If I can be of any assistance, please contact me at or (501)

Transcription

1 January 19, 2016 James Travis, Mill Manager West Fraser, Inc. PO Box 39 Mansfield, AR RE: Mansfield, a Division of West Fraser, Inc. Inspection (Scott Co) AFIN: NPDES Permit No.: AR Dear Mr. Travis: On December 29, 2015, I performed a Compliance Evaluation Inspection and an Industrial Stormwater Inspection of the above-referenced 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. Copies of the inspection reports are enclosed for your records. Please refer to the Summary of Findings section of each of the attached inspection reports and provide a written response for each violation that was noted. This response should be mailed to the attention of the Water Division Inspection Branch at the address at the bottom of this letter or ed to Water-Inspection-Report@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 February 5, If I can be of any assistance, please contact me at mccabe@adeq.state.ar.us or (501) Sincerely, Kerri McCabe Inspector Supervisor Water Division cc: James Travis, Mill Manager, West Fraser, Inc., james.travis@westfraser.com Joey Henderson, EHS Supervisor, West Fraser, Inc., joey.henderson@westfraser.com Page 1 of 15

2 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR FACILITY INFORMATION NAME: Mansfield, a Division of West Fraser, Inc. LOCATION: 700 Hwy 71 South CITY: Mansfield, AR RESPONSIBLE OFFICIAL NAME: / TITLE James Travis / Mill Manager COMPANY: West Fraser, Inc. MAILING ADDRESS: PO Box 39 CITY, STATE, ZIP: Mansfield AR PHONE & EXT: / FAX: / WATER DIVISION INSPECTION REPORT AFIN: PERMIT #: AR DATE: 12/29/2015 COUNTY: 64 Scott PDS #: MEDIA: WN GPS LAT: LONG: LOCATION: Entrance FACILITY TYPE: 2 - Industrial FACILITY EVALUATION RATING: 2 - Marginal INSPECTION INFORMATION INSPECTOR ID#: S - State DATE(S): ENTRY TIME: EXIT TIME: 12/29/ :45 14:00 FAYETTEVILLE SHALE RELATED: N INSPECTION TYPE: Compliance Evaluation PERMIT EFFECTIVE DATE: 2/1/2010 PERMIT EXPIRATION DATE: 1/31/2017 FAYETTEVILLE SHALE VIOLATIONS: N INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/ /ETC.: James Travis/Mill Manager/(479) /james.travis@westfraser.com Joey Henderson/EHS Supervisor/(479) /joey.henderson@westfraser.com Alana Sullivan/District 4 Water Inspector james.travis@westfraser.com CONTACTED DURING INSPECTION: Yes AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated) S PERMIT U FLOW MEASUREMENT N STORMWATER M RECORDS/REPORTS S LABORATORY M FACILITY SITE REVIEW M OPERATION & MAINTENANCE M EFFLUENT/RECEIVING WATER M SELF-MONITORING PROGRAM M SAMPLING M SLUDGE HANDLING/DISPOSAL N PRETREATMENT ** OTHER: SUMMARY OF FINDINGS The following violations were noted during the inspection: 1.) Flow is not being measured at the frequency/type specified in the permit. Personnel are monitoring flow one month out of the quarter and reporting qualitative readings. The only flow data being supplied on DMRs are measured and reported when the contract lab collects samples of the discharge. This is a violation of Part I, Section A of the permit. Flow is to be monitored/measured five times per week and reported quantitatively in MGD. The type is instantaneous, which requires a means of measuring head and utilizing a formula to calculate flow. 2.) Two Total Suspended Solids (TSS) samples were collected in November, 2015 (November 5 and 16). The Monthly Average and Daily Max for TSS effluent limitations were exceeded for the quarter (see DMR calculation sheet). This is a violation of Part I, Section A of the permit. A Non-Compliance Report (NCR) is due to the Department with the 4Q 2015 DMR by Jan 25, ) The two-stage recirculating system utilized for wastewater treatment consists of two ponds. The depth of solids (mainly sediment) is unknown in the two ponds. Accumulation of solids in the ponds reduces retention time and design volume. This is a violation of Part II, Condition #3 of the permit. Solids accumulation should be managed to reduce pollution to waters of the State. 4.) The two ponds of the treatment system did not have adequate freeboard. This is a violation of Part II, Condition #5 of the permit. 5.) The following items violate Part III, Section B.1.A of the permit: Inspection Report Page 2 of 15

3 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR Vegetation and debris are built up in the outfall structure. The structure needs to be clean and free of vegetation/debris. Pond levees show signs of erosion particularly around the truck/equipment wash area. Levees need to be protected to reduce erosion. 6.) The Dissolved Oxygen (DO) sample for June 17, 2015 exceeded holding time. Per 40 CFR 136, DO is to be analyzed immediately. This is a violation of Part III, Section C.3 of the permit. The permittee needs to instruct the contract lab to utilize a field DO meter during sample collection or the permittee needs to purchase a DO meter for onsite analysis. 7.) The permittee did not have all required records onsite for review. Specifically, there were no Chain of Custody (COC) forms or lab analyses sheets provided by the contract lab. This is a violation of Part III, Section C.7 of the permit. The permittee has requested all required records from the contract lab and has supplied the requested documents to the inspector. The permittee must retain three (3) years of records onsite per Part III, Section C.7 of the permit. No further response required for this item. 8.) The contract lab is not completely filling out the COC forms with the information required by Part III, Section C.8.A F of the permit. Specifically, the June 17, 2015 COC is missing exact place and the November 5, 2015 COC is missing individual who performed the sampling/measuring, preservatives, and sample matrix. This is a violation of Part III, Section C.8 of the permit. Also, the permittee will need to review this section for records maintained onsite for flow and debris and incorporate any missing information into applicable forms. Please be advised that a DO sample was not collected or analyzed for in November, 2015 with the other sample parameters. Failure to sample/analyze for DO for 4Q 2015 is a violation of Part I, Section A of the permit. Permittee needs to update the contact information for the permit. Specifically, mailing address and contact phone number. Please submit updates and corrected information to the Water Division Permits Branch at Water-permit-application@adeq.state.ar.us. Inspection Report Page 3 of 15

4 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR GENERAL COMMENTS On Tuesday, Dec 29, 2015 I met with the above-mentioned inspection participants to conduct inspections of the facility s wastewater treatment pond and industrial stormwater program (separate report). Inspection consisted of a site assessment and a records review. Site assessment: Treatment consists of a two-stage recirculating system with a recirculating pond (0.023 acre; surface area) and a sedimentation pond (1.0 acre; surface area). Waste streams consist of wet-deck runoff, boiler blowdown, boiler water softener backwash, equipment wash water, and stormwater. A permit modification request was received by the Department Oct 2015 for the addition to discharge kiln condensate from the permitted outfall. The wastewater treatment system has primarily been used for stormwater runoff, and Mr. Travis stated that the wet-deck has not been used to wet stored lumber in several years. However, there are plans to begin utilizing the wet-deck in early The treatment system has no freeboard and was discharging via Outfall 001 during the inspection, and the depth of solids (mainly sediment) in the ponds is unknown. Vegetation of the levees was controlled, but erosion rills/gullies were noted along the interior levees. The outfall structure consists of a trapezoid weir plate with a 4 PVC pipe installed below the plate. Discharge from both the weir plate and PVC pipe flows to two rectangular weir plates downstream, which then flows to a manmade conveyance converging with Coop Creek. There was no staff gauge mounted at the outfall structure, and the contract lab is measuring head from the 4 PVC pipe and using it in conjunction with the Manning formula. Records review: Flow is not being measured at the frequency/type as outlined in Part I, Section A of the permit. Personnel are using a flow sheet one month out of the quarter and using a check mark to indicate qualitative flow (check mark means yes and line through space means no ). Debris is also being measured like this. There were no Chains of Custody (COCs) or lab analyses sheets available for review; however, Mr. Henderson contacted the lab and supplied the requested documents. There were minor issues noted with the contract lab s COCs. INSPECTOR S SIGNATURE: Kerri McCabe DATE: 1/19/2016 SUPERVISOR S SIGNATURE: Jason Bolenbaugh DATE: Inspection Report Page 4 of 15

