Document Edy6an9pwvwmG3KMYg451njB4

Multi-Media Inspection Report Camp Santiago Joint Maneuver Training Center Salinas, PR May 2023 Submitted to: U.S. ENVIRONMENTAL PROTECTION AGENCY WJC Building, 1200 Pennsylvania Ave., NW Washington DC, 20004 Submitted by: Abt Associates, Inc. under CONSULTING AGREEMENT # 53965 Task Order# 68HERC22Q011 Prepared by: Charles Zafonte, contract inspector, 6554 Scenic View Drive, Macungie, PA 18062 and by Erin Floto, Jillian Harvey-Shepard and Carlos Colombani, inspectors, USEPA Region 2 X EPA Contractor X ERIN FLOTO c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=ERIN FLOTO, 0.9.2342.19200300.100.1.1=68001003648097 2023.08.28 15:08:34 -04'00' 2023.003.20269 Enforcement Officer ECAD-CAPSB-CAS USEPA R2 X Digitally signed by CARLOS COLOMBANI DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=CARLOS COLOMBANI, 0.9.2342.19200300.100.1.1=68001003667785 Date: 2023.08.28 15:31:19 -04'00' Adobe Acrobat version: 2023.003.20284 Enforcement Officer ECAD-CAPSB-CAS USEPA R2 X Digitally signed by JILLIAN HARVEY-SHEPARD DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, 0.9.2342.19200300.100.1.1=68001004499143, cn=JILLIAN HARVEY-SHEPARD Date: 2023.09.05 08:30:59 -04'00' Adobe Acrobat Reader version: 2023.003.20244 Enforcement Officer ECAD-CAPSB-CAS USEPA R2 KATHLEEN MALONE- X BOGUSKY Digitally signed by KATHLEEN MALONE-BOGUSKY Date: 2023.09.05 10:00:53 -04'00' Chief, Compliance Assurance Section ECAD-CAPSB-CAS Camp Santiago Multi-Media Inspection Report 2 This page has intentionally been left blank Camp Santiago Multi-Media Inspection Report 3 MULTI-MEDIA INSPECTION REPORT U.S. Environmental Protection Agency, Region 2 Enforcement and Compliance Assurance Division 290 Broadway, 21st floor, New York, New York 10007-1866 Locational Information Facility Name: Camp Santiago Joint Maneuver Training Center Facility Address: State Rd #1, Intersection Rd #154, Salinas, PR 00751 Latitude & Longitude: 18.001111, -66.291677 ICIS & other Program ID Codes as appropriate FRS: 110067612630 CAA: 02000110006868979 and PR0000007212300028 CWA: PRU201970 and PRR053286 PWS: PR563095 RCRA: PR5211810002; PRD982275406 UST: PR-02-04-0005 (AAFES) Sector Information Federal Facility: SIC: NAICS: Yes 9711 (National Security) 928110 (National Security) Environmental Sensitivity Information Potential Flood-Prone Area: No (See Appendix C: FEMA Flood Map) Potential EJ Concerns: Yes (See Appendix D: EJ SCREEN) Inspection Information Dates of Inspection: May 22-23, 2023 Inspectors: Carlos Colombani, EPA-R2-CEPD Erin Floto, EPA-R2-ECAD-CAPSB Jillian Harvey-Shepard, EPA-R2-ECAD-CAPSB Charles Zafonte, subcontractor to Abt Associates Facility Representatives See attached sign-in sheet, Appendix A Updates to EPA Databases Camp Santiago appears to be SQG. Camp Santiago Multi-Media Inspection Report 4 Table of Contents 1. INTRODUCTION..................................................................................................................... 6 2. APPLICABILITY OF ENVIRONMENTAL LAWS ............................................................ 7 Clean Air Act (CAA) .............................................................................................................. 7 Clean Water Act (CWA)......................................................................................................... 7 Emergency Planning and Community Right-to-Know Act (EPCRA) ................................... 7 Resource Conservation and Recovery Act (RCRA) ............................................................... 7 Safe Drinking Water Act (SDWA) ......................................................................................... 7 3. FACILITY TOUR AND DOCUMENT REVIEW ................................................................ 7 Scope of Compliance Evaluation............................................................................................ 7 CAA ........................................................................................................................................ 7 SDWA PWSS ......................................................................................................................... 8 RCRA Hazardous Waste....................................................................................................... 11 RCRA UST ........................................................................................................................... 14 4. PRELIMINARY FINDINGS ................................................................................................. 15 RCRA Hazardous Waste....................................................................................................... 15 SDWA PWSS ....................................................................................................................... 16 5. ENVIRONMENTAL ASSISTANCE .................................................................................... 18 6. REQUESTED INFORMATION ........................................................................................... 19 APPENDICES:............................................................................................................................ 19 A: FACILITY SIGN IN LOG........................................................................................ 19 B: INSPECTION PHOTOGRAPHS............................................................................. 19 C: FEMA FLOOD MAP ................................................................................................ 19 D: EJ SCREEN ............................................................................................................... 19 E: UST INSPECTION CHECKLIST ........................................................................... 19 Camp Santiago Multi-Media Inspection Report 5 1. INTRODUCTION The Region 2 office of the U.S. Environmental Protection Agency (EPA) requested a compliance evaluation inspection under the Federal Facilities Inspection Initiative across federal environmental statutes and regulations of Camp Santiago Joint Maneuver Training Center (CSJMTC), located in Salinas, PR. The Region 2 office determined that: (1) EPA Inspector Carlos Colombani, would conduct a Resource Conservation and Recovery Act - Subtitle C (hazardous waste management) evaluation of the facility; (2) EPA Inspector Erin Floto would conduct a Clean Air Act evaluation of the facility; and (3) contractor Abt Associates, Inc. and its subcontractor, Charles Zafonte, under EPA's Federal Facilities Enforcement Office contract, would provide assistance to EPA in preparing for and conducting the evaluation, as well as preparing the report, for the following federal environmental programs, as applicable to the facility: Safe Drinking Water Act (SDWA) Public Water System Supervision (PWSS), Resource Conservation and Recovery Act - Subtitle I (underground storage tanks), Clean Water Act (CWA) National Pollutant Discharge Elimination System (NPDES), and CWA Spill Prevention, Control & Countermeasure (SPCC). Since EPA allotted five days for the inspection of six federal facilities, the Region 2 office also directed that if time is limited, the facilities should be evaluated for compliance with the four programs in the priority order listed above. Ms. HarveyShepard and Messrs. Colombani and Zafonte conducted the joint evaluation of the facility on-site on May 22-23, 2023, while Ms. Floto conducted her evaluation off-site. This report presents their observations and findings. In preparation for the on-site multi-media inspection (MMI) as well as to conduct the Clean Air Act (CAA) offsite compliance monitoring (OfCM) activity, Erin Floto, in her role as the Federal Facility Program Manager (FFPM), contacted facility representative Lieutenant Colonel Brenda Acosta on February 16, 2023, requesting documents. A OneDrive folder was