Document OzkDY47E7Jan6V4yazxVKVOG1

EPA REGION 10 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 03/25/2024 11:30 AM (PT) Announced: Yes 03/25/2024 02:40 PM (PT) Access: Granted 40F, Overcast Water Clean Water Act, NPDES, Stormwater - Industrial Compliance Evaluation Inspection Permittee Name Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Pacific Steel Group, Inc. Pacific Steel Group - Tacoma 401 E Alexander Avenue, Suite 407 Tacoma, Washington 98421 Pierce 47.279764, -122.410548 FRS ID Permit Number SIC NAICS WAT5886523624 WAR309612 3449 (Miscellaneous Metal Work) 332312 (Fabricated Structural Metal Manufacturing) Lead Inspector: RAYMOND ANDREWS Date: 2024.05.14 14:34:20 -07'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2024.05.14 14:38:17 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA Region 10 contreras.peter@epa.gov (206) 553-6708 Pacific Steel Group - Tacoma WAR309612 SECTION I - Opening Conference I arrived at the Pacific Steel Group - Tacoma (the "Site" or "Facility"), located at 401 E Alexander Avenue, Tacoma, Washington at 11:30 AM (PT) on 03/25/2024 for an announced inspection. I was accompanied by Nicolas Haddad, an Inspector in Training, who was there to observe inspection procedures. I presented credentials to Eric Benson, CEO, and David Perkins, Executive Vice President & General Counsel. I informed them I was there to conduct an inspection to determine compliance with the Clean Water Act (CWA) and the facility's Washington Department of Ecology's (WDOE) Industrial Stormwater General Permit (ISGP), permit # WAR309612. This report is based on information supplied by Mr. Benson and Mr. Perkins, direct observations made by me, and records and reports maintained by the facility. In addition, information gathered prior to, or after, the inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization EPA Region 10 EPA Region 10 Pacific Steel Group Pacific Steel Group Attendee Name Raymond Andrews Nicolas Haddad David Perkins Eric Benson Title Lead Inspector Inspector Executive VP General Counsel CEO Present in Opening Conf. Yes Yes Yes Yes Present in Closing Conf. Yes Yes Yes Yes Facility Information Responsible Official? David Perkins, Executive Vice President, d.perkins@pacificsteelgroup.com How long has the facility been in operation? Pacific Steel Group began operations on the site on June 3, 2019 What is the total area of the facility site? The facility's site covers approximately 2.25 acres. Is the site owned or The site is leased from the Port of Tacoma leased? What is the facility's The facility's receiving water is Blair Waterway which is an offshoot of receiving water? Commencement Bay. What percentage of The entire site is covered by buildings or asphalt. All industrial activities are the site is impervious performed in buildings or under cover. ground? How many employees does the facility have and what are its hours of operation? The facility has 15 full time employees and operates from 4:00am until 2:00pm, Monday through Friday. The facility is closed on weekends and holidays. 2 of 6 Pacific Steel Group - Tacoma WAR309612 WAR The facility conducts loading and unloading operations of dry bulk materials onto and off flatbed trailers. What is the facility's primary activities? Does the facility conduct, and document, routine inspections required by the permit? How many inlets, outfalls, and/or drains does the facility have? Does the facility analyze water samples in-house? How often does the facility conduct sampling? What is the contract lab's contact information? PSG Tacoma processes approximately 400 tons of rebar monthly. The rebar is bent and ground to different shapes per customer specifications or to meet the needs of the retail market. The processing of the rebar occurs in enclosed buildings or covered areas. Some of the equipment used in the process includes heaters, chillers, coilers, threaders, table benders, and shear lines. Eric Garth and Ron Ackles are the employees responsible for conducting and documenting the routine monthly visual inspections at the site. The facility has two catch basins on site. One is located near the north end of the warehouse, and the other is in a laydown yard. Both catch basins flow to a single outfall. All water sampling and analysis are contracted out. Sampling is conducted