NPDES Compliance Evaluation Inspection (CEI) Report · 3/28/2017  · NPDES Compliance Evaluation...

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NPDES Compliance Evaluation Inspection (CEI) Report Facility Name and Location Entry Date Entry Time Lehigh Southwest Cement Co. Permanente Facility 24001 Stevens Creek Blvd. Cupertino, CA 95014 February 14, 2017 10:50 am Permit Effective Date Permit Expiration Date May 1, 2014 April 30, 2019 Mailing Address Same as facility location? Yes No Notified? Yes No If no, rationale: CIWQS Inspection ID 27604036 NPDES Permit Number CA0030210 Receiving Water Name Permanente Creek Permit Order No. R2-2014-0010 County Santa Clara Cease and Desist Order (CDO) No. R2-2014-0011 Plant Classification N/A Type of Discharge Industrial Large Process Wastewater / Stormwater CIWQS Place ID 273205 Names and Titles of Onsite Representatives Name Title Phone Email Sam Barket III Area Environmental Manager (408) 996-4269 (Direct) (408) 202-7534 (Cell) [email protected] Erika Guerra Environmental Director - Cement (925) 244-6570 [email protected] Manju Shivalingappa Environmental Engineer (408) 996-4236 Manjunath.Shivalingappa@ LehighHanson.com Name and Title of Responsible Official Name Keith Andrew Krugh Title Plant Manager, Lehigh Hanson Region West Phone (408) 996-4231 Email [email protected] Does responsible official match permit based contact information on file? Yes No Keith Krugh replaced the previous responsible official as Plant Manager in January 2017. The Discharger informed the Regional Water Board of this change and CIWQS has been revised accordingly. Inspector Information Presented Credentials? Yes No Organization San Francisco Bay Regional Water Board Name John H. Madigan, P.E. James Parrish Title Water Resource Control Engineer Water Resource Control Engineer Phone (510) 622-2405 (510) 622-2381 Email [email protected] [email protected]

Transcript of NPDES Compliance Evaluation Inspection (CEI) Report · 3/28/2017  · NPDES Compliance Evaluation...

NPDES Compliance Evaluation Inspection (CEI) Report Facility Name and Location Entry Date Entry Time Lehigh Southwest Cement Co. Permanente Facility 24001 Stevens Creek Blvd. Cupertino, CA 95014

February 14, 2017 10:50 am Permit Effective

Date Permit

Expiration Date May 1, 2014 April 30, 2019

Mailing Address Same as facility location? Yes ☒ No ☐ Notified? Yes ☒ No ☐

If no, rationale:

CIWQS Inspection ID 27604036 NPDES Permit Number CA0030210 Receiving Water Name Permanente Creek

Permit Order No. R2-2014-0010 County Santa Clara

Cease and Desist Order (CDO) No. R2-2014-0011 Plant Classification N/A

Type of Discharge Industrial Large Process

Wastewater / Stormwater

CIWQS Place ID 273205

Names and Titles of Onsite Representatives Name Title Phone Email

Sam Barket III Area Environmental Manager (408) 996-4269 (Direct) (408) 202-7534 (Cell) [email protected]

Erika Guerra Environmental Director - Cement (925) 244-6570 [email protected]

Manju Shivalingappa Environmental Engineer (408) 996-4236 Manjunath.Shivalingappa@

LehighHanson.com Name and Title of Responsible Official Name Keith Andrew Krugh Title Plant Manager, Lehigh Hanson Region West Phone (408) 996-4231 Email [email protected] Does responsible official match permit based contact information on file? Yes ☐ No ☒ Keith Krugh replaced the previous responsible official as Plant Manager in January 2017. The Discharger informed the Regional Water Board of this change and CIWQS has been revised accordingly.

Inspector Information Presented Credentials? Yes ☒ No ☐ Organization San Francisco Bay Regional Water Board Name John H. Madigan, P.E. James Parrish Title Water Resource Control Engineer Water Resource Control Engineer Phone (510) 622-2405 (510) 622-2381 Email [email protected] [email protected]

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

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I. PRE-INSPECTION PERMIT REVIEW Yes No N/A Is the facility as described in the permit? ☐ ☒ ☒ Has the Water Board been notified of any process/production modifications? ☒ ☐ ☐ Was a permit reissuance application submitted to the Water Board on time? ☐ ☐ ☒ Was the permit modified prior to any facility or discharge changes? ☐ ☒ ☐ Discharge Points Discharge Point 001 (Pond 4A): Treated process wastewater to Permanente Creek. (Not inspected.) Discharge Point 002 (Pond 13B): Non-industrial stormwater (see Notes). Discharge Point 003 (Pond 9): Non-industrial stormwater and upwelled groundwater (see Notes). Discharge Point 004 (Pond 17): Industrial stormwater from Rock Plant to Permanente Creek Discharge Point 005 (Pond 20): Industrial stormwater from Aluminum Plant, entry road, nearby hillside to Permanente Creek Discharge Point 006 (Pond 30): Industrial stormwater from East Materials Storage Area (EMSA) to Permanente Creek

