Document x0pppE7Rw9qY1nbMGgmLa7Z1

EPA Region 5: Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date: Time: Media: Statute (s)/Program(s): Type of inspection: Access: February 22, 2023 Inspection Announced: No Entry: 10:05 AM Exit: 3:50 PM Wastewater and Stormwater Clean Water Act, NPDES, Industrial Stormwater, Direct Discharger Clean Water Act, NPDES, Pretreatment, Indirect Discharger CEI - Compliance Evaluation Inspection Granted Permittee Name: Facility or Site Name: Facility/Site Physical Address: (City, State, Zip Code) County/Parish: Caterpillar, Inc. Caterpillar, Inc. - Pontiac, IL 1300 4-H Park Road Pontiac, Illinois 61764 Livingston County Permit Numbers: SIC or NAICS: 2022-EP-67798; ILR006863 3519 Flatebo, Theodore Date: 2023.04.06 11:54:58 -05'00' Digitally signed by Flatebo, Theodore Inspector Signature and Date:_________________________________________________ Approver Name and Title: Ryan J. Bahr, Section 2 Supervisor Water Enforcement and Compliance Assurance Branch RYAN BAHR Digitally signed by RYAN BAHR Date: 2023.04.06 17:19:01 -05'00' Approver Signature and Date: ________________________________________________ Page 1 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 Persons Participating in Inspection: Organization/Title EPA, Environmental Engineer EPA, Physical Scientist IEPA, Environmental Protection Specialist IEPA, Environmental Protection Engineer IEPA, Environmental Protection Engineer Caterpillar, EHS Manager Caterpillar, EHS Manager Caterpillar, Facilities Engineering Manager Caterpillar, EHS Professional Caterpillar, EHS Professional Name Phone Email Present at Present at Opening Closing Conference Conference Ted Flatebo (312) 886-9402 flatebo.ted@epa.gov Yes Yes Matthew (312) 886-2405 schulte.matthew@epa.gov Yes Yes Schulte Jeffrey Holste (217) 278-5800 jeffrey.holste@illinois.gov Yes Yes Amelia Allen (217) 278-5800 amelia.allen@illinois.gov Yes Yes Chulgi Kim (217) 278-5800 chulgi.kim@illinois.gov Yes Yes Kevin Bennett (815) 842-6000 bennett_kevin_m @cat.com Yes Yes Robert Irwin (815) 842-6000 irwin.robert@cat.com Yes Yes Mark Andrews (815) 842-6000 andrews_mark_d@cat.com Yes No Caley Niday (815) 842-6000 caley.niday@cat.com Yes Yes Mackenzie (815) 842-6000 mackenzie.hickey@cat.com No Yes Hickey Page 2 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 TABLE OF CONTENTS SECTION I - INTRODUCTION ................................................................................................................................... 3 SECTION II - INSPECTION ........................................................................................................................................ 4 SECTION III - OBSERVATIONS ................................................................................................................................. 6 SECTION IV - RECORDS REVIEW ............................................................................................................................. 9 SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS.......................................................................... 13 SECTION VI - AREAS OF CONCERN ........................................................................................................................ 13 SECTION VII - CLOSING CONFERENCE .................................................................................................................. 19 SECTION VIII - LIST OF APPENDICES ..................................................................................................................... 19 SECTION I - INTRODUCTION Site Entry and Inspection Objectives United States Environmental Protection Agency (EPA) Inspectors Ted Flatebo and Matthew Schulte, accompanied by Illinois Environmental Protection Agency (IEPA) inspectors Jeffrey Holste, Amelia Allen, and Chulgi Kim, arrived at Caterpillar, Inc. (the Site or Facility), located at 1300 4-H Park Road, Pontiac, Illinois at 10:05 AM on February 22, 2023 for an unannounced inspection. The five inspectors, collectively referred to as the inspection team, parked their vehicles in the east parking lot and entered the Facility through the entrance in the northeast corner of the building. Mr. Flatebo approached the security desk and informed the security guard that the inspection team was at the Facility for an inspection and requested to speak to a Facility Manager or an EHS Manager. The inspection team waited in the building lobby until approximately 10:35 AM when the inspection team was escorted by Facility personnel to a conference room. The inspection team presented their individual credentials to site representatives Kevin Bennett, Robert Irwin, Mark Andrews, and Caley Niday. Mr. Flatebo informed the Facility representatives that this was an EPA Region 5 inspection to determine compliance with the Clean Water Act (CWA), the National Pollutant Discharge Elimination System (NPDES) permit program and Categorical Pretreatment regulations. The inspection was conducted under the authority of the CWA NPDES permit program and Section 308 of the CWA. The table above identifies the attendees who participated in the inspection. This report is based on information supplied by Facility representatives, observations made by the EPA inspectors, and records and reports maintained by the Facility, IEPA, and EPA. These include the following: direct observations made by the EPA inspectors, photographs taken by EPA inspectors, and verbal or written statements made or supplied by Facility representatives during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA inspectors by Facility 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, IEPA, and public records may be Page 3 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 included in this report. During the opening conference, facility representatives were asked if they considered any information confidential business information (CBI). Mr. Bennett stated no information was considered CBI. Background Information The inspection team conducted an opening conference with Facility representatives, beginning at approximately 10:40 AM. The team gathered the following Facility information: Caterpillar, Inc. (Caterpillar) began operations at the Facility in 1978. The