monthly by: Catchall Environmental 3221 Center St Tacoma, Washington 98409 (253) 572-0989 Water sample analysis is conducted by: Friedman & Bruya, Inc. Environmental Chemists 5500 4th Avenue South Seattle, Washington 98108 (206) 285-8282 SECTION II - Observations No observations were made that constitute an Area of Concern. SECTION III - Records Review Records may not be in sequential order. Record: Other - EPA's Integrated Compliance Information System (ICIS) Database AOC: Yes Ref #: RA1-RR-006 Reviewed Date: 03/19/2024 Pre-inspection I reviewed EPA's ICIS database for the period from March 2019 through February 2024. I found the facility failed to submit its 2021 Annual Report. I also found the facility failed to submit complete Discharge Monitoring Reports by the due date on five occasions. A table of the late DMRs is in Appendix 3. 3 of 6 Record: Laboratory Analysis Reports Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Pacific Steel Group - Tacoma WAR309612 WAR AOC: No Reviewed Date: 05/13/2024 Post Inspection, I reviewed laboratory analysis and chain of custody documents from January 2020 through December 2023. I did not note any Areas of Concern. Record: Annual Reports Ref #: RA1-RR-004 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 05/13/2024 Post inspection, I reviewed the facility's Annual Reports covering 2020, 2021, and 2022. The Annual Reports for 2020 and 2021 both have a signature date of March 23, 2024. The Annual Report for 2022 had an error. The report was signed by Mr. Anthony Encinias on May 16, 2023. Due to continued exceedances of some pollutant parameters, the facility was required to initiate Level 2 Corrective Actions. The error is the report gives a Level 2 Corrective Action completion date of November 23, 2011. Record: Other - Routine Facility Inspection Reports AOC: Yes Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 05/13/2024 Post inspection I reviewed routine facility inspection reports covering December 2020 through February 2024. The inspection reports appear to be complete; however, I noted many of the inspection reports had not been certified, as required, by a "Duly Authorized" individual. An example of an unsigned facility inspection report is included in Appendix 2 of this report. Record: Other - SWPPP Map AOC: Yes Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 03/25/2024 At the time of the inspection, I reviewed the facility site map in the Stormwater Pollution Prevention Plan (SWPPP). The map had a revision date of December 13, 2023. The map was missing the following required elements: the size of the property in acres; locations of all structural source control BMPs; locations of all stormwater conveyances; and locations and sources of run-on from adjacent properties that may contain pollutants. Record: SWPPP AOC: No Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 03/25/2024 At the time of inspection, I reviewed the facility's Stormwater Pollution Prevention Plan (SWPPP), dated December 2023. The SWPPP appeared to contain all required information except for certain elements missing from the SWPPP map. The map is addressed fully in another section of this report. 4 of 6 SECTION IV - Sampling Activities No sampling was conducted. Pacific Steel Group - Tacoma WAR309612 WAR SECTION V - Areas of Concern Areas of Concern may not be in sequential order. The presentation of Areas of Concern does not constitute a formal compliance determination or violation. AOC Reference #: RA1-RR-003 Records Review: Other - Routine Facility Inspection Reports Permit Requirement G2.A of the permit states, "All permit applications shall be signed: 1. In the case of corporations, by a responsible corporate officer. 2. In the case of a partnership, by a general partner of a partnership. 3. In the case of sole proprietorship, by the proprietor. 