Document yre7xbNMg35GNzRxJM6y0G0Br

UNITED STATES AGENCY ENVIRONMENTAL PROTECTION REGION 1 BOSTON, MA 02109 Date:Dated as shown on electronic signature(s) Subj:Inspection Report Clean Water Act - National Pollutant Discharge Elimination System (" NPDES ") Stiles and Hart Brick Company From:Eleanor Horvath, Inspector Thru:Alex Rosenberg, Acting Manager, Water Technical Unit 1 Digitally signed by To:FileALEX ROSENBERG Artby Date: 2024.09.26 I. Facility Information 16:35:41 -04'00 ' A. Facility Name:Stiles and Hart Brick Company B. Facility Location:127 Cook St # 3307, Bridgewater, MA 02324 C. Facility Contacts:Lincoln Andrews, Owner, Stiles and Hart Brick Company Jim Maltais, Operations Manager, Stiles and Hart Brick Company Renee Andrews, Stiles and Hart Brick Company D. NPDES ID No (s).: None II. Background Information A. Date(s) of inspection: September 3, 2024 B. Weather Conditions: Sunny, 70 degrees Fahrenheit C. US EPA Representative(s): Alex Rosenberg, Clean Water Act Inspector, U.S. EPA Region 1 Eleanor Horvath, Clean Water Act Inspector, U.S. EPA Region 1 ED_019088A_00005663-00001 Margarita Chatterton, Clean Water Act Inspector, U.S. EPA Region 1 Davianna Vasconcelos, Clean Air Act Inspector, U.S. EPA Region 1 Grace Perry, Clean Air Act Inspector, U.S. EPA Region 1 D. State / Local Representative(s): None E. Federally Enforceable Requirements Covered During the Inspection: EPA 2021 Multi - Sector General Permit EPA Spill Prevention, Control, and Countermeasure (SPCC) rule F. Previous Enforcement Actions: None III. Type and Purpose of Inspection Permit Applicability Evaluation IV. Facility Description The site is approximately 142 acres, including offices, manufacturing facilities, mining areas, and open space. It is surrounded by open space to the east and west and state- owned correctional facilities to the north. The site is bordered by the Taunton River to the south and east, with open space, agricultural land, and a residential development across the river in neighboring Middleborough. V. Inspection Inspector Rosenberg called Mr. Lincoln Andrews on Thursday, August 29th, the week before the inspection. Mr. Andrews granted access and said he would be onsite to accompany EPA on the inspection. EPA arrived at the facility at approximately 10:00 AM. A. Opening Conference Mr. Andrews met EPA onsite, along with his wife, Ms. Renee Andrews, and Mr. Jim Maltais, the facility's Operations Manager. The opening conference began at approximately 10:15 AM. All EPA inspectors presented their credentials. Inspector Rosenberg explained the purpose of the inspection, and discussed general and Clean Water Act - related details of the facility with Mr. Andrews. Following this, Inspector Vasconcelos asked Mr. Andrews questions regarding the Clean Air Act. Mr. Andrews gave a comprehensive description of the facility and its activities as they relate to both the Clean Water and Clean Air Acts. Mr. Andrews described the following aspects of the facility and its activities: 2 ED_019088A_00005663-00002 The brick manufacturing process is comprised of the following steps: mining, mixing, forming, drying, and firing. The site has potable well water, and a number of septic fields for the discharge of sewerage. Water is used sparsely in the manufacturing processes, primarily for the washing of brick molds, as cutting lubricant, and when necessary to increase the humidity of the raw product. Recycle systems are in place for all washing and / or cutting waters. No process water (i.e., industrial wastewater) is discharged offsite from the industrial processes. * There are no storm drains onsite, nor floor drains in the manufacturing facilities. The facility uses a small amount of oil to run onsite equipment and stores oil in two above ground storage tanks: one for fueling onsite vehicles / machinery (estimated volume of 1,500 gallons), and the other to run a diesel pump (estimated at 150 gallons). B. Facility Tour The group began the site walk by touring the manufacturing facilities and surrounding outdoor areas. Mr. and Ms. Andrews were not present for this portion of the inspection. From the offices where the opening conference was held, the group walked south, approaching the western side of the manufacturing buildings. EPA observed a large double - walled tank as well as other evidence of industrial activities (e.g., stockpiles of bricks and coal, other tanks, equipment / machinery, waste material) throughout the yard (see photos 14-19, 53, 55-61, 64-71). The group briefly entered the building to observe aspects of the brick cutting system with its water recycler (see photos 62-63). Inspectors explained the requirement under oil regulations (specifically, the Spill Prevention, Control and Countermeasure Rule, or SPCC) to inspect all aboveground storage tanks and their associated systems of containment on a monthly basis, and to conduct integrity testing for certain types of tanks on the frequency specified in the regulations. Mr. Maltais explained that although industrial activities are exposed to stormwater (i.e., not under cover) in this area, there is a large earthen berm south of the manufacturing facilities and yard that prevents any stormwater from running offsite into the nearby Taunton River. While walking east along the southern edge of the facility, EPA observed this berm between manufacturing areas and the river through a densely vegetated buffer zone. At the southeastern corner of the manufacturing area, a railway track formed an additional berm for the impedance of stormwater flow. The railway crossed the river via a bridge. EPA inspectors observed that the southern earthen berm ended approximately 20 feet from the railway along the shore of the river. Where the berm was not present 3 ED_019088A_00005663-00003 stormwater could potentially discharge to the river. Photographs of this area were captured and no evidence of material transport along this conveyance path was observed (see photos 50-52). The group then entered the manufacturing building. EPA observed kilns, brick dryers, the burner room, the brick machine, the transfer machine, the pug mill, the carousel, and