ECAR Fact Sheet for Texas
Wastewater Discharges

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

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

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 industrial discharges is usually handled by wastewater treatment plants, but you are usually required to conduct "pretreatment" of the discharge. The second is 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. If you have questions regarding sanitary wastewater, contact your local sewer authority or the Texas Commission on Environmental Quality (TCEQ) Water Quality Division.

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.

There are three primary options for disposing of industrial wastewater from auto recycling facilities:

1. Haul it 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 "hazardous" you must manage it using special procedures. For more information, see the Hazardous Waste Plain Language Guide. If the wastewater is non-hazardous, then you should maintain test records that support your determination.
2. Discharge it to a municipal sanitary sewer system (POTW). You will need to obtain a permit or written permission to discharge to your local sewer system and you must follow any local rules that apply. You will also have to follow certain federal and state rules. These rules may or may not be stated in your permit. A summary of the federal and state rules is given below.
3. Discharge it to a stream, pond, lake, wetland or other water source. This is a potential option, but one that requires a TPDES permit (Texas Pollutant Discharge Elimination System). 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 an economical solution when there is a sufficiently small volume of wastewater generated (see BMPs for minimizing the volume). Option 2 is viable when the facility is located in an area served by a municipal sanitary sewer system. Before you begin to discharge industrial wastewater using option 2 you must acquire a permit or written notification from either your local sewer district or TCEQ. 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;
• 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 these rules, 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). In most instances, wastewater will require some form of pretreatment prior to discharge into the sewer system.

There may be other restrictions, beyond pretreatment requirements, so recyclers must check with local sewer authorities.

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. The UIC program was established as part of the Safe Drinking Water Act and requires facilities that discharge non-sanitary wastewaters to ground water to either (1) close the cesspool, dry well or septic system, or (2) obtain a permit under the UIC program. For more information, see the Septic Tanks and Disposal Wells Fact Sheet.

Permits. The TCEQ encourages applicants to set up a preapplication meeting by calling the Wastewater Permitting Section, prior to submitting a TPDES permit application. Prior to submitting new permit applications or amendment applications, the applicant must determine if the receiving water is listed on the State of Texas Clean Water Act Section 303(d) list. This list identifies waters in the state that do not meet, or are not expected to meet, applicable water quality standards. If the receiving water is on the 303(d) list, the TCEQ will carefully evaluate if the proposed new permit or proposed additional discharge (e.g., flow increase) will cause or contribute to the violation of water quality standards. Federal requirements prohibit any issuance of a permit to a new source or a new discharger if the discharge will cause or contribute to a violation of water quality standards.

Links to the Regulations and Forms. Use the following links to view the regulations and permit forms pertaining to wastewater.

TDEQ Wastewater Permits

Texas Surface Water Quality Standards

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.

1. 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.
2. 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

1. For more information on water issues, contact the TCEQ Water Quality Division at 512-239-4671.
2. For general questions, contact the TCEQ Regional Office nearest you.
3. To report a spill/release or other pollution emergencies, contact the Emergency 24-hour Hotline at 1-800-832-8224.
4. To report an environmental incident or complaint, contact 1-888-777-3186.

1. Floor Drains
2. Stormwater
3. Septic Tanks and Disposal Wells

1. Washwater Guidance Manual

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