Document DZDpzOJBDG7NN2R14bM8R4OO
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4
ATLANTA FEDERAL CENTER 61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
ELECTRONIC EMAIL CONFIRMATION OF EMAIL RECEIPT REQUESTED
Mr. Rick Baldwin Environmental Manager Challenge Richmond, LLC 110 Continental Drive Richmond, KY 40475 rbaldwin@challenge-mfg.com
Re: Compliance Evaluation Inspection Report NPDES Permit No. KY0074748
Dear Mr. Baldwin:
The U.S. Environmental Protection Agency Region 4 and the Kentucky Division of Water conducted a Compliance Evaluation Inspection of the Challenge Richmond, LLC industrial storm water system on July 27, 2021. The objective of the inspection was to assess the permittee's compliance with the Clean Water Act and to the National Pollutant Discharge System (NPDES) permit. The inspection results have been summarized in the enclosed Compliance Evaluation Inspection Report.
The EPA appreciates your cooperation. If you have specific questions about the inspection report, please contact Dennis Sayre at (404) 562-9756 or at Sayre.Dennis@epa.gov. Please verify receipt of this letter and report by emailing Mr. Sayre at the email address provided.
Sincerely,
JAIRO CASTILLO
Digitally signed by JAIRO CASTILLO Date: 2021.09.29 16:02:55 -04'00'
Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch
Enclosure
cc: Constance Coy, constance.coy@ky.gov Kentucky Division of Water
Internet Address (URL) http://www.epa.gov
United States Environmental Protection Agency Region 4 Enforcement and Compliance Assurance Division Water Enforcement Branch 61 Forsyth Street, SW Atlanta, Georgia 30303
Compliance Evaluation Inspection Report Challenge Richmond, LLC NPDES Permit: KY0074748
Project No. CV-KY0074748-072721 110 Continental Drive Richmond, KY 40475
Inspection Date: July 27, 2021 Inspector:
Dennis Sayre, EPA Region 4
Inspection Report Prepared by: Dennis Sayre September 3, 2021
Approval Sheet Title: Compliance Evaluation Inspection Challenge Richmond, LLC
Approving Official:
JAIRO CASTILLO
Digitally signed by JAIRO CASTILLO Date: 2021.09.29 16:02:27 -04'00'
Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch
9/29/2021 Date
Enforcement Officer:
DENNIS SAYRE
Digitally signed by DENNIS SAYRE Date: 2021.09.29 16:15:14 -04'00'
Dennis Sayre, Environmental Engineer Wastewater Enforcement Section Water Enforcement Branch
9/29/2021 Date
` COMPLIANCE EVALUATION INSPECTION REPORT
Challenge Richmond, LLC, Project No. CV-KY0074748-072721
Table of Contents 1. INTRODUCTION.................................................................................................................................................. 3 2. PARTICIPANTS.................................................................................................................................................... 3 3. FACILITY DESCRIPTION ................................................................................................................................... 3 4. INSPECTION PROCEDURES .............................................................................................................................. 3 5. FINDINGS AND CONCLUSIONS ....................................................................................................................... 3 6. PERMIT ................................................................................................................................................................. 4 7. RECORDS AND REPORTS ................................................................................................................................. 4 8. SAMPLING............................................................................................................................................................ 5 9. DISCUSSION ........................................................................................................................................................ 6 10. ATTACHMENTS................................................................................................................................................... 6
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` COMPLIANCE EVALUATION INSPECTION REPORT
Challenge Richmond, LLC, Project No. CV-KY0074748-072721
1. INTRODUCTION
The U.S. Environmental Protection Agency, Region 4 and the Kentucky Division of Water (KDOW) conducted a Compliance Evaluation Inspection (CEI) at the Challenge Richmond, LLC facility (Facility) located at 110 Continental Drive in Richmond, Kentucky on July 27, 2021. The inspection was conducted under the authority of Section 308 of the Clean Water Act (CWA), as amended. This narrative report and attachments present the results of the inspection.
2. PARTICIPANTS
Name
Dennis Sayre Brad Ammons John Hanks Rick Baldwin Justin Grace
Position
EPA Inspector EPA Inspector KDOW Inspector Environmental Manager Engineering Manager
Phone Number
404-562-9756 404-562-9769 502-330-6414 859-595-0148 502-592-4967
3. FACILITY DESCRIPTION
The Facility discharges industrial storm water collected from the parking lot and loading docks located on the north side of the Facility. Collected storm water is conveyed to Outfall 001. Outfall 001 effluent is discharged into Harts Fork through a grass covered open channel ditch.
