united states environmental protection … · one waste cardboard dumpster and one scrap metal...

NPDES Industrial No-Exp. Storm Water AFIN: 42-00078 Permit #: ARR00A572

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C. 20460

NPDES Compliance Inspection Report

Form Approved

OMB No. 2040-0003 Approval Expires 7-31-85

Section A: National Data System Coding

Transaction Code

NPDES

Yr/Mo/Day

Inspec. Type

Inspector

Fac. Type

1 N 2 5 3 A R R 0 0 A 5 7 2 11 12 1 2 0 3 1 2 17 18 C 19 S 20 2

Remarks

-

Inspection Work Days

Facility Evaluation Rating

BI

QA

-------------------------------Reserved------------------------------

67

69

70 4

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)

Stark Manufacturing, LLC

310 Pennington Dr, Paris, AR 72855

Entry Time/Date

1000/ 3/12/12

Permit Effective Date

6/8/10 Exit Time/Date

1030/ 3/12/12

Permit Expiration Date

6/30/14

Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s)

Sonia Parham/ Safety/ 479-963-3046

Note: Mike Koehler is on permit but no longer with company.

Other Facility Data

PDS# 064397

Name, Address of Responsible Official/Title/Phone and Fax Number

Sonia Parham/ Safety/ 479-963-3046

Note: Mike Koehler is on permit but no longer with company.

310 Pennington Dr, Paris, AR 72855

Contacted

Yes No

Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated)

S 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 M

Storm Water N

Other:

Section D: Summary of Findings/Comments (Attach additional sheets if necessary)

Met with Sonia Parham (Safety) during the inspection. Ms. Parham walked the facility grounds with me.

One waste cardboard dumpster and one scrap metal dumpster un-covered (Also additional empty dumpster un-covered). Solids were on the ground near a dock (possibly metal dust/blasting material).

Name(s) and Signature(s) of Inspector(s)

Travis Harmon

Agency/Office/Telephone/Fax

Arkansas Department of Environmental Quality /

Russellville / 479-968-7339 x 14 / 479-968-7321

Date

Signature of Reviewer

Agency/Office/Phone and Fax Numbers

Date

NPDES Industrial No-Exp. Storm Water AFIN: 42-00078 Permit #: ARR00A572

No Exposure Exclusion Verification

Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future? Answering Yes to any of these questions indicates the facility is not eligible for the No Exposure Exclusion.

a. Using, storing, or cleaning industrial machinery or equipment, and areas where residuals from using, storing, or cleaning industrial machinery or equipment remain and are exposed to storm water.

Y N

Comments:

b. Are materials or residuals on the ground or in storm water inlets from spills/leaks. Y N

Comments: metal dust or blast material on ground near loading dock.

c. Are materials or products from past industrial activity exposed. Y N

Comments:

d. Is material handling equipment exposed (except adequately maintained vehicles). Y N

Comments:

e. Are materials or products during loading/unloading or transporting activities exposed. Y N

Comments:

f. Materials or products stored outdoors (except final products intended for outside use [e.g., new cars] where exposure to storm water does not result in the discharge of pollutants).

Y N

Comments:

g. Materials contained in open, deteriorated, or leaking storage drums, barrels, tanks, and similar containers. Y N

Comments:

h. Materials or products handled/stored on roads or railways owned or maintained by the discharger. Y N

Comments:

i. Waste materials exposed (except waste in covered, non-leaking containers [e.g., dumpsters]). Y N

Comments: Un-covered dumpsters during inspection (3: 1 cardboard, 1 scrap metal, 1 empty).

j. Application or disposal of process wastewater (unless otherwise permitted). Y N

Comments:

k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated (i.e., under an air quality control permit) and evident in the storm water outflow.

Y N

Comments:

General Comments: Inspected 3/12/12. Met with Sonia Parham (Safety) during the inspection. Ms. Parham walked the facility grounds with me. Violations: (b) One waste cardboard dumpster and one scrap metal dumpster un-covered (Also additional empty dumpster un-covered). (i) Solids on ground near dock (possibly metal dust/blasting material). Other: Pallets stacked outside. I did not see any obvious contaminants on the pallets at the time of inspection. The facility should inspect pallets and store any dirty or contaminated pallets under cover.

March 19, 2012 Sonia Parham Stark Manufacturing, LLC 310 Pennington Dr. Paris, AR 72855 AFIN: 42-00078 NPDES Permit No.: ARR00A572 Dear Ms. Parham: On March 12, 2012, I performed a routine compliance inspection of the waste water 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. Un-covered waste dumpsters in use at the facility. Some solids on the ground. This conflicts the requirements of No exposure (Part I, 1.8). One waste cardboard dumpster and one scrap metal dumpster un-covered (Also additional empty dumpster un-covered). Solids were on the ground near a dock (possibly metal dust/blasting material). All dumpsters should be covered or located under cover to prevent materials from coming into contact with storm water. Spilled materials should be cleaned up using dry methods.

