Document RJ3o5dm0X4XB001X3g5Y1zd2k

Pretreatment Compliance Inspection: CWA Authority, Indianapolis, Indiana Control Authority Name and Address CWA Authority, Inc. 2020 N. Meridian Street Indianapolis, Indiana 46201 Responsible Official Jeffrey Hansen, Director of Wastewater Plant Operations Inspection Participants CWA Authority Ann McIver, Director of Environmental Stewardship Cheryl Carlson, Manager, Environmental Compliance, Environmental Stewardship Jeff Guinn, Pretreatment Programs Supervisor Beth Noel, Environmental Specialist Keith Holsinger, Environmental Specialist Nathaniel Berg, Environmental Specialist Indiana Department of Environmental Management Mary Armacost, Pretreatment Coordinator U.S. Environmental Protection Agency Valerie Dooling, Environmental Engineer Megan Bobb, Life Scientist Newton Ellens, Pretreatment Program Coordinator Inspection Dates: May 19 to 22, 2025 Newton Ellens, Inspector: NEWTON Digitally signed by NEWTON ELLENS Inspector Signature: ______E_L__L_E_N__S______15_:0_0:_23_-0_5'_00_' ________ Date: 2025.07.24 Molly Smith, Section 1 Supervisor, Water Enforcement Compliance Assurance Branch: MOLLY Digitally signed by MOLLY SMITH Approver Signature: _S_M__I_T_H________15_:4_9:3_2_-0_5'_00_' __________________ Date: 2025.07.24 Contents SECTION 1.0: INTRODUCTION............................................................................................................. 3 SECTION 2.0: SITE BACKGROUND AND PRELIMINARY REVIEW ........................................................... 3 SECTION 3.0: SUPPLEMENTAL DATA REVIEW/INTERVIEW INFORMATION .......................................... 4 A. Pretreatment Program Modification: .........................................................................................4 B. Legal Authority: ...........................................................................................................................4 C. IU Characterization:.....................................................................................................................4 D. Hauled Waste:.............................................................................................................................4 E. Application of Pretreatment Standards and Requirements .......................................................5 F. Compliance Monitoring: ..............................................................................................................5 G. Enforcement:...............................................................................................................................5 H. Data Management/Public Participation:....................................................................................6 SECTION 4.0: FILE REVIEWS ................................................................................................................ 6 4.1 IU Identification ..............................................................................................................................6 4.2 Facility Information .........................................................................................................................7 4.3 IU Evaluation .................................................................................................................................10 A. Issuance of IU Control Mechanism ...........................................................................................10 B. Application of IU Pretreatment Standards: ..............................................................................12 C. CA Compliance Monitoring .......................................................................................................12 D. CA Enforcement Activities ........................................................................................................13 E. IU Self-Monitoring and Reporting .............................................................................................13 SECTION 5.0: SUMMARY OF FINDINGS ............................................................................................. 