re: dierks mill expansion project inspection (howard co) afin: … · 2020. 1. 1. · inspection...

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July 10, 2015 Richard Murders, Plant Manager Weyerhaeuser NR Company PO Box 38 Dierks, AR 71833 RE: Dierks Mill Expansion Project Inspection (Howard Co) AFIN: 31-00016 NPDES Permit No.: ARR154738 Dear Mr. Murders: On June 30, 2015 I performed a Reconnaissance 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. 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 case has been referred directly to the Water Division Enforcement Branch for further review. Weyerhaeuser NR Company should immediately initiate all actions necessary to resolve and correct the violations cited in the inspection report. Written notification of the corrective actions taken for the violations must be submitted within thirty (30) calendar days from receipt of this letter to the attention of Richard Healey, Water Division Enforcement Branch Manager, at (501) 682-0649 or [email protected]. This written notification should include; but not limited to, photographs and/or copies of other documentation. If I can be of any assistance, please contact me at [email protected] or (479) 424-0333. Sincerely,

Dannielle Gray District 4 Field Inspector Water Division

mailto:[email protected]

Inspection Report: Dierks Mill Expansion Project, AFIN: 31-00016, Permit #: ARR154738

Inspection Report Page 2 of 14

WATER DIVISION INSPECTION REPORT AFIN: 31-00016 PERMIT #: ARR154738 DATE: 6/30/2015 COUNTY: 31 Howard PDS #: 085140 MEDIA: WN GPS LAT: 34.123104 LONG: -94.006938 LOCATION: Entrance

FACILITY INFORMATION INSPECTION INFORMATION NAME:

Dierks Mill Expansion Project LOCATION:

120 Main Ave. CITY:

Dierks, AR

FACILITY TYPE:

2 - Industrial INSPECTOR ID#:

71330 S - State FACILITY EVALUATION RATING:

N INSPECTION TYPE:

Reconnaissance DATE(S): ENTRY TIME: EXIT TIME:

6/30/2015 12:34 14:45

PERMIT EFFECTIVE DATE:

3/5/2015 PERMIT EXPIRATION DATE:

10/31/2016 RESPONSIBLE OFFICIAL

NAME: / TITLE

Richard Murders / Plant Manager COMPANY: Weyerhaeuser NR Company MAILING ADDRESS:

PO Box 38 CITY, STATE, ZIP: Dierks AR 71833 PHONE & EXT: / FAX:

870-286-4224 / 870-286-4241 EMAIL:

[email protected]

FAYETTEVILLE SHALE RELATED: N FAYETTEVILLE SHALE VIOLATIONS: N

INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/EMAIL/ETC.:

Donald McFarland, Construction Manager 870-286-2193 / [email protected] Shelly Boykin, Environmental Manager 870-286-4224 / [email protected]

CONTACTED DURING INSPECTION: *** AREA EVALUATIONS

(S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated) S PERMIT ** FLOW MEASUREMENT U STORMWATER ** RECORDS/REPORTS ** LABORATORY U FACILITY SITE REVIEW U OPERATION & MAINTENANCE U EFFLUENT/RECEIVING WATER U SELF-MONITORING PROGRAM ** SAMPLING ** SLUDGE HANDLING/DISPOSAL ** PRETREATMENT ** OTHER:

SUMMARY OF FINDINGS The following violations were noted during inspection:

1. An illicit discharge is occurring and causing pollution in Holly Creek. Specifically, sediment from the site is entering Holly Creek at two locations described in the General Comments below. The Arkansas Water and Air Pollution Control Act 8-4-217 (a)(1) states, “It shall be unlawful for any person to cause pollution, as defined in 8-4-102, of any of the waters of this State.”

2. Sediment controls installed are not adequate to control erosion from the site. This is a violation of Part

I, Section B.12.A.1 and B.12.A.5 of the permit.

3. Dewatering of the sediment pond is occurring resulting in contaminated discharges to Holly Creek. This is a violation of Part I, Section B.12.C of the permit.



