august 18, 2008 mr. jimmy meadows, president … 18, 2008 mr. jimmy meadows, president r.u.m., inc....

August 18, 2008 Mr. Jimmy Meadows, President R.U.M., Inc. P.O. Box 181060 Fort Smith, AR 72918 RE: Shiloh Creek Apartments, Russellville, AR AFIN: 58-00573 NPDES Permit No.: ARR152402 Dear Mr. Meadows: On July 31, 2008, Amy Beck and I performed a routine compliance inspection of the above referenced construction site 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. The Storm Water Pollution Prevention Plan (SWPPP) for the site was not being kept current. This is a violation of Part II.A.3 of the permit. Rock check dams noted on the site map along the western side of the property were not in place on the day of inspection. Additional silt fencing that had been installed on site was not noted on the site map. 2. The silt fencing that was on site was observed as not being properly installed and maintained. This is a violation of Part II.B.17 of the permit. 3. Sediment was observed along the northern edge of the property beyond the installed silt fencing. This sediment has a high potential to enter the waters of the State (Shiloh Creek). This is a violation of Section 8-4-217(a)(2) of the Arkansas Water and Air Pollution Control Act 472. 4. The required on-site inspections of outfalls and sediment controls were not conducted as per the SWPPP and the permit. This is a violation of Part II.A.4.e of the permit. Your SWPPP requires that these inspections be conducted at least once every seven days. Additionally, evidence of concrete washout was observed at the site in close proximity to Shiloh Creek. This washout was allowed to flow across the property towards the creek. While not a violation at this time, please be reminded that the general storm water permit does not allow for the off-site discharge of such materials. 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

Shiloh Creek Apartments August 18, 2008

Storm Water Report Page 2

contain detailed documentation describing the course of action taken to correct the items noted. This corrective action should be completed as soon as possible, and the written response is due by September 11, 2008. 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 any assistance, please contact me at 479-968-7339. Sincerely, Greg Kremers District 5 Field Inspector Water Division cc: Water Division Enforcement Branch

Water Division Permits Branch

ADEQ Const. Storm Water Insp. AFIN: 58-00573 Permit #: ARR152402

Storm Water 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 2 4 0 2 11 12 0 8 0 7 3 1 17 18 W 19 S 20 2

Remarks

A F I N 5 8 --- 0 0 5 7 3 Inspection Work Days

Facility Evaluation Rating

BI

QA

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

67 0 0 1

69

70 N

71

N

72

N

73

74

75

80

Section B: Facility Data

Entry Time/Date 1000 / 7-31-2008

Permit Effective Date July 19, 2007

Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) Shiloh Creek Apartments 803 Sandstone Circle Russellville, AR 72802

Exit Time/Date 1105 / 7-31-2008

Permit Expiration Date

Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Guy Dickinson, Job Superintendent / 479-264-7338

Other Facility Data

Contacted

Yes No

Name, Address of Responsible Official/Title/Phone and Fax Number Jimmy Meadows, President R.U.M., Inc. P.O. Box 181060 Fort Smith, AR 72918

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

N U N S Sampling Operations & Maintenance Flow Measurement Permit

N N N S Pollution Prevention Sludge Handling/Disposal Self-Monitoring Program Records/Reports

N N N N Facility Site Review Compliance Schedules Pretreatment Multimedia

N N U N Effluent/Receiving Waters Laboratory Storm Water Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) Previous inspection conducted on May 6 & 7, 2008. Observed violations on 7-31-2008:SWPPP not being kept current. Silt fencing not being properly installed and maintained. Sediment leaving the site with potential to enter waters of the State. On-site inspections not being performed per the SWPPP.

