INDUSTRIAL  STORMWATER
FACT  SHEET SERIES
                                       Sector M: Automobile Salvage Yards
           U.S. EPA Office of Water
           EPA-833-F-06-028
           December 2006
 What is the NPDES stormwater permitting program for industrial
 activity?
 Activities, such as material handling and storage, equipment maintenance and cleaning, industrial
 processing or other operations that occur at industrial facilities are often exposed to stormwater. The
 runoff from these areas may discharge pollutants directly into nearby waterbodies or indirectly via
 storm sewer systems, thereby degrading water quality.

 In 1990, the U.S. Environmental Protection Agency (EPA) developed permitting regulations under the
 National Pollutant Discharge Elimination System (NPDES) to control stormwater discharges associated
 with eleven categories of industrial activity. As a result, NPDES permitting authorities, which may be
 either EPA or a state environmental agency, issue stormwater permits to control runoff from these
 industrial facilities.


 What types of industrial facilities are required to obtain permit
 coverage?
 This fact sheet specifically discusses stormwater discharges from automobile salvage yards as
 defined by Standard Industrial Classification (SIC) and includes battery reclaimers, salvage yards, and
 automobile recyclers (Primary SIC 5015). Facilities and products in this group fall under the following
 categories, all of which require coverage under an industrial stormwater permit:
    4 Activities related to dismantling of used motor vehicles for the purpose of selling parts
    4 Wholesale or retail distribution of used motor vehicle parts

 What does an industrial stormwater permit require?
 Common requirements for coverage under an industrial stormwater permit include development of a
 written stormwater pollution prevention plan (SWPPP), implementation of control measures, and sub-
 mittal of a request for permit coverage, usually referred to as the Notice of Intent or NOI. The SWPPP
 is a written assessment of potential sources of pollutants in stormwater runoff and control measures
 that will be implemented at your facility to minimize the discharge of these pollutants in runoff from
 the site. These control measures include site-specific best management practices (BMPs), maintenance
 plans, inspections, employee training, and reporting. The procedures detailed in the SWPPP must be
 implemented by the facility  and updated as necessary, with a copy of the SWPPP kept on-site. The in-
 dustrial stormwater permit also requires collection of visual, analytical, and/or compliance monitoring
 data to determine the effectiveness of implemented BMPs. For more information on EPA's industrial
 stormwater permit and links to State stormwater permits, go to www.epa.gov/npdes/stormwater
 and click on "Industrial Activity."

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector M: Automobile Salvage Yards
  What pollutants are associated with my facility's activities?
  Pollutants conveyed in stormwater discharges from automobile salvage yards will vary. There are a
  number of factors that influence to what extent industrial activities and significant materials can
  affect water quality.
     4 Geographic location
     4 Topography
     4 Hydrogeology
     4 Extent of impervious surfaces (i.e., concrete or asphalt)
     4 Type of ground cover (e.g., vegetation, crushed stone, or dirt)
     4 Outdoor activities (e.g., material storage, loading/unloading, vehicle maintenance)
     4 Size of the operation
     4 Type, duration, and intensity of precipitation events
  The activities, pollutant sources, and pollutants detailed in Table 1 are commonly found at automobile
  salvage yards.
  Table 1. Common Activities, Pollutant Sources, and Associated Pollutants at Automobile Salvage
  Yards
Activity
Vehicle Dismantling
Used Parts Storage
Outdoor Vehicle and
Equipment Storage
Vehicle and Equipment
Maintenance
Vehicle, Equipment,
and Parts Washing
Areas
Liquid Storage in
Above Ground Storage
Tanks
Illicit Connection to
Storm Sewer
Pollutant Source
Oil, anti-freeze, batteries, gasoline, diesel fuel,
hydraulic fluids, electrical switches
Batteries, chrome bumpers, wheel balance
weights, tires, rims, filters, radiators, catalytic
converters, engine blocks, hub caps, doors,
drivelines, galvanized metals, mufflers
Leaking engines, chipping/corroding bumpers,
chipping paint, galvanized metal
Parts cleaning
Waste disposal of greasy rags, oil filters, air
filters, batteries, hydraulic fluids, transmission
fluids, radiator fluids, degreasers
Spills of oil, degreasers, hydraulic fluids,
transmission fluid, and radiator fluids
Fluids replacement, including oil, hydraulic
fluids, transmission fluid, and radiator fluids
Washing and steam cleaning waters
External corrosion and structural failure
Installation problems
Spills and overfills due to operator error
Sanitary water
Floor drains
Vehicle washwaters
Radiator flushing wastewater
Leaking underground storage tanks
Pollutant
Oil and grease, ethylene glycol, heavy metals,
mercury
Sulfuric acid, galvanized metals, oil and grease,
heavy metals, petroleum hydrocarbons, total
suspended solids (TSS)
Oil and grease, arsenic, organics, heavy metals,
total suspended solids (TSS)
Chlorinated solvents, oil and grease, heavy
metals, acid/alkaline wastes
Oil, heavy metals, chlorinated solvents, acid/
alkaline wastes oil, heavy metals, chlorinated
solvents, acid/alkaline wastes, ethylene glycol
Oil, arsenic, heavy metals, organics, chlorinated
solvents, ethylene glycol
Oil, arsenic, heavy metals, organics, chlorinated
solvents, ethylene glycol
Oil and grease, detergents, heavy metals,
chlorinated solvents, phosphorus, salts,
suspended solids
Fuel, oil and grease, heavy metals, materials
being stored
Bacteria, biochemical oxygen demand (BOD),
suspended solids
Oil and grease, heavy metals, chlorinated
solvents, fuel, ethylene glycol
Oil and grease, detergents, metals, chlorinated
solvents, phosphorus, suspended solids
Ethylene glycol
Materials stored or previously stored
  EPA 833-F-06-028

