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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 05/17/2023 9:00 AM (PT) Announced: Yes 05/17/2023 11:30AM (PT) Water Clean Water Act, NPDES, Wastewater - Industrial CEI - Compliance Evaluation Inspection Permittee Name Facility Physical Address City, State, Zip Code Facility GPS Coordinates Facility Owner Facility Owner Address City, State, Zip Code Sierra Pacific Industries - Eugene Plant 90201 Highway 99 North Eugene, Oregon 97402 44.110581 N -123.179096 W Sierra Pacific Industries P.O. Box 496028 Redding, California 96049 FRS ID Permit # / ODEQ File # SIC Code 110006697743 ORR0022985 / 80207 2421 - Sawmills and Planing Mills, General Inspection Contacts: Organization EPA Region 10 Oregon Department of Environmental Quality Oregon Department of Environmental Quality Sierra Pacific Industries - Eugene Plant Sierra Pacific Industries Sierra Pacific Industries - Eugene Plant Sierra Pacific Industries - Eugene Plant Name Title Jon Klemesrud Lead Inspector Andy Ullrich Inspector/Compliance Officer Brad Eagleson Inspector/Compliance Officer Brandon Mainard Environmental Coordinator Jeremy Higgins Environmental Director Matt Bosch Division Manager Jason Nelson Staff / Sampler Present in Opening Conf. Yes Yes Yes No Yes Yes No Present in Closing Conf. Yes Yes Yes No Yes Yes No EPA Inspector Signature/Date JON KLEMESRUD Jon Klemesrud Digitally signed by JON KLEMESRUD Date: 2023.07.17 15:16:06 -07'00' Supervisor Signature/Date PETER CONTRERAS Date: 2023.07.17 15:23:09 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras, Chief FDDWES CWA NPDES Inspection Report ORR0022985 This inspection report is based on information supplied by conversations with Mr. Brandon Mainard, Mr. Jeremey Higgins, Mr. Matt Bosch, Mr. Jason Nelson, 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 review of EPA, State, and/or public records. SECTION I - INTRODUCTION Entry and Inspection Chronology I was joined on the inspection by Oregon Department of Environmental Quality (ODEQ) representatives Mr. Andy Ullrich and Mr. Brad Eagleson. To ensure staffing and availability, this inspection was announced one day prior. At approximately 9:50 AM on May 16, 2023, I called and left a voicemail with Mr. Brandon Mainard, Environmental Coordinator at the Sierra Pacific Industries - Eugene Plant. On the voicemail, I introduced myself and discussed that I had been asked to conduct a routine on-site inspection to assess compliance with the facility's coverage under ODEQ's Individual Wastewater Discharge Permit. I was able to reach Mr. Mainard by phone at approximately 1:00 PM, during our call Mr. Mainard welcomed the inspection but explained that he was currently out of state and attending a training event in California. Mr. Mainard discussed that he could assist by coordinating with Mr. Jeremy Higgins, Environmental Director with Sierra Pacific Industries. According to Mr. Mainard, Mr. Higgins was scheduled to be at the facility the following day. Following our call, Mr. Mainard later confirmed the inspection with Mr. Higgins and a start time of 9:00 AM on May 17, 2023. Mr. Ullrich, Mr. Eagleson and I arrived on-site at approximately 9:00 AM on May 17, 2023 and met with Mr. Higgins and also met Mr. Matt Bosch, Division Engineer at the Eugene Plant. At this time, we had our initial introductions and were then escorted to a conference room where we began the inspection with an opening conference. During the opening conference I presented my EPA credentials, discussed the purpose/expectations of the inspection, provided my business card and a copy of EPA's Small Business Resources Information Sheet. We began with a brief discussion regarding general roles/responsibilities and a brief history of facility operations. It was discussed that the facility was previously owned and operated by the Seneca Sawmill Company up until the fall of 2021, when it was purchased by Sierra Pacific Industries. We also discussed recent (December 2021 - January 2023) self-reported exceedances as outlined in Attachment A, 5-Year Reported Effluent Exceedances. The inspection consisted of an opening conference, a walk-through of the wastewater collection areas and related infrastructure and concluded with a closing conference. During the closing conference, we discussed our walkthrough observations, potential areas of concern and EPA's general inspection report/follow-up process. As records weren't available for review at the time of inspection due to Mr. Mainard's absence, a follow-up records review/request occurred post-inspection as discussed in Section III of this inspection report. We were accompanied throughout the inspection walk-through by Mr. Higgins and Mr. Bosch. Facility representative Mr. Jason Nelson was only present for a portion of the walk-through. A post-inspection call occurred with Mr. Mainard