Facility was previously owned and occupied by another company before Caterpillar took procession of it. The property covers approximately 100 acres with approximately 879,605 ft2 of interior space. The Facility produces fuel system components, including fuel injectors, fuel pumps, and exhaust after treatment components. Operations performed include machining, grinding, heat treatment, and welding. The Facility operates 24 hours a day, 7 days a week and employs approximately 700 Caterpillar employees and approximately 700 contractors. Process wastewater generated at the Facility is covered by IEPA Water Pollution Control Permit No. 2022-EP67798. The effective date of the permit is November 28, 2022, and the permit is scheduled to expire on October 31, 2027. The Permit identifies that the Facility is subject to metal finishing point source categorical pretreatment standards (40 C.F.R. 433). Process wastewaters generated at the Facility include, but are not limited to: water-based coolant waste, deionized water, reverse osmosis water, wash tanks, cooling towers, boilers, parts wash water, quench tank wastewater, oily mop water, and metal coloring wastewater. After use, all of these process wastewaters are sent to the Facility wastewater treatment system and effluent is discharged through a single Outfall to the City of Pontiac (City) combined sewer collection system for treatment at the City's wastewater treatment plant. Sanitary wastewater is discharged directly to the City's combined sewer without treatment. Stormwater generated at the Facility is covered by IEPA National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharged from Industrial Activities (Stormwater General Permit) number ILR006863. The effective date of the permit is April 5, 2017 and it was scheduled to expire on March 31, 2022. IEPA administratively extended the Stormwater General Permit, and it was in effect on the date of the inspection. The Facility's Storm Water Pollution Prevention Plan (SWPPP) identifies two stormwater Outfalls. Both Outfalls discharge to the North Creek, which runs along the Facility's southeast property line. North Creek is a tributary to the Vermilion River. SECTION II - INSPECTION The opening conference concluded at approximately 11:25 AM. Afterwards the inspection team began the Facility walk through while accompanied by Mr. Bennett and Mr. Irwin. Below is a general description of the walk through. Specific observations are documented in Section III of this report. Page 4 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 Interior Manufacturing Area The Facility walk through began in the interior manufacturing area. Parts move through a variety of production steps including machining, grinding, welding and heat treatment. Parts then undergo a quality control inspection before they are shipped to another Caterpillar facility for further processing. At various stages in the process, the parts do come into direct contact with water. Examples include water-based coolants used in the machining phase and water in the parts washers. Additional manufacturing processes include blasting the surface of parts utilizing using glass beads, which is a dry process. Both gas-based and oil-based quenching is also conducted at the Facility. All wastewater generated at the Facility is sent to the vault in the basement level for holding until it can be transferred to the wastewater treatment system. Spent coolant is directed to the wastewater treatment system through a pumping system that bypasses the vault. There are approximately five floor drains in the manufacturing area that lead to the vault. These drains function as dump stations for employees to dispose of mop water and various other waste waters as they are generated. Wastewater Treatment System Following the walkthrough of the manufacturing area, the inspection team proceeded to the wastewater treatment system. The treatment system is located both indoors and outdoors at the southern end of the Facility. All process wastewater generated is sent to a vault before it is pumped to the Facility's wastewater treatment system. Oil is decanted from the vault as an additional pretreatment step. The treatment system discharges effluent through a single Outfall to the City of Pontiac's (City) combined sewer collection system. Sanitary waste is discharged directly to the City's collection system. The wastewater treatment system is composed of holding tanks, chemical mixing tanks, flocculation tanks, a dissolved air floatation (DAF) system, sludge pit, and a centrifuge. See Pretreatment Diagram in Appendix 2. The wastewater treatment system operates on a batch treatment process. The Facility contracts out the operation of the treatment system to four operators. Two of the four operators hold IEPA Class K wastewater operator certificates. During the inspection, the inspection team spoke to certified operator Jesse Ranta about the operation of the treatment system. Mr. Ranta walked the treatment train and explained his sampling protocols. Stormwater After inspecting the wastewater treatment system, the inspection team continued outdoors to observe the stormwater best management practices (BMPs) and the stormwater Outfalls. The Facility has developed a site-specific Stormwater Pollution Prevention Plan (SWPPP). The SWPPP reviewed by Mr. Flatebo was revised on Oct. 28, 2022. During the opening conference Ms. Niday explained that Caterpillar utilizes a contractor to perform most of its Stormwater General Permit compliance activities such Page 5 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 as routine expectations and sampling. Stormwater BMP inspections are conducted on a weekly, monthly, and annual basis. Ms. Niday stated that she joins the contractor, at minimum, during the monthly inspection. The United States Geological Survey (USGS) rain gage in the Vermilion River in Pontiac, Illinois measured 0.61 inches of rain between 3:00 AM and 3:00 PM on February 22, 2023. Stormwater that falls on the Facility is conveyed by gravity to one of two oil-water separators before it is discharged to an Outfall into the North Creek. The inspection team observed the Facility while it was raining and observed both stormwater Outfalls actively discharging. The