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January 19, 2016 James Travis, Mill Manager West Fraser, Inc. PO
Box 39 Mansfield, AR 72944 RE: Mansfield, a Division of West
Fraser, Inc. Inspection (Scott Co) AFIN: 64-00049 NPDES Permit No.:
AR0048232 Dear Mr. Travis: On December 29, 2015, I performed a
Compliance Evaluation Inspection and an Industrial Stormwater
Inspection of the above-referenced facility in accordance with the
provisions of the Federal Clean Water Act, the Arkansas Water and
Air Pollution Control Act, and the regulations promulgated
thereunder. Copies of the inspection reports are enclosed for your
records. Please refer to the “Summary of Findings” section of each
of the attached inspection reports and provide a written response
for each violation that was noted. This response should be mailed
to the attention of the Water Division Inspection Branch at the
address at the bottom of this letter or e-mailed to
[email protected]. This response should
contain documentation describing the course of action taken to
correct each item noted. This corrective action should be completed
as soon as possible, and the written response with all necessary
documentation (i.e., photos) is due by February 5, 2016. If I can
be of any assistance, please contact me at [email protected]
or (501) 682-0642. Sincerely,
Kerri McCabe Inspector Supervisor Water Division cc: James
Travis, Mill Manager, West Fraser, Inc.,
[email protected] Joey Henderson, EHS Supervisor, West
Fraser, Inc., [email protected]
mailto:[email protected]:[email protected]:[email protected]:[email protected]
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 2 of 15
WATER DIVISION INSPECTION REPORT AFIN: 64-00049 PERMIT #:
AR0048232 DATE: 12/29/2015 COUNTY: 64 Scott PDS #: 088659 MEDIA: WN
GPS LAT: 35.063448 LONG: -94.244634 LOCATION: Entrance
FACILITY INFORMATION INSPECTION INFORMATION NAME:
Mansfield, a Division of West Fraser, Inc. LOCATION:
700 Hwy 71 South CITY:
Mansfield, AR
FACILITY TYPE:
2 - Industrial INSPECTOR ID#:
84022 S - State FACILITY EVALUATION RATING:
2 - Marginal INSPECTION TYPE:
Compliance Evaluation DATE(S): ENTRY TIME: EXIT TIME:
12/29/2015 09:45 14:00
PERMIT EFFECTIVE DATE:
2/1/2010 PERMIT EXPIRATION DATE:
1/31/2017 RESPONSIBLE OFFICIAL
NAME: / TITLE
James Travis / Mill Manager COMPANY: West Fraser, Inc. MAILING
ADDRESS:
PO Box 39 CITY, STATE, ZIP: Mansfield AR 72944 PHONE & EXT:
/ FAX:
479-928-4446 / EMAIL:
[email protected]
FAYETTEVILLE SHALE RELATED: N FAYETTEVILLE SHALE VIOLATIONS:
N
INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/EMAIL/ETC.:
James Travis/Mill Manager/(479)
928-4446/[email protected] Joey Henderson/EHS
Supervisor/(479) 928-4446/[email protected] Alana
Sullivan/District 4 Water Inspector
CONTACTED DURING INSPECTION: Yes AREA EVALUATIONS
(S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not
Applicable/Evaluated) S PERMIT U FLOW MEASUREMENT N STORMWATER M
RECORDS/REPORTS S LABORATORY M FACILITY SITE REVIEW M OPERATION
& MAINTENANCE M EFFLUENT/RECEIVING WATER M SELF-MONITORING
PROGRAM M SAMPLING M SLUDGE HANDLING/DISPOSAL N PRETREATMENT **
OTHER:
SUMMARY OF FINDINGS The following violations were noted during
the inspection: 1.) Flow is not being measured at the
frequency/type specified in the permit. Personnel are monitoring
flow one month out of the quarter and reporting qualitative
readings. The only flow data being supplied on DMRs are measured
and reported when the contract lab collects samples of the
discharge. This is a violation of Part I, Section A of the permit.
