Document yme4kzXrxxX1n7Jkz1ZE5mZ33

EPA REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection February 22, 2024, 10:30 a.m. (CST) Announced: No February 22, 2024, 05:30 p.m. Access: Granted (CST) Rainy, drizzle, off and on through the day Water Clean Water Act, National Pollutant Discharge Elimination System (NPDES) permit program Industrial Stormwater Inspection (ISI) Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Mailing Address (If different) Danone US, LLC Danone 216 Southgate Drive Minster, OH 45865 40.3836, -84.3748 Elizabeth.MASTELLER@danone.com FRS ID 110000395787 Permit Number(s) (If Applicable) OH0078531 SIC and/or NAICS 31151 Lead Inspector: William Jones WILLIAM [Signature] JONES Digitally signed by WILLIAM JONES Date: 2024.04.22 15:00:39 -05'00' EPA REGION 5 Jones.William@epa.gov (312) 886-6058 Supervisor Review: Molly Smith MOLLY S[SMigInTaHture] Digitally signed by MOLLY SMITH Date: 2024.04.22 15:57:32 -05'00' EPA REGION 5 Smith.Molly@epa.gov SECTION I - INTRODUCTION Site Entry and Inspection Objectives EPA Region 5 Lead Inspector, William Jones, arrived at Danone (the "Site" or "Facility"), located at 216 Southgate Drive, Minster, Ohio 45865, at 10:30 a.m. (CST) on February 22, 2024, for an unannounced inspection. EPA Region 5 Lead Inspector presented credentials to Dave Merritt and informed them that this was an EPA Region 5 inspection to investigate elements as authorized by Clean Water Act (CWA) Section 308 and 1 of 31 Danone Inspection Date(s): 2-22-2024 implementing regulations. This report is based on information supplied by Danone representatives, direct observations made by EPA Region 5 inspectors, records and reports maintained by the permittee and other information including: photographs taken by EPA Region 5 inspector(s), verbal or written statements made by information supplied by Danone representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 5 inspector(s) by Danone representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of US Environmental Protection Agency (EPA), state, and/or public records may be included in this report. Attendees Organization EPA REGION 5 EPA Region 5 Danone Danone Danone Danone Danone Attendee Name William Jones Joe Forth Dave Merritt Brian Scott Elizabeth Masteller Adam Milner Toby Goecke Title Lead Inspector Environmental Engineer Senior Plant Director Senior Maintenance Manager Senior EHS Manager Engineering Director Production Director Present in Opening Conf. Yes Yes Yes Yes Yes No No Present in Closing Conf. Yes Yes Yes Yes Yes Yes Yes Facility/Site Description EPA REGION 5 lead inspector confirmed the following facility information: Facility/Site Information Location(s) Location/Area/Sub-area Storm Sewer Outfall Facility Storm Outfalls Outdoor material Outdoor refueling area Graham packaging receiving area Pretreatment Plant Description Storm Sewer Outfall into Miami-Erie Canal Permitted outfall locations on north side of facility Outdoor material area located at the main plant Outdoor refueling area located at the main plant Receiving area located at the main plant This is a separate area where their process wastewater is treated before it goes to the Village of Minster SECTION II - OBSERVATIONS Location: Storm Sewer Outfall Observation #: WJ1-OB-001 Date: February 22, 2024 Weather: rainy The storm sewer that Danone reportedly discharges into appeared to be relatively clear where it entered the 2 of 31 Danone Inspection Date(s): canal. Photo(s) 1 to 3 2-22-2024 Location: Facility Storm Outfalls Observation #: WJ1-OB-002 Date: February 22, 2024 Weather: rainy The storm sewer outfalls (1, 2 and 4) that Danone has on the northside of the building are controlled with valves, which are normally kept closed and which would have to be opened for a discharge to occur. The storm pond in this location would overflow back to one of the outfalls. Photo(s) 4 to 8 Location: Outdoor material area Observation #: WJ1-OB-003 Date: February 22, 2024 Weather: rainy Photos 9-11 show an area where metal is discarded into hoppers. The metal appeared oily and there was metal outside of the uncovered hoppers, along with an oily sheen on the ground leading towards a storm drain. Photo 12 shows an outdoor material area that is mainly under a roof. Photo(s) 9 to 12 Location: Outdoor refueling area Observation #: WJ1-OB-004 Date: February 22, 2024 Weather: rainy Photos 13 and 14 shows a refueling area with used absorbent material left on the ground. An oily sheen can be seen in one of the photos. Photo(s) 13 to 14 Location: Graham packaging receiving area Observation #: WJ1-OB-005 