achieving compliance with the stormwater rule & other environmental rules for auto salvage yard...
TRANSCRIPT
Achieving Compliance with the Stormwater Rule
& Other Environmental Rules for Auto Salvage Yard
Prepared by the
Small Business Environmental Assistance
Program
Partnership for Clean Waters
Small Business Environmental Assistance Program
Partnershipsfor
Clean Waterin
Tennessee
Small Business Environmental Assistance Program
What is the SBEAP?A technical,
administrative, and regulatory support program on environmental
issues for small businesses
How We Can Help You?
Workshops like the one today Free confidential Site Visits Hands on Help with Permits and
compliance assistance Helpful Materials - Brochures,
Videos and Handouts Access to Free Local Assistance
Workshop Objectives
Educate the auto salvage industry on the impacts of Storm water run-off
Explain the Storm water Rule and Policy and their regulatory impacts
Explain other environmental laws impact the auto salvage industries
Review and encourage Best Management Practices for handling day to day operations to reduce exposure risk and pollution
Provide resource and assistance information
View Video
Workshop Topics
Storm Water Runoff Clean Water Act Storm Water Permit Notice of Intent (NOI) Storm Water Pollution Prevention Plan Environmental Rules Best Management Practices
Storm Water Runoff ...
Storm water runoff is simply rain water or ice and snow melt that runs off the land into streams, rivers, and lakes. When storm water runs through polluted sites it picks up pollutants and transport them into water ways.
Storm Water Pollutants
Oil & Grease Transmission fluids Hydraulic fluids Antifreeze Lawn care chemicals Toxic chemicals Sediment Bacteria
Storm water Pollution Harms Our Environment ...
Pollute our drinking water supply
Restrict swimming area Kills fish Fish consumption advisories
have been issued in Tennessee
Protecting Storm Water Benefits your Business
Professionalism and pride in your business
It’s the Law Environmental Protection
Regulatory Hierarchy …
Congress (Clean Water Act) Environmental Protection Agency
(EPA) Code of Federal Regulations (CFR) States (Tennessee Multi-Sector
Permit) Local (Permit, Policy, and Guidance)
Clean Water Act …
1899 Rivers and Harbors Act 1948 Federal Water Pollution Control
Act (FWPCA) 1965 Water Quality Act 1970 Refuse act Permit Program 1972 FWPCA Amendment 1977 Clean Water Act 1987 Water Quality Act
Water Quality Act of 1987 …
The law allowed the EPA to govern storm water discharges from 11 categories of industrial activities and construction sites
Discharge of Storm Water was associated with Industrial Activity
11 categories of industrial activities include manufacturing, processing, materials storage, recycling, mining oil and gas, hazardous waste facilities, landfills, steam electric power plants and more…
Storm Water Permit
Individual permit Requires more Monitoring More Expensive to implement
Tennessee Multi-Sector Permit (TMSP)
How to apply for a Storm Water Permit?
Prepare Storm Water Pollution Prevention Plan (SWPPP)
File Notice of Intent (NOI) for the TMSP with regulatory Agency
Storm Water Pollution Prevention Plan
Prepare a Stormwater Pollution Prevention Plan …
Identify items to be included in SWPPP SWPPP Coordinator
Create a SWPPP Team Identify Responsibility Each Member Implement the SWPPP Plan Implement and Oversee Employee Training Conduct inspection and Monitoring Oversee maintenance practices of the
SWPPP Prepare and submit report
Prepare a Stormwater Pollution Prevention Plan …
Facility Description Site Map Facility Location Site Activities Site Description Storm Water Drainage System
Prepare a Stormwater Pollution Prevention Plan …
Inventory of Potential Pollutant Sources Significant Material Inventory Historic Spill and Leak Record Potential Areas for Storm Water
Contamination Available Storm Water Sampling Data
Prepare a Stormwater Pollution Prevention Plan …
Storm Water Management Control Compliance with Other Programs
• Resource Conservation Recovery Act (RCRA)
Storm Water Management Practices• Best Management Practice (BMPs)
Storm Water Treatment
Facility Monitoring Requirements …
Three Types of Monitoring Visual Examination Compliance Monitoring Analytical (Chemical) Monitoring
Visual Monitoring Requirements …
Quarterly examination of discharge Color Odor Solids Foam
No analytical tests
Compliance Monitoring …
Annual Compliance Inspection Required Annually Determine Best Management Practices
Implemented Operational Change
Analytical Monitoring
Required Annually Grab Sample(s) Required to Submit Results March 31st of the Following Year
Compliance and Reporting Requirements
Employee Training Implementation of SWPPP Schedule Record Retention (three years) Principal Executive Office Signature Provision for Amendment of the Plan Corporate Certification
Notice of Intent (NOI)
Storm Water Application Review
When will the Storm Water Permit Expire?
