Document 6bpmvn6wOBnY6N851147bwm3

EPA REGION 10 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 11/22/2024 10:13 AM (PT) Announced: No 11/22/2024 03:50 PM (PT) Access: Granted 50F, Partly Cloudy Water Clean Water Act, NPDES, Stormwater - Industrial Compliance Evaluation Inspection Permittee Name Facility or Site Name Facility Physical Address City, State, Zip Code County Facility GPS Coordinates Rosboro, LLC Rosboro Lumber Company - Springfield Facility 2509 Main Street Springfield, Oregon 97477 Lane 44.043527, -122.991031 FRS ID Permit Number SICs 110000771200 ORR227182 2411 (Log Storage & Handling) 2421 (General Sawmills & Planing Mills) 2439 (Structural Wood Members, not elsewhere classified) Lead Inspector: RAYMOND ANDREWS Date: 2025.01.14 07:49:29 -08'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: Contreras, Peter Peter Contreras EPA Region 10 Digitally signed by Contreras, Peter Date: 2025.01.14 08:03:42 -08'00' contreras.peter@epa.gov (206) 553-6708 Rosboro Lumber Company - Springfield Facility Permit # ORR227182 SECTION I - Opening Conference I arrived at the Rosboro Lumber Company - Springfield Facility (the "Site" or "Facility"), located at 2509 Main Street, Springfield, Oregon, at 10:13 AM (PT) on 11/22/2024 for an unannounced inspection. I presented my credentials to Jim Daniels and informed him I was there to conduct an inspection to determine compliance with the Clean Water Act (CWA) and the facility's Oregon Department of Environmental Quality (ODEQ) 1200-Z permit for industrial stormwater, permit # ORR227182. This report is based on information supplied by Mr. Daniels, my direct observations, and records and reports maintained by the permittee. In addition, information gathered prior to or after the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization Attendee Name Present in Present in Title Opening Conf. Closing Conf. EPA Region 10 Raymond Andrews Lead Inspector Yes Yes Rosboro Lumber Jim Daniels Environmental Yes Yes Company Supervisor Facility Information Responsible Official? Jim Daniels Type of Operation? Lumber mill Years in Operation? Been in operation under Rosboro since 1938 Size of Facility? The total size of the site, including log storage, is approximately 104 acres. Is property leased? The facility is a mix of owned and leased property. Shifts/Days of Operations? The facility has approximately 300 employees. The sawmill runs, on average, 4 days a week, 10 hours per day. Industrial activities exposed to stormwater? Logs, finished lumber, package products, and heavily equipment, i.e., forklifts, etc., are stored outside. Personnel conducting Mr. Daniels is the Environmental Supervisor and performs all inspections and inspections/sampling? conducts all sampling. How many Outfalls/Sampling locations does the facility have? The facility has 12 outfalls but not all of them are monitored. Six of the outfalls are considered "substantially identical" to one or more of the other six outfalls. The facility is only required to monitor Outfalls 001, 010, 013, 018, 023, 010, 018, and 033. However, the facility has a monitoring waiver for most parameters at several of its outfalls. The only outfalls that are monitored are 001 for total copper (Cu) & chemical oxygen demand (COD), and 013 for total suspended solids (TSS), total copper (Cu) & chemical oxygen demand (COD). Receiving Waters? The facility's monitoring waiver ends on June 30, 2025, and sampling must recommence on July 1, 2025. The facility has two proximal receiving waters, Mill Race Creek, and the Q Street ditch, both flow to the Willamette River. The Q Street ditch receives water from Outfalls 001, 002, 005, 006, 009, 010, 011, 013, 023, 033, and 101. Mill Race Creek received water from Outfall 018. 2 of 5 Rosboro Lumber Company - Springfield Facility Permit # ORR227182 SECTION II - Observations Location: Swale/Outfall 001 AOC: Yes Observation #: RA1-OB-001 Date: 11/22/2024 Weather: 50F, Partly Cloudy Outfall 001 is in the bioswale used to contain and guide stormwater. Biochar bags are placed around the inlet as a Best Management Practice (BMP) to mitigate the discharge of pollutants, i.e. copper, as part of the facility's Tier 2 action plan. The biochar bags needed maintenance. The upper right segment of the biochar bags is allowing water to pass without filtration through the bags. Photo 1. IMG-202411221121172117150014.jpg SECTION III - Records Review Records may not be in sequential order. Record: DMR Reports Ref #: RA1-RR-007 Reviewed By: Raymond Andrews AOC: No Reviewed Date: 01/08/2025 Post inspection, I requested to review the facility's Discharge Monitoring Reports (DMRs) from 1Q 2022 through 4Q 2024. The facility provided the following DMRs: Jul - Sep 2022 (1Q) Oct - Dec 2022 (2Q) Jan - Mar 2022 (3Q) Jan - Mar 2023 (3Q) I pulled all the DMRs not provided by the facility