Document nkZR1qdw8knVLOZbaoV82LYV2
Report Title: Inspection Date: Regulatory Program: Type of Activity: Facility Name: Permittee: Facility Owner/Operator:
Facility Address: Latitude and Longitude: Permit No.: Site Specific Permit No.: NPDES Permit Effective Date: NPDES Permit Expiration Date: SIC code: Unique Project #:
Clean Water Act Compliance Inspection Report 5/1/2024 National Pollutant Discharge Elimination System (NPDES) Industrial Stormwater Street Alley Cleaning Division Operations Campus Facility DC Department of Public Works DC Department of Public Works
1831 Fenwick Street, NE, Washington D.C. 20002 39.91293N, 76.98367W DCR050000 (Master General Permit) DCR05J00A (No Exposure Certification) 05/11/2021 (Applied for Coverage) 02/28/2026 4212 ECAD-5374
Site/Facility Representative(s): Melvin Hodges Phone: 202-710-4996 Email: melvin.hodges@dc.gov
EPA Inspectors: Pete Gold, USEPA Region 3-Inspector Phone: 215-814-5236 Email: gold.peter@epa.gov Brian Tolton, USEPA Region 3-Inspector Phone: 214-814-3291 Email: tolton.brian@epa.gov
State/Local Inspectors: Robert Burnett, DC DOEE-Inspector Phone: 202-578-6237 Email: robert.burnett@dc.gov
Report Preparer Signature/Date
PETER
GOLD
Digitally signed by PETER GOLD Date: 2024.05.20 14:22:44 -04'00'
Peter Gold (3ED32), NPDES Section 1
Supervisor Signature/Date
DSB ID: ECAD-5374
MICHAEL
GREENWALD
Digitally signed by MICHAEL GREENWALD Date: 2024.05.20 16:40:03 -04'00'
Mike Greenwald (3ED32), Acting Section Chief, NPDES Section 1
Street Alley Cleaning Division Operations Campus Facility (DCR050000, DCN05J00A) Compliance Evaluation Inspection Report
TABLE OF CONTENTS
I.
INTRODUCTION ........................................................................................... 3
A.
Inspection Opening Conference...................................................... 3
B.
Weather and Precipitation.............................................................. 4
C.
Summary of the Facility .................................................................. 4
II.
OBSERVATIONS ........................................................................................... 4
III.
CLOSING CONFERENCE................................................................................ 6
List of Attachments: Attachment A: 2021 EPA Multi-Sector General Permit (MSGP) for Stormwater Discharges
Associated with Industrial Activity Attachment B: Photograph Log Attachment C: Notice of Intent (NOI) No Exposure Certification (NEC) Attachment D:DC DOEE Inspection Report Attachment E: April 8, 2021, Stormwater Pollution Prevention Plan for DPW 1831 Fenwick
Street, NE Washington, DC 20002 Attachment F: 2022 Annual Report for Stormwater Discharges Associated with Industrial
Activity Under the NPDES MSGP Attachment G:2023 Annual Report for Stormwater Discharges Associated with Industrial
Activity Under the NPDES MSGP
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Street Alley Cleaning Division Operations Campus Facility (DCR050000, DCN05J00A) Compliance Evaluation Inspection Report
I.
INTRODUCTION
On May 1, 2024, representatives from EPA Region 3 and a representative of the DC Department of Energy and Environment ("DOEE") (hereinafter, collectively referred to as "the Inspection Team") arrived at the Department of Public Works (DPW) Street Alley Cleaning Division Operations Campus Facility (hereinafter, "the Facility") in Washington, DC. The purpose of the inspection was to assess the Facility's compliance with EPA's Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity, Permit No. DCR05J00A (hereinafter, the "Permit") and other applicable regulations.
A. Inspection Opening Conference The Inspection Team arrived at the Plant at approximately 10:00 a.m. for the inspection. The Inspection Team met with the following Facility representatives:
Name
Peter Gold Brian Tolton
Robert Burnett
Melvin Hodges Daniele Lawrence Amy Morgan Jennifer Duckworth Nicole Schneiter Daniel Dunlap
Table 1: Inspection Attendee List
Affiliation
Telephone
EPA Region 3 Inspectors
Email
USEPA Region 3 215 814 -5236 Gold.Peter@epa.gov
USEPA Region 3 215-814-3291 Tolton.Brian@epa.gov
State/Local Inspectors
DC DOEE
202-578-6237 Robert.Burnett@dc.gov
Site/Facility Representatives
DC DPW
202-740-4996 Melvin.Hodges@dc.gov
DC DPW
202-345-2497 Daniele.Knight@dc.gov
DC DOEE
202-804-8965 Amy.Morgan@dc.gov
Tetra Tech
973-378-9115 Jennifer.Duckworth@tetratech.com
Tetra Tech
703-885-5456 Nicole.Schneiter@tetratech.com
Tetra Tech
703-851-3283 Daniel.Dunlap@tetratech.com
Mr. Pete Gold, Mr. Brian Tolton and Mr. Robert Burnett displayed their credentials to the Facility Representatives at the outset of the inspection, and explained the purpose of the inspection was to evaluate the Facility's compliance with the Permit. A copy of the 2021 Permit is provided in Attachment 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.
