Document 7Ox7voGeoLv6dkv6zNMVz7Zxa
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION III WATER BRANCH, ENFORCEMENT
AND COMPLIANCE ASSURANCE DIVISION CLEAN WATER ACT
COMPLIANCE INSPECTION REPORT
for
Name of Facility: Denton Scrap Metal Recycling, LLC Facility Address: 24769-A Meeting House Rd, Denton, MD 21629 Mailing Address: 24769-A Meeting House Rd, Denton, MD 21629
Report Prepared on:
3/22/2022 Date
By:
,
Environmental Scientist (PG Environmental)
Signature
Report Final as of: March 23, 2022 Date
By: Signature
, EPA
General Information
Type of Inspection: Owner: Operator: Permittee: NPDES Permit No: NPDES Permit Effective Date: NPDES Permit Expiration Date: Receiving Water and/or MS4: Latitude and Longitude:
Stormwater Denton Scrap Metal Recycling, LLC Denton Scrap Metal Recycling, LLC Denton Scrap Metal Recycling, LLC MDR003194 January 1, 2014 December 31, 2018 Upper Choptank River 38 53' 28.52" N, 75 50' 39.47" W
On-Site Facility Inspection Overview
On February 16, 2022, EPA contractors, PG Environmental and Eastern Research Group (hereinafter, collectively referred to as the EPA Inspection Team) conducted a compliance evaluation inspection at Denton Scrap Metal Recycling, LLC (hereinafter, Facility) in Denton, Maryland. A representative from the Maryland Department of the Environment (MDE) also attended the inspection.
Approximate Entry Time: 8:30 AM (EST) Approximate Exit Time: 11:15 AM (EST)
Unique Project Identifier (UPI): 3E22WN030A
Unique Project Identifier: 3E22WN030A
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Denton Scrap Metal Recycling, LLC (MDR003194) Compliance Evaluation Inspection Report
TABLE OF CONTENTS
Page
I.
INTRODUCTION............................................................................................................................ 3
II. INSPECTION PROCESS ................................................................................................................ 3 Inspection Opening Conference .......................................................................................................3 Facility Site Walk.............................................................................................................................4 Summary of Observations................................................................................................................5 SWPPP Requirements.........................................................................................................5 Benchmark Exceedances.....................................................................................................6 Proper Operation and Maintenance...................................................................................12 Closing Conference........................................................................................................................13
Appendix A: NPDES General Discharge Permit for Storm Water Associated with Industrial Activities, Permit No. 12SWA
Appendix B: Photograph Log Appendix C: Exhibit Log
o Exhibit 1 - Stormwater Pollution Prevention Plan (SWPPP), June 24, 2016 o Exhibit 2 - Revised Stormwater Pollution Prevention Plan (SWPPP), February 15, 2022 o Exhibit 3 - Onsite SWPPP Management Review and Certification o Exhibit 4 - Onsite SWPPP Certification o Exhibit 5 - Integrated Compliance Information System Data Report o Exhibit 6 - Corrective action recommendations in the June 24, 2016 SWPPP o Exhibit 7 - Detailed Facility Report
Unique Project Identifier: 3E22WN030A
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Denton Scrap Metal Recycling, LLC (MDR003194) Compliance Evaluation Inspection Report
I.
INTRODUCTION
On February 16, 2022, EPA contractors, PG Environmental and Eastern Research Group (hereinafter, collectively referred to as the EPA Inspection Team) conducted a compliance evaluation inspection at Denton Scrap Metal Recycling, LLC (hereinafter, Facility) in Denton, Maryland. A representative from the Maryland Department of the Environment (MDE) also attended the inspection. Denton Scrap Metal Recycling, LLC is identified as the Permittee. The primary purpose of the inspection was to review the onsite Facility operations, to review the accuracy and reliability of the Facility's self-monitoring and reporting program, and to obtain information that will assist EPA in assessing the Facility's compliance with the requirements of the Permit.
The Facility is located at 24769 Meeting House Road, Denton, MD 21629, and is a scrap and waste recycling facility. The Facility employs a staff of 3-4 employees to process recyclables, operate and maintain the yard, and perform administrative functions. Staff from the environmental consulting firm, Grapewell Stormwater Consulting, Inc., provide general consulting guidance and sampling kits for quarterly visual monitoring. Grapewell staff also provide stormwater pollution prevention plan (SWPPP) updates and, in the future, will perform annual comprehensive site inspections. The Facility is responsible for all other Permit requirements. The Facility previously employed James Environmental Management, Inc. to provide SWPPP updates; perform employee training; conduct annual comprehensive site inspections; and conduct quarterly visual inspections for the Facility. Grapewell Stormwater Consulting, Inc. was hired approximately six months prior to the inspection to replace James Environmental Management, Inc.. The Facility sends quarterly visual monitoring samples to Chesapeake Labs Inc. for analysis. The Facility's onsite SWPPP map identifies one (1) outfall onsite (Outfall 001). Outfall 001 is located on the Facility's southern perimeter, south of a settling basin.
