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on siteto clean it out and suggested a range of options to repair the BMP before using it again. We also discussed moving this BMP to an upland area above the drainage ditch.

ADOT/Fisher is also working on SR 179 above Morgan Wash, which flows less than ¼ mile to Oak Creek. We observed evidence of storm water pooling across the highway at this location. According to ADOT/Fisher, this storm water is pumped and discharged into a small filtering basin built into the slope above Morgan Wash (see Photos 0078-79). We did not observe any pumping or discharging during the inspection, but the filtering area appeared to be undersized. Additionally, water discharged from this area and the small filtering basin will cross disturbed soil before entering Morgan Wash (see Photo 0079).

Good Housekeeping: ADOT/Fisher indicated that all concrete washout occurs in small plastic kiddie-pools. When I pointed out a concrete wash-water spill at the bridge site, Harris stated that it probably resulted from moving the kiddie-pool before the concrete had set (see Photo 0038). We visited three staging yards: 1) Chapel, 2) Morgan, and 3) Highland. ADOT/Fisher treats the pumped drill water from the Oak Creek bridge site at the Chapel staging yard (see earlier discussion). We observed several unlabelled 5-gallon buckets of oily waste that were not stored within secondary containment at the Morgan staging yard (see Photo 0071). According to Harris, previously there had been a roll-off container where contaminated sediments were placed. Additionally, there were small containers (daily use) of gasoline, oils and other chemicals scattered throughout the yard, not placed under cover or in secondary containment (see Photo 0074). Self- inspection reports dating back to at least May, 24, 2008 indicate issues similar to what I observed for storage of daily use materials. We observed staining on the ground and there was no spill kit readily available (see Photo 0073). ADOT/Fisher did not have a key to unlock the Highland Yard so we did not inspect that area.

Paperwork: I reviewed the SWPPP on-site. ADOT’s copy of the SWPPP was on site; however Fisher’s copy was not. I requested a copy of Fisher’s SWPPP to be sent to EPA and it was received on February 23, 2010. A review of the inspection reports sent to EPA on February 23, 2010 indicates there may be problems with the inspections. For instance, we inspected the site on February 5, 2010 and noted the above problems. ADOT/Fisher also conducted a weekly inspection of the site on February 5, 2010. The inspector certified that the site was “in compliance with the SWPPP and Permit No. ASG2008-001,” with the exception of some relatively minor BMP issues. The site inspector did not mention any problems with pump water discharge at the Chapel staging yard, the Garland slope BMPs, or the coffer dam. From the inspection report it is not apparent that the inspector even visited the Chapel staging yard.

A review of the paperwork indicates ADOT/Fisher may have problems with how and when BMPs issues are corrected. For instance, on January 8, 2010 the inspector noted that “old concrete wash out” spills needed to be removed from the Morgan Yard. The inspector ‘verified’ that this was corrected on January 15, 2010 by dating and initialing the form. This same “corrective action” was needed at each of the next four inspections until finally on January 29, 2010, the “corrective action” was changed to


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