No documentation that a Storm Water Pollution Prevention Plan (SWPPP) has been developed for this facility.

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1 February 17, 2009 Bobby Vincent, Owner 5084 Hwy. 38 West Des Arc, Arkansas RE: Industrial Storm Water Compliance Inspection AFIN: NPDES Permit No.: ARR Dear Mr. Vincent: On February 12, 2009, I conducted a routine compliance inspection of the sawmill 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. This inspection revealed the following violations: No documentation that a Storm Water Pollution Prevention Plan (SWPPP) has been developed for this facility. The above item requires your immediate attention. Please submit a written response to the Water Division Enforcement Branch of this Department at the following address: Cindy Garner, Technical Assistance Manager Water Division Enforcement Branch Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR This response should contain detailed documentation 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 March 17, 2009.

2 Bobby Vincent, Owner Page 2 For additional information you may contact the Enforcement Branch by telephone at or by fax at If I can be of any assistance, please contact me at (870) Sincerely, District 6 Inspector Water Division cc: Water Division Enforcement Branch 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 A F I N 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) 5084 Highway 38 West Hickory Plains, Arkansas Prairie County, Arkansas Entry Time/Date 9:45 a.m. 2/12/09 Exit Time/Date 11:00 a.m. 2/12/09 Permit Effective Date April 1, 2004 Permit Expiration Date March 31, 2009 Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Bobby Vincent, Owner (870) Name, Address of Responsible Official/Title/Phone and Fax Number Bobby Vincent, Owner 5084 Highway 38 West Des Arc, Arkansas Yes Contacted No Other Facility Data N W S N Permit Records/Reports N N 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 N U Sampling S 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) At the time of inspection, the following violation was noted: No documentation that a Storm Water Pollution Prevention Plan (SWPPP) has been developed for this facility. Pollution Prevention Plan Name(s) and Signature(s) of Inspector(s) Steven L. Henderson Agency/Office/Telephone/Fax ADEQ/ White Hall/ (870) / (870) Date February 17, 2009 Signature of Reviewer Agency/Office/Phone and Fax Numbers Date NPDES Report Page 3

4 ADEQ Water NPDES Inspection AFIN: Permit #: ARR SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS S M U NA NE DETAILS: 1. CORRECT NAME AND MAILING ADDRESS OF PERMITTEE: 2. NOTIFICATION GIVEN TO EPA/STATE OF NEW DIFFERENT OR INCREASED DISCHARGES: 3. NUMBER AND LOCATION OF DISCHARGE POINTS AS DESCRIBED IN PERMIT: 4. ALL DISCHARGES ARE PERMITTED: SECTION B: STORM WATER POLLUTION PREVENTION PLAN EVALUATION PERMITTEE SWPPP MEETS PERMIT REQUIRMENTS DETAILS: No documentation of a SWPPP. 1. Pollution Prevention Team S M U NA NE A. Identify specific individuals B. Outline their responsibilities 2. Description of potential pollutant sources, including: A. Site map indicating: A1) Drainage areas A2) Drainage patterns/outfalls A3) Structural and non-structural controls A4) Surface waters A5) Significant materials exposed to precipitation A6) The location of leaks or spills that have occurred in the last 3 years. A7) Location of industrial activities exposed to precipitation including: i. Fueling stations ii. Vehicle/equipment maintenance or cleaning areas iii. Loading/unloading areas iv. Waste treatment, storage, or disposal areas v. Liquid storage tanks vi. Processing areas vii. Storage areas B. A list of pollutants likely to be present in the discharges C. Description of significant materials handled, treated, stored, or disposed of such that exposure to storm water occurred in the last 3 years. C1). Description of the method and location of storage or disposal C2) Description of all material management practices C3) Description and location of existing structural and non- structural controls D. List of significant spills and leaks that occurred in the 3 years prior to the effective date of this Permit E. Summary of existing storm water sampling data F. Description of areas with a high erosion potential G. A narrative summarizing potential pollutant sources 3. A description of appropriate measures and controls, including: A. Good housekeeping procedures B. Preventive maintenance procedures C. Spill prevention and response procedures D. Inspection procedures E. Employee training program F. Recordkeeping and internal reporting procedures NPDES Report Page 4

