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FIRST CLASS AND CERTIFIED MAIL 9214 7969 0099 9790 1424 8109 75

February 26, 2024

JOSHUA COHEN
c/o COLUMBIA AUTO PARTS INC
700 MAIN STREET
WEST COLUMBIA, SC 29170

Re: Compliance Evaluation


Storm Water Pollution Prevention Plan (SWPPP)
COLUMBIA AUTO PARTS, INC, County: Lexington
NPDES Certification # SCR002101 v3.0
Inspection Date: November 15, 2023 Inspector: Paul F Wise

Dear Permittee:

The South Carolina Department of Health and Environmental Control (SCDHEC) conducted
a Storm Water Compliance Evaluation Inspection (SWCEI) at the above referenced facility.
The permittee is authorized to discharge under the South Carolina NPDES General Permit
for Storm Water Discharges Associated with Industrial Activity (Permit No. SCR000000).

Based on the findings of the inspection, a rating of Unsatisfactory has been assigned to the
implementation of your storm water management program. Please respond in writing to
this office by April 15, 2024, stating what action has been taken to address the
deficiencies. Attach a copy of this letter to your reply.

Citation Description
6.2.1.1 Failure to perform quarterly benchmark monitoring.
2.1.2.1.h Failure to minimize exposure of discharges from
manufacturing and processing areas to stormwater
systems. Failure to ensure that drains from a shop
drain do not drain to the stormwater drainage
system. A small oil water treatment system is located
behind the garage. Oily water from the garage floor
drains is discharged to the treatment system.
Treated water from the unit is pumped to small
stormwater pond which does not discharge.
2.1.2.1.f Failure to minimize exposure of manufacturing,
processing and storage areas to stormwater. Failure
to drain fluids from vehicles prior to on-site storage.
Fluids are not drained from vehicles prior to on-site
storage.
5.1.8 and Section 3 Failure to update plan.
8.M.4 Failure to provide inspections as required by this
Sector.
8.M.2.1 Failure to provide spill and leak prevention
procedures as required by this Sector.
6.2.4.2.b Failure to follow TMDL requirements.
4.3.1 Failure to conduct Annual Comprehensive Site
Inspections as required by the permit.
6.2.1.1 Failure to perform quarterly benchmark monitoring.
4.2.1 Failure to conduct Quarterly Visual assessments as
required by the permit
6.2.4.2.a Failure to evaluate, provide pollutant of concern
information, and/or monitor for discharges to
impaired waters on the 303-d List.
4.1.1 Failure to conduct Routine Facility Inspections as
required by the permit.
2.1.2.3 Failure to maintain control measures that are used
to achieve effluent limits in this permit. Erosion was
noted on the roads on the lower part of the site.
There was no evidence of sediment leaving site.
8.M.2.2 Failure to provide employee training as required by
this Sector.
1.3.1.a.iv Failure to submit a complete and accurate Notice of
Intent (NOI) in as prescribed in this section.
5.3.a Failure to retain a copy of the current SWPPP at the
facility and make it immediately available to the
Department; Tribal or local agencies approving
storm water management plans; and the operator of
an MS4 receiving discharges from the site at the time
of an onsite inspection or upon request.
4.1.1 Failure to conduct Routine Facility Inspections as
required by the permit.

Mr. Cohen, you discussed with the Department the possibility of using the oily water
treatment unit simply as an accumulation unit for the wastewater generated from your shop
building and not as a treatment unit. The accumulated wastewater would be periodically
pumped to containers that would be shipped off site for proper treatment and disposal. If
you make this change to the way you are using the oily water treatment unit, wastewater
construction permitting will not be necessary. You also indicated that if you make this
change, you would cease discharging wastewater to the pit. In accordance with South
Carolina Regulation R.61-9.505.1.b(1), you must cease discharging wastewater to the pit
since you do not have the required land application permit for that activity.
Sending your wastewater offsite is addressed by South Carolina Regulation R.61-67.300.G.2
as a “pump and haul” activity for industrial wastewater. Please note that if the volumes of
your shipments exceed the thresholds in this regulation (100 gallons per day, 700 gallons
per week, and 3000 gallons per month) you must seek approval from the Department for
the pump and haul activity unless your shipments are intermittent as defined by the
regulation. You have indicated your expected volumes will be significantly less than these
volumes.

