Document By7k9E1rRq7GnRq9Ze4R5MoNE

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 May 31, 2024, 12:05 p.m. (CST) Announced: No May 31, 2024, 04:08 p.m. (CST) Access: Granted Sunny 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) Kinder Morgan Limestone Storage Area, Bottom Ash Storage Area, South Salt Domes, Main Terminal, Cargill Salt Pad Kinder Morgan Bulk Terminal/1225 S. Carferry Dr, 1235 S Carferry DR, 1601 S Carferry DR, 1900 S. Harbor, 1201 E. Bay Street. Milwaukee, WI 53207 Milwaukee William_Baines@Kindermorgan.com FRS ID Permit Number(s) (If Applicable) WIU000039, WIU000041, WIU000037, WIU000040 SIC and/or NAICS 4226 Lead Inspector: WILLIAM William Jones JONES Digitally signed by WILLIAM JONES Date: 2024.08.07 11:19:16 -05'00' EPA REGION 5 Jones.William@epa.gov (312) 886-6058 Supervisor Review: MOLLY Molly Smith SMITH Digitally signed by MOLLY SMITH Date: 2024.08.07 11:35:20 -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 Kinder Morgan Bulk Terminals (the "Site" or "Facility"), located at various addresses listed above all of which are located on the Port of Milwaukee in Milwaukee, Wisconsin at 12:05 p.m. (CST) on May 31, 2024, for an unannounced inspection. EPA Region 5 Lead Inspector presented credentials to William Baines and informed him that this was an EPA Region 5 inspection to 1 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 investigate elements as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. This report is based on information supplied by Kinder Morgan representatives, direct 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 Kinder Morgan 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 Kinder Morgan representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to 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 EPA Region 5 Wisconsin DNR Wisconsin DNR Port of Milwaukee Kinder Morgan Attendee Name William Jones Andi Hodaj Jamie Lambert Elexius Passante Brian Kasprzyk William Baines IV Facility/Site Description Title Lead Inspector Environmental Engineer Wastewater Specialist Senior Chief Engineer Operations Manager MBT Present in Opening Conf. Yes Yes Yes Yes Yes Yes Present in Closing Conf. Yes Yes Yes No No Yes EPA REGION 5 lead inspector confirmed the following facility information: Facility/Site Information Location(s) Location/Area/Sub-area Limestone pile/parcel 8 Bottom ash area/open dock Salt Dome area/parcel 31 Salt pile adjacent to salt dome area/parcel 32 Salt pile on parcel 17 Storm drain inlet on S. Harbor Drive, and parcel 1/3 area Description Area where limestone can be loaded onto ships via a conveyor Area where bottom ash is stored Location of two salt domes Area where salt is stored uncovered Salt pile and ditch on west side of salt pile This is an inlet on S. Harbor drive and inlets that are in the parcels 1 and 3 area. SECTION II - OBSERVATIONS Location: Limestone pile/parcel 8 Observation #: WJ1-OB-001 Date: May 31, 2024 Weather: Sunny 2 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 EPA observed the pebble limestone pile and conveyor where it is loaded onto ships. EPA observed the limestone piled up to the edge of the Kinnickinnic River under the conveyor. Photos 1 to 2 Location: Bottom Ash Area/open dock Observation #: WJ1-OB-002 Date: May 31, 2024 Weather: Sunny EPA observed Bottom Ash stored in this area along the river. EPA observed that the concrete jersey barriers were not containing the ash, and ash was outside of the barriers nearby the Kinnickinnic River. EPA observed that the inlet protection, by the orange cone, was not completely covering the inlet, and the piles of ash were uncovered/exposed. EPA observed ash mixed into the storm water that was ponded and appeared to have drained to the inlet, by the orange cone, that leads to the Kinnickinnic River, according to the stormwater pollution prevention plan (SWPPP). Photos 3 to 11 Location: Salt dome area/parcel 31 Observation #: WJ1-OB-003 Date: May 31, 2024 Weather: Sunny EPA observed two salt domes in this area. EPA observed that some of the salt had spilled outside of the salt dome. EPA observed salt-stained ground, up to the edge of the site, and the Kinnickinnic River. Photos 12 to 17 Location: Salt pile adjacent to salt pile area/parcel 32 Observation #: WJ1-OB-004 Date: May 31, 2024 Weather: Sunny EPA observed salt staining on the ground leading to the Kinnickinnic River. Photos 18 to 20 Location: Salt pile on parcel 17 Observation #: WJ1-OB-005 Date: May 31, 2024 Weather: Sunny EPA observed a hole in the tarp covering the salt pile, and water appeared to have washed the salt off the pile, in the area below the hole, and it had stained the pavement and street nearby. Photos 21 to 27 3 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Location: Storm drain inlet on S. Harbor Drive, and parcel 1/3 area Observation #: WJ1-OB-006 Date: May 31, 2024 Weather: Sunny EPA observed that the facility's best management practices, at the time of the inspection, have not been effective in keeping the salt from entering the inlet on S. Harbor Drive. Also, the salt pile on parcel 3 is nearby two