Document jZN4w6GGXqMwNOjvZR59nKgR
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4
ATLANTA FEDERAL CENTER 61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
ELECTRONIC EMAIL CONFIRMATION OF EMAIL RECEIPT REQUESTED
Ms. Julie Smoak Environmental Manager Toyota Tsusho America 702 Triport Road Georgetown, Kentucky 40324 Julie_Smoak@taiamerica.com
Re: Compliance Evaluation Inspection Report NPDES Permit No. KY0110060
Dear Ms. Smoak:
The U.S. Environmental Protection Agency, Region 4 and the Kentucky Division of Water conducted a Compliance Evaluation Inspection (CEI) of the Toyota Tsusho America, Inc. industrial storm water system on July 28, 2021. The objective of the inspection was to assess the permittee's compliance with the Clean Water Act and the National Pollutant Discharge Elimination System (NPDES) permit. The inspection results have been summarized in the enclosed CEI Report.
The EPA appreciates your cooperation. If you have specific questions about the inspection report, please contact Brad Ammons at (404) 562-9769 or via email at ammons.brad@epa.gov. Please verify receipt of this letter and report by emailing Mr. Ammons at the email address provided.
Sincerely,
JAIRO
Digitally signed by JAIRO CASTILLO
CASTILLO
Date: 2021.10.20 16:12:46 -04'00'
Jairo Castillo, P.E., Chief
Wastewater Enforcement Section
Water Enforcement Branch
Enclosure
cc: Constance Coy, constance.coy@ky.gov Kentucky Division of Water
Internet Address (URL) http://www.epa.gov
United States Environmental Protection Agency Region 4 Enforcement and Compliance Assurance Division Water Enforcement Branch 61 Forsyth Street, SW Atlanta, Georgia 30303
Compliance Evaluation Inspection Report Toyota Tsusho America, Inc. NPDES Permit: KY0110060
Project No. CV-KY0110060-072821 702 Triport Road
Georgetown, KY 40324 Inspection Date: July 28, 2021
Inspectors: Brad Ammons, EPA Region 4 Dennis Sayre, EPA Region 4 Deborah Singleton, KY Division of Water Jarrod Jones, KY Division of Water
Inspection Report Prepared by: Brad Ammons
October 18, 2021
Title and Approval Sheet Title: Compliance Evaluation Inspection Toyota Tsusho America, Inc.
Approving Official:
JAIRO CASTILLO
Digitally signed by JAIRO CASTILLO Date: 2021.10.20 16:13:16 -04'00'
Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch
10/20/2021
Date
Enforcement Officer:
Brad Ammons, Environmental Engineer Wastewater Enforcement Section Water Enforcement Branch
10/20/2021
Date
` COMPLIANCE EVALUATION INSPECTION REPORT
Toyota Tsusho America, Inc., Project No. CV-KY0110060-072821
Table of Contents
1. INTRODUCTION.................................................................................................................................................. 3 2. PARTICIPANTS.................................................................................................................................................... 3 3. FACILITY DESCRIPTION ................................................................................................................................... 3 4. INSPECTION PROCEDURES .............................................................................................................................. 3 5. FINDINGS AND CONCLUSIONS ....................................................................................................................... 3 6. PERMIT ................................................................................................................................................................. 4 7. RECORDS AND REPORTS ................................................................................................................................. 4 8. SAMPLING ........................................................................................................................................................... 5 9. DISCUSSION ........................................................................................................................................................ 5 10. ATTACHMENTS .................................................................................................................................................. 5
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` COMPLIANCE EVALUATION INSPECTION REPORT
Toyota Tsusho America, Inc., Project No. CV-KY0110060-072821
1. INTRODUCTION
The U.S. Environmental Protection Agency, Region 4 and the Kentucky Division of Water (KDOW) conducted a Compliance Evaluation Inspection (CEI) at the Toyota Tsusho America, Inc. (Toyota) facility (Facility) located at 702 Triport Road in Georgetown, Kentucky on July 28, 2021. The inspection was conducted under the authority of Section 308 of the Clean Water Act (CWA), as amended. This narrative report and attachments present the results of the inspection.
2. PARTICIPANTS
Name Brad Ammons Dennis Sayre Deborah Singleton Jarrod Jones Julie Smoak Ted Malin
Nicole Galavotti
Position EPA Inspector EPA Inspector KDOW Inspector KDOW Inspector Environmental Manager Facility Maintenance & Security Shield Environmental
Phone Number 404-562-9769 404-562-9756 502 564-3410 502 564-3410 859-209-0438 859-537-2501
859-294-5155
3. FACILITY DESCRIPTION
The Facility discharges industrial storm water collected from the 76-acre site. In 2005, the Facility was switched from a general storm water permit to an individual storm water permit because of the "green metal" building and metal storage area. There are two storm water detention ponds on-site.
