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U.S. Environmental Protection Agency Region 5 Purpose: Clean Water Act National Pollutant Discharge Elimination System Compliance Evaluation Inspection Facility: Hilltop Basic Resources, Inc. Downtown Cincinnati River Terminal 511 W. Water Street Cincinnati, Ohio 45202 Inspection Date: May 24, 2023 U.S. EPA Representatives: Jake Berger, Physical Scientist, 312-353-8024, berger.jake@epa.gov Jennifer Bush, Environmental Scientist, 312-886-0879, bush.jennifer@epa.gov Facility Representatives: Tom Ackley, Plant & Maintenance Manager Geoff Coldiron, Safety Director Report Prepared by: Jake Berger, Physical Scientist Water Enforcement and Compliance Assurance Branch, Section 1 Digitally signed by Berger, Berger, Jake Date: 2023.06.16 Jake Inspector Signature and Date: _____________14_:2_6:_57_-_05_'00_' ___________________________ Approver Name and Title: Molly Smith, Section 1 Supervisor Water Enforcement and Compliance Assurance Branch MOLLY Digitally signed by MOLLY SMITH Approver Signature and Date: S__M_I_T_H________14_:2_2:_43_-0_5_'00_' __________________________ Date: 2023.06.16 PURPOSE OF INSPECTION The purpose of the inspection by the U.S. Environmental Protection Agency (USEPA) at the Hilltop Basic Resources, Inc. - Downtown Cincinnati River Terminal (Hilltop or Facility) was to describe, evaluate, and document compliance with the Clean Water Act (CWA) and their National Pollutant Discharge Elimination System (NPDES) permit. BACKGROUND Hilltop is a ready-mix concrete producer with 40 employees in Cincinnati, Ohio. Hilltop is located on the Ohio River and receives bulk sand and gravel aggregate material at the Facility via barge. Powdered cement is brought in via truck. Hilltop produces about 650 cubic yards of concrete onsite per day and takes it out via their own concrete mixer trucks. Bulk sand and stone aggregate material are stored in large, uncovered piles in the stockyard near the concrete production area, uphill from the Ohio River. Hilltop uses water from the city to use as an ingredient for the concrete. Hilltop has two well water pumps on the property: one serves as a backup for the city water supply, and one is used to clean the conveyors when in use, and if necessary. Hilltop takes samples of their industrial stormwater discharges from where stormwater flows into the city storm drain on Water Street. These discharges are covered by the Ohio Environmental Protection Agency (OEPA) Industrial Storm Water General Permit (Permit) (OEPA Facility ID # 1GR01157*GG; Federal NPDES Identifier # OHR000007) which has an Effective Date of September 15, 2022, and an Expiration Date of May 31, 2027. INSPECTION Jake Berger and Jennifer Bush of USEPA first arrived at the Facility at 9:04 a.m. EDT and were met by Tom Ackley (Plant & Maintenance Manager). Jake Berger and Jennifer Bush showed him their credentials and identification, and began the opening conference. Opening Conference USEPA staff explained that the purpose of the inspection was to: Review Hilltop's records, including sample measurements, monitoring activities, and storm water plans, as required by the Permit for Facility ID # 1GR01157*GG; Conduct a walkthrough of the Facility; Identify locations where storm water control had the potential to be insufficient; and Inform Hilltop of areas of concern regarding the records review and Facility walkthrough. The opening conference ended at 9:32 a.m. EDT and was immediately followed by a Facility walkthrough with Tom Ackley and Geoff Coldiron. 2 Facility Walkthrough USEPA staff made the following observations during the Facility walkthrough with Tom Ackley and Geoff Coldiron, further documented in the Photograph Log (attached): Hilltop is planning to end operations at this Facility and relocate to a new location farther south on the Ohio River. Hilltop predicts that this Facility will be permanently closed, and operations will begin at a new location by the end of 2024. A pump house uses water to rinse out the inside of the drums of the mixer trucks. This water is contained in two pits, to be continually reused onsite for this purpose, and is not discharged (Photo 16). The Facility lacks stormwater and sediment controls along the front of the concrete truck loading station and the stormwater drains on Water Street. Sediment that had been rinsed off the concrete trucks had accumulated along the driveway to the loading station and around the stormwater drains (Photos 1 - 4, Photo 17). At the time of the inspection there was a pile of material spilled off the conveyor belt in the southeast corner of the Facility. According to the Facility, this excess material is removed after each barge is unloaded; however, at the time of the inspection, sediment and rock aggregate material had still accumulated in this corner (Photos 9 - 11). There were no stormwater or sediment controls to prevent this material from flowing down the ramp to the barge dock and into the Ohio River, where sediment and aggregate material had also accumulated (Photo 7 and Photo 8). The southern edge of the Facility and the stockyard lacks stormwater control measures in several places, which allows excess material that is pushed up to the edge to fall down the steep surface leading down to the Ohio River (Photos 12 - 14). The Facility walkthrough tour ended at 10:55 a.m. EDT and was followed by a review of Hilltop's records. Records Review USEPA began reviewing hard copy and electronic records provided by Hilltop with Tom Ackley and Geoff