Document q34aYDNpMXN6bqG57wmqbkX4G

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 04/30/2025 8:52 AM (CT) Announced: No 04/30/2025 11:40 AM (CT) Access: Granted Sunny and close to 60 degrees Fahrenheit (F) Water Clean Water Act, NPDES, Stormwater - Industrial Industrial Stormwater Inspection (ISI) Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County Facility GPS Coordinates Mailing Address City, State, Zip Code WOW Logistics TreeHouse Foods 1164 O'Hare Blvd Hobart, Wisconsin 54115 Brown 44.454599, -88.134539 1450 McMahon Road Neenah, Wisconsin, 54956 FRS ID Permit Number SIC and/or NAICS 110071155176 WIR05IA08 4225 - General Warehousing and Storage Regulatory Representatives Participating in Inspection: Title Name N/A N/A Organization N/A Lead Inspector: Danny Nguyen Supervisor Review: Mr. Brooke Furio EPA REGION 5 nguyen.danny@epa.gov 06/18/2025 (440) 250-1709 BROOKE FURIO Digitally signed by BROOKE FURIO Date: 2025.06.18 13:47:01 -04'00' EPA REGION 5 furio.brooke@epa.gov (440) 250-1705 1 of 31 WOW Logistics Company Inspection Date: 04/30/2024 SECTION I - INTRODUCTION Site Entry and Inspection Objectives EPA REGION 5 inspector, Danny Nguyen, arrived at WOW Logistics Company (WOW), located at 1164 O'Hare Boulevard (Blvd), Hobart, Wisconsin 54115, at 8:52 AM (CT) on 04/30/2025 for an unannounced inspection. Mr. Nguyen presented his credentials to Mr. Dave Hurlbut and informed him that this was an EPA REGION 5 inspection to investigate elements of the Clean Water Act (CWA) and applicable regulations. This report is based on information supplied by WOW's representatives, direct observations made by the EPA REGION 5 inspectors, records and reports maintained by the permittee and other information including: photographs taken by EPA REGION 5 inspectors, physical evidence collected by the EPA REGION 5 inspectors, measurements taken by EPA REGION 5 inspectors, verbal or written statements made by information supplied by WOW's representatives during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA REGION 5 inspectors by WOW's representatives during or subsequent to the on-site inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization EPA REGION 5 TreeHouse Foods TreeHouse Foods WOW Logistics Attendee Name Danny Nguyen Dave Hurlbut Chris Kanikula Tony Hill Title NPDES Inspector Warehouse Manager EHS Manager, Manufacturing Plant Facility Manager Present in Opening Conf. Yes Yes Yes Yes Present in Closing Conf. Yes Yes Yes No Facility/Site Description EPA REGION 5 inspector confirmed the following facility information: WOW applied for and was issued a General Permit to Discharge Under the United States Environmental Protection Agency (EPA) National Pollution Discharge Elimination System NPDES ID WIR05IA08. The 1164 O'Hare Blvd facility is owned by the WOW Logistics Company and leased for use by TreeHouse Foods. The facility has been leased for approximately twenty years under various brand names (Dean Foods, Bay Valley Foods). The approximately 510,000 square feet single building is used for mainly private brands pickles repackaging, storage, and distribution along with some dry dairy and oatmeal. There is no manufacturing at the facility. The facility has two discharge points where stormwater flows and is collected and then conveyed to the Village of Hobart sewer system. Best management practices (BMPs) employed include good housekeeping and maintenance on the outside near the loading and unloading areas. Inspections and monitoring are conducted by a third-party contractor (Mach IV Engineering LLC) hired by WOW. 2 of 31 WOW Logistics Company Inspection Date: 04/30/2024 Facility/Site Information Responsible official John Elrick Verify SIC Code 4225 Personnel conducting Brad McDermid and Randy Herter (both from Mach IV Engineering LLC) inspections/sampling Sampling locations Discharge points 001 and 002 (per SWPPP) Copy of the SWPPP Yes at WOW office in Neenah, Wisconsin Number of employees 30 Receiving Water Dutchman Creek Number/location of Stormwater Inlets/ Outfalls/Drains including near docks or storage areas and where they initially drain (MS4, ditch detention basin) There are two