Document k9JvnMMXXLnO5zN2OMOBDyJbq

Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Region 10 Enforcement and Compliance Assurance Division 1200 6th Avenue Seattle, WA 98101 INSPECTION REPORT Inspection Date: Time: Media: Regulatory Program: 02/24/2021 Entry: 1:30 p.m. Exit: 2:40 p.m. Water CWA NPDES/Construction Stormwater Operator Name(s): Operator Addresses: Operator City, State, Zip Code: Site Name: Site Physical Location: City, State, Zip Code: Site Contact(s): County: Brighton Development, Inc. - (Notice of Intent IDR1002TX) 2929 West Navigation Drive, Suite 400 Meridian, Idaho 83642 Hill's Century Farm North Subdivision No. 2 3401 East Amity Road, Meridian, Idaho, 83642 Latitude/Longitude 43.558268N, 116.353572W Meridian, Idaho, 83642 Manny Wheaton, Assistant Superintendent Phone: (208) 960-4609 Email: Brighton Development, Inc. mwheaton@brightoncorp.com Ada County, Idaho Site Identifier: Estimated Site Area to be Disturbed: Site Receiving Water(s) Site Receiving Water(s) Description: NPDES Permit: EPA Site Tracking Numbers: Notice of Intent (NOI) Site Timeline(s): Hill's Century Farm North Subdivision No. 2 30 acres Farr Lateral, Tenmile Creek, Rawson Canal, Fivemile Creek Canals and creeks 2017 EPA Construction General Permit (CGP) IDR1002TX Start Date: 12/14/2020 End Date: 12/14/2021 Inspector(s): Steven Chase - PG Environmental Signature: U.S. EPA Contract Inspector (Lead Inspector) Kelly Davis - ERG, Inc. Charissa Bujak - EPA Region 10 ERG Inc., Staff U.S. EPA Inspector (720) 789-8048 Date: 04/26/2021 (703) 633-1600 (208) 378-5754 Inspection Date: February 24, 2021 1 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report EPA Region 10 Recipient: Brian Levo Signature: BRIAN LEVO Digitally signed by BRIAN LEVO Date: 2021.04.27 11:08:43 -07'00' Date: Inspection Date: February 24, 2021 2 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Table of Contents Section I - Inspection Information ...................................................... 4 Purpose and Scope of the Inspection ...................................................................................................... 4 Opening Conference................................................................................................................................. 4 Site Description ........................................................................................................................................ 4 Documents Requested During Inspection ............................................................................................... 5 Section II - Observations .................................................................... 5 Section III - Areas of Concern ............................................................. 6 Records Review Areas of Concern ........................................................................................................... 6 3. Permit Part 7.2.10 (SWPPP Certification) ........................................................................................ 9 Field Observation Areas of Concern ........................................................................................................ 9 Section IV - Closing Conference........................................................ 11 Attachment A - Photograph Log and Photos .................................... 12 Attachment B - Exhibit Log .............................................................. 18 Attachment C - Inspection Reports Attachment D- Stormwater Pollution Prevention Plan Inspection Date: February 24, 2021 3 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Section I - Inspection Information Purpose and Scope of the Inspection On February 24, 2021, Steven Chase, U.S. Environmental Protection Agency (EPA) Contract Inspector, Eastern Research Group (ERG), Inc. staff inspector Kelly Davis, and EPA Region 10 Inspector Charissa Bujak, (hereafter, we or Inspection Team) conducted a construction stormwater inspection of Hill's Century Farm North Subdivision No. 2 construction project (hereafter, Site) operated by Brighton Development, Inc. (the Permittee). The purpose of the inspection was to determine compliance with the requirements of EPA's National Pollutant Discharge Elimination System (NPDES) 2017 General Permit for Discharges of Stormwater Associated with Construction Activities (the Permit). The inspection consisted of two parts, a preliminary records review and a Site walk-through. Inspection photographs from the Site walk-through are included in Attachment A and photographs from the onsite records review are included in Attachment B. The Inspection Team requested a digital copy of the files reviewed during the inspection and performed a more thorough review after the onsite inspection. Inspection reports provided by the Permittee are included as Attachment C and the Site's Stormwater Pollution Prevention Plan (SWPPP) is included as Attachment D. Opening