4. INSPECTION PROCEDURES
The overall objective of this CEI was to evaluate the condition and operational performance of the Facility's industrial storm water best management practices, storm water collection system and the permittee's self-monitoring program and offer compliance assistance as needed. Specific tasks included an opening conference, conducting an interview with the Facility management, reviewing Discharge Monitoring Reports (DMRs) and other records, conducting a site visit, and a closing conference.
5. FINDINGS AND CONCLUSIONS
(Refer to Attachment 1 for cited photographs)
Outfalls 003, 005 and 006 are monitored quarterly and outfalls 004 and 007 are monitored monthly.
In 2018, Toyota had all the underground pipes assessed by cameras (closed circuit television (CCTV)) and in 2019/2020 bid contracts to rehabilitate all the pipes.
In April 2020, a sinkhole in the area that drains to Outfall 004 was discovered. Outfall 004 is east of the Green Metals, Inc's building (see Figure 1. below). The sinkhole was approximately 50' long and 6' deep. An area of vegetation approximately 300' long and 50' wide was cleared to fill in the sinkhole and surrounding area with an estimated 400 tons of limestone riprap. See photo of rehabilitated sinkhole area looking toward outfall 004 (Photo 2)
The Facility exceeded the Total Suspended Solids (TSS) permit limit for Outfall 004 in 4th quarter
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` COMPLIANCE EVALUATION INSPECTION REPORT
Toyota Tsusho America, Inc., Project No. CV-KY0110060-072821
2018, 2nd quarter 2019, 4th quarter 2020, 1st quarter 2021, and 2nd quarter 2021. The latter three quarters of exceedances occurred during the excavation and remediation of the sinkhole. The Facility exceeded the Oil and Grease permit limit for Outfall 004 in 4th quarter 2018. The Facility representative had no explanation for the Oil and Grease (O&G) exceedance but noted there is an employee parking lot that drains to Outfall 004. The Facility exceeded the TSS permit limit for Outfall 003 (Photo 4) in 4th quarter 2018. No explanation for this exceedance was given. The Facility also exceeded the TSS permit limit for Outfall 005 in 1st quarter 2019 and 1st quarter 2021. The Facility representative noted that they had completed rehabilitation of the detention basin upstream of Outfall 005 because it was heavily vegetated, and the inlet and outlet structures were too close to each other. This work was completed in 2020/2021.
Figure 1. Facility outlay map. 6. PERMIT
The National Pollutant Discharge Elimination System (NPDES) permit number KY0110060 (Permit) became effective on October 1, 2019 and the Permit expires on September 30, 2024. Pollutants of interest in the Permit include pH, TSS, and Oil & Grease. The Facility is permitted to discharge industrial storm water into an unnamed tributary of Dry Run. 7. RECORDS AND REPORTS A review of EPA's Enforcement and Compliance History Online (ECHO) website shows the Facility to be in Significant Non-compliance (SNC) for TSS exceedances at Outfall 004 for 4th quarter 2020, 1st quarter 2021 and 2nd quarter 2021. Tables 1 below is a summary of NPDES effluent limit exceedances.
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` COMPLIANCE EVALUATION INSPECTION REPORT
Toyota Tsusho America, Inc., Project No. CV-KY0110060-072821
Outfall
003 004 004 004 004 004 004 004 004 004 004 004 004 005
Table 1. Effluent limit exceedances from July 1, 2018 to June 30, 2021.
Parameter
Monitoring
Effluent Exceedance
Frequency
TSS
Quarterly
4th quarter 2018
TSS
Monthly
October 2018 (160% over limit)
TSS
Monthly
November 2018 (11% over limit)
TSS
Monthly
May 2019 (3% over limit)
TSS
Monthly
October 2020 (85% over limit)
TSS
Monthly
November 2020 (104% over limit)
TSS
Monthly
January 2021 (753% over limit)
TSS
Monthly
February 2021 (59% over limit)
TSS
Monthly
March 2021 (59% over limit)
TSS
Monthly
April 2021 (28% over limit)
TSS
Monthly
May 2021 (210% over limit)
TSS
Monthly
June 2021 (210% over limit)
O&G TSS
Monthly Quarterly
November 2018 (17% over limit) 1st quarter 2019
8. SAMPLING Shield Environmental conducts sampling for TSS, Oil & Grease, and pH. Records reviewed include DMRs and Chain of Custody forms, which appeared to be in good order.
9. DISCUSSION The facility has already rehabilitated the area that drains to outfall 004 to address the TSS permit limit exceedance. No further action is warranted.
10. ATTACHMENTS 1. Photographs 2. EPA ECHO printout
END REPORT
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Toyota Tsusho America, Inc. Attachment 1 - Photographs Project No. CV-KY0110060-072821
Photo 1: Inlet to Outfall 004.
Photo 2: Remediated area upstream of Outfall 004.
Photo 3: Outfall 004 (to Dry Run).
Photo 4: Outfall 003 (in detention basin).
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Effluent Limit Violations
SNC Violations