4. In the case of a municipal, state, or other public facility, by either a principal executive 5. officer or ranking elected official." G2.B of the permit states, in part, "All reports required by this permit and other information requested by Ecology shall be signed by a person described above or by a duly authorized representative of that person..." AOC: I noted many of the inspection reports had not been certified, as required, by a "Duly Authorized" individual. An example of an unsigned facility inspection report is included in this report. AOC Reference #: RA1-RR-002 Records Review: Other - SWPPP Map Permit Requirement S3.B of the permit states, "The SWPPP shall contain a site map, a detailed assessment of the facility, a detailed description of the BMPs, Spill Prevention and Emergency Cleanup Plan, and a sampling plan. The Permittee shall identify any parts of the SWPPP which the facility wants to claim as confidential business information. 1. The site map shall identify (site map may be multiple pages if needed): b. The size of the property in acres. e. Locations of all structural source control BMPs. i. Locations of all stormwater conveyances including ditches, pipes, catch basins, vaults, ponds, swales, etc. p. Locations and sources of run-on to your site from adjacent properties that may contain pollutants." AOC: The facility's SWPPP site map was missing the following required elements: the size of the property in acres; locations of all structural source control BMPs; locations of all stormwater conveyances; and locations and sources of run-on from adjacent properties that may contain pollutants. 5 of 6 AOC Reference #: RA1-RR-004 Records Review: Annual Reports Pacific Steel Group - Tacoma WAR309612 WAR Permit Requirement S9.C of the permit states, in part, "Permittees shall include the following information with each annual report. The Permittee shall...d. Describe the status of any Level 2 or 3 corrective actions triggered during the previous calendar year, and identify the date it expects to complete corrective actions." AOC: The Annual Report for 2022 had an error. The report was signed by Mr. Anthony Encinias on May 16, 2023. Due to continued exceedances of some pollutant parameters, the facility was required to initiate Level 2 Corrective Actions. The error is report gives a Level 2 Corrective Action completion date of November 23, 2011. AOC Reference #: RA1-RR-006 Records Review: Other - EPA's Integrated Compliance Information System (ICIS) Database Permit Requirement S9.C.1 of the permit states, in part, "The Permittee shall submit a complete and accurate Annual Report to the Department of Ecology no later than May 15th of each year..." AOC: I found the facility failed to submit its 2021 Annual Report. AOC Reference #: RA1-RR-006 Records Review: Other - EPA's Integrated Compliance Information System (ICIS) Database Permit Requirement Part S9.B of the permit states, "The Permittee shall submit sampling data obtained during each reporting period on a Discharge Monitoring Report (DMR) or a Solids Monitoring Form (SMR)8 form provided, or otherwise approved, by Ecology." AOC: I found the facility failed to submit complete Discharge Monitoring Reports by the due date on five occasions. A table of the late DMRs is in Attachment B. SECTION VI - Closing Conference I held a closing conference with facility personnel at 2:45 PM (PT) on 03/25/2024. During the closing conference, I discussed the observations and Areas of Concern identified during the inspection. I told the facility representatives the Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 3. Discharge Monitoring Report Table 6 of 6 APPENDIX 1: Photo Log All photos were taken by Lead EPA Inspector, Ray Andrews, during the inspection. Photos were not manipulated beyond minor cropping for sizing and labels or callouts to draw attention to the subject of the photo. All photos were taken with a government issued iPad through the SmartTools website and inserted directly into the photo log. Catch basis 1 with bio-char insert, photo 1 03/25/2024 12:26 PM (PT) No CBI No PII IMG-202403251226542654168998.jpg Photographer: Raymond Andrews Catch basis 1 with bio-char insert, photo 2 03/25/2024 12:27 PM (PT) No CBI No PII IMG-202403251227362736162913.jpg Photographer: Raymond Andrews Pacific Steel Group - Tacoma WAR309612 WAR Sampling Point 1 (SP1) in relation to covered work area IMG-202403251231163116148815.jpg 03/25/2024 12:31 PM (PT) No CBI No PII Photographer: Raymond Andrews Sampling Point 1 (SP1), close up 03/25/2024 12:31 PM (PT) No CBI No PII IMG-202403251231263126171754.jpg Photographer: Raymond Andrews Pacific Steel Group - Tacoma WAR309612 WAR Sampling Point 1 (SP1), open, showing bio-char 03/25/2024 12:32 PM (PT) No CBI No PII IMG-202403251232373237163896.jpg