Document 2RE3mqe6xbr9KkLXej63X76zp

EPA Region 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 12/13/2022 08:00 AM (ET) Announced: No 12/13/2022 02:05 PM (ET) Access: Granted Cloudy Water Clean Water Act, National Pollutant Discharge Elimination System (NPDES), Industrial CEI - Compliance Evaluation Inspection Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Eramet Marietta Metallurgical Plant Eramet Marietta Metallurgical Plant 16705 Rt 7 South, Riverview Marietta, Ohio 45750 Washington County 39.372906, -81.523579 FRS ID 110000741966 Permit Number(s) (If Applicable) OH0004006 SIC and/or NAICS 3313 Regulatory Representatives Participating in Inspection: Title Name Inspector Jake Berger Inspector William Jones Organization EPA Region 5 EPA Region 5 Lead Inspector: Jake Berger Supervisor Review: Molly Smith Digitally signed by Berger, Berger, Jake Jake Date: 2022.12.29 14:20:28 -06'00' EPA Region 5 Berger.Jake@epa.gov (312) 353-8024 EPA Region 5 Smith.Molly@epa.gov 1 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 SECTION I - INTRODUCTION Site Entry and Inspection Objectives EPA Region 5 Lead Inspector, Jake Berger, arrived at the Eramet Marietta Metallurgical Plant (the "Site" or "Facility"), located at 16705 Rt 7 South, Riverview, Marietta, Ohio 45750, at 08:00 AM (ET) on 12/13/2022 for an unannounced inspection. EPA Region 5 Lead Inspector presented credentials to Mark Carpenter and informed the Facility that this was an EPA Region 5 inspection to determine compliance as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. This report is based on information supplied by Eramet Marietta Metallurgical Plant representatives, direct observations made by the EPA Region 5 inspector, records and reports maintained by the permittee and other information including: photographs taken by EPA Region 5 inspector(s), physical evidence collected by the EPA Region 5 inspector(s), measurements taken by EPA Region 5 inspector(s), verbal or written statements made by information supplied by Eramet Marietta Metallurgical Plant representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 5 inspector(s) by Eramet Marietta Metallurgical Plant representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization EPA Region 5 EPA Region 5 Eramet Marietta Attendee Name Jake Berger William Jones Mark Carpenter Title Lead Inspector Inspector Environmental Engineer Present in Opening Conf. Yes Yes Yes Present in Closing Conf. Yes Yes Yes Facility/Site Description EPA Region 5 lead inspector confirmed the following facility information: Eramet is a facility that performs smelting of high carbon ferromanganese to low and medium carbon ferromanganese to be used as an alloy in steel production. Eramet is authorized to discharge pollutants in accordance with their NPDES permit # 0ID00001*GD issued by the Ohio Environmental Protection Agency with Application # OH0004006. The Facility is located at 16705 State Route 7 South, Marietta, Washington County, Ohio in a heavy industrial area located along the Ohio River. The Facility was initially constructed in the early 1950s by the Union Carbide Corporation (UCC) as part of a larger UCC-owned facility for the manufacturing of ferroalloys and polystyrenes. The operations were sold to Elkem Metals in 1981 and thereafter to Eramet Marietta, Inc. (EMI) in 1999. EMI currently operates a metallurgical manufacturing facility that manufactures manganese alloys such as silicomanganese, ferromanganese and other manganese products. The EMI Main Facility is located in the central portion of the property and includes the core of EMI's operations, encompassing 21.3 acres of the Site. The Facility and outbuildings total 525,644 gross square feet. The Facility is surrounded by other commercial and industrial facilities to the east and west. The northern portion of the property consists of 734.54 acres, containing mostly undeveloped land and a 92-acre wastewater/sludge impoundment, hereafter referred to as the North Impoundment. The southern portion of the Facility's property (south of Route 7), which is adjacent to the Ohio River, includes the EMI wastewater treatment plant (WWTP), a former sludge storage pond, three operating sludge storage ponds, Mid-Ohio Valley Lime Company, and a closed fly ash landfill. 