Document 6bymdYVazZZGrDb9ygEqYdb13

EPA Region 10 Enforcement and Compliance Assurance Division Clean Water Act (CWA) Inspection Report Inspection Entry Date/Time Inspection Exit Date/Time Weather Media/Statute(s)/Program(s) Type of Inspection 05/22/2024 9:30 AM (PST) Announced: No 05/22/2024 1:30 PM (PST) Access: Granted Partly Cloudy, 53 F Water, Clean Water Act, NPDES, Industrial Stormwater CEI - Compliance Evaluation Inspection Facility Name Physical Address City/State/Zip Code County Facility GPS Coordinates Facility Mailing Address City/State/Zip Code Pacific Steel and Recycling - Lewiston 604 12th Street North Lewiston, Idaho 83501 Nez Perce County 46.42668 N -117.015248 W 604 12th Street North Lewiston, Idaho 83501 FRS ID NPDES Permit Tracking # 110067021975 IDR053088 Inspection Contacts: Organization Name Title EPA Region 10 Pacific Steel and Recycling - Lewiston Pacific Steel and Recycling - Lewiston Pacific Steel and Recycling - Lewiston Pacific Steel and Recycling Jon Klemesrud Tom Miller David Geiger Danielle Phipps Kirby Farner Lead Inspector Branch Manager HSET Coordination Office Manager HSET Director Present in Present in Opening Conf. Closing Conf. Yes Yes Yes Yes Yes Yes No No No No EPA Inspector Signature/Date JON KLEMESRUD Jon Klemesrud, FDDWES Digitally signed by JON KLEMESRUD Date: 2024.08.09 11:42:52 -07'00' Supervisor Signature/Date PETER CONTRERAS Peter Contreras, Chief FDDWES Digitally signed by PETER CONTRERAS Date: 2024.08.09 15:29:38 -07'00' 2024 CWA NPDES IDR053088 Inspection Report This inspection report is based on information supplied by conversations with Mr. Tim Miller, Mr. David Geiger, or direct observations made at the time of the inspection. This inspection report may also include information gathered from a review of EPA/Idaho Department of Environmental Quality (IDEQ) files and/or public records. SECTION I - INTRODUCTION Facility Description Pacific Steel & Recycling - Lewiston (hereinafter referred to as the "Facility") is a scrap and recycling receiving/processing facility and new steel distributer located within the Port of Lewiston, Idaho. The Facility provides scrap, commercial, consumer and e-recycling services, as well sales and distribution of new steel products within the area. The Facility is one of 34 similar branches operated by Pacific Steel & Recycling across 9 states. The Facility has been at its current location for approximately 25 years, operating on approximately 7.87 acres north of the Clearwater River. See Attachment A, Aerial Image (Google Earth). There are approximately 18 employees at the Facility, operating from 8am-4pm, Monday through Friday. Operations generally include scrap receiving, scrap storage, scrap processing, scrap shipping, as well as commercial and consumer recycling receiving, storage, processing, and shipping. The Facility also conducts new steel receiving, storage, sales, processing, and shipping. The Facility does not perform any commercial/consumer recycling sorting, only bailing of bailing of the received products. Industrial areas and material storage areas include truck trailer parking and storage areas, new steel storage areas, scrap loading and unloading areas, scrap processing areas, recycling/bin storage and loading/unloading areas, recyling processing (bailing) areas. A rail spur accesses the property from the southern perimeter. Permit Information The Facility is permitted to discharge stormwater to the City of Lewiston's Municipal Separate Storm Sewer System (MS4) under the National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit for Stormwater Discharges Associated with Industrial Activity (MSGP). The 2021 MSGP became effective on March 1, 2021, and is set to expire on February 28, 2026. The Facility certified their Notice of Intent (NOI) (permit application) on May 14, 2021 (Attachment B). The NPDES tracking number issued to the Facility is IDR053088. Prior to the 2021 MSGP, the Facility was covered under the previous version of the permit, the 2015 EPA MSGP. Permitting authority was transferred from EPA Region 10 to Idaho Department of Environmental Quality (IDEQ) on July 1, 2021, as IDEQ became the delegated authority for General NPDES Stormwater Permits under Phase IV of the scheduled transfer. Within their NOI, the Facility identified six potential discharge points/areas where stormwater can leave the property. In general, the Facility directs stormwater not infiltrated into a single catch basin (Outfall 001) located centrally within the property. The Facility has identified three other substantially identical discharge points where stormwater could leave the property, including Outfall 003, Outfall 004, Outfall 005. There is also a roadside catch basin located outside the property boundary, along 12th Street North that the Facility has identified as Outfall 002. The Facility has identified another substantially identical discharge point to Outfall 002, Outfall 006. Both catch basins (Outfall 001 and Outfall 002) are believed to discharge to the MS4. As the Facility's industrial activity falls under the standard industrial classification (SIC) code 5093, (Scrap and Waste Materials), the Facility is subject to the additional requirements of Part 8, Subpart N, Sector N1 (Recycling and Waste Recycling Facilities except Source-Separated), including sector-specific benchmark monitoring for Chemical Oxygen Demand (COD), Total Suspended Solids (TSS), Total Recoverable Iron (Iron), Total Recoverable Aluminum (Aluminum), Total Recoverable Copper (Copper), Total Recoverable Lead (Lead) and Total Recoverable Zinc (Zinc). Page 2 of 64 Entry and Inspection Chronology 2024 CWA NPDES IDR053088 Inspection Report This was an unannounced inspection by EPA Region 10; IDEQ was invited to participate in the inspection but was not in attendance. The inspection consisted of an opening conference, a walk-through of the Facility, a records review, and concluded with a closing conference. During the closing conference I discussed my observations, potential compliance concerns and EPA's general compliance review process. On the day of the inspection, I arrived at the Facility's main office at 9:30AM and was greeted by Branch Manager, Mr. Tom Miller. I introduced myself and discussed that I had been asked to conduct a routine NPDES compliance inspection regarding the Facility's coverage under the MSGP. Mr. Miller discussed that the Facility's Environmental/Health Safety coordinator, Mr. David Geiger, was the primary on-site staff member associated stormwater monitoring conducted for MSGP compliance. Mr. Miller stated that Mr. Geiger was currently out of the office and attending a safety seminar at nearby Lewis-Clark State College. Mr. Miller discussed that he would prefer to have Mr. Geiger present for the inspection and would call Mr. Geiger to pull him from the safety seminar. After Mr. Miller contacted Mr. Geiger, we agreed to begin the inspection at 10:15AM, so that Mr. Geiger could return and join us for the inspection. I departed the Facility and then returned at 10:15AM. Once returned to the main office, Mr. Miller introduced me to Mr. Geiger, and we had initial introductions. Mr. Miller invited us into his back office to begin the inspection. At this time, I presented my EPA inspector credentials and restated the purpose and scope of the inspection. I also provided a copy of EPA's Small Business Resources Information Sheet and EPA Industrial Stormwater Fact Sheet associated with "Scrap Recyling and Waste Recycling Facilities." During our introductions, it was discussed that Mr. Geiger had been at the Facility for approximately 14 years. Among other duties at the Facility, Mr. Geiger was involved with monitoring/sample collection required by the MSGP. It was discussed that general MSGP direction/support comes from Pacific Steel and Recycling's corporate Health & Safety/Environmental Director, Mr. Kirby Farner. It was discussed that Mr. Farner is located at the corporate headquarters in Great Falls, Montana. Following introductions, Mr. Miller provided a brief history on the Facility as well as a general background of dayto-day operations. Regarding permit compliance, it was discussed that in 2023, the Facility had experienced issues with their contract laboratory (Energy Labs) in Billings, Montana that resulted in no samples being collected in 2023. It was discussed that the Facility continues to exceed the benchmark parameters for several parameters. Mr. Miller discussed that the Facility tries to be pro-active regarding stormwater/environmental compliance, emphasizing good housekeeping practices, as the Facility maintains an on-site sweeper and contracts out for routine vacuum sweeping with Valley Sweeping in Lewiston. In addition, berming and infiltration is used to control stormwater discharges from most of the scrap processing areas, various structures and containers are utilized to minimize exposure. To assist in orienting me with the Facility's layout and control measures, a Site Plan was provided (Attachment C). After a brief review of the Site Plan, we prepared to continue the inspection with a site walk-through. Mr. Miller brought in and introduced me to the Facility's Office Manager, Ms. Danielle Phipps; it was discussed that Ms. Phipps would be joining on the walk-through to take duplicate photographs for the Facility during the inspection. We then began the walk-through outside of the main office, along the eastern property boundary. Photographs taken during the inspection are attached to this inspection report as Attachment D, Photograph Log. I was accompanied throughout the inspection by Mr. Miller and Mr. Geiger. Ms. Phipps was present for only the walk-through. Page 3 of 64 SECTION II - OBSERVATIONS Site Review 2024 CWA NPDES IDR053088 Inspection Report As discussed earlier in this report, industrial areas at the Facility generally include truck trailer parking and storage areas, new steel storage areas, scrap loading and unloading areas, scrap processing areas, recycling/bin storage and loading/unloading areas, recyling processing (bailing) areas. The Facility has identified potential pollutant sources exposed to stormwater to include aluminum cans, motor blocks, ferrous and non-ferrous metal, oil, and grease. Potential pollutants include aluminum, copper, iron, lead, zinc, oil, and grease. Examples of best management practices (BMPs) adopted by the Facility include but not limited to minimizing exposure and discharges, good housekeeping, routine sweeping, preventive maintenance of vehicles/equipment, spill prevention and response, on-site inspections, employee training, sediment, and erosion control, inlet protection, berming, management of runoff. As discussed earlier in this report, the Facility identified six potential discharge points/areas where stormwater can leave the property. In general, the Facility directs stormwater not infiltrated into a single catch basin (Outfall 001) located centrally within a paved area of the property. There is also a roadside catch basin located outside the property boundary, along 12th Street North (Outfall 002). Both catch basins are believed to discharge to the MS4. Walk-Through Observations: Location: Eastern Perimeter, Entrance Areas, Northern Perimeter Observation #: OB-001 We first walked north from the main office and observed the unpaved areas along the northeast portions of the Facility (Photo 1). Perimeter fencing surrounds the property, there were two open gated entrances along the northeast perimeter. One primary paved entrance is used for the main office and the employee parking area, the second entrance is just north of the primary entrance and is unpaved and is generally used for truck trailer entry and exit. The northern portion of the Facility is unpaved and flat, stormwater is generally infiltrated within the graveled surface. The area is used for truck/trailer parking and storage, new steel storage and temporary scrap and recyling storage bins. From the eastern perimeter along 12th Street North, we