Storm Water Discharge Permits and the Cooperative Compliance Program (CCP) for Auto Recyclers and Scrap and Waste Recyclers

Storm Water: An Environmental Problem

Storm water is one of the largest sources of surface water contamination. When storm water encounters materials such as oils, gas, heavy metals, and solvents at recycling facilities, it can become significantly polluted, leading to surface and ground water contamination. Fuel tanks, batteries, oily scrap, automobile bodies, white goods, antifreeze, waste oils, leaky hydraulic lines, and shredder fluff are just a few of the potential sources of storm water contamination.

Federal Storm Water Requirements

Since 1990, federal regulations require that scrap and waste recyclers and automotive recyclers obtain coverage under an industrial storm water permit to prevent storm water pollution.

Wisconsin Storm Water Requirements

In Wisconsin, the DNR issues storm water permits under Wisconsin's Pollutant Discharge Elimination System (WPDES) permitting program. The storm water WPDES permit requires development and implementation of a Storm Water Pollution Prevention Plan (SWPPP). The permittee develops the SWPPP for their facility and implements Best Management Practices (BMPs) to reduce the potential for storm water contamination. BMPs focusing on pollution prevention are usually the most cost-effective way to prevent storm water contamination.

Storm Water Permit Requirements and the Cooperative Compliance Programs

In the early 1990s, the DNR, Wisconsin Institute of Scrap Recyclers (WISRI), and Concerned Auto Recyclers (CARS), proposed an innovative Cooperative Compliance Program (CCP) as an option in the permit. As a result of their cooperative efforts, the CCP option is now part of the industry-specific storm water general permits for scrap and waste recyclers (Recycