Document MdXokdNOO15kjKdrgO95n2B7

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8 1595 Wynkoop Street Denver, CO 80202-1129 Phone 800-227-8917 www.epa.gov/region08 Ref: 8ENF-W-NW SENT VIA EMAIL DIGITAL READ RECEIPT REQUESTED Frank Kills In Water Facilities Manager Rosebud Casino fkillsinwater@rosebud-casino.com Re: Inspection Report for Rosebud Casino Wastewater Treatment Facility, NPDES Permit No. SD0034584 Dear Mr. Kills In Water: On September 21, 2022, representatives of the U.S. Environmental Protection Agency inspected the Rosebud Casino Wastewater Treatment Facility located in Todd County, South Dakota to evaluate compliance with the facility's National Pollutant Discharge Elimination System permit for wastewater. The inspection was conducted under the authority of Section 308 of the Clean Water Act (Act). Enclosed is a report of the inspection. Inspection findings are summarized within the enclosed inspection report in a table titled "Findings, Corrective Actions and Recommendations." Within thirty (30) days of receipt of this report, please provide the EPA and Rosebud Sioux Tribe Environmental Program with a summary of corrective actions taken to address each of the findings identified in the report and any information that may change the findings or content of the report. This summary should be sent to: Stephanie Meyers meyers.stephanie@epa.gov Ivan Crow Eagle ivan.croweagle@rst-nsn.gov Please contact me at 303-312-6938 or meyers.stephanie@epa.gov if you have any questions regarding this letter or the enclosed report. Sincerely, STEPHANIE Digitally signed by STEPHANIE MEYERS MEYERS Date: 2022.11.21 08:54:27 -07'00' Stephanie Meyers NPDES and Wetlands Enforcement Section Enforcement and Compliance Assurance Division Enclosures: 1) Rosebud Casino NPDES Inspection Report - Wastewater Treatment Facility 2) Rosebud Casino Photo Log cc: The Honorable Scott Herman, President, Rosebud Sioux Tribe (via email) Ivan Crow Eagle, Environmental Director, Rosebud Sioux Tribe (via email) NPDES Inspection Report - Wastewater Treatment Facility National Database Information Inspection Date: September 21, 2022 Inspection Type: CEI - Wastewater Treatment Facility Entry/Exit Time: 1:10 pm / 4:00 pm NPDES ID Number: SD0034584 NAICS Code: 221320 Inspection ID: 202209_SD0034584 Lead inspector and affiliation: Stephanie Meyers / EPA Region 8 Inspector and affiliation: Akash Johnson / EPA Region 8 Facility Location Information (Name/Location/ Mailing Address) Site/Facility Name & Location: Rosebud Casino Wastewater Treatment Facility 30421 US Highway 83 Todd County, South Dakota 69201 Email Report to: Mr. Frank Kills In Water Facilities Manager Rosebud Casino fkillsinwater@rosebud-casino.com Contact Information Facility Contacts: (indicate primary lead and present during inspection) Name(s)/Title Frank Kills In Water / Facilities Manager / Rosebud Casino / primary lead during the inspection Kingsley Ryan / Operator / Rosebud Casino / present during inspection James Harp / Maintenance Worker / Rosebud Casino / present during inspection Person/Company meeting definition of "Operator" Authorized Official(s) (Per NOI?) Rosebud Casino Frank Kills In Water / Facilities Manager / Rosebud Casino Permit Information Is the permit on site and available? Yes Lagoon Category: Individual Reporting Frequency: Permit Quarterly Effective Date: October 1, 2017 Expiration Date: September 30, Is the Facility under a 2022 - Administratively compliance schedule? No continued at time of the inspection Is correct contact information indicated on ICIS? No Indicate correct contact information: Permittee - Frank Kills In Water Receiving Water(s): Unnamed drainageway tributary to Rock Creek Outfall 001 from the Ecolo-Chief Plant located near Latitude 43.000556/RQJLWXGH-100.576389 Regulatory Inspector's source of information: Statement of basis for the permit, permit, facility records, EPA records, EPA databases, facility representatives and facility observations. Areas Evaluated During Inspection Permit Self-Monitoring Program Records Compliance Schedule Facility Site Review Laboratory Effluent/Receiving Waters Operations and Maintenance Flow Measurement Sludge Handling/Disposal Report Review and Signature Drafter Name Stephanie Meyers Reviewer Name Akash Johnson Supervisor Signature/Name MICHAEL MICHAEL BOEGLIN Digitally signed by BOEGLIN 09:19:39 -07'00' Date: 2022.11.18 Michael Boeglin Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6938 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6067 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6250 Pretreatment Pollution Prevention Stormwater Combined Sewer Overflow Sanitary Sewer Overflow Date 11/7/2022 Date 11/15/2022 Date 11/18/2022 Inspection Narrative and Site Description The inspection was conducted at the Rosebud Casino Wastewater Treatment Facility (WWTF or facility) located in Todd County, South Dakota, on the Rosebud Reservation, to evaluate compliance with its National Pollutant Discharge Elimination System (NPDES) permit. The EPA is responsible for implementing the NPDES program in Indian Country within the State of South Dakota. The inspection was announced approximately two weeks prior to the inspection to coordinate logistics for the inspection. On September 21, 2022, U.S Environmental Protection Agency (EPA) inspectors Stephanie Meyers and Akash Johnson met with Facilities Manager Frank Kills In Water and Operators Kingsley Ryan and James Harp, all with Rosebud Casino. The EPA inspectors presented their credentials and had an opening conference in the WWTF office to explain the purpose of the inspection. The inspectors proceeded to ask questions of facility representatives, review operation and maintenance records, and inspect the facility to help the inspectors evaluate compliance with the facility's permit. Throughout the inspection, the inspectors noted their observations in a checklist. Photographs taken during the inspection are included in the attached photo log. The Rosebud Casino is owned and operated by the Rosebud Sioux Tribe and is located in Todd County, South Dakota. The Rosebud Casino consists of a hotel (Quality Inn), casino, restaurant, fuel plaza, administration offices, and the WWTF. The Quality Inn hotel has 60 guest rooms, two meeting rooms, and an 8,600-gallon indoor pool. Wastewater from the hotel, casino, fuel plaza, administration offices, and restaurant is piped to the WWTF. Before the pool is drained for maintenance, the water is tested for the total chlorine levels. Sodium Thiosulfate is added until all chlorine is neutralized before being drained