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HomeMy WebLinkAboutSWPPP Inspection Memo - Feb 2024 MEMORANDUM February 22, 2024 Mr. Marc Valenti, CPWP-S Manager of Operations Lexington DPW 201 Bedford Street Lexington, MA 02420 RE: NPDES Phase II Stormwater Assistance Pollution Prevention & Good Housekeeping for Municipal Operations Winter 2024 Quarterly SWPPP Observation Dear Mr. Valenti, In order to fulfill the requirements of the 2016 National Pollution Discharge Elimination System (NPDES) Stormwater General Permit, Environmental Partners Group, LLC. (EP) conducted site visits of Town-owned facilities that maintain a Stormwater Pollution Prevention Plan (SWPPP). These facilities require a quarterly observation, in accordance with Section 2.3.7.b.iii of the Stormwater General Permit. On February 20, 2024, EP visited the two Town-owned facilities that require SWPPP observations: the Department of Public Works and the Compost Facility. These site visits were conducted during dry weather conditions. The SWPPP observations included touring the grounds of each property, observing all storage stockpiles, material loading areas, fueling stations, equipment operation and maintenance areas, vehicle washing areas, salt piles, areas of erosion, and waste handling and disposal areas. In addition, Structural Control Measures, such as catch basins, BMPs, and inlet/outlets, were observed and determined to be effectively operating or in need of maintenance or replacement. Observations were recorded in the Site Observation Reports, attached in Appendices A and B. The site visits of the Department of Public Works and Compost Facility found that the sites are generally in compliance with respect to the Pollution Prevention and Good Housekeeping minimum control measures of the Stormwater General Permit. The only areas that require attention are described below. 2 of 3 envpartners.com • Department of Public Works o Minor amount of trash noticed throughout the stormwater BMPs. o The Town should continue cutting back vegetation within its stormwater basins periodically to ensure that the plant grown does not limit the storage capacity of the basins. The Town stated that Essex Horticultural inspects the stormwater basins on a bi-annual basis and maintains them as necessary. o During previous inspections, a pipe was observed entering the catch basin in front of the Salt Shed, and flow was observed during dry weather.  In March 2023, EP spoke with a neighboring resident of the DPW, and they believed a stream was culverted and the pipe observed at the DPW could contain this stream water. The neighbor indicated that the stream may have been culverted years before the DPW was built. The Town should determine the source of this pipe, confirm that this pipe does convey this culverted stream, and update the stormwater mapping accordingly. o The mapping at the DPW Facility in PeopleGIS needs to be updated. Additional structures including catch basins and inlet/outlets were observed in the field that are not captured on PeopleGIS. • The Compost Facility o The Town should consider implementing a new stormwater management system to better treat and manage stormwater. Initial corrective actions can consist of implementing some short-term sediment and erosion control BMPs (e.g., silt sock, berm, repositing the compost piles) to reduce sediment transport. Intermediate actions can include the Town evaluating site drainage BMPs to improve the overall stormwater management at the site. o The outlet west of the hazardous waste collection area was partially blocked by leaves and other debris. Additionally, the riprap pad in front of the outlet contained leaves, brush, and sediment. These issues should be addressed to ensure the outlet and riprap pad are functioning as designed. o The outlet discharging into the woods, located in the southeast portion of the compost facility, was covered in leaves and other debris, and could not be located. These issues should be addressed to ensure the outlet and riprap pad are functioning as designed. o Empty oil drums were found in the hazardous waste collection area. If waste oil collection is collected and stored in the facility, they should be placed on a concrete palette, have proper signage, and include an accessible spill kit. Corrective actions taken in response to these findings should be documented in writing by the facility managers of the individual facilities, with a copy kept on file with other Stormwater General Permit compliance documentation. The Town continues to maintain their stormwater BMPs. The replaced riprap behind the salt shed continues to be in good condition. The catch basins and proprietary separator BMPs (Hydro International) within the facility should be cleaned on an as needed basis and/or per the factory O&M manual. 