Document 3JMRLZaaav94gdyKNn11dZJpD

EPA Region 10 Enforcement and Compliance Assurance Division Clean Water Act (CWA) Inspection Report Inspection Entry Date/Time Inspection Exit Date/Time Media Statute(s)/Program(s) Type of Inspection 01/03/2024 9:55 AM (PT) Announced: No 01/03/2024 1:45 PM (PT) Water Clean Water Act, NPDES, Stormwater - Industrial CEI - Compliance Evaluation Inspection Permittee Name Facility Name Facility Physical Address City, State, Zip Code Facility GPS Coordinates Facility Owner Facility Owner Address City, State, Zip Code Trails End Recovery Trails End Recovery 2060 SE Airport Lane Warrenton, Oregon 97146 46.143889 N -123.875278 W Custom Excavating by Dean Larson Inc. DBA: Trails End Recovery 2060 SE Airport Lane Warrenton, Oregon 97146 FRS ID Permit # / ODEQ File # SIC Code 110069599330 ORR127194 / 112084 5093 - Scrap and Waste Materials (Primary), 5261 - Retail Nurseries, Lawn and Garden Supply (Secondary) Inspection Contacts: Organization EPA Region 10 EPA Region 10 Trails End Recovery Trails End Recovery EPA Inspector Signature/Date Supervisor Signature/Date Name Jon Klemesrud CJ Langlois Alex Raichl Rachel Marriott Title Lead Inspector Present in Opening Conf. Yes Inspector Yes General Manager Yes Office Manager Yes Present in Closing Conf. Yes Yes Yes Yes JON KLEMESRUD Jon Klemesrud PETER CONTRERAS Peter Contreras, Chief FDDWES Digitally signed by JON KLEMESRUD Date: 2024.03.08 14:22:49 -08'00' Digitally signed by PETER CONTRERAS Date: 2024.03.08 15:39:23 -08'00' 2024 CWA NPDES ORR127194 Inspection Report This inspection report is based on information supplied by conversations with Mr. Alex Raichl and Ms. Rachel Marriott or direct observations made at the time of the inspection, and records and reports maintained by the permittee. This inspection report may also include information gathered from a review of EPA, ODEQ, and/or public records. SECTION I - INTRODUCTION Entry and Inspection Chronology This was an unannounced inspection. I was joined on the inspection by fellow EPA Region 10 Inspector, CJ Langlois. Oregon Department of Environmental Quality (ODEQ) was invited to accompany us on the inspection but was not in attendance. On January 3, 2024, CJ Langlois (EPA) and I arrived on-site at approximately 9:50 AM. After parking in the designated visitor parking area outside of the main office, CJ Langlois and I approached the main service window located along the facility's entry/exit scale. We were then greeted at the sliding window by Office Manager, Ms. Rachel Marriott. I introduced myself and explained that I had been asked to conduct a routine on-site inspection at Trails End Recovery. The inspection purpose was to assess compliance with the facility's coverage under ODEQ's Industrial Stormwater Discharge Permit (1200-Z), in coordination with ODEQ. Ms. Marriot agreed to the inspection and invited us inside the main office area. She subsequently informed Mr. Alex Raichl, General Manager of Trails End Recovery of the inspection via phone. As Mr. Raichl was on-site, he made his way into the main office area to join us. Following our initial introductions with Mr. Raichl, CJ and I presented our EPA inspector credentials and I discussed the purpose/expectations of the inspection. I also provided my business card and a copy of EPA's Small Business Resources Information Sheet, which was briefly discussed. Mr. Raichl informed us that about 1-2 weeks prior, he had received an evening phone call from a woman within EPA's Emergency Operations Center, inquiring about a possible fire that was reported at the Facility. Mr. Raichl discussed that there hadn't been a fire and initially questioned if that was the nature of our visit. I explained that I wasn't aware of the call/incident and that my inspection was pursuant to the stormwater discharge under ODEQ's stormwater permit (1200-Z). The inspection continued as Mr. Raichl then offered to lead us on a walk-through of the facility while Ms. Marriott would prepare some of permit required/related documentation to be reviewed after the walk-though. The inspection consisted of an opening conference, a walk-through of stormwater areas and related infrastructure, a records review, and a closing conference. During the closing conference, we discussed the walk-through observations, potential areas of concern and next steps. Portions of the records review occurred both pre- and postinspection as discussed in Section III of this inspection report. We were accompanied throughout the inspection by Mr. Raichl. Ms. Marriott was present for the opening conference, on-site records review and closing conference. Permit/Compliance History Trails End Recovery (hereinafter referred to as the "Facility") is permitted under ODEQ's Industrial Stormwater Discharge Permit (1200-Z) for their discharges into an unnamed slough and roadside ditch. The roadside ditch eventually connects to the unnamed slough after it travels approximately 1580 feet. The unnamed slough then discharges to the Lewis and Clark River, which then flows then into Younds Bay and the Columbia River Estuary. The Facility was first permitted under the 1200-Z on January 28, 2003. The current permit tracking number assigned to the Facility is ORR127194 (ODEQ File # 112084). The Facility is also subject to the sector specific requirements identified in Schedule E of the 1200-Z Permit (Sector N - Scrap and Waste Materials). Monitoring requirements for Sector N, include benchmark sampling for Chemical Oxygen Demand (COD) and Total Aluminum. As the Facility discharges to the Columbia River watershed, statewide benchmark sampling is required for Total Copper, Total Lead, Total Zinc, pH, and Total Suspended Solids (TSS). See Attachment A, ODEQ Issued Monitoring Requirements Letter. The current monitoring requirements were effective with the reissuance of the 1200-Z (July 1, 2021). Page 2 of 103 2024 CWA NPDES ORR127194 Inspection Report The Facility was last inspected by ODEQ on July 10, 2019, ODEQ conducted a subsequent sampling event on March 13, 2020. Based upon the findings of the ODEQ inspection and sampling event, the Facility was issued an Administrative Final Order by ODEQ on March 30, 2020 (OR-WQ/SW-NWR-2019-24). The Facility most recently triggered Tier I corrective action requirements in December 2023, as sample results from their Pond 2 discharge exceeded sector-specific benchmark limits for Aluminum. Additionally in 2023, the Facility also triggered Tier 1 corrective action requirements in November 2023 (Pond 2 & Pond 3 discharges), May 2023 (Pond 2 discharges), March 2023 (Pond 2 discharges) and January 2023 (Pond 2 discharges). The 2023 Tier 1 corrective actions were primarily triggered for exceedances of the sector-specific benchmark requirements for Aluminum and COD. SECTION II - SITE REVIEW / OBSERVATIONS Site Review Trails End Recovery is a materials recovery and recycling facility located just outside of Warrenton, Oregon, retail landscape materials are also sold on-site. Activities at the Facility generally include the receiving, sorting, and processing of wood products, yard debris, concrete and asphalt, brush/land clearing debris, dirt/rock/sod, scrap metal, mixed construction debris, wood ash and log yard material. Once sorted and processed, recovered/recycled products are stored, trucked off-site or sold to drive-up customers. Each load of incoming material is inspected, the Facility does not receive asbestos containing materials, liquids (i.e., paint, motor oil, cooking oil, gasoline), chemicals, medical waste, hazardous waste, fuel tanks, bulk tires, contaminated soil, tar roofing, light bulbs, car batteries. For construction debris, the facility requires a completed asbestos survey at the time of arrival (prior to entering). On-site activities are conducted during all months of the year. The Facility is open to the public from 8:00AM to 4:30PM Monday through Friday, and Saturdays 9:00AM to 3:30PM (April - September). The Facility's footprint is approximately 8.7 acres with approximately 32% of those acres having impermeable surface, which include the sorting area, product bins, woody debris area and the two buildings (office and maintenance shop). The remaining pervious areas generally consist of compacted gravel and stockpiles. Regarding stormwater management, the Facility has segmented the site into five separate sub-basins and four stormwater settling ponds. Except for a single catch basin within the employee parking area, there is no collection system beyond the four stormwater settling ponds and a few designed/constructed earthen channels near the topsoil and inert stockpiles. Stormwater that isn't infiltrated generally travels as sheet flow towards the settling ponds. Industrial activities generally occur throughout the site, as materials are stored/managed, processed, and transported in all site locations. See Attachment B, Site Layout. We began the inspection walk-through just outside of the main office, near the scale entrance within Sub-basin 1. For the walk through, we generally observed each drainage area/sub-basin, locations of industrial activities and the associated stormwater discharge location. Photographs taken during the site-walk through are attached to this inspection report as Attachment C, Photograph Log. Walk-Through Observations: Location: Sub-Basin 1 Observation #: OB-01 We first observed the main scale area within Sub-Basin 1 (SB-1) (Photo 1), Mr. Raichl discussed that each incoming/delivery load is required to stop at the scale and the driver is required to provide certified "paperwork" (a completed asbestos survey) for construction debris/demolition loads. It was discussed that the Facility primarily receives materials for recyling from a local waste management company, Recology (approximately 3- Page 3 of 103 2024 CWA NPDES ORR127194 Inspection Report 12 trucks/bins each day), as well as materials from local contractors and the general public. At the time of inspection, stormwater near the scale generally appeared to infiltrate within the permeable areas around the scale and office area. No staining/sheens were observed. North of the scale area within SB-1, we observed the Facility's maintenance shop. Mr. Raichl discussed that the maintenance shop is shared with a separate entity but same ownership, Custom Excavating by Dean Larson, Inc., located north of the of Facility. We observed a "chipper" that was parked on the concrete pad to the west of the maintenance shop (Photo 2). According to Mr. Raichl, the "chipper" was being temporarily staged awaiting a new/replacement engine. No staining/sheens were observed around the staged equipment. Stormwater was generally observed to infiltrating within the permeable areas south of the concrete pad, a few small areas of ponding were also observed. We continued the walk-through east, along the northwest perimeter towards the "chipping area" (Photo 3). According to Mr. Raichl, mechanical wood chipping occurs within this area and as well as stockpiling sorted wood debris that will be used for chipping. Wood chips are then temporarily stored before they are loaded and hauled to a paper mill in Wauna, Washington. On the western edge of the chipping area, the Facility utilizes a shipping container to store additional spill kits, absorbents, and other spill response items/tools (Photo 4). We continued east through the "chipping area" and observed the concrete pad (Photo 5) and permeable areas south of the pad, including portions of the hogfuel processing/stockpile area (Photo 6 & Photo 7). The Facility can process approximately 500 yards/day of hogfuel which also gets hauled to the paper mill in Wauna, Washington. Bark is received from a nearby lumber mill and is screened/processed as economy park and then wholesaled. Mr. Raichl discussed that when received, creosote/treated lumber is now kept in bins temporarily and returned to Recology during the next delivery (likely the same day). We also observed the northern perimeter (Photo 8), which includes an access road separating the industrial areas from an unnamed slough (permitted receiving water to the north). East of the concrete/impervious pad, we observed Pond 1 (Photo 9 - Photo 11). Pond 1 was observed to be constructed with rows of rock/gravel extending across the pond, separating the pond into five separate chambers. Oil absorbant "snakes" were extended across the pond to remove floatable oil/grease, a "bio-bag" and mesh guard was placed around the pond's discharge pipe. I also observed oil absorbant pads placed within the cells. At the time of inspection, Pond 1 was receiving stormwater as sheet flow from the areas north of the hogfuel processing/stockpile area, influent stormwater was observed to be turbid as it entered the pond. A "bio-bag" had been placed in the influent channel (southwest corner). Mr. Raichl discussed that Pond 1's receiving water to