RE: Viskase Companies Inc., Osceola, AR - NPDES Compliance inspection

Transcription

1 July 18, 2011 Stanley K. Miller, Plant Manager Viskase Companies Inc E. State Hwy. 198 Osceola, AR RE: Viskase Companies Inc., Osceola, AR - NPDES Compliance inspection AFIN: NPDES Permit No.: AR Dear Mr. Miller: On March and April 1, 2011, fellow inspector Brent Walker and I performed a compliance sampling inspection of the wastewater treatment 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: 1. There was not adequate freeboard in the sludge ponds. At the time of the inspection, there was less than 3 inches of freeboard in the southeast pond and the top of the levee appeared soft in some areas. 2. The ph reporting on DMR s was not accurate. The monthly average was being reported instead of the daily minimum that is required by Part I, A. of the permit. 3. Improper operation and maintenance; this violates Part II Section B. Item 1.a. of the permit. The following items were noted at the wastewater plant: a) The composite sampler was in need of repair. Effluent samples were not accurately flow proportioned as required by the permit. b) The bio-treatment unit contained an excessive amount of solids in the clarifier. The following items were noted during the stormwater portion of the inspection: a) The liner of the secondary containment around the glycerin storage tanks was damaged and required repair/replacement. b) Oil was seeping through the wall of the production facility on the Northeast corner. c) There were dark stains on the ground near the compactor area. It appeared to be from a leak coming from the compactor. d) The drain plug/valve was left open on two outdoor secondary containment structures.

2 Stanley Miller, Viskase Companies Inc. July 18, 2011 Page 2 4. The SWPPP did not include the following items required under Part III, 4.B. of the permit: a) Location of the Wastewater treatment plant. b) The sludge ponds and drying areas. c) The H 2 SO 4 storage areas. d) The CS 2 storage area. e) Location of the railroad. f) The employee and visitor parking area. g) The location of receiving streams and areas of run-on and run-off. 5. Stormwater discharges from outfalls 002 and 003 were not being sampled as required by Part I A. and Part III Condition 6 of the permit. The permit requires that all stormwater discharges that occur during daylight hours be sampled. Currently, only those discharges that originate during daylight hours are being sampled. The above items require your immediate attention. Please submit a written response to these findings to the Water Division Enforcement Branch of this Department. 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 is due by July 28, For additional information you may contact the Enforcement Branch by telephone at or by fax at If I can be of assistance, please contact me at greenway@adeq.state.ar.us or ext.-15. Sincerely, Michael B. Greenway District 3 Field Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch NPDES Report Page 2

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10 September 8, 2011 Dewayne Lucius Viskase Companies Inc E. State Hwy. 198 Osceola, AR RE: AFIN: Permit No.: AR Dear Mr. Lucius: The Department has received your response to the March and April 1, 2011 inspections of your facility by our District Field Inspector, Brent Walker and Michael Greenway. Your response has been deemed deficient for the following reasons: 1. The response did not contain detailed documentation of the items addressed in the August 16, 2011 response letter. Please submit photograph documentation of the following completed corrective actions noted in the inspection report. a. Adequate sludge pond freeboard, b. The repaired hole in the digester wall of the Bio-unit clarifier, c. Adequate cleaning around the compactor. 2. The response stated that the facility would evaluate the liner of the secondary containment around the mineral oil and propylene glycol storage tanks. Please submit a report of stating the evaluation results with a corrective action plan. A copy of the inspection report and the inadequate response is included with this letter for your review. Please submit an adequate response to the Water Enforcement Branch by October 31, Failure to adequately respond by this date will be considered in determining the enforcement action, if required. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at or you may me at suel@adeq.state.ar.us. Sincerely, Kevin Suel Enforcement Analyst Water Division Enforcement Section

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18 November 21, 2011 Dewayne Lucius Viskase Companies Inc E. State Hwy. 198 Osceola, AR RE: AFIN: Permit No.: AR Dear Mr. Lucius: The Department has received your response dated October 20, 2011 to the March and April 1, 2011 inspections of your facility by our District Field Inspector, Brent Walker and Michael Greenway. Your letter appears to adequately address the discrepancies identified during the visit. The Department expects that 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, Kevin Suel Enforcement Analyst Water Division Enforcement Branch