Document 3Q7DrdbQ0Xz4v4Y3rZBbOY8ba
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2
290 BROADWAY NEW YORK, NY 10007-1866
September 27, 2023
Via Electronic Mail To: rritterson@deptford-nj.org
Rob Ritterson, Superintendent Department of Public Works Deptford Township 1011 Cooper Street Deptford, NJ 08096
Re: REQUEST FOR INFORMATION, Pursuant to Section 308 of the CWA Docket. No. CWA-IR-23-011 Deptford Township MS4 NJPDES Permit No. NJG0152153 EPA Compliance Inspection - July 26, 2023 & July 27, 2023 (Virtual Audit), August 2, 2023 (Field Inspection)
Dear Superintendent Ritterson:
The purpose of this Request for Information ("RFI") letter is to require you to submit information to the United States Environmental Protection Agency ("EPA") regarding the municipal separate storm sewer system ("MS4") operated and maintained by Deptford Township.
Section 308(a) of the Clean Water Act ("CWA"), 33 U.S.C. 1318(a), provides that whenever it is necessary to carry out the objectives of the CWA, including determining whether or not a person/agency is in violation of Section 301 of the CWA, 33 U.S.C. 1311, EPA shall require the submission of any information reasonably necessary to make such a determination. Under the authority of Section 308 of the CWA, EPA may require the submission of information necessary to assess the compliance status of any facility/site and its related appurtenances.
On July 26 - 27, 2023, and August 2, 2023, EPA conducted a Compliance Evaluation Inspection ("CEI") of Deptford Township's (the "Township") MS4 program. The purpose of the CEI was to evaluate the Township's compliance with the conditions and limitations of the New Jersey Department of Environmental Protection ("NJDEP") New Jersey Pollutant Discharge Elimination System R9 - Tier A Municipal Stormwater General Permit. Enclosed is a copy of EPA's CEI report detailing the findings and observations of the CEI, including Potential Non-Compliance Items and Areas of Concern.
REQUEST FOR INFORMATION
The Township is hereby required, pursuant to Section 308(a) of the CWA, 33 U.S.C. 1318(a), to submit the following no later than sixty (60) calendar days of receipt of this RFI:
Internet Address (URL) http://www.epa.gov Recycled/Recyclable Printed with Vegetable Oil Based inks on Recycled Paper (Minimum 25% Postconsumer)
1. A written response describing how the Township has addressed or will address the Potential NonCompliance Items and Areas of Concern in the enclosed CEI report, including a corrective action plan and timeframe for addressing the Potential Non-Compliance Items.
CERTIFICATION
Any documents to be submitted by you must be sent by certified mail or its equivalent and shall be signed by an authorized representative of the respective entity (see 40 C.F.R. 122.22), and shall include the following certification:
"I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitted false information, including the possibility of fine and imprisonment for knowing violations."
All information required to be submitted by this RFI shall be sent by email to the following EPA and NJDEP representatives:
Justine Modigliani, P.E., Chief CWA Compliance Section, Water Compliance Branch
Enforcement and Compliance Assurance Division US EPA Region 2
Modigliani.Justine@epa.gov with copy to
Arvizu.Christy@epa.gov
and
Bryan Barrett, Bureau Chief Bureau of Water Compliance & Enforcement - Southern
NJDEP Bryan.Barrett@dep.nj.gov
with copy to Eileen.Kull@dep.nj.gov
Failure to provide the required information may subject the facility to civil/criminal penalties pursuant to Section 309 of the CWA. Failure to comply with the RFI shall also subject the facility to ineligibility for participation in work associated with Federal contracts, grants or loans.
We look forward to the Township's cooperation in this matter. If you have questions regarding the RFI, or CEI report, please feel free to contact Christy Arvizu of my staff via e-mail at arvizu.christy@epa.gov or via phone at (212) 637-4224.
Sincerely,
Digitally signed by DOUGHLAS
DOUGHLAS MCKENNA MCKENNA
Date: 2023.09.27 16:18:37 -04'00'
Doughlas McKenna, Chief Water Compliance Branch
Enclosure
cc: Thomas Newman, Deptford Township, Township Manager (twpmanager@deptford-nj.org) Bryan Barrett, Bureau Chief, Southern Bureau of Water Compliance and Enforcement, NJDEP (Bryan.Barrett@dep.nj.gov) Eileen Kull, Southern Bureau of Water Compliance and Enforcement, NJDEP (Eileen.Kull@dep.nj.gov) Justine Modigliani, Chief, CWA Section, EPA Region 2 (Modigliani.Justine@epa.gov)