February 9, 2012...February 9, 2012 Mike Maloney Unimin Corporation P.O. Box 29 Guion, AR 72540-0029...

February 9, 2012

Mike Maloney

Unimin Corporation

P.O. Box 29

Guion, AR 72540-0029

RE: NPDES Compliance Inspection, Unimin Corporation – Guion Facility

AFIN: 33-00002 NPDES Permit No.: AR0001899, AR0001899C, ARR153588, and

ARR00B148

Dear Mr. Maloney:

On December 14, 2011 and December 15, 2011, ADEQ staff Steve Johnson, Brent Walker and I

performed routine compliance, industrial stormwater, construction stormwater, and construction of

wastewater treatment system inspections of the above referenced facility. These inspections were

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.

The compliance evaluation inspection revealed the following permit (AR0001899) violations:

1. Non-standard devices were used to measure flow at all 3outfalls (001, 010, and 011).

Additionally, there was no documentation to show that flow measurement methods were

within +/- 10% of true discharge. This violates Part III, Section C. Item 2. of the permit

which requires that appropriate flow measurement devices and methods consistent with

accepted scientific practices shall be selected and used to insure the accuracy and reliability

of measurements of the volume of monitored discharges. The devices shall be installed,

calibrated, and maintained to insure the accuracy of the measurements are consistent with

the accepted capability of that type of device. Devices selected shall be capable of

measuring flows with a maximum deviation of less than +/- 10% from true discharge rates

throughout the range of expected discharge volumes and shall be installed at the monitoring

point of discharge.

2. Oil and Grease, COD, and TSS monthly averages were incorrectly reported as flow

weighted values on DMR’s. This violates Part IV, Item 18. of the permit which requires the

“Monthly average” to be calculated as the sum of all daily discharges measured during a

calendar month divided by the number of daily discharges measured during that month.

Mike Maloney, Unimin Corporation – Guion Facility

February 9, 2012

NPDES Report Page 2

3. The time and individual performing measurement was not recorded for flow measurements.

This violates Part III, Section C. Item 8. of the permit which requires that records and

monitoring information shall include:

a) The date, exact place, time and methods of sampling or measurements, and

preservatives used, if any;

b) The individuals(s) who performed the sampling or measurements;

c) The date(s) analyses were performed;

d) The individual(s) who performed the analyses;

e) The analytical techniques or methods used; and

f) The measurements and results of such analyses.

The industrial stormwater inspection revealed the following permit (ARR00B148) violations:

1. The SWPPP was not updated as required. This violates Part 4.3 of the permit which requires

the permittee to modify the SWPPP whenever there is a change in design, construction,

operation, or maintenance of any BMP which cause(s) the SWPPP to be less effective in

controlling pollutants. The following items were noted;

a. The change in the number and location of outfalls was not updated in the SWPPP.

b. There was a process water outfall and a stormwater outfall in different locations with the

same ID (Outfalls 011).

c. The SWPPP did not include water sources for the listed outfalls.

d. The SWPPP did not address all areas that were disturbed by mining activity.

Specifically, there was a disturbed area east of the northern open mining area that was

not included in the SWPPP.

2. Each stormwater outfall was not sampled twice a year as required by the permit. This

violates Part 3.7 of the permit which requires each stormwater outfall to be sampled and

analyzed separately unless an outfall has been determined to be similar in accordance with

part 3.7.1 of the permit. Part 3.5 of the permit requires the facility to monitor at least twice

within a calendar year, within the time frames specified.

3. BMP’s were not adequately maintained to keep materials from washing offsite with

stormwater. It appeared that sand from the facility had washed into a tributary of Guion

Slough near the southern part of the facility. This violates Part 6.17(a) of the permit which

requires the operator to properly operate and maintain all control (and related

appurtenances)which are installed or used by the operator to achieve compliance with the

conditions of this permit at all times.

