Document MaJVMrkevw8akxD0Q4OzKmGy

REPORT OF COMPLIANCE EVALUATION INSPECTION (INDUSTRIAL STORMWATER) BNSF Railway Company - Hobson Yard 801 W. O Street Lincoln, NE 68528 Authorization Number: NER910391 BY U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 7 ENFORCEMENT AND COMPLIANCE ASSURANCE DIVISION (ECAD) WATER BRANCH/DRINKING WATER & INSPECTIONS SECTION (WB/DWIS) ON MAY 3, 2023 Introduction At the request of the Water Branch (WB), Enforcement and Compliance Assurance Division (ECAD), a Compliance Evaluation Inspection (Industrial Stormwater) was conducted on May 3, 2023, at the BNSF-Hobson Yard located at 801 West O Street in Lincoln, Nebraska. The inspection was conducted under the authority of Section 308 of the Clean Water Act, as amended. It was conducted in accordance with the U.S. Environmental Protection Agency (EPA) Region 7 Standard Operating Procedures for Compliance Inspections (ENST SOP No. 2332). This narrative report presents the findings of the inspection. Mr. Jason Windhorst and Mr. Randol Wehrbein with the Nebraska Department of Environment and Energy were present during the inspection. Participants BNSF Railway-Hobson Yard x Rob Schroeder, Project Manager Environmental Operations. Robert.Schroeder@BNSF.com x Joshua Pope, Terminal Superintendent. x Michael Dover, Assistant Terminal Superintendent x Don Lee, Manager of Safety and Transportation EA Engineering, Science, and Technology Inc. x Maria Tran, Environmental Scientist Nebraska Department of Environment and Energy-NPDES Compliance Section x Jason Windhorst, Environmental Specialist, QCIS, QPSWPPP x Randol Wehrbein, Environmental Specialist U.S. Environmental Protection Agency (EPA), Region 7 x Naji J. Ahmad, Environmental Engineer, ECAD/WB/DWIS Procedures and Introduction Messrs. Jason Windhorst and Randol Wehrbein and I arrived at the at BNSF-Hobson Yard (Yard) at 9:00 A.M. on May 3, 2023. We met with Messrs. Joshua Pope, Michael Dover, Don Lee, and Rob Schroeder. We introduced ourselves, I presented my credentials, and I explained the purpose and procedures of the industrial stormwater compliance evaluation inspection. These included completing the Region 7 Industrial Stormwater Worksheet (Attachment 1), completing the Receipt for Documents and Samples Form and the US EPA Confidentiality Notice, evaluating self-monitoring and stormwater management practices and the Stormwater Pollution Prevention Plan (SWPPP) (Attachment 2) and conducting a Yard walk-through with photographs (Attachment 3). I provided Mr. Schroeder with the U.S. EPA Small Business Resources Information Sheet and the U.S. EPA Confidentiality Notice. Mr. Schroeder suggested that we start the inspection at his office where all the files are located. At Mr. Schroeder's office we also met with Ms. Maria Tran. After a brief description of the Yard operations, Ms. Tran provided us with the SWPPP document and outfalls monitoring records. Most of the records are stored electronically, Therefore, I requested an electronic copy of the records to be sent via email. Soon after, using a site map provided by Mr. Windhorst, Mr. Schroeder and Ms. Tran escorted Messrs. Windhorst and Wehrbein and I on a visual inspection of the Yard. During the Yard walkthrough, we looked at the material storage area where we observed oily material and sediment in at least three stormwater inlets (NOPF #1) leading to Outfall 03 and outfall 04, then we looked at the B-1 West Fueling Platform, the Cushman Tank Farm area where we observed poor housekeeping practices (NOPF #2) where blue gloves and floatable were on the ground and in the ditch leading to Outfall 08. We also looked at an open-top dumpster full of what appeared to be brake pads (NOPF #3), and finally we looked at Outfalls 07, 08, 09, 10, 11, 12, 01, 02, 03, and 04 respectively. After the Yard walkthrough, I discussed my preliminary observations of the Yard. I held a formal exit meeting with Mr. Schroeder and Ms. Tran and Messrs. Windhorst and Wehrbein. I informed Mr. Schroeder that I will issue a Notice of Preliminary Findings (NOPF) (Attachment 7) via email. I also informed Mr. Schroeder that I would communicate to him deficiencies that I may find upon my return to the office. The Yard chose not to claim any confidential business information. Yard Description The Hobson Yard is located at 801 West O Street in Lincoln, Nebraska. The Yard is located on a total of area of 493.48 acres owned and operated by BNSF Railway Company. Approximately 67 acres have industrial activities or significant materials that may contact stormwater. The Yard is bounded on the west and south by vacant areas along with Middle Creek, industrial and commercial development to the north, and Salt Creek to the east. According to the SWPPP document, industrial activities covered under the General Permit include locomotive fueling platforms, locomotive