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NPDES Compliance Inspection Report Atkore Plastic Pipe Corporation Eugene, Oregon Permit #: ORR231302 Inspection Date: March 23, 2021 Prepared by: Raymond Andrews U.S. Environmental Protection Agency, Region 10 Enforcement & Compliance Assurance Division Water Enforcement & Field Branch Field, Data & Drinking Water Enforcement Section Signature/Date: Andrews, Raymond L. Date: 2021.05.27 09:47:15 -07'00' Digitally signed by Andrews, Raymond L. Supervisor Signature/Date: PETER CONTRERAS Date: 2021.05.27 10:34:46 -07'00' Digitally signed by PETER CONTRERAS Atkore Plastic Pipe NPDES #ORR231302 Contents I. Facility Information ............................................................................................................ 1 II. Inspection Information........................................................................................................ 1 III. Permit Information.............................................................................................................. 2 IV. Background ..................................................................................................................... 2 V. Inspection Chronology........................................................................................................ 2 VI. Opening Conference ........................................................................................................... 2 VII. Laboratory Inspection ......................................................................................................... 3 VIII. File Review ..................................................................................................................... 4 IX. Site Inspection..................................................................................................................... 4 X. Areas of Concern ................................................................................................................ 5 XI. Closing Conference............................................................................................................. 6 ATTACHMENT A - Aerial Images of Site Provided by the Facility ATTACHMENT B - Inspection Photographs and Photograph Log Atkore Plastic Pipe NPDES #ORR231302 (All details in this report were obtained through conversations with Mr. Keith Dinkheller or from observations made during the inspection.) I. Facility Information Facility Name: Atkore Plastic Pipe Corporation Facility Owner/Operator: Atkore International Physical Address: 2220 Nugget Way Eugene, Oregon 97403 Lat/Long: 44.03650, -123.03003 Mailing Address: 2220 Nugget Way Eugene, Oregon 97403 NAICS Code: SIC Code: 326122 (Plastics Pipe and Pipe Fitting Manufacturing) 3084 (Plastics Pipe & Pipe Fitting mfg (pt)) Facility Contacts: Keith Dinkheller Plant Manager Office Phone: 541-746-6066 Cell Phone: 435-531-9793 Email: kdinkheller@atkore.com Permit Number: ORR231302 Receiving Water: MS4 Willamette River II. Inspection Information Inspection Date: March 23, 2021 Inspector: Raymond Andrews, Inspector EPA Region 10, ECAD /FDDWES Phone: 206-553-4252 Arrival Time: 10:00 AM Departure Time: 2:00 PM Weather: Sunny, 41F Page 1 of 6 Purpose: Atkore Plastic Pipe NPDES #ORR231302 To determine facility compliance with the Oregon 1200-Z General National Pollutant Discharge Elimination System (NPDES) permit and the Clean Water Act. III. Permit Information Atkore Plastic Pipe Corporation ("Facility") is permitted under the Oregon 1200-Z General National Pollutant Discharge Elimination System (NPDES) Stormwater Discharge Permit ("Permit"). The Facility's permit, NPDES permit # ORR231302, became effective on August 1, 2017, and will expire on July 31, 2022. The facility is permitted under Sector Y (Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industry) of the permit and has had permit coverage since 2017. IV. Background Atkore International, Inc. owns and operates Atkore Plastic Pipe Corporation located at 2220 Nugget Way in Eugene, Oregon. The facility was previously inspected by the Environmental Protection Agency (EPA) for compliance with the Oregon 1200-Z Stormwater Discharge permit on September 16, 2019. At the time of the inspection, no areas of concern were identified. V. Inspection Chronology This was an announced inspection. On March 22, 2021, I called Mr. Keith Dinkheller, Plant Manager, and stated that I wanted to conduct a NPDES compliance inspection of the Atkore Plastic Pipe Corporation facility in Eugene, Oregon. We agreed to meet at the facility on March 23, 2021, at 10:00 am. I conducted an Opening Conference, which included an interview of Mr. Dinkheller, followed by a records review, a site inspection, and a Closing Conference. Inspector's Note: All directional references used in this report are approximations. VI. Opening Conference I arrived at the facility at 10:00 am, as agreed. I presented my credentials to Mr. Dinkheller and provided him a copy of the EPA Small Business Resource Sheet. I explained the purpose of the inspection was to determine compliance with the Oregon Department of Environmental Quality's (ODEQ) 1200-Z permit and the Clean Water Act (CWA). The following information was obtained through conversation with Mr. Dinkheller. The facility has been in operation at its current location since 2017. The facility operates 24-hours a day, seven days a week, and has 106 full time employees. Mr. Dinkheller started working at the facility in August 2019. Page 2 of 6 Atkore Plastic Pipe