The construction stormwater inspection revealed the following permit (ARR153588) violations:

1. The slopes of the pond under construction (Pond T) were not adequately stabilized.

Mike Maloney, Unimin Corporation – Guion Facility

February 9, 2012

NPDES Report Page 3

No violations were observed during the wastewater treatment construction inspection

(Permit #AR001899C)

The above items require your immediate attention. Please submit a written response to these

findings to the Water Division Enforcement Branch of this Department. 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 February 21, 2012.

For additional information you may contact the Enforcement Branch by telephone at 501-682-0639

or by fax at 501-682-0910.

If I can be of assistance, please contact me at [email protected] or 870-935-7221 ext.-15.

Sincerely,

Michael B. Greenway

District 3 Field Inspector

Water Division

cc: Water Division Enforcement Branch

Water Division Permits Branch

ADEQ Water NPDES Inspection AFIN: 33-00002 Permit #: ARR153588

NPDES Report

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Washington, D.C. 20460

NPDES Compliance Inspection Report

Form Approved

OMB No. 2040-0003

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 1 5 3 5 8 8 11 12 1 1 1 2 1 4 17 18 R 19 S 20 2

Remarks

3 3 - 0 0 0 0 2 I Z A R D

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)

Unimin Corporation

South end of Main Street

Guion, AR

Izard County

Entry Time/Date

12-14-2011 / 10:15

12-15-2011 / 10:30

Permit Effective Date

June 10, 2011

Exit Time/Date

12-14-2011 / 16:45

12-15-2011 / 17:00

Permit Expiration Date

October 31, 2016

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

Gary Blankenship / QC-Safety Supervisor / 870-346-5301 / fax: 870-346-5707

Other Facility Data

35.924483

-90.94013

PDS # 063618

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

Mike Maloney / Plant Manager / 870-346-5301

Unimin Corporation – Guion Facility

P.O. Box 29

Guion, AR 72540-0029

Contacted

Yes No

Section C: Areas Evaluated During Inspection

(S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated)

S Permit N

Flow Measurement U

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 U

Storm Water N

Other:

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

On December 14, 2011 and December 15, 2011 a routine compliance inspection of the Unimin Corporation – Guion Facility was conducted by ADEQ staff Steve

Johnson, Brent Walker, and Michael Greenway. During the course of this inspection , a construction stormwater inspection was also conducted and revealed the

following violation:

1. The slopes of the pond under construction (Pond T) were not adequately stabilized.

Refer to the letter accompanying the December 14, 2011 compliance evaluation inspection (CEI) for more information.

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

Michael B. Greenway Brent Walker

Agency/Office/Telephone/Fax

AR Dept. of Environmental Quality-Jonesboro

(870) 935-7221 ext. 15 / (870) 935-4715 (Fax)

Date

December 21, 2011

Signature of Reviewer

Agency/Office/Phone and Fax Numbers

Date

ADEQ Water NPDES Inspection AFIN: 33-00002 Permit #: ARR153588

Water Division NPDES Photographic Evidence Sheet

Location: Unimin Corporation – Guion Facility

Photographer: Michael Greenway Witness: Brent Walker

Photo # 1 Of 4 Date: 12/15/2011 Time: 15:16

Description: Construction of Pond T, which is located between Guion Slough (left of photographed area) and

White River (background).



Description: Unstabilized slopes on the outer edge of Pond T. A silt fence has been installed near the bottom

of the slope. Guion slough is barely visible near the top left of photo.

ADEQ Water NPDES Inspection AFIN: 33-00002 Permit #: AR0001899

NPDES Report

Water Division NPDES Photographic Evidence Sheet

Location: Unimin Corporation – Guion Facility



Description: Movement of sediment downhill from the unstabilized slopes of Pond T. Guion Slough is

visible in the top of photo.



Description: Unstabilized slopes on the outer edge of Pond T near outfall 011. Guion slough is visible near

the top of photo.