3 of 3 envpartners.com The next SWPPP site visit should be completed in the next quarter (between April and June 2024). Please do not hesitate to email or call us if you have any questions or require any additional information. Sincerely, Environmental Partners Group, LLC Natalie Pommersheim Project Manager P: 617.657.0257 E: nmp@envpartners.com Karen Chan Project Scientist P: 617.657.0271 E: knc@envpartners.com CC: John Zaccardi – Town of Lexington DPW Eric Kelley, PE, CHMM, LEED GA – Environmental Partners Attachments Certification Page Appendix A. DPW Site Observation Report, Figure, and Photos Appendix B. Compost Facility Site Observation Report, Figure, and Photos CERTIFICATION “I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.” Printed Name ___________________________________________ Signature ________________________________________________ Date _________________________________________ envpartners.com APPENDIX A Department of Public Works Site Observation Report, Figure, and Photos DPW SWPPP QUARTERLY SITE OBSERVATION CHECKLIST __________________Date: __________________ Time: Inspector(s) Name(s): Inspector(s) Signature(s): Weather Conditions During Site Visit: Description of Any Discharge Occurring at the Time of the Site Visit: Conduct a thorough observation of the entire facility and grounds Areas to Observe Potential Pollutant Sources:Description of problem: Good Action Needed? (Routine) “Corrective Action”† Needed? Action Completed? (Date) Parking Lots Generator Transformer Cold Storage Dumpsters Recycling Collection & Storage Areas Yard/Storage Area Salt Shed and Loading Area Snow Stockpile Area Asphalt Emulsifier Tank Brine Solution Tank Hydrant (by the sediment forebay) Fueling Station General Facility Grounds & Outfall:Good Action Needed? (Routine) “Corrective Action”† Needed? Action Completed? (Date) Observe catch basins, outfalls, sediment forebays, and rain gardens for evidence of damage, erosion or any discharge of pollutants. Ensure that facility grounds show no signs of poor housekeeping (e.g., materials, residues, or trash that may come in contact with stormwater). Ensure there are no spots, pools, puddles, or other traces of oil, grease, or other chemicals on the ground around the facility, either liquid or solid. Ensure there is no evidence of offsite tracking of materials and no blowing of raw, final, or waste materials outside of the operational areas. Ensure there are no leaks or spills from equipment, drums or other containers, or containers in poor condition outside the facility. †Corrective Action” is triggered for systemic problems with control measures (e.g., if a dumpster lid is occasionally left open, this does not trigger “corrective action;” however, if a dumpster lid is missing or inoperable, this triggers corrective action. If an area needs routine sweeping, this does not trigger “corrective action;” however, if an area needs sweeping and is not being swept because supplies are not available or staff is not assigned, this triggers corrective action.) Identification of any previously unidentified discharges from the Site:  Yes*  No If yes, describe: Describe any incidences of noncompliance observed (i.e., corrective action needed), summary of corrective actions taken and date initiated and completed (attach additional sheets if necessary): Karen Chan, Environmental Partners N/A Do any control measures need maintenance, repairs, or replacement?  Yes*  No If yes, describe: The Town should continue cutting back vegetation within its stormwater basins periodically to ensure that the plant growth does not limit the storage capacity of the basins. Some trash was noted in all BMPs. Inspect subsurface chambers and clean outs as necessary. Any additional control measures needed to comply with permit requirements?  Yes*  No If yes, describe: 9:00-9:30 AMFebruary 20, 2024 Sunny, 30s Are modifications to SWPPP necessary? Yes No If yes, describe: DPW SWPPP QUARTERLY SITE OBSERVATION CHECKLIST Any other notes? The Town continues to maintain their stormwater BMPs. BMP maintenance occurs bi-annually. The next scheduled maintenance is to occur this spring. The replaced riprap behind the salt shed continues to be in good condition. The catch basins and proprietary separator BMPs (Hydro International) within the facility should be cleaned on an as needed basis and/or per the factory O&M manual. Per the Town, town-wide catch basin cleaning occurs once a year. During the winter rain events, the facility experienced moderate flooding. Staff determined that a culvert was blocked, causing water to backup and flood. The Town cleared the blockage and will continue regular maintenance on that culvert in the future. Salt was found eroding from the salt/sand shed. Routine sweeping along the area is recommended. Figure Exported: 8/21/2019 By: mroberts Using: \\woodardcurran.net\shared\Projects\0227871.05 Lexington MA - 2018-2019 MS4 Support\wip\GIS\Project Files\DPW_SWPPP_Figure2_11x17_August2019.mxd"¥ "¥ "¥"¥"¥ "¥ "¥"¥ "¥ "¥ "¥ "¥ "¥"¥ "¥ "¥ "¥ "¥ "¥ "¥ "¥ "¥ "¥ "¥ "¥ "¥ "¥ "¥ "¥ !!