Document vVZ87LmZD4ovZ9mNX6qkp6eJR

* UNI TED e STAT ES AGENCY ENVIRONMRENETGALPI ROONTE C1T ION 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:Eleanor Horvath, U.S. Environmental Protection Agency Inspector Thru:Newton Tedder, U.S. Environmental Protection Agency Inspector To: FileDigitalElLyE ANsOiRg nEeLEdANOR bHORyVA TH I. Facility Information Date: 2025.01.22 A. Facility Name:Adams Landfill HClOoRsuVreA0T9:H2 1:36 -05'00 ' B. Facility Location:Crosby Road Grafton, MA 01519 C. Facility Contacts:Nicholas Mucci Business Development Director Clean Earth, Inc. 933 First Avenue, Suite 200 King of Prussia, PA 19406 Jennifer Moore Administrative Assistant Clean Earth, Inc. 933 First Avenue, Suite 200 King of Prussia, PA 19406 D. ID No (s).:N / A II. Background Information A. Date(s) of inspection: 12/05/2024 ED_019088A_00005867-00001 B. Weather Conditions: 37 degrees Fahrenheit, overcast. Snow on ground. C. US EPA Representative(s): Newton Tedder Eleanor Horvath D. State / Local Representative(s): N / A E. Federally Enforceable Requirements Covered During the Inspection: National Pollutant Discharge Elimination System Construction General Permit (" CGP "), Effective February 17th, 2022 F. Previous Enforcement Actions: N / A III. Type and Purpose of Inspection Evaluation IV. Facility Description Adams Landfill Closure is a prior landfill and current construction site in Grafton, Massachusetts (hereafter referred to as the " site "). The site comprises approximately five acres and is surrounded by residential areas to the north and west, open space to the south, and a wetland complex and stream, which is a tributary of the Quinsigamond River, to the east. V. Inspection A. Opening Conference Inspectors Newton Tedder and Eleanor Horvath arrived onsite at approximately 11:30 AM. They entered the construction trailer, introduced themselves to Ms. Jennifer Moore, presented their credentials, and explained the purpose of the inspection. Ms. Moore granted EPA site access and explained that she would gather copies of the site's permits and operator's contact information for review at the closing conference. Outside the construction trailer, EPA observed two signs facing the public roadway (Crosby Road) with information about the site and its permits (photo locations 95, 96). B. Facility Tour EPA began the site tour at the northwestern corner of the site near the construction trailer, walking clockwise around the outer perimeter of the site. There were silt fences along northern, eastern, and southern edges of the disturbed area. EPA observed locations where sediment- laden water had accumulated against the silt fence (photo locations 88, 100, 101) and / or silt fences had fallen (photo locations 88, 91, 100, 101, 104, 105, 107, 112). At the northeastern corner of the site, EPA observed a detention basin and its spillway pointing east toward the offsite stream and wetlands (photo locations 90, 102). Along the eastern edge of the site, Inspectors Tedder and Horvath observed wetlands and a streambed through a strip of trees 2 ED_019088A_00005867-00002 (photo location 91, 92), as well as what appeared to be wetland delineation flags approximately two feet from the disturbed area (photo location 93). The interior of the site was comprised of many large unstabilized stockpiles of soil. Heavy machinery (e.g., excavators) were actively working with stockpiles on the southern end of the site. The center of the site was approximately 30 feet higher in elevation than the silt fences around the edge, and the site was steeply sloped from the higher elevation to the lower along the eastern portion of the site toward the wetlands and stream (photo location 106, 110). At the site entrance, EPA observed considerable trackout from the site onto the public roadway (photo locations 94, 113). C. Closing Conference The closing conference occurred at approximately 12:05 PM in the construction trailer where the opening conference was held. Ms. Moore provided EPA a copy of the site's Wetlands permit from the Massachusetts Department of Environmental Protection, as well as the name and contact information of herself and her supervisor, Mr. Nicholas Mucci, the project manager. Mr. Mucci was on the phone for the closing conference, allowing EPA to ask further questions about the site. He explained that construction began around the spring of 2022. The near - term construction timeline includes an estimated six more months of soil import, followed by six months of the soil capping process. Portions of the site require 10 to 15 more feet of fill before they are at the target grade. Inspector Horvath asked Mr. Mucci whether the site would remain active through the winter, and he explained that they are unsure about whether the site will shut down some or all of its operations, as it depends on the demand for soil. Inspector Horvath then asked Mr. Mucci about the plan for the stockpiles in the meantime. Mr. Mucci stated that that the largest pile, near the construction trailer and the northern end of the site, would be inactive for the next month before it is relocated and then used later used in the capping process. Mr. Mucci explained that the capping process was expected to begin in approximately six months, after the soil import process concluded, and last for approximately six months after that before the site is stabilized. Inspector Horvath asked whether the site had a Stormwater Pollution Prevention Plan (" SWPPP ") - Mr. Mucci said that they likely had one somewhere in the trailer, but that he could send EPA a copy via email. Inspector Horvath told Mr. Mucci and Ms. Moore that they would receive an inspection report within 70 days of the inspection. She also indicated that she would be requesting a copy of the site's SWPPP over email and would likely have some follow - up questions for Mr. Mucci. EPA departed at approximately 12:15 PM. D. Inspection Photos Photo Location ID Field Description 3 ED_019088A_00005867-00003 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 4 ED_019088A_00005867-00004 114 115 116 92 96 95 94 Track out 93 Wetlands flags 91 00 90 Spillway 69 89 88 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. 5 ED_019088A_00005867-00005