Document oMD9M78kQ1Mgaq0L911n3MG0R

U.S. EPA, Region 5 Enforcement and Compliance Assurance Division 77 West Jackson Street, Chicago, IL 60604 UNPERMITTED INDUSTRIAL FACILITY STORMWATER INSPECTION CHECKLIST Inspection Date(s): Time: Weather Conditions: Media/Program: June 8, 2022 Entry: 12:00 p.m. Exit: 2:15 p.m. Rainy Water - Clean Water Act (CWA) 301, 402 - Industrial Stormwater Operator Name: Owner Name: Facility or Site Name: Permit ID or Tracking # (leave blank if no permit): SIC Code(s) (Primary & Relevant Others): Facility Address: (City, State, Zip Code) County: Geographic Coordinates: Operator Mailing address: Owner Mailing address: Regular Days/Hours of Operation: # of Employees at location: Size of Facility (in acres): Receiving Water(s): Date facility est. @ location: Paul Kasperski Epix Tube Company 3317 500 North Broadway Aurora, Illinois, 60505 Kane County 41.766879, -88.307662 500 North Broadway, Aurora, Illinois 60505 5800 Wolf Creek Pike, Dayton, Ohio 45426 6 days a week, 16 hours a day 22 1.3 acres Indian Creek Approximately 2009 Onsite Representative: Name: Nancy Young Title: Vice President - Aurora Phone #: 937-529-4858 Office Email: Authorized Official: Contacted? Not by EPA, but by Nancy Young Name: Paul Kasperski Title: Owner Phone #: Email: pwk@clearlymachine.com Additional Personnel Participating in Inspection: Name: Miguel Madrigal Title: Plant Manager Inspector(s): Name(s): William Jones Jake Berger Inspection Report Author: Name: William Jones Title: Wet Weather Program Mgr Physical Scientist Phone #: 312 886-6058 312-353-8024 Signature/Date: WILLIAM JONES Digitally signed by WILLIAM JONES Date: 2022.08.02 07:30:53 -05'00' Supervisor Review: Name: Molly Smith Signature/Date: MOLLY SMITH Digitally signed by MOLLY SMITH Date: 2022.08.01 16:54:00 -05'00' Epix Tube Company SECTION I - INTRODUCTION Purpose of the Inspection The purpose of the inspection was to determine compliance with the industrial stormwater requirements under 301 and 402(p) of the CWA and its implementing regulations found at 40 CFR Part 122.26. The inspection was (check one) unannounced announced and consisted of interviewing facility representatives, recording field observations, and taking photographs to document site conditions throughout the facility at the time of the inspection. Opening Conference 1) Brief narrative documenting those present, introductions, and explanation of the purpose of the inspection. Attendees: William Jones, Jake Berger, Miguel Madrigal, Nancy Young 2) Credentials presented to: Nancy Young 3) Confidential Business Information (CBI) collected: yes no 4) Facility has been individually notified by Permit authority or EPA that it is subject to stormwater permitting requirements? Yes No Describe: The facility representatives present were not aware of Industrial Stormwater Permits. 5) Has the Facility applied for an Industrial Stormwater Permit or a Waiver from the requirement to have one (such as through the filing of a No Exposure Certification)? Yes No Describe: 6) Overview of Facility (attach, if available): a) Aerial of facility with immediate environs, especially any storm drain inlets and surface waters Yes No; b) Site map showing industrial processes and locations Yes No; and c) Facility schematics labeling industrial processes occurring onsite Yes No. FACILITY'S OPERATION & PRODUCT DESCRIPTION Brief description of business and industrial activities occurring throughout the site. Include operator's description and note any documentation that further establishes SIC code (permit applications, reports, business registries, website, etc). Epix Tube in Aurora manufactures tube from sheets of metal by hot rolling and forming steel and galvanized steel. The Facility paints the tubes with acetone and a clear coat of paint. Additionally information can be found at: www.epixtube.com The facility sells the tubes. Other industrial facilities owned/operated by same business entity? Yes No Ohio that employs around three to four times as many people as the Aurora location. Describe: Epix Tube has a facility in Dayton, SECTION II - OBSERVATIONS Pollutant Sources SITE EVALUATION Note location (including whether occurring indoor or outdoor, and whether outdoor areas are paved or unpaved), quantity/size, design issues, any operation and maintenance (O&M) deficiencies (including the nature and extent), potential pollutants, and evidence of exposure 2 Epix Tube Company to stormwater. Are best management practices (BMPs) in place to minimize or eliminate stormwater discharges from industrial activities? If so, please describe. Loading/Unloading Operations The facility has tractor trailers unloading steel and picking up pipe and tubing on the south side of the building. There was also a tractor trailer parked near this area. The water was ponding near this area and had an oily sheen on it. Industrial Manufacturing/ Processing Operations Epix manufacturing operations are located inside the buildings. Industrial Machinery & Equipment Storage Storage of Industrial Materials or Products Liquid Storage (e.g., Storage Drums) Tanks, Liquid Anti freeze is stored outside on the south side of the building in what appears to be a 55-gallon plastic container with an open lid and in a small bucket on the ground that is