C:\Documents and Settings\allen-daniel\Local Settings\Temporary Internet Files\Content.Outlook\PMWGGM81\GU_SW Compliance Response 2-21-12.DOC

4000 Baker Road · Ottawa, IL 61350 (Phone) 815/434-4178 · (Fax) 815/434-3828 February 21, 2012 Water Division Enforcement Branch Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR 72118-5317 RE: Compliance Inspection December 14-15, 2011 – Unimin Corporation Guion Plant NPDES Permit No. AR0001899, AR0001899C, ARR153588, and ARR00B148

AFIN: 33-00002 Dear Mr. Greenway: In response to the Compliance Inspection on December 14-15, 2011 please note the following. The areas of concern are listed with Unimin’s response in italics. Permit AR0001899 1. Non-standard devices were used to measure flow at a1l 3 0utfalls (001, 010, and 011).

Additionally, there was no documentation to show that flow measurement methods were within +/- 10% of true discharge. This violates Part III, Section C. Item 2. of the permit which requires that appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected and used to insure the accuracy and reliability of measurements of the volume of monitored discharges. The devices shall be installed, calibrated, and maintained to insure the accuracy of the measurements are consistent with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a maximum deviation of less than +/- 10% from true discharge rates throughout the range of expected discharge volumes and shall be installed at the monitoring point of discharge. Unimin operated the Outfalls OO1 and O11 believing that they were Parshall flumes which can be measured with an accuracy of +/-10%. Following a discussion with ADEQ, ADEQ has advised that the discharge structures are not Parshall flumes. Unimin believes that the structures are a standard open channel and by using the correct calculation, the accuracy of +/- 10% will be met to be in compliance with the regulations. For Outfall 010, the California pipe method has been used for some time, but this will be replaced with either a Parshall flume or an open channel which can be measured with the required accuracy. This replacement will take place by May 1, 2012.

2. Oil and Grease, COD, and TSS monthly averages were incorrectly reported as flow weighted values on

DMR's. This violates Part IV, Item 18 of the permit which requires the "Monthly average" to be calculated as the sum of all daily discharges measured during a calendar month divided by the number of daily discharges measured during that month.

Environmental Affairs


Unimin has corrected the methodology of reporting the “Monthly Average” starting in December 2011 and will continue to report these values correctly in the future.

3. The time and individual performing measurement was not recorded for flow measurements. This violates

Part III, Section C. Item 8 of the permit which requires that records and monitoring information shall include: a) The date, exact place, time and methods of sampling or measurements, and preservatives used, if any; b) The individual(s) who performed the sampling or measurements: c) The date(s) analyses were performed; d) The individual(s) who performed the analyses; e) The analytical techniques or methods used; and f) The measurements and results of such analyses. The log book used to record information on the samples taken has been modified to include the items in a) and b) in the above section of the permit. All required information will be recorded for all future samples.

Permit ARR00B148 1. The SWPPP was not updated as required. This violates Part 4.3 of the permit which requires the

permittee to modify the SWPPP whenever there is a change in design, construction, operation, or maintenance of any BMP which cause(s) the SWPPP to be less effective in controlling pollutants. The following items were noted; a) The change in the number and location of outfalls was not updated in the SWPPP. b) There was a process water outfall and a stormwater outfall in different locations with the same ID

(Outfalls 011). c) The SWPPP did not include water sources for the listed outfalls. d) The SWPPP did not address all areas that were disturbed by mining activity. Specifically, there was a

disturbed area east of the northern open mining area that was not included in the SWPPP. Unimin has scheduled a site inspection in March 2012 to review the items listed above and will then modify the SWPPP by April 15, 2012 to meet the requirements in the permit.

2. Each stormwater outfall was not sampled twice a year as required by the permit. This violates Part 3.7 of

the permit which requires each stormwater outfall to be sampled and analyzed separately unless an outfall has been determined to be similar in accordance with part 3.7.1 of the permit. Part 3.5 of the permit requires the facility to monitor at least twice within a calendar year, within the time frames specified.

Unimin will sample all outfalls twice per year as required in the permit. This will be reflected in the next annual report to be submitted in January of 2013.

3. BMP's were not adequately maintained to keep materials from washing offsite with stormwater. It

appeared that sand from the facility had washed into a tributary of Guion Slough near the southern part of the facility. This violates Part 6.17(a) of the permit which requires the operator to properly operate and maintain all control (and related appurtenances) which are installed or used by the operator to achieve compliance with the conditions of this permit at all times.


