Document zQJaodoe1rQz8MMyMed27pbjn

COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5 Purpose: NPDES Compliance Evaluation Inspection Facility: Rock Island Arsenal (RIA) 1 Rock Island Arsenal Rock Island, Illinois, 61299 NPDES Permit: ILR001154 Date of Inspection: August 1 - 2, 2023 EPA Inspectors: Val Dooling, Environmental Engineer, (312) 886-7167 Eric Small, Physical Scientist, (312) 886-6680 Rock Island Arsenal Representatives: Diana Gilbert, Stormwater Program Manager, (309) 782-3604 Laura St. Louis, Environmental Coordinator, (309) 782-5366 Sandra Black, Environmental Protection Specialist, (309) 782-2801 Report Prepared By: Val Dooling, Environmental Engineer EPA Inspector Signature and Date: VALERIE Digitally signed by VALERIE DOOLING _D_O__O__L_IN__G_____10_:5_4:4_3_-0_5'_00_' ________________________ Date: 2023.10.06 Approver Name and Title: Ryan J. Bahr, Section 2 Supervisor Water Enforcement and Compliance Assurance Branch Approver Signature and Date: MOLLY Digitally signed by MOLLY SMITH _S_M__I_T_H________13_:4_0:0_5_-0_5'_00_' ________________________ Date: 2023.10.06 TABLE OF CONTENTS I. Introduction ........................ 1 II. Background ........................ 1 III. Opening Conference............ 1 IV. Stormwater Discussion......... 3 V. Stormwater Site Visit............ 6 VI. Pretreatment Discussion........ 9 VII. Pretreatment Site Visits........ 9 VIII. Closing Conference............ 10 LIST OF APPENDICES Appendix A: Photo Log Appendix B: Aerial Facility Image Appendix C: NPDES Permit Sector Specific Requirements Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 I. INTRODUCTION The purpose of the report is to describe, evaluate and document the Rock Island Arsenal's compliance with the Clean Water Act (CWA) and its National Pollutant Discharge Elimination System (NPDES) permit. II. BACKGROUND On August 1 - 2, 2023, EPA conducted a Clean Water Act Compliance Evaluation Inspection at the Rock Island Arsenal facility, a federal facility, as part of an announced multi-media inspection. Rock Island Arsenal (RIA) holds a stormwater National Pollutant Discharge Elimination System (NPDES) Stormwater Permit for Industrial Activity (Appendix C) since 1994. According to the Stormwater Pollution Prevention Plan, the industrial activities present at the facility are: abrasive blasting, electroplating, foundry, industrial furnaces, hazardous waste generation and storage, heat treatment and forging, machining, print shop, rubber coating, salt storage, surface coating, test firing, vehicle maintenance, welding and woodworking. In addition to its stormwater permit, RIA is permitted to discharge pretreated industrial wastewater from Buildings 212 and 299 under an Industrial User Permit with the City of Rock Island, Illinois and the National Categorical Pretreatment Standard 40 Code of Federal Regulations (CFR) 433 Metal Finishing regulations. III. OPENING CONFERENCE On August 1 - 2, 2023, Eric Small and I (CWA EPA Inspectors) arrived at the Rock Island Arsenal facility as part of a U.S. EPA multi-media inspection focusing on Clean Water Act, Safe Drinking Water Act and underground storage tanks inspections. I was joined by Cher Benisek, Thomas Swenson, Joan Rogers, and Arturo Cisneros all of U.S. EPA and Andrew Holloway and Sneh Patel of Illinois EPA. We met with Rock Island Arsenal Garrison environmental representatives Laura St. Louis, Environmental Coordinator, Diana Gilbert, Stormwater Program Manager and Sandra Black, Environmental Protection Specialist. At the Opening Conference we were joined by the Garrison leadership representatives of Dan Mitchell, Garrison Commander, Eric Brown, Garrison Sargent Major and Gary Koski, Director of Public Works. A full list of the individuals present is listed in Table 1. Cher Benisek introduced the scope and objectives of the multimedia inspection and explained that as part of the inspections EPA would take photographs and asked if anything discussed was Confidential Business Information. Each EPA Inspector then showed their inspector credentials to the Rock Island Arsenal Garrison representatives present. 