May 26, 2023. Permit/Compliance History Sierra Pacific Industries - Eugene Plant is permitted to discharge to the A-1 Amazon Channel under an individual ODEQ Waste Discharge Permit (ORR0022985). The Permit was issued to the Seneca Sawmill Company (prior owner) on September 30, 2006. According to ODEQ, the permit was administratively continued after expiring on August 31, 2011. The facility also operates under a separate ODEQ issued Industrial Stormwater Discharge Permit (1200-Z). On November 10, 2022, the Facility submitted a Noncompliance Reporting Form to ODEQ for "missed sample days and below benchmark pH levels during the November 1, 2021 - July 1, 2022 timeframe (Attachment B). According to file documentation, the last ODEQ inspection for ORR0022985 permit compliance occurred on August 3, 2017, while being owned and operated by the Seneca Sawmill Company. Page 2 of 34 SECTION II - OBSERVATIONS CWA NPDES Inspection Report ORR0022985 Site Review Sierra Pacific Industries - Eugene Plant (hereinafter referred to as the "Facility") operates as a sawmill and planing mill within a northwest industrial area of Eugene, Oregon. See Attachment C, Aerial Map, for a Facility overview from Google Earth. The Eugene Plant is one of several facilities owned and operated by Sierra Pacific Industries. According to the Facility's website (www.spi-ind.com), "Sierra Pacific Industries is a third-generation, family-owned forest products company based in Anderson, California. SPI owns and manages more than 2.4 million acres of timberland in California, Oregon and Washington and is one of the largest U.S. lumber manufacturers." Operations at the Facility include log receiving, log handling and storage, log debarking, saw milling and planing, and a cogeneration facility. Industrial wastewater sources from the Facility consist of log deck sprinkler runoff, vehicle wash water and boiler/cogeneration blowdown. Wastewater is directed toward a series of collection ditches and settling/retentions ponds that eventually flow to the Facility's outfall (Outfall 001) for discharge to the A-1 Channel which flows into Amazon Creek at River Mile 3.9. As outlined within Schedule A of the ORR0022985 Permit (Attachment D), the Facility is required to comply with the following seasonal discharge limitations: Monitoring requirements for the discharge limitations are outlined in Schedule B of the ORR0022985 Permit: For the inspection walk-through, we first traveled to the vehicle wash area. Photographs taken during the walkthrough are attached to this inspection report as Attachment E, Photograph Log. Page 3 of 34 Walk-Through Observations: CWA NPDES Inspection Report ORR0022985 Location: Vehicle Wash Area Observation #: OB-01 We first toured the Facility's designated vehicle wash area located near the eastern perimeter (Photo 1). This area is located on the north end of the facility's maintenance shop. At this location, a variety of Facility vehicles are washed as needed, generally for the removal of accumulated mud/sawdust. Vehicles are washed within a paved area utilizing a hose station that is plumbed with fresh water. No soap or detergents are used in the washing. Spent wash water (and removed debris) primarily travels to the north as sheet flow and enters an eastern drainage channel located within the property. A single catch basin is also located in the southwest corner of the wash area to also capture wash water from the area (Photo 2). The catch basin also discharges to eastern drainage channel via piping. It was discussed that the eastern drainage channel continues north briefly before it is piped underground and then resurfaces southeast/east of the log yard where it also receives log deck sprinkler runoff in numerous entry points. The drainage channel travels north along the eastern perimeter and eventually enters a settling pond which discharges to the A-1 Channel as Outfall 001. At the time of inspection, we observed the paved wash area to be clean and free of debris. Accumulated sediment/ material was observed within the vegetated receiving channel. As a best management practice (BMP), absorbent booms to remove oils/grease were observed to be placed along the entrance to the drainage channel, in several areas across the channel, and around the entrance to the single catch basin. According to Mr. Bosch, the booms are replaced as needed and accumulated debris within the drainage channel is removed as needed. Location: Settling Pond & Outfall 001 Observation #: OB-02 Following our time at the vehicle wash area, we traveled to the Facility's settling pond and Outfall 001 location (Photo 3), located approximately 650 yards north of the vehicle wash area and within the northeastern portion of the property, just south of E. Enid Road. The primary influent to the settling pond is located on the south end of the pond where it receives