November 5, 2009 Mr. Charles Clark, Vice President Smackover, AR 71762 RE: Compliance Inspection AFIN: 70-00039 NPDES Permit No.: AR0000591 Dear Mr. Clark: On 10/15/2009, I performed an inspection of the 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: The facility had an unpermitted discharge from the storm water retention pond which was a result of excessive rainfall. This unpermitted discharge was reported to the NPDES Enforcement Section in Little Rock. Since this unpermitted discharge was reported as required, no response to this letter is needed at this time. If I can be of any assistance, please contact me at 870-862-0680. Sincerely, District 8 Field Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch
Form Approved OMB No. 2040-0003 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C. 20460 NPDES Compliance Inspection Report Section A: National Data System Coding Transaction Code NPDES Yr/Mo/Day Inspec. Type Inspector Fac. Type 1 N 2 5 3 A R 0 0 0 0 5 9 1 11 12 0 9 1 0 1 5 17 18 R 19 S 20 2 Remarks Inspection Work Days Facility Evaluation Rating BI QA -------------------------------Reserved------------------------------ 67 69 70 N 71 N 72 N 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) Smackover, AR Entry Time/Date 10:59 /10/15/2009 Exit Time/Date 11:47/10/15/2009 Permit Effective Date 7/1/2006 Permit Expiration Date 6/30/2011 Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Charles Clark, Vice President, 870-725-3611 Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Charles Clark, Vice President, 870-725-3611 Smackover, AR 71762 Yes Contacted No Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) N Permit N Flow Measurement N Operations & Maintenance N Sampling N Records/Reports N Self-Monitoring Program N Sludge Handling/Disposal N Pollution Prevention N Facility Site Review N Compliance Schedules N Pretreatment N Multimedia N Effluent/Receiving Waters N Laboratory N Storm Water N Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) This inspection was performed due to excess rainfall that the area has received. The facility reported to Little Rock that the storm water pond on the site was endanger of overtopping which would result in any oil on the pond to float out into Smackover Creek. There was also a danger that the creek would overtop the levee and push the oil into the backwater of the stream. The facility reported that it was pumping storm water from the holding pond to the back waters of Smackover Creek, resulting in an unpermitted discharge. On the date of the inspection, the facility had a 4 inch pump which was discharging into the backwaters of Smackover Creek. The area had experienced above normal rainfall and the 9 acre storm water retention pond was within 6 inches of overtopping the levee. The facility had pumped the water down about 1 foot. Smackover Creek was still rising and had already flooded the lube plant loading rack. I advised Mr. Clark to take samples of the water from the pump for the same parameters as the storm water outfalls. Name(s) and Signature(s) of Inspector(s) Agency/Office/Telephone/Fax AR Dept. of Environmental Quality/ El Dorado 870-862-0680, Fax 870-862-3509 Date 02 November 2009 Signature of Reviewer Agency/Office/Phone and Fax Numbers Date NPDES Report Page 2
1 Of 6 Date: 10/15/2009 Time: 11:41 Lube plant loading rack, flooded by Smackover Creek 2 Of 6 Date: 10/15/2009 Time: 11:43 Smackover Creek flooded into refinery NPDES Report Page 3
3 Of 6 Date: 10/15/2009 Time: 11:46 Storm water retention pond, showing oil on pond, pump station pumps to WWTP and also pump used to pump water out of pond, unpermitted discharge. 4 Of 6 Date: 10/15/2009 Time: 11:46 Showing detail of oil on pond NPDES Report Page 4
5 Of 6 Date: 10/15/2009 Time: 11:46 Water being discharged from pump into backwater of Smackover Creek 6 Of 6 Date: 10/15/2009 Time: Showing lowest portion of pond levee. Level in pond got within 6 inches of overtopping pond NPDES Report Page 5