Flow is to be monitored/measured five times per week and reported
quantitatively in MGD. The type is “instantaneous,” which requires
a means of measuring head and utilizing a formula to calculate
flow. 2.) Two Total Suspended Solids (TSS) samples were collected
in November, 2015 (November 5 and 16). The Monthly Average and
Daily Max for TSS effluent limitations were exceeded for the
quarter (see DMR calculation sheet). This is a violation of Part I,
Section A of the permit. A Non-Compliance Report (NCR) is due to
the Department with the 4Q 2015 DMR by Jan 25, 2016. 3.) The
two-stage recirculating system utilized for wastewater treatment
consists of two ponds. The depth of solids (mainly sediment) is
unknown in the two ponds. Accumulation of solids in the ponds
reduces retention time and design volume. This is a violation of
Part II, Condition #3 of the permit. Solids accumulation should be
managed to reduce pollution to waters of the State. 4.) The two
ponds of the treatment system did not have adequate freeboard. This
is a violation of Part II, Condition #5 of the permit. 5.) The
following items violate Part III, Section B.1.A of the permit:
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 3 of 15
• Vegetation and debris are built up in the outfall structure.
The structure needs to be clean and free of vegetation/debris.
• Pond levees show signs of erosion particularly around the
truck/equipment wash area. Levees need to be protected to reduce
erosion.
6.) The Dissolved Oxygen (DO) sample for June 17, 2015 exceeded
holding time. Per 40 CFR 136, DO is to be analyzed “immediately.”
This is a violation of Part III, Section C.3 of the permit. The
permittee needs to instruct the contract lab to utilize a field DO
meter during sample collection or the permittee needs to purchase a
DO meter for onsite analysis. 7.) The permittee did not have all
required records onsite for review. Specifically, there were no
Chain of Custody (COC) forms or lab analyses sheets provided by the
contract lab. This is a violation of Part III, Section C.7 of the
permit. The permittee has requested all required records from the
contract lab and has supplied the requested documents to the
inspector. The permittee must retain three (3) years of records
onsite per Part III, Section C.7 of the permit. No further response
required for this item. 8.) The contract lab is not completely
filling out the COC forms with the information required by Part
III, Section C.8.A – F of the permit. Specifically, the June 17,
2015 COC is missing “exact place” and the November 5, 2015 COC is
missing “individual who performed the sampling/measuring,”
“preservatives,” and “sample matrix.” This is a violation of Part
III, Section C.8 of the permit. Also, the permittee will need to
review this section for records maintained onsite for flow and
debris and incorporate any missing information into applicable
forms. Please be advised that a DO sample was not collected or
analyzed for in November, 2015 with the other sample parameters.
Failure to sample/analyze for DO for 4Q 2015 is a violation of Part
I, Section A of the permit. Permittee needs to update the contact
information for the permit. Specifically, mailing address and
contact phone number. Please submit updates and corrected
information to the Water Division Permits Branch at
[email protected].
mailto:[email protected]
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 4 of 15
GENERAL COMMENTS On Tuesday, Dec 29, 2015 I met with the
above-mentioned inspection participants to conduct inspections of
the facility’s wastewater treatment pond and industrial stormwater
program (separate report). Inspection consisted of a site
assessment and a records review. Site assessment: Treatment
consists of a two-stage recirculating system with a recirculating
pond (0.023 acre; surface area) and a sedimentation pond (1.0 acre;
surface area). Waste streams consist of wet-deck runoff, boiler
blowdown, boiler water softener backwash, equipment wash water, and
stormwater. A permit modification request was received by the
Department Oct 2015 for the addition to discharge kiln condensate
from the permitted outfall. The wastewater treatment system has
primarily been used for stormwater runoff, and Mr. Travis stated
that the wet-deck has not been used to wet stored lumber in several
years. However, there are plans to begin utilizing the wet-deck in
early 2016. The treatment system has no freeboard and was
discharging via Outfall 001 during the inspection, and the depth of
solids (mainly sediment) in the ponds is unknown. Vegetation of the
levees was controlled, but erosion rills/gullies were noted along
the interior levees. The outfall structure consists of a trapezoid
weir plate with a 4” PVC pipe installed below the plate. Discharge
from both the weir plate and PVC pipe flows to two rectangular weir
plates downstream, which then flows to a manmade conveyance
converging with Coop Creek. There was no staff gauge mounted at the
outfall structure, and the contract lab is measuring head from the
4” PVC pipe and using it in conjunction with the Manning formula.
Records review: Flow is not being measured at the frequency/type as
outlined in Part I, Section A of the permit. Personnel are using a
flow sheet one month out of the quarter and using a check mark to
indicate qualitative flow (check mark means “yes” and line through
space means “no”). Debris is also being measured like this. There
were no Chains of Custody (COCs) or lab analyses sheets available
for review; however, Mr. Henderson contacted the lab and supplied
the requested documents. There were minor issues noted with the
contract lab’s COCs.
