Document Y9v4ggrpX4jB1KLqgYQLMw5rk

Cardinal Forge Industrial User Inspection Report March 3, 2021 U.S. Environmental Protection Agency Region 5 Purpose: Industrial User Compliance Evaluation Inspection Facility: Cardinal Forge 1040 South Main Street Rochelle, Illinois 61068 Inspection Date: March 3, 2021 EPA Representatives: Ted Flatebo, Environmental Engineer, 312-886-9402, Flatebo.Ted@epa.gov Newton Ellens, Pretreatment Program Manager, 312-353-5562, Ellens.Newton@epa.gov Facility Representatives: Lucas Ray, Controller, LucasR@forgerg.com Kent Paul, Chief Financial Officer, KentP@forgerg.com Matt McMeekan, Plant Manager, 815-561-8172 Report Prepared by: Ted Flatebo, Environmental Engineer Water Enforcement and Compliance Assurance Branch, Section 2 NEWTON ELLENS Digitally signed by NEWTON ELLENS Inspector Signature and Date:_________________________D_a_t_e:_2_0_21_.0_4_.2_1_0_9_:5_6_:2_0_-0_5_'0_0'____ Approver Name and Title: Ryan J. Bahr, Section 2 Chief, Water Enforcement and Compliance Assurance Branch RYAN BAHR Digitally signed by RYAN BAHR Approver Signature and Date: _________________________D_a_te_:_2_0_21_._04_._2_1_1_5:_4_8:_0_1_-0_5_'0_0_' _ Approval Date: _0__4__/2__1__/_2__0__2__1_____________________________________ PURPOSE OF INSPECTION The purpose of this announced inspection at the Forge Resources Group, LLC dba Cardinal Forge, (Cardinal Forge) Facility ILP000399, located at 1040 South Main Street, Rochelle, Illinois 61068 was to describe, evaluate, and document compliance with the Clean Water Act (CWA) and associated pretreatment regulations. COVID-19 PRECAUTIONS COVID-19 precautions included conducting the inspection opening conference on March 2, 2021 via Microsoft Teams conference call. On March 3, 2021 inspectors drove to and from the facility in separate vehicles. During the inspection, EPA inspectors and site representatives wore face masks and observed social distancing throughout the inspection. BACKGROUND Cardinal Forge is an indirect industrial discharger to the City of Rochelle's (City) wastewater treatment plant (NPDES No. IL0030741) located at 888 Treatment Plant Road, Rochelle, Illinois. EPA is the control authority for the industry as the City currently does not administer an approved pretreatment program. The City submitted an industrial user survey (IUS), as required by their national pollution discharge elimination system (NPDES) permit, to EPA on August 31, 2020. The IUS identified Cardinal Forge as being subject to two categorical pretreatment standards; 40 CFR 467.46 - Aluminum Forming, Subpart D; and 40 CFR 468.15 - Copper Forming, Subpart A (Attachment B). The City of Rochelle does have a pretreatment department although this is not an EPA approved program. The City issued Discharge Permit No. 054 to Cardinal Forge which was effective December 1, 2019 and expires November 30, 2022 (Attachment C). The Cardinal Forge facility contains one building which houses all operations including production, warehouse, and administrative office space (Attachment D). Cardinal Forge's North American Industry Classification System (NAICS) code is #332111, "Iron and Steel Forging". The facility operates Monday through Friday, typically 8 hours per day but can operate longer hours depending on production volumes. There are 16 employees at the facility. The facility began operations at the site in 2001. The company began with two forges and has since undergone multiple expansions in building square footage and process capacity, but the primary business activity has remained consistent. 2 INSPECTION Opening Conference An opening conference for the inspection was conducted at 10:00 A.M. on March 2, 2021 via Microsoft Teams conference call. This opening conference was attended by EPA inspectors Ted Flatebo and Newton Ellens and Cardinal Forge representatives Lucas Ray, Controller, and Kent Paul, Chief Financial Officer. After introductions were made, I stated that the purpose of the EPA's inspection at the Cardinal Forge facility was to conduct an announced inspection on March 3, 2021 to describe, evaluate, and document compliance with the Clean Water Act (CWA) and associated categorical pretreatment regulations. I stated that the inspection would include the opening conference meeting to discuss the facility's operations/to answer interview questions, to conduct a facility operations tour and inspection, and to conduct a closing conference. I also explained to the representatives that a final inspection report will be prepared after the inspection, and it they will be provided a copy summarizing the findings. I stated that the opening conference will entail an interview to secure detailed information on the manufacturing process at the facility, a succinct discussion regarding pretreatment activities if any, and a records review of requested materials related to operations as an industrial user discharging to a publicly owned wastewater treatment works (POTW) located in the City of Rochelle and owned and operated by the City. I stated that we would be finished with the on-site inspection by the afternoon. I asked if there were any confidential business information (CBI) restrictions or concerns (Attachment E). Mr. Paul responded that he would prefer that no final forged products were photographed due to customer privacy concerns, but otherwise there were no CBI concerns. On-Site Inspection EPA inspectors drove to the Cardinal Forge facility in separate vehicles and met at 9:15AM in the parking lot to jointly enter the facility lobby to meet with Lucas Ray, and Matt McMeekan, Plant Manager. Upon entering the lobby, we introduced ourselves and presented our credentials to Mr. Ray and Mr. McMeekan, and reiterated the intent of the visit. During the inspection, EPA inspectors and facility representatives wore face masks and observed social distancing. The inspection began at the start of the forging process with delivery of materials to the facility. Cardinal Forge's primary raw materials are aluminum alloy and brass alloy billets. The facility typically uses three different alloys of aluminum depending on customer specifications: 7075, 2014, 6061 (Document I). The brass alloys used include 3770, UNS C63000, C14500 (Document II). All of the brass alloys used contain at least 50% copper by weight. Billets arrive at the facility pre-cut to the length required for a specific order. They are first weighed, and the quantity of billets is confirmed before being cleaned. The pre-cut billets are cleaned in a large vibrating bowls (Pictures 1-3). Mr. McMeekan stated the facility has three such bowls on site and that all three are used to clean finished forged 3 products but only one bowl is used for raw billets. These vibrating bowls contain a cleaning media and operate on a closed-loop water system that contains a wastewater treatment system (WWTS). Water that flows from the three separate vibrating bowls is pumped to a water filter housed under the elevated walking platform (picture 4). A filter is placed on top of this box and is replaced once or twice daily depending on production volume. From there, the water is pumped to a holding tank (picture 5). This tank collects the wastewater and stores it until sufficient volume is collected to active the floats in the tank, at which point the water is pumped into the WWTS manufactured by Ringwood (picture 6-7). According to Mr. McMeekan, the WWTS treats the water through pH adjustment and the addition of a clay product called RM10. This clay is stored in a large elevated tote adjacent to the treatment system and is mixed with the wastewater automatically to bind to pollutants and create a sludge. The sludge is removed through a filter paper which is located on a spool and continuously fed into the machine. The filter paper-sludge combination is collected in a bin (pictures 8, 11) and is hauled from the facility approximately quarterly. Cardinal Forge provided trash hauling records (Document V). They have a primary account with the trash company for their standard waste disposed of in dumpsters and a second account which is charged for this sludge waste. During the inspection, I observed pooled water at the base of the WWTS and there was evidence of a recent overflow. Mr. McMeekan stated that a small quantity of water spilled while the filter paper roll was replaced and that a staff member would soon clean up the water. No floor drains were observed in the facility. Mr. McMeekan stated that the WWTS has an automatic pH adjustment system which uses concentrated sulfuric acid and sodium hydroxide. Both of these chemicals are stored in single walled 55-gallon barrels, within a chemical storage unit with a roll up door (pictures 12-14). Although the chemical storage unit does have built-in secondary containment, the sulfuric acid and sodium hydroxide are incompatible chemicals and should not be stored in close proximity to each other. In addition, the label on the sulfuric acid barrel states that the chemical "Reacts violently with water". This barrel is stored approximately three feet from the WWTS. When questioned if any wastewater leaves this closed-loop system that feeds the vibrating cleaning bowls, Mr. McMeekan stated that no water is ever removed from the system and that it is only topped off with fresh water as necessary due to water loss through evaporation. Mr. McMeekan also said that no water samples have been collected from the WWTS. After the billets are cleaned, they are ready to be forged. The aluminum or brass is first heated in an oven adjacent to the forging apparatus to bring it to the correct temperature, typically between 250 to 500. The billet is then placed into a mold sprayed with an oil-water lubrication mixture. This lubrication evaporates in the forging process and does not create a wastestream. The molds used by Cardinal Forge are either owned by themselves or they belong to the customer depending on their contract agreement. Once the billet has been forged into a product, one of two things happens. Either the product can have the excess material around the edge trimmed to reveal the final product shape or the rough 4 forged product can be sent to one of the six solution furnaces on site (pictures 16-17). According to Mr. McMeekan, all aluminum products are placed in the solution furnaces, either before or after the excess material is trimmed, but brass products are never put into the solution furnaces. These solution furnaces house water tanks holding 853 gallons of water. Depending on the product specifications, the water may be heated to 140 or it may be room temperature water. Products are held in the water for 30-35 minutes. Mr. McMeekan stated that the solution furnaces are drained as necessary, and the water flows through a piping system directly to the sanitary sewer without treatment. Products that require hot water (140) in the solution furnace are produced at the beginning of the day, and then any products that require room temperature water are produced later in the day. Mr. McMeekan said that it varies widely how often the tanks are drained and refilled. It is sometimes daily and sometimes it can be weeks between draining depending on the products that are being produced. Records are not kept for how often the tanks are drained and refilled. He also