Document YGD5K3oX8nyRJK0ZXM3b8Q8Gy

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Agancy Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) -=C-o- mpany Name: Facility Name: ~acility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: ~~ -- 09/22/2015 Water CAFO . --- ------ .... ~--~---~------- . - Boyd Gaming Corporation Delta Downs Racetrack, Casino and Hotel 2717 Delta Downs Drive Vinton, LA 70668 2717 Delta Downs Drive Vinton, LA 70668 Calcasieu Parish -- Chuck Willhite --- I Director of_ Facilities chuchwillhite@boydgaming.C()m FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: N/A LA0120111 N/A 711212 7948 -- Personnel participating in inspection: - Chuck Willhite Delta Downs Juan Ibarra EPA R6/6EN-WC Abu Senkayi EPA R6/6EN-WC -- - Director of-Facilities Inspector Enforcement Officer - -- --- -~ ~- -- - --~ -- -- 337-589-9006 214-665-8493 214-665-8403 -- -~ EPA Lead Inspector ' Signature/Date Supervisor Signature/Date - -- ..., - / / ;:::;,t;"'"' ~- ii~;~e~-1f~:ft:~/>;17':r=~-- . -~/>(;; .LiZ< / ?('(rcff r-:1/ ,t1upervisorname} // () ~ .Z///''/;?&VA" Date c<_,(/C"//? IJ&te/ 6ENFORM-019-R6 (10/6/14) 1 2 of 19 Boyd Gaming Corporation I Delta Downs Racetrack, Casino and Hotel Inspection Date 09/22/2015 Section I INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Juan Ibarra and Abu Senkayi arrived at the Boyd Gaming Corporation I Delta Downs Racetrack, Casino and Hotel (Delta Downs) at 1645 on September 22, 2015, for an unannounced inspection. We met with Mr. Chuck Willhite/Director of Facilities. We presented our credentials to Mr. Willhite and informed him that this was an EPA inspection to determine compliance with the Administrative Order issued on 8/26/2013 (CWA-06-2013-1875) and the Clean Water Act Concentrated Animal Feeding Operations (CAFO) regulations. The scope of the inspection is a full compliance evaluation. FACILITY DESCRIPTION Delta Downs is a large CAFO that operates a horse racetrack, with both a Quarter Horse and a Thoroughbred Season. When we arrived, there were approximately 200 horses stabled at the facility. Maximum capacity is 1,320 horses during racing season, but they normally stable around 1200 to 1300 horses. The facility has 22 barns, of which 20 barns have 60 stalls per barn, with the two other barns being a Receiving Barn and a Holding Barn. Each barn has eight covered horse wash racks (four per side), two manure bins, and generally four walkers. Wastewater from the covered horse wash racks discharge to one of two lagoons thru a subsurface collection system. The collection system consists of a series of dual chamber settling tanks (one for each side of the barn) that send the wastewater into one of seven lift stations, each equipped with dual grinder pumps (for redundancy) and lighted alarms. The lift stations then send the wastewater to one of two retention lagoons. The east lagoon has a capacity of 9,542,300 gallons, and the west lagoon has a capacity of 12,614,300 (based on the As-Built drawings provided by Thompson Engineering, Inc.). The new covered manure bins have extended wing walls and fixed curbing that provides excellent storm water protection (see the Appendix 1 photo log). The old manure bins were smaller (no wing walls) and uncovered. Additionally, the facility has implemented improved manure management controls and BMPs that will be described below. Section II- OBSERVATIONS Delta Downs responded to the requirements of EPA Administrative Order CWA-06-2013-1875 by eliminating the unpermitted discharge of horse wash rack wastewater to the adjacent off-property drainage channels. This was accomplished by the installation of a collection system consisting of covered horse wash racks that discharge into settling tanks (dual chambered septic tanks) plumbed to one of seven lift stations. The collection system routes the isolated wash rack wastewater to one of two lagoons, with the West Lagoon being a new unit. 2 3 of 19 Boyd Gaming Corporation I Delta Downs Racetrack, Casino and Hotel Inspection Date 09/22/2015 Manure wastes are now contained within the new improved and roofed manure bins. Additionally, a new worker has been hired to specifically manage the manure bins and manure collection program, as well as keeping the production area clean. These management controls are supported by the purchase of a new tractor for her use as she cleans the grounds. This is reportedly her only job duty, and the tractor is a dedicated piece of equipment for this task. We observed some tall vegetation and shrubs on the embankment of the East Lagoon. This lagoon should be kept mowed to prevent embankment perforation by plant roots such as the brush seen in photos 10 and 13. As the plants grow and become trees, the roots compromise the embankments integrity. Additionally, the West Lagoon only had about 3" of freeboard. Although the facility is diverting influent flows from Barns 12-22 to the East Lagoon, operational management of lagoon levels must be balanced between both lagoons. Wash rack flows from Barns 1-11 go directly into the West Lagoon, while influent flows from Barns 12-22 can be diverted into either lagoon. Aside from improvements in operational management of the two lagoons, other lagoon management options mentioned by Mr. Willhite included the current use of the water truck to take water out of the West Lagoon and use it for dust control, and possible improvement of the West Lagoon embankment elevation. Section Ill- AREAS OF CONCERN Delta Downs has not adequately maintained the East Lagoon embankment to remove brush. Lagoon embankment maintenance is a standard maintenance condition for all CAFOs. The West Lagoon has not provided for a minimum of 1' of freeboard, and preferably 2' of freeboard. At the time of the inspection, the West Lagoon had about 3" of freeboard. Section IV- FOLLOW UP Section IV- FOLLOW UP A copy of inspection report detailing the two Areas of Concern will be sent to the facility. Also, Delta Downs will submit to EPA and LDEQ a signed certification indicating that the requirements of EPA's Order have been met. This certification shall include a summary of the completed work and photographs to document the actions taken. Section V- LIST OF APPENDICES Appendix 1- Photo Log and Aerial Photo (showing location/direction of photographs) -14 photos taken 9/22/15 3 4 of 19 Boyd Gaming Corporation I Delta Downs Racetrack, Casino and Hotel Inspection Date 9/22/2015 Appendix 1 Photograph Log 5 of 19 6 of 19 7 of 19 8 of 19 9 of 19 10 of 19 11 of 19 12 of 19 13 of 19 14 of 19 15 of 19 16 of 19 17 of 19 18 of 19 19 of 19