Document 2E5KrKLZxb1kgXKqOJyYLyy6

U.S. ENVIRONMENTAL PROTECTION AGENCY REGION III WATER BRANCH, ENFORCEMENT AND COMPLIANCE ASSURANCE DIVISION CLEAN WATER ACT COMPLIANCE INSPECTION REPORT for Name of Facility: The Berg Brothers Recycling Company Facility Address: 1401 West Hamburg Street, Baltimore, MD, 21230 Mailing Address: 1401 West Hamburg Street, Baltimore, MD, 21230 Report Prepared on: 1/7/2022 Date Report Final as of: Date By: , Environmental Scientist (PG Environmental) Signature Digitally signed by Gold, Gold, Peter Peter Date: 2022.01.10 By: 09:27:16 -05'00' , EPA Signature General Information Type of Inspection: Owner: Operator: Permittee: NPDES Permit No: NPDES Permit Effective Date: NPDES Permit Expiration Date: Receiving Water/MS4: Latitude and Longitude: Industrial Stormwater The Berg Brothers Recycling Company The Berg Brothers Recycling Company The Berg Brothers Recycling Company MDR001402 January 1, 2014 December 31, 2018 (administratively continued) Gwynns Falls (tributary to the Patapsco River), Part of Middle Branch and Northwest Harbor, Baltimore City MS4 located along Bayard Street and Wicomico Street 39.27727, -76.6337 On-Site Facility Inspection Overview On November 16, 2021, a representative from U.S. Environmental Protection Agency (EPA) Region III and EPA's contractor, PG Environmental (hereinafter, the EPA Inspection Team), conducted a compliance evaluation inspection at the Berg Brothers Recycling Company in Baltimore, Maryland. The Berg Brothers Recycling Company is identified as the Permittee and owns and operates the Facility. Two representatives from the Maryland Department of the Environment (MDE) also attended the inspection. Approximate Entry Time: 12:15 PM (EST) Approximate Exit Time: 2:00 PM (EST) Unique Project Identifier (UPI): 3E22WN023A Unique Project Identifier: 3E22WN023A Page 1 of 11 Inspection Date: November 16, 2021 Berg Brothers Recycling Company (MDR001402) Industrial Stormwater Report TABLE OF CONTENTS PAGE I. INTRODUCTION............................................................................................................................ 3 II. INSPECTION PROCESS ................................................................................................................ 3 Inspection Opening Conference .......................................................................................................3 Weather and Precipitation Conditions..............................................................................................4 Facility Site Walk.............................................................................................................................4 Records Review ...............................................................................................................................5 Summary of Observations................................................................................................................6 Closing Conference........................................................................................................................11 List of Appendices Appendix A: Photograph Log Appendix B: Exhibit Log o Exhibit 1 - SWPPP Cover and Excerpts from Onsite Photos o Exhibit 2 - Permittee Quarterly Monitoring and Inspection Reports (Q1 2021 through Q3 2021) o Exhibit 3 - ICIS Database Benchmark Monitoring Data (Outfall No. 001; July 1, 2018 through June 30, 2021) o Exhibit 4 - EPA ECHO Detailed Facility Report Appendix C: MDE 12-SW Permit Unique Project Identifier: 3E22WN023A Page 2 of 11 Inspection Date: November 16, 2021 Berg Brothers Recycling Company (MDR001402) Industrial Stormwater Report I. INTRODUCTION On November 16, 2021, a representative from U.S. Environmental Protection Agency (EPA) Region III and EPA's contractor, PG Environmental (hereinafter, the EPA Inspection Team), conducted a compliance evaluation inspection at the Berg Brothers Recycling Company in Baltimore, Maryland (Facility). The Berg Brothers Recycling Company is identified as the Permittee and owns and operates the Facility. The EPA Inspection Team was joined on the inspection by two representatives from the Maryland Department of the Environment (MDE). The purpose of the inspection was to assess the Permittee's compliance with MDE's National Pollutant Discharge Elimination System (NPDES) General Permit for Discharges of Stormwater Associated with Industrial Activities (12-SW, Registration No. MDR001402; hereinafter, the Permit). The Facility is classified under Sector N of the Permit, Scrap Recycling and Waste Recycling Facility (NonSource Separated, Nonliquid Recyclable Materials). The Facility is a 1.58-acre scrap metal recycling center. Most of the Facility is covered by concrete and compacted dirt and gravel. Ferrous and nonferrous scrap metal are brought into the Facility primarily by commercial haulers and a small number of local peddlers. Trash brought into the Facility (wood pallets, plastics, and various non-metals) is separated and hauled off, accounting for approximately one truckload per month. Facility representatives stated that they accept vehicles that have been "greened" only from one vendor. Vehicle tires are separated and stored until there is enough to fill a truckload. The Facility does not have a shredder and material is separated and may be cut or grated using a large mechanical shear, which was out of service at the time of the inspection. Manual sorting operations take place using an excavator and a bobcat skid steer. The Facility President stated that the majority of the stormwater runoff onsite flows southeast to the retaining wall along Wicomico Street and infiltrates at the foot of the wall. He stated that runoff from the northeast part of the site is captured in a trench drain on the north side of the liquid storage building, which discharges to the east onto Bayard Street, and the City of Baltimore MS4. During the opening conference, the Facility President stated that the Bayard Street outfall was the only outfall onsite (i.e., all other runoff infiltrated at the retaining wall). The EPA Inspection Team observed an additional outfall location near the Wicomico entrance during the Facility site walk. The Stormwater Pollution Prevention Plan (SWPPP) map appears to identify the outfall on Bayard Street as Outfall No. 002 and the outfall near the Wicomico entrance as Outfall No. 001. Refer to Observation 8 for additional details. II. INSPECTION PROCESS Inspection Opening Conference The EPA Inspection Team arrived at the Facility at 12:15 PM (EST) for the inspection. Mr. Jake Albright of PG Environmental displayed his Clean Water Act Inspector credential to the Facility representatives at the outset of the inspection and explained that the purpose of the inspection was to observe compliance with the Permit. The EPA Inspection Team explained that any information that the Facility deemed to be confidential business information ("CBI") should be identified during the inspection and it would be handled as CBI according to EPA's CBI procedures. Table 1 describes the individuals that participated in the inspection. Unique Project Identifier: 3E22WN023A Page 3 of 11 Inspection Date: November 16, 2021 Berg Brothers Recycling Company (MDR001402) Industrial Stormwater Report Name Jake Albright Kate Forsmark Mike Greenwald Joe Miller Wendy Huang Adam Berg, President Brian Stitiski, Business Manager Diana Svitchar, Office Manager Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region III Contractors and Representatives PG Environmental (703) 956-1957 Jake.Albright@pgenv.com PG Environmental (352) 262-9910 Kate.Forsmark@pgenv.com EPA Region III (215) 814-2398 Greenwald.Michael@epa.gov Maryland Department of the Environment MDE (410) 537-3506 joseph.miller1@maryland.gov MDE (410) 537-3526 wendy.huang@maryland.gov Facility Representative Berg Brothers (443) 277-0533 adam@bergrecycling.com Berg Brothers - - Berg Brothers (410) 336-4565 diana@bergbrothers.com Weather and Precipitation Conditions During the inspection, the weather was sunny and cool. National Oceanic and Atmospheric Administration (NOAA) National Weather Service precipitation data for the date of the inspection and five days prior are provided in the Table 2 below: Station Name Cylburn Park, MD US Cylburn Park, MD US Cylburn Park, MD US Cylburn Park, MD US Cylburn Park, MD US Cylburn Park, MD US Table 2. Precipitation Data Date 11/11/2021 11/12/2021 11/13/2021 11/14/2021 11/15/2021 11/16/2021 Precipitation Amount (inches)1 0.00 0.99 0.02 0.00 0.00 0.00 Facility Site Walk As part of the inspection process, the EPA Inspection Team visually observed the site conditions in the