You are requested to submit an updated Stormwater Pollution Prevention Plan


(SWPPP) addressing operations at Columbia Auto Parts by April 15, 2025.

Please note that failure to comply with the NPDES permit conditions places you in
violation of Sections 48-1-90 and 48-1-110 of the Code of Laws of South Carolina.

If you have any questions concerning the inspection report, contact Paul F Wise, contact me
803-898-4181.

Sincerely,

Paul F Wise
Stormwater Compliance Manager
Water Pollution Compliance Section
Bureau of Water
WISEPF@dhec.sc.gov
(803) 898-4181
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
General Information
Permit Number SCR002101

1. Inspection Start Date 11/15/2023

1a. Inspection Start Time 1:30 PM

2. Inspection End Date 11/16/2023

2a. Inspection End Time 4:00 PM

Inspection was initiated on 11/15/23 at 01:30 pm. Activities on 11/15/2023 consisted of walking
the site and inspecting the inside of the onsite storage facility and garage where cars are
dismantled and parts are stored. Mr. Cohen participated in a follow-up meeting at DHEC offices at
2600 Bull Street pm 11/16/23 wherein he provided documents which were not accessible on
11/16/23. The floors of the office where these materials are housed had just been stripped and the
newly applied wax was still wet. It was agreed that Mr. Cohen would bring the documents to DHEC
offices the next day (11/16/16).
3. Facility/Department On-Site Representative Information
Name Title Telephone Number Attended Closing
Conference
Josh Cohen Owner 803-445-8045; email: X
jcohen992@gmail.com
Mel Leaphart SCDHEC X
Paul Wise SCDHEC 803-898-4181 X

4. Is the responsible party's name and mailing address current. If not See comment section.
provide the current information.

Josh Cohen is managing the facility and is listed as the CEO of Columbia Auto Parts. According to
tax records, T&S Real Estate, LLC owns the property and all the equipment associated with the
business and the location. Mr. Tim Dickensheets is the Managing Member of T&S Real Estate, LLC.
Mr. Cohen also works for Mr. Tim Dickensheets. Department staff has asked Mr. Cohen to provide
documentation to support his position that T&S Real Estate does not own or operate Columbia
Auto Parts.
5. Provide a general description of the nature of the industrial activities at
the facility.
The facility receives wrecked vehicles for salvage and scrap metal recycling. (SECTOR M -
AUTOMOBILE SALVAGE YARD) Vehicles are parted out to the general public and
subsequently/eventually crushed and sold for the scrap metal. (SECTOR N - SCRAP METAL AND
WASTE RECYLING). The facility also receives other scrap metal (automobile rims and tires
separately) for recycling.

Section A
When a deficiency is identified, as needed, describe the problem that
causes the deficiency in the comments section of the question.

1. Is the site active and operating?

2/26/2024 6:37 AM 1
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section A
Photo Uploaded: 11/27/2023

Photo Uploaded: 11/27/2023

Photo Uploaded: 11/27/2023

2/26/2024 6:37 AM 2
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section A
Photo Uploaded: 11/27/2023

Photo Uploaded: 11/27/2023

Photo Uploaded: 11/27/2023

2/26/2024 6:37 AM 3
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section A
Photo Uploaded: 11/27/2023

Photo Uploaded: 11/27/2023

Photo Uploaded: 11/27/2023

2/26/2024 6:37 AM 4
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section A
Photo Uploaded: 11/27/2023

Photo Uploaded: 11/27/2023

2. Does it appear that the site can apply for a 'No exposure' Certification?

3. Does the site appear to be eligible to apply for a Notice of Termination?

4. Does the Facility have an Industrial Stormwater Permit?

Violation Determined: 11/15/2023


1.3.1.a.iv
Permit SCR002101 is expired. Mr. Cohen has been invited to his Site in ePermitting to address his
expired coverage, 11/17/23. To date he has not accepted the invite.
5. Is the SIC code provided on the NOI correct?

