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COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5 Purpose: Clean Water Act National Pollutant Discharge Elimination System (NPDES) Compliance Evaluation Inspection Facility: Ardagh Glass, Inc. 524 East Center Street Dunkirk, Indiana 47336 Dates of Inspection: March 13 - 14, 2024 EPA Inspectors: Val Dooling, Environmental Engineer, (312) 886-7167 Dean Maraldo, Physical Scientist, (312) 353-2098 IDEM Inspector: Mary Armacost, Pretreatment Coordinator Facility Representatives: Teresa Fouch, EHS Manager Ray Ostrowski, Corporate Environmental Engineer Jay King, Facilities Maintenance Supervisor Richard M. Tomicek, VP, Environmental Compliance Report Prepared By: Val Dooling, Environmental Engineer EPA Inspector Signature and Date: Dooling, Digitally signed by Dooling, Valerie Date: 2024.05.02 __V_a__le_r_ie________15_:2_5:_51_-0_5_'00_' _______________________ Approver Name and Title: Ryan J. Bahr, Section 2 Supervisor Water Enforcement and Compliance Assurance Branch Approver Signature and Date: Digitally signed by Bahr, Bahr, Ryan Date: 2024.05.02 Ryan _______________1_6:_09_:0_0 -_05_'0_0'_______________________ TABLE OF CONTENTS I. Introduction .......................................... 1 II. Background .......................................... 1 III. Opening Conference ........................... 1 IV. Facility Discussion .............................. 2 V. Facility Site Visit ................................... 5 VI. Closing Conference ............................. 7 LIST OF APPENDICES Appendix A: Photo Log Appendix B: Aerial image of Ardagh Glass Inc. Dunkirk Facility Appendix C: IDEM Pretreatment Permit INP000201 Part I Appendix D: Chlorides (mg/l) concentration values in combined wastestream Appendix E: City of Dunkirk Violation of Wastewater Discharge Permit Letter Appendix F: Ardagh Glass Response to Dunkirk Wastewater Permit Violation Letter Ardagh Glass CEI Inspection - March 13-14, 2024 I. INTRODUCTION The purpose of the report is to describe, evaluate and document Ardagh Glass, Inc.'s compliance with the Clean Water Act (CWA) and the National Pretreatment Categorical Effluent Guidelines. II. BACKGROUND On March 13-14, 2024, EPA conducted a Clean Water Act Compliance Evaluation Inspection at the Ardagh Glass, Inc. (Ardagh) Facility located at 524 East Center Street in Dunkirk, Indiana, which manufactures commercial glass containers for food and beverage customers. Ardagh is an industrial user of the City of Dunkirk Wastewater Treatment Plant, which holds National Pollutant Discharge Elimination Permit (NPDES) IN0021491. Ardagh also holds NPDES Permit IN0061816 and Indiana Department of Environmental Management (IDEM) Industrial Wastewater Pretreatment Permit INP000201. IDEM Permit INP000201 lists the outfall that discharges combined wastewater to the City of Dunkirk as "Outfall 001"and NPDES Permit IN0061816 lists "Outfall 001" as a different location which is authorized to discharge stormwater, furnace quench water and non-contact cooling water ultimately to Big Lick Creek. To avoid confusion, for the remainder of this inspection and corresponding report, the outfalls listed in Permit IN0061816 are named "Outfall 1" and "Outfall 2" and the combined wastewater discharge point to the City of Dunkirk listed in IDEM Permit INP000201 is named "combined wastewater discharge point". III. OPENING CONFERENCES Inspector Dean Maraldo, IDEM Inspector Mary Armacost and I arrived at Ardagh Facility on March 13, 2024 at 2:15pm and met with Teresa Fouch, EHS Manager. During the opening conference, Ms. Fouch was present in person and Ray Ostrowski, Corporate Environmental Engineer, was present on a speaker phone. I presented my credentials to Ms. Fouch and requested whether any information that would be discussed was considered Confidential Business Information. I explained the purpose and scope of the inspection and then began a discussion of the facility. At 3:30pm, IDEM and EPA Inspections left the facility and agreed to return at 8:00am the following day. On March 14, 2024, Inspectors Maraldo, Armacost and I arrived at Ardagh Glass at 8:05am and met in person with Jay King, Facilities Maintenance Supervisor, and Richard M. Tomicek, VP, Environmental Compliance, as well as Ms. Fouch and Mr. Ostrowski. I also presented my credentials to Messrs. Ostrowski, King, and Tomicek and requested whether any discussions would be considered Confidential Business Information. Ardagh representatives explained that Ardagh's glass making process is universal, but their glass cooling process is proprietary; however, it is outside the scope of this inspection. Photographs collected of wastewater generation and treatment do not include Ardagh's proprietary glass cooling process. 