Document zoXNQkqm7d63oExYMJGvk8K90

EPA Region 10 Enforcement and Compliance Assurance Division Clean Water Act (CWA) Inspection Report Inspection Entry Date/Time Inspection Exit Date/Time Media Statute(s)/Program(s) Type of Inspection 04/26/2023 9:00 AM (PT) Announced: Yes 04/26/2023 12:36 PM (PT) Water Clean Water Act, NPDES, Stormwater - Industrial CEI - Compliance Evaluation Inspection Permittee Name Facility Name Facility Physical Address City, State, Zip Code Facility GPS Coordinates Facility Owner Facility Owner Address City, State, Zip Code Lamb Weston, Inc. Lamb Weston, Inc. - Boardman West Plant 600 NE Columbia Avenue Boardman, Oregon 97818 45.845558 N -119.682827 W Lamb Weston, Inc. 599 South Rivershore Lane Eagle, Idaho 83616 FRS ID Permit # / ODEQ File # SIC Code 110014074811 ORR121405 / 103436 2038 - Frozen Specialty Food Manufacturing Inspection Contacts: Organization EPA Region 10 Oregon Department of Environmental Quality Lamb Weston, Inc. Boardman West Plant Lamb Weston, Inc. Boardman West Plant Lamb Weston, Inc. Lamb Weston, Inc. Boardman West Plant EPA Inspector Signature/Date Supervisor Signature/Date Name Jon Klemesrud Martha Cruse Title Lead Inspector Inspector Present in Opening Conf. Yes Yes Present in Closing Conf. Yes Yes Brian Jackson Plant Manager No No Jared Murrey Environmental Yes Yes Manager Mary Beth Miller Sr. Manager No Yes Corporate EHS Dillon Hadaway Engineering No No Manager JON KLEMESRUD Jon Klemesrud PETER CONTRERAS Peter Contreras, Chief FDDWES Digitally signed by JON KLEMESRUD Date: 2023.05.23 14:35:52 -07'00' Digitally signed by PETER CONTRERAS Date: 2023.05.23 14:52:16 -07'00' CWA NPDES ORR121405 Inspection Report This inspection report is based on information supplied by conversations with Mr. Brian Jackson, Mr. Jared Murrey, Ms. Mary Beth Miller, or direct observations made at the time of the inspection, and records and reports maintained by the permittee. This inspection report may also include information gathered from a review of EPA, State, and/or public records. SECTION I - INTRODUCTION Entry and Inspection Chronology I was joined on the inspection by Oregon Department of Environmental Quality (ODEQ) representative Martha Cruse. To ensure staffing and availability, this inspection was announced just prior. At approximately 2:30 PM on April 25, 2023, I called and left a message with Mr. Brian Jackson, Facility Manager. On the message, I introduced myself and discussed that I had been asked to conduct a routine on-site inspection at the Lamb Weston, Inc. Boardman West Plant, the inspection was to assess compliance with the facility's coverage under ODEQ's Industrial Stormwater Discharge Permit (1200-Z), in coordination with ODEQ. At approximately 7:30 AM the morning of the inspection (April 26, 2023), Mr. Jackson returned my call. I further explained that I had planned to conduct the inspection that morning. Mr. Jackson welcomed the inspection but explained that he would be unable to attend as he was currently off-site. Mr. Jackson discussed that he would coordinate with Mr. Jared Murrey, Environmental Manager and/or Mr. Dillon Hadaway, Engineering Manager to be available and accompany me on the inspection. I discussed that the inspection would include a walk-through of the facility and a review of permit related documents. We agreed to begin the inspection at 9:00 AM. Ms. Cruse (ODEQ) and I arrived on-site at approximately 9:00 AM on April 26, 2023, we signed-in as visitors and were escorted upstairs to a conference room and met with Mr. Murrey. Following our initial introductions, I presented my EPA credentials, discussed the purpose/expectations of the inspection, and provided my business card. We had a brief discussion regarding confidential business information (CBI), general facility operations and recent stormwater history. Mr. Murrey explained that he had only been employed by Lamb Weston, Inc. for approximately two months. Prior to Mr. Murrey's onboarding, the facility had been without an environmental manager for approximately one year. Mr. Murrey discussed that during the time without an environmental manager, he believed environmental duties at the facility were generally split between numerous staff. The inspection consisted of an opening conference, a walk-through of stormwater impacted areas and related infrastructure, a records review, and concluded with a closing conference. During the closing conference, we discussed the walk-through observations, potential areas of concern and next steps. Portions of the records review occurred both pre- and post-inspection, as discussed in Section III of this inspection report. We were accompanied throughout the inspection by Mr. Murrey. Ms. Mary Ann Miller, Corporate EHS Sr. Manager joined us during the facility walk-through and was present for the remainder of the inspection, including the closing conference. Ms. Miller is based out of the Lamb Weston, Inc. corporate office in Kennewick, Washington, supporting several Lamb Weston, Inc. facilities. Permit/Compliance History Lamb Weston, Inc. - Boardman West Plant (hereinafter referred to as the "Facility") is permitted to discharge to an adjacent surface water pond under the ODEQ's Industrial Stormwater Discharge Permit (1200-Z). The surface water pond is located approximately 1/3-mile south of the Columbia