INSPECTOR’S SIGNATURE: Kerri McCabe DATE: 1/19/2016
SUPERVISOR’S SIGNATURE: Jason Bolenbaugh DATE:
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 5 of 15
SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES
OBSERVATIONS S M U NA NE DETAILS: 1. CORRECT NAME AND MAILING
ADDRESS OF PERMITTEE: Need to update mailing address to PO Box 39,
Mansfield, AR 72944. Y N NA NE 2. NOTIFICATION GIVEN TO EPA/STATE
OF NEW DIFFERENT OR INCREASED DISCHARGES: Increase from kiln
condensate (Oct 2015). Y N NA NE 3. NUMBER AND LOCATION OF
DISCHARGE POINTS AS DESCRIBED IN PERMIT: Y N NA NE 4. ALL
DISCHARGES ARE PERMITTED: Y N NA NE
SECTION B: RECORDKEEPING AND REPORTING EVALUATION RECORDS AND
REPORTS MAINTAINED AS REQUIRED BY PERMIT S M U NA NE DETAILS:
Facility uses contract lab for all sampling, analyses, and DMR
reporting; all records from contract lab need to remain at
facility. 1. ANALYTICAL RESULTS CONSISTENT WITH DATA REPORTED ON
DMRS: Y N NA NE 2. SAMPLING AND ANALYSES DATA ADEQUATE AND INCLUDE:
S M U NA NE
a. DATES AND TIME(S) OF SAMPLING: Y N NA NE b. EXACT LOCATION(S)
OF SAMPLING: Y N NA NE c. NAME OF INDIVIDUAL PERFORMING SAMPLING: Y
N NA NE d. ANALYTICAL METHODS AND TECHNIQUES: Y N NA NE e. RESULTS
OF CALIBRATIONS: Y N NA NE f. RESULTS OF ANALYSES: Y N NA NE g.
DATES AND TIMES OF ANALYSES: Y N NA NE h. NAME OF PERSON(S)
PERFORMING ANALYSES: Y N NA NE
3. LABORATORY EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS
ADEQUATE: S M U NA NE 4. PLANT RECORDS INCLUDE SCHEDULES, DATES OF
EQUIPMENT MAINTENANCE AND REPAIR: S M U NA NE 5. EFFLUENT LOADINGS
CALCULATED USING DAILY EFFLUENT FLOW AND DAILY ANALYTICAL DATA: Y N
NA NE
SECTION C: OPERATIONS AND MAINTENANCE TREATMENT FACILITY
PROPERLY OPERATED AND MAINTAINED S M U NA NE DETAILS: Two-stage
recirculating system; recirculating pond and sedimentation pond. 1.
TREATMENT UNITS PROPERLY OPERATED: S M U NA NE 2. TREATMENT UNITS
PROPERLY MAINTAINED: Solids depth is unknown in both ponds;
inadequate depth can result in short-
circuiting and reduced retention time. Flow from recirculating
pond is directly in front of outfall structure in sedimentation
pond.
S M U NA NE
3. STANDBY POWER OR OTHER EQUIVALENT PROVIDED: No mechanical
parts. S M U NA NE 4. ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT
FAILURES AVAILABLE: S M U NA NE 5. ALL NEEDED TREATMENT UNITS IN
SERVICE: S M U NA NE 6. ADEQUATE NUMBER OF QUALIFIED OPERATORS
PROVIDED: S M U NA NE 7. SPARE PARTS AND SUPPLIES INVENTORY
MAINTAINED: S M U NA NE 8. OPERATION AND MAINTENANCE MANUAL
AVAILABLE: Y N NA NE 9. STANDARD OPERATING PROCEDURES AND SCHEDULES
ESTABLISHED: Y N NA NE 10. PROCEDURES FOR EMERGENCY TREATMENT
CONTROL ESTABLISHED: Must maintain freeboard; ponds above freeboard
limit. Y N NA NE 11. HAVE BYPASSES/OVERFLOWS OCCURRED AT THE PLANT
OR IN THE COLLECTION SYSTEM IN THE LAST YEAR: Y N NA NE 12. IF SO,
HAS THE REGULATORY AGENCY BEEN NOTIFIED: Y N NA NE 13. HAS
CORRECTIVE ACTION BEEN TAKEN TO PREVENT ADDITIONAL
BYPASSES/OVERFLOWS: Y N NA NE 14. HAVE ANY HYDRAULIC OVERLOADS
OCCURRED AT THE TREATMENT PLANT: Y N NA NE 15. IF SO, DID PERMIT
VIOLATIONS OCCUR AS A RESULT: Y N NA NE
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 6 of 15
SECTION D: SAMPLING PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS
S M U NA NE DETAILS: Contract lab conducts all sampling, analyses,
and reporting of DMRs. 1. SAMPLES TAKEN AT SITE(S) SPECIFIED IN
PERMIT: Y N NA NE 2. LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES:
Y N NA NE 3. FLOW PROPORTIONED SAMPLES OBTAINED WHEN REQUIRED BY
PERMIT: Y N NA NE 4. SAMPLING AND ANALYSES COMPLETED ON PARAMETERS
SPECIFIED IN PERMIT: No DO for Nov 2015. Y N NA NE 5. SAMPLING AND
ANALYSES PERFORMED AT FREQUENCY SPECIFIED IN PERMIT: Flow is not
being monitored or sampled at
frequency/type specified in permit; facility personnel is
monitoring one month out of the quarter and not reporting by
quantitative means.
