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NPDES Stormwater Industrial and Construction Inspection Report National Database Information Inspection Date:03/04/2025 NPDES ID Number: COR05I301 Entry/Exit Time: 9:00/15:00 Inspection ID: 202503_COR05I301 Facility Type: Gas Processing Plant Inspection Type: Stormwater Industrial SIC Code: 1321 Natural Gas Liquids Lead Inspector/Affiliation/Telephone: Kevin Stockton/ERG/720-789-8050 Inspector/Affiliation/Telephone: Shannon Egger/ERG/703-633-1600 Inspector/Affiliation/Telephone: Geoff Hensgen/Southern Ute Indian Tribe/970-563-3111 Facility Location Information Site/Facility and Location: Mailing address: Ignacio Gas Plant 3746 Country Road 307 Durango, Colorado 81303 La Plata County Harvest Four Corners, LLC 1755 Arroyo Dr, Bloomfield, New Mexico 87413 Latitude: 37.1442779 N Longitude: -107.7864066 W Receiving Water(s): Unnamed tributary to Florida River Impaired waters: No Contact Information Permittee (owner): Co-Permittee: Authorized Official: Facility Contact(s): Facility Operator: Name and Title Harvest Four Corners, LLC N/A Mike Perkerewicz, Facility Foreman Monica Smith, Environmental Specialist Chad Snell, Environmental Specialist - Contractor Nathan Work, Operations Manager Industrial Permit Information Date NOI Submitted: 05/25/2021 SWPPP on site: Yes SWPPP Implementation Satisfactory: No (refer to Findings 2-5) Permit Effective Date: 06/24/2021 Copy of NOI on site: Yes SWPPP Satisfactory: No (refer to Finding 1) Satisfactory SWPPP must be current and complete Expiration Date: 02/28/2026 Harvest Four Corners, LLC 1 of 12 NPDES Stormwater Industrial and Construction Inspection Report Areas Evaluated During Inspection Permit Records Facility Site Review Effluent/Receiving Waters Self-Monitoring Program Compliance Schedule Laboratory Operations and Maintenance Report Review and Signature Inspector Signature/Name Kevin Stockton Reviewer Signature/Name Stephanie Meyers Supervisor Signature/Name EMILIO Digitally signed by EMILIO LLAMOZAS LLAMOZAS 15:25:19 -06'00' Date: 2025.04.17 Emilio Llamozas Address/Phone Number ERG Golden Office 1113 Washington Avenue Suite 300 Golden, CO 80401 720-789-8050 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ECA-W-N Denver, Colorado 80202 303-312-6938 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ECA-W-N Denver, Colorado 80202 303-312-6407 Flow Measurement Pollution Prevention Stormwater No Exposure Date 3/25/2025 (Draft) 4/15/2025 (Final) Date 3/26/2025 Date 04/09/2025 Harvest Four Corners, LLC 2 of 12 NPDES Stormwater Industrial and Construction Inspection Report Inspection Narrative, Facility and Industrial Activity Description The inspection was conducted at the Harvest Four Corners, LLC (Permittee) Ignacio Gas Plant (Facility) located within the Southern Ute Reservation near Durango, Colorado. The EPA is responsible for implementing the National Pollutant Discharge Elimination System (NPDES) program in Indian Country within the State of Colorado. The focus of the inspection was to determine the Permittee's compliance with its NPDES Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity (NPDES Permit number COR05I301). EPA announced the Inspection to the Permittee via phone and email on February 19, 2025. On March 4, 2025, at approximately 9:00 AM, the U.S. Environmental Protection Agency (EPA) contracted inspectors from Eastern Research Group (ERG), Kevin Stockton and Shannon Egger, as well as Geoff Hensgen, Water Quality Manager from the Southern Ute Indian Tribe (collectively, the Inspection Team) arrived at the Facility. After completing the required safety training, the Inspection Team met with Facility representatives Monica Smith (Environmental Specialist), Mike Perkerewicz (Plant Foreman), Nathan Work (Operations Manager), and Chad Snell (Environmental Specialist Contractor). The Inspection Team and Facility representatives began with an opening conference to make introductions and discuss the purpose of the inspection. Kevin Stockton of ERG presented his EPA-issued Clean Water Act (CWA) Inspector Credential. The Facility is operated by Harvest Four Corners, LLC and provides compression, conditioning, and processing for natural gas recovered in the San Juan Gathering System, which spans the southwest corner of Colorado and the northwest corner of New Mexico. The Facility conditions approximately 500 to 600 million standard cubic feet of field gas per day (MMscfd) into saleable gas liquids and residue gas. The primary plant operations