Document 70MqQB7KpJZJNeD86OZkB8wOo

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III Four Penn Center - 1600 John F. Kennedy Blvd. Philadelphia, Pennsylvania 19103 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: General Permit #: Site Specific Permit #: NAICS Code: Unique Project #: Clean Water Act Compliance Inspection Report 06/22/2022 National Pollutant Discharge Elimination System (NPDES) Municipal Stormwater Borough of Steelton MS4 Borough of Steelton Borough of Steelton 123 North Front Street Steelton, PA 17113 40.2359 Longitude: -76.8417 Dauphin PAG-13 PAG133625 924110 SIC: 9511 3E22WN088A Facility Representative(s): Point of Contact Jeffrey Baltimore - Borough of Steelton Public Works Director Phone: (717) 585-3120 Email: jbaltimore@steeltonpa.com EPA Inspectors: Shane McAleer - EPA Region 3 Phone: (215) 814-5616 Email: mcaleer.shane@epa.gov Chuck Schadel - EPA Region 3 Phone: (215) 814-5761 Email: schadel.chuck@epa.gov State/Local Inspectors: Scott Arwood - Pennsylvania Department of Environmental Protection Phone: (717) 783-0368 Email: sarwood@pa.gov Leah Staley - Pennsylvania Department of Environmental Protection Phone: (717) 705-4814 Email: lestaley@pa.gov Heather Dock - Pennsylvania Department of Environmental Protection Phone: Email: hdock@pa.gov Report Preparer Signature/Date SHANE MCALEER Digitally signed by SHANE MCALEER Date: 2022.08.09 11:07:21 -04'00' Shane McAleer, Enforcement Officer NPDES Enforcement Section (3ED32) 8/9/22 Date Supervisor Signature/Date MICHAEL Digitally signed by MICHAEL GREENWALD GREENWALD 10:54:30 -04'00' Date: 2022.08.10 Michael Greenwald, Acting Section Chief NPDES Enforcement Section, (3ED32) 8/10/22 Date Unique Project#: 3E22WN088A Borough of Steelton MS4 06/22/2022 Table of Contents I. Introduction ................................................................................................................................. 3 A. Inspection Opening Conference ............................................................................................. 3 B. Weather and Precipitation Conditions.................................................................................... 4 II. Site/Facility Activity ................................................................................................................. 4 III. Observations ............................................................................................................................. 5 IV. Records Review ........................................................................................................................ 6 V. Closing Conference.................................................................................................................... 6 Attachment A: Attachment B: Attachment C: Attachment D: List of Attachments Photograph Log NPDES General Permit Steelton Borough 2020 and 2021 Annual Reports PCSWM BMP Plans Unique Project #: 3E22WN088A Page 2 of 6 Borough of Steelton MS4 06/22/2022 I. Introduction On June 22, 2022, an inspection team composed of staff from the U.S. Environmental Protection Agency (EPA) Region III (hereinafter, "EPA Inspection Team") met with representatives of the Pennsylvania Department of Environmental Protection (PADEP) at the Borough of Steelton ("Borough" or "Steelton") Maintenance Yard at 282 Christian Street, Steelton, PA. At the Maintenance Yard, the EPA Inspection Team met with Jeff Baltimore, Steelton Public Works Director, and Randy Watts, Borough Engineer from Herbert, Rowland, & Grubic, Inc. (HRG) and explained the purpose of the visit was to perform a compliance evaluation inspection (CEI) of the Borough's Municipal Separate Storm Sewer System (MS4) program to assess compliance with National Pollutant Discharge Elimination System (NPDES) General Permit No. PAG133625, issued by PADEP, effective date May 1, 2018. The Inspection Team conducted an inspection of minimum control measures (MCMs) 5 and 6 of the Borough's MS4 program and a review of the Borough's Annual Reports regarding MCM 3. The EPA Inspection Team inspected the Borough's Maintenance Yard, which contained the Maintenance Shop/Lab/Garage (referred to as "Maintenance Shop"), as well as the one post construction stormwater management (PCSWM) best management practice (BMP) that was identified by the Borough prior to the inspection. The photographs for this report have been processed in order to assign to each photo the original camera-generated file name (e.g., IMAG0032) and