Photographer: Raymond Andrews Rebar stored outside in yard 03/25/2024 12:35 PM (PT) No CBI No PII IMG-202403251235483548116926.jpg Photographer: Raymond Andrews Pacific Steel Group - Tacoma WAR309612 WAR 1 of 4 catch basins in public thoroughfare maintained by port, photo 1 03/25/2024 12:37 PM (PT) No CBI No PII IMG-202403251237193719141966.jpg Photographer: Raymond Andrews 1 of 4 catch basins in public thoroughfare maintained by port, photo 2 03/25/2024 12:37 PM (PT) No CBI No PII IMG-202403251237393739137754.jpg Photographer: Raymond Andrews Pacific Steel Group - Tacoma WAR309612 WAR Outfall 03/25/2024 12:42 PM (PT) No CBI No PII IMG-202403251242394239166340.jpg Photographer: Raymond Andrews Pacific Steel Group - Tacoma WAR309612 WAR APPENDIX 2: Document Log Document Type Other - Routine Facility Inspection Report Annual Reports Annual Reports Document Name Contains CBI PSG_October 2021.pdf No Contains Uploaded By PII No Raymond Andrews Date Received 05/13/2024 2021 Annual Report - No No Raymond Andrews 05/13/2024 PSGT ISGP.pdf 2022 Annual Report - No No Raymond Andrews 05/13/2024 PSGT ISGP.pdf Industrial Stormwater General Permit Annual Report Form Permit No. WAR-309612 Site Name: PSG Tacoma Site County: Pierce Use this form to submit your annual report to Ecology. This form is not protected. Use your F11 key to maneuver through the fields. Attach corrective action documentation, and/or additional sheets if necessary. All facilities must submit a signed annual report each year on or before May 15th. Retain a copy of your submitted report onsite for Ecology review. 1. Benchmarks Exceeded This report is based on samples collected during calendar year 2021. Did you exceed the benchmark for any parameter during the above noted calendar year (Jan 1st - Dec 31st)? Note: If you sampled a parameter (other than pH or visible oil sheen) at a discharge point more than once during a quarter, the average of the sample results must be compared to the benchmark. Yes - Complete Sections 2 and 3 and sign and submit the form as described in Section 4. No - Complete Section 2, skip Section 3, and sign and submit the form as described in Section 4. Include any additional comments here: 2. Stormwater Problems Identified At the Facility Instructions: Based on the best available information, briefly describe any potential or actual stormwater pollution problem(s) you identified during the previous calendar year (Jan 1st - Dec 31st). Sources of available information may include (but may not be limited to): SWPPP reviews, audits made by consultants or providers of technical assistance, inspection reports or other notification made by federal/state/local authorities, visual observations, and/or your facility's monthly site inspections (selfinspections). For each problem identified, provide the date you discovered the problem (estimate if necessary). Do not include problems discovered through stormwater sampling. This information is covered in Section 3. Date Problem Discovered: Describe the Problem: Date Problem Discovered: Describe the Problem: Date Problem Discovered: Describe the Problem: Date Problem Discovered: Describe the Problem: ECY 070-382 (Rev. 01/2015) 3. Corrective Actions Planned or Taken Instructions: Complete this section for each pollutant parameter (e.g., turbidity, copper) that exceeded a benchmark during the previous calendar year (Jan 1st - Dec 31st). The permit requires you to identify the condition triggering the need for corrective action review. To do this, indicate below which quarters had a sample result that exceeded the benchmark. If more than one sample was taken at a sample location, indicate which quarters had an average sample result that exceeded the benchmark. Note: If you exceeded the benchmark for more than one parameter (e.g., turbidity and zinc), make additional copies of Section 3 and complete one for each parameter. Pollutant Parameter: 5 benchmarks (O&G, Lead, Turbidity, Zinc, Copper) were exceeded during the following quarters (check all that apply): 1st Quarter (January, February, March) 2nd Quarter (April, May, June) 3rd Quarter (July, August, September) 4th Quarter (October, November, December) Instructions: For the pollutant parameter above, summarize any Level 1, 2, or 3 corrective actions completed during the previous calendar