Document 7MpkXZpwKYv8K19KqxNLkO33g

J & J RECYCLING INSPECTION REPORT Inspection Date(s): Facility or Site Name: Facility/Site Physical Location: (city, state, zip code) Mailing address (if different from above): Facility/Site Contact: Website: RCRA ID Number: Latitude, Longitude: 19 July 2023 J & J Recycling 1641 Richmond Terrace Staten Island, NY 10310 Inspection Announced: No Dawn Miller, Office Manager Dawn@JandJRecycling.com 718-757-2011 https://www.jandjrecycling.com/ NYR000262733 40.6399062161234, -74.12203270363634 Facility/Site Personnel Participating in Inspection: Dawn Miller Office Manager Joe DePinto Donald Hawker Corinne Farrell (by email) Yard Manager Scale Operator TABS Consulting Group Dawn@JandJRecycling.com m/718-757-2011 o/718-273-3000 o/718-273-3000 o/718-273-3000 2 52nd Street - Box B11 Brooklyn, NY 11232 Ph - (718) 492-6464 Fax - (718) 492-4066 metrortk@aol.com Inspector(s): Carl F. Plssl US EPA, Enforcement Officer/Engineer Plossl.Carl@epa.gov (212) 637-4088 Additional Inspection Report Elements: 1. J & J RECYCLING INSPECTION PHOTOS.pptx (photos) 2. Stormwater Maps Inspection Report Author: Carl F. Plssl CARL PLOSSL Digitally signed by CARL PLOSSL Date: 2023.10.12 12:49:48 -04'00' Supervisor Leonard Grossman LEONARD GROSSMAN Digitally signed by LEONARD GROSSMAN Date: 2023.10.12 13:21:38 -04'00' 1 RCRA Compliance Branch J & J RECYCLING INSPECTION REPORT SECTION I - INTRODUCTION Purpose of the Inspection Objective A Compliance Evaluation Inspection (CEI) was conducted to determine the facility's compliance with the Resource Conservation and Recovery Act (RCRA) requirements for hazardous waste management. The facility was not previously inspected for RCRA compliance and had not notified as a generator. Opening Conference I, EPA Region 2 RCRA inspector Plssl, arrived at the J & J Recycling facility at ~1:39 pm on July 19, 2023, for an unannounced inspection of the auto salvage and metal recycling facility. I met with Dawn Miller, Office Manager, and was introduced to Donald Hawker, Scale Operator, and Joe DePinto (who would be conducting the facility tour). We discussed the facility past and current operations, waste management and disposal practices, and the nature of RCRA inspections. Ms. Miller was familiar with NYSDEC and other agency inspections but not those conducted pursuant to RCRA federal and state hazardous waste regulations. Facility/Site Description From J & J Recycling: ABOUT J&J RECYCLING J&J Recycling is based in Staten Island, New York. We buy junk cars, all types of scrap metal; ferrous and non ferrous. This includes copper, brass, aluminum, all grades of wire, steel, stainless steel and much more. We also pay cash for cars regardless of condition or title status (salvage or missing, etc). In most cases, the towing is free. Once we receive your car, our professional staff will properly prep your vehicle so it can be safely and properly recycled. Since we are the only car crushing operation on Staten Island, we can pay the best price for your junk car. In addition to buying scrap metal and cars, we also sell various salvaged building materials like rebar, steel beams and plumbing and electrical fittings at a up 50% discount below retail. Give us a call at 718-273-3000 or Click Here for a free quote on how much your car is worth. VEHICLES FOR PARTS See our inventory below of vehicles for parts J&J Recycling has a number of vehicles that are available for our customers to purchase parts from. Images on this site are posted at the time of arrival and may not reflect the current state of the car, please contact us here or call 718-273-3000 to confirm availability and pricing. 2 RCRA Compliance Branch J & J RECYCLING INSPECTION REPORT die According to Ms. Miller and Mr. De: General o Ms. Miller employed here since March 2017 o J&J in operation over 10 years o Untitled cars, later than ~2014, not a significant share (legal issues) o 2 crusher/bailers on site, 1 currently used, the other old (scrap?) o Much of site, i.e., junkyard and storage, is compacted fill, rock, and soil o Fluid and parts storage area floods on occasion Main business o Vehicles 50% towed in, 50% driven in (J&J Towing is unrelated) ~30% significantly damaged o Other metal scrap, including drums Throughput: o Currently process ~6 vehicles/day, ~25-30/week