inlets; however, the SWPPP states that these inlets lead to the combined sewer. The SWPPP does not show the blueish green colored plastic pipe with slits cut into the bottom. At the time of the inspection, it was not clear if this also drains to the combined sewer. Photos 27 to 32 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: No Reviewed Date: July 31, 2024 The SWPPP did not identify the blueish green pipe, shown in photograph 32. Additionally, the SWPP did not identify where storm water enters this pipe and where it goes, i.e. storm or combined sewer. SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION V - AREAS OF CONCERN It was unclear at the time of the inspection if the bottom ash storage, identified in Kinder Morgan's SWPPP as parcel 2 (1235 S. Carferry Drive), is covered by an industrial stormwater permit. During the inspection, the filter fabric was not adequately covering the inlets, and material has piled along the river. Additionally, at the time of the inspection, bottom ash was being used to hold down the fabric on top of the jersey barriers, which does not help to contain the bottom ash. During the inspection, the inspectors witnessed salt that was not completely covered in several areas, which has led to salt blowouts, salt staining on the roadway, and salt entering the storm sewer on S. Harbor Drive. Salt was also observed outside of the salt storage buildings. EPA observed salt staining the Kinnickinnic River. EPA observed poor housekeeping and a lack of clean-up of the spilled salt. At the time of the inspection the SWPPP was not updated to show the additional storm drain inlet at the ash storage area. Also, the blueish-green pipe identified by EPA inspectors during the inspection was not investigated to determine if this is an inlet for storm water, where it goes to, nor is it included in the SWPPP. Terminal 4 and 4a - at the time of the inspection it was unclear if the interior building drains are connected to the storm drain system. The facility was unaware. See above observations in section II and III related to the areas of concern. 4 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA REGION 5 Lead Inspector held a closing conference with Facility personnel at 03:10 p.m. on May 31, 2024, 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 Andi Hodaj, Jamie Lambert and Will Baines, 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: Lime storage area - the unloading of material appears to have spilled material at the edge of the river. Plumbing for Terminal 4a and 4 (1500 S. Lincoln Memorial Drive) - Unknown if the indoor plumbing is connected to the storm water system. Inlet by the cruise ship/ash storage area - Unknown if the inlet is connected to the storm sewer system. The inlet is not being inspected. Also, material was observed along the edge of the river. Ash storage area - The berm around the ash storage pile is not adequate to keep the ash from entering the drain and being transported to the river. EPA inspectors observed an inlet in the bottom ash storage pile area, identified with a cone, that is not on the SWPPP maps, nor was it clear at the time of the inspection where this goes to. During the inspection, EPA inspectors observed salt leading to the river and corroding the metal pilings in the area south of the salt domes. At the time of the inspection, inspectors observed salt staining that had created a trail to the river, at the Compass site. At parcel 17, inspectors observed a salt blowout that led to salt reaching the roadway. Inspectors observed the storm inlet along S. Harbor Drive (see photos), which had a salt-stained trail leading to it and was heavily corroded during the inspection. EPA inspectors noted that the scale at 1900 S. Harbor has an inlet by it that receives storm water with salt, but it is unclear at the time of the inspection where the bluish green inlet pipe connects to. Additionally, inspectors noted the salt pile was uncovered nearby. EPA inspectors noted an insufficient berm around the salt pile on parcel 5 and 6. Follow Up No information was requested by the inspector to be shared after the inspection. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 3. Port of Milwaukee Parcel map 5 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: APPENDIX 1: PHOTO LOG 5-31-2024 6 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 1. Small pile of limestone and conveyor at parcel 8. May 31, 2024/1:00 p.m. No PII Port of Milwaukee Parcel 8. North-west IMGP0001.JPG Photographer: William Jones 7 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 2. Limestone material at edge of parcel 8 under the conveyor. The material is piled up to the top edge of the pilings along the Kinnickinnic river. May 31, 2024/1:02 p.m. No PII Port of Milwaukee Parcel 8 IMGP0002.JPG Photographer: William Jones Camera Direction: West 8 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Area just north of the bottom ash pad. The inlet has a cloth filter and sediment has accumulated around the inlet. May 31, 2024/1:19 p.m. No PII Port of Milwaukee parcel A open dock area Camera Direction: North IMGP0003.JPG Photographer: William Jones 9 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 4. Area just north of the bottom ash pad. IMGP0004.JPG The inlet has a cloth filter and sediment has accumulated around the inlet. This is also shown in photograph 3. May 31, 2024/1:19 p.m. No PII Photographer: William Jones Port of Milwaukee parcel A open dock area Camera Direction: Down 10 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photo 5. Bottom ash stored next to Kinnickinnic River. Ash is not contained within the barriers and is located on the edge of the river. May 31, 2024/1:25 p.m. No PII Port of Milwaukee Parcel A open dock area View looking South IMGP0005.JPG Photographer: William Jones 11 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 6. Bottom Ash pile along the river. The orange cone sits on top of a catch basin. It appears that rain water ponds in the area as can been seen by the water marks on the ash piles. The piles are uncovered. May 31, 2024/1:35 p.m. No PII IMGP0006.JPG Photographer: William Jones Port of Milwaukee parcel A open dock area. View looking North 12 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 7. Close up of orange cone shown in photograph 6 and area surrounding it. The catch basin inlet can be seen below the orange cone. Filter fabric does not completely cover the inlet. IMGP0007.JPG May 31, 2024/1:36 p.m. No PII Port of Milwaukee parcel A open dock area. View looking down Photographer: William Jones 13 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 8. Close up of catch basin inlet shown in photograph 7 and area surrounding it. Filter fabric does not completely cover the inlet. May 31, 2024/1:36 p.m. No PII Port of Milwaukee Parcel A open dock area View looking down IMGP0008.JPG Photographer: William Jones 14 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 9. Bottom Ash pile along the river. The orange cone sits on top of a catch basin. It appears that rain water ponds in the area as can been seen by the water marks on the ash piles. This area is also shown in photographs 6-8. May 31, 2024/1:37 p.m. No PII Port of Milwaukee parcel A open dock area View looking north IMGP009.JPG Photographer: William Jones 15 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 10. Area showing pooled storm water with ash piles shown at top of photograph. These same ash piles are shown in photographs 6 and 9. It appears that water has flowed from the pooled water to the location of the orange cone in the past. May 31, 2024/1:41 p.m. No PII Port of Milwaukee parcel A open dock area View looking north IMGP0010.JPG Photographer: William Jones 16 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 11. Close up of ponded water in photo 10 in ash storage area. May 31, 2024/1:42 p.m. No PII Port of Milwaukee parcel A open dock area IMGP0011.JPG Photographer: William Jones View looking down 17 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 12. Salt on the ground between the salt domes and salt stored outside of the dome at the entrance to the dome. May 31, 2024/1:47 p.m. No PII Salt domes at Parcel 31 Looking Westerly IMGP0012.JPG Photographer: William Jones [Geographic Coordinates] 18 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 13. Salt on the ground between the salt domes. This area is also shown in photograph 12. May 31, 2024/1:50 p.m. No PII Port of Milwaukee Parcel 31 salt domes View looking Westerly IMGP0013.JPG Photographer: William Jones 19 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 14. Area west of the salt domes by the Kinnickinnic River. The grayish coloring on the pavement/ground appears to be salt. Holes were observed in the sheet pilings along the edge of the river. May 31, 2024/1:52 p.m. No PII Port of Milwaukee parcel 31 area View looking westerly IMGP0014.JPG Photographer: William Jones 20 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 15. Area along the Kinnickkninick River IMGP0015.JPG show in photograph 14. The metal sheet pilings appear corroded and have holes in them. May 31, 2024/1:53 p.m. No PII Port of Milwaukee parcel 31 along the waterfront. View looking Southerly Photographer: William Jones 21 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 16. View of sheet pilings shown in photograph 15 showing the holes and corrosion. May 31, 2024/1:53 p.m. No PII Port of Milwaukee lot 31 area along the Kinnickinnick River View looking westerly IMGP0016.JPG Photographer: William Jones 22 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 17. Closeup of area adjacent to salt domes showing ponded salt water May 31, 2024/1:58 p.m. No PII Port of Milwaukee parcel 31 area View looking easterly IMGP0017.JPG Photographer: William Jones 23 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photo 18. Shows a salt pile on the right side of the IMGP0018.JPG photograph and grayish white salt staining on the ground on the left side of the photograph leading to the river. May 31, 2024/2:03 p.m. No PII Photographer: William Jones Port of Milwaukee view of lot 32 View looking Northwest 24 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photo 19. Close