12/5/2018 Inspection Report NPDES -I- STORMWATER COMPLIANCE INSPECTION REPORT WADOE Simwa?e? a State Of Washington Department Of Ecology i?i?t'i?t't ?i 3190 160th Avenue SE, Bellevue, WA 98008-5452 me: (232; 22333833 Section A: General Data inspection Date NPDES Permit# County Receiving Waters Inspector Facility Type 11/20/2018 WAR001134 King Duwamish River Ben Billick Alex White Industrial Discharges to: Surface Water Ground Water UNANNOUNCED Inspection Section B: Facility Data Name and Location of Site Inspected Lat Long Entry Time Permit Effective Date Ardagh Glass Inc. Lat: 4755197012826 10:30 AM 01/01/2015 5801 Marginal Way Long: ?122.339350957719 Seattle, WA 98134 Exit Time Permit Expiration Date 2:00 PM 12/31/2019 On-Site Representative(s): number(s) or E-mail Additional Participants: Lana Getubig, Manager Albertus Kariko, Operations Manager (206) 768-6221; Iana.rgetubngardaghgroupcom (206) 768-6275; Responsible Official(s): Ben Michaelson, Plant Manager 5801 Marginal Way - Yes NO Seattle, WA 98134 Samples Taken? El El Phone: (206) 768-6241 Photos Taken? >14 Section C: Summary of Findings/Comments BACKGROUND Ardagh Glass Inc. is covered under Ecology's Industrial Stormwater General Permit (ISGP Ecology?s stormwater unit has conducted an inspection at this Industrial site in the past. Ardagh Glass exceeded the numeric effluent limit for total suspended solids (TSS) at their four discharge monitoring points a total Of 17 times from January 1, 2017 through the end Of the second quarter of 2018. Ecology issued a Warning Letter (Attachment 1) for these TSS exceedances on November 15, 2018. The purpose of this inspection was to follow-up on the T88 effluent limit exceedances described in the Warning Letter, determine the facility's compliance with the ISGP, and provide technical assistance as appropriate. Upon arrival Ecology Inspectors Ben Billick and Alex White met with Lana Getubig, the EH88 Manager Of the facility, and Albertus Kariko, the Operations Manager for the facility. We discussed the history Of effluent limit and benchmark exceedances at the facility, as well as the treatment BMPs currently installed on-site as a result Of a past Level 3 Corrective Action. Treatment BMPs currently installed include treatment catch basins with a filtration and sorbent media system in drainage basins 1, 2, and 3; cisterns with treatment media at most downspouts; and a Contech Vortechs clarifier at outfall 2. Installation of treatment BMPs was completed in 2016. According to L. Getubig, the facility switched from a limestone based treatment media to biochar in the catch basins and cisterns in May 2018. We discussed the T88 effluent limit exceedances and the need for Ardagh Glass to develop a strategy to control T35 and prevent future discharges that exceed the T88 effluent limit and violate the ISGP. B. Billick and A. White then reviewed ISGP compliance documents for the facility and watched the site's safety training presentation prior to conducting aninspection of the site with L. Getubig. Document Review: - Discharge Monitoring Reports (DMRs) are up to date and laboratory analytical reports are retained on-site. Sampling conducted so far for 2018 shows that the facility has already triggered a Level 3 Corrective Action for Copper, as well as Level 2 Corrective Actions for Zinc and Turbidity. . Inspections of the facility are being conducted. Inspection reports were available for review and appeared complete. . A copy of the current ISGP is kept in the site log book. 0 The for the facility is dated 11/2016 and was last signed and certified on 1/12/2018. The appeared Ardagh Glass Page 1 Of 6 12/5/2018 Inspection Report NPDES 134 complete, with the exception of the following deficiencies: A complete spill log is not being maintained for the facility. Large spills are being tracked in an electronic spill log, but a log with records of all spills was not available. 