Document NE2x3Gkrb5a3ry5rxOvxLbGYp

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 ") Route 111 Auto Sales From:Damian Bednarz, InspectorDAMIANDigitally BBEEDNDANRZADRaZte :s 2i02g3n.1e0.d1 7 b1y5: 5D0A: M28I-A04N' 00 ' Thru:Andrew Spejewski, Inspector To:File I. Facility Information A. Facility Name:Route 111 Auto Sales B. Facility Location:415 Emerson Avenue Hampstead, NH 03841 C. Facility Contacts: Joseph Gerraughty, President 603-329-4600, Route 111 auto@gmail.com D. NPDES ID No (s).: NHR1001JF II. Background Information A. Date(s) of inspection: August 30, 2023 B. Weather Conditions: 75 , cloudy C. US EPA Representative(s): Damian Bednarz D. State / Local Representative(s): NA E. Federally Enforceable Requirements Covered During the Inspection: National Pollutant Discharge Elimination System Construction General Permit (CGP) (Effective February 17, 2022) F. Previous Enforcement Actions: None known ED_019088A_00004272-00001 III. Type and Purpose of Inspection Evaluation of EPA general permit for stormwater discharges from construction activities. IV. Facility Description The 409 Emerson Ave, Hampstead, NH construction project (the " Site ") is the construction of a new car dealership, including a dealership showroom / office building and multiple parking lots. Prior to construction this area was forested. At the time of the inspection, the building and parking lots east of the building were complete and in use, and parking lots south and west of the building were still being graded and finished. Multiple catch basins and stormwater structures are present on the Site and serve to divert stormwater into a detention and percolation basin in the southwestern corner of the project footprint (slide 65). This area of Hampstead, NH is not routed to any municipal infrastructure such as sewers. The Site features a septic tank and aboveground leaching field in the shape of a mound. There are four buildings along Route 111 that existed prior to this construction. V. Inspection I arrived at Route 111 Auto Sales in Hampstead, NH at approximately 1 PM. A. Opening Conference I walked into the front door of the currently operational automobile dealership and asked to speak with Joseph " Joe " Gerraughty, president of the business. Mr. Gerraughty greeted me, and I showed my credentials and explained that the purpose of my visit was to conduct observations in relation to the Construction General Permit (" CGP "). I asked about the current progress of the permitted construction project. Mr. Gerraughty explained that the construction was phased, and that one such phase was paving the front parking area. This phase was completed in July of 2023, and roughly 40 percent of the worked area was paved and impervious (Slide 1-6, 65). The Site's current Notice of Intent (" NOI ") estimates that the project should be entirely complete by October of 2024, and Mr. Gerraughty expressed he wanted it finished before winter of 2024. Mr. Gerraughty further explained that he owned 8 acres of land in this spot and was reworking about 3 to 4 of those acres regarding this Site. I asked Mr. Gerraughty about the Site's inspection frequency. He explained that Millenium Engineering, Inc., conducts weekly visual inspections. I subsequently asked to receive copies of the last 3 months of inspection reports post inspection. I also asked for the Site's Storm Water Pollution Prevention plan (" SWPPP "). Mr. Gerraughty did not have it on hand for review before the Site tour but was able to provide a copy both digitally and physically by the end of this inspection. 2 ED_019088A_00004272-00002 B. Facility Tour We left the building and discussed the completed phase in the parking lot. I noticed a drain (slide 4) and asked where the stormwater daylights. Mr. Gerraughty explained that all on - site stormwater catchment basins and culvert systems are routed to the detention basin in the back of the site (slide 35). In addition, the roof gutters were lined into this stormwater conveyance system. Mr. Gerraughty explained that there are many layers within the detention basin to assist with its function, such as sand and woodchips. I asked about a patch of tall grass in the middle of the parking lot (slide 6). Mr. Gerraughty said it was a septic system, as this part of town did not have municipal infrastructure such as sewer piping. I noticed an estimated 7 " earthen and rock berm surrounding one section of the parking lot (slide 7, 8). Downgradient of this berm, I noticed several eroded channels (slide 13). Beneath these eroded channels. I observed a silt fence which was loaded with mud and sediment from the bottom to the top, noted in the photo album as " Silt Fence Breach # 1 " (slide 11). The parking lot around this area featured small patches of sediment in clumps (slide 7, 8, 14). At the end of the recently paved parking area, I observed two stormwater catchment grates, surrounded by a berm of about one foot (slide 15, 16). Mr. Gerraughty explained that these stormwater grates are routed to the detention pond. On the other side of the business'garage, I observed a downed silt fence, noted as " Downed Silt Fence # 1 " in this inspection's photo album (slide 17, 18). On the other side of the silt fence, I noticed sediment of the same color as on the inside of the fence, indicating that sediment had been leaving the Site for some