Y N NA NE
6. SAMPLE COLLECTION PROCEDURES ADEQUATE: Y N NA NE a. SAMPLES
REFRIGERATED DURING COMPOSITING: Y N NA NE b. PROPER PRESERVATION
TECHNIQUES USED: Y N NA NE c. CONTAINERS AND SAMPLE HOLDING TIMES
CONFORM TO 40 CFR 136: DO for June 2015 exceeded holding time
of
“instantaneous.” Y N NA NE 7. IF MONITORING IS PERFORMED MORE
OFTEN THAN REQUIRED ARE RESULTS REPORTED ON THE DMR: TSS collected
twice
for Nov 2015; DMR is due by Jan 25, 2016. Y N NA NE
SECTION E: FLOW MEASUREMENT PERMITTEE FLOW MEASUREMENT MEETS
PERMIT REQUIREMENTS S M U NA NE DETAILS: Permittee is not measuring
flow at frequency/type specified; recording is not quantitative. 1.
PRIMARY FLOW MEASUREMENT DEVICE PROPERLY INSTALLED AND MAINTAINED:
N TYPE OF DEVICE: Trapezoid weir
(length unknown); 4” PVC pipe; rectangular weir with end
contractions (length unknown); rectangular weir w/o end
contractions (length unknown); no staff gauge. Vegetation/debris in
weir boxes.
Y N NA NE
2. FLOW MEASURED AT EACH OUTFALL AS REQUIRED: Flow is being
measured by contract lab when collecting samples; not at
frequency/type specified in permit. Y N NA NE
3. SECONDARY INSTRUMENTS (TOTALIZERS, RECORDERS, ETC.) PROPERLY
OPERATED AND MAINTAINED: Y N NA NE 4. CALIBRATION FREQUENCY
ADEQUATE: Y N NA NE 5. RECORDS MAINTAINED OF CALIBRATION
PROCEDURES: Y N NA NE 6. CALIBRATION CHECKS DONE TO ASSURE
CONTINUED COMPLIANCE: Y N NA NE 7. FLOW ENTERING DEVICE WELL
DISTRIBUTED ACROSS THE CHANNEL AND FREE OF TURBULENCE:
Vegetation/debris in weir
boxes. Y N NA NE 8. FLOW MEASUREMENT EQUIPMENT ADEQUATE TO
HANDLE EXPECTED RANGE OF FLOW RATES: Need to install staff gauge
at
each primary device. Y N NA NE
9. HEAD MEASURED AT PROPER LOCATION: Head measured at 4” PVC
pipe; calculate flow (cfs) using Manning equation. Y N NA NE
SECTION F: LABORATORY PERMITTEE LABORATORY PROCEDURES MEET
PERMIT REQUIREMENTS S M U NA NE DETAILS: Contract lab conducts all
sampling, analyses, and reporting of DMRs. 1. EPA APPROVED
ANALYTICAL PROCEDURES USED (40 CFR 136.3 FOR LIQUIDS, 503.8(B) FOR
SLUDGES): DO for June 2015
exceeded holding time. Y N NA NE
2. IF ALTERNATIVE ANALYTICAL PROCEDURES ARE USED, PROPER
APPROVAL HAS BEEN OBTAINED: Y N NA NE 3. SATISFACTORY CALIBRATION
AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT: Y N NA NE 4. QUALITY
CONTROL PROCEDURES ADEQUATE: Y N NA NE 5. DUPLICATE SAMPLES ARE
ANALYZED >10% OF THE TIME: Y N NA NE 6. SPIKED SAMPLES ARE
ANALYZED >10% OF THE TIME: Y N NA NE 7. COMMERCIAL LABORATORY
USED: Y N NA NE
a. LAB NAME: Data Testing, Inc.
