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 VPDES general permit registration statement requirements and General Permit (VAC 25-151) found below under "Links to the Regulations and Forms". To apply for coverage under the general permit, you must: 1. Prepare and implement a Storm Water Pollution Prevention Plan (SWPPP) according to the requirements given in 9 VAC 25-151-80 of the general permit. 2. Complete and submit a Virginia Pollutant Discharge Elimination System (VPDES) general permit registration statement to: You must submit a registration statement at least 30 days prior to the commencement of the industrial activity at your facility. If your facility discharges stormwater through large or medium municipal separate storm sewer systems (systems located in a city with a population of 100,000 or more), you are required to submit a copy of your registration statement to the operator of that system. 3. The general permit (VAC 25-151) expires at midnight on June 30, 2004. If you wish to continue your coverage under the new general permit, you must submit a new registration statement at least 180 days before the expiration date of the existing permit. 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 storm water pollution prevention plan (SWPPP) must be developed for each facility covered under the general permit. This plan must be implemented before you submit your registration statement. The requirements of the plan are described in section 9 VAC 25-151-80 of the general permit. The SWPPP must be signed in accordance with 9 VAC 25-151-70 E 11 of the general permit and must be retained on-site and made available to the authorities upon request. 2. Update the SWPPP as necessary whenever there is a change in your operations that has a significant affect on stormwater. 3. At least once a year, a comprehensive inspection must be performed to evaluate compliance. A report summarizing the inspection must be prepared according to 9 VAC 25-151-80 D 4.c of the general permit and retained on-site for at least three years. 4. Quarterly visual inspections of BMPs are required to be conducted by qualified facility personnel according to the details given in 9 VAC 25-151-200 C.c. 4. Automotive recycling operations are required to perform analytical monitoring for the pollutants listed in Table 200 of section 9 VAC 25-151-200 at least semi-annually (2 times a year) during the second and fourth years of coverage under the general permit. The details describing the monitoring requirements are given in section 9 VAC 25-151 C of the general permit. 5. The results of the analytical monitoring must be reported on a Discharge Monitoring Report (DMR) form according to 9 VAC 25-151-70 E 3. These results must be submitted to the Department’s regional office no later than the 10th day of the month after monitoring takes place. Except for the information related to your sewage sludge use and disposal activities (which must be retained for a period of at least five years) all of your monitoring information must be retained onsite for a period of three years from the date of the sample or report. Your SWPPP 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 SWPPP you must consider the use of certain BMPs that EPA and VPDES 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 hazardous waste determinations and management. Federal EPA National Pollutant Elimination Discharge System (NPDES) Stormwater Regulations VPDES Industrial General Permit Registration Statement VPDES Permit Application Fee Form 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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