Saturday, April 4, 2009

Auto Salvage Sector - SWPPP - Stormwater Permit Proposed Requirements

UPDATE: On July 6, 2009, MPCA is scheduled to release its proposed Multisector Industrial General Stormwater Permit. In July, Caltha LLP will be hosting seminars in several cities across Minnesota to provide information on the proposed permit and rule changes, and steps facilities can take to reduce their impact.

For more information, go to:

MPCA SWPPP Permit - Industrial Stormwater Permit Reissue Seminars


On March 19, 2009, the Minnesota Pollution Control Agency released a revised working draft of its proposed multisector industrial stormwater discharge general permit. This permit, once promulgated, will replace the existing industrial stormwater permit, which expired in October of 2002.

Some key changes in the March 19, 2009 draft are the additional details for 25 different sector specific requirements. The requirements described below are proposed for the Automobile Salvage Yards Sector (Sector M). Sector M includes sites primarily engaged in the dismantling or wrecking used motor vehicles for parts recycling or resale and scrap. These requirements are in addition to permit requirements that apply to all sectors.

Employee Training:
The SWPPP must address the following areas in the employee training program: proper handling (collection, storage, and disposal) of oil, used mineral spirits, anti-freeze, mercury switches, freon, and solvents.

Good Housekeeping:
The SWPPP must include to the maximum extent feasible:
1) store all batteries indoors;
2) recycle lead battery cable ends and wheel balancing weights;
3) remove all fluids from vehicles and recycle or dispose accordingly;
4) remove and segregate mercury switches and mercury containing devices;
5) recycle fuels,
6) remove and dispose of freon as required with complete avoidance of venting to atmosphere;
7) remove and dispose of glycols as required;
8) remove and recycle all lead parts;
9) separate and recycle, if feasible, plastics or dispose as solid waste;
10) store all engines and transmissions (that have been removed from vehicles) in covered areas not exposed to precipitation.

The site must immediately inspect vehicles arriving at the facility for leaks. The site must inspect for signs of leakage, all equipment containing oily parts, hydraulic fluids, any other types of fluids, or mercury switches; and also inspect all vessels and areas where hazardous materials and general automotive fluids are stored, including mercury switches, brake fluid, transmission fluid, freon, and antifreeze.

The facility must conduct two of the monthly inspections during runoff events. One of the inspections shall be performed during a snow melt runoff event. Each inspection must include a visual assessment of the runoff to identify any visible sheens or films that indicate the presence of oil or grease in the discharge.

Stormwater Controls:
Each site must implement the following management practices: berms or drainage ditches on the property line (to help prevent run-on from neighboring properties); installation of detention ponds; installation of filtering devices such as sand filter or mixed media filters, and oil and water separators. Engines and transmissions, and similar oily parts shall be stored in covered areas or, at a minimum, be covered with impermeable tarps or similar material to eliminate contact with stormwater; and Above ground liquid storage tanks must have secondary containment.

Mercury Minimization Plan:
All automotive recyclers must enroll in the End of Life Vehicle Solutions Corporation (ELVS) program. The ELVS program took over the management of the Minnesota Mercury Recovery Program for automotive recyclers and scrap metal recyclers in May 2006. ELVS provides these recycling operations with collection buckets and will pay the costs of transportation, retorting/recycling or disposal of elemental mercury from the automotive switches. ELVS provides educational materials to promote vehicle and scrap metal recycling and proper management of mercury switches and other mercury containing devices.

In addition to the ELVS program, each site must also evaluate its facility to identify and determine any additional sources of mercury that may be introduced to, or used at, the facility. This may include mercury containing devices such as switches including float switches, manometers, barometers, batteries, flame sensors, hydrometers, manometers, medical devices, lamps, mercury compounds, pyrometers, relays, thermometers, freezers, pressure gauges, thermostats, etc. The plan mustevaluate how any mercury containing devices may be removed to the extent feasible, or segregated to avoid spills and contact with stormwater.

Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual and chemical (benchmark) monitoring. For benchmark monitoring, the benchmark concentrations or values apply to all facility types:

TSS 100 mg/L
Total Aluminum 1.5 mg/L
Total Lead 0.164 mg/L
Total Iron 1.0 mg/L

Note: Benchmarks for lead, aluminum, iron were derived based on the Aquatic Life Standards for these parameters in Minnesota Rules.

[Read more about use of Aquatic Life Standards to derive stormwater benchmarks]
[Read more about how benchmarks are used under the proposed MPCA industrial permit]
[Read more about what a 100 mg/L benchmark for TSS relates to]

The March 19, 2009 draft for the industrial stormwater discharge general permit is a “work in progress”; it is anticipated that requirements will change prior to being published for public review and comment.

Looking for other sector information? Click here for a link to all sector requirements

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at
Caltha LLP Website

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