: Facility: Duck Creek Small Boat Harbor County: Craven 699 Galloway Rd Region: Washington Bridgeton NC 28519 Contact Person: Raymond Benton Title: Phone: 252-638-1702 Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s) On -site representative Frank Benton Phone: Related Permits: Inspection Date: 1210912010 Entry Time: 09:30 AM Exit Time: 11:00 AM Primary Inspector: Samir Dumpor Phone: 252-948-3960 Secondary Inspector(s): Reason for Inspection: Complaint Inspection Type: Compliance Evaluation Permit Inspection Type: Ship and Boat Building Stormwater Discharge COC Facility Status: ❑ Compliant ■ Not Compliant Question Areas: 0 Storm Water (See attachment summary) Page: 1 ra W, Permit: NCG190028 Owner - Facility: Duck Creek Small Boat Harbor Inspection Date: 12/09/2010 Inspection Type: Compliance Evaluation Reason for Visit: Complaint Inspection Summary: The marina is currently implementing some good measures to address the stormwater and wastewater runoff, like use of vacuum sanders and tarps, however since the boat maintenance is performed by boat owners, these practices are not mandatory and nor easily implemented. Currently wastewater and some waste materials are discharging freely from site comingled with stormwater runoff and without almost any treatment. Some filter screens are used to filter wash water, but it is still not allowable to discharge the wastewater without a permit into waters of the the state. According to permit, our recommendation was to plan for wastewater collection system of permanent nature rather than just tarps and to dispose of wastewater and waste materials properly (not in waters of the state). The SPPP plan should be revised to include these measures. Page: 2 Permit: NCG190028 Owner - Facility: Duck Creek Small Boat Harbor Inspection Data: 12/09/2010 Inspection Type: Compliance Evaluation Reason for Visit: Complaint Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ■ 0 0 0 # Does the Plan include a General Location (USGS) map? ■ 0 0 0 # Does the Plan include a "Narrative Description of Practices"? ■ 0 0 0 # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ 0 0 0 # Does the Plan include a list of significant spills occurring during the past 3 years? 0 ■ # Has the facility evaluated feasible alternatives to current practices? ❑ ■ ❑ 0 # Does the facility provide all necessary secondary containment? ■ 0 0 0 # Does the Plan include a BMP summary? ■ 0 0 0 # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ ❑ 0 0 # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ # Does the facility provide and document Employee Training? ■ 0 0 0 # Does the Plan include a list of Responsible Party(s)? ■ 0 0 0 # Is the Plan reviewed and updated annually? ■ 0 0 0 # Does the Plan include a Stormwater Facility Inspection Program? ■ 0 0 0 Has the Stormwater Pollution Prevention Plan been implemented? ■ 0 0 0 Comment: SPPP plan does not address waste material and waste water treatment and disposal. Currently the marina discharges wastewater comingled with stormwater directly into the ditch that is connected with Duck Creek without any treatment . The marina is implementing some good measures like vacuum sanders and tarps to collect all waste material from boat maintenance, but not on mandatory principle. The stormwater from boat washing is sent through filter screen before mixes up with the stormwater. The facility is advised to implement mandatory measures to collect waste material and to install some sort of permanent wastewater collection and disposal method rather than discharge it of the stream. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ 0 0 0 Comment: Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ■ 0 0 ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑ Page: 3 .f Permit: NCG190028 Owner - Facility: Duck Creek Small Boat Harbor Inspection Date: 12/09/2010 Inspection Type: Compliance Evaluation Reason for Visit: Complaint Comment: Analytical monitoring is performed however the monitoring sheet shows exceedance of benchamtk valuse for Copper and Lead. The reason for exceedance is lack of wastewater collection and permitted disposal rather than discharge to receiving waters. It is required that the permitee follow the Tiered response guidelines within the