year and include the dates you completed the corrective actions. Level 1 corrective action Describe the additional operational source control BMPs you implemented (Permit Condition S8.B): Inspect the storm drain inlet at the sample point prior to forecasted rain events. Sweep and/or vacuum visible sediment in surrounding areas prior to forecasted rain events. Date corrective action was completed: 5/5/2021 Level 2 corrective action Describe the additional structural source control BMPs you implemented (Permit Condition S8.C): Date corrective action was completed: Level 3 corrective action Describe the additional treatment BMPs you implemented (Permit Condition S8.D): Date corrective action was completed: Instructions: For the pollutant parameter listed above, describe the status of any Level 2 or 3 corrective actions triggered during the previous calendar year, but have not yet been completed. Identify the date you expect to complete corrective actions. Level 2 corrective action Describe the status of the corrective action: Date you expect to complete corrective action: Level 3 Corrective Action Describe the status of the corrective action: Date you expect to complete corrective action: ECY 070-382 (Rev. 01/2015) 4. Certification by Permittee "I certify under penalty of law that this document and all attachments were prepared under my direction, or supervision, in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." Anthony Encinias Pacific Steel Group 3-23-24 Printed Name Company Date Signature* *Note: Signature not required if the form is submitted electronically through the Water Quality Permitting Portal *Federal regulations require this report to be signed by the following person, or a duly authorized representative: A. In the case of corporations, by a responsible corporate officer. Note: Responsible Corporate Officer is defined on p.59 of ISGP: http://www.ecy.wa.gov/programs/wq/stormwater/industrial/ISGPFinal2015.pdf B. In the case of a partnership, by a general partner of a partnership. C. In the case of sole proprietorship, by the proprietor. D. In the case of a municipality, state, federal, or other public facility: by either a principal executive officer or ranking elected official. A person is a duly authorized representative only if: 1. The authorization is made in writing by a person described above and submitted to Ecology. 2. The authorization specifies either an individual or a position having responsibility for the overall operation of the regulated facility, such as the position of plant manager, superintendent, position of equivalent responsibility, or an individual or position having overall responsibility for environmental matters. Please upload the completed form to the Water Quality Permitting Portal: http://www.ecy.wa.gov/programs/wq/permits/paris/portal.html. Make sure you retain a copy for your records. Click on "Permit Submittals" Then, click on "My Permits", and Then, click on "Submittals". If you have any issues or questions, please contact Ecology's IT support staff at WQWebPortal@ecy.wa.gov or call 800-633-6193/Option 3 If you have questions about this form, contact the following Ecology staff: Location Contact Name Phone E-mail City of Seattle, and Kitsap, Pierce, and Thurston counties Josh Klimek 360-407-7451 josh.klimek@ecy.wa.gov Island, King, and San Juan counties Clay Keown 360-407-6048 clay.keown@ecy.wa.gov Adams, Asotin, Columbia, Ferry, Franklin, Garfield, Grant, Lincoln, Pend Oreille, Skagit, Snohomish, Spokane, Stevens, Walla, Whatcom, and Whitman counties. Shawn Hopkins 360-407-6442 shawn.hopkins@ecy.wa.gov Benton, Chelan, Clallam, Clark, Cowlitz, Douglas, Grays Harbor, Jefferson, Kittitas, Klickitat, Lewis, Mason, Okanogan, Pacific, Skamania, Wahkiakum, and Yakima counties. Joyce Smith 360-407-6858 joyce.smith@ecy.wa.gov To request materials in a format for the visually impaired, call the Water Quality Program at Ecology, 360-407-6600, Relay Service 711, or TTY 877-833-6341. ECY 070-382 (Rev. 01/2015) APPENDIX 3: Discharge Monitoring Report Table Pacific Steel Group - Tacoma WAR309612 WAR Late Discharge Monitoring Reports End Monitoring Period Due Date Date Received Dec 2021 2/15/2022 3/19/2022 Mar 2022 5/15/2022 6/16/2022 Jun 2022 8/15/2022 9/16/2022 Sep 2022 11/15/2022 12/17/2022 Dec 2022 2/15/2023 5/5/2023