Document 6baOkEkb80zaMyRQmjLK1Yw36

EPA REGION 10 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 07/31/2024 09:30 AM (PT) Announced: Yes 07/31/2024 01:20 PM (PT) Access: Granted 56F, Sunny Water Clean Water Act, NPDES, Stormwater - Industrial Compliance Evaluation Inspection Permittee Name Site Name Site Physical Address City, State, Zip Code Borough Facility GPS Coordinates Mailing Address City, State, Zip Code Benjamin Storey - AKDOT&PF Petersburg James A Johnson Airport 1450 Haugen Drive Petersburg, Alaska 99833 Petersburg 56.810288, -132.943912 P.O. Box 112506 Juneau, Alaska 99811 FRS ID Permit Number SIC 110070519480 AKR06AC89 4581 (Airports, Flying Fields & Services) Lead Inspector: RAYMOND ANDREWS Date: 2024.08.27 07:48:18 -07'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2024.08.27 08:22:38 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA Region 10 contreras.peter@epa.gov (206) 533-6708 Petersburg James A. Johnson Airport NPDES # AKR06AC89 SECTION I - Opening Conference I arrived at the Petersburg James A Johnson Airport (the "Site" or "Facility"), located at 1450 Haugen Drive, Petersburg, Alaska, at 09:30 AM (PT) on 07/31/2024 for an announced inspection. I presented my credentials to Benjamin Storey 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 # AKR06AC89. 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 Regional AKDOT&PF Ben Storey Environmental Yes Yes Manager AKDOT&PF Ivar Enge Equipment Operator Yes Yes Facility Information Responsible official? Erik Norberg; eric.norberg@alaska.gov cc: Ben Storey and Barry Youngberg Type of Operation? Airport Industrial Sector? Sector S (Air Transportation) Is property owned? The State of Alaska owns and operates the airport. Site size? The fence line bounded area is 50.69 acres. Years in operation? The runway was built in 1967. The current primary building was built in 1995. Number of employees? The facility has five employees including the mechanic. Hours/Days of operation? The facility operates from 6am until 4:30pm Monday through Friday during Summer operations. During Winter operations, the facility operates Monday through Friday from 5am until 4pm. Industrial activities exposed to stormwater? During winter, the facility conducts de-icing operations on the runway. The facility conducts all vehicle maintenance inside the building. Personnel conducting inspections/sampling Barry Youngberg conducts all sampling and inspections for the site. The facility is only required to conduct quarterly visual assessments (QVAs). The facility is not required to conduct water sample analysis because the facility does not use 100 tons or more of urea or 100,000 gallons of pure glycol in glycol-based deicing fluids. What is your The facility is only required to do Quarterly Visual Inspections. monitoring frequency? Sampling locations? Samples are collected at seven designated outfalls identified on the SWPPP map. Receiving Water? Stormwater first enters Mill and Hammer sloughs which empty into Wrangell Narrows. Number/location of Outfalls? The site does not have catch basins. The entirety of the stormwater that lands on the site sheet flows to the vegetated area surrounding the paved areas. 2 of 5 Petersburg James A. Johnson Airport NPDES # AKR06AC89 Stormwater Treatment? The facility does not conduct active treatment. All stormwater runoff leaves the paved area and enters a vegetated area where it infiltrates. Industrial activities exposed to stormwater? The only industrial activity exposed to stormwater is de-icing operations. The facility uses a new de-icer called New Deal, which binds to the soil. Type of materials The facility has a large stockpile of sand on site. The pile is uncovered but the pile and/or vehicles stored lays at the end of a downslope path off the road and a vegetated area bounds the outdoors? rear of the pile. SECTION II - Observations No observations were made that constitute an area of concern. SECTION III - Records Review Records may not be in sequential order. Record: Other - SWPPP Map AOC: No Ref #: RA1-RR-007 Reviewed By: Raymond Andrews Reviewed Date: 07/31/2024 At the time of the inspection, I reviewed the facility's SWPPP map. It appeared to have all required components. No areas of concern were identified. Record: Other - Quarterly Visual Assessments (QVAs) AOC: Yes Ref #: RA1-RR-006 Reviewed By: Raymond Andrews Reviewed Date: 07/31/2024 At the time of the inspection, I requested to review QVAs from 1Q 2020 through 2Q 2024. The QVAs were not signed in accordance with Appendix A, part 1.12. The QVAs were not documented as required by the permit, i.e., there was no photo documentation. Record: Other - Routine Facility Inspections AOC: Yes Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Reviewed