Document 2qzJo1J9nnM85LVkNwdjjpD2R

EPA Region 10 Enforcement and Compliance Assurance Division Clean Water Act (CWA) Inspection Report Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 03/14/2024 10:00 AM (PST) Announced: No 03/14/2024 11:45 AM (PST) Access: Granted Mostly Sunny, 43 F Water Clean Water Act, NPDES, Stormwater - Construction CEI - Compliance Evaluation Inspection Permittee Name General Contractor Project or Site Name Project/Site Physical Address County/Borough/Parish Facility GPS Coordinates Permittee Mailing Address Toll Brothers, Inc. Toll Brothers, Inc. Vinje Hill Estates 1317 71st Avenue SE, Lake Stevens, Washington, 98258 Snohomish County 47. 984428405 N -122.134841918 W 8815 122nd Avenue NE, Kirkland, Washington 98033 FRS ID Permit Number NAICS 110071280511 WAR311241 238910 (Site Preparation Contractors) Inspection Contacts: Organization Name EPA Region 10 WA Ecology Toll Brothers, Inc. Toll Brothers, Inc. Jon Klemesrud Megan Junod Eric Weisenstein Andrew Acker Title Lead Inspector Present in Opening Conf. Yes Inspector Yes Land Development Manager No Construction Manager Yes Present in Closing Conf. Yes Yes No Yes EPA Inspector Signature/Date JON KLEMESRUD Jon Klemesrud Digitally signed by JON KLEMESRUD Date: 2024.04.15 14:00:49 -07'00' Supervisor Signature/Date PETER CONTRERAS Peter Contreras, Chief FDDWES Digitally signed by PETER CONTRERAS Date: 2024.04.15 14:57:14 -07'00' 2024 CWA NPDES WAR311241 Inspection Report This inspection report is based on information supplied by conversations with Mr. Eric Weisenstein and Mr. Andrew Acker, or direct observations made at the time of the inspection, and records and reports maintained by the permittee. This inspection report may also include information gathered from a review of EPA, State, and/or public records. SECTION I - INTRODUCTION Entry and Inspection Chronology This was an unannounced inspection; I was joined on the inspection by Washington State Department of Ecology (Ecology) inspector Ms. Megan Junod. At approximately 8:30AM on the day of the inspection, I called and spoke with Mr. Eric Weisenstein, Land Development Manager with Toll Brothers, Inc. Mr. Weisenstein is listed as the project's "Responsible Official" on the most recent Electronic Signature Agreement Form (December 1, 2023). On the call, I introduced myself and discussed that I had been asked to conduct an on-site inspection at the Vinje Hill Estates construction project, to assess compliance with the project's coverage under Ecology's Construction Stormwater General Permit (CGP). I explained that the inspection was in coordination with Ecology and would include a walk-through of the construction site and a review of permit related documents. Mr. Weisenstein welcomed to the inspection and provided me with the phone number for the on-site contact associated with the project, Mr. Andrew Acker, Construction Manager with Toll Brothers, Inc. I subsequently called Mr. Acker and I restated the purpose of my call. Mr. Acker discussed that the construction site was active and that he would be on-site and available for the inspection. We agreed to meet at 10:00AM. Ms. Junod (Ecology) and I arrived on-site at approximately 10:00AM, we were greeted by Mr. Acker near the construction site entrance, along 72nd Ave. SE. Following our initial introductions, I presented my EPA credentials and discussed the purpose and expectations of the inspection and provided my business card. We had a brief discussion regarding the project's general timeline and recent activities. Mr. Acker discussed that during the initial land development phase in 2023, four model homes were constructed and completed in August 2023. Disturbed/exposed areas then received hydroseeding in preparation for the wet weather months. Construction ramped up again in January 2024. It was discussed that Toll Brothers, Inc. conducts general construction activities, including stormwater BMP implementation and maintenance. CESCL duties are also managed on-site by Toll Brothers, Inc., including routine site inspections and stormwater sampling/monitoring. The inspection consisted of an opening conference, a walk-through of the construction site, a records review and concluded with a closing conference. During the closing conference we discussed our observations made during the walk-through, potential compliance concerns and next steps. We were accompanied throughout the inspection by Mr. Acker. Post-inspection, I followed up with