Document ByaXwrd76pV1Xbr8442w0rmxj
Report Title: Inspection Date: Regulatory Program(s): Type of Activity: Site/Facility Name: Permittee(s): Site/Facility Operator: Site/Facility Address:
Latitude: County/Parish: Permit Number: NAICS Code: Unique Project #:
Clean Water Act Compliance Inspection Report
09/25/2024
National Pollutant Discharge Elimination System (NPDES)
Industrial Wastewater
Vibrantz Specialty Products
Vibrantz Specialty Products
Vibrantz Specialty Products
610 Pittman Road
Baltimore Maryland, 21226
39.19469
Longitude: -76.56416
Anne Arundel
MD0001775
325180
SIC: 2819
ECAD-523
Site/Facility Representative(s): Bryan Jenkins Phone: (410) 375-1054 Sophia Li Phone: (610) 618-6350
Email: Email:
Point of Contact
Bryan.Jenkins@Vibrantz.com
Sophia.Li@Vibrantz.com
EPA Inspectors: Shane McAleer Phone: (215) 814-5616 Brian Tolton Phone: (215) 814-3291
State/Local Inspectors: Wendy Huang Phone: (410) 537-3526
Email: Mcaleer.Shane@EPA.gov Email: Tolton.Brian@EPA.gov
Email: Wendy.Huang@maryland.gov
Report Preparer Signature/Date
Supervisor Signature/Date
BRIAN TOLTON
Digitally signed by BRIAN TOLTON Date: 2024.12.02 11:14:16 -05'00'
Brian Tolton, Physical Scientist
3ED33
JESSICA
Digitally signed by JESSICA DUFFY
DUFFY
Date: 2024.12.02 10:57:43 -05'00'
Jessica Duffy, NPDES Section 2 Chief, 3ED33
Date Date
Unique Project#: ECAD-523
Section
Vibrantz Specialty Products Industrial Wastewater 09/25/2024
Table of Contents Page
I Introduction............................................................................................................... 3 A Inspection Opening Conference...................................................................... 3 B Weather and Precipitation Conditions............................................................ 4 C Summary of the Facility................................................................................... 4
II Facility Activity............................................................................................... 5
III Observations.................................................................................................... 6
IV Records Review............................................................................................... 6
V Closing Conference......................................................................................... 7
VI List of Attachments.......................................................................................... 8
Unique Project #: ECAD-523
Page 2 of 8
I. Introduction
Vibrantz Specialty Products Industrial Wastewater 09/25/2024
On September 25, 2024, an inspection team composed of staff from the U.S. Environmental Protection Agency ("EPA") Region III (hereinafter, referred to as the "EPA Inspection Team") and a representative of the Maryland Department of the Environment ("MDE") conducted an industrial wastewater inspection of the Vibrantz Specialty Products LLC facility (hereinafter, "the facility"). The purpose of the inspection was to observe compliance with the Clean Water Act (CWA) and to verify compliance with the facility's National Pollutant Discharge Elimination System (NPDES) Permit No. MD0001775 (hereinafter, the "Permit") and applicable State and Federal regulations. The EPA Inspection Team performed a concurrent industrial stormwater compliance evaluation inspection; however, the following inspection report covers the industrial wastewater inspection only.
A. Inspection Opening Conference
The EPA Inspection Team arrived at the site at est. 10:30 AM for the inspection. Inspectors met with the following facility representatives:
Name
Shane McAleer Brian Tolton
Bryan Jenkins Sophia Li
Adam Bates Doug
Crawford
Wendy Huang
Table 1: Inspection Attendee List
Affiliation
Telephone
Email
EPA Region III Inspectors and Contractors
EPA Inspector
(215) 814-5616
Mcaleer.Shane@EPA.gov
EPA Inspector
Vibrantz Vibrantz Vibrantz Vibrantz
(215) 814-3291 Site/Facility Representatives
(410) 375-1054 (610) 618-6350 (410) 672-9110 (410) 636-7155
Tolton.Brian@EPA.gov
Bryan.Jenkins@Vibrantz.com Sophia.Li@Vibrantz.com
Adam.Bates@Vibrantz.com Doug.Crawford@Vibrantz.com
State or County Representatives
MDE
(443) 934-7737
Wendy.Huang@Maryland.gov
The EPA inspection team displayed their credentials to the facility operator, Vibrantz, at the outset of the inspection, and explained the purpose of the inspection was to observe compliance with its Permit. A copy of the Permit is provided in Attachment 1. The EPA Inspection Team informed the Operator that any information that the Facility deemed to be confidential business information ("CBI") should be identified to EPA representatives during the inspection and it would be handled as CBI according to EPA's CBI procedures.