6. If the SIC Code is not correct, what is it? Explain why it has changed.
Sectors would be M (5015) and N (5093).

2/26/2024 6:37 AM 5
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section B: SWPPP Details
When a deficiency is identified, as needed, describe the problem that
causes the deficiency in the comments section of the question.

1. Was there a SWPPP on site to review?

Violation Determined: 11/15/2023


5.3.a
The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1a. Identify the date the SWPPP was prepared or last updated.

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1b. Is the plan up to date?

Violation Determined: 11/15/2023


5.1.8 and Section 3
The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1c. Is the plan signed by the appropriate person?

1d. Is the plan certified?

1e. Does the SWPPP have a general location map for this facility?

Section C: Pollution Prevention Team Details


When a deficiency is identified, as needed, describe the problem that
causes the deficiency in the comments section of the question.

1. Are all Pollution Prevention Team details contained on the site?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1a. Does the SWPPP identify team member(s) by name or title?

1b. Does the SWPPP identify each team member's responsibilities?

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COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section C: Pollution Prevention Team Details
1c. Do the team's responsibilities address all aspects of the SWPPP?

Section D: Discharges to Impaired Waters on the 303-d


List
1. Have all items regarding the 303-d listed waters been completed as
required?

Violation Determined: 11/15/2023


6.2.4.2.a
An evaluation has not been completed under the current permit.
1a. Was an evaluation done to see if the Facility discharges to impaired
water body on the 303-d list?

Violation Determined: 11/15/2023


6.2.4.2.a
An evaluation has not been completed under the current Permit.
1b. If applicable, what impaired water body does the facility discharge to
and what is the pollutant of concern?

1c. If applicable, has the facility monitored (at least 1/year) at each outfall
for the pollutant of concern?

1d. Has the facility provided written documentation that the pollutant is not
present or not expected to be present in the facility’s stormwater discharge?

Section E: Discharges to Impaired Waters that HAS an


established TMDL
Established Total Maximum Daily Load (TMDL)

1. Have all items regarding the TMDL waters been completed as required?

Violation Determined: 11/15/2023


6.2.4.2.b
An evaluation has not been completed under the current Permit.
1a. Was an evaluation done to establish if the Facility discharges to an
impaired water body that has an established TMDL? NOTE: If reply is
“NO”, then checklist is complete.

Violation Determined: 11/15/2023


6.2.4.2.b
An evaluation has not been completed under the current Permit.
1b. If the facility discharges to a TMDL, list the waterbody and the
impairment.

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COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section E: Discharges to Impaired Waters that HAS an
established TMDL
1c. Has the facility conducted monitoring for the pollutant of concern listed
in the TMDL as required by the permit?

Section F: Measures and Controls Details


1. Are all measures and control details in compliance?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1a. Does the SWPPP describe the housekeeping procedures?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1b. Was the preventative maintenance program in compliance? If no,
explain in the comments section.

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1c. Were the spill prevention and response procedures in compliance? If no,
explain in the comments section.

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1d. Was the employee training effort in compliance? If no, explain in the
comments section.

Violation Determined: 11/15/2023


5.1.5.1.a.iv.
Training records were not provided for current imployees.
1e. Are erosion and sediment controls in compliance? If no, explain in the
comments section.

Erosion was noted on the roads on the lower part of the site. This erosion has resulted in sediment
filling the stormwater ponds. There was no evidence of sediment leaving site.
1f. Is stormwater runoff management in compliance? If no, explain in the
comments section.

2/26/2024 6:37 AM 8
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section G: Site Map Details
1. Was the site map correct and contain all required information?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1a. Size of the property in acres or square feet.

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1b. Location of facility buildings, structures and impervious surfaces.

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1c. Direction of stormwater flow (using arrows).

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1d. Locations of all existing structural control measures.

Violation Determined: 11/15/2023


5.1.2
A small oil water treatment system is located behind the garage. Oily water from the garage floor
drains is discharged to the treatment system. Treated water from the unit pumped to small
stormwater pond which does not discharge. The Department has determined that the treatment
unit and the discharge to the stormwater pond are not permitted. The facility has been notified
that the system is not properly permitted. The facility representative indicated that the system can
be eliminated. The oily water can be collected in totes and picked up with other oily water
generated on the site.
1e. Identify receiving waters, if impaired or if a TMDL is assigned.

1f. All stormwater conveyances (pipes, ditches)?

1g. Locations of potential pollutant sources.

2/26/2024 6:37 AM 9
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section G: Site Map Details
1h. Locations of past significant spills or leaks.

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1i. Locations of stormwater monitoring points.

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1j. Stormwater inlet locations.

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1k. Locations of outfalls including a unique ID.

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1l. Drainage area for each outfall.

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1m. If stormwater discharges from the site to an MS4, is the name of the
MS4 listed on the site map?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
1n. Location and description of non-stormwater discharges.

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.

2/26/2024 6:37 AM 10
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section G: Site Map Details
1o. Locations of fueling stations, equipment maintenance, loading and
unloading, etc.

There are no fueling stations or equipment maintenance activities on the site.


1p. Location and source of run-on of pollutants from adjacent property.

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.

Section H: Routine Facility Inspections


1. Are Routine Facility inspections in compliance?

Inspections were not being conducted by the current owner.


2. Are routine facility inspections conducted at least once/quarter?

Violation Determined: 11/15/2023


4.1.1
Inspections were not being conducted by the current owner.
3. Was at least one inspection conducted when stormwater discharge was
occurring?

Violation Determined: 11/15/2023


4.1.1
Routine inspection documentation must include the following:

4a. Inspection date and time.

4b. Full name and signature of inspector

4c. Weather info and description of any discharge at time of inspection.

4d. Any previously unidentified discharges of pollutants from site?

4e. Any control measures needing maintenance or repair?

4f. Any failed control measures that need replacement?

4g. Any incidents of noncompliance observed?

4h. Any additional control measures needed to comply with permit?

2/26/2024 6:37 AM 11
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section I: Potential Pollutant Sources Details
1. Were all Potential Pollutant sources requirements met?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
Does the SWPPP:

2a. List industrial activities exposed to stormwater?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
2b. Inventory potential pollutants exposed to rain now or in the past 3
years?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
2c. Identify where leaks/spill could occur to SW discharges & outfall that
may be affected?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
2d. Identify where leaks/spill occurred the past 3 years?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
2e. Identify the location of any salt storage piles?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.

2/26/2024 6:37 AM 12
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section I: Potential Pollutant Sources Details
2f. Include a summary of discharge sampling data?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
3. Was a Non-Stormwater (SW) Discharge Evaluation completed?

The SWPPP was not available for review at the time of the inspection. Mr. Cohen did bring what
appeared to be a partial document to DHEC offices on Thursday, November 16, 2023. A cursory
review revealed that the document was last updated under the previous owner's name. Therefore
it was not reviewed further.
3a. Was the date of the Non-Stormwater Discharge identified?

3b. Include a description of the evaluation criteria that was used?

3c. Include a list of the outfalls or onsite drainage points that were
observed?

3d. Include a list of the different types of non-SW discharge(s) and source
locations?

3e. Include a description of the action(s) taken, such as a list of control


measures used to eliminate unauthorized discharge(s), if any were
identified.

Section J: Quarterly Visual Assessments


1. Are Quarterly Visual Assessments in compliance?

2. Are stormwater sample visual assessments conducted at least


once/quarter?

Violation Determined: 2/1/2024


4.2.1
Quarterly visual assessment documentation must include the following:

3a. Sample location.

3b. Collection date and time, and visual assessment date and time.