stated that the solution furnaces are all drained once per year for an annual servicing. During this time, solids are removed from the bottom of the tank and a cleaner is used to scrub the interior surfaces. He was unable to provide the name of the cleaning product used. After the parts have completed both the solution treatment and surplus material trimming stages, the parts are placed in an aging oven. The facility has four ovens, which are used to improve product quality. The length of time the parts spends in the oven and at what temperature vary but 350 for 10 hours is common. Following this step, the parts are inspected for final quality. Depending on customer specifications, some final sanding to remove rough edges may be conducted. Additionally, some customers may require a product inspection immediately after forging. This process takes place in the hot inspection area. A quench tank is located in this area (picture 18-19) to rapidly cool parts after forging so that an employee can handle and inspect them. Water from the quench tank is discharged, without treatment, to the sanitary sewer. This concluded the facility walk through which ended at 10:47 A.M. Water Usage During the opening conference, I asked Mr. Ray and Mr. Paul how much water the Cardinal Forge facility used on an average daily/monthly basis. They were unable to provide an answer but indicated we should review the City of Rochelle water utility bills they had provided (Document IV). They stated that other than the City water meter, there were no other water metering devices within the facility. Mr. Paul stated that he did not believe there had been any significant, meaning more than 20%, changes in water usage at the facility in the past 3 years. Next, I asked about specific areas of water usage at the facility. Mr. Ray and Mr. Paul indicated they believed the primary usage of water at the facility was for employee hygiene and sanitary waste. The facility does have an employee locker room space with showers; although, Mr. Ray stated he did not believe they were used on a regular basis. They described the water usage associated with the vibrating cleaning bowls and the solution furnaces, as being used for parts cleaning and treating forged products respectively. 5 The facility does not use a boiler or cooling tower. The solution furnaces contain their own water heating equipment to heat the tanks as necessary. All water entering the facility flows through a water filter (picture 15). The facility production area floor appeared to be composed entirely of polished concrete and we did not observe any floor drains anywhere in the facility. According to Mr. McMeekan, the floors are cleaned weekly using a mechanical floor scrubber, this is a dry process and does not generate wastewater. No production or storage of materials occurs outdoors. There is an uncovered, paved employee parking lot immediately north of the building. Chemical Usage The facility does have a parts cleaner onsite which is used as necessary and serviced by an outside contractor. The facility also has their oily rags laundered for them by a vendor. The facility stores their chemicals in 55-gallon drums (picture 9-10). Chemicals used include trim press oil (Rockway 220-s), hydraulic fluid (Rock Valley Oil and Chemical Co. Trojan 32aw), gear oil (Rock Valley Oil and Chemical Co. RV Ep Lube, S-460), and 142 solvent (VS140). The facility places buckets under the faucet for each drum to catch drippings. At the base of the rack where the drums are stored, absorbent was sprinkled on the ground as a precaution. The absorbent was dry and clean at the time of inspection. I asked Mr. McMeekan if the facility had spill kits on site and he stated they did not. The facility also had one 55-gallon drum for used oil. Mr. Ray provided one hazardous waste hauling manifest from Rock Island Lubricants (Attachment F) for disposal of used mineral spirts and used oil. Categorical Pretreatment Standards During the opening conference I asked Mr. Ray and Mr. Paul if Cardinal Forge was subject to any categorical pretreatment standards. They responded that they did not believe the facility was subject to any of these standards. Next, I asked if they had conducted any wastewater sampling or if they had any designated sampling locations at the facility. They responded the company has neither designated any sample locations nor conducted any sampling. They also indicated that although the City of Rochelle discharge permit reserves the right for a City representative to sample the facility's wastewater, the City has not done so. According to EPA records, the facility has never submitted a baseline monitoring report or any other type of categorical pretreatment monitoring reports. The facility was evaluated to determine if the aluminum forming (40 CFR 467) and copper forming (40 CFR 468) categorical pretreatment regulations were applicable. Upon completing the inspection, reviewing the regulations in the federal register, and the applicable guidance document, the facility appears to generate wastestreams from processes defined as categorical: water discharged from the quench tank in the hot inspection area and water discharged from the solution furnaces. 