Document 7R6QYx2m8o20Y8w0vw3Mk47bV

CWA COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5 Facility: TLB Wood Products, LLC N5624 County Road C Seymour, Wisconsin 54311 NPDES Permit Number: WIR05IA00 Purpose: To evaluate compliance with applicable stormwater regulations under the National Pollutant Discharge Elimination System (NPDES) permit program and the Clean Water Act (CWA). Date of Inspection: April 29, 2025 EPA Region 5 Water Enforcement Compliance Assurance Representatives: Keith Middleton, Environmental Engineer, middleton.keith@epa.gov, 312-886-6465 Danny Nguyen, Environmental Engineer/Scientist, nguyen.danny@epa.gov, 440-250-1709 Eric Small, Physical Scientist, small.eric@epa.gov, 312-886-6680 Facility Representatives: Doug Olson, President, TLB Wood Products, doug@tlbcompanies.com, 920-833-9031 Report Prepared by: Keith Middleton, Environmental Engineer KEITH MIDDLETON Date: 2025.06.16 15:47:19 -05'00' Digitally signed by KEITH MIDDLETON Inspector Signature: ___________________________________________________________ Approver Name and Title: Ryan Bahr, Section 2 Supervisor, Water Enforcement and Compliance Assurance Branch Bahr, Ryan Digitally signed by Bahr, Ryan Date: 2025.06.16 16:48:31 -05'00' Approver Signature and Date: ___________________________________________________ TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 INTRODUCTION On April 29, 2025, representatives from the U.S. Environmental Protection Agency, Region 5 conducted a Compliance Evaluation Inspection at the TLB Wood Products, LLC facility in Seymour, Wisconsin ("facility"). The purpose of this inspection was to evaluate this facility's compliance with the CWA and the facility's EPA issued National Pollutant Discharge Elimination System ("NPDES") permit. This inspection consisted of the following: an opening conference, discussions concerning the facility's Stormwater Pollution Prevention Plan (SWPPP), compliance with this facility's NPDES permit, a facility site walk-through, and a closing conference. Any findings and concerns that EPA identified during the inspection are listed in the section entitled "Areas of Concern" starting on page 12 of this report. FACILITY BACKGROUND This facility is owned by DSO Properties LLC and operated by TLB Wood Products, LLC. According to Doug Olson, Facility President, this facility is located on a 10-acre parcel of land on the southwest corner of the Oneida Nation Tribal Lands in Outagamie County. Mr. Olson indicated that he purchased this business in approximately 2012; the facility had been previously operating in this location since the 1980s. A stormwater ditch located to the west of the facility, east of County Road C drains most of the facility. This stormwater ditch ("County C roadside ditch") is within roadway right-of-way and is maintained by the Outagamie County Highway Department. There are two other stormwater ditches that drain to the County C roadside ditch that were created by the facility on the north and south property boundaries. EPA learned during the inspection that the property north of the facility was a private residential home and the property to the west and the south was owned by Oneida Nation. This facility produces mulch, animal bedding and biomass fuel. These products are made at this facility from approximately 90% virgin wood that is grinded up by the onsite grinder machines or from bark extracted from logs at paper mills. The facility also uses #2 waste wood (usually waste wood or pallets) for some products. The facility also makes colorized mulch at this facility. Color can be added to the mulch using colorizer/dye products. Mr. Olson estimated that about 60% of the mulch produced onsite is dyed/colored. There are about 18 full-time employees that work at this facility. Production is seasonal with the continuous production occuring from April 1st to July 4th. During this time, production occurs for approximately 9.5 hours a day, five days a week within one shift. The facility will also be open during this time on Saturdays for a half-day. After July 4th, the facility will typically be open sporadically, as needed. The buildings onsite consist of a main shop/office building with an attached storage building. General vehicle parking is located between the shop/office building and County C highway. The separate storage building was being rented out to another entity at the time of this inspection and was not inspected. Within the shop, the facility stores diesel exhaust fluid, hydraulic fluid, and colorant/mulch dye. All of the grinding wood products to produce mulch, animal bedding, and 2 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 biomass fuels is done outdoor by specialized machinery. The facility's Standard Industrial Classification (SIC) code is 2421 (General Sawmills and Planing Mills). National Pollutant Discharge Elimination System Permit EPA issued this facility a National Pollutant Discharge Elimination System (NPDES) MultiSector General Permit for stormwater discharges associated with industrial activity on July 12, 2021. This permit ("Stormwater Permit") expires on February 28, 2026. According to Mr. Olson, the facility was previously covered under a Wisconsin Pollutant Discharge Elimination System (WPDES) general permit for industrial stormwater discharges. The requirements of the Stormwater Permit include the following: Identifying the onsite stormwater controls used to minimize pollutant discharges (Part 2 of the Stormwater Permit). Inspection and Stormwater Monitoring procedures (Parts 3 and 4 of the Stormwater Permit), including: o Routine Facility Inspection Requirements (Part 3.1 of the Stormwater Permit); o Quarterly Visual Assessment Requirements (Part 3.2 of the Stormwater Permit); o Indicator Monitoring (Part 4.1 of the Stormwater Permit); and o Benchmark Monitoring (Part 4.2 of the Stormwater Permit). The requirements of a Stormwater Pollution Prevention Plan (Part 6 of the Stormwater Permit). The reporting and recordkeeping requirements (Part 7 of the Stormwater Permit). For the Indictor and Benchmark Monitoring