Document wrZ43GbLgZKnvnyLRob4mwJvQ

EPA REGION 10 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 11/20/2024 09:00 AM (PT) Announced: No 11/20/2024 01:25 PM (PT) Access: Granted 55F, Overcast Water Clean Water Act, NPDES, Stormwater - Industrial Compliance Evaluation Inspection Permittee Name Facility Name Facility/Site Physical Address City, State, Zip Code County Facility GPS Coordinates Perlenfein, Inc American Auto Salvage 3000 Main Street Springfield, Oregon 97478 Lane 44.04584, -122.983041 FRS ID Permit Number SIC 110069604556 ORR803755 5015 (Motor Vehicle Parts, used) Lead Inspector: RAYMOND ANDREWS Date: 2024.12.30 10:40:26 -08'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: Contreras, Peter Peter Contreras EPA Region 10 Digitally signed by Contreras, Peter Date: 2024.12.30 11:02:12 -08'00' contreras.peter@epa.gov (206) 553-6708 American Auto Salvage Permit # ORR803755 SECTION I - Opening Conference I arrived at the American Auto Salvage (the "Site" or "Facility"), located at 3000 Main Street, Springfield, Oregon, at 09:00 AM (PT) on 11/20/2024 for an unannounced inspection. I presented credentials to Nick Brown and informed him I this was there to conduct an inspection to determine compliance with the Clean Water Act (CWA) and the facility's Oregon Department of Environmental Quality (ODEQ) 1200-Z permit for industrial stormwater, permit # ORR803755. This report is based on information supplied by Mr. Brown, my direct observations, and records and reports maintained by the permittee. In addition, information gathered prior to or after the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization Attendee Name Present in Present in Title Opening Conf. Closing Conf. EPA Region 10 Raymond Andrews Lead Inspector Yes Yes ODEQ Kathy Jacobsen Stormwater Specialist Yes Yes American Auto Salvage Nick Brown General Manager Yes Yes Facility Information Responsible Official Nick Brown Type of Operation Auto salvage Size of Facility Site 2.75 acres Is property owned or The property is leased. leased? Receiving Water Mill Race Creek Number of Employees The facility has 12 employees that work from 8:00am until 4:30pm Monday through Friday. Type of Materials The facility stores used vehicles and auto part outdoors. and/or Vehicles Stored Outdoors Personnel Conducting Mr. Brown conducts sampling and inspections. Inspections/Sampling Sampling Locations The stormwater is sampled on the west side of facility as it exits the transport pipe to flow into Mill Creek. Number/Location of Outfalls The facility discharges though a single outfall. The facility has three catch basins, which collect stormwater and are connected in series. The basins are encircled by bio-char bags to reduce the quantity of copper that is discharged. The bio-char bags were implemented as part of the Tier 2 Corrective Action Plan. Once the water reaches a certain level in catch basic 3, the water flows from underground piping to the discharge point. BMPs/Stormwater Treatment The facility's BMPs/Treatment include the three catch basins, bio char booms around catch basins, berms, and site grading to direct the stormwater flow to the catch basins. Has the facility had At the time of the inspection, Mr. Brown told me he would send to me any any benchmark copies of benchmark exceedances the facility had within the 12 months prior exceedances in the last to the month of inspection. I never received the documents. I sent Mr. Brown 12 months? an email on 12/09/2024 asking for the information with a follow-up email on 12/12/2024. I never received a response. 2 of 6 American Auto Salvage Permit # ORR803755 Was the Tier 2 The plan was implemented. The biochar booms were and an integral part of Stormwater Treatment the of the Tier 2 plan. Plan implemented? Was the Tier 2 Mr. Brown Does not yet know if the plan is effective because the first sample Stormwater Treatment taken since its implementation was November 20, 2025, the day prior to the Plan effective? inspection, and the results have not been received. Do you still have a monitoring waiver? The facility has a monitoring waiver for all parameters except copper. Location Description Discharge/Monitoring Point The discharge/monitoring point is the point where the pipe carrying stormwater from the catch basin exits the ground and discharges into the receiving water, Mill Race Creek. Used Vehicle Storage Yard The primary area of the facility where "waste" cars are stored until disposal. SECTION II - Observations Location: Used Vehicle Storage Yard Observation #: RA1-OB-001 Date: 11/20/2024 Weather: 55F, Overcast At the time of the inspection, I observed two dumpsters in different areas of the yard that were not covered. One of