Document aR29nN520p3Xra9K3dVLdwe

EPA REGION 10 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 12/17/2024 09:05 AM (PT) Announced: No 12/17/2024 11:05 AM (PT) Access: Granted 50F, Overcast Water Clean Water Act, NPDES, Stormwater - Industrial Compliance Evaluation Inspection Permittee Name Site Name Site Physical Address City, State, Zip Code County Facility GPS Coordinates Mailing Address City, State, Zip Code Lurre Construction Kuna Mora Pit aka Blacks Creek Pit East Kuna Mora Road Kuna, Idaho 83634 Ada 43.467962, -116.16060 307 Badiola Street Caldwell, Idaho 836056 FRS ID Permit Number SIC IDT8632340353 IDR05J10O 1442 (Construction sand & gravel mining) 1429 (Other crushed & broken stone mining & quarrying (pt)) Lead Inspector: RAYMOND ANDREWS Date: 2025.02.10 08:45:08 -08'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: Contreras, Peter Peter Contreras EPA Region 10 Digitally signed by Contreras, Peter Date: 2025.02.10 12:18:01 -08'00' contreras.peter@epa.gov (206) 553-6708 1 of 11 Lurre Construction Permit # IDR05J10O SECTION I - Opening Conference I arrived at the Lurre Construction site ("Site"), located at East Kuna Mora Road, Kuna, Idaho, at 09:05 AM on 12/17/2024 for an unannounced inspection. I presented my credentials to Mike Kolberg, Foreman, and informed him I was there to conduct an inspection to determine compliance with the Clean Water Act (CWA) and the site's National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) For Stormwater Discharges Associated with Industrial Activity, permit # IDR05J10O. This report is based on information supplied by Mr. Kolberg, Jack Nygaard, Syman Consultant, my direct observations, and records and reports maintained by the permittee. In addition, information gathered prior to or after the Inspection from a review of EPA, State, and/or public records may be included in this report. Lurre Construction is not a construction operation. It excavates sand, gravel and rock which are used for various aspects of construction projects. Lurre shares the site with Granite Excavation (IDR05J10R) and they use the same consultant, Syman Company, to manage stormwater. Lurre Construction operates from the lower portion of the Site. Syman specializes in providing stormwater compliance solutions for various industries and produced a single Stormwater Pollution Prevention Plan (SWPPP) for the site which encompasses both Lurre's and Granite's activities. In addition to writing the site's SWPPP, Syman maintains the Best Management Practices (BMPs), conducts routine site inspections, and conducts sampling. The Syman representative that works with Lurre and Granite, Jack Nygaard, was unavailable on the day of the Lurre inspection but he was there for the Granite inspection the following day and provided information for the Lurre inspection that Mr. Kolberg was unable to provide. Attendees Organization Attendee Name Title Present in Present in Opening Conf. Closing Conf. EPA Region 10 Raymond Andrews Lead Inspector Yes Yes Lurre Construction Mike Kolberg Foreman Yes Yes Site Information Type of Operation? Mineral Mining and Processing Is property owned? The property is leased from the Idaho Department of Land. Size of Site? The total size of the site is approximately 110 acres. Years in Operation? Lurre Construction started operations around February 1, 2023. Number of Employees? The site has three to five employees. Hours/Days of Operations? The site is operational 7AM - 5 PM, Monday through Friday. Some weekends are worked during peak construction season. Industrial activities exposed to stormwater? The site excavates raw material, crushes it, then sorts and loads it for shipping. Type of materials Construction aggregates, loaders, bulldozers, excavators, dump trucks, and/or vehicles stored crushers, and power sorters are all stored outside. outdoors? Number of Outfalls? The Lurre operations discharged through a single outfall, Outfall 001. There are no inlets or drains on site. 2 of 6 Lurre Construction Permit # IDR05J10O Sampling locations? The site's discharge is sampled at Outfall 001. Personnel conducting Jack Nygaard, the Syman Consultant, conducts inspections and sampling. inspections/sampling? How often does the Mr. Nygaard conducts quarterly sampling. site conduct sampling? Does the site analyze water samples inhouse? All water samples are analyzed by a contract lab. What is the contract lab's contact information? Analytical Laboratories, Inc. 1804 N 33 Road Boise, Idaho 83703 (208) 342-5515 Receiving Water? The receiving water is Tenmile Creek which is a 3rd order stream below Blacks Creek Reservoir. Describe stormwater's Stormwater flows downslope, from north to south in the southern portion of flow path across the the property. It flows