Document MoGnrLDgkRapbEb97zkXbgQkL
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION III WATER BRANCH, ENFORCEMENT
AND COMPLIANCE ASSURANCE DIVISION CLEAN WATER ACT
COMPLIANCE INSPECTION REPORT
for
Name of Facility: Consolidated Scrap Resources, Inc. Facility Address: 1616 N. Cameron Street, Harrisburg, PA, 17103 Mailing Address: 1616 N. Cameron Street, Harrisburg, PA, 17103
Report Prepared on: Report Final as of:
9/14/2021 Date
10/01/2021 Date
By:
,
Environmental Scientist (PG Environmental)
Signature
MARK
By: ZOLANDZ
Signature
Digitally signed by MARK
ZOLANDZ
Date: 2021.10.01
15:56:23 -04'00'
, EPA
General Information
Type of Inspection: Owner: Operator: Permittee: NPDES Permit No: NPDES Permit Effective Date: NPDES Permit Expiration Date: Receiving Water/MS4:
Latitude and Longitude:
Industrial Stormwater Consolidated Scrap Resources, Inc. Consolidated Scrap Resources, Inc. Consolidated Scrap Resources, Inc. PAR603506 (PAG-03) September 24, 2016 September 23, 2021 Paxton Creek (tributary to the Susquehanna River), MS4 located along North Cameron Street 40.27809, -76.87926
On-Site Facility Inspection Overview
On August 12, 2021, a representative from U.S. Environmental Protection Agency (EPA) Region III's contractor, PG Environmental (the Inspector), conducted a compliance evaluation inspection at Consolidated Scrap Resources, Inc. in Harrisburg, Pennsylvania. Consolidated Scrap Resources, Inc. is identified as the Permittee and owns and operates the Facility. A representative from the Pennsylvania Department of Environmental Protection (DEP) also attended the inspection.
Approximate Entry Time: 9:30 AM (EDT) Approximate Exit Time: 1:15 PM (EDT)
Unique Project Identifier (UPI): 3E21WN044A
Unique Project Identifier: 3E21WN044A
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TABLE OF CONTENTS
PAGE
I.
INTRODUCTION............................................................................................................................ 3
II. INSPECTION PROCESS ................................................................................................................ 4 Inspection Opening Conference .......................................................................................................4 Weather and Precipitation Conditions..............................................................................................5 Facility Site Walk.............................................................................................................................5 Records Review ...............................................................................................................................6 Summary of Observations................................................................................................................7 Closing Conference........................................................................................................................12
List of Appendices Appendix A: Photograph Log Appendix B: Exhibit Log
o Exhibit 1 - Facility Stormwater Flow Discharge Map o Exhibit 2 - Integrated Contingency Plan o Exhibit 3 - ICIS Database Benchmark Monitoring Data (July 1, 2018 through June 30, 2021) o Exhibit 4 - EPA ECHO Detailed Facility Report o Exhibit 5 - Original Corrective Action Plan (March 2019) o Exhibit 6 - Corrective Action Plan Update (September 2019) o Exhibit 7 - Corrective Action Plan Update (March 2020) o Exhibit 8 - Corrective Action Plan Update (February 2021) o Exhibit 9 - Supervisor Monthly Walk Around Checklists (February 2021 through July 2021)
Appendix C: PAG-03 Permit
Unique Project Identifier: 3E21WN044A
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I.
INTRODUCTION
On August 12, 2021, a representative from U.S. Environmental Protection Agency (EPA) Region III's contractor, PG Environmental (the Inspector), conducted a compliance evaluation inspection at Consolidated Scrap Resources, Inc. in Harrisburg, Pennsylvania (Facility). Consolidated Scrap Resources, Inc. (CSR) is identified as the Permittee and owns and operates the Facility. The Inspector was joined on the inspection by a representative from the Pennsylvania Department of Environmental Protection (DEP). The purpose of the inspection was to assess the Permittee's compliance with the DEP's National Pollutant Discharge Elimination System (NPDES) General Permit for Discharges of Stormwater Associated with Industrial Activities (PAG-03, Registration No. PAR603506; hereinafter, the Permit). The Facility is classified under Sector P of the Permit, Scrap and Waste Recycling Facilities.
