Document zQaLv2kkrqm1EexrKa1rQpwy0

US Environmental Protection Agency - Region 2 Caribbean Environmental Protection Division Response and Remediation Branch Resource Conservation and Recovery Act (RCRA) Choose an item. Facility Name: EPA ID Number: Date of Inspection: Generator Status in Record: Generator Status at the time of inspection: RCRA Permitted: Basis for Inspection: Corrective Action: Project ID DCN Administrative & Recycling Corp. PRN008026791 August 18, 2022 Non-Notifier SQG No Complaint No CEPD-RCRA-22-0425 Facility Physical Location: Bo. Martin Gonzalez, Sector La Palmita, PR Road - 887, km 0.9 (Municipality, PR, zip code) Carolina, Puerto Rico 00985 Geographical Coordinates: 18 22' 58" N and 65 58' 17" W Facility Owner: Mr. Carlos Sanchez, President (787) 257-5003 acordero@dcncorporation.com Mailing address: P.O. Box 744 Gurabo. Puerto Rico 00778 Facility Operator: Ms. Andrea Cordero, CEO (787) 318-0598 acordero@dcncorporation.com Mailing address: P.O. Box 744 Gurabo. Puerto Rico 00778 NAICS: 423930 SIC: 5093 Area: 6,735.6056 m2 (1.66 acres} Number Employees: Approximately 11 (F/T) Personnel participating in inspection: Eduardo R. Gonzalez EPA Region 2-CEPD Enforcement Officer (787) 977-5839 Deborah Rivera Carolina Municipality Director Env. Affairs (787) 752-1788 Carlos Sanchez DCN Recycling Corp. President (787) 257-5003 Ms. Andrea Cordero DCN Recycling Corp. CEO (787) 318-0598 Status: Final Record Schedule: 1044(c) } Multi-media Checklist: ATTACHMENT # Referral: CWA EPA Lead Inspector Signature/Date X 02/09/2023 Supervisor Signature/Date DAVID CUEVAS- Digitally signed by DAVID CUEVAS-MIRANDA X MIRANDA Date: 2023.02.09 14:10:04 -04'00' D avid N. Cu evas M iran d a, Ph .D . 1 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 1 INTRODUCTION On August 18, 2022, a Resource Conservation and Recovery Act (RCRA) Compliance Evaluation Inspection (CEI "the Inspection") was conducted by EPA at DCN Administrative & Recycling Corp. (the "Facility") to address a fire incident occurred on August 11, 2022 at the Facility and referred by the Carolina Municipality's Environmental Affairs. Representatives from the Carolina Municipality's Environmental Affairs also accompanied EPA during the inspection. The Inspection was also conducted to verify the scrap metal recycling activities being undertaken at the Facility, and to address community complaints alleging strong odors and oily water from recycling operation and overflow of used oil and other spent solvents (i.e., gasoline from tanks, brake fluid, automatic transmission fluids and battery fluids, etc.) toward a nearby community known as Las Palmitas Ward. The community also complained about excessive noise, strong odors of solvents, explosions, fire incidents, and crushing of automobiles in the property. Therefore, the main objective of the Inspection was to evaluate existing Facility's compliance pursuant to Section 3007 of the Solid Waste Disposal Act, as amended by the RCRA of 1976 and the Hazardous and Solid Waste Amendments (HSWA) of 1984, 42 U.S.C. 6901, 6927 and other EPA's regulations pursuant to various Federal laws and statues. DCN Administrative & Recycling Corp. is approximately 6,736 square meters (m2) scrap metal recycling facility located in Martin Gonzalez Ward, Sector La Palmita, PR Road - 887, km 0.9 Carolina, Puerto Rico 00985. Refer to Figure 1 for the location and to Figure 2 for an aerial photograph of the Facility, ATTACHMENT I. The Facility operates under a Puerto Rico Department of Natural and Environmental Resources (DNER) Permit No. IP-16-022 which expires on March 19, 2024. The DNER permit was issued under Ms. Andrea Cordero, President of DCN Administrative & Recycling Corp., as the sole authorized party to operate the Facility, who also shares Facility's authority with Mr. Carlos Sanchez, CoPresident. The August 18, 2022, Inspection consisted of an opening interview with Ms. Andrea Cordero, President of DCN Administrative & Recycling Corp., to discuss alleged explosion and fire incident at the Facility and to corroborate the immediate actions undertaken by the Facility. As part of the Inspection, an opening meeting, walkthrough, documents review and closing meeting were conducted to evaluate Facility's compliance with the requirements that govern hazardous waste generators, universal waste handlers and used oil generators, as applicable. According to EPA records, the Facility has never submitted a RCRA Section 3010 Notification of Regulated Waste Activity to EPA. However, EPA assigned an Identification Number PRN008026791 in RCRA Info after it conducted an Inspection of the Facility in August 2022. DNER inspected the Facility under the Commonwealth's Hazardous Waste program on April 21, and August 10, 2022, respectively, and potential compliance issues were identified regarding used oils, universal wastes, and special wastes. 2 FACILITY PHYSICAL DESCRIPTION AND OPERATION DCN Administrative & Recycling Corp. is a 6,736 m2 scrap metal recycling facility located in Sector La Palmita, PR Road - 887, km 0.9 Carolina, Puerto Rico. The Facility operates as a scrap metal recycler processor and exporter of ferrous and nonferrous metals to United States and other countries (see Pictures 1 and 2). According to Facility's records, metal recycling process has been in operation at this location since at least November 2016. It also operates as an auto salvage yard, buying and taking in abandoned vehicles, partially dismantling, crushing, storing, then reselling as scrap steel to scrap yard metal facilities Status: Final 2 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 in Puerto Rico and the United States (see Picture 3). As part of its crushing operations, DCN Administrative & Recycling Corp. generates used oil and other vehicle fluids, some hazardous (see Picture 4). According to facility's records, metal recycling process an average of 5 to 6 vehicles per day and conducts auto crushing, shedding, and bailing operations at the site. At the north side of the Facility there is a residential community known as Martin Gonzalez Ward, Sector La Palmita. As recorded at the Facility, any fluids generated from rainwater or auto crushing operations flow into the ground and downgradient towards the community and into an unnamed creek which is located north of the property edge (see Picture 5) which then flows into the Blasino Channel. Runoff would be expected to contain transmission fluids, gasoline, diesel, motor oil, antifreeze/coolant, windshield washer fluid, refrigerants, brake fluid, lead, and mercury. As evidenced during the Inspection, all mixed fluids generated from crushing and compacting operations are trapped into a metal tray-typed and collected with absorbent materials. Once the tray is full, it leaks onto bare soils and flow downgradient and off the property (see Pictures 6 and 7). DCN Administrative & Recycling's infrastructure consists of concrete pads and open-air areas supplemented by roofed warehouse structures, which are mostly used for recycling operations and storage of processed metal materials. A concrete building is used as an