0 Installation of treatment BMPs in response to a past Level 3 Corrective Action was completed in 2016, however, the states that the installation of treatment BMPs is ongoing. An Manual for the treatment BMPs was included as an appendix to the Site inspection: . The eastern portion of the site discharges to combined sewer and is therefore not covered under the The western portion of the site is divided into four drainage basins, each served by a separate storm drainage system with an outfall to the Duwamish River. . The majority of the site is paved. Alligator cracking and other pavement damage was observed throughout the site. The poor pavement condition likely reduces sweeping efficacy and contributes to sediment and debris control issues on?site. 0 Vacuum sweeping of the site is conducted on a weekly basis. Sweeping is conducted by both a street sweeping contractor and by using small, ride-on industrial shop sweepers that are owned by the facility. Despite sweeping activities, significant accumulation of sediment, dust, and particulate debris was observed in multiple locations on- site. Sediment and debris accumulation was particularly high in the drainage basin for outfall 3. The majority of industrial activities in this drainage basin are conducted by Strategic Materials, a tenant of Ardagh Glass that sorts and processes glass for recycling. Track out of fine debris particles from inside Strategic Materials? operations building onto the outside pavement was observed. Piles of debris were also observed on the pavement outside of the Strategic Materials building. Additional areas of heavy sediment and debris accumulation were observed near the bag houses in drainage basin 1 and around large objects dumpsters) throughout the site that may not be easily accessed by the street sweepers. We discussed the need for improved sediment control with L. Getubig, as the BMPs currently employed do not provide all known, available, and reasonable methods of prevention, control, and treatment (AKART). . All dumpsters are fitted with lids that are kept closed when not in use. . Several of the catch basins on-site required maintenance to remove accumulated sediment and debris from the treatment media/filter inserts. . A paving contractor was on?site performing concrete work during the inspection. We observed the operator of one of the concrete trucks washing out on-site in drainage basin 3, directly adjacent to the Duwamish River. The operator was attempting to collect the wash water in a five?gallon bucket, but much of it was spilling onto the ground. The operator stopped the washing activities when instructed to do so. Pavement staining that appeared to be from another concrete truck being washed out onto the ground was also observed in one location in drainage basin 2 during the inspection. 0 A piece of heavy equipment and a contractor?s truck were actively leaking fluid at the time of the inspection. No actions had yet been taken to contain or clean up the leaks when they were observed. - Spill kits were stored in multiple locations on?site. . The facility has an on-site maintenance shop for their equipment. The majority of liquid products in the shop were stored on a secondary containment pallet; however, one 55?gallon drum of oil and a few miscellaneous containers of automotive fluids did not have containment. The maintenance shop is relatively small and has a door that opens to the outside, so liquid spills outside of containment could reach the outside. Section D: Compliance Requirements and Recommendations . Ardagh Glass is in violation of permit condition S3.B.4.b.i.3, failure to maintain stormwater drainage/treatment BMPs. Within 10 calendar days of receipt of this report. inspect all catch basin treatment BMPs. remove excess sediment and debris, and replace treatment media as necessary. . Ardagh Glass is in violation of permit condition S3.B.4.b.i.3.d, failure to immediately clean up spills and leaks. Ensure that future spills and leaks are cleaned up immediately and that contaminated spill cleanup materials are properly disposed of. Ensure that appropriate staff are properly trained in the facility?s procedures for identifying and responding to spills and leaks. . Ardagh Glass is in violation of permit condition S3.B.4.b.i.7.ii, failure to properly manage washwater. Immediately ensure that all washing activities, including washout of concrete trucks, are conducted in areas where the