Document 2Re7LyVEo6YLLxoDYzRBQnXeN
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III
1650 Arch Street Philadelphia, Pennsylvania 19103-2029
Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Facility Name: Permittee(s): Facility Operator: Permittee Address: Facility Address: Facility Latitude: Facility Longitude: County/Parish: Permit No: NAICS Code: SIC: Unique Project #:
Clean Water Act Compliance Inspection Report 11/30/2022 National Pollutant Discharge Elimination System (NPDES) Industrial Discharge Program Naval Support Facility Indian Head (NSFIH) Naval Support Facility Indian Head (NSFIH) Naval Support Facility Indian Head (NSFIH) 3972 Ward Road, Suite 101, Indian Head, Maryland 20640-5157 3972 Ward Road, Suite 101, Indian Head, Maryland 20640-5157 38.596648 -77.179034 Charles County MD0003158 562219 4953 3E23WN016A
Facility Representative(s):
Point of Contact
Chris Goddard
Email: christopher.j.goddard2.civ@us.navy.mil
EPA Inspectors:
Kaitlin McLaughlin - EPA Region III
Phone: (215) 814-2393 Email: McLaughlin.Kaitlin@epa.gov
Michael Greenwald - EPA Region III
Phone: (215) 814-2398 Email: Greenwald.Michael@epa.gov
State/Local Inspectors (see report body for list of additional inspectors):
Greg Kolarik
Email: greg.kolarik@maryland.gov
Report Preparer Signature/Date
Supervisor Signature/Date
Kaitlin McLaughlin, Enforcement Officer NPDES Enforcement Section (3ED32)
Digitally signed by MARK
MARK ZOLANDZ ZOLANDZ
Date: 2023.02.03 16:55:07 -05'00'
Mark Zolandz, Section Chief NPDES Enforcement Section (3ED32)
2/2/2023 Date
2/3/2023
Date
Unique Project#: 3E23WN016A
Section
Naval Support Facility Indian Head (NSFIH) - Industrial Discharge Program 11/30/2022
Table of Contents
Page
I Introduction............................................................................ 3 A Inspection Opening Conference...................................................................... 3 B Weather and Precipitation Conditions............................................................. 3
II Facility Activity............................................................................................... 4 III Observations.................................................................................................... 4 IV Records Review............................................................................................... 6 V Closing Conference......................................................................................... 6 VI List of Attachments.......................................................................................... 6
Unique Project #: 3E23WN016A
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Naval Support Facility Indian Head (NSFIH) - Industrial Discharge Program 11/30/2022
I. Introduction
On November 30, 2022, an inspection team composed of staff from the U.S. Environmental Protection Agency ("EPA") Region III (hereinafter, "EPA Inspection Team") conducted an inspection of the Naval Support Facility Indian Head (NSFIH) Industrial Discharge Program. The purpose of the inspection was to observe compliance with the Clean Water Act (CWA) and to verify compliance with the facility's National Pollutant Discharge Elimination System (NPDES) Permit No. MD0003158 (hereinafter, the "Permit") and applicable State and Federal regulations.
A. Inspection Opening Conference
The EPA Inspection Team arrived at the facility at approximately 8:00 AM. Representatives from the Maryland Department of the Environment (MDE) were in attendance. The following inspectors and representatives were present for the inspection:
Name
Kaitlin McLaughlin Michael Greenwald
Linsey De La Rosa Hayden Dermanelian
William Fabey Chris Goddard Tara Meadows Kenneth Robitaille
Diana Rose Victoria Waranoski
Greg Kolarik
Table 1: Inspection Attendee List
Affiliation
Telephone
Email
EPA Region III Inspectors
EPA Region III 215-814-2393
McLaughlin.Kaitlin@epa.gov
EPA Region III 215-814-2398
Greenwald.Michael@epa.gov
Facility Representatives
NSFIH EV
956-975-7415
linsey.delarose.civ@us.navy.mil
NSWC
703-587-1681 hayden.dermanelian.civ@us.navy.mil
NSFIH EV
301-997-3776
william.b.fabey.civ@us.navy.mil
NSFIH EV
240-298-4376 christopher.j.goddard2.civ@us.navy.mil
NSFIH EV
202-718-0665
tara.l.meadows2.civ@us.navy.mil
NSFIH EV
202-718-0682 kenneth.r.robitaille.civ@us.navy.mil
NSFIH EV
301-744-2267
diana.l.rose.civ@us.navy.mil
NAVFAC EV 202-685-8056 victoria.m.waranoski.civ@us.nvy.mil
State or County Representatives
MDE
443-532-9020
greg.kolarik@maryland.gov
Kaitlin McLaughlin and Michael Greenwald displayed their credentials to the facility representatives at the outset of the inspection, and explained the purpose of the inspection was to observe compliance with its Permit. A copy of the Permit is provided in Attachment 1.
