Document K6zykb9v9Y7mZkJ42M5rgaO8K

U.S. Environmental Protection Agency Region 5 Purpose: Clean Water Act National Pollutant Discharge Elimination System Compliance Evaluation Inspection Facility: Martin Marietta - Kellogg Avenue Yard 4439 Kellogg Ave. Cincinnati, Ohio 45226 Inspection Date: May 23, 2023 EPA Representatives: Jake Berger, Physical Scientist, 312-353-8024, berger.jake@epa.gov Jennifer Bush, Physical Scientist, 312-886-0879, bush.jennifer@epa.gov Facility Representatives: Greg Curry; Plant Manager Ken Robinson, Operator/Loader Report Prepared by: Jake Berger, Physical Scientist Water Enforcement and Compliance Assurance Branch, Section 1 Digitally signed by Berger, Berger, Jake Date: 2023.06.07 Jake Inspector Signature and Date: ______________0_8_:02_:4_6_-0_5'0_0_' _________________________ Approver Name and Title: Molly Smith, Section 1 Supervisor, Water Enforcement and Compliance Assurance Branch MOLLY Digitally signed by MOLLY SMITH Approver Signature and Date: __S_M__IT__H_______1_1:_07_:0_2 _-05_'0_0'___________________________ Date: 2023.06.07 Page 1 Martin Marietta - Kellogg Avenue Yard PURPOSE OF INSPECTION The purpose of the inspection by the U.S. Environmental Protection Agency (USEPA) at Martin Marietta - Kellogg Avenue Yard (Martin Marietta or Facility) was to describe, evaluate, and document compliance with the Clean Water Act (CWA) and their National Pollutant Discharge Elimination System (NPDES) permit. BACKGROUND The Facility is a concrete aggregate vendor in Cincinnati, Ohio. The Facility is located on the Ohio River and receives bulk #8 pea gravel and bulk sand at the Facility via barge, and #57 pea gravel at the Facility via truck. Bulk sand and gravel material are stored in piles across the stock yard above the Ohio River water level. The Facility samples their industrial storm water discharges from 1 onsite stormwater basin. This basin and the Facility's industrial stormwater discharges are covered by the Ohio Environmental Protection Agency (OEPA) Industrial Storm Water Multi-Sector General Permit No. OHR000007 (Permit) (OEPA Facility Permit # 1GR01461*CG) which has an Effective Date of November 1, 2022, and an Expiration Date of May 31, 2027. INSPECTION Jake Berger and Jennifer Bush of USEPA first arrived at the Facility at 8:15 a.m. EDT and were met by Ken Robinson (Operator/Loader). Jake Berger and Jennifer Bush showed Ken Robinson their credentials and identification, and he helped them contact Greg Curry (Plant Manager) via phone. Greg Curry arrived at the Facility at 9:20 a.m. EDT, and Jake Berger and Jennifer Bush showed him their credentials and identification and began the opening conference. Opening Conference USEPA staff explained that the purpose of the inspection was to: Review Facility's records, including sample measurements, monitoring activities, and storm water plans, as required by the Permit; Conduct a walkthrough of the Facility; Identify locations where storm water control had the potential to be insufficient; and Inform Facility of areas of concern regarding the records review and Facility walkthrough. Page 2 Martin Marietta - Kellogg Avenue Yard Facility Walkthrough USEPA staff and Greg Curry began the facility walkthrough at 9:40 AM EDT. USEPA staff made the following observations during the Facility walkthrough, further documented in the Photograph Log (attached): All stockpiles are stored uncovered (Photo 1 and Photo 2). Dredged material from the stormwater basin is stored in a pile in the northwest corner of the yard (Photo 3). This has no containment or coverage. The retaining area and stormwater basin was dredged in April 2023 following a flood event. Greg Curry noted this is the deepest the stormwater basin has been dug to his knowledge in order to better handle flooding at the Facility (Photo 3, Photo 5, Photo 6, Photo 9, and Photo 13). Significant flooding from the Ohio River occurs onsite (Photo 7, Photo 8, Photo 11, and Photo 12). Greg Curry said that extreme past flood events have resulted in the water level rising to the material storage yard. Retaining wall at end of conveyer belt ramp is filled with excess scraps and material, with minimal capacity for additional stormwater events. (Photo 9 and Photo 10). There is no management or implementation of best management practices for storm water that comes in contact with the stockpiles in the storage area near the conveyer belt split at the top of the ramp. Sediment runoff and erosion into the ramp area towards the Ohio River is evident (Photo 14). The Facility walkthrough tour ended at 11:08 AM EDT and was immediately followed by the records review. Records Review USEPA began reviewing hard copy and electronic records provided by Martin Marietta with Greg Curry at 11:10 a.m. EDT. The following areas of concern were identified: Section 2.1.2.9 of the Permit requires Martin Marietta to "train all employees who work in areas where industrial materials or activities are exposed to storm water, or who are responsible for implementing activities necessary to meet the conditions of this permit (e.g., inspectors, maintenance personnel), including all members of your Pollution Prevention Team. Training shall cover both the specific control measures used to achieve the conditions in this Part, and monitoring, inspection, planning, reporting, and documentation requirements in other parts of this permit. Ohio EPA requires that training be conducted at least annually." Facility had no records available at the time of inspection of any employee training related to storm water pollution