While we have tried to present a summary of the essential information on this topic, you should be aware that other items, such as local regulations, may apply to you. Please read the disclaimer.
What You Need to Know
The Clean Water Act requires virtually every automotive salvage or recycling operator to obtain a stormwater permit (with very few exceptions to this rule). Therefore, if you own or operate an automotive salvage facility you are required to maintain a stormwater permit. Rain or snow falling on your property can pick up contaminants as it runs off, and can carry the contaminants through drainage systems directly into streams, rivers, and lakes. The term "stormwater" refers to this type of runoff.
Stormwater permits are required because stormwater that comes in contact with metals, oil and grease, used batteries and tires, and other materials common at automotive recycling facilities may cause pollution that can affect the local community's ability to swim and fish in lakes, rivers, and streams. For example, the mercury that still may be found in old automotive switches is toxic to humans and to the fish they may catch and eat. By taking some common sense actions under the stormwater permit to prevent stormwater contamination, you can provide your community with environmental benefits to compliment the value of recycling end-of-life vehicles.
In 1987, Congress mandated that "industrial" sites obtain stormwater permits through the National Pollutant Discharge Elimination System or NPDES program. In 1990, EPA defined "industrial" to include, among many other types of sites, "salvage yards and automotive recyclers." [Title 40 CFR 122.26(b)(14)(vi)] as Standard Industrial Classification or SIC code 5015. Usually grouped with metal salvage yards that are classified as SIC code 5093.
What is NPDES?
The NPDES permit program addresses water pollution by regulating point sources that discharge pollutants to waters of the United States. EPA authorized state agencies to perform NPDES or stormwater permitting, administrative, and enforcement aspects of the program.
In Missouri, the Department of Natural Resources (MO-DNR) issues Missouri State Operating Permits for storm water discharges under the industrial general permit MOR. General permits reduce the amount of time and paperwork involved in obtaining a stormwater permit. You must apply for and obtain a Missouri State Operating Permit for storm water discharge if you own or operate vehicle salvage or recycling operations unless:
• You store 50 or fewer vehicles at any time and you do not process more than 50 vehicles per year.
• The storm water from your site discharges to a combined sewer system (storm sewers and sanitary sewers drain in a common pipe to a wastewater treatment plant). Your local public works office can tell if your area has combined sewers.
• Your facility meets “no-exposure” criteria and you have filed a no-exposure certification with the department.
General permits cover an entire industry and are issued statewide for a period of five years. It is up to the individual facility operator to apply for the permit and pay the annual permit fee.
If Construction Projects will include the removal of vegetation, grading or excavating in an area one acre or larger, you will need a Land Disturbance Permit. Land Disturbance Permits require the use of “best management practices” (BMPs) to minimize soil erosion from the site. BMPs include maintaining vegetation, temporary re-vegetation, silt fences, straw bales and sediment basins.
A storm water pollution prevention plan (SWPPP) is required for all storm water permits. The plan must be completed prior to submitting the stormwater permit application known as the "Notice of Intent." The plan should be kept on-site at the facility or construction site that generates the storm water discharge.
Your SWPPP must include a description of potential sources of stormwater pollution and measures and controls, including best management practices (BMPs) that will be implemented at your facility to prevent or minimize stormwater contamination. When developing the SWPPP, you must consider the use of certain BMPs that EPA and DNR consider applicable to specific areas such as vehicle dismantling/storage areas and fluids storage areas. However, you do not need to limit yourself to just these BMPs.
Exceptions. Under the conditional no exposure exclusion, operators of industrial facilities in any of the 11 categories of "storm water discharges associated with industrial activity," (except construction activities, which are addressed under the construction component of the NPDES Storm Water Program) have the opportunity to certify to a condition of "no exposure" if their industrial materials and operations are not exposed to storm water. As long as the condition of "no exposure" exists at a certified facility, the operator is excluded from NPDES industrial storm water permit requirements. This is uncommon in automotive recycling.
In April 2017, the MO-DNR issued a letter to general industrial permittees DISCONTINUING the quarterly stormwater sampling and reporting requirement in the state of Missouri.
The letter states that the Best Management Practices or BMPs spelled out in the Storm water Pollution Prevention Plan or SWPPP adequately control the contaminants to stormwater associated with industrial activity. The permit still requires the maintenance and implementation of the SWPPP. Those requirements include conducting and logging periodic inspections within the SWPPP.