the north (unnamed slough) is tidally influenced and when "King Tides" are observed, the unnamed slough will occasionally overflow over the northern perimeter access road and flood Pond 1. Mr. Raichl explained that he believed this was due to a known Tide Gate issue, where the unnamed slough discharges to the Lewis and Clark River. According to Mr. Raichl, this overflow had most recently occurred 1-2 weeks prior, around the Christmas holiday. Mr. Raichl believed the Facility had most recently performed maintenance on Pond 1 the week prior. Maintenance was believed to include replacing the absorbant materials and fixing the bio-bag associated with the discharge pipe. Mr. Raichl discussed that the recent maintenance would've been documented in the most recent facility inspection report, which would be available within the Facility office. We then crossed the access road to the north and observed the Pond 1 discharge/monitoring location (DP001). DP001 appeared to be discharging slightly, the discharge was observed to be clear with no sheen (Photo 12 & Photo 13). We continued the walk-through east along the access road and observed the northern portion of topsoil and inert storage areas. The Facility maintains a vegetated (grass) channel along the north end of the piles as a best management practice (BMP), a channel separates the two stockpiles (Photo 14 - Photo 16). Stormwater not infiltrating within these areas was directed towards the southeast corner of Pond 1. Page 4 of 103 Location: Sub-Basin 4 Observation #: OB-02 2024 CWA NPDES ORR127194 Inspection Report We continued the walk-through to the eastern portion of the Facility, into Sub-Basin 4 (SB-4). SB-4 generally includes the eastern portion of the of the inerts pile, crushed concrete storage areas, Pond 4, and a wetland area south of the industrial areas. We first observed the unnamed slough from this location (Photo 17), as well the eastern portion of the inerts pile and the access road that separates the inerts pile from Pond 4 (Photo 18). The Facility has constructed a vegetated/bioswale area south of Pond 4 (Photo 19). Water within the vegetated/bioswale area is designed to either infiltrate or enter Pond 4. I observed "bio-bags" staked within the vegetated bioswale area and around Pond 4. An earthen berm separates Pond 4 into two separate chambers. I observed oil-absorbant "snakes" placed across both chambers and oil absorbant pads placed within Pond 4 (Photo 20). We then crossed the access road to the north and observed the Pond 4 discharge/monitoring location (DP004). DP004 was discharging slightly, the discharge was observed to be clear with no sheen, foam was present at the immediate discharge point (Photo 21 & Photo 22). We continued the walk-through south, towards the wetland area located in the southeast corner of the property (Photo 23). Mr. Raichl discussed that a wetland delineation/survey had been conducted for the area. At this location industrial areas were separated from the wetland by perimeter blocks. Standing water and flagging was observed within portions the wetland area. Within SB-4, the area was generally sloped towards the industrial areas and away from the wetland areas. Location: Sub-Basin 2 Observation #: OB-03 We continued the walk-through southwest, into Sub-Basin 2 (SB-2). SB-2 generally includes Pond 2 and the southeast industrial areas of the Facility, primarily material stockpiles and a designated screening area. We first observed a rock/gravel stockpile area within the eastern portion of SB-2 (Photo 24) as well as another stockpile area east of Pond 2 (Photo 25 & Photo 26). We continued west and observed the southern perimeter (Photo 27) and processing screening area west of Pond 2. Staining/sheens were observed on the surface near a front loader that was parked at the location (Photo 28 & Photo 29). We continued to Pond 2, located along the east side of a Facility access road to Highway 101 Alternate (Photo 30). Pond 2 generally serves the areas north and northeast of Pond 2 (Photo 31 & 32). Ecology blocks were placed around the perimeter of the pond, I observed oil absorbant "snakes" placed across the pond with "biobags" placed in the north and northwest perimeter, oil absorbant pads were also placed within the pond (Photo 33). Pond 2 baffles were observed to need maintenance. When viewing the Pond 2 discharge into the roadside ditch (DP002), the discharge appeared to be turbid (Photo 34). I observed stormwater entering Pond 2 from a southeast area, near the pond's outfall structure. I discussed that stormwater entering the pond near the outfall structure could potentially impact the turbidity seen at the DP002, as the pond could be "short-circuiting" where the settling in the pond is limited and BMP's within the pond aren't fully utilized. Mr. Raichl discussed that the Facility had also purchased and installed "bio-char filter socks" at the Pond 2 outfall structure, oyster shells were also being utilized within the Pond and were stockpiled south of the pond (Photo 35 & Photo 36). From this area we also observed the Pond 2 receiving water, the roadside ditch along Highway 101 Alternate (Photo 37 & Photo 38). We continued west and observed areas north/west of Pond 2 (Photo 39), including designated product/landscape material storage areas, where products (i.e., topsoil) are available for commercial/public sale. Many products/materials were tarped at the time of inspection (Photo 40). Location: Sub-Basin 3 Observation #: OB-04 We continued the walk-through west into Sub-Basin 3 (SB-3), primary industrial activities occurring within SB-3 Page 5 of 103 2024 CWA NPDES ORR127194 Inspection Report include the mixed construction debris receiving and sorting area. A portion of SB-3 is impervious, as sorting and separating occurs on a large concrete pad. Stormwater within SB-3 is either infiltrated or designed to enter Pond 3 as sheet flow. Pond 3 is located on the Facility's southern perimeter and discharges to the roadside ditch along Highway 101 Alternate. Within SB-3, we first observed the Facility's air separator, an EDGE MC1400 Material Classifier (Photo 41) used to remove/classify material such as rock. According to Mr. Raichl, the Facility had previously used a "water separator" made by Flocait which was taken off-line and removed approximately 3 years ago. While viewing the air separator location, I observed staining/sheens on the surface downslope of the device (Photo 42 & Photo 43). According to Mr. Raichl, sheens observed are likely the result routine maintenance performed on the machine, as equipment such as the air separator have set maintenance schedules and receive grease applications at various points every 8-hours of run time. At the time of inspection, stormwater flowing from this area was observed to be traveling downslope towards Pond 3. We also observed stormwater from the receiving/sorting area traveling south towards Pond 3 (Photo 44). We then observed Pond 3 (Photo 45), which was receiving stormwater at the northwest corner of the pond (Photo 46), primarily from the receiving/sorting area. Pond 3 was constructed with 2 cells/chambers separated by an earthen berm with a PVC pipe allowing flow between. I observed oil absorbent "snakes" placed across the pond as well as oil absorbent pads placed within the cells (Photo 47). We observed the Pond 3 discharge (DP003) into the roadside ditch along Highway 101 Alternate as well as the upstream and downstream portions of the roadside ditch (Photo 48 & Photo 49). The discharge pipe was partially submerged within the roadside ditch, turbid water was observed within the ditch (upstream/downstream) as well as at discharge point. No sheen was observed. We further observed Pond 3's influent flow from the receiving/sorting area and air separator area (Photo 50). We continued north to the receiving/sorting area (Photo 51), at the time of inspection the Facility was receiving/sorting a bin of mixed construction debris/material from Recology at the time of inspection. We also observed temporary storage bins staged within the area, stormwater from this area was observed to be ponded or traveling downslope towards Pond 3 as sheet flow. Location: Material Storage Area (Maintenance Shop) Observation #: OB-05 Our walk-though continued north as we returned to maintenance shop; we followed Mr. Raichl inside the maintenance shop to observe the lubricant/material storage areas for various products that are used/stored on-site. Within one of the garage bay's (north bay) we observed bulk storage totes of motor oil, power steering fluid, hydraulic fluid, antifreeze and gear oil (Photo 52 - Photo 56). Storage totes were placed above secondary containment pallets within the enclosed/indoor maintenance shop. Mr. Raichl then led us to another garage bay within the maintenance shop where he displayed the various greasing agents used on the outdoor machinery. Greasing agents included "Chevron Delo," "Chevron Starplex" and "Bio-High Temp 180" (Photo 57- Photo 59). Mr. Raichl discussed that the Bio-High Temp 180 product was believed to be biodegradable product and had been recently incorporated into Facility maintenance operations. Location: Pond 3 Discharge Observation #: OB-06 Prior to departing the Facility, as part of the closing conference (following the Facility walk-through and records review) I requested that we return to the Pond 3 discharge location (DP003) to potentially collect effluent samples as part of the EPA inspection. Mr. Raichl agreed to the sampling request, and we returned to the Pond 3 discharge location following the closing conference (Photo 60). No samples were ultimately collected as the Pond 3 discharge pipe was observed to be partially submerged within the roadside ditch and upstream flow from the roadside ditch was observed to be partially entering into the discharge pipe, preventing the collection of a sample Page 6 of 103 2024 CWA NPDES ORR127194 Inspection Report representative of only the Pond 3 discharge. We discussed with Mr. Raichl and then departed the Facility. SECTION III - RECORDS REVIEW Record: Storm Water Pollution Control Plan (SWPCP) Ref #: RR-001 A copy of the Facility's SWPCP was on-site and available for review at the time of inspection. An electronic version of the SWPCP was also provided pre-inspection by ODEQ (Attachment D). The SWPCP was dated July 27, 2022, and was most recently submitted to ODEQ in April of 2023. The SWPCP was prepared by Robert S. Bogar, M.S. (consultant). The SWPCP included the applicable elements required/discussed within Schedule A. Part 10 of the permit. The SWPCP also included an attached Site Layout Map, Pond BMP Diagram(s), and a Spill Prevention and Response Plan. Record: Site Inspection Reports Ref #: RR-002 Monthly site inspections for permit compliance are conduced primarily by Ms. Marriot. Inspections are documented using a checklist created by the Facility, which include specific sections for each of the Facility's sediment ponds (including discharges), as well as for industrial areas within the "yard" area. It was discussed by Ms. Marriott that in addition to the monthly site inspection, the checklist is used throughout the calendar month to also indicate the date of the visual observation, monthly rain total, and BMP/maintenance performed. Inspection reports were on-site and available for review at the time of inspection. I reviewed monthly site inspection reports for 2023, 2022, and 2021. In addition, Ms. Marriott provided me with printed copies of 2023 the inspection reports. The permit requires that all records (including inspection reports) be retained by the permittee for a least three years. The most recent monthly site inspection was documented the week prior to the inspection, on 12/27/2023 (Attachment E). Previous inspections were also documented on 11/30/2023, 10/26/2023, 9/26/2023, 8/23/2023,7/17/2023, 6/06/2023, 5/30, 2023, 4/20/2023, 3/28/2023, 2/20/2023, 1/31/2023, 12/26/2022, 11/30/2022, 10/21/2022, 9/28/2022, 8/31/2022, 7/29/2022, 6/29/2022, 5/31/2022, 4/20/2022, 3/30/2022, 2/16/2022, 1/31/2022, 12/30/2021, 11/25/2021, 10/30/2021, 9/20/2021, 8/19/2021, 7/23/2021, 6/24/2021, 5/27/2021, 4/27/2021, 3/29/2021, 2/22/2021, 1/31/2021. Site inspection reports were complete, corrective action items were documented and marked complete once addressed. BMP and pond maintenance activities performed by the Facility were documented throughout the month on the second page of the corresponding inspection report/checklist. The month's visual observation date was also listed on the site inspection report. For 2023, Visual observations were made on 12/4/2023, 11/13/2023, 10/17/2023, 9/19/2023, 8/29/2023, 7/24/2023, 6/19/2023, 5/5/2023, 4/21/2023, 3/10/2023, 2/6/2023, 1/16/2023. BMP maintenance was last documented as occuring the week prior to the inspection, on 12/28/2023. Maintenance included adding more