Analytical Monitoring requirements of the permit Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? # Were all outfalls observed during the inspection? # If the facility has representative outfall status, is it properly documented by the Division? # Has the facility evaluated all illicit (non stormwater) discharges? Comment: See above comments in SPPP and Anayitical Monitoring section Yes No NA NE Page:4 Michael F. Easley, Governor William G. Ross Jr., Secretary r- North Carolina Department of Environment and Natural Resources i N, . Alan W..Klimek, P.E. Director Division of Water Quality May 25, 2006 Mr. Raymond Benton Duck Creek Small Boat Harbor P.O. Box 40 Bridgeton, NC 28519 Subject: Stormwater General Permit NCG190000 Operations and Maintenance Reminder Duck Creek Small Boat Harbor COC# NCG190028 Craven County Dear Permittee: Our records indicate that you have been issued a Stormwater General Permit and a Certificate of . -- Coverage for your facility. These permits have specific conditions that must be met in order for you to be in compliance with your permit. It is your responsibility, as the permit holder, to read and comply with the conditions contained in the permit. It is our responsibility, as the issuing authority, to make sure that the operation and maintenance of your facility complies with the conditions contained in your permit. To assist you in complying with — these conditions, we are attaching a Technical Bulletin specific to your permit requirements. -We are -- currently in the process of developing our inspection schedule. Therefore, you should have all of your records up to date as we may be contacting you in the near future to set up an inspection of your facility. If you have any questions, please do not hesitate to contact Samir Dumpor, Pat Durrett or myself at (252)946-6481. /Sincerely Al Hodge, Supervisor Washington Regional Office Surface Water Protection Unit Encl. CC: WaRO files North Carolina Division of Water Quality Internet: h2o.enr.state.nc.us 943 Washington Square Mall Phone: 252-946-6481 One Washington, NC 27889 FAX 252-946-9215 NorthCaroll/ina An Equal Opportunity/Afdrmadve Action Em&yer-50%Recycled110% Post Consumer Paper Aat {Q((%( Tko-sc(e,� �;3o�ovj Compliance Inspection Report Permit: NCG190028 Effective: 09/O1/04 Expiration: 08/31/09 Owner: Duck Creek Small Boat Harbor SOC: Effective: Expiration: Facility: Duck Creek Small Boat Harbor County: Craven 699 Galloway Rd Region: Washington Bridgeton NC 28519 Contact Person: Raymond Benton Title: Phone:252-638-1702 Directions to Facility: - l637-204iS - System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 1211412006 Entry Time: 10:20 AM Exit Time: 12:30 PM Primary Inspector: Jeff A Manning Phone: 252-948-3966 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Ship and Boat Building Stormwater Discharge CDC Facility Status: Cl Compliant 4 Not Compliant Question Areas: Storm Water l /' �V cit.. Cam. (See attachment summary) Page:1 r) Permit: NCG190028 Owner - Facility: Duck Creek Small Boat Harbor Inspection Date: 1211412006 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: At the time of the inspection the facility was unaware of the requirements of their permit. Page: 2 Permit: NCG190028 Owner- Facility: Duck Creek Small Boat Harbor Inspection Date: 12/14/2006 Inspection Type: Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ❑ ■ ❑ ❑ # Does the Plan include a General Location (USGS) map? ❑ ■ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ❑ ■ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ■ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ■ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ❑ ■ ❑ ❑ # Does the facility provide all necessary secondary containment? ❑ ■ ❑ ❑ # Does the Plan include a BMP summary? ❑ ■ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ■ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ■ ❑ ❑ # Does the facility provide and document Employee Training? ❑ ■ ❑ Cl # Does the Plan include a list of Responsible Party(s)? ❑ ■ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ ■ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ ■ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ■ ❑ ❑ Comment: At the time of the inspection the facility had no SPPP. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ■ ❑ ❑ Comment: The facility has not been monitoring as per the permit. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ ■ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ■ ❑ ❑ Comment: The facility has not been monitoring as per the permit. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ■ ❑ ❑ # Were all outfalls observed during the inspection? ■ ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ■ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑ Comment: The facility did not have a copy of the permit and certificate of coverage available at the time of the inspection. Page:3 Yes No NIA NE 12. If # 11 is yes- it is regularly inspected with pumping records maintained and available for inspection. ❑ ❑ (7 ❑ Fueling Activities: Have petroleum spill prevention practices been Implemented such as: 1. permittee has a regular inspection program for hoses, pipes and tanks; ❑ ❑ ❑ 2. permittee is using emergency shutoffs on fuel lines; ❑ ❑ ❑I ❑ 3. permittee has removed the lock on fuel nozzles that are used to j hold open the nozzle without being held; ❑ ❑ ❑1 ❑ 4. trains staff in spill prevention, containment & clean-up procedures; ❑ ❑ © ❑ 5. Oil absorbent material is available for use at fuel tanks; ❑ ❑ I❑ ❑ 6. prohibits the use of detergents & emulsifiers on'fuel spills; ❑ ❑ ED ❑ 1 7. has information on disposal of oil spill response equipment; ❑ , ❑ ❑I ❑ 8. Secondary containment is provided around fuel storage; [� ❑ ❑1 ❑ • A positive answer on # 4or 5 under boat maintenance repair will require comments. Inspection comments: �Qaf w4a�,2M1`1� ig heja. ed. a( con . —fp- M WI/V u' p Y"_? 'Tim •-,�'i�rl� jC�ft.PJti.. Y; PiU-If to ca�urmv� Inspector signature Date: s BIMS QUESTIONS FOR NCG190000 Facility Name:COC# NCG19�oz9 }}c,rtjc> r Rst Management Practices Yes No NA NE Site: Has everything possible been done to divert and/or filter runoff water, such as: 1. The site is covered with crushed stone; 0' ❑ ❑ ❑ 2. Buffers were created around the site, ie: plantings, filter strips etc.; ❑ [T ❑ ❑ 3. Slopes are managed at site to minimize runoff; [f ❑ ❑ ❑ 4. Roofs or secondary containment is provided around any materials stored outside. ❑ ©' ❑ ❑ Boat Maintenance & Repair: Have precautions been taken to recover pollutants at the source, such as; ' 1. Maintenance and repair work is performed inside buildings; ❑ Z ❑ ❑ 2. Sandblasting is performed within buildings, spray booths, or tarp enclosures; ❑ ❑ ❑ • 3. Vacuum sanders or other methods to collect paint dust and chips are used when prepping hulls; *4. Power washing is done on site; *5. Water from the power washing is collected and treated prior to discharge; *6. If the answer to #5 is yes, is there a permit for the wastewater discharge? ❑ ❑ ❑ 7. Uses or encourages the use of phosphate free and biodegradeable detergents; ❑✓ ❑ ❑ ❑ ❑ 0 ❑ ❑ ✓ ❑ 8. Uses or encourages the use of low -toxicity or non -toxic anti -fouling paints; ❑ ❑ ❑ 9. Uses or encourages the use of non -toxic antifreeze for wintering engines; 2' ❑ ❑ ❑ 10. Recovers antifreeze when possible; u ❑ ❑ ❑ 11. Has a pump -out station available; ❑ ❑ El ❑ °State of North Carolina 'Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Wayne McDevitt, Secretary Kerr T. Stevens, Director August 27, 1999 J RAYMOND BENTON DUCK CREEK SMALL BOAT HARBOR P.O. BOX 40 BRIDGETON, NC 28519 11511' NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Subject: Reissue - NPDES Stormw Duck Creek Small Boat H COC Number NCG 190028 Craven County Dear Permittee: 2 n 101 er P"I11NGTON REGIONAL OFFICE In response to your renewal application for continued coverage under general permit NCG190000, the Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency. dated December 6, 1983. The following information is included with your permit package: * A copy of general stormwater permit NCG190000 * A Stormwater Pollution Prevention Plan (SPPP) Certification Form. Completion of this form is required to certify that you have developed and implemented the SPPP as per the conditions of the permit. This form must be completed and returned to the Division within 30 days of receipt of this letter. DO NOT SEND the SPPP with the signed form. * Five copies of the Analytical Monitoring