include inlet compression, dehydration, carbon dioxide removal, natural gas liquid (NGL) removal, fractionation, and storage. NGLs are transported off-site via pipelines and tanker trucks. Y-grade ethane is transported off-site in a dedicated pipeline. The loading of the remaining NGLs occurs through loading racks. There are two propane loading racks, one butane loading rack, and two natural gasoline loading racks. The Ignacio Warehouse is located in the west area of the Facility and receives shipments for plant operations. Various potential stormwater pollutants (petroleum products, amine, bleach) used in the Facility's natural gas processing operations are stored in tanks within secondary containment basins throughout the Facility. The Permittee implements a Spill Prevention, Control, and Countermeasure (SPCC) Plan for bulk chemicals stored at the Facility. Most of the Facility is unpaved (a combination of gravel, rock, and dirt) and there is a general grade from north to south. The Facility manages industrial wastewater through a system of evaporation ponds permitted by the Colorado Oil and Gas Conservation Commission. The Clear Water Pond in the south-central area of the Facility contains fresh water, pumped from the Florida River, to be used in plant processes and is dredged approximately every 3 years. The Permittee stores dredged material in a Soil Drying Containment area in the east area of the Facility (refer to Appendix A, Photographs 1, 2, and 3). The East Excess Pond contains cooling tower blow down, boiler blow down, and reverse osmosis reject Harvest Four Corners, LLC 3 of 12 NPDES Stormwater Industrial and Construction Inspection Report Inspection Narrative, Facility and Industrial Activity Description water before it is pumped to the Evaporation ponds in the south area of the Facility (refer to Appendix A, Photograph 4). Industrial wastewater is stored in two above-ground storage tanks in the east area of the Facility (refer to Appendix A, Photographs 5 and 6). These tanks are emptied daily and wastewater is hauled offsite for disposal by a third-party contractor. The Inspection Team reviewed the Facility Stormwater Pollution Prevention Plan (SWPPP), site map, industrial stormwater self-inspection records, and stormwater training documents. Weekly industrial stormwater inspections were reviewed for first, second, and third quarters in 2024. Quarterly visual inspections were reviewed for the first, second, and third quarters in 2024. Operator training logs and slide decks were reviewed for 2024. Discharge monitoring reports and laboratory sample analysis results were reviewed for January 2024 through January 2025. Two discharge events occurred in the period of review, one on June 22, 2024 and one on September 17, 2024. Both samples were collected from sample point 5 which is located upgradient from Outfall IGP-011. The Inspection Team confirmed that the sample analysis results were correctly reported on the corresponding June and September 2024 DMRs. Facility representatives stated that samples were unable to be taken from the other outfalls due to insufficient flow. The Inspection Team, accompanied by Facility representatives, conducted a walkthrough of the Facility starting at Outfall IGP-012 along the northern side of the Office and Control Room (refer to Appendix A, Photographs 7 and 8). From there, the Inspection Team and Facility representatives proceeded clockwise around the Facility perimeter, observing Gosney Pond, stormwater drainage pathways, and storage areas in the northwest corner of the Facility. Then, the Inspection Team and Facility representatives observed the stormwater drainage pathways along the Facility's north perimeter and storage areas in Drainage Areas 4 and 5. Next, the Inspection Team and Facility representatives observed stormwater outfalls, storage areas, and control measures in Drainage Area 15. Then, the Inspection Team and Facility representatives observed the boneyard area in Drainage Area 6, stormwater drainage pathways in Drainage Area 9, the East and West Excess Ponds in drainage area 12, and Outfall IGP-009 in Drainage Area 11. Next, the Inspection Team and Facility representatives observed the Facility perimeter around the North and South Evaporation Ponds including Outfall IGP-011. To conclude the Facility walkthrough, the Inspection Team and Facility representatives observed the North Evaporation Stormwater Holding Pond, as well as the industrial process areas, stormwater drainage pathways, and control