Document MJZKbRJMLEZ3DyExybgvaXzRy
RCRA COMPLIANCE EVALUATION INSPECTION REPORT
1) Inspector and Author of Report
Brooke York Environmental Engineer (404) 562-8025 york.brooke@epa.gov RCRA Enforcement Section EPA Region 4, AFC-10th Floor 61 Forsyth Street, SW Atlanta, Georgia 30303
2) Facility Information
TAV Holdings, Inc. 3311 Empire Boulevard SW Atlanta, Georgia 30354 EPA ID # GAD033537663
3) Primary Contact
Alex Camozzi, Director of Operations acamozzi@tavholdingsinc.net
4) Inspection Participants
Heli Tello, TAV, Fabrication Inventory Manager Alex Camozzi, TAV, Director of Operations Bob Brown, TAV Richard Posey, GAEPD Solid Waste Lina Yazbak, GAEPD Industrial Stormwater Jaliyl Collins, GAEPD Industrial Stormwater Faney Foster, GAEPD Hazardous Waste Jeffrey Hargrove, GAEPD District Office David Champagne, EPA, Region 4 Brooke York, EPA, Region 4
5) Date of Inspection
October 6, 2021
6) Applicable Regulations
Chapter 391-3-11 of the Georgia Hazardous Waste Management Act, adopts and incorporates by reference 40 CFR Parts 260 - 266, 268, 270, 273 & 279. The Georgia Hazardous Waste Management Act, O.C.G.A. 12-8-60, et seq. as amended (Act), Chapter 391-3-11 of the Georgia
RCRA CEI Report TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 1 of 41
October 6, 2021
Rules for Hazardous Waste Management (Rules), and those portions of 40 CFR Parts 260-270, 273, and 279 that are adopted into the Rules by reference).
As the State's authorized hazardous waste program operates in lieu of the federal RCRA program, the citations of those authorized provisions alleged herein will be to the authorized State program; however, for ease of reference, the federal citations will follow in brackets.
7) Purpose of Inspection
This unannounced compliance evaluation inspection (CEI) was conducted to evaluate the facility's compliance with applicable requirements of RCRA and corresponding the Georgia Environmental Protection Division (GAEPD) regulations.
8) Facility Description
TAV Holdings, LLC (TAV) operates a facility that includes at a minimum; offices and warehouse storage at 3311 Empire Boulevard SW; the northern portion of the parking lot at 3325 Empire Boulevard SW; the Keebler Complex (3 buildings, the White Building, the Process Building and the Keebler Building) at 111 Hollow Tree Lane; the Fabrication Shop at 3405 Empire Boulevard SW; and the laydown yard and stockpile at 3320 Empire Boulevard SW. The TAV facility receives automobile shredder residue (ASR), fluff generated from the shredding of automobiles, various stages of ASR in the recovery process, and previously land filled ASR, from multiple offsite sources. The material received would otherwise be disposed of in solid waste landfills that are appropriately designed, operated, and permitted to receive, store, and dispose of the solid wastes. At the time of the CEI, the only environmental permit TAV held was an industrial stormwater permit (GAIS14016)from GAEPD.
Inspectors were informed that the incoming material is received at no cost to TAV. The material TAV receives does not appear to be primarily made up of metal (more than 50%) and is not from the mining of ore or minerals. TAV has not notified of its intent to conduct treatability studies, or as a secondary materials handler. All the materials received for processing at TAV are solid wastes. The solid waste received is stored outside upon delivery. The solid waste is seperated based on particle size, and undergoes several screening and particle size reduction processes, in an effort to recover metals, primarily copper. As the solid waste is processed, material not high enough in recovered metals to be sold for recovery or smelting, is stored onsite, and recirculated through the process indefinitely. No disposal records of any of the wastes generated from the processing of the ASR have been provided.
9) Previous Inspection History
No prior RCRA inspection conducted at the facility.
10) Findings
The inspectors arrived at TAV at 9:05 AM EDT. Mr. Tello greeted the inspectors Richard Posey, GAEPD Solid Waste, Lina Yazbak, GAEPD Industrial Stormwater, Jaliyl Collins, GAEPD Industrial Stormwater, Faney Foster, GAEPD Hazardous Waste, Jeffrey Hargrove, GAEPD District Office, David
RCRA CEI Report TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 2 of 41
October 6, 2021
Champagne, EPA, Region 4, and Brooke York, EPA, Region 4, the inspectors showed their credentials and explained the purpose of the inspection and indicated the use of a camera to take pictures during the inspection. In addition, the EPA inspector discussed the company's ability, pursuant to 40 C.F.R. 2.203, to assert a business confidentiality claim for information submitted to the EPA. Mr. Tello insisted that the inspectors wait until the Director of Operations, Alex Camozzi, arrived to escort the inspectors through the facility. Once Mr. Camozzi arrived the inspectors confirmed the personal protection equipment required for the facility tour. The facility tour began at approximately 10:05 AM EDT.