influent flow from the eastern drainage channel, which primarily receives flow from the log deck sprinkler system but also includes vehicle wash water flow when utilized. Blowdown from the boiler/cogeneration facility enters at the north end of the settling pond via a single white influent pipe, at a location near the pond's discharge (Photo 4). From this location at the north end of the pond, we observed absorbant booms placed near the discharge and the Outfall 001 structure and concrete weir (Photo 5). At this Outfall 001 location, water discharges from the settling pond to a drainage ditch that enters the A-1 channel (receiving water). According to Mr. Bosch and Mr. Higgins, the Facility's sample and flow monitoring location is within the receiving channel, downstream of the discharge structure (Photo 6 & Photo 7). Mr. Bosch said he would call and arrange for us to meet with Mr. Jason Nelson, Mr. Nelson is a Facility representative who primarily conducts discharge sampling and flow monitoring for permit compliance. We would meet during the next portion of the walk-through. At the time of inspection, the discharge from the pond was observed to be slightly turbid but generally clear, with no floating solids or debris. The concrete discharge structure was equipped with a drop-gate and was fitted with a perforated steel screen and a layer of wire mesh screening. The holes in the perforated screen were approximately 1-inch in diameter. The wire mesh screen was observed to be eroded and therefore did not extend down to water's surface (Photo 8). Location: Log Deck Runoff Collection & Boiler/Cogeneration Observation #: OB-03 Following our time at the north end of the settling pond and Outfall 001, we walked to the south end of the pond and observed the drainage channel's discharge piping into the settling pond (Photo 9). From this location we also observed northern portion of the drainage channel (Photo 10), northwest of the log yard. Absorbant booms were Page 4 of 34 CWA NPDES Inspection Report ORR0022985 installed across the channel in multiple locations to attempt to remove any oil/grease off the surface of the water. The drainage channel receives water coming off the log deck from the log spray down sprinkler system and the vehicle wash area (when in use). According to Mr. Bosch, the drainage channel receives an annual cleanout by a facilities crew where settled material is excavated from the channel. Post-inspection, Mr. Mainard later clarified that the drainage channel is in-fact cleaned our more frequently then annually and was last completed in February of 2023. We then walked the eastern perimeter of the log yard along the drainage channel (Photo 11 & Photo 12). Portions of the log yard are generally sloped to the east, log deck runoff travels as sheet flow to the eastern drainage channel. A concrete catchment area located in the eastern corner of property is engineered to allow for solids to settle from a large area of the log deck (Photo 13). Solids are retained prior to discharge to the drainage channel and removed as needed. According to Mr. Bosch, the log yard is swept daily beginning at 4:30 AM via the Facility's mechanical sweeper truck. After completing the walk-through of the eastern drainage channel, we met with Mr. Nelson southeast of the log scale to discuss the Facility's effluent sampling/monitoring procedures. Mr. Nelson displayed the Facility's pH meter, a Palm pH 220 manufactured by Extech Instruments (Photo 14). It was also discussed that effluent temperature was monitored using a handheld infrared thermometer. We followed Mr. Nelson back to his office area and observed the pH buffer solutions (Photo 15). According to Mr. Nelson, a two-point calibration is conducted using pH 7.00 and 4.00 buffer solutions. We also observed the Facility's portable flow monitoring device, a Global Water Flow Probe Model FP111. It was discussed that permit required monitoring for flow, pH, temperature and a visual observation for floating solids/debris is conducted and analyzed in-house, primarily by Mr. Nelson or another Facility representative from the log deck working area. For oil and grease and total suspended solids, samples are collected internally and then delivered to Analytical Laboratory Group (ALG) in Eugene, Oregon for analysis. We continued the walk-through to the Facility's boiler/cogeneration building and observed the various controls and chemicals utilized in the process (Photo 16 - Photo 18). The walk-through concluded after our time at the boiler/cogeneration building. We had a brief closing conference and traveled back to the main office and then departed the Facility. SECTION III - RECORDS REVIEW The following documents were reviewed as part of this inspection. Record: Discharge Monitoring Reports Ref #: RR-001 Prior to the inspection, I reviewed submitted DMRs over the past 5-years. This