GENERAL COMMENTS I inspected this facility in response to a complaint. The complaint alleged that Holly Creek downstream of Weyerhaeuser was very turbid and was receiving sediments not normally observed in the creek. Two sources of sediment pollution were identified during investigation. I began my investigation upstream of Weyerhaeuser at the Holly Creek bridge crossing on Reservoir Road. No excessive turbidity was noted at this location (Photo 1). I systematically worked my way downstream until I came upon observable turbidity in the stream. I did not note turbidity at the Hwy 278 bridge over Holly Creek (Photos 2-4). Turbidity and sediment pollution was noted on the downstream-side of the Holly Creek bridge on Mill Road adjacent to the ongoing Dierks Mill Expansion Project (Photos 5-7 and 10). On the upstream-side of the bridge, no turbidity was noted. Mr. Donald McFarland informed that they had had a rain event that washed away stormwater BMPs around the crane pad construction area immediately adjacent to Holly Creek and Mill Road. As a result, sediment had been released to the creek. Mr. McFarland further explained that efforts were underway to repair the ditch and install additional BMPs (Photo 8). At the time of investigation, sediments were lining the ditch up to its confluence with Holly Creek (Photos 7 and 9). Upon identifying the above source of pollution, we continued downstream. I observed a second source of pollution: a direct discharge of turbid waters leaving the construction site and entering Holly Creek (Photos 13 and 14). It was not raining during investigation, and the water was entering the creek rapidly. We sourced this water to a slough on the west-side of the construction area adjacent to the railroad tracks (Photo 11 and 12). Water was entering the slough from the sediment pond (Photos 15 and 16). A contractor onsite stated that an 8” secondary drainage had been installed in the sediment pond and was open, and they were dewatering the sediment pond. I advised Mr. McFarland to cease dewatering activities immediately. Samples were collected by Ms. Kerri McCabe, ADEQ Inspector Supervisor, on June 30, 2015. Results are included with this report (Attachment 1). Following inspection, Mr. McFarland sent an email regarding the findings of my investigation. That email is attached as Attachment 2.

INSPECTOR’S SIGNATURE: Dannielle Gray DATE: 7/9/2015

SUPERVISOR’S SIGNATURE: Kerri McCabe DATE: 7/9/2015



Water Division Photographic Evidence Sheet Location: Dierks Mill Expansion Project Photographer: Dannielle Gray Date: 6/30/2015 Time: 1317 Witness: Donald McFarland & Shelly Boykin Photo #: 1

Description: Holly Creek from Reservoir Road bridge at 34.124367, -94.001633; facing upstream – upstream of illicit discharge.

Photographer: Dannielle Gray Date: 6/30/2015 Time: 1325 Witness: Donald McFarland & Shelly Boykin Photo #: 2

Description: Holly Creek from Hwy 278 bridge at 34.123458, -94.007983; facing upstream – upstream of illicit discharge.



Water Division Photographic Evidence Sheet

Location: Dierks Mill Expansion Project Photographer: Dannielle Gray Date: 6/30/2015 Time: 1325 Witness: Donald McFarland & Shelly Boykin Photo #: 3 Description: Close-up of Photo 2 showing clear water upstream of Weyerhaeuser.


Description: Holly Creek from Hwy 278 bridge at 34.123383, -94.007633; facing downstream – upstream of illicit discharge.



Water Division Photographic Evidence Sheet Location: Dierks Mill Expansion Project Photographer: Dannielle Gray Date: 6/30/2015 Time: 1331 Witness: Donald McFarland & Shelly Boykin Photo #: 5

Description: Holly Creek from Mill road bridge at 34.120847, -94.007702 - facing downstream. Note turbidity.

Photographer: Dannielle Gray Date: 6/30/2015 Time: 1333 Witness: Donald McFarland & Shelly Boykin Photo #: 6 Description: Mill road bridge over Holly Creek; facing north east.




Location: Dierks Mill Expansion Project Photographer: Dannielle Gray Date: 6/30/2015 Time: 1335 Witness: Donald McFarland & Shelly Boykin Photo #: 7 Description: Sediment entering Holly Creek from construction site to the northeast.

Photographer: Dannielle Gray Date: 6/30/2015 Time: 1345 Witness: Donald McFarland & Shelly Boykin Photo #: 8 Description: Ditch maintenance occurring immediately upstream of Holly Creek.




Location: Dierks Mill Expansion Project Photographer: Dannielle Gray Date: 6/30/2015 Time: 1348 Witness: Donald McFarland & Shelly Boykin Photo #: 9 Description: Sediments lining channel in drainage towards Holly Creek.

