Through a collaborative stakeholder process, Coastkeeper has developed a draft storm water permit for scrap metal facilities in our region. Our main goal is to give scrapyard operators clear guidelines on how to treat or eliminate the discharge of polluted runoff from the site.
On February 9, 2012, the Santa Ana Regional Water Quality Control Board approved Orange County Coastkeeper’s permit to reduce polluted runoff from scrapyards. The permit requires all facilities engaged in scrap metal recycling within the region to implement phases of BMPs to reduce and eliminate runoff pollution. Coastkeeper is proud that the process of working with industry leaders to implement new standards will benefit each group involved, and we can continue with our mission to protect our region’s water quality.
Investigation: Identifying the problem
As part of our ongoing investigation program that in the past has targeted the construction industry and wholesale nurseries, Coastkeeper has most recently focused on metal recyclers. Several years ago, we started collecting runoff samples from scrapyard facilities across throughout the region, and found high metal concentrations in water discharging from these facilities. Since then, we’ve launched a program to reduce and when possible eliminate polluted runoff from scrap metal recyclers in our region, and ultimately statewide.
Litigation: Enforcing the Clean Water Act
One of Coastkeeper’s five program pillars is enforcement. We occasionally use litigation as a tool to encourage specific industries that have not complied with clean water laws to come into compliance. In the past few years, Coastkeeper has litigated numerous scrap yards, metal salvage yards, and related metal facilities. Our main goal is for the scrapyard operators to treat or eliminate the discharge of polluted runoff from the site.
Although our litigation efforts have been successful on a case-by-case basis, they have not led to a shift across the entire industry. Regulation and enforcement of water quality standards for scrap metal facilities have been inconsistent. That’s why Coastkeeper decided that the best step forward was to work with the scrap metal industry to develop a permit that will be rigorous, improve water quality, and dramatically reduce polluted discharges from scrapyards.
The Stakeholder Process: A clear path to compliance
In April 2010, Coastkeeper brought together a stakeholder group of industry members, the Regional Water Board staff, and engineers to develop standards that scrapyards can achieve while at the same time making significant water quality improvements. With an agreed upon suite of basic Best Management Practices (BMPs), advanced treatment systems, and numeric discharge limits at the end of the pipe, we have the opportunity to make significant progress in improving water quality from metal recycling facilities and related businesses.
This new regional permit will also benefit the scrapyards by 1) giving a clear path to compliance, and 2) leveling the playing field by making sure each yard is doing their duty to protect water quality. In November 2010, the stakeholder group reached a consensus on the basic content and framework for a draft permit. This agreement was then handed over to the Regional Board staff to be written into permit language. Stay tuned for a public workshop on the draft permit in early 2011.
What will the new permit do?
The permit is based on a combination of BMPs that will result in mass loading reductions of pollutants and the installation of advanced treatment. The permit will require all scrap metal facilities to develop a plan to install a variety of Best Management Practices (BMPs) at their facility in phases:
- Phase I: Early Action BMPs such as a robust sweeping and cleaning program, employee education and training, paving all unpaved industrial areas, etc.
- Phase II: These are more substantial BMPs such as isolating industrial areas from contact with rainfall and runoff, removal of contaminated building materials, diversion of runoff from non-industrial areas, developing various action plans, etc.
- Phase III: Design and install an advanced treatment system to treat remaining runoff. In order to develop a performance standard for the treatment systems, Coastkeeper will collect samples from facilities that already have systems in place to establish the industry baseline.
If scrapyards do not elect to comply with this new permit process, they will have to meet California Toxic Rule standards.