Document jzM3jv3oM0oYEL5JMR1Jk7Yy

f EPA REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Mailing Address (If different) June 6, 2024, 10:00 a.m. (EST) Announced: No June 6, 2024, 01:20 p.m. (EST) Access: Granted by City of Toledo Dry and Sunny. It rained on June 5th. Water Clean Water Act, National Pollutant Discharge Elimination System (NPDES) permit program Industrial Stormwater Inspection (ISI) Omni Polymers 1925 Nebraska Toledo, Ohio 43607 Lucas Omni Polymers Intl Corp, c/o Joe LaRosa, 149 Braebrook Drive, Whitby Ontario, Canada L1R 0M9 Joe@ueservice.ca; joe@opolyusa.com FRS ID Permit Number(s) (If Applicable)/identifier SIC and/or NAICS OHU000054 Possibly 5093 Lead Inspector: WILLIAM William Jones JONES Digitally signed by WILLIAM JONES Date: 2024.07.03 08:40:39 -05'00' EPA REGION 5 Supervisor Review: Digitally signed by Ryan Ryan Bahr Date: 2024.07.03 Bahr Ryan Bahr 15:59:23 -05'00' EPA REGION 5 Jones.William@epa.gov (312) 886-6058 Bahr.Ryan@epa.gov SECTION I - INTRODUCTION Site Entry and Inspection Objectives EPA Region 5 Lead Inspector, William Jones, arrived at Omni Polymers (the "Site" or "Facility"), located at 1925 Nebraska Ave, Toledo, Ohio 43607, at 10:00 a.m. (Eastern time) on June 6, 2024, for an unannounced inspection. EPA Region 5 Lead Inspector wore his credentials. The City of Toledo provided access to the facility's 1 of 48 Omni Polymers Inspection Date: f 6-6-2024 site. There were no employees of Omni Polymers present. This Region 5 EPA inspection to investigate compliance is authorized by Clean Water Act (CWA) Section 308 and implementing regulations. This report is based on information supplied by a tenant of Omni Polymers and direct observations made by EPA Region 5 inspectors. In addition, information gathered prior to or after the Inspection from a review of US Environmental Protection Agency (EPA), state, and/or public records may be included in this report. We were not able to go through the building to inspect all of it for interior drains or pretreatment requirements due to safety concerns. There was a strong chemical odor present near the building that was coming from the inside of the building. The fire department cautioned against entering the building. Attendees Organization Attendee Name Title EPA REGION 5 EPA Region 5 Ohio EPA City of Toledo City of Toledo City of Toledo City of Toledo City of Toledo City of Toledo City of Toledo Tenant William Jones Andi Hodaj Brittany Brockmann Michelle Hughes Regina Collins Christian Jackowski Lashana Weeks Timothy Clapp Ryan Grant Anthony Bernal Bill Roth Lead Inspector Environmental Engineer Environmental Specialist II Chief of Emergency Response Chief, Water Resources Senior Environmental Specialist Deputy Chief Fire Inspector Fire Safety Inspector Tenant/maintenance Facility/Site Description EPA REGION 5 lead inspector confirmed the following facility information: The facility does not have an industrial storm water permit. The facility appears to be recyling plastic, and pressure-testing containers for reuse. Facility/Site Information Location(s) Location/Area/Sub-area Description East side of Main building by Bay door View inside building Green trash container and trailer Trash and storm catch basin Manhole #1 Manhole by south fence line 2 of 48 Omni Polymers Inspection Date: f 6-6-2024 Manhole #2 Container area Large storage building on SE side of main building Bay door on south center side of building Storm sewer manhole Northwest of main building Inside storm sewer manhole south of Omni Polymers Outfall into Swan Creek Manhole along south side of building Container/small shed area on south side of building Area where alcohol is stored View inside building and area just outside of building View inside manhole Manhole is located along North Fearing Blvd This is the former outfall for CSO #124 SECTION II - OBSERVATIONS Location: East side of Main Building by Bay Door Observation #: WJ1-OB-001 Date: June 6, 2024 Weather: Sunny Intermediate Bulk Storage Containers (IBC) can be seen inside the building through the bay door. A trench drain is at the entrance to the door. Photos 1 to 2 Location: Green Trash Container and Trailer Observation #: WJ1-OB-002 Date: June 6, 2024 Weather: Sunny The trash can is overflowing and trash bags are on the ground. There is a storm drain inlet nearby under a trailer. On top of the trailer is a fuel container with liquid inside of it. There is staining on the ground below where the fuel container is. Photos 3 to 6 Location: Manhole #1 Observation #: WJ1-OB-003 Date: June 6, 2024 Weather: Sunny Inside a manhole located in the southern end of the site near the fence there are multiple pipes connecting into the manhole. One white pipe and three darker pipes connect into the manhole here. The white pipe appears to be coming from a North-easterly direction. The darker pipes appear to go in a South, North and West Direction. Photo 7 Location: Manhole #2 3 of 48 Omni Polymers Inspection Date: f 6-6-2024 Observation #: WJ1-OB-004 Date: June 6, 2024 Weather: Sunny The inside of manhole #2 located on the south-east side of the building. Liquid appears to have filled it to the top