6 The aluminum forming category was promulgated in 1988 and the copper forming category was promulgated in 1986. Because the facility began operations in 2001, their wastestreams may be subject to the pretreatment standards for new sources for both regulations: 40 CFR 467.46 and 40 CFR 468.15. Closing Conference After completing the facility walk through, the EPA inspection team went to the facility's conference room to discuss their findings and to prepare for the closing conference. At 11:10 A.M. a closing conference with Mr. Ray and Mr. McMeekan was conducted. During the closing conference, I briefly reviewed and discussed the information and documents we received and summarized our observations. I also discussed the preliminary areas of concern, noting that these would be finalized when we sent our inspection report. I gave the Cardinal Forge representatives the opportunity to ask questions regarding the inspection and our preliminary findings. I then ended the closing conference and the inspection team departed the facility at 11:30 A.M. OBSERVATIONS AND AREAS OF CONCERN EPA has the following areas of concern following the review of information gathered during the inspection. The categorical pretreatment regulations at 40 CFR 467.40 describes that the forging subcategory is applicable to "discharges of pollutants to waters of the United States and introductions of pollutants into publicly owned treatment works from the core of the forging subcategory and the ancillary operations". In particular, 40 CFR 467.46- Aluminum Forming, Subpart D includes standards for new aluminum forming processes. Similarly, 40 CFR 468.10 - Copper Forming describes that the subpart applies to "discharges of pollutants to waters of the United States, and introduction of pollutants into publicly owned treatment works from the forming of copper and copper alloys except beryllium copper alloys". The water bath cooling process at the solution furnaces was observed as an ancillary operation utilized at the forge and results in a discharge. The quench tank ancillary operation also resulted in a discharge. The facility has not submitted a baseline monitoring report to EPA, has not conducted effluent sampling, and has not maintained sufficient records to determine compliance with a production-based pretreatment standard. The team noted storage of incompatible concentrated sodium hydroxide and sulfuric acid immediately next to each other, and in the vicinity of water. 7 LIST OF ATTACHMENTS A. Photo Log B. City of Rochelle Industrial User Survey - Dated August 31, 2020. C. City of Rochelle Discharge Permit No. 054 D. Cardinal Forge Floor Plan E. Confidential Business Information (CBI) and Personal Privacy Information (PPI) Document. F. Hazardous Waste Hauling Manifest - Dated August 10, 2018. G. Cardinal Forge Response to City of Rochelle Industrial User Survey H. Baxter Woodman Site Inspection - Dated May 14, 2019 LIST OF DOCUMENTS PROVIDED TO EPA NOT ATTACHED TO REPORT BUT ARE AVAILABLE FOR REVIEW UP REQUEST I. Aluminum Delivery Receipts II. Brass Deliver Receipts III. Metal Recycling Receipts IV. Rochelle Municipal Utilities, Water Bills V. Northern Illinois Disposal Invoices 8 Attachment A Cardinal Forge EPA Inspection March 3, 2021 All photos taken by Ted Flatebo, Environmental Engineer, U.S. EPA Camera: Ricoh WG-4 1: RIMG0032 Description: One of three vibrating washers used to clean raw billets and forged products. Location: Northwest corner of building. Camera Direction: North. Date/Time: March 3, 2021 / 9:47 A.M. Page 1 Cardinal Forge March 3, 2021 2: RIMG0033 Description: Water nozzles used to spray water contained in a closed loop-system onto billets/parts as they exit the vibrating cleaning bowls. Location: Northwest corner of building. Camera Direction: North. Date/Time: March 3, 2021 / 9:48 A.M. 3: RIMG0034 Description: Overview of vibrating cleaning bowls. Note forged parts in bowl being cleaned in media mixture. Location: Northwest corner of building. Camera Direction: Down. Page 2 Cardinal Forge March 3, 2021 Date/Time: March 3, 2021 / 9:49 A.M. 4: RIMG0035 Description: Water filter tank under elevated platform. Water from all vibrating bowl flows through the filter paper on top of tank before flowing to wastewater treatment system. Location: Northwest corner of building. Camera Direction: Northwest. Date/Time: March 3, 2021 / 9:50 A.M. Page 3 Cardinal Forge March 3, 2021 5: RIMG0036 Description: Holding tank for wastewater between the water filter tank and the wastewater treatment system. Note floats within tank that activate wastewater treatment system when sufficent volume is collected. Location: Northwest corner of building. Camera Direction: Down. Date/Time: March 3, 2021 / 9:51 A.M. Page 4 Cardinal Forge March 3, 2021 6: RIMG0037 Description: Wastewater treatment system. machine and backup roll. Location: Northwest corner of building. Camera Direction: West. Date/Time: March 3, 2021 / 9:52 A.M. Note roll of continuous feed filter paper installed in 7: RIMG0038 Description: Wastewater treatment system manufacturer sign. Location: Northwest corner of building. Camera Direction: West. Date/Time: March 3, 2021 / 9:53 A.M. Page 5 Cardinal Forge March 3, 2021 8: RIMG0039 Description: Sludge exiting wastewater treatment system. Location: Northwest corner of building. Camera Direction: East. Date/Time: March 3, 2021 / 9:54 A.M. 9: RIMG0040 Description: Chemical storage area. Drip buckets are placed under spouts of barrels but no secondary containment is present. Location: Northwest corner of building. Camera Direction: Northwest. Date/Time: March 3, 2021 / 9:57 A.M. Page 6 Cardinal Forge March 3, 2021 10: RIMG0041 Description: Used oil storage. Note secondary containment around barrel and filter media for wastewater treatment system. Location: Northwest corner of building. Camera Direction: Southeast. Date/Time: March 3, 2021 / 10:01 A.M. Page 7 Cardinal Forge March 3, 2021 11: RIMG0042 Description: Overview of wastewater treatment system. Location: Northwest corner of building. Camera Direction: Northwest. Date/Time: March 3, 2021 / 10:06 A.M. Page 8 Cardinal Forge March 3, 2021 12: RIMG0043 Description: Chemical storage area. Note water on the ground surrounding wastewater treatment system. Location: Northwest corner of building. Camera Direction: Northwest. Date/Time: March 3, 2021 / 10:07 A.M. Page 9 Cardinal Forge March 3, 2021 13: RIMG0044 Description: Sodium hydroxide and sulfuric acid storage area, chemicals are used for wastewater treatment pH adjustment. Note strong acid and base stored next to each other in single-hulled barrels. Location: Northwest corner. Camera Direction: Northwest. Date/Time: March 3, 2021 / 10:11 A.M. Page 10 Cardinal Forge March 3, 2021 14: RIMG0045 Description: Close up of Sulfuic acid and sodium hydroxide lables. Note sulfuric acid lable states "Reacts violently with water". Location: Within yellow plastic chemical storage container in northwest corner of building. Camera Direction: North. Date/Time: March 3, 2021 / 10:11 A.M. Page 11 Cardinal Forge March 3, 2021 15: RIMG0046 Description: Water filter for municipal water entering the building. This is the only water supply for the facility. Location: South wall of building. Camera Direction: South. Date/Time: March 3, 2021 / 10:24 A.M. Page 12 Cardinal Forge March 3, 2021 16: RIMG0047 Description: Overview of solution furnace one, two, and three. furnaces at the facility. Location: Along north wall of building. Camera Direction: North. Date/Time: March 3, 2021 / 10:32 A.M. There are six total solution 17: RIMG0048 Description: Water stored within solution furnace. Location: Along north wall of building. Camera Direction: Down. Date/Time: March 3, 2021 / 10:32 A.M. Page 13 Cardinal Forge March 3, 2021 18: RIMG0049 Description: Quench tank within hot inspection area. Location: North-center of building. Adjacent to a solution furnace. Camera Direction: North. Date/Time: March 3, 2021 / 10:45 A.M. 19: RIMG0050 Description: Water within quench tank in the hot inspection area. Location: North-center of building. Adjacent to a solution furnace. Camera Direction: Down. Date/Time: March 3, 2021 / 10:45 A.M. Page 14 Cardinal Forge March 3, 2021 Attachment B August 31, 2020 U.S. Environmental Protection Agency Region 5 Water Enforcement and Compliance Assurance Branch 77 West Jackson Blvd. Chicago, Illinois 60604 Subject: City of Rochelle - Rochelle Water Reclamation Facility NPDES Permit No. IL0030741 Status Update on Pretreatment Activities - Special Condition 11 Dear Water Enforcement and Compliance Assurance Branch: The City of Rochelle has retained Baxter & Woodman, Inc. to assist with NPDES compliance for the Rochelle Water Reclamation Facility (WRF) Permit No. IL0030741. This submittal describes the City's pretreatment activities and a listing of the significant industrial users in accordance with Special Condition 11. The deadline for the report of pretreatment activities was 12-months after the effective date of the permit, September 1, 2019. Major Work Efforts: Industrial User Survey The City of Rochelle has an informal pretreatment program which was initiated in 1993. The City and Baxter & Woodman have completed an industrial user survey of both the permitted and unpermitted industries and businesses in the WRF service area. The City and Baxter & Woodman developed a list of 52 industrial users within the service area using local maps, the Illinois Manufacturing Directory, and general knowledge from City staff members, including existing permitted users in the program. Special consideration was given to include businesses that may be using phosphorus containing chemicals, to complete the requirements of Special Condition 18 for influent reduction of phosphorus. A survey was sent to each business requesting a response to the industrial user survey. This survey gathered information from each industrial user on the type of business, raw materials, processes completed, discharge of process waste, and use of phosphorus containing chemicals. Industry surveys were collected from 44 industries. Eight locations were excluded as they were determined to be vacant, out of the WRF service area, on septic, or no longer hauling process wastewater to the WRF. Baxter & Woodman screened the surveys, contacted industries for follow up questions, and determined necessary site inspections. Site inspections were completed by the City or Baxter & Woodman at the following 11 businesses:  Erie Foods International, Inc. Carbon Green Greenhouse LLC, DBA MightyVine BrightFarms CHI Greenhouse Blue Beacon Truck Wash Cardinal Forge Continuous Cast Alloys Hixson Lumber Sales Master Graphics News Media Corporation Rochelle Travel Plaza Silgan Containers Manufacturing Baxter & Woodman worked with the City to collect information during the site inspections and classifications were determined based on the processes the industries implement. The City had process information on several industries who have industrial user discharge permits. The permits, permit applications, and other documentation of the existing industrial users in Rochelle's pretreatment program were reviewed to determine the classifications of industries. Due to the impacts of COVID-19, site inspections were not possible at all industries, however classifications were determined based on information available. Three categorical industrial users and five significant industrial users were identified during the survey. They are: Continuous Cast Alloys - Horizontal continuous casting - metal foundry, using nickel, cobalt, chrome, molybdenum, silicon, carbon, beryllium, tungsten, and boron. Water is used to clean the parts and some parts go through a vibratory