Date: February 22, 2024 Weather: rainy Plastic pellets (white granules) were observed outdoors on the ground. Photo(s) 15 to 16 Location: Pretreatment plant 3 of 31 Danone Inspection Date(s): 2-22-2024 Observation #: WJ1-OB-006 Date: February 22, 2024 Weather: rainy Recent grading work has left the ground unstabilized and muddy water is making its way into the storm drain inlets, which drain to storm water outfall 3. Photo(s) 17 to 21 SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: Facility Map Ref #: WJ1-RR-001 Reviewed By: William Jones AOC: No Reviewed Date: November 2, 2023 A map of the facility was emailed to William Jones that shows the storm drain inlets and connections. This verified that the locations in the main facility. Photos attached are connected to the storm sewer pipe on the on the side of the facility that runs underneath First Street. Also, the Graham packing facility has storm drains outside of it that connect into the same storm sewer system. See Appendix 3 for a summary of effluent exceedances. SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. 4 of 31 Danone Inspection Date(s): 2-22-2024 SECTION V - AREAS OF CONCERN Permit OH0078531, Part I, A. Final Effluent limitations and Monitoring Requirements Permit OH0078531, Part IV, C.1 "You shall minimize the exposure of manufacturing, processing, and material storage areas (including loading and unloading, storage, disposal, cleaning, maintenance, and fueling operations) to rain, sno, snowmelt and runoff by either locating these industrial materials and activities inside or protecting them with storm resistant coverings...." Permit OH0078531, Part IV, C.2 "Good housekeeping. You shall keep clean all exposed areas that are potential sources of pollutants using such measures as sweeping at regular intervals, keeping materials orderly and labeled, and storing materials in appropriate containers." Permit OH0078531, Part IV, C.4 "Spill Prevention and Response Procedures. You shall minimize the potential for leaks, spills and other releases that may be exposed to stormwater and develop plans for effective response to such spills if or when they occur. At a minimum, you shall implement:...c. Procedures for expeditiously stopping, containing, and cleaning up leaks, spills, and other releases..." Permit OH0078531, Part IV, C.5. "Erosion and Sediment Controls. You shall stabilize exposed areas and contain runoff using structural and/or non-structural control measures to minimize onsite erosion and sedimentation, and the resulting discharge of pollutants..." See above observations in section 2 and 3 related to the areas of concern. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA REGION 5 Lead Inspector held a closing conference with Facility personnel at 04:55 p.m. (EST) on October 25, 2023, for the inspection. During the closing conference, EPA REGION 5 Lead Inspector discussed the observations and Area(s) of Concern identified during the inspection. Observations and Area(s) of Concern have not yet been evaluated for a formal compliance determination. William Jones, along with the attendees listed above, were present for the closing conference. Mr. Jones shared that the observations and Areas of Concern were preliminary. Mr. Jones confirmed that no information gathered was considered Confidential Business Information. A copy of the Storm Water Pollution Prevention Plan, plant layout showing storm sewers and detention pond were requested. Information was requested for when the Facility started to discharge indirectly to Minister, as was dates of the storm water training of the Facility team. Mr. Jones stated that the spill of diesel needed to be recorded in the SWPPP. He also noted that the Facility's SWPPP inspections are not in the binder. The training log was not up to date. The housekeeping on the site was not good in the areas with the oily metal scrap bins with the oily sheen on the ground. Also, the refueling tank spill was not cleaned up properly with the absorbent material left behind. The plastic pellets we observed near the Graham area needed to be addressed. At the Pretreatment area, the sediment laden water running into the outfall from the disturbed area needed to be addressed. Elizabeth Masteller indicated that January 11th, 2024, was the last time the Facility opened stormwater outfall 1 5 of 31 Danone Inspection Date(s): and 2. Follow Up The following items were requested by the inspector at the time of the inspection. Location: WJ1-AF-001 Area: Sub-area: Facility storm drain map, which was emailed during the inspection to William Jones. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 3. Discharge Monitoring Report results 2-22-2024 6 of 31 Danone Inspection Date(s): APPENDIX 1: PHOTO LOG 2-22-2024 Photograph 1. Storm Sewer Outfall into Miami Erie Canal February 22, 2024/1:17 p.m. No PII Near Canal (45) and First Street North-east IMGP0001.JPG Photographer: William Jones 7 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 2. Storm Sewer Outfall into Miami Erie Canal. Same outfall as photo 1. February 22, 2024/1:18 p.m. No PII Near Canal (45) and First Street Camera Direction: South-west IMGP0002.JPG Photographer: William Jones 8 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 3. Storm Sewer Outfall into Miami Erie Canal. Same outfall as photo 1. February 22, 2024/1:18 p.m. No PII Near Canal (45) and First Street Camera Direction: South-east IMGP0003.JPG Photographer: William Jones 9 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 4. Danone outfall 002 and sign February 22, 2024/1:43 p.m. No PII near south main street and first street Camera Direction: South-west IMGP0004.JPG Photographer: William Jones 10 of 31 Danone Inspection Date(s): 2-22-2024 Photo 5. Manhole near outfall 001. Mr. Scott believes IMGP0005.JPG the pipe passing though the chamber is a sanitary line. February 22, 2024/1:52 p.m. Northside of Danon building Looking down into manhole No PII Photographer: William Jones 11 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 6. Outfall 001 with sign. February 22, 2024/1:53 p.m. No PII IMGP0006.JPG Photographer: William Jones Northside of Danon Building and South of First street View looking south 12 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 7. Outfall 004 IMGP0007.JPG February 22, 2024/1:59 p.m. No PII Northside of Danone facility and south of First Street View looking south Photographer: William Jones 13 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 8. Sampling area at retention pond February 22, 2024/2:03 p.m. No PII Northside of facility and south of First Street View looking south IMGP0008.JPG Photographer: William Jones 14 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 9. Uncovered metal recycling hoppers. An oily sheet can be seen IMGP0009.JPG on the pavement coming from the hoppers February 22, 2024/2:34 p.m. No PII Photographer: William Jones Shipping/loading area at Danone View looking southwest 15 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 10. Uncovered metal recycling hoppers. Metal is outside of the hoppers. An oily sheen can bee seen on the ground. February 22, 2024/2:33 p.m. No PII Shipping/loading area View looking south IMGP0010.JPG Photographer: William Jones 16 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 11. Oily metal was observed inside the hoppers. An oily sheen was flowing towards a storm drain inlet in the top of the photograph February 22, 2024/2:35 p.m. No PII Recycling hoppers and shipping area IMGP0011.JPG Photographer: William Jones View looking east 17 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 12. Miscellaneous equipment storage February 22, 2024/2:39 p.m. No PII Shipping and loading area. Looking Northwest IMGP0012.JPG Photographer: William Jones [Geographic Coordinates] 18 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 13. Diesel Fuel tank with spill cleaning materials around the tank. An oily sheen can be seen at the bottom left of the photo. February 22, 2024/2:46 p.m. No PII Northweast side of shiping area View looking Northeast IMGP0013.JPG Photographer: William Jones 19 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 14. Diesel Fuel tank with fuel cleanup materials present around refueling area. It was raining during the inspection. The drain valve appeard to be open and water was draining out of it. February 22, 2024/2:49 p.m. No PII Northeast side of shipping area. View looking west IMGP0014.JPG Photographer: William Jones 20 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 15. Graham Packaging Receiving area. Pleastic pellets were observed on the ground. February 22, 2024/2:56 p.m. East side of the general shipping area. View looking west No PII IMGP0015.JPG Photographer: William Jones 21 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 16. Graham Packaging Receiving area. Pleastic pellets were observed on the ground February 22, 2024/2:56 p.m. No PII East side of the general shipping area. View looking west IMGP0016.JPG Photographer: William Jones 22 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 17. Silty water can be seen flowing from IMGP0017.JPG the unstabilized area near the center of the photograph to