2 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 According to the United States Geological Survey (USGS) Fleming/Parkersburg/Marietta/Valley Mills Quadrangle Topographic Map, the nearest body of surface water to the Facility is the Ohio River adjacent to the Facility to the south. On-site catch basins direct storm water to the Ohio River via six (6) NPDES-permitted outfalls. All direct contact storm water runoff at the Main Facility enters the on-Property storm sewer system and discharges to the Ohio River through Outfall 003. Eramet and Energizer renewed their agreement in 2001 to have Eramet receive Energizer's wastestreams. Energizer is an electrolytic manganese manufacturer that has a wastestream that discharges to Eramet's UNOX (Union Carbide Oxidation Process). UNOX is a legacy treatment system that contains a lime silo for treating the wastestream from Energizer containing acidity and manganese. Energizer's principal waste stream is manganese rich and acidic. The goal of these wastestreams is for Energizer to reuse them. If their recycling tank is too full, they discharge to UNOX. The wastestream is treated by adjusting the pH 10.5 or higher to create a manganese hydroxide and clarifies in the north impoundment, through Outfall 605, and exits through Outfall 003 into the Ohio River. Eramet can reject Energizer's wastestream if it causes Eramet to be unable to treat the wastestream. The Eramet onsite sanitary treatment facility is run by operator of record Steve Elliot, City of Marietta chief operator, Class 1. Eramet has had no sludge disposal since 2019. In April 2022, Eramet started to dose the influent with higher amounts of lime, effectively maintaining the pH of the treatment process above 10.5 to facilitate the precipitation of manganese hydroxides. Eramet is confident that the improvements at the UNOX system make Eramet capable of handling the manganese and acidity received from Energizer. Facility/Site Information Have there been or are there plans to make changes in the process(es) that will cause a new, different, or increased discharge? Plans to decrease total water usage by changing from open loop to closed loop cooling system. Do you use in-house or contract out for laboratory analyses? Or both? In-house for most analyses. Contract out testing for phenols, cyanide, lead, cadmium, barium, fecal, BOD, and sludge analysis to Microbac. Do you self-monitor Yes and keep monitoring records? Outfalls (and do the 6 numbers and locations match the permit?) Size of Facility 1,084 acres What are the raw materials used? Coal, coke, manganese ore, carbon electrode paste Type of Operation Smelting What is the principal Ferromanganese and silica manganesae 3 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 product generated? Responsible official verified Marc Mounier-vehier Industrial Sector/Sub- 3313 sector Locations Location/Area/Sub-area Outfall 003 Outfall 007 Outfall 008 Outfall 602 Outfall 603 Outfall 605 Sample point 589 Sanitary treatment facility Settling Ponds UNOX wastewater treatment system Wastewater solids north impoundment Description Combined discharge of storm water, noncontact cooling, treated process and sanitary wastewaters (outfalls 602, 603, and 605) to Ohio River. (Lat: 39 21' 51"; Long: -81 31' 12") Discharge from Elkem fly ash disposal area surface runoff to Ohio River. No monitoring required. (Lat: 39 21' 58"; Long: -81 30' 48") Discharge from Elkem fly ash disposal area leachate treatment system prior to mixing with AMP Ohio's bottom ash pond discharge via drainage way to the Ohio River. (Lat: 39 21' 51"; Long: -81 30' 55") Discharge from sewage treatment plant after disinfection and prior to combining with outfall 0ID00001003. (Lat: 39 21' 52"; Long: 81 31' 12") Discharge from process sludge settling ponds prior to combining with other wastewaters tributary to outfall 0ID00001003; samples to be taken from Manhole #492. (Lat: 39 21' 55"; Long: -81 31' 28") Discharge from sludge storage impoundment prior to combining with other wastewaters tributary to outfall 0ID00001003; samples to be taken at Manhole #497. (Lat: 39 22' 26"; Long: -81 31' 22") Sludge removed from the sanitary waste water treatment plant for final disposal. Clarification of scrubber wastewater. Union Carbide Oxidation Process, location of lime addition. SECTION II - OBSERVATIONS Location: Settling Ponds Observation #: JB4-OB-001 Date: 12/13/2022 Weather: Addition of ferrosulfate in setting pond recirculation to induce a reduction reaction of chrome 6 to chrome 3. Sampling occurs here at location 008. Photo(s) 1. IMG-20221213110656656208986.jpg Location: Outfall 003 4 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 Observation #: JB4-OB-002 Date: 12/13/2022 Weather: Sampling location for Outfall 003, including monitoring for chlorine and pH. Flow rate at 003 is calculated as the sum of GRD (Good River Distribution) intake for Eramet + flow at 605 + flow at 602 + flow at 603. Photo(s) 1. IMG-202212131124142414209316.jpg Location: Outfall 602 Observation #: JB4-OB-003 Date: 12/13/2022 Weather: Sampling location for 605, acting as a clarifier, which then flows