The Facility is a 28-acre scrap metal recycling center. Most of the Facility is covered by compacted dirt and gravel, with a portion (mainly access roads) comprising impervious asphalt. Paxton Creek runs along the western perimeter of the site, and Asylum Run borders the Facility to the north. The Facility is located entirely within the 100-year Paxton Creek floodplain.
Ferrous and nonferrous scrap metal and small quantities of consumer-scale recyclables (cardboard, plastic bottles, aluminum cans) are brought into the Facility by commercial haulers, the general public, or transferred from one of five other CSR collection sites and then separated based on type. A large portion of the scrap is processed via the Facility's shredder. The hydraulic shredder system processes and sorts scrap into a usable/shippable form and allows the non-recyclable auto shredder residue (ASR), or "fluff," to be sorted out. The ASR material is the non-metallic waste stream from the shredder process (plastic, foam, paper, etc.). The Facility Manager stated that some ASR is hauled to a landfill on a daily basis. A hydraulic shear and two balers are also used periodically to process scrap prior to shipment. All scrap is loaded onto trucks and shipped offsite for further processing. Large piles of pre-processed scrap, shredded scrap, and ASR were observed staged throughout the site. According to the Facility Manager, the shredder processes approximately 700 tons of material per day, and approximately 400 tons of material are hauled offsite each day.
CSR maintains a fleet of vehicles and equipment onsite used for collecting and processing scrap. Additionally, the Facility has a maintenance shop building for vehicle and equipment maintenance as well as a variety of aboveground storage tanks and fluid storage containers used for fleet and equipment operations. Figure 1 includes a list of fluid materials maintained onsite (including used oil) as well as the total volume and container type for each. The Facility manager stated that in addition to CSR vehicles and equipment, several independent contractors also utilize the site. These contractors are responsible for the operation and maintenance of their equipment. The Facility manager stated that spill kits are maintained on all CSR equipment. He added that contractors are supposed to have spill kits on their equipment, but this is not always the case; he stated he will remind contractors of this requirement if they are found without one.
The Facility has four mapped outfalls. Outfall No. 001 discharges runoff collected primarily from an employee parking area into the municipal separate storm sewer system (MS4) located along North Cameron Street. The Facility Manager was unsure whether the MS4 on North Cameron Street was operated by the City of Harrisburg or the Pennsylvania Department of Transportation (PennDOT).
Outfall No. 002 is a piped outfall into Paxton Creek that discharges runoff collected in catch basins, mostly from the retail area. The outfall was not able to be located at the time of the inspection (refer to Observation 5 of this report for additional details).
Outfall No. 003 is a piped outfall into Paxton Creek that discharges runoff collected in catch basins, mostly from the Penn Harris Dock area, maintenance shop area, and surrounding access roads.
Unique Project Identifier: 3E21WN044A
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Outfall No. 004 is located just east of the shredder area and discharges sheet flow into Paxton Creek from the shredder area and the vicinity of the adjacent ASR and scrap piles. Sheet flow leaves the site in multiple locations along the northwestern perimeter of the Facility but is only monitored at Outfall No. 004 (refer to Observation 4 of this report for additional details). A stormwater flow and discharge map was provided following the inspection and is included as Appendix B, Exhibit 1.
As noted previously, the Facility experienced a significant precipitation event of more than 3-inches of rain during the 24-hours prior to the inspection. Much of the site had standing water, ranging from a few inches to over 1 foot, in low-lying areas during the inspection, including around the shredder, the shear system, in the retail area, and around the scrap piles staged south of the maintenance building. Refer to Observation 1 of this report for additional details.
Figure 1. Facility Material, Waste, and Oil Inventory (from the Facility's Integrated Contingency Plan; refer to Appendix B, Exhibit 2)
II. INSPECTION PROCESS
Inspection Opening Conference
The Inspector arrived at the Facility at 9:30 AM (EDT) for the inspection. Jake Albright of PG Environmental displayed his Clean Water Act inspector credential to the Facility representatives at the outset of the inspection and explained that the purpose of the inspection was to observe compliance with the Permit. The Inspector 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.
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Name
Table 1: Inspection Attendee List
Affiliation
Telephone
EPA Region III Contractor
Email
Jake Albright
PG Environmental
(703) 956-1957
Jake.Albright@pgenv.com
Pennsylvania Department of Environmental Protection
Heather Dock
DEP
(717) 705-4785
hdock@pa.gov
Facility Representative*
Marty Jackson, Facility Manager
Consolidated Scrap Resources, Inc.