first observed a roadside catch basin that the Facility has identified as Outfall 002 (Photo 2) within the Site Plan (Attachment C). The catch basin is located outside of the Facility's perimeter fencing and collects stormwater along 12th Steet North. An adjacent strip of graveled land/surface separates the Facility's fenced areas and 12th Street North. No discharge into the catch basin was observed at the time of inspection. Due to the slope and surface types, it appeared that during rain events, most of the flow to the catch basin would be from the paved areas of 12th Street North and not from the paved/unpaved portions of the Facility. As 12th Street North is within the Port of Lewison, I discussed that to the extent possible, the Facility should consider direction of flow and source if/when collecting a sample from Outfall 002 (to ensure the flow is representative of Facility's contribution/operations). We continued north along the 12th Street North. and observed a parked trailer containing some scrap metal to be parked along the adjacent strip of graveled land/surface (Photo 3). Mr. Miller discussed that the trailer and parking area is not associated with the business; however, potential customers will occasionally arrive after hours and leave items/trailers within the area and then return for scrap sales/delivery. While referencing the Site Plan (Attachment C), Mr. Geiger and Mr. Miller attempted to verify the location of Page 4 of 64 2024 CWA NPDES IDR053088 Inspection Report Outfall 006, shown to be in the general area that we were standing. They were unsure if the potential outfall was a catch basin/inlet structure. Based upon no observed catch basin or inlet structure, it was believed that Outfall 006 was not a catch basin or inlet, rather a potential area for stormwater not-infiltrated to leave the property. We continued inside the northern gated entrance and observed the norther unpaved portions of the property including the storage areas. We observed empty totes and new steel storage/culverts (Photo 4). Mr. Miller discussed that the empty totes were triple rinsed and are staged at this location to be later utilized by for scrap sorting and storage/transport, as the plastic also serves as a containment structure for any residual debris. We observed several roll-off bins/containers south of the northern storage areas (Photo 5). It was discussed that the roll-off bins/containers are received and staged at the location until they are brought back to the scrap area for processing/crushing. Bins are typically only staged at this receiving location for a half-day. We continued west to the northwest perimeter and observed the fencing and a slight berm separating the northwestern areas from what was described as a marsh area that was heavily vegetated (Photo 6). It was discussed that the marsh area is adjacent to the City of Lewiston's wastewater treatment plant and is not part of the Facility's property. Location: Central Paved Areas, Outfall 001, New Steel Building, Scrap Processing Observation #: OB-002 We continued south into the central areas of the Facility, towards the "new steel building" where pavement begins. The new steel building is an enclosed building where various new steel products are stored and processed/cut indoors under cover. It was discussed that new steel items 20-feet and under are processed/cut indoors, new steel items greater than 20-feet are processed/cut outdoors, generally west of the new steel building. Northeast of the new steel building, we observed the central catch basin identified as Outfall 001 (Photo 7). The paved area was sloped so that the central catch basin receives stormwater from the surrounding paved areas to north, south, east, and west. In general, the paved areas near Outfall 001 appeared to be well maintained and free of debris/staining. These areas include the areas northwest of the office building, areas north and east of the new steel building and areas north of the mixed recycling bins (Photo 8, Photo 9). The central catch basin was equipped with sediment filter fabric, Mr. Geiger discussed that the fabric was last changed out in February 2024. It was discussed that the central catch basin (Outfall 001) is the primary sample collection point for stormwater monitoring. I asked Mr. Geiger how samples are collected from the catch basin, and he explained that a sheet flow sample is collected from the paved surface as stormwater enters the catch basin and sediment filter fabric. We walked around the north side of the new steel building to the western perimeter and observed the cutting area used to process/cut the longer lengths of new steel product (Photo 10). We observed the plate sheering machine/area outdoors under cover on a concrete slab. The torch/cutting area was within an uncovered graveled area north of the plate sheering machine/area. Various steel products were observed to be stored north of the new steel building on storage racks (Photo 11). We continued southwest of the new steel building towards the scrap processing area. We observed the Facility's vehicle fluid drain station used to empty/collect fluids from scrap vehicles before they are processed (Photo 12). The area utilizes an asphalt berm for containment, staining was observed throughout the containment area. Noth of the area, a large, vegetated berm and swale extends along the north perimeter, Page 5 of 64 2024 CWA NPDES IDR053088 Inspection Report between the Facility's property and the vegetative marsh area. Concrete ecology blocks also extend across a portion the north perimeter, between the Facility's access road and the vegetative perimeter (Photo 13). We continued west through the scrap processing area, where scrap metal sorted and compacted. It was discussed that processed scrap is ultimately delivered to Schnitzer Steel in Portland, Oregon. We observed the vegetated berm and swale throughout the northern perimeter (Photo 14), as well as the vegetated berm continuing across the western perimeter of the scrap processing area (Photo 15). We then observed the southern and central portions of scrap processing area. Southern portions of the scrap processing area were unpaved and stacked concrete ecology blocks extended across the southern property line and rail spur entrance (Photo 16, Photo 17). Primary/central scrap sorting and processing areas remain unpaved, and stormwater is designed to be infiltrated (Photo 18, Photo 19). Location: Fuel/Lubricant Storage Area, Consumer/Commercial Recycling Storage Area Observation #: OB-003 Following our time near within the scrap processing area, we continued along the southern perimeter to the Facility's enclosed fuel/lubricant storage area, contained within a repurposed rail car. Stored materials included diesel fuel, hydraulic oil, and engine oil (Photo 20). The diesel tank was double walled, and each product was within secondary containment. In general, the area appeared to be well maintained, stormwater is generally designed to flow south to a vegetated area along the rail spur. North of the fuel/lubricant storage area we observed/discussed a stockpile of absorbant material used for spill response. We also observed the Facility's sweeper attachment (Photo 21). It was discussed that in-house sweeping occurs once per week and as needed. In addition, the Facility utilizes Valley Sweeping for vacuum sweeping services every other week. Mr. Miller discussed that he would have to verify the contracted schedule Valley Sweeping. We continued east along the southern perimeter to the area south of the New Steel Building, we observed the receiving area for the consumer/commercial recyling areas (Photo 22). Materials include mixed recyling, cardboard and newspaper. It was discussed that no sorting consumer/commercial recyling occurs at the Facility, only bailing of the received materials for shipping/transport. The area is generally sloped that stormwater would travel towards Outfall 001. The bailing machine was located just east of the area under cover. NE of the covered bailing area we observed a pile of aluminum piping (Photo 23). It was discussed that due to the longer lengths of piping, the material was temporarily stored at the location so it could be sheared into smaller lengths prior to further processing. From this area we viewed the paved collection area south of Outfall 001, east of the new steel building (Photo 24). Location: Non-Ferrous Scrap Staging Areas, Loading Areas, Southeast Perimeter, Public Recycling/Receiving Area Observation #: OB-004 We continued around the south side for the bailing building and observed stockpiled alumnium scrap awaiting pick-up/shipping (Photo 25). It was discussed that in general, processed materials awaiting pick-up/shipping are stored under cover within shipping containers. Mr. Miller discussed that the stockpiled aluminum materials observed were just pulled from the shipping containers, in preparation for truck shipment to Post Falls, Idaho. We continued to the shipping/loading areas within the southeast corner (Photo 26) and then then exited the Page 6 of 64 2024 CWA NPDES IDR053088 Inspection Report Facility, via a southeast gate along 12th Street North. We then observed the downslope areas south of the Facility's perimeter fencing (Photo 27). We also observed the entrance/exit area used for shipping (Photo 28). Mr. Geiger and Mr. Miller attempted to verify the location of Outfall 003, Outfall 004, and Outfall 005 (Attachment C), shown to be in the general area that we were standing/observing. They were unsure if potential outfalls were catch basin/inlet structures. Based upon no observed catch basin or inlet structure, it was believed that the potential outfalls were not catch basin or inlets, rather a potential area for stormwater not-infiltrated to leave the property. Due to the slope of the area, the Facility had also recently updated their Site Plan to include potential inflow areas (Attachment C). We observed one roadside catch basin/inlet south of the Facility's property, upslope along 12th Street N (Photo 29). The walk-through concluded after observing the Facility's smaller receiving area typically used for smaller deliveries, including batteries, aluminum cans and copper wire (Photo 30). SECTION III - Records Review The following records were reviewed as part of the inspection: Record: Discharge Monitoring Reports (DMRs) & Laboratory Analytical Data Ref #: RR-001 As discussed earlier within this report, the Facility is subject to benchmark monitoring for COD, TSS, Aluminum, Copper, Iron, Lead, and Zinc. Prior to the inspection, I reviewed quarterly DMR data submitted over the past 5-years (May 2019 - May 2024). This was also completed by a review of an exceedance report generated by EPA's Integrated Compliance Information System (ICIS). According to the Facility records, sampling of discharge events occurred on May 17, 2019, January 28, 2020, June 29, 2020, November 18, 2020, March 3, 2022, September 22, 2022, and January 25, 2024. The review noted 14 benchmark exceedances, including exceedances for COD, TSS, Iron, Zinc, Aluminum and Lead: Quarter (Q): Parameter: Q1 2020 TSS Q1 2020 Iron Q1 2020 Aluminum Q1 2020 Zinc Q2 2020 Iron Q2 2020 Aluminum Q4 2020 Lead Reported Value: Benchmark Value: 100 mg/L 138 mg/L 12.6 mg/L 1.00 mg/L 4.92 mg/L 0.75 mg/L 0.138 mg/L 0.11 mg/L 4.00 mg/L 1.0 mg/L 4.52 mg/L 0.75 mg/L 0.0690 mg/L 0.0796 mg/L Page 7 of 64 Q4 2020 TSS Quarter (Q): Parameter: Q4 2020 Iron Q4 2020 Aluminum Q4 2020 Zinc Q1 2022 TSS Q1 2024 TSS Q1 2024 COD 115 mg/L 2024 CWA NPDES IDR053088 Inspection Report 100 mg/L Reported Value: Benchmark Value: 9.05 mg/L 1.0 mg/L 4.52 mg/L 0.75 mg/L 0.222 mg/L 0.110 mg/L 476 mg/L 100 mg/L 309 mg/L 100 mg/L 168 mg/L 120 mg/L At the time of inspection, it was discussed that benchmark and effluent monitoring samples are collected by Mr. Geiger. Samples are mailed via ground shipping to the contract laboratory Energy Labs in Billings, MT for analysis. Chain-of-custody documentation is completed, and samples are placed