The letter states that the permit will be updated in the coming months. It also states that sampling may be requested by individual facilities that have conducted illegal discharges, had compliance issues, complaint investigations, or evidence of off-site impact from their industrial activity.
An inspector may check the facility for compliance with environmental regulations. Conducting a "self-audit" will identify and correct problems before they result in penalties.
Use the following list to audit your stormwater permit:
- Does your facility have a stormwater permit? Verify that your facility has a current stormwater permit issued by the Missouri DNR if your facility falls under the requirement.
- Has your facility developed and implemented a stormwater pollution prevention plan or SWPPP? Verify that a SWPPP has been prepared and is available on-site for inspection. Review the plan and verify that BMPs have been implemented. Note: If the facility is inspected, the SWPPP will be checked against all requirements in the permit. It is required that all SWPPPs be fully compliant with the permit.
- Does your facility have a stormwater monitoring program? Review your records to verify that visual observations and sampling have been performed.
Best Management Practices (BMPs)
Most regulations tell you what you have to do to be in compliance, but they don't explain how to do it. That's where "best management practices" come into play. BMPs are proven methods that help you to get into compliance and stay there. The following BMPs are recommended for stormwater pollution prevention.
The following is a list of BMPs for auto salvage facilities identified by EPA when the stormwater regulations were published:
Dismantling and vehicle maintenance:
- Drain all fluids from vehicles upon arrival at the site. Segregate the fluids and properly store or dispose of them.
- Maintain an organized inventory of materials used in the maintenance shop.
- Keep waste streams separate (i.e. waste oil and solvents). Non-hazardous substances that are contaminated with hazardous substances are considered a hazardous waste.
- Recycle antifreeze, gasoline, used oil, mineral spirits and solvents.
- Dispose of greasy rags, oil filters, air filters, batteries, spent coolants and degreasers properly.
- Label and track the recycling of waste material.
- Drain oil filters before disposal or recycling.
- Store cracked batteries in a nonleaking secondary container.
- Promptly transfer used fluids to the proper container.
- Do not pour liquid waste down floor drains, sinks or outdoor storm drains.
- Plug floor drains that are connected to the storm or sanitary sewer. If necessary, install a sump that is pumped regularly.
- Inspect the maintenance area regularly for proper implementation of control measures.
- Filter stormwater discharges with devices such as oil-water separators.
- Train employees on proper waste control and disposal procedures.
Outdoor vehicle, equipment and parts storage:
- Use drip pans under all vehicles and equipment waiting for maintenance and during maintenance.
- Store batteries on impervious surfaces. Curb, dike or berm this area.
- Confine storage of parts, equipment and vehicles to designated areas.
- Cover all storage areas with permanent cover (roof) or temporary cover (canvas tarps).
- Inspect the storage yard for drip pans and other problems regularly.
Vehicle, equipment and parts washing areas:
- Avoid washing parts or equipment outside.
- Use phosphate-free biodegradable detergents.
- Consider using detergent-based or water-based cleaning systems in place of organic solvent degreasers.
- Designate an area for cleaning activities.
- Contain steam cleaning washwaters or discharge under an applicable NPDES permit.
- Ensure that washwaters drain well, and are not draining into a MS4 or surface water body.
- Do not discharge wastewater into a dry well.
- All discharges authorized by the general stormwater permit must fully meet all applicable water quality standards.
- Inspect cleaning area regularly.
- Install curbing, berms or dikes around cleaning areas.
- Liquid storage in above ground containers:
- Maintain good integrity of all storage containers.
- Install safeguards (such as berms) against accidental releases in the storage area.
- Inspect storage tanks to detect potential leaks. Perform preventative maintenance.
- Inspect piping systems for failures or leaks.
- Train employees on proper filling and transfer procedures.
Improper connection with storm sewers:
- Plug all floor drains if it is unknown whether the connection is to storm sewer or sanitary sewer. Alternatively, install a sump that is pumped regularly.
- Update facility schematics to accurately reflect all plumbing connections.
- Install a safeguard against vehicle washwaters and parts cleaning water entering the storm sewer unless permitted.
- Maintain and inspect the integrity of all underground storage tanks; replace when necessary.