bowl. Classification: Categorical Industrial User 40 CFR 471.35-Nonferrous Metals Forming and Metal Powders Point Source Category Subpart C - Nickel-Cobalt Forming - New Source 40 CFR 471.55 - Nonferrous Metals Forming and Metal Powders Point Source Category Subpart E - Refractory Metals Forming - New Source Cardinal Forge - Closed die forging using aluminum, and brass (58-61% copper) Classification: Categorical Industrial User 40 CFR 467.46 Aluminum Forming Point Source Category Subpart D - Forging Subcategory - New Source 40 CFR 468.15 Copper Forming Point Source Category Subpart A - Copper Forming Subcategory - New Source Water Enforcement and Compliance Assurance Branch United States Environmental Protection Agency - Region 5 August 31, 2020 200144.30 Page 2 CHS, Inc. - Manufacturing of ethanol used for fuel, corn oil, Distiller's Dried Grains with Solubles (DDGS), and Wet Distiller's Grains with Solubles (WDGS) Classification: Categorical Industrial User 40 CFR 414.111 - Organic Chemicals, Plastics and Synthetic Fibers (OCPSF) Subpart K -Indirect Discharge Point Sources - New Source 40 CFR 406.26 - Grain Mills Point Source Category Subpart B Corn Dry Milling Subcategory - New Source Allied Waste Industries of Illinois - Dixon Landfill - Non-hazardous waste landfill hauling leachate to the WRF, daily average flow 27,000 gallons per day Classification: Significant Industrial User, based on landfill leachate (non-domestic wastewater) hauled greater than 25,000 gallons per day Rochelle Foods LLC - Manufacturing meat products including bacon, ham, and microwaveable meals using meat products, meat smoking products, vegetables, starches and packaging materials; daily average flow of process wastewater 400,032 gallons per day Classification: Significant Industrial User, based on process flow discharged of greater than 25,000 gallons per day and past occurrences of treatment plant upsets and slug loads the WRF Rochelle Waste Disposal - Municipal solid waste landfill pumping leachate by forcemain to the WRF, daily average flow 86,500 gallons per day Classification: Significant Industrial User, based on landfill leachate (non-domestic wastewater) discharged greater than 25,000 gallons per day Waste Management -Dekalb County Landfill - Solid waste landfill hauling leachate to the WRF, daily average flow 40,000 gallons per day Classification: Significant Industrial User, based on landfill leachate (non-domestic wastewater) discharged greater than 25,000 gallons per day Waste Management - Prairie Hill Landfill - Solid waste landfill hauling leachate to the WRF, daily average flow 30,000 gallons per day Classification: Significant Industrial User, based on landfill leachate (non-domestic wastewater) discharged greater than 25,000 gallons per day Several industries will be evaluated further to confirm phosphorus containing waste. This information will be included in the Phosphorus Discharge Optimization Plan, to be submitted prior to the 36-month deadline of September 1, 2022. Water Enforcement and Compliance Assurance Branch United States Environmental Protection Agency - Region 5 August 31, 2020 200144.30 Page 3 Pretreatment Activity As of the date of this report, there are three categorical industrial users and five significant industrial users within the WRF service area. The WRF is not currently having any operational issues due to industries, however plant upset has occurred in the past. FBC Industries, an industrial user manufacturing additives and preservatives for the food and beverage industry, had a tank failure in 2017 resulting in 15,000 gallons of calcium chloride to be discharged to the WRF. Spill containment measures have been added to address this. Rochelle Foods, a significant industrial user, had violations in the past and as recently as June 2020 causing fats, oils and grease and surfactants at the treatment plant. The City is working with Rochelle Foods to maintain compliance with pretreatment standards. Pretreatment permittees including Rochelle Foods, CHS, Rochelle Waste Disposal, and Rochelle Energy collect samples for analysis to meet the City's local limits and for the calculation of surcharge. Notices of violation are issued when necessary and site inspections are completed by City staff on an annual basis. No further pretreatment activities are planned or expected at this time, however the City will be evaluating industries as they move into the service area for any potential impacts to the WRF. We trust that this response will provide an adequate update for compliance with Special Condition 11. Please contact Ms. Sharon Hawkins (815-561-2067) of Rochelle Municipal Utilities with any comments, questions or concerns. Sincerely, BAXTER & WOODMAN, INC. CONSULTING ENGINEERS Lisa G. Lucht, P.E. LGL C: Adam Lanning, City of Rochelle (via email) Jay Mulholland, City of Rochelle (via email) Sharon Hawkins, City of Rochelle (via email) Nichole Schaeffer, Baxter & Woodman, Inc. (via email) ELECTRONIC SUBMITTAL ONLY I:\Crystal Lake\ROCHC\200144-NPDES Compliance Assist\30-NPDES Compliance\SC11-IU Survey & PT Report\SC11 Report\2020 Letter to USEPA region 5 - SC 11 as sent 083120.docx Water Enforcement and Compliance Assurance Branch United States Environmental Protection Agency - Region 5 August 31, 2020 200144.30 Page 4 Attachment C Attachment D EXIT EXIT EXIT EXIT EXIT EXIT EXIT EXIT Attachment E Confidential Business and Personal Privacy Information Assertion Requirements You may assert a business confidentiality claim covering any parts of the information requested in the attached Appendix B, as provided in 40 C.F.R. 2.203(b). To make a confidentiality claim, submit the