Document 0rjd4k5m02waa2mJM04j5bBV

NPDES Inspection Report - Wastewater Treatment Facility National Database Information Inspection Date: August 19, 2024 Inspection Type: CEI - Wastewater Treatment Facility Entry/Exit Time: 9:15 a.m. - 3:20 p.m. NPDES ID Number: SDG589507 NAICS Code: 221320 Inspection ID: 202408_SDG589507 Lead inspector and affiliation: Brit Rustad / EPA Region 8 Inspector and affiliation: Jennifer Ferrando / EPA Region 8 Facility Location Information Site/Facility Name & Location: Pine Ridge Community Wastewater Treatment Facility Lat/Long: 43 0'44.00"N, 10235'18.00"W (lagoon) Red Top Ave., Pine Ridge, SD 57770 Email Report to: Ernie Abold, Director, Oglala Sioux Tribe (OST) Water & Sewer h20sewer@gwtc.net Contact Information Facility Contacts: Person/Company meeting definition of "Operator" Authorized Official(s) Name(s)/Title Ernie Abold / Director / OST Water & Sewer / present during the opening and closing conferences as well as the inspection James Begeman / Tribal Utility Consultant / Indian Health Service (IHS) / present during the opening and closing conferences as well as the inspection Oglala Sioux Tribe, Water and Sewer (OST Water & Sewer) Ernie Abold / Director / OST Water & Sewer Permit Information Is the permit on site and available? Lagoon Category: Discharge. Sub- Monitoring Frequency: Semi Yes, digitally category C, according to the Annual for effluent authorization of coverage letter. Effective Date: 04/05/2016 Expiration Date: 12/31/2020 Is the Facility under a compliance (administratively continued) schedule? No Is correct contact information indicated on ICIS? Yes Indicate correct contact information: N/A Receiving Water(s): unnamed tributary of the White Clay Creek Regulatory Inspector's source of information: Notice of Intent for the permit, ICIS, ECHO and facility representatives Page 1 of 14 Areas Evaluated During Inspection Permit Self-Monitoring Program Records Compliance Schedule Facility Site Review Laboratory Effluent/Receiving Waters Operations and Maintenance Flow Measurement Sludge Handling/Disposal Pretreatment Pollution Prevention Stormwater Combined Sewer Overflow Sanitary Sewer Overflow Report Review and Signature Drafter Name Draft Date Contact Information BRIT Digitally signed by BRIT RUSTAD Brit Rustad Date: 2024.10.22 RUSTAD 09:17:23 -06'00' 9/11/2024 U.S. EPA Region 8 Denver, Colorado rustad.brit@epa.gov (303) 312-6885 Reviewer Name Draft Date Contact Information U.S. EPA Region 8 Jennifer Ferrando 9/13/2024 Denver, Colorado ferrando.jennifer@epa.gov (303) 312-6601 Management Reviewer Name/Signature/Date Contact Information EMILIO LLAMOZAS U.S. EPA Region 8 Digitally signed by EMILIO Denver, Colorado LLAMOZAS Date: 2024.10.22 07:56:46 -06'00' llamozas.emilio@epa.gov (303) 312-6407 Emilio Llamozas, NPDES and Wetlands Enforcement Section Supervisor Inspection Narrative and Site Description 1.0 Introduction The inspection was conducted at the Pine Ridge Community wastewater treatment facility (facility; WWTF) located in Pine Ridge, South Dakota, to evaluate compliance with the facility's National Pollutant Discharge Elimination System (NPDES) permit. The EPA is responsible for implementing the NPDES program in Indian Country within the State of South Dakota. The inspection was announced approximately one month prior to the inspection to coordinate logistics for the inspection. On the morning of August 19, 2024, U.S. Environmental Protection Agency (EPA) inspectors Brit Rustad and Jennifer Ferrando (collectively, "we") met with Oglala Sioux Tribe Water & Sewer (OST Water & Sewer) Director, Ernie Abold. We were also joined by Indian Health Service (IHS) representative James Begeman, Tribal Utility Consultant. We presented our credentials and had an Page 2 of 14 opening conference in the OST Water & Sewer office where we explained the purpose of the inspection and discussed the design, operation, and Clean Water Act and NPDES compliance of multiple WWTFs operated by the OST Water & Sewer, including the subject facility. After the opening conference, we proceeded to conduct site reviews of the WWTFs operated by OST Water & Sewer, including the subject facility, for the remainder of August 19, 2024, through August 22, 2024. Throughout the inspection, we noted our observations in a checklist. Photographs taken during the inspection are included in the attached photo log. 2.0 OST Water & Sewer Operations During the opening conference when discussing all facilities, Ernie Abold indicated that over the course of a week all WWTFs, including four lift stations, are checked. OST Water & Sewer is not keeping weekly inspection logs for these checks or any operations or maintenance logs. Only two of the four lift stations currently have Supervisory Control and Data Acquisition (SCADA) capabilities, which creates a burden for the limited staff to physically go check the two remaining lift stations several times per week to ensure they are operating properly. Ernie Abold stated that OST Water & Sewer performs jetting of the collection system for all WWTFs twice a year, in the spring and fall. Lastly, sludge has not been removed from any WWTFs; according to the tribal utility consultant, sludge accumulation has not been an issue with any of the lagoons on Pine Ridge based on previous depth testing and observations. OST Water & Sewer operates both the water distribution as well as sewer collections systems across the Pine Ridge Reservation, which encompasses just over 2 million acres. According to Ernie Abold there are approximately 48,000 tribal members with half of these being served by the sewer collections system and the other half being primarily on septic systems. Septage from the majority of these septic systems is pumped and hauled to OST Water & Sewer's WWTFs throughout the reservation. At the time of the inspection, OST Water & Sewer employed 3 operators, in addition to the Director, and various managerial and administrative support staff. Only one of the three operators held any certifications. OST Water & Sewer customers, rates, and finances were briefly discussed during the opening conference. Users are billed a single, monthly water and wastewater fee. Ernie Abold stated that OST Water & Sewer's budget is not supplemented by any other resources. OST Water & Sewer recently began a 5-year rate increase, as the last rate increase was in 2009. Additionally, according to the OST Water & Sewer representative, the utility is owed over $1 million in outstanding user fees. This is in part a result of OST Water & Sewer's limited ability to discontinue service for customers who do not pay their bill. 3.0 Facility Description and Site Review The facility is permitted as a discharge facility under the EPA Region 8 General Permit for Wastewater Lagoon Systems in Indian Country in South Dakota (Permit) issued in 2016. An NOI was submitted on September 30, 2024, for coverage under the 2022 LGP. The NPDES Permits Section is currently Page 3 of 14 processing the NOI. According to the facility representatives the facility serves roughly 5,000 people in the Pine Ridge community, a few restaurants, a car wash, and a hospital. The facility accepts hauled waste from pumped septic tanks in the surrounding communities. The hauled waste is dumped into a manhole nearest the lift station. Waste can be diverted separately to each of the system's 3 primary cells. The 3 primary cells had an HDPE liner added in 2014. Waste flows from the primary cells to the upper secondary cell, which had its liner replaced last year. From the upper secondary cell, waste flows to the lower secondary cell and finally the 4 wetland cells. We started the inspection at the lift station, located approximately 1.3 miles northeast of the lagoon along BIA Road 32. The lift station gate was closed and locked and signage was present (photo 1). Inside the fenced area we observed the grinder vault (photo 2) and wet well (photo 3). We proceeded to inspect the electrical panel (photo 4) which appeared to be functioning as intended and pump hours were roughly equal between the two pumps. Lastly, we observed the dry well (photo 5). After leaving the lift station we drove to the lagoon. When we arrived, the gate was closed and supported by a fence post. The gate did not have a lock preventing unauthorized access. Signs were clearly visible next to the entrance. Upon entering the gate, we observed the 3 primary cells (photos 6 and 8). Prairie dog holes were abundant throughout the lagoon (photo 7). We drove around the exterior of the facility and observed the secondary cells, upper and lower (photo 9). Continuing around the exterior we observed the depth indicator in the upper secondary cell (photo 10) before continuing to the lower secondary cell (photo 11). At the southwest corner of the lower secondary cell, we observed the Thirsty Duck flow control device (photo 12) used in the level control structure for the cell. Next to the level control structure was an inlet gate valve structure with significant erosion at the base (photo 13). Trees and overgrown vegetation were noted primarily around the lower secondary cell (photo 14) and wetland cells (photo 15). The outfall has a V notch weir built into the outlet structure, just inside the fence (photo 16). The outfall, outside the perimeter fence, had significant erosion at the base (photo 16). Before leaving the facility, after the gate had been closed, several people were seen driving their ATVs inside the lagoon area. At the end of our inspections of OST Water & Sewer-operated WWTFs on August 22, 2024, we held a brief closing conference with Ernie Abold and James Begeman where we discussed preliminary findings. The following week on August 29, 2024, the EPA sent an email to Ernie Abold with the preliminary findings from the inspection and resources for documenting inspections, a lagoon troubleshooting guide, and a lift station standard operating procedures template. Findings, Corrective Actions and Recommendations Finding #1: The Permittee was not documenting weekly lagoon inspections. The facility representative stated that OST Water & Sewer staff visit each lagoon and lift station weekly, but did not maintain records of the inspections. The inspectors provided the facility representatives with a lagoon inspection report template form (Appendix D of the 2022 Lagoon General Permit) that the facility representatives could use to document the weekly lagoon inspections. Page 4 of 14 Permit Requirement: Part 3.3.1 of the Permit states, "On at least a weekly basis, unless otherwise modified by written approval from the EPA, the permittee shall inspect its wastewater treatment facility. The permittee shall maintain a notebook recording all information obtained during the inspection. At a minimum, the notebook shall include the following: 3.3.1.1. Name of facility and permit number; 3.3.1.2. Date and time of the inspection; 3.3.1.3. Name of the inspector(s); 3.3.1.4. The facility's discharge status; 3.3.1.5. The flow rate of the discharge if occurring; 3.3.1.6. If a discharge is occurring, has occurred since the previous inspection, and/or if a discharge is likely to occur before the next inspection. (Note: If a discharge has occurred or is likely to occur before the next inspection, perform the appropriate monitoring and reporting requirements in Parts 3.2 and 5.4 of this permit if not already done.); 3.3.1.7. Is there is any leakage through the dikes; 3.3.1.8. Are there are any animal burrows in the dike; 3.3.1.9. Is there any erosion of the dikes (e.g., rills, cracks or other structural indications of erosion); 3.3.1.10. Are there are any rooted plants, including weeds growing in the water; 3.3.1.11. Does the vegetation growth on the dikes needs mowing (e.g. greater than 6" tall); 3.3.1.12. List the date scheduled for operation and maintenance procedures to be undertaken at the wastewater treatment facility. 