The inspectors seperated into 2 groups. Mr. Camozzi escorted the hazardous waste inspectors.
Receiving The facility tour began in the receiving area. Several piles of ASR, solid waste, were observed in this area (Figures 48 and 49). The solid waste in this area is stored in open piles that are exposed to weather elements. The area had received rainfall in the days prior to the inspection and the solid waste piles were wet. Water contaminated with small particles was observed flowing from the south to the north where the outdoor processing, storage and Receiving Area are located. The water was observed to be pooling in the area immediately east of the Receiving Area (Figures 87 and 88). This area is known as the Jig Storage.
The inspectors reviewed the sources of the water and found that stormwater and operation process water, from the processing of the solid waste, was being swept out of the building. Due to holes in the roof and inadequate containment, both sources of water flow through the facility from south to north and collect in the asphalt area seen in Figures 87 and 88.
Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Ga. Comp. R. and Regs. 391-3-11-.07(1) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11].
The inspectors overserved numerous piles of solid waste in various stages of processing being stored outside. Some of these piles were of solid waste that had been reduced in particle size that would pass through the US Standard #200 sieve.
Processing The Main Processing Area is inside the buildings. The facility utilizes ball mills, particle size separation, eddy current, and vibration to separate metal particles from the material. Inspectors observed that much of the building was being used to store waste that had already been processed at least once. The waste consisted of very small particle sizes, as seen in Figures 60 and 61. The facility claimed that they were storing the already processed solid waste material with the intent of continuing to process it and claimed that it had recoverable concentrations of copper. The inspectors asked how long the material had been stored and how frequently the material was processed. The facility did not provide any information demonstrating how long and/or how frequently the solid waste was processed/stored.
Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Ga. Comp. R. and Regs. 391-3-11-.07(1) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure
RCRA CEI Report TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 3 of 41
October 6, 2021
wastes are properly managed according to applicable RCRA regulations articulated in Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11].
Wastewater Treatment/Clarifier The processes all include the use of water. The facility collects stormwater in several areas at the facility and uses it in the processes. Much of the process water is swept out the doors of the process building, where it accumulates in low lying areas and it is pumped to a tank where flocculant is added to aid in the precipitation of solids from the water. The solids are removed by a backhoe and placed back into the processing. From the clarifier the water is pumped to a large tank. At the time of the CEI, the clarifier and the tank were observed to be overflowing. The secondary containment in the Wastewater Treatment (WWT) Area could not be properly inspected due to the accumulation of sludge on the surface. Figures 71 - 79 illustrate the condition of this area at the time of the CEI.
Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Ga. Comp. R. and Regs. 391-3-11-.07(1) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11].
Storage The area to the northwest of the WWT Area is used to store this material. The facility claims that the solid waste material continues to contain recoverable metals. However, the inspectors observed that the material is being allowed to wash offsite with stormwater. The facility has failed to manage the material as a commodity.
Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Ga. Comp. R. and Regs. 391-3-11-.07(1) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11].
Outfall 003 The inspectors observed Outfall 003. The area had a large concrete tank/settling basin that appeared to be used to separate solids from liquids. At the time of the CEI the basin was completely full of sludge. Evidence of stormwater and sludge overflowing the basin and by-passing the Outfall can be seen in Figures 100-106.
Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Ga. Comp. R. and Regs. 391-3-11-.07(1) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11].
Lay-down Yard and Stored Waste The parcel across the street from 3311 Empire Boulevard was observed to be used for storing old equipment and process solid waste material. The waste is piled in a landfill-like fashion as seen in Figures 84 and 112.
RCRA CEI Report TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 4 of 41
October 6, 2021
Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Ga. Comp. R. and Regs. 391-3-11-.07(1) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11].
