Ensure your compliance to regulatory requirements.
By Sue Schauls
The Clean Water Act (CWA) requirements established a framework for regulating industrial storm water discharge under the National Pollutant Discharge Elimination System (NPDES) permit, commonly referred to as a storm water permit, based on their potential to contribute to storm water pollution from industrial activity. Those industries identified by standard industrial classification (SIC) code include salvage activity. Automotive salvage activity typically uses SIC code 5015 for whole-sale used automotive parts.
Automotive salvage yards have concerns for adding pollutants to storm water runoff due to the sheer number of vehicles present in a yard at any given time. Effective pollution prevention of these pollutants is accomplished through choosing the most applicable Best Management Practice (BMP) as identified in the Storm Water Pollution Prevention Plan (SWPPP) developed as part of the storm water permit requirements.
The storm water permit process differs from state to state but basically follows the U.S. Environmental Protection Agency guidance:
1) Complete a Notice of Intent (NOI) to discharge storm water.
2) Run a public notice in local newspapers.
3) Pay the applicable fee to the state agency.
4) Prepare and maintain a Storm Water Pollution Prevention Plan (SWPPP).
5) Begin an annual inspection of the facility for storm water pollution prevention and provide training to employees.
6) Monitor the storm water runoff by collecting samples for laboratory analysis, based on the state specific interval, either annually or quarterly (or not at all!).
The Automotive Recyclers Association requires certified member facilities to attain and maintain a storm water permit, a certificate of no exposure or a state specific waiver based on zero discharge or location within a Municipal Separate Storm Sewer System (MS4), generally in large urban areas.
The ARA CAR Certification program has asked environmental assistance groups, state agencies and certification auditors to provide storm water training workshops to help all auto recyclers to maintain compliance with the stormwater regulations. Planned storm water workshop webinars will be posted on the Environmental Compliance for Auto Recycling (ECAR) website at http://www.ecarcenter.org. Workshops are currently planned for Michigan, Iowa, Kansas, Connecticut, and Wisconsin. Details are found on the ECAR Center website.
The ECAR Center is a “one-stop shop” for all automotive dismantling and recycling operations and provides comprehensive and up-to-date environmental compliance assistance. Its mission is to help reduce potential impacts on the environment from the automotive recycling sector through better availability of information regarding various forms of best management practices, pollution control and prevention and compliance with environmental regulations.
Sue Schauls is an environmental and safety expert whose career started 28 years ago at the Iowa Waste Reduction Center at University of Northern Iowa. She is the Certification Consultant to the ARA and can be reached at sue@a-r-a.org. She is also the Executive Director of the Iowa Automotive Recyclers association and compliance consultant to the industry through the ARA’s Certified Auto Recyclers (CAR) program and the I-CARE program – Iowa Certified Automotive Recyclers Environmental Program.
