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Indiana Department of Environmental Management

IDEM > Compliance > Land Compliance > Auto Salvage > Auto Salvage Recyclers Environmental Self-Audit Workbook > Section J: Water Section J: Water

All salvage operations need to be aware of their potential impact on storm water and how to decrease any negative impacts they may be having. Because many items at an auto salvage business are stored outside without cover, it is important to practice “good housekeeping measures”. These measures can help reduce or eliminate the exposure of contaminants released by activities such as fluids removal, dismantling, crushing, and shredding, to rain and snow. This section will cover the most pertinent water issues that businesses in the auto salvage sector encounter.

(1) Are there any existing or planned land disturbing activities greater than one (1) acre at your facility?

If “NO”, skip question 1a.

Land disturbing activities include any man-made change of the land surface, including purposefully removing vegetative cover, excavating, grading, filling, and construction activity that will expose the soil surface.

Consider your present and future activities; if your plans include any land disturbing activities as described above, circle yes. If you are not sure if your activities qualify, contact IDEM’s Office of Water Quality (OWQ) - Wetlands & Storm Water Section at (800) 451-6027 or (317) 233-8488.

Contacting IDEM will assist you with determination of your construction activity’s jurisdiction in relationship to either a storm water conservation district (SWCD) or municipal separate storm sewer system (MS4) entity at the local level.

Indiana Department of Environmental Management
Office of Water Quality Wetlands - Storm Water Section
100 N. Senate Avenue, MC 65-42 IGCN 1255
Indianapolis, IN 46204-2251

(1a) Does your facility have a permit for land disturbing activities as referenced under 327 IAC 15-5?

If you have determined that you are conducting or planning land disturbing activities greater than one (1) acre, have you contacted IDEM and received a permit for those activities? If the answer is “NO”, then you will need to submit a RTC plan form to IDEM.

If you have not already begun your land disturbing activities, your facility needs to obtain a valid permit under 327 IAC 15-5. To obtain a permit:

  1. develop a construction plan to address erosion, and sedimentation and pollutants that will be associated with the post construction land use;
  2. submit the construction plan to the local soil and water district office or to the local “Municipal Separate Storm Sewer System” (MS4) entity if your facility is located within an MS4 jurisdiction. Contact IDEM at the number on the right to determine if you are within a MS4 jurisdiction; and,
  3. submit a notice of intent (NOI) (including proof of publication, plan approval verification, and $100 application fee), to IDEM at the address in the orange box listed above.

If you have already started your land disturbing activity without a valid permit under 327 IAC 15-5, your facility needs to obtain a valid permit. To obtain a permit complete the three steps described above and take immediate action to implement appropriate erosion and sediment control measures to reduce the discharge of sediment.

(2) Is there extensive soil build-up on the roads around your facility?

Extensive soil build-up can be defined as the amount of soil or dirt build-up that may be a potential vehicle contamination issue, driving obstruction or driving hazard. Examine the roads around your property.

Can you see evidence that soil is being tracked onto the roads?

If there is evidence of tracking, circle YES and submit an RTC plan form.

If an RTC plan form is necessary, you can come back into compliance by keeping all public and private roadways cleared of accumulated soil/sediment resulting from run-off or tracking. Document all of your efforts in clearing the debris. Bulk clearing of soil/sediment cannot include flushing the area with water. Any cleared soil/sediment shall be redistributed on site so that it will not run-off or be tracked off the property.

(3) Is your facility (or any part of it) located in a potential floodway?

Examine your facility to determine if any part of it is in a floodway. A floodway is the channel of a river or stream and the parts of the floodplain adjoining the channel that are reasonably required to efficiently carry and discharge the flood water or flood flow of a river or stream.

“Floodplain” means the area adjoining a river or stream that has been or may be covered by flood water.

(3a)If you answered “YES” to the above question, does your facility have any construction or filling activities in a potential floodway?

If you have determined that your facility is in a floodway, are you planning/conducting any construction activities at your facility? A permit is required to erect, make, use, or maintain a structure, an obstruction, a deposit, or an excavation in or on a floodway. Typical activities requiring a permit may include bank protection, bridges, buildings, culverts, channel work, dams, excavations, fills, levees, outfalls, clean-ups, removals, and utility crossings.