3.3.1.13. Identification of operational problems and/or maintenance problems; 3.3.1.14. Recommendations, as appropriate, to remedy identified problems; 3.3.1.15. A brief description of any actions taken with regard to problems identified; and, 3.3.1.16. Other information, as appropriate. The permittee shall maintain the notebook in accordance with required record-keeping items listed above and shall make the log available for inspection, upon request, by authorized representatives of the U.S. Environmental Protection Agency or the applicable Tribe (see Part 5.10 of this permit)." Part 3.3.3 of the Permit states, "Problems identified during the inspection shall be listed with corrective action and a time frame to correct the issue. Example: repair cracks in North berm, remove animal and repair burrow, within 7 days. (See Part 6.5 of this permit.)" Part 5.7 of the Permit states, "The permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, inspection records, notifications to the EPA per this permit, and DMRs, for a period of at least five years from the date of the sample, measurement, report, application or submittal. Records of monitoring required by this permit related to sludge use and disposal activities must be kept at least five years (or longer as required by 40 C.F.R. Part 503). Page 5 of 14 This period may be extended by request of the Director at any time. Data collected on site, data used to prepare the DMR, copies of DMRs, a copy of this NPDES permit, and the notice of intent for permit coverage, must be maintained on site." Corrective Action: Ensure that lagoon inspections are conducted on a weekly basis and documented in accordance with the Permit. Ensure that weekly lagoon inspection reports are retained in accordance with the recordkeeping requirements of the Permit. Provide the EPA and the Oglala Sioux Tribe Environmental Department with 1 month's worth of weekly inspection reports. Finding #2: Overgrown vegetation and trees were evident throughout the cells. Vegetation more than six inches in height, cattails and trees were present on the inside of most cells and on some berms (photos 6, 8, 11, and 14). Trees were growing inside the wetland cells (photo 15). Permit Requirement: Part 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance. In addition to the operation and maintenance items in the manual for the lagoon system, the permittee shall do the following maintenance: 6.5.1. Take necessary action to promptly correct the problem of leakage through the dikes; 6.5.2. Take necessary action to promptly remove burrowing animals from the dikes; 6.5.3. Promptly repair damage to dikes caused by burrowing animals and/or erosion; 6.5.4. Remove rooted plants, including weeds, from the water on a regular basis or as needed; and 6.5.5. Keep the dikes mowed on a regular basis during the growing season or as needed (e.g., keep growth below 6" in height)." Corrective Action: Remove the trees on the inside and around the berms in all cells, and remove overgrown vegetation and cattails from the primary and secondary cells, in accordance with Part 6.5 and relevant subparts of the Permit. Submit to the EPA and the Oglala Sioux Tribe Environmental Department photos of all cells after the vegetation and trees have been removed. Finding #3: Animal burrows were evident throughout the cells. Excessive prairie dog holes were evident on most of the berms (photo 7). Page 6 of 14 Permit Requirement: Part 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance. In addition to the operation and maintenance items in the manual for the lagoon system, the permittee shall do the following maintenance: 6.5.1. Take necessary action to promptly correct the problem of leakage through the dikes; 6.5.2. Take necessary action to promptly remove burrowing animals from the dikes; 6.5.3. Promptly repair damage to dikes caused by burrowing animals and/or erosion; 6.5.4. Remove rooted plants, including weeds, from the water on a regular basis or as needed; and 6.5.5. Keep the dikes mowed on a regular basis during the growing season or as needed (e.g., keep growth below 6" in height)." Corrective Action: Remove burrowing animals and make repairs where burrowing animals have damaged berms, in accordance with Part 6.5 and relevant subparts of the Permit. Submit to the EPA and the Oglala Sioux Tribe Environmental Department a plan which address the removal of burrowing animals, repair of damage, and efforts that will be taken to keep burrowing animals out of the lagoon. In addition to the plan, provide photos showing the repairs of the current burrows. Finding #4: DMRs have not been submitted for several reporting periods. According to the authorization of coverage letter, the facility is covered under Discharge Subcategory C, which requires semiannual reporting. The Permittee had not submitted DMRs for the effluent monitoring periods listed below at the time of the inspection and as a result the Permittee was in significant noncompliance (SNC) status for failing to submit DMRs. The following DMRs were missing: 1. The DMR for outfall 001C-1B for the monitoring period from July 1, 2023, to December 31, 2023, which was due on January 28, 2024. 2. The DMR for outfall 001C-1B for the monitoring period from January 1, 2024, to June 30, 2024, which was due on July 28, 2024. Permit Requirement: Part 5.4.2 of the Permit states, "Reporting of Effluent Monitoring Results for calendar quarter or semi-annual period DISCHARGE Facilities. Effluent monitoring results obtained during the previous calendar quarter or semi-annual period shall be summarized and reported on a Discharge Monitoring Page 7 of 14 Report (DMR) Form (EPA No. 3320-1), postmarked no later than the 28th day of the month following the completed reporting period. If no discharge occurs during the reporting period, "no discharge" shall be reported, see example below. Legible copies of these, and all other reports required herein, shall be signed and certified in accordance with the Signatory Requirements (see Part 7.7), and submitted to the Planning and Targeting Program and the applicable Tribe at the addresses given in Part 5.4.4 below." Example: Reporting Period Quarterly (e.g. April - June) Semi-annually (e.g. July - December) DMR Due Date 28th day following the end of the quarter (July 28th) 28th day following the end of the 6th month (January 28th) Corrective Action: Submit all DMRs that are past due and provide evidence that these DMRs have been submitted in a response to this report. Ensure that all DMRs are submitted in a timely manner in accordance with Part 5.4.2 of the Permit. EPA checked NetDMR on 8/29/2024 and notes that past DMRs were updated on 8/27/2024 using NODI code C, indicating that no discharge occurred during those reporting periods. No further action is required for this finding. Finding #5: The gate to the lagoon was not locked. The gate was closed at the time of the inspection but was not locked. While leaving the facility, several people were seen driving around inside the fenced area on ATVs. EPA Guidance: EPA has developed guidance manuals on the proper operation and maintenance of lagoons. One of the guidance materials is called "Principles of Design and Operations of Wastewater Treatment Pond Systems for Plant Operators, Engineers, and Managers" (August 2011, EPA/600/R-11/088). https://www.epa.gov/sites/production/files/2014-09/documents/lagoon-pond-treatment-2011.pdf This guidance manual indicates on page 9-20 that, "[t]o discourage use of the ponds for recreation, the entire area should be fenced and warning signs displayed." Permit Requirement: Part 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set Page 8 of 14 of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance." Recommendation: Ensure the lagoon gate can be locked to prevent unauthorized access and entrance. Finding #6: The Permittee was not calibrating the pH meter. The facility representative stated that the pH meter that is used to measure the effluent and receiving water pH had never been calibrated. Permit Requirement: Part 5.7 of the Permit states, "The permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, inspection records, notifications to the EPA per this permit, and DMRs, for a period of at least five years from the date of the sample, measurement, report, application or submittal." Corrective Action: Ensure the pH meter is calibrated in accordance with the manufacturer's recommendations using current (un-expired) buffer solutions before the meter is used for effluent monitoring in accordance with the Permit requirements. Retain calibration records, in accordance with requirements of the Permit. Provide the EPA and the Oglala Sioux Tribe Environmental Department with a description of the corrective actions taken to address this finding, including a copy of the procedures that will be followed to calibrate the meter and an example log sheet that will be used to document the calibration. Finding #7: Facility does not have enough staff or funding. During the opening conference, staffing and funding resources were discussed. The facility representatives estimated that six operators