an email to Mr. Weisenstein recapping the general inspection activities that had occurred and potential compliance concerns discussed with Mr. Acker. I also provided a copy of EPA's Small Business Resources Information Sheet. Project History The Vinje Hill Estates construction project (hereinafter referred to as the "Project") is permitted to discharge stormwater to Ebey Slough under the CGP coverage, the permit tracking number assigned to the project is WAR311241. Based upon my review within Ecology's Permitting and Reporting Information System (PARIS), the initial permit application (notice of intent) was submitted on April 6, 2022, by Mr. Aaron Kopet, Vice President of Toll Brothers, Inc. Permit coverage was effective on May 13, 2022. No prior EPA/Ecology inspection/enforcement activity had been previously documented. Page 2 of 23 SECTION II - OBSERVATIONS Site Review 2024 CWA NPDES WAR311241 Inspection Report The Project consists of developing a 9.85 acres site into a housing subdivison, including 23 single-family residential lots and neighborhood park/play area(s). The Project's development also includes public-rights-ofway, associated driveways, utilities, landscaping, and frontage improvements. Total disturbed acreage for the Project is 5.54 acres, with topography sloping to the west. See Attachment A, Site Plans. Prior to construction, the acreage included several structures, including a house, barn, shed, and a gravel driveway. Existing vegetation included trees grass and brush. A prior manmade wetland area is also located/maintained within the central portions of the Project boundary. Construction activities over the life of the Project generally include site preparation, demolition, excavation for utilities, foundations, grading, utility installation, asphalt paving concrete pours and landscaping. Stormwater infrastructure includes a primary collection system (underground pipes and a series catch basins) that convey runoff to an engineered stormwater vault located in the northwest corner of the property. The stormwater vault discharges into the City of Lake Steven's MS4, and ultimately into the Snohomish River via Ebey Slough. Ebey Slough is located just west of the Project. At the time of inspection, the majority of site was well established. Frontage work/landscaping and sidewalks/curbing was generally complete. Utility installation and stormwater infrastructure had been installed in 2023, and several lots had started vertical construction. In general, undeveloped housing lots were well stabilized from 2023 hydroseeding. According to Mr. Acker, approximately one-half of the Project's housing lots had already been sold. Approximately 4-houses were being constructed each month. Following the opening conference, we began the site walk-through. We started at the northeast corner of the Project, the area with the highest elevation. Photographs taken during the walk-through are attached to this inspection report as Attachment B, Photograph Log. Walk-Through Observations: Location: Eastern Construction Areas Observation #: OB-001 To reach the northeast corner of the site we first walked upslope through the construction site, via the 72nd Ave. SE and "Road B." We arrived at the northeast corner/perimeter; a wooded area that would remain undisturbed. Mr. Acker discussed that this eastern perimeter of the site was generally left as a nature area for the future residents. From this eastern location, we observed the three eastern housing lots located along the southern perimeter (Photo 1). The three housing lots were undeveloped and well stabilized after being hydroseeded in 2023. We then walked west, towards the eastern culdesac loop and observed the Project's easternmost catch-basin (Photo 2). Mr. Acker discussed that all catch basins were currently tied into the stormwater drainage system discharging to the local MS4. It was observed that the easternmost catch basin had no inlet protection. Mr. Acker discussed that all catch basins for the Project should be equipped with sediment/filter fabric and that in this instance, it must have recently been removed to perform concrete repair work on the associated curbing. Mr. Acker discussed that he would ensure that the sediment/filter fabric was re-installed. It was noted that the area upslope of the catch basin was either paved or well stabilized. We continued west along the culdesac loop and observed another roadside catch basin, located on the south side of