the dumpsters contained miscellaneous items. The second dumpster contained old radiators that had been removed from waste vehicles. Photos 1. IMG-2024112012180618695352.jpg 2. IMG-202411201224562456115206.jpg Location: Used Vehicle Storage Yard Observation #: RA1-OB-002 Date: 11/20/2024 Weather: 55F, Overcast At the time of the inspection, I observed two catch basins that were encircled with bio-char bags. The bags were use as Best Management Practices (BMPs) to filter pollutants from the stormwater prior to the water entering the catch basin. The bio-char bags around catch basin 1 had been flattened, were ineffective, and needed replacement/maintenance. The bio-char bags around catch basin 2 were also ineffective and needed replacement/maintenance. (The facility has three catch basins. Catch basin three was properly encircled by the bio-char bags.) Photos 1. IMG-20241120121921192196302.jpg 2. IMG-20241120122719271996898.jpg Location: Discharge/Monitoring Point Observation #: RA1-OB-003 Date: 11/20/2024 Weather: 55F, Overcast The site discharges into a ditch through a 6-inch diameter PVC pipe. The ditch flows to the receiving water, Mill Race Creek. At the time of the inspection, the water level in the ditch had almost fully submerged the discharge pipe. The facility could not obtain a representative sample of its discharge due to the discharge mixing with water from other sources. Photo 1. IMG-202411201237533753177992.jpg 3 of 6 SECTION III - Records Review Records may not be in sequential order. Record: Other - ODEQ Revised Sampling Waiver Email Ref #: RA1-RR-007 Reviewed By: Raymond Andrews American Auto Salvage Permit # ORR803755 AOC: No Reviewed Date: 12/20/2024 Post inspection, I reviewed the revised monitoring waiver sent by the Oregon Department of Environmental Quality (ODEQ) to the facility, dated October 25, 2023. The revised waiver reinstated the facility's requirement to sample for copper. Record: Other - Tier 2 Stormwater Treatment Plan AOC: No Ref #: RA1-RR-006 Reviewed By: Raymond Andrews Reviewed Date: 12/20/2024 Post inspection, I reviewed the facility's Tier 2 Stormwater Treatment Plan (STP), dated January 24, 2023. The STP was created for the facility by Aquarius Environmental, LLC, to address the excessive copper in the facility's discharges as outlined in ODEQ's email from November 16, 2023. Record: Other - Email from ODEQ to Facility AOC: No Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Reviewed Date: 12/20/2024 Post inspection, I reviewed an email from Kathy Jacobsen of the Oregon Department of Environmental Quality (ODEQ), dated November 16, 2023. The email informed the facility that the facility was required to meet Tier 2 Corrective Action requirements based on discharge monitoring report (DMR) data for copper from 2021 through 2022. Record: Other - Facility Training Records AOC: No Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 11/11/2024 At the time of the inspection, I requested to review annual facility training records from 2020 through 2023. The facility provided a sign-in sheet for training conducted in 2020. After 2020, training was tracked electronically. I did not note any areas of concern. Record: Other - Visual Monitoring Reports AOC: Yes Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 11/20/2024 At the time of Inspections, I requested to review the facility's monthly visual monitoring reports from January 2022 through October 2024. The facility was missing visual monitoring reports for: December 2022 June 2023 July 2023 September 2023 October 2023 February 2024 March 2024 April 2024 June 2024 July 2024 October 2024 I told Mr. Brown that reports are required even if there is no discharge and an annotation of "No Discharge" should be made on the report for that month. AOC: The facility did not have 11 of the 34 visual monitoring reports that were requested. 4 of 6 American Auto Salvage Permit # ORR803755 Record: Other - Facility Routine Monthly Inspection Reports Ref #: RA1-RR-002 Reviewed By: Raymond Andrews AOC: No Reviewed Date: 11/20/2024 At the time of Inspections, I requested to review the facility's routine monthly inspection reports from January 2022 through October 2024. All the reports were available. I did not note any areas of concern. Record: Other - Stormwater Pollution Control Plan (SWPCP) AOC: Yes Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 11/20/2024 At the time of inspection, I reviewed the SWPCP, dated October 2024. The cover page of the plan did not have the correct DEQ File # or EPA permit # and was missing the county. SECTION IV - Sampling Activity No sampling was conducted. SECTION V - Areas of Concern Areas of Concern may not be in sequential order. The