to the WWTF. The kitchen in the restaurant is connected to a cement vault grease trap, in line with the sewer system. Backup power generators are maintained onsite. The WWTF is an activated sludge Ecolo-Chief package plant, which consists of a primary separation tank, four aeration tanks, a secondary clarifier, an aerobic digester for sludge, and a UV disinfection system. The average design flow of the system is 58,000 gallons per day (gpd) with a peak flow design of 87,900 gpd. After the opening conference, inspectors went to inspect the lift station wet well (photo 61), which is located just before the influent flow meter (photo 62) and primary separation tank (photo 63). Raw sewage enters the covered primary separation tank (photo 63) where primary separation and digestion of floatables occurs. Sludge is not routinely wasted from the primary separation tank. Inspectors then observed wastewater flowing to the four aeration tanks (photo 64) in sequence where aeration decreases as wastewater flows through each of the four tanks. Wastewater then flows to the secondary clarifier (photo 65) where the activated sludge settles out and water overflows across a surface weir. Facility representatives stated sludge from the secondary clarifier is pumped down once a week to the aerobic digester (photo 66), and sludge from the digester and secondary clarifier is pumped back to the primary separation or the first aeration tank for additional treatment. Facility representatives stated they can also pump sludge from the secondary clarifier to the primary separation tank, for occasions such as cleaning or inspection of the secondary clarifer. A v-notch weir in the clarifier prevents floating material from entering the UV disinfection line. Each tank is drained annually and visually inspected/repaired for leaks. The final treatment phase is the disinfection process, where wastewater flows through an ultraviolet (UV) light system (photo 67). UV bulbs are cleaned weekly and replaced every 6 months. A flow meter (photo 68) measures the treated effluent after UV disinfection and then is continuously discharged through a pipe (photo 69) to the outfall (photo 70). Treated effluent flows in a channel into a natural vegetated field (photo 71) just north of the Ecolo-Chief WWTF. A facility representative stated they have never observed treated effluent flow beyond the tree line north of the facility, which is approximately 0.1 mile from the WWTF. After inspecting the WWTF, inspectors then inspected the grease interceptor (photo 72), which facility representatives indicated is pumped out once every two months. At the end of the inspection, the inspectors held a closing conference with Mr. Kills In Water where they discussed preliminary findings. On October 18, 2022, inspectors requested sampling and laboratory records from monitoring periods ending on March 31, 2021; December 31, 2021; March 31, 2022; and June 30, 2022, to evaluate the facility's compliance with effluent limits and use of EPA approved sampling and analysis methods. These records were received on November 9, 2022, after the inspection report had been completed. Records will be reviewed separately and any findings pertaining to the review of these records will be coordinated with facility representatives. Findings, Corrective Actions and Recommendations Finding #1: Calibration records for pH meter calibration were not properly documented. The individual performing pH meter calibration was not being documented in records. Permit requirement: Part 2.6 of the permit states, "Records of monitoring information shall include: 2.6.1 The date, exact place, and time of sampling or measurements; 2.6.2 The initials or name(s) of the individual(s) who performed the sampling or measurements; 2.6.3 The date(s) analyses were performed; 2.6.4 The time(s) analyses were initiated; 2.6.5 The initials or name(s) of individual(s) who performed the analyses; 2.6.6 References and written procedures, when available, for the analytical techniques or methods used; and, 2.6.7 The results of such analyses, including the bench sheets, instrument readouts, computer disks or tapes, etc., used to determine these results." Corrective Action: Ensure that the individual performing pH meter calibration is being documented. Provide the EPA and Tribe with a description of the corrective actions taken to address this finding. NPDESInspectionReport-IndustrialUser Nameofindustryandlocation: Controlauthority/PermitNo./FacilityID: RossReels 1101MayflyDrive Montrose,Colorado81401 Dateofvisit: CityofMontrose FacilitydidnothaveaCityPretreatmentIndustrial UserPermit. NPDESID:COPU00171 InspectionID:202309_COPU00171 NAICSCode:333999AllOtherMiscellaneous GeneralPurposeMachineryManufacturing Latitude:38.48481N,Longitude:107.89256W Timeofvisit: September26,2023 9:48am-11:28am Name(s)/Affiliationofinspector(s): EmilioLlamozas/U.S.EnvironmentalProtectionAgency,Region8(lead) StephaniePassarelli/U.S.EnvironmentalProtectionAgency,Region8 HyrumWebb/CityofMontrose Name/Title/Affiliation: TonyLugard/DirectorofOperations/RossReels RobHauck/DirectorofEngineering/RossReels KatlynNagel/Engineer/RossReels ReportReviewandSignature DrafterName Address/PhoneNumber U.S.EPARegion8 Date 1595WynkoopStreet 8ENFWNW 12/04/2023 Denver,Colorado80202 EmilioLlamozas 3033126407 ReviewerName Address/PhoneNumber Date U.S.EPARegion8 1595WynkoopStreet StephaniePassarelli 8ENFWNW Denver,Colorado80202 12/05/2023 3033126803 SupervisorSignature/Name Address/PhoneNumber Date EMILIO Digitally signed by EMILIO LLAMOZAS Date: 2023.12.05 LLAMOZAS 11:41:42 -07'00' U.S.EPARegion8 1595WynkoopStreet 8ENFWNW Denver,Colorado80202 12/05/2023 EmilioLlamozas 3033126407 Page 1 of 8 InspectionDescription: OnSeptember26,2023,U.S.EnvironmentalProtectionAgency(EPA)inspectorsEmilioLlamozasand StephaniePassarelli(jointlyreferredtoasinspectors)andtheCityofMontrose(City)inspectorHyrumWebb conductedanindustrialuserinspectionofRossReelsinMontrose,Coloradoaspartofapretreatment complianceinspection(PCI)oftheCity.TheCityhadidentifiedRossReelsasanIndustrialUser(IU),buthad determinedthatthefacilitydidnotmeetthesignificantindustrialusercriteriaandthushadnotrequireda significantindustrialpermitforthefacility.TheinspectionwasannouncedtoRossReelsthemorningofthe inspection. Uponarrivingtothefacilityatapproximately9:48am,Mr.WebbintroducedtheinspectorstoRossReels' DirectorofOperations,TonyLugard.TheinspectorsalsometRobHauck,RossReel'sDirectorofEngineering andKatlynNagel,anEngineerwithRossReels.Theinspectorsbegantheopeningconferencebypresenting theirinspectorcredentialsandexplainingthegeneralpurposeandproceduresoftheinspection.Duringthe