the road along the western area of the culdesac loop (Photo 3). Sediment/filter fabric was installed Page 3 of 23 2024 CWA NPDES WAR311241 Inspection Report within the catch basin. According to Mr. Acker, sediment/filter fabric installed within the Project's catch basins are changed out as needed by on-site staff. Mr. Acker also explained that he conducts a weekly site/BMP inspection, typically every Friday. Location: Central Construction Areas Observation #: OB-002 We continued west along "Road B" and observed the completed landscaped areas to the south. We also observed a wetland area (Photo 4) within the Project boundary. Mr. Acker discussed that the wetland area was manmade prior to the Project's development. The Project now maintains the wetland area and has installed temporary irrigation to help establish the newly planted landscaped areas, east of the wetland. Within the central construction areas, we then observed the northern perimeter. In general, vacant housing lots north of "Road B" were well stabilized having been hydroseeded in 2023 (Photo 5). Existing fencing extended along the northern perimeter within the stabilized areas. From this central area, the site begins to slope steeply to the west. We observed the Project's job-site trailer and another roadside catch basin on the north side of "Road B" (Photo 6). From this location we also observed the western portions of the site, where much of the active construction was occuring at the time of inspection. Several housing lots had started vertical construction (Photo 7 & Photo 8). Location: Eastern Construction Areas & Discharge Location Observation #: OB-003 We then continued west, downslope via "Road B" until we arrived back to 72nd Ave SE. and observed the dedicated concrete washout area (Photo 9). Mr. Acker discussed that the washout area has worked well but would need to be emptied soon as it was approaching capacity. We observed several material stockpiles in the area covered with plastic sheeting, one area of plastic sheeting was observed to be in need of maintenance to ensure continued coverage. We then continued north, along 72nd Ave SE to the northern perimeter. Mr. Acker discussed that due to the steep slopes within this project area, the area had previously experienced flooding into a neighboring lot. Construction staff was working to improve the curbing, to ensure stormwater is fully captured within two roadside catch basins connecting to the stormwater drainage system (Photo 10 & Photo 11). From this area we also observed the completed construction areas to the west, including the four model homes and constructed park/play structure (Photo 12). Mr. Acker discussed that the stormwater vault infrastructure was installed below the park/play structure. We observed various access points to the stormwater vault along the north side of the play structure. We continued to the northwest perimeter, along 71st Ave SE to an underground vault structure east of the 71st Ave SE sidewalk. Mr. Acker discussed that within the vault is the project's outfall/monitoring location, a discharge pipe extends into the City of Lake Steven's MS4 system. It was discussed that Mr. Acker monitors Turbidity from this location, using a sample bottle and pole. The discharge pipe enters the vault from the east, the City of Lake Steven's MS4 piping extends south to north (Photo 13). Mr. Acker called Mr. Weisenstein at the time of inspection to confirm the flow paths. We observed Project's discharging at the time of inspection, as water was leaving the discharge pipe and entering the MS4 stormwater vault. The discharge was observed to be clear; however, accumulated sediment Page 4 of 23 2024 CWA NPDES WAR311241 Inspection Report was observed within the Project's discharge pipe. Mr. Acker was unsure of when sediment would have been deposited within the discharge piping. It was discussed that no benchmark exceedances had been recorded. We returned to the Project's main stormwater vault location (Photo 14), and then back to the central construction areas. We observed a foundation to be actively under construction within a housing lot. It was discussed that a French drain was installed belowground, along the western perimeter to capture stormwater (Photo 15). Mr. Acker discussed that the French drain system was connected to the stormwater vault/collection system. I discussed that BMPs should be considered for the unworked/exposed soils at the location, due to the proximity of