Document 2R1VNvJNkzjXBpQx8mBB10Nrp

UNITED STATESUNITED STATES ENVIRONMENTAL PROTECTION AGENCY * *REGION 1 ENVIRONMENTAL AGENCY5 POST OFFICEB OSSTQOUN,A RMAE ,0 21S0U9-I3T9E12 100 PROTECTION Drafted Date:23 Sept 2021 Finalized Date:15 October 2021 Subj:Inspection Report Clean Water Act - National Pollutant Discharge Elimination System (" NPDES ") U-Haul Construction From:Andrew Spejewski, Enforcement Officer Thru:Stephanie Tougas, Enforcement Officer To:File I. Facility Information A. Facility Name:U-Haul Construction B. Facility Location: Duval Road Lancaster, MA 01523 C. Facility Contacts: Jeff Vaine, Project Manager U-Haul Co. 499 Montgomery St. Chicopee, MA 01020 413-535-0150, Jeffery_vaine@uhaul.com D. NPDES ID No (s).: None II. Background Information A. Date(s) of inspection: September 17, 2021 B. Weather Conditions: Clear C. US EPA Representative(s): Andrew Spejewski D. State / Local Representative(s): David Koonce, Town of Lancaster Conservation Agent Thomas Christopher, Chair, Town of Lancaster Conservation Commission ED_019088A_00019790-00001 E. Federally Enforceable Requirements Covered During the Inspection: 2017 NPDES General Permit for Discharges from Construction Activities (2017 Construction General Permit) F. Previous Enforcement Actions: No federal actions known III. Type and Purpose of Inspection Unannounced evaluation of compliance with the 2017 Construction General Permit IV. Facility Description The site lies north of a pre - existing parking lot and building. The high point is in the center of the west side of the currently cleared area, and it slopes downward to the east over most of the site, as well as down to the south in the southwest corner and slightly down to the north towards the north end. At the time of the inspection, a large area of several acres had been cleared and partially graded. V. Inspection Mr. Spejewski arrived at the parking lot at about noon. Mr. Koonce and Mr. Christopher also arrived at the same time. No workers were on the construction site itself, but two U- Haul employees were working on the existing building. They provided contact information for Jeff Vaine (see details below). A. Opening Conference Mr. Spejewski called Mr. Vaine and explained the purpose of the inspection. Mr. Vaine described himself as the owner representative. Mr. Spejewski requested that either a representative come to the site, or that Mr. Spejewski get permission to walk the site unaccompanied. Mr. Vaine granted permission to Mr. Spejewski to walk the site. Shortly thereafter, Mr. Vaine called back and said he could be at the site in fifteen minutes or so. Mr. Spejewski agreed to meet him on site. B. Facility Tour The site had been cleared and partially graded, with bare dirt exposed over the entire site. No areas had any stabilization. Several soil stockpiles had no stabilization or perimeter protection, except one small stockpile in the northeast that was partially covered in weeds. At various places, several - inch - deep gullies had formed on the multiple moderately steep slopes on the site. A line of new silt fence was in place across the center of the site, running north - south across the general slope of the site. 2 ED_019088A_00019790-00002 Along the south edge of the cleared area (with the parking lot to the south), the site was mostly graded slightly away from the parking lot and down to the southeast corner of the site. The southeast corner of the site had new - looking lines of silt fence and either hay bales or gravel berm, between the east edge of the parking lot and the site, and along the east edge of the site. The corner included a berm channeling flow to a small shallow informal stormwater retention basin (with standing turbid water). The basin discharged to the east through a gravel berm. Along the east side of the site, a line of stumps and debris was in place several yards inside of (and uphill from) a silt fence / haybale line along the east edge of the cleared area. There was extensive sediment inside the silt fence at the foot of the slope, and in several places, sediment deposits were in the woods past the silt fence, with no sign of silt fence failure Near the north edge of the east side, more sediment was deposited in the woods, leading perhaps 20-30 yards to an area with wet ground and puddles, full of reeds and cattails. Another spot in the northeast corner had sediment past the new line of silt fence. Another small shallow informal stormwater retention basin was located in the northeast corner of the site. It appeared to discharge over a low point in the earth wall just inside of the silt fence line. To the north, the terrain was at or above the cleared site. The terrain to the west was generally at or above the site. At the west side of the south edge of the site, just north of the existing building, the site drained to a very shallow wide ditch running south through a flat area west of the building, with turbid standing water. South of the building, the ditch ran more steeply down the hill to join a drainage ditch running west along the north side of Duval Road. C. Records Review N / A (see below) D. Closing Conference Mr. Vaine arrived on site soon after the tour completed. Mr. Spejewski introduced himself and presented his credentials. Mr. Vaine introduced himself as the owner representative [his business card lists him as'project manager'for UHaul of Western Massachusetts and Vermont]. Mr. Spejewski asked when the project first disturbed earth. Mr. Vaine said he believed it was in April, before his involvement with the site, however Mr. Koonce said he believed it was actually July of this year. 3 ED_019088A_00019790-00003 Mr. Vaine said the construction was on hold, and current plans were only to comply with the Conservation Commission's orders for erosion control. Mr. Spejewski asked about NPDES permits and a Stormwater Pollution Prevention Plan. Mr. Vaine said he did not believe permit coverage was obtained, nor a SWPPP prepared. Mr. Spejewski noted that the site appeared to need coverage under the Construction General Permit. Mr. Spejewski also noted that the permit requires temporary or permanent stabilization of areas not being actively worked, but EPA would discuss the site with the Conservation Commission before making any formal or informal recommendations for next steps. Mr. Spejewski then thanked Mr. Vaine for his time and departed at approximately 1:00 PM. Picture List: IMG 2492.JPGFacing west, south edge of site IMG 2493.JPGFacing east, south edge of site IMG 2494.JPGFacing north over site, from south edge IMG 2495.JPGFacing southeast over southeast corner IMG 2496.JPGDetail, east side of site IMG 2497.JPGFacing north along east side of site IMG 2498.JPGCenter - north of east side IMG 2499.JPGEast border and woods, center north IMG 2500.JPGFacing north to northeast corner IMG 2501.JPGFacing west over northeast corner IMG 2502.JPGSediment deposits in woods, east of north edge of site IMG_2503.JPGWoods, east of north edge of site IMG 2504.JPGWet area at end of sediment deposits IMG 2505.JPGFacing onto site from near wet area IMG 2506.JPGNortheast edge of site IMG 2507.JPGNortheast part of site, with part of informal basin IMG 2508.JPGFacing onto site, over informal basin in northeast IMG 2509.JPGFacing north from north - center of site IMG 2510.JPGDrainage to informal basin in northeast IMG 2511.JPGFacing over informal basin in northeast IMG 2512.JPGFacing north to north edge of site IMG 2513.JPGFacing west, north of existing building IMG 2514.JPGShallow ditch west of existing building IMG 2515.JPGSouth part of drainage ditch, facing Duval Road IMG 2516.JPGSlope down to Duval Road, facing southwest IMG 2517.JPGFacing east, north of existing building * 4 ED_019088A_00019790-00004 Unless otherwise noted, this report describes conditions at the facility / property as observed by EPA inspector(s), and / or through records provided to and / or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. 50 ED_019088A_00019790-00005