presence of the Facility President and Business Manager. The primary purpose of the inspection was to review industrial processes and stormwater management at the Facility, the accuracy and reliability of the Permittee's self-monitoring and reporting program, and to obtain information that will assist EPA in assessing the Permittee's compliance with Permit requirements. Photographs were taken during the inspection by Mr. Jake Albright (PG Environmental). Photographs used to support the observations in this report are included in Appendix A, Photograph Log. Photographs not used are kept on file at EPA Region III. Documents used to support the observations in this report are included in Appendix B, Exhibit Log. The EPA Inspection Team began the walk-through at the Facility entrance located on the northern perimeter of the site, off of West Hamburg Street, where the scale for commercial haulers is located (refer to Appendix A, Photograph 1). The EPA Inspection Team observed various piles of engine parts separated out and stored throughout the north central portion of the site as well as piles of scrap metal, trash, and tires waiting to be sorted (refer to Appendix A, Photographs 3 through 6). The EPA Inspection Team then 1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Unique Project Identifier: 3E22WN023A Inspection Date: November 16, 2021 Page 4 of 11 Berg Brothers Recycling Company (MDR001402) Industrial Stormwater Report entered into the liquid storage building where a trench drain was observed along the north entrance to the building (refer to Appendix A, Photograph 8). The trench drain was connected to Outfall No. 002 on Bayard Street. Within the liquid storage building, the EPA Inspection Team observed many 55-gallon drums with various contents as well as a 1,000-gallon diesel aboveground storage tank (AST), a fuel oil AST, and a container for hydraulic fluid (refer to Appendix A, Photographs 9 through 13). The diesel AST was observed to be contained within a dumpster acting as secondary containment. A spill kit consisting of a large bag of sawdust on a pallet with scooping containers was observed near the diesel AST (refer to Appendix A, Photograph 14). The EPA Inspection Team proceeded down to the partial basement of the building where a sump pump was located. It was unclear where the sump pump discharged (refer to Appendix A, Photograph 15). The EPA Inspection Team proceeded to the manual separation building where various piles of metals were stored in boxes, plastic containers, and on shelving. A small shear used to cut metal was also observed within this building (refer to Appendix A, Photographs 20 and 21). The EPA Inspection Team then entered the main storage building located along the western perimeter of the Facility, used for accepting and storing scrap metals. South of the main storage building and in proximity to various scrap metal piles, a stormwater retaining wall was observed. A curb inlet structure located in the retaining wall was observed at this location (refer to Appendix A, Photographs 29 and 30). The inlet structure had three manholes with openings to three chambers. Facility representatives opened the manholes so the EPA Inspection Team could observe the interior of the structure. The structure contained weir walls and an up-flow pipe, with apparent discharge to Wicomico Street (refer to Appendix A, Photographs 31 through 34). The structure appeared to function as a trash/sediment separator. The Facility representatives were not aware of this structure or the apparent outfall at the time of the inspection; however, the Facility's consultant had included the location as Outfall No. 001 in the quarterly monitoring and inspection reports reviewed onsite. The location was also included on the Facility's SWPPP map (refer to Appendix B, Exhibit 1). Refer to Observation 8 for additional details. The EPA Inspection Team continued through the Facility, observing various scrap storage piles and the large shear system (refer to Appendix A, Photograph 38), which was out of service at the time of the inspection. Pooled water was observed against the shear system and the retaining wall (refer to Appendix A, Photograph 39). The EPA Inspection Team exited the Facility through a gate within the eastern perimeter wall and walked north up Bayard Street to Outfall