Document 3JNYvnL501KyNwOdq8Qd1NwQx

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1, ECAD - WCB 5 Post Office Square - Suite 100, Boston, MA 02109-3912 Clean Water Act (CWA) Inspection Report Program: Industrial Stormwater Permittee Name: Weber Auto & Truck Parts Inspection Type: Compliance Evaluation Inspection (CEI) NPDES / ICIS No.: NHR053298 Inspection Entry Date: November 6, 2023 Inspection Entry Time: 1:54 PM (EDT) Inspection Exit Date: November 6, 2023 Inspection Exit Time: 2:45 PM (EDT) Facility Inspected: Weber Auto & Truck Parts 135 Pond Island Road, Derry, NH 03038 Lat, Long: 42.8684 , -72.2602 NAICS / SIC Code: 5015-Motor Vehicle Parts, used; 5093 - - Scrap & Waste Materials; 3341 - Secondary Smelting and Refining of Nonferrous Metals EPA Reviewer: Alex Rosenberg Digitally signed by ALEX ROSENBERG Analy Date: 2023.1-025'.002 ' 0 11:23:38 State Representative(s): Laurel Pushee (NH DES) On - site Facility Representative(s): Nancy Piccirilli, Office Administrator, nancy@weberautoparts.com, (603) 432-2084 Responsible Official: Gina Piccirilli, Director, gina@weberautoparts.com, 781-858-2084 Name and Signature of Inspector Phone Number / Email Date: Robert Naeser - Contract Inspector, PG Environmental (720) 789-8049 12/18/2023 RH rob.naeser@pgenv.com INTRODUCTION: On November 6, 2023, U.S. Environmental Protection Agency contractor, PG Environmental, conducted an industrial stormwater Compliance Evaluation Inspection (CEI) at Weber Auto & Truck Parts located in the Derry, New Hampshire, Rockingham County (Facility or Site). Mr. Robert Naeser, an EPA Clean Water Act (CWA) credentialed inspector (EPA Inspector) led the inspection, presented credentials to the On - site Facility Representative, Nancy Piccirilli, upon arrival at the Facility, and conducted an opening conference. The purpose of the CEI was to assess the Facility's compliance status with respect to EPA's 2021 Industrial Stormwater Multi - Sector General Permit (2021 MSGP). At the time of the inspection, the On - site Facility Representative did not know if a notice of intent (NOI) was submitted for coverage under the 2021 MSGP. The On - site Facility Representative contacted Aries Engineering, the Facility's engineering consultant (consultant) and the consultant was unable to produce an NOI. The inspection was conducted on November 6, 2023. The EPA Inspector returned to the Facility on November 8, 2023 to speak with John Piccirilli (co - Director) about whether the Facility had submitted a NOI for coverage under the 2021 MSGP. The EPA Inspector did not walk the Facility on November 8, 2023. ED_019088A_00012921-00001 Weber Auto & Truck Parts CEI Report On November 9, 2023, following the inspection, Gina Piccirilli (co - Director and responsible official) emailed a copy of the EPA's letter from 2021 acknowledging receipt of the NOI for 2021 MSGP coverage and stormwater pollution prevention plan (SWPPP) to the EPA Inspector. These are attached as Appendix B and C. Weather conditions at the time of the inspection were overcast skies and temperatures of approximately 48 F. According to precipitation data from the closest National Oceanic and Atmospheric Administration (NOAA), weather station, at the Concord Municipal Airport, NH, received approximately 0.04 inches of rainfall on November 5, 2023, the day before the inspection. ATTACHMENTS: Appendix A-Photograph Log Appendix B-2021 MSGP NOI EPA Letter Appendix C-SWPPP FINDINGS AND OBSERVATIONS: Facility Description The Facility, Weber Auto & Truck Parts, is a salvage vehicle parts recycling facility. The Facility is 10 acres and has been operating at this location since 1962. The Facility is primarily engaged in activities classified under Standard Industrial Classification (SIC) Codes 5015-Motor Vehicle Parts, used and 5093-Scrap & Waste Materials. The Facility SWPPP also lists SIC code 3341-Secondary Smelting and Refining of Nonferrous Metals as a co - located industrial activity. Per the SWPPP, and EPA Inspector observations, activities that take place at the Facility include vehicle fluid and parts removal as well as occasional auto repair, vehicle crushing, metal bailing, and aluminum smelting. Facility equipment is powered by diesel and gasoline which are stored and dispensed inside the fluid's recovery building. The Facility burns used motor oil and fuel oil for on - site heating. The main buildings on - site are the office / parts storage / oil storage building, the fluids recovery building, and the smelting shed. The