1 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 Table 1. Name Val Dooling Cher Benisek Eric Small Title/Organization Phone Email Inspector/EPA 312-886-7167 Dooling.Valerie@epa.gov Inspector/EPA 440-250-1710 Benisek.Cher@epa.gov Inspector/EPA 312-886-6680 Small.Eric@epa.gov Present Opening Closing CWA Site Confer Confer Walkthrough Yes Yes Yes Yes Yes No Yes Yes Yes Diana Gilbert Stormwater Programs 309-782-3604 Diana.L.Gilber12civ@army.mil Yes Yes Yes Laura St. Louis Environmental 309-782-5366 Laura.R.Stlouisciv@army.mil Yes Yes Yes Coordinator Sandra Black Environmental 309-782-2801 Sandra.L.Black13.ciu@army.mil Yes Yes Yes Protection Specialist Dan Mitchell Garrison Commander 309-782-7722 Daniel.DMitchell.alil@army.mil Yes Yes No Gary Koski Director DPW 309-782-3825 Gary.R.Koski.civ@army.mil Yes Yes No Eric Brown Garrison Sargent 210-996-4796 James.c.Brown42@army.mil Yes Yes No Major Arturo Cisneros Inspector/EPA 312-886-7447 Cineros.Arturo@epa.gov Yes No No Joan Rogers Inspector/EPA 312-886-2785 Roger.Joan@epa.gov Yes Yes No Thomas Swenson Inspector/EPA 312-886-5265 Swenson.Thomas@epa.gov Yes Yes No Andrew Holloway Env. Engineer 815-987-2388 Andrew.Holloway@illinois.gov Yes Yes No Sneh Patel Env. Engineer 847-294-4362 Sneh.Patel@illinois.gov Yes Yes No 2 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 IV. STORMWATER DISCUSSION The RIA has been a military installation since the last 1800 and has had multiple uses. Previously, it had a prisoner of war camp during the Civil War, a hospital during World War I and had temporary warehouses during World War II. Currently, the Army Garrison owns most of the land on the RIA with Veterans Affairs and U.S. Army Corps of Engineers owning parts of the island and a total of eight tenants operate on the island. The RIA first applied for and received its NPDES Permit for Stormwater Discharges from Industrial Activity in 1994. Its most recent Notice of Intent submission was on July 17, 2023. There are 14 outfalls on the island that convey stormwater to the Mississippi River and each correspond to a unique drainage area. According to the Stormwater Pollution Prevention Plan (SWPPP), the RIA is located on 155 acres within five industrial activity zones. Electroplating processes and foundry building are located in Zone 2. Hazardous waste generation is located in Zones 2 and 5. Test firing is located in Zone 5. The SWPPP states that in all zones there is industrial activity which requires sector specific testing. Appendix C lists all additional sector benchmarks monitoring, indicator monitoring and additional requirements that are applicable at all outfalls. The RIA has not changed any of its processes or zones from the last NPDES inspection which occurred in 2018. The RIA is located on the Mississippi River and has intermittent flooding each year. During flood times, the Garrison erects Hesco flood barriers in areas on the north, northwest and southwest that are in expected flood zones. During the flooding events, the stormwater outfalls are closed to prevent elevated river water from flowing into the stormwater system. The last dry weather storm sampling event to evaluate the need for unauthorized non-stormwater discharges was from 2013. Ms. Gilbert stated that there is one scheduled to occur within the year. The November 2013 results indicated that the sanitary sewer was not infiltrating or tied into the storm sewer network. There were higher counts of magnesium, herbicide and fecal coliform counts which indicated road salt, weed killers and animal feces. Monitoring The SWPPP lists applicable SIC codes: 9711, 24, 27, 30, 33, 35. A two-digit standard industrial classification (SIC) code is listed in the SWPPP for some industries and a four-digit SIC code for others. Illinois ILR10 Permit Attachment 2 Sector Specific Requirements determines which sector requirements are applicable using four digit SIC codes. See Table s which is adapted from Illinois ILR10 Permit Attachment 2 Sector Specific Requirements in which multiple subsectors could apply for each of the two-digit SIC codes 24, 33, and 34. 3 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 Table 2. SIC Code Lis ted on RIA SWPPP ILR10 Attachment 2 Subsector SIC Code or Activity Represented Activity Code S ector A: Timber Products A1 2421 General Sawmills and Planing M ills A2 2491 Wood Preserving A3 2411 Log Storage and Handling 2426 Hardwood Dimension and Flooring M ills 2429 Special Product Sawmills, Not elsewhere Classified 2431-2439, M ilwork, Veneer, Plywood and Structural Wood 24 expect 2434 A4 2448 Wood Pallets and Skids 2449 Wood Containers, Not elsewhere classified 2451, 2452 Wood Buildings and M obile Homes 2493 Reconstituted Wood Products 2499 Wood Products, not else where Classified 2441 Nailed and Lock Corner Wood Boxes and Shook S ector X: Printing and Publishing 27 X1 2711 - 2796 Printing, Publishing, and Allied Industries S ector Y: Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries 3011 Tires and Inner Tubes 3021 Rubber and Plastics Footwear 30 Y1 3052, 3053 Gaskets, Packing and Sealing Devices, and Rubber and Plastic Hoses and Belting 3061, 3069 Fabricated Rubber Products, Not elsewhere Classified 3081 - 3089 M iscellaneous Plastics Products S ector F: Primary Metals F1 2212-3317 Steel Works, Blast Furnaces and Rolling and Finishing M ills F2 3321-3325 Iron and Steel Foundries F3 3351-3357 Rolling, Drawing