o CNG and EVs turned away Source of scrap vehicles: owners and tow operators (who may have title) Prearrival preparation varies from none to stripped Typical process for "drive-ups": 3 RCRA Compliance Branch J & J RECYCLING INSPECTION REPORT o Weigh in o Functionality assessment (e.g., does the engine still run, transmission still good) o Paperwork and payment o Moved to back w/loader Stacked to await turn Racked Fuel tanks removed (drained in separate area) Remove fluids: oil, antifreeze, trans, power steering, & brake) Remove engine, wheels/tires, battery Brake fluid drained if leaking or brakes are removed for parts CFCs removed o Batteries, wheels, removed Tires separated Wheels separately recycled as scrap Aluminum wheels segregated Wheel weights accumulated in bucket Batteries palleted and plastic wrapped for Lead cable ends not purposely managed separately o Stripped of parts with value Air bags not removed or otherwise processed (left in arrival state)(issue w/FDNY) Mercury switches screened for with older models (becoming rare) Engines removed o Remainder of junker is crushed/bailed (loaded/unloaded in crusher/bailer with grapple) o Stored until sale and transport offsite Waste dispositions: o Batteries are wrapped, accumulated, and sold for recycling to Asisco[sp?] NJ o Cables/auto wires are cut and sold (at times) o Cable ends (some Pb) left with scrap vehicle o Airbags are left in (issue w/FDNY) Facility says that it's has been told to not store/accumulate air bag assemblies or individual cartridges. o Diesel disposition unknown (stored in unlabeled 55-gal drums) o Gasoline used by employees "Bad" gas, e.g., mixed w/diesel, disposed w/Safety Kleen (~55-gal/yr)(unlabeled) Issue w/FDNY regarding gasoline storage/recycling and lack of sufficient fire suppression equipment Facility says that it's has been told to not store/accumulate gasoline w/o full fire suppression equipment as required of gas stations. o Oil sold to recycler (Quick Response) trans, power steering, & brake fluids as oil o Antifreeze sold to recycler (Quick Response) o Wheels sold as parts or scrap Wheel weights not separately/systematically managed 4 RCRA Compliance Branch J & J RECYCLING INSPECTION REPORT o Tires pulled from wheels J&J pays to dispose w/Ben Tires o Mercury switches no longer managed (mostly an issue with older cars, pre-2005) o Electronics scrapped with body o Drum residuals not managed (except as scrap) o Crusher fluids disposed as used oil o Crusher solids as solid waste Facility stormwater: o Stormwater Plan available o Facility footprint heterogeneous surface of soil, fill, concrete, and asphalt with drainage directly to adjacent property, Heritage Park, and the Kill Van Kull (see attached map)1,2 No oil/water separator No above or below ground detention basins/tanks Records requested: o SW Plan Map (attached) SECTION II - OBSERVATIONS The accompanying J & J RECYCLING INSPECTION PHOTOS.pptx document is the complete set of inspection observations made during the facility walkthrough with Mr. DePinto. SECTION III - AREAS OF CONCERN Concerns No proper airbag igniter management Ongoing issue w/waste gasoline storage Unlabeled used oil and contaminated gasoline containers No planned lead cable end management (addressed during inspection) Lack of stormwater controls Closing Conference Ms. Miller, Mr. DePinto, and I reviewed my findings and we discussed any follow up. Ms. Miller asked for guidance on proper management and disposal on air bag cartridges and waste gasoline as they believe that the FDNY prohibits the collection of air bag cartridges and may be prohibiting the collection and storage of waste gasoline. 1 The Kill Van Kull is a tidal strait between Staten Island, New York and Bayonne, New Jersey in the United States. It is approximately 3 miles (4.8 km) long and 1,000 feet (305 m) wide and connects Newark Bay with Upper New York Bay. 2 https://www.nycgovparks.org/parks/R160/ Heritage Park is a passive recreational park located along the waterfront of Staten Island's north shore on the Kill Van Kull and was created through a partnership between The Trust for Public Land, The Port Authority of New York and New Jersey, and NYC Parks. 5 RCRA Compliance Branch J & J RECYCLING INSPECTION REPORT INSPECTION PHOTOGRAPHS: see attached PowerPoint. 6