requested information and indicate that you are making a claim of confidentiality. Any document for which you make a claim of confidentiality should be marked by attaching a cover sheet stamped or typed with a caption or other suitable form of notice to indicate the intent to claim confidentiality. The stamped or typed caption or other suitable form of notice should employ language such as "trade secret" or "proprietary" or "company confidential" and indicate a date, if any, when the information should no longer be treated as confidential. Information covered by such a claim will be disclosed by EPA only to the extent permitted and by means of the procedures set forth in 40 C.F.R. Part 2. Under 40 C.F.R. 144.5, the following information is not entitled to confidential treatment and claims of confidentiality will be denied: name and address of any permit applicant or permittee, and information which deals with the existence, absence, or level of contaminants in drinking water. Allegedly confidential portions of otherwise non-confidential documents should be clearly identified. EPA will construe the failure to furnish a confidentiality claim with your response to the information request as a waiver of that claim, and the information may be made available to the public without further notice to you. Determining Whether the Information Is Entitled to Confidential Treatment Pursuant to 40 C.F.R. Part 2, Subpart B, EPA may at any time send you a letter asking that you support your confidential business information (CBI) claim. If you receive such a letter, you must respond within the number of days specified by EPA. Failure to submit your comments within that time would be regarded as a waiver of your confidentiality claim or claims, and EPA may release the information. If you receive such a letter, EPA will ask you to specify which portions of the information you consider confidential by page, paragraph and sentence. Any information not specifically identified as subject to a confidentiality claim may be disclosed to the requestor without further notice to you. For each item or class of information that you identify as being CBI, EPA will ask that you answer the following questions, giving as much detail as possible: 1. For what period of time do you request that the information be maintained as confidential, e.g., until a certain date, until the occurrence of a special event or permanently? If the occurrence of a specific event will eliminate the need for confidentiality, specify that event. 2. Information submitted to EPA becomes stale over time. Why should the information you claim as confidential be protected for the time period specified in your answer to question number 1? 3. What measures have you taken to protect the information claimed as confidential? Have you disclosed the information to anyone other than a governmental body or someone who is bound by an agreement not to disclose the information further? If so, why should the information still be considered confidential? 4. Is the information contained in any publicly available databases, promotional publications, annual reports or articles? Is there any means by which a member of the public could obtain access to the information? Is the information of a kind that you would customarily not release to the public? 5. Has any governmental body made a determination as to confidentiality of the information? If so, attach a copy of the determination. 6. Do you assert that the information is submitted on a voluntary or a mandatory basis? Explain the reason for your assertion. If you assert that the information is voluntarily submitted information, explain whether and why disclosure of the information would tend to lessen the availability to EPA of similar information in the future. 7. Is there any other information you deem relevant to EPA's determination regarding your claim of business confidentiality? If you receive a request for a substantiation letter from the EPA, you bear the burden of substantiating your confidentiality claim. Conclusory allegations will be given little or no weight in the determination. In substantiating your CBI claim(s), you must bracket all text so claimed and mark it "CBI." Information so designated will be disclosed by EPA only to the extent allowed by and by means of the procedures set forth in 40 C.F.R. Part 2, Subpart B. If you fail to claim the information as confidential, it may be made available to the public without further notice to you. Please also note that pursuant to 40 C.F.R. 2.204, EPA may determine that the information you claimed as CBI is clearly not entitled to confidential treatment and issue a final determination without providing you an opportunity to substantiate your claim. Examples of information clearly not entitled to confidential treatment include effluent data, as defined in 40 C.F.R. 2.302(A)(2), and information in National Pollution Discharge Elimination System permit applications are not entitled to confidential treatment. See 40 C.F.R. 122.7. Personal Privacy Information Please segregate any personnel, medical and similar files from your responses and include that information on a separate sheet(s) marked as "Personal Privacy Information." Disclosure of such information to the general public may constitute an invasion of privacy. 2 Attachment F `-- A 50 1320 1stSmael Z3',f%7.`3,'2i'.3%o Phone: (309) 788-1854 Fax: (309) 786-3946 INVOICE Batclt 03368 Invoioer PJD Invoice Number: 0025451-lN Invoice Date: 8/10/2018 Paw 1 SOLD TO: ___I SHIP TO: CARDINAL FORGE P.O. BOX 567 Dekalb. IL 60115 L_ mpfiacz %<..