Document M86dB1xvpnVxGj63bx9VRRQ9

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 04/21/2022 National Pollutant Discharge Elimination System (NPDES) Municipal Stormwater Camp Hill Borough MS4 Camp Hill Borough Camp Hill Borough 2145 Walnut Street Camp Hill, PA 17011 40.241100 Longitude: -76.921570 Cumberland PAG013 PAG133549 924110 SIC: 9511 3E22WN082A Site/Facility Representative(s): Point of Contact Lester Lanman Phone: (717) 730-3964 Email: llanman@camphillborough.com EPA Inspectors: Peter Gold Phone: (215) 814-5236 Email: Gold.Peter@epa.gov Chuck Schadel Phone: (215) 814-5761 Email: Schadel.Chuck@epa.gov Ed Simas Phone: (215) 814-2124 Email: Simas.Edward@epa.gov State/Local Inspectors: Leah Staley - Pennsylvania Department of Environmental Protection Phone: 717-705-4814 Email: lestaley@pa.gov Jacob Rakowsky - Pennsylvania Department of Environmental Protection Phone: 717-705-4918 Email: jrakowsky@pa.gov Gold, Peter Digitally signed by Gold, Peter Date: 2022.05.12 09:56:42 -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 12:50:17 -04'00' Jessica Duffy, Acting Section Chief NPDES Enforcement Section, (3ED32) Date Unique Project#: 3E22WN082A Camp Hill Borough MS4 04/21/2022 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: Attachment D: Attachment E: Permit 2020 Annual Report Correspondence with the Borough PCSWMBMP Plans Unique Project #: 3E22WN082A Page 2 of 6 Camp Hill Borough MS4 04/21/2022 I. Introduction On April 21, 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 Camp Hill Public Works Facility at 422 S. 24th Street, Camp Hill, PA. At the facility, the EPA Inspection Team met with Lester Lanman (Camp Hill, Director of Public Works). 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 the borough's Annual Reports (MCM3). 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 a facility visit of the one of the borough's municipal yards. 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 422 S. 24th Street at approximately 1:30 PM 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 three 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 2. 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 04/16/2022 04/17/2022 04/18/2022 04/19/2022 04/20/2022 04/21/2022 Precipitation Amount (inches)1 0.0 0.0 0.0 0.87 0.0 0.0 1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Unique Project #: 3E22WN082A Page 3 of 6 Camp Hill Borough MS4 04/21/2022 II. Facility Activity Camp Hill Borough is in Cumberland County Pennsylvania. The borough is bordered to the east by the Borough of Lemoyne, to the west by Hampden Township, to the south by Lower Allen Township and the north by Hampden Township. The borough has an area of 2.1 square miles and a population of approximately 8,000 residents. According to the borough's 2021 Operations and Maintenance plan there are eight borough facilities including the Public Works Facility which was inspected. III. Observations Prior to the inspection the EPA Inspection Team chose and requested the 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 conducted site visits of the Public Works Facility and the three 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..." Page 13 of the 2021 Camp Hill Operations and Maintenance Manual informs the borough that "When bulk materials are stored outside, they are stored in areas with berms or curbs to prevent stormwater runoff." Observation #1: During the inspection of the Public Works Facility, the EPA Inspection Team observed several piles of sand, gravel and road materials in the bulk storage area with no visible berms or curbing. There appeared to be some migration of sand within the bulk storage area but did not appear to migrate from the facility (Photograph DSCN3300 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." Unique Project #: 3E22WN082A Page 4 of 6 Camp Hill Borough MS4 04/21/2022 Observation #2: According to the borough's 2021 Annual Report dry weather screenings were not conducted in 2021. The 2020 Annual Reports (Attachment C) notes that 10 of the borough's outfalls were inspected for dry weather flows. In the review of the 2020 dry weather screening forms the EPA Inspection Team noted that Outfalls #5 and 8 were identified as having no flow but photographs taken during the screening appear to show a flow from these outfalls. The Borough Representatives agreed that it appeared these photos show flows. The Borough Engineer noted that when the inspections took place there was rainfall within 72-hours of the inspection but that the flows observed were clear and lacked odor or oil. The borough notified EPA that it intends to re-inspect these two outfalls. 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 #3: The plans for the PCSWMBMPs were requested and reviewed by the inspection team prior to the inspection. It appeared during the inspections that 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 Willow Park (Photograph DSCN3310 of the Photo Log) had some erosional marks on the bank that were recently stabilized by the borough. The inflow and outflow structures of the BMP appeared to be unobstructed. The BMP at Schafer Park (Photograph DSCN3314 of the Photo Log) appeared to have some signs of erosion behind an inflow pipe. The inflow and outflow structures of the BMP appeared to be unobstructed. The BMP at Beverly Park (Photograph DSCN3319 of the Photo Log) appeared well vegetated, and the inflow and outflow structures appeared un-obstructed. IV. Records Review The EPA Inspection Team reviewed the 2020 and 2021 Annual Reports for Camp Hill Borough, the Operations and Maintenance Plan for the borough, the General Permit and PCSWMBMP plans. V.Closing Conference At the conclusion of the onsite 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 Unique Project #: 3E22WN082A Page 5 of 6 that were not identified at the time of the closing conference. The inspection concluded at approximately 3:30 PM (EDT). Camp Hill Borough MS4 04/21/2022 Unique Project #: 3E22WN082A Page 6 of 6