Document 0LkebJeVvw6yY6nN7VbJnbj0O

EPA REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 04/28/2025 1:15 PM (CT) Announced: No 04/28/2025 4:00 PM (CT) Access: Granted Sunny and close to 50 degrees Fahrenheit (F) Water Clean Water Act, NPDES, Stormwater - Industrial Industrial Stormwater Inspection (ISI) Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County Facility GPS Coordinates Mailing Address City, State, Zip Code United States Postal Service (USPS) - Green Bay Vehicle Maintenance Facility (VMF) USPS Green Bay VMF 300 Packerland Drive Green Bay, Wisconsin 54303 Brown 44.533978, -88.097475 Same as site address Same as site address FRS ID Permit Number SIC and/or NAICS 110005420552 WIR051IA05 4311 - USPS Regulatory Representatives Participating in Inspection: Title Name N/A N/A Organization N/A Lead Inspector: Danny Nguyen EPA REGION 5 nguyen.danny@epa.gov 06/18/2025 (440) 250-1709 Supervisor Review: Mr. Brooke Furio BROOKE FURIO Digitally signed by BROOKE FURIO Date: 2025.06.18 13:14:15 -04'00' EPA REGION 5 furio.brooke@epa.gov (440) 250-1705 1 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 SECTION I - INTRODUCTION Site Entry and Inspection Objectives EPA REGION 5 inspector, Danny Nguyen, arrived at United States Postal Service Green Bay VMF (USPS GB VMF), located at 300 Packerland Drive, Green Bay, Wisconsin 54303, at 1:15 PM (CT) on 04/28/2025 for an unannounced inspection. Mr. Nguyen presented his credentials to Mr. Christopher Dallas and informed him that this was an EPA REGION 5 inspection to investigate elements of the Clean Water Act (CWA) and applicable regulations. This report is based on information supplied by USPS GB VMF's representatives, direct observations made by the EPA REGION 5 inspectors, records and reports maintained by the permittee and other information including: photographs taken by EPA REGION 5 inspectors, physical evidence collected by the EPA REGION 5 inspectors, measurements taken by EPA REGION 5 inspectors, verbal or written statements made by information supplied by USPS GB VMF's representatives during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA REGION 5 inspectors by USPS GB VMF's representatives during or subsequent to the on-site inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization EPA REGION 5 USPS GB VMF USPS GB VMF USPS GB VMF Attendee Name Danny Nguyen Christopher Dallas Joseph Green Chris Dewolfe Title NPDES Inspector Acting Manager Supervisor Vehicle Maintenance Manager Present in Opening Conf. Yes Yes Yes Present in Closing Conf. Yes Yes Yes Yes Yes Facility/Site Description EPA REGION 5 inspector confirmed the following Facility information: USPS GB VMF applied for and was issued a General Permit to Discharge Under the United States Environmental Protection Agency (EPA) National Pollution Discharge Elimination System NPDES ID WIR05IA05. The USPS GB VMF facility is located within the main USPS Green Bay property boundaries located at 300 Packerland Drive address. The USPS GB VMF conducts maintenance (oil changes, engine maintenance, tire changes) on a variety of different USPS vehicles such as small USPS trucks, Long Life Vehicles (LLVs), Mercedes-Benz Metris compact vans, and the Promaster trucks (largest). The action area for the facility's stormwater discharges extends downstream from the facility via the City of Green Bay storm sewer system. The facility's drainage connects to the city's storm sewer system along Packerland Drive and flows in an easterly direction ultimately discharging to the Beaver Dam Creek. Best management practices (BMPs) employed include frequent sweeping and housekeeping around the production areas and on the outside. Inspections and monitoring are conducted by Mr. Chris Dewolfe. The USPS GB VMF's stormwater program is separate from the main USPS stormwater program. 