Document bB0eL5L4N3NjLkEKOOmo4aMV1

Inspection Date: Time: Media: Statute (s)/Program(s): Type of inspection: Access: Permittee Name: Facility or Site Name: Facility/Site Physical Address: (City, State, Zip Code) County/Parish: Permit and Application Number: SIC or NAICS: EPA Region 5: Enforcement and Compliance Assurance Division INSPECTION REPORT July 28, 2022 Inspection Announced: No Entry: 8:30 AM Exit: 10:00 AM Stormwater Clean Water Act, NPDES, Industrial Stormwater, Indirect Discharger CEI - Compliance Evaluation Inspection Granted Republic Services Republic Services 3950 Mississippi Avenue Cahokia Heights, Illinois 62206 St. Clair County ILR006145 4212 Flatebo, Theodore Digitally signed by Flatebo, Theodore Inspector Signature and Date:_________________________D_a_t_e:_2_0_2_2._0_8._1_8 _14_:_51_:_07__-0_5_'0_0'___ Approver Name and Title: Ryan J. Bahr, Section 2 Supervisor Water Enforcement and Compliance Assurance Branch Bahr, Ryan Digitally signed by Bahr, Ryan Approver Signature and Date: _________________________D_a_te_:_2_0_22_._08_._1_8_1_5:_4_2:_5_7_-0_5_'0_0_' _ Page 1 of 15 Republic Services July 28, 2022 Persons Participating in Inspection: Organization/Title Name Phone EPA, Environmental Engineer EPA, Environmental Engineer Illinois EPA, Inspector Republic Services, Operations Supervisor Republic Services, Operations Manager Ted Flatebo Ray Cullen Wayne Caughman Billy Prentice Aaron Campbell (312) 886-9402 (312) 996-0538 (618) 346-5120 (314) 744-8156 (618) 332-3220 Email flatebo.ted@epa.gov Present at Present at Opening Closing Conference Conference Yes Yes cullen.raymond@epa.gov Yes Yes wayne.caughman @illinois.gov Yes Yes bprentice Yes Yes @republicservices.com acampbell2 @republicservices.com No Yes TABLE OF CONTENTS I. II. III. IV. V. VI. VII. VIII. Introduction......................................................................................................2 Inspection.........................................................................................................3 Observations.......................................................................................................5 Records Review...................................................................................................5 Sampling Activities and Analytical Results.................................................................7 Areas of Concern.................................................................................................7 Closing Conference..............................................................................................9 List of Appendices................................................................................................9 SECTION I - INTRODUCTION Site Entry and Inspection Objectives U.S. Environmental Protection Agency Region 5 (EPA) inspectors Ted Flatebo and Ray Cullen, and Illinois Environmental Protection Agency (IEPA) inspector Wayne Caughman arrived at Republic Services (the "Site" or "Facility"), located at 3950 Mississippi Avenue, Cahokia Heights, Illinois at 8:30 AM on July 28, 2022 for an unannounced inspection. The two EPA inspectors and one IEPA inspector, will be collectively referred to as the inspection team. The inspection team presented their credentials to Mr. Prentice and informed him that this was an EPA inspection to determine compliance with the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) program. The inspection was conducted under the authority of the NPDES Page 2 of 15 Republic Services July 28, 2022 program and Section 308 of the CWA. The table above identifies the attendees who participated in the inspection. This report is based on information supplied by Facility representatives, observations made by the EPA inspectors, and records and reports maintained by the permittee, IEPA, and EPA. These include the following: direct observations made by the EPA inspectors, photographs taken by EPA inspectors, and verbal or written statements made or supplied by Facility representatives (the permittee) during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA inspectors by Facility representatives during or subsequent to the on-site inspection. In addition, information gathered prior to or subsequent to the inspection from a review of EPA, IEPA, and public records may be included in this report. During the opening conference, Mr. Prentice was asked if he considered any information to be confidential business information (CBI). Mr. Prentice stated that no information was considered CBI by the Facility. Background Information Prior to the inspection, EPA inspectors confirmed the following information: Storm water generated at 3950 Mississippi Avenue, Cahokia Height, Illinois is covered by IEPA general NPDES permit for storm water discharges from industrial activities No. ILR006145 (Permit). IEPA records indicate the Permit was issued to Allied Waste Services. The Permit places requirements on the Permittee regarding