No. 002 (refer to Appendix A, Photographs 41 through 43). The EPA Inspection Team concluded the Facility walkthrough back along West Hamburg Street and at the Facility's main office. Additional details related to the site conditions at the time of the inspection are included in the Summary of Observations section below. Records Review The EPA Inspection Team partially reviewed some of the Facility's documentation onsite, including the SWPPP and SWPPP map, Notice of Intent to Discharge under the Permit, and Q1 through Q3 2021 visual and benchmark monitoring reports. At the conclusion of the inspection, the EPA Inspection Team requested the Facility provide the following electronically to review remotely after the inspection: a copy of the SWPPP (including maps), quarterly inspection and benchmark monitoring reports for the 24 months preceding the inspection, the most recent comprehensive site inspection/ Unique Project Identifier: 3E22WN023A Page 5 of 11 Inspection Date: November 16, 2021 Berg Brothers Recycling Company (MDR001402) Industrial Stormwater Report evaluation, cleaning/sweeping log for the 3 months preceding the inspection, and monthly maintenance inspection reports for 2021. A followup request for the materials was made to the Facility representatives via email on November 18, 2021. As of the date this report was drafted, the Permittee had not provided the requested documents for review. Summary of Observations The following section summarizes the EPA Inspection Team's observations relative to the Permit requirements. Benchmark Monitoring Part V.B of the Permit requires the Permittee to "monitor for any benchmark parameters specified for the industrial sector(s), both primary industrial activity and any co-located industrial activities, applicable to your discharge." The schedule requires the Permittee to "conduct benchmark monitoring quarterly for four (4) full quarters, starting the first full monitoring period (found in Part V.C.7) that occurs, six (6) months after registering under this permit." For data not exceeding benchmarks, after "collection of 4 quarterly samples, if the average of the 4 monitoring values for any parameter does not exceed the benchmark, you have fulfilled your monitoring requirements for that parameter for the permit term." For data exceeding benchmarks after collection of 4 quarters of samples, "if the average of the 4 monitoring values for any parameter exceeds the benchmark, you must review the selection, design, installation, and implementation of selected control measures to determine if modifications are necessary to meet the effluent limits in this permit." Figure 1. Sector N Benchmark Monitoring Requirements. The Facility experienced benchmark exceedances for multiple parameters at least 44 times between January 1, 2018 and September 30, 2021 (28 from Outfall No. 001 and 16 from Outfall No. 002). The Facility's SWPPP map and inspection forms identify Outfall No. 001 as the outfall from the curb inlet structure in the southern portion of the Facility and Outfall No. 002 as the piped outfall to Bayard Street. Unique Project Identifier: 3E22WN023A Page 6 of 11 Inspection Date: November 16, 2021 Berg Brothers Recycling Company (MDR001402) Industrial Stormwater Report The EPA Inspection Team reviewed monitoring data provided by the Permittee for Quarters 1 through 3 of 2021 (refer to Appendix B, Exhibit 2) as well as data contained in EPA's Integrated Compliance Information System (ICIS) database, dating back to January 1, 2018 (refer to Appendix B, Exhibit 3). Benchmark exceedances are summarized in Table 3 and Table 4. The EPA Inspection Team observed that monitoring results for Outlet No. 002 were not included in the ICIS database. Additionally, as noted in Observation 1, the Permittee did not provide the requested 24 months of benchmark monitoring data for review following the inspection; therefore, the data included in Table 4 only accounts for discharges from Outfall No. 002 monitored during Q1 2021 through Q3 2021. There may be additional exceedances dating further back in time that are not represented in Table 4. Table 3. Reported Benchmark Exceedances for Outfall No. 001 (January 1, 2018 through September 30, 2021) Monitoring Outfall Parameter Reported Benchmark Period End Value Value Units 9/30/2021 001 Cu 0.0459 0.014 