the French drain. We continued back upslope to the east and observed another housing lot under active construction. Straw had been applied to exposed soils (Photo 15). The inspection walk-through concluded as we arrived back at the Project's job-site trailer to conduct the records review. SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: Stormwater Pollution Prevention Plan (SWPPP) Reference #: RR-001 The Project's SWPPP binder was located within the job-site trailer and was brought out by Mr. Acker. The SWPPP was prepared by "The Blueline Group. Inc.," on May 25, 2022. The SWPPP narrative include the 13 required elements contained with the permit. The SWPPP binder also included a current version of the permit and Notice of Permit Coverage Letter. Within the SWPPP narrative, there was a statement regarding 303(d) and/or Total Maximum Daily Load (TMDL) for the receiving waterbody: "A mistake was made in Washington State Water Quality Assessment listings, pH and DO levels were listed as impairments in 1997, however, remarks state that the listings were errors, and the measurements were within the natural conditions of the water body. Therefore, there is a no known impairments in any receiving waterbodies downstream from this site." Record: SWPPP Site Map Reference #: RR-002 The Project's Site Map was located on the wall within the job-site trailer (Photo 16). The Site Map included numerous BMP locations as well as BMP implementation dates. It was noted that the sampling/monitoring location and the concrete washout area were not identified within the Site Map. We discussed the permit requirements associated with the Site Map and the tracking of BMP implementation and maintenance. Record: Routine Site Inspection Reports Reference #: RR-003 Routine Site Inspection Reports were available at the time of inspection. Inspection reports are completed and stored electronically by the permittee within an internal task management system. It was discussed that site inspection reports are completed using corporate checklist/template following each inspection. Site inspections were primarily conducted weekly by Mr. Acker. The most recent inspection report was completed on March 8, 2024. Site Inspection Reports were reviewed for 2024 and occurred on the following dates: 03/08/2024, 03/01/2024, 02/23/2024, 02/16/2024, 02/09/2024, 02/02/2024, 01/26/2024, 01/19/2024, 01/12/2024 and 01/04/2024. Page 5 of 23 2024 CWA NPDES WAR311241 Inspection Report It was noted that the checklist was a series of yes/no questions regarding general permit items, BMP conditions and BMP maintenance activities. It was also noted that sampling events are not recorded on the checklist. See Attachment C, 01/05/2024 Site Inspection Report, as a checklist example. Record: Discharge Monitoring Reports (DMRs) Reference #: RR-004 DMR's for the Project were reviewed pre-inspection using Ecology's Permitting and Reporting Information System (PARIS). I reviewed DMR's applicable at the time of inspection (June 2022 - December 2023). The January 2024 and February 2024 DMRs were not available within PARIS. DMR's were submitted by the current "Responsible Official," Mr. Weisenstein, or previously by Mr. Aaron Kopet. The review indicated that the Project routinely discharges, and that turbidity sampling/monitoring occurs. No benchmark exceedances had been reported. It was also observed that no pH sampling/monitoring was being conducted for the Project. Within the DMRs, during sampling events the pH monitoring field was either marked with the reporting code "M" or left blank. Reporting code "M" is defined as "Monitoring is Conditional/Not Req this MP." Several DMRs were flagged within PARIS as "late submittal," including December 2023, October 2023, September 2023, February 2023, and September 2022. At the time of inspection, Mr. Acker discussed that when a turbidity sample is collected, it is then analyzed onsite, and the value is entered directly into the DMR at that time. Mr. Acker demonstrated the DMR entry process from his computer and provided me with a printed copy of the January 2024 and February 2024 DMRs (Attachment D). It was discussed that the January 2024, and February 2024 DMRs had been completed by Mr. Acker but were awaiting official submittal/signature by Mr. Weisenstein. When asked about pH sampling/monitoring, Mr. Acker discussed that pH sampling/monitoring hadn't occurred. We then discussed the permit requirements regarding pH sampling. In