re: albemarle west plant brine disposal system inspection ... · inspection report: albemarle west...

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September 24, 2018 Jason L. Bevan, Plant Manager Albemarle Corporation P.O. Box 729 Magnolia, AR 71754 RE: Albemarle West Plant Brine Disposal System Inspection (Columbia Co) AFIN: 14-00011 State Permit No.: 4007-WR-3 Dear Mr. Bevan: On August 21 and August 23, 2018, I performed a Reconnaissance Inspection of the above-referenced facility in response to a reported 500bbl release into Big Creek. This inspection was performed in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. A copy of the inspection report is enclosed for your records. Please refer to the “Summary of Findings” section of the attached inspection report and provide a written response for each violation that was noted. This response should be mailed to the attention of the Office of Water Quality Inspection Branch at the address at the bottom of this letter 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 documentation (i.e., photos) is due by October 8, 2018. If I can be of any assistance, please contact me at [email protected] or (501) 837-2073. Sincerely,

Michael Young District 8 Field Inspector Office of Water Quality

Inspection Report: Albemarle West Plant Brine Disposal System, AFIN: 14-00011, Permit #: 4007-WR-3

Inspection Report Page 2 of 17

WATER DIVISION INSPECTION REPORT AFIN: 14-00011 PERMIT #: 4007-WR-3 DATE: 8/21/2018 COUNTY: 14 Columbia PDS #: 104607 MEDIA: WN GPS LAT: 33.248349 LONG: -93.282079 LOCATION: General Area

FACILITY INFORMATION INSPECTION INFORMATION NAME:

Albemarle West Plant Brine Disposal System LOCATION:

West of Columbia County 15 CITY:

Magnolia, AR

FACILITY TYPE:

2 - Industrial INSPECTOR ID#:

101531 S - State FACILITY EVALUATION RATING:

N INSPECTION TYPE:

Reconnaissance DATE(S): ENTRY TIME: EXIT TIME:

8/21/2018 09:46 10:51 8/23/2018 09:30 12:20 8/29/2018 09:40 12:00

PERMIT EFFECTIVE DATE:

1/1/2014 PERMIT EXPIRATION DATE:

12/31/2018 RESPONSIBLE OFFICIAL

NAME: / TITLE

Jason L. Bevan / Plant Manager COMPANY: Albemarle Corporation MAILING ADDRESS:

P.O. Box 729 CITY, STATE, ZIP: Magnolia AR 71754 PHONE & EXT: / FAX:

870-235-6000 / 870-235-6001 EMAIL:

[email protected]

FAYETTEVILLE SHALE RELATED: N FAYETTEVILLE SHALE VIOLATIONS: N

INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/EMAIL/ETC.:

Steven Stamps/870-235-6000 Philip Storey/870-235-6000 Josh Wiggins/870-235-6000 Robin Goldsby/ADEQ D8 Water Inspector Dr. Kendall Moles/AGFC Malacologist (on 8/29/2018) Brittanie Gloyd/ADEQ D7 Water Inspector (on 8/29/2018)

CONTACTED DURING INSPECTION: No

AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated)

S PERMIT ** FLOW MEASUREMENT ** STORMWATER ** RECORDS/REPORTS ** LABORATORY ** FACILITY SITE REVIEW ** OPERATION & MAINTENANCE ** EFFLUENT/RECEIVING WATER ** SELF-MONITORING PROGRAM ** SAMPLING ** SLUDGE HANDLING/DISPOSAL ** PRETREATMENT ** OTHER:

SUMMARY OF FINDINGS 1.) Tail brine released from the West Plant Brine Disposal System entered Big Creek. This is a violation of the Arkansas Water and Air Pollution Control Act 472 (A.C.A. § 8-4-217(a)(1)) which states, ” Cause pollution, as defined in § 8-4-102, of any of the waters of this state.” 2.) A rupture of an 8” transite line caused a release of 500bbl tail brine from the disposal system. This is a violation of permit condition Part I. (6.).



