Document ymM0E9w4O98rx5ryXyaO6Ed76

COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5 Purpose: NPDES Compliance Evaluation Inspection Facility: Cynamic Chemical Company 1472 Louis Bork Drive Batavia, Illinois 60510 Date of Inspection: March 19, 2024 EPA Inspectors: Val Dooling, Environmental Engineer, (312) 886-7167 Sophie Bazan, Physical Scientist, (312) 886-6068 IEPA Representatives: Ricardo NG, Environmental Protection Engineer Mohammed Saleem, Environmental Protection Engineer City of Batavia Representatives: Zac Bonesz, Superintendent, Wastewater Division Cynamic Chemical Company Representatives: Tim Daley, President, Owner Lisa Johnson, Plant Manager Report Prepared By: Val Dooling, Environmental Engineer EPA Inspector Signature and Date: VALERIE Digitally signed by VALERIE DOOLING DOOLING Date: 2025.05.06 11:29:49 -05'00' _____________________________________________ Approver Name and Title: Ryan J. Bahr, Section 2 Supervisor Water Enforcement and Compliance Assurance Branch Approver Signature and Date: Digitally signed by Bahr, Bahr, Ryan Date: 2025.05.06 Ryan ______________11_:4_9:0_7_-0_5'_00_' ________________________ TABLE OF CONTENTS I. Introduction ................................................................................................................................. 1 II. Background ................................................................................................................................. 1 III. Opening Conference and Discussion at Batavia WWTP ............................................................ 1 IV. Opening Conference and Discussion at Cynamic Chemical Company ...................................... 3 V. Facility Site Visit .......................................................................................................................... 5 VI. Closing Conference .................................................................................................................... 6 LIST OF APPENDICES Appendix A: Inspection Photo Log Appendix B: Aerial image of Cynamic Chemical Company Appendix C: Batavia WWTP Memo Appendix D: Dissolved Oxygen in Batavia WWTP Activated Sludge Appendix E: Gas Detector Detection and Sensitivity Appendix F: Manholes Tested for Presence of Flammable Gasses Appendix G: Semivolatile, Volatile and Total Organic Carbon results from Appendix H: Cease and Desist Letter to Cynamic Appendix I: Chemical Oxygen Demand Results from Cynamic Appendix J: Semi Volatile Organics at Batavia WWTP Appendix K: Screening Technique to Identify Gas/Vapor Toxic Discharges Appendix L: Screening Technique to Identify Flammable/Explosive Discharges Cynamic Chemical Company CEI Inspection - March 19, 2025 I. INTRODUCTION The purpose of the report is to describe, evaluate and document Cynamic Chemical Company ("Cynamic")'s compliance with the Clean Water Act (CWA) and the National Pretreatment Categorical Effluent Guidelines. II. BACKGROUND On March 19, 2025, EPA conducted a Clean Water Act Compliance Evaluation Inspection at City of Batavia Wastewater Treatment Plant (WWTP) located at 400 S Shumway Avenue in Batavia, Illinois and at Cynamic Chemical Company ("Cynamic") located at 1472 Louis Bork Drive Batavia, Illinois 60510. Batavia WWTP does not have a federally approved pretreatment program and the State of Illinois is not approved for a pretreatment program, so EPA is the Control Authority and Approval Authority. Cynamic is an industrial user of Batavia, which holds NPDES Permit IL0022543, effective January 9, 2019, and expired December 31, 2023, and was administratively continued. Cynamic did not self-identify as a categorical industrial user that is subject to effluent standards. III. OPENING CONFERENCE AND DISCUSSION AT BATAVIA WWTP Inspector Sophie Bazan, Illinois Environmental Protection Agency (IEPA) Inspectors Ricardo NG and Mohammed Saleem and I arrived at Batavia WWTP at 10:15am. I presented my credentials to Zac Bonesz and began the opening conference. I requested whether any information that was discussed was confidential business information and he replied that it was not. Mr. Bonesz described the current situation with its industrial user, Cynamic, in which the industry must hold all wastewater rather than sending it to the sewer since it is under a ceaseand-desist letter from Batavia WWTP. The city has not physically severed the connection between the industry and sewer, but the facility is legally not allowed to discharge anything other than domestic wastewater. Mr. Bonesz stated the company is currently complying. I asked him to describe what events took place that led to the WWTP upset in February 2025. Mr. Bonesz stated that he had produced a written narrative of events (Appendix C) and also described the following to me: On Friday, February 21, 2025, WWTP Operators noted a "horrible, chemical-like, petrol-like" smell surrounding the WWTP. The aeration tanks, when operating normally, would have a crisp foam. At this time, operators noted there was