Document NDD5wKNyEB92eXgdmezL7jbQ

Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Site/Facility Name: Permittee(s): Site/Facility Operator: Site/Facility Address: Latitude: County/Parish: Permit Number: NAICS Code: DSB ID: Clean Water Act Compliance Inspection Report 06/25/2024 National Pollutant Discharge Elimination System (NPDES) Industrial Stormwater CEI Penny's Auto Parts and Salvage Penny's Auto Parts and Salvage Henry E. Archie 13304 Telegraph Road Woodbridge, VA 22192 38.6653 Longitude: -77.2855 Prince William County VAR052115 441330 SIC: 5015 ECAD-5492 Site/Facility Representative(s): Henry Archie, Owner Phone: (703) 643-2011 Virdell Buffington, Jr. Phone: (571) 330-5609 Email: N/A Email: N/A Point of Contact EPA Inspectors: Kaitlin McLaughlin, Environmental Engineer, NPDES Section 2, 3ED32 Phone: (215) 814-2393 Email: McLaughlin.Kaitlin@epa.gov Samuel Magro, Enforcement Inspector, NPDES Section 1, 3ED32 Phone: (215) 814-2158 Email: Magro.Samuel@epa.gov Report Preparer Signature/Date Supervisor Signature/Date DSB ID: ECAD-5492 8/29/2024 Kaitlin McLaughlin (3ED33), NPDES Section 2 JESSICA DUFFY Digitally signed by JESSICA DUFFY Date: 2024.08.30 08:17:52 -04'00' Jessica Duffy (3ED33), Section Chief, NPDES Section 2 Section Table of Contents Penny's Auto Parts and Salvage 06/25/2024 Page I Introduction.................................................................................................................. 3 A Inspection Opening Conference......................................................................... 3 B Weather and Precipitation Conditions............................................................... 3 C Summary of the Facility...................................................................................... 4 II Facility Activity.................................................................................................... 4 III Observations....................................................................................................... 6 IV Records Review................................................................................................... 10 V Closing Conference............................................................................................. 10 VI List of Attachments............................................................................................. 10 DSB ID: ECAD-5492 Page 2 of 11 I. Introduction Penny's Auto Parts and Salvage 06/25/2024 On June 25, 2024, an inspection team composed of staff from the U.S. Environmental Protection Agency ("EPA") Region III (hereinafter, "EPA Inspection Team") conducted an industrial stormwater inspection of the Penny's Auto Parts and Salvage (hereinafter, the "Site" or "Facility"). The purpose of the inspection was to observe compliance with the Clean Water Act (CWA) and to verify compliance with the Facility's National Pollutant Discharge Elimination System (NPDES) Permit No. VAR052115 (hereinafter, the "Permit") and applicable State and Federal regulations. A. Inspection Opening Conference The EPA Inspection Team arrived at the Facility approximately 10:15 a.m. for the inspection. Inspectors met with the following Facility representatives: Name Kaitlin McLaughlin Samuel Magro Amy Dooley Henry Archie Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region III Inspectors and Contractors USEPA Region 3 (215) 814-2393 McLaughlin.Kaitlin@epa.gov USEPA Region 3 (215) 814-2158 Magro.Samuel@epa.gov VADEP Representatives VADEP (571) 866-6085 Amy.Dooley@deq.virginia.gov Site/Facility Representatives Owner, Penny's Auto Parts (703) 643-2011 N/A and Salvage Kaitlin McLaughlin and Samuel Magro displayed their credentials to Mr. Henry Archie, owner of Penny's Auto Parts and Salvage, at the onset of the inspection, and explained the purpose of the inspection was to observe compliance with its Permit. A copy of the Permit is provided in Attachment 1. The EPA Inspection Team informed Mr. Archie that any information that the Facility deemed to be confidential business information ("CBI") should be identified to EPA representatives during the inspection and it would be handled as CBI according to EPA's CBI procedures. Mr. Archie stated that the Facility did not have CBI to identify. B. Weather and Precipitation Conditions During the inspection, the weather was sunny and approximately 90 F. National Oceanic and Atmospheric Administration (NOAA) National Weather Service precipitation data for the date of the inspection and 5 days prior are provided in the Table 2 below: DSB ID: ECAD-5492 Page 3 of 11 Penny's Auto Parts and Salvage 06/25/2024 Table 2. Precipitation Data Station Name Date WOODBRIDGE 5.9 NW, VA US US1VAPW0010 WOODBRIDGE 5.9 NW, VA US US1VAPW0010 WOODBRIDGE 5.9 NW, VA US US1VAPW0010 WOODBRIDGE 5.9 NW, VA US US1VAPW0010 WOODBRIDGE 5.9 NW, VA US US1VAPW0010 WOODBRIDGE 5.9 NW, VA US US1VAPW0010 6/20/2024 6/21/2024 6/22/2024 6/23/2024 6/24/2024 6/25/2024 Precipitation Amount (inches)1 0.00 0.00 0.00 0.00 0.00 0.00 C. Summary of the Facility The Facility is located at 13304 Telegraph Road, Woodbridge, VA 22192. The Permit identifies the permittee as Penny's Auto Parts and Salvage, which uses the 13059 Minnieville Road, Woodbridge, VA 22192 as a billing address. The Facility is owned and operated by Mr. Henry