Document 3NQK2272Lx37ropKde2jGDJz6

U.S. Environmental Protection Agency Region 5 Purpose: Clean Water Act National Pollutant Discharge Elimination System Compliance Evaluation Inspection Facility: Carmeuse Lime, Inc. - Lorain Dock Operations 1840 Idaho Avenue Lorain, Ohio 44052 Inspection Date: June 23, 2022 EPA Representatives: Jake Berger, Physical Scientist, 312-353-8024, berger.jake@epa.gov Anne Marie Vincent, Life Scientist, 440-250-1720, vincent.annemarie@epa.gov Facility Representatives: Justin Bowers, Area Environmental Manager - Ohio Region Report Prepared by: Jake Berger, Physical Scientist Water Enforcement and Compliance Assurance Branch, Section 1 Digitally signed by Berger, Berger, Jake Jake Date: 2022.07.26 Inspector Signature and Date: __________________0_9_:57_:1_2_-0_5'0_0_' _____________________ Approver Name and Title: Molly Smith, Section 1 Supervisor, Water Enforcement and Compliance Assurance Branch MOLLY Digitally signed by MOLLY SMITH Approver Signature and Date: _____S__M_I_T_H________D09_a:t2e_6::_2504_2-2_0.50_'70.0_2'7_______________________ PURPOSE OF INSPECTION The purpose of the inspection by the U.S. Environmental Protection Agency (USEPA) at Carmeuse Lime, Inc. - Lorain Dock Operations (Carmeuse or Facility) was to describe, evaluate, and document compliance with the Clean Water Act (CWA) and their National Pollutant Discharge Elimination System (NPDES) permit. BACKGROUND The Facility was formerly the Jonick Dock & Terminal Company until it was sold to Carmeuse Lime, Inc. in September 2021. Carmeuse is a distributor of bulk limestone material in Lorain, Ohio. Carmeuse is located on the Black River and receives bulk stone material at the Facility via barge. Customers purchase stone and remove it from the Facility via truck. Bulk stone material is stored in uncovered piles, at the water level, near the Black River. Carmeuse samples the Facility's industrial storm water discharges to the Black River from 3 outfalls near the uncovered stone piles. These outfalls are covered by the Ohio Environmental Protection Agency (OEPA) Industrial Storm Water General Permit (Permit) (OEPA Facility ID # 3GR01074*CG; Federal NPDES Identifier # OHR000006) which has an Effective Date of June 1, 2017. Permit # OHR000006 expired on May 31, 2022, and Carmeuse has 90 days from June 1, 2022 (the Effective Date of Permit # OHR000007) to submit a Notice of Intent (NOI) to OEPA to receive continued coverage under Permit # OHR000007. Carmeuse's industrial storm water discharges continue to be authorized under Permit # OHR000006 during this interim period. INSPECTION Jake Berger and Anne Marie Vincent of USEPA first arrived at the Facility at 7:50 a.m. EDT and were met by Kelly Allomong (Scale Operator). Jake Berger and Anne Marie Vincent showed her their inspector credentials and identification and were instructed to wait for Rob Hajski (Dock Foreman) to come up from the dock area. Rob Hajski explained that he would not be able to leave the dock operations to participate in the inspection, so Justin Bowers (Area Environmental Manager - Ohio Region) was called to come in from Carmeuse's office in Grand River, Ohio. Justin Bowers arrived at 10:30 a.m. EDT to serve as the Facility representative for the inspection. Jake Berger and Anne Marie Vincent showed him their credentials and identification and began the opening conference. Opening Conference USEPA staff explained that the purpose of the inspection was to: Review Carmeuse's records, including sample measurements, monitoring activities, and storm water plans, as required by Permit # 3GR01074*CG; Conduct a walkthrough of the Facility; Identify locations where storm water control had the potential to be insufficient; and 2  Inform Carmeuse of areas of concern regarding the records review and facility walkthrough. Records Review Carmeuse had a binder of some storm water documents at the truck scale office. This included document templates for storm water record keeping, employee training records, and an undated and abridged version of their Storm Water Pollution Prevention Plan (SWPPP). Justin Bowers provided electronic copies of their self-inspection documentation and monitoring results. Justin Bowers immediately sent the full version of the SWPPP, which was finalized on January 31, 2020, to Jake Berger via email. Upon review of these records, the following areas of concern were identified: Section 2.1.2.9 of the Permit requires Carmeuse to "train all employees who work in areas where industrial materials or activities are exposed to storm water, or who are responsible for implementing activities necessary to meet the conditions of this permit (e.g., inspectors, maintenance personnel), including all members of your Pollution Prevention Team. Training shall cover both the specific control measures used to achieve the conditions in this Part, and monitoring, inspection, planning, reporting, and documentation requirements in other parts of this permit. Ohio EPA requires that training be conducted at