requirement, this facility is covered under Sector A, Subsector A1 (based on the NOI, the facility's SIC code, and Part 8 of the Stormwater Permit). This subsector requires Indictor Monitoring at this facility for each quarter (beginning the Fourth Quarter of 2021) for polycyclic aromatic hydrocarbons (PAHs) if the facility has a sealed/resealed paved surface with coal-tar sealcoat. During the inspection, Mr. Olson told EPA that he did not believe coal-tar sealcoat had been used onsite at the facility. For Benchmark Monitoring, the facility's subsector requires monitoring chemical oxygen demand (COD), total suspended solids (TSS), and zinc in the first year of permit coverage (Fourth Quarter of 2021 to the Third Quarter of 2022) and the fourth year of permit coverage (Fourth Quarter of 2024 to the Third Quarter of 2025). Facility-Identified Stormwater Discharge Points In Appendix A of the Stormwater Permit, "Discharge Point" is defined as the "location where collected and concentrated stormwater flows are discharged from the facility such that the first receiving waterbody into which the discharge flows either directly or through a separate storm sewer system is a water of the U.S." In the facility's Notice of Intent (NOI), four stormwater discharge points are identified. Three of these discharge points (001, 002, and 003) in the NOI are labeled as an Unnamed Ditch, with the other discharge point (004) described as the East Properly Line. When reviewing the 3 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 corresponding latitude/longitude, it appears that Discharge Point 001 was within County C roadside ditch, Discharge Point 002 was within the facility-made north property line stormwater ditch, Discharge Point 003 was within the facility-made south property line stormwater ditch, and Discharge Point 004 was on the east side of the property. The NOI indicated that Discharge Point 001, 002, and 003 were determined by the facility to be substantially identical. Receiving Waters Exhibit 1: TBL Wood Products Facility Site Location - USGS Map Source: USGS The National Map As previously mentioned, the outfalls discharge to an unnamed ditch that runs alongside County Road C and is located west of the facility. The roadway ditch flows to the south approximately 1,000 feet to another unnamed ditch that flows east. This unnamed ditch flows east in a meandering route approximately six miles to Duck Creek. Duck Creek is shown as a permanent waterbody on the USGS National Map website (Exhibit 1, see above). Duck Creek then continues north and flows into Lake Michigan. Duck Creek has impairments for fish and aquatic life related to murky water (turbidity) and nitrogen/phosphorus. According to Exhibit 1, there is also an area delineated as a wetland, located east of the facility. 4 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 SITE INSPECTION Exhibit 2: TLB Wood Products Facility Location1 Source: Google Maps (2025) Initial Inspection Discussion The EPA inspection team, consisting of Mr. Middleton, Mr. Nguyen, and Mr. Small arrived at the facility at approximately 8:45 am on Tuesday, April 29, 2025. The weather was mostly cloudy, windy, and dry with a temperature of approximately 51 Fahrenheit. It had rained approximately 0.75 inches at the site 12 hours prior to EPA's inspection. After parking in the facility's parking lot west of the facility, the EPA inspectors entered the facility's office building on the second floor of the facility. After explaining to the office manager that EPA was at the facility to perform a CWA stormwater inspection, Mr. Olson came out to meet EPA inspectors. EPA was then shown to a conference room on the southeast corner on the second floor of the office portion of the facility's main building. After EPA explained the purpose of the inspection, Mr. Middleton, Mr. Nguyen, and Mr. Small then presented their EPA inspector credentials to Mr. Olson. Next, Mr. Middleton discussed EPA's Confidential Business Information (CBI) provision and notified Mr. Olson that EPA would be requesting documents and taking pictures at the facility during this inspection. EPA also proposed a tentative schedule for the inspection. 1 Notes on Exhibit 1: The red box is the facility's approximate site boundaries. 5 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 EPA and Mr. Olson then began discussing background information of the TLB Wood Products facility, including the history of the facility and the general operations of the facility. This information is summarized above in the Facility Background section on page 2 of the inspection report. Stormwater Discharge Points Next, EPA inspectors discussed the facility's onsite stormwater discharge outfalls. EPA was informed by Mr. Olson that there was a different orientation of facility's discharge points than what was presented in the facility's NOI, based on a facility map created by Mr. Olson (updated site map). Mr. Olson indicated to the EPA inspectors that there were two stormwater outfalls on the north property line (discharging to the north perimeter stormwater ditch) with four stormwater outfalls on the west property line (discharge to the County C roadside ditch) with a total of six outfalls. Mr. Olson told EPA that basically three-quarters of the site drained to the west towards the roadside ditch with the other quarter of the site draining east. Mr. Olson specified that on the southern perimeter of the facility, the flow from the bark pile was sheet flow runoff to the south perimeter stormwater ditch. This ditch then flowed into the County C roadside ditch. Mr. Olson also acknowledge that the northeast corner of the site had the lowest elevation onsite and would flood during large precipitation events. EPA then learned from Mr. Olson that there were two pumped discharges from the facility to the County C roadside ditch. The first pumped discharge was draining a low area in the loading dock that would flood with stormwater during rain events. This area was drained through a drain in the loading dock, which was connected to a sump located in the shop that then