Document 6BNeo3d8GD8BQ7Jgx4L06pbVd

US 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 April 11, 2025, 8:30 a.m. (EST) Announced: No April 11, 2025, 11:51 p.m. (EST) Access: Granted Cloudy Water Clean Water Act, National Pollutant Discharge Elimination System (NPDES) permit program Industrial Stormwater Inspection (ISI) Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Mailing Address (If different) Mondelz Global LLC Mondelz Toledo Ohio Facility (fka Kraft Foods Global Inc) 2221 Front St Toledo, Ohio 43605 Lucas nicholas.patterson@mdlz.com FRS ID Permit Number(s) (If Applicable) OHU000055 SIC and/or NAICS 2041 Lead Inspector: William JonesWILLIAM JONES Digitally signed by WILLIAM JONES Date: 2025.06.16 14:55:18 -05'00' EPA REGION 5 Jones.William@epa.gov (312) 886-6058 Supervisor Review: MOLLY Molly Smith SMITH Digitally signed by MOLLY SMITH Date: 2025.06.16 16:31:36 -05'00' EPA REGION 5 Smith.Molly@epa.gov SECTION I - INTRODUCTION Site Entry and Inspection Objectives EPA Region 5 Lead Inspector, William Jones, arrived at Mondelz Toledo Ohio Facility (the "Site" or "Facility"), located at the address listed above which is located close to the Maumee River in Toledo, Ohio at 8:30 a.m. EST on April 11, 2025, for an unannounced inspection. EPA Region 5 Lead Inspector presented credentials to Nicolas Patterson and informed him that this was an EPA Region 5 inspection to investigate, as authorized by Clean Water Act (CWA) Section 308 and implementing regulations, including the Facility's industrial storm water permit. This report is based on information supplied by Mondelz Global LLC representatives, direct 1 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 observations made by EPA Region 5 inspectors, records and reports maintained by the permittee and other information including: photographs taken by EPA Region 5 inspectors, verbal or written statements made by information supplied by Mondelz Global LLC 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 inspectors by Mondelz Global LLC representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or after the Inspection from a review of US Environmental Protection Agency (EPA), state, and/or public records may be included in this report. Attendees Organization EPA Region 5 Attendee Name William Jones Title Lead Inspector Present in Opening Conf. Yes EPA Region 5 Jeremy Leggett Physical Scientist Yes Mondelz Global LLC Nicholas Patterson Senior Health and Yes (nicholas.patterson@mdlz.com) Safety Environmental Specialist Mondelz Global LLC Trevor Parks (trevor.parks@mdlz.com Health and Safety Yes Environmental Specialist Present in Closing Conf. Yes Yes Yes Yes Facility/Site Description EPA Region 5 lead inspector confirmed the following facility information: Mondelz Toledo Ohio Facility is owned by Mondelz Global LLC. Mondelz Toledo Ohio Facility is a flour mill. The Facility uses wheat berries (Grain) to produce flour. On September 12, 2022 and July 22, 2024, the Ohio Environmental Protection Agency (Ohio EPA) approved coverage under general storm water industrial permit OHR000007 for Kraft Foods Global Inc at 2221 Front Street in Toledo, Ohio, with a permit effective date of September 12, 2022, and August 1, 2024, respectively. The expiration date is May 31, 2027. The letters were sent to Reid Kersey at Mondelz Global LLC. Facility/Site Information Location(s) Location/Area/Sub-area Hopper cars area Dock area Area near scales Description Area where hopper cars are on site and nearby storm sewer inlets and outfall. Area where barges are received with grain Area where truck scales area and nearby storm drain inlets Nicholas Patterson stated the Facility employs about 93 employees, and mostly run 24-hours a day, seven days a week. Mr. Patterson stated the Facility gets wheat berries and produce flour and ships out via truck and rail. The Facility receives the wheat berries by truck, barge and rail. Mr. Patterson does the monthly stormwater inspections and CT consultants do the sampling. US EPA requested a copy of the Facility's Storm Water Pollution Prevention Plan (SWPPP), but Mr. Patterson required US EPA to request copies of all compliance documents in 2 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 writing. The Facility reported quarterly benchmark monitoring exceedances from fourth quarter of 2022 through third quarter of 2024. The Facility has two cyclonic separators for stormwater. Mondelz uses diesel fuel (approximately 15,000 gallons of storage), food grade oil, and fumigants. Crown does the preventative maintenance for Mondelz's forklifts. Plymouth does the maintenance on the diesel