partially covered with a solid piece of material. Neither container had secondary containment and are just upslope of where the stormwater was running off the Faciltiy into the stream. Miguel said that the Facility has a waste hauler come and take out the waste liquids, but did not know when they last picked up containers from the area on the west side of the Facility. To the west of the building (back of the building) there is a storage area of waste Tolulene, waste acetone, and waste oil that is outside in 55-gallon drums. During the inspection, the Toluene and acetone drums were bulging at the top. Also, there were larger containers that were partially filled with Charcool, which is what the Facility uses to cool their machinery. There were 55-gallon drums stored in a second smaller building near the entrance of the Facility. Pollutant Sources Note location (including whether occurring indoor or outdoor, and whether outdoor areas are paved or unpaved), quantity/size, design issues, any O&M deficiencies (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are BMPs in place 3 Epix Tube Company to minimize or eliminate stormwater discharges from industrial activities? If so, please describe. Waste Storage/Disposal Areas (solid and/or hazardous) To the west of the building (back of the building) there is a storage area of waste Tolulene and waste acetone and waste oil that is outside in 55-gallon drums. At the time of the inspection, the Toluene and acetone drums were bulging at the top. Also, there were larger containers that were partially filled with Charcool, which is what the Facility uses to cool their machinery. There were also 55-gallon drums stored in a second smaller building near the entrance of the site. Waste Treatment Facilities (e.g., Pretreatment Systems) Fueling Stations/Equipment Maintenance Areas & Cleaning Areas Near a southwestern corner of their building there was a black plastic container that was used to change oil. This container was left outside in the rain and there was an oily residue and sheen on the ground nearby the plastic container. Miguel stated that this was left by the contractor that they have come and change the oil on their three forklifts. Sediment & Erosion Controls Spills/Leaks Handling Facility reported that no spills have occurred. Outside Shelters Temporary (Date Established___________________) Permanent OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS List any established stormwater discharge points. For each such discharge point, describe its location, the Facility areas it serves, Receiving Water/MS4 into which it discharges, Receiving Water appearance, date the discharge point was established, and evidence of present or past discharge (e.g., Facility records or visual evidence such as stains, deposits, ponding). There is a manhole near the front of the Facility. In the manhole is a pipe that leads towards the stream to the south of the property. This receives water from the parking lot, sump pump discharge from the sump inside the Facility. There was rust colored staining on the ground from water that had drained to the manhole. On the north bank of Indian Creek, running along the Facility and just west of Broadway, there was a discharge coming from the Facility. There was a break in the barrier along the south side of the Facility that was discharging storm water into Indian Creek. Storm water drains to this area from the ponded area below the tractor trailers and from the area where the anti freeze was stored outside. An oily sheet was observed on top of the ponded water. See photos. 4 Note evidence of any discharge pathways from the Facility not otherwise noted above, and for each pathway, describe its location, slope, the Facility areas it may serve, evidence of past or present migration of pollutants offsite via the pathway (e.g., Facility records or visual evidence such as stains, deposits, ponding), Receiving Water/MS4, and Receiving Water appearance. Note evidence of any nonstormwater discharges, including process water discharges, from the Facility, and for any such discharge, describe its nature, source, discharge location, Receiving Water/MS4, Receiving Water appearance, and discharge authorization, if any. SECTION III - AREAS OF CONCERN Epix Tube Company CITATION DESCRIPTION SUPPORTING INFORMATION CWA 301 Discharge without a permit. Water with rust was entering the storm drain inlet that led towards Indian Creek. Water with an oily sheen was also ponding on the Facility's site and then flowing off the south side of the Facility through a break in the berm and into Indian Creek. See photographs. SECTION IV - CLOSING CONFERENCE Attendees: Was CBI collected? Yes No Describe: Summary of areas of concern(s) listed above: From the Facility, EPA identified two discharges industrial stormwater without a permit via a storm drain and through a bermed area. Waste chemicals and antifreeze were stored outside where they could spill. A black plastic oil changing pan, stored outside, was identified, along with oil on the pavement. The inspectors also noted rusty sump water entering storm drain inlet. SECTION V - LIST OF ATTACHMENTS (as identified in #6 above, where applicable) 5 Attachment A - Aerial of facility Attachment B -Photograph Log Epix Tube Company 6