II. INSPECTION PROCESS
Inspection Opening Conference
The EPA Inspection Team arrived at the Facility at approximately 8:30 AM (EST) for the inspection. Mr.
Taylor Fontaine of PG Environmental displayed his Clean Water Act Inspector credential to Kelly Boyle of
Joseph Smith & Sons Inc. and Ben Wells of Grapewell Stormwater Consulting, Inc. (hereinafter, Facility
representatives). Joseph Smith & Sons Inc. owns the Facility and other scrap yards. The EPA Inspection
Team 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.
Table 1. Inspection Attendee List
Name
Affiliation
Telephone
Email
EPA Region III Contractors
Taylor Fontaine, Inspector
PG Environmental
(703) 956-1977
taylor.fontaine@pgenv.com
Kelly Davis, Inspector
Eastern Research Group, Inc.
(703) 633-1646
Facility Representatives
kelly.davis@erg.com
Kelly Boyle
Smith Industries
(410) 479-2110
KBoyle@jsmith-sons.com
Ben Wells, Environmental Consultant
Michele Burroughs, Regulatory and Compliance Engineer
Grapewell Stormwater Consulting, Inc.
(443) 340-7557
State or County Representatives
Maryland Department of the Environment
(410) 901-4043
ben@grapewellconsulting.com michele.burroughs@maryland.gov
Unique Project Identifier: 3E22WN030A
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Denton Scrap Metal Recycling, LLC (MDR003194) Compliance Evaluation Inspection Report
Weather and Precipitation Precipitation was not observed on the day of the inspection. Partly cloudy skies with a maximum temperature of approximately 41 degrees Fahrenheit were experienced on the day of 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.
Precipitation Preceding Inspection
Station Name
Date
Denton 5.8 WSW, MD US US1MDCL0010 Denton 5.8 WSW, MD US US1MDCL0010 Denton 5.8 WSW, MD US US1MDCL0010 Denton 5.8 WSW, MD US US1MDCL0010 Denton 5.8 WSW, MD US US1MDCL0010 Denton 5.8 WSW, MD US US1MDCL0010
2/11/2022 2/12/2022 2/13/2022 2/14/2022 2/15/2022 2/16/2022
Precipitation Amount (inches)1
0.00 0.00 0.00 0.04 Not reported Not reported
Facility Site Walk
As part of the process, the EPA Inspection Team visually observed Facility conditions in the presence of the Facility representatives. Areas viewed during the Facility walk include:
Office; Non-ferrous material and used battery storage garage; Truck scale; Outdoor material storage area; Envirorack; Fluids storage area; Baler; Retention area; and Outfall 001.
The Facility encompasses approximately 3.25 acres and contains an office building connected to a nonferrous material and used battery storage garage (refer to Appendix B, Photographs 1 and 2), a roadway and a truck scale (refer to Appendix B, Photograph 3), an outdoor material storage area (refer to Appendix B, Photographs 4 through 10), an Envirorack (refer to Appendix B, Photograph 11) in a covered fluids storage area (refer to Appendix B, Photographs 11 through 16), a retention area and Outfall 001 (refer to Appendix B, Photographs 17 through 24), and a baler (refer to Appendix B, Photographs 25 through 27). All stormwater onsite drains to the settling basin at the Facility's southern retention area located by the southern perimeter (refer to Appendix B, Photograph 17). Stormwater then is directed through an earthen channel that contains multiple filter socks and a rock check dam (refer to Appendix B, Photographs 18 through 22). Stormwater is then discharged from the Facility's outfall, Outfall 001 (refer to Appendix B, Photographs 23 and 24). The Facility does not connect to a municipal separate storm sewer system. The Facility is bordered by Schultz & Sons Salvage Inc. to the west and east. The two properties are not divided by a barrier.
The Facility receives non-ferrous and ferrous metals including "white goods," which include household items such as refrigerators and microwaves, and cars. The Facility accepts wrecked vehicles that are ten years or older. The Facility exports collected mercury switches every two years. Accepted vehicles are first weighed on a scale next to the non-ferrous material and used battery storage garage. Vehicles are then
1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/).
