Document GzdLLv31b5wmEmmvMqLqn9NgY

NPDES Inspection Report - Stormwater Industrial National Database Information Inspection Date: 7/27/2023 Entry/Exit Time: 8:00 am / 10:15 am Inspection Type: Industrial Stormwater NPDES ID Number: COUT00256 SIC Code: 3441 and 3446 Inspection ID: 202307_COUT00256 Lead Inspector and affiliation: Stephanie Meyers / EPA Region 8 Inspector and affiliation: Althea Wilson / EPA Region 8 Inspector and affiliation: Eric Philyaw / Colorado Department of Public Health and Environment Site/Facility Name and Location: Midwest Fabrication and Steel, LLC 1015 E Northern Avenue Pueblo, CO 81006 Permit Information Is the permit on site and available? Unpermitted Date Application Submitted: Unpermitted facility Latitude: 38.244325N facility Longitude: -104.600025W Receiving Water(s): Unnamed, unclassified ditch Acreage: approximately 14.3 acres thence to the Arkansas River Regulatory Inspector's source of information: Facility observations Areas Evaluated During Inspection Permit Self-Monitoring Program Records Compliance Schedule Pollution Prevention Stormwater Facility Site Review Laboratory No Exposure Effluent/Receiving Waters Operations and Maintenance Other: Flow Measurement Contact Information Facility Contacts: Primary lead and present during inspections Person/Company meeting definition of "Operator" Authorized Official(s) (Per NOI or SWPPP) Sludge Handling/Disposal Other: Name(s)/Title Rebekah Woods / Owner / Midwest Fabrication and Steel, LLC / Primary lead during the opening conference Darrell Woods / Owner Midwest Fabrication and Steel, LLC / Primary lead during the field inspection Midwest Fabrication and Steel, LLC N/A, since there is currently no permit for this facility NPDES Inspection Report - Stormwater Industrial Report Review and Signature Drafter Name Stephanie Meyers Reviewer Name Althea Wilson Supervisor Signature/Name EMILIO Digitally signed by EMILIO LLAMOZAS LLAMOZAS 17:51:01 -06'00' Date: 2023.09.12 Emilio Llamozas Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6938 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6026 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6407 Date 8/2/2023 Date 8/9/2023 Date 9/8/2023 Inspection Narrative and Site Description On July 27, 2023, U.S. Environmental Protection Agency (EPA) inspectors Stephanie Meyers and Althea Wilson along with Colorado Department of Public Health and Environment (CDPHE) inspector Eric Philyaw arrived at Midwest Fabrication and Steel, LLC (facility) at 8:00 am to conduct an inspection and evaluate the facility's need for industrial stormwater permit coverage. The EPA and CDPHE performed a joint inspection at this facility. The inspection was announced one week prior to the inspection, to coordinate logistics for the inspection and to ensure that appropriate personnel would be available. The EPA inspectors along with CDPHE met with Rebekah and Darrell Woods, Owners of Midwest Fabrication and Steel, LLC. EPA inspector, Stephanie Meyers, presented her credentials and had an opening conference to explain the purpose of the inspection. The inspectors began by going through a series of checklist questions with the facility representatives. Once complete, the inspectors proceeded to inspect the facility and asked questions to the facility representative to help the inspectors evaluate the need for industrial stormwater permit coverage. Throughout the inspection, the inspectors noted their observations in a checklist. Photographs taken during the inspection are included in the attached photo log. Midwest Fabrication and Steel, LLC is located at 1015 E Northern Avenue in Pueblo, Colorado. The facility was established in 1932, and on January 1, 2018, Rebekah and Darrell Woods took over the company and became the new owners. The facility has approximately 27 employees and provides various steel fabrication and finishing services. Facility representatives stated formed steel is purchased from mills and then fabricated into various products such as steel staircases, hand railings, structural beams, and more for contract jobs. Steel is not reheated at the facility, but several pieces of equipment are on site to cut, weld, roll, bend, drill, sand blast, and finish steel products. Finished products are then sold within the State of Colorado. NPDES Inspection Report - Stormwater Industrial Inspection Narrative and Site Description After the opening conference, inspectors then walked the facility and first observed the fabrication shop (photo 76), which is where steel is welded into various products such as those discussed above. There is a machine within the fabrication shop used to cut steel (photo 77). This machine utilizes soluble oil to cool the steel while it's being cut. Inspectors then walked through the warehouse building (photo 80), where they observed an oil spill (photo 78) near the Pacific Press shear machine, and the Cosen cutting saw (photo 79) which also utilizes soluble oil to cool steel while cutting. Facility representatives indicated these machines recycle the soluble oil to cool steel and rarely need to replenish it. Though when needed, soluble oil is available in the 55-gallon drum stored outside of the warehouse (photo 81). Inspectors then walked the northeast end of the facility, where pieces of steel are stored, and a stormwater drainage pathway was observed (photo 82). Next, inspectors looked at the sand blaster (photo 84). A calcium iron silicate abrasive material called Black Beauty (photo 88) is used in conjunction with high pressure air to clean the steel. Next to the sand blast area, there is an outdoor fueling tank (photo 85) that holds approximately 300 gallons of fuel for equipment. After looking at the east end of the property, inspectors proceeded to walk the northwest end of the property where they observed evidence of past stormwater flow (photo 86) towards the channel that borders the north end of the facility. Inspectors observed scrap steel stored outside in an uncovered dumpster (photo 