Document 91jp6a1q3DygXaqx0zVpOREVV

Ref: 8 Montana SENT VIA EMAIL DIGITAL READ RECEIPT REQUESTED Traditional Homes, LLC 36332 Fulkerson Lane Polson, Montana 59860 Re: Inspection Report for Hillcrest Development/Traditional Homes, LLC, MTR10I050 Dear : On November 13, 2024, a representative of the U.S. Environmental Protection Agency inspected the Hillcrest development construction site in Polson, Montana, to evaluate compliance with the site's National Pollutant Discharge Elimination System permit for stormwater construction discharges. The inspection was conducted under the authority of Section 308 of the Clean Water Act (Act). Enclosed is a report of the inspection. Inspection findings are summarized within the enclosed inspection report in a table titled "Findings, Corrective Actions and Recommendations." Within thirty (30) days of receipt of this report, please provide the EPA with a summary of corrective actions taken to address each of the findings identified in the report and any information that may change the findings or content of the report. This summary should be sent to: U.S. EPA Region 8 (8 Montana) NPDES and Wetlands Enforcement Section Helena, MT 59626 Confederated Salish and Kootenai Tribes Acting Environmental Division Director Polson, MT Finding #2: Traditional Homes did not have required documents on-site. Specifically, a copy of the SWPPP and associated site map was not available for review. Permit requirement: Part 7.3 of the general permit states, "You must keep a current copy of your SWPPP at the site or at an easily accessible location so that it can be made available at the time of an on-site inspection...." Part 7.2.4 of the general permit includes a site map as part of the SWPPP. Part 7.4.1 of the general permit states, "You must modify your SWPPP, including the site map(s), within seven (7) days of any [changes or updates to the site]." Corrective Action: Ensure an up-to-date copy of the SWPPP and site map are maintained so they are available for on-site inspections. In a response to this report, provide EPA and the Tribes with an updated copy of the SWPPP and site map (electronic format is acceptable). Finding #3: Inspections were not being completed and/or documented. Specifically, inspections were not being conducted or documented as required. Permit requirement: Part 4.0 of the general permit includes the requirements of who is responsible for conducting inspections, the frequency of inspections, and documenting the inspections. Part 7.2.7 of the general permit includes the procedures for inspection schedule, maintenance, and corrective actions as part of the SWPPP. Corrective Action: Ensure on-site inspections are being conducted at the required frequency and are being documented and retained as required. Identify and implement any corrective actions identified during inspections within the required timeframe. In the response to this report, provide EPA and the Tribes with one month of weekly inspection reports in accordance with permit requirements. Finding #4: Best Management Practices were not installed to minimize the discharge of sediment. Specifically, there is an area of disturbance located at northwest of the staging area and northeast of the temporary retention pond where no BMP has been installed to control sediment-laden stormwater from leaving the site and entering the property adjacent to the project area. As a result, there is a potential for a discharge of pollutants in stormwater from construction activities. BMPs must be implemented and maintained to minimize potential pollutants in storm water discharges. Permit requirement: Part 2.1 of the general permit states, "You must design, install, and maintain stormwater controls required in Parts 2.2, 2.3, and 2.4 to minimize the discharge of pollutants in stormwater from construction activities." Traditional Homes - Hilcrest Development MTR10I050 Page 5 of 7 Corrective Action: In the response to this report, provide EPA and the Tribes with a description of the corrective actions taken to address this finding. Provide photographic evidence documenting the corrective action when complete. Finding #5: Best Management Practices were not properly installed. Specifically, the silt fence fabric was not installed consistently with a minimum of six inches in the ground, soil was pushed up on the fabric in place of compacted backfill, and ends of silt fence were not properly overlapped (photos 106, 111 and 112). As a result, there is a potential for a discharge of pollutants in stormwater from construction activities. Please note: BMPs are required to be designed, installed, and maintained in effective operating condition. Permit requirement: Part 2.1 of the general permit states, "You must design, install, and maintain stormwater controls required in Parts 2.2 2.3, and 2.4 to minimize the discharge of pollutants in stormwater from construction activities." Part 2.1.2 of the general permit states, "Design and install all stormwater control in accordance with good engineering practices, including applicable design specifications." Part 5.1 of the general permit states, "You must take corrective action to address any of the following condition identified at your site: ... 5.1.2 A stormwater control necessary to comply with the requirements of this permit was never installed, or was installed incorrectly..." Corrective Action: The BMP must be re-installed per the design specifications. In the response to this report, provide EPA and the Tribes with a description of the corrective actions taken to address this finding. Provide photographic evidence documenting the corrective action when complete. Finding #6: Installed Best Management Practices were not being maintained. Specifically, silt fence had slack and/or torn fabric, stakes were not upright and broken (photos 106, 111 and 112). As a result of improper BMP maintenance, there is a potential for a discharge of pollutants in stormwater from construction activities. BMPs must be implemented and maintained to minimize the discharge of sediment from the project area. Permit requirement: Parts 2.1, of the general permit states, "You must design, install, and maintain stormwater controls required... to minimize the discharge of pollutants in stormwater from construction activities." Part 2.1.2 of the general permit states, "Design and install all stormwater control in accordance with good engineering practices, including applicable design specifications." Part 2.1.4 of the general permit states, "Ensure all stormwater controls are maintained and remain in effective operating condition during permit coverage and are protected from activities that would reduce their effectiveness." Traditional Homes - Hilcrest Development MTR10I050 Page 6 of 7 Part 5.1 of the general permit states, "You must take corrective action to address any of the following condition identified at your site: ... 5.1.1 A stormwater control needs a significant repair or a new or replacement control is needed...." Corrective Action: The silt fence BMP requires maintenance and repair. In the response to this report, provide EPA and the Tribes with a description of the corrective actions taken to address this finding. Provide photographic evidence documenting the corrective action when complete. Finding #7: Polson B canal discharge location. During the inspection, stated the Polson B canal ends within the Polson Bay Golf Course. Follow up: If available, provide any information concerning the current path of the Polson B canal from the construction site to its end point. Traditional Homes - Hilcrest Development MTR10I050 Page 7 of 7