Document Mrn49e8Q8aKgg3do0bpGv9Oz

U.S. Environmental Protection Agency, Region 4 61 Forsyth Street SW, Atlanta, GA 30303 Compliance Inspection Report for Stormwater Discharges from Construction Activities (CGP) Site/Project Name: Insurance Auto Auctions-Millington FACILITY DATA NPDES Tracking Number: TNR155426 Date Coverage was Issued: 8/4/2023 Name of Permittee (Developer/Operator): Scott Guenther Inspection Purpose: CGP compliance inspection Tennessee Department of Transportation (TDOT) Project? Yes No Onsite Representative: No onsite representative took part in the inspection, but a representative for the Site granted access. Phone Number: Email Address: N/A N/A Responsible Official: Scott Guenther, Senior Vice President of North American Operations Insurance Auto Auctions Phone Number: Email Address: (713) 551-3699 sguenther@iaai.com INSPECTION ENTRY DATES/TIMES Entry Date/Time: July 10th, 2024 / 9:00 AM Exit Date/Time: July 10th, 2024 / 10:38 AM NAMES OF STATE INSPECTORS Name: Joellyn Brazile, Environmental Consultant Tennessee Department of Environment and Conservation (TDEC) Phone Number: 901-237-6000 Email Address: Joellyn.Brazile@tn.gov AREAS EVALUATED DURING INSPECTION (Check those areas evaluated) X Permit Self-Compliance Program Pretreatment X Records Compliance Schedule X Pollution Prevention X Facility Site Review Laboratory X Storm Water X Effluent/ Receiving Waters X Operations & Maintenance Combined Sewer Overflow Flow Measurement Sludge Handling/ Disposal Sanitary Sewer Overflow INSPECTION SUMMARY On July 10, 2024, Jeremy Judd from EPA Region 4, Joellyn Brazile from TDEC, and two (2) contractors from Eastern Research Group (ERG), Taylor Fontaine and Ryan Marrero-Vila (the EPA Inspection Team), conducted an unaccompanied construction general permit (CGP) inspection of the Insurance Auto Auctions-Millington project. The documents used for the record review were retrieved from the Tennessee Department of Environment and Conservation's Document Viewer database (https://tdec.tn.gov/documentviewer/search/CGP). EPA AND CONTRACTOR REPRESENTATIVES Inspector Name: Email Address: Office/Phone Number: Jeremy Judd EPA Region 4 Signature: Judd.Jeremy@epa.gov (206) 769-1789 Page 1 of 8 Taylor Fontaine Eastern Research Group Signature: Ryan Marrero-Vila Eastern Research Group Signature: Management Name: Ahmad Dromgoole EPA Region 4, Water Section Chief AHMAD Digitally signed by AHMAD DROMGOOLE Signature: DROMGOOLE Date: 2024.09.16 12:46:53 -04'00' Taylor.Fontaine@erg.com Ryan.Marrero-Vila@erg.com Email Address: Dromgoole.Ahmad@epa.gov (703) 956-1977 (571) 439-6262 Office/Phone Number: (404) 562-9212 GPS Coordinates: Receiving Water(s), blue line stream or MS4: Total site area acres & disturbed acres? Part 1.4.2 Total project size over 50 acres? Part 5.5.3.3 NOI submitted? Part 1.4. Email on NOI: Has Owner or Operator changed? NPDES Construction Stormwater Worksheet (Tennessee) 1. FACILITY LOCATION INFORMATION Latitude 35.27286 Longitude -89.96173 Unnamed Tributary to Loosahatchie River that discharges to the Loosahatchie River Weather Conditions: Approximately 82F and sunny. According to precipitation data from the National Oceanic and Atmospheric Administration (NOAA), the Millington, TN area received 1.94 inches of rain the day before the inspection and trace amounts the day of the inspection. 59.65 total acres/48.43 disturbed acres per the SWPPP Yes No Notice of Coverage Effective Date August 4, 2023 Notice of Coverage Expiration Date September 30, 2026 Yes, submitted on 6/5/2023. sguenther@iaai.com Discharge to 303(d) listed or TMDL waters Exceptional Tennessee Waters Yes (nutrients, e. coli, sedimentation/ siltation, lead, mercury, dioxin, chlordane, PCB) No Has a new Aquatic No NOI been No Resource No submitted? Alteration Page 2 of 8 Permit? 2. STORMWATER POLLUTION PREVENTION PLAN (SWPPP) AND EROSION PREVENTION AND SEDIMENT CONTROL (EPSC) PLAN (PLAN) INFORMATION AND SUPPORTING DOCUMENTS (A copy of the Plan may be brought back to the office for a complete review) PLAN TOPICS YES NO N/A a. Stormwater Pollution Prevention Plan (SWPPP) developed and available on site (Parts X 5.1, 5.3.4, and 7.2)? b. SWPPP developed by a qualified individual (Part 5.2)? X c. SWPPP is signed by a duly authorized representative (Parts 5.3.3, 8.7.2, and 8.7.3)? X d. SWPPP modified or updated to reflect current Site conditions (Part 5.4.1)? X SWPPP available on site is dated August 1, 2023, and currently reflects the Site conditions. e. SWPPP includes Site description (Part 5.5.1)? [nature of construction; description and timeline of sequence of activities; total area of Site and disturbed portion; peak discharge X info of Site before and after construction.] f. SWPPP identifies source(s) of all non-stormwater discharge(s) (Part 5.5.3.12)? X g. Erosion Prevention and Sediment Controls (EPSC) Plan developed and available in the SWPPP (Parts 5.5.2 and 5.5.3)? (Date of plan?) X Most recent EPSC plan was developed July 21, 2023 [Refer to Appendix C, Exhibit Log (Exhibit 1)]. h. SWPPP/EPSC Plan describe the intended sequence and includes a description of interim X & permanent stabilization measures (Parts 5.5.1, 5.5.3.2, and 5.5.3.4)? i. Was a site assessment conducted for each outfall draining 10 or more acres or 5 or more acres if draining to waters with unavailable parameters or Exceptional Tennessee Waters (Part 5.5.3.8)? X According to the Site EPSC Plan Outfalls #2 and #3 drain more than 10 acres. The SWPPP and ESC did not include a site assessment for these outfalls. 