to 003. Photo(s) 1. IMG-202212131132143214199766.jpg Location: Outfall 603 Observation #: JB4-OB-004 Date: 12/13/2022 Outfall 603, containing scrubber recycle water. Photo(s) 1. IMG-202212131143534353288116.jpg Weather: Location: UNOX wastewater treatment system Observation #: JB4-OB-005 Date: 12/13/2022 UNOX treatment system Photo(s) 1. IMG-202212131154125412559719.jpg Weather: Location: Outfall 605 Observation #: JB4-OB-006 Date: 12/13/2022 Outfall 605, flow monitoring and composite sampling Photo(s) 1. IMG-20221213120353353677965.jpg Weather: Location: Wastewater solids north impoundment Observation #: JB4-OB-007 Date: 12/13/2022 Final resting place for manganese hydroxide. Weather: 5 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 Photo(s) 1. IMG-20221213121209129179269.jpg ERAMET MARIETTA METALLURGICAL PLANT Observation #: JB4-OB-008 Date: 12/13/2022 Diesel refueling tank with containment Photo(s) 1. IMG-202212131227292729591548.jpg Weather: SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: Compliance Monitoring & Enforcement Report Ref #: JB4-RR-007 Reviewed By: Jake Berger AOC: Yes Reviewed Date: 12/13/2022 No records of completed Routine Facility Stormwater Inspections. Record: Personnel Training Ref #: JB4-RR-006 Reviewed By: Jake Berger AOC: No Reviewed Date: 12/13/2022 Reviewed SPCC (Spill Prevention Control and Countermeasure) and SWPPP (Storm Water Pollution Prevention Plan) annual employee trainings to satisfy NPDES permit requirements. Record: Compliance Monitoring & Enforcement Report Ref #: JB4-RR-005 Reviewed By: Jake Berger AOC: Yes Reviewed Date: 12/13/2022 No records for any Stormwater Annual Reports since the NPDES permit became effective in 2019. Record: Other - Quarterly Visual Stormwater Assessment Ref #: JB4-RR-004 Reviewed By: Jake Berger AOC: No Reviewed Date: 12/13/2022 Reviewed Quarterly Visual Stormwater Assessments to satisfy NPDES permit requirements. Record: Process Description/Flow Diagram Ref #: JB4-RR-003 Reviewed By: Jake Berger AOC: No Reviewed Date: 12/13/2022 Line Diagram: General sanitary wastewater flow Photo(s) 1. IMG-20221213095800580103364.jpg Record: Process Description/Flow Diagram Ref #: JB4-RR-002 Reviewed By: Jake Berger AOC: No Reviewed Date: 12/13/2022 6 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 Line Diagram: cooling water flow Photo(s) 1. IMG-20221213095642564294117.jpg Record: Process Description/Flow Diagram Ref #: JB4-RR-001 Reviewed By: Jake Berger Industrial process wastewater flows Photo(s) 1. IMG-2022121309520452490124.jpg SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. AOC: No Reviewed Date: 12/13/2022 SECTION V - AREAS OF CONCERN Areas of Concern may not be in sequential order. The presentation of areas of concern does not constitute a formal compliance determination or violation. AOC Reference #: JB4-RR-005 Records Review: Compliance Monitoring & Enforcement Report Regulation and/or Permit Requirement NPDES Permit OH0004006, OH0004006-V,A,2 OH0004006-V,A,2 - Annual Report. You shall complete an annual report using the Annual Reporting Form provided by Ohio EPA at the following location: http://www.epa.ohio.gov/portals/35/permits/OHR000006/ARForm.docx You are not required to submit your annual report to Ohio EPA unless specifically requested. The timeframe to complete the report is at the discretion of the permittee but the same schedule to complete shall be maintained throughout this permit term. You shall keep the completed annual reports with your SWPPP. AOC: Eramet has not completed any Stormwater Annual Reports since the NPDES permit became effective in 2019. AOC Reference #: JB4-RR-007 Records Review: Compliance Monitoring & Enforcement Report Regulation and/or Permit Requirement NPDES Permit: OH0004006 OH0004006-IV,E,1,a OH0004006 OH0004006-IV,E,1 OH0004006 OH0004006-IV,K,3 7 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 OH0004006-IV,E,1 - Routine Facility Inspections OH0004006-IV,E,1,a - Conduct routine facility inspections of all areas of the facility where industrial materials or activities are exposed to storm water, and of all storm water control measures used to comply with Part IV. Items A-C conditions contained in this permit. Routine facility inspections shall be conducted at least quarterly (i.e., once each calendar quarter) although in many instances, more frequent inspection (e.g., monthly) may be appropriate for some types of equipment, processes, and control measures or areas of the facility with significant activities and materials exposed to storm water. Perform these inspections during periods when the facility is in operation. You shall specify the relevant inspection schedules in your SWPPP document as required in Part