Document 6BnnVJKNR39YbRrd93XgqMj5o

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: February 27, 2024 Entry: 10:27 AM Exit: 11:45 AM 60's and sunny Water - CWA 301, 402 - Industrial SW/NEC Trademark Metals Recycling Trademark Metals Recycling - Miami Shredder Miami-Dade Class VI Permit - CLVI-20180023 5093* 3440 NW 135th Street Opa Locka, FL 33054 25.895818, -80.256770 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: 3440 NW 135th Street Opa Locka, FL 33054 Miami-Dade 7:00 AM - 4:30 PM (M - F); 7:00 AM - 12:00 PM (Sat); Closed (Sun) 16 7.5 acres in total with approximately 6.3 acres of outdoor activity Opa Locka Canal, approximately 300' north of the facility 2005 Onsite Representatives: Name: Sixto Chavez Title: Facility Manager Phone: 813-469-1864 Email: sean.peloquin@tmrecycling.com Authorized Official: Contacted? Yes No Name: Joe Stalker Title: Environmental Manager Phone: 813-394-9919 Email: joe.stalker@tmrecycling.com Additional Personnel Participating in Inspection: Name: Title: Mark Bianculli Regional Manager Sean Peloquin Facility Manager - Opa Locka yard Inspector(s): Kate Forsmark Kelsey Guy Rachel Olugbemi Jeremy Judd Inspection Report Author: Name: Kate Forsmark Title: Lead Inspector Inspector Inspector Inspector Signature: Company: Eastern Research Group, Inc. Eastern Research Group, Inc. Environmental Protection Agency, Headquarters Environmental Protection Agency, Region 4 Date: March 22, 2024 Page 1 of 6 SECTION I - INTRODUCTION Trademark Metals Recycling - Miami Shredder Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted 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 CWA and its implementing regulations found at 40 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 February 27, 2024, a U.S. Environmental Protection Agency (EPA) contractor, Eastern Research Group, Inc. (ERG), conducted an industrial stormwater non-filer inspection at Trademark Metals Recycling - Miami Shredder located in Opa Locka Florida (facility). Rachel Olugbemi of EPA Headquarters, Jeremy Judd of EPA Region 4, and Kate Forsmark and Kelsey Guy of ERG (collectively, EPA Inspection Team) met with the Facility representatives Sixto Chavez, Joe Stalker, and Mark Bianculli. 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 64F. According to precipitation data from the National Oceanic and Atmospheric Administration (NOAA)1, the Opa Locka, Florida area received no rain the day of or the day prior to the inspection. 2) Credentials presented to: Sixto Chavez and Joe Stalker 3) Facility acknowledged receiving previous outreach materials or correspondence on Permit requirements? Yes No Describe: N/A 4) Facility has been individually notified by permit authority or EPA that it is subject to stormwater requirements? Yes No Describe: The facility is aware of industrial stormwater permitting requirements for all of Trademark Metals Recycling's other Florida facilities, which are located outside of Miami-Dade County and have industrial stormwater permits. Miami-Dade County restricts metals recycling facilities under SIC Code 5093 from discharging stormwater. Due to this restriction, the facility directs stormwater to a facility-owned dry infiltration pond for groundwater infiltration, permitted under a Class VI Permit# CLVI-20180023 through Miami-Dade County's Municipal Code Section 24-47, effective since July 16, 2019. 1Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Page 2 of 6 Trademark Metals Recycling - Miami Shredder Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted 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...). The facility is a shredder yard that recycles scrap metals. Ferrous metals are only received from commercial sources or transferred from the Trademark Metals Recycling - Opa Locka facility (the Opa Locka facility) across Cairo Lane and are shredded onsite at the facility. Loads are inspected before they are accepted, and any hazardous materials are rejected. Once the facility processes materials through shredding, the materials are sent out for recycling via rail car or into export containers for shipment on trucks. Other industrial facilities owned/operated by same business entity? Yes No Describe: Trademark Metals Recycling has 22 metals recycling facilities throughout Florida. SECTION II - OBSERVATIONS Pollutant Sources Loading/Unloading Operations Industrial Manufacturing/ Processing Operations Industrial Machinery & Equipment Storage Storage of Industrial Materials or Products Liquid Storage (e.g., Tanks, Liquid Storage Drums) SITE EVALUATION Note location, quantity/size, design issues, any O&M deficiencies (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are BMPs in place to minimize or eliminate stormwater discharges from industrial activities? The facility unloads materials from commercial sources for processing in a central location. Once processed, the materials are loaded into trucks to get loaded into rail cars located at the Opa Locka facility. The facility processes ferrous scrap metals for recycling. The ferrous metals are put through a shredder and packaged for delivery to a smelting facility. The facility has two loaders, three