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Street Alley Cleaning Division Operations Campus Facility (DCR050000, DCN05J00A) Compliance Evaluation Inspection Report
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 Table 2 below.
Table. 2 Precipitation Preceding Inspection1
Station Name
Date
ALEXANDRIA 5.6 SSW, VA US US1VAFX0063 ALEXANDRIA 5.6 SSW, VA US US1VAFX0063 ALEXANDRIA 5.6 SSW, VA US US1VAFX0063 ALEXANDRIA 5.6 SSW, VA US US1VAFX0063 ALEXANDRIA 5.6 SSW, VA US US1VAFX0063 ALEXANDRIA 5.6 SSW, VA US US1VAFX0063
04/26/2024 04/27/2024 04/28/2024 04/29/2024 04/30/2024 05/01/2024
Precipitation Amount (inches)2
Trace 0.00 0.05 0.00 0.00 0.01
C. Summary of the Plant
The DPW Street and Alley Cleaning facility operates as a staging and storage area for fleet vehicles used for snow and leaf operations, street sweeping, and trash pickup. The approximately 5.83-acre site is comprised of three designated areas: Area 1, Area 2, and Area 3. Area 1 consists of a trailer/office building, employee parking, seasonal mulch storage, and two separate roll-off dumpster locations. Area 2 consists of container storage, fenced storage sheds, vehicle storage (street and alley cleaning vehicles including garbage trucks and snow plows with salt spreaders), maintenance equipment, and the Okie Street equipment lot. Area 3 consists of additional vehicle and equipment storage, and additional roll off dumpsters where contracted waste haulers dispose of their trash. Access to the property is from Fenwick Street NE from the West, and Okie Street NE from the North. Areas 2 and 3 direct flows to the District's Municipal Separate Storm Sewer System (MS4) .
II. OBSERVATIONS
As part of the inspection, the Inspection Team visually observed Facility conditions and documented those conditions through Photographs.
The Photographs (Attachment B) for this report have been processed using EPA Region 3 's Photograph Management Process. A camera generated file name (e.g., PC050006) is assigned to each Photograph as part of the process. The file names generated by the camera are used to identify each Photograph in the Main Narrative and Photograph Log of this inspection report. Unused Photographs are digitally stored and maintained in the inspection file. Unused Photographs are available upon request.
1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/).
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Street Alley Cleaning Division Operations Campus Facility (DCR050000, DCN05J00A) Compliance Evaluation Inspection Report
The following section presents the Inspection Team's observations relative to the Facility's Permit requirements.
Permit Requirement
Part 2.1.2.7 of the 2021 MSGP states "You must enclose or cover storage piles of salt, or piles containing salt, used for deicing or other commercial or industrial purposes, including maintenance of paved surfaces, in order to minimize pollutant discharges. You must implement appropriate measures (e.g., good housekeeping, diversions containment) to minimize exposure resulting from adding to or removing materials from the pile..."
Part 6 of the 2021 MSGP states the permittee "...must prepare a SWPPP for your facility before submitting your NOI for permit coverage...."
Page 16 of the 2021 SWPPP states "All salt is stored where it is protected from being exposed to stormwater in a covered area and elevated off the ground or inside"
Observation 01: The Inspection Team observed two small residual piles of salt on the ground without any observed containment in the fenced section of Area 2. This condition was documented in Photographs 7 and 8 of Attachment B.
Permit Requirement
Section 2.1.2.2. of the 2021 MSGP states the permittee "...must keep clean all exposed area that are potential sources of pollutants. You must perform good housekeeping measures in order to minimize pollutant discharges, including but not limited to..." Section 2.1.2.2.a "Sweep or vacuum at regular intervals or, alternatively, wash down the area and collect and/or treat, and properly dispose of the washdown water...."
