Document RgvG2w4p4BRz4JY2Ygy5xmM7

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 Laboratory Services & Applied Science Division Water Quality Section 980 College Station Road Athens, Georgia 30605-2720 October 27, 2021 MEMORANDUM SUBJECT: Akebono Brake Corporation Final Report Elizabethtown, KY LSASD Project ID: 21-0330 FROM: THRU: Chris McHugh, Environmental Engineer Water Quality Section Greg White, Chief Water Quality Section GREGORY WHITE Digitally signed by GREGORY WHITE Date: 2021.10.27 14:43:32 -04'00' TO: Jairo Castillo-Valenzuela, P.E., Chief Wastewater Enforcement Section Enforcement & Compliance Assistance Division Attached is the Final Report for the Akebono Brake Corporation NPDES Reconnaissance Sampling Inspection. If you have any questions concerning the sampling event, please call me at (706) 410-4082 or email me at mchugh.christopher@epa.gov. Attachments: cc (via email) : Dennis Sayre, ECAD : Sandra Aker, LSASD Mission: To provide sound Science to our customers through superior environmental evaluation Vision: To be a solutions-oriented organization, and seen as a leader in sound science through innovation, responsive customer service, and cutting-edge expertise Project ID: 21-0330 NPDES Sampling Evaluation Report Akebono Brake Corporation 300 Ring Road Elizabethtown, Kentucky Project Date: August 31, 2021 Report Date: October 27, 2021 LSASDFORM-066-R1 081821 Project Leader: Chris McHugh Water Quality Section Field Services Branch Laboratory Services & Applied Science Division USEPA - Region 4 980 College Station Road Athens, Georgia 30605-2720 The ANSI National Accreditation Board attests that U.S. EPA Region 4 Laboratory Services and Applied Science Division fulfills the requirements of ISO/IEC 17025:2017 ANAB Forensic Testing & Calibration AR 3125:2019 in the field of Forensic Testing. The activities contained in this report fall within the scope of accreditation, Certificate Number: FT-0330. Expires 31 July 2022. LSASD ID: 21-0330 Final Report Page 1 of 2 Requestor: Jairo Castillo Chief Water Enforcement Branch Enforcement and Compliance Assurance Division USEPA - Region 4 61 Forsyth Street SW Atlanta, GA, 30303-8960 LSASDFORM-066-R1 081821 Analytical Support: Inorganic Chemistry Section Laboratory Services and Applied Science Division 980 College Station Rd Athens, GA 30605 Approvals: LSASD Project Leader: CHRISTOPH CHRISTOPHER MCHUGH Digitally signed by ER MCHUGH -04'00' Date: 2021.10.27 14:26:09 Chris McHugh Water Quality Section Field Services Branch Approving Official: GREGORY WHITE Digitally signed by GREGORY WHITE Date: 2021.10.27 14:45:16 -04'00' Greg White, Chief Water Quality Section Field Services Branch LSASD ID: 21-0330 Final Report Page 2 of 2 Table of Contents 1. INTRODUCTION................................................................................................................. 4 2. SUMMARY ........................................................................................................................... 4 3. SAMPLE ANALYSIS RESULTS ....................................................................................... 5 List of Tables and Figures TABLE 1 - INSPECTION PERSONNEL ..................................................................................... 4 TABLE 2 - EPA SAMPLE RESULTS VS. PERMITTED LIMITS ............................................. 5 FIGURE 1 - SAMPLE COLLECTION POINTS .......................................................................... 