Document GBDVVx0x2GmNOGVDwZOZqMev

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 03/21/2023 09:10 AM (ET) Announced: No 03/22/2023 11:30 AM (ET) Access: Granted Cloudy, dry Water Clean Water Act, NPDES, Industrial CEI - Compliance Evaluation Inspection Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Ohio Coatings Co. Ohio Coatings Co. 2100 Tin Plate Place Yorkville, OH 43971 Belmont 40.14658, -80.70718 FRS ID 110000735526 Permit Number(s) (If Applicable) OH0120588 (effective December 1, 2022 through November 30, 2027) SIC and/or NAICS 3312 Lead Inspector: Megan Zale MEGAN ZALE EPA Region 5 Digitally signed by MEGAN ZALE Date: 2023.05.30 09:48:22 -04'00' zale.megan@epa.gov (440) 250-1711 Supervisor Review: Brooke Furio Digitally signed by Furio, Furio, Brooke Date: 2023.05.30 Brooke 10:56:53 -04'00' EPA Region 5 furio.brooke@epa.gov (440) 250-1705 SECTION I - INTRODUCTION Site Entry and Inspection Objectives Dave Emerich, Process Control Manager, was out on medical leave during the inspection. EPA Region 5 Lead Inspector, Megan Zale, arrived at the Ohio Coatings Co. (the "Site" or "Facility"), located at 2100 Tin Plate Place, Yorkville, OH 43971, at 09:10 AM (ET) on 03/21/2023 for an unannounced inspection. EPA Region 5 Lead Inspector presented credentials to Lori Clark and Doug Crow and informed them that this was an EPA Region 5 inspection to determine compliance as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. This report is based on information supplied by Ohio Coatings Co. representatives, direct observations made by the EPA Region 5 inspector, records and reports maintained by the permittee and other information including: photographs taken by EPA Region 5 inspector(s), physical evidence collected by the EPA Region 5 inspector(s), measurements taken by EPA Region 5 inspector(s), verbal or written statements 1 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 made by information supplied by Ohio Coatings Co. 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 inspector(s) by Ohio Coatings Co. representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization EPA Region 5 EPA REGION 5 Ohio Coatings Ohio Coatings Ohio Coatings Ohio Coatings Attendee Name Megan Zale Jonathan Moody Lori Clark Doug Crow Dave Emerich Dave Bechtel Title Lead Inspector Inspector VP - Commercial Senior Quality Technician Process Control Manager Electrical Manager Present in Opening Conf. Yes Yes Yes Yes Present in Closing Conf. Yes Yes Yes No No Yes No Yes Facility/Site Description The EPA Region 5 lead inspector confirmed the following facility information: Ohio Coatings purchases light gauge carbon steel cold rolled coils and electrolytically tin plates them. The coils are cleaned with NaOH based cleaner, rinsed with reverse osmosis treated water ("RO water"), pickled/cleaned with sulfuric acid based cleaner, rinsed with RO water, tension-leveled, trimmed, then tin plated and rinsed with RO water again. The plating medium is methyl-sulfonic acid. The coils are then chemically treated with sodium dichromate. All RO water rinses drain directly to the wastewater equalization tank and subsequently flows through the wastewater treatment process of neutralization, flocculation with a polymer, clarification, and then liquid flows over weirs to two sand filters, and solids go to a thickener, filter press, and off-site disposal. Clean water from the sand filters flows over a weir and to the final outfall box. The sand filters are a continuous backwash type and the backwash is directed back to the equalization tank. Sodium dichromate chemical treatment wastewater is directed to a chrome rinse equalization tank and then a chrome reduction tank, where it is treated with sodium bisulfite to reduce hexavalent chromium to trivalent chromium. It then flows to the wastewater treatment equalization tank. All coils are stored indoors. The RO water is treated pumped well water. Municipal water is used in the kitchen and laboratory, which flows through a drain system and then to the equalization tank and through wastewater treatment. Blowdown from the facility's cooling towers and the air scrubber goes to the equalization tank and through wastewater treatment. The facility utilizes a 275-gallon quench tank which has a continuous 8 to 10 gallon per minute (gpm) outflow to wastewater treatment during operation. The facility's design flow is 0.094 million gallons per day. Facility/Site Information Industrial Sector/Sub- SIC Categories 3312 and 3471 sector Type of Operation Electrolytic tin plating of light gauge carbon steel cold rolled coils 2 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Size of Facility 40 acres Outfalls (and do the numbers and locations match the permit?) 