Document 2RQexgkpqpnqejqo48XQyoaM6

U.S. EPA Headquarters Enforcement Division 1200 Pennsylvania Avenue NW, Washington, DC 20004 UNPERMITTED INDUSTRIAL FACILITY STORMWATER INSPECTION CHECKLIST Inspection Date Time Weather Conditions Media/Program Operator Name: Facility or Site Name: Permit ID or Tracking #: SIC Code: Facility Address: (city, state, zip code) Geographic Coordinates: Mailing address: (city, state, zip code) County: Regular Days/Hours of Operation: # of Employees at location: Size of Facility (in acres): Receiving Water(s): Date facility est. @ location: May 13, 2024 Entry: 3:15 PM Exit: 5:00 PM 80's F and sunny Water - CWA 301, 402 - Industrial SW/NEC Stone's Wrecking Yard Stone's Wrecking Yard N/A; No permit at the time of the inspection 5015 - Motor Vehicle Parts, Used; or 7538 - General Automotive Repair Shops 203 E 4th St Justin, TX 76247 33.087299, -97.292397 203 E 4th St Justin, TX 76247 Denton County 8:30 AM - 5:30 PM (Monday - Friday) 5 1-2 acres in total size with approximately 1 acre of outdoor activity The closest receiving waterbody, according to the Texas Commission on Environmental Quality's (TCEQ) Surface Water Quality Segments Viewer is an unnamed tributary of Denton Creek (approximately 0.75 miles north of the Facility). The receiving waterbody was not observed due to distance from the Facility. 1965 Onsite Representatives: Name: Chris Stone Title: Owner Phone: (940) 242-3238 Email: chrisswyauto@yahoo.com Authorized Official: Contacted? x Yes No Name: Chris Stone Title: Owner Phone: (940) 242-3238 Email: chrisswyauto@yahoo.com Additional Personnel Participating in Inspection: Name: N/A Title: N/A Inspector(s): Taylor Fontaine Mariah Papac Ivy Koberlein Sharron Crayton Inspection Report Author: Title: Lead Inspector Inspector Inspector Inspector Company: Eastern Research Group, Inc. Eastern Research Group, Inc. Environmental Protection Agency, Headquarters Environmental Protection Agency, Region 6 Page 1 of 6 Name: Taylor Fontaine Signature: Supervisor Review: Name: Ruben Alayon-Gonzalez Signature: RUBEN ALAYONGONZALEZ Stone's Wrecking Yard - Stormwater Inspection 5/13/2024 All photos taken by Taylor Fontaine, ERG Date: June 19, 2024 Digitally signed by RUBEN ALAYONGONZALEZ Date: 2024.06.28 13:21:34 -05'00' Date: June 28, 2024 SECTION I - INTRODUCTION Purpose of the Inspection The purpose of the inspection was to determine compliance with the industrial stormwater requirements under 301 and 402(p) of the Clean Water Act (CWA) and its implementing regulations found at 40 Code of Federal Regulations (CFR) Part 122.26. The inspection was unannounced and consisted of interviewing Facility representatives, recording field observations, and taking photographs to document site conditions throughout the Facility at the time of the inspection. Opening Conference 1) Brief narrative documenting those present, introductions, presentation of credentials, and explanation of the purpose of the inspection. On May 13, 2024, a U.S. Environmental Protection Agency (EPA) contractor, Eastern Research Group, Inc. (ERG), conducted an industrial stormwater non-filer inspection at Stone's Wrecking Yard located in Justin, Texas (Facility). Ivy Koberlein of EPA Headquarters, Sharron Crayton of EPA Region 6, and Taylor Fontaine and Mariah Papac of ERG (collectively, EPA Inspection Team) met with the Facility representative, Chris Stone. The EPA Inspection Team presented their credentials and explained that it was EPA's understanding that the Facility did not have an industrial stormwater permit. The EPA Inspection Team explained they were onsite to conduct a Clean Water Act stormwater inspection, which includes observing the current operations of the facility and assessing the potential for stormwater discharges from the Facility. The weather at the time of the inspection was sunny and approximately 84F. According to precipitation data from the National Oceanic and Atmospheric Administration (NOAA)1, the Dallas, Texas area received 0.18 inches of rain the day prior to the inspection and 0.72 inches of rain the day of the inspection. 2) Credentials presented to: Chris Stone 3) Facility acknowledged receiving previous outreach materials or correspondence on Permit requirements? X Yes No Describe: a) The Facility representative stated they had a stormwater permit as recently as 2018 but could not locate records, and the Facility was not recorded in the Texas Commission on Environmental Quality (TCEQ) Water Quality Permit database. 1Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Page 2 of 6 Stone's Wrecking Yard - Stormwater Inspection 5/13/2024 All photos taken by Taylor Fontaine, ERG 4) Facility has been individually notified by permit authority or EPA that it is subject to stormwater requirements? X Yes No Describe: a) The Facility representative stated they had a stormwater permit as recently as 2018 but could not locate records. FACILITY'S OPERATION & PRODUCT DESCRIPTION *Description of business and industrial activities occurring throughout the site. (Include operator's description and note any documentation that further establishes SIC code (permit applications, reports, business registries, website...). Stone's Wrecking Yard is an engine repair shop and auto salvage yard. The Facility accepts used automobiles and parts from public and commercial sources. Fluids (i.e., oil, coolant, antifreeze) are drained from the vehicles, engines and transmissions are removed, and the bodies of the vehicles are cut up to be sold for scrap. The vehicle dismantling and fluids removal takes place inside a large garage. Some of the engines are dismantled and sold for parts. The Facility also does engine repairs on automobiles, boats, lawnmowers, and other equipment. Following dismantling, vehicle parts are then stored uncovered outside in the yard. Other industrial facilities owned/operated by same business entity? o Yes x No Describe: N/A SECTION II - OBSERVATIONS Pollutant Sources Loading/Unloading Operations SITE EVALUATION Note location, quantity/size, design issues, any operation and maintenance (O&M) deficiencies (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are Best Management Practices (BMPs) in place to minimize or eliminate stormwater discharges from industrial activities? The Facility receives vehicles and uses forklifts to offload them at the Facility for dismantling. The Facility also loads parts they sell using forklifts. Loading and unloading takes place near the Facility's entrance in an uncovered area. Industrial Manufacturing/ Processing Operations The Facility dismantles used vehicles and resells used parts. The vehicles are drained of fluids upon arrival at the Facility and reusable parts (i.e., engines, transmissions, tires, and batteries) are removed to be sold. The Facility uses a covered, dedicated garage in the center of the Facility to drain fluids and remove parts from vehicles. Once all parts are removed, the bodies of the vehicles are sold for scrap. The Facility conducts engine repairs inside the garage. Industrial Machinery & Equipment Storage The Facility has one forklift and one loader for moving materials around the Facility. Equipment is located throughout the Facility. Storage of Industrial Materials or Products The Facility stores used vehicle parts and customer equipment throughout the yard without cover and exposed to stormwater [refer to Appendix B, Photograph Log (Photographs 1, 5, 9, 11, 14, 15, 16, 18, 19, 20, 23, 25, and 28)]. Liquid Storage (e.g., Tanks, The Facility stores used engine and hydraulic oil in a poly tote and a 2,200-gallon Liquid Storage Drums) tank. The EPA Inspection Team observed the tote and tank were without secondary containment and with evidence of leaking [refer to Appendix B, Page 3 of 6 Stone's Wrecking Yard - Stormwater Inspection 5/13/2024 All photos taken by Taylor Fontaine, ERG Pollutant Sources Waste Storage/Disposal Areas (solid and/or hazardous) Waste Treatment Facilities (e.g., Pretreatment Systems) SITE EVALUATION Note location, quantity/size, design issues, any operation and maintenance (O&M) deficiencies (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are Best Management Practices (BMPs) in place to minimize or eliminate stormwater discharges from industrial activities? Photograph Log (Photographs 2 and 21)]. The EPA Inspection Team did not observe any receptables (other than small trash cans ranging from 20-30 gallons) for waste storage, and a 30-40 yard uncovered, open-top dumpster, which was utilized to store ties. None observed or reported at the Facility. Fueling Areas, Equipment Maintenance Areas & The Facility representative stated they utilize local gas stations to fuel their Cleaning Areas vehicles and equipment. Sediment & Erosion Controls The EPA Inspection Team observed that the ground surface throughout the Facility was dirt and crushed gravel with the exception of the areas immediately adjacent to the garage, which were paved concrete [refer to Appendix B, Photograph Log (Photographs 2, 3, 9, 11, 13, and 17)]. Sediment and erosion controls were not observed at the Facility. Spills/Leaks Handling The Facility had absorbent material for spills stored in the warehouse. The EPA Inspection Team, however, observed the ground surface throughout the Facility was stained with oil and petroleum sheens in pooled stormwater [refer to Appendix B, Photograph Log (Photographs 1 through 6, 13, 16, 17, 18, and 29)]. Outside Shelters Temporary (Date Established___________________) Permanent None observed or reported at the Facility. Evidence of nonstormwater sources/discharges (allowable if permitted under MSGP)? Evidence of process wastewater sources/discharges? Evidence of non-stormwater sources/discharges was not observed during the inspection. Evidence of process wastewater sources/discharges were not observed during the inspection. Page 4 of 6 Stone's Wrecking Yard - Stormwater Inspection 5/13/2024 All photos taken by Taylor Fontaine, ERG OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS The EPA Inspection Team observed two stormwater discharge points from the Facility. These were identified as areas with evidence of concentrated flow offsite. 