inspection team observed a sheen on a stormwater flow within the Facility. Additionally, the inspection team observed a large pit dug immediately north to the fire suppression system water storage tanks located at the south end of the Facility. Mr. Irwin explained that the pipes that supply the tanks were leaking and were in the process of being repaired. Mr. Flatebo observed the pipes actively leaking at a rate of approximately 10 gallons per minute. There was a sump pump placed in the pit that was collecting the leaked water and discharging it into the stormwater conveyance system. See Photo 18. Categorical Pretreatment Standards IEPA permit 2022-EP-67798 identifies discharges from the Facility as subject to metal finishing point source categorical pretreatment standards found in 40 C.F.R. 433. The Facility submitted a permit renewal application to IEPA on Aug. 1, 2022 in which the Facility also identified that they were subject to the metal finishing point source categorical pretreatment standards. In an email sent on March 16, 2023, Mr. Flatebo requested Mr. Bennett to provide additional information on what processes the Facility conducts that would be subject to the metal finishing point source categorical pretreatment standards. On March 31, 2023, Mr. Bennett provided a response indicating that the Facility performs a cold black oxide coating process. See further information in the observations section. SECTION III - OBSERVATIONS Observations may not be in sequential order. Page 6 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 Unique Identifying No. TF-OB-001 TF-OB-002 TF-OB-003 TF-OB-004 TF-OB-005 TF-OB-006 TF-OB-007 TF-OB-008 Observation Water-based coolants are generated on site from potable water purchased from the local water utility and a coolant concentrate. There is a well located within the Facility boundaries, but according to Mr. Bennett it has not been in use for a few years. When the coolant is spent, it is piped to one of a few coolant filtering machines located throughout the manufacturing floor. The coolant is filtered and piped back into individual machines for further use. The wastewater generated by the filtering machines is manually transferred to the vault in the basement level for holding until it can be processed by the wastewater treatment system. See Photo 1. The Facility has a single flow meter located on site. This is a flow meter used to measure potable water purchased from the water utility. Ms. Niday stated that according to the Facility's water bills, the Facility consumes approximately 2,500 - 3,000 gallons of potable water per hour. There are no additional flow meters used within the manufacturing process and the Facility could not provide detailed historical average flow rates for individual processes. On the manufacturing floor there is designated areas for oil storage and a designated area for additional liquid chemical storage. These areas are both surrounded by a berm that provides secondary containment in the event of a spill. The storage areas were observed to be at capacity and chemicals/oil were stored immediately outside the berm area and did not have secondary containment. See Photo 5. The oil quench tanks produce a wastestream. A pipe was observed discharging from each oil quench tank to a small floor drain for that individual tank. According to Mr. Bennett, the wastewater is directed to the wastewater treatment system. See Photo 7. A 55-gallon drum of Cynamic Alti-Mate 64, a disinfecting agent, was observed to be stored immediately on top of a floor drain leading to the wastewater treatment system. See Photo 10. In the wastewater lab area, Mr. Ranta showed the inspection team a FMC liquid sampler. See Photo 14. Mr. Ranta explained this is the sampler used for composite effluent compliance sample collection. The sampler collects samples based on a time interval, not a flow interval. The sampler has a builtin refrigeration system. There was no thermometer in the sampler and Mr. Ranta was unable to provide a temperature log. Mr. Ranta explained that grab effluent compliance samples are collected from the north end of the dissolved air floatation tank (DAF) when it is actively discharging. The DAF effluent is sent to outdoor Tank 3 for holding before it is discharged to the City's combined sewer collection system. Area of Concern? No No Yes Yes No Yes Yes No Page 7 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 TF-OB-009 Mr. Ranta stated that the wastewater treatment system utilizes multiple pH No adjustment steps to aid in the treatment process. These steps are accomplished through the use and monitoring of pH probes within treatment tanks. Mr. Ranta stated that there is no process for calibrating the internal pH probes. TF-OB-010 The metal finishing point source categorical pretreatment standard found in 40 No C.F.R. 433 is applicable to facilities that perform one or more of six core operations. One of those operations is coatings, including metal coloring. The Facility's August 2022 permit application submitted to IEPA identified that the Facility is subject to the metal finishing point source pretreatment standards. Additionally, in an email sent to Mr. Flatebo on March 31, 2023, Mr. Bennett identified that the Facility performs cold black oxide coating. If a facility performs one or more of the six core operations, the wastewater generated by those operation(s) is subject to the pretreatment standards as well as any wastewater generated by the auxiliary operations identified in the regulation. The Facility performs multiple auxiliary operations, including but not limited to: cleaning, machining, grinding, burnishing, heat treating, welding, and electrochemical machining. TF-OB-010 All process wastewater generated at the Facility is directed to the wastewater Yes treatment system. This includes wastewater generated by metal finishing point source categorial processes as well as non-categorical waste streams such as boiler blow down, cooling tower blowdown, and reverse osmosis reject water. Wastewater is also introduced into the treatment system via the approximately 5 dump stations located in the manufacturing areas. See Photo 4. The Facility does not have an approved combined wastestream formula that