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).
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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
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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