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Denton Scrap Metal Recycling, LLC (MDR003194) Compliance Evaluation Inspection Report
placed on the Envirorack (refer to Appendix B, Photograph 11), removed of batteries, and drained of liquids under a cover in the liquid storage area. Vehicles and other metals are collected and crushed using the onsite baler (refer to Appendix B, Photographs 25 through 27). Used oil from vehicles and oily water from the baler are collected in 550-gallon tanks and stored in the liquid storage area (refer to Appendix B, Photographs 11, 13, and 14). Diesel is collected in a 500-gallon double-walled tank and stored in the liquid storage area (refer to Appendix B, Photograph 12). Motor oil and hydraulic liquids are collected in 300gallon totes and stored in the liquid storage area (refer to Appendix B, Photographs 15 and 16). The crushed material then is transported to a facility in Capital Heights, MD for further processing. The Facility representatives stated that a spill kit is stored onsite.
Records Review
The EPA Inspection Team conducted a records review to evaluate the Facility's compliance with the Permit. Most of the records and reports required by the Permit were available for review prior to and after the inspection. The Facility's electronic discharge monitoring reports (eDMRs) were provided electronically and reviewed offsite prior to the onsite inspection. The following were reviewed:
eDMR data during the period from March 2017 (First Quarter following Permit effective date through December 2021);
The SWPPP, dated June 24, 2016 and revised SWPPP dated February 15, 2022 (refer to Appendix C, Exhibits 1 through 5) (reviewed onsite);
Routine Facility Inspection records from December 2017 through December 2021 (reviewed onsite);
Comprehensive Site Compliance Evaluation records for 2017, 2018, 2019, 2020, and 2021 (reviewed onsite);
Facility Staff Annual Training records for 2017, 2018, 2019, 2020, 2021, and 2022 (reviewed onsite); and
Quarterly Visual Inspection records for December 2017 through December 2021 (reviewed onsite).
Summary of Observations
The following section summarizes the EPA Inspection Team'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.
SWPPP Requirements
Permit Part III.C.2.c states that the site map must provide the following: i. "size of the property in acres;
ii. the location and extent of significant structures and impervious surfaces
iii. the location and extent for planned restoration of impervious surfaces, or nutrient reduction
measures;
iv. directions of stormwater flow (use arrows);
v. locations of all existing structural control measures or BMPs;
vi. locations of all receiving waters in the immediate vicinity of your facility, indicating if any of the
waters are impaired and if so, whether the waters have TMDLs established for them;
vii. locations of all stormwater conveyances including ditches, pipes, and swales;
viii. locations of potential pollutant sources identified under Part III.C.3;
ix. locations where significant spills or leaks identified under Part III.C.3 have occurred;
x. locations of all stormwater monitoring points;
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xi. locations of all stormwater inlets and outfalls, with a unique identification code for each outfall (e.g., Outfall No. 1, No. 2, etc.) indicating if you are treating one or more outfalls as substantially identical, and an approximate outline of areas draining to each outfall;
xii. municipal separate storm sewer systems, where your stormwater discharges to them; xiii. locations and descriptions of all non-stormwater discharges identified under Part I.E.3; xiv. locations of the following activities where such activities are exposed to precipitation:
fueling stations; vehicle and equipment maintenance and/or cleaning areas; loading/unloading areas; locations used for treatment, storage, or disposal of wastes; liquid storage tanks; processing and storage areas;"
The Facility SWPPP map did not include all Permit-required elements. Specifically, the onsite SWPPP map (refer to Appendix C, Exhibit 1) depicted the settling basin in a location that did not match the location observed onsite. The SWPPP map also did not include locations of existing structural control measures such as filter socks or the rock check dam, and did not include locations of stormwater conveyances such as the earthen channel or the pipes that discharge to Outfall 001 (refer to Appendix B, Photographs 17 through 24). The Facility representatives provided an updated copy of the SWPPP on February 18, 2022 (refer to Appendix C, Exhibit 2). The updated SWPPP map did not include the location of the settling basin, filter socks, rock check dam, earthen channel, or pipes that discharge to Outfall 001.
Part III.C.7 states that, "You must modify your SWPPP whenever necessary to address any of the triggering conditions for corrective action in Part IV and to ensure that they do not reoccur, or to reflect changes implemented when a review following the triggering conditions in Part IV.B indicates that changes to your control measures are necessary to meet the effluent limits in this permit. Changes to your SWPPP document must be made in accordance with the corrective action deadlines in Parts IV.C and IV.D, and must be signed and dated in accordance with Part II.C."
