Document gaN91VDJe4wejO6avgYypNwdV

Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Site/Facility Name: Permittee(s): Site/Facility Operator: Site/Facility Address: Latitude: County/Parish: Permit Number: NAICS Code: DSBID #: Clean Water Act Compliance Inspection Report 05/01/2024 National Pollutant Discharge Elimination System (NPDES) Construction Stormwater The Catholic University of America West Campus Solar Project The Catholic University of America Stuart Contractors LLC and Sun Tribe Solar 3750 Harewood Road NE Washington, D.C., 20017 38.9245 Longitude: -77.00909 District of Columbia DCR1000BM 221114 SIC: 4911 ECAD-5463 Site/Site representative(s): Clay Tharrington, Sun Tribe Solar Phone: 804-252-6606 Email: EPA Inspectors: Angela Weisel Phone: 215-814-2124 Email: Samuel Magro Phone: 215-814-3158 Email: State/Local Inspectors: Izanami Navarro, DOEE Phone: 202-604-5894 Email: Point of Contact Clay.tharrington@suntribesolar.com weisel.angela@epa.gov magro.samuel@epa.gov Izanami.navarro@dc.gov Report Preparer Signature/Date Supervisor Signature/Date DSBID #: ECAD-5463 Angela Weisel, Inspector Date NPDES Enforcement Section 1 (3ED32) Michael Greenwald, Acting Section Chief Date NPDES Enforcement Section 1 (3ED32) Section The Catholic University of America - West Campus Solar Project 5/1/2024 Table of Contents Page I 3 A Inspection Opening Conference...................................................................... 3 B Weather and Precipitation Conditions............................................................ 4 II Site Activity and Walkthrough......................................................................... 4 III Observations.................................................................................................... 5 IV Records Review............................................................................................... 8 V Closing Conference.......................................................................................... 8 VI List of Attachments.......................................................................................... 10 Attachment A Construction General Permit Attachment B Photograph Log Attachment C Exhibit Log DSBID #: ECAD-5463 Page 2 of 10 I. Introduction The Catholic University of America - West Campus Solar Project 5/1/2024 On May 1, 2024, an inspection team composed of staff from the U.S. Environmental Protection 3 Construction Stormwater Inspection of the Catholic University of America -West Campus Solar Project site the site located at 3750 Harewood Road NE, Washington, D.C. 20017. The purpose of the inspection was to observe compliance with the Clean Water Act (CWA) and to verify compliance with the facility National Pollutant Discharge Elimination System (NPDES) Construction General Permit (CGP) Permit No. DCR1000BM The Permit became effective on November 28, 2022 and shall expire on February 16, 2027. A. Inspection Opening Conference The EPA Inspection Team arrived at the site at est. 10:30 AM for the inspection. Inspectors met with the following site representative: Name Angela Weisel Samuel Magro Clay Tharrington Izanami Navarro Table 1. Inspection Attendee List Affiliation Telephone Email EPA Region 3 Inspectors Lead EPA Inspector 215-814- Weisel.angela@epa.gov 2124 EPA Inspector 215-814- Magro.samuel@epa.gov 3158 Site Representatives Sun Tribe Solar 804-252- Clay.tharrington@suntribesolar.com 6606 State or County Representatives DC DOEE 202-604- Izanami.navarro@dc.gov 5894 The EPA Inspection Team displayed their credentials to the site representative at the outset of the inspection and explained the purpose of the inspection was to observe compliance with its Permit. A copy of the Permit is provided in Attachment A. The EPA Inspection Team informed the site representative that any information that the site deemed to be confidential business DSBID #: ECAD-5463 Page 3 of 10 The Catholic University of America - West Campus Solar Project 5/1/2024 B. Weather and Precipitation Conditions During the inspection, weather was sunny. National Oceanic and Atmospheric Administration (NOAA) National Weather Service precipitation data for the date of the inspection and 5 days prior are provided in Table 2 below: Table 2. Precipitation Data Station Name Date WASHINGTON 2.6 NE, DC US, S1DCDC0026 WASHINGTON 2.6 NE, DC US, S1DCDC0026 WASHINGTON 2.6 NE, DC US, S1DCDC0026 WASHINGTON 2.6 NE, DC US, S1DCDC0026 WASHINGTON 2.6 NE, DC US, S1DCDC0026 WASHINGTON 2.6 NE, DC US, S1DCDC0026 4/26/2024 4/27/2024 4/28/2024 4/29/2024 4/30/2024 5/1/2024 Precipitation Amount (inches) 0 0 0.05 0 0 0.06 II. Site Activity and Walkthrough The Catholic University of America West Campus Solar Project, located at 3750 Harewood Road, NE, Washington, D.C., 20017, is under active construction. The construction site is operated Construction of the project began on January 16, 2023. The project being constructed is a solar farm to collect energy for the Catholic University of America. At the time of the inspection, all of the solar panels had been installed on the farm. The total estimated area to be disturbed is 20.75 acres. The EPA Inspection Team began the walk-through by walking parallel to Harewood Rd. through the solar field. The EPA Inspection Team observed silt fence along the perimeter of the site and Site representatives stated that this was the name of the waterway that ran through a portion