Document Y9vGe3Vw7jOqVOwOKXLJDkboN

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN WATER ACT INSPECTION REPORT Calumet Specialty Products Partners, L.P., Burnham, Illinois Jason Hewitt, Life Scientist Water Enforcement Branch, Section 1 Molly Smith, Section Chief Water Enforcement Branch, Section 1 File BASIC INFORMATION Facility Name: Calumet Specialty Products Partners, L.P. Facility Location: 14000 Mackinaw Avenue, Burnham, Illinois 60633 NPDES Permit Number: N/A Facility Type: Petroleum Products Transfer Terminal Date of Inspection: May 28,2021 EPA Inspector(s): 1. Jason Hewitt, Life Scientist 2. Bill Jones, Environmental Engineer Other Attendees: 1. Henry Banach, Calumet Specialty Products Partners, L.P., Plant Manager 2. Mark W. Cheesman, Calumet Specialty Products Partners, L.P., SR. HSE Assessor 3. Angie Martin, Heritage Environmental Services, Vice President 4. Steve Lucero, Heritage Environmental Services, Project Manager Contact Email Address: henry.banach@calumetspecialty.com; mark.chessman@clmt.com Inspection Type: Industrial Stormwater Facility Notification: Unannounced Inspection Announced Inspection Regulations Relevant to Inspection: Industrial Stormwater Exposure - 40 C.F.R. 122.26 Stormwater Discharges, Clean Water Act section 301 Arrival Time: Departure Time: 9:00 AM 12:00 PM OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility The following information was obtained verbally from Henry Banach, Mark Chessman, Angie Martin, and Steve Lucero unless otherwise noted. Company Ownership: Calumet Specialty Products Partners LP, 2780 Waterfront Parkway East Dr. Ste 200, Indianapolis, Indiana 46214. Process Description: Calumet Refining, LLC is nationwide company primarily engaged in blending, compounding, and re-refining lubricating oils and greases from purchased mineral, animal, and vegetable materials. The parent company is Calumet Specialty Products L.P. The Burnham Terminal location, which was inspected, is a terminal and blending facility that accepts petroleum products via rail, stores them on site, and receives tanker trucks that accept, load, and transport the product off site. The Terminal takes 2 switches per week, with an average throughput of 80 rail cars monthly, and loads approximately 14 trucks per day, 5 days per week. The facility can do some product blending and has an in-house lab to test and certify. The Burnham facility SIC code is 5171 (Petroleum Bulk Stations and Terminals). Staff Interview(s): Staff Interviews began at approximately 9:30 am with Jason Hewitt representing EPA and the aforementioned other attendees representing Calumet Specialty Products L.P. Bill Jones arrived at approximately 9:30 am. Page 2 of 1 Plant Manager Henry Banach stated that the facility operates as a bulk station and terminal and there is no vehicle maintenance and washing at the facility, vehicles are sent offsite for services. Consultant Angie Martin stated that the facility does not have an EPA Clean Water Act (CWA) permit but does have coverage under the Illinois Registration of Smaller Sources (ROSS) Program and has a Cook County Environmental Control Permit. Additionally, the facility has a local stormwater permit agreement with Metropolitan Water Reclamation District (MWRD). The state has never requested that the facility apply for any additional CWA coverage. Henry Banach stated that all stormwater onsite is collected and tested and pretreated for oil and grease prior to discharge to the sewer system, and that the facility is built to hold a 20-year 24 hour storm plus the volume of the largest tank. He also indicated that there were emergency spill kits on site and the facility has an emergency spill standard operating procedure. As per Henry Banach, Angie Martin, and Steve Lucero, there is 1000ft of skirted boom on site and a small John Boat which can be used to place the initial boom. Additionally, there is an emergency contractor (Heritage Environmental) which is on hand if needed, has Oil Spill Response Organization (OSRA) certification, and that all oil spill response equipment including backups are held on site. Henry Banach stated that there have been no major spills in the past and provided spill reports for the previous 3 years. Henry Banach stated that there have been no issues with water level or river flooding into or out of the site. A berm covers both sides of the site and has been around for a long time. The berm periodically gets rebuilt and is maintained frequently. For the stormwater system, there is regular maintenance on the skimmer system (oil water separator) and the system has an alarm. The collection tank for the oil water separator is frequently pumped out and the remaining oil sold back to market. Henry Banach indicated that the lab does generate some hazardous waste. Angie Martin stated that Heritage Environmental disposes of the hazardous waste offsite. Facility Walk-Through Occurred: Yes Data Collected and Observations: The facility walkthrough focused on the site perimeter controls and internal stormwater sewer system. Stormwater on