River. The permit tracking number assigned to the Facility is ORR121405. The Facility is also subject to the sector specific requirements identified in Schedule E of the 1200-Z Permit (Sector U - Food and Kindred Products). According to file documentation, no prior ODEQ inspection information was available. In 2014, the Facility triggered Tier II corrective action requirements of the permit for benchmark exceedances of zinc, copper, and total suspended solids (TSS). Completed corrective action measures included covering galvanized roofs with a thermoplastic polyolefin (TPO) membrane, installing diversion berms and increased frequency of sweeping/ maintenance. In 2019, the Facility triggered another Tier II corrective action for elevated levels of zinc. As a corrective action, a new stormwater infiltration basin and associated pump station was constructed for 100% infiltration. The construction of the infiltration basin and pump station was completed on December 3, 2021. Page 2 of 55 SECTION II - OBSERVATIONS CWA NPDES ORR121405 Inspection Report Site Review The Facility is a frozen potato processing plant, located within an industrial area of Boardman, Oregon. On-site activities include raw potato unloading, washing, blanching, frying, freezing, packaging, and shipping of finished potato products. Activities are conducted during all months of the year. According to Mr. Murrey, production at the Facility occurs 24/7 while operating two 12-hour shifts. Regular administrative business hours are 8:00 AM - 5:00 PM, Monday-Friday. The Facility has been at its current location since approximately 1980, and there are currently 400 employees. See Attachment A, General Location Map. Stormwater within pervious/graveled areas of the property is designed to be infiltrated/evaporated within those areas. For the Facility's impervious areas (majority of the site), stormwater is collected within a series of catch basins and routed to three separate stormwater infiltration basins designed to infiltrate/evaporate stormwater. Two of the three infiltration basins are smaller in size and serve the southern industrial areas and southern building roof drains. In 2021, a larger infiltration basin was constructed in the northwest corner of the property and serves the remaining impervious areas and roof drains. As discussed earlier in this report, the new infiltration basin was constructed in response to a 2019 Tier II corrective action and designed to infiltrate stormwater that was previously discharged to a surface water pond located immediately north of the Facility. The surface water pond is the permitted receiving water. The Facility has not discharged to the surface water pond since the infiltration pond and associated pump station was completed, on December 3, 2021. We began the inspection walk-through within the southeast parking areas. We generally traveled the process flow from raw potato receiving to finished product shipping. During the walk-through we also observed other industrial areas, including material storage areas, the cooking oil rail loading/unloading areas, potato residual staging areas, hazardous waste storage area, empty tote storage and solid waste storage areas. Photographs taken during the site-walk through are attached to this inspection report as Attachment B, Photograph Log. Walk-Through Observations: Location: Southeast Parking Lot Observation #: OB-01 We first observed the Facility's main parking lot and truck access road (Photo 1). The access road is generally the east end of the main parking area and is used for incoming raw potato delivery by truck/trailer. Four catch basins serve this general area and route stormwater to the Facility's primary pump station and associated infiltration located in the northwest section of the property. Prior to December 2021, the catch basins discharged directly to the northern surface water pond. At the time of inspection, catch basins within the parking area were observed to be equipped with a removable metal strainer basket and were generally free of accumulated sediment/debris. According to on-site records, catch basins were last cleaned by the Facility's sanitation staff on February 13, 2023. I discussed that the 2014 Tier II Corrective Action Report mentioned possibly utilizing treatment units within the catch basins, Mr. Murrey was not aware of any additional catch basin BMPs beyond the strainer baskets, such as sediment fabric or treatment media. Location: Raw Product Receiving Area Observation #: OB-02 We continued the walk-through north, to the raw product (potato) receiving area (Photo 2). Raw potatoes are received at the Facility via truck where they are conveyed indoors and unloaded for further processing, including washing, blanching, frying, freezing, and packaging. Being relatively new to the Facility, Mr. Murrey wasn't able to provide the approximate number of incoming trucks/trailers of raw product being delivered each day. The SWPCP lists potential pollutants from this raw product receiving area to include raw potatoes, sediment, vines, Page 3 of 55 CWA NPDES ORR121405 Inspection Report rocks, residual truck oil and grease, and silt water from the silt separation system. At the time of inspection, we observed piles accumulated sediment and a few raw potatoes outdoors in the general receiving