prevention. However, Greg Page 3 Martin Marietta - Kellogg Avenue Yard Curry noted this was typically done annually, but the annual trainings have not happened since 2020. Section 6.2.1.2 of the Permit requires Martin Marietta to conduct Benchmark Monitoring of industrial storm water, take an average of the monitoring concentration values, compare these averages to the benchmark concentration, and take additional actions if the average monitoring values exceed the benchmark concentration. Martin Marietta conducted this sampling; however, several of the samples collected exceeded the laboratory holding times and the results showed a "Non-Detect" for the required analyte. For these sampling events, the Facility was unable to provide additional sampling results that followed the method holding times and were appropriately sensitive. The records review portion of the inspection concluded at 12:46 PM EDT and was immediately followed by the closing conference, led by Jake Berger. Closing Conference USEPA staff relayed the following preliminary comments to Greg Curry during the closing conference: Stormwater pollution prevention training is required annually for all on-site employees, which has not been conducted in several years according to Greg Curry. Benchmark Monitoring (and any additional sampling conducted on site) samples are required to not exceed the laboratory holding times. Deficiencies were observed during the Facility walkthrough, such as general management of sediment, the lack of erosion control and runoff prevention near the large material piles leading to the ramp to the Ohio River, and the filled retaining wall on the shoreline of the Ohio River. USEPA confirmed that no information collected during the inspection was considered Confidential Business Information. USEPA concluded the inspection and left the Facility at 1:10 PM EDT. Page 4 Martin Marietta - Kellogg Avenue Yard Martin Marietta - Kellogg Avenue Yard EPA Inspection May 23, 2023 All photos taken by Jake Berger, Physical Scientist, U.S. EPA Camera: Olympus Tough TG-6 1: P5230001 Description: Gravel pile and front of yard Location: Northeastern side of property Camera Direction: South Date/Time: May 23, 2023/9:45AM EDT Page 5 Martin Marietta - Kellogg Avenue Yard 2: P5230002 Description: Sand pile and conveyer belt (in background) Location: Northeastern side of property Camera Direction: Southwest Date/Time: May 23, 2023/9:46 AM EDT 3: P5230003 Description: Dredged material and scrap pile Location: Northwestern edge of property, north of downhill ramp Camera Direction: West Date/Time: May 23, 2023/9:53 AM EDT Page 6 Martin Marietta - Kellogg Avenue Yard 4: P5230004 Description: Conveyer belt for barge unloading Location: Ramp to river from yard Camera Direction: West Date/Time: May 23, 2023/10:10 AM EDT 5: P5230005 Description: Stormwater catch basin Location: Middle of ramp towards river Camera Direction: West Date/Time: May 23, 2023/10:11 AM EDT Page 7 Martin Marietta - Kellogg Avenue Yard 6: P5230006 Description: Stormwater catch basin with ramp in background Location: Western side of ramp Camera Direction: Southwest Date/Time: May 23, 2023/10:12 AM EDT 7: P5230007 Description: Material from flooding event 2023 Location: Area near stormwater catch basin Camera Direction: West Date/Time: May 23, 2023/10:16 AM EDT Page 8 Martin Marietta - Kellogg Avenue Yard 8: P5230008 Description: High water lines from 2023 floods Location: Shoreline at bottom of ramp Camera Direction: North Date/Time: May 23, 2023/10:20 AM EDT 9: P5230009 Description: Retaining wall Location: Bottom of ramp, end of conveyer belt Camera Direction: Southwest Date/Time: May 23, 2023/10:21 AM EDT Page 9 Martin Marietta - Kellogg Avenue Yard 10: P5230010 Description: Retaining wall from shoreline Location: Shorline, north of retaining wall Camera Direction: South Date/Time: May 23, 2023/10:25 AM EDT 11: P5230011 Description: Log in conveyer belt from flood Location: End of conveyer belt Camera Direction: North Date/Time: May 23, 2023/10:30 AM EDT Page 10 Martin Marietta - Kellogg Avenue Yard 12: P5230012 Description: Log in conveyer belt from other side previous photo Location: Under end of conveyer belt Camera Direction: South Date/Time: May 23, 2023/10:32 AM EDT 13: P5230013 Description: Ramp down to loading area from retaining wall area Location: End of conveyer belt Camera Direction: East Date/Time: May 23, 2023/10:35 AM EDT Page 11 Martin Marietta - Kellogg Avenue Yard 14: P5230014 Description: Ramp down to river Location: Conveyer split area Camera Direction: West Date/Time: May 23, 2023/10:38 AM EDT 15: P5230015 Description: Conveyer belt for P Gravel and berm on west side Location: Yard Camera Direction: South Date/Time: May 23, 2023/10:41 AM EDT Page 12 Martin Marietta - Kellogg Avenue Yard 16: P5230016 Description: Top of berms (vegetated) Location: West side of yard, uphill of ramp Camera Direction: West Date/Time: May 23, 2023/10:44 AM EDT 17: P5230017 Description: Shoreline behind vegetated ridge/berm Location: OH river shorline, south western corner of property Camera Direction: North Date/Time: May 23, 2023/10:57 AM EDT Page 13 Martin Marietta - Kellogg Avenue Yard 18: P5230018 Description: Truck rinse area/wheel wash station with holding pond in background Location: Front of yard, near entrance/exit Camera Direction: Southwest/West Date/Time: May 23, 2023/11:04 AM EDT 19: P5230019 Description: Wheel wash and holding ponds Location: Front of yard, near entrance/exit Camera Direction: West Date/Time: May 23, 2023/11:05 AM EDT Page 14 Martin Marietta - Kellogg Avenue Yard