5 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS S M U NA NE DETAILS: 1. CORRECT NAME AND MAILING ADDRESS OF PERMITTEE: Need to update mailing address to PO Box 39, Mansfield, AR Y N NA NE 2. NOTIFICATION GIVEN TO EPA/STATE OF NEW DIFFERENT OR INCREASED DISCHARGES: Increase from kiln condensate (Oct 2015). Y N NA NE 3. NUMBER AND LOCATION OF DISCHARGE POINTS AS DESCRIBED IN PERMIT: Y N NA NE 4. ALL DISCHARGES ARE PERMITTED: Y N NA NE SECTION B: RECORDKEEPING AND REPORTING EVALUATION RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT S M U NA NE DETAILS: Facility uses contract lab for all sampling, analyses, and DMR reporting; all records from contract lab need to remain at facility. 1. ANALYTICAL RESULTS CONSISTENT WITH DATA REPORTED ON DMRS: Y N NA NE 2. SAMPLING AND ANALYSES DATA ADEQUATE AND INCLUDE: S M U NA NE a. DATES AND TIME(S) OF SAMPLING: Y N NA NE b. EXACT LOCATION(S) OF SAMPLING: Y N NA NE c. NAME OF INDIVIDUAL PERFORMING SAMPLING: Y N NA NE d. ANALYTICAL METHODS AND TECHNIQUES: Y N NA NE e. RESULTS OF CALIBRATIONS: Y N NA NE f. RESULTS OF ANALYSES: Y N NA NE g. DATES AND TIMES OF ANALYSES: Y N NA NE h. NAME OF PERSON(S) PERFORMING ANALYSES: Y N NA NE 3. LABORATORY EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS ADEQUATE: S M U NA NE 4. PLANT RECORDS INCLUDE SCHEDULES, DATES OF EQUIPMENT MAINTENANCE AND REPAIR: S M U NA NE 5. EFFLUENT LOADINGS CALCULATED USING DAILY EFFLUENT FLOW AND DAILY ANALYTICAL DATA: Y N NA NE SECTION C: OPERATIONS AND MAINTENANCE TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED DETAILS: Two-stage recirculating system; recirculating pond and sedimentation pond. S M U NA NE 1. TREATMENT UNITS PROPERLY OPERATED: S M U NA NE 2. TREATMENT UNITS PROPERLY MAINTAINED: Solids depth is unknown in both ponds; inadequate depth can result in shortcircuiting and reduced retention time. Flow from recirculating pond is directly in front of outfall structure in sedimentation S M U NA NE pond. 3. STANDBY POWER OR OTHER EQUIVALENT PROVIDED: No mechanical parts. S M U NA NE 4. ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE: S M U NA NE 5. ALL NEEDED TREATMENT UNITS IN SERVICE: S M U NA NE 6. ADEQUATE NUMBER OF QUALIFIED OPERATORS PROVIDED: S M U NA NE 7. SPARE PARTS AND SUPPLIES INVENTORY MAINTAINED: S M U NA NE 8. OPERATION AND MAINTENANCE MANUAL AVAILABLE: Y N NA NE 9. STANDARD OPERATING PROCEDURES AND SCHEDULES ESTABLISHED: Y N NA NE 10. PROCEDURES FOR EMERGENCY TREATMENT CONTROL ESTABLISHED: Must maintain freeboard; ponds above freeboard limit. Y N NA NE 11. HAVE BYPASSES/OVERFLOWS OCCURRED AT THE PLANT OR IN THE COLLECTION SYSTEM IN THE LAST YEAR: Y N NA NE 12. IF SO, HAS THE REGULATORY AGENCY BEEN NOTIFIED: Y N NA NE 13. HAS CORRECTIVE ACTION BEEN TAKEN TO PREVENT ADDITIONAL BYPASSES/OVERFLOWS: Y N NA NE 14. HAVE ANY HYDRAULIC OVERLOADS OCCURRED AT THE TREATMENT PLANT: Y N NA NE 15. IF SO, DID PERMIT VIOLATIONS OCCUR AS A RESULT: Y N NA NE Inspection Report Page 5 of 15