maintenance and repair (servicing), locomotive tie-up, locomotive sanding, railcar maintenance and repair, significant material storage areas, track equipment fueling, track equipment maintenance and repair, vehicle and equipment fueling, and vehicle and equipment maintenance and repair. Outfall # Outfall 01 Outfall 02 Outfall 03 Outfall 04 Outfall 05 Outfall 06 Outfall 07 Outfall 08 Outfall 09 Outfall 10 Description Located approximately 100 yards southeast of the WWTP and is identified as a culvert which flows north and discharges into wetlands. The inlet to this culvert is situated in a low area on the northern side of the adjacent access road. Source areas contributing flows to this outfall predominantly include the areas south and east of the WWTP, including DTL Fueling. A culvert discharge located north of the WWTP lagoons. It discharges into an adjacent wetland. Source areas contributing flows to this outfall include the area around the WWTP. Discharge of this outfall is into the same wetland as Outfall 01. Located approximately 135 yards east of the Work Equipment Building and is identified as a culvert which discharges into the north drainage ditch. Industrial activity sources contributing include track equipment staging/cleaning. Located farther northwest of the Work Equipment Building and is identified as a culvert that also discharges to the north drainage ditch. It also drains storm water from the overpass. Source areas include the Diesel Shop Area, Locomotive Staging, tank farm and material storage. Located approximately 1,000 feet northeast of the B-1 East Tank farm and is identified as a culvert which discharges into the north drainage ditch. Source areas include the B-2 East Tank Farm, DTL Fueling, track material storage area, and a sand tower. Located east of the B1 East (Old) Fueling platform and is identified as a culvert that discharges into the north drainage ditch. Sources contributing to this area include a sand tower, equipment storage, and DTL Fueling. Located on the northern side of B-1 West Fueling Platform and is identified as sheet flow that discharges into a low area that then flows into the north drainage ditch. Drainage ditch located directly east of the 40th Street overpass, which discharges into the north drainage ditch. Source area to the Outfall is from the Cushman Tank Farm. Located approximately 100 yards west of B-2 West Fueling Platform and is a storm sewer outlet which drains the southern side of the B-1 Fueling Platform. It discharges to a low area that ponds and then infiltrates or evaporates. Located about 2,500 feet east of B-2 West Fueling Platform. This culvert discharges into a drainage ditch which then flows into Monitored Location #1 NO Location #2 Location #2 Location #2 Location #2 NO NO (NOPF #3) Location #1 Location #1 Outfall 11 Outfall 12 Middle Creek. Source areas contributing include the B-2 west fueling platform and DTL fueling areas. About 1,600 feet east of B-2 East Fueling Platform (Old), and is identified as the south end of a drainage ditch that flows into Middle Creek. Source areas include the B2-east fueling platforms, Car Repair Shop, RIP Track Area, and DTL fueling areas. About 1,660 feet east of B-2 East (New) Fueling platform and is identified as a culvert that discharges to a ditch to Middle creek. Source area is DTL Fueling. Location #3 Location #1 Site Drainage Patterns Based on the local topography of the site and drainage description provided and indicated on the site plans included in the SWPPP, overall, the Yard is flat with several storm water drainage ponds on-site in low areas, allowing stormwater to evaporate or infiltrate. The Yard is approximately 3 miles in length by 0.25 miles wide. During significant rain events storm water discharges off site in several areas. The northern half of the Yard slopes gently toward the north, where it enters Outfalls 01, 02, 03, 04, 05, 06, and 07 which span the length of the yard. These Outfalls drain into the northern drainage ditch which drains into unnamed tributaries that flow east and ultimately discharge into Salt Creek. The storm water drainage from the southern half of the yard flows to the south, into Outfalls 09, 10, 11, and 12 which span the yard. These Outfalls discharge into Middle Creek which flows east to Salt Creek. Storm water from the Cushman Tank Farm and loading area close to 40 Street Overpass flows to the WWTP through the onsite sewer system. Drainage around the area that does not go to the WWTP flows to Outfall 08. Based on current Yard activities: x Outfalls 03 through 06 are substantially similar with DTL Fueling and parts storage areas as the industrial activity associated with these outfalls as well as similar runoff coefficients. x Outfalls 02 and 07 do not have discharges associated with industrial activities. Thus, they are not subject to monitoring. x