locomotives. Mr. Patterson said that there have been no spills onsite since he has been here. The Facility has five outfalls, four of which the Facility collects samples from. The Facility uses a basket and a sock. In 2024 three additional socks were installed to bring the total number installed to six. US EPA viewed photos of containers the Facility uses to take visual observation samples from. Mr. Patterson said that every drain gets vacuumed out annually. The Facility also has two cyclonic separators. One separator is installed for flows to Outfalls 3 and 4, and a second one is installed for flows to outfall 5. SECTION II - OBSERVATIONS Location: Hopper cars area Observation #: WJ1-OB-001 Date: April 11, 2025 Weather: Cloudy US EPA observed sediment on the ground near the hopper cars and storm drain inlets. Photos 1 through 7. Location: Dock area Observation #: WJ1-OB-002 Date: April 11, 2025 Weather: Cloudy US EPA observed sediment in storm drains and unstabilized ground. Photos 15 through 17, 19, and 22. Location: Dock area Observation #: WJ1-OB-003 Date: April 11, 2025 Weather: Cloudy US EPA observed accumulations of grain along the dock area near holes in the sheet piling, and erosion along the fence line. Photos 8 through 10, 25, and 27-31. 3 of 38 Mondelz Toledo Ohio Facility Inspection Date: Location: Area by dust collector Observation #: WJ1-OB-004 Date: April 11, 2025 EPA observed dust on the ground by the dust collector Photo 24 4-11-2025 Weather: Cloudy SECTION III - RECORDS REVIEW Records may not be in sequential order Record: Storm Water Pollution Prevention Plan Ref #: WJ1-RR-001 Reviewed By: William Jones AOC: Yes Reviewed Date: April 11, 2025 The onsite version of the SWPPP is dated October 2022, and the last revision was marked as March 2023. 1. Information collected through a Clean Water Act Section 308 Information Request following the inspection is under review. SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted as part of the inspection. 4 of 38 Mondelz Toledo Ohio Facility Inspection Date: SECTION V - AREAS OF CONCERN 4-11-2025 See below for areas of concern related to the current industrial storm water General Permit OHR000007: Part 2.1.2.2 Good Housekeeping: Requires the facility to keep clean all exposed areas that are potential sources of pollutants, using measures such as sweeping at regular intervals, keeping materials orderly and labeled, and storing materials in appropriate containers. US EPA documented areas of concern around Track 2 and the contractor roll off area. Sediment was observed on the concrete by the hopper cars and around the storm drain inlets. Dust was also observed on the ground by the dust collector. See photograph 24. US EPA documented grain accumulation near the waterway /dock area. US EPA also documented sediment build up to the top of the sheet pilings in some areas. See photographs 8-10, 25, and 27-31. US EPA documented areas of concern in the Outfall 5 area. The area has a patch of unstabilized black dirt near an outfall. See photograph 17. Inside a storm sewer shown in photographs 15 and 16, US EPA documented sediment and trash accumulation inside the structure leading into the storm water pipe. Section 2.1.2.5 Erosion and Sediment Controls: "You shall stabilize exposed areas and contain runoff using structural and/or non-structural control measures to minimize onsite erosion and sedimentation, and the resulting discharge of pollutants. Among other actions you shall take to meet this limit, you shall place flow velocity dissipation devices at discharge locations and within outfall channels where necessary to reduce erosion and or settle out pollutants." US EPA documented exposed areas not stabilized. See photographs 3, 6, 8, 17, 19, 25, and 29. Section 2.1.2.11 Waste, Garbage and Floatable Debris: "You shall ensure that waste, garbage, and floatable debris are not discharged to receiving waters by keeping exposed ares free of such materials or by intercepting them before they are discharged." See photographs 15 and 16 for documentation of garbage and floatable material inside sewer. SWPPP: US EPA noted that the SWPP is not up to date. US EPA also documented holes in the sheet piling along the dock, which was not identified in the SWPPP. See above observations in Section II and III related to the areas of concern. 