area, primarily beneath some staged trailers containing the raw product. It was discussed that stormwater from this area generally travels north as sheet flow toward a depressed area near a curbed rail spur. A stormwater catch basin is located upgradient of the depressed area to convey stormwater to the Facility's pump station and northwest infiltration basin. As discussed earlier in this report, prior to December 2021, the catch basin discharged directly to the northern surface water pond. Mr. Murrey was not aware of any sweeping practices or sweeping contracts utilized at the Facility, including at this raw product receiving area. Residuals (sediment/rocks) from the silt separation area are removed and staged in bunkers located in a northern area of the Facility. We also discussed that the Facility contracts with "IFC" (Industrial Fumigant Company, LLC), for external rodent boxes and other pest control measures within the processing areas. Location: Empty Tote and Potato Residuals Staging Area Observation #: OB-03 We continued the walk-through further north and observed an empty tote storage area within the northeast corner of the Facility (Photo 3). Just west of the empty tote storage area is a potato residuals storage area, where discarded processing wastes are loaded and staged for hauling. It was discussed that similar to the raw product receiving area, stormwater from this area generally travels north as sheet flow, towards the same depressed area near the rail spur. A stormwater catch basin located upgradient of the depressed area conveys stormwater to the Facility's pump station and northwest infiltration basin. At the time of inspection, we observed discarded potato residuals on the surface of several loading areas. We also observed accumulated sediment north of the loading area, near the rail spur curbing (Photo 4). Location: Stormwater Pump Station Observation #: OB-04 We then observed the Facility's stormwater pump station and wet well associated with the NE infiltration basin (Photo 5). The pump station was manufactured by Gorman-Rupp and was installed in 2021, in conjunction with the construction of the northeast infiltration basin. The pump station was described to operate based on float switches within the wet well. At the time of inspection, we observed both a red and green light illuminated on the top of the lift station. When asked about the station's alarm system and illuminated indicator lights, Mr. Murrey discussed that being relatively new to the Facility, he would have to follow-up post-inspection regarding specifics of the pump station and alarm system. Mr. Murrey lifted the cover of the wet-well, we observed a slight trickle of flow entering the wet-well from one of the influent pipes. When asked about the source of the influent flow during the current dry weather conditions, Mr. Murrey discussed that he would have to follow-up as he was not certain of the source, possibly residual flow from a recent broken water pipe. Mr. Murrey explained that earlier in the day, he was informed that a pipe leak associated with some ongoing interior construction had occurred within the Facility's main office entrance area. Mr. Murrey was going to confirm the source of the water and if it entered the nearby stormwater catch basin in the parking area. Location: Raw Product Residual Storage Area Observation #: OB-05 The walk-through continued west, to the raw product/residual storage bunkers and surrounding areas. We observed a roof downspout filtration unit attached to a production building (Photo 6). According to Mr. Murrey, the roof downspout is routed to the stormwater pump station that was just observed. Mr. Murrey was unsure when the filtration unit was installed or last serviced. We then walked north and observed the raw product residual storage area, located southwest of the surface water pond. Residuals from the raw product silt separation process are temporarily stored in uncovered concrete Page 4 of 55 CWA NPDES ORR121405 Inspection Report "bunkers" contained within the area (Photo 7). The area is slightly bermed to prevent stormwater from entering the process area, as well as contain any runoff/stormwater from entering the process area. An adjacent catch basin (Photo 8) captures the stormwater/wastewater within the bermed area and routes to the Facility's process wastewater system. Process wastewater generated at the Facility is discharged to the Port of Morrow wastewater treatment plant. Mr. Murrey explained that the storage bunkers were temporarily moved the week prior, to address a spill-cleanup of cooking oil that occurred in the area. The spill occurred due to a binded rotary screen within the Facility's process wastewater system. The spill was reported to ODEQ and did not reach the stormwater system. Material associated with the spill was contained on-site and removed by a contractor (Safety-Kleen). Location: Cooking Oil Unloading/Loading Area Observation #: OB-06 We continued west and observed the cooking oil unloading/loading areas located north of the main plant. At this location, rail cars containing cooking oil are first heated, and then oil is pumped into on-site storage tanks. According to the SWPCP, potential pollutants from this area includes edible (cooking) oils, residual vehicular oils, and condensate from the oil car