14 A. Areas of Concern........................................................................................................................14 ATTACHMENT I: INDUSTRIAL USER SITE VISIT REPORTS ATTACHMENT II: ARCWOOD ENVIRONMENTAL PHOTO LOG ATTACHMENT III: CROSSROADS FARMS DAIRY PHOTO LOG ATTACHMENT IV: SVC MANUFACTURING, INC. PHOTO LOG ATTACHMENT V: LIST OF INDUSTRIAL USERS THAT SUBMITTED HAZARDOUS WASTE NOTIFICATIONS TO CWA AUTHORITY 2 SECTION 1.0: INTRODUCTION The U.S. Environmental Protection Agency (EPA) conducted a Federal Pretreatment Compliance Inspection (PCI) of the CWA Authority, Inc., Belmont and Southport Advanced Wastewater Treatment Plants (Belmont and Southport AWTPs or POTW) from May 19 to 22, 2025. The purpose of the inspection was to investigate the procedures and implementation of CWA Authority's pretreatment program. CWA Authority has a National Pollutant Discharge Elimination System (NPDES) Permit-- Permit No. IN0023183 (Permit IN0023183). Part III.A. of Permit IN0023183 states that CWA Authority is required to operate its approved industrial pretreatment program, approved on March 29, 2016, and any subsequent approved modifications. EPA's inspection consisted of: 1. Review of requested submittals prior to on-site inspection; 2. Interviews and discussion with CWA Authority staff; 3. Industrial User (IU) file reviews; and 4. Site visits at four IUs: Ecobat Resources, SVC Resources, Crossroads Farms Dairy, and Arcwood Environmental. On May 19, 2025, at 7:40 a.m., E.T., inspectors Newton Ellens, Valerie Dooling, and Megan Bobb (EPA staff) arrived at the CWA Authority office, located at 2020 N. Meridian Street, Indianapolis, Indiana. There, they met CWA Authority and Indiana Department of Environmental Management (IDEM) staff. EPA inspectors presented their credentials and began the inspection. SECTION 2.0: SITE BACKGROUND AND PRELIMINARY REVIEW The Belmont AWTP has a design flow rate of 120 million gallons per day (MGD) and an average flow rate of 95.6 MGD. The Belmont AWTP has the following treatment processes: 1. Primary: screening, grit removal, and primary clarifiers; 2. Secondary: oxygen/air nitrification systems and final clarifiers; and 3. Tertiary: tertiary filters, chlorine and ultraviolet disinfection. The Southport AWTP has a design flow rate of 125 MGD and an average flow rate of 91.3 MGD. The Southport AWTP has the same treatment processes as the Belmont AWTP. Permit IN0023183 states: Flow from the Belmont AWTP can be diverted to the Southport AWTP during both wet and dry weather. The sludge generated at the Southport AWTP plant is pumped to the Belmont AWTP plant for treatment and ultimate disposal. The Belmont and Southport AWTPs function and are operated as a single system. 3 SECTION 3.0: SUPPLEMENTAL DATA REVIEW/INTERVIEW INFORMATION A. Pretreatment Program Modification: CWA Authority is reviewing the format and current language of its sewer use ordinance (SUO), and according to CWA Authority this review is being done with the intent to improve its clarity. CWA Authority intends to produce a proposed draft for review in late 2025 or early 2026. B. Legal Authority: CWA Authority has interjurisdictional agreements with seven satellite communities. The agreements are implemented through a contract that applies to each satellite community. CWA Authority implements the pretreatment program on behalf of contributing jurisdictions with industrial users. Whitestown is a community that disconnected from the CWA Authority system 10 years ago; the community built a 2 MGD wastewater treatment plant. Currently, a pipe that connects Whitestown's collection system to CWA Authority's system is broken. Whitestown, however, could potentially bypass the broken pipe and pump its wastewater into CWA Authority's POTW, so Whitestown's interjurisdictional agreement with CWA Authority is still in effect. C. IU Characterization: CWA Authority identifies Significant Industrial Users (SIUs) through different methods and sources, including: Sources that contact the Pretreatment Program or CWA Authority, Inc. directly; Internal coordination within the organization with Business Development, Billing, and sewer permitting teams; Review of local resources including news and internet; Complaint responses; Coordination with contributing jurisdictions; and IDEM public notices. As of May 1, 2025, CWA Authority has 31 non-categorical SIUs and 19 Categorical Industrial Users (CIUs). CWA Authority does not classify any of its CIUs as non-significant. CWA Authority requires new CIUs to submit a baseline monitoring report 90 days prior to discharging. D. Hauled Waste: CWA Authority does accept hauled wastewater from groundwater remediation sites. There are two types of control mechanisms CWA Authority uses for groundwater remediations sites: Long-term: This is for discharges expected to last a year or more. CWA Authority evaluates whether these sites should be permitted. If CWA Authority determines that a site does not need a discharge permit, then it may simply monitor its discharge to assess surcharges. Currently, CWA Authority has two long-term groundwater remediation sites. Short-term: This is for discharges that are expected to last less than a year. Special discharge agreements apply to short-term dischargers. 