Document m3MJL2GQBRvXRkQd7a78DqmO
EPA REGION 10 Enforcement and Compliance Assurance Division INSPECTION REPORT
Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection
04/05/2023 11:00 AM (PT) Announced: No 04/05/2023 02:45 PM (PT) Access: Granted 50F, Clear Water Clean Water Act, NPDES, Stormwater - Construction Compliance Evaluation Inspection
Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County Facility GPS Coordinates
Harbor Customs Development, Inc. Olympic Sunset View Apartments 81 NE Ridge Point Blvd Belfair, Washington 98528 Mason 47.455405, -122.818175
FRS ID Permit Number SIC
WAT6759445305 WAR309504 1522 (Multifamily housing construction (pt))
Lead Inspector:
RAYMOND ANDREWS Date: 2023.06.12 15:09:05 -07'00' Digitally signed by RAYMOND ANDREWS
Raymond Andrews
EPA Region 10
andrews.raymond@epa.gov (206) 553-4252
Supervisor Review:
PETER CONTRERAS Date: 2023.06.12 15:43:00 -07'00' Digitally signed by PETER CONTRERAS
Peter Contreras
EPA Region 10
contreras.peter@epa.gov
(206) 553-6708
SECTION I - Opening Conference
I arrived at the Olympic Sunset View Apartments (the "Site" or "Facility"), located at 81 NE Ridge Point Boulevard, Belfair, Washington, at 11:00 AM (PT) on 04/05/2023 for an unannounced inspection. I presented my credentials to Dustin Larson and informed him I was there to conduct an inspection to determine compliance with the Clean Water Act (CWA) and the Washington Department of Ecology (WDOE) Construction Stormwater General Permit. (CGP). This report is based on information supplied by Olympic Sunset View Apartments representatives, direct observations made by me, and records and reports maintained by the permittee. In addition, information gathered prior to, or after, the inspection from a review of EPA, State, and/or public records may be included in this report.
Olympic Sunset View Apartments Permit # WAR309504
NOTE: During post-inspection follow-up, Mr. Scott Anderson notified me that Mr. Larson was no longer associated with the project. As the Director of Development, Mr. Anderson is the Responsible Official for this project. He is also the Construction Erosion and Sediment Control Lead (CESCL) for the project.
Attendees
Organization
EPA Region 10 Harbor Custom Development, Inc. Harbor Custom Development, Inc.
Attendee Name Raymond Andrews
Scott Anderson Dustin Larson
Title
Lead Inspector Director of Development
Superintendent
Present in Opening Conf.
Yes
Present in Closing Conf.
Yes
No
No
Yes
Yes
Site Information
Operator Name
DRK Development, Inc
Disturbed Area
Approximately 4 acres
Site Receiving Water Irene Creek
Outfall
The site only has a single outfall that drains all stormwater into a stormwater retention pond. Once the stormwater in the retention pond reaches a certain level, it flows to a second off-site pond through the vertical outlet in the retention pond and then the stormwater flows to Irene Creek.
Construction start and projected end dates
Phase 1 of the project started in March 2021. The projected end of Phase 1 is June 2023. Phase 2 of the project will consist of constructing 5 buildings and the installation of road overlays.
Current Phase of Construction
At the time of inspection, the project was nearing the end of Phase 1. Phase 1 consisted of paving the first road and construction of 7 buildings. To complete Phase one, the site needs to finish inside of constructed buildings and landscaping.
Is there a signed SWPPP onsite?
There was a Stormwater Pollution Plan (SWPPP), dated January 2021, available on-site.
Inspection Frequency
Weekly routine inspections are conducted on-site.
Date of most recent At the time of the inspection, the most recent routine site inspection had been
self-inspection
conducted the week of March 27th.
Is the site required The site is required to conduct turbidity sampling. The samples are collected by
to conduct turbidity Mr. Anderson, the site CESCL, conducts turbidity sampling weekly and during rain
sampling?
events of over half an inch of accumulation.
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Olympic Sunset View Apartments Permit # WAR309504
SECTION II - Observations At the time of inspection, it appeared that the site had addressed all the WDOE concerns listed in the state's inspection report of September 20, 2021.
I did not observe any areas of concern during the site tour.
SECTION III - Records Review
Records may not be in sequential order.
Record: Other - Washington Department of Ecology (WDOE) Inspection Report
AOC: No
Ref #: RA1-RR-008 Reviewed By: Raymond Andrews
Reviewed Date: 06/06/2023
I reviewed an inspection report, dated September 20, 2021, for an inspection conducted at the site by the WDOE. The report had several areas of concern related to the site's failure to implement Best Management Practices (BMPs) including, drain slopes, plastic cover, and detention ponds not installed, rill and gully erosion observed throughout site, unstabilized stockpiles, and sediment discharges observed off-site. This inspection led to the state issuing the site a Notice of Penalty with an attached penalty of $1,000.
Record: Other - Stormwater Pollution Prevention Plan (SWPPP) Map
AOC: Yes
Ref #: RA1-RR-007 Reviewed By: Raymond Andrews
Reviewed Date: 04/05/2023
At the time of the inspection, I reviewed the site's SWPPP map. The map is being used as a living document and is being updated periodically. However, the map appears to be missing some elements required by the permit. The SWPPP map is missing the locations of structural and non-structural BMPs; approximate slopes, contours, and direction of stormwater flow before and after major grading activities; and areas where final stabilization has been accomplished and no further construction-phase permit requirements apply.
