ECAR Fact Sheet for Pennsylvania
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. 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:

• Over 250 auto/truck bodies with drive lines (engine, transmission, axels, and wheels), 250 drivelines or any combination thereof (in whole or in parts), which are exposed, to stormwater;
• Over 500 auto/truck units (bodies with or without drivelines in whole or in parts), which are stored exposed to stormwater; or
• Over 100 units per year are dismantled and drainage or stormwater or automotive fluids occurs in areas exposed to stormwater.

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
(PA'S SITE REQUIRES YOU TO LOG IN AS A GUEST)

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 (PAG-3) or has an individual stormwater permit issued by PDEP.
2. Has your facility developed and implemented a Preparedness, Prevention, and Contingency (PPC) plan? Verify that a PPC plan has been prepared and implemented and is available onsite for inspection. Review the plan and verify that BMPs have been implemented. Update the plan when operational changes occur that impact stormwater.
3. Has your facility conducted visual inspections? Review your records to verify that annual inspections have been performed. Proof of these activities must be incorporated into your PPC plan.
4. Has your facility maintained monitoring results and records? Verify that all inspection records are maintained for at least one year after termination of the 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:

• 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

Contacts

1. For general permit questions, contact 717-787-8184.
2. In the event of a pollution emergency, contact 717-787-4343.

Related ECAR Fact Sheets

1. SWPPP

Other Relevant Resources

1. NPDES MS4 Permit Application and Annual Report Forms
   (PA'S SITE REQUIRES YOU TO LOG IN AS A GUEST)
2. EnvCAP's Industrial Stormwater Resource Locator
3. PNEAC Offers Industrial Stormwater Permit Guide

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