Max Flow / Total Suspended Solids (TSS), July 2016 – February 2017

Discharge Point Flow, million gallons per day (MGD) or

gallons per day (gpd) TSS, pounds per day (lbs/d) and

milligrams per liter (mg/L) Discharge Point 001: Discharge Point 002: Discharge Point 003: Discharge Point 004: Discharge Point 005: Discharge Point 006:

3.0 MGD No discharge 122,300 gpd 11,200 gpd 18,500 gpd 8,400 gpd

316 lbs/d (55 mg/L) No discharge

17 mg/L 12 mg/L

180 mg/L 9.5 mg/L

Permitting concerns that might affect inspection process The Discharger requested permit and cease and desist order (CDO) amendments by letter dated December 30, 2016, to account for changes to the final site configuration. The Discharger plans to locate the scaled-up Final Treatment System (FTS) near the Cement Plant dome instead of adjacent to Pond 4A and to co-locate Discharge Point 001 with the Pond 1 emergency discharge point (see Notes). Information gathered by this inspection will support permit and CDO amendments.

Notes: Pond 1: The Discharger installed Pond 1, which has a capacity of 4 million gallons, just south of the Cement Plant in April 2016. Stormwater runoff and process wastewater are directed to Pond 1 and pumped to Pond 11 and the Cement Plant Reclaim Water System (Reclaim System). Water that is not re-used in the cement manufacturing process is pumped to Discharge Point 001 (Pond 4A) or to the Interim Treatment System (ITS). Pond 1 has an unpermitted emergency discharge point to Permanente Creek. Pond 1 discharged at this point for a total of approximately nine days in four separate events from January 10 through February 7, 2017 (see Section II, Notes, Spills/Bypasses). Discharge Point 002 (Pond 13B): Discharge Point 002 has not discharged since March 2014 and is currently dry (Photo 1). Discharge Point 003 (Pond 9): Discharge Point 003 discharges runoff from the slope directly adjacent to Pond 9 and upwelled groundwater. The Discharger has isolated Pond 9 from industrial stormwater runoff that previously flowed to it, which now flows to the Dinky Shed Basin and is pumped to Pond 1. Pond 9 is home to endangered California red-legged frogs (CRLFs). Discharge Point 004 (Pond 17): Discharge Point 004 discharges stormwater runoff from the Rock Plant; previously, it also discharged stormwater runoff that flowed through the Rock Plant from adjacent hillsides; the Discharger now diverts this runoff around the Rock Plant and discharges it directly to Permanente Creek, as approved by Regional Water Board letter dated October 26, 2015.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

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Discharge Point 005 (Pond 20): The Discharger has added sodium bisulfite application for pH control and a series of check dams and “Floc Logs” to remove solids. The Discharger is considering an automatic pH control system to address continued pH violations. Discharge Point 006 (Pond 30): The Discharger discovered CRLFs at Pond 30 and enclosed the pond with a frog-proof fence to prevent any more frogs from taking up residence. The Discharger installed a French drain to intercept potentially selenium-impacted subsurface flow from the EMSA before it reaches Pond 30; the Discharger stores intercepted water in a holding tank and transfers it to Pond 1.