the discussion, Mr. Acker estimated that over 1000 cubic yards of concrete would be used for the Project. When asked to view the Project's turbidity meter, Mr. Acker stated that the meter wasn't currently on-site, as it was being temporarily used/borrowed at another construction site. SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted for this inspection. SECTION V - AREAS OF CONCERN Area(s) of Concern may not be in sequential order. The presentation of Area(s) of Concern (AOC) does not constitute a formal compliance determination or violation. AOC Reference #: AOC-001 Records Reference #: RR-004 (pH Sampling) Regulation and/or Permit Requirement: Page 6 of 23 2024 CWA NPDES WAR311241 Inspection Report Permit Condition S4.D. describes the pH sampling requirement if construction activity results in the "disturbance of 1 acre or more and involves significant concrete work (significant concrete work means greater than 1000 cubic yards placed or poured concrete or recycled concrete used over the life of a project)." Permit Condition S4.D.1. states: "The Permittee must perform pH analysis on site with a calibrated pH meter, pH test kit, or wide range pH indicator paper. The Permittee must record pH sampling results in the site logbook." Permit Condition S4.D.2. states: "During the applicable pH monitoring period defined below, the Permittee must obtain a representative sample of stormwater and conduct pH analysis at least once per week. a. For sites with significant concrete work, the Permittee must begin the pH sampling period when the concrete is first placed or poured and exposed to precipitation, and continue weekly throughout and after the concrete placement, pour and curing period, until stormwater pH is in the range of 6.5 to 8.5 (su)." AOC: As discussed earlier within this report, DMR's for the Project were reviewed pre-inspection using Ecology's Permitting and Reporting Information System (PARIS). It was observed that no pH monitoring/sampling was being reported. During sampling events the pH monitoring field within the DMR was either marked with the reporting code "M" or left blank. Reporting code "M" is defined as "Monitoring is Conditional/Not Req this MP." At the time of inspection, when asked about pH sampling/monitoring, Mr. Acker discussed that pH sampling/monitoring hadn't occurred. We then discussed the permit requirements regarding pH sampling. In the discussion, Mr. Acker estimated that over 1000 cubic yards of concrete would be used for the Project. The concern is that based upon the permit language, pH monitoring may be applicable for the Project and pH monitoring is not being conducted. AOC Reference #: AOC-002 Records Reference #: RR-004 Discharge Monitoring Reports Regulation and/or Permit Requirement: Permit Condition S5.B Discusses "Permittees required to conduct water quality sampling in accordance with Special Conditions (S4.C (Turbidity/Transparency), S4.D (pH), S8 (303[d]/TMDL sampling), and/or G12 (Additional Sampling) must submit the results to Ecology. Permittees must submit monitoring data using Ecology's WQWebDMR web application accessed through Ecology's Water Quality Permitting Portal." "Permittees must submit DMR forms to be received by Ecology within 15-days following the end of each month." AOC: As discussed earlier within this report, DMR's for the Project were reviewed pre-inspection using Ecology's Permitting and Reporting Information System (PARIS). Several DMRs were flagged within PARIS as "late submittal," including December 2023, October 2023, September 2023, February 2023, and September 2022. The December 2023 DMR was submitted on February 26, 2024. The October 2023 and September 2023 DMR were submitted on December 4, 2023. The February 2023 DMR was submitted on April 13, 2023. The September 2022 DMR was submitted on November 6, 2022. At the time of inspection, the January 2024 DMR had yet to be submitted. It was discussed that the January Page 7 of 23 2024 CWA NPDES WAR311241 Inspection Report 2024 DMR (and February 2024) had been completed by Mr. Acker but were awaiting official submittal/signature by Mr. Weisenstein. Mr. Acker provided me with a printed copy of the January 2024 and February 2024 DMRs that were complete but had yet to be submitted (Attachment D). The concern is the late submittal of the DMRs based upon the permit language. AOC Reference #: AOC-003 Records Reference #: RR-003 (Site Inspection Reports) Regulation and/or Permit Requirement: Permit