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector M: Automobile Salvage Yards
  What BMPs can be used to minimize contact between stormwater
  and potential pollutants at my facility?
  A variety of BMP options may be applicable to eliminate or minimize the presence of pollutants
  in stormwater discharges from automobile salvage yards. You will likely need to implement a
  combination or suite of BMPs to address stormwater runoff at your facility. Your first consideration
  should be for pollution prevention BMPs, which are designed to prevent or minimize pollutants
  from entering stormwater runoff and/or reduce the volume of stormwater requiring management.
  Prevention BMPs can include regular cleanup, collection and containment of debris in storage areas,
  and other housekeeping practices, spill control, and employee training. It may also be necessary to
  implement treatment BMPs, which are engineered structures,  intended to treat stormwater runoff
  and/or mitigate the effects of increased  stormwater runoff peak rate, volume, and velocity. Treatment
  BMPs are generally more expensive to install and maintain and include oil-water separators, wet
  ponds, and proprietary filter devices.

  The management practices discussed herein are well suited mechanisms to prevent or control the
  contamination of stormwater discharges associated with automobile salvage yards. In general, it is
  important to develop a stormwater management policy statement, review the policy with employees,
  and keep it posted. Additionally, identifying weaknesses in current facility practices will aid the
  permittee in determining appropriate BMPs that will achieve a reduction in pollutant loadings.

  All facilities should implement BMPs in the following areas of the site:
     4 Vehicle dismantling and maintenance areas
     4 Vehicle, parts, and equipment storage areas
     4 Material storage areas
     4 Vehicle, parts, and equipment cleaning areas

  Mercury switch used in vehicle. Be aware: specific permit requirements may vary according to
  permitting authority so it is important to reference the requirements applicable of the state in which
  your facility is located. For instance, many states are now addressing the issue of mercury switch
  removal to prevent mercury releases that occur from automobile recycling. Mercury  switches have
  been used until recently for hood, trunk, or door lights.

  BMPs must be selected and implemented to address the following:

  Good Housekeeping Practices
  Good housekeeping is a practical, cost-effective way to maintain a clean and orderly facility to prevent
  potential pollution sources from coming into contact with stormwater. It includes establishing proto-
  cols to reduce the possibility of mishandling materials or equipment and training employees in good
  housekeeping techniques. Common areas where good housekeeping practices should be followed in-
  clude trash containers and adjacent areas, material storage areas, vehicle and equipment maintenance
  areas, and loading docks. Good housekeeping practices must include a schedule for regular pickup and
  disposal of garbage and waste materials and routine inspections of drums, tanks, and containers for
  leaks and structural conditions. Practices also include containing and covering garbage, waste materi-
  als, and debris. Involving employees in routine monitoring of housekeeping practices has proven to
  be an effective means of ensuring the continued implementation of these measures.

