Municipal Separate Storm Sewer System (MS4) Inspection AFIN: , NPDES Permit No.: ARR040023

Transcription

1 December 18, 2012 Honorable Marilyn Edwards County Judge, Washington County 2615 Brink Drive Fayetteville, AR RE: Municipal Separate Storm Sewer System (MS4) Inspection AFIN: , NPDES Permit No.: ARR Dear Judge Edwards: On November 7 and 8, 2012, members from ADEQ s Water Division Permits Branch and Inspection Branch performed a Municipal Separate Storm Sewer System (MS4) Audit on Washington County. This Audit was performed in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. Overall, the County appeared to have implemented an effective program to identify and eliminate discharges to the MS4. Robyn Reed, Environmental Affairs & Recycling Director, had an excellent general awareness of the stormwater program. This inspection revealed the following: Section Illicit Discharge Detection and Elimination The Department noted areas for improvement with regard to the County s illicit discharge detection and elimination program. This includes: 1. A map of the stormwater conveyance system has not yet been completed as required by Section of the general permit. 2. The County does address illicit discharges when discovered; however, the County has not implemented a systematic approach for detecting illicit discharges at all outfalls during dry weather screenings. During the inspection, Mrs. Reed stated that the Road Department looks for illicit discharges when conducting maintenance activities in the area; however, the County has not implemented a systematic approach for detecting illicit discharges at all outfalls during dry weather screenings.

2 Page 2 Although the Washington County Road Department is not included in the Washington County MS4 jurisdiction, an operation and maintenance program that includes a training component with the ultimate goal of preventing or reducing pollutant runoff from municipal operations should be developed and implemented. Best Management Practices had not been implemented to prevent the discharge of sediment and other pollutants from various areas of the Washington County Road Department equipment yard. The following items were noted: 1. Small hydrocarbon spills were observed on the ground. All hydrocarbon spills must be cleaned up immediately. 2. Best Management Practices had not been implemented to prevent the discharge of sediment and other pollutants from various areas. 3. Floatable and blowable litter was observed on the grounds. 4. A written procedure for opening the valve in the containment structure with used oil, etc. should be developed and implemented. 5. Concrete was not disposed of in a designated concrete washout area. 6. The waste bins were not covered at the time of the inspection. The above items require your immediate attention. Please submit a written response to these findings to the Water Division Inspection Branch of this Department. This response should be mailed to the address at the bottom of the first page of the letter or ed to Water-Inspectionreport@adeq.state.ar.us. 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 January 4, If I can be of any assistance, please contact me at , ext. 12. Sincerely, Alison West District 1 Field Inspector Water Division cc: Water Division Permits Branch NPDES Report Page 2

3 ADEQ Water NPDES Inspection AFIN: Permit #: ARR Form Approved OMB No UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C NPDES Compliance Inspection Report 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 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) Washington County MS Brink Drive Fayetteville, AR Entry Time/Date 9:00 a.m./ :30 a.m./ Exit Time/Date 2:45 p.m./ :40 a.m./ Permit Effective Date August 1, 2009 Permit Expiration Date July 31, 2014 Name(s) of On-Site Representative(s)/Title(s)/Phone and Robyn Reed/Environmental Affairs and Recycling Director/ /rreed@co.washington.ar.us Katie Teague/U of A Cooperative Extension Service Jane Maginot/U of A Cooperative Extension Service Other Facility Data PDS# Name, Address of Responsible Official/Title/Phone and Fax Number Honorable Marilyn Edwards County Judge, Washington County 2615 Brink Drive Fayetteville, AR Yes Contacted No Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) S SWMP M Illicit Discharge program N Sampling S Monitoring /Records/Reports S Construction Storm Water N Self-Monitoring Program N Pollution Prevention / S Public Outreach S Post Construction N Multimedia S Public Participation S Municipal Operations PP S Storm Water Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) 1. Storm Sewer System Map has not been completed per Section of the permit. 2. County does not have a plan/schedule to evaluate illicit discharges other than relying on the Road Department to identify or report those when they are in the field or if there is a complaint. 3. Although not part of the MS4, violations were recorded at the Washington County Road Department s equipment yard. Name(s) and Signature(s) of Inspector(s) Alison West/ Agency/Office/Telephone/Fax Arkansas Department of Environmental Quality-Fayetteville , ext. 12/ Date November 28, 2012 Signature of Reviewer Agency/Office/Phone and Fax Numbers Date NPDES Report Page 3