3. SITE DESCRIPTION AND PLAN and The Insurance Auto Auctions-Millington site is a commercial project for the construction of an automotive storage facility. When complete the facility will include a 7,812 square foot building, an employee parking lot, a drop off zone, an unloading area, and inventory parking. The SWPPP notes that the storage facility will assist with the online auction business. At the time of the inspection, the site was cleared of vegetation and two (2) wetlands were present along the perimeter of the Site. The EPA Inspection Team observed most of the Site sloped southeast towards a sediment basin at the corner of the Site. The area northeast of the eastern-most protected wetland sloped to the east towards Loosahatchie River. One (1) general contractor worker from Browning Contractors Inc. was grading sections of the site in a loader and told the EPA Inspection Team that the sediment basin was still under construction but was actively being used. This worker did not accompany the EPA Inspection Team for the inspection. The EPA Inspection Team observed a perimeter silt fence on the western and southern portions of the Site, one Page 3 of 8 (1) construction entrance along Fite Road, and two (2) drop inlets that were protected by silt fence. 4. RECORD REVIEW Record Review YES NO N/A a. Representative onsite: X b. Records available onsite or "readily available" (Part 5.3.4 and 7.2)? The notice of intent, the SWPPP, and a business card for Diann Kelley, Site Inspector, were X within the mailbox onsite [Refer to Appendix C, Exhibit Log (Exhibit 2)]. Documentation of previous inspection reports were not present. c. Has the Site submitted a Notice of Intent (NOI) (Part 1.4.1)? X d. Was the NOI submitted and signed by an individual who has daily operational control (Parts 3.1.1 and 3.1.6)? X Yes, the NOI was signed by Scott Guenther and submitted on 6/5/2023. e. Does the Site map include the following: Site acreage to be disturbed, all outfalls discharging runoff from the property, streams receiving the discharge, and storm sewer X systems conveying the discharge from outfalls (Part 3.2.2)? f. Project exceeds 50 acres of disturbance (Part 5.5.3.3)? X Total disturbed area of the project is 48.43 acres. g. If yes to 4.f, is the Permittee maintaining a rainfall log per calendar day? X h. If yes to 4.f., are site inspections conducted at least twice weekly and following any rainfall event of more than 0.5 inches in 24 hours by authorized representative (Part 5.5.3.9 and 5.5.3.10)? i. If yes to 4.f., is the Permittee conducting stormwater runoff monitoring shall be conducted at each outfall draining 10 or more acres (Section 5.5.3.5) or 5 or more acres if draining to waters with unavailable parameters or Exceptional Tennessee Waters (Section 6.4.1)? j. If no to 4.f., are Permittee site inspections conducted at least twice weekly by authorized representative (Part 5.5.3.9 and 5.5.3.10)? No on-site representative was present to confirm, and site inspection documents were not present in the SWPPP box at the construction entrance. k. Inspections documented on Construction Stormwater Inspection Certification Form (Part 5.5.3.11)? No on-site representative was present to confirm, and site inspection documents were not present in the SWPPP box at the construction entrance. X X X X Erosion Prevention and Sediment Controls (EPSCs) a. Are all applicable EPSCs installed and maintained per the SWPPP per the 5. FIELD EVALUATION & PLAN IMPLEMENTATION Check BMPs Listed in the Plan Note location, quantitative description, design issue, O&M deficiencies (including the nature and extent), and sediment off site in accordance with the Tennessee Erosion Prevention & Sediment Control Handbook. The EPA Inspection Team observed that EPSC measures, namely No the silt fence and check dams present in the EPSC plan, were not installed at the northeastern boundary of the Site. Page 4 of 8 current phase? b. Are EPSCs functioning correctly at all disturbed areas/material storage areas? c. Are EPSCs functioning correctly at outfall/discharge points such that there is no