of the manhole with little bits of what appears to be floating plastic on top of the liquid. A rope and what appears to be a black electrical cord stretch down into the liquid in the manhole. Photo 8 Location: Container area Observation #: WJ1-OB-005 Date: June 6, 2024 Weather: Sunny Photograph 9. Plastic storage container with drain at bottom over storm drain inlet. This is just south of the building near the trash compactor. Photographs 10-11 show containers outside the facility labeled sulfuric acid. It is unknown if the containers are empty. Photographs 11-12 show a small storage building. In front of the building is an inlet to a manhole that water can flow through. Photograph 12 shows Intermediate IBC stored in the building shown in photograph 11. The white IBCs have liquid in them. The blue tank appears to be a fuel tank. The building does not have a berm to contain any spills. Photograph 13 shows more IBC. Photographs 14-16 show a storage barn with IBCs inside. Photographs 17-18 show an area near the storage barn where small pieces of plastic can be seen on the ground. Photographs 19-22 show an area where alcohol is stored. Photographs 23-26 and 29-30 show the inside of the facility by the bay door that faces south, on the south end of the facility. Two interior drains are in the area shown in photographs 24 and 30. Mr. Bill Roth stated that the water level rises in the two drains during a rain, and that he believes they are connected to the manhole in photograph 8. Photographs 26, 27 and 28 show a storm drain catch basin just outside of the south bay door. Bits of plastic can be seen in the catch basin. Photos 9 to 30 Location: Storm sewer manhole to the northwest of the main building Observation #: WJ1-OB-006 Date: June 6, 2024 Weather: Sunny Storm water manhole to the Northwest of the main building along Nebraska Avenue. Photos 31 to 32 4 of 48 Omni Polymers Inspection Date: f Location: Inside storm sewer manhole south of Omni Polymers building Observation #: WJ1-OB-007 Date: June 6, 2024 Weather: Sunny Water was flowing through the storm sewer. Photos 33 to 34 6-6-2024 Location: Outfall into Swan Creek Observation #: WJ1-OB-008 Date: June 6, 2024 Weather: Sunny Photographs 35-37 show the outfall and a piece of plastic near the outfall. Photos 35 to 37 SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: Facility Map Ref #: WJ1-RR-001 Reviewed By: William Jones Facility staff were not available to provide records. AOC: No Reviewed Date: November 2, 2023 SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted by USEPA using approved test methods. SECTION V - AREAS OF CONCERN Clean Water Act Section 301 (a) provides that "Except as in compliance with this section and sections...402 of this Act, the discharge of any pollutant by any person shall be unlawful." The facility does not have a storm water discharge permit. The facility has pollutants present outside of the building on the ground and in storm water catch basins. The facility has a catch basin on the south end of its site that has a pipe connected into it that leads to the south, in the direction of Swan Creek. Plastic was observed near the storm sewer outfall into Swan Creek. The facility appears to have interior drains near the south bay door that are tied into the manhole shown in photograph 8. 5 of 48 Omni Polymers Inspection Date: f 6-6-2024 SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA REGION 5 Lead Inspector was unable to hold a closing conference with the facility due to a facility representative not being on site. SECTION VII - LIST OF APPENDICES 1. Photo Log 6 of 48 Omni Polymers Inspection Date: APPENDIX 1: PHOTO LOG (times below are in eastern time) 6-6-2024 7 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 1. View inside Omni Polymers building IMGP0033.JPG June 6, 2024/10:27 a.m. No PII Photographer: William Jones East Side of Omni Polymers building looking west into the building showing a storage area Camera Direction: Westerly 8 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 2. View inside of Omni Polymers Building. Same as photo 1. June 6, 2024/10:27 a.m. No PII East Side of Omni Polymers building looking west into the building showing a storage area Camera Direction: Westerly IMGP0034.JPG Photographer: William Jones 9 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 3. Trash container with overflowing trash June 6, 2024/10:46 a.m. No PII South-East side of site Camera Direction: Southerly IMGP0035.JPG Photographer: William Jones 10 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 4. Trash container with overflowing trash June 6, 2024/10:46 a.m. No PII South-east side of site. This container is also shown in photograph 3. Camera Direction: South-west IMGP0036.JPG Photographer: William Jones 11 of 48 Omni Polymers Inspection Date: 6-6-2024 Photo 5. Trailer with storm drain inlet under wheel. IMGP0037.JPG June 6, 2024/10:48 a.m. No PII A gas can with liquid inside of it is on the trailer. Staining can be seen on the ground under the front of the trailer. The trailer is also shown in photograph 4. Camera Direction: Looking southerly Photographer: William Jones 12 