office. Eleven (11) full-time employee work on-site, and they operate six days per week from Mondays through Fridays from 7:00 am to 4:00 pm and Saturdays from 8:00 am to 12:00 pm. Information provided by the Facility indicated that crushing, shedding and bailing operations of vehicles and other metals are conducted on-site, and the major portion of the facility is used for the temporary storage of wrecked vehicles, motor engines and scrap metal. Facility operating records indicate that it processes approximately 250 tonnage of scrap material per month from outside sources. In addition, 150 dismantled cars (i.e., 3,000-4,000 pounds/car) are received monthly, from other junkyards located throughout northern area of Puerto Rico. According to DCN Administrative & Recycling Corp. records and quarterly solid waste permit (DS-2) reports1, the facility manages approximately 250 Tonnage2 of processed scrap metal monthly Facility's representatives, Ms. Andrea Cordero, President, and Mr. Carlos Sanchez, Co-President, emphasized to EPA that the Facility has a permit from DNER for the storage and recycling of nonhazardous wastes under RCRA Subtitle D, including used oils (Permit No. IP-16-022 Expiration Date: March 29, 2024). Based on preliminary Inspection discussion, EPA had determined that the recycling program at the Facility was not adequate, and there was a potential threat to public health and the environment associated with the mismanagement of auto fluids generated during crushing operations including but not limited to spent solvents, batteries, used oils, crushed auto lamps during recycling operations. 1 Reports are quarterly submitted to the Puerto Rico Department of Natural and Environmental Resources (DNER). 2 Gross Registered Tonnage (GRT) represents the total internal volume of a vessel, where a register ton is equal to a volume of 100 cubic feet (2.83168 m3), which volume, if filled with fresh water, would weigh around 2,800 kg or 2.8 tonnes ~ 1 tonne = 1,000 kg. Status: Final 3 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 2.1 FACILITY PHYSICAL The Facility is located at approximately 70 feet above mean sea level. Figure 1 presents the location on a portion of the US Geological Service (USGS) Topographical Map. Figure 2 presents an aerial photograph of the Facility. The closest superficial water body is an unnamed creek located north of the property that discharges into the Blasino Channel that flows into the Atlantic Ocean. The facility consists of various rectangular shaped metal building used as processing and storage warehouses and as well as administrative offices. DCN Administrative & Recycling Corp. is delimited at the North by a community known as Martin Gonzalez Ward, Sector La Palmita, at the West and South by an industrial sector and other businesses such as Puma Gas Station, Rooms-ToGo Outlet located on PR Road 877, and at the East of the Facility there is an undeveloped land property surrounded by PR Road No. 3 and food industry, Jalisco Restaurant & Sports Bar, located on Jose Severo Avenue. 3 AUTO SALVAGE OPERATIONS (SOLID AND HAZARDOUS WASTE GENERATION) According to facility representatives, in a typical daily operation DCN Administrative & Recycling accepts discarded metal goods (i.e., ferrous, and nonferrous) from both industry and commercial and scrapyard sources. It also accepts some abandoned cars in varying levels of disassembly at the Facility. Of the 100-250 tons/month accepted, mostly are scrap metals and some are few dismantled cars received from other scrapyard facilities or discarded by car owners. According to the facility representatives, most cars are received with very little fluids and engine parts since most are received from previous scrap metal providers that dismantle the vehicles for parts selling. Once the cars are received, they are placed in the metal piles which are eventually processed along with other scrap metals, and sent to metal reclaiming facilities in China, Korea, Panam and United States. No drainage of car fluids or parts removal is conducted at the site. Additionally, and according to facility representatives, DCN Administrative & Recycling weighs and conducts cursory inspections of the received scrap metals and cars. In some instances, most cars accepted on platform trucks may strip their fluids on concrete floors which flows toward on-site collection sumps or off-site street curbs, and discharges into the Blasino Channel. Engine parts are not removed nor transmissions, tires, wheels, or radiators. Once vehicles are weighed, they are sent directly to the metal piles. A record notebook was requested and used as part of the initial inspection procedures to provide an inventory for all scrap metal and junked cars received at the Facility. However, some junked cars are received inside dumper or platform trucks which makes it difficult to conduct a cursory inspection. Accordingly, the record notebook was designed to assist Facility's staff during the process of verifying and confirming the weight of scrap metals and junked cars, but not to confirm if the cars contain fluids, parts or components that may be considered as hazardous materials or wastes. As stated by the Facility's representative, all the components of most of the junked cars received and accepted from Junkyards have their engine parts, braking systems and other parts removed previously as part of the scrapping and resale procedures. However, some of the components of the engine, braking systems, gasoline residues, transmission oils, switches and cables or any other parts (i.e., diesel, motor oil, antifreeze/coolant, windshield washer fluid, refrigerants, brake fluid, lead, and mercury, and switches, etc.) of the junked cars that arrive at the Facility could remain in the junked cars. The Facility does not remove any car components or fluids from incoming junked cars and accepts them "as is" and temporary place them in piles for further Status: Final 4 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 crushing process. According to Facility's records, it is estimated that over 150 junked cars are received monthly. DCN Administrative carries out the above general auto salvage operations directly on concrete floors surrounded by a near residential community known as El Sector La Palmita, and natural ground depression which contains an unnamed creek which discharges into the Blasino Channel. As confirmed by facility representatives, abandoned cars are accepted "as is" and not stripped of known toxic/hazardous materials. Spills of auto fluids pool and can soak into the concrete floors. Stormwater is not well managed onsite since water discharges are constantly observed running off-site. Mostly crushing of metal piles and junked vehicles take place. Consumable materials and reusable fluids, such as gasoline, engine oil, brake fluid, and refrigerants, if any, are not collected on premises. 