NPDES #ORR231302 Atkore Plastic Pipe Corporation is part of a larger corporation, Atkore International, Inc. The parent corporation has multiple locations engaged in a wide range of activities. This facility makes PVC electrical conduit as well as PVC water and irrigation pipe so it can serve both the electrical and plumbing markets. The facility receives pre-made plastic pipe which it cuts, bends, and flares to customer specifications. "Flaring" is the process of enlarging one end of a pipe so another pipe can connect to it. The facility conducts activities indoors and outdoors. Indoor Activities Indoor activities include manufacturing and packaging of products, maintenance of production equipment, and maintenance of one of the forklifts by a contractor since the forklift is leased. Some forklifts are parked inside. Outdoor Activities Outdoor activities are loading and unloading of raw materials and finished products, and storage of packaged product awaiting ship out. No cleaning of equipment or material is performed outside. Some forklifts are parked outside when not in use. The forklifts I observed outside had drip pans in place. Per the permit, the facility is required to conduct routine monthly inspections, and quarterly visual inspections. Both the monthly and quarterly inspections are conducted by Terry Engleheart, the Quality Assurance (QA) Inspector. According to Mr. Dinkheller, the site is generally flat, however, the property has a highpoint running the length of the property along the northwest - southeast axis. The slight downward slope from the center of the property facilitates drainage and control of stormwater. VII. Laboratory Inspection On August 7, 2018, ODEQ waived the facility's sampling requirements for oil & grease (O&G), pH, total suspended solids (TSS), total copper (Cu), and total lead (Pb), in accordance with Schedule B.4 of the permit. Additionally, on January 9, 2019, ODEQ waived the sampling requirement for total zinc (Zn). The waiver extends through the end of the permitting cycle, which ends on July 31, 2022. Schedule B.4 allows a facility to request a monitoring waiver after four consecutive qualifying samples show the facility is below permit benchmarks. The facility continues to monitor for the impairment parameters of mercury (Hg), dissolved lead (Pb), total iron (Fe), and biochemical oxygen demand (BOD). The facility does not maintain an in-house laboratory. All monitored parameters are analyzed by: Analytic Laboratory Group 361 West 5th Avenue Eugene, Oregon 97401 (541) 485-5401 Page 3 of 6 VIII. IX. Atkore Plastic Pipe NPDES #ORR231302 Analytic laboratory prepares the facility's Discharge Monitoring Reports (DMRs) for the facility. After receiving the completed DMRs from the laboratory, Mr. Dinkheller reviews and signs them then submits them to ODEQ. File Review The permit requires that documentation be retained for a minimum of three years. I reviewed the following records and documents: Permit Reissuance Letter - October 24, 2018 Stormwater Pollution Control Plan (SWPCP) - revised January 18, 2021 Monthly Facility Inspection Reports - March 2018 through February 2021 Chain-of-Custody Documents - March 2018 through February 2021 Discharge Monitoring Reports (DMRs) - February 2018 through February 2021 Annual Employee Training Records - 2018 through 2020 Monitoring Waiver Letter - January 9, 2019 All requested documents were available and reviewed. Site Inspection An aerial image, provided by the facility, appears in Attachment A. The photographs used in this inspection report and a complete photo log appears in Attachment B. Following the records review, Mr. Dinkheller and I walked outside so I could conduct the site inspection. The facility's site covers approximately 11.25 acres with almost the entirety of the footprint impervious to penetrative rainfall. About 62% of the site is exposed to precipitation with the remaining 38% covered by structures. Once the Opening Conference concluded, I asked to be shown to the center of the property so that I could try to discern the slope. Upon exiting the office building, I saw several stacks of plastic pipe which were banded to pallets (Photo 1). Mr. Dinkheller said those stacks of pipe were waiting to be loaded up and shipped to storage. The site had several locations where plastic pipe were either waiting to be shipped to storage or waiting to be taken into the production building to be cut and shaped (Photo 2). I also observed a covered, three-sided structure, which was used to store tanks and barrels containing oil and glycerin (Photo 3). The tanks were double-walled, and the floor of the structure was raised and grated to act as secondary containment. When we reached the approximate center of the property, I surveyed the area. From my position, I could discern a slight downward slope to the east and west. On the east side, it appeared stormwater would sheet flow in an easterly direction to the street, Nugget Way, and would enter the City of Eugene's ("City") MS4 system. Mr. Dinkheller guided me to the City's storm drain, which lay just outside the eastern perimeter fence. As we approached the fence, I observed straw waddle (Photo 4) lining the facility side of the fence. Mr. Dinkheller said the straw waddle prevents particulate matter from entering the City's Municipal Separate Storm Sewer System (MS4) through the storm drain (Photo 5), which catches some of the site's stormwater. From the MS4, the water eventually enters the Willamette River. Page 4 of 6 Atkore Plastic Pipe