openingconference,Mr.Lugard,Mr.HauckandMs.Nagelprovidedanoverviewofthefacility'soperations, focusingontheprocessesthatgeneratewastewater,thewastewaterpretreatmentsystem,andtheplansto buildanewanodizingfacility. Followingtheopeningconference,Mr.Lugard,Mr.HauckandMs.Nagelaccompaniedthegroupofinspectors onafacilitywalkthrough.Todocumentandrecordtheconversationandinspectionobservations,the inspectorstooknotesusingchecklistswithquestionsapplicabletotheindustrialuser.Photographstaken duringtheinspectionareincludedintheattachedphotolog. EPAinspectorsconductedaclosingconferencewithMr.Lugard,Mr.HauckandMs.Nagelandprovided generalobservationsandpreliminaryfindingsfromtheinspection.TheEPAandCityrepresentativesleftthe facilityatapproximately11:28am. OnOctober12,2023,theEPAsentpreliminaryfindingsfromtheinspectionviaemailtoMr.LugardandMr. Hauck.OnOctober13,2023,Mr.Lugardsentanemailresponseindicatingthatsecondarycontainmentwas installedonthetumblersoapandprovidedaphotoofthesecondarycontainment.OnNovember8,2023, Mr.LugardsentanemailresponseindicatingthattheRossReelsmanufacturingfacilityandthefuture anodizingfacilityaretwononcontiguousbusinessparcelsandtwononcontiguousbuildings.Hisemail indicatedthattheRossReelsmanufacturingfacilityislocatedat1101MayflyDriveandthefutureRossReels anodizingfacilitywillbelocatedat1331MayflyDriveSuiteG104.Mr.Lugardrequestedapermitapplication fromtheCityandindicatedthathewouldsubmitazerodischargewastewaterpermitapplicationtotheCity forthefutureRossReelsanodizingfacility.OnNovember29,2023,theCitysentanindustrialuserpermit applicationtoRossReelsforitsnewanodizingfacility.Mr.Lugardindicatedthattheywouldcompletethe industrialuserpermitapplicationandsendittotheCity.Healsoindicatedthatthegoalistohavethe anodizingfacilityoperationalbyDecember21,2023. Page 2 of 8 1.Whatdoesthisindustryproduce? Thefacilitymanufacturesflyfishingreelsandflyfishingaccessories(plyers,clippers,flytyingdevices,etc.). ThefacilityhasCNCmachinesthatcreatethedifferentpartsforthereels.Thepartsarethensenttoan offsitefacilityinCaliforniaforanodizingandthenbroughbackforassembly. 2.HowistheindustryclassifiedbythePOTW? TheCityclassifiedRossReelsasanIndustrialUser(IU)andhadnotrequiredapretreatmentindustrialuser permitforthisfacility.Themachiningfacilitylocatedat1101MayflyDrive,Montrose,Coloradodoesnot meettheapplicabilitycriteriaformetalfinishingfoundat40CFR.10(a)becausethefacilitydoesnot performanyofthesixmetalfinishingcoreoperations. Atthetimeoftheinspection,RossReelswasintheprocessofbuildinganewanodizingfacilitylocatedat 1331MayflyDrive,SuiteG104,Montrose,Colorado.Thenewanodizingfacilityisexpectedtobegin operationsbytheendofDecember2023.RossReelsindicatedthattheanodizingprocesswillbeazero dischargeprocessbecausethewastewaterwillbetreatedinanevaporatorandthesolidswillbedisposed offsite.EPAdidnotinspectthenewanodizingfacilityaspartofthisinspectionbecausethefacilitywas underactiveconstruction. 3.Havetherebeenanysignificantchangesinprocessesorflow? NochangeshaveoccurredatthefacilitysinceRossReelsstartedoperations.TheRossReelsmachiningfacility locatedat1101MayflyDrive,Montrose,Coloradodoesnotmeettheapplicabilitycriteriaformetalfinishing foundat40CFR.10(a)becausethefacilitydoesnotperformanyofthesixmetalfinishingcoreoperations. RossReelsisbuildingananodizingfacilitylocatedat1331MayflyDrive,SuiteG104,Montrose,Colorado. RossReelsindicatedthatthenewanodizingfacilitywillbeazerowastewaterdischargefacility.Operationsat thenewfacilityareexpectedtobeginattheendofDecember2023. SincetheRossReelsmachiningfacilitylocatedat1101MayflyDriveandthefutureRossReelsanodizing facilitylocatedat1331MayflyDrive,SuiteG104operationsoccurattwodifferentnoncontiguouslocations, theyareconsideredtwodifferentfacilities.TheRossReelsanodizingfacilitymeetstheapplicabilitycriteria formetalfinishingfoundat40CFR433.10(a).RossReelsplanstoapplyforazerodischargewaterpermit fromtheCity,sincethefacilityisnotplanningtodischargetheirwastewaterstotheCity. 4.Whatrawmaterialsareused? Thefacilityusesthefollowingmaterials: x Aluminum6061T651 x Stainlesssteel x Siliconbronze x Titanium x 5080Coolant x Oil Page 3 of 8 x Hybridpolymerceramicmedia x Cleaningsoap(RotoBrite) 5.Whatprocessesareusedtomaketheproduct(s)?Indicateanywastesgeneratedanddestinationof wastes. RossReelsreceivesaluminumsparsthatarecutindifferentpucksizes.Thealuminumpucksarethen machinedinapproximately28ComputerNumericalControl(CNC)machinestodifferentspecifications. TheCNCmachineshaveasumpwhereusedoilcollects.Theusedoilisdisposedoffsite(photo559). TheCNCmachinesarecleanedonaregularbasisandtheusedcoolantisstoredinatote(photo558).The usedcoolantissenttotheonsiteevaporator(photo560).Theliquidisevaporatedandthesolidsarecollected foroffsitedisposal.SafetyCleanremovesthesolidsanddisposesthemoffsite. Thealuminumpartsarethendeburredbyhandandthenplacedinatumblerforpolishing(photo563).Hybrid polymerceramicmediaandsoap(RotoBrite)areaddedtothetumbler. Wastewaterfromthetumblerflows outofintothesecondarycontainmentforthetumbler.Someofthesolidssettleinsecondarycontainment andarecollectedforoffsitedisposal.Thewastewaterthenflowsoutofthesecondarycontainmentviaa whitePVCpipeintothetrenchdrainandintothesump(photo564).Thewastewaterinthesumppumpis senttoacentrifugewhereadditionalsolidsareremoved(photo565).RossReelstestedthewastewaterafter thecentrifugeinJune2022andprovidedtheresultstotheCity.Basedonthereviewoftheresults,theCity determinedthatRossReelsdidnotneedapretreatmentindustrialuserpermit. ThepartsthatneedanodizingaresentoffsitetoananodizingfacilityinCalifornia.InthefutureRossReelswill sendthepartstotheirnewanodizingfacilitylocatedinMontrose,Colorado.Afteranodizing,partsare returnedtotheMontrosefacilitywheretheyareassembledintothefinalproducts. Thestainlesssteelpartsareplacedinaspinnerforpolishing(photo561).Thewastewaterfromthespinneris filteredintoa5gallonbucketthatisstorednexttothesink(photo565)andthenplacedintoadrum(photo 562).Thewastewaterinthisdrumispumpedtotheevaporatorwhenitreachesacertainheight.Therewasa signabovethespinnerthatread,"Attention-Donotsendspinnerwaterdowndrain-Disposeofspinner waterinlabeledbin."RossReelsrepresentativesindicatedthatstaffaretrainednottosendspinnerwater downthedrain. 6.Whereiswaterusedandwhatisthesourceofthewater(city,well,river,etc.)? ThefacilityusesCitywaterinitsoperations,andtheapproximatemonthlyusageofwateris9,000to10,000 gallonswhichincludesprocesswastewaterandsanitarywastewater.Waterisusedformanufacturingofparts intheCNCmachinesandtocleanpartsinthetumblerandspinner. 