mg/L 6/30/2021 001 Fe 1.525 1.0 mg/L 6/30/2021 001 Pb 0.1319 0.082 mg/L 6/30/2021 001 Cu 0.0511 0.014 mg/L 6/30/2021 001 Zn 0.4767 0.12 mg/L 03/31/2021 001 Al 1.025 0.75 mg/L 3/31/2021 001 COD 215 120 mg/L 3/31/2021 001 Al 1.025 0.75 mg/L 3/31/2021 001 Fe 2.66 1.0 mg/L 3/31/2021 001 Zn 0.905 0.12 mg/L 3/31/2021 001 Cu 0.1102 0.014 mg/L 12/31/2020 001 Cu .042 0.014 mg/L 09/30/2020 001 Cu .023 0.014 mg/L 03/31/2020 001 Al .95 0.75 mg/L 03/31/2020 001 Cu .072 0.014 mg/L 03/31/2020 001 Fe 4.06 1.0 mg/L 03/31/2020 001 Pb .174 0.082 mg/L 03/31/2020 001 Zn .629 0.12 mg/L 12/31/2019 001 Cu .053 0.014 mg/L 06/30/2019 001 Zn .174 0.12 mg/L 03/31/2019 001 Al .812 0.75 mg/L 03/31/2019 001 Cu .071 0.014 mg/L 03/31/2019 001 Fe 3.35 1.0 mg/L 03/31/2019 001 Pb .1 0.082 mg/L 03/31/2019 001 Zn .51 0.12 mg/L 12/31/2018 001 Cu .065 0.014 mg/L 12/31/2018 001 Fe 3.33 1.0 mg/L 12/31/2018 001 Zn .279 0.12 mg/L Unique Project Identifier: 3E22WN023A Page 7 of 11 Inspection Date: November 16, 2021 Berg Brothers Recycling Company (MDR001402) Industrial Stormwater Report Table 4. Reported Benchmark Exceedances for Outfall No. 002 (January 1, 2021 through September 30, 2021) Monitoring Outfall Parameter Reported Benchmark Period End Value Value 9/30/2021 002 COD 760 120 9/30/2021 002 TSS 106 100 9/30/2021 002 Fe 1.829 1.0 9/30/2021 002 Zn 0.225 0.12 9/30/2021 002 Cu 0.0525 0.014 6/30/2021 002 COD 240 120 6/30/2021 002 TSS 339 100 6/30/2021 002 Al 1.672 0.75 6/30/2021 002 Fe 3.039 1.0 6/30/2021 002 Pb 0.2656 0.082 6/30/2021 002 Zn 1.003 0.12 6/30/2021 002 Cu 0.2035 0.014 3/31/2021 002 COD 350 120 3/31/2021 002 TSS 210 100 3/31/2021 002 Zn 0.2978 0.12 3/31/2021 002 Cu 0.1386 0.014 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 EPA's Enforcement and Compliance History Online (ECHO) database indicates the Facility was in a state of significant noncompliance (SNC) between July 1, 2018 and September 30, 2020 for failure to report (refer to Appendix B, Exhibit 4). According to the data included in EPA's ICIS database, the Permittee submitted the Q4 2018 report about one month late, on February 28, 2019. Additionally, ICIS indicates a report was not received for Q1 2018 or Q3 2018. As stated previously, ICIS only includes data for Outfall No. 001. Corrective Actions Part IV.B.2 of the Permit states, if "the average of 4 quarterly sampling results exceeds an applicable benchmark. If less than 4 benchmark samples have been taken, but the results are such that an exceedance [sic] of the 4 quarter average is mathematically certain (i.e., if the sum of quarterly sample results to date is more than 4 times the benchmark level) this is considered a benchmark exceedance [sic], triggering this review;" the Permittee must review the selection, design, installation, and implementation of control measures to determine if modifications are necessary to meet the effluent limits in this permit. Part IV.C of the Permit states, "You must document your discovery of any of the conditions listed in parts IV.A and IV.B within 24 hours of making such discovery. Subsequently, within 14 days of such discovery, you must document any corrective action(s) to be taken to eliminate or further investigate the deficiency, or if no corrective action is needed, the basis for that determination. Specific documentation required within 24 hours and 14 days is detailed in part IV.D. If you determine that changes are necessary following your review, any modifications to your control measures must be made before the next storm event if possible, or as soon as practicable following that storm event. In the event that a deficiency cannot be addressed fully Unique Project Identifier: 3E22WN023A Page 8 of 11 Inspection Date: November 16, 2021 Berg Brothers Recycling Company (MDR001402) Industrial Stormwater Report within 30 days, you must call the Department Compliance program and make the Department aware of the situation. These time intervals are not grace periods, but are schedules considered reasonable for documenting your findings and for making repairs and improvements. They are included in this permit to ensure that the conditions prompting the need for these repairs and improvements are not allowed to persist indefinitely." According to the reviewed DMR data (refer to Appendix B, Exhibits 2 and 3), the Facility had multiple instances where