4 ADEQ Water NPDES Inspection AFIN: Permit #: ARR SECTION A: STORM WATER MANAGEMENT PROGRAM (SWMP) SWMP PROPERLY DEVELOPED AND IMPLEMENTED DETAILS: Permit Engineers reviewed SWMP. S M U NA NE 1. IS THE SWMP BEING ADEQUATELY ENFORCED? (3.1.1.) 2. HAVE MEASURABLE GOALS FOR EACH BMP BEEN ESTABLISHED? ( ) 3. DOES THE MS4 DISCHARGE INTO AN IMPAIRED WATERBODY (303d)? ( ) IF SO, AND THE MS4 IS A CONTRIBUTOR, HAVE THE BMPS BEEN ENHANCED AS REQUIRED? ( ) 4. HAS A TABLE OF ORGANIZATION BEEN DEVELOPED? ( ) 5. WAS AN ANNUAL REVIEW OF THE SWMP PERFORMED AS REQUIRED? (3.4.1) 6. DOES THE MS4 SHARE RESPONSIBILITY WITH ANOTHER ENTITY IN THE IMPLEMENTATION OF ANY REQUIRED MEASURES? (3.3) 7. DOES THE MS4 DISCHARGE INTO A 303(d) LISTED WATERBODY? (3.4.5) IMPAIRMENT PARAMETER? 8. ARE MEASURES BEING TAKEN TO IDENTIFY AND ELIMINATE THE LISTED POLLUTANT? (3.4.5) COMMENTS: There were no deficiencies noted with respect to this control measure. The MS4 shares responsibilities with the University of Arkansas and Northwest Arkansas Regional Planning. SECTION B: MONITORING / RECORDKEEPING AND REPORTING IS THE PERMITTEE KEEPING ALL MONITORING RECORDS AS REQUIRED DETAILS: Permit Engineers reviewed annual report. S M U NA NE 1. WAS THE ANNUAL REPORT SUBMITTED BY THE DATE REQUIRED? (4.3.1) 2. HAS A MONITORING PROGRAM BEEN DEVELOPED TO EVALUATE PROGRAM COMPLIANCE? (3.1) 3. ARE MONITORING INFORMATION RECORDS, CALIBRATION AND MAINTENANCE RECORDS MAINTAINED? (4.2.1) 4. HAVE STORM WATER SAMPLES BEEN COLLECTED AND ANALYZED? (3.5) COMMENTS: There were no deficiencies noted with respect to this control measure. SECTION C: PUBLIC EDUCATION AND OUTREACH IS THE PERMITTEE ADEQUATELY EDUCATING THE PUBLIC AS STATED IN THE SWMP? DETAILS: S M U NA NE 1. HAS THE PERMITTEE INFORMED THE PUBLIC ABOUT REDUCING STORM WATER POLLUTION? ( ) IF SO, HOW? Pamphlets-U of A Cooperative Extension Service, TV, Staff Display, Electronic Distribution, Trail Displays, Storm Drain Murals, Rain Barrel Workshops 2. HOW ARE MATERIALS DISTRIBUTED? ( ) Garden Clubs, Festivals, Creek Clean-up, Etc. 3. HAS A RATIONAL STATEMENT BEEN DEVELOPED AND IMPLEMENTED AS REQUIRED? ( ) 4. DOES THE PROGRAM INCLUDE MORE THAN ONE MECHANISM AND TARGET AT LEAST 5 THEMES? ( ) 5. DOES AT LEAST ONE THEME OR MESSAGE TARGET THE LAND DEVELOPMENT COMMUNITY ( ) COMMENTS: The MS4 has an excellent public education and outreach program. There were no deficiencies noted with the respect to this control measure. SECTION D: PUBLIC INVOLVEMENT AND PARTICIPATION IS THE PERMITTEE ADEQUATELY INVOLVING THE PUBLIC AS STATED IN THE SWMP? DETAILS: S M U NA NE 1. HAS THE PERMITTEE INVOLVED THE PUBLIC IN THE DEVELOPMENT AND SUBMITTAL OF THE NOI AND SWMP DESCRIPTION? ( ) IF SO, HOW? 2. WHO ARE THE TARGET AUDIENCES FOR THE PUBLIC INVOLVEMENT PROGRAM? ( ) Specific based interest/use 3. HAS THE PUBLIC INVOLVEMENT/PARTICIPATION PROGRAM INCLUDED FIVE PUBLIC ACTIVITIES AS REQUIRED?( ) 4. WHAT ARE THE TYPES OF PUBLIC INVOLVEMENT ACTIVITIES INVOLVED IN THE PROGRAM? E-waste, creek clean ups, rain barrel workshops, homeowners, construction, gardening, etc. NPDES Report Page 4