Outfall 08 should have been considered a monitored outfall due to the industrial activities that drain to it (NOPF#3). x Outfalls 01, 09, 10, and 12 are substantially similar with DTL Fueling as the industrial activity associated with these outfalls as well as similar runoff coefficients. x Outfall 11 requires observation/monitoring. Findings and Observations All findings and observations of this inspection concern the Yard's status of compliance with the requirements of the NPDES general permit. These findings are based on my interviews with Yard personnel, my review of records provided to me by Yard personnel, and my visual observations of the site. All observations were discussed in detail with Mr. Schroeder and Ms. Tran throughout the inspection and during the formal exit meeting on May 3, 2023. Photos taken during the inspection on May 3, 2023, are included in Attachment 3 with the associated photo log. 1. As identified in the General Permit, discharges associated with industrial activity from the Hobson Yard are subject to analytical monitoring under Sector P-Land Transportation and Warehousing of Section 8.P of the General Permit. a. Indicator Monitoring: The Facility is required to complete indicator monitoring of stormwater discharges for three parameters: pH, TSS, COD, and PAH. The indicator monitoring parameters are "report-only" and do not have thresholds or baseline values for comparison, therefore no follow-up action is triggered or required. Indicator monitoring is neither benchmark monitoring nor an effluent limitation. Instead, it is a permit condition. Thus, failure to conduct indicator monitoring is a permit violation. b. Benchmark Monitoring: is not necessary at this Yard based upon the Sector P requirements outlined in the General Permit. c. Effluent Limitation Monitoring: Effluent limitations monitoring is not necessary at this Facility based upon the Sector P requirements outlined in the General Permit. d. Impaired Waters/TMDL: the Yard does not directly discharge to impaired waters. Therefore, impaired waters monitoring is not required. 2. The SWPPP was signed on September 28, 2022. The SWPPP document (Attachment 2) appeared adequate and included all the necessary forms and maps to achieve compliance with the NPDES permit. 3. During my visual observation of Outfall 09, I noticed there were two pipes located within a few feet of each other, (PVC and metal) both of which discharge to a low area that ponds and then infiltrates or evaporates. The 4" PVC (photo 21) was clear and evidence of discharge, the 8"-12" metal pipe however had 30% sediment deposit and evidence of discharge as shown in photo 22 below. Photo 22, Unidentified discharge point at Outfall 09 I asked Mr. Schroeder and Ms. Tran which pipe the SWPPP identifies as the outfall. Ms. Tran indicated the PVC pipe is the one monitored. As mentioned above, this outfall is located approximately 100 yards west of B-2 West Fueling Platform and is a storm sewer outlet which drains the southern side of the B-1 Fueling Platform. I further asked about the source of discharge via the metal pipe, Mr. Schroeder and Ms. Tran were unable to identify the source of the discharge. Further to the north I observed an inlet metal pipe (photo 24) pointing in the same direction as the outlet pipe of concern. However, we were unable to verify it was the same pipe. 4. During the inspection, Outfalls 10, 11, 12, 02, and 04 had standing water at the mouth of the outlet. Outfalls 09, 01, and 03 had significant buildup of sediment and were in need of maintenance. 5. I issued NOPF #1, because I observed an oily substance and sediment in at least three stormwater inlets (photos 1, 3, and 8) and significant ground discoloration (photo 4) at the Material Storage area in the Yard. Photo 3, Oily Substance in the stormwater inlet at the Material Storage area 6. I issued NOPF #2 for poor housekeeping practices because I observed used gloves on the ground in vicinity of Outfalls 07 and Outfall 08 (photo 14) and floatable trash in the ditch leading to Outfall 08 (photo 17). In addition, I observed ground discoloration on the ground beneath an open container full of what appeared to be used locomotive brake pads. The drainage valve was open (photo 18). 7. I issued NOPF #3, because the Yard SWPPP identified Outfall 08 as one of the outfalls that do not have discharges associated with industrial activities. Thus, Yard personnel failed to monitor it. As mentioned in item 4 above, the open container is located in the ditch that leads to Outfall 08. I explained to Yard personnel that storing process material in an open container causing ground discoloration is considered industrial activity. 8. Quarterly Outfalls visual stormwater inspections appeared adequate (Attachment 5). 