heating process. We observed several areas where condensate and residual oil staining was present on the paved surface areas. We observed the single stormwater catch basin that serves this area, located downslope to the north. The catch basin was covered with a seal/mat, and water was observed to be traveling to the catch basin and ponding above the seal/mat. (Photo 9). Location: Covered Hazardous Waste Storage Area and Dumpster Storage Area Observation #: OB-07 We continued the walk-through further west and observed the covered hazardous waste storage/containment area. The area was locked/gated and was contained under cover, with secondary containment and a non-discharging catchment drain. West of this area was the Facility's dumpster area where several roll-off containers are located for general waste and scrap metal (Photo 10 & Photo 11). According to the SWPCP, scrap metal is picked up by a local metal scrap service provider and the refuse from the trash dumpsters are transported to the regional transfer station under contract with a local waste hauler. We observed the dumpsters to be without lids/covers and several areas of accumulated sediment/debris. Located downslope to the east, a single stormwater catch basin serves this area. The catch basin was covered with a seal/mat. As discussed earlier in this report, Mr. Murrey was not aware of any sweeping practices or contracts utilized by the Facility, including at this dumpster storage area. Location: Northwest Infiltration Basin Observation #: OB-08 We then observed the northwest infiltration basin that receives stormwater from the northern pump station (Photo 12). As discussed earlier in the report, stormwater previously discharged to the northern surface water pond now discharges to the northwest infiltration basin. Mr. Murrey discussed that he believes the infiltration basin is currently operating as designed and showed a recent picture on his phone of stormwater within the infiltration basin that had since infiltrated/evaporated. Location: Empty Tote Staging Area Observation #: OB-09 We continued the walk-through southwest and observed another empty tote staging area, located near the south of the northwest infiltration basin. The surface within the area was compacted gravel, as were the remaining areas of the western perimeter. The nearest catch basin was the one just previously viewed, to the east within the paved dumpster area. We observed one tote that was full of cooking oil and exposed without cover (Photo 13). No staining or residuals were observed in the general area. Page 5 of 55 Location: Southern Area(s) & Main Entrance Observation #: OB-10 CWA NPDES ORR121405 Inspection Report We continued the walk-through to the south and observed the two southern infiltration basins and the Facility's shipping/loading area(s) (Photo 14 - 16). In general, stormwater within the Facility's southern areas is either infiltrated/evaporated within the impervious areas or routed to the two southern infiltration basins, where stormwater is then infiltrated/evaporated. Industrial activities occuring within the southern areas include vehicle traffic for trucking/shipping, used cooking oil filter storage (Photo 17) and metal/pipe storage (Photo 18). We concluded the walk-though after observing the parking lot catch basin that had possibly received residual flow from an earlier pipe leak (Photo 19). SECTION III - RECORDS REVIEW Record: Storm Water Pollution Control Plan (SWPCP) Ref #: RR-001 A copy of the Facility's SWPCP was on-site and available for review at the time of inspection. An electronic version of the SWPCP was also provided pre-inspection by ODEQ. The SWPCP listed the same revised and certification date of August 30, 2021. The SWPCP was revised by Mr. Nabil Mohamed, the prior Environmental Manager and certified by Mr. Brian Jackson, Plant Manager. The SWPCP included the applicable elements required/discussed within Schedule A. Part 10 of the permit. The SWPCP also included General Location Map and a blank Monthly Stormwater Inspection Checklist. Mr. Murrey discussed that he had recently reviewed the SWPCP as part of his recent onboarding, he plans to update the document to align with current staffing/contacts and include the northwest infiltration basin and associated pump station that was installed in 2021. Post-inspection on May 11, 2023, the Facility provided an update that they have contacted Valley Science and Engineering for assistance in updating the SWPCP. See Attachment C, EPA and DEQ Response Letter. Record: Site Inspection Reports & Employee Training Ref #: RR-002 When asked about Monthly Site Inspection Reports required by the permit, Mr. Murrey did not believe they were being conducted by the Facility during the time without an Environmental Manager. Mr. Murrey also stated that he hadn't documented a monthly site inspection since starting at the Facility approximately two months prior. Mr. Murrey discussed that he was able to view/access some prior inspection reports completed by the previous Environmental Manager, Mr. Nabil Mohamed in various electronic file locations. Via Mr. Murrey's laptop, we viewed the available documentation. The most recent monthly site inspection and associated reports was documented on 02/17/2022. Previous inspections were also documented on 01/18/2022, 12/21/2021, 11/24/21, 10/26/2021, 09/23/2021, 08/25/2021. 