Document g2gkvdygwOKrV42ZeBkvaqM7Q
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: 11:00 AM
Exit: 11:26 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:
Mejia Used Auto Parts Mejia Used Auto Parts None Unknown by facility representatives 5141 E 10th Court Hialeah, FL 33013 25.86954, -80.26180 5141 East 10th Court Hialeah, FL 33013 Miami-Dade County 8:00 AM - 5:00 PM (M - F); Closed (Sat & Sun) 6 0.32 acres total; 0.26 acres exposed Little River Canal, approximately 360' north of the facility Over 30 years
Onsite Representatives:
Name: Christian Chaviano
Title: Assistant Manager
Email: mejiaparts@gmail.com
Authorized Official:
Contacted? Yes No
Name: Carlos Taquero
Title: Owner
Email: mejiaparts@gmail.com
Additional Personnel Participating in Inspection:
Name: N/A
Title: N/A
Phone: 305-681-8154 Phone: 786-366-2403
Inspector(s): Kelsey Guy Kate Forsmark Rachel Olugbemi
Jeremy Judd
Henry Webster
Inspection Report Author: Name: Kelsey Guy
Title: Lead Inspector Inspector Inspector Inspector Inspector
Signature:
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Company: Eastern Research Group, Inc. Eastern Research Group, Inc. Environmental Protection Agency - HQ Environmental Protection Agency - Region 4 Florida Department of Environmental Protection
Date: May 21, 2024
SECTION I - INTRODUCTION
Mejia Used Auto Parts Stormwater Inspection 2/28/2024
All photos taken by Kelsey Guy and Kate Forsmark, 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 Mejia 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 representatives, Carlos Taquero and Christian Chaviano. 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 77F. 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: Carlos Taquero, Owner, and Christian Chaviano, Assistant Manager
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/).
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Mejia Used Auto Parts Stormwater Inspection 2/28/2024
All photos taken by Kelsey Guy and Kate Forsmark, 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 and reseller of vehicle parts. The facility purchases vehicles at auctions and the vehicles are delivered to the facility for dismantling and resale of the vehicle parts. The facility dismantles the vehicles under cover in the facility's dismantling area (refer to Appendix B, Photographs 4 and 5). The EPA Inspection Team observed stored parts, both covered and exposed, in the facility's yard (refer to Appendix B, Photographs 5 through 7, and 10).
Oil is drained from the transmissions and engines onsite in the covered dismantling area (refer to Appendix B, Photographs 4 and 5)
The facility uses a third party for refueling forklifts onsite, as needed.
Other industrial facilities owned/operated by same business entity? Yes No Describe: N/A
SECTION II - OBSERVATIONS
Pollutant Sources
Loading/Unloading Operations
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?
The facility has three forklifts used to load/unload vehicles delivered to the facility's rear entrance on East 10th Lane (refer to Appendix B, Photographs 7 and 8).
Industrial Manufacturing/
Processing Operations
The facility dismantles vehicles and resells vehicle parts. The facility has a vehicle dismantling area located in the yard's covered area where vehicle parts are removed and used vehicle fluids are drained (refer to Appendix B, Photograph 4).
Industrial Machinery & Equipment Storage
The facility had three propane forklifts in use at the time of the inspection (refer to Appendix B, Photograph 10). The facility representatives stated the three forklifts are stored without cover in the facility's yard.
A vehicle lift was in the covered vehicle dismantling area (refer to Appendix B, Photograph 4).
Storage of Industrial Materials or Products
Vehicles to be dismantled and dismantled vehicle bodies are stored in the facility's yard without cover (refer to Appendix B, Photographs 6, 7, and 10). The facility
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Mejia Used Auto Parts Stormwater Inspection 2/28/2024
All photos taken by Kelsey Guy and Kate Forsmark, ERG, unless otherwise noted
stored vehicle parts (i.e., car transmissions, engines, and doors) under cover in the facility's northwest corner (refer to Appendix B, Photograph 5).
Liquid Storage (e.g., Tanks, Liquid Storage Drums)
The EPA Inspection Team observed two fluid storage containers, one 55-gallon drum labeled "used antifreeze only" and one unlabeled 330-gallon poly tote, under cover in the facility's dismantling area, both without secondary containment (refer to Appendix B, Photographs 11 and 12). The facility representative stated the unlabeled poly tote stored used oil drained onsite, and a third party removes the used oil as needed.
