Document 6Bw1zm03JR24xr8Q9j746Jgj6

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 12/10/2024 - 12/11/2024 Water NPDES Stormwater/CWA 402 Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: U.S. Department of The Air Force Tinker Air Force Base 7535 5th Street Oklahoma City, OK 73145 7535 5th Street Oklahoma City, OK 73145 Oklahoma (405)734-1228 Mr. John Truong Water Quality Program Manager john.truong@us.af.mil FRS Number: Identification/Permit Number(s): Media Identifier Number: NAICS: SIC: N/A OKR040006 N/A 928110 9711 Personnel participating in inspection: Sharron A. Crayton 6EN-WS Inspector/Enforcement Officer EPA Lead Inspector Signature/Date Sharron A. Crayton Sharron A. Crayton 01/30/2025 Date Supervisor Signature/Date RUBEN ALAYON-GONZALEZ Date: 2025.01.31 13:08:48 -06'00' Digitally signed by RUBEN ALAYON-GONZALEZ Ruben Alayon-Gonzalez Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 PURPOSE OF THE INSPECTION U.S. EPA Region 6 inspectors Sharron Crayton and Carol Johnson arrived at the Tinker Air Force Base (AFB) facility located in Oklahoma City, OK, on December 10, 2024, at approximately 8:00 AM for an announced Compliance Evaluation Inspection (CEI). This site visit served as a multi-media inspection of the Tinker AFB's Public Water Systems and Stormwater Systems in coordination with the Oklahoma Department of Environmental Quality (ODEQ) and the U.S. EPA Headquarters. The inspectors initially met with the Water Quality Program Manager for the U.S. Department of the Air Force, Tinker AFB, Mr. John Truong. During a joint opening conference, the stormwater inspectors presented their credentials and informed Mr. Truong (and other attendees in-person) that the stormwater portion of this inspection was part of a National Enforcement Initiative focusing on Federal facilities' compliance with the Oklahoma Pollutant Discharge Elimination System (OPDES) Municipal Separate Storm Sewer System (MS4) Phase II Permit [specifically, applicable minimum control measures (MCMs) and measurable goals] and the Clean Water Act (CWA). In addition, Mr. Truong and attendees were informed that the inspection would also focus on the facility's compliance with the OPDES Multi-Sector General Permit (MSGP), and OPDES Construction General Permit (CGP) requirements regarding Best Management Practices (BMPs), including good housekeeping on active construction sites (see Attachments A and B Combined Opening and MediaSpecific Conference Attendee Rosters). In lieu of an MS4 Self-Assessment, prior to the inspection, the Tinker AFB provided the EPA, via an informal email request for information, applicable documents to the inspector (S. Crayton) for review. This inspection also included on-site reviews of the Tinker AFB's small MS4 storm water management plan (SWMP) and relevant files, MSGP and CGP stormwater pollution prevention plans (SWPPPs) and associated recordkeeping requirements, as well as an on-site inspection of the drainage area(s) under the MS4, MSGP, and CGP. Various environmental staff members and/or contractors for the Tinker AFB, accompanied the EPA inspectors during the on-site MS4, MSGP, and construction site inspection(s). In addition, staff with the ODEQ Water Quality Division participated with EPA's inspection efforts. Mr. Mark Thibodeau, Environmental Program Specialist participated with the MS4 inspection efforts, and Mr. Jason Ma, Environmental Investigator participated with the MSGP and CGP evaluation efforts. The inspectors conducted a closing conference with Mr. Truong, Tinker AFB Management, and ODEQ (see Attachments C and D - Combined Closing Conference and Media-Specific Attendee Rosters) to discuss the documents reviewed on-site, additional requests for information, and subsequent efforts of the on-site inspection(s). In addition, during the closing conference, the inspectors discussed pending areas of concern (AOCs) noted during the inspection(s) and items further detailed in this report. Mr. Truong was contacted via email on December 18, 2024, regarding the requests for additional documents (as detailed in Section IV of this report). 