Document x5bw76Oj9M4r6gKN2w6ajNB7y

U.S. Environmental Protection Agency Region 5 Purpose: Clean Water Act National Pollutant Discharge Elimination System Compliance Evaluation Inspection Facility: MPR Sand Terminals, LLC 5330 Guernsey Street Bellaire, Ohio 43906 Inspection Date: February 22, 2023 EPA Representatives: Jake Berger, Physical Scientist, 312-353-8024, berger.jake@epa.gov Andi Hodaj, Environmental Engineer, 312-353-4645, hodaj.andi@epa.gov Facility Representatives: Justin Brown, Vice President of Operations Report Prepared by: Jake Berger, Physical Scientist Water Enforcement and Compliance Assurance Branch, Section 1 Digitally signed by Berger, Berger, Jake Date: 2023.03.16 Jake Inspector Signature and Date: ________________1_1:3_1_:50_-_05_'0_0'________________________ 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________16_:4_2:_27_-0_5'_00_' _________________________ Date: 2023.03.16 PURPOSE OF INSPECTION The purpose of the inspection by the U.S. Environmental Protection Agency (USEPA) at the MPR Sand Terminals, LLC facility (MPR Sand or Facility) was to describe, evaluate, and document compliance with the Clean Water Act (CWA). BACKGROUND MPR Sand does not have a National Pollutant Discharge Elimination System (NPDES) permit. The Facility is a frac sand distribution site. Sand is unloaded from barges on the Ohio River into the sand storage warehouse, and then moved into silos to be loaded into trucks and taken offsite. MPR Sand has 35 employees and operates 24 hours per day, 365 days per year. INSPECTION Jake Berger and Andi Hodaj of USEPA first arrived at the Facility at 11:37 a.m. EST and were met by Justin Brown, Vice President of Operations, MPR Sand. Jake Berger and Andi Hodaj (inspectors) showed Mr. Brown their inspector credentials and were granted a tour of the Facility and began the opening conference. Opening Conference USEPA staff explained that the purpose of the inspection was to: Gain an understanding of MPR Sand's operations; Conduct a walkthrough of the Facility; Identify locations where storm water control had the potential to be insufficient; and Inform MPR Sand of areas of concern identified during the inspection. Facility Walkthrough USEPA staff began the Facility walkthrough at 12:16 p.m. EST and made the following observations, further documented in the Photograph Log (attached): The metal walls used to retain sediment and sand in the Supply Area are not sufficiently preventing stormwater, sand, and sediment from entering the Ohio River (Photos 2 - 5). Holes in the retaining wall are seen at a height lower than the retained sand and stormwater, allowing for a discharge of stormwater, sand, and sediment through the wall and into the Ohio River (Photo 3). Similar deficiencies are seen in the corners between the metal parts of the retaining walls (Photo 4). Sand and sediment have accumulated behind the retaining walls, to the extent that it has filled up behind the wall, and is overflowing into the Ohio River (Photo 5). 2  Sand, sediment, and stormwater have also accumulated behind the walls of the Harbor Area up to the same height as the wall (Photos 6 - 8). Sand and sediment are evident on the top surface of the harbor wall, directly above the Ohio River (Photo 8). Stormwater is collected in two catch basins beside the sand loading station (Photos 13 and 14) and is discharged to the Ohio River through a permanently installed pipe (Photo 10). A channel of stormwater runoff, sand, and sediment, which leads into the Ohio River, is evident at the north boundary of the Harbor Area (Photo 11). The Facility walkthrough tour ended at 1:38 p.m. EST. Records Review Since MPR Sand does not have an NPDES permit and does not conduct any monitoring, selfinspections, or sampling for their stormwater runoff or stormwater control mechanisms, a records review was not part of this inspection. Closing Conference The closing conference began at 1:38 p.m. EST. USEPA staff discussed the following with Mr. Brown during the closing conference: Stormwater and sediment are not being completely contained within the site, and are entering the Ohio River from the Supply Area and Harbor Area; and USEPA confirmed that no information collected during the inspection was considered Confidential Business Information. USEPA concluded the inspection and left the Facility at 1:50 p.m. EST. 3 MPR Sand Terminals, LLC EPA Inspection February 22, 2023 All photos taken by Jake Berger, Physical Scientist, U.S. EPA Camera: Olympus Tough TG-6 1: P2220027 Description: Overview of supply area Location: Supply area Camera Direction: North Date/Time: 2/22/2023 - 12:34 p.m. EST 2: P2220028 Description: Sand accumulation in supply area Location: Supply area Camera Direction: East Date/Time: 2/22/2023 - 12:37 p.m. EST 3: P2220029 Description: Seepage from the near top of the sediment/sand retaining wall, actively discharging stormwater into the Ohio River Location: Supply area Camera Direction: South Date/Time: 2/22/2023 - 12:40 p.m. EST 2 4: P2220030 Description: Stormwater runoff exiting through the corner of the sediment/sand retaining wall into the Ohio River Location: Supply area Camera Direction: East Date/Time: 2/22/2023 - 12:41 p.m. EST 5: P2220031 Description: Sand overflowing the edge of the retaining wall into the Ohio River Location: Supply area Camera Direction: North Date/Time: 2/22/2023 - 12:42 p.m. EST 3 6: P2220032 Description: Ponded stormwater runoff and sand next to the Ohio River Location: Harbor area Camera Direction: North Date/Time: 2/22/2023 - 12:44 p.m. EST 7: P2220033 Description: Ponded stormwater and sand next to the Ohio River Location: Harbor area Camera Direction: North Date/Time: 2/22/2023 - 12:47 p.m. EST 4 8: P2220034 Description: Sand on top of the harbor wall on the Ohio River Location: Harbor area Camera Direction: North Date/Time: 2/22/2023 - 12:54 p.m. EST 9: P2220035 Description: Double walled fuel tank Location: Sand unloading conveyor system Camera Direction: South Date/Time: 2/22/2023 - 1:06 p.m. EST 5 10: P2220036 Description: Black pipe discharging stormwater into the Ohio River Location: North end of harbor area Camera Direction: East Date/Time: 2/22/2023 - 1:08 p.m. EST 11: P2220037 Description: Runoff channel flowing around the north boundary wall of the harbor area Location: North end of harbor area Camera Direction: East Date/Time: 2/22/2023 - 1:09 p.m. EST 6 12: P2220038 Description: Drainage pipe below the sand waste pile Location: Sand loading station Camera Direction: Northwest Date/Time: 2/22/2023 - 1:14 p.m. EST 13: P2220039 Description: Catch basin with opening covered by orange dandy bag, south of the truck filling station. Drains to the black discharging pipe in Photo 10. Location: Sand loading station Camera Direction: West Date/Time: 2/22/2023 - 1:16 p.m. EST 7 14: P2220040 Description: Catch basin with opening covered by orange dandy bag, north of the truck filling station. Drains to the black discharging pipe in Photo 10. Location: Sand loading station Camera Direction: West Date/Time: 2/22/2023 - 1:16 p.m. EST 15: P2220041 Description: Inside of sand storage warehouse Location: Sand warehouse Camera Direction: East Date/Time: 2/22/2023 - 1:21 p.m. EST 8 16: P2220042 Description: Drain next to the sand warehouse. Drains to the ditch north of the property and into the Ohio River. Location: Next to sand storage warehouse Camera Direction: East Date/Time: 2/22/2023 - 1:23 p.m. EST 9