6 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR SECTION D: SAMPLING PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS DETAILS: Contract lab conducts all sampling, analyses, and reporting of DMRs. S M U NA NE 1. SAMPLES TAKEN AT SITE(S) SPECIFIED IN PERMIT: Y N NA NE 2. LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES: Y N NA NE 3. FLOW PROPORTIONED SAMPLES OBTAINED WHEN REQUIRED BY PERMIT: Y N NA NE 4. SAMPLING AND ANALYSES COMPLETED ON PARAMETERS SPECIFIED IN PERMIT: No DO for Nov Y N NA NE 5. SAMPLING AND ANALYSES PERFORMED AT FREQUENCY SPECIFIED IN PERMIT: Flow is not being monitored or sampled at frequency/type specified in permit; facility personnel is monitoring one month out of the quarter and not reporting by quantitative Y N NA NE means. 6. SAMPLE COLLECTION PROCEDURES ADEQUATE: Y N NA NE a. SAMPLES REFRIGERATED DURING COMPOSITING: Y N NA NE b. PROPER PRESERVATION TECHNIQUES USED: Y N NA NE c. CONTAINERS AND SAMPLE HOLDING TIMES CONFORM TO 40 CFR 136: DO for June 2015 exceeded holding time of instantaneous. Y N NA NE 7. IF MONITORING IS PERFORMED MORE OFTEN THAN REQUIRED ARE RESULTS REPORTED ON THE DMR: TSS collected twice for Nov 2015; DMR is due by Jan 25, Y N NA NE SECTION E: FLOW MEASUREMENT PERMITTEE FLOW MEASUREMENT MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: Permittee is not measuring flow at frequency/type specified; recording is not quantitative. 1. PRIMARY FLOW MEASUREMENT DEVICE PROPERLY INSTALLED AND MAINTAINED: N TYPE OF DEVICE: Trapezoid weir (length unknown); 4 PVC pipe; rectangular weir with end contractions (length unknown); rectangular weir w/o end contractions (length unknown); no staff gauge. Vegetation/debris in weir boxes. 2. FLOW MEASURED AT EACH OUTFALL AS REQUIRED: Flow is being measured by contract lab when collecting samples; not at frequency/type specified in permit. Y N NA NE Y N NA NE 3. SECONDARY INSTRUMENTS (TOTALIZERS, RECORDERS, ETC.) PROPERLY OPERATED AND MAINTAINED: Y N NA NE 4. CALIBRATION FREQUENCY ADEQUATE: Y N NA NE 5. RECORDS MAINTAINED OF CALIBRATION PROCEDURES: Y N NA NE 6. CALIBRATION CHECKS DONE TO ASSURE CONTINUED COMPLIANCE: Y N NA NE 7. FLOW ENTERING DEVICE WELL DISTRIBUTED ACROSS THE CHANNEL AND FREE OF TURBULENCE: Vegetation/debris in weir boxes. Y N NA NE 8. FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGE OF FLOW RATES: Need to install staff gauge at each primary device. Y N NA NE 9. HEAD MEASURED AT PROPER LOCATION: Head measured at 4 PVC pipe; calculate flow (cfs) using Manning equation. Y N NA NE SECTION F: LABORATORY PERMITTEE LABORATORY PROCEDURES MEET PERMIT REQUIREMENTS S M U NA NE DETAILS: Contract lab conducts all sampling, analyses, and reporting of DMRs. 1. EPA APPROVED ANALYTICAL PROCEDURES USED (40 CFR FOR LIQUIDS, 503.8(B) FOR SLUDGES): DO for June 2015 exceeded holding time. Y N NA NE 2. IF ALTERNATIVE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN OBTAINED: Y N NA NE 3. SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT: Y N NA NE 4. QUALITY CONTROL PROCEDURES ADEQUATE: Y N NA NE 5. DUPLICATE SAMPLES ARE ANALYZED >10% OF THE TIME: Y N NA NE 6. SPIKED SAMPLES ARE ANALYZED >10% OF THE TIME: Y N NA NE 7. COMMERCIAL LABORATORY USED: Y N NA NE a. LAB NAME: Data Testing, Inc. b. LAB ADDRESS: 3434 Country Club, Fort Smith, AR c. PARAMETERS PERFORMED: Flow, COD, TSS, Temp, Debris, DO, O&G, and ph 8. BIOMONITORING PROCEDURES ADEQUATE: Y N NA NE a. PROPER ORGANISMS USED: Y N NA NE b. PROPER DILUTION SERIES FOLLOWED: Y N NA NE c. PROPER TEST METHODS AND DURATION: Y N NA NE d. RETESTS AND/OR TRE PERFORMED AS REQUIRED: Y N NA NE Inspection Report Page 6 of 15