office / parts storage / oil storage building is located on the northern side of the Facility, adjacent to Pond Island Road. This building stores fuel oil and holds the oil burning furnace (refer to Appendix A, Photograph 13). Incoming vehicles are drained of motor oil, gasoline, and antifreeze inside the fluids recovery building (refer to Appendix A, Photographs 2 and 20). Recovered gasoline, used motor oil, and antifreeze are stored in the fluid recovery building. Gasoline is used in Facility equipment and the motor oil is relocated to the office / parts storage / oil storage building for burning when capacity is available. Aluminum is smelted into blocks in the smelting shed. The Facility's outdoor industrial activities include parking for salvage vehicles (pre - processing), storage of processed vehicles, stockpiling of metal recycling, bailing, and storage of aluminum blocks (refer to Appendix A, Photographs 3, 4, 6, 7, 8, 9, 11, and 12). The bailer bales ferrous metal from the stockpiles. Weber Auto & Truck Parts CEI Inspection Date: November 6, 2023 2 ED_019088A_00012921-00002 Weber Auto & Truck Parts CEI Report An unnamed surface water flows north approximately 100 feet from the southeastern and eastern perimeters of the Facility. The unnamed surface water would receive stormwater discharges from the Facility (refer to Appendix A, Photographs 15, 16, 17, and 18). The unnamed surface water flows north to Ballard Pond. The National Wetlands Inventory (NWI) maps a wetland on all sides of the Facility, except for the northern side which abuts Pond Island Road (refer to Figure 1). National Wetlands Inventory surface waters and wetlands TM GET DATAPRINTQFIND LOCATION BASEMAPS > MeasureLEGEND MAP LAYERS > Wetlands Riparian Riparian Mapping Areas Data Source O Source Image Scale: O image Year Areas of Interest: OFWS Managed Lands O Historic Wetland Data PSSIE PROTEC PSS1 / EMIE 14514 42.867 71.260 U.S. Fish and Wildlife Service, National Standards and Support Team. Wetlanesri Figure 1. NWI Map of the area surrounding Weber Auto & Truck Parts Facility Drainage Systems and Discharges The Facility grounds were surfaced with a mix of concrete and compacted earth. The buildings, metal recycling stockpiles, and bailer were all on concrete slabs. The EPA Inspector observed the processed vehicle and scrap vehicle and parts area, on the east side of the fluid recovery building, and the incoming vehicle storage area were on compacted earth. The EPA Inspector observed that stormwater would flow from the center of the Facility toward the perimeters, consistent with the flow arrows on the SWPPP site map. The SWPPP site map shows a berm constructed around the Facility to contain stormwater on - site. The EPA Inspector observed the Facility perimeter consisted of school bus bodies and trailers (refer to Appendix A, Photographs 5 and 10). Due to safety concerns, the EPA Inspector was not able to observe if a berm was present beyond the bus and trailer perimeter; however, Photograph 10 shows a portion of a berm between the Facility and the surface water to the east. The EPA Inspector was not able to verify if the berm was continuous around the Facility's perimeter because the school buses, trailers, and material stockpiles along the Facility's perimeter were not safe to cross. Weber Auto & Truck Parts CEIInspection Date: November 6, 2023 3 ED_019088A_00012921-00003 Weber Auto & Truck Parts CEI Report The SWPPP Site Map shows Discharge Point 001 at the southernmost part of the berm. Facility stormwater discharges would flow through Discharge Point 001 toward the unnamed surface water through the NWI- mapped wetland areas (refer to Figure 1 and Photographs 15, 16, 17, and 18). See Figure 2 below for an aerial view of the Facility showing the Facility's general layout, location, and approximate flow patterns. Cars Varu Car WEBER AUTO & TRUCK PARTS INC Surfacewater FeaturesFluid Recovery Wednes Building Coverings Catchments Hydrologic Units Google Earth 1905Imagery Date: 10/10/2020 42952 03.60 N 71 15 / 35: 76 W elev 269 ft Figure 1. Google Earth aerial view with the EPA WATERS feature layer of the Facility. The blue arrows depict observed flow patterns, the red line is the approximate Facility perimeter. The approximate location of Discharge Point 001, through the perimeter berm, is depicted with the blue circle - the location was obtained from the SWPPP Site Map. Observations The EPA Inspector observed that the On - site Facility Representative and others employed