measures in Drainage Areas 7 and 8. Photographs of the above-described areas are referenced from Appendix A as applicable in the Findings, Corrective Actions and Recommendations Section of this report. After the Facility walkthrough, preliminary findings were discussed during a closing conference with Mr. Hensgen, Ms. Smith, Mr. Perkerewicz, Mr. Work, and Mr. Snell. Facility Operators, Tommy Novotny and Tyler Whitt, also joined for the closing conference. Additional documents, including a revised version of the SWPPP, weekly and quarterly inspection reports for the third quarter of 2024, and the operator training logs were requested to be emailed to the inspectors following the inspection. The Inspection Team left the Facility at 15:00. Harvest Four Corners, LLC 4 of 12 NPDES Stormwater Industrial and Construction Inspection Report Findings, Corrective Actions and Recommendations Finding 1: The Permittee's SWPPP site map did not contain all elements required by the Permit. Specifically, the SWPPP map did not contain the locations of: a. All stormwater conveyances including ditches, pipes, and swales. For example, the site map does not show all ditches that convey stormwater to Facility ponds and outfalls, or subsurface connections between storm drain inlets (refer to Appendix B, Exhibit 1). b. All stormwater pollutant sources. For example, the site map does not show dredge material stockpiles outside the Facility fence line in the east area of the Facility (refer to Appendix A, Photographs 9 and 10 and Appendix B, Exhibit 1). c. Stormwater monitoring points (refer to Appendix B, Exhibit 1). d. Locations of stormwater run-on to the Facility from neighboring properties (refer to Appendix B, Exhibit 1). The Inspection Team observed one location along the Facility's northeast perimeter (Drainage Area 15) where stormwater appeared to flow onto the Facility from the neighboring undeveloped property (refer to Appendix A, Photographs 11 and 12). e. All stormwater inlets and discharge points, with a unique identification code for each discharge point and an approximate outline of the areas draining to each discharge point. The Inspection Team also observed that the Drainage Areas identified on the site map are not correlated with the Facility's outfalls and do not accurately portray stormwater drainage throughout the Facility. For example, Drainage Area 15 contains three outfalls, and many of the drainage areas contain zero outfalls (refer to Appendix B, Exhibit 1). Facility representatives stated that Gosney Pond, which discharges to Outfall IGP-011, receives drainage from many areas of the Facility beyond Drainage Area 13. Outfall IGP-006 is not located on the Facility's perimeter and therefore does not represent a location where stormwater discharges from the Facility (refer to Appendix B, Exhibit 1). The Inspection Team observed eight potential unidentified stormwater outfalls along the Facility's perimeter (refer to Appendix A, Photographs 12 through 25): o Drainage Area 15 contains three outfalls on the site map; however the Inspection Team observed an additional three potential outfalls (refer to Appendix A, Photographs 12 through 14, 17, 18 and 25). o Drainage Area 11 contains one outfall on the site map; however, the Inspection Team identified an additional potential outfall (refer to Appendix A, Photographs 19 and 20). o Drainage Area 14 contains one outfall on the site map; however, the Inspection Team identified four additional potential outfalls (refer to Appendix A, Photographs 21 through 24). Permit requirements: Part 6.2.2.3 of the Permit requires the Permittee's SWPPP to include a site map "showing: a. Boundaries of the property and the size of the property in acres; b. Location and extent of significant structures and impervious surfaces; c. Directions of stormwater flow (use arrows), including flows with a significant potential to cause soil erosion; Harvest Four Corners, LLC 5 of 12 NPDES Stormwater Industrial and Construction Inspection Report Findings, Corrective Actions and Recommendations d. Locations of all stormwater control measures; e. Locations of all receiving waters, including wetlands, in the immediate vicinity of your facility. Indicate which waterbodies are listed as impaired and which are identified by your state, tribe, or EPA as Tier 2, Tier 2.5, or Tier 3 waters; f. Locations of all stormwater conveyances including ditches, pipes, and swales; g. Locations of potential pollutant sources identified under Part 6.2.3.2; h. Locations