Document 7MQ3MQg95N3gzj5jXwMvOXZX6

U.S. EPA Headquarters Enforcement Division 1200 Pennsylvania Avenue NW, Washington, DC 20004 UNPERMITTED INDUSTRIAL FACILITY STORMWATER INSPECTION CHECKLIST Inspection Date Time Weather Conditions Media/Program February 27, 2024 Entry: 8:50 AM Exit: 11:45 AM 60's and sunny Water - CWA 301, 402 - Industrial SW/NEC Operator Name: Facility or Site Name: Permit ID or Tracking #: SIC Code: Facility Address: (city, state, zip code) Geographic Coordinates: Mailing address: (city, state, zip code) County: Regular Days/Hours of Operation: # of Employees at location: Size of Facility (in acres): Receiving Water(s): Date facility est. @ location: Trademark Metals Recycling Trademark Metals Recycling - Opa Locka Miami-Dade Class VI permit: 20110016 5093* 13200 Cairo Lane Opa Locka, FL 33054 25.893965, -80.258419 13200 Cairo Lane Opa Locka, FL 33054 Miami-Dade 8:00 AM - 4:30 PM (M - F); 8:00 AM - 12:00 PM (Sat); Closed (Sun) 25 15.6 acres with approximately 15.0 acres of outdoor activity Opa Locka Canal, approximately 500' north of the facility 2005 Onsite Representatives: Name: Sean Peloquin Title: Facility Manager - Opa Phone: 813-469-1864 Locka Email: sean.peloquin@tmrecycling.com Authorized Official: Contacted? Yes No Name: Joe Stalker Title: Environmental Manager Phone: 813-394-9919 Email: joe.stalker@tmrecycling.com Additional Personnel Participating in Inspection: Name: Title: Mark Biancullio Regional Manager Sixto Chavez Facility Manager - Miami Shredder Inspector(s): Kate Forsmark Kelsey Guy Rachel Olugbemi Jeremy Judd Inspection Report Author: Name: Kate Forsmark Title: Lead Inspector Inspector Inspector Inspector Signature: Company: Eastern Research Group, Inc. Eastern Research Group, Inc. Environmental Protection Agency, Headquarters Environmental Protection Agency, Region 4 Date: March 22, 2024 Page 1 of 6 SECTION I - INTRODUCTION Trademark Metals Recycling - Opa Locka Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted Purpose of the Inspection The purpose of the inspection was to determine compliance with the industrial stormwater requirements under 301 and 402(p) of the CWA and its implementing regulations found at 40 CFR Part 122.26. The inspection was unannounced and consisted of interviewing facility representatives, recording field observations, and taking photographs to document site conditions throughout the facility at the time of the inspection. Opening Conference 1) Brief narrative documenting those present, introductions, presentation of credentials, and explanation of the purpose of the inspection. On February 27, 2024, a U.S. Environmental Protection Agency (EPA) contractor, Eastern Research Group, Inc. (ERG), conducted an industrial stormwater nonfiler inspection at Trademark Metals Recycling - Opa Locka located in Opa Locka, Florida (facility). Rachel Olugbemi of EPA Headquarters, Jeremy Judd of EPA Region 4, and Kate Forsmark and Kelsey Guy of ERG (collectively, EPA Inspection Team) met with the facility representatives Sean Peloquin, Joe Stalker, and Mark Biancullio. The EPA Inspection Team presented their credentials and explained that it was EPA's understanding that the facility did not have an industrial stormwater permit. The EPA Inspection Team explained they were onsite to conduct a Clean Water Act stormwater inspection which includes observing the current operations of the facility and assessing the potential for stormwater discharges from the facility. The weather at the time of the inspection was sunny and approximately 64F. According to precipitation data from the National Oceanic and Atmospheric Administration (NOAA)1, the Opa Locka, Florida area received no rain the day of or the day prior to the inspection. 2) Credentials presented to: Sean Peloquin 3) Facility acknowledged receiving previous outreach materials or correspondence on Permit requirements? Yes No Describe: N/A 4) Facility has been individually notified by permit authority or EPA that it is subject to stormwater requirements? Yes No Describe: The facility is aware of industrial stormwater permitting requirements; their other facilities, all located outside of Miami-Dade County, have industrial stormwater permits. Miami-Dade County restricts metals recycling facilities under SIC code 5093 from discharging stormwater. Due to this restriction, the facility has a system which retains all stormwater onsite for groundwater infiltration, permitted under a Class VI Permit# 20110016 through Miami-Dade County's Municipal Code Section 24-47, effective since January 27, 2012. 1Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Page 2 of 6 Trademark Metals Recycling - Opa Locka Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted FACILITY'S OPERATION & PRODUCT DESCRIPTION *Description of business and industrial activities occurring throughout the site. (Include operator's description and note any documentation that further establishes SIC code (permit applications, reports, business registries, website...). The facility is a scrap metals recycling facility. According to Mr. Stalker, the Facility's Standard Industrial Classification (SIC) code is 5093 - Scrap and waste materials. Mr. Stalker is the environmental manager of all Trademark Metals Recycling facilities in Florida. The Opa Locka facility acts as the feeder yard or the entry point for scrap metal to enter the facility's system. The facility accepts scrap metal from both public and commercial sources and accepts both ferrous and non-ferrous metals. Loads are inspected before they are accepted, and any hazardous materials are rejected. Upon receipt, the facility sorts the materials and sends them out for recycling once processed. Processing includes sorting non-metals out, separating ferrous and nonferrous metals, and shredding or shearing the metals into transportable sizes. Processed ferrous metals leave the facility via rail cars and non-ferrous metals leave the facility via trucks. Other industrial facilities owned/operated by same business entity? Yes No Describe: Trademark Metals Recycling has 22 metals recycling facilities throughout Florida. SECTION II - OBSERVATIONS Pollutant Sources Loading/Unloading Operations Industrial Manufacturing/ Processing Operations SITE EVALUATION Note location, quantity/size, design issues, any O&M deficiencies (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are BMPs in place to minimize or eliminate stormwater discharges from industrial activities? The facility unloads materials from public and commercial sources for processing. Once processed, the metals are either loaded into trucks in a central location at the facility or onto rail cars located on the western perimeter of the facility for removal from the site. The facility processes ferrous and non-ferrous scrap metals for recycling. Metals are sorted by type using a material handler with a large magnet. Ferrous metals are put through a shredder at the Miami-Shredder location across Cairo Lane and packaged for delivery to a smelting facility. Non-ferrous materials are packaged using a bailer for delivery to a third party. Processing operations occur outside and are exposed to stormwater. Industrial Machinery & Equipment Storage The facility has two mobile shears for cutting metals, one bailer, seven materials handlers, and multiple forklifts and skid steers for moving materials around the facility. Page 3 of 6 Storage of Industrial Materials or Products Liquid Storage (e.g., Tanks, Liquid Storage Drums) Pollutant Sources Waste Storage/Disposal Areas (solid and/or hazardous) Waste Treatment Facilities (e.g., Pretreatment Systems) Trademark Metals Recycling - Opa Locka Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted The facility stores ferrous and non-ferrous scrap metal in uncovered piles around the yard and exposed to stormwater. The facility stores diesel fuel and hydraulic oil onsite, under cover and in secondary containment for fueling and maintaining equipment. Note location, quantity/size, design issues, any O&M deficiencies (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are BMPs in place to minimize or eliminate stormwater discharges from industrial activities? The facility's solid waste dumpsters for general solid waste were located west of the storage warehouse. The dumpsters were exposed to stormwater. None observed or reported at the facility. Fueling Stations/Equipment Maintenance Areas & Cleaning Areas The facility representative stated that the facility stores diesel fuel and hydraulic oil in a central location at the facility. Per the facility's SPCC plan, the tanks are double walled. The tanks are in the processing area and due to safety concerns, the EPA Inspection Team did not observe the tanks. Equipment is maintained under cover inside the storage warehouse. Larger equipment (i.e., excavators and materials handlers) is fueled and maintained where the equipment is located. Sediment & Erosion Controls None observed or reported at the facility; the ground surface throughout the facility is paved. Spills/Leaks Handling Outside Shelters Evidence of nonstormwater sources/discharges (allowable if permitted under MSGP)? The facility representative stated they maintain spill kits in the respective fueling areas. Due to the location of the tanks, the EPA Inspection Team did not observe the spill kits for safety reasons. Temporary (Date Established___________________) Permanent None observed or reported at the facility. The EPA Inspection Team did not observe evidence of non-stormwater sources/discharges. Page 4 of 6 Trademark Metals Recycling - Opa Locka Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted Evidence of process wastewater sources/discharges? None observed. OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS Number and description of each potential Stormwater Discharge point from the facility In accordance with Miami-Dade County requirements (Section 24-47 of the Code of Miami-Dade County), stormwater discharges are not allowed from industrial facilities under SIC code 5093. The facility maintains a Class VI permit with Miami-Dade County which is required for the "installation of a drainage system for any project that has known soil or groundwater contamination; or that uses, generates, handles, disposes of, discharges, or stores hazardous materials" (refer to Appendix C). As such, the facility developed a stormwater management system to retain stormwater at the facility. The EPA Inspection Team observed that facility stormwater is directed to onsite storm drains which drain to Sunshine Pond, an infiltration pond, for retention, evaporation, and groundwater infiltration. The inlets observed in Sunshine Pond are the end points to the underground stormwater conveyance system which collects stormwater throughout the facility. The EPA Inspection Team also observed the perimeters to be the highest points at the facility which facilitates retaining stormwater onsite. Evidence of pollutants migrating offsite (stains, deposits, ponding) at discharge points, into receiving waters or in MS4 Evidence of Nonstormwater Discharges leaving site (authorized or unauthorized) The facility's southern entrance is partially paved and less graded than the northern entrance. The EPA Inspection Team observed sediment track-out onto Cairo Lane (refer to Appendix B, Photographs 2 through 5). None observed. Description of general gradients/slopes onsite, all apparent discharge points, and discharge pathway from Facility to Receiving Water or MS4 (storm drains, channel, swale, ditches, driveway, pipes, & etc.) The EPA Inspection Team observed the facility to be graded inward from all perimeters directing stormwater to one of the onsite storm drains. The onsite storm drains direct stormwater to "Sunshine Pond," the facility's onsite infiltration pond (refer to Appendix B, Photographs 6 through 11). Sunshine Pond has inlets for groundwater infiltration and is designed with a capacity for a 100-year storm. Sunshine Pond additionally has trenches that direct stormwater through a sand filter and into the groundwater as recharge. The EPA Inspection Team observed a pipe from the Trademark Metal Recycling facility across the street (i.e., Trademark Metal Recycling - Miami Shredder). Water collects onsite at the Miami Shredder location and is pumped through the pipe to the Opa Locka facility. The facility representatives stated there is no backflow from their Opa Locka facility to their Miami Shredder facility. Page 5 of 6 SECTION III - AREAS OF CONCERN Trademark Metals Recycling - Opa Locka Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted 1) The EPA Inspection Team observed two inlets in the northern portion of Sunshine Pond to be approximately two feet below the ground surface and filled in with dirt, potentially reducing the functionality/capacity of the inlet and stormwater conveyance system (refer to Appendix B, Photographs 10 and 11). 2) The EPA Inspection Team observed sediment track-out from the facility's southern entrance onto Cairo Lane (refer to Appendix B, Photographs 4 and 5). SECTION IV - LIST OF APPENDICES Appendix A - Aerial Location Appendix B - Photograph Log Appendix C - Facility Document Submissions Page 6 of 6