\ 5 CARDIANL FORGE 1040 S MAIN ST Rocheile, IL 61068 __J L - Net 30 Days Order N0: 0027960 Thomas Mason Order Date 8/3/2018 J Shig Date 8/3/2018 Sh_ip VIA DEST Item Number UIM Whse: Ordered Shipped Back Ordered USEDMS /DD GL 000 0.00 55.000- USED MINERAL SPIRITS PICKED UP (1) FULL DRUM OF USED MINERAL SPIRITS PICKED UP (1) FULL DRUM OF USED OIL EACH 0.00 2.000 Drum Deposit TOOK (2) EMPTY CLOSED TOP DRUMS FOR REPLACEMENT CREDIT WILL BE ISSUED WHEN DRUMS ARE RETURNED FULL REF: SO# 27960 MANlFEST# 25535 55.000 0.000 Price 0.0000 25.0000 F.O.B .-_I _J ' 1 CARDIN I Amount 0.00 50.00 kwiktag as 239 045 559 Thank you for your order A 1% per month service charge can be added to an invoices unpaid for more than 30 days from invoice date Net Invoice: Less Discount; Freight 33195 Tax? Invoice Total: om 50.00 0-00 0-00 50.00 Cardinal Forge Company 1040 South Main St Rochelle, Illinois 61068 Phone: 815-561-8172 Purchase Order - Completed PO Number: 1699 PO Reference: Ordered: 8/23/2018 Customer ID: ROCKIS Supplier: Rock Island Lubricants Thomas Mason 1320 First Street. PO Box 5015 Rock Island IL phone 3094885631 Toll Free 800-522-1150 Fax 3O9_786_3946 EmaiI'thornas@n`|coinc ' com 61204-5015 Shipping Method: Best Way Terms: Fax: 815~561--0613 Status: Required: Completed 9/6/2018 8:18:13 AM W0Completed: 8/23/2018 Reference: Ship To: Cardinal Forge Company 1040 South Main St Rochelle Illinois 61068 Phone 815-561-8172 Fax 815-561-0613 Bill To. Forge Resources Group Po Box 369 Dekalb Illinois 60115 Phone 815-758-6400 Fax 815-787-8588 Service comments W0 Reference Account Pick up used oil and solvent and drop off two empties <none> Quantity 1.00 hours Price Discount Line Total 50.00 0.00% Subtotal Freight Tax Total Amt Paid 50.00 50.00 0.00 0.00 50.00 0.00 Printed 8/23/2018 8:21:41 AM By Matt Hitchcock Charge to <none> Page 1 of 1 ~ Fluid Care VA ` I320 lst Street ' Rock lsiand, IL 6120! RECYCLlNG*MANlFEST V L * * ; * . 5 Transgorter1 Comgany Name RILCO Fluid Care ~ MANIFEST Phone #2 PO.# EPA ID # iLDO258117D4 Designated Faciligy and Site Address RILCO Fiuid Care 1320 1st Strget Rock Island, "IL 61201 Phone #: 309/788/1854 Fax #: 309/786-3946 EPA ID #: ILDO25811704 THIS MANIFEST IS YOUR CERTIFICATION OF FULLY RECYCLED MATERIALS. COMPLETE DOCUMENTATION REMAlNS ON FILE AT RILCO FLUID CARE AND IS AVAILABLE UPON REQUEST. SHlPPlNG NAME, DESCRIPTION, AND ~ ~ ~ DATE QUANTITY c 4- DESCRlPTlON : i=i|t s Gaiions Used Oil Antifreeze ~<4 Barrel(s) Used Absorbents Ganons of Oily Water Mix SPECIAL INSTRUCTIONS AND ADDITIONAL INFORMATION: ON SPEC BURNER FUEL COPIES OF USED OIL ANALYSIS ARE AVAILABLE ATJHE RILCO FLUID CARE OFHCE LOCATED AT: 1320 1ST STREET, ROCK iSLAND, IL 61201 309/788-1854 K ` Comp_any's Certification: I certify the above described materials are not subject to Federal/State regulations for reporting proper disposal of non-hazardous materials. ~ ` Fnsgoner 1: ~ ~ ~~~ 1 Acknowiedge repeipt of materials ~ NAME "., Processing V, v ~1 ' Facility: Acknowledge in ~ ~ ,V.,,.--, _.,.4 receipt of materials. Assure all materiais will be recycled with contracted guideline, no portion will belandfilled. NAME: EPA 10%: SIGNATURE: ~ = ` - DOT# 367095 White - Pick Up Copy~ Yellow - ` : * Q Pink -- DATE: UPM#O3670~96--lL -'.7`I'7 ,7 7,'?! \r~\(!F`:"7 33v'-J r' /.Vrmr!, /z` /i,.';`(7I Sales Order Order Number: 0027960 Order Date: 8/3/2018 Expiration Date: 8/3/2018 Page: 1 SOLD TO: CARDINAL FORGE PO, BOX 567 Dekalb, IL 60115 ._._ SHlP TO: CARDIANL FORGE 1040 S MAIN ST Rochelle, IL 61068 _Jl_ _J Terms Salesperson` Net 30 Days Thomas Mason Order NO: 0027960 Customer Number: Order Date CARDIN 8/3/2018 sum Datg 8/3/2018 Salesperson E-mail: Ship VIA item Nu~mber UIM whse; Ordered Shipped USEDMS ~~ ~ ~~ ~~ /DD G1. 000 0.000 0.000 USED MINERAL SPIRITS PICK UP (1) FULL DRUM OF USED MINERAL SPIRITS PICK UP 1 ._ I UM OF USED OIL EACH 0.000 0.000 ~ rum Deposit TAKE (2) MPTY CLOS ~D TOP DRUMS IN CASE THEY NEED Back Order 0.000 0.000 REPLACEMENTS Customer P.O. Number DEST Price 0.0000 F.0.B, 250000 ~Amount `$10.00 0.00 Net Order: Less Discount: Freight: Sales Tax: Order Total: 0.00 0.00 0.00 ;~}0._(V)0 0`.`0O Rum mam $am ~ I320 Ist Street Rock Island, H. 6120! RECYCL|N@MANlREST GgneratQr's Name and Address: `E 1 5, 1-, L I I I Transgorter 1 Comganx Ngmg RILCO Fiuid Care E < MANIFEST Phone #2 ` Q; 1:, P.O.# 309/7884854 EPA ID # ILD025811704 Designated Facility and Site Address RILCO Fiuid Care 1320 1st Street Rock Island, IL 61201 Phone #: 309/788/1854 Fax #: 309/786-3946 EPA ID #: |LDO25811704 T!-HS MANIFEST l8 YOUR CERTIFICATION OF FULLY RECYCLED MATERIALS. COMPLETE DOCUMENTATKDN REMNNS ON FILE AT RILCD FLUiD CARE AND IS AVNLABLE UPON REQUEST. SHIPPING NAME, DESCR!PTlON, AND IDENTIFICATION DATE REQUESTED QUANT!TY C A ~ E ~ ~ " Wjjf " DESCR!PT|ON i=`.n:;e; Used Gallons ' Oil ` ; :7 : Antifreeze ` BarreI(s) Used Absorbents Gallons of Oi|y Water Mix Q," mg', E; Emptycflrums 53; E 3 SPECiAL INSTRUCTIONS AND ADDYHONAL INFORMATION: ON SPEC BURNER FUEL COPIES OF USED OIL ANALYSIS ARE AVAILABLE ATGTHE RILCO FLUID CARE OFF|CE LOCATED AT: 1320 1ST STREET, ROCK ISLAND. M. 61201 309/7884854 Company's Certification: I certify the above described materials are not subject to Federal/State regulations for ~~ reporting proper disposal of non--hazardous materials. ~~~ V . 1: Ackhovhedge ref/eip of materiais N J' /*1 . "'?,x 1' 7' 1,95,` ;':":' ,v`f}_'<;f,4~ j 5`GNATURE'Z J Processing Facility: Acknowledge receipt of materiats. Assure all materiais will be recycled in accordance with contracted guideline, no portion will be tandfmed. NAME; EPA um: lLD025811704 ; S!GNATURE:_ x DOT# 367056 3 White -- Pick Up Copy Yellow - Accounting ~ .6 Pink - Generators DATE: `Q .1 UPM#O367096-lL Attachment G Attachment H