(717) 233-7927
mjackson@consolidatedscrap.com
Scott Schneidenberg, Shredder Consolidated Scrap Manager Resources, Inc. - -
*Mr. Rick Hare, CSR Director of Safety and Environmental Compliance, was consulted briefly over the phone during
the records review of the inspection but was not present. Mr. Hare is the primary environmental program contact for
all CSR facilities (rhare@consolidatedscrap.com; (717) 843-0931).
Weather and Precipitation Conditions
During the inspection, the weather was sunny and humid. The Facility experienced a significant heavy rain event during the evening prior to 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 2 below:
Station Name
HARRISBURG 1 NE, PA US HARRISBURG 1 NE, PA US HARRISBURG 1 NE, PA US HARRISBURG 1 NE, PA US HARRISBURG 1 NE, PA US HARRISBURG 1 NE, PA US
Table 2. Precipitation Data
Date
08/07/2021 08/08/2021 08/09/2021 08/10/2021 08/11/2021 08/12/2021
Precipitation Amount (inches)1 0.15 0 0 0.01 0.52
2.55
Facility Site Walk
As part of the inspection process, the Inspector visually observed the site conditions in the presence of the Facility Manager and the Shredder Manager. The primary purpose of the inspection was to review industrial processes at the Facility, the accuracy and reliability of the Permittee's self-monitoring and reporting program, and to obtain information that will assist EPA in assessing the Permittee's compliance with Permit requirements.
Photographs were taken during the inspection by Mr. Jake Albright (PG Environmental). Photographs used to support the observations in this report are included in Appendix A, Photograph Log. Photographs not used are kept on file at EPA Region III. Documents used to support the observations in this report are included in Appendix B, Exhibit Log.
The Inspector began the walk-through at the Facility entrance located on the eastern perimeter of the site, along North Cameron Street (refer to Appendix A, Photograph 1). The Inspector observed piles of hauled in scrap, separated based on type, stored throughout the central portion of the site, awaiting processing (e.g., shredding). The Inspector observed the Penn Harris Dock area, which included a trench drain at the
1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/).
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entrance to the dock that discharges to Outfall No. 003 (refer to Appendix A, Photographs 2 through 4). From the Penn Harris Dock, the Inspector followed the access road to the maintenance shop area (refer to Appendix A, Photographs 5 through 8). A catch basin was located on the access road west of the Penn Harris Dock; the inlet to the basin was covered in mud and sediment.
Within the maintenance shop, the Inspector observed a space for indoor vehicle and equipment maintenance as well as various fluids stored for vehicle/equipment operation (washer fluid, transmission fluid, and antifreeze; refer to Appendix A, Photograph 9). Outside the maintenance shop, on the north side of the building, the Inspector observed a trench drain that collected runoff to be discharged through Outfall No. 003 into Paxton Creek (refer to Appendix A, Photographs 10 through 14).
After the maintenance shop area, the Inspector continued along the western perimeter of the Facility, observing various scrap storage areas and the location of Outfall No.003 (refer to Appendix A, Photographs 15 through 20). Facility representatives stated Outfall No. 002 was also located in this general area; however, it was unable to be located at the time of the inspection.
The Inspector continued the inspection within the Facility's retail area, located near the entrance in the central-eastern part of the site (refer to Appendix A, Photographs 21 through 26). The Inspector observed scrap piles generated mostly from smaller private haulers and residential customers. Catch basins that collected runoff to be conveyed to Outfall No. 002 were located in the area.
The Inspector continued the inspection along the Facility's northwestern perimeter and observed ASR and scrap piles, the shredder, and the Outfall No. 004 location (refer to Appendix A, Photographs 27 through 36). The Inspector observed a jersey barrier, rock, and filter sock BMP at Outfall No. 004, adjacent to the ASR pile.
Next, the Inspector observed the area around the shear building, located in the northwest corner of the site (refer to Appendix A, Photographs 37 through 43). The area included the shear building, various scrap piles, and a partially covered ASR pile. The Inspector also observed, another, separate, business located just north of the Facility in this general area, Advanced Recovery Technologies (ART; refer to Appendix A, Photographs 44 and 45). According to the Facility Manager, ART helps CSR in further processing some of CSRs post shredder material. He was unsure of ART's permit status at the time of the inspection. The Inspector briefly viewed inside the ART building.