many bricks in various statuses of production (see photos 23-27, 31-36, 38-39, 41- 49). EPA noted the presence of oil - filled operational equipment associated with many of the pieces of equipment within the building (see photos 28-30, 37, 40), and mentioned to facility representatives the need to include them in their SPCC plan when any individual tank has a capacity of 55 gallons or greater. An area at the center of the building is open to the elements between two distinct sections of roofing (see photos 21-22). Bricks are being staged in this area. Mr. Maltais explained that stormwater falling on this uncovered area, as well as stormwater from the building's roof gutters, flow into a subterranean cistern at the center of the building complex and then infiltrates into the ground. From the manufacturing buildings, the inspection group walked west along a gravel roadway toward the mining ponds. The first body of water (" Pond A ") was observed through dense vegetation to the south of the gravel road (see photo 13), approximately 0.15 miles from the buildings. Mr. Maltais described this as an old pit that was no longer used. After walking approximately 0.4 miles from the manufacturing buildings, the group approached an area of more recent mining. At this point in the inspection, Mr. and Ms. Andrews reunited with the group. EPA observed a pump being used to move water from the southeasternmost pond (" Pond B "), and a diesel tank with an approximate capacity of 100 gallons associated with the pump (see photos 4-7, 9-11). Mr. Maltais explained that water is pumped from Pond B into an adjacent pond to the northeast (" Pond C "), from which water flows by gravity drainage through a culvert into the pond to the North (" Pond E "). Another area northeast of Pond B, south of Pond A, was entirely dry (see photo 8 and figure 1). This dry area is where facility representatives stated mining activities are currently being conducted. Facility representatives further explained that when mining activities are to be conducted in Pond B, water must be removed via the pump to enable the removal of clay by dragging a claw along the ground and loading the aggregated material into a dump truck. 4 ED_019088A_00005663-00004 St Hicut Pond E Pond A Pond C Pond D Outfall Pump location Pond B Figure 1. Aerial image of mining areas with ponds labeled. The group walked counterclockwise around Pond D from the pump location, and observed the location where Pond E discharges on occasion into the Taunton River. Inspector Tedder observed the discharge location through very dense vegetation (see photos 1-2). Facility representatives stated that discharge into the river from Pond E usually occurs a few times per year, dependent on seasonal rainfall amounts. Inspectors observed no stormwater conveyance paths offsite from mining activities. Inspectors explained that under the industrial stormwater permit, the discharge of mine dewatering water is permitted if treated by an appropriate control (MSGP Part 1.2.2.3.c.). Inspectors observed no turbidity or a suspended solids (the pollutant of concern for mining activities) in Pond E near the discharge location. Inspectors discussed that this was likely due to the pollutant treatment train that is being implemented (the long - distance flowpath to increase settling due to longer residence time within Ponds C and E). The group walked back northeast from the discharge location toward the manufacturing buildings and offices, where the site tour was concluded. C. Closing Conference The closing conference occurred at approximately 2:30 PM. Inspector Rosenberg thanked Mr. Andrews, Ms. Andrews, and Mr. Maltais for their time. He then explained that there are two programs under the Clean Water Act whose regulations might apply to the facility: the Multi - Sector General Permit (MSGP) and the Spill Prevention, Control and Countermeasure Rule (SPCC). Inspector Rosenberg described MSGP applicability and the process of applying for MSGP coverage, should it be determined that the facility requires it. It was explained that if stormwater associated with industrial activities do not discharge offsite (e.g., by ensuring that a permanent berm completely surrounds all industrial activities), then the permit does not apply to those respective activities. 5 ED_019088A_00005663-00005 Regarding oil regulations (SPCC), inspectors noted that an oil storage capacity above the regulatory applicability threshold was observed onsite, and therefore an SPCC plan must be drafted and implemented. EPA indicated that they would be following up with an inspection report within 60 days. EPA departed at approximately 3:30 PM. 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. VI. Inspection Photos Photo Log PageField - Level Image Descriptions t well Small diesel tank 1823D5r6y7 00i n4 ,t5haPt um pd Piith roescet ion 9All the clay is gone 10Other end of pump and tank 11 Pump 12 Stockpile 13Old pit through tree 14Unused drag line 15Old tank 16 Stuff 17This is am old stack 18Label on tank 19Water truck 20Drainage gaps in floor 21Pitched into gutters and cistern, which infiltrates 22Gutters drain into cistern down there 23Another angle of carousel 24This is the carousel 25Brick machine gears 26Vents from dryers 6 ED_019088A_00005663-00006 27Pug mill 28, 29Hydraulic tank for brick mover 30Transfer machine tank 31Little leak 32 Tank 33 Tanks 34 Dryers 35Buckets and stuff 36 Label 37There's a tank in there 38 Tanks 39Brick machine. Was last running last Thursday Hydraulic tank might need SPCC (this is for brick 40 matching; Alex estimates over 55 gallons) 41,42 System 43 Bricks 44These are drying 45Burner room 46Smells like gas around here 47 Dryers 48 Kiln 49 kiln 50Slope from river 51Edge of river 52 River 53 Piles 543 of 4 exhaust stacks from dryers 55 Air 56Waste material etc 57Coal stockpile 58 Piles 59Engine label 60Pallets and coal 61Pump engine 62Closer on room 63Brick cutting system with water recycler 64Small example stockpile 65Small tanks 66Tank wide angle 67More tank stickers 68Sticker on tank 69 Tank 7 ED_019088A_00005663-00007 70 Tank 71 Tank 8 00 ED_019088A_00005663-00008