the average of four quarterly sampling results exceeded applicable benchmarks, and corrective actions had not been documented or implemented. For example, for the Facility exceeded the average copper concentration benchmark at Outfall No. 001 during the most recently reported four-quarter period, averaging 0.069 mg/L from Q4 2020 through Q3 2021. Additionally, there were multiple quarters where benchmark values were more than four times higher than the benchmark at Outfall No. 001, including: - Q1 2021 for copper (0.1102 mg/L) and zinc (0.905 mg/L) - Q1 2020 for copper (0.72 mg/L), iron (4.06 mg/L), and zinc (0.629 mg/L) - Q1 2019 for copper (0.071 mg/L) and zinc (0.51 mg/L) - Q4 2018 for copper (0.065 mg/L) As stated previously, the EPA Inspection Team was only able to review benchmark data for Outfall No. 002 for Q1 2021 through Q3 2021. However, the data indicated multiple quarters where benchmark values were more than four times higher than benchmark concentrations, including: - Q3 2021 for COD (760 mg/L) - Q2 2021 for copper (0.2035 mg/L) and zinc (1.003 mg/L) - Q1 2021 for copper (0.2978 mg/L) According to Facility representatives, at the time of the inspection, the Facility had not evaluated or implemented any corrective actions in response to benchmark exceedances. The SWPPP was documented as last updated on February 5, 2021 (refer to Appendix A, Exhibit 1). Sector-specific BMPs Part III.B of the Permit states that "the technology-based limits included in Part III.B.1 and in Appendix D, the term "minimize" means reduce and/or eliminate to the extent achievable using control measures (including best management practices) that are technologically available and economically practicable and achievable in light of best industry practice." Part III.B.1.b.vi of the Permit states the Permittee must "divert, infiltrate, reuse, contain, or otherwise reduce stormwater runoff, to minimize pollutants in your discharges." Sector N of the Permit (Scrap Recycling and Waste Recycling Facilities) Part N.3.1.2. Scrap and Waste Material Stockpiles and Storage (Outdoor), states "Minimize contact of stormwater runoff with stockpiled materials, processed materials, and nonrecyclable wastes." Control measures include "(a) permanent or semi-permanent covers; (b) sediment traps, vegetated swales and strips, catch basin filters, and sand filters to facilitate settling or filtering of pollutants; (c) dikes, berms, containment trenches, culverts, and surface grading to divert runoff from storage areas; (d) silt fencing/bio-logs; and (e) oil and water separators, sumps, and dry absorbents for areas where potential sources of residual fluids are stockpiled (e.g., automobile engine storage areas)." The EPA Inspection Team did not observe control measures in the vicinity of Outfall No. 001, along the southern perimeter of the Facility. The inlet appeared to be in the direct flow path from stormwater runoff coming from both the main storage building and the piles of scrap metal to the south of the building. Additionally, a Facility gate was located Unique Project Identifier: 3E22WN023A Page 9 of 11 Inspection Date: November 16, 2021 Berg Brothers Recycling Company (MDR001402) Industrial Stormwater Report directly adjacent to the to the inlet for Outfall No. 001; the gate had a gap under the base without any control measure such as a dike, berm, containment trench, culvert, or surface grading to stop or divert stormwater runoff from leaving the site (refer to Appendix A, Photographs 30 and 35). A portion of the flow in the northern part of the site appeared as though it would drain north, under one of the site's perimeter gates, and onto West Hamburg Street and not be captured by the trench drain at the liquid storage building (as indicated on the SWPPP map and stated by Facility representatives; refer to Appendix B, Exhibit 1). There was no berm or grading to prevent stormwater from leaving the site at this location or direct runoff to the trench drain. Various scrap materials were located, uncovered, adjacent to the gate (refer to Appendix A, Photographs 16 through 18). Flow to West Hamburg Street would eventually enter the City of Baltimore MS4. The EPA Inspection Team Observed uncovered and otherwise unprotected scrap piles throughout the site. Runoff from the uncovered scrap piles in the northern