Document QJEvMgJamO8Bp2Z0zoy9MEzRL

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 May 17, 2024 Entry: 9:15 AM Exit: 10:00 AM 75 F 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: JCV Recycling JCV Recycling N/A; No permit at the time of the inspection 5093 - Scrap and Waste Materials 2400 Hopper Road Houston, TX 77093 29.879283, -95.348583 2400 Hopper Road Houston, TX 77093 Harris County 8:00 AM - 7:00 PM (Monday - Friday), 8:00 AM - 5:30 PM (Saturday); Closed (Sunday) 4 Approximately 0.4 acres total with approximately 0.34 acres of outdoor activity The closest surface waterbody, according to the Texas Commission on Environmental Quality's (TCEQ) Surface Water Quality Segments Viewer is Halls Bayou located approximately 0.28 miles east of the Facility. The closest receiving waterbody, the stormwater conveyance running along the Facilities western perimeter, is the Houston MS4. 2019 Onsite Representatives: Name: Jose Vasquez Title: Owner Phone: (713) 933-4647 Email: scrapmetal_jcv@hotmail.com Authorized Official: Contacted? x Yes No Name: Jose Vasquez Title: Owner Phone: (713) 933-4647 Email: scrapmetal_jcv@hotmail.com Additional Personnel Participating in Inspection: Name: N/A Title: N/A Inspector(s): Taylor Fontaine Mariah Papac Ivy Koberlein Sharron Crayton Inspection Report Author: Title: Lead Inspector Inspector Inspector Inspector Company: Eastern Research Group, Inc. Eastern Research Group, Inc. Environmental Protection Agency, Headquarters Environmental Protection Agency, Region 6 Page 1 of 6 Name: Mariah Papac Supervisor Review: Name: Signature: Signature: JCV Recycling - Stormwater Inspection 5/17/2024 All photos taken by Taylor Fontaine, ERG Date: June 4, 2024 Date: 07/10/2024 SECTION I - INTRODUCTION 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 Clean Water Act (CWA) and its implementing regulations found at 40 Code of Federal Regulations (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 May 17, 2024, a U.S. Environmental Protection Agency (EPA) contractor, Eastern Research Group, Inc. (ERG), conducted an industrial stormwater non-filer inspection at JCV Recycling located in Houston, Texas (Facility). Ivy Koberlein of EPA Headquarters, Sharron Crayton of EPA Region 6, and Taylor Fontaine and Mariah Papac of ERG (collectively, EPA Inspection Team) met with the Facility representative, Jose Vasquez. 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 CWA 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 cloudy and approximately 75F. According to precipitation data from the National Oceanic and Atmospheric Administration (NOAA)1, the Houston, Texas area received 1.16 inches of rain the day prior to the inspection and 0.01 inches of rain the day of the inspection. 2) Credentials presented to: Jose Vasquez 3) Facility acknowledged receiving previous outreach materials or correspondence on Permit requirements? Yes x No Describe: N/A 4) Facility has been individually notified by permit authority or EPA that it is subject to stormwater requirements? Yes x No Describe: N/A 1Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Page 2 of 6 JCV Recycling - Stormwater Inspection 5/17/2024 All photos taken by Taylor Fontaine, ERG FACILITY'S OPERATION & PRODUCT DESCRIPTION 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...). JCV Recycling is a scrap metal recycling facility. The Facility accepts ferrous and nonferrous metals including but not limited to vehicles and vehicle parts, appliances, and cables, as well as used batteries and car parts from commercial and public sources. Materials are sorted, processed, and sold as scrap to commercial and public customers. Other industrial facilities owned/operated by same business entity? Yes x No Describe: N/A SECTION II - OBSERVATIONS Pollutant Sources Loading/Unloading Operations Industrial Manufacturing/ Processing Operations Industrial Machinery & Equipment Storage Storage of Industrial Materials or Products Liquid Storage (e.g., Tanks, Liquid Storage Drums) Waste Storage/Disposal Areas (solid and/or hazardous) Waste Treatment Facilities (e.g., Pretreatment Systems) Fueling Stations/Equipment SITE EVALUATION Note location, quantity/size, design issues, any operation and maintenance (O&M) deficiencies (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are Best Management Practices (BMPs) in place to minimize or eliminate stormwater discharges from industrial activities? The Facility unloads scrap metal from commercial and public sources in the northern portion of the Facility. Once sorted and processed, the products are placed under cover in cardboard boxes and on wooden pallets for customer pickup. The Facility sorts the metals based on type (i.e., copper) and product (i.e., engines) for recycling. Materials containing fluids are drained, categorized, and sorted for customer pickup. The Facility has a forklift and an excavator for moving materials around the Facility. Equipment is located throughout the Facility [refer to Appendix B, Photograph Log (Photographs 10 and 19)]. The Facility stores scrap metals throughout the property. Materials are stored in uncovered piles and are exposed to stormwater [refer to Appendix B, Photograph Log (Photographs 1 through 4, 8, 12, 18, 19, 21, and 22)]. The Facility stores liquids drained from received vehicles and engines inside an enclosed shed. The EPA Inspection team observed sheen on pooled stormwater adjacent to the liquid storage shed [refer to Appendix B, Photograph Log (Photograph 4)]. The Facility has a solid waste dumpster for general solid waste [refer to Appendix B, Photograph Log (Photograph 22)]. None