5 ADEQ Water NPDES Inspection AFIN: Permit #: ARR COMMENTS: There were no deficiencies noted with the respect to this control measure. SECTION E: ILLICIT DISCHARGE DETECTION AND ELIMINATION IS THE PERMITTEE ADEQUATELY ADDRESSING ILLICIT DISCHARGES AS STATED IN THE SWMP? DETAILS: S M U NA NE 1. HAS A PROGRAM BEEN DEVELOPED TO ADDRESS AND IMPLEMENT ILLICIT DISCHARGES? ( ) 2. IS THE PROGRAM BEING ENFORCED AS NOTED IN THE SWMP? ( ) 3. WHAT ENFORCEMENT PROCEDURES ARE USED TO BRING VIOLATORS INTO COMPLIANCE? 4. HAS THE PERMITTEE DEVELOPED AN ADEQUATE STORM SEWER MAP IDENTIFYING ALL OUTFALLS? ( ) 5. HAS THE PERMITTEE INFORMED THE GENERAL PUBLIC OF HAZARDS ASSOCIATED WITH ILLEGAL DISCHARGES?(3235) 6. HAS THE PERMITTEE DEVELOPED AND IMPLEMENTED A PLAN TO DETECT AND ELIMINATE NON-STORMWATER DISCHARGES, INCLUDING ILLEGAL DUMPING, INTO THE SYSTEM? ( ) 7. HAS A RATIONALE BEEN DEVELOPED THAT DOCUMENTS THE DECISION PROCESS FOR THE DEVELOPMENT OF A STORM WATER ILLICIT DISCHARGE DETECTION AND ELIMINATION SYSTEM? ( ) 8. HAS DRY WEATHER SCREENING OF ALL STORM WATER OUTFALLS LOCATED WITHIN THE MS4 S URBANIZED AREA OCCURRED AS REQUIRED BY THE PROGRAM? ( ) 9. DOES THE ANNUAL REPORT INCLUDE INFORMATION SUCH AS NUMBER OF ILLICIT DISCHARGES FOUND, AND THE NUMBER OF ILLICIT DISCHARGES ELIMINATED? ( ) COMMENTS: 1. A map of the stormwater conveyance system has not yet been completed. 2. The County does address illicit discharges when discovered; however, the County has not implemented a systematic approach for detecting illicit discharges at all outfalls during dry weather screenings. During the inspection, Mrs. Reed stated that the Road Department looks for illicit discharges when in the area. SECTION F: CONSTRUCTION SITE STORM WATER RUNOFF CONTROL HAS THE PERMITTEE DEVELOPED, IMPLEMENTED AND ENFORCED A PROGRAM TO REDUCE POLLUTANTS FROM CONSTRUCTION SITES? S M U NA NE 1. HAS AN ORDINANCE