Document 9J0rD7Dqj51ayQ3VqyXqjaaaL

Region 6 Compliance Assurance and Enforcement Division sMS4 Inspection Report Inspection Date(s): Media: Regulatory Program(s) 12/9/2019 Water CWA Storm Water Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: City of Santa Fe City of Santa Fe 500 Market Street, Suite 200 Santa Fe, New Mexico 87501 500 Market Street, Suite 200 Santa Fe, New Mexico 87501 Santa Fe County Melissa McDonald mamcdonald@santafenm.gov River and Watershed Manager FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: N/A NMR040000 N/A 921110 9111 Personnel participating in inspection: Stephanie Meyers US EPA/6ECDWR Carol Johnson US EPA/6ECDWR David Esparza US EPA/6ECDWM Jennifer Foote NMED Melissa McDonald City of Santa Fe Dee Beingessner Alex Puglisi City of Santa Fe City of Santa Fe Victor Lucero Dave Pike Sam Burnett City of Santa Fe City of Santa Fe City of Santa Fe Life Scientist Life Scientist Environmental Engineer Supervisor Rivers and Watershed Manager City Engineer NPDES Compliance Specialist Program Manager Stormwater Project Admin Project Administrator 214-665-6496 214-665-8471 505-366-8402 505-827-0596 505-955-6840 505-955-6641 505-955-4232 505-955-2117 505-955-2134 505-955-6853 EPA Lead Inspector Signature/Date STEPHANIE MEYERS Digitally signed by STEPHANIE MEYERS DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=STEPHANIE MEYERS, 0.9.2342.19200300.100.1.1=68001003655867 Date: 2020.01.15 10:01:37 -06'00' Stephanie Meyers Date Supervisor Signature/Date CURRY JONES Digitally signed by CURRY JONES DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=CURRY JONES, 0.9.2342.19200300.100.1.1=68001003655418 Date: 2020.01.15 09:55:57 -06'00' Curry Jones Date 6ENFORM-019-R7 (2/15/2017) 1 City of Santa Fe Inspection Date 12/9/2019 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Stephanie Meyers, Carol Johnson, and David Esparza, as well as New Mexico Environment Department Industrial and Stormwater Team Supervisor, Jennifer Foote arrived at the City of Santa Fe (City) offices at 9:00am on December 9, 2019, for an announced inspection. We met with Melissa McDonald, Rivers and Watershed Manager; Dee Beingessner, City Engineer; Alex Puglisi, NPDES Compliance Specialist; Victor Lucero, Program Manager; David Pike, Stormwater Project Admin; and Sam Burnett, Project Administrator. I informed representatives of the City that this was an EPA inspection to determine compliance with the City's NPDES Small Municipal Separate Storm Sewer System (MS4) Phase II Permit and the Clean Water Act. The inspection was conducted under the authority of the National Pollutant Discharge Elimination System (NPDES) permit program, in accordance with the Federal Clean Water Act. FACILITY DESCRIPTION The City of Santa Fe is a Phase II MS4 that discharges to surface waters of the United States. The City is responsible for compliance with permit conditions relating to discharges from portions of the MS4 for which it is the operator, and Storm Water Management Program (SWMP) implementation on portions of the MS4 for which it is the operator. Section II - OBSERVATIONS The areas evaluated during the inspection will be rated in the sMS4 Overview found in Appendix 3. Before exiting the facility, an exit briefing was conducted to discuss our findings. During the exit briefing, we informed the City of areas of concerns noted during the inspection. Section III - AREAS OF CONCERN Several areas of concern were found during the inspection: 1) At the City's Service Center, we observed that overall, good housekeeping was lacking. Paint storage containers were left exposed and open (Photo 1), paint storage tanks were also exposed (Photo 2), runoff from the Service Center drains to two ditches, one of which is directly connected to an irrigation channel (Photo 4), vehicle wash materials covered a portion of the site and were draining to the ditch next to the irrigation channel (Photos 7, 8, and 10), road paint was being tested not far from the drain connected to the ditch (Photo 11), and the spill kit is not easily accessible as it is locked inside a building (Photo 13). 2 City of Santa Fe Inspection Date 12/9/2019 2) The Service Center does not have a Multi-Sector General Permit. 3) The City does not have an electronic database to maintain records. 4) The City's storm water team seems to be understaffed with just one full time employee, and unorganized regarding each individual's role on the team. Section IV - FOLLOW UP After the December 9, 2019 inspection, EPA received an email from Melissa McDonald on January 3, 2020, containing information on the City's Storm Water Management Program. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log Appendix 2 - Sign-in Sheet Appendix 3 - sMS4 Overview 3 City of Santa Fe Inspection Date 12/9/2019 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0697 Date and Time of Photo: 12/9/2019, 12:12pm Photographer: Stephanie Meyers Description: Road paint storage uncovered, some containers open UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0699 Date and Time of Photo: 12/9/2019, 12:14pm Photographer: Stephanie Meyers Description: Underground road paint storage tanks UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0707 Date and Time of Photo: 12/9/2019, 12:45pm Photographer: Stephanie Meyers Description: Salt and other de-icing materials stored on site, contained by concrete barrier UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0710 Date and Time of Photo: 12/9/2019, 12:54pm Photographer: Stephanie Meyers Description: First ditch where materials from Service Center drain to, overflow pipe and spillway connecting ditch to irrigation channel UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0711 Date and Time of Photo: 12/9/2019, 12:56pm Photographer: Stephanie Meyers Description: Low point at the Service Center, which drains to a second ditch UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0713 Date and Time of Photo: 12/9/2019, 1:02pm Photographer: Stephanie Meyers Description: Minimal staining where vehicles are stored UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0714 Date and Time of Photo: 12/9/2019, 1:03pm Photographer: Stephanie Meyers Description: Drainage inlet, which empties to ditch near irrigation channel UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0715 Date and Time of Photo: 12/9/2019, 1:04pm Photographer: Stephanie Meyers Description: Vehicle wash materials inside drainage inlet UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0717 Date and Time of Photo: 12/9/2019, 1:05pm Photographer: Stephanie Meyers Description: Oil leaking near drainage inlet UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0718 Date and Time of Photo: 12/9/2019, 1:07pm Photographer: Stephanie Meyers Description: Vehicle wash materials puddling near drainage inlet UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0720 Date and Time of Photo: 12/9/2019, 1:08pm Photographer: Stephanie Meyers Description: Testing road paint near drainage inlet that goes to ditch next to irrigation channel UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0722 Date and Time of Photo: 12/9/2019, 1:19pm Photographer: Stephanie Meyers Description: Spill kit not easily accessible inside locked building UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: City of Santa Fe Service Center City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: DSCN0723 Date and Time of Photo: 12/9/2019, 1:20pm Photographer: Stephanie Meyers Description: Fueling station City of Santa Fe Inspection Date 12/9/2019 Appendix 2 Sign-In Sheet City of Santa Fe Inspection Date 12/9/2019 Appendix 3 sMS4 Overview City of Santa Fe Inspection Date 12/9/2019 United States Environmental Protection Agency Dallas, Texas sMS4 OVERVIEW Name of sMS4 and Address: Pre-Assessment Date: Section A: sMS4 Information City of Santa Fe Permit Number: 500 Market Street, Suite 200, Santa Fe, NM December 9, 2019 NMR040000 Section B: Summary of the Interview (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Evaluated) M SWMP implemented S Illicit Discharge Detection and Elimination program M SWMP management trained U Municipal Good Housekeeping program S Construction Site Runoff program S Inspection schedule established for applicable Control Measures S Post-Construction Site Runoff program S Public Education, Outreach and Participation S Enforcement Actions M Data Management N Inspection of Industrial facilities S Structural Controls/Green Infrastructures/Pollutant Reduction Projects Section C: Summary of the sMS4 Inspection (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Evaluated) U Permit S Records/Reports/Inventory M SWPPP, SOP, Management Guidelines or Good Housekeeping Manual in place M Trained Staff (emergency spill response, storm water) M Spill Kit M Scheduled facility inspection and clean up S Fueling Station M Trash bins and disposal areas U Equipment and Vehicle Wash area U Outfalls M Storage Bins U Training programs M Vehicle Maintenance area U General Good Housekeeping Section D: Summary of the Inspection Observation (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Evaluated) S Uses an Inspection form or Checklist S Checks inspection reports for completion: date, signature S Takes appropriate and timely enforcement action S Notifies operator about areas of concern S Determines that a SWPPP is on site M Files the completed inspection report in a database S Determines NOI submitted or Permit on site S Follows-up with the operator if corrective action/s required S Checks for storm water discharges S Checks frequency of inspections S Checks storm water conveyances for protective covers