Friday, February 19, 2010

MPCA Requirements for Automobile Salvage Yards Sector

The Minnesota Pollution Control Agency (MPCA) has issued its revised multi-sector industrial stormwater discharge general permit (MSGP). This permit will replace the existing industrial stormwater permit, which expired in October of 2002.

[Read a summary of the overall Minnesota permit, stormwater monitoring, and sector requirements]

All manufacturing, industrial and “industrial-like” sites that require a permit to discharge stormwater will be required to come into compliance with the revised permit, and to submit an application for permit coverage by either June 1, August 1 or October 1, depending on their industrial sector.

Click here to review a list affected industrial sectors and application deadlines for each sector

The revised permit details requirements for 29 different industrial sectors. The requirements described below are 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, refrigerants, 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 refrigerants 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 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, refrigerants, 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.

If stormwater ponds are built, they must meet design standards listed in the permit. No new stormwater infiltration devises are allowed.

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 must evaluate 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 revised MPCA industrial permit]
[Read more about what a 100 mg/L benchmark for TSS relates to]

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 in Minnesota 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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