2 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 The generation of this report is based on information supplied by Tinker AFB (the permittee), observations made by the inspectors, and review of records and reports maintained by the permittee, the state of Oklahoma, and the U.S. EPA. FACILITY DESCRIPTION The Tinker AFB is a Phase II MS4 United States Air Force installations facility, which is the worldwide manager for a wide range of aircraft, engines, missiles, software and avionics and accessory components that discharges to surface waters of the United States. Tinker AFB is responsible for compliance with permit conditions relating to discharges from portions of the MS4 for which it operates, and applicable SWMP implementation, via OKR040006, effective September 29, 2021, and will expire at midnight, May 31, 2026. The facility is also authorized to discharge stormwater associated with industrial activity under OPDES MSGP OKR051575, issued on September 7, 2023. Discharges associated with stormwater from construction projects are authorized under OKR106450, effective June 23, 2023. Section II - OBSERVATIONS Inspection of the MS4 Program evaluated how Tinker AFB has implemented the six (6) Minimum Control Measures of its SWMP: 1) Public Education and Outreach; 2) Public Involvement/Participation; 3) Illicit Discharge Detection and Elimination (IDDE); 4) Construction Site Stormwater Runoff Control; 5) Post Construction Stormwater Management in New Development and Redevelopment; and 6) Pollution Prevention and Good Housekeeping for Municipal Operations, including other subjects such as data management, inspection schedules, citizen complaints, legal authority, and measurable goals. The EPA inspectors also conducted a review of Tinker AFB's MSGP compliance requirements for the following seven (7) Sectors: K - Hazardous Waste Treatment, Storage or Disposal Facilities; L - Landfills and Land Application Sites and Open Dumps; N - Scrap Recycling and Waste Recycling Facilities; P - Land Transportation and Warehousing; S-Air Transportation; AA - Fabricated Metal Products; and AB Transportation Equipment, Industrial or Commercial Machinery. Additionally, the inspectors conducted a walk-through of the KC-46A 3-Bag Hanger construction project operating under CGP Permit OKR1034347 (see Section III of this report for additional details regarding the condition of the project site). Section III - AREAS OF CONCERN Areas of concern (AOCs) are derived from on-site observations and/or review from the December 10th & December 11th Compliance Evaluation Inspection (CEI) and from subsequent documents provided electronically by the environmental staff via email prior to, during, and/or after the inspection efforts. The following AOCs are specific to the MS4 Program: 1. Globally, the site was not in compliance with the MS4 Program at the time of inspection. More specifically, several program deficiencies were noted, which included, but were not limited to: a. Inaccurate reporting of meeting compliance with various modules in the sites annual MS4 reports; 3 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 b. Deficiencies with not achieving measurable goals of the SWMP and/or not providing the details to substantiate achievement of various goals; c. Deficiencies with training and accountability of trained individuals; d. Lacking systems to accurately track and quantify measurable goals; e. Lacking tracking data and/or tools to document calls to the environmental hotline, nature of calls, and/or date of resolution; f. The facility was unable to accurately identify and provide the total number of associated outfalls covered under the MS4 Program. Specifically, the facility included "high priority outfalls" and other outfalls covered under their wastewater industrial permit and/or non-industrial (all stormwater) outfalls in the final count, which was depicted as approximately 125 total outfalls (29: industrial and 96: non-industrial outfalls); and g. Other items were not being met as per the current SWMP, such as: i. Failure to confirm that the SWMP was reviewed and/or revised, if applicable, on an annual basis as required by the MS4 permit. The associated Record of Review section on Page viii of the February 2022 SWMP provided to the inspectors for review was blank; ii. Section 4.2 of the February 2022 SWMP failed to provide general roles and responsibilities for the Storm Water Pollution Prevention Team, Unit Environmental Coordinator (UEC), and Installation Personnel; and iii. As per Section 6.a.iii.(c) of the February 2022 SWMP, the facility failed to verify and/or maintain documentation confirming stabilization measures were implemented within 14 calendar days of completion of maintenance activities/projects associated with line breaks, emergency repairs, and routine maintenance. The following AOCs are specific to the MSGP Program: The facility was unable to accurately identify and provide the total number of associated outfalls covered under the MSGP Program, as well as confirm that the outfalls were completely representative of the industrial activity without commingling with other discharges. Specifically, during interviews with Mr. Truong, six (6) outfalls (005, 007, 008, 009, 011, and 012) were initially communicated as MSGP outfalls; however, discussion in the SWPPP indicated there were seven (7) stormwater (only) outfalls, but they were not identified numerically. However, during continued discussions and review of various maps, including