Document XObzzegkVVemvQp191MkjyRdR
LSASD Project ID: 25-0065
Dlubak Glass Company
NPDES Compliance Evaluation Inspection
Location: 1050 Industry Rd., Lawrenceburg, KY 40342
Project Date(s): November 18th, 2024 Report Date: December 23rd, 2024
FSBFORM-1403-R0 073024
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
LSASD Project ID: 25-0065
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Project Requestor:
Jairo Castillo, P.E. Section Chief Wastewater Enforcement Section Enforcement and Compliance Assurance Division U.S. Environmental Protection Agency 61 Forsyth Street, SW Atlanta, GA 30303 404.562.9756 (office)
Analytical Support: None
Approvals: CHRISTOPHER MCHUGH
Chris McHugh, Inspector Water Quality Section Field Services Branch
Digitally signed by CHRISTOPHER MCHUGH Date: 2024.12.23 12:18:23 -05'00'
Date
Approving Officials:
SANDRA AKER
Sandra Aker for Joel Owen, Technical Reviewer Water Quality Section Field Services Branch
Digitally signed by SANDRA AKER Date: 2024.12.23 12:33:35 -05'00'
Date
SANDRA AKER
Sandra Aker for Greg White, Section Chief Water Quality Section Field Services Branch
Digitally signed by SANDRA AKER Date: 2024.12.23 12:34:03 -05'00'
Date
JOHN GOODWIN
Jairo Castillo, P.E., Supervisor Wastewater Enforcement Section Water Enforcement Branch
Digitally signed by JOHN GOODWIN Date: 2024.12.23 16:01:53 -05'00'
Date
LSASD Project ID: 25-0065
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FSBFORM-1403-R0 073024
1. Introduction
On November 18th, 2024, staff of the United States Environmental Protection Agency (EPA) Region 4, Laboratory Services and Applied Science Division (LSASD), conducted a National Pollutant Discharge Elimination System (NPDES) Compliance Evaluation Inspection (CEI) at Dlubak Glass Company in Lawrenceburg, Kentucky. The inspection was conducted under the authority of Section 308 of the Clean Water Act (CWA), as amended, and followed the procedures listed in the LSASD Project No. 25 - 0065 Sample and Analysis Plan (SAP). This report presents the results of the inspection. Table 1 lists the inspection participants and facility staff.
Name Chris McHugh Deborah Singleton Jarod Jones Robert Daniell
Table 1 - Inspection Personnel
Organization EPA Region 4 LSASD
Inspection KDEP Frankfort Regional Office KDEP Frankfort Regional Office KDEP Frankfort Regional Office
Date on Site 11/18/2024 11/18/2024 11/18/2024 11/18/2024
Contact Info Mchugh.christopher@epa.gov
Singleton.deborah@ky.gov Jones.Jarod@ky.gov Daniell.robert@ky.gov
There were no responsible officials available the day of the inspection to answer questions or provide documents. Facility access was granted by the front desk associate inside the main office.
2. Inspection Procedures
The objective of this inspection was to evaluate the condition of the facility's NPDES stormwater best management practices (BMP) and the permittee's self-monitoring program and offer compliance assistance as needed. Specific tasks included conducting an opening conference, interviewing facility staff, conducting a facility walkthrough, observing the receiving waters, and conducting a closing conference.
3. Facility Description
Dlubak Glass Company recycles glass brought onsite from automotive, cathode light tubes, lighting, plate, fiberglass, container, and specialty glass industries. It is permitted by KY0113433 and authorized to discharge to receiving waters: unnamed tributaries (UT) to Cedar Brook. The permit expires on December 31st, 2027.
LSASD Project ID: 25-0065
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Figure 1 - Facility Grounds from Main Office Parking Lot
The facility grounds are a mix of concrete impervious surface with gravel made from crushed glass pathway between different piles of glass and vinyl sheathing (Figure 1). There are two main crushing stations located in the center of Figure 2.
Outfall 002, 003, 004 are spaced alongside the northside of the property with a berm put in place to detain stormwater runoff before discharge (Figure 2 and Table 2 below). Outfall 001 is on the southside of the property. Near the main entrance is the vinyl sheathing pile that has previously burned (Figure 3). Figure 4 shows the condition of the vinyl sheathing pile that was not burned heading North. The berm in Figure 2 and pictured in Figure 5 extends down the property line around the crushed glass pile.
The concrete containment wall along the North and East sides of the property was buried and overtopped by glass products (Figure 6, 7, and 8).
Near the main pile of glass products awaiting to be crushed (Figure 9) is a large area that retains surface water (Figure 10).
LSASD Project ID: 25-0065
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FSBFORM-1403-R0 073024 Yellow Line: Stormwater Berm Blue line: Concrete Containment Structure
Figure 2 - Aerial View of Facility Grounds
Figure 3 - Vinyl Sheathing Pile Burned Section
LSASD Project ID: 25-0065
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Figure 4 - Vinyl sheathing pile and pathway to northside of property
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Figure 5 - Berm facing East down property line.
Figure 6 - East side of property, Crushed glass pile over top of concrete walls
LSASD Project ID: 25-0065
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FSBFORM-1403-R0 073024 Figure 7 - Glass overtop of concrete containment structure
LSASD Project ID: 25-0065
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Figure 8 - Glass product spilled outside of containment structure.
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Figure 9 - Main pile of glass products.
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Table 2 - Facility Stormwater Outfalls
Outfall No.