3c. Name and signature of person(s) collecting the sample and performing
assessment.

3d. Nature of the discharge (e.g. runoff, snowmelt).

3e. Observation results (e.g. color, odor, solids present, foam, oil sheen,
etc)

2/26/2024 6:37 AM 13
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section J: Quarterly Visual Assessments
3f. Probable source of any observed contamination.

3g. If applicable, why it was not possible to take samples within the first 30
minutes.

Section K: Annual Comprehensive Site Inspections


1. Are the Annual Comprehensive Site Inspections in compliance?

1a. What was the most recent inspection date?

2. Are Annual Comprehensive Inspections conducted at this facility?

Violation Determined: 11/15/2023


4.3.1
Comprehensive site inspection documentation must include the following:

3a. Date of inspection.

3b. Name and title of personnel making the inspection.

3c. Findings from inspection of areas identified in Part 4.3.1 of the Permit.

3d. Observations related to implementation of control measures including:


- previously unidentified discharges
- previously unidentified pollutants in discharges
- evidence of pollutants discharging from facility outfalls and condition of
outfall, including energy dissipation to prevent scouring.
- additional control measures needed

3e. If SWPPP revisions were needed during the previous year, were they
documented during the annual inspection?

3f. Any incidents of noncompliance or certification that the facility is in


compliance.

3g. Certification statement from Appendix B of General Permit.

4. Did the Facility review the DHEC approved TMDLs?

Section L: Field Observation Details


When a deficiency is identified, as needed, describe the problem that
causes the deficiency in the comments section of the question.

2/26/2024 6:37 AM 14
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section L: Field Observation Details
1. Did the Field Observation show the site in compliance?

There was a illicit discharge from a treatment unit (oil/water separator) to a "stormwater" pond to
the southwest of the unit. The small oil water treatment system is located behind the garage. Oily
water from the garage floor drains is discharged to the treatment system. Treated water from the
unit pumped to small stormwater pond which does not discharge. The Department has determined
that the treatment unit and the discharge to the stormwater pond are not permitted. The facility
has been notified that the system is not properly permitted. The facility representative indicated
that the system can be eliminated. The oily water can be collected in totes and picked up with
other oily water generated on the site.
1a. Were the receiving areas maintained?

1b. Were the shipping areas maintained?

1c. Were the process areas maintained?

Violation Determined: 11/15/2023


2.1.2.3
2.1.2.1.h: A small oil water treatment system is located behind the garage. Oily water from the
garage floor drains is discharged to the treatment system. Treated water from the unit pumped to
small stormwater pond which does not discharge. The Department has determined that the
treatment unit and the discharge to the stormwater pond are not permitted. The facility has been
notified that the system is not properly permitted. The facility representative indicated that the
system can be eliminated. The oily water can be collected in totes and picked up with other oily
water generated on the site.
1d. Were the storage areas maintained?

Violation Determined: 11/15/2023


2.1.2.3
2.1.2.1.f: Fluids are not drained from vehicles prior to onsite storage.
1e. Were the fueling areas maintained?

There are no fueling areas present.


1f. Were the maintenance areas maintained?

1g. Were the drainage structures maintained?

1h. Was erosion controlled?

Violation Determined: 11/15/2023


2.1.2.3
Erosion was noted on the roads on the lower part of the site. This erosion has resulted in sediment
filling the stormwater ponds. There was no evidence of sediment leaving site.
2. Were all pollutants controlled from leaving the site?

2/26/2024 6:37 AM 15
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
Industrial Stormwater Inspection - SCR000000
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Section L: Field Observation Details
2a. Were pollutants kept off public streets and highways?

2b. Were pollutants kept off adjacent property?

2c. Were pollutants kept out of stream(s), lake(s), or river(s)?

Closing Conference
1. Has a closing conference with the Responsible Party been performed?

1a. If no closing conference was performed with the Responsible Party


during the inspection, was contact made with the Responsible Party
afterwards to perform the closing conference? Only if a closing conference
with the RP was performed onsite, enter NA.