objectionable color contrast in the receiving stream, and no other water quality impacts? d. Are EPSCs functioning correctly at ingress/egress points such that there is no evidence of track out? e. If applicable, have discharges from dewatering activities been managed by appropriate controls? (permit section 4.1.3) If "No," describe below the measure to be implemented to address deficiencies. f. If construction activity at any location onsite has temporarily/permanently ceased, was the area 5. FIELD EVALUATION & PLAN IMPLEMENTATION The EPA Inspection Team observed sediment accumulation to the height of the silt fence in the southern, southwestern, western, and eastern portions of the Site [Refer to Appendix B, Photograph Log (Photographs 15-17, 19-22, and 25)]. At the time of the inspection, the Site's sediment basin was under construction, with two (2) of the four (4) planned inlets already constructed. With the sediment basin still being under construction, it was actively being used to collect surface flow from the Site, with no stabilization present along the No embankments. According to the EPSC, the sediment basin should have been completely constructed before being used to collect and treat stormwater [Refer to Appendix B, Photograph Log (Photographs 5-7, and 9)]. The EPA Inspection Team observed that the southwestern corner of the Site had sediment accumulation with no EPSCs present [Refer to Appendix B, Photograph Log (Photograph 18)]. No The EPA Inspection Team observed a constructed channel that went from the sediment basin pump to the Site's perimeter silt fence. The manmade channel's discharge point was being used as the outlet for the sediment basin pump. No pollutants were observed in the discharged waste at the time of the inspection [Refer to Appendix B, Photograph Log (Photographs 11 and 12)]. The Operator had not installed a stabilized construction entrance or other sediment control at the site entrance/exit off Fite Road[Refer to Appendix B, Photograph Log (Photograph 1)]. No Sediment track out was observed leaving from the Site onto Fite Road from the construction entrance/exit [Refer to Appendix B, Photograph Log (Photograph 1)]. The EPA Inspection Team observed one (1) pump at the sediment basin for the removal of excess water from the basin. The pump discharged to the southeast into a constructed channel, which Yes then discharges to an open field further southeast. No pollutants were observed in the discharged waste at the time of the inspection [Refer to Appendix B, Photograph Log (Photographs 10-12)]. No No temporary or permanent stabilization was observed during the inspection. Page 5 of 8 stabilized within 14 days? (permit section 3.5.3.2) If yes, describe below each location and measures taken to stabilize the area(s). g. Have pollution prevention measures been installed, implemented, and maintained to minimize the discharge of pollutants from wash waters, exposure of materials and discharges from spills and leaks per section 4.1.4? If "No," describe below the measure to be implemented to address deficiencies. h. If a concrete washout facility is located on site, is it clearly identified on the project and maintained? If "No," describe below the measures to be implemented to address deficiencies. i. Have all previous deficiencies been addressed? If "No," describe the remaining deficiencies in the Comments section. j. Silt Fences k. Storm Drain Inlet/Outlet Protection (Specify: Filter Fabric, Gravel Bags, etc.) 5. FIELD EVALUATION & PLAN IMPLEMENTATION The EPA Inspection Team did not observe any pollution N/A prevention measures since the Operator was not washing or servicing equipment or storing materials with the potential to spill or leak at the time of inspection. N/A No concrete washout facility was observed during the inspection. There was no Site representative or previous inspection report No documentation onsite; therefore, the EPA Inspection Team was unable to review previous inspection reports to identify previous deficiencies and corrective actions taken. Silt fences were observed installed at the site at the time of the inspection, but not at all identified locations in the EPSC plan. No Refer to the "Are all applicable EPSCs installed and maintained per the SWPPP per the current phase?" section for more information on the condition of the silt fences. One (1) inlet on the northwestern portion of the Site, between the northernmost wetland and the construction entrance off Fite No Road before the railroad crossing, was unprotected and was surrounded with accumulated sediment. The EPSC indicated that the inlet should have protection in the form of a mineral aggregate mound surrounding it [Refer to Appendix B, Page 6 of 8 5. FIELD EVALUATION & PLAN IMPLEMENTATION Photograph Log (Photograph 23)]. l. Construction Entrance & Exit Controls One (1) inlet in the center portion of the Site had sediment deposited over the silt fence protection and into the inlet. The EPSC plan indicated that the inlet protection is a mineral aggregate mound surrounding the inlet [Refer to Appendix B, Photograph Log (Photograph 8)]. The EPA Inspection Team observed one (1) construction entrance off Fite Road. However, this entrance was not identified in the Site EPSC Plans [Refer to Appendix B, Photograph Log No (Photograph 1)] [Refer to Appendix C, Exhibit Log (Exhibit 1)]. Moreover, the EPSCs observed at this site were not functioning to prevent sediment tracking from the Site onto Fite Road [Refer to Appendix B, Photograph Log (Photograph 1)]. m. Truck Wash Down Controls N/A A truck wash down area was not present at the Site at the time of the inspection. n. Concrete truck washout pit At the time of the inspection, concrete work was not being done N/A at the Site and no concrete washout pits were present at the inspection. o. Other Practices (e.g., fueling containment, control areas for maintenance, etc.) N/A None present at the time of the inspection. p. Proper Storage & Control of Construction Debris & The EPA Inspection Team observed one (1) partially covered lime Chemicals (i.e., sand, litter, No and dirt pile without erosion or sediment controls in the center of paint, solvents, petroleum, the Site [Refer to Appendix B, Photograph Log (Photograph 2)]. & etc.) 6. OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS Outfall, Stormwater Discharge & Receiving YES NO Water a. Number & location of stormwater N/A discharge(s)/outfall(s) consistent with the Plan The EPA Inspection Team, despite walking the perimeter of the Site, was not able to confirm the specific number and locations of stormwater outfalls because there was no on-site representative. b. Evidence of off-site accumulation of sediment observed in receiving water The EPA Inspection Team walked the perimeter of the Site and X observed no evidence of off-site accumulation of sediment within the receiving water during the inspection. c. Non-stormwater X discharge observed The EPA Inspection Team observed sediment discharge offsite in the southwestern, western, and eastern portions of the Site [Refer to Appendix B, Photograph Log (Photographs 17, 18, 19, and 20)]. Page 7 of 8 7. INSPECTION OBSERVATIONS AND AREAS OF CONCERN Observations CGP, Part 5.5.3.1.c. states "[i]f sediment escapes the permitted area, off-site accumulations that have not reached a stream must be removed at a frequency sufficient to minimize off-site impacts (e.g., sediment that has escaped a construction site and collected in a street must be removed so that it does not subsequently wash into storm sewers and streams during the next rain..." The EPA Inspection Team observed evidence of sediment discharge offsite [Refer to Appendix B, Photograph Log (Photographs 17, 18, 19, and 20)]. The construction entrances were not installed to the Structural Practices section in the SWPPP [Refer to Appendix C, Exhibit Log (Exhibit 2)]. The detail specifies clean stone sizes from 2 inches to 4 inches to a depth of at least 8 inches, underlain with geotextile fabric. The EPA Inspection Team observed one (1) construction entrance along Fite Road that was not stabilized [Refer to Appendix B, Photograph Log (Photograph 1)]. Sediment track out was observed leaving from the Site onto Fite Road from the construction entrance/exit [Refer to Appendix B, Photograph Log (Photograph 1)]. SWPPP, Page 11 states "Sediment must be removed from sediment traps, silt fences, sediment basins and other sediment controls when design capacity has been reduced by 50%." The EPA Inspection Team observed silt fence with sediment accumulation that reduced the capacity of the control by at least 50% [Refer to Appendix B, Photograph Log (Photographs 15-17, 19-22, and 25)] [Refer to Appendix C, Exhibit Log (Exhibit 2)]. Exit interview conducted with: N/A, no onsite Site representative was present to conduct an exit interview. Appendix A - Aerial Location Appendix B - Photograph Log Appendix C - Exhibit Log Page 8 of 8 Insurance Auto Auctions-Millington Inspection Report - Appendix A, Aerial Location Appendix A Aerial Location Inspection Date: July 10, 2024 Insurance Auto Auctions-Millington Inspection Report - Appendix A, Aerial Location Construction Entrance/Exit Outfall #1 Outfall #3 Outfall #4 Outfall #2 Figure 1. Aerial Image of the Insurance Auto Auctions-Millington project from Google Earth (Dated 2024). The yellow line is the approximate Site perimeter, and the blue lines are the inferred directions of stormwater flow due to grading of the Site. Page 1 of 1 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Appendix B - Photograph Log Insurance Auto Auctions - Millington All photos taken on