Date: 07/31/2024 At the time of the inspection, I reviewed the facility's routine facility inspections from January 2020 through June 2024. The facility's routine inspection reports were not sign in accordance with Appendix A, part 1.12 of the permit. Record: Annual Reports AOC: Yes Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 07/31/2024 At the time of the inspection, I reviewed the facility's available Annual Reports. The only Annual Reports in the SWPPP binder were for the 2022 and 2023 reporting years so those were the only reports I reviewed. The Annual Report for the 2023 reporting year was signed March 30, 2023. This only accounts for a quarter of the reporting year. Record: Other - Employee Training Records AOC: Yes Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 07/31/2024 At the time of the inspection, I reviewed the facility's employee training records. The SWPPP binder contained certificates showing employee training was completed but there were no dates of when the training was completed. 3 of 5 Petersburg James A. Johnson Airport NPDES # AKR06AC89 Record: SWPPP Ref #: RA1-RR-002 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 07/31/2024 At the time of the inspection, I reviewed the facility's Stormwater Pollution Prevention Plan (SWPPP), with a preparation date of October 9, 2020. The SWPPP needs to be updated. One member listed as a member of the SWPPP Team has retired. Record: Other - EPA's Integrated Compliance Information System (ICIS) Database AOC: Yes Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 07/30/2024 Prior to the inspection, I reviewed a report from EPA's ICIS database covering the period from June 2019 through 2024. The report indicated the facility failed to submit Annual Reports for the years 2020 through 2023. 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 - EPA's Integrated Compliance Information System (ICIS) Database Permit Requirement Part 9.2 of the permit states, in part, "A permittee must submit an annual report to DEC...By February 15th of the year following the reporting year..." AOC: The facility failed to submit Annual Reports for the years 2020 through 2023. AOC Reference #: RA1-RR-002 Records Review: SWPPP Permit Requirement Part 5.6.5 of the SWPPP states, in part, "The SWPPP must be updated at least annually." AOC: The SWPPP is not being updated annually. AOC Reference #: RA1-RR-003 Records Review: Other - Employee Training Records Permit Requirement Part 5.8.5 of the Permit states, "Records of employee training, including date training received." AOC: Employee training documentation does not include the date the training was received. AOC Reference #: RA1-RR-004 Records Review: Annual Reports Permit Requirement Part 9.2 of the permit states, in part, "A permittee must submit an annual report to DEC...By February 15th of the year following the reporting year, the permittee must submit the annual report to DEC..." AOC: The facility's 2023 Annual Report only covered the first three month of the reporting year. 4 of 5 Petersburg James A. Johnson Airport NPDES # AKR06AC89 AOC Reference #: RA1-RR-005 Records Review: Other - Routine Facility Inspections Permit Requirement Appendix A, Part 1.12.5 of the permit states, "Any person signing a document under Appendix A, Part 1.12.2 or Part 1.12.3 shall certify as follows: "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." " AOC: The facility's routine inspection reports were not signed in accordance with Appendix A, part 1.12 of the permit. AOC Reference #: RA1-RR-006 Records Review: Other - Quarterly Visual Assessments (QVAs) Permit Requirement Appendix A, Part 1.12.5 of the permit states, "Any person signing a document under Appendix A, Part 1.12.2 or Part 1.12.3 shall certify as follows: "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." " AOC: The QVAs were not signed in accordance with Appendix A, part 1.12. AOC Reference #: RA1-RR-006 Records Review: Other - Quarterly Visual Assessments (QVAs) Permit Requirement Part 6.2.2 of the permit states, in part, "A permittee must document the results of their visual assessments and maintain this documentation onsite with the SWPPP...documentation of the visual assessment must include...Photographs of sample and sample location..." AOC: The QVAs were not documented as required by the permit, i.e., there was no photo documentation. SECTION VI - Closing Conference I held a closing conference with Facility personnel at 01:20 PM (PT) on 07/31/2024 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. P1020019 - Sand Pile, photo 1 P1020020 - Sand Pile, photo 2 P1020021 - Outfall to Miller Slough P1020022 - Culvert, transfers water runoff from one side of the road to the other side for discharge into one of the sloughs