would provide new effluent limits which account for the dilution by non- categorical wastestreams. TF-OB-011 A sheen was observed in stormwater runoff between the Manufacturing 1 and Yes wastewater treatment areas. See Photo 11. TF-OB-012 Turbid stormwater runoff was observed in the gutter immediately east of the Yes fire suppression system water storage tanks. See Photo 19. TF-OB-013 Stormwater Outfall 002 and Outfall 003 were observed discharging during the Yes inspection. Both outfalls were discharging water which was discolored and the water immediately downstream of the outfalls was discolored compared to upstream. See Photos 20, 21, 24, and 25. TF-OB-014 Stormwater was observed flowing under the Facility fence line and towards Yes the North Creek in two places between Outfall 002 and Outfall 003. Per the Facility's SWPPP, the two afore mentioned outfalls are the only two locations where stormwater discharges are monitored. See Photos 23, 26, and 27, Page 8 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 TF-OB-015 A pipe was observed in the northeast corner of the tank farm at the Facility. Yes The pipe had stormwater flowing into it. TF-OB-016 Softball size chunks of road salt were on the ground in the immediate vicinity Yes of a salt application truck. See Photo 28. TF-OB-017 Road salt is stored at the Facility within a covered shed immediately south of No the wastewater treatment area. SECTION IV - RECORDS REVIEW Records may not be in sequential order. Unique Identifying No. TF-RR-001 Record Water Pollution Control Permit Renewal Application - Dated Aug. 1, 2022 This application was submitted to IEPA in order to renew Permit No. 2017-EP62654. The application was submitted more than 90 days from the permit expiration date as required by IEPA. The application identifies the Facility's Standard Industrial Classification (SIC) Code as 3519 - Internal Combustion Engines, Not Elsewhere Classified and its North American Industry Classification System (NAICS) Code as 33618 - Other Engine Equipment Manufacturing. TF-RR-002 The application also identifies that the Facility is subject to the Metal Finishing Point Source Category in 40 CFR 433. Waste Treatment Plant Wastewater Collection Flow Diagram, Page 21 of Water Pollution Control Permit Renewal Application - Dated July 2022 The diagram depicts the wastewater sources generated at the Facility and which treatment system each wastestream is directed towards. Examples of wastestreams identified include: -Wash and Phosphate System (1 unit) -Heat Treat Washer (1 unit) -Tumbler (7 units) -Sonic Degreaser (2 units) -Zinc Phosphate Line (1 unit) -Zinc Plating Line (1 unit) The diagram indicates there are two treatment systems: Area of Concern? No Yes Page 9 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 Unique Identifying No. TF-RR-003 TF-RR-004 TF-RR-005 Record -Oil Waste Treatment System (oily flows) - Discharges to the City of Pontiac Sanitary Treatment Plant. Estimated 100,380 GPD average flow. -Heavy Metals Treatment System (plating flows) - Discharges to the Vermillion River. Estimated 197,080 GPD average flow. Area of Concern? During the inspection, the inspection team did not observe a heavy metals treatment system or the presence of a Zinc Phosphate Line or a Zinc Plating Line In an email sent to Mr. Flatebo on March 31, 2022, Mr. Bennett clarified that Yes the Waste Treatment Plant Wastewater Collection Flow Diagram referenced in TF-RR-002 is incorrect and that the Facility does not have a heavy metals treatment system and the Facility does not have a zinc phosphate line or a zinc plating line. Annual Facility Site Inspection - Dated Nov. 25, 2021 Yes The annual comprehensive site inspection, conducted on Oct. 21, 2021, does not state whether Outfall 002 and Outfall 003 were discharging at the time of the inspection. In a weekly visual inspection conducted on Nov. 24, 2020, a "light sheen" was observed at Outfall 002. The document states that no corrective action was required. The inspection reports in this annual filing do not include observations of the two stormwater oil-water separators and if they are full or in need of servicing. Water: Monthly Totals - Document Not Dated Yes The document provides monthly total of flows through processes that utilize water. It is unclear the source of the information. Flows provided include: Potable Water Entering Facility: 4.44 million gallons Effluent from Wastewater Treatment: 2.40 million gallons Reverse Osmosis Influent: 1.94 million gallons Reverse Osmosis Reject: 0.72 million gallons This flow diagram does not align with the Waste Treatment Plant Wastewater Collection Flow Diagram on Page 21 of Water Pollution Control Permit Renewal Application. This diagram indicates that cooling tower blowdown and reverse osmosis reject water bypasses the wastewater treatment system. The Waste Treatment Plant Wastewater Collection Flow Diagram indicate that Page 10 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 Unique Identifying No. TF-RR-006 TF-RR-007 Record cooling tower blowdown and reverse osmosis reject are directed to the Heavy Metals Treatment System. Area of Concern? See Appendix 3. IEPA Water Pollution Control Permit No. 2022-EP-97798 - Date Issued Nov. 28, No 2022. This permit places a variety of requirements on the Facility, including: -Effluent limits from 40 CFR 433 - Pretreatment Standards for Existing Sources; -Annual sampling requirement; and -Sampling reporting requirements for both IEPA and EPA. The permit also specifically states that the permittee is subject to the Federal Pretreatment standards and regulation, including 40 C.F.R. 403 and that the effluent limit "...numbers do not reflect a reduction in the numerical limitation due to the contributing flows of sanitary wastes, non-contact cooling water, and other dilution wastewaters not regulated..." 