GENERAL COMMENTS On August 21, 2018 at approximately 08:00, I was contacted by Steve Card, Albemarle Environmental Manager, who stated that a release of an unknown amount of tail brine occurred overnight in Magnolia, AR. Mr. Card stated that there may be a fish kill as a result in Big Creek. At approximately 09:46, I arrived at the location of the release. I immediately observed an excavated area with an 8” pipe exposed (see Photo 1) and a flow feature where the tail brine entered Big Creek (see Photo 2). Immediately downstream of the release, I observed numerous deceased fishes of different species (see Photos 3-9). I arranged to return on August 23 to further assess the extent of the kill after Albemarle had investigated the release and commenced remediation. On August 23, 2018 at approximately 09:30, I arrived to continue the assessment of the tail brine release. Albemarle crews had cleared an area along Big Creek to provide better access and had stated that the endpoint of the fish kill was ~1.5 miles downstream from the release. I confirmed the extent of the fish kill and observed fishes, turtles, crayfish, and numerous mussels. I contacted AGFC Malacologist Dr. Kendall Moles who stated that he would return to the area on August 29, 2018 to conduct a collection of shells for identification purposes. On August 29, 2018, Dr. Moles, Brittanie Gloyd, ADEQ District 7 Water Inspector, and I conducted a mussel shell collection in Big Creek. During the collection, I observed that the crews continued to remediate Big Creek by releasing freshwater upstream of the impacted area and pumping downstream. A fish kill report will be generated as a result of this release. The facility was required to send a Sampling Analysis Plan (SAP) to ADEQ Water Division Enforcement Branch and daily email updates. A copy of the final report of remediation will be required as a response to this inspection report.

INSPECTOR’S SIGNATURE: Michael Young DATE: 9/17/2018

SUPERVISOR’S SIGNATURE: Kerri McCabe DATE: 9/21/2018



ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

NO DISCHARGE INDUSTRIAL PERMIT INSPECTION FORM

AFIN: 14-00011 Log No.:

Permit No.: 4007-WR-3 Inspection Date: August 21, 2018

Media: Water Inspector: Michael Young

Compliance Status: ¨ IN / OUT

1A. Description of Process (including type of industry, materials produced, and major by- products): Tail Brine disposal system for Albemarle West Plant

2A. Any complaints registered against this permitted facility? ¨Yes No If yes, give date and description of complaint: 3A. Are there any additions, modifications, or corrections to the facility since the last inspection? ¨ Yes No If yes, explain: 1B. Furnish a simplified flow diagram of the treatment system and include main components, flow

sequence through plant, and calculated or estimated flows. West PlantCooling TowersTail Brine PipelineClass V Injection Wells 2B. Nearest Stream: Big Creek 3B. Does wastewater from this facility cause adverse effect on the waters of the State: Yes ¨No If yes, describe: During a release wastewater causes impairments and adverse effects. 4B. Are operating records kept as required by permit? Yes ¨No ¨N/A If no, explain:

5B. Are maintenance records kept as required by permit? Yes ¨No ¨N/A

If no, explain: 6B. Are Samples routinely taken? ¨ Yes ¨No N/A 7B. Does the sampling program meet the requirements of the permit? ¨ Yes ¨No N/A If no, explain: 8B. What laboratory does the facility use? Address: Telephone:

1C. Do laboratory procedures and records meet the requirements of the permit? ¨ Yes ¨No N/A If no, explain: 2C. Is contaminated runoff a problem? ¨ Yes No ¨N/A



If yes, explain: 3C. Is sludge disposal required? ¨ Yes No ¨N/A If yes, describe (including final destination):

4C. Is the treatment system being properly operated and maintained as required by permit?

¨ Yes ¨No N/A If no, explain Inspector Signature:

Michael Young Date of Report: September 17, 2018

Signature of Reviewer:

Kerri McCabe Date of Review: September 21, 2018



Water Division Photographic Evidence Sheet

Location: Albemarle West Plant Brine Disposal SystemOff Columbia County Road 15 in Magnolia, AR Photographer: Michael Young Date: 08/21/2018 Time: 10:49 Witness: Robin Goldsby Photo #: 1 Description: Excavated area and 8” transite line where tail brine release occurred.

Photographer: Michael Young Date: 08/21/2018 Time: 10:51 Witness: Robin Goldsby Photo #: 2 Description: Flow path of tail brine to Big Creek.




Location: Albemarle West Plant Brine Disposal SystemOff Columbia County Road 15 in Magnolia, AR Photographer: Michael Young Date: 08/21/2018 Time: 10:26 Witness: Robin Goldsby Photo #: 3 Description: Deceased fishes in Big Creek.

Photographer: Michael Young Date: 08/21/2018 Time: 10:26 Witness: Robin Goldsby Photo #: 4 Description: Deceased fishes in Big Creek.





