Document jDnE2EZkgNRm2L3ZeqNBYBj9

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 155 Seattle, WA 98101 ENFORCEMENT & COMPLIANCE ASSURANCE DIVISION SUBJECT: CLEAN WATER ACT INSPECTION REPORT Anchorage Sand & Gravel Co., Inc. - Klatt Road Facility, Anchorage, Alaska PREPARED BY: Tara Martich, CWA Enforcement Specialist Water Enforcement & Field Branch, Surface Water Enforcement Section SIGNATURES: Lead Inspector TARA-ANN MARTICH Digitally signed by TARAANN MARTICH Date: 2023.02.14 09:00:24 -09'00' Supervisor MICHELE JENCIUS Digitally signed by MICHELE JENCIUS Date: 2023.02.14 11:09:23 -08'00' BASIC INFORMATION Facility Name: Anchorage Sand & Gravel Co., Inc. - Klatt Road Facility Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Office Location: 1040 O'Malley Rd, Anchorage, Alaska 99515 NPDES ID: AKR06AB65 Date of Inspection: Wednesday, September 14, 2022 Lead Inspector: Tara Martich, CWA Enforcement Specialist Other Attendees: 1. Mickey Regan Jencius, EPA 2. Kris Shippen, Environmental Manager, Anchorage Sand & Gravel Co., Inc. Purpose of Inspection: Stormwater inspection Facility Type: Sand and gravel processing Regulations Central to Inspection: National Pollutant Discharge Elimination System (NPDES) Page 1 of 9 Arrival Time: 11:30 AM Departure Time: 2:20 PM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Credentials Presented CBI warning to facility provided The information in this section was obtained verbally from Kris Shippen unless otherwise noted. The opening conference was held in a conference room at Anchorage Sand & Gravel Co., Inc. (AS&G) office. The office is located a few blocks east of the Klatt Road Facility ("facility"). Process Description: AS&G brings sand and gravel to the Klatt Road Facility, where it is then crushed, washed and/or screened and distributed into stockpiles. Some materials are further processed at the concrete readymix plant or at the block plant. Materials leave the site as final sand and gravel products. Piping around the facility collects stormwater and brings it to a settling pond. If the settling pond overflows, then the discharge is directed, via an underground pipe, to the Municipality of Anchorage storm sewer system. AS&G displays a large aerial photograph of the Klatt Road Facility in its conference room. EPA asked about operations visible in the aerial photograph but excluded from the Klatt Road Facility SWPPP map. EPA identified three additional areas that are part of the Klatt Road Facility operations: 1) Precast Area, 2) Building Materials, and 3) Storage. AS&G shared that it specifically excluded Building Materials from the Klatt Road Facility SWPPP because of Building Materials' SIC number. Figure 1: Areas covered by 2020 SWPPP Page 2 of 9 Figure 2: Aerial of Klatt Road Facility. Precast Area, Building Materials & Storage are owned/operated by AS&G. Other Information: AS&G updated its SWPPP in 2020. A water truck is used for dust suppression, as needed. The crusher foreman typically directs the water truck, but any shop or employee can request the water truck. Once per week, a sweeper truck sweeps the facility. In between sweeper truck visits, brooms can be used to sweep. Broom-sweeping is directed by a foreman. The Environmental compliance team includes Kris Shippen and PJ Larsen (Lead Foreman). Discharges. According to Kris Shippen, the facility has not discharged effluent since at least 2019, when Kris Shippen began his employment with AS&G. Training. Annually, Kris Shippen provides SWPPP training to the facility foreman. The facility has foremen at the crusher, cement terminal, sacking, block plant, precast, batch plant and recycle crusher. Routine Visual Monitoring. Kris Shippen conducts routine visual monitoring, which he does not document. During the routine monitoring, Kris uses a pH pen meter to determine pH of the pond. Whenever Kris observes track-out, he requests the sweeper truck, as well as the water truck for dust control. Quarterly SWPPP Inspections. Kris Shippen and/or PJ Larsen conduct quarterly SWPPP inspections. They try to conduct these inspections during rain events. RECORDS REVIEW EPA reviewed and/or attempted to review the following inspection reports onsite. Quarterly SWPPP Inspections 2nd quarter 2022 - conducted by PJ Larsen on 6/28/2022 during clear conditions. Page 3 of 9  1st quarter 2022 - conducted by Kris Shippen on 3/18/2022 during clear conditions. This inspection report was not available for review at the time of inspection. AS&G provided a copy after the inspection via email. 4th quarter 2021 - conducted by PJ Larsen on 9/30/2021 during clear conditions. This inspection was conducted before October 1, e.g., before the 4th quarter. 3rd quarter 2021 - conducted by PJ Larsen on 6/30/2021 during clear conditions. 2nd quarter 2021 - conducted by PJ Larsen on 4/20/2021 during clear conditions. 1st quarter 2021 - conducted by Kris Shippen on 3/26/2021 during clear conditions. The SWPPP inspection was not dated in the annual certification. 