001 and 002. The locations match the permit. Do you self-monitor Yes and keep monitoring records? Do you use in-house or contract out for laboratory analyses? Or both? Contract out for all permit analyses but do in-house testing for pH and temperature Have there been or No are there plans to make changes in the process(es) that will cause a new, different, or increased discharge? Location(s) SECTION II - OBSERVATIONS OHIO COATINGS CO. Observation #: MZ2-OB-001 Date: 03/21/2023 Weather: Cloudy, dry The designated stormwater effluent pipe outside of the facility had a significant amount of flow on the day of the inspection. Steam could be seen coming from the pipe, which indicated that the flow did not consist entirely of stormwater. It appeared to exit the outfall prior to the diffuser (Photos # 492 through 505). A schematic received from facility representatives showed that a PVC pipe for the facility's wastewater effluent was located within the stormwater pipe and connected to the diffuser. OHIO COATINGS CO. Observation #: MZ2-OB-002 Date: 03/21/2023 Weather: Cloudy, dry There was no wet thermometer in the effluent automatic sampler refrigerator. OHIO COATINGS CO. Observation #: MZ2-OB-003 Date: 03/21/2023 The pH buffers for the effluent sampling probe appeared dirty. OHIO COATINGS CO. Observation #: MZ2-OB-004 Date: 03/21/2023 3 of 30 Weather: Cloudy, dry Weather: Cloudy, dry Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Some of the wastewater treatment components were located outside. These components were the sludge thickener, clarifier, equalization tank, and cooling towers. OHIO COATINGS CO. Observation #: MZ2-OB-005 Date: 03/21/2023 Weather: Cloudy, dry Facility representative Doug Crow stated that a weekly calibration was completed for the effluent pH probe, but the process that was shown to EPA during the inspection was a calibration verification. SECTION III - RECORDS REVIEW EPA requested via email six months of calibration records for the effluent pH probe. The records show that facility personnel record the slope percentage approximately every week. EPA also requested via email the pH probe model and user manual to verify whether the facility was following calibration or verification procedures and did not receive it from the facility representatives. Water balance numbers shared with EPA by Doug Crow via discussion during the inspection: Flow rates shared with EPA Gallons of flow per day by facility representative (calculated from flow in Process during inspection previous column) Clean 4 gpm* 5760 Pickel(etch) 5 gpm 7200 plating 6 gpm 8640 Quench 6 gpm 8695 chemtreat 9 gpm 12960 Fume Scrubber 5 gpm 7200 Aux Fume Scrubber 8 gpm 192 cooling towers 4 gpm 5760 RO reject 20000 gal/day 20000 Softeners 100 gal/regeneration** 300 Boilers 125 gal/week 25 *gpm = gallons per minute **gal/regeneration = gallons used per water softener regeneration process Total 76,732 Permit Renewal Application The facility's most recent NPDES permit renewal application, Ohio EPA form 2C (for the permit effective December 1, 2022 through November 30, 2027), lists the total flow from outfall 001 as 0.091 MGD in Section II. B. It also includes a list of process wastewater to outfall 001. Outfall 002 is not included in the Section II.B. table. 4 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 The information contained in Section II does not distinguish the process wastewater volume from the noncontact cooling water and does not include the reject water from the reverse osmosis, softeners, and boilers. Per the information entered in Section II.C. of the form 2C, the 0.091 MGD volume includes the process wastewater and the non-contact cooling water. The "Fact Sheet Regarding an NPDES Permit To Discharge to Waters of the State of Ohio for Ohio Coatings Company" for the most recent permit (December 1, 2022 through November 30, 2027) includes the statement: "Non-contact cooling water blowdown contributes 0.005 MGD to outfall 001. As a