Laboratory Facility representatives were able to inform inspectors of the percent metal content in various piles of the solid waste material onsite. The Facility Representative informed the inspectors of the onsite laboratory. The inspectors spoke with the Laboratory Manager who explained that all the solid waste sold from the facility is analyzed prior to leaving the facility, that at least some of the solid waste is analyzed prior to processing, and some in-process material had been analyzed. All the samples ever analyzed are stored in an onsite data system. The inspectors asked what the average amount of lead in the samples analyzed had been and requested the ability to review the data. The inspectors were informed that lead content could range from 0.25% to 13% but it was not clear what material this estimate was for. The data was not available for review at the time of the inspection. The inspectors observed a box holding nine (9) 2.5-liter bottles of waste nitric acid and waste hydrochloric acid. The bottles collecting waste were labeled with the product labels and were not labeled hazardous waste or dated. The technician estimated that a 2.5-liter bottle takes approximately 1 month to accumulate.
Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Ga. Comp. R. and Regs. 391-3-11-.07(1) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11].
Records No records were reviewed at the time of the inspection. The inspectors requested specific records at the time of the inspection. On October 21, 2021, the EPA issued a Request for Information pursuant to Section 3007 of RCRA. As of the drafting of this report the information had not been received. At the conclusion of the CEI, the inspectors went over the preliminary concerns observed during the CEI.
12) Signed
B__R___O___O___K__E____Y__O___R___K__
Digitally signed by BROOKE YORK Date: 202_1__.1_1_._1_8__1_5_:_3_9_:0_6__-_0_5_'_0_0_'__
Brooke York
Date
Inspector and Author of Report
Champagne,
Digitally signed by Champagne,
David
David
Date: 2021.11.18 16:38:35 -05'00'
___________________________
_________________________
David Champagne
Date
Inspector
RCRA CEI Report TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 5 of 41
October 6, 2021
13) Concurrence and Approval
ARACELI CHAVEZ Date: 2021.11.18 16:50:44 -05'00' Digitally signed by ARACELI CHAVEZ
___________________________
_________________________
Araceli B. Chavez
Date
Chief
RCRA Enforcement Section
RCRA CEI Report TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 6 of 41
October 6, 2021
TAV Holdings, Inc. Atlanta, Georgia
EPA ID No.: GAD033537663 EPA RCRA CEI Photographs "PXL" Photographs taken by: David Champagne Camera Model: Google Pixel 3 XL "IMG" Photographs taken by: Brooke York
Camera Model: iPhone XR
Photos taken by Brooke York and David Champagne October 6, 2021
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 7 of 41
October 6, 2021
Figure 1: IMG_3070.jpg- CNC machine in the Shipping Building
Figure 2: IMG_3071.jpg - CNC machine in the Shipping Building
Figure 3: IMG_3072.jpg - oil under the CNC machine in the Shipping Building
Figure 4: IMG_3073.jpg - Pump oil in a bucket in the Shipping Building
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 8 of 41
October 6, 2021
Figure 5: IMG_3074.jpg - Metal shavings in the Shipping Building
Figure 6: IMG_3075.jpg - Paint sprayer in the Fabrication Building
Figure 8: IMG_3077.jpg - TAV's Signature Paint by Sherwin Williams
Figure 7: IMG_3076.jpg - TAV's Signature Paint by Sherwin Williams
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 9 of 41
October 6, 2021
Figure 9: IMG_3078.jpg - Paint bucket with liquid in it in the Fabrication Building
Figure 10: IMG_3079.jpg - Storage of material in the Fabrication Building
Figure 11: IMG_3080.jpg - Storage of material in the Fabrication Building
Figure 12: IMG_3081.jpg - View from rear of Fabrication Building
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 10 of 41
October 6, 2021
Figure 13: IMG_3082.jpg - Staining on ground of Fabrication
Figure 14: IMG_3083.jpg - Rear of Fabrication Building
Figure 15: IMG_3084.jpg- Rear of Fabrication Building
Figure 16: IMG_3085.jpg- Rear of Fabrication Building
