Document evNzox6MxxyV6DD3DbgbddKjg
Locks to Report Title: Inspection Date: Regulatory Program:
Type of Activity: Facility Name: Permittee: Facility Owner/Operator: Facility Address:
Latitude and Longitude: Permit No.: NPDES Permit Effective Date: NPDES Permit Expiration Date: SIC code:
Clean Water Act Compliance Inspection Report 12/6/2023 National Pollutant Discharge Elimination System (NPDES) Industrial Stormwater Four Seasons Produce Four Seasons Produce, Inc. Four Seasons Produce
P.O. Box 788 400 Wabash Road Ephrata, PA 17522 N 40 12' 14", W -76, 9' 6" PA0247537 3/1/2020 2/28/2025 5148
Report Preparer Signature/Date
Supervisor Signature/Date
PETER GOLD
Digitally signed by PETER GOLD Date: 2024.01.30 07:18:44 -05'00'
Peter Gold (3ED32) NPDES Section 1
MARK ZOLANDZ Date: 2024.01.30 08:22:34 -05'00' Digitally signed by MARK ZOLANDZ
Mark Zolandz (3ED32) Chief, NPDES Section 1
DSB ID: ECAD-535
High Steel Structures (NPDES Permit PA0247537) Compliance Evaluation Inspection Report
TABLE OF CONTENTS
I.
INTRODUCTION ...................................................................................................... 3
A.
Inspection Opening Conference................................................................3
B.
Weather and Precipitation........................................................................3
C.
Summary of the Facility ............................................................................4
II.
OBSERVATIONS ...................................................................................................... 4
III.
CLOSING CONFERENCE...........................................................................................6
List of Attachments: Attachment A: NPDES Storm Water Permit PA0247537 Attachment B: Photograph Log
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I.
INTRODUCTION
On December 6, 2023, representatives from EPA Region 3 and representatives of the Pennsylvania Department of Environmental Protection ("PADEP"), hereinafter, collectively referred to as "the Inspection Team", conducted an inspection of the Four Seasons Produce facility (hereinafter, "the Facility") located in Lancaster, PA. The purpose of the inspection was to observe compliance with the Clean Water Act (CWA) and to verify compliance with the Permittee's National Pollutant Discharge Elimination System ("NPDES") Permit No. PA0247537 (hereinafter, "the Permit") and applicable State and Federal regulations.
A. Inspection Opening Conference The Inspection Team arrived at the Facility at approximately 1:00 p.m. for the inspection and met with Facility representatives and displayed credentials to Facility representatives. The inspection involved the following people:
Name
Peter Gold, NPDES Inspector Erin DeSandro, NPDES Inspector Benjamin Evick, SPCC Inspector
Pat McGee
Table 1: Inspection Attendee List
Affiliation
Telephone
EPA Region III Inspectors
USEPA Region 3
215 814 -5236
USEPA Region 3
215-814-2125
USEPA Region 3
304-234-0272
State/Local Representatives
PA DEP
717-756-5220
Adam Nothstein
PA DEP
223-895-6295
Megan Majeski Randy Groff
PA DEP
717-772-5810
Facility Representatives
Four Seasons Produce 717-721-2795
Email Gold.Peter@epa.gov Desandro.Erin@epa.gov Evick.Benjamin@epa.gov
Patrmcgee@pa.gov Anothstein@pa.gov Mmajeski@pa.gov
Randyg@fsproduce.com
Mr. Pete Gold, Ms. Erin DeSandro, and Mr. Benjamin Evick displayed their credentials to the Facility Representatives at the outset of the inspection, and explained the purpose of the inspection was to observe compliance with its Permit. A copy of the Permit is provided in Appendix A. The Inspection Team informed the Facility Representatives that any information that the Facility deemed to be confidential business information ("CBI") should be identified to EPA representatives during the inspection and it would be handled as CBI according to EPA's CBI procedures.
B. Weather and Precipitation At the time of the inspection, the weather was partly cloudy skies; no precipitation was experienced during the inspection. 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 below.
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High Steel Structures (NPDES Permit PA0247537) Compliance Evaluation Inspection Report
Table. 2 Precipitation Preceding Inspection1
Station Name
Date
Lancaster Airport, PA US USW00054737 Lancaster Airport, PA US USW00054737 Lancaster Airport, PA US USW00054737 Lancaster Airport, PA US USW00054737 Lancaster Airport, PA US USW00054737 Lancaster Airport, PA US USW00054737
12/1/2023 12/2/2023 12/3/2023 12/4/2023 12/5/2023 12/6/2023
Precipitation Amount (inches)2 0.18 0.02 0.42 0.00 0.00 Trace
C. Summary of the Facility
Four Seasons Produce, Inc. is a full-service wholesale produce distributor supplying organic produce. Produce brought into Four Seasons Produce is distributed to organic markets, food co-ops, independent retailers, chain stores, juice bars and other produce buyers in the Mid-Atlantic and Northeast regions. The warehouse contains 6 climate zones for produce storage and ripening rooms for bananas and avocado.
II. OBSERVATIONS As part of the inspection, the Inspection Team visually observed Facility conditions and documented those conditions through photographs.
The photographs (Appendix - B) for this report have been processed using EPA Region 3 's Photo Management Process. A file name (e.g., 2023-12-06--13.59.39_PC060072) which incorporates the date and time the photo was taken (e.g., 2023-12-06--13.59.39), as well as the original camera generated file name (e.g., PC060072) is assigned to each photo as part of the process. The file names generated by the camera are used to identify each photo in the Main Narrative and Photo Log of this inspection report. Unused photos are digitally stored and maintained in the inspection file. Unused photos are available upon request.