II. PRE-INSPECTION MONITORING REPORT REVIEW

Summary of effluent limit violations since last inspection

Constituent No. of Violations Corrective Action Reported No action

reported

pH 4 Discharger considering automated pH control at Discharge Point 005 ☐

Settleable Solids 1 Incident investigated, personnel issue corrected. ☐ Total Dissolved Solids (TDS) 1 Incident investigated, personnel issue corrected. ☐ Total Suspended Solids (TSS) 5 Incident investigated, personnel issue corrected. ☐ Notes Reports reviewed: The November and December 2016 self-monitoring reports (SMRs) were reviewed and compared to the corresponding lab reports; the January 2017 report was reviewed and compared to field reports. Effluent violations: The permit sets effluent limits for TSS, settleable matter, turbidity, metals, and conventional pollutants. The CDO sets interim limits for solids and exempts the Discharger from penalties for exceeding certain permit limits if it complies with the CDO. Permit and CDO interim limit violations since June 2016 are summarized below; exceedances of permit limits exempt from penalties under the CDO are not included. Discharge Point 001: One TSS interim limit (230 mg/L) violation, July 2016 (270 mg/L). One settleable solids interim limit (1.3 milliliters per liter per hour [mL/L/hr]) violation, July 2016 (3.0 mL/L/hr). One TDS permit limit (1,000 mg/L) violation, July 2016 (1,200 mg/L). Discharge Point 005: Four pH permit limit (8.5 standard units [s.u.]) violations, November - December 2016 (8.6 to 9.9 s.u.). Monitoring and Reporting Program observations since last inspection Yes No N/A Responsible person signs and certifies the DMRs and/or SMRs ☒ ☐ ☐ Discharger monitors at frequency required by permit ☒ ☐ ☐ All data collected are summarized ☐ ☒ ☐ Detection limits are reported ☒ ☐ ☐ “Less than” and estimated values are properly carried through the calculations ☒ ☐ ☐ Flow measurement period used for load calculations brackets sampling period ☒ ☐ ☐ Loading rates are properly calculated ☒ ☐ ☐ Data reported in time frame and frequency required by permit ☒ ☐ ☐ Have any spills/bypasses been reported to the Regional Water Board? ☒ ☐ ☐ Notes All data collected are summarized: The Discharger did not directly report flow measured at Monitoring Location EFF-001A in the SMRs; however, the Discharger used this flow to calculate the TSS mass discharge it reported. The Discharger provided the November and December 2016 Monitoring Location EFF-001A flow data, allowing the inspectors to verify the mass loading calculations for those months. Loading Rates: The December 14, 2016, TSS result at Monitoring Location EFF-001A was reported for December 8, 2016, in the hard-copy SMR. This reporting error was carried through the TSS mass loading calculations for December 8 and December 14 through 17, 2016 (Attachment 1).

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

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Spills/Bypasses: The Discharger reported the following unauthorized discharges from the Pond 1 emergency discharge point in January and February 2017: 15:15 pm, January 9 to approximately 18:00 pm, January 13; no flow estimate. 04:00 am, January 20, to 11:00 am, January 23; no flow estimate. 15:00 pm, January 23 to 02:30 am, January 24; no flow estimate. 09:30 am, February 7 to 11:15 am, February 8; estimated flow rate 2,500 to 3,000 gallons per minute (gpm). 04:00 am, February 20 to 0820 am, February 22; no flow estimate. The Discharger notified the Regional Water Board of these discharges per federal Standard Provisions section I.G.3.c. As stated in Section I, water stored in Pond 1 is pumped to Pond 11, then to Pond 4A and the ITS if not re-used. Facility representatives stated pumping capacity is 2,500 gpm from Pond 1, but only 575 gpm from Pond 11. This restricted pumping capacity contributed to the unauthorized discharges from Pond 1. Facility representatives stated that the final site configuration will include increased pumping capacity from Pond 11 to eliminate this problem. The Discharger has also verbally informed the Regional Water Board that it intends to construct additional infrastructure to store and treat high wet-weather flows and prevent future unauthorized discharges. Details will be forthcoming in a formal proposal. Effluent data from Pond 1 collected on January 11 and 20 indicate levels of selenium (24 to 25 ug/L) and hexavalent chromium (43 ug/L) exceeding water quality objectives. Effluent data from subsequent Pond 1 discharges are not yet available.

III. RECORDS AND REPORTS REVIEW

Required onsite?

Available onsite?

Comments Yes No Yes No N/A Not Inspected

Current NPDES permit ☒ ☐ ☒ ☐ ☐ ☐ Permit modifications ☐ ☐ ☐ ☐ ☒ ☐ Permit amendments ☐ ☐ ☐ ☐ ☒ ☐ Cease and Desist Order ☒ ☐ ☒ ☐ ☐ ☐ Monitoring and reporting program ☒ ☐ ☒ ☐ ☐ ☐

Standard provisions ☒ ☐ ☒ ☐ ☐ ☐ Industrial pretreatment program ☐ ☐ ☐ ☐ ☒ ☐

Plant maintenance records/log book ☒ ☐ ☐ ☒ ☐ ☐

The individual responsible for maintaining these records was not present.

Plant operation and maintenance manual ☐ ☐ ☐ ☐ ☐ ☒

Equipment manuals ☐ ☐ ☐ ☐ ☐ ☒ Plant engineering drawings ☐ ☐ ☐ ☐ ☐ ☒ Collection system drawings ☐ ☐ ☐ ☐ ☒ ☐ Collection system Maintenance records ☐ ☐ ☐ ☐ ☒ ☐

Spill and bypass records ☒ ☐ ☒ ☐ ☐ ☐

SPCC plan / SWPPP ☒ ☐ ☒ ☐ ☐ ☐ Last updated December 2016

Operational logs ☐ ☐ ☐ ☐ ☒ ☐ Auxiliary power check logs ☐ ☐ ☐ ☐ ☐ ☒

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

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IV. OPERATIONS AND MAINTENANCE REVIEW Yes No N/A Not