on bags of ice prior to shipping. As discussed earlier within this report, in 2023, the Facility had experienced issues receiving new sample bottles from Energy Labs, including new bottles not received and/or sent to wrong addresses, which in part resulted in no samples being collected in 2023. As a subsample, I reviewed analytical reports including chain-of-custody documentation from the January 25, 2024, and September 22, 2022, sampling events. It was noted that samples were received at the lab 5 days after collection/mailing resulting in sample temperatures recorded at 21.1 C and 10.8 C, respectively. Record: Stormwater Pollution Prevention Plan (SWPPP) Ref #: RR-002 At the time of the inspection, I conducted a cursory review of the Facility's SWPPP that was certified on August 4, 2021. The SWPPP was developed using the Industrial SWPPP template and appeared to meet the minimum requirements of the MSGP. The Facility's Site Plan (map) was last updated on December 26, 2023 (Attachment C). Corrective action documentation was also included within the SWPPP (Attachment E). Documentation included a January 12, 2024, report discussing that the first quarter inspection in 2023 was missed, and an inspection was conducted 10 days later during the second quarter. The corrective action was documented in response to a Notice of Noncompliance received from IDEQ, which indicated the missed inspection. Based upon the corrective action plan, IDEQ responded with a Compliance Determination Letter (Attachment F). In addition, the SWPPP contained two items serving as corrective action documentation associated with triggering "Additional Implementation Measures (AIM)" under the MSGP, due to the benchmark exceedances. The first correction action was in response to triggering AIM 1 and was dated October 14, 2022. The corrective action discussed increasing contracted sweeping frequency to once per week and increasing the frequency of brooming within the loading area of the non-ferrous areas. The second corrective action was in response to Page 8 of 64 2024 CWA NPDES IDR053088 Inspection Report triggering AIM 2 and was dated February 12, 2014. The corrective action discussed that "based on these results (in comparison to results from other Pacific branches), I don't believe they are reflective of true pollutant constitutes leaving our property" and "therefore, on future sampling, please use a "Sheet Flow Method" which will provide a more true analysis." Site Inspection Reports, Visual Assessments & Annual Reports Ref #: RR-003 At the time of inspection, I requested to review Quarterly Site Inspection Reports, Visual Assessments and Annual Report documentation over the past 5-years (May 2019 - May 2024). Site inspection reports and visual assessments are maintained on-site and were generated using the MSGP templates. See Attachment G, 2024 Q1 Quarterly Visual Assessment Form and Routine Facility Inspection Report. Documented site inspections and visual assessments are currently conducted by Mr. Geiger. Site inspections and visual assessments conducted in 2019 were documented as begin conducted by Mr. Jordan Smith. Quarterly site inspections and visual assessment forms were documented as being completed on the following dates: May 17, 2019, September 30, 2019, December 27, 2019, January 28, 2019, June 29, 2020, September 30, 2020, November 18, 2020, April 6, 2021, June 30, 2021, September 30, 2021, December 27, 2021, March 3, 2022, June 18, 2022, September 22, 2022, December 19, 2023, January 25, 2024. Applicable annual reports (2019-2023) and were also reviewed. SECTION IV- SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted for this inspection. SECTION V - AREAS OF CONCERN The presentation of Area(s) of Concern (AOC) does not constitute a formal compliance determination or violation. The following AOCs were identified as part of the inspection: AOC Reference #: AOC-1 Permit Coverage Signage Location Regulation and/or Permit Requirement: Section 1.3.5 of the 2021 MSGP indicates that notice of permit coverage must be posted in a "safe, publicly assessable location in close proximity to your facility" and "use a font large enough to be readily viewed from a public right-of-way" At the time of inspection, when discussing the permit requirement, Mr. Miller and Mr. Geiger directed me the notice of permit coverage signage, which was posted inside of the main office on the wall of the entrance/exit. Based upon the language in the permit, the concern is that the signage was not viewable from a public right-ofway/location. Post-inspection, on June 12, 2024, Mr. Miller provided an update via email that a permit coverage sign was installed facing the 12th Street North main Facility entrance. See Attachment H, Post Inspection Correspondence. Page 9 of 64 AOC Reference #: AOC-2 2024 CWA NPDES IDR053088 Inspection Report Corrective Action Documentation Regulation and/or Permit Requirement: Section 3.2.2.5, 5.1.1 and 5.1.1.5 of the MSGP identifies conditions requiring corrective action documentation, including SWPPP review and revision: "whenever a visual assessment shows evidence of stormwater pollution (e.g., color, odor, floating solids, settled solids, suspended solids, foam.)" "You must review and revise, as appropriate, your SWPPP (e.g. source of pollution; spill and leak procedures; non-stormwater discharges; the selection, design, installation and implementation of your stormwater control measures) so that this permit's effluent limits are met, and pollutant discharges are minimized." At the time of inspection, it was discussed/observed that corrective action documentation is not completed during incidences of observed stormwater pollution (e.g. color, odor, floating solids, settled solids, suspended solids, foam.) during the quarterly visual assessments. According to the MSGP Visual Assessment Form for January 25, 2024 (Attachment G), the collected sample was described as "dark brown," and the clarity indicator was marked "cloudy." Based upon the language in the permit, the concern is that no corresponding record of SWPPP review/revision (or correct action) was being documented. Post-inspection, on June 12, 2024, Mr. Miller provided an update via email that included the comment from Mr. Farner: "it's a "best practice" to try and correct concerns in "real time" if visually observed. I suggest documenting an attempted improvement (CA) on p.16 of your SWPPP, when visual assessment concerns appear." See Attachment H, Post Inspection Correspondence. AOC Reference #: AOC-3 Additional Implementation Measures (AIM) Level 2 Response Regulation and/or Permit Requirement: Section 5.2.4.1 of the MSGP discusses the Aim Level 2 responses, and states that "you must review you SWPPP and implement additional pollution prevention/good housekeeping SCMs conditional on prevention/good housekeeping SCMs, considering good engineering practices, beyond what you did in your AIM Level 1 responses that would reasonably be expected to bring your exceedances below the parameter's benchmark threshold. Refer to the MSGP sector-specific fact sheets for recommended controls found at [https://www.epa.gov/npdes/stormwater-dischargesindustrial-activities-fact-sheets-and-guidance]" As discussed earlier within this report, based upon the continued benchmark exceedances, the Facility has triggered AIM Level 2 Status. At the time of inspection, it was discussed/observed that the AIM Level 2 corrective action response, dated February 12, 2014, discussed that "based on these results (in comparison to results from other Pacific branches), I don't believe they are reflective of true pollutant constitutes leaving our property" and "therefore, on future sampling, please use a "Sheet Flow Method" which will provide a more true analysis." The concern is that the documented corrective action would not reasonably be expected to lower the exceedances below the parameters benchmark threshold. In addition, it was discussed that sample collection already occurs via a sheet flow method. Post-inspection, on June 12, 2024, Mr. Miller provided an update via email that included the comment from Mr. Farner: "I respectfully submit that the corrective action in this case was a "re-training" of Sheet Flow Sampling Method which could result in bringing constituent levels down and more representative results. This is substantiated in writing (on February 12, 2024) with the six-minute YouTube link as part of the CA. It is possible, that a refined sampling process would reduce a cloudy visual sample and potentially unrepresentative results. Page 10 of 64 AOC Reference #: AOC-4 2024 CWA NPDES IDR053088 Inspection Report Sample Preservation Temperature Regulation and/or Permit Requirement: Section 4.2. of the MSGP discusses that required monitoring, including benchmark, "unless otherwise specified, samples must be analyzed consistent with 40 CFR Part 136 analytical methods that are sufficiently sensitive for the monitored parameter. Within 40 CFR Part 136, Table II (Required Containers, Preservation Techniques, and Holding Times) states "Aqueous samples must be preserved at 6 C" Per the Industrial Stormwater Monitoring and Sampling Guide "samples should be kept at approximately 39 F (4 C) until the cooler is delivered to the lab." As discussed earlier in this report, at the time of inspection it was discussed that the facility utilizes Energy Labs in Billings, MT for sample analysis and bag of ice are used during ground shipping. When reviewing chain-ofcustody documentation for the samples, it was noted that were taking approximately 5-days to be received at the contract laboratory and were received at temperatures such as 21.1 C and 10.8 C. The concern was that samples were not being received within the required preservation temperature. Ensuring proper sample preservation will help confirm the accuracy and precision of the lab's analysis. I discussed that the Facility might consider overnight shipping, switching to a more local laboratory, or adjust the ice/cooling method. Post-inspection, on June 12, 2024, Mr. Miller provided an update via email that "on June 3rd we had a qualifying rain event, and we were able to obtain a sample as outlined by the "Sheet Flow Sampling Method." After David packaged the sample correctly, I had the cooler next day air freight to Energy Labs in Billings. This should eliminate any delays and ensure the quality of the sample. See Attachment H, Post Inspection Correspondence." AOC Reference #: AOC-5 2023 Benchmark Monitoring and Visual Assessments Regulation and/or Permit Requirement: Section 3.2.1 of the MSGP discusses the required Visual Assessment Frequency, required quarterly. Section 4.2.2.3. of the MSGP discusses the required Benchmark Monitoring Schedule, required quarterly. Section 8.N.7. of the MSGP identifies sector specific benchmarks that apply to Sector N. As discussed earlier within this report, at the time of inspection it was discussed that the Facility had experienced issues receiving new sample bottles from Energy Labs, including new bottles not received and/or sent to wrong addresses, which in part resulted in no samples being collected in 2023. The 2023 Annual Report stated that "there were no discharges/sample events" and "there were no discharge/sample events qualifying a visual assessment." Based upon the impervious areas and outfall(s) observed at the time of inspection, it is assumed that the Facility would routinely discharge during rain events, providing an opportunity for sample collection and a visual assessment. Based upon the permit language, the concern is that the Facility did not collect a quarterly benchmark sample or visual assessment during any quarter within 2023. Post-inspection, on June 12, 2024, Mr. Miller provided an update via email that included the comment from Mr. Farner: "It's fair to say that for a sig. portion CY23, the facility was not able to sample due to two errors made by Energy Labs (Billings) in getting coolers to #25. This is well documented. These errors were