b. LAB ADDRESS: 3434 Country Club, Fort Smith, AR 72903
c. PARAMETERS PERFORMED: Flow, COD, TSS, Temp, Debris, DO,
O&G, and pH
8. BIOMONITORING PROCEDURES ADEQUATE: Y N NA NE a. PROPER
ORGANISMS USED: Y N NA NE b. PROPER DILUTION SERIES FOLLOWED: Y N
NA NE c. PROPER TEST METHODS AND DURATION: Y N NA NE d. RETESTS
AND/OR TRE PERFORMED AS REQUIRED: Y N NA NE
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 7 of 15
SECTION G: EFFLUENT/RECEIVING WATERS OBSERVATIONS BASED ON
VISUAL OBSERVATIONS ONLY S M U NA NE DETAILS: Discharging from 4”
PVC pipe below trapezoid weir; low flow. OUTFALL #: OIL SHEEN
GREASE TURBIDITY VISIBLE FOAM FLOATING SOLIDS COLOR OTHER
001 NO NO YES NO YES BROWN LOW FLOW
SECTION H: SLUDGE DISPOSAL SLUDGE DISPOSAL MEETS PERMIT
REQUIREMENTS S M U NA NE DETAILS: Depth of solids (mainly sediment)
is unknown; can affect retention time and design volume. 1. SLUDGE
MANAGEMENT ADEQUATE TO MAINTAIN EFFLUENT QUALITY: S M U NA NE 2.
SLUDGE RECORDS MAINTAINED AS REQUIRED BY 40 CFR 503: S M U NA NE 3.
FOR LAND APPLIED SLUDGE, TYPE OF LAND APPLIED TO: (E.G., FOREST,
AGRICULTURAL, PUBLIC CONTACT SITE): N/A
SECTION I: SAMPLING INSPECTION PROCEDURES SAMPLE RESULTS WITHIN
PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. SAMPLES OBTAINED THIS
INSPECTION: Y N NA NE 2. TYPE OF SAMPLE: GRAB: COMPOSITE: METHOD:
FREQUENCY: 3. SAMPLES PRESERVED: Y N NA NE 4. FLOW PROPORTIONED
SAMPLES OBTAINED: Y N NA NE 5. SAMPLE OBTAINED FROM FACILITY'S
SAMPLING DEVICE: Y N NA NE 6. SAMPLE REPRESENTATIVE OF VOLUME AND
NATURE OF DISCHARGE: Y N NA NE 7. SAMPLE SPLIT WITH PERMITTEE: Y N
NA NE 8. CHAIN-OF-CUSTODY PROCEDURES EMPLOYED: Y N NA NE 9. SAMPLES
COLLECTED IN ACCORDANCE WITH PERMIT: Y N NA NE
SECTION J: STORM WATER POLLUTION PREVENTION PLAN STORM WATER
MANAGEMENT MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: Part II,
Condition #3 requires BMPs; stormwater inspected under ARR00A473.
1. SWPPP UPDATED AS NEEDED: DATE OF LAST UPDATE: Y N NA NE 2. SITE
MAP INCLUDING ALL DISCHARGES AND SURFACE WATERS: Y N NA NE 3.
POLLUTION PREVENTION TEAM IDENTIFIED: Y N NA NE 4. POLLUTION
PREVENTION TEAM PROPERLY TRAINED: Y N NA NE 5. LIST OF POTENTIAL
POLLUTANT SOURCES: Y N NA NE 6. LIST OF POTENTIAL SOURCES AND PAST
SPILLS AND LEAKS: Y N NA NE 7. ALL NON-STORM WATER DISCHARGES ARE
AUTHORIZED: Y N NA NE 8. LIST OF STRUCTURAL BMPS: Y N NA NE 9. LIST
OF NON-STRUCTURAL BMPS: Y N NA NE 10. BMPS PROPERLY OPERATED AND
MAINTAINED: Y N NA NE 11. INSPECTIONS CONDUCTED AS REQUIRED: Y N NA
NE
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 8 of 15
DMR Calculation Check
Reporting Period: From 2015 04 01 To 2015 06 30 Year Month Day
Year Month Day
Parameter Checked: Oil & Grease
Loading Concentration Mass (lbs/day) (mg/L) Mo Avg / Daily Max
Mo Avg Daily Max
Reported Value:
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 9 of 15
DMR Calculation Check
Reporting Period: From 2015 10 01 To 2015 12 31 Year Month Day
Year Month Day
Parameter Checked: TSS
Loading Concentration Mass (lbs/day) (mg/L) Mo Avg / Daily Max
Mo Avg Daily Max
Reported Value: N/A / N/A 100 194 Calculated Value: N/A / N/A
100 194 Permit Value: N/A / N/A 35 53
If calculated value does not equal reported value, explain: DMR
is due to the Department by Jan 25, 2016; two TSS samples collected
for Nov 2015. Concentration Mo Avg = 194 + 7/2 = 100.5 mg/l. This
is an effluent limitation exceedance and requires a Noncompliance
Report to be submitted with DMR.