Inspected Were all records and reports required by permit organized and available? ☒ ☐ ☐ ☐ Was influent flow meter calibration available onsite? ☐ ☐ ☒ ☐ Date of last calibration See Notes Calibration performed by… See Notes Was effluent flow meter calibration available onsite? ☒ ☐ ☐ ☐ Date of last calibration July 19, 2016 Calibration performed by… Emerson Process Management Were flow measurement records maintained for past 3 years? ☐ ☐ ☐ ☒ Is a maintenance management program in place? ☒ ☐ ☐ ☐ Number of open work orders See Notes Oldest date of open work order See Notes Are entries to the operational logs made in pen? ☐ ☐ ☒ ☐ Were all operational log entry modifications made with suitable cause? ☐ ☐ ☒ ☐ Were reported spills and bypasses recorded in operational logs? ☐ ☐ ☒ ☐ Is the facility staffing requirement described in O&M manual? ☐ ☐ ☐ ☒ Is the facility staffed in accordance with O&M manual? ☐ ☐ ☐ ☒ Were there auxiliary power check logs? ☐ ☐ ☐ ☒ Air Board permit number Notes Influent flow meter calibration: Permit does not require influent monitoring. Maintenance management program: We were unable to determine the number of open work orders for maintenance because the individual responsible for maintaining those records was not present. Work orders for maintenance are created by individuals who note deficiencies and rank them according to level of concern. Problems that can be addressed immediately are typically handled informally and not recorded. The Discharger checks the status of equipment weekly and performs routine preventative maintenance.

V. MONITORING RECORDS REVIEW

Yes No N/A Not Inspected

Are monitoring records and laboratory reports retained in accordance with Attachment D (5 years if related to sewage sludge and biosolids use and disposal; 3 years if related to anything else)?

☒ ☐ ☐ ☐

Are data reported on DMRs/SMRs consistent with analytical results? ☐ ☒ ☐ ☐ Is the onsite laboratory ELAP certified? ☐ ☐ ☒ ☐ Certification Number N/A Expiration Date N/A

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

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N/A Not Inspected

Parameters measured onsite ☐ ☐ 1.Flow 2. Temperature 3. pH 4. Conductivity 5. Turbidity 6. Dissolved oxygen (DO) / DO Saturation Constituents analyzed with hand-held equipment ☐ ☐

Most recent calibration date

Standard expiration date

1. pH Each use Not inspected 2. Conductivity Each use Not inspected 3. Turbidity Each use Not inspected 4. DO / DO Saturation Each use Not inspected 5. Temperature Each use Not inspected Notes Data reported on DMRs / SMRs consistent with analytical results: Inconsistencies between the November and December 2016 SMRs and laboratory reports are listed below: November 2016 SMR: The November 10, 2016, ITS influent hexavalent chromium and mercury results (ITS data table) appeared to be switched with the effluent results. December 2016 SMR: The Discharger omitted the ITS data table from this report. (The Discharger did maintain the December 2016 ITS monitoring, sampling, and analytical records, which were available during the inspection). The December 14, 2016, TSS result at Monitoring Location EFF-001A (3.8 mg/L) was reported for December 8, 2016, in the Discharge Point 001 (Pond 4A) data table (Attachment 1), but was reported correctly to CIWQS. This discrepancy affected the TSS mass loading reported for December 8 and December 14 – 17, 2016 (see Section II, Monitoring and Reporting Program, Notes).

VI. MONITORING REPORT REVIEW

Yes No N/A Not Inspected

Are loading calculations prepared correctly? ☒ ☐ ☐ ☐ Are contract laboratory records and chains of custody available? ☒ ☐ ☐ ☐ Do sampling and analytical records include:

a. Dates, times, and locations of sampling ☒ ☐ ☐ ☐ b. Names of individuals performing sampling ☒ ☐ ☐ ☐ c. Analytical methods ☒ ☐ ☐ ☐ d. Results of analyses ☒ ☐ ☐ ☐ e. Dates of analyses ☒ ☐ ☐ ☐ f. Times of analyses, as necessary to verify holding times ☒ ☐ ☐ ☐ g. Analysts names or initials ☒ ☐ ☐ ☐ h. Instantaneous flow at grab sample locations, if required ☐ ☐ ☒ ☐

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

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MONITORING PROCEDURES Yes No N/A Not Inspected

