August 8, 2016 Marty Renfrow, Plant Manager Husqvarna Plastics Nashville 139 Old Airport Road Nashville, AR 71852 RE: Husqvarna Plastics Nashville Inspection AFIN: 31-00000 Permit No.: ARR000000 Dear Mr. Renfrow: On July 6, 2016 I performed a Reconnaissance Inspection of the above referenced facility in response to a complaint. The complaint alleged that a 2016 Google Earth photo revealed open dumpsters, waste piles and other activities in the rear of the facility. The complaint also stated that the location previously had a Stormwater Permit along with other permits under AFIN 31-00252 when it was owned by Ox Bodies, Inc. This inspection was conducted in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. A copy of the inspection report is enclosed for your records. Please refer to the Summary of Findings section of the attached inspection report 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 e- mailed 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 August 22, 2016. If I can be of any assistance, please contact me at smithron@adeq.state.ar.us or 870-777-7585. Sincerely, Red Smith District 7 Field Inspector Water Division CC: John H. Wesson, Safety & Environmental Manager Page 1 of 7
Inspection Report: Husqvarna Plastics Nashville, AFIN: 31-00000, Permit #: ARR000000 FACILITY INFORMATION NAME: Husqvarna Plastics Nashville LOCATION: From intersection of Hwy 371 & N MainStreet go north for 2 miles on Hwy 980 and turn right onto Old airport Rd for.13 miles. Facility on left side. CITY: Nashville RESPONSIBLE OFFICIAL NAME: / TITLE Marty Renfrow / Plant Manager COMPANY: Husqvarna Plastics Nashville, LLC. MAILING ADDRESS: 139 Old Airport Road CITY, STATE, ZIP: Nashville AR 71852 PHONE & EXT: / FAX: 870-845-3198 / EMAIL: WATER DIVISION INSPECTION REPORT AFIN: 31-00000 PERMIT #: ARR000000 DATE: 7/6/2016 COUNTY: 31 Howard PDS #: 092153 MEDIA: WN GPS LAT: 33.033372 LONG: -93.839914 LOCATION: Entrance FACILITY TYPE: 2 - Industrial FACILITY EVALUATION RATING: 1 - Unsatisfactory INSPECTION INFORMATION INSPECTOR ID#: 26294 S - State DATE(S): ENTRY TIME: EXIT TIME: 7/6/2016 10:00 12:00 INSPECTION TYPE: Reconnaissance PERMIT EFFECTIVE DATE: PERMIT EXPIRATION DATE: FAYETTEVILLE SHALE RELATED: N FAYETTEVILLE SHALE VIOLATIONS: N INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/EMAIL/ETC.: Marty Renfrow / Plant Mgr. / 870-557-4595 c. Steve Harvill / Husqvarna Forestry Products Plant Mgr. / 870845-6788 Tony Cochran / Husqvarna Forestry Products marty.renfrow@husqvarnagroup.com CONTACTED DURING INSPECTION: Yes AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated) U PERMIT N FLOW MEASUREMENT N STORMWATER N RECORDS/REPORTS N LABORATORY S FACILITY SITE REVIEW S OPERATION & MAINTENANCE N EFFLUENT/RECEIVING WATER N SELF-MONITORING PROGRAM N SAMPLING N SLUDGE HANDLING/DISPOSAL N PRETREATMENT N OTHER: SUMMARY OF FINDINGS Husqvarna Plastics Nashville, LLC is a manufacturer of plastic products, has a Standard Industrial Classification (SIC) Code of 3089 and is not authorized to Discharge Stormwater Associated With Industrial Activity. This is a violation of the provisions of the Arkansas Water and Air Pollution Control Act and the Clean Water Act. The facility is required to obtain a Stormwater Industrial General Permit (ARR000000). GENERAL COMMENTS The facility was clean. There were several roll-off dumpsters of scrap materials such as rejected plastic parts, wood pallets, cardboard, and plastic wrap (pictures 4, 5, 6, 8, & 9). These dumpsters were open topped with non-seal rear doors. There was a lay down area for scrap steel (picture 10) on the east side of the property. The loading dock at the northwest corner of the facility had a sump pump installed with a line directly hooked up to a storm drain. I explained that area should be monitored for oil and grease before pumping. INSPECTOR S SIGNATURE: Red Smith DATE: 8/5/2016 SUPERVISOR S SIGNATURE: Jason Bolenbaugh DATE: 8/8/2016 Inspection Report Page 2 of 7
Inspection Report: Husqvarna Plastics Nashville, AFIN: 31-00000, Permit #: ARR000000 Water Division Photographic Evidence Sheet Location: Husqvarna Plastics Nashville Photographer: Red Smith Date: 7/6/2016 Time: 1050 Witness: Marty Renfrow, Steve Harvill, Tony Cochran Photo #: 1 Description: Pumps for the cooling system. Photographer: Red Smith Date: 7/6/2016 Time: 1053 Witness: Marty Renfrow, Steve Harvill, Tony Cochran 2 Description: Hose coming from sump in loading dock area going into storm drain. Inspection Report Page 3 of 7