and Extruding of Nonferrous M etals 33 F4 3363-3369 Nonferrous Foundries (Castings) 3331-3339 Primary Smelting and Refining of Nonferrous M etals F5 3341 Secondary Smelting and Refining of Nonferrous M etals 3398, 3399 M iscellaneous Primary M etal Products S ector AA: Fabricated Metal Products 3411 - 3499 Fabricated M etal Products, Except M achinery and Transportation Equipment and 34 AA1 (except 3479) coating, Engraving and Allied Services AA2 3479 Fabricated M etal Coating and Engraving According to the SWPPP, benchmark testing is conducted at all 14 outfalls for chemical oxygen demand (COD), total suspended solids (TSS), total aluminum, total zinc, total copper, total iron, nitrate plus nitrite and water hardness. All benchmark requirements and all sector specific requirements, including benchmark and indicator monitoring that are applicable to RIA according to the NPDES Illinois ILR00 Attachment 1 are listed in Appendix C. Additionally, the receiving water for stormwater is the Mississippi River, which is impaired for mercury, polychlorinated biphenyls (PCB) and fecal coliform, but does not have any total maximum daily load (TMDL) established. RIA also tests PCBs and mercury, but fecal coliform is not tested as it is not a byproduct of any manufacturing process. 4 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 Table 3 lists all 2021 and 2022 yearly average samples that exceeded sector specific benchmarks. Of the 14 outfalls, approximately 50% of outfalls surpassed aluminum benchmarks and over 50% of outfalls surpassed nitrate plus nitrate benchmarks in both years. Table 3 Sampling Name Outfall D93 Outfall D92 Outfall D98 Outfall D105 Outfall F14 Sluice Gate 295 Pump Station 295 Outfall E56 Outfall 127 Outfall C39 Outfall C45 Sluice Gate and Catch Basin SE A20 Sluice Gate Outfall ID 1 2 3 4 5 6 7 8 9 10 11 13 14 Analyte Nitrate + Nitrite Aluminum COD Nitrate + Nitrite TSS Aluminum TSS Aluminum Nitrate + Nitrite Nitrate + Nitrite Aluminum Nitrate + Nitrite Aluminum Nitrate + Nitrite Nitrate + Nitrite TSS Aluminum Nitrate + Nitrite Aluminum TSS Nitrate + Nitrite Aluminum TSS Nitrate + Nitrite Aluminum Nitrate + Nitrite TSS Aluminum Zinc TSS Nitrate + Nitrite Aluminum Benchmark (mg/L) 0.68 1.1 120 0.68 100 1.1 100 1.1 0.68 0.68 1.1 0.68 1.1 0.68 0.68 100 1.1 0.68 1.1 100 0.68 1.1 100 0.68 1.1 0.68 100 1.1 0.23 100 0.68 1.1 2022 Average (mg/L) 1.4 1.5 123 1.1 162 10.9 1.0 2.08 0.98 0.88 0.8 670 2.32 1.43 1.16 0.92 2.4 1.0 2.0 2001 19 2.0 1.0 2021 Average (mg/L) 413 2.03 0.98 1.38 2.29 1.39 1.24 1.1 0.73 131 1.4 1 4.7 605 6.01 140 1.7 1.75 1.5 187 5.8 Ms. Gilbert acknowledged that some sampling had exceeded benchmark levels are stated that they are reviewing whether control measures modifications are necessary. Ms. Gilbert stated that as part of the dry weather sampling test, she expects natural background pollutant levels could contribute to the exceedance of the benchmark, but at this time that has not been characterized or ruled out as a pollutant source. 5 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 V. STORMWATER SITE VISIT On August 2, 2023, at 8:00 am, EPA CWA Inspectors and Ms. Gilbert visited stormwater controls located in yards outside the fueling station, hazardous waste storage, former coal pile, foundry yard, salt storage dome, outdoor Jeep storage area, and dumpster storage area. The sample monitoring points for outfalls 5, 6, 7 and 13, and Outfalls 10 and 11 were also visited. The hazardous waste storage building is located in Industrial Zone 1 and discharges to Outfall 5. All hazardous waste is stored indoors and I did not see any stored outdoors. Ms. Gilbert stated that a rubber inlet plug to protect the inlet from hazardous material spills is located at the building in case of a spill which escapes the facility. Also, the employees perform weekly inspections of the hazardous waste area. We also viewed the sampling point for Outfall 5 which is the nearest upstream valve. The location of Outfall 5 is beyond the fence line in a marshy area and was not accessible. Ms. Gilbert stated that all stormwater inspections take place at this monitoring point and not the actual outfall. We next viewed the fueling station which is outside of the drainage area of Outfall 5. The fueling area is open for Garrison employes and a limited number of others, but not for outside contractors. Fuel is stored in a double walled above ground storage tank. According to Ms. Gilbert, the entire fueling area acts as secondary containment and a spill kit is present, if needed. In Industrial Zone 2, we walked south on Sylvan Drive along the south end of the former coal pile. Ms. Gilbert pointed out yellow markers indicating monitoring wells. In an earlier conversation, I spoke with Scott