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The City of Harrisburg, Pennsylvania, Incorporated March 19, 1860 Department of Puble Works gineering Apuil 15, 2015 Mr. Paul B, MeNamee, President McNamee Strategic Consulting, LLC '525 Gatehouse Ln W. York, PA 17402-4332 Re: 1400 Block of South 14* Street CDBG-DR Program Application Environmental Review Record ‘Dea Mr, MeN ‘This letter is in response to your email and letter dated April 6, 2015. In your emsil you stated that you stated the process ofthe Environmental Review forthe project. As discussed ‘during our March 23,2013, the majority of the Funding for this project willbe through FEMA ‘and FEMA requires both the historic and environmental review to be handled by FEMA Region LL, During a phone conversation with HUD officials including HUD Region IMf Director Jane Vincent) on April 9, 2015, the HUD officials confirmed that the Historic and Environmental Review should be coordinated with FEMA. Please do not stat the process of the Environmental Review forthe project before coordinating with FEMA, Here is response to your specific request for information: 1. Requests In discussions with HUD, there must be a direct connection of the sinkhole mitigation project to Tropical Storm Lee relative to the uiilization of CDBG-DR program funds. In reviewing the Gannet Fleming reports attached to the Application, I did ‘nol fd any discussion relative to the sinkholes being caused as a divect result of Tropical Storm Lee. There is mention that the sinkholes could be the result of fluctuating groundwater levels due to heavy precipitation and runoff and seasonal groundwater fluctuations, as well as leaky utility tines. There is also discussion that sinkholes had developed in the area prior to 2011. It is necessary that the City provide further engineering and geotechnical/geologic information and detail that provide evidence, connectivity or some further connection with Tropical Storm Lee. I am available to meet with you and Gannet Fleming. to further diseuss this issue, Without the farther connection ‘0 a declared disaster-related event, the project could possibly be deemed ineligible for CDBG-DR funding, Response: First, [kindly request that you invite me to participate in any future lscussions with HUD about this project to avoid confusion and duplication of effort. Second, 1 kindly request that if you are going to state ar inger thatthe City's application fils to meet a legal or regulatory standard, that you reference the specific statute or regulation at issue. Thitd, if ‘you are going to allege that a federal official made a determination, please be name the individual to avoid confusion and duplication of effort. Finally, it is unfortunate that you did not attend the Sinkhole Summit held on November 7, 2014 where the City had numerous experts ftom all over the country speak about ths topic. Every level of govemnment, except for Dauphin County, was in attendance. Ifyou had attended the Sinkole Summit and read the three reports prepared by Gannett Fleming, Inc. you would see that the connection ofthe project to Tropical ‘Storm Lee's self-evident. Simply put, the heavy rainfall that oceured during Tropical Storm Lee resulted in serious and more frequent sinkhole activity in the location ofthe project and the scope ofthis project isto mitigate that activity A sinkhole isa subsidence feature. Subsidence occurs through the eter) the physical and chemical weathering of rock; 2) excessive pumping of groundwater or (3) subsurface erosion due to the failure of existing uty lines. Thee is wo pumping of eroundvate nthe eit of the project. Therefore, the sinkholes present onthe 1400 book of South I Street in Harrisburg could not have been caused by the pumping of groundwater. As demonscated in South HarisburgSinkhole Evaluation reports, the only underground utiles on this block are water and gas. There are no sanitary or stonm sewer on the 1400 block of South 14" Sueet. A ‘water main beak id occur oncustently wit the sinkholes that opened-up in March of 2014 Following the incident, Capital Region Water, the owner ofthe water main filed a chim with its insurance carrie. The erie hired an independent engineer (investigate the break (including the pipe ite and determined that the water main break was caused by the collapse ofthe earth underneath the water main, This finding is eosistent with () the lack of reported water leaks prior othe sinkhole; (2) the fet hat sinkholes continue vo appea afte the water man was repuized; (3) the large number of actre-like anomalies observed several blocks away frm the location ofthe water main break; and (4) the presence of subsurface