Vehicles received at the facility are typically empty of coolant and antifreeze upon arrival, in the case they are not, the facility drains the vehicle fluids onsite in the dismantling area.
Pollutant Sources
Waste Storage/Disposal Areas (solid and/or hazardous)
Waste Treatment Facilities (e.g., Pretreatment Systems)
Fueling Stations/Equipment Maintenance Areas & Cleaning Areas
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?
The EPA Inspection Team observed a lidded trash can for general trash at the facility's main entrance (refer to Appendix B, Photograph 1).
None observed or reported at the facility.
The facility representatives stated the forklifts are powered by propane and refueled onsite by a third party.
Sediment & Erosion Controls
None observed or reported at the facility; the facility was fully paved.
Spills/Leaks Handling
Oil staining was observed on the ground surface throughout the facility (refer to Appendix B, Photographs 4, 7, 11, and 13). Spill kits were not observed.
Outside Shelters
Temporary (Date Established___________________) Permanent
The EPA Inspection Team observed a roofed area at the west end of the facility along East 10th Court (refer to Appendix B, Photographs 4 and 5). The roofed area covered the facility's vehicle dismantling area (refer to Appendix B, Photographs 11 and 12).
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Evidence of nonstormwater sources/discharges (allowable if permitted under MSGP)?
Evidence of process wastewater sources/discharges?
Mejia Used Auto Parts Stormwater Inspection 2/28/2024
All photos taken by Kelsey Guy and Kate Forsmark, ERG, unless otherwise noted
Evidence of non-stormwater sources/discharges was not observed during the inspection.
Evidence of process wastewater sources/discharges was not observed during the inspection.
OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS
Number and description of each potential Stormwater Discharge Point from the Facility
The eastern and western facility perimeters were enclosed by concrete block walls except for the entrances/exits. The EPA Inspection Team observed a shallow westward gradient from the facility's western end to East 10th Court (refer to Appendix B, Photographs 1 and 2) and a shallow eastward gradient from the facility's eastern end to East 10th Lane (refer to Appendix B, Photographs 7 and 8).
The northern and southern perimeters did not contain walls or curbing to prevent stormwater runoff to the neighboring properties.
The EPA Inspection Team did not observe any stormwater inlets onsite.
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)
Evidence of pollutants migrating offsite was not observed during the inspection.
Evidence of non-stormwater discharges leaving the 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.)
In the western portion of the facility's yard, the EPA Inspection Team observed the gradient of the ground surface sloped west towards East 10th Court (refer to Appendix B, Photograph 22), towards a stormwater inlet approximately 40' west of the entrance/exit (refer to Appendix B, Photographs 1 and 2).
On the east side of the facility's dismantling area, the EPA Inspection Team observed a gradient sloping east (refer to Appendix B, Photographs 7 and 8), towards East 10th Lane to a stormwater inlet approximately 20' southeast from the facility's eastern entrance/exit (refer to Appendix B, Photographs 8 and 15).
The stormwater inlets were located within the public right of way. The EPA Inspection Team did identify City owned stormwater inlets approximately 1500' west of the facility at State Road 953/E 8th Avenue using the Miami-Dady County
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Mejia Used Auto Parts Stormwater Inspection 2/28/2024
All photos taken by Kelsey Guy and Kate Forsmark, ERG, unless otherwise noted
Stormwater Line map2. The EPA Inspection Team observed the Little River Canal approximately 360' north of the facility. SECTION III - AREAS OF CONCERN 1) The Inspection Team observed the facility was engaged in dismantling motor vehicles for the purpose of selling parts. These activities are included in the description of 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 a pooled liquid with sheen near the hydraulic press and used vehicle fluids storage (refer to Appendix B, Photographs 4, 11, and 13). SECTION IV - LIST OF APPENDICES Appendix A - Aerial Location Appendix B - Photograph Log
2 https://gis-mdc.opendata.arcgis.com/datasets/MDC::stormwater-line/explore?location=25.870564%2C-80.261580%2C16.73
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