Document VJOE7jajwbO14MzbgveXxvNkN

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 10/23/2024 - 10/24/2024 Water NPDES Stormwater/CWA 402 Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: U.S. Department of The Air Force Joint Base San Antonio (JBSA) Lackland 1555 Gott St. JBSA Lackland, TX 78236 1555 Gott St. JBSA Lackland, TX 78236 Bexar (210) 671-0355 Ms. Sharon Jones Acting Chief, Environmental Compliance sharon.jones.13@us.af.mil FRS Number: Identification/Permit Number(s): Media Identifier Number: NAICS: SIC: N/A TXR00068 and TXR05DB56 N/A 928110 9711 Personnel participating in inspection: Sharron A. Crayton 6EN-WS Inspector/Enforcement Officer EPA Lead Inspector Signature/Date Sharron A. Crayton Sharron A. Crayton 12/16/2024 Date Supervisor Signature/Date RUBEN ALAYON-GONZALEZ Date: 2024.12.19 12:55:17 -06'00' Digitally signed by RUBEN ALAYON-GONZALEZ Ruben Alayon-Gonzalez Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION U.S. Department of The Air Force JBSA Lackland TPDES MS4 #: TXR040068 TPDES MSGP #: TXR05DB56 Inspection Dates: 10/23&24/2024 PURPOSE OF THE INSPECTION U.S. EPA Region 6 inspector Sharron Crayton arrived at the Joint Base San Antonio (JBSA) Lackland facility on October 22, 2024, at approximately 8:00 AM for an announced Compliance Evaluation Inspection (CEI). This site visit served as a multi-media inspection of the JBSA Lackland's Public Water Systems and Stormwater Systems in coordination with the Texas Commission on Environmental Quality (TCEQ) and the U.S. EPA Headquarters. The inspector initially met with the Environmental Compliance Chief for the U.S. Department of the Air Force, JBSA Lackland, Ms. Sharon Jones. During a joint opening conference, the stormwater inspector presented her credentials and informed Ms. Jones (and other attendees in-person and virtually) that the stormwater portion of this inspection was part of a National Enforcement Initiative focusing on Federal facilities' compliance with the Texas Pollutant Discharge Elimination System (TPDES) Municipal Separate Storm Sewer System (MS4) Phase II Permit [specifically, applicable minimum control measures (MCMs) and measurable goals] and the Clean Water Act (CWA). In addition, Ms. Jones and attendees were informed that the inspection would also focus on the facility's compliance with the TPDES Multi-Sector General Permit (MSGP), and TPDES Construction General Permit (CGP) requirements regarding Best Management Practices (BMPs) on active construction sites (see Attachments A and B for combined in-person attendee roster and site-specific attendee rosters). In lieu of an MS4 Self-Assessment, prior to the inspection, the JBSA Lackland provided, via an informal email request for information, applicable documents to the inspector for review. This inspection also included on-site reviews of the JBSA Lackland's small MS4 storm water management plan (SWMP) and relevant files, MSGP and CGP stormwater pollution prevention plans (SWPPPs) and associated recordkeeping requirements, as well as an on-site inspection of the drainage area(s) under the MS4, MSGP, and CGP. Various members of the global/combined Installation (environmental) Water Quality Program for JBSA Lackland, JSBA Fort Sam Houston, and JSBA Randolph accompanied the inspector during the on-site MS4, MSGP, and construction site inspection(s). Upon completion of inspection efforts for the JBSA Fort Sam Houston facility, site-specific inspection efforts for JBSA Lackland commenced the afternoon of October 23, 2024, and ended on October 24, 2024. The inspector conducted a closing conference with Ms. Jones, JSBA Management, members of the Installation Water Quality Program, and Ms. Rhonda Reza, Environmental Investigator with the TCEQ (see Attachment C - Combined Closing Conference Roster) to discuss the documents reviewed on-site, additional requests for information, and subsequent efforts of the on-site inspection. In addition, during the closing conference, the inspector discussed pending areas of concern (AOCs) noted during the inspection and items further detailed in this report (as detailed in Section III of this report). The generation of this report is based on information supplied by JBSA Lackland (the permittee), observations made by the inspector, and review of records and reports maintained by the permittee, the state of Texas, and the U.S. EPA. 2 U.S. Department of The Air Force JBSA Lackland TPDES MS4 #: TXR040068 TPDES MSGP #: TXR05DB56 Inspection Dates: 10/23&24/2024 FACILITY