  Minimizing Exposure
  Where feasible, minimizing exposure of potential pollutant sources to precipitation  is an important
  control  option. Minimizing exposure prevents pollutants, including debris, from coming into contact
  with precipitation and can reduce the need for BMPs to treat contaminated stormwater runoff. It can
  also prevent debris from being picked up by stormwater and carried into drains and surface waters.
  Examples of BMPs for exposure minimization include covering materials  or activities with temporary


  EPA 833-F-06-028                                                                           3

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector M: Automobile Salvage Yards
  structures (e.g., tarps) when wet weather is expected or moving materials or activities to existing
  or new permanent structures (e.g., buildings, silos, sheds). Even the simple practice of keeping a
  dumpster lid closed can be a very effective pollution prevention measure.

  Erosion and Sediment Control
  BMPs must be selected and implemented to limit erosion on areas of your site that, due to
  topography, activities, soils, cover, materials, or other factors are likely to experience erosion. Erosion
  control BMPs such as seeding, mulching, and sodding prevent soil from becoming dislodged and
  should  be considered  first. Sediment control BMPs such as silt fences, sediment ponds, and stabilized
  entrances trap sediment after it has eroded. Sediment control BMPs should be used to back-up
  erosion control BMPs.

  Management of Runoff
  Your SWPPP must contain a narrative evaluation of the appropriateness of stormwater  management
  practices that divert, infiltrate, reuse, or otherwise manage stormwater runoff so as to reduce the
  discharge of pollutants. Appropriate measures are highly site-specific, but may include, among others,
  vegetative swales, collection and reuse of stormwater, inlet controls, snow management, infiltration
  devices, and wet  retention measures.

  A combination of preventive and treatment BMPs will yield the most effective stormwater
  management for minimizing the offsite discharge of pollutants via stormwater runoff. Though not
  specifically outlined in this fact sheet, BMPs must also address preventive maintenance records or
  logbooks, regular facility inspections, spill prevention and response, and employee training.

  Specific runoff management practices for automobile salvage facilities include the installation/use of:
     4  Berms or drainage ditches on the property line (to prevent run-on from neighboring properties
     4  Berms for  uncovered outdoor storage of soiled parts, engine blocks, and above-ground liquid
        storage
     4  Detention ponds
     4  Filtering devices and oil/water separators

  All BMPs require  regular maintenance to function as intended. Some management measures have
  simple maintenance requirements, others are quite involved. You must regularly inspect all BMPs to
  ensure they are operating properly, including during runoff events. As soon as a  problem is found,
  action to resolve  it should be initiated immediately.

  Implement BMPs, such as those listed below in Table 2 for the control of pollutants at automobile sal-
  vage yards, to minimize and prevent the discharge of pollutants in  stormwater. Identifying weakness-
  es in current facility practices will aid the permittee in determining appropriate BMPs that will achieve
  a reduction in pollutant loadings. BMPs listed in Table 2 are broadly applicable to automobile salvage
  yards; however, this is not a complete list and you are recommended to consult with regulatory agen-
  cies or a stormwater engineer/consultant to identify appropriate BMPs for your facility.

  Table 2. BMPs for Potential Pollutant Sources at Automobile Salvage Yards
   Activity
BMPs
   Dismantling and vehicle
Minimize exposure
                      Q  Installation of a consolidated processing area, including a covered and bermed impermeable
                         concrete surface equipped with a drain, where all fluids are drained.

                      Fluid and Parts Removal
                      FJ  Drain all fluids from vehicles upon arrival at the site. Segregate the fluids and properly store
                         or dispose of them.