the date and time the photo was taken (e.g., 2022-06-22--15.53.01). The camera-generated file name is used to identify each photo in the main narrative of this inspection report. Unused photos are digitally stored and maintained in the inspection file. Unused photos are available upon request. A. Inspection Opening Conference The EPA Inspection Team arrived at the Borough-owned facility (Maintenance Yard) located at 282 Christian Street at approximately 1:30 PM for the announced inspection. Chuck Schadel and Shane McAleer of the EPA identified themselves to the Borough Representatives, displayed their credentials and described the purpose of the compliance inspection. The EPA Inspection Team with Borough representatives then walked and inspected the facility. The Inpsection Team's observations are listed later in this document and are grouped by type of observation made. Name Shane McAleer Chuck Schadel Jeffrey Baltimore Randy Watts Scott Arwood Leah Staley Heather Dock Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region III Inspectors and Contractors EPA Region III (215) 814-5616 mcaleer.shane@epa.gov EPA Region III (215) 814-5761 schadel.chuck@epa.gov Site/Facility Representatives Borough of Steelton (717) 585-3120 jbaltimore@steeltonpa.com HRG - - State or County Representatives PADEP (717) 783-0368 sarwood@pa.gov PADEP (717) 705-4814 lestaley@pa.gov PADEP - hdock@pa.gov Unique Project #: 3E22WN088A Page 3 of 6 Borough of Steelton MS4 06/22/2022 B. Weather and Precipitation Conditions During the inspection, weather was partly sunny. 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 1 below: Table 1. Precipitation Data Station Name Date Carlisle Water Plant, PA US USC00361920 Carlisle Water Plant, PA US USC00361920 Carlisle Water Plant, PA US USC00361920 Carlisle Water Plant, PA US USC00361920 Carlisle Water Plant, PA US USC00361920 Carlisle Water Plant, PA US USC00361920 06/17/2022 06/18/2022 06/19/2022 06/20/2022 06/21/2022 06/22/2022 Precipitation Amount (inches)1 0.0 0.0 0.0 0.0 0.0 0.09 II. Facility Activity The Borough of Steelton is in Dauphin County, Pennsylvania. The Borough is approximately 4 miles southeast of the City of Harrisburg and is bordered by (and encompassed within) the Township of Swatara to the north and Township of Lower Swatara to the south. The Susquehanna River is a few hundred feet west of the Borough, with Cumberland County to the northwest and York County to the southwest. The Borough has an area of 1.9 square miles and a population of 6,263 residents, according to the 2020 census. According to the Borough's Operations and Maintenance Plan, updated March 2019, there are 17 Borough-owned facilities and activities requiring operations and maintenance, including the Maintenance Yard (listed as "Maintenance Garage" in the Annual Report) which was inspected. According to the Borough's MS4 Annual Report for 2021, the only PCSWM BMP in the Borough is an underground infiltration basin owned by Steel Works LLC ("Steel Works"), which was observed during the inspection. Prior to the inspection, the EPA Inspection Team requested the design plans for the Steel Works PCSWM BMP from the Borough and the 2020 and 2021 Borough MS4 Annual Reports from PADEP. The Annual Reports were provided and reviewed prior to the inspection to assess for compliance with the General Permit. The Steel Works design plans were provided during the inspection and reviewed. The EPA Inspection Team inspected two locations during the inspection: 1) the Municipal Yard, which included the Maintenance Shop; and 2) the Steel Works PCSWM BMP. The observations made by the EPA Inspection Team are identified below. 1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Unique Project #: 3E22WN088A Page 4 of 6 III. Observations Borough of Steelton MS4 06/22/2022 Location #1 - Maintenance Yard During the inspection of the Maintenance Yard, the EPA inspection Team walked the Yard and parking lot and observed the Maintenance Shop, which included a washbay containing floor drains, an Oil / Water Seperator (OWS), and the Salt Storage Barn. Good Housekeeping MCM 6 of the General Permit states "The permittee must develop and implement an O&M program that includes a training component and has the ultimate goal of preventing and reducing pollutant runoff from operations, facilities and activities under the control of the permittee" MCM 6 best management practice (BMP) 2 of the General Permit states "The written O&M program shall stress pollution