features on roadways with 10 utilities suchas Seot St and Pigeon St Having ruled out both groundvater pumping and failure of existing silty line as causes, the eause a the sinkholes that continue to appear on the 400 block of South 14® Steet in Harrisburg could only have been caused by the physical and ehemical weathering of the rock. ‘The physical weathering of rock ia slow process, while the chemical weathering is an accelerated process. As explained in the Emergency Sinkhole Investigation Report, a core boring was taken approximately 65 fet from the intersection of South 14 and Magnolia Steet to recover soi and rock samples for classification, ‘The result ofthe boring confirmed that he sol layer was cay and the rock layer was limestone. ‘The significance of limestone is that it can be dissolved by certain acids. The solubility ‘of limestone in pure water is extremely low. “Rainwater in Pennsylvania hasan average pH of | 4.5, 80 we see that rainwater is an acid.” Kochanov, W.E. (2005), Sinkholes in Pennsylvania: Pennsylvania Geological Survey, Educational Sevies 11, pp. 5. “The rate ofthe dissolution of Himestone] rack generally depends on the solubility and specific rate constant of the constituent ‘mineral, the degree of saturation of the solvent, the area presented othe solvent and the motion ofthe solvent... Major concentrations of earbon dioxide are released when organic material ‘decays, and are taken into solution by rainwater that percolates through the soil, This infiltration ‘drainage isthe prime source of chemically aggressive groundwater in limestone karst.” ‘Waltham, Bell and Culshaw, (2005), Sinkholes and Subsidence: Karst and Cavernous Rocks in Engineering and Construction, pp. 5-7, Springer-Praxis. ‘Knowing that groundwater can dissolve limestone ina relatively short time period (compared tothe physical weathering of rock) the investigation leads tothe periods of high ‘ground water tables. The heavy precipitation and resulting high ground water tables during ‘Tropical Storm Lee are documented inthe CDBG-DR Program Guidelines, “Tropical Storm Lee began impacting Pennsylvania on the evening of Tuesday, September 6, 2011, Statewide rainfall totals of 5.5 to 17.37 inches fell over the frst 48 hours f te storm. The entire commonwealth received above average rain fll over the previous 30 days, and the streams were all running high a aresult” The City of Harisburg was at the center ofthe storm. Based upon a U.S. Dopattment of Commerce, National Oceanic and Atmospheric Administration's Regional Service Assessment, Remnants of Tropical Storm Lee and the Susquehanna River Basin Flooding of September 6-10, 2011, the closest recordings tothe project site were 2E Paxtonia ‘hich received 13.51 inches and the Harrisburg Airport which received 13.30 inches. ‘The rainfall accumulations and high-water records were shattered during Tropical Storm Lee and the effects of storm on the groundwater table at the projet site, which was already saturated by Hurricane Irene rainfall, was unprecedented As stated in South Harrisburg Sinkhole Evaluation, the “area is prone to fluctuations in {groundwater level due to periods of heavy precipitation.” Tropial Storm Lee qualifies as a Petiod of heavy precipitation, MeGlade and Geyer (1976) indicate that in the limestone geology found in the greater Harrisburg metropolitan area, “Ground-water levels fluctuate seasonally and respond rapidly to heavy rains and surface runo.” Ii also stated inthe same reference that, “Water table shows rapid response to heavy rains because of recharge to well-developed subsurface drainage.” ‘The report goes on to explain the delay inthe sinkhole activity caused by the fluctuating groundwater able. "The natural aching action of overburden soils und pavement sections can delay the surface expression of developing voids suchas sinkholes and closed depressions.” (GF Report 2, page 4). Collapses occur, and a sinkhole is formed, when the thick ‘overburden lacks adequate arch fo support the overburden pressures and by soil raveling, where ‘moisture causes the upper portion ofthe cavity to erode and collapse into the cavity. Soil raveling is typically eaused by changes in groundwater levels, ineluding the severe rainfall, ding Tropical Storm Lee, According to Dauphin County's Hazardous Mitigation Plan dated December 27, 2010 there have been two sinkholes in the project vicinity prior to December 27, 2010. The City of Hereisburg has one documented sinkhole onthe 1400 block of South 14" St. prior to Tropical Storm Lee (that oceured in 2007). Following Tropical Storm Lee, at least five sinkholes have

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