was generally completed by a review of an exceedance report generated by EPA's Integrated Compliance Information System (ICIS), physical DMR's were also reviewed. While being operated by Sierra Pacific Industries, the review noted self-reported effluent limit exceedances of pH on 12 occasions, as well as one exceedance of total suspended solids (monthly average) and one exceedance of temperature (weekly average). A copy of the exceedance report is attached to this report as Attachment A, 5-Year Reported Effluent Exceedances. When reviewing DMR's, it was noted that for two months, narrative within the "comments" section self-reported days that temperature monitoring did not occur, including one additional month for which sampling for oil and grease did not occur. The dates of missing temperature monitoring were reported as 11/25/2021, 11/26/2021, 11/28/2021, and two unspecified dates in May of 2022. Oil and grease sampling and analysis did not occur during the reporting month of April 2022. Page 5 of 34 Record: Monitoring Records Ref #: RR-002 CWA NPDES Inspection Report ORR0022985 At the time of inspection, during the opening conference I discussed that I would be requesting to review monitoring records associated with the permit, including bench sheet monitoring, analytical data and chain-ofcustody documentation. According to Mr. Bosch and Mr. Higgins, those records would be kept with Mr. Mainard and neither of them had access to those documents, and I would have to follow-up with Mr. Mainard postinspection in regard to those records. At the time of inspection, when observing the Facility's portable pH, temperature, and flow meter instruments we discussed calibration records and procedures with Mr. Nelson. Mr. Nelson discussed that the pH meter is calibrated routinely, the date of calibration for the pH meter is written on the outside of the pH meter box once calibrated (Photo 15). Based upon the dates listed on the box, the last calibration occurred on "5/8," (2023) past calibration dates also included "4/24, 4/10, 3/27, 3/13, 2/27, 2/13, 1/30, 1/16, 1/3, 12/12, 11/21, 11/7, 10/24, 10/10, 9/26 and 9/12." Mr. Nelson was not aware of any calibration records or procedures for the Facility's portable flow meter or handheld infrared thermometer. Following the inspection, on May 19, 2023, I sent Mr. Mainard a general follow-up email and requested sampling/monitoring documentation records as discussed during the opening conference. As a subsample, I requested sampling data for the months of July 2022, November 2021, and October 2020. See Attachment F, Post Inspection Email Correspondence. Mr. Mainard provided the records via email on June 1, 2023. Records provided included analytical reports including chain-of-custody documentation and monthly bench sheets. Data within the received records were consistent with the associated DMRs. 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: Exceedance of Discharge Limitations Regulation and/or Permit Requirement: Schedule A.1.a. within the permit lists the waste discharge limitations. pH range is listed as 6.5 - 8.5 (standard units). TSS is listed as 50 mg/L for May 1 - October 31, and 130 mg/L for November 1 - April 30. Temperature is listed as "shall not exceed 18 degrees Celsius as a weekly average." In regard to floating solids/debris the permit states, "none allowed (See Note 2)" Note 2 states that "debris is defined as anything that can be retained by a 5-mesh screen." Observation: As discussed earlier in this report, as part of this inspection I reviewed submitted DMRs over the past 5-years. This was generally completed by a review of an exceedance report generated by EPA's Integrated Compliance Information System (ICIS), and physical DMR's were also reviewed. While being operated by Sierra Pacific Industries, the review noted self-reported effluent limit exceedances of pH on twelve occasions, and one exceedance of total suspended solids (monthly average) and on exceedance of temperature (weekly average). A copy of the exceedance report is attached to this report as Attachment A, 5-Year Reported Effluent Exceedances. On November 10, 2022, the Facility submitted a Noncompliance Reporting Form to ODEQ for "missed sample days and below benchmark pH levels during the November 1, 2021 - July 1, 2022 timeframe" (Attachment B). The form noted the cause of the noncompliance as "lack of training. The company was going through a transition period of new employees and were not trained properly on taking temps daily and pH calibrations and Page 6 of 34 CWA NPDES Inspection Report ORR0022985 sampling." Corrective actions were stated as "since that time and moving forward training has been done and new pH machines have been purchased. Two qualified people that have been trained correctly to collect samples go together in order to make sure everything goes smoothly." Post