DESCRIPTION As noted in the facility's SWMP, JBSA Lackland is a United States Department of Defense (DoD) installation encompassing a total land area of 8,881 acres, whose mission is to command, operate, administer resources, and provide support to assigned, attached, satellite, and tenant units. Diverse base processes include the operation and maintenance of roads, sanitary and storm sewers, buildings, offices, hospitals, housing, dormitories, and other military training and operations. The facility is a Phase II (small) MS4 that discharges to surface waters of the United States, via TXR040068 issued by the TCEQ, via authorization that was administratively continued, as of March 26, 2024. Specifically, per the March 24th TCEQ correspondence, the facility submitted a Notice of Intent (NOI) seeking coverage under MS4 General Permit (TXR040000), which expired on January 24, 2024. However, the application process was not completed prior to the expiration date of the permit. Accordingly, the TCEQ's Executive Director converted the facility's NOI under the 2019 general permit into an application for an individual permit. In the interim, the TCEQ administratively continued the facility's MS4 Permit TX040068 until: 1) an individual permit is issued or denied, or 2) the facility submits an NOI and obtains coverage under the renewed 2024 Phase II MS4 General Permit. The facility is also authorized to discharge stormwater associated with industrial activity under TPDES Multi-Sector General Permit (MSGP) TXR05DB57, issued on November 9, 2021. Discharges associated with stormwater from construction projects are authorized under TXR150000. Section II - OBSERVATIONS Inspection of the MS4 Program evaluated how JBSA Lackland Houston has implemented the six (6) Minimum Control Measures of its SWMP: 1) Public Education and Outreach; 2) Public Involvement/Participation; 3) Illicit Discharge Detection and Elimination (IDDE); 4) Construction Site Stormwater Runoff Control; 5) Post Construction Stormwater Management in New Development and Redevelopment; and 6) Pollution Prevention and Good Housekeeping for Municipal Operations, including other subjects such as data management, inspection schedules, citizen complaints, legal authority, and measurable goals. The EPA inspector also conducted a review of JBSA Lackland's MSGP compliance requirements for Sector L: Landfills and Land Application Sites, and Sector P: Land Transportation and Warehousing. Additionally, the inspector conducted a walk-through of the Dunn Dental Clinic Construction Project located at the base at the corner of McGuire St. and Hughes Ave., for stormwater from construction activities, via CGP Permit TXR1571RS, effective August 8, 2024. The EPA Inspector also observed the inspection techniques of Ms. Samantha Bartholomew, member of the collective JSBA Installation Water Quality Program, as she demonstrated how she conducts construction storm water inspections. Overall, the JBSA Inspector's techniques appeared to be thorough and detailed (see Section III of this report for additional details regarding the condition of the project site). 3 U.S. Department of The Air Force JBSA Lackland TPDES MS4 #: TXR040068 TPDES MSGP #: TXR05DB56 Inspection Dates: 10/23&24/2024 Section III - AREAS OF CONCERN Areas of concern (AOCs) are derived from on-site observations and/or review from the October 23rd & October 24th Compliance Evaluation Inspection (CEI) and from subsequent documents provided electronically by the installation staff via email prior to, during, and/or after the inspection efforts. The following AOCs are specific to the MS4 Program: 1. Globally, the site was not in compliance with the MS4 Program at the time of the inspection. More specifically, several program deficiencies were noted, which included, but were not limited to: a. Inaccurate reporting of meeting compliance with various modules and associated Best Management Practices (BMPs) in the site's annual MS4 report(s); b. Deficiencies with not achieving measurable goals of the SWMP but indicting in the annual report that goals had been achieved or not providing the details to substantiate achievement of various goals; c. Lacking systems to accurately track measurable goals; d. Deficiencies with training and accountability of trained individuals; e. Referencing an affirmative/compliant use of design and environmental specifications to support BMP compliance requirements in the annual report, however, interviews with site personnel disclosed these