at the Facility were not familiar with the 2021 MSGP. The EPA Inspector visited the Facility on November 6 and 8, 2023 and both times the Facility's consultant was called regarding whether the Facility was covered under the 2021 MSGP, the consultant did not know. On November 9, 2023, the On - site Facility Representative emailed the EPA Inspector a copy of an EPA letter acknowledging receipt of the NOI for 2021 MSGP coverage and the Facility SWPPP (refer to Appendix B and C). The EPA Inspector observed used motor oil, gasoline, and antifreeze stored in double - walled tanks inside the fluid recovery building (refer to Appendix A, Photograph 2). Used motor oil was also stored inside the Weber Auto & Truck Parts CEIInspection Date: November 6, 2023 4 ED_019088A_00012921-00004 Weber Auto & Truck Parts CEI Report office / parts storage / oil storage building along with the oil burning furnace (refer to Appendix A, Photograph 13). The EPA Inspector observed uncovered metal recycling piles east and south of the fluids recovery building (refer to Appendix A, Photographs 3, 4, 8, 9, and 11). The EPA Inspector observed a truck leaking fuel in the parking area on the north side of the office / parts storage / oil storage building, the truck was dropping off metal and was not owned by the Facility (refer to Appendix A, Photograph 14). The EPA Inspector observed motors and other engine parts stored outside, on the ground, without cover, to the east of the fluids recovery building (refer to Appendix A, Photograph 8). The EPA Inspector observed at least one vehicle in the scrap vehicle and parts area still had an engine, the engine was uncovered (refer to Appendix A, Photograph 6). The EPA Inspector did not observe Discharge Point 001 because the on - site Facility Representative was not aware of how stormwater discharged the Site and a copy of the SWPPP was not available for review. POTENTIAL NONCOMPLIANCE ITEMS: 1. At the time of the inspection, the EPA Inspector identified the following at the Facility: a. The Facility'SWPPP lists SIC Codes 5015-Motor Vehicle Parts, used; 5093-Scrap & Waste Materials; 3341-Secondary Smelting and Refining of Nonferrous Metals and therefore, is regulated under 40 C.F.R. 122.26 for stormwater discharges associated with industrial activity. i. The On - site Facility Representative was not familiar with the 2021 MSGP and was unaware of whether the Facility had submitted a NOI for coverage under the 2021 MSGP. ii. The Facility did not have a SWPPP available for on - site review. b. Motors and other vehicle parts were stored on the ground, uncovered and uncontained. c. Metal recycling stockpiles that were potential pollutant sources including oil, grease, dust, total suspended solids, turbidity, and metals. d. A truck was leaking fuel in the parking lot in front of the Facility. e. Facility stormwater discharges would flow to an unnamed surface water that runs along the east and southeast side of the Facility. The unnamed surface water was approximately 100 feet from the Facility perimeter. f. At least one vehicle in the scrap vehicle and parts area still had an engine, the engine was uncovered. 2. Upon receipt of the SWPPP, the EPA Inspector observed the following: a. The electronic SWPPP provided to the EPA Inspector was not signed and certified. 2021 MSGP Part 6.2.7 states " You must sign and date your SWPPP in accordance with Appendix B, Subsection 11. " b. The stormwater pollution prevention team is identified in the SWPPP by job title, not employee name. 2021 MSGP Part 6.2.1 states " You must identify the staff members (by name or title) that comprise the facility's stormwater pollution prevention team as well as their individual responsibilities. " Weber Auto & Truck Parts CEI Inspection Date: November 6, 2023 5 ED_019088A_00012921-00005 Weber Auto & Truck Parts CEI Report CLOSING: At the conclusion of the inspection, the EPA Inspector held a closing conference with the Facility representative and discussed the preliminary findings and observations of the inspection. The EPA Inspector reiterated that all observations were preliminary and not compliance determinations. The closing conference began at 2:40 PM (EDT) and concluded at approximately 2:45 PM (EDT). On November 8, 2023 John Piccirilli stated that he would talk further with his consultant about 2021 MSGP coverage and email any additional information to the EPA Inspector. Weber Auto & Truck Parts CEI Inspection Date: November 6, 2023 6 ED_019088A_00012921-00006