7 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR SECTION G: EFFLUENT/RECEIVING WATERS OBSERVATIONS BASED ON VISUAL OBSERVATIONS ONLY S M U NA NE DETAILS: Discharging from 4 PVC pipe below trapezoid weir; low flow. OUTFALL #: OIL SHEEN GREASE TURBIDITY VISIBLE FOAM FLOATING SOLIDS COLOR OTHER 001 NO NO YES NO YES BROWN LOW FLOW SECTION H: SLUDGE DISPOSAL SLUDGE DISPOSAL MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: Depth of solids (mainly sediment) is unknown; can affect retention time and design volume. 1. SLUDGE MANAGEMENT ADEQUATE TO MAINTAIN EFFLUENT QUALITY: S M U NA NE 2. SLUDGE RECORDS MAINTAINED AS REQUIRED BY 40 CFR 503: S M U NA NE 3. FOR LAND APPLIED SLUDGE, TYPE OF LAND APPLIED TO: (E.G., FOREST, AGRICULTURAL, PUBLIC CONTACT SITE): N/A SECTION I: SAMPLING INSPECTION PROCEDURES SAMPLE RESULTS WITHIN PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. SAMPLES OBTAINED THIS INSPECTION: Y N NA NE 2. TYPE OF SAMPLE: GRAB: COMPOSITE: METHOD: FREQUENCY: 3. SAMPLES PRESERVED: Y N NA NE 4. FLOW PROPORTIONED SAMPLES OBTAINED: Y N NA NE 5. SAMPLE OBTAINED FROM FACILITY'S SAMPLING DEVICE: Y N NA NE 6. SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE: Y N NA NE 7. SAMPLE SPLIT WITH PERMITTEE: Y N NA NE 8. CHAIN-OF-CUSTODY PROCEDURES EMPLOYED: Y N NA NE 9. SAMPLES COLLECTED IN ACCORDANCE WITH PERMIT: Y N NA NE SECTION J: STORM WATER POLLUTION PREVENTION PLAN STORM WATER MANAGEMENT MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: Part II, Condition #3 requires BMPs; stormwater inspected under ARR00A SWPPP UPDATED AS NEEDED: DATE OF LAST UPDATE: Y N NA NE 2. SITE MAP INCLUDING ALL DISCHARGES AND SURFACE WATERS: Y N NA NE 3. POLLUTION PREVENTION TEAM IDENTIFIED: Y N NA NE 4. POLLUTION PREVENTION TEAM PROPERLY TRAINED: Y N NA NE 5. LIST OF POTENTIAL POLLUTANT SOURCES: Y N NA NE 6. LIST OF POTENTIAL SOURCES AND PAST SPILLS AND LEAKS: Y N NA NE 7. ALL NON-STORM WATER DISCHARGES ARE AUTHORIZED: Y N NA NE 8. LIST OF STRUCTURAL BMPS: Y N NA NE 9. LIST OF NON-STRUCTURAL BMPS: Y N NA NE 10. BMPS PROPERLY OPERATED AND MAINTAINED: Y N NA NE 11. INSPECTIONS CONDUCTED AS REQUIRED: Y N NA NE Inspection Report Page 7 of 15