Adner, Physical Scientist, who was familiar with the former coal piles. Mr. Adner stated that the coal pile is a Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) site with nested groundwater wells monitoring for metals and semi volatiles. In 2019 - 2020, the site was excavated and filled with clean gravel. Ms. Gilbert stated that in the next year, this area will be used for solar and reciprocating internal combustion engine (RICE) generator installation. After completion of the initial excavation, older aerial photographs identified a larger coal pile that expands the CERCLA site into three other areas which have not yet been excavated. According to Mr. Adler, there are currently nine monitoring wells and he is expecting on adding 28 more at multiple depths. South of the former coal pile area, we viewed the valves upstream of Outfalls 6 and 7 which serve as the sampling monitoring points. Ms. Gilbert stated that the outfalls are located beyond the fenceline in a marshy area and are not accessible. We drove to the foundry yard on the west of the foundry building. At this location a dumpster for sand mold waste is located under a canopy roof. We observed some sand molds that were on the ground, outside of the roof. Ms. Gilbert spoke with foundry staff who stated that the procedure is to let the sand cool on the ground first then transfer it under roof to the dumpster. They assured us that all the sand that was observed had only been placed there that morning and would be removed by the end of the day. I asked Ms. Gilbert if the protocols change when wet weather is expected, and she stated that the foundry staff do not put the hot waste sand molds outside on the ground during wet weather. There was a nearby inlet with a drain filter to keep sand from entering the stormwater system. I observed there was sand and some debris on the filter. Ms. 6 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 Gilbert stated that JMTC is assigned to replace the inlet filter as needed. Also, in the foundry yard, I observed a sign for "Emission Control Dust" hazardous waste accumulation area. I saw some barrels labeled hazardous waste and I did not observe secondary containment for the hazardous waste in this area. Ms. Gilbert stated that the dry scrubbers for the foundry building and for Building 299 are indoors. We viewed dumpster storage areas south of multiuse Building 299. I observed that many of these dumpsters were open or did not have lids. At this site only wood pallets had been discarded into the dumpsters. We also viewed the storage area that is identified as outdoor Jeep storage. I saw vehicles, trailers and other miscellaneous dry storage located there. Ms. Gilbert stated that in 2029 this will be phased out as a storage area and a structure is expected to be built. We drove to the salt storage dome that is north of the outdoor Jeep storage. At this location I viewed some erosion, white staining on the ground and salt spillage in the loading area. Ms. Gilbert stated there is already an approved regrading project for later this year to repair the erosion. Flow from Industrial Zones 3 and 4 discharge to Outfalls 10 and 11. There was recent construction at these two outfalls to separate a previously combined outfall into two separate discharge points. Although construction has been completed, the NPDES Stormwater Permit for Construction Activity is still active since the vegetative cover has not reached sufficient percentage to close out the permit. Ms. Gilbert stated that the first round of seeding did not take, and another round of seeding will be scheduled. Both Outfalls 10 and 11 were easily accessible and had new riprap. Stormwater samples are collected at the outfalls and not at the valve upstream like at the other outfalls we visited. I observed some flow in each of the two outfalls. Since it was dry weather, Ms. Gilbert was not sure where it was orginating but stated that there is a dry weather sampling event scheduled within the year which could identify the source. Earlier in the day, near the office, I had observed a utility crew working at a utility manhole near the office. Ms. Gilbert stated that since the island has such a high-water table, sitting water in the utility and communication manholes have to be pumped weekly. When asked where the water is discharged to, Ms. Gilbert stated that it is discharged to a stormwater manhole, although this particular utility manhole was in a different discharge area. Ms. Gilbert stated that there is boat storage and launch for rescue on the Mississippi River. There is no cleaning or fueling or maintenance for the boat on the installation. There is minor vehicle maintenance in Zone 3; oil changes could occur here, but not major repairs. Neither the boat