Photographer: Dannielle Gray Date: 6/30/2015 Time: 1336 Witness: Donald McFarland & Shelly Boykin Photo #: 10 Description: Turbidity in immediate vicinity where sediment entered Holly Creek from inadequate stormwater controls around crane pad construction site.




Location: Dierks Mill Expansion Project Photographer: Dannielle Gray Date: 6/30/2015 Time: 1357 Witness: Donald McFarland & Shelly Boykin Photo #: 11 Description: Slough perpendicular to Holly Creek; sediment pond from construction site drains to this slough.

Photographer: Dannielle Gray Date: 6/30/2015 Time: 1353 Witness: Donald McFarland & Shelly Boykin Photo #: 12 Description: Slough in Photo 11 above draining through rock dam to Holly Creek.




Location: Dierks Mill Expansion Project Photographer: Dannielle Gray Date: 6/30/2015 Time: 1354 Witness: Donald McFarland & Shelly Boykin Photo #: 13 Description: Confluence of construction site slough and Holly Creek – turbid waters entering Holly Creek.

Photographer: Dannielle Gray Date: 6/30/2015 Time: 1356 Witness: Donald McFarland & Shelly Boykin Photo #: 14 Description: Holly Creek immediately downstream of confluence of construction site slough and Holly Creek.



Water Division Photographic Evidence Sheet Location: Dierks Mill Expansion Project Photographer: Dannielle Gray Date: 6/30/2015 Time: 1406 Witness: Donald McFarland & Shelly Boykin Photo #: 15 Description: Sediment pond; metal culvert in photo left contains 8” secondary drain.


Description: Sediment pond showing waters not high enough to drain from pond overflow (cement box left).



Water Division Photographic Evidence Sheet Location: Dierks Mill Expansion Project Photographer: Dannielle Gray Date: 6/30/2015 Time: 1413 Witness: Donald McFarland & Shelly Boykin Photo #: 17 Description: Standpipe contains shut off for secondary drain valve in sediment pond.


Description: Holly Creek from the South Arkansas Avenue bridge - facing upstream (downstream of illicit discharge).



Figure 1: Google Earth image dated Nov 16, 2014 showing area of investigation.

5301 Northshore Drive

North Little Rock, AR 72118

Telephone: 501-682-0744

Client Report For: District 12 Routine+Metals 2015 1720-1721Attention:

Client Address:

, AR

Report Date: July 08, 2015LAB ID: AR15JUL01-06Comment:

Approved By:__________________________________ Date:July 08, 2015

Page 1 of 3

Client: District 12 Client Sample ID: RED0034B

Lab ID: 2015-1720 Collection Date: 6/30/2015 9:05:00 AM

Matrix: Water

Analyses

Turbidity EPA 180.1 Batch: 15070207 Run: 1

Result Reporting Limit

MDL Qual Unit

Turbidity 110 0.02 0.02 NTUDilution Factor 1Analyzed By Kathryn HattenhauerAnalysis Date/Time 7/1/2015 14:02

Page 2 of 3

[email protected] Ruehr

North Liitle Rock, AR 721185301 Northshore DriveArkansas Department of Environmental Quality Laboratory Contact:

Client: District 12 Client Sample ID: RED0034A

Lab ID: 2015-1721 Collection Date: 6/30/2015 9:23:00 AM

Matrix: Water

Analyses

Turbidity EPA 180.1 Batch: 15070207 Run: 1

Result Reporting Limit

MDL Qual Unit

Turbidity 5.68 0.02 0.02 NTUDilution Factor 1Analyzed By Kathryn HattenhauerAnalysis Date/Time 7/1/2015 14:04

Page 3 of 3

[email protected] Ruehr

North Liitle Rock, AR 721185301 Northshore DriveArkansas Department of Environmental Quality Laboratory Contact:



Attachment 2: Email from Mr. Donald McFarland regarding inspection. Gray, Dannielle From: McFarland, Donald Sent: Thursday, July 02, 2015 11:50 AM To: Gray, Dannielle Cc: Boykin, Shelly; Nolan, Michael Subject: Follow up from Dierks, AR site inspection on June, 30 2015 Dannielle, We just wanted to follow up with you on your Weyerhaeuser Dierks site visit from June 30, 2015. We have completed and initiated the listed corrective actions to help improve the existing stormwater BMPs. We felt it was important to give you an update and let you know that we are taking the stormwater management very seriously.

