Document Ex5yLVb5RgN0q0ajpKrN6j46x

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103-2029 Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Facility Name: Permittee(s): Facility Operator: Permittee Address: Facility Address: Facility Latitude: Facility Longitude: County/Parish: Permit No: NAICS Code: SIC: Unique Project #: Clean Water Act Compliance Inspection Report 09/29/2021 National Pollutant Discharge Elimination System (NPDES) Industrial Stormwater Chemalloy Co., Inc. Chemalloy Company, LLC Chemalloy Company, LLC 1301 Conshohocken Road, Conshohocken, PA 19428 1301 Conshohocken Road, Conshohocken, PA 19428 40.101700 -75.316640 Montgomery PAR200003 331110 3399 3E21WN009A Facility Representative(s): Point of Contact Luiz Spiezio Email: luiz.spiezio@metalpowdergroup.com EPA Inspectors: Mike Greenwald EPA Region III Phone: (215) 814-2398 Email: Greenwald.Michael@epa.gov Shane McAleer EPA Region III Phone: (215) 814-5616 Email: Mcaleer.Shane@epa.gov Report Preparer Signature/Date Mike Greenwald, Enforcement Officer Date NPDES Enforcement Section (3ED32) Supervisor Gold, Peter Digitally signed by Gold, Peter Date: 2021.11.22 08:10:02 -05'00' Signature/Date Pete Gold, Acting Chief Date NPDES Enforcement Section (3ED32) Unique Project#: 3E21WN009A Section Table of Contents Chemalloy Co., Inc. 09/29/2021 Page I 3 A Inspection Opening Conference...................................................................... 3 B Weather and Precipitation Conditions............................................................. 3 II Facility Activity............................................................................................... 4 III Observations.................................................................................................... 5 IV Records Review............................................................................................... 13 V Closing Conference......................................................................................... 13 VI List of Attachments.......................................................................................... 13 Unique Project #: 3E21WN009A Page 2 of 13 Chemalloy Co., Inc. 09/29/2021 I. Introduction On September 29, 2021, an inspection team composed of staff from the U.S. Environmental n industrial stormwater inspection of the Chemalloy Co., Inc facility . The purpose of the inspection was to observe compliance with the Clean Water Act (CWA) and to verify compliance with the facility National Pollutant Discharge Elimination System (NPDES) Permit No. PAR200003 regulations. A. Inspection Opening Conference The EPA Inspection Team arrived at the site at est. 10:00 AM. Representatives from the Pennsylvania Department of Environmental Protection (PADEP) were not in attendance. The following inspectors and representatives were present for the inspection: Name Mike Greenwald Shane McAleer Luiz Spiezio Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region III Inspectors and Contractors EPA Region III (215) 814- Greenwald.Michael@epa.gov 2398 EPA Region III (215) 814- Mcaleer.Shane@epa.gov 5616 Facility Representatives Chemalloy Co., Inc. - Luiz.spiezio@metalpowdergroup.com Mike Greenwald and Shane McAleer displayed their credentials to the site representatives 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 Mr. Spiezio that any information that the facility deemed to be confidential business B. Weather and Precipitation Conditions During the inspection, weather was clear. The closest 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 CONSHOHOCKEN, PA US USC00361737 CONSHOHOCKEN, PA US USC00361737 CONSHOHOCKEN, PA US USC00361737 CONSHOHOCKEN, PA US USC00361737 CONSHOHOCKEN, PA US USC00361737 CONSHOHOCKEN, PA US USC00361737 9/24/21 9/25/21 9/26/21 9/27/21 9/28/21 9/29/21 Precipitation Amount (inches)1 3.00 0.00 0.00 0.00 0.00 0.18 1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Unique Project #: 3E21WN009A Page 3 of 13 Chemalloy Co., Inc. 09/29/2021 II. Facility Activity The facility was approved for permit coverage under the PAG-03 General Permit for Discharges of Stormwater Associated with Industrial Activity, with an effective date of September 1, 2017. The Permit identifies the permittee as Chemalloy Company, Inc. Facility representatives stated that the facility is now affiliated with the Metal Powder Group. The facility is located at 1301 Conshohocken Road, Conshohocken, PA 19428. Approximately 35 employees operate on-site, and hours of operation are two eight-hour shifts from Monday to Friday. The facility primarily grinds, sizes, and prepares approximately 300 different raw materials. The , which is dated May 2017 (see Attachment 3 for the PPC Plan) states manufactured into products using a variety of methods such as drying, agglomeration, calcining, mixing and blending, size reduction, classification, and packaging. The small remainder is redistributed in the original containers without physical