provided to the facility to drop files related to the various statutes. Documents were provided over time into the OneDrive file. Notification for the MMI was provided via phone and confirmed by email one week prior to the date of the MMI. CSJMTC is primarily a field training center for the Puerto Rico Army National Guard (PRANG). The facility sits on approximately 12,000 acres in an arid area of southern Puerto Rico. Camp Santiago consists of barracks, firing ranges, facility maintenance areas, vehicle fueling and maintenance areas and office buildings. While troops reside overnight during training exercises, Camp Santiago has no permanent housing. A major tenant of Camp Santiago is the Maneuver Area Training Equipment Site (MATES), which maintains and fuels military vehicles. MATES has its own EPA Facility Registry System (FRS) and Resource Conservation and Recovery Act (RCRA) generator ID numbers, but compliance with most of the environmental laws and regulations is managed by Camp Santiago. The official point of contact for Camp Santiago is Colonel Carlos Caez-Sierra, and the primary environmental contact is Mr. Jose Velasquez, Director, Department of Public Works. He and Marisol Diaz, Ileana Mejia, Legna Siberon, and Maria Santiago escorted us and provided information on the facility. Arriving at approximately 2:15 pm on May 22, 2023, Mr. Velasquez greeted us in Building 55, where we presented EPA and contractor credentials and business cards and offered in- and out-briefings and the option of claiming confidential information (none claimed). The Camp Santiago Multi-Media Inspection Report 6 attached meeting sign-in sheet, (See Appendix A), identifies the meeting participants, including facility representatives who phoned in from Fort Buchanan, which, located in San Juan, provides a significant support and management function for Camp Santiago. 2. APPLICABILITY OF ENVIRONMENTAL LAWS Clean Air Act (CAA) The facility's twenty-four generators as well as their air conditioners/chillers are subject to the CAA. Clean Water Act (CWA) The facility discharges all wastewater to the Puerto Rico Aqueduct and Sewer Authority (PRASA)'s local Publicly Owned Treatment Works (POTW); however, the facility does not meet EPA and PRASA criteria requiring a wastewater discharge permit. The facility did submit a Notice of Intent (NOI) to be covered under the EPA Municipal Separate Storm Sewer Systems (MS4) Permit. Also, due to its 119,000-gallon above-ground fuel storage capacity, the facility is subject to the spill prevention, control and countermeasure (SPCC) requirements under the CWA; the facility updated its SPCC Plan this year. Emergency Planning and Community Right-to-Know Act (EPCRA) The facility files Tier 2 reports for chlorine and for diesel fuel. Resource Conservation and Recovery Act (RCRA) The facility's programmatic IDs are listed as Very Small Quantity Generators (VSQG) of hazardous waste under Subtitle C of RCRA (RCRA-C). The facility also operates regulated underground storage tanks (USTs) under Subtitle I of RCRA (RCRA-I). Safe Drinking Water Act (SDWA) The facility supplies its own potable water from two on-site wells and is subject to the Public Water System Supervision (PWSS) program as a non-transient, non-community water system. 3. FACILITY TOUR AND DOCUMENT REVIEW Scope of Compliance Evaluation This compliance evaluation included the following applicable programs: CAA, SDWA PWSS, RCRA-C and RCRA-I. CWA NPDES and CWA SPCC evaluations were not conducted due to time restraints. No multi-media screening checklist was completed. Ms. Floto conducted the CAA OfCM activity; Mr. Colombani conducted the RCRA-C inspection; and Ms. HarveyShepard and Mr. Zafonte conducted the SDWA PWSS and RCRA-I inspections. We reflected our observations in the respective sections of the report, below. CAA All observations related to the CAA were completed during an off-site review of the documents. EPA requested the facility's CAA permit as well as the facility's emergency generator records. The facility has 24 emergency generators. The facility's permit allows for emergency generators Camp Santiago Multi-Media Inspection Report 7 to be in use for a maximum of 515 hours per calendar year. The facility did not provide the requested logs for individual generators but did provide the specifications for each emergency generator, their current hour meter reading, and the annual hours each generator was in use from 2019-2022. Please see Section 6, "Requested Information." In addition to the generators, the facility provides in-house maintenance for their air conditioning units that contain refrigerants. The facility provided the certification for the on-site technician and there were no concerns with the documentation provided. The facility does not have any units that have a refrigerant charge capacity over 50 lbs. SDWA PWSS The following information was gathered from documents provided by PRANG in advance of the inspection and from discussions during the the inspection. CSJMTC is located on 12,000 acres of mountainous terrain in Salinas Puerto Rico. The facility has no permanent residences; troops are only housed temporarily during training periods. The CSJMTC Public Water System is composed of two deep water wells; chlorine and phosphate injection; a 350,000-gallon concrete water storage tank and distribution pipelines. Source water wells No. 1 and No. 2 are pumped alternately, and controlled manually or by a timer. The water storage tank is located uphill of and at the opposite end of the facility's distribution system from the water wells. The tank can be filled only through the water mains of the distribution system and thus can only be filled after all the distribution lines are filled with water and the pressure in the distribution lines rises to a maximum level and is maintained at that pressure. Consequently, the water mains, which are approximately fifty years old, are subjected to frequent, ongoing stress. As indicated above, the facility has no permanent residents, but troops are housed on-site during training periods. As a result, water demand is extremely cyclical, depending on whether troops are present for training. This results in lengthy periods of time when no water is used, especially at night, and water use during the day is limited primarily to offices. This leads to frequent periods of water stagnation in its storage tank and in its distribution system. The facility lacks a Supervisory Control and Data Acquisition (SCADA) system; adequate calibrated flow meters; and temperature, turbidity, and chlorine sensors. A detailed 2016 infrastructure assessment for the facility concluded that approximately 75% of the water produced by the system is being lost due to excessive water pressures and aging water mains. Exacerbating the condition of the facility's water mains is scaling caused by the hardness of the aquifer's groundwater. The system has never softened its potable water. The water-bearing formation being used by the facility's water wells is subject to increasing water withdrawals and saltwater intrusion, which can be expected to make the extracted water even harder in the future. In addition, Camp Santiago plans to expand its capacity for troop training, from current levels (which reach 1,000) to 1,400 in the short term, and ultimately to 2,230. If increasing groundwater hardness, decreasing groundwater supply, or any other characteristic makes groundwater use insufficient in the future, the facility intends to draw its water from PRASA. Camp Santiago Multi-Media Inspection Report 8 The facility has initiated a multi-phase project to improve its public water supply system based on the findings and recommendations of the 2016 infrastructure assessment mentioned above. Although we have requested, but have not yet received, a written description of the