time. In this area of the Site, I observed rip rap surrounded by a partially unburied silt fence (slide 19) and a flared - end stormwater inlet. This inlet has an outlet downgradient of the Site, followed by more rip rap material (slide 24). On the other side of this unburied silt fence, I noted some sediment had left the fence. In the photo album this is labeled as " Silt Fence Breach # 2 " (slide 20). Partially buried silt fences in this area also exhibited sediment build up, indicating that stormwater deposition of solids was occuring in these areas (slide 21). Continuing to follow the silt fence, I observed a downed, and possibly broken, silt fence. This is noted in the photo album as " Downed Silt Fence # 2 " (slide 22). I asked Mr. Gerraughty what the significance was of what appeared to be catch basin inlets covered with metal plates (slide 23, 27). He explained that while construction operations are occurring around these basins, that they will continue to be covered in efforts to not overload the detention basin with sediment. The only functioning (uncovered) stormwater drains were in the paved area, in front of the business. Downgradient of the flared - end stormwater culvert and a steep drop - off, I observed sediment accumulation before a silt sock and a berm of about 2 ', topped with large rocks (slide 26). I continued along the edge of what became a steeper drop off point (slide 28) and noted extensive rip rap placement, as well as sediment accumulation beyond the 3 ED_019088A_00004272-00003 control measures (slide 29). The accumulation of the fine and bright sediment was level beyond a certain point, indicating consistent stormwater deposition of solids in this area. Above this drop off were numerous active stockpiles, as well as flooding (slide 30). The ground was easily disturbed as I walked through it, and heavy machinery tracks were visible. Within the Site's footprint, I observed a pipe within a densely vegetated area (slide 31). I asked Mr. Gerraughty what the purpose of this pipe was, and he did not know at the time of me asking. He said he would follow up with me promptly on the matter. After the inspection, Mr. Gerraughty had an excavator lift the pipe, and it was found that it was not attached to anything. At this point in the inspection, Mr. Gerraughty received an important, business - related call. I explained that I could continue my observations surrounding the detention basin on my own, and that I would regroup with him later. Mr. Gerraughty then left to tend to his business, and I continued to take a closer look at the Site's perimeter. I observed fine sediment accumulation on the inside of the southern silt fence (slide 36). Further along the silt fence, south of the detention basin, I observed a downed silt fence with similarly colored sediment on both sides of the fence (slide 39). This is denoted in the photo album as " Silt Fence Breach # 3 ". Standing over this silt fence, I observed the same - colored sediment in the distance (slide 40). Along the western edge of the detention basin, I observed accumulated sediment along the foot of a silt fence, and sediment staining far above the current sediment level (slide 41). I continued to follow the fence in a counterclockwise fashion and observed intact silt fences (slides 42-47). The northern side of the detention pond, beyond a patch of riprap, I observed a completely buried silt fence (slide 48, 49, 50). The sediment had risen to the point where vegetation was partly buried, and the accumulation was level throughout. This area is noted in the photo album as " silt fence breach # 4 ". I observed standing water beyond this buried silt fence (slide 51). Beneath the steep drop off mentioned before, around the flared - end culverts, I observed barren sides of the currently worked area (slide 53). The other side however was covered in an even layer of rip rap and had dense vegetation beyond it (slide 55). I was able to take a photo of the same visible sediment accumulation (slide 56) as I noted in slide 29. The sediment was also visible in an area where there was a gap in vegetation (slide 57). D. Closing Conference Mr. Gerraughty had returned to me after I walked the Site's western perimeter. I said that I had finished my walk around, and that we could continue the conversation inside. He also brought me a freshly printed SWPPP. Mr. Gerraughty and I exchanged contact information for future contact. He asked what some of the next steps were, and if I had observed any issues. I explained that the permit requires regular upkeep and inspections of silt fences, and that accumulated sediment that 4 ED_019088A_00004272-00004 could pose a risk of potential overflow needs to be removed from the area of accumulation. I pointed in general areas in which I remembered seeing a breach in silt fences. Mr. Gerraughty said he would contact his stormwater experts and have them remove the excess sediment and send photos when this task is completed. I further explained that I would send a report with my observations within 60 days of the inspection day. On September 6, 2023, Mr. Gerraughty emailed me and said that downed silt fences were repaired, and that sediment was removed from both sides of every breach. I departed at approximately 2:30 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. 5 50 ED_019088A_00004272-00005