The following section presents the Inspection Team's observations relative to the Facility's Permit requirements.
Permit Requirement
Part I.A. of the Permit states "... samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s): at Outfall 001"
Observation 01: Outfall 001, according to facility representatives, is located at the discharge point of the large stormwater basin (Attachment B, Photos PC060042, PC060043 and PC060044). According to facility representatives, the sampling contractor may be taking samples in the small basin instead due to a
1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/).
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High Steel Structures (NPDES Permit PA0247537) Compliance Evaluation Inspection Report
lower flow in the large basin (Attachment B, Photos PC060038 and PC060039). PA DEP was not informed of this change if it did occur.
Permit Requirement
Part C.III.C.1.a of the Permit requires the permittee to "Use grading, berming or curbing to prevent runoff of polluted stormwater and divert run-on away from areas that contain polluted stormwater."
Observation 02: The Facility had two stormwater basins. The smaller basin was more recently constructed and received runoff from the recently roofed portion of the Facility and some inlets in the parking lot. The smaller basin flowed into the larger basin, which also received roof runoff and flows from additional inlets in the parking lot. The larger basin then discharged across Route 272. The Inspection Team observed several inlets without stormwater BMPs; some of inlets drained to the stormwater basins on site while other discharged directly into the East Cocalico Township Municipal Separate Storm Sewer System (MS4) (Attachment B, Photos PC060036, PC060052, PC060061, PC060062, PC060083, PC060084, PC060085, PC060087, PC060088, PC060094 and PC060105).
Permit Requirement
Part C.III.C.1.b of the Permit states the permittee shall "Locate materials, equipment, and activities so that potential leaks and spills are contained or able to be contained or diverted before discharge to surface waters"
Observation 03: The Inspection Team walked the parking area around the Facility. It appeared that some inlets allowed vehicles to park directly over the inlet (Attachment B, Photo PC060085).
Permit Requirement
Part C.III.C.1.c of the Permit states the permittee shall "Clean up spills and leaks promptly using dry methods (e.g., absorbents) to prevent the discharge of pollutants to surface waters."
Observation 04: The Inspection Team observed what appeared to be small areas of petroleum staining in sections of the parking lot (Attachment B, Photos PC060088, PC060089 and PC060105) and staining on concrete pads that held the generators (Attachment B, Photos PC060080 and PC060081).
Permit Requirement
Part C.III.C.1.g of the permit states that the permittee shall "Drain fluids from equipment that will be decommissioned....".
Observation 05: The Inspection Team observed a portion of refrigeration unit stored outside by the maintenance garage with a small amount of absorbent material around it potentially indicating a past leak (Attachment B, Photo PC060095).
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High Steel Structures (NPDES Permit PA0247537) Compliance Evaluation Inspection Report
Permit Requirement Part C.III.D.2.p of the Permit requires the facility to evaluate and document in the Annual Report "The presence of authorized non-stormwater discharges that were not identified in the permit application and non-stormwater discharges not authorized by this permit."
Observation 06: The Inspection Team observed a small white PVC pipe discharging water (Attachment B, Photos PC060068, PC060069 and PC060070). The facility representative stated that the discharge was potable water from fire suppression equipment. The water from the pipe flowed into a waste storage area where the water could potentially mix with pollutants. The water then flowed into what appeared to be an unprotected stormwater inlet (Attachment B, Photos PC060063, PC060066, PC060067, PC060068, PC060069 and PC060070).
Permit Requirement
Part C.III.E.1 of the Permit states that "The permittee shall develop and implement a PPC Plan....."
Observation 07: On the day of the inspection, the Inspection Team requested a copy of the Facility's Preparedness, Prevention and Contingency (PPC) Plan. A follow-up email requesting the PPC and other documents was sent to the Facility on December 26, 2023. The Facility responded to EPA on December 27, 2023, and informed EPA that there was no PPC Plan, Stormwater Pollution Prevention Plan or Storm Water Management Plan for the Facility.
Permit Requirement
Part C.III.D.1 of the Permit states that "The permittee shall visually inspect the following areas and BMPs on a semiannual basis....."
Observation 08: On the day of the inspection, the Inspection Team requested a copy of the Facility's routine inspections. A follow-up email requesting documentation of routine inspections and other documents was sent to the Facility on December 26, 2023. The Facility responded to EPA on December 27, 2023, and informed EPA that there were "no records on file" of routine inspections.
Permit Requirement
Part C.III.C.4.c of the Permit states that the permittee shall "Develop and implement employee and contractor training on the procedures for expeditiously stopping, containing, and cleaning spills, and other releases. The permittee shall conduct periodic training, no less than annually, and document the training on the Annual Report...."
Observation 10: On the day of the inspection, the Inspection Team requested a copy of the Facility's training documentation. A follow-up email requesting documentation of employee training was sent to the Facility on December 26, 2023. The Facility responded to EPA on December 27, 2023, and informed EPA that there was employee training "conducted during the annual report". However, documentation of the training was not provided to EPA.
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III. CLOSING CONFERENCE
At the conclusion of the onsite inspection, the Inspection Team met with the Facility Representatives for a closing conference. The Inspection Team shared preliminary observations with the Facility Representatives and requested additional documentation from the Facility. The Inspection Team reiterated to the Facility Representatives that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further review by EPA upon the additional review of records and documentation. Additional observations may be contained in this inspection report that were not identified at the time of the closing conference after EPA reviewed additional materials following the inspection. On December 27, 2023, EPA received some requested documents from the Facility, which were reviewed by EPA.
The inspection concluded at approximately 3:30 PM (EDT).
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