was pumped the water out to the County C roadside ditch. The second pumped discharge was a pump that drained the area underneath the colorizer machine, located south of office/shop. This pump discharge also is pumped to the County C roadside ditch west of the facility. After the inspection, EPA reviewed the facility's SWPPP and SWPPP site map. EPA noticed the SWPPP site map had eight identified letter designated stormwater discharge outfalls. Discharge Points H and G discharged to the north perimeter stormwater ditch, Discharge Points A, B, C, and D discharge to the County C roadside ditch, and Discharge Points E and F discharge to the field to the east, owned by Oneida Nation. Benchmark Monitoring EPA and Mr. Olson then discussed the benchmark monitoring that was required to be performed by TLB Wood Products pursuant to Part 4.2.2 of its Stormwater Permit from the Fourth Quarter of 2021 to the Third Quarter of 2022, EPA learned from Mr. Olson that: Mr. Olson does not sample at the same stormwater outfalls identified for each quarter, due to some confusion with the Central Data Exchange (CDX) DMR submittal process for benchmark monitoring. Mr. Olson told EPA that there are only two outfalls are included in the DMR and was unable to add additional outfalls to the DMR after 6 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 discussing with EPA Region 5. Therefore, Mr. Olson began taking two samples for each quarter. Mr. Olson said he would also vary the locations where each sample was obtained in either the north perimeter stormwater ditch, the south perimeter stormwater ditch, or the County C roadside ditch. Mr. Olson uses one of two 5-gallon bucket to obtain a benchmark monitoring sample, filling about 2 gallons into the bucket for each sample. Since he uses only two separate buckets, he can only conduct two samples at a time. Mr. Olson will then transport the bucket(s) with the stormwater sample(s) by vehicle over to Badger Laboratories in Green Bay Wisconsin. According to Google Maps, this drive would take approximately 25 minutes. The sample bucket(s) is/are not cooled/kept on ice during these trips, nor are there any other sample preservation utilized, pursuant to 40 C.F.R. Part 136, that were employed. Mr. Olson told EPA that when he reaches Badger Laboratories, the stormwater sample is then poured into the appropriate sample glassware. Discharge Point 001/002/003 Parameter 4th Q 1st Q 2nd Q 2021 2022 2022 Zinc Not 0.017 0.033 g/L (freshwater) enough g/L Total rain to 2.2 mg/L 3.4 mg/L Suspended sample Solids Chemical 30.0 mg/L 5.7 mg/L Oxygen Demand * Average computed from three sampling events 3rd Q 2022 0.021 g/L 13 mg/L 56.0 mg/L Benchmark Benchmark Average Total Thresholds 0.022 g/L* 260 g/L 6.2 mg/L* 100 mg/L 30.6 mg/L* 120 mg/L Discharge Point 004 Parameter 4th Q 2021 Zinc 0.053 (freshwater) g/L Total 14.0 Suspended mg/L Solids Chemical 36 mg/L Oxygen Demand 1st Q 2022 0.009 g/L 3.8 mg/L 35.0 mg/L 2nd Q 2022 0.008 g/L 18.0 mg/L 3rd Q 2022 0.021g/L Benchmark Average Total 0.023 g/L Benchmark Thresholds 260 g/L 30.0 mg/L 16.5 mg/L 100 mg/L 41.0 mg/L 83.0 mg/L 48.8 mg/L 120 mg/L The results of the first-year benchmark monitoring results are included above. These results were less than the pollutant parameter thresholds specified in Part 8 of the Stormwater Permit. Therefore, TLB Wood Products did not continue to perform any additional benchmark monitoring or implement any correction actions after the 3rd quarter 2022 sampling was 7 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 completed. Mr. Olson did indicate that TLB had started performing the facility's Stormwater Permit required fourth-year benchmark monitoring, using the same protocol described in the bullet points above. Mr. Olson indicated to EPA that Badger Laboratories had in the past performed the sampling themselves, but he was not aware which of the samples were performed by Badger Laboratories and how those samples were preserved. After the inspection, EPA noted that the NOI indicates that there are three discharge points that discharge the County C roadside ditch that the facility indicated were substantially identical. Part 4.1.1 of the Stormwater Permit allows the facility to monitor effluent at just one of the discharge points and apply the results to the other substantially identical discharge points. EPA's understanding is that CDX used the information from the facility's 2021 NOI submission and that this is why there were only two stormwater discharge points that were included in the facility's DMR, Discharge Point 001 (this could be samples from 001, 002, or 003) and Discharge Point 004. Stormwater Inspections Then, EPA and Mr. Olson discussed the inspection requirements in Part 3 of the Stormwater Permit. Mr. Olson said that he conducts the routine facility inspections and the quarterly visual inspections and records the information on a separate checklist. EPA requested and received the routine facility inspections, and the quarterly visual inspections conducted in 2024. Mr. Olson conducted routine facility inspections on March 26, 2024, May 7, 2024, June 20, 2024, July 8, 2024, September 20, 2024, and December 28, 2024. The quarterly visual inspections were conducted by Mr. Olson on March 26, 2024 (Discharge Points C and H), June 20, 2024 (Discharge Points A and F), September 20, 2024 (Discharge Points D and H), and November 5, 2024 (Discharge Points B and G). When conducting the quarterly visual inspections, Mr. Olson will take the stormwater sample in a green 5-gallon bucket at two of the stormwater discharge points. These stormwater discharge points that were sampled during each quarterly visual inspection are identified above in parentheses. Mr. Olson also fills out and submits the annual report. After the inspection, EPA confirmed that TLB Wood Products had submitted an annual report each year from 2021 through 2024 to EPA, as required by the Stormwater Permit. Stormwater Pollution Prevention Plan EPA confirmed with Mr. Olson that the SWPPP submitted with the NOI and dated June 9, 2021, was the most current