processing. All grinding and processing of materials occurs indoors. Raw materials are stored both indoors and outdoors. Products produced at the facility are shipped offsite. The facility representatives stated that the facility does not have any processes that generate wastewater. The total facility area encompasses approximately 9.5 acres, which includes indoor operations, equipment storage areas, bulk material storage areas, chemical/liquid container storage areas, and stormwater collection areas. The PPC Plan contains a facility identifies these areas. contain stormwater and to minimize exposure to pollutant generating sources. The PPC Plan identifies activities where potential spills and leaks may occur, including: material storage areas, diesel fuel, propylene glycol storage and use, waste oils, hydraulic/gear/motor oils, solvents, caustic soda, waste storage, salt, and oil filled transformers. The stormwater conveyance system onsite includes various inlets throughout the site that drain to two separate outlets: Outlet 001 and Outlet 002. The system also collects offsite stormwater from facility map. This inlet collect stormwater upstream of their system that may be in contact with another industrial site. Outlet 001 is located in the parking lot at the southwest corner of the facility. Outlet 001 collects stormwater from inlets along the southern portion of the site, as well as any stormwater that is collected via the upstream inlet at the southeastern corner of the property. Discharges from Outlet 001 leave the site through a pipe that runs under Conshohocken Road. The pipe runs under another industrial site that is west of the facility and ultimately discharges into the Schuylkill River. Outlet 002 is located in the northwestern corner of the facility. Outlet 002 collects stormwater from inlets along the northern portion of the facility. The area surrounding the Outlet 002 grate is a detention basin, which collects additional stormwater in the area. This area appeared to be heavily vegetated. The EPA Inspection team was not able to observe the grate where sampling is conducted at the time of the inspection due to the heavy vegetation making the area inaccessible. The PPC Plan indicates that the Outlet 002 discharges into a culvert under Conshohocken Road. Unique Project #: 3E21WN009A Page 4 of 13 Chemalloy Co., Inc. 09/29/2021 The facility is required to conduct sampling at their two outlets on a bi-annual basis to monitor for the parameters listed in Appendix B (Primary Metals) of the Permit. Sampling is conducted twice a year Samples are taken at three locations: Outlet 001 and Outlet 002 are sampled as required by the Permit, and the facility takes additional samples for the upstream inlet located on the southeast side of the property that is tied into their stormwater drainage system. The facility representatives indicated that they sample at this upstream inlet location to ensure that they can monitor if the upstream flows collected at the inlet are contributing to any pollutant discharges at Outlet 001. III. Observations The inspection observations below are made pursuant to the requirements of the Permit. Photographs were taken during the inspection by Shane McAleer and are provided in attachment 2. Preparedness, Prevention, and Contingency (PPC) Plan attached as Attachment 3. he PPC Plan. The PPC Plan is Part C.IV.A (Preparedness, Prevention and Contingency (PPC) Plan) of the Permit Pa. Code Section 91.34 ID 400-2200-001), its NPDES-specific addendum and the minimum requirements Part C.IV.B of the Permit states PPC Plan on an annual basis, at a minimum, and when one or more of the following occur: 1. Applicable DEP or federal regulations are revised, or this General Permit is revised. 2. The PPC Plan fails in an emergency. circumstances change in a manner that materially increases the potential for fires, explosions or releases of toxic or hazardous constituents; or which changes the response necessary in an emergency. 4. The list of emergency coordinators or equipment changes. Observation 1. The EPA Inspection Team observed that the PPC Plan, at the time of the inspection, was dated May 2017. There did appear to be minor updates and corrections made to the PPC Plan, including to the list of emergency coordinators and the facility map, but these did not appear to be dated. Facility representatives noted that the PPC Plan was in the process of being updated and provided correspondence dated July 16, 2021 wherein it is noted that the facility requested assistance from a third-party contractor to update the PPC Plan. Unique Project #: 3E21WN009A Page 5 of 13 Chemalloy Co., Inc. 09/29/2021 Environmental Emergency -2200-001 (see Attachment 4) identifies the requirements of the elements of a PPC and SPR Plan. Each of these elements is further described in this guidance document. Certain plan elements may not be entirely applicable or appropriate for a specific manufacturing or commercial