If you are conducting construction or filling activities in a floodway, then you will need to submit an RTC plan form. The plan will indicate and document that you contacted the Indiana Department of Natural Resources - Floodplain Management Section at (877) 928-3755 or (317) 232-4160 to obtain a floodway construction permit.

(4) Is your facility (or any part of it) located within a potential wetland area?

The Clean Water Act defines wetlands as those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions.

Conditions and factors that determine a wetland area are presented on the next page.

This definition from the Clean Water Act means that a wetland has three main characteristics.

  • The first characteristic is vegetation. Wetland vegetation generally has shallow root systems, swollen trunks, and roots that grow above the soil surface. Common wetland vegetation includes cattails, bulrushes, sphagnum moss, bald cypress, willows, sedges, rushes, arrowheads and lily pads.
  • The second characteristic is hydric soils (e.g., soils that are developed in conditions where water has limited soil oxygen for long periods of the growing season). Indicators of hydric soils include peats or mucks, a thick layer of decomposing plant material on the surface, blue-gray or grayish color soil, or a rotten egg smell.
  • The third characteristic is hydrology. Wetlands can be hard to recognize as they can be dry during part of the year. Wetlands need to have water at or above the soil surface for a sufficient period of time so as to influence plant and soil type. Examples of wetland hydrology include standing or flowing water observed on the area during the growing season, waterlogged soil during the growing season, water marks on trees or other erect objects, and thin layers of sediments on leaves or other objects.

If you determine that your facility is located in a potential wetland area, you will need to submit an RTC plan form that indicates and documents that you have contacted both IDEM and the U.S. Army Corps of Engineers (USACE) to obtain any necessary permits. To determine any requirements that you may be subject to, contact IDEM’s OWQ - Wetlands & Storm Water Section at (800) 451-6027, also contact the USACE at (502) 315-6733 (Louisville), or (574) 232-1952 (South Bend).

(5) Does your facility or your landlord pay a municipality or community for water service?

If “YES”, skip question 5a.

(5a) If you answered “NO” to the above question, does your facility have a Public Water System (PWS) ID number?

A “public water system (PWS)” is any facility that has at least fifteen (15) service connections or regularly serves an average of at least twenty five (25) individuals daily for at least 60 days per year.

A PWS ID number is also needed for a private well that serves twenty five (25) individuals for at least 60 days per year. If your facility does not have a PWS ID number, you must submit an RTC plan form that indicates and documents that you have contacted IDEM’s Drinking Water Branch at (800) 451-6027 ext. 8-3299 or (317) 308-3299.

(6) Has your facility submitted a Rule 6 Notice of Intent (NOI) letter for storm water run-off exposed to industrial activity?

A notice of intent (NOI) letter is a written notification indicating a facility’s intention to comply with the terms of Rule 327 IAC 15-6, or Rule 6 general storm water requirements, in lieu of applying for an individual national pollutant discharge elimination system (NPDES) permit. An NOI letter includes information required under 327 IAC 15-6-5.

If your SIC code is 5015 and/or 5093, and you have activities or materials exposed to rain and snow, and you have a point source discharge composed of storm water and allowable non-storm water to a water(s) of the state, then you will need to submit a Rule 6 NOI letter for storm water run-off(327 IAC 5-1.5-40).

A Point source discharge is any discernable, confined, and discrete conveyance, including, but not limited to, any of the following from which pollutants are or may be discharged:

  1. Pipe
  2. Ditch
  3. Channel
  4. Tunnel
  5. Conduit
  6. Well
  7. Discrete fissure
  8. Container
  9. Rolling stock
  10. Concentrated animal feeding operation
  11. Landfill leachate system
  12. Vessel
  13. Other floating craft

A Water of the State is an accumulation of water, surface and underground, natural and artificial, public and private, or parts thereof, which are wholly or partially within, flow through, or border upon this state. However, the term does not include any private pond, or any pond, reservoir, or facility built for reduction or control of pollution or cooling of water prior to discharge unless the discharge there from causes or threatens to cause water pollution.