main discharge points on the property (001 and 002). Discharge point 001 is located on the south side of the property just west of the employee entrance road and 002 is on the east side of the property. The site area is comprised of asphalt parking and grass areas with swales. BMPs/Stormwater Treatment Good housekeeping and maintenance in the loading and unloading areas outside. Industrial activities exposed to stormwater Limited to loading and unloading operations for transport via semi-truck of goods at the facility docks Industrial Sector/Sub- P/P1 sector Type of Operation General Warehousing and Storage Shifts/Hours/Days of Two shifts operating 5:00AM to 1:30PM and 1:30PM to 10:00PM, Monday through Operations/Shutdowns Friday Size of Facility 21 acres Is the SWPPP team present No (Mach IV was not present) Name of the person engaging with the inspector Dave Hurlbut Type of materials Semi-trailer trucks and/or vehicles stored outdoors 3 of 31 WOW Logistics Company Inspection Date: 04/30/2024 Location(s) Location/Area/Sub-area Indoor area Outdoor area SECTION II - OBSERVATIONS Location: Indoor Area Observation #: DN1-OB-001 Description Consist of a work area named Bright Line for repackaging of pickles The outdoor area consists of asphalt parking, trash roll-offs and bins, grass areas with swales, loading and unloading areas, propane storage, and semi-trailer truck parking area Date: 04/30/2025 Weather: Sunny and close to 65 degrees F EPA observed the following during the walkthrough of the indoor area: Drain in ambient area. Per Mr. Hurlbut, the drain goes to the Hobart city sewer and is used for mop, pressure wash, and scrubber wash water. The entire floor is cleaned out quarterly. There is a separate permit with the city for the inside drains. In the Bright Line repackaging area, Mr. Nguyen observed three additional drains that go to the city sewer system according to Mr.Hurlbut. ECOLAB Lift RT is the soap used for cleaning the floors. The forklift charging area, riding floor scrubber, and warehouse storage areas were observed. Mr. Hurlbut stated there is no raw or used oil, facility vehicles, washing, painting operations, or spraying of pesticides on-site. All forklifts are leased. When there is a bad forklift battery, it gets replaced by the leaser (batteries are not kept on-site). Photos 1. DSCN1100.JPG 2. DSCN1101.JPG 3. DSCN1102.JPG 4. DSCN1103.JPG 5. DSCN1104.JPG 6. DSCN1105.JPG 7. DSCN1106.JPG Location: Outdoor area Observation #: DN1-OB-002 Date: 04/30/2025 Weather: Sunny and close to 65 degrees F EPA observed the following during the walkthrough of the outdoor area: Mr. Nguyen observed three open non-covered large roll-offs filled with expired product that could not be sold according to Mr. Hurlbut. A trash bin with an open lid was observed. 4 of 31 WOW Logistics Company Inspection Date: 04/30/2024 Mr. Nguyen observed a drainage ditch and silk fence on the west side of the property. Mr. Hurlbut stated the ditch and silk fence are on the adjacent residential property and were installed by the residential property owner. Mr. Nguyen and walked and observed the north side of the property area behind the building. The swale area on the northeast side of the property was observed. Mr. Nguyen observed discharge point 002 along the adjacent property on the east side of the facility. Three drains (Photos DSCN 1116-DSCN1119) were observed in the asphalt parking lot south of the facility: One drain near the loading and unloading dock on the east side, one drain near the main entrance to the facility, and one drain on the west side near the trash roll-offs and bin. Mr. Hurlbut stated he did know if the drains go to the city sewer system. The drains are not listed as part of the action area and discharge points. No permit coverage sign was observed during the outside walkthrough. Photos 1. DSCN1107.JPG 2. DSCN1108.JPG 3. DSCN1109.JPG 4. DSCN1110.JPG 5. DSCN1111.JPG 6. DSCN1112.JPG 7. DSCN1113.JPG 8. DSCN1114.JPG 9. DSCN1115.JPG 10. DSCN1116.JPG 11. DSCN1117.JPG 12. DSCN1118.JPG 13. DSCN1119.JPG 14. DSCN1120.JPG SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: SWPPP Ref #: DN1-RR-001 Reviewed