A Facility representative did not sign and date modifications to the SWPPP. The updated SWPPP had a space for logging modifications in Appendix 8 - SWPPP Modifications (refer to Appendix C, Exhibit 2). Appendix 8 did not document any modifications. The EPA Inspection Team observed during the inspection that the SWPPP was modified in 2019, as observed on Management Review and Certification (refer to Appendix C, Exhibit 3), and 2021, as observed in the SWPPP Certification (refer to Appendix C, Exhibit 4). The Facility also provided the EPA Inspection Team with an updated SWPPP immediately after the inspection; however, these changes were not documented.
Benchmark Exceedances
Part V.B of the Permit requires the Permittee to "monitor for any benchmark parameters specified for the industrial sector(s), both primary industrial activity and any co-located industrial activities, applicable to your discharge." The schedule requires the Permittee to "conduct benchmark monitoring quarterly for four (4) full quarters, starting the first full monitoring period (found in Part V.C.7) that occurs, six (6) months after registering under this permit." For data not exceeding benchmarks, after "collection of 4 quarterly samples, if the average of the 4 monitoring values for any parameter does not exceed the benchmark, you have fulfilled your monitoring requirements for that parameter for the permit term." For data exceeding benchmarks after collection of 4 quarters of samples, "if the average of the 4 monitoring values for any
Unique Project Identifier: 3E22WN030A
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parameter exceeds the benchmark, you must review the selection, design, installation, and implementation
of selected control measures to determine if modifications are necessary to meet the effluent limits in this
permit."
Permit Part IV states that, "If any of the following conditions occur, you must review and revise the
selection, design, installation, and implementation of your control measures to ensure that the condition is
eliminated and will not be repeated in the future...
2.
a discharge violates a numeric effluent limit...
5.
you find in your routine facility inspection (Part V.A.1), quarterly visual assessment (Part
V.A.3), or comprehensive site inspection (Part V.A.2) that your control measures are not
being properly operated and maintained."
Part IV.B defines a mathematically certain exceedance as a, "sum of quarterly sample results to date is
more than 4 times the benchmark level." These exceedances also require that the permittee, "review the
selection, design, installation, and implementation of your control measures to determine if modifications
are necessary to meet the effluent limits in this permit."
Based on a review of the Facility's Integrated Compliance Information System (ICIS) Data Report (refer to Appendix C, Exhibit 5), the EPA Inspection Team observed the Facility had 29 instances from March 2018 through December 2021 when the average of 4 consecutive parameter monitoring values exceeded benchmark concentrations. These average exceedances occur 5 times for total recoverable iron; 9 times for copper; 6 times for zinc; 6 times for aluminum; and 3 times for chemical oxygen demand (COD). Additionally, the data shows 2 mathematically certain exceedances (where a single sample concentration is greater than four times the limit) of zinc. All monitoring values for TSS, total recoverable iron, copper, lead, zinc, aluminum, and COD are summarized in Tables 2 through 8 below. All benchmark exceedances are highlighted in red.
Table 2. Outfall 001 Final Benchmark Exceedances for Total Suspended Solids (TSS) (March 2017 through December 2021)
Monitoring Period End
Date
03/31/2017
Parameter Solids, total suspended
Limit Value
100
Concentration Not reported
Four Quarter Concentration Averages (Benchmark Exceedances
Are Highlighted Red)
N/A
06/30/2017 Solids, total suspended 100 Not reported
N/A
09/30/2017 Solids, total suspended 100
60
N/A
12/31/2017 Solids, total suspended 100
13
18
03/31/2018 Solids, total suspended 100
<3.2
-*
06/30/2018 Solids, total suspended 100
<3.2
-*
09/30/2018 Solids, total suspended 100
32
-*
12/31/2018 Solids, total suspended 100
<5
-*
03/31/2019 Solids, total suspended 100
<5
-*
06/30/2019 Solids, total suspended 100
20
-*
09/30/2019 Solids, total suspended 100
6
-*
12/31/2019 Solids, total suspended 100
110
-*
03/31/2020 Solids, total suspended 100
9
36
06/30/2020 Solids, total suspended 100
10
34
09/30/2020 Solids, total suspended 100
<2.5
-*
12/31/2020 Solids, total suspended 100
17
-*
03/31/2021 Solids, total suspended 100
35
-*
06/30/2021 Solids, total suspended 100
6
-*
09/30/2021 Solids, total suspended 100
4
16
12/31/2021 Solids, total suspended 100
7
13
* = Value could not be determined because a concentration was too small to be determined accurately.
