ECAR
Fact Sheet for Virginia
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
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 Virginia Department
of Environmental Quality (DEQ) Water Quality Programs at 804-698-4108.
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:
- Haul it to a publicly owned water
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 ECAR
Hazardous Waste Fact Sheet.
If the wastewater is non-hazardous, then you should maintain test
records that support your determination.
- Discharge it to a municipal sanitary
sewer system. You will almost certainly have to "pretreat"
your discharge and you will need to obtain a permit or written
permission to discharge to your local sewer system. You will have
to follow all local laws that apply, as well as 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.
- Discharge it to a stream, pond,
lake, wetland or other water source. This is a potential option,
but one that requires a VPDES permit (Virginia 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 the DEQ. 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 you 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. Virginia has two
water permits that regulate industrial wastewater. In order to discharge
your wastewater to a water of the state, or a point-source discharge,
you must obtain a Virginia Pollutant Discharge Elimination System
(VPDES) permit. If your discharges constitute a non-point source
discharge, or discharge to a location other than a state water body,
you will likely need a Virginia Pollution Abatement (VPA) permit.
Check with your DEW regional office for more information.
Links to the Regulations and Forms.
Use the following links to view the regulations and permit forms
pertaining to wastewater.
Virginia
Pollution Abatement (VPA) Permit
Virginia
Pollutant Discharge Elimination System (VPDES) Permit
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.
- 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.
- 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 on water
issues, contact the DEQ Water Division at 804-698-4109.
- To report a spill or leak during
business hours, contact the nearest DEQ
Regional Office. During
nights, holidays and weekends, call the 24-hour number at 1-800-468-8892.
- To report an environmental incident
or complaint, contact the nearest DEQ
Regional Office.
Related
ECAR Fact Sheets
- Floor
Drains
- Stormwater
- Septic
Tanks and Disposal Wells
Other
Relevant Resources
None.
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