OR OTHER REGULATORY MECHANISM BEEN IMPLEMENTED TO REQUIRE EROSION AND SEDIMENT CONTROLS? ( ) County Judge Order 2. HAVE ENFORCEMENT PROCEDURES BEEN DEVELOPED TO BRING CONSTRUCTION SITES INTO COMPLIANCE? (32411) 3. HAVE REQUIREMENTS BEEN DEVELOPED FOR THE CONTROL OF WASTES AT THE CONSTRUCTION SITE? ( ) 4. HAVE PROCEDURES BEEN DEVELOPED FOR SITE INSPECTION AND ENFORCEMENT OF CONTROL MEASURES? ( ) 5. HAS A RATIONALE BEEN DEVELOPED THAT DOCUMENTS THE DECISION PROCESS FOR THE DEVELOPMENT OF A CONSTRUCTION SITE STORM WATER CONTROL PROGRAM? ( ) 6. ARE ALL SWPPPS (>1 ACRE) REVIEWED AS PART OF THE PRE-CONSTRUCTION SITE PLAN REVIEW? ( ) 7. ARE ALL SITES >1 ACRE INSPECTED MONTHLY TO ENSURE COMPLIANCE? ( ) 8. DOES THE ANNUAL REPORT INCLUDE INFORMATION SUCH AS NUMBER OF SWPPPS REVIEWED, NUMBER OF INSPECTIONS, NUMBER OF VIOLATION LETTERS ISSUED, NUMBER OF ENFORCEMENT ACTIONS, AND NUMBER OF COMPLAINTS? ( ) COMMENTS No active construction sites since SECTION G: POST-CONSTRUCTION STORM WATER MANAGEMENT HAS THE PERMITTEE DEVELOPED, IMPLEMENTED AND ENFORCED A PROGRAM TO ADDRESS STORM WATER RUNOFF FROM NEW DEVELOPMENT OR REDEVELOPMENT? S M U NA NE 1. HAS A STRATEGY BEEN DEVELOPED AND IMPLEMENTED WHICH INCLUDES A COMBINATION OF STRUCTURAL AND /OR NON STRUCTURAL BMP S FOR THE COMMUNITY? ( ) 2. HAS A RATIONALE BEEN DEVELOPED THAT DOCUMENTS THE DECISION PROCESS FOR THE DEVELOPMENT OF A POST CONSTRUCTION SWMP? ( ) 3. DOES THE RATIONALE ADDRESS BOTH THE OVERALL POST-CONSTRUCTION SWMP, INDIVIDUAL BMP S, MEASURABLE GOALS, AND WHO IS RESPONSIBLE FOR THE PROGRAM? ( ) 4. DOES THE ANNUAL REPORT INCLUDE THE NUMBER OF SITES REQUIRING POST CONSTRUCTION CONTROLS, NUMBER OF PRE- CONSTRUCTION PLANS REVIEWED, AND THE NUMBER OF INSPECTIONS PERFORMED TO ENSURE AS BUILT REQUIREMENTS? ( ) 5. DOES THE PROGRAM CONTAIN LOW IMPACT DEVELOPMENT AND GREEN INFRASTRUCTURE WAIVERS? ( ) NPDES Report Page 5

