Document RJ6V5DjY58eLq6eeno4zEdMB7

EPA REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 04/24/2025 08:55 AM (ET) 04/24/2025 11:28 AM (ET) Announced: No Access: Granted Water Clean Water Act, NPDES, Industrial Compliance Evaluation Inspection (CEI) Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Mailing Address (If different) City, State, Zip Code Hirzel Canning Co (0387000242) Hirzel Canning Co (0387000242) 411 Lemoyne Rd Northwood, OH 43619 41.60965, -83.47401 FRS ID 110008595760 Permit Number(s) (If Applicable) OH0135666 SIC and/or NAICS 2033 Lead Inspector: Joseph Forth JOSEPH FORTH EPA REGION 5 Digitally signed by JOSEPH FORTH Date: 2025.06.13 10:25:52 -05'00' Forth.Joseph@epa.gov (312) 886-7275 Supervisor Review: Molly Smith MOLLY SMITH EPA REGION 5 Digitally signed by MOLLY SMITH Date: 2025.06.13 11:17:38 -05'00' Smith.Molly@epa.gov 1 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 SECTION I - INTRODUCTION Site Entry and Inspection Objectives EPA REGION 5 Lead Inspector, Joseph Forth, arrived at the Hirzel Canning Company (0387000242) (the "Site" or "Facility"), located at 411 Lemoyne Rd, Northwood, OH 43619, at 08:55 AM (ET) on 04/24/2025 for an unannounced inspection. EPA REGION 5 Lead Inspector presented credentials to Jessica Hirzel and informed the Facility that this was an EPA REGION 5 inspection to investigate as authorized by Clean Water Act (CWA) Section 308. This report is based on information supplied by Hirzel Canning Company (0387000242) representatives, direct observations made by the EPA REGION 5 inspector, records and reports maintained by the permittee and other information including: photographs taken by EPA REGION 5 inspector(s), physical evidence collected by the EPA REGION 5 inspector(s), measurements taken by EPA REGION 5 inspector(s), verbal or written statements made by information supplied by Hirzel Canning Company (0387000242) representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA REGION 5 inspector(s) by Hirzel Canning Company (0387000242) representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization EPA REGION 5 EPA REGION 5 EPA REGION 5 Hirzel Hirzel Attendee Name Joseph Forth Megan Bobb Tatiana Frontera Jessica Hirzel Dan Jackson Facility/Site Description Title Lead Inspector Inspector Inspector Plant Manager Wastewater Superintendent Present in Opening Conf. Yes Yes Yes Yes Yes Present in Closing Conf. Yes Yes Yes Yes No EPA REGION 5 lead inspector confirmed the following facility information: Hirzel Canning Company is a facility that processes and packages (cans) tomatoes and cabbage. During fresh produce season, the facility employs 80 employees. The Facility is open Monday through Saturday. The Facility is split into two seasonal plants. The cabbage plant operates from 7:00 AM to 7:00 PM and the tomato plant operates from 6:00 AM to 9:00 PM. From August to mid-October, the Facility processes tomatoes. From July to late October or early November, the Facility processes cabbage. The process begins with receiving the produce from the farms, once received the produce is washed with water. Hirzel grows 5% of the tomatoes used in the process, the rest of the tomatoes and cabbages are from contract farmers. Plant receives 30 truck loads of tomatoes and 5-6 truckloads of cabbage per day during processing season. Cabbage is passed through a tumbler system and sprayed with water. Tomatoes washed in the transfer trucks, the water then helps convey the tomatoes, via floating, into the plant. Water is also utilized for heating/steam and for sanitation of equipment. Tomatoes are cooked in tanks and peeled. Minimal water is added to the product when canned, most liquid is derived from the produce. Off-season is when cabbage is canned and pasta sauce and other products are made. All wastewater has solids separated and is then applied to the grass fields behind the facility The spray field systems were brought online in Summer 2024. The fields have a capture system for