site gravity drains to a series of inlets which are all on an internal sewer. The internal sewer is gravity fed to a pump room and then pumped to an oil water separator, prior to being held, and then discharged to MWRD. MWRD samples at a manhole located directly to the east, off property, of the site (see image 23). The facility also has a surge wall which protects stormwater from going off site where rail cars unload (see image 1). Multiple inlets with standing water were observed, and it was noticeable that these inlets were well maintained but draining water slowly were the gravity elevation was higher (see images 2, 3, 6, 6, 8, 11, 15, 16, 17, 25, 28, 32). No trains were active on site, but trucks were present loading product near inlets (see image 4, 14). General maintenance on site was good as evidence by lack Page 3 of 1 of sheen at most inlets, although sheen was present at the most low lying area (see image 28), and site flow characteristics were acting as designed with no evidence of water leaving the site or pooling in areas without inlets. One area of the site (see image 16) upper elevation east side, may not have had the necessary elevation gradient to ensure stormwater from heavy rainfall would stay on site, but this was not verified. All industrial waste and storage containers not actively being used were enclosed in the Inside storage Building on the North end of the site (see image 13). The pump room appeared in good working order (see images 18, 19, 20), and there was no evidence of issues with the oil/water seperator (see image 21). Focusing on the low-lying areas of the site. It was evident that the height of the berm was sufficient to contain stormwater on the site (see images 24, 27, and 31) and there was no evidence of any petroleum product above the berm in the vegetation (see image 29, 30, 33, 34) or in the Grand Calumet (see image 26, 35). Also in the low lying area, the facility has a dry hydrant (see image 29 and 30) which is a non-pressurized permanent pipe system installed to allow the withdrawal of water from the Grand Calumet River to provide a water source for fire suppression close to potential areas of concern. Additionally, while the facility was inspected following a rain event, there was no evidence of stormwater coming into contact with the site and leaving the site without pretreatment. Photos and/or Videos: were taken during the inspection. See attachment A Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Spill Notification Forms From 2016 to Present 2. Oil Water Skimmer Water Sample Test Results from 3/16/2016 to 5/12/2021 CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Facility staff indicated that CBI was collected during the inspection. Facility staff indicated that CBI was not collected during the inspection Requested documents: Facility Spill Prevention, Control, and Countermeasure Plan (SPCC Plan) [Received 5/28/2021] Compliance Assistance: It is recommended that the site conditions around the inlet identified in image 16 be checked to confirm they are to the correct gradient to keep water gravity flowing away from the property line of the site. Page 4 of 1 Areas of Concern: None SIGNATURES Report Date is date of Section Chief signature. X JASON HEWITT Report Author Digitally signed by JASON HEWITT Date: 2021.07.06 10:13:33 -05'00' X MOLLY SMITH Section Chief Digitally signed by MOLLY SMITH Date: 2021.07.09 12:51:59 -05'00' Page 5 of 1 Facility Name: Calumet Specialty Products Partners, L.P. Facility Location: 14000 Mackinaw Avenue, Burnham, Illinois 60633 Date of Inspection: May 28, 2021 APPENDICES AND ATTACHMENTS 1. Attachment A - Photo Log 2. Attachment B - Approximate Photo Locations 3. Attachment C - Facility Drainage Diagram Appendices Page 1 of 1 Calumet Specialty Products Partners, L.P. Burnham, IL EPA Inspection May 28, 2021 All photos taken by Jason Hewitt, Environmental Engineer, U.S. EPA Camera: Pentax Optio WG-1 GPS 1: IMGP0001 Description: Surge Wall Location: See 1 on Attachment B Camera Direction: East Date/Time: May 28, 2021 Page 1 Calumet Specialty Products Burnham Terminal May 28, 2021 2: IMGP0002 Description: Catch Basin Location: See 2-4 on Attachment B Camera Direction: North Date/Time: May 28, 2021 3: IMGP0003 Description: Catch Basin South of Four Tanks Location: See 2-4 on Attachment B Camera Direction: North Date/Time: May 28, 2021 Page 2 Calumet Specialty Products Burnham Terminal May 28, 2021 4: IMGP0004 Description: Hose and Bucket Below Tank Truck Location: See 2-4 on Attachment B Camera Direction: South Date/Time: May 28, 2021 5: IMGP0005 Description: Catch Basin Location: See 5-6 on Attachment B Camera Direction: East Date/Time: May 28, 2021 Page 3 Calumet Specialty Products Burnham Terminal May 28, 2021 6: IMGP0006 Description: Catch Basin Location: See 5-6 on Attachment B Camera Direction: East Date/Time: May 28, 2021 7: IMGP0007 Description: Product Transfer Pumps Location: See 7-8 on Attachment B Camera Direction: Northeast Date/Time: May 28, 2021 Page 4 Calumet Specialty Products Burnham Terminal May 28, 