9. I issued NOPF #4 for inadequate site inspections based on my review of routine and comprehensive inspection reports (Attachment 6). Inspection reports failed to identify: a. The container I observed near Cushman farm tank area within the vicinity of Outfall 08, was missing a valve plug. b. The trash in the ditch within the Cushman farm tank area within the vicinity of Outfall 08. c. The oily substance and sediment in the stormwater inlet and ground discoloration at the material storage area. d. The poor housekeeping practices in the vicinity of Outfall 07 an Outfall 08. e. That there was a release sediment and deposition of sand at Outfalls 09, 03, and 09, as I observed during my site observation (photos 22, 34, and 38). f. The need for BMPs maintenance and repairs. 10. On July 17, 2017, I received an email from MR. Schroeder that included BNSF response to the NOPF (Attachment 8). Conclusion Overall, structural controls such are ripraps and rock check dams appeared adequate. However, non-structural controls such as adequate site inspections, maintenance of BMPs, cleaning of sediment at the outfalls, and good housekeeping practices were inadequate. BNSF should investigate the source of discharge through the metal pipe at Outfall 09. NAJI AHMAD Digitally signed by NAJI AHMAD Date: 2023.07.21 16:40:23 -05'00' Naji J. Ahmad Environmental Engineer, WB/DWIS Digitally signed by Moran, Moran, Nicole Date: 2023.07.24 08:21:33 Nicole _____________-05_'00_' ________ Nicole Moran Section Chief, WB/DWIS ATTACHMENTS 1. R7 ISW Checklist 2. SWPPP 3. Site photos 4. NPDES Permit 5. Quarterly outfall visual stormwater inspections 6. Routine & Comprehensive Inspection reports 7. NOPF 8. Response to NOPF NPDES Industrial Storm Water Worksheet (Industrial) - Page 1 - Background Information (complete in field) National Database Information General Inspection Type NPDES ID Number Inspection Date Inspector Type Facility Type Industrial Stormwater NER910391 May 3, 2023 EPA RR transportation Inspector Name Naji Ahmad Telephone 913 551 7190 Entry Time 9:00AM Exit Time 12:30PM Signature NAJI AHMAD Date: 2023.07.21 16:41:01 -05'00' Digitally signed by NAJI AHMAD Name/Location/ Mailing Address GPS Coordinates Receiving Water(s)/MS4's Facility Location Information BNSF Railway Company - Hobson Yard 801 W. O Street, Lincoln, Nebraska 68528 Latitude 40.789704 Longitude Middle and Salt Creek -96.727642 Contact Information Name Owner/Permittee BNSF Railway Company - Hobson Yard Operator BNSF Railway Company - Hobson Yard Co-Permittee Facility Contact Rob Schroeder, Project Manager Environmental Operations Authorized Official(s) Rob Schroeder, Project Manager Environmental Operations Telephone 531-530-9984 531-530-9984 Site Information: Industrial Activity Transportation and Warehousing SIC Code(s) 4011 Basic Permit Information (circle one) Permit Coverage YES Permit Type General Copy of NOI on site? YES NOI Date ? Basic SWPPP Information 1. SWPPP on site YES 2. SWPPP Satisfactory* YES 3. SWPPP Implementation YES Satisfactory 4. *A Satisfactory SWPPP must be both current and complete (see pages 4, 5, and 6 of this checklist). Attachment 1 Page 1 of 6 NPDES Industrial Storm Water Worksheet (Industrial) - Page 2 - SWPPP Implementation (complete in field) Industrial Activity General (describe principal product, production rate, potential pollutants, areas exposed to precipitation, direction of storm water flow) The Hobson Yard is located at 801 West O Street, Lancaster County, Lincoln, Nebraska. The Yard is located on a total of area of 493.48 acres owned and operated by BNSF. Approximately 67 acres have industrial activities or significant materials that may contact storm water. The Yard is bounded on the west and south by vacant areas along with Middle Creek, industrial and commercial development to the north, and Salt Creek to the east. According to the SWPPP document, industrial activities covered under the General Permit include locomotive fueling platforms, locomotive maintenance and repair (Servicing), locomotive Tie-Up, locomotive sanding, railcar maintenance and repair, significant material storage areas, track Equipment fueling, track equipment maintenance and repair, vehicle and equipment fueling, and vehicle and equipment maintenance and repair. Facility Description (describe age and size of facility, number of employees, hours of operation) The Hobson Yard is located at 801 West O Street, Lancaster County, Lincoln, Nebraska. The Yard is located on a total of area of 493.48 acres owned and operated by BNSF. Approximately 67 acres have industrial activities or significant materials that may contact storm water. The Yard is bounded on the west and south by vacant areas along with Middle Creek, industrial and commercial development to the north, and Salt Creek to the east. Attachment 1 Page 2 of 6 NPDES Industrial Storm Water Worksheet (Industrial) - Page 3 - Storm Water Controls List the structural and