Document nGYBdRxX5YJ5GpJ6jORmGnr1

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 08/02/2024 12:20 PM (PT) Announced: Yes 08/02/2024 03:35 PM (PT) Access: Granted 60F, Sunny Water Clean Water Act, NPDES, Stormwater - Industrial Compliance Evaluation Inspection Permittee Name Facility Name Facility Physical Address City, State, Zip Code Borough Facility GPS Coordinates Mailing Address City, State, Zip Code Wayne Newton - Alaska Airlines Inc. Alaska Airlines Petersburg Station 1504 Haugen Drive Petersburg Census Subarea, AK 99833 Petersburg 56.80739, -132.93806 P.O. Box 68900 SEAZE Seattle, Washington 98168 FRS ID Permit Number SIC 110070072428 AKR06AC00 4512 (Scheduled Air Transportation) Lead Inspector: RAYMOND ANDREWS Date: 2024.08.28 12:58:38 -07'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2024.08.28 15:22:59 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA Region 10 contreras.peter@epa.gov (206) 553-6708 Alaska Airlines Petersburg Station Permit # AKR06AC00 SECTION I - Opening Conference I arrived at the Alaska Airlines Petersburg Station (the "Site" or "Facility"), located at 1504 Haugen Drive, Petersburg, Alaska, at 12:20 PM (PT) on 08/02/2024 for an announced inspection. I presented my credentials to Tina Rodriguez and informed her I was there to determine compliance with the Clean Water Act (CWA), and the facility's National Pollutant Discharge Elimination System (NPDES) permit, permit # AKR06AC00. This report is based on information supplied by facility representatives, direct observations made by me, and records and reports maintained by the facility. 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. Attendees Organization Attendee Name Title Present in Present in Opening Conf. Closing Conf. EPA Region 10 Raymond Andrews Lead Inspector Yes Yes Alaska Airlines Tina Rodriquez Environmental Affairs Yes Yes Program Manager Alaska Airlines Darcey Hedlund Customer Service Lead Yes Yes Facility Information Responsible official? Tina Rodriguez, christina.rodriguez.heald5@alaskaair.com Type of Operation? Airport Industrial Sector Sector S (Air Transportation) Is property owned? Alaska Airlines owns the office building, maintenance building and a warehouse. The land the airport is situated on belongs to the State of Alaska. Site size? The total site land area is approximately 240 acres. The approximate size of the operational area is 50 acres. Years in operation? The facility has been operating at this since for approximately 80 years. Number of employees? The facility has approximately six full time employees, but the facility increases staffing to 11 during the Summer. Hours/Days of Operations? The facility operates 7-days a week from 8:00am until 4:30pm. Industrial activities exposed to stormwater? During winter, the facility conducts de-icing operations. The facility uses a glycolbased product but does not meet or exceed the threshold that would trigger pollutant monitoring. The facility does not use products containing urea. Personnel conducting inspections/sampling? Skyler Cummings, the Station Agent, conducts all sampling and monitoring. The facility is only required to conduct quarterly visual assessments (QVAs). The facility is not required to conduct water sample analysis because the facility does not use urea products, or 100,000 gallons glycol based deicing products. What is your site The facility is only required to monitor by conducting Quarterly Visual monitoring frequency? Inspections. Sampling location? The facility samples near the southeast corner of the building from sheet flow. Receiving Water Wrangell Narrows Number/location of Outfalls? The facility does not have specific outfalls. The stormwater sheet flows into a vegetated area. As stated above, samples are collected from the sheet flow. 2 of 7 Alaska Airlines Petersburg Station Permit # AKR06AC00 Stormwater Treatment? The facility does not conduct active treatment. All stormwater runoff leaves the paved area and enters a vegetated area where it infiltrates. Type of materials The facility does not store anything outside. and/or vehicles stored outdoors? SECTION II - Observations No observations were made that constitute an area of concern. SECTION III - Records Review Records may not be in sequential order. Record: Other - Comprehensive Site Inspections AOC: No Ref #: RA1-RR-008 Reviewed By: Raymond Andrews Reviewed Date: 08/26/2024 At the time of the inspection, I reviewed the facility's 2020 - 2023 Comprehensive Site Inspections. I did not note any areas of concern. Record: Other - Routine Monthly Inspection Reports AOC: No Ref #: RA1-RR-007 Reviewed By: Raymond Andrews Reviewed Date: 08/02/2024 At the time of the inspection, I reviewed facility Routine Monthly Inspection Reports from January 2021 through July 2024. I did not note any areas of concern. Record: Other - ADEC Authorization to Discharge Letter AOC: No Ref #: RA1-RR-006 Reviewed By: Raymond Andrews Reviewed Date: 08/23/2024 Post inspection, I reviewed the facility's Authorization to Discharge Letter from the Alaska Department of Environmental Observation (ADEC), dated July 20, 2020. Record: Other - Notice of Intent AOC: No Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Reviewed Date: 08/23/2024 Post inspection, I reviewed the facility's Notice of Intent (NOI), dated July 7, 2020. Record: Annual Reports AOC: No Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 08/02/2024 At the time of the inspection, I reviewed the facility's Annual Reports for 2021 through 2023. I did not note any areas of concern. Record: Other - SWPPP Map AOC: Yes Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 08/02/2024 At the time of inspection, I reviewed the facility's SWPPP map. I found the map was missing the location of stormwater monitoring points. 