                      FJ  Drain oil filters (and all vehicle parts) before disposal or recycling.
  EPA 833-F-06-028

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INDUSTRIAL STORMWATER  FACT SHEET SERIES
Sector M: Automobile Salvage Yards
  Table 2.  BMPs for Potential Pollutant Sources at Automobile Salvage Yards (continued)
   Activity
BMPs
   Dismantling and
   vehicle maintenance
   (continued)
Fluid and Parts Removal (continued)
FJ  Inspect vehicles for leaks as soon as possible once they arrive on-site. Inspect vehicles
    quarterly for signs of leakage. Check for unwanted material that could have been placed in
    the vehicle.
FJ  When pulling parts from vehicles in the yard, employ a catch sled or tray to recover the
    majority of fluids which will be released. Place drip pans, large plastic sheets, or canvas
    under vehicles or equipment  during maintenance and dismantling activities. Where drip
    pans are used, they should not be left unattended to prevent accidental spills.
FJ  Engine oil should be drained  and stored in clearly labeled tanks or containers. Tanks and
    containers must be kept in good operating condition, free  of any visible spills or leaks,
    structural damage, or deterioration.
FJ  Remove battery as soon as feasible after vehicle enters the facility.
Q  Promptly transfer used fluids  to the proper container.
FJ  Empty and clean drip pans and containers; do not leave full drip pans or other open
    containers around the shop.
FJ  Remove all mercury switches  as soon as possible making sure not to puncture the mercury
    container during removal. Ship switches to End of Life Vehicle Solutions (ELVS).

Vehicle Processing
Q  Maintain an organized inventory of materials used in the maintenance  shop.
FJ  Designate one person to keep track of parts in the yard. As soon as a hulk is salvaged to
    its minimum extent, it should be processed for shredding to minimize the dripping of fluids
    and clutter in the yard.

Material Storage
FJ  Nonhazardous substances that are contaminated with a hazardous substance are
    considered a hazardous substance.
Q  Store cracked batteries  in a nonleaking secondary container.
FJ  Keep waste streams separate (e.g., waste oil and mineral spirits).
Recycling and Disposal
Q  Recycle anti-freeze, gasoline,  used  oil, mineral spirits, windshield washer fluid, and solvents.
FJ  Label and track the recycling  of waste material (e.g.,  used oil, spent solvents, and batteries).
Q  Dispose of greasy rags,  oil filters, air filters, batteries, spent coolant, and degreasers
    properly.

Discharges
FJ  Know where your sumps and drains discharge to. Do not pour liquid waste down floor
    drains, sinks, or outdoor storm drain inlets.
FJ  Plug floor drains that are connected to the storm or sanitary sewer. If necessary, install a
    sump that is pumped regularly.
Q  Screen out sludges and solids before they reach the waste  sump. Use an absorbent pad
    around the perimeter of sumps to prevent unwanted hazardous materials from entering.
Q  Prohibit the practice of  hosing down the shop floor, using dry cleanup  methods, and/or
    collecting the stormwater runoff from the maintenance area and providing treatment.
FJ  Treat stormwater discharges with devices such as oil-water separators.
   Outdoor vehicle,
   equipment, and parts
   storage
Minimizing Exposure

FJ  Cover all storage areas with a permanent cover (e.g., roofs) or temporary cover (e.g., canvas
    tarps).

Q  Store lead parts in a covered container that is capable of handling the excessive weight of
    lead. If storing lead tire weights with batteries, make sure weights are not placed under
    batteries or allowed to roll around as that could puncture batteries.
  EPA 833-F-06-028

