Document NN2qad0jOn0NKpon6Qn1gnzq8

U.S. EPA Headquarters Enforcement Division 1200 Pennsylvania Avenue NW, Washington, DC 20004 UNPERMITTED INDUSTRIAL FACILITY STORMWATER INSPECTION CHECKLIST Inspection Date Time Weather Conditions Media/Program February 28, 2024 Entry: 10:10AM Exit: 10:45 AM 70's and sunny Water - CWA 301, 402 - Industrial SW/NEC Operator Name: Facility or Site Name: Permit ID or Tracking #: SIC Code: Facility Address: (city, state, zip code) Geographic Coordinates: Mailing address: (city, state, zip code) County: Regular Days/Hours of Operation: # of Employees at location: Size of Facility (in acres): Receiving Water(s): Date facility est. @ location: 11th Avenue Auto and Truck Recyclers Inc. 11th Avenue Auto and Truck Recyclers Inc. Unpermitted at the time of the inspection Unknown by facility representatives 5166 E 11th Avenue & 5151 11th Avenue Hialeah, FL 33013 25.869285, -80.260962 5166 E 11th Avenue Hialeah, FL 33013 Miami-Dade 7:30 AM - 4:00 PM (Mon - Fri); Closed (Sat - Sun) 4 Approximately 1.5 acres total with approximately 1.1 acres of outdoor activity Little River Canal, approximately 400' north of the facility 1996 Onsite Representatives: Name: Arnold Diaz Title: Owner Phone: 305-687-0309 Email: arnold@autotruckrecyclers.com Authorized Official: Contacted? Yes No Name: Arnold Diaz Title: Owner Phone: 305-687-0309 Email: arnold@autotruckrecyclers.com Additional Personnel Participating in Inspection: Name: N/A Title: N/A Inspector(s): Kate Forsmark Kelsey Guy Rachel Olugbemi Jeremy Judd Henry Webster Inspection Report Author: Name: Kate Forsmark Title: Lead Inspector Inspector Physical Scientist Environmental Engineer Environmental Specialist I Signature: Page 1 of 6 Company: Eastern Research Group, Inc. Eastern Research Group, Inc. Environmental Protection Agency, Headquarters Environmental Protection Agency, Region 4 Florida Department of Environmental Protection, Southeast District Date: March 29, 2024 SECTION I - INTRODUCTION 11th Avenue Auto and Truck Recyclers Inc. Stormwater Inspection 2/28/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted Purpose of the Inspection The purpose of the inspection was to determine compliance with the industrial stormwater requirements under 301 and 402(p) of the CWA and its implementing regulations found at 40 CFR Part 122.26. The inspection was unannounced and consisted of interviewing facility representatives, recording field observations, and taking photographs to document site conditions throughout the facility at the time of the inspection. Opening Conference 1) Brief narrative documenting those present, introductions, presentation of credentials, and explanation of the purpose of the inspection. On February 28, 2024, a U.S. Environmental Protection Agency (EPA) contractor, Eastern Research Group, Inc. (ERG), conducted an industrial stormwater nonfiler inspection at 11th Avenue Auto and Truck Recyclers Inc. in Hialeah, Florida (facility). Rachel Olugbemi of EPA Headquarters, Jeremy Judd of EPA Region 4, Kate Forsmark and Kelsey Guy of ERG, and Henry Webster of Florida Department of Environmental Protection (collectively, EPA Inspection Team) met with the facility representative, Arnold Diaz. The EPA Inspection Team presented their credentials and explained that it was EPA's understanding that the facility did not have an industrial stormwater permit. The EPA Inspection Team explained they were onsite to conduct a Clean Water Act stormwater inspection which includes observing the current operations of the facility and assessing the potential for stormwater discharges from the facility. The weather at the time of the inspection was sunny and approximately 76F. According to precipitation data from the National Oceanic and Atmospheric Administration (NOAA)1, the Hialeah, Florida area received no rain the day of or the day prior to the inspection. 2) Credentials presented to: Arnold Diaz 3) Facility acknowledged receiving previous outreach materials or correspondence on Permit requirements? Yes No Describe: N/A 4) Facility has been individually notified by permit authority or EPA that it is subject to stormwater requirements? Yes No Describe: The facility has a solid waste annual operating permit from Miami-Dade County's Department of Regulatory and Economic Resources' Division of Environmental Management (DERM). FACILITY'S OPERATION & PRODUCT DESCRIPTION 1Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Page 2 of 6 11th Avenue Auto and Truck Recyclers Inc. Stormwater Inspection 2/28/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted Description of business and industrial activities occurring throughout the site. (Include operator's description and note any documentation that further establishes SIC code (permit applications, reports, business registries, website...). The facility is split into two locations on either side of 11th Avenue, the west yard (5166 E 11th Avenue) is on the west side of E 11th Avenue and the east yard (5151 E 11th Avenue) is directly across the street on the east side of E 11th Avenue (refer to Appendix A). The facility dismantles vehicles in each yard, with a focus on trucks and vans in the west yard and a focus on cars in the east yard. After dismantling, the facility sells the vehicles body parts, engines, and transmissions in the yard where they were dismantled. The facility purchases vehicles at auction which are delivered to their facility via truck. Once offloaded, vehicles are moved into areas under cover in each yard where they are drained of any fluids not already lost or drained, prior to purchase, by the facility. The engines, transmissions, tires, batteries, and other miscellaneous parts (i.e., lights, doors, mirrors) are removed and inventoried at the facility for resale. Vehicle bodies are stored outside in both yards until they are sold or scrapped. Per the facility's website (https://autotruckrecyclers.com/) they are an auto salvage facility that reuses most parts and sends the remainder of parts to a scrap recycler. Other industrial facilities owned/operated by same business entity? Yes No Describe: N/A SECTION II - OBSERVATIONS Pollutant Sources Loading/Unloading Operations SITE EVALUATION Note location, quantity/size, design issues, any O&M deficiencies (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are BMPs in place to minimize or eliminate