1 Ardagh Glass CEI Inspection - March 13-14, 2024 IV. FACILITY DISCUSSION The following Facility Discussion is a combination of information obtained during both March 13 and March 14th discussions. Ms. Fouch explained that press and blow glass manufacturing of amber and flint glass containers began in this location in 1889 and that the current site is leased from the City of Dunkirk. The site has been purchased by different companies throughout its history. Ardagh purchased the company St. Gobain, who previously operated in the facility in 2012. Ardagh employes over 400 employees split over three shifts which runs 24 hours per day, every day. According to facility representatives, it has the fastest beer bottle making individual section (IS) machine which makes 786 bottles per minute. Mr. Ostrowski explained the facility has a hot end and cool end sections and estimates that 95% of the wastewater is generated at the hot end with the remaining 5% used for hydrostatic testing of shatterability. The following is a brief description of the hot end line. The facility has two natural gas oxy-fuel furnaces which produce flint (clear) and amber (brown) glass food containers. Furnace 1 has five flint shops and Furnace 2 has three amber shops. The furnace is charged with cullet, which is recycled or broken glass, and proportioned virgin materials, consisting of sand, soda ash, carbon, dolomite, electrostatic precipitate dust among other materials. The percentage of cullet to virgin materials varies depending on the product and the market fluctuations. The furnace is above 2300 degrees Fahrenheit (F), and electrodes ensure that the molten glass is maintained at consistent temperature. Shearing cuts molten glass into identical gobs which are sent to an IS forming machine for molding. Hot end coater adds polycoat, or duracote, to formed bottles as a basecoat then an annealing lehr reheats the glass containers to strengthen according to specific integrity standards. The two furnaces are continuously operating and have been producing glass since their initial installation. A cold rebuild is extremely rare, which requires the furnaces to be completely shut down and occurs every 8-12 years. All maintenance performed on the furnace is hot repair which occurs when the furnace is still operating. Quality issues can arise if the molten glass temperature varies by five degrees. If a hotspot is discovered (could be due to metals or contaminants and could damage the charger), first air will be used to cool and if that doesn't work then cooling water will be used. Recently, Furnace 2 had an emergency hot bottom repair. Furnace 1 was installed in 1993 and has once had a cold rebuild in 2012 and has a cold rebuild scheduled later this year in 2024. Furnace 2 was installed in 1998 and had its cold rebuild in 2011. The previous owners had a consent decree in 2014 to control sulfur dioxide and nitrogen oxides and after purchasing the operations, Ardagh installed semi-dry electrostatic precipitator scrubbers to remove particulates and sulfur compounds. Mr. Ostrowski explained how process water is treated: Incoming water is mainly well water (approximately 400,000 gallons per day (gpd)) and city water from Dunkirk (approximately 50,000 (gpd) is also used. Well water is first processed with iron removal and then half of the 2 Ardagh Glass CEI Inspection - March 13-14, 2024 water is softened prior to reblending with treated city water. Treated water is stored in a water tower which supplies water to the industrial processes. City water goes through a water softener process and then is used as potable sanitary and is also stored in cooling towers, to be used as cooling water for compressors, electrodes and other heat exchangers. According to a flow diagram, the Ardagh facility uses water in the following processes and in the approximate amounts: cullet quench water (300,000 gpd), scrubber mist (50,000 gpd), non-contact cooling (42,000 gpd), shear lubricant (15,000 gpd), sanitary (9500 gpd), floor and mold wash (6000 gpd), cooling towers (5000 gpd), air compressor condensate blowdown (1500 gpd) and hydrostatic bottle testing (300 gpd). Wastewater discharged to the City of Dunkirk is bled from a pretreatment system that collects wastewater from cullet quench water, shear lubricant, floor and mold wash, and hydrostatic testing. The pretreatment process begins with collection of process wastewater in the basement trench, then through a grit chamber to the sump where it will be pumped to the wastewater treatment building, called the "water barn". Enzymes for hydrocarbon, biochemical oxygen demand (BOD) and chemical oxygen demand (COD) degredation, and nutrients are added. Wastewater is pumped into one of two oil water separators and then into a twochambered aeration basin with aerated enzyme biological treatment. The aeration basin is level controlled and will either be recycled as cullet quench water or bled to the wastewater discharge point. Combined wastewater entering the municipal sewer consists of pretreatment system discharge (330,000 gpd) combined with sanitary (9500 gpd), cooling tower blowdown (2500 gpd), iron removal backwash (2000 gpd), main water softener backwash (1000 gpd), and air compressor condensate blowdown (1500 gpd). I asked how much recirculated water is bled to the municipal sewer or reused in process and Ms. Fouch answered that the amount of processing water depended on the production needs. While glass manufacturing is continuously occuring, some of the glass is product and some is cullet to be recycled. A larger quantity of water is used when the equipment is producing cullet to keep the cullet chute to the basement cool to prevent molten glass from