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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 06/28/2024 09:00 AM (PT) Announced: Yes 06/28/2024 02:20 PM (PT) Access: Granted 56F, Overcast Water Clean Water Act, NPDES, Stormwater - Industrial Compliance Evaluation Inspection Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code Borough Facility GPS Coordinates Mailing Address City, State, Zip Code Ronald Miller - City & Borough of Wrangell Wrangell Marine Service Center 525 Front Street Wrangell, Alaska 99929 Wrangell 56.468771, -132.380247 P.O. Box 531 Wrangell, Alaska 99929 FRS ID Permit Number SIC 110070517615 AKR06AD53 3731 (Ship Building & Repairing) 3732 (Boat Building & Repairing) Lead Inspector: RAYMOND ANDREWS Date: 2024.08.14 13:44:54 -07'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2024.08.14 14:34:14 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA Region 10 contreras.peter@epa.gov (206) 553-6708 Wrangell Marine Service Center NPDES # AKR06AD53 SECTION I - Opening Conference Site Entry and Inspection Objectives I arrived at the Wrangell Marine Service Center (the "Site" or "Facility"), located at 525 Front Street, Wrangell, Alaska, at 09:00 AM (PT) on 06/28/2024 for an announced inspection. I presented my credentials to Steve Miller and informed him I was there to determine compliance with the Clean Water Act (CWA), and the facility's National Pollutant Discharge Elimination System (NPDES) permit, permit # AKR06AD53. 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 City of Wrangell Steve Miller Harbor Master Yes Yes Site Information Responsible official? Steve Miller Type of Operation? Harbor Size of Facility Approximately 5 acres Is property owned or The property is owned by the City of Wrangell. leased? Years in operation? The Harbor has been in operation since approximately 2007. Industrial Sector? Sector R - Ship and Boat Building and Repair Yards Number of employees? The facility has seven employees working seven days a week from 7am until 11:30pm. Is the SWPPP team present? The only member of the SWPPP Team present is Mr. Miller. Receiving Water Zimovia Straight Personnel conducting Mr. James Early, Marine Service Center Team Leader, was previously the primary inspections/sampling? inspector and sample collector. Mr. Early left his position approximately a week before the inspection. Mr. Miller also conducts inspections and sampling. Sampling locations Sector R facilities are only required to perform Quarterly Visual Assessments (QVAs). QVAs are always done at outfalls 1 through 4. Outfall 5 is frequently underwater and cannot be sampled. How many Stormwater The site has approximately 26 catch basins, and a total of five outfalls. Outfalls 1 Inlets and Outfalls through 3 are along the shoreline approximately 20 feet apart. Outfalls 2 and 3 does the site have? are concealed in the shore rocks and not easily visualized. BMPs and Stormwater All catch basins are fitted with filter inserts. Stormwater collected by the catch Treatment? basins passes through one of several oil/water separators located around the site prior to discharge. 2 of 7 Wrangell Marine Service Center NPDES # AKR06AD53 Industrial activities exposed to stormwater? Boat repairs are conducted both under cover and in the open with exposure to stormwater. Type of materials Boats awaiting, or undergoing, repair are stored both on the site's asphalt or on and/or vehicles stored the water. outdoors? SECTION II - Observations No observations were made during the site tour that constitute an area of concern. SECTION III - Records Review Records may not be in sequential order. Record: Other - SWPPP Maps AOC: No Ref #: RA1-RR-015 Reviewed By: Raymond Andrews Reviewed Date: 08/08/2024 Post inspection, I reviewed the SWPPP maps required by the permit. The General Location Map met the requirements of the permit. The Site Map was missing a few requirements which are listed in the Areas of Concern. Record: SWPPP AOC: Yes Ref #: RA1-RR-014 Reviewed By: Raymond Andrews Reviewed Date: 08/08/2024 Post-inspection, I conducted an in-depth review of the facility's updated Stormwater Pollution Prevention Plan (SWPPP), dated July 27, 2020. The SWPPP was not signed and certified as required by Appendix A, Section 1.12.5 of the permit. Several deficiencies I observed during the on-site review of the SWPPP were corrected prior to this post-inspection review of an updated SWPPP. The SWPPP has sections for "Schedules and Procedures for Monitoring", "Good Housekeeping", "Maintenance", "Spill Prevention and Response Procedures", and "Employee Training". The sections of the SWPPP for Schedules and Procedures of Monitoring, Spill Prevention & Spill Response, and Employee Training meet permit requirements; however, the sections of the SWPPP covering Good Housekeeping and Maintenance do not include a schedule of activities. There was no documentation in the SWPPP showing it has been reviewed and updated annually as required by the permit. Record: Other - Comprehensive Site Inspections AOC: Yes Ref #: RA1-RR-013 Reviewed By: Raymond Andrews Reviewed Date: 08/07/2024 At the time of the inspection, I requested Comprehensive Site Inspections from 1Q 2020 through 2Q 2024. None of the Comprehensive Site Inspection Reports were signed and certified in accordance with Appendix A, Subsection 1.12 of the permit. Record: Other - Quarterly Visual Assessments (QVAs) AOC: Yes Ref #: RA1-RR-012 Reviewed By: Raymond Andrews Reviewed Date: 08/07/2024 Post-inspection, I requested Quarterly Visual Assessments (QVAs) from 1Q 2020 through 2Q 2024, for a more thorough review. The QVAs for 2Q and 3Q 2020 were missing. None of the QVAs I reviewed had the required photo documentation attached. 