inspection, during a follow-up call with Mr. Mainard on May 26, 2023, he discussed that since the inspection the Facility has made some operational changes and provided training to ensure proper sampling and calibration procedures are followed moving forward. AOC #2: Calibration of Monitoring Equipment Regulation and/or Permit Requirement: Schedule F, Section B.1. within the permit states: "The permittee must at all times operate and maintain all facilities and systems of treatment and control (and related appurtenances) that are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operations and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures." Observation: As discussed earlier in the report, at the time of inspection Mr. Nelson provided calibration records for the pH meter, which included the day/month written on the outside of box containing the pH meter. In general, the records showed the device was calibrated twice a month. I discussed that the device should be calibrated prior to each use (weekly) to ensure accurate measurements and reporting. I suggested that at a minimum, proper documentation of calibrations should include the full date and time, the name of the individual who performed the calibration, what buffer solutions were used and the results of the calibration. I also discussed that the Facility should consider a 3-point calibration or utilizing a 10.00 buffer solution as some of the reported values were above 7.00 s.u. It was also discussed that temperature is measured for permit compliance using a handheld infrared thermometer. No calibration procedures or previous calibration date was known. We discussed that the Facility consider monitoring temperature using a device that is immersed below the surface to ensure the reading is truly representative of the discharge. We also discussed that the device used for temperature monitoring should be verified against a National Institute of Standards and Testing (NIST) traceable thermometer. It was also discussed that Facility should ensure their portable flow monitoring device, a Global Water Flow Probe Model FP111 is calibrated to report accurate flows. In general, the concern is that at the time of inspection, the facility was lacking adequate quality assurance procedures to ensure accurate reporting of flow, pH and temperature. Post inspection, during a follow-up call with Mr. Mainard on May 26, 2023, he discussed that since the inspection the Facility has made some operational changes and provided training to ensure proper sampling and calibration procedures are followed moving forward. AOC #3: Outfall Screening Regulation and/or Permit Requirement: Schedule F, Section B.1. within the permit states: "The permittee must at all times operate and maintain all facilities and systems of treatment and control (and related appurtenances) that are installed or used by the permittee to achieve compliance with the conditions of this permit. Schedule A.1.a. within the permit lists the waste discharge limitations. In regard to floating solids/debris the Page 7 of 34 CWA NPDES Inspection Report ORR0022985 permit states, "none allowed (See Note 2)" Note 2 states that "debris is defined as anything that can be retained by a 5-mesh screen." Observation: As discussed earlier in the report, at the time of inspection we observed the concrete discharge structure to be equipped with a drop-gate and was fitted with a perforated steel screen and a layer of wire mesh screening. The holes in the perforated screen were approximately 1-inch in diameter, the wire mesh screen was observed to be eroded and therefore did not extend down to water's surface (Photo 8). Although no floating solids/debris we observed within the effluent at the time of inspection, the concern is that the Facility's screening that was installed meet the permit requirement was eroded and did not extend down to the water's surface in a manner that would prevent the discharge of floating solids/debris. Post inspection, during a follow-up call with Mr. Mainard on May 26, 2023, he discussed that since the inspection the Facility has ordered new screening that will be installed to replace the eroded screening that was observed. SECTION VI - CLOSING CONFERENCE Closing Conference Following the walk-through, a closing conference was held with Mr. Bosch and Mr. Higgins. We discussed our general observations, areas of concern and general inspection report transmittal procedures. I then thanked them for their time and assistance during the inspection and departed the Facility. SECTION VIII - LIST OF APPENDICES Attachment A - 5-Year Reported Effluent Exceedances Attachment B - Noncompliance Reporting Form (November 10, 2022) Attachment C - Aerial Map (Google Earth) Attachment D - ORR0022985 Permit Attachment E - Photograph Log Attachment F - Post Inspection Email Correspondence Page 8 of 34 CWA NPDES