B. Weather and Precipitation Conditions
The closest 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 Data
Station Name
Date
ALEXANDRIA 6.6 WNW, VA US US1VAFX0081 ALEXANDRIA 6.6 WNW, VA US US1VAFX0081
11/24/22 11/25/22
Precipitation Amount (inches)1 0.00
0.11
1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/).
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Naval Support Facility Indian Head (NSFIH) - Industrial Discharge Program 11/30/2022
ALEXANDRIA 6.6 WNW, VA US US1VAFX0081 ALEXANDRIA 6.6 WNW, VA US US1VAFX0081 ALEXANDRIA 6.6 WNW, VA US US1VAFX0081 ALEXANDRIA 6.6 WNW, VA US US1VAFX0081 ALEXANDRIA 6.6 WNW, VA US US1VAFX0081 ALEXANDRIA 6.6 WNW, VA US US1VAFX0081
11/26/22
0.04
11/27/22
0.00
11/28/22
0.19
11/29/22
0.00
11/30/22
0.21
12/1/22
0.08
II. Facility Activity
NSFIH is a naval base which consists of various industrial activities including explosive and propellant manufacturing, research, development, assembly, and testing. The facility discharges industrial wastewater, stormwater, and various process wastewaters.
The facility implements an industrial program and is regulated under the Permit, which became effective on June 1, 2022 and expires on May 31, 2027. The facility discharges through various outfalls to the Potomac River and the Mattawoman Creek, both designated as Use II under the Cost of Maryland Regulations (COMAR) 26.08.02.02 protected for water contact recreation, fishing, aquatic life, wildlife, and support of shellfish harvesting (non-shellfish harvesting) water and is protected for estuarine and marine aquatic life.
The inspection included discussions with industrial staff, file reviews, and field visits. The discharge locations are documented in the facility's Storm Water Pollution Prevention Plan (SWPPP) (Attachment 3). A certification statement is included with the SWPPP that was signed by the facility on March 29, 2022.
The EPA Inspection Team conducted additional on-site interviews and reviewed a portion of the facility's records. Additional records were reviewed offsite.
Observations based on both the offsite compliance review and the field visits are documented in the sections below.
III. Observations
The inspection began with a records review and interview questions. The inspection observations below are made pursuant to the requirements of the Permit. Photographs were taken during the inspection by a facility representative Linsey De La Rosa and are provided in Attachment 2. The Photograph Log referenced throughout this inspection report is designated as Controlled Unclassified Information (CUI).
The EPA Inspection Team traveled to and inspected the outfalls discussed below in this section with facility representatives. Facility representatives stated that each of the industrial outfalls are sampled once a month and recorded in the monthly field log. The October 2022 Industrial Outfalls Monthly Field Log is provided in Attachment 4.
The Permit has the outfalls divided into different Groups based on the effluent limitations and monitoring requirements of each outfall. The EPA Inspection Team visited an outfall from each Group.
