Document 2RzkXvR0XOyd7Dp9dwrad3N16

Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Site/Facility Name: Permittee(s): Site/Facility Operator: Site/Facility Address: Latitude: County/Parish: Permit Number: NAICS Code: DSB ID : Clean Water Act Compliance Inspection Report 05/01/2024 National Pollutant Discharge Elimination System (NPDES) Construction Stormwater WMATA Northern Bus Garage Replacement Project Clark Construction Group LLC Clark Construction Group LLC 4615 14th Street NW Washington D.C. 20011 38.947653 N Longitude: 77.031926 W District of Columbia DCR1000A7 411101 SIC: 485111 ECAD-5462 Site/Facility Representative(s): Daryl Lloyd Phone: (240) 935-1515 Paul Pinkard Phone: (202) 345-0362 Zane Wolf Phone: (443) 826-1498 EPA Inspectors: Shane McAleer Phone: (215) 814-5616 Brian Tolton Phone: (215) 814-3291 Johannah Jacobson Phone: (215) 814-2318 State/Local Inspectors: Brent Levy Phone: (202) 329-7138 Email: Email: Point of Contact Daryl.lloyd@clarkconstruction.com Paul.pinkard@clarkconstruction.com Email: zane.wolf@clarkconstruction.com Email: Mcaleer.Shane@EPA.gov Email: Tolton.Brian@EPA.gov Email: Jacobson.Johannah@EPA.gov Email: Brent.Levy@DC.gov Report Preparer Signature/Date SHANE MCALEER Digitally signed by SHANE MCALEER Date: 2024.06.20 14:08:00 -04'00' Shane McAleer Environmental Engineer, 3ED33 Date Supervisor Signature/Date JESSICA DUFFY Digitally signed by JESSICA DUFFY Date: 2024.06.20 14:04:13 -04'00' Jessica Duffy, NPDES Section 2 Chief, 3 ED33 Date DSB ID: ECAD-5462 Clark Construction Group LLC/WMATA Northern Bus Garage Replacement Project 05/01/2024 Table of Contents Section Page I Introduction............................................................................ 3 A Inspection Opening Conference...................................................................... 3 Weather and Precipitation 3 B Conditions............................................................. C Summary of the Facility.................................................................................. 4 II Site Activity..................................................................................................... 4 III Observations.................................................................................................... 4 IV Closing Conference......................................................................................... 6 V Records Review ......................................................................................... 6 VI List of Attachments.......................................................................................... 7 Unique Project #: ECAD-5462 Page 2 of 8 Clark Construction Group LLC/WMATA Northern Bus Garage Replacement Project 05/01/2024 I. Introduction On May 1, 2024, an inspection team composed of staff from the U.S. Environmental Protection Agency ("EPA") Region 3 and a representative of the Department of Energy and Environment ("DOEE") (hereinafter, referred to as the "EPA Inspection Team") conducted a construction stormwater inspection of the Washington Metropolitan Area Transit Authority (WMATA) Northern Bus Garage Replacement site (hereinafter, "the site"). The purpose of the inspection was to observe compliance with the Clean Water Act (CWA) and to verify compliance with the site's National Pollutant Discharge Elimination System (NPDES) Permit No. DCR1000A7 (hereinafter, the "Permit") and applicable State and Federal regulations. A. Inspection Opening Conference The EPA Inspection Team arrived at the site at est. 13:45 for the inspection. Inspectors met with the following site representatives: Name Shane McAleer Brian Tolton Johannah Jacobson Daryl Lloyd Paul Pinkard Zane Wolf Brent Levy Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region 3 Inspectors and Contractors EPA Inspector (215) 814- Mcaleer.Shane@EPA.gov 5616 EPA Inspector (215) 814- Tolton.Brian@EPA.gov 3291 EPA Inspector (215) 814- Jacobson.Johannah@EPA.gov 2318 Site/Facility Representatives Clark Construction (240) 935- Daryl.lloyd@clarkconstruction.com 1515 Clark Construction (202) 345- Paul.Pinkard@clarkconstruction.com 0362 Clark Construction (443) 826- Zane.Wolf@clarkconstruction.com 1498 State or County Representatives DOEE (202) 329- Brent.Levy@DC.gov 7138 The EPA inspection team displayed their credentials to Clark Construction Representaives at the outset of the inspection, and explained the purpose of the inspection was to observe compliance with its Permit. A copy of the Permit is provided in Attachment 1. During the opening conference, the EPA Inspection Team reviewed Permit documentation included in the site stormwater pollution prevention plan (SWPPP) binder. The EPA Inspection Team informed Clark Construction that any information that the Facility deemed to be confidential business Unique Project #: ECAD-5462 Page 3 of 8 Clark Construction Group LLC/WMATA Northern Bus Garage Replacement Project 05/01/2024 information ("CBI") should be identified to EPA representatives during the inspection and it would be handled as CBI according to EPA's CBI procedures. B. Weather and Precipitation Conditions During the inspection, weather was clear and sunny [description of the weather]. National Oceanic and Atmospheric Administration (NOAA) National Weather Service precipitation data for the date of the inspection and 5 days prior are provided in the Table 2 below: Table 2. Precipitation Data Station Name Date WASHINGTON 5.1 NW, DC US (US1DCDC0014) WASHINGTON 5.1 NW, DC US (US1DCDC0014) WASHINGTON 5.1 NW, DC US (US1DCDC0014) WASHINGTON 5.1 NW, DC US (US1DCDC0014) WASHINGTON 5.1 NW, DC US (US1DCDC0014) WASHINGTON 5.1 NW, DC US (US1DCDC0014) 4/26/2024 4/27/2024 4/28/2024 4/29/2024 4/30/2024 5/1/2024 Precipitation Amount (inches)1 0 0 0.06 0 0 0.35 C. Summary of the Site/Facility The WMATA Northern Bus garage project is an active