where significant spills or leaks identified under Part 6.2.3.3 have occurred; i. Locations of all stormwater monitoring points; j. Locations of stormwater inlets and discharge points, with a unique identification code for each discharge point (e.g., 001, 002), indicating if you are treating one or more discharge points as "substantially identical" under Parts 3.2.4.5, 6.2.5.3, and 4.1.1, and an approximate outline of the areas draining to each discharge point; k. If applicable, municipal separate storm sewer systems (MS4s) and where your stormwater discharges to them; l. Areas of Endangered Species Act-designated critical habitat for endangered or threatened species, if applicable. m. Locations of the following activities where such activities are exposed to precipitation: i. fueling stations; ii. vehicle and equipment maintenance and/or cleaning areas; iii. loading/unloading areas; iv. locations used for the treatment, storage, or disposal of wastes; v. liquid storage tanks; vi. processing and storage areas; vii. 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; viii. transfer areas for substances in bulk; ix. machinery; x. locations and sources of run-on to your site from adjacent property that contains significant quantities of pollutants." Corrective Action: In accordance with Part 6.2.2 of the Permit, update the site map to include the locations of all stormwater conveyances including ditches, pipes, and swales, all stormwater pollutant sources, stormwater monitoring points, and all stormwater inlets and discharge points, with a unique identification code for each discharge point and an approximate outline of the areas draining to each discharge point. Include the updated site map in the SWPPP and submit the updated SWPPP and site map to EPA. Harvest Four Corners, LLC 6 of 12 NPDES Stormwater Industrial and Construction Inspection Report Findings, Corrective Actions and Recommendations Finding 2: The Facility Plant Operators who were present at the closing conference stated that they have not been trained on how to properly collect representative stormwater samples. Additionally, the Inspection Team observed that the Permittee's stormwater training slides did not include content on stormwater sampling. The Facility Plant Operators are responsible for collecting stormwater samples in accordance with the monitoring requirements in Part 4 of the Permit. Based on conversations with Facility representatives, they collect samples from the downstream end of the North Stormwater Holding Pond when they open the valve to discharge flow to Outfall IGP-011 following significant storm events. The Permittee reported two discharge events in 2024 (on 6/22/24 and 9/17/24) where samples were taken from sample point 5 at Outfall IGP-011. Facility representatives explained that the remaining outfalls had insufficient flow to capture a sample during both discharge events. After collecting the samples, the Plant Operators send the samples to Eurofins (formerly Hall Environmental) in Albuquerque, New Mexico for analysis. Permit requirements: Part 2.1.2.8a of the Permit (Type of Personnel Who Require Training) states "You must train all employees who work in areas where industrial materials or activities are exposed to stormwater, or who are responsible for implementing activities necessary to comply with this permit (e.g., inspectors, maintenance personnel), including all members of your stormwater pollution prevention team. You must ensure the following personnel understand the requirements of this permit and their specific responsibilities with respect to those requirements: i. Personnel who are responsible for the design, installation, maintenance, and/or repair of controls (including pollution prevention measures); ii. Personnel responsible for the storage and handling of chemicals and materials that could become pollutants discharged via stormwater; iii. Personnel who are responsible for conducting and documenting inspections and monitoring as required in Parts 3 and 4; and iv. Personnel who are responsible for taking and documenting corrective actions as required in Part 5. Section B.10 of Appendix B of the Permit (Monitoring and Records) specifies additional monitoring requirements. Corrective Action: In accordance with Part 2.1.2.8 of the Permit, ensure that all personnel responsible for conducting stormwater monitoring (Permit Section 4) understand the requirements of the Permit and their specific responsibilities with respect to those requirements. Provide