project, discussions during the on-site inspection indicate the following general aspects to the project: Phase 1 - a new water well monitoring system. Phase 2 - an upgraded water treatment plant for water chlorination, softening and phosphate addition. Phase 3 - design of a new distribution system. Phase 4 - new mains for the distribution system. Facility representatives did not feel free to discuss the details of the project because of a civil and perhaps criminal case being pursued against the contractor hired for the initial phase(s) of the project. A second contractor, however, has completed approximately 65% of the design of a new distribution system for Phase 3. On Day 2 of the inspection, May 23, 2023, Ms. Harvey-Shepard and Mr. Zafonte met with the facility's water treatment plant operators, Mr. Felix Sanchez and Ms. Wilmarie Cardona. Water treatment operator certificates were provided for Mr. Sanchez (Operator IV, expiring on June 18, 2023; Photo 1) and Ms. Cardona (Operator III, expiring on February 13, 2025; Photo 2). They escorted us to the potable water wells and then we followed the water flow to the water treatment facilities, the water storage tank, and a distribution point. During the tour, we made the following observations: Well No. 1 is located within a chain-link fenced area, topped with barbed wire and secured with a lock (Photo 3). The wellhead is housed in Building No. 002 on a concrete pad, which was dry and satisfactorily clean at the time of visit. From the wellhead, water flows through three flow valves, two check valves and a pressure relief valve (Photo 4), which, we were advised, were last confirmed to be operational in 2019. PRANG has no documentation of the valves ever being tested. We were advised that the well pump and water-bearing formation are located approximately 90 feet below the ground surface. We observed that the piping from the well was equipped with a flow meter, but it was not operational. We were advised that the flow meter has been inoperable for years (Photo 5). The last flow data are from 2014; instead, flow is inferred from pump flow velocity and the duration of operation. The meter has not been repaired or replaced because PRANG has been advised to not make changes because changes could jeopardize the enforcement case against the original contractor. We would also learn that this is also the reason for the additional concerns enumerated below not being addressed. The pressure relief valve on Well No. 1 discharges to an open pipe outside the building. The pipe opening was not screened (Photo 6). By text the following week, Mr. Velasquez provided photographs of #24-mesh screening on this pipe and on the other open pipes we observed to be unscreened (see below) in the buildings at Wells No. 1 and 2 and the chlorine injection building. We then inspected Well No. 2, which is located within another chain-link fenced area, topped with barbed wire, and secured with a lock (Photo 7). The No. 2 wellhead is in Building No. 003 (Photos 8 & 9). The enclosure also contained a shed, two water treatment buildings, and a gas storage building, as described below. Each building Camp Santiago Multi-Media Inspection Report 9 contained one room only. We observed a similar piping configuration and conditions for Well No. 2 as for Well No. 1. In addition to the meter not working (Photo 10), Camp Santiago representatives stated that the pressure relief valve for Well No. 2 could not be calibrated. Within the Well No. 2 enclosure was a rectangular shed with one of its long sides open to view. Within the shed, we observed at least several dozen bags of an ion exchange resin designed for water softening. Some of the bags were open and resin was scattered about the shed, unprotected from the elements (Photos 11 & 12). Upon inquiry, facility representatives expressed no knowledge of the material, or why it was there and could provide no Safety Data Sheet for it. Next to the shed was a building that was dominated by two softener treatment tanks, one of which had the top separated from its sides (Photos 13-15). Camp Santiago representatives advised that this resulted from an explosion of the water softening system installed by the initial on-site contractor. We were advised that the Camp Santiago water has never been softened. The only operable equipment in the building was a small phosphate feed pump, which is operated the only way the current equipment allows, manually, based on the water level in the facility's only potable water storage tank (Photo 16). The operating pressure was approximately 135 psi, which is required to overcome the high pressures in the distribution lines made necessary by the lack of a dedicated water main from the wells to the storage tank. An approximately 55-gallon drum of phosphate solution was not in secondary containment (Photo 17). Next to this building is the chlorine injection building. Between the two buildings was a potable water supply tap with threads for a connection and no cross-connection protection. Camp Santiago representatives stated that they had no idea why the tap is there, or that it presents a potential cross-connection. The door of the chlorine building was not equipped with panic hardware; instead, we were advised, the door is kept open whenever the building is visited (Photo 18). The door included a window, allowing a view of room conditions before entering it. Immediately outside the building door was an eyewash station and an overhead shower. Upon testing them, we found that the shower worked, but the eyewash did not (Photo 18). A 150-lb chlorine tank was loosely chained to the rear wall, was not situated on a scale, and was piping chlorine gas into the water line at approximately 300 psi (Photo 19). The room was dry and housekeeping satisfactory, a fan was exhausting room air, and a chlorine sensor was appropriately located about a foot off the floor. We were advised that the sensor has never been calibrated. We observed two unscreened openings at the floor level to the outside of the building; each with wires in their primary plastic insulation, but not contained in electrical conduits (Photos 20 & 21). The windows on either side of the building were equipped with louvers, which appear to provide limited air flow (Photo 22). Upon inquiry, we learned that the personal protective equipment for the chlorine building is located approximately 200 yards away; we suggested a closer location for it since it would be needed in an emergency. Next to the chlorine injection building is the chlorine storage building (Photo 23), which contained a 45 kg container of granular calcium hypochlorite, two empty and two full 150-lb cylinders of chlorine chained to a wall (Photos 24 & 25), and the same style window louvers with apparently limited air flow. The room contained four bags marked as resin (Photos 26 & 27). Camp Santiago representatives stated that they had no idea Camp Santiago Multi-Media Inspection Report 10 what it is, or why a contractor left them there. The facility had no Safety Data Sheet for the material. The two water treatment operators stated that the procedure they follow when changing chlorine cylinders is as follows: o Ensure, when the alarm sounds, or when the weight indicates the gas level is low, that they have backup personnel, which can be one of the facility's security officers on weekends if only one operator is on-site [Note: The chlorine cylinder scale is not working]. o Get a mask with a chlorine cartridge and ensure that the exhaust fan is on. o Close the cylinder valve, unscrew the gas connection, and unchain the cylinder from the wall. o Remove the cylinder and hand-truck it to the gas storage building. o Reverse the above steps for the new cylinder. o Check joints for leaks with ammonia, and if a white precipitate forms, tighten the connection until no