form and five copies of the Qualitative Monitoring form * A copy of a Technical Bulletin on the Stormwater program which outlines program components and addresses frequently asked questions * A corrected Certificate of Coverage if you indicated a name change on the Renewal Application Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package please contact Bill Mills of the Central Office Stormwater and General Permits Unit at (919) 733-5083, ext. 548 Sincerely, b�`- for Kerr T. Stevens Director, Division of Water Quality cc: Central Files Washington Regional Office 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG190000 CERTIFICATE OF COVERAGE No. NCG190028 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended. DUCK CREEK SMALL BOAT HARBOR is hereby authorized to discharge stormwater from a facility located at DUCK CREEK SMALL BOAT HARBOR, 699 GALLOWAY ROAD BRIDGETON CRAVEN COUNTY to receiving waters designated as Duck Creek in the Neuse River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, I1I, IV, V, and VI of General Permit No. NCG190000 as attached. This certificate of coverage shall become effective August 27, 1999. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day August 27, 1999. for Kerr T. Stevens, Director Division of Water Quality By Authority of the Environmental Management Commission 1�2r State of North Carolina Department of Environment, Health and Natural Resources Division of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director September 1, 1995 Raymond Benton Duck Creek Small Boat Marbor P.O. Box 40 Bridgeton, NC 28519 Subject: General Permit No. NCG 190000 Duck Creek Small Boat Marbor COC NCG 190028 Craven County Dear Raymond Benton: In accordance with your application for discharge permit received on April 5, 1995, we are forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated December 6, 1983. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit by submitting an individual permit application. Unless such demand is made, this certificate of coverage shall be final and binding. Please take notice that this certificate of coverage is not transferable except after notice to the Division of Environmental Management. The Division of Environmental Management may require modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any question concerning this permit, please contact MR. BILL MILLS at telephone number 919/733-5083. cc: -Washington -Regional -Office P.O. Box 29535, Raleigh, North Carolina 27626-0535 An Equal Opportunity Affirmative Action Employer Sincerely, Co'.t:en :1.: u... A. Preston Howard, Jr. P.E. Telephone 919-733-7015 FAX 919-733-2496 50% recycled/ 10% post -consumer paper 0 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES DIVISION OF ENVIRONMENTAL MANAGEMENT GENERAL PERMIT NO. NCG190000 CERTIFICATE OF COVERAGE NO. NCG190028 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Raymond E. Benton is hereby authorized to discharge stormwater from a facility located at Duck Creek Small Boat Harbor I I Sandy Point Road Bridgeton Craven County to receiving waters designated as Duck Creek in the Neuse River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV of General Permit No. NCG190000 as attached. This Certificate of Coverage shall become effective September 1, 1995. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day September 1, 1995. A. Preston Howard, Jr., P.E., Director Division of Environmental Management By Authority of the Environmental Management Commission NEW BERN QUADRANGLE NORTH CAROLINA , , yw350o�". • 7.5 MINUTE SERIES (TOPOGRAPHIC).. SE/4 NEW BERN 15' QUADRANGLE \a rrVV 'BAYBORO II'/ r301 N", SKIN68MI, - 3]] ..i - ':77°0 ,�OLYMPIA 2.2 Z `, I 2 590000 FEET 14 35°07 30 3 9 F t t ti- °Daybeacm q .< :'•. ,r.� \ °°j .` A \(\ 17 \4 1 P x \ � w �\ .3 .�E Piled Jc• �. \ t Drl �0a` P�geton - °'N\�, q� 3e88 ��n..'•. < Dolphino �.�•�. ne • \ 6 ��•• _ o U . it A A A \.� •-. � � SS - �1JL:-J Grove 15 s I Dcam moo 3887 i \ q Piling o Cdu -0 r I .P 01I '?`• - xZ 500000 '►' i Ire �I'• Pi�'ng w 1rKK _ _ FEET sr ower ��� {i _ 1 1--QLew Bern •� �' 1 Light Union Point Sandy Point n - Pile t+ tl`( 3886 l - n Sm up DO Pilc qa = Area' 4_1 Piling 3885 / Itt+;Jame'>:.