NPDES #ORR231302 The facility maintains a bioswale (Photo 6) on the eastern edge of the site just inside the perimeter fence, it catches stormwater that sheet flows from the southeastern section of the site. Mr. Dinkheller said the bioswale allows some stormwater to infiltrate. We continued the inspection by walking the perimeter of the facility in a northerly direction to the end of the property. In the northeastern corner of the property, the facility maintains an "Infiltration Strip". The infiltration strip serves the same purpose as the bioswale by catcheing stormwater from the northeastern section of the site. The site has two sampling points. The first sampling point is in the northeastern section of the site. A representative of Analytic Laboratory Group (ALG) takes a grab sample from a manhole (Photo 7) on the site. We turned west and walked to the northwestern corner of the site. The northwestern corner of the property is the terminus of the stormwater collection system for the west side of the site. Stormwater sheet flows from the west side of the site into an old gravel-covered railroad track spur. The stormwater "typically" follows the railroad tracks (Photo 8). Any stormwater that does not infiltrate enters a storm drain (Photo 9). The drain is protected from excessive particulate matter by a filter sock on the upstream side. The second sampling point is on the southwestern edge of the site. Mr. Dinkheller said the sample is collected at this location using a procedure that ponds stormwater as it sheet flows. The sample is collected by a facility employee under the supervision of an ALG representative. Once the sample is collected, it is handed to the representative. The Willamette River is approximately 450 yards east of the facility. X. Areas of Concern At the time of inspection, I found the following areas of concern: A. Schedule A.6.b of the Permit states, "The SWPCP must be signed and certified in accordance with 40 CFR 122.22." 40 CFR 122.22 requires a responsible officer of the company to sign the statement, "I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining information, I believe that the submitted information is true, accurate, and complete." During the inspection, I reviewed the Stormwater Pollution Control Plan (SWPCP). The SWPCP was signed and included the correct certification language as required by 40 CFR 122.2; however, the information in the SWPCP was not accurate. In section 3.5.1 of the SWPCP, the plan stated the Stormwater Pollution Control Team (SPCT) was identified in Table 7; however, Table 7 identifies the location of spill kits. The SPCT table is labeled as Table 9. Page 5 of 6 Atkore Plastic Pipe NPDES #ORR231302 B. Schedule A.7.b. of the Permit indicates requirements for the site map, which includes "loading/unloading areas", "processing and storage areas", and "transfer areas for substances in bulk." At the time of the inspection, the site map did not include the locations of "loading/unloading areas", "processing and storage areas", and "transfer areas for substances in bulk." C. Schedule A.7.c.i of the Permit states that the SWPCP must "...indicate who is responsible for on-site management of significant materials and include their contact information." At the time of the inspection, the SWPCP did not indicate, by name, who was responsible for on-site management. The SWPCP listed those responsible by position title only. D. Schedule A.7.c.iii of the Permit states the SWPCP must contain an Operations and Maintenance (O&M) Plan for "...passive treatment and low impact development control measures..." which includes "...routine maintenance standards." At the time of the inspection, the facility was using a passive treatment system but the SWPCP did not contain an O&M Plan. XI. Closing Conference On March 23, 2021, I held a closing conference with Mr. Dinkheller. We discussed my observations and I gave a brief overview of the post-inspection process. I thanked him for his time and assistance. Page 6 of 6 ATTACHMENT A Aerial Images of Site Provided by the Facility cs - Control St ructure M L- Monit oring location DP - Discharge point Atkore Plastic Pipe Corporation ATTACHMENT B Inspection Photographs and Photograph Log (Photographs taken by Ray Andrews on March 23, 2021 with a Panasonic DMC-FH25 camera) l I Photo 1 / P1000793 - Plastic Pipe, awaiting transport to storage Photo 2 / P1000794 - Plastic Pipe, waiting to be processed ~ Photo 3 / P1000801 - Drum & Tank, storage area Photo 4 / P1000795 - Straw Waddle Photo 5 / P1000796 - Storm Drain, east side Photo 6 / P1000803 - Bioswale Photo 7 / P1000802 - Sampling Location Photo 8 / P1000800 - Railroad Track Path, facing north Ecology Blocks Sidewalk Photo 9 / P1000799 - Storm Drain, west side Complete list of photographs taken during the inspection: P1000784 - SWPCP, Cover Page P1000785 - SWPCP, Title Page P1000786 - SWPCP, Certification Page P1000787 - SWPCP, Review Table P1000788 - SWPCP, 3.5.1 SPCT, Table 7 referenced P1000789 - SWPCP, Table 7 P1000790 - SWPCP, Table 9 P1000791 - Permit Assignment Letter, page 1 P1000792 - Permit Assignment Letter, page 2 P1000793 - Plastic Pipe, awaiting transport to storage P1000794 - Plastic Pipe, waiting to be processed P1000795 - Straw Waddle P1000796 - Storm Drain, east side P1000797 - Storm Drain, east side, close-up P1000798 - Packaged Pipe, awaiting ship out P1000799 - Storm Drain, west side P1000800 - Railroad Track Path, facing north P1000801 - Drum & Tank, storage area P1000802 - Sampling Location P1000803 - Bioswale