Document Lp3db3yYdoDdMoj1ovXL7QvxQ

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 03/26/2026 Water CWA, NPDES, Storm Water Industrial GP Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: The Yaffe Companies, Inc. Rogers Iron and Metal Corporation (RIMCO) 721 N Arkansas Street Rogers, Arkansas 72756 P.O. Box 1806 Rogers, Arkansas 72756 Benton County 479-636-2666 Matt McNally General Manager mmcnally@yaffeco.net FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110011449110 ARR00B814 N/A 423930 and 423510 5093 and 5051 Personnel participating in inspection: Paul Juarez EPA Region 6/ ECD-WA Kerri McCabe EPA Region 6/ ECD-WA William Cody Arkansas Division of Environmental Quality (ADEQ) Matt McNally RIMCO Kyley Girty The Yaffe Companies, Inc. Wesley Glass RIMCO Inspector Inspector Inspector II General Manager Corporate Environmental Manager Assistant Manger EPA Lead Inspector Signature/Date PAUL JUAREZ Date: 2026.04.22 13:40:06 -05'00' Digitally signed by PAUL JUAREZ Paul Juarez Date Supervisor Signature/Date ANTHONY LOSTON Anthony Loston Digitally signed by ANTHONY LOSTON Date: 2026.04.23 07:03:49 -05'00' Date 6ENFORM-019-R9 (02/27/2025) 1 The Yaffe Companies, Inc. / Rogers Iron and Metal Corporation (RIMCO) Inspection Date 03/26/2026 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Paul Juarez and Kerri McCabe and ADEQ inspector William Cody arrived at Rogers Iron and Metal Corporation (RIMCO) at 10:03am on 03/26/2026, for an announced inspection. We met Matt McNally (General Manager of RIMCO), Kyley Girty (Corporate Environmental Manager of Yaffe), and Wesley Glass (Assistant Manager of RIMCO) at the opening conference. Inspectors presented their credentials to Mr. McNally, Mr. Girty, and Mr. Glass and informed them that this was an EPA inspection to determine compliance with the facility's Industrial Stormwater General Permit (IGP; ARR000000) coverage under the National Pollutant Discharge Elimination Program (NPDES). The scope of the inspection is a full compliance evaluation (FCE). FACILITY DESCRIPTION EPA conducted an inspection of RIMCO, whose parent company is Yaffe Companies, Inc. RIMCO is a scrap metal sorting and recycling facility whose grounds are bisected by North Arkansas Street in Rogers, Benton County, Arkansas. RIMCO's NAICS codes are 423930 (Recyclable Material Merchant Wholesalers) and 423510 (Metal Service Centers and Other Metal Merchant Wholesalers). The facility's SIC codes are 5093 (Scrap and Waste Materials) and 5051 (Metals Service Centers and Offices). The facility's Industrial Sector is N1 - Scrap Recycling and Waste Recycling Facilities except Source-Seperated Recycling. The western section of the facility retains Outfall 001 while the eastern section retains Outfall 002 (Appendix 1; Photo 5). The scrap metal piles were organized into large piles. The landscape gradient was engineered to lead towards the two (2) outfalls. Section II - OBSERVATIONS Recordkeeping Review (January 1, 2023- Present) Five (5) of twelve (12) facility self-inspection reports were missing from the previous three years of quarterly inspection. Facility representatives informed the inspectors that there is an electronic copy of these missing reports that would later be emailed to the inspector. The email with the five (5) inspection reports was received by EPA on 03/31/2026 at 11:16 am. The most recent seven (7) self-inspection reports were present and accounted for within the records. The previous three (3) years of Storm Water Annual Reports (SWAR) were missing. Facility representatives informed the inspectors that there is an electronic copy of these missing reports that would later be emailed to the inspector. The email with the three (3) SWARs was received by EPA on 03/31/2026 at 11:16 am. Inspectors observed that 2025 sampling data was missing. Inspectors were informed that there was a change in leadership where communication to sample for 2025 was not received by the succeeding management. Therefore, sampling for 2025 did not take place. Sampling data for 2023 and 2024 were present and accounted for. 2 The Yaffe Companies, Inc. / Rogers Iron and Metal Corporation (RIMCO) Inspection Date 03/26/2026 Inspectors observed that a Corrective Action Plan (CAP) was triggered 11/18/2024 for an exceedance of Total Aluminum (Al). Proper protocol according to the IGP was followed. Inspectors observed missing laboratory data from 2023 samples for Outfalls 001 and 002. Facility representatives