4. INSPECTION PROCEDURES
The overall objective of this CEI was to evaluate the condition and operational performance of the Facility's industrial storm water best management practices, storm water collection system and the permittee's self-monitoring program and offer compliance assistance as needed. Specific tasks included an opening conference, conducting an interview with the Facility management, reviewing Discharge Monitoring Reports (DMRs) and other records, conducting a site visit, and a closing conference.
5. FINDINGS AND CONCLUSIONS
(Refer to Attachment 1 for cited photographs)
Storm water drains were observed on the north-northeast and north-northwest side of the Facility. Storm drain socks were installed in the grated storm drains to catch sediment and other solids, (Photos 1, 2 and 3).
The gravel lot located on the north-northwest side of the building deposits sediment into the storm drain socks. Sediment and gravel were observed in the drainage sock. Facility management stated that they plan to pave the parking lot in front of the scrap metal dock on the northwest side of the facility, (Photo 4).
Uncovered dumpsters on the northwest side of the Facility in the gravel parking lot. (Photo 5) Fence line in front of Outfall 001, northwest corner of the Facility, had drainage pipe laid next to
the fence to control gravel and solids runoff from the parking lot (Photo 6). No discharges were observed from Outfall 001 (Photo 7). Silt fence lining was installed in the construction zone on the east side of the Facility. Construction
activity is to extend the existing parking lot (Photos 8 and 9). The south side of the Facility's roof is drained to the west from a sloped area (Photo 10).
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` COMPLIANCE EVALUATION INSPECTION REPORT
Challenge Richmond, LLC, Project No. CV-KY0074748-072721 Construction activity plans on the north side of the Facility includes paving to replace portions of the gravel parking lot, mostly in front of the scrap metal dock, to better control storm water runoff and as a part of the Facility's Zinc exceedance mitigation plan. (Figure 1) The Facility's Stormwater Best Management Practices Plan (SWBMPP) states in Section 3.1, "Scrap metal is separated by metal type and is stored in dumpster or bins under and awning outside the northwest corner of the property structure."
Figure 1. Construction activity map. 6. PERMIT
The National Pollutant Discharge Elimination (NPDES) permit number KY0106194 (Permit) became effective on September 1, 2018 for the previous owner, Gill Industries, Inc, and was transferred to the Facility on May 29, 2020. The Permit expires on August 31, 2023. Pollutants of interest in the Permit includes pH, Total Suspended Solids (TSS), Oil & Grease, Hardness (as mg/l CaCO3), and Total Recoverable Zinc. The Facility is permitted to discharge industrial storm water into Harts Fork, a tributary of Silver Creek. 7. RECORDS AND REPORTS A review of EPA's Enforcement and Compliance History Online (ECHO) website shows the Facility to be in Significant Non-compliance for effluent exceedances and late DMR submissions. Tables 1 and 2 below is a summary of NPDES effluent limit violations and late DMR submissions.
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` COMPLIANCE EVALUATION INSPECTION REPORT
Challenge Richmond, LLC, Project No. CV-KY0074748-072721
Table 1. Effluent limit exceedances from December 1, 2020 to June 30, 2021.
Pollutant of Interest
Effluent Limit (mg/L)
Statistical Basis
Monitoring Period End
Date
DMR Value DMR Report (mg/L) Date
TSS
30 MO AVG
7/31/2020
201
12/15/2020
TSS
60 Daily Maximum 7/31/2020
201
12/15/2020
TSS
60 Daily Maximum 8/31/2020
365
12/15/2020
TSS
30 MO AVG
8/31/2020
365
12/15/2020
Zinc
0.203 Daily Maximum 8/31/2020
0.22 12/15/2020
TSS
60 Daily Maximum 9/30/2020
204
12/15/2020
TSS
30 MO AVG
9/30/2020
204
12/15/2020
Zinc
0.203 Daily Maximum 9/30/2020
0.25 12/15/2020
TSS
60 Daily Maximum 11/30/2020
67
3/18/2021
TSS
30 MO AVG
11/30/2020
67
3/18/2021
TSS
30 MO AVG
1/31/2021
266
3/18/2021
TSS
60 Daily Maximum 1/31/2021
266
3/18/2021
Zinc
0.203 Daily Maximum 1/31/2021
0.26
3/18/2021
Zinc
0.203 Daily Maximum 3/31/2021
0.35
5/11/2021
Zinc
0.203 Daily Maximum 4/30/2021
0.28
6/24/2021
TSS
30 Monthly Average 5/31/2021
185
6/24/2021
TSS
60 Daily Maximum 5/31/2021
185
6/24/2021
Oil & Grease 10 Monthly Average 5/31/2021
32.8
6/24/2021
Oil & Grease 15 Daily Maximum 5/31/2021
32.8
6/24/2021
Zinc
0.203 Daily Maximum 5/31/2021
0.52
6/24/2021
Table 2. Late DMR records from
December 1, 2020 to June 30, 2021.