corrected (by the lab) and Branch #25 sampled in January 2024." Page 11 of 64 2024 CWA NPDES IDR053088 Inspection Report SECTION VI - CLOSING CONFERENCE AND POST INSPECTION ACTIVITIES Closing Conference Following the Facility tour and records review, a closing conference was held with Mr. Miller and Mr. Geiger. I discussed my general observations, potential area of concerns and next steps. I then thanked everyone for their time and cooperation with the inspection and departed the Facility. Post-Inspection Activities Post Inspection, on May 31, 2024, I called the City of Lewiston and spoke with Mr. Joe Kaufman, Engineering Project Supervisor: Stormwater - Wastewater, regarding the MS4 Drainage system along 12th Street North. Mr. Kaufman discussed/provided stormwater infrastructure mapping detailing the MS4 connection system within the area. According to the City, the collection system associated with the Facility drains subsurface to a discharge pipe and into the marsh/pond area located north/northwest of the Facility. The marsh/pond is part of the Lewiston Levee system which is pumped to the Clearwater River (Attachment H). Post-inspection, on May 31, 2024, I provided a follow-up email summarizing the inspection activities and observations, including areas of concern. I also discussed my communication with the City of Lewiston and provided a copy of the MS4 mapping (Attachment H). On June 12, 2024, Mr. Miller responded to my email and provided an update to the potential areas of concern discussed at the time of inspection. The email also included comments made by Mr. Miller (Attachment H). SECTION VII - LIST OF APPENDICES Attachment A - Aerial Image (Google Earth) Attachment B - Notice of Intent (NOI) Attachment C - Site Plan Attachment D - Photograph Log Attachment E - Corrective Action Documentation Attachment F - IDEQ Notice of Noncompliance & Compliance Determination Letter Attachment G - 2024 Q1 Quarterly Visual Assessment Form & Routine Facility Inspection Report Attachment H - Post-Inspection Email Correspondence & City of Lewiston MS4 Mapping Page 12 of 64 2024 CWA NPDES IDR053088 Inspection Report ATTACHMENT A Aerial Image (Google Earth) Page 13 of 64 2024 CWA NPDES IDR053088 Inspection Report ATTACHMENT B Notice of Intent (NOI) Page 14 of 64 NPDES FORM 3510-6 Permit Inf ormation 2024 CWA NPDES IDR053088 Inspection Report UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, DC 20460 NOTICE OF INTENT (NOI) FOR STORMWATER DISCHARGES ASSOCIATED W ITH INDUSTRIAL ACTIVITY UNDER THE NPDES MULTI-SECTOR GENERAL PERM IT FORM Approved OMB No. 2040-0004 Master Permit Number: IDR050000 NPDES ID: IDR053088 Eligibility Information State/territory where your facility is discharging: ID Does your facility discharge to federally recognized Indian Country lands? No Are you a "Federal Operator" as defined in Appendix A (https://www.epa.gov/sites/production/files/2021-01/documents/2021_msgp__appendix_a_-_definitions.pdf)? No Which type of form would you like to submit? Notice of Intent (NOI) By indicating "Yes" below, I confirm that I understand that the MSGP only authorizes the stormwater discharges in Part 1.1.2 and the allowable non-stormwater discharges listed in Part 1.2.2. Any discharges not expressly authorized in this permit cannot become authorized or shielded from liability under CWA section 402(k) by disclosure to EPA, state, or local authorities after issuance of this permit via any means, including the Notice of Intent (NOI) to be covered by the permit, the Stormwater Pollution Prevention Plan (SWPPP), during an inspection, etc. If any discharges requiring NPDES permit coverage other than the allowable stormwater and non-stormwater discharges listed in Parts 1.2.1. and 1.2.2. will be discharged, they must be covered under another NPDES permit. Yes Are you a new discharger or a new source as defined in Appendix A (https://www.epa.gov/sites/production/files/202101/documents/2021_msgp_-_appendix_a_-_definitions.pdf)? No Have stormwater discharges from your facility been covered previously under an NPDES permit? Yes If yes, provide your most current NPDES ID (i.e., permit tracking number) if you had coverage under EPA's MSGP or the NPDES permit number if you had coverage under an EPA individual permit: IDR053088 Are you discharging to any waters of the U.S. that are designated by the state or tribal authority under its antidegradation policy as a Tier 3 water (Outstanding National Resource water)? (See Appendix L (https://www.epa.gov/sites/production/files/202101/documents/2021_msgp_-_appendix_l_-_list_of_tier_3_tier_2_and_tier_2.5_waters.pdf)) No Does your facility discharge to a federal CERCLA site listed in Appendix P (https://www.epa.gov/sites/production/files/202101/documents/2021_msgp_-_appendix_p_-_list_of_federal_cercla_sites.pdf)? No What is the legal name of the Operator as defined in Appendix A (https://www.epa.gov/sites/production/files/202101/documents/2021_msgp_-_appendix_a_-_definitions.pdf)? PACIFIC STEEL AND RECY CLING What is the name of your facility or activity as defined in Appendix A (https://www.epa.gov/sites/production/files/202101/documents/2021_msgp_-_appendix_a_-_definitions.pdf)? PACIFIC STEEL AND RECY CLING Operator Inf ormation Page 15 of 64 Page 1 of 13 Operator Information Operator Name: PACIFIC STEEL AND RECY CLING Operator Mailing Address Address Line 1: 604 12th Street North Address Line 2: ZIP/Postal Code: 83501 County or Similar Division: Nez Perce 2024 CWA NPDES IDR053088 Inspection Report City: Lewiston State: ID Operator Point of Contact Information First Name Middle Initial Last Name: Tom Miller Title: Manager Phone: 208-743-2181 Ext.: Email: tom_miller@pacif ic-steel.com Facility Inf ormation Facility Information Facility Name: PACIFIC STEEL AND RECY CLING Facility Address Address Line 1: 604 12TH STREET NORTH Address Line 2: ZIP/Postal Code: 59404 County or Similar Division: Nez Perce City: LEWISTON State: ID Latitude/Longitude for the Facility Latitude/Longitude: 48.3034N, 116.5408W Latitude/Longitude Data Source: Map Horizontal Reference Datum: NAD 27 General Facility Information What is the ownership type of the facility? Corporation Estimated area of industrial activity at your facility exposed to stormwater (rounded to the nearest quarter acre): 2.5 Is your facility presently inactive and unstaffed? No Exception f or Inactiv e and Unstaf f ed Facilities: The requirement f or indicator monitoring, impaired waters monitoring, and/or benchmark monitoring does not apply at a f acility that is inactiv e and unstaf f ed, as long as there are no industrial materials or activ ities exposed to stormwater. Page 16 of 64 Page 2 of 13 If circumstances change during the permit term that af f ect y our qualif ications f or this exception to m2o0ni2to4riCnWg rAeqNuPirDemESeInDtsR0(i5.e3.0i8n8duIsntsrpiaelcmtiaotnerRiaelspoorrt activ ities exposure to stormwater or y our f acility 's activ e/inactiv e and staf f ed/unstaf f ed status) y ou must submit a NOI notif y ing EPA of the change in circumstances. Sector-Specific Information Primary Sector: N Primary Subsector: N1 Primary SIC Code: 5093 Discharge Inf ormation By indicating "Yes" below, I confirm that I understand that the MSGP only authorizes the stormwater discharges in Part 1.2.1 and the allowable non-stormwater discharges listed in Part 1.2.2. Any discharges not expressly authorized in this permit cannot become authorized or shielded from liability under CWA section 402(k) by disclosure to EPA, state, or local authorities after issuance of this permit via any means, including the Notice of Intent (NOI) to be covered by the permit, the Stormwater Pollution Prevention Plan (SWPPP), during an inspection, etc. If any discharges requiring NPDES permit coverage other than the authorized stormwater and non-stormwater discharges listed in Parts 1.2.1 and 1.2.2 will be discharged, they must be covered under another NPDES permit. Yes Federal Effluent Limitation Guidelines Identify the Effluent Limitation Guideline(s) that apply to your stormwater discharges. There are no guidelines associated with the sector(s) selected in the Facility Inf ormation section abov e. Are you requesting permit coverage for any stormwater discharges subject to effluent limitation guidelines? No Other Discharge Information Does your facility discharge into a Municipal Separate Sewer System (MS4)? Yes If yes, provide the name of the MS4 operator: City of Lewiston Receiving Waters Information List all of the stormwater discharge points f rom y our f acility. Discharge Point 001: Applicable Sectors Select the Sectors/Subsector(s) that apply to this discharge point. Sector N - SCRAP RECY CLING FACILITIES Subsector N1 - Scrap Recy cling and Waste Recy cling Facilities except SourceSeparated Latitude/Longitude: 46.4276N, 117.0163W This discharge point is Substantially Identical to an existing discharge point. Receiving Water Page 17 of 64 SIC/Activity Code 5093 Page 3 of 13 GNIS Name: n/a Waterbody Name: Clearwater Riv er Is this receiving water saltwater or freshwater? Freshwater 2024LCisWteAdNWPDatEeSr IIDDR:053088 Inspection Report n/a Is this receiving water designated by the state or tribal authority under its antidegradation policy as a Tier 2 (or Tier 2.5) water (water quality exceeds levels necessary to support propagation of fish, shellfish, and wildlife and recreation in and on the water)? No Will you have stormwater discharges from paved surfaces that will be initially sealed or re-sealed with coal-tar sealcoat where industrial activities are located during coverage under this permit? No Benchmark Monitoring Are you subject to benchmark monitoring requirements for a hardness-dependent metal? Yes What is the hardness of your receiving water(s)? 87.5 (mg/L) Impaired Waters Monitoring Is the receiving water listed as impaired on the 303(d) list and in need of a TMDL? No Has a TMDL been completed for this receiving waterbody? No Discharge Point 003: Applicable Sectors Select the Sectors/Subsector(s) that apply to this discharge point. Sector N - SCRAP RECY CLING FACILITIES Subsector N1 - Scrap Recy cling and Waste Recy cling Facilities except SourceSeparated SIC/Activity Code 5093 Latitude/Longitude: 46.427N, 117.0154W This discharge point is Substantially Identical to an existing discharge point. Substantially Identical to Discharge Point ID: 001 Receiving Water GNIS Name: n/a Waterbody Name: Clearwater Riv er Is this receiving water saltwater or freshwater? Freshwater Listed Water ID: n/a Page 18 of 64 Page 4 of 13 Is this receiving water designated by the state or tribal authority under its antidegradation po2li0c2y4aCsWaATiNerPD2E(SorIDTRie0r5320.58)8wIantsepre(cwtiaotnerRqeupoalritty exceeds levels necessary to support propagation of fish, shellfish, and wildlife and recreation in and on the water)? No Will you have stormwater discharges from paved surfaces that will be initially sealed or re-sealed with coal-tar sealcoat where industrial activities are located during coverage under this permit? No Benchmark Monitoring Are you subject to benchmark monitoring requirements for a hardness-dependent metal? Yes What is the hardness of your receiving water(s)? 87.5 (mg/L) Impaired Waters Monitoring Is the receiving water listed as impaired on the 303(d) list and in need of a TMDL? No Has a TMDL been completed for this receiving waterbody? No Discharge Point 007: 002 Applicable Sectors Select the Sectors/Subsector(s) that apply to this discharge point. Sector N - SCRAP RECY CLING FACILITIES Subsector N1 - Scrap Recy cling and Waste Recy cling Facilities except SourceSeparated SIC/Activity Code 5093 Latitude/Longitude: 46.427505N, 117.015384W This discharge point is Substantially Identical to an existing discharge point. Receiving Water GNIS Name: n/a Waterbody Name: Clearwater Riv er Is this receiving water saltwater or freshwater? Freshwater Listed Water ID: n/a Is this receiving water designated by the state or tribal authority under its antidegradation policy as a Tier 2 (or Tier 2.5) water (water quality exceeds levels necessary to support propagation of fish, shellfish, and wildlife and recreation in and on the water)? No Will you have stormwater discharges from paved surfaces that will be initially sealed or re-sealed with coal-tar sealcoat where industrial activities are located during coverage under this permit? No Page 19 of 64 Page 5 of 13 2024 CWA NPDES IDR053088 Inspection Report Benchmark Monitoring Are you subject to benchmark monitoring requirements for a hardness-dependent metal? Yes What is the hardness of your receiving water(s)? 