Document jmDBLbzwYYYprJL6g0JgN3QVy

EPA Inspection ReportPage 1 of 154 0" EPAu~ ...,, is,.., , _ Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 07/06/2016 Water CWA Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Evangeline Enterprises, L.L.C. Evangeline Training Center 3620 N.E. Evangeline Throughway Carencro, LA 70520 P.O. Box 729 Carencro, LA 70520 Lafayette Parish A.J. Credeur I General Manager ajcredeur@j'.ahoo.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: N/A LAU004016 N/A 711212 7948 Personnel participating in inspection: A.J. Credeur Evangeline Training Center Juan Ibarra EPA/6EN-WR Abu Senkayi EPA/6EN-WR General Manager Inspector Enforcement Officer 337-896-4268 214-665-8493 214-665-8403 EPA Lead Inspector Signature/Date Supervisor Signature/Date .,,,, ~ / /Y / /' . ( 4//B/4~~~ /./-} -~ - l . ,, ,, I - -I I / -:/} ,;/./_ I /// / M b _,.U7I' ~ ,!() / /r~/'-J / I / 57/.5/.;Lt?/, / Date I .. I I )( /J tJ / 2fi ~-/ ,/_..../ , I 6ENFORM-019-R6 (10/6/14) 1 EPA Inspection ReportPage 2 of 154 Evangeline Enterprises, L.L.C. / Evangeline Training Center Inspection Date 07/06/2016 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors, Juan Ibarra and Abu Senkayi, arrived at the Evangeline Enterprises, L.L.C./Evangeline Training Center (facility) at 0847 hours on July 6, 2016, for an unannounced inspection. Abu Senkayi and I presented our credentials to the Security Staff at the front gate to gain site access, and then to Mr. A.J. Credeur/General Manager when he arrived at the facility office. We informed Mr. Credeur that we would be conducting an EPA inspection to determine compliance with the facility's previously issued EPA Administrative Orders, and the Clean Water Act (CWA). The scope of the inspection was a full compliance evaluation (FCE) which included an evaluation of the facility's physical site and operational conditions. Mr. Credeur accompanied the inspectors during a portion of the site inspection that involved the demolition of six horse barns, but was not available for the end of the site inspection. The facility was initially inspected by EPA on June 26, 2013. Subsequently, a Cease and Desist Order (CWA-06-2013-1861) was issued on July 29, 2013. The Order required the facility to cease and desist all discharges of pollutants from the production area, and submit a plan summarizing the activities implemented to stop the unpermitted discharges. The facility submitted a response dated September 11, 2013, but it did not provide a plan to eliminate the discharges. A second Administrative Order (CWA06-2014-1852) was issued to the facility on November 17, 2014, again requesting a plan and schedule to construct a properly designed wastewater retention structure, and collect process wastewater samples from the three outfalls during rainfall events greater than 0.5". A second EPA/LDEQ inspection was conducted January 15, 2015, to follow up on the facility's compliance with the previously issued Administrative Orders. Aside from removing the washing machines from the horse barns, no operational changes were made to eliminate the discharge of horse wash rack process wastewater and manure contaminated storm water runoff. An Administrative Complaint (Penalty Order CWA-06-2015-1717) was issued to the facility on February 9, 2015. However, the Penalty Order was withdrawn on August 27, 2015 because EPA decided to refer the facility to the Department of Justice for further action including injunctive relief. As of the day of this inspection, the facility had not eliminated their unpermitted discharges (thru the three outfalls), and had not begun the design work to construct a proper wastewater retention structure. The purpose of this inspection was to document the operating conditions at the facility, and determine if any changes had occurred to the operation since the four previous EPA inspections conducted on June 26, 2013, January 15, 2015, September 22, 2015, and January 28-29, 2016. We completed the inspection at 1532, and exited the facility without being able to hold a Closing Conference with Mr. Credeur. 2 EPA Inspection ReportPage 3 of 154 Evangeline Enterprises, L.L.C. / Evangeline Training Center Inspection Date 07/06/2016 FACILITY DESCRIPTION As described in the initial EPA inspection (conducted on June 26, 2013) the facility was a large unpermitted CAFO with 28 horse barns and 520 horses at the time of the inspection (the number of horse barns has now changed as described below). The total capacity during the first inspection was 1260 horses, however, at the time of this inspection there were approximately 279 stabled horses. Each horse barn had four wash racks that discharge off property thru a series of manmade ditches that run parallel to the barns. Also, the facility has a Receiving Barn and small Pony Barn that provide stalls to horses that have come to the facility to work out on the track for a few hours, but not stay overnight. The production area had three