the wastewater that then conveys the wastewater to the lagoon system. November through July is when the lagoon system is open and 2 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 actively discharging. The average flow when discharging is 0.15 million gallons per day (mgd). The 3 lagoons are connected in series. In Spring 2024, the barrier wall between ponds 2 and 3 was removed and the lagoons combined. Solid wastes are separated before reaching the lagoons and sent to a composting facility in Pemberville, OH. The Facility discharges via Outfall 001 to Wolf Creek. When the weather is below 32 degrees Fahrenheit, the Facility has the capability to discharge directly to the City of Oregon wastewater treatment plant (WWTP). This discharge is not identified in the Ohio EPA NPDES Permit #OH0135666. The Facility is only allowed to discharge from Outfall 001 during the day, while an operator is present. Dan Jackson, Facility staff, performs visual inspections of Outfall 002. The Facility installed a new stormwater separation system to prevent stormwater from entering the wastewater stream. The front half of the Facility has a retention pond for stormwater, the back half of the property is segregated and does not route to the retention pond. Additional stormwater capital projects are in the planning stage. At the time of the inspection, the Facility's new stormwater separation system was not included in the SWPP given to EPA inspectors for review. The Facility also shared with EPA, during the inspection, that it was investigating installing a dissolved air floatation system (DAF) for further wastewater treatment. The sampling point for Outfall 001 is located at the valve which controls discharge to Wolf Creek. According to the Facility, grab samples are collected by Dan Jackson. The Facility was not, as of the date of inspection, recording the time at which pH samples were being analyzed to document the samples are being analyzed within 15 minutes from the time of collection. The Facility uses Jones and Henry Laboratories to analyze samples. Jones and Henry provide sample containers pre-filled with preservatives, and Dan Jackson collects the samples and transports the samples to Jones and Henry. Facility/Site Information Location(s) Location/Area/Sub-area Application Fields, Treatment Lagoons, and Outfalls Tomato and Cabbage Plants Description The fields in which wastewater is applied, the lagoons in which land filtered wastewater receives further treatment, and Outfalls 001 and 002. All processes and equipment associated with the tomato processing plant. SECTION II - OBSERVATIONS Location: Tomato and Cabbage Plants Observation #: JF1-OB-001 Date: 04/24/2025 Facility utilizes a caustic bath to separate skins from the tomatoes. According to the Facility, all floor drains in the production area connect to the wastewater system. The can cooler system recycles water throughout the day, then purges to wastewater at the end of the day. Storm drains in the produce unloading area are connected to the wastewater system. 3 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 Photo(s) 1. IMG_0466.JPG 2. IMG_0465.JPG 3. IMG_0467.JPG 4. IMG_0468.JPG 5. IMG_0469.JPG 6. IMG_0481.JPG 7. IMG_0479.JPG 8. IMG_0480.JPG Location: Application Fields, Treatment Lagoons, and Outfalls Observation #: JF1-OB-002 Date: 04/24/2025 Screened wastewater is kept in aeration tanks until full, then discharges to be sprayed in the application fields. At the time of inspection, Outfall 001 was discharging. Dan Jackson stated that the valve which controls the discharge had begun malfunctioning in early April 2025, allowing some discharge to continuously exit the outfall. At the time of the inspection the outfall was discharging. On May 15, 2025, after the inspection, the Facility provided a photo of the newly installed valve. Photo(s) 1. IMG_0470.JPG 2. IMG_0478.JPG 3. IMG_0477.JPG 4. IMG_0473.JPG 5. IMG_0472.JPG 6. IMG_0476.JPG 7. IMG_0474.JPG 8. IMG_0475.JPG 