precipitate forms when more ammonia is applied to the joint. We inspected the facility's wastewater lift station (Building 00341), where Mr. Luis Rivera identified himself as the only operator. A hose, which is used to clean the wastewater inlet rack, was screwed onto a potable water tap (Photo 28). It was not equipped with a vacuum breaker. The influent racks are cleaned weekly, with trash disposed appropriately depending on the results of toxicity testing (Photo 29). We observed that the lift station was supported by an emergency generator (Photo 30) fueled by a 550-gallon aboveground tank storing diesel fuel (Photo 31). Although the tank was in secondary containment, the containment structure also included a vertical open pipe a few inches long set into the concrete (Photo 32). Camp Santiago representatives stated that they had no idea why it was there, or where it led. By text on May 27, 2023, PRANG provided photos showing that the pipe was eliminated, and the floor sealed with concrete. Just inside the building was a fire extinguisher that was significantly undercharged and with no inspection tag attached (Photos 33 & 34). At the PX building, the fire sprinkler suppression system included a water tap with threads and a hose attached (Photos 35 & 36). At Building 1011 as well as another building, we observed faucets outdoors with no cross-connection protection and with a connected hose lying on the ground (Photos 37 & 38). The hatchway for the facility's 350,000-gallon concrete water storage tank (Building 845) had no sanitary seal and was flaking material (Photos 40 & 41). The surface of the tank roof appears degraded in several places (Photos 42-44). RCRA Hazardous Waste The CSJMTC facility has two entities with RCRA programmatic identification numbers: MATES (PRD982275406) and the rest of the facility (PR5211810002, CSJMTC). MATES is entirely within the borders of Camp Santiago. As stated in Section 2.1 above, both entities are classified in EPA's RCRAInfo database and the public Enforcement and Compliance History Online (ECHO) website as very small quantity generators (VSQGs) of hazardous waste. The two entities were evaluated to determine if either exceeded the thresholds of a VSQG, and if they were following the applicable hazardous waste management requirements. Camp Santiago Multi-Media Inspection Report 11 CSJMTC and MATES generate various universal and hazardous wastes. These include spent fluorescent lamps, batteries, used coolant, used oil, contaminated fuel/diesel, aerosol cans, and paint wastes. The hazardous waste is sent off the island to the continental United States. The Defense Logistics Agency (DLA) is the one in charge of the pickups and shipments. Based on conversations with Ms. Santiago, both entities are managed as VSQGs. As VSQGs, these entities would be exempt from most hazardous waste regulations provided they: continue to identify all their hazardous waste; generate less than 100-kg of nonacute hazardous waste and 1 kg of acute hazardous waste per month; never accumulate more than 1,000-kg of nonacute hazardous waste, 100-kg of acute spill cleanup residue, and 1-kg of other acute hazardous waste on-site at any time; and continue to ensure that the hazardous waste they generate is sent to an offsite treatment, storage, recycling, or disposal facility capable and permitted to handle such waste. Based on information gathered from RCRAInfo, there were three overall shipments in 2019, one shipment in 2020, two shipments in 2021, one shipment in 2022, and one shipment so far in 2023. The following table breaks down the shipments made each calendar year by manifest tracking numbers for both MATES and CSJMTC: MATES Manifest Tracking Number 019765061JJK 019765379JJK 020920707JJK 021854002JJK 023163514JJK 023163890JJK Shipping Date January 28, 2019 June 25, 2019 December 10, 2019 September 22, 2020 June 28, 2021 November 9, 2021 Amount of Waste (kg) 454 1089 136 1950 1588 454 Camp Santiago Manifest Tracking Number 024047895JJK 024382113JJK Shipping Date August 2, 2022 March 21, 2023 Amount of Waste (kg) 27 30 The following table summarizes the hazardous waste shipments completed by the Facility broken down by IDs for both MATES and CSJMTC by calendar year: PRD982275406 - MATES Manifest Year Acute? 2018 Non-Acute 2019 Non-Acute Amount of Waste (kg) 454 1678 Monthly Average (kg) 38 140 Camp Santiago Multi-Media Inspection Report 12 2020 Non-Acute 1950 163 2021 Non-Acute 2041 170 PR5211810002 - Camp Santiago Manifest Year Acute? Amount of Waste (kg) 2022 Non-Acute 27 2023 Non-Acute 30 Based on individual hazardous waste shipments, it appears that on June 25, 2019; September 22, 2020; and June 28, 2021, MATES stored more than the VSQG accumulation limit of 1,000 kg of hazardous waste on site at one time. Moreover, such storage above the VSQG limit would have been occuring for some time in 2020 and 2021 assuming the less than 100 kg a month VSQG generation rate for non-acute hazardous waste unless MATES generated more than the VSQG monthly rate in those years. In fact, based on the amount of hazardous waste shipped by calendar year, it appears that MATES did generate on average at the small quantity generator (SQG) rate of more than 100 kg per month but less than 1,000 kg per month in 2019, 2020 and 2021. Thus, although MATES does not track waste generation rates on a monthly basis to be able to accurately quantify their monthly hazardous waste generation and correctly determine their waste generator classification, based on the above, from 2019-2021, MATES should have been following at least the SQG requirements. Since there were no manifests in EPA's system pertaining to MATES after 2021, Ms. Santiago provided two manifests via email. Manifest 024047894JJF dated August 24, 2022, and manifest 024382126JJK dated March 23, 2023. These were non-hazardous waste and universal waste shipments. CSJMTC stores its hazardous waste at the Logistics Area and MATES stores it within their secured boundary in the accumulation bay. At the Logistics Area, Ms. Madelyn Matias (Supply Staff Sergeant) and Ms. Santiago participated in the walkthrough of the area. Typically, the hazardous waste stored are absorbent materials and aerosol cans. In addition, used oil and universal waste is stored for recycling purposes. The waste is stored in Building 25. At the time of the inspection, the following waste was being stored: a box of spent fluorescent lamps dated February 2023; and a 55-gallon drum of aerosol cans from 2022 that is still in use. The building is equipped with spill kits, an eye washing station, and a fire extinguisher in case of a spill and/or emergency. Also, emergency contact information and protocols to follow are posted at the entrance. Note, the box of spent fluorescent lamps and the 55-gallon drum were in good condition and closed. Pertaining MATES, the site has three (3) areas where waste is generated: Tin 1, Tin 2, and Tin 3 (all vehicle maintenance shops). Typically, the waste generated by MATES is used oil/used oil filters, used rags and absorbent pads. Each Tin has two (2) satellite point areas where Satellite Camp Santiago Multi-Media Inspection Report 13 Point 1 has a container per waste stream of absorbent pads and used oil, and Satellite Point 2 has a container per waste stream of used oily rags, absorbent pads, used oil and filters. Once full, these are moved into the Waste Area. At the Waste Area, three 55-gallon drums of used oil filters and used oil were being stored. These drums when shipped by DLA will go for recycling. Only key personnel have access to the Waste Area. The area is equipped with spill kits, an eye washing station, a fire suppression system and fire extinguishers in case of a spill and/or emergency. Also, emergency contact information and protocols to follow are posted at the entrance. RCRA UST A full compliance