observed or reported at the Facility. None observed or reported at the Facility. Page 3 of 6 Pollutant Sources Maintenance Areas & Cleaning Areas Sediment & Erosion Controls Spills/Leaks Handling Outside Shelters Evidence of nonstormwater sources/discharges (allowable if permitted under MSGP)? Evidence of process wastewater sources/discharges? JCV Recycling - Stormwater Inspection 5/17/2024 All photos taken by Taylor Fontaine, ERG SITE EVALUATION Note location, quantity/size, design issues, any operation and maintenance (O&M) deficiencies (including the nature and extent), potential pollutants, and evidence of exposure to stormwater. Are Best Management Practices (BMPs) in place to minimize or eliminate stormwater discharges from industrial activities? The EPA Inspection Team observed that the ground surface throughout the Facility was partially paved [refer to Appendix B, Photograph Log (Photographs 10 through 12, 15 through 17, and 19)]. The perimeter areas, the southwestern corner, and the northern driveway area are gravel [refer to Appendix B, Photograph Log (Photographs 1 through 5, 8, 9, 13, 17, 18, and 20 through 23)]. The EPA Inspection Team observed discolored stormwater, sheens on pooled stormwater, and staining on the ground surface [refer to Appendix B, Photograph Log (Photograph 4, 6, 9 through 12, and 15 through 17)]. Spill kits were not observed or reported at the Facility. Temporary (Date Established___________________) Permanent None observed or reported at the facility. Evidence of non-stormwater sources/discharges was not observed during the inspection. None observed. OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS The EPA Inspection Team observed one (1) stormwater discharge point from the Facility: 1) The discharge point was along the western perimeter of the Facility behind Number and description of each potential Stormwater Discharge Point from the Facility the main building. The EPA Inspection Team observed a discrete stormwater pathway leading from the Facility under the fence along the western perimeter [refer to Appendix B, Photograph Log (Photographs 7, 24, and 26 through 28)]. 2) The flow pathway led to a Houston MS4 stormwater conveyance outside the Facility [refer to Appendix B, Photograph Log (Photographs 24, 25, and 28 through 30)]. The stormwater conveyance flows north where it discharges into a swale that flows into Halls Bayou. Evidence of pollutants The EPA Inspection Team did not observe evidence of pollutants migrating offsite Page 4 of 6 JCV Recycling - Stormwater Inspection 5/17/2024 All photos taken by Taylor Fontaine, ERG OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS migrating offsite (stains, into receiving waters or an MS4. deposits, ponding) at discharge points, into receiving waters or in MS4 Evidence of Non- stormwater Discharges Evidence of non-stormwater sources/discharges was not observed during the leaving site (authorized or inspection. unauthorized) Description of general gradients/slopes onsite, all apparent discharge points, and discharge The EPA Inspection Team observed that the ground surface throughout the Facility was primarily gravel, except for the paved center portion of the Facility [refer to Appendix B, Photograph Log (Photographs 1 through 5, 8 through 13, 15, and 17 through 23)]. pathway from Facility to Receiving Water or MS4 (storm drains, channel, swale, ditches, driveway, pipes, & etc.) The EPA Inspection Team observed the Facility to be graded slightly towards the north and west. Stormwater had the potential to flow north and west. A discrete stormwater discharge point was observed under the western Facility perimeter where it discharged into a Houston MS4 stormwater conveyance channel. SECTION III - AREAS OF CONCERN 1) At the time of the inspection, the EPA Inspection Team identified the following at the Facility: a. The Facility is engaged in scrap metal recycling (SIC Code 5093 - Scrap and Waste Materials). SIC Code 5093 is regulated under 40 C.F.R. 122.26 for stormwater discharges associated with industrial activity. b. The Facility's outdoor areas were used for industrial activities including storage of scrap parts/materials. c. At the time of the inspection, the Facility did not have coverage under the 2021 MSGP for Stormwater Discharges Associated with Industrial Activity. d. Facility stormwater, from areas used for industrial activities, discharges to a stormwater conveyance channel that flows along the western Facility perimeter. The EPA Inspection Team observed a discrete stormwater flow path from the Facility to the offsite stormwater conveyance channel. 2) The EPA Inspection Team observed discolored stormwater and a sheen on pooled stormwater throughout the Facility [refer to Appendix B, Photograph Log (Photograph 4, 10 through 12, and 15 through 17)]. 3) The EPA Inspection Team observed staining on the ground surface throughout the Facility [refer to Appendix B, Photograph Log (Photographs 6 and 9)]. A spill kit was not observed or reported at the Facility. 4) The EPA Inspection Team observed nine 55-gallon drums containing unknown substances without lids and exposed to stormwater [refer to Appendix B, Photograph Log (Photographs 13 and 14)]. Page 5 of 6 JCV Recycling - Stormwater Inspection 5/17/2024 All photos taken by Taylor Fontaine, ERG 5) The EPA Inspection Team observed bags of ceramic glue in the northeast corner of the facility that were uncovered and exposed to stormwater [refer to Appendix B, Photograph Log (Photograph 22)]. SECTION IV - LIST OF APPENDICES Appendix A - Aerial Location Appendix B - Photograph Log Page 6 of 6