5 ADEQ Water NPDES Inspection AFIN: Permit #: ARR G. Non-storm water discharge certification H. Identify authorized non-storm water discharges and appropriate controls I. Erosion and sediment controls for areas with a high erosion potential J. A narrative consideration of traditional storm water management practices K. Plans for implementation and maintenance of traditional measures found reasonable and appropriate. 4. Annual Site Compliance Evaluation Reports which include: A. A summary of the scope of the inspection B. Personnel making the inspection C. Major Observations D. Actions taken to revise the Pollution Prevention Plan E. Certification of compliance or a list of non-compliance incidents 5. If discharging to a large or medium municipal separate storm sewer, compliance with applicable requirements in the municipal storm water management program. 6. Consistency of the SWPPP with other plans 7. Additional requirements for facilities subject to Emergency Planning and Community Right to Know Act (EPCRA) Section 313 requirements A. A description of the measures used in areas where Section 313 water priority chemicals are stored, processed, or otherwise handled to: A1) Minimize the potential contact or storm water run-on with the chemicals A2) Prevent exposure of the chemicals to storm water and wind B. A discussion of the measures taken to minimize the discharge of Section 313 water priority chemicals from the following areas: B1) Liquid storage areas B2) Non-liquid storage areas B3) Truck and railcar loading areas B4) Truck and railcar loading areas B5) Transfer, processing, or handling areas B6) Other areas B7) Preventive maintenance and housekeeping B8) Facility security B9) Training B10) Professional Engineer (PE) certification every 3 years 8. Assurance that any salt storage piles present onsite are covered or enclosed NPDES Report Page 5

6 ADEQ Water NPDES Inspection AFIN: Permit #: ARR NPDES Report Page 6

7

8 May 4, 2009 Bobby Vincent, Owner 5084 Hwy 38 West Des Arc, AR RE:, Permit Tracking Number ARR000052, AFIN , Inspection of February 12, 2009 Dear Mr. Vincent: The Department has received your response to the February 12, 2009 inspection of. The response has been deemed deficient for the following reason: The response did not contain documentation that the Storm Water Pollution Prevention Plan (SWPPP) was developed as required by the Permit. You will need to submit a copy of the SWPPP to this office. Please submit a copy of the SWPPP no later than May 18, Failure to adequately respond by this date will be considered in determining the enforcement action, if required, for this site. You will need to include your Permit Tracking Number ARR and AFIN Number on any correspondence with this Department. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at or you may me at stout@adeq.state.ar.us. Sincerely, Marilyn Stout Program Support Manager Water Division Enforcement Section

9 July 29, 2009 Mr. Bobby Vincent, Owner 5084 Hwy. 38 West Des Arc, AR RE:, Permit Tracking Number ARR000052, AFIN , Inspection of February 12, Dear Mr. Jameson: The Department has received your response to the inspection of the Hickory Plains Tie & Lumber, dated February 12, The response has been deemed deficient for the following reasons: 1. The response did not contain documentation that the Storm Water Pollution Prevention Plan (SWPPP) was developed as required by the Permit. You will need to submit a copy of the SWPPP to this office or at the least an update of your progress. Please submit an adequate response by August 12, Failure to adequately respond by this date will be considered in determining the enforcement action, if required, for this facility. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at or you may me at boycej@adeq.state.ar.us. Sincerely, James D. Boyce Enforcement Analyst Water Division Enforcement Section

10

11 August 21, 2009 Mr. Bobby Vincent, Owner 5084 Hwy. 38 West Des Arc, AR RE:, Permit Tracking Number ARR000052, AFIN , Inspection of February 12, Dear Mr. Vincent: The Department has received your response to the February 12, 2009, inspection of. This response was deemed deficient for the following reason: The response did not contain documentation that the Storm Water Pollution Prevention Plan (SWPPP) was developed as required by the Permit. You will need to submit a copy of the SWPPP to this office. If you require assistance to achieve this requirement please contact Amanda Leamons of the ADEQ Public Outreach Office at telephone number or you may her at leamonsa@adeq.st.ar.us. Please submit a response by September 25, Failure to respond by this date will be considered in determining the enforcement action, if required, for this site. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at or you may me at boycej@adeq.state.ar.us. Sincerely, James D. Boyce Enforcement Analyst Water Division Enforcement Section

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