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ECAR
Fact Sheet for
Pennsylvania Regulations BACK to VIRTUAL TOUR 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.
How to Get Permit Coverage. Start by downloading and carefully reading the Notice of Intent (NOI) form and General Permit (PAG-3) found below under "Links to the Regulations and Forms". To apply for coverage under the general permit, you must: 1. Prepare and implement a Preparedness, Prevention, and Contingency (PPC) plan in accordance with the PDEP’s guidelines in 25 Pa. Code 101.3. 2. Complete and submit a notice of intent (NOI) form to the appropriate regional office of the Pennsylvania Department of Environmental Protection (PDEP). Your NOI must be submitted 30 prior to commencing any industrial discharge. If your facility is already authorized to discharge under the previous general permit, and you wish to renew your coverage, you must complete and submit an NOI at least 180 days prior to the expiration date of the old permit. If the PDEP has not notified your facility of its authorization to discharge within 30 days of the submittal of your NOI, you may assume that coverage is granted and may commence industrial activity. 2. The general permit (PAG-3) was issued March 5, 2003 and expires at midnight on October 4, 2003, unless reissued on or before this date by the PDEP. 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. 1. A Preparedness, Prevention, and Contingency (PPC) plan, in accordance with the PDEP’s guidelines in 25 Pa. Code 101.3, must be developed for each facility covered under the general permit. This plan must provide compliance with the terms of the PPC plan prior to submitting your NOI. The requirements of the plan are described in Part B.3 of the general permit. The PPC plan must be signed in accordance with Part B.1.c the general permit and must be retained on-site and made available to the authorities upon request. 2. Your facility must conduct Comprehensive Site Compliance Evaluations at least once a year in order to determine the level of effectiveness that the PPC plan is providing. Based on the results of the inspection, the pollution measures and controls identified in the PPC plan must be revised as appropriately within 15 days of the inspection. Implementation of those revisions must be in place no later than 90 days after the inspection. A report summarizing the scope of the Comprehensive Site Compliance Inspection must be written and kept onsite as part of the PPC Plan for at least one year after the coverage of the permit terminates. 3. Automotive recycling operations above certain size criteria must conduct annual facility inspections in addition to the Comprehensive Site Compliance Evaluation. The instructions for monitoring are contained in Part A.2.d of the general permit. These monitoring requirements apply to automotive recycling operations with:
Your facility is required to retain the PPC plan, data used to complete the NOI, and all records of your Compliance Evaluations and annual inspections for at least one year after coverage under the general permit expires or terminates. Your PPC plan 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 PPC plan you must consider the use of certain BMPs that EPA and PDEP consider applicable to specific areas such as vehicle dismantling/storage areas and fluids storage areas. For more specific information on developing a Pollution Prevention Plan, visit the ECAR SWPPP fact sheet. Links to the Regulations and Forms. Use the following links to view the regulations pertaining to stormwater management. NPDES MS4 Permit Application and Annual Report Forms Federal EPA National Pollutant Elimination Discharge System (NPDES) Stormwater Regulations 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.
Best Management Practices (BMPs) The following is a list of BMPs for auto salvage facilities identified by EPA when the stormwater regulations were published: Dismantling and vehicle maintenance:
Outdoor vehicle, equipment and parts storage:
Vehicle, equipment and parts washing areas:
Liquid storage in above ground containers:
Improper connection with storm sewers:
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