ECAR Fact Sheet for Vermont
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

As an auto recycler, you almost certainly generate wastewater through operations such as rinsing parts and washing engines, cars 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're potentially causing significant problems for which you will be held responsible.  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 decided to focus on auto recyclers in particular. 

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 with the proper permits. Non-sanitary or "process wastewater" discharges are 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 illegally 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.
• "Process 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, equipment, trucks, or machinery.

Sanitary wastewater can be discharged to a city sewer system or an approved septic tank system, but you will need a wastewater disposal permit from the Vermont Department of Environmental Conservation (DEC) Wastewater Management Division (WWMD). The only exception is if your discharge began prior to 1970, and the system has not been modified since 1970. Contact the WWMD Regional Office serving your area for more information on obtaining a discharge permit.

Process wastewater is regulated differently than sanitary wastewater. If you combine sanitary and process wastewater, then the mixed wastewater is regulated like process wastewater. All process wastewater discharges are regulated by federal and state regulations and in most cases, also by local regulations established by the wastewater treatment facility.

Disposal Options.  There are four primary options for disposing of process wastewater from auto recycling facilities:

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 approval from your local sewer district or POTW. You also will 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 often must be between 6.0 and 9.0;
• 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.

Multi-Sector General Permit for Stormwater Discharges

Vermont Underground Injection Control Regulations

Vermont Water Pollution Control Regulations

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 Multi-Sector General Permit to discharge to surface waters and you will likely need a permit to discharge to your local sewer authority. Check with your local wastewater treatment facility and the Vermont Department of Environment and Conservation (DEC) to ensure you have the proper permits.
2. 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.
3. 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, contact the Vermont Department of Environmental Conservation, Wastewater Management Division at 802-241-3822.
2. To report a spill or leak, call the Vermont Division of Waste Management at 802-241-3888 (weekdays), the 24-hour spill reporting hotline at 800-641-5005, or the National Response Center at 800-424-8802.
3. To report an environmental incident or complaint, call 802-241-3820, or contact the nearest regional enforcement officer.

Related ECAR Fact Sheets

1. Stormwater
2. Septic Tanks and Disposal Wells

Other Relevant Resources

1. VT DEC Wastewater Discharges Fact Sheet
2. Vermont EAD - Auto Salvage Yard Environmental Resource Center

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