Document 2NbB6ZKBLGQBpvK7187bgnK06
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
05/22/2024 Water (CWA) Water (CWA) Construction Stormwater Program
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
MidAmerica Environmental Holdings, LLC
USA Disposal - El Dorado
101 Warehouse Drive
El Dorado, AR 71730
4101 Old Oak Drive
Little Rock, AR 72212
Union County
501-404-2020
Kirk Brown (318-773-3852)
Director of Operations
Kirk.brown@trekkerenergy.com
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
N/A ARR153062; ADEQ AFIN 70-01210 for the facility N/A 213112 1389
Personnel participating in inspection:
Kerri McCabe
EPA / Region 6 ECDW
Michael Young
ADEQ / Office of Water Quality
Kirk Brown
Trekker Energy Services
Cody Eubanks
MidAmerica Environ. Holdings, LLC
Inspector / Enforcement Officer Inspector Supervisor Director of Operations Site Manager
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
KERRI MCCABE
Kerri McCabe
Digitally signed by KERRI MCCABE Date: 2024.06.05 10:54:52 -05'00'
Date
JEANNE ECKHART Date: 2024.06.10 16:16:57 -05'00' Digitally signed by JEANNE ECKHART
Jeanne Eckhart
Date
6ENFORM-019-R8.2 (02/12/2020)
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MidAmerica Environmental Holdings, LLC / USA Disposal - El Dorado (ARR153062 / CWA) Inspection Date 05/22/2024
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
EPA Region 6 inspector Kerri McCabe (lead) arrived at MidAmerica Environmental Holdings, LLC / USA Disposal - El Dorado, located at 101 Warehouse Drive, El Dorado, Arkansas, 71730 at 33.204359, 92.613940; at 1050 on 05/22/2024 for an announced inspection. Mr. Kirk Brown, Trekker Energy Services, was present at the time of the inspection. The inspection was conducted by the authority of the Clean Water Act (CWA) and the National Pollution Discharge Elimination System (NPDES) Construction Stormwater General Permit (CGP; ARR153062) issued by the Arkansas Department of Energy and Environment - Division of Environmental Quality (hereafter "ADEQ") to determine compliance with Environmental Protection Agency (EPA) regulations. Mr. Micheal Young, with ADEQ - Office of Water Quality - Compliance Branch, was present at the time of the inspection.
Details of the latest CGP inspection conducted by ADEQ - Office of Water Quality on 04/22/2020 can be found at the following hyperlink:
https://www.adeq.state.ar.us/downloads/WebDatabases/InspectionsOnline/111814-insp.pdf
FACILITY DESCRIPTION
EPA conducted an inspection on the MidAmerica Environmental Holdings, LLC / USA Disposal - El Dorado site, which is a drilling mud bulking facility for oil-based and water-based drilling fluids, Exploration and Production (E&P) wastes, and additional liquid wastes listed in the State No-Discharge (SND, 5077-WR-7) permit issued by the State of Arkansas. There are five (5) concrete holding pits, 23 frac tanks, one (1) storage building for bulking material (sawdust), one (1) concrete slab for stockpiling bulked material (sawdust blended with liquid wastes), and one (1) stormwater pond. Approximately 6.5 acres of the active property have been used for land filling and land application of bulked material.
The facility was formally a mining site and borrow pit for clay soil.
The original CGP was issued 09/01/2009, and the CGP has been recertified three times for 2011, 2016, and 2021. The general permit expires 10/31/2026. All construction activity listed in the original Stormwater Pollution Prevention Plan (SWPPP) submitted with the CGP Notice of Intent (NOI) has been completed, see hyperlink for original SWPPP submitted with the CGP NOI.
