Document wKROm6ZxXqyVpBg3bZNvJ4GG6

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY MULTI-MEDIA COMPLIANCE EVALUATION INSPECTION Facility: Beelman River Terminals, Inc. - Chicago Facility NPDES Permit Number: ILR005489 - General Industrial Stormwater Permit - terminated October 25, 2017 Issued Permit IL0080123 - Beelman River Terminal Inc. never received Individual Permit Date of Inspection: May 1, 2023 U.S EPA Region 5 Representatives: Cheryl Burdett, Inspector Valerie Dooling, Inspector 312-886-1463 312-886-7167 State Representatives: No State Representative Facility Representatives: Fernando Gonzales, Loader/Operator 773-812-9786 Report Prepared by: Cheryl Burdett, CAFO Program Manager CHERYL Digitally signed by CHERYL BURDETT Inspector Signature: _B_U__R_D__E_T__T____14_:5_7:_24_-0_5'_00_' ________________________________ Date: 2023.06.27 Approver Title: Ryan Bahr, Section 2 Supervisor, Water Enforcement and Compliance Assurance Branch Digitally signed by RYAN RYAN BAHR Date: 2023.06.27 BAHR Approver Signature/Date: _____________1_5_:31_:5_8_-0_5'0_0_' ________________________________ Background: This report is based on information supplied during, prior, and after the on-site inspection by representatives of Beelman River Terminals, Inc. (Beelman River Terminal) Illinois Environmental Protection Agency and direct observations made by the U.S. EPA Region 5 inspectors including: photographs taken by U.S. EPA Region 5 inspectors, physical evidence (sampling) collected by the U.S. EPA Region 5 inspectors, verbal or written statements made by Beelman River Terminal representatives during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the U.S. EPA Region 5 inspectors. The Facility discharges into the Calumet River, a traditional navigable waterway. 1 Interview: I, U.S. EPA Region 5 Lead Inspector, Cheryl Burdett, arrived at Beelman River Terminal located at 3020 East 104th Street Chicago, Illinois 60617 at approximately 10:00 a.m. on May 1, 2023 for an unannounced NPDES Industrial Stormwater Inspection. I was joined by U.S. EPA inspector Valerie Dooling. We introduced ourselves and presented our credentials to Mr. Fernando Gonzales. I informed him that this was a U.S. EPA Region 5 Industrial Stormwater inspection to investigate elements of the Clean Water Act (CWA) and their National Pollutant Discharge Elimination System (NPDES) permit. The inspection was conducted under the authority of the CWA NPDES permit program and Section 308 of the CWA. I explained Confidential Business Information (CBI) and asked that if during the inspection if Beelman River Terminal determines that any information or photographs obtained by U.S.EPA Region 5 meets the criteria as CBI to inform U.S. EPA Region 5 either during the inspection or after they receive the inspection report. We asked questions to Mr. Gonzales from the Industrial User Industrial Storm Water Inspection checklist. Mr. Gonzales stated that his title was Loader/Operator for Beelman River Terminal. We asked where the main office for Beelman River Terminal was located, which he stated was in St. Louis, Missouri. We asked Mr. Gonzales what role Rock Salt USA had with this Facility. Mr. Gonzales stated that salt stored onsite was from Rock Salt USA, owned by Cargill. The salt is brought in on barges (not owned by Cargill) where it is transported off the barges by a conveyor system to a big pile on a concrete pad located at Beelman River Terminal 3020 E 104th Street Chicago, Illinois 60617. Beelman River Terminal also stores green salt, which has a green coloring added and used for deicing and is stored in the warehouse on-site. Beelman River Terminal uses trucks to move the green salt into the warehouse. According to Mr. Gonzales, this site receives 2-3 shipments, approximately 300,000 tons of salt per year. We asked if they had a National Pollutant Discharge Elimination System (NPDES) permit. Mr. Gonzales thought they had a permit for this site but did not have the Permit on-site. Mr. Gonzales did not know if the NPDES Permit was an Individual or General Permit. Mr. Gonzales stated that they do not keep any records at this site and did not know the Facility's SIC/NACS code. We asked if there is any maintenance done onsite and Mr. Gonzales stated there is no vehicle maintenance done on-site. The site does not have any water sources or drains on-site. According to Mr. Gonzales, there are two designed Outfall points where stormwater surface flows to the north and discharges into the Calumet River. According to Mr. Gonzales , he conducts visual inspections looking for oil and grease when it