Document Yr7pqjDop5vVxaY2vEV7MRjkD

REGION 5 Enforcement and Compliance Assurance Division Inspection Date: Time: Media: Statute (s)/Program(s): Type of inspection: Access: INSPECTION REPORT May 28, 2025 Inspection Announced: No Entry: 12:45 PM EST Exit: 2:15 PM EST Water Clean Water Act, National Pollutant Discharge Elimination System (NPDES), Industrial CEI - Compliance Evaluation Inspection Granted Permittee Name: Facility or Site Name: Facility/Site Physical Address: (city, state, zip code) County/Parish: Harsco Environmental Harsco Environmental 1344 Bowman Street Mansfield, Ohio 44903 Richland Permit Number: OH0084030 Page 1 of 15 REGION 5 Enforcement and Compliance Assurance Division Persons Participating in Inspection: Title Name Phone Email Present at Present at Opening Closing Conference Conference Physical Scientist, Matthew (312) 886-2405 schulte.matthew@epa.gov Yes Yes EPA Schulte Life Scientist, EPA Megan Bobb (312) 353-6057 bobb.megan@epa.gov Yes Yes Physical Scientist, Sophie Bazan (312) 886-6068 EPA bazan.sophie@epa.gov Yes Yes Site Manger Michael -- Farlow mfarlow@harsco.com Yes Yes Lead Inspector: Matthew Schulte MATTHEW SCHULTE Digitally signed by MATTHEW SCHULTE Date: 2025.07.31 09:28:05 -05'00' Region 5 schulte.matthew@epa.gov (312) 886-2405 Supervisor Review: Molly Smith MOLLY SMITH Region 5 Digitally signed by MOLLY SMITH Date: 2025.07.31 12:01:10 -05'00' smith.molly@epa.gov (312) 353-8773 SECTION I - INTRODUCTION Site Entry and Inspection Objectives Region 5 Lead Inspector, Matthew Schulte, and inspectors Megan Bobb and Sophie Bazan arrived at Harsco Environmental (the "Site" or "Facility"), located at 1344 Bowman Street in Mansfield, Ohio, at 12:45 PM on May 28, 2025, for an announced inspection. Inspectors presented their credentials to Site Manager Michael Farlow and informed the Facility that this was an EPA Region 5 inspection to investigate elements of the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permit program. The inspection was conducted under the authority of the CWA NPDES permit program and Section 308 of the CWA. The table above identifies the attendees that participated in the inspection. This report is based on information supplied by Facility representatives, observations made by the Region 5 inspectors, and records and reports maintained by the permittee and Region 5. These include the following: direct observations made by the Region 5 inspectors, photographs taken by Region 5 inspectors, physical evidence collected by Region 5 inspectors, measurements taken by Region 5 inspectors, verbal or written statements made or supplied by Facility representatives (the permittee) during or subsequent to the on-site Page 2 of 15 Harsco Environmental Inspection Date(s): May 28, 2025 inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the Region 5 inspectors by Facility representatives during or subsequent to the on-site inspection. In addition, information gathered prior to or subsequent to the inspection from a review of U.S. EPA, State, and public records may be included in this report. Facility/Site Description Region 5 Lead Inspector confirmed the following Facility information: The Facility is a scrap metal sorting and recycling yard. The Facility's sole customer is Cleveland-Cliffs Steel Corp: Mansfield Works (CCMW). Along with scrap metal, the Facility will also store carbon, iron ingots, and other alloys onsite for CCMW. All scrap metal onsite originates from other various scrap metal processing yards and the Facility does not purchase residential scrap. On average, the Facility provides 1,400 tons of material to CCMW on a daily basis. The Facility only has one outfall, identified as Outfall 001, which handles all stormwater runoff that occurs onsite. Prior to discharge through Outfall 001, all stormwater gathers in an onsite stormwater holding pond. The Facility has 31 employees and operates 24 hours per day 7 days a week. SECTION II - OBSERVATIONS Observations may not be in sequential order. Unique Identifying No. MS-OB-001 MS-OB-002 Observation During the site tour, inspectors observed a stormwater collection ditch that surrounded the Facility's North and East sides to bring water to the onsite stormwater holding pond. (Photos 5, 6, 8, and 11) During the site tour, Inspectors observed alloys stored onsite for CCMW that were kept in a specific area under coverage, protected from rain. (Photo 7) Area of Concern? No No SECTION III - RECORDS REVIEW Records reviewed may not be in sequential order. No. MS5RR-001 Record Inspectors observed that recent discharge monitoring reports (DMRs) show exceedances for total suspended solids. Are of Concern? Yes SECTION V - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Page 3 of 15 Harsco Environmental Inspection Date(s): May 28, 2025 No. MS-RR-001 Inspectors observed that recent discharge monitoring reports (DMRs) show exceedances for total suspended solids. The Facility is required to meet the effluent standards outlined in their "NPDES Permit OH0084030: Part I, A. - FINAL EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS." SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The Lead Inspector held a closing conference with Facility personnel on May 28, 2025, for the inspection. During the closing conference, the Lead Inspector discussed the observations and Area of Concern identified during the inspection. Observations and the Area of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - LIST OF APPENDICES Appendix 1 - Photo Log [times listed on images are in Central Standard Time. Times listed to left of photo log are in Eastern Standard Time]. Page 4 of 15 REGION 5 Enforcement and Compliance Assurance Division Facility Name & Location: Harsco Environmental 1344 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 1 Time: 1:25 PM Direction Photo Taken: West Photo Description: Site overview from Facility entrance. Photographer: Megan Bobb Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: Harsco_01.JPG Page 5 of 15 Harsco Environmental Inspection Date(s): Facility Name & Location: Harsco Environmental 1344 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 2 Time: 1:31 PM Direction Photo Taken: South Photo Description: Scrap metal pile with some visible rust on some scrap. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: Harsco_02.JPG Page 6 of 15 Harsco Environmental Inspection Date(s): Facility Name & Location: Harsco Environmental 1344 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 3 Time: 1:37 PM Direction Photo Taken: Southwest Photo Description: Slag piles from CCMW used to prevent runoff. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: Harsco_03.JPG Page 7 of 15 Harsco Environmental Inspection Date(s): Facility Name & Location: Harsco Environmental 1344 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 4 Time: 1:40 PM Direction Photo Taken: West Photo Description: End of property on the West end. No scrap piles located in this area. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: Harsco_04.JPG Page 8 of 15 Harsco Environmental Inspection Date(s): Facility Name & Location: Harsco Environmental 1344 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 5 Time: 1:44 PM Direction Photo Taken: North Photo Description: Collection pond pathway in back. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: Harsco_05.JPG Page 9 of 15 Harsco Environmental Inspection Date(s): Facility Name & Location: Harsco Environmental 1344 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 6 Time: 1:44 PM Direction Photo Taken: East Photo Description: Collection pond pathway/ditch bordering Facility. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: Harsco_06.JPG Page 10 of 15 Harsco Environmental Inspection Date(s): Facility Name & Location: Harsco Environmental 1344 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 7 Time: 1:49 PM Direction Photo Taken: North Photo Description: Alloy silos. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: Harsco_07.JPG Page 11 of 15 Harsco Environmental Inspection Date(s): Facility Name & Location: Harsco Environmental 1344 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 8 Time: 1:50 PM Direction Photo Taken: North Photo Description: Ditch connected to holding pond. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: Harsco_08.JPG Page 12 of 15 Harsco Environmental Inspection Date(s): Facility Name & Location: Harsco Environmental 1344 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 9 Time: 1:58 PM Direction Photo Taken: West Photo Description: Inflow from holding ditch connected to storm water pond. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: Harsco_09.JPG Page 13 of 15 Harsco Environmental Inspection Date(s): Facility Name & Location: Harsco Environmental 1344 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 10 Time: 1:58 PM Direction Photo Taken: West Photo Description: Storm water holding pond. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: Harsco_10.JPG Page 14 of 15 Harsco Environmental Inspection Date(s): Facility Name & Location: Harsco Environmental 1344 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 11 Time: 2:04 Direction Photo Taken: South Photo Description: Collection ditch from the road surrounding the Facility and connected to the storm water holding pond. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: Harsco_11.JPG Page 15 of 15