001
Type External
Latitude (N)
38.030683
Longitude (W)
-84.886849
Receiving Water UT to Cedar Brook
002 External 38.033250 -84.883889
UT to Cedar Brook
003 External 38.032778 -84.884444
UT to Cedar Brook
004 External 38.033056 -84.88500
UT to Cedar Brook
Description
Stormwater runoff from facility grounds
Stormwater runoff from facility grounds
Stormwater runoff from facility grounds
Stormwater runoff from facility grounds
For each outfall 001, 002, and 003, the facility is subject to the following permit effluent limitations and monitoring requirements show in Table 3. Outfall 004 is subject to the limitations in Table 4.
Table 3 - Effluent Limitations and Monitoring Requirements
Effluent Limitations
Monitoring Requirements
Loadings (lb/d)
Concentrations
Parameters Units Monthly
Avg.
Daily Max.
Min Monthly Avg.
Daily Max.
Max. Frequency
Sample Type
Flow
MGD Report Report N/A N/A
N/A N/A Monthly Instantaneous
pH
SU
N/A
N/A 6.0 N/A
N/A 9.0 Monthly
Grab
Total
Suspended mg/L N/A
N/A N/A 30
60
N/A Monthly
Grab
Solids
Oil and mg/L N/A N/A N/A 10 15 N/A Monthly Grab Grease
Hardness
(as mg/L mg/L N/A
N/A N/A Report Report N/A Monthly
Grab
CaCo3)
Biological
Oxygen mg/L N/A
N/A N/A Report Report N/A Monthly
Grab
Demand
Chemical
Oxygen mg/L N/A
N/A N/A Report Report N/A Monthly
Grab
Demand
Total
Recoverable mg/L N/A
N/A N/A Report Report N/A Monthly
Grab
Iron
Total
Recoverable mg/L N/A
N/A N/A Report Report N/A Monthly
Grab
Lead
LSASD Project ID: 25-0065
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Table 4 - Outfall 002 Effluent Limitations and Requirements
Parameters
Flow pH Total Suspended Solids Hardness (as mg/L CaCo3) Biological Oxygen Demand Chemical Oxygen Demand Total Recoverable Iron Total Recoverable Lead
Units MGD SU mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Effluent Limitations
Loadings (lb/d)
Monthly Daily Min.
Avg.
Max.
Report Report N/A
N/A
N/A 6.0
Concentrations
Monthly Avg.
Daily Max.
N/A
N/A
N/A
N/A
N/A
N/A N/A
30
60
N/A
N/A N/A Report Report
N/A
N/A N/A Report Report
N/A
N/A N/A Report Report
N/A
N/A N/A Report
4.0
N/A
N/A N/A Report Report
Monitoring Requirements
Max.
N/A 9.0
Frequency
Monthly Monthly
Sample Type
Instantaneous Grab
N/A Monthly
Grab
N/A Monthly
Grab
N/A Monthly
Grab
N/A Monthly
Grab
N/A Monthly
Grab
N/A Monthly
Grab
4. Records and Reports I. Discharge Monitoring Reports (DMR) Review
The facility has repeated permit effluent exceedances over the last 12 quarters for Total Suspended Solids and Oil & Grease violations via discharge from Outfall 001, 002, and 004 that has led to the facility being listed on the Significant/Category 1 Noncompliance (SNC) list. The KDEP Frankfort Regional Office is currently assessing these exceedances.
II. Records Review There were no representative officials present during the inspection to provide records.
III. Sampling Review There were no representative officials present during the inspection to provide sampling protocol information.
5. Effluent and Receiving Waters
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Outfalls 002, 003, and 004 were observed with discharge during the inspection. Outfall 001 was not accessible. The discharge from outfall 002 had an oily, iridescent sheen on the surface of the water.
Figure 10 - Outfall 002 sheen 6. State Enforcement and Sampling
The KDEP Frankfort Regional Office is currently working with Dlubak Glass Company to address the SNC status of the facility. State inspectors sampled each outfall as well as upstream and downstream of the facility. The results are attached to this report. Based on the upstream and downstream data for metals and total suspended solids along with the data from each outfall, Table 5 includes several notable metal concentrations and Table 6 includes one exceedance for total suspended solids.
Table 5 - State Sampling 11/07/24 Results Comparison.
Parameter
Aluminum Molybdenum Boron Lithium Sodium Chromium Copper Lead Vanadium Total Suspended Solids
Upstream concentration (g/L)
83.1 1.26 Not detected Not detected 15200 (15.2 mg/L) 0.775 3.00 0.51 Not detected 3.5 (mg/L)
Downstream concentration (g/L)
1130 21.3 .210 30.7 38600 (38.6 mg/L) 1.89 6.54 1.26 2.86 12.0 (mg/L)
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Table 6 - NPDES Permit exceedances from state sampling 11/07/24.
Parameter Total Suspended Solids
Location Outfall 001
Result 270 mg/L
Daily Maximum Limit 60 mg/L
7. Discussions and Findings
The following are recommendations based on the inspection:
Dlubak Glass Company should continue to engage with the KDEP Frankfort Regional Office to address state inspector concerns found during previous state inspection.
Dlubak Glass Company should maintain and upkeep the existing Stormwater BMP to mitigate pollutant concentration levels in the Stormwater discharge below permit limitations.
Dlubak Glass Company should consider additional BMPs to help meet the NDPES permit limitations.
End of Report
LSASD Project ID: 25-0065
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