the EPA with a written narrative description of the corrective action to address this finding. Harvest Four Corners, LLC 7 of 12 NPDES Stormwater Industrial and Construction Inspection Report Findings, Corrective Actions and Recommendations Finding 3: The Inspection Team observed stormwater pollutant sources without overhead cover or other control measures implemented to minimize pollutant discharges in stormwater runoff. Specifically, the Inspection Team observed: a. Uncovered and uncontained piles of dredged sediment located outside of the fence line in the north area of the Facility (refer to Appendix A, Photographs 9 and 10). b. Uncovered and uncontained piles of dredged sediment located outside the Soil Drying Containment area in Drainage Area 15 (refer to Appendix A, Photographs 26 and 27). c. Scrap and reclaimed metal parts stored directly on the ground and without containment or overhead cover in the boneyard in the east area of the Facility, as well as upgradient from Gosney Pond in the northwest area of the Facility (refer to Appendix A, Photographs 28 through 34). Some of the metal materials in the boneyard were stored on pallets or racks to prevent direct contact with stormwater flow, but many of the materials were sitting directly on the ground. d. An uncovered scrap metal dumpster in the boneyard (refer to Appendix A, Photographs 35 and 36). The Inspection Team observed liquid leaking from the dumpster (refer to Appendix A, Photograph 37). Permit requirements: Part 2.1 (Stormwater Control Measures) of the Permit states, "You must select, design, install, and implement stormwater control measures (including best management practices) to minimize pollutant discharges that address the selection and design considerations in Part 2.1.1, meet the non-numeric effluent limits in Part 2.1.2, meet limits contained in applicable effluent limitations guidelines in Part 2.1.3, and meet the water quality-based effluent limitations in Part 2.2. The selection, design, installation, and implementation of control measures to comply with Part 2 must be in accordance with good engineering practices and manufacturer's specifications. Note that you may deviate from such manufacturer's specifications where you provide justification for such deviation and include documentation of your rationale in the part of your SWPPP that describes your control measures, consistent with Part 6.2.4. You must modify your stormwater control measures per Part 5.1 if you find that your control measures are not achieving their intended effect of minimizing pollutant discharges (i.e., your discharges will be controlled as necessary such that the receiving water of the United States will meet applicable water quality standards or meet any of the other non-numeric effluent limits in this permit). Regulated stormwater discharges from your facility include stormwater run-on that commingles with stormwater discharges associated with industrial activity at your facility. 2.1.1 Stormwater Control Measure Selection and Design Considerations. You must consider the following when selecting and designing control measures: 2.1.1.1 Preventing stormwater from coming into contact with polluting materials is generally more effective, and less costly, than trying to remove pollutants from stormwater; 2.1.1.2 Using stormwater control measures in combination may be more effective than using control measures in isolation for minimizing pollutants in your stormwater discharge; Harvest Four Corners, LLC 8 of 12 NPDES Stormwater Industrial and Construction Inspection Report Findings, Corrective Actions and Recommendations 2.1.1.3 Assessing the type and quantity of pollutants, including their potential to impact receiving water quality, is critical to designing effective stormwater control measures that will achieve the limits in this permit; 2.1.1.4 Minimizing impervious areas at your facility and infiltrating stormwater onsite (including bioretention cells, green roofs, and pervious pavement, among other approaches) can reduce the frequency and volume of discharges and improve ground water recharge and stream base flows in local streams, although care must be taken to avoid ground water contamination; 2.1.1.5 Attenuating flow using open vegetated swales and natural depressions can reduce in-stream impacts of erosive flows; 2.1.1.6 Conserving and/or restoring riparian buffers will help protect streams from stormwater discharges and improve water quality; 2.1.1.7 Using treatment interceptors (e.g., swirl separators and sand filters) may be appropriate in some instances to minimize the discharge of pollutants..." Corrective Action: In accordance with Part 2.1 of the Permit, select, design, install, and implement stormwater control measures to minimize pollutant discharges in stormwater runoff from dredged sediment and scrap and reclaimed metal materials. Provide the EPA with a written narrative description and photographs of the corrective actions to address this finding. Harvest Four Corners, LLC 9 of 12 NPDES Stormwater Industrial and Construction Inspection Report Findings, Corrective Actions and Recommendations Finding 4: The Inspection Team observed unstabilized slopes throughout the Facility with evidence of erosion (e.g., rills). Specifically, the Inspection Team observed evidence of erosion at the following locations: a. The bank of the ditch that drains into Gosney Pond (refer to Appendix A, Photograph 38). b. The stormwater drainage pathway along the fence line in northeastern corner of Drainage Area 5 (refer to Appendix A, Photograph 39). c. The western bank of the decommissioned West Excess Pond (refer to Appendix A, Photographs 40, 41, and 42). d. The western bank of the ditch leading to Outfall IGP-011 from the culvert at the western end of the North Evaporation Stormwater Holding Pond (refer to Appendix A, Photograph 43). e. Along the fence line in Drainage Area 15, south of the Soil Drying Containment area (refer to Appendix A, Photograph 44). f. The stormwater drainage pathway leading to West Excess Pond (refer to Appendix A, Photograph 45). g. A slope upgradient from a stormwater drainage path in Drainage Area 15 which leads to Outfall IGP-006 (refer to Appendix A, Photograph 46). h. The bank of the ditch near the parking lot in the west area of the Facility, which drains to North Evaporation Stormwater Holding Pond (refer to Appendix A, Photograph 47). The Inspection Team observed accumulated sediment and gravel in stormwater conveyances and drainage pathways, as well as at Facility outfalls. Specifically, the Inspection Team observed accumulated sediment and/or gravel at the following locations: i. In the North Evaporation Stormwater Holding Pond, as well as in the inlets, ditches, culverts and drainage channel that drain to and from of the pond (refer to Appendix A, Photographs 48 through 57). j. In a stormwater holding pond that receives drainage from Drainage Area 7 and drains to North Evaporation Holding Pond (refer to Appendix A, Photographs 58 and 59). k. In Gosney Pond, as well as in the culverts and ditches that convey stormwater both into and from Gosney Pond (refer to Appendix A, Photographs 60 through 69). l. The ditch upgradient from Outfall IGP-001 (refer to Appendix A, Photographs 70, 71, and 72) m. A drainage ditch in the northwestern corner of Drainage Area 15, which drains to Outfall IGP- 003 (refer to Appendix A, Photographs 73 and 74). n. Inside the catch basin of an unprotected storm drain inlet just west of the Make-Up Water Tank area, in Drainage Area 1 (refer to Appendix A, Photographs 75 and 76). o. Inside the catch basins of a series of connected storm drain inlets along the Facility's north perimeter (refer to Appendix A, Photographs 77 through 82). No inlet protection control measures were implemented to prevent material from entering the catch basins. p. In two culverts in Drainage Area 15 that ultimately drain to Outfall IGP-003 (refer to Appendix A, Photographs 83 through 87). q. Immediately upgradient from Outfall IGP-004 (refer to Appendix A, Photographs 88, 89, and 90). Harvest Four Corners, LLC 10 of 12 NPDES Stormwater Industrial and Construction Inspection Report Findings, Corrective Actions and Recommendations r. A drainage ditch conveying stormwater from the northern corner of Drainage Area 6 to Outfall IGP-006 (refer to Appendix A, Photographs 91 through 94). s. A culvert and stormwater drainage pathways upgradient from Outfall IGP-009, south of the East and West Excess Ponds (refer to Appendix A, Photographs 95 through 99). t. In a ditch along the west berm of Clearwater Pond in the south-central area of the Facility (refer to Appendix A, Photograph 100). u. Upgradient from a culvert that drains into the boneyard in Drainage Area 6 (refer to Appendix A, Photograph 101). v. Inside the Outfall IGP-011 discharge pipe and in the stormwater drainage pathway upgradient from Outfall IGP-011 (refer to Appendix A, Photographs 102, 103, and 104). Permit requirements: Part 2.1.2.5 (Erosion and