Document 6oZg9dOKb71E3Y1Qmj8q5aY1

U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 3 WATER BRANCH, ENFORCEMENT AND COMPLIANCE ASSURANCE DIVISION CLEAN WATER ACT COMPLIANCE INSPECTION REPORT for Name of Facility: Metal Center Recycling Facility Address: 4023 Ohio River Road, Huntington, WV 25702 Mailing Address: 4023 Ohio River Road, Huntington, WV 25702 Report Prepared on: 11/2/2023 Date Report Final as of: 11/2/2023 Date By: , Environmental Scientist (PG Environmental) Signature MARK Digitally signed by MARK ZOLANDZ By: ZOLANDZ Date: 2023.11.02 15:49:10 -04'00' Signature , EPA General Information Type of Inspection: Owner: Operator: Permittee: NPDES Permit No: NPDES Permit Issued Date: NPDES Modification Date: NPDES Permit Expiration Date: Receiving Water and/or MS4: Latitude and Longitude: Industrial Stormwater Metal Center Recycling Metal Center Recycling Metal Center Recycling General Permit Number: WV0111457 General Permit Registration Number: WVG612103 September 12, 2019 January 26, 2021 (effective February 25, 2021) September 12, 2024 Ohio River 38.4311 N, -82.3683 W On-Site Facility Inspection Overview On September 18, 2023, a representative from EPA Region III's contractor, PG Environmental (hereinafter, referred to as the EPA Inspector) conducted an industrial stormwater compliance evaluation inspection at Metal Center Recycling (hereinafter, Facility) in Huntington, West Virginia. Metal Center Recycling is the Permittee and owns and operates the Facility. A representative from the West Virginia Department of Environmental Protection (WVDEP) also attended the inspection. Approximate Entry Time: 1:00 PM (EDT) Approximate Exit Time: 2:45 PM (EDT) Unique Project Identifier (UPI): 3E23WN120A Metal Center Recycling (WV0111457) Industrial Stormwater Inspection Report TABLE OF CONTENTS PAGEI. INTRODUCTION............................................................................................................................3 II. INSPECTION PROCESS ................................................................................................................ 3 Inspection Opening Conference .......................................................................................................3 Facility Inspection............................................................................................................................4 Summary of Observations................................................................................................................6 Monitoring and Reporting...................................................................................................6 Closing Conference..........................................................................................................................8 Appendix A: West Virginia National Pollutant Discharge Elimination System Multi-Sector General Water Pollution Control Permit (General Permit No. WV0111457). Appendix B: Photograph Log Appendix C: Exhibit Log o Exhibit 1 - Facility SWPPP, dated July 2022 o Exhibit 2 - EPA ECHO Detailed Facility Report Unique Project Identifier: 3E23WN120A Page 2 of 8 Inspection Date: September 18, 2023 Metal Center Recycling (WV0111457) Industrial Stormwater Inspection Report I. INTRODUCTION On September 18, 2023, a representative from EPA Region III's contractor, PG Environmental (hereinafter, referred to as the EPA Inspector) conducted an industrial stormwater compliance evaluation inspection at Metal Center Recycling (hereinafter, Facility) in Huntington, West Virginia. Metal Center Recycling is the Permittee and owns and operates the Facility. A representative from the West Virginia Department of Environmental Protection (WVDEP) also attended the inspection. The purpose of the inspection was to assess the Permittee's compliance with WVDEP's National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Water Pollution Control Permit (General Permit No. WV0111457 and General Permit Registration No. WVG612103; hereinafter, the Permit; refer to Appendix A). The Facility is classified under Sector G of the Permit, for scrap recycling and waste recycling facilities. The Facility is located at 4023 Ohio River Road, Huntington, WV, and is a metal recycling plant. Metal Center Recycling employs three full time staff, including a supervisor, yard supervisor, and a buyer. The Facility also employs additional part-time staff as needed and is looking to hire more staff members. The Facility's Stormwater Pollution Prevention Plan (SWPPP) map identifies one (1) stormwater outfall, Outfall 001. Outfall 001 is located along the southern fence line near the northeastern corner of the Facility. Runoff from the Facility collects in a trench lined with limestone rocks positioned just upstream of the outfall. The concrete pad where scrap metal is stored on the eastern side of the Facility is sloped to channel runoff into the trench. The outfall discharges into a wetland area south of the Facility. Facility representatives were unaware of how stormwater discharged from Outfall 001 ultimately