2 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 Facility/Site Information Responsible official Christopher Dallas Verify SIC Code 4311 Personnel conducting Chris Dewolfe (previous manager) inspections/sampling Sampling locations Discharge points 001, 002, and 003 Copy of the SWPPP Yes. On-site Number of employees 15 (VMF Building) Receiving Water Beaver Dam Creek Number/location of Stormwater Inlets/ Outfalls/Drains including near docks or storage areas and where they initially drain (MS4, ditch detention basin) There are three main discharge points on the property (001, 002, and 003). Discharge point 002 is located on the southwest side of the property just outside of the wash bay, 003 is located south in between the VMF and the main USPS facility, and 001 is north of discharge point 003. The site area is comprised of mainly asphalt parking and roadways; and building footprint space. There is one main covered outdoor storage area for used tires and old equipment. The tires are stored on wheeled carts. Stormwater on the property flows southeasterly to the City of Green Bay storm sewer along Packerland Drive. BMPs/Stormwater Treatment Frequent sweeping and good housekeeping around the production areas and on the outside. Industrial activities exposed to stormwater Vehicle maintenance and washing; tire and old equipment storage; oil storage Industrial Sector/Sub- P/P1 sector Type of Operation USPS Shifts/Hours/Days of Two shifts operating between 6:00AM to 10:00PM, Monday through Friday Operations/Shutdowns Size of Facility 0.82 acres Is the SWPPP team Yes present Name of the person engaging with the inspector Christopher Dallas Type of materials Small USPS trucks, Long Life Vehicles (LLVs), Mercedes-Benz Metris compact vans, and and/or vehicles stored the Promaster trucks (largest); New and used oil; Old tires and equipment outdoors 3 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 Location(s) Location/Area/Sub-area Outdoor area Indoor area Description The outdoor area consists of approximately 0.82 acres of asphalt roadways and parking. The indoor area consists of vehicle wash bay, auto repair and paint shop, fluid storage, battery storage, and vehicle maintenance areas SECTION II - OBSERVATIONS Location: Outdoor area Observation #: DN1-OB-001 Date: 04/28/2025 Weather: Sunny and close to 50 degrees F EPA observed the following during the walkthrough of the outdoor area: At discharge point 002 drain on the southeast side of the property, Mr. Nguyen observed an underground pipe flowing into the drain from the south. Facility representatives did not know where the pipe source was from or if it flowed from the adjacent property south of property boundary. On the west side of the property, Mr. Nguyen observed some old broken and degraded vehicle chocks on the ground west of discharge point 002. At the covered storage area, Mr. Nguyen observed used tires stored on wheeled carts and old equipment. Some of the used tires and old equipment were observed to be exposed and not under cover. Starting outside on the north side of the VMF, Mr. Nguyen observed two 275-gallon oil storage tanks. Mr. Dallas stated the tanks were double walled. One tank held new oil and the other tank held used oil. On the northeast side of the VMF building and southwest of the main USPS building, Mr. Nguyen observed the discharge point 001 drain. On the east side of the VMF building and southwest of the main USPS building, Mr. Nguyen observed discharge point 003 drain. Mr. Nguyen observed pallets, trash roll-off bin, and an outside covered storage area just outside the main USPS building. Mr. Dallas stated the storage area is managed by separate personnel at the main USPS building. 4 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 Photos 1. DSCN1050.JPG 2. DSCN1051.JPG 3. DSCN1052.JPG 4. DSCN1053.JPG 5. DSCN1054.JPG 6. DSCN1055.JPG 7. DSCN1056.JPG 8. DSCN1057.JPG 9. DSCN1058.JPG 10. DSCN1059.JPG 11. DSCN1061.JPG 12. DSCN1076.JPG Location: Outdoor area Observation #: DN1-OB-002 Date: 04/28/2025 Weather: Sunny and close to 50 degrees F EPA observed the following during the walkthrough of the indoor area: In the vehicle wash bay, a drain was observed and Mr. Nguyen inquired where the washwater drains. Mr. Dallas stated the washwater drains to a concrete oil/water separator that is separate from the oil/water separator used in the auto body shop. A