5 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA REGION 5 Lead Inspector held a closing conference with Facility personnel on April 11, 2025, 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. William Jones, along with Jeremy Leggett, Nick Patterson, and Treavor Parks were present for the closing conference. Mr. Jones shared that the observations and Areas of Concern were preliminary. Mr. Jones confirmed that no information gathered was considered Confidential Business Information. Mr. Jones then relayed the following preliminary observations to the Facility representatives: Documented housekeeping by track 2 and the contractor roll off area. Documented the accumulation of grain near the waterway. Documented Outfall 5 where there is an area of black dirt with the potential to be swept into the outfall. Current SWPPP does not show all the Facility's discharge points. Since the Facility did not provide copies of documents during the inspection, US EPA request the documents through a Clean Water Action Section 308 Information Request. Follow Up A Clean Water Act Section 308 Information Request was sent to the Facility on April 24, 2025. Responses were received on May 1, and 8, 2025. SECTION VII - LIST OF APPENDICES 1. Photo Log 6 of 38 Mondelz Toledo Ohio Facility Inspection Date: APPENDIX 1: PHOTO LOG All photos taken in the eastern time zone by William Jones, Environmental Engineer, U.S. EPA Camera: Pentax WG-1 4-11-2025 7 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 1. Ground alongside of the track where the hopper cars were. Sediment can be seen on the ground by the hopper car. This is the track 2 loading area. April 11, 2025/10:05 a.m. No PII Mondelz Toledo Ohio Facility Camera Direction: North-east IMGP0001.JPG Photographer: William Jones 8 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 2. Ground alongside of the track where the hopper cars were. Sediment can be seen on the ground by the hopper car. April 11, 2025/10:05 a.m. No PII Mondelz Toledo Ohio Facility IMGP0002.JPG Photographer: William Jones Camera Direction: North-east 9 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photo 3. View of outfall near hopper cars shown in photographs 1 and 2. This unstabilized area drains to outfall 001. April 11, 2025/10:11 a.m. No PII Mondelz Toledo Ohio Facility Camera Direction: Down IMGP0003.JPG Photographer: William Jones 10 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 4. Closeup of inlet shown in photograph 3. April 11, 2025/10:13 a..m. No PII Mondelz Toledo Ohio Facility Camera Direction: Downward IMGP0004.JPG Photographer: William Jones 11 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photo 5. View through hole of manhole lid shown in photograph 4. Sediment can be seen at the bottom of the inlet protection. April 11, 2025/10:13 a.m. No PII Mondelz Toledo Ohio Facility View looking down IMGP0005.JPG Photographer: William Jones 12 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 6. Second mahole leading to outfall 001 April 11, 2025/10:15 a.m. No PII Mondelz Toledo Ohio Facility View looking easterly IMGP0006.JPG Photographer: William Jones 13 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 7. Close view through hole in manhole lid shown IMGP0007.JPG in photograph 6. Sediment can be seen in the inlet protection. April 10, 2025/10:16 a.m. Mondelz Toledo Ohio Facility View looking down No PII Photographer: William Jones 14 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 8. Fence with dock area beyond fence April 11, 2025/10:23 a.m. No PII Mondelz Toledo Ohio Facility Looking westerly IMGP0008.JPG Photographer: William Jones 15 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 9. Fence dock area next to area shown in photograph 8. Grain can be seen accumulating at the edge of the dock against the sheet pilings. Holes can be seen in the sheet pilings. April 11, 2025/10:28 a.m. No PII Mondelz Toledo Ohio Facility South-westerly IMGP009.JPG Photographer: William Jones 16 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 10. Closer view of dock area shown on the right side of photograph 9. Grain can be seen just on the other side of the fence. Grain has also accumulated along the sheet pilings at the edge of the water. Holes can be seen in the sheet pilings where the grain has accumulated. April 11, 2025/10:28 a.m. No PII Mondelz Toledo Ohio Facility Westerly IMGP0010.JPG Photographer: William Jones 17 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 11. Inlet along roadway near the dock area shown in photograph 10. April 11, 2025/10:31 a.m. No PII Mondelz Toledo Ohio Facility Looking down IMGP0011.JPG Photographer: William Jones 18 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 12. Closeup of inlet shown in photograph 11. This leads to outfall #2. April 11, 2025/10:31 a.m. No PII Mondelz Toledo Ohio Facility View down IMGP0012.JPG Photographer: William Jones 19 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 