87.5 (mg/L) Impaired Waters Monitoring Is the receiving water listed as impaired on the 303(d) list and in need of a TMDL? No Has a TMDL been completed for this receiving waterbody? No Discharge Point 008: 004 Applicable Sectors Select the Sectors/Subsector(s) that apply to this discharge point. Sector N - SCRAP RECY CLING FACILITIES Subsector N1 - Scrap Recy cling and Waste Recy cling Facilities except SourceSeparated SIC/Activity Code 5093 Latitude/Longitude: 46.426983N, 117.015743W This discharge point is Substantially Identical to an existing discharge point. Substantially Identical to Discharge Point ID: 007 Receiving Water GNIS Name: n/a Waterbody Name: Clearwater Riv er Is this receiving water saltwater or freshwater? Freshwater Listed Water ID: n/a Is this receiving water designated by the state or tribal authority under its antidegradation policy as a Tier 2 (or Tier 2.5) water (water quality exceeds levels necessary to support propagation of fish, shellfish, and wildlife and recreation in and on the water)? No Will you have stormwater discharges from paved surfaces that will be initially sealed or re-sealed with coal-tar sealcoat where industrial activities are located during coverage under this permit? No Benchmark Monitoring Are you subject to benchmark monitoring requirements for a hardness-dependent metal? Yes Page 20 of 64 Page 6 of 13  What is the hardness of your receiving water(s)? 87.5 (mg/L) 2024 CWA NPDES IDR053088 Inspection Report Impaired Waters Monitoring Is the receiving water listed as impaired on the 303(d) list and in need of a TMDL? No Has a TMDL been completed for this receiving waterbody? No Discharge Point 009: 005 Applicable Sectors Select the Sectors/Subsector(s) that apply to this discharge point. Sector N - SCRAP RECY CLING FACILITIES Subsector N1 - Scrap Recy cling and Waste Recy cling Facilities except SourceSeparated SIC/Activity Code 5093 Latitude/Longitude: 46.427043N, 117.017358W This discharge point is Substantially Identical to an existing discharge point. Substantially Identical to Discharge Point ID: 007 Receiving Water GNIS Name: n/a Waterbody Name: Clearwater Riv er Is this receiving water saltwater or freshwater? Freshwater Listed Water ID: n/a Is this receiving water designated by the state or tribal authority under its antidegradation policy as a Tier 2 (or Tier 2.5) water (water quality exceeds levels necessary to support propagation of fish, shellfish, and wildlife and recreation in and on the water)? No Will you have stormwater discharges from paved surfaces that will be initially sealed or re-sealed with coal-tar sealcoat where industrial activities are located during coverage under this permit? No Benchmark Monitoring Are you subject to benchmark monitoring requirements for a hardness-dependent metal? Yes What is the hardness of your receiving water(s)? 87.5 (mg/L) Page 21 of 64 Page 7 of 13 Impaired Waters Monitoring Is the receiving water listed as impaired on the 303(d) list and in need of a TMDL? No Has a TMDL been completed for this receiving waterbody? No 2024 CWA NPDES IDR053088 Inspection Report Discharge Point 010: 006 Applicable Sectors Select the Sectors/Subsector(s) that apply to this discharge point. Sector N - SCRAP RECY CLING FACILITIES Subsector N1 - Scrap Recy cling and Waste Recy cling Facilities except SourceSeparated SIC/Activity Code 5093 Latitude/Longitude: 46.427989N, 117.015394W This discharge point is Substantially Identical to an existing discharge point. Substantially Identical to Discharge Point ID: 001 Receiving Water GNIS Name: n/a Waterbody Name: Clearwater Riv er Is this receiving water saltwater or freshwater? Freshwater Listed Water ID: n/a Is this receiving water designated by the state or tribal authority under its antidegradation policy as a Tier 2 (or Tier 2.5) water (water quality exceeds levels necessary to support propagation of fish, shellfish, and wildlife and recreation in and on the water)? No Will you have stormwater discharges from paved surfaces that will be initially sealed or re-sealed with coal-tar sealcoat where industrial activities are located during coverage under this permit? No Benchmark Monitoring Are you subject to benchmark monitoring requirements for a hardness-dependent metal? Yes What is the hardness of your receiving water(s)? 87.5 (mg/L) Impaired Waters Monitoring Is the receiving water listed as impaired on the 303(d) list and in need of a TMDL? No Page 22 of 64 Page 8 of 13 Has a TMDL been completed for this receiving waterbody? No 2024 CWA NPDES IDR053088 Inspection Report SWPPP Inf ormation Has the SWPPP been prepared in advance of filing this NOI, as required? Yes SWPPP Contact Information: First Name Middle Initial Last Name: Tom Phone: 208-743-2181 Email: tom_miller@pacif ic-steel.com Miller Ext.: SWPPP Availability: Your current SWPPP or certain inf ormation f rom y our SWPPP must be made av ailable through one of the f ollowing three options. Select one of the options and prov ide the required inf ormation. Note: you are not required to post any confidential business information (CBI) or restricted information (as defined in Appendix A (https://www.epa.gov/sites/production/files/2021-01/documents/2021_msgp_-_appendix_a_-_definitions.pdf)) (such information may be redacted), but you must clearly identify those portions of the SWPPP that are being withheld from public access. Option 1: Attach a current copy of your SWPPP to this NOI. Option 2: Maintain a Current Copy of your SWPPP on an Internet page (Universal Resource Locator or URL). Option 3: Provide the following information from your SWPPP: A. Describe your onsite industrial activities exposed to stormwater and potential spill and leak areas. e.g., material storage; equipment f ueling, maintenance, and cleaning; cutting steel beams Aluminum Cans, Motor Blocks, Ferrous Metal, Non-Ferrous Metal, Oil/Grease B. List the pollutants(s) or pollutant constituent(s) associated with each industrial activity exposed to stormwater that could be discharged in stormwater and/or in any authorized non-stormwater discharges listed in Part 1.1.3. Aluminum, Copper, Iron, Lead, Zinc, Oil/Grease C. Describe the control measures you will employ to comply with the non-numeric technology-based effluent limits required in Part 2.1.2 and Part 8, and any other measures taken to comply with the requirements in Part 2.2 Water Quality-Based Effluent Limitations (see Part 5.2.4). Good housekeeping, Preventative Maintenance, Spill Prevention and Response, Internal Ins pections, Employee Training, Sediment and Erosion Control, Management of Runoff D. Provide a schedule for good housekeeping and maintenance (see Part 5.2.5.1) and a schedule for all inspections required in Part 4 (see Part 5.2.5.2). Best Management Practices/Controls will be conducted daily/weekly/quarterly unless corre ctive actions are implemented that requisite new measures and/or more detail. Endangered Species Protection Worksheet: Criterion C2 Page 23 of 64 Page 9 of 13 2024 CWA NPDES IDR053088 Inspection Report The following questions will help you determine your eligibility under Part 1.1.4 of the permit with respect to protection of Endangered Species Act (ESA) species and critical habitat(s). Please refer to Appendix E (https://www.epa.gov/sites/production/files/202101/documents/2021_msgp_-_appendix_e_-_procedures_relating_to_endangered_species_protection.pdf) of the 2021 MSGP for important information regarding your obligations under this permit concerning ESA-protected species and critical habitat(s). Determine ESA Eligibility Criterion Are your industrial activities already addressed in another operator's valid certification of eligibility for your "action area" under eligibility criteria A, C, D, or E of the 2021 MSGP? No Are your industrial activities the subject of a permit under section 10 of the ESA by the USFWS and/or NMFS, and this authorization addresses the effects of your facility's discharges and discharge-related activities on ESA-listed species and critical habitat? No You must determine whether species listed as either threatened or endangered under the Endangered Species Act, and/or their critical habitat are located in y our f acility 's action area. ESA-listed species and critical habitat are under the purv iew of the NMFS and the USFWS. Determine Your Action Area Your "action area" (as defined in Appendix A (https://www.epa.gov/sites/production/files/2021-01/documents/2021_msgp_-_appendix_a__definitions.pdf)) includes all areas to be affected directly or indirectly by the action and not merely the immediate area involved in the action, including areas beyond the footprint of the facility that are likely to be affected by stormwater discharges, discharge-related activities, and authorized non-stormwater discharges. You must select and confirm that all the following are true: In determining my "action area", I have considered that discharges of pollutants into downstream areas can expand the action area well beyond the footprint of my facility and the discharge point(s). I have taken into account the controls I will be implementing to minimize pollutants and the receiving waterbody characteristics (e.g. perennial, intermittent, ephemeral) in determining the extent of physical, chemical, and/or biotic effects of the discharges. I confirm that all receiving waterbodies that could receive pollutants from my facility are included in my action area. True In determining my "action area", I have considered that discharge-related activities must also be accounted for in determining my action area. I understand that discharge-related activities are any activities that cause, contribute to, or result in stormwater and authorized non-stormwater point source discharges, and measures such as the siting, construction, and operation of stormwater controls to control, reduce, or prevent pollutants from being discharged. I understand that any new or modified stormwater controls that will have noise or other similar effects, and any disturbances associated with construction of controls, are part of my action area. True Provide a written description of your action area and explain your rationale for the extent of the action area drawn on your map. Click here for an example. In terms of NMFS - Action Area logically constitutes the West Coast Region by which Wate rs of the State have conveyance associated with this Permit. In terms of USFW, Action A rea reasonably constitutes immediate receiving waters. Attach a map of the action area for your facility. Mapping tool IPaC (the Information, Planning, and Consultation System) located at http://ecos.fws.gov/ipac/ (https://ecos.fws.gov/ipac/) or click here (/net-msgp/documents/action_area_example.pdf) for an example. Name IPAC Resource List - Nez Perce County 051121.pdf (attachment/710553) Uploaded Date 05/14/2021 Size 3.60 MB Determine if ESA-listed species and/or critical habitat are in your facility's action area. Page 24 of 64 Page 10 of 13 ESA-listed species and critical habitat are under the purview of the NMFS and the USFWS, and20in24mCaWnyAcNaPsDesE,SyIoDuR0w5i3ll0n88eeIdnstpoecatciqouniRreeport species and critical habitat lists from both federal agencies. National Marine Fisheries Service (NMFS) To obtain NMFS-listed species and critical habitat inf ormation, use the resources listed below: General Resources: NOAA Fisheries, Regions Page (https://www.f isheries.noaa.gov /regions) For the Northeastern U.S.: NOAA Fisheries Greater Atlantic