By: Danny Nguyen AOC: Yes Reviewed Date: 5/16/2025 The latest SWPPP dated May 2, 2025 was reviewed and the following observations were made: The SWPPP did not include directions of stormwater flow on the site map. The SWPPP did not include loading and unloading areas and locations used for storage and disposal of wastes. The SWPPP did not identify the three drains on the south side of the facility near the waste storage area, the main entrance, and the loading and unloading area. 5 of 31 WOW Logistics Company Inspection Date: 04/30/2024 At the time of the inspection, the TreeHouse representatives could not locate a complete copy of the current SWPPP at the facility in any accessible format. Record: Personnel Training Ref #: DN1-RR-002 Reviewed By: Danny Nguyen AOC: Yes Reviewed Date: 5/16/2025 After review of Treehouse Food's training documents, employees at the site go through new hire orientation, emergency action plan, and pest control training that discuss spill emergency procedures, maintenance, and facility housekeeping. Training does not include overview of SWPPP. Although some members on the SWPPP team received training, not all members listed on the SWPPP team had documentation of training. Record: Routine Inspections Ref #: DN1-RR-003 Reviewed By: Danny Nguyen 2023-2025 routine inspection reports were reviewed. Record: Quarterly Visual Assessment of Stormwater Discharges Ref #: DN1-RR-004 Reviewed By: Danny Nguyen AOC: No Reviewed Date: 5/16/2025 AOC: No Reviewed Date: 5/16/2025 2023-2025 Quarterly Visual Assessment reports were reviewed. Record: Monitoring Ref #: DN1-RR-005 Reviewed By: Danny Nguyen AOC: No Reviewed Date: 5/16/2025 2024-2025 Indicator Monitoring report and analysis were reviewed. SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. 6 of 31 WOW Logistics Company Inspection Date: 04/30/2024 SECTION V - AREA OF CONCERN Areas of Concern (AOC) may not be in sequential order. The presentation of Areas of Concern does not constitute a formal compliance determination or violation. AOC Reference #: DN1-OB-001 Location: Outdoor area Regulation and/or Permit Requirement Section 2.1.2.2(c) of the EPA Multi-Sector General Permit (MSGP) requires "The permittee must keep clean all exposed areas that are potential sources of pollutants. You must perform good housekeeping measures that includes keeping al dumpster lids closed when not in use to minimize pollutant discharges". AOC: Three large trash roll-offs and one large bin were observed open and with no cover to minimize exposure to wind and weather. AOC Reference #: DN1-OB-001 Location: Outdoor area Regulation and/or Permit Requirement Section 1.3.5 of the EPA Multi-Sector General Permit (MSGP) requires "The permittee must post a sign or other notice of permit coverage at a safe, publicly accessible location in proximity to your facility." AOC: No permit coverage sign was observed during the outside walkthrough. AOC Reference #: DN1-RR-001 Record: SWPPP Regulation and/or Permit Requirement Section 6.2.2.3(c & j) and (m)(iii & iv) of the EPA Multi-Sector General Permit (MSGP) requires "The permittee must include a site map that includes directions of stormwater flow (use arrows), locations of stormwater inlets and discharge points and approximate outline of the areas draining to each discharge point, and locations where activities are exposed to precipitation such as loading and unloading areas and locations used for storage or disposal of waste". AOC: The SWPPP did not include directions of stormwater flow on the site map. The SWPPP did not include loading and unloading areas and locations used for storage and disposal of wastes. The SWPPP did not identify the three drains on the south side of the facility near the waste storage area, the main entrance, and the loading and unloading area. 7 of 31 WOW Logistics Company Inspection Date: 04/30/2024 AOC Reference #: DN1-RR-001 Record: SWPPP Regulation and/or Permit Requirement Section 6.4 of the EPA Multi-Sector General Permit (MSGP) requires "The permittee must retain a complete copy of your current SWPPP required by the permit at the facility in any accessible format". AOC: At the time