Document 82J9Yre7JbND1akzOdby0dxam
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III
1650 Arch Street Philadelphia, Pennsylvania 19103-2029
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
04/20/2022
National Pollutant Discharge Elimination System (NPDES)
Municipal Stormwater
Mechanicsburg Borough MS4
Mechanicsburg Borough
Mechanicsburg Borough
36 West Allen Street
Mechanicsburg, PA 17055
40.241080
Longitude: -77.010210
Cumberland
PAG013
PAG133553
924110
SIC: 9511
3E22WN080A
Site/Facility Representative(s):
Point of Contact
C H Lehr
Phone: (717) 691-3318 Email: Chlehr@mechanicsburgborough.org
Greg Rogalski - Pennoni Associates (Borough Engineer)
Phone: (717) 620-5947 Email: grogalski@pennoni.com
EPA Inspectors:
Angela Weisel
Phone: (215) 814-2120 Email: Weisel.Angela@epa.gov
Chuck Schadel
Phone: (215) 814-5761 Email: Schadel.Chuck@epa.gov
Eddie Simas
Phone: (215) 814-2124 Email: Simas.Eddie@epa.gov
State/Local Inspectors:
Leah Staley - Pennsylvania Department of Environmental Protection
Phone: 717-705-4814
Email: lestaley@pa.gov
Gold, Peter Digitally signed by Gold, Peter Date: 2022.05.12 10:01:04 -04'00'
Report Preparer Signature/Date
Peter Gold, Enforcement Officer
Date
NPDES Enforcement Section (3ED32)
Supervisor Signature/Date
JESSICA DUFFY
Digitally signed by JESSICA DUFFY Date: 2022.05.12 12:51:24 -04'00'
Jessica Duffy, Acting Section Chief
NPDES Enforcement Section, (3ED32)
Date
Unique Project#: 3E22WN080A
Mechanicsburg Borough MS4 04/20/2022
Table of Contents I. Introduction ................................................................................................................................. 3
A. Inspection Opening Conference ............................................................................................. 3 B. Weather and Precipitation Conditions.................................................................................... 3 II. Site/Facility Activity ................................................................................................................. 4 III. Observations ............................................................................................................................. 4 IV. Records Review ........................................................................................................................ 5 V. Closing Conference.................................................................................................................... 5
List of Attachments
Attachment A: Photo Log
Attachment B: Attachment C:
Permit PCSWMBMP Plans
Unique Project #: 3E22WN080A
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Mechanicsburg Borough MS4 04/20/2022
I. Introduction
On April 20, 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 Mechanicsburg Borough Highway Garage at 108 West Allen Street Mechanicsburg, PA. At the facility, the EPA Inspection Team met with C H Lehr (Mechanicsburg Borough) and Greg Rogalski (Pennoni Associates, Borough Engineer). The Inspection Team was conducting an inspection of minimum control measures (MCMs) 5 and 6 of the borough's Municipal Separate Storm Sewer System (MS4) program and a review of MCM 3 from the borough's Annual Reports. The EPA Inspection Team inspected three post construction stormwater management best management practices (PCSWMBMPs) that were selected by the EPA Inspection Team prior to the inspection and the borough's municipal yard. 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., 2022-03-19--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 facility located at 108 West Allen Street at approximately 9:00 AM for the announced inspection. The EPA Inspection Team identified themselves to the Borough Representatives, displayed their credentials and described the purpose of the compliance inspection. The EPA Inspection Team with the Borough Representative then walked the facility and visited the four PCSWMBMPs. The Inpsection Team's observations are listed later in this document and are grouped by type of observation made.
B. Weather and Precipitation Conditions
During the inspection, weather was 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 2 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
04/15/2022 04/16/2022 04/17/2022 04/18/2022 04/19/2022 04/20/2022
Precipitation Amount (inches)1 0.00 0.00 0.00 0.00 0.87
0.00
1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/).
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Mechanicsburg Borough MS4 04/20/2022
II.Site/Facility Activity The Mechanicsburg Borough is in Cumberland County Pennsylvania. The borough is bordered to the east by Lower Allen Township, to the west by Silver Spring and Monroe Townships, to the south by Upper Allen Township and to the north by Hampden Township. The borough has an area of 2.41 square miles and a population of approximately 9,300 residents.
Observations Prior to the inspection the EPA Inspection Team chose and requested the design plans for three PCSWMBMPs and the operation and maintenance plans for the Borough. In addition, the inspection team requested the 2020 and 2021 MS4 Annual Reports for the borough. These documents were reviewed prior to the inspection and assessed for permit compliance. The EPA Inspection Team inspected the municipal yard and PCSWMBMPs. The observations made by the EPA Inspection Team are identified below.
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..."
Section 3.5 of the Borough's Pollution Prevention and Good Housekeeping Program for Municipal Operations MCM #6 states that "Dry spills are to be swept and cleaned up immediately, based on the safety to do so, to prevent transmittal to stormwater or dispersion by wind."
Observation #1: During the inspection of the Highway Garage the EPA Inspection Team observed piles of cold patch asphalt, salt, compost material and aggregate outside of their storage areas where they could potentially be entrained in stormwater runoff (Photographs DSCN2678 through DSCN2680 of the Photo Log).
Dry Weather Screening The General Permit requires "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 "...existing permittees, each of the identified regulated small MS4 outfalls shall be screened during dry weather at least once by March 15, 2023."
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Mechanicsburg Borough MS4 04/20/2022
Observation #2: According to the 2020 and 2021 Annual Reports there are 27 MS4 outfalls within the Borough. Dry weather screens were not conducted in either the 2020 or 2021 reporting period according to the Annual Reports.
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..."
Section 2.3.c of the Borough's Pollution Prevention and Good Housekeeping Program for Municipal Operations MCM #6 states "...Vegetative basin cover is to be maintained at 95%. Areas of bare or sparse vegetation is to be addressed by soil aerating, conditioning, seeding and mulching (as necessary) to restore a proper vegetative cover...."
Observation #3: The plans for the PCSWMBMPs were requested and reviewed by the inspection team prior to the inspection. It appeared during the inspectionsthat the BMPs were located, configured, and contained the inlets and outlets as depicted in the plans.
The EPA Inspection Team inspected three PCSWMBMPs within the Borough:
The BMP at the Soldiers in Sailors Park appeared to be well vegetated and maintained (Photograph DSCN2686 of the Photo Log).
The BMP at Rutters had trash in one of the detention facilities (Photograph DSCN2695 of the Photo Log), the BMP also had some areas around the swale with sparse vegetation (Photograph DSCN2701of the Photo Log).
The BMP at Keystone appeared to have bare soils and a potential sink hole around one of the outflow structures (Photographs DSCN2707 and DSCN2709 of the Photo Log). A general view of the BMP can be seen in Photograph DSCN2706.
III. Records Review The EPA Inspection Team reviewed the 2020 and 2021 Annual Reports for Mechanicsburg Borough, the Borough's Pollution Prevention and Good Housekeeping Program for Municipal Operations MCM #6, the General Permit and PCSWMBMP plans.
IV.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.
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Mechanicsburg Borough MS4 04/20/2022
The inspection concluded at approximately 11:00 AM (EDT).
Unique Project #: 3E22WN080A
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