rains. Mr. Gonzales stated that he collects samples that he thinks are analyzed for oil and grease at the two designed Outfall points once per year during rain events. Mr. Gonzales did not know the name of the laboratory where the samples are taken to and did not have the sampling information, such as chain of custodies or results at this site. 2 Walkthrough: After going through the checklist, we started the walk-through with Mr. Gonzales. We went first into the warehouse with Mr. Gonzales where the green salt was stored. According to Mr. Gonzales, the salt comes in green and is used for deicing. We observed the green salt and observed puddles of green liquid from the salt (photographs RIMG0236 through RIMG0238). Mr. Gonzales had stated there are no drains in the warehouse (photographs RIMG0237 and RIMG0238). We asked Mr. Gonzales about the barrels in the warehouse. Mr. Gonzales stated that they store new and used oil in the barrels within the warehouse (photographs RIMG0239 through 241). We walked with Mr. Gonzales out of the warehouse to the north side of the warehouse where we observed a large excavator (photograph RIMG0235) which in the past was used to move salt off the barges. According to Mr. Gonzales, salt is now moved off of the barges using a conveyor system. At the northwest corner of the Facility, we observed a pile of sand and crushed limestone. The sand is used to keep the tarp down over the large salt pile and the crushed limestone for the berm along the Calumet River on the north and east sides of Facility to prevent stormwater from discharging into the Calumet River (photograph RIMG0243), except at designed Outfalls 01 and 02. We observed that the area behind where the crushed limestone was stored had a stormwater pathway into the Calumet River (photographs RIMG0244 and RIMG0245). We continued with Mr. Gonzales walking east along the north side of the Facility along the Calumet River. We observed the crushed limestone berm and seawall along the north side of the Facility. We observed that the majority of the large salt pile was covered under a tarp that was held down by sand (photographs RIMG0246 through RIMG0248). We observed that prior to outfall 01 - West Drain there was a discharge from Beelman River Terminal into the Calumet River from an area that was not identified by Mr. Gonzales as a designed Outfall point (photographs RIMG0205 through RIMG0209). We continued to walk with Mr. Gonzales along the north side of the Facility to the east where we observed flow from the north side of the large salt pile and the uncovered salt piles across the concrete pad discharging at the designed Outfall 01 - West Drain (photographs RIMG0230 through RIMG0234) and designed Outfall 02 - East Drain (photographs RIMG0210 through RIMG0213). We observed that three areas along the north side of the Facility were discharging into the Calumet River, at the time of the inspection. We continued with Mr. Gonzales to walk the perimeter of Beelman River Terminal along the east side of the Calumet River where we observed holes within the seawall. In areas where there were cracks and holes within the seawall, we observed that the crushed limestone berm was eroding into the crack of the seawall and into the Calumet River (photographs RIMG0217 through RIMG0221). We continued walking along the east side of the Facility along the berm and observed pooling on the inside of the crushed limestone berm. We observed exposed salt east of the large salt pile. We turned and walked on the south side of the Facility with Mr. Gonzales to the west toward the exposed face of the large salt pile and the open piles of the salt. We started walking back to the check-in area with Mr. Gonzales at the southwest side of the Facility and observed the scale (photograph RIMG0249). There is a drain that conveys flow to the south side of the facility. The Facility has put up concrete blocks to contain runoff and 3 materials from leaving the site and prevent run-on from the adjacent site. We explained to Mr. Gonzales on our way back to the check-in area that we were going to collect samples. Mr. Gonzales stated that he would like to split samples. We went back to our vehicle to prepare bottles for sampling for both the Facility and U.S. EPA Region 5. Mr. Gonzales had stated that we could drive our vehicle back to the sampling locations. We collected our first sample on the north side of the Facility west of Outfall 01, which Mr. Gonzales did not identify as a designed Outfall. We collected samples and labeled it S02Runoff Site. The sample results from S02- Runoff Site showed that pollutants were