of the site. The site had installed super silt fence and rip rap along the culverts and outlets (refer to Attachment B, Photographs 007 through 009 and 016 through 018). At the time of the inspection, the solar farm construction had been completed and permanent stabilization measures such as seeding were applied (refer to Attachment B, Photograph 011). At the time of the inspection, there were two bioretention ponds being constructed (refer to Attachment B, Photographs 003, 004, 010, 020 and 021). The EPA Inspection Team continued parallel to Harewood Rd. and then Irving St. where the condition of the silt fence was observed (refer to Attachment B, Photographs 012 through 015). The silt fence in the southern corner of the site (corner of Irving St. and N Capitol St.) was observed (refer to Attachment B, Photograph 019). The site walk-through continued parallel to DSBID #: ECAD-5463 Page 4 of 10 The Catholic University of America - West Campus Solar Project 5/1/2024 the silt fences and super silt fences along N. Capitol St. (refer to Attachment B, Photographs 025 through 030). In the northwestern corner of the site, mulch appeared to be toppling a silt fence. The mulch is EPA Inspection Team continued along the fence line parallel to Scale Gate Rd. (refer to Attachment B, Photograph 034 and 035). In areas where grading could lead to runoff, filter socks were used (refer to Attachment B, Photographs 022 through 024 and 028 and 029). The walk-through continued to the Northwest construction entrance off of Scale Gate Rd. Scale Gate Rd. is a private road used specifically for access to this site, and connects to Harewood Rd. A stabilized construction entrance was observed at the time of the inspection (refer to Attachment B, Photographs 032 and 033). On Scale Gate Rd., materials and stockpiles were observed (refer to Attachment B, Photographs 036 through 038). At the main construction entrance, signage was posted on the entrance gates at Harewood Rd., including various permits and DOEE signage (refer to Attachment B, Photographs 039 and 040). The condition of the main construction entrance to Scale Gate Rd. was observed (refer to Attachment B, Photographs 041 through 045). The observations from the inspection are described in detail below in the Observations section. Photographs were taken during the inspection by Samuel Magro of EPA, and are provided in Attachment B, Photograph Log. Documents used to support the observations in this report are included in Attachment C, Exhibit Log. Site self-inspections are completed by a representative from Stuart. III. Observations The inspection observations below are made pursuant to the requirements of the Permit. Permit Coverage post a sign or other notice of your permit coverage at a safe, publicly accessible location in close proximity to the construction site. The notice must be located so it is visible from the public road that is nearest to the active part of the construction site, and it must use a font large enough to be readily viewed from a public right-of-way. At a minimum, the notice must include: DSBID #: ECAD-5463 Page 5 of 10 The Catholic University of America - West Campus Solar Project 5/1/2024 A. The NPDES ID (i.e., permit tracking number assigned to your NOI and the EPA webpage where a copy of the NOI can be found (https://permitsearch.epa.gov/epermitsearch/ui/search)); B. A contact name and phone number for obtaining additional construction site information; C. The Uniform Resource Locator (URL) for the SWPPP (if available), or the following Plan (SWPPP) for this site, contact the EPA Regional Office at [include the appropriate CGP Regional Office contact information found at https://www.epa.gov/npdes/contactusD. discharge or in the receiving water, contact the EPA through the following website: https://www.epa.gov/enforcement/report-environmental- Observation 1: At the time of the inspection, information for the site SWPPP and the following statement discharge or in the receiving water, contact the EPA through the following website: https://www.epa.gov/enforcement/report-environmental-violations was not posted. Signage for various permits, and DOEE signage was found on the fence (refer to Attachment B, Photographs 039 and 040). General Stormwater Control Design, Installation, and Maintenance 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. a. Comply with any specific maintenance requirements for the stormwater controls listed in this permit, as well as any recommended by the manufacturer. b. If at any time you find that a stormwater control needs routine maintenance (i.e., minor effective operating condition, not including significant repairs or the need to install a new or replacement control), you must immediately initiate the needed work, and complete such work by the close of the next business day. If it is infeasible to complete the routine maintenance by the close of the next business day, you must document why this is the case and why the repair or other upkeep to be performed should still be considered routine maintenance in your inspection report under Part 4.7.1c and complete such work no later than seven (7) calendar days from the time of discovery of the condition requiring maintenance. c. If you must repeatedly (i.e., three (3) or more times) make the same routine maintenance fixes to the same control at the same location, even if the fix can be completed