Document jy53rOpER2YJ2kaVwNVQ1XwDk

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 02/16/2023 09:08 AM (PT) 02/16/2023 11:00 AM (PT) Sunny, 45F Water Clean Water Act, NPDES, Industrial Industrial Stormwater Inspection Announced: No Access: Granted Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Mailing Address City, State, Zip Code Interstate Concrete and Asphalt Interstate Concrete and Asphalt - Richland Facility 2505 Robertson Drive Richland, WA 99352 Benton County 46.321889, -119.288002 P.O. Box 3366 Spokane, Washington 99220-3366 FRS ID Permit Number NAICS ORT9663738365 WAG505182 212321 - Construction Sand and Gravel Mining 327320 - Ready-Mix Concrete Manufacturing 327390 - Other Concrete Product Manufacturing Lead Inspector: RAYMOND ANDREWS Date: 2023.04.11 07:44:07 -07'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2023.04.11 09:59:20 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA Region 10 contreras.peter@epa.gov (206) 553-6708 Page 1 of 8 Interstate Concrete and Asphalt - Richland Facility WAG505182 SECTION I - INTRODUCTION Site Entry and Inspection Objectives I arrived at the Interstate Concrete and Asphalt - Richland site (the "Site" or "Facility") for an unannounced inspection. I presented my inspector credentials to Jana McDonald and informed her I was there to determine compliance with the Clean Water Act (CWA) and the Washington Department of Ecology's (WDOE) Sand and Gravel General Permit. This report is based on information and documentation supplied by Interstate Concrete and Asphalt and direct observations made during the inspection. 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 Title EPA Region 10 Raymond Andrews Lead Inspector CRH Americas Materials, Inc. CRH Americas Materials, Inc CRH Americas Materials, Inc Jana McDonald Environmental Manager Kelby Johnson Ready Mix General Manager Jimmie Roper Ready Mix Site Superintendent Present in Opening Conf. Yes Yes Yes Yes Present in Closing Conf. Yes No No No Site Information: Responsible Official What is the principal product generated? Type of Operation Mike McBreen, Vice President, michael.mcbreen@na.crh.com The principal product produced is concrete. The raw material, i.e., sand and gravel, required to produce concrete is quarried onsite. The quarried materials are then sent to the Wash Plant to be separated into its different components. Most of the quarried material is used as inputs to make concrete but some is sold on the retail market. Size of Facility Outfalls? Parameters monitored? Concrete produced at the facility is primarily sold on the retail market; however, some is made into other products such as ecology blocks. 227 acres No outfalls are identified in the Site Management Plan (SMP) or Site map; however, there is an outfall identified as 001 in the Notice of Intent for permit coverage renewal dated September 29, 2020. The facility is only required to monitor pH, which is monitored in-house. The pH meter is calibrated prior to each use and the calibration buffer solutions are within their expiration dates. Page 2 of 8 SECTION II - OBSERVATIONS Interstate Concrete and Asphalt - Richland Facility WAG505182 We walked the production portion first, and then drove to the back of the property where sand and gravel quarrying operations occurred (Photos 1 & 2) as needed to acquire more raw materials for production. At the time of my visit to the quarry area, minimal activity was on-going. Photo 1/P1010587 - Quarry Area, facing north Photo 2/P1010588 - Quarry Side Wall, facing east In the production area, there were gravel and sand piles located around the site. The topography of the site appeared to be graded slightly down towards the north (Photo 3). On the northern perimeter of the property is a berm that helps keep any stormwater on-site (Photo 4). The northern perimeter berm is a remnant from when the front area was quarried. Page 3 of 8 Interstate Concrete and Asphalt - Richland Facility WAG505182 Photo 3/P1010578 - Gravel Piles, site graded down to north Photo 4/P1010580 - Gravel Piles, berm to north As I