Document kmodzQoXdo0BNnOo4jn5p8MpV

U.S. EPA Headquarters Enforcement Division 1200 Pennsylvania Avenue NW, Washington, DC 20004 UNPERMITTED INDUSTRIAL FACILITY STORMWATER INSPECTION CHECKLIST Inspection Date Time Weather Conditions Media/Program May 13, 2024 Entry: 4:00 PM Exit: 5:00 PM 82F and Sunny Water - CWA 301, 402 - Indu strial SW/NEC Operator Name: Facility or Site Name: Permit ID or Tracking #: SIC Code: Facility Address: (city, state, zip code) Geographic Coordinates: Mailing address: Twin Coves Marina(city, state, zip code) County: Regular Days/Hours of Operation: # of Employees at location: Size of Facility (in acres): Receiving Water(s): Date facility est. @ location: Waterview Marinas Twin Coves Marina N/A; No permit at the time of the inspection 4493 - Marinas 4500 Murrell Park Rd #9 Flower Mound, TX 75022 33.004594, -97.099156 4500 Murrell Park Rd #9 Flower Mound, TX 75022 Denton County 10:00 AM - 6:00 PM (Monday - Sunday) 5 Approximately 9.91 acres of land not including slips/docks on Grapevine Lake. Facility located on Grapevine Lake 1974 Onsite Representatives: Name: John Swick Title: Partner Phone: (469) 956-5012 Email: jswick@waterviewmarinas.com Authorized Official: Contacted? Yes No Name: John Swick Title: Partner Phone: (469) 956-5012 Email: jswick@waterviewmarinas.com Additional Personnel Participating in Inspection: Name: N/A Title: N/A Inspector(s): Christopher Pardo Ryan Marrero-Vila Carol Johnson Destinee Agwuna Title: Lead Inspector Inspector Inspector Inspector Company: Eastern Research Group, Inc. Eastern Research Group, Inc. Environmental Protection Agency, Region 6 Environmental Protection Agency, Region 6 Page 1 of 6 Twin Coves Marina - Stormwater Inspection 5/13/2024 All photos taken by Christopher Pardo, ERG Inspection Report Author: Name: Ryan Marrero-Vila Supervisor Review: Name: Lori Tanner (acting for Ruben Alayon-Gonzalez) Signature: Signature Date: July 3, 2024 Date 07/10/2024 SECTION I - INTRODUCTION Purpose of the Inspection The purpose of the inspection was to determine compliance with the industrial stormwater requirements under 301 and 402(p) of the Clean Water Act (CWA) and its implementing regulations found at 40 Code of Federal Regulations (CFR) Part 122.26. The inspection was unannounced and consisted of interviewing Facility representatives, recording field observations, and taking photographs to document site conditions throughout the Facility at the time of the inspection. Opening Conference 1) Brief narrative documenting those present, introductions, presentation of credentials, and explanation of the purpose of the inspection. On May 13, 2024, a U.S. Environmental Protection Agency (EPA) contractor, Eastern Research Group, Inc. (ERG), conducted an industrial stormwater non-filer inspection at Twin Coves Marina located in Flower Mound, Texas (Facility). Carol Johnson and Destinee Agwuna of EPA Region 6, and Chris Pardo and Ryan Marrero-Vila of ERG (collectively, EPA Inspection Team) met with the Facility representative, John Swick. The EPA Inspection Team presented their credentials and explained that it was EPA's understanding that the Facility did not have an industrial stormwater permit. The EPA Inspection Team explained they were onsite to conduct a Clean Water Act stormwater inspection, which includes observing the current operations of the facility and assessing the potential for stormwater discharges from the Facility. The weather at the time of the inspection was sunny and approximately 82F. According to precipitation data from the National Oceanic and Atmospheric Administration (NOAA)1, the Flower Mound, Texas area received 0.05 inches of rain the day prior to the inspection and 0.93 inches of rain the day of the inspection. 2) Credentials presented to: John Swick (Partner of Waterview Marinas) 3) Facility acknowledged receiving previous outreach materials or correspondence on Permit requirements? Yes No Describe: The Facility did not acknowledge receiving previous outreach materials. The Facility's previous Texas Commission on Environmental Quality (TCEQ) Stormwater Multi-Sector General Permit was terminated in 2003. 