sticking to the sides. While amber lines are always making the same product, the flint lines will change approximately once per day. During production ramp up, when cullet is produced, more recycled water is consumed and less wastewater is discharged to the municipal sewer than during full production. An emergency bypass has been built into the pretreatment system to bypass the oil water separators, since that is slowest process. The previous practice to most quickly reduce flooding was to open the bypass if there was any basement flooding. Since IDEM inspection in November 2023, the emergency bypass has been locked and Ardagh's new policy is that management must be called prior to unlocking, which has not occurred since adding the lock. Also, since IDEM inspection, Mr. King, took over maintenance and implemented changes such as cleaning out trenches, walls and equipment and grit chambers which are expected to eliminate basement flooding. Since implementing these new practices, the basement has not had issues with flooding. 3 Ardagh Glass CEI Inspection - March 13-14, 2024 The oil water separator has augers which remove sludge to thickening tanks. Liquids from the thickening tanks return to the pretreatment system prior to the oil water separator using a manual valve. Another change implemented after November 2023, is that the facilities team will daily blow out the augers and weekly isolate one filter and remove solids. The sludge thickening tanks are serviced by a contractor, Crystal Clean, and at the same time, it will remove the floating oil scum from the aeration basin. I asked what pollutants of concern would expect to be in cullet, particularly if trace metals were a concern. Mr. Ostrowski answered that possibly some trace contaminants could be in raw materials present and cullet has a small percentage of lead. However, metals pose a qualtiy issue and could damage the furnace with a hotspot, so a magnet removes metals prior to entering the furnace. Mr. Ostrowski informed me that shear, swab and machine oil was also expected to be present to be in wastewater. Swab oil is a releasing agent for the mold, which are brass or cast iron, and each mold must be lubricated every 20 minutes and would be present in the floor wash. The mold swab oil is graphite based, and it will volatilize upon contact with the hot molds and deposit on surfaces and floor. Since any oil that contacts product must be animal fat based to be food safe and swab oil is petroleum based the first few bottles are contaminated and are recycled as cullet. Once per quarter, and usually around December holidays the machines and floors are pressure washed. The equipment is black from swab oil deposition, and it is expected that swab oil is present during this washing. Shear water, reverse osmosis water which contacts shears, is expected to contain shear oil. The oil must be used to keep molten glass from sticking to the cutting edge. Many machines also use 20 weight machine oil in Lincoln automatic lubricators. I asked if Ardagh was aware of any issues at Dunkirk WWTP and Mr. Ostrowski replied that he was aware of an oil and grease issue in the past and that Ardagh paid for removal of 2200 gallons from a large tank and two biobags of sludge from the Dunkirk WWTP. The letter from Dunkirk, Indiana City Attorney describing this 2023 incident is included as Appendix E. He thought that this event occurred before some of the adjustments to maintenance which have occurred since November 2023. Mr. Ostrowski stated that chlorides in the wastewater were most likely due to water softening. There is a large water softener used for the water tower/cooling tower and also smaller water softeners around the facility. Brine water at 20 ppm is used during media regeneration as sodium replaces hard water and the chloride is discharged in backwash to the pretreatment system. According to Ms. Fouch, Ardagh used approximately 700,000 pounds (lbs) of salt in 2022 and 1,000,000 pounds of salt in 2023. Ardagh hired a consultant in November 2023 to perform an elution study for the efficiency of its water softeners to maximize efficiency and add flow meters to construct a mass balance. Mr. Ostrowski stated by maximizing water softeners it would potentially reduce chlorides; however, the study did not determine the amount of chlorides which would be in the effluent when the water softeners were operating at maximum efficiency. 4 Ardagh Glass CEI Inspection - March 13-14, 2024 Another change that Ardagh recently undertook was an efficiency project to install new chillers for the hydrostatic testing tanks which would recirculate cooling water instead of using one pass water. This change ended up in a reduction of 86,000 gallons per day water usage. Ardagh is also trying to determine where phosphates originated in its processes and have determined that the surfactants for floor wash, IS machines wash, salt cakes and virgin materials do not have phosphate. V. FACILITY SITE VISIT On March 14, 2024 at 10:43 AM, EPA, IDEM and Ardagh representatives began walking around the facility. The stormwater areas visited are hot reject cullet flint pile, visitors parking lot, flint and amber cullet piles, ground surrounding near pretreatment water barn, water