outfalls which discharge commingled process wastewater and contaminated storm water runoff. The facility experienced unpermitted discharges of process wastewater from the production area during both wet and dry weather periods thru these outfalls. Process wastewater consists of horse wash rack water, horse pool back-wash water, and contaminated storm water from the horse stable production area (including manure bins, walkers and walkway areas). Production area (contaminated) storm water included runoff from the manure and waste bedding concrete storage bins, the pasture manure storage area, exposed raw materials storage areas, walkers and walkway areas. Non-contact storm water commingled with the other wastewaters and consisted of barn roof runoff. All storm water commingled with process wastewater became process wastewater. An additional unpermitted point of discharge developed when the facility began using a pasture manure storage area located about 120' west of the Unnamed Tributary of Francois Coulee, and approximately 350' east of the horse barns (See Appendix I Photograph Log, photos 31-35). This manure storage area was first documented during the January 28-29, 2016, inspection report Photograph Log which showed that the storage pile had discharged (prior to the inspection) nutrient laden storm water runoff into the Unnamed Tributary of Francois Coulee. This storage process did not constitute composting management, but rather improper disposal. Furthermore, manure composting operations must be done within the watershed of a lagoon which contains the runoff from the 25-yr/24-hr rain event. As described in Section II Observations - Facility Housekeeping and Unpermitted Discharges, and Potential for Unpermitted Discharges from C&D Waste/Pasture Manure Storage below, the facility recently (since the previous January 28-29, 2016 EPA inspection) excavated an unpermitted (on-site) Construction and Demolition (C&D) waste landfill located between the Unnamed Tributary of Francois Coulee and the pasture manure storage area. The C&D landfill had the potential to contribute pollutants to the Unnamed Tributary of Francois Coulee (in the same area of the creek as the pasture storage area) should the excavation pit fill with storm water. The facility also had a 4.5 acre sanitary sewage oxidation pond and lift station located in the center of the practice track. The pond received gravity flow sanitary wastewater from the production area's four barn restrooms (located in Barns D, J, M, and P), the new restroom and shower building that housed four sets of restrooms, and the laundry area. The oxidation pond once served the grandstands, which no longer exist, when the facility used to hold racing events. This oxidation pond was designed as a "no discharge" sanitary sewage treatment unit. 3 EPA Inspection ReportPage 4 of 154 Evangeline Enterprises, L.L.C. / Evangeline Training Center Inspection Date 07/06/2016 Section II - OBSERVATIONS Unpermitted Discharges and Discharge Routes into the Vermilion River The EPA inspection reports from the June 26, 2013 and January 28-29, 2016 inspections document the route of the southeast (SE), west (W), and northeast (NE) outfalls into the Vermilion River. At the time of this inspection, the facility was experiencing an unpermitted discharge of process wastewater from the W and SE outfalls (no samples were taken), but there was no discharge from the NE outfall at that time. The SE outfall discharged into the Unnamed Tributary of Francois Coulee, which then merged with Francois Coulee, thence into the Vermilion River, a Water of the U.S. The W outfall discharged into a drainage ditch which crosses under I-49 and enters Francois Coulee, thence the Vermilion River. Facility Housekeeping and Unpermitted Discharges During the inspection, we found most of the same repeat sources of process wastewater and commingled contaminated storm water discharges as those described in the four previous EPA inspections conducted on June 26, 2013, January 15, 2015, September 22, 2015, and January 28-29, 2016. The sources of unpermitted contaminated process wastewater discharges (thru the three facility outfalls) continued to include unabated discharges from the horse wash racks into the facility's manmade drainage channels, contaminated storm water runoff from the manure waste storage bins (photos 24, 26-29), and storm water runoff from the horse walker/walkway areas. Additionally, a pair of sand filters, used to back-wash water at the horse swimming ring (not mentioned in the previous EPA inspection reports) also discharged process wastewater into the manmade drainage channels that would discharge thru the SE outfall (photos 17-19). The pasture manure storage area continued to have runoff potential into the Unnamed Tributary of Francois Coulee, even though a catch basin had been excavated to reduce runoff discharges (had about a foot of freeboard). However, a new potential source of runoff (not seen during prior inspections, but documented within this inspection report) was an excavated pit for C&D waste, located between the pasture manure storage pile and the Unnamed Tributary of Francois Coulee. Manure Bin Management The Photograph Log (photos 24-30) documents that the manure bins continued to have unabated storm water exposure, spillage and track out that would generate contaminated runoff into the drainage channels during rainfall events. This issue, which was documented in the previous EPA inspection reports, includes frequently seen spillage over the back wall of the manure bins. Additionally, according to the facility's submitted response (to EPA Administrative Order CWA-06-2014-1861) dated September 11, 2013, the facility stated that they would begin using tarps to cover the manure bins to minimize exposure to storm water. However, none of the manure storage bins were covered at the time of the inspection. The tarps were observed laying against the back side of the bins. Additionally, it was noted that each of the manure bins had a slight slope toward the adjacent concrete wash rack ditch to help channel contaminated storm water runoff into the ditch collection system. 4 EPA Inspection ReportPage 5 of 154 Evangeline Enterprises, L.L.C. / Evangeline Training Center Inspection Date 07/06/2016 Potential for Unpermitted Discharges from C&D Waste/Pasture Manure Storage The facility had recently excavated a C&D waste storage pit (an unpermitted landfill containing waste from the barn demolition) situated about 60' from the Unnamed Tributary of Francois Coulee, and located immediately east of the pasture manure storage area. Additionally, a storm water collection pit was excavated at the northeast side of the pasture manure storage area to capture storm water runoff from the manure storage area prior to discharging into the Unnamed Tributary of Francois Coulee. Neither the C&D pit, nor the pasture manure storage area pit were discharging at the time of the inspection. The manure storage pit had about a foot of freeboard, and the C&D pit appeared to have several feet of freeboard. It appeared that the pasture manure storage pile had not changed since the prior EPA inspection conducted January 28-29, 2016 (with the exception of the storm water pit). As such, the facility was not complying with the composting design submitted by the facility to LDAF in January 2007, but rather was dumping the manure in large piles. This storage process did not constitute composting management, but rather improper disposal. Furthermore, manure composting operations must be done within the watershed of a lagoon which contains the runoff from the 25-yr/24-hr rain event. Mr. Credeur stated that the manure was currently given to a farmer named Phillip Melancon to whom the facility hauls manure, a composting operation (owned by Ken Arceneaux) that sold the material as "Poo-Yie" at a local businesses (Lafayette Materials), and to a wholesale nursery named Live Oak Gardens (in New Iberia). However, Mr. Credeur did not maintain manure disposal records. Demolition of Six Horse Barns and Other Closures At the time of the inspection, the facility had demolished six horse barns (E thru H, V and W) which included the restrooms that were located in Barns G and V. Mr. Credeur had earlier stated that the C&D waste was being sent to the Livonia, Louisiana landfill operated by Waste Management, however, some of the C&D waste was found in the on-site unpermitted landfill. Mr. Credeur was not available at the end of the day/inspection to discuss the source of the waste material in the on-site landfill. Mr. Credeur also stated that he was preparing to demolish Barns T and U, and that R and S would follow. Mr. Credeur said that the owner, Mr. Castille, had indicated that he intended to take down a total of 15 barns, however, Mr. Credeur did not know which of the remaining barns would constitute the last five of the 15 total barn demolitions. At the locations where barns had been demolished, the horse walkers had been removed, and the facility planned to sell them. At this point in time, 15 horse walkers had been taken down. Also, some of the manure storage bins had been removed. Mr. Credeur also said that some of the barns (G and H) were so termite infested that the wooden structures crumbled like powder. Also, Mr. Credeur stated that he thought that a year from now, it was possible that Evangeline Training Center may not exist. The facility had also closed the kitchen about two months prior to the inspection, sold the Chaplain's building, and planned to sell the kitchen building as well. 5 EPA Inspection ReportPage 6 of 154 Evangeline Enterprises, L.L.C. / Evangeline Training Center Inspection Date 07/06/2016 Horse Boarding and Water Use Records During the inspection, records were collected to document horse stall lease billing, a blank stall lease agreement, examples of weekly horse barn counts, and water usage