Document k6d9j3V1KL93KndZy33JY76yb
UNITED STATES
AGENCY
ENVIRONMENTAL
PROTECTION
REGION 1
BOSTON, MA 02109
Date:Dated as shown on electronic signature(s)
Subj:Inspection Report - Clean Water Act (" CWA ")
National Pollutant Discharge Elimination System (" NPDES ")
From:Stephanie Tougas, EPA Inspector
STEPHANIE
TOUGAS
Digitally signed by
STEPHANIE TOUGAS
Date: 2024.11.26 08:22:33
-05'00 '
Thru:Ray Putnam, EPA inspector
To:File
I. Facility Information
A. Facility Name:Palmer Woods
B. Facility Location:Stephen C. Savage Way
Plaistow, NH 03865
C. Facility Contacts:Steve Doherty, Developer - DC Development and
Construction, LLC
3 Valerie Way Unit 1
Sandown, NH 0387
Bill Hall, Engineer
Engineer - Civil Design Consultants, Inc
whall@civildci.com
D. ID No (s).:s,
II. Background Information
A. Date(s) of inspection: 11/19/2024
B. Weather Conditions: 50 degrees F, sunny.
ED_019088A_00020468-00001
C. US EPA Representative(s): Stephanie Tougas
Ray Putnam
D. State / Local Representative(s): None
E. Federally Enforceable Requirements Covered During the Inspection:
2022 Construction General Permit
F. Previous Enforcement Actions: N / A
III. Type and Purpose of Inspection
Evaluation
IV. Facility Description
Palmer Woods is a planned residential development of 16 homes located on a 20 acre
parcel, with approximately 6-7 acres of disturbance. All but 3 of the homes were
completed at the time of the inspection. The site is located just north of Seaver Brook.
The lowest point of the site is the southwest corner where the infiltration basin is
located. Construction began in Spring of 2023 and anticipated completion time is Spring
of 2025.
V. Inspection
I announced the inspection via a phone call to Mr. Doherty on November 18, 2024.
Inspector Putnam and I arrived at approximately 9:30 AM. Mr. Doherty and Mr. Hall met
us on site.
A. Opening Conference
I presented my credentials and explained the purpose of the inspection. I informed Mr.
Hall and Mr. Doherty that EPA noticed a large clearing on aerial imagery in close
proximity to a water of the U.S. as part of routine screening procedures, and could not
locate a Notice Of Intent (NOI) for the site. Mr. Doherty explained that he had obtained
a NHDES AOT permit as well as an Army Corps CWA 404 permit for the wetland crossing
in order to construct Stephen C. Savage Way (the cul - de - sac the homes are located). I
explained that for construction sites that disturb more than an acre of land that have
the potential to discharge stormwater into a water of the US, an application (NOI) for
coverage under the federal Construction General Permit is required in addition to local
and state permits. Mr. Hall said he would check to see if they had applied for coverage
at this site. They explained that they were maintaining erosion controls and conducting
weekly inspections.
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B. Facility Tour
We began the site walk starting at the wetland crossing, observing silt socks upslope of
the wetlands. They said they followed all New Hampshire and Army Corp requirements
for constructing the crossing.
We then walked clockwise starting along the perimeter in the northeast section of the
site where there was active construction work on homes. They were in the process of
building the leach field / subsurface wastewater disposal system behind the home.
Inspector Putnam and I observed a narrow wetland band downslope of the home in the
wooded, undisturbed area. Mr. Doherty said all clearing and cutting at the site was
complete had and left a wooded buffer between the back of these homes and the
wetlands.
As we continued walking, Inspector Putnam and I noted fill directly in wetland. Mr. Hall
explained that this was permitted fill of approximately 250 square feet. I suggested that
they install erosion controls to prevent the fill from encroaching further into the
undisturbed portion of the wetland. Mr. Doherty made a phone call and requested
additional silt socks to install in this area.
We made our way towards the infiltration basin at the southwest corner of the site. The
basin was complete, and dry given the lack of rain the past few weeks. The sides of the
infiltration basin were stabilized. Inspector Putnam and I observed a conveyance feature
downslope of the infiltration basin that was connected to the wetlands where fill was
permitted. I followed the conveyance to the edge of the property line. It appeared the
conveyance feature continued towards Seaver Brook.
C. Records Review
We walked back to the cars and Mr. Doherty showed us some of the records he kept in
his truck. I noted the folder where he kept his NHDES and Army Corps permit, and I
flipped through two large binders that contained weekly inspection reports of the site
erosion controls.
D. Closing Conference
I reiterated to Mr. Doherty and Mr. Hall the need to address the area downslope of the
disturbed wetland with erosion controls. I explained that the conveyance feature
downslope of the infiltration could convey stormwater to Seaver Brook, a water of the
US, and that we would follow up regarding permit applicability. We departed at
approximately 10:30 AM.
Shortly after we left the site, Mr. Doherty emailed me a photo showing the installation
of the silt socks downslope of the wetland and Mr. Hall emailed me a copy of the site
plans.
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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.
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