storage nor vehicle maintenance areas were viewed as part of the facility site visit. Next, we drove to the historic weapons test range in Industrial Zone 5. No test weapons are discharged outdoors anymore and the firing range is currently indoors. I viewed the sampling point for Outfall 13 which is the nearest upstream pump since the outfall is not accessible. Near this location, I noticed a discharge pipe that was installed at the edge of the island and there was a hose line depression in the grass leading up to the discharge pipe. Ms. Gilbert stated that this discharge point was in use during flood events when Outfall 13 was closed to prevent inundation of floodwater into the stormwater system. A temporary sump pump was used at the last flood 7 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 event to pump out stormwater in low lying areas to the discharge point. On the stormwater inlet leading to Outfall 13, I noticed sediment and vegetation on the inlet. Ms. Gilbert stated that this inlet did not have a filter. Ms. Gilbert stated that the sidewalk snowplows can harm vegetation and create erosional areas throughout the entire island. In areas where this occurs, straw wattles are installed at the inlet to prevent sediment from entering the stormwater system. I viewed one such inlet near the office. We completed the stormwater portion of the facility site visit on August 2, 2023 at 11:46 am. 8 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 VI. PRETREATMENT DISCUSSION RIA is an Industrial User of the City of Rock Island, Illinois and is regulated under an Industrial User Permit with the City of Rock Island, Illinois and the National Categorical Pretreatment Standard 40 Code of Federal Regulations (CFR) 433 Metal Finishing regulations. Building 212 and Building 299 each have pretreatment units after its categorical metal finishing industrial process. After pretreatment, the process wastewater combines with the building's domestic wastestream and then is sent to the RIA pumphouse where it joins with all other wastestreams before being sent to the City of Rock Island sewer system. The Garrison owns all buildings and utilities including sewer pipes and also holds the NPDES Permits, but its tenants own the machines, processes and operate the pretreatment units. Joint Manufacturing and Technology Center (JMTC) operates a black oxide, nickel and zinc plate shop and pretreatment unit in Building 212 and the U.S. Navy operates a cartridge case facility and pretreatment unit in Building 299. VII. PRETREATMENT SITE VISITS Joint Manufacturing and Technology Center (JMTC) Facility As part of the pretreatment site visit, the CWA Inspectors met with JMTC security and received clearance at 11:15 am on August 1, 2023. For both pretreatment sites, CWA Inspectors, Ms. Gilbert and Ms. Black were present. At the pretreatment unit of the plating line, we met with Troy Hemphill, JMTC Operator and Class K Wastewater Operator. Mr. Hemphill has been in his position for two years, and he stated that he is the only wastewater operator at this pretreatment unit which does not have a backup. Mr. Hemphill described the five industrial plating lines, or Phases, which create wastewater: Phase I: hexavalent chromium Phase Ib: phosphating (includes black oxide) and hexavalent meta-seal Phase II: hexavalent chromium, zinc and cadmium Phase III: hexavalent chromium, anodizing and hard coat Phase IV: trivalent chromium Wastewater can be processed on automatic or manual. On the automatic cycle, hexavalent chromium to trivalent chromium conversion occurs. Mr. Hemphill estimated that the amount of wastewater processed is around 12,000 gallons per week, but production is not constant and based on contracted work. In addition to wastewater from the primary lines there can be wastewater from condensate or water treatment reverse osmosis discharge water, and spills are also routed to the pretreatment units. There is a separate sump in the pretreatment area that receives wastewater from secondary containment wastewater that is discharged via gravity. Previously, there was an event when the secondary containment sump received too much water and the entire pretreatment area was under 1-2 feet of water which caused some pumps to need to be replaced. 