Document b5DMgOQovj93O77goZae2NoGO

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: 9:10 AM Exit: 10:00 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: Rastro Unique Used Auto Parts Rastro Unique Used Auto Parts Unpermitted at the time of the inspection Unknown by facility representatives 1071 East 52nd Street Hialeah, FL 33013 25.870357, -80.261424 1071 East 52nd Street Hialeah, FL 33013 Miami-Dade 8:00 AM - 5:00 PM (M - F); 8:00 AM - 5:00 PM (Sat); Closed (Sun) 3 0.75 acres total, approximately 0.5 acres of outdoor activity Little River Canal Approximately 10 years Onsite Representatives: Name: Karla Sabat Title: Owner Phone: 305-681-8888 Email: rastrounique@gmail.com Authorized Official: Contacted? Yes No Name: Karla Sabat Title: Owner Phone: Email: 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 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 Signature: Date: March 22, 2024 Page 1 of 6 SECTION I - INTRODUCTION Rastro Unique Used Auto Parts 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 Rastro Unique Used Auto Parts located 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, Karla Sabat. 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 71F. 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: Karla Sabat 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 1Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Page 2 of 5 Rastro Unique Used Auto Parts Stormwater Inspection 2/28/2024 All photos taken by Kelsey Guy, 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...). The facility is an auto dismantler that purchases vehicles from auction. The vehicles are dismantled at the facility and the used parts are sold. Upon arrival at the facility, the vehicles are drained of any remaining fluids, engines and transmissions are removed, and other miscellaneous parts (i.e., doors, lights, mirrors) are disassembled from the vehicle. All parts are stored and sold at the facility. The facility sells vehicle bodies to scrap yards if the vehicle bodies are not sold. Other industrial facilities owned/operated by same business entity? Yes No Describe: N/A SECTION II - OBSERVATIONS Pollutant Sources 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? Loading/Unloading Operations The facility offloads incoming vehicles with forklifts; vehicles are both offloaded and temporarily stored adjacent to the entrance/exit on East 52nd Street (refer to Appendix B, Photographs 2, 3, and 6). The EPA Inspection Team observed unloading of vehicles at the facility at the time of the inspection. Industrial Manufacturing/ Processing Operations Industrial Machinery & Equipment Storage Vehicles are drained of fluids and dismantled for resale of individual parts. Dismantling takes place in an uncovered area in the southeast corner of the facility's yard (refer to Appendix B, Photograph 16). The facility has one propane forklift and one diesel forklift used for loading/unloading and moving vehicles and parts around the yard (refer to Appendix B, Photographs 6 and 8). Storage of Industrial Materials or Products The facility stores dismantled vehicles parts exposed to stormwater throughout the yard and under cover inside the facility's warehouse (refer to Appendix B, Photographs 9, 10, and 12 through 16). The facility stores parts until they are sold. Liquid Storage (e.g., Tanks, Liquid Storage Drums) The facility has a dedicated area in the northwest corner of the facility's yard for used vehicle fluid storage. The EPA Inspection Team observed three covered 55gallon drums labeled "only used oil" stored within secondary containment (refer to Appendix B, Photograph 11). Page 3 of 5 Pollutant Sources Waste Storage/Disposal Areas (solid and/or hazardous) Waste Treatment Facilities (e.g., Pretreatment Systems) Fueling Stations/Equipment Maintenance Areas & Cleaning Areas Rastro Unique Used Auto Parts Stormwater Inspection 2/28/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted 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? Not observed or reported at the facility. Not observed or reported at the facility. The diesel forklift is fueled onsite. The facility dismantles vehicles in an uncovered area in the southeast corner of the facility's yard on the west side of the warehouse (refer to Appendix B, Photograph 16). Sediment & Erosion Controls The entire facility is paved with concrete. Spills/Leaks Handling The EPA Inspection Team did not observe spill kits at the facility. Outside Shelters Temporary (Date Established___________________) Permanent Not observed or reported at the facility. Evidence of nonstormwater sources/discharges (allowable if permitted under MSGP)? Evidence of process wastewater sources/discharges? Evidence of non-stormwater sources/discharges was not observed. Not observed at the facility. OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS Number and description of each potential Stormwater Discharge Point from the Facility The EPA Inspection Team observed the northern perimeter of the facility was directly adjacent to the Little River Canal. The northern portion of the facility was above the canal (refer to Appendix B, Photograph 14). The facility's entrance/exit was graded south (refer to Appendix B, Photographs 4 and 8). The EPA Inspection Team observed a hole where garden hoses were run through in the facility's southern perimeter concrete block wall, downgradient of the southern Page 4 of 5 Rastro Unique Used Auto Parts Stormwater Inspection 2/28/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted portion of the facility (refer to Appendix B, Photographs 17 through 19). 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) Oil stains were visible within the facility and at the entrance (refer to Appendix B, Photographs 7 and 11). 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 facility's northern perimeter is directly adjacent to the Little River Canal (refer to Appendix B, Photograph 14). The facility's yard is generally sloped downward from north to south towards the southern perimeter. The facility's entrance/exit was graded south towards the road, which sloped towards the drain on East 52nd Street (refer to Appendix B, Photographs 4, 5, and 8). The hole in the southern perimeter's wall also was graded south towards the drain on East 52nd Street (refer to Appendix B, Photographs 17 through 19). Facility representatives stated that the drain was owned by the city, and that stormwater flows from the facility and from the street into the drain. SECTION III - AREAS OF CONCERN 1) The Inspection Team observed the facility was engaged in dismantling motor vehicles for the purpose of selling parts, an industrial activity classified under SIC Code 5015 - Motor Vehicle Parts, Used. 40 C.F.R. 122.26 regulates businesses classified under SIC Code 5015 for stormwater discharges associated with industrial activity. 2) The EPA Inspection Team observed the facility storing purchased vehicles delivered from auction outside of the facility uncovered and over a storm drain on East 52nd Street (refer to Appendix B, Photographs 4 and 5). Received vehicles are not drained of fluids before arrival at the facility. 3) The EPA Inspection Team did not observe a curb or other barrier to prevent facility stormwater from flowing to the Little River Canal along the facility's northern perimeter (refer to Appendix B, Photographs 12, 13 and 14). SECTION IV - LIST OF APPENDICES Appendix A - Aerial Location Appendix B - Photograph Log Page 5 of 5