4 SOLID AND HAZARDOUS WASTE GENERATION The Facility only provided verbal information about the potential generation of spent solvents, mixtures of spent solvent/used oil, and other non-hazardous waste such as used oils, spent batteries and tires. In some instances, spent solvent is added to the used oil collected in a 500-gallon double wall tank with secondary containment located in the Fuel and Used Oil Storage Area. Approximately, 250-300 gallon of used oil is disposed of monthly and hauled by Ruben Martinez Oil Collection Services. 4.1 HAZARDOUS WASTE (AND HAZARDOUS WASTE CONSTITUENT) GENERATION AND MANAGEMENT At the time of the Inspection, numerous potential solid waste streams can be generated and disposed of on-site. Some of these waste streams, may including discarded gasoline (D018), constitute hazardous wastes. Other waste streams such as discarded materials containing break fluids, lead (D008), reactives (D003), and materials containing mercury (D009) likely constitute hazardous waste. These waste streams include: 1. Waste fuels, predominantly gasoline with some diesel, is generated from the handling, removal of tanks, and long-term storage of automobiles and other vehicles. Waste fuel filters are included in this waste stream. As the crushing and junker storage (leaking fluids) were conducted directly on concrete floors with no impermeable cover, some quantities of motor vehicle fluids are potentially disposed directly to beneath soils and, to a certain extent, evaporated to the ambient air. At maximum of 150 junked cars per month that are received with a residual of 1-liter of gasoline/car, this waste stream would represent some 150 kg/month (330 lb/month) of hazardous waste. Spent/discarded gasoline is both an ignitable hazardous waste (D001) and a toxic characteristic waste for benzene (D018). Discarded diesel #2 fuel is likely to be an ignitable hazardous waste (D001). 2. Waste antifreeze/coolant is generated from the handling, crushing, and long-term storage of automobiles and other vehicles. As crushing operations and junker storage were conducted directly on concrete floors with no impermeable cover, some quantities of motor vehicle fluids are potentially disposed directly to beneath soils and, to a certain extent, evaporated to the ambient air. At maximum of 30 junked cars per month with a residual of -liter of antifreeze/coolant/car, this waste stream could represent some 75 kg/month (165 lb/month) of hazardous waste. Antifreeze/coolant is comprised primarily of water and ethylene glycol or propylene glycol. Ethylene glycol is a non-RCRA toxic substance (though EPCRA-reportable). Antifreeze/coolant Status: Final 5 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 is known to become contaminated during use with benzene, PCE/TCE, and metals, such as lead, cadmium or mercury; 3. Waste lead wheel weights are generated from the handling, crushing, and long-term storage of automobiles and other vehicles. While wheel and tires are generally removed by the facility prior to crushing. The Facility does not remove or segregate lead wheel weights for further recycling. Wheel weights made of lead are clipped onto wheel rims to ensure even balancing of wheels. At 2.5 oz/tire, this waste stream would represent some 953 lb/month of hazardous waste if they could be crushed with junked cars. These lead weights may exhibit the toxic characteristic for lead (D008); 4. Discarded lead-acid batteries are recovered by the facility from most vehicles. At the time of the Inspection, approximately 25 discarded or damaged lead acid batteries were being stored and placed on a wood pallet. No waste labeling was present. In addition, lead cable ends were in evidence during the Inspection on junked cars. Facility practice is to collect all batteries and be picked up by a local battery recycling center, known as Caribbean Metals, and get paid for them. Approximately, 7,000 lbs of battery are collected on wood pallets every four month for disposal with Caribbean Metals. However, no evidence was provided by the Facility about the battery recycling company. Lead-acid batteries contain both lead and acid (sulfuric acid) and generally exhibit the toxic hazardous wastes characteristic for lead (D008) and corrosive hazardous wastes for acid (D002). No effort to remove, segregate or otherwise handle lead cable ends, sometimes left with junked cars after batteries are removed, was made by the Facility; 5. Junked, removable, mercury-containing auto components are not inspected for, identified, removed, segregated, or otherwise dealt with by the Facility. Such auto components include: a. Light removable, mercury-containing switches (e.g., tilt switches used on under-hood and truck lighting); b. Anti-lock braking systems; c. Active ride control or ride leveling sensors; d. High intensity discharge systems (headlights, tail lamps); and e. Virtual image instrument panels; 6. The Facility, while aware of such components, believes that removal before scrapping is only required in the United States, not Puerto Rico. Facility policy is to ignore these components. The crushing and long-term storage of automobiles and other vehicles containing mercury components would likely release mercury directly to the concrete pad and, to a certain extent, to the ambient air. At 0.54-gm of mercury/car, this waste stream would represent some 0.18-lb/month of elemental mercury hazardous waste (150-lbs/year Hg which is the amount in ~3.5 million fluorescent bulbs). The failure to remove known, mercury-containing components precludes the scrap metal exemption (see analogous treatment of scrap metal circuit boards in 40 CFR 261.4(a)(13). Mercury is toxic hazardous waste (D009) and these components may exhibit that characteristic; 7. Discarded airbag cartridges, containing sodium azide, are not inspected for, identified, removed, segregated, or otherwise dealt with by the Facility. Vehicles with airbags remaining in place can trigger explosions inside the Facility. The crushing and long-term storage of automobiles and other vehicles containing airbag cartridges could release sodium azide (water soluble) directly to the concrete pad and, to a certain extent, to the ambient air as a toxic dust. Sodium azide, in its commercial chemical form, is a RCRA acutely hazardous waste for toxicity. Discarded airbag cartridges are likely a reactive hazardous waste (D003); Status: Final 6 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 8. Diesel fuel leaks from heavy equipment and long-term storage of trucks. Discarded diesel #2 fuel is likely to be an ignitable hazardous waste (D001); 9. Waste oil mixed with spent solvents generated from a variety of on-site equipment particularly from the crushing activities. Facility did not provided records indicating that used oil is picked up by a local used oil company. At the time Inspection, waste oil was generally accumulated in 500gallon double wall tank beside the entrance area, in some instances containers were unlabeled and open throughout the Facility. Heavily stained were previously observed on the containers and on the concrete floors. Huge amount of waste oils was observed beneath the crusher machine. Drums and containers were open and unlabeled. Since crushing of vehicles takes place on concrete floors most waste oil fluids strip from car's