would be needed, in addition to the Director, to operate the WWTFs in compliance with the permit requirements; however, at the time of the inspection, only three operators were employed by OST Water & Sewer. In addition, the utility does not have sufficient revenue and is not able to collect unpaid user fees to fund necessary operation and maintenance activities. It is apparent based on that conversation as well as field observations that this facility does not have adequate staff or funding to fully comply with the permit. Permit Requirement: Part 6.1 of the Permit states, "The permittee must comply with all conditions of this permit. Any failure to comply with the permit may constitute a violation of the Clean Water Act and may be grounds for enforcement action, including, but not limited to permit termination, revocation and reissuance, modification, or denial of a permit renewal application. The permittee shall give the director advance notice of any planned changes at the permitted facility that will change any Page 9 of 14 discharge from the facility, or of any activity that may result in failure to comply with permit conditions." Recommendation: EPA recommends developing a staffing and funding plan (plan) that includes the number of staff needed to comply with the permit, staff retention plan (competitive pay and proper training), SOPs for collection of outstanding fees, and evaluation of alternative funding sources. EPA also recommends that the plan should include deadlines for accomplishing each of the items listed in the plan. Finding #8: DMR shows an incorrect NODI code. The DMR submitted for December 31, 2022, for Outfall 001C-1B used NODI code I, indicating that the effluent had been land applied. All previous and subsequent DMRs used NODI code C, indicating that no discharge occurred for that reporting period. During the opening conference this irregularity in reporting was discussed and facility representatives stated that this must have been an error, as they do not land apply their effluent. Permit Requirement: Part 5.4.2 of the Permit states, "Reporting of Effluent Monitoring Results for calendar quarter or semi-annual period DISCHARGE Facilities. Effluent monitoring results obtained during the previous calendar quarter or semi-annual period shall be summarized and reported on a Discharge Monitoring Report (DMR) Form (EPA No. 3320-1), postmarked no later than the 28th day of the month following the completed reporting period. If no discharge occurs during the reporting period, "no discharge" shall be reported, see example below. Legible copies of these, and all other reports required herein, shall be signed and certified in accordance with the Signatory Requirements (see Part 7.7), and submitted to the Planning and Targeting Program and the applicable Tribe at the addresses given in Part 5.4.4 below." Part 5.4.4.1 of the Permit states, "Electronic submission of discharge monitoring reports: NPDES permittees required to submit DMRs may use NetDMR after requesting and receiving permission from the EPA. After the EPA has approved the facility's request, the NetDMR tool enables permittees to complete their DMRs via a secure Internet connection. For more information on getting started, please visit; https://netdmr.epa.gov/netdmr/public/getting_started.htm." Corrective Action: Enter the appropriate NODI codes, if applicable, when inputting data into NetDMR. Update the December 31, 2022, DMR with the appropriate NODI code, or sampling results, for all parameters. In a response to the EPA and the Oglala Sioux Tribe Environmental Department, provide a screenshot of updated data in NetDMR or inform EPA and the Oglala Sioux Tribe Environmental Department that corrections have been made so that the data can be verified. Page 10 of 14 Finding #9: The Permittee failed to submit Discharge Monitoring Reports. During the opening conference, when discussing this facility, Ernie Abold stated that there may have been a discharge last year. This is not reflected in NetDMR because all the DMRs reviewed for 2023 indicated no discharge. Permit Requirement: Part 3.2 of the Permit states, "At a minimum, upon the effective date of this permit, the following constituents shall be monitored at the frequency and with the type of measurement indicated; samples or measurements shall be representative of the volume and nature of the monitored discharge. If no discharge occurs during the entire monitoring period, it shall be stated on the Discharge Monitoring Report (DMR) Form (EPA No. 3320-1) that no discharge or overflow occurred. ...Sub-category C - Semi-annual/periodic Monitoring Effluent Characteristic Flow, MGD 5-day BOD5, mg/L Total Suspended Solids (TSS), mg/L pH, standard units Total Ammonia Nitrogen (as N) Escherichia coli, colonies/100 mL a/ Total Nitrogen (N), mg/L Total Phosphorus (P), mg/L Oil and Grease, Visual Oil and Grease, mg/L b/ Frequency a/ a/ a/ a/ a/ a/ b/ a/ a/ a/ c/ Sample Type Instantaneous Grab Grab Instantaneous Grab Grab Grab Grab Observation Grab a/ The discharge shall be monitored three times per week for the first week of discharge (sample taken and flow rate measured), including once as soon as practical after the unauthorized release is discovered or when an expected unauthorized release begins, and at weekly intervals thereafter until the unauthorized release stops. If the discharge lasts less than one week in duration, monitoring shall be performed at the beginning, middle, and end of the discharge event. b/ Monitoring for Escherichia coli is required during the months of May thru September. c/ In the event that an oil sheen or floating oil is observed in the discharge, a grab sample shall be taken immediately and analyzed in accordance with the requirements of 40 C.F.R. Part 136." Part 5.4.2 of the Permit states, "Reporting of Effluent Monitoring Results for calendar quarter or semi-annual period DISCHARGE Facilities. Effluent monitoring results obtained during the previous calendar quarter or semi-annual period shall be summarized and reported on a Discharge Monitoring Report (DMR) Form (EPA No. 3320-1), postmarked no later than the 28th day of the month following Page 11 of 14 the completed reporting period. If no discharge occurs during the reporting period, "no discharge" shall be reported, see example below. Legible copies of these, and all other reports required herein, shall be signed and certified in accordance with the Signatory Requirements (see Part 7.7), and submitted to the Planning and Targeting Program and the applicable Tribe at the addresses given in Part 5.4.4 below." Example: Reporting Period Semi-annually (e.g. July - December) DMR Due Date 28th day following the end of the sixth month (January 28th) Part 5.4.4.1 of the Permit states, "Electronic submission of discharge monitoring reports: NPDES permittees required to submit DMRs may use NetDMR after requesting and receiving permission from the EPA. After the EPA has approved the facility's request, the NetDMR tool enables permittees to complete their DMRs via a secure Internet connection." Part 5.6 of the Permit states, "Records of monitoring information shall include: 5.6.1 The date, exact place, and time of sampling or measurements; 5.6.2. The initials or name(s) of the individual(s) who performed the sampling or measurements; 5.6.3. The date(s) analyses were performed; 5.6.4. The time(s) analyses were initiated; 5.6.5. The initials or name(s) of individual(s) who performed the analyses; 5.6.6. References and written procedures, when available, for the analytical techniques or methods used; and, 5.6.7. The results of such analyses, including the bench sheets, instrument readouts, computer disks or tapes, etc., used to determine these results." Part 5.7 of the Permit states, "The permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, inspection records, notifications to the EPA per this permit, and DMRs, for a period of at least five years from the date of the sample, measurement, report, application or submittal. Records of monitoring required by this permit related to sludge use and disposal activities must be kept at least five years (or longer as required by 40 C.F.R. Part 503). This period may be extended by request of the Director at any time. Data collected on site, data used to prepare the DMR, copies of DMRs, a copy of this NPDES permit, and the notice of intent for permit coverage, must be maintained on site." Corrective Action: Ensure that all required monitoring is conducted during discharge events in accordance with the permit. Determine if a discharge occurred last year, and if so, update NetDMR with the correct sampling data. If a discharge occurred and there is no sampling data, use the appropriate NODI code to document the event (For example, NODI code E - Failed to Sample/Required Analysis Not Page 12 of 14 Conducted). In a response to the EPA and the Oglala Sioux Tribe Environmental Department, either provide a screen shot of NetDMR, updated with the sampling information for the monitoring period in which the discharge occurred, or inform EPA and the Oglala Sioux Tribe Environmental Department of the corrected data so it can be verified in NetDMR. If no discharge occurred last year and current NetDMR records are accurate, notify EPA, so that this finding can be closed. Finding #10: The soil was eroded under an inlet gate valve and outlet structure. During the facility inspection significant erosion was noted at the base of the inlet gate valve from the lower secondary cell (photo 13). Erosion also was noted under the concrete flared end section at the outfall (photo 16). Permit Requirement: Part 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance." Part 6.5.3 of the Permit states, "Promptly repair damage to dikes caused by burrowing animals and/or erosion" Corrective Action: Repair areas of erosion throughout the facility during regular operation and maintenance. In a response to the EPA and the Oglala Sioux Tribe Environmental Department, provide photos showing corrective actions taken to repair the erosion. Finding #11: The facility was experiencing recurrent force main breaks. During the opening conference when discussing the facilities collection system, facility representatives indicated that there have been 11 force main breaks in the past 5-7 years. Facility representatives become aware of the main break when the amperage at the lift station increases dramatically. Once they become aware of the high amperage, facility personnel drive the line and find an area of ground that is saturated. To catch these breaks sooner, a high amperage alarm has been set for the lift station notifying facility personnel through the SCADA system. Facility representatives stated that they have been relining pipes over the last 2 years and an emergency project has been created through IHS to replace 3000 feet of the sewer main to fix these issues. Permit Requirement: Part 5.8.1 of the Permit states, "The permittee shall report any noncompliance which may endanger health or the environment as soon as possible, but no later than twenty-four (24) hours from the Page 13 of 14 time the permittee first became aware of the circumstances. The report shall be made to the EPA, Region 8, Preparedness, Assessment and Response Program at (303) 293-1788 and the applicable Tribe (see Appendix A for list of Tribes and telephone numbers)." Part 5.8.2 of the Permit states, "The following occurrences of noncompliance shall be reported by telephone to the EPA, Region 8, NPDES Enforcement Unit at (800) 227-8917 (8:00 a.m. - 4:30 p.m. Mountain Time) and the applicable Tribe (see Appendix A for list of Tribes and telephone numbers) (8:00 a.m. - 4:30 p.m. local time) by the first workday following the day the permittee became aware of the circumstances: ... 