After the ART Building, the Inspector observed the large baler, the eastern perimeter of the site (including the Facility exit), and the catch basin in the employee parking lot that connects to Outfall No. 001 and the local MS4 (refer to Appendix A, Photographs 46 through 52). The Inspector concluded the Facility walkthrough at the Facility's main office.
Additional details related to the site conditions at the time of the inspection are included in the Summary of Observations section below.
Records Review
The Inspector conducted a records review to evaluate the Permittee's compliance with the Permit. The Facility's Integrated Contingency Plan, which is inclusive the Facility's preparedness, prevention, and contingency (PPC) plan, was available and reviewed onsite, as well as provided digitally after the inspection; however, most document review was conducted offsite. The Facility's electronic discharge monitoring report (eDMR) data, corrective action plans (CAPs), and a DEP inspection report were provided electronically by DEP and reviewed offsite. The following documents were reviewed:
EPA Integrated Compliance Information System (ICIS) data during the period from July 1, 2018 through June 30, 2021
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Facility Integrated Contingency Plan (dated September 2017, amended June 16, 2021) Facility Stormwater Flow Discharge Map (dated November 22, 2019) CSR CAPs (multiple versions; most recent update February 2021) Monthly supervisor inspection records (February 2021 through July 2021) Monthly operator inspection records (February 2021 through July 2021) Street sweeper log (January 1, 2021 through August 16, 2021) Bi-annual electronic discharge monitoring reports (eDMRs) and lab data (July 2018 through June
2021) CSR Annual Reports (2018, 2019, and 2020) DEP Facility inspection report (February 5, 2019)
Summary of Observations The following section summarizes the Inspector's observations relative to the Permit requirements.
Site Flooding
According to Facility representatives and the Integrated Contingency Plan, the Facility was built in the 100-year flood plain of Paxton Creek and floods during heavy rain events (one to two times per year). They stated that Paxton Creek will over top its banks and flood the Facility from the west, and the MS4 on North Cameron Street will back up and flood the Facility from the east. This occurred during the evening preceding the inspection, and the majority of the site was muddy or flooded at the time of the inspection. Several large scrap and waste piles were surrounded by pools of water, several inches to more than one foot deep in some places. Site conditions in specific areas of the site are discussed in more detail in the following observations.
Benchmark Monitoring Appendix P of the Permit requires the Permittee to "monitor and report analytical results for the parameters listed below [see Figure 2] on Discharge Monitoring Reports (DMRs) for representative outfalls, subject to footnotes provided. The benchmark values listed below are not effluent limitations, and exceedances do not constitute permit violations. However, if the permittee's sampling demonstrates exceedances of benchmark values for two consecutive monitoring periods, the permittee shall submit a corrective action plan within 90 days of the end of the monitoring period triggering the plan."
Figure 2. Sector P benchmark monitoring requirements (from Appendix P of the Permit).
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According to EPA's ICIS database, the Facility experienced six benchmark exceedances for chemical oxygen demand (COD; five of the six for Outfall No. 003), nine benchmark exceedances for total suspended solids (TSS; six of the nine from Outfall No. 003), and two benchmark exceedances for oil and grease (both from Outfall No. 003) between July 1, 2018 and June 30, 2021 (refer to Appendix B, Exhibit 3 and Table 3 below).
Table 3. Reported Benchmark Exceedances (July 1, 2018 through June 30, 2021)
Monitoring Outfall Parameter eDMR Benchmark Units
Period End
Value
Value
06/30/2021
003
COD
270
120
mg/L
06/30/2021
001
TSS
155
100
mg/L
06/30/2021
003
TSS
245
100
mg/L
12/31/2020
003
TSS
154
100
mg/L
12/31/2020
003 Oil & Grease
88
30
mg/L
06/30/2020
002
COD
156
120
mg/L
06/30/2020
003
COD
908
120
mg/L
06/30/2020
001
TSS
178
100
mg/L
06/30/2020
002
TSS
130
100
mg/L
06/30/2020
003
TSS
1060
100
mg/L
12/31/2019
003
COD
445
120
mg/L
12/31/2019
003
TSS
456
100
mg/L
06/30/2019
003
COD
404
120
mg/L
06/30/2019
003
TSS
344
100
mg/L
06/30/2019
003
Oil & Grease
98.4
30
mg/L
12/31/2018
003
COD
202
120
mg/L
12/31/2018
003
TSS
323
100
mg/L
EPA's Enforcement and Compliance History Online (ECHO) database indicates the Facility was in a state of significant noncompliance (SNC) between January 1, 2019 and March 31, 2021 for failure to report (refer to Appendix B, Exhibit 4). The Inspector verified submittal of all eDMRs, on time, between July 1, 2018 and June 30, 2021. It appears the SNC designation may be linked to the fact that the Facility once had five outfalls but no longer discharges to Outfall No. 005; therefore, no monitoring has occurred at the location for years. It is unclear exactly when the Facility stopped discharging to Outfall No. 005. The Permittee reported "NODI **8**" for Outfall No. 005 during the second half 2018 and first half of 2019 and has not included Outfall No. 005 in reporting since the first half of 2019.
