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. Material handling and storage, equipment maintenance and cleaning, and other activities at industrial facilities are often exposed to the weather. Runoff from rainfall or snowmelt that comes in contact with these activities can pick up pollutants, and transport them directly to a nearby river, lake, or coastal water or indirectly via a storm sewer and degrade water quality. 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." Federal regulations at 40 CFR 122.26(b)(14)(i)-(xi) require stormwater discharges associated with specific categories of industrial activity to be covered under NPDES permits.
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. Stormwater discharges associated with specific categories of industrial activity to be covered under NPDES permits (unless otherwise excluded). One of the categories—construction sites that disturb five acres or more—is generally permitted separately because of the significant differences between those activities and the others. The other 11 categories of regulated industrial activities include:
Category Six (vi): Metal scrapyards, salvage yards, automobile junkyards, and battery reclaimers
EPA has developed a fact sheet for each of the 29 industrial sectors regulated by the MSGP. Each fact sheet describes the types of facilities included in the sector, typical pollutants associated with the sector, and types of stormwater control measures used to minimize the discharge of the pollutants. Sector M: Automobile Salvage Yards (PDF)
Storm Water Pollution Prevention Plan (SWPPP)
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. EPA has provided guidace on developing an SWPPP:
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 considers 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.
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.
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 state 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.
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