part of the site appeared as though it could either flow directly onto West Hamburg Street or into the Outfall No. 002 trench drain on the north side of the liquid storage building (refer to Appendix A, Photographs 16 through 18). Runoff from the uncovered scrap piles behind the main storage building appeared as though it could flow into the Outfall No. 001 inlet structure or under the Facility gate at Wicomico Street (refer to Appendix A, Photographs 27 and 28). Facility representatives explained that the site was graded in such a way that the majority of the runoff from the southeastern portion of the site would flow to the stormwater retaining wall along Wicomico Street and infiltrate. Evidence of this site grading was observed by dark staining on the ground along the wall (refer to Appendix A, Photographs 26, 37, and 39). Good Housekeeping Part III.B.1.b.ii requires the Permittee to "clean all exposed areas that are potential sources of pollutants." Additionally, Part VI.M of the Permit states, "You must at all times properly operate and maintain all facilities and systems of treatment and control which are installed or used to achieve compliance with the conditions of the permit." The curb inlet separator structure at Outfall No. 001 appeared in need of maintenance. Facility representatives stated they were unaware of the structure or outfall location prior to the inspection. During the opening conference Facility representatives stated that the Bayard Street outfall (Outfall No. 002 according to the SWPPP map; refer to Appendix B, Exhibit 1) was the only outfall from the site. The structure was full of trash and other debris at the time of the inspection (refer to Appendix A, Photographs 29 through 35). Facility representatives stated that the structure had not been maintained or cleaned out to their knowledge. The EPA Inspection Team did observe that the Facility's consultant had included Outfall No. 001 in the quarterly monitoring and inspection reports reviewed onsite, and the location was included on the Facility's SWPPP map. The EPA Inspection Team made the following additional observations related to good housekeeping: - Dark staining was observed on the ground outside, to the north, of the liquid storage building, near the Facility perimeter and the Facility gate to West Hamburg Street (refer to Appendix A, Photographs 16 and 17). Unique Project Identifier: 3E22WN023A Page 10 of 11 Inspection Date: November 16, 2021 Berg Brothers Recycling Company (MDR001402) Industrial Stormwater Report - A petroleum tank was observed near the northern perimeter of the Facility without secondary containment (refer to Appendix A, Photograph 19). It was unclear if the tank was in use. - Dark staining was observed in various areas within the main storage building area (refer to Appendix A, Photographs 23 and 24). - Large, uncovered, piles of scrap metal were observed within the center of the site (refer to Appendix A, Photograph 25). Employee Training Part III.C.5.iv of the Permit states, "The SWPPP must identify how often training will take place. All training must be held at least once per calendar year (or more often if employee turnover is high)." The SWPPP only included documentation of training for 2021 and 2018 (refer to Appendix A, Exhibit 1). Facility representatives stated at the time of the inspection that they did not have any other documented training. As stated previously, the EPA Inspection Team did not review the SWPPP in its entirety due to it not being fully provided in response to the records request. This included not being able to review SWPPP-prescribed training. Closing Conference At the conclusion of the onsite inspection, the EPA Inspection Team conducted a closing conference with the Facility representatives and shared preliminary observations. The EPA Inspection Team reiterated that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by the EPA Inspection Team upon the additional review of records and documentation. Additional observations may be contained in this inspection report that were not identified at the time of the closing conference after the additional review of materials following the inspection. The inspection concluded at approximately 2:00 PM (EST). Unique Project Identifier: 3E22WN023A Page 11 of 11 Inspection Date: November 16, 2021