Document EvK6EyjdvVZaamMmaqbE63OnR

REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date: Time: Media: Statute (s)/Program(s): Type of inspection: Access: April 23, 2025 Inspection Announced: No Entry: 9:35 AM EST Exit: 12:00 PM EST Water Clean Water Act, National Pollutant Discharge Elimination System (NPDES), Industrial CEI - Compliance Evaluation Inspection Granted Permittee Name: Facility or Site Name: Facility/Site Physical Address: (city, state, zip code) County/Parish: Midwest Terminal Ironville Midwest Terminal Ironville 2863 Front Street Toledo, Ohio 43605 Lucas Permit Number: OHR000007 (OEPA Facility Permit #: 2GR02035*BG) Page 1 of 12 REGION 5 Enforcement and Compliance Assurance Division Persons Participating in Inspection: Title Name Phone Physical Scientist, Matthew (312) 886-2405 EPA Schulte Environmental Joseph Forth (312) 886-7275 Engineer Supervisor Shawn Partin -- General Manager Mark Hall -- Lead Inspector: Matthew Schulte Email schulte.matthew@epa.gov Forth.joseph@epa.gov Shawn.Partin@mwtti.com Mark.Hall@mwtti.com Present at Opening Conference Yes Present at Closing Conference Yes Yes Yes Yes Yes No Yes Supervisor Review: Molly Smith Region 5 schulte.matthew@epa.gov (312) 886-2405 MOLLY SMITH Region 5 Digitally signed by MOLLY SMITH Date: 2025.06.27 09:43:34 -05'00' smith.molly@epa.gov (312) 353-8773 SECTION I - INTRODUCTION Site Entry and Inspection Objectives Region 5 Lead Inspector, Matthew Schulte, and inspector Joseph Forth arrived at Midwest Terminal Ironville Facility (the "Site" or "Facility"), located at 2863 Front Street, at 9:35AM on April 23, 2025, for an announced inspection. Inspectors presented their credentials to site supervisor Shawn Partin and informed the Facility that this was an EPA Region 5 inspection to investigate elements of the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permit program. The inspection was conducted under the authority of the CWA NPDES permit program and Section 308 of the CWA. The table above identifies the attendees that participated in the inspection. This report is based on information supplied by Facility representatives, observations made by the Region 5 inspectors, and records and reports maintained by the permittee and Region 5. These include the following: direct observations made by the Region 5 inspectors, photographs taken by Region 5 inspectors, physical evidence collected by Region 5 inspectors, measurements taken by Region 5 inspectors, verbal or written statements made or supplied by Facility representatives (the permittee) during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the Region 5 inspectors by Facility representatives during or subsequent to the on-site inspection. In addition, Page 2 of 12 Midwest Terminal Ironville Inspection Date(s): April 23, 2025 information gathered prior to or subsequent to the inspection from a review of U.S. EPA, State, and public records may be included in this report. Facility/Site Description Region 5 Lead Inspector confirmed the following Facility information with representatives from the Facility: The Facility is a bulk storage and transloading facility. Raw materials are transported to Facility by barge and truck. Raw materials held onsite include iron pellets as ballast, limestone, mill scale, aluminum, and diced tomatoes. A majority of the material is shipped by truck, with the Facility receiving anywhere from 20-50 trucks per day. Mill scale and iron ore are the only materials that are brought in by barge. On average the Facility will store 300,000 tons of iron during the winter, and 150,000 - 250,000 tons of other material throughout the site. The Facility has a storm water capture system that spans around the perimeter of the Facility. All of the storm water catch basins around the Facility connect to a containment area for Outfall 002-A. Outfall 002-A discharges to the Maumee River. Storm water captured in the dock area is directed to Outfall 001 which discharges to the Maumee River. SECTION II - OBSERVATIONS Observations made by the EPA intersection team during the site tour. Observations may not be in sequential order. Unique Identifying No. MS-OB-001 MS-OB-002 MS-OB-003 MS-OB-004 Observations During the site tour, inspectors observed spilled material from unloading vessels stored on piles in the dock area (Photo #5). During the site tour, inspectors observed storm water drains throughout the facility located near material piles (Photo #7). During the site tour, inspectors observed some storage areas surrounded by ditches and berms to prevent runoff of materials (Photos: #3 and #4). During the site route, inspector observed that only water used onsite appeared to be by water spray trucks for dust control. Area of Concern? Yes Yes No No SECTION III - RECORDS REVIEW Records reviewed may not be in sequential order. No. MS5-RR-001 Record Documents requested during inspection were supplied to EPA by email on April 25, 2025. Documents received included: Storm Water Pollution Prevention Plan (SWPP) with Attachments Page 3 of 12 Midwest Terminal Ironville Inspection Date(s): No. Record Coverage under State General Storm Water Permit Stormwater Sample Results Benchmark