��'. Dolphin ./ A tl%Light eyr �s Foul \ �1 �ti'Area y- 3arr�es,Cliy \ ♦ /� Area �✓/y}"Bk._ \ 'Green Spring �/ 1 13 \� V; pint - VA I ��c Light 7 Black Beacon oLight }� / �, V .•� Point _z �r r 17 • _- z/ , V. 14 I 9 Dr en •� Theater '.Beacmnt 44 c95(--Qa ua�'? NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM NOTICE OF INTENT REQUESTING COVERAGE UNDER GENERAL PERMIT NO. NCGI90000 STORMWATER DISCHARGES associated with activities classified as Ship and Boat Building and Repairing [Standard Industrial Classification Code (SIC) 373] and Marinas (SIC 4493). Complete this Notice of Intent (NOI) and mail to the following address: North Carolina Division of Environmental Management Water Quality Section, NPDES Group P.O. Box 29535 Raleigh, North Carolina 27626-0535 The NOI must be accompanied with a general permit filing fee of W.00 and a copy of a county map or USGS quad with the location of the facility clearly marked on the map. The check should be made out to the North Carolina Department of Environment, Health, and Natural Resources. I. . Facility Owner/Operator Information Provide the following location information for the owner/operator of the facility. This may or may not be the same as the facility location information. - Name: t K 3 0 o Address' O I�a X go - /00 q-O F- city:1'�Tkkbn-6 ON State: 1\4 (71, k Zip: Phone: (Rl9 II. Facility Location Information Fill in the appropriate requested facility location information in the spaces provided. Do not write "same as above". Facility Name: CjzE,ZY, kw.LI -0 A 443? t 0iZ Contact: Address: O - o O - /oo SAr[ o a� City: R , ►-'T-O t4 State: N C Zip: County: C-IZA\l F—N Phone jRl4 1 G 35 [ > 0 NOI 19 Page 1 of 3 Pages y evl� rro ro..ras un. i�r i(a _— pve.lt Gr�rEK MAR'," fill Cef. NEW BEZN `q• f: p / iu1 pi— . CROATAN lj P \ C R O\-�%7 A N DUCK CREEK SMALL BOAT HARBOR P. 0. BOX 248 PH. 638-1702 PH. 637 2045 BRIDGETON, N.C. 28519 FEE SCIIFDUi,f�: I?P'F'ECTPVE JANUARY 1 , 2007 YARD SERVICES HAUL/LAUNCH FEE (MINIMUM $140.00) HAUL/LAUNCH FEE LOAD OR OFF-LOAD FROM TRAILER HAUL/LAUNCH FEE, USE OF THIRD STRAP HAUL/LAUNCH FEE (MINIMUM ($160.00) WEEK -ENDS PRESSURE CLEAN HULL BY YARD CREW ONLY MASTS (STEP,, OR UNSTEP) BY YARD CREW ONLY NOTE: EXTRA MAST CHARGE OVER ONE N00I SANDERS -VACS, BUFFERS, PROP PULLER.AVAILARLE ELECTRICITY USED:!ON BOAT ONE TIME CHARGE YARD STORAGE FEES BOATS UP TO 30 FEET BOATS OVER 30 FEET TO 36 FEET BOATS OVER 36 FEET MINIMUM YARD STORAGE FEE TEMPORARY TRANSIENT WET STORAGE FEE NOTE: LONG TERM STORAGE OVER 90 DAYS DIS- COUNTED 20% THIS RATE REQUIRES PAYMENT IN ADVANCE OTHER SERVICE CHARGES CONTRACTOR SERVICE FEE CRANE SERVICE (MINIMUM FEE $50.00) FORK-LIFT SERVICE (MINIMUM FEE $45.00) BOAT TOWING SERVICE (MINIMUM FEE $200.00) AIR COMPRESSOR SERVICE $7 $7 $9 $9 $4 $4 $)00 $15 $15 00/FP. 50/FT. 00/FT 50/FT. 00/iIR. 00/DAY 00 $6.00/DAY $10.00/D.AY $50.00/DAY $10.00/DAY $2.50/F':'. $100.00 $90.00 $100.00/HR. $25.00/DA1' GENERAL YARD RULES 1) WET 8 DRY.STORAGE'BOTH REQUIRE A RENTAL FEE 2) YARD RESERVES RIGHT TO USE OF WET SLIP WHEN VACANT BY LESSEE 3) ABSOLUTELY NO SPRAY PAINTING IN YARD 4) ALL YARD WORKERS ARE RESPONSIBLE FOR KEEPING THEIR AREA FREE OF TRASH, OTHER -WISE A CLEAN UP FEE OF $35.00 WILL 13F. CHARGED 5) THIS IS A DO IT YOUR -SELF YARD DUCK CREEK MARINA IS NOT RESPONSIBLE FOR ANY INJURY THAT MIGHT OCCUR TO YOUR -SELF OR WORK -MEN 6) ADDITIONAL FEES MAY BE CHARGED FOR EXTRA YARD SERVICE. ON HAUL -OUTS, PRESSURE WASH, MAST SERVICES 7) CONTRACTORS WORKING ON CUSTOMERS BOATS SUBJECT TO A YARD CONTRACTOR FEE NO CASH NO SPLASH DUCK CREEK SMALL BOAT HARBOR P. 0. BOX 248 PH. 638-1702 PH, 637.2045 BRIDGETON, N.C. 28519 NOTICE TO ALL HANDS USING DUCK CREEK MARINA.FACILITIES STATE OF NORTH CAROLINA AND EPA CLEAN AIR ACT REQUIRE THE FOLLOWING REGULATIONS TO BE OBSERVED BEFORE ANY YARD WORK MAY PROCEED. 1.) SPRAY PAINTING MUST BE IN A DESIGNATED AREA WITH A SURROUND CURTAIN BEFORE ANY WORK MAY PROCEED. 2.) AN ELECTRIC ORBITAL SANDER WITH HOLES IN THE SANDING DISC ATTACHED TO A SHOP'VACUUM CLEANER IS REQUIRED TO SAND THE HULL BOTTOM. 3.) ALL DUST AND RESIDUE FROM SCRAPING AND SANDING MUST BE COLLECTED AT DAYS END AND PLACED IN A YARD DISPOSAL CONTAINER. NOTE: ALL BOAT OWNERS ARE REQUIRED TO FOLLOW THESE GUIDE LINES FOR DUCK CREEK MARINA TO STAY IN COMPLIANCE WITH EPA REGULATIONS. 1