reaches the Ohio River, which is located less than a quarter mile to the north of the Facility. The Facility typically operates 8 a.m. to 4:30 p.m. Monday-Friday, and 8 a.m. to 11:30 a.m. on the weekends. The Permittee sends quarterly monitoring samples to Pace Analytical. Photographs taken during the inspection are included in Appendix B (Photograph Log), and documents supporting observations in this report are included in Appendix C (Exhibit Log). II. INSPECTION PROCESS Inspection Opening Conference The EPA Inspector arrived at the Facility at approximately 1:00 PM (EDT) for the inspection. Mr. Jake Okun of PG Environmental displayed his Clean Water Act inspector credential to Facility representatives upon entry and explained the primary purpose of the inspection was to evaluate the Facility's compliance relevant to the Permit requirements. The EPA Inspector explained that any information that the Facility deemed to be confidential business information ("CBI") should be identified during the inspection and it would be handled as CBI according to EPA's CBI procedures. Table 1 describes the individuals that participated in the inspection. Name Jake Okun, Inspector Allen Howard Adam Napier David Dennis Table 1: Inspection Attendee List Affiliation Telephone EPA Region III Inspectors and Contractors Email PG Environmental (720)-789-8055 jake.okun@pgenv.com Facility Representatives Metal Center Recycling (304) 390-5746 Metal Center Recycling (304)-390-5746 WVDEP Allen.Howard@themetalcenter.com Themetalcenter2554@gmail.com WVDEP (304) 389-7636 David.a.dennis@wv.gov Unique Project Identifier: 3E23WN120A Page 3 of 8 Inspection Date: September 18, 2023 Metal Center Recycling (WV0111457) Industrial Stormwater Inspection Report Weather and Precipitation At the time of the inspection, the weather was partly cloudy skies with a high temperature of approximately 75 degrees Fahrenheit; no precipitation was experienced during the inspection. National Oceanic and Atmospheric Administration (NOAA) National Weather Service precipitation data for the date of the inspection and 5 days prior are provided in the table below. Table. 2 Precipitation Preceding Inspection1 Station Name Date HUNTINGTON 1.7 ESE, WV US (US1WVCB0017) HUNTINGTON 1.7 ESE, WV US (US1WVCB0017) HUNTINGTON 1.7 ESE, WV US (US1WVCB0017) HUNTINGTON 1.7 ESE, WV US (US1WVCB0017) HUNTINGTON 1.7 ESE, WV US (US1WVCB0017) HUNTINGTON 1.7 ESE, WV US (US1WVCB0017) 9/18/23 9/17/23 9/16/23 9/15/23 9/14/23 9/13/23 Precipitation Amount (inches)2 0.41 0.28 0.00 0.00 0.00 0.08 Facility Inspection As part of the inspection, the EPA Inspector visually observed Facility conditions in the presence of the Facility representatives (refer to Appendix B, Photographs 1 through 13). The Facility encompasses approximately 2 acres and contains a scrap metal/residential commercial recycling center, a garage/material storage shed, uncovered scrap metal piles, and several uncovered roll off containers containing scrap metal. The Facility purchases consumer and industrial scrap metal to store onsite until it can be recycled. Facility representatives informed the EPA Inspector that they direct all runoff from the eastern portion of the Facility (where the uncovered scrap metal is stored) into a drainage ditch that is lined with limestone rocks (refer to Appendix B, Photographs 2 through 5). Facility representatives stated that the scrap metal piles are constantly worked, and that metal is generally stored onsite for a maximum of 35 days before it is removed. The uncovered scrap metal sits on a concrete pad that is layered with Geomat and a plastic landfill-grade liner. The concrete pad is sloped toward the limestone ditch. The ditch drains to a pipe which represents Outfall 001 (refer to Appendix B, Photographs 6 and 7). The pipe then extends below grade to the other side of the Facility's fence (refer to Appendix B, Photograph 8). The ground on the other side of the fence slopes slightly upward, and Facility representatives stated that it is difficult to channel stormwater away from the Facility. Because of this, compliance samples are generally taken from a small pool of water that collects at the edge of the pipe on the Facility-side of the fence line. Facility representatives stated that the surface of the pool is usually flowing during storm events, so they try to collect representative samples from the surface. Outfall 001 is the only discharge point at the Facility, and it is located along the southern fence line in the northeastern portion of the Facility. The outfall discharges to a wetland area that is slightly uphill from the Facility. Facility representatives stated that most of the stormwater runoff from the yard drains into the limestone ditch and seeps into the ground before it reaches Outfall 001. A pig sock was being used as a best management practice (BMP) to prevent metal leeching into the drainage ditch (refer to Appendix B, Photograph 4). The sock is placed around the ditch in between the scrap metal piles and the outfall. Facility representatives indicated that