informed the inspectors that there is an electronic copy of the missing data that would later be emailed to the inspector. The email with the 2023 data was received by EPA on 03/31/2026 at 11:16 am. Facility Tour Fugitive solid waste was observed outside containment on the southeastern corner of the facility (Appendix 1; Photo 1). Outfall 002 appeared to be well-maintained with added Best Management Practices (BMP), including three (3) metal absorbent bags and rip-rap (Appendix 1; Photo 2). Outfall 001had fugitive solid waste present at the time of the inspection. Three (3) absorbent booms were staked into the ground and utilized as additional BMPs (Appendix 3; Photo 3) Additional fugitive solid waste was observed outside the facility's boundary near Outfall 001 (Appendix 1; Photo 4). Good housekeeping practices were recommended during the inspection. Section III - AREAS OF CONCERN According to Part 2.2 Parameter Benchmark Monitoring of the ADEQ IGP, eight (8) pollutants assigned to RIMCO's Industrial Sector identifier (N1) must be monitored with a frequency of once/year to determine the overall effectiveness of control measures. In 2025, the pollutants were not sampled/monitored. Closing Conference EPA Region 6 inspectors Paul Juarez and Kerri McCabe and ADEQ inspector William Cody conducted a closing conference at The Yaffe Companies, Inc. / Rogers Iron and Metal Corporation (RIMCO) at 12:15 pm on 03/26/2026 for the inspection. During the closing conference, the inspectors reviewed the one (1) Area of Concern (AOC) noted during the inspection, fielded questions from facility personnel, and provided information about the next steps in the inspection process. Section IV - FOLLOW UP The following information was received by EPA via email on 03/31/2026 after exiting the Facility on 03/26/2026: Five (5) missing self-inspection reports. Three (3) missing SWARs from 2023, 2024, and 2025. Missing laboratory data from 2023. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 5 photos taken on 3/26/2026 3 The Yaffe Companies, Inc. / Rogers Iron and Metal Corporation (RIMCO) Inspection Date(s) 03/26/2026 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 1 Facility/Location: Rogers Iron and Metal Corporation RIMCO City: Rogers County: Benton County State: AR Direction: N Filename: Camera Model: Photographer: Latitude: Description: R0010279.JPG Photo Date: 03/26/2026 Time: 11:31:18 am RICOH WG-6 Paul Juarez Witness Name: Kerri McCabe 36 20' 23.382" N Longitude: 94 6' 46.644" W Fugitive solid waste was observed outside containment along the southeastern corner of the facility grounds. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 2 Facility/Location: Rogers Iron and Metal Corporation RIMCO City: Rogers County: Benton County State: AR Direction: W Filename: Camera Model: Photographer: Latitude: Description: R0010281.JPG Photo Date: 03/26/2026 Time: 11:37:01 am RICOH WG-6 Paul Juarez Witness Name: Kerri McCabe 36 20' 29.22" N Longitude: 94 6' 46.71" W Outfall 002 appeared well-maintained with three (3) green metal-absorbent bags and rip-rap. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 3 Facility/Location: Rogers Iron and Metal Corporation RIMCO City: Rogers County: Benton County State: AR Direction: S Filename: Camera Model: Photographer: Latitude: Description: R0010282.JPG Photo Date: 03/26/2026 Time: 11:49:08 am RICOH WG-6 Paul Juarez Witness Name: Kerri McCabe 36 20' 27.438" N Longitude: 94 6' 52.104" W Outfall 001. A light and absorbent boom was observed as an additional BMP. Solid waste run-on from surrounding city streets was observed at or near Outfall 001. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 4 Facility/Location: Rogers Iron and Metal Corporation RIMCO City: Rogers County: Benton County State: AR Direction: N Filename: Camera Model: Photographer: Latitude: Description: R0010283.JPG Photo Date: 03/26/2026 Time: 11:52:52 am RICOH WG-6 Paul Juarez Witness Name: 36 20' 27.372" N Longitude: Fugitive solid waste observed in proximity to Outfall 001. Kerri McCabe 94 6' 51.786" W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 5 Facility/Location: Rogers Iron and Metal Corporation RIMCO City: Rogers County: Benton County State: AR Direction: Filename: Camera Model: Photographer: Latitude: Description: RIMCOaerial3262 Photo Date: 03/26/2026 Time: 026.jpg RICOH WG-6 Google Witness Name: N/A N/A Longitude: N/A Aerial map of Rogers Iron and Metal Corporation. 10:53:21 am