5 LSASD ID: 21-0330 Final Report Page 1 of 5 NPDES Sampling Evaluation Akebono (Permit No. KY0089672) 1. Introduction On August 31, 2021, a representative of the U.S. Environmental Protection Agency (USEPA) Region 4 Laboratory Services and Applied Science Division (LSASD) conducted a National Pollutant Discharge Elimination System (NPDES) Reconnaissance Sampling Evaluation at Akebono in Elizabethtown, Kentucky. The evaluation was requested by the ECAD Water Enforcement Branch as part of the agency's goal to address significant non-compliance (SNC) facilities. Grab samples were collected at the effluent discharge location consistent with the facility's NPDES permit and at the North property line where adjacent property stormwater runoff enters onto Akebono's property. Samples were analyzed for total suspended solids (TSS) listed on the issued NPDES Permit KY0089672. The inspection followed the procedures listed in the LSASD Project No. 21-0330 Sample and Analysis Plan (SAP). Table 1 lists the sampling participants. Inspector Chris McHugh Table 1 - Inspection Personnel Organization USEPA Region 4 LSASD Date(s) on site 8/31/21 Dave Pedigo Akebono Environmental Engineer/ Facility Manager 8/31/21 2. Summary The analytical results from the effluent discharge (EFF001) were within the NPDES permitted limits for TSS. During the inspection, the alleged cause (heavy rain) for the persistent TSS violations was observed (remnants of Hurricane Ida) and can be seen in the pictures below. During heavy rain events, a rock-lined channel coming from the northside adjacent property discharges cloudy stormwater runoff. The runoff enters the Akebono collection system before discharging at EFF001. Based on the inspection interview with Dave Pedigo, the facility has been in contact with the Kentucky Department of Environmental Protection (KDEP), and there is ongoing discussion about the issue regarding periodic TSS exceedance levels. Akebono claims that the incoming stormwater runoff is the cause for its inability to meet the required NPDES permit limit for TSS. Samples were collected at the incoming stormwater discharge channel and had higher levels of TSS (7.9 mg/L) than from the discharge at EFF001 (5.0 mg/L). Note, the incoming stormwater runoff isn't a substantial order of magnitude higher than the discharge at LSASD ID: 21-0330 Final Report Page 2 of 5 EFF001. It is recommended that ECAD follow-up with the KDEP to gather more information on potential actions to assist Akebono with regaining compliance or potential enforcement actions. 3. Sample Analysis Results The grab samples were analyzed for the parameters listed below. The sample at EFF001 for TSS (5.0 mg/L) was within the permitted limit. Additionally, the sample collected at the North rocklined channel from the adjacent property stormwater runoff was 7.9 mg/L for TSS. Table 2 - EPA Sample Results vs. Permitted Limits Analyte TSS TSS EPA Analytical Results 5.0 mg/L *U 7.9 mg/L Permitted Limit 60 mg/L daily maximum N/A Sample Location Effluent (EFF001) North property line rock-lined channel DATA QUALIFIER DEFINITIONS - U The analyte was not detected at or above the reporting limit. Figure 1 - Sample Collection Points LSASD ID: 21-0330 Final Report Page 3 of 5 Photo Log Taken facing the adjacent property line during the inspection 8/31/21. Cloudy white stormwater runoff enters the Akebono collection system via this rock-lined channel. Facing the Akebono facility, with back to adjacent property. The cloudy stormwater enters into the Akebono collection system. Taken on 8/31/21. LSASD ID: 21-0330 Final Report Page 4 of 5 Appendix A The following table lists the total number of pages for each of the Analytical Datasheets for this report. Each document is contained in the PDF portfolio. R4LIMS ID 21-0330 Lab ID E213609 Analysis TSS Total Pages 8 LSASD ID: 21-0330 End of Report Final Report Page 5 of 5 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Laboratory Services and Applied Science Division 980 College Station Road, Athens, Georgia 30605-2700 D.A.R.T. Id: 21-0330 Project: 21-0330, Akebono - Reported by Laura Ackerman September 15, 2021 MEMORANDUM SUBJECT: FROM: THRU: TO: FINAL Analytical Report Project: 21-0330, Akebono Laura Ackerman LSB Inorganic Chemistry Section Chief John Deatrick, Chief Laboratory Services Branch Christopher McHugh Attached are the final results for the analytical groups listed below. This report shall not be reproduced except in full without approval of the Region 4 laboratory. These analyses were performed in accordance with the Laboratory Services Branch's Laboratory Operations and Quality Assurance