4 CWA Authority has a hauled waste program: Hauled waste discharges are only allowed only at the Belmont AWTP headworks. The Belmont AWTP is secured with fencing, a security guard, and a gate attendant. Hauled waste is only accepted during business hours. All loads are pre-screened through visual assessment and pH monitoring. Pre-approval required for any wastewater that is non-domestic. Each load is sampled. Samples are retained, for if an issue arises. A hauler ticket is generated for each load. E. Application of Pretreatment Standards and Requirements Combined sewer system: The sewer system in the Indianapolis city center is combined. The sewer system outside the city center is separate. During rain events, CWA Authority sends a notification (via email or text) to certain IUs within the combined sewer system. The email instructs each IU to pause its discharge. CWA Authority determined which IUs should stop discharging (during rain events) through modeling. The Indianapolis International Airport has a basin to hold its wastewater. CWA Authority has local limits for total petroleum hydrocarbons, pH, arsenic, berylium, cadmium, total chromium, hexavalent chromium, copper, amenable cyanide, lead, mercury, nickel, total phenols, pentachlorophenol, selenium, silver, and zinc. CWA Authority uses a uniform allocation for local limits. F. Compliance Monitoring: Generally, CWA Authority conducts annual SIU inspections. CWA Authority may conduct more frequent inspections, based upon the circumstances. CWA Authority analyzes samples for pH, temperature, and lower explosive limit (LEL). For all other samples, CWA collects each sample, and ESG (a contract laboratory) conducts the sample analysis. Certain IUs have notified CWA Authority of hazardous waste discharges. CWA Authority provided copies of hazardous waste discharge notifications to EPA (Attachment V).1 For slug discharge control plans: During each SIU inspection, CWA Authority evaluates whether the SIU should have a slug discharge control plan. G. Enforcement: CWA Authority had a long history of enforcement against Metalworking Lubricants, a centralized waste treatment facility. CWA Authority cited Metalworking Lubricants for discharging oily waste that discharged through one of CWA Authority's combined sewer overflow points in September 2019. In addition, Metalworking Lubricants had multiple exceedances of pretreatment standards. CWA Authority's enforcement against Metalworking Lubricants included issuance of a compliance agreement, multiple notices of violation, penalties, a notice of administrative hearing, and a 1 EPA did not locate any records of corresponding hazardous waste discharge notifications. 5 termination of service. Metalworking Lubricants relinquished its industrial user permit and stopped discharging process wastewater to the sewer by December 1, 2022. According to testing conducted in May and June of 2023, the Southport AWTP's effluent exceeded toxicity limits under Permit IN0023183. Subsequently, CWA Authority has conducted a toxicity reduction evaluation (TRE) for the Southport AWTP. It conducts interceptor testing as part of its evaluation. CWA Authority submitted a seventh quarterly report under the TRE on March 31, 2025. CWA Authority's testing has not identified a source of the toxicity. CWA stated that it is considering different factors that may affect test results (e.g., cross-contamination of sampling equipment, disinfection at the wastewater treatment plant, stormwater sources, sources of quaternary ammonia, etc.) H. Data Management/Public Participation: CWA Authority currently uses Linko software for data management. CWA Authority is in the process of transitioning to a new data management system (KLIR). Currently, all IUs submit paper self-monitoring reports. CWA Authority plans to use a Cross-Media Electronic Reporting Rule (CROMERR)-compliant system to receive self-monitoring reports from industrial users. SECTION 4.0: FILE REVIEWS 4.1 IU Identification IU Permit Number 285901 739901 283008 IU Name Aurorium Indianapolis LLC Arcwood Environmental, LLC Vesta Pharmaceuticals, Incorporated IU Type NonCategorical SIU CIU CIU Avg total flow (gpd) 600,000 56,425 230 Avg process flow (gpd) 350,000 49,855 10 Visited During Audit? no yes no Reviewer Valerie Dooling Mary Armacost Megan Bobb Categorical Pretreatment Standard N/A 40 CFR 437 CENTRALIZED WASTE TREATMENT POINT SOURCE CATEGORY 40 CFR 439 PHARMACEUTICAL MANUFACTURING POINT SOURCE CATEGORY 6 IU Permit Number IU Name 202601 Crossroads Farms Dairy 334104 Ecobat Resources Indiana, LLC 353702 Nelson Global Products Inc 203303 