Document zQoDEwxeZEL52Ydp7d2gE65E6

Inspection Date: Time: Media: Statute (s)/Program(s): Type of inspection: Access: Permittee Name: Facility or Site Name: Facility/Site Physical Address: (city, state, zip code) County/Parish: Permit Number: REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT 8/23/2022 Inspection Announced: No Entry: 11:40 AM (EST) Exit: 3:50 PM (EST) Water Clean Water Act, National Pollutant Discharge Elimination System (NPDES), Industrial Compliance Evaluation Inspection Granted Plymouth Tube Co. Plymouth Tube Co. 572 W State Road 14 Winamac, Indiana 46996 Pulaski INP000240 Persons Participating in Inspection: Title Name Phone Physical Scientist, EPA Matthew (312) 886-2405 Schulte Environmental Engineer, EPA Newton Ellens (312) 353-5562 Stormwater Specialist - IDEM Rob Beck (317) 690-8805 Wastewater Margaret (219) 246-6148 Inspector - IDEM Hayes Wastewater Aaron Deeter (317) 691-1915 Inspector - IDEM Corporate Environmental and Safety Manger Jenna Griffith (574) 946-3125 Email schulte.matthew@epa.gov Ellens.newton@epa.gov rbeck@idem.in.gov mhayes@idem.in.gov adeeter@idem.in.gov jmgriffith@plymouth.com Present at Present at Opening Closing Conference Conference Yes Yes Yes Yes Yes Yes Yes No Yes No Yes No Page 1 of 28 Plymouth Tube Co. Inspection Date(s): Persons Participating in Inspection: Director of Operations Environmental Coordinator Ricky Searcy (574) 946-3125 Dawn Pickett (574) 946-3125 dpickett@plymouth.com 8/23/2022 Yes No No Yes Lead Inspector: Matthew Schulte Region 5 schulte.matthew@epa.gov Additional Persons Participating in Inspection: Newton Ellens Region 5 hodaj.andi@epa.gov Supervisor Review: Molly Smith MOLLY SMITH Region 5 Digitally signed by MOLLY SMITH Date: 2022.10.25 20:32:10 -05'00' smith.molly@epa.gov (312) 886-2405 312-353-4645 (312) 353-8773 SECTION I - INTRODUCTION Site Entry and Inspection Objectives Region 5 Lead Inspector, Matthew Schulte, and inspector Newton Ellens arrived at Plymouth Tube Co. (the "Site" or "Facility"), located at 572 W. State Road 14, Indiana, at 11:40 AM (EST) on August 23, 2022, for an unannounced inspection. Inspectors presented their credentials to Ricky Searcy and informed the Facility that this was an EPA Region 5 inspection to determine compliance with the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permit program. The inspection was conducted under the authority of the CWA NPDES permit program and Section 308 of the CWA. The table above identifies the attendees that participated in the inspection. This report is based on information supplied by Facility representatives, observations made by the Region 5 inspectors, and records and reports maintained by the permittee and Region 5. These include the following: direct observations made by the Region 5 inspectors, photographs taken by Region 5 inspectors, physical Page 2 of 28 Plymouth Tube Co. Inspection Date(s): 8/23/2022 evidence collected by Region 5 inspectors, measurements taken by Region 5 inspectors, verbal or written statements made or supplied by Facility representatives (the permittee) during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the Region 5 inspectors by Facility representatives during or subsequent to the on-site inspection. In addition, information gathered prior to or subsequent to the inspection from a review of U.S. EPA, State, and public records may be included in this report. Facility/Site Description Region 5 Lead Inspector confirmed the following Facility information: The Facility is a specialty manufacturer of carbon alloy, nickel alloy, and stainless precision steel tubing. The Facility operates five days a week, Monday through Friday, for 24 hours a day and produces wastewater primarily through its hot mill pickle tanks and quench and temper process. The maximum daily flow that the facility estimates is 25,000 gallons per day. Roughly 100,000 pounds of material is brought to the Facility on flatbed trucks daily. The Facility is currently undergoing an operational change focused on increasing their production rates due to the closure of the Plymouth Tube Co. Facility located in Streator, Illinois. This operational change has resulted in an increase in the amount of material being processed at the Facility, but has not involved an increase in the amount of wastewater being generated. Stormwater that falls on site is directed towards the North end of the facility towards stormwater outfall 001. Any wastewater generated on site is treated in batch tanks before being discharged to the City. SECTION II - OBSERVATIONS Observations may not be in sequential order. Unique Identifying No. MS5-OB-001 MS5-OB-002 MS5-OB-003 MS5-OB-004 MS5-OB-005 MS5-OB-006 MS5-OB-007 Observation Calibrations for daily pH readings are not recorded. Daily pH readings are taken 3 times a day. A monthly monitoring sheet is recorded and provided to the City containing the pH and flow readings. Secondary containment is present for all acid and rinse tanks on-site. Stormwater samples are taken at a culvert located within the plant upstream from Outfall 001. Facility has experienced past zinc exceedances Facility is currently in the process of ramping up production processes resulting in increased material being processed with the same water usage. The scale pit and cooling tower are on closed loop system. Well water is used to replenish and water lost to evaporation on an as-needed basis. Area of Concern? Yes No No Yes Yes Yes No Page 3 of 28 Plymouth Tube Co. Inspection Date(s): 8/23/2022 SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. No. MS5-OB-001 Calibrations for daily pH readings are performed daily, but are not recorded. MS5-OB-004 All calibrations should be recorded and include the date and time for when they are performed. Stormwater samples are taken at a culvert located within the plant upstream from Outfall 001. MS5-OB-005 Samples taken should be taken at the specified outfall location and be representative of the Facility's discharge. Facility has experienced zinc effluent exceedances. MS5-OB-006 Facility experienced an 81 percent exceedance of zinc for its monthly average in July 2022. Facility should ensure that all discharges are in compliance with their Permit. Facility is currently in the process of ramping up production processes resulting in increased material being processed with the same water usage. Facility may need to reevaluate its production based limits contained in their Permit to reflect this operation change. SECTION IV - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The Lead Inspector held a closing conference with Facility personnel on August 23, 2022, for the inspection. During the closing conference, the Lead Inspector discussed the observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. Follow Up The following items were requested by the inspector at the time of the inspection: Letter of Sufficiency showing coverage under the State's General Stormwater Permit Stormwater Pollution Prevention Plan (SWPPP) - Received by email on September 21, 2022. Chain of custodies for the last sampling events done for both stormwater and industrial wastewater - Received by email on September 21, 2022. Copy of the last stormwater site inspection performed under the SWPPP - Received by email on September 21, 2022. Spill Prevention Control and Countermeasure (SPCC) plan - Received by email on September 21, 2022. Copy of the last annual inspection required by the SPCC plan - Received by email on September 21, 2022. Page 4 of 28 Plymouth Tube Co. Inspection Date(s): 8/23/2022 Copy of the wastewater industrial permit - Received by email on September 21, 2022, however, file corrupted and unable to open. Discharge Monitoring Reports for the past year and flow - not received. Meter Calibration record or last purchase record of new meter/installation - Received by email on September 21, 2022. Calculation of production rates for the past year - Received by email on September 21, 2022. SECTION V - LIST OF APPENDICES Appendix 1 - Photo Log [times listed on images are in Eastern Standard Time (EST)] Page 5 of 28 Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 1 Time: 1: 47 PM Direction Photo Taken: Photo Description: Open grating for any spills to contain water in closed loop system. REGION 5 Enforcement and Compliance Assurance Division Photographer: Newton Ellens Camera: Canon Power Shot SX230 HS File: plymouth_001.JPG Page 6 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 2 Time: 1:50 PM Direction Photo Taken: Photo Description: Scale Pit. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_002.JPG Page 7 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 3 Time: 1:51 PM Direction Photo Taken: South Photo Description: Scale Hopper hauled every 6 weeks. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_003.JPG Page 8 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 4 Time: 1:54 PM Direction Photo Taken: East Photo Description: Cooling tower automatic refuel station. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_004.JPG Page 9 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 5 Time: 1:56 PM Direction Photo Taken: South Photo Description: Lift station on the north side of Facility to sanitary. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_005.JPG Page 10 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 6 Time: 1:56 PM Direction Photo Taken: North Photo Description: Diesel Station with secondary containment. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_006.JPG Page 11 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 7 Time: 2:06 PM Direction Photo Taken: South Photo Description: Acid and rinse tanks with open grating to capture and hold any spills. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_007.JPG Page 12 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 8 Time: 2:06 PM Direction Photo Taken: South Photo Description: Acid and Rinse tanks Acid and rinse tanks with open grating to capture and hold any spills. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_008.JPG Page 13 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 9 Time: 2:14 PM Direction Photo Taken: North Photo Description: Holding/floc/mix tanks for pH monitoring and adjustment. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_009.JPG Page 14 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 10 Time: 2:12 PM Direction Photo Taken: North Photo Description: Holding/floc/mix tanks for pH monitoring and adjustment. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_010.JPG Page 15 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 11 Time: 2:18 PM Direction Photo Taken: Photo Description: Monitoring screen for reaction and mix tanks and pH monitoring. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_011.JPG Page 16 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 12 Time: 2:22 PM Direction Photo Taken: Photo Description: Connection to monitoring equipment. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_012.JPG Page 17 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 13 Time: 2:22 PM Direction Photo Taken: Photo Description: pH monitoring screen. 8/23/2022 Photographer: Newton Ellens Camera: Canon Power Shot SX230 HS File: plymouth_013.JPG Page 18 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 14 Time: 2:25 PM Direction Photo Taken: Photo Description: Daily pH monitoring sheet/record. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_014.JPG Page 19 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 15 Time: 2:25 PM Direction Photo Taken: Photo Description: Monthly city monitoring sheet. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_015.JPG Page 20 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 16 Time: 2:32 PM Direction Photo Taken: Photo Description: Flow meter for water connection to City Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_016.JPG Page 21 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 17 Time: 2:36 PM Direction Photo Taken: North Photo Description: Stormwater outfall 001 located on the North end of Facility. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_017.JPG Page 22 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 18 Time: 2:45 PM Direction Photo Taken: Photo Description: Culvert/sampling location for Outfall 001. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_018.JPG Page 23 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 19 Time: 3:00 PM Direction Photo Taken: East Photo Description: Rinse tanks with secondary containment underneath. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_019.JPG Page 24 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 20 Time: 3:04 PM Direction Photo Taken: South Photo Description: Rinse and acid tanks with secondary containment underneath. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_020.JPG Page 25 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 21 Time: 3:05 PM Direction Photo Taken: South Photo Description: Rinse and acid tanks with secondary containment underneath. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_021.JPG Page 26 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 22 Time: 3:05 PM Direction Photo Taken: Photo Description: Cold water rinse tank and cleaner tank with secondary containment underneath. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_022.JPG Page 27 of 28 Plymouth Tube Co. Inspection Date(s): Facility Name & Location: Plymouth Tube Co. 572 W State Road 14 Winamac, IN 46996 Date Photograph Was Taken: 8/23/2022 Photo No.: 23 Time: 3:08 PM Direction Photo Taken: North Photo Description: Empty container and waste storage area. Photographer: Newton Ellens 8/23/2022 Camera: Canon Power Shot SX230 HS File: plymouth_023.JPG Page 28 of 28