2020 Annual Wastewater Sampling Report - Dated March 1, 2021 Yes The report contains a cover letter and two analytical reports from PDC Laboratories. The first report is dated June 16, 2020 and the second is dated December 22, 2020. Both reports contain wastewater analytical results and a chain of custody. The analytical results indicate that there were not effluent limit violations as compared to limits stated in Permit No. 2017-EP-62654. The analytical reports include pH values as analyzed by PDC Laboratory personnel. A field pH value, analyzed within 15-minutes of grab sample collection, was not provided. Both chains of custody indicate that grab and composite samples were collected. The chains of custody do not indicate how many bottles were used to collect samples, the material of the bottles used, the preservation method for each sample bottle, the start or stop time of the composite sample, and what sample type was used for each analyte. The cover letter of the report was signed by Caley Niday, Caterpillar employee whose title is EHS Professional. Page 11 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 Unique Identifying No. TF-RR-008 TF-RR-009 TF-RR-010 Record 2021 Annual Wastewater Sampling Report - Dated May 4, 2022 The report contains a cover letter and two analytical reports from PDC Laboratories. The first report is dated May 28, 2021 and the second is dated December 30, 2021. Both reports contain wastewater analytical results and a chain of custody. The analytical results indicate that there were not effluent limit violations as compared to limits stated in Permit No. 2017-EP-62654. The analytical reports include pH values as analyzed by PDC Laboratory personnel. A field pH value, analyzed within 15-minutes of grab sample collection, was not provided. Both chains of custody indicate that grab and composite samples were collected. The chains of custody do not indicate how many bottles were used to collect samples, the material of the bottles used, the preservation method for each sample bottle, the start or stop time of the composite sample, and what sample type was used for each analyte. The cover letter of the report was signed by Caley Niday, Caterpillar employee whose title is EHS Professional. Waste Water Treatment Work Instructions - Printed on April 23, 2012. The Records Section (Page 5) states that wastewater test sample records sheets should be shredded after one year of retention. Records should be maintained for at a minimum of 3 years. Stormwater Pollution Prevention Plan (SWPPP) - Revised on Oct. 28, 2022 The SWPPP does not contain a topographic map. The SWPPP's facility map is not legible. The stormwater pollution prevention team members do not have email addresses provided. The Facility discharges stormwater to North Creek, which is a tributary of the Vermilion River. The Vermilion River is impaired and has a Total Maximum Daily Loading as approved by IEPA. The SWPPP does not note the receiving water is impaired. The percent of impervious surfaces at the Facility is not identified. Area of Concern? Yes Yes Yes Page 12 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 Unique Identifying No. TF-RR-011 TF-RR-012 Record The pollutants expected to be present in stormwater discharge are not identified. Jeremiah Johnson has an IEPA Class K wastewater operator certificate - Dated Dec. 4, 2007. The Facility is subject to the metal finishing point source categorical pretreatment regulations found in 40 C.F.R. 433, therefore the general pretreatment regulations found in 40 C.F.R. 403 are also applicable. The general pretreatment regulations require categorical facilities submit periodic reports on continued compliance in June and December annually to the Control Authority. EPA Region 5 is this Facility's Control Authority. The Facility submitted reports to IEPA and EPA reports once annually, in May 2021 and May 2022. Semi-annual reports must be signed by someone who satisfies the pretreatment program signatory requirements. Area of Concern? No Yes SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No samples were collected as part of this NPDES inspection. SECTION VI - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Unique Identifying No. TF-OB-003 Record There are no additional flow meters used within the manufacturing process and the Facility could not provide detailed historical average flow rates for individual processes. TF-OB-004 40 C.F.R. 403.12(b)(4) On the manufacturing floor there is designated areas for oil storage and a designated area for additional liquid chemical storage. These areas are both surrounded by a berm that provides secondary containment in the event of a spill. The storage areas were observed to be at capacity with and chemicals/oil were stored immediately outside the berm area and did not have secondary containment. See Photo 5. 40 C.F.R. 112 Page 13 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 TF-OB-006 TF-OB-007 TF-OB-010 TF-OB-011 TF-OB-012 TF-OB-013 A 55-gallon drum of Cynamic Alti-Mate 64, a disinfecting agent, was observed to be stored immediately on top of a floor drain leading to the wastewater treatment system. See Photo 10. 40 C.F.R. 112 In the wastewater lab area, Mr. Ranta showed the inspection team a FMC liquid sampler. See Photo 14. Mr. Ranta explained this is the sampler used for composite effluent compliance sample collection. The sampler collects compliance samples on a time-proportional basis, not a flow proportional. 40 C.F.R. 403(g)(3) The sampler has a built-in refrigeration system. There was no thermometer in the sampler and Mr. Ranta was unable to provide a temperature log. 40 C.F.R. 136 All process wastewater generated at the Facility is directed to the wastewater treatment system. This includes wastewater generated by metal finishing point source categorial processes as well as non-categorical waste streams such boiler blow down, cooling tower blowdown, and reverse osmosis reject water. Wastewater is also introduced into the treatment system via the approximately 5 dump stations located in the manufacturing areas. See Photo 4. 40 C.F.R. 403.6(d) The Facility does not have an approved combined wastestream formula that would provide new effluent limits which account for the dilution by non-categorical wastestreams. 