Archie. Mr. Archie stated that he is the only employee at the Facility but that Mr. Virdell Buffingon, Jr. assists with paperwork periodically. The Facility has one outfall, Outfall 001, on the southeast corner of the property. Mr. Archie stated that flow goes to Marumsco Creek, which is tributary to the Potomac River. The Facility encompasses three acres, all of which are used for industrial activity. Mr. Archie explained that vehicles arriving onsite are placed in the outdoor pre-processing holding area located in the southeastern area of the Facility. Mr. Archie stated that vehicles are brought to an uncovered processing rack/fluid removal area where batteries are stripped, fluids are drained, and major components are removed. Oils and fuel are drained separately into drums and burned in a furnace. The vehicles are then transferred and stored in an outdoor post-processing holding lot. There is no vehicle crusher located onsite. The Facility also has a covered garage, where vehicle parts are stored, and an office. The Facility has vehicle components, such as tires, transmissions, engines, and fuel tank parts piled and stored throughout the lot. II. Facility Activity As part of the inspection process, the EPA Inspection Team visually observed the site conditions in the presence of the Mr. Archie. The primary purpose of the inspection was to review industrial processes and operations at the Facility. Photographs were taken during the inspection by Mr. Samuel Magro. Photographs used to support the observations in this report are included in Attachment 2, Photograph Log. The 1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). DSB ID: ECAD-5492 Page 4 of 11 Penny's Auto Parts and Salvage 06/25/2024 photographs for this report have been processed using EPA Region 3's Photo Management Process. A camera generated file name (e.g., P1010001) is assigned to each photograph as part of the process. The file names generated by the camera are used to identify each photograph in the Main Narrative and Photographs Log of this inspection report. Unused photographs are digitally stored and maintained in the inspection file. Unused photographs are available upon request. The EPA Inspection Team began the Facility walk-through at the entrance located off Telegraph Road. The EPA Inspection Team observed the pre-processing holding area and the exterior of the trailer office (Photos P6250001 and P6250002). Around the back side of the office building, the EPA Inspection Team observed miscellaneous tanks, drums, and buckets. One of the buckets was filled with an unknown oily liquid with a sheen (Photos P6250053 and P6250054). The EPA Inspection Team continued along the northeastern perimeter of the Facility and observed a tire storage area (Photos P6250003 and P6250004) before continuing to the fluid removal area/disassembly shop (Photos P6250052, P6250011 and P6250005). In front of the fluid removal area/disassembly area the EPA Inspection Team observed several material piles and sections. Photo P6250006 shows vehicle batteries outside on the ground. Photos P6250009 and P6250010 show various containers filled with unknown waste oils and fluids. There is a retrofitted oil tank that is being used as an incinerator in the fluid removal area that Mr. Archie states he uses to burn oil and gas (Photo P6250008). Photo P6250037 shows staining on the ground outside of the disassembly shop doors. Photo P6250034 shows the interior of the disassembly shop, directly adjacent to the doors. Photos P6250033, P6250035, P6250027 and P6250028 show other materials that are stored in the disassembly shop. The EPA Inspection Team continued through the Facility to an outdoor vehicle processing rack located northwest of the fluid removal area/disassembly shop (Photos P6250036 and P6250004). In the vehicle processing rack area, the EPA Inspection Team observed a drum filled with an unknown liquid (Photo P6250030). The surface of the liquid had an oil sheen appearance. Also in the vehicle processing rack area, there was a full bottle of motor oil, rusted drums, and rusted paint cans (Photo P6250029). Photo P6250031 shows the staining on the ground under the vehicle processing rack and Photo P6250032 shows the plugged-in power washer under the vehicle processing rack. Across from the fluid removal area/disassembly shop there is another parts storage area. In this area, the EPA Inspection Team observed batteries (Photo P6250038), tire rims (Photo P6250007), transmission parts (Photo P6250050), and engine parts (Photo P6250051) in uncovered areas across the facility. DSB ID: ECAD-5492 Page 5 of 11 Penny's Auto Parts and Salvage 06/25/2024 The EPA Inspection Team continued towards the back of the Facility where vehicles are stored post-processing. Photo P6250012 shows the view of the road leading to the post-processing storage area. Photo P6250018 and P6250019 show overview pictures of vehicles in the postprocessing storage lot. Once in the back lot, the EPA inspection Team observed several processed vehicles that still contained fluids. Photo P6250014 shows brake fluid in vehicle 1. Photos P6250015, P6250016, and P6250017 show power steering fluid and coolant in vehicle 2. Photo P6250021 shows power steering fluid in vehicle 3. The EPA Inspection Team then reached