Document Y02geqBJ1K36YmkG5nNdkBKn

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 11/19/2024 09:26 AM (PT) Announced: No 11/19/2024 02:10 PM (PT) Access: Granted 55F, Overcast Water Clean Water Act, NPDES, Stormwater - Industrial Compliance Evaluation Inspection Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County Facility GPS Coordinates Mailing Address City, State, Zip Code Swanson Group Manufacturing, LLC Springfield Plywood & Veneer 1651 South F Street Springfield, Oregon 97477 Lane 44.04207, -123.005269 P.O. Box 250 Glendale, Oregon 97442 FRS ID Permit Number SICs 110001655575 ORR221309 2421 (Sawmills & Planing Mills, General) 2436 (Softwood Veneer & Plywood) Lead Inspector: RAYMOND ANDREWS Date: 2025.01.16 09:10:36 -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: 2025.01.16 09:40:26 -08'00' contreras.peter@epa.gov (206) 553-6708 Springfield Plywood & Veneer Permit # ORR221309 SECTION I - Opening Conference I arrived at the Swanson Group Manufacturing's Springfield Plywood & Veneer facility (the "Site" or "Facility"), located at 1651 S F St, Springfield, Oregon, at 09:26 AM (PT) on 11/19/2024 for an unannounced inspection. I presented my credentials to Doug Rue 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 # ORR221309. This report is based on information supplied by Mr. Rue, 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 Swanson Group Doug Rue Log Yard Lead Yes Yes Swanson Group Mike Vohland Maintenance Yes Yes Manager Swanson Group Kelly Smith Plant Superintendent Yes Yes Facility Information Responsible official? Is property owned or leased? Years in operation? Type of Operation Size of Facility? Number of employees? Jeff Remington; jeff.remington@swansongroup.biz The property is owned by Swanson Group. Swanson Group bought out the previous owner in 2007. The facility produces plywood and veneers from logs. The total facility site is approximately 31 acres with the log ward taking up approximately 12 of those acres. The facility has approximately 220 employees to cover all shifts. The mill operates three 8-hour shift, Monday through Friday, and will occasionally run extra shifts on Saturday to meet a customer order. Number of sampling locations? The facility has six outfalls but only five sampling locations. Outfall 005 sends its stormwater to Outfall 006 for discharge. Samples are collected at Outfalls 001 - 004 and Outfall 6. The discharge from Outfall 5 is sent by underground pipe to Outfall 6 for discharge. Receiving Water? Willamette River Who conducts monitoring? Mr. Rue conducts the sampling, inspections, and reporting. Does the facility conduct The facility conducts a monthly visual assessment by observing the water as visual assessments? it flows out of the outfalls. What parameters is the facility required to analyze? The facility is required to conduct water sample analysis for zinc (Zn), copper (Cu), total suspended solids (TSS), chemical oxygen demand (COD), iron (Fe), lead (Pb), and pH. The facility analyzes pH on site. All other parameters are analyzed by the contract lab: Analytical Laboratory Group 361 West 5th Avenue Eugene, Oregon 97401 (541) 485-8404 2 of 8 Springfield Plywood & Veneer Permit # ORR221309 Have you had any The facility has exceeded its benchmarks for zinc, COD, and TSS. Multiple benchmark exceedances Tier I reports were submitted due to the exceedances. The Tier I reports in the past 12 months? were reviewed in "Records Review." BMPs/Stormwater Treatment? The facility uses catch basins with oil/water separators. The catch basins are either surrounded by filter booms or contain absorbent pads. The facility discharges into a heavily vegetated flow channel (ditch) which then drains into the Willamette River. Type of materials and/or The facility stores raw logs, packaged products waiting for ship out, heavy vehicles stored equipment, i.e. forklifts, and a water truck which is used for dust control. outdoors? SECTION II - Observations Location: Outside Storage Observation #: RA1-OB-001 Date: 11/19/2024 Weather: 55F, Overcast Packaged finished product. Photo(s) 1. IMG-20241119135223522383817.jpg Location: Outside Storage Observation #: RA1-OB-002 Date: 11/19/2024 Weather: Material waiting for processing. Photo(s) 1. IMG-2024111913100510584894.jpg Location: Outside Boiler Observation #: RA1-OB-003 Date: 11/19/2024 Weather: At the time of inspection, I observed an open dumpster that contained ash from the boiler. It did not appear the dumpster was being actively loaded or unloaded. Photo(s) 1. IMG-202411191320572057121497.jpg Location: Outside Boiler Observation #: RA1-OB-004 Date: 11/19/2024 Weather: At the time of the inspection, I observed piles of sawdust accumulated on the walls and ground outside the boiler building. Photo(s) 1. IMG-202411191327502750113399.jpg 3 of 8 Springfield Plywood & Veneer Permit # ORR221309 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: 01/13/2025 Post inspection, I reviewed the facility's Discharge Monitoring Reports (DMRs) from 1Q 2022 through 4Q 2024. I did not note any areas of concern. Record: Tier II Corrective Action Responses AOC: No Ref #: RA1-RR-006 Reviewed By: Raymond Andrews Reviewed Date: 01/13/2025 Post Inspection, I reviewed two Tier II Corrective Action Response (CAR) SPCP Addendums, dated February 9, 2023 (Addendum 1), and November 15, 2023 (Addendum 2). The Responses were prepared for the facility by the contract engineering firm EGR & Associates, Inc. The Addendum 1 CAR was in response to exceedance of the benchmark geometric mean for total suspended solids (TSS) at Outfall 006. The corrective action plan required the facility to retrofit the settling basin in the log grading and storage area with baffles to improve settling efficiency of sediment in the stormwater. The Addendum 2 CAR was in response to exceedance of the benchmark geometric mean for zinc (Zn) at Outfall 004. The facility and the contract engineer determined the most likely cause of the excessive zinc in the stormwater was runoff from the rooftops. To mitigate the discharge of zinc, the corrective action plan required the facility to install a self-contained downspout filter treatment unit at each of the roof downspouts. The filters use a filter media that specifically targets dissolved metals including zinc. The facility selected the Storm Clean assembled downspout filter system manufactured by CleanWay Environmental Partners with MetalZorb metals filtration media. The downspout pipes were connected to an individual filter unit, which has an internal high-flow bypass. The filter units will discharge onto adjacent pavement as currently occurs with the roof downspouts. Photo(s) 1. IMG-20241119134536453684437.jpg 2. IMG-20241119134544454489323.jpg Record: Routine Monthly Facility Inspection Reports AOC: No Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Reviewed Date: 11/19/2024 At the time of inspection, I reviewed the facility's routine monthly inspection reports from January 2022 through October 2024. I did not note any areas of concern. Record: Monthly Visual Inspections AOC: Yes Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 11/19/2024 At the time of inspection, I reviewed monthly visual assessments from January 2022 through October 2024. According to Mr. Rue, the facility is not conducting visual inspections in accordance with the permit. The permit requires samples be collected in a clean, colorless glass or plastic container for inspection in a well-lit area. Mr. Rue is making his observations without collecting a sample in a container. Record: Facility Benchmark Exceedance Tier I Reports AOC: No Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 11/19/2024 4 of 8 Springfield Plywood & Veneer Permit # ORR221309 At the time of the inspection, I reviewed the facility's Tier I reports for the following dates. each date is the benchmarks that were exceeded at each outfall. 