from south to north at the northern portion of the site. property. BMPs/Stormwater Treatment? The facility uses available topsoil from clearing and grubbing to create topsoil berms at the facility's limits of disturbance to prevent stormwater discharges from leaving the facility. Overburden is stockpiled on the south end of the project limits, since the southern portion of the site receives heavy stormwater flows from up slope. The subgrade material is very porous, and stormwater infiltrates into the ground or evaporates. Other BMPs include secondary containments for fuel storage, which are double walled tanks. SECTION II - Observations No observations were made on site that constituted an area of concern. SECTION III - Records Review Records may not be in sequential order. Record: SWPPP AOC: No Ref #: RA1-RR-007 Reviewed By: Raymond Andrews Reviewed Date: 01/24/2025 Post inspection, I reviewed the Site's Stormwater Pollution Prevention Plan (SWPPP) with a preparation date of July 7, 2022. Syman, LLC is the consultant that created the SWPPP. Syman also does all the inspections and sampling required by the permit. Syman is the consultant for both Lurre Construction (IDR05J10O) and Granite Excavation (IDR05J10R) which share the site. Since it is a single site, Syman prepared one SWPPP that covers activities of each entity on the site. The SWPPP has entries specific to each operational entity as it applies, but a majority of the SWPPP addresses the site as a whole. The only areas of concern I found with the SWPPP are missing elements of the Site Map. The SWPPP map is required to use arrows to show the direction of stormwater flow. While the map does have arrows, there is nothing on the map, or in the Legend, explaining what the arrows represent. The Site Map showed the location of the two outfalls on the site, but it did not show the location of the sampling points. If the outfalls are the sampling points, the map should indicate that is the case. 3 of 6 Record: DMR Reports Ref #: RA1-RR-006 Reviewed By: Raymond Andrews Lurre Construction Permit # IDR05J10O AOC: No Reviewed Date: 01/24/2025 Post inspection, I reviewed Discharge Monitoring Reports (DMRs) from 4Q 2023 through 3Q 2024. I did not note any areas of concern. Record: Other - Site Routine Inspection Reports AOC: Yes Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Reviewed Date: 01/24/2025 Post inspection, I reviewed the Site's Routine Inspection Reports from 4Q 2022 through 4Q 2024. The report for 4Q 2022, dated November 30, 2022, checked "No" in the box for the fueling area indicating the controls were not adequate and recommended secondary containment be installed for "fuel/drums." The lack of secondary containment was reported again on the 1Q 2023 routine site inspection report. The 2Q 2023 - 4Q 2024 inspection reports indicate the fueling area had adequate controls during those inspections but none of the reviewed reports indicate what was done to bring the secondary containment from "not adequate" to "adequate". Record: Other - Site Annual Reports AOC: Yes Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 01/24/2025 Post inspection, I reviewed two of the Site's Annual Reports. One of the annual reports appears to be for the reporting year 2022 based on its contents. However, that report was not dated, signed and certified as required. The other Annual Report was for the 2023 report year and was properly dated, signed, and certified. Record: Notice of Intent AOC: No Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 12/12/2024 Prior to the inspection, I reviewed the site's Notice of Intent (NOI) to discharge, dated September 22, 2022. No area of concern was identified. Record: Other - Letter of Authorization to Discharge AOC: No Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 12/12/2024 Prior to the inspection, I reviewed a Letter of Authorization, dated October 26, 2022, to discharge under Idaho's 2021 Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activity (MSGP). Record: Other - ICIS Benchmark Report AOC: No Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 12/12/2024 Prior to the inspection, I reviewed a benchmark report generated from EPA's Integrated Compliance Information System (ISCIS) database. The report was provided by Jason Rodrigues and retrieved from the database on December 11, 2024. The report covered the four quarters of 2024. The report showed the site did not report any benchmark exceedances for the year. SECTION IV - Sampling Activities No sampling was conducted. SECTION V - Areas of Concern Areas of Concern may not be in sequential order. The presentation of Areas of Concern does not constitute a formal compliance determination or violation. 