Photographer: Michael Young Date: 08/23/2018 Time: 10:14 Witness: Photo #: 10 Description: Deceased fishes in Big Creek.




Location: Albemarle West Plant Brine Disposal SystemOff Columbia County Road 15 in Magnolia, AR Photographer: Michael Young Date: 08/23/2018 Time: 10:20 Witness: Photo #: 11 Description: Deceased fishes in Big Creek.

Photographer: Michael Young Date: 08/23/2018 Time: 10:24 Witness: Photo #: 12 Description: Deceased fishes in Big Creek.




Location: Albemarle West Plant Brine Disposal SystemOff Columbia County Road 15 in Magnolia, AR Photographer: Michael Young Date: 08/23/2018 Time: 10:20 Witness: Photo #: 13 Description: Deceased turtle in Big Creek.

Photographer: Michael Young Date: 08/23/2018 Time: 10:49 Witness: Photo #: 14 Description: Deceased turtle in Big Creek.




Location: Albemarle West Plant Brine Disposal SystemOff Columbia County Road 15 in Magnolia, AR Photographer: Michael Young Date: 08/23/2018 Time: 10:32 Witness: Photo #: 15 Description: Deceased crayfish in Big Creek.

Photographer: Michael Young Date: 08/23/2018 Time: 10:16 Witness: Robin Goldsby Photo #: 16 Description: Deceased mussel in Big Creek.




Location: Albemarle West Plant Brine Disposal SystemOff Columbia County Road 15 in Magnolia, AR Photographer: Michael Young Date: 08/23/2018 Time: 10:21 Witness: Photo #: 17 Description: Deceased mussel in Big Creek.

Photographer: Michael Young Date: 08/23/2018 Time: 10:51 Witness: Photo #: 18 Description: Deceased mussel in Big Creek.



Figure 1. Overview of the extent of the fish kill in Big Creek as the result of a tail brine release.

From: Young, MichaelTo: McConnell, MelissaSubject: FW: Albemarle Tail Brine Spill Follow-up Report on Big CreekDate: Tuesday, October 30, 2018 11:49:20 AMAttachments: Followup Spill Remediation Report - Big Creek 2018.pdf

Melissa, Would you please attach this to WID 24913? Thank you, Michael YoungDistrict 8 InspectorEl Dorado Field OfficeADEQ Office of Water QualityCell Phone: [email protected]

From: Healey, Richard Sent: Tuesday, September 25, 2018 9:54 AMTo: Clem, SarahCc: Leamons, Bryan; Bolenbaugh, Jason; Osborne, Caleb; Lemaster, Jeff; Hanson, Linda; Solaimanian,Jamal; McCabe, Kerri; Young, Michael; Johnson, Miles; Taylor, Bailey; Lawrence, MyrlSubject: Albemarle Tail Brine Spill Follow-up Report on Big Creek SarahPlease review the attached follow-up spill remediation report for the Albemarle tail brine releaseinto big creek. Please let me know if any additional remediation is needed. Thanks

Richard C. HealeyEnforcement Branch ManagerOffice of Water QualityArkansas Department of Environmental [email protected] From: [email protected] [mailto:[email protected]] Sent: Thursday, September 20, 2018 2:45 PMTo: Healey, Richard; Young, MichaelCc: [email protected]; [email protected]: Tail Brine Spill Follow-up Report See attached follow-up report for tail brine spill that occurred on August 20, 2018.

Thanks,
mailto:/O=ARKANSAS DEPT. OF ENVIRONMENTAL QUALITY/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=YOUNGMmailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]

December 6, 2018 Jason L. Bevan, Plant Manager Albemarle Corporation P.O. Box 729 Magnolia, AR 71754 RE: Albemarle Tail Brine Release - Response to Inspection (Columbia Co)

AFIN: 14-00011 State Permit No.: 4007-WR-3 Dear Mr. Bevan: I have reviewed the response pertaining to my August 21 and 22, 2018 follow-up of the 500bbl tail brine release into Big Creek. The information provided sufficiently addresses the violations referenced in my inspection report. At this time, the Department has no further comment concerning this particular inspection. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. 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) 837-2073 or you may e-mail me at [email protected]. Sincerely,

Michael Young District 8 Field Inspector Office of Water Quality

24913.pdfFW_ Albemarle Tail Brine Spill Follow-up Report on Big CreekFollowup Spill Remediation Report - Big Creek 2018 (2)

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