Document 6BpbbvzLBxw44wR9KXpOR672E
EPA REGION 10 Enforcement and Compliance Assurance Division
INSPECTION REPORT
Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute/Program Type of Inspection
06/06/2023 09:30 AM (PT)
Announced: No
06/06/2023 02:25 PM (PT)
Access: Granted
46F, Overcast, Drizzly
Water
Clean Water Act, NPDES, 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
Petro Star Kodiak - North Pacific Fuel Petro Star Kodiak - Bulk Petroleum Terminal 715 Shelikof Street Kodiak, Alaska 99615 Kodiak Island 57.78483, -152.42387 3900 C Street Anchorage, Alaska 99503
FRS ID Permit Number SIC
110025220990 AK0029441 5171 (Petroleum bulk stations & terminals)
Lead Inspector:
RAYMOND ANDREWS Date: 2023.07.12 11:30:49 -07'00' Digitally signed by RAYMOND ANDREWS
Raymond Andrews
EPA Region 10
andrews.raymond@epa.gov
(206) 553-4252
Supervisor Review:
PETER CONTRERAS Date: 2023.07.12 11:41:27 -07'00' Digitally signed by PETER CONTRERAS
Peter Contreras
EPA Region 10
contreras.peter@epa.gov
(206) 553-6708
Petro Star Kodiak - Bulk Petroleum Terminal AK0029441
SECTION I - Opening Conference I arrived at the Petro Star North Pacific Fuel Kodiak Terminal (the "Site" or "Facility"), located at 715 Shelikof Street, Kodiak, Alaska, at 09:30 AM (PT) on 06/06/2023 for an unannounced inspection. I presented my credentials to Rick Borton and informed him I was there to conduct an inspection to determine compliance with the Clean Water Act (CWA) and the facility's Alaska Pollutant Discharge Elimination System (APDES) permit, permit # AK0029441. This report is based on information supplied by Petro Star representatives, direct observations made by me, and records and reports maintained by the permittee. 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
North Pacific Fuel
Cleo Chernoff
Administrative Manager
Yes
Yes
North Pacific Fuel
Rick Borton
Kodiak Terminal Manager
Yes
Yes
Facility Information Responsible Official Type of Operation
Size of Facility Outfalls
Lisa Lewis; llewis@petrostar.com
The facility is a fuel distribution operation. The primary focus of the operation is the fueling of sea-going vessels. However, the facility does deliver fuel to some homes and businesses on Kodiak Island.
The facility site is approximately 2.5 acres, which includes the upper and lower tank farms and the receiving and distribution terminal.
The site has three Outfalls.
Outfall 001 (Terminal) - Water collected at the terminal goes to an underground storage tank with an oil/water separator. Once the influent passes through the oil/water separator, it is pumped to a 2,900 gallon above ground holding tank. Once the tank is full, its pH and temperature are tested, and it's visually observed for sheen prior to discharge into the storm drain. The storm drain flows to St Paul's Harbor.
Outfall 002 (Upper Tank Farm) - Water is collected in a lined lagoon. When the lagoon is full, it is checked for pH, temperature, and sheen. If those parameters are within acceptable limits, the water is pumped over a containment wall into a field so it can infiltrate. If a sheen is observed, the water is pumped to the holding tank at Outfall 001 so it can go through the oil/water separator and then follows the path of Outfall 001.
Does the facility selfanalyze? Do you contract out for laboratory analyses?
How many employees do you have? When does the facility operate?
Outfall 003 (Lower Tank Farm) - Follows the same process as Outfall 002.
The facility monitors pH, flow, total aromatic hydrocarbon (TAH), and total aqueous hydrocarbon (TAqH).
Twice a year, the facility sends water samples to a contract lab for analysis of TAH and TAqH. The contract lab is:
SGS North America Inc. 200 West Potter Drive Anchorage, Alaska 99518 (907) 562-2343
The facility conducts year-round operations from 8:00 am until 5:00 pm, Monday through Friday. An "on-call" person is available on the weekends and after hours. The facility has a total of 11 employees, including four office personnel,
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Petro Star Kodiak - Bulk Petroleum Terminal AK0029441
SECTION II - Observations I did not observe any areas of concern during the site tour.
SECTION III - Records Review Records may not be in sequential order. Record: Other - Weekly Tank Farm and Pipeline Inspection Log
Ref #: RA1-RR-012 Reviewed By: Raymond Andrews
AOC: No Reviewed Date: 06/06/2023
At the time of inspection, I reviewed the facility's Weekly Tank Farm and Pipeline Inspection Logs from January 2022 through june 2023. I did not find any issues.
Record: Other - Oil/Water Separator Inspection Checklist
AOC: No
Ref #: RA1-RR-011 Reviewed By: Raymond Andrews
Reviewed Date: 06/06/2023
At the time of inspection, I reviewed the facility's oil/water separator inspection logs from January 2022 through May 2023. I did not find any issues.
Record: Other - Letter from EPA to Facility
AOC: No
Ref #: RA1-RR-010 Reviewed By: Raymond Andrews
Reviewed Date: 06/06/2023
At the time of the inspection, I reviewed a letter, dated October 17, 2022, from EPA to the facility. The letter stated EPA had reviewed the facility's Facility Response Plan and it met the requirements of 40 CFR and the Clean Water Act. EPA informed the Facility its Response Plan was approved for 5-years ending October 17, 2027.
Record: Other - Best Management Practice (BMP) Plan and BMP Review Certification
AOC: No
Ref #: RA1-RR-009 Reviewed By: Raymond Andrews
Reviewed Date: 06/06/2023
At the time of the inspection, I reviewed the facility's BMP plan, dated September 2020. I also reviewed the BMP Plan certification, dated January 31, 2022, for the 2021 reporting year. I did not find any issues with either document.