version of the facility's SWPPP. EPA also discussed with Mr. Olson the Stormwater Pollution Prevention Team listed in Section 2.0 of the SWPPP. EPA then learned that both Guy Bunnel and Janet Brill were no longer employed at the facility but were still listed within the Stormwater Pollution Prevention Team. On May 19, 2025, Mr. Olson emailed Mr. Middleton an updated Stormwater Pollution Prevention Team. 8 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 After the inspection, EPA reviewed the facility's SWPPP, any additional concerns with the SWPPP that were observed during EPA's review are tabulated within the areas of concern below. Other Items Discussed: - Mr. Olson is the TLB employee that is responsible for compliance with the Stormwater Permit at this facility. - Some fuel is stored onsite in a 500-gallon tank, located near the loading dock area. Mr. Olson indicated that a private company fills the facility's equipment with fuel afterhours with mobile fuel tanks. - No salt is applied onsite as a deicer during the winter months. - Employees are trained on cleaning up spilled materials, with spill kits located within the facility's equipment. - Mr. Olson indicated to EPA that the discharged grinded wood onsite would act as an absorbant for stormwater or any liquid spills. - Facility did not have a sign in a visible public facing location with its NPDES Permit information listed, as required by Part 1.3.5 of the Stormwater Permit. Facility Walk-Through At approximately 10:30 am, Mr. Middleton, Mr. Nguyen, Mr. Small, and Mr. Olson began a walk-through of the facility, starting with the indoor shop area, located to the north of the office. The EPA inspection team observed the storage location of totes containing the mulch colorizer dye in the shop (Photograph 3 in Attachment A). Mr. Olson indicated that the facility dyes mulch red, brown and black with brown being the most popular color. EPA and Mr. Olson then walked to the north inside the shop to the loading dock stormwater pump located in a sump near the loading dock (Photograph 4 in Attachment A). As previously mentioned, this pump conveys stormwater to the County C roadside ditch west of the facility. EPA and Mr. Olson then walked outside to observe the loading dock (Photograph 7 in Attachment A). EPA observed the drain that is near the building in the loading dock that is connected to the dock stormwater pump. Next, EPA walked past the fuel tank locations and onsite dumpsters (Photograph 5 and 6 in Attachment A). Note the lid for both dumpsters were open at the time of the inspection. Next, EPA and Mr. Olson walked to the northeast to the facility's low elevation at the northeast corner of the site. When arriving at the northeast corner of the facility, EPA observed the north perimeter stormwater ditch (Photograph 8, 9, and 10 in Attachment A). At this location, EPA did not observe any stormwater erosion or any other evidence that would identify a point stormwater discharge to the north perimeter stormwater ditch. Photograph 9 in Attachment A shows a hydraulic connection from the north property. Mr. Olson indicated to EPA that during heavy precipitation, stormwater runoff from the north property will flow onto the facility and then into the north perimeter stormwater ditch. EPA and Mr. Olson then walked to a trailer 9 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 storage area in the northeast corner of the site. Mr. Olson indicated to EPA that in the Fall of 2024, the facility began burying cement blocks in this area to allow the trailers being stored here not to be stuck in the mud during wet periods. EPA and Mr. Olson then viewed and discussed the property north of the facility (Photographs 11 and 12 in Attachment A). EPA and Mr. Olson then continued walking to the south on the east facility property boundary. Near the area on the site map where Discharge Point F was identified, EPA and Mr. Olson stopped to observe this area (Photograph 13 in Attachment A). A large storage pile of natural grinded mulch was stored in this area (the pile on the left in Photograph 2 in Attachment A). Next, EPA and Mr. Olson walked to the south in the center of the facility to the colorizer mulch unit (Photograph 1, 14, and 15 in Attachment A). At the colorizer mulch unit, EPA observed a tote of dye that was next to the colorizer mulch unit with uncolored mulch being loaded into the unit by a front loader. Mr. Olson explained that the pumped discharge from the colorizer mulch unit is located underneath the center of the unit and will only discharge when stormwater flows into the drain. At the time of the inspection, the facility was dyeing mulch brown. This dyed mulch would be then stored into one of three bins located west of the colorizer mulch unit, based on the color of the mulch. EPA and Mr. Olson then walked to the east back to the east facility property boundary. While walking to the east facility property boundary, Mr. Olson pointed out the machinery used to make animal bedding in this location, including grinding machines and the metal/wood separator that ensures that any metal (e.g. nails) in grinded pallets or recycled wood is not within the final animal bedding product. Mr. Olson also showed EPA the different animal bedding products, with some of the high-grade animal bedding product stored under a covered unit (Photograph 16 in Attachment A). Near this location at the east property boundary, in the area on the site map where Stormwater Discharge Point E is labeled, EPA observed areas where there was some evidence of wood products that been transported offsite (Photograph 18 in Attachment A). An aerial map of the site appears to show a potential discharge offsite that is within a channel through the property east of the facility, originating at the facility. EPA was not able to clearly observe this potential discharge point from the facility, along the east property boundary, due to the tall grasses within the offsite area to the east. EPA and Mr. Olson then turned around and walked to the southwest. During this walk, EPA walked past a #2 waste wood storage