Inspection Report ORR0022985 ATTACHMENT A 5-Year Reported Effluent Exceedances Page 9 of 34 DMR Review Range: May 1, 2018 to May 1, 2023 Facility Information Facility Location Violation Code: E90 Last Resfresh Date ay 12, 2023 CWA NPDES Inspection Report ORR0022985 Last Formal Enforcement Action FRS Facility UIN 110006697743 LAT 44.111889 EA Identifier NPDES ID OR0022985 LONG -123.177778 Final Order Issued Permit Name SENECA SAWMILL COMPANY Major/Minor Minor Permit SIC Desc Sawmills And Planing Mills, Gene Water Body Name UNKNOWN TMDL ID Number and Months of Violations 49 11 Permit Information Original Issue Date 12/17/85 Issue Date 9/20/06 Effective Date 10/1/06 Expiration Date 8/31/11 Permit Status EXP EA Type Desc Month Outfall Parameter Code and Name NOV 2021 001 A 00530 Solids, total suspended DEC 2021 001 A 00400 pH JAN 2022 001 A 00400 pH FEB 2022 001 A 00400 pH MAR 2022 001 A 00400 pH MAR 2022 001 A 00400 pH APR 2022 001 A 00400 pH MAY 2022 001 A 00400 pH JUN 2022 001 A 00400 pH JUL 2022 001 A 00010 Temperature, water deg. centigrade JUL 2022 001 A 00400 pH SEP 2022 001 A 00400 pH JAN 2023 001 A 00400 pH JAN 2023 001 A 00400 pH DMR Value 160 6.3 5.5 10 5 9.4 5.8 5.6 4.6 19.1 2 5.4 6.2 9 Permit Limit 130 mg/L 6.5 SU 6.5 SU 8.5 SU 6.5 SU 8.5 SU 6.5 SU 6.5 SU 6.5 SU 18 deg C 6.5 SU 6.5 SU 6.5 SU 8.5 SU % Exceeda 23 3 15 18 23 11 11 14 29 6 69 17 5 6 Limit Type MO AVG DAILY MN DAILY MN DAILY MX DAILY MN DAILY MX DAILY MN DAILY MN DAILY MN WKLY AVG DAILY MN DAILY MN DAILY MN DAILY MX #V Due/Rec'd #DL 30 12/15 12/08 1 1/15 1/13 1 2/15 2/14 1 3/15 3/04 1 4/15 4/14 1 4/15 4/14 1 5/15 5/12 1 6/15 6/10 1 7/15 7/08 7 8/15 8/15 1 8/15 8/15 1 10/15 10/04 1 2/15 2/07 1 2/15 2/07 Page 10 of 34 1 CWA NPDES Inspection Report ORR0022985 ATTACHMENT B Noncompliance Reporting Form (November 10, 2022) Page 11 of 34 CWA NPDES Inspection Report ORR0022985 Oregon Department of Environmental Quality Noncompliance Reporting Form For all permit violations, including monitoring requirements. Use this form to report all instances of noncompliance except sanitary sewage overflows. Fill out all fields and sign. You may attach additional information to this report to explain the circumstances of noncompliance. This information may include but is not limited to maintenance records and monitoring results. FACILITY / CONTACT INFORMATION Name of Permittee:Seneca Sawmill Company Contact Name:Brandon Mainard Phone: 541-689-1011 Email:bmainard@spi-ind.com Date:11/10/2022 DEQ Permit #:OR0022985 DEQ File #: EPA ID #: OR Has non-compliance been corrected?: Yes No Expected time noncompliance is expected to continue: Date/Time Started: 11/01/21 Date/Time Stopped : 7/1/2022 Description of Noncompliance: Investigation shows missed sample days and below benchmark PH Levels AGENCY AND PUBLIC NOTIFICATION Was the non-compliance one of the following: A noncompliance which may endanger health or the environment Yes No An unanticipated bypass which exceeds any effluent limitation in this permit Yes No An upset which exceeds any effluent limitation in this permit Yes No Violation of a maximum daily discharge limitation Yes No If yes to any of the above, complete the rest of this section. OERS Number:n/a Signs posted? Where?:n/a Media contacted? Who?:n/a List any other steps taken to notify the public and/or state and federal agencies: n/a CAUSE(S) Cause or suspected cause(s): Lack of training. The company was going through a transition period of new employees and were not trained properly on taking temps daily and PH Calibrations and sampling. Page 12 of 34 1 of 2 CWA NPDES Inspection Report ORR0022985 Oregon DEQ Noncompliance Reporting Form continued RAINFALL DATA Rainfall (for storm-related noncompliance): inches Design Storm: inches Source of rainfall data: CORRECTIVE ACTIONS List actions taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance. Actions taken (describe): Since that time and moving forward Training has been done and new PH machines have been purchased. Two qualified people that have been trained correctly to collect samples go together in order to make sure everything goes smoothly. Actions planned and schedule for those actions (describe): Task list on Calendar and follow up with Enviromental Coordinator before submitting. Comments: COMMENTS I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Authorized Signature Brandon Mainard Name (print) EHS Coordinator Title (print) Page 13 of 34 11-10-2022 Date 541-689-1011 Phone bmainard@spi-ind.com Email 2 of 2 CWA NPDES Inspection Report ORR0022985 ATTACHMENT C Aerial Map (Google Earth) Page 14 of 34 CWA NPDES Inspection Report ORR0022985 ATTACHMENT D ORR0022985 Permit Page 15 of 34 CWA NPDES Inspection Report ORR0022985 Page 16 of 34 CWA NPDES Inspection Report ORR0022985 Page 17 of 34 CWA NPDES Inspection Report ORR0022985 Page 18 of 34 CWA NPDES Inspection Report ORR0022985 Page 