If you have no materials (e.g., cars, parts, machinery) stored outside, and no activities (e.g., fluid removal, crushing, shredding, dismantling) conducted outside, then you can file a U.S. EPA – No Exposure Certification form #3510-11 instead of an NOI. If you have already filed a Rule 6 NOI, then you must submit the Notice of Termination/Exclusion (NOT/E) form 54087 in conjunction with the No Exposure Certification. If your facility does not meet the definition of having a point source discharge, you may submit a Notice of Termination/Exclusion (NOT/E) form 54087.

If you have not submitted your NOI letter or no exposure exclusion form, you will need to submit an RTC plan form that describes how you will address this deficiency.

To be in compliance you will need to do one of the following items:

  • If you have activities conducted outside or materials stored outside, you will need to contact IDEM’s Office of Water Quality-Wetlands & Storm Water Section at (800) 451-6027 and submit a Rule 6 NOI form to IDEM. A $50 application fee and public notice in your local newspaper are required to be submitted with the NOI in order for it to be complete.
  • If you do not have any materials stored outside and do not conduct activities outside, you can contact IDEM’s Office of Water Quality-Wetlands & Storm Water Section at (800) 451-6027 and submit a no exposure exclusion form to IDEM.
(6a) Does your NOI identify all the locations of outfalls and drainage areas (i.e., an area that discharges surface water) at your facility?

An outfall can be any location where water leaves your property through a variety of conveyances , such as pipes, ditches, channels, tunnels, conduits (i.e., a natural or artificial channel through which something such as a fluid is conveyed), streams, curbs, gutters, or drain inlets.

 

Diagram of auto salvage recycler yard with outfalls noted.

Examine all your activities that could lead to storm water contamination (e.g., fluid removal, crushing, storage, dismantling). Identify all locations that storm water can travel from each activity and write them down. Next, compare the outfalls and drainage areas that you wrote down to the ones listed in your NOI. If there are differences between the two, then you will need to submit a RTC plan form. The RTC plan form should indicate and document that you contacted IDEM’s OWQ - Wetlands & Storm Water Section at (800) 451-6027 and submitted an amended NOI that reflects the outfalls and drainage areas on your property.

(7) Has your facility developed a Storm Water Pollution Prevention Plan (SWP3)?

After you submit an Notice of Intent (NOI), you have 365 days to develop and implement a SWP3. The SWP3 is a written document that prevents pollutant sources from entry into storm water run-off by developing and implementing best management practices and controls at your facility.

The plan should include:

  • a list of staff and their responsibilities for the storm
  • water pollution prevention team;
  • a copy of the NOI;
  • a site map and soil maps;
  • a description of the potential pollutant source areas, and a description of existing and planned management activities;
  • sampling strategies and analytical results of run-off monitoring; and,
  • references to any other applicable facility plans.

You should answer “NO” to this question if you have never developed and implemented a SWP3 at your facility, even if you are still within the initial 365 day window. If you have not developed and implemented a SWP3 at your facility, you will need to submit an RTC plan form that documents how you will address this issue. You must provide a timeline to IDEM indicating your schedule for developing and implementing your SWP3.

(8) Has your facility submitted the Storm Water Pollution Prevention Plan (SWP3) certification checklist (form 51287) signed by a qualified professional to IDEM?

A qualified professional is someone trained and experienced in storm water treatment techniques. An example of this may be a consultant or engineer who does storm water work.

If you have not submitted your SWP3 certification checklist, then you will need to submit an RTC plan form. To be in compliance, you will need to submit your SWP3 certification checklist to IDEM or provide a timeline for completing and submitting the SWP3 certification checklist to IDEM.

(9) Do you use good housekeeping measures to ensure that contaminants from auto salvage activities are not exposed to storm water?

For an example of a good housekeeping inspection program, see Appendix: Water of this guide. Good housekeeping is defined as maintaining a clean work environment to reduce or eliminate the potential mobilization of pollutants by storm water.

