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ECAR
Fact Sheet for Colorado
Wastewater
Discharges
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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
Wastewater is often generated by operations such as the rinsing of
parts, and the washing down of engines or dirty tools. If water
becomes mixed with oil, antifreeze, solvents, or other liquids,
it is important that it be properly treated and contained prior
to discharge. If your wastewater is currently just
going down an unregulated drain, you've got a problem. Even
if your activities have gone unnoticed for years, there is an increasing
chance that you will be inspected. The federal EPA and the
states are starting to look much more carefully at sources of water
pollution that have so far remained unidentified, and they have
(rightly or wrongly) decided that auto recyclers are a significant
problem area.
You
will almost certainly need separate permits both for stormwater
runoff (see the ECAR Stormwater fact sheet) and for any industrial
wastewater that you generate. This page will give you an overview
of how to handle your industrial wastewater.
Regulations
This
fact sheet addresses wastewater discharges other than stormwater,
which is covered by a different fact sheet. Wastewater from salvage
yards can be subdivided into two main types:
- "Sanitary wastewater" includes the water coming
from lavatories/washrooms, showers, drinking fountains, etc.
- "Industrial wastewater" includes the water
going into floor drains in areas such as dismantling, discharges
from aqueous cleaning, water from steam cleaning or equipment
wash down, water used for floor cleanup in dismantling areas
(e.g., mop water), or water from any other sources where it
comes into contact with dismantled parts or equipment.
Colorado's
regulations on wastewater generally reflect those established under
federal law. Sanitary wastewater can be discharged to a city sewer
system, however, most local governments require businesses to obtain
a discharge permit. Sanitary wastewater cannot be discharged to
a stream, pond, or wetland without having a special permit. If you
have questions regarding sanitary wastewater, contact your local
sewer authority or the Colorado Department of Public Health
and Environment (CDPHE).
Industrial
wastewater is regulated differently than sanitary wastewater. If
you combine sanitary and industrial wastewater, then the mixed wastewater
is regulated like industrial wastewater. All industrial wastewater
discharges are regulated by federal and state regulations and in
most cases, also by local regulations.
Permits. A National Discharge Elimination
System (NPDES) permit from the CDPHE is required to discharge industrial
wastewater directly into surface water (like a stream or river)
or groundwater. Most auto recyclers qualify for coverage under
the general permit.
Some
facilities do not discharge their wastewater directly into a surface
water body, but discharge into a sanitary sewer system/sewage treatment
plant. If your wastewater is not discharged into a surface water body like
a stream or river, but rather to a sanitary sewer system/sewer treatment
plant, you will likely need a permit. See the Department's Wastewater
Discharge Permit Application for more information. As an automotive
recycler, you may qualify to obtain coverage under the state's Minimal
Discharge Industrial Wastewater Application.
Pretreatment. To
meet the standards of your local sewer authority, you may need to
install treatment equipment such as an oil/water separator to prevent
oil and sludge from being discharged to the sewer. This is referred
to as "pretreatment." In some cases, the skimmed oil can be
managed with your used oil. See the ECAR Used Oil Fact Sheet. However, sludge collected
by pretreatment equipment will have to be periodically removed and
disposed of, possibly as a hazardous waste (you must make a hazardous waste
determination). In most instances, wastewater will require some form of pretreatment
prior to discharge into the sewer system.
Spills. When a chemical spill or release
occurs in Colorado, there are a number of reporting and notification
requirements that must be followed by the agency or individual responsible
for the spill. These requirements tend to be confusing, and regulations
often overlap.
At minimum, notify the Colorado 24-hour Emergency Spill/Release Reporting
Line at 877-518-5608 and the Local Emergency Planning Committee
at 303-273-1622, immediately or within 24-hours. Refer to the Spill Response Fact Sheet to determine your reporting requirements.
Links
to the Regulations and Forms. Use the following links to view the regulations and permit forms pertaining
to wastewater.
CDPHE Discharge
Requirements
Wastewater
Discharge Permit Application
Minimal
Discharge Industrial Wastewater Application
Federal Safe Drinking Water
Act Requirements
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 wastewater management activities.
- Does your facility discharge process wastewater?
Are the discharges authorized by a permit? Check all uses of water and
steam within the industrial areas of your facility. Determine
where wastewater is generated and discharged. You must have a
permit or written authorization for all industrial water discharges.
- Has the water been pretreated? Depending on which POTW you discharge to, you may be required
to obtain a pretreatment permit from the POTW. Check to make sure
you have the appropriate permits.
- Is oil or solvent discharged to the sewer? Federal and state laws prohibit
the discharge of oil or flammable solvents to the sewer system.
These are regulated wastes that must be properly disposed of.
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 wastewater management.
- Limit water use and the volume of water discharged
through conservation methods and by reusing water whenever possible.
- Train employees to use water efficiently.
- Don't use water for cleaning floors and equipment
unless absolutely necessary. Use dry cleanup methods for spills.
- Post signs at all floor drains and sinks in industrial
areas of your facility to discourage employees from using the
drains to dispose of oil, other vehicle fluids, solvent, paint
or similar liquids. Review these rules with your employees.
- Use only non-toxic soaps to clean floors and
vehicles instead of hazardous materials.
- If you have floor drains at your facility that
are not in use, consider having them capped or plugged to prevent
misuse or accidental discharges.
- Prevent drips and spills from reaching the floor.
- Check your floor drains and make certain you
know where they discharge.
- Setup and use a maintenance schedule for inspection
and cleaning of floor drains, oil/water separators, traps, etc.
- Never have floor drains where hazardous materials
are stored.
- If your wastewater is nonhazardous, you may want
to purchase evaporating equipment to evaporate your wastewater.
It should be noted that evaporators may require an air permit
or registration, and evaporator bottoms may be considered a hazardous
waste.
- Don't use degreaser solvents to clean engines.
Most engine degreasers are hazardous and should not be discharged
to a POTW. Even if you use nonhazardous degreasers, the oil and
grease concentration in the spent degreaser may exceed the limit
allowed by your sewer authority.
Contacts
- For more information, contact the
Colorado Department of Health and Environment's Pretreatment
Program at 303-692-3618 or the Permits Unit at 303-692-3500.
- To
report a spill or leak, at minimum, call the Colorado 24-hour
Emergency Spill/Release Reporting Line at 877-518-5608 and the
Local Emergency Planning Committee at 303-273-1622, immediately
or within 24-hours. Refer to the Spill Response Fact Sheet to determine your reporting requirements.
- To
report an environmental incident or complaint, contact the nearest
regional
office.
Related
ECAR Fact Sheets
- Stormwater
Other
Relevant Resources
- Colorado
- List of Pretreatment Coordinators by POTW
- Colorado's Automotive Salvage Yard Waste Management Practices
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