installation. In these cases the person preparing the plan should act accordingly and should provide a brief explanation as to why the plan element(s) in The section includes the following requirement: of a 7 minute USES map show the following: Facility Location Facility name Facility ID # Name of 7 minute USES quadrangle County Location of facility site and site boundaries Location of each storage tank Location of surface drainage courses leading away from the site, and major surface streams and tributaries near the site Location of any known public and private surface water intakes downstream from the This section also includes the following requirement: following: shows the General layout of the site Property boundaries Areas occupied by manufacturing or commercial activities Raw materials and product storage Loading and unloading operations High risk areas where spills and leaks most likely would occur Waste handling, storage, and treatment facilities Drains, pipes, and channels which lead away from potential leaks or spill areas Outfall pipes which discharge to surface streams or drainage channels Secure and open-access areas Entrance and exit routes to the site facility map contains the general layout of the facility, stormwater conveyances, material storage areas, and other information that is specified in Part C.IV.A (Preparedness, Prevention and Contingency (PPC) Plan) of the Permit ordance with 25 Unique Project #: 3E21WN009A Page 6 of 13 Chemalloy Co., Inc. 09/29/2021 ID 400-2200-001), its NPDES-specific addendum and the minimum requirements b Observation 2. The EPA Inspection Team observed that the PPC Plan, at the time of the inspection, contained a facility map that did not appear to be consistent with the current facility layout. An inlet was observed in proximity to Building No. 7 and Plant No. 6 that did not appear to be on the facility map provided. See Photograph DSCN2277. An area between Building No. 5a and Warehouse A appeared to be used as empty drum storage. See Photographs DSCN2305 and DSCN2307. Two inlets were located between Building No. 5a and Warehouse A that did not appear on the facility map. See Photographs DSCN2317, DSCN2319, and DSCN2322. manhole did not appear to be on the facility map. See Photograph DSCN2367. An area on the east side of the facility appeared to be used as material storage. Several open drums appeared to have metals stored inside. map. See Photographs DSCN2404, DSCN2432, and DSCN2435. An area east of Plant No. 5 appeared to have palettes and drums stored. This did not appear to be labeled as a storage area on the facility map. See Photograph DSCN2449. A storage pile of wood chips was being stored in the area east of Plant No. 5. This did not appear to be on the facility map. See Photograph DSCN2452. The area north east of Building No. 7 did not appear to have an inlet. The facility map shows an inlet located by the north east corner of Building No. 7. See Photographs DSCN2494 and DSCN2495 for the area. Training Part C.IV.A.6 (Preparedness, Prevention and Contingency (PPC) Plan) of the Permit yees and contractors on pollution prevention, BMPs, and emergency response measures. This training must be implement employee and contractor training on the procedures for expeditiously stopping, Unique Project #: 3E21WN009A Page 7 of 13 Chemalloy Co., Inc. 09/29/2021 containing, and cleaning up leaks, spills, and other releases. The permittee shall conduct periodic training, no less than annually, and document the training on the Annual Report require Observation 3. The EPA Inspection Team observed that the PPC plan indicated that annual training is conducted for employees. At the time of the inspection, the PPC plan did not appear to have records of when the training occurred. The facility representative stated that they were unaware of the last date that the training occurred. Operation and Maintenance Part B.I. shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances), including BMPs, which are installed or used by the permittee to achieve compliance with the terms and conditions of this General Permit. Proper operation and maintenance includes, but is not limited to, adequate laboratory controls such as appropriate quality assurance procedures. The permittee shall properly operate and maintain backup or auxiliary facilities or similar systems installed by the permittee, as necessary to achieve compliance with the terms and conditions of this Observation 4. Observation 5. The EPA Inspection Team observed various stormwater inlet grates that appeared to be in need of maintenance. The grates to two inlets east of Plant No. 4 appeared to be covered in foliage and weeds. See Photographs DSCN2437, DSCN2438, and DSCN2441. The grate to an inlet appeared to be covered in debris and palettes in an area east of Plant No. 5. See Photographs DSCN2450 and DSCN2451. A grate to an inlet appeared covered in materials in the area south of Plant No. 5. See Photographs