a Nikon CoolPix AW110 Digital Camera by Taylor Fontaine Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Fite Road Photograph 1. View, facing northeast, of a Site entrance/exit off Fite Road. The entrance/exit did not have sediment controls, and sediment track out was observed leading from the Site onto Fite Road. Photograph 2. View, facing south, of a partially covered pile of lime and dirt in the center of the Site without erosion or sediment controls. Page 1 of 13 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Photograph 3. View, facing northwest, of corrugated piping that was being installed in the southern portion of the Site. Photograph 4. View, facing southeast, of a disturbed area and sediment basin (dotted yellow lines) in the southeastern portion of the Site. Page 2 of 13 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Photograph 5. View, facing southeast of the sediment basin in the southeastern portion of the Site. At the time of the inspection, the basin had not been stabilized, but was being utilized by the Permittee as a temporary basin during construction. Photograph 6. View, facing north, of a headwall and pipe leading into the basin shown in Photograph 5. At the time of the inspection, the stormwater piping had not been connected to this basin but had been connected to others. Page 3 of 13 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Photograph 7. View, facing southeast, inside the sediment basin shown in Photograph 5. Photograph 8. View of an inlet in the center of the Site where sediment had been deposited over the silt fence inlet protection and into the inlet. Page 4 of 13 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Photograph 9. View, facing northeast, of the basin shown in Photographs 4, 5, and 7. Sediment basin Photograph 10. View, facing southwest, of a pump removing water from the sediment basin. Page 5 of 13 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Photograph 11. View, facing southeast, of a manmade trench used for the discharge of the water pumped from the sediment basin. Photograph 12. Additional view, facing southeast, of the manmade channel (yellow outline) shown in Photograph 11. There was no evidence of sediment extending beyond the channel or offsite. Page 6 of 13 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Photograph 13. View, facing southwest, of sediment and vegetation against the perimeter silt fence in the southern portion of the Site. Photograph 14. View, facing east, of a raised inlet in the center of the Site. Page 7 of 13 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Photograph 15. View, facing southwest, of sediment accumulation against the silt fence along the Site's southern boundary. Sediment had accumulated to at least half the heigh of the silt fence. Photograph 16. View, facing south, of sediment accumulation against the silt fence in the southwestern portion of the Site. Silt fence in the area had separated from posts and required maintenance or reinstallation. Page 8 of 13 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Offsite Overtopping the silt fence Photograph 17. View, facing south, of sediment accumulation overtopping the silt fence in the southwestern portion of the Site. Photograph 18. View, facing west, of a lack of perimeter controls (e.g., silt fence) in the southwestern portion of the Site. Page 9 of 13 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Silt fence Photograph 19. View, facing north, of sediment accumulation overtopping the silt fence in the western portion of the Site. Photograph 20. View, facing east, of vegetation that had fallen and partially collapsed the silt fence on the eastern boundary of the Site. Page 10 of 13 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Wetland area Top of the silt fence Photograph 21. View, facing northeast, of sediment accumulation to the height of the silt fence in the western portion of the Site. Wetland area Top of the silt fence Photograph 22. View, facing northeast, of sediment accumulation to the height of the silt fence in the western portion of the Site. Page 11 of 13 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Photograph 23. View, facing southeast, of an inlet without any inlet protection to prevent sediment intrusion. Collapsed fence Photograph 24. View, facing southeast, of a collapsed silt fence along the Site's eastern boundary. Page 12 of 13 Inspection Date: July 10, 2024 Insurance Auto Auctions - Millington Inspection Report - Appendix B, Photograph Log Photograph 25. View, facing northeast, of the northern boundary of the Site. According to the Site EPSC Plan, the Site should have silt fence along the northeastern boundary of the site. However, at the time of the inspection, no silt fence was present. Page 13 of 13 Inspection Date: July 10, 2024