billings. Following the inspection we received (by email) monthly summary information on horse stall billing records dating back to January 2013. Appendix 2 contains the horse stall billing records for total horse numbers, excluding the horses that the owner, Mr. Castille, had within Barn X (recently as many as 35-36 horses in May and June of 2016). Within Appendix 3 are two sample invoices for the month of June for horse barns A and L (billed 6/4/16), and the examples of how the facility conducts its weekly horse counts for the weeks of 5/24/16, 5/31/16, and 6/7/16. Appendix 4 contains the blank Stall Lease Agreement. The City of Carencro provides the water used in the production area. Production area water is used for horse wash racks, horse drinking water, and trainer water needs such as restrooms. The Evangeline Training Center receives a monthly water bill, for water used thru the 15th of each month. A summary of water usage (generally a little more than two million gallons per month, but sometimes less) from 11/15/2014 to 11/15/2015 were as follow: 11/15/14 to 12/15/15 - 1,699,500 12/15/15 to 1/15/15 - 2,331,480 1/15/15 to 2/15/15 - 1,864,070 2/15/15 to 3/15/15 - 1,961,540 3/15/15 to 4/15/15 - 2,506,890 4/15/15 to 5/15/15 - 2,042,929 5/15/15 to 6/15/15 - 2,374,410 6/15/15 to 7/15/15 - 2,075,170 7/15/15 to 8/15/15 - 2,471,180 8/15/15 to 9/15/15 - could not find 9/15/15 to 10/15/15 - could not find 10/15/15 to 11/15/15 - 2,034,970 6 EPA Inspection ReportPage 7 of 154 Evangeline Enterprises, L.L.C. / Evangeline Training Center Inspection Date 07/06/2016 Section III - AREAS OF CONCERN The following Areas of Concern were documented during the inspection: x As detailed in Section I, the facility has not complied with the two previously issued Administrative Orders to cease the unpermitted discharge of production area process wastewater. x The facility had unpermitted discharges of production area process wastewater from the facility's W and SE outfalls into Francois Coulee and the Unnamed Tributary of Francois Coulee (respectively), thence the Vermilion River. x Best Management Practices were not implemented to properly manage manure and waste bedding at the concrete manure bins, resulting in significant amounts of spillage and washout/track-out on the pavement and the barn ditch drainage system. x The C&D waste pit, and the pasture manure storage area and pit were located within approximately 60' to 120' (respectively) of the Unnamed Tributary of Francois Coulee. Both areas had the potential to discharge contaminated storm water into the Unnamed Tributary of Francois Coulee, and both activities were unpermitted waste disposal methods. x The facility was not composting manure and waste bedding according to the LDAF permit requirements. Additionally, any manure composting operations must be done within the watershed of a lagoon which contains the runoff from the 25-yr/24-hr rain event. x Unpermitted contaminated process wastewater discharges (thru the three facility outfalls) continued to include unabated discharges from the horse wash racks into the facility's manmade drainage channels, contaminated storm water runoff from the manure waste storage bins, and storm water runoff from the horse walker/walkway areas. Additionally, a pair of sand filters, used to back-wash water at the horse swimming ring, also discharges into the ditch leading to the SE outfall. Section IV - FOLLOW UP EPA will address the Areas of Concern with appropriate enforcement actions. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log -35 EPA photos taken 7/6/16 Appendix 2 - Monthly Horse Stall Billing Records Appendix 3 - Sample Invoices for Barns A and L, and Weekly Horse Counts Appendix 4 - Blank Stall Lease Agreement 7 EPA Inspection ReportPage 8 of 154 EPA Inspection ReportPage 9 of 154 Evangeline Enterprises, L.L.C. / Evangeline Training Center Inspection Date 7/6/2016 Appendix 1 Photograph Log EPA Inspection ReportPage 10 of 154 EPA Inspection ReportPage 11 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana W side of ditch system SE OTFL E side of Barn A-K ditch system Photo File Name: P7060001 Date of Photo: 7/6/2016 Time of Photo: 0900 Photographer: Juan Ibarra Description: Production area wastewater from the horse wash racks discharged thru the SE outfall. The source of the wastewater was the west side of the Barns A-K wash rack ditch system. The east side of the Barns A-K ditch system was not generating an off-site discharge at the time of the inspection. Estimated rate of flow was about 2-4 gpm. The water appeared relatively clear, and minnows were present. The view is toward the west. EPA Inspection ReportPage 12 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060002 Date of Photo: 7/6/2016 Time of Photo: 0904 Photographer: Juan Ibarra Description: All of the flow discharging thru the SE outfall was coming from the west side drainage ditch system of Barns A-K. The photo was taken from the south