4) Facility has been individually notified by permit authority or EPA that it is subject to stormwater requirements? Yes No Describe: N/A 1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Page 2 of 7 Twin Coves Marina - Stormwater Inspection 5/13/2024 All photos taken by Christopher Pardo, ERG FACILITY'S OPERATION & PRODUCT DESCRIPTION Description of business and industrial activities occurring throughout the site. (Include operator's description and note any documentation that further establishes SIC code (permit applications, reports, business registries, website...). The Facility is a boat storage and fueling marina with approximately 400 wet-slips and jet ski docks, with 370 wet-slips having canopy-cover [refer to Appendix B, Photo Log (Photographs 11, 21, 29, 30, 31, 37 and 38)]. The Facility offers on-water fueling (gasoline) via one fueling station on the pier [refer to Appendix B, Photo Log (Photographs 32-34)]. The land portion of the Facility covers approximately 10 acres and includes a parking lot [refer to Appendix B, Photo Log (Photographs 21 and 22)], a maintenance warehouse [refer to Appendix B, Photo Log (Photographs 2-8)], uncovered boat trailer storage [refer to Appendix B, Photo Log (Photographs 9,11 and 24)], and an uncovered miscellaneous storage area [refer to Appendix B, Photo Log (Photographs 1320)]. The Facility representative stated that no boat repair or boat maintenance services are offered at the Facility. The maintenance warehouse houses groundskeeping equipment (i.e., lawnmowers and leaf blowers) stored on the ground and on metal shelves, facility vehicle maintenance equipment and used fluids, and pesticides which are stored on secondary containment [refer to Appendix B, Photo Log (Photographs 2-5)]. The Facility contains open dry storage lots for boats and trailers in the yard surrounding the metal maintenance warehouse in the northern portion of the Facility. Note that during the inspection, the western most portion of the dry storage area was flooded [refer to Appendix B, Photo Log (Photographs 9-11 and 23)]. The Facility was previously permitted under a TCEQ Texas Pollutant Discharge Elimination System (TPDES) Stormwater Multi-Sector General Permit for Industrial Facilities. According to EPA's records, the TCEQ permit was terminated in 2003. Other industrial facilities owned/operated by same business entity Yes No Describe: The Facility is owned/operated by Waterview Marinas which has seven (7) marinas across three (3) states. Two (2) in Oklahoma, four (4) in Texas, and one (1) in Florida according to the Waterview Marinas website, https://waterviewmarinas.com/twin-coves-marina/. SECTION II - OBSERVATIONS SITE EVALUATION Pollutant Sources Note location, quantity/size, design issues, any operation and maintenance (O&M deficiencies) (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are Best Management Practices (BMPs) in place to minimize or eliminate stormwater discharges from industrial activities? Page 3 of 7 Twin Coves Marina - Stormwater Inspection 5/13/2024 All photos taken by Christopher Pardo, ERG Loading/Unloading Operations The Facility receives gasoline from a mobile fuel truck into the 12,000-gallon, double-walled aboveground storage tank (AST) located at the southeastern portion of the Facility [refer to Appendix B, Photo Log (Photograph 25)]. Industrial Manufacturing/ The EPA Inspection Team observed the Facility's primary business is boat storage. Processing Operations No industrial manufacturing or processing operations were observed or reported on site. Industrial Machinery & Equipment Storage The Facility had one (1) telescopic forklift which was stored outside on the gravel lot surrounding the maintenance warehouse [refer to Appendix B, Photo Log (Photographs 12 and 23)]. In addition, the maintenance warehouse, located in the northern portion of the Facility, housed general groundskeeping [refer to Appendix B, Photo Log (Photographs 4 and 6)]. At the time of the inspection, the EPA Inspection Team observed a stockpile of black polyethylene dock floats and old boat lift equipment located about 100 feet east of Grapevine Lake [refer to Appendix B, Photo Log (Photographs 13, 14, and 20)]. Storage of Industrial Materials or Products The EPA Inspection Team observed a pile of approximately nine (9) black polyethylene dock floats on a wooden barge in one of the Facility's