6 ADEQ Water NPDES Inspection AFIN: Permit #: ARR COMMENTS: Primarily voluntarily and encouraged. Post construction BMPs are inspected in response to a complaint. SECTION H: POLLUTION PREVENTION/GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS HAS THE PERMITTEE DEVELOPED AND IMPLEMENTED A PROGRAM TO REDUCE POLLUTION FROM MUNICIPAL OPERATIONS? S M U NA NE 1. DOES THE PROGRAM INCLUDE EMPLOYEE TRAINING TO PREVENT AND REDUCE STORM WATER POLLUTION FROM PUBLIC OPERATIONS? ( ) 2. DOES THE PERMITTEE HAVE A LIST OF INDUSTRIAL FACILITIES OWNED BY THE MS4 THAT ARE SUBJECT TO ADEQ GENERAL STORM WATER PERMIT REQUIREMENTS? ( ) NO IGP Facilites. 3. IS THE ADEQ PERMIT NUMBER OR COPY OF THE INDUSTRIAL STORM WATER NOI INCLUDED? 4. DO MUNICIPAL FACILITIES NOT REQUIRED TO OBTAIN PERMIT COVERAGE ALL HAVE AN IMPLEMENTED SWPPP? 5. HAS AN O&M PROGRAM BEEN IMPLEMENTED TO PREVENT OR REDUCE POLLUTANT RUNOFF FROM MUNICIPAL OPERATIONS? ARE THE MUNICIPAL OPERATIONS THAT ARE AFFECTED BY THE O&M PROGRAM LISTED AS REQUIRED? ( ) 6. ARE MAINTENANCE ACTIVITIES, MAINTENANCE SCHEDULES, AND LONG-TERM INSPECTION PROCEDURES FOR CONTROLS TO REDUCE FLOATABLES AND OTHER POLLUTANTS TO THE MS4 SPECIFIED AS REQUIRED? ( ) COMMENTS: The Washington County Road Department does not fall in the Washington County MS4 jurisdiction. However, an operation and maintenance program that includes a training component and has the ultimate goal of preventing or reducing pollutant runoff from the municipal operation should be developed and implemented. Best Management Practices had not been implemented to prevent the discharge of sediment and other pollutants from various areas of the Washington County Road Department yard. NAME OF PUBLIC FACILITY: Washington County Road Department MS4 MAINTENANCE FACILITY INSPECTION ADDRESS OF FACILITY: 2615 S. Brink Drive, Fayetteville, AR DATE AND TIME OF VISIT: November 8, 2012/8:30 a.m.-9:10 a.m. FACILITY CONTACT (NAME, TITLE AND PHONE NUMBER): Shawn Shrum, Assistant Road Superintendent 1. HAS THE FACILITY DEVELOPED AND IMPLEMENTED A SWPPP OR STORMWATER PLAN? 2. DOES THE PLAN INCLUDE A SITE MAP, LIST OF POLLUTANT SOURCES, BMP S, AND MAINTENANCE PROCEDURES? 3. DOES THE PERMITTEE CONDUCT AND DOCUMENT PERIODIC INSPECTIONS OF THE FACILITY? 4. ARE STORM DRAINS LABELED, FREE OF DEBRIS, AND IN GOOD CONDITION? 5. ARE VEHICLE MAINTENANCE ACTIVITIES CONDUCTED IN A DESIGNATED PLACE NOT EXPOSED TO STORM WATER? 6. ARE FUELING STATIONS PROPERLY DESIGNED WITH SPILL KITS NEARBY? 7. ARE VEHICLES WASHED ON SITE? IF SO, IS THE WASH WATER DISCHARGED TO THE MS4 OR THE SANITARY SEWER? 8. ARE ALL MATERIALS THAT ARE POTENTIAL STORM WATER CONTAMINANTS STORED UNDER COVER OR IN SECONDARY CONTAINMENT? 9. ARE ALL HAZARDOUS MATERIALS PROPERLY LABELED AND STORED TO PREVENT EXPOSURE TO STORM WATER? 10. ARE WASTE BINS PROPERLY COVERED AND ARE WASTES PROPERLY DISPOSED? 11. HOW IS LANDSCAPE WASTE STORED? Stored outside. Exposed to rain. 12. WHAT TYPE OF STORM WATER TRAINING DOES THE FACILITY STAFF RECEIVE? County could not provide documentation of staff training on stormwater rules. INSPECTION COMMENTS: The following items were noted: 1. Small hydrocarbon spills observed on the ground. All hydrocarbon spills must be cleaned up immediately. 2. Best Management Practices had not been implemented to prevent the discharge of sediment and other pollutants from various areas NPDES Report Page 6