oyster shells to Pond 2 and Pond 3, replacing, and adding a "bio-char" bag to Pond 2, changing "soakers" within Pond 1, fixing a Pond 1 bio-bag, cleaning the Pond 1 mesh guard (outlet pipe) and removing hogfuel from within Pond 1. Additional BMP/maintenance activities that were documented in December 2023, included changing "soakers" within Pond 1, Pond 2, and Pond 3 on 12/4/2023, the removal of "two scrap metal loads" on 12/7/2023, yard clean-up including stabilizing stockpiles on 12/8/2023, changing "soakers" in all ponds on 12/12/2023, changing "snakes" in Pond 1 on 12/21/2023, and the pick-up of blown garbage from a windstorm on 12/26/2023. The December 2023 site inspection report also indicated 14-iches of rain for the month. Record: Discharge Monitoring Data & Tier I Reports Ref #: RR-003 Page 7 of 103 2024 CWA NPDES ORR127194 Inspection Report Stormwater monitoring/analytical data was reviewed as part of this inspection. As discussed earlier in this report, the Facility is subject to the sector specific requirements identified in Schedule E of the 1200-Z Permit (Sector N - Scrap and Waste Materials). Monitoring requirements for Sector N, include benchmark sampling for Chemical Oxygen Demand (COD) and Total Aluminum. As the Facility discharges to the Columbia River watershed, statewide benchmark sampling is required for Total Copper, Total Lead, Total Zinc, pH, and Total Suspended Solids (TSS). See Attachment A, ODEQ Issued Monitoring Requirements Letter. Prior to current permit term, the Facility also had monitoring requirements for other parameters, including Total Iron. The Facility collects effluent samples from each of their four stormwater ponds. Samples are primarily collected by Mr. Raichl. pH analysis occurs in-house by Ms. Marriott, using a Yinmik pH testing probe. pH results are documented within a "pH Field Notes" document maintained by the Facility. When reviewing the pH Field Notes documentation, I observed that the Facility wasn't recording the time of the pH sample analysis, I discussed that it should be recorded to ensure that the 15-minute hold time is being met. It was discussed that the pH testing probe is regularly calibrated using a 3-point calibration. pH meter calibrations are recorded within a calibration log maintained by the Facility. For all other parameters, the Facility utilizes contract laboratory ALS Environmental, located in Kelso, Washington. Once analyzed, sample results are sent electronically to the Facility and complied by Ms. Marriott for submittal to ODEQ in the form of Discharge Monitoring Reports (DMR). If a benchmark value is exceeded, Ms. Marriott completes a Tier I Report utilizing the ODEQ template. Completed Tier I Reports were also requested/reviewed as part of this inspection, including for 2023, 2022, and 2021 (Attachment F). It was discussed that the most recent sampling event had occurred on December 4, 2023. The following benchmark exceedances were noted in 2023, 2022, 2021 while reviewing Discharge Monitoring Data and completed Tier I Reports: Sample Date: Outfall Location: Parameter: Reported Value: Benchmark Value: 12/4/2023 Pond 2 Total Aluminum 1.30 mg/L 1.10 mg/L 11/13/2023 Pond 2 Total Aluminum 2.61mg/L 1.10 mg/L 11/13/2023 Pond 3 Total Aluminum 1.26 mg/L 1.10 mg/L 11/13/2023 Pond 3 Chemical Oxygen Demand 120 mg/L 120 mg/L 4/21/2023 Pond 2 Total Aluminum 3.61 mg/L 1.10 mg/L 4/21/2023 Pond 2 Chemical Oxygen Demand 198 mg/L 120 mg/L 4/21/2023 Pond 4 Chemical Oxygen Demand 149 mg/L 120 mg/L 4/21/2023 Pond 4 Total Aluminum 1.87 mg/L 1.10 mg/L 3/10/2023 Pond 2 Total Aluminum 7.41 mg/L 1.10 mg/L 3/10/2023 Pond 2 Total Suspended Solids 170 mg/L 100 mg/L 3/10/2023 Pond 2 Chemical Oxygen Demand 241 mg/L 120 mg/L 3/10/2023 Pond 3 Total Aluminum 9.97 mg/L Page 8 of 103 1.10 mg/L Sample Date: Outfall Location: Parameter: 2024 CWA NPDES ORR127194 Inspection Report Reported Value: Benchmark Value: 3/10/2023 Pond 3 Total Copper 0.040 mg/L 0.023 mg/L 3/10/2023 Pond 3 Total Suspended Solids 272 mg/L 120 mg/L 3/10/2023 Pond 4 Chemical Oxygen Demand 159 mg/L 120 mg/L 3/10/2023 Pond 4 Total Aluminum 4.34 mg/L 1.10mg/L 12/29/2022 Pond 2 Total Aluminum 1.83 mg/L 1.10 mg/L 12/05/2022 Pond 2 Total Aluminum 6.62 mg/L 1.10 mg/L 12/05/2022 Pond 2 Chemical Oxygen Demand 149 mg/L 120 mg/L 12/05/2022 Pond 4 Chemical Oxygen Demand 228 mg/L 120 mg/L 4/12/2022 Pond 1 Total Aluminum 1.17 mg/L 1.10 mg/L 4/12/2022 Pond 2 Total Aluminum 2.70 mg/L 1.10 mg/L 4/12/2022 Pond 3 Total Aluminum 2.97 mg/L 1.10 mg/L 4/12/2022 Pond 4 Total Aluminum 1.18 mg/L 1.10 mg/L 4/12/2022 Pond 4 Chemical Oxygen Demand 232 mg/L 120 mg/L 2/14/2022 Pond 2 Total Aluminum 5.86 mg/L 1.10 mg/L 2/14/2022 Pond 3 Chemical Oxygen Demand 202 mg/L 120 mg/L 2/14/2022 Pond 3 Total Aluminum 11.00 mg/L 1.10 mg/L 2/14/2022 Pond 3 Total Suspended Solids 358 mg/L 100 mg/L 2/14/2022 Pond 3 Total Copper 0.031 mg/L 0.023 mg/L 12/13/2021 Pond 2 Total Aluminum 4.59 mg/L 1.10 mg/L 12/13/2021 Pond 2 Chemical Oxygen Demand 283 mg/L 120 mg/L 11/10/2021 Pond 2 Total Suspended Solids 164 mg/L 100 mg/L 11/10/2021 Pond 2 Total Copper 0.039 mg/L 0.023 mg/L 11/10/2021 Pond 2 Total Aluminum 10.80 mg/L Page 9 of 103 1.10 mg/L Sample Date: Outfall Location: Parameter: 2024 CWA NPDES ORR127194 Inspection Report Reported Value: Benchmark Value: 11/10/2021 Pond 2 Chemical Oxygen Demand 209 mg/L 120 mg/L 11/10/2021 Pond 3 Total Aluminum 8.98 mg/L 1.10 mg/L 11/10/2021 Pond 3 Chemical Oxygen Demand 155 mg/L 120 mg/L 11/10/2021 Pond 3 Total Suspended Solids 290 mg/L 100 mg/L 11/10/2021 Pond 3 Total Copper 0.027 mg/L 0.023 mg/L 11/10/2021 Pond 4 Chemical Oxygen Demand 514 mg/L 120 mg/L 11/10/2021 Pond 4 Total Suspended Solids 142 mg/L 100 mg/L 05/28/2021 Pond 1 Chemical Oxygen Demand 174 mg/L 120 mg/L 05/28/2021 Pond 1 Total Iron 4.19 mg/L 1.0 mg/L 05/28/2021 Pond 2 Chemical Oxygen Demand 180 mg/L 120 mg/L 05/28/2021 Pond 2 Total Iron 4.13 mg/L 1.0 mg/L 05/28/2021 Pond 3 Chemical Oxygen Demand 173 mg/L 120 mg/L 05/28/2021 Pond 3 Total Iron 4.13 mg/L 1.0 mg/L 05/28/2021 Pond 4 Chemical Oxygen Demand 174 mg/L 120 mg/L 05/28/2021 Pond 4 Total Iron 4.07 mg/L 1.0 mg/L 04/26/2021 Pond 1 Total Iron 5.90 mg/L 1.0 mg/L 04/26/2021 Pond 2 Total Iron 2.0 mg/L 1.0 mg/L 04/26/2021 Pond 3 Total Iron 8.52 mg/L 1.0 mg/L 04/26/2021 Pond 3 Chemical Oxygen Demand 130 mg/L 120 mg/L 04/26/2021 Pond 4 Total Iron 2.0 mg/L 1.0 mg/L Record: Facility Logs Ref #: RR-004 Page 10 of 103 2024 CWA NPDES ORR127194 Inspection Report At the time of inspection, I also reviewed additional logs kept by the Facility, including a Yard Watering Log, Shop Spill Log, and a Truck Wash Log and an Employee Training Log. The Watering Log is used to document a water truck usage on-site, to minimize the generation of dust during the summer months. A Shop Spill Log is kept to document spills and associated clean-ups, it was discussed that spill kits are kept in every machine/truck. The Truck Wash Log is kept documenting on-site truck washing, no more than eight trucks are washed per week and no detergents/hot water is used. It was discussed that the Facility routinely uses Blue Beacon Truck Wash, off Interstate-5 for to wash some of their vehicles while dispatched. The Facility maintains an employee training log, employees are trained on stormwater topics and the SWPCP. Stormwater training is a component of quarterly meetings as well as weekly meetings. SECTION V - AREAS OF CONCERN Areas of Concern may not be in sequential order. The presentation of Areas of Concern (AOC) does not constitute a formal compliance determination or violation. AOC #1: Pond 3 Regulation and/or Permit Requirement: Schedule A.1.a. within the permit states: "Minimize exposure of manufacturing, processing, material storage areas, loading and unloading, disposal, cleaning, maintenance and fixed fueling areas to rain and snow, snowmelt and runoff. To the extent technologically available, and economically practicable and achievable in light of best industry practice, the permit registrant must do the following: i. Locate materials and activities indoors or protect them with storm resistant covers if stormwater from affected areas may discharge to surface waters. Acceptable covers include permanent structures such as roofs or buildings or properly secured temporary covers such as tarps; ii. Use grading, berming or curbing to divert stormwater away from these areas and prevent stormwater contamination." Schedule A.1.i within the permit states: "Clean, maintain, and repair all control measures, including stormwater structures and temporary measures, catch basins, and treatment facilities to ensure effective operation as designed and in a manner that prevents the discharge of pollution." Observations: As discussed earlier in this report, during the walk-through within Sub-Basin 3, turbid stormwater from the receiving/sorting area was observed to be ponded or traveling downslope into Pond 3 as sheet flow (Photo 44, Photo 51). Turbid stormwater and sheens were also observed near the separating area (air separator) and was observed to flowing towards Pond 3. Stormwater entering/exiting Pond 3 was observed to be turbid. Absorbent "snakes" and absorbent pads contained within the pond appeared in need of maintenance. According to the SWPCP, wood staked bio-bags are to be installed along the north end of Pond 3, no bio-bags were observed at Pond 3 at the time of inspection. According to the December 2023 Site Inspection Report, "soakers" were last replaced in Pond 3 on 12/12/2023, additional oyster shells were added to Pond 3 on 12/28/2023. As discussed earlier in this report, according to Facility monitoring data, discharges from Pond 3 have exceeded the benchmark values for Total Aluminum, Total Copper, Total Suspended Solids and Chemical Oxygen Demand. The concern is the observed turbid influent/effluent of Pond 3 and potential lack of stormwater controls to prevent/divert stormwater away from the receiving/sorting/separating areas to prevent stormwater contamination. Based upon the observed turbidity and Pond 3 benchmark exceedances, current BMPs, corrective actions and/or the maintenance schedule utilized by the Facility may not be sufficient. Page 11 of 103 AOC #2: Pond 1 2024 CWA NPDES ORR127194 Inspection Report Regulation and/or Permit Requirement: Schedule A.1.a. within the permit states: "Minimize exposure of manufacturing, processing, material storage areas, loading and unloading, disposal, cleaning, maintenance and fixed fueling areas to rain and snow, snowmelt and runoff. To the extent technologically available, and economically practicable and achievable in light of best industry practice, the permit registrant must do the following: i. Locate materials and activities indoors or protect them with storm resistant covers if stormwater from affected areas may discharge to surface waters. Acceptable covers include permanent structures such as roofs or buildings or properly secured temporary covers such as tarps; ii. Use grading, berming or curbing to divert stormwater away from these areas and prevent stormwater contamination." Schedule A.1.i within the permit states: "Clean, maintain, and repair all control measures, including stormwater structures and temporary measures, catch basins, and treatment facilities to ensure effective operation as designed and in a manner that prevents the discharge of pollution." Observation: As discussed earlier in this report, during the walk-through within Sub-Basin 1, turbid stormwater from the hogfuel area was observed to be ponded or traveling downslope into Pond 1 as sheet flow (Photo 9). Water within the Pond appeared turbid, absorbent "snakes" and absorbent pads contained within the pond appeared in need of replacement (Photo 11). A rock baffle within Pond 1 appeared to need maintenance (Photo 10). According to the December 2023 Site Inspection Report, on 12/28/2023, Pond 1 "soakers" were replaced, the mesh guard was cleaned, hogfuel was removed and the bio-bag was repaired. The concern is the condition of the Pond 1 BMPs after receiving maintenance the week prior. In addition, the potential lack of stormwater controls to prevent/divert stormwater away from the hogfuel areas to prevent stormwater contamination. Current BMPs and/or the maintenance schedule utilized by the Facility may not be sufficient to prevent the discharge of pollution. AOC #3: Pond 2 Regulation and/or Permit Requirement: Schedule A.1.a. within the permit states: "Minimize exposure of manufacturing, processing, material storage areas, loading and unloading, disposal, cleaning, maintenance and fixed fueling areas to rain and snow, snowmelt and runoff. To the extent technologically available, and economically practicable and achievable in light of best industry practice, the permit registrant must do the following: i. Locate materials and activities indoors or protect them with storm resistant covers if stormwater