% of the Limit (Red if it
Exceeds 4X the Benchmark) 60 13 32 20 6 110 9 10 17 35 6 4 7
Concentration Units
mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L
Unique Project Identifier: 3E22WN030A
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Table 3. Outfall 001 Final Benchmark Exceedances for Total Recoverable Iron (March 2017 through December 2021)
Monitoring Period End
Date
03/31/2017
Parameter Iron, total recoverable
Limit Concentration Value 1.00 Not reported
Four Quarter Concentration Averages (Benchmark Exceedances
Are Highlighted Red)
N/A
% of the Limit (Red if it
Exceeds 4X the Benchmark)
-
Concentration Units
mg/L
06/30/2017 Iron, total recoverable 1.00 Not reported
N/A
-
mg/L
09/30/2017 Iron, total recoverable 1.00
2.10
N/A
210
mg/L
12/31/2017 Iron, total recoverable 1.00
0.44
0.64
44
mg/L
03/31/2018 Iron, total recoverable 1.00
0.19
0.68
19
mg/L
06/30/2018 Iron, total recoverable 1.00
0.31
0.76
31
mg/L
09/30/2018 Iron, total recoverable 1.00
1.50
0.61
150
mg/L
12/31/2018 Iron, total recoverable 1.00
0.77
0.69
77
mg/L
03/31/2019 Iron, total recoverable 1.00
0.23
0.70
23
mg/L
06/30/2019 Iron, total recoverable 1.00
1.20
0.93
120
mg/L
09/30/2019 Iron, total recoverable 1.00
1.40
0.90
140
mg/L
12/31/2019 Iron, total recoverable 1.00
2.80
1.41
280
mg/L
03/31/2020 Iron, total recoverable 1.00
0.65
1.51
65
mg/L
06/30/2020 Iron, total recoverable 1.00
1.50
1.59
150
mg/L
09/30/2020 Iron, total recoverable 1.00
0.38
1.33
38
mg/L
12/31/2020 Iron, total recoverable 1.00
0.57
0.78
57
mg/L
03/31/2021 Iron, total recoverable 1.00
1.70
1.04
170
mg/L
06/30/2021 Iron, total recoverable 1.00
0.97
0.91
97
mg/L
09/30/2021 Iron, total recoverable 1.00
0.07
0.83
7
mg/L
12/31/2021 Iron, total recoverable 1.00
0.32
0.76
32
mg/L
* = Value could not be determined because a concentration was too small to be determined accurately.
Table 4. Outfall 001 Final Benchmark Exceedances for Copper (March 2017 through December 2021)
Monitoring Period End
Date
03/31/2017
Parameter Copper, total [as Cu]
Limit Value
0.014
Concentration Not reported
Four Quarter Concentration Averages (Benchmark Exceedances
Are Highlighted Red)
N/A
% of the Limit (Red if it
Exceeds 4X the Benchmark)
-
Concentration Units
mg/L
06/30/2017 Copper, total [as Cu]
0.014 Not reported
N/A
-
mg/L
09/30/2017 Copper, total [as Cu]
0.014
0.021
N/A
150
mg/L
12/31/2017 Copper, total [as Cu]
0.014
0.017
0.0095
121
mg/L
03/31/2018 Copper, total [as Cu]
0.014
0.003
0.010
24
mg/L
06/30/2018 Copper, total [as Cu]
0.014
0.010
0.013
71
mg/L
09/30/2018 Copper, total [as Cu]
0.014
0.024
0.014
171
mg/L
12/31/2018 Copper, total [as Cu]
0.014
0.022
0.015
157
mg/L
03/31/2019 Copper, total [as Cu]
0.014
0.010
0.016
71
mg/L
06/30/2019 Copper, total [as Cu]
0.014
0.035
0.023
250
mg/L
09/30/2019 Copper, total [as Cu]
0.014
0.020
0.022
143
mg/L
12/31/2019 Copper, total [as Cu]
0.014
0.010
0.019
71
mg/L
03/31/2020 Copper, total [as Cu]
0.014
<0.008
-*
-
mg/L
06/30/2020 Copper, total [as Cu]
0.014
0.016
-*
114
mg/L
Unique Project Identifier: 3E22WN030A
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Monitoring Period End
Date
09/30/2020
Parameter Copper, total [as Cu]
Limit Value
0.014
Concentration 0.010
Four Quarter Concentration Averages (Benchmark Exceedances
Are Highlighted Red)
-*
12/31/2020 Copper, total [as Cu]
0.014
0.024
-*
03/31/2021 Copper, total [as Cu]
0.014
0.056
0.027
06/30/2021 Copper, total [as Cu]
0.014
0.028
0.030
09/30/2021 Copper, total [as Cu]
0.014
0.048
0.039
12/31/2021 Copper, total [as Cu]
0.014
0.066
0.050
1 The benchmark value is hardness dependent. * = Value could not be determined because a concentration was too small to be determined accurately.