7 ADEQ Water NPDES Inspection AFIN: Permit #: ARR Floatable and blow able litter was observed on the grounds. 4. A written procedure for opening the valved in the containment structure with used oil, etc. should be developed and implemented. 5. Concrete waste was not disposed in a designated concrete washout area. 6. The waste bin was not covered at the time of the inspection. Google Earth Satellite Imagery of Washington County Environmental Affairs and Washington County Road Department. NPDES Report Page 7

8 ADEQ Water NPDES Inspection AFIN: Permit #: ARR MS4 MAINTENANCE FACILITY INSPECTION PHOTO PAGE LOCATION Washington County Road Department PHOTOGRAPHER Dennis Benson DATE / TIME 8:37 a.m. DESCRIPTION: Waste bin not covered at the time of the inspection. LOCATION Washington County Road Department PHOTOGRAPHER Dennis Benson DATE / TIME 8:39 a.m. DESCRIPTION: Waste bin not covered at the time of the inspection. NPDES Report Page 8

9 ADEQ Water NPDES Inspection AFIN: Permit #: ARR LOCATION Washington County Road Department PHOTOGRAPHER Dennis Benson DATE / TIME 8:38 a.m. DESCRIPTION: Ground stained from failure to properly clean up hydrocarbon spills. LOCATION Washington County Road Department PHOTOGRAPHER Dennis Benson DATE / TIME 8:47 a.m. DESCRIPTION: Ground stained from failure to properly clean up hydrocarbon spills. NPDES Report Page 9

10 ADEQ Water NPDES Inspection AFIN: Permit #: ARR LOCATION Washington County Road Department PHOTOGRAPHER Alison West DATE / TIME 8:47 a.m. DESCRIPTION: Best Management Practices had not been implemented to prevent the discharge of sediment and other pollutants. NPDES Report Page 10

11 ADEQ Water NPDES Inspection AFIN: Permit #: ARR LOCATION Washington County Road Department PHOTOGRAPHER Alison West DATE / TIME 8:55 a.m. DESCRIPTION: Best Management Practices had not been implemented to prevent the discharge of sediment and other pollutants. LOCATION Washington County Road Department PHOTOGRAPHER Alison West DATE / TIME 8:55 a.m. DESCRIPTION: Concrete waste was not disposed in a designated concrete washout area. NPDES Report Page 11

12 ADEQ Water NPDES Inspection AFIN: Permit #: ARR OUTFALL VISUAL INSPECTION REPORT OUTFALL LOCATION Dogwood Drive and Windsock Lane LAT/LONG DATE / TIME 9:55 a.m./november 8, 2012 PREDOMINANT WATERSHED LAND USE Residential EVALUATOR DATE OUTFALL LAST INSPECTED BY PERMITTEE DAYS SINCE LAST RAINFALL INCHES OUTFALL DESCRIPTION END OF PIPE DIAMETER INCHES PIPE MATERIAL OPEN CHANNEL Y N 1. IS THE OUTFALL SUBMERGED? 2. WHAT IS THE CONDITION OF THE OUTFALL STRUCTURE? Good with some surrounding erosion. VISUAL OBSERVATION 1. WATER FLOW VOLUME NONE LOW MODERATE HIGH INTERMITTENT 2. WATER FLOW COLOR CLEAR MUDDY MILKY OR CLOUDY OIL SHEEN SOAPY /FOAMY OTHER 3. DEBRIS IN PIPE NONE SEDIMENT TRASH OTHER 4. WATER FLOW ODOR NONE PETROLEUM SEWAGE / H2S OTHER 5. IS DEBRIS FROM THE OUTFALL PRESENT IN THE RECEIVING STREAM? 6. STAINING AND SCUM PRESENT NONE IRON OXIDE WHITE GREEN ALGAE OILY SCUM OUTFALL INSPECTION COMMENTS: There was no discharge at the outfall at the time of the inspection. DATE / TIME 9:49 a.m. OUTFALL PHOTO NPDES Report Page 12

13 CERTIFIED MAIL: January 31, 2013 Honorable Marilyn Edwards County Judge, Washington County 2615 Brink Drive Fayetteville, AR Re: Failure to Respond to Inspection AFIN: , Permit No. ARR Dear Judge Edwards: A letter dated December 18, 2012, was sent by ADEQ to you. The letter outlined the findings of an inspection conducted on November 7 and 8, 2012, of the above referenced facility. The letter requested that a written response be submitted to the Water Division Inspection Branch of this Department by January 4, To date, no response has been received. Please submit a written response by February 18, Thank you for your attention to this matter. Should you have any questions, feel free to contact me at , ext. 12 or you may me at west@adeq.state.ar.us. Sincerely, Alison West District 1 Field Inspector Water Division cc: Enforcement Branch

