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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 27, 2024 Entry: 2:50 PM Exit: 3:35 PM 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: Caribe Truck & Auto Parts Caribe Truck & Auto Parts Unpermitted at the time of the inspection Unknown by facility representatives 13000 Port Said Road Opa Locka, FL 33054 25.893077, -80.252996 13000 Cairo Lane Opa Locka, FL 33054 Miami Dade 8:00 AM - 5:00 PM (M - F); 8:00 AM - 1:00 PM (Sat); Closed (Sun) 4 Approximately 0.75 acres with approximately 0.6 acres of outdoor activity Little River Canal, approximately 1,000' south of the facility 2005 Onsite Representatives: Name: Efrain Velez Title: Owner Email: velazatruck@aol.com Authorized Official: Contacted? Yes No Name: Efrain Velez Title: Owner Email: velazatruck@aol.com Additional Personnel Participating in Inspection: Name: Andrea Velez Title: Manager Phone: 305-685-5949 Phone: 305-685-5949 Inspector(s): Kate Forsmark Kelsey Guy Rachel Olugbemi Jeremy Judd Inspection Report Author: Name: Kate Forsmark Title: Lead Inspector Inspector Physical Scientist Environmental Engineer Signature: Company: Eastern Research Group, Inc. Eastern Research Group, Inc. EPA Headquarters EPA Region 4 Date: March 22, 2024 Page 1 of 6 SECTION I - INTRODUCTION Caribe Truck & Auto Parts Stormwater Inspection 2/27/2024 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 27, 2024, a U.S. Environmental Protection Agency (EPA) contractor, Eastern Research Group, Inc. (ERG), conducted an industrial stormwater nonfiler inspection at Caribe Truck & Auto Parts located in Opa Locka Florida (facility). Rachel Olugbemi of EPA Headquarters, Jeremy Judd of EPA Region 4, and Kate Forsmark and Kelsey Guy of ERG (collectively, EPA Inspection Team) met with the facility representatives, Efrain Velez and Andrea Velez. 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 79F. According to precipitation data from the National Oceanic and Atmospheric Administration (NOAA)1, the Opa Locka, Florida area received no rain the day of or the day prior to the inspection. 2) Credentials presented to: Efrain Velez and Andrea Velez 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 X No Describe: The facility has a solid waste annual operating permit from Miami-Dade County's Department of Regulatory and Economic Resources' Division of Environmental Management (DERM). DERM conducted an inspection of the facility in 2022, focused on oil storage and spill management. 1Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Page 2 of 6 Caribe Truck & Auto Parts Stormwater Inspection 2/27/2024 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 operates as a vehicle dismantler which purchases vehicles (i.e., commercial trucks) from auction or from individuals who sell to the facility. The facility drains any remaining fluids, such as engine and hydraulic oil and antifreeze, from the vehicles. The facility removes tires, batteries, engines, transmissions, and other miscellaneous parts (i.e., doors). The engines and other used parts are either sold or exported and the metal from the vehicle bodies is sold for scrap. A third party collects and removes the fluids, tires, and batteries from the facility. 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 loads and unloads vehicles for dismantling, parts for resale, and metal scraps for a buyer onto trucks or customers' vehicles. The facility loads containers onsite to export used engines. Loading and unloading are done using one of the facility's four forklifts in the facility's yard near the entrance/exit (refer to Appendix B, Photograph 2). Industrial Manufacturing/ Processing Operations The facility dismantles commercial trucks to sell individual used parts. Dismantling occurs on an uncovered concrete pad in the center of the facility's yard (refer to Appendix B, Photograph 5). The facility sells scrap metals to a buyer who removes them from site. Industrial Machinery & Equipment Storage The facility has four forklifts used to load/unload materials and move vehicles/parts around the yard (refer to Appendix B, Photograph 3). The facility representatives stated they store the forklifts under the roofed area in the yard (refer to Appendix B, Photographs 3 and 9). Storage of Industrial Materials or Products The facility stores used vehicle parts throughout the facility's yard (refer to Appendix B, Photographs 5 through 9). The EPA Inspection Team observed that approximately half of the parts were stored without cover and would be exposed to stormwater. Parts stored without cover included engine parts that could be coated Page 3 of 6 with oil. Caribe Truck & Auto Parts Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted Liquid Storage (e.g., Tanks, Liquid Storage Drums) Pollutant Sources Waste Storage/Disposal Areas (solid and/or hazardous) Waste Treatment Facilities (e.g., Pretreatment Systems) Fueling Stations/Equipment Maintenance Areas & Cleaning Areas The facility stores 55-gallon drums of used oil under cover and in secondary containment (refer to Appendix B, Photograph 9). The EPA Inspection Team observed a tote containing used oil on shelving next to the containment with drums. The tote was under cover but not in secondary containment (refer to Appendix B, Photograph 9). The facility representatives stated fluids (i.e., oil and antifreeze) are drained on site and removed by a subcontractor. 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 one portable toilet centrally located at the yard (refer to Appendix B, Photograph 3) and one solid waste dumpster with a lid that was partially open (refer to Appendix B, Photograph and 8). Not observed or reported at the facility. Forklifts are fueled onsite in the covered area where fluids are stored (refer to Appendix B, Photographs 3 and 9). Sediment & Erosion Controls Approximately 50% of the ground surface at the facility is paved and the other 50% is compacted dirt and gravel. Spills/Leaks Handling Outside Shelters The EPA Inspection Team observed a pallet with at least seventeen bags of absorbent next to the office (refer to Appendix B, Photograph 10). Temporary (Date Established___________________) Permanent The facility has one permanent shelter on the facility's south perimeter used to store vehicle parts (engines and transmissions) and fluids (refer to Appendix B, Photographs 3 and 9), and one permanent shelter attached to the west end of the facility's office on the facility's north perimeter (refer to Appendix B, Photograph 10). Page 4 of 6 Evidence of nonstormwater sources/discharges (allowable if permitted under MSGP)? Caribe Truck & Auto Parts Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted Evidence of non-stormwater sources/discharges was not observed. Evidence of process wastewater sources/discharges? Evidence of process wastewater sources/discharges was not observed. OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS Number and description of each potential Stormwater Discharge Point from the Facility The perimeter of the facility is enclosed by a concrete block wall apart from the entrance/exit onto Port Said Road. The EPA Inspection Team observed that the entrance graded downward from Port Said Road towards the facility (refer to Appendix B, Photographs 2 and 12). The EPA Inspection Team did not observe any drains nor inlets on site. The facility representative stated that stormwater pools within the facility near the entrance/exit and also on Port Said Road, but stormwater does not cross the entrance. 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) None observed. None observed. 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 perimeter of the facility is enclosed by a concrete block wall, except for the facility's entrance/exit on Port Said Road (refer to Appendix B, Photographs 6, 7, and 11). The EPA Inspection Team observed the entrance graded down from Port Said Road (refer to Appendix B, Photographs 2 and 12). The EPA Inspection Team observed the remainder of the facility generally graded inward. The EPA Inspection Team observed pooled stormwater in the center of the facility (refer to Appendix B, Photograph 8). Port Said Road is graded south towards the Little River Canal, a distance of approximately 1,000 feet. The EPA Inspection Team observed storm drains along the road (refer to Appendix B, Photographs 13 and 14). Page 5 of 6 SECTION III - AREAS OF CONCERN Caribe Truck & Auto Parts Stormwater Inspection 2/27/2024 All photos taken by Kelsey Guy, ERG, unless otherwise noted 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. SECTION IV - LIST OF APPENDICES Appendix A - Aerial Location Appendix B - Photograph Log Page 6 of 6