9 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 The treatment system consists of metal batch tanks, sludge tanks, a filter press separator, and effluent tanks. The treatment system can run in automatic or manual mode and the operator identifies which way it is operating. The operator uses cup and bench test to determine necessary treatment. Treatment depends on the plating lines and the wastewater which is produced, but generally consists of a metal precipitation, solids removal and neutralization. Each metal batch tank has options of addition of sodium hydroxide, ferric chloride or sulfuric acid to each tank. Conversion of hexavalent to trivalent chromium is done through acidification and sodium metabisulfite addition. Flocculation is achieved through ferric chloride or polymer additions. The filter press produces F listed hazardous waste and is operated on both manual or automatic operations. Recycled water from the filter press is routed back to the metal batch tank. The operator will run the water through an additional filtration system prior to discharging to the effluent tanks. All treated wastewater remains in the effluent tanks until the operator turns on a pump to release it to the sewer; therefor, in the case of power failure, the wastewater will not automatically be discharged to the sewer. Grab sampling and 3-day composite samples of final effluent wastewater are collected from the effluent tanks for compliance with the City of Rock Island pretreatment permit. The black oxide solidifies into a "cement-like mass" in the sludge tanks and it must be cleaned out every 5 years. The operator is expecting this to occur in September. We completed the JMTC portion of the facility site visit on August 1, 2023 at 2:20 PM. Quad City Cartridge Case Facility At the pretreatment unit of the cartridge case facility, we met with Dave Charlson, Facilities Technician and Class K Wastewater Operator. For this pretreatment unit, Mr. Charlson is the backup operator while the main operator is out on leave. At this facility there is a zinc phosphating line and a "soap and coat" line. At the time of the inspection there is no electroplating process, but Mr. Charlson stated that it is possible that electroplating could return. The phosphating process occurs as part of the heat treat line. For the pretreatment units, wastewater first flows into an equalization tank then moves to tanks for acidication and precipitation of metals. The pretreatment unit has little flow and Mr. Charlson stated that to take 24-hour composite samples for its City of Rock Island pretreatment permit, they must save up wastewater to be able to discharge for 24 hours. The average discharge volume is 8000 gallons per month, or one batch each month. There is an oil water separator and Mr. Charlson stated that all oil water separators and grease traps are cleaned and inspected by the City of Rock Island as part of its basic operational contract. We completed the Quad City Cartridge Case Facility portion of the facility site visit at 2:20 PM. VIII. CLOSING CONFERENCE At 3:30 PM we began a closing conference with the same EPA and Garrison representatives present as at the Opening Conference. EPA noted the following areas of concern: 10 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 Stormwater Areas of Concern: 1. In 2021 and 2022, approximately 50% or more of yearly average samples of the 14 outfalls exceeded sector specific aluminum and nitrate plus nitrate benchmarks. 2. There was vegetative or industrial debris on the Zone 5 and foundry stormwater inlets. 3. Barrels labeled hazardous waste were located in the foundry yard and near the stormwater inlet and no secondary continment was present. 4. The practices that are used for flooding and high-water table are not listed in the SWPPP. The two practices observed are: a. Pumping out sitting water in the utility and communication manholes weekly to the stormwater system. b. Stormwater discharge through a temporary discharge point in use during flood events such as the discharge point at Outfall 13. 5. The SWPPP lists two digit applicable SIC codes: 24, 27, 30, 33, 35, but a four digit SIC code is necessary to determine which sector requirements are applicable. Pretreatment Area of Concern: 1. The JMTC wastewater operator is the only wastewater operator at this pretreatment unit and does not have a backup. The inspection and closing conference ended at 4:15pm and EPA CWA Inspection left the facility. Documents received during the inspection: Maps of Facility Areas and Industrial Drainage Zones Stormwater Pollution Prevention Plan dated October 2022 Rock Island Arsenal Major Tenant Leadership Environmental Division Staff Garrison Command Structure USAG RIA Organization Structure 11 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 Appendix A: Inspection Photo Log Rock Island Arsenal EPA Inspection August 1-2, 2023 All photos taken by Eric Small, Physical Scientist, U.S. EPA Camera: RICOH WG-4 GPS 1: RIMG0036 Description: Polymer storage and mixing tanks for pretreatment units. The three tanks are located within secondary containment. Location: JMTC Pretreatment Unit Date/Time: August 1, 2023 12:17 PM A1 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 2: RIMG0037 Description: Mixing and storage tanks within the pretreatment system. On the left foreground are three batch tanks and sludge tanks are in the center back. Samples can be collected via the spigot on each tank once the tank is 30% full. There is a drain under the spigot that drains back to the start of the pretreatment system. Location: JMTC Pretreatment Unit Date/Time: August 1, 2023 12:21 PM A2 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 3: RIMG0038 Description: Sump in the pretreatment area that recieves wastewater from a secondary containment area via gravity. Previously, there was an event when the secondary containment sump received too much water and the entire pretreatment area was under 1-2 feet of water which caused some pumps to need to be replaced. Location: JMTC Pretreatment Unit Date/Time: August 1, 2023 12:34 PM A3 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 4: RIMG0039 Description: Valves on the metals batch tanks that allow sodium metabisulfite, sodium hydroxide, lime slurry, ferric chloride and sulfuric acid additions. Each of the three batch tanks have the same valves. Location: JMTC Pretreatment Unit Date/Time: August 1, 2023 12:44 PM A4 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 5: RIMG0040 Description: Primary pump that recieves wastewater from the plating units above and pumps it to the JMTC Plating Unit Location: JMTC plating area located upstream of the pretreatment unit Date/Time: August 1, 2023 12:54 PM A5 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 6: RIMG0041 Description: One of the plating lines that discharge to the JMTC Pretreatment Unit. Wastewater is designed to overflow the units and fall into the primary confinement area below. Location: JMTC plating area located upstream of the pretreatment unit Date/Time: August 1, 2023 1:00 PM A6 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 7: RIMG0042 Description: View downward next to the plating unit from Photo 6. Wastewater is designed to overflow the plating unit and flow downward to the primary confinement area below, which is pumped to the JMTC pretreatment unit. Location: JMTC Plating Unit located upstream of the pretreatment unit Date/Time: August 1, 2023 1:00 PM A7 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 8: RIMG0045 Description: Double walled above ground fuel storage tank located in the fueling station. Location: Fueling station Date/Time: August 2, 2023 9:01 AM A8 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 9: RIMG0046 Description: Southern view of the valve upstream of Outfall 5 where compliance samples are collected. The actual outfall is located in the marshy area beyond the fenceline and was not accessible during the inspection. Location: Compliance sampling collection point for Outfall 5 Date/Time: August 2, 2023 9:10 AM A9 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 10: RIMG0047 Description: Non-vegetated area beyond the railroad tracks is the location of the former coal pile which is now a CERCLA groundwater monitoring site. Ms. Gilbert stated that the plan for this area is to install solar and RICE generators. Location: Former coal pile Date/Time: August 2, 2023 9:15 AM A10 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 11: RIMG0048 Description: Pumphouse and valves upstream of Outfalls 6 and 7. The compliance samples for Outfalls 6 and 7 are collected at the grate next to the pumphouse. In the right rearground is the fenceline and the actual outfalls are located in the marshy area beyond the fenceline and were not accessible at the time of the inspeciton. Location: Compliance sample point for Outfalls 6 and 7 Date/Time: August 2, 2023 9:21 AM A11 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 12: RIMG0049 Description: In the foundry yard hot sand molds are left to cool (right) and by the end of the day will be placed into the dumpsters that are covered by a canopy (left). Location: Foundry yard Date/Time: August 2, 2023 9:46 AM A12 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 13: RIMG0051 Description: Waste sand molds that are left in the foundry yard to cool prior to moving them to the dumpsters underroof. The stormwater inlet is located in the center rear ground. Location: Foundry yard Date/Time: August 2, 2023 9:48 AM A13 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 14: RIMG0052 Description: Stormwater inlet located in the foundry yard, near the sand molds. The inlet has a drain filter that is assigned to JMTC for periodic inspection and replacement. At the time of the inspection, sand and debris were present on the filter and inlet. Location: Foundry yard Date/Time: August 2, 2023 9:52 AM A14 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 15: RIMG0053 Description: Barrels