Document 2Nzn38KEgOEXojrDEzjyyyVD7

EPA REGION 10 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statutes/Programs Type of Inspection 06/07/2024 09:00 AM (PT) Announced: Yes 06/07/2024 02:30 PM (PT) Access: Granted 55F, Sunny Water Clean Water Act, NPDES, Stormwater - Industrial Compliance Evaluation Inspection Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code Borough Facility GPS Coordinates Mailing Address City, State, Zip Code Mark Reid Alaska Marine Trucking, LLC 3295 Tongass Avenue Ketchikan, Alaska 99901 Ketchikan Gateway 55.35374, -131.68862 6520 Kulis Drive Anchorage, Alaska 99502 FRS ID Permit Number SIC 110067188215 AKR06AC74 4212 (Local Trucking, without Storage) Lead Inspector: RAYMOND ANDREWS Date: 2024.07.30 10:32:21 -07'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2024.07.30 11:05:31 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA Region 10 contreras.peter@epa.gov (206) 553-6708 Alaska Marine Trucking, LLC NPDES Permit # AKR06AC74 SECTION I - Opening Conference I arrived at the Alaska Marine Trucking, LLC (the "Site", "Facility", or "AMT"), located at 3295 Tongass Avenue, Ketchikan, Alaska at 09:00 AM (PT) on 06/07/2024 for an announced inspection. I presented my credentials to Ilir Zhuta and informed him I was there to determine compliance with the Clean Water Act (CWA), and the facility's National Pollutant Discharge Elimination System (NPDES) permit, permit # AKR06AC74. This report is based on information supplied by facility representatives, direct observations made by me, and records and reports maintained by the facility. In addition, information gathered prior to, or after, the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization Attendee Name Title Present in Present in Opening Conf. Closing Conf. EPA Region 10 Raymond Andrews Lead Inspector Yes Yes Alaska Marine Trucking Ilir Zhuta Service Center Yes Yes Manager Alaska Marine Trucking Andrew Heuscher Director of Regulatory Yes Yes Compliance & Claims Alaska Marine Trucking Jeffrey Barney HSSE Manager Yes Yes Facility Information Responsible official? Jeffrey Barnes, HSSE Manager Type of Operation The facility is a freight moving company. The facility receives incoming freight from barges. Outgoing freight is received from customers, prepared for shipping, and shipped out on barges. Industrial Sector? The facility is in Sector P (Land Transportation and Warehousing). Sector P does not require any pollutant monitoring. Is property owned or The site is owned by Alaska Marine Trucking. leased? Size of Facility The facility site is approximately three acres. Years in operation? The business has been in operation for approximately 52 years under AMT. Number of employees? The facility maintains approximately 19 year-round employees. Days and hours of operation? The warehouse operates Monday through Friday from 8am until 5pm. Shifts and number of personnel working are adjusted when barges come in for off-loading. Personnel conducting Mr. Zhuta conducts the sampling for Quarterly Visual Inspections (QVIs) and inspections/sampling? prepares the Discharge Monitoring Reports (DMRs). Receiving Water? The facility discharges into Tongass Narrows. Industrial activities exposed to stormwater? Heavy equipment, i.e., forklifts, is exposed to stormwater as it loads and unloads barges. Forklifts are stored outside when not in operation. The facility does conduct vehicle maintenance on-site, but it is performed on a concrete pad in a bay. Number/location Outfalls? The facility has two outfalls. Outfall 1 is located near the southwest corner of the yard. The stormwater that is discharged through Outfall 1 passes through an oil/water separator prior to discharging off-site. Outfall 2 is located near the southeast corner of the yard. 2 of 5 Alaska Marine Trucking, LLC NPDES Permit # AKR06AC74 Sampling locations? Discharges are sampled at the outfalls. BMPs/Stormwater Treatment? The facility uses catch basins with cloth filters to treat stormwater. The catch basins are also surrounded by booms to slow water flow and filter out sediment. Water that enters the catch basins flow directly to one of the outfalls. An oil/water separator receives drainage from the shop rooftop. The o/w separator also receives water from a floor drain in the shop, but the shop drain is not exposed to stormwater. The facility uses berms to direct stormwater to the catch basins. SECTION II - Observations During the site tour, I did not observe anything that would constitute an area of concern. SECTION III - Records Review Records may not be in sequential order. Record: Other - Quarterly Visual Inspections (QVIs) AOC: No Ref #: RA1-RR-008 Reviewed By: Raymond Andrews Reviewed Date: 06/07/2024 At the time of the inspection, I reviewed the facility's QVIs covering 1Q 2021 through 1Q 2024. I did not note any areas of concern. Record: Other - Routine Inspection Reports AOC: No Ref #: RA1-RR-007 Reviewed By: Raymond Andrews Reviewed Date: 06/07/2024 At the time of the inspection, I reviewed the facility's Routine Inspection Reports covering the January 2021 through May 2024. I did not note any areas of concern. Record: Other - EPA's Integrated Compliance Information System (ICIS) Database AOC: Yes Ref #: RA1-RR-006 Reviewed By: Raymond Andrews Reviewed Date: 