Date Name(s) and Signature(s) of Inspector(s) Agency/Office/Telephone/Fax Arkansas Department of Environmental Quality /

August 18, 2008 Russellville / 479-968-7339 / 479-968-7321 Greg Kremers Signature of Reviewer Agency/Office/Phone and Fax Numbers Date


Storm Water Report

A. General Information Site Name: Shiloh Creek Apartments Latitude: N35° 18’ 49.64” Longitude: W93° 07’ 44.38” Total Acreage: 9 Acreage Disturbed: 9 Starting Date: October, 2007 Project Type:

Residential Commercial Industrial Roadway Other: Construction Stage:

Clearing Rough Grading Infrastructure Building Construction Final Stabilization Inactive Other:

Permit Type: General Individual Unpermitted

Site Posted: Yes No Improper

B. Storm Water Pollution Prevention Plan (SWPPP) [Part II Section A of Permit] SWPPP Developed and Onsite? Yes No Incomplete Not Updated as Needed Comments: Rock check dams noted on the site map along western side of property were not in place. Additional silt fencing that was in place was not noted on the site map. Are Stabilization Practices Satisfactory? Yes No NA Comments: Are erosion controls Satisfactory? Yes No NA Comments: See Photos 1-6. Evidence of sediment leaving the site? Yes No NA Comments: Sediment deposits observed beyond silt fencing. Evidence of off-site tracking? Yes No NA Comments: Evidence of sediment entering the Waters of the State? Yes Likely No NA Comments: At northwest corner of property. See Photo 3 & 4. Are inspections conducted and records kept as required in the permit? Yes No NA Comments: SWPPP requires inspections every 7 days. Last documented inspection was on 7-23-2008 or 8 days prior to ADEQ visit. Is corrective action taken based on results of inspections? Yes No NA Comments: Unable to determine. Last 4 documented inspections showed silt fence to be OK. See Photo 7. Inspections that were conducted did not appear to be done adequately. Are daily rainfall totals recorded? Yes No NA Rainfall measured using: On-site Rain Gauge NA Other: Comments: Rain gauge missing on day of inspection General Comments:


Storm Water Report

Water Division Construction Storm Water Photographic Evidence Sheet Location: Shiloh Creek Apartments, Russellville, AR Photographer: Witness: Greg Kremers Amy Beck Photo # Of 1 8 Date: Time: 7-31-08 1025 Description: Major site outfall at NW corner of property. Undercut fence is partially visible at bottom center.

Photographer: Witness: Greg Kremers Amy Beck Photo # Of Date: Time: 2 8 7-31-08 1025 Description: Closer view of Photo 1 showing the undercut fence. Flow is concentrated at this location.


Storm Water Report

Water Division Construction Storm Water Photographic Evidence Sheet Location: Shiloh Creek Apartments, Russellville, AR Photographer: Witness: Greg Kremers Amy Beck Photo # Of 3 8 Date: Time: 7-31-2008 1026 Description: Section of unmaintained silt fence located behind fencing seen in Photo 1 & 2.

Photographer: Witness: Greg Kremers Amy Beck Photo # Of Date: Time: 4 8 7-31-2008 1026 Description: Sediment deposit at NW outfall on the bank of Shiloh Creek.


Storm Water Report

Water Division Construction Storm Water Photographic Evidence Sheet Location: Shiloh Creek Apartments, Russellville, AR Photographer: Witness: Greg Kremers Amy Beck Photo # Of 5 8 Date: Time: 7-31-2008 1020 Description: Silt fencing along north side of property that was not entrenched.

Photographer: Witness: Greg Kremers Amy Beck Photo # Of Date: Time: 6 8 7-31-2008 1023 Description: Two sections of silt fencing not properly joined.


Storm Water Report

Water Division Construction Storm Water Photographic Evidence Sheet Location: Shiloh Creek Apartments, Russellville, AR Photographer: Witness: Greg Kremers Amy Beck Photo # Of 7 8 Date: Time: 7-31-2008 1101 Description: Last inspection form for July, 2008. Note the last 4 inspections.

Photographer: Witness: Greg Kremers Amy Beck Photo # Of Date: Time: 8 8 7-31-2008 1029 Description: Concrete washout.

October 2, 2008 Jimmy Meadows R.U.M. Inc. P.O. Box 181060 Fort Smith, AR 72918 RE: Shiloh Creek Apartments, NPDES Permit Tracking Number ARR152402,

AFIN 58-00573, Response to Inspection Dear Mr. Meadows: The Department has received your response to the July 31, 2008 inspection of your facility by our District Field Inspectors, Amy Beck and Greg Kremers. Your response appears to adequately address the discrepancies identified during the visit. The Department assumes 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 company 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 Administrator Water Division Enforcement Section

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