Inspection Details

Site ID	Parent Site	Location	County	EFO
4773	Archer Daniels Midland (ADM) Company	2782 Chelsea Avenue	Shelby	Memphis

Inspection Number

54403

Site ID

4773

Permit Number

TN0000281

Inspection date

11/8/2016

Inspection type

Compliance Eval (non-sampling) (CEI)

Status

Out of Compliance

Notes

Deficiency letter issued for the following issues that need attention:
1. Elevated benchmark concentrations of BOD and TSS continue to be present from SW outfalls onsite; no explanation as to the cause of the exceedances or corrective measures implemented onsite to prevent future occurrences were reported. It was recommended that this information be provided as an attachment to the NetDMRs submittals should benchmark concentrations continue to be in exceedance. Additionally, the SWPPP needs to be modified to include the corrective measures implemented onsite.
2. The site inspection revealed that the procedure of collecting samples are unacceptable. It was discovered that the same glass container is used to obtain the samples at each outfall, which may result in cross-contamination of the samples obtained. It was recommended that the facility find an alternative means in collecting the samples.
3. The facility conducts a drift check of the pH meter prior to each sampling event to verify if the pH meter is accurate within a range specified in the manual. Only if the range is exceeded, is the pH meter calibrated. Due to the frequency of analysis required by the NPDES permit, calibration is required by approved methodology to ensure accuracy. The Division requires that the pH meter be calibrated prior to each sampling event to ensure its accuracy and compliance with the permit.