06/07/2024 At the time inspection, I reviewed a report from EPA's ICIS database covering the period from June 2019 through May 2024. The report indicated the facility submitted its 2020 through 2022 Annual Report late. Record: Other - APDES Inspection Report AOC: No Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Reviewed Date: 06/07/2024 At the time of the inspection, I reviewed an inspection report for an inspection conducted by the Alaska Department of Environmental Conservation (ADEC) on September 29, 2020. The only Area of Concern listed by ADEC was the SWPPP had a previous permit number. ADEC told the facility it should update the SWPPP to show the current permit number. The SWPPP I reviewed for this inspection had the correct permit number. I did not note any areas of concern. Record: Other - Notice of Intent (NOI) to Discharge and the ADEC Authorization to Discharge AOC: No Letter Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 06/07/2024 At the time of the inspection, I reviewed the facility's Notice of Intent (NOI) to Discharge and the ADEC Authorization to Discharge Letter. The NOI was dated July 24, 2020. The Authorization Letter approved the facility's request to discharge with an effective date of August 17, 2020. 3 of 5 Alaska Marine Trucking, LLC NPDES Permit # AKR06AC74 Record: Other - Audit Letter Ref #: RA1-RR-003 Reviewed By: Raymond Andrews AOC: No Reviewed Date: 06/07/2024 At the time of the inspection, I reviewed an audit letter from Restoration Science & Engineering, LLC (RSE). AMT called in RSE to perform a SWPPP audit. RSE audited the SWPPP in May 2024, and found inconsistencies between the original SWPPP, dated July 2020, and conditions on the ground. Record: Other - Stormwater Pollution Prevention Plan (SWPPP) AOC: Yes Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 06/07/2024 At the time of the inspection, I reviewed the facility's SWPPP. The SWPPP had a preparation date of July 2020 with a "SWPPP Revision Date DRAFT" of June 2024. The revised SWPPP draft was in response to the audit conducted by RSE the previous month. The SWPPP was certified by the company President, Mark Reid, on June 6, 2024. The revised SWPPP addressed most of the issues discovered by RSE during its audit; however, the facility SWPPP map was incomplete. The map was missing, the size of the property in acres, locations of all existing structural controls (i.e., berms), and locations of all stormwater monitoring points. Record: Other - Signature Delegation AOC: No Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 06/07/2024 At the time of inspection, I reviewed the facility's "Designation of Signature Authority", dated April 26, 2024. Signature authority was delegated from Mark Reid, President, to Ilir Zhuta, Service Center Manager, and Jeffrey Barney, Health, Safety, Security, and Environmental Manager (HSSE). SECTION IV - Sampling Activity No sampling was conducted. SECTION V - Areas of Concern Areas of concern may not be in sequential order. The presentation of areas of concern does not constitute a formal compliance determination or violation. AOC Reference #: RA1-RR-002 Records Review: Other - Stormwater Pollution Prevention Plan (SWPPP) Permit Requirement Part 5.2.3.3 of the permit states, in part, the SWPPP should "Provide a map showing...the size of the property in acres...locations of all existing structural control measures...locations of all storm water monitoring points..." AOC: The facility SWPPP map was incomplete. The map was missing, the size of the property in acres, locations of all existing structural controls (i.e., berms), and locations of all stormwater monitoring points. AOC Reference #: RA1-RR-006 Records Review: Other - EPA's Integrated Compliance Information System (ICIS) Database Permit Requirement Part 9.1 of the permit states, in part, "All monitoring data collected pursuant to Parts 7.2 must be submitted to DEC...no later than the 15th day of the following month after the permittee has received the complete laboratory results for all monitored outfalls for the reporting period. AOC: The facility submitted its 2020 - 2022 Annual Reports late, as seen in the table below. Annual Report Year Annual Report Due Annual Report Received 2020 February 15, 2021 April 06, 2023 2021 February 15, 2022 April 06, 2023 2022 February 15, 2023 January 03, 2024 4 of 5 Alaska Marine Trucking, LLC NPDES Permit # AKR06AC74 SECTION VI - Closing Conference I held a closing conference with facility personnel at 02:30 PM (PT) on 06/07/2024 for the inspection. During the closing conference, I discussed the observations and Areas of Concern I identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - List of Appendices 1. Photo Log 5 of 5 APPENDIX 1: Photo Log All photos were taken by Lead EPA Inspector, Ray Andrews, during the inspection. Photos were not manipulated beyond minor cropping for sizing and labels or callouts to draw attention to the subject of the photo. All photos taken during the inspection are included in the Photo Log; however, only photos that support an Observation or Area of Concern are included in the inspection report. P1010971 - SWPPP Cover Page P1010972 - SWPPP, page 2 P1010973 - South Outfall P1010974 - Protected Catch Basin P1010975 - Protected North Catch Basin