SVC Manufacturing, Inc. 281901 Micronutrients USA, LLC IU Type NonCategorical SIU CIU CIU NonCategorical SIU CIU Avg total flow (gpd) 214,000 267,000 72,000 652,454 Avg process flow (gpd) 188,000 262,000 38,500 628,854 43,553 Visited During Audit? yes yes no no no Reviewer Valerie Dooling Megan Bobb Mary Armacost Newton Ellens Newton Ellens Categorical Pretreatment Standard N/A 40 CFR 421 NONFERROUS METALS MANUFACTURING POINT SOURCE CATEGORY 40 CFR 433 METAL FINISHING POINT SOURCE CATEGORY N/A 40 CFR 415 INORGANIC CHEMICALS MANUFACTURING 4.2 Facility Information Aurorium Indianapolis LLC. 1500 South Tibbs Avenue Indianapolis, Indiana 46241 Prior to July 14, 2023, Aurorium Indianapolis LLC (Aurorium) was called Vertellus Integrated Pyridines LLC. Previously, CWA Authority categorized Aurorium as subject to the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) category. On April 3, 2024, the facility stopped discharging categorical process wastewater. Currently, it only discharges non-process wastewater. CWA Authority issued a revised permit to Aurorium to account for the name change and to remove the OCPSF categorical designation. The information listed below--and the associated file review--applies to the time when Aurorium was subject to the OCPSF category (i.e., prior to April 3, 2024): Source of wastewater: Four individual operating units generate process wastewater. Process wastewater is generated in reactions, and by water that comes into direct contact with the chemical processes. 7  Final products: The industrial user is a synthetic organic chemical plant that produces pyridine, picolines, vinylpyridines and related compounds. Pretreatment: Wastewater is stored in tanks prior to pretreatment. The water is first pH adjusted with sulfuric acid to a target range of 8-9. A flocculant is added to the wastewater in a clarifier where solids settle and are transferred to a tank for processing. The wastewater is then sent through multimedia filters to further remove solids. Finally, the wastewater is steam stripped to remove volatile organic compounds prior to discharge. The wastewater is then sent through a heat exchanger to cool it prior to discharging to the sewer. The solids from the clarifier are sent through a filter press. The solids from the filter press are dropped into a hopper, transferred to a roll-off and landfilled. Type of discharge: continuous Arcwood Environmental, LLC 7901 W, Morris St Indianapolis, Indiana 46231 Production process description: The facility is a centralized waste treater. It treats metalbearing and organic-bearing wastewater. Pretreatment: Processes consist of chemical precipitation, cyanide destruction, and pH adjustment, sedimentation, and a sludge filter press. Sewer outfalls: There are four outfalls: o 01 - Combined, o 02 - Metal Bearing, o 03 - Organics bearing, and o 04 - Cyanide treatment Type of discharge: batch Vesta Pharmaceuticals, Incorporated 5767 Thunderbird Road Indianapolis, Indiana 46236 Facility produces pharmaceutical supplements in capsule, tablet, or powder form and ships them out in bulk or retail. The facility takes in the raw materials, blend them together to create the product, and encapsulate, tablet, or powder fill as necessary. The facility then packages the products for bulk or retail. There are four cleaning streams: blending, powder packaging, encapsulation and tableting, and capsule/tablet packaging. In all of these cleaning streams the excess product is removed, walls and floors are swept, rinsed, and treated with cleaning solution. Everything is rinsed, collected, and dumped down the drain continuously. The facility does not employ any wastewater treatment. 8 Crossroads Farms Dairy 400 S Shortridge Road Indianapolis, Indiana 46219 Sources of wastewater: o Water used for flushes between batches of ice cream product or for sanitation of the ice cream filing equipment and related conveying systems. o Water used for flushing and cleaning of milk pasteurizing equipment and ice cream clean in place equipment as well as the clean in place of the milk filing room, caser stacking room, cooler and cooler floor chain lubrication. o Raw milk tank clean in place operation. Final products: Fluid milk, orange juice, apple cider, fruit flavored drinks, teas, bottled water, ice cream, ice cream novelties and fruit bars. Pretreatment: There are no pretreatment processes. Outfall description: There is one outfall. Type of discharge: continuous. Ecobat Resources Indiana, LLC 7870 West Morris St. Indianapolis, Indiana 46231 The facility was formerly called Quemetco. The facility was incorporated on February 15, 2023. The facility makes both