RE: AFIN: Permit No.: 5025-W

Transcription

1 October 28, 2009 Billy Staton Terra Renewal Services, Inc. P.O. Box 3036 Russellville, AR RE: AFIN: Permit No.: 5025-W Dear Mr. Staton: On October 23, 2009, Eric Fleming and I performed a routine compliance inspection of the waste treatment and disposal facility in accordance with the provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated thereunder. This inspection revealed the following violations: 1. The Storage Tank Plan for Inclement Weather Storage of Industrial Wastewater submitted by Terra Renewal Services on May 22, 2008 to ADEQ and the permit issued by ADEQ on November 30, 2008 stated: the facility will consist of one steel storage tank and a secondary containment area. It further states that the secondary containment area will consist of a pad and an earthen berm. There were five storage tanks observed at the facility and there was no earthen berm or secondary containment area constructed at the storage tank facility. This is a violation of Part I, 3 and 7, and Part II.A.17. of the permit. 2. There were a few spills observed around the storage tanks with no containment controls. This is a violation of the Arkansas Water and Air Pollution Control Act (A.C.A (a)(2)), Part 1(2), and Part II.A.12 of the permit. 3. An FRAC tank is being used to store the grease trap waste on site. This is the improper container for storing this waste, and a violation of Part I (3)(7). 4. The injection truck has grease on the top and side of the truck which could potentially run off the truck into the waters of the state during a rain event. The above items require your immediate attention. Please submit a written response to these findings to Cindy Garner, Water Division Enforcement Branch Manager. This response should be mailed to the address below. 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. pictures) is due by November 8, 2009.

2 Billy Staton, Terra Renewal Services, Inc. October 28, 2009 Page 2 For additional information you may contact the Enforcement Branch by telephone at or by fax at If I can be any assistance, please contact me at keller@adeq.state.ar.us or Sincerely, Dawn Keller District 9 Field Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch No Discharge Industrial Report Page 2

3 ADEQ Water Industrial No Discharge AFIN: Permit #: 5025-W ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY NO DISCHARGE INDUSTRIAL PERMIT INSPECTION FORM AFIN: Log No.: Permit No.: 5025-W Inspection Date: October 23, 2009 Media: Water Inspector: Dawn Keller Compliance Status: IN / OUT 1A. Name of Facility: Pulaski County Storage Tank Address: E. Hensley Rd, Hensley, AR County: Pulaski 2A. Name of On-Site Representative: None 3A. Name of Responsible Official: Gabriel Timby Address: P.O. Box 3036, Russellville, AR Telephone: A. Parent Company: Terra Renewal Services, Inc. Address: P.O. Box 3036, Russellville, AR Telephone: A. Description of Process (including type of industry, materials produced, and major byproducts): Beneficial use of industrial wastewater treatment residuals generated at food processing facilities, including post-processing food waste, residuals, and DAF skimmings; post processing animal and pet food waste; poultry processing waste ( including DAF skimmings, blood, and lagoon residuals; excludes feathers and offal), grease trap waste; feed & grain mill waste; hatchery waste; and beneficial use pretreatment waste and residues. 6A. Any complaints registered against this permitted facility? Yes No If yes, give date and description of complaint: Anonymous call received on October 21, 2009 regarding the dumping of drill-cutting waste on property owned by Bill Richardson of Hensley trucks dumping waste everyday. This was on an adjoining permitted facility. 7A. Are there any additions, modifications, or corrections to the facility since the last inspection? Yes No If yes, explain: First inspection 1B. Furnish a simplified flow diagram of the treatment system and include main components, flow sequence through plant, and calculated or estimated flows. No Discharge Industrial Report Page 3