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 6. View inside of the manhole lid shown in photograph 5. June 6, 2024/10:48 a.m. No PII IMGP0038.JPG Photographer: William Jones The inside of the manhole shows a white pipe on the left leading into the structure. The pipe is brown at the bottom of the white pipe. Camera Direction: View looking down 13 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 7. Inside manhole #1. IMGP0039.JPG June 6, 2024/11:02 a.m. No PII Photographer: William Jones View of the inside of a manhole located in the southern end of the site near the fence line and marked in the attached general sketch as manhole #1, where multiple pipes are connecting into the manhole. One white pipe and three darker pipes connect into the manhole here. The white pipe appears to be coming from a North-easterly direction and has brown material in the bottom of it. The darker pipes appear to go in a South, North and West Direction. Camera Direction: View looking down 14 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 8. Inside manhole #2 June 6, 2024/11:06 a.m. No PII View of the inside of manhole located on the south-east side of the building). Liquid appears to have filled it to the top of the manhole with little bits of what appears to be floating plastic on top of the liquid. A rope and what appears to be a black electrical cord stretch down into the liquid in the manhole. Camera Direction: View looking down IMGP0040.JPG Photographer: William Jones 15 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 9. Plastic storage container with drain at bottom over storm drain inlet. This is just south of the building near the trash compactor. June 6, 2024/11:12 a.m. No PII IMGP0041.JPG Photographer: William Jones Camera Direction: View looking southwest 16 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 10. Drums stored outside. Two of the drums are marked Sulfuric Acid and the drums in the photo are also marked corrosive. June 6, 2024/11:13 a.m. No PII Near the track compactor just south of the building Camera Direction: View looking south-westerly IMGP0042.JPG Photographer: William Jones 17 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 11. A stack of containers that are also shown in photograph 10. June 6, 2024/11:18 a.m. No PII The containers are next to a small storage building. Shown in front of the building is an inlet to a manhole that water can flow through. IMGP0043.JPG Photographer: William Jones 18 of 48 Omni Polymers Inspection Date: Camera Direction: View looking south 6-6-2024 19 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 12. Intermediate Bulk Containers (IBC) stored in the building shown in photograph 11. The white IBC have liquid in them. The blue tank appears to be a fuel tank. The building does not have a berm to contain any spills. June 6, 2024/11:28 a.m. No PII Inside the building shown in photograph 11. Camera Direction: Looking south IMGP0044.JPG Photographer: William Jones [Geographic Coordinates] 20 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 13. IBCs stored outside next to the building shown in photograph 11. June 6, 2024/11:28 a.m. No PII South of the main building Camera Direction: View looking South-west IMGP0045.JPG Photographer: William Jones 21 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 14. IBC with dark liquid dried on outside of it. IMGP0046.JPG The container is half filled with a dark liquid. June 6, 2024/11:30 a.m. No PII Photographer: William Jones South of main building to the west of the building shown in photograph 11. Camera Direction: View looking south-west 22 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 15. Building with IBCs inside of it. IMGP0047JPG June 6, 2024/11:31 a.m. No PII Photographer: William Jones Building south of the main building. This building is also shown in photograph 14. 23 of 48 Omni Polymers Inspection Date: Camera Direction: View looking south 6-6-2024 24 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 16. Close up of IBC shown in phtograph 15. The container contained a dark liquid. June 6, 2024/11:31 a.m. No PII IMGP0048.JPG Photographer: William Jones Camera Direction: View looking south 25 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 17. Former dumping area southwest of the main building June 6, 2024/11:38 a.m. No PII Also, see photograph 18. Camera Direction: View looking south IMGP0049.JPG Photographer: William Jones 26 of 48 Omni Polymers Inspection Date: 6-6-2024 Photo 18. Close up of area shown in photograph 17 showing what appears to be bits of plastic among the rocks/dirt June 6, 2024/11:38 a.m. No PII IMGP0050.JPG Photographer: William Jones Camera Direction: View looking down 27 of 48 Omni Polymers Inspection Date: 6-6-2024 Photo 19. Inside of the large shed south of the main facility that is used for storing alcohol. This container is also shown in photographs 20 and 21. June 6, 2024/11:42 a.m. No PII IMGP0051.JPG Photographer: William Jones Camera Direction: View looking south-east 28 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 20. Photo inside of large shed where alcohol is IMGP0052.JPG stored June 6, 2024/11:42 a.m. No