This response should be mailed to the address below, or e-mailed to [email protected]. 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 documentations (i.e. photos) is due by March 30, 2012. For additional information you may contact the Enforcement Branch by telephone at 501-682-0639 or by fax at 501-682-0880. Other comments: The facility has pallets stacked outside. I did not see any obvious contaminants on the pallets at the time of inspection. The facility should inspect pallets and store any dirty or contaminated pallets under cover. If I can be of any assistance, please contact me at [email protected] or at 479-968-7339 extension 14. Sincerely,

Travis Harmon District 5 Field Inspector Water Division cc: Water Division Enforcement Branch

Water Division Permits Branch

mailto:[email protected]:[email protected]:[email protected]

From: Sawyer, SamTo: Allen-Daniel, LeslieSubject: FW: Response to AFIN:42-00078Date: Friday, March 30, 2012 1:57:20 PMAttachments: CAR2042 .pdf

CAR 2041 .pdfTraining record.pdf

From: [email protected] [mailto:[email protected]] Sent: Friday, March 30, 2012 1:35 PMTo: Water-Enforcement-ReportCc: [email protected]; [email protected]; [email protected]: Response to AFIN:42-00078 NPDES Permit No.: ARR00A572

Below are the corrective actions taken for the No Exposure Exclusion Verification findings from a

routine compliance inspection on 3/12/12.

b. metal dust or blast material on ground near loading dock - Corrective Action,

i. un-covered dumpters during inspection (3: 1 cardboard, 1 scrap metal, 1 empty) - Corrective

Action, ,

Please contact me if you have any questions.

God bless and keep you,

Sonia Parham Safety/Training Coordinator Stark Mfg LLC 310 Pennington Dr Paris, AR 72855 1-479-963-3046 ext. 1204

When one door closes another door opens; but we so often look so long and so regretfully upon the closed door, that we do not see the oneswhich open for us. ~Alexander Graham Bell~
mailto:/O=ARKANSAS DEPT. OF ENVIRONMENTAL QUALITY/OU=ADEQ1/CN=RECIPIENTS/CN=MAIL BOXES/CN=SAWYERmailto:[email protected]

Corrective Action Report:

CAR Number: 2042 CAR Open Date: 03/27/2012 Opened By Sonia Parham

Source: InternalAudit

(check one)

System Non Conformance

Part Non Conformance

Management Review Issue

Customer / 3rd Party Non Conformance

Safety Issue

Environmental Issue

Assigned To: AndrewWelch

Status: Open Response Due04/10/2012Revised Due date 04/10/2012

Department: Production

CAN or NCR Ref. No. Element:

DESCRIBE THE PROBLEM:If problem is product related then list FULL Customer Part Number & Cell Number here

P.N. / Cell # / Problem Category:Defects: out of

PROBLEM

Metal dust or blast material on ground near loading dock

1. CONTAINMENTISOLATE & CONTAIN SUSPECT PARTSLink to DMA record, if appropriate to CAR -->

2. PLAN (Root Cause Analysis)Step 1. Restate the problemStep 2. Using brainstorming rules, list as many causes as possible under thevarious categories without discussion.Step 3. Once all possible sources are exhausted, discuss the various causesStep 4. Determine the 3 most likely (various voting methods available). Numberthem in order of importance (1 is the most likely cause)

Restate theProblem insimplest termspossible.--------->

Materials Manpower Methods Machines

DESCRIBE THE ROOT CAUSE OF THE PROBLEM:At end of the day, sand blasting filters are blown out, outside of building. Theblasting process is taking carbon off of parts.Inside - Swept up sand blasting medium is collected in a tub, with no specifieddisposal instruction.

Sweep up blasting medium outside, from filters, and store in plant untilconfirmation of disposal is made.Define disposal instruction and train employees.

3. DODETERMINE & IMPLEMENT THE BEST SOLUTION:Reminder: Be sure to consider the use of Mistake Proofing Methods as a means to preventrecurrence.

The outside area has been cleaned. A metal drum has been placed in the sandblast area for used medium and cleaning of filters. Disposal options are beinginvestigated with Safety Kleen and local Environmental reps.

4. CHECKEVIDENCE OF ACTION TAKEN:

before

after

Collection for blasting

medium

EVIDENCE OF EFFECTIVENESS

5. ADJUSTIS THE SOLUTION EFFECTIVE OR SHOULD OTHER STEPS BE TAKEN.?

SHOULD THIS SOLUTION BE APPLIED TO CROSSLINE ACTIVITIES?