Record: SWPPP
AOC: No
Ref #: RA1-RR-006 Reviewed By: Raymond Andrews
Reviewed Date: 04/05/2023
At the time of the inspection, I reviewed the site's Stormwater Pollution Prevention Plan (SWPPP), dated January 5, 2021. The SWPPP appeared to have all the minimum required elements.
Record: Other - Washington Department of Ecology (WDOE) Notice of Penalty
AOC: No
Ref #: RA1-RR-005 Reviewed By: Raymond Andrews
Reviewed Date: 04/07/2023
I reviewed a Notice of Penalty, dated September 20, 2021, issued by the WDOE. The Notice of Penalty was issued because the site failed to implement all Best Management Practices (BMPs) as required by the permit. The site was issued a $1,000 fine.
Record: Other - Facility Site Inspection Form
AOC: No
Ref #: RA1-RR-004 Reviewed By: Raymond Andrews
Reviewed Date: 04/05/2023
At the time of the inspection, I reviewed the most recent facility site inspection form, dated March 24, 2023. The inspection had been conducted by Scott Anderson, the project's Certified Erosion and Sediment Control Lead (CESCL). The inspection report contained the minimum required elements.
Record: Other - EPA's Integrated Compliance Information System (ICIS) Database
AOC: No
Ref #: RA1-RR-003 Reviewed By: Raymond Andrews
Reviewed Date: 06/05/2023
Upon review of data in EPA's ICIS database from June 1, 2018, through May 31, 2023, I found the site had exceeded its turbidity benchmarks for the monitoring periods ending September 30, 2021, and March 31, 2022.
Exceeding the benchmark is not a concern because the site followed the reporting procedures and protocols required by the permit.
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Olympic Sunset View Apartments Permit # WAR309504
Record: Other - EPA's Integrated Compliance Information System (ICIS) Database
AOC: Yes
Ref #: RA1-RR-002 Reviewed By: Raymond Andrews
Reviewed Date: 06/05/2023
Upon review of data in EPA's ICIS database from June 1, 2018, through May 31, 2023, I found the site had failed to sample, analyze, or report pH data for monitoring period ending on September 30, 2021.
SECTION IV - Sampling Activities No sampling was conducted.
SECTION V - Areas of Concern Areas of Concern may not be in sequential order.
The presentation of Areas of Concern does not constitute a formal compliance determination or violation
AOC Reference #: RA1-RR-002 Permit Requirement
Records Review: Other - EPA's Integrated Compliance Information System (ICIS) Database
Permit Part S5.B, "Permittees required to conduct water quality sampling in accordance with Special Conditions S4.C (Turbidity/Transparency), S4.D (pH), S8 (303[d]/TMDL sampling), and/or G12 (Additional Sampling) must submit the results to Ecology."
AOC:
After the inspection, I reviewed EPA's ICIS data from June 1, 2018, through May 31, 2023. I found the site failed to sample, analyze, or report pH data for monitoring period ending on September 30, 2021.
AOC Reference #: RA1-RR-007 Permit Requirement
Records Review: Other - Stormwater Pollution Prevention Plan (SWPPP) Map
Permit Part S9.E, "The SWPPP must also include a legible site map (or maps) showing the entire construction site. The following features must be identified, unless not applicable due to site conditions...3. Approximate slopes, contours, and direction of stormwater flow before and after major grading activities...5. Locations of structural and nonstructural controls (BMPs) identified in the SWPPP...10. Areas where final stabilization has been accomplished and no further construction-phase permit requirements apply."
AOC:
The SWPPP map, shown below, was missing the locations of structural and non-structural BMPs; approximate slopes, contours, and direction of stormwater flow before and after major grading activities; and areas where final stabilization has been accomplished and no further construction-phase permit requirements apply.
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Olympic Sunset View Apartments Permit # WAR309504
SECTION VI - Closing Conference I held a closing conference with Mr. Larson at 02:45 PM (PT) on 04/05/2023. During the closing conference, I discussed my observations and the Areas of Concern I identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - List of Appendices
1. Photo Log
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APPENDIX 1: Photo Log
All photos were taken by Lead EPA Inspector, Ray Andrews, during the inspection.
Photos were not manipulated beyond minor cropping for sizing and labels or callouts to draw attention to the subject of the photo.
All photos taken during the inspection are included in the Photo Log; however, only photos that support an Area of Concern are included in the inspection report.
P1010694 - Construction Stormwater Site Inspection Form, page 1 P1010695 - Construction Stormwater Site Inspection Form, page 2 P1010696 - Construction Stormwater Site Inspection Form, page 3 P1010697 - Construction Stormwater Site Inspection Form, page 4 P1010698 - Construction Stormwater Site Inspection Form, page 5 P1010699 - SWPPP Site Diagram/Map P1010700 - SWPPP Signature Page P1010701 - Downslope Facing Highway 3, photo 1 P1010702 - Downslope Facing Highway 3, photo 2 P1010703 - Phase 2 Slabs (Foreground), Complete Phase 1 Houses (Background), photo 1 P1010704 - Phase 2 Slabs (Foreground), Complete Phase 1 Houses (Background), photo 2 P1010705 - Property Edge, Mounds Covered with Plastic and/or Straw, photo 1 P1010706 - Property Edge, Mounds Covered with Plastic and/or Straw, photo 2 P1010707 - Property Edge, Mounds Covered with Plastic and/or Straw, photo 3 P1010708 - Wide View of Stormwater Retention Pond P1010709 - Inlet Pipes in Retention Pond (Barely Visible on Far Edge) P1010710 - Vertical Outlet in Retention Pond