4 ADEQ Water Industrial No Discharge AFIN: Permit #: 5025-W No Discharge Industrial Report Page 4

5 ADEQ Water Industrial No Discharge AFIN: Permit #: 5025-W 2B. Nearest Stream: Campbell Bayou 3B. Does wastewater from this facility cause adverse effect on the waters of the State: Yes No If yes, describe: 4B. Are operating records kept as required by permit? Yes No N/A If no, explain: No one on site. 5B. Are maintenance records kept as required by permit? Yes No N/A If no, explain: 6B. Are Samples routinely taken? Yes No N/A 7B. Does the sampling program meet the requirements of the permit? Yes No N/A If no, explain: 8B. What laboratory does the facility use? NA Address: Telephone: 1C. Do laboratory procedures and records meet the requirements of the permit? Yes No N/A If no, explain: 2C. Is contaminated runoff a problem? Yes No N/A If yes, explain: 3C. Is sludge disposal required? Yes No N/A If yes, describe (including final destination): 4C. Is the treatment system being properly operated and maintained as required by permit? Yes No N/A If no, explain Note Summary Of Findings/Comments Below. No Discharge Industrial Report Page 5

6 ADEQ Water Industrial No Discharge AFIN: Permit #: 5025-W SUMMARY OF FINDINGS/COMMENTS 1. The Storage Tank Plan for Inclement Weather Storage of Industrial Wastewater submitted by Terra Renewal Services on May 22, 2008 to ADEQ and the permit issued by ADEQ on November 30, 2008 stated: the facility will consist of one steel storage tank and a secondary containment area. It further states that the secondary containment area will consist of a pad and an earthen berm. There were five storage tanks observed at the facility and there was no earthen berm or secondary containment area constructed at the storage tank facility. This is a violation of Part I, 3 and 7, and Part II.A.17. of the permit. 2. There were a few spills observed around the storage tanks with no containment controls. This is a violation of the Arkansas Water and Air Pollution Control Act (A.C.A (a)(2)), Part 1(2), and Part II.A.12 of the permit. 3. An FRAC tank is being used to store the grease trap waste on site. This is the improper container for storing this waste, and a violation of Part I (3)(7). 4. The injection truck has grease on the top and side of the truck which could potentially run off the truck into the waters of the state during a rain event Inspector Signature: Date of Report: October 23, 2009 Signature of Reviewer: Date of Review: No Discharge Industrial Report Page 6

7 ADEQ Water Industrial No Discharge AFIN: Permit #: 5025-W Water Division No Discharge Industrial Photographic Evidence Sheet Location: Terra Renewal Services, Inc. Industrial Wastewater Storage Site, Hensley, AR Photographer: Dawn Keller Witness: Eric Fleming Photo # 1 Of 4 Date: 10/23/2009 Time: 9:38 a.m. Description: Large Spill from a storage tank on facility site. This was not reported as required. Photographer: Dawn Keller Witness: Eric Fleming Photo # 2 Of 4 Date: 10/23/2009 Time: 9:40 a.m. Description: 5 storage tanks located on the facility site. A containment berm was not constructed as required. No Discharge Industrial Report Page 7

8 ADEQ Water Industrial No Discharge AFIN: Permit #: 5025-W Water Division No Discharge Industrial Photographic Evidence Sheet Location: Terra Renewal Services, Inc. Industrial Wastewater Storage Site, Hensley, AR Photographer: Dawn Keller Witness: Eric Fleming Photo # 3 Of 4 Date: 10/23/2009 Time: 9:46 a.m. Description: FRAC tank containing grease trap waste on the facility site. Photographer: Dawn Keller Witness: Eric Fleming Photo # 4 Of 4 Date: 10/23/2009 Time: 9:42 a.m. Description: Injection Truck with silt and grease caked on the side. No Discharge Industrial Report Page 8

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12 November 19, 2009 Billy Staton Environmental Director Terra Renewal P.O. Box 3036 Russellville, AR RE: Permit No W, AFIN , Terra Renewal Wastewater Storage Facility, Response to Inspection Dear Mr. Staton: The Department has received your response dated November 5, 2009 to the October 23, 2009 inspection of Terra Renewal s Hensley, Arkansas wastewater storage facility by District Field Inspector Dawn Keller. The response has been deemed adequate by this Department. Acceptance of this response by the Department does not preclude any future enforcement action 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 company and how expeditiously the violations were addressed in determining any civil penalty that may be necessary for any future violations. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at or you may me at anderson@adeq.state.ar.us. Sincerely, Alan Anderson Enforcement Analyst Water Division Enforcement Branch

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