ECAR Fact Sheet for Vermont
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 (VTR050001) found below under "Links to the Regulations and Forms".

To apply for coverage under the general permit, you must:

1. Prepare and implement your Stormwater Pollution Prevention Plan (according to the description given in Section 6 of the general permit).

2. Complete and submit a notice of intent (NOI) form as well as the required fees to:

The fees for stormwater permitting are established by state statute and change periodically. When you request a NOI application form from the Vermont Agency of Natural Resources (VANR), you will be notified of current fees.

You must also send a public notice of your completed NOI by submitting on a form provided by the Secretary of the VANR to the municipal clerk of the municipality in which your facility and your discharges are located.

3. You must file your NOI with the VANR at least 90 days before you plan to discharge. Only after the Secretary sends you a written authorization verifying the validity of your NOI may begin to discharge according to the terms and conditions of the general permit.

The public notice period follows the receipt of any application for coverage under the general permit and is a time in which the Secretary of the VANR provides an opportunity for written comments regarding whether the application and certification comply with the terms and conditions of the permit. Your authorization from the Secretary is generally sent within 30 business days of the end of the initial ten-day public notice period.

4. The general permit (VTR050001) is a five-year permit that expires in 2008.

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 submitting your NOI to the Agency. The requirements of the plan are described in Section 6 of the general permit. The SWPPP must be signed according to section 10.8 of the general permit and 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 Section 6.3.5 of the general permit and retained on-site. If non-compliance if found, the SWPPP should be updated within two weeks of the evaluation.

4. Quarterly Visual Monitoring is required for facilities covered under the general permit. The specific requirements for the visual monitoring are given in Part 7.1.1 of the general permit.

5. Automotive recycling operations are required to perform Benchmark Monitoring of the pollutants given in Attachments A and B of the general permit. The purpose of this monitoring is to assess the effectiveness of the SWPPP and identify where amendments need to be made. Benchmarking must be preformed on a quarterly basis during years two and four of the general permit (2004 and 2006). The details of this required Monitoring are given in Part 7.1.2 of the general permit.

6. Records of your Monitoring must be made according to the guidelines given in Section 7.6 of the general permit. The results of the monitoring must be submitted to the Agency on a Discharge Monitoring Report (DMR) form, which may be obtained from the agency’s Stormwater Management Program. The completed and signed DMR forms must be sent to:

Vermont Agency of Natural Resources
Department of Environmental Conservation
Water Quality Division, Stormwater Management Program
103 South Main Street, Building 10 North
Waterbury, Vermont 05671-0408

The deadline for submission of analytical benchmark monitoring results is the last day of each monitoring year. These records must also be retained onsite for at least 5 years from the date of the measurement or inspection.

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 VANR 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.

General Permit VTR050001

Federal EPA National Pollutant Elimination Discharge System (NPDES) Stormwater Regulations

In addition to the MSGP for stormwater discharges associated with industrial activity, there are other stormwater permits that may apply to auto salvage recyclers. For more information:

VT Department of Environmental Conservation Stormwater Permitting Information.

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 (VTR050001) or has an individual stormwater permit issued by VANR.
2. Has your facility developed and implemented a stormwater pollution prevention plan? Verify that a SWPPP 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 stormwater benchmarking and visual inspections? Review your records to verify that benchmarking and inspections have been performed. Proof of these activities must be incorporated into your SWPPP.
4. Has your facility maintained monitoring results and records? Verify that all monitoring and inspection records are maintained for at least five years from the date of sample collection or for the term of the permit, whichever is greater.

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 802-241-4320.

Related ECAR Fact Sheets

1. SWPPP

Other Relevant Resources

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