Document 0gZxwNboDe7jdV0g0g4w37RGb

U.S. Environmental Protection Agency Region 5 Purpose: Clean Water Act National Pollutant Discharge Elimination System Compliance Evaluation Inspection Facility: Zekelman Industries, Inc. - Atlas Tube Division 1855 East 122nd Street Chicago, Illinois 60633 Inspection Date: August 15, 2022 EPA Representatives: Jake Berger, Physical Scientist, 312-353-8024, berger.jake@epa.gov Jason Hewitt, Environmental Engineer, 312-353-3114, hewitt.jason@epa.gov Facility Representatives: Robert Werth, Environmental Manager Eric Mouser, Warehouse Operations Manager Gerald Kurelko, Plant Manager Report Prepared by: Jake Berger, Physical Scientist Water Enforcement and Compliance Assurance Branch, Section 1 Digitally signed by Berger, Berger, Jake Jake Date: 2022.08.31 Inspector Signature and Date: ______________08_:1_0:_46_-0_5_'00_' __________________________ Approver Name and Title: Molly Smith, Section 1 Supervisor, Water Enforcement and Compliance Assurance Branch MOLLY Digitally signed by MOLLY SMITH Approver Signature and Date: _S_M__I_T_H________D13a_:t0e_4::25_042_-20_.50'9_0.00_'2___________________________ PURPOSE OF INSPECTION The purpose of the inspection by the U.S. Environmental Protection Agency (USEPA) at Zekelman Industries, Inc. - Atlas Tube Division (Atlas Tube or Facility) was to describe, evaluate, and document compliance with the Clean Water Act (CWA) and their National Pollutant Discharge Elimination System (NPDES) permit. BACKGROUND Atlas Tube manufactures hollow steel products in Chicago, Illinois, and discharges to an unnamed tributary of Lake Calumet. Atlas Tube discharges non-contact cooling water from their cooling tower blowdown and industrial storm water runoff via one combined outfall. This outfall is covered by the Illinois Environmental Protection Agency (IEPA) NPDES Permit # IL0076627 (Permit) which has an Effective Date of February 1, 2018. INSPECTION Jake Berger and Jason Hewitt of USEPA first arrived at the Facility at 8:45 a.m. CDT and were met by Gerald Kurelko (Plant Manager). Jake Berger and Jason Hewitt showed him their inspector credentials and identification and were instructed to call Robert Werth (Environmental Manager) who was not at the Facility on the day of the inspection. Jake Berger called Robert Werth at 9:04 a.m. CDT and explained the purpose of the inspection and began the opening conference. Opening Conference USEPA staff explained to Robert Werth that the purpose of the inspection was to: Review Atlas Tube's records such as sample measurements, monitoring activities, and storm water plans, as required by the Permit Conduct a walkthrough of the Facility; Identify locations where storm water control had the potential to be insufficient; and Inform Atlas Tube of areas of concern regarding the records review and facility walkthrough. Records Review Since Robert Werth was not able to review documents in person with USEPA, Jake Berger requested electronic copies of Atlas Tube's Storm Water Pollution Prevention Plan (SWPPP), Spill Prevention Control and Countermeasures (SPCC) plan, quarterly visual observations, annual facility inspections, and employee storm water training records. Robert Werth sent these documents to Jake Berger via email on August 16. Upon USEPA's review of these documents (which occurred after the in-person inspection had concluded), no areas of concern were 2 identified. The phone call with Robert Werth concluded at 9:49 a.m. CDT and was immediately followed by a Facility walkthrough tour with Eric Mouser (Warehouse Operations Manager). Facility Walkthrough USEPA staff made the following observations during the Facility walkthrough, further documented in the Photograph Log (attached): As shown in Photo 2 and Photo 3, sections of the banks of the storm water swale have little to no vegetation and are showing signs of erosion. As shown in Photo 3, sections of the storm water swale contain underground pipes that are clogged with trash and debris. As shown in Photo 4, totes containing a mixture of oil and water are stored outside and lack secondary containment. The Facility walkthrough tour ended at 10:40 p.m. CDT and was immediately followed by the closing conference. Closing Conference During the closing conference, USEPA staff explained to Eric Mouser that the provided documents would be reviewed later and that an inspection report would be sent to Robert Werth. USEPA confirmed that no information collected during the inspection was considered Confidential Business Information. USEPA concluded the inspection and left the Facility at 10:45 a.m. CDT. 3 Zekelman Industries, Inc. - Atlas Tube Division EPA Inspection 8/15/2022 All photos taken by Jake Berger, Physical Scientist, U.S. EPA Camera: Olympus TG-6 1: P8150001 Description: Starting location of storm water swale Camera Direction: W Date/Time: 8/15/2022 - 9:54 a.m. CDT 4 2: P8150002 Description: Storm water swale, open dumpsters, leachate in swale Camera Direction: S Date/Time: 8/15/2022 - 9:56 a.m. CDT 3: P8150003 Description: Storm water swale containing build up of trash and debris Camera Direction: N Date/Time: 8/15/2022 - 9:58 a.m. CDT 5 4: P8150004 Description: Totes containing a mixture of oil and water Camera Direction: NW Date/Time: 8/15/2022 - 10:05 a.m. CDT 5: P8150005 Description: Discharge of non-contact cooling water, drains to storm water swale Camera Direction: E Date/Time: 8/15/2022 - 10:11 a.m. CDT 6 6: P8150006 Description: Discharge of non-contact cooling water, drains to storm water swale Camera Direction: E Date/Time: 8/15/2022 - 10:11 a.m. CDT 7: P8150007 Description: Storm water inlets and laydown yard Camera Direction: NW Date/Time: 8/15/2022 - 10:19 a.m. CDT 7 8: P8150008 Description: Storm water inlets and laydown yard Camera Direction: NW Date/Time: 8/15/2022 - 10:19 a.m. CDT 9: P8150009 Description: Storm water swale near where outfall pipe leaves the property, facing upstream Camera Direction: W Date/Time: 8/15/2022 - 10:33 a.m. CDT 8 10: P8150010 Description: Storm water swale near where outfall pipe leaves the property, facing downstream Camera Direction: E Date/Time: 8/15/2022 - 10:33 a.m. CDT 11: P8150011 Description: Upstream view of storm water swale on north end of site Camera Direction: E Date/Time: 8/15/2022 - 10:34 a.m. CDT 9 12: P8150012 Description: Downstream view of storm water swale on north end of site Camera Direction: W Date/Time: 8/15/2022 - 10:35 a.m. CDT 10