Complaint ID 107816 — Public Copy

Today we sent out a July 9, 2024 B-H Transfer Notice of Violation (NOV) closure letter since as stated in the June 25, 2024 action entry they have put forth a great effort to reclaim lost plastic pellets from the downstream property and the stream and its buffer. In the May 8, 2024 CAP we received they estimate 300 gallons of plastic pellets had been recovered and 98% removed from downstream property and waterway. Twenty-one tons of spilled soda was also clean-up in the railcar loading area and sent to Wolf Creek Landfill. In addition, B-H Transfer has installed screen wire mesh to its storm drain inlets to prevent loss of plastic pellets in the future from the site. An industrial stormwater permit application has been submitted for the site and should be issued soon. The stream buffer disturbance is being handled by the City of Sandersville Local Issuing Authority (LIA) for Erosion & Sedimentation Control for further compliance.

Today we received and email from Mr. Jud Turner of the Gilbert Harrel Law Group that stated B-H Transfer continues to make progress implementing the Corrective Action Plan (CAP) and the contractor is restoring the streams buffer zone with permanent grass for immediate stabilization. The contractor has stated to Jud, the woody shrubs will not be available until the fall and they will be planted at that time which is the best time for planting them to ensure their viability. EPD Program Manager Sean Hayes was in agreement with this upcoming action. B-H Transfer has put forth a great effort to reclaim lost plastic pellets from the downstream property and the stream and its buffer. In the May 8, 2024 CAP we received they estimate 300 gallons of plastic pellets had been recovered and 98% removed from downstream property and waterway. Twenty-one tons of spilled soda was also clean-up in the railcar loading area and sent to Wolf Creek Landfill. In addition, B-H Transfer has installed screen wire mesh to its storm drain inlets to prevent loss of plastic pellets in the future from the site. An industrial stormwater permit application has been submitted for the site and should be issued soon. The stream buffer disturbance is being handled by the City of Sandersville Local Issuing Authority (LIA) for Erosion & Sedimentation Control for further compliance.

Today we were updated regarding the submitted CAP by Jud Turner regarding the stream buffer restoration plan. They have a contractor working to install vegetation along the creek buffer zone. The contractor informed them that the shrubs chosen for the project will be available in the fall of the year, and that the fall is also the preferred planting season for the woody vegetation. Mr. Turner ask, "Given that instruction from the contractor, would EPD allow us to begin establishing the grass cover during the summer, but wait until the shrubs are available in the fall to get them installed?" EPD Program Manager Sean Hayes responded in agreement they wait to plant shrubs.

Today we received from Triple Point Engineering the B-H Transfer buffer restoration plan (Plan). The Plan is uploaded here. The May 8, 2024 CAP we received stated the contractor that will conduct the restoration will be retained by July 1, 2024.

Today we received the EPD Air Program written response regarding the B-H Transfer air permit application. The response stated that at this time the facility does not meet the threshold of be required to obtain an air quality permit. The letter is uploaded here.

Today we were on site at B-H Transfer railyard to go further upstream on Sun Hill Creek and observed the new screens at all the stormdrain inlets. An image is uploaded here of one of the inlet screens that should do well to capture any plastic pellets.

Today we received a Corrective Action Plan (CAP) from Law Office GILBERT, HARRELL, SUMERFORD & MARTIN's Jud Turner. The CAP is uploaded here. In the CAP they documented the efforts taken to clean-up the soda ash and plastic pellet spills around the railyard. In addition, they documented the efforts taken to remove plastic pellets from the downstream property owners parcel. They are awaiting Watershed's decision on what Standard Industrial Classification (SIC) code to use for their Industrial Stormwater Notice of Intent for permit coverage. The detailed Rules and calculations regarding they believe they are exempt from obtaining an air permit for the transfer of soda ash from railcars to tankers.

We have not received a CAP from B-H Transfer yet and they still have until May 8, 2024 to submit the CAP.

Today we held a conference here in our office and B-H Transfer is committed to cleaning up the plastic pellets and soda ash spilled at the railyard. It was agreed that the submittal of the Corrective Action Plan (CAP) is extended to May 8, 2024.

Today we issued a complaint investigation correspondence (uploaded here) for water quality and air quality violations observed during the February 16, 2024 complaint investigation. In addition, named as deficiencies the unpermitted industrial storm water discharge and the Sun Hill Creek stream buffer damage caused by the site's industrial activity. At the request of B-H Transfer the letter's conference date was changed to 1:00pm on March 25, 2024.

Today I sent an email to B-H Transfer regarding the observations made during the complaint investigation and that a letter would be issued.

Today I left a voice mail message for Sandersville Railroad Company Freight Agent Mr. Jason Carter regarding the complaint we had received, our observations during the investigation, and the need for a corrective action plan.

Today we investigated the complaint and met with the Riverkeeper and gained access to a property just downstream of the B-H Transfer station off of Waco Mill Road. At the downstream location we observed on Sun Hill Creek small white plastic pellets on the banks of the creek and floating on the water. We then went further downstream to various points and observed more plastic pellets. We observed plastic pellets on Sun Hill Creek approximately 3,000 feet southeast of the Sandersville Railroad Company railroad yard and B-H Transfer. Our understanding is B-H Transfer has had some laborers remove some of the plastic pellets since this loss of product from their railyard began 3 weeks ago but more remain in the creek. Some images are uploaded here. After meeting with the Riverkeeper we then went to B-H Transfer main office at 750 Sparta Road to conduct an investigation into the source of the plastic pellets and met with Mr. Keith Johnson Vice President of Operations. We then went to the B-H Transfer station at the Sandersville Railroad yard off of Waco Mill Road. There we observed soda ash on the ground and plastic pellets. There were storm drain in the railyard and they had pinestraw bales surrounding them. Our understanding is these had recently been installed. On there site at Sun Hill Creek we observed where storm water runoff had taken spilled soda down into the creek or a washdown had occurred to the creek water. The site does not have industrial storm water permit coverage. Products that are transferred there are plastic pellets, soda ash, S Carb, Kaolin clay, and calcium carbonate. We requested they email us the safety data sheets for all products transferred at the facility. We were told they have an engineer coming this Thursday to assess their site and give guidance on how to best prevent product from leaving the site via storm water flow. We advised them to have the engineer come up with a corrective action plan (CAP) as we would soon request a CAP via a letter.