side of the facility's paved road where the west portion of the Barn A-K ditch system flowed under the facility entrance road and discharged thru the channel shown in photo 1. The view is looking west. Note that the bar ditch above the point where the wash rack discharge entered the drainage channel was dry, and not contributing any flow to the discharge from the production area. EPA Inspection ReportPage 13 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060003 Date of Photo: 7/6/2016 Time of Photo: 0905 Photographer: Juan Ibarra Description: Looking north, at the west horse wash rack ditch system that discharged wastewater from Barns A-K into the SE outfall. This production area wastewater was discharging thru the SE outfall at a rate of approximately 2-4 gpm. All of the flow discharging thru the SE outfall was coming from the west side drainage ditch system of Barns A-K. The photo was taken from the facility's paved road where the west portion of the Barn A-K ditch system flowed under the facility entrance road and discharged thru the channel shown in photo 1. EPA Inspection ReportPage 14 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060004 Date of Photo: 7/6/2016 Time of Photo: 0907 Photographer: Juan Ibarra Description: Close-up of the duck weed seen in photo 3. EPA Inspection ReportPage 15 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060005 Date of Photo: 7/6/2016 Time of Photo: 0915 Photographer: Juan Ibarra Description: Looking at the W outfall discharge point as it left the facility property, and entered the ditch that flowed toward I-49 as shown in photo 6. EPA Inspection ReportPage 16 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060006 Date of Photo: 7/6/2016 Time of Photo: 0916 Photographer: Juan Ibarra Description: Looking west at the discharge channel of the W outfall, as it flowed toward I-49. The new Fed-EX distribution center was under construction, immediately west of the Evangeline Training Center practice track. EPA Inspection ReportPage 17 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060007 Date of Photo: 7/6/2016 Time of Photo: 0921 Photographer: Juan Ibarra Description: Looking east (toward the horse practice track fence - white metal in the background) at the W outfall discharge channel. The photo was taken from the I-49 frontage road. Note the aquatic looking plants. There was no other contribution source to the water in this channel, other than the wash rack discharge coming thru the W outfall. EPA Inspection ReportPage 18 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060008 Date of Photo: 7/6/2016 Time of Photo: 0929 Photographer: Juan Ibarra Description: Looking south, from Sonnier Road, at the NE outfall. The channel was not discharging at the time of the inspection, but was holding standing water. About 50-60 feet downstream, the streambed was dry, as seen in photo 10. EPA Inspection ReportPage 19 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060009 Date of Photo: 7/6/2016 Time of Photo: 0929 Photographer: Juan Ibarra Description: Close-up of the water at the NE outfall. The water had a slight grey cast, the sediment had a dark color, and minnows were present. Also, there was no upstream contribution of flow from the bar ditch along Sonnier Road. EPA Inspection ReportPage 20 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060010 Date of Photo: 7/6/2016 Time of Photo: 0939 Photographer: Juan Ibarra Description: Looking north at the NE outfall drainage channel after it had flowed under Sonnier Road. The channel was dry within approximately 10' north of Sonnier Road. EPA Inspection ReportPage 21 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060011 Date of Photo: 7/6/2016 Time of Photo: 1002 Photographer: Juan Ibarra Description: A photo taken from Mr. Credeur's office, looking northeast. The photo showed a portion of the production area where horse Barns E-H had been razed. Additionally, Barns W and V (not shown) had also been razed, yielding a total of six demolished barns. Mr. Credeur stated that restrooms in Barns G and V were eliminated due to the demolition. Additionally, Mr. Credeur stated that the next barns scheduled for demolition were R, S, T and U, and that the owner, Mr. Castille, had indicated that he intended to take down 15 barns. However, Mr. Credeur did not know which of the remaining barns would constitute the last five of the 15 total barn demolitions. Also, Mr. Credeur stated that he thought that a year from now, it was possible that Evangeline Training Center may not exist. EPA Inspection ReportPage 22 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060012 Date of Photo: 7/6/2016 Time of Photo: 1156 Photographer: Juan Ibarra Description: Looking northwest at the area where horse Barns E-H had previously been located. Two of the manure bins (E and F) were still standing. EPA Inspection ReportPage 23 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060013 Date of Photo: 7/6/2016 