Connecticut DEP issued a revised General Permit with an Effective Date of October 1, 2011

• Applicable to “Auto Salvage Yards” which have specific “Sector” requirements
• Numerous significant changes from previous Stormwater General Permit

 What Do I Need To Do?

• Any facility with an existing Stormwater Permit must complete the registration form and submit it to the CT DEP along with their payment (most auto recyclers fee is $500, $1,000 for larger facilities) by June 1, 2011.
• Update your site SWPPP in accordance with new October 1, 2011 General Permit
• SWPPP must be certified by Professional Engineer (PE) or Certified Hazardous Materials Manager (CHMM)

NOTE: The stormwater plan itself can be completed after the June 1, 2011 deadline as just the Registration Form with payment is due by June 1, 2011.

What If I Don’t Already Have A Stormwater Permit?

•  New Registrations have until either July 1st or August 1st, 2011 However if you are and existing facility that should have previously registered the CT DEP is requiring:
  • Register under the existing CT DEP Stormwater General Permit (e.g. October 1, 2002)
  • Then register again under the new CT DEP Stormwater General Permt (e.g. October 1, 2011)

What Are the Penalties for Not Registering for a Stormwater Permit?

• The CT DEP has the ability to issue Fines and/or an Administrative Order known as a Consent Decrees
• Terms for any Fines and/or Administrative Orders (Consent Decrees) are established on a case-by-case basis

What Are My Next Steps?

 For Further Information Contact Korth Engineering, LLC at:

• Phone: (860) 295-9458 or (860) 989-2800
• Email: enveng@kortheng.com
• Website: www.kortheng.com

Answer:The Connecticut Department of Environmental Protection (CT DEP) issues a General Permit for the Discharge of Stormwater Associated with Industrial Activity in accordance with U.S. EPA guidelines.  Any facility with a Standard Industrial Code (SIC) detailed in this General Permit is automatically included in the program.  Auto Recyclers have an applicable SIC code.  Two (2) options are regulatory available:

a) Prepare a SWPPP for your site in accordance with the CT DEP Stormwater General Permit.  Note: Permits must be certified by a Professional Engineer (P.E.) or Certified Hazardous Materials Manager (CHMM) and revised whenever the CT DEP issues a new General Permit which is typically every 5 years).  OR

b) Demonstrate with a “No Exposure Certification” that a SWPPP is not applicable to the facility.

Question:How does a facility demonstrate that there is No Stormwater Exposure?

Answer:  A CT DEP No Exposure Certification form (DEP-PERD-REG-014NE) form must be completed.  In order to utilize this form all answers detailed in “Part V: Exposure Checklist” must be able to be checked as “No”.  An excerpt of “Part V:” from this checklist is detailed below.

Note: The complete No Exposure Certification Form is available from the CT DEP Website at (http://www.ct.gov/dep/site/default.asp) under “Water Discharge Permits and General Permits” in the permit type “Stormwater Associated with Industrial Activities” then under Common Forms.

WHAT ARE MY REQUIREMENTS AND WHEN?

Question: Why is Initial and Annual Reporting of Chemicals Required?

Answer: Reporting includes the Local Emergency Planning Commission (LEPC) which is typically the local Fire Department who are the First Responders if there is an on-site incident.  Reporting is required so that the LEPC is aware of the type of dangers present at the site.

Question: As an Auto Recycler what types of Chemicals May Require Reporting?

Answer: Typical Chemicals associated with Auto Recyclers’ which Require Reporting include:

• Oil (stored in excess of 10,000 lbs, approx. 1,320 gallons)
• Antifreeze (stored in excess of 10,000 lbs, approx. 1,100 gallons)
• Gasoline (stored in excess of 10,000 lbs, approx. 1,600 gallons)
• Diesel Fuel (stored in excess of 10,000 lbs, approx. 1,400 gallons)
• Sulfuric Acid (stored in excess of 500 lbs, approx. 100 batteries)
• Lead (stored in excess of 10,000 lbs, approx. 500 batteries)

Note: Reporting is based on the maximum quantity of the particular chemical stored on-site at any time during the calendar year.  Hence typically a good guideline to utilize is the “Potential” on-site storage capacity for that particular chemical.