07/19/2021, 06/08/2021, 05/19/2021, 04/22/2021, 03/24/21, 02/23/2021, 01/21/2021. There were also monthly inspection records completed by the sanitation division in 2020, including on 01/28/2020, 02/21/2020 and 03/19/2020. Site inspections were primarily documented using the Facility's Monthly Stormwater Inspection Checklist. Documentation also included a record of the catch basin cleanouts being conducted by the sanitation division on February 13, 2023. When asked about employee training, Mr. Murrey and Ms. Miller discussed that stormwater training is completed annually and for new hires within a Lamb Weston, Inc. electronic training platform. Training was last documented in January 2023. We discussed that Ms. Miller or Mr. Murrey would provide an electronic copy of the PowerPoint presentation of the stormwater training curriculum post-inspection via email. On May 11, 2023, the Facility provided follow-up including a PowerPoint of the training materials. Page 6 of 55 CWA NPDES ORR121405 Inspection Report Record: Discharge Monitoring Data (DMR) & Laboratory Analytical Data Ref #: RR-003 DMRs and associated stormwater monitoring/analytical data was reviewed as part of this inspection. According to Mr. Murrey and a review of DMR data, the Facility has not discharged since the installation of the northwest infiltration basin in December of 2021. For past discharges to the adjacent surface water pond, the Facility was conducing stormwater monitoring per Schedule B (Monitoring Requirements) within the permit. Monitoring was completed 4 times per year for PCBs, total copper, total lead, total zinc, pH, total suspended solids (TSS), oil and grease and mercury. The facility sampled from three separate outfalls (Outfall 001, Outfall 002, and Outfall 003), each discharging the to the surface water pond. On December 26, 2019, after continuing to exceed the benchmark for zinc at Outfall 002 and 003, the Facility submitted a new Tier II Corrective Action Report and a Mass Reduction Waiver. The Facility would address the exceedances by constructing the new infiltration basin for 100% infiltration. On August 17, 2020, ODEQ approved the Tier II corrective action. See Attachment D, 2019 Tier II Corrective Action Engineering Report & ODEQ Approval Letter. Via a Facility spreadsheet on Mr. Murrey's laptop, the following benchmark exceedances were noted while implementing the Tier II corrective action: Quarter 3, 2021 - TSS reported value: 276 mg/l (benchmark 100 mg/l) Quarter 3, 2021 - Zinc reported value: 0.248 mg/l (benchmark 0.12 mg/l) Quarter 4, 2021 - Zinc reported value: 0.18 mg/l (benchmark 0.12 mg/l) Quarter 2, 2020 - TSS reported value: 113 mg/l (benchmark 100 mg/l) Quarter 4, 2020 - Zinc reported value 0.214 mg/l (benchmark 0.12 mg/l) Select analytical and visual reports including chain-of-custody documentation were reviewed. Reporting Quarters (Q) reviewed included Q3- 2020/2021. For Q3 - 2020/2021, sampling dates included January 8, 2021, and November 6, 2020. On the Q3 - 2020/2021 DMR, it was reported in the DMR correspondence that for the precipitation even of January 8, 2021, a freshwater leak occurred within the facility premises and previous to this precipitation event and caused high silt loading into the filters leading to high suspended solids readings in the lab." The following benchmark exceedances of the geometric mean were noted: Outfall 001 - TSS reported value 205 mg/l (benchmark 100 mg/l) Outfall 001 - Copper reported value 0.033 mg/l (benchmark 0.020 mg/l) Outfall 001 - Zinc reported value 0.33 mg/l (benchmark (0.12 mg/l) Outfall 002 - Zinc reported value 0.24 mg/l (benchmark 0.12 mg/l) Outfall 003 - TSS reported value 177 mg/l (benchmark 100 mg/l) Outfall 003 - Zinc reported value 0.25 mg/l (benchmark 0.25 mg/l) It was also noted that the January 8, 2021 analytical report that the TSS sample for Outfall 001 required a dilution factor of 100.00. SECTION V - AREAS OF CONCERN Areas of Concern may not be in sequential order. The presentation of Areas of Concern (AOC) does not constitute a formal compliance determination or violation. AOC #1: Uncovered Dumpsters Page 7 of 55 CWA NPDES ORR121405 Inspection Report Regulation and/or Permit Requirement: Schedule A.1.c. within the permit states: "Cover all waste contained in bins or dumpster 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. " Observation: As discussed earlier in the report, during the walk-through within the designated dumpster area we observed dumpsters used for general garbage and scrap metal to be without covers or lids (Photo 10 & Photo 11). Along the southern edge of the Facility, we also observed the used cooking oil filter discard bin without cover or containment in a southern area of the facility. Additionally, oil staining was observed throughout the area containing the cooking oil discard bin (Photo 17). The concern is the observed lack of cover(s) or lid(s) on the waste dumpsters when compared to the language in the permit. It is recognized that the nearest stormwater catch basin to dumpster area was equipped with a drain cover/mat. As the inspection occurred during dry weather conditions, the seal/effectiveness of the drain cover/mat was unknown. Although the Facility has reported no recent discharge with the implementation of