Document X7DBo2jJkLpm8gN0ndxmNxJww
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 StormwaterInspection Type: Compliance Evaluation Inspection (CEI)
Permittee Name: Chuck DrewNPDES / ICIS No.: (Unpermitted at time of inspection)
Inspection Entry Date: November 7, 2023Inspection Exit Date: November 7, 2023
Inspection Entry Time: 9:06 AM (EDT)Inspection Exit Time: 10:12 PM (EDT)
Facility Inspected: Drew's Auto Parts, A Division of
Camero Heaven, 112 Clark Road, Tilton NH 03276
Lat, Long: 43.448773 , -71.614740
NAICS / SIC Code: Not known by the On - site Facility
Representative
EPA Representative(s) on - site: Damian Bednarz (EPA Region 1)Digitally signed by
ALEX ROSENBERG
Artby Date: 2023.12.20
EPA Reviewer: Alex Rosenberg10:53:12 -05'00 '
State Representative(s): Laurel Pushee (NH DES)
On - site Facility Representative(s):
Chuck Drew, Owner, chuck.drew@camaroheaven.com, 603-286-8855
Responsible Official: Chuck Drew, Owner, chuck.drew@camaroheaven.com, 603-286-8855
Name and Signature of Inspector
Robert Naeser - Contract Inspector, PG Environmental
Roth
Phone Number / EmailDate:
(720) 789-804912/18/2023
rob.naeser@pgenv.com
INTRODUCTION:
On November 7, 2023, U.S. Environmental Protection Agency contractor, PG Environmental, conducted an
industrial stormwater Compliance Evaluation Inspection (CEI) at Drew's Auto Parts, A Division of Camaro
Heaven, located in Tilton, New Hampshire, Belknap 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, Chuck Drew, 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 Facility had not
submitted a NOI for coverage under the 2021 MSGP.
Weather conditions at the time of the inspection were overcast skies with temperatures of approximately 42 F.
According to precipitation data from the closest National Oceanic and Atmospheric Administration (NOAA)
weather station, the Laconia, NH area, received no rainfall in the five days leading up to the inspection.
ATTACHMENTS:
Appendix A-Photograph Log
ED_019088A_00013090-00001
Drew's Auto Parts, A Division of Camero Heaven
CEI Report
FINDINGS AND OBSERVATIONS:
Facility Description
The Facility is owned by Chuck Drew, the On - site Facility Representative. The On - site Facility Representative
stated the Facility started operating at this address more than 20 years ago. The Facility covers 3.5 acres and
employs four people. The Facility dismantles used automobiles for parts and sells used cars and trucks. Vehicles
stored on - site are purchased from the public and at auction. Stored vehicles are parked on a concrete pad before
processing. Processing is the removal of fluids, batteries, and resalable parts from end - of - life vehicles (ELV)
and takes place inside the garage located behind the office. ELVs are parked in the yard after processing, the
yard surface is compacted dirt. The Facility employs an outside contractor, as needed, to crush vehicles and
unsellable parts on - site.
The Facility has one main building at the northern end of the property that includes the office and garage. A
concrete pad south of the main building holds ELVs waiting for processing (refer to Appendix A, Photograph
13). On the eastern side of the Facility there are five shipping containers and one shed that store resalable parts.
An access road runs north to south from the entrance to the ELV storage area. The remainder of the Facility
stores ELVs (refer to Appendix A, Photographs 2, 7, 8, 12, and 15). Figure 1 is an aerial image of the Facility
showing the location of the main building concrete pad, containers and shed, and ELV storage.
The Facility is situated on the south side of a hill and slopes from front (north) to the back (south) (refer to
Appendix A, Photographs 2 and 8). Clark Road borders the Facility's north end, the rest of the Facility is
surrounded by private property.
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*** 5/2023
Containers and
PROTECTION
shed
Surfacewater FeaturesMain BuildingCamaro Heaven
StreamsCamaro Heaven / Drew Auto Parts
Canals
Pipelines
WaterbodiesConcrete Pad
Coastlines
Catchments
Hydrologic Units
EPA Linked Data
ELV storage
ATTAINS Assessments
Beaches
Clean Watersheds Needs Survey
Facilities that Discharge to Water
Facility Registry Service
Fish Consumption Advisories
Fish Tissue Data
Monitoring LocationsUnnamed surface water
Nonpoint Source Projects
Other Linked Data
USGS Streamgages
Image 202 Arbus
Google Earth
1985Imagery Date: 5/20/2023 lat 43.447295 lon -71.613537 elev 443 ft eye alt 1258 ft
Figure 1. Google Earth with EPA WATERS feature layer aerial view of the Facility. The blue arrows depict observed flow patterns, the red line shows
the unnamed surface water mapped by the EPA WATERS extension.
Facility Drainage Systems and Discharges
The yard throughout the Facility is compacted earth. An unnamed receiving water flows along the Facility's
eastern and southern perimeter (refer to Appendix A, Photographs 5, 6, 9, and 10 and Figure 1). The unnamed
receiving water is a tributary to the Winnipesaukee River located approximately 1,200 feet to the south of the
Facility (Figure 2).
