Document G5VRbD5QqX6jwN57yYaDrjyGV

UNITED STATESUNITED STATES ENVIRONMENTAL PROTECTION AGENCY * *REGION 1 ENVIRONMENTAL AGENCY5 POST OFFICEB OSSTQOUN,A RMAE ,0 21S0U9-I3T9E12 100 PROTECTION Date:Dated as shown on electronic signature(s) Subj:Inspection Report Clean Water Act - National Pollutant Discharge Elimination System (" NPDES ") SPS New England DAMIANDigitally signed by From:Damian Bednarz, InspectorDAMIAN BEDNARZ Date: 2023.10.02 13:56:22 BEDNARZ -04'00 ' Thru:Alex Rosenberg, Inspector To: File I. Facility Information A. Facility Name:SPS New England B. Facility Location:95 Behen Street Everett, MA 02149 C. Facility Contacts: Greg Bashaw, Ship Captain D. NPDES ID No (s).: NA, unpermitted II. Background Information A. Date(s) of inspection: August 16, 2023 B. Weather Conditions: 72 , cloudy C. US EPA Representative(s): Alex Rosenberg, Damian Bednarz D. State / Local Representative(s): NA E. Federally Enforceable Requirements Covered During the Inspection: 40 C.F.R. 122.26-NPDES Multi - Sector General Permit (" MSGP ") for Stormwater Discharges Associated with Industrial Activity (issued January 15, 2021, modified September 29, 2021) F. Previous Enforcement Actions: None known ED_019088A_00003952-00001 III. Type and Purpose of Inspection Evaluation IV. Facility Description SPS New England (the " Facility ") is a contract construction company staged in Everett, MA. The Facility specializes in bridge, highway, transit, and marine construction projects. Equipment necessary for construction projects are loaded onto barges and are sent to the project destination. The Facility stages multiple tugboats and barges as well as equipment on standby should a project require it. The Facility footprint is approximately 2 acres. To the west of the Facility is the Island End River, which flows into the Mystic River located about 2,000 feet downstream to the South. V. Inspection EPA Inspectors Alex Rosenberg and Damian Bednarz (" Inspector Team ") arrived at approximately 12 PM. A. Opening Conference Inspector Team was greeted by SPS Construction's ship captain, Greg Bashaw. Mr. Rosenberg explained the reason for the inspection which involved an anonymous complaint sent to EPA of a pressure washing operation resulting in paint chips escaping the Facility boundaries. Mr. Bashaw explained that SPS New England (the " Facility ") owns 5 tugboats and 5 construction barges, and that these vessels are maintained at a shipyard in Newburyport, MA. About 20 feet away from where the Inspector Team was standing, one tugboat, approximately 40 feet in length, was propped up on metal stilts and wood beams. Mr. Rosenburg asked about the nature of the work being conducted on the tugboat. Mr. Bashaw stated that a power washing operation was occurring on the tugboat's underside to remove its paint in order to then repaint. The Facility had decided to conduct engine work at this location at the same time, rather than the shipyard in Newburyport, because of its relatively small size compared to the rest of the fleet. Mr. Bashaw explained that power washing and engine work are not typical operations that occur at the Facility, and that this work was temporary. Mr. Bashaw also mentioned that the Facility does not conduct any kind of cargo loading or unloading, and that their main function was to load equipment and construction supplies onto barges for various projects. B. Facility Tour The Inspector Team observed the propped - up tugboat with deteriorating paint on its underside (slide 1, 2). Mr. Bashaw mentioned that the power washing operation is not complete yet, and that the crew would return after their lunch break to continue working on it. Red paint residue was observed on the pavement below the tugboat (slide 3). Inspector Team also observed red colored water and paint residue flowing into a long 2 ED_019088A_00003952-00002 drainage channel covered by grates (slides 4-6). This same red colored water appeared to be stagnant within the drain at the time of observation (slide 7). The drain system continues towards the neighboring property beyond a chain - link fence (slides 10, 11) to the North and then passes through a parking lot. To the South, the drain leads towards the Facility storage areas (slide 12). The total length of this drain is about 800 feet from one end to another. Mr. Rosenberg asked about the purpose of this drainage system and where it discharges. Mr. Bashaw stated that, based on his understanding, waters captured here are contained under the concrete and do not daylight into the nearby river. Further, Mr. Bashaw stated that he did not know about the capacity of the system, what organization manages it, or how often the wastewaters are disposed of. He explained that all he knew was that the system was designed to specifically capture waste that might seep from the remediated superfund site over which the property is located, and that it is therefore permissible to allow tainted waters, such as pressure waters, to enter it. Mr. Bashaw recommended contacting the city of Everett to find out more about the drains. Mr. Bednarz and Mr. Bashaw investigated the Facility boundary with Island End River. Mr. Bednarz observed floating debris and particulates in the water (slide 13, 14) in addition to paint chips of the same color as the tugboat's underside along the dock's edge (slide 15). Mr. Bashaw stated that most debris found on the property are from seagulls as they often drop clams from above to access the food inside the shells. D. Closing Conference Inspector Team and Mr. Bashaw had regrouped at the work trailer. The power washing crew had arrived back on site from their break. One worker joined the conversation. In discussion about work being conducted on the tugboat, he had mentioned that power washing and blasting occurs infrequently. He recalled that he conducted painting and blasting at some point in the last year when they renewed the seawall of the property that is half submerged in the water. Mr. Rosenberg explained that while power washing occurs, the Facility must implement measures such as (berms and / or protective barriers) to ensure no discharge of pollutants (wash water, paint chips or dust) is discharged into the river. Mr. Bashaw then instructed the team of workers to put up a temporary barrier while the washing continued. The Inspector Team did not see the installation of this temporary barrier while on - site. Mr. Rosenberg explained the applicability of the MSGP permit Is based on the types of exposed industrial activities that occur on site, and how conducting maintenance on vessels might make the Facility applicable to Sector Q or Sector R. Mr. Rosenberg also explained that an inspection report will be produced and sent to the Facility within 60 days of this inspection. Inspector Team left the Facility and followed the followed the drainage system to the North. No discharge point or outfall was observed however vertical open pipes were present within the middle of the drain. Waters might drain through these pipes (slide 18). 3 ED_019088A_00003952-00003 There were two flow paths within the drain. One side was wet, and the other was dry. Power wash water was draining to the wet side, and it is the wet side that connects to the location with the vertical drain pipes. Mr. Rosenberg also noticed 3 manhole covers in the Facility parking lot (slide 29) which might be access points for water management infrastructure. In this area, Inspector Team also noted several dilapidated 55-gallon drums which appeared to be full of liquid (slide 30). They were also visibly rusting from the outside. Inspector Team departed at approximately 1 PM. 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. 4 ED_019088A_00003952-00004