% of the Limit (Red if it
Exceeds 4X the Benchmark) 71
171
400
200
343
474
Concentration Units
mg/L mg/L mg/L mg/L mg/L mg/L
Table 5. Outfall 001 Final Benchmark Exceedances for Lead (March 2017 through December 2021)
Monitoring Period End
Date
03/31/2017
Parameter Lead, total [as Pb]
Limit Value
0.082
Concentration Not reported
Four Quarter Concentration Averages (Benchmark Exceedances
Are Highlighted Red)
N/A
% of the Limit (Red if it Exceeds
4X the Benchmark)
-
Concentration Units
mg/L
06/30/2017 Lead, total [as Pb] 0.082 Not reported
N/A
-
mg/L
09/30/2017 Lead, total [as Pb] 0.082
0.0062
N/A
8
mg/L
12/31/2017 Lead, total [as Pb] 0.082
0.0029
0.002275
4
mg/L
03/31/2018 Lead, total [as Pb] 0.082
0.0025
0.0029
3
mg/L
06/30/2018 Lead, total [as Pb] 0.082
0.0035
0.003775
4
mg/L
09/30/2018 Lead, total [as Pb] 0.082
0.0060
0.003725
7
mg/L
12/31/2018 Lead, total [as Pb] 0.082
<0.002
-*
-
mg/L
03/31/2019 Lead, total [as Pb] 0.082
<0.002
-*
-
mg/L
06/30/2019 Lead, total [as Pb] 0.082
0.0033
-*
4
mg/L
09/30/2019 Lead, total [as Pb] 0.082
<0.002
-*
-
mg/L
12/31/2019 Lead, total [as Pb] 0.082
0.0075
-*
9
mg/L
03/31/2020 Lead, total [as Pb] 0.082
0.0031
-*
4
mg/L
06/30/2020 Lead, total [as Pb] 0.082
0.0020
-*
2
mg/L
09/30/2020 Lead, total [as Pb] 0.082
0.0059
0.004625
7
mg/L
12/31/2020 Lead, total [as Pb] 0.082
0.0120
0.00575
15
mg/L
03/31/2021 Lead, total [as Pb] 0.082
0.0340
0.013475
41
mg/L
06/30/2021 Lead, total [as Pb] 0.082
0.0042
0.014025
5
mg/L
09/30/2021 Lead, total [as Pb] 0.082
0.0044
0.01365
5
mg/L
12/31/2021 Lead, total [as Pb] 0.082
0.0044
0.01175
5
mg/L
* = Value could not be determined because a concentration was too small to be determined accurately.
Table 6. Outfall 001 Final Benchmark Exceedances for Zinc (March 2017 through December 2021)
Monitoring Period End
Date
03/31/2017
Parameter Zinc, total [as Zn]
Limit Value
0.12
Concentration Not reported
Four Quarter Concentration Averages (Benchmark Exceedances
Are Highlighted Red)
N/A
% of the Limit (Red if it Exceeds
4X the Benchmark)
-
Concentration Units
mg/L
06/30/2017 Zinc, total [as Zn]
0.12
Not reported
N/A
-
mg/L
09/30/2017 Zinc, total [as Zn]
0.12
0.08
N/A
68
mg/L
12/31/2017 Zinc, total [as Zn]
0.12
0.09
0.04225
73
mg/L
03/31/2018 Zinc, total [as Zn]
0.12
0.09
0.064
73
mg/L
06/30/2018 Zinc, total [as Zn]
0.12
0.06
0.07925
51
mg/L
Unique Project Identifier: 3E22WN030A
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Monitoring Period End
Date
09/30/2018
Parameter Zinc, total [as Zn]
Limit Value
0.12
Concentration 0.08
Four Quarter Concentration Averages (Benchmark Exceedances
Are Highlighted Red)
0.07925
% of the Limit (Red if it Exceeds
4X the Benchmark)
68
12/31/2018 Zinc, total [as Zn]
0.12
0.07
0.07375
55
03/31/2019 Zinc, total [as Zn]
0.12
0.06
0.06575
46
06/30/2019 Zinc, total [as Zn]
0.12
0.05
0.064
45
09/30/2019 Zinc, total [as Zn]
0.12
0.05
0.0555
39
12/31/2019 Zinc, total [as Zn]
0.12
0.12
0.069
100
03/31/2020 Zinc, total [as Zn]
0.12
0.10
0.08025
83
06/30/2020 Zinc, total [as Zn]
0.12
0.07
0.08375
57
09/30/2020 Zinc, total [as Zn]
0.12
0.27
0.1395
225
12/31/2020 Zinc, total [as Zn]
0.12
0.54
0.2445
450
03/31/2021 Zinc, total [as Zn]
0.12
0.70
0.3945
583
06/30/2021 Zinc, total [as Zn]
0.12
0.09
0.399
72
09/30/2021 Zinc, total [as Zn]
0.12
0.13
0.364
108
12/31/2021 Zinc, total [as Zn]
0.12
0.13
0.2613
108
1 The benchmark value is hardness dependent. * = Value could not be determined because a concentration was too small to be determined accurately.
