Document gDg1xXpa1mXmK9orNx7zGXpaV

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1600 John F Kennedy Boulevard Four Penn Center Philadelphia, Pennsylvania 19103 Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Facility Name: Permittee(s): Facility Operator: Facility Address: Lat/Long: County/Parish: Permit Number: NAICS & SIC Codes: Unique Project #: Clean Water Act Compliance Inspection Report 08/25/2022 National Pollutant Discharge Elimination System (NPDES) Pretreatment Industrial User Inspection Pennex Aluminum Pennex Aluminum Pennex Aluminum 50 Community Street, Wellsville, PA 17365 40.0524, -76.93907 York PAP132000 423510/5051 3E22WN033A Facility Representative(s): Point of Contact Nathan Foor Training Coordinator Pennex Aluminum Phone: 717-432-9647 Email: NFoor@pennexaluminum.com EPA Inspectors: Aaron Thomson - EPA Inspector (3ED33) Phone: 215-814-2116 Email: Thomson.aaron@epa.gov Report Preparer Signature/Date Supervisor Signature/Date Aaron Thomson, Inspector 1600 John F. Kennedy Boulevard (3ED33) Philadelphia, PA 19103 JESSICA Digitally signed by JESSICA DUFFY DUFFY Date: 2023.06.06 07:48:21 -04'00' Jessica Duffy, Acting NPDES 2 Section Chief 1600 John F. Kennedy Boulevard Philadelphia, PA 19103 Date Date Pennex Aluminum Pretreatment Industrial User Inspection 08/25/2022 Table of Contents I. Introduction ......................................................................................................................................................... 3 A. Inspection Opening Conference ............................................................................................................... 3 B. Weather and Precipitation Conditions...................................................................................................... 3 II. Facility Activity/Walkthrough ........................................................................................................................... 3 III. Observations ..................................................................................................................................................... 4 IV. Records Review .............................................................................................................................................. 10 V. Closing Conference.......................................................................................................................................... 10 VI. List of Attachments......................................................................................................................................... 10 Unique Project #: 3E22WN033A Page 2 of 10 I. Introduction Pennex Aluminum Pretreatment Industrial User Inspection 08/25/2022 On August 15, 2022, Aaron Thomson (hereinafter, or the ) an inspector Region III conducted an on-site inspection of the Pennex Aluminum facility (hereinafter, Pennex , or facility pretreatment program. The facility is an aluminum extrusion plant, which receives raw aluminum, melts it, casts it into logs and then extrudes it, creating a finished product. The facility is located at 50 Community Street, Wellsville, PA 17365. The purpose CWA ) and the applicable Federal Pretreatment Regulations. The Pennsylvania Department of Environmental Protection was invited to the inspection but chose not to attend. No controlling document or permit was provided by the Facility as of writing this report. A. Inspection Opening Conference The EPA Inspector arrived at the facility at approximately 11:00 AM for the on-site inspection. Inspector Thomson met with the following facility representatives: Name Aaron Thomson Nathan Foor Gary Yeager Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region III Inspectors and Contractors EPA - Philadelphia 215-814-2116 Thomson.aaron@epa.gov Site/Facility Representatives Pennex Aluminum 717-432-9647 NFoor@pennexaluminum.com Pennex Aluminum 717-432-9647 None provided Inspector Thomson displayed their credentials to Mr. Gary Yeager , Maintenance Manager at Pennex and Mr. Nathan Foor Foor at the outset of the inspection, and explained the purpose of the inspection was to observe compliance with the Federal Pretreatment Regulations. The EPA Inspector informed Mr. Yeager that any information that the Facility inspection and it would be B. Weather and Precipitation Conditions During the inspection, the weather was sunny with a high of 90 degrees Fahrenheit. II. Facility Activity/Walkthrough The Pennex Aluminum facility is an aluminum casting and extrusion manufacturing plant. The facility receives raw aluminum scrap which are melted and cast into cylinders of aluminum which are then extruded. The