Document 65vgLabe3RyonEGZ0Vq82Xv1
UNITED STATESUNITED STATES ENVIRONMENTAL PROTECTION AGENCY
* *REGION 1
ENVIRONMENTAL
AGENCY5 POST OFFICEB OSSTQOUN,A RMAE ,0 21S0U9-I3T9E12
100
PROTECTION
Drafted Date:24 Sept 2021
Finalized Date:15 Oct 2021
Subj:Inspection Report
Clean Water Act - National Pollutant Discharge Elimination
System (" NPDES ")
Laurel Hill Estates Construction
From:Andrew Spejewski, Enforcement Officer
Thru:Neil Handler, Senior Enforcement Coordinator
To:File
I. Facility Information
A. Facility Name:Laurel Hill Estates Construction
B. Facility Location: 2038 Lunenburg Road
Lancaster, MA 01523
C. Facility Contacts:Ron Koivu, President
Harbor Classic Homes LLC
rek64@yahoo.com
James Rheault, Site Engineer
jrheault@whitmanbingham.com
D. NPDES ID No (s).: MAR10036S
II. Background Information
A. Date(s) of inspection: September 17, 2021
B. Weather Conditions: Clear, dry
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
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E. Federally Enforceable Requirements Covered During the Inspection: 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
Evaluation of compliance with the 2017 Construction General Permit
IV. Facility Description
The site is a construction project planned as a residential development, lying west of
Lunenburg Road. The site slopes down to the east towards the road, and slightly down to
the north along the road, as well as slightly down to the south at the extreme southern end
of the site.
A road enters from Lunenburg Road about 20 yards from the southern end of the site.
The road goes west uphill, then turns north to the northwest end of the site.
In the southeast corner (south of the road entrance), there are large stockpiles and a large,
deep retention basin. A permanent retention basin is planned for the northeast corner of
the site, but at the time of the inspection it was not completed.
At the time of the inspection, the entire area adjacent to Lunenburg Road had been
cleared and at least partially graded, as well as the road (and a short area on either side of
the road). The road was graded dirt, with some gravel, and catch basins were in place.
V. Inspection
Before the inspection, Mr. Koonce told Mr. Spejewski he had contacted the site owner
and arranged to meet at the site with Mr. Rheault, the Site Engineer.
Mr. Spejewski, Mr. Koonce, and Mr. Christopher arrived at the site about 11:00 AM.
There, they met Mr. Rheault.
A. Opening Conference
Mr. Spejewski presented his credentials, provided a copy of the Small Business
Information Sheet and explained the purpose of the inspection.
Mr. Rheault explained that he had just been hired as the engineer for the site. He said
that at the moment the only plans for the site were to stabilize everything for the winter.
According to Mr. Koonce the site had been a mix of forest and open field before the
project.
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B. Records Review
Mr. Spejewski asked about a SWPPP [Stormwater Pollution Prevention Plan] for the site.
Mr. Rheault said that he did not at the moment have a copy of the existing SWPPP, and
that he would be preparing a new one for the site. Mr. Rheault said he would get a copy
of the current SWPPP and email it to Mr. Spejewski. [Note: On September 17, Mr.
Rheault emailed a copy of the SWPPP to Mr. Spejewski].
C. Facility Tour
The group toured the site.
The site entrance, between Lunenburg Road and the site road, has a layer of gravel, with
no sediment accumulation.
The site road was dirt with some gravel. Catch basins were in place, with catchbasin top
openings at the grade of the road in most cases, and filter fabric inserts in each catch
basin.
The road had (fairly new looking) crushed stone check dams at several places; there was
sediment accumulated behind each dam. There was some erosion of the road, into very
small gullies; it was not clear whether the erosion pre - dated the check dams.
Along the central part of the road, after it turned to the north, the north side of the road
was a slope up away from the road which had been cleared for 10 to 20 yards. Past the
clearing was well - established grass and weeds. The slope had clear signs of erosion with
small gullies forming.
The road sloped slightly up as it went north to roughly the middle of the site, then sloped
slightly down to the north from there. Check dams were in place on the northern slope
down, too.
A retention basin was in place east of the road, near the north - south midpoint of the road.
The basin was formed of crushed - stone walls, on the downhill side of the road. Turbid
water remained in the basin. In the woods below the basin, disturbances in leaves and
debris appeared to indicate past flow through the area, but little or no sediment deposits
were observed.
The road ended at the north in a widened turn - around. The area around the road had been
cleared and graded; established grass was in place up to the edge of the unpaved road.
The southern edge of the site was next to a pre - existing housing development; the road
for the pre - existing development was slightly raised above the level of the site (at least at
the western half of the southern border). Flow from the southern part of the road and
nearby areas led around a stockpile to a flat area and then appeared to flow east towards
the large retention basin in the southeast.
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The large retention basin in the southeast had a small amount of standing water. It was
surrounded by various stockpiles, none stabilized or otherwise protected, and flat areas of
bare dirt. No signs of overflow from the basin could be seen. The bare dirt walls of the
basin did not show significant erosion (possibly indicating a fairly recent installation).
North of the site road, next to Lunenburg Road, a flow channel had been constructed
from the road leading to a moderately large retention basin. Like the retention basin to
the southwest, it had some standing water, and the bare earth walls appeared fairly new.
North of that retention basin was the outfall from site drainage. Mr. Rheault stated that
this was the planned location of the site's permanent stormwater basin. Mr. Rheault said
that the excavator had begun construction, but after hitting clay, stopped. Mr. Koonce
said that the site had discharged turbid stormwater from this point during a storm in the
summer.
At the time of the inspection, the concrete outfall led to a small basin formed of crushed
stone walls. Outside of the basin was an area with well - established grass and two rows of
wood - mulch berms.
D. Closing Conference
Mr. Spejewski noted the lack of stabilization over much of the site. Mr. Rheault said that
stabilizing the site and re - designing the permanent basin were his only priorities at this
point. Mr. Spejewski thanked Mr. Rheault for his time and left the site.
Picture List:
IMG 2476.JPGFacing east to Lunenburg Road over site entrance
IMG 2477.JPGFacing south from north of site entrance
IMG 2478.JPGFacing north to stockpile, from near site entrance
IMG 2479.JPGCatch basin, on slope east of entrance
IMG 2480.JPGCheck dam on road, uphill from entrance
IMG 2481.JPGFacing northwest along west side of road
IMG 2482.JPGCheck dam in central (north - south) part of road
IMG 2483.JPGBasin south of central part of road
IMG 2484.JPGWoods below basin south of road
IMG 2485.JPGFacing north to end of road
IMG 2486.JPGFacing south, drainage at southwest corner of site
IMG 2487.JPGSouth edge of site (west end)
IMG 2488.JPGFacing north over basin at southeast of site
IMG 2489.JPGFacing northeast over basin at southeast of site
IMG 2490.JPGFacing north over temporary basin in center - east
IMG 2491.JPGFacing north of site of permanent basin
* END *
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
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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.
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