Unimin will maintain and operate this BMP and others as required in the permit, and will perform any necessary upgrades and maintenance. These modifications will be completed by April 15, 2012. However, Unimin feels that at least some, if not all, of the material seen in the tributary of Guion Slough near the southern part of the facility was deposited there by backwater coming up from the White River during one of the recent large floods.

Permit ARR153588 1. The slopes of the pond under construction (Pond T) were not adequately stabilized.

Unimin understands that stabilization of the side slopes needed to occur as soon as practicable and since the stabilization method was to seed the slopes this was scheduled to occur within two weeks of the project being completed. Unimin did not view the project as being completed in sections and therefore did not feel that stabilization of a section was necessary. After discussing this with ADEQ following receipt of this compliance letter, Unimin understands that applying a cooler weather cover crop as an intermediate stabilization step would have aided in complying with the intent of the permit.

Unimin strives to comply with environmental regulations and is very proactive in maintaining compliance at its facilities. If you have any questions, or require any additional information, please contact me at [email protected], by phone: 815/431-2205, or at the above address. Respectfully, Unimin Corporation Steve Froisland Environmental Engineer CC: M. Maloney

B. Shalter

mailto:[email protected]

From: Stout, MarilynTo: Allen-Daniel, LeslieSubject: FW: Unimin AR001899, AR0001899C, ARR53588, and AR00B148Date: Thursday, April 19, 2012 9:29:42 AM

Leslie –Can you save this to: PDS 063618, 063368, 063369, and 063367 for me? Thanks! Marilyn From: Walker, Brent Sent: Thursday, April 19, 2012 8:37 AMTo: Stout, MarilynSubject: FW: Unimin AR001899, AR0001899C, ARR53588, and AR00B148 Brent L. Walker


Water Division - Jonesboro Field Office

Arkansas Department of Environmental Quality

870-935-7221 ext.-12

[email protected]

From: Johnson, Steven Sent: Tuesday, April 03, 2012 14:59To: Uyeda, CraigCc: Walker, Brent; Fleming, Eric; Greenway, Michael; Saunders, SeanSubject: RE: Unimin AR001899, AR0001899C, ARR53588, and AR00B148 Hello Craig, Unimin has hired new Environmental Compliance personnel and we have been asked to perform acompliance assistance visit at this site. It appears this facility is moving in a good directionconcerning environmental protection matters. I support the extension proposed in the email belowthat may be needed for “fine tuning” of the draft revised SWPPP. Thanks, Steve From: Walker, Brent Sent: Monday, April 02, 2012 12:19 PMTo: Johnson, StevenCc: Fleming, Eric; Greenway, Michael; Saunders, SeanSubject: Unimin AR001899, AR0001899C, ARR53588, and AR00B148 Steve I just spoke with Phil Wilkes at Unimin regarding corrective action from our December 2011inspection. In their response to the inspection, they self-imposed an April 15, 2012 deadline for a

mailto:/O=ARKANSAS DEPT. OF ENVIRONMENTAL QUALITY/OU=ADEQ1/CN=RECIPIENTS/CN=STOUT



new SWPPP. They currently have a new draft SWPPP and would like to take us up on my offer for acompliance assistance visit. Currently it looks like my first opening that matches their schedule islate April or early May – in my opinion, Sean’s attendance is mandatory, so we’ll have to work withhis schedule too. Michael actually wrote the letter and inspection report, so he gets a say also, ifhe desires.

I advised them to send a letter to enforcement asking for a one month extension of the April 15th

deadline for a final revised SWPPP. If you agree with the extension, will you please pass this alongwith your recommendation to Enforcement? Thanks,Brent Brent L. Walker


Water Division - Jonesboro Field Office

Arkansas Department of Environmental Quality

870-935-7221 ext.-12

[email protected]


February 9, 2012...February 9, 2012 Mike Maloney Unimin Corporation P.O. Box 29 Guion, AR 72540-0029...

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