ECAR Fact Sheet for Colorado
Stormwater

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

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The following fact sheet was prepared by the ECAR Center staff. Once prepared, each ECAR Center fact sheet undergoes a review process with the applicable state environmental agency(ies). You can check on the status of the review process here. Please read the disclaimer on the status page. 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.

What You Need to Know

The Clean Water Act requires virtually every automotive salvage or recycling operator to obtain a stormwater permit. The exceptions to this rule are few, and they are explained further in the detailed information provided below. Therefore, if you own or operate a salvage or recycling operation and you do not currently have a stormwater permit, you most likely are out of compliance. The purpose of this fact sheet is to help you either to get into compliance or to assist you to develop a more efficient and effective compliance strategy.

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.

In 1987, Congress mandated that "industrial" sites obtain stormwater permits. 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)]. These mandates apply across the country, regardless of your state. Congress and EPA took this action 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 localized 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 or even some new parts is toxic to humans and to the fish they may catch and eat. By obtaining a stormwater permit, and more importantly, by taking some common sense actions under the permit to prevent stormwater contamination, you can provide your community with environmental benefits to compliment the value of recycling end-of-life vehicles.

Although Congress and EPA created the national rules that provide the basic framework for stormwater regulations, the rules are implemented by the individual state environmental agencies. EPA may help certain states develop programs and it provides guidance to all states, but for the most part, you obtain a stormwater permit from your state environmental agency. Information about your state permit, compliance requirements, contact information, and other helpful hints are provided in the following pages of this site. The most important part of the compliance program is developing a stormwater pollution prevention plan, and this site will help you to develop such a plan. The key for you is to make sure that you implement the plan and adhere to your legal obligations.

Regulations

How to Get Permit Coverage.

To apply for coverage under the general permit, you must:

1. Submit both an original copy of the completed application form and a Stormwater Management Plan (SWMP) to:

The owner (or operator) of the facility must submit an application for the authority to discharge at least 30 days prior to the anticipated date of discharge. Automotive recycling facilities must include the Standard Industrial Classification (SIC) Code 5015 in the respective section of the application.

Unless you are notified by CDPS to the contrary, you are covered under the general permit 30 days after the date that the application is received. If the Division requests additional data in order for the permit to be granted, it shall have an additional 15 days to issue or deny authorization for the particular discharge.

Any permitted facility discharging to a municipal storm sewer shall provide the municipality with a copy of the permit application, Annual Reports, SWMP and/or Discharge Monitoring Reports, upon request.

How to Comply with the Permit Requirements. To maintain coverage under the general permit, you must comply with all the terms of the permit. Below is a summary of key requirements.

A stormwater management plan (SWMP) must be developed for each facility covered by this permit and submitted to the Colorado Discharge Permit System (CDPS) along with the application for discharge. This plan must

• identify potential sources of pollution which may reasonably be expected to affect the quality of stormwater discharges associated with industrial activity from the facility
• describe and ensure the implementation of specific Best Management Practices described in Part I.B.1 of the application form of permit COR-060000
• include a description of each proposed sampling point, and a summary of any existing discharge sampling data must also be included in the plan
• include a schedule for employee-training programs, and the identification of procedures for and intervals of comprehensive inspections consistent with Part I.C.5.

The SWMP shall include the following items, at a minimum:

a. Industrial Activity Description. The plan shall provide a narrative description of the industrial activity taking place at the site. This description shall identify the presence of activities such as vehicle dismantling, vehicle crushing, material shredding, material baling, battery reclaiming, outdoor vehicle and equipment storage.

b. Site Map. The plan shall include a site map indicating items such as an outline of the drainage area of each stormwater outfall (to the extent possible), each existing structural control measure to reduce pollutants in stormwater runoff, surface water bodies nearby, and the location of outdoor processing activities (vehicle dismantling, crushing, etc.), storage areas and monitoring points.

c. Stormwater Management Controls. Each recycling facility covered by this permit shall develop a description of stormwater management controls appropriate for the site, and implement such controls. The appropriateness and priorities of controls in a plan shall reflect identified potential sources of pollutants at the facility. The description of stormwater management controls shall address the following minimum components, including a schedule for implementing such controls:

1) SWMP Administrator - The SWMP shall identify a specific individual within the organization who is responsible for developing the SWMP and overseeing its implementation, maintenance, and revision. The activities and responsibilities of the administrator shall address all aspects of the facility's SWMP.

