Document baVd03owq1kvd5EEzK7r3j1q3
UNITED STATESUNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 1
NVIRONMAGEENCBYOS5 TPOOSNT, OFMFAIC E0 S2Q1U0AR9E-, 3S9U1IT2E
100
PROTECTION
Date:Dated as shown on electronic signature(s)
Subj:Inspection Report
Clean Water Act - National Pollutant Discharge Elimination System
(" NPDES ")
Sanborn Lane
STEPHANIDigitalSlTyE PsHAiNgInEe dTO UbGyA
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From:Stephanie Tougas, InspectorE DTaOtUeG:A S2
02414:.370:431 -.05'1000 '
Thru:Eleanor Horvath, Inspector
To:File
I. Facility Information
A. Facility Name:Sanborn Lane / Farmhouse Lane
B. Facility Location:103 Sanborn Lane
Reading, MA 01867
C. Facility Contacts:Cody Hall, Construction Supervisor
M.G. Hall Contractors, Inc.
office@mghallcontractors.com
D. NPDES ID No (s).: MAR1004X8
II. Background Information
A. Date(s) of inspection: December 19, 2023
B. Weather Conditions: 45 degrees F, sunny. Heavy rain day prior.
C. US EPA Representative(s):
Stephanie Tougas
Eleanor Horvath
D. State / Local Representative(s):
None
E. Federally Enforceable Requirements Covered During the Inspection:
2022 EPA Construction General Permit
ED_019088A_00020153-00001
F. Previous Enforcement Actions:
None
III. Type and Purpose of Inspection
Compliance Evaluation
IV. Facility Description
The site is located off Sanborn Lane in Reading, MA and bordered by properties on
Sandborn Lane, Thomas Drive, and Lilah Lane. The site is approximately two acres with
three houses, one on each lot. At the time of the inspection, two of the homes were
complete and the last house was actively being built. The road leading into the site was
paved and sidewalks were complete. The site is located approximately 0.5 miles east
and south of the Ipswich River.
V. Inspection
I announced the inspection to the Facility the morning of the inspection via a phone call
to Mr. Hall.
We arrived at approximately 9:30 AM and met Mr. Hall.
A. Opening Conference
I presented my credentials, provided a copy of the Small Business Resources
Information Sheet, and explained the purpose of the inspection. I explained that EPA
had received some complaints from neighbors alleging stormwater runoff onto their
properties. Mr. Hall said that they have since worked to address those concerns and
expanded the stormwater filtration system to include a retention basin. He explained
that originally the stormwater fed into a catch basin that directed flow into a filtration
field behind one of the houses. After receiving concerns and working with the town, he
said they now have built a retention basin that stormwater initially flows into. Once a
certain capacity is reached in that basin, the stormwater is then diverted into the
filtration system, where each lot has a separate filtration field.
I asked Mr. Hall about the Low Erosivity Waiver that the operator filed for this site on
11/16/2023. I explained that to qualify for this type of waiver would be unlikely for sites
in New England and that the waiver is predominantly meant for climates like Arizona.
Mr. Hall said he believed it was a mistake and that he intends to file an NOI for CGP
coverage. He said he did not know he needed a NPDES permit, but that he was working
closely with the town and following its stormwater bylaws. He says he does inspections
of erosion controls daily and writes reports for the town. I explained that the CGP likely
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has similar requirements as the town, with some additional requirements such as having
a Stormwater Pollution Plan (SWPPP).
B. Facility Tour
We began the site walk by walking behind the actively built house, moving
counterclockwise. We observed silt socks and a stockpile. Mr. Hall said it was actively
being worked on and I said if the stockpile remains inactive for 14 or more days it needs
to be stabilized. We observed an area where sediment had appeared to breach the silt
socks and begin accumulating around the base of a tree. I pointed this area out to him,
and he said they would address it.
We then walked into the yard behind one of the completed homes to observe the
filtration field. As explained before, there are now filtration fields behind each home.
We then walked back to the center of the site, where three employees of the town of
Reading were now in attendance. They asked why we were there, and I explained that
we had received a tip and they said they were there for a similar reason. Mr. Alex
Rozycki, the town of Reading Senior Civil Engineer, said that they have been working
with Mr. Hall to redevelop the stormwater system and believe that Mr. Hall has
significantly improved the situation by building the retention pond.
EPA, the town employees, and Mr. Hall walked to the entrance of the site. There is a
break point about 100 feet from Sanborn Lane where the site begins to slope down
towards Sanborn Lane. At the base of the entrance, there are two areas where Mr. Hall
is in the process of installing catch basins. At the time of the inspection, the structures
were there but not the grates. Mr. Hall indicated that when the catch basins are
installed and functional, stormwater is expected to flow into the catch basins and
subsequently into the retention basin rather than offsite into the road.
We walked onto Sanborn Lane and I asked Mr. Rozycki if there had been runoff into the
road and where it had been observed flowing. He said that because of the slope up to
the east on Sanborn Lane, the flow likely goes into a wooded area across from the
entrance rather than west on Sanborn Lane. I did not observe any catch basins on
Sanborn Lane in this area.
D. Closing Conference
I thanked Mr. Hall for his time and explained that he likely will need to re - file the correct
type of NOI. We discussed the area where sediment had begun to accumulate, and the
town had suggested another row of sediment controls up the slope a little, such as
haybales. I said I would be following up with an inspection report.
We departed at approximately 10:15 AM.
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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.
Inspection photo captions
Image
Caption
20231219_144556606_iOS.heic last house of three homes being constructed
20231219_144631737_iOS.heic silt socks along perimeter
20231219_144638976_iOS.heic an area where the sediment has begun to breach the silt socks
20231219_144654125_iOS.heic more silt socks along perimeter
20231219_144826056_iOS.heic area behind home actively being built
20231219 144906917 iOS.heic area where sediment is beginning to accumulate
20231219_145021961_iOS.heic area where sediment has breached the silt sock and accumulating
20231219_145031681_iOS.heic behind fence of completed house
20231219_145126494_iOS.heic filtration field outlet
20231219_145228284_iOS.heic inspector hole for filtration field
20231219_145303041_iOS.heic filtration field for one of the completed homes
20231219_145530058_iOS.heic
catch basin on site that funnels stormwater to the retention basin and
then to the filtration fields
20231219_150245892_iOS.heic retention basin
20231219_150253094_iOS.heic retention basin with view of inlet
20231219_150444327_iOS.heic downslope of site entrance at Sanborn where catch basin will be installed
20231219_150557811_iOS.heic same as previous photo except opposite side
20231219_150842941_iOS.heic view of previous photo looking upslope standing on Sanborn
20231219_150933222_iOS.heic
area across from site entrance where it appears stormwater likely would
flow into from site
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