no foam on the aeration tanks. The dissolved oxygen (DO) in these tanks had dropped to zero during the previous night. There are emergency blowers that start operating at 2ppm, and these revived the DO for a time, but eventually, the DO was at zero and continued to be at that same level (Appendix D). Samples collected from the nitrification basin indicated that the microbial activity had died and that no internal plant processes were active. Operators noted that all midge flies, leeches and snails that typically live under the roof in the covered final clarifiers had died. 1 Cynamic Chemical Company CEI Inspection - March 19, 2025 Mr. Bonesz estimated that approximately 10-12 million gallons of untreated effluent went through the plant during the five-day time period from February 21 to 25 or 2.2 million gallons per day. At that time, the effluent was a milky color. Batavia WWTP has a UV disinfection system. During this time period, it was operating at maximum power; however, the ultraviolet transmittance (UVT) was around 4% compared to the typically operating range around 60%. The WWTP was operated to maximize wasting in order to flush out the contaminant that caused the upset. Operators had raised the level of digesters and would maximize centrifuging out. The sludge was not tested at this time. Once the DO levels indicated that the contaminant has been flushed from the plant, approximately 150,000 gallons of seed was introduced to the WWTP on Tuesday February 25, 2025. The seed slug consisted of return activated sludge (RAS) from a nearby city that had similar profiles of industrial and residential percentages. Eleven days after the initial upset, Batavia WWTP was back online. Prior to this incident, the WWTP had been operating very well with no problem meeting NPDES Permit limits. Mr. Bonesz told me that he had a portable combustible gas leak detector (Appendix E) at the WWTP which was used periodically to check for gas leaks. At the time of the upset and chemical like smell on February 21, 2025, the gas meter was activated at the highest level, indicating presence of combustible gas. Operators and staff were instructed to open all doors and vents in order to prevent a possible explosion. The WWTP has been under some construction and, as a result, the flows from east (across the Fox River) and from the west had been separated and operators could determine that the flow from the east had presence of the combustible gas whereas the west flow did not. Mr. Bonesz directed a team of public works staff from the WWTP and collection systems to move upstream on the east laterals and check each manhole upstream for the presence of the combustible gas. Appendix F shows a map of the manholes that indicated presence of combustible gas. The last manhole that indicated the presence of combustible gas was at an industrial park and all manholes upstream of that one did not. Mr. Bonesz stated that at that time, the manholes smelled violent, and many of his staff left the search early complaining of headaches. For the health of his staff, he discontinued the search for the source of the odor. Overall, five WWTP staff and seven water department staff, as well as some construction staff were exposed to the odor and many left early with headaches. Mr. Bonesz continued that search on Tuesday, February 25, 2025. While the WWTP plant was reseeded, the public works staff noticed the same odor at the WWTP that occurred on Friday and therefore began a door-to-door search of the industrial park which discharges to the manhole where the combustible gas meter last was activated. On that day, the manhole was also checked for the same odor and staff noted the same pungent odor downstream of that manhole whereas staff noted no odor upstream. At Cynamic, just prior to the point where process wastewater is discharged to the Batavia sewer is a triple-basin fats, oils and grease (FOG) and water separator (triple basin). When staff removed the lid of the triple basin, the WWTP staff identified the same pungent odor as had 2 Cynamic Chemical Company CEI Inspection - March 19, 2025 been in the manholes and at the WWTP. The odor was noted to be stronger at the facility, and the combustible gas meter was activated at the highest level. WWTP staff took a grab sample of the residual wastewater that was sitting in the triple basin (Appendix G), but the facility was not discharging at the time. WWTP staff informed the Cynamic Plant Manager that the contents were potentially explosive and issued a cease-and-desist letter to Cynamic (Appendix H), citing the City of Batavia's sewer use ordinance (SUO) which prohibits discharges to the sewer that cause damage to the WWTP including viscous, flammable, explosive liquids, solids or gases such as gasoline, benzene, naphtha, or fuel oil. Batavia staff allowed one batch discharge from Cynamic of a week's worth of their wastewater on March 6, 2025, and collected a sample from the discharge at that time which identified 10,900 mg/L of