result of the dilution, NSPS [40 CFR 433.16(c)] require lower limits which are reflected in the calculation for total suspended solids, total cyanide, chromium, and total toxic organics. A ratio of 0.005 MGD to average flow was used: 0.094 MGD yields a 5.3 percent reduction in limits for these parameters." Based on the information provided by the facility during the inspection, the percentage of the dilutional flow would be the combination of the cooling towers and blowdowns, 26,085 gallon/day (5,760 + 20,000 + 300 + 25) and divided by the total flow, 76,732 gallon/day which is approximately 34%. This is different than the approximate 5% dilutional flow reported in the most recent permit application. Schematic showing that a PVC pipe for the facility's wastewater effluent was located within the stormwater pipe and connected to the diffuser. SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS USEPA staff conducted field monitoring using an AT-600 manufactured by In-Situ Inc with serial number 689929. The AT-600 included a pH probe, and a temperature/specific conductivity probe. A calibration was conducted in the afternoon on March 20, 2023, with an In-Situ QuickCal solution for specific conductivity and ORP. A threepoint pH calibration was conducted in the morning on March 22, 2023, with 4.00, 7.00 and 10.00 buffer standards. All measurements were taken on March 22, 2023. Time Description Lat Long Temp Sp. Cond. pH (F) (uS/cm) 9:27 AM Discharge effluent box inside facility, 40.1469617 -80.7103217 79.5 6,359 7.90 shown in photo DSCN0488.JPG and DSCN0489.JPG. 9:52 AM Stormwater outfall (002) shown in 40.1465900 -80.707335 67.5 4,610 8.00 photo DSCN0497.JPG 9:54 AM Edge of the Ohio River upstream of the 40.1466483 -80.707090 46.0 300 8.02 confluence of the conveyance shown in photo DSCN0497.JPG 9:55 AM Edge of the Ohio River downstream of 40.1465333 -80.707055 45.1 453 7.79 the confluence of the conveyance shown in photo DSCN0497.JPG ORP (mV) -108 114 152 174 SECTION V - AREA OF CONCERN Area(s) of Concern may not be in sequential order. The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. 5 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 AOC Reference #: MZ2-OB-001 Regulation and/or Permit Requirement Page 9 of the "Fact Sheet" for the facility's current NPDES permit states: "Outfall 001 discharges treated process wastewaters via a 3-port diffuser (installed in July 2015) to the Ohio River. Outfall 002 discharges only stormwater. The diffuser extends from the final outfall pipe separated from the storm water at outfall 002." Page 14 of the "Fact Sheet" states that the diffuser is used to meet whole effluent toxicity limits. AOC: At the time of the inspection, there was a significant quantity of flow coming from outfall 002 which is supposed to be the stormwater only outfall. It was not raining at the time of the inspection. Based on field monitoring conducted during the inspection, the temperature and specific conductivity of the water at outfall 002 was similar to the field monitoring parameters at outfall 001. The temperature at 001 was 79.5 fahrenheit and the temperature at 002 was 67.5 fahrenheit which was warmer than the ambient air temperature and the temperature of the river which was approximately 46 degrees fahrenheit. The specific conductivity at outfall 001 was 6,359 uS/cm, the specific conductivity at 002 was 4,610 uS/cm, the specific conductivity in the Ohio River upstream of the confluence was 300 uS/cm. The designated stormwater effluent pipe outside of the facility had a significant amount of flow on the day of the inspection. Steam could be seen coming from the pipe. It appeared to exit the outfall prior to the diffuser. A schematic received from facility representatives showed that a PVC pipe for the facility's wastewater effluent was located within the stormwater pipe and connected to the diffuser. AOC Reference #: MZ2-OB-005 Regulation and/or Permit Requirement Page 16 of the facility's current NPDES permit: "3. FACILITY OPERATION AND QUALITY CONTROL All wastewater treatment works shall be operated in a manner consistent with the following: A. At all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee necessary to achieve compliance with the terms and conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with conditions of the permit. B. The permittee shall