the POTW conveyance system includes backwash water generated from the water-cooling system process used on metal during the extrusion process, blowdown from non-contact cooling water, and sanitary wastewater. According to Mr. Yeager, the wastewater (backwash) generated during the extrusion process is collected in an equalization storage tank where it is monitored for pH, Oxygen-Reduction Potential (ORP) and conductivity. Backwash both leaving and entering the EQ tank is filtered to remove physical media. When the conductivity of the water in the EQ exceeds desirable process limits, the pH of the wastewater is measured with a probe to ensure it is still within permitted discharge limits, if necessary the pH is adjusted with neutralization, and then moved to a reservoir tank to be discharged to the POTW conveyance system. Mr. Yeager stated the probe is calibrated Unique Project #: 3E22WN033A Page 3 of 10 Pennex Aluminum Pretreatment Industrial User Inspection 08/25/2022 not been supplied by the Facility as of writing this report. Mr. Yeager stated that the water is discharged in batches, automatically, approximately once per day shift. According to Mr. Yeager, the facility calibrates pH, ORP and conductivity daily, and Guardian (no location/further information given) calibrates their systems monthly. Mr. Yeager stated that the monitoring system runs 24/7 and will notify their phones via email if any issues occur. Inspector Thomson requested information or documents relating to the categorical industrial user status of the facility, as of writing this report and as of writing this report, the requested documents have not been provided by the Facility. A Categorical Industrial User (CIU) is subject to the Federal Pretreatment Regulations 40 CFR Part 403. Categorical Industrial User Regulations 40 CFR Part 433.15 details the pretreatment standards of an existing aluminium forming point source, extrusion subcategory. The facility discharges to the Wellsville publicly owned treatment works (POTW). Because the facility discharges into a POTW without an approved pretreatment program, EPA is designated as the Control Authority per 40 CFR Part 403.3(f), and as such is the authority for inspections under section 308 of the CWA. After the opening conference, Mr. Yeager led a tour of the processes that contribute to the wastewater discharge to the sewage system. monitoring probe console (Attachment 1 Photographs 1 and 2). Next, Inspector Thomson was led to the filtration system, a tank with granular activated carbon (GAC) filter media, (Attachment 1 Photographs 3 and 4), which was adjacent to the equalization tank (Attachment 1 Photograph 5). (Attachment 1 Photographs 6 and 7). tank (reservoir tank holding post- treatment wastewater) point (Attachment 1 Photograph 8) and leads the . sampling station, where expired buffers were observed (Attachment 1 Photographs 9, 10 and 11). Finally, ed wastewater (Attachment 1 Photograph 12) including a flow meter and shutoff valve. This concluded the site tour. III. Observations A checklist was utilized during the review and is provided below. The checklist is divided into sections, with Observations listed under each section. Photographs were taken during the inspection by Inspector Aaron Thomson, and are provided in Attachment 1. Not all photographs taken during the inspection are included in this report. Visual Observations pertaining to each section are listed at the end of each section. Section 1. General Information General Description of Processes and Products Are there any alternates to effluent monitoring conducted? (e.g., TTO/TOMP, Waiver requirements?) Describe in Yes No N/A Comments aluminum casting/extrusion No info provided Unique Project #: 3E22WN033A Page 4 of 10 Provide production rates for all processes subject to production based standards and include: 1) Process 2) production rate used for calculating limits 3) production rate for last 12 months Any anticipated changes in processes or production rates? List the production rate listed on the approval letter Shift information, list 1) Shift # 2) No. of Employees 3) Hours 4) Work Days Is production seasonal? If yes, describe List all visual observations pertaining to this section Pennex Aluminum Pretreatment Industrial User Inspection 08/25/2022 No info provided 4 shifts/day runs 24/7, discharges approximately once per day shift Section 2. Categorical Industry Categorical Industry? Category(s): Subcategory(s): Regulatory New Source Date: New source? List of categorical processes List of other operations producing wastewater List all visual observations pertaining to this section Yes No N/A Comments No