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MENTAL PROTECTION
Sent via Electronic Mail (Dated as shown on electronic signature)
Mark Hill, Manager
Hills Yacht Yard Inc.
60 River Street
Beverly, MA 01915
hillsyachtyard@gmail.com
Subject: November 1, 2022, EPA Inspection
Dear Mr. Hill:
On November 1, 2022, the U.S. Environmental Protection Agency (EPA) performed an
inspection at Hills Yacht Yard Inc., located at 60 River Street, Beverly, MA (the Facility),
regarding compliance with the National Pollutant Discharge Elimination System program of the
Clean Water Act (CWA). A copy of the inspection report is included as an attachment to this
letter along with a photo album.
The industrial activities taking place at the Facility are classified under the Standard Industrial
Classification (SIC) code 4493 (Marinas) which is an applicable code under the Multi - Sector
General Permit for Stormwater Discharges Associated with Industrial Activity (MSGP) (Sector
Q- Water Transportation Facilities). EPA notes that the Facility was previously covered under
the 2015 MSGP, but did not reapply for coverage under the 2021 MSGP. This means that, as
currently configured, stormwater discharges from the Facility are not authorized, and are being
discharged in violation of the CWA, until you obtain permit coverage under the current 2021
MSGP.
EPA has contacted you three times since the 2015 MSGP was terminated to try and resolve this
matter. In order to demonstrate that you are taking action to come into compliance with the
CWA, please take the following steps and report your progress in an electronic format to me at
Rosenberg.alex@epa.gov, within the time frames described below.
1. Within 30 days of receiving this letter, submit an estimated date by which the Facility
will submit a Notice of Intent (NOI) to discharge under the 2021 MSGP. The NOI must
be submitted via the Central Data Exchange (CDX). A fact sheet on how to sign - up for
an account on CDX is attached (# 1). Fact sheets covering NOI submittal (# 2) (through
the CDX application named NeT - MSGP) and monitoring data submission (through the
CDX application named NeT - DMR) (# 3) are also attached. Upon submission of your
Facility's NOI, please email me, indicating the date of such submission.
2. Within 60 days of receiving this letter, submit a copy of an updated Facility Stormwater
Pollution Prevention Plan (SWPPP). A SWPPP template can be found on the national
ED_019088A_00012933-00001
MSGP website. Ensure that it includes a description of any improvements made to the
pollutant control measures for the boat washing and boat maintenance area. To be clear,
process water discharges from boat washing are prohibited unless individual NPDES
permit authorization is obtained, which is separate from the MSGP application. Under the
MSGP however, good housekeeping and other pollution control measures must be
implemented to prevent stormwater from carrying any residual pollutants left on the
surface of boat washing pads from discharging at authorized outfalls.
Please refer any questions related to technical issues in this letter to me at 617-918-1709 or
Rosenberg.alex@epa.gov. Legal issues may be directed to Sam Horowitz, Enforcement Counsel,
at (617) 918-1512 or Horowitz.samuel@epa.gov.
Sincerely,
Alex Rosenberg, Water Compliance Unit Inspector
Enforcement and Compliance Assurance Division
Enclosures:
Inspection Report
Inspection Photo Album
Fact Sheet Applying for MSGP Coverage Step 1 (CDX)
Fact Sheet - Applying for MSGP Coverage Step 2 (NOI & SWPPP)
Fact Sheet L Applying for MSGP Coverage Step 3 (NetDMR)
CCs (electronic only):
John Macauley, MASS DEP
Susannah King, MASS DEP
Sam Horowitz, Enforcement Counsel, US EPA
1 https://www.epa.gov/npdes/stormwater-discharges-industrial-activities-fact-sheets-and-
guidance # guidance
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