effectively monitor the operation and efficiency of treatment and control facilities and the quantity and quality of the treated discharge." AOC: Facility representative Doug Crow stated that a weekly calibration was completed for the effluent pH probe, but the process that was shown to EPA during the inspection appeared to be a calibration verification. EPA was unable to determine the manufacturers recommendations for the calibration and verification schedule for the pH probe. EPA requested the probe model number and manual after the inspection from the facility but did not receive it. 6 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 AOC Reference #: MZ2-OB-005 Regulation and/or Permit Requirement: Page 9 of the fact sheet for the facility's current NPDES permit: "Non-contact cooling water blowdown contributes 0.005 MGD to outfall 001. As a result of the dilution, NSPS [40 CFR 433.16(c)] require lower limits which are reflected in the calculation for total suspended solids, total cyanide, chromium, and total toxic organics. A ratio of 0.005 MGD to average flow was used: 0.094 MGD yields a 5.3 percent reduction in limits for these parameters." AOC: RO reject is not included in the dilutional flow calculation in the facility's most recent permit renewal application, which created an incorrect water balance. It is also not included as a contributing flow source in section II B of the most recent permit renewal application. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA Region 5 Lead Inspector held a closing conference with Facility personnel at 11:30 AM (ET) on 03/22/2023 for the inspection. During the closing conference, EPA Region 5 Lead Inspector discussed the observations and Area(s) of Concern identified during the inspection. Observations and Area(s) of Concern have not yet been evaluated for a formal compliance determination. EPA conducted the closing conference on 3/22/2023 at 10:30 AM. Dave Emerich joined via phone call. EPA stated that there should be a wet thermometer in the automatic sampler fridge where the effluent leaves the plant. EPA also mentioned that the pH buffers for the outfall sampling that were stored near the effluent automatic sampler looked dirty. EPA asked for information about the blue liquid in the floor drain next to the effluent location in the facility and Dave Emerich responded that it was precipitation from chemical testing in lab and that the chemicals from the laboratory go through the drain and to treatment. EPA asked if a pH calibration versus a pH verification is done at the effluent location regularly. Dave Emerich answered that pH is calibrated weekly. EPA asked if drawings were available for the effluent piping to the outfall diffuser system and asked about the apparent effluent flow in the stormwater pipe outside of the black effluent pipe. Dave Emerich verified that the black pipe should be effluent. He said it begins inside the facility. He confirmed that the 3-foot diameter pipe is the stormwater pipe. He said drawings were with the PTI for the installation of the outfall diffuser. He also said both the diffuser and the black stormwater pipe were installed in June 2014. He also said he does not know where the current flow in the stormwater pipe is coming from. He said there is normally no flow in the stormwater pipe on dry days like the day of the inspection. Follow Up EPA received an email from Dave Emerich on May 9th, 2023 containing a schematic showing that a PVC pipe for the facility's wastewater effluent was located within the stormwater pipe and connected to the diffuser. The email also stated that the PVC pipe was found dislodged from its position and allowing water to bypass, and that repairs were planned for May 13th, 2023. EPA received an additional email from Dave Emerich on May 26th, 2023 which contained photos showing repairs made to the diffuser line. 7 of 30 Ohio Coatings Co. Inspection Date(s): SECTION VII - LIST OF APPENDICES 1. Photo Log 03/21/2023 - 03/22/2023 8 of 30 Ohio Coatings Co. Inspection Date(s): APPENDIX 1: PHOTO LOG 03/21/2023 - 03/22/2023 Cleaning process DSCN0457.JPG 03/21/2023 10:25 AM Photographer: Megan Zale Facility processing area No CBI No PII Cleaning process. Fume collection is through white pipe or duct, above process Cleaning process fume water DSCN0458.JPG 03/21/2023 10:25 AM Photographer: Megan