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 ! # #;;;;;;;;; AsphaltEmulsifier Salt ShedTrailersPlowsDPW Buildin g Equipment St o r a g e Maintenance Bay WashBay FluidBay Offices ParkingCold Storage;;;;TrailersLoading Dock;TemporaryLandscaping Storage PublicSand CatchBasinFixtures PVCPipeCardboard Dumpster Recycling Plastic TotersWaste Dumpster Pallets Scrap MetalRoll-Off Dumpster BrineSolutionTanks Concrete Blocks FuelingStation TransformerDiesel Generator Manufactur e d S y s t e m Infiltration C h a m b e r Manufactured SystemInfiltration ChamberManufactur e d S y s t e m I n f i l t r a t i o n C h a m b e r Manufactured SystemInfiltration ChamberDownstreamDefender ManufacturedSystemGreen Roof RainGarden RainGarden RainGarden Rain Garde n Rain Garden ConstructedStormwater WetlandInfiltration - Porous PavementIn f i l t r a t ion - Po rou s Pa v emen t Vegetated Swale Vegetated Swale Ve g e t a te d Swa le SedimentForebay SedimentForebay Sediment Forebay SedimentForebay «2«1 «3 «4 Hydrant F Service Layer Credits: Source: Esri, Ü 0 50 100 150 20025 FeetLegend #Outfall DPW Site Features !!2 Manhole "¥Catchbasin Collector Culvert Open Channel Drainage Areas Stormwater Treatment CITY OF LEXINGTON, MASWPPPDPW SiteDrainage FIGURE 3-2 DATE: AUGUST 2019 JOB NO.: 0227871.05 DOC: DPW_SWPPP_Figure2_11x17_August2019.mxd DRAWN BY: JS/JC 1 " = 100 'SCALE: Town of Lexington - DPW Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 1 of 10 Town of Lexington DPW Facility SWPPP Inspection Photos Vegetated swale located behind the parking lot. Town of Lexington - DPW Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 2 of 10 DPW rain garden located south of the DPW offices. Town of Lexington - DPW Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 3 of 10 The Manufactured System Infiltration Chamber located adjacent to the DPW Building. Town of Lexington - DPW Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 4 of 10 Outlet located in the DPW facility (top photo, HDPE pipe). Inlet located in the DPW facility (bottom photo, RCP pipe). Town of Lexington - DPW Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 5 of 10 Salt/sand shed. Routine sweeping around the shed is recommended. Town of Lexington - DPW Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 6 of 10 Riprap at swale should be refreshed/replenished (top photo, located adjacent to the Minuteman bike path). Riprap behind the DPW’s salt shed continues to be working properly. Riprap should be refreshed/replenished (bottom photo, located behind the salt shed) Town of Lexington - DPW Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 7 of 10 Town of Lexington - DPW Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 8 of 10 Town of Lexington - DPW Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 9 of 10 Town of Lexington - DPW Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 10 of 10 Outfall located north of the DPW. envpartners.com APPENDIX B Compost Facility Site Observation Report, Figure, and Photos QUARTERLY SITE INSPECTION CHECKLIST Description of Any Discharge Occurring at the Time of the Inspection: Conduct a thorough inspection of the entire facility and grounds. Areas to Inspect Potential Pollutant Sources:Description of problem: Good Action Needed? (Routine) “Corrective Action”† Needed? Action Completed? (Date) Parking Lots & Vehicle Traffic Areas Waste Collection (scrap metal) Compost Piles Catch Basin Cleanings & Street SweepingsEquipment Storage & Maintenance Areas Electric Transformers 400-Gallon Fuel Oil Tank Septic Tank Holding Area Earth Material Storage Area Yard/Storage Area General Facility Grounds & Outfall:Good Action Needed? (Routine) “Corrective Action”† Needed? Action Completed? (Date) Inspect catch basins, outfall, gutters, compost piles, and stormwater infiltration areas for evidence of damage, erosion or any discharge of pollutants. Ensure that facility grounds show no signs of poor housekeeping (e.g., materials, residues, or trash that may come in contact with stormwater). Ensure there are no spots, pools, puddles, or other traces of oil, grease, or other chemicals on the ground around the facility, either liquid or solid. Ensure there is no evidence of offsite tracking of materials and no blowing of raw, final, or waste materials outside of the operational areas. Ensure there are no leaks or spills from equipment, drums or other containers, or containers in poor condition outside the facility.†Corrective Action” is triggered for systemic problems with control measures (e.g., if a dumpster lid is occasionally left open, this does not trigger “corrective action;” however, if a dumpster lid is missing or inoperable, this triggerscorrective action. If an area needs routine sweeping, this does not trigger “corrective action;” however, if an area needs sweeping and is not being swept because supplies are not available or staff is not assigned, this triggers corrective action.)Do any control measures need maintenance, repairs, or replacement?  