the bottom left corner of the photograph. February 22, 2024/3:15 p.m. No PII Photographer: William Jones Driveway at Danone Wastewater Pretreatment Plant. View looking northeast 23 of 31 Danone Inspection Date(s): 2-22-2024 Photo 18. Silty water can be seen flowing from the right of the photograph to the left. This is the same flow of water that is show in photograph 17. February 22, 2024/3:15 p.m. No PII Driveway at Danone Wastewater Pretreatment Plant. View looking Northeast IMGP0018.JPG Photographer: William Jones 24 of 31 Danone Inspection Date(s): 2-22-2024 Photo 19. Silty water can be seen flowing from the top IMGP0019.JPG center of the photograph to the storm drain inlet at the bottom of the phtograph. This is the same flow of water that is show in photograph 18. Date/Time: February 22, 2024/3:18 p.m. No PII Photographer: William Jones Driveway at Danone Wastewater Pretreatment Plant. View looking Northeast 25 of 31 Danone Inspection Date(s): 2-22-2024 Photograph 20. Storm Drain inlet/location of outfall 003 February 22, 2024/3:19 p.m. No PII West side of Danone Wastewater Pretreatment Plant View looking west IMGP0020.JPG Photographer: William Jones Photograph 21. Moving Bed Biofilm Reactor process February 22, 2024 No PII Danone Wastewater Pretreatment Plant View looking west IMGP0021.JPG Photographer: William Jones 26 of 31 Danone Inspection Date(s): APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By CBI PII 2-22-2024 Date Received 27 of 31 Danone Inspection Date(s): APPENDIX 3: Discharge Monitoring Report (DMR) results 2-22-2024 Table 1. DMR Outfall Limits Parameter Desc 001 Solids, total suspended 001 Solids, total suspended 001 Solids, total suspended 001 Solids, total suspended BOD, 001 carbonaceous [5 day, 20 C] BOD, 001 carbonaceous [5 day, 20 C] BOD, 001 carbonaceous [5 day, 20 C] BOD, 001 carbonaceous [5 day, 20 C] BOD, 001 carbonaceous [5 day, 20 C] BOD, 001 carbonaceous [5 day, 20 C] BOD, 001 carbonaceous [5 day, 20 C] Oil and 001 grease [soxhlet extr.] tot. BOD, 001 carbonaceous [5 day, 20 C] BOD, 001 carbonaceous [5 day, 20 C] BOD, 001 carbonaceous [5 day, 20 C] 001 BOD, Statistical Base Short Desc DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG MO AVG Units mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l Limit 45 30 45 30 23 15 23 15 15 23 15 10 15 23 15 15 Monitoring result 129.375 129.375 66 66 32 32 58 58 16 54 54 12 22 78 78 20.25 Monitoring Period End Date 06/30/2019 06/30/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 11/30/2020 11/30/2020 03/31/2021 09/30/2021 09/30/2021 12/31/2021 01/31/2022 03/31/2022 03/31/2022 05/31/2022 DMR Value Received Date 7/10/2019 7/10/2019 11/12/2019 11/12/2019 11/12/2019 11/12/2019 12/11/2020 12/11/2020 4/12/2021 10/6/2021 10/6/2021 1/13/2022 2/15/2022 4/14/2022 4/14/2022 6/13/2022 Percent Exceedance 188% 331% 47% 120% 39% 113% 152% 287% 7% 135% 260% 20% 47% 239% 420% 35% 28 of 31 Danone Inspection Date(s): carbonaceous [5 day, 20 C] BOD, 001 carbonaceous DAILY MX mg/l 23 [5 day, 20 C] BOD, 001 carbonaceous MO AVG mg/l 15 [5 day, 20 C] Oil and 001 grease DAILY MX mg/l 10 [soxhlet extr.] tot. BOD, 001 carbonaceous MO AVG mg/l 15 [5 day, 20 C] BOD, 001 carbonaceous MO AVG mg/l 15 [5 day, 20 C] BOD, 002 carbonaceous MO AVG mg/l 15 [5 day, 20 C] 002 Solids, total DAILY MX mg/l 45 suspended 002 Solids, total MO AVG mg/l 30 suspended BOD, 002 carbonaceous DAILY MX mg/l 23 [5 day, 20 C] BOD, 002 carbonaceous MO AVG mg/l 15 [5 day, 20 C] BOD, 002 carbonaceous DAILY MX mg/l 23 [5 day, 20 C] BOD, 002 carbonaceous MO AVG mg/l 15 [5 day, 20 C] BOD, 002 carbonaceous DAILY MX mg/l 23 [5 day, 20 C] BOD, 002 carbonaceous MO AVG mg/l 15 [5 day, 20 C] BOD, 002 carbonaceous DAILY MX mg/l 23 [5 day, 20 C] BOD, 002 carbonaceous MO AVG mg/l 15 [5 day, 20 C] 002 BOD, DAILY MX mg/l 23 24.78 12/31/2022 1/10/2023 24.78 12/31/2022 1/10/2023 23.4 02/28/2023 3/6/2023 19.64 02/28/2023 3/6/2023 20.69 05/31/2023 6/7/2023 18.87 05/31/2019 6/10/2019 120 10/31/2019 11/12/2019 120 10/31/2019 11/12/2019 140 10/31/2019 11/12/2019 140 10/31/2019 11/12/2019 40 01/31/2020 2/10/2020 40 01/31/2020 2/10/2020 52 01/31/2021 2/9/2021 52 01/31/2021 2/9/2021 54 01/31/2022 2/15/2022 54 01/31/2022 2/15/2022 28 03/31/2022 4/14/2022 29 of 31 2-22-2024 8% 65% 134% 31% 38% 26% 167% 300% 509% 833% 74% 167% 126% 247% 135% 260% 22% Danone Inspection Date(s): carbonaceous [5 day, 20 C] BOD, 002 carbonaceous MO AVG mg/l 15 [5 day, 20 C] BOD, 004 carbonaceous MO AVG mg/l 15 [5 day, 20 C] 28 03/31/2022 4/14/2022 18.87 05/31/2019 6/10/2019 2-22-2024 87% 26% 30 of 31 Danone Inspection Date(s): 2-22-2024 31 of 31