polypropylene pellets and lead ingots/bars from spent lead batteries. The facility takes in the batteries and uses battery cracking to separate the lead and case components. The facility uses furnace wet air pollution control and kettle wet air pollution control to control the production area--this generates wastewater. Wastewater is combined and treated using neutralization, coagulation, flocculation, clarification, and sand filtration. There is one outfall to the sewer system and two monitoring points, one for the POTW and one for the facility. The facility discharges in batches, usually 15 batches per day. Nelson Global Products Inc 2840A Fortune Circle Drive West Indianapolis, Indiana 46241 Process description: The facility produces tubular or sheet metal fabricated components for diesel engines or related equipment. Final products: The facility produces parts various for Caterpillar and airlines. Pretreatment: There is no treatment of the process water. Type of discharge: continuous 9 SVC Manufacturing, Inc. 5858 Decatur Blvd. Indianapolis, Indiana 46421 The permittee is a beverage manufacturing facility for bottled and canned soft drink and carbonized water. The site has eight production lines. Six of these lines are used to produce beverages including Gatorade, G2, Propel, and Recover. The newest line is for production of non-traditional beverages that are not conductive to hot-fill, such as protein shakes. The plant also produces concentrate and beverage in bag-in-box packaging. The wastewater pH balancing system consists of two pit basins (primary and secondary). The facility typically discharges continuously. However, it does have the ability to discharge batches (for off-spec product). Micronutrients USA, LLC 1550 Research Way Indianapolis, Indiana 46231 The facility produces copper chloride salt and solution and ammonium hydroxide/ammonium chloride alkaline etchant solutions primarily from waste copper-laden etchants. Feedstock is manufactured from a copper shop. Regulated wastewater is collected throughout the plant and transferred to a raw water storage tank (T-921). The wastewater is transferred to tank T-922, where sodium hydroxide is added to precipitate metal constituents. The clarified wastewater is transferred through filter cartridges and transferred to wastewater storage tank T-931. The sludge from T-922 is sent to a filter press. The dewatered wastewater is sent back to T-922 for treatment. The treated wastewater is transferred to tank T-931, where it is analyzed prior to discharge. Approximately 700 gallons per day (gpd) is discharged in batches. Categorical limits are applied at the end of process, prior to combining with dilution flows: boiler blowdown (100 gpd), sanitary wastewater (2,500 gpd) and air compressor condensate. 4.3 IU Evaluation A. Issuance of IU Control Mechanism Statement of Non-transferability Each IU permit does not include a requirement for the IU to provide a copy of the existing IU permit to the new owner or operator. 10 Applicable effluent limits (local limits, categorical standards, Best Management Practices) Crossroads Farms Dairy - None of the local limits from Table 1 of the SUO (CWA 2-2011) were included in the permit. Ecobat Resources Indiana, LLC - The permit does not include limits for: beryllium, chromium, hexavalent chromium, amenable cyanide, mercury, nickel, total phenols, pentachlorophenol, or selenium. Nelson Global Products - The IU permit states that the IU may submit a certification statement and a toxic organic management plan (TOMP). The IU has a TOMP; the IU permit, however, does not indicate whether the IU has submitted a specific TOMP that satisfies CWA Authority. A TOMP must include best management practices, including the method of disposal used instead of dumping and procedures for ensuring that toxic organics do not routinely spill or leak into the wastewater. The IU permit, however, does not incorporate the TOMP's requirements. Sample types (grab or composite) Nelson Global Products Inc - The IU permit has time proportional sampling requirements. However, the IU's daily flow varied more than 20 % of the average flow. Out of 36 months for flow rate data, 19 months had flow rates that were more than 20% different from the average flow (9 rates below average and 10 rates above average). Record-keeping requirements Each IU permit does not require the IU to make records available for inspection and copying by the EPA, nor does it extend the record retention period during the course of any unresolved litigation regarding the Industrial User or POTW or when requested by EPA. Notice of slug loading SVC Manufacturing and Micronutrients: Each IU permit requires the IU to notify the POTW about a slug within one hour of discovery of the slug, as opposed to requiring immediate notification. Notification of spills, bypasses, upsets, etc. IU permits reference SUO for requirements to establish the affirmative defense of an upset. The IU, however, does not list the associated upset notification requirements under 40 C.F.R. 403.16(c)(3). Notification by IU of hazardous waste discharge Each SIU permit includes a hazardous waste discharge notification requirement. The notification requirement, however, does not incorporate all of the notification requirements under 40 C.F.R. 11  403.12(p). B. Application of IU Pretreatment Standards: Classification as new/existing source Micronutrients: According to the IU permit, the IU is subject to pretreatment standards for new sources (PSNS).2 However, the IU permit file does not include the date when the facility was constructed. CWA Authority obtained information online indicating that construction commenced on 11/8/94. Ecobat Resources Indiana, LLC - The IU permit application does not include the date the IU's operations began. During the inspection, the POTW used IDEM files to determine when the IU's operations and to verify the classification as an existing source. Calculation and application of production-based standards Ecobat Resources Indiana, LLC - Monthly lead production rates show a decline over the last 3 years. The production-based standards in the IU permit, however, are based upon the original production rates written in the permit application. Application of most stringent limit Micronutrients: The IU permit includes a zinc local limit at the "end of process," instead of the "end of pipe." Local limits are applied at the "end of pipe," (the point of connection to the CWA collection system). C. CA Compliance Monitoring Analysis for all regulated parameters Arcwood Environmental, LLC - The POTW did not sample the IU for selenium. The POTW only sampled a subset of local limit pollutants that are listed in the IU permit.3 Vesta Pharmaceuticals, Incorporated - CWA Authority did not sample the IU for local limit parameters. 2 The new source date for Part 415, Subpart AJ (excluding CuSO4) is 10/25/83. 3 EPA and IDEM staff noted that CWA Authority's SIU sample analysis results did not include results for selenium, a local limit pollutant. CWA responded that they did collect selenium samples at SIUs, but they did not consider selenium sampling to be a requirement. CWA Authority recently added selenium limits to the SIUs' permits. CWA Authority has appealed the selenium limit in Permit IN0023183, and it expects the limit to be removed. CWA Authority would then remove the selenium local limit from its SUO. However, the selenium local limit was established in CWA Authority's SUO as early as August 15, 2018 (the date of the SUO's latest amendment). Therefore, per 40 C.F.R. 403.8(f)(2)(v), CWA Authority is required to conduct sample analysis for selenium at each SIU. 12 Crossroads Farms Dairy - CWA Authority did not sample the IU for arsenic, beryllium, cadmium, chromium (T), chromium (hex), copper, cyanide (amenable), lead, mercury, nickel, total phenols, pentachlorophenol, and silver. Ecobat Resources Indiana, LLC - CWA Authority did not collect samples for beryllium, chromium, amenable cyanide, mercury, nickel, total phenols, and pentachlorophenol. Nelson Global Products Inc - CWA Authority did not collect samples for arsenic, beryllium, hexavalent chromium, amenable cyanide, mercury, total phenols, pentachlorophenol and TTO. SVC Manufacturing, Inc.: The POTW does not collect samples for arsenic, beryllium, cadmium, chromium (T), chromium (hex), copper, cyanide (amenable), lead, mercury, nickel, total phenols, pentachlorophenol, selenium, silver, zinc, and total petroleum hydrocarbons. Micronutrients USA, LLC: The POTW sample analytical reports do not include results for the following local limit pollutants: arsenic, beryllium, cadmium, chromium, hexavalent chromium, amenable cyanide, lead, mercury, total phenols, pentachlorophenol, silver, and total petroleum hydrocarbons. D. CA Enforcement Activities Identification of discharge violations Micronutrients USA, LLC: Sample analytical results (for a sample collected at Building 400 by the POTW on 9/28/23) shows a result of 1.28 milligram per liter (mg/L) of copper. This exceeds the categorical monthly average limit for copper (1.1 mg/L). According to the files, the POTW did not collect any additional copper samples at Building 400 in September 2023. POTW staff stated that the last enforcement action taken against Micronutrients was in 