Yes*  No If yes, describe: Identification of any previously unidentified discharges from the Site:  Yes*  No If yes, describe: Any additional control measures needed to comply with permit requirements?  Yes*  No If yes, describe: Date: ____________________________________ Time: Inspector(s) Name(s): Inspector(s) Signature(s): Weather Conditions During Site Visit: Karen Chan, Environmental Partners February 20, 2024 Sunny, 30s N/A 9:45-10:15 AM The Compost Facility likely needs a new stormwater management system to better remove materials from the stormwater prior to discharging off the property. Initial corrective actions can consist of implementing some short-term sediment and erosion control BMPs (e.g. silt sock, berm, rearrangement of compost pile locations) to reduce sediment transport. Intermediate actions can include the Town evaluating site drainage BMPs to improve overall stormwater management at the site. The outlet was partially covered by leaves and other debris, and the outlet's riprap pad contains debris/sediment. Both need maintenance QUARTERLY SITE INSPECTION CHECKLIST Describe any incidences of noncompliance observed (i.e., corrective action needed), summary of corrective actions taken, and date initiated and completed (attach additional sheets if necessary): Are modifications to SWPPP necessary? Yes No If yes, describe: X The two catch basins on site are buried and no longer convey stormwater due to the regrading of the nearby road. The SWPPP should be updated to reflect these changes. The buried catch basins likely no longer need to be observed quarterly. Also, the Town should consider decomissioning the discharge point of the catch basins. Empty oil drums were found in the hazardous waste collection area. If waste oil collection is collected and stored in the facility, they should be placed on a concrete palette, have proper signage, and include an accessible spill kit. *Any required modifications to control measures must be made before the next storm event if possible, or as soon as practicable. Figure Exported: 11/13/2019 By: mroberts Using: \\woodardcurran.net\shared\Projects\0227871.05 Lexington MA - 2018-2019 MS4 Support\wip\GIS\Project Files\Compost_SWPPP_11x17_November2019.mxd") ") !( !( "!;Î"!;Î ;;;;;;;;;;;; ;;;CANOPIED MAINTENANCE SHED MATERIALS STORAGE(catch basin cleaning, cold patch, gravel, rubble, sand, street sweepings) COMPOST AREAS PARKING AREA OFFICE HAZARDOUS WASTE COLLECTION AREA ELECTRICALTRANSFORMER SEPTIC HOLDING TANK MATERIALS STORAGE(clean wood, metal,refrigerators) MATERIALS STORAGE(baseball dirt, gravel, playground mix, rip rap, sand) LOCATION OF STORMWATERDISCHARGE INTO WOODS LOCATION OF STORMWATERDISCHARGE INTO WOODS DA-1 DA-2 DA-3 F Ü 0 50 100 150 20025 Feet Legend Drainage Areas Outfall Lines ")Outfall Points !(Stormwater Discharge "!;Î BMP CITY OF LEXINGTON, MASWPPPCompost Facility Plan FIGURE # 3-2 DATE: NOVEMBER 2019 JOB NO.: 0227871.05 DOC: Compost_SWPPP_11x17_November2019.mxd DRAWN BY: MTR 1 " = 200 'SCALE: Town of Lexington - Compost Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 1 of 10 Town of Lexington Compost Facility SWPPP Inspection Photos Town of Lexington - Compost Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 2 of 10 Town of Lexington - Compost Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 3 of 10 Ponding observed towards the end of the facility. Stormwater management recommended to aid in drainage. Town of Lexington - Compost Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 4 of 10 Outlet is partially covered with debris and is recommended to be cleared with the assistance of the Highway Department. Town of Lexington - Compost Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 5 of 10 Empty propane tanks. Town of Lexington - Compost Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 6 of 10 Electronics stockpiles. Town of Lexington - Compost Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 7 of 10 Barrels were observed as being empty. Town of Lexington - Compost Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 8 of 10 Oil drums were empty during inspection. If waste oil collection is collected and stored in the facility, they should be placed on a concrete palette, have proper signage, and include an accessible spill kit. Town of Lexington - Compost Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 9 of 10 Additional ponding observed around the composting areas. Town of Lexington - Compost Facility February 20, 2024 Winter 2024 – SWPPP Inspection Environmental Partners Page 10 of 10 Additional stock piles located adjacent to the composting piles.