from the Oregon Department of Environmental Quality's (ODEQ) "Public Submittal Records" webpage, https://ordeq-edmspublic.govonlinesaas.com/pub/pub-rcd/home. I did not note any areas of concern. Record: Other - Routine Monthly Facility Inspections Ref #: RA1-RR-006 Reviewed By: Raymond Andrews AOC: No Reviewed Date: 12/31/2024 Post inspection, I reviewed the facility's Routine Monthly Inspections from January 2023 through November 2024. The inspections are maintained on EXCEL spreadsheets, but they are comprehensive and appear to cover all permit requirements. I did not note any areas of concern. Record: Other - Training Records AOC: No Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Reviewed Date: 11/22/2024 At the time of inspection, I reviewed annual training records for 2021 through 2024. I did not note any areas of concern. Record: Other - ODEQ Monitoring Waiver Letter AOC: No Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 11/22/2024 At the time of inspection, I reviewed the Monitoring Waiver Letter from the Oregon Department of Environmental Quality (ODEQ) to the facility based on a monitoring waiver request the facility submitted through ODEQ's on-line portal on March 2, 2023. The ODEQ letter waived monitoring of most parameters of the facility's 5 monitoring locations, 001, 010, 013, 018, and 023. The waiver letter still required monitoring for total copper and Chemical oxygen demand (COD) at locations 001, and TSS, total copper and COD at location 013. 3 of 5 Rosboro Lumber Company - Springfield Facility Permit # ORR227182 Record: Other - Corrective Action Tier 2 Report AOC: No Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 11/22/2024 At the time of inspection, I reviewed the facility's Corrective Action Tier 2 Report, dated November 7, 2023. The Tier 2 Corrective Action was required because the facility exceeded the geometric mean of total suspended solids (TSS) benchmark for the 2022 through 2023 monitoring year. The facility reported a geometric mean of 284 mg/L at Monitoring Location SW-013 while the corresponding benchmark value for TSS is 100 mg/L. The facility estimated an average of 321 pounds of aerial particulate debris is generated monthly immediately west of the veneer ditch. Due to prevailing winds from the west, and through visual confirmation, the facility and its contractor, PBS, determined a significant portion of aerial particulate debris appears to be depositing into the veneer ditch. Particulate debris deposition resulting from these typical industrial operations is assumed to be contributing to excessive TSS levels in SW-013. On-site treatment to reduce TSS included closure of the veneer ditch via a ducted manifold and subsurface stormwater drainage pipe connecting to an existing stormwater drainage confluence point and inclusion of in-line TSS removal technologies implemented immediately east of SW-013 to capture and treat all stormwater collected from Basin C1. Future TSS permit benchmark exceedances will be prevented through a combination of source control and physical screening of particulate debris. Record: Other - SWPCP Addendum for Tier 2 Action AOC: No Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 11/22/2024 At the time of inspection, I reviewed the facility's SWPCP Addendum for Tier 2 Corrective Action, dated December 31, 2024. The Tier 2 Corrective Action was required because the facility exceeded the geometric mean total copper benchmark for the 2021 through 2022 monitoring year. The facility reported a geometric mean of 0.022 mg/L at Monitoring Location 001 while the corresponding benchmark value for total copper is 0.015 mg/L. To reduce the concentration of total copper, the Tier 2 Correction Action chose to install biochar filled filter socks upstream, and around the inlet of, Outfall 001. Record: Other - Stormwater Pollution Control Plan (SWPCP) AOC: No Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 11/22/2024 At the time of inspection, I reviewed the facility's Stormwater Pollution Control Plan (SWPCP), dated September 4, 2024. I did not note any areas of concern. 4 of 5 Rosboro Lumber Company - Springfield Facility Permit # ORR227182 SECTION IV - Sampling Activities No sampling was conducted. SECTION V - AREAS OF CONCERN Areas of Concern may not be in sequential order. The presentation of Areas of Concern does not constitute a formal compliance determination or violation. AOC Reference #: RA1-OB-001 Location: Swale/Outfall 001 Permit Requirement Schedule A.2.a of the permit states, in part, "The permit registrant must select, design, install, implement and Maintain (emphasis added) control measures, including all best management practices (BMPs)..." AOC: Biochar bags (BMP) needed maintenance because they were allowing unfiltered water to pass. SECTION VI - Closing Conference I held a closing conference