up of salt staining in photograph 18 leading towards the river. Date/Time: May 31, 2024/2:04 p.m. No PII Port of Milwaukee view of parcel 32 with Kinnickinnic River in the background. View looking Northwesterly IMGP0019.JPG Photographer: William Jones 25 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 20. Closeup of the wall along the IMGP0020.JPG Kinnickinnic River showing erosion and holes in the wall leading to the river. This area is shown in photograph 19. May 31, 2024/2:05 p.m. No PII Photographer: William Jones Port of Milwaukee area along open dock near parcel 32. View looking westerly 26 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 21. Showing a structure with water flowing into it from a ditch on the east side of the salt pile located on parcel 17. The SWPPP indicates that this leads to the combined sewer. May 31, 2024/2:25 p.m. No PII Port of Milwaukee parcel 17. View looking southerly and down IMGP0021.JPG Photographer: William Jones 27 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 22. View of top of structure shown in photograph 21 and ditch on east side of salt pile. May 31, 2024/2:25 p.m. No PII Port of Milwaukee parcel 17 View looking south-west IMGP0022.JPG Photographer: William Jones 28 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 23. View of concrete structure shown in photograph 22 and 21. Salt staining can be seen on the ground in the center of the photograph May 31, 2024/2:28 p.m. No PII Port of Milwaukee parcel 17, north-west side of salt pile View looking south-west IMGP0023.JPG Photographer: William Jones Photograph 24. Salt water can be seen ponded on the north side of the salt pile with staining leading out towards the gate and onto the roadway. May 31, 2024/2:29 p.m. No PII Port of Milwaukee parcel 17 View looking westerly IMGP0024.JPG Photographer: William Jones 29 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 25. Salt water can be seen ponded on the north side of the salt pile with staining leading out towards the gate. This area is also shown in photograph 24. May 31, 2024/2:29 p.m. No PII Port of Milwaukee parcel 17 View looking westerly IMGP0025.JPG Photographer: William Jones 30 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 26. North side of the salt pile with staining shown in the gutter outside of the fenceline. Also see photograph 25. May 31, 2024/2:29 p.m. No PII Port of Milwaukee parcel 17 View looking northerly IMGP0026.JPG Photographer: William Jones Photograph 27. North side of salt pile showing area that has lost salt. IMGP0027.JPG The black plastic cover is also ripped open in the top right-hand side of the photograph. This appears to have allowed rainwater to go under the tarp and to wash salt off the pile and onto the pavement. May 31, 2024/2:34 p.m. No PII Photographer: William Jones Port of Milwaukee parcel 17 View looking southerly 31 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 28. Photograph of storm drain inlet between parcel 9 and IMGP0028.JPG S. Harbor Drive showing a salt trail leading to the storm drain inlet. The salt pile in the top middle of the photograph is uncovered along parcel 5. May 31, 2024/2:41 p.m. No PII Photographer: William Jones Port of Milwaukee along S. Harbor Drive along parcel 9 View looking southerly 32 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 29. Close-up of the storm drain inlet shown in photograph IMGP0029.JPG 28 showing the salt staining around the inlet and the corrosion. May 31, 2024/2:41 p.m. No PII Photographer: William Jones Port of Milwaukee along S. Harbor Drive along parcel 9 View looking down Photograph 30. Storm drain inlet near the scale and just north of salt pile on parcel 1. This is also shown in photograph 31. May 31, 2024/3:00 p.m. No PII 33 of 38 IMGP0030.JPG Photographer: William Jones Port of Milwaukee - Kinder Morgan Inspection Date: Port of Milwaukee parcel 1 and 3 View looking down 5-31-2024 Photograph 31. Storm drain inlet near scale just north of salt pile on parcel 3. The salt pile can been seen at the top of the photograph. Salt has stained the pavement and leads to the storm drain inlet. This is also shown in photograph 30. The SWPPP indicates that this drains to the combined sewer. May 31, 2024/3:00 p.m. No PII Port of Milwaukee parcels 1 and 3 View looking west IMGP0031.JPG Photographer: William Jones 34 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 Photograph 32. Riser pipe with slits at the bottom. The salt pile is uncovered next to the pipe. It is unknown where the pipe drains to. May 31, 2024/3:04 p.m. No PII Port of Milwaukee parcel 1 and 3 View looking westerly IMGP0032.JPG Photographer: William Jones 35 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: APPENDIX 2: DOCUMENT LOG 5-31-2024 Document Type SWPPP Document Name Storm Water Pollution Prevention Plan, Milwaukee Bulk Terminal, August 2022 Contains Contains Uploaded By CBI PII No No Date Received 5-31-2024 36 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: APPENDIX 3: Port of Milwaukee parcel map 5-31-2024 37 of 38 Port of Milwaukee - Kinder Morgan Inspection Date: 5-31-2024 38 of 38