the infiltration basins, sediment/debris/pollutants entering the stormwater system could have the potential to accumulate within the pump station and/or infiltration basins impacting their performance. AOC #2: Housekeeping Regulation and/or Permit Requirement: Schedule A.1.g. within the permit states: "Routinely clean all exposed areas that may contribute pollutants to stormwater with measures such as sweeping at regular intervals, litter pick-up, keeping materials orderly and labeled, promptly clean-up spills and leaks, proper maintenance of vehicles and stowing materials in appropriate containers." Observation: As discussed earlier in this report, during the walk-through we observed several areas with accumulated sediment/debris, specifically at the raw product receiving area (Photo 2), potato residual staging area (Photo 4), dumpster area (Photo 11) and the used cooking oil filter storage bin area (Photo 17). At the time of inspection, Mr. Murrey was not aware of any sweeping practices or sweeping contracts utilized at the Facility, including at these industrial areas. The concern is the accumulated sediment observed within these areas when compared to the language in the permit. Although the Facility has reported no recent discharge with the implementation of the infiltration basins, sediment/debris/pollutants entering the stormwater system could have the potential to accumulate within the pump station and/or infiltration basins impacting their performance. On May 11, 2023, the Facility provided follow-up correspondence stating that "the parking lot is routinely swept, and litter is collected and properly disposed. Monthly inspections help identify when additional maintenance is required on an as needed basis. The parking lot drains discharge to a catch basin containing a weir designed to drop out sediment and debris prior to discharge into the pond." See Attachment C, EPA and DEQ Response Letter. AOC #3: Alarm Light Illuminated at the Stormwater Pump/Lift Station Regulation and/or Permit Requirement: Page 8 of 55 CWA NPDES ORR121405 Inspection Report Schedule A.1.i. within the permit states: "Clean, maintain and repair all control measures including stormwater structures and temporary measures, catch basins, and treatment facilities to ensure effective operation as designed and in a manner that prevents the discharge of pollution." Observation: As discussed earlier in the report, during the walk-through while at the stormwater pump station we observed both a red and green light illuminated on the top of the pump/lift station (Photo 5). When asked about the station's alarm system and illuminated indicator lights, Mr. Murrey discussed that being relatively new to the Facility, he would have to follow-up post-inspection regarding specifics of the pump station and alarm system. On May 11, 2023, the Facility provided follow-up correspondence (Attachment C) stating that "the red-light alert was indicative of a float backup error which occurred on 02/04/2023. All stormwater continued to discharge to the bioswale as required. Harms Engineering will be contacted as a follow-up to ensure the lift station alarm is operating properly." Separately in response to my inquiry if all connections to the surface water pond were capped with the design/connection to the northwest infiltration pond, the Facility provided that "all lines routed to the surface water pond were capped except for an overflow line connected to the lift station sump. This pipe was to remain as an overflow in accordance with Harms Engineering Stormwater Pump Station design. The concern is that the alarm system associated with the stormwater pump/lift station may not be currently operating as designed. In the event of a pump failure, the pump station would overflow to the surface water pond. AOC #4: Exposed Tote of Used Cooking Oil Regulation and/or Permit Requirement: Schedule A.1.c. within the permit states: "Recycle or properly dispose of wastes to eliminate or minimize exposure of pollutants to stormwater. Cover all waste contained in bins or dumpster 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. " Observation: As discussed earlier in the report, during the walk-through within the empty tote storage area we observed a full tote containing used cooking oil according to Mr. Murrey. The top of the tote had been cut open and was exposed without a lid. The concern is the full tote of used oil observed without a functioning lid/cover and potentially exposed to stormwater during rain events. It is recognized that the nearest stormwater catch basin was equipped with a drain cover/mat, however, the seal/effectiveness of the drain cover/mat was unknown due to the dry weather conditions. Although the Facility has reported no recent discharge with the implementation of the NW infiltration basin, cooking oil entering the stormwater system could have the potential to accumulate within the pump station and/or infiltration basins impacting their performance. AOC #5: Observed Flow within the Pump Station Wet-Well Observation: As discussed earlier in the report, during the walk-through at the stormwater pump/lift station we observed a slight trickle of influent flow during dry weather conditions. When asked about the source of the influent flow during the current dry weather conditions, Mr. Murrey discussed