Zale Facility processing area No CBI No PII Cleaning process fume water flows here and is then pumped to wastewater treatment 9 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Main fume exhaust DSCN0459.JPG 03/21/2023 10:31 AM Photographer: Megan Zale Facility processing area No CBI No PII Main fume exhaust - reverse osmosis treatment occurs where screen is. Wastewater flows out through pipe in bottom left of photo via sump pump (blue) to equalization tank. Pumps that spray reverse osmosis water for cleaning DSCN0461.JPG 03/21/2023 10:35 AM Photographer: Megan Zale Facility processing area No CBI No PII Pumps that spray reverse osmosis water for cleaning. Drains to sump 1 10 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 RO Water Pumps After Pickling Station DSCN0463.JPG 03/21/2023 10:41 AM Photographer: Megan Zale Facility processing area No CBI No PII Reverse osmosis water pumps after pickling station Reverse osmosis rinse after electro-plating 03/21/2023 10:46 AM Facility processing area Reverse osmosis rinse after electro-plating DSCN0465.JPG Photographer: Megan Zale No CBI No PII 11 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 RO rinse after sodium dichromate deposition 03/21/2023 10:51 AM Facility processing area RO rinse after sodium dichromate deposition DSCN0466.JPG Photographer: Megan Zale No CBI No PII Wastewater treatment process diagram 03/21/2023 10:56 AM Laboratory Wastewater treatment process diagram DSCN0467.JPG Photographer: Megan Zale No CBI No PII 12 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 SCADA Log for chemical spills or wastewater treatment issues DSCN0468.JPG 03/21/2023 11:00 AM Photographer: Megan Zale Laboratory No CBI No PII SCADA log for chemical spills or wastewater treatment issues Sludge Press 03/21/2023 11:11 AM Wastewater Treatment Area Sludge press DSCN0469.JPG Photographer: Megan Zale No CBI No PII 13 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Effluent sampler 03/21/2023 11:12 AM Wastewater Treatment Area Effluent sampler DSCN0470.JPG Photographer: Megan Zale No CBI No PII Effluent sampler refrigerator 03/21/2023 11:13 AM Wastewater Treatment Area Effluent sampler refrigerator DSCN0471.JPG Photographer: Megan Zale No CBI No PII 14 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Thickener (foreground) and clarifier (background) 03/21/2023 11:17 AM Wastewater Treatment Area Thickener (foreground) and clarifier (background) DSCN0472.JPG Photographer: Megan Zale No CBI No PII EQ tank on right, cooling towers on left 03/21/2023 11:18 AM Wastewater Treatment Area Equalization tank on right, cooling towers on left DSCN0473.JPG Photographer: Megan Zale No CBI No PII 15 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Clarifier with center well 03/21/2023 11:21 AM Wastewater Treatment Area Clarifier with center well DSCN0474.JPG Photographer: Megan Zale No CBI No PII Thickener DSCN0475.JPG 03/21/2023 11:21 AM Photographer: Megan Zale Wastewater Treatment Area No CBI No PII Thickener (sludge from bottom of clarifier is pumped here) 16 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Sand Filters 03/21/2023 11:22 AM Wastewater Treatment Area Sand filters DSCN0476.JPG Photographer: Megan Zale No CBI No PII Flocculation tank 03/21/2023 11:31 AM Wastewater Treatment Area Flocculation tank DSCN0477.JPG Photographer: Megan Zale No CBI No PII 17 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Neutralization tank DSCN0478.JPG 03/21/2023 11:32 AM Photographer: Megan Zale Wastewater Treatment Area No CBI No PII Neutralization tank (NaOH or dilute sulfuric acid added here) Chrome reduction tank DSCN0479.JPG 03/21/2023 11:36 AM Photographer: Megan Zale Wastewater Treatment Area No CBI No PII Chrome reduction tank (sodium bisulfite used to reduce hexavalent chromium to trivalent chromium) 18 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Additives DSCN0481.JPG 03/21/2023 11:42 AM Photographer: Megan Zale Wastewater Treatment Area No CBI No PII Additives. Contained spill would go to equalization tank. RO tank 03/21/2023 11:43 AM Wastewater Treatment Area Reverse osmosis tank (10,000 gallons) DSCN0482.JPG Photographer: Megan Zale No CBI No PII 19 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Well water tank 03/21/2023 11:43 AM Wastewater Treatment Area Well water tank (10,000 gallons) DSCN0483.JPG Photographer: Megan