1/5/2022 - Sampled 11/23/2021, Results 12/13/2021 OF 1 (Cu) OF 2 (Zn) OF 3 (Zn) OF 4 (COD) OF 6 (COD, TSS) 2/11/2022 - Sampled 12/22/2021, Results 1/12/2022 OF 2 (Zn) OF 3 (Zn) OF 4 (COD) OF 6 (COD) 4/12/2022 - Sampled 3/9/2022, Results 3/17/2022 OF 2 (Zn) OF 3 (Zn) OF 4 (COD) OF 6 (Cu, COD, TSS) 4/20/2022 - Sampled 4/4/2022, Results 4/18/2022 OF 1 (Cu, COD, TSS) OF 2 (Zn) OF 3 (Zn) OF 6 (COD) 12/12/2022 - Sampled 11/11/2022, Results 11/21/2022 OF 2 (Zn) OF 3 (Zn) OF 4 (Zn, COD) 1/20/2023 - Sampled 12/10/2022, Results 12/27/2022 OF 1 (Zn, COD) OF 2 (Zn) OF 3 (Zn) OF 4 (Zn, COD) OF 6 (COD, TSS) 2/16/2023 - Sampled 1/11/2023, Results 1/19/23 OF 2 (Zn) OF 3 (Zn, Cu, COD, TSS) OF 4 (Zn, COD) OF 6 (COD, TSS) 4/17/2023 - Sampled 3/2/2023, Results 3/17/2023 OF 2 (Zn) OF 3 (Zn) OF 4 (Zn, COD) 12/13/2023 Sampled 11/6/2023, Results 11/16/2023 OF 1 (Cu, COD) OF 2 (Zn) OF 3 (Zn) OF 4 (Zn, COD, TSS) OF 6 (COD) 2/1/2024 - Sampled 12/22/24, Results 1/2/2024 OF 1 (Zn, Cu, COD, TSS) OF 2 (Zn) Under 5 of 8  OF 3 (Zn) OF 4 (Zn, COD) 3/26/2024 - Sampled 2/14/2024, Results 2/28/2024 OF 1 (Fe, COD) OF 3 (Zn) OF 4 (COD) 4/12/2024 - Sampled 3/4/2024, Results 3/18/2024 OF 2 (Zn) OF 3 (Zn) OF 4 (COD) OF 6 (COD) Springfield Plywood & Veneer Permit # ORR221309 Not all Tier I reports required a Tier II Action Response because the parameters' geometric means had not been exceeded. Record: Laboratory Analysis Reports AOC: No Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 11/19/2024 At the time of inspection, I reviewed lab analysis reports from 1Q 2022 through 3Q 2024. I did not note any areas of concern. Record: Stormwater Pollution Control Plan (SPCP) AOC: Yes Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 11/19/2024 At the time of inspection, I reviewed the facility's Stormwater Pollution Control Plan (SPCP), dated June 2021. The SPCP shows the facility is under SIC code 2421 (Sawmills and Planing Mills, General) but based on activities, SIC code 2436 (Softwood Veneer and Plywood) should probably be added as a secondary activity. The facility is no longer monitoring or discharging from Outfall 5, so the map should be updated. The site plan does not indicate when packaged products are stored outside. The site plan does not show the loading and offloading areas. The site plan is missing the immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured products, waste material, or by-products used or created by the facility. Photo(s) 1. IMG-20241119104817481797970.jpg 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-RR-004 Records Review: Monthly Visual Inspections Permit Requirement Part B.12.e of the permit states, in part, "Conduct visual observations of a sample in a clean, colorless glass or plastic container in well-lit area..." AOC: The samples are not being collected in a clean, colorless glass or plastic container for inspection in a well-lit area. 6 of 8 AOC Reference #: RA1-RR-001 Springfield Plywood & Veneer Permit # ORR221309 Records Review: Stormwater Pollution Control Plan (SPCP) Permit Requirement Schedule A.8.f of the permit states, "The permit registrant must keep the SWPCP current and revise it as necessary to reflect current site conditions and changes to the site." AOC: The facility is no longer monitoring or discharging from Outfall 5, so the map should be updated. AOC Reference #: RA1-RR-001 Records Review: Stormwater Pollution Control Plan (SPCP) Permit Requirement Part Schedule A.10.b.i.8 of the permit states, in part, "The SWPCP must contain the following information...areas used for outdoor manufacturing, treatment, storage, or disposal of significant materials..." AOC: The site plan does not indicate where packaged products are stored outside. AOC Reference #: RA1-RR-001 Records Review: Stormwater Pollution Control Plan (SPCP) Permit Requirement Part Schedule A.10.b.i.19.C & G states, in part, "The SWPCP must contain the following information...locations of the following materials and activities if they are exposed to stormwater and applicable...loading/unloading