Region ESA Section 7 Mapper (https://noaa.maps.arcgis.com/apps/webappv iewer/index.html? id=1bc332edc5204e03b250ac11f 9914a27) For Puerto Rico: Acropora critical habitat map (https://www.f isheries.noaa.gov /resource/map/acropora-elkhorn-and-staghorn-coral-critical-habitat-mapand-gis-data) Green turtle critical habitat map (https://www.f isheries.noaa.gov /resource/map/green-turtle-critical-habitat-map-and-gis-data) Hawksbill Turtle critical habitat map (https://www.f isheries.noaa.gov /resource/map/hawksbill-turtle-critical-habitat-map-and-gis-data) Western U.S.: West Coast Region Protected Resources App (https://www.webapps.nwf sc.noaa.gov /portal/apps/webappv iewer/index.html? id=7514c715b8594944a6e468dd25aaacc9) Pacific Islands: Contact the Pacif ic Islands Regional Of f ice at (808) 725-5000 or pirohonolulu@noaa.gov (mailto:pirohonolulu@noaa.gov ) I have checked the webpages listed above and confirmed that: There are NMFS-listed species and/or critical habitat in my action area. For NMFS species, include the full printout from the Species Directory with the correct Region selected. Name NOAA Species Directory - West Coast 051121.pdf (attachment/710555) Uploaded Date 05/14/2021 U.S. Fish and Wildlife Service (USFWS) To obtain FWS-listed species and critical habitat inf ormation, use the resources listed below: IPaC (the Inf ormation, Planning, and Consultation Sy stem) (https://ecos.f ws.gov /ipac/) For instructions f or using IPaC, click here. Size 4.57 MB I have checked the webpages listed above and confirmed that: There are FWS-listed species and/or critical habitat in my action area. For FWS species, include the full printout from your IPaC query/Official Species List. Name IPAC Resource List - Nez Perce County 051121.pdf (attachment/710556) Uploaded Date 05/14/2021 Size 3.60 MB You may be eligible under Criterion C. You must assess whether y our discharges and discharge-related activ ities are likely to adv ersely af f ect ESA-listed species or critical habitat, and whether any additional measures are necessary to ensure no likely adv erse ef f ects. In order to make a determination of y our f acility 's likelihood of adv erse ef f ects, y ou must complete the Criterion C Eligibility f ields below. Criterion C Eligibility Select which applies: Page 25 of 64 Page 11 of 13 2024 CWA NPDES IDR053088 Inspection Report Criterion C2: Facility eligible for Criterion C in the 2015 M SGP with changes to ESAlisted species, critical habitat, or action area. Your facility was eligible for Criterion C in the 2015 MSGP, but there have been changes in your facility's action area, and/or there are additional ESA-listed species and/or critical habitat under the jurisdiction of the USFWS and/or NMFS in your action area since your certification under Criterion C under the 2015 MSGP. You must provide a description of the basis of this criterion selected on your NOI form and provide documentation supporting your eligibility determination in your SWPPP. Select which applies: I am seeking coverage under the MSGP as an existing discharger and there are no modifications to my facility. Provide a description of the changes in the facility's action area. Enter N/A if not applicable. N/A Provide the USFWS and/or NMFS resources consulted that helped you determine that additional species and/or critical habitat have been listed/designated by either of the Services in your action area. NOAA Fisheries and IPAC Resource List What ESA-listed species and/or critical habitat are located in your "action area"? Several Threatened and Endangered. Attached in NOI and Facility SWPPP Binder Distance in miles between your site and the ESA-listed species and/or critical habitat within the action area: 2000 Provide a description of EPA approved measures you will implement or will continue to implement to ensure no likely adverse effects on ESA-listed species and/or critical habitat. 1. No discharge off site as best possible. 2. Source Control and Housekeeping of potential pollutants (SWPPP Intent) Note: Any missing or incomplete inf ormation in this section may result in a delay of y our cov erage under the permit. Historic Preserv ation: Criterion A The following questions will help you determine your eligibility under Part 1.1.5 of the permit with respect to preservation of historic properties. You may still use the paper instructions in Appendix F (https://www.epa.gov/sites/production/files/202101/documents/2021_msgp_-_appendix_f_-_procedures_relating_to_historic_properties_preservation.pdf) of the MSGP in advance or in conjunction with answering the questions in this section of the form. For more information about your State Historic Preservation Office (SHPO) or Tribal Historic Preservation Office (THPO), please visit the National Park Service (NPS) websites at: State Historic Preservation Office (SHPO) (https://www.nps.gov/subjects/nationalregister/state-historic-preservation-offices.htm) Tribal Historic Preservation Office (THPO) (https://www.nps.gov/history/tribes/Tribal_Historic_Preservation_Officers_Program.htm) Are you an existing facility that is resubmitting for certification under the 2021 MSGP? Yes Page 26 of 64 Page 12 of 13 If you are an existing facility you should have already addressed National Historic Prese2r0v2a4tioCnWAActN(PNDHEPSAI)DiRs0su53e0s.88ToIngsapienctcioovneRreagpoert under the 2015 MSGP, you were required to certify that you were either not affecting historic properties or had obtained written agreement from the relevant SHPO or THPO regarding methods of mitigating potential impacts. Will you be constructing or installing any new stormwater control measures? No You are eligible under Criterion A. Certif ication Inf ormation I certif y under penalty of law that this document and all attachments were prepared under my direction or superv ision in accordance with a sy stem designed to assure that qualif ied personnel properly gathered and ev aluated the inf ormation submitted. Based on my inquiry of the person or persons who manage the sy stem, or those persons directly responsible f or gathering the inf ormation, the inf ormation submitted is, to the best of my knowledge and belief , true, accurate, and complete. I hav e no personal knowledge that the inf ormation submitted is other than true, accurate, and complete. I am aware that there are signif icant penalties f or submitting f alse inf ormation, including the possibility of f ine and imprisonment f or knowing v iolations. Signing an electronic document on behalf of another person is subject to criminal, civ il, administrativ e, or other lawf ul action. Certified By: Kirby Farner Certifier Title: HSET Director Certifier Email: kirby _f arner@pacif ic-steel.com Certified On: 05/14/2021 11:45 AM ET Page 27 of 64 Page 13 of 13 2024 CWA NPDES IDR053088 Inspection Report ATTACHMENT C Site Plan Page 28 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 29 of 64 2024 CWA NPDES IDR053088 Inspection Report ATTACHMENT D Photograph Log All photographs taken by Jon Klemesrud on May 22, 2024 Nikon Coolpix AW100 Page 30 of 64 2024 CWA NPDES IDR053088 Inspection Report Photograph Log - Pacific Steel & Recycling - Lewiston Photo #:01 (DSCN3740) Description: Facing west, photo of material storage and trailer parking area located in the northern portion of the Facility. Photo #:02 (DSCN3741) Description: Facing south, photo of stormwater Outfall 002. Roadside catch basin located along 12th Steet North. Photo #:03 (DSCN3742) Description: Facing south, photo from 12th Street North. Facility boundary is within the fenced area. Parked trailer observed within the public right of way. Was discussed the trailer was likely from a customer who arrive outside of business hours. Photo #:04 (DSCN3743) Description: Facing west, photo of material storage area north of the Facility. Triple rinsed/empty totes are stored and used to package and transport materials off-site. Page 31 of 64 2024 CWA NPDES IDR053088 Inspection Report Photograph Log - Pacific Steel & Recycling - Lewiston Photo #:05 (DSCN3744) Description: Facing south, photo within material storage area. Bins are delivered and stored temporarily until brought into the crushing/processing area. Photo #:06 (DSCN3745) Description: Facing south, photo of western perimeter along the northern material storage area. Photo #:07 (DSCN3746) Description: Facing east, photo of central catch basin identified as Outfall 001. Filter/sediment fabric installed within catch basin. Catch basin is located northeast of the New Steel Building. Photo #:08 (DSCN3747) Description: Facing south, photo of catch basin drainage/collection area for Outfall 001. Photo taken east of the New Steel Building. Page 32 of 64 2024 CWA NPDES IDR053088 Inspection Report Photograph Log - Pacific Steel & Recycling - Lewiston Photo #:09 (DSCN3748) Description: Facing west, photo of catch basin/collection area for Outfall 001. Photo taken east of New Steel Building. Photo #:10 (DSCN3749) Description: Facing south, photo of unpaved area east of the New Steel Building. Area is used for cutting/torching of longer metal pieces. Photo #:11 (DSCN3750) Description: Facing east, photo of material storage area located north of the New Steel Building. Photo #:12 (DSCN3751) Description: Photo of bermed area used for fluid drainage of scrap vehicles. Page 33 of 64 2024 CWA NPDES IDR053088 Inspection Report Photograph Log - Pacific Steel & Recycling - Lewiston Photo #:13 (DSCN3752) Description: Facing east, photo paved access road to crushing/processing area. Bermed trench runs along the north end of the crushing/processing area. Photo #:14 (DSCN3753) Description: Facing east, photo paved access road to crushing/processing area. Bermed trench runs along the north end of the crushing/processing area. Photo #:15 (DSCN3754) Description: Facing north, Photo of the bermed western perimeter of the Facility. Photo #:16 (DSCN3755) Description: Facing east, photo of the southwester perimeter of the Facility Page 34 of 64 2024 CWA NPDES IDR053088 Inspection Report Photograph Log - Pacific Steel & Recycling - Lewiston Photo #:17 (DSCN3756) Description: Facing west, photo of rail spur located along the south. Photo #:18 (DSCN3757) Description: Facing northeast, photo of central processing/sorting area. Photo #:19 (DSCN3758) Description: Facing north, photo of central processing/sorting area. Photo #:20 (DSCN3759) Description: Facing south, photo of covered fueling/lubricant area. Page 35 of 64 2024 CWA NPDES IDR053088 Inspection Report Photograph Log - Pacific Steel & Recycling - Lewiston Photo #:21 (DSCN3760) Description: Facing east, photo of stockpiled absorbant materials and sweeper/broom attachment. Photo #:22 (DSCN3761) Description: Facing south, photo of mixed recycling receiving area. Photo #:23 (DSCN3762) Description: Facing southeast, photo of staged aluminum piping awaiting cutting. Due to length/size, piping was staged at location. Area is northeast of mixed recycling receiving area. Photo #:24 (DSCN3763) Description: Facing north, photo of paved collection area for catch basin Outfall 001. Page 36 of 64 2024 CWA NPDES IDR053088 Inspection Report Photograph Log - Pacific Steel & Recycling - Lewiston Photo #:25 (DSCN3764) Description: Facing east, photo of aluminum scrap awaiting pick-up/transport off-site. Shipping container is normally used to store the material awaiting pick-up/transport. Photo #:26 (DSCN3765) Description: Facing east, photo of shipping/loading area. Photo #:27 (DSCN3766) Description: Facing west, photo of southeast perimeter fencing between railway and Facility. Photo #:28 (DSCN3767) Description: Facing north, photo of eastern perimeter fencing between 12th Street North Page 37 of 64 2024 CWA NPDES IDR053088 Inspection Report Photograph Log - Pacific Steel & Recycling - Lewiston Photo #:29 (DSCN3768) Description: Facing north, photo of roadside catch basin located south of the Facility along 12th Street North. Photo #:30 (DSCN3769) Description: Facing south, photo from inside material receiving area. Page 38 of 64 2024 