info from facility provided 40 CFR Part 433.15, Subpart A: Metal Finishing. wastewater that is discharged) Rinse/wash Information or documentation regarding categorical status was requested by Inspector Thomson at the time of the inspection and as of writing this report the Facility has supplied no further documents or information Section 3. Characterization of Wastewater Discharges (CFR 433.15) Yes No N/A Comments Describe the time of day discharge to sewer occurs Are discharges seasonal (if yes, describe) Batch Discharge, once per day shift Unique Project #: 3E22WN033A Page 5 of 10 Pennex Aluminum Pretreatment Industrial User Inspection 08/25/2022 Attach a block flow diagram of manufacturing process in the Facility Activity section of the inspection report, including: chemical storage area, and wastewater generated. Identify all regulated, unregulated and dillution wastewater discharges. Include sample location, discharge flow rates and method of disposal*. Note any recent changes. *disposal method CD - Continuous discharge to sanitary ND - Not discharged or disposed BD - Batch discharge to sanitary sewer HH - Hauled as hazardous waste OD - Other disposal - not to sanitary sewer HW - Hauled as nonhazardous waste List all visual observations pertaining to this section Section 4. Pretreatment Facility Pretreatment installed? Briefly describe treatment processes and operation. Describe sludge storage and disposal method Describe appearance of effluent at time of inspection. List all visual observations pertaining to this section Yes No N/A Comments Consists of filtering physical media, measuring/neutralizing pH Water is filtered through granular activated carbon. Filtered water is measured for pH, conductivity and ORP and, if necessary, neutralized to bring pH with permitted parameters before being discharged to the POTW n/a n/a monitoring to verify that no further treatment is necessary Section 5. Self Monitoring Yes No N/A Comments Does facility have a sampling plan or protocol including use of 40 C.F.R. Part 136 techniques (obtain copy)? Not Provided Is sampling location (identified on block flow diagram) the same as in control mechanism? If no, explain. Not Provided Is this sampling location permanently identified by a sign, painted number, or other means? Is this sampling location shown on the chain of custody form? Unique Project #: 3E22WN033A Not Provided Page 6 of 10 Are any parameters monitored by approved methods more frequently than required at permitted sampling location?. If yes to previous question, are all results submitted to the control authority? Does facility resample and report within 30 days of discovering a violation? Are sampling records maintained on site? Describe for how long. Is flow determined as required by permit? How is flow determined (i.e., estimated or measured)? Is flow measurement appropriate? Is flow measurement device calibrated? Does the facility have an operator's manual for its pH meters? Does the facility do a proper 2-point calibration of its pH meter in accordance with the operator's manual? Is other monitoring equipment (e.g. DO meter) calibrated? Describe how often if yes. Is sampling and analysis done in-house or by contract? If by contract, list company. Is QA/QC program for sampling and analysis adequate? Obtain copy of plan if available. List all visual observations pertaining to this section Pretreatment Pennex Aluminum Industrial User Inspection 08/25/2022 Not Provided Not Provided Not Provided Not Provided Not Provided Measured continuously (meter) Guardian (no info available) 1/month Expired buffers Monthly by Guardian (no info available)/daily calibration by facility Not Provided Not Provided Buffers observed were expired Section 6. Hazardous Waste Management Yes No N/A Comments Is IU aware of RCRA regulations? Does facility generate any hazardous waste? If yes, indicate type of waste, method of management on site and means of disposal on a separate sheet. Describe any spillage problems or any other releases that are observed. Inspector Thomson asked for description of process to remove/haul physical media generated from filtration, no info provided Has facility notified POTW and EPA of any hazardous waste discharges to the sewer? List all visual observations pertaining to this section Section 7. Spill Prevention Yes No N/A Comments Unique Project #: 3E22WN033A Page 7 of 10 Has the facility had any spills or been responsible for slug loads? List dates of events in comments. If yes to previous question, was POTW notified? Does the facility have spill notification procedures posted? Has the facility evaluated its need for a spill prevention plan at