OCTOBER 6, 2025 - ADMINISTRATIVE ORDER ON CONSENT
On August 08, 2023, representatives of the EPA and SCDES performed a Stormwater Compliance Evaluation Inspection (CEI) at Respondent?s Site No. 211, the Walterboro, SC plant, to evaluate the Respondent?s compliance with the requirements of Sections 301
and 402(p) of the CWA, 33 U.S.C. ?? 1311 and 1342(p); the regulations promulgated thereunder at 40 C.F.R. ? 122.26, and the Permit.
On October 16, 2023, the EPA issued an Inspection Report to the Respondent by email.
The Inspection Report indicated that during the CEI, the EPA inspectors observed the following:
A. The Walterboro, South Carolina Site No 211 is a pallet manufacturing
facility (SIC Code 2448), but has not submitted an NOI for coverage under
the existing Permit or obtained a No Exposure Certification.
On August 29, 2024, the EPA issued a Notice of Violation and 308 Information Request to the Respondent with regards to the Walterboro, SC, plant No. 211.
EPA then identified the Facility as one of eight (8) sites, including Walterboro, South Carolina Site No 211, located in the Southeast Region owned and operated by 48 Forty Solutions that did not have existing coverage under a NPDES Permit to discharge
stormwater associated with industrial activity from the Facility.
Based on the hydrology of the Facility and historic rainfall data, the EPA has determined that from the time industrial activities and operations at the Facility began to present, s