from affected areas may discharge to surface waters. Acceptable covers include permanent structures such as roofs or buildings or properly secured temporary covers such as tarps; ii. Use grading, berming or curbing to divert stormwater away from these areas and prevent stormwater contamination." Schedule A.1.i within the permit states: "Clean, maintain, and repair all control measures, including stormwater structures and temporary measures, catch basins, and treatment facilities to ensure effective operation as designed and in a manner that prevents the discharge of pollution." Observation: As discussed earlier in this report, during the walk-through within Sub-Basin 2, the Pond 2 baffles, absorbent "snakes" and absorbent pads contained within the pond appeared in need of maintenance. Stormwater was observed to be entering Pond 2 from a southeast area, near the pond's outfall structure, potentially "short- circuiting" the pond's settling ability. Stormwater exiting Pond 2 was observed to be turbid. According to the SWPCP, wood staked bio-bags are to be installed along the north Page 12 of 103 end of Pond 2, no bio-bags were observed at 2024 CWA NPDES ORR127194 Inspection Report Pond 2 at the time of inspection. According to the December 2023 Site Inspection Report, "soakers" were last replaced in Pond 2 on 12/12/2023. On 12/28/23, additional oyster shells were added, the "bio-char" bag was replaced and an additional "bio-char" bag was added. As discussed earlier in this report, according to Facility monitoring data, discharges from Pond 2 have exceeded the benchmark values for Total Aluminum, Total Copper, Total Suspended Solids and Chemical Oxygen Demand. The concern is the observed turbid effluent of Pond 2 and the potential lack of stormwater controls to prevent/divert stormwater away from the screening area to prevent stormwater contamination. Based upon the observed turbidity and Pond 2 benchmark exceedances, current BMPs, corrective actions and/or the maintenance schedule utilized by the Facility may not be sufficient to prevent the discharge of pollution. AOC #4: Staining/Sheens Observed Regulation and/or Permit Requirement: Schedule A.1.a. within the permit states: "Minimize exposure of manufacturing, processing, material storage areas, loading and unloading, disposal, cleaning, maintenance and fixed fueling areas to rain and snow, snowmelt and runoff. To the extent technologically available, and economically practicable and achievable in light of best industry practice, the permit registrant must do the following: i. Locate materials and activities indoors or protect them with storm resistant covers if stormwater from affected areas may discharge to surface waters. Acceptable covers include permanent structures such as roofs or buildings or properly secured temporary covers such as tarps; ii. Use grading, berming or curbing to divert stormwater away from these areas and prevent stormwater contamination; iii. Locate materials, equipment and activities in containment and diversion systems, including the storage of leaking or leak-prone vehicles and equipment awaiting maintenance, to prevent leaks and spills from contaminating stormwater; iv. Use drip pans or absorbents under or around leaking or leak-prone vehicles/equipment or store indoors." Schedule A.1.h.i within the permit states: "Clean up spills or leaks promptly using absorbents or other effective methods to prevent discharges of pollutants and use spill/overflow protection equipment." Schedule A.1.i within the permit states: "Regularly inspect, clean, maintain, and repair all industrial equipment and systems and materials handing and storage areas that area exposed to stormwater to avoid situations that may result in leaks, spills, and other potential releases of pollutants discharged to receiving waters." Observation: As discussed earlier in the report, during the walk-through within Sub-Basin 2 staining/sheens were observed on the surface near a front loader (Photo 28 & Photo 29). During the walk-through of Sub-Basin 3, while viewing the air separator location, I observed staining/sheens on the surface downslope of the device (Photo 42 & Photo 43). The concern is the staining/sheens at the observed locations. In addition, at the time of inspection Mr. Raichl discussed that sheens are frequently observed around the air-separator device, likely related to the frequency of the scheduled maintenance of the device (grease applications) and the exposure to stormwater. AOC #5: Benchmark Exceedances Observation: As discussed earlier in this report, according to Facility monitoring data, discharges from the Facility have been reported to exceeded benchmark values on 50 occasions between 2023-2021. Page 13 of 103 2024 CWA NPDES ORR127194 Inspection Report The concern is the frequency of the reported benchmark exceedances. Corrective actions, BMPs and/or the maintenance schedule utilized by the Facility have not been effective in eliminating the frequency of the benchmark exceedances. SECTION VI - CLOSING CONFERENCE Closing Conference Following the walk-through and records review a closing conference was held with Mr. Raichl and Ms. Marriott. I discussed my general observations, areas of concern and follow-up items, including potentially collecting effluent samples from Pond 3 as part of the EPA inspection. I then thanked them for their time and assistance during the inspection and we departed the Facility's main office. As discussed earlier in this report, no samples were ultimately collected following the closing conference, as the Pond 3 discharge pipe was observed to be partially submerged within the roadside ditch and upstream flow from the roadside ditch was observed to be partially entering into the discharge pipe, preventing the collection of a sample representative of only the Pond 3 discharge. We discussed our observation of the discharge pipe with Mr. Raichl and then departed the Facility. SECTION VII - POST INSPECTION CORRESPONDENCE On January 4, 2024, the Facility provided electronic copies of analytical results for 2023 (as discussed during the records review). On January 10, 2024 the Facility provided documentation of responses actions to items discussed at the time of inspection. See Attachment G, Inspection Response Documentation. SECTION VIII - LIST OF APPENDICES Attachment A - ODEQ Issued Monitoring Requirements Letter Attachment B - Site Layout Attachment C - Photograph Log Attachment D - Stormwater Pollution Control Plan (SWPCP) Attachment E - December 27, 2023, Site Inspection Report (Monthly) Attachment F - Tier I Reports (2023, 2022, 2021) Attachment G - Inspection Response Documentation Page 14 of 103 2024 CWA NPDES ORR127194 Inspection Report ATTACHMENT A ODEQ Issued Monitoring Requirements Letter Page 15 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 16 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 17 of 103 2024 CWA NPDES ORR127194 Inspection Report ATTACHMENT B Site Layout Page 18 of 103 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report Page 19 of 103 2024 CWA NPDES ORR127194 Inspection Report ATTACHMENT C Photograph Log All photographs taken by Jon Klemesrud on January 3, 2024 Nikon Coolpix AW100 Page 20 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:01 (DSCN3450) Description: Facing east, photo of the main office building and truck scale/entry. Photo #:02 (DSCN3451) Description: Facing northwest, photo of the maintenance building (shared with Dean Larson Excavation). Woodchipper was staged outdoors awaiting engine replacement. Photo #:03 (DSCN3452) Description: Facing east, photo of chipping area. Wood is processed in this area into "chips" and hauled to a nearby papermill in Wauna, WA. Photo #:04 (DSCN3453) Description: Facing north, photo of additional spill kits and absorbant materials used for re-supply. Items are stored in a closed shipping container east of the maintenance shop. It was discussed that spill kits are also contained within each vehicle. Page 21 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:05 (DSCN3454) Description: Facing east, photo of staged woodchipper. Photo #:06 (DSCN3455) Description: Photo of wood debris storage/processing area. The wood product is brought in from Recology and processed onsite as hog fuel and hauled daily to a paper mill in Wauna, WA. Photo #:07 (DSCN3456) Description: Facing south, photo of the hog fuel processing area. Photo #:08 (DSCN3457) Description: Facing east, photo of the northern boundary, north of the topsoil storage area. Page 22 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:09 (DSCN3458) Description: Facing west, photo of the western inlet to Pond 1. Photo #:10 (DSCN3459) Description: Facing north, photo of the Pond 1 cells/chambers. Photo #:11 (DSCN3462) Description: Facing south, photo of the Pond 1 cells/chambers. Photo #:12 (DSCN3460) Description: Facing west, photo of the Pond 1 discharge/outfall to unnamed slough. No sheen was observed at the time of inspection, discharge from the outfall was observed to be clear. Page 23 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:13 (DSCN3461) Description: Facing east, photo of the Pond 1 discharge/outfall to unnamed slough. No sheen was observed at the time of inspection, discharge from the outfall was observed to be clear. Photo #:14 (DSCN3463) Description: Facing east, photo of the north end of the topsoil storage area. Facility maintains the vegetated area as a BMP. Photo #:15 (DSCN3464) Description: Facing southwest, photo of the north/northwest end of the topsoil storage area. Facility maintains the vegetated area as a BMP. Photo #:16 (DSCN3465) Description: Facing south, photo of the drainage area between the topsoil pile and "intert" pile. Page 24 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:17 (DSCN3466) Description: Facing west, photo north boundary and unnamed slough. Photo #:18 (DSCN3467) Description: Facing south, photo of the eastern portion of the inerts pile, west of Pond 4. Photo #:19 (DSCN3468) Description: Facing north, photo of Pond 4. Photo #:20 (DSCN3469) Description: Facing north, photo of the northern cells within Pond 4. Page 25 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:21 (DSCN3470) Description: Facing east, photo of the Pond 4 discharge to the unnamed slough. No sheen observed, clear discharge. Foam observed at immediate discharge point. Photo #:22 (DSCN3471) Description: Photo of Pond 4 discharge to the unnamed slough. No sheen observed, clear discharge. Foam observed at immediate discharge point. Photo #:23 (DSCN3472) Description: Facing southwest, photo of wetland area located in the southeast corner of the property. Photo #:24 (DSCN3473) Description: Facing southwest, photo of rock stockpile area north/west of wetland area. Page 26 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:25 (DSCN3474) Description: Facing southwest, material stockpile area east of Pond 2. Photo #:26 (DSCN3475) Description: Facing north, ponded stormwater south of inerts storage area. Photo #:27 (DSCN3476) Description: Facing west, photo of southern boundary between the Facility's industrial activities and Highway 101 Alternate. Photo #:28 (DSCN3477) Description: Facing southeast, photo of sheen/staining observed near a front loader east of Pond 2. Page 27 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:29 (DSCN3478) Description: Facing south, photo of a processing/screening area. East of Pond 2. Photo #:30 (DSCN3479) Description: Facing south, photo of Pond 2. Photo #:31 (DSCN3480) Description: Facing east, photo of area east of Pond 2 and north of the processing/screening area. Photo #:32 (DSCN3481) Description: Facing north, photo of area north/northwest of Pond 2. Page 28 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:33 (DSCN3482) Description: Facing west, photo of Pond 2 outlet cell, Photo #:34 (DSCN3483) Description: Facing west, photo of Pond 2 discharge. No sheen observed, discharge appeared turbid at the time of inspection. Photo #:35 (DSCN3484) Description: Photo of Biochar filter socks, stored near Pond 2. Photo #:36 (DSCN3485) Description: Facing north, photo of Pond 2. Page 29 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:37 (DSCN3486) Description: Facing east, photo of the Pond 2 discharge to the unnamed slough. Photo #:38 (DSCN3487) Description: Facing west, photo of the of unnamed ditch upstream of the Pond 2 discharge location. Photo #:39 (DSCN3488) Description: Facing east, photo of the area north and west of Pond 2. Photo #:40 (DSCN3489) Description: Photo of covered stockpiled material/topsoil for commercial/public sale. Page 30 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:41 (DSCN3490) Description: Facing northeast, photo of the air separator. In service for approx. 