evaluation was done for two USTs at the Army and Air Force Exchange Service (AAFES) for which a Region 2 UST Checklist was completed (see Appendix E). A summary of the full compliance evaluation at the AAFES is also provided below. Time constraints permitted only partial compliance inspection of the USTs at POL (Petroleum, Oil & Lubricants) and no inspection of the UST at MATES. AAFES Two 12,000-gallon USTs are presently in use by the facility to store gasoline for fueling vehicles, which were both installed in 2004. The UST systems consist of double walled fiberglass reinforced plastic (FRP) tanks with pressurized FRP piping. They both have doubled walled spill buckets, overfill alarms, and doubled-walled piping containment sumps. Interstitial monitoring is used for release detection for both the tanks and piping for both UST systems. The last triennial test of the overfill alarm was conducted on June 28, 2022. Triennial containment integrity tests of the spill buckets and piping containment sumps are not required since they are doubled-walled and the monthly walkthrough inspections by AAFES check for leaks in the interstitial areas. AAFES had one-year of records of their monthly walkthrough inspections. AAFES has 8 dispensers, which all have under dispenser containment that was installed in 2004 and replaced in 2019. The under-dispenser containment undergoes daily visual inspections and were last checked for integrity on June 28, 2022. AAFES had 12 months of release detection records for both their piping and tanks and the release detection equipment was last tested for operability on June 28, 2022. The pressurized piping is equipment with an automatic line leak detector (ALLD), which were last tested for operability on May 1, 2023. AAFES has designated two Class A/B UST operators: Mr. Juan Martinez and Ms. Mildred Guzman. Training documentation for Mr. Martinez and Ms. Guzman were shown to EPA during the inspection along with proof that all designated Class C operators have been trained. However, AAFES did not have a list of designated operators, which, at a minimum, (1) identified all current Class A, B and C operators for the facility, and (2) include the names, Class of operator trained, date assumed duties, date each completed initial training, and any retraining. POL Camp Santiago Multi-Media Inspection Report 14 The Camp Santiago area designated as POL contained two USTs. Petroleum Supply Specialists Nelson Leon and Jose Ortiz operate the tanks and provided access to them. On June 21, 2021, the Puerto Rico Department of Natural Resources and the Environment issued PRANG Permit # UST 2-86-1929 for operation of the two tanks until June 21, 2024. The permit states that the two tanks: Have a capacity of 25,000 gallons each; Store diesel fuel; Were installed in 1980; and Are composed of double-wall steel, shielded from corrosion by cathodic protection. The permit states that the piping connected to the two tanks is single-wall fiberglass-reinforced plastic and that pumping is safe suction. Opening the tank-top sumps revealed clean and dry tank-top sumps with little corrosion and confirmed pumping is achieved through suction from the dispensers. A Veeder Root TLS-350 automatic tank gauge (ATG) provided tank leak detection, and an ES-2 rectifier provided cathodic protection of the tank. Opening the fill ports revealed clean and dry spill buckets, but no overfill protection through a flapper valve. A ball float valve, instead, was installed on each vent line. Note: ball float valves are not recommended for use with suction piping. We observed an overfill alarm on the outside of the operator's building. This overfill alarm was connected to the tank monitor for these UST systems, and the alarm sounded when the test button was pushed. The tank monitor showed "All Functions Normal." The ATG is the primary method of tank release detection (records provided for the last twelve months), while line tightness testing provides piping release detection (copy viewed on-site). POL also uses ground vapor monitoring and annual tank tightness testing, the records of which confirmed no leakage. Monthly checklists documented inspections of the UST systems and the cathodic protection system. The impressed current system was observed to be operating at the time of the inspection. A contractor conducting inspections of the system every two months confirmed sufficient protection. The loading/unloading areas for these USTs have concrete secondary containment, well beyond any requirements, with valves normally closed and only opened when rain accumulates in the dikes after checking for an oil sheen. 4. PRELIMINARY FINDINGS Based on observations made during the inspection and/or a review of records related to the inspection, the following preliminary findings have been noted. RCRA Hazardous Waste REGULATORY, STAUTORY, OR PERMIT REFERENCE 40 CFR Part 262.14(a)(3) and FIELD OBSERVATIONS On June 25, 2019; September 22, 2020; and June 28, 2021, MATES Camp Santiago Multi-Media Inspection Report 15 (4): A VSQG may not store more than 1,000 kg (2,200 lbs) of hazardous waste or 1 kg (2.2 lbs) of acute hazardous waste on site at any time stored more than the VSQG on-site accumulation quantity threshold of 1,000 kg of non-acute hazardous waste on-site at one time. SDWA PWSS Significant deficiencies and areas of concern were identified in various areas of the PWS and are noted in the following tables. Significant deficiencies include, but are not limited to defects in the design, operation or maintenance, or a failure or malfunction of the sources, treatment, storage, or distribution system, that have been determined to be causing or have the potential for causing the introduction of contamination into the water delivered to consumers. As per 40 CFR 141.723(c), a response in writing, indicating the procedure and schedule for correcting each significant deficiency is required within 45 days of receipt of this report. AREA OF INSPECTION Source Treatment SIGNIFICANT DEFICIENCIES FIELD OBSERVATIONS The pressure relief valve on Well No. 1 discharges to an open pipe outside the building. The pipe opening was not screened (Photo 6). Corrective Action: Mr. Velasquez provided photographs via text message the following week of #24-mesh screening on this pipe, and on the other open pipes we observed to be unscreened in the buildings at Wells No. 1 and 2, and the chlorine injection building. Three flow valves, two check valves and a pressure relief valve receiving flow from the Well No. 1 wellhead were inoperable. CSJMTC/PRANG representatives stated that valve operation was last confirmed in 2019 and valve testing is not recorded. We observed a similar piping configuration and conditions for Well No. 2 as for Well No. 1. In addition to the meter not working (Photo 10), Camp Santiago representatives stated that the pressure relief valve for Well No. 2 could not be calibrated. In a shed within the Well No. 2 enclosure, we observed several dozen opened/destroyed bags of an ion exchange resin, and resin scattered about the floor of the shed, unprotected from the elements (Photo 12). In the chlorine injection building, a 150-lb chlorine gas tank was loosely chained to the rear wall and not situated on a scale. Content measures of tanks are estimated manually. CSJMTC/PRANG representatives advised that the chlorine scale was inoperable, and the chlorine gas sensor had never been calibrated. Camp Santiago Multi-Media Inspection Report 16 Distribution System Finished Water Storage Water System Management & Operations We observed two unscreened pipes at the floor level of the chlorine injection building which opened to the outside, and a wall opening too large for the pipe within it (Photos 17 & 18). An approximately 55-gallon drum of phosphate solution in the chlorine & treatment room was not in secondary