Document VGG7vj1KxEqBGaD82Z78ab6rZ

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 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: Onsite Representatives: May 16, 2024 Entry: 9:30 AM Entry: 10:20 AM 70F's and Sunny Water - CWA 301, 402 - Industrial SW/NEC Primstone LLC Primstone Design Center N/A. Unpermitted at the time of the inspection SIC Code 3281 - Cut Stone and Stone Products. 9410 E Mt Houston Rd Montgomery, TX 77356 29.891200, -95.249550 9410 E Mt Houston Rd Montgomery, TX 77356 Harris County 8:00 AM - 4:00 PM (M - F); Closed (Sat - Sun) 20 Approximately 3 acres total with approximately 2 acres of outdoor activity The nearest receiving water is the unnamed vegetated gravel swale located 150 feet southeast of the Facility 2004 Name: Freddie Hernandez Title: Facility Manager Phone: 281-827-9390 Email: N/A; no email provided Authorized Official: Contacted? Yes No Name: Charles Youssef Title: Owner Phone: 832-704-9598 Email: charles.youssef@primstonellc.com Additional Personnel Participating in Inspection: Name: N/A Title: N/A Inspector(s): Christopher Pardo Ryan Marrero-Vila 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 Name: Christopher Pardo Supervisor Review: Name: Signature: CPardo Signature: Page 1 of 6 Date: June 28, 2024 Date: 07/10/2024 Primstone LLC - Stormwater Inspection 5/16/2024 All photos taken by Christopher Pardo, ERG, unless otherwise noted 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 16, 2024, a U.S. Environmental Protection Agency (EPA) contractor, Eastern Research Group, Inc. (ERG), conducted an industrial stormwater non-filer inspection at Primstone LLC located in Montgomery, Texas (Facility). Ivy Koberlein of EPA Headquarters, Sharron Crayton of EPA Region 6, and Christopher Pardo and Ryan Marrero-Vila of ERG (collectively, EPA Inspection Team) met with the Facility representative, Freddie Hernandez. 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 78F. According to precipitation data from the National Oceanic and Atmospheric Administration (NOAA), the Montgomery, Texas area received no rain the day of and the day prior to the inspection. 2) Credentials presented to: Freddie Hernandez 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: N/A Page 2 of 7 Primstone LLC - Stormwater Inspection 5/16/2024 All photos taken by Christopher Pardo, ERG, unless otherwise noted 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...). Primstone LLC is a marble and granite countertop manufacturer that molds, shapes, and cuts marble and granite slabs into sinks and countertops for commercial and residential clients. Countertop manufacturing occurs inside the two (2) large warehouses located in the western portion of the Facility [refer to Appendix B, Photograph Log (Photographs 11, 46 and 48)]. In addition to cutting operations, the Facility washes marble and granite using water drawn from an onsite well [refer to Appendix B, Photograph Log (Photograph 17)]. Stone molds, uncut marble/granite, and finished countertops were stored inside the warehouses and outside on paved and unpaved areas [refer to Appendix B, Photograph Log (Photographs 1, 3, 4, 7, 9, 11-14, 46 and 48)]. Other industrial facilities owned/operated by same business entity? Yes 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 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? Loading and unloading operations occur on the paved concrete surface in the center of the Facility. The Facility unloads uncut granite and marble slabs from a semi-truck using one of the Facility's forklifts. The EPA Inspection Team observed Facility workers cutting raw marble and granite using wet saws inside the southern warehouse [refer to Appendix B, Photograph Log (Photograph 11)]. Shaping and finishing of marble and granite slabs occurs within the northern warehouse. The EPA Inspection Team observed two (2) forklifts for moving materials around the Facility. One (1) forklift was parked in the yard among uncut marble/granite slabs in the southern portion of the Facility [refer to Appendix B, Photograph Log (Photograph 12)]. Industrial stone cutting and fabricating equipment were located inside the southern warehouse [refer to Appendix B, Photograph Log (Photograph 11)]. The Facility stores uncut marble and granite slabs outside on a concrete pad and on grass in the center and southern portions of the Facility [refer to Appendix B, Page 3 of 7 Primstone LLC - Stormwater Inspection 5/16/2024 All photos taken by Christopher Pardo, ERG, unless otherwise noted Pollutant Sources 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? Photograph Log (Photographs 4, 7, 12-14, 46 and 48)]. All materials are stored uncovered. 