discharging into the Calumet River (photographs RIMG0205 through RIMG0209). During the collection of the first sample S02 - Runoff Site, we had an accident with the camera and had to retake all the photographs that we had previously taken on the walk-through of the Facility prior to collecting samples. We had a second camera which we used to retake the photographs of the areas of the Facility during the walk-through and of where we collected sample S02-Runoff Site. The second camera did not have the correct timestamp on the photographs. The photographs were taken an hour later than what was timestamped on the photograph. Also, the photographs of the walk-through do not coincide with the description of the walk-through written above. We continued to walk east along the north side of the Facility and were told by Mr. Gonzales that the West Drain is Outfall 01, a designed outfall point. We observed that there was a discharge into the Calumet River We walked past Outfall 01- West Drain and observed Outfall 02 - East Drain. We observed that there was discharge from designed Outfall 02 - East Drain. We collected samples from Outfall 02-East Drain and labeled the samples as S01- East Drain (RIMG0210 through RIMG0213). The sample results from the samples labeled S01- East Drain showed that pollutants were being discharged into the Calumet River. We observed that the face of the salt to the east was exposed and east of the large pile of salt was more salt that was uncovered (RIMG0214 and RIMG0215). During the inspection, precipitation was coming into contact with the uncovered salt and the exposed face of the large pile of salt. (RIMG0214 and RIMG0215). We walked back to the west along the north side of the Facility to Outfall 01 - West Drain. We observed that there was discharge from Outfall 01 - West Drain into the Calumet River. We collected samples from Outfall 01- West Drain and labeled the samples as S03 - West Drain. The sample results from samples labeled S03-West Drain showed pollutants were being discharged into the Calumet River. We went back to the vehicle to preserve our samples and the Facility's samples. We also wrote up the chain of custody for us and the Facility's samples. 4 Exit Briefing: We asked the Facility to choose their set of samples and provided them with a chain of custody. We explained that we would follow-up with an email that was provided by Mr. Gonzales during the interview to get further information on the operation of the Facility and their permit. It was unclear if the Facility had a General or Individual Permit. We explained that without the Permit and SWPPP we were not aware of what the Facility should be doing, so we did not discuss areas of concern. We did explain that the Facility is required to have their permit and documents required by their permit on-site readily available. I sent an email with a list of documents required by Beelman River Terminal's General NPDES Permit ILR005489. I was contacted by phone by Rita Buechter, Engineer, BHMG Engineers, Inc. (previously Hastings Engineering, Inc.) on June 12, 2023 stating that Beelman River Terminal was informed by Illinois EPA that it should not be covered under a General Industrial Stormwater NPDES permit and should apply for an Individual Permit. Illinois EPA sent me the letter that Illinois EPA sent to Beelman River Terminal on August 23, 2017 that read that the facility is required to obtain an Individual NPDES Permit. Ms. Buechter, BHMG Engineers, Inc. sent me an email with the Individual Permit Application for Beelman River Terminal. Illinois EPA sent me a form that showed that Beelman River Terminal's General Permit was terminated on October 25, 2017. It was changed to an individual permit on October 25, 2017 and documented as permit Number IL0080123. Hasting Engineering, Inc. submitted samples on behalf of Beelman River Terminal in support of its Individual NPDES Permit ILA0080123. Hastings Engineering, Inc. collected samples and had them analyzed by PDC Laboratory for Outfall 01 and Outfall 02. Ms. Buechter stated that they have never received a copy of the Individual Permit and that they have emailed and phoned Illinois EPA to determine the status of their Individual Permit application. According to Ms. Buechter, they have not been following any permit or updating or following a SWPPP, since they have never received their Individual Permit from Illinois EPA and their General Permit was terminated. Information Supplied to After U.S. EPA REGION 5 May 1, 2023 Inspection 1. Illinois EPA provided EPA with the following documents by email on May 10, 2023 dates: o