washwater can be collected and properly disposed of. Washwater is considered a process water and cannot be Ardagh Glass . Page 2 of 6 12/4/2018 Inspection Report NPDES allowed to discharge to surface waters or the storm drainage system. Ardagh Glass is in violation of permit condition S10.C, failure to apply all known and reasonable methods of prevention, control, and treatment (AKART) for the management of sediment, dust, and particulate debris on-site. Within 30 calendar days of receipt of this report develop and implement a plan to better control sediment. dust. and particulate debris on-site. Ensure that the is updated to reflect any changes in BMPs. In accordance with permit condition 83.A.4.a.ii, update the facility within 30 calendar days of receipt of this report to include a complete spill log and details of the treatment BMPs installed on-site. In accordance with permit condition SS.B.4.b.i.4.a, ensure that containers of chemical liquids, fluids, and petroleum products kept in the maintenance shop are stored in secondary containment. Though these materials are stored inside, the small size of the shop and proximity to the outdoors creates a possibility that spills could reach the storm drainage system. As described in the Warning Letter dated November 15, 2018, Ardagh Glass has had multiple instances of non- compliance with the T88 effluent limits established in permit condition 36.0.1.0 and Table 6 of the Ensure that a written response to the Warning Letter is submitted to Ecology within the timeline given in the letter. The response should include information on how Ardagh Glass proposes to address the source of these exceedances and prevent future exceedances in the future. Ecology recommends that Ardagh Glass conduct additional discharge sampling, as practicable, for the fourth quarter 2018 discharge monitoring report in order to ascertain the performance of the treatment BMP improvements installed in May 2018. Additional sampling and associated additional data would better inform the Engineering Report already required by Level 3 Corrective Actions for Copper, due in 2019. The Permittee and Site Contact information that Ecology has on file for Ardagh Glass is out of date. In order to update the Site Contact information for the facility please email the necessary changes to Ecology Permit Administrator Josh Klimek at @h.klimek@ecv.wa.qov. In order to update the facility's Permittee please submit a Modification of Coverage form to Ecology. When completing the form you should select ?Other? for the type of modification that is being requested and include an explanation that the modification is only to update the Permittee information. A copy of the Modification of Coverage form can be found here: For questions about this report please contact Ecology Inspector Ben Billick at bbil461@ecy.wa.gov, (425) 649- 7059, or Dept. of Ecology, Water Quality Program, 3190 160th Ave SE, Bellevue, WA. 98008. For assistance with any of these compliance issues or recommendations regarding Best Management Practices see the Stormwater Management Manual for Western Washington, volumes IV and (SWMM). To obtain a copy of the SWMM you may go to Ecology's website at: The Department of Ecology has the authority to issue formal enforcement actions including issuance of orders and civil penalties of up to $10,000 per day per violation for violations of your NPDES permit and/or state laws and regulations. 17/0/25 Date Alex White Date Senior Water Quality Inspector Water Quality Inspector Water Quality Program Water Quality Program Ardagh Glass Page 3 of 6 12/4/2018 Inspection Report PHOTO AD NPDES DENDUM -ARDAGH GLASS 11/20/18 I .4 002 DESCRIPTION: TRACK OUT OF FINE DEBRIS FROM STRATEGIC MATERIALS BUILDING AND SMALL PILES OF DEBRIS OUTSIDE OF DOORS. 113' DESCRIPTION: PILE 0 THE DUWAMISH RIVER IN DRAINAGE BASIN 3. ii I 003 004 DESCRIPTION: HEAVY DUST ACCUMULATION 7 AROUND BAG HOUSESIN DRAINAGE BASIN 1. I*1Irusa . . ,3 . - Luml .. *?Autamabilus ..: I 253-53?-1-mn . . . 