materials handlers, and multiple forklifts and skid steers for moving materials around the facility. Equipment is located throughout the facility. The shredder is located in the southern portion. The facility stores ferrous scrap metals throughout the property. Materials are stored in uncovered piles around the yard and exposed to stormwater. The facility stores diesel fuel and hydraulic oil onsite, under cover and in secondary containment for fueling and maintaining equipment. Page 3 of 6 Pollutant Sources Waste Storage/Disposal Areas (solid and/or hazardous) Waste Treatment Facilities (e.g., Pretreatment Systems) Fueling Stations/Equipment Maintenance Areas & Cleaning Areas Sediment & Erosion Controls Trademark Metals Recycling - Miami Shredder Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted Note location, quantity/size, design issues, any O&M deficiencies (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are BMPs in place to minimize or eliminate stormwater discharges from industrial activities? The facility has solid waste dumpsters for general solid waste. Not observed or reported at the facility. The EPA Inspection Team observed fuel stored under cover on the western perimeter of the facility. Per the facility's SPCC plan, the gasoline tank is double walled, and the other tanks are contained within secondary containment. Equipment is maintained under cover inside the maintenance warehouse. Larger equipment (i.e., excavators and materials handlers) is fueled and maintained where the equipment is located. The EPA Inspection Team observed that the ground surface throughout the facility is paved, except for the southern entrance/exist onto Cairo Lane (refer to Appendix B, Photograph 1). The facility is swept weekly using a street sweeper. The facility is sprayed daily to control dust using a water truck. Drains are cleaned regularly using a vacuum truck. Spills/Leaks Handling The facility maintains spill kits with all of their tanks. Outside Shelters Evidence of nonstormwater sources/discharges (allowable if permitted under MSGP)? Evidence of process wastewater sources/discharges? Temporary (Date Established___________________) Permanent Not observed or reported at the facility. Evidence of non-stormwater sources/discharges was not observed during the inspection. None observed. Page 4 of 6 Trademark Metals Recycling - Miami Shredder Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS Number and description of each potential Stormwater Discharge Point from the Facility In accordance with Miami-Dade County requirements, stormwater discharges are not allowed from industrial facilities under SIC Code 5093. The facility maintains a Class VI permit with the county which is needed for the "installation of a drainage system for any project that has known soil or groundwater contamination; or that uses, generates, handles, disposes of, discharges, or stores hazardous materials." As such, the facility directs stormwater to a facility-owned dry retention basin. (refer to Appendix B, Photographs 3 through 7 and 9). Evidence of pollutants migrating offsite (stains, deposits, ponding) at discharge points, into receiving waters or in MS4 Evidence of Nonstormwater Discharges leaving site (authorized or unauthorized) The southern entrance/exit onto Cairo Lane is unpaved and the EPA Inspection Team observed sediment track-out onto the roadway (refer to Appendix B, Photograph 1). None observed. The EPA Inspection Team observed the facility to be graded inward from the perimeters, directing stormwater to onsite storm drains. Description of general gradients/slopes onsite, all apparent discharge points, and discharge pathway from Facility to Receiving Water or MS4 (storm drains, channel, swale, ditches, driveway, pipes, & etc.) Storm drains in the southeast portion of the facility direct stormwater to a 250,000gallon tank where water is used as cooling water for the shredder system. Storm drains in the northern entrance/exit onto 135th street and central portion of the facility are connected to exfiltration trenches where stormwater is filtered prior to infiltration into the groundwater as recharge (refer to Appendix B, Photographs 6, 7, and 9). Exfiltration trenches are subsurface infiltration pipes or tanks designed to store and infiltrate stormwater. The exfiltration trenches are located centrally at the facility. Stormwater in the northwestern portion of the facility is pumped into a sump (refer to Appendix B, Photographs 3 through 5), then across Cairo Lane, and into the Trademark Materials Recycling - Opa Locka facility's Sunshine Pond. Sunshine Pond has dry wells for groundwater infiltration and is designed with a capacity for a 100-year storm. SECTION III - AREAS OF CONCERN 1) The southern entrance/exit onto Cairo Lane is unpaved and the EPA Inspection Team observed sediment trackout onto the roadway (refer to Appendix B, Photograph 1). SECTION IV - LIST OF APPENDICES Page 5 of 6 Appendix A - Aerial Location Appendix B - Photograph Log Appendix C - Facility Submissions Trademark Metals Recycling - Miami Shredder Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted Page 6 of 6