3 of 7 Wrangell Marine Service Center NPDES # AKR06AD53 Record: Other - Routine Facility Inspections Ref #: RA1-RR-011 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 08/07/2024 At the time of the inspection, I requested Routine Facility Inspections from 1Q 2020 through 2Q 2024. The facility was missing a report for 1Q 2020. The 2Q 2020 report was missing the date and time of inspection, and the inspector's name and title. Record: Other - Employee Training Records AOC: No Ref #: RA1-RR-010 Reviewed By: Raymond Andrews Reviewed Date: 08/07/2024 Post-inspection, I reviewed personnel training records for 2020 through 2023. I did not note any areas of concern. Record: Other - EPA's Integrated Compliance Information System (ICIS) Database AOC: No Ref #: RA1-RR-009 Reviewed By: Raymond Andrews Reviewed Date: 06/26/2024 Pre-inspection, I reviewed a deficiencies report from EPA's ICIS database covering June 2019 through May 2024. I did not note any areas of concern. Record: Annual Reports AOC: No Ref #: RA1-RR-008 Reviewed By: Raymond Andrews Reviewed Date: 06/28/2024 At the time of the inspection, I requested the facility's Annual Reports for 2021 through 2023. The facility produced the requested reports. I did not note any areas of concern. Record: Other - Routine Quarterly Inspection Reports AOC: No Ref #: RA1-RR-007 Reviewed By: Raymond Andrews Reviewed Date: 06/28/2024 At the time of the inspection, I reviewed routine quarterly inspection reports covering 2021 thought 2023. I did not note any Areas of Concern. Record: Other - Quarterly Visual Inspections (QVIs) AOC: Yes Ref #: RA1-RR-006 Reviewed By: Raymond Andrews Reviewed Date: 06/28/2024 At the time of the inspection, I reviewed QVIs from 2021 through 2023. None of the QVIs had the required photographic documentation. Record: Other - Employee Training Records AOC: Yes Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Reviewed Date: 06/28/2024 At the time of the inspection, I requested to review employee training documentation for the years 2021 2023. The facility could not produce training records for 2023. Record: Other - SWPPP Site Map AOC: Yes Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 06/28/2024 At the time of inspection, I reviewed the site's SWPPP map. The map was missing: the size of the property in acres, locations of all storm water monitoring points (Monitoring points are co-located with discharge points but they do not have an identifying designator), vehicle and equipment maintenance and/or cleaning areas. 4 of 7 Wrangell Marine Service Center NPDES # AKR06AD53 Record: SWPPP Ref #: RA1-RR-003 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 06/28/2024 At the time of the inspection, I reviewed the facility's SWPPP, dated January 30, 2020. The cover page of the SWPPP had the incorrect SWPPP Contact. SWPPP team in the SWPPP needs to be updated. Two members listed as part of the SWPPP Team are no longer employed by the facility. Record: Other - ADEC Authorization to Discharge AOC: No Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 06/28/2024 At the time of the inspection, I reviewed the sites authorization to discharge, dated November 9, 2020. The authorization only lists 3 outfalls. Record: Notice of Intent AOC: No Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 06/28/2024 At the time of inspection, I reviewed the site's Notice of Intent (NOI) to gain coverage under the APDES MSGP, dated October 8, 2020. The NOI lists 3 outfalls, but Mr. Miller said the site has 5 outfalls. The SWPPP map also indicates there are 5 outfalls. Post inspection, Mr. Miller provided me a copy of an NOI update, dated October 23, 2020, that included the two outfalls listed in the original NOI. SECTION IV - Sampling Activity 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-004 Records Review: Other - SWPPP Site Map Permit Requirement Part 5.2.3.3 of the permit states, in part, "Site map. Provide a map showing...the size of the property in acre...locations of all storm water monitoring points...vehicle and equipment maintenance and/or cleaning areas..." AOC: The map was missing: the size of the property in acres, locations of all storm water monitoring points (Monitoring points are co-located with discharge points but they do not have an identifying designator), vehicle and equipment maintenance and/or cleaning areas. AOC Reference #: RA1-RR-005 Records Review: Other - Employee Training Records Permit Requirement Part 4.2.9 of the permit states, in part, "A permittee must train all employees who work in areas where industrial materials or activities are exposed to storm water, or who are responsible for implementing activities necessary to meet the conditions of this permit... including all members of the permittee's Pollution Prevention Team...Training shall be conducted at least annually (or more often if employee turnover is high) and documented in the SWPPP." AOC: At the time of the inspection, the facility could not produce training records for 2023. Post inspection, the facility sent me a copy of the training records for 2023. 