chemical oxygen demand (Appendix I). Batavia reiterated its cease and desist to Cynamic, citing prohibition of unusual chemical oxygen demand in such quantities as to constitute a significant load on the wastewater treatment works in the Batavia SUO. Staff noted that it took approximately four hours for the discharge to leave Cynamic and at that time, they observed a large amount of foam at the WWTP. I asked Mr. Bonesz to describe the wastewater discharges from other industries neighboring Cynamic who discharge to the same spot as the manhole where the combustible gas meter last was active. He told me that one is a cleaning company that sends out cleaners and does no manufacturing onsite and another is a paperboard company that neutralizes its wastewater, but staff did not notice the distinct odor at either of those companies. I asked Mr. Bonesz whether there had been previous incidents or past problems from industry at the WWTP. He told me that no survey of Batavia's industrial users had been done, but an industrial user and FOG survey had been planned for in the next year. He told me that operators had noted foaming or black wastewater passthrough the WWTP in the past, but never as bad as this upset. After this discussion, IEPA and USEPA Inspectors left Batavia WWTP. IV. OPENING CONFERENCE AND DISCUSSION AT CYNAMIC CHEMICAL COMPANY Inspector Sophie Bazan, Illinois Environmental Protection Agency (IEPA) Inspectors Ricardo NG and Mohammed Saleem and I arrived at Cynamic Chemical Company at 11:50am. We met with Lisa Johnson, Plant Manager, who instructed us to call Tim Daley, President and Owner of Cynamic, who was not present locally. I was not able to present my credentials, as we spoke with Mr. Daley via phone. I asked him whether any information discussed was Confidential Business Information (CBI). He told me that chemical ingredients are not CBI but the exact percentages of ingredients in their products are CBI, which was beyond the scope of this inspection. Mr. Daley described the processes at the facility as mixing raw ingredients to produce commercial and industrial cleanup products. The process is strictly mixing raw products and does not involve reactions via heating or cooling. Examples of cleanup products are janitorial 3 Cynamic Chemical Company CEI Inspection - March 19, 2025 and kitchen dish detergents, rinse aids, floor cleaners or carpet cleaning aids. He told me that there are about 20 employees at the facility and the positions on site are usually two batch makers and a "gopher" on the liquid side and the rest are positions filling bottles and drums and shipping and receiving. The facility operates 6am - 4:30pm for 4 days per week. I asked how often new products come to market, he told me that many products have not changed in 20 years and that it has been a while since any new products were developed. He told me there are five products that are made the most frequently: alkali dish detergent, rinse agent, laundry detergent, dish detergent and Pull-It-Out. The facility has been in the same location for the past 12 years and at first did not have any mixers. Between 2015 - 2018 mixers were slowly added to the facility and it has been operating in its current setup since 2019. At the time of inspection, there are 10 mixers that surround a wastewater pan which can process up to 500,000 gallons of varying products. A second mixer is located in a separate part of the building and is reserved for one product, labeled Pull it Out, which does not discharge to the wastewater pan. I asked if there were floor drains in the facility and what the spill protocol is to prevent a slug discharge to the sewer. Mr. Daley told me that he is not aware of any floor drains that go to the sewer. All wastewater goes to the triple catch basin on the south side of the facility. If powder spills, it will be swept up and put in dumpster, if not hazardous. If liquid spills, it would be cleaned up with a floor scrubber and discharged to wastewater pan. I asked for a description of the chemicals that are stored onsite and how the facility purchases chemicals in bulk. Mr. Daley told me that raw materials are purchased based on how fast each is consumed and how quickly it can be replenished, but most things can be delivered in a few days. He told me that they are purchased in 50-pound bags, drums and totes by over 100 different vendors. Mr. Daley stated that there is generally no hazardous waste onsite, and if so, a contractor will remove any drums. I asked for the hazardous waste manifest for the last year, and Mr. Daley did not think that there was one in the last year since he told me that it has only occurred a few times in the last 12 years. He did not think that the laboratory would generate any hazardous waste either, or if so, it would not be a significant amount. He described the process wastewater as rinse from the sides of mixing tank, the rinse from the filler lines and weekly floor cleaning scrubber. Wastewater is discharged into pans and