treatment, and the fire suppression tank. The pretreatment areas visited are aeration basin, water barn including oil water separators, bypass and bleed valve, combined wastewater sample point, and the water treatment building. The production areas visited are basement wastewater collection, first floor amber IS machine and Furnace 2 in hot end, and mezzanine duracote mixing area. Immediately outside the office is the hot flint cooling area, where flint cullet from the basement is cooled prior to moving it to the cullet pile near the parking lots. Two stormwater access points are near the hot flint cullet cooling pile (Photo 1). According to Mr. King, the square stormwater drain has been removed from stormwater piping and now discharges to the sanitary sewer. The second manhole, which is mostly closed by a metal plate does have a small access opening that could allow stormwater to pass (Photo 2). I asked whether this manhole also drains to the sanitary sewer. Mr. Ostrowski replied that it drains to the stormwater outfall. Mr. King told me that their cleaning practice is to seal the storm sewer off at the outfall end and backflush the pipes towards a vacuum which would collect the backflush water and send it to the pretreatment system. After completing the rest of the site visit, Mr. Maraldo and I returned to this area during a rain event and noted flow towards and into the square drain (Photo 35). We continued walking through the parking area and cullet piles. I noted cullet covering and overtopping concrete blocks next to and spilling over into the visitors parking area (Photo 3). I also noted two covered structures in the cullet storage area but the flint and amber cullet piles where significantly larger than the covered structures (Photos 3-5). At the end of the site visit, Mr. Maraldo and I returned and observed significant flow entering two different storm drains located in the visitor's parking area (Photos 33-34). Next, we continued to the industrial wastewater pretreatment area called the water barn. Two aeration basins run in parallel with four aerators in each basin. According to Mr. King, usual operation procedure is to have one aerator on. At the time of the inspection, I noted that one 5 Ardagh Glass CEI Inspection - March 13-14, 2024 aerator was operating in each basin. I observed floating scum buildup on west aeration basin, black flecks floating in the aeration basin and a black scum line on the basin at the water's edge. Mr. Ostrowski noted that the floating scum is vacuumed out by Crystal Clean but they do not clean the scum off the back of the basin, only remove any accumulated floating scum. Inside the water barn, two oil water separators (Photos 13-14), two sludge thickener tanks, and enzymes and nutrient additons (Photos 9-10) are located. Mr. Ostrowski showed the valve to bypass the oil water separators and I observed that it was locked and a sign was present (Photo 12). After treatment wastewater is recirculated as cullet cooling water, any additional wastewater beyond what was used passes through the bleed valve. The valve is manually adjusted to keep the levels in the aeration basin and the recirculating water steady. I observed that the valve was reading at 60% open during inspection (Photo 8). There is a sample point just beyond the bleed valve used for internal dosing. I observed a logbook and Mr. King stated that samples were collected for internal process control (Photo 11) and not for regulatory compliance. We walked to the sample hut where there is a manhole for combined wastestream (Photo 15) and an autosampler (Photo 16). The autosampler is new, as of January 2024, but was not collecting samples at the time of inspection. I saw that there was no thermometer in the autosampler, and that the autosampler screen did not provide a temperature reading on its screen. The temperature of the combined wastestream and flow are documented and at the time of the inspection the temperature was reading 67.4 degrees Faherenheit and the flow meter was reading 269 gallons per minute. Mr. Ostrowski told me that CF Environmental is contracted to collect the sample and their procedure was to set up the autosampler the day before so that a 24 hour composite sample would be collected. He was not sure whether CF Environmental would also check the sample temperature at the time of collection. While walking outside of the sample hut and towards the employee parking lot, I observed a portable pump located near a stormwater drain (Photo 17). Mr. King stated that this pump was necessry to prevent the parking lot from flooding, since stormwater would accumulate in this area. We walked to the building that houses the water softener and iron removal treatment for process water sent to the watertower. Brine water tank is stored outside of the building and underroof (Photo 18). Mr. King identified that he would "fluff" the iron removal sand media with pressurized air. At the time of the inspection, I observed that orange water was sitting on the floor. I noticed a drip on the iron removal treatment which had a panel installed to move the water from hitting the treatment tank and instead fall onto the floor (Photo 19). In the same building, near the entry, I noted a drain (Photo 20). When I asked where this drain leads to, Mr. King replied that if the building was flooded it would drain to the sanitary sewer, but the small amount of sitting water that I observed would not reach this drain. We next went to the basement of the processing building, and viewed how wastewater is collected prior to entering the pretreatment system. In the basement, various porous 6 Ardagh Glass CEI Inspection - March 13-14, 2024 dumpsters are placed under chutes which collect hot cullet and discharge cullet cooling water to the floor (Photo 21). Cullet dumpsters are transferred to the hot cullet cooling pile outside via forklift. The floor also has two secondary containment dikes under the furnaces and at the time of the inspection one containment area was partially full of water (Photo 22). A pump had been installed in the containment area and was pumping the water to the basement floor (Photo 23). The floor is sloped and Mr. Ostrowski identified the location of the grit chambers where all wastewater on the floor would flow towards (Photo 24). Due to the hazards of falling cullet, we did not view the grit chambers. We next went to the processing floor (directly above the basement) where the IS machnies are located (Photos 25-28). We viewed the gob sheer location where sheer oil is used (Photo 25). We observed swab oil (Photo 27) being applied to molds and volatilizing. We noted the drains for cooling water which is collected in the basement (Photo 26). Mr. King identified the drains that would be used for floor cleaning (Photo 28). I observed a black residue on the floor and equipment, and Mr. Ostrowski told me that this was in part due to volatlized swab oil. We next went to the furnace floor directly above the processing floor. We observed the Furnace 2 and its forehearth with chargers (Photo 29). Mr. Ostrowski identified the location where a hot repair had recently occurred and the drains that would be used during the hot repair (Photo 30). We next observed the duracote applied onto flint bottles and Mr. Ostrowski informed me that any excess duracote is discharged to the basement to the pretreatment system. We then walked to the mezzanine where concentrated duracote was stored and mixed. I observed secondary containment surrounding this area, which included a small water softener unit, brine tank and mixer (Photo 31). The duracote mixer must be drained once a month through a drain that also flows to the basement. (Photo 32). Once we finished at the processing building, a rain event had occurred and Inspector Maraldo and I viewed the stormwater drains next to the visitors parking lot (Photos 33-34) and I observed significant ponding and inflow. We also observed stormwater flow through the hot cullet cooling pile (Photo 35) towards the drain. We then concluded the site visit at 1:01 PM. VI. CLOSING CONFERENCE I began a closing conference at 1:15PM. The following are the areas of concern discussed during the closing conference. 1. The national pretreatment standards at 403.5 prohibits discharges that introduce into a POTW any pollutant(s) which cause Pass Through or Interference. Chlorides are used by Ardagh in its water treatment process and discharged through the combined wastestream to the Dunkirk POTW. Dunkirk POTW has exceeded its NPDES Permit final chloride effluent limits. 7 Ardagh Glass CEI Inspection - March 13-14, 2024 2. The national pretreatment standards at 403.5 prohibits discharges that introduce into a POTW any pollutant(s) which cause Pass Through or Interference. Oil and grease are used by Ardagh in its industry process and discharged through combined wastestream to the Dunkirk POTW, including the events described in Appendix E. Dunkirk POTW has identified floating oil and grease in its chlorine contact chamber prior to its outfall. 3. Cullet piles outside of cover and outside of concrete walls. Stormwater monitoring and non-numerical effluent limits in Permit IN0061816 Part D.4 list minimizing exposure to precipitation and good housekeeping measures to keep exposed areas orderly. The best management practice (BMP) for the cullet piles and waste cullet piles is to contain cullet piles in cullet bunkers and maintain good housekeeping around area according to Ardagh's Contingency, Emergency, and Spill Prevention Plan (CESPP) Appendix Table H-3 Exposed Significant Materials. 4. According to sampling results submitted through DMRs the following effluent limitations from Permit IN0061816 Part I.A were exceeded: Date Outfall Parameter Monitoring Type Permit Limit Sample Value 10/2021 001 11/2021 002 06/2022 001 12/2022 001 01/2024 001 Oil and Grease Temperature Temperature Temperature Temperature Monthly Average Daily Max Daily Max Daily Max Daily Max 10.0 mg/l 73.0 F 93.0 F 60.0 F 53.0 F 11.45 mg/l 75.0 F 99.5 F 63.1 F 75.2 F 5. While sample collection was not occuring at the time of the inspection, no temperature probe was located in the combined wastewater autosampler to verify the sample holding temperature. 6. Prior to November 2023, the oil water separator bypass was used to expedite wastewater treatment prior to discharging to the Dunkirk POTW. 7. Portable pump located at edge of parking lot which discharges stormwater to grassy area is not identified in Stormwater Pollution Prevention Plan (SWPPP). I concluded the inspection at 1:56 PM and EPA and IDEM Inspectors left the facility. 