it takes a large storm event for stormwater to flow through the drain to the outfall. Figure 1, SWPPP Site Map (below) shows the site map that is included in the Facility's SWPPP. Note: directions of sheet flow are not included in the site map. 1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Unique Project Identifier: 3E23WN120A Page 4 of 8 Inspection Date: September 18, 2023 Metal Center Recycling (WV0111457) Industrial Stormwater Inspection Report Figure 1. SWPPP Site Map A sheen was observed on water that had collected near the metal receiving area (refer to Appendix B, Photograph 13). This area is where metal initially enters the Facility and is sorted. Additionally, Facility representatives stated that if metal is identified to contain chemicals or liquids, it is sorted until it can be drained properly. Facility representatives stated that their policy is to not accept metal that has not been drained of fluids (e.g., engines), but that metal containing fluids occasionally enters the Facility by mistake. The metal receiving area is located up-gradient from the limestone-lined drainage ditch that ultimately discharges to Outfall 001. Additional details related to the Facility conditions at the time of the inspection are included in the Summary of Observations section below. Records Review The EPA Inspector reviewed records pertaining to Permit requirements. The Facility's electronic discharge monitoring reports (eDMRs) were not provided to the EPA Inspector for review, but Facility representatives stated that they had sampled approximately two weeks prior to the inspection. Samples were still being analyzed by Pace Analytical. The following records were reviewed: EPA Enforcement and Compliance History Online (ECHO) detailed facility reports SWPPP, dated July 2022 Pace Analytical Baseline Samples, April 2022 Routine facility inspection records from January 2022 through August 2023 Unique Project Identifier: 3E23WN120A Page 5 of 8 Inspection Date: September 18, 2023 Metal Center Recycling (WV0111457) Industrial Stormwater Inspection Report Summary of Observations The following section summarizes the EPA Inspector's observations relative to the Facility's Permit requirements, including the status of certain treatment units, operation and maintenance practices, and the Facility's monitoring and reporting documentation. Monitoring and Reporting Appendix A, Part III.1 of the Permit, Representative Sampling, Sample Type and Sampling Period, states "Permittee's quarterly reporting start date is determined by the date coverage under the GP was issued and/or reissued. Registrations issued/reissued on the first through the 15th of a month will use that month to determine the quarterly reporting date. Registrations issued after the 15th of each month will use the next month to determine the reporting start date. For example, if permit coverage was issued in February, on or prior to the 15th of the month, you would report your results by May 20th. If permit coverage was issued in February, after the 15th of the month, you would report your results on June 20th." Section A, Sector G of the Permit includes the following sector-specific monitoring requirements: The Facility failed to submit quarterly DMRs from October 1, 2022, through March 31, 2023 (the two quarters prior to the inspection, refer to Exhibit 2, EPA ECHO Detailed Facility Report). The Facility representatives stated that they sent samples to Pace Analytical, a contract laboratory, to establish background levels in April 2022, but did not conduct any additional compliance sampling until approximately two weeks prior to the inspection. Facility representatives stated that they had sent their most recent quarterly samples to Pace Analytical approximately two weeks prior to the inspection and expected to get their results before the end of the current quarter. Appendix A, Part III.6 of the Permit, Records Retention, states "The permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for the permit, for a period of at least three (3) years from the date of Unique Project Identifier: 3E23WN120A Page 6 of 8 Inspection Date: September 18, 2023 Metal Center Recycling (WV0111457) Industrial Stormwater Inspection Report the sample, measurement, report or application. This period may be extended by request of the Director at any time." DMRs and supporting laboratory data were not available for review onsite at the time of the inspection. Facility representatives were unable to provide hardcopies and did not have any available electronically. Part A of the Permit, Monitoring Requirements, states "Furthermore, permittees must obtain approval of their SWPPP and install and implement all controls and measures contained in their SWPPPs and must modify the SWPPP in accordance with Section B.17 .C when conditions warrant." Facility representatives stated that there were procedures and BMPs in place at the Facility that were not included in their SWPPP. For example, the concrete pad containing Geomatting and landfill liner and the pig sock used to prevent