of the inspection, the TreeHouse representatives could not locate a complete copy of the current SWPPP at the facility in any accessible format. AOC Reference #: DN1-RR-002 Records: Personnel Training Regulation and/or Permit Requirement Section 2.1.2.8 (a) and (b)(i) of the EPA Multi-Sector General Permit (MSGP) requires "The permittee must train all employees who work in areas where industrial materials or activities are exposed to stormwater or who are responsible for implementing activities necessary to comply with this permit, including all members of your SWPPP, and they must be trained in an overview of what is in the SWPPP. AOC: After review of Treehouse Food's training documents, employees at the site go through new hire orientation, emergency action plan, and pest control training that discuss spill emergency procedures, maintenance, and facility housekeeping. Training does not include overview of SWPPP. Although some members on the SWPPP team received training, not all members listed on the SWPPP team had documentation of training. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA REGION 5 Inspector held a closing conference with the participants listed above at 11:15AM (CT) on 04/30/2025 for the inspection. During the closing conference, Mr. Nguyen discussed the observations and Area(s) of Concern identified during the inspection. Observations and Area(s) of Concern have not yet been evaluated for a formal compliance determination. Mr. Hurlbut did not make a CBI claim. EPA communicated to Mr. Hurlbut that the inspection report will be emailed to WOW Logistics representative within 70 days of the day of the inspection. 8 of 31 WOW Logistics Company Inspection Date: 04/30/2024 Follow Up The following items were requested by the inspector at the time of the inspection. Location: DN1-CC-FD Area: Sub-area: EPA requested a copy of the stormwater training given to TreeHouse Foods, WOW, and Mach IV Engineering LLC employees. Received via email on 5/14/2025 and 5/16/2025. DN1-CC-FD EPA requested TreeHouse Food's Emergency Action Plan. Received via email on 5/14/2025. DN1-CC-FD EPA requested any written agreement between WOW, Mach IV, and TreeHouse for delegation of stormwater responsibilities EPA did not receive requested documents. DN1-CC-FD EPA requested 2024 and 2025 inspection, visual assessment, and monitoring reports. Received uploaded documents on 5/16/2025. DN1-CC-FD EPA requested most current SWPPP. Received uploaded documents on 5/16/2025. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 9 of 31 WOW Logistics Company Inspection Date: APPENDIX 1: PHOTO LOG 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 10:16 AM No CBI No PII Indoor drainage near Bright Line repackaging area DSCN1100.JPG Photographer: Danny Nguyen 10 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 10:18 AM No CBI No PII Indoor drainage near Bright Line repackaging area DSCN1101.JPG Photographer: Danny Nguyen 11 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 10:24 AM No CBI No PII Indoor drainage near Bright Line repackaging area DSCN1102.JPG Photographer: Danny Nguyen 12 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 10:28 AM No CBI No PII Indoor drainage near Bright Line repackaging area DSCN1103.JPG Photographer: Danny Nguyen 13 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 10:31 AM No CBI Indoor Floor Scrubber No PII DSCN1104.JPG Photographer: Danny Nguyen 14 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 10:32 AM No CBI Indoor Floor Cleaning Chemicals and Soap No PII DSCN1105.JPG Photographer: Danny Nguyen 15 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 10:33 AM No CBI Indoor Warehouse Area No PII DSCN1106.JPG Photographer: Danny Nguyen 16 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 10:38 AM No CBI Outside facing west Outside open trash roll-offs No PII DSCN1107.JPG Photographer: Danny Nguyen 44.454508, - 88.13529 17 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 10:39 AM No CBI Outside facing north Outside open trash bin No PII DSCN1108.JPG Photographer: Danny Nguyen 44.454493, - 88.135737 18 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 