2021 8: IMGP0008 Description: Catch Basin Near Pump Location: See 7-8 on Attachment B Camera Direction: North Date/Time: May 28, 2021 9: IMGP0009 Description: Drip Pan Location: See 9-11 on Attachment B Camera Direction: East Date/Time: May 28, 2021 Page 5 Calumet Specialty Products Burnham Terminal May 28, 2021 10: IMGP0010 Description: Tanks Location: See 9-11 on Attachment B Camera Direction: West Date/Time: May 28, 2021 11: IMGP0011 Description: Catch Basin Location: See 9-11 on Attachment B Camera Direction: West Date/Time: May 28, 2021 Page 6 Calumet Specialty Products Burnham Terminal May 28, 2021 12: IMGP0012 Description: Plant Pump House Location: See 12 on Attachment B Camera Direction: South Date/Time: May 28, 2021 13: IMGP0013 Description: Inside Storage Building North end of Site Location: See 13 on Attachment B Camera Direction: East Date/Time: May 28, 2021 Page 7 Calumet Specialty Products Burnham Terminal May 28, 2021 14: IMGP0014 Description: Truck over Trench Drain Location: See 14-16 on Attachment B Camera Direction: West Date/Time: May 28, 2021 15: IMGP0015 Description: Catch Basin West of Truck Location: See 14-16 on Attachment B Camera Direction: West Date/Time: May 28, 2021 Page 8 Calumet Specialty Products Burnham Terminal May 28, 2021 16: IMGP0016 Description: Catch Basin and Tank Location: See 14-16 on Attachment B Camera Direction: East Date/Time: May 28, 2021 17: IMGP0017 Description: Catch Basin Location: See 17 on Attachment B Camera Direction: West Date/Time: May 28, 2021 Page 9 Calumet Specialty Products Burnham Terminal May 28, 2021 18: IMGP0018 Description: Pump Room with Progressive Cavity Pump Location: See 18-20 on Attachment B Camera Direction: Date/Time: May 28, 2021 19: IMGP0019 Description: Pump Room with Progressive Cavity Pump Location: See 18-20 on Attachment B Camera Direction: Date/Time: May 28, 2021 Page 10 Calumet Specialty Products Burnham Terminal May 28, 2021 20: IMGP0020 Description: Pump Room with Progressive Cavity Pump Location: See 18-20 on Attachment B Camera Direction: Date/Time: May 28, 2021 21: IMGP0021 Description: Oil/Water Seperator, Flow to POTW Location: See 21 on Attachment B Camera Direction: South Date/Time: May 28, 2021 Page 11 Calumet Specialty Products Burnham Terminal May 28, 2021 22: IMGP0022 Description: Emergency Boom, Site Berm Location: See 22 on Attachment B Camera Direction: South Date/Time: May 28, 2021 23: IMGP0023 Description: Offsite Manhole where Metropolitan Water Recclamaition Disctrict Samples Location: See 23 on Attachment B Camera Direction: North Date/Time: May 28, 2021 Page 12 Calumet Specialty Products Burnham Terminal May 28, 2021 24: IMGP0024 Description: Berm and Standing Water on Low End of Site Location: See 24 on Attachment B Camera Direction: South Date/Time: May 28, 2021 25: IMGP0025 Description: Catch Basin Location: See 25 on Attachment B Camera Direction: West Date/Time: May 28, 2021 Page 13 Calumet Specialty Products Burnham Terminal May 28, 2021 26: IMGP0026 Description: Grand Calumet Directly Adjacent to Site Location: See 26-28 on Attachment B Camera Direction: Southwest Date/Time: May 28, 2021 27: IMGP0027 Description: Low End of Site Berm Location: See 26-28 on Attachment B Camera Direction: South Date/Time: May 28, 2021 Page 14 Calumet Specialty Products Burnham Terminal May 28, 2021 28: IMGP0028 Description: Catch Basin with Oil Sheen Location: See 26-28 on Attachment B Camera Direction: South Date/Time: May 28, 2021 29: IMGP0029 Description: Dry Hydrant on Berm Location: See 29-35 on Attachment B Camera Direction: Southwest Date/Time: May 28, 2021 Page 15 Calumet Specialty Products Burnham Terminal May 28, 2021 30: IMGP0030 Description: Dry Hydrant on Berm Location: See 29-35 on Attachment B Camera Direction: Southwest Date/Time: May 28, 2021 31: IMGP0031 Description: Standing water by Berm on Road Location: See 29-35 on Attachment B Camera Direction: West Date/Time: May 28, 2021 Page 16 Calumet Specialty Products Burnham Terminal May 28, 2021 32: IMGP0032 Description: Catch Basin Inlet in Standing Water Location: See 29-35 on Attachment B Camera Direction: North Date/Time: May 28, 2021 33: IMGP0033 Description: Dense Vegetation Along Top of Berm Location: See 29-35 on Attachment B Camera Direction: North Date/Time: May 28, 2021 Page 17 Calumet Specialty Products Burnham Terminal May 28, 2021 34: IMGP0034 Description: Top of Berm Location: See 29-35 on Attachment B Camera Direction: West Date/Time: May 28, 2021 35: IMGP0035 Description: Grand Calumet Off Site Entry Location: See 29-35 on Attachment B Camera Direction: West Date/Time: May 28, 2021 Page 18 Calumet Specialty Products Burnham Terminal May 28, 2021 FIGURE 3 - SITE PLAN Spill Preven on Control and Countermeasure Plan Calumet Specialty Products Partners, L.P. July 2016 29-35 26-28 24 25 22 21 23 18-20 2-4 1 5-6 7-8 9-11 17 14-16 13 12 NOTE: DRAWING NOT TO SCALE 45 FIGURE 5 - FACILITY DRAINAGE DIAGRAM Spill Preven on Control and Countermeasure Plan Calumet Specialty Products Partners, L.P. July 2016 NOTE: DRAWING NOT TO SCALE 47