monitoring results and verification of completion April 23, 2025 SECTION V - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. No. MS-OB-001 Spilled material from unloading vessels is stored on piles in the dock area (Photo #5). MS-OB-002 Facility's SWPPP: Section 3.2 - Good Housekeeping Maintaining clean area at the dock face area using brooms and/or shovels, cleaning fines and spillage from conveyor bents. EPA observed that the Facility's dock does not contain any berms or other barriers to prevent the piles of material from entering water runoff during rain events. Facility has stated that the spilled material is moved off the dock within a day or two. Some storm water drains throughout the facility are located near material piles (Photo #7). Facility's SWPPP: Section 3.2 - Good Housekeeping Cleaning catch basins when the depth of debris reaches 60% of the sump depth. MS-RR-001 Debris should be prevented where possible from entering the catch basins, and cleaning may be required for routine operation and maintenance. The Facility's SWPPP, provided to EPA on April 25, 2025, is dated November 2022. Some information within SWPPP, such has staff and contact names, is out of date. SWPPP should be evaluated on an annual basis and updated regularly to ensure correct employee training. Facility's SWPPP: Section 3.9 - Employee Training The Facility conducts SWPP plan and spill discharge prevention training for affected employees the Ironville Facility at least once per year to ensure ongoing adequate understanding of the SWPP Plan and response actions for the facility. In addition, all new employees will have initial SWPP training as part of employee orientation. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The Lead Inspector held a closing conference with Facility personnel on April 23, 2025, for the inspection. During the closing conference, the Lead Inspector discussed the observations and Areas of Concern identified Page 4 of 12 Midwest Terminal Ironville Inspection Date(s): April 23, 2025 during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - LIST OF APPENDICES Appendix 1 - Photo Log [times listed on images are incorrect. Correct times for photos are in Eastern Standard Time (EST) to left of photo log.] Page 5 of 12 REGION 5 Enforcement and Compliance Assurance Division Facility Name & Location: Midwest Terminal Ironville 2863 Front Street, Toledo, Ohio 43605 Date Photograph Was Taken: April 23, 2025 Photo No.: 1 Time: 10:54AM Direction Photo Taken: West Photo Description: Outfall 002-A into the Maumee River. Photographer: Matthew Schulte Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: MTI_01.jpg Page 6 of 12 Midwest Terminal Ironville Inspection Date(s): Facility Name & Location: Midwest Terminal Ironville 2863 Front Street, Toledo, Ohio 43605 Date Photograph Was Taken: April 23, 2025 Photo No.: 2 Time: 10:51AM Direction Photo Taken: South Photo Description: Containment Area prior to Outfall 002A. Photographer: Matthew Schulte April 23, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: MTI_02.jpg Page 7 of 12 Midwest Terminal Ironville Inspection Date(s): Facility Name & Location: Midwest Terminal Ironville 2863 Front Street, Toledo, Ohio 43605 Date Photograph Was Taken: April 23, 2025 Photo No.: 3 Time: 10:47AM Direction Photo Taken: Southwest Photo Description: Aluminum storage pile surrounded by ditch and berm. Photographer: Matthew Schulte April 23, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: MTI_03.jpg Page 8 of 12 Midwest Terminal Ironville Inspection Date(s): Facility Name & Location: Midwest Terminal Ironville 2863 Front Street, Toledo, Ohio 43605 Date Photograph Was Taken: April 23, 2025 Photo No.: 4 Time: 11:14AM Direction Photo Taken: North Photo Description: Train tracks and berm to west of storage piles. Photographer: Matthew Schulte April 23, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: MTI_04.jpg Page 9 of 12 Midwest Terminal Ironville Inspection Date(s): Facility Name & Location: Midwest Terminal Ironville 2863 Front Street, Toledo, Ohio 43605 Date Photograph Was Taken: April 23, 2025 Photo No.: 5 Time: 11:05AM Direction Photo Taken: Northeast Photo Description: Vessel unloading area and pile of spilled material. Photographer: Matthew Schulte April 23, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: MTI_05.jpg Page 10 of 12 Midwest Terminal Ironville Inspection Date(s): Facility Name & Location: Midwest Terminal Ironville 2863 Front Street, Toledo, Ohio 43605 Date Photograph Was Taken: April 23, 2025 Photo No.: 6 Time: 11:14AM Direction Photo Taken: North Photo Description: Storage piles and track from vessel dock. Photographer: Matthew Schulte April 23, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: MTI_06.jpg Page 11 of 12 Midwest Terminal Ironville Inspection Date(s): Facility Name & Location: Midwest Terminal Ironville 2863 Front Street, Toledo, Ohio 43605 Date Photograph Was Taken: April 23, 2025 Photo No.: 7 Time: 11:10AM Direction Photo Taken: South Photo Description: Drain leading to containment area for Outfall 002A Photographer: Matthew Schulte April 23, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: MTI_07.jpg Page 12 of 12