least every two years? If yes to previous question, was it determined that they needed one? Does the IU have a spill prevention (SP) plan to address spills to the POTW? If spills occurred- Did the IU follow procedures outlined in the spill plan at the time of spills? If spills occurred- Were procedures effective in containing the spill? Is the facility keeping records of spill events? Have there been any changes in spill procedures recently. Describe if yes. List all visual observations pertaining to this section Pennex Aluminum Pretreatment Industrial User Inspection 08/25/2022 Facility not aware of any spill/slug Not Provided Not Provided Not Provided Section 8. Recordkeeping Review. Yes No N/A Comments Current IU control mechanism (through EPA, not a permit) Not Provided Notices and correspondence with control authority including: a. Self monitoring report transmittals? Not Provided b. BMR if required? Not Provided c. Other? Not Provided Do sampling records include: a. Date of sampling event? Not Provided b. Time of sampling event? Not Provided c. Name of sampling person and affiliation? Not Provided d. Sample collection method? Not Provided e. Method of sample preservation? Not Provided f. Description of sample location? Not Provided g. Name of person conduction analysis? Not Provided h. Date of analysis? Not Provided i. Time of analysis, if applicable (i.e., BOD, Cr?) Not Provided j. Sample analyses method? Not Provided Is type of sample specified in control mechanism? Not Provided Unique Project #: 3E22WN033A Page 8 of 10 Are all parameters monitored at the required frequency? Note any discrepancies in comments. Analytical results? Are all monitoring results sent to the Control Authority? Are copies sent to the POTW? Appropriate production records for production based standards? Documentation of flow rates and volumes? Are records maintained at least 3 years? List all visual observations pertaining to this section Pennex Aluminum Pretreatment Industrial User Inspection 08/25/2022 Not Provided Not Provided Not Provided Not Provided Not Provided Not Provided Not Provided Section 9. EPA Sampling Were samples taken? Describe sampling location, method, and time: List all visual observations pertaining to this section Yes No N/A Comments Section 10. Stormwater Does facility have a stormwater permit? If yes, describe what type of permit along with issuance and expiration dates Does facility have a stormwater pollution prevention plan? Describe any BMPs that the facility is currently implementing. List all visual observations pertaining to this section Yes No N/A Comments According to Mr. Yeager, no stormwater permit is necessary on site Section 11. Current Compliance Status Indicate compliance with: a. effluent limits (indicate in comments the date range reviewed) b. monitoring (indicate in comments the date range reviewed) c. recordkeeping/reporting (indicate in comments the date range and records reviewed) List all visual observations pertaining to this section Yes No N/A Comments Not Provided Not Provided Not Provided Unique Project #: 3E22WN033A Page 9 of 10 Pennex Aluminum Pretreatment Industrial User Inspection 08/25/2022 IV. Records Review As part of the inspection, prior to the inspection via teleconference and during the inspection, Inspector Thomson requested the following documentation be sent via email up to two weeks after the inspection: Control mechanism, 2 years worth of monitoring reports with chain of custody and sample results and slug/spill control plans (Attachment 1, Photograph 13). Additionally, during the inspection, Inspector Thomson asked for information relating to the categorical status, the removal and haulage of waste generated from the filtration system as well as process flow diagrams relating to the pretreatment. No information or documentation was provided by the facility as of writing this report. V. Closing Conference After the facility inspection, the EPA Inspection Team met with the facility representatives for a closing conference. The EPA Inspection Team shared preliminary observations with the facility. The EPA Inspection Team reiterated to the facility representatives that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by EPA upon the additional review of records and documentation. Additional observations may be contained in this inspection report that were not identified at the time of the closing conference after EPA reviewed additional materials following the inspection. The inspection concluded at 1:00 PM VI. List of Attachments Attachment 1. Photo Log Attachment 2. Detailed Facility Report _ ECHO _ US EPA Unique Project #: 3E22WN033A Page 10 of 10