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 10 of 15
Water Division Photographic Evidence Sheet Location: Mansfield,
a Division of West Fraser, Inc. Photographer: Kerri McCabe Date:
Dec 29, 2015 Time: 11:13 Witness: Alana Sullivan Photo #: 1
Description: Outfall structure; series of weirs with a 4” PVC pipe
at bottom of trapezoid weir.
Photographer: Kerri McCabe Date: Dec 29, 2015 Time: 11:16
Witness: Alana Sullivan Photo #: 2 Description: Sedimentation pond;
note lack of freeboard and general turbidity of water.
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 11 of 15
Water Division Photographic Evidence Sheet
Location: Mansfield, a Division of West Fraser, Inc.
Photographer: Kerri McCabe Date: Dec 29, 2015 Time: 11:16 Witness:
Alana Sullivan Photo #: 3 Description: Sedimentation pond looking
toward truck/equipment wash area.
Photographer: Kerri McCabe Date: Dec 29, 2015 Time: 11:21
Witness: Alana Sullivan Photo #: 4
Description: Recirculating pond discharges to sedimentation pond
via pipe directly in front of outfall structure.
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 12 of 15
Water Division Photographic Evidence Sheet
Location: Mansfield, a Division of West Fraser, Inc.
Photographer: Alana Sullivan Date: Jan 6, 2016 Time: 9:42 Witness:
Joey Henderson Photo #: 5
Description: Wash bay for truck/equipment washing; built to
discharge directly to sedimentation pond.
Photographer: Alana Sullivan Date: Jan 6, 2016 Time: 9:44
Witness: Joey Henderson Photo #: 6 Description: Slots to discharge
to sedimentation pond.
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 13 of 15
Water Division Photographic Evidence Sheet
Location: Mansfield, a Division of West Fraser, Inc.
Photographer: Alana Sullivan Date: Jan 6, 2016 Time: 9:44 Witness:
Joey Henderson Photo #: 7 Description: Erosion caused by runoff
from wash bay.
Photographer: Alana Sullivan Date: Jan 6, 2016 Time: 9:44
Witness: Joey Henderson Photo #: 8 Description: Erosion caused by
runoff from wash bay.
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 14 of 15
Water Division Photographic Evidence Sheet Location: Mansfield,
a Division of West Fraser, Inc. Photographer: Alana Sullivan Date:
Jan 6, 2016 Time: 9:43 Witness: Joey Henderson Photo #: 9
Description: Cleaner/degreaser used for truck/equipment wash; SDS
provided.
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Inspection Report: Mansfield, a Division of West Fraser, Inc.,
AFIN: 64-00049, Permit #: AR0048232
Inspection Report Page 15 of 15
Figure 1. Google Earth image dated Oct 5, 2013 showing major
structures of the treatment system at West Fraser, Inc. –
Mansfield.
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1
McConnell, Melissa
From: McCabe, KerriSent: Wednesday, December 30, 2015 2:59 PMTo:
[email protected]; [email protected]:
Sullivan, Alana ([email protected])Subject: West Fraser,
Inc. - Mansfield Plant InfoAttachments:
outfall_modification_form.pdf
Mr. Travis and Mr. Henderson, It was nice to meet you two yesterday. I am including some info to clarify my inspections: AR0048232
1.)
Flow should be measured five times per week (per Part I, Sec A of the individual permit). You will need to verify how and where the contract lab is measuring flow. Flow is not measured qualitatively (as in YES/NO). It is to be represented in MGD. The lab should supply you their justification. Since there is an overflow pipe installed below the trapezoid weir, flow will need to be measured at the rectangular weir that is directed in the same direction as the stream channel. I suggest a mounted staff gauge for easier measuring and viewing. The form used by the facility contains all required info. Please start keeping one of these for every month regardless of discharge. Report “No Discharge” when there is no flow at the weir.
This is a link to a flow measuring mobile app: http://www.elecdata.com/blog/flow‐calculation‐app‐for‐ios‐and‐android/
2.)
Copies of the Chains of Custody (COCs) must be supplied and retained onsite for inspection. You need to contact your contract lab and have them supply the last three (3) years of COCs for your records and to start supplying them from this moment forward.