4th quarter 2020 -conducted by Kris Shippen on 11/14/2020 during snowy conditions. 3rd quarter 2020 - conducted on by Kris Shippen on 9/8/2020 during cloudy conditions. 2nd quarter 2020 - conducted by PJ Larsen on 5/1/2020 during cloudy conditions. 1st quarter 2020 - conducted by Kris Shippen on 3/20/2020 during raining/sleeting conditions. Observation. Although, Kris Shippen told EPA that AS&G attempted to conduct its quarterly SWPPP inspections on rainy days, only 1 of the 10 the quarterly SWPPP inspections was conducted on a rainy day. Annual Reports 2021 Annual Report. The MSGP Annual Reporting Form was submitted to the Alaska Department of Environmental Conservation on 2/8/2022 and based upon an inspection conducted by Kris Shippen on 9/30/2021. 2020 Annual Report. The MSGP Annual Reporting Form was submitted to the Alaska Department of Environmental Conservation on 2/4/2021 and based upon an inspection conducted by Kris Shippen on 10/17/2020. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: During the tour, the sun shined, and no clouds were visible. It was a clear day. A water truck actively watered facility surfaces. EPA walked the facility starting in the southwest corner, at Building Materials. EPA could not distinguish a line of demarcation between the SIC-excluded Building Materials and the portion of the facility covered by the SWPPP. Materials stored along the eastern border of the facility, which belonged to operations covered by the SWPPP, were located within both the SIC excluded area and SWPPP covered areas. When EPA asked AS&G about exactly where the SWPPP coverage began and ended by Page 4 of 9 pointing to materials stored along the eastern border, AS&G was not able to clearly articulate a boundary between its Block Storage Yard and Building Materials. Walking north, we saw the Block Storage Yard and the Block Plant. We saw the salt pile, which was covered with a tarp. We then walked to the main sand and gravel processing area and towards the pond. We saw the facility entrance, which slopes towards Walter J. Hickel Parkway. We walked along an internal facility road that borders the northern edge of the property. Along that roadway, we could see a cut in the bank where stormwater had recently discharged. There was very wet mud in the cut. Figure 3: Facility Road Along Northern Boundary with Cut EPA looked at where the cut flowed to. We could see leaves and grass covered with mud and a path to where the muddy discharge flowed. A large deposit of sediment sat at the bottom of the path. Some young grasses grew on the sediment, indicating the that the sediment pile had gown over time. The Figure 4: View of Cut from Northern Side of Fence Figure 5: Path of Discharge through Cut, Muddy Grass/Leaves Page 5 of 9 Figure 7: Path from Cut & Sediment Deposit Figure 6: Sediment Deposit and Curb northernmost face of the pile dropped at an almost 90-degree angle to the curb. The curb, next to the deposit, appeared well-maintained. A storm drain inlet is located a few feet east of the sediment pile. Next, we looked at the onsite pond and its discharge overflow pipe. When we arrived at the discharge overflow pipe, it was actively discharging. Debris on the grate above the overflow-pipe indicated the water was higher than the grate at some point. Kris Shippen commented that he was surprised to see the pond discharging and then further commented that the discharging was new. We pointed out to Kris Shippen the mudline on the vegetation around the pond. The mudline was more than a foot above the current pond level. We told AS&G the mudline indicated the pond had been discharging for some time. Kris appeared to understand. He said he would pull a sample of the discharge. Figure 8: Overflow Pipe Discharging Page 6 of 9 Just west of the pond, at AS&G's Klatt Road Facility, is Granite Construction's operation. The operation appeared to mainly be a hot mix asphalt plant. However, it also appeared to have access to and use AS&G's stockpiles. To anyone unfamiliar with the site, Granite's operation appears to be part of AS&G's Klatt Road Facility. Again, like with Building Materials, it was difficult to tell where one operation ends and the other begins. Figure 9: Mudline at Pond Lang Street, a municipal street, runs through the middle of AS&G's operation. West of Lang Street AS&G crushes and stockpiles reclaimed asphalt pavement and other materials. When we walked across Lang Street, we observed discharges entering the storm drains on both the northeast and northwest corners of Lang Street and Hickel Parkway. Turbid waters sheet-flowed across the surface of the reclaimed asphalt pavement crushing operation. No BMPs were present to filter the sheet flow from the reclaimed asphalt paving area before it entered Figure 10: Granite Construction / Reclaimed Asphalt Crushing & Stockpiles Page 7 of 9 Figure 11: Discharge