For additional information on the facility's CGP history and original SWPPP, see the hyperlinks below:
https://www.adeq.state.ar.us/home/pdssql/p_permits_online_npdes_additonal.aspx?PmtNbr=ARR153 062&Category=PermitInformation&Title=Permit%20Information
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MidAmerica Environmental Holdings, LLC / USA Disposal - El Dorado (ARR153062 / CWA) Inspection Date 05/22/2024
https://www.adeq.state.ar.us/downloads/WebDatabases/PermitsOnline/NPDES/PermitInformation/AR R153062_SWPPP_20090901.pdf
Aerial Image 1. Overview of USA Disposal facility. Google Earth image date 05/14/2023. Section II - OBSERVATIONS I observed the signage and an overview of the facility, see Appendix 1 (Photograph Log), Photo No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed disturbed soil associated with land filling and land applying activities. See Photo No. 3 through No. 5. I observed the sedimentation pond associated with the original CGP converted into a stormwater pond. The stormwater pond contained unknown liquid wastes and sediment. Black staining, a hydrocarbon sheen, gas bubbles, and an odor were noted at the stormwater pond. See Photo No. 6. I observed areas associated with the original construction project outlined in the SWPPP, which included two (2) small concrete holding pits (see Photo No. 7 through No. 9), three (3) larger concrete holding pits (see Photo No. 10 through No. 12), a concrete slab used for bulking sawdust and liquid wastes (see Photo No. 13), and outbuildings used for sawdust storage and office space (see Photo No. 14).
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MidAmerica Environmental Holdings, LLC / USA Disposal - El Dorado (ARR153062 / CWA) Inspection Date 05/22/2024
Section III - AREAS OF CONCERN
A closing conference was held with Mr. Kirk Brown with Trekker Energy Services during the inspection. Areas of concern at the time of the inspection include the following (also noted with Appendix 2, CGP Inspection Cheek Sheet):
An active discharge from the stormwater pond via opened drainpipe of stormwater commingled with unknown liquid wastes, see CGP Part I, Section B., Condition 11, B.;
Releases of unknown liquid wastes from the concrete pits and leachate from bulked material, see CGP, Part I, Section B., Condition 13, D., 3;
Releases throughout the property and stormwater pond contents noted with hydrocarbon sheens, see CGP, Part I, Section B., Condition 13, E., 5;
Releases throughout the property noted with hydrocarbon sheens, see CGP, Part I, Section B., Condition 22, A. and B.;
The SWPPP has not been updated since August 2009, see CGP, Part II, Section A., Condition 1, C.; The SWPPP and associated contents were not available onsite, see CGP, Part II, Section A.,
Condition 2, A.; The SWPPP has not been updated since August 2009, see CGP, Part II, Section A., Condition 3; Documents required by the SWPPP are not maintained, see CGP, Part II, Section B., Condition 1,
A. and B.; Releases of unknown liquid wastes from the process area and leachate from stockpiled bulked
material were noted throughout the property, see CGP, Part II, Section B., Condition 6; The designated stormwater pond contained unknown wastes, concrete holding pits had erosion
in the earthen berms from releases, and frac tanks onsite had no secondary containment; see CGP, Part II, Section B., Condition 17, A.
Information about the CGP (ARR153062), issued to the operator by ADEQ, can be viewed at the following hyperlink:
https://www.adeq.state.ar.us/downloads/WebDatabases/PermitsOnline/NPDES/Permits/ARR153062.p df
Section IV - FOLLOW UP
Inspector will conduct follow-up phone calls with the company representative(s) over the coming weeks and months to ensure areas of concern are properly addressed.