• We have blanked off both the 48” RCP pipe at the inlet structure. • We have ensured that the 8” skimmer valve is fully closed while Weyerhaeuser is making the BMP

improvements. We will open the standpipe filter/skimmer valve open once we have completed the corrective actions.

• We are in the process of pumping the stormwater from the drainage ditch prior to Holly Creek and back into the new settling pond to better allow us to stabilize the drainage ditch without the disturbing the stormwater in the ditch. This pumping will also help reduce the stormwater flow from filtering into Holly Creek until Weyerhaeuser completes the improvements to the site BMPs.

• We are in process of stabilizing the soils near the drainage ditch and installing a check dam to help increase the stormwater settling time.

• We have met with our engineering group and FTN (the company that we had help us write up our SWPPP) to devise a corrective action plan to improve the stormwater quality and are in the process of implementing these plans.

• We are in the process of improving and adding additional BMP’s to better manage the stormwater suspended solids at low flow conditions. These BMPs include: installing additional silt fencing, straw bales and rock check dams to improve filtration and sedimentation control; stabilizing disturbed soils near the drainage ditch to Holly Creek; and reviewing the potential for passive suspended solids treatment during low flow/settling pond skimmer conditions.

• We have scheduled our Silt Fencing contractor to add additional silt fencing along the drainage ditch area and install silt stop floc logs in appropriate areas. Contractor should arrive 7‐7‐2015 to add additional silt fencing and other control measures.

On the 8” pipe that we had talked about during your inspection, the 8” line is connected the standpipe filter/skimmer from the main settling pond as designed. This standpipe filter/skimmer system is being used to help filter the suspended solids and increase stormwater sedimentation time. As designed the stormwater slowly filters through the system and slowly lowers (increases stormwater surge capacity) the settling pond water levels passively. Please do not hesitate to call or email if you have any questions or concerns. Let safety be your uncompromisable core value in all that you do. Donald McFarland Construction Manager Weyerhaeuser Engineering Services Cell: (903) 932‐8165 Fax: (253) 928‐1918

From: Healey, RichardTo: Trotta, Jacqueline; Gray, DannielleCc: Bolenbaugh, Jason; McCabe, Kerri; McConnell, MelissaSubject: FW: Response to Dierks Mill Expansion Project Inspection 7-10-15 Letter AFIN: 31-00016, NPDES Permit No.:

ARR154738Date: Tuesday, August 11, 2015 4:31:20 PMAttachments: Response to 7-10-15 ADEQ Inspection Letter.pdf

FYI

Richard C. HealeyEnforcement Branch ManagerWater DivisionArkansas Department of Environmental [email protected]

From: Boykin, Shelly [mailto:[email protected]] Sent: Tuesday, August 11, 2015 4:13 PMTo: Healey, RichardCc: Murders, Richard; Nolan, Michael; McFarland, DonaldSubject: Response to Dierks Mill Expansion Project Inspection 7-10-15 Letter AFIN: 31-00016, NPDESPermit No.: ARR154738 Mr. Healey, Attached is Weyerhaeuser Dierks Mill’s response letter addressing findings from a ReconnaissanceInspection performed by ADEQ’s Dannielle Gray on June 30, 2015. Should you have any questions, please feel free to contact me at one of the numbers below orRichard Murders at 870-286-4235. Thank you. Shelly BoykinEnvironmental ManagerWeyerhaeuser CompanyPO Box 38 - 120 Main AvenueDierks, AR 71833870-286-4224 (Office)870-784-2710 (Cell)870-286-4241 (Fax)

mailto:/O=ARKANSAS DEPT. OF ENVIRONMENTAL QUALITY/OU=ADEQ1/CN=RECIPIENTS/CN=MAIL BOXES/CN=HEALEYRmailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]

Mid-South Lumber

PO Box 38 120 Main Avenue Dierks, AR 71833 Phone: 870-286-4235 Fax: 870-286-4268 [email protected]