3 years and replaced Flocait water separator. Photo #:42 (DSCN3491) Description: Facing northeast, photo of the air separator and processing area downslope of the air separator. Sheen/staining observed. Photo #:43 (DSCN3492) Description: Sheen/staining observed downslope of the air separator/processing area. Stormwater flowing towards Pond 3. Photo #:44 (DSCN3494) Description: Facing north, photo of stormwater flowing as sheet flow from the sorting/receiving area towards Pond 3. Page 31 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:45 (DSCN3493) Description: Facing south, photo of Pond 3. Photo #:46 (DSCN3495) Description: Facing south, photo of the influent flow into Pond 3. Photo #:47 (DSCN3496) Description: Facing north, photo of Pond 3. Photo #:48 (DSCN3497) Description: Facing west, photo of upstream location of the Pond 3 outfall, within the roadside drainage ditch. Page 32 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:49 (DSCN3498) Description: Facing east, photo of the downstream location of the Pond 3 outfall, within the roadside drainage ditch. Photo #:50 (DSCN3499) Description: Facing north, photo of Pond 3 and contributing drainage area. Photo #:51 (DSCN3500) Description: Facing west, photo of the receiving/sorting area. Photo #:52 (DSCN3501) Description: Photo from inside the maintenance shop, motor oil storage tote. Page 33 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:53 (DSCN3502) Description: Photo from inside the maintenance shop, power steering fluid storage tote. Photo #:54 (DSCN3503) Description: Photo from inside the maintenance shop, antifreeze and gear oil storage tote(s). Photo #:55 (DSCN3504) Description: Photo from inside the maintenance shop, hydraulic fluid storage tote. Photo #:56 (DSCN3505) Description: Photo from inside the maintenance shop, oil/lubricant storage area. Page 34 of 103 2024 CWA NPDES ORR127194 Inspection Report Photograph Log - Trails End Recovery Photo #:57 (DSCN3506) Description: Photo from inside the maintenance shop, grease cartridge used on on-site machinery. Photo #:58 (DSCN3507) Description: Photo from inside the maintenance shop, grease cartridge used on on-site machinery. Photo #:59 (DSCN3508) Description: Photo from inside the maintenance shop, grease cartridge used on on-site machinery. Photo #:60 (DSCN3509) Description: Facing west, photo of upstream location of the Pond 3 outfall, within the roadside drainage ditch. Page 35 of 103 2024 CWA NPDES ORR127194 Inspection Report ATTACHMENT D Stormwater Pollution Control Plan (SWPCP) Page 36 of 103 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report National Pollution Discharge Elimination System STORMWATER POLLUTION CONTROL PLAN FOR: Facility: Trails End Recovery Owner: Dean Larson Contacts: Alex Raichl and Rachel Marriott (503) 861-6030 customex.trailsend@gmail.com File No. 112084 EPA No. ORR127194 Primary SIC: 5093 Secondary SIC: 5261 NPDES 1200-Z Industrial Stormwater Discharge General Permit 2060 SE Airport Lane Warrenton Clatsop County Oregon 97146 SWPCP Prepared By: Robert S. Bogar, M.S. 949 14th Street Astoria, OR 97103 & TER July 27, 2022 Page 37 of 103 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report TABLE OF CONTENTS GENERAL LOCATION.............................................................................. 2 General Location Map.................................................................................. 2 SITE DESCRIPTION .................................................................................. 3 SITE CONTROLS ....................................................................................... 5 PREVENTATIVE MAINTENANCE ......................................................... 8 MONITORING LOCATIONS AND RECEIVING WATERS .................. 9 EDUCATION TRAINING AND ELEMENTS ........................................ 11 SIGNATURE PAGE.................................................................................. 12 Figure 2: Site Map APPENDIX A APPENDIX B Spill Prevention and Response Plan Employee Education and Pond BMPs Page 38 of 103 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report GENERAL LOCATION The project site is located on a topographically flat area approximately 1 mile south of Youngs Bay and less than mile west of The Lewis and Clark River. Boundaries of the property are defined by Alternate Highway 101 on the south, DOT maintained ditches and property on the west, and on the north and east by an unnamed slough. The project site covers an area of approximately 364,650 ft2 (8.37 acres), and includes portions of Tax Lots 700, 702, 703 and 704. The project site lies at an estimated elevation of about 15 ft. above mean sea level. Possible wetlands are located near the east portions of Sub-basin 4 at the project site. This area to the north is associated with the slough that drains surface water runoff to the east to The Lewis and Clark River. General Location Map Page 39 of 103 2 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report SITE DESCRIPTION Trails End Recovery (TER) is a Material Recovery and Recycling Facility and a retail landscape product supply. TER accepts clean wood, clean brush and yard debris, concrete and asphalt, treated wood products, dirty brush/land clearing debris, dirt/rock/sod, non-fluid/gas-containing appliances and other scrap metal, mixed construction debris, asphalt 3-tab roofing (not for processing), wood ash and log yard material. The incoming trucks are weighed on a scale immediately north of the TER office building and offloaded based on the type of material brought in. For mixed construction debris, clean wood, treated wood, sheetrock, scrap metal, and asphalt roofing, sorting is conducted near the main entry to the yard (labeled "sorting area" on Figure 2). These materials are separated and processed or placed in temporary storage. Any materials that contain liquid waste, hazardous waste, or other chemicals are not accepted by TER. Other recycling operations at the site include: various machinery is used to dry screen/separate or air screen/separate materials. TER screens/separates bark, rocks, sand, soil, and log yard material. These processes involve the separation of bark and rock, or soil and rock. After processing, the sand, rock, and boulders are marketed separately as base rock, fill material, beauty bark, mulch, hogfuel, landscape rock, flat rock, and gravel. Bark fines are screened/mixed with wood ash and composted bark and then marketed as topsoil. Some of the clean processed rock is utilized onsite to improve the working surface and to reduce soil runoff and surface water turbidity. Marketed topsoil is tested for several metals, nutrient levels (potassium, phosphorus, and nitrogen), and physical properties (bulk density, moisture content, organic and mineral fraction, etc.). Treatment of materials onsite is limited to physical separation, screening, grinding, and mixing of materials with no chemical treatment of any materials conducted onsite. The various retail products are stored in uncovered areas as shown on the attached Figure 2. Unprocessed construction materials stored at the site include creosoted piles and treated lumber located near the north end of Sub-basin 1. Treated wood piles have been raised to prevent direct contact with the ground within 72 hours of receipt. Bulk, uncrushed concrete is stored for crushing and is utilized as the main ingredient of the concrete aggregate. The concrete pile is located near Settling Pond 4, located in Sub-basins 1 and 4 (see Figure 2). Prior Operations No impacts from prior operations have been noted at the facility. Business Hours Trails End Recovery is open to the public from 8:00 AM to 4:30 PM Monday through Friday, between April and September we are also open Saturdays 9:00 AM to 3:30 PM. Potential Pollutants in Stormwater Discharges/Drainage Patterns Sub-basin 1 drains to Settling Ponds 1a and 1b located toward the north side of the facility. Pond 1 accepts runoff from the hogfuel production area, creosoted pile and treated lumber storage areas, and soil storage. Potential pollutants from stored products or activities conducted in Sub-basin 1 could include; hydrocarbon contamination from creosote storage, hydraulic fluid from machinery or traffic, TSS levels from soil, or incidental plastics. Sub-basin 1 drains an area of approximately 115,384 ft2 (2.65 acres) including about Page 40 of 103 3 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report 49,024 ft2 (1.13 acres) of impermeable surface (42% impermeable). See Figure 2. Sub-basin 2 drains to Settling Pond 2 located near the south gate of the project site. Pond 2 accepts runoff from storage of unscreened log yard material, landscaping product areas (southwest portion), wood ash, concrete storage area and mixed wood and rock storage. Sub-basin 2 potential pollutants include TSS from exposed soil and bark or hydraulic fluid from machinery or traffic through the gate. Sub-basin 2, drains an area of approximately 62,698 ft2 (1.4 acres), including about 9,092ft2 (0.2 acres) of impermeable surface (14.5 % impermeable). Sub-basin 3 drains to Settling Pond 3a and 3b and accepts runoff from the mixed construction debris sorting area, 3-tab asphalt shingles, scrap metal for recycling, a parking area near the TER office, and landscaping product storage areas. Potential pollutants from stored products or activities include turbidity from high traffic volume, incidental plastics or other materials, motor oil from the parking area, or hydraulic fluid from equipment and customer vehicles. Sub-basin 3, drains an area of approximately 93,945 ft2 (2.16 acres), including about 56,759 ft2 (1.3 acres) of impermeable surface (60 % impermeable). The Flocait operation would take place in Sub-Basin 3. The Flocait is currently not in use until the Flocait manual can be implemented. Sub-basin 4 drains into the bioswale south of Settling Pond 4a and 4b. Pond 4 accepts the runoff from concrete storage area, unscreened topsoil, unscreened bark, fill dirt storage, and a small gravel parking area. Potential pollutants from stored products or activities include TSS from exposed soil, incidental plastics, or hydraulic fluid from heavy equipment or vehicles. Sub-basin 4 drains an area of approximately 92,620 ft2 (2.12 acres). None of Sub-basin 4 is impermeable surface. Sub-basin 5 is a small area west of the maintenance shop at the TER facility. Potential pollutants in this area include oil and grease from employee parked vehicles or customer vehicles. Besides the 10x10 onramp to the scale, none of Sub-basin 5 is impermeable surface. Stormwater runoff enters a catch basin and enters the roadside ditch south of the facility. Impervious Surface Area The two buildings utilized by TER cover a combined area of approximately 5,408 ft2. The total impervious surface at the project site including the buildings and yard areas is approximately 121,324 ft2 (2.78 acres) or approximately 32% of the 380,079 ft2 (8.7 acres) project site (increased from 11% in November 2007, 16% in 2009 and 26% in 2014). Non-Stormwater Discharges Exterior vehicle wash water that does not use hot water or detergent; restricted to less than eight per week. Unless circumstances won't allow, vehicles are washed offsite. There is one discharge point that is excluded from monitoring. In sub-basin 3, near discharge point DP003 there is a groundwater pipe that drains into the man-made roadside ditch. The pipe originates from around the perimeter of the subgrade tank as shown in Figure 2 (labeled M) to drain surrounding groundwater. This pipe only drains groundwater. Page 41 of 103 4 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report SITE CONTROLS Stormwater Best Management Practices- Control Measures TER has developed, implemented, and maintained stormwater controls appropriate for the project site. The purpose of these site controls is to comply with technology based effluent limits to eliminate or minimize the potential to contaminate stormwater, and to prevent any violation of instream water quality standards from stormwater. TER has employed the following types of best management practices appropriate for the site: Bio-bags- are placed in specific areas around each pond. Bio-bags slow water sufficiently to trap sand, silt and clay in and upstream of the bio-bag. They fit the contours of the land. Bio-bags are replaced if they break or are plugged. Oil soaker pads and snakes- each pond has two to four oil soaker pads per chamber and one to two oil snakes per chamber. The oil soaker pads will soak up any surface oils and the oil snakes will catch any oil missed by the pads. Both oil pad and snake soakers are replaced as needed. Rock baffles- All four ponds have rock baffles to slow the water flow and allow sediment to settle before discharging. The rock baffles are inspected for effectiveness and rock is added if needed. Pond 4 has a short vegetated bioswale that helps filter water and slow the velocity to allow settlement. Excess soil