2) Identification of Potential Pollutant Sources and Best Management Practices - The SWMP shall identify potential sources of pollutants at the site, and assess the potential of these sources to contribute pollutants to stormwater discharges associated with industrial activity. The SWMP must also describe appropriate Best Management Practices (BMPs) to reduce the potential of these sources to contribute pollutants to stormwater discharges. In each case where stormwater pollution potential exists, appropriate preventive measures must be taken and documented.

Links to the Regulations and Forms. Use the following links to view the regulations pertaining to stormwater management.

Stormwater Permits

Federal EPA National Pollutant Elimination Discharge System (NPDES) Stormwater Regulations

Self-Audit Checklist

When an inspector comes to your facility, there are certain things he or she checks to see if you are in compliance with environmental regulations. It makes good sense for you to perform a "self-audit" and catch and correct problems before they result in penalties. Also, there are some compliance incentives associated with self-audits (see Audit Policy Page).

Use the following list to audit your stormwater permit.

1. Is your facility covered under a general permit or does your facility have an individual stormwater permit? Verify that your facility is either covered under the general permit (COR-060000) or has an individual stormwater permit issued by CDPS.
2. Has your facility developed and implemented a stormwater pollution prevention plan? Verify that a SWPPP has been prepared, implemented, and submitted to the CDPS along with the application for discharge. Review the plan and verify that BMPs have been implemented, and keep a copy of the plan onsite for inspection. Update the plan when operational changes occur that impact stormwater.
3. Has your facility conducted stormwater sampling and visual inspections? Review your records to verify that annual sampling and inspections have been performed. Proof of these activities must be incorporated into your SWPPP.
4. Has your facility maintained monitoring results and records? Verify that all monitoring and inspection records are maintained for at least three years from the date of sample collection or for the term of the permit, whichever is greater.

Best Management Practices (BMPs)

Following are two lists of BMPs for auto recycling facilities.  The first list is included in Colorado’s general permit application.  The second list was identified by EPA when the stormwater regulations were published.

Mandatory BMPs - All Auto Recycling facilities must include the following BMPs:

For Auto Recycling Facilities (SIC Code 5015)

a) Upon arrival at the site, or as soon as feasible thereafter, vehicles must be inspected for leaks. Prior to storage on site, measures must be taken to reduce the risk of any leaks impacting stormwater.

b) A quarterly inspection for leaks must be conducted on any equipment or parts stored or used outdoors containing oil, hydraulic fluids, brake fluid, transmission fluid, radiator fluids, etc. and all outdoor liquid storage containers (e.g., tanks, drums). When leaks are identified, measures must be taken to reduce the potential of these exposures to impact stormwater runoff. A record of these inspections and measures taken to correct problems must be kept, and a summary must be included in the Annual Report as specified at Part I.E of this permit.

c) A discussion of measures and controls to be implemented at the facility that are specific to the proper handling, storage and disposition of scrap lead-acid batteries.

d) Prior to crushing, vehicles shall be drained of all fluids, or other appropriate means for recovering liquids released due to crushing activities must be implemented. The SWMP shall include a discussion of the procedures followed to drain vehicles or recover liquids, and measures and controls specific to the proper handling, storage and disposition of these drained fluids.

e) Other BMPs appropriate for the control of identified potential pollutant sources. These may include structural BMPs such as berms to control runon, detention ponds, oil/water separators, etc.

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.
• 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.

Contacts

1. For general questions, contact Colorado’s Water Quality Control Division at 303-692-3500.

Related ECAR Fact Sheets

1. SWPPP

Other Relevant Resources

1. Colorado Stormwater Program Fact Sheet
2. Stormwater Sampling Guidance Document
3. Colorado Stormwater General Permit Application
4. EnvCAP's Industrial Stormwater Resource Locator
5. Colorado's Automotive Salvage Yard Waste Management Practices

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