Time of Photo: 1159 Photographer: Juan Ibarra Description: Looking north-northeast at the closed cafeteria. Mr. Credeur stated that the owner planned to sell the cafeteria building, and the former Chaplain's building (shown in photo 14) had already been sold. The laundry building located on the east side of the cafeteria building was still in operation. EPA Inspection ReportPage 24 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060014 Date of Photo: 7/6/2016 Time of Photo: 1200 Photographer: Juan Ibarra Description: Looking north-northeast at the former Chaplain's building and six of the removed horse walkers that will also be sold. EPA Inspection ReportPage 25 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060015 Date of Photo: 7/6/2016 Time of Photo: 1208 Photographer: Juan Ibarra Description: Looking north-northwest at the location of Barn W. Barn W (along with Barn V which was located to the right and not shown in this photo) was razed, and the C&D material was being sent to the Livonia Landfill operated by Waste Management using the manure transport truck. EPA Inspection ReportPage 26 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060016 Date of Photo: 7/6/2016 Time of Photo: 1208 Photographer: Juan Ibarra Description: Looking east-northeast at Barns T and U. Barn U (the closest of the two) was scheduled to be razed in the next day or so. EPA Inspection ReportPage 27 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060017 Date of Photo: 7/6/2016 Time of Photo: 1217 Photographer: Juan Ibarra Description: Looking south at the horse pool. The cafeteria was located on the other side of the trees and horse trailers. EPA Inspection ReportPage 28 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060018 Date of Photo: 7/6/2016 Time of Photo: 1217 Photographer: Juan Ibarra Description: Looking east at the horse pool back-wash filters. The filter back-wash discharges into the facility ditch drainage system (located next to the large tree), which would flow toward the SE outfall. EPA Inspection ReportPage 29 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060019 Date of Photo: 7/6/2016 Time of Photo: 1218 Photographer: Juan Ibarra Description: Looking east at the horse pool back-wash filter discharge lines (two white PVC lines) that would flow into the facility ditch drainage system (located next to the large tree). EPA Inspection ReportPage 30 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060020 Date of Photo: 7/6/2016 Time of Photo: 1219 Photographer: Juan Ibarra Description: Looking west at the horse pool back-wash filters (left) and a horse wash rack located next to horse pool. The wash rack discharge line would also discharge into the facility ditch drainage system. EPA Inspection ReportPage 31 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060021 Date of Photo: 7/6/2016 Time of Photo: 1331 Photographer: Juan Ibarra Description: Looking west at the facility's ground water storage tank (red tank on the left) and the tanker used to wet the track (on the right). Ground water was used solely to wet the horse practice track. The security entrance building was located in the distant background. EPA Inspection ReportPage 32 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060022 Date of Photo: 7/6/2016 Time of Photo: 1345 Photographer: Juan Ibarra Description: The point where the horse pool drainage channel goes west, under the facility's unpaved road. The pipe ran under the road for approximately 70', and would discharge into the East Ditch that led to the SE outfall. The view is looking east. EPA Inspection ReportPage 33 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060023 Date of Photo: 7/6/2016 Time of Photo: 1346 Photographer: Juan Ibarra Description: Looking at the horse pool drain line where it would channel discharge flow into the East ditch that would then flow to the SE outfall. EPA Inspection ReportPage 34 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060024 Date of Photo: 7/6/2016 Time of Photo: 1418 Photographer: Juan Ibarra Description: Looking southwest at the manure bin located on the north side of Barn S. This was the typical condition of the facility's manure bins at the time of the inspection. Note that all the manure bins were located immediately next to the concrete lined horse wash rack drainage channel, and that the bins were sloped to drain toward the horse wash rack drainage ditches. EPA Inspection ReportPage 35 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060025 Date of Photo: 7/6/2016 Time of Photo: 1420 Photographer: Juan Ibarra Description: Looking south-southeast at the back side of the manure bin located on the north side of Barn S. This spillage on the back side of the manure bins was also typical condition of the facility's manure bins at the time of the inspection. Note that this manure bin did not have a tarp. EPA Inspection ReportPage 36 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060026 