Document ZBonL9rmG0Mdp2E665aoyzy0

REGION 6 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Time: Media: Statute(s)/Program(s): Type of inspection: Access: 02/15/2022 - 02/16/2022 Announced: No Entry: 09:15 AM (CT) Exit: 11:47 AM (CT) Water Clean Water Act, NPDES, Stormwater - Industrial CEI - Compliance Evaluation Inspection Granted Permittee Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) County/Parish: Facility GPS Coordinates: Mailing address: (If different) (City, state, zip code) HRP BROWNSVILLE HRP BROWNSVILLE 16200 JOSE GARZA RD BROWNSVILLE, TX 78521 25.966119, -97.369274 Facility/Site Identifier: Permit Number: SIC or NAICS: 110064287999 TXR05DF29 Persons Participating in Inspection: Title Name Lead Inspector EPA Inspector Kenneth AuBuchon Scott Rice Phone (281) 983-2151 Email aubuchon.kenneth@epa.gov Present at Opening Conf. Yes (304) 231-0501 rice.scott@epa.gov Yes SteelCoast President EHS Manager Mark Hodgson (956) 509-2031 mhodgson@steelcoastus.com Yes Felipe Ramirez (956) 509-2031 framirez@steelcoastus.com Yes VP-Marine Operations Project Accountant Chief Financial Officer EPA Inspector Mike Furgatch (956) 509-2031 mfurgatch@steelcoastus.com Yes Antonio Medrano Alberto Garcia (956) 509-2031783 (956) 509-2031 amedrano@steelcoastus.com Yes agarcia@steelcoastus.com Yes Jessica Schlafstein (912) 667-6492 schlafstein.jessica@epa.gov Yes 1 of 5 Present at Closing Conf. Yes Yes Yes Yes No No No No HRP BROWNSVILLE Inspection Date(s): 02/15/2022 - 02/16/2022 EPA Inspector - Angela Hays (214) 665-2285 hays.angela@epa.gov Yes No EPA Site Lead EPA Contractor Lydia Johnson lydia.johnson@erg.com Yes No OSHA Inspector Saul Charles Yes No OSHA Inspector Stephanie Dovalina Yes No Lead Inspector: Kenneth AuBuchon KENNETH AUBUCHON Digitally signed by KENNETH AUBUCHON DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=KENNETH AUBUCHON, 0.9.2342.19200300.100.1.1=68001003655902 Date: 2022.03.23 12:14:07 -05'00' REGION 6 aubuchon.kenneth@epa.gov Supervisor Review: Roberto Bernier ROBERTO BERNIER Digitally signed by ROBERTO BERNIER DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=ROBERTO BERNIER, 0.9.2342.19200300.100.1.1=68001003655586 Date: 2022.03.23 15:00:30 -05'00' REGION 6 bernier.roberto@epa.gov 2 of 5 HRP BROWNSVILLE Inspection Date(s): 02/15/2022 - 02/16/2022 SECTION I - INTRODUCTION Site Entry and Inspection Objectives REGION 6 Lead Inspector, Kenneth AuBuchon, arrived at the HRP BROWNSVILLE (the "Site" or "Facility"), located at 16200 JOSE GARZA RD, at 09:15 AM (CT) on 02/15/2022 for an unannounced inspection. REGION 6 Lead Inspector presented his/her credentials to Mike Furgatch and informed him/her that this was a REGION 6 inspection to determine compliance with the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permit program. The inspection was conducted under the authority of REGION 6 NPDES permit program, under the authority of the Federal CWA of Section 308. The table above identifies the attendees that participated in the inspection. This report is based on information supplied by HRP BROWNSVILLE representatives, observations made by the REGION 6 inspector, and records and reports maintained by the permittee and the REGION 6 including: direct observations made by the REGION 6 Inspector(s), photographs taken by REGION 6 inspector(s), physical evidence collected by the REGION 6 inspector(s), measurements taken by REGION 6 inspector(s), verbal or written statements made by information supplied by HRP BROWNSVILLE representatives(the permittee) during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the REGION 6 inspector(s) by HRP BROWNSVILLE representatives during or subsequent to the on - site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of USEPA, State, and public records may be included in this report. Facility/Site Description REGION 6 lead inspector confirmed the following facility information: HRP Brownsville, LLC dba Steel Coast is a ship recycling and scraps processing company with one of the largest and most technologically advanced reclamation, remediation, and recycling facilities located in North America. Located 16200 Jose Garza Rd. Brownsville, Texas on an 82-acre Facility on the North side of the Port of Brownsville, Texas, Steel Coast dismantles US Navy and Merchant Ships by evaluating each ship for hazardous materials and liquids before dismantling occurs on cutting pads and metal separation areas. Metals are separated by type and transported for off-site recycling. The Facility also provides automotive Industrial decommissioning as well as other industrial and commercial sources of recyclable metals. The facility coordinates are N 25 57' 52" Latitude and W 97 22' 12" Longitude. The facility is located in Cameron County. A Site Location Map and a Surface Drainage Diagram (Appendix A), of the Facility are provided. This Facility operates under the primary NAICS code of 423930 - Recyclable Materials Merchant Wholesalers and the primary SIC Code 5093 - Scrap and Waste Materials. The Facility operates 13 hours a day M-F (6 am to 7 pm) and 4 hrs on some Saturdays. Facility/Site Information Responsible official Name of the person engaging with the inspector Is the SWPPP team present Size of Facility Mark Hodgson Felipe Ramirez Yes 88 acres 3 of 5 HRP BROWNSVILLE Inspection Date(s): 02/15/2022 - 02/16/2022 Shifts/Hours/Days of 13 hours M-F 6am -7pm Operations/Shutdowns Is property owned or Leased (site is owned by Brownsville Navigation District) leased? Type of Operation Ship Recycling and Scrap process Industrial Sector/Sub- SIC 5093 sector Industrial activities exposed to stormwater Marine vessel dismantling and recycling, Torch cutting, metal scrapping and recycling, vehicle shredding BMPs/Stormwater Treatment See SWPPP Number/location of See SWPPP Stormwater Inlets/ Outfalls/Drains including near docks or storage areas and where they initially drain (MS4, ditch detention basin) Receiving Water Brownsville Ship Channel, Reach Basin: South Bay (Oyster Waters) Location(s) Location/Area/Sub-area Stormwater SWPPP Wastewater Description Discharge Locations listed in the SWPPP Discharge - Pretreatment Process SECTION II - OBSERVATIONS Observations may not be in sequential order. Location: Stormwater SWPPP Observation #: KA1-OB-001 Contains CBI: No Date: 02/15-16/2022 As part of the inspection, the Storm Water Pollution Prevention Plan (SWPPP) was reviewed for the effectiveness and implementation to protect storm water discharges. No areas of concern were noted with the SWPPP during this review. SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: SWPPP Ref #: KA1-RR-001 Reviewed By: Kenneth AuBuchon AOC: No Reviewed Date: 02/15-16/2022 4 of 5 HRP BROWNSVILLE Inspection Date(s): SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION V - AREAS OF CONCERN I observed no areas of concern at the time of the inspection. 02/15/2022 - 02/16/2022 SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The REGION 6 Lead Inspector held a closing conference with Facility personnel at 11:47 AM (CT) on 02/16/2022 for the inspection. During the closing conference, REGION 6 Lead Inspector discussed the observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. Follow Up No follow up was required after exiting the facility on 02/15/2022. I observed no follow up at the time of the inspection. Communication Log No additional information received by REGION 6 after exiting the Facility on 02/16/2022. 5 of 5