7.Describetheprocesseswhichdischargewastewater. PleaserefertoSections5and9oftheinspectionreportforadescriptionoftheprocessesthatdischarge wastewater. Page 4 of 8 8.Describethesamplelocation.AretheCAandindustryusingthesamelocation? RossReelsdischargeswastewaterfromthetumblersafteritpassesthroughthecentrifuge(photo565).Ross Reelsindicatedthatapproximately80gallonsperdayfourtimesperweekaredischargedfromthecentrifuge totheCity'ssanitarysewer.RossReelstestedthewastewaterafterthecentrifugeinJune2022andprovided theresultstotheCity.Basedonthereviewoftheresults,theCitydeterminedthatRossReelsdidnotneeda pretreatmentindustrialuserpermit. 9.Describethetreatmentsysteminplace. Thefacilitydischargeswastewaterfromthetumblerintoasecondarycontainment(photo564),which collectssomeofthesolidsastheysettle.Thesolidsarecollectedanddisposedoffsite.Thewastewater thengoestothecentrifugewhichfurtherseparatessolids(photo565).Thesolidsarecollectedfromthe centrifugeanddisposedoffsite.ThewastewateristhendischargedtotheCity. TheCNCmachineshaveasumpwhereusedoilcollects.Theusedoilisdisposedoffsite(photo559). TheCNCmachinesarecleanedonaregularbasisandtheusedcoolantisstoredinatote(photo558).The usedcoolantissenttotheonsiteevaporator(photo560).Theliquidisevaporatedandthesolidsarecollected foroffsitedisposal.SafetyCleanremovesthesolidsanddisposesthemoffsite. 10.Whatchemicalsaremaintainedatthefacility?Howaretheystored?Isadequatespillpreventionin place? Thefacilitystores110gallonsofsemisyntheticmetalworkingfluidthatisusedintheCNCmachines (H8L25080D)(photo567).Therewerenodrainsinthisareaofthefacility. Thefacilityalsostoresthetumblersoap(RotoBrite)nexttothetumbler(photo566).Thetumblersoap containerwasstoredwithoutsecondarycontainmentnexttothetrenchdrainthatsendswastewatertothe centrifugewhichdischargestotheCitysewer.Therefore,thereisapotentialforaslugdischargefromthe tumblersoapiftherewasaspillorleakfromthetumblersoapcontainer.OnOctober13,2023,Mr.Lugard sentanemailresponseindicatingthatsecondarycontainmentwasinstalledonthetumblersoapand providedaphotoofthesecondarycontainment. 11.Areanyhazardouswastesstoredordischarged? TheRossReelsrepresentativesindicatedthatnohazardouswastesarestoredordischargedfromthe facility.Thefacilityrepresentativesindicatedthatthesolidscollectedintheevaporatorarenotconsidered hazardouswaste. FINDINGSANDCORRECTIVEACTIONS Thefollowingfindingswereidentifiedduringtheinspection.TheEPAhasrequestedtheCityworkdirectlywith RossReelstooverseecorrectionofthesedeficiencies.NoresponsefromRossReelstotheEPAisrequested atthistime. Page 5 of 8 Finding1-Thetumblersoapwasstoredwithoutsecondarycontainmentonthetrenchdrainsthat dischargestotheCity. Thefacilitystoresthetumblersoap(RotoBrite)nexttothetumbler(photo566).Thetumblersoapcontainer wasstoredwithoutsecondarycontainmentnexttothetrenchdrainthatsendswastewatertothecentrifuge whichdischargestotheCitysewer.Therefore,thereisapotentialforaslugdischargefromthetumbler soapiftherewasaspillorleakfromthetumblersoapcontainer.OnOctober13,2023,Mr.Lugardsentan emailresponseindicatingthatsecondarycontainmentwasinstalledonthetumblersoapandprovideda photoofthesecondarycontainment. PretreatmentRequirements Accordingtotherequirementsat40C.F.R.403.8(f)(2)(vi),thePOTWshalldevelopandimplement procedurestoensurecompliancewiththerequirementsofaPretreatmentProgram.Ataminimum,these proceduresshallenablethePOTWto,"EvaluatewhethereachsuchSignificantIndustrialUserneedsaplan orotheractiontocontrolSlugDischarges.ForIndustrialUsersidentifiedassignificantpriortoNovember 14,2005,thisevaluationmusthavebeenconductedatleastoncebyOctober14,2006;additional SignificantIndustrialUsersmustbeevaluatedwithin1yearofbeingdesignatedaSignificantIndustrialUser. Forpurposesofthissubsection,aSlugDischargeisanyDischargeofanonroutine,episodicnature, includingbutnotlimitedtoanaccidentalspilloranoncustomarybatchDischarge,whichhasareasonable potentialtocauseInterferenceorPassThrough,orinanyotherwayviolatethePOTW'sregulations,local limitsorPermitconditions.TheresultsofsuchactivitiesshallbeavailabletotheApprovalAuthorityupon request.SignificantIndustrialUsersarerequiredtonotifythePOTWimmediatelyofanychangesatits facilityaffectingpotentialforaSlugDischarge.IfthePOTWdecidesthataslugcontrolplanisneeded,the planshallcontain,ataminimum,thefollowingelements: (A) Descriptionofdischargepractices,includingnonroutinebatchDischarges; (B) Descriptionofstoredchemicals; (C) ProceduresforimmediatelynotifyingthePOTWofSlugDischarges,includinganyDischargethat wouldviolateaprohibitionunder403.5(b)withproceduresforfollowupwrittennotification withinfivedays; (D) Ifnecessary,procedurestopreventadverseimpactfromaccidentalspills,includinginspectionand maintenanceofstorageareas,handlingandtransferofmaterials,loadingandunloadingoperations, controlofplantsiterunoff,workertraining,buildingofcontainmentstructuresorequipment, measuresforcontainingtoxicorganicpollutants(includingsolvents),and/ormeasuresand equipmentforemergencyresponse." CorrectiveAction OnOctober13,2023,Mr.Lugardsentanemailresponseindicatingthatsecondarycontainmentwas installedonthetumblersoapandprovidedaphotoofthesecondarycontainment.Noadditionalresponse isrequiredatthistime. _________________________________________________________________________________________ Finding2-RossReelsnewanodizingfacilityneedstoapplyforazerodischargeindustrialuserpermit. RossReelsisbuildinganewanodizingfacility.Thenewanodizingfacilitylocatedat1331MayflyDrive,Suite G104,Montrose,ColoradoandisexpectedtobeginoperationsbytheendofDecember2023.RossReels Page 6 of 8 indicatedthattheanodizingprocesswillbeazerodischargeprocessbecausethewastewaterwillbe treatedinanevaporatorandthesolidswillbedisposedoffsite. OnNovember8,2023,Mr.LugardsentanemailtotheEPAindicatingthattheRossReelsmanufacturing facilitylocatedat1101MayflyDriveandthefutureanodizingfacilitylocatedat1331MayflyDriveSuiteG104 aretwononcontiguousbusinessparcelsandtwononcontiguousbuildings.Mr.Lugardindicatedthathewould submitazerodischargewastewaterpermitapplicationtotheCityforthefutureRossReelsanodizingfacility. SincetheRossReelsmachining(1101MayflyDrive)andthefutureanodizing(1331MayflyDrive,SuiteG 104)operationsoccurattwodifferentnoncontiguouslocations,theyareconsideredtwodifferentfacilities. Theanodizingfacility(1331MayflyDrive,SuiteG104)meetstheapplicabilitycriteriaformetalfinishing foundat40CFR433.10(a).RossReelsplanstoapplyforazerodischargewaterpermitfromtheCity,since thefacilityisnotplanningtodischargetheirwastewaterstotheCity.Themachiningfacility(1101Mayfly Drive)doesnotmeettheapplicabilitycriteriaformetalfinishingfoundat40CFR.10(a)becausethefacility doesnotperformanyofthesixmetalfinishingcoreoperations. RossReelsisrequiredtosubmitanindustrialuserpermitapplicationtotheCityforthenewanodizing