Zale No CBI No PII Water softener tanks 03/21/2023 11:44 AM Wastewater Treatment Area Water softener tanks DSCN0484.JPG Photographer: Megan Zale No CBI No PII 20 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Buffers for pH probe calibration at effluent sampler DSCN0485.JPG 03/21/2023 11:47 AM Photographer: Megan Zale Wastewater Treatment Area No CBI No PII Buffers for pH probe calibration at effluent sampler Log at effluent auto-sampler 03/21/2023 11:48 AM Wastewater Treatment Area Log at effluent auto-sampler DSCN0486.JPG Photographer: Megan Zale No CBI No PII 21 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Effluent flow sensor and temp sensor DSCN0487.JPG 03/21/2023 11:59 AM Photographer: Megan Zale Wastewater Treatment Area No CBI No PII Effluent flow sensor (large sensor) and temperature sensor (small sensor) Weir for effluent flow monitor 03/21/2023 12:00 PM Wastewater Treatment Area Weir for effluent flow monitor DSCN0488.JPG Photographer: Megan Zale No CBI No PII 22 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Effluent during plant operation 03/22/2023 09:24 AM Wastewater Treatment Area Effluent during plant operation DSCN0489.JPG Photographer: Megan Zale No CBI No PII Blue liquid in floor drain system near effluent 03/22/2023 09:27 AM Wastewater Treatment Area Blue liquid in floor drain system near effluent DSCN0490.JPG Photographer: Megan Zale No CBI No PII 23 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Blue liquid in floor drain system near effluent 03/22/2023 09:27 AM Wastewater Treatment Area Blue liquid in floor drain system near effluent DSCN0491.JPG Photographer: Megan Zale No CBI No PII Stormwater outfall on facility grounds 03/22/2023 09:36 AM Facility grounds Stormwater outfall on facility grounds DSCN0492.JPG Photographer: Megan Zale No CBI No PII 24 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Flowing liquid in stormwater pipe 03/22/2023 09:38 AM Facility grounds Flowing liquid in stormwater pipe DSCN0493.JPG Photographer: Megan Zale No CBI No PII Manhole downstream of first stormwater outfall. Per Dave Bechtel, the black pipe is the water from outfall 001 and goes to the diffuser. 03/22/2023 09:45 AM Facility grounds Manhole downstream of first stormwater outfall DSCN0495.JPG Photographer: Megan Zale No CBI No PII 25 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Significant flow from stormwater outfall pipe. Per Dave Bechtel, the black pipe is wastewater from facility effluent and goes to the diffuser in the Ohio River. 03/22/2023 09:48 AM Outfall 001 Significant flow from stormwater outfall pipe DSCN0497.JPG Photographer: Megan Zale No CBI No PII 26 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Significant flow from stormwater outfall (002). Per DSCN0498.JPG Dave Bechtel, the black pipe is the wastewater from facility effluent and goes to the diffuser in the Ohio River. 03/22/2023 09:49 AM Photographer: Megan Zale Outfall 001 No CBI No PII Significant flow from stormwater outfall 27 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Effluent from stormwater outfall flowing toward DSCN0500.JPG river. Per Dave Bechtel, the black pipe is the water from facility effluent and goes to the diffuser in the Ohio River. 03/22/2023 09:56 AM Photographer: Megan Zale Outfall 001 No CBI No PII Effluent from stormwater outfall flowing toward river Facing stormwater outfall from river. Outfall 002. 03/22/2023 09:58 AM Outfall 001 Facing stormwater outfall from river DSCN0501.JPG Photographer: Megan Zale No CBI No PII 28 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Facing stormwater outfall from river. Outfall 002. 03/22/2023 09:58 AM Outfall 001 Facing stormwater outfall from river DSCN0502.JPG Photographer: Megan Zale No CBI No PII Manhole upstream of stormwater outfall 03/22/2023 10:06 AM Facility grounds Manhole upstream of stormwater outfall DSCN0503.JPG Photographer: Megan Zale No CBI No PII 29 of 30 Ohio Coatings Co. Inspection Date(s): 03/21/2023 - 03/22/2023 Stormwater outfall integrator readout 03/22/2023 10:11 AM Facility grounds Stormwater outfall integrator readout DSCN0504.JPG Photographer: Megan Zale No CBI No PII Stormwater outfall integrator readout DSCN0505.JPG 03/22/2023 10:11 AM Photographer: Megan Zale Facility grounds No CBI No PII Stormwater outfall integrator readout - says 0.22 feet per second 30 of 30