Unique Project #: ECAD-523
Page 3 of 8
B. Weather and Precipitation Conditions
Vibrantz Specialty Products Industrial Wastewater 09/25/2024
During the inspection, weather was overcast, around 70 F. National Oceanic and Atmospheric Administration (NOAA) National Weather Service precipitation data for the date of the inspection and 5 days prior are provided in the Table 2 below:
Table 2. Precipitation Data
Station Name
Date
Baltimore Washington International Airport MD US (USW00093721)
Baltimore Washington International Airport MD US (USW00093721)
Baltimore Washington International Airport MD US (USW00093721)
Baltimore Washington International Airport MD US (USW00093721)
Baltimore Washington International Airport MD US (USW00093721)
Baltimore Washington International Airport MD US (USW00093721)
9/20/2024 9/21/2024 9/22/2024 9/23/2024 9/24/2024
9/25/2024
Precipitation Amount (inches)1
0.00
0.03
0.27
0.11
0.07
0.19
C. Summary of the Facility
Vibrantz Specialty Products, LLC (formerly Erachem-Comilog and Prince Specialty Products, LLC) owns and operates their Baltimore manganese refining facility located on a 70-acre site bounded on the east and north by the Patapsco River and on the west by Curtis Creek. The facility is engaged in multiple types of processes for the manufacturing of over forty manganese products, including manganese chloride, manganese nitrate, manganese dioxide, manganous dioxide, lithium manganese oxide, manganous manganic oxide, manganese sesquioxide, manganese carbonate, nitrided ferromanganese, and nitrided manganese. The facility processes high-purity manganese ores (mainly from Africa) and byproducts into manganesebased products for use as metals alloys, animal feeds, fertilizers, electronics, steel, etc. Operations are continuous, seven days a week, 365 days a year. Operators work 12-hour shifts. Approximately 80% of the property is within the "main basin" where stormwater runoff along with process wastewater, non-contact cooling water (NCCW), and equipment wash water is conveyed to and treated at the onsite industrial wastewater treatment plant (IWTP), which discharges via Outfall 001 to Curtis Creek. The water collected in the "main basin" is either
1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/).
Unique Project #: ECAD-523
Page 4 of 8
Vibrantz Specialty Products Industrial Wastewater 09/25/2024
recycled back through the facility or is treated at the IWTP. The IWTP process includes pH adjustment, precipitation, oxidation, filtration and chemical addition of hydrated lime.
II. Facility Activity
During the inspection, the EPA Inspection Team observed: the manganese process buildings, exterior of the buildings, stockpiles, cooling towers, detention basins, IWTP, and in-house laboratory. The EPA Inspection Team was escorted around the Facility by representatives from Vibrantz who described the manganese production process. A photolog is provided in Attachment 2 of photographs taken by the EPA Inspection Team. There are two manganese ore stockpiles that are covered and stored on the west side of the property (Photo 1). The manganese ore is then transported to different buildings depending on what manganese byproduct is being manufactured. The solid waste left over from the refinery process, referred to as "gangue", is placed in stockpiles near the northwest portion of the facility (Photo 4), where it awaits hauling via truck offsite for disposal. The EPA inspection team were also escorted through each facility building to observe each step of the manganese refining process. Process and equipment wash waters typically get pumped to designated collection areas within each building. The collected wastewater is either recycled or pumped to the IWTP. The IWTP treatment processes consist of pH adjustment, precipitation, oxidation, filtration and chemical addition of hydrated lime (Photos 8 and 11 through 14). Treated industrial wastewater effluent from the IWTP is conveyed through an underground 4-inch pipe that runs southwest under the facility, under the adjacent U.S Coast Guard property, and discharges through a single-port diffuser at Outfall 001 to Curtis Creek below the water surface. The outfall was not observed during the inspection. An ISCO 4700 automated composite sampler collects a 24-hour flow proportional sample of the IWTP effluent (Photo 21 and 22). The composite sample is picked up by a Microbac courier every Tuesday and Thursday. A schematic diagram of the IWTP process is provided in Attachment 4.