1) Discharge Point #1 was in the southwestern portion of the Facility. The gradient of the facility slopes from the fence line down to the drainage ditch. Near the discharge point, there are patches of grass missing along the slope, loose wood near the fence line and black staining along the Number and description drainage ditch. Stormwater flows downhill from the Facility fence line of each potential southwest towards the adjacent constructed stormwater conveyance (e.g., Stormwater Discharge drainage ditch) that surrounds the Facility [refer to Appendix B, Point from the Facility Photograph Log (Photograph 31)]. 2) Discharge Point #2 was along the western boundary of the Facility. Sediment and rocks are downhill from the fence line along the route of the discharge. Soil is present at the junction of the flow path and the stormwater conveyance. Stormwater is conveyed from the Facility west towards the adjacent stormwater conveyance [refer to Appendix B, Photograph Log (Photograph 33). Evidence of pollutants migrating offsite (stains, deposits, ponding) at discharge points, into receiving waters or in The EPA Inspection Team observed evidence of sediment and rocks deposited offsite into the stormwater conveyance at Discharge Point #2 [refer to Appendix B, Photograph Log (Photograph 33)]. MS4 Evidence of Nonstormwater Discharges leaving site (authorized or unauthorized) The EPA Inspection Team observed evidence of sediment and rocks deposited offsite into the stormwater conveyance at Discharge Point #2 [refer to Appendix B, Photograph Log (Photograph 33)]. Stated in the "Sediment & Erosion Controls" section of this report, the EPA Description of general Inspection Team observed that the ground surface throughout the Facility was gradients/slopes onsite, dirt and crushed gravel with the exception of the areas immediately adjacent to all apparent discharge the garage which were paved concrete [refer to Appendix B, Photograph Log points, and discharge (Photographs 2, 3, 9, 11, 13, and 17)]. The EPA Inspection Team observed the pathway from Facility to Facility to be graded slightly outwards towards the west from the center, Receiving Water or MS4 conveying stormwater to the west and southwest. (storm drains, channel, swale, ditches, driveway, See the Section above titled "Number and description of each potential pipes, & etc.) Stormwater Discharge Point from the Facility" above for more information on discharge points. SECTION III - AREAS OF CONCERN 1) At the time of the inspection, the EPA Inspection Team identified the following at the Facility: Page 5 of 6 Stone's Wrecking Yard - Stormwater Inspection 5/13/2024 All photos taken by Taylor Fontaine, ERG a. The EPA Inspection Team observed the Facility to be engaged in the sale of used auto parts and engine repair. These activities are included in the description of SIC Codes 5015 - Motor Vehicle Parts, Used and 7538 - General Automotive Repair Shops. SIC Code 5015 is regulated under 40 C.F.R. 122.26 for stormwater discharges associated with industrial activity. b. The Facility's outdoor areas were used for industrial activities including storage of scrap parts and materials. c. At the time of the inspection, the Facility did not have coverage under the 2021 MSGP for Stormwater Discharges Associated with Industrial Activity. d. Facility stormwater, from areas used for industrial activities, discharges to a stormwater conveyance along the Facility perimeters that is part of the street right-of-way outside the Facility [refer to Appendix B, Photograph Log (Photographs 30 through 36)]. The EPA Inspection Team observed clear evidence of concentrated flow originating from the Facility offsite. 2) The EPA Inspection Team observed a polyethylene tote used to store waste oil that presented evidence of leaking. Specifically, the EPA Inspection Team observed the tote to have oil staining beneath it on the adjacent ground surface [refer to Appendix B, Photograph Log (Photograph 2)]. 3) The EPA Inspection Team observed petroleum staining on the ground surface throughout the Facility including by the 2,200-gallon waste oil tank [refer to Appendix B, Photograph Log (Photographs 2, 5, 6, 13, 18, and 29)]. 4) The EPA Inspection Team observed used gas tanks that were uncapped and contained collected stormwater [refer to Appendix B, Photograph Log (Photographs 19 and 20)]. 5) The EPA Inspection Team observed a used vehicle with a used battery uncovered and exposed to stormwater [refer to Appendix B, Photograph Log (Photograph 23)]. 6) The EPA Inspection Team observed evidence of sediment and rocks deposited offsite into the stormwater conveyance at Discharge Point #2 [refer to Appendix B, Photograph Log (Photograph 33)]. SECTION IV - LIST OF APPENDICES Appendix A - Aerial Location Appendix B - Photograph Log Page 6 of 6