Record: Other - ADEC Noncompliance Notification
AOC: No
Ref #: RA1-RR-008 Reviewed By: Raymond Andrews
Reviewed Date: 06/06/2023
At the time of inspection, I reviewed a Noncompliance Notification from the facility to the Alaska Department of Conservation (ADEC). The notification was dated February 9, 2021, and notified the state the facility did not conduct the 2021 annual review and certification of the Best Management Practices (BMP) plan by the January 31st deadline. The certification was subsequently submitted.
Record: Other - Chain of Custody Record
AOC: No
Ref #: RA1-RR-007 Reviewed By: Raymond Andrews
Reviewed Date: 06/06/2023
At the time of the inspection, I reviewed a random chain of custody document, dated December 15, 2020. I did not find any issues.
Record: Other - Secondary Containment Drainage Log
AOC: No
Ref #: RA1-RR-006 Reviewed By: Raymond Andrews
Reviewed Date: 06/06/2023
At the time of inspection, I reviewed the facility's Secondary Containment Drainage Log, dated May 10, 2023. The drainage log tracks the pH, if a sheen was observed, when the pumps were opened and closed, and the total gallons drained.
Record: Other - pH Meter Calibration Logs
AOC: No
Ref #: RA1-RR-005 Reviewed By: Raymond Andrews
Reviewed Date: 06/06/2023
At the time of inspection, I reviewed the facility's pH Meter Calibration Logs from November 2022 through May 2023. The pH meter is calibrated prior to each use. I did not find any issues.
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Petro Star Kodiak - Bulk Petroleum Terminal AK0029441
Record: Other - Discharge Monitoring Reports (DMRs) Ref #: RA1-RR-004 Reviewed By: Raymond Andrews
AOC: No Reviewed Date: 06/06/2023
At the time of inspection, I reviewed the facility's Discharge Monitoring Reports (DMRs) from June 2018 through May 2023. I did not find any issues.
Record: Other - Discharge Monitoring Report Data Sheet
AOC: No
Ref #: RA1-RR-002 Reviewed By: Raymond Andrews
Reviewed Date: 06/06/2023
At the time of the inspection, I reviewed the facility's Discharge Monitoring Report (DMR) working data sheet for May 2023.
Record: Other - Quality Assurance Project Plan (QAPP)
AOC: Yes
Ref #: RA1-RR-001 Reviewed By: Raymond Andrews
Reviewed Date: 06/06/2023
At the time of the inspection, I reviewed the facility's Quality Assurance Project Plan (QAPP), dated September 3, 2020. I identified the following issues with the QAPP:
The QAPP was not prepared using the mandated guidance and requirements documents. The QAPP did not show analytical detection and quantitation limits for each target compound or type and
number of quality assurance field samples. The QAPP did not show the training and qualifications of personnel. The QAPP did not have the name and address of the contract lab.
SECTION IV - Sampling Activities 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-001
Records Review: Other - Quality Assurance Project Plan (QAPP)
Permit Requirement Permit Part 2.1.6.4, "At a minimum, a QAPP must include...Name, address, and telephone number of all laboratories used by or proposed to be used by the permittee."
AOC: The QAPP did not have the name and address of the contract lab.
AOC Reference #: RA1-RR-001
Records Review: Other - Quality Assurance Project Plan (QAPP)
Permit Requirement Permit Part 2.1.6.3, "At a minimum, a QAPP must include...Qualification and training of personnel..."
AOC: The QAPP did not show the training and qualifications of personnel.
AOC Reference #: RA1-RR-001
Records Review: Other - Quality Assurance Project Plan (QAPP)
Permit Requirement Permit Part 2.1.6.1, "At a minimum, a QAPP must include...analytical detection and quantitation limits for each target compound, type and number of quality assurance field samples..."
AOC: The QAPP did not show analytical detection and quantitation limits for each target compound or type and number of quality assurance field samples.
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Petro Star Kodiak - Bulk Petroleum Terminal AK0029441
AOC Reference #: RA1-RR-001
Records Review: Other - Quality Assurance Project Plan (QAPP)
Permit Requirement Permit Part 2.1.5, "Throughout all sample collection and analysis activities, the permittee must use DEC approved QA/QC and chain-of-custody procedures, as described in the Requirements for Quality Assurance Project Plans (EPA/QA/R-5) and Guidance for Quality Assurance Project Plans (EPA/QA/G-5). The QAPP must be prepared in the format specified in these documents."
AOC: The QAPP was not prepared using the guidance and requirements documents referenced in Permit Part 2.1.5. This is evidenced by the other QAPP related AOCs.
SECTION VI - Closing Conference I held a closing conference with Facility personnel at 02:25 PM (PT) on 06/06/2023. During the 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
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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 photo.
All photos taken during the inspection are included in the Photo Log; however, only photos that support an Area of Concern are included in the inspection report.
P1010763 - DMR data sheet (Outfall 1), dated May 2023 P1010764 - PSI Secondary Containment Drainage Log, dated May 10, 2023 P1010765 - pH Meter Calibration Log, dated November 17, 2022 - May 24, 2023 P1010766 - Chain of Custody Document, dated December 15, 2020 P1010767 - Non-compliance Notification, February 9, 2021 P1010768 - 2021 BMP Certification, dated January 31, 2022 P1010769 - Letter - Review of Facility Response Plan, dated October 17, 2022 P1010770 - O/W Separator Inspection Checklist, dated May 3, 2023, page 1 P1010771 - O/W Separator Inspection Checklist, dated May 3, 2023, page 2 P1010772 - Weekly Tank Farm and Inspection Log, dated June 3, 2023