engine can flow on surface soils illegally; 10. Contaminated stormwater runoff from crushing and storage of vehicles and other materials, is not managed and either percolates into the onsite concrete floors or flows off property and either percolates into the offsite soil or flows into the local water creek. Runoff would be expected to contain transmission fluids, gasoline, diesel, motor oil, antifreeze/coolant, windshield washer fluid, refrigerants, brake fluid, lead, and mercury; 11. Contaminated soil resulting from exposure to above auto fluid and other releases; and, 12. Spent fluorescent light bulbs and other mercury lamps could be generated, and at least in part, crushed with metal piles or deposed of with the regular trash. Facility records were unavailable either during the Inspection or subsequently to demonstrate the proper management of spent fluorescent light bulbs. Spent fluorescent bulbs can be a toxic characteristic waste for mercury (D009). According to the Facility's representative, no hazardous waste has been managed, manifested, or otherwise disposed in operations. Preliminary hazardous waste calculations from the above waste stream analysis indicates generation rates greater than 100-kg/month (220-lbs/month), i.e., a small quantity generator. DCN Administrative did not make hazardous waste determinations regarding any of these waste streams and did not have interim status or a permit authorizing the disposal of hazardous waste at its Facility. 4.2 POLLUTION PREVENTION & WASTE MINIMIZATION Beyond efforts inherent in junkyards and scrap metal operations, no other Pollution Prevention (P2) or Waste Minimization efforts were identified. 5 OPENING MEETING An opening meeting was held between Ms. Andrea Cordero, chief executive officer (CEO), and Mr. Carlos Sanchez, President, both from DCN Administrative & Recycling Corp., Ms. Deborah Rivera Velzquez, Municipality of Carolina - Environmental Affairs Director, and I. I identified myself as EPA RCRA Enforcement Officer and told the facility representatives that the purpose of my visit was to conduct a CEI at the Facility to evaluate its hazardous waste management practices and compliance. In addition, I stated that EPA received a complaint from the Municipality of Carolina to address a fire incident occurred on August 11, 2022, at the Facility. During the meeting, I asked directly to Ms. Cordero about the current scrap metal and junkyard operations undertaken at the Facility. She mentioned that scrap business was only related of ferrous and nonferrous metals and that she was accepting over 150 monthly Status: Final 7 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 junked cars from other facilities. She added that that fire incident initiated at the pile of junker cars due to probably to a spark from the scrapyard crane during picking-up junker cars at the Facility. At the opening meeting, the EPA Inspector discussed the objectives of the RCRA Inspection, and the requirements under RCRA scrapyard exclusion, if any, for a used oil generators and/or junkyard/scrap metal recycling facility. Based on the initial Inspectors' observations, operations at the Facility consisted of receiving and weighting cargo trucks filled with scrap metals including motor engines, and white household goods. The procedure used at the Facility for the recycling of scrap metals consist of: 1) receiving scrap metals at the entrance gate; 2) weighting and/or visual inspecting of incoming cargo trucks; 3) placing the scrap metals in the central yard area; 4) segregating and piling scrap metals by metal's properties (i.e. ferrous, nonferrous, and white goods); 5) picking up segregated metals with an excavator, in some circumstances crushing wrecked vehicles and other large metal pieces conducted on-site; and, 6) pulling together and loading in trailer trucks, and picking up and transporting to metal reclaiming facilities in China, Korea, Panam or United States. At the meeting, I requested Ms. Cordero to provide me for review the following documents associated with Facility's metal recycling operations: 1. Ferrous and Nonferrous Monthly Inventory to materials received and recycled; 2. Junked Cars Inventory of monthly received and crushed at the Facility; 3. Contingency and Emergency Preparedness Plan; 4. Used Oil Generator Permit and disposal manifests; 5. Spill Prevention, Control and Countermeasure Plan (SPCC); 6. Training Certificates associated with hazardous waste management (provided at the meeting: McCoy Certificate dated, August 9, 2016); 7. EPA Hazardous Waste Activities Notification (EPA I.D. Number - not requested); 8. Facility Site Map; 9. Stormwater Prevention and Pollution Plan (SWPPP); and, 10. Management of standard operating procedures ("SOPs") for spent batteries, aerosol cans, used oil, spent fluorescent lamps and antifreeze/coolant in cars and white goods. 6 FACILITY WALKTHROUGH (AUGUST 18, 2022 INSPECTION) The RCRA Inspection through the facility included: (1) Entrance Gate and Weighing Scale Area; (2) Compacting Aluminum Accumulation Area; (3) Material Processing & Collection Area (Oudoor); (4) Machine Shop Area; (5) Ferrous Metal Collection Area; (6) Fuel and Used Oil Storage Area; (7) Alloy Wheel Collection Area; (8) Compacting Cars Area; and (9) Fire Incident Scrapyard Site Area (Auto Salvage). The tour was performed at all metal shed buildings surrounding the office building. 6.1 ENTRANCE GATE AND WEIGHING SCALE AREA The EPA Inspector proceeded to inspect the entrance gate and weighting scale station area where all cargo trucks are visually inspected before segregating into small-scale stations (see Picture 8). According to Facility representatives, junked cars are not weighed; these are directly transported to the crushing machine area in platform trucks. The weighting scale station area is located at the center of the property. A loading concrete pad area is located north of the entrance where all scrap metals are collected and segregated according to material properties (see Picture 9). The aluminum metals (i.e., windows, Status: Final 8 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 handlers, doors, and baskets, etc.) are first segregated and processed, and then placed into 1-cy textile bags located in the west area of the property. All other ferrous metals are also segregated and collected into similar recycling manner. According to Ms. Cordero, junked cars received prior dismantled by other metal reclaiming facilities and received at the property for further crushing by using an excavator and later placed into trailer trucks for transportation. It was expressed by Ms. Cordero that when junked cars are discarded in the property, they are crushed with the compactor machine to reduce its size and to place it into trailer trucks. EPA Inspector asked Ms. Cordero how her employees conduct the visual inspection of the cargo trucks at the entrance gate area, since it was hard to look inside of the dump trucks content. She replied that scrap metals are accepted "as is" even mixed with whitegoods and auto parts (i.e., motor engines). EPA Inspector observed that some of the cargo trucks at the property had mostly discarded mixed metals including motor engines, engine cables for breaking, air-conditioning compressors, and electric systems at the time of the inspection. Observations recorded at the Entrance Gate and Weighing Scale Area included: 1. Dismantled motor engines with no control or prevention of releases of used oil or stormwater run-off contaminated with transmission fluids, gasoline, diesel, and other motor oil fluids (see Picture 10); and, 2. Approximately twenty-five (25) discarded auto batteries placed on a wood pallet without any means of containment measures or labels. According to Ms. Cordero a battery carrier would be contacted to recycle the auto batteries at the property (see Picture 11). 