Condition S4.B.4 states: "The Permittee must summarize the results of each inspection in an inspection report or checklist and enter the report/checklist into, or attach it to, the site logbook. At a minimum, each inspection report or checklist must include: a. Inspection date and time. b. Weather information. c. The general conditions during inspection. d. The approximate amount of precipitation since the last inspection. e. The approximate amount of precipitation within the last 24 hours. f. A summary or list of all implemented BMPs, including observations of all erosion/sediment control structures or practices. g. A description of: i. BMPs inspected (including location). ii. BMPs that need maintenance and why. iii. BMPs that failed to operate as designed or intended, and iv. Where additional or different BMPs are needed, and why. h. A description of stormwater discharged from the site. The Permittee must note the presence of suspended sediment, turbidity, discoloration, and oil sheen, as applicable. Construction Stormwater General Permit Page 12 i. Any water quality monitoring performed during inspection. j. General comments and notes, including a brief description of any BMP repairs, maintenance, or installations made following the inspection. k. An implementation schedule for the remedial actions that the Permittee plans to take if the site inspection indicates that the site is out of compliance. The remedial actions taken must meet the requirements of the SWPPP and the permit. l. A summary report of the inspection. m. The name, title, and signature of the person conducting the site inspection, a phone number or other reliable method to reach this person, and the following statement: I certify that this report is true, accurate, and complete to the best of my knowledge and belief. AOC: As discussed earlier within this report, Routine Site Inspection Reports were available and reviewed at the time of inspection. Inspection reports are completed and stored electronically by the permittee within an internal task management system. It was discussed that site inspection reports are completed using corporate checklist/template following each inspection. It was noted that the checklist was a series of yes/no questions regarding general permit items, BMP conditions and BMP maintenance activities. It was also noted that sampling events are not recorded on the checklist. See Attachment C, 01/05/2024 Site Inspection Report, as a checklist example. The concern is that the Project's Site Inspection Report checklist/template does not appear to include the majority of the permit required elements (i.e., approximate amount of precipitation since the last inspection, a summary or list of all implemented BMPs, including observations of all erosion/sediment control structures or practices, a description of BMPs inspected (including location, a description of stormwater discharged from the Page 8 of 23 site, any water quality monitoring performed during the inspection. 2024 CWA NPDES WAR311241 Inspection Report AOC Reference #: AOC-004 Observation Reference #: OB-003 Accumulated Sediment Within Discharge Pipe AOC: As discussed earlier within this report, while observing the Project's discharge location. The Project's discharge was observed to be clear; however, accumulated sediment was observed within the Project's discharge pipe (Photo 13). Mr. Acker was unsure of when sediment would have been deposited within the discharge piping. It was discussed that no benchmark exceedances had been recorded. The concern is the presence of the of accumulated sediment within the Project's discharge pipe. SECTION VI - CLOSING CONFERENCE AND POST INSPECTION CORRESPONDENCE Closing Conference Following the walk-through of the construction areas and the records review, a closing conference was held with Mr. Acker. We discussed our general observations the potential areas of concern. I then thanked him for his time and cooperation with the inspection. Post Inspection Correspondence Post-inspection on March 15, 2024, I followed up with an email to Mr. Weisenstein recapping the general inspection activities that had occurred and the potential areas of concern discussed with Mr. Acker. I also provided a copy of EPA's Small Business Resources Information Sheet. SECTION VII - LIST OF APPENDICES Attachment A - Site Plans Attachment B - Photograph Log Attachment C - 01/05/2024 Routine Site Inspection Report Attachment D - January 2024 & February 