40 C.F.R. 403.6(e) A sheen was observed in stormwater runoff between the Manufacturing 1 and wastewater treatment areas. See Photo 11. Permit No. ILR006863 - Section H.1.d Turbid stormwater runoff was observed in the gutter immediately east of the fire suppression system water storage tanks. See Photo 19. Permit No. ILR006863 - Section H.1.d Stormwater Outfall 002 and Outfall 003 were observed discharging during the inspection. Both outfalls were discharging water which was discolored and the water immediately downstream of the outfalls was discolored compared to upstream. See Photos 20, 21, 24, and 25. Page 14 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 TF-OB-014 TF-OB-015 TF-OB-016 TF-RR-002 Permit No. ILR006863 - Section H.1.d Stormwater was observed flowing under the Facility fence line and towards the North Creek in two places between Outfall 002 and Outfall 003. Per the Facility's SWPPP, the two afore mentioned outfalls are the only two locations where stormwater discharges are monitored. See Photos 23, 26, and 27, Permit No. ILR006863 - Section F.f A pipe was observed in the northeast corner of the tank farm at the Facility. The pipe had stormwater flowing into it. Permit No. ILR006863 - Section G Softball size chunks of road salt were on the ground in the immediate vicinity of a salt application truck. See Photo 28. Permit No. ILR006863 - Section G Waste Treatment Plant Wastewater Collection Flow Diagram, Page 21 of Water Pollution Control Permit Renewal Application - Dated July 2022 The diagram depicts the wastewater sources generated at the Facility and which treatment system each wastestream is directed towards. -The diagram indicates there are two treatment systems: -Oil Waste Treatment System (oily flows) - Discharges to the City of Pontiac Sanitary Treatment Plant. Estimated 100,380 GPD average flow. -Heavy Metals Treatment System (plating flows) - Discharges to the Vermillion River. Estimated 197,080 GPD average flow. During the inspection, the inspection team did not observe a heavy metals treatment system or the presence of a Zinc Phosphate Line or a Zinc Plating Line. In an email sent to Mr. Flatebo on March 31, 2022, Mr. Bennett clarified that the Waste Treatment Plant Wastewater Collection Flow Diagram referenced in TF-RR-002 is incorrect and that the Facility does not have a heavy metals treatment system and the Facility does not have a zinc phosphate line or a zinc plating line. TF-RR-003 In an email sent to Mr. Flatebo on March 31, 2022, Mr. Bennett clarified that the Waste Treatment Plant Wastewater Collection Flow Diagram referenced in TF-RR-002 is incorrect Page 15 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 and that the Facility does not have a heavy mets treatment system and the Facility does not have a zinc phosphate line or a zinc plating line. TF-RR-004 TF-RR-005 Annual Facility Site Inspection - Dated Nov. 25, 2021 The annual comprehensive site inspection, conducted on Oct. 21, 2021, does not state whether Outfall 002 and Outfall 003 were discharging at the time of the inspection. Permit No. ILR006863 - Section G In a weekly visual inspection conducted on Nov. 24, 2020, a "light sheen" was observed at Outfall 002. The document states that no corrective action was required. Permit No. ILR006863 - Section H.h.1 The inspection reports in this annual filing do not include observations of the two-oil water separators and if they are full or in need of servicing. Permit No. ILR006863 - Section G Water: Monthly Totals - Document Not Dated The document provides monthly total of flows through processes that utilize water. It is unclear the source of the information. Flow provided include: Potable Water Entering Facility: 4.44 million gallons Effluent from Wastewater Treatment: 2.40 million gallons Reverse Osmosis Influent: 1.94 million gallons Reverse Osmosis Reject: 0.72 million gallons This flow diagram does not align with the Waste Treatment Plant Wastewater Collection Flow Diagram on Page 21 of Water Pollution Control Permit Renewal Application. This diagram indicates that cooling tower blowdown and reverse osmosis reject water bypasses the wastewater treatment system. The Waste Treatment Plant Wastewater Collection Flow Diagram indicates that cooling tower blowdown and reverse osmosis reject water are directed to the Heavy Metals Treatment System. In an email sent to Mr. Flatebo on March 31, 2022, Mr. Bennett clarified that the Waste Treatment Plant Wastewater Collection Flow Diagram referenced in TF-RR-005 is incorrect and that the Facility will work to update the diagram. Page 16 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 TF-RR-007 TF-RR-008 2020 Annual Wastewater Sampling Report - Dated March 1, 2021 The report contains a cover letter and two analytical reports from PDC Laboratories. The first report is dated June 16, 2020 and the second is dated December 22, 2020. Both reports contain wastewater analytical results and a chain of custody. The analytical results indicate that there were not effluent limit violations as compared to limits stated in Permit No. 2017-EP-62654. The analytical reports include pH values as analyzed by PDC Laboratory personnel. A field pH value, analyzed within 15-minutes of grab sample collection, was not provided. Permit No. 2022-EP-67798 - Special Condition 5(A) and 40 C.F.R. 136 Both chains of custody indicate that grab and composite samples were collected. The chains of custody do not indicate how many bottles were used to collect samples, the material of the bottles used, the preservation method for each sample bottle, the start or stop time of the composite sample, and what sample type was used for each analyte. 40 C.F.R. 136 The cover letter of the report was signed by Caley Niday, Caterpillar employee whose title is EHS Professional. 40 C.F.R. 403.12(l) 2021 Annual Wastewater Sampling Report - Dated May 4, 2022 The report contains a cover letter and two analytical reports from PDC Laboratories. The first report is dated May 28, 2021 and the second is dated December 30, 2021. Both reports contain wastewater analytical results and a chain of custody. The analytical results indicate that there were not effluent limit violations as compared to limits stated in Permit No. 2017-EP-62654. The analytical reports include pH values as analyzed by PDC Laboratory personnel. A field pH value, analyzed within 15-minutes of grab sample collection, was not provided. Permit No. 2022-EP-67798 - Special Condition 5(A) and 40 C.F.R. 136 Both chains of custody indicate that grab and composite samples were collected. The chains of custody do not indicate how many bottles were used to collect samples, the material of the bottles used, the preservation method for each sample bottle, the start or stop time of the composite sample, and what sample type was used for each analyte. 