Date of Photo: 7/6/2016 Time of Photo: 1421 Photographer: Juan Ibarra Description: Looking south-southwest at the manure waste that had discharged from the Barn S manure bin into the horse wash rack concrete drainage ditch. All manure bins were slightly sloped to drain storm water runoff into the horse wash rack drainage ditches. EPA Inspection ReportPage 37 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060027 Date of Photo: 7/6/2016 Time of Photo: 1424 Photographer: Juan Ibarra Description: Looking southwest at the manure bin located next to Barn R. Again, as was seen at Barn S, the manure bin had spillage outside of the bin walls, and sloped slightly toward the horse wash rack concrete drainage ditch. EPA Inspection ReportPage 38 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 28 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060028 Date of Photo: 7/6/2016 Time of Photo: 1427 Photographer: Juan Ibarra Description: Looking west at the Barn R manure bin located on the north side of the barn. The manure bin (on the right) was slightly sloped toward the concrete lined horse wash rack ditch, and would discharge contaminated storm water runoff to the facility outfalls. EPA Inspection ReportPage 39 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 29 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060029 Date of Photo: 7/6/2016 Time of Photo: 1430 Photographer: Juan Ibarra Description: One of the better maintained manure bins located at Barn I. Although the horse wash rack ditch was clean, there was some spillage, particularly on the back side of the bin. Still the bin was sloped to drain toward the horse wash rack ditch during rain events. Note: Barns X, Y, Z, Churchill and Belmont had manure bins located in the middle (between the horse barns) so that they did not directly discharge into the concrete horse wash rack drainage ditches. No photo was taken. EPA Inspection ReportPage 40 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 30 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060030 Date of Photo: 7/6/2016 Time of Photo: 1433 Photographer: Juan Ibarra Description: Looking south at the manure spillage on the back side of Barn I. This bin had a tarp laying over the back side of the manure bin, however, none of the facility manure bins were tarped at the time of the inspection. EPA Inspection ReportPage 41 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 31 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060031 Date of Photo: 7/6/2016 Time of Photo: 1511 Photographer: Juan Ibarra Description: Looking east at the pasture manure storage pile located in the pasture approximately 350' east of Barns A-B, and approximately 120' west of the Unnamed Tributary of Francois Coulee (located at the tree line). Note: There were about six trees that appeared dead, either from a fire that was burned in a new adjacent C&D waste pit or other unknown causes. EPA Inspection ReportPage 42 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 32 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060032 Date of Photo: 7/6/2016 Time of Photo: 1514 Photographer: Juan Ibarra Description: Looking southeast at the pasture manure storage pile. EPA Inspection ReportPage 43 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 33 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060033 Date of Photo: 7/6/2016 Time of Photo: 1514 Photographer: Juan Ibarra Description: Looking southeast at the new excavated storm water catch basin, located at the northeast side of the pasture manure storage pile. The new pit appeared to have been constructed to contain storm water runoff from the manure storage pile, which during the 1/28-29/2016 inspection showed evidence of having a discharge to the Unnamed Tributary of Francois Coulee. EPA Inspection ReportPage 44 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 34 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060034 Date of Photo: 7/6/2016 Time of Photo: 1515 Photographer: Juan Ibarra Description: Looking south at the new excavated storm water catch basin, located at the northeast side of the pasture manure storage pile. The new pit appeared to have been constructed to contain storm water runoff from the manure storage pile, which during the 1/28-29/2016 inspection showed evidence of having a discharge to the Unnamed Tributary of Francois Coulee. The pasture manure storage pile is located on the right, and the excavated sand is located on the left. The catch basin had about a foot of freeboard. EPA Inspection ReportPage 45 of 154 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 35 Location: Evangeline Enterprises, L.L.C. / Evangeline Training Center City: Carencro Parish: Lafayette State: Louisiana Photo File Name: P7060035 Date of Photo: 7/6/2016 Time of Photo: 1516 Photographer: Juan Ibarra Description: Looking south at the new excavated storm water catch basin. 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