labeled hazardous waste that were located in the foundry yard and near the stormwater inlet from photo 14. No secondary containment was present. Location: Foundry yard Date/Time: August 2, 2023 10:05 AM A15 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 16: RIMG0054 Description: Dumpsters and waste storage located in Industrial Zone 2. Dumpsters were not covered at the time of the inspection. The dumpsters were full of wood pallets. Location: Dumpster storage Date/Time: August 2, 2023 10:53 AM A16 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 17: RIMG0055 Description: Erosion area present near the salt storage dome. Some salt staining was present near the erosional area. Salt spillage was present near the salt loading area. Location: Salt storage dome Date/Time: August 2, 2023 11:05 AM A17 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 18: RIMG0056 Description: Erosion and white salt staining on a stormwater pathway leading to the stormwater inlet. This photo is the flow pathway downstream of Photo 17. Location: Salt storage dome Date/Time: August 2, 2023 11:06 AM A18 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 19: RIMG0057 Description: Outfalls 10 and 11. Construction had recently finished on these two outfalls to separate them and make them more accessible. At the time of the inspection, both outfalls had some flow. Location: Outfalls 10 and 11 Date/Time: August 2, 2023 11:12 AM A19 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 20: RIMG0058 Description: Valves upstream of Outfalls 10 and 11. This photograph is taken above the outfalls shown in Photo 19 and shows the receiving waters of the Mississippi River. The construction permit was still active since the vegetative cover had not taken. Location: Outfalls 10 and 11 Date/Time: August 2, 2023 11:19 AM A20 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 21: RIMG0059 Description: Vegetative cover near the valves for Outfalls 10 and 11 shows in Photo 20. Location: Outfall 10 and 11 Date/Time: August 2, 2023 11:19 AM A21 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 22: RIMG0060 Description: Valve upstream of Outfall 13 in and the compliance sample point. The outfall is located beyond the fenceline and was not accessible. Location: Outfall 13 Date/Time: August 2, 2023 11:31 AM A22 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 23: RIMG0061 Description: Discharge pipe that was installed under the fenceline near Outfall 13 and a hose line in the grass leading to the discharge pipe. Ms. Gilbert stated that this point had been used to pump out stormwater during the last flood event when the outfalls valves were closed to prevent flooding entering the stormwater system. Location: Outfall 13 Date/Time: August 2, 2023 11:35 AM A23 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 24: RIMG0062 Description: Stormwater inlet in a low lying area of Industrial Zone 5. Ms. Gilbert stated that a sump pump was place in this area during the last flood event and pumped to the discharge point on Photo 23. At the time of the inspection, there was grass and debris on the inlet and an inlet filter was not in use. Location: Industrial Zone 5 near Outfall 13 Date/Time: August 2, 2023 11:37 AM A24 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 25: RIMG0063 Description: Stormwater inlet near the Garrison offices. Ms. Gilbert stated that the snowplows tear up the grass which contributes to sediment entering the stormwater system. In places like this inlet, a straw waddle is used to prevent erosion from leaving the grass, and a drain filter is used in the inlet. Location: Garrison offices Date/Time: August 2, 2023 1:23 PM A25 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 8: RIMG0064 Description: Processing area where drains in the floor are designed as secondary containment and to route wastewater to the pretreatment unit. Location: Quad City Cartridge Case Facility Date/Time: August 2, 2023 1:42 PM A26 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 26: RIMG0065 Description: Wash tunnel that is designed to discharge to the floor drains and then to the pretreatment units. Location: Quad City Cartridge Case Facility Date/Time: August 2, 2023 1:43 PM A27 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 Appendix B: Aerial image of Rock Island Arsenal with stormwater outfalls Note: Aerial image with stormwater outfalls taken from Rock Island Arsenals Stormwater Pollution Prevention Plan. Images do not represent conditions observed and are only to be used as reference. B1 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 Appendix C: NPDES Permit Sector Specific Requirements C1 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 C2 Rock Island Arsenal CEI Inspection - August 1 - 2, 2023 C3