pile that continued mostly pallets that was used for some products (Photograph 19 in Attachment A). Then EPA and Mr. Olson reached the bark storage pile on the south side of the facility (Photograph 20 in Attachment A). EPA observed the south boundary of the facility (Photograph 24 in Attachment A) and did not observe any stormwater erosion or any other evidence that would identify a stormwater discharge from the facility offsite to the south. Next, EPA and Mr. Olson walked to the west to view the County C roadside ditch. Photographs 22 and 23 in Attachment A show the County C roadside ditch upstream and downstream from 10 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 the facility's south entrance. There are two entrances to the facility that cross-over the County C roadside ditch with a culvert connecting the County C roadside ditch under the facility entrances. Mr. Olson told EPA that in the Fall in 2024, the Outagamie County Highway Department cut all of the vegetation in the County C roadside ditch. Not all of the discarded vegetation was removed after this cutting and Mr. Olson was concerned that the vegetation would cause clogging in the culverts. EPA and Mr. Olson walked to the southwest corner of the site to look at the County C roadside ditch and then walked north along the ditch. Approximately 250 feet north of the south entrance to the facility, EPA inspectors observed the colorizer unit discharge location on the east side of the roadside ditch. During the inspection, a discharge did not occur from the colorizer unit when EPA was observing this location. At the discharge location, it appears that the vegetation around the discharge pipe was stained a dark brown color (Photographs 26, 27, and 28 in Attachment A). About 225 feet north from the colorizer unit discharge, EPA observed the discharge location from the loading dock stormwater pump on the east side of the County C roadside ditch. During the inspection, a discharge did not occur from the loading dock stormwater pump when EPA was at this location. EPA was unable to see the exact discharge location, given that the discharge pipe was covered by vegetation and submerged. EPA and Mr. Olson then continued to walk north along the roadside ditch to the facility's north entrance. EPA then observed the County C roadside ditch at the north entrance, both upstream and downstream of the entrance (Photographs 31 and 32 of Attachment A). EPA and Mr. Olson walked east along the north property perimeter stormwater ditch approximately to the point where EPA and the facility's started the perimeter walkthrough. EPA and Mr. Olson then walked back to the office to the south. Along the way while walking through the shop indoors, EPA observed the storage location of used chemicals in the shop (Photograph 34 in Attachment A). EPA finished its walk-through of the site at approximately 12:00 pm and walked back to the facility's conference room in the office for a closing conference. Closing Conference Mr. Middleton began the closing conference in the facility's conference room at approximately 12:05 pm. Mr. Middleton, Mr. Nguyen, Mr. Small, and Mr. Olson were all present for the closing conference. EPA then went over the preliminary concerns it found during its inspection, some of which are listed below. EPA also told Mr. Olson that it would develop an inspection report that summarized its inspection of this facility and anticipated that it would provide a copy of the report once it was finalized in approximately 60 days to the facility. EPA then answered Mr. Olson's questions related to the inspection and EPA confirmed that it had not obtained any information or taken any pictures that were considered CBI. The closing conference ended at approximately 12:25 pm. 11 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 EPA ended the inspection and exited the facility at approximately 12:30 pm. DOCUMENTS OBTAINED DURING THE INSPECTION: A. Facility Stormwater Benchmark Monitoring Results/DMR Data - 3rd Quarter 2021 to 2nd Quarter 2022 B. 2024 Facility Quarterly Visual Inspections C. 2024 Facility Routine Inspections DOCUMENTS OBTAINED AFTER THE INSPECTION: A. Updated Stormwater Pollution Prevention Team - Section 2.0 of the Stormwater Pollution Plan B. Picture of Facility's Stormwater Permit Coverage Sign AREAS OF CONCERN: EPA has identified ten areas of concern based on findings during the inspection of the TLB Wood Products facility and based on a post-inspection review of the information provided to EPA by facility representatives. An enumerated list of the areas of concern are listed below: 1. Stormwater Discharge Points and Sampling Location for Benchmark and Quarterly Visual Sampling: In the NOI, four stormwater discharge points were identified. During the inspection when discussing the onsite stormwater discharge points with Mr. Olson, six stormwater discharge points were discussed.2 During EPA's review of the SWPPP, EPA noted that there are eight stormwater discharge points identified in the facility's SWPPP site map. These discrepancies make assessing the facility's compliance with its benchmark monitoring and quarterly visual monitoring difficult. EPA has identified at least five locations within the facility that discharge stormwater offsite: North Perimeter Stormwater Ditch discharge to the County C roadway ditch Stormwater dock pump discharge to the County C roadway ditch Colorizer unit pump discharge to the County C roadway ditch South Perimeter Stormwater Ditch discharge to the County C roadway ditch East stormwater discharge to east offsite property (roughly Discharge Point E on the SWPPP site map) 2. Benchmark Monitoring: EPA learned during the inspection and during a review of submitted information after the review the following concerns about the facility's benchmark monitoring: 2 This also corresponds to a site map, that is different than the site map in the SWPPP, that was submitted with the SWPPP and NOI 12 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 a. It is unclear if the facility sampled at the correct stormwater discharge points