prevention and good housekeeping measures, contain site-specific information, and include the following: ... Controls for reducing or eliminating the discharge of pollutants from streets, roads, highways, municipal parking lots, maintenance and storage yards, waste transfer stations, fleet or maintenance shops with outdoor storage areas, salt / sand (antiskid) storage locations and snow disposal areas..." Observation #1: During the inspection of the Maintenance Yard, staining was observed on the pavement outside of the Maintenance Shop where it is potentially exposed to stormwater transport. The conditions at the time of inspection can be observed in photos DSCN3405 and DSCN3406 of the Photo Log. Drainage contours from this area appeared to direct flow towards an inlet located in Christian Street. The inlet was observed to contain a filter sock (see photo DSCN3414). The washbay for the Maintenance Shop was observed, which contained floor drains that lead to the OWS (see photo DSCN3409). Jeff Baltimore, Borough Public Works Director, stated that the staining was the result of leaking of hydraulic fluid from a blown hydraulic line on a street sweeper owned by the neighboring municipality Swatara Township. The leaking street sweeper was on loan by Swatara Township in order to perform Borough street sweeping while the Borough's street sweeper was being serviced. Observation #2: During the inspection of the Maintenance Yard, salt was observed on the pavement outside of the Salt Storage Barn where it is potentially exposed to stormwater transport. The conditions at the time of inspection can be observed in photos DSCN3411, DSCN3412, and DSCN3413 of the Photo Log. Dry Weather Screening The General Permit requires "For new permittees, all of the identified regulated small MS4 outfalls shall be screened during dry weather at least twice within the 5-year period following approval of coverage under this General Permit" and that "...for existing permittees, each of the identified regulated small MS4 outfalls shall be screened during dry weather at least once by March 15, 2023." Unique Project #: 3E22WN088A Page 5 of 6 Borough of Steelton MS4 06/22/2022 Observation #3: According to the 2020 and 2021 Annual Reports, the Borough, which is an existing permitee, conducted dry weather screening on all 30 Borough MS4 outfalls in the past five years. Three of the MS4 outfalls were dry weather-screened in 2020, and an additional three MS4 outfalls were screened in 2021. The dry weather screening reports conducted in 2020 and 2021 are contained in the Annual Reports (See Attachment C). Location #2 - Steel Works PCSWM BMP The EPA Inspection Team inspected the one Borough PCSWM BMP identified by the Borough and listed in the Borough 2020 and 2021 Annual Reports, which was an underground infiltration basin located at the Steel Works parking lot. See photos DSCN3415, DSCN3416, and DSCN3421 of the Photo Log. Operation and Maintenance of PCSWMBMPs BMP 3 of MCM 5 of the General Permit requires municipalities to "Ensure adequate O&M of all post-construction stormwater management BMPs that have been installed at development or redevelopment projects that disturb greater than or equal to one acre..." Observation #4: The plans for the Steel Works PCSWM BMP were provided by the Borough and reviewed by the EPA Inspection Team during the inspection (see photo DSCN3418). During the field inspection, the visible components of the BMP appeared to match the plans. IV. Records Review The EPA Inspection Team reviewed the 2020 and 2021 Annual Reports for Steelton Borough, which contained, among other items, the Operations and Maintenance Plan for the Borough. The EPA Inspection Team also reviewed the General Permit and the Steel Works PCSWM BMP plans. V.Closing Conference At the conclusion of the field inspection, the EPA Inspection Team conducted a closing conference with Borough representatives and shared preliminary observations. The EPA Inspection Team reiterated to the Borough representatives that all preliminary observations discussed were not compliance determinations. Preliminary observations shared with the Borough are subject to further investigation by EPA, including additional review of records and documentation. As a result, additional observations may be contained in this inspection report that were not identified at the time of the closing conference. The inspection concluded at approximately 2:15 PM (EDT). Unique Project #: 3E22WN088A Page 6 of 6