containment (Photo 17). At Building 1033 we observed a faucet without backflow prevention. At Building 1011, we observed a faucet outdoors with a connected hose lying on the ground, without backflow prevention. At the wastewater lift-station (Building 00341), a hose used to clean the wastewater inlet rack (Photo 29) was connected to a potable water tap and was not equipped with a vacuum breaker. The hatchway for the 350,000-gallon concrete water storage tank (Building 845) had no sanitary seal and was flaking material (Photo 41). The surface of the tank roof appears degraded in several places (Photos 42-44). We observed that the piping from the well was equipped with a flow meter, but it was not operational at the time of inspection. Flow meters for both Wells No.1 & No. 2 were not operational at the time of inspection (Photos 5 & 10). Facility representatives expressed no knowledge of the type of resin observed on floor of shed in Well No.2 enclosure; Safety Data Sheet for the material was unavailable. AREA OF INSPECTION Source Pumps, Pump Facilities and Controls Treatment AREAS OF CONCERN FIELD OBSERVATIONS Horses and their fecal matter were observed on the grounds in various areas of the facility. CSJMTC/PRANG representatives stated they were unsure of the number of horses, who owned the horses or the location of the owner. The facility lacks a Supervisory Control and Data Acquisition (SCADA) system, which monitors information from calibrated flow meters; and temperature, turbidity, and chlorine sensors. The windows of the chlorine injection building and the chlorine storage building were equipped with small louvers, which provided inadequate air flow. Camp Santiago Multi-Media Inspection Report 17 Distribution Water Storage Water System Management & Operations Doors of the chlorine injection building and the chlorine gas tank storage building were not equipped with panic hardware. In the chlorine injection building, we observed electric wires covered with plastic insulation, but not contained in an electrical conduit. The facility lacks a cross-connection control and backflow prevention program. The cyclical nature of the facility's water demand creates areas of stagnant water in the distribution system where water is little used. The facility's water storage tank can stratify during periods of low water usage; the tank has no features that provide mixing of stored water. We observed that the lift station operations were supported by an emergency generator, fueled by a 550-gallon tank storing diesel fuel. Although the tank was in secondary containment, the containment structure also included a permanent vertical open pipe a few inches long. PRANG representatives stated that they had no idea why it was there, or where it led. Corrective Action: Following the inspection, PRANG documented that the open pipe was cut and sealed with cement. Although Camp Santiago representatives stated that the facility's fire department flushes the water mains, uses velocity meters to ensure adequate flow velocity for scouring, and samples before- and afterflushing to determine whether additional flushing is appropriate, no records are kept. Thus, the effectiveness of the flushing program is unclear. The facility lacks a valve exercising and inventory program, which would specify the number of turns for each valve and would ensure that valves are readily available for each valve size and type that may need to be replaced during the exercise program. Personal protective equipment for use in response to the chlorine building is located approximately 200 yards away. The eyewash station at the side of the chlorine injection building was inoperable. 5. ENVIRONMENTAL ASSISTANCE To increase the Federal community's understanding and compliance with applicable environmental requirements, EPA, along with other Federal agencies, sponsor Fed Center, the Federal government's home for comprehensive environmental stewardship and compliance assistance Camp Santiago Multi-Media Inspection Report 18 information for Federal facility managers and their agencies. Fed Center can be accessed via the worldwide web at https://www.fedcenter.gov/ Also, based on the observations made during the inspection, the facility could consider: Establishing a method of tracking hazardous waste generation by month as a best management practice to ensure they accurately know their hazardous waste generator classification and the requirements they need to follow; and Creating a list of designated UST operators, which, at a minimum, (1) identifies all current Class A, B and C operators for the facility, and (2) includes the names, Class of operator trained, date assumed duties, date each completed initial training, and any retraining. Note: This is a requirement of the 2015 revisions to the 1988 EPA UST regulations that Puerto Rico is in the process of incorporating into their requirements. 6. REQUESTED INFORMATION EPA is requesting individual generator logs from 2019-2022 to complete this compliance evaluation. Once received, the information will be reviewed. APPENDICES: A: FACILITY SIGN IN LOG B: INSPECTION PHOTOGRAPHS C: FEMA FLOOD MAP D: EJ SCREEN E: UST INSPECTION CHECKLIST Camp Santiago Multi-Media Inspection Report 19 APPENDIX A: FACILITY SIGN IN LOG Camp Santiago Multi-Media Inspection Report 20 Facility: La m:p ...)ao-n a...90 I dQ:;" c;J uat'l , p& NAME Charles Zafonte TITLE EPA contractor RESPONSIBILITY Re: THIS MEETING Lead inspector Bwa r~> tl T' - iiin::- ::; IL--~ .b' e- ~ c#1 -p to PHONE 610-392-6960 EMAIL ADDRESS zafontechas@gmail.com g:c,v\JQOj=o! Jillian Harvey-Shepard Ca<\os 'j . e:o\O\"'f)b:n', u.: l5~f. Ve- r; 3,...f. v c~ ./ "Aokli~ W/Je?. I (b r~dCA t: re, Au:> (~ Mo...n'Q. Sa rz;tJqcu',) ,j t:LtOvf1.a. /I (?/" 'a.. Ha.i MiQ./ /\d"o '~cu v EPA Inspector- In Training tPA~ dJ,f?w IJ/'V('f~- b'fuJ Wic:t'dl>r",iJ r-.../A, Enl/I~.j.~ fr- ~~ GnVI(, S,x~sf I ;6J'lVI'~~~f c:. f=t'-iod) , ~' -&tPrItGCI U ~tV:A- \-\'1\\ () W )Il1z ,.,. VI CI. OfodJ r V Io, 0 hol'(J , vie, 0 ho I'll. I 212-637-4078 harveyshepard.jillian@epa.gov ''(;i1- ql1 - ~'t 1j:;~90Z- ZrcfY ft;,1-Z.J'i- 3ilr{ 7g7 2.'1 I~O{) x: I '1)"'({C! ""1,& 1 L'il~ Iii ()~ XID'?3 '7g"1 28Y Ii-lIP y'/07Y ,<!1-~' Ic./OO x: (05tl to\ON'\~\ . ('Q.( \o~0epQ. <;jdJ .r 5"e .e -IIt {,). j ;A. < !> t~, f., . "".1 /() 6",,,,,,"/ r .)1.-f ( ( ~;\k. IO~l- fu,'~I"MJW. I. Ie o~' WI;{ br:~d"'-, L . aco5-k."1/>I;I6J~ ,;, / j\~~ .me> ~-ejo..rf\~ fY\.:. (\~S Q (~.,rY'YUf (Yll I rY\o.Y,~,,,,,,,, ,50-.1'\4,'% l> \"\.+~@c:..rmoy m;, 1 C{ 0cL1/70. ~.seco...- f'1}(;I,-,j c.w t, "",I ar'mu, rru l I Faenit,. Otrnf:l 2ittdi &~ /m-.d'bl:Qt\ I PR:=- Bafe"'&-Tirrre'. I,.t I '9( < J I v' - ...."./ Y NAME TITLE RESPONSIBILITY Re: THIS MEETING PHONE - EMAIL ADDRESS Charles Zafonte EPA contractor Lead inspector 610-392-6960 zafontechas@gmail.com Jillian Harvey-Shepard Wi\f(Oy~ Coyck~ Fel \(0 S c. V' " ckeL EPA Inspector- In Training Rubb0z ~v QX~y' f>\aM~ ~f)(} I-b/~ ~ I (JjJe v~ -j/l~-pt tI .VJ1{tlAa.. ~r7'+/~ V' ,--105 c ;; Vt [Izt<(/~ ~ ./ ~(\ OS ~ . Co'o,b~\ / :I\-tv.ru 'f\\~\ ~ /' 'J,c b~J&)bt,'7 J Ynl; YN)M.tvM Silt (/)f'W ( 0) ire (-/rr-- E 1-*\ TnS{kC -\of ~\-""~'--O 5~Si0t\~5"~ }>)>L{) ~/J , ~ vc.nw, /-: (Zeep, -1-\\1\1 (/) -a(LUttl~~I\ ~ r~c~ 8 h(l l1 ~Q~;~ \ Ch{,'s1\'q", G~~o \ \.-l A--(l2~S&JffL~ M~AJ-;:6>e{5I(\ '~ij'el' /;lJtf(S ;kFZl'pt-- .w/tf'/*~ ~ -7 ~ Ov.*-~lI.ea lvl) Co..('los ~e L.. 0(\1....( CFMo D\recW V (6.. ~') Ate 'IO,(\dvn vJ)r\ 'R CC\ C ~H. D 6I.'('-.tQ.R ( v,'C- o\to (\Q. \ e~ (0~onLtt ~~ e.(\~r d os\ I\G, \:)0~ 08 212-637-4078 harveyshepard.jillian@epa.gov ,87- 5'S7-~ \ \:) vQ;\ tno-N. c.0:"'~@~'.e~ '7'17' 3J-s-006J j-{"-1--Z.E9- I yvo {()et /() f- 3 r ir/10 i-r 7 Y" ~ \:XSa(\c ~ -z . 1U@Qc.r\ leu\<.. <...err") J11 Ct.t" ra -1/.1. ' : rJ-h' a~{), /1.{? ().. tV Q rtru, . rML j()ft.