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 11 of 41
October 6, 2021
Figure 17: IMG_3086.jpg- Rear of Fabrication Building
Figure 18: IMG_3087.jpg- Contents of Dumpster in rear of Fabrication Building
Figure 19: IMG_3088.jpg- Rear of Fabrication Building
Figure 20: IMG_3089.jpg- Rear of Fabrication Building
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 12 of 41
October 6, 2021
Figure 21: IMG_3090.jpg - Rear of Fabrication Building
Figure 22: IMG_3091.jpg - Mr. Brown said this was an Aluminum Refractory Skull
Figure 23: IMG_3092.jpg - Scrap Aluminum Figure 24: IMG_3093.jpg - Lead acid batteries
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 13 of 41
October 6, 2021
Figure 25: IMG_3094.jpg - Maintenance Shop parts washer
Figure 26: IMG_3095.jpg - Containers of unknown waste in the Keebler Building
Figure 27: IMG_3096.jpg - Containers of unknown waste in the Keebler Building
Figure 28: IMG_3097.jpg - Containers of electronic scrap circuit boards in the Keebler
Building
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 14 of 41
October 6, 2021
Figure 29: IMG_3098.jpg - Close up of apparently processed electronic scrap circuit
boards in the Keebler Building
Figure 30: IMG_3099.jpg - Pile of quick lime in the Keebler building
Figure 31: IMG_3100.jpg - Containers of unknown waste in the Keebler Building
Figure 32: IMG_3101.jpg - Containers of unknown waste in the Keebler Building
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 15 of 41
October 6, 2021
Figure 33: IMG_3102.jpg - Containers of unknown waste and pile of solid waste in the
Keebler Building
Figure 34: IMG_3103.jpg - Piles of solid waste stored in the Keebler Building
Figure 35: IMG_3104.jpg - Piles of solid waste stored in the Keebler Building
Figure 36: IMG_3105.jpg - Piles of solid waste stored in the Keebler Building
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 16 of 41
October 6, 2021
Figure 37: IMG_3106.jpg - Keebler Building showing holes in roof
Figure 38: IMG_3107.jpg- Keebler Building showing holes in roof
Figure 39: IMG_3108.jpg - Containers of unknown waste in the Keebler Building
Figure 40: IMG_3109.jpg - Containers of unknown waste in the Keebler Building
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 17 of 41
October 6, 2021
Figure 41: IMG_3110.jpg- Containers of unknown waste in the Keebler Building
Figure 42: IMG_3111.jpg- Containers of unknown waste in the Keebler Building
Figure 43: IMG_3112.jpg - Lab sample retention Figure 44: IMG_3113.jpg - Lab sample retention
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 18 of 41
October 6, 2021
Figure 45: IMG_3114.jpg - Lab sample retention Figure 46: IMG_3115.jpg - Lab sample retention
Figure 48: PXL_20211006_140722625.jpg - Receiving Area
Figure 47: IMG_3116.jpg - Acid waste in the lab
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 19 of 41
October 6, 2021
Figure 49: PXL_20211006_140801482.jpg - Receiving Area
Figure 50: PXL_20211006_141553356.jpg - Initial Processing, sorting by particle size
Figure 51: PXL_20211006_141559639.jpg - Sorted material
Figure 52: PXL_20211006_142355136.jpg - Processing in White Building
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 20 of 41
October 6, 2021
Figure 53: PXL_20211006_142804965.jpg Processing
Figure 54: PXL_20211006_142810714.jpg Processing
Figure 55: PXL_20211006_143440106.jpg Processing
Figure 56: PXL_20211006_143445271.jpg Processing
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 21 of 41
October 6, 2021
Figure 57: PXL_20211006_143449364.jpg - Process wastewater leaving the building
Figure 58: PXL_20211006_143636252.jpg - Sorted materials in the Processing Area
Figure 60: PXL_20211006_145602623.jpg - Solid Waste stored near the Wastewater Treatment area
Figure 59: PXL_20211006_145257774.MP.jpg - Eddy Current Process used to recover Aluminum
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 22 of 41
October 6, 2021
Figure 61: PXL_20211006_145612675.MP.jpg - Solid Waste stored near the Waste Water Treatment area
Figure 62: PXL_20211006_145830569.jpg Clarifier
Figure 63: PXL_20211006_145842021.jpg Clarifier
Figure 64: PXL_20211006_145902126.jpg - Sludge flowing across the floor.