Concentration Units
mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L
Table 7. Outfall 001 Final Benchmark Exceedances for Total Recoverable Aluminum (March 2017 through December 2021)
Monitoring Period End
Date 03/31/2017 06/30/2017 09/30/2017 12/31/2017 03/31/2018 06/30/2018 09/30/2018 12/31/2018 03/31/2019 06/30/2019 09/30/2019 12/31/2019 03/31/2020 06/30/2020 09/30/2020 12/31/2020 03/31/2021
Parameter
Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable
Limit Value
0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75
Concentration
Not reported Not reported
2.30 0.22 0.08 0.14 0.90 1.30 0.30 1.30 0.22 2.10 0.58 0.27 0.08 0.27 0.96
Four Quarter Concentration Averages (Benchmark Exceedances
Are Highlighted Red) N/A N/A N/A 0.63 0.65 0.685
0.335 0.605 0.66 0.95 0.78 0.98 1.05 0.7925 0.75775 0.30025 0.39525
% of the Limit (Red if it Exceeds 4X the Benchmark)
307 29 11 19 120 173 40 173 29 280 77 36 11 36 128
Concentration Units
mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L
Unique Project Identifier: 3E22WN030A
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Denton Scrap Metal Recycling, LLC (MDR003194) Compliance Evaluation Inspection Report
Monitoring Period End
Date
Parameter
Limit Value
Concentration
Four Quarter Concentration Averages (Benchmark Exceedances
Are Highlighted Red)
% of the Limit (Red if it Exceeds 4X the Benchmark)
06/30/2021 Aluminum, total
0.75
<0.05
-*
-
recoverable
09/30/2021 Aluminum, total
0.75
<0.05
-*
-
recoverable
12/31/2021 Aluminum, total
0.75
0.13
-*
17
recoverable
* = Value could not be determined because a concentration was too small to be determined accurately.
Concentration Units
mg/L mg/L mg/L
Table 8. Outfall 001 Final Benchmark Exceedances for Chemical Oxygen Demand (March 2017
through December 2021)
Monitoring Period End
Date
Parameter
Limit Value
Concentration
Four Quarter Concentration Averages (Benchmark Exceedances
Are Highlighted Red)
% of the Limit (Red if it Exceeds 4X the Benchmark)
03/31/2017 Chemical Oxygen
120
Not reported
N/A
-
Demand [COD]
06/30/2017 Chemical Oxygen
120
Not reported
N/A
-
Demand [COD]
09/30/2017 Chemical Oxygen
120
45
N/A
38
Demand [COD]
12/31/2017 Chemical Oxygen
120
21
17
18
Demand [COD]
03/31/2018 Chemical Oxygen
120
7
18
6
Demand [COD]
06/30/2018 Chemical Oxygen
120
8
20
7
Demand [COD]
09/30/2018 Chemical Oxygen
120
37
18
31
Demand [COD]
12/31/2018 Chemical Oxygen
120
43
24
36
Demand [COD]
03/31/2019 Chemical Oxygen
120
16
26
13
Demand [COD]
06/30/2019 Chemical Oxygen
120
62
40
52
Demand [COD]
09/30/2019 Chemical Oxygen
120
40
40
33
Demand [COD]
12/31/2019 Chemical Oxygen
120
66
46
55
Demand [COD]
03/31/2020 Chemical Oxygen
120
<6.4
-*
-
Demand [COD]
06/30/2020 Chemical Oxygen
120
140
-*
117
Demand [COD]
09/30/2020 Chemical Oxygen
120
28
-*
23
Demand [COD]
12/31/2020 Chemical Oxygen
120
213
-*
178
Demand [COD]
03/31/2021 Chemical Oxygen
120
157
135
131
Demand [COD]
06/30/2021 Chemical Oxygen
120
63
115
53
Demand [COD]
09/30/2021 Chemical Oxygen
120
74
127
62
Demand [COD]
12/31/2021 Chemical Oxygen
120
351
161
293
Demand [COD]
* = Value could not be determined because a concentration was too small to be determined accurately.
Concentration Units
mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L
The EPA Inspection Team observed that the Facility's onsite SWPPP documented recommended corrective actions to prevent further benchmark exceedances but did not document whether corrective actions were implemented (refer to Appendix C, Exhibit 6).