Coldiron at 11:00 a.m. EDT. The following areas of concern were identified: Storm water pollution prevention training is required annually for all on-site employees, which has not been conducted since 2019. Section 5.5 of Hilltop's Stormwater Pollution Prevention Plan states that the riverbanks are separated from the remainder of the Facility with concrete block dikes. Sections of the riverbank lacked sufficient containment with concrete blocks, as described above. Section 5.5 also does not describe any stormwater controls to be used to minimize 3 pollution or runoff in areas such as the spillage corner, barge dock, barge dock ramp, and concrete truck loading station, as described above. USEPA and Hilltop staff paused the records review from 11:45 a.m. EDT to 12:55 p.m. EDT. The records review then continued until 1:25 p.m. EDT, and USEPA ended the records review by requesting that the following documents be provided electronically as soon as possible to USEPA after the inspection: Hilltop's Stormwater Pollution Prevention Plan; Hilltop's most recent Stormwater Annual Report; and Documentation of Hilltop's most recent stormwater employee training. These documents were sent electronically to Jake Berger on June 9, 2023. The records review was immediately followed by the closing conference. Closing Conference USEPA staff relayed the following preliminary comments to Tom Ackley during the closing conference: Areas of the Facility, such as the spillage corner, barge dock, barge dock ramp, and concrete truck loading station, lack stormwater control measures. Sediment and aggregate materials had accumulated in these areas, which could be conveyed to the storm drains or the Ohio River. The southern edge of the Facility, along the stockyard, lacks stormwater control measures to prevent aggregate material from falling into the Ohio River. Storm water pollution prevention training is required annually for all on-site employees, and according to records at the Faciltiy, has not been conducted since 2019. USEPA confirmed that no information collected during the inspection was considered Confidential Business Information. USEPA concluded the inspection and left the Facility at 1:45 p.m. EDT. 4 Hilltop Basic Resources, Inc. - Downtown Cincinnati River Terminal U.S. EPA Inspection: May 24, 2023 All photos taken by Jake Berger, Physical Scientist, U.S. EPA Camera: Olympus Tough TG-6 1: P5240021 Description: Concrete mixing truck getting washed while loaded with concrete Location: Concrete truck loading station Camera Direction: Northeast Date/Time: May 24, 2023 / 9:38 a.m. EDT 5 2: P5240022 Description: Runoff of water used to spray the concrete trucks Location: Concrete truck loading station Camera Direction: East Date/Time: May 24, 2023 / 9:48 a.m. EDT 3: P5240023 Description: Truck wash runoff into the sewer manhole on Water Street Location: Water Street, near concrete loading station Camera Direction: East Date/Time: May 24, 2023 / 9:48 a.m. EDT 6 4: P5240024 Description: Runoff of water used to spray the concrete trucks, and location of where stormwater monitoring samples are taken. Location: Water Street, near the concrete loading station Camera Direction: Southwest Date/Time: May 24, 2023 / 9:51 a.m. EDT 5: P5240025 Description: Sand pile behind concrete blocks Location: Stockyard Camera Direction: Southwest Date/Time: May 24, 2023 / 9:54 a.m. EDT 7 6: P5240026 Description: Stockyard and material conveyor belt Location: Stockyard Camera Direction: Southwest Date/Time: May 24, 2023 / 9:57 a.m. EDT 7: P5240027 Description: Barge dock platform on the Ohio River with scraps of sand and gravel material Location: Barge dock Camera Direction: South Date/Time: May 24, 2023 / 10:03 a.m. EDT 8 8: P5240028 Description: Ramp leading down from stockyard to barge loading platform Location: Barge dock Camera Direction: Northeast Date/Time: May 24, 2023 / 10:04 a.m. EDT 9: P5240029 Description: Corner containing piles of material spilled from the conveyor belt. Ohio River in background behind trees. Location: Conveyor belt spillage corner Camera Direction: East Date/Time: May 24, 2023 / 10:11 a.m. EDT 9 10: P5240030 Description: Spillage corner overlooking the Ohio River Location: Conveyor belt spillage corner Camera Direction: Southwest Date/Time: May 24, 2023 / 10:12 a.m. EDT 11: P5240031 Description: Edge of spillage corner directly above the Ohio River Location: Conveyor belt spillage corner Camera Direction: South Date/Time: May 24, 2023 / 10:13 a.m. EDT 10 12: P5240032 Description: Scrap material along Southern edge of Facility directly above the Ohio River Location: Stockyard Camera Direction: South Date/Time: May 24, 2023 / 10:20 a.m. EDT 13: P5240033 Description: Scrap material along southern edge of Facility directly above the Ohio River Location: Stockyard Camera Direction: West Date/Time: May 24, 2023 / 10:20 a.m. EDT 11 14: P5240034 Description: Edge of stockyard Location: Stockyard Camera Direction: East Date/Time: May 24, 2023 / 10:23 a.m. EDT 15: P5240035 Description: Unknown outfall near southwest corner of Facility Location: Southwest corner of Facility, downhill from stockyard on the Ohio River Camera Direction: South Date/Time: May 24, 2023 / 10:30 a.m. EDT 12 16: P5240036 Description: Mixer truck rinse water Location: Mixer truck rinse station Camera Direction: Northwest Date/Time: May 24, 2023 / 10:36 a.m. EDT 17: P5240037 Description: Truck wash runoff entering storm drain Location: Water Street Camera Direction: West Date/Time: May 24, 2023 / 10:41 a.m. EDT 13