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector M: Automobile Salvage Yards
  Table 2.  BMPs for Potential Pollutant Sources at Automobile Salvage Yards (continued)
   Activity
BMPs
   Outdoor vehicle,
   equipment, and parts
   storage (continued)
Runoff Minimization
FJ  Install curbing, berms, or dikes around storage areas.
Q  Install berms or drainage ditches on the property line.
FJ  Install berms for uncovered outdoor storage of oily parts, engine blocks, and above ground
   liquid storage.
FJ  Install filtering devices and oil/water separators.
Q  Use drip pans, large sheets of plastic,  or canvas under all vehicles and equipment waiting
   for and during maintenance.
Q  Store mercury switches in covered, leak-proof containers in a way that prevents the glass
   capsule from  breaking. (Manage mercury switches as hazardous waste. Containers should
   be labeled with "Hazardous Waste - Spent Mercury Switches")
FJ  Use secondary containment for stored liquids such as oil, gas, and antifreeze, as well as for
   lead acid batteries.
Good Housekeeping
FJ  Tank storage should be secured and locked.
Q  Do not stockpile old tires as they are both a fire hazard and a breeding ground for
   mosquitoes and rodents. Use indoor tire racks.
Q  Confine storage of parts, equipment,  and vehicles to designated areas.
FJ  Vehicles of similar make and model should be located in a common area. Vehicles whose
   parts have higher demand should  be in a common  area and easily accessible.
Q  Repair malfunctioning equipment  that is responsible for any leak or spill as soon as possible.
Q  Store batteries on impervious surfaces. Store batteries inside on a pallet or outside in a leak
   proof container. Curb, dike, or berm this area.
   Vehicle, equipment,
   and parts washing
   areas
Q  Designate an area for cleaning activities.
FJ  Perform all parts cleaning operations indoors or cover and berm outside cleaning areas.
Q  Clean parts using minimal amounts of solvents or detergents.
FJ  Recycle and  reuse cleaning fluids where practical.
Q  Use phosphate-free biodegradable detergents.
FJ  Use detergent-based or water-based cleaning systems in place of organic solvent
   degreasers.
FJ  Contain steam cleaning washwaters or discharge under an applicable NPDES permit.
Q  Ensure that washwaters drain well.
FJ  Inspect cleaning area regularly.
Q  Install curbing, berms, or dikes around cleaning areas.
Q  Remove or deploy airbags prior to crushing or other maintenance activities.
FJ  Be certain all fluids have been drained from vehicle prior to crushing.
Q  Fluid should be collected in a covered container, tested, and disposed of accordingly.
   Vehicle crushing
   activities
   Capture crusher fluids to prevent spillage. Collect this mixture of fluids in a spill-proof
   covered container and dispose of it properly. It should not be allowed to drain onto the
   ground. Keep the drain within the crusher clean so that the fluids do not collect and
   overflow from the crusher onto the ground.
  EPA 833-F-06-028

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector M: Automobile Salvage Yards
  Table 2. BMPs for Potential Pollutant Sources at Automobile Salvage Yards (continued)
   Activity
BMPs
   Vehicle crushing
   activities (continued)
FJ  Installation of an engineering fabric, such as geotextiles, followed by gravel, or a bermed
   impermeable concrete surface would be ideal as a foundation under the crusher.

FJ  Develop a preventative maintenance program that involves timely inspections and/or
   maintenance of the crusher and facility equipment and vehicles.

Q  Keep the crusher equipment clean.
   Automotive wastes
   Fuel - Drain fuel tanks, using air or hand pumps, into double-walled storage tanks. "Good"
   fuels can be reused on-site; "bad" fuels must be disposed of.

   Antifreeze -  Reclaim and re-use, if possible.

   Freon (CFCs) - Voluntarily recapture, in anticipation of new regulations.

   Used motor  oil - Drain and store in double-walled tanks. Re-use on-site or send offsite for
   refining/fuel blending. Accepted practice to leave oil in the engine during storage. Oil filters
   should drain for 24-hours. Empty filters return to vehicle for scrap metal reclamation.

   Other fluids  and oils - Drain as completely  as mechanically possible.  Do not burn used oil
   unless approved.

   Asbestos Brake Shoes and Clutches - If handled, should be wetted down to prevent
   asbestos particulates from becoming airborne.

   Mercury switches - Remove promptly and avoid breakage. Store as hazardous waste.

   Do not use vehicle fluids, oil, or fuels for dust or weed control.
   Liquid storage in above
   ground containers
FJ  Maintain good integrity of all storage containers.

FJ  Install safeguards (such as diking, berming, or permanent secondary containment) against
   accidental releases at the storage area.

FJ  Valves on permanent secondary containment should be kept in the "off" position and
   locked at all times, except when collected water is removed.

Q  Inspect storage tanks to detect potential leaks and perform preventive maintenance.

Q  Inspect piping systems (pipes, pumps, flanges, couplings, hoses, and valves) for failures or
   leaks.
   Illicit connection to
   storm sewer
   Plug all floor drains if it is unknown whether the connection is to storm sewer or sanitary
   sewer systems. Alternatively, install a sump that is pumped regularly.

   Perform dye testing to determine if interconnections exist between sanitary water system
   and storm sewer system.

   Update facility schematics to accurately reflect all plumbing connections.

   Install a safeguard against vehicle washwaters and parts cleaning waters entering the storm
   sewer unless permitted.