Conference A notice of inspection was attempted via phone call to the Site Contact, Mr. Manny Wheaton at approximately 11:30 a.m. on the day of the inspection without success. Mr. Wheaton returned the Inspection Team's call at approximately 12:00 p.m. and agreed to meet us on site at 1:30 p.m. We met with Zack Meyers of Brighton Development, Inc. near the Site construction entrance prior to conducting the records review and Site walk-through. We were also joined by Mr. Manny Wheaton of Brighton Development, Inc. who served as an Assistant Superintendent and Best Management Practice (BMP) inspector for the Site. Brighton Development, Inc. staff had elected to conduct biweekly inspections plus inspections after qualifying rain events (i.e., greater than 0.25"in 24 hours). Brighton Development, Inc. staff used storm data from the NOAA weather station at the Boise airport, Boise Air Terminal (KBOI). Syman, LLC performs BMP maintenance on site. During the opening conference, Charissa Bujak and I, Steven Chase, presented our EPA inspector credentials to Mr. Meyers and Mr. Wheaton (the Site Representatives), exchanged business cards, and informed Site Representatives of the purpose of the Site inspection. Site Description The Site is located off East Amity Road in the City of Meridian, ID, roughly 8 miles southwest of Boise. The Site is comprised of construction activities for a planned single-family home residential community. The Site's western perimeter extends along South Eagle Road. The Site borders another construction project to the north. To the east and south of the Site are private residential properties. The Site has one construction entrance located off East Amity Road that connects to the Site via a roadway that runs through the construction project to the north of the Site. For an aerial image of the Site, refer to Attachment B, Exhibit 1. The Site's total planned disturbance area is 30 acres, as described in the Site's Inspection Date: February 24, 2021 4 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Notice of Intent (NOI), which was certified by Mr. Jon Wardle on November 23, 2020. Construction activities began in January 2021. At the time of the inspection, rough grading had been completed and storm sewer installation was in progress, but fine grading, pavement/sidewalk construction, installation of storm drain inlets and catch basins, and vertical construction had not begun. The official receiving waters for stormwater discharged from the Site include Farr Lateral canal, Tenmile Creek, Rawson Canal, and Fivemile Creek as described in the Site's Stormwater Pollution Prevention Plan (SWPPP) and NOI. The Inspection Team also observed an unnamed irrigation canal along the western perimeter of the Site that Site Representatives stated collects stormwater via sheet flow. Site Representatives explained that stormwater from the Site is collected in a sediment basin located on the Site's northwestern perimeter, a seepage bed located on the Site's southwest perimeter, and in the unnamed irrigation canal along the western perimeter. Stormwater collected in the unnamed irrigation canal discharges to the sediment basin before discharging canal north of the Site through the unammed irrigation canal, and then discharges to Tenmile Creek, then subsequently to the Boise River. Site connections to the other official receiving water bodies listed on the NOI were unclear to the Inspection Team. Tenmile Creek and Fivemile Creek are impaired for E. coli and sediment and have a TMDL (ID# 64560) named the, 2015 Sediment and Bacteria Addendum, Sep 2015. The Farr Lateral and Rawson Canal are not impaired. Documents Requested During Inspection Due to the ongoing COVID-19 pandemic, the Inspection Team confirmed Site documentation to be available at the time of the inspection but did not review the documentation in detail onsite. The site provided inspection reports from the beginning of the project on January 13, 2021 through February 24, 2021. The Inspection Team requested the following documents electronically for review following the onsite inspection. Inspection reports provided by the Permittee are included as Attachment C and the Site's Stormwater Pollution Prevention Plan (SWPPP) is included as Attachment D. Current copy of Site SWPPP and map. The three most recent months of Site inspection records and corrective action reports (note that construction had begun January 2021) Section II - Observations Following the opening conference and initial records review, the Inspection Team, accompanied by the Site Representatives, began the Site walk-through at approximately 1:50 p.m. At the time of the inspection, the weather was mostly sunny with temperatures in the upper-30's and a steady, mild wind. We began the Site walk-through at the Site entrance and followed the Site perimeter in a clockwise pattern, completing the walk-through back at the Site entrance. For a list