CWA NPDES IDR053088 Inspection Report ATTACHMENT E Corrective Action Documentation Page 39 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 40 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 41 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 42 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 43 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 44 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 45 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 46 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 47 of 64 2024 CWA NPDES IDR053088 Inspection Report ATTACHMENT F IDEQ Notice of Noncompliance & Compliance Determination Letter Page 48 of 64 1118 F St, Lewiston, ID 83501 (208) 799-4370 2024 CWA NPDES IDR053088 Inspection Report Brad Little, Governor Jess Byrne, Director January 11, 2024 Kirby Farner HSET Director Pacific Steel and Recycling 5 River Drive South Great Falls, MT 59404 Subject: Notice of Noncompliance - Pacific Steel and Recycling Idaho Pollutant Discharge Elimination System (IPDES) Permit IDR053088 Dear Mr. Farner: The Idaho Department of Environmental Quality (DEQ) has determined that Pacific Steel and Recycling is out of compliance with IPDES Permit IDR053088. The non-compliance is due to: Failure to conduct an inspection during the first quarter of 2023. Part 3.1.4 of the Permit states "The qualified personnel must conduct inspections at least quarterly..." DEQ is providing this notice so Pacific Steel and Recycling may correct the noncompliance with IPDES Permit IDR053088. Please provide the following information or documentation by February 11, 2024: Written explanation why the facility failed to conduct the inspection during the first quarter of 2023, and what the facility is doing to prevent the recurrence of future noncompliance. DEQ appreciates your cooperation in resolving this matter. DEQ encourages you to continue your compliance efforts; responsibility for compliance with the IPDES permit rests with the permittee. If you have any questions concerning this matter, please do not hesitate to contact me at (208) 7994887 or via email carolyn.whitney@deq.idaho.gov. Sincerely, Carolyn Whitney IPDES Compliance Officer Lewiston Regional Office cc: AJ Maupin, DEQ Lewiston Regional Office Ann Lefler, DEQ State Office Page 49 of 64 2024 CWA NPDES IDR053088 Inspection Report From: To: Cc: Subject: Date: Attachments: Klemesrud, Jon tom_miller@pacific-steel.com Carolyn Whitney EPA Stormwater Inspection - Pacific Steel & Recyling (Lewiston) Friday, May 31, 2024 4:07:00 PM Storm Drainage Nr 12th St North.pdf Hi Tom, Thanks again for your time and assistance last week for the EPA inspection in Lewiston, I enjoyed meeting you, Dave, and Danielle. You were great hosts and seemed very knowledgeable on many items related to stormwater compliance. If helpful just to summarize again, I was tasked by EPA Region 10 (R10) to conduct an on-site Clean Water Act (CWA) inspection, pursuant to the facility's coverage under the industrial stormwater 2021 Multi-Sector General Permit (MSGP) (Tracking #IDR053088). R10 routinely works with IDEQ (and others) on conducting inspections under the CWA. Note that the inspection last week was routine in nature and not based off any complaints. According to EPA/IDEQ records, the facility hadn't been inspected for permit compliance in recent years. As discussed on-site, I will be reviewing my notes/photographs while preparing my inspection report that will be transmitted to you electronically upon completion. I wanted to send this initial/inspection follow-up email to ensure you have my contact information and to circle back on a few items that were discussed. 1. Regarding the Stormwater Collection System, as you recall while walking the facility there were a few questions regarding discharge/outfall locations when comparing what we saw vs what was included in the SWPPP. Post-inspection, I reached out to the City of Lewiston for some stormwater infrastructure mapping for the areas around 12th Street N. The City provided me with the attached map which seems to align with observations on site, one central catch basin inlet located NE of the "New Steel Building" (Outfall 001) and once catch basin inlet located on 12th Street N, adjacent from 7th Ave N (Outfall 002). It's also the City's understanding that there is a buried pipe connection (Asset #6474) to a central manhole (Asset #99058) near "Potential Outfall 005 along the railway south of the property. " Per the City, the collection system within the mapping area drains subsurface to a discharge pipe (Asset #6315) into the marsh/pond area that is located north of the Facility. I believe the marsh/pond is part of the Lewiston Levee system which is pumped to the Clearwater River. I wanted to share this information with you as I think it could be helpful in implementing your SWPPP moving forward. 2. Regarding Corrective Action Documentation, Section 5.1.1 and 5.1.1.5. of the MSGP (page 45 of the permit) discusses that "Conditions Requiring SWPPP Review and Revision to Ensure Effluent Limits are Met" are to include "whenever a visual assessment shows evidence of stormwater pollution (e.g., color, odor, floating solids, settled solids, suspended solids, foam.) Page 14 of the MSGP 2021 Record Keeping Template offers a template to document corrective actions. At the time of inspection, it was discussed that corrective action Page 50 of 64 1118 F St, Lewiston, ID 83501 (208) 799-4370 2024 CWA NPDES IDR053088 Inspection Report Brad Little, Governor Jess Byrne, Director January 17, 2024 Kirby Farner HSET Director Pacific Steel and Recycling 5 River Drive South Great Falls, MT 59404 Subject: Compliance Determination Letter - Pacific Steel and Recycling, Idaho Pollutant Discharge Elimination System (IPDES) Permit IDR053088 Dear Mr. Farner: This letter is a follow-up from the Idaho Department of Environmental Quality (DEQ) regarding the Notice of Noncompliance on January 11, 2024. Based upon the corrective action plan submitted, the reminders implemented by David Geiger, and information available to DEQ at this time, DEQ has determined that you are currently compliant regarding this matter. The receipt of this letter from DEQ is your documentation of this determination and it is recommended that you retain this letter in your facility records. DEQ appreciates your cooperation in resolving this matter. DEQ encourages you to continue your compliance efforts; responsibility for compliance with the IPDES permit rests with the permittee. If you have any questions concerning this matter, please do not hesitate to contact me at (208) 799-4887 or via email carolyn.whitney@deq.idaho.gov. Sincerely, Carolyn Whitney IPDES Compliance Officer Lewiston Regional Office cc: AJ Maupin, DEQ Lewiston Regional Office Ann Lefler, DEQ State Office Page 51 of 64 2024 CWA NPDES IDR053088 Inspection Report ATTACHMENT G 2024 Q1 Quarterly Visual Assessment Form & Routine Facility Inspection Report Page 52 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 53 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 54 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 55 of 64 2024 CWA NPDES IDR053088 Inspection Report Page 56 of 64 2024 CWA NPDES IDR053088 Inspection Report ATTACHMENT H Post-Inspection Email Correspondence & City of Lewiston MS4 Mapping Page 57 of 64 2024 CWA NPDES IDR053088 Inspection Report documentation is not completed during incidences of "observed pollution" during visual assessments. 3. Regarding Permit Coverage Signage, Section 1.3.5 of the MSGP (page 14 of the permit) indicates that the notice of permit coverage must be posted in a "safe, publicly accessible location in close proximity to your facility" and "use a font large enough to be readily viewed from a public right-of-way." At the time of inspection, the permit coverage signage was posted inside the office on the wall. 4. Regarding AIM Level 2 Responses, Section 5.2.4.1 of the MSGP (page 49) discusses the Aim Level 2 Responses, and states that "you must review your SWPPP and implement additional pollution prevention/good housekeeping SCMs, considering good engineering practices, beyond what you did in your AIM Level 1 responses that would reasonably be expected to bring your exceedances below the parameter's benchmark threshold." At the time of inspection, SWPPP documentation indicated the corrective action for the AIM Level 2 Response would be "use a Sheet Flow Method" for sample collection. My concern is that the documented corrective action would not reasonably be expected to lower the exceedances below the parameter's benchmark threshold. In addition, it was discussed that the sample was collected via a sheet flow method. 5. Regarding sample transport/analysis, at the time of inspection it was discussed that the facility utilizes Energy Labs in Billings, MT. for sample analysis and ice is used during transport. When reviewing chain-of-custody documentation for the samples, it was noted that were taking approximately 5-days to be received at the contract laboratory and were received at temperatures such as 21.1 degrees C and 10.8 degrees C. Per the Industrial Stormwater Monitoring and Sampling Guide, as seen on page 30 and 32 of the guide, based upon holding time and sample preservation "samples should be kept at approximately 39 degrees F (4 degrees C) until the cooler is delivered to the lab." Ensuring proper sample preservation will help confirm the accuracy and precision of the lab's analysis. The Facility might consider overnight shipping or switching to a more local laboratory to address the re-occuring issue of samples being received at a temperature greater than 4 degrees C. 6. It was also discussed that in 2023, the Facility had issues receiving sampling materials from their contract laboratory in Billings, MT. lab which resulted in no samples collected during 2023. My concern is that a stormwater sample was not collected during a discharge event in 2023. 7. Regarding on-site observations near the aluminum shipping area, Section 8.N.3.1.2 (page 159 of the permit) states that "minimize contact of stormwater with stockpiled materials, processed materials, and nonrecyclable wastes through implementation of control measures." At the time of inspection, we observed several covered storage areas (shipping containers) to be used for material storage that weren't being utilized. As a reminder, my observations on-site should not be interpreted as a final compliance determination. If you have any further questions about the inspection process or want to discuss any items in more detail, please feel free to reach out to myself, or Carolyn Whitney (IDEQ) (cc'd). Page 58 of 64 2024 CWA NPDES IDR053088 Inspection Report Jon Klemesrud Field, Data, & Drinking Water Enforcement Section Enforcement & Compliance Assurance Division (M/S 20-C04) U.S. Environmental Protection Agency, Region 10 (206) 553-5068 Page 59 of 64 City of Lewiston 2024 CWA NPDES IDR053088 Inspection Report 1 inch = 150 feet RPL365W0813085 RPL365W0813140 920 7th Avenue North Date: 5/31/2024 RPL365W08131C1 RPL365W0813053 RPL365W0813051 RPL365W0813075 RP L05300 8100 RPL0530 RP L05300 810003 1425 7th Avenue North RP L05300 8100 RPL365W0813128 604 12th Street North 1205 6th Avenue North BLDG B 1205 6th Avenue North BLDG A 1205 6th Avenue North 1205 6th Avenue North BLDG C 1224 6th Avenue North RPL365W0813127 1212 6th Avenue North Page 60 of 64 RPL365W0312000 1330 3rd Avenue Nort h 1428 7th Avenue North RP L18000 810401 RP L18000 810501 RP L18000 810503 This drawing is only a visual aid information and locations are approximate. There is no guarantee or warranty is expressed or implied for its accuarcy. RP L18000 12001A 2024 CWA NPDES IDR053088 Inspection Report From: To: Cc: Subject: Date: Tom Miller Klemesrud, Jon; Kirby Farner David Geiger; Tom Miller; Chris Kimball Update. EPA Stormwater Inspection - Pacific Steel & Recyling (Lewiston) Wednesday, June 12, 2024 12:03:22 PM Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Jon, I shared your summery with Kirby Farner, our Corporate HSET Director. Below you will find his input in red. I hope this is helpful. I appreciated your visit because it was a chance for me to grow in knowledge about what is expected regarding managing our facility. No matter how prepared you believe you are, there is always room to improve and get better. As a team in Lewiston, David and I are committed to do just that. Since your visit, we have made the following improvements: 1. Stormwater Collection System. With the help of the map that you provided and some internal conversations, we fully understand what drainage goes where and how it gets there without question. 