8 Ardagh Glass CEI Inspection - March 13-14, 2024 Documents Received from Ardagh: Hardcopy received during the Inspection: Safety Data Sheet (SDS) for Delo 400 XLE SAE 15W-40 Heavy Duty Motor Oil Material Safety Data Sheet (MSDS) for floor cleaner 6905 Manufactured by ChemStation SDS for Swab lubricant Kleenmold 170 MSDS for floor cleaner Product MJ540 Manufactured by Tomco Chemicals Heritage-Crystal Clean workorder 00-00PAGM7 for January 4, 2024 Heritage-Crystal Clean workorder 00-00PBXHG for January 11, 2024 Heritage-Crystal Clean workorder 00-00PD945 for January 18, 2024 Heritage-Crystal Clean workorder 00-00PESL2 for January 26, 2024 Heritage-Crystal Clean workorder 00-00PH75X for February 2, 2024 Heritage-Crystal Clean workorder 00-00PJH9W for February 8, 2024 Heritage-Crystal Clean workorder 00-00PJLPJ for February 9, 2024 Heritage-Crystal Clean workorder 00-00PL2JG for February 16, 2024 Heritage-Crystal Clean workorder 00-00PMGCS for February 23, 2024 Workorder 826951609 clean basement trench on February 15, 2024 Workorder 826951179 clean basement trench tank 2 on February 20, 2024 Workorder 826870762 iron filtration flush on March 31, 2023 Workorder 826875650 finish 4th iron ore vessel and chlorine junk pumps on April 19, 2023 CESPP Appendix Table H-3 Exposed significant materials including potential pollutants Electronic documents received via email: CESPP including SWPPP and Slug Control Plan requirements Dated photo of bypass lock installed City of Dunkirk Violation of Wastewater Discharge Permit Letter Ardagh Dunkirk Violation Letter Request for Additional Time Letter Ardagh Dunkirk Violation Response to City Violation Letter Ardagh Glass Response to Dunkirk Wastewater Permit Violation Letter Dunkirk CY23 Hazardous Waste Biennial Report 2024 - 0223 Hazardous chemical list 3-18-2024 Water softener salt purchase amounts for 2022 and 2023 Duracote Safety Data Sheet Ardagh wastewater pretreatment facility manual Ardagh monthly monitoring reports for 2021 - 2023 Ardagh discharge monitoring reports for 2021 - 2023 9 Ardagh Glass CEI Inspection - March 13-14, 2024 Appendix A: Inspection Photo Log Ardagh Glass EPA Inspection 03/14/2024 All photos taken by Val Dooling, Environmental Engineer, U.S. EPA Camera: RICOH WG-4 GPS Times listed in Eastern Time Zone 1: ARDA0377 Description: Hot flint cullet cooling pile. Square storm grate in front of the cullet pile is connected to the sanitary sewer and the round manhole at bottom right is connected to the storm sewer. Location: Cullet cooling piles Date/Time: 03/14/2024 11:30AM A1 Ardagh Glass CEI Inspection - March 13-14, 2024 2: ARDA0378 Description: Round manhole with open access hole next to the hot flint cullet cooling pile from Photo 1. Mr. King stated that the manhole is equipted with sock filters to prevent broken glass from reaching the outfall. The procedure is to periodically pressure backwash the storm sewers starting near the outfall and collect into a vaccuum truck. Location: Hot cullet cooling piles Date/Time: 03/14/2024 11:30AM A2 Ardagh Glass CEI Inspection - March 13-14, 2024 3: ARDA0379 Description: Yellow barriers demarcate the visitors parking lot located next to flint cullet pile. Cullet has overflowed and covered a concrete block wall which is located behind the yellow barriers. In rear right, the amber covered enclosure is visable and on the right the flint covered enclosure is visable and cullet is seen inside and outside of both enclosures. Location: Cullet piles Date/Time: 03/14/2024 11:32AM A3 Ardagh Glass CEI Inspection - March 13-14, 2024 4: ARDA0380 Description: View of same enclosure and yellow barrier from the Visitor's parking lot as Photo 3. Flint cullet is in foreground and amber cullet is in rear ground. Location: Cullet piles Camera Direction: Date/Time: 03/14/2024 11:33AM A4 Ardagh Glass CEI Inspection - March 13-14, 2024 5: ARDA0381 Description: View of same two enclosures as Photo 3 from different angle. Flint cullet pile is on left and amber cullet is on right. A yellow concrete wall can be seen on the bottom left with the flint cullet on top and outside of the concrete wall. Location: Cullet piles Date/Time: 03/14/2024 11:35 AM A5 Ardagh Glass CEI Inspection - March 13-14, 2024 6: ARDA0382 Description: West aeration basin with floating scum visable in corner. Note some black flecks floating in the aeration basin near the scum. Black scum line can be seen builtup on the edge of the aeration basin. Location: Water barn Date/Time: 03/14/2024 11:39AM A6 Ardagh Glass CEI Inspection - March 13-14, 2024 7: ARDA0383 Description: West aeration basin with black scum line. Location: Water barn Date/Time: 03/14/2024 11:41AM A7 Ardagh Glass CEI Inspection - March 13-14, 2024 8: ARDA0384 Description: Bleed value open at 60 percent. This can be manually adjusted to keep the levels in the aeration basin and the recirculating water steady. The industrial wastewater discharge occurs through this bleed valve. Location: Water barn Date/Time: 03/14/2024 11:47AM A8 Ardagh Glass CEI Inspection - March 13-14, 2024 9: ARDA0385 Description: Enzymes and nutrients for hydrocarbon