40 C.F.R. 136 Page 17 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 TF-RR-009 TF-RR-010 TF-RR-012 The cover letter of the report was signed by Caley Niday, Caterpillar employee whose title is EHS Professional. 40 C.F.R. 403.12(l) Waste Water Treatment Work Instructions - Printed on April 23, 2012. The Records Section (Page 5) states that wastewater test sample records sheets should be shredded after one year of retention. Records should be maintained for at a minimum of 3 years. 40 C.F.R. 403.12(o) Stormwater Pollution Prevention Plan (SWPPP) - Revised on Oct. 28, 2022 The SWPPP does not contain a topographic map. Permit No. ILR006863 - Section E.5.a The SWPPP's facility map is not legible. Permit No. ILR006863 - Section E.5.b The stormwater pollution prevention team members do not have email addresses provided. Permit No. ILR006863 - Section E.7 The Facility discharges stormwater to North Creek, which is a tributary of the Vermilion River. The Vermilion River is impaired and has a Total Maximum Daily Loading as approved by IEPA. The SWPPP does not note the receiving water is impaired. Permit No. ILR006863 - Section C.1 The percent of impervious surfaces at the Facility is not identified. Permit No. ILR006863 - Section E.5.b The pollutants expected to be present in stormwater discharge are not identified. Permit No. ILR006863 - Section E.5 The Facility is subject to the metal finishing point source categorical pretreatment regulations found in 40 C.F.R. 433, therefore the general pretreatment regulations found in 40 C.F.R. 403 are also applicable. The general pretreatment regulations require categorical facilities submit periodic reports on continued compliance in June and December annually to the Control Authority. EPA Page 18 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 Region 5 is this Facility's Control Authority. The Facility submitted reports to IEPA and EPA reports once annually, in May 2021 and May 2022. 40 C.F.R. 403.12(e)(1) Semi-annual reports must be signed by someone who satisfies the pretreatment program signatory requirements. 40 C.F.R. 403.12(l) SECTION VII - CLOSING CONFERENCE Closing Conference The inspection team held a closing conference with Facility personnel beginning at approximately 3:00 PM. During the closing conference, inspectors discussed the observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VIII - LIST OF APPENDICES Appendix 1 - Photo Log Appendix 2 - Wastewater Treatment Flow Diagram Appendix 3 - Facility Water Volume Diagram Page 19 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 Appendix 1 - Photo Log Page 20 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 Caterpillar, Inc. - Pontiac, IL EPA Inspection February 22, 2023 All photos taken by Ted Flatebo, Environmental Engineer, U.S. EPA Camera: Ricoh WG-4 1: RIMG0124 Description: Coolant filtering machine. Spent filter cloth exiting machine in foreground. Waste liquid is stored in blue bin in the center of the photo. Location: Manufacturing 2 Date/Time: February 22, 2023, 11:41 AM Page 21 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 2: RIMG0125 Description: Lubricant exiting machine. Location: Manufacturing 2 Date/Time: February 22, 2023, 11:45 AM Page 22 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 3: RIMG0126 Description: Part washing machine. Washing occurs on the left side of the machine and rinsing on the right side of the machine. Location: Manufacturing 2 Date/Time: February 22, 2023, 11:48 AM 4: RIMG0127 Description: Liquid waste disposal area. Location: Manufacturing 2 Date/Time: February 22, 2023, 11:51 AM Page 23 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 5: RIMG0128 Description: New oil stored outside of the white cinderblock oil storage room. This room is immedately behind the wall in the background of the photo. The blue oval depics secondary containment for the oil totes. The red circle depics the lack of secondary containment for the 55 gallon drum. Location: Oil storage area. Date/Time: February 22, 2023, 11:59 AM 6: RIMG0129 Description: Heat treatment and oil quench. Drain under equipment goes to storage vault in the basement. Page 24 of 50 Caterpillar, Inc. - Pontiac, IL Location: Heat Treatment Date/Time: February 22, 2023, 12:03 PM February 22, 2023 7: RIMG0130 Description: Steam condinsate line draining to floor drain which flows to basement vault. Location: Manufacturing 4 Date/Time: February 22, 2023, 12:08 PM 8: RIMG0131 Description: Wastewater vault overview. Location: Basement. Page 25 of 50 Caterpillar, Inc. - Pontiac, IL Date/Time: February 22, 2023, 12:10 PM February 22, 2023 9: RIMG0132 Description: Trench drain that flows to vault. Location: Basement Date/Time: February 22, 2023, 12:13 PM Page 26 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 10: RIMG0133 Description: Liquid waste disposal area. Note storage of Cynamic Alti-Mate 64 in blue container directly above drain. Location: Manufacturing 1 Date/Time: February 22, 2023, 12:27 PM Page 27 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 11: RIMG0134 Description: Stormwater flow with visible sheen. Location: Outside between Manufacturing 1 and wastewater treatment area Date/Time: February 22, 2023, 12:29 PM Page 28 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 12: RIMG0135 Description: Overview of ODP (oxygen deprive product) tank. Location: Outdoor section of wastewater treatment area - northwest tank. Date/Time: February 22, 2023, 12:35 PM Page 29 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 13: RIMG0136 Description: Overview of DAF (dissolved air floatation) tank. Location: East end of indoor wastewater treatment area. Date/Time: February 22, 2023, 12:41 PM Page 30 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 14: RIMG0137 Description: Effluent composite sampler. Location: Lab section of wastewater treatment area. Date/Time: February 22, 2023, 12:58 PM Page 31 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 15: RIMG0138 Description: Tank 2 - Wastewater influent storage