of areas of concern regarding the onsite review of Permit required documents, refer to Section III, Areas of Concern. The Inspection Team made the following observations during the Site walk-through of the inspection: We observed construction activities that consisted of sewer utility instillation. We observed an overall lack of stabilization measures and perimeter control BMPs throughout the Site (refer to Section III, Areas of Concern, below for more details). Inspection Date: February 24, 2021 5 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report As we progressed towards the northeast Site perimeter, we observed an unstabilized soil stockpile that did not have sediment barriers installed on all downgradient perimeter areas (refer to Area of Concern 4). We also observed a lack of perimeter controls along a majority of the eastern perimeter of the Site (refer to Areas of Concern 5). We progressed along the southern perimeter towards the western perimeter of the Site. We did not see any areas of concern along the southern perimeter. As we progressed along the western perimeter of the Site, we observed an unstabilized soil stockpile on the southwest perimeter (refer to Area of Concern 4). Adjacent to the unstabilized soil stockpile was an irrigation channel that extended along the western perimeter of the Site that lacked perimeter controls on the southwest end of the perimeter (refer to Area of Concern 5). We continued to the northwest perimeter of the Site and observed a sediment basin that discharges stormwater from the northwest perimeter to an irrigation canal north of the Site. We continued along the northern perimeter of the Site and observed a dewatering ditch that extended along the northern perimeter of the Site that connected to the sediment basin on the northwest perimeter of the Site. Adjacent to the dewatering ditch along the north-central perimeter of the Site, we observed an unstabilized soil stockpile (refer to Area of Concern 4). We concluded the Site walk-through portion of the inspection near the Site entrance. Section III - Areas of Concern The presentation of areas of concern does not constitute a formal compliance determination or violation. An area of concern is an observation that the Inspection Team made that may be inconsistent with the requirements of the Permit. The Inspection Team noted areas of concern in both the records review performed post-inspection and the onsite field inspection. Records Review Areas of Concern 1. Permit Part 7.2.4 (Site Map) Include a legible map, or series of maps, showing the following features of the site: a. Boundaries of the property; b. Locations where construction activities will occur, including: i. Locations where earth-disturbing activities will occur (note any phasing), including any demolition activities; ii. Approximate slopes before and after major grading activities (note any steep slopes (as defined in Appendix A)); iii. Locations where sediment, soil, or other construction materials will be stockpiled; iv. Any water of the U.S. crossings; v. Designated points where vehicles will exit onto paved roads; vi. Locations of structures and other impervious surfaces upon completion of construction; and Inspection Date: February 24, 2021 6 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report vii. Locations of on-site and off-site construction support activity areas covered by this permit (see Part 1.2.1c). c. Locations of all waters of the U.S. within and one mile downstream of the site's discharge point. Also identify if any are listed as impaired, or are identified as a Tier 2, Tier 2.5, or Tier 3 water; d. Areas of federally listed critical habitat within the site and/or at discharge locations; e. Type and extent of pre-construction cover on the site (e.g., vegetative cover, forest, pasture, pavement, structures); f. Drainage patterns of stormwater and authorized non-stormwater before and after major grading activities; g. Stormwater and authorized non-stormwater discharge locations, including: i. Locations where stormwater and/or authorized non-stormwater will be discharged to storm drain inlets; and ii. Locations where stormwater or authorized non-stormwater will be discharged directly to waters of the U.S. h. Locations of all potential pollutant-generating activities identified in Part 7.2.3g; i. Locations of stormwater controls, including natural buffer areas and any shared controls utilized to comply with this permit; and j. Locations where polymers, flocculants, or other treatment chemicals will be used and stored. AND Permit Part 7.1 (General Requirements) All operators associated with a construction site under this permit must develop a SWPPP consistent with the requirements in Part 7 prior to their submittal of the NOI. The SWPPP must be kept up-to-date throughout coverage under this permit. If a SWPPP was prepared under a previous version of this permit, the operator must