then it is pumped into the wastetank. Mr. Daley described the pan as a raised 12- by 16-foot platform that holds 700 gallons and the wastetank is 2000-gallon mixer. The laboratory technician will collect a sample, and since the untreated wastewater will often have a high pH, it will be neutralized with acid until it is below 8. The 2000-gallon wastetank is discharged to a 6000gallon tank. When this second tank is full, it is discharged through a surge tank and then through the triple basin FOG-water separator, then afterwards combined with domestic wastewater and discharged to the sewer. Generally, one batch discharge of 8000-gallons is discharged once a week. The surge tank was implemented because the discharge flow would be too large for the triple basin and would pool on the floor and bottom of valve. 4 Cynamic Chemical Company CEI Inspection - March 19, 2025 When asked if the laboratory performs any other tests than pH, Mr. Daley told me that the lab will test products for quality control. I asked what happens to products and raw materials that are outside of the desired quality range. Mr. Daley told me that they never have anything out of quality control. If a product doesn't meet standards, then it would be adjusted and reworked into a new batch to meet standards. Mr. Daley told me that wastewater is not recorded when it is discharged to the city and he does not know, prior to the city's cease and desist order on February 25, when the last discharge of wastewater to the city occurred. Other than pH neutralization, no other tests or samples are collected on the wastewater. Inspector Saleem indicated the results of the sampling at Batavia collected on February 25, 2025 (Appendix G) which identified the presence of various benzene containing organic chemicals and asked whether Mr. Daley was aware what or if any benzene containing products could have been discharged to the sewer. Mr. Daley replied that he did not know what would have been its source. Inspector Saleem then referenced the safety data sheets (SDS) for products "DSC" and "Cynamic Cleaner Degreaser" which list Alkyl dimethyl ethylbenzyl ammonium chlorides, alkyl dimethylbenzylammonium chloride and alkylbenzyldimethylammonium chloride as ingredients and questioned whether potential reactions could occur in the wastewater mixing tank which would result in these benzene containing compounds. Mr. Daley replied that he is not aware of any reactions but stated that there are over 500 chemicals and potentially tens of thousands of things could occur. Mr. Daley expressed that he did not believe that the February 25th sample collected from the triple basin by Batavia staff was representative of Cynamic's discharge because there was no discharge at the time of sample collection, and the basin is designed to separate FOG from water, and he was not sure whether the sample was collected from the oil or water side of the triple basin. I asked whether Cynamic has ever sampled its discharge for FOG, volatile or semi volatile organics, or anything other than pH and Mr. Daley replied that they had not. Mr. Daley told me that Cynamic's currently plan to come into compliance with the City of Batavia SUO is to reduce their wastewater chemical oxygen demand (COD) using enzymes until it reaches a level that is permitted by the SUO. V. FACILITY SITE VISIT On March 19, 2025 at 12:45 PM, EPA, IEPA Inspectors and Ms. Johnson began walking around the facility. Mr. Daley remained on the phone with us during our walkthrough of the facility. He informed us that we may not speak with staff other than Ms. Johnson and the laboratory technician. We started in the laboratory where the wastewater samples would be analyzed for pH. Then we walked the location of the ten mixers and wastewater pan (Photo 1). Bulk materials in IBC poly tanks and totes were stored on shelving along the walls, adjacent to the mixers and wastewater pan. Ms. Johnson informed us that this storage area is for the essential raw materials that were most frequently used. I noted totes stacked on the floor labeled as "blue" or "pink". Ms. Johnson told me that these were rinses from the mixers that will be incorporated into the next batch. The color coding is to group like materials into the same rinse. She provided me the documents that describe grouping products that contain floor finish, mineral spirits, disinfectant and sanitizer rinse water policy according to a color code system. 