Are adequate equipment and procedures used for onsite analyses? pH ☐ ☐ ☐ ☒ Dissolved oxygen ☐ ☐ ☐ ☒ Temperature ☐ ☐ ☐ ☒ Turbidity ☐ ☐ ☐ ☒ UV transmittance ☐ ☐ ☒ ☐ Other ☐ ☐ ☐ ☒ Is refrigeration satisfactory? ☐ ☐ ☐ ☒ Are grab samples collected during representative discharge conditions? ☐ ☐ ☐ ☒ Do monitoring locations appear to be appropriate? ☒ ☐ ☐ ☐ Do composite sampling procedures comply with the permit? ☐ ☐ ☐ ☒ Are automatic samplers properly cleaned and maintained? ☐ ☐ ☐ ☒ Are samples adequately preserved? ☐ ☐ ☐ ☒ Are sample containers appropriate for the samples collected? ☐ ☐ ☐ ☒ Are samples collected using appropriate protocols? ☐ ☐ ☐ ☒ Are coliform samples collected directly into sterile containers? ☐ ☐ ☒ ☐ Does coliform sampling occur after the last introduction of wastes? ☐ ☐ ☒ ☐ Is the number of discharge points as described in the permit? ☒ ☐ ☐ ☐ Are the locations of the discharge outfalls as described in the permit? ☒ ☐ ☐ ☐ Is the name of the receiving water as described in the permit? ☒ ☐ ☐ ☐ Is site free of any evidence of spills or bypasses? ☐ ☒ ☐ ☐ Do the sampling and monitoring appear representative of the discharge? ☒ ☐ ☐ ☐ Are groundwater monitoring wells capped and locked? ☐ ☐ ☐ ☒ Notes Loading Calculations: See comments on TSS mass calculations in Sections II and V. Evidence of spills or bypasses: There was no evidence of additional spills or bypasses to those the Discharger reported (Section II, Monitoring and Reporting Program observations since last inspection, Notes). There was evidence of recent significant stormwater flows (see Photo 18).

VII. FINAL EFFLUENT AND RECEIVING WATER MONITORING

APPEARANCE OF FINAL EFFLUENT Yes No Not

Inspected Condition during the inspection Clear (not cloudy) ☒ ☐ ☐ Colorless ☒ ☐ ☐ Free of sheen ☒ ☐ ☐ Free of scum ☒ ☐ ☐ Free of foam ☒ ☐ ☐ Other ☐ ☐

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

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Notes The inspectors observed discharge at Discharge Points 004 and 006 (see Photos 16 and 35). Flow could be heard at Pond 9, apparently under gravel around the pond outlet (Photo 8). Discharge Point 003 could not be visually observed due to high flow conditions that made direct access to the creek bank unsafe. Facility representatives described the discharges at Discharge Points 004 and 006 as runoff; however, stormwater accumulated in Ponds 17 and 30 did not reach the level of the outlet pipes (see Photos 14 and 31). The discharges could possibly have been due to infiltration into the discharge pipes. A second pipe was observed within the Discharge Point 004 pipe (Photo 16); the facility representative stated it was likely a water line installed through the existing discharge pipe to avoid having to dig a trench for it.

APPEARANCE OF RECEIVING WATER Yes No

Upstream condition is similar

Not Inspected

Condition during the inspection Free of distinctly visible plume ☒ ☐ ☐ ☐ Free of foam and sheen ☒ ☐ ☐ ☐ Free of snails ☒ ☐ ☐ ☐ Free of erosion at the discharge point ☒ ☐ ☐ ☐ Free of bottom deposits ☒ ☐ ☐ ☐ Free of filamentous algae growth ☒ ☐ ☐ ☐ Free of microbial layers on aquatic plants ☒ ☐ ☐ ☐ Other ☐ ☐ ☐ Notes The inspectors observed Permanente Creek at several locations: upstream of Pond 13 and Discharge Point 002 (Photo 5); Pond 13 (Photos 2 -4); just downstream of Pond 13 (Photo 6); the vicinity of Discharge Point 003 (Photo 9); Discharge Point 004 (Photos 15 and 16); and the vicinity of the emergency discharge point from Pond 1 (Photo 25). Permanente Creek was turbid and moderately brown at and downstream of Pond 13.

VIII. SITE WALK INSPECTION

Weather and site conditions present during time of inspection Sunny, clear, mid-60 degrees Fahrenheit. Impacts from recent rain were evident, including continued runoff, high flow in Permanente Creek, and retained water in ponds and other structures. In addition, part of a facility road was significantly damaged (Photo 18); while not a direct subject of the inspection, this damage is worth noting as evidence of the intensity of recent rains and amount of stormwater runoff. Treatment Process (described in permit)

Appeared Compliant

Not Present

Non-Operational

Lacking Maintenance

Not Inspected

Pond 13B ☒ ☐ ☐ ☐ ☐ Pond 9 ☐ ☐ ☐ ☒ ☐ Pond 17 ☐ ☐ ☐ ☒ ☐ Pond 20 ☐ ☐ ☐ ☒ ☐ Pond 1 ☒ ☐ ☐ ☐ ☐ Pond 30 ☒ ☐ ☐ ☐ ☐ Pond 11 ☐ ☐ ☐ ☐ ☒ ITS ☐ ☐ ☐ ☐ ☒

