Skiver Development of Arkansas, in

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1 0/?2b.r Skiver Development of Arkansas, in January 23,2007 NPDES Enforcement Section Arkansas Department of Environmental Quality P.O. Box 8913 Little Rock, Arkansas RE: AFIN: NPDES Permit No: ARR Bellevue Addition Phase IV Dear Sir or Madam, In response to the letter dated December 18,2006, I submit the following: 1 & 2. We are conducting inspections every 14 days or less. Although no one is perfect I continue to strive to do what is right. 3. I am perplexed that you say I am not conducting the rain reports properly when in "your" report you took a picture of my report, dated 12/12/06, indicating the last day of rain and the amount of rain, see attached copy of picture submitted in my report. 4. SWPPP has been signed, see attached copies. 5. SWPPP has been modified on-site to show what we actually have on-site. Some of the general language used by my engineer, Bond Consulting, has also been modified to what we are actually using with regard to erosion control. Vehicle entrance is covered with B- stone not vegetative groundcover, change has also been made on permit. 6. We continue to work on all areas of development with regard to the mentioned area on the north side. This is an area we continue to fill, in order to bring it out of the floodplain, therefore area does continue to be disturbed. 7. Silt fences, framed with 2x4 construction, have been installed around drop inlets where hay bales failed to control sediment runoff. This is documented on our drawing in mailbox. 8. The only thing I can say regarding our retention basin is that - when it stops raining long enough for things to dry out - we will complete the basin. Until such time, I consider the retention basin to be in the "construction" phase. The delay in my answer was granted, by Cindy Garner, to enable me to give it to her at our onsite meeting on January 23, Davis Ranch Road / Cabot, Arkanaas Telephone or Fax SO

2 Skiver Development of Arkansas, Znc. Although mistakes have been made, I continue attempting to work with ADEQ to resolve any issues, hence a meeting with Kim Fuller, December 4, 2006, a meeting with Mo Shafi, Mary Leath, Dennis Benson and Cindy Garner on December 29, 2006, and finally an on-site meting with Dennis Benson and Cindy Garner on January 23,2007. My hopes after this last meeting are that I am found to be in compliance of my past short-comings. Again, thank you for your valuable time. Respectfwlly, Clint Skiver Davis Ranch Road 1 Cabot, Arkansas I Telephone $ or SO I Fax SO

3 ADEQ A R K A N S A S Department of Environmental Quality NPDES Storm Water - ost recent ins that are to be performed every 7 days, instead of every 14 days. Inspections are not performed on a weekly basis.

4 POLLUTION PREVENTION PLAN CERTIFICATION 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 gathered and evaluated 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, induding the possibility of fine and imprisonment for Owner Date: /2-2/&a9

5 CONSTRUCTOR'S CERTIFICATION I I certify under penalty of the law that I understand the terms and conditions of the National Pollutant Discharge Elimination System (NPDES) general permit that authorizes storm water discharges associated with construction activity from the construction site identified-a) part of this certification. Signed: Skiver Development! Owner Address: PO Box 730 Cabot, Arkansas Telephone: (501) Date: ILL\ - d@

6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C NPDES Compliance Inspection Report Form Approved OMB No Approval Expires Section A: National Data System Coding Transaction Code NPDES yr/mo/day Inspec. Type Inspector Fac Type 1 N A R R W 19 S 20 2 Remarks A F I N P u l a s k i C o u n t y 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) Bellevue Addition Phase IV - located north of Graham Road, and west of N. Eastern Ave., in Jacksonville, AR Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Entry Time/Date 0930 on Exit Time/Date 1015 on Permit Effective Date Permit Expiration Date Other Facility Data none Name, Address of Responsible Official/Title/Phone and Fax Number Clint Skiver Developer / Skiver Development PO BOX 730 Cabot, AR Contacted Yes No x Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) U Permit N Flow Measurement U Operations & Maintenance N CSO/SSO U Records/Reports N Self-Monitoring Program N Sludge Handling/Disposal N Pollution Prevention U Facility Site Review N Compliance Schedules N Pretreatment N Multimedia M Effluent/Receiving Waters N Laboratory U Storm Water N Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) This inspection was performed at the request of the NPDES Enforcement Branch. The inspection revealed the following: 1. Inspections are unsatisfactory. Numerous problems were found with the erosion controls. 2. The inactive portions of the site are not being stabilized as required by the permit. The northern end of the site has not changed since my inspection. 3. The SWPPP is STILL not signed as required. 4. The SWPPP is not being implemented as required. The controls in the SWPPP, and what is actually on site are not the same. 5. Numerous problems were found with the SWPPP. See the attached photos for details. Name(s) and Signature(s) of Inspector(s) Agency/Office/Telephone/Fax Date Eric M. Fleming / ADEQ / Little Rock / Signature of Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form (Rev. 9-94) Previous editions are obsolete.