1b. If no closing conference was able to be performed, explain why and


what efforts were made to perform one. Only if a closing conference was
performed, enter NA.
NA

Findings
Inspection Result: Unsatisfactory

2/26/2024 6:37 AM 16
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
SW Sector N - Scrap Recycling and Waste Recycling
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Instructions
Use the comments section of each question to provide additional feedback.
This should include explanation of any violations.

The requirements in Subpart N apply to storm water discharges associated


with industrial activity from Scrap Recycling and Waste Recycling facilities
as identified by the SIC Code specified under Sector N in Table D-1 of
Appendix D of the permit.

Separate permit requirements have been established for recycling facilities


that only receive source-separated recyclable materials primarily from non-
industrial and residential sources (i.e., common consumer products
including paper, newspaper, glass, cardboard, plastic containers, and
aluminum and tin cans). This includes recycling facilities commonly
referred to as material recovery facilities (MRF).

Subpart N - Sector N - Scrap Recycling and Waste


Recycling Facilities
1. Are inbound recyclable and waste materials control concerns addressed?

2. Are material stockpiles and storage concerns addressed?

3. Are the exposed to cutting fluids item concerns addressed?

4. Are the Potential Pollutant Sources concerns addressed?

5. Are the waste processing area concerns addressed?

6. Are the battery program concerns addressed?

7. The Spill Prevention and Response concerns are addressed?

8. Waste Material Storage (Indoor): are the waste material storage


concerns being addressed?

9. Waste Material Storage (Outdoor): are the waste material storage


concerns being addressed?

10. Are the trucks and rail car waste transfer area concerns addressed?

11. Are the inbound recyclable material control concerns addressed (Source
Separated Materials)?

12. Are the outdoor storage concerns addressed? (Source Separated


Materials)

13. Are the indoor storage and material processing concerns addressed?
(Source Separated Materials)

2/26/2024 6:37 AM 17
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
SW Sector N - Scrap Recycling and Waste Recycling
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Subpart N - Sector N - Scrap Recycling and Waste
Recycling Facilities
14. Are the vehicle and equipment maintenance concerns addressed?
(Source Separated Materials)

15. Are the drainage area site map concerns addressed?

Not reviewed at this time. The SWPPP was not current.


16. Maintenance Schedules / Procedures concerns are addressed?

17. Are the inspections for waste recycling facilities concerns addressed?

Violation Determined: 2/1/2024


8.N.5.1

Benchmarks (for subsector N1 only)


1. Has the facility conducted quarterly benchmark monitoring for the four
constituents listed in Table 8.N-1?

Violation Determined: 11/15/2023


6.2.1.1
2. Was the average of the 4 samples below the benchmark concentration?

3. If needed, was follow-up monitoring conducted and control measures


modified to meet the benchmarks?

2/26/2024 6:37 AM 18
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
SW Sector M - Automobile Salvage Yards
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Instructions
Use the comments section of each question to provide additional feedback.
This should include explanation of any violations.

The requirements in Subpart M apply to storm water discharges associated


with industrial activity from Automobile Salvage Yards as identified by the
SIC Code specified under Sector M in Table D-1 of Appendix D of the
permit.

Subpart M - Sector M - Automobile Salvage Yards


1. Are Spill and Leak Prevention concerns addressed?

Violation Determined: 11/15/2023


8.M.2.1: Drain vehicles intended to be
dismantled of all fluids upon arrival at the
site (or as soon thereafter as feasible), or
employ some other equivalent means to
prevent spills and leaks. An example of
other equivalent means would be placing
vehicles not drained upon arrival on an
impermeable area that is bermed and/or
drains to a sump to capture any potential
fluid leaks. Potential stormwater pollution
is precluded until the fluids can be
removed.
Fluids have not been removed from vehicles as required above.
2. Are Employee Training concerns addressed?