areas [and] immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured products, waste material, or by-products used or created by the facility..." AOC: The site plan did not show the loading and offloading areas. The site plan is missing the immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured products, waste material, or by-products used or created by the facility. AOC Reference #: RA1-OB-003 Location: Outside Boiler Permit Requirement Schedule A.1.c of the permit states, in part, "Cover all waste contained in bins or dumpsters where there is a potential for drainage of stormwater through the waste to prevent exposure of stormwater to these pollutants. Acceptable covers include, storage of bins or dumpsters under roofed areas or use of lids or properly secured temporary covers such as tarps." AOC: There was open dumpster that contained ash from the boiler. It did not appear the dumpster was being actively loaded or unloaded. AOC Reference #: RA1-OB-004 Location: Outside Boiler Permit Requirement Schedule A.1.g of the permit states, in part, "Routinely clean all exposed areas that may contribute pollutants to stormwater with measures such as sweeping at regular intervals..." AOC: Piles of sawdust were accumulated on the walls and ground outside the boiler building. 7 of 8 Springfield Plywood & Veneer Permit # ORR221309 SECTION VI - Closing Conference I held a closing conference with Facility personnel at 02:10 PM (PT) on 11/19/2024 for the inspection. During the closing conference, I discussed the 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 8 of 8 APPENDIX 1: PHOTO LOG Site Map, photo 1 11/19/2024 10:48 AM No CBI No PII IMG-20241119104817481797970.jpg Photographer: Raymond Andrews Site Map, photo 2 11/19/2024 10:50 AM No CBI No PII IMG-202411191050565056121596.jpg Photographer: Raymond Andrews Outfalls 002 11/19/2024 01:05 PM No CBI Outfall 002 discharge pipe. No PII IMG-20241119130531531179340.jpg Photographer: Raymond Andrews Outside Storage 11/19/2024 01:10 PM (PT) No CBI No PII Raw material waiting outside for processing. IMG-2024111913100510584894.jpg Photographer: Raymond Andrews Catch Basin 003 IMG-202411191312321232135324.jpg 11/19/2024 01:12 PM No CBI No PII Photographer: Raymond Andrews Catch basin 003 with oil/water separator on right. Outside Boiler 11/19/2024 01:20 PM No CBI Open dumpster with ash from boiler. No PII IMG-202411191320572057121497.jpg Photographer: Raymond Andrews Outside Boiler 11/19/2024 01:27 PM No CBI Sawdust piles outside of boiler area. No PII IMG-202411191327502750113399.jpg Photographer: Raymond Andrews Outfall 001 11/19/2024 01:34 PM No CBI Outfall 001 with oil absorbent pads. No PII IMG-202411191334233423154693.jpg Photographer: Raymond Andrews Catch Basin 006 11/19/2024 01:40 PM Catch basin 006, photo 1. No CBI No PII IMG-20241119134007407123578.jpg Photographer: Raymond Andrews Catch Basin 006 11/19/2024 01:40 PM No CBI Catch basin 006, photo 2. No PII IMG-202411191340134013130039.jpg Photographer: Raymond Andrews Storm Clean Downspout Filter System, exterior, IMG-20241119134525452570542.jpg photo 1 11/19/2024 01:45 PM No CBI No PII Photographer: Raymond Andrews The above photo is the Storm Clean downspout filter system which collects and filters runoff from the facilities rooftops. Every roof downspout has its own Storm Clean filter. Inside the filter system is the MetalZorb metals filtration media, which filters a variety of metals including the target metal, zinc. Storm Clean Downspout Filter System, exterior, photo 2 11/19/2024 01:45 PM No CBI No PII IMG-20241119134536453684437.jpg Photographer: Raymond Andrews Storm Clean Downspout Filter System, Interior 11/19/2024 01:45 PM No CBI No PII Filter for runoff from building roof, interior IMG-20241119134544454489323.jpg Photographer: Raymond Andrews Outside Storage 11/19/2024 01:52 PM No CBI No PII Packaged finished product waiting for ship out. IMG-20241119135223522383817.jpg Photographer: Raymond Andrews