2020. E. IU Self-Monitoring and Reporting Sampling by IU at frequency specified in control mechanism/regulations Crossroads Farms Dairy - There are sample analysis results that the facility collects that are not included on the facility's self-monitoring reports. Analysis by IU of all required pollutants in accordance with appropriate sampling techniques and analytical methods Nelson Global Products Inc - Detection limits for TTOs sampled on May 26, 2022, were too high to determine compliance. Detection limits ranged from 20 microgram per liter (ug/L) to 500 mg/L. The majority of detection limits were 100 ug/L. 13 Micronutrients USA, LLC - Sample analysis reports do not indicate the analytical method used for pH monitoring. Micronutrients USA, LLC - self-monitoring reports do not include results for nickel, selenium, and zinc. The IU permit includes monitoring requirements for these pollutants. IU submission/implementation of slug discharge control plan SVC Manufacturing: The IU does have a slug control plan, dated October 8, 2021. The plan requires the IU to notify the POTW about accidental discharges to the sewer within one hour of knowing about the incident, as opposed to requiring immediate notification. Notification of significant change in production Ecobat Resources Indiana, LLC - The IU has production-based limits. According to the IU's selfmonitoring reports, The IU's pounds of lead scrap production appear to vary significantly: Reporting period July to December 2024 January 2023 to June 2023 Highest lead scrap production rate (pounds per month) 28,587,930 (July 2024) 21,641,000 (February 2023) Lowest lead scrap production rate (ponds per month 22,947865 (October 2024) 27,142,000 (May 2023) Despite the significant production changes, the IU file did not include IU notifications of significant production changes. Production-based reports Ecobat Resources Indiana, LLC - The IU's self-monitoring reports do not include a reasonable measure of the IU's actual long-term daily production rate. SECTION 5.0: SUMMARY OF FINDINGS A. Areas of Concern 40 C.F.R. 403.8(f)(1)(iii)(B) (2) 403.8(f)(1)(iii)(B) (3) File Reviews Each IU permit does not include a requirement for the IU to provide a copy of the existing IU permit to the new owner or operator. Crossroads Farms Dairy - None of the local limits from Table 1 of the SUO (CWA 2-2011) were included in the permit. Report Section 4.3 A. 4.3 A. 14 403.8(f)(1)(iii)(B) (3) 403.8(f)(1)(iii)(B) (3) 403.8(f)(1)(iii)(B) (4) 403.8(f)(1)(iii)(B) (4) 403.8(f)(1)(iii)(B) (4) 403.8(f)(1)(iii)(B) (4) 403.8(f)(1)(iii)(B) (4) and 403.12(p) 40 C.F.R. 403.8(f)(2)(iii) 40 C.F.R. 403.8(f)(2)(iii) 40 C.F.R. 403.6(c)(5)(iii) Ecobat Resources Indiana, LLC - The permit does not include limits for: beryllium, chromium, hexavalent chromium, amenable cyanide, mercury, nickel, total phenols, pentachlorophenol, or selenium. Nelson Global Products - The IU permit states that the IU may submit a certification statement and a TOMP. The IU has a TOMP; the IU permit, however, does not indicate whether the IU has submitted a specific TOMP that satisfies CWA Authority. A TOMP must include best management practices (including the method of disposal used instead of dumping and procedures for ensuring that toxic organics do not routinely spill or leak into the wastewater). The IU permit, however, does not incorporate the TOMP's requirements. Nelson Global Products Inc - The IU permit has time proportional sampling requirements. However, the IU's daily flow varied more than 20 % of the average flow. Out of 36 months for flow rate data, 19 months had flow rates that were more than 20% different from the average flow (9 rates below average and 10 rates above average). Each IU permit does not require the IU to make records available for inspection and copying by the EPA, nor does it extend the record retention period during the course of any unresolved litigation regarding the Industrial User or POTW or when requested by EPA. SVC Manufacturing and Micronutrients: Each IU permit requires the IU to notify the POTW about a slug within one hour of discovery of the slug, as opposed to requiring immediate notification. IU permits reference SUO for requirements to establish the affirmative defense of an upset. The IU, however, does not list the associated upset notification requirements under 40 C.F.R. 403.16(c)(3). Each SIU permit includes a hazardous waste discharge notification requirement. The notification requirement, however, does not incorporate all of the notification requirements under 40 C.F.R. 403.12(p). Micronutrients - According to the IU permit, the IU is subject to pretreatment standards