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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
Corrective Action Report:
CAR Number: 2041 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: Karin Anhalt
Status: Closed Response Due04/10/2012Revised Due date 04/10/2012
Department: Materials
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
Uncovered dumpsters during ADEQ inspection ( 1 cardboard, 1 scrap metal, 1empty)
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: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
3. DODETERMINE & IMPLEMENT THE BEST SOLUTION:Reminder: Be sure to consider the use of Mistake Proofing Methods as a means to preventrecurrence.
Train employeesPlace tarp on cardboard binSchedule pick up and removal of empty metal binMove scrap metal bin under awning
4. CHECKEVIDENCE OF ACTION TAKEN:
Training accomplished on 3/20/12Tarp put on cardboard collection bin
Scrap metal bin, under the awning
Empty metal bin no longer on premises
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 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
Corrective Action Report:
CAR Number: 2041 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: Karin Anhalt
Status: Closed Response Due04/10/2012Revised Due date 04/10/2012
Department: Materials
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
Uncovered dumpsters during ADEQ inspection ( 1 cardboard, 1 scrap metal, 1empty)
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: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
3. DODETERMINE & IMPLEMENT THE BEST SOLUTION:Reminder: Be sure to consider the use of Mistake Proofing Methods as a means to preventrecurrence.
Train employeesPlace tarp on cardboard binSchedule pick up and removal of empty metal binMove scrap metal bin under awning
4. CHECKEVIDENCE OF ACTION TAKEN:
Training accomplished on 3/20/12Tarp put on cardboard collection bin
Scrap metal bin, under the awning
Empty metal bin no longer on premises
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 03/29/2012Gloria Kessler/STARKMFG
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
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)