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

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Notes Pond 13B: As stated in Section I, Pond 13B no longer receives industrial stormwater and has not discharged since March 2014. This pond was dry (Photo 1). Pond 9: A stated in Section I, this pond no longer receives industrial stormwater; Photo 7 shows the pond isolated from runoff from the adjacent road by straw wattles. Pond 9 cannot be maintained due to the presence of CRLFs. Pond 17: Pond 17 retained a significant volume of water (Photos 10 and 12-14). One internal check dam appeared to be breached (Photo 13). The damage to one side of the pond noted in the June 2016 inspection had not been repaired; however, this damage had not worsened and apparently did not affect pond integrity. Pond 20: Pond 20 did not retain significant water (Photo 19). The discharge structure at Monitoring Location EFF-005 retained silt (Photo 20). Due to recent rains and high flows, most check dams were absent; the remaining check dam was breached (Photo 22). This would have reduced the effectiveness of the bisulfite application and floc logs, and may have contributed to pH violations discussed in Section II. Pond 1: Pond 1 was approximately ¾ full (Photos 26 and 27). Several inflows to Pond 1 were observed (Photos 28 through 30). Pond 30: Pond 30 retained some water (Photos 31 and 32); CRLFs were audible to inspectors and facility representatives. Pond 30 is surrounded by a frog-proof fence. Water from the French drain the north side of Pond 30 is stored in a holding tank (Photo 34) and transferred to Pond 1.

EMERGENCY OPERATION Yes No N/A Not Inspected

Is available back-up power appropriate for emergency conditions? ☐ ☐ ☐ ☒ Are there alarms systems for power and equipment failure? ☐ ☐ ☐ ☒ Are treatment control procedures established for emergencies? ☐ ☐ ☐ ☒

CHEMICALS ONSITE

MSDS Available?

Secondary Containment? Not

Inspected Yes No Yes No

Sodium Bisulfite ☐ ☐ ☐ ☒ ☐ ☐ ☐ ☐ ☐ ☐

Yes No N/A Not Inspected

Is spill clean-up and containment equipment available? ☐ ☐ ☐ ☒

IX. SITE WALK OPERATION AND MAINTENANCE INSPECTION Yes No N/A Not

Inspected Maintenance program appears to be in place and being followed ☒ ☐ ☐ ☐ Lift stations appear properly maintained and have back-up power ☐ ☐ ☒ ☐ Odors are adequately controlled, including… ☒ ☐ ☐ ☐ Ponds ☒ ☐ ☐ ☐ Headworks ☐ ☐ ☒ ☐ Sludge processing facilities ☐ ☐ ☒ ☐ Storage appears to control leachate and runoff ☐ ☒ ☐ ☐ Public access to storage is prevented ☒ ☐ ☐ ☐ No safety concerns were observed that might interfere with proper

O&M or monitoring ☒ ☐ ☐ ☐

Flow devices appear to be property installed and maintained, and operating without interference ☒ ☐ ☐ ☐

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

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Yes No N/A Not

Inspected Notes Storage controls leachate and runoff: Recent heavy rains led to the unauthorized discharges discussed in Section II and VIII. There was no evidence of uncontrolled leachate.

Stormwater handling description No separate description is needed.

Attachment 1: December 14, 2016, TSS Result and

December 2016 SMR Data Table for Discharge Point 001

Laboratories, Inc.Environmental Testing Laboratory Since 1949

Lehigh SW Cement Co.

24001 Stevens Creek Blvd

Cupertino, CA 95014

Project:

Project Number:

Project Manager:

Lehigh

EFF-001A

Sam Barket

Reported: 12/29/2016 11:19

BCL Sample ID: 1635318-03 Client Sample Name:

Constituent Result Units Method Bias QualsMB Lab

Water Analysis (General Chemistry)

Run #

EFF-001A LC-SW20161214-EFF-001A, 12/14/2016 3:15:00PM, Stefan Hoeft

MDLPQL

Total Suspended Solids (Glass Fiber) mg/L S050.563.8 0.56 EPA-160.2 1ND

QC

Batch IDDilutionInstrumentAnalystDate/Time

Run

Prep DateMethodRun #

12/22/16 12/22/16 12:25 OJP MANUAL 1.111 BZL1911EPA-160.2 1

The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.All results listed in this report are for the exclusive use of the submitting party. BC Laboratories, Inc. assumes no responsibility for report alteration, separation, detachment or third party interpretation.