Manual (LSB LOQAM) found at www.epa.gov/region4/sesd/asbsop. Any unique project data quality objectives specified in writing by the data requestor have also been incorporated into the data unless otherwise noted in the Report Narrative. Chemistry data have been verified based on the LSB LOQAM specifications and have been qualified by this laboratory if the applicable quality control criteria were not met. Verification is defined in Chapter 5 of the LSB LOQAM. For a listing of specific data qualifiers and explanations, please refer to the Data Qualifier Definitions included in this report. The reported results are accurate within the limits of the method(s) and are representative only of the samples as received by the laboratory. Analyses Included in this report: Method Used: Accreditations: Classical/Nutrient Analyses (CNA) Solids USGS I-3765-85 (Water) ISO Page 1 of 8 E213609 CNA FINAL 09 15 21 0827 9/15/21 8:27 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Laboratory Services and Applied Science Division 980 College Station Road, Athens, Georgia 30605-2700 D.A.R.T. Id: 21-0330 Project: 21-0330, Akebono - Reported by Laura Ackerman Sample Disposal Policy Due to limited space for long term sample storage, LSB's policy is to dispose of samples on a periodic schedule. Air samples collected in summa canisters will be disposed of 30 days following the issuance of this report. All other sample media including original samples, sample extracts and or digestates will be disposed of, in accordance with applicable regulations, 60 days from the date of this report. This sample disposal policy does not apply to criminal samples which are held until the laboratory is notified by the criminal investigators that case development and litigation are complete. These samples may be held in the laboratory's custody for a longer period of time. If samples require storage beyond the 60-day period, please contact the Sample Control Coordinator by e-mail at R4SampleCustody@epa.gov. Page 2 of 8 E213609 CNA FINAL 09 15 21 0827 9/15/21 8:27 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Laboratory Services and Applied Science Division 980 College Station Road, Athens, Georgia 30605-2700 D.A.R.T. Id: 21-0330 Project: 21-0330, Akebono - Reported by Laura Ackerman SAMPLES INCLUDED IN THIS REPORT Project: 21-0330, Akebono Sample ID 21--0330-0001 21-0330-0002 Laboratory ID E213609-01 E213609-02 Matrix Wastewater Wastewater Date Collected 8/31/21 09:20 8/31/21 10:15 Date Received 9/3/21 8:00 9/3/21 8:00 Page 3 of 8 E213609 CNA FINAL 09 15 21 0827 9/15/21 8:27 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Laboratory Services and Applied Science Division 980 College Station Road, Athens, Georgia 30605-2700 D.A.R.T. Id: 21-0330 Project: 21-0330, Akebono - Reported by Laura Ackerman DATA QUALIFIER DEFINITIONS U The analyte was not detected at or above the reporting limit. ACRONYMS AND ABBREVIATIONS CAS Chemical Abstracts Service Note: Analytes with no known CAS identifiers have been assigned codes beginning with "E", the EPA ID as assigned by the EPA Substance Registry System (www.epa.gov/srs), or beginning with "R4-", a unique identifier assigned by the EPA Region 4 laboratory. MDL Method Detection Limit - The minimum concentration of a substance (an analyte) that can be measured and reported with a 99% confidence that the analyte concentration is greater than zero. MRL Minimum Reporting Limit - Analyte concentration that corresponds to the lowest demonstrated level of acceptable quantitation. The MRL is sample-specific and accounts for preparation weights and volumes, dilutions, and moisture content of soil/sediments. TIC Tentatively Identified Compound - An analyte identified based on a match with the instrument software's mass spectral library. A calibration standard has not been analyzed to confirm the compound's identification or the estimated concentration reported. ACCREDITATIONS: ISO Accredited to ISO/IEC 17025:2017 and accreditation requirements for Forensic Science Testing Laboratories. Refer to