August 11, 2015 Mr. Richard Healey Arkansas Department of Environmental Quality Water Division Enforcement Branch Manager 5301 Northshore Drive North Little Rock, AR 72118-5317 Email: [email protected] RE: Weyerhaeuser Dierks Mill NPDES Permit No. AAR154738; AFIN 31-00016 Response to Inspection Report Dear Mr. Healey: In response to the Arkansas Department of Environmental Quality’s (ADEQ) letter dated July 10, 2015, Weyerhaeuser is submitting this notification of the corrective actions taken for the ADEQ inspection findings. This series of correspondence and response is related to Weyerhaeuser’s efforts to improve the site stormwater conditions and runoff. Below we have listed our response to each ADEQ finding in your letter of July 10, 2015 and photographs of the corrective action improvements are attached to this letter for your reference. ADEQ Listed Finding:

1. An illicit discharge is occurring and causing pollution in Holly Creek. Specially, sediment form the site is entering Holly Creek at two locations described in the General Comments below. [1- Turbidity and sediment pollution was noted on the downstream-side of the Holly Creek bridge on the Mill Road adjacent to the ongoing Dierks Mill Expansion Project. 2- A direct discharge of turbid waters leaving the construction site and entering Holly Creek.] The Arkansas Water and Air Pollution Control Act 8-4-217 (a)(1) states, “It shall be unlawful for any person to cause pollution, as defined in 8-4-102, of any of the waters of the State.”;

Weyerhaeuser Response:

1a. Weyerhaeuser blanked-off (boarded) the Stormwater Basin 1 overflow discharge structure and 48” pipe on June 30, 2015. This was done to increase the temporary stormwater basin storage capacity, increase stormwater settling time, and reduce the frequency of the stormwater discharging from Stormwater Basin 1 while Weyerhaeuser implemented corrective actions measures. See Photo 1.

1


1b. Weyerhaeuser also began pumping turbid stormwater from the main drainage ditch (prior to Holly Creek) back into Stormwater Basin 1. This pump back system helped reduce the turbid stormwater flow from filtering into Holly Creek until Weyerhaeuser fully completes the improvements to the site BMPs, which include stabilizing the main drainage ditch.

1c. The stormwater drainage ditch along the North side of the Radial Crane is in the process of being diverted to Stormwater Basin 1 so that it will no longer drain directly to Holly Creek. Photo 2 shows the work that has been performed on this drainage ditch diversion. We anticipate that this work will be completed by August 14, 2015.

ADEQ Listed Finding:

2. Sediment controls installed are not adequate to control erosion from the site. This is a violation of Part I, Section B.12.A.1 and B.12.A.5 of the permit.;


2a. During the month of May and June, the Weyerhaeuser site received approximately 25.06 inches of rainfall based upon daily records at the mill site. With 20.41 inches in May and 4.65 inches in June; the unusual amount of rainfall did impact Weyerhaeuser’s performance of some of the BMPs. These impacted BMPs, along with the implemented corrective action plans, have improved the management of stormwater and erosion.

2b. Weyerhaeuser met with the design engineering group and FTN Associates, Ltd. to help develop the summarized corrective action plans to improve the site BMPs that were not adequate.

2c. Weyerhaeuser has improved existing BMPs and is implementing additional BMPs to better manage the stormwater erosion and suspended solids. These BMPs/corrective actions include:

a. Weyerhaeuser is in the process of stabilizing the soils within and around the final drainage ditch and will install check dams to help increase the stormwater settling time. Double rows of silt fencing will be added near the Radial Crane slope. Expected completion date: 8-21-2015.

b. Straw bale check dams in low flow drainage channels will be added. Expected completion date: 8-21-2015.

c. Rock check dams in higher flow drainage channels. d. The drainage channel (identified as a slough in the ADEQ inspection report) west of the Radial

Crane pad is in the process of being re-graded and the channel side slopes will be armored with riprap. As per the site grading plans, this channel will serve as the permanent receiving point for water discharged from Basin No. 1. Expected completion date: 8-21-2015.

e. Diverting stormwater to Stormwater Basin 1. f. The Radial Crane pad exterior side slopes have been seeded and covered with straw mulch. To

promote the growth of vegetation, the side slopes will be watered as required to help with germination and vegetation establishment. This work has been completed and is shown in Photo 3.

g. Final grading and seeding has been performed on the slopes immediately adjacent to Basin No. 1. This work has been completed and is shown in Photo 4.

h. The roadway on top of the Radial Crane slope has been covered with gravel to help with the stabilization of the roadway.