87) and an open bag of the Black Beauty sand blasting material (photo 88). Inspectors also observed storage of welding gas outside of the fabrication building (photo 89), final product storage (photo 90), a low point along the northwest end of the property where stormwater has the potential to run off (photo 91), outdoor storage of empty drums (photo 92), and a Piranha Plasma table used to punch notches in steel (photo 93). After the inspection of the facility, the inspectors returned to the main office and held a closing conference with Rebekah and Darrell Woods where they discussed observations. After leaving the facility, inspectors walked the area just outside the northwest end of the facility and observed the drainage area that would receive runoff from the facility (photo 94), as well as a concrete conveyance directly west of that area (photo 95). Findings, Corrective Actions, and Recommendations Finding 1: Midwest Fabrication and Steel, LLC is an industrial facility under industrial stormwater Sector AA: Fabricated Metal Products Manufacturing Facilities, operating without industrial stormwater permit coverage. The facility's primary SIC codes are 3441 (Fabricated Structural Metal) and 3446 (Architectural and Ornamental Metal Work), both of which fall under industrial stormwater Sector AA: Fabricated Metal Products Manufacturing Facilities, requiring industrial stormwater permit coverage. The facility has outdoor industrial operations/activities as well as outdoor storage of materials. The inspectors observed several stormwater drainage pathways at the facility during the inspection, including: 1. A stormwater drainage pathway was observed on the northeast end of the facility (photo 82). 2. Evidence of past stormwater flow (photo 86) was observed towards the channel that borders the north end of the facility. 3. A low point was observed along the northwest end of the property where stormwater has the NPDES Inspection Report - Stormwater Industrial Findings, Corrective Actions, and Recommendations potential to run off (photo 91). The inspectors also observed the drainage area that would receive runoff from the facility (photo 94), as well as a concrete conveyance directly west of that area (photo 95). Regulatory Information: In 1987, the US Congress amended the Clean Water Act to expressly include stormwater discharges from industrial activities as requiring Clean Water Act controls. In 1990, EPA issued regulations that require specific industrial activities to obtain permits in order to discharge stormwater from their facilities under 40 C.F.R. 122.26. The Water Quality Control Division of the Colorado Department of Public Health and Environment has direction and authority to administer stormwater permitting in Colorado through the Colorado Water Quality Control Act, and its implementing regulations and permits. In accordance with the Colorado Water Quality Control Act and the Colorado Discharge Permit System (CDPS) Regulations 5-CCR 1002-61, CDPS discharge permit coverage is required for stormwater discharges from specific industrial activities to surface waters of the State. Facilities engaged in fabricated metal products manufacturing (SIC codes 3411-3499) as the primary industrial activity, are specifically required to obtain permit coverage or a No-Exposure Certification, for discharges of stormwater associated with industrial activities from the facility to surface waters of the State. A No-Exposure Certification may be obtained for facilities where all industrial materials and activities are protected by a storm-resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff. Due to the outdoor storage of materials as well as industrial activities being conducted outdoors, Midwest Fabrication and Steel, LLC does not currently qualify for the No-Exposure Certification. Corrective Action: Within 45 days of receipt of this report, submit a permit application for the CDPS General Permit for Stormwater Discharges Associated with Non-Extractive Industrial Activity (COR900000). See the attached Industrial Stormwater Permit Application Form. For assistance with the permit application or if you have any questions, please contact Mary Welch with CDPHE at mary.welch@state.co.us. Finding 2: Sand blasting activities were being conducted outside uncontained (photo 84). Inspectors observed sand blasting occuring just south of the drainage ditch that borders the north end of the facility, where the Black Beauty material as described above is used to clean steel. Recommendation: Ensure sand blasting material is contained and implement a routine sweeping schedule to clean up any Black Beauty material left on the ground. Finding 3: Black Beauty material is stored outdoors uncovered (photo 88). Inspectors observed the Black Beauty material used for sand blasting activities was stored in an open bag outdoors, where some of the material had spilled out. Recommendation: Clean up the spilled Black Beauty material and ensure the material is stored in a closed bag or container. NPDES Inspection Report - Stormwater Industrial Findings, Corrective Actions, and Recommendations Finding 4: Scrap steel is stored outdoors uncovered (photo 87). Inspectors observed scrap steel stored in a dumpster outdoors and uncovered near the north end of the facility. Recommendation: Cover the dumpster containing scrap steel and ensure any other dumpsters on site are also covered. Finding 5: Empty drums are stored outdoors (photo 92). Inspectors observed empty drums stored outdoors uncovered and without caps near the northwest corner of the facility. Recommendation: Dispose of the empty drums that are stored outdoors or bring empty drums inside under cover until they can be properly disposed of. Finding 6: There was an oil spill at the Pacific Press shear machine (photo 78). Inspectors observed an oil spill below the Pacific Press shear machine where absorbant material was used for the spill and still remained. 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