tank. Location: Outdoor section of wastewater treatment area - south center tank. Date/Time: February 22, 2023, 1:16 PM Page 32 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 16: RIMG0139 Description: Tank 3 - Wastewater effluent storage tank. Location: Outdoor section of wastewater treatment area - southeast tank. Date/Time: February 22, 2023, 1:17 PM Page 33 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 17: RIMG0140 Description: Weir at the north end of the DAF unit. This is the grab sample compliance sampling location. Location: East end of indoor wastewater treatment area. Date/Time: February 22, 2023, 1:20 PM Page 34 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 18: RIMG0141 Description: Valve assembly that feeds potable water to the two fire suppression system storage tanks. Blue circle denotes active leak in the valve assembly. Red circle denotes sump pump actively draining water. Location: North of the two fire suppression system tanks located at southern end of the Facility. Date/Time: February 22, 2023, 13:28 PM Page 35 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 19: RIMG0142 Description: Turbid stormwater flowing through gutter towards storm drain. Location: Intersection of the two roads immediately east of the fire suppression system water tanks. Date/Time: February 22, 2023, 1:32 PM Page 36 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 20: RIMG0143 Description: Stormwater Outfall 002. Note brown streak of brown material in North Creek originating at the Outfall. Location: North Creek, southern of two Outfalls identified in SWPPP. Date/Time: February 22, 2023m 2:00 PM 21: RIMG0144 Description: Stormwater Outfall 002. Location: North Creek, southern of two Outfalls identified in SWPPP. Date/Time: February 22, 2023, 2:00 PM Page 37 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 22: RIMG0145 Description: Stormwater flowing through Facility fence towards North Creek. Location: Along Facility fence line between Outfalls 002 and 003 Date/Time: February 22, 2023, 2:03 PM 23: RIMG0146 Description: Overview of stormwater flow depicted in Photo 22. Blue circle denotes erosion of material under Facility fence line. Location: Along Facility fence line between Outfalls 002 and 003. Date/Time: February 22, 2023, 2:04 PM Page 38 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 24: RIMG0147 Description: Stormwater Outfall 003. Note brown streak of material in North Creek originating at the Outfall. Location: North Creek, northern of two Outfalls identified in SWPPP. Date/Time: February 22, 2023, 2:05 PM 25: RIMG0148 Description: Stormwater Outfall 003. Location: North Creek, northern of two Outfalls identified in SWPPP. Date/Time: February 22, 2023, 2:06 PM Page 39 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 26: RIMG0149 Description: Stormwater flow through Facility fence towards North Creek. Location: Along Facility fence line between Outfalls 002 and 003. Date/Time: February 22, 2023, 2:08 PM Page 40 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 27: RIMG0150 Description: Overview of stormwater flow depicted in Photo 26. Location: Along Facility fence line between Outfalls 002 and 003. Date/Time: February 22, 2023, 2:08 PM Page 41 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 28: RIMG0151 Description: Road salt application truck. Hopper in truck bed was full at time of inspeciton. Blue circle denotes chunks of road salt exposed to storm water. Location: Along Facility fence line, adjacent to Outfall 002. Date/Time: February 22, 2023, 2:14 PM Page 42 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 29: RIMG0152 Description: Hoses leading from outdoor wastewater treatment area to grass. Location: Outdoor section of wastewater treatment area. Date/Time: February 22, 2023, 2:15 PM Page 43 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 30: RIMG0153 Description: Tank farm loading/unloading location. Note catch basin directly beneath the end of the pipes. Location: Tank farm in southwest corner of the Faciliy. Date/Time: February 22, 2023, 2:20 PM 31: RIMG0155 Description: Overview of stormwater captured in tank farm secondary containment. Blue circle denotes pipe in Photo 32. Location: Tank farm in southwest corner of the Faciliy. Date/Time: February 22, 2023, 2:23 PM Page 44 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 32: RIMG0156 Description: Pipe actively taking on water from within tank farm secondary containment. See overview of pipe location in Photo 31. Location: Tank farm in southwest corner of the Faciliy. Date/Time: February 22, 2023, 2:23 PM Page 45 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 Appendix 2 - Wastewater Treatment Flow Diagram Page 47 of 50 February 22, 2023 Flo ccu lat o r Spillter o South Sludge Pit ,300 al Clean water (Could ll with wastewater if needed, but it is bloc ed o by manual valve) FC 4A Solid removal from bo om P 2024 P 2023 rain 3 ,400 al Wastewater 3 ,400 al Wastewater Tan 3 Tan 2 Tan 3 ,400 al Air valve FC 4 Sludge Trough ba es rain P 2040 P 203 FC 4 350 al Pressuri a on Tan P 200 P 200 To City FC 3A Air valve FC 3 anual alve P200 FC A FC FC 5A iluted Caus c 2 Tan 500 al P 203 P 2035 Oil Sump 350 al FC 2A FC 2 Air valve P2004 FC 5 P 200 P 2000 Plat e Separator Removaldown to 5 ppm and 0 microns Solidsblowo to sludge pit FC A Oilconcentra on tan E20 2 4000 al Tote O P Coolant Tan (coolant from nits) 3 ,400 al Sulfuric Acid 4050 al Chemical i ing Tan E2000 500 al P probe located in inlet tan before it goes into mi ing tan P2032 P203 Page 48 of 50 North Sludge Pit ,300 al Caterpillar, Inc. - Pontiac, IL Centrifuge Surge Tan 200 al S immers Over AF e ciency 0 5 ow removal of solids Auger Screw under s immers Filtered water from centrifuge goes to oil sump Sludge rollo located under Caterpillar Con den al reen centrifuge P202 Polymer Tan 500 al P202 Polymer Tan 500 al Cooling Tower F 20 F 200 F 2000 Air lowers Pump Ferric Tan Pump 5,300 al P 20 Caus c Tan P 5,300 al 20 P 2 P Pumps in basement Oily Waste Central Pumping ( uilding asement) arious c oolant pipes from uilding Caterpillar, Inc. - Pontiac, IL February 22, 2023 Appendix 3 - Facility Water Volume Diagram Page 49 of 50 Caterpillar, Inc. - Pontiac, IL February 22, 2023 Page 50 of 50