Document mBD0myYaJJZxBx3wymqnOMGXB
* UNI TED * STA TESR UNE ITEG D SI TATEO S EN NVI RON1 MEN
TAL PROTECTION AGENCY
AGENCY5 POST OFFICE BSOSQTUOAN,R EMA, 02S1U09I-T39E1 2
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ONMENTALPROTECTION
VIA EMAIL
Date as per electronic signature
Chris Strickler
Chesapeake Development, LLC
746 D.W. Highway, Unit B
Merrimack, NH 03054
chris@cdcnh.com
Subject: August 5, 2021, U.S. Environmental Protection Agency Inspection
Dear Mr. Strickler:
On August 5, 2021, the U.S. Environmental Protection Agency (" EPA ") performed an inspection
at Highfield Commons Phase 1B in Rochester, NH. The EPA conducted this inspection to evaluate
compliance with the NPDES General Permit for Discharges from Construction Activities (2017
Construction General Permit). A copy of the inspection report is included as an attachment to this
letter.
Specific comments, informed by the inspection, are as follows:
1. The slope east of the new access road which runs from the end of Fillmore Boulevard
southeast to Hussey Hill Road must be adequately stabilized in accordance with Part
2.2.3 of the 2017 Construction General Permit; straw and plastic netting may not be
adequate if the straw washes away as has happened at other locations on the site.
2. Several spots on a slope to the northeast (leading down to the former antenna access
road) are severely eroded and must be stabilized in accordance with Part 2.2.3 of the 2017
Construction General Permit.
3. The concrete containment for the fuel tank / dispenser is cracked and crumbling on the
inside and may need to be replaced if it does not meet the requirements identified in Part
2.3.3.c of the 2017 Construction General Permit.
4. The stockpile north and east of Eisenhower drive, and surrounding areas, appear to have
been unstabilized for more than 14 days. See Part 2.2.14 of the Permit for stabilization
requirements.
5. A gravel site entrance or other sediment track - out control should be installed between
Hussey Hill Road and the new access road (and other places where sustained traffic will
be leaving the site or transitioning to paved roads). The track - out control near the storage
containers and fuel containers needs to be maintained in accordance with Part 2.2.4 of the
2017 Construction General Permit.
ED_019088A_00019737-00001
6. Several different companies have been identified in relation to this site. Please provide
the formal name of the company with day - to - day operational control of the site (e.g., they
are authorized to direct workers at the site to carry out activities required by the 2017
Construction General Permit; in most cases this is the project's general contractor).
Within 14 days of the date of this letter, please provide a response to EPA via email to Andrew
Spejewski at spejewski.andrew@epa.gov. The response should contain a written description and
pictures documenting how the items in 1 to 5 above have been addressed, along with a written
response to item 6 above. For technical questions, you may contact Andrew Spejewski of my
staff at (617) 918-1014 or spejewski.andrew@epa.gov. Legal issues may be directed to Tahani
Rivers, Enforcement Counsel, at rivers.tahani@epa.gov or at (617) 918-1299.
Sincerely,
Digitally signed by
NEIL
NEIL HANDLER
Date: 2021.08.26
HANDLER 11: 26: 28-04'00 '
Neil Handler
Senior Enforcement Coordinator
Water Compliance Section
Enforcement and Compliance Assurance Division
Enclosures: Inspection Report for August 5, 2021, U.S. EPA Inspection
CCs (electronic only):
Chris Strickler
Ed Pope
Tahani Rivers, U.S. EPA
Andrew Spejewski, U.S. EPA
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