5.8.2.2. Any unauthorized release, including sanitary sewer overflows;" Part 5.8.3 of the Permit states, "A written submission shall also be provided to the EPA and to the applicable Tribe within five days of the time that the permittee becomes aware of the circumstances. The written submission shall contain: 5.8.3.1. A description of the noncompliance and its cause; 5.8.3.2. The period of noncompliance, including exact dates and times; 5.8.3.3. The estimated time noncompliance is expected to continue if it has not been corrected; and, 5.8.3.4. Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance. Part 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance." Corrective Action: Ensure future main breaks and any unauthorized releases that may endanger human health and the environment are reported to the EPA per Permit requirements. In a response to the EPA and the Oglala Sioux Tribe Environmental Department, provide an update on the project to repair the force main line with a projected timeline for completion. Page 14 of 14 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8 RESOURCE CONSERVATION AND RECOVERY ACT 'EZ>/E&KZDd/KE &EWZD&>> ZZ/hdZ &>ZZ &Z ^>s^^>h 'D ZZ EZZ^ Z/Z: >Y'Z d d >/ZZZZDh^W/Z /Z >:ZZh^W/Z :DZtDZ/Z tDZ/Z 'DWZD&WZ Z,^>WZ :ZEZ>ZZ^ZWZ ZZ,^DWZZZdZZ ZZZZZ :ZhDtZZWZZdZ ZZ dZZZZZZZZZ WDWZ :ZZWZ dWZZ/Z ZZ/Z ZZZ^ &d WE/^WWZZZZ KE/^ D,d DZ ZZZZZZhZhZZ h &EWZD&hdZ &>ZZ^>s^^>h Z/Z: /Zd hZ/Z WZtDZZ dZZZZZZZZ ZdZZZZZZZZZZZ ZZZZZZZ KWE/E'KE&ZE hZZZZDDZD tZZZDZZ ZtZZZZ ZZ ^Z/Wd/KEK&/E^Wd/KE ZZ^ ZZZZ/Z>Y'Z>Y'ZZ dZZZZZZZZ ZZZ &WZZ WZZZZZZZ ZZZZZZ Zd ^>ZZZ ZZZZZZZ ZZZZZ ZZZZd ZZZZ ZZZZZYYZZZZ ZZZ ZZZZZZhY ZZZZZZZZ ZZZZZZZZ ZZZ WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: ZZZZZ,ZZZZ ZDZZ&Z /ZZZZZZ ZZ ZZZZZ x D& x W&& x ^ x W x tZZ&& ZZ ZZZZtZ Z /ZZ^ZZ ZZZZZtZZ ZZZZZZZ ZZZZZ ZZ ZZ dZZZZZZZ ZtZZZ ZZZ ^D dKhZ/E&KZDd/KE ZZZWZZ WWZZZZZZhY hYWZZ Z&Z x WZ x WZZ x x WZZ WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: x t x dZZZZ x > x hZZ x hZ x x tZZ^ x hZ x WZZ x x &Z x KZZZZ dZZZZZZZZ Z /tZtZ/ZZ^Z ZZZ/ZZZ ZDZZZZZZ ZZZZZdZZ ZZ /tZtZZ/ZZ^Z ZZZZ,Zt ZZZ ZtZtZZZZZZ ZZZZ^ZZZ ZZWDZZ ZZZZ ZZZ^^ZZ&ZZ ZZ:DZZZZZZ ZZZ^Z ZZ&ZZ Z/ZZZZ ZZZZZZ ZZZZZZZZ ZZ WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: ZZ'Z^YZZZd ZZZZDEZ ZZ,ZZ dZZZ ZZZZZ:Z ZZZZ& ZZdZZZ'Z ^ZZZZ /ZZd/ZZZZ ZdZZ^ ZZZ/WZZZZZZ ZK:DZZZ ZZZZZZZZZ ZZZZZ/Z: ZZZZZZZZ ZZZZZZZ Z /ZZZZZ ZZZZdZ /ZZd/ZZZZZ ZZZZZZ ZZZZZZZZ ZZZ KZZ/ZZZ ZZZZZZ //ZZZZZ ZZZ KZ/ZZZZ ZtZZ dZZZZ ZZ /tZ/ZKZ Z^ZZdZZZ^Z ZZZZZ^ZZ /ZZZ WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: ZZZZZZDZ ZZZdZZ ZZZZZZ E/ZZZZZZD ZZZZ ZZZZ /tZW/ZZZ tZtWZZ^ZZZZZ ZZZZZ ZZZ //ZZ ZZZZZZ ZZtZ/ZZ ZZZZZ,ZZZ ZZZdZ ZZZZDZ ZZZ^ZZZ /ZZZ ZZZZ/Z ZZZZZZZZ ZZZZZZZ ZZZZ ZZ^ZZZK:DZ ZZZZZ ZZZZZ //ZZdWttd ZZdZ ZZZZZZZZ^ZZZ K:DZZZZZ Z^ZZZ KZZZZZ/ZZZZZZZ ZZZZ WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: E/ZZZZZZZZ KZZZZ/Z ZZZZZZZd ZZZ ZZZZZ ZZZZZ E/ZZZZ ZZZZZ ZZZ dZZZZZ ,ZZZWYZ' ZZ dZZWZZZd ZZZZZZZZZ ZZZWZZZZZ ZZZ ZZZZZZZZZ >K^/E'KE&ZE ZZ/ZZZ x dZZZZZZZ ZZZZ^Z x Z'ZZ ZZ x WZZZZ 'ZZ x ,ZZZZZZZZ x ZZZZZZZ ZZZZ x &ZZtZZ ZZZ x d^^Z< WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: x &ZZZZ x ddW x ZZZZZ x dZZZ x dZZZZZ ZZ x dZZZZ Z x ZZZZWZ WK^d/E^Wd/KEKhDEdd/KEZs/t K:DZZZZ x ZZZ x d^^Z< x >ZZZ x ZZZ K:DZZZZ x ZWZZZ' K:DZZZZZ x ZZdZZZZ /d/KE>/E&KZDd/KEE &ZZZZZ x ,ZZZ x ,ZZZZ x hZZWZZZZZh x ZZZZZZZWZYZ'ZZZ hZZZZ WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: ^/'EdhZ^ A NNETTE MAXWELL Date: 2024.07.31 11:04:29 -06'00' Digitally signed by ANNETTE MAXWELL DZZ/Z Digitally signed by Susarla, Susarla,SridharSridhar ^^D Date: 2024.08.01 11:14:41 -06'00' ZZKWZ ZZZ dd,DEd>/^d ^D WWZZ hYWZZ &ZZ WZ  ^D WZD& ^ &ZZ >ZZ tZt /Z'ZZD >D >ZZZ E & t d tZ ^ D  WWZZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: dd,DEdW,KdK>K' WZZD DZ/WZ^Z WZZ/D'ZZZZZZZ &ZZZZZ WZZZZZZZ ZZZ WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: WZZ/D'ZZZZZZ WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: WZZ/D'ZZZZZ tZZZZZ> d WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: WZZ/D'ZZZZdWtZ WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: WZZ/D'ZZZZZZ WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: WZZ/D'ZZZZZZ Z WZ &EWZD&hdZ &>ZZ^>s^^>h Z/Z: WZZ/D'ZZZZZ ZZZ WZ  hYWZZ Facility Name: Pioneer Metal Finishing (UTR000007062) Facility Location: 1225 S Legacy View Street, Salt Lake City, Utah Date of Inspection: June 4, 2024 ATTACHMENT 3 - UTAH DEQ PHOTOGRAPHS All photographs in this photo log were collected by Judith Moran of Utah DEQ during the inspection on June 4, 2024. Photo 1: Photo of a hazardous waste SAA container located in the Wet Coat West paint storage area. Page 1 of 12 Facility Name: Pioneer Metal Finishing (UTR000007062) Facility Location: 1225 S Legacy View Street, Salt Lake City, Utah Date of Inspection: June 4, 2024 Photo 2: Photo of the same SAA shown in photo 1 of this attachment. Photo 3: Emergency response procedure posted next to the paint storage area. Page 2 of 12 Facility Name: Pioneer Metal Finishing (UTR000007062) Facility Location: 1225 S Legacy View Street, Salt Lake City, Utah Date of Inspection: June 4, 2024 Photo 4: Emergency response procedure posted next to the paint storage area. Photo 5: 5-gallon buckets used by painters to accumulate solvents after rinsing their paint guns. Page 3 of 12 Facility Name: Pioneer Metal Finishing (UTR000007062) Facility Location: 1225 S Legacy View Street, Salt Lake City, Utah Date of Inspection: June 4, 2024 Photo 6: Photo of the contents of one of the two cans shown in photo 5 after facility personnel removed the lid to show the contents. Photo 7: Photo of test strip used to assess a spill into secondary containment in the Building 1 90-day central accumulation area. Page 4 of 12 Facility Name: Pioneer Metal Finishing (UTR000007062) Facility Location: 1225 S Legacy View Street, Salt Lake City, Utah Date of Inspection: June 4, 2024 Photo 8: Photo of the spill into secondary containment referenced in the photo 7 description. Photo 9: Photo of a drum of GardoStrip Q4599 on the secondary containment shown in photo 8. Page 5 of 12 Facility Name: Pioneer Metal Finishing (UTR000007062) Facility Location: 1225 S Legacy View Street, Salt Lake City, Utah Date of Inspection: June 4, 2024 Photo 10: Photo of a wall posting of wastewater treatment process. Photo 11: Photo of a wall posting of wastewater treatment process. Page 6 of 12 Facility Name: Pioneer Metal Finishing (UTR000007062) Facility Location: 1225 S Legacy View Street, Salt Lake City, Utah Date of Inspection: June 4, 2024 Photo 12: Photo of a cubic yard box of hazardous waste located in the Building 2 Wet Coat East 90-day central accumulation area. Photo 13: Close-up of the label on the container shown in photo 12, showing that the label was missing an accumulation start date. Page 7 of 12 Facility Name: Pioneer Metal Finishing (UTR000007062) Facility Location: 1225 S Legacy View Street, Salt Lake City, Utah Date of Inspection: June 4, 2024 Photo 14: Photo of an additional cubic yard box containing hazardous waste located in the Building 2 Wet Coat East 90-day central accumulation area. Photo 15: Close-up of the label on the container shown in photo 14, showing that the label is missing an accumulation start date. Page 8 of 12 Facility Name: Pioneer Metal Finishing (UTR000007062) Facility Location: 1225 S Legacy View Street, Salt Lake City, Utah Date of Inspection: June 4, 2024 Photo 16: Photo of the label shown in photo 13 after facility personnel added the accumulation start date to the label. Photo 17: Photo of the label shown in photo 15 after facility personnel added the accumulation start date to the label. Page 9 of 12 Facility Name: Pioneer Metal Finishing (UTR000007062) Facility Location: 1225 S Legacy View Street, Salt Lake City, Utah Date of Inspection: June 4, 2024 Photo 18: Photo of the wastewater treatment filter press. Photo 19: Photo of spilled filter cake on the floor in the area shown in photo 18. Page 10 of 12 Facility Name: Pioneer Metal Finishing (UTR000007062) Facility Location: 1225 S Legacy View Street, Salt Lake City, Utah Date of Inspection: June 4, 2024 Photo 20: Photo of additional pieces of filter cake on the drum in the foreground in the area shown in photo 18. Also visible at left in a containment pan is water containing filter cake and filter press drippings. Photo 21: Photo of spilled filter cake on the floor west of the filter press, and potential chromium-containing green residue in the area of the filter press. Page 11 of 12 Facility Name: Pioneer Metal Finishing (UTR000007062) Facility Location: 1225 S Legacy View Street, Salt Lake City, Utah Date of Inspection: June 4, 2024 Photo 22: Close-up of the area shown in photo 21. Photo23: Photo of the filter press shown in photo 18 and containment pan visible in photo 20. Page 12 of 12  &ZZ Maxwell, Annette From: Sent: To: Cc: Subject: Attachments: Follow Up Flag: Flag Status: Daniel Renner <drenner@pioneermetal.com> Wednesday, June 12, 2024 3:53 PM Maxwell, Annette; Jacobson, Linda; Judith Moran; Alexis Adams Dave Dettman; Chad Earl Pioneer Metal Finishing EPA RCRA Inspection Pioneer Metal Finishing RCRA Corrections Packet.pdf; Reducer NO. K69 530-2138.pdf; Hazardous Waste Manifest and Land Disposal Record Spreadsheet 2023-2024.xlsx; ARRANGEMENTS WITH LOCAL AUTHORITIES.pdf Follow up Flagged Z dZZZWZZZZ ZZZ 'ZZZZ WZZZZZZtZZZZ ZZZZZZZ WZZZZZZ dZ Danny Renner Environmental Health & Safety Lead Pioneer Metal Finishing 1225 S Legacy View Street Salt Lake City, Utah 84104 Direct: 801-214-7223 Cell: 417-207-0387 Email: drenner@pioneermetal.com dZZ/ZZZZ ZZ/ZZZZZZZ ZZZ/ZZZ 1 RCRA Audit Action Item Packet Listed in this packet are the corrective actions taken outlined in the meeting reviewing the RCRA Inspection with the following Agents: Annette Maxwell, Linda Jacobson, Judy Moran, and Lexi Adams. In this meeting, cosmetic and administrative changes were discussed that if put in place would bring Pioneer Metal Finishing into compliance. Pioneer Metal Finishing was allowed until End of Day Wednesday June 12, 2024 to submit and verify that these corrective actions had taken place. Date of Audit: June 4, 2024 Location: Pioneer Metal Finishing 1225 S. Legacy View Street Salt Lake City, UT 84104 Team Members: General Manager: Chad Earl Corporate EHS Manager: Dave Dettman Site EHS Lead: Danny Renner Quality Lead: Matt Federer Laboratory Manager: Jeerson Ngo 1 Action Item 1: Attachments 1. Updated EAP and Reference Guide a. Local Authority Agreement attached, in process of collecting signatures. 