For my inspection report, I need COCs for the June 2015 Pond Discharge, Nov 2015 Pond Discharge (2), and Nov 2015 Stormwater sample events. Please have Data Testing, Inc. supplies those to you.
3.)
BMPs referenced in Part II, Cond 3 are going to be addressed in the IGP inspection. ARR00A473 The biggest concern to address for this inspection is identifying all outfalls to the stream that runs through the property. I have included an Outfall Modification form. You will need to identify where any water from your facility enters the creek. Start upstream (east‐side of the property) and work your way downstream (west‐side of the property). Decide what is to be considered similar and what is not based on what the stormwater is exposed to; sample accordingly. Once outfalls are identified, you will need to implement structural controls and/or behavioral practices at these areas. For this facility, minimizing exposure by asphalting/paving/concreting high‐traffic areas is an excellent idea. Most of the issues that are contributing to benchmark exceedances for COD/TSS are sediment and woody debris. If you have any questions, feel free to contact me. I have to have the report submitted by Jan 10, 2016 for review/process. You should have it before that timeframe. Thank you.
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2
Kerri McCabe Inspector Supervisor ADEQ – Water Division Field Services – Inspection Branch Office – (501) 682‐0642 Work Cell – (501) 352‐5641 Fax – (501) 682‐0880 5301 Northshore Drive North Little Rock, AR 72118‐5317
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ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY
5301 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS 72118-5317
/ TELEPHONE 501-682-0744 / FAX 501-682-0880
www.adeq.state.ar.us
OUTFALL MODIFICATION FORM
The enclosed form may be used to request modifications of
outfalls covered under NPDES general permit ARR000000 for
discharges of stormwater associated with industrial activity
(except from construction activity). The numbering of outfalls
should be
sequential and begin with Outfall 001 (i.e. if Outfall 001 is
deleted, Outfall 002 will become Outfall 001).
Attach additional pages to modify more than one outfall.
Outfall Modification Type: Add (Skip Section II) Remove (Skip
Section III) Move
Permit Tracking No. ARR00___________________________ AFIN:
_________________________
I. FACILITY INFORMATION:
Mailing Address:
City: State: Zip:
II. CURRENT OUTFALL INFORMATION:
Outfall:
Outfall Latitude: degrees minutes seconds
Outfall Longitude: degrees minutes seconds
Receiving Stream:
III. NEW OUTFALL INFORMATION:
Outfall:
Outfall Latitude: degrees minutes seconds
Outfall Longitude: degrees minutes seconds
Receiving Stream:
IV. CONSULTANT INFORMATION (if applicable):
Consultant Contact Name: Company:
Consultant Phone Number: Email Address:
V. SIGNATORY REQUIREMENTS:
“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.”
Responsible/Cognizant Official Printed Name:
________________________________ Title:_______________________
Responsible/Cognizant Official Signature:
________________________________________ Date:
__________________
ATTACH A SITE MAP SHOWING THE NAME AND LOCATION OF EVERY
OUTFALL
THAT WILL BE COVERED UNDER YOUR EXISTING GENERAL PERMIT AFTER
THIS
MODIFICATION.
Permittee: Contact Name:
Facility Name: Phone Number:
Facility City: Zip: Email Address:
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1
McConnell, Melissa
From: McCabe, KerriSent: Wednesday, December 30, 2015 3:02 PMTo:
[email protected]; [email protected]:
List of Certified Contract Labs
Mr. Travis, Since you asked about labs yesterday, I am including a link to the list of certified labs. https://www.adeq.state.ar.us/techsvs/lab_cert/labcert.aspx Kerri McCabe Inspector Supervisor ADEQ – Water Division Field Services – Inspection Branch Office – (501) 682‐0642 Work Cell – (501) 352‐5641 Fax – (501) 682‐0880 5301 Northshore Drive North Little Rock, AR 72118‐5317
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1
McConnell, Melissa
From: Joey Henderson Sent: Wednesday, January 06, 2016 11:58
AMTo: McCabe, Kerri; [email protected]: SDS for
vehicle washAttachments: XL - 500 .pdf
Joey Henderson Environmental Health & Safety West Fraser Mansfield
-------------EOP--------------- This e-mail message and any
attachments are confidential. Any dissemination or use of this
information by a person other than the intended recipient is
unauthorized. If you are not the intended recipient, please notify
me by return e-mail, do not open any attachment and delete this
communication and any copy. Thank you
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March 8, 2016 James Travis, Mill Manager West Fraser, Inc. PO
Box 39 Mansfield, AR 72944 RE: Response to Inspections (Scott
Co)
AFIN: 64-00049 NPDES Permit No.: AR0048232 ARR00A473
Dear Mr. Travis: I have reviewed the response pertaining to my
December 29, 2015 inspections of the Mansfield, a Division of West
Fraser, Inc. facility. The information provided sufficiently
addresses the violations referenced in my inspection reports. At
this time, the Department has no further comment concerning these
particular inspections. Acceptance of this response by the
Department does not preclude any future enforcement action deemed
necessary at this site or any other site. Please be advised
regarding the Corrective Action Plan (CAP) for permit ARR00A473,
the CAP is not a “working document.” It is to be implemented within
30 days of a benchmark exceedance per Part 3.12.1 of the general
permit. Best Management Practices (BMPs) are to be constantly
evaluated for effectiveness, and parameter benchmark exceedances
are indications that the SWPPP needs to be reevaluated and BMPs
improved. If we need further information concerning this matter, we
will contact you. Thank you for your attention to this matter.