(.'I/([,j'-<~J7{'''''(; . ~.., 01~rl->o-y,hi 1'01-Q11 -~'C~"2 'f- IOl~ 1'(1"1 - ~t-yj- ( ,,(00 181- Z-{1- 39z,1 CO\O(Ylml\~ ~ co.(\D~Ve.PC\. 3<:." i\c.Gc.~fA..V'f'\ \IY'."\ ,c..~ '<Y'I". l\:~Cl~ .\'V\t yO'/Q",ck. 'O/>~~:t.J'CA~_W,I\ej~,11 ~1,tto 5oD4 (~Sl rt' 'lPq~.Q).~.lMt\l''CiS. M [)@t{bl.\,J'l! lAd '. J l\ (&1-IL~<Ko8( '.oO{\, ~l(,,-~(U,z.,(-fu t@61~c,\\ ...) J 137qJ4 b~~1 r\,h( \S~'(t,'\. MQ(\i\ - '( i' Ve{Cl.IiA;(@a{#~. ~,I I ;:78,7 - '/,;7tJ -//C:?J ~OCI;H /&-t"?" -d <:1;,;kt.i~ :c/-ry' . ..." J )(loQ; ,S7 -28'1, t'k>[) rCA:\(\tJ~ 1(. raez.Sie(V"A \I\~ll' 2.<6i, l 'fOO ((l) C\.V' N'Y . VV\ t \ . y. IDS'-\ IM:/ I ~ army APPENDIX B: INSPECTION PHOTOGRAPHS Photo 1 - Treatment Operator IV certificate for Mr. Sanchez Ms. Cardona Photo 2 - Treatment Operator III certificate for Ms. Cardona Camp Santiago Multi-Media Inspection Report 21 Photo 3 - Well No.1/Building (Bldg.) 002, secured enclosure and signage. Photo 4 -Bldg.002; Well No. 1 well head Camp Santiago Multi-Media Inspection Report 22 Photo 5-Well No.1 flow meter (non-functional) Photo 6 - Bldg.002; unscreened pipes at the rear of building Camp Santiago Multi-Media Inspection Report 23 Photo 7 - Well No.2/Bldg.003 secured enclosure signage Photo 8 - Bldg. 003 faade Camp Santiago Multi-Media Inspection Report 24 Photo 9 - Bldg. 003; interior, Well No.2 wellhead Photo 10 - Bldg. 003; Well No.2 flow meter Camp Santiago Multi-Media Inspection Report 25 Photo 11 - Shed in Well No.2 enclosure, bags of ion exchange resin Photo 12 - Opened bags of exposed of ion exchange resin Camp Santiago Multi-Media Inspection Report 26 Photo 13 - Treatment & Chlorine Room; water softener tanks 1&2 Photo 14 - Water softener tank 2; top of tank separated from its sides Camp Santiago Multi-Media Inspection Report 27 Photo 15 - Water softener tank 2 electrical hub Photo 16 - Phosphate chemical (55gallon drum), chemical analyzer and feed pump Camp Santiago Multi-Media Inspection Report 28 Photo 17 - Treatment & Chlorine Room; 55-gallon drum of phosphate chemical on wooden pallet Photo 18 - Door of chlorine injection bldg. (interior facing), overhead shower & eye wash station Camp Santiago Multi-Media Inspection Report 29 Photo 19 - Chlorine bldg. exhaust fan, chlorine gas tank and scale (1 of 2) Photo 20 - Chlorine room; unscreened wall opening with unprotected wiring (1 of 2) Camp Santiago Multi-Media Inspection Report 30 Photo 21 - Chlorine room; unscreened wall opening with unprotected wiring (2 of 2) Photo 22 - Chlorine injection building; louvered window Camp Santiago Multi-Media Inspection Report 31 Photo 23 - Chlorine storage shed Photo 24 - Chlorine gas cylinders (full & empty), granular calcium hypochlorite Camp Santiago Multi-Media Inspection Report 32 Photo 25 - 45-kg container of granular calcium hypochlorite Photo 26 - Chlorine storage shed; ion exchange resin (1 of 2) Camp Santiago Multi-Media Inspection Report 33 Photo 27 - Chlorine storage shed; ion exchange resin (2 of 2) Photo 28 - Bldg. 00341; wastewater lift station Camp Santiago Multi-Media Inspection Report 34 Photo 29 - Bldg. 00341; wastewater inlet screen Photo 30 - Wastewater lift station diesel-fueled power generator Camp Santiago Multi-Media Inspection Report 35 Photo 31- Bldg.00341; 550-gallon above ground diesel fuel storage tank Photo 32 -Bldg. 00341; diesel fuel tank secondary containment; in-ground vertical pipe Camp Santiago Multi-Media Inspection Report 36 Photo 33- Bldg. 00341; fire extinguisher without inspection tag Photo 34 - Bldg. 00341; depressurized fire extinguisher Camp Santiago Multi-Media Inspection Report 37 Photo 35- PX bldg.; fire suppression water supply and check valves Photo 36 - PX bldg.; hose connected directly to fire suppression water supply Camp Santiago Multi-Media Inspection Report 38 Photo 37 - Bldg. 1011; outdoor faucet with connected hose Photo 38 - Area of Bldg. 1011; threaded outdoor faucet Camp Santiago Multi-Media Inspection Report 39 Photo 39 - Bldg. 845; potable water storage tank secured enclosure and signage Photo 40 - Bldg. 845; potable water storage tank hatchway (1of 2) Camp Santiago Multi-Media Inspection Report 40 Photo 41- Bldg. 845; potable water storage tank hatchway (2of 2) Photo 42 -Bldg. 845; surface of potable water storage tank (1 of 3) Camp Santiago Multi-Media Inspection Report 41 Photo 43 -Bldg. 845; surface of potable water storage tank (2 of 3) Photo 44 - Bldg. 845; surface of potable water storage tank (3 of 3) Camp Santiago Multi-Media Inspection Report 42 Appendix C: Federal Emergency Management Agency (FEMA) 100 Year Flood Zone and EPA's Region 2 Composite Flood Risk Layer The facility is not located within a FEMA 100-year flood zone area. The facility is not located within the EPA's Region 2 Composite Flood Risk potential risk area. Camp Santiago Multi-Media Inspection Report 43 srarts, United States Environmental Protection Agency (EPA) Region 2 290 Broadway New York, NY 10007-1866 Underground Storage Tank (UST) Inspection Form INSPECTNOARME(S)C: awbs Zufk DATE: SIC CODE: ICIS #: L. Location of Tank(s) Facility Name Street Addrtss Ble 1S City Salix County o Tribal Saine State ZipCode O0757 II. Ownership of Tank(s) Owner Name AAFES Street Address City Sae County O same as location (I.) State Zip Code Phone Number Email/Websiteafes.c 2874 2626wtinezjue ConPtearcstonJ(s)har Mhine IIB. OperatorofTank(s) Contractor Name O same as location (L.) Phone Number: Email/Website Contact Person(s) IIC. Ownership ofUST(S)at Other Facilities Street Address City Phone Number State Zip Code Fax Number County o Do you own UST(s) at other UST Facilities Yes / No If Yes, How manyFacilities How many USTS II. Notification [280.22S- ubpartB] O Notification to implementing agency; name. StatFeacilitIyD# 57 2-090oUS DaItsesued:Novs, o DaEtexpires:Mov 5 2023 Any change from previous Notification noted? (Owner/ Operator/Substance stored/ Substance compatibility?) IfYes, Describe: Yo N& IV. Financial Responsibility [280.93(a)S- ubpartH) o State Fund* o Private Insurance: Insurer/Policy # oGuarantee o Local Government O Surety Bond o Self Insured oLetter ofCredit 8Not Required (Federal & Stategovernment,hazardoussubstanceUSTS) *IFNY State,then answer:Is there private insurance for third party bodily injury? V. Operator Training [280.240-SubpartJ] JnCatiea Is therean individual trained for Aand B operatorclasses?, Name ofClassAOperator Uilredaugnen Are all operators for class C trained? Does owner have a list of designated operators currently trained at each facility? Does owner have proof of operators training or retraining? Notes: Yes No g Yes c Noo Yeso No Yesk No o Page 1 of 8 Init/Date 01/09/2020 VI. Tank Information Tank No. Tank presently in use If not, date last used (see Section XII) If empty,verify1" orlessleft (seeSectionXII) Capacityof Tank(gal) Substance Stored 2,o002,000 lResale Krenis Compatibility Records Available? (CompatibilityDemonstrated?) MIY Tank installed/Upgraded NA 2o04 2uDt TankConstruction: Bare Steel, Sti-P3, Retrofitted sacrificial anode, Impressed Current, Composite, FRP, Interior lining, Vaulted Secondary Containment? SpillPrevention[ 280.20(c)X1)X).280.21(d)) Dw w Double Walled? YN If Yes,LastMonthlyCheck? I{NO, Last Triennial Containment Integrity Test? Overfill Prevention (specify type) NA $ 280.20(c)(1)(i),280.21(d)) Last TriennialInspection? SpecialConfiguration: Compartmentalized, Manifolded, Field Constructed, Airport Hydrant System VIL. Piping Information PipingType: Pressure, Suction Piping Construction: No Peses5e Bare Steel, Sacrificial Anode, Impressed Current, Flex, FRP, Double-walled (DW), Non-corrodible piping UnderDispenserContainment(UDC")? YN If Yes, installationdate? Date of last visual inspection/periodic monitoring/ Part of Line RD? YIN Ifabove Y, UDCDoubleWalled? Y/N 200 Daly paily IIDW, Last Monthly Check of AnnularSpace? If non-DW or no monthly check of DW, last 3-Yr Containment IntegrityTest? Page 2 of 8 