2

i. A stormwater diversion berm is being added to the top of the Radial Crane slope to divert the stormwater to Basin 1 instead of discharging down the slope to the silt fences. Expected completion date: 8-14-2015.

j. The height of the Stormwater Basin 1 standpipe will be increased and the filter fabric will be replaced. These improvements are being proposed to allow for more efficient removal of suspended solids and draining of Basin No. 1. Expected completion date: 8-28-2015.

k. Passive flocculent aids will be installed in the storm drainage pipes that drain into Stormwater Basin 1. These passive flocculent aids will promote the settling of suspended solids in Basin No. 1. Expected completion date: 8-21-2015.

l. Some of the new mill roadways that are at final grade have been covered with gravel. m. A significant portion of the site construction is near final grade and as planned stormwater BMPs

have been added to the permanent storm drainage facilities installed at the site. The temporary drainage ditches from these areas are in the process of being removed and replaced by these permanent drainage facilities. Expected completion date: 9-11-2015.

n. Areas where no building structures or roadways are planned and where final grade has been established have been covered with topsoil and seeded and/or stabilized with straw mulch or erosion control matting.

o. The suspended solids in the water being held in Stormwater Basin No. 1 have been slow to settle. Weyerhaeuser has contacted a company who specializes in water clarification in order to lower the turbidity of the stormwater in the sediment pond and slough area for discharge to Holly Creek in a controlled manner and in accordance with the Construction Stormwater Pollution Prevention Plan. Expected completion date: 8-28-2015.


3. Dewatering of the sediment pond is occurring resulting in contaminated discharges to Holly Creek. This is a violation of Part I, Section B.12.C of the permit.;


3a. The above referenced inspection finding states that Weyerhaeuser was dewatering the sediment pond Basin 1. The stormwater sedimentation Basin 1 was not being dewatered as defined in the permit. The stormwater was passively being filtered through filter fabric wrapped around a fixed perforated standpipe drain and not considered a dewatering activity. The system was being operated as designed to slowly and passively release the stormwater to allow more settling time and filtration of the stormwater. While Weyerhaeuser was not conducting a dewatering of the stormwater basin as defined in the Permit, we understand ADEQ’s concern with the observed turbidity of the water. Although, the standpipe filter skimmer was working as designed, the soil type within the construction zone does not settle as expected and the suspended soil particles were staying suspended even with these extended settling times. Therefore, Weyerhaeuser did temporarily close the 8 inch valve for the stormwater standpipe filter skimmer in Stormwater Basin 1. Weyerhaeuser also implemented additional corrective actions/BMPs to help reduce the stormwater total suspended solids (TSS) in the Basin 1 before re-opening the passive skimmer system. Weyerhaeuser believes that the ADEQ-referenced dewatering of the stormwater basin was not a dewatering activity as defined in the Permit. During the inspection, the stormwater was being discharged from the passive standpipe filter skimmer system and not actively being dewatered (as defined by the Permit).

3

Attachment 1

Photo 1. We have blocked off the 48” drainage pipe and closed the 8” valve to keep water from entering the slough area. Matches ADEQ pic # 16 and 17

Photo 2. Have started re-routing the drainage ditch around the circle crane back towards

the sediment pond. Matches ADEQ Picture No. 8.

Photo 3. We have seeded the slope of the crane mound area and added double silt fencing to keep sediment from entering the slough area and Holly Creek area.

Photo 4. Seeding complete and grass starting to grow up around the sediment pond basin.

Photo 5. Picture off of Log Haul Bridge matches up with ADEQ Picture Nos. 5, 6, and 7.

Photo 6. Looking at the slough release point into Holly Creek. Matches up with ADEQ Picture Nos. #13 and 14.

Photo 7. Old entrance into Holly Creek from drainage ditch on SW side of circle crane

mound area. Matches ADEQ Picture No. 9.

Photo 8. Water going through gauge area in Holly Creek. Water is clear.