that he would have to follow-up as he was not certain of the source, and indicated it was possibly residual flow from a recent broken water pipe. Mr. Murrey Page 9 of 55 CWA NPDES ORR121405 Inspection Report explained that earlier in the day, he was informed that a pipe leak associated with some ongoing interior construction had occurred within the Facility's main office entrance area. Mr. Murrey was going to confirm the source of the water and if it entered the nearby stormwater catch basin in the parking area. On May 11, 2023, the Facility provided follow-up correspondence (Attachment C) stating that "the source of the water entering the lift station was determined to be process water from a plugged line on the rooftop which entered rooftop storm drains. The water was primarily fresh water utilized to flush the line. The lift station sump was pumped out and transferred to the process water treatment system for treatment and discharge to the Port of Morrow. AOC #6: Missing Monthly Site Inspection Documentation Regulation and/or Permit Requirement: Schedule A.12.a. describes the requirement of monthly inspections. Schedule A.12.i. states: "Document monthly inspections in an inspection report that is retained on-site and submitted to DEQ or agent upon request. The inspection report must include: i. The inspection date and time; ii. The name(s) of the inspector(s); iii. Control measures and treatment facilities needing cleaning, replacement, maintenance, reconditioning or repair; iv. The condition of the drainage and conveyance system and need for maintenance; v. Previously unidentified sources of pollutants; vi. Stormwater discharge visual observations vii. Nature of the discharge; whether caused by snow or rain; and viii. Any corrective action response, source control or maintenance taken or scheduled to remedy problems found. Observation: As discussed earlier in this report, the Facility was unable to provide monthly site inspection reports from March 2022 to the date of the inspection (April 26, 2023). SECTION VI - CLOSING CONFERENCE Closing Conference Following the walk-through and records review a closing conference was held with Mr. Murrey and Ms. Miller. We discussed our general observations, areas of concern and follow-up items including the records request. I then thanked them for their time and assistance during the inspection, we signed out of the visitor log and departed the Facility. SECTION VII - POST INSPECTION CORRESPONDENCE On May 11, 2023, the Facility provided follow-up documentation and responses to items discussed at the time of inspection. See Attachment C, EPA and DEQ Response Letter. SECTION VIII - LIST OF APPENDICES Page 10 of 55 CWA NPDES ORR121405 Inspection Report Attachment A - General Facility Map Attachment B - Photograph Log Attachment C - EPA and DEQ Response Letter Attachment D - 2019 Tier II Corrective Action Engineering Report and Approval Letter Page 11 of 55 CWA NPDES ORR121405 Inspection Report ATTACHMENT A General Facility Map Page 12 of 55 ATTACHMENT A CWA NPDES ORR121405 Inspection Report General Location Map Site Map (pdf file attached separate) (Drawing #7000-301) 21 Page 13 of 55 CWA NPDES ORR121405 Inspection Report ATTACHMENT B Photograph Log All photographs taken by Jon Klemesrud on April 26, 2023 Nikon Coolpix AW100 Page 14 of 55 CWA NPDES ORR121405 Inspection Report Photograph Log - Lamb Weston, Inc. - Boardman West Plant Photo #:01 (DSCN3218) Description: Facing south, photo of a stormwater catch basin within the facility parking lot. According to Mr. Murrey and the SWPCP, the parking lot stormwater catch basins are routed north to the pump station and associated northwest infiltration basin. Photo #:02 (DSCN3219) Description: Facing south, photo of the raw product receiving area. Observed areas with accumulated sediment. Photo #:03 (DSCN3220) Description: Facing northwest, photo of empty chemical totes and the discarded product storage/staging area. Photo #:04 (DSCN3221) Description: Facing southwest, photo of the stormwater catchment area and catch basin near the discarded product storage/staging area. Page 15 of 55 CWA NPDES ORR121405 Inspection Report Photograph Log - Lamb Weston, Inc. - Boardman West Plant Photo #:05 (DSCN3222) Description: Facing north, photo of the Gorman Rupp stormwater lift station associated with the northwest infiltration basin. Photo #:06 (DSCN3223) Description: Facing west, photo of a roof downspout filtration unit manufactured by Clean Way. Photo #:07 (DSCN3224) Description: Facing northwest, photo of residual storage area. Stormwater captured within this area is collected separately and routed to wastewater treatment system for reuse and/or discharge to the Port of Marrow wastewater treatment plant. Photo #:08 (DSCN3225) Description: Facing northwest, photo of catch basins serving the residual storage area. Catch basins are plumbed to the process wastewater treatment system. Page 16 of 55 CWA NPDES ORR121405 Inspection Report Photograph Log - Lamb Weston, Inc. - Boardman West Plant Photo #:09 (DSCN3226) Description: Facing south, photo of the cooking oil unloading area (rail). Stormwater catch basin is located just north and covered with a drain cover mat. Photo #:10 (DSCN3227) Description: Facing northwest, photo of the scrap metal dumpster and general garbage/dumpster