debris is scraped up off the high traffic areas to prevent tracking and runoff. New rock is placed around each pond regularly to slow moving water and stabilize the high traffic areas. Impervious expansion- TER is periodically expanding the impervious areas when leftover concrete is available. A buffer of approximately 15 feet (the road) along the slough will remain clear of all storage or products to help prevent site material falling into the slough. Vegetated compost berms are used around most stock piles. Compost is positively charged which tends to attract and hold the soil particles. In addition, the biota in the compost consumes oil and grease and can convert some soluble pollutants into insoluble forms. The compost berms are inspected for berm blow outs or saturation. During winter months, inactive soil piles are tarped to prevent soil runoff. Tarps are usually held down with tires and only removed for loading. Inside the maintenance building, an oil soaker berm is kept along the oil bins to absorb spills or drips. Oil pads and absorbent litter is used to clean up small spills. Equipment and vehicles are inspected regularly for leaks. Any leaks are fixed or taken out of service immediately. Employee training is done to ensure the correct spill response procedures and preventive measures are taken. Each pond has been constructed with oil and grease trap that pull water from the bottom of each pond. The oil soakers will soak up any potential surface oils. Spill kits are kept in every machine and truck for easy access in the event of a spill. Several spare kits are kept onsite and are replaced after use. Page 42 of 103 5 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report Incoming material is sorted and inspected for any hazardous materials or liquids and then contained to prevent tracking throughout the facility and entering stormwater. Any unacceptable materials are rejected. Employees inspect the facility for debris daily. The sorting area is also bordered by eco-blocks and metal bins to contain the materials. Areas that are used for processing barks and wood are also bordered by eco-blocks, wood poles, or vegetated compost berms to contain the materials. All 4 ponds are dug out monthly to keep sediment levels down. There are mesh caps covering the outflow pipes to prevent any solids from leaving the site. Soil stockpiles with vegetation are "do not disturb" zones to maintain natural erosion control. Each pond has a Cherne Gripper Plug that can be placed in the outfall pipe to prevent the water from leaving the ponds in the event of a spill. Minimize Exposure As described above TER minimizes exposure of contaminants to the environment by working with petroleum hydrocarbons indoors in its maintenance shop, and storing petroleum hydrocarbons indoors and in appropriate storage containers above secondary containment. TER has placed an oil absorbent berm around petroleum storage areas in accordance with best management practices to prevent a potential release from impacting stormwater quality. Storage in the TER maintenance building includes the storage of waste oil from vehicle repair projects and vehicle maintenance. The waste oil is stored in a large 1,000-gallon tank located along the northeast interior wall of the TER maintenance building. Other mixtures of petroleum fuel and lubricants include gear lube, bar and chain oil, SAE 10w, SAE 30w, SAE 50w, windshield fluid, and anti-freeze contained in labeled containers above secondary containment bins. All chemicals are disposed of properly. Smaller 2-gallon and 5-gallon containers stored within the building onsite include power steering fluid, 2 cycle oil, automatic transmission fluid and gasoline. Because some heavy equipment located on-site utilizes diesel fuel and hydraulic fluid, each vehicle / heavy machinery operated at the TER facility is equipped with a spill cleanup kit containing oil absorbent mats, epoxy repair putty, gloves, disposal bags, and absorbent litter. Heavy equipment at the facility does not typically operate immediately adjacent to stormwater ponds (except briefly when accessing landscaping bins near Pond 3). Any spills from heavy machinery or other vehicles will be contained and cleaned up immediately to prevent a release into pond waters (all are equipped with oil and grease traps). Approximately 80% of TER equipment is now using vegetable biodegradable grease. Areas of high traffic are regularly rocked and graded and rock is replaced in areas around ponds to help reduce turbidity, this helps by scraping up any soil that has been tracked by traffic from becoming runoff into the ponds. Compost berms, eco-blocks, and tarps are used around select soil piles during the winter months. Equipment awaiting maintenance are stored on the paved area behind the maintenance shop, or if possible, inside the shop. Oil soakers, drip pans or an oil berm is placed under or around the equipment if needed and left in place until the leak is repaired. No permanently inoperable vehicles are stored at the TER facility. Scrap metal in the receiving area is inspected for controlled liquid chemicals. TER does not accept computers, transformers, or other appliances that contain liquid chemicals. Any loads that have non-acceptable materials are rejected. Page 43 of 103 6 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report TER also minimizes exposure by providing information and educational materials to customers about acceptable and non-acceptable materials. TER's Solid Waste Operations Plan outlines procedures for handling incidental non-acceptable materials. Oil and Grease Oil absorbent pads and snakes are currently utilized in each of the ponds to contain any potential petroleum hydrocarbons. Each pond has been constructed with oil and grease trap that pull water from the bottom of each pond. Spill kits are stored in all vehicles and equipment, near fueling stations, oil bays, and spares are kept in storage containers (labeled on Figure 2). See Appendix B Employee Education and Pond BMPs Waste Chemicals and Material Disposal Waste oil, stored in the TER maintenance building, is disposed of when required (approximately quarterly) by Emerald Services, Inc. Metal bins, stored in the Sorting Area, are picked up for recycling, approximately once a month, by Metro Metals. Or TER hauls scrap metal to local scraps yards to prevent accumulation on site. Non-recyclables dumpsters, stored in the Sorting Area, are removed approximately daily by Recology Western Oregon. Erosion and Sediment Control Ongoing activities to improve stormwater quality and reduce erosion includes, cleaning up any excess muddy debris and replacing it with crushed rock in areas where fine-grained sediment is exposed and also paving areas with non-cured concrete as it becomes available from other projects. The access roadway along the north facility boundary and adjacent to the unnamed slough is regraded periodically to slope away from the slough with additional gravel placed at this location. Drainage has also been improved adjacent to a spring identified immediately south of the access roadway. Surface waters emanating from the spring have been diverted to the south and are treated by Pond 1 prior to entering the slough. Exposed soils are vegetated before winter months and a compost berm is placed around soil stockpiles to prevent runoff. TER also compacts the stockpiles to help seal and prevent soil movement. Tarps are utilized to help control runoff when the stockpiles become inactive during winter months. Debris Control, Dust Generation, and Vehicle Tracking The sorting area is surrounded by eco-blocks to prevent debris from blowing around the facility. The staff monitors the entire facility daily and removes garbage that may have blown around. TER is reducing dust by paving with concrete and by placing crushed rock. During the summer months, TER daily sprays the facility with a water truck, kept onsite, to diminish dust generation. Incoming materials are stacked up and stabilized daily to prevent customers or employees from driving through it and tracking it through the facility. Page 44 of 103 7 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report Housekeeping Any construction debris containing garbage or non-recyclable materials is sorted in an area dedicated to that process on an impermeable surface as described above. It is bordered by eco-blocks to contain the materials and is processed quickly. Employees working in that area regularly clean up any materials that might have blown out of the sorting area. They also run large magnets around the facility to pick up nails or other pieces of metal. When possible, all maintenance of vehicles is conducted inside the maintenance shop supporting a flat single pour concrete slab with no floor drains. Regular cleaning of the floors and building keeps material from being tracked outside of the structure. Any spills are cleaned up immediately. Heavy equipment and company vehicles are routinely inspected for leaks and repaired immediately if discovered. PREVENTATIVE MAINTENANCE Daily (undocumented) inspections are conducted of the following: Checking for and removing any garbage in or around the ponds Making sure the pond soakers are in place and clean Checking each pond for oil sheen or other potential spills Monitoring the condition of bio-bags and replacing them as needed Product bins- checking for overflow/containment and the condition of the eco-blocks Sorting Area- checking for any liquid staining or liquid chemical spills/staining Inspecting equipment and trucks for leaks A minimum of (documented) monthly inspections is conducted on the following: Interior fluid storage area Settling ponds Visual inspection for leaks around equipment Each pond is equipped with an 8-inch PVC pipe that pulls water from near the bottom of the pond, directs water through a 90-degree elbow and discharges water downgradient either into the ditch or slough. These pipes minimize the potential for oil and grease or other light non-aqueous phase liquids (LNAPLs), to impact waters adjacent to the TER facility. Vegetated man-made ditches connect ponds 2 and 3 with the slough (directly for Ponds 1 and 4) which conveys stormwater runoff to The Lewis and Clark River. All ponds have double basins with rock baffles in order to slow the water velocity and allow more time for solids to settle. Discharge from Pond 3 would have to travel approximately 1580 feet through a vegetated ditch to the unnamed slough and another 574 feet to Lewis and Clark River. The fluid storage area within the TER shop is inspected monthly for leaks of the 55-gallon drums or valves. Absorbent cloths and absorbent berms are utilized to contain any low volume spills. Equipment is inspected monthly and during routine maintenance to detect hydraulic leaks, motor oil fluid leaks or fuel leakage (gas or diesel). Machinery will be shut down upon a leak detection until defective parts are repaired or replaced. Approximately 80% of TER's yard equipment is using biodegradable grease and oils. Page 45 of 103 8 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report The Sorting Area is inspected on a daily basis for liquid staining, signs of liquid chemical staining or liquid chemical spills. Potential spills could include paint, liquid petroleum hydrocarbons or other chemical products. In the event that the liquid is not readily identifiable, the chemical spill will be contained and handled by a qualified individual. Although TER does not accept these chemicals, incidental chemicals may come into the facility. If they are discovered, the customer must take them back or TER disposes of them in accordance with solid and/or hazardous waste rules. Although TER conducts the above inspections in order to lessen the likelihood of spills that might impact the project site environment, TER recognizes that spills may still occur. Spill response procedures have been developed as part of Employee Orientation and Education Program which will inform personnel of the components and goals of the SWPCP as well as address spill response procedures and the necessity of good housekeeping practices. MONITORING LOCATIONS AND RECEIVING WATERS Stormwater quality is currently being monitored at four discharge outfalls, Discharge Points DP001 through DP004 shown on Figure 2. They correspond to the outlets from Settling Ponds 1 through 4. Ponds 1 (46.144276, -123.872194) and Pond 4 (46.144321, -123.871016) are on the Northern side of the facility and they both discharge into an unnamed slough which discharges to The Lewis and Clark River. Lewis and Clark River runs into Youngs Bay, and the Columbia River Estuary. Pond 2 (46.143001, 123.872201) and Pond 3 (46.143217, -123.873639) are both on the Southern side of the facility and both discharge into a man-made ditch and after approximately 1580 feet it reaches