4100 Atlas Court Bakersfield, CA 93308 (661) 327-4911 FAX (661) 327-1918 www.bclabs.com Page 8 of 12Report ID: 1000557922

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Monitoring Location EFF-001A, December 14, 2016, TSS result of 3.8 mg/L.
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CIWQS Place ID 273205 Monthly Self‐Monitoring Summary ReportLehigh Southwest Cement Company Permanente Plant

NPDES Permit No. CA0030210December 2016

Pond 4A: Discharge 001 Total Res Settleable Chromium

Date Flow Rate TSS O&G Temp pH Chlorine Matter (VI)1 Mercury Nickel1 Selenium Thallium1 TDS Turbidity Acute Tox Survival  Reproductive Standard Observationsgpd mg/L mg/L degree C s.u. mg/L mL/L/hr ug/L ug/L ug/L ug/L ug/L mg/L NTU % survival TUc  TUc  mg/L lbs/day

cont. 1/week 1/month 1/month 1/day 1/day 1/month 2/month 1/month 2/month 1/month 2/month 1/week 1/day 1/quarter 1/day (M‐F) 1/weekGrab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab C‐24 Grab

20 6.5, 8.5 0.0 0.20 16 0.020 160 8.2 3.4 2000 10 58.010 0.10 8.0 0.041 82 4.1 1.7 1000 5.0

230 1.3 60012/1/2016 1,498,206 7.7 0.0 2.1 Green/clear, no odor 4.6 * 13.912/2/2016 1 1,294,732 7.6 0.0 2.5 Blue/clear, no odor 11.512/3/2016 911,909 0.012/4/2016 533 0.012/5/2016 861,038 7.5 0.0 6.3 Blue, no odor 0.012/6/2016 1,233,618 7.6 0.0 2.8 Blue/clear, little foam, no odor 13.812/7/2016 2 1,141,714 7.7 0.0 2.5 Blue/clear, no odor 9.3 H 19.312/8/2016 1,576,248 3.3 7.6 0.0 ND<0.10 26.0 1000 3.8 Blue/clear, no odor 3.8 H 10.912/9/2016 1,559,150 7.5 0.0 5.7 some suspended material, clear no odo 9.8 32.012/10/2016 1,772,574 45.212/11/2016 1,488,584 59.012/12/2016 1,165,672 7.7 0.0 3.7 Clear, no odor 0.012/13/2016 1,340,074 7.7 0.0 2.3 100 Clear, no odor 20 H 29.712/14/2016 3 1,598,433 7.7 0.0 3.1 Blue/clear, no odor 52.412/15/2016 1,754,035 7.8 0.0 10.1 Gray, no odor 95.012/16/2016 1,686,346 4.0 ND<0.76 13.29 7.8 0.0 ND<0.10 6.5 0.00645 89 27.7 0.21 J 940 14.6 2.9 6.4 Clear/gray, no odor. 73.812/17/2016 1,819,465 94.312/18/2016 1,582,662 41.212/19/2016 1,490,584 7.5 0.0 3.08 Clear, no odor 17 45.712/20/2016 1,330,121 2.3 7.8 0.0 ND<0.10 13 68 23.3 ND<0.10 890 8.6 Gray, no odor 40.112/21/2016 4 1,340,594 7.8 0.0 2.7 Blue/clear, no odor 0.012/22/2016 1,095,440 7.9 0.0 2.0 Blue/clear, no odor 0.012/23/2016 1,213,096 4.012/24/2016 0 0.012/25/2016 0 0.012/26/2016 695,070 0.012/27/2016 1,289,926 7.8 0.0 2.3 Clear, no odor 0.012/28/2016 5 1,169,772 7.6 0.0 2.6 Clear, no odor 2.012/29/2016 1,649,183 2.6 7.7 0.0 ND<0.10 28.7 1000 2.90 Clear, no odor 11.0 41.312/30/2016 1,001,137 NM 0.0 4.7 Clear, no odor 19.712/31/2016 0 0.0Max Daily Flow (gpd) 1,819,465 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐Min Daily Flow (gpd) 0 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐

Monthly Ave Flow (MGD) 1.2 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐36.6 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐‐ 4.0 ND ‐ 7.9 0.0 ND 13 0.00645 89 28.7 0.21 1000 14.6 ‐ ‐ ‐ ‐ ‐ 95.0‐ ‐ ND ‐ ‐ ‐ ND 9.9 0.00645 78 26.4 ND 958 4.4 ‐ ‐ ‐ ‐ ‐ ‐

1/day applies to Monday through Friday; J = estimated value below reporting limit (DNQ); H = sample holding time was exceeded*  weekly sample collected on 11/28/16;  ** weekly TSS result is still pendingNM = not measured due to meter malfunction

Chronic Toxicity 001A

TSS

Monthly Average

Units

Sample FrequencySample Type

Limit ‐ Daily MaxLimit ‐ Monthly Ave

1/quarter

1= flow‐weighted average effluent concentration calculated, defined as the summed products of the pollutant concentration in each sample collected and analyzed in a calendar montmultiplied by the volumetric flow rate at the time the sample was collected, divided by the sum of those flow rates. Non‐detectresults shall be treated as zero.