5 of 7 Wrangell Marine Service Center NPDES # AKR06AD53 AOC Reference #: RA1-RR-011 Records Review: Other - Routine Facility Inspections Permit Requirement Part 6.1.1 of the permit states, in part, "Inspections must be conducted at least quarterly (i.e., once each permit quarter)..." AOC: The facility was missing the Routine Facility Inspection Report for 1Q 2020. AOC Reference #: RA1-RR-011 Records Review: Other - Routine Facility Inspections Permit Requirement Part 6.1.2 of the permit states, in part, "A permittee must document the findings of each routine facility inspection performed and maintain this documentation onsite with the SWPPP...At a minimum, the permittees documentation of each routine facility inspection must include...The inspection date and time...The name(s) and signature(s) of the inspector(s)..." AOC: The 2Q 2020 report was missing the date and time of inspection, and the inspector's name and title. AOC Reference #: RA1-RR-012 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." AOC: The QVAs for 2Q and 3Q 2020 were missing. AOC Reference #: RA1-RR-012 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...(a)t a minimum, the permittees documentation of the visual assessment must include...Photographs of sample and sample location..." AOC: None of the QVAs had the required photo documentation attached. AOC Reference #: RA1-RR-013 Records Review: Other - Comprehensive Site Inspections Permit Requirement Part 6.3.2 of the permit states, in part, "At a minimum, the permittees documentation of the comprehensive site inspection must include...A statement, signed and certified in accordance with Appendix A, Subsection 1.12 of the permit." Appendix A, Subsection 1.12.5 of the permit states, in part, "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..." AOC: None of the Comprehensive Site Inspection Reports were signed and certified in accordance with Appendix A, Subsection 1.12 of the permit. 6 of 7 Wrangell Marine Service Center NPDES # AKR06AD53 AOC Reference #: RA1-RR-014 Records Review: SWPPP Permit Requirement Part 5.2.7 of the permit states, "A permittee must sign and date the SWPPP in accordance with Appendix A, Subsection 1.12, including the date of signature." Appendix A, Section 1.12.5 of the permit states, "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..." AOC: The SWPPP was not signed and certified as required by Appendix A, Section 1.12.5 of the permit. Part 5.2.7 of the permit states, "A permittee must sign and date the SWPPP in accordance with Appendix A, Subsection 1.12, including the date of signature." AOC Reference #: RA1-RR-014 Records Review: SWPPP Permit Requirement Part 5.2.6.1 of the permit states, in part, "The following must be documented in the SWPPP... Good Housekeeping - A schedule for regular pickup and disposal of waste materials, along with routine inspections for leaks and conditions of drums, tanks and containers... Maintenance - Preventative maintenance procedures, including regular inspections, testing, maintenance, and repair of all industrial equipment and systems, and control measures, to avoid situations that may result in leaks, spills, and other releases, and any back-up practices in place should a runoff event occur while a control measure is off-line. The SWPPP shall include the schedule or frequency for maintaining all control measures used to comply with the effluent limits in Part 4..." AOC: The SWPPP does not include schedules for Good Housekeeping activities or Maintenance. AOC Reference #: RA1-RR-003/014 Records Review: SWPPP Permit Requirement Part 5.6.5 of the permit states, in part, "The SWPPP must be updated at least annually." AOC: The SWPPP has not been reviewed or updated annually. SECTION VI - Closing Conference I held a closing conference with Facility personnel at 02:20 PM (PT) on 06/28/2024 for the inspection. During the closing conference, I discussed the observations and Areas of Concern I 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 7 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. P1010996 - Boats undergoing Repairs, photo1 P1010997 - Boats undergoing Repairs, photo2 P1010998 - Boats undergoing Repairs, photo3 P1010999 - Boat being Repaired under Cover P1020001 - Outfall 1, photo 1 P1020002 - Outfall 1, photo 2 P1020003 - Outfalls 2 and 3, concealed in rocks, photo 1 P1020004 - Boat Wash P1020005 - Boat Wash and Catch Basin (Near ground) P1020006 - Outfall 4