October 13, Todd Risius, EHS Manager Cargill Pork, LLC P.O. Box 699 Russellville, AR RE: Inspection of Cargill London Feed Mill

Transcription

1 October 13, 2010 Todd Risius, EHS Manager Cargill Pork, LLC P.O. Box 699 Russellville, AR RE: Inspection of Cargill London Feed Mill AFIN: NPDES Permit No.: ARR00C466 Dear Mr. Risius: On September 23, 2010, I performed a routine compliance inspection of the London Feed Mill in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. This inspection revealed the following violation: Solids (feed) from the truck loading area were observed in the uncovered walkway south of the facility s office. The feed is exposed to precipitation and/or runoff. The current system does not qualify for the industrial storm water no exposure exclusion, under 40 CFR (g). Immediate action is required to provide a storm resistant shelter to protect industrial materials and activities from exposure to rain, snow, snow melt, and runoff and retain your no exposure certification. The above item requires your immediate attention. Please submit a written response to these findings to Ms. Cindy Garner, Water Division Enforcement Branch Manager. The response should be mailed to the address below. Your response should contain detailed documentation, including photographs, describing the course of action taken to correct the item noted. This corrective action should be completed as soon as possible, and the written response is due by October 23, For additional information you may contact the Enforcement Branch by telephone at or by fax at

2 Todd Risius, Cargill London Feed Mill October 13, 2010 Page 2 If I can be any assistance, please contact me at Sincerely, District 5 Field Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch NPDES Report Page 2

3 NPDES Industrial No-Exp. Storm Water AFIN: Permit #: ARR00C466 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C NPDES Compliance Inspection Report Section A: National Data System Coding Form Approved OMB No Approval Expires Transaction Code NPDES Yr/Mo/Day Inspec. Type Inspector Fac. Type 1 N A R R 0 0 C W 19 S 20 1 Remarks C e r t i f i e d n o e x p o s u r e Inspection Work Days Facility Evaluation Rating BI QA Reserved N 71 N 72 N Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) Cargill London Feed MIll West of the intersection of Hwy 64 and Hwy 333, on the south side of Hwy Hwy 64 London, AR Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Bud J. Akers IV / Plant Manager / Ph.: / Fax: Name, Address of Responsible Official/Title/Phone and Fax Number Todd Risius, EHS Manager P.O. Box 699 Russellville, AR Phone: ext. 241 Fax: S N Permit Records/Reports N N Entry Time/Date 1036 / Exit Time/Date 1130 / Yes Contacted No Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) Flow Measurement Self-Monitoring Program N N Operations & Maintenance Sludge Handling/Disposal Permit Effective Date 08/20/2010 Permit Expiration Date 06/30/2014 Other Facility Data N, W N N Sampling Pollution Prevention U N N N Facility Site Review Compliance Schedules Pretreatment Multimedia N N S N Effluent/Receiving Waters Laboratory Storm Water Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) Feed spills from the truck loading area to and uncovered area south of the office. Name(s) and Signature(s) of Inspector(s) Agency/Office/Telephone/Fax Date Arkansas Department of Environmental Quality / October 12, 2010 Russellville / / Signature of Reviewer Agency/Office/Phone and Fax Numbers Date NPDES Page 3

4 NPDES Industrial No-Exp. Storm Water AFIN: Permit #: ARR00C466 No Exposure Exclusion Verification Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future? Answering Yes to any of these questions indicates the facility is not eligible for the No Exposure Exclusion. a. Using, storing, or cleaning industrial machinery or equipment, and areas where residuals from using, storing, or cleaning industrial machinery or equipment remain and are exposed to storm water. Y N b. Are materials or residuals on the ground or in storm water inlets from spills/leaks? Y N Feed from the truck loading area was observed on the ground in the uncovered area south of the office. c. Are materials or products from past industrial activity exposed? Y N d. Is material handling equipment exposed (except adequately maintained vehicles)? Y N e. Are materials or products during loading/unloading or transporting activities exposed? Y N Feed spilled from the loading socks falls down a sloped area to an exposed portion of the facility. f. Materials or products stored outdoors (except final products intended for outside use [e.g., new cars] where exposure to storm water does not result in the discharge of pollutants). Y N g. Materials contained in open, deteriorated, or leaking storage drums, barrels, tanks, and similar containers. Y N h. Materials or products handled/stored on roads or railways owned or maintained by the discharger. Y N i. Waste materials exposed (except waste in covered, non-leaking containers [e.g., dumpsters]). Y N j. Application or disposal of process wastewater (unless otherwise permitted). Y N k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated (i.e., under an air quality control permit) and evident in the storm water outflow. Y N General Facility product was observed in an exposed area of the facility. The product was not seen in the stormwater drainage. NPDES Page 4