the certificate and scope of accreditation FT-0330 at: http://www.epa.gov/aboutepa/about-region-4s-science-and-ecosystem-support-division-sesd NR Not accredited for this test. DW Accredited for conformance with ISO/IEC 17025:2017 and testing elements in the Fifth Edition of the Manual for the Certification of Laboratories Analyzing Drinking Water, EPA 815-R-05-004, 2005. Refer to the certificate and scope of accreditation AT-2628 at: http://www.epa.gov/aboutepa/about-region-4s-science-and-ecosystem-support-division-sesd ISO/DW Accredited to ISO/IEC 17025:2017 and accreditation requirements for Forensic Science Testing Labs, and conformance with ISO/IEC 17025:2017 and testing elements in the Manual for the Certification of Laboratories Analyzing Drinking Water. Page 4 of 8 E213609 CNA FINAL 09 15 21 0827 9/15/21 8:27 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Laboratory Services and Applied Science Division 980 College Station Road, Athens, Georgia 30605-2700 D.A.R.T. Id: 21-0330 Project: 21-0330, Akebono - Reported by Laura Ackerman Project: 21-0330, Akebono Classical/Nutrient Analyses Sample ID: 21--0330-0001 Station ID: EFF001 Date Collected: 8/31/21 9:20 CAS Number Analyte Lab ID: E213609-01 Matrix: Wastewater Results Qualifiers Units MRL Prepared Analyzed Method E1642818 Total Suspended Solids 5.0 U mg/L 9/03/21 5.0 9:32 9/07/21 USGS I-3765-85 10:40 Page 5 of 8 E213609 CNA FINAL 09 15 21 0827 9/15/21 8:27 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Laboratory Services and Applied Science Division 980 College Station Road, Athens, Georgia 30605-2700 D.A.R.T. Id: 21-0330 Project: 21-0330, Akebono - Reported by Laura Ackerman Project: 21-0330, Akebono Classical/Nutrient Analyses Sample ID: 21-0330-0002 Station ID: INF001 Date Collected: 8/31/21 10:15 CAS Number Analyte Lab ID: E213609-02 Matrix: Wastewater Results Qualifiers Units MRL Prepared Analyzed Method E1642818 Total Suspended Solids 7.9 mg/L 9/03/21 5.0 9:32 9/07/21 USGS I-3765-85 10:40 Page 6 of 8 E213609 CNA FINAL 09 15 21 0827 9/15/21 8:27 Analyte Batch 2109016 - C 2540 Solids Blank (2109016-BLK1) USGS I-3765-85 Total Suspended Solids LCS (2109016-BS1) USGS I-3765-85 Total Suspended Solids LCS (2109016-BS2) USGS I-3765-85 Total Suspended Solids LCS (2109016-BS3) USGS I-3765-85 Total Suspended Solids LCS (2109016-BS4) USGS I-3765-85 Total Suspended Solids LCS Dup (2109016-BSD1) USGS I-3765-85 Total Suspended Solids Duplicate (2109016-DUP1) USGS I-3765-85 Total Suspended Solids MRL Verification (2109016-PS1) USGS I-3765-85 Total Suspended Solids UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Laboratory Services and Applied Science Division 980 College Station Road, Athens, Georgia 30605-2700 D.A.R.T. Id: 21-0330 Project: 21-0330, Akebono - Reported by Laura Ackerman Classical/Nutrient Analyses (CNA) - Quality Control US-EPA, Region 4, LSASD Result Reporting Limit Units Spike Source %REC Level Result %REC Limits RPD Prepared: 09/03/21 Analyzed: 09/07/21 U 5.0 mg/L 93.800 Prepared: 09/03/21 Analyzed: 09/07/21 5.0 mg/L 100.00 93.8 77.1-110 92.500 Prepared: 09/03/21 Analyzed: 09/07/21 5.0 mg/L 100.00 92.5 77.1-110 90.200 Prepared: 09/03/21 Analyzed: 09/07/21 5.0 mg/L 100.00 90.2 77.1-110 103.90 Prepared: 09/03/21 Analyzed: 09/07/21 5.0 mg/L 100.00 104 77.1-110 95.300 Prepared: 09/03/21 Analyzed: 09/07/21 5.0 mg/L 100.00 95.3 77.1-110 1.59 Source: E213608-01 Prepared: 09/03/21 Analyzed: 09/07/21 8.7000 5.0 mg/L 8.5000 2.33 3.0000 Prepared: 09/03/21 Analyzed: 09/07/21 5.0 mg/L 5.0000 60.0 57.1-130 RPD Limit Notes U 10 10 MRL-2, U Page 7 of 8 E213609 CNA FINAL 09 15 21 0827 9/15/21 8:27 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Laboratory Services and Applied Science Division 980 College Station Road, Athens, Georgia 30605-2700 D.A.R.T. Id: 21-0330 Project: 21-0330, Akebono - Reported by Laura Ackerman U MRL-2 Notes and Definitions for QC Samples The analyte was not detected at or above the reporting limit. MRL verification for Non-Potable Water matrix Page 8 of 8 E213609 CNA FINAL 09 15 21 0827 9/15/21 8:27