Section V - LIST OF APPENDICES
Appendix 1 - Photograph Log - 14 photos taken 05/22/2024. Appendix 2 - CGP Inspection Check Sheet
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MidAmerica Environmental Holdings, LLC / USA Disposal - El Dorado (ARR153062 / CWA) Inspection Date 05/22/2024
Appendix 1 Photograph Log
14 Photos
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010150 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1231 Latitude: 33.204317 Longitude: -92.614067 Photographer: Kerri McCabe Description: Looking SW, this photo showed the signage for the facility.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010151 Orientation: NW Date of Photo: 05/22/2024 Time of Photo: 1231 Latitude: 33.204305 Longitude: -92.614038 Photographer: Kerri McCabe Description: Looking NW, this photo showed the overview of the facility. This area is part of the original Construction Stormwater General Permit (CGP) issued by the State of Arkansas in September 2009.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010156 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1235 Latitude: 33.205900 Longitude: -92.614517 Photographer: Kerri McCabe Description: Looking SW, this photo showed disturbed soil at the facility. Land filling and land applying has occurred at the facility.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010157 Orientation: S-SW Date of Photo: 05/22/2024 Time of Photo: 1237 Latitude: 33.206347 Longitude: -92.614905 Photographer: Kerri McCabe Description: Looking S-SW, this photo showed disturbed soil at the facility. Location was formally a mining site and borrow pit for clay soil.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010158 Orientation: S-SW Date of Photo: 05/22/2024 Time of Photo: 1237 Latitude: 33.206350 Longitude: -92.615783 Photographer: Kerri McCabe Description: Looking S-SW, this photo showed disturbed soil at the facility. Location was formally a mining site and borrow pit for clay soil.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010177 Orientation: SE Date of Photo: 05/22/2024 Time of Photo: 1251 Latitude: 33.204483 Longitude: -92.616117 Photographer: Kerri McCabe Description: Looking SW, this photo showed the stormwater pond utilized by the facility, which is permitted under NPDES permit ARR001445. Sedimentation pond from the CGP has been converted.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 7
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010203 Orientation: W-NW Date of Photo: 05/22/2024 Time of Photo: 1303 Latitude: 33.204250 Longitude: -92.614933 Photographer: Kerri McCabe Description: Looking W-NW, this photo showed a frac tank stored between two (2) subsurface, concrete pits. This area was covered under the original CGP.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 8
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010204 Orientation: W Date of Photo: 05/22/2024 Time of Photo: 1303 Latitude: 33.204250 Longitude: -92.614933 Photographer: Kerri McCabe Description: Looking W, this photo showed the subsurface, concrete pit to the left of the frac tank in
Photo No. 7. This area was covered under the original CGP.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 9
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010205 Orientation: W-SW Date of Photo: 05/22/2024 Time of Photo: 1303 Latitude: 33.204350 Longitude: -92.615067 Photographer: Kerri McCabe Description: Looking W-SW, this photo showed the subsurface, concrete pit to the right of the frac tank
in Photo No. 7. This area was covered under the original CGP.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 10
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010198 Orientation: NE Date of Photo: 05/22/2024 Time of Photo: 1300 Latitude: 33.204021 Longitude: -92.615184 Photographer: Kerri McCabe Description: Looking NE, this photo showed a large, concrete pit used for storing liquid wastes (contents
unknown). This area was covered under the original CGP.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 11
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010206 Orientation: NW Date of Photo: 05/22/2024 Time of Photo: 1304 Latitude: 33.204400 Longitude: -92.615350 Photographer: Kerri McCabe Description: Looking NW, this photo showed a large, concrete pit used for storing liquid wastes
(contents unknown). This area was covered under the original CGP.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 12
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010209 Orientation: N-NE Date of Photo: 05/22/2024 Time of Photo: 1305 Latitude: 33.204396 Longitude: -92.615476 Photographer: Kerri McCabe Description: Looking N-NE, this photo showed another large, concrete pit used to catch leachate from
bulked material. Soil used to make an earthen berm. This area was covered under the original CGP.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 13
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010216 Orientation: W-SW Date of Photo: 05/22/2024 Time of Photo: 1307 Latitude: 33.204667 Longitude: -92.614583 Photographer: Kerri McCabe Description: Looking W-SW, this photo showed an overview of the mixing area with liquid wastes in frac
tanks (photo left), and bulked material stockpiled. This area was covered under the original CGP.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 14
Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947)
City: El Dorado
County/Parish: Union
State: Arkansas
Photo File Name: R0010217 Orientation: S Date of Photo: 05/22/2024 Time of Photo: 1320 Latitude: 33.204650 Longitude: -92.614517 Photographer: Kerri McCabe Description: Looking S, this photo showed an overview of the bulking material (sawdust) storage area and outbuilding for an office. This area was covered under the original CGP.