8 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR DMR Calculation Check Reporting Period: From To Year Month Day Year Month Day Parameter Checked: Oil & Grease Loading Concentration Mass (lbs/day) (mg/l) Mo Avg / Daily Max Mo Avg Daily Max Reported Value: <0.003 / <0.003 <1.4 <1.4 Calculated Value: / Permit Value: 10 / If calculated value does not equal reported value, explain: Used Daily Max flow provided by contract lab for Loading = 1.4 mg/l x MGD x 8.34 = lbs/day. Used Mo Avg flow provided by contract lab for Loading = 1.4 mg/l x MGD x 8.34 = lbs/day. Inspection Report Page 8 of 15

9 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR DMR Calculation Check Reporting Period: From To Year Month Day Year Month Day Parameter Checked: TSS Loading Concentration Mass (lbs/day) (mg/l) Mo Avg / Daily Max Mo Avg Daily Max Reported Value: N/A / N/A Calculated Value: N/A / N/A Permit Value: N/A / N/A If calculated value does not equal reported value, explain: DMR is due to the Department by Jan 25, 2016; two TSS samples collected for Nov Concentration Mo Avg = /2 = mg/l. This is an effluent limitation exceedance and requires a Noncompliance Report to be submitted with DMR. Inspection Report Page 9 of 15

10 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Mansfield, a Division of West Fraser, Inc. Photographer: Kerri McCabe Date: Dec 29, 2015 Time: 11:13 Witness: Alana Sullivan Photo #: 1 Description: Outfall structure; series of weirs with a 4 PVC pipe at bottom of trapezoid weir. Photographer: Kerri McCabe Date: Dec 29, 2015 Time: 11:16 Witness: Alana Sullivan Photo #: 2 Description: Sedimentation pond; note lack of freeboard and general turbidity of water. Inspection Report Page 10 of 15

11 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Mansfield, a Division of West Fraser, Inc. Photographer: Kerri McCabe Date: Dec 29, 2015 Time: 11:16 Witness: Alana Sullivan Photo #: 3 Description: Sedimentation pond looking toward truck/equipment wash area. Photographer: Kerri McCabe Date: Dec 29, 2015 Time: 11:21 Witness: Alana Sullivan Photo #: 4 Description: Recirculating pond discharges to sedimentation pond via pipe directly in front of outfall structure. Inspection Report Page 11 of 15

12 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Mansfield, a Division of West Fraser, Inc. Photographer: Alana Sullivan Date: Jan 6, 2016 Time: 9:42 Witness: Joey Henderson Photo #: 5 Description: Wash bay for truck/equipment washing; built to discharge directly to sedimentation pond. Photographer: Alana Sullivan Date: Jan 6, 2016 Time: 9:44 Witness: Joey Henderson Photo #: 6 Description: Slots to discharge to sedimentation pond. Inspection Report Page 12 of 15

13 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Mansfield, a Division of West Fraser, Inc. Photographer: Alana Sullivan Date: Jan 6, 2016 Time: 9:44 Witness: Joey Henderson Photo #: 7 Description: Erosion caused by runoff from wash bay. Photographer: Alana Sullivan Date: Jan 6, 2016 Time: 9:44 Witness: Joey Henderson Photo #: 8 Description: Erosion caused by runoff from wash bay. Inspection Report Page 13 of 15

14 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Mansfield, a Division of West Fraser, Inc. Photographer: Alana Sullivan Date: Jan 6, 2016 Time: 9:43 Witness: Joey Henderson Photo #: 9 Description: Cleaner/degreaser used for truck/equipment wash; SDS provided. Inspection Report Page 14 of 15

15 Inspection Report: Mansfield, a Division of West Fraser, Inc., AFIN: , Permit #: AR Figure 1. Google Earth image dated Oct 5, 2013 showing major structures of the treatment system at West Fraser, Inc. Mansfield. Inspection Report Page 15 of 15