   Maintain and inspect the  integrity of all underground storage tanks; replace when
   necessary.
  What if activities and materials at my facility are not exposed to
  precipitation ?
  The industrial stormwater program requires permit coverage for a number of specified types of
  industrial activities. However, when a facility is able to prevent the exposure of ALL relevant activities
  and materials to precipitation, it may be eligible to claim no exposure and qualify for a waiver from
  permit coverage.
  EPA 833-F-06-028

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector M: Automobile Salvage Yards
  If you are regulated under the industrial permitting program, you must either obtain permit coverage
  or submit a no exposure certification form, if available. Check with your permitting authority for
  additional information as not every permitting authority program provides no exposure exemptions.

  Where do I get more information?
  For additional information on the industrial stormwater program see
  www.epa.gov/npdes/stormwater/msgp.

  A list of names and telephone numbers for each EPA Region or state NPDES permitting authority can
  be found at www.epa.gov/npdes/stormwatercontacts.

  References
  Information contained in this Fact Sheet was compiled from EPA's past and present Multi-Sector
  General Permits and from the following sources:
     4  Automotive Recyclers Association. 2000. "Stormwater Best Management Practices."
        http://ara.timberlakepublishing.com/content.asp?pl=430&sl=468&contentid=474

     4  City of Phoenix, Street Transportation Department, Storm Water Management Section. 2004.
        Prevent Stormwater Contamination Best Management Practices for Section M - Automotive
        Salvage Yards. SIC Code: 5015.
        http://phoenix.gov/STREETS/ausalya5.pdf

     4  Delaware Department of Natural Resources and Environmental Control, Division of Air and
        Waste  Management: Solid and Hazardous Waste. 2000. Salvage Yard Manual.
        www.dnrec.state.de.us/dnrec2000/divisions/awm/hw/hw/salvage.htm

     4  Florida Department of Environmental Protection and Florida Auto Dismantlers and Recyclers
        Association. 2002. Florida Green Yards, An Environmental Compliance Workbook for
        Automotive Recyclers.
        www.dep.state.fl.us/central/Home/Green_Yards/Compliance_Wkb_SalvageYards.pdf

     4  Environmental Compliance for Automotive Recyclers. 2005.
        www.ecarcenter.org

     4  Michigan Department of Environmental Quality.1999. Guide for Salvage Yard Owners.
        www.deq.state.mi.us/documents/deq-ead-tas-salvyard.pdf

     4  Monroe County Small Business Pollution Prevention Task Group and New York State
        Department of Environmental Conservation. "Auto Recyclers Guide to a Cleaner Environment
        - Best Management Practices."

     4  Northeast Waste Management Officials' Association. "P2Rx Topic Hub: Mercury-Automotive
        Table of Contents."
        www.newmoa.org/prevention/topichub/toc.cf m?hub=104&subsec=7&nav=7

     4  Sustainable Conservation. "Auto Recycling Project Overview."
        www.suscon.org/autorecycling/index.asp

     4  Sustainable Conservation. "Stormwater Management: A Guide for Auto Recycler Owners and
        Operators."
        www.suscon.org/autorecycling/pdfs/autorecycling_factsheet_english.pdf
  EPA 833-F-06-028

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector M: Automobile Salvage Yards
        U.S. EPA - Region 8 Hazardous Waste Management Division, Hazardous Waste Minimization
        Program. 1995. EnviroSense Fact Sheet: Pollution Prevention Opportunities for the Automotive
        Recycling Industry.
        http://es.epa.gov/techinfo/facts/epa/epa-fs.html

        U.S. EPA, Office of Science and Technology. 1999. Preliminary Data Summary of Urban
        Stormwater Best Management Practices. EPA-821-R-99-012
        www.epa.gov/OST/stormwater

        U.S. EPA. The National Vehicle Mercury Switch Recovery Program.
        www.epa.gov/mercury/switch.htm

        U.S. EPA, Office of Wastewater Management. NPDES Stormwater Multi-Sector General Permit
        for Industrial Activities (MSGP).
        www.epa.gov/npdes/stormwater/msgp

        VT Solid Waste Districts and Alliances, VT Department of Environmental Conservation,
        Environmental Assistance Division. Best Management Practices (BMP) for Vermont's Auto
        Salvage Yards.
        www.anr.state.vt.us/DEC/ead/sbcap/salvage/PDF/bmpguide.pdf
  EPA 833-F-06-028

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