facilityasrequiredbytheCityOrdinanceSection366. PretreatmentRequirements Sec.366.Industrialwastewaterdischargepermits. (A) IndustrialWastewaterDischargePermitsRequired.AllSignificantIndustrialUsersproposingto connecttoordischargewastewaterintothePOTWshallapplyforandobtainanIndustrial WastewaterDischargePermitfromtheCity.AnexistingSignificantIndustrialUserthathasfileda timelywastewaterIndustrialWastewaterDischargePermitapplicationinaccordancewiththese RegulationsmaycontinuetodischargeifauthorizedbytheCity. (B) NewIndustrialUsers;ApplyingforanIndustrialWastewaterDischargePermit.AnyIndustrialUser requiredtoobtainanIndustrialWastewaterDischargePermitwhoproposestobeginor recommencedischargingintothePOTWmustapplyforandobtainsuchpermitpriortothe beginningorrecommencingofsuchdischarge.TheIndustrialUsershallfileawastewaterIndustrial WastewaterDischargePermitapplicationonformsprovidedbytheCitycontainingtheinformation specifiedinSubsection(F)below.ThecompletedapplicationfortheIndustrialWastewater DischargePermitmustbefiledatleast90dayspriortothedateuponwhichanydischargewillbegin orrecommence.AnIndustrialWastewaterDischargePermitapplicationcontainingincompleteor inaccurateinformationwillnotbeprocessedandwillbereturnedtotheIndustrialUser.TheCity mayissueawastewaterIndustrialWastewaterDischargePermitatanytimeafterreceiptofthe completedwastewaterIndustrialWastewaterDischargePermitapplication. (C) ExistingIndustrialUsers;ApplyingforanIndustrialWastewaterDischargePermitReissuance.An IndustrialUserwithanexpiringanIndustrialWastewaterDischargePermitshallapplyforanew PermitbysubmittingacompletewastewaterIndustrialWastewaterDischargePermitapplicationat least90dayspriortotheexpirationoftheIndustrialUser'sexistingPermit.TheIndustrialUsershall fileawastewaterIndustrialWastewaterDischargePermitapplicationonformsprovidedbytheCity Page 7 of 8 containingtheinformationspecifiedinSubsection(F)below.AnIndustrialWastewaterDischarge Permitapplicationcontainingincompleteorinaccurateinformationwillnotbeprocessedandwillbe returnedtotheIndustrialUser.AnIndustrialUserwithanexistingIndustrialWastewaterDischarge Permitthathasfiledacompleteandtimelyapplicationmaycontinuetodischarge,asapprovedin writingbytheCity,throughanadministrativeextensionoftheexistingpermitifthedelayinpermit issuanceisnotduetoanyactorfailuretoactontheIndustrialUser'spart. (D) OtherIndustrialUsers.TheCitymayrequireotherIndustrialUserstoapplyforandobtainan IndustrialWastewaterDischargePermit,permitorothercontrolmechanismtocarryoutthe purposesoftheseRegulations.TheCitymayissueanIndustrialWastewaterDischargePermit,a zerodischargepermitorothercontrolmechanism,including,butnotlimitedto,authorizationsto dischargeandlettersauthorizingdischargeasdeterminedtobeappropriate. CorrectiveAction SubmitanindustrialuserpermitapplicationtotheCityofMontroseforthenewanodizingfacility.On November8,2023,Mr.LugardsentanemailresponseindicatingthattheRossReelsmanufacturingfacility andthefutureanodizingfacilityaretwononcontiguousbusinessparcelsandtwononcontiguousbuildings. TheRossReelsmanufacturingfacilityislocatedat1101MayflyDriveandthefutureRossReelsanodizing facilityislocatedat1331MayflyDriveSuiteG104.Mr.LugardrequestedapermitapplicationfromtheCity andindicatedthathewouldsubmitazerodischargewastewaterpermitapplicationtotheCityforthefuture RossReelsanodizingfacility.OnNovember29,2023theCitysentanindustrialuserpermitapplicationtoRoss Reelsforitsnewanodizingfacility.Mr.Lugardindicatedthattheywouldcompletetheindustrialuserpermit applicationandsendittotheCity.Healsoindicatedthatthegoalistohavetheanodizingfacilityoperational byDecember21,2023. Page 8 of 8 NPDES Inspection Report - Industrial User Name of industry and location: Control authority / Permit No. / Facility ID: Royal Crest Dairy, Inc. 800 Weaver Park Road Longmont, Colorado 80501 Date of visit: City of Longmont Permit No. 22-07-115 NPDES ID: COPU00170 Inspection ID: 202301_COPU00170 NAICS Code: 31151 - Dairy Product Manufacturing Latitude: 1/RQJLWXGH-105.075941W Time of visit: January 19, 2023 1:20 pm - 3:05 pm Name(s) / Affiliation of inspector(s): Stephanie Meyers / U.S. Environmental Protection Agency, Region 8 (lead) Emilio Llamozas / U.S. Environmental Protection Agency, Region 8 Mary Paterniti / City of Longmont Name / Title / Affiliation: Roy Ladrick / General Manager / Royal Crest Dairy, Inc. Terry Koenig / Maintenance Lead / Royal Crest Dairy, Inc. Report Review and Signature Drafter Name STEPHANIE STEPHANIE MEYERS Digitally signed by MEYERS Date: 2023.02.15 17:38:55 -07'00' Stephanie Meyers Reviewer Name Emilio Llamozas Supervisor Signature/Name MICHAEL BOEGLIN Digitally signed by MICHAEL BOEGLIN Date: 2023.02.15 08:12:24 -07'00' Michael Boeglin Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6938 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6407 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6250 Date 2/10/2023 Date 2/13/2023 Date 2/16/2023 Inspection Description: On January 19, 2023, U.S. Environmental Protection Agency (EPA) inspectors Stephanie Meyers and Emilio Llamozas (jointly referred to as inspectors) and the City of Longmont (City) inspector Mary Paterniti conducted an industrial user inspection of Royal Crest Dairy, Inc. (Royal Crest or facility) in Longmont, Page 1 of 5 Colorado as part of a pretreatment compliance inspection (PCI) of the City. The City had identified Royal Crest as a Significant Industrial User (SIU) permitted to discharge to the City's sanitary sewer system under Permit Number 22-07-115 (permit). The inspection was announced to Royal Crest the afternoon of the inspection. Upon arriving to the facility at approximately 1:20 pm, Mr. Koenig, Maintenance Lead for Royal Crest, introduced the inspectors to Royal Crest's General Manager, Roy Ladrick. The inspectors began the opening conference by presenting their credentials and explaining the general purpose and procedures of the inspection. During the opening conference, Mr. Ladrick provided an overview of the facility's operations, focusing on the processes that generate wastewater and the planned updates to the facility. Following the opening conference, Mr. Ladrick and Mr. Koenig accompanied the group of inspectors on a facility walkthrough, with focus placed on the processing and bottling of dairy products, chemical and waste storage areas, and the sampling point. To document and record the conversation and inspection observations, the inspectors took notes using bound checklists with questions applicable to the permitted industrial user. Photographs taken during the inspection are included in the attached photo log. EPA inspectors conducted a closing conference with Mr. Ladrick and Mr. Koenig and provided general observations and preliminary findings from the inspection. The EPA and City representatives left the facility at approximately 3:05 pm. 1. What does this industry produce? The facility is a dairy processing and bottling facility that produces various milk products, sour cream, buttermilk, yogurt, and ice cream. The facility also stores packaged food products that are made at other facilities for home delivery. 