Corrective Action Plan In response to the benchmark exceedances described above, the Permittee developed and began implementing a CAP targeted at Outfall No. 003 in March of 2019. The CAP has been revised four times, most recently in February 2021. The original CAP called for the closure/filling in of Outfall No. 003 and associated drainage infrastructure and directing runoff via curb and gutter to Outfall No. 004 (refer to Appendix B, Exhibit 5); this action had not been pursued at the time of the inspection. The original CAP was reviewed following the inspection, and not discussed with Facility representatives onsite; it is unclear why this action was not implemented.
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A September 2019 update of the CAP does not mention closing Outfall No. 003 but calls for the installation of filter socks above the trench drain that discharges to Outfall No. 003 (i.e., on the north side of the maintenance building) as well as an increased inspection frequency (quarterly) of the drain and cleaning as needed (refer to Appendix B, Exhibit 6). A March 2020 update increases the inspection frequency to every two months (refer to Appendix B, Exhibit 7), and a February 2021 revision prescribes a bimonthly inspection frequency (refer to Appendix B, Exhibit 8). All other provisions remain the same throughout the updates.
The Permittee provided inspection records showing the CSR Director of Safety and Environmental Compliance conducts monthly Facility walk-throughs which include a checklist item for ensuring areas around stormwater outfalls are free of debris and fluids. The checklist does not provide much detail on observations made or whether any corrective actions (e.g., trench drain cleaning) needed to be taken (refer to Appendix B, Exhibit 9).
At the time of the inspection, the Inspector observed a rock bed and filter socks installed at the trench drain; however, oily sheen was observed actively flowing into the drain (refer to Appendix A, Photographs 10 through 13). Sheen was not evident at Outfall No. 003 at the time of the inspection.
The Permittee reported no discharge at Outfall No. 004, the sheet flow outfall adjacent to the western ASR pile and shredder, during five of the six reported monitoring periods since July 1, 2018. The Permittee reported no discharge at Outfall No. 002 once.
Table 4. Reported Instances of No Discharge at an Outfall (July 1, 2018 through June 30, 2021)
Monitoring Period End Outfall No Discharge Code
06/30/2021 002-S
NODI C
06/30/2021 004-S
NODI C
12/31/2020 004-S
NODI C
06/30/2020 004-S
NODI C
12/31/2019 004-S
NODI C
12/31/2018 004-S
NODI C
Outfalls Part C.I.A of the Permit states, "The permittee is authorized to discharge stormwater associated with industrial activity from its site, alone or in combination with authorized non-stormwater discharges, through the outfalls identified in the NOI submitted for coverage under this General Permit."
The Inspector observed that Outfall No. 004 was not representative of all runoff discharging via sheet flow along the western and northwestern perimeter of the Facility into Paxton Creek. Specifically, Outfall No. 004 did not appear as though it would be representative of sheet flow runoff from the shear building area, located in the northwest corner of the Facility, approximately 450-500 feet north of Outfall No. 004 (refer to Appendix A, Photographs 37 through 39 and Appendix B, Exhibit 1). Outfall No. 004 is the only location onsite where sheet flow is monitored. In addition to the shear building and associated equipment, there were also a variety of scrap piles located in the vicinity, as close as approximately 50 feet east of Paxton Creek.
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Facility representatives were unable to locate Outfall No. 002 at the time of the inspection. The Permittee provided a map showing Outfall No. 002 located just north of Outfall No. 003 (refer to Appendix B, Exhibit 1). Facility representatives stated that the Director of Safety and Environmental Compliance would know the location but was unavailable to be onsite during the inspection.