Should you have any questions, feel free to contact me at (501)
682-0642 or you may e-mail me at [email protected].
Sincerely,
Kerri McCabe Inspector Supervisor Water Division
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From: McCabe, KerriTo: McConnell, MelissaSubject: FW: West
FraserDate: Friday, March 18, 2016 10:24:40 AMAttachments:
image001.png
Melissa, Please attach this email to WID 19133. Thank you.
Kerri
McCabeInspector SupervisorADEQ – Water DivisionField Services – Inspection Branch Office – (501) 682-0642Work Cell – (501) 352-5641Fax – (501) 682-08805301 Northshore DriveNorth Little Rock, AR 72118-5317
From: Pennye Bray [mailto:[email protected]] Sent: Friday, March
18, 2016 9:27 AMTo: McCabe, KerriCc: Dannia WilsonSubject: RE: West
Fraser Ms. McCabe, I do not believe they are installing a collection system to the pond. It is my understanding that theyare tying into existing pipelines but I will check, thanks for the heads up on that. We have actuallyalready submitted a modification application to add the discharge to the permitted sources. Pennye
From: McCabe, Kerri [mailto:[email protected]] Sent: Friday, March 18, 2016 9:22 AMTo: Pennye Bray Cc: Dannia Wilson ; McWilliams, Clark Subject: RE: West Fraser
mailto:/O=ARKANSAS DEPT. OF ENVIRONMENTAL QUALITY/OU=EXCHANGE
ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=MCCABEmailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]
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Ms. Bray, Thank you for your attention to this matter and for assisting West Frasher, Inc. (Mansfield). I willforward this information to the Permits Branch because Ms. Casey Vickerson is no longer with theDepartment, and the facility may have been assigned a new Permit Engineer. Please be advised thatif the facility is installing a collection system from the new kiln area to the wastewater treatmentpond (wet deck pond) it may need to be included with the State Construction permit (modification). I have copied Mr. Clark McWilliams if you have any direct questions or comments concerning thisaspect of the inspection. Thank you again,
Kerri
McCabeInspector SupervisorADEQ – Water DivisionField Services – Inspection Branch Office – (501) 682-0642Work Cell – (501) 352-5641Fax – (501) 682-08805301 Northshore DriveNorth Little Rock, AR 72118-5317
From: Pennye Bray [mailto:[email protected]] Sent: Friday, March
18, 2016 9:14 AMTo: McCabe, KerriCc: Dannia WilsonSubject: West
Fraser Good Morning Ms. McCabe, I am working with West Fraser to assist them in complying with the corrective actions developed inresponse to the findings of your inspection conducted on December 29, 2015. I wanted to provide aprogress report for your records. The preliminary design drawings for the outfall redesign and bermstabilization to provide the required retention time and freeboard have been delivered to WestFraser for their review. We anticipate that they will approve the design early next week and then wewill complete the NPDES Construction Permit Application. We anticipate that the application will besubmitted to ADEQ by the March 31, 2016 date we included in the compliance schedule. Pleasefeel free to call me with any questions that you may have regarding the project.
mailto:[email protected]
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Sincerely,
Pennye L. BraySenior Project ManagerECCI13000 Cantrell
RoadLittle Rock, AR 72223(501) 975-8100 – Phone(501) 975-6789-
Faxwww.ecci.com
http://www.ecci.com/
AR0048232_insp_20151229List of Certified Contract
Labsoutfall_modification_formSDS for vehicle washWest Fraser Inc -
Mansfield Plant Inro