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 Maintenance Areas & Cleaning Areas Sediment & Erosion Controls Spills/Leaks Handling Stone molds were also stored uncovered outside on wooden racks over the concrete pad and on grass in the center portion of the Facility [refer to Appendix B, Photograph Log (Photographs 1, 3, 6, 8, 9, 46 and 48)]. The EPA Inspection observed one (1) large black tank located at the northwest corner of the Facility's stormwater retention pond [refer to Appendix B, Photograph Log (Photograph 45)]. According to the Facility representative, this tank was filled with water for fire suppression. The EPA Inspection Team observed one (1) tank, measuring approximately 80gallons, at the southwestern corner of the Facility's stormwater retention pond. This tank, according to the Facility Representative, is a well pressure tank used for acquiring groundwater for marble and granite washing [refer to Appendix B, Photograph Log (Photograph 17)]. The EPA Inspection Team observed one (1) uncovered solid waste roll-off dumpster stored on the paved surface in the center of the Facility [refer to Appendix B, Photograph Log (Photographs 5 and 44)]. The dumpster contained cardboard debris, plastic bags, and fragmented stone slabs. None observed or reported at the Facility. None observed or reported at the Facility. Not applicable None observed or reported at the facility. Temporary (Date Established Unknown ) Permanent Outside Shelters Evidence of non- One (1) canopy tent measuring approximately 20 feet by 12 feet was observed between the two (2) large warehouses in the western portion of the Facility. Stone molds were stored underneath the black canopy tent [refer to Appendix B, Photograph Log (Photograph 6, 8, and 43)]. Evidence of allowable non-stormwater sources/discharges were not observed Page 4 of 7 Pollutant Sources stormwater sources/discharges (allowable if permitted under MSGP)? Evidence of process wastewater sources/discharges? Primstone LLC - Stormwater Inspection 5/16/2024 All photos taken by Christopher Pardo, ERG, unless otherwise noted 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? during the inspection. The EPA Inspection Team observed a process wastewater stream from the southern warehouse discharging offsite to the wooded area located to the southeast of the Facility via Discharge Point #2 [refer to Appendix B, Photograph Log (Photographs 18-24 and 26-34)]. The southern warehouse is used to cut marble and granite slabs. The process wastewater stream was turbid and white in color. The EPA Inspection Team observed white sediment accumulation on the vegetation along the flow path of the process wastewater stream. A second process wastewater outlet was observed at the southern warehouse [refer to Appendix B, Photograph Log (Photographs 38 and 39)]. Process wastewater from this outlet ponded adjacent to the warehouse and a thick layer of white sediment was observed immediately around the process wastewater outlet. The EPA Inspection Team observed a corroded/crumbling pipe exiting the southern warehouse with white sediment in and around the pipe [refer to Appendix B, Photograph Log (Photographs 24, 26, and 40-42)]. The EPA Inspection Team did not determine the intended function, or prior use, of this corroded/crumbling pipe. OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS The EPA Inspection Team observed Discharge Point #1 at the northernmost corner of the Facility's stormwater retention pond, which occupied the eastern portion of the site. According to the Facility representative, stormwater overflows the pond and discharges stormwater past the Facility fence line and into the wooded area located to the Facility's east side. [refer to Appendix B, Photograph Log Number and description (Photograph 47)]. The EPA Inspection Team observed ponded water within the of each potential wooded area which receives water from Discharge Point #1 [refer to Appendix B, Stormwater Discharge Photograph Log (Photographs 49-51)]. Point from the Facility The EPA Inspection Team additionally observed Discharge Point #2 within the wooded area located to the south of the Facility. One (1) observed process wastewater stream flowed from the southern warehouse for approximately 200 feet south into the wooded area [refer to Appendix B, Photograph Log (Photographs 18-24 