PPC Plan Part C.III.A of the Permit states, "The permittee shall develop and implement a PPC Plan in accordance with 25 Pa. Code 91.34 following the guidance contained in DEP's "Guidelines for the Development and Implementation of Environmental Emergency Response Plans" (DEP ID 400-2200-001), its NPDESspecific addendum and the minimum requirements below.
1. The PPC Plan must identify all potential sources of pollutants that may reasonably be expected to affect the quality of stormwater discharges from the facility.
2. The PPC Plan must describe preventative measures and BMPs that will be implemented to reduce or eliminate pollutants from coming into contact with stormwater resulting from routine site activities and spills.
3. The PPC Plan must address actions that will be taken in response to on-site spills or other pollution incidents.
4. The PPC Plan must identify areas which, due to topography or other factors, have a high potential for soil erosion, and identify measures to limit erosion. Where necessary, erosion and sediment control measures must be developed and implemented in accordance with 25 Pa. Code Chapter 102 and DEP's "Erosion and Sediment Pollution Control Manual" (DEP ID 363-2134-008).
5. The PPC Plan must address security measures to prevent accidental or intentional entry which could result in an unintentional discharge of pollutants.
6. The PPC Plan must include a plan for training employees and contractors on pollution prevention, BMPs, and emergency response measures. This training must be conducted in accordance with Part C II.E.3.
7. If the facility is subject to SARA Title III, Section 313, the PPC Plan must identify releases of "Water Priority Chemicals" within the previous three years. Water Priority Chemicals are those identified in EPA's "Guidance for the Determination of Appropriate Methods for the Detection of Section 313 Water Priority Chemicals" (EPA 833-B-94-001, April 1994). The Plan must include an evaluation of all activities that may result in the stormwater discharge of Water Priority Chemicals.
8. Spill Prevention Control and Countermeasure (SPCC) plans may be used to meet the requirements of this section if the minimum requirements are addressed."
The Facility's Integrated Contingency Plan does not include all minimum Permitrequired provisions for a PPC plan, most notably Part C.III.A.1 and Part C.III.A.2 of the Permit (refer to Appendix B, Exhibit 2). The Facility's Integrated Contingency Plan was developed to satisfy requirements for an SPCC plan and PPC plan; however, the integrated plan only covers potential liquid pollutants such as petroleum products and waste stored onsite. The integrated plan does not include description of other pollutant sources, such as the many scrap and waste piles staged throughout the site, nor does it describe preventative measures and BMPs that will be implemented to reduce or eliminate pollutants from scrap and solid waste storage areas.
Additionally, the Integrated Contingency Plan does not discuss measures to prevent sediment-laden runoff from discharging from the site. Most access roads are paved; however, a large portion of the site is compacted dirt and gravel. The Inspector observed mud and sediment entering an unprotected trench drain at the Penn Harris Dock (refer to Appendix A, Photographs 2 through 4) as well as entering a catch basin located just west of the Penn Harris Dock building (the basin had a filter in it; refer to Appendix A, Photographs 5 through 7). The Inspector also observed sediment track-out leaving the
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site exit onto North Cameron Street (refer to Appendix A, Photographs 49 through 51). MS4 inlets were observed along North Cameron Street.
During the inspection, Facility representatives were able to provide documentation showing that the paved areas of the site are typically swept via street sweeper multiple times per week. They stated that the site was in particularly bad shape during the inspection due to the recent heavy rain and flooding.
Sector-specific BMPs Part C.II.A of the Permit states, "The permittee shall implement and maintain all BMPs specified in the applicable sector-specific appendix or appendices, as identified on page 1 of this General Permit, unless DEP makes a determination and notifies the permittee that alternative pollution prevention measures provide equivalent protection."
Appendix P, Part III.2 of the Permit (Scrap and Waste Material Stockpiles and Storage (Outdoors)) states, "Minimize contact of stormwater runoff with stockpiled materials, processed materials, and non-recyclable wastes through implementation of control measures including but not limited to the following: permanent or semi-permanent covers; sediment traps, vegetated swales and strips, catch basin filters, and sand filters to facilitate settling or filtering of pollutants; dikes, berms, containment trenches, culverts, and surface grading to divert runoff from storage areas; silt fencing; and oil and water separators, sumps, and dry absorbents for areas where potential sources of residual fluids are stockpiled (e.g., automobile engine storage areas)."