3 of 7 Alaska Airlines Petersburg Station Permit # AKR06AC00 Record: Other - Quarterly Visual Assessments (QVAs) Ref #: RA1-RR-002 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 08/02/2024 At the time of inspection, I reviewed the facility's QVAs for the previous 16 quarters. The QVAs were not signed in accordance with permit requirements. The facility is required to sample quarterly. In the 1st and 3rd Quarters of 2023, the facility did not collect a sample and annotated on the Quarterly Visual Monitoring Form that there was no qualifying rainfall. The 1st Quarter form was dated January 18, 2023. The 3rd Quarter Form was dated July 11, 2023. January and July are the first months of their respective quarters. The facility did not have QVA documentation for the 3rd and 4th Quarters of 2021. Several of the QVAs were missing one or both photographs required as documentation. The Quarterly visual monitoring forms for two quarters was missing the date. The Quarters missing documentation requirements are listed in the Areas of Concern. Record: SWPPP AOC: Yes Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 08/02/2024 At the time of the inspection, I reviewed the facility's Stormwater Pollution Prevention Plan (SWPPP), dated July 2020. There was no documentation in the SWPPP indicating it has been reviewed or updated annually. 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. AOC Reference #: RA1-RR-002 Records Review: Other - Quarterly Visual Assessments (QVAs) Permit Requirement Part 6.2.2 of the permit states, in part, "The QVAs were not sign in accordance with permit requirements...At a minimum, the permittees documentation of the visual assessment must include...Photographs of sample and sample location...Quarterly Visual Assessment Documentation must be signed and certified in accordance with Appendix A, Subsection 1.12 of the permit." Appendix A, Subsection 1.12 of the permit states, "1.12.5 In accordance with 18 AAC 83.385, an APDES permit application must be signed as follows: Any person signing a document under Appendix A, Part 1.12.2 or Part 1.12.3 shall certify as follows: "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 gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted 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 QVAs were not sign in accordance with permit requirements. 4 of 7 Alaska Airlines Petersburg Station Permit # AKR06AC00 AOC Reference #: RA1-RR-001 Records Review: SWPPP Permit Requirement Part 5.6.5 of the permit states, in part, "The SWPPP must be updated at least annually." AOC: There is nothing in the SWPPP documenting that it has been reviewed or updated annually. AOC Reference #: RA1-RR-002 Records Review: Other - Quarterly Visual Assessments (QVAs) Permit Requirement Part 6.2.1 of the permit states, in part, "Once each calendar quarter for the entire permit term, the permittee must collect a storm water sample from each outfall...and conduct a visual assessment of each of these samples...If no discharge occurs during the quarterly visual assessment period, the permittee must still report no discharge for this monitoring period..." AOC: The facility did not allow the entire quarterly visual assessment period to expire prior to claiming there was no discharge. AOC Reference #: RA1-RR-002 Records Review: Other - Quarterly Visual Assessments (QVAs) Permit Requirement Part 6.2.1 of the permit states, in part, "Once each calendar quarter for the entire permit term, the permittee must collect a storm water sample from each outfall...and conduct a visual assessment of each of these samples...If no discharge occurs during the quarterly visual assessment period, the permittee must still report no discharge for this monitoring period..." AOC: The facility did not have QVA documentation for the 3rd and 4th Quarters of 2021. AOC Reference #: RA1-RR-002 Records Review: Other - Quarterly Visual Assessments (QVAs) Permit Requirement Part 6.2.2 of the permit states, in part, "A permittee must document the results of their visual assessments and maintain this documentation onsite with the SWPPP...At a minimum, the permittees documentation of the visual assessment must include...Sample collection date and time, and visual assessment date and time for each sample...Photographs of sample and sample location..." AOC: Several of the QVAs were missing one or both of the documentation photos and two were missing the date. The Quarters missing photo documentation are 1Q 2023, 1Q & 4Q 2022, and 2Q & 4Q 2023. The Quarters missing the date of collection are 3Q & 4Q 2022. AOC Reference #: RA1-RR-003 Records Review: Other - SWPPP Map Permit Requirement Part 5.2.3.3 of the Permit states, in part, "Provide a map showing...locations of all storm water monitoring points..." AOC: The SWPPP Map was missing the location of stormwater monitoring points. 5 of 7 Alaska Airlines Petersburg Station Permit # AKR06AC00 SECTION VI - Closing Conference I held a closing conference with Facility personnel at 03:35 PM (PT) on 08/02/2024 for the inspection. During the closing conference, I discussed the 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 7 APPENDIX 1: Photo Log All photos were taken by Lead EPA Inspector, Ray Andrews, during the inspection. Photos were not manipulated beyond minor cropping for sizing and labels or callouts to draw attention to the subject of the photo. All photos taken during the inspection are included in the Photo Log; however, only photos that support an Observation or Area of Concern are included in the inspection report. P1020023 - Certification of Urea Non-use P1020024 - SWPPP, De-icing, page 7 P1020025 - Monthly Inspection Report, dated July 25, 2024, page 1 P1020026 - Monthly Inspection Report, dated July 25, 2024, page 2 P1020027 - Quarterly Visual Assessment, dated May 20, 2023 P1020028 - Quarterly Visual Assessment, dated January 18, 2023