PII Photographer: William Jones Camera Direction: View looking east 29 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 21. View inside of large shed showing container shown in photograph 19. June 6, 2024/11:42 a.m. No PII Camera Direction: View looking south IMGP0053.JPG Photographer: William Jones 30 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 22. Photo inside of large shed where alcohol is IMGP0054.JPG stored June 6, 2024/11:45 a.m. No PII Photographer: William Jones Camera Direction: View looking west 31 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 23. View inside of building from Bay door on south side of building looking to the right. June 6, 2024/11:57 a.m. No PII IMGP0055.JPG Photographer: William Jones Camera Direction: View looking south-easterly 32 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 24. View inside of building from Bay door on south side of building looking straight in. June 6, 2024/11:57 a.m. No PII IMGP0056.JPG Photographer: William Jones Camera Direction: View looking north 33 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 25. View inside of building from Bay door on south side of building looking to the left. June 6, 2024/11:57 a.m. No PII IMGP0057.JPG Photographer: William Jones Camera Direction: View looking north-west 34 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 26. View inside of building from Bay door on south side of building looking straight into the building. A storm drain inlet is shown in the bottom of the photo that is just outside of the doorway. June 6, 2024/11:57 a.m. No PII This area is also shown in photographs 24 and 28 Camera Direction: View looking north and down IMGP0058.JPG Photographer: William Jones 35 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 27. View inside of storm drain inlet shown in IMGP0059.JPG photograph 26. Bits of material can bee seen in the photos that appear to be bits of plastic based on the shape and lighter color. June 6, 2024/11:58 a.m. No PII Photographer: William Jones Close up of manhole grate shown in phtographs 26 and 28. Camera Direction: View looking down 36 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 28. Close up of storm sewer inlet shown in photographs 26 and 27. June 6, 2024/11:58 a.m. No PII IMGP0060.JPG Photographer: William Jones Camera Direction: View looking down 37 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 29. View from inside of the bay door of the area shown in photograph 23. June 6, 2024/12:01 p.m. No PII IMGP0061.JPG Photographer: William Jones Camera Direction: View looking south-east 38 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 30. View from inside of the bay door of the area shown in photograph 23. June 6, 2024/12:02 p.m. No PII An opening into the drain system is in the floor just to the right of the center of the photograph. Camera Direction: View looking south-east IMGP0062.JPG Photographer: William Jones 39 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 31. View inside of storm manhole at the northwest corner of the main building near Nebraska Ave June 6, 2024/12:23 p.m. No PII IMGP0063.JPG Photographer: William Jones Camera Direction: View looking down 40 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 32. View inside of storm manhole to the Northwest corner of the main building near Nebraska Ave June 6, 2024/12:24 p.m. No PII IMGP0064.JPG Photographer: William Jones Camera Direction: View looking down 41 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 33. View inside of storm manhole receiving downpipe of storm sewers connected to sound end of Omni Polymers. June 6, 2024/ 1:00 p.m. No PII IMGP065.JPG Photographer: William Jones Camera Direction: View looking down 42 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 34. Top section of manhole with green paint. The manhole is also shown in photograph 33. June 6, 2024/1:02 p.m. No PII This is located along the north side of North Fearing Blvd south of the Omni Polymers facility between the railroad bridges Camera Direction: View looking northerly IMGP0066.JPG Photographer: William Jones 43 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 35. Storm water outfall into Swan Creek formerly known as CSO 124. A net and absorbent boom is in front of the outfall. June 6, 2024/1:11 p.m. No PII The outfall is near Highland Park and Emery street in Toledo. IMGP0067.JPG Photographer: William Jones 44 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 36. Storm water outfall into Swan Creek formerly known as CSO 124. This is also shown in photograph 35. A white piece of plastic was observed near the bottom of the photograph. June 6, 2024/1:14 p.m. No PII This outfall is near Highland Park and Emery Street in Toledo. IMGP0068.JPG Photographer: William Jones 45 of 48 Omni Polymers Inspection Date: 6-6-2024 Photograph 37. A close up of the white piece of plastic shown in photograph 36. June 6, 2024/1:14 p.m. No PII This plastic is near the outfall shown in photograph 36. View looking down IMGP0069.JPG Photographer: William Jones 46 of 48 Omni Polymers Inspection Date: 6-6-2024 47 of 48 Omni Polymers Inspection Date: 6-6-2024 48 of 48