Storm water permit expires every 5 years
Storm water permit for auto salvage yard expires December 31, 2006
Annual fees
No fee for facilities less than one acre
$250 for facilities equal to or greater than one acre and less than five acres
$300 for facilities equal to or greater than five acres and less than 10 acres
$450 for facilities equal to or greater than 10 acres and less than 25 acres
Other Environmental Laws for Auto Salvage Yard
Resource Conservation Recovery Act (RCRA)
Comprehensive Environmental Response Compensation Liability Act (CERCLA)
More about RCRA ...
The Resource Conservation and Recovery Act (RCRA) regulates the generation, storage, disposal, and treatment of wastes.
RCRA Goals ...
Protect us from the hazards of improper waste management
Conserve energy and natural resources by recycling and recovery
Reduce or eliminate waste
Clean up waste, which may have spilled, leaked, or been improperly disposed of
Types of waste
Solid Waste Non-hazardous waste Hazardous waste Special waste
Definition of Hazardous Waste
Hazardous waste exists in many forms such as solid, liquid and gas.
How do we know we have hazardous waste? Hazardous waste are either listed or
they exhibit any of four characteristics: ignitable, corrosive, toxic, or
reactive (flammable)
Tell me more …
There are three main types of generators of hazardous waste:- Conditionally Exempt Small Quantity
Generator (CESQG), less than 220Ib (100kg) a month
- Small Quantity Generator (SQG), more than 220 Ib (100 kg) less than 2200 Ib (1000kg) a month
- Large Quantity Generator (LQG), more than 2200 Ib (1000 kg) a month
Requirements for CESQG
- Identify your hazardous waste- No more than 2200 pounds (1000
kg) of hazardous waste accumulated at any one time
- Comply with storage quantity limits- Ensure proper treatment and
disposal of your waste
Requirements for SQG
Get an Environmental Protection (EPA) Identification Number
Obtain a copy of EPA form 8700-12 Fill in the form completely Send the form to State Division of Solid
Waste Management
Requirements for SQG
No more than 13200 pound ( 6000 kg) of hazardous waste accumulated at an one time
Comply with storage quantity limits
Ensure proper treatment and disposal of your waste
Selecting a transporter of Hazardous Waste
Determine your needs:- Quantity- Types- Costs- References- Permits- Insurance- Compliance history
Best Management Practices
Best Management Practices for Auto Salvage Yards …
Drain all fluids from vehicles upon arrival at the site. Segregate the fluids and properly store and dispose of them.
Keep waste stream separate (i.e waste oil and solvents). Non-hazardous substances that are contaminated with hazardous substances are considered a hazardous waste.