review and update the SWPPP to ensure that this permit's requirements are addressed prior to submitting an NOI for coverage under this permit. (Area of Concern 1) During the initial onsite records review, we observed that the SWPPP Site map did not include all minimum information as required by Part 7.2.4 of the Permit. The onsite map did not include the following information (refer to Attachment B, Exhibit 2): Locations where sediment, soil, or other construction materials will be stockpiled (Permit Part 7.2.4.b.iii) - We observed that the onsite SWPPP map did not include locations where sediment and soil would be stockpiled. The Site had three locations where soil was stockpiled - one location at the northeast perimeter of the Site, one location at the southwestern perimeter of the Site, and one location on the Inspection Date: February 24, 2021 7 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report north-central perimeter of the Site (refer to Attachment A, Photographs 1 through 4); Drainage patterns of stormwater and authorized nonstormwater before and after major grading activities (Permit Part 7.2.4.f); Stormwater and authorized non-stormwater discharge locations (Permit Part 7.2.4.g) - We observed a discharge location that was not identified on the SWPPP map that discharged into an offsite irrigation channel from a sediment basin located at the northwest perimeter of the Site. An irrigation ditch along the western perimeter of the Site and a drainage dewatering ditch along the northern perimeter of the Site discharged into the sediment basin (refer to Photographs 5 and 6). Locations of stormwater controls, including natural buffer areas and any shared controls utilized to comply with this permit (Permit Part 7.2.4.i) - We observed that the onsite SWPPP map displayed fiber rolls installed at the perimeters of the Site; however, we did not observe fiber rolls. On the southern perimeter of the Site we observed vegetated berms and soil berms. On the northern and northwestern perimeters of the Site we observed soil berms. We did not observe perimeter controls on the eastern perimeter of the Site, except along one perimeter south of the unstabilized soil stockpile that had a soil berm (refer to Attachment A, Photographs 1, 2, 3, 7, 8, and 9). 2. Permit Part 4.2 (Frequency of Inspections) At a minimum, you must conduct a site inspection in accordance with one of the two schedules listed below, unless you are subject to the Part 4.3 site inspection frequency for discharges to sensitive waters or qualify for a Part 4.4 reduction in the inspection frequency: 4.2.1 At least once every seven (7) calendar days; or 4.2.2 Once every 14 calendar days and within 24 hours of the occurrence of a storm event of 0.25 inches or greater, or the occurrence of runoff from snowmelt sufficient to cause a discharge. To determine if a storm event of 0.25 inches or greater has occurred on your site, you must either keep a properly maintained rain gauge on your site, or obtain the storm event information from a weather station that is representative of your location. For any day of rainfall during normal business hours that measures 0.25 inches or greater, you must record the total rainfall measured for that day in accordance with Part 4.7.1d. AND Permit Part 4.3 (Increase in Inspection Frequency for Sites Discharging to Sensitive Waters) Inspection Date: February 24, 2021 8 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report For any portion of the site that discharges to a sediment or nutrient-impaired water or to a water that is identified by your state, tribe, or EPA as Tier 2, Tier 2.5, or Tier 3 for antidegradation purposes (see Part 3.2), instead of the inspection frequency specified in Part 4.2, you must conduct inspections in accordance with the following inspection frequencies: Once every seven (7) calendar days and within 24 hours of the occurrence of a storm event of 0.25 inches or greater, or the occurrence of runoff from snowmelt sufficient to cause a discharge. To determine if a storm event of 0.25 inches or greater has occurred on your site, you must either keep a properly maintained rain gauge on your site, or obtain the storm event information from a weather station that is representative of your location. For any day of rainfall during normal business hours that measures 0.25 inches or greater, you must record the total rainfall measured for that day in accordance with Part 4.7.1d. (Area of Concern 2) We observed on page 42 of the SWPPP, that the Permittee had elected to conduct biweekly inspections plus inspections after qualifying rain events (i.e., greater than 0.25"in 24 hours) (refer to Attachment C). As stated in the NOI, due to stormwater discharging to Tenmile Creek and Fivemile Creek that are impaired for sediment, according to part 4.3 of the Permit, the Permittee must conduct weekly inspections plus inspections after qualifying rain events. It was noted that the Permittee had been conducting inspections at this frequency as observed in the inspection reports, however the SWPPP did not reflect the accurate frequency (refer to Attachment D). We observed gaps in between Site inspections that were greater than 7 days. We observed a 12-day gap between an inspection conducted on 1/20/2021 and an inspection conducted on 2/2/2021; an 8-day gap between an inspection on 2/2/2021 and an inspection 1/10/2021; and another 8-day gap between an inspection on 2/16/2021 and 2/24/2021 (refer to Attachment D). 