2. How is the industry classified by the POTW? The City classified Royal Crest as a Significant Industrial User (SIU) because the facility discharges an average of 25,000 gallons per day or more of process wastewater to the POTW, which is in accordance with 40 C.F.R. 403.3(v). The facility is also a categorical industry under 40 C.F.R Part 405: Dairy Products Processing Point Source Category, Subpart B - Fluids Products Subcategory, however there are no pretreatment standards established for this subcategory; therefore, the facility is subject to the requirements of 40 C.F.R. 403. 3. Have there been any significant changes in processes or flow? No changes have occurred at the facility since Royal Crest started operations in 1995. The facility has future sustainability plans that will likely reduce wastewater flows to 45,000 gallons per day. They also have plans to install an equalization tank system for pretreatment, where a lift station will pump the facility's wastewater to two 14,000-gallon tanks that will hold process wastewater and will monitor pH and turbidity. The planned tank upgrades are further described in Section 9. 4. What raw materials are used? The facility uses the following materials: Page 2 of 5 x Dairy products (milk, chocolate milk, sour cream, cream, buttermilk, yogurt, ice cream, etc.) x Sugar x Cocoa x Soy-based products x Various pre-packaged food products for home delivery only x Caustics x Sanitizers x Acids (sulfuric acid used for pH neutralization) 5. What processes are used to make the product(s)? Indicate any wastes generated and destination of wastes. Royal Crest receives tanker trucks of raw milk from Dairy Farmers of America and Mile High Dairy. The raw milk is placed into holding silos, and is then tested for bacteria, allergens, and butter fats. Raw milk that does not pass these tests is pumped to the 2,000-gallon slop tank in the tanker truck receiving bay (Photo 255). Facility representatives stated this milk is then pumped into a truck owned by McDonald Farms Enterprises, Inc. (Photo 256), who transports and treats the waste. According to facility representatives, McDonald Farms hauls off approximately six to eight 6,000-gallon loads each month. The raw milk that does pass all tests goes through a centrifuge to have fat contents separated out. The separated cream fat is used for various products and stored in a separate tank. The raw milk that had been separated then goes through the pasteurization process, where milk is heated to a specific temperature for a set time period to kill harmful bacteria. Once the pasteurization process is complete, milk is packaged into various bags, bottles, or cartons and stored in refrigerated rooms prior to being loaded up into trucks to be shipped out. Sometimes, the by-products of the milk, such as buttermilk and cream are used for other products. A culture tank is used for certain products such as buttermilk, sour cream, and yogurt. Royal Crest also produces chocolate milk, which requires the use of added product and a blender. Royal Crest conducts a clean-in-place (CIP) of all tanks using HydroxySan every 24 hours on production days. The CIP equipment has turbidity meters that measure the wastewater. High turbidity wastewater from the CIP process is pumped to the slop tank and hauled off by McDonald Farms Enterprises, Inc. The low turbidity wastewater is sent to the pH equalization tank. 6. Where is water used and what is the source of the water (city, well, river, etc.)? The facility uses City water in its operations, and the approximate monthly usage of water is 1.6 million gallons. Water is used for cleaning of tanks and rinsing of equipment. Both the boiler that pasteurizes the dairy products and refrigeration system also utilize water. 7. Describe the processes which discharge wastewater. Please refer to Sections 5 and 9 of the inspection report for a description of the processes that discharge wastewater. 8. Describe the sample location. Are the CA and industry using the same location? Royal Crest has two outfalls that discharge to the City's collection system; Outfall 01, which is the final discharge location and Outfall 02, which is the manhole downstream of Outfall 01 for the City's compliance Page 3 of 5 sampling. For the purpose of the permit, Outfall 02 is for City monitoring only and there are no additional sampling requirements for this outfall. Outfall 01 is a flume inside the private manhole in the parking lot in front of the processing building and downstream of the sand/oil interceptor. A pump pulls this water into a refrigerated ISCO sampler (Photo 259) for sample collection on Monday, Tuesday, Thursday, and Friday at 2:00 pm. A courier then picks up the samples each day, loads them into a cooler with ice, and takes them to the laboratory for analysis. The City takes their compliance sample at Outfall 01 and conducts independent monitoring at Outfall 02 which is a manhole downstream of Outfall 01. 9. Describe the treatment system in place. A drainage system in the production area captures all cleaning water and process wastewater and sends it to a 5,000 gallon pH equalization tank near the loading dock (Photo 257). CIP low turbidity wastewater and wastewater from cleaning the pasteurizer tanks is also sent through the pH equalization tank. The pH equalization tank is treated with sulfuric acid, if the pH needs to be lowered to meet the permit limits. The process wastewater then flows through a sand and oil separator, which is located underground via manholes near the loading dock (Photo 258). After this, wastewater then flows to the City's wastewater treatment system. The milk receiving bay also has a sand and oil separator that discharges downstream of the other sand and oil separator near the loading dock, but prior to Outfall 02. Section 3 describes the plans for a new treatment system. Facility representatives explained that when the new treatment system is in place, the pH equalization tank will no longer be used and will be removed from the facility. The facility plans to install a lift station that will pump the wastewater from the facility to two 14,000-gallon tanks. The two 14,000-gallon tanks that will be installed will be top-agitated tanks with CIP capabilities. They will also have containment structures around them should a spill event occur. Testing of tank water will be conducted prior to any discharge to the City for pH and turbidity. If the test results are above the BOD, TSS or pH permit limits, the wastewater will be hauled off by McDonald Farms Enterprises, Inc. in order to avoid permit exceedances. 