with Mr. Daniels at 03:50PM (PT) on 11/20/2024 for the inspection. During the closing conference, I discussed any observations and Areas of Concern I identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - List of Appendices 1. Photo Log 5 of 5 APPENDIX 1: Photo Log SWPCP signature page 11/22/2024 10:51 AM No CBI 44.04219451, -122.98983568 No PII IMG-20241122105113511373977.jpg Photographer: Raymond Andrews Log Yard 11/22/2024 11:05 AM No CBI 44.04205617, -122.98958469 Stacked logs waiting for milling. No PII IMG-20241122110524524106818.jpg Photographer: Raymond Andrews Storage Area near Production Building IMG-20241122110556556109969.jpg 11/22/2024 11:05 AM No CBI No PII Photographer: Raymond Andrews 44.04197833, -122.98835305 Laminated stock, i.e., Lam Stock, that did not make the grade and will be re-cut to dimensional lumber. Hogg Fuel Hogg Fuel Storage Area IMG-2024112211094094096606.jpg 11/22/2024 11:09 AM No CBI No PII Photographer: Raymond Andrews 44.0421393, -122.98972186 Hogg fuel piles that have been delivered and is waiting to be used in the boilers. Water Overflowing Biochar Bag Bioswale/Outfall 001 IMG-202411221121172117150014.jpg 11/22/2024 11:21 AM No CBI No PII Photographer: Raymond Andrews 44.04590985, -122.98660826 Bioswale with biochar bags around inlet as required by part of the Tier 2 corrective action plan. Biochar bags need maintenance. Water that enters the inlet flows out through the white pipe and discharges to the Q Street ditch. Samples are collected from the center of the biochar bags using a bottle on a long pole. Row of Orenco Filters Orenco Filters IMG-20241122113008308163948.jpg 11/22/2024 11:30 AM No CBI No PII Photographer: Raymond Andrews 44.04425762, -122.98935753 The iron grate covers a sediment catch basin. There are four Orenco filters in the foreground. The flow is split equally through the four filters and comes back together to enter underground to an "AquaSwirl" system. NOTE: The Aqua-Swirl Stormwater Treatment System is a custom engineered, postconstruction flow-through water quality device designed to remove coarse sediment, debris and freefloating oil by utilizing hydrodynamic separation technology. (Definition is from the AquaShield Website, Aqua-Swirl, Stormwater Hydrodynamic Separator - AquaShield, Inc., accessed 1/10/2025.) Aqua-Swirl Inlet Outfall 013 Aqua-Swirl 11/22/2024 11:35 AM No CBI 44.04589363, -122.99048206 Aqua-Swirl inlet in foreground. No PII IMG-202411221135203520132602.jpg Photographer: Raymond Andrews Aqua-Swirl Inlet Outfall 013 Outfall 013 11/22/2024 11:35 AM No CBI 44.04586392, -122.99000677 Outfall 013 in relation to Aqua-Swirl. No PII IMG-202411221135563556145852.jpg Photographer: Raymond Andrews Outfall 013 11/22/2024 11:36 AM No CBI 44.04584046, -122.99002219 Outfall 013 sampling point. No PII IMG-20241122113601361156832.jpg Photographer: Raymond Andrews Outfall 023 11/22/2024 11:39 AM No CBI 44.04585255, -122.99003692 Outfall 023 sampling point. No PII IMG-202411221139263926175021.jpg Photographer: Raymond Andrews Outfall 033 11/22/2024 11:41 AM No CBI 44.04582095, -122.99236734 No PII IMG-202411221141334133201438.jpg Photographer: Raymond Andrews Outfall 003 11/22/2024 11:41 AM No CBI 44.04584904, -122.99164982 Flow in relation to Outfall 003 No PII IMG-202411221141404140189201.jpg Photographer: Raymond Andrews Outfall 003 Sampling Point IMG-202411221143134313131416.jpg 11/22/2024 11:43 AM No CBI No PII Photographer: Raymond Andrews 44.04569543, -122.99223538 Outfall 003 is sampled from the grate to the left of the outfall. Outfall 005 Discharge Pipe Outfall 005 IMG-202411221149214921182370.jpg 11/22/2024 11:49 AM No CBI No PII Photographer: Raymond Andrews 44.04545265, -122.99376482 Outfall 005 is outside of the property fence boundary. Overflow Pipe Evaporation pond IMG-20241122120148148112174.jpg 11/22/2024 12:01 PM No CBI No PII Photographer: Raymond Andrews 44.04517103, -122.99642254 Evaporation pond, photo 1. The white pipe in the background is for overflow. If the pond's water level gets too high, water overflows into the pipe and flows west to discharge out of Outfall 006 into the city's sewer system. Outfall 006 is not a monitoring point. Overflow Pipe Evaporation pond 11/22/2024 12:01 PM No CBI 44.04481117, -122.99635071 Evaporation pond, photo 2. No PII IMG-20241122120158158117976.jpg Photographer: Raymond Andrews Outgoing Product Storage Yard IMG-202411221202022270959.jpg 11/22/2024 12:02 PM No CBI No PII Photographer: Raymond Andrews 44.04433259, -122.99560422 Packaged "glulam beams". NOTE: A "glulam beam" is a structural engineered wood product made up of layers of dimensional lumber bound together with long-lasting, moisture-resistant structural adhesives. (Definition is from the HPD Consultant, inc. website, https://www.hpdconsult.com/what-isglulam-beam/, accessed 1/10/2025.)