Sediment Control) of the Permit states: "To minimize pollutant discharges in stormwater, you must minimize erosion by stabilizing exposed soils at your facility and placing flow velocity dissipation devices at discharge locations to minimize channel and streambank erosion and scour in the immediate vicinity of discharge points. You must also use structural and non-structural control measures to minimize the discharge of sediment. If you use polymers and/or other chemical treatments as part of your controls, you must identify the polymers and/or chemicals used and the purpose in your SWPPP. There are many resources available to help you select appropriate SCMs for erosion and sediment control, including EPA's Stormwater Discharges from Construction Activities website at: https://www.epa.gov/npdes/stormwater-discharges-construction-activities." Corrective Action: In accordance with Part 2.1.2.5 of the Permit, stabilize exposed soils and use flow velocity dissipation devices at discharge locations to minimize channel and streambank erosion and scour in the immediate vicinity of discharge points. Use structural and non-structural control measures to control the discharge of sediment. Provide the EPA with a written narrative description and photographs of the corrective actions to address this finding. Finding 5: The Inspection Team observed stormwater control measures in need of maintenance throughout the Facility. Specifically, the Inspection Team observed: a. Catch basins containing sediment and rocks above outlet pipes (refer to Appendix A, Photographs 75 through 82). No control measures were implemented to minimize material entering the catch basin inlets. b. Straw wattles that were deteriorated and/or had sediment accumulated against them (refer to Appendix A, Photographs 105 and 106). Additionally, wattles installed around the Soil Drying Containment area in the northwest area of the Facility appeared to have been recently installed, but there were gaps between some consecutive segments creating potential for sediment to leave the site (refer to Appendix A, Photographs 107, 108, and 109). c. Sediment accumulated against a straw wattle that had been installed along the southeastern fence line of Drainage Area 14, next to the South Evaporation Pond (refer to Appendix A, Photographs 110 and 111). Harvest Four Corners, LLC 11 of 12 NPDES Stormwater Industrial and Construction Inspection Report Findings, Corrective Actions and Recommendations x A concrete washout area in the northeast area of the Facility (Drainage Area 15) that was more than half full (refer to Appendix A, Photograph 112). Additionally, the Inspection Team observed that Facility's routine self-inspection reports from 8/15/2024, 8/21/2024 and 2/28/2025 identified straw wattles in need of replacement around the dredged sediment piles in the northeast area of the Facility. However, the other maintenance issues listed above were not identified in the Facility's self-inspection records. Permit requirements: Part 2.1.2.3.a (Maintenance Activities) of the Permit states, "You must maintain all control measures that are used to achieve the effluent limits in this permit in effective operating condition, as well as all industrial equipment and systems, in order to minimize pollutant discharges. This includes: ii. Performing inspections and preventive maintenance of stormwater drainage, source controls, treatment systems, and plant equipment and systems that could fail and result in discharges of pollutants via stormwater. iii. Maintaining non-structural control measures (e.g., keep spill response supplies available, personnel appropriately trained). iv. Inspecting and maintaining baghouses at least quarterly to prevent the escape of dust from the system and immediately removing any accumulated dust at the base of the exterior baghouse.* v. Cleaning catch basins when the depth of debris reaches two-thirds (2/3) of the sump depth, or in line with manufacturer specifications, whichever is lower, and keeping the debris surface at least six inches below the lowest outlet pipe." Corrective Action: In accordance with Part 2.1.2.3.a of the permit, ensure that all stormwater control measure maintenance needs are identified through inspections and maintenance is conducted as needed to keep control measures in effective operating condition. Provide the EPA with a written narrative description and photographs of the corrective actions to address this finding. 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