The Inspector observed ASR-type material on the banks of Paxton Creek in multiple locations along the western perimeter of the site, including near the jersey barrier in the vicinity of Outfall No. 003 and on the downstream side of the jersey barrier, rock, and filter sock BMP next to the western ASR pile (refer to Appendix A, Photographs 19, 28, 29, 31, 32, and 33). The western ASR pile was uncovered; the pile was located about 5 feet from the edge of the jersey barrier (refer to Appendix A, Photograph 31). The jersey barrier, rock, and filter sock BMP was the only control implemented to protect the ASR pile. The Inspector did not observe noticeable ASR material in Paxton Creek.
The northern ASR pile was partially covered at the time of the inspection (refer to Appendix A, Photograph 43). The Inspector observed some material stored outside the covered area. The northern ASR pile was located approximately 300 feet east of Paxton Creek; according to Facility representatives, no stormwater catch basins were located in the area.
None of the scrap piles observed onsite were covered or otherwise protected to minimize contact of stormwater runoff. Facility representatives explained that the portions of the central and southern areas of the site were graded in such a way that runoff would pool in the middle of the property and either infiltrate or evaporate over time; a low lying "retention pond" was located along the eastern perimeter of the site (refer to Appendix A, Photograph 48). The site grading was represented on the Facility's stormwater flow map (refer to Appendix B, Exhibit 1) as well as evident in the observations made of pooled water in the middle of the site at the time of the inspection (refer to Appendix A, Photographs 8, 14, 20, and 34). Runoff in the northern and western part of the site sheet flows west into Paxton Creek.
At the time of the inspection, murky, cloudy, runoff was observed flowing from the preprocessed scrap piles in the retail area into a catch basin located outside the small baler building (refer to Appendix A, Photographs 22 through 26). The Facility Manager stated that a filter sock should be located in the catch basin; however, a photograph taken by the
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Inspector did not show a filter sock in place (refer to Appendix A, Photograph 26). According to Facility representatives, the basin drains to Outfall No. 002.
Additionally, the Inspector observed a pile of rusted rotors in the retail area that Facility representatives stated was staged on top of a catch basin that also drains to Outfall No. 002 (refer to Appendix A, Photograph 21). They stated that the pile had been there for years and that they did not believe the catch basin was protected.
As noted previously, at the time of the inspection, the Inspector observed a rock bed and filter socks installed at the trench drain on the north side of the maintenance shop; however, oily sheen was observed actively flowing into the drain, downstream of the BMP (refer to Appendix A, Photographs 10 through 13). The BMP had been placed at the trench drain as part of the Facility's CAP for Outfall No. 003.
Good Housekeeping Part C.II.C.4 requires the Permittee to "Eliminate floor drain connections to storm sewers."
The Inspector observed a floor drain inside the shear building located next to fluid storage drums that were not in secondary containment (refer to Appendix A, Photograph 41) as well as in close proximity to leaking equipment (refer to Appendix A, Photograph 40). Petroleum product stains were observed on the floor around the drain. Facility representatives were unsure where the floor drain discharged to.
Spill Prevention and Responses Part C.II.E.2 requires the Permittee to "Implement procedures for material storage and handling, including the use of secondary containment and barriers between material storage and traffic areas, or a similarly effective means designed to prevent the discharge of pollutants from these areas."
The Inspector observed fluid storage drums inside the maintenance shop, near the north garage door, as well as near a floor drain in the shear building stored without secondary containment (refer to Appendix A, Photographs 9 and 41). The Inspector also observed an oil sheen (i.e., spill) on the second floor of the large baler building, near the open access door (refer to Appendix A, Photograph 47). It is unclear where the spill originated. Part C.II.B.3 of the Permit requires the Permittee to clean up spills and leaks promptly using dry methods (e.g., absorbents) to prevent the discharge of pollutants to surface waters." The spill in the large baler building did not appear to be an immediate threat to water quality.
Closing Conference
At the conclusion of the onsite inspection, the Inspector conducted a closing conference with the Facility Manager and shared preliminary observations. The Inspector reiterated that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by the Inspector 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 1:15 PM (EDT).
Unique Project Identifier: 3E21WN044A
Page 12 of 12
Inspection Date: August 12, 2021