Monitoring
Period End DMR Due Ddays Date DMR
Date
Date
Late
Submitted
6/30/2020 7/28/2020
140 12/15/2020
7/31/2020 8/28/2020
109 12/15/2020
8/31/2020 9/28/2020
78 12/15/2020
9/30/2020 10/28/2020
48 12/15/2020
11/30/2020 12/28/2020
79 3/18/2021
12/31/2020 1/28/2020
48 3/18/2021
TSS exceedances are likely a result of storm water runoff depositing gravel fines and dust from the gravel parking lot into the storm water drains. Paving the parking lot and the scrap metal dock to eliminate the gravel may address TSS exceedances. Facility management believes that storm water runoff from the galvanized roof is the source of zinc in the effluent. The Facility has in place a zinc control plan to address zinc exceedances; however, there is no current plan to replace the galvanized roof or provide a protective coating.
8. SAMPLING
McCoy & McCoy Laboratories, Inc. (Lab) conducts sampling for TSS, Oil & Grease, Hardness (as mg/l CaCO3), and Total Recoverable Zinc. The Facility provides sampling and measures for storm water flow and pH. Various Lab analytical reports were reviewed, no deficiencies were noted. EPA
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Challenge Richmond, LLC, Project No. CV-KY0074748-072721
also reviewed the Facility's logbook used to record storm water flow and pH data, including pH probe calibration. Inspectors observed that the latest data recorded in the logbook, dated July 13, 2021, indicated that the pH probe was calibrated using 4.0 pH, 7.0 pH, and 10.0 pH buffer solutions (Photo 11). EPA inspectors also observed that pH buffer solutions located next to the pH probe expired in January 2021, July 2020, and August 2020 (Photo 12). The Facility also had onsite a buffer solution for 7.0 that was within its expiration date (Photo 13). The Facility's Environmental Manager mentioned that new buffer solutions are on order.
Flow is calculated using a set volume container and mathematical formula provided to the Facility.
9. DISCUSSION
Using expired pH buffer solutions may provide inadequate pH probe calibration leading to nonrepresentative sampling, as required by Section 2.9 of the NPDES Permit. Also, procedures should be put in place to ensure timely DMR submission to address late DMR violations and to ensure compliance with the NPDES Permit.
Storm water samples collected between June 1, 2018 and June 30, 2021 shows zinc in the analytical data for each month that samples were collected, with concentrations ranging from 0.05mg/L to 0.52mg/L. Trend data provided in Table 3 shows an increase in zinc concentration over time. If the Facility's assumption regarding the source of the zinc is correct, the trending data may be indicative of an aging galvanized coating on the Facility roof. The Facility should evaluate the alternatives to control zinc concentrations in the roof storm water runoff, to include providing a protective coating on the existing roof or replacing the roof as needed.
Table 3. Reported Zinc concentrations. Daily Maximum and Monthly Average reported as the same value.
Storm water contacting metal in the dumpsters can wash oxidized metal from the scrap and into the storm water runoff. Dumpsters containing scrap metal should be covered in accordance with the Facility's SWBMPP.
10. ATTACHMENTS
1. Photographs 2. ECHO screenshot
END REPORT
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Challenge Richmond, LLC Attachment 1 - Photographs Project No. CV-KY074748-072721
Figure A1: Photo locations.
Photo 1: Loading dock drainage and truck loading garage. N-NE side of the building.
Photo 2: Loading area storm drainage. N-NW side of the building.
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Challenge Richmond, LLC Attachment 1 - Photographs Project No. CV-KY074748-072721
Photo 3: Loading area storm drain sock to catch gravel Photo 4: Gravel lot. N-NW side of the building. and other solids inside the culvert shown in Photo 2.
Photo 5: Dumpsters located in gravel lot. N-NE side of Photo 6: Fence located behind dumpsters shown in
the building.
Photo 5.
Photo 7: Outfall 001 located approximately 25 feet from the fence shown in Photo 8.
Photo 8: Construction zone silt fence. East side of the building.
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Challenge Richmond, LLC Attachment 1 - Photographs Project No. CV-KY074748-072721
Photo 9: Construction zone SE corner of the building. Photo 10: Construction zone SE corner of the building.
Photo 11: Facility pH and storm water flow log.
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Challenge Richmond, LLC Attachment 1 - Photographs Project No. CV-KY074748-072721
Photo 12: pH 4, 7, and 10 buffer solutions.
Photo 13: pH 7 buffer solution.
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