Violation Determined: 2/1/2024


8.M.2.2 : If applicable to your facility,
address the following areas (at a
minimum) in your employee training
program: proper handling (collection,
storage, and disposal) of oil, used mineral
spirits, anti-freeze, mercury switches, and
solvents.
3. Are Management of Runoff concerns addressed?

4. Are the Drainage Area Site Map concerns addressed?

Not evaluated. The SWPPP provided was not up to date.

2/26/2024 6:37 AM 19
COLUMBIA AUTO PARTS, INC, : VJ17-KQQG-0RQ
SW Sector M - Automobile Salvage Yards
Inspector: Paul Wise
Start Date: 11/09/2023 Completed Date: 02/26/2024
Subpart M - Sector M - Automobile Salvage Yards
5. Are the Additional Inspection Requirements concerns addressed?

Violation Determined: 2/1/2024


8.M.4 : Immediately (or as soon thereafter
as feasible) inspect vehicles arriving at the
site for leaks. Inspect quarterly for signs of
leakage all equipment containing oily
parts, hydraulic fluids, any other types of
fluids, or mercury switches. Also, inspect
quarterly for signs of leakage all vessels
and areas where hazardous materials and
general automotive fluids are stored,
including, but not limited to, mercury
switches, brake fluid, transmission fluid,
radiator water, and antifreeze.

Benchmarks
The benchmark values of some metals are dependent on water hardness.
For these parameters, permittees must determine the hardness of the
receiving water (see Appendix J, “Calculating Hardness in Receiving Waters
for Hardness Dependent Metals,” for methodology), in accordance with Part
6.2.1.1, to identify the applicable ‘hardness range’ for determining their
benchmark value applicable to their facility.

1. Has the facility conducted quarterly benchmark monitoring constituents


listed in Table 8.M-1?

Violation Determined: 11/15/2023


6.2.1.1
2. Was the average of the 4 samples below the benchmark concentration?

3. If needed, was follow-up monitoring conducted and control measures


modified to meet the benchmarks?

2/26/2024 6:37 AM 20
COLUMBIA AUTO PARTS, INC, (VJ17-KQQG-0RQ)
Violation List

Form Determined Description Sec. #

Industrial 11/15/2023 Reference: 1.3.1.a.iv


Stormwater
Inspection -
SCR000000
Permit SCR002101 is expired. Mr. Cohen has been invited to
his Site in ePermitting to address his expired coverage,
11/17/23. To date he has not accepted the invite.
Industrial 11/15/2023 Reference: 5.3.a
Stormwater SWPPP not maintained onsite.
Inspection -
SCR000000
The SWPPP was not available for review at the time of the
inspection. Mr. Cohen did bring what appeared to be a partial
document to DHEC offices on Thursday, November 16, 2023.
A cursory review revealed that the document was last updated
under the previous owner's name. Therefore it was not
reviewed further.
Industrial 11/15/2023 Reference: 5.1.8 and Section 3
Stormwater
Inspection -
SCR000000
The SWPPP was not available for review at the time of the
inspection. Mr. Cohen did bring what appeared to be a partial
document to DHEC offices on Thursday, November 16, 2023.
A cursory review revealed that the document was last updated
under the previous owner's name. Therefore it was not
reviewed further.
Industrial 11/15/2023 Reference: 6.2.4.2.a
Stormwater
Inspection -
SCR000000
An evaluation has not been completed under the current
permit.
Industrial 11/15/2023 Reference: 6.2.4.2.a
Stormwater
Inspection -
SCR000000
An evaluation has not been completed under the current
Permit.
Industrial 11/15/2023 Reference: 6.2.4.2.b
Stormwater
Inspection -
SCR000000
An evaluation has not been completed under the current
Permit.