6.2 COMPACTING ALUMINUM ACCUMULATION AREA The EPA Inspector proceeded to inspect the Compacting Aluminum Accumulation Area in which all aluminum scrap metals are collected and processed in this area. The area consisted of steel shed with concrete pad in which a weighting scale is also used before and after segregating all aluminum metals before being transfer into 1-cy textile bags (see Picture 12) As observed by the EPA Inspector aluminum scrap metals are first segregated by metal properties (i.e., aluminum cans), crushed with compacting machines to reduce metals size, and then immediately transferred to 1-cy white cloth bags (see Picture 13). Observations recorded at the Compacting Aluminum Accumulation Area included: 1. Two (2) 55-gallon steel drums open with used oil waste content not properly labelled with the words, "Used Oil," and surrounded with scrap metals heavily impacted with used oil (see Pictures 14 and 15); 2. Two (2) 5-gallon plastic containers with used oil not properly labeled with the words, "Used Oil," (see Picture 16); and, 3. There was evidence of leaks and spills incidents on the concrete floor that appear to contain used oil from crushing machines and heavily impacting soils in the backyard with used oil (see Picture 17). 6.3 MATERIAL PROCESSING & STORAGE AREA (OUTDOOR); The EPA Inspector proceeded to inspect the Material Processing & Storage Area in which most of the processed scrap metals are compacted and stored in compressed package blocks. Observations recorded at the Material Processing & Storage Area included: Status: Final 9 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 1. There were approximately four (4) 1-cy yard "white cloth" bags with motor engine parts and other metals leaking used oils on the concrete floor without any means of control (see Picture 18); 2. One (1) engine motor laying on the concrete floor leaking fluids on the concrete floor; and, 3. There was evidence of numerous leaks and spill incidents on the concrete floor that appear to contain motor engine fluids that migrated and heavily impacted with used oils the backyard soils near the property perimeter fence (see Picture 19). 6.4 MACHINE SHOP AREA The EPA Inspector proceeded to inspect the Machine Shop Area. In this area mechanic repairs and maintenance jobs are conducted on the heavy equipment machine. In addition, nonferrous metals are collected, segregated, and packed for shipping into China, Korea, Panam and United States. During the Inspections, it was observed that some engine motors were leaking fluids and stained all over the concrete floors. Sand or other absorbent material was not used to control or clean up used oil spills, therefore, there were no means of control of engine fluids flowing toward perimeter fence and outside the property. Observations recorded at the Machine Shop Area included: 1. Approximately seven (7) discarded extinguishers placed on the concrete floors without any containment measures or labels (see Picture 20); 2. Dismantled motor engines with no control or prevention of releases of used oil or stormwater runoff contaminated with transmission fluids, gasoline, diesel, and other motor oil fluids (see Picture 21); 3. One (1) 5-gallon plastic container open and with used oil not properly labeled with the words, "Used Oil," (see Picture 22); and, 4. Approximately over one hundred (100) discarded batteries rolled in plastic firm and placed on a wood pallet without any means of containment measures or labels. According to Ms. Cordero a battery carrier has been contracted to recycle the auto batteries at the property (see Picture 23). 6.5 FERROUS METAL COLLECTION AREA The EPA Inspector proceeded to inspect the Ferrous Metal Collection Area in which all scrap metals are collected and processed in this area. The area consisted of concrete pad and other bare soils areas in which an excavator and a bulldozer machine segregate, process and transfer all scrap metals into cargo trucks. As observed by EPA Inspector scrap metals are first segregated by metal properties, crushed with the excavator to reduce metals size, and then immediately sent to the cargo trucks (see Picture 24). It was expressed by Ms. Cordero that when scrap metals are is discarded on her property, crushed it with the excavator machine to reduce its size and to place it into cargo trucks. Observations recorded at the Ferrous Metal Collection Area included: 1. Two (2) abandoned heavy equipment machine "Sky Tracks" leaking engine motor fluids on soil grounds. Ms. Cordero indicated that both machines were used for repair parts of other machines (see Picture 25); 2. There was one water tower and seep collection sump to control and manage stormwater run-on and run-off of the property. According to Ms. Cordero, the water tower is being nonfunctional since beginning of January 2022. The collection sump has dimensions of 8' x 12' x 9' deep and was observed fully filled with sediments and heavily impacted with used oils (see Picture 26); Status: Final 10 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 3. Piles of scrap metals placed on bare soils and being operated by an excavator leaking oily fluids on the ground (see Picture 27); and, 4. There were several auto wheels rims, some containing lead weights which were not removed along with gas-contained cylinders which were mixed with the scrap metals (see Picture 28). 6.6 FUEL AND USED OIL STORAGE AREA The EPA Inspector proceeded inspect the Fuel and Used Oil Storage Area. This area consisted of a metal shed with a ceiling and a secondary containment system and housed two (2) 500-gallon above grounddoble wall tanks to store used oils and diesel clearly labeled (see Picture 29). The 500-gallon used oil tank was labeled with the Spanish words, "Aceite Usado," (which is the translation for "Used Oil"). All leaking fluids from the crushing machine operations are stored in this tank. There was an EPA's concern during the Inspection that runoffs from the Facility were accumulated at this location during rain events and were discharged directly toward a nonfunctional sump and then into the sidewalk curb nearby water creek located northwest of the property edge (see Picture 30). As observed during the Inspection, the Facility provided with absorbent materials around the used oil storage area to reduce the sediments and other debris that might be carried out by the stormwater. However, the EPA Inspector informed Ms. Cordero that absorbent materials would not control or prevent releases of used oil or stormwater run-off contaminated with transmission fluids, gasoline, diesel, motor oil, antifreeze/coolant, windshield washer fluid, refrigerants, brake fluid, lead, and mercury. 