construction site located on an approximately 6.0-acre parcel of land bordered by Decatur Street to the north, Iowa Avenue on the northeast, Arkansas Avenue on the east, Buchanan Street on the south, and 14th Street on the west. The project entails the reconstruction of an existing WMATA bus facility. The new WMATA Northern Bus garage facility will have the capacity to store 150 zero emission buses. Clark Construction is currently on Phase II of construction and estimated construction to be completed by December 2026. II. Site Activity After the opening conference, the EPA performed a site walk. During the site walk, the EPA Inspection Team observed: the site perimeter, the site interior, and the existing stormwater controls on the interior of the site and along the site boundaries. The EPA Inspection Team was escorted by representatives from Clark Construction. The inspection observations were made pursuant to the requirements of the Permit. The observations from the inspection are 1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Unique Project #: ECAD-5462 Page 4 of 8 Clark Construction Group LLC/WMATA Northern Bus Garage Replacement Project 05/01/2024 described in detail below in the Observations section. Photographs were taken during the inspection by Johannah Jacobson, and are provided in Attachment 2. III. Observations Permit requirement Section 2.3.3 subsection C. " Have a spill kit available on site that is in good working condition (i.e., not damaged, expired, or used up) and ensure personnel are available to respond immediately in the event of a leak or spill." Observation 01: The Inspection team observed that a spill kit was not located near the site vehicle fueling tank (see Photo 23 in Attachment 2). The only spill kit on-site was located near the site entrance. Inspection Follow-up: Clark Construction submitted a photo showing that the spill kit was moved adjacent to the site vehicle fueling tank (see Photo 24 in Attachment 2). Permit requirement Section 2.1.4 "Ensure all stormwater controls are maintained and remain in effective operating condition during permit coverage and are protected from activities that would reduce their effectiveness." Observation 02: The Inspection team observed construction equipment, trash and other debris piled up on the curb line of the site boundary along Iowa and Arkansas Streets, upstream of silt socks designed to control sediment from entering the curb inlet at the corner of Arkansas and Buchanan Streets (See Photo 17 in Attachment 2). Inspection Follow-up: Clark Construction submitted a photo showing that the construction equipment and debris were removed and this area on the curb line was cleaned up (see Photo 18 in Attachment 2). Permit requirement Section 2.2.4 "Minimize sediment track-out." Observation 03: Unique Project #: ECAD-5462 Page 5 of 8 Clark Construction Group LLC/WMATA Northern Bus Garage Replacement Project 05/01/2024 The Inspection team observed a cattle grate installed at the site entrance which was designed to reduce sediment track-out. The grate was full of stone and sediment (See Photo 19 in Attachment 2).. Inspection Follow-up: Clark Construction submitted a photo showing that cattle grate was cleaned out and the stone and sediment was removed (See Photo 20 in Attachment 2). Permit Requirement 2.3.4 subsection b. "Do not allow liquid wastes to be disposed of through infiltration or to otherwise be disposed of on the ground" Observation 04: The Inspection team observed concrete slurry spillover outside of a concrete wash out containment bin near the entrance of the site (see Photo 21 in Attachment 2). Inspection Follow-up: Clark Construction submitted a photo showing that the concrete slurry spill outside of the concrete wash out containment was cleaned up (see Photo 22 in Attachment 2). IV. Closing Conference After the site walk, the EPA Inspection Team met with the site representatives for a closing conference. The EPA Inspection Team shared preliminary observations with the facility. The EPA Inspection Team reiterated to the facility representatives that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by EPA upon the additional review of records and documentation. The EPA Inspection Team stated they would be requesting records as a follow up to the inspection and that additional observations may be contained in this inspection report that were not identified at the time of the closing conference, as a result of the records request. The inspection concluded at 15:30 V. Records Review The EPA Inspection Team requested Permit documentation, which was provided by Clark Construction on March 14, 2024. The documentation includes: the site SWPPP (see Unique Project #: ECAD-5462 Page 6 of 8 Clark Construction Group LLC/WMATA Northern Bus Garage Replacement Project 05/01/2024 Attachment 3); the site Erosion and Sediment Control (ESC) plan (see Attachment 4); the site self-inspection reports over the last 4 months (see Attachment 5); and the site's Notice of Intent (NOI) (see Attachment 6). Note that the NOI was provided as an Appendix in the SWPPP. The remaining SWPPP appendices were too large to include in this report but are available upon request. Clark Construction submitted photographic evidence of corrective actions performed as a result of the EPA Inspection Team's preliminary observations. The photographs indicating the corrective actions were received by the EPA on Friday 5/3/2024 and are reflected in this inspection report. Unique Project #: ECAD-5462 Page 7 of 8 Clark Construction Group LLC/WMATA Northern Bus Garage Replacement Project 05/01/2024 VI. List of Attachments Attachment 1: Attachment 2: Attachment 3: Attachment 4: Attachment 5: Attachment 6: NPDES Permit Photograph Log SWPPP Erosion and Sediment Control Plan Self-Inspections Notice of Intent Unique Project #: ECAD-5462 Page 8 of 8