Inspection Report: Husqvarna Plastics Nashville, AFIN: 31-00000, Permit #: ARR000000 Water Division Photographic Evidence Sheet Location: Husqvarna Plastics Nashville Photographer: Red Smith Date: 7/6/2016 Time: 1053 Witness: Marty Renfrow, Steve Harvill, Tony Cochran 3 Description: Sump in loading dock. Photographer: Red Smith Date: 7/6/2016 Time: 1055 Witness: Marty Renfrow, Steve Harvill, Tony Cochran 4 Description: Plastics and cardboard in dumpster going to Upper Southwest Landfill. Inspection Report Page 4 of 7
Inspection Report: Husqvarna Plastics Nashville, AFIN: 31-00000, Permit #: ARR000000 Water Division Photographic Evidence Sheet Location: Husqvarna Plastics Nashville Photographer: Red Smith Date: 7/6/2016 Time: 1055 Witness: Marty Renfrow, Steve Harvill, Tony Cochran 5 Description: More of the same as in picture 4 Photographer: Red Smith Date: 7/6/2016 Time: 1058 Witness: Marty Renfrow, Steve Harvill, Tony Cochran 6 Description: Looking at the aver all area at the rear of the facility. Inspection Report Page 5 of 7
Inspection Report: Husqvarna Plastics Nashville, AFIN: 31-00000, Permit #: ARR000000 Water Division Photographic Evidence Sheet Location: Husqvarna Plastics Nashville Photographer: Red Smith Date: 7/6/2016 Time: 1059 Witness: Marty Renfrow, Steve Harvill, Tony Cochran 7 Description: Compressor room. Photographer: Red Smith Date: 7/6/2016 Time: 1059 Witness: Marty Renfrow, Steve Harvill, Tony Cochran 8 Description: Roll off dumpster ready to go to Upper Southwest. Inspection Report Page 6 of 7
Inspection Report: Husqvarna Plastics Nashville, AFIN: 31-00000, Permit #: ARR000000 Water Division Photographic Evidence Sheet Location: Husqvarna Plastics Nashville Photographer: Red Smith Date: 7/6/2016 Time: 1109 Witness: Marty Renfrow, Steve Harvill, Tony Cochran 9 Roll-off dumpster with miscellaneous materials, i.e. pallets, cardboard, some metal. These materials Description: were sent to a recycler and sorted. Photographer: Red Smith Date: 7/6/2016 Time: 1110 Witness: Marty Renfrow, Steve Harvill, Tony Cochran 10 Description: Used metal stacked on east side of facility. Inspection Report Page 7 of 7
Response to ADEQ Water Division Inspection of Husqvarna Plastics Nashville on July 6, 2016 John Wesson, Safety & Environmental Manager, August 19, 2016 Photograph #1 & #2 Roll-off Dumpsters with tarpaulins covering tops Photo #1 Photo #2 Photo #4 Photo #3 Photographs #3 & #4 showing pallet storage and grounds. Husqvarna Forestry N.A., Inc. #1 Poulan Drive Nashville, AR 71852 1 (3)
Response to ADEQ Water Division Inspection of Husqvarna Plastics Nashville on July 6, 2016 John Wesson, Safety & Environmental Manager, August 19, 2016 Photo #5 Photo #6 Steel and other material, has been removed from east and north sides of the annex building. Photo #7 Photo #8 Open shed has been cleared of unused Material Covered locking switch for trained operator to check condition of water before pumping. Husqvarna Forestry N.A., Inc. #1 Poulan Drive Nashville, AR 71852 2 (3)
Response to ADEQ Water Division Inspection of Husqvarna Plastics Nashville on July 6, 2016 John Wesson, Safety & Environmental Manager, August 19, 2016 Photo #9 Photo #10 Sump pump switch with lock in place Overview of sump pump with new controls Husqvarna Forestry N.A., Inc. #1 Poulan Drive Nashville, AR 71852 3 (3)
August 29, 2016 Mr. John H. Wesson Safety and Environmental Manager Husqvarna Forestry Products #1 Poulan Drive Nashville, AR 71852 RE: Inspection Response Dear Mr. Wesson: I have reviewed the response pertaining to my July 6, 2016 inspection of the Husqvarna Plastics, Nashville facility. The information provided sufficiently addresses the violations referenced in my inspection report. At this time the Department has no further comment concerning this particular inspection. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. 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 870-777-7585 or you may e-mail me at smithron@adeq.state.ar.us. Sincerely, Red Smith District 7 Field Inspector Water Division