6.7 ALLOY WHEEL COLLECTION AREA The EPA inspector proceeded to inspect the Alloy Wheel Collection Area. This area was used as a central accumulation area in which all alloy wheels received at the Facility were collected and packed in 1-cy white cloth bags. It was observed the most alloy wheel rims contained lead weights which were not properly removed before packaging (see Picture 31). The area was "outdoor" and did not have any concrete pad to collect or control stormwater runoff that percolated and become in direct contact with the wheel leads. As observed by the EPA Inspector, the Facility does not remove or segregate lead wheel weights for further recycling. As explained to Ms. Cordero, these lead weights may exhibit the toxic characteristic for lead (D008) and may directly percolate into the bare soils. 6.8 COMPACTING CARS AREA The EPA Inspector proceeded to inspect the Compacting Cars Area where crushing and bailing of junked cars is performed. The area consisted of an outdoor bare soil in which an ALJON 580 CL machine (i.e., crusher, bailer) is sited (see Picture 32). The machine has the capacity to manage over twenty (20) vehicles per day. Once the vehicles are placed in the area, the machine is turned on and all the cars along with other scrap metals are shredded and bailing into small metal blocks for further processing or final reclaiming. As observed during the Inspection, large amounts of scrap metal piles, and burned junked vehicles were accumulated in this area. According to Ms. Cardona, the crushing machine has been broken since July 2022, and will be repaired very soon. She added that the Facility used to crush around twenty (20) cars per day and to continue processing all accumulated scrap metals once the machine is fixed and operational. During the Inspection, it was observed that most junked vehicles nearby this area were destroyed by the fire incident occurred on August 11, 2022. According to Facility representative, the junked vehicles although previously dismantled may still contained the gas tanks, engine cables, car switches, air Status: Final 11 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 conditioning lines, and braking systems containing residual fluids. As discussed during the Inspection with Ms. Cardona, the procedure used at the Facility for the recycling of vehicles and scrap metals consisted of receiving junked vehicles with fluids and most parts at the scale station. The EPA Inspector stated that it was hard to conduct a visual inspection of the junked cars at the entrance gate, since most of the junked cars were delivered in platform or cargo trucks all placed on top of the other. She responded that junked cars are accepted "as is" and only from other Junkers, since most of the car components are removed. I reiterated that some of the junked cars contained components that were potential hazardous materials such a gasoline residue in the gas tank. She replied that if any fluid leaks during crushing, these would be collected in the steel tray and/or 55-gallon drums (see Picture 33). She added that they use absorbent material to control all fluid releases on the crushing machine. As observed during the Inspection, all leaking fluids were collected into a steel pad beneath the crushing machine. All drums containing leaking fluids from crushing operations are managed as used oil and disposed of with Ruben Martinez Used Oil Collection Services. No hazardous waste characterization is performed on the leaking fluids from the crushing operations on routine basis (see Picture 34). The EPA Inspector observed car fluids leaking on bare soils. Some of the leaks on the soil perceived strong odors of gasoline. EPA Inspector informed Ms. Cardona that she needed to control or prevent releases of used oil or stormwater run-off contaminated with transmission fluids, gasoline, diesel, motor oil, antifreeze/coolant, windshield washer fluid, refrigerants, brake fluid, lead form the crushing machine area. As observed by the EPA Inspectors, there were fluids leaking on the soils and pavement areas flowing toward the entrance and nearby unnamed creek situated northwest of the Facility (see Picture 35). 6.9 FIRE INCIDENT SCRAPYARD SITE AREA The EPA Inspector proceeded to inspect the Fire Incident Scrapyard Site Area. According to Ms. Cordero the fire incident occurred on August 11, 2022, around 1:00 pm and was extinguished by the Fire Department at 6:00 pm on the same day. It was estimated that over 300 junked cars were burned along with ferrous and nonferrous scrap metals temporary accumulated before crushing operations. It was also stated by Ms. Cardona that the fire incident initiated at the pile of junker cars due to probably to a spark from the scrapyard crane during picking-up junked cars at the Facility. It was an untypical number of junked cars accumulated on this area since the crushing machine has been out of service in July 2022. As observed by the EPA Inspector, several piles of mixed destroyed and burned scrap metals were accumulated at the site including motor engines, car fragments, spent tires, alloy wheels, seats, dashes, steel frames, PVC pipes, steel beams, auto batteries, metal cables, car plastic bumpers, brake parts, lead weighs and junked car carcass leaking fluids and staining the soil ground (see Picture 36). It was also observed by the EPA Inspector, fluids leaking on the soils and pavement areas flowing toward the entrance and nearby unnamed creek situated northwest of the Facility (see Picture 37). Observations recorded at the Fire Incident Scrapyard Site Area included: 1. Four (4) 55-gallon steel drums with used oil waste content not properly labeled with the words, "Used Oil" (see Picture 38); and, 2. One (1) 55-gallon drum open and with rags heavily impacted with used oil not properly labeled with the words, "Used Oil," (see Picture 38). Status: Final 12 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 7 DOCUMENTS REVIEW The EPA Inspector was informed by Ms. Cardona, CEO of DCN Administrative & Recycling Corp., that her secretary would be sending the following document via e-mail: 1. Contingency and Emergency Preparedness Plan; 2. Spill Prevention, Control and Countermeasure Plan (SPCC); 3. Stormwater Prevention and Pollution Plan (SWPPP) Map; and, 4. Facility Site Map. The EPA Inspector requested and reviewed DNER's Used Oil Permit and manifests regarding the used oil pickups done by Ruben Martinez Use Oil Collection Services. The EPA Inspector also reviewed some records associated with the inventory of number of junked cars received and processed at the Facility on a monthly basis since January 2022 until July 2022. Formal inventories segregating scrap metals and junked vehicles were also provided for review. The EPA Inspector was also provided with some RCRA Training Certifications. At the end of the document review session, I reviewed the requested documents provided by Ms. Cardona after the Facility walkthrough and she stayed with me to answer any question on the following: 1. Ferrous and Nonferrous Monthly Inventory to materials received and recycled January thru July 2022; 2. Junked Cars Inventory of monthly received and crushed at the Facility; 3. Used Oil Generator Permit and disposal manifests; and, 4. Training Certificates associated with hazardous waste management (provided at the meeting: McCoy Certificate dated, August 9, 2016), The EPA Inspector learned that the Facility did have in a report describing specific standard operating procedures ("SOP") for spent batteries, aerosol cans, spent fluorescent lamps and antifreeze/coolant in cars and white goods. 