Section 2.1.2.4.a. of the 2021 MSGP addresses spill prevention and response and states the facility must "Clean up spills and leaks promptly using dry methods (e.g. absorbents) to prevent the discharge of pollutants;..."
Section 2.1.2.5 of the 2021 MSGP states the permittee "...must minimize erosion by stabilizing exposed soils."
Observation 02: The Inspection Team observed piles of sediment and spill kit residue throughout Area 3. The sediment and spill kit residue were exposed to precipitation and could potentially migrate to the MS4 system. It appeared that sediment from the site perimeter may also be migrating into Area 3. These conditions are documented in Photographs 14 through 17 of Attachment B.
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Street Alley Cleaning Division Operations Campus Facility (DCR050000, DCN05J00A) Compliance Evaluation Inspection Report
At the time of the inspection, the Facility was placing hay bails around an exposed area between Area 2 and 3. These conditions are documented in Photographs 3 and 4 of Attachment B.
Permit Requirement
Part 2.1.2.3 of the 2021 MSGP states the permittee "...must maintain all control measures that are used to achieve the effluent limits in this permit in effective operating condition...."
Part 6 of the 2021 MSGP states the permittee "...must prepare a SWPPP for your facility before submitting your NOI for permit coverage...."
Page 16 of the 2021 SWPPP states "Material storage piles are covered with a tarp or awning." and "Tarps are regularly inspected to ensure they are intact and being used and secured properly."
Page 17 of the 2021 SWPPP states "Always keep trash containers closed, covered or tarped and rolloff doors closed."
Observation 03: The Inspection Team observed a tear in a tarp which was covering cement forms that were used for public garbage pail ballast. The tarp was covering cement forms. This is documented in Photographs 1 and 2 of Attachment B.
At the time of inspection, the roll-off container in Area 2 that was on-site receiving waste did not appear to have a cover or tarp and no cover or tarp was seen in the area in proximity to the container. This is documented in Photographs 11 and 12 of Attachment B.
Permit Requirement
Part 2.1.2.4.d of the 2021 MSGP addresses spill prevention and response and states "Plainly label containers (e.g., "Used Oil," "Spent Solvents," "Fertilizers and Pesticides") that could be susceptible to spillage or leakage to encourage proper handling and facilitate rapid response if spills or leaks occur."
Part 6 of the 2021 MSGP states the permittee "...must prepare a SWPPP for your facility before submitting your NOI for permit coverage...."
Page 17 of the 2021 SWPPP states "Trash bins, dumpsters, and roll-offs do not have cracks, holes, incorrect labels, or unsealed drain plugs. If any of these issues are observed, it is reported and fixed immediately."
Observation 04:
The Inspection Team observed blue plastic drums in a shed in Area 2, some of which lacked
labeling. An empty drum was placed haphazardly above the full drums. The pathway to the
drums was not clear of obstructions. The drums were located on a secondary containment
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Street Alley Cleaning Division Operations Campus Facility (DCR050000, DCN05J00A) Compliance Evaluation Inspection Report
pallet and within a covered shed so that they were not exposed to stormwater and any leaks may be collected by the pallet. The condition at the time of the EPA inspection is documented in Photograph 6 of Attachment B.
Permit Requirement
Section 2.1 of the 2021 MSGP "You must select, design and install, and implement stormwater control measures (including best management practices) to minimize pollutant discharges that address the selection and design considerations in Part 2.1.1, meet the non-numeric effluent limits in Part 2.1.2, meet limits contained in applicable effluent limitations guidelines in Part 2.1.3 and meet the water quality-based effluent limitations in part 2.2."
Part 3.2.1 of the 2021 MSGP requires the permittee to conduct quarterly visual assessments (QVAs) on a quarterly basis.
Part 3.2.2.5 of the 2021 MSGP requires the permittee to initiate corrective action "Whenever the visual assessment shows evidence of stormwater pollution in the discharge."
Observation 05: All the QVAs collected in 2022 and 2023 showed evidence of stormwater pollution in the discharge and the facility initiated corrective actions after each QVA (Attachments F and G). Pages 18 and 19 of the SWPPP require no inlet filter for the trench drains or the sewer inlets. The sewer inlets have stormcepters in them. However, during the site visit, the Inspection Team observed inlet protection on and around the sewer inlets. There was a significant amount of sediment around the inlets. This is documented in Photographs 18 and 20 of Attachment B.
There was no inlet protection around the trench drains.
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 that all preliminary observations discussed were not compliance determinations. 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.
The inspection concluded at approximately 11:30 AM (EST).
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