Auditor: Sonia Parham/STARKMFGScheduled for follow up audit on -

Findings:

CAR CLOSEDThis CAR is closed when signed by one of the following:

DateSigned

ElectronicallySigned By:

Manufacturing Mgr.

Quality Director




(check one)





Safety Issue

Environmental Issue

Assigned To: Karin Anhalt

Status: Closed Response Due04/10/2012Revised Due date 04/10/2012

Department: Materials




PROBLEM

Uncovered dumpsters during ADEQ inspection ( 1 cardboard, 1 scrap metal, 1empty)





DESCRIBE THE ROOT CAUSE OF THE PROBLEM:Employees did not have a clear understanding of what is acceptable/notacceptable environmental practices.

Train employees on acceptable/not acceptable environmental practices.Put tarp over cardboard scrap bin, to protect from rainRemove empty metal bin from premisesStore scrap metal bin under the awning, out of the weather at shipping dockarea


Train employeesPlace tarp on cardboard binSchedule pick up and removal of empty metal binMove scrap metal bin under awning


Training accomplished on 3/20/12Tarp put on cardboard collection bin

Scrap metal bin, under the awning

Empty metal bin no longer on premises





Findings:


DateSigned


Manufacturing Mgr.

Quality Director 03/29/2012Gloria Kessler/STARKMFG

Attendance & Competency Record

Course Name: Environmental Policy, Regulationsand Procedures - refressher on keeping collectionbins covered outside or out of the weather.

Date: 03/20/2012Length: .17 Hrs

Course Instructor: Karin Anhalt Type: OJT

Trainees

Who attended: Who proved competent: (as defined in courseoutline)Tim Harkey; Andy Trusty; Tony Williams;Gomer Cummins




(check one)





Safety Issue

Environmental Issue

Assigned To: Karin Anhalt

Status: Closed Response Due04/10/2012Revised Due date 04/10/2012

Department: Materials




PROBLEM

Uncovered dumpsters during ADEQ inspection ( 1 cardboard, 1 scrap metal, 1empty)





DESCRIBE THE ROOT CAUSE OF THE PROBLEM:Employees did not have a clear understanding of what is acceptable/notacceptable environmental practices.

Train employees on acceptable/not acceptable environmental practices.Put tarp over cardboard scrap bin, to protect from rainRemove empty metal bin from premisesStore scrap metal bin under the awning, out of the weather at shipping dockarea


Train employeesPlace tarp on cardboard binSchedule pick up and removal of empty metal binMove scrap metal bin under awning


Training accomplished on 3/20/12Tarp put on cardboard collection bin

Scrap metal bin, under the awning

Empty metal bin no longer on premises





Findings:


DateSigned


Manufacturing Mgr.

Quality Director 03/29/2012Gloria Kessler/STARKMFG




(check one)





Safety Issue

Environmental Issue

Assigned To: AndrewWelch

Status: Open Response Due04/10/2012Revised Due date 04/10/2012

Department: Production




PROBLEM

Metal dust or blast material on ground near loading dock





DESCRIBE THE ROOT CAUSE OF THE PROBLEM:At end of the day, sand blasting filters are blown out, outside of building. Theblasting process is taking carbon off of parts.Inside - Swept up sand blasting medium is collected in a tub, with no specifieddisposal instruction.

Sweep up blasting medium outside, from filters, and store in plant untilconfirmation of disposal is made.Define disposal instruction and train employees.


The outside area has been cleaned. A metal drum has been placed in the sandblast area for used medium and cleaning of filters. Disposal options are beinginvestigated with Safety Kleen and local Environmental reps.


before

after

Collection for blasting

medium





Findings:


DateSigned


Manufacturing Mgr.

Quality Director

Attendance & Competency Record

Course Name: Environmental Policy, Regulationsand Procedures - refressher on keeping collectionbins covered outside or out of the weather.

Date: 03/20/2012Length: .17 Hrs

Course Instructor: Karin Anhalt Type: OJT

Trainees

Who attended: Who proved competent: (as defined in courseoutline)Tim Harkey; Andy Trusty; Tony Williams;Gomer Cummins

April 9, 2012 Ms. Sonia Parham Stark Manufacturing, LLC 310 Pennington Dr. Paris, AR 72855 RE: AFIN: 42-00078 NPDES Permit Tracking No.: ARR00A572 Dear Ms. Parham: The Department has received your response to the March 12, 2012 inspection of your facility by our District Field Inspector, Travis Harmon. Your letter appears to satisfy 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 501-682-0633 or you may e-mail me at [email protected]. Sincerely,

Amy Schluterman Enforcement Analyst Water Division Enforcement Branch

Spark.pdfEmailCAR 2041 (2)CAR2042 (2)Training record (2)

united states environmental protection … · one waste cardboard dumpster and one scrap metal...

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