Monthly MaxMonthly Total (MG)

Interim Limit (CDO)

C‐24

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December 14, 2016, TSS result reported for December 8, 2016; corresponding mass discharge should be based on 9.3 mg/L TSS.
jmadigan
Callout
December 14 - 17, 2016, mass discharge should be based on December 14, 2016, TSS result (3.8 mg/L).
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Attachment 2: Site Photos

February 14, 2017 NPDES Compliance Evaluation Inspection

Lehigh Southwest Cement Co., Permanente Facility

24001 Stevens Creek Blvd. Cupertino, CA

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

2

Photo 1: Pond 13B. Pond has not discharged since March 2014

Photo 2: Discharge Point 002 viewed from west side of Pond 13 / Permanente Creek.

Pond 13B is directly behind the discharge point and embankment.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

3

Photo 3: Pond 13 dam and footbridge, viewed from west bank of

Permanente Creek. Pond 13 is left of the photo.

Photo 4: Pond 13 viewed looking upstream (North) from the footbridge.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

4

Photo 5: Permanente Creek at receiving water Monitoring Location RSW-001,

approximately 50 feet upstream of Pond 13.

Photo 6: Culverted section of Permanente Creek viewed looking South from the footbridge.

Receiving water Monitoring Location RSW-002 is located within this reach.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

5

Photo 7: Pond 9, to the left; Permanente Creek and Discharge Point 003 are to the right.

Note straw wattles to prevent runoff from entering pond.

Photo 8: Outlet from Pond 9. California red-legged frogs preclude

maintenance of the outlet. Flow was audible but not visible.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

6

Photo 9: Permanente Creek near Discharge Point 003. The discharge point itself was not accessible.

Photo 10: Pond 17 (lower end) and retained water.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

7

Photo 11: Pipe overhanging Pond 17, source unknown.

Photo 12: Pond 17 (middle section) and internal check dam.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

8

Photo 13: Pond 17 (upper section). Check dam appears breached.

Photo 14: Pond 17 outlet point to Discharge Point 004. Water level in pond is below the inlet;

however, Photo 16 shows a discharge at Discharge Point 004.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

9

Photo 15: Discharge Point 004 and Permanente Creek

Photo 16: Discharge Point 004. Note a discharge and a second, small-diameter pipe.

The discharge may be due to infiltration into the discharge pipe; facility representatives stated the small-diameter pipe may have been installed at this location to avoid the need to trench.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

10

Photo 17: Dinky Shed. This is the low point for runoff from upstream roads and hillsides,

including that diverted from Pond 9. Water collected here is pumped to Pond 1.

Photo 18: Road washout near Dinky Shed (center background). The abandoned pipe is the old Discharge Point 004 line; facility representatives stated it was damaged by equipment clearing debris after the road had washed out.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

11

Photo 19: Pond 20 looking west from the lower end. Check dams absent.

Photo 20: Monitoring Location EFF-005 at Discharge Point 005

from Pond 20 (lower end). Note silt from recent rains.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

12

Photo 21: Pond 20, typical Floc Log installation secured against high flows.

Photo 22: Pond 20, looking upstream (west) from Discharge Point 005. Note the partially washed-out check dam in the center of the photo.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

13

Photo 23: Sodium bisulfite at Pond 20 for pH control.

Photo 24: Sodium bisulfite application point.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

14

Photo 25: Permanente Creek near the Pond 1 emergency discharge point;

the discharge point itself could not be observed.

Photo 26: Pond 1 emergency discharge outlet.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

15

Photo 27: Pond 1 from east side. Capacity is 4 million gallons. Influent pipes are visible in the far left corner and near the far

right corner of the pond; effluent pump to Pond 11 is at center of far side.

Photo 28: Overland flow to Pond 1 (to left). Flow from hoses (center-right, upper left) is from underground maintenance

work; flow from pipe in front of concrete block (right) is from the truck wash.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

16

Photo 29: Truck wash discharge from pipe in front of concrete block.

Photo 30: Discharge from hose in upper left of Photo 27

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

17

Photo 31: Pond 30. Outlet pipe to Discharge Point 006 is visible in center; frog-proof fence on opposite bank. California red-

legged frogs were audible.

Photo 32: Upper (eastern) end of Pond 30, directly left of part shown in previous photo.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

18

Photo 33: Swale leading to Pond 30 (left of photo).

Photo 34: Holding tank on north side of Pond 30 stores underground flow intercepted by a recently installed French drain

before it reaches Pond 30. The Discharger is considering sending this water to Pond 1 and ultimately to treatment.

Lehigh Southwest Cement Company Permanente Plant

CIWQS Inspection No. 27604036

Attachment 2 – Site Photos NPDES Compliance Evaluation Inspection Report

19

Photo 35: Discharge Point 006. Discharge is occurring despite Pond 6 water level not reaching outfall pipe (see Photo 29).

Photo 36: Riprap slope to Permanente Creek (not visible).