by the close of the next business day, you must either: DSBID #: ECAD-5463 Page 6 of 10 The Catholic University of America - West Campus Solar Project 5/1/2024 i. Complete work to fix any subsequent repeat occurrences of this same problem under the corrective action procedures in Part 5, including keeping any records of the condition and how it was corrected under Part 5.4; or ii. Document in your inspection report under Part 4.7.1c why the specific reoccurrence of this same problem should still be addressed as a routine maintenance fix under this Part.18 d. If at any time you find that a stormwater control needs a significant repair or that a new or replacement control is needed, you must comply with the corrective action deadlines for completing such work in in Part 5.2.1c. Observation 2: At the time of the inspection, the silt fence in the southern corner of the site (corner of Irving St. and N Capitol St.) (refer to Attachment B, Photograph 019) appeared to be in need of maintenance. Erosion and Sediment Controls Minimize sediment track- This requires permittees to: a. Restrict vehicle use to properly designated exit points; b. Use appropriate stabilization techniques at all points that exit onto paved roads; i. Exception: Stabilization is not required for exit points at linear utility construction sites that are used only episodically and for very short durations over the life of the project, provided other exit point controls are implemented to minimize sediment track-out; c. Implement additional track-out controls as necessary to ensure that sediment removal occurs prior to vehicle exit; and d. Where sediment has been tracked-out from your site onto paved roads, sidewalks, or other paved areas outside of your site, remove the deposited sediment by the end of the same business day in which the track-out occurs or by the end of the next business day if track-out occurs on a non-business day. Remove the track-out by sweeping, shoveling, or vacuuming these surfaces, or by using other similarly effective means of sediment removal. You are prohibited from hosing or sweeping tracked-out sediment into any constructed or natural site drainage feature, storm drain inlet, or receiving water. Observation 3: At the time of the inspection, sediment track-out was observed at the main construction entrance (Harewood Rd.) (refer to Attachment B, Photographs 041 through 044). Corrective Actions Part 5.1 following conditions identified at your site: take corrective action to address any of the DSBID #: ECAD-5463 Page 7 of 10 The Catholic University of America - West Campus Solar Project 5/1/2024 5.1.1 A stormwater control needs a significant repair or a new or replacement control is needed, or, in accordance with Part 2.1.4c, you find it necessary to repeatedly (i.e., three (3) or more times) conduct the same routine maintenance fix to the same control at the same location (unless you document in your inspection report under Part 4.7.1c that the specific reoccurrence of this same problem should still be addressed as a routine maintenance fix under Part 2.1.4); or 5.1.2 A stormwater control necessary to comply with the requirements of this permit was never installed, or was installed incorrectly; or Part 5.4.1 of the permit requires a corrective action log be kept: a. ific condition and the date and time it was identified. b. Within 24 hours of completing the corrective action (in accordance with the deadlines in Part 5.2), document the actions taken to address the condition, including whether any SWPPP Observation 4: At the time of the inspection, it was unclear what, if any, corrective actions were completed as no corrective action log was provided by the facility. Stormwater Pollution Prevention Plan (SWPPP) Part maintain records showing the dates of all SWPPP modifications. The records must include the name of the person authorizing each change Observation 5: At the time of the inspection, it was unclear what, if any, modifications were made to the SWPPP as the site did not provide a SWPPP modification log. IV. Records Review The EPA Inspection Team reviewed documentation including: the site SWPPP, and most recent self- inspection reports. Documents were sent to the EPA Inspection Team after the inspection and received on May 1, 2024. Copies of these attachments are provided in Attachment C, Exhibit Log. V. Closing Conference After the site walk, the EPA Inspection Team met with the site representative for a closing conference. The EPA Inspection Team shared preliminary observations with the site representatives. The EPA Inspection Team reiterated to the site representative that all DSBID #: ECAD-5463 Page 8 of 10 The Catholic University of America - West Campus Solar Project 5/1/2024 preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by EPA upon the additional review of records and documentation. Additional observations may be contained in this inspection report that were not identified at the time of the closing conference after EPA reviewed additional materials following the inspection. The inspection concluded at 11:30 AM. DSBID #: ECAD-5463 Page 9 of 10 VI. List of Attachments The Catholic University of America - West Campus Solar Project 5/1/2024 Attachment A: Construction General Permit Attachment B: Photograph Log Attachment C: Exhibit Log Exhibit 1: Site SWPPP Exhibit 2: Self- Inspection Reports DSBID #: ECAD-5463 Page 10 of 10