during the benchmark monitoring period. From EPA's review after the inspection, the DMR submittal was set up to corresponded to the information in the facility's NOI. The facility should have sampled at one discharge point from Discharge Point 001/002/003 and then sample from Discharge Point 004, as identified in the NOI. EPA is not clear if the facility performed sampling in this manner. In addition, if the discharge points changed, as indicated in the SWPPP site map or the other revised site map, the facility should have submitted a revised NOI to EPA within 30 calendar days after the discharge point information changed, pursuant to Part 1.3.4.1 in the Stormwater Permit. b. The facility did not sample at Discharge Point 001/002/003 in the fourth quarter of 2021, due to the lack rainfall. Part 4.2.2.4 of the Stormwater Permit indicates that "when conditions prevent you from obtaining four samples in four consecutive quarters, you must continue monitoring until you have the four samples required for calculating your benchmark monitoring average." Since the facility did not submit any additional benchmark monitoring data for Discharge Point 001/002/003, the facility did not meet the requirements of Part 4.2.2.4 of the Stormwater Permit. c. EPA is concerned that the benchmark monitoring is currently being implemented in a manner inconsistent with the first-year benchmark monitoring; which includes the issues detailed in concerns #1, #2, and #3. 3. Preservation of Benchmark Monitoring Samples: Mr. Olson informed EPA that when the facility was performing benchmark monitoring sampling, it would obtain the samples in a five-gallon bucket. Then Mr. Olson would drive the samples, without being cooled, to the Badger Laboratories for sample analysis. The drive from the facility to Badger Laboratories, according to Google Maps, is approximately 25 minutes. Part 4.2 requires that the facility conduct its benchmark monitoring in year 1 and year 4 using analytical methods consistent with 40 C.F.R. Part 136. The following preservation requirements are necessary for the following parameters analyzed within the facility's benchmark monitoring: a. COD: cool to equal to or less than 6 Celsius; add sulfuric acid to lower pH to less than 2. b. TSS: cool to equal to or less than 6 Celsius. c. Zinc: add nitric acid to lower pH to less than 2 at least 24 hours prior to analysis. EPA's understanding is that the COD and TSS sample preservation requirements were not/are not being done for the facility's benchmark monitoring. In addition, it is unclear to EPA if the sampling preservation requirements for zinc were/are met. If the preservation of the benchmark monitoring sampling was not done correctly, pursuant to 40 C.F.R. Part 136, EPA would be concerned about accuracy of that sampling. 4. Housekeeping/Dumpster Issues: During the inspection, EPA observed that onsite dumpster lids near the loading dock were left open (see Photograph 5 and 6 in 13 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 Attachment A). Part 2.1.2.2.c of the Stormwater Permit requires that dumpster lids are closed when not in use. 5. Stormwater Permit Coverage Sign: Part 1.3.5 of the Stormwater Permit requires the facility to post a sign or other notice of your permit coverage at a safe, publicly accessible location in close proximity to your facility. This part of the Stormwater Permit also includes information that must be included in this sign or other notice. During the inspection, EPA did not observe a sign or other notice with this required information. On May 27, 2025, Mr. Olson sent EPA an email with a picture of its Stormwater Permit coverage sign that was placed at the north entrance of the facility. This Stormwater Permit coverage sign appears to meet the requirements of Part 1.3.5 of the Stormwater Permit. 6. Discolored Area Near Colorized Mulch Unit Pump Discharge: During the inspection, EPA observed the location where the colorized mulch unit pump discharged to the County C roadside ditch. The area around the location appeared to be stained a dark brown (Photograph 26 in Attachment A). EPA is concerned that the discharge from the colorized mulch unit could signify that stormwater pollution from this discharge point may be affecting the County C roadside ditch, due to the presence of color. Note that Part 3.2.2.5 of the Stormwater Permit would require corrective action procedures, pursuant to Part 5.1.1 of the Stormwater Permit, if a visual assessment of the stormwater pollution in the discharge, such as color. 7. Routine Inspections: After reviewing the facility's routine inspection documentation, it was not clear from the description/documentation that stormwater discharges were occuring during the time of the inspection. Part 3.1.6.4.a requires descriptions of any stormwater discharges that occur at the time of a routine inspection. 8. Quarterly Visual Assessments: a. Part 3.2.1. of the Stormwater Permit requires that the facility collect a stormwater sample from each discharge point (unless the discharge points are substantially identical). From the quarterly visual assessment of the stormwater discharge form, provided by the facility during the inspection, the facility only sampled at one or two of the discharge points per quarter. Even when accounting for the substantially identical discharge points, from the NOI, the facility did not conduct quarterly visual assessments at enough of the discharge points (based on the SWPPP site map/updated site map) or consistently at Discharge Point 004 (based on the NOI) in 2024. b. Part 3.2.2.1 of the Stormwater Permit requires the facility to make an assessment of a stormwater discharge sample in a clean, colorless glass/plastic container. During the inspection, EPA learned that Mr. Olson conducts the assessment using 14 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 a green-colored, semi-opaque 5-gallon plastic bucket, which is not a colorless container. Since the quarterly visual assessment procedures in Part 3.2.2.4 of the Stormwater Permit require a visual observation of the stormwater discharge