2. Hazardous Waste Manifest and Land Disposal Record Spreadsheet 2023-2024 3. SDS for K-69 Reducer 2 Action Item 2: Spill Pallet Housekeeping. The spill pallet was rinsed into our waste water treatment collection area and allowed to dry before returning to it's original location. An Annual secondary containment house keeping task was created for this task to be carried out by the Lab. It was determined that the reason the pH tested at zero was due to the incorrect testing strip to be used. The test used the day of the audit measures total chlorine and when we tested with the proper pH strip is was in the 5-6 range. 3 4 Action Item 3: Waste Water Equipment Preventative Maintenance Task 5 Action Item 4: Filter Cake Housekeeping Task Housekeeping is now a required task after each filter cake transfer. This area will be monitored in the weekly RCRA inspection. *Filter cake disposal was in process at time of documentation. 6 7 Action Item 5: Disposal of expired nitric acid drums The drums were treated through the wastewater system, triple rinsed and disposed of. 8 Action Item 6: Disposal of unlabeled drums The Drums were treated through our wastewater system, triple rinsed, and disposed of. 9 Action Item 7: Label Gardostrip drum with hazardous waste label and add accumulation date. The contents of the original Gardostrip drum were transferred to a poly drum due to its corrosive nature. 10 Action Item 8: Update Waste Paint Transfer Process. The five gallon buckets have been removed from the process altogether. We have moved the 55 gallon drums to the mixing stations and have attached a locking funnel. The funnel for wet coat west is still in transport and should arrive on 6/13/2024. So currently all painters are cleaning their guns in wet coat east. We also updated the acetone and K-69 secondary containers with the proper placards. 11 Action Item 9: Update Lacquer Thinner Transfer Process The Flammable cabinets were moved closer to where the waste stream is being created and grounded. The five gallon containers were relabeled and two were decommissioned. The expectation from our team members is that they will be emptying the cans at the end of each shift. 12 Action Item 10: Install TCP Satellite Drum This drum has replaced the TCP drum we were using during the time of the inspection. It has been added to our facility map and the weekly RCRA inspection form. 13 Action Item 11: EP and Chromic Scrubber The scrubbers that service the EP and Chromic lines utilize a water drip filtration system. The water from those scrubbers is then directly run into our waste water treatment process. Routine maintenance is performed every ten years to clean and evaluate the internal system. The arrows in the below picture indicate the path that the waste water takes to enter the treatment tank. 14 Action Item 12: TCLP for Used filters and Sand Blast Media The used filters were deemed hazardous from the RCRA 8 Metals TCLP; D004(arsenic), D007(Chromium), D008(lead). A profile is in development with Clean Harbors and the contents of that drum have been transferred to a closed poly drum labeled hazardous waste. 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Yes yes yes Final Manifest Return Date from Disposer 2/6/2023 2/6/2023 3/17/2023 Clean Clean Harbors MAD0393222 Harbors UTD9815521 yes 77 Argonite LLC Clean Harbors Clean Harbors MAD0393222 Grassy UTD991301 yes 748 Mountain, LLC Clean Harbors MAD0393222 Safety Kleen KYD05334810 yes Systems, INC 8 Clean Clean Harbors MAD0393222 Harbors UTD9815521 yes 77 Argonite LLC Clean Harbors Clean Harbors MAD0393222 Grassy UTD9913017 yes 48 Mountain, LLC Clean Harbors MAD0393222 Safety Kleen KYD05334810 yes Systems, INC 8 3/24/2023 4/6/2023 4/17/2023 6/14/2023 6/2/2023 8/1/2023 Disposal Code H132 H132 H061 H040 H132 H061 H040 H132 H061 Clean Harbors MAD0393222 Safety Kleen KYD05334810 yes Systems, INC 8 8/1/2023 H061 Clean UTD9815521 Clean Harbors MAD03932225 Harbors 77 Yes Argonite LLC Clean Harbors MAD03932225 Safety Kleen KYD05334810 Yes Systems, INC 8 Clean Harbors UTD9913017 Clean Harbors MAD03932225 Grassy 48 Yes Mountain, LLC Clean Harbors Clean Harbors MAD03932225 Grassy UTD9913017 Yes 48 Mountain, LLC 9/26/2023 H040 10/15/2023 H061 10/9/2023 H132 10/9/2023 H132 018381372FL Waste Paint 12 E CH607714 Related 3 DM N/A N/A 10/18/2023 1200 P Materials 13 018381371FL CH995228 Filter Cake 2 E CF N/A N/A 10/18/2023 1600 P 018381371FL Spent Plastic 13 E CH2521829 Blast Media 2 w/Chromium CF N/A N/A 10/18/2023 1600 P 019163378FL Waste 14 E CH607705 Trichloroethyl 3 DM N/A N/A 11/28/2023 400 P ene 019163381FL Waste Paint 15 E CH607714 Related 600 DM N/A N/A 11/28/2023 600 P Materials 16 019163380FL CH995228 Filter Cake 800 CF N/A N/A 11/28/2023 800 p E Clean Harbors MAD03932225 Safety Kleen KYD05334810 yes Systems, INC 8 Clean Harbors UTD9913017 Clean Harbors MAD03932225 Grassy 48 yes Mountain, LLC Clean Harbors UTD9913017 Clean Harbors MAD03932225 Grassy 48 yes Mountain, LLC Clean UTD9815521 Clean Harbors MAD03932225 Harbors 77 yes Argonite LLC Clean Harbors MAD03932225 Safety Kleen KYD05334810 yes Systems, INC 8 Clean Harbors Clean Harbors MAD03932225 Grassy UTD9913017 yes 48 Mountain, LLC 11/16/2023 H061 11/14/2023 H132 11/14/2023 H132 12/6/2023 H040 12/21/2023 H061 12/18/2023 H132 ZZE'DEd^t/d,>K>hd,KZ/d/^ EZ>ZWZ&KZZd ZZZZZ^>Z,Z>ZWZ >ZZZ ^ ^Z >ZZZ dZ,ZtZZ^ZhdZZ ZZZEZ>ZZZZZZ x dZZZ Z Z Z Z ZZZZ Z Z x ZZZZZ Z x ZZZZZZZZZ tZZZZZZZ ZZZZZ tZ ZZZZZZ ZZZZZZ Z /ZZZZZZZZZ ZZ ^ Z Z,^> WZD& ^>s^ ^>h  >ZZ  h/>/E' >ZZ  EZt t Z, >ZZ D Z W ZZ EZ ^EZZ ,Zd Z tWZ tW^Z Z D && ZZZ W Z EZZ ZZ t sZ Z ZZ ^W DZ Z & & td ZZZ ^Z Z ZZZ & ZZ  ZZZZZZZZZ d d, Z , ZZZZ, D, Z dZZZ dZ ZZZZZZZ ZZZZ dZZZ ZZ Z ZZZZ ZZZZ ZZZZ ZZZ ZZZ ZZ ZZZ DZZ ZZZZZ ZZZZZZ ZZZ ZZZZ/ ZZ ZZDZZZ ZZZ,, ^,,^,D D,DD ZZZZZZZZ ZZ ZZZ^ZZZZZ ZZZ ZZ Z DZZZZZ ZZZ ZZZZ ZZZ>sZ ZZZ ZZZZZd ZZZZ ZZZZ Maxwell, Annette From: Sent: To: Cc: Subject: Attachments: Daniel Renner <drenner@pioneermetal.com> Thursday, June 13, 2024 9:56 AM Maxwell, Annette; Jacobson, Linda; Judith Moran; Alexis Adams Dave Dettman; Chad Earl RE: Pioneer Metal Finishing EPA RCRA Inspection WI EAP-001_A Emergency Action Plan Update.pdf; Emergency Response Reference Guide Update.pdf Z dZZZWZZZZ ZZZ 'ZZDZ /ZZ/ZZZWZ' dZ Danny Renner Environmental Health & Safety Lead Direct: 801-214-7223 Cell: 417-207-0387 &ZZ ^t:WD dZ DDZZZZ:DZZZ Z ZZZZ ^WZD&WZZ/Z 'ZZZZ WZZZZZZtZZZZ ZZZZZZZ WZZZZZZ dZ Danny Renner Environmental Health & Safety Lead Pioneer Metal Finishing 1 1225 S Legacy View Street Salt Lake City, Utah 84104 Direct: 801-214-7223 Cell: 417-207-0387 Email: drenner@pioneermetal.com dZZ/ZZZZ ZZ/ZZZZZZZ ZZZ/ZZZ 2 Pioneer Metal Finishing Emergency Response Quick Reference Guide Document # Revision WI EAP-002 6/12/2024 &Emergency Z WZZZ ^ZZZZ ^ZZZZ ^ZZZZ ^ZZZZ Chad Earl Danny Renner Matt Federer John Twamley Jefferson Ngo PIONEER METAL FINISHING 1225 S. Legacy View Street Salt Lake City, Utah 84104 DZE801-550-4362 DZE 417-207-0387 DZE 724-258-7492 DZE 386-455-3162 DZE 801-230-1649 EZ&Z2s5 days/week with occasional Saturday work, however tZZZas Z ,Zt/ZZ EZt tZ, >ZZ D Z W ZZ EZ ^EZZ ,Zd Z tWZD & tW^ZZZZ Z & W Z EZZZZ tZZ sZ Z ^WD Z Z & & tdZZZ ^ZZZ ZZZ Z & * Contact Chemtrac for emergency medical treatment information at 1800-424-9300. If in eyes, wash eyes for several minutes. Page 1 of 7 Pioneer Metal Finishing Job Title / Environmental Responsibilities ENVIRONMENTAL MANAGER Primary HW emergency coordinator; sampling and characterizing wastes; hazardous waste handling and cleanup; prepare drums and shipping papers and manifests for shipment; ENVIRONMENTAL ENGINEER Alternate HW emergency coordinator; sampling and characterizing wastes; hazardous waste handling and cleanup; prepare drums and shipping papers and manifests for shipment; OPERATORS Hazardous Waste handling and cleanup; prepare hazardous waste for shipment; prepare shipping papers and manifests for shipment; recordkeeping. WATER TREATMENT OPERATORS Emergency Response ENVIRONMENTAL SPECIALIST Sampling and characterizing wastes; hazardous waste handling and cleanup; prepare drums for shipment; recordkeeping; training. ENVIRONMENTAL TECHNICIAN Prepare shipping papers and manifests for shipment; recordkeeping; training Emergency Response Quick Reference Guide Document # Revision General Awareness New Hire RCRA; Annual Onsite RCRA New Hire RCRA; Annual Onsite RCRA New Hire RCRA; Annual Onsite RCRA New Hire RCRA; Annual Onsite RCRA New Hire RCRA; Annual Onsite RCRA New Hire RCRA; Annual Onsite RCRA Job Specific RCRA Job Specific Other" Emergency Response Annual Training Full DOT Hazmat - Every 3 Years Annual Emergency Action Plan (EAP) Training Annual Training Full DOT Hazmat - Every 3 Years Annual Emergency Action Plan (EAP) Training Annual Training Annual Training Annual Training Annual Training Full DOT Hazmat - Every 3 Years Annual Emergency Action Plan (EAP) Training Full DOT Hazmat - Every 3 Years Full DOT Hazmat - Every 3 Years Full DOT Hazmat - Every 3 Years Annual Emergency Action Plan (EAP) Training Annual Emergency Action Plan (EAP) Training Annual Emergency Action Plan (EAP) Training Page 2 of 7 Employee Danny Renner Jefferson Ngo Chad Earl Dave Dettman Patrick McClure Matt Cowperthwaite Rawad Al-Khalidi Alex Larsen Leo Santiago