the unnamed slough. The slough is not an impaired water body. Primary SIC: 5093, Secondary SIC: 5261. Pond Flow Calculations Pond flow calculations were conducted in order to size outlet pipe diameters to prevent flooding of the project site. Ideally, the smallest possible diameter pipes are used in order to increase pond detention time while still preventing flooding for likely rainfall events. Pond flow calculations utilized areal coverage estimates based on measurements of each pond taken in November 2017 (shown on Figure 2 Site Plan) and were sized for Type II storm events for 24-hour one-inch rainfall events. Sub-basin infiltration rates were defined for either impermeable surfaces or un-vegetated dirt roads. CN numbers of 98% runoff (allowing 2% evaporation) and 89% runoff (equivalent to dirt roads) were utilized for impermeable and permeable surfaces, respectively. The length of outlet pipes was modeled for 6 feet to 14 feet pipe lengths (Pond 2 has a longer pipe that outlets directly into the man-made vegetated ditch) and modeled as smooth sided pipes. To calculate pond capacity the dimensions of each pond were recorded including width, length and approximate pond depths. For modeling purposes pond sidewalls were approximated at a 1:1 (horizontal to vertical) slope with relative elevations provided for outflow elevations. These calculations are conservative. A generalized diagram showing a single pond and outflow pipes is shown below: Page 46 of 103 9 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report Total treated volume of water for each pond is presented below: Pond Length Pond Width Pond Depth Sub-Basin Area (Sq Ft) Max Flow (CFS) Pipe Diameter (in) Treated Volume (Ac Ft) Pond Statistics Pond 1 a/b Pond 2 a/b 36/46 32/32 12 12 3-5 3-5 115,384 62,698 1.49 .90 8 8 0.092 .039 Pond 3 a/b 20/16 15/19 3-5 93,945 1.93/1.9 8/10 .099/.099 Pond 4 a/b 20/22 13/13 3-5 92,620 1.02/0.97 8/8 0.042/0.041 Results upon calculation suggest that 8-inch outflow pipes are more than adequate for all of the ponds except for Pond 3b requiring a 10-inch outflow pipe. This is due to the size of the basin relative to the pond size. The total volume of treated water is highest for Ponds 3a and 3b (about 0.099-acre feet) and Page 47 of 103 10 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report lowest for Pond 2 (0.039-acre feet). SPILL PREVENTION AND RESPONSE PROCEDURES The Spill Prevention and Response Plan is included in Appendix A. EDUCATION TRAINING AND ELEMENTS TER implements education and training of each new employee within 30 days of the date of hire and annually thereafter. Participants acknowledged annual training attendance by signing a signature page, which are maintained in the TER office onsite. The General Manager, Office Manager and/or the Shop Foreman are responsible for providing employee orientation and education for new employees and annual review for existing employees. Employees who do not conduct duties related to the implementation of the SWPCP or who do not work in areas where stormwater is exposed to industrial activities may be exempt from this requirement. Employees are informed of the pertinent components and goals of the 1200-z permit and this SWPCP. See Appendix B Employee Training and Pond BMPs CUSTOM EXCAVATING OPERATIONS From time-to-time operations between Custom Excavating and Trails End Recovery cross paths. Custom Excavating delivers wood products to Trails End Recovery for processing. Custom Excavating's trucks transporting wood products are weighed in at the scale then proceed to either the chipping area that is directly in front of the scale (labeled "woody debris" on Figure 2), or towards the trailer tipper located on the southeast end of the hogfuel area. When not in use, these trucks are either in the parking area southwest of the office or past the north facility boundary line. Although Custom Excavating's trucks and equipment are stored and used at the Trails End facility, there are no separate operations other than described above. Page 48 of 103 11 2024 CWA NPDES ORR127194 Inspection Report Page 49 of 103 Trails End Recovery SWPCP File No. 112084 2024 CWA NPDES ORR127194 Inspection Report Page 50 of 103 APPENDIX A 2024 CWA NPDES ORR127194 Inspection Report SPILL PREVENTION AND RESPONSE PLAN FOR: Custom Excavating by Dean Larson Inc. Trails End Recovery 2060 SE Airport Lane Warrenton, OR 97146 Contact Person: Alex Raichl (503) 861-6030 customex.trailsend@gmail.com File No. 112084 ORR12-7194 Issued 12803 GEN1200Z CLATSOP/NWR Permit 1200-Z (#17589) Report By: Robert S. Bogar, M.S. 949 14th Street Astoria, OR 97103 Revised August 31, 2021 Page 51 of 103 2024 CWA NPDES ORR127194 Inspection Report Spill Prevention and Response Plan SPILL PREVENTION AND RESPONSE PLAN TABLE OF CONTENTS 1.0 INTRODUCTION AND SCOPE OF WORK .............................................................................................. 3 2.0 RESPONSE PLAN .................................................................................................................................. 3 3.0 SPILL RESPONSE PERSONNEL .............................................................................................................. 3 4.0 DESCRIPTION OF RISKS........................................................................................................................ 3 5.0 DESCRIPTION OF MATERIALS .............................................................................................................. 3 6.0 PREVENTIVE MEASURES/BEST MANAGEMENT PRACTICES................................................................ 3 7.0 CONTAINMENT ................................................................................................................................... 4 8.0 SPILLS ON TO SOIL............................................................................................................................... 4 9.0 SPILLS INTO WATER............................................................................................................................. 5 10.0 DISPOSAL........................................................................................................................................... 5 11.0 TRAINING .......................................................................................................................................... 5 12.0 REQUIRED ITEMS ONSITE.................................................................................................................. 6 13.0 WHEN TO REPORT A SPILL ................................................................................................................ 6 14.0 EMERGENCY CONTACT INFORMATION ............................................................................................ 6 Page 52 of 103 Page 2 2024 CWA NPDES ORR127194 Inspection Report Spill Prevention and Response Plan 1.0 INTRODUCTION AND SCOPE OF WORK Custom Excavating and Trails End Recovery is an industrial salvage and recycling business. Currently Trails End Recovery (TER) accepts clean and mixed wood, brush, and yard debris, tree stumps, treated wood products, asphalt, concrete, dirt, rock and sod, excavation materials, scrap metal, demolition debris, sheetrock, and asphalt roofing. Products are transported by trucks, which are weighed on a scale immediately north of the TER building, and offloaded for sorting near the main entry to the yard. 2.0 RESPONSE PLAN This plan outlines the general procedures followed in the event of a release or spill of a hazardous or regulated material or waste. 3.0 SPILL RESPONSE PERSONNEL General Manager- Alex Raichl (503) 741-6867 Shop Manager- Bert Chase (503) 741-6916 Office Manager- Rachel Marriott (503) 298-1445 Shop Assistant- Robert Byrd (503) 468-2266 4.0 DESCRIPTION OF RISKS TER does not accept hazardous or dangerous waste. The recycling processes do not involve or create major quantities of hazardous or regulated waste. Of the limited amount of hazardous or regulated material used onsite, the proper management of their handling and storage will be ensured to mitigate any potential effects to on-site personnel or the environment. Although the risk of a significant release is low, this plan provides best management practices and guidelines to further reduce the risk from a release. The most common types of spills are small and easily contained. Spills of fuel, lubricants during operations can occur as a result of fueling, hydraulic hose brakes, mechanical damage or vandalism. 5.0 DESCRIPTION OF MATERIALS The main categories of hazardous/regulated materials used will be: Recycled/stockpiled construction materials Equipment coolants and maintenance chemicals including fuels, lubricating and hydraulic oils Construction vehicles which contain antifreeze, fuels and lubricants Safety Data Sheets for all typical materials used by the facility are stored onsite at all times. 6.0 PREVENTIVE MEASURES/BEST MANAGEMENT PRACTICES Equipment Staging, Maintenance and Fueling Page 53 of 103 Page 3 2024 CWA NPDES ORR127194 Inspection Report Spill Prevention and Response Plan Store and maintain equipment in a designated area Make sure all containers are labeled correctly Use secondary containment (drain pan) to catch spills when removing or changing fluids Use proper equipment (pumps, funnels) to transfer fluids Do not "top-off" tanks Do not leave fueling unattended Keep spill kits readily accessible Check incoming vehicles for leaking oil and fluids Transfer used fluids and oil filters to waste or recycling drums Inspect equipment routinely for leaks and spills Repair equipment immediately, if necessary Implement a preventative maintenance schedule for equipment and vehicles Regulated Waste/Hazardous Waste Storage Area. Use secondary containment for any stored fluids. Use entire volume before disposing of the container Retain the original product label or SDS Recycle any useful material (used oil) Segregate wastes by waste type Minimize the quantity of hazardous waste generated onsite and maintain storage quantities, times and disposal in compliance with USEPA regulations (note, it is not anticipated that the site will generate hazardous waste) Arrange for disposal of hazardous/regulated waste at an approved waste facility as needed. Do not store waste unnecessarily. Train employees in proper hazardous/regulated material and waste management 7.0 CONTAINMENT Hazardous Substances as defined in 40 CFR (Section) 302.4 must be stored within berms or other secondary containment devices to prevent leaks and spills from contaminating stormwater. The Environmental Protection Agency interprets section 101(14) to exclude crude oil and fractions of crude oil including hazardous substances such as benzene, in what in commonly known as the petroleum exclusion. While it would be extremely unlikely that a release of this volume of liquid petroleum hydrocarbon would reach Pond 1, TER placed an oil soaker berm around the 55-gallon tanks is in accordance with best management practices for the project site to prevent impacts to stormwater quality. Screening of scrap metal in the receiving area is inspected of controlled liquid chemicals. TER does not accept computers, transformers, or compressors, or other appliances that contain liquid chemicals, unless the chemicals have been removed. 8.0 SPILLS ON TO SOIL In the event that a soil spill occurs, the following procedures are to be followed: Page 54 of 103 Page 4 2024 CWA NPDES ORR127194 Inspection Report Spill Prevention and Response Plan Stop operations. Identify the product- check container design, warning labels, markings etc. Prevent personnel from approaching the area and keep them at a distance sufficiently removed that they will not be injured by, or cause, a fire or explosion. Stop the flow at the source-reduce or terminate the motion of product without endangering anyone. Assess the extent of the spill. Get spill kit and place the oil sock around the spill. Dump kitty litter or hogfuel on spill. Report the spill to the department manager and provide basic information such as location of spill, what was spilled and the amount spilled. Fill out a Spill Response Form if it is a reportable spill. The petroleum spill does not need to be reported to the Oregon Department of Environmental Quality (ODEQ) if the following criteria are met: The quantity is known to be less than 42 gallons; and The spill is contained and under the control of the spiller; and The spill has not and is not likely to reach land or waters of the state; and The spill is cleaned up within 24 hours of discovery. A spill is considered to have not impacted land if it occurs on a paved surface such as asphalt or concrete. A spill in a dirt or gravel parking lot is considered to have impacted land and is reportable if it does not meet the above requirements. Report the spill to other federal and local authorities, if required. 