DSCN2489 and DSCN2491. this area contained a grate where Outlet 002 was located. The EPA Inspection team was not able to observe the outlet grate at the time of the inspection due to heavy vegetation making the area inaccessible. See Photograph DSCN2465. Appendix B.III (Sectorcontained in Part.C.II of the General Permit, the permittee shall implement, at a minimum, all of the following BMPs that are applicable to the processes in place at the Unique Project #: 3E21WN009A Page 8 of 13 Chemalloy Co., Inc. 09/29/2021 Observation 6. The EPA Inspection Team observed a storage pile of wood chips that was being stored in the area east of Plant No. 5. There did not appear to be erosion controls present. See Photograph DSCN2452. Pollution Prevention and Exposure Minimization Permittee shall minimize the exposure of manufacturing, processing, and material storage areas (including loading and unloading, storage, disposal, cleaning, maintenance, and fueling operations) to rain, snow, snowmelt, and runoff in order to minimize pollutant discharges by either locating industrial materials and activities inside or protecting them with storm resistant coverings wherever feasible. The permittee shall Part C.II.B (Pollution Prevention and Exposure Minimization) of the Permit states, Use grading, berming or curbing to prevent runoff of polluted stormwater and divert runon away from are Observation 7. The EPA Inspection Team observed a pipe leading from Warehouse A to the parking lot of the facility in proximity to Outlet 001. See Photograph DSCN2215. The EPA Inspection Team observed that this was an indoor garage where vehicles were stored. The facility representatives stated that flows would enter the area from a garage door opening due to the sloped impervious pavements south of this area. See Photograph DSCN2346 for the garage opening. A pump and floor drains were installed in the garage to pump stormwater into the parking lot in proximity to Outlet 001. Locate materials, equipment, and activities so that potential leaks and spills are Observation 8. The EPA Inspection Team observed a tank at the entrance of Plant No. 4b. There appeared to be liquid that had spilled or leaked from this tank that was present on the ground, which was being collected in a stormwater drain. The facility representative stated that this is a water tank, and the water is used in the process of dust collection. See Photograph DSCN2394. Part C.II.B (Pol Keep all dumpster lids closed when not in use. For dumpsters and roll off boxes that do not have lids, ensure that discharges have a control (e.g. secondary containment, treatment). This General Permit does not authorize dry weather discharges from Part C.II.B (Pollution Prevention and Exposure Minimization) of the Permit states, Clean up spills and leaks promptly using dry methods (e.g. absorbents) to prevent the Unique Project #: 3E21WN009A Page 9 of 13 Observation 9. Chemalloy Co., Inc. 09/29/2021 The EPA Inspection Team observed various onsite dumpsters that did not appear to have a lid or cover. Various dumpsters appeared to have liquid leaking from the bottom. A dumpster was observed in the southwest area of the facility in proximity to Maintenance Shop Building No. B. This dumpster was and various chemical containers. See Photographs DSCN2250 and DSCN2251. There also appeared to be a liquid on the ground that had leaked from the corner of the dumpster. See Photographs DSCN2252 and DSCN2253. A dumpster south of facility map appeared not to have a lid or cover. See Photograph DSCN2364. A dumpster in proximity to Plant No. 5 appeared to not have a lid or cover. See Photograph DSCN2391. uncovered. See Photograph DSCN2368 and DSCN2375. There appeared to be a liquid on the ground that had leaked from the bottom. See Photographs DSCN2371 and DSCN2372. Spill Prevention and Responses Part C.II.E (Spill Prevention and Responses) of the Permit states, minimize the potential for leaks, spills and other releases that may be exposed to stormwater and develop a plan consistent with Part.C.IV for effective responses to such releases. The permittee shall conduct the following spill prevention and response including the use of secondary containment and barriers between material storage and traffic areas, or a similarly effective means designed to prevent the discharge of Observation 10. The EPA Inspection Team observed various drums, containers, and barrels with liquids and materials throughout the site. These barrels appeared to lack secondary containment. Empty drums were stored at the west side of Maintenance Shop Building No. B. See Photographs DSCN2226 and DSCN2227. A drum and did not appear to have secondary containment. See Photograph DSCN2234. A container labeled sulfuric acid was observed in this area and did not appear to have secondary containment. See Photograph DSCN2246. Drums of antifreeze appeared to lack secondary containment south of Plant No. 6. See Photographs DSCN2267, DSCN2268, and