3. Permit Part 7.2.10 (SWPPP Certification) You must sign and date your SWPPP in accordance with Appendix I, Part I.11. (Area of Concern 3) During the onsite records review, we observed that the Delegation of Authority Form located in Appendix J of the SWPPP was not signed. The Form was completed, but not signed or dated, under the name Jon Wardle of Brighton Development, Inc. (refer to Attachment B, Exhibit 3). Field Observation Areas of Concern 4. Permit Part 2.2.5 (Erosion and Sediment Control Requirements) Inspection Date: February 24, 2021 9 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Manage stockpiles or land clearing debris piles composed, in whole or in part, of sediment and/or soil: a. Locate the piles outside of any natural buffers established under Part 2.2.1 and away from any stormwater conveyances, drain inlets, and areas where stormwater flow is concentrated; b. Install a sediment barrier along all downgradient perimeter areas; c. For piles that will be unused for 14 or more days, provide cover or appropriate temporary stabilization (consistent with Part 2.2.14); d. You are prohibited from hosing down or sweeping soil or sediment accumulated on pavement or other impervious surfaces into any stormwater conveyance, storm drain inlet, or water of the U.S. AND SWPPP Part 4.3 (Sediment track out, erosion and sediment control #8- stockpile management) "Locate stockpiles a min of 50 ft away from concentrated flows of stormwater, drainage courses, and inlets Protect all stockpiles from stormwater run-on using a temporary perimeter sediment barrier such as berms, dikes, fiber rolls, silt fences, sandbags, or gravel bags Implement wind erosion control practices as appropriate on all stockpiled material. Place bagged materials on pallets and under cover." (Area of Concern 4) We observed three unstabilized soil stockpiles on site that did not have sediment barriers installed on all the down gradient perimeter areas. The stockpiles were located on the northeastern perimeter of the Site, the southwest perimeter of the Site, and the north-central perimeter of the Site. Additionally, the stockpiles located on the southwest and north-central perimeters of the Site were located within 50 ft from the concentrated flows from the irrigation canal and the dewatering ditch (refer to Attachment A, Photographs 1 through 4). 5. Permit Part 2.2.3 (Install sediment controls along any perimeter areas of the site that will receive pollutant discharges.) a. Remove sediment before it has accumulated to one-half of the above-ground height of any perimeter control. b. Exception. For areas at "linear construction sites" (as defined in Appendix A) where perimeter controls are infeasible (e.g., due to a limited or restricted right-of-way), implement other practices as necessary to minimize pollutant discharges to perimeter areas of the site. Inspection Date: February 24, 2021 10 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report (Area of Concern 5) We observed a lack of perimeter control measures implemented on the eastern and southwestern perimeters of the Site (refer to Attachment A, Photographs 1, 3, and 7). Tire tracks were additionally observed in the unnamed irrigation ditch located on the western perimeter of the Site that receives Site drainage (refer to Attachment A, Photograph 9). A soil berm was observed south of the unstabilized soil stockpile along the northeastern perimeter of the Site (refer to Attachment A, Photograph 2). The Inspection Team noted during the document review that while the SWPPP described various BMPs that could be used as perimeter controls (e.g. silt fence, fiber rolls) no cohesive plan on how perimeter control would be maintained was included. Section IV - Closing Conference We held a closing conference at the conclusion of the inspection at approximately 2:30 p.m. During the closing conference, we clearly stated that this summary of observations (i.e., areas of concern) was "preliminary" and subject to addition, deletion, and/or modification. The summary of preliminary inspection observations and areas of concern were communicated with the Site Representatives, Mr. Meyers and Mr. Wheaton of Brighton Development, Inc. Area of Concern 1 - The SWPPP Site map did not include all minimum required information; Area of Concern 2 - Inspection frequency not reflective of Permit requirements in