2. Permit Coverage Signage has been installed, see photo. It's facing 12th St North the main entrance into the facility. 3. I have informed Valley Sweeping of Lewiston, that we do want weekly sweeping of the pavement and along the curb and gutter of 12th St North property line. This is done with their vacuum sweeper. We still maintain our own sweeper as well. Together, this will help ensure proper maintenance is achieved. 4. I believe there might have been some confusion on the aluminum storage areas. Yes, we do have covered storage areas and yes, we do use them. See attached photo. However, the day you were here is also the day we loaded them into a truck for shipment to Real Alloys in Post Falls, ID. See attached dispatch sheet. My crew did have them staged outside to make loading the product more efficient and to verify the weights and the grade of materials loaded. They did this in preparation for the load leaving. It was an unfortunate coincidence during your visit. 5. Storm Water Sampling. On June 3rd we had a qualifying rain event, and we were able to obtain a sample as outlined by the "Sheet Flow Sampling Method." After David packaged the sample correctly, I had the cooler next day air freight to Energy Labs in Billings. This should eliminate any delays and ensure the quality of the sample. As of today, I have no details of the results from the sample. I am happy to forward them to you once I receive them. Please feel free to correspond any other questions you may have about our facility. Kirby, David, and I are happy to respond. Thank you! Page 61 of 64 Tom Tom Miller Branch Manager Lewiston, ID 83501 Ph:208-743-2181 Fax: 208-743-3150 Cell: 208-792-7720 www.pacific-steel.com tom_miller@pacific-steel.com 2024 CWA NPDES IDR053088 Inspection Report From: Klemesrud, Jon <Klemesrud.Jon@epa.gov> Sent: Friday, May 31, 2024 4:08 PM To: Tom Miller <Tom_Miller@pacific-steel.com> Cc: Carolyn Whitney <carolyn.whitney@deq.idaho.gov> Subject: [EXTERNAL] EPA Stormwater Inspection - Pacific Steel & Recyling (Lewiston) Hi Tom, Thanks again for your time and assistance last week for the EPA inspection in Lewiston, I enjoyed meeting you, Dave, and Danielle. You were great hosts and seemed very knowledgeable on many items related to stormwater compliance. If helpful just to summarize again, I was tasked by EPA Region 10 (R10) to conduct an on-site Clean Water Act (CWA) inspection, pursuant to the facility's coverage under the industrial stormwater 2021 Multi-Sector General Permit (MSGP) (Tracking #IDR053088). R10 routinely works with IDEQ (and others) on conducting inspections under the CWA. Note that the inspection last week was routine in nature and not based off any complaints. According to EPA/IDEQ records, the facility hadn't been inspected for permit compliance in recent years. As discussed on-site, I will be reviewing my notes/photographs while preparing my inspection report that will be transmitted to you electronically upon completion. I wanted to send this initial/inspection follow-up email to ensure you have my contact information and to circle back on a few items that were discussed. 1. Regarding the Stormwater Collection System, as you recall while walking the facility there were a few questions regarding discharge/outfall locations when comparing what we saw vs what was included in the SWPPP. Post-inspection, I reached out to the City of Lewiston for some stormwater infrastructure mapping for the areas around 12th Street N. The City provided me with the attached map which seems to align with observations on site, one central catch basin inlet located NE of the "New Steel Building" (Outfall 001) and once catch basin inlet located on 12th Street N, adjacent from 7th Ave N (Outfall 002). It's also the City's understanding that there is a buried pipe connection (Asset #6474) to a central manhole (Asset #99058) near "Potential Outfall 005 along the railway south of the property. " Per the City, the collection system within the mapping area drains subsurface to a discharge pipe (Asset #6315) into the marsh/pond area that Page 62 of 64 2024 CWA NPDES IDR053088 Inspection Report is located north of the Facility. I believe the marsh/pond is part of the Lewiston Levee system which is pumped to the Clearwater River. I wanted to share this information with you as I think it could be helpful in implementing your SWPPP moving forward. This was Pacific's understanding too, as documented in the Notice of Intent (NOI) - conveyance to the City of Lewiston MS4 system and eventually to the Clearwater River. The attached map (MS4 System) is helpful. Let's print-off and put in our Binder (behind our SWPPP site maps). I will do that at Corporate, too. 2. Regarding Corrective Action Documentation, Section 5.1.1 and 5.1.1.5. of the MSGP (page 45 of the permit) discusses that "Conditions Requiring SWPPP Review and Revision to Ensure Effluent Limits are Met" are to include "whenever a visual assessment shows evidence of stormwater pollution (e.g., color, odor, floating solids, settled solids, suspended solids, foam.) Page 14 of the MSGP 2021 Record Keeping Template offers a template to document corrective actions. At the time of inspection, it was discussed that corrective action documentation is not completed during incidences of "observed pollution" during visual assessments. This one is a little confusing (in permit language) since we are not required "to ensure effluent limits are met." Instead, we are under Benchmark Status and AIM/Correction Action Program (i.e. four quarter average). But, either way it's a "best practice" to try and correct concerns in "real time" if visually observed. I suggest documenting an attempted improvement (CA) on p.16 of your SWPPP, when visual assessment concerns appear. 3. Regarding Permit Coverage Signage, Section 1.3.5 of the MSGP (page 14 of the permit) indicates that the notice of permit coverage must be posted in a "safe, publicly accessible location in close proximity to your facility" and "use a font large enough to be readily viewed from a public right-of-way." At the time of inspection, the permit coverage signage was posted inside the office on the wall. The key line in this part is "public right-of-way". That is defined as street, avenue, road, sidewalk, etc. Depending on facility, signage can be seen via public right-of-way by means of an office window. However, this may not always be the case. Consequently, it's agreed at our #25 location, signage on a property fence (in front-of-public right of way) is more aligned with intent. 4. Regarding AIM Level 2 Responses, Section 5.2.4.1 of the MSGP (page 49) discusses the Aim Level 2 Responses, and states that "you must review your SWPPP and implement additional pollution prevention/good housekeeping SCMs, considering good engineering practices, beyond what you did in your AIM Level 1 responses that would reasonably be expected to bring your exceedances below the parameter's benchmark threshold." At the time of inspection, SWPPP documentation indicated the corrective action for the AIM Level 2 Response would be "use a Sheet Flow Method" for sample collection. My concern is that the documented corrective action would not reasonably be expected to lower the exceedances below the parameter's benchmark threshold. In addition, it was discussed that the sample was collected via a sheet flow method. I respectfully submit that the corrective action in this case was a "re-training" of Sheet Flow Sampling Method which could result in bringing constituent levels down and more representative results. This is substantiated in writing (on February 12, 2024) with the six-minute YouTube link as part of the CA. It is possible, that a refined sampling process would reduce a cloudy visual sample and potentially unrepresentative results. 5. Regarding sample transport/analysis, at the time of inspection it was discussed that the facility utilizes Energy Labs in Billings, MT. for sample analysis and ice is used during transport. When reviewing chain-ofcustody documentation for the samples, it was noted that were taking approximately 5-days to be received at the contract laboratory and were received at temperatures such as 21.1 degrees C and 10.8 degrees C. Page 63 of 64 2024 CWA NPDES IDR053088 Inspection Report Per the Industrial Stormwater Monitoring and Sampling Guide, as seen on page 30 and 32 of the guide, based upon holding time and sample preservation "samples should be kept at approximately 39 degrees F (4 degrees C) until the cooler is delivered to the lab." Ensuring proper sample preservation will help confirm the accuracy and precision of the lab's analysis. The Facility might consider overnight shipping or switching to a more local laboratory to address the re-occuring issue of samples being received at a temperature greater than 4 degrees C. This is a black/white case. I agree with and appreciate Mr. Klemesrud's statements. This is a matter where we know that ground shipping works in terms of parameter hold time. But, temperature is a different matter. No matter how much ice we put in the cooler, we can't always control temperature over a 3-5 day period. And, it seems like, After COVID, ground shipping is taking longer and longer... At the same time, from a management perspective, Energy Labs (Billings) provides a consolidated solution that is manageable (for the company). Unless, there is a hold time issue (like in Boise with E-coli parameter/8 hours), I ask Pacific branches to still go to Energy Labs (Billings). We just need to pack with ice via overnight shipping. 6. It was also discussed that in 2023, the Facility had issues receiving sampling materials from their contract laboratory in Billings, MT. lab which resulted in no samples collected during 2023. My concern is that a stormwater sample was not collected during a discharge event in 2023. It's fair to say that for a sig. portion CY23, the facility was not able to sample due to two errors made by Energy Labs (Billings) in getting coolers to #25. This is well documented. These errors were corrected (by the lab) and Branch #25 sampled in January, 2024. 7. Regarding on-site observations near the aluminum shipping area, Section 8.N.3.1.2 (page 159 of the permit) states that "minimize contact of stormwater with stockpiled materials, processed materials, and nonrecyclable wastes through implementation of control measures." At the time of inspection, we observed several covered storage areas (shipping containers) to be used for material storage that weren't being utilized. Business circumstances are nearly always changing at scrap metal facility. Consequently, it is impractical for best practices (as detailed in a SWPPP) to be followed 100% of the time. Nevertheless, this was a good observation by Mr. Klemesrud and reminder to permitted facility to do the best it can. As a reminder, my observations on-site should not be interpreted as a final compliance determination. If you have any further questions about the inspection process or want to discuss any items in more detail, please feel free to reach out to myself, or Carolyn Whitney (IDEQ) (cc'd). Jon Klemesrud Field, Data, & Drinking Water Enforcement Section Enforcement & Compliance Assurance Division (M/S 20-C04) U.S. Environmental Protection Agency, Region 10 (206) 553-5068 CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Page 64 of 64