Thoughts From “The Environmental Guy”

What Do You Need To Do To Keep Them Off Your Back?

 Gary Bevell asked that I put some thoughts down on what you should be concerned about and what actions you should be taking while you deal with the USEPA and the North Carolina Department of Health, Environment, and Natural Resources.

 Most everybody knows the EPA has announced they are giving the State some assistance in Compliance and Enforcement for the Storm Water Permit program.  Before we discuss the details, let’s talk about why the EPA is doing this. 

 It has been my experience around the country that when the USEPA decides that a state is not enforcing the regulations they are supposed to enforce, then the USEPA decides to come in and help that state out.  This is often times done with or without the state’s agreement.  We have seen this happen in Florida, Texas, Virginia, Pennsylvania and Kansas. 

What do you need to do to keep them off your back?

 For those that have heard me speak before, you will remember that I suggested there are two things you must do:

Do It In The Yard

Cover It With Paper

 In other words, if you are supposed to put the oil in the bucket then do that.  Don’t just do it sometimes; do it every time.  If you are supposed to pull the batteries out of the cars and store them on a pallet under a roof, then do it.  Don’t just do it sometimes; do it every time.  Don’t let the batteries sit on the ground for a day or two before you pick them up.  Do what you said you were going to do.  Pull the batteries and store them on a pallet under a roof. 

 Cover it with paper.  Document, document, document!  If you don’t already have your Storm Water Discharge Permit from the State of North Carolina you should either apply immediately or have somebody apply immediately for you.  Does the State or the USEPA know whether or not you have a permit?  You bet they do!  They just go to the Yellow Pages or the tax rolls for the State and see who advertises for the sale of used parts or calls themselves a salvage dealer.  Then they compare this list with the list of facilities that have a permit. 

 For those that know me, you know that I truly despise the scare tactics of some folks in the consulting industry.  But I must communicate to you the facts.  In Florida, USEPA inspectors have handed out fines in the $5000 range for not applying for a permit.  The facts say it is not worth it to fiddle around about getting a permit.  That is most of the scare tactic stuff I will write in this article. 

 You must have a Storm Water Pollution Prevention Plan (SWPPP).  This is going to be the document that spells out your Best Management Practices.  When the EPA inspectors come, they will want to see this document.  You can write your own or you can have an environmental consultant write it for you.  Either way you are supposed to have a Plan. 

The EPA inspector will walk through the yard and see if you are doing what you say you are doing in your Plan.  It has been my experience with these inspectors that they see a lot more than we would like for them to see when they are walking around.  How do you make this go smoother?  Do some housekeeping!  If you have some bad staining, clean it up.  If there is oil or batteries or gasoline sitting outside in the yard, clean it up.  Close the hoods on your cars in the yard.  Pick up the tires.  Do not let the tire pile get big.  Do the training of the employees you are supposed to be doing.  If you are washing parts with a steam genie or other water type washer and the water is running to the ground you should stop this practice immediately.  Wash water on the ground requires a very special and expensive permit.  It is not worth the cost.  Go out and just pick up a little! 

 You need to be taking rainwater samples.  It is my opinion that you need some assistance on this.  Picking a laboratory, collecting the samples correctly, interpreting the sample data, preparing the reports for the State, all can be daunting.  Ask somebody for assistance on this.  

 This article is prepared by Mike James with James Environmental Management, Inc.  Mr. James and his team at JEM are the recognized leaders in providing assistance for auto recyclers across the country.  A frequent writer and speaker for the industry as well as a strong advocate for the auto recycling industry, Mr. James works for many recyclers in North Carolina and assisted 4 of the facilities sued by the Nuese River Foundation a few years ago. 

James Environmental Management Inc. 

mike@jamesenvironmental.com

512-244-3631