5 Cynamic Chemical Company CEI Inspection - March 19, 2025 Each policy lists the chemical formulas or product lines that must be captured into the colored totes including rinses from mixing tanks, holding tanks, totes and filling lines and that no rinse water is permitted to flush down the sanitary sewer. I observed the ten tanks which surround the wastewater pan (Photo 1). I observed some 50gallon barrels and other pails sitting on top of the wastewater pan and Ms. Johnson explained that everything that was open was actively being used to make product. I asked whether each mixer has a dedicated tank. Mr. Daley told me that none of the main mixing tanks are dedicated, except tank 2, but they are trying to get better about mixing similar types of products back-to-back. Tank 2 is used as the wastewater collection tank. Mr. Daley told me that from the wastewater pan, wastewater is stored in mixer 3 until it is manually released about once a week. From the mixing tank area, we walked past the filling line and more storage of bulk raw materials to the mixing tank for the Pull-it-out mixer (Photo 2). Near this mixer were stacked IBC totes labeled with the product name and a raised platform with a supersack on top. We then walked to the triple basin (Photo 3). I observed that the lids were off, and the basins were exposed. There was some liquid sitting in each of the three basins (Photo 4). Mr. Daley told me that the triple basin is scheduled to be cleaned monthly. I did not observe any strong odors at the time of the inspection. Next to the basin was the white tote that Mr. Daley explained was the overflow tank. There was a white pipe and clear tubing which were disconnected. Mr. Daley explained that the white pipe is a vent, and the poly tubing would normally connect to the overflow tank which would then discharge to the triple basin, but both have been disconnected since Batavia issued its cease-and-desist letter. Nearby the triple basin was a floor drain (Photo 5). Mr. Daley explained anything that flowed through the drain would be discharged to the triple basin. Adjacent to the floor drain and triple basin was the storage area for empty mineral spirits totes waiting to be shipped back to the company from where it was purchased (Photo 6). I asked whether these totes were also rinsed before they were stored in this area, and Mr. Daley explained that they were not. We walked to the manhole where Batavia collected its sample on March 6th (Photo 7) and Mr. Daley explained that this sample was of combined domestic and process wastewater while a discharge of process wastewater was occuring. We also walked to the loading docks. At the bottom of the loading docks was a floor drain (Photo 8). Mr. Daley explained that there was a sump pit with a pump that was operated automatically by float and would also drain to the triple basin. We then concluded the site walkthrough at 1:20 PM. VI. CLOSING CONFERENCE I began a closing conference at 1:21PM. The following are the areas of concern discussed during the closing conference. 6 Cynamic Chemical Company CEI Inspection - March 19, 2025 1. Prohibition against passthrough or interference General prohibitions at 40 CFR that that a user may not introduce into a WWTP: a. any pollutant(s) which cause Passthrough or Interference (40 CFR 403.5(a)(1)); or b. petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will cause interference or pass through (40 CFR 403.5(b)(6)). Batavia WWTP's suffered an upset where the dissolved oxygen in the aerated tank was at zero, the microbial activity in the nitrification basin had died, disinfection rate was insufficient and approximately 10-12 million gallons of untreated effluent went through the plant to the receiving waters. Sampling taken at Cynamic's triple basin (Appendix G) and at Batavia WWTP (Appendix J) have overlapping presence of semi-volatiles: acetophenone, bis-(2-ethylhexyl) phthalate, diethyl phthalate, di-n-butyl phthalate, napthalene and overlapping absence of other semi-volatiles. Batavia WWTP staff noted the same odor at Cynamic triple basin as at Batavia WWTP and the combustible gas meter was activated at the highest level. Odors and combustible gas meter readings at manholes between Cynamic and Batavia WWTP indicate that the gases had been discharged to the manhole downstream from Cynamic. Samples collected at Cynamic's triple basin indicates presence of substances prohibited by the City of Batavia's sewer use ordinance which prohibits discharges that contain: (a) gasoline, benzene, naptha, fuel oil or other flammable or explosive liquid, solid or gas from being discharged to any sanitary sewer. It also prohibits (b) wastes containing a toxic, radioactive or poisonous substance in sufficient quantity to injure or interfere with any sewage treatment process, constitute a hazard to humans or animals or create any hazard in the receiving waters of the sewage treatment plant. (c) unusual chemical oxygen demand or chlorine requirements in such quantities as to constitute a significant load on the wastewater treatment works (d) unusual volume or flow or concentration of wastes constituting slugs. (e) waters or wastes containing substances which are not amenable to treatment or reduction by the wastewater treatment processes employed or are amenable to treatment only to such degree that the wastewater treatment plant effluent cannot meet the requirements of agencies having jurisdiction over discharge to the receiving waters. 