third party contractor (Safety Kleen) cleans out the wash bay drains and all other inside drains quarterly. Mr. Nguyen observed the auto body repair and paint shop. He observed a drain on the floor and asked if the drain stops inside the bay. Mr. Dewolfe stated the auto body shop has its own oil/water separator and is also cleaned out quarterly by Safety Kleen. Mr. Nguyen observed containers in the fluid storage room on secondary containment. There was a floor drain observed inside the room that was stated to also go to the concrete oil/water separator. Mr. Nguyen observed used battery storage with secondary containment in the storage room. In the vehicle maintenance area, Mr. Nguyen observed an oil filter crusher/press and a sink drain used for transfer of used oil to the outside oil storage tank. 5 of 35 USPS Green Bay VMF Inspection Date: Photos 1. DSCN1049.JPG 2. DSCN1060.JPG 3. DSCN1063.JPG 4. DSCN1064.JPG 5. DSCN1065.JPG 6. DSCN1066.JPG 7. DSCN1067.JPG 8. DSCN1068.JPG 9. DSCN1069.JPG 10. DSCN1070.JPG 11. DSCN1071.JPG 12. DSCN1072.JPG 04/28/2024 SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: SWPPP Ref #: DN1-RR-001 Reviewed By: Danny Nguyen AOC: Yes Reviewed Date: 04/28/2025 The latest SWPPP dated 2021 was reviewed and the following observations were made: The SWPPP included several emergency contacts who have transitioned or retired. Road map for location of the facility was not included in the SWPPP. Record: Personnel Training Ref #: DN1-RR-002 Reviewed By: Danny Nguyen AOC: No Reviewed Date: 5/12/2025 Stormwater and SWPPP content training was reviewed. Mr. Joseph Green provided the training slides and stated all employees have to go through the training. Record: Routine Inspections Ref #: DN1-RR-003 Reviewed By: Danny Nguyen AOC: Yes Reviewed Date: 04/28/2025 Last quarterly inspection was conducted in November 2021 per written inspection checklist. No further documentation has been provided of quarterly routine inspections conducted before and after November 2021. 6 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 Record: Quarterly Visual Assessment of Stormwater Discharges Ref #: DN1-RR-004 Reviewed By: Danny Nguyen AOC: Yes Reviewed Date: 04/28/2025 No quarterly visual assessments were observed. Mr. Dewolfe stated that since a third party (Atlas) conducts the facility's quarterly monitoring sampling and analysis, that would take the place of the quarterly visual assessment and inspection. Therefore, they stopped doing quarterly visual assessments. No further documentation was provided of quarterly visual assessments. Record: Monitoring Ref #: DN1-RR-005 Reviewed By: Danny Nguyen AOC: No Reviewed Date: 04/28/2025 Quarterly sampling and analysis reports in NetDMR were reviewed. SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION V - AREA OF CONCERN Areas of Concern (AOC) may not be in sequential order. The presentation of Areas of Concern does not constitute a formal compliance determination or violation. AOC Reference #: DN1-OB-001 Location: Outdoor area Regulation and/or Permit Requirement Section 2.1.2.2 of the EPA Multi-Sector General Permit (MSGP) requires "The permittee must keep clean all exposed areas that are potential sources of pollutants. You must perform good housekeeping measures to minimize pollutant discharges." AOC: On the west side of the property, Mr. Nguyen observed some old broken and degraded vehicle chocks on the ground west of discharge point 002. At the covered storage area, Mr. Nguyen observed used tires stored on wheeled carts and old equipment. Some of the used tires and old equipment were observed to be exposed and not under cover. 