Attached "Beelman inspection.pdf" Illinois Environmental Protection Agency DWPC/FOS Industrial Storm Water Inspection on July 28, 2016 for the site located at 10443 South Muskegon Avenue Chicago, Illinois. o Attached "Beelman termination file. pdf Illinois Environmental Protection Agency General NPDES Permit -Beelman River Terminal-Chicago Facility General NPDES Permit No. ILR005489 Permit Coverage Determination - Individual NPDES Permit Required. Stamped August 23, 2017. Illinois Environmental Protection Agency-Notice of Renewal General Storm Water Permit for Industrial Site Activities - ILR005489. Stamped July 6, 2017. Illinois Environmental Protection Agency Division of Water Pollution Control Notice of Intent (NOI) for General Permit to discharge Storm Water Associated with 5 Industrial Activity (Excluding Construction Activity) - Beelman River TerminalChicago Facility Permit renewal. Stamped on October 8, 2013. Beelman River Terminals Notice of Intent for General Permit to Discharge Storm Water Associated with Industrial Activity at Beelman River Terminal - Chicago Facility City of Chicago, Kane County, Illinois. Stamped on October 8, 2013. o Attached "Beelman permit file.pdf" Letter Received by Illinois EPA on 9/30/1996 from Hastings Engineering, Inc with the following attachments: Stormwater Discharge Permit Application for Beelman River Terminals, Inc. Notice of Intent for General Permit Coverage General Form 1 USEPA NPDES Form Form 2F, USEPA NPDES Form Illinois Environmental Protection Agency Stormwater Permit Review Notes dated October 1, 1996 Attached Form 2F NPDES Permit Application for Permit to discharge Storm Water Discharges Associated with Industrial Activity signed by Sam Beelman, President July 7, 2011. Initial Permit Approval: 9/27/1996; Termination: 10/25/2017; Other: Changed to Individual Permit 10/25/2017 o Attached document "Beelman doc 1. Pdf Discharge Information - Sampling Results for Outfall 01 Discharge Information - Sampling Results for Outfall 02 PDC Analytical Results for Samples collected on 4/19/2018 and received on 4/20/2018 and chain of custodies. 2. Illinois EPA provided U.S. EPA REGION 5 with the following documents by email on May 23, 2023 dates: o Illinois Environmental Protection Agency sent an email with the following website to obtain the NPDES Permit for Beelman River Terminals -Chicago Facility - https://epa.illinois.gov/topics/forms/water-permits/storm-water/general-permits.html o Attached the "searchable 2017 ILRPermit.pdf" 3. Rita Buechter, rbuechter@bhmg.com BHMG Engineering, Inc. submitted the following documents by email on June 12, 2023: o 2017019002.pdf Letter from Beelman River Terminals to Illinois Environmental Protection Agency - RE: Beelman River Terminal-Chicago Terminal NPDES Permit Coverage dated October 19, 2017. Form 1 General - EPA General Information Form 2F NPDES - EPA Application Permit to Discharge Storm Water Discharges Associated with Industrial Activity signed by Frank Beelman III on October 19, 2017. o 05112018 Analysis Submission.pdf From Hastings Engineering, Inc. to Illinois Environmental Protection Agency to Illinois Environmental Protection Agency - Laboratory Analysis for stormwater samples collected 6 in support of the application submitted to obtain an individual NPDES permit for Beelman River Terminal - Chicago Terminal. o 2017 Beelman Chicago SWPPP.pdf Areas of Concern: During the exit briefing, we explained to Mr. Gonzales that they should be keeping records required by their NPDES permit on-site. After reviewing the following information submitted to me by Ms. Buechter and Illinois EPA, I have the following concern: EPA observed discharges from three separate areas from the site into the Calumet River. Beelman River Terminals, Inc. did not have their NPDES permit on-site during the inspection. Beelman River Terminals, Inc did not have their SWPPP on-site during the inspection. BHMG Engineers, Inc sent to EPA by email on June 12, 2023, an outdated SWPPP for Beelman River Terminals, Inc. Chicago, Illinois. It was prepared by Hastings Engineering, Inc. St. Louis, Missouri dated January 2017. 7 Name of Site S01 S02 West Drain S03 B01 Table 1: Sampling Data Location Total Total Suspended Dissolved Solids Solids East 48 mg/L 38400 Drain mg/L (Outfall 01) West 346 mg/L 5340 Runoff mg/L Location West 410 mg/L 46600 Drain mg/L (Outfall 02) U U Calcium 217 mg/L 16.2 mg/L 227 mg/L U Magnesium 11.7 mg/L 40.2 mg/L 14.2 mg/L U Potassium 12.1 mg/L U 16.9 mg/L U Sodium 11900 mg/L 2010 mg/L 17300 mg/L U Chloride 21200 mg/L 3170 mg/L 27400 mg/L U Sulfate 549 mg/L 182 mg/L 389 mg/L U 8