into Storm Drain at NE Corner of Lang Street & Gilman Parkway Figure 12: Discharge into Storm Drain at Reclaimed Asphalt Recycling (NW corner of Lang Street and Gilman Parkway) into the gutter on Lang Street, and then into the storm drain. We pointed the turbid discharge out to Kris Shippen. Kris commented he would need to figure out how to collect a sample and mentioned he believed the water could include contaminates from properties upstream. We followed the water flow. Upstream properties were not discharging. We also told Kris, if/when AS&G's upstream neighbor(s)' discharged, Kris could collect a sample of that (before it came into contact with AS&G's discharge) to establish a baseline. During the site walk, we noted several drums, and other materials stored in areas that did not include spill containment and/or located in areas where water flowed towards the onsite ponds. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Concerns: 1) Notion the facility has not discharged since 2019, even though it was actively discharging on the day of the inspection; 2) no history of sampling of discharges (During the inspection on a clear/non-rainy day, EPA found the pond directly discharging to municipal storm system and noted discharges from site entering into storm drains); 3) excluding the precast area, storage area and building materials area from the SWPPP; and 4) lack of records for pH measurement of the pond. Page 8 of 9 Requested documents: 2020 SWPPP Quarterly Reports Q1 2020 - Q3 2022 Results of Discharge Sampling Page 9 of 9 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 APPENDIX 1 - PHOTO LOG Appendices Page 1 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 1: 2020 SWPPP indicates no non-stormwater discharges Picture 2: September 30, 2021, Inspection conducted by P.J. Larson Appendices Page 2 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 3: September 30, 2021, Annual Report indicates inspection conducted by Kris Shippen Picture 4: Material Storage excluded from 2020 SWPPP Appendices Page 3 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 5: Materials Stored at Building Materials and Excluded from SWPPP Picture 6: Evidence of Onsite Erosion Appendices Page 4 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 7: Chevron Meropa 150 Picture 8: Anchorage Sand & Gravel Pond and Ready Mix Truck at Granite Construction Ready Mix Plant Appendices Page 5 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 9: Location of Discharge North of Pond Picture 10: Gravel Installation Appendices Page 6 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 11: Gravel Installation Picture 12: Onsite Pond Mudline and Buried Pipe Appendices Page 7 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 13: Material Stored in the Water Flow Path to Pond Picture 14: Stormwater Control Appendices Page 8 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 15: Stormwater Control Picture 16: Sheet Flow from Recycle Asphalt Paving (RAP) Processing Area Appendices Page 9 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 17: Discharge from RAP Processing Area Picture 18: Discharge from RAP Processing Area Appendices Page 10 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 19: Discharge from RAP Processing Area Picture 20: Discharge from RAP Processing Area Appendices Page 11 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 21: Discharge from RAP Processing Area Picture 22: Ponding and Sheet Flow from RAP Processing Area Appendices Page 12 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 23: Ponding and Sheet Flow from RAP Processing Area Picture 24: Precast Area and Materials Stored Outside Appendices Page 13 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 25: Precast Area and Materials Stored Outside Picture 26: Discharge at NW Corner of Lang and Gilman Appendices Page 14 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 27: Discharge at NE Corner of Lang St. and Gilman Pkwy. Picture 28: Apparent Removal of Mud from Discharge Location along Northern Facility Road Appendices Page 15 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 29: Discharge along Northern Facility Road Picture 30: Storm Drain in Gilman Pkwy Gutter Appendices Page 16 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 31: Discharge and Sediment from Northern Facility Road Picture 32: Buildup of Sediment from Discharge along Northern Facility Road Appendices Page 17 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 33: Sediment and Sediment Path from Discharge along Northern Facility Road Picture 34: Storm Drain in Gilman Pkwy Appendices Page 18 of 19 Facility Name: Anchorage Sand & Gravel Facility Location: 11195 Lang St, Anchorage, Alaska 99515 Date of Inspection: September 14, 2022 Picture 35: Discharge from AS&G into Storm Drain in Gilman Pkwy. Picture 36: Sediment and Cobble Deposited from the Discharge along Northern Facility Road Appendices Page 19 of 19