storage area, just east of the northwest bioswale. The adjacent stormwater catch basin was covered with a drain cover mat. Photo #:11 (DSCN3229) Description: Facing south, photo of the scrap metal dumpster and other dumpsters used for garbage/waste storage. No lids observed. Accumulated sediment observed within the area. Photo #:12 (DSCN3228) Description: Facing southwest, photo of the northwest infiltration basin that receives stormwater from the pump station. Page 17 of 55 CWA NPDES ORR121405 Inspection Report Photograph Log - Lamb Weston, Inc. - Boardman West Plant Photo #:13 (DSCN3230) Description: Facing west, photo of empty tote storage area. One tote was marked "used oil" and was full of used cooking oil. Photo #:14 (DSCN3231) Description: Facing southeast, photo of the southeast infiltration basin. Receives stormwater from southern areas and the southeast building roof drain. Photo #:15 (DSCN3232) Description: Facing north, photo of the final product shipping area. Photo #:16 (DSCN3233) Description: Facing southwest, photo of the southern infiltration basins that receives stormwater from the southern areas outside of the boiler building. Page 18 of 55 CWA NPDES ORR121405 Inspection Report Photograph Log - Lamb Weston, Inc. - Boardman West Plant Photo #:17 (DSCN3234) Description: Facing north, photo of used cooking oil filters contained within an uncovered dumpster. Used oil residuals were observed outside of the containment bin. Photo #:18 (DSCN3234) Facing south, photo of an empty drum storage area and "boneyard area." Photo #:19 (DSCN3236) Description: Facing north, photo of northwest parking lot catch basin. Page 19 of 55 CWA NPDES ORR121405 Inspection Report ATTACHMENT C EPA and DEQ Response Letter Page 20 of 55 CWA NPDES ORR121405 Inspection Report Page 21 of 55 CWA NPDES ORR121405 Inspection Report Page 22 of 55 CWA NPDES ORR121405 Inspection Report Page 23 of 55 CWA NPDES ORR121405 Inspection Report Page 24 of 55 CWA NPDES ORR121405 Inspection Report ATTACHMENT D 2019 Tier II Corrective Action Engineering Report and ODEQ Approval Letter Page 25 of 55 CWA NPDES ORR121405 Inspection Report Page 26 of 55 CWA NPDES ORR121405 Inspection Report Page 27 of 55 CWA NPDES ORR121405 Inspection Report Page 28 of 55 CWA NPDES ORR121405 Inspection Report Page 29 of 55 CWA NPDES ORR121405 Inspection Report Page 30 of 55 CWA NPDES ORR121405 Inspection Report Page 31 of 55 CWA NPDES ORR121405 Inspection Report Page 32 of 55 CWA NPDES ORR121405 Inspection Report Page 33 of 55 CWA NPDES ORR121405 Inspection Report Page 34 of 55 CWA NPDES ORR121405 Inspection Report Page 35 of 55 CWA NPDES ORR121405 Inspection Report Page 36 of 55 CWA NPDES ORR121405 Inspection Report Page 37 of 55 CWA NPDES ORR121405 Inspection Report Page 38 of 55 CWA NPDES ORR121405 Inspection Report Page 39 of 55 CWA NPDES ORR121405 Inspection Report Page 40 of 55 CWA NPDES ORR121405 Inspection Report Page 41 of 55 CWA NPDES ORR121405 Inspection Report Page 42 of 55 CWA NPDES ORR121405 Inspection Report Page 43 of 55 CWA NPDES ORR121405 Inspection Report Page 44 of 55 CWA NPDES ORR121405 Inspection Report Page 45 of 55 CWA NPDES ORR121405 Inspection Report Page 46 of 55 CWA NPDES ORR121405 Inspection Report Page 47 of 55 CWA NPDES ORR121405 Inspection Report Page 48 of 55 CWA NPDES ORR121405 Inspection Report Page 49 of 55 CWA NPDES ORR121405 Inspection Report Page 50 of 55 CWA NPDES ORR121405 Inspection Report Page 51 of 55 CWA NPDES ORR121405 Inspection Report Page 52 of 55 CWA NPDES ORR121405 Inspection Report Page 53 of 55 CWA NPDES ORR121405 Inspection Report Page 54 of 55 CWA NPDES ORR121405 Inspection Report Kate Brown, Governor Northwest Region Portland Office/Water Quality 700 NE Multnomah Street, Suite 600 Portland, OR 97232-4100 (503) 229-5263 FAX (503) 229-6957 TTY 711 August 17, 2020 Rob Burden, Jr Lamb Weston, Inc P.O. Box 379 Boardman, Oregon 97818 RE: Tier II Corrective Action Response - Accept File Number: 103436 Facility: Boardman West Plant Morrow County Mr. Burden, On December 30, 2019, the Department of Environmental Quality (DEQ) received the Tier II Report addendum to your Stormwater Pollution Control Plan (SWPCP) for the facility referenced above. After careful review, DEQ has deemed this Tier II Report and revised SWPCP acceptable in accordance with Schedule A.11.j of the 1200-Z General Permit. The implementation deadline for the proposed Tier II corrective action is June 30, 2021. You may submit revisions to this proposal for consideration, these will need to be reviewed by DEQ prior to implementation. Upon completion of Tier II corrective action, you must: 1) Provide written confirmation to DEQ of Tier II corrective action installation no later than 30 calendar days from completion, Schedule A.11.h. 2) Evaluate whether the treatment measures were properly installed, maintained and implemented and whether modifications to these measures are necessary, if sampling results continue to exceed benchmark parameter(s) no later than 30 calendar days of obtaining the sample results, Schedule A.11.j.iii.(1). Should you have any questions about the content of this letter, please feel free to contact me at 503-2296843 or kennedy.michael@deq.state.or.us. Sincerely, Michael Kennedy Water Quality Specialist Oregon Department of Environmental Quality - Northwest Region Page 55 of 55