10. What chemicals are maintained at the facility? How are they stored? Is adequate spill prevention in place? A 200-gallon tote of sulfuric acid is stored next to the pH equalization tank. 55-gallon drums of caustics and sanitizers (HydroxySan and Pro-Oxine) are stored in an area off of the processing room over secondary containment (Photo 260). Acids are stored in 55-gallon drums over secondary containment entirely separate from all other chemical storage areas (photo 261). 11. Are any hazardous wastes stored or discharged? No hazardous wastes are stored or discharged from the facility. FINDINGS AND CORRECTIVE ACTIONS The following findings were identified during the inspection. The EPA has requested the City work directly with Royal Crest to oversee correction of these deficiencies. No response from Royal Crest to the EPA is requested at this time. Page 4 of 5 Finding 1 - The facility did not include all of the required components in its Waste Management Plan (WMP). The facility's WMP is missing several of the elements required by the City pertaining to chemical storage and spills and a facility diagram. These required elements are found in the City Ordinance Section 14.08.350. The three elements that were missing in the WMP were: 1. An ongoing and complete inventory and description of the types and quantities of pollutants and chemicals used or stored by the industrial user; and 2. A diagram of the facility including the process and storage location(s), and the locations of floor drains to sanitary or storm sewers; and 3. A description of spill containment, treatment and disposal methods of pollutants and chemicals used or stored by the industrial user. Pretreatment Requirements According to the City Ordinance Section 14.08.350, the following elements are required to be in the facility's WMP and are currently missing: 1. An ongoing and complete inventory and description of the types and quantities of pollutants and chemicals used or stored by the industrial user; and 2. A diagram of the facility including the process and storage location(s), and the locations of floor drains to sanitary or storm sewers; and 3. A description of spill containment, treatment and disposal methods of pollutants and chemicals used or stored by the industrial user. Corrective Action Update the WMP for the facility that includes all the elements described above. Provide the City with a copy of the WMP. _________________________________________________________________________________________ Finding 2 - The ISCO sampler did not contain a backup thermometer. The ISCO sampler that pulls process wastewater from underground piping that flows to Outfall 01 did not contain a backup thermometer to ensure accuracy of temperature to meet samples preservation requirements of 6 C. Facility representatives stated the ISCO sampler temperature is calibrated once per year, but it is best practice to maintain another thermometer to ensure accuracy. Recommendation It is recommended that an independently calibrated thermometer be placed inside the ISCO sampler to ensure accurate temperature readings of the sampler to show that BOD and TSS samples are stored at below 6 C. Provide the City with a description of how this recommendation was addressed. Page 5 of 5 NPDES Inspection Report - Industrial User Name of industry and location: San Juan Fabrication and Powder Coating 2171 E. Main Street Montrose, Colorado 81401 Control authority / Permit No. / Facility ID: City of Montrose Facility does not have a City Pretreatment Industrial User Permit. NPDES ID: COPU00147 Inspection ID: 202309_COPU00147 Date of visit: Time of visit: September 27, 2023 8:10 am - 8:45 am Name(s) / Affiliation of inspector(s): Emilio Llamozas / U.S. Environmental Protection Agency, Region 8 (lead inspector) Stephanie Passarelli / U.S. Environmental Protection Agency, Region 8 Hyrum Webb / City of Montrose Name / Title / Affiliation: Gabe Welfelt / Owner / San Juan Fabrication and Powder Coating Report Review and Signature Drafter Name STEPHANIE STEPHANIE PASSARELLI Digitally signed by PASSARELLI 12:55:58 -07'00' Date: 2023.12.19 Stephanie Passarelli Reviewer Name Emilio Llamozas Supervisor Signature/Name EMILIO Digitally signed by EMILIO LLAMOZAS LLAMOZAS 11:25:56 -07'00' Date: 2023.12.19 Emilio Llamozas Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6803 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6407 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6407 Date 12/14/2023 Date 12/19/2023 Date 12/19/2023 Page 1 of 5 Inspection Description: On September 27, 2023, U.S. Environmental Protection Agency (EPA) inspectors Emilio Llamozas and Stephanie Passarelli (jointly referred to as inspectors) and the City of Montrose (City) inspector Hyrum Webb conducted an industrial user inspection of San Juan Fabrication and Powder Coating in Montrose, Colorado as part of a pretreatment compliance inspection (PCI) of the City. San Juan Fabrication and Powder Coating was previously inspected in 2017 and was determined to be a non-significant industrial user. The inspectors stopped by the facility unannounced on September 26th to conduct a facility inspection. However, at the time Mr. Welfelt was out town, and requested the inspectors return on September 27th to complete a walkthrough of the facility. On September 27th, upon arrival at the facility at approximately 8:10 am, the inspectors conducted the opening conference, presented their inspector credentials, and explained the general purpose and procedures of the inspection. During the opening conference, Mr. Welfelt provided an overview of the facility's operations, including identification of any processes that have potential for spills and slug discharges. Following the opening conference, Mr. Welfelt provided a walkthrough of the facility to visually review the unit processes discussed during the opening conference. To document and record the conversation and inspection observations, the inspectors took notes using checklists with questions applicable to the industrial user. Photographs taken during the inspection are included in the attached photo log. EPA inspectors conducted a closing conference with Mr. Welfelt and provided general observations and preliminary findings from the inspection. The EPA and City representatives left the facility at approximately 8:45 am. On October 12, 2023, the EPA sent preliminary findings from the inspection via email to Mr. Welfelt. Findings were primarily stormwater focused and reiterated in this inspection report. 