stated in "Site Information" above, the quarried material is sent to a Wash Plant. The Wash Plant discharges wastewater into a gulley where it infiltrates (Photos 5 - 7). Page 4 of 8 Interstate Concrete and Asphalt - Richland Facility WAG505182 Discharge Pipe from Wash Plant Photo 5/P1010581 - Discharge from Wash Plant, photo 1 Photo 6/P1010582 - Discharge from Wash Plant, photo 2 Page 5 of 8 Interstate Concrete and Asphalt - Richland Facility WAG505182 Photo 7/P1010583 - Discharge from Wash Plant, photo 3 The site also maintains a truck washing area (Photo 8). The trucks pull into chutes which are part of a closed loop water recycling system. The water used to wash the trucks runs to the rear of the chute and enters a concrete pond that collects the water (Photo 9). Water enters the pond from the washing chutes via passthrough holes at the bottom of the diving wall. Pass-through Holes Photo 8/P1010585 - Truck Wash Area Page 6 of 8 Interstate Concrete and Asphalt - Richland Facility WAG505182 Pass-through Holes Photo 9/P1010586 - Concrete Pond The facility tries to capture and reuse as much water as possible. All captured water is carried by underground piping that surfaces at the site's concrete reclamation settling pond (Photo 10). The sediment settles out and the water is siphoned out for reuse. The settling ponds are cleaned of sediment as needed. Photo 10/ P1010586 - Concrete Reclamation Water Settling Pond Page 7 of 8 SECTION III - RECORDS REVIEW Interstate Concrete and Asphalt - Richland Facility WAG505182 I reviewed the following documents: Notice of Intent (Renewal) - dated September 29, 2020 Site Management Plan (SMP) - dated October 15, 2018 SMP Site Map - dated 2018 Discharge Monitoring Reports (DMRs) - February 2022 through January 2023 EPA's Integrated Compliance Information System - January 1, 2018 through February 28, 2023 SECTION IV - AREA OF CONCERN AOC Reference #: RA1-RR-001 Records Review: Facility Map Regulation and/or Permit Requirement S5.D.2.b of the Permit states, the site map must "show the drainage area for each point." AOC: The Richland site map did not show the drainage area for each monitoring point. AOC Reference #: RA1-RR-002 Records Review: Facility Map Regulation and/or Permit Requirement S5.D.2.d of the Permit states, the site map must "label whether the discharge is to surface water or groundwater." AOC: The Richland site map did not label if stormwater discharges to surface water or groundwater. AOC Reference #: RA1-RR-004 Records Review: Other - Site Management Plan Regulation and/or Permit Requirement S5.D.2.a of the Permit states, in part, the site map must "assign a unique identifier up to four characters (e.g. S001, S002, etc.) to each outfall and monitoring point." AOC: The Site Management Plan (SMP), dated October 15, 2018, identifies two stormwater sample location, i.e., monitoring points, labeled SW1 and SW2. The SMP does not indicate a discharge point or outfall. The Notice of Intent (NOI) renewal application lists four monitoring points, i.e., sampling locations, labeled MP2 - MP5. The NOI identifies a single outfall as 001. The facility site map shows four monitoring points, labeled MP1 MP4. The site map does not show a discharge point. SECTION V - CLOSING CONFERENCE I conducted a closing conference with facility personnel. During the closing conference, I discussed observations made during the inspection. I informed the attendees my observations and Areas of Concern have not been evaluated for a formal compliance determination. SECTION VI - LIST OF APPENDICES 1. Photo Log Page 8 of 8 APPENDIX 1: PHOTO LOG P1010578 - Gravel Piles, site graded down to north P1010579 - Gravel Piles, berm to north, in distance P1010580 - Gravel Piles, berm to north, close-up P1010581 - Discharge from Wash Plant, photo 1 P1010582 - Discharge from Wash Plant, photo 2 P1010583 - Discharge from Wash Plant, photo 3 P1010584 - Concrete Pond P1010585 - Truck Wash Area P1010586 - Concrete Reclamation Water Settling Pond P1010587 - Quarry Area, facing north P1010588 - Quarry Side Wall, facing east