Document aJneZKeMONwY6k53DY3rGZo1M

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 ") Town Line Estates From:Andrew Spejewski, Inspector ANDREWDigitally signed by ANDREW SPEJEWSKI SPEJEWSKIDate: 2023.06.09 15:44:12 -04'00 ' Thru:Stephanie Tougas, Inspector To:File I. Facility Information A. Facility Name:Town Line Estates B. Facility Location: 20 Old County Road Hudson, MA 01749 C. Facility Contacts: Brian Jacobs TownLine Estates, LLC 272 Bacon St Waltham, MA 02451 781-248-9951 projects@mr-re.com D. NPDES ID No (s).: None II. Background Information A. Date(s) of inspection: May 8, 2023 B. Weather Conditions: Clear, Dry C. US EPA Representative(s): Andrew Spejewski D. State / Local Representative(s): None ED_019088A_00019906-00001 E. Federally Enforceable Requirements Covered During the Inspection: EPA construction general permit for stormwater F. Previous Enforcement Actions: None III. Type and Purpose of Inspection Unannounced Evaluation of Construction Stormwater compliance IV. Facility Description The main part of the site is roughly rectangular, lying northeast of Old County Road. To the northwest is woods with a drainage running northwest away from the site; to the southwest is Old County Road; to the northeast is Lake Boon; and to the southeast, woods and an extension of Lake Boon. Additionally, a narrow corridor goes north to a smaller cleared area on a peninsula into Lake Boon. The site slopes down to the lake and to a drainage to the northeast, with generally a fairly gentle slope in the cleared area of the site, sloping more steeply between the site and the lake. At the time of the inspection, the site had been cleared and grubbed, with loam stripped from most of the site. V. Inspection A. Opening Conference Mr. Spejewski arrived at the site unannounced at about 11:40 AM. He parked off site and walked onto the site, finding Kevin Russel. Mr. Russel identified himself as a foreman for J.R.Vinagro. Mr. Russel brought Mr. Spejewski to Rob Horne, who identified himself as the site Superintendent for J.R. Vinagro. Mr. Spejewski presented his credentials, provided a copy of the Small Business Information Sheet and explained the purpose of the inspection. Mr. Horne said that Mr. Vinagro was only the sitework contractor; they did the clearing and would do roadwork, but would not be excavating foundations. Mr. Horne identified the owner as Brian Jacobs; he believed the corporate entity was TownLine Estates, LLC. Mr. Horne said he was not responsible for permitting; he believed the owner just got permits in the last couple weeks, and that the owner would be responsible for documenting erosion control inspections. Mr. Horne did not have a full Stormwater Pollution Prevention Plan, and did not have documentation of operator erosion control inspections. 2 ED_019088A_00019906-00002 Mr. Horne showed a site plan with erosion controls, indicating several temporary basins and a permanent stormwater basin along the northwest edge of the main part of the site. B. Facility Tour Mr. Horne explained that the site entrance was being redone. He pointed out large yellow plastic mats in a pile that would be used as a site entrance to control dirt track - out from tires (Mr. Horne said he is using them for the first time on a site). The site entrance at that point did not have any gravel or other track - out control, but appeared to have been freshly scraped or graded within the last day or so. Mr. Horne said they had few trucks going in or out at this point anyway. Mr. Horne volunteered that a short section of silt tube had been accidentally removed recently and he was planning on fixing it that day. Mr. Spejewski and Mr. Russel then toured the rest of the site. While they toured the west part of the site, Mr. Horne took a section of silt tube toward the northeast side. The site was completely cleared and grubbed. Less than half the site still had loam, which was being removed during the inspection. The soil underneath the loam appeared to be fairly sandy, and there was little sign of significant overland flow. Along the northwest side of the main site, the terrain sloped down toward a drainage off the site running northwest. There was silt tube and silt fence in place along the edge of the site toward the drainage. A pre - existing one - lane paved driveway led across the main site and into the peninsula to the north. On either side of the driveway, in the main site, were small basins with standing water. Mr. Russel said these were intended as temporary basins during construction. The peninsula area to the north had been cleared and grubbed, up to the top of the slope down toward the lake. The slope down to the lake was undisturbed woods. There was silt sock in place at the edge of the cleared area. A pre - existing small house was in the peninsula area. Behind the house, inside the silt tube, were two old paint cans lying on the ground. Mr. Spejewski pointed these out to Mr. Russel as potential sources of pollution. In the main body of the site, the northeast edge also had a strip of undisturbed woods between the cleared area and the lake. Silt sock was in place along the length of the edge (including new sock in the area Mr. Horne was earlier observed working). There was no sign of sediment escaping the site in this area. To the southeast, a shallow inlet of the lake approached the site with a steep slope down. The slope was undisturbed, but provided a narrower buffer than most of the rest of the site. Silt sock was in place at this point. 3 ED_019088A_00019906-00003 A large loam stockpile was in place just west of the lake inlet, upslope from the inlet. The stockpile appeared freshly worked. There was no stabilization on the pile, and no protection around the base of the pile in any direction. Mr. Spejewski and Mr. Russel then met Mr. Horne again. D. Closing Conference Mr. Spejewski discussed the site briefly with Mr. Russel and Mr. Horne, noting the paint cans, and the need for protection for the stockpile. Mr. Spejewski thanked them for their time and departed at approximately 12:30 PM. Mr. Spejewski then spoke via phone with Mr. Jacobs on May 15. Mr. Jacobs confirmed the ownership of the site. Mr. Jacobs said that he had been advised he did not need a NPDES permit due to not having any discharge. Mr. Spejewski explained the definition of discharge for the CGP did not require a pipe, but any discrete channelized flow off of the site that reaches a water of the US. Mr. Spejewski noted that with the distance to the lake, it seemed likely there could be discharge during rain events. Mr. Jacobs indicated he would consider obtaining CGP permit coverage. Mr. Spejewski requested that if so, Mr. Jacobs email Mr. Spejewski the permit tracking number for the site. Picture List: IMG 2932.JPGSite Entrance from Old County Road IMG 2933.JPGInspector error; useless photograph IMG 2934.JPGPlastic sheets for site entrance track - out control IMG 2935.JPGFacing northwest edge of site, to drainage IMG 2936.JPGFacing north, over temporary basin IMG 2937.JPGTemporary basin on site IMG 2938.JPGFacing east over site IMG 2939.JPGSilt tube near drainage to northwest IMG 2940.JPGWest side of clearing on peninsula IMG 2941.JPGEast side of clearing on peninsula IMG 2942.JPGNorth side of existing house at north side of peninsula IMG 2943.JPGNortheast edge of site IMG 2944.JPGEastern corner of site IMG 2945.JPGSouthern corner of site IMG 2946.JPGFacing Old County Road, showing stockpile ** 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 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 4 ED_019088A_00019906-00004 concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. 50 ED_019088A_00019906-00005