the western property line (Photo P6250020). Continuing south within the Facility, the EPA Inspection Team noticed the ground sloping downward until the Team reached the southwest corner of the Facility and property boundary (Photo P6250022). Photos P6250025 and P6250026 show photos of petroleum staining on the ground in the southwest area of the post-processing vehicle storage area. Photo P6250013 shows an empty storage tank in the southwest area of the post-processing vehicle storage area. Along the southern edge of the Facility, the EPA inspection Team observed gaps along the bottom of the fence (Photos P6250023 and P6250024). The EPA Inspection Team continued towards the southeastern corner of the Facility. The EPA Inspection Team observed a burn area with ash and staining on the ground (Photos P6250039 and P6250040). The EPA Inspection Team also observed a white van with the doors open (Photo P6250045). Inside the van, there was a propane tank (Photo P6250043), insulation materials (Photo P6250042), and paint cans (Photo P6250044). At the southeast corner of the property, the EPA Inspection Team observed the sampling location of outfall 001(Photo P6250041). The condition of the area was very overgrown and dry at the time of the inspection. The EPA Inspection Team then left the property and doubled back to outside of the property to see the location of Outfall 001. Photo P6250046 shows a picture of Outfall 001 with the exact location indicated by flags. Photos P6250047 and P6250048 show the view from Outfall 001 looking downhill away from the property. The ground was dry at the time of the inspection. The EPA Inspection Team concluded the Facility walkthrough outside of the Facility's office. III. Observations After the inspection opening conference, the Inspection Team performed a Facility walkthrough. As part of the inspection, the Inspection Team visually observed Facility conditions and documented those conditions through photographs. The following section presents the Inspection Team's observations relative to the Facility's Permit requirements. DSB ID: ECAD-5492 Page 6 of 11 Records Penny's Auto Parts and Salvage 06/25/2024 Part II.B.2 of the Permit states: "The permittee shall retain copies of the SWPPP, including any modifications made during the term of this permit, records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the registration statement for this permit, for a period of at least three years from the date that coverage under this permit expires or is terminated. This period of retention shall be extended automatically during the course of any unresolved litigation regarding the regulated activity or regarding control standards applicable to the permittee, or as requested by the board." Observation 01: At the time of the inspection, Mr. Archie did not have any records or documentation on site at the Facility. Following the inspection, neither Mr. Archie nor Mr. Buffington were willing and/or able to provide any records or documentation. Stormwater Pollution Prevention Plan (SWPPP) Part III of the Permit states: "A stormwater pollution prevention plan (SWPPP) shall be developed and implemented for the facility covered by this permit. The SWPPP is intended to document the selection, design, and installation of control measures, including BMPs, to minimize the pollutants in all stormwater discharges from the facility, and to meet applicable effluent limitations and water quality standards." Observation 02: At the time of the inspection, the Facility did not have a SWPPP document developed or implemented. Sector Specific Permit Requirements - Automobile Salvage Yards Part IV.B of the Permit states: "Spill and leak prevention procedures. All vehicles that are intended to be dismantled shall be properly drained of all fluids prior to being dismantled or crushed, or other equivalent means shall be taken to prevent leaks or spills of fluids upon arrival at the DSB ID: ECAD-5492 Page 7 of 11 Penny's Auto Parts and Salvage 06/25/2024 site, or as soon thereafter as feasible. All drained fluids shall be managed to minimize leaks or spills." Observation 03: The EPA inspection Team did not observe any procedures to prevent spills and leaks at the time of the inspection. Specifically, around the back side of the office building, the EPA Inspection Team observed miscellaneous tanks, drums, and uncovered buckets filled with an unknown oily liquid with a sheen (Photos P6250053 and P6250054); in front of the fluid removal area/disassembly area, the EPA Inspection Team observed vehicle batteries outside on the ground (Photo P6250006), various containers filled with unknown waste oils and fluids (Photos P6250009 and P6250010), and staining on the ground outside of the disassembly shop doors (Attachment 2, P6250037); in the vehicle processing rack area, the EPA Inspection Team observed a drum filled with an unknown oily liquid with a sheen (Photo P6250030), a full bottle of motor oil, rusted drums, and rusted paint cans (Photo P6250029), and staining on the ground under the vehicle processing rack (Photo P6250031); in the parts storage area across from the fluid removal area/disassembly shop, the EPA Inspection Team observed batteries (Photo P6250038), tire rims (Photo P6250007), transmission parts (Photo