2. Prohibition against discharge of toxic gases, vapor or fumes Specific prohibitions listed at 40 CFR 403.5(b)(7) state that pollutants shall not be introduced into a WWTP which result in the presence of toxic gases, vapors, or fumes within the WWTP in a quantity that may cause acute worker health and safety problems. 7 Cynamic Chemical Company CEI Inspection - March 19, 2025 Using EPA's Screening Technique to Identify Gas/Vapor Toxic Discharges, vapor concentrations collected February 25, 2025 by grab sample from Cynamic's triple basin exceeded screening levels of Napthalene, di-n-butyl phthalate, chloroform and xylenes (Appendix K). The screening technique references ACGIH threshold limit value-time weighted averages (TLV-TWA) which are the gas/vapor toxicity levels that workers may be repeatedly exposed, over a 8-hour workday and a 8-hour workweek without adverse effect. Discharges above the screening levels may warrant further investigation. City of Batavia wastewater treatment employees reported insect and invertebrate die off events in enclosed space of final clarifier at the time of incident, possibly due to toxic vapors in the wastewater. City of Batavia wastewater treatment employees reported negative health impacts, such as headaches, while performing their jobs both at the wastewater treatment facility and while servicing manholes in the collection system. 3. Prohibition against discharge of fire or explosion hazards Specific prohibitions at 40 CFR 403.5(b)(1) states that pollutants shall not be introduced into a WWTP which create a fire or explosion hazard in the WWTP, including, but not limited to, wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees Centigrade using the test methods specified in 40 CFR 261.21. Characteristic of ignitability at 40 CFR 261.21(a)(1) states that a solid waste exhibits the characteristic of ignitability if a representative sample of the waste is a liquid that has a flash point less than 60 C (140 F). Five of the pollutants that were identified present at Cynamic's triple basin had flashpoints less than 60 C (140 F). Pollutant Concentration Flashpoint 2-Chlorotoluene 3.75 mg/L 96F Acetone 3.27 mg/L 0F Ethylbenzene 0.195 mg/L 59F Xylene 0.385 85F Toluene 0.121 40F Using EPA's Screening Technique to Identify Flammable/Explosive Discharges, vapor concentrations collected February 25, 2025 by grab sample from Cynamic's triple basin approached screening levels for napthalene (Appendix L). The screening technique references 10% of the lower explosive limit (LEL). Discharges that exceed screening levels may warrant further investigation. 8 Cynamic Chemical Company CEI Inspection - March 19, 2025 A gas detector identified presence of combustible gases at Cynamic's triple basin and in the manholes leading from Batavia water treatment facility directly to the manhole closest to Cynamic's discharge point. The gas detector identifies the presence of the vapor form of napthalene, phthalates, toluene, acetone, xylenes and benzene, among other gases at levels above 10ppm. I concluded the inspection at 1:30 PM and EPA and IEPA Inspectors left the facility. 9 Cynamic Chemical Company CEI Inspection - March 19, 2025 Appendix A: Inspection Photo Log Cynamic Chemical Company EPA Inspection: March 19, 2025 All photos taken by Sophie Bazan, Physical Scientist, U.S. EPA Camera: Canon PowerShot SX230 HS Note: All timestamps are one hour earlier than photos were taken. 1: IMG_0254 Description: Ten mixers, each of varying sizes surrounding the wastewater pan. Mixers have a valve with hose connection centered above the wastewater pan. The wastewater pan is the raised silver platform. Two drums are located on a pallet sitting atop the wastewater pan. Another drum and several pails are also sitting atop the wastewater pan. At least one drum is open and several hoses are attached to the open drum. Location: Cynamic Chemical Company Date/Time: March 19, 2025 12:57 AM A1 Cynamic Chemical Company CEI Inspection - March 19, 2025 2: IMG_0255 Description: One mixer labeled "#25" is in center of frame. A valve attached to a hose is on the lower section of the mixer. To the left are six stacked IBC totes labeled as "Pull It Out". To the right is a platform. A dry mixer is located below the platform in the process of filling several fiber drums. On top of the platform off the edge is a supersack. On the floor is a noticable white powder residue. Location: Cynamic Chemical Company Date/Time: March 19, 2025 1:01 PM A2 Cynamic Chemical Company CEI Inspection - March 19, 2025 3: IMG_0256 Description: The triple basin FOG/water separator is located underneath a shelving system. Three open holes are against the wall and lids are propped up to the right of the holes. A white pipe is installed in three points into the ground adjacent to the triple basin and brown flexible tubing is located next to the pipe. Both the white pipe and brown tubing have open connections. A white tank used as a surge tank is located to the left of the triple basin. Location: Cynamic Chemical Company Date/Time: March 19, 2025 1:05 PM A3 Cynamic