9. IMG_0471.JPG SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: Other - Photo of Valve Replacement Ref #: JF1-RR-006 Reviewed By: Joseph Forth Facility provided a photo of the replaced valve for Outfall 001. Record: Other - Safety Data Sheet Ref #: JF1-RR-005 Reviewed By: Joseph Forth AOC: No Reviewed Date: 05/15/2025 AOC: No Reviewed Date: 05/15/2025 4 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 Facility provided the Safety Data Sheet for the caustic additive for the tomato process. Document(s) 1. CAUSTIC - SDS.pdf Record: Other - Lab Chain of Custody Form Ref #: JF1-RR-004 Reviewed By: Joseph Forth AOC: No Reviewed Date: 05/15/2025 Facility provided chain of custody record form. Document(s) 1. nw-lab_007735.pdf Record: Process Description/Flow Diagram Ref #: JF1-RR-003 Reviewed By: Joseph Forth AOC: No Reviewed Date: 05/15/2025 Facility provided product process flow and wastewater flow diagrams. Document(s) 1. NORTHWOOD Product Process Flow Diagram.pdf 2. NORTHWOOD Wastewater Flow Schematic.pdf Record: Other - SWPPP Ref #: JF1-RR-002 Reviewed By: Joseph Forth AOC: No Reviewed Date: 05/15/2025 Facility provided Stormwater Pollution Prevention Plan (SWPPP) from October 2023. Document(s) 1. SWPPP Northwood 10-12-2023.pdf Record: DMR Reports Ref #: JF1-RR-001 Reviewed By: Joseph Forth AOC: No Reviewed Date: 05/15/2025 Discharge Monitoring Reports (DMRs) for February, March and April 2025. Document(s) 1. report (1).pdf 2. report (2).pdf 3. report (3).pdf 4. report (4).pdf SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. 5 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 SECTION V - AREA(S) OF CONCERN Area(s) of Concern may not be in sequential order. The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. AOC Reference #: JF1-OC-FD AOC: Opening Conference The Facility was not, as of the date of inspection, recording the time at which pH samples were being analyzed to ensure the samples are being analyzed within 15 minutes. AOC Reference #: JF1-OC-FD AOC: Opening Conference When the weather is below 32 degrees Fahrenheit, the Facility has the capability to discharge directly to the City of Oregon WWTP. This discharge is not currently listed in the Ohio EPA NPDES Permit # OH0135666. AOC Reference #: JF1-OC-FD AOC: Opening Conference The Facility has not updated their SWPPP to include the new stormwater system mid-2024. AOC Reference #: JF1-OB-002 AOC: Location: Application Fields, Treatment Lagoons, and Outfalls At the time of inspection, Outfall 001 was discharging. Dan Jackson stated that the valve which controls the discharge had begun malfunctioning in early April 2025, allowing a portion of the discharge to continuously exit Outfall 001, including constantly during the inspection. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA REGION 5 Lead Inspector held a closing conference with Facility personnel at 11:28 AM (ET) on 04/24/2025 for the inspection. During the closing conference, EPA REGION 5 Lead Inspector discussed the observations and Area(s) of Concern identified during the inspection. Observations and Area(s) of Concern have not yet been evaluated for a formal compliance determination. Follow-Up 6 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 U.S. EPA staff requested documentation of the repair of the Outfall 001 valve on 5/30/2025. On 6/2/2025, U.S. EPA staff requested documentation of whether Hirzel has measured the receiving water flow volumetric rate or received approval from Ohio EPA to exceed a discharge rate of 90 gallons per minute, per cubic feet per second of the receiving stream. Communication Log U.S. EPA Staff received documents from Jessica Hirzel on 5/20/2025. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 7 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): APPENDIX 1: PHOTO LOG 04/24/2025 - 04/24/2025 Photo #1 04/24/2025 10:20 AM No CBI No PII Tomato and Cabbage Plants Photo of tomato washing area and peeler feed. IMG_0465.JPG Photographer: Joseph Forth East Photo 2 04/24/2025 10:21 AM No CBI Tomato and Cabbage Plants Photo of water spouts to fill tomato trucks No PII IMG_0466.JPG Photographer: Joseph Forth East 8 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 Photo 3 04/24/2025 10:28 AM No CBI Tomato and Cabbage Plants Photo of can cooling system. No PII IMG_0467.JPG Photographer: Joseph Forth East Photo 4 04/24/2025 10:31 AM No CBI Tomato and Cabbage Plants Photo of rotary screen. No PII IMG_0468.JPG Photographer: Joseph Forth East 9 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 Photo 5 04/24/2025 10:34 AM No CBI No PII Tomato and Cabbage Plants Photo of aeration tank and solids dumpster. IMG_0469.JPG Photographer: Joseph Forth West Photo 6 04/24/2025 10:36 AM No CBI No PII Application Fields, Treatment Lagoons, and Outfalls Photo of spraying field. IMG_0470.JPG Photographer: Joseph Forth North 10 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 Photo 7 IMG_0471.JPG 04/24/2025 10:38 AM No CBI No PII Photographer: Joseph Forth Application Fields, Treatment Lagoons, and Outfalls Downward Photo of wastewater collection pit from spraying field that will be pumped to the lagoons. Photo 8 04/24/2025 10:40 AM No CBI No PII Application Fields, Treatment Lagoons, and Outfalls Photo of pond 1 and inlet pipe. IMG_0472.JPG Photographer: Joseph Forth West 11 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 Photo 9 04/24/2025 10:41 AM No CBI No PII Application Fields, Treatment Lagoons, and Outfalls Photo of pond 2. IMG_0473.JPG Photographer: Joseph Forth East Photo 10 04/24/2025 10:43 AM No CBI No PII Application Fields, Treatment Lagoons, and Outfalls Photo of pond 4 and discharge valve. IMG_0474.JPG Photographer: Joseph Forth West 12 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 Photo 11 04/24/2025 10:46 AM No CBI No PII Application Fields, Treatment Lagoons, and Outfalls Photo of Outfall 001. IMG_0475.JPG Photographer: Joseph Forth Northeast Photo 12 04/24/2025 10:46 AM No CBI No PII Application Fields, Treatment Lagoons, and Outfalls Photo of Outfall 002. IMG_0476.JPG Photographer: Joseph Forth East 13 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 Photo 13 04/24/2025 10:47 AM No CBI No PII Application Fields, Treatment Lagoons, and Outfalls Photo of outfall signage for Outfalls 001 and 002. IMG_0477.JPG Photographer: Joseph Forth East Photo 14 04/24/2025 10:52 AM No CBI No PII Application Fields, Treatment Lagoons, and Outfalls Photo of stormwater outfall valve. IMG_0478.JPG Photographer: Joseph Forth Downward 14 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 Photo 15 04/24/2025 10:57 AM No CBI Tomato and Cabbage Plants Photo of cabbage tumbler. No PII IMG_0479.JPG Photographer: Joseph Forth Cabbage Plant Photo 16 04/24/2025 10:58 AM No CBI No PII Tomato and Cabbage Plants Photo of cabbage wastewater holding tank. IMG_0480.JPG Photographer: Joseph Forth Downward, Cabbage Plant 15 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 Photo 17 04/24/2025 11:01 AM No CBI Tomato and Cabbage Plants Photo of tomato pit waste water. No PII IMG_0481.JPG Photographer: Joseph Forth Downward, tomato plant 16 of 17 Hirzel Canning Co (0387000242) Inspection Date(s): 04/24/2025 - 04/24/2025 APPENDIX 2: DOCUMENT LOG Document Type DMR Reports DMR Reports DMR Reports DMR Reports Other - SWPPP Process Description/Flow Diagram Process Description/Flow Diagram Other - Lab Chain of Custody Form Other - Safety Data Sheet Document Name report (1).pdf report (2).pdf report (3).pdf report (4).pdf SWPPP Northwood 1012-2023.pdf NORTHWOOD Product Process Flow Diagram.pdf NORTHWOOD Wastewater Flow Schematic.pdf nw-lab_007735.pdf Contains CBI No No No No No No No No Contains PII No No No No No No No No Uploaded By Joseph Forth Joseph Forth Joseph Forth Joseph Forth Joseph Forth Joseph Forth Joseph Forth Joseph Forth CAUSTIC - SDS.pdf No No Joseph Forth Date Received 5/15/2025 5/15/2025 5/15/2025 5/15/2025 5/15/2025 5/15/2025 5/15/2025 5/15/2025 5/15/2025 17 of 17