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 23 of 41
October 6, 2021
Figure 65: PXL_20211006_145919867.jpg - Tank receiving process wastewater and sludge/wastewater overflow on the floor
Figure 66: PXL_20211006_145946590.jpg - Process wastewater and sludge flowing from the
process onto the ground in the wastewater treatment area
Figure 67: PXL_20211006_150035330.jpg - Wastewater treatment area
Figure 68: PXL_20211006_150046651.jpg Clarifier
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 24 of 41
October 6, 2021
Figure 69: PXL_20211006_150052233.jpg Clarifier
Figure 70: PXL_20211006_150131436.jpg - Wastewater Treatment Area
Figure 71: PXL_20211006_150436133.jpg Clarifier
Figure 72: PXL_20211006_151016463.jpg - Wastewater Treatment Area
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 25 of 41
October 6, 2021
Figure 73: PXL_20211006_151020218.jpg - Wastewater Treatment Area
Figure 74: PXL_20211006_151028251.jpg - Wastewater Treatment Area
Figure 75: PXL_20211006_151034451.MP.jpg - Wastewater Treatment Area Tanks
Figure 76: PXL_20211006_151038425.jpg - Wastewater Treatment Area
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 26 of 41
October 6, 2021
Figure 77: PXL_20211006_151059043.MP.jpg - Process water overflowing from Wastewater Treatment Area tanks
Figure 78: PXL_20211006_151136679.jpg - Wastewater Treatment Area
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 27 of 41
October 6, 2021
Figure 80: PXL_20211006_151153926.jpg - Wastewater Treatment Area
Figure 79: PXL_20211006_151149845.jpg - Wastewater Treatment Area
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 28 of 41
October 6, 2021
Figure 81: PXL_20211006_151548117.jpg - Plugged up Stormwater drain
Figure 82: PXL_20211006_151615119.jpg - Neighboring facility
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 29 of 41
October 6, 2021
Figure 83: PXL_20211006_151632795.jpg - Plugged up Stormwater drain
Figure 84: PXL_20211006_151955923.PORTRAIT.jpg -
Landfilled solid waste across the street
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 30 of 41
October 6, 2021
Figure 85: PXL_20211006_152327728.jpg - Plugged up Stormwater drain
Figure 86: PXL_20211006_152333693.jpg - Plugged up Stormwater drain
Figure 87: PXL_20211006_153116223.jpg - Receiving Area
Figure 88: PXL_20211006_153123989.jpg - Receiving Area
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 31 of 41
October 6, 2021
Figure 89: PXL_20211006_153550684.jpg - Receiving Area
Figure 90: PXL_20211006_155432203.jpg - Fabrication Building
Figure 91: PXL_20211006_160641125.jpg - Fabrication Building
Figure 92: PXL_20211006_180006404.jpg - Product staged in Shipping Area
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 32 of 41
October 6, 2021
Figure 94: PXL_20211006_180547574.jpg - Partially melted aluminum in the Basement
Figure 93: PXL_20211006_180036072.jpg - Product staged in Shipping Area
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 33 of 41
October 6, 2021
Figure 95: PXL_20211006_180654758.jpg - Aluminum Pellets to be Shipped
Figure 96: PXL_20211006_180949101.jpg Rear side of solid waste pile near Outfall 3
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 34 of 41
October 6, 2021
Figure 98: PXL_20211006_181114686.jpg - Rear side of solid waste pile near Outfall 3
Figure 97: PXL_20211006_181046518.jpg - Rear side of solid waste pile near Outfall 3
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 35 of 41
October 6, 2021
Figure 99: PXL_20211006_181118853.jpg - Rear side of solid waste pile near Outfall 3
Figure 100: PXL_20211006_181257842.jpg - Outfall 3
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 36 of 41
October 6, 2021
Figure 101: PXL_20211006_181402496.jpg - Wastewater flow approaching Outfall 3
Figure 102: PXL_20211006_181422067.jpg - Outfall 3
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 37 of 41
October 6, 2021
Figure 103: PXL_20211006_181428388.jpg - Outfall 3
Figure 104: PXL_20211006_181449950.jpg - Outfall 3
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 38 of 41
October 6, 2021
Figure 105: PXL_20211006_181504940.jpg - Outfall 3
Figure 106: PXL_20211006_181511578.jpg - Outfall 3
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 39 of 41
October 6, 2021
Figure 107: PXL_20211006_181815901.jpg - Settling Sludge from Stormwater Runoff in Outfall 3
Figure 108: PXL_20211006_183631146.PORTRAIT.jpg - Stormwater Runoff from Solid Waste Pile/Landfill
in Laydown Yard
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 40 of 41
October 6, 2021
Figure 109: PXL_20211006_183635073.MP.jpg - Stormwater Runoff from Solid Waste Pile/Landfill Laydown yard
Figure 110: PXL_20211006_183813827.jpg - Solid Waste Pile/Landfill Laydown Yard
EPA RCRA CEI Photographs TAV Holdings, Inc. EPA ID No.: GAD033537663
Page 41 of 41
October 6, 2021