Chemical Company CEI Inspection - March 19, 2025 4: IMG_0257 Description: A closer view of the open holes of the triple basin. Two open holes and the white pipe are visible. A liquid is visible in each of the open holes. Location: Cynamic Chemical Company Date/Time: March 19, 2025 1:05 PM A4 Cynamic Chemical Company CEI Inspection - March 19, 2025 5: IMG_0258 Description: A floor drain is visible in foreground and the triple basin and surge tank are visible in the background. The shelving unit is visible with wrapped supplies stored above and to the right of the triple basin. Location: Cynamic Chemical Company Date/Time: March 19, 2025 1:06 PM A5 Cynamic Chemical Company CEI Inspection - March 19, 2025 6: IMG_0259 Description: Totes of empty chemicals are stored three high to be picked up by the transport company. At front are several totes that are labeled "Mineral Oil". The location of this photo is adjacent to the floor drain and triple basin from Photo 5. Location: Cynamic Chemical Company Date/Time: March 19, 2025 1:07 PM A6 Cynamic Chemical Company CEI Inspection - March 19, 2025 7: IMG_0260 Description: Manhole outside of Cynamic building where WWTP staff collected a sample of Cynamic's wastewater discharge consisting of combined process and domestic wastewaters on March 6, 2025. Location: Cynamic Chemical Company Date/Time: March 19, 2025 1:08 PM A7 Cynamic Chemical Company CEI Inspection - March 19, 2025 8 8: IMG_0261 Description: Floor drain on center of two loading docks. The dock appears to be sloped to allow liquids to flow towards drain. A truck is parked at one of the docks. The ground under the truck and surrounding most of the drain is a darker color indicating presence of a liquid. Location: Cynamic Chemical Company Date/Time: March 19, 2025 1:19 PM A8 Cynamic Chemical Company CEI Inspection - March 19, 2025 Appendix B: Aerial image of Cynamic Chemical Company Cynamic Chemical Company and neighboring businesses have been identified according to Google Business. Note: Aerial images obtained from Google Earth. Images do not represent conditions observed and are only to be used as reference. B1 Cynamic Chemical Company CEI Inspection - March 19, 2025 Appendix C: Batavia WWTP memo C1 Cynamic Chemical Company CEI Inspection - March 19, 2025 C2 Cynamic Chemical Company CEI Inspection - March 19, 2025 Appendix D: Dissolved Oxygen in Batavia WWTP Activated Sludge Screenshot of Dissolved Oxygen in Digester Level and Influent Sludge at Batavia WWTP from February 20, 2025 at 6:00 am through February 22 at 6:00 PM as a midway point. The graph indicates a drop in DO after 6am on February 20, 2025 and beginning recovery after February 22, 2025. D1 Cynamic Chemical Company CEI Inspection - March 19, 2025 Screenshot of Dissolved Oxygen in Digester Level and Influent Sludge at Batavia WWTP from February 19 at 8:30 PM to February 20, 2025 at 8:30 PM indicating a drop in DO after 6am on February 20, 2025. A smaller peak on the downward slope indicates when the backup blower was activated at DO of 2.0. D2 Cynamic Chemical Company CEI Inspection - March 19, 2025 Screenshot of Dissolved Oxygen in Digester Level and Influent Sludge at Batavia WWTP from February 20 at 5:30 AM to March 8, 2025 at 5:30 AM with a midpoint at February 28, 2025 at 5:30 AM. D3 Cynamic Chemical Company CEI Inspection - March 19, 2025 Appendix E: Gas detector used by WWTP staff with information on detection and sensitivity E1 Cynamic Chemical Company CEI Inspection - March 19, 2025 Appendix F: Manholes tested in search with tracer line indicating positive reading from gas detector and close up of manholes on Louis Bork Drive. F1 Cynamic Chemical Company CEI Inspection - March 19, 2025 Appendix G: Semivolatile, Volatile and Total Organic Carbon results from Cynamic from February 25, 2025 G1 Cynamic Chemical Company CEI Inspection - March 19, 2025 G2 Cynamic Chemical Company CEI Inspection - March 19, 2025 G3 Cynamic Chemical Company CEI Inspection - March 19, 2025 G4 Cynamic Chemical Company CEI Inspection - March 19, 2025 G5 Cynamic Chemical Company CEI Inspection - March 19, 2025 G6 Cynamic Chemical Company CEI Inspection - March 19, 2025 G7 Cynamic Chemical Company CEI Inspection - March 19, 2025 G8 Cynamic Chemical Company CEI Inspection - March 19, 2025 G9 Cynamic Chemical Company CEI Inspection - March 19, 2025 G10 Cynamic Chemical Company CEI Inspection - March 19, 2025 G11 Cynamic Chemical Company CEI Inspection - March 19, 2025 G12 Cynamic Chemical Company CEI Inspection - March 19, 2025 G13 Cynamic Chemical Company CEI Inspection - March 19, 2025 G14 Cynamic Chemical Company CEI Inspection - March 19, 2025 G15 Cynamic Chemical Company CEI Inspection - March 19, 2025 G16 Cynamic Chemical Company CEI Inspection - March 19, 2025 G17 Cynamic Chemical Company CEI Inspection - March 19, 2025 G18 Cynamic Chemical Company CEI Inspection - March 19, 2025 G19 Cynamic Chemical Company CEI Inspection - March 19, 2025 G20 Cynamic Chemical Company CEI Inspection - March 