7 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 AOC Reference #: DN1-RR-001 Record: SWPPP Regulation and/or Permit Requirement Section 6 of the EPA Multi-Sector General Permit (MSGP) requires "The permittee must keep their SWPPP up-to-date throughout their permit coverage." AOC: The SWPPP included several emergency contacts who have transitioned or retired. Road map for location of the facility was not included in the SWPPP. AOC Reference #: DN1-RR-003 Records: Routine Inspections Regulation and/or Permit Requirement Section 3.1 and 3.1.6 of the EPA Multi-Sector General Permit (MSGP) requires "The permittee must perform routine facility inspections of areas as covered by requirements in the permit" and to "document the findings of the inspections and maintain the reports in the SWPPP." AOC: Last quarterly inspection was conducted in November 2021 per written inspection checklist. No further documentation has been provided of quarterly routine inspections conducted before and after November 2021. AOC Reference #: DN1-RR-004 Records: Quarterly Visual Assessment of Stormwater Discharges Regulation and/or Permit Requirement Section 3.2.1, 3.2.2, and 3.2.3 of the EPA Multi-Sector General Permit (MSGP) requires "The permittee must once each quarter for your entire permit coverage collect a stormwater sample from each discharge point and conduct a visual assessment of each of those samples" by following the visual assessment procedures outlined in section 3.2.2, and to "document the results of the visual assessments and maintain the reports in the SWPPP." 8 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 AOC: No quarterly visual assessments were observed. Mr. Dewolfe stated that since a third party conducts the facility's quarterly monitoring sampling and analysis, that would take the place of the quarterly visual assessment and inspection. Therefore, they stopped doing quarterly visual assessments. No further documentation was provided of quarterly visual assessments. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA REGION 5 Inspector held a closing conference with the participants listed above at 03:35 PM (CT) on 04/28/2025 for the inspection. During the closing conference, Mr. Nguyen discussed the observations and Area(s) of Concern identified during the inspection. Observations and Area(s) of Concern have not yet been evaluated for a formal compliance determination. Mr. Dallas did not make a CBI claim. EPA communicated to Mr. Dewolfe that the inspection report will be emailed to him within 70 days of the day of the inspection. Follow Up The following items were requested by the inspector at the time of the inspection. Location: DN1-CC-FD Area: Sub-area: EPA requested a copy of the stormwater training given to employees. Received via email on 5/12/2025. DN1-CC-FD EPA requested all of 2020 and Summer of 2021 quarterly routine inspection reports. EPA did not receive requested documents. DN1-CC-FD EPA requested all sample lab analysis reports conducted for all three discharge points in the Fall of 2022 and all of 2023. EPA was able to view submitted reports on NetDMR. 9 of 35 USPS Green Bay VMF Inspection Date: SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 04/28/2024 10 of 35 USPS Green Bay VMF Inspection Date: APPENDIX 1: PHOTO LOG 04/28/2024 VMF - Vehicle Wash Bay 04/28/2025 2:03 PM No CBI Inside facing east Indoor drainage in the vehicle wash bay No PII DSCN1049.JPG Photographer: Danny Nguyen 44.533587, - 88.097773 11 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Discharge point 002 DSCN1050.JPG 04/28/2025 2:05 PM No CBI No PII Photographer: Danny Nguyen Outside facing south 44.533762, - 88.09735 Discharge point 002 drain just outside vehicle wash bay 12 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Discharge point 002 DSCN1051.JPG 04/28/2025 2:05 PM No CBI No PII Photographer: Danny Nguyen Outside facing west 44.533762, - 88.09735 Close up of discharge point 002 drain with piping from south 13 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Outside Area DSCN1052.JPG 04/28/2025 2:07 PM No CBI No PII Photographer: Danny Nguyen Outside facing west 44.533758 - 88.09775 Old vehicle chocks on the ground west of discharge point 002 drain 14 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Outside Area 04/28/2025 2:08 PM No CBI No PII Outside facing west Outdoor covered storage with old tires and equipment DSCN1053.JPG Photographer: Danny Nguyen 44.533913, - 88.09767 15 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Outside Area 04/28/2025 2:08 PM No CBI No PII Outside