Best Management Practices for Auto Salvage Yards …
Recycle antifreeze, gasoline, used oils, and solvents
Dispose of greasy rags, oil filters, batteries, and spent coolants properly
Label and track the recycling of waste materials
Promptly transfer used fluids to the proper container
Best Management Practices for Auto Salvage Yards …
Plug floor drains that are connected to the storm sewer
Filter storm water discharges with devises such as oil-water separators
Train employees on proper waste control and disposal procedures
Store batteries on impervious surface. Curb, dike or berm this area
Best Management Practices for Auto Salvage Yards …
Confine storage of parts, equipment and vehicles to designated areas
Cover all the parts storage areas with permanent roof or temporary cover (canvas tarps)
Best Management Practices for Hazardous Waste
Use a container compatible with type of waste generated
Keep accumulation containers closed except when adding or removing waste
Label containers with words “Hazardous waste”
Mark accumulation start date on container Do not mix hazardous waste with non-
hazardous waste Meet record-keeping and reporting
requirements
Benefits of Best Management Practices
Cleaner, Safer Shops Healthier work environment, with
potentially fewer employee sick days
Reduced potential for exposures Waste reduction
Benefits of Best Management Practices
Lower costs Easier to meet regulatory
requirements Reduced pollutant emissions Better worker protection and
satisfaction
Benefits of Best Management Practices
Reduces harm to the environment Environmental fines and liabilities
for improper management avoid ed
Resources for Auto Salvage Yards
Best Management Practices Web Sites & Associations Technical fact sheets & Brochures Training workshops
On-line Resources
Tennessee Small Business Environmental Assistance Program (SBEAP)
http://www.tn.gov/environment/apc/sbeap/
Others: http://www.ccar-greenlink.com http://www.ecarcenter.org
HOW DOES OZONE AFFECT YOU
•Good up high, Bad nearby
• A gas of 3 Oxygen atoms
• NOX +VOC’s + sunlight = Ozone
•CFC’s + UVB rays = O3 “eaters”
HOW DOES OZONE AFFECT YOU
•Smog is harmful to plants
• UVB rays causes skin cancers
• Double trouble - single fix
THE OZONE EATERS
RELATIVE SOURCES OF CFC’S
• Refrigeration and A/C systems• Shop parts cleaning solvents• Foam Product • Halon Firefighting and Lighting Equipment• Aerosols• Medical sterilization processes
OH SAY CAN YOU CFC
•You must recover, recycle or reclaim all CFC’s from vehicles and equipment
•Anyone servicing a vehicle A/C system must be certified
OH SAY CAN YOU
CFC
•All shops servicing A/C systems must have EPA approved recovery equipment
•Violating 1990 TITLE VI LAWS can cost $25,000.00 per day per violation
HISTORY OF OZONE PROTECTION LAWS
• Sept. ‘87- 24 Nations sign Montreal Protocol to reduce / eliminate Ozone depletion
• Jan. ‘90- USA Clean Air Act Amendments Title VI regulates making, selling and using CFCs
• Nov. ‘93 - EPA standards for A/C equipment
HISTORY OF OZONE PROTECTION LAWS
•Nov. ‘94 - EPA sales restrictions of A/C gases to certified technicians only
•June ‘95 - EPA list of approved gas substitutes •Dec. ‘95 - EPA CFC manufacturing prohibition
REFRIGERANT SAFETY
Understand refrigerant MSDS specifications
Follow equipment operation instructions
Wear all required personal safety equipment
Never inhale A/C Gas or -oil mist Settles in low spots
REFRIGERANT SAFETY
Use only “DOT” approved storage tanks
Never mix R-134a with air to check for leaks
Never use a disposable tank again -- NEVER AGAIN
Never fill any tank past 60% capacity
REFRIGERANT SAFETY
NO CERTIFICATION / NO SERVICING SYSTEM
SUMMARY SLIDE
TITLE VI Regulates production and use of Ozone depleting chemicals
TDEC does not have TITLE VI enforcement authority
TDEC will refer complaints to Region 4 of EPA for their investigation
IT’S COOL TO RECYCYLECOOLANTS , OIL , & FLUIDS
Recycle Oil
(800) 287-9013
SBEAP
(800) 734- 3619
PAY ME NOW OR PAY ME LATER
Citations
Lawyers
Fines
Shutdowns
BE AWARE AS YOU REPAIR
The oil you waste-you may soon taste !
Floor drains do the right thing
Label & date all containers
Never mix shop fluids
BE AWARE AS YOU REPAIR
Use drip pans
Drain all fluids before starting
Work under a covered bay
Work on impervious floors
SPILLS CAN & DO KILL
Great fishing spots
Household pets
Game & Wildlife
Aquatic birds-Exxon
SPILLS CAN & DO KILL
Landscaping
Crops & Fruit Groves
Timber stands
Creeks, Rivers, Lakes
Summary
Auto salvage yards must have a Storm water permit
Failure to have a permit or to comply with terms of a permit that you already have can subject your facility to a penalty, fine, and possible business closure
Comply with other environmental rules Review Best Management Practices for
handling waste materials Be in compliance and call us if we can
help
CALL US TOLL FREE AT:CALL US TOLL FREE AT:
1-800-734-36191-800-734-3619
Tennessee Small Business Environmental Assistance Program (SBEAP)
Have a Great Day !!!
Wrap -Up - Q&A
Contacts
Workshop Evaluation(s)