boat slips. The Facility was replacing old dock floats with these new ones [refer to Appendix B, Photo Log (Photograph 35)]. Two (2) multimixer devices, containing an unidentified mix, were located on the same wooden barge as the black polyethylene dock floats [refer to Appendix B, Photo Log (Photograph 36)]. Liquid Storage (e.g., Tanks, Liquid Storage Drums) The EPA Inspection Team observed one (1) double-walled 12,000-gallon gasoline AST located in the southeastern portion of the Facility approximately 500 feet upgradient of Grapevine Lake [refer to Appendix B, Photo Log (Photographs 25)]. The EPA Inspection Team observed two (2) secondary containment pallets within the warehouse. One (1) containment pallet contained used oil containers, gas cans, and other miscellaneous fluid containers. The other containment pallet contained jugs of pesticides [refer to Appendix B, Photo Log (Photographs 2, 3, and 5)]. Waste Storage/Disposal Areas (solid and/or hazardous) The EPA Inspection Team observed a 200-gallon polyethylene tank stored over a wooden pallet in the miscellaneous storage area [refer to Appendix B, Photo Log (Photographs 13 and 15-18)]. The polyethylene tank contained sanitary waste and was located approximately 100 feet upgradient of Grapevine Lake. According to the Facility Representative, this tank was temporarily stored here after being Page 4 of 7 Twin Coves Marina - Stormwater Inspection 5/13/2024 All photos taken by Christopher Pardo, ERG Pollutant Sources SITE EVALUATION Note location, quantity/size, design issues, any operation and maintenance (O&M deficiencies) (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are Best Management Practices (BMPs) in place to minimize or eliminate stormwater discharges from industrial activities? removed from a mobile bathroom trailer, due to recent flooding of the lake [refer to Appendix B, Photo Log (Photograph 22)]. The EPA Inspection Team observed solid waste dumpsters for general solid waste located by the metal maintenance warehouse. These dumpsters contained pieces of discarded Styrofoam dock floats. The dumpsters were not equipped with permanent covers/lids. The EPA Inspection Team observed a 250-gallon grease trap, from the on-site restaurant, stored in the southeastern portion of the Facility [refer to Appendix B, Photo Log (Photographs 26 and 27)]. The EPA Inspection Team observed cooking oil and grease on the ground directly beneath the tank. This grease trap was located approximately 475 feet upgradient of Grapevine Lake. The EPA Inspection Team observed used vehicle fluids stored inside the maintenance warehouse [(refer to Appendix B, Photo Log (Photographs 2 and 3)]. All oil containers, gas cans, and any other miscellaneous fluid containers were stored over a spill containment pallet. Waste Treatment Facilities The EPA Inspection Team observed two (2) large black tanks associated with a (e.g., Pretreatment decommissioned aerobic wastewater treatment system in the western portion of Systems) the Facility [refer to Appendix B, Photo Log (Photographs 14 and 19)]. Fueling Stations/Equipment Maintenance Areas & Cleaning Areas The EPA Inspection Team observed a gasoline fueling station located centrally on the Facility's dock. The fueling station was connected to the 12,000-gallon gasoline tank via underground pipes [refer to Appendix B, Photo Log (Photographs 32-34)]. According to the Facility representative, minor vehicle maintenance such as oil and fluid changes for Facility machinery/vehicles occur within the maintenance warehouse. Sediment & Erosion Controls The EPA Inspection Team did not observe areas of the Facility that required erosion and sediment controls. Spills/Leaks Handling The EPA Inspection Team did not observe spill kits located near potential sources of contamination (e.g., fueling areas). Page 5 of 7 Outside Shelters Twin Coves Marina - Stormwater Inspection 5/13/2024 All photos taken by Christopher Pardo, ERG Temporary (Date Established___________________) Permanent The EPA Inspection Team observed approximately 14 canopy-style awnings which were 100-300 feet in length [refer to Appendix B, Photo Log (Photographs 11, 21, 29, 30, 31, 37 and 38)]. These awnings contained boat slips underneath. Pollutant Sources Evidence