Unique Project #: 3E23WN016A
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Naval Support Facility Indian Head (NSFIH) - Industrial Discharge Program 11/30/2022
The Group 3 outfall the EPA Inspection Team visited was Outfall 1696 (Photograph Log, Page 48). Outfall 1696 is located at the Agile Plant and consists of non-contact cooling water. Photograph Log, Pages 49-52 show downstream of outfall 1696.
The groundwater outfall the EPA Inspection Team visited was groundwater discharge 696 outside of Building 696. The discharge is from a sink inside Building 696 (Photograph Log, Page 69) which flows into a PVC pipe under the sink (Photograph Log, Page 68) and through the wall outside (Photograph Log, Pages 66 and 67). The discharge from outfall 696 is hand and wash sink wastewater.
The Group 5 outfall the EPA Inspection Team visited was outfall 107 (Photograph Log, Page 70). Outfall 107 is located at Building 3123 which is a Reverse Osmosis Building. The discharge out of outfall 107 is reverse osmosis reject water.
The Group 4 outfall the EPA Inspection Team visited was outfall 140 (Photograph Log, Pages 73 and 71). Outfall 140 is located at the former coal pile runoff area. There previously used to be a coal plant at this location with coal storage piles. Facility representatives stated that the plant had been demolished and the last coal piles had been removed over 4 years ago. Facility representatives also stated that the outfall is still designated as a coal pile runoff discharge outfall in the permit because MDE requires the piles to have been removed for at least 5 years.
Observation 1.
At the time of the inspection, The EPA Inspection Team observed foam in outfall 140 (Photograph Log, Page 72). The EPA Inspection Team also observed the upstream drainage area leading to outfall 140 (Photograph Log, Page 74) and did not observe any foam.
The Group 6 outfall the EPA Inspection Team visited was outfall 100A. At the time of the inspection, the outfall pipe was below the surface of the water of the settling pond (Photograph Log, Pages 77 and 78). There is signage at the 100A settling pond describing the pool of water (Photograph Log, Pages 75 and 76). The discharge from outfall 100A consists of river water backflush.
The Group 2 outfall the EPA Inspection Team visited was outfall 1030 (Photograph Log, Page 81). The outfall is located at the Trident Facility. The sampling location is inside the building, but the discharge flows through a PVC pipe into the floor of the building (Photograph Log, Page 83) and out of the side of the building (Photograph Log, Page 84). The PVC pipe ends in a swale outside and the flow continues downstream (Photograph Log, Pages 85-87). The discharge from outfall 1030 is comprised of non-contact cooling water and groundwater infiltration.
The Group 1 outfall the EPA Inspection Team visited was outfall 849 (Photograph Log, Page 89) located inside Building 849. The outfall line drains to a cooling well outside the building (Photograph Log, Page 91) then discharges to a ditch (Photograph Log, Page 90) and continues downstream. The discharge out of outfall 849 is non-contact cooling water.
Unique Project #: 3E23WN016A
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Naval Support Facility Indian Head (NSFIH) - Industrial Discharge Program 11/30/2022
IV. Records Review
EPA requested and received copies of the following documents:
Last 3 months of Net DMRs Building 849 settling tank info Most recent monthly field sheet
Records pertaining to the inspection report are attached, with additional records being kept on file.
V. Closing Conference
After the site walk, the EPA Inspection Team met with the site representatives for a closing conference. The EPA Inspection Team shared preliminary observations with the site representatives. The EPA Inspection Team reiterated to the site representatives that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation 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 industrial inspection was the second inspection of a three-part CWA inspection of NSFIH. The third and final inspection of NSFIH was concluded on December 1, 2022. At the conclusion of the third inspection, the EPA Inspection Team met with site representatives for a comprehensive closing conference. The EPA Inspection Team shared preliminary observations with the site representatives and reiterated the above information.
The final closing conference concluded at approximately 3:00 PM on December 1, 2022.
VI. List of Attachments
Attachment 1. Attachment 2. Attachment 3. Attachment 4.
NPDES Permit Photograph Log SWPPP October 2022 Industrial Outfalls Monthly Field Log
Unique Project #: 3E23WN016A
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