the storm water generated at the Facility. This general permit had an effective date of April 5, 2017, and the Permit was scheduled to expire on March 31, 2022. The Permit has been administratively extended by IEPA and was still active on the date of inspection. SECTION II - INSPECTION Opening Conference After the inspection team presented their credentials to Mr. Prentice, the team began the inspection opening conference at 8:30 AM. Mr. Prentice provided the following information: the Facility operates 24 hours per day, 7 days a week. The Facility operates two primary shifts, with a single employee working the overnight shift. The Facility serves as a trash truck depot for preventative maintenance, washing, fueling, and parking. The depot supports approximately 35-40 trucks, and the Facility has approximately 35 employees. Some empty roll off dumpsters are stored on site. Trucks and dumpsters are empty when they are at the Facility, refuse is disposed of at various landfills depending on the type of refuse collected. The Facility does have a Storm Water Pollution Prevention Plan (SWPPP) which was provided to the inspection team upon request. The SWPPP on site was dated June 2015 and revised in October 2017. Following the inspection, the Facility provided an updated SWPPP dated April 2022. Facility Walk Through After concluding the opening conference, EPA inspectors Mr. Flatebo and Mr. Cullen began the Facility walk through with Mr. Prentice. Mr. Caughman remained in the office and reviewed the SWPPP. Page 3 of 15 Republic Services July 28, 2022 The inspectors began in the truck washing area north of the fueling station. This area is not covered by a structure. The area has an oil-water seperator where wash water drains to. Mr. Prentice stated that the oil-water seperator is not connected to the sewer and is drained by a contractor when it is full. The April 2022 SWPPP states that the oil-water seperator is comprised of two tanks with capacities of 500 and 2,500 gallons. According to Richard Moreno, maintenance supervisor, trucks are washed weekly on Saturdays using a pressure washer stored in the building between the truck washing area and the fueling area. Truck washing is performed by a contractor. The Facility provided its two most recent hauling manifests for the oil-water seperator: July 19, 2022: 4,600 gallons of oily water June 4, 2021: 4,000 gallons of oily water Outside of truck washing, all maintenance activities are carried out in the maintenance building. Engine fluids are drained using a pit and fluid collection system. The system directs used fluids to their corresponding containers. There are multiple floor drains within the maintenance building, which according to Mr. Morena drain to the oil-water seperator. Mr. Moreno also stated that the floor scrubber used within the maintenance building disposes of its dirty water via the oil-water seperator. Within the maintenance building, there is a single room that stores all of the new and used engine fluids, the room itself acts as secondary containment and contains no floor drains. The April 2022 SWPPP identified the following fluid storage capacities: Used Motor Oil: Diesel Engine Oil: Hydraulic Fluid: Antifreeze: Used Antifreeze: Gear Oil: Transmission Fluid: Windshield Washer Fluid: 1000 gallons 560 gallons 560 gallons 275 gallons 275 gallons 275 gallons 175 gallons 300 gallons EPA inspectors observed a Facility employee dispose of dirty mop water on the ground in the parking lot. Inspectors discussed with Facility staff the best management practices for disposing of oily mop water. EPA inspectors then moved to the fueling area. The Facility has a 10,000 gallon underground diesel fuel storage tank. There is a single fuel pump station with two hoses attached. The fueling area is not covered by a structure. A spill kit is located in the building between the fueling area and the truck washing area. Mr. Prentice stated that each truck is equipped with a spill kit for use in the field as necessary. EPA inspectors then moved to the outdoor storage area for trucks and dumpsters. Inspectors observed both roll off dumpsters and front load dumpsters stored at the Facility. Mr. Prentice stated that the front load dumpsters of various sizes are not normally stored at this Facility and were being stored there on a temporary basis. When Page 4 of 15 Republic Services July 28, 2022 asked how stormwater is disposed of when it collects in open dumpsters, Mr. Prentice stated that the water is emptied onto the ground. In the truck parking area, stained soil was observed. Both the 2015 and 2022 SWPPPs state that there is a wastewater aeration system located at the Facility that treats wastewater and discharges it to a channel located southeast of the maintenance building. Following the inspection, EPA spoke to Joshua Allen, an environmental manager for Republic Services. Mr. Allen clarified that the aeration system treats sanitary wastewater