19 of 34 CWA NPDES Inspection Report ORR0022985 Page 20 of 34 CWA NPDES Inspection Report ORR0022985 Page 21 of 34 CWA NPDES Inspection Report ORR0022985 Page 22 of 34 CWA NPDES Inspection Report ORR0022985 Page 23 of 34 CWA NPDES Inspection Report ORR0022985 Page 24 of 34 CWA NPDES Inspection Report ORR0022985 Page 25 of 34 CWA NPDES Inspection Report ORR0022985 ATTACHMENT E Photograph Log All photographs taken by Jon Klemesrud on May 17, 2023 Nikon Coolpix AW100 Page 26 of 34 CWA NPDES Inspection Report ORR0022985 Photograph Log - Sierra Pacific Industries - Eugene Photo #:01 (DSCN3272) Description: Facing northwest, photo of the vehicle wash area and discharge location. Vehicles are washed with fresh water and effluent travels as sheet flow to the north drainage ditch. The drainage ditch is piped underground and then surfaces along the eastern portion of the property prior to discharging to the settling pond and outfall 001. Photo #:02 (DSCN3273) Description: Facing north, photo of catch basin southwest of the vehicle wash area. The catch basin also receiving flow from the vehicle wash area and discharges via pipe to the drainage ditch to the north. Absorbant boom located around the catch basin and within the drainage ditch. Booms area replaced as needed by operations crew. Photo #:03 (DSCN3274) Description: Facing south, photo of the north settling pond. The pond discharges from the northwest corner via the black conveyance pipe. Photo #:04 (DSCN3275) Description: Facing south, photo of the boiler blowdown effluent discharging to the settling pond a few inches from the pond's discharge conveyance pipe. Page 27 of 34 CWA NPDES Inspection Report ORR0022985 Photograph Log - Sierra Pacific Industries - Eugene Photo #:05 (DSCN3276) Description: Facing south, photo of the effluent weir/gate north of the settling pond. Photo #:06 (DSCN3277) Description: Facing south, photo of the effluent weir/gate north of the settling pond from the sample/flow monitoring location. Photo #:07 (DSCN3278) Description: Facing east, photo of the sampling location north of the effluent weir/gate. Photo #:08 (DSCN3279) Description: Facing north, photo of the effluent weir/gate and screening. The metal grate was composed of holes approximately 1 inch in diameter. Mesh screening was observed to be attached to the metal grate but did not extend down into the discharge. Page 28 of 34 CWA NPDES Inspection Report ORR0022985 Photograph Log - Sierra Pacific Industries - Eugene Photo #:09 (DSCN3280) Description: Facing northwest, photo of the north end of the drainage ditch/channel discharging to the settling basin. Absorbant booms stretched across the ditch/channel. The ditch/channel was last cleaned out in November 2022 (approx.). Photo #:10 (DSCN3281) Description: Facing northeast, photo of the northeast end of the drainage ditch/channel discharging to the settling basin. Absorbant booms stretched across the ditch/channel. The ditch/channel was last cleaned out in November 2022 (approx.) Photo #:11 (DSCN3282) Description: Facing south, photo of the northeast corner of the log yard, south of the settling pond. Photo #:12 (DSCN3283) Description: Facing south, photo of the northeast corner of the log yard, south of the settling pond. Water from the log sprinkler system travels as sheet flow the east and discharges to the drainage ditch/channel. Page 29 of 34 CWA NPDES Inspection Report ORR0022985 Photograph Log - Sierra Pacific Industries - Eugene Photo #:13 (DSCN3284) Description: Facing south, photo of the eastern log deck area, south of the truck/log scale. Water from the areas of log sprinkler system on the log deck is conveyed to this central capture area and discharged to drainage ditch channel. Log yard is swept daily. Photo #:14 (DSCN3285) Description: Photo of the Facility's pH peter. Photo #:15 (DSCN3286) Description: Photo of the pH calibration buffers and dates indicating calibration. A 2-point calibration is conducted using standards of 4 and 7. Photo #:16 (DSCN3287) Description: Photo within the cogeneration boiler condensate treatment system building. Page 30 of 34 CWA NPDES Inspection Report ORR0022985 Photograph Log - Sierra Pacific Industries - Eugene Photo #:17 (DSCN3288) Description: Photo within the cogeneration boiler condensate treatment system building. Photo #:18 (DSCN3289) Description: Photo within the cogeneration boiler condensate treatment system building. Page 31 of 34 CWA NPDES Inspection Report ORR0022985 ATTACHMENT F Post Inspection Email Correspondence Page 32 of 34 CWA NPDES Inspection Report ORR0022985 From: To: Cc: Subject: Date: Attachments: Klemesrud, Jon mbosch@spi-ind.com; bmainard@spi-ind.com; jhiggins@spi-ind.com ULLRICH Andy DEQ; EAGLESON Bradley DEQ SPI-Eugene - EPA Inspection: Requested Documentation / Follow-Up Friday, May 19, 2023 11:21:00 AM image001.png Hi Brandon/Jeremy/Matt, Thanks again