 Question & Answer: When is Chemical Reporting Required?

•  Initial Reporting: Whenever Maximum Quantity of a Particular Chemical is Stored on-site
• Annual Reporting: By March 1^st of the particular Calendar Year

Question: What are the Potential Penalties for Not performing Labeling & Reporting?

Answer: There is the potential of monetary fines from Regulatory Agencies if discovered during an Inspection.  However the most significant concern is Civil and/or Criminal Liability associated with an on-site Incident!

 For Further Information Contact Korth Engineering, LLC at:

•  Phone: (860) 295-9458 or (860) 989-2800
• Email: enveng@kortheng.com
• Website: www.kortheng.com

WHAT ARE MY REQUIREMENTS & HOW DO I COMPLY?

As an Auto Recycler a variety of chemicals and petroleum products are stored and utilized on site.  Per the Emergency Planning and Community Right-To-Know Act (EPCRA) there are various regulatory requirements.  These requirements are not unique to Auto Recyclers as they are applicable to any business utilizing chemicals ranging from an office using cleaning supplies to a large manufacturer.

There are Four Typical Requirements which need to be Satisfied which are:

• Container Labeling with Material Names and OSHA Information
• Material Safety Data Sheets (MSDS) need to be available for All On-site Materials
• Initial Reporting of particular Chemicals stored on-site
• Annual Reporting of particular chemicals stored on-site

 How Do I Satisfy These Requirements?

 Container Labeling: Various Methods Available Including:

• Containers Labeled by Vendor Selling the Chemical
• Generic Labels with Required OSHA Information are available Free to CAR members
• Obtain Labeling Information from MSDS

 Material Safety Data Sheets: Various Sources Including:

• Available from Vendors who Supply the Chemical
• Generic MSDS’s available from various Chemical Publications or various Websites
• MSDS’s provided in the “Connecticut Auto Recycling Industry” “Management & Compliance” Program Guidebook (prepared by Korth Engineering, LLC) for Particular Materials for Waste Characterization purposes are also acceptable for satisfying OSHA Requirements

 Initial Reporting:Completion of Notification Forms and Submittal To Regulatory Agencies

 Annual Reporting:Completion of Tier II “EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY” Form and Submittal To Regulatory Agencies

For Further Information Contact Korth Engineering, LLC at:

• Phone: (860) 295-9458 or (860) 989-2800
• Email: enveng@kortheng.com
• Website: www.kortheng.com

Requirement:

• All containers containing used, scrap or waste materials must be properly labeled. Example items include: 1) pallets of used batteries 2) used oil in drip pans or in tanks 3) gasoline for on-site reuse or off-site disposal. Applicable labels need to address both Waste Management and OSHA regulations.

How Do I Know How To Label A Container?

• First a material must be properly classified according to applicable waste regulations, which includes consideration of both the material type and ultimate use or disposal method. Then the proper label or labels can be selected.  A “Connecticut Auto & Recycling Industry Management & Compliance Program” guide has been prepared for CAR that specifies recommended labeling for various types of materials.

Are There Any General Guidelines For Container Labeling?

• All containers from temporary containers such as drip pans to larger storage containers like pallets, drums or tanks need a Waste Management label (examples: “Used Oil”, “Gas”, “Universal Waste Used Batteries”). Hence materials need to be designated and segregated by material type and use / disposal method. The storage containers need to include a second label for OSHA purposes (examples: “Danger Windshield Fluid”, “Danger Corrosive Mercury”).   In particular cases an area can be labeled instead of, or in addition to, the container itself.

How Do I Obtain Labels?

• CAR has made various types of labels to address both Waste Management and OSHA requirements available to members for free.  These labels address requirements associated with common types of materials and typical use / disposal methods.  A copy of the “Connecticut Auto & Recycling Industry Management & Compliance Program” guide is also available free to CAR members.