16 McConnell, Melissa From: Sent: To: Cc: Subject: Attachments: McCabe, Kerri Wednesday, December 30, :59 PM Sullivan, Alana West Fraser, Inc. - Mansfield Plant Info outfall_modification_form.pdf Mr. Travis and Mr. Henderson, It was nice to meet you two yesterday. I am including some info to clarify my inspections: AR ) Flow should be measured five times per week (per Part I, Sec A of the individual permit). You will need to verify how and where the contract lab is measuring flow. Flow is not measured qualitatively (as in YES/NO). It is to be represented in MGD. The lab should supply you their justification. Since there is an overflow pipe installed below the trapezoid weir, flow will need to be measured at the rectangular weir that is directed in the same direction as the stream channel. I suggest a mounted staff gauge for easier measuring and viewing. The form used by the facility contains all required info. Please start keeping one of these for every month regardless of discharge. Report No Discharge when there is no flow at the weir. This is a link to a flow measuring mobile app: calculation app for ios and android/ 2.) Copies of the Chains of Custody (COCs) must be supplied and retained onsite for inspection. You need to contact your contract lab and have them supply the last three (3) years of COCs for your records and to start supplying them from this moment forward. For my inspection report, I need COCs for the June 2015 Pond Discharge, Nov 2015 Pond Discharge (2), and Nov 2015 Stormwater sample events. Please have Data Testing, Inc. supplies those to you. 3.) BMPs referenced in Part II, Cond 3 are going to be addressed in the IGP inspection. ARR00A473 The biggest concern to address for this inspection is identifying all outfalls to the stream that runs through the property. I have included an Outfall Modification form. You will need to identify where any water from your facility enters the creek. Start upstream (east side of the property) and work your way downstream (west side of the property). Decide what is to be considered similar and what is not based on what the stormwater is exposed to; sample accordingly. Once outfalls are identified, you will need to implement structural controls and/or behavioral practices at these areas. For this facility, minimizing exposure by asphalting/paving/concreting high traffic areas is an excellent idea. Most of the issues that are contributing to benchmark exceedances for COD/TSS are sediment and woody debris. If you have any questions, feel free to contact me. I have to have the report submitted by Jan 10, 2016 for review/process. You should have it before that timeframe. Thank you. 1

17 Kerri McCabe Inspector Supervisor ADEQ Water Division Field Services Inspection Branch Office (501) Work Cell (501) Fax (501) Northshore Drive North Little Rock, AR

18 OUTFALL MODIFICATION FORM The enclosed form may be used to request modifications of outfalls covered under NPDES general permit ARR for discharges of stormwater associated with industrial activity (except from construction activity). The numbering of outfalls should be sequential and begin with Outfall 001 (i.e. if Outfall 001 is deleted, Outfall 002 will become Outfall 001). Attach additional pages to modify more than one outfall. Outfall Modification Type: Add (Skip Section II) Remove (Skip Section III) Move Permit Tracking No. ARR00 AFIN: I. FACILITY INFORMATION: Permittee: Contact Name: Facility Name: Phone Number: Facility City: Zip: Address: Mailing Address: City: State: Zip: II. CURRENT OUTFALL INFORMATION: Outfall: Outfall Latitude: degrees minutes seconds Outfall Longitude: degrees minutes seconds Receiving Stream: III. NEW OUTFALL INFORMATION: Outfall: Outfall Latitude: degrees minutes seconds Outfall Longitude: degrees minutes seconds Receiving Stream: IV. CONSULTANT INFORMATION (if applicable): Consultant Contact Name: Consultant Phone Number: Company: Address: V. SIGNATORY REQUIREMENTS: 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 gather and evaluate 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, including the possibility of fine and imprisonment for knowing violations. Responsible/Cognizant Official Printed Name: Title: Responsible/Cognizant Official Signature: Date: ATTACH A SITE MAP SHOWING THE NAME AND LOCATION OF EVERY OUTFALL THAT WILL BE COVERED UNDER YOUR EXISTING GENERAL PERMIT AFTER THIS MODIFICATION. ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS / TELEPHONE / FAX

19 McConnell, Melissa From: Sent: To: Subject: McCabe, Kerri Wednesday, December 30, :02 PM List of Certified Contract Labs Mr. Travis, Since you asked about labs yesterday, I am including a link to the list of certified labs. Kerri McCabe Inspector Supervisor ADEQ Water Division Field Services Inspection Branch Office (501) Work Cell (501) Fax (501) Northshore Drive North Little Rock, AR

