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