5 NPDES Industrial No-Exp. Storm Water AFIN: Permit #: ARR00C466 Industrial Stormwater Compliance Inspection Report Further Explanation This inspection was prompted by an approximate 2800 gallon soy oil spill occurring on the site on September 22, The spill was reported by Mr. Richard Gray (phone: ) of Cargill on I arrived at the site on and spoke with Mr. Bud Akers, Plant Manager. Mr. Akers informed me a mixer solenoid had failed causing the valve controlling the soy oil to remain open. Oil filled the basement until it triggered the sump pump to pump the oil outside, south of the facility. Oil had pooled along the facility s rail line and then ran between the main railroad and the facility along the storm flow path. From here oil flowed back north through a culvert and was contained by an emergency earth berm constructed on the southeast side of the facility. During this site visit, I observed Roto-Rooter on scene vacuuming up ponded oil near Cargill s rail line. I also observed equipment removing contaminated soil. An earthen berm had been placed in the flow path between the sump pump discharge and the culvert to prevent additional oil from leaving that area. On September 28, 2010 I returned to the facility and met with Mr. Akers and Mr. Todd Risius, Cargill EHS Manager. During this site visit, I observed some contaminated soil south of the plant had been removed. A series of hay bales and silt fence had been placed between the spill and the culvert to prevent sediment and oil from entering the culvert. Some oil was still visible on the ground and inside the culvert. Mr. Risius informed me the culvert was going to be replaced. On the downstream (north) side of the culvert, the emergency berm had been cut. Mr. Risius explained they thought the spill had been adequately cleaned so the facility purposely breached the berm. As the water left the containment area, they noticed the dirt used to construct the berm was contaminated with oil. Recontaminated water flowed off the property north of the railroad tracks, through a culvert, to a low area south of the railroad tracks. Mr. Risius went on to explain the emergency berm was rebuilt and the water was being pumped back to the containment area as needed. Hay bales had been placed downstream of the newly contaminated pool. I observed oil on the water in the pool, as well as the pump system. I observed approximately one foot of freeboard between the contaminated water and the pool s natural outfall. On October 4, 2010, I returned to the facility and spoke with one of the Feed Mill employees. Mr. Akers was not on site, so the employee showed me the spill site. I observed oil diapers had been placed along the site of the spill. Additional diapers and a boom were observed in the offsite pool south of the railroad tracks. Oil in this pool had been reduced to a light sheen. Additionally, no oil was observed on the ground at the spill site south of the plant. I did notice some of the oil absorbents contained quite a bit of oil and suggested to the employee they continue to change out the absorbents frequently. I telephoned Mr. Akers on October 7, Mr. Akers informed me the culvert had been replaced, 2 vac-trucks of fluids, and tons of soil had been removed in the clean up. The soil was taken to the Yell County Waste Management Landfill. I reiterated to him the oil absorbents required frequent changing until no further contamination is observed. I informed him the absorbents needed to be disposed of properly and should not be left in the ditch. After the last site visit, I feel the spill clean up is under control and no further action is required. NPDES Page 5

6 NPDES Industrial No-Exp. Storm Water AFIN: Permit #: ARR00C466 Location: Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet Cargill London Feed Mill None Photo # 1 Of 8 Date: Time: 1054 Feed observed in exposed walkway south of the office. None Photo # 2 Of 8 Date: Time: 1058 From inside truck loading area, feed observed on the ground passes under the wall to the exposed walkway. NPDES Page 6

7 NPDES Industrial No-Exp. Storm Water AFIN: Permit #: ARR00C466 Location: Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet Cargill London Feed Mill None Photo # 3 Of 8 Date: Time: 1041 Flow path of oil spill from the discharge (upper right) through the culvert (lower left). Photo # 4 Of 8 Date: Time: 1043 Sump pump discharge is in a covered rail loading area on the south side of the feed mill. Soy oil contamination was observed west and east of the covered loading area. NPDES Page 7

8 NPDES Industrial No-Exp. Storm Water AFIN: Permit #: ARR00C466 Location: Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet Cargill London Feed Mill None Photo # 5 Of 8 Date: Time: 1431 Soil removed from contaminated area east of the pump discharge. Shown is one of a series of sediment/flow controls installed. Photo # 6 Of 8 Date: Time: 1432 Small collections of oil were observed throughout the spill site on 2 nd visit. NPDES Page 8

9 NPDES Industrial No-Exp. Storm Water AFIN: Permit #: ARR00C466 Location: Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet Cargill London Feed Mill None Photo # 7 Of 8 Date: Time: 1443 Contaminated water collected in an off-site pool, south of the RR tracks, with hose used to pump water back to the emergency containment. Photo # 8 Of 8 Date: Time: 1127 Oil absorbents being utilized in off-site pool during last site visit. NPDES Page 9

10

11

12

13

14 November 4, 2010 Todd Risius, EHS Manager Cargill Pork, LLC P.O. Box 699 Russellville, AR RE: NPDES Permit No.: ARR00C466 AFIN: Response to Inspection Dear Mr. Risius: The Department has received your response to the September 23, 2010 routine compliance inspections of your facility by our District Field Inspector,. Your letter appears to adequately address the discrepancies identified during the visit. The Department assumes the corrective actions taken will be maintained to ensure consistent compliance with the requirements of the permit. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. The Department will keep the inspection and response on file. If future violations occur that require enforcement action, the Department will consider the inspection and response as required by the Pollution Control and Ecology Commission Regulation No. 7, Civil Penalties. This regulation requires the Department to consider the past history of your site and how expeditiously the violations were addressed in determining any civil penalty that may be necessary for any future violations. 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 or you may me at Sincerely, Sam Sawyer Enforcement Coordinator Water Division Enforcement Branch