20 McConnell, Melissa From: Sent: To: Subject: Attachments: Joey Henderson Wednesday, January 06, :58 AM McCabe, Kerri; SDS for vehicle wash XL pdf Joey Henderson Environmental Health & Safety West Fraser Mansfield EOP This message and any attachments are confidential. Any dissemination or use of this information by a person other than the intended recipient is unauthorized. If you are not the intended recipient, please notify me by return , do not open any attachment and delete this communication and any copy. Thank you 1

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34 March 8, 2016 James Travis, Mill Manager West Fraser, Inc. PO Box 39 Mansfield, AR RE: Response to Inspections (Scott Co) AFIN: NPDES Permit No.: AR ARR00A473 Dear Mr. Travis: I have reviewed the response pertaining to my December 29, 2015 inspections of the Mansfield, a Division of West Fraser, Inc. facility. The information provided sufficiently addresses the violations referenced in my inspection reports. At this time, the Department has no further comment concerning these particular inspections. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. Please be advised regarding the Corrective Action Plan (CAP) for permit ARR00A473, the CAP is not a working document. It is to be implemented within 30 days of a benchmark exceedance per Part of the general permit. Best Management Practices (BMPs) are to be constantly evaluated for effectiveness, and parameter benchmark exceedances are indications that the SWPPP needs to be reevaluated and BMPs improved. 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 (501) or you may me at mccabe@adeq.state.ar.us. Sincerely, Kerri McCabe Inspector Supervisor Water Division

35 From: To: Subject: Date: Attachments: McCabe, Kerri McConnell, Melissa FW: West Fraser Friday, March 18, :24:40 AM image001.png Melissa, Please attach this to WID Thank you. Kerri McCabe Inspector Supervisor ADEQ Water Division Field Services Inspection Branch Office (501) Work Cell (501) Fax (501) Northshore Drive North Little Rock, AR From: Pennye Bray Sent: Friday, March 18, :27 AM To: McCabe, Kerri Cc: Dannia Wilson Subject: RE: West Fraser Ms. McCabe, I do not believe they are installing a collection system to the pond. It is my understanding that they are tying into existing pipelines but I will check, thanks for the heads up on that. We have actually already submitted a modification application to add the discharge to the permitted sources. Pennye From: McCabe, Kerri [mailto:mccabe@adeq.state.ar.us] Sent: Friday, March 18, :22 AM To: Pennye Bray <PBray@ecci.com> Cc: Dannia Wilson <DWilson@ecci.com>; McWilliams, Clark <mcwilliamsc@adeq.state.ar.us> Subject: RE: West Fraser

36 Ms. Bray, Thank you for your attention to this matter and for assisting West Frasher, Inc. (Mansfield). I will forward this information to the Permits Branch because Ms. Casey Vickerson is no longer with the Department, and the facility may have been assigned a new Permit Engineer. Please be advised that if the facility is installing a collection system from the new kiln area to the wastewater treatment pond (wet deck pond) it may need to be included with the State Construction permit (modification). I have copied Mr. Clark McWilliams if you have any direct questions or comments concerning this aspect of the inspection. Thank you again, Kerri McCabe Inspector Supervisor ADEQ Water Division Field Services Inspection Branch Office (501) Work Cell (501) Fax (501) Northshore Drive North Little Rock, AR From: Pennye Bray [mailto:pbray@ecci.com] Sent: Friday, March 18, :14 AM To: McCabe, Kerri Cc: Dannia Wilson Subject: West Fraser Good Morning Ms. McCabe, I am working with West Fraser to assist them in complying with the corrective actions developed in response to the findings of your inspection conducted on December 29, I wanted to provide a progress report for your records. The preliminary design drawings for the outfall redesign and berm stabilization to provide the required retention time and freeboard have been delivered to West Fraser for their review. We anticipate that they will approve the design early next week and then we will complete the NPDES Construction Permit Application. We anticipate that the application will be submitted to ADEQ by the March 31, 2016 date we included in the compliance schedule. Please feel free to call me with any questions that you may have regarding the project.

37 Sincerely, Pennye L. Bray Senior Project Manager ECCI Cantrell Road Little Rock, AR (501) Phone (501) Fax