presentation of Areas of Concern does not constitute a formal compliance determination or violation. AOC Reference #: RA1-RR-001 Records Review: Other - Stormwater Pollution Control Plan (SWPCP) Permit Requirement Schedule A10. of the permit states, in part, "a. Title Page - The title page of the SWPCP must contain the following information: v. File number and EPA permit number as indicated in permit coverage documents..." AOC: The plan did not have the correct DEQ File # or EPA permit #. AOC Reference #: RA1-OB-001 Location: Used Vehicle Storage Yard Permit Requirement Schedule A.1.c of the permit states, in part, "Cover all waste contained in bins or dumpsters where there is a potential for drainage of stormwater through the waste to prevent exposure of stormwater to these pollutants." AOC: At the time of the inspection, I observed two dumpsters in different areas of the yard that were not covered. One of the dumpsters contained miscellaneous items. The second dumpster contained old radiators that had been removed from waste vehicles. AOC Reference #: RA1-OB-002 Location: Used Vehicle Storage Yard Permit Requirement Schedule A.2.a of the permit states, in part, "The permit registrant must select, design, install, implement and maintain control measures, including all best management practices (BMPs)..." AOC: At the time of the inspection, I observed two catch basins that were encircled with bio-char bags. The bags were use as Best Management Practices (BMPs) to filter pollutants from the stormwater prior to the water entering the catch basin. The bio-char bags around catch basin 1 had been flattened, were ineffective, and needed replacement/maintenance. The bio-char bags around catch basin 2 were also ineffective and in need of replacement/maintenance. 5 of 6 American Auto Salvage Permit # ORR803755 AOC Reference #: RA1-OB-003 Location: Discharge/Monitoring Point Permit Requirement Schedule B.7.a.i of the permit states, "Samples must be representative of the discharge." AOC: The site discharges into a ditch through a 6-inch diameter PVC pipe. The ditch flows to the receiving water, Mill Race Creek. At the time of the inspection, the water level in the ditch had almost fully submerged the discharge pipe. The facility could not obtain a representative sample of its discharge due to the discharge mixing with water from other sources. AOC Reference #: RA1-RR-003 Records Review: Other - Visual Monitoring Reports Permit Requirement Schedule B.12.c of the permit states, in part, "Conduct visual inspections at the site on a monthly basis when the facility is in operation." AOC: The facility did not have 11 of the 34 visual monitoring reports that were requested. SECTION VI - Closing Conference I held a closing conference with Facility personnel at 01:25 PM (PT) on 11/20/2024 for the inspection. During the closing conference, I discussed my observations and Areas of Concern I identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - List of Appendices 1. Photo Log 6 of 6 APPENDIX 1: Photo Log Down Grade 11/20/2024 12:17 PM (PT) No CBI Used Vehicle Storage Yard Yard with slight down slope to north. No PII IMG-2024112012170517598656.jpg Photographer: Raymond Andrews 44.04592866, -122.98459158 Dumpster 1 IMG-2024112012180618695352.jpg 11/20/2024 12:18 PM (PT) No CBI No PII Photographer: Raymond Andrews Used Vehicle Storage Yard 44.04592389, -122.98461136 Uncovered dumpster containing miscellaneous items. Catch Basin 1 IMG-20241120121921192196302.jpg 11/20/2024 12:19 PM (PT) No CBI No PII Photographer: Raymond Andrews Used Vehicle Storage Yard 44.04588319, -122.98471248 Catch basin 1 with biochar filer bag showing lack of maintenance. Need replacing. Dumpster 2 11/20/2024 12:24 PM (PT) No CBI No PII Used Vehicle Storage Yard Uncovered dumpster containing old radiators. IMG-202411201224562456115206.jpg Photographer: Raymond Andrews 44.04595495, -122.98464505 Catch Basin 2 IMG-20241120122719271996898.jpg 11/20/2024 12:27 PM (PT) No CBI No PII Photographer: Raymond Andrews Used Vehicle Storage Yard 44.04603593, -122.98493034 Catch basin 2 with biochar bags. Requires maintenance. The bags are ineffective in lower right corner. Catch basin 3 11/20/2024 12:32 PM (PT) No CBI Vegetated area near outfall. Catch basin 3 in good repair. No PII IMG-20241120123201321198184.jpg Photographer: Raymond Andrews 44.0460117, -122.98489131 Discharge Point IMG-202411201237533753177992.jpg 11/20/2024 12:37 PM (PT) No CBI No PII Photographer: Raymond Andrews Discharge/Sampling Point 44.04587403, -122.9858689 The facility cannot acquire a representative sample due to the discharge pipe being partially submerged. Water discharges into a ditch which flows to Mill Race creek.