20181527 Ver 1_NOV Response letter_20191017

Notice of Violation and Recommendation for enforcement response
We have been diligently working since we were notified of this violation to immediately address the
turbidity levels that were caused by the water run-off from our site.
The discharge that occurred giving us the raised level of NTU was from the effects of the hurricane and
the unexpected amount of precipitation from that storm. There was an estimated 4-5' of sludge
material that ran off into the marina during the storm that needed to be removed. The turbidity testing
that followed one day after the hurricane was, in our opinion, the main reason behind the high NTU
reading.
Following the hurricane, it was shown that the double dewatering basins with a rip rap/rock rundown
with wattle protection were not effective for treatment of the sludge that was needed to be pumped
from the marina. At the request of Mr. Trentt James and Mr. Robb Mairs, all dewatering activities into
the sediment basins has ceased. All sedimentation that penetrated into the wetlands has been removed
with hand shovels and buckets. There will be no more pumping into the initial sediment basins without
first contacting Mr. lames or Mr. Mairs. There is an attached map of the initial sediment basins.
Because of the site progression from Mr. D Logan, he has escalated the excavation of Wet pond #4 and
anticipate the completion in the next two weeks (see photos). Please see attached plan sheet showing
the new direction for dewatering. Moving forward, all water pumped from the pond will be discharged
through a dewatering bag and spilled on a containment area with 2 catch basins (photo #1). The water
will dump into the forebay of Pond #4. The size of this wet pond will allow all sediment to settle and
clean water will overflow the rip rap weir into the wetlands. Pond #4 area is significantly larger that our
initial dewatering sediment ponds, and feel this will be adequate to completely eliminate turbidity
issues in both the wetland areas and all surface waters. The Weir overflow is also nearly 1,000 LF
farther upland to allow for more treatment through the wetlands. This has been the suggestion of
NCDEQ from the beginning, and was not practical in a construction and/or cost standpoint until now. As
it stands, an estimated $65,000-$75,000 was used to construct and actively maintain the initial 2
dewatering/sedimentation basins that have now been deemed unsatisfactory. These were built above
and beyond what the plans have shown for sediment.
We are fortunate that our marina dewatering activities are nearly completed and believe this will
eliminate any further violations. All bulkhead walls surrounding the marina are up and will eliminate all
sediment run off into the marina. The remaining material to be excavated from the marina is clean,
hard, coarse, gray sand material, so we are anticipating cleaner discharge.
As of Oct. 9`h, Mr. D Logan has directly reached out to Mr. Robb Mairs and Mr. Trentt James for a follow-
up visit affirming that the violations were taken seriously and were immediately addressed and
corrected. Mr. Mairs & Mr. James have been resourceful in helping us continually combat the turbidity
levels that have made it to the waterways, and we will reach out to them directly if we need additional
help moving forward. We all share the goal of no turbidity issues in our waterway.
RECEIRDMIGDENRIRWR
OCT 17 2019
Water Quality Regional
yv>, "ffice

Photo #1, Discharge spillway w/ clewatering bag
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RECEIVCC/10EHR/M
OCT 17 2019
Water Quality Regional
Operations Section
Wilmington Regional Office

Wet Pond #4 nearing completion, Facing inland
RECEIVEDINDDENRIDWR
OCT 17 /-m
Water Quality Regional
Operations Section
Wilmington Regional Office

Wet Pond #4 Facing towards the waterway
RECElVEDitiCDEN RIDWR
OCT 17 niq
Water Quality Regional
Operations Section
Wilmington Regional office

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Initial Sediment basins. This has been abandoned and will not be utilized.
1 MIK'9ltiCQ1 NRIDWR
OCT 112019
Woter Quality ^regional
porations Sectmn
Wilmington R^giondl Office