1. What does this industry produce? San Juan Fabrication and Powder Coating produces custom products (i.e., hand railings, stairs, wall art) according to customer specifications and orders. The facility conducts cutting, welding, fabrication, and powder coating unit processes. 2. How is the industry classified by the POTW? The City previously classified San Juan Fabrication and Powder Coating as non-significant Industrial User (IU) and had not required a pretreatment industrial user permit for this facility. 3. Have there been any significant changes in processes or flow? Since the last inspection at this facility in 2017, there have been no changes in the facility operations. Page 2 of 5 4. What raw materials are used? The facility uses the following materials: x Stainless steel x Steel x Aluminum x Oil x Synthetic cutting fluid (Kimball Midwest) x Denatured alcohol 5. What processes are used to make the product(s)? Indicate any wastes generated and destination of wastes. San Juan Fabrication and Powder Coating produces custom made products according to customer specifications. Raw materials including stainless steel, steel and aluminum, are received and proceed through either cutting, welding, fabrication or powder coating operations dependent on final product. The fabrication process line uses small quantities of cutting oil/fluid in the fabrication machines and then weld together parts to form final product. A 5-gallon container of synthetic cutting oil used in the machines is stored in the shop (photo 568), no wastewater is used or discharged from this process line. Following fabrication, products requiring powder coating are first transported to the sand blasting booth located outside behind the main shop. Coal slag is used in sandblasting to remove any burrs, rust, or previous finishes. Parts are then transported to the powder coating booth located in an adjacent building behind the main shop. Products are cleaned by spraying with denatured alcohol and then wiped down with wipes which are disposed of in the trash. A 5-gallon bucket of denatured alcohol is shown in photo 569. Parts are placed in the powder coating booth (photo 571), and negatively charged as powder coating is applied. The parts are then sent to the oven to cure the powder coat finish (photo 572). Finished products are then delivered to customers. No acid wash or phosphate wash is conducted, and no wastewater is used or discharged from this process line. 6. Where is water used and what is the source of the water (city, well, river, etc.)? The facility is provided water from the City for domestic uses only. No process operations require water. 7. Describe the processes which discharge wastewater. The facility does not discharge any process wastewater, only domestic wastewater is discharged. 8. Describe the sample location. Are the CA and industry using the same location? Based on review and prior inspections, the City determined that San Juan Fabrication and Powder Coating does not need a pretreatment industrial user permit, and therefore does not conduct any wastewater sampling. Page 3 of 5 9. Describe the treatment system in place. N/A. The facility does not discharge any process wastewater, only domestic wastewater is discharged. 10. What chemicals are maintained at the facility? How are they stored? Is adequate spill prevention in place? The facility stores only small quantities of chemicals on site including: 5 gallons of synthetic cutting oil (Kimball Midwest) (photo 568), and 5 gallons of denatured alcohol (photo 569). A 55-gallon drum of used oil was place outside and collected any spent oil from operations, and properly disposed of offsite. In addition, in the back of the facility outside between the sandblast booth and the powder coating booth, the facility has a 100-gallon diesel fuel storage tank (photo 570). There was no secondary containment observed for the diesel tank. Several gasoline containers were also observed on the ground near the fuel tank. Inspectors recommended any small gasoline containers be stored inside, or properly dispose of used containers. 11. Are any hazardous wastes stored or discharged? Representatives indicated that no hazardous wastes are stored or discharged from the facility. FINDINGS AND CORRECTIVE ACTIONS The following findings were identified during the inspection. The EPA has requested the City work directly with San Juan Fabrication and Powder Coating to oversee correction of these items. No response from San Juan to the EPA is requested at this time. Finding 1 - No secondary containment for outdoor diesel fuel storage tank. A 100-gallon diesel tank is located outside behind the machine shop, between the powder coating building and the sand blasting booth. The tank is elevated on a stand; however, no secondary containment was present (photo 570). In addition, two discarded empty 5-gallon gasoline fuel containers were in the area. Pretreatment Requirements None - not permitted IU. Corrective Action On October 12, 2023, inspectors sent preliminary findings to Mr. Welfelt recommending a secondary containment structure be provided to prevent any potential stormwater runoff concerns should a spill or failure of the fuel tank occur. Also recommended to store gasoline containers inside the buildings or properly dispose of old containers. _________________________________________________________________________________________ Finding 2 - Spent coal slag from the sand blasting booth was on the ground outside the enclosed sand blasting booth. Page 4 of 5 During inspection of the outside process area, spent coal slag from the sand blasting booth was observed extend from the booth area into the common walkway and surrounding area, which could runoff during precipitation events. Pretreatment Requirements None - not permitted IU. Recommendations: On October 12, 2023, inspectors sent preliminary findings to Mr. Welfelt recommending routine cleaning of sand blasting booth to ensure spent media, residual coal slag (Black Magic), is contained within the sandblasting booth. Keeping the powder within the sand blasting booth and proper disposal of spent media prevents any potential stormwater runoff. Page 5 of 5