non-structural controls employed by the facility. (provide a brief description of each) Structural: RCDs in ditches leading to outfalls, vegetative covers, ripraps at the mouth of outfalls. Storm sewer leading to on site WWTP. Non-structural: Inspections, employee training, SW discharge monitoring Structural controls employed at the outfalls. Are the controls (indicate "yes" or "no", or if not appropriate, explain) reasonable and Structural: YES appropriate Non-structural: NO (NOPF #1, #2 and #4) for the facility? Are the controls installed correctly and maintained in effective operating (indicate "yes" or "no", or if not appropriate, explain) YES SWPPP Implementation (continued) Storm Water Controls (continued) Provide a brief description of other controls that manage/prevent/ minimize storm water runoff. (e.g., erosion and sediment controls, exposure minimization, diversion structures, pollution prevention, inlet protection/control at storm drains) Structural: RCDs in ditches leading to outfalls, vegetative covers, ripraps at the mouth of outfalls. Storm sewer leading to on site WWTP. Non-structural: Inspections, employee training, SW discharge monitoring Structural controls employed at the outfalls. Miscellaneous Any evidence of (e.g., storm water runoff, dry weather discharge, co-mingling of process wastewater) discharge to receiving waters? Yes Do the storm water outfalls on site correspond with those listed on the site map and in (indicate "yes" or "no", or if not appropriate, explain) YES Attachment 1 Page 3 of 6 NPDES Industrial Storm Water Worksheet (Industrial) - Page 4 - SWPPP Review (can be completed in office) General Is there a SWPPP? YES Is a copy of the SWPPP on site? YES Did all "operators" and co-permittees sign the YES SWPPP? Did the signatures include the certification YES statement? Were the signatories authorized to sign? YES Is an individual/team responsible for YES developing/implementing SWPPP identified (e.g., pollution prevention team)? Are employee training records regarding YES storm water pollution prevention topics included in SWPPP? Operator evaluation of ESA requirements. YES Site Map Is there a site map? YES Drainage patterns/ outfalls? YES Identification of types of pollutants likely to be YES discharged from each drainage area? Location of major structural controls used to YES reduce pollutants in runoff? Name of receiving water(s) or MS4's listed? YES Is receiving water a tributary to waters of the YES U.S. (if "yes" indicate name of tributary)? Location of significant materials exposed to YES storm water? Locations of major spills occurring YES within 3 years from date of NOI? Location of fueling, maintenance, loading and unloading, material storage, waste YES disposal? Notes: Notes: Attachment 1 Page 4 of 6 NPDES Industrial Storm Water Worksheet (Industrial) - Page 5 - SWPPP Review (continued) Summary of Potential Pollutant Sources Description of activities, materials, features of site with potential to contribute significant YES amounts of pollutants to storm water? Significant Spills & Leaks List of significant spills and leaks over 3year time period, description of response YES taken, and actions to prevent similar spills in the future? Storm Water Controls Does the SWPPP describe the non- YES structural controls that will be used to prevent/reduce discharge of pollutants in storm water runoff? Does the SWPPP describe the structural YES controls that will be used to prevent/reduce discharge of pollutants in storm water runoff? Does the SWPPP describe other controls YES that will be used to prevent/reduce off-site tracking or blowing of sediment, dust and raw, final or waste materials, or other solid materials and floating debris? Does the SWPPP incorporate the 8 YES baseline controls (good housekeeping, minimizing exposure, PM, spill prevention/response procedures, routine inspections and comprehensive site evaluations, employee training, sediment and erosion control, runoff management)? Does the SWPPP contain completed YES routine inspection reports/logs regarding reportable implementation of 8 baseline controls? Does the SWPPP describe the pollutant or YES activity to be controlled by each selected control and provide an implementation schedule? Notes: Notes: Notes: Attachment 1 Page 5 of 6 NPDES Industrial Storm Water Worksheet (Industrial) - Page 6 - SWPPP Review (continued) Non-Storm Water Discharges Certification that facility has been tested for YES non-storm water discharges from the site? Description of testing method, drainage YES points, observed results, and date of test? Monitoring Are samples collected within 30 minutes of measurable weather events occurring 72 YES hours after previous measurable weather event? Photograph Log 1. 2. 3. See Narrative Report 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. Notes: Notes: Attachment 1 Page 6 of 6