8 CLOSING MEETING After completion of the walkthrough and document review, I met with Ms. Andrea Cordero, chief executive officer (CEO), and Mr. Carlos Sanchez, President, both from DCN Administrative & Recycling Corp., Ms. Deborah Rivera Velzquez, Municipality of Carolina - Environmental Affairs Director, to conduct a closing meeting. I indicated that the purpose of the closing meeting is to inform the facility about the RCRA Inspection observations. I communicated the facility the following: At the end of the RCRA Inspection, the EPA Inspector emphasized to Ms. Cordero that the management of potentially hazardous waste and/or used oil management program at the DCN Administrative & Recycling Corp. was not satisfactory based on the observations and concerns that were identified. In addition, the EPA Inspector emphasized on the following concerns: Making hazardous waste determinations, especially on car components and containers containing spent solvents mixed with used oil, and auto batteries recycling program in compliance with EPA requirements; Status: Final 13 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 Developing of an emergency plan and appropriate emergency preparedness appropriate to manage and control hazardous waste in case of an accident or emergency; Applying for an EPA Identification Number for hazardous waste notification activities; Losing EPA's Scrap Metal Exclusion: Labeling of Used oil drums and containers, and keep them closed with lids; and, Reducing the risks to minimize fire, explosions, and hazardous waste and/or hazardous constituents releases into the environment. 9 ATTACHMENTS I. Figure 1- Facility Location Map and Figure -2 Aerial Photograph II. Appendix I - Site Pictures Status: Final 14 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 FIGURES Compliance Evaluation Inspection Report DCN Administrative & Recycling, Corp. EPA ID: PRN008026791 Date: August 22, 2022 Status: Final 15 CEPD-RCRA-22-0425 Resource Conservation and Recovery Act DCN Administrative & Recycling Corp. PRN008026791 SITE PICURES Compliance Evaluation Inspection Report DCN Administrative & Recycling, Corp. EPA ID: PRN008026791 Date: August 22, 2022 Status: Final 16 CEPD-RCRA-22-0425 Picture 1 - DCN RECYCLING, CORP. -- It is a 6,736 m2 scrap metal recycling facility located in Sector La Palmita, PR Road - 887, km 0.9 Carolina, Puerto Rico. Picture 2--DCN RECYCLING, CORP. - The Facility operates as a scrap metal recycler processor and exporter of ferrous and nonferrous metals to China, Korea, Panam and United States. Picture 3--DCN RECYCLING, CORP. - The Facility also operates as an auto salvage yard, buying and taking in abandoned vehicles, partially dismantling, crushing, storing, then reselling as scrap steel to scrap yard metal facilities in Puerto Rico and the United States Picture 4-- DCN RECYCLING, CORP. - As part of its crushing operations, DCN Administrative & Recycling Corp. generates used oil and other vehicle fluids some hazardous. Title: DCN RECYCLING, CORP. , Carolina, Puerto Rico EPA ID: Project: PRN008026791 CEPD-RCRA-22-0425 Pictures taken by: Eduardo Gonzalez August 22, 2022 Picture 5- DCN RECYCLING, CORP. - As recorded at the Facility, any fluids generated from rainwater or auto crushing operations flow into the ground and downgradient towards the community and into an unnamed creek and flows into the Blasino Channel. Picture 6 - DCN RECYCLING, CORP. - As observed during EPA Inspection, all mixed fluids generated from crushing and compacting operations are trapped into a metal tray-typed and collected with absorbent materials. Picture 7--DCN RECYCLING, CORP. - As evidenced during EPA Inspection, once the tray is full, it leaks onto bare soils and flow downgradient and off the property. Picture 8 - DCN RECYCLING, CORP. -- As observed during EPA Inspection, the entrance gate and weighting scale station area is where all cargo trucks are visually inspected before segregating into small-scale stations. Title: DCN RECYCLING, CORP. , Carolina, Puerto Rico EPA ID: Project: PRN008026791 CEPD-RCRA-22-0425 Pictures taken by: Eduardo Gonzalez August 22, 2022 Picture 9- DCN RECYCLING, CORP. -- The weighting scale station area is located at the center of the property. A loading concrete pad area is located north of the entrance where all scrap metals are collected and segregated according to material properties. Picture 10 - DCN RECYCLING, CORP. - At the Entrance Gate and Weighing Scale Area, dismantled motor engines with no control or prevention of releases of used oil or stormwater runoff contaminated with transmission fluids, gasoline, diesel, and other motor oil fluids. Picture 11--DCN RECYCLING, CORP. - Approximately twenty-five (25) discarded auto batteries placed on a wood pallet without any means of containment measures or labels. According to Ms. Cordero a battery carrier would be contacted to recycle the auto batteries at the Entrance Gate and Weighing Scale Area. Picture 12 - DCN RECYCLING, CORP. - The Aluminum Accumulation Area consisted of steel shed with concrete pad in which a weighting scale is also used before and after segregating all aluminum metals before being transfer into 1-cy textile bags. Title: DCN RECYCLING, CORP. , Carolina, Puerto Rico EPA ID: Project: PRN008026791 CEPD-RCRA-22-0425 Pictures taken by: Eduardo Gonzalez August 22, 2022 Picture 13- DCN RECYCLING, CORP. - EPA Inspector observed aluminum scrap metals are first segregated by metal properties (i.e., aluminum cans), crushed with compacting machines to reduce metals size, and then immediately transferred to 1-cy white cloth bags. Picture 14 - DCN RECYCLING, CORP. - As observed, at the Entrance Gate and Weighing Scale Area there two (2) 55-gallon steel drums open with used oil waste content not properly labelled with the words, "Used Oil," and surrounded with scrap metals heavily impacted with used oil. Picture 15--DCN RECYCLING, CORP. -- As observed, at the Entrance Gate and Weighing Scale Area there two (2) 55gallon steel drums open with used oil waste content not properly labelled with the words, "Used Oil," and surrounded with scrap metals heavily impacted with used oil. Picture 16 - DCN RECYCLING, CORP. - As observed, at the Entrance Gate and Weighing Scale Area there were two (2) 5gallon