2015-08-11 Weyer Ltr to ADEQ - SW Construction Response (no sig page)

signature page

Photo Log

Mid-South Lumber

PO Box 38 120 Main Avenue Dierks, AR 71833 Phone: 870-286-4235 Fax: 870-286-4268 [email protected]

August 11, 2015 Mr. Richard Healey Arkansas Department of Environmental Quality Water Division Enforcement Branch Manager 5301 Northshore Drive North Little Rock, AR 72118-5317 Email: [email protected] RE: Weyerhaeuser Dierks Mill NPDES Permit No. AAR154738; AFIN 31-00016 Response to Inspection Report Dear Mr. Healey: In response to the Arkansas Department of Environmental Quality’s (ADEQ) letter dated July 10, 2015, Weyerhaeuser is submitting this notification of the corrective actions taken for the ADEQ inspection findings. This series of correspondence and response is related to Weyerhaeuser’s efforts to improve the site stormwater conditions and runoff. Below we have listed our response to each ADEQ finding in your letter of July 10, 2015 and photographs of the corrective action improvements are attached to this letter for your reference. ADEQ Listed Finding:

1. An illicit discharge is occurring and causing pollution in Holly Creek. Specially, sediment form the site is entering Holly Creek at two locations described in the General Comments below. [1- Turbidity and sediment pollution was noted on the downstream-side of the Holly Creek bridge on the Mill Road adjacent to the ongoing Dierks Mill Expansion Project. 2- A direct discharge of turbid waters leaving the construction site and entering Holly Creek.] The Arkansas Water and Air Pollution Control Act 8-4-217 (a)(1) states, “It shall be unlawful for any person to cause pollution, as defined in 8-4-102, of any of the waters of the State.”;


1a. Weyerhaeuser blanked-off (boarded) the Stormwater Basin 1 overflow discharge structure and 48” pipe on June 30, 2015. This was done to increase the temporary stormwater basin storage capacity, increase stormwater settling time, and reduce the frequency of the stormwater discharging from Stormwater Basin 1 while Weyerhaeuser implemented corrective actions measures. See Photo 1.

1


1b. Weyerhaeuser also began pumping turbid stormwater from the main drainage ditch (prior to Holly Creek) back into Stormwater Basin 1. This pump back system helped reduce the turbid stormwater flow from filtering into Holly Creek until Weyerhaeuser fully completes the improvements to the site BMPs, which include stabilizing the main drainage ditch.

1c. The stormwater drainage ditch along the North side of the Radial Crane is in the process of being diverted to Stormwater Basin 1 so that it will no longer drain directly to Holly Creek. Photo 2 shows the work that has been performed on this drainage ditch diversion. We anticipate that this work will be completed by August 14, 2015.


2. Sediment controls installed are not adequate to control erosion from the site. This is a violation of Part I, Section B.12.A.1 and B.12.A.5 of the permit.;


2a. During the month of May and June, the Weyerhaeuser site received approximately 25.06 inches of rainfall based upon daily records at the mill site. With 20.41 inches in May and 4.65 inches in June; the unusual amount of rainfall did impact Weyerhaeuser’s performance of some of the BMPs. These impacted BMPs, along with the implemented corrective action plans, have improved the management of stormwater and erosion.

2b. Weyerhaeuser met with the design engineering group and FTN Associates, Ltd. to help develop the summarized corrective action plans to improve the site BMPs that were not adequate.

2c. Weyerhaeuser has improved existing BMPs and is implementing additional BMPs to better manage the stormwater erosion and suspended solids. These BMPs/corrective actions include:

a. Weyerhaeuser is in the process of stabilizing the soils within and around the final drainage ditch and will install check dams to help increase the stormwater settling time. Double rows of silt fencing will be added near the Radial Crane slope. Expected completion date: 8-21-2015.

b. Straw bale check dams in low flow drainage channels will be added. Expected completion date: 8-21-2015.

c. Rock check dams in higher flow drainage channels. d. The drainage channel (identified as a slough in the ADEQ inspection report) west of the Radial

Crane pad is in the process of being re-graded and the channel side slopes will be armored with riprap. As per the site grading plans, this channel will serve as the permanent receiving point for water discharged from Basin No. 1. Expected completion date: 8-21-2015.

e. Diverting stormwater to Stormwater Basin 1. f. The Radial Crane pad exterior side slopes have been seeded and covered with straw mulch. To

promote the growth of vegetation, the side slopes will be watered as required to help with germination and vegetation establishment. This work has been completed and is shown in Photo 3.

g. Final grading and seeding has been performed on the slopes immediately adjacent to Basin No. 1. This work has been completed and is shown in Photo 4.

h. The roadway on top of the Radial Crane slope has been covered with gravel to help with the stabilization of the roadway.