stormwater discharges from industrial activities? The facility offloads vehicles (i.e., cars and trucks) bought at auction from delivery trucks on E 11th Avenue. The facility moves the vehicles via forklifts to the facility's eastern or western dismantling areas. Industrial Manufacturing/ Processing Operations The facility dismantles cars and trucks to resell the individual parts. Dismantling occurs undercover in both the east yard and the west yard (refer to Appendix B, Photographs 5, 6, 16, and 17). The facility drains used oil under cover in both yards. Typically, freon and coolant are drained from the vehicles before arrival at the facility, but occasionally the facility must drain these fluids which is done under cover in both yards. Industrial Machinery & Equipment Storage The facility has four forklifts that are stored under cover when not in use (refer to Appendix B, Photographs 6, 7, and 16). The forklifts are diesel and propane powered and are fueled onsite by a third party. Page 3 of 6 Storage of Industrial Materials or Products Liquid Storage (e.g., Tanks, Liquid Storage Drums) Pollutant Sources Waste Storage/Disposal Areas (solid and/or hazardous) Waste Treatment Facilities (e.g., Pretreatment Systems) Fueling Stations/Equipment Maintenance Areas & Cleaning Areas 11th Avenue Auto and Truck Recyclers Inc. Stormwater Inspection 2/28/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted The facility stores vehicle transmissions, engines, and body parts inside the warehouse, in the dismantling areas and in the yard (refer to Appendix B, Photographs 4 through 6, 8 through 12, and 17 through 19). Body parts are only stored for a few months, and if not sold in that time are scrapped. The facility stores used oil drained from vehicles' engines and transmissions under cover in the dismantling areas (refer to Appendix B, Photograph 4). Note location, quantity/size, design issues, any O&M deficiencies (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are BMPs in place to minimize or eliminate stormwater discharges from industrial activities? The facility stores used oil, freon, and coolant for disposal in the dismantling area, under cover and in secondary containment (refer to Appendix B, Photograph 4). Not observed or reported at the facility. The facility uses a third party to fuel the forklifts onsite. The facility does not have a dedicated area for fueling. Fuel is brought in via truck by the third party. Sediment & Erosion Controls Not observed at the facility; approximately half of the ground surface throughout the facility is paved. Spills/Leaks Handling Not observed at the facility. Outside Shelters Evidence of nonstormwater sources/discharges (allowable if permitted under MSGP)? Temporary (Date Established___________________) Permanent In the west yard of the facility, there is a covered area on the north where trucks are dismantled and drain fluids. The covered area is connected to the parts warehouse (refer to Appendix B, Photograph 6). In the east yard, there is a covered area on the north end for dismantling cars and storing parts (refer to Appendix B, Photographs 15 through 17). Evidence of non-stormwater sources/discharges were not observed during the inspection. Page 4 of 6 Evidence of process wastewater sources/discharges? 11th Avenue Auto and Truck Recyclers Inc. Stormwater Inspection 2/28/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted Evidence of process wastewater sources/discharges was not observed. OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS Number and description of each potential Stormwater Discharge Point from the Facility In the west yard, the EPA Inspection Team observed the west yard's entrance graded west, away from E 11th Avenue (refer to Appendix B, Photographs 7 and 13). The northwest corner of the yard was graded west towards E 10th Lane (refer to Appendix B, Photographs 21 and 22). The northwest corner of the facility is used for storing vehicle bodies that have undergone dismantling. The EPA Inspection Team observed that the east yard sloped east to west, through the yard's entrance/exit onto E 11th Avenue (refer to Appendix B, Photograph 15). Evidence of pollutants migrating offsite (stains, deposits, ponding) at discharge points, into Receiving Waters or in MS4 Evidence of Nonstormwater Discharges leaving site (authorized or unauthorized) Evidence of pollutants migrating offsite was not observed during the inspection. Evidence of non-stormwater discharges leaving site was not observed during the inspection. Description of general gradients/slopes onsite, all apparent discharge points, and discharge pathway from Facility to Receiving Water or MS4 (storm drains, channel, swale, ditches, driveway, pipes, & etc.) The east yard slopes east to west, towards the yard's entrance/exit onto E 11th Avenue, where a storm drain is located approximately 8 feet west of the facility's entrance/exit (refer to Appendix B, Photograph 15). The southern and northern perimeters of the east yard are enclosed by concrete block walls. The EPA Inspection Team observed pooling in two central locations at the facility's west yard (refer to Appendix B, Photographs 7 and 10). The facility did not have perimeter controls in the northwest portion of the facility and was graded west towards E 10th Lane. Two storm drains were observed to the west of the facility's west yard along E 10th Lane (refer to Appendix B, Photographs 21 and 22). The Little River Canal is located approximately 400 feet north of the facility. SECTION III - AREAS OF CONCERN 1) The EPA Inspection Team observed the facility storing and transporting wrecked and dismantled vehicles and vehicle parts. These activities are included in the description of SIC Code 5015 - Motor Vehicle Parts, Used. Businesses classified under SIC Code 5015 are regulated under 40 C.F.R. 122.26 for stormwater discharges associated with industrial activity. Page 5 of 6 11th Avenue Auto and Truck Recyclers Inc. Stormwater Inspection 2/28/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted 2) The EPA Inspection Team observed storm drains approximately 8 feet west of the facility's east yard entrance/exit. The facility did not have controls in place to prevent stormwater discharges from the site. SECTION IV - LIST OF APPENDICES Appendix A - Aerial Location Appendix B - Photograph Log Page 6 of 6