2024 Discharge Monitoring Reports Page 9 of 23 2024 CWA NPDES WAR311241 Inspection Report Attachment A Site Map Page 10 of 23 2024 CWA NPDES WAR311241 Inspection Report Page 11 of 23 2024 CWA NPDES WAR311241 Inspection Report Attachment B Photograph Log All Photographs taken by Jon Klemesrud on March 14, 2024 Nikon Coolpix AW100 Page 12 of 23 2024 CWA NPDES WAR311241 Inspection Report Photograph Log - Vinje Hill Estates Photo #:01 (DSCN3602) Description: Facing west, photo from within wooded area of northwest project boundary. Wooded area is being maintained as a walking/pet area. Three lots to the south were undeveloped and well stabilized after being hydroseeded in 2023. Photo #:02 (DSCN3603) Description: Facing southwest, photo of easternmost catch basin. Catch basin is located upslope of active construction areas near stabilized landscaping areas. Concrete repair work recently conducted at the location. No inlet protection observed. Photo #:03 (DSCN3604) Description: Facing west, photo of roadside catch basin located west of the culdesac roadway. Filter fabric installed within the catch basin. Surrounding housing lots well stabilized with hydroseeding/landscaping. Photo #:04 (DSCN3605) Description: Facing southwest, photo of wetland area near the upper/eastern construction areas Mr. Acker discussed that he had been told the wetland area was manmade. Landscaped area/wetland is irrigated for maintenance. Page 13 of 23 2024 CWA NPDES WAR311241 Inspection Report Photograph Log - Vinje Hill Estates Photo #:05 (DSCN3606) Description: Facing northwest, photo of stabilized north housing lots awaiting construction. Photo #:06 (DSCN3607) Description: Facing east, photo of job-site trailer and roadside catch basin. Catch basin was equipped with inlet protection/fabric filter. Frontage areas landscaped. Photo #:07 (DSCN3608) Description: Facing west, photo of southern in active construction phase. Photo #:08 (DSCN3609) Description: Facing west, photo of northern lots starting in active construction. Page 14 of 23 2024 CWA NPDES WAR311241 Inspection Report Photograph Log - Photograph Log - Vinje Hill Estates Photo #:09 (DSCN3610) Description: Facing west, photo of designated concrete washout area. Photo #:10 (DSCN3611) Description: Facing east, photo of newly constructed curbing to assist with stormwater capture to drainage system. Fiber wattles, sandbags and inlet protection observed at catch basin. Photo #:11 (DSCN3612) Description: Facing south, photo of sidewalk and construction areas from the northern perimeter. Photo #:12 (DSCN3613) Description: Facing west, photo of constructed park/play structure. Stormwater vaults located underneath the park/play structure to the north. Outfall to the west. Page 15 of 23 2024 CWA NPDES WAR311241 Inspection Report Photograph Log - Photograph Log - Vinje Hill Estates Photo #:13 (DSCN3614) Description: Photo of discharge/monitoring location and connection to Lake Steven's MS4. Discharge observed to be clear at the time of inspection. Accumulated sediment within the discharge pipe. Photo #:14 (DSCN3615) Description: Facing east, photo of constructed park/play structure located in the northwest corner of the Project. Photo #:15 (DSCN3616) Description: Facing south, photo of housing lot foundation under construction. French drain installed underground, west of the foundation. French drain connected to stormwater collection system. Photo #:16 (DSCN3617) Description: Facing north, photo of straw coverage on unstabilized portion of newly constructed housing lot. Page 16 of 23 2024 CWA NPDES WAR311241 Inspection Report Photograph Log - Photograph Log - Vinje Hill Estates Photo #:17 (DSCN3618) Description: Photo of the SWPPP Site Map within the Project's job-site trailer. Other Photographs Not Included: DSCN3619: SWPPP (Page 1) DSCN3620: SWPPP (Page 2) DSCN3621: SWPPP (Page 3) DSCN3622: Permit Coverage Certification DSCN3623: SWPPP (Page 4) DSCN3624: SWPPP (Page 5) DSCN3625: SWPPP (Page 6) DSCN3626: SWPPP (Page 1) Page 17 of 23 2024 CWA NPDES WAR311241 Inspection Report Attachment C 01/05/2024 Routine Site Inspection Report Page 18 of 23 2024 CWA NPDES WAR311241 Inspection Report Page 19 of 23 2024 CWA NPDES WAR311241 Inspection Report Page 20 of 23 2024 CWA NPDES WAR311241 Inspection Report Attachment D January 2024 and February 2024 Discharge Monitoring Reports Page 21 of 23 2024 CWA NPDES WAR311241 Inspection Report Page 22 of 23 2024 CWA NPDES WAR311241 Inspection Report Page 23 of 23