2

i. A stormwater diversion berm is being added to the top of the Radial Crane slope to divert the stormwater to Basin 1 instead of discharging down the slope to the silt fences. Expected completion date: 8-14-2015.

j. The height of the Stormwater Basin 1 standpipe will be increased and the filter fabric will be replaced. These improvements are being proposed to allow for more efficient removal of suspended solids and draining of Basin No. 1. Expected completion date: 8-28-2015.

k. Passive flocculent aids will be installed in the storm drainage pipes that drain into Stormwater Basin 1. These passive flocculent aids will promote the settling of suspended solids in Basin No. 1. Expected completion date: 8-21-2015.

l. Some of the new mill roadways that are at final grade have been covered with gravel. m. A significant portion of the site construction is near final grade and as planned stormwater BMPs

have been added to the permanent storm drainage facilities installed at the site. The temporary drainage ditches from these areas are in the process of being removed and replaced by these permanent drainage facilities. Expected completion date: 9-11-2015.

n. Areas where no building structures or roadways are planned and where final grade has been established have been covered with topsoil and seeded and/or stabilized with straw mulch or erosion control matting.

o. The suspended solids in the water being held in Stormwater Basin No. 1 have been slow to settle. Weyerhaeuser has contacted a company who specializes in water clarification in order to lower the turbidity of the stormwater in the sediment pond and slough area for discharge to Holly Creek in a controlled manner and in accordance with the Construction Stormwater Pollution Prevention Plan. Expected completion date: 8-28-2015.


3. Dewatering of the sediment pond is occurring resulting in contaminated discharges to Holly Creek. This is a violation of Part I, Section B.12.C of the permit.;


3a. The above referenced inspection finding states that Weyerhaeuser was dewatering the sediment pond Basin 1. The stormwater sedimentation Basin 1 was not being dewatered as defined in the permit. The stormwater was passively being filtered through filter fabric wrapped around a fixed perforated standpipe drain and not considered a dewatering activity. The system was being operated as designed to slowly and passively release the stormwater to allow more settling time and filtration of the stormwater. While Weyerhaeuser was not conducting a dewatering of the stormwater basin as defined in the Permit, we understand ADEQ’s concern with the observed turbidity of the water. Although, the standpipe filter skimmer was working as designed, the soil type within the construction zone does not settle as expected and the suspended soil particles were staying suspended even with these extended settling times. Therefore, Weyerhaeuser did temporarily close the 8 inch valve for the stormwater standpipe filter skimmer in Stormwater Basin 1. Weyerhaeuser also implemented additional corrective actions/BMPs to help reduce the stormwater total suspended solids (TSS) in the Basin 1 before re-opening the passive skimmer system. Weyerhaeuser believes that the ADEQ-referenced dewatering of the stormwater basin was not a dewatering activity as defined in the Permit. During the inspection, the stormwater was being discharged from the passive standpipe filter skimmer system and not actively being dewatered (as defined by the Permit).

3

Attachment 1

Photo 1. We have blocked off the 48” drainage pipe and closed the 8” valve to keep water from entering the slough area. Matches ADEQ pic # 16 and 17

Photo 2. Have started re-routing the drainage ditch around the circle crane back towards

the sediment pond. Matches ADEQ Picture No. 8.

Photo 3. We have seeded the slope of the crane mound area and added double silt fencing to keep sediment from entering the slough area and Holly Creek area.

Photo 4. Seeding complete and grass starting to grow up around the sediment pond basin.

Photo 5. Picture off of Log Haul Bridge matches up with ADEQ Picture Nos. 5, 6, and 7.

Photo 6. Looking at the slough release point into Holly Creek. Matches up with ADEQ Picture Nos. #13 and 14.

Photo 7. Old entrance into Holly Creek from drainage ditch on SW side of circle crane

mound area. Matches ADEQ Picture No. 9.

Photo 8. Water going through gauge area in Holly Creek. Water is clear.

ARR154738_insp resp_20150811.pdfFW_ Response to Dierks Mill Expansion Project Inspection 7-10-15 Letter AFIN_ 31-00016, NPDES Permit No._ ARR154738Response to 7-10-15 ADEQ Inspection Letter (2)2015-08-11 Weyer Ltr to ADEQ - SW Construction Response (no sig page)signature pagePhoto Log

re: dierks mill expansion project inspection (howard co) afin: … · 2020. 1. 1. · inspection...

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