generated at the Facility and discharges it to the channel southeast of the maintenance building. Mr. Allen confirmed that all process wastewater flows to the oil-water seperator where it is stored until it is hauled away by a contractor. SECTION III - OBSERVATIONS Observations may not be in sequential order. Unique Identifying No. TF-OB-001 Observation Fueling area does not have a structure to prevent stormwater contamination. TF-OB-002 TF-OB-003 The new/used fluid storage tanks in the maintenance building are not clearly labeled. There was stained soil in the truck parking area. TF-OB-004 A Facility employee disposed of oily mop water on the ground outside. TF-OB-005 The oil-water seperator was full. Area of Concern? Yes Yes Yes Yes Yes SECTION IV - RECORDS REVIEW Records may not be in sequential order. Page 5 of 15 Republic Services July 28, 2022 Unique Identifying No. TF-RR-001 TF-RR-002 TF-RR-003 TF-RR-004 TF-RR-005 TF-RR-006 TF-RR-007 TF-RR-008 TF-RR-009 TF-RR-010 TF-RR-011 TF-RR-012 TF-RR-013 TF-RR-014 Record Documentation required to be kept with the SWPPP was not available for review during the inspection. Documentation provided by the Facility after the inspection included: -Employee training records; and -April 2022 SWPPP. There is insufficient documentation to verify if the 2020 annual SWPPP inspection was conducted. The oil-seperator was emptied by a contractor on July 19, 2022 and on June 5, 2021, but the seperator was full on the date of inspection. The frequency of servicing by the contractor does not appear to be sufficient. The Facility did not submit a Notice of Intent (NOI) to IEPA for coverage under the 2017-2022 storm water general permit for industrial activities. The Facility provided insufficient documentation to verify if quarterly visual observations were made at each outfall. The Facility provided insufficient documentation to verify if any of the quarterly SWPPP inspections were not conducted within 72 hours of a 0.25 inch rain fall event. The quarterly SWPPP inspections provide comments such as "Yes," "No," and "Ok" in the comment section. It is not clear which question each response is related to. The quarterly SWPPP inspections provide an employee signature. Some of these signatures are not legible and no printed employee name is provided. The Facility provided insufficient documentation to verify if the annual inspection reports and SWPPP were submitted electronically to IEPA every year. IEPA records identify the Facility as owned and operated by Allied Waste Services. At the time of inspection, the Facility was operating under the name Republic Services. If there was a change in ownership, the Facility should have filed a Notice of Termination (NOT) with IEPA within 30 days. Inspectors observed soil staining in the truck parking area. There was no documentation in the SWPPP regarding a corrective action to clean up stained soil and to prevent future contamination. The April 2022 SWPPP states that all trash containers stored outdoors should be covered. Inspectors observed containers that were not covered. The April 2022 SWPPP does not contain information regarding the frequency, volume, or destination of truck wash water disposal. The Facility has a wastewater aeration system that treats sanitary wastewater and discharges it to a channel southeast of the maintenance building. Area of Concern? Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Page 6 of 15 Republic Services July 28, 2022 TF-RR-015 The Facility's SIC code 4212 is listed as an SIC requiring coverage in Subpart P No - Land Transportation and Warehousing of Appendix 1 of the Stormwater General Permit applicable to this Facility. SECTION V - SAMPLING AND ANALYTICAL RESULTS No samples were collected during this inspection. SECTION VI - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Unique Identifying No. TF-OB-001 Record Fueling area does not have a structure to prevent contamination of stormwater. TF-OB-002 Permit ILR006145, Section F.e.ii The new/used fluid storage tanks in the maintenance building are not clearly labeled. TF-OB-003 Permit ILR006145, Appendix 1, Section P.3.1.3 There was soil contamination in the truck parking area. TF-OB-004 Permit ILR006145, Section H.1.a A Facility employee disposed of oily mop water on the ground outside. TF-OB-005 Permit ILR006145, Section H.1.a The oil-water seperator was full. TF-RR-001 Permit ILR006145, Section F.2.viii Documentation required to be kept with the SWPPP was not available for review during the inspection. Documentation provided by the Facility after the inspection included: -Quarterly SWPPP inspections for the first two quarters of 2022; -Employee training records; and -Updated SWPPP (April 2022). TF-RR-002 Permit ILR006145, Section E There is insufficient documentation to verify if the 2020 annual SWPPP inspection was conducted. TF-RR-003 Permit ILR006145, Section G The oil-seperator was emptied by a contractor on July 19, 2022 and on June 