There is a drain collection system that captures stormwater and potential spills from between the main production area buildings (Photo 9). Stormwater in this area flows to a sump where it gets pumped (Photo 10) to a 20,000-gallon storage tank at the IWTP(Photo 13). At the north end of the facility there is a 6,000-gallon sump (the main basin sump, see Photos 16 and 18) that collects stormwater and gets pumped to a 410,000-gallon storage tank (referred to as the mother of all tanks, or MOAT, Photo 15). The stormwater and process water collected in both the 20,000-gallon storage tank and the MOAT is fed over an extended period to the IWTP and treated as capacity allows. If stormwater from the main basin exceeds the sump capacity or that of the MOAT during a large precipitation event, stormwater overflows into a vegetated channel and is conveyed to three large stormwater detention basins (Photo 19), which discharge via Outfall 003 to an unnamed tributary to the Patapsco River.
Unique Project #: ECAD-523
Page 5 of 8
Vibrantz Specialty Products Industrial Wastewater 09/25/2024
III. Observations
Permit requirement Part II section B.8.a
8. POWER FAILURE In order to maintain compliance with the effluent limitations and prohibitions of this permit, the permittee shall either:
a. provide an alternative power source sufficient to operate the wastewater collection and treatment facilities or, b. halt, reduce or otherwise control production and all discharges upon the reduction, loss, or failure of the primary source of power to the wastewater collection and treatment facilities.
Observation 01:
The EPA Inspection team observed that the main basin sump did not have an alternative power source. See Attachment 3 for Vibrantz power contingency memo that was reviewed during records request process.
IV. Records Review
During the opening and closing conferences, the EPA Inspection Team indicated an EPA records request would be submitted to facility representatives after the inspection. The following records were requested by EPA, and provided by the Facility operator via email and the EPA file transfer website on November 4, 2024:
Current Industrial wastewater permit Information on the disposal of any removed substances (Permit Section I. Special
Condition D) Hauling manifests for gangue waste Analytical laboratory Reports (Permit Section I. Special Condition E) Wastewater Operator Certification (Permit Section I. Special Condition F) A description of the methodology used to estimate flow (Permit Section I. Special
Condition G) Best Management Practices (BMPs) plan (Permit Section I. Special Condition T) Power Failure Contingency (Permit Section I. B. 8) DMRs (2022-2024) Lab tech Sample forms with temperature readings Direct Flow readings (pH, Turbidity etc) (2024).
Unique Project #: ECAD-523
Page 6 of 8
Vibrantz Specialty Products Industrial Wastewater 09/25/2024
Vibrantz provided a letter memo agreeing to send all requested records. All records requested were uploaded to the EPA portal as outlined in the memo. Vibrantz records request memo can be found in Attachment 5. Due to amount of requested records, they will not be included in this inspection report.
V. Closing Conference
After the facility walk, the EPA Inspection Team met with the facility representatives for a closing conference. The EPA Inspection Team shared preliminary observations with the facility. The EPA Inspection Team reiterated to the facility representatives that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by EPA upon the additional review of records and documentation. Additional observations may be contained in this inspection report that were not identified at the time of the closing conference after EPA reviewed additional materials following the inspection.
The inspection concluded at 14:30
Unique Project #: ECAD-523
Page 7 of 8
VI. List of Attachments
Vibrantz Specialty Products Industrial Wastewater 09/25/2024
Attachment 1: Attachment 2: Attachment 3: Attachment 4: Attachment 5:
NPDES Permit (MD0001775) Photograph Log Power Failure Contingency Memo IWTP Schematic Diagram Records Request Memo
Unique Project #: ECAD-523
Page 8 of 8