for new sources (PSNS). However, the IU permit file does not include the date when the facility was constructed. CWA Authority obtained information online indicating that construction commenced on 11/8/94. Ecobat Resources Indiana, LLC - The IU permit application does not include the date the IU's operations began. During the inspection, the POTW used IDEM files to determine when the IU's operations and to verify the classification as an existing source. Ecobat Resources Indiana, LLC - Monthly lead production rates show a decline over the last 3 years. The production-based standards in the IU 4.3 A. 4.3 A. 4.3 A. 4.3 A. 4.3 A. 4.3 A. 4.3 A. 4.3 B. 4.3 B. 4.3 B. 15 and 403.8(f)(1)(iii)(B) (3) 403.8(f)(1)(iii)(B) (3) 403.8(f)(2)(v) 403.8(f)(2)(v) 403.8(f)(2)(v) 403.8(f)(2)(v) 403.8(f)(2)(v) 403.8(f)(2)(v) 403.8(f)(2)(v) 403.8(f)(5) 403.8(f)(2)(iv) and 403.12(g)(6) permit, however, are based upon the original production rates written in the permit application. Micronutrients: The IU permit includes a zinc local limit at the "end of process," instead of the "end of pipe." Local limits are applied at the "end of pipe," (the point of connection to the CWA collection system). Arcwood Environmental, LLC - The POTW did not sample the IU for selenium. The POTW only sampled a subset of local limit pollutants that are listed in the IU permit. Vesta Pharmaceuticals, Incorporated - CWA Authority did not sample the IU for local limit parameters. Crossroads Farms Dairy - CWA Authority did not sample the IU for arsenic, beryllium, cadmium, chromium (T), chromium (hex), copper, cyanide (amenable), lead, mercury, nickel, total phenols, pentachlorophenol, and silver. Ecobat Resources Indiana, LLC - CWA Authority did not collect samples for beryllium, chromium, amenable cyanide, mercury, nickel, total phenols, and pentachlorophenol. Nelson Global Products Inc - CWA Authority did not collect samples for arsenic, beryllium, hexavalent chromium, amenable cyanide, mercury, total phenols, pentachlorophenol and TTO. SVC Manufacturing, Inc.: The POTW does not collect samples for arsenic, beryllium, cadmium, chromium (T), chromium (hex), copper, cyanide (amenable), lead, mercury, nickel, total phenols, pentachlorophenol, selenium, silver, zinc, and total petroleum hydrocarbons. Micronutrients USA, LLC: The POTW sample analytical reports do not include results for the following local limit pollutants: arsenic, beryllium, cadmium, chromium, hexavalent chromium, amenable cyanide, lead, mercury, total phenols, pentachlorophenol, silver, and total petroleum hydrocarbons. Micronutrients USA, LLC: Sample analytical results (for a sample collected at Building 400 by the POTW on 9/28/23) shows a result of 1.28 mg/L of copper. This exceeds the categorical monthly average limit for copper (1.1 mg/L). According to the files, the POTW did not collect any additional copper samples at Building 400 in September 2023. POTW staff stated that the last enforcement action taken against Micronutrients was in 2020. Crossroads Farms Dairy - There are sample analysis results that the facility collects that are not included on the facility's self-monitoring reports. 4.3 B. 4.3 C. 4.3 C. 4.3 C. 4.3 C. 4.3 C. 4.3 C. 4.3 C. 4.3 D. 4.3 D. 16 403.12(g)(5) and 136.1 (c) 403.12(g)(5) and 136.3, Table IB 403.8(f)(2)(iv) and 403.12(g)(1) 403.8(f)(2)(vi) 403.8(f)(2) and 403.6(c)(9) 403.8(f)(2)(iv) and 403 12(e)(4) Nelson Global Products Inc - Detection limits for TTO sampled on May 26, 2022, were too high to determine compliance. Detection limits ranged from 20 ug/L to 500 mg/L. The majority of detection limits were 100 ug/L. Micronutrients USA, LLC - Sample analysis reports do not indicate the analytical method used for pH monitoring. Micronutrients USA, LLC - self-monitoring reports do not include results for nickel, selenium, and zinc. The IU permit includes monitoring requirements for these pollutants. SVC Manufacturing: The IU does have a slug control plan, dated October 8, 2021. The plan requires the IU to notify the POTW about accidental discharges to the sewer within one hour of knowing about the incident, as opposed to requiring immediate notification. Ecobat Resources Indiana, LLC - The IU has production-based limits. According to the IU's self-monitoring reports, The IU's pounds of lead scrap production appear to vary significantly. Despite the significant production changes, the IU file did not include IU notifications of significant production changes. Ecobat Resources Indiana, LLC - The IU's self-monitoring reports do not include a reasonable measure of the IU's actual long-term daily production rate. 4.3 D. 4.3 D. 4.3 D. 4.3 D. 4.3 D. 4.3 D. 17