5, 2021. The seperator was full on the date of inspection. The frequency of servicing by the contractor does not appear to be sufficient. Permit ILR006145, Section F.2.viii Page 7 of 15 Republic Services July 28, 2022 TF-RR-004 TF-RR-005 TF-RR-006 TF-RR-007 TF-RR-008 TF-RR-009 TF-RR-010 TF-RR-011 TF-RR-012 TF-RR-014 The Facility did not submit a Notice of Intent (NOI) to IEPA for coverage under the 20172022 storm water general permit. Permit ILR006145, Section D.1.a.i The Facility provided insufficient documentation to verify if quarterly visual observations were made at each outfall. Permit ILR006145, Section J The Facility provided insufficient documentation to verify if any of the quarterly SWPPP inspections were not conducted within 72 hours of a 0.25 inch rain fall event. Permit ILR006145, Section G.1 The quarterly SWPPP inspections provide comments such as "Yes," "No," and "Ok" in the comment section. It is not clear which questions these responses are related to. Permit ILR006145, Section G The quarterly SWPPP inspections provide an employee signature. Some of these signatures are not legible and no printed employee name is provided. Permit ILR006145, Section G.2.b The Facility provided insufficient documentation to verify if the annual inspection reports and SWPPP were submitted electronically to IEPA every year. Permit ILR006145, Section K.1 IEPA records identify the Facility as owned and operated by Allied Waste Services. At the time of inspection, the Facility was operating under the name Republic Services. If there was a change in ownership, the Facility should have filed a Notice of Termination (NOT) with IEPA within 30 days. Permit ILR006145, Section L.4.a Inspectors observed soil staining in the truck parking area. There was no documentation in the SWPPP regarding a corrective action to clean up stained soil and to prevent future contamination. Permit ILR006145, Section H.1.a The April 2022 SWPPP states that all trash containers stored outdoors shall be covered. Inspectors observed containers that were not covered. Permit ILR006145, Section E.9.a The Facility has a wastewater aeration system that treats sanitary wastewater and discharges it to a channel southeast of the maintenance building. 40 C.F.R. 402 Page 8 of 15 Republic Services July 28, 2022 SECTION VII - CLOSING CONFERENCE Closing Conference The inspection team held a closing conference with Facility personnel beginning at approximately 9:45 AM. During the closing conference, inspectors 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. The inspection team left the Facility at approximately 10:00 AM. SECTION VIII - LIST OF APPENDICES Appendix 1 - Photo Log Page 9 of 15 Republic Services July 28, 2022 Republic Services EPA Inspection July 28, 2022 All photos taken by Ted Flatebo, Environmental Engineer, U.S. EPA Camera: Ricoh WG-4 1: RIMG0070 Description: Truck washing area. Oil-water separator located underground, covered by gray covers in center of photo. Location: North of diesel pumping area. Camera Direction: East Date/Time: July 28, 2022, 8:58 AM Page 10 of 15 Republic Services July 28, 2022 2: RIMG0071 Description: Pressure washer used for truck washing. Location: Inside building between truck washing area and diesel pumping area. Camera Direction: North Date/Time: July 28, 2022, 8:59 AM 3: RIMG0072 Description: Floor drain in maintenace building. Drains to oil-water seperator. Location: Maintenance building. Camera Direction: West Date/Time: July 28, 2022, 9:06 AM Page 11 of 15 Republic Services July 28, 2022 4: RIMG0073 Description: Engine fluid collection system and maintence pit. Location: Mainteance buidling. Camera Direction: North Date/Time: July 28, 2022, 9:10 AM 5: RIMG0074 Description: Facility employee dissposed of mop water outside. Location: Mainteance building. Camera Direction: South Date/Time: July 28, 2022, 9:15 AM Page 12 of 15 Republic Services July 28, 2022 6: RIMG0075 Description: Overview of fluids storage area. Location: Maintance building. Camera Direction: Northwest Date/Time: July 28, 2022, 9:18 AM 7: RIMG0076 Description: Overview of fluids storage area. Location: Maintance building. Camera Direction: Southwest Date/Time: July 28, 2022, 9:18 AM Page 13 of 15 Republic Services July 28, 2022 8: RIMG0077 Description: Overview of diesel pumping area. Location: North of maintenace buidling. Camera Direction: North Date/Time: July 28, 2022, 9:22 AM 9: RIMG0078 Description: Roll off storage area. Note some containers are not covered. Location: Northwest corner of property. Camera Direction: Northwest Date/Time: July 28, 2022, 9:26 AM Page 14 of 15 Republic Services July 28, 2022 10: RIMG0079 Description: Dumpster storage area. Note some containers are not covered. Location: West end of property. Camera Direction: West Date/Time: July 28, 2022, 9:27 AM 11: RIMG0080 Description: Soil staining. Location: Truck parking area. Camera Direction: North Date/Time: July 28, 2022, 9:29 AM Page 15 of 15