13. Pavement damp from liquid under truck close to dock area April 11, 2025/10:35 a.m. No PII Mondelz Toledo Ohio Facility Down IMGP0013.JPG Photographer: William Jones 20 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 14. Area south-easterly of the grain unloading area April 11, 2025/10:37 a.m. No PII Mondelz Toledo Ohio Facility Looking down at the rip rap and the Maumee River IMGP0014.JPG Photographer: William Jones 21 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 15. Storm sewer inlet that leads to outfall3/4. April 11, 2025/10:39 a.m. No PII Mondelz Toledo Ohio Facility Looking down IMGP0015.JPG Photographer: William Jones 22 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 16. Close up through the grate shown in photograph 15. April 11, 2025/10:40 a.m. No PII Mondelz Toledo Ohio Facility Looking down IMGP0016.JPG Photographer: William Jones 23 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 17. Storm water inlet leading to outfall 005. This IMGP0017.JPG is near the truck grain unloading area. April 11, 2025/10:46 a.m. No PII Photographer: William Jones Mondelz Toledo Ohio Facility Looking down 24 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 18. View of inlet protection inside manhole shown in photograph 19. April 11, 2025/10:47 a.m. No PII Mondelz Toledo Ohio Facility View down IMGP0018.JPG Photographer: William Jones 25 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 19. Area east of truck unloading area. Unstabilized area east of the scales. April 11, 2025/10:51 a.m. No PII Mondelz Toledo Ohio Facility Easterly IMGP0019.JPG Photographer: William Jones 26 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 20. Hydraulic fluid staining on the pavement by the truck unloading area. April 11, 2025/10:54 a.m. No PII Mondelz Toledo Ohio Facility North-Easterly IMGP0020.JPG Photographer: William Jones 27 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 21. Staining on the pavement by the truck unloading area. April 11, 2025/10:55 a.m. No PII Mondelz Toledo Ohio Facility North-Easterly IMGP0021.JPG Photographer: William Jones 28 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 22. Roll off container for dust collector. Some is IMGP0022.JPG spilled on the ground. April 11, 2025/10:58 a.m. No PII Photographer: William Jones Mondelz Toledo Ohio Facility Easterly 29 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 23. Inside the roll off container shown in photograph 22. April 11, 2025/10:59 a.m. No PII Mondelz Toledo Ohio Facility Easterly IMGP0023.JPG Photographer: William Jones 30 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 24. Dust collector and dust buildup April 11, 2025/11:10 a.m. Mondelz Toledo Ohio Facility Easterly No PII IMGP0024.JPG Photographer: William Jones 31 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 25. Dock area with sediment buildup along sheet IMGP0025.JPG pilings. April 11, 2025/11:19 a.m. No PII Photographer: William Jones Mondelz Toledo Ohio Facility Westerly 32 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 26. Outfall 001 into the Maumee April 11, 2025/11:20 a.m. Mondelz Toledo Ohio Facility View looking down No PII IMGP0026.JPG Photographer: William Jones 33 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 27. Dock area showing the grain build up along the sheet pilings April 11, 2025/11:22 a.m. No PII Mondelz Toledo Ohio Facility Westerly IMGP0027.JPG Photographer: William Jones 34 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 28. Dock area showing the sheet pilings and grain along the pilings. April 11, 2025/11:22 a.m. No PII Mondelz Toledo Ohio Facility Southerly IMGP0028.JPG Photographer: William Jones 35 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 29. Dock area shown in photograph 28. Near the middle of the photograph can be seen erosion and grain accumulation April 11, 2025/11:23 a.m. No PII Mondelz Toledo Ohio Facility Southerly IMGP0029.JPG Photographer: William Jones 36 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 30. Grain can be seen accumulating along the sheet pilings on the edge of the dock. The red arrows point to the grain. April 11, 2025/11:25 a.m. No PII Mondelz Toledo Ohio Facility Easterly and down IMGP0030.JPG Photographer: William Jones 37 of 38 Mondelz Toledo Ohio Facility Inspection Date: 4-11-2025 Photograph 31. Grain can be seen accumulating along the IMGP0031.JPG sheet pilings on the edge of the dock at ground level. The red arrows point to the grain. Holes can be seen in the sheet piling. April 11, 2025/11:27 a.m. No PII Photographer: William Jones Mondelz Toledo Ohio Facility Easterly 38 of 38