Document X7kv1OrVGwk0RnDX1396G4GVJ

EPA Region 10 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 11/15/2022 09:30 AM (PT) Announced: No 11/15/2022 02:45 PM (PT) Access: Granted Sunny, 50F Water Clean Water Act, NPDES, Stormwater - Industrial ISI - Industrial Stormwater Inspection Permittee Name Facility or Site Name Facility Address City, State, Zip Code Count Facility GPS Coordinates WestRock CP LLC WestRock 9930 N Burgard Way Portland, OR 97203 Multnomah County 45.61298, -122.77831 FRS ID Permit Number SIC 110069567846 ORR242301 2653 (Corrugated & Solid Fiber Box mfg) Regulatory Representatives Participating in Inspection: Title Name Environmental Manager Stacy Hibbard Organization City of Portland Lead Inspector: RAYMOND ANDREWS Raymond Andrews EPA Region 10 Digitally signed by RAYMOND ANDREWS Date: 2023.01.23 13:22:05 -08'00' andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Peter Contreras EPA Region 10 Digitally signed by PETER CONTRERAS Date: 2023.01.23 13:51:31 -08'00' contreras.peter@epa.gov (206) 553-6708 SECTION I - INTRODUCTION Site Entry and Inspection Objectives I arrived at WestRock ("Site" or "Facility"), located at 9930 N Burgard Way, Portland, OR 97203, at 9:30 AM (PT) on 11/15/2022 for an unannounced inspection. I presented my credentials to Tom Maas, Production Manager, and Cameron Manning, EHS Manager. I informed them I was there to conduct an inspection to determine compliance with the Clean Water Act (CWA), and the facility's Oregon 1200-Z Industrial Stormwater Discharge permit. I was accompanied on the inspection by Stacy Hibbard, City of Portland Environmental Manager, as an observer. This report is based on information supplied by Mr. Maas, Mr. Manning, and Mr. Karl Schumacher, Senior Environmental Services Manager, direct observations made at the time of the inspection; and a review of records and reports maintained by the facility. In addition, information gathered from a review of EPA, State, and/or public records may be included in this report. Attendees Organization Attendee Name Title EPA Region 10 Raymond Andrews City of Portland Stacy Hibbard WestRock Cameron Manning WestRock Tom Maas WestRock Karl Schumacher Lead Inspector Environmental Manager EHS Manager Production Manager Sr. Environmental Services Manager Present in Present in Opening Conf. Closing Conf. Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Facility/Site Information Responsible Official? Name of Primary Person Engaging with the Inspector? Is SWPCP Team Present? Size of Facility? Hours/Days of Operations? Is Property Owned? Type of Operation? Industrial Activities Exposed to Stormwater? BMPs/Stormwater Treatment? Tom Maas, Production Manager Cameron Manning, EHS Manager Part of SWPCP team was Present; Tom Mass & Cameron Manning are present; however the Maintenance Manager, Justin Hoyt, was not present. The site covers approximately 10 acres. Five acres are covered by buildings, three acres are covered by asphalt/pavement, and two acres are covered in a combination of gravel and vegetation. Most of north side is unpaved. The facility operates 24 hours a day, Monday - Friday with 3 shifts. The Property is mostly owned by WestRock CP LLC. Approximately 2.5 acres of the property site is leased from Schnitzer Investment Corp. The facility makes corrugated boards and boxes. The facility stores wood pallets and triple-rinsed 250-gallon chemical storage totes outside. Stormwater is collected in catch basins. Once in the catch basins the water gravity flows to an infiltration Planter. Number/Location of Stormwater Inlets/ Outfalls/Drains? The facility has a total of seven monitored catch basins, an infiltration basin, and an infiltration planter. Two of the catch basins are in the parking lot. Receiving Water The receiving water is a slip of the Willamette River. Does the facility have any waivers for sampling? The facility does not have any current monitoring waivers. When was the facility's last inspection? The facility was last inspected in March 2022 by the City of Portland. The state has delegated the City of Portland the authority to monitor compliance with all permitted facilities within the City footprint. The City inspects every permitted facility annually. Has the facility ever had an enforcement action The Oregon Department of Environmental Quality (ODEQ) taken against it? took an enforcement action against the facility in May 2020. Additional Information: ODEQ issued a civil penalty of $11,478 to the facility for failure to monitor for benchmark and impairment pollutants from February 26, 2019, through June 30, 2019. The site is graded so stormwater sheet flows to one of the catch basins. The catch basins have filter inserts and are encircled by absorbent socks. The purpose of the filters and socks were used to reduce the quantity of particulate matter entering the catch basins. While not listed as an area of concern, it appears that several of the socks needed maintenance. All catch basins are sampled individually through grab sampling. The infiltration basin receives and treats runoff from the eastern part of the building roofs and the paved areas northeast and east of the building. Roof drains from the eastern part of the building are piped to the infiltration basin. The infiltration planter receives runoff from the southern paved area. Runoff from the northern area sheet flows to the infiltration planter via wall notches that allow runoff to directly flow into the infiltration planter. Catch Basin 1 receives runoff from the paved area southeast of the building. Catch Basin 2 receives sheet flow from the north. Catch Basin 3 receives sheet flow from a portion of the paved area south of the building. Catch Basin 4 sheet flow primarily from East and West in parking area/drive through. Catch basin 5 receives sheet flow primarily from the north and a little from the west. The facility has three outfalls. The outfalls were inaccessible at the time of the inspection so were not observed. SECTION II - OBSERVATIONS Photo 1/P1010537 - Catch Basin 1 Photo 2/P1010532 - Catch Basin 2 Photo 3/P1010530 - Catch Basin 4 Photo 4/P1010531 - Catch Basin 5 Photo 5/P1010536 - Infiltration Planter Record: Other - Stormwater Pollution Control Plan (SWPCP) Ref #: RA1-RR-009 Reviewed By: Raymond Andrews AOC: No Reviewed Date: 11/15/2022 Record: Other - 3rd Party Consent Decree with Northwest Environmental Defense Center (NEDC) AOC: No Ref #: RA1-RR-008 Reviewed By: Raymond Andrews Reviewed Date: 11/15/2022 Record: Personnel Training Ref #: RA1-RR-007 Reviewed By: Raymond Andrews No annual training conducted in 2021. Record: Other - Monthly Site Inspection Logs Ref #: RA1-RR-006 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 11/15/2022 AOC: No Reviewed Date: 11/15/2022 Record: Other - Weekly Catch Basin Inspection Logs Ref #: RA1-RR-005 Reviewed By: Raymond Andrews AOC: No Reviewed Date: 11/15/2022 Record: Other - Monthly Infiltration Basin Inspection Logs AOC: No Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Record: DMR Reports Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Record: Laboratory Analysis Reports Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Record: Other - Stormwater Corrective Action Tier I Report Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 11/15/2022 AOC: No Reviewed Date: 11/15/2022 AOC: No Reviewed Date: 11/15/2022 AOC: No Reviewed Date: 11/15/2022 SECTION III - AREAS OF CONCERN Areas of Concern may not be in sequential order. The presentation of areas of concern does not constitute a formal compliance determination or violation. AOC Reference #: RA1-RR-007 Records Review: Personnel Training Regulation and/or Permit Requirement Schedule A.1.j.iii Education and training must be documented and must occur: (1) No later than 30 calendar days after hiring an employee who works in areas where stormwater is exposed to industrial activities or conducts duties related to the implementation of the SWPCP; (2) No later than 30 calendar days after change in duties for key personnel in Schedule A.1.j.ii; and, (3) Annually thereafter AOC: No annual training conducted in 2021. SECTION IV - CLOSING CONFERENCE I held a closing conference with Stacy Hibbard and facility personnel at 02:45 PM (PT) on 11/15/2022. During the closing conference, I discussed my observations and the Area of Concern identified during the inspection. SECTION V - LIST OF APPENDICES 1. Photo Log APPENDIX 1: PHOTO LOG P1010529 - Catch Basin 4, photo 1 (Not used in Report) P1010530 - Catch Basin 4, photo 2 P1010531 - Catch Basin 5 P1010532 - Catch Basin 2 P1010533 - Catch Basin 6, photo 1 (Not used in Report) P1010534 - Catch Basin 6, photo 2 (Not used in Report) P1010535 - Infiltration Planter, photo 1 P1010536 - Infiltration Planter, photo 2 (Not use in Report) P1010537 - Catch Basin 1 P1010538 - Catch Basin 1 Monitoring Location (Not used in Report)