Init/Date Section Continues to Page 3 01/09/2020 VII. PipingInformation Tank No. Secondary Containment Sump Used for ReleaseDetection? YN IfYes, Is Containment Sump Single/Double Walled? (SW/DW) For SW, or DW w/o monthly check of annular space, last 3-YR integrity check/DW sumps with monthly monitoring - Last check of Annularspace? Tank and Piping Notes: 2 (Continued) YY NA VII. Corrosion Protection (280.31) Tank No. Integrity Assessmentconductedprior to upgrade Interior Lining Interior lininginspected Is lining sole protection? Y/N Impressed Current Sacrifcial Anode: CP Test Records 60-day Rectifier inspection records CP Test Records CP Notes: (Include notes of any Interior Lining inspection) Ne IX. ReleaseDetection (280.43-SubpartD) Tank RDMethods ATG |Interstitial Monitoring Groundwater Monitoring* VaporMonitoring* Inventory Controlw/ TTT Manual Tank Gauging ManualTank Gauging w/ TTT SIR 12 Months Monitoring Records ($ 280.41(a), Must Make Available Last 12 Months For Compliance 280.45(6) *Site assessment/installation documentation? RD Equipment Last Tested? N/A Page 3 of 8 InittDate Section Continues on Page 4 01/09/2020 IX. ReleaseDetection (Continued) Tank RD Notes: (State What Months Records Were Available, Describe Any Failures and Deseribe What Investigation Occurred Due to Failure) Tank No. Pressurized & Non-Exempt Suction Piping RD Methods O NIA Interstitial Monitoring Groundwater Monitoring* Vapor Monitoring* Other? (specify) OR AnnualLine Tightnes Test MtMod AND ALLD Installed? Y/N LastAnnual Test ($280.44(a) hal3 12 Months Monitoring Records ($ 280.4I(b)()(H) *Site assessment/installation documentation? RD Equipment Last Tested? AreundDerispenCseorntainmen(UtsDCM)onitored? via Visual Inspection via Electronic Monitoring Records of inspections available? Mothale4 ha sors) uat UDC Monitoring Notes: (Records of release: State the past 12 months monitoring records) Piping RD Notes: (State What Months Records Were Available, Deseribe Any Failures and Describe What Investigation Oceurred Due to Failure) Page 4 of 8 Init/Date 01/09/2020 X. Repairs ($280.33-SubparCt ] N/A Repaired tanks and piping are tightness tested within 30 days of repair completion CP systems are tested/inspected within 6 months of repair ofany cathodically protected UST system Records of repairs are maintained "Overfil/Spill/Secondary Containment systems are tested/inspected within 30 days of repair" XI. Temporary Closure [$280.70-SubpartG] NIA Yo NUnknown o Yo No Unknowno Yo No Unknowno CP continues to be maintained UST system contains product and release detection is performed Cap and secure all lines, pumps, manways Yo N UnknownO Yo No Unknowno Yo NO Unknown o XII. Release History [280.50-SubpartE] NNA o To your knowledge, are there any public or private Drinking Water Wells in the vicinity? Yes /(N O Evidence of release or spills at facility O Evidence of release in the surrounding area to the facility o Releases reported to implementing agency; if so, date(s). o Release confirmed; when and how_ o Initial abatement measures and site characterization o Soil or ground water contamination O Remediation ongoing o Unusual Operating Conditions o Interstitial Monitoring alams o Greater than 25 gallons (estimate) IS280.53) o Free product removal o Corrective action plan submitted O Remediation completed, no further action; date(s) Notes: XII. Walkthrough Inspections ($280.36-SubparCt ] Owner and operators must conduct walkthrough inspections of the following: Must have monthly records Y No Spill Prevention Equipment- must be checked for damage, remove liquid or debris, and check fill cap. DW spill prevention equipment with interstitial monitoring- must check for leak in interstitial area. YNo Yo No N/A Release detection equipment-must check to ensure operating with no alarms and review records of release detection testing,. Yo No Must have annually records Containment sumps - must check for damage, leaks, remove liquid or debris. DW sumps with interstitial monitoring -must be checked for leak in interstitial area. Hand held release detection equipment - must check tank gauge sticks or groundwater bailer. * Owners and operators of UST System(s) must maintain records of operation and maintenance walkthroughinspectionsfor oneyear. YoNO Y No N/AO Y No Page 5 of 8 Init/Date 01/09/2020 SITE DRAWING DATE: Sps(o23 TIME ON SITE: TIME OFF SITE: WEATHhEoRht,umeidle, ma,cloudy ENVIRONMENTALLSYENSITIVEAREA: Yo N If"Yes", pleasedescribe: (NoT 1o SALE) DISPENSERS 3 8 o Pictures Page 6 of 8 Init/Date 01/09/2020 Facility Name Address UST Reg # THE UNITED STATES ENVIRONMENTAL REGION 2 UST PROGRAM Underground Storage Tank Team New York, NY 10007-1866 PROTECTION AGENCY (EPA) Inspector Observation Report Inspection of Underground Storage Tanks (USTS) D No areas of concern observed at the conclusion of this inspection. a The above named facility was inspected by a duly authorized observations and/or recommended corrective action(s): representative of EPA Region 2, and the following are the inspector's Areas of Concern Observed: RegulatoryCitation Area of Concern Wone Actions Taken: D Field Citation; # Comments/Recommendations: o Additional information required o On-site request/Due date Title ofUSTOwner/Operator Representative:70 Ye Mar Name of USTOWner/Operator Representative: Mldred Gu3aen (Pleaseprin (Signature) Other Paticipants: Juen Martine Dperat Name of EPA Inspector/representative: Chares tinte Rlease print) (Sig9ure)" NA (Credential Number) <23/2023 Date of Inspection Time Page 7 of 8 Init/Date AMWPM 01/09/2020 Location: Documents Not Available During the On-Site Inspection Please Provide As Soon As Possible Facility ID Number: o Tank Registration Certificate o Operator Training Records (Individuals training or retraining) o Demonstrate Financial Responsibility o Automatic Line LeakDetectorTestRecords - Annual o Line Leak TestRecords - Annual o Evidence of Spill Prevention o Evidence of Overfill Prevention o Tank Release Detection Records o Vapor Monitoring Records - Monthly (12 MostRecentMonths) o Under Dispenser Containment (Visual inspection or electronic monitoring) o Site Assessment to Demonstrate Monitor Wells Properly Installed/Located o Documentation of Compatibility for USTSystems o Corrosion Protection Inspection Records o Documentation of Periodic Walk-through Inspection o WalkthroughInspectionRecords - Monthly andAnnually o Other (specify) Additional Recommendations: Page 8 of 8 Init/Date 01/09/2020 Required Fields to be used for ICIS Only ComplianceMonitoring Activity: UST Inspection Inspection ConclusionDataSheet o 1) Did you observe deficiencies (areas of concern during the on-site inspection? Deficiencies observed: (Put an X for each observed deficiency) Potential failure to complete or submit a notification, report, certification, or manifest Potential failure to folow or develop a required management practice or procedure Potential failure to maintain a record or failure to disclose a document Potential failure to maintain/inspectrepair meters, sensors, and recording equipment Potential failure to report regulated events, such as spills, accidents, etc. 2) If you observed deficiencies, did you communicate the deficiencies to the Facility during the inspection? Yes/ No 3) Did you observe the Facility take any actions during the inspection to address the deficiencies noted? Yes I No If yes, what actions were taken? NA NA 4) Did you provide general Compliance Assistance in accofdane with the policy on the role of the EPA Inspector In providing Compliance Assistance during Inspections? Yes/'NO 5) Did you provide site-specific Compliance Assistance in accord,ce with the policy on the role of the EPA nspector in providing Compliance Assistance during the inspection? Yes (No This report was reviewed and deemed complete by: Reviewer Signature Date Page 1 of 1 Init/Date 01/09/2020