P6250050), and engine parts (Photo P6250051); in the post-processing vehicle storage lot, the EPA inspection Team observed several processed vehicles that still contained fluids. Photo P6250014 shows brake fluid in vehicle 1. Photos P6250015, P6250016, and P6250017 show power steering fluid and coolant in vehicle 2. Photo P6250021 shows power steering fluid in vehicle 3; in the southwest corner of the Facility, the EPA Inspection Team observed petroleum staining on the ground (Photos P6250025 and P6250026); in the southeastern corner of the facility, The EPA Inspection Team observed a burn area with ash and staining on the ground (Photos P6250039 and P6250040); and along the southern edge of the Facility, The EPA Inspection Team observed a white van with the doors open containing a propane tank (Photo P6250043), insulation materials (Photo P6250042), and paint cans (Photo P6250044). Part IV.B of the Permit states: "Inspections. Upon arrival at the site, or as soon thereafter as feasible, vehicles shall be inspected for leaks. Any equipment containing oily parts, hydraulic fluids, any other types of fluids, or mercury switches shall be inspected at least quarterly (four times per year) for signs of leaks. All vessels, containers, or tanks and areas where hazardous materials and general automotive fluids are stored, including mercury switches, brake fluid, DSB ID: ECAD-5492 Page 8 of 11 Penny's Auto Parts and Salvage 06/25/2024 transmission fluid, radiator water, and antifreeze, shall be inspected at least quarterly for leaks. Quarterly inspection records shall be maintained with the SWPPP." Observation 04: Mr. Archie does not inspect the Facility quarterly and does not document or maintain any records of inspections. Part IV.B of the Permit states: "Employee training. Employee training shall, at a minimum, address the following areas when applicable to a facility: proper handling (collection, storage, and disposal) of oil, used mineral spirits, antifreeze, mercury switches, and solvents." Observation 05: At the time of the inspection, there were no records of any employee training. Part IV.B of the Permit states: "Management of runoff. The permittee shall implement control measures to divert, infiltrate, reuse, contain, or otherwise reduce stormwater runoff to minimize pollutants in discharges from the facility. The following management practices shall be used to prevent or reduce the discharge of pollutants to surface waters: a. Berms or drainage ditches on the property line used to help prevent run-on from neighboring properties; b. Berms for uncovered outdoor storage of oily parts and engine blocks; c. Aboveground liquid storage; d. The installation of detention ponds, filtering devices, or oil/water separators; and e. Another control measure used to prevent or reduce the discharge of pollutants to surface waters." Observation 06: The EPA inspection Team did not observe any stormwater control measures in place to manage stormwater runoff at the time of the inspection. DSB ID: ECAD-5492 Page 9 of 11 IV. Records Review Penny's Auto Parts and Salvage 06/25/2024 During the opening conference, the EPA Inspection Team asked to review documentation such as the NPDES Permit, recent DMRs, the Facility SWPPP, self-inspection reports, lab results, etc. Mr. Archie states that he did not have any documentation on site. When asked if he kept any documentation electronically, Mr. Archie said no. The EPA Inspection Team asked if Mr. Archie would be able to provide any of the requested documentation, he said no but that Mr. Buffington might have some documents. VADEP representatives stated that they might be able to provide some documentation when they go back to their office after the inspection was over. On the day of the inspection, Amy Dooley from VADEP emailed recent DMRs and a copy of the Permit to EPA. This copy of the Permit is effective as of July 1, 2024 and is provided in Attachment 3. The DMRs provided by VADEP are included in Attachments 4, 5, 6, 7, and 8. The EPA Inspection Team spoke with Mr. Buffington by phone on July 26, 2024 at approximately 10:30am to ask for any documentation on Penny's Auto Parts and Salvage. Mr. Buffington stated that he did not have any documentation to provide. V. Closing Conference At the conclusion of the onsite inspection, the EPA Inspection Team conducted a closing conference with Mr. Archie and shared preliminary observations. The EPA Inspection Team reiterated that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by the EPA Inspection Team upon the additional review of records and documentation. Additional observations may be contained in this inspection report that were not identified at the time of the closing conference after the additional review of materials following the inspection. The inspection concluded at approximately 11:45 a.m. VI. List of Attachments Attachment 1: Attachment 2: Attachment 3: Attachment 4: Attachment 5: NPDES Permit VAR052115 Effective July 1, 2019 Photograph Log NPDES Permit VAR052115 Effective July 1, 2024 DMR Jan - June 2023 DMR Jul - Dec 2023 DSB ID: ECAD-5492 Page 10 of 11 Attachment 6: Attachment 7: Attachment 8: DMR Jan - June 2024 TMDL DMR Jul - Dec 2023 TMDL DMR Jan - June 2024 Penny's Auto Parts and Salvage 06/25/2024 DSB ID: ECAD-5492 Page 11 of 11