leeching chemicals from the scrap metal piles are not detailed in the SWPPP (refer to Appendix B, Photograph 4). SWPPP Requirements Part B.17.A of the Permit, SWPPP Requirements, states "...To facilitate this process, the plan; shall also include, but not be limited to: A site map indicating: each drainage and discharge structure; an outline of the drainage area of each discharge point, each past or present area used for outdoor storage or disposal of significant materials; each existing structural control measure to reduce pollutants in stormwater runoff; materials loading and access area; each hazardous waste storage or disposal facility (including each area not required to have a Resource Conservation and Recovery Act (RCRA) permit which is used for accumulating hazardous waste under 40 CFR section 262.34); each well where fluids from the facility are injected underground; sinkholes; springs; and other surface water bodies." The site map contained in the Facility SWPPP was not detailed and did not contain information regarding stormwater drainage. Specifically, the map did not include depiction of BMPs, sheet flow direction, and drainage structures. The site map was simply an aerial image showing the Facility and where the outfall was but did not provide any other information (refer to Figure 1, SWPPP Site Map). Pollution Mitigation Appendix A, Part I.3 of the Permit, Management Conditions, Duty to Mitigate, states "The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit, which has a reasonable likelihood of adversely affecting human health or the environment." The EPA Inspector made the following observations pertaining to discharges that could adversely impact human health or the environment: a. There was a puddle of standing water containing a noticeable sheen positioned near the scrap metal receiving area (refer to Appendix B, Photograph 13). This area is located in proximity to the limestone lined drainage ditch that leads to Outfall 001. The metal receiving area was not contained on all sides, and it appeared that runoff from this area would flow down-gradient toward the drainage ditch (refer to Appendix B, Photograph 9). b. A pig sock was being used as a BMP in the drainage area leading to Outfall 001, but it did not appear to be touching the ground in some places (refer to Appendix B, Photograph 4). The drainage area was located directly next to an uncovered scrap metal storage area (refer to Appendix B, Photographs 4 and 5). Facility representatives stated that stormwater flows Unique Project Identifier: 3E23WN120A Page 7 of 8 Inspection Date: September 18, 2023 Metal Center Recycling (WV0111457) Industrial Stormwater Inspection Report were rarely high enough to reach the pig sock, and that they generally drained prior to reaching the outfall. c. A scrap metal roll off container containing scrap metal that Facility representatives had identified as "potentially containing oil or other chemicals" had holes near the base and was uncovered (refer to Appendix B, Photographs 10 through 12). Facility representatives stated that they placed the scrap metal in the container until they could ensure that it was drained of all fluids/chemicals. It appeared that the water would flow from a hole in the bottom of the container toward the Outfall 001 drainage area in a heavy rain event. Representative Sampling Appendix A, Part III.1 of the Permit, Representative Sampling, Sample Type and Sampling Period, states "Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity." And "Monitoring for all parameters for sectors A-W must be taken before the stormwater comingles with the receiving water. Samples must be taken as close to receiving waters as possible." Facility representatives stated that stormwater monitoring samples were usually taken by scooping out flowing water from the mouth of the pipe upstream of Outfall 001 (refer to Appendix B, Photograph 7). The end of the pipe of Outfall 001 that discharges to the wetland was located on the opposite side of a perimeter fence, and Facility representatives stated that it was difficult to access (refer to Appendix B, Photograph 8). Additionally, the ground on the other side of the fence sloped toward the Facility, and Facility representatives stated that this caused challenges with water flowing out of the outfall (refer to Appendix B, Photograph 1). Closing Conference After the Facility inspection, the EPA Inspector met with the Facility representatives for a closing conference and shared preliminary observations. The EPA Inspector reiterated to the Facility representatives that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by the EPA Inspector upon the additional review of records and documentation. Additional observations may be contained in this inspection report that were not identified at the time of the closing conference, as a result of reviewing additional documentation following the inspection. The inspection concluded at approximately 2:45 PM (EDT). Unique Project Identifier: 3E23WN120A Page 8 of 8 Inspection Date: September 18, 2023