9.0 SPILLS INTO WATER Stop the source of the spill immediately Shut down all equipment and ignition sources in the area Plug the pond pipe until spill is cleaned up Install boom and absorbent to contain the spill Notify the Department Manager Notify ODEQ Notify a spill response contractor, if necessary Clean up absorbent and waste materials and dispose at an approved waste disposal facility Decontaminate the area, equipment and surfaces that have contacted the spilled material 10.0 DISPOSAL Hazardous Wastes will be transported via truck to an appropriate disposal facility as needed. Stored waste oil is picked up by Emerald Services, Inc., approximately quarterly. 11.0 TRAINING All personnel working at TER will be informed of all possible spill hazards, as well as the location, content, and usage of spill kits. All new employees will receive a copy of TER's Occupational Health Page 55 of 103 Page 5 2024 CWA NPDES ORR127194 Inspection Report Spill Prevention and Response Plan and Safety Program, SDS Training, and an Employee Handbook. Sections of this information are reviewed quarterly during Company Meetings and weekly tailgate meetings. 12.0 REQUIRED ITEMS ONSITE A spill kit should include: Poly containment pail, oil absorbent pads, oil absorbent socks, heavy duty disposal bags, nitrile gloves, all-purpose absorbent (such as sawdust or kitty litter), shovels, plugs, and clamps to control line breaks. 13.0 WHEN TO REPORT A SPILL You are responsible for the immediate cleanup of your spill, regardless of the quantity involved. The responsibility lies with the person who spills the product, as well as the person owning or having authority over the oil or hazardous material. Reportable spills include: any amount of oil to waters of the state; oil spills on land in excess of 42 gallons; hazardous materials that are equal to, or greater than, the quantity listed in the Code of Federal Regulations, 40 CFR Part 302 (List of Hazardous Substances and Reportable Quantities), and amendments adopted before July 1, 2002. 14.0 EMERGENCY CONTACT INFORMATION Oregon Emergency Response System (OERS) (800) 452-0311 Fire Department 911 USEPA National Response Center (800) 424-8802 Page 56 of 103 Page 6 2024 CWA NPDES ORR127194 Inspection Report 2060 SE AIRPORT LANE WARRENTON, OR 97146 * (503)861-6030 * FAX (503)861-4341 customex.trailsend@gmail.com www.trailsendrecovery.com APPENDIX B Stormwater Pollution Protection Plan Training 1. Specific control measures used to achieve the narrative technology-based effluent limits such as spill response procedures and good housekeeping practices Spill response procedures- Clean up spills promptly, dispose of liquids correctly and promptly. Make sure all containers are labeled. Good housekeeping- Keeping garbage picked up, alerting management about leaks and spills, keep materials orderly and properly labeled, materials are stowed in proper containers, proper maintenance of vehicles and/or equipment. Regular dust suppression of the yard, write it down on your timecard for office record keeping. 2. Monitoring, inspection, reporting and documentation requirements. Pond Monitoring-Checking for oil sheen, foam, turbidity (muddy water), garbage or other debris, clean soakers and snakes, bio-bags are in place and in working condition, replace if needed. Check the pipes to make sure they are clear for water flow. See Pond BMPs. Monthly inspection reporting is required by DEQ. Documentation is required by DEQ. All monthly yard and pond inspections, SWPCP revisions, corrective actions and other reports are documented and stored in the office. Ponds Pond 1- Located at the Northeast side of the Property (see map) Pond 2- Located Southeast near the gate on the Property Pond 3- Located at the South side of the Property Pond 4- Located at the East side of the Property Each pond will be inspected daily by the yard staff and every month by the Office Manager. They will also be inspected after large storm events; the inspection results will be recorded in the binder that's located in the office. Any garbage around or in the ponds should be picked up and disposed of daily. When inspecting the ponds, check for signs of high sediment, color, odor, foam, turbidity, oil sheen, and outflow (make sure pipes are clear). Effective 1/2018, Amended 8/2019, 8/2021 Page 57 of 103 1 | Page 2024 CWA NPDES ORR127194 Inspection Report All ponds must have a minimum of three oil soakers at all times, these will be switched out as needed. They will also each have 2 oil snakes across each pond to ensure 100% containment should a spill occur. See Pond BMPs Oil soakers will be disposed of in biohazard bags, located in the safety closet. Report any issues immediately to your supervisor. Many of the ponds have rock baffles, report any needs for repair. Shop Oil Bay Oil soakers will be disposed of in biohazard bags, located in the safety cabinet. All spills in the shop must be cleaned up immediately. All oils and fuel must be stored and kept in appropriate labeled containers, with secondary containment procedures in place. Oil soakers and absorbents must be kept on hand at all times, notify your supervisor if the stock is getting low. The containment boom around oil bay perimeter must be kept clean and checked regularly. Monthly inspection results of the oil bay are kept in the shop. See Spill Response Plan for spills over 42 gallons. By signing below, I acknowledge that I received and read a copy of Trails End Recovery's Spill Pollution Response Plan, received a copy of the Pond BMPs, and have been trained on the information above. ___________________________________________ Printed Name ___________________________ Date ___________________________________________ Employee Signature Effective 1/2018, Amended 8/2019, 8/2021 Page 58 of 103 2 | Page 2024 CWA NPDES ORR127194 Inspection Report Effective 1/2018, Amended 8/2019, 8/2021 Page 59 of 103 3 | Page TER Pond BMPs Pond #1-Near hogfuel area Potential Issues and Notes about Pond: 1. Hogfuel debris can runoff into pond. 2. Road around pond tends to get muddy. 3. Bio-bags will need inspected regularly and replaced as needed. 4. Machines are closest to this pond; beware of oil sheen or runoff. 2024 CWA NPDES ORR127194 Inspection Report Pond #2- Near back gate Potential Issues and notes about pond: 1. Near bark pile, watch for floating bark-remove daily. 2. Lots of traffic near pond, watch for garbage and runoff. Page 60 of 103 2024 CWA NPDES ORR127194 Inspection Report Pond #3- Near Product Bins Potential Issues and notes about pond: 1. Road in front of chamber 1 can get muddy. Add gravel when needed. 2. Bio-bags need checked regularly (broken or plugged) and replaced as needed. Pond #4- Near the backside of the concrete pile Potential Issues and notes about pond: 1. Bio-bags need checked regularly in the bioswale (ditch) 2. Keep concrete chunks away from the pond. Page 61 of 103 2024 CWA NPDES ORR127194 Inspection Report ATTACHMENT E December 27, 2023, Site Inspection Report (Monthly) Page 62 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 63 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 64 of 103 2024 CWA NPDES ORR127194 Inspection Report ATTACHMENT F Tier I Reports (2023, 2022, 2021) Page 65 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 66 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 67 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 68 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 69 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 70 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 71 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 72 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 73 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 74 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 75 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 76 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 77 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 78 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 79 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 80 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 81 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 82 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 83 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 84 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 85 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 86 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 87 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 88 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 89 of 103 2024 CWA NPDES ORR127194 Inspection Report Page 90 of 103 2024 CWA NPDES ORR127194 Inspection Report ATTACHMENT G Inspection Response Documentation Page 91 of 103 2024 CWA NPDES ORR127194 Inspection Report From: To: Subject: Date: Attachments: Rachel Marriott Klemesrud, Jon Re: Trails End Recovery Sample Results Wednesday, January 10, 2024 4:16:46 PM EPA Inspection 1-3-24.pdf Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Good afternoon Jon, We appreciate the recent EPA inspection of our Trails End Recovery facility in Warrenton. Following the inspection, we have taken steps to address all identified issues to ensure ongoing compliance with environmental regulations. Attached are some photos of the BMP maintenance that was completed last week. We are open to further collaboration and welcome any recommendations for our continued compliance. Please let us know if you have any questions. Thank you, Rachel Marriott Office Manager Custom Excavating by Dean Larson Inc. DBA: Trails End Recovery 2060 SE Airport Lane Warrenton, OR 97146 P: (503) 861-6030 F: (503) 861-4341 www.customexcavatinginc.com DISCLAIMER: CONFIDENTIALITY NOTICE TO RECIPIENT This email (including attachments) is covered by the Electronic Communications Privacy Act, 18 U.S.C. 25102521, is confidential and may be legally privileged (including, without limitation, attorney-client privilege). If you are not the intended recipient, you are hereby notified that any retention, dissemination, distribution or copying of this communication is strictly prohibited. If you have received this message in error, please notify the sender, and delete it immediately. On Fri, Jan 5, 2024 at 2:04PM Klemesrud, Jon <Klemesrud.Jon@epa.gov> wrote: Page 92 of 103 Trails End Recovery 2060 SE Airport Lane Warrenton, OR 97146 2024 CWA NPDES ORR127194 Inspection Report Page 93 of 103 2024 CWA NPDES ORR127194 Inspection Report BMP Maintenance done Jan. 3, 2024 - Pond 1 The absorbent pads, absorbent socks and biobags were replaced. Page 94 of 103 2|Page 2024 CWA NPDES ORR127194 Inspection Report BMP Maintenance done Jan.4 & 5, 2024- Pond 1 Thursday 1/4/24 we skimmed Pond 1, cleaned the baffles, and added more rock. Friday 1/5/24 we finished maintenance on the baffles. Page 95 of 103 3|Page 2024 CWA NPDES ORR127194 Inspection Report BMP Maintenance done Jan. 3, 2024 - Pond 2 The biobags were replaced on the SE side of Pond 2 to slow the incoming runoff. We replaced and added additional absorbent pads. Page 96 of 103 4|Page 2024 CWA NPDES ORR127194 Inspection Report BMP Maintenance done Jan. 4 & 5, 2024 - Pond 2 Thurs 1/4/24 we cleaned up the bark around the pond, refreshed the biobags, and did some maintenance on the baffles. Fri 1/5/24 We expanded the rock around the pond, added biochar bags to the baffles, and added berms on the west and southeast sides to channel runoff to the north side of the pond to increase settling time. We also added log barriers around the southeast side to prevent equipment or vehicles from parking nearby. Page 97 of 103 5|Page 2024 CWA NPDES ORR127194 Inspection Report BMP Maintenance done Jan. 4 & 5, 2024 - Pond 2 The lighter colored rock is the new berm added to channel the water. Page 98 of 103 6|Page 2024 CWA NPDES ORR127194 Inspection Report BMP Maintenance done Jan. 3, 2024 - Pond 3 All absorbent pads were replaced and we added additional rock around Pond 3a. Page 99 of 103 7|Page 2024 CWA NPDES ORR127194 Inspection Report BMP Maintenance done Jan. 5, 2024 - Pond 3 Friday 1/5/24 we dug out Pond 3a chamber and changed the absorbent pads again, dugout and replaced the inlet rock, and added rock to the road. Cleaned up small amount of sheen adjacent to Pond 3a. Page 100 of 103 8|Page 2024 CWA NPDES ORR127194 Inspection Report BMP Maintenance done Jan. 3, 2024 - Pond 4 Pond 4 - added additional absorbent pads Page 101 of 103 9|Page Sheen from the recent oil change on the Edge Air Screener (adjacent to inlet to Pond 3) was cleaned up with absorbent pads. Additional rock was added around Pond 3. 2024 CWA NPDES ORR127194 Inspection Report Page 102 of 103 10 | P a g e 2024 CWA NPDES ORR127194 Inspection Report Small leak from the 500 loader was cleaned up, the machine hoses were capped and it was moved to the shop for repairs. Page 103 of 103 11 | P a g e