degredation which are added to the wastewater in the aeration basin. Location: Water barn Date/Time: 03/14/2024 11:47AM A9 Ardagh Glass CEI Inspection - March 13-14, 2024 10: ARDA0386 Description: Enzymes for fats, oils and grease (FOG), hydrocarbon and chemical oxygen demand (COD) degredation that are added to the pretreatment wastewater. Mr. King stated that the amount added is 2 bags of each. Location: Water barn Date/Time: 03/14/2024 11:49 AM A10 Ardagh Glass CEI Inspection - March 13-14, 2024 11: ARDA0387 Description: Log book next to sample tap downstream of bleed valve. The samples collected are process controls for the pretreated industrial wastewater prior to combining with domestic and cooling water to form combined wastewater. Location: Water barn Date/Time: 03/14/2024 11:59 AM A11 Ardagh Glass CEI Inspection - March 13-14, 2024 12: ARDA0388 Description: Locked oil water separator bypass valve with a sign that indicates it is locked and to call manager. According to Ms. Fouch the lock and sign were installed November 10, 2023. Location: Water barn Date/Time: 03/14/2024 11:59 AM A12 Ardagh Glass CEI Inspection - March 13-14, 2024 13: ARDA0389 Description: Two oil water separators in green and two oil thickeners on back left. Crystal clean will periodically collect the thickener waste. Mr. King stated that maintenance is to spray the augers on the oil water separators daily. Location: Water barn Date/Time: 03/14/2024 12:02 PM A13 Ardagh Glass CEI Inspection - March 13-14, 2024 14: ARDA0390 Description: View of the top of oil water separators and oil thickeners in rear. Location: Water barn Date/Time: 03/14/2024 12:02 PM A14 Ardagh Glass CEI Inspection - March 13-14, 2024 15: ARDA0391 Description: View into open vault of the combined wastestream and Parshall flume used for flow monitoring. An autosampler collects regulatory samples at this point. Location: Sample hut Date/Time: 03/14/2024 12:07 PM A15 Ardagh Glass CEI Inspection - March 13-14, 2024 16: ARDA0392 Description: View into autosampler which was not collecting a sample at the time of inspection. Note, thermometer is not present and tubing is not aligned with the sample collection jug. Location: Sample hut Date/Time: 03/14/2024 12:10 PM A16 Ardagh Glass CEI Inspection - March 13-14, 2024 17: ARDA0393 Description: Portable pump set up near edge of paved parking lot to remove pooled stormwater and relocate to the grass yard. Location: Parking lot Date/Time: 03/14/2024 12:15 PM A17 Ardagh Glass CEI Inspection - March 13-14, 2024 18: ARDA0394 Description: Water softener brine tank located outside and underroof. Location: Water treatment building Date/Time: 03/14/2024 12:19 PM A18 Ardagh Glass CEI Inspection - March 13-14, 2024 19: ARDA0395 Description: Iron removal sand filter located in water treatment building. Mr. King described the process of fluffing the sand media in the tank at the center. At the time of inspection, a panel was placed on top of the piping (top right) which would relocate a drip to the floor and not onto the pipe. At the time of the inspection, I observed orange water on the floor (bottom left). Location: Water treatment building Date/Time: 03/14/2024 12:22 PM A19 Ardagh Glass CEI Inspection - March 13-14, 2024 20: ARDA0396 Description: Drain in water treatment room which discharges to the sanitary sewer. Nalco controls determines ratio of city water and well water that the water tower receieves for use in industrial processes. Location: Water treatment building Date/Time: 03/14/2024 12:23 PM A20 Ardagh Glass CEI Inspection - March 13-14, 2024 21: ARDA0397 Description: Cullet cooling water discharging in the basement and, while not pictured, hot cullet will also fall into the dumpsters. Wastewater flows through the holes in the dumpsters to the basement floor and is directed to the grit chamber for entry in the pretreatment system. Forklifts systematically discard cullet in dumpsters to the hot cullet pile for cooling. I observed sand and broken glass also on the basement floor. Location: Basement in hot end of processing building Camera Direction: Date/Time: 03/14/2024 12:28 PM A21 Ardagh Glass CEI Inspection - March 13-14, 2024 22: ARDA0398 Description: View inside the secondary containment wall into the flooded glass containment area. A hose was located in the flooded contaimnent area and discharging water onto the basement floor. Location: Basement in hot end of processing building Date/Time: 03/14/2024 12:30 PM A22 Ardagh Glass CEI Inspection - March 13-14, 2024 23: ARDA0399 Description: View of hose from Photo22 discharging water from glass containment area onto the basement floor. Location: Basement in hot end of processing building Date/Time: 03/14/2024 12:31 PM A23 Ardagh Glass CEI Inspection - March 13-14, 2024 24: ARDA0400 Description: Basement floor with wastewater, sand, and glass. Mr King indicated that the grit chamber is located under the metal plates in the center of the photgraph. Due to the hazards of falling cullet, inspectors did not view the grit chamber up close. Location: Basement in hot end of processing building Date/Time: 03/14/2024 12:32 PM A24 Ardagh Glass CEI Inspection - March 13-14, 2024 25: ARDA0401 Description: View looking up at sheet as orange gobs are