Jefferson Ngo Alex Larsen Hung Nguyen Leo Santiago Danny Renner Jefferson Ngo Danny Renner Jefferson Ngo WI EAP-002 6/12/2024 Pioneer Metal Finishing Emergency Response Quick Reference Guide Document # Revision Street Map WI EAP-002 6/12/2024 Page 3 of 7 Pioneer Metal Finishing Emergency Equipment Locations (Bldg 1) Emergency Response Quick Reference Guide Document # Revision WI EAP-002 6/12/2024 Page 4 of 7 Pioneer Metal Finishing Emergency Equipment Locations (Bldg 2) Emergency Response Quick Reference Guide Document # Revision WI EAP-002 6/12/2024 Page 5 of 7 Pioneer Metal Finishing Evacutation Map (Bldg 1) Emergency Response Quick Reference Guide Document # Revision WI EAP-002 6/12/2024 Page 6 of 7 Pioneer Metal Finishing Evacutation Map (Bldg 2) Emergency Response Quick Reference Guide Document # Revision WI EAP-002 6/12/2024 Page 7 of 7 Revised: 02/21/2024 Emergency Action Plan Document # Revision WI EAP-001 B Scope: This emergency response plan applies to Pioneer Metal Finishing - Salt Lake Division and personnel. Purpose: The purpose of this document is to: Minimize and eliminate the risk of injury to employees and neighbors of Pioneer Metal Finishing in the case of an emergency, Prevent or minimize the effect of releases of environmentally hazardous materials from Pioneer Metal Finishing operations, Ensure compliance with Federal (OSHA and EPA) and Utah (DEQ) regulations related to emergency action plans and hazardous materials contingency plans, specifically: Federal Code 29 CFR 1910.38 Federal Code 40 CFR 265, Sub Part D Utah Administrative Code R315-7 Utah Administrative Code R315-9 Definitions: Incident: An occurrence of a chemical spill, a fire, an explosion, or other occurrence where action is required to protect humans and/or the environment. Emergency: Either a safety emergency or an environmental hazard emergency. A single incident can meet both definitions. Environmental hazard emergency: An incident within the facility that releases environmentally hazardous materials into the air, the soil, the sewer system, or the storm drains. Environmentally hazardous materials: Materials defined by the Environmental Protection Agency as "hazardous waste" under Federal Code 40 CFR 261. Safety emergency: An incident within the facility that places the safety of people at the facility or those outside the facility in imminent danger. This document serves both as the emergency response plan required by the Federal Safety Code (OSHA) and the contingency plan required by the Federal Environmental Protection Code (EPA) and Utah Administrative Code (DEQ). Emergency Coordinators Primary: Chad Earl Backup: Danny Renner Backup: Matt Federer Backup: John Twamley Backup: Jefferson Ngo Fire Response Initial response Remain at a safe distance from the fire. Evacuate the immediate area. Report the fire by calling the emergency coordinator. Include the estimated size of the fire in the report. Assess the risk. FIGHT THE FIRE USING AVAILABLE FIREFIGHTING EQUIPMENT ONLY IF: The fire is limited to a single material (it has not spread), and There are no flammable solvents involved, and The air appears safe to breathe (not overly hot or smoky), and The fire is no larger than a trash can (55 gallons), and There is safe access to appropriate fire-fighting equipment nearby, and You are trained on how to use the available fire-fighting equipment, and Page 1 of 15 Revised: 02/21/2024 Emergency Action Plan Document # Revision WI EAP-001 B There is a clear evacuation path, should the fire grow. DO NOT FIGHT THE FIRE IF THE ABOVE CONDITIONS ARE NOT MET! If the fire is not safe to fight, pull the nearest fire alarm and/or call 911 to summon firefighting support. Emergency Coordinator Based upon visual assessment of the situation and knowledge of the plant configuration and operations, confirm or overrule the initial responder's decision to fight or not fight the fire. Assess risk and determine if utilities should be shut off to the affected area. If so, shut them off. Take action, as necessary, to prevent the spread or reignition of the fire in the same or other areas. Evaluate risk and determine whether this constitutes an "Emergency". It is an "Emergency" if: The fire is uncontrolled, or The fire poses an imminent danger to humans, or The fire has involved environmentally hazardous materials and has not been contained, or The fire has involved environmentally hazardous materials and has resulted in a release of hazardous materials to the air, soil, sewer system, or storm drain. Note: Firefighting materials such as sprinkler water or fire hose water may wash environmentally hazardous materials into the sewer or storm drains. Note: Burnt materials and ash may be released from a fire that is contaminated with environmentally hazardous materials If it is an "Emergency": Determine if a larger-scale evacuation is needed. If so, direct appropriate evacuation by announcing over the paging system. Determine if outside agency support is required. If so, contact the appropriate outside agency. x For firefighting support, call 911. The Salt Lake City Fire Department has jurisdiction. o Upon arrival, the fire department assumes full control of the situation, and the Emergency Coordinator shall act as a resource to the fire department. x For life-threatening emergency medical assistance: call 911 x For non-life-threatening medical assistance between 8:00 a.m. and 5:00 p.m., contact Concentra Medical Center, 1735 South Redwood Road, Salt Lake City; phone 801-973-4434. x For non-life-threatening medical assistance between 7:00 p.m. and 10:00 p.m., contact First Med Industrial Clinic, 5911 South Fashion Place Blvd., Murray; phone 801-266-6483. x For non-life-threatening medical assistance between 10:00 p.m. and 7:00 a.m., contact St. Mark's Hospital, 1200 E 3900 S, Salt Lake City; phone 801-268-7111. x For environmentally hazardous material emergency containment and cleanup, contact Clean Harbors, phone 800-645-8265. x If police control is required, call 911. The Salt Lake City Police Department has jurisdiction. o Upon arrival, the police department assumes full control of the situation, and the Emergency Coordinator shall act as a resource to the police department. As a reminder, any injuries must be reported immediately to the employee's supervisor and Human Resources (via an injury report) within 24 hours. x Ensure that any safety equipment used (fire extinguishers, spill kit components, etc.) is restored to fully operational condition before restarting operations in the affected area. Page 2 of 15 Revised: 02/21/2024 Emergency Action Plan Document # Revision WI EAP-001 B Chemical spill (liquid or solid) response Initial response Remain at a safe distance from the spilled chemical. Evacuate immediate area Call the spill team member with the spill location, description of what is spilled, and the estimated quantity. Spill Team (Control, Contain, Clean up) Assess risk. Determine whether this constitutes an "Emergency" Factors to consider: In conjunction with another incident (such as a fire or earthquake)? Is the spilled chemical (type and quantity) imminently dangerous to humans? Is the spilled chemical an environmentally hazardous material? Has the source of the spill stopped or not? Is the spill contained or not contained? Is the spilled chemical flammable or not? Was the spill indoors or outdoors (consider effects of wind, sun, rain, snow, etc.) If there is a risk to personnel beyond the currently evacuated area, evacuate to the degree necessary to protect personnel. Immediately notify the emergency coordinator if the spill constitutes an Emergency. Do the following, to the degree that they can be done safely: Control (stop the source of) the spill. Contain spill. Clean up spill x Make appropriate use of MSDS's, PPE, and spill kits to safely clean up the spill. x Dispose of any spill clean-up materials that may contain hazardous waste per hazardous waste procedures and EPA/DEQ regulations. Contact the site environmental leader for specific guidance. Notify the emergency coordinator of a non-emergency spill within 24 hours (72 hours on a Friday, Saturday or Sunday) Post-clean-up activities x Restock spill kit and PPE. x Meet with the safety coordinator and emergency coordinator to create the report and evaluate the response, looking for improvement opportunities. Emergency coordinator Evaluate risk and determine whether this constitutes an "Emergency". It is an "Emergency" if: The spilled chemical (type and quantity) poses imminent danger to humans, or The spilled chemical is an environmentally hazardous material, and the source of the spill has not been shut off, or The spilled chemical is an environmentally hazardous material, and the spill has not been contained, or The spilled chemical is an environmentally hazardous material, and the spill has resulted in a release to the air, soil, sewer system, storm drain, or If it is an "Emergency": Based on the risks present, determine if a larger-scale evacuation is needed. If so, pull the fire alarm. Assess risk and determine if utilities should be shut off to the affected area. If so, shut them off. Take action, as necessary, to prevent the spread or reignition of the spill to other hazardous materials. Determine if outside agency support is required. If so, contact the appropriate outside agency. x For firefighting support, call 911. The Salt Lake City Fire Department has jurisdiction. o Upon arrival, the fire department assumes full control of the situation, and the Emergency Coordinator shall act as a resource to the fire department. x For life-threatening emergency medical assistance: call 911 Page 3 of 15 Revised: 02/21/2024 Emergency Action Plan Document # Revision WI EAP-001 B x For non-life-threatening medical assistance between 8:00 a.m. and 5:00 p.m., contact Concentra Medical Center, 1735 South Redwood Road, Salt Lake City; phone 801-973-4434. x For non-life-threatening medical assistance between 7:00 p.m. and 10:00 p.m., contact First Med Industrial Clinic, 5911 South Fashion Place Blvd., Murray; phone 801-266-6483. x For non-life-threatening medical assistance between 10:00 p.m. and 7:00 a.m., contact St. Mark's Hospital, 1200 E 3900 S, Salt Lake City; phone 801-268-7111. x For environmentally hazardous material emergency containment and cleanup, contact Clean Harbors, phone 800-645-8265. x For environmentally hazardous material emergency containment and cleanup, contact Clean Harbors, phone 800-645-8265. x If police control is required, call 911. The Salt