least annually." Carmeuse has no records of providing any employee training related to storm water pollution prevention since 2017. Section 5.1.7 of the Permit requires the SWPPP to be signed and dated by a responsible corporate officer. The digital copy of the 2020 SWPPP that was provided was not signed. Section 5.3 of the Permit requires that a copy of the SWPPP shall be retained at the facility. Only part of the SWPPP was available at the Facility, as described above. Section 6.2.1 of the Permit requires Carmeuse to conduct Benchmark Monitoring of industrial storm water, take an average of the monitoring concentration values, compare these averages to the benchmark concentration, and take additional actions if the average monitoring values exceed the benchmark concentration. The limits for Lead and Zinc are hardness dependent as described in Section 8.Q.6 of the Permit. Carmeuse conducted this sampling but made no calculations of the average measured concentrations and did not compare their data to the benchmark concentrations. Therefore, Carmeuse never determined if they were meeting or exceeding the benchmark concentrations. The SWPPP needs to be updated to reflect changes at the Facility which include, but are not limited to, the permanent removal of one the outfalls, changes in the types of materials stored onsite, and ownership/staffing changes. The records review portion of the inspection concluded at 11:40 a.m. EDT and was immediately followed by a Facility walkthrough tour with Justin Bowers. 3 Facility Walkthrough USEPA staff made the following observations during the Facility walkthrough, further documented in the Photograph Log (attached): The gravel surface of the loading platform near Outfall A lacks containment around the edges (Photo 1). Sections of the metal barrier are level with the gravel surface, allowing gravel to fall into the Black River. The vegetated berm along the Black River shoreline used to contain storm water does not extend the entire length of the material storage area (Photo 8 and Photo 9). Runoff and erosion leading into the Black River are evident at the northern end of the material storage area, where there is no berm. The Facility walkthrough tour ended at 12:40 p.m. EDT and was immediately followed by the closing conference. Closing Conference USEPA staff relayed the following preliminary comments to Justin Bowers during the closing conference: Carmeuse has until 90 days from June 1, 2022, to submit a NOI to OEPA to receive continued coverage under Permit # OHR000007; The SWPPP will need to be reviewed and updated within 180 days from June 1, 2022, as required by Section 5 of the Permit; Benchmark Monitoring results need to be averaged, and that average is to be compared to the Benchmark Monitoring limits to determine if correctional action is needed. Hardness also needs to be measured in order to determine the corresponding limits for Lead and Zinc; Carmeuse is required to complete annual storm water training; A complete and signed version of the SWPPP needs to be available onsite; and Storm water controls were insufficient in some areas to prevent erosion and runoff to the Black River, such as the loading platform and north end of the material storage area. USEPA confirmed that no information collected during the inspection was considered Confidential Business Information. USEPA concluded the inspection and left the Facility at 12:56 p.m. EDT. 4 Carmeuse Lime, Inc. EPA Inspection 6/23/2022 All photos taken by Jake Berger, Physical Scientist, U.S. EPA Camera: Olympus Tough TG-6 1: P6230023 Description: Outfall A Location: Loading area; platform edge near outfall Camera Direction: North Date/Time: 6/23/2022 - 11:56 a.m. EDT * Photograph time stamps are in Central Daylight Time due to camera settings, actual time of photograph is noted in the caption below each image. 5 2: P6230024 Description: Runoff path into outfall A Location: Loading area Camera Direction: Northeast Date/Time: 6/23/2022 - 11:57 a.m. EDT 3: P6230025 Description: Outfall A Location: Loading area Camera Direction: Down/North Date/Time: 6/23/2022 - 11:58 a.m. EDT 6 4: P6230026 Description: Outfall B Location: Loading area Camera Direction: North Date/Time: 6/23/2022 - 12:06 p.m. EDT 5: P6230027 Description: Closeup of Outfall B Location: Loading area Camera Direction: North Date/Time: 6/23/2022 - 12:07 p.m. EDT 7 6: P6230028 Description: Runoff path into Outfall D Location: Onshore material storage area Camera Direction: Northwest Date/Time: 6/23/2022 - 12:17 p.m. EDT 7: P6230029 Description: Outfall D Location: Onshore material storage area Camera Direction: West Date/Time: 6/23/2022 - 12:18 p.m. EDT 8 8: P6230030 Description: Erosion rill off storage area driveway Location: North side of onshore material storage area Camera Direction: West Date/Time: 6/23/2022 - 12:34 p.m. EDT 9: P6230031 Description: Erosion channel along shoreline Location: North side of onshore material storage area Camera Direction: West Date/Time: 6/23/2022 - 12:38 p.m. EDT 9