SWPPP and gaps of more than 7 days in between Site inspections; Area of Concern 3 - The Delegation of Authority Form was not signed; Area of Concern 4 - Unstabilized soil stockpiles did not have a sediment barriers installed on the down gradient perimeter areas; Area of Concern 5 - Lack of perimeter control measures; The closing conference concluded at approximately 2:40 p.m. Inspection Date: February 24, 2021 11 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Attachment A - Photograph Log and Photos Photograph Log The photographs were taken during the inspection by Mr. Steven Chase, PG Environmental, and Kelly Davis, ERG Inc., U.S. EPA Contractors, Nikon Coolpix W300 digital camera and a Nikon Coolpix A900. Original copies of the photos are on file. Inspection Date: February 24, 2021 12 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Soil stockpile Site perimeter Photograph 1. View, facing southwest, of the Site's northeastern perimeter (photograph taken from off site). Note the lack of perimeter controls and the unstabilized soil stockpile that lacked sediment barriers installed on the down gradient perimeter area to the east. Site perimeter Soil berm Soil stockpile Photograph 2. Another view, facing west, of the Site's northeastern perimeter (photograph taken from on site). Note the soil berm on the southern side of the unstabilized stockpile. Inspection Date: February 24, 2021 13 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Site perimeter and irrigation channel Soil stockpile Photograph 3. View, facing north, of the irrigation channel along the western perimeter of the Site along South Eagle Road . Note the lack of perimeter control and the unstabilized soil stockpile that lacked sediment barriers installed on the down gradient perimeter areas. Soil stockpile Dewatering ditch Photograph 4. View, facing northeast, of the dewatering ditch installed along the northern perimeter of the Site. Note the soil stockpile located adjacent to the dewatering ditch and the lack of sediment barriers installed on the down gradient perimeter areas. Inspection Date: February 24, 2021 14 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Discharge location Irrigation Channel Sediment basin Direction of flow Photograph 5. View, facing north, of the irrigation channel leading to the sediment basin located on the northwest perimeter of the Site. Note the signs of previous containment of water and the discharge point from the northwest perimeter. Discharge location Sediment basin Direction of flow Dewatering ditch Photograph 6. Another view, facing north, of the sediment basin located on the northwest perimeter of the Site. Note the dewatering ditch leading to the basin, signs of previous containment of water, and the discharge point from the northwest perimeter. Inspection Date: February 24, 2021 15 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Site perimeter Photograph 7. View, facing south, of the southeast perimeter of the Site (photograph taken from off site). Note the lack of perimeter controls. Soil berm Vegetated berm Photograph 8. View, facing west, of the southern perimeter of the Site (photograph taken from off site). Note the use of berms as perimeter controls. Inspection Date: February 24, 2021 16 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Moisture Tire tracks Soil berm Site perimeter and irrigation channel Photograph 9. View, facing northwest, of the irrigation channel on the northwestern perimeter of the Site along South Eagle Road. Note the moisture and the tire tracks in the irrigation channel and the soil berm. Inspection Date: February 24, 2021 17 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Attachment B - Exhibit Log Inspection Date: February 24, 2021 18 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Discharge point Sediment basin Site Dewatering ditch Site Entrance Irrigation ditch Exhibit 1. Google maps (imagery copyright 2021). Location of Hill's Century Farm North Subdivision No. 2 in Meridian, Idaho. Note the approximate Site perimeter outlined with the dotted yellow line. Inspection Date: February 24, 2021 19 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Exhibit 2. Image of the Site map provided to the Inspection Team during the onsite inspection (image was cropped to focus on map details). It was noted the Site map does not contain all Permit-required elements, such as locations of stockpiles, drainage patterns of stormwater and authorized non-stormwater, authorized non-stormwater discharge locations, and updated perimeter controls. Inspection Date: February 24, 2021 20 Hill's Century Farm North Subdivision No. 2 Construction Stormwater Inspection Report Exhibit 3. Image of the unsigned Delegation of Authority that was observed during the onsite records review. Note that the form was completed by Jon Wardle of Brighton Development, Inc. but not signed or dated. Inspection Date: February 24, 2021 21