005 DESCRIPTION: DEBRIS AND SEDIMENT ACCUMULATION AT BASE OF DUMPSTER. .1 11'- . M. 006 DESCRIPTIO 3. MENT CATCH BASIN IN Ardagh Page 4 Of 6 12/4/2018 Inspection Report NPDES 11/20/18 I . PHOTO ADDENDUM - ARDAOHV GLAS I .5 r?r? - 007 DESCRIPTION: HEAVY SEDIMENT AND DEBRIS 008 DESCRIPTION: CONCRETE TRUCK THAT WAS WASHED OUT ACCUMULATION ON TOP OF THE TREATMENT MEDIA INSIDE THE ONTO THE GROUND ADJACENT TO THE DUWAMISH RIVER. CATCH BASIN SHOWN IN PHOTO 006. ALLIGATOR CRACKING ON PAVEMENT IN FOREGROUND OF PHOTO. ?1 009 DESCRIPTION: 010 DESCRIPTION: HEAVY ADJACENT TO RIVER. ALLIGATOR DRAG GROUND. 5. 01 1 DESCRIPTION: SHEEN ON WATER FROM LEAKING 012 DESCRIPTION: 55-GALLON OIL DRUM OFF OF SECONDARY CONTRACTOR TRUCK. CONTAINMENT PALLET IN THE MAINTENANCE SHOP. Ardagh Glass Page 5 of 6 12/4/2018 Inspection Report NPDES Attachment 1 Ardagh Glass Warning Letter for Total Suspended Solids Effluent Limit Exceedances Ardagh Glass Page 6 of 6 STATE or WASHINGTON DEPARTMENT OF ECOLOGY Northwest Regional Office 0 3190 160th Ave SE 0 Bellevue, WA 98008-5452 0 425-649-7000 711 for Washington Relay Service 0 Persons with a speech disability can call 877-833-6341 November 15, 2018 Mr. Michael Gibbons, Plant Manager Ardagh Glass Inc 5801 Marginal Way Seattle, WA 98134-2413 Re: WARNING LETTER: National Pollutant Discharge Elimination System (NFDES), Industrial Stormwater General Permit (ISGP) Number WAR001134, Ardagh Glass Inc. Dear Mr. Gibbons: Your Discharge Monitoring Reports (DMRs) show that your facility was 'out of compliance with the ef?uents limits in the 2nd and 4th quarters of 2017 and the 1St and 2nd quarters of 2018 (see Table' 1) according to the discharge limits set in your NPDES ISGP, and required parameters were not measured in the 3Id quarter of 201 7. The Total Suspended Solids (TSS) ef?uent limit became effective on January 1, 2017 for discharges to a 303 (d)?1isted water (see ISGP special condition 86.C.1.c, Table 6), which includes the Duwamish Waterway. The DMR is the principal tool used to evaluate compliance with permit requirements. The Department of Ecology (Ecology) places great importance on timely submittal of complete and accurate DMRs. Non-complianCe noti?cations are required by your permit. Ecology received your notices of noncompliance dated August 5, 2017; November 13, 2017; February 14, 2018; May 15, 2018; and August 7, 2018; via DMR Facility Notes. Other than for February 15 2017, this part of your permit requirement has been ful?lled. Ecology notes that exceedance of TSS limits is a problem for your facility (Table Ecology requests that you address the root source of this problem and propose a solution to prevent future. exceedances. Within 30 calendar days of receipt of this letter, submit a written response detailing your proposed solution to Ben Billick Further failures to comply with the conditions of your permit could result in Ecology taking formal administrative enforcement action, including issuing orders and penalties. If you have any questions or concerns, please contact ISGP inspector Alex White or Ben Billick: Alex White (425) 649-7263 alwh461@ecy.wa. gov Ben Billick (425) 649-7059 bbil46 1@ecy.wa. gov Table 1: TSS Violations from January 2017 to present Sample Date Monitoring Point Sample Measurement Max Limit February 15, 2017 3 360 mg/L 30-mg/L February 15, 2017 4 150 mg/L 30 mg/L May 16,2017 7 3 430 mg/L 30 mg/L May 16, 2017 4 140 trig/L 30 mg/L September 29, 2017 1 Analysis not conducted - September 29, 2017 3 Analysis not conducted September 29, 2017 4 Analysis not conducted October 17, 2017 3 86 mg/L 30 mg/L October 17, 2017 4 72 mg/L 30 mg/L March 9, 2018 1 110 mg/L 30 mg/L March 9, 2018 2 60 mg/L 30 mg/L March 9, 2018 3 1300 mg/L 30 mg/L March 9, 2018 4 120 mg/L 30 mg/L March 23, 2018 1 34 m?g/L 30 mg/L March 23, 2018 3 980 mg/L 30 mg/L March 23, 2018 4 510 mg/L 30 mg/L April 13, 2018 1 38 mg/L 30 mg/L April 13, 2018 2 49 mg/L 30 mg/L April 13, 2018 3 980 Ing/L 30 mg/L April 13, 2018 4 390 mg/L 30 mg/L TSS Total Suspended Solids Sincerely, Gretchen Onstad Enforcement Coordinator Water Quality Program CC: 602 Central Files: Ardagh Glass Inc, WAR001134, WQ 6.4 Alex White, Ecology Ben Billick, Ecology Michael Gibbons, Plant Manager, Ardagh Glass Inc, michaelj .gibbons@ardaghgroup.com Lana Getubig, HSE FAC Mgr, Ardagh Glass Inc, lana.getubig@honeywell.com