facing west Outdoor covered storage with old tires and equipment DSCN1054.JPG Photographer: Danny Nguyen 44.533913, - 88.09767 16 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Outside Area 04/28/2025 2:10 PM No CBI No PII Outside facing east Discharge point 001 drain west of main USPS building DSCN1055.JPG Photographer: Danny Nguyen 44.534338, - 88.097323 17 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Outside Area DSCN1056.JPG 04/28/2025 2:12 PM No CBI No PII Photographer: Danny Nguyen Outside facing southeast 44.534338, - 88.097323 Outside oil storage tanks piped into the VMF facility 18 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Outside Area 04/28/2025 2:15 PM No CBI Outside facing east Discharge point 002 drain No PII DSCN1057.JPG Photographer: Danny Nguyen 44.533758, - 88.096825 19 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Outside Area 04/28/2025 2:15 PM No CBI Outside facing north Discharge point 002 drain No PII DSCN1058.JPG Photographer: Danny Nguyen 44.533758, - 88.096825 20 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Outside Area 04/28/2025 2:15 PM No CBI No PII Outside facing north Outdoor storage area from main USPS building DSCN1059.JPG Photographer: Danny Nguyen 44.53378, - 88.096721 21 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Inside Area 04/28/2025 2:18 PM No CBI Inside facing south Auto repair and paint shop area No PII DSCN1060.JPG Photographer: Danny Nguyen 22 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Outside Area DSCN1061.JPG 04/28/2025 2:20 PM No CBI No PII Photographer: Danny Nguyen Opened discharge point 002 drain with underground pipe from south ** PHOTO DSCN1062.JPG WAS BLURRED AND IS NOT INCLUDED IN THE INSPECTION REPORT ** 23 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Inside Area 04/28/2025 2:21 PM No CBI Body repair and paint shop drain No PII DSCN1063.JPG Photographer: Danny Nguyen 24 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Inside Area 04/28/2025 2:23 PM Fluid Storage Room No CBI No PII DSCN1064.JPG Photographer: Danny Nguyen 25 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Inside Area DSCN1065.JPG 04/28/2025 2:23 PM No CBI No PII Photographer: Danny Nguyen Fluid Storage Room drain goes to oil/water separator 26 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Inside Area 04/28/2025 2:25 PM No CBI No PII Used batteries and equipment storage room DSCN1066.JPG Photographer: Danny Nguyen 27 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Inside Area 04/28/2025 2:26 PM No CBI No PII Oil/water separator in vehicle maintenance area DSCN1067.JPG Photographer: Danny Nguyen 28 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Inside Area 04/28/2025 2:38 PM No CBI Maintenance area drain No PII DSCN1068.JPG Photographer: Danny Nguyen 29 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Inside Area 04/28/2025 2:38 PM No CBI Main vehicle maintenance area No PII DSCN1069.JPG Photographer: Danny Nguyen 30 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Inside Area DSCN1070.JPG 04/28/2025 2:39 PM No CBI No PII Photographer: Danny Nguyen Used oil sink drain that goes into the outside used oil storage tank 31 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Inside Area 04/28/2025 2:40 PM No CBI Main vehicle maintenance area No PII DSCN1071.JPG Photographer: Danny Nguyen 32 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Inside Area 04/28/2025 2:40 PM No CBI Oil filter crusher and press No PII DSCN1072.JPG Photographer: Danny Nguyen ** PHOTOS DSCN1073-1075.JPG ARE PHOTOS OF SWPPP PAGES FOR OPERATION DESCRIPTIONS. PHOTOS ARE NOT INCLUDED IN THE REPORT** 33 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 VMF - Outside Area 04/28/2025 2:57 PM Outside facing south Entry sign into facility No CBI No PII DSCN1076.JPG Photographer: Danny Nguyen 44.53378, - 88.096721 34 of 35 USPS Green Bay VMF Inspection Date: 04/28/2024 APPENDIX 2: DOCUMENT LOG Document Type Document Document Name Contains CBI USPS- No SWPPPCourseTranscript- May-2025.pdf Contains PII No Sent/Uploaded By Joseph Green Date Received 5/12/2025 35 of 35