cut and fall onto the IS machine (below and outside of photo). I observed sheer water, which contains sheer oil, falling along with the gobs. Location: Ground floor in hot end of processing building Date/Time: 03/14/2024 12:38 PM A25 Ardagh Glass CEI Inspection - March 13-14, 2024 26: ARDA0402 Description: Funnel and chute which collects and transfers process cullet water to basement. The funnels are connected to the pipe discharging wastewater from Photo 21. Location: Ground floor in hot end of processing building Date/Time: 03/14/2024 12:38 PM A26 Ardagh Glass CEI Inspection - March 13-14, 2024 27: ARDA0403 Description: Swab oil and swabs used to lubricate molds. Location: Ground floor in hot end of processing building Date/Time: 03/14/2024 12:39 PM A27 Ardagh Glass CEI Inspection - March 13-14, 2024 28: ARDA0404 Description: Floor drains on main floor under IS machines. Mr. King explained that when the floors are washed the water discharges to the basement through these floor drains. Location: Ground floor in hot end of processing building Date/Time: 03/14/2024 12:40 PM A28 Ardagh Glass CEI Inspection - March 13-14, 2024 29: ARDA0405 Description: Side of charger with visable molten glass in charger. The short end of the rectangler charger is visable where ingredients are added to the furnace. Electrodes along the long end of the charger keep the molten glass at an even temperature. Location: Furnance level of hot end of processing building Date/Time: 03/14/2024 12:45 PM A29 Ardagh Glass CEI Inspection - March 13-14, 2024 30: ARDA0406 Description: Drain under long end of the same charger as Photo 29. Cooling water used to cool the charger during hot rebuild is discharged through this drain to the basement. Location: Furnance level of hot end of processing building Date/Time: 03/14/2024 12:47 PM A30 Ardagh Glass CEI Inspection - March 13-14, 2024 31: ARDA0407 Description: Duracote (also called poly-coat) water softener and reverse osmosis system and excess chemical stored in diked area on mezzanine level. Mr. Ostrowski explained that duracote allows the label to propserly adhere to the bottles. Location: Duracote mixing area Date/Time: 03/14/2024 12:56 PM A31 Ardagh Glass CEI Inspection - March 13-14, 2024 32: ARDA0408 Description: Drain located on the side of the Duracote mixer which is loctaed outside the picture. Monthly the mixer is drained and is discharged to the basement and the pretreatment system. Location: Duracote mixing area Date/Time: 03/14/2024 12:58 PM A32 Ardagh Glass CEI Inspection - March 13-14, 2024 33: ARDA0409 Description: Drain in visitors parking lot. The stormwater flows from the surrounding parking areas and pools into this part of the parking lot. I observed a deep pool of stormwater and rapidly swirling water as the storwmwater was entering this drain. The flint culllet is in rear. Same visitor's parking area as in Photo 3. Location: Visitor's parking area Date/Time: 03/14/2024 1:08 PM A33 Ardagh Glass CEI Inspection - March 13-14, 2024 34: ARDA0410 Description: A second drain in the visitors parking lot. This is a different drain than the one in Photo 33. This is the same area though and the same area as photo 3. Location: Visitor's parking area Date/Time: 03/14/2024 1:08 PM A34 Ardagh Glass CEI Inspection - March 13-14, 2024 35: ARDA0411 Description: Hot cullet cooling pile. This square drain discharges to the pretreatment system and the round manholes discharge to the stormwater drain as documented in Photos 1-2. Location: Hot flint cullet pile Date/Time: 03/14/2024 1:09 PM A35 Ardagh Glass CEI Inspection - March 13-14, 2024 Appendix B: Aerial image of Ardagh Glass Inc. Dunkirk Facility Note: Aerial images obtained from Ardagh's CESPP Figure 2 and attributed to Google Earth. Images do not represent conditions observed and are only to be used as reference. B1 Ardagh Glass CEI Inspection - March 13-14, 2024 Appendix C: IDEM Pretreatment Permit No INP000201 Part I C1 Ardagh Glass CEI Inspection - March 13-14, 2024 C2 Ardagh Glass CEI Inspection - March 13-14, 2024 C3 Ardagh Glass CEI Inspection - March 13-14, 2024 C4 Ardagh Glass CEI Inspection - March 13-14, 2024 C5 Ardagh Glass CEI Inspection - March 13-14, 2024 C6 Ardagh Glass CEI Inspection - March 13-14, 2024 C7 Ardagh Glass CEI Inspection - March 13-14, 2024 C8 Ardagh Glass CEI Inspection - March 13-14, 2024 C9 Ardagh Glass CEI Inspection - March 13-14, 2024 C10 Ardagh Glass CEI Inspection - March 13-14, 2024 C11 Ardagh Glass CEI Inspection - March 13-14, 2024 Appendix D: Concentration of chlorides (mg/l) in Ardagh Glass' combined wastestream effluent Graph of Chlorides (mg/l) concentration values at combined Wastewater Discharge Point obtained from Monthly Monitoring Reports for from required by IDEM Industrial Discharge Permit ILP000201 D1 Ardagh Glass CEI Inspection - March 13-14, 2024 Appendix E: City of Dunkirk Violation of Wastewater Discharge Permit Letter E1 Ardagh Glass CEI Inspection - March 13-14, 2024 E2 Ardagh Glass CEI Inspection - March 13-14, 2024 E3 Ardagh Glass CEI Inspection - March 13-14, 2024 Appendix F: Ardagh Glass Response to Dunkirk Wastewater Permit Violation Letter F1 Ardagh Glass CEI Inspection - March 13-14, 2024 F2 Ardagh Glass CEI Inspection - March 13-14, 2024 F3