of nonstormwater sources/discharges (allowable if permitted under MSGP)? Evidence of process wastewater sources/discharges? SITE EVALUATION Note location, quantity/size, design issues, any operation and maintenance (O&M deficiencies) (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are Best Management Practices (BMPs) in place to minimize or eliminate stormwater discharges from industrial activities? Evidence of non-stormwater sources/discharges was not observed during the inspection. Evidence of process wastewater sources/discharges was not observed during the inspection. OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS Number and description of each potential Stormwater Discharge Point from the Facility The entire Facility sloped down and westward towards Grapevine Lake. Facility stormwater would discharge directly to Grapevine Lake [refer to Appendix B, Photo Log (Photographs 11, 21, and 22)]. Uncovered boat docks were located directly over the lake and would directly discharge any stormwater and accompanying pollutants into Grapevine Lake [refer to Appendix B, Photo Log (Photographs 32, 37, and 38)]. Evidence of pollutants migrating offsite (stains, deposits, ponding) at discharge points, into receiving waters or in MS4 The EPA Inspection Team did not observe evidence of pollutants migrating offsite into receiving waters or an MS4. Evidence of Nonstormwater Discharges leaving site (authorized or unauthorized) Evidence of non-stormwater discharges was not observed during the inspection. Page 6 of 7 Twin Coves Marina - Stormwater Inspection 5/13/2024 All photos taken by Christopher Pardo, ERG Description of general gradients/slopes onsite, all apparent discharge points, and discharge pathway from Facility to Receiving Water or MS4 (storm drains, channel, swale, ditches, driveway, pipes, & etc.) The EPA Inspection Team observed that the ground surface throughout the Facility was mostly unpaved and was composed of grass or gravel. The only paved portion of the Facility was the parking lot which, at the time of the inspection, was submerged underneath the water due to recent flooding. The EPA Inspection Team observed that Facility stormwater would convey as overland flow to Grapevine Lake [refer to Appendix B, Photo Log (Photographs 11, 21, and 22)]. SECTION III - AREAS OF CONCERN At the time of the inspection, the EPA Inspection Team identified the following at the Facility: 1) At the time of the inspection, the EPA Inspection Team identified the following at the Facility: a. The Facility is engaged in providing boat storage wet-slips, jet ski docks, boat trailer storage lots, and on-site boat fueling; activities consistent with SIC Code 4493 - Marinas). SIC Code 4493 is regulated under 40 C.F.R. 122.26 for stormwater discharges associated with industrial activity. b. At the time of the inspection, the Facility did not have coverage under the 2021 Multi-General Stormwater Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity. 2) The Facility's on land and outdoor areas were used for boat/trailer storage, boat fueling, and storage of other miscellaneous marina related materials such as polyethylene dock floats and boat lift equipment [refer to Appendix B, Photographs 7-15, 18-20, and 23-24)]. 3) The EPA Inspection Team did not identify any best management practices (BMPs) such as spill kits near potential liquid sources of pollution such as the dock-based fueling station [refer to Appendix B, Photo Log (Photographs 32-34)]. 4) The EPA Inspection Team observed cooking oil and grease staining on the ground immediately beneath the 250-gallon grease trap stored in the southeastern portion of the Facility [refer to Appendix B, Photo Log (Photographs 26 and 27)]. This grease trap was located approximately 475 feet upgradient of Grapevine Lake. 5) The EPA Inspection Team observed a 200-gallon polyethylene tank approximately one-half full of sanitary waste stored on a wooden pallet in the miscellaneous storage area on the Facility's west side [refer to Appendix B, Photo Log (Photographs 13, 15-18)]. The uncontained sanitary waste tank was located approximately 100 feet upgradient from Grapevine Lake. SECTION IV - LIST OF APPENDICES Appendix A - Aerial Location Appendix B - Photograph Log Page 7 of 7