10:46 AM No CBI Outside facing east Outside north side of building No PII DSCN1109.JPG Photographer: Danny Nguyen 44.454458, -88.136065 19 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods DSCN1110.JPG 04/30/2025 10:46 AM No CBI No PII Photographer: Danny Nguyen Outside facing west 44.455345, -88.138845 Outside west side of building with silk fence from adjacent property 20 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 10:46 AM No CBI Outside facing west Outside northeast side of property No PII DSCN1111.JPG Photographer: Danny Nguyen 44.45536, -88.138736 21 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 11:00 AM No CBI Outside facing northeast Outside facing northeast No PII DSCN1112.JPG Photographer: Danny Nguyen 44.455653, -88.1382 22 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 11:00 AM No CBI Outside facing southeast No PII DSCN1113.JPG Photographer: Danny Nguyen 44.455742, -88.131937 Outside east side of building with adjacent property 23 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 11:03 AM No CBI Outside facing southeast No PII DSCN1114.JPG Photographer: Danny Nguyen 44.455742, -88.131928 Outside east side of building with adjacent property 24 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 11:04 AM No CBI Outside facing southeast No PII DSCN1115.JPG Photographer: Danny Nguyen 44.455742, -88.131928 Outside east side of building with adjacent property 25 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 11:06 AM No CBI Outside facing east No PII Outside drain in front parking lot on east side DSCN1116.JPG Photographer: Danny Nguyen 44.454471, -88.132607 26 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 11:07 AM No CBI Outside facing south No PII DSCN1117.JPG Photographer: Danny Nguyen 44.454163, -88.133083 Outside drain in front parking lot on east side facing employee entrance road on east side 27 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 11:08 AM No CBI Outside facing east No PII DSCN1118.JPG Photographer: Danny Nguyen 44.454407, -88.13349 Outside middle drain in front parking lot near loading/unloading dock 28 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 11:09 AM No CBI Outside facing west No PII DSCN1119.JPG Photographer: Danny Nguyen 44.454462, -88.134753 Outside drain in front parking lot on the west side 29 of 31 WOW Logistics Company Inspection Date: 04/30/2024 WOW Logistics - TreeHouse Foods 04/30/2025 11:41 AM No CBI Outside facing north No PII Employee entrance road facing front of facility DSCN1120.JPG Photographer: Danny Nguyen 44.453275, -88.134935 30 of 31 WOW Logistics Company Inspection Date: 04/30/2024 APPENDIX 2: DOCUMENT LOG Document Type Email Attachment Email Attachment Email Attachment Uploaded Document Uploaded Document Uploaded Document Uploaded Document Uploaded Document Uploaded Document Uploaded Document Uploaded Document Uploaded Document Uploaded Document Uploaded Document Uploaded Document Uploaded Document Uploaded Document Uploaded Document Email Attachment Email Attachment Document Name Contains CBI 2025 NHO Safety - Short No for EPA.pptx EHS-CR-7-816-01 Hobart No DC Emergency Action Plan.doc Pest.docx No 2021 MSGP SWPPP - No WOW - 2024-03-05.pdf 2021 MSGP SWPPP - No WOW - 2024-10-31.pdf 2021 MSGP SWPPP - No WOW - 2025-05-02.pdf 2024 Q1 Sampling No Analysis Results.pdf 2024 Q2 Sampling No Analysis Results.pdf 2024 Q3 Sampling No Analysis Results.pdf 2024 Q4 Sampling No Analysis Results.pdf 2025 Q1 Sampling No Analysis Results.pdf D1 2025-03-31.pdf No D1 2025-04-21.pdf No D1 2025-05-02.pdf No D2 2025-03-31.pdf No D2 2025-04-21.pdf No D2 2025-05-02.pdf No Links to Previous No SWPPPs.docx A_Training No Log_2023_06_27.pdf A_Training No Log_2024_06_27.pdf Contains PII No No No No No No No No No No No No No No No No No No No No Sent/Uploaded By Christopher Kanikula Christopher Kanikula Christopher Kanikula Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Tony Hill Date Received 5/14/2025 5/14/2025 5/15/2025 5/16/2025 5/16/2025 5/16/2025 5/16/2025 5/16/2025 5/16/2025 5/16/2025 5/16/2025 5/16/2025 5/16/2025 5/16/2025 5/16/2025 5/16/2025 5/16/2025 5/16/2025 5/20/2025 5/20/2025 31 of 31