Examine your routines and policies at your facility. Do you conduct daily, weekly, or monthly inspections (depending on your needs) to determine if spills are cleaned-up, all fluids are stored in closed containers, all removed parts are stored under cover, and any other activities required to keep your facility clean and running smoothly are occurring?

If you do not take measures to ensure that you maintain a clean work environment at your facility, answer “NO”. If you answered “NO”, you will need to submit an RTC plan form. To be in compliance, you will need to implement good housekeeping measures. Describe the housekeeping measures that are being implemented and submit the plan to IDEM.

(9a) Has your facility developed best management practices (BMPs) to improve the quality of storm water run-off?

BMPs are any of the following measures to prevent or reduce the pollution of the Waters of the State. Schedules of activities, prohibitions of practice, treatment requirements, operation and maintenance procedures, use of containment facilities, and other management practices.

Have you developed and implemented BMPs at your facility? If you have not developed and implemented BMPs, answer “NO”. If you answered “NO” to this question, then you will need to submit an RTC plan form. To be in compliance, you will need to develop BMPs and submit them to IDEM. In addition, you will need to submit a schedule for implementing the BMPs.

A list of possible BMPs for water is located in Appendix: Water.

(10) Do you have records documenting your quarterly storm water inspections?

If you do not conduct quarterly inspections, or you do not maintain records of your quarterly inspections, you will need to submit an RTC plan form. To be in compliance, you will need to conduct and document quarterly storm water inspections, and then address any problems noted during an inspection. To be in compliance, you will also need to submit to IDEM a copy of your first quarterly storm water inspection.

See Appendix: Water for an example of a quarterly stormwater visual monitoring form.

(11) Do you have records of your annual employee training on the components and goals of the SWP3?

Do you conduct annual storm water training and maintain records? If your answer is “NO”, then you will need to submit an RTC plan form. To be in compliance, you will need to provide and document annual training to all employees regarding the components and goals of the SWP3. Provide the training documentation for the current year to IDEM.

Information for annual employee SWP3 training is located in Appendix: Water.

(12) Has your facility submitted storm water sample results of the required twelve (12) parameters?

The required parameters are: oil and grease, CBOD5 (carbonaceous biochemical oxygen demand), COD (chemical oxygen demand), TSS (total suspended solids), TKN (total kjeldahl nitrogen), total phosphorous, pH, nitrate plus nitrite nitrogen, lead, iron, copper and aluminum.

On an annual basis (or more frequently if requested), you will need to sample the outfalls designated on your NOI. The first annual sample must be taken prior to the implementation of the SWP3. Samples must be taken during a qualifying rainfall event. This means that all samples must be collected from discharges resulting from a measurable storm event at least 72 hours after the previous measurable storm event. A measurablestorm event means the total accumulation of rainfall mustbe greater than or equal to one-tenth (1/10) an inch ofrainfall.

Required grab samples must be collected during the first 30 minutes, or as soon thereafter as practicable, of discharge at the storm water outfalls. The pH measurement must be taken at the time the grab sample is collected (e.g., due to holding time exceedance, pH can not be analyzed by an off-site laboratory), and can not be estimated using a color comparison (e.g., test strips).

Each time you sample, you will need to test for all the parameters listed above. For information on where to send your samples, call IDEM’s OWQ - Wetlands & Storm Water Section at (800) 451-6027, or see Appendix: Water of this guide for a list of labs and consultants located in the state. A copy of the results must be submitted to IDEM within 30 days after receipt back from the lab. This submittal should include analytical results, a chain of custody form and field data from the time the sample was collected.

If you have not submitted your results, you will need to submit an RTC plan form. To be in compliance, you will need to sample all identified storm water run-off sources of the next measurable (one-tenth (1/10”) of an inch) rainfall event and submit results as well as plans to ensure sampling takes place annually to IDEM.

(12a) Do your sample results indicate any contamination* by the twelve (12) parameters?

Examine your storm water results. Do the results exceed the following benchmarks?