Unique Project Identifier: 3E22WN030A
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Denton Scrap Metal Recycling, LLC (MDR003194) Compliance Evaluation Inspection Report
Permit Part 4.c states that, "If you are required to do benchmark monitoring for specific pollutants you must report the quarterly measurements no later than 28 days following the Monitoring Period (Part V. C.7), and according to the other Monitoring Procedures (Part V.C)."
The Facility did not submit Quarter 1 or Quarter 2, 2017, benchmark monitoring quarterly measurements as reported in the ICIS Data Report and Detailed Facility Report (refer to Appendix C, Exhibits 5 and 7). The Facility submitted the Quarter 3 and Quarter 4, 2017 benchmark monitoring quarterly measurements 286 days late and 193 days late respectively, as summarized in Table 9 below. Quarter 3, 2017 measurements were due on October 28, 2017. Quarter 4, 2017 measurements were due on January 28, 2018.
NPDES ID
MDR003194
MDR003194
MDR003194 MDR003194 MDR003194 MDR003194 MDR003194 MDR003194
MDR003194
MDR003194 MDR003194 MDR003194 MDR003194 MDR003194 MDR003194
MDR003194
MDR003194 MDR003194 MDR003194 MDR003194 MDR003194 MDR003194
MDR003194
MDR003194 MDR003194 MDR003194 MDR003194 MDR003194
Table 9. Outfall 001 Late or Unsubmitted Reports
Monitoring Period End
Date
Parameter
DMR Received
Date
03/31/2017
03/31/2017
03/31/2017 03/31/2017 03/31/2017 03/31/2017 03/31/2017 06/30/2017
06/30/2017
06/30/2017 06/30/2017 06/30/2017 06/30/2017 06/30/2017 09/30/2017
09/30/2017
09/30/2017 09/30/2017 09/30/2017 09/30/2017 09/30/2017 12/31/2017
12/31/2017
12/31/2017 12/31/2017 12/31/2017 12/31/2017 12/31/2017
Aluminum, total recoverable Chemical Oxygen Demand [COD] Copper, total [as Cu] Iron, total recoverable Lead, total [as Pb] Solids, total suspended Zinc, total [as Zn] Aluminum, total recoverable Chemical Oxygen Demand [COD] Copper, total [as Cu] Iron, total recoverable Lead, total [as Pb] Solids, total suspended Zinc, total [as Zn] Aluminum, total recoverable Chemical Oxygen Demand [COD] Copper, total [as Cu] Iron, total recoverable Lead, total [as Pb] Solids, total suspended Zinc, total [as Zn] Aluminum, total recoverable Chemical Oxygen Demand [COD] Copper, total [as Cu] Iron, total recoverable Lead, total [as Pb] Solids, total suspended Zinc, total [as Zn]
Not received
Not received
Not received Not received Not received Not received Not received Not received
Not received
Not received Not received Not received Not received Not received
8/10/2018
8/10/2018
8/10/2018 8/10/2018 8/10/2018 8/10/2018 8/10/2018 8/10/2018
8/10/2018
8/10/2018 8/10/2018 8/10/2018 8/10/2018 8/10/2018
Number of Days
Late N/A
N/A
N/A N/A N/A N/A N/A N/A
N/A
N/A N/A N/A N/A N/A 286
286
286 286 286 286 286 193
193
193 193 193 193 193
Proper Operation and Maintenance
Part III.B.1.b.ii states that, "You must keep clean all exposed areas that are potential sources of pollutants, using such measures as sweeping at regular intervals, keeping materials orderly and labeled, and storing materials in appropriate containers. A good practice for ensuring housekeeping activities are performed at regular intervals would be keeping a schedule for routine grounds maintenance and cleanup."
The EPA Inspection Team made the following good housekeeping observations at the Facility:
Unique Project Identifier: 3E22WN030A
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Denton Scrap Metal Recycling, LLC (MDR003194) Compliance Evaluation Inspection Report
1. Staining and debris was observed by piles of recyclables in the material storage area, underneath a 300-gallon tote on the pavement and on the shipping container, and north of the baler (refer to Appendix B, Photographs 5, 16, 27).
2. Sediment was observed in the earthen channel that leads from the settling basin to Outfall 001 (refer to Appendix B, Photographs 19 through 22).
Closing Conference
After the Facility walk, the EPA Inspection Team met with the Facility representatives for a closing conference and shared their preliminary observations. The EPA Inspection Team 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 Inspection Team and EPA 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 after the additional review of materials following the inspection.
The inspection concluded at approximately 11:15 AM (EST).
Unique Project Identifier: 3E22WN030A
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Inspection Date: February 16, 2022