those contained in the November 2023 SWPPP, the facility was unable to affirmably identify and confirm the total number of MSGP outfalls located at the facility. As referenced in the November 2023 MSGP SWPPP (under the Tinker AFB OKR05 Sampling Summary discussion), the plan referenced that since the facility's wastewater individual permit OK0000809 stormwater discharge sampling program was more stringent than the MSGP Program, analytical monitoring data from this program and the addition of ammonia monitoring would be used in lieu of MSGP parameters for Outfalls 005, 007, 008, 009, 011, and 012. However, Table 3 - Summary of Stormwater Monitoring Requirements and the SWPPP's Significant Spills and Leaks 2019-2022 Map, the map contained seven (7) OPDES outfalls and 19 industrial outfalls. Mr. Truong was challenged with providing clarity with respect to accurate designation of the MSGP outfalls. 4 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 The following AOCs are specific to the CGP Program: 1. Via interviews with Mr. Truong, he informed the inspectors that in 2024, he inspected a total of 24 construction areas with authority to discharge stormwater. However, via additional discussions, it was revealed by the inspectors that: a. The facility lacked a tracking system and/or tools to verify when Notice of Intents (NOIs), SWPPPs, CGP Permit Coverage, and/or Notice for Construction postings were provided and/or completed, prior to disturbance of soil; b. The facility lacked a tracking system and/or tools to document the number of construction outfalls located on site. Application information such as NOIs, construction site notices, inspection records, etc., as per Section 1.5.4 of the JBSA Environmental Specification document are not consistently provided to installation by contractors, prior to construction projects commencing; and 2. Poor housekeeping conditions were observed at the KC-46A 3-Bag Hanger construction project. Specifically, discarded concrete on the ground and comingled with sediment/soil, and other construction debris was noted in the project area (see Appendix 1, Photographs #1 and #2). Section IV - FOLLOW UP No follow-up efforts are needed as of the completion of this inspection report. Via email communication on December 18, 2024, the EPA received 19 documents, per the inspector's request. Information contained in these 19 documents were also reviewed and utilized for completion of this report. Section V - LIST OF APPENDICES AND ATTACHMENTS Appendix 1: Photograph Log - Two (2) photos taken 12/11/2024 Attachment A: 12/10/2024 Combined Opening Meeting Attendee Roster Attachment B: 12/10/2024 Tinker AFB Media-Specific Opening Meeting Attendee Roster Attachment C: 12/11/2024 Combined Closing Meeting Attendee Roster Attachment D: 12/11/2024 Tinker AFB Media-Specific Closing Meeting Attendee Roster 5 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 Appendix 1 Photograph Log 6 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo No. 1 Location: Tinker AFB KC-46A 3-Bag Hanger Construction Project City: Oklahoma City County: Oklahoma State: OK Description: View, of poor housekeeping conditions at the KC-46A 3-Bag Hanger construction project are, with discarded concrete on the ground and comingled with sediment/soil (as noted by red arrows), and other construction debris (such as plastic, boxes, insulation, etc.). Date of Photo: 12/11/2024 Photographer: John Truong for Sharron Crayton 7 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo No. 2 Location: Tinker AFB KC-46A 3-Bag Hanger Construction Project City: Oklahoma City County: Oklahoma State: OK Description: Additional view, of poor housekeeping conditions at the KC-46A 3-Bag Hanger construction project area, with discarded concrete on the ground and comingled with sediment/soil and other construction debris (such as plastic, boxes, insulation, etc.). Date of Photo: 12/11/2024 Photographer: John Truong for Sharron Crayton 8 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 Attachment A 12/10/2024 Combined Opening Meeting Attendee Roster 9 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 10 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 11 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 Attachment B 12/10/2024 Tinker AFB Media-Specific Opening Meeting Attendee Roster 12 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 13 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 Attachment C 12/11/2024 Combined Closing Meeting Attendee Roster 14 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 15 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 Attachment D 12/11/2024 Tinker AFB Media-Specific Closing Meeting Attendee Roster 16 U.S. Department of The Air Force Tinker Air Force Base ODEQ MS4 #: OKR040006 Inspection Date(s): 12/10&11/2024 17