  • Oil and grease: 15 mg/LCBOD5: 30 mg/L
  • COD: 120 mg/L
  • TSS: 100 mg/L
  • TKN: Unknown sudden increase**
  • Total phosphorous: 2.0 mg/L
  • pH: 6.0-9.0 s.u. (anything < 6.0 and > 9.0 will
  • result in answering YES)
  • Nitrate plus Nitrite Nitrogen: 0.68 mg/L
  • Lead, total: 0.0816 mg/L
  • Iron, total: 1.0 mg/L
  • Copper, total: 0.0636 mg/L
  • Aluminum, total: 0.75 mg/L

If any of your results exceed the benchmark results, go to question 12b.

* Contamination means the results exceed the benchmark level.

** A sudden increase will be a marked increase in TKN results when compared with previous annual testing.

(12b) Did your facility identify the source(s) of the contaminant(s) and eliminate them?

If you determined that storm water results exceeded the benchmark levels, did you identify the source(s) of the contaminants(s) and eliminate them? If the answer is “NO”, then you will need to submit an RTC plan form. To be in compliance, you will need to:

  1. identify the source of the contaminant(s);
  2. develop and implement a plan to eliminate the contaminant(s); and,
  3. submit the plan to IDEM.
(13) Has your facility submitted the annual report to IDEM?

The annual report is required to be submitted 365 days after the NOI submittal.

The annual report should include the following:

  1. any changes to the original NOI;
  2. any changes to facility, operations or activities;
  3. comparison of all sampling results; and,
  4. any BMPs or corrective measures implemented.

If you have not submitted your report, you will need to submit an RTC plan form. To be in compliance, you will need to answer the questions above and submit your report to IDEM.

All correspondence should be addressed to:

Indiana Department of Environmental Management
Office of Water Quality
Rule 6 Coordinator
100 N. Senate Avenue, MC 65-42
Indianapolis, IN 46204-2251.

For more information, call IDEM - Office of Water Quality at (800) 451-6027 or (317) 233-8488.

Construction activity exceeding one acre.

For additional information about land disturbing activities, visit the IDEM Storm Water Permits Web site, or contact IDEM’s OWQ Wetlands and Storm Water Section at:

(800) 451-6027 or (317) 233-8488

For information regarding the development of a construction plan see the Indiana Storm Water Quality Manual, or contact IDEM’s OWQ - Wetlands & Storm Water Section at (800) 451-6027 or (317) 233-8488.

Construction activity exceeding one acre.

Extensive soil build-up.

Map of floodway and floodplain.

Construction within a floodway.

For additional information about activities in a floodway, visit the Indiana Department of Natural Resources Web site.

Forested wetland area.

Emergent wetland area.

For additional information about wetlands regulations, visit the IDEM Wetlands, Lakes & Streams website.

For additional information about drinking water, visit the IDEM Drinking Water Web site.

If you have any questions about drinking water rules and regulations contact the IDEM Drinking Water Branch at:

(800) 451-6027 ext. 8-3299 or
(317) 308-3299

or the U.S. EPA Safe Drinking Water Hotline at (800) 426-4791.

Planned retention pond.

List of SIC codes that require a storm water permit if there is a point source discharge into a Water of the State.

For further information about Storm Water, contact IDEM’s OWQ - Wetlands & Storm Water Section at:

(800) 451-6027.

Aerial photo of auto recycler salvage yard with outfalls noted.

Sample storm water pollution prevention plan cover page.

For further information, the U.S. EPA has developed a manual to guide facilities in developing their own storm water pollution prevention plans.

To order “Storm water management for industrial activities: developing pollution prevention plans and best management practices manual”, (document number U.S. EPA 832-R-92-006), call the National Technical Information Service at (800) 553-6847.

View of auto recycler yard practicing good housekeeping.

For further information about Storm Water, contact IDEM’s OWQ - Wetlands & Storm Water Section at:

(800) 451-6027.

Pooled storm water.

Properly kept facility records.

For more information on a qualifying rainfall event and how to sample, visit the IDEM Rule 6 Definitions or How To Do Stormwater Sampling: A guide for industrial facilities.

Water sample testing.

Fluid release from salvage vehicle.

IDEM facility inspection.

Auto Salvage Recyclers Workbook