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National Wetlands InventoryO FIND LOCATION
surface waters and wetlands
BASEMACS * MeasureLEGEND
Wetlands
MAP LAVERS
Riparian Mapping Areas:
Drew Auto Parts
Unnamed
Surface Water
O image ar
Areas of Interes
OFWS Managed Lands
Historic Wetland Data
PROUSSIE
Wind pesauka River
Winnipesaukee River
43.446 14514 121 6124US Fish and Wildlife PRSOIeEr
vice National Standards and support and Perianes innern, EV VED LIGHT FORGE com a POWERED esri
Figure 2. NWI Map of the area surrounding Drew Auto Parts
The EPA Inspector observed stormwater would flow south from the front of the Facility to the back of the
Facility then discharge to the unnamed surface water. The unnamed surface water was approximately 10 feet
south of the Facility's southern perimeter (refer to Appendix A, Photographs 2, 4, 5, 6, 7, and 8). The EPA
Inspector observed locations along the eastern perimeter where the unnamed surface water was less than five
feet away from the ELV storage area, stormwater runoff from ELVS on the eastern edge of the Facility could
enter the unnamed surface water at these locations (refer to Appendix A, Photographs 9 and 10). The EPA
Inspector observed that the Facility was not equipped with a berm or other structural best management practice
(BMP) to prevent or inhibit the flow of stormwater offsite and into the unnamed surface water.
The EPA Inspector observed the unnamed surface water from the Facility's southern and eastern perimeters.
The EPA Inspector also observed where the unnamed surface water crossed under West Main Street in Tilton,
NH (refer to Appendix A, Photographs 16, 17, and 18). This location was approximately 500 feet south and
downstream from the Facility and approximately 800 feet north and upstream from the Winnipesaukee River.
These distances were estimated using Google Earth.
See Figure 1 above for an aerial view of the Facility showing the Facility's general layout, location, and
approximate stormwater flow patterns.
Observations
The EPA Inspector observed that the Facility was not equipped with a berm or other structural BMP to prevent
or inhibit the flow of stormwater from the Facility and into the unnamed surface water (refer to Appendix A,
Photographs 4 and 7).
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The EPA Inspector observed two 275-gallon tanks, one for used oil and one for used antifreeze, located under
cover on the south side of the main building (refer to Appendix A, Photograph 14). The Facility had one waste
oil burner for disposing of waste oil with an associated 225-gallon tank.
The EPA Inspector observed rill erosion running from the east side of the access road to the ELV storage area
(refer to Appendix A, Photograph 3).
The EPA Inspector observed a pile of used tires on the southern perimeter, between ELV storage and the
unnamed surface water (refer to Appendix A, Photograph 4).
The EPA Inspector observed that most ELVs in the yard were elevated above the ground on rims or tires (refer
to Appendix A, Photographs 8 and 12).
The EPA Inspector observed at least one ELV with an uncovered engine in the ELV storage area in the southern
portion of the Facility (refer to Appendix A, Photograph 11).
The Facility had at least five shipping containers and one shed used to store resalable used parts. The EPA
Inspector observed scrap vehicle parts, including at least one engine, outside of the containers and on the
ground (refer to Appendix A, Photograph 15).
The EPA Inspector observed that waste oil and waste antifreeze were stored in 275-gallon single wall tanks
under an awning on the south side of the main building (refer to Appendix A, Photograph 14). The tanks did not
have secondary containment.
POTENTIAL NONCOMPLIANCE ITEMS:
1. At the time of the inspection, the EPA Inspector identified the following at the Facility:
a. The Facility is engaged in automobile dismantling and resale of used automobile parts (SIC Code 5015
- - Motor Vehicle Parts, used). SIC Code 5015 is regulated under 40 C.F.R. 122.26 for stormwater
discharges associated with industrial activity.
b. The Facility's outdoor areas were used for industrial activities including storage of ELVs, preprocessed
vehicles, scrap parts, and tires.
c. At the time of the inspection, the Facility did not have coverage under the 2021 MSGP for Stormwater
Discharges Associated with Industrial Activity.
d. Facility stormwater, from areas used for industrial activities, discharges to an unnamed surface water
that flows along the eastern and southern Facility perimeters. The unnamed receiving water runs less
than five feet from the eastern perimeter and approximately 10 feet from the southern perimeter. The
EPA Inspector observed discrete conveyance paths from the Facility to the unnamed surface water.
AREAS OF CONCERN:
1. At the time of the inspection, the EPA Inspector identified the following at the Facility:
a. One ELV with an uncovered engine.
b. Scrap parts, including at least one engine, were stored on the ground in front of the storage
containers.
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c. Rill erosion was present along the access road from the front of the Facility / main building to the
ELV storage area.
d. Used tires were piled between the ELV storage area and the unnamed surface water along the
southern perimeter.
e. The Facility was not equipped with a berm or other structural BMPs to prevent or inhibit the flow
of stormwater from the Facility to the unnamed surface water.
f. Secondary containment was not provided for the 275-gallon waste oil and waste antifreeze tanks.
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 10:00 AM
(EDT) and concluded at approximately 10:12 AM (EDT).
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