14 Bolenbaugh, Jason From: Sent: To: Subject: Attachments: Sophia Stephenson Wednesday, February 20, :03 AM Water-Inspection-Report; West, Alison; Yarberry, Katherine response letter to Washington County's MS4 audit Audit Response Letter doc; Policy for Handling and Disposing of Containment Area Rain Water docx Please see the attached documents. 1. Follow up letter to audit 2. Written procedure for opening the valve in the containment structure Thank you. Have a great day. Sophia Stephenson Environmental Affairs & Recycling Director Washington County 2615 Brink Drive Fayetteville, AR

15 Marilyn Edwards County Judge Sophia Stephenson Director WASHINGTON COUNTY STATE OF ARKANSAS Office of Environmental Affairs & Recycling February 19, 2013 Arkansas Department of Environmental Quality Attn: Water Inspection Division 5301 Northshore Drive North Little Rock, AR RE: Response to Municipal Separate Storm Sewer System (MS4) Inspection AFIN: , NPDES Permit No.: ARR To Whom It May Concern: This letter is in response to the audit performed by ADEQ on Washington County s MS4. This audit was conducted in November of 2012 at which time Robyn Reed was the director of the Washington County Environmental Affairs and Recycling Department. A letter was sent in January requesting that Washington County follow up on some areas that needed improvement. As of the beginning of January, I, Sophia Stephenson, became the Director of the Environmental Affairs Department. I was not involved with the stormwater program before becoming Director. I am attempting to address each issue to the best of my ability and knowledge. Illicit Discharge Detection and Elimination ADEQ noted areas of the County s illicit discharge detection and elimination program that need improvement mapping outfalls and detection of illicit discharges. The MS4 areas under the jurisdiction of Washington County have changed with the most recent census data. The stormwater conveyance system and outfalls have not yet been mapped. I am working on gathering information about these new MS4 areas in order to begin mapping the conveyance system. Once the system has been mapped, we will develop a schedule for monitoring outfalls during dry weather screenings. I anticipate a completion date for mapping outfalls and developing a plan to be May 30, I would like to be in communication with ADEQ about this timeframe and modify as necessary. Please let me know if this is acceptable. Washington County Operations & Maintenance Center 2615 Brink Drive Fayetteville, Arkansas Telephone: Fax: sstephenson@co.washington.ar.us

16 Marilyn Edwards County Judge Sophia Stephenson Director WASHINGTON COUNTY STATE OF ARKANSAS Office of Environmental Affairs & Recycling Road Department Equipment Yard Six issues were found in the Road Department s equipment yard and have been addressed as follows. 1. The hydrocarbon spills have been cleaned up. Katie Teague, University of Arkansas Extension Agent, conducts training with the road department employees each December. She addressed the importance of cleaning spills at the most recent training. 2. A silt fence has been erected to control the runoff of any sediment. This area has also been seeded. Silt fence will remain in place until vegetation cover has been established. 3. Litter was picked up from the yard and more trash cans were placed outside. The Road Department cleaned and organized the entire yard area. Washington County Operations & Maintenance Center 2615 Brink Drive Fayetteville, Arkansas Telephone: Fax: sstephenson@co.washington.ar.us

17 Marilyn Edwards County Judge Sophia Stephenson Director WASHINGTON COUNTY STATE OF ARKANSAS Office of Environmental Affairs & Recycling 4. The valve now has a lock on it, and Shawn Shrum, Assistant Road Superintendent, has written a procedure for opening a valve in the containment structure. See attached document. 5. The Road Department now has a designated concrete washout area with signage. Washington County Operations & Maintenance Center 2615 Brink Drive Fayetteville, Arkansas Telephone: Fax: sstephenson@co.washington.ar.us

18 Marilyn Edwards County Judge Sophia Stephenson Director WASHINGTON COUNTY STATE OF ARKANSAS Office of Environmental Affairs & Recycling 6. The waste bins noted that were not covered are two large containers, one for the collection of scrap metal the other for bagged trash or bulky items. The dumpster that collects bagged trash and bulky items has a solid bottom to collect any water. This 40 yard dumpster is taken to Boston Mountain Solid Waste District transfer station. The transfer station has a leachate collection system in place. No water that touches trash from this 40 yard dumpster is released onto the ground. The metal trailer that we currently have does not hold water. I have contacted the company who services our metal trailer, RIMCO. The next time the metal trailer is full (one to two months), it will be replaced with a roll off container which will hold liquids. RIMCO collects all liquids from roll off containers and processes it. In the future no water that touches the scrap metal will touch the ground. The road department does not currently have a SWPPP. I will work with Shawn Shrum to develop a plan for the road department equipment yard. Sincerely, Sophia Stephenson Sophia Stephenson Director, Environmental Affairs & Recycling Washington County Washington County Operations & Maintenance Center 2615 Brink Drive Fayetteville, Arkansas Telephone: Fax: sstephenson@co.washington.ar.us