sample, including the documentation of the color and the clarity of the stormwater, the use of a colorless container is important. c. Part 3.2.2.2 of the Stormwater Permit requires the facility to collect the quarterly visual assessment within the first 30 minutes of an actual discharge from a storm event. It is unclear from the quarterly visual assessment of the stormwater discharge form, provided by the facility during the inspection, meets this requirement. If the facility was not able to conduct the sample within 30 minutes, an explanation needs to be provided, pursuant to Part 3.2.3.7 of the Stormwater Permit (this line is left blank on many of the filled out 2024 quarterly visual assessment forms. d. Part 3.2.4.3 of the Stormwater Permit requires that the facility, if in an area that typically receives snow and if the facility receives snow at least once over a period of four quarters, perform at least one of the quarterly visual assessments during a snowmelt discharge event. EPA notes that within its review of the quarterly visual assessment information that was provided during the inspection that it does not appear that one of the 2024 quarterly visual assessment occurred during a snowmelt event. e. EPA is concerned that the stormwater discharge points are not representative of the correct number or location of the stormwater discharge points, pursuant to concern #1. 9. Stormwater Pollution Prevention Plan Review: After the inspection, EPA reviewed the SWPPP and compared it with the requirements in its Stormwater Permit. EPA has the following observations regarding the facility's SWPPP: a. Overall, there are a number of references to the facility's previous WNDR stormwater permit, which the facility is no longer covered under. b. The General Facility Information section at the beginning of the SWPPP is out of date, with the permit number referring to the previous WDNR permit number, the previous stormwater outfalls identified as 4 outfalls, and the Erika Seidler listed as the facility contact. c. Part 6.2.5.1 of the Stormwater Permit includes the requirement to develop a schedule, or the convention used to determine when good housekeeping and preventative maintenance is required. The facility's SWPPP Good Housekeeping and Preventive Maintenance sections identify the tasks, but no corresponding schedule. d. The employee training section in the facility's SWPPP includes a description of the facility's employee training. Since the Stormwater Pollution Prevention Team is not current, it is unclear if the employee training has been kept up to date, pursuant to Part 2.1.2.8 of the Stormwater Permit. 15 TLB Wood Products, LLC (WIR05IA00) - April 29, 2025 e. Part 6.2.2.3 of the Stormwater Permit requires that the facility provide a site map in its SWPPP. After reviewing the site map in the SWPPP, EPA notes that following required elements are missing from the current site map: i. The boundaries of the property and size of the property in acres is not included (6.2.2.3.a); ii. The location and extent of impervious surfaces is not shown (6.2.2.3.b); iii. The location of the northern/southern perimeter stormwater ditches, the dock pump discharge and the colorizer discharge are not shown (6.2.2.3.f); iv. The location of 8 stormwater monitoring points/discharge points are identified, instead of the number identified in the facility's NOI (6.2.2.3.i and j). v. The location of the fuel storage tanks and grinding machinery (6.2.2.3.m). f. Section 3.3 of the facility's SWPPP includes an inventory of potential sources of contamination. The discharge from the colorizer is not identified specifically within this list of contamination, as required in Part 2.1.1.3 of the Stormwater Permit. g. Section 4.0 of the facility's SWPPP incorporates the facility's Spill Control and Countermeasures Requirement by reference. This plan should also be included as an attachment to the SWPPP. h. It is unclear how the bulk storage will be managed within the referred best management practices (BMPs). i. The annual facility site compliance inspection and the quarterly visual monitoring section in the SWPPP has information that pertains to the WNDR stormwater permit and not the EPA Stormwater Permit. j. The annual chemical stormwater sampling section in the SWPPP does not reflect the benchmark monitoring requirements in Part 4.2.2. of the Stormwater Permit. k. EPA is unclear about the meaning of the implementation schedule section in the SWPPP. l. Part 6.2.2.2 of the Stormwater Permit requires the facility to include a general location map (e.g. an U.S. Geological Survey quadrangle map) with enough detail to identify the location of the facility and all receiving water for the stormwater discharges. The facility's current SWPPP does not include a general location map that meets this requirement. 10. Offsite Stormwater from North Property: During the inspection, EPA observed the potential for stormwater flow from the north adjacent property to flow onto the facility's site/north perimeter stormwater ditch. If stormwater from the property to the north does flow onto the facility's site and there are significant quantities of pollutants in the stormwater run-on, the facility needs to include the location of this flow in the SWPPP site map, pursuant to Part 6.2.2.3.m(x) of the Stormwater Permit. LIST OF ATTACHMENTS: A. Photograph Log 16 Attachment A: TLB Wood Products, LLC - Seymour, Wisconsin Inspection Photograph Log U.S. EPA Inspection - April 29, 2025 All photos taken by Keith Middleton, Environmental Engineer, U.S. EPA Camera: Canon PowerShot SX230 HS 1: IMG_1173 Description: Colorizer and Finished Mulch Piles Location: TLB Wood Products - Office Camera Direction: North Date/Time: April 29, 2025 - 9:35 am CDT Page 1 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 2: IMG_1174 Description: Natural/Virgin Wood Pile Location: TLB Wood Products - Office Camera Direction: North Date/Time: April 29, 2025 - 10:19 am CDT 3: IMG_1175 Description: Wood Colorizer Dye Tote Storage Location: TLB Wood Products - Shop Camera Direction: N/A Date/Time: April 29, 2025 - 10:35 am CDT Page 2 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 4: IMG_1176 Description: Dock Stormwater Sump Pump Location: TLB Wood Products - Shop Camera Direction: N/A Date/Time: April 29, 2025 - 10:37 am CDT 5: IMG_1177 Description: Garbage Dumpster and Diesel Tanks Location: TLB Wood Products Camera Direction: Northeast Date/Time: April 29, 2025 - 10:41 am CDT Page 3 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 6: IMG_1078 Description: Garbage Dumpster and Diesel Tanks (2) Location: TLB Wood Products Camera Direction: North Date/Time: April 29, 2025 - 10:41 am CDT 7: IMG_1079 Description: Loading Dock Location: TLB Wood Products Camera Direction: West Date/Time: April 29, 2025 - 10:42 am CDT Page 4 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 8: IMG_1180 Description: North Perimeter Stormwater Ditch Location: TLB Wood Products Camera Direction: West Date/Time: April 29, 2025 - 10:45 am CDT 9: IMG_1181 Description: Northeast Corner of the Facility's Site and the Start of the North Perimeter Stormwater Ditch Location: TLB Wood Products Camera Direction: Northeast Date/Time: April 29, 2025 - 10:47 am CDT Page 5 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 10: IMG_1182 Description: Facility's Northern Property Line and the Start of the North Perimeter Stormwater Ditch Location: TLB Wood Products Camera Direction: West Date/Time: April 29, 2025 - 10:49 am CDT 11: IMG_1183 Description: Facility's Eastern Property Line Location: TLB Wood Products Camera Direction: South Date/Time: April 29, 2025 - 10:49 am CDT Page 6 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 12: IMG_1184 Description: Looking Towards the Facility's Northeast Corner Location: TLB Wood Products Camera Direction: North Date/Time: April 29, 2025 - 10:57 am CDT 13: IMG_1185 Description: Facility's Eastern Property Line; near Stormwater Discharge Point F Location: TLB Wood Products Camera Direction: South Date/Time: April 29, 2025 - 10:58 am CDT Page 7 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 14: IMG_1186 Description: Colorizer Unit Location: TLB Wood Products Camera Direction: Southwest Date/Time: April 29, 2025 - 11:03 am CDT 15: IMG_1187 Description: Colorizer Being Loaded with Mulch Location: TLB Wood Products Camera Direction: West Date/Time: April 29, 2025 - 11:06 am CDT Page 8 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 16: IMG_1188 Description: Covered Animal Bedding Produced Location: TLB Wood Products Camera Direction: Southeast Date/Time: April 29, 2025 - 11:08 am CDT 17: IMG_1189 Description: Eastern Property Boundary; Further South Near Bedding Storage Location: TLB Wood Products Camera Direction: South Date/Time: April 29, 2025 - 11:09 am CDT Page 9 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 18: IMG_1190 Description: East Boundary of Facility; near Bedding Coverage Storage Area/Stormwater Discharge Point E Location: TLB Wood Products Camera Direction: East Date/Time: April 29, 2025 - 11:09 am CDT 19: IMG_1191 Description: #2 Waste Wood Storage Pile Location: TLB Wood Products Camera Direction: East Date/Time: April 29, 2025 - 11:10 am CDT Page 10 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 20: IMG_1192 Description: Bark Storage Pile Location: TLB Wood Products Camera Direction: South Date/Time: April 29, 2025 - 11:19 am CDT 21: IMG_1193 Description: TLB Wood Product Site; From South Boundary Location: TLB Wood Products Camera Direction: Northeast Date/Time: April 29, 2025 - 11:19 am CDT Page 11 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 22: IMG_1194 Description: Roadside Ditch; at Facility's South Entrance Location: TLB Wood Products Camera Direction: North Date/Time: April 29, 2025 - 11:22 am CDT 23: IMG_1195 Description: Roadside Ditch; at Facility's South Entrance Location: TLB Wood Products Camera Direction: South Date/Time: April 29, 2025 - 11:22 am CDT Page 12 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 24: IMG_1196 Description: South Boundary of the Facility Location: TLB Wood Products Camera Direction: East Date/Time: April 29, 2025 - 11:28 am CDT 25: IMG_1197 Description: Roadside Ditch; South Property Line Location: TLB Wood Products Camera Direction: Southwest Date/Time: April 29, 2025 - 11:28 am CDT Page 13 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 26: IMG_1198 Description: Colorizer Unit Discharge Location: TLB Wood Products Camera Direction: N/A Date/Time: April 29, 2025 - 11:36 am CDT 27: IMG_1199 Description: Roadside Ditch; South of Colorizer Unit Discharge Location: TLB Wood Products Camera Direction: South Date/Time: April 29, 2025 - 11:38 am CDT Page 14 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 28: IMG_1200 Description: Roadside Ditch; North of Colorizer Unit Discharge Location: TLB Wood Products Camera Direction: North Date/Time: April 29, 2025 - 11:38 am CDT 29: IMG_1201 Description: Dock Pump Discharge Location to Roadside Ditch Location: TLB Wood Products Camera Direction: N/A Date/Time: April 29, 2025 - 11:42 am CDT Page 15 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 30: IMG_1202 Description: Roadside Ditch; North Entrance/Culvert Location: TLB Wood Products Camera Direction: Northwest Date/Time: April 29, 2025 - 11:43 am CDT 31: IMG_1203 Description: Roadside Ditch; South of North Entrance Location: TLB Wood Products Camera Direction: South Date/Time: April 29, 2025 - 11:44 am CDT Page 16 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 32: IMG_1204 Description: Roadside Ditch; North of North Entrance (Upstream of Facility) Location: TLB Wood Products Camera Direction: North Date/Time: April 29, 2025 - 11:45 am CDT 33: IMG_1205 Description: North Property Perimeter Ditch Location: TLB Wood Products Camera Direction: East Date/Time: April 29, 2025 - 11:46 am CDT Page 17 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025 34: IMG_1206 Description: Storage Location of Chemicals in Shop Location: TLB Wood Products - Shop Camera Direction: N/A Date/Time: April 29, 2025 - 11:53 am CDT Page 18 TLB Wood Products, LLC - Seymour, Wisconsin April 29, 2025