Appendix 2 Construction Stormwater General Permit
Inspection Check Sheet Pages 1 - 3
SECTION A: SITE POSTING AND SITE INFORMATION
Site Name: USA Disposal Total Acreage: 40 acres
Acreage Disturbed: 8 acres
Project Type: Residential Commercial Industrial Municipal Other
Construction Phase:
Clearing Rough Grading Infrastructure Building Construction Final Inactive Other Original construction of the facility is completed; current disturbance from land filling and land application of bulked wastes.
If project is part of larger common plan of development, what is development name and permit number (Part I, A.31)?
Development Name: N/A
Development Permit No:
1. Is site properly posted with Notice of Coverage (NOC)? Posting must be at the site entrance and visible to the public. NOC is complete and reflects the correct location of the SWPPP (Part II, A.2.D). For linear sites, the posting is at the area actively under construction (Part II, A.2.D).
Y N NA NE
2. Do stormwater discharges from the site enter an ERW, NSW, or ESW, or a waterbody listed on the 303(d) list or a waterbody with an approved TMDL (Part I, B.11)?
Y N NA NE
A. If yes, have additional BMPs been implemented to sufficiently protect water quality or prevent to the maximum extent possible exposure to stormwater of pollutants that could potentially impact water quality (Part I, B.11.E-F)?
Comments:
Y N NA NE
Activities at the site are not related to construction. Current disturbed areas are from land filling and land application of bulked wastes.
SECTION B: SWPPP AND INSPECTIONS
1. Is the SWPPP being maintained onsite from 08:00 am to 5:00 pm (Part II, A.2.A)?
A. If yes, is a complete and updated SWPPP and site map maintained onsite (Part II, A.3)? SWPPP was reviewed from ADEQ PDS; SWPPP from August 2009.
2. What is the inspection frequency selected in the SWPPP? Once every 7 days OR 14 days and within 24 hours of 0.25 inch rain event
3. If the inspection frequency is every 14 days or within 24 hours of a 0.25 inch rain event, is a rain gauge properly installed and checked (Part II, A.4.N.1.b)?
4. Are inspection records available for review (Part II, A.4.N.3)?
5. Is the chosen inspection frequency being followed by the permittee?
Y N NA NE Y N NA NE
Y N NA NE Y N NA NE Y N NA NE
6. What is the date of the last inspection conducted by the permittee? No inspection reports available for review.
7. Are DEQ inspection forms being used? A. If no, do the alternative inspection forms contain the required information (Part II, A.4.N.2)?
8. Do the inspections address the current site conditions (Part II, A.4.N)? 9. Do the inspections include all areas of the site and all applicable offsite areas (Part II,
A.4.N)? 10. Does the inspector note pollution entering stormwater conveyances or discharges offsite
(Part II, A.4.N)? 11. Does the inspector ensure all stormwater control measures are properly installed and
maintained (Part II, A.4.N)?
12. Are all outfalls being inspected (Part II, A.4.N)?
13. Are all construction entrances and exits inspected for offsite tracking (Part II, A.4.N)?
14. Are all corrective actions being implemented within 3 business days (Part II, A.4.O)?
Y N NA NE Y N NA NE Y N NA NE Y N NA NE Y N NA NE
Y N NA NE Y N NA NE Y N NA NE Y N NA NE
Comments: There are no records of inspections being conducted.
SECTION C: EFFLUENT LIMIT GUIDELINES AND BUFFER ZONES
1. Are all erosion and sediment controls installed and effective (Part I, B.13.A)?
2. Is offsite tracking of sediment occurring?
3. Has construction activities ceased in any areas previously disturbed (Part II, A.4.G.2)?
A. If yes, have construction activities ceased for more than 14 days?
i. If yes, have temporary or permanent stabilization measures been initiated?