and 26-34)]. Stormwater from the southwestern portion of Page 5 of 7 Primstone LLC - Stormwater Inspection 5/16/2024 All photos taken by Christopher Pardo, ERG, unless otherwise noted OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS the Facility would commingle with the process wastewater stream and flow southward and offsite into the wooded area. Evidence of pollutants migrating offsite (stains, deposits, ponding) at discharge points, into receiving waters or in MS4 The EPA Inspection Team observed process wastewater flowing from the southern warehouse to the south and outside the Facility border through Discharge Point #2. The process wastewater flowed approximately 200 feet offsite before discharging into a swampy wooded area south of the Facility. The EPA Inspection Team observed white sediment accumulation along the flow path of this process wastewater stream and within the wooded area located to the south of the Facility [refer to Appendix B, Photograph Log (Photographs 18-24 and 26-34)]. Evidence of Nonstormwater Discharges leaving site (authorized or unauthorized) The EPA Inspection Team observed evidence of an unauthorized process wastewater stream from the southern warehouse exiting the Facility through Discharge Point #2 and flowing approximately 200 feet into the swampy wooded area located south of the Facility [refer to Appendix B, Photograph Log (Photographs 26-29)]. The EPA Inspection Team observed the Facility graded southeast towards the 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.) stormwater retention pond and the swampy wooded area located to the southeast of the Facility. Stormwater from the retention pond would flow through Discharge Point #1 into the wooded area located to the east of the Facility [refer to Appendix B, Photograph Log (Photograph 47)]. Stormwater and commingled process wastewater would flow through Discharge Point #2 in the wooded area located to the south of the Facility [refer to Appendix B, Photograph Log (Photographs 18-24 and 26-34)]. Based off the observed slope of the entire area, stormwater and process wastewater which discharged into the swampy wooded area would potentially convey further southeast as overland flow towards an unnamed vegetated gravel swale located next to train tracks to the southeast of the Facility [refer to Appendix B, Photograph Log (Photographs 49-53)]. SECTION III - AREAS OF CONCERN 1) The EPA Inspection Team observed the facility engaged in manufacturing marble and granite countertops. The Facility's industrial activities include molding, shaping, and cutting marble and granite slabs into sinks and countertops. The EPA Inspection Team observed outdoor industrial activities consisted of storage of raw and cut granite and marble, rock molds, and loading/unloading operations. These activities are included in the description of SIC Code 3281 - Cut Stone and Stone Products. Businesses classified under SIC Code 3281 are regulated under 40 C.F.R. 122.26 for stormwater discharges associated with industrial activity. 2) The EPA Inspection Team observed two (2) discharge points. a. Discharge Point #1 was the overflow from the on-site stormwater retention pond to the wooded area to the east of the Facility [refer to Appendix B, Photograph Log (Photograph 47)]. b. Discharge Point #2 had an active discharge of turbid process wastewater during the inspection [refer to Appendix B, Photograph Log (Photographs 18-23 and 26-29)]. The turbid process Page 6 of 7 Primstone LLC - Stormwater Inspection 5/16/2024 All photos taken by Christopher Pardo, ERG, unless otherwise noted wastewater originated in the Facility's southern warehouse where granite and marble are cut with wet saws. 3) The EPA Inspection Team observed white dust from the cutting operations outside on the paved concrete pad in the center of the Facility. This layer of white dust was located approximately 50 feet upgradient from the onsite stormwater retention pond [refer to Appendix B, Photograph Log (Photographs 6, 8, and 43)]. 4) At the time of the inspection, the Facility did not have coverage under the 2021 Multi-General Stormwater Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity. 5) At the time of the inspection, the Facility also did not have coverage under a Texas Pollutant Discharge Elimination System (TPDES) permit for discharges associated with process related wastewater and/or process related storm water. SECTION IV - LIST OF APPENDICES Appendix A - Aerial Location Appendix B - Photograph Log Page 7 of 7