for facilitating/hosting EPA and ODEQ on short notice Wednesday for the Clean Water Act (CWA) inspection at the Eugene facility. We enjoyed our time on-site and it was good to get updated on current operations since the last ODEQ inspection, which I believe occurred in 2017. Note that this inspection was limited to the ODEQ issued NPDES wastewater individual permit (OR0022985). I think the inspection went well and it appeared wastewater infrastructure was operating smoothly. Brandon - If you wish, I would be happy to schedule a call/meeting for next week to discuss my inspection observations further as well as next-steps. These were already discussed in more detail with Jeremy and Matt during the inspection. With Brandon's absence, monitoring records [bench sheet data and analytical (lab) reports] were not available for review on-site. As the permit is setup for self-monitoring, I wanted to follow up with a request to review (electronically) a few sampling related items as they relate to permit compliance. A review of these items are generally standard for all inspections. As a snapshot, I was hoping to review a few randomly selected months/weeks of monitoring data for the parameters required under the permit. (pH, flow, temperature, TSS, BOD, oil & grease and observations of floating solids/debris). This would include any laboratory analytical results for the requested sampling events, also including chain of custody documentation and any bench sheet data/in-house monitoring results collected by the sampler. Months requested include July 2022, November 2021 and October 2020. Additionally, if there are any internal standard operating procedures or QA/QC documents related to sampling or flow measurement I would like to review those as well. As discussed with Jeremy and Matt on-site, the following potential compliance concerns were identified and discussed yesterday: Prior to the inspection I reviewed DMR submitted data going back 5 years, the following exceedances of the permit limit(s) were reported. It was noted that the facility did complete a non-compliance report on November 10, 2022 to address the prior exceedances (11/01/2021 - 7/01/2022). While observing the gated outfall. We observed some mesh screening that was attached to the steel gate, the mesh screening appeared to be warn/eroded and was not submerged in the effluent flow. Page 33 of 34 CWA NPDES Inspection Report ORR0022985 The steel gate was composed of approximately 1-inch holes. Schedule A.1.a. states that no floating solids/debris are allowed to be discharged. Note 2 defines "Debris" as anything that can be retained by a 5 mesh screen. Although no floating solids/debris were observed to be discharging at the time of inspection, if the screen is used to address the requirement I would suggest repairing the mesh to ensure compliance with the debris discharge permit language. When discussing temperature measurement, Jason (Nelson) discussed that the facility uses an infrared thermometer. As the infrared thermometer is measuring surface temperature, I would suggest the facility review the approved method (40 CFR 136) for temperature to ensure temperature monitoring is compliant with one of the approved standard methods. I did note this was also an "action item" documented in the 2017 ODEQ inspection report. When discussing pH calibration, Jason (Nelson) discussed that the pH meter calibrations are documented on the outside of the box containing the pH meter, which listed a series of days/months, most recently "5/8." pH calibration was discussed as a 2-point calibration using standard solutions of 4 and 7. Buffers selected for a 2 point calibration should bracket the expected value of the pH sample and the pH meter should be calibrated prior to each use. Given the variability in the reported pH values, the facility should consider a 3 point calibration and calibration records should include the full date, name of he person who performed the calibration, the buffers used, the time of calibration, the temperature of the buffer, the pH value prior to calibration and the slope (in %). I did note that pH calibration documentation was also an "action item" documented in the 2017 ODEQ inspection report. Thanks again for your time and assistance, if I could get the requested documentation sometime next week that would be much appreciated. Feel free to reach out if you have any questions/concerns. One last item, I am providing a link to a general compliance assistance document that we typically hand-out on all inspections, it may contain some links to some available resources: https://www.epa.gov/sites/default/files/2017-06/documents/smallbusinessinfo.pdf Jon Klemesrud Field, Data, & Drinking Water Enforcement Section Enforcement & Compliance Assurance Division (M/S 20-C04) U.S. Environmental Protection Agency, Region 10 (206) 553-5068 Page 34 of 34