4. Are any discharges from dewatering activities occurring? A. If yes, are the dewatering discharges managed by using appropriate BMPs (Part I, B.13.C)?
5. Is the permittee minimizing the discharge of pollutants from equipment and vehicle washing, wheel wash water, and other wash waters by using appropriate BMPs (Part I, B.13.D.1)?
6. Are any materials, products, or wastes associated with construction activities managed in a way that allows materials to discharge or leave the site (Part I, B.13.D.2)?
7. Are spills or leaks of potential pollutants evident (Part I, B13.D.3)? 8. Are any of the following discharges occurring (Part I, B.13.E)?
Concrete Washout Wash-out of Stucco, Paint, Oils, Curing Compounds Fuel or Oil Soaps, Solvents, or Detergents Toxic or Hazardous Substances Other
9. Are there any process waters discharges or non-stormwater discharges occurring that are not allowed under this permit (A.C.A 8-4-217(b)(1)(E) & Part I, B.10)?
10. Has sediment been discharged or placed off the construction site (A.C.A. 8-4-217(a)(2))? If sediment has been discharged to waters of the State, provide the name of the waterbody. UT of Boggy Creek, thence Boggy Creek, thence Bayou De Loutre, to Ouachita River; jurisdictional wetlands.
11. Are natural buffer zones being maintained at all times (Part I, B.14.A-B)?
12. If a linear project, do the natural buffer zone setbacks meet the requirements established by the Department (Part I, B.14.C)?
Comments:
Y N NA NE Y N NA NE Y N NA NE Y N NA NE Y N NA NE Y N NA NE Y N NA NE Y N NA NE Y N NA NE Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE Y N NA NE
Activities onsite are not from construction; activities include land filling and land application of bulked wastes.
Wetlands onsite with placed fill. Rip-rap check dams noted in the CGP/IGP SWPPP are not implemented. Stormwater pond contained unknown wastes.
SECTION D: SEDIMENT BASINS
1. Is sediment basin required?
Y N NA NE
A. If yes, is the sediment basin installed and is it installed as described in the SWPPP? Y N NA NE
2. Does the sediment basin have adequate storage capacity?
3. Are proper outlet structures (withdraw water from the surface) in place for the basin (Part I, B.13.F)?
4. Have velocity dissipation devices been installed at discharge points, within concentrated flow areas serving two or more acres, or along drainage courses where required to prevent erosive flows (Part II, A.4.I.3.b)?
Y N NA NE Y N NA NE
Y N NA NE
Comments:
Sediment pond from CGP has been converted to stormwater pond for IGP. Two discharge pipes installed at the bottom of the stormwater pond. Rip-rap check dams noted in both the CGP and IGP SWPPP are not installed in drainage areas.
OUTFALL VISUAL INSPECTION REPORT
OUTFALL LOCATION: 001
PHOTO NUMBER:
OUTFALL DESCRIPTION: Pipes from stormwater pond
1. Does the outfall match the location in the SWPPP and site map? Y N
2. Does the discharge occur from one of the following? Pond Sheet flow Ditch Other (Explain):
3. If a sediment pond or impoundment is present, is water withdrawn from the surface? Y N NA
4. What activity is near the outfall structure? Processing of bulked wastes; storage of bulk liquid wastes; storage of bulk sawdust
Comments:
VISUAL OBSERVATION 1. Was a discharge occurring at the time of the inspection? Y N NA
2. Discharge water flow color: Clear Turbid Oil Sheen Soapy/Foamy Other Black with odor
3. Are unpermitted discharges occurring or solid waste leaving the site? Y N NA
A. If yes, what pollutant is being discharged? Sediment Trash Concrete Washout Unknown liquid wastes from process areas
4. Is debris from the outfall present in the receiving stream? Y N NA NE Comments:
Other
Overflow of process areas into stormwater pond; unknown wastes.