ECAR
Fact Sheet for Tennessee
Wastewater
Discharges
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
As
an auto recycler, you almost certainly generate wastewater through
operations such as the rinsing of parts and the washing down of
engines and 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.
There
are a few basic rules to keep in mind. The first is that wastewater
from ordinary lavatory use and hand washing ("sanitary wastewater")
can generally be discharged to a city sewer or a septic field
only if it does not contain any waste from industrial
sources. Wastewater from industrial discharges is usually handled
by wastewater treatment plants, but you will probably be required
to conduct “pretreatment” of the discharge. Most importantly, you
should remember that the storm drains that carry rain and snow runoff
from dismantling yards, roof downspouts, parking lots, and other
surfaces typically go directly to open waterways, and must never
be used for disposal. It is important that all the employees
at your yard are aware of these rules, and that they respect them.
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.
Sanitary
wastewater can be discharged to a city sewer system or an approved
septic tank system. 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.
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.
Disposal
Options. There are three primary options for disposing of industrial
wastewater from auto recycling facilities:
- Discharge
it to a POTW (Publicly Owned Treatment Works) or Sanitary Sewer
System. If your facility discharges industrial wastewater
into a municipal sewer that is connected to a POTW, you must meet
the standards set by the receiving water treatment facility. Also,
you may be required to treat your wastewater prior to discharging
it to a sewer or POTW, and you will need a permit or written permission
for all discharges. Contact your municipality to obtain a discharge
permit and for applicable local requirements. You must also follow
state and federal requirements, which are outlined under the Regulations
section below.
- Haul
it to an approved treatment facility. If your area is not
served by a municipal sewer system, you may opt to transport your
wastewater to an approved treatment facility. Before you haul
wastewater you must perform a hazardous waste determination. This
may involve getting it tested by a laboratory. If the wastewater
is non-hazardous, then you should maintain test records that support
your determination.
- Haul
it to a Hazardous Waste Treatment Facility. If your industrial
wastewater is considered "hazardous," you must manage
it using special procedures. For more information, see the ECAR
Hazardous Waste Fact Sheet. You will need to ensure that the
tank storing this wastewater meets the requirements contained
in the hazardous waste rules. In addition, you must ensure that
you properly manage the wastewater upon removing it from the tank
and that it is transported by certified hazardous waste transporters.
- Discharge
it to the Surface Waters. If your facility discharges industrial
wastewater via a “point source” (such as a pipe, etc.) directly
to waters of the state, you will be required to obtain a National
Pollutant Discharge Elimination System (NPDES) permit. Waters
of the state include (but are not limited to) ground water, storm
drains, rivers, ponds, streams, lakes and ditches. NPDES permits
set limits on the quantity, discharge rate and concentrations
of pollutants in the water that are discharged from a point source
into waters of the state. If you obtain this type of permit, you
will be required to frequently collect samples of your wastewater
and have them analyzed at a laboratory. You will also have reporting
and recordkeeping responsibilities.
Most
auto recyclers use option 1 or 2. Option 1 is viable when the facility
is located in an area served by a sanitary sewer system, while Option
2 is the economical choice when the volume is small. Before you
begin to discharge industrial wastewater using option 1, you must
acquire a permit or written notification from your local sewer district
or POTW. You will also have to meet certain rules found in federal
and state regulations, including:
- You
are prohibited from discharging any pollutant, including oil,
that may upset or interfere with the sewage treatment processes
or pass through the system untreated;
- The
pH of your wastewater must not be lower than 5.0;
- You
cannot discharge pollutants (e.g., solvents) that may cause a
fire in the sewer system; and
- You
cannot discharge pollutants such as sludge (e.g., grease, dirt)
that may clog the sewer system.
Pretreatment.
To meet the rules listed above, 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.”
The oil and 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).
*It
is important to note that discharging industrial wastewater to a
septic tank is not a viable option. Septic tank systems, wells,
drain fields, cesspools and similar disposal sites are regulated
by federal and state Underground Injection Control (UIC) program
rules that are designed to prevent the contamination of underground
drinking water supplies. For more information see the Septic Tanks and Disposal Wells
Fact Sheet.
Links
to the Regulations and Forms. Use the following links to view
the regulations and permit forms pertaining to wastewater.
NPDES Permits
Tennessee
Underground Injection Control Regulations
Tennessee
General Water Quality Rules
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 NPDES
permit to discharge to surface waters and you will likely need
a permit to discharge to your local sewer authority. Check with
your local POTW and the Tennessee Department of Environment and
Conservation (TDEC) to ensure you have the proper permits.
- Have
you performed the necessary pretreatment? If you are discharging
to a sewer system/treatment plant, you may have to perform pretreatment
of your waste. Check with your local sewer authority.
- 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 TDEC Division of Water Pollution
Control at 615-532-0625.
- To
report a spill or leak, call the Tennessee State Emergency Operations
Center 24-hour hotline at 800-262-3300, or the National Response
Center at 800-424-8802.
- To
report an environmental incident or complaint, contact the nearest
regional office.
Related
ECAR Fact Sheets
- Stormwater
- Septic Tanks and Disposal
Wells
Other
Relevant Resources
- Tennessee’s NPDES
Program Permitting Information
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