Document 91yezmdNQ47EYDdJ7NGj0ZRZ7

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 05/01/2023 09:00 AM (PT) 05/01/2023 02:40 PM (PT) 50, Overcast Water Clean Water Act, NPDES, Stormwater - Industrial Compliance Evaluation Inspection Permittee Name Site Name Site Physical Address City, State, Zip Code County Facility GPS Coordinates Mailing Address City, State, Zip Code Interstate Concrete & Asphalt Interstate Concrete & Asphalt - Pendleton Interstate Concrete & Asphalt - Grubbs Emigrant Road, County Road 937 Pendleton, OR 97801 Umatilla Pendleton - 45.671760, -118.729524 Grubbs - 45.623354, -118.627895 P.O. Box 3366 Spokane, Washington 99220 FRS ID Permit Numbers SIC ORT9756163775 Pendleton - ORR05IA01 Grubbs - ORR05IA00 3273 (Ready mix concrete mfg) - Pendleton 1429 (Other crushed & broken stone mining & quarrying (pt)) - Grubbs Lead Inspector: RAYMOND ANDREWS Date: 2024.07.02 15:01:40 -07'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2024.07.02 17:09:09 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA Region 10 contreras.peter@epa.gov (206) 553-6708 Interstate Concrete and Asphalt - Pendleton Site ORR05IA01 Interstate Concrete and Asphalt - Grubbs Site ORR05IA00 SECTION I - Opening Conference I arrived at the Interstate Concrete & Asphalt - Pendleton (the "Site" or "Facility"), located on Emigrant Road, County Road 937, Pendleton, Oregon, at 09:00 AM (PT) on 05/01/2024 for an announced inspection. I was accompanied by Emily Siangkam, an Inspector in Training, who was there to observe inspection procedures. I presented my credentials to Steven Warnock and informed him I was there to determine compliance with the Clean Water Act (CWA), and the facility's Oregon Muli-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity, permit numbers, ORR05IA01 (Pendleton Site) and ORR05IA00 (Grubbs Site). This report is based on information supplied by Mr. Warnock, direct observations made by me and Ms. Siangkam, and/or a review of records and reports maintained by the facility. In addition, information gathered either prior to or after the Inspection from a review of EPA, State, and/or public records may be included in this report. American Rock Products, the sites' operator, is a subsidiary of CRH, a publicly traded company. This is a combined report for the primary site (Pendleton) and the quarry site (Grubbs). Attendees Organization Attendee Name Title Present in Opening Conf. EPA Region 10 Raymond Andrews Lead Inspector Yes Present in Closing Conf. Yes EPA Region 10 Emily Siangkam Inspector Yes Yes American Rock Steve Warnock Site Manager Yes Yes Products ARH America's Garrett Sullivan Senior Environmental Yes Yes Materials Specialist Site Information Responsible official Personnel conducting inspections/sampling Sampling locations Years in operation Number of employees Receiving Water Number/location of Stormwater Outfalls BMPs/Stormwater Treatment Steven Warnock; steve.warnock@americanrockproducts.com Mr. Warnock conducts sampling, monitoring, and the annual SWPPP training for employees. One at each location, monitoring monthly but report quarterly American, Rock Products, a subsidiary of CRH, has been operating the site since 2019; however, the site has been used for much longer, but the exact start date is unknown. The sites average a combined 7 - 10 employees. The primary production site (Pendleton) operates from 7:00am until 3:00pm Monday through Friday. The excavation site (Grubbs) operates when the primary site needs additional gravel for operations. Umatilla River There is one outfall at each site, but the sites are graded and bermed to maintain stormwater on-site. The sites do not treat stormwater. Most water infiltrates. Berms and grading are used to keep stormwater on-site. Water from truck washing is contained in an adjacent sump and retention pond. Page 2 of 5 Interstate Concrete and Asphalt - Pendleton Site ORR05IA01 Interstate Concrete and Asphalt - Grubbs Site ORR05IA00 Industrial activities exposed to stormwater Gravel crushing and washing is exposed to stormwater. The hot mix asphalt and ready-mix production machines equipment is also exposed to stormwater. Industrial Sector Sector J: Mineral Mining and Dressing Type of Operation The sites produce asphalt and concrete mix. Is property owned or The sites are primarily owned; however, a small portion of land is leased from the leased? Umatilla tribe. Size of Facility 34.75 acres - Pendleton site, 35 acres - Grubbs site Is the SWPPP team present Mr. Warnock and Mr. Sullivan are members of the SWPPP team. The SWPPP team is designated by position. Type of materials The site stores input material such as gravel and aggregate outdoors, as well as and/or vehicles stored packaged Ready Mix concrete product. The site also stores heavy equipment such as outdoors dump trucks and bucket loaders outdoors. What parameters is the facility monitoring? The facility monitors for total suspended solids (TSS), pH, and Nitrates/Nitrites. Samples are sent to a contract lab for analysis when there is a discharge. The only parameter the site analyzes is pH. What is the facility's The sites monitor monthly. monitoring frequency? SECTION II - Observations No Observations were made that constitute an Area of Concern. SECTION III - Records Review Records may not be in sequential order Record: Other - Facility Quarterly Visual Inspection Reports Ref #: RA1-RR-005 Reviewed By: Raymond Andrews AOC: No Reviewed Date: 05/01/2024 At the time of inspection, I reviewed Quarterly Visual Inspection (QVI) Reports for 2022 and 2023 for both the Grubbs (ORR05IA00) and Pendleton (ORR05IA01) sites. I did not note any areas of concern. Record: Annual Reports AOC: No Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 05/01/2024 At the time of inspection, I reviewed the 2022 and 2023 Annual Reports for both the Grubbs (ORR05IA00) and Pendleton (ORR05IA01) sites. I did not note any areas of concern. Record: Other - Monthly Site Inspection Reports AOC: No Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 05/01/2024 At the time of the inspection, I reviewed monthly site inspection reports from January 2022 through December 2023 for both the Grubbs (ORR05IA00) and Pendleton (ORR05IA01) sites. The inspection reports appear complete and include the items required by the permit. I did not note any areas of concern. Record: Other - EPA's Integrated Compliance Information System (ICIS) Database AOC: No Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 05/01/2024 At the time of inspection, I reviewed information in EPA's ICIS database from June 2019 through May 2024 for both the Grubbs (ORR05IA00) and Pendleton (ORR05IA01) sites. I did not note any areas of concern. Page 3 of 5 Interstate Concrete and Asphalt - Pendleton Site ORR05IA01 Interstate Concrete and Asphalt - Grubbs Site ORR05IA00 Record: SWPPP Ref #: RA1-RR-001 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 05/01/2024 At the time of the inspection, I reviewed the facility's Stormwater Pollution Control Plans (SWPPPs) for both the Grubbs (ORR05IA00) and Pendleton (ORR05IA01) sites, both dated June 1, 2021. Pendleton The SWPPP for the Pendleton site indicates the site conducts impaired water monitoring but does not give specifics of monitoring procedures or timelines. Attachments listed in the body of the SWPPP were not included in the SWPPP binder. The SWPPP listed the incorrect number for the National Response Center. The Pendleton SWPPP was missing the following items: 1. SWPPP Certification signature 2. Employee Training records 3. Legible Site map - The text on the site map is too small to read so it's not possible to determine if it has all the elements required by the permit. The General Location map was adequate. Grubbs The SWPPP for the Grubbs site indicates the site conducts impaired water monitoring but does not give specifics of monitoring procedures or timelines. The SWPPP listed the incorrect number for the National Response Center and listed numbers for the Idaho Department of Environmental Quality (IDEQ) but not the Oregon Department of Environmental Quality (ODEQ) even though the site is in Oregon. The Grubbs SWPPP was missing the following 1. SWPPP Certification signature 2. Stormwater Control Measures (SCMs) 3. Employee Training records SECTION IV - Sampling Activity 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-RR-001 Records Review: SWPPP Permit Requirement Permit Part 6.2.7 states, "Signature Requirements. You must sign and date your SWPPP in accordance with Appendix B, Subsection 11." AOC: Both the Pendleton and Grubbs site SWPPPs was missing the SWPPP Certification signature. AOC Reference #: RA1-RR-001 Records Review: SWPPP Permit Requirement Permit Part 6.2.5.1.e.iv of the permit states, in part, "You must document the following in your SWPPP...A log of the dates on which specific employees received training." AOC: Both the Pendleton and Grubbs site SWPPPs were missing Employee Training documentation. Page 4 of 5 Interstate Concrete and Asphalt - Pendleton Site ORR05IA01 Interstate Concrete and Asphalt - Grubbs Site ORR05IA00 AOC Reference #: RA1-RR-001 Records Review: SWPPP Permit Requirement Permit part 6.2.2.3 of the permit states, in part, "Your SWPPP must include the following...Site map. Provide a map showing..." AOC: The Pendleton SWPPP site map was illegible. The text on the site map is too small to read so it's not possible to determine if it has all the elements required by the permit. AOC Reference #: RA1-RR-001 Records Review: SWPPP Permit Requirement Part 6.2.4 of the permit states, in part, "Description of Stormwater Control Measures to Meet TechnologyBased and Water Quality-Based Effluent Limits. You must document the location and type of stormwater control measures you have specifically chosen and/or designed..." AOC: The Grubbs site SWPPP did not include Stormwater Control Measures (SCMs). AOC Reference #: RR-001 Records Review: SWPPP Permit Requirement Table 8.J-1 of the permit shows the sites in Subsector J must conduct indicator monitoring for Polycyclic Aromatic Hydrocarbons (PAHs). AOC: Mr. Garrett stated the site is supposed to be conducting PAH monitoring; however, there was no mention of indicator monitoring in the SWPPP. SECTION VI - Closing Conference I held a closing conference with facility personnel at 02:15 PM (PT) on 05/01/2024 for the inspection. During the closing conference, I discussed my observations and the 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 Page 5 of 5 APPENDIX 1: Photo Log All photos were taken by Lead EPA Inspector, Ray Andrews, during the inspection. Photos were not manipulated beyond minor cropping for sizing and labels or callouts to draw attention to the subject of the photo. All photos taken during the inspection are included in the Photo Log; however, only photos that support an Area of Concern are included in the inspection report. Pendleton P1010918 - Site Map P1010919 - Sign at Facility Entrance P1010920 - Sump for Truck Wash P1010921 - Truck Wash P1010922 - Retention Pond for Truck Wash Sump Overflow P1010923 - Aggregate Gravel Pile P1010924 - Gravel Piles and Working Road P1010925 - Gravel Wash P1010926 - Interior Gravel Berm Approximately 50 feet from Exterior Berm P1010927 - Exterior Berm Adjacent to River Grubbs P1010928 - Gravel-Lined Pit