2/26/2024 6:37 AM 21
Industrial 11/15/2023 Reference: 6.2.4.2.b
Stormwater
Inspection -
SCR000000
An evaluation has not been completed under the current
Permit.
Industrial 11/15/2023 Reference: 5.1.5.1.a.iv.
Stormwater
Inspection -
SCR000000
Training records were not provided for current employees.
Industrial 11/15/2023 Reference: 5.1.2
Stormwater
Inspection -
SCR000000
A small oil water treatment system is located behind the
garage. Oily water from the garage floor drains is discharged to
the treatment system. Treated water from the unit pumped to
small stormwater pond which does not discharge. The
Department has determined that the treatment unit and the
discharge to the stormwater pond are not permitted. The
facility has been notified that the system is not properly
permitted. The facility representative indicated that the system
can be eliminated. The oily water can be collected in totes and
picked up with other oily water generated on the site.
Industrial 11/15/2023 Reference: 4.1.1
Stormwater
Inspection -
SCR000000
Inspections were not being conducted by the current owner.
Industrial 11/15/2023 Reference: 4.1.1
Stormwater
Inspection -
SCR000000
Industrial 2/1/2024 Reference: 4.2.1
Stormwater
Inspection -
SCR000000
Industrial 11/15/2023 Reference: 4.3.1
Stormwater
Inspection -
SCR000000

2/26/2024 6:37 AM 22
Industrial 11/15/2023 Reference: 2.1.2.1.h
Stormwater
Inspection -
SCR000000
2.1.2.1.h: A small oil water treatment system is located behind
the garage. Oily water from the garage floor drains is
discharged to the treatment system. Treated water from the
unit pumped to small stormwater pond which does not
discharge. The Department has determined that the treatment
unit and the discharge to the stormwater pond are not
permitted. The facility has been notified that the system is not
properly permitted. The facility representative indicated that the
system can be eliminated. The oily water can be collected in
totes and picked up with other oily water generated on the site.
Industrial 11/15/2023 Reference: 2.1.2.1.f
Stormwater
Inspection -
SCR000000
2.1.2.1.f: Fluids are not drained from vehicles prior to onsite
storage.
Industrial 11/15/2023 Reference: 2.1.2.3
Stormwater
Inspection -
SCR000000
Erosion was noted on the roads on the lower part of the site.
This erosion has resulted in sediment filling the stormwater
ponds. There was no evidence of sediment leaving site.
SW Sector M - 11/15/2023 Reference: 8.M.2.1
Automobile Salvage Drain vehicles intended to be dismantled of all fluids upon
Yards arrival at the site (or as soon thereafter as feasible), or employ
some other equivalent means to prevent spills and leaks. An
example of other equivalent means would be placing vehicles
not drained upon arrival on an impermeable area that is
bermed and/or drains to a sump to capture any potential fluid
leaks. Potential stormwater pollution is precluded until the
fluids can be removed.
Fluids have not been removed from vehicles as required
above.
SW Sector M - 2/1/2024 Reference: 8.M.2.2
Automobile Salvage If applicable to your facility, address the following areas (at a
Yards minimum) in your employee training program: proper handling
(collection, storage, and disposal) of oil, used mineral spirits,
anti-freeze, mercury switches, and solvents.

SW Sector M - 2/1/2024 Reference: 8.M.4


Automobile Salvage Immediately (or as soon thereafter as feasible) inspect vehicles
Yards arriving at the site for leaks. Inspect quarterly for signs of
leakage all equipment containing oily parts, hydraulic fluids,
any other types of fluids, or mercury switches. Also, inspect
quarterly for signs of leakage all vessels and areas where
hazardous materials and general automotive fluids are stored,
including, but not limited to, mercury switches, brake fluid,
transmission fluid, radiator water, and antifreeze.

SW Sector M - 11/15/2023 Reference: 6.2.1.1


Automobile Salvage
Yards

2/26/2024 6:37 AM 23
SW Sector N - Scrap 2/1/2024 Reference: 8.N.5.1
Recycling and Waste The inspections must be performed quarterly, pursuant to Part
Recycling 4.1, and include, at a minimum, all areas where waste is
generated, received, stored, treated, or disposed of and that
are exposed to either precipitation or storm water runoff.

SW Sector N - Scrap 11/15/2023 Reference: 6.2.1.1


Recycling and Waste
Recycling

2/26/2024 6:37 AM 24

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