DNR issues administrative consent order to Conti-Tech

The Iowa Department of Natural Resources (DNR) has issues an administrative consent order with Contitech USA, Inc (Conti-Tech) in Mt. Pleasant.

The consent order was created for the purpose of resolving water quality violations made by Conti-Tech, which resulted in the discharge of wastewater.

With the wastewater discharge, Conti-Tech violated its treatment agreement with the City of Mt. Pleasant.

The order requires Conti-Tech to “operate and maintain is Mt. Pleasant facility in compliance with applicable law and to pay an administrative penalty of $10,000.00.”

The statement of facts enlisted in the order are as follows:

1. Conti-Tech neither agrees nor disagrees with these statements of fact and agrees to the terms of this Order for settlement purposes only.

2. Conti-Tech owns and operates a hose manufacturing facility at 400 N. Goodyear Road, Mount Pleasant, Iowa (Facility).

3. The City of Mount Pleasant (Mount Pleasant) owns and operates a publicly owned treatment works. The Facility discharges wastewater to the treatment works.

4. In December 2013, Conti-Tech entered into a Treatment Agreement (TA) with Mount Pleasant. The terms of the 2013 TA are incorporated into this Order by reference.

5. Relevant to this order, the 2013 TA had limits on zinc, temperature, and oil and grease (O&G) discharges.

6. Since January 2014, the Facility has operated as a significant industrial user (SIU).

7. On November 30, 2015, the DNR issued Conti-Tech a Notice of Violation (NOV) for violations of 567 IAC 62.1(6). These violations included discharges in excess of the zinc, temperature, and O&G limits in the 2013 TA. Notably, the DNR noted twenty violations each for zinc and temperature between February 2014 and September 2015.

8. In December 2015, Conti-Tech began taking action to remedy the violations noted in the November 30 NOV by installing a filtration system to remove zinc, including testing, engineering, and design of the system.

9. On or about September 12-15, 2016, the U.S. Environmental Protection Agency (EPA) conducted a compliance inspection of the Facility. The EPA noted that ContiTech had violated the zinc limits for every month since February 2014. However, the EPA also noted Conti-Tech was nearly finished with the construction of the filtration system to remedy the zinc discharge violations.

10. On or about November 22, 2016, the EPA contacted Conti-Tech to confirm the construction was complete. Conti-Tech informed the EPA that it was complete.

11. On April 20, 2018, the DNR issued Conti-Tech an NOV for additional violations of 567 IAC 62.1(6). The DNR again noted that for every month between September2016 and January 2018, the Facility was discharging effluent that exceeded the 2013 TA limits for zinc. The DNR also noted multiple discharges of effluent that exceeded the TA limits for temperature and O&G.

12. On or about April 16, 2018, the DNR sent a letter to Mount Pleasant advising the City that failure by the City to bring Conti-Tech into compliance with the 2013 TA may result in action against the City.

13. In May 2018, Conti-Tech, with assistance from Mount Pleasant, began working to rectify the continual violations noted in the April 16, 2018, NOV.

14. On April 19, 2019, Conti-Tech and Mount Pleasant agreed to a new TA. The terms of the 2019 TA are incorporated into this Order by reference.

15. Relevant to this order, the 2019 TA has limits on zinc, temperature, and O&G discharges. Notably, the 2019 TA removed the zinc concentration limits while retaining the zinc mass limits.

16. On April 9, 2020, the DNR issued Conti-Tech a NOV for violations of 567 IAC 62.1(6). These violations included discharges in June, August, October, November, and December that were in excess of the zinc limits in the 2019 TA.

17. On April 22, 2020, Conti-Tech submitted a plan of action (POA) to the DNR stating how the company would address the violations related to zinc. The POA explained that Conti-Tech would re-route additional waste streams through the Facility’s treatment system, assess low zinc formulations of the Facility’s highest value compounds, evaluate and repair sump systems to pump water through the filtration system, and add sump pumps to the Facility’s preventative maintenance system.

18. On May 27, 2020, Conti-Tech submitted a supplemental POA notifying DNR that Conti-Tech would be modifying its current testing to measure the level of dissolvedzinc in its wastewater to provide additional data to evaluate its discharge.

19. On September 25, 2020, Conti-Tech submitted a letter to the DNR confirming implementation of the remedial measures outlined in the POA and supplemental POA to ensure the Facility’s compliance with the zinc limits in its TA. Conti-Tech through this letter asserted that the company had returned to compliance with the 2019 TA.

20. On October 15, 2020, the DNR issued Conti-Tech a NOV for violations of 567 IAC 62.1(6). These violations included discharges in excess of the zinc and O&G limits inthe 2019 TA. However, the NOV noted the steps taken by Conti-Tech during the summer of 2020.

21. In July 2021, the Facility implemented a number of long-term capital improvements to ensure maximum treatment of the Facility’s wastewater streams in compliance with the 2019 TA.

22. On August 9, 2021, the DNR issued Conti-Tech a NOV for violations of 567 IAC 62.1(6). These violations included discharges in excess of the zinc and O&G limits.

23. Since August 2021, the Facility has been in compliance with the zinc limits in its TA. The DNR noted a violation of the maximum O&G concentration limit in August 2021, and a violation of the maximum pH limit in November 2021.

24. On September 30, 2021, Conti-Tech’s counsel notified DNR that the long-term capital improvements were implemented at the Facility and provided information regarding investigation and resolution of O&G exceedances in the Facility’s wastewater.