7 Site Name: Bellevue Addition Phase IV Permit #: ARR Lat: N Date: Long: W Total Acreage: 13.2 Acreage Disturbed: <13.1 Starting Date: Project Type: Construction Stage: x Residential Industrial Clearing Building Const. Commercial Roadway x Rough Grading Final Stabilization Other: x Infrastructure Inactive Other: Permit Type: Site Posted: SWPPP: x General x Yes Yes Individual No No Unpermitted Improper x Incomplete Are stabilization practices satisfactory? Yes x No N/A List (seeding, mulching, geotextiles, etc.): Are erosion controls Satisfactory? Yes x No N/A List (silt fences, hay/straw bales, sedimentation ponds, riprap, etc): Silt fences, hay bales, detention basin. Proper operation and maintenance of all facilities & systems of treatment & control? Yes x No Comments: Hay bales and silt fences are still not being maintained. Evidence of sediment leaving the site? Evidence of off-site tracking? x Yes No Yes x No Evidence of sediment entering the Waters of the State? Yes x No Are inspections conducted and records kept as required in the permit? Yes x No Date of Last Inspections are still unsatisfactory. Inspection: Is there a rain gauge on-site? Are daily rainfall totals recorded? x Yes No Yes x No Comments: See the photo sheets for problems noted during this inspection.

8 Recently reworked curb inlet. Excessive sediment is present in the bottom of the drain

9 Most recent inspection, still not showing that the 3 outfalls have been inspected as required. The inspection report also states that inspections are to be performed every 7 days, instead of every 14 days. Inspections are not performed on a weekly basis.

10 The SWPPP has still not been signed as required. Neither the Owner nor the contractor have signed the SWPPP.

11 Offsite Tracking: SWPPP states that vehicles will be travel a route that is continuously covered with vegetation. A truck cleaning area is also mentioned. Neither the truck cleaning area nor the vegetated travel route could be found on site nor were they included on the site map. Erosion and sediment controls: This section makes mention of using rip rap check dams as erosion controls. There are no rock check dams on site. The detention basin is not listed in the SWPPP as an erosion control. Erosion matting is not listed as an erosion control. Temporary Stabilization: Makes mention of seeding the non active areas of the site as a stabilization practice. This has not occurred.

12 Storm Water Management: States that the outlet piping will be stabilized with rip rap and erosion matting. This has not occurred. There is not erosion matting on site. The detention basin is not mentioned in this section. Improperly installed hay bale. There was a gap of about 4 under this hay bale, which would allow storm water to flow, unchecked, into the storm drain system.

13 This photo shows the detention basin as appearing the same as during my last visit to the site. The basin was allegedly in the process of construction during my last inspection. No further construction to the basin has occurred since Also, the site map in the SWPPP, does not stated that any construction has occurred on the basin since prior to my last inspection. These two photos show an outfall which is in a state of disrepair. The silt fence in this area has been blown out, allowing contaminated storm water to discharge off site. This was not stated in the most recent inspection.

14 This photo shows the 3 rd outfall from the site. Like the other 2 outfalls, this one is not noted on the site map. This outfall is located between the other 2 outfalls. This photo shows an unstabilized area near the north side of the site. This area appears the same as during my last inspection of

15 Unstabilized, unvegetated main vehicle entrance.