IV. Items A-C. These routine inspections shall be performed by qualified personnel (for definition see VI Definitions) with at least one member of your storm water pollution prevention team participating. At least once each calendar year, the routine facility inspection shall be conducted during a period when a storm water discharge is occurring. OH0004006-IV,K,3 - Additional Inspection Requirements. (See also Part IV.E.) As part of conducting your quarterly routine facility inspections (Part IV.E.), address all potential sources of pollutants, including (if applicable) air pollution control equipment (e.g., baghouses, electrostatic precipitators, scrubbers, and cyclones), for any signs of degradation (e.g., leaks, corrosion, or improper operation) that could limit their efficiency and lead to excessive emissions. Consider monitoring air flow at inlets and outlets (or use equivalent measures) to check for leaks (e.g., particulate deposition) or blockage in ducts. Also inspect all process and material handling equipment (e.g., conveyors, cranes, and vehicles) for leaks, drips, or the potential loss of material; and material storage areas (e.g., piles, bins, or hoppers for storing coke, coal, scrap, or slag, as well as chemicals stored in tanks and drums) for signs of material losses due to wind or storm water runoff. AOC: Eramet has no records of completed Routine Facility Stormwater Inspections, required once per quarter, having ever been completed since the effective date of the NPDES permit in 2019. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA Region 5 Lead Inspector held a closing conference with Facility personnel at 02:05 PM (ET) on 12/13/2022 for the inspection. During the closing conference, EPA Region 5 Lead Inspector discussed the observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. EPA confirmed that no information or photos collected are Confidential Business Information. Follow Up No follow up was required after exiting the facility on 12/13/2022. 8 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 Communication Log No additional information received by EPA Region 5 after exiting the Facility on 12/13/2022. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 9 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 APPENDIX 1: PHOTO LOG Photos taken using a Panasonic Toughbook CF-20 Diagram of Wastewater Flows 12/13/2022 09:52 AM EST IMG-2022121309520452490124.jpg Photographer: Jake Berger No CBI No PII Diagram of Cooling Water Flow 12/13/2022 09:56 AM EST IMG-20221213095642564294117.jpg Photographer: Jake Berger No CBI No PII 10 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 Diagram of General Sanitary Wastewater Flow 12/13/2022 09:58 AM EST IMG-20221213095800580103364.jpg Photographer: Jake Berger No CBI No PII Diesel refueling tank 12/13/2022 12:27 PM EST IMG-202212131227292729591548.jpg Photographer: Jake Berger No CBI No PII 11 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 12/13/2022 11:24 AM EST Outfall 003 IMG-202212131124142414209316.jpg Photographer: Jake Berger No CBI No PII 12/13/2022 11:32 AM EST Outfall 602 IMG-202212131132143214199766.jpg Photographer: Jake Berger No CBI No PII 12 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 12/13/2022 11:43 AM EST Outfall 603 IMG-202212131143534353288116.jpg Photographer: Jake Berger No CBI No PII 12/13/2022 12:03 PM EST Outfall 605 IMG-20221213120353353677965.jpg Photographer: Jake Berger No CBI No PII 13 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 12/13/2022 11:06 AM EST Settling Ponds IMG-20221213110656656208986.jpg Photographer: Jake Berger No CBI No PII 12/13/2022 11:54 AM EST UNOX wastewater treatment system IMG-202212131154125412559719.jpg Photographer: Jake Berger No CBI No PII 14 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 12/13/2022 12:12 PM EST Wastewater solids north impoundment IMG-20221213121209129179269.jpg Photographer: Jake Berger No CBI No PII 15 of 16 Eramet Marietta Metallurgical Plant Inspection Date: December 13, 2022 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded Date CBI PII By Received Permit OH0004006_Eramet_Permit_20190901.pdf No No Jake 12/12/2022 Berger Inspection Report - Previous OH0004006_Eramet_OEPAinsp_20220311.pdf No No Jake 12/12/2022 Berger Violation History OH0004006_Eramet_NCnotif_Fecal_20220527.pdf No No Jake 12/12/2022 Berger Violation History OH0004006_Eramet_NCnotif_Mn_20220301.pdf No No Jake 12/12/2022 Berger Violation History OH0004006_Eramet_NCnotif_Mn_20220401.pdf No No Jake 12/12/2022 Berger Violation History OH0004006_Eramet_NCnotif_Zn_20221005.pdf No No Jake 12/12/2022 Berger Communications OH0004006_Eramet_NOVresp_20220331.pdf No No Jake 12/12/2022 Berger 16 of 16