19 Washington County Road Department Policy for Handling and Disposing of Containment Area Rain Water Washington County has established certain guidelines for handling rainwater that collects in the containment areas for our holding tanks. The containment areas have locks placed on the drain and only certain personnel have access to keys for the locks. Those personnel have been trained on this policy. The majority of the excess water will evaporate off. During times of heavy rain and when evaporation is not enough, rainwater will be removed by an approved company and properly disposed of. Written By: Shawn Shrum February 5, 2013

20 February 26, 2013 Honorable Marilyn Edwards County Judge, Washington County 2615 Brink Drive Fayetteville, AR RE: Response to Municipal Separate Storm Sewer System (MS4) Inspection AFIN: , NPDES Permit No.: ARR Dear Judge Edwards: I have reviewed the response pertaining to the Department s November 7-8, 2012 audit of the Washington County Municipal Separate Storm Sewer System. The response indicated it will take approximately 3 months to complete a storm sewer system map. This is an acceptable time line for the Department. To facilitate tracking your progress toward resolving this issue, please submit to the Department a final report depicting a complete stormwater system map as required by Part 3, Section of the general permit. In addition, the response must, also, include a systematic approach for detecting illicit discharges at all outfalls during dry weather screenings. This report should be received by the Department no later than May 25, Thank you for your attention to this matter. Should you have any questions, feel free to contact me at , ext. 12 or you may me at west@adeq.state.ar.us. Sincerely, Alison West District 1 Inspector Water Division

21 Marilyn Edwards County Judge Sophia Stephenson Director WASHINGTON COUNTY STATE OF ARKANSAS Office of Environmental Affairs & Recycling May 24, 2013 Arkansas Department of Environmental Quality Attn: Water Inspection Division 5301 Northshore Drive North Little Rock, AR RE: Response to Municipal Separate Storm Sewer System (MS4) Inspection AFIN: , NPDES Permit No.: ARR To Whom It May Concern: This letter is an update of the progress by Washington County in response to the November 2012 audit performed by ADEQ on Washington County s MS4 area. Road Department Equipment Yard and Surrounding Buildings Six issues were found in the Road Department s equipment yard. All issues have been addressed and remediated as stated in the February letter from Washington County. Certification for No Exposure Exclusion has been filled out and should be received by ADEQ by June 5 th. The No Exposure Exclusion pertains to the Household Hazardous Waste Drop-off Facility. The road department does not currently have a SWPPP. Shawn Shrum, Assistant Road Superintendent, and I will work together to develop a plan for the road department equipment yard. Notification in Personnel Change A letter was sent to ADEQ in April notifying the department that Sophia Stephenson is now the Director of the Environmental Affairs Department and the contact for the MS4 stormwater program. Washington County Operations & Maintenance Center 2615 Brink Drive Fayetteville, Arkansas Telephone: Fax: sstephenson@co.washington.ar.us

22 Marilyn Edwards County Judge Sophia Stephenson Director Illicit Discharge Detection and Elimination WASHINGTON COUNTY STATE OF ARKANSAS Office of Environmental Affairs & Recycling Washington County experienced a complete change in MS4 areas as a result of the 2010 census. As a result of this change, we have until July 31, 2014 to complete mapping the storm sewer system. I am in the process of negotiating with an engineering firm to map the storm sewer system for the County s MS4 area. I plan on having a timeline for the completion of this work soon. Sincerely, Sophia Stephenson Sophia Stephenson Director, Environmental Affairs & Recycling Washington County Washington County Operations & Maintenance Center 2615 Brink Drive Fayetteville, Arkansas Telephone: Fax: sstephenson@co.washington.ar.us