plastic containers with used oil not properly labeled with the words, "Used Oil." Title: DCN RECYCLING, CORP. , Carolina, Puerto Rico EPA ID: Project: PRN008026791 CEPD-RCRA-22-0425 Pictures taken by: Eduardo Gonzalez August 22, 2022 Picture 17- DCN RECYCLING, CORP. - As observed by the EPA Inspector at the Compacting Aluminum Accumulation Area, there were leaks incidents on the concrete floor that appears to contain used oil from crushing machines and heavily impacting soils in the backyard with used oil. Picture 18 - DCN RECYCLING, CORP. - At the Material Processing & Storage Area there were approximately four (4) 1cy yard "white cloth" bags with motor engine parts and other metals leaking used oils on the concrete floor without any means of control. Picture 19--DCN RECYCLING, CORP. - As observed at the Material Processing & Storage Area, there were lots of leak incidents on the concrete floor that appears to contain motor engine fluids that migrated and heavily impacted with used oils the backyard soils near the property perimeter fence. Picture 20 - DCN RECYCLING, CORP. - As observed at the Machine Shop Area , there were approximately seven (7) discarded extinguishers placed on the concrete floors without any containment measures or labels. Title: DCN RECYCLING, CORP. , Carolina, Puerto Rico EPA ID: Project: PRN008026791 CEPD-RCRA-22-0425 Pictures taken by: Eduardo Gonzalez August 22, 2022 Picture 21- DCN RECYCLING, CORP. - As observed at the Machine Shop Area, dismantled motor engines with no control or prevention of releases of used oil or stormwater run-off contaminated with transmission fluids, gasoline, diesel, and other motor oil fluids. Picture 22 - DCN RECYCLING, CORP. - As observed at the Machine Shop Area, there was one (1) 5-gallon plastic container open and with used oil not properly labeled with the words, "Used Oil." Picture 23--DCN RECYCLING, CORP. - As observed by the EPA Inspector at the Machine Shop Area, there were approximately over one hundred (100) discarded batteries rolled in plastic firm and placed on a wood pallet without any means of containment measures or labels. Picture 24 - DCN RECYCLING, CORP. - As observed by the EPA Inspector at the Ferrous Metal Collection Area, scrap metals are first segregated by metal properties, crushed with the excavator to reduce metals size, and then immediately sent to the cargo trucks. Title: DCN RECYCLING, CORP. , Carolina, Puerto Rico EPA ID: Project: PRN008026791 CEPD-RCRA-22-0425 Pictures taken by: Eduardo Gonzalez August 22, 2022 Picture 25- DCN RECYCLING, CORP. - As observed by the EPA Inspector at the Ferrous Metal Collection Area, there were two (2) abandoned heavy equipment machine "Sky Tracks" leaking engine motor fluids on soil grounds. Picture 26 - DCN RECYCLING, CORP. - At the Ferrous Metal Collection Areas, there was one water tower and seep collection sump to control and manage stormwater run-on and run-off of the property. The water tower was out of service and the sump was fully filled with sediments and heavily impacted with used oils. Picture 27--DCN RECYCLING, CORP. - The EPA Inspector observed at the Ferrous Metal Collection Areas, piles of scrap metals placed on bare soils and being operated by an excavator leaking oily fluids on the ground. Picture 28 - DCN RECYCLING, CORP. - TThe EPA Inspector observed at the Ferrous Metal Collection Areas, several auto wheels rims some containing lead weights which were not removed along with gas-contained cylinders which were mixed with the scrap metals. Title: DCN RECYCLING, CORP. , Carolina, Puerto Rico EPA ID: Project: PRN008026791 CEPD-RCRA-22-0425 Pictures taken by: Eduardo Gonzalez August 22, 2022 Picture 29 - DCN RECYCLING, CORP. - As observed, the Fuel and Used Oil Storage Area consisted of a metal shed with a ceiling and a secondary containment system and housed two (2) 500-gallon above ground-doble wall tanks to store used oils and diesel clearly labeled. Picture 30 - DCN RECYCLING, CORP. - As observed during the EPA Inspection, there were run-offs from the Facility were accumulated at the Fuel-Oil Station during rain events and were discharged directly toward a nonfunctional sump and then into the sidewalk curb nearby water creek located northwest of the property edge. Picture 31--DCN RECYCLING, CORP. - At the Alloy Wheel Collection Area, all alloy wheels are received, collected and packed in 1-cy white cloth bags. It was observed the most alloy wheel rims contained lead weights were not properly removed before packaging. Picture 32 - DCN RECYCLING, CORP. - The EPA Inspector proceeded to inspect the Compacting Cars Area where crushing and bailing of junked cars is performed. using an ALJON 580 CL machine (i.e., crusher, bailer) at the site. Title: DCN RECYCLING, CORP. , Carolina, Puerto Rico EPA ID: Project: PRN008026791 CEPD-RCRA-22-0425 Pictures taken by: Eduardo Gonzalez August 22, 2022 Picture 33 - DCN RECYCLING, CORP. - As stated by EPA, junked cars contained components that were potential hazardous materials such a gasoline residue in the gas tank and any fluid leaks generated during crushing is collected in the steel tray and/ or 55-gallon drums. Picture 34 - DCN RECYCLING, CORP. - As observed during the EPA Inspection, all drums containing leaking fluids from crushing operations are managed as used oil and disposesd of with Ruben Martinez Used Oil Collection Services. No hazardous waste characterization is performed on the leaking fluids from the crushing operations on routine basis. Picture 35--DCN RECYCLING, CORP. - As observed by the EPA Inspectors at the Compacting Cars Area, there were fluids leaking on the soils and pavement areas flowing toward the entrance and nearby unnamed creek situated northwest of the Facility. Picture 36 - DCN RECYCLING, CORP.--As observed at the Fire Incident Scrapyard Site Area, there were several piles of mixed destroyed and burned scrap metals accumulated at the site including motor engines, car fragments, spent tires, alloy wheels, seats, dashes, steel frames, and PVC pipes. Title: DCN RECYCLING, CORP. , Carolina, Puerto Rico EPA ID: Project: PRN008026791 CEPD-RCRA-22-0425 Pictures taken by: Eduardo Gonzalez August 22, 2022 Picture 37- DCN RECYCLING, CORP. - It was also observed by the EPA Inspector at the Fire Incident Scrapyard Site Area, fluids leaking on the soils and pavement areas flowing toward the entrance and nearby unnamed creek situated northwest of the Facility. Picture 38 - DCN RECYCLING, CORP. - The EPA Inspector observedat Fire Incident, four (4) 55-gallon steel drums with used oil waste content and one (1) 55-gallon drum open and with rags heavily impacted with used not properly labeled with the words, "Used Oil." Title: DCN RECYCLING, CORP. , Carolina, Puerto Rico EPA ID: Project: PRN008026791 CEPD-RCRA-22-0425 Pictures taken by: Eduardo Gonzalez August 22, 2022 Title: Figure 1: DCN Administrative & Recycling, Corp., Carolina, Puerto Rico--Location Photo EPA ID: Project: PRN008026791 CEPD-RCRA-22-0425 Title: Figure 2: DCN Administrative & Recycling, Corp., Carolina, Puerto Rico - Aerial EPA ID: Project: PRN008026791 CEPD-RCRA-22-0425