19, 2025 G21 Cynamic Chemical Company CEI Inspection - March 19, 2025 G22 Cynamic Chemical Company CEI Inspection - March 19, 2025 G23 Cynamic Chemical Company CEI Inspection - March 19, 2025 G24 Cynamic Chemical Company CEI Inspection - March 19, 2025 G25 Cynamic Chemical Company CEI Inspection - March 19, 2025 G26 Cynamic Chemical Company CEI Inspection - March 19, 2025 G27 Cynamic Chemical Company CEI Inspection - March 19, 2025 G28 Cynamic Chemical Company CEI Inspection - March 19, 2025 G29 Cynamic Chemical Company CEI Inspection - March 19, 2025 G30 Cynamic Chemical Company CEI Inspection - March 19, 2025 G31 Cynamic Chemical Company CEI Inspection - March 19, 2025 G32 Cynamic Chemical Company CEI Inspection - March 19, 2025 G33 Cynamic Chemical Company CEI Inspection - March 19, 2025 G34 Cynamic Chemical Company CEI Inspection - March 19, 2025 G35 Cynamic Chemical Company CEI Inspection - March 19, 2025 G36 Cynamic Chemical Company CEI Inspection - March 19, 2025 G37 Cynamic Chemical Company CEI Inspection - March 19, 2025 G38 Cynamic Chemical Company CEI Inspection - March 19, 2025 G39 Cynamic Chemical Company CEI Inspection - March 19, 2025 G40 Cynamic Chemical Company CEI Inspection - March 19, 2025 G41 Cynamic Chemical Company CEI Inspection - March 19, 2025 G42 Cynamic Chemical Company CEI Inspection - March 19, 2025 G43 Cynamic Chemical Company CEI Inspection - March 19, 2025 G44 Cynamic Chemical Company CEI Inspection - March 19, 2025 G45 Cynamic Chemical Company CEI Inspection - March 19, 2025 G46 Cynamic Chemical Company CEI Inspection - March 19, 2025 G47 Cynamic Chemical Company CEI Inspection - March 19, 2025 G48 Cynamic Chemical Company CEI Inspection - March 19, 2025 G49 Cynamic Chemical Company CEI Inspection - March 19, 2025 G50 Cynamic Chemical Company CEI Inspection - March 19, 2025 G51 Cynamic Chemical Company CEI Inspection - March 19, 2025 G52 Cynamic Chemical Company CEI Inspection - March 19, 2025 G53 Cynamic Chemical Company CEI Inspection - March 19, 2025 G54 Cynamic Chemical Company CEI Inspection - March 19, 2025 G55 Cynamic Chemical Company CEI Inspection - March 19, 2025 G56 Cynamic Chemical Company CEI Inspection - March 19, 2025 G57 Cynamic Chemical Company CEI Inspection - March 19, 2025 G58 Cynamic Chemical Company CEI Inspection - March 19, 2025 G59 Cynamic Chemical Company CEI Inspection - March 19, 2025 G60 Cynamic Chemical Company CEI Inspection - March 19, 2025 G61 Cynamic Chemical Company CEI Inspection - March 19, 2025 G62 Cynamic Chemical Company CEI Inspection - March 19, 2025 Appendix H: Cease and Desist Letter to Cynamic H1 Cynamic Chemical Company CEI Inspection - March 19, 2025 H2 Cynamic Chemical Company CEI Inspection - March 19, 2025 Appendix I: Chemical Oxygen Demand Results from Cynamic from March 6, 2025 I1 Cynamic Chemical Company CEI Inspection - March 19, 2025 Appendix J Semi Volatile Organics at Batavia WWTP from February 22, 2025 J1 Cynamic Chemical Company CEI Inspection - March 19, 2025 J2 Cynamic Chemical Company CEI Inspection - March 19, 2025 Appendix K: Screening Technique to Identify Gas/Vapor Toxic Discharges for Pollutants Identified in February 25, 2025 sample collected at Cynamic's Triple Basin (Appendix G) Adapted from June 1992 United States Environmental Protection Agency Guidance to Protect WWTP Workers from Toxic and Reactive Gases and Vapors, Appendix B The screening technique entails (1) identifying gas/vapor toxicity criteria; (2) conversion of gas/vapor toxicity criteria into corresponding IU discharge screening levels; (3) comparison of these screening levels with actual IU discharge levels. Discharges above the specified screening level may warrant further investigation. The toxicity criteria reference the American Conference of Governmental Industrial Hygienists (ACGIH) threshold limit value-time weighted averages (TLV-TWA) which are the gas/vapor toxicity levels are the vapor phase concentrations of volatile organic compounds to which nearly all workers may be repeatedly exposed, over a 8-hour workday and a 8 hour workweek without adverse effect. Cvap from ACGIH.org; HA from pubchem.ncbi.nlm.nih.gov K1 Cynamic Chemical Company CEI Inspection - March 19, 2025 K2 Cynamic Chemical Company CEI Inspection - March 19, 2025 Appendix L: Screening Technique to Identify Flammable/Explosive Discharges for Pollutants Identified in February 25, 2025 sample collected at Cynamic's Triple Basin (Appendix G) Adapted from June 1992 United States Environmental Protection Agency Guidance to Protect WWTP Workers from Toxic and Reactive Gases and Vapors, Appendix C The screening technique describes a procedure that will (1) Convert lower explosive limit (LEL) data into corresponding IU discharge screening levels, and (2) compare the screening levels to actual IU discharge levels. Discharges that exceed screening levels may warrant further investigation. MW, LEL and Flash Point from pubchem.ncbi.nlm.nih.gov L1 Cynamic Chemical Company CEI Inspection - March 19, 2025 L2