4 of 6 Lurre Construction Permit # IDR05J10O AOC Reference #: RA1-RR-004 Records Review: Other - Site Annual Reports Permit Requirement Part 7.4 of the Permit states, in part, "You must submit an Annual Report to EPA via NeT-MSGP...by January 30th for each year of permit coverage containing information generated from the past calendar year. You must include the following information in the Annual Report..." Part 7.4.3 of the Permit states, in part, "Your Annual Report must also include a statement, signed and certified in accordance with Appendix B, Subsection 11." Appendix B, Subsection 11, of the Permit states, "Any person signing documents in accordance with Appendix B, Subsections 11.A or 11.B above must include the following certification: "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information contained therein. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information contained is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." " AOC: The Annual Report for the reporting year 2022 was not dated, signed and certified as required. AOC Reference #: RA1-RR-007 Records Review: SWPPP Permit Requirement Part 6.2.2.3 of the Permit states the SWPPP must provide a map showing, in part, "c. Directions of stormwater flow (use arrows), including flows with a significant potential to cause soil erosion...i. Locations of all stormwater monitoring points..." AOC: There is nothing on the map explaining what the arrows represent. The Site Map did not show the location of the sampling points. AOC Reference #: RA1-RR-005 Records Review: Other - Site Routine Inspection Reports Permit Requirement Part 3.1.6 of the Permit states, in part, "You must document the findings of your facility inspections and maintain this report with your SWPPP...You must conduct any corrective action required as a result of a routine facility inspection..." Part 6 of the Permit states, in part, "As distinct from the SWPPP, the additional documentation requirements (see Part 6.5) are so that you document the implementation (including inspection, maintenance, monitoring, and corrective action) of the permit requirements." Part 6.5 of the Permit states, in part, "...the site is required to keep the following inspection, monitoring, and certification records with your SWPPP...6.5.4 Documentation of any maintenance and repairs of stormwater control measures, including the date(s) of regular maintenance, date(s) of discovery of areas in need of repair/replacement, and for repairs, date(s) that the control measure(s) returned to full function, and the justification for any extended maintenance/repair schedules..." AOC: The Site did not document corrective actions taken to address the lack of secondary containment. 5 of 6 Lurre Construction Permit # IDR05J10O SECTION VI - Closing Conference I held a closing conference with Mr. Kolberg at 11:05 AM (PT) on 12/17/2024 for the inspection. During the closing conference, I discussed my observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - List of Appendices 1. Photo Log 6 of 6 APPENDIX 1: Photo Log SWPPP 12/17/2024 09:29 AM No CBI No PII Site Entrance Site Entrance Sign with SWPPP, Photo 1 IMG-2024121709290929992564.jpg Photographer: Raymond Andrews 43.45889954, -116.25683151 SWPPP 12/17/2024 09:29 AM No CBI No PII Site Entrance Site Entrance Sign with SWPPP, Photo 2 IMG-20241217092950295078753.jpg Photographer: Raymond Andrews 43.45889954, -116.25683151 Lurre Site 12/17/2024 10:06 AM No CBI 43.46565925, -116.16299315 Conveyor, photo 1 No PII IMG-202412171006026288907.jpg Photographer: Raymond Andrews Lurre Site 12/17/2024 10:06 AM No CBI 43.46565925, -116.16299315 Conveyor, photo 2 No PII IMG-202412171006046485726.jpg Photographer: Raymond Andrews Lurre Site IMG-202412171008038388815.jpg 12/17/2024 10:08 AM No CBI No PII Photographer: Raymond Andrews 43.46567401, -116.16302884 End of Conveyor on left side of photo with bucket loader and dump truck Lurre Site 12/17/2024 10:11 AM No CBI 43.46567401, -116.16302884 General site photo No PII IMG-20241217101134113490247.jpg Photographer: Raymond Andrews Lurre Site 12/17/2024 10:12 AM No CBI No PII 43.46567401, -116.16302884 Access Road with working rock pile on the left IMG-202412171012371237105595.jpg Photographer: Raymond Andrews Lurre Site 12/17/2024 10:12 AM No CBI No PII 43.46619069, -116.16298221 Rock Crusher with piled rock in foreground IMG-202412171012461246104539.jpg Photographer: Raymond Andrews Lurre Site IMG-20241217101517151775904.jpg 12/17/2024 10:15 AM No CBI No PII Photographer: Raymond Andrews 43.46267093, -116.15593659 Access road with active site perimeter berm, photo 1 Lurre Site IMG-20241217101524152481859.jpg 12/17/2024 10:15 AM No CBI No PII Photographer: Raymond Andrews 43.46267005, -116.15594107 Access road with active site perimeter berm, photo 2