efforts were not consistent and/or did not exist as reported; f. Various logs and/or tracking data tools could not be provided during the inspection and/or did not exist (i.e., street weeping logs; calls to the environmental hotline, nature of calls, and date of resolution; signature documentation (vs typed names) for training provided, etc.); g. As of the date of this inspection, the facility has not finalized efforts with submitting a completed MS4 NOI and obtaining coverage under the renewed 2024 Phase II MS4 General Permit. Per interviews with members of the Installation Water Quality Program, specifically Ms. Jones and Ms. Bartholomew, these efforts would be completed by the end of November/December 2024. The following AOCs are specific to the MSGP Program: 1. Via interviews with members of the Installation Water Quality Program, specifically Ms. Jones, Ms. Bartholomew, and Mr. Gerald Johnson, the current five (5) MSGP outfall destinations are incorrect at the facility. Via a PowerPoint presentation shared during the inspection and associated interviews, it was noted that on or about October 2022, the facility engaged in discussions with the TCEQ to inform the agency that current MSGP outfalls are located at installation MS4 boundaries instead of at individual facilities - this practice is not authorized by the MSGP permit. Specifically, the facility communicated to the TCEQ that designated outfalls for JBSA Lackland were observed to be not representative of the runoff from the individually permitted areas of industrial activity. Current outfalls are located in areas that received runoff from mixed sources including urbanized areas which were part of the MS4 and undeveloped area(s), and therefore could result in inaccurate water quality monitoring data. As such, the facility communicated to the TCEQ that it would reevaluate and redesignate the locations of its MSGP storm water outfalls. However, as of the date of this inspection report these efforts have not been completed, and the associated MSGP Storm Water Pollution Prevention Plan (SWPPP) has not been revised. 4 U.S. Department of The Air Force JBSA Lackland TPDES MS4 #: TXR040068 TPDES MSGP #: TXR05DB56 Inspection Dates: 10/23&24/2024 The following AOCs are specific to the CGP Program: 1. The TCEQ Large Construction Site Notice for the Dunn Dental Clinic Project Site (TXR1571RS) was posted, but the details of the notice were illegible (see Appendix 1, Photograph #1). Section IV - FOLLOW UP Please provide the EPA with a status update of the MS4 NOI and MSGP outfall reevaluation efforts. Section V - LIST OF APPENDICES AND ATTACHMENTS Appendix 1: Photograph Log - One (1) photo taken 10/24/2024 Attachment A: 10/22/2024 Combined Opening Meeting Attendee Roster Attachment B: 10/23/2024 JSBA Lackland Site-Specific Opening Meeting Attendee Roster Attachment C: 10/25/2024 Combined Closing Meeting Attendee Roster 5 U.S. Department of The Air Force JBSA Lackland TPDES MS4 #: TXR040068 TPDES MSGP #: TXR05DB56 Inspection Dates: 10/23&24/2024 Appendix 1 Photograph Log 6 U.S. Department of The Air Force JBSA Lackland TPDES MS4 #: TXR040068 TPDES MSGP #: TXR05DB56 Inspection Dates: 10/23&24/2024 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo No. 1 Location: JSBA Lackland City: JSBA Lackland County: Bexar State: TX Description: View, of TCEQ Large Construction Site Notice for Dunn Dental Clinic Project Site (TXR1571RS), with illegible details regarding construction notice. Date of Photo: 10/24/2024 Photographer: Sharron Crayton 7 U.S. Department of The Air Force JBSA Lackland TPDES MS4 #: TXR040068 TPDES MSGP #: TXR05DB56 Inspection Dates: 10/23&24/2024 Attachment A 10/22/2024 Combined Opening Meeting Attendee Roster 8 U.S. Department of The Air Force JBSA Lackland TPDES MS4 #: TXR040068 TPDES MSGP #: TXR05DB56 Inspection Dates: 10/23&24/2024 9 U.S. Department of The Air Force JBSA Lackland TPDES MS4 #: TXR040068 TPDES MSGP #: TXR05DB56 Inspection Dates: 10/23&24/2024 Attachment B 10/23/2024 JSBA Lackland Site-Specific Opening Meeting Attendee Roster 10 U.S. Department of The Air Force JBSA Lackland TPDES MS4 #: TXR040068 TPDES MSGP #: TXR05DB56 Inspection Dates: 10/23&24/2024 11 U.S. Department of The Air Force JBSA Lackland TPDES MS4 #: TXR040068 TPDES MSGP #: TXR05DB56 Inspection Dates: 10/23&24/2024 Attachment C 10/25/2024 Combined Closing Meeting Attendee Roster 12 U.S. Department of The Air Force JBSA Lackland TPDES MS4 #: TXR040068 TPDES MSGP #: TXR05DB56 Inspection Dates: 10/23&24/2024 13