DSCN2269. Unique Project #: 3E21WN009A Page 10 of 13 Chemalloy Co., Inc. 09/29/2021 Drums outside of Building No. 6a. did not appear to have secondary containment. See Photograph DSCN2351. Raw Material appear to be secondary containment present for the drums in this area. See Photographs DSCN2361 and DSCN2362. Drums did not appear to have secondary containment on the east side DSCN2401. Drums were being stored in the Good Housekeeping appeared to contain liquid. See Photograph DSCN2420. There also secondary containment. See Photograph DSCN2422. Drums did not appear to have secondary containment in the area east of Plant No. 5. See Photograph DSCN2449. Drums did not appear to have secondary containment in an area by Plant No. 2a labeled "Bulk and Containerized Raw Ore Outdoor Storage". See Photograph DSCN2458. good housekeeping measures in order to minimize pollutant discharges including the drain c Observation 11. The EPA Inspection Team observed a floor drain in Warehouse A. The facility representative lifted the top of the drain and demonstrated that an inflatable plug was being used to prevent liquids from entering the drain. See Photographs DSCN2328 and DSCN2332. Routine Inspections inspections. inspect the following areas and BMPs on a semi annual basis (calendar periods), at a 1. Areas where industrial materials or activities are exposed to stormwater. 2. Areas identified in the Preparedness, Prevention and Contingency (PPC) Plan required in Part C IV as potential pollutant sources. 3. Areas where spills or leaks have occurred in the past three years. Unique Project #: 3E21WN009A Page 11 of 13 Chemalloy Co., Inc. 09/29/2021 4. Stormwater outfalls and locations where authorized non-stormwater discharges may commingle. 5. Physical BMPs used to comply with this General Permit. At least once each calendar year, the routine inspection must be conducted during a period when a stormwater discharge is occurring. Observation 12. The EPA Inspection Team reviewed the inspection records for the semiannual inspections that the facility conducted from 2019 to 2021 (see Attachment 5). The Permit requires that the routine inspections occur at least once during a calendar year when a stormwater discharge is occuring. The inspection records did not have a section to include the weather and precipitation conditions at the time of the inspections. It was also (i.e. Outlets) 001 and 002 during all of the inspections conducted from 2019 to 2021. ctivities are exposed to include locations such as the: Waste Oil Storage Area, Raw Material Storage Bays, Residual Waste Area, and Diesel Fuel Tank Area. It was unclear if these included other areas noted on the facility map, including the Outdoor Storage Area, Bulk and Containerized Raw Ore Outdoor Storage, Catch Basin, and the Equipment Storage Area. The inspection forms were blank for the section labeled BMPs were inspected during the inspections and the condition of those BMPs. Reporting Requirements Report The permittee shall submit a complete Annual Report to the DEP office that - 03 Annual Report template, 3850-PM-BCW0083h. The Annual Report shall address activities under the General Permit for the previous calendar year. The permittee shall submit the Annual Report electronically if notified by DEP in writing. If the permittee discharges to a municipal separate storm sewer system (MS4), a copy of the Annual Observation 13. The EPA Inspection Team requested annual reports submitted in 2019, 2020, and 2021. The facility representatives stated that these reports were not completed for the time periods requested. Unique Project #: 3E21WN009A Page 12 of 13 Chemalloy Co., Inc. 09/29/2021 IV. Records Review EPA requested and reviewed the following documents: 1. Notice of Intent (NOI) 2. Signed General Permit 3. The site map from the PPC plan that was current during the inspection. 4. Annual reports submitted in 2019, 2020, and 2021. 5. Routine Inspections conducted for 2019, 2020, and 2021 6. The PPC plan we reviewed during the inspection. 7. Chain of Custodies and Lab Analyses for 2019, 2020, and 2021 with the sampling/analysis for the Benchmark Monitoring required by the Permit. 8. Letter dated July 16, 2021 regarding updates to the PPC plan. Records pertaining to the inspection report are attached, with additional records being kept on file. V. Closing Conference After the site walk, the EPA Inspection Team met with the site representatives for a closing conference. The EPA Inspection Team shared preliminary observations with the site representatives. The EPA Inspection Team reiterated to the site 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 approximately 1:30 PM. V. List of Attachments Attachment 1. Attachment 2. Attachment 3. Attachment 4. Attachment 5. NPDES Permit Photograph Log PPC Plan dated May 2017 Guidelines for the Development and Implementation of Environmental -2200-001 Site Self Inspections 2019-2021 Unique Project #: 3E21WN009A Page 13 of 13