Lake City Police Department has jurisdiction. o Upon arrival, the police department assumes full control of the situation, and the Emergency Coordinator shall act as a resource to the police department. As a reminder, any injuries must be reported immediately to the employee's supervisor and to Human Resources (via an injury report) within 24 hours. If there has been: A release of more than 1 kilogram (2.2 pounds) of an acute hazardous waste, or A release of more than 100 kilograms (220 pounds) of non-acute hazardous waste, or A release, fire, or explosion that could threaten human life or the environment outside the facility: Immediately notify the Utah DEQ business hours phone line at 801-536-0200, or the 24-hour hotline at 1-801-536-4123, with the following information: 1. Name, phone number, and address of the person responsible for the spill, 2. Name, title, and phone number of the person reporting the release, 3. Time and date of the spill, 4. Location of the spill, being as specific as possible including the nearest town, city, highway, or waterway, 5. Description contained on the manifest (or container label) and the amount of material spilled, 6. The cause of the spill, and 7. What emergency action has been taken to minimize the threat to human health and the environment. Supervise the spill containment and clean up. x Ensure that the spill team makes appropriate use of MSDS's, PPE, and spill kits to safely clean up the spill. x Dispose of any spill clean-up materials that may contain hazardous waste per hazardous waste procedures and EPA/DEQ regulations. Contact the site environmental leader for specific guidance. x Ensure that any safety equipment used (fire extinguishers, spill kit components, etc.) is restored to fully operational condition before resuming operations in the affected area. Characterize and quantify, to the degree possible, any hazardous material release. x If there has been any release of environmentally hazardous material, notify the following, to notify them that all emergency equipment has returned to fully operational condition before resuming operations in the affected area.: o the Salt Lake City Police Department (if they have responded), o the Salt Lake City Fire Department (if they have responded), and o the Director of Utah DEQ, x If there has been a hazardous material release, ensure that no waste incompatible with the released material is treated, stored, or disposed of until the cleanup is complete. Page 4 of 15 Revised: 02/21/2024 Emergency Action Plan Document # Revision WI EAP-001 B x If the incident was deemed to be an "Emergency", complete an internal incident report, including the date and time of the incident and any pertinent details. x If there has been a release of any environmentally hazardous waste, file a written report to the Director of the Utah Department of Environmental Quality within 15 calendar days of the incident. The report shall include: o Name/address/phone# of owner/operator, o Name/address/phone# of facility, o Date, time, and type of incident, o Name and quantity of material involved, o Extent of any injuries, o An assessment of the actual or potential hazard to human health or the environment, and o An estimate of the quantity and disposition of recovered material that resulted from the incident Earthquake response The applicable sections of the fire and chemical spill response sections shall be used in response to an earthquake. Evacuation procedure When notified by the emergency coordinator (either in person or over the paging system), or when the fire alarm is sounded, all employees shall evacuate the buildings using the indicated emergency exit paths, and proceed to their assigned assembly area. Employees shall notify and assist others, particularly contractors, vendors and other visitors, as they evacuate. When the receptionist evacuates, they shall bring the Visitor's Log with them to the assembly area. If the receptionist is not at their desk, other evacuating office staff shall bring it to the assembly area. When supervisors and managers evacuate, they shall bring their employee lists with them, if it is safe to do so. Supervisors and managers should be the last to leave the area, ensuring that, to the best of their ability, all employees are out of the area. Supervisors and managers shall close the doors behind them as they evacuate, to help limit the spread of a fire or other emergency. Supervisors and managers shall determine if their assigned employees are all present at the assembly area and if not, to report the missing employee(s) names and last observed location to the Emergency Coordinator. The Emergency Coordinator shall ensure (either by themselves or by assignment) that those on the Visitor's Log who are listed as still on-site are accounted for. The Emergency Coordinator shall compile a list of any persons (employees and/or visitors) who are unaccounted for, and either take appropriate action to resolve the list (perhaps they are not on site) or find those listed as missing. If the police or fire departments arrive on site, the Emergency Coordinator shall provide them with information on who is missing and where they were last seen. When the situation is deemed safe for re-entry, the Emergency Coordinator (or police or fire departments, if they are on-scene), shall notify employee that the situation is "all clear". The Emergency Coordinator (or police or fire departments, if they are on-scene) is the only one who can give permission to reenter evacuated buildings. This permission may be given on an individual building-by-building basis. Page 5 of 15 Revised: 02/21/2024 Emergency Action Plan Document # Revision WI EAP-001 B Employees are not to return to the buildings until the Emergency Coordinator informs them that the areas are "all clear". Alarm systems There are multiple alarm systems in place at Pioneer Metal Finishing. In this document, all references are to the fire alarm system, The alarm systems include: Fire alarm system Externally monitored by the external security company (Peak Alarm) and the Salt Lake City Fire Department. This alarm system has a beeping horn sound and requires an emergency response as outlined below under "fire response". Upon alarm (unless notified to ignore in advance), the external security company will notify the following, in order, for a response: Maintenance Electrician Maintenance Manager General Manager Maintenance Coordinator IT Manager Once a responder is reached, the responder is responsible to arrive on-site to manager the emergency if needed, and to notify the correct Pioneer personnel for additional response to the emergency. Security alarm system Externally monitored by the external security company (Peak Alarm), who will respond to investigate upon alarm. This alarm has a continuous, oscillating sound, somewhat like an emergency vehicle, and does not require an emergency response. Boiler temperature alarm Locally monitored by tankline and maintenance personnel . This alarm has a continuous sound, similar to a car alarm, and does not require an emergency response. Evacuate the immediate area. Page 6 of 15 Revised: 02/21/2024 Emergency Equipment Locations (Bldg 1) Emergency Action Plan Document # Revision WI EAP-001 B Page 7 of 15 Revised: 02/21/2024 Emergency Equipment Locations (Bldg 2) Emergency Action Plan Document # Revision WI EAP-001 B Page 8 of 15 Evacuation Map (Bldg 1) Revised: 02/21/2024 Emergency Action Plan Document # Revision WI EAP-001 B Page 9 of 15 Evacuation Map (Bldg 2) Revised: 02/21/2024 Emergency Action Plan Document # Revision WI EAP-001 B Page 10 of 15 Revised: 02/21/2024 Contents of Spill Kit #1 Bldg. 1 - WCWest CNT SIZE SPILL KIT ITEMS 1 Hydiron Test Strips Pkg 1 Silver Shield Booties 2 L Blue Protective Suit 1 XL Blue Protective Suit 2 Blue Booties 2 Green Gloves 3 White Plastic Suit w/Feet 1 Duct Tape 4 Purple/Pink Absorbent PIG Pads 8 40" Gray Socks 2 10' Pink PIG Snake (sock) 3 4' Pink PIG Snake (sock') 25 Absorbent Rags 1 White Oil Sock 12 QT Oil Sand Absorbent 2 Safety Goggles/Glasses 4 Garbage Bags for Hazardous Waste 1 Caution Tape Emergency Action Plan Document # Revision WI EAP-001 B Contents of Spill Kit #3 Bldg. 1 - ChemTreat by Roll Up Door CNT SIZE PLASTIC BOTTLE TAPED TO UNDERSIDE OF LID 1 Hydiron Test Strips 2 Silver Shield Booties 1 LG Silver Shield Gloves 2 10 Green Gloves 1 Blue Protective Suit w/Feet 1 XL Blue Protective Suit 1 LXL Blue Protective Suit 1 Moldex 8002 Face Mask w/8300 Cartrg. 2 Goggles/Safety Glasses 1 Caution Tape 1 Duct Tape 2 Purple/Pink Absorbent PIG Pads 3 4' Pink PIG Snake (Sock) 25 Absorbent Rags 3 Plastic Tarps 4 Garbage Bags for Hazardous Waste NEAR BY: 2-5 gal. buckets. of Floor Dry. 1-5 gal. bucket of Citric Acid Spill Kit, 1-Shower Kit:(2 towels, Shower Gel, Flipflops, Accident Report & Pen) Page 11 of 15 Revised: 02/21/2024 Contents of Spill Kit #4 Bldg. 2 - Heat Treat CNT SIZE SPILL KIT ITEMS 1 Hydiron Test Strips 1 XL Blue Protection Suit 2 White Plastic Suits w/Feet 2 Safety Goggles/Glasses 2 10 Green Gloves 2 Pink Absorbent PIG Pads 3 10' Pink PIG Snake (Sock) 1 3' Pink PIG Snake (Sock) 1 Neuralizing Absorbent Pillow 3 10' Pink PIG Snake (Sock) 1 3' Pink PIG Snake (Sock) 6 Absorbent Rags 3 Garbage Bags for Hazardous Waste 1 Duct Tape 1 Plastic Tarp Near By: 2-5 gal. bkts. Of Floor Dry Emergency Action Plan Document # Revision WI EAP-001 B Contents of Spill Kit #5 Bldg. 2 - Tank Line NE near Filter Press CNT SIZE PLASTIC BOTTLE TAPED TO UNDERSIDE OF LID 1 Acid Neutralizing Instruction Booklet 1 Hydiron Test Strips 3 LXL Dupont Tyvek Suits 1 LXL PIG WP908 LXL Blue Poncho 2 Safety Goggles/Glasses 1 10 Green Gloves 3 PIB Acid Neutralizing Absorbent Pillow 1 PIB Base Neutralizing Absorbent Pillow 2 Other Absorbent Pillows 7 PIG Pink Mats 2 10' Pink PIG Snake (Sock) 4 4' Pink PIG Snake (Sock) 25 Absorbent Rags 1 Duct Tape 1 Caution Tape 5 Garbage Bags for Hazardous Waste NEAR BY: 1-Shower Kit, 1-5 gal. Floor Dry, 1-5 gal. Citric Acid Page 12 of 15 Revised: 02/21/2024 Emergency Action Plan Document # Revision WI EAP-001 B Contents of Spill Kit #6 Contents of Spill Kit #7 Bldg. 2 - Anodize NW by RO WATER TANKS Bldg. 2 - WCE - Between Paint Booths CNT SIZE SPILL KIT ITEMS CNT SIZE PLASTIC BOTTLE TAPED TO UNDERSIDE OF LID 1 Hydiron Test Strips 1 Hydiron Test Strips 2 Silver Shield 2 Silver Shields 1 XXL Blue Protective Suit 1 LXL Blue Protective Suit 3 10 Green Gloves 1 Blue Poncho 1 Slightly Used Tyvek Suit 2 10 Green Gloves 1 Duct Tape 2 Goggles/Safety Glasses 1.5 Purple/Pink Absorbent PIG Pads 3 4' Pink PIG Snake (Sock) 2 10' Pink PIG Snake (Sock) 2 11' Pink PIG Snake (Sock) 4 4' Pink PIG Snake (Sock) 10 Absorbent Rags 1 Acid Pillow 3 Water proof White Suits 1 Base Pillow 1 Caution Tape 25 Absorbent Rags 1 Duct Tape 1 roll Garbage Bags for Hazardous Waste 1 Garbage Bags for Hazardous Waste 1 Duct Tape 1 Caution Tape NEAR BY: 1-5 gal. Soda Ash, 1-Shower Kit NEAR BY: 1-5 gal. Floor Dry, 1-Shower Kit Page 13 of 15 Revised: 02/21/2024 Contents of Spill Kit #8 Bldg. 3 - Anodize Near NE by Tank Line CNT SIZE SPILL KIT ITEMS 1 Hydrion Test Strips 1 XL Plastic Tychem Suit 2 LG Silver Shield Gloves 2 LXL Blue Protective Suit 2 LG Silver Shield Gloves 2 10 Green Gloves 2 Rubber Apron 2 Safety Goggles/Glasses Purple/Pink Absorbent PIG Pads Pink PIG Snake (Sock) Pink PIG Snake (Sock) 25 Absorbent Rags 1 Garbage Bags for Hazardous Waste 1 Duct Tape 1 Safety Slip Bath Mat 1 Caution Tape Emergency Action Plan Document # Revision WI EAP-001 B Contents of Spill Kit #9 & #10 Located at North and South Fire Hydrants CNT SIZE PLASTIC BOTTLE TAPED TO UNDERSIDE OF LID 3 Bags Absorbent Page 14 of 15 Revised: 02/21/2024 Emergency Action Plan Document # Revision Spill Kit Replacement Form REPORT WHAT YOU USE TO THE SAFETY OFFICE CNT SIZE SPILL KIT ITEMS Hydiron Test Strips Silver Shield Booties Blue LXL Plastic Suit (WP:908) Blue Booties Green Gloves White Plastic Suits w/Feet Duct Tape Purple/Pink Absorbent PIG Pads Gray Socks Pink PIG Snake (Sock) Pink PIG Snake (Sock) Absorbent Rags White Oil Sock Oil Sand Absorbent WI EAP-001 B Page 15 of 15 Maxwell, Annette From: Sent: To: Cc: Subject: Attachments: Daniel Renner <drenner@pioneermetal.com> Thursday, June 13, 2024 4:54 PM Maxwell, Annette; Jacobson, Linda; Judith Moran; Alexis Adams Dave Dettman; Chad Earl RE: Pioneer Metal Finishing EPA RCRA Inspection IMG_1300.jpeg Z dZZZWZZZZ ZZZ 'ZZZZ dZZZZ W dZ Danny Renner Environmental Health & Safety Lead Direct: 801-214-7223 Cell: 417-207-0387 &ZZ ^d:D dZDDZZZZZZZ: DZZZZ ZZZZ ^ZWZD&WZZ/Z 'ZZDZ /ZZ/ZZZWZ' dZ Danny Renner Environmental Health & Safety Lead Direct: 801-214-7223 Cell: 417-207-0387 1 &ZZ ^t:WD dZDDZZZZ:DZZZ Z ZZZZ ^WZD&WZZ/Z 'ZZZZ WZZZZZZtZZZZ ZZZZZZZ WZZZZZZ dZ Danny Renner Environmental Health & Safety Lead Pioneer Metal Finishing 1225 S Legacy View Street Salt Lake City, Utah 84104 Direct: 801-214-7223 Cell: 417-207-0387 Email: drenner@pioneermetal.com dZZ/ZZZZ ZZ/ZZZZZZZ ZZZ/ZZZ 2  s, IncLlll Tel: 206.979.5633 L.C. Lee & Associates, Inc. 421 North Forest Street Bellingham, Washington 98225 Tel: 206.979.5633 Email: [lyndon@lcleeinc.com] Technical Memorandum October 22, 2024 ______________________________________________________________________________ To: Peggy Livingston - EPA Region 8 Rebecca Little Owl - EPA Region 8 Samuel Stratton - DOJ/ENRD From: Lyndon C. Lee, Ph.D., SPWS L.C. Lee & Associates, Inc. CC: LCLA/cf Ref: Bunn Restoration Site - L.C. Lee August 6, 2024 Site Visit/Inspection Summary ______________________________________________________________________________ This Technical Memorandum has been developed to summarize an August 6, 2024 field visit/site inspection by Lyndon C. Lee at the Bunn Property Ecosystem Restoration on the Yaak River, Montana. I. Date of Field Visit/Site Inspection: August 6, 2024 2. Site Location: Bunn Property, at Latitude 48.824392 North/Longitude -115.829935 West 3. Participants: a. Catherine Weichman, Watershed Consulting (Botanist/Plant Ecologist) b. Tim Lindsey (Geologist/Project Manager) d. Douglas Allen (Attorney) e. Lyndon C. Lee (L.C. Lee & Associates - Expert for DOJ/EPA) 4. Time of Visit: 12: 00 Noon to 3 PM. 5. Weather Conditions: Clear, Warm, and Sunny 6. Antecedent Precipitation Conditions: Drier Then Normal, Moderate Drought (Figure 1). 7. Overall Conclusion: As of August 6, 2024, the Bunn Restoration Site is in good condition. It needs continued maintenance for weed controls and required compliance monitoring to ensure interim progress towards all Project Targets and final achievement of the overall Project Goals are at year five (5) following establishment of baseline (Time Zero) conditions. (Figure 2). 8. Monitoring Grading for this project was essentially complete in the fall of 2021. Apparently, some plantings also took place in the fall of 2021. These were augmented sometime in 2022. Survey of the asbuilt grades for the site were completed in 2023, along with Ms. Weichman's first vegetation monitoring report. Throughout this interval, no single and systematic report was offered to declare "Baseline/Time Zero" conditions for the site and thus formally end construction and start monitoring. During the site visit, Lee spent considerable time emphasizing this point and requested that Ms. Weichman and Mr. Lindsey work together to backtrack using their notes and observations and reconstruct Baseline/Time Zero conditions and document such in a Baseline/Time Zero Report. Lee emphasized that the Baseline/Time Zero Report needs to be developed or structured in a way that addresses Hydrologic, Biogeochemical, Plant Community, and Faunal Support/Habitat Project Targets at Baseline/Time Zero. Please see Appendix A in this Technical Memorandum for an example outline. This documentation will form the basis for showing progress towards (or away from) Project Targets in subsequent monitoring years. It will also help to signal any needs for adaptive management or contingency measures that are necessary to keep the project on track (see Appendix B Example Matrix). 9. Grading (Figure 3) - a. Overall, the grading of the site achieved by July, 2023 met the objectives for the site. b. As always when working wet ground, some anomalies exist between what was put forth as the grading plan in the Basis of Design for the project and the achieved grades. This is particularly true in the northwest corner of the site, where it appears that grading operations were unable to completely remove what is/was generally known as "Stockpile 1", which consisted of a combination of mineral and organic soils mixed with vegetation strippings. It appears that a significant amount of the former Stockpile 1 was spread around the northwest corner of the site. It is essentially inaccessible now and the area requires observation for emergence of weeds from the former stockpile materials and as necessary, aggressive weed controls. c. Surface Water Connections to the Yaak River Main Channel system were correctly graded and are intact and functioning. Some evidence of beaver activity on the site and within the excavated connection channels was noted, but is certainly to be expected throughout the life of the project. 10. Plantings a. Baseline/Time Zero Plantings - The contractors lost control of tallies (number, species, and location) of plantings on the restoration site, making development of baseline/Time Zero conditions difficult. To this end, Lee requested that Ms. Weichman work with Mr. Lindsey to try and reconstruct what species were planted, where they were planted, and how many were planted as of declaration of Baseline/Time Zero conditions. These results should be presented in the form of plant take off tables that document plantings by logical zones within the restoration area. Usually, such tables list species down the left side of a matrix, and number planted (density), on-center or triangular spacing, stock (e.g. container, bare root, live cuttings, etc.), and planting microsites/notes (Please see Appendix C for an example). LCLA Technical Memorandum - Bunn Restoration Site, Yaak River Montana, October 22, 2024 L.C. Lee Field Visit 2 b. Weeds - The major weed species on the site is reed canary grass (Phalaris arundinaceae). This non-native weed is highly invasive and is well established in massed clones or "invasion fronts" throughout the restoration site. Lee emphasized the need for continued weed control efforts and adaptive management strategies that will give native plantings a chance to become well established and dominant on the site. 11. Monitoring Interval a. Considerable discussion was focused on ending the compliance monitoring interval because it was Mr. Lindsey's opinion that the Bunn Restoration Site was doing well. Lee pointed out the glitches in establishment of Baseline/Time Zero conditions and the lack of a comprehensive Baseline/Time Zero report and subsequent reports keyed to Baseline/Time Zero conditions. Further, Lee emphasized the need in monitoring years subsequent to baseline/Time Zero, to address progress towards or away from Project Targets, and identification of any adaptive management or contingency measures that may be necessary to ensure that the Bunn Restoration project achieves the overall project objectives. Lee finished by saying it was ultimately up to EPA Region 8 to determine if and when monitoring should be continued or truncated. b. Consent Decree provisions for continued stewardship - Misters Lindsey and Allen requested that in light of Mr. Bunn's passing and the likelihood that Mr. Bunn's son will convey the property, that provisions for continued stewardship of the Bunn Restoration Site articulated in the Consent Decree be waived or terminated. Lee noted this request but deferred any decisions to EPA Region 8. 12. Next Steps/Recommendations a. Develop (retroactively) a systematically structured Baseline/Time Zero Report b. Adjust or amend all following monitoring reports to the Baseline/Time Zero Report and document success (or failures) towards achieving the Project Targets and overall project goals accordingly. c. Submit 2024 reports as required. d. Continue weed controls, especially targeting reed canary grass. e. Negotiate with EPA Region 8 regarding the monitoring timelines and the request for waiver of stewardship provisions of the Consent Decree. f. Schedule another EPA/DOJ site visit/inspection in the interval July - August of 2025. LCLA Technical Memorandum - Bunn Restoration Site, Yaak River Montana, October 22, 2024 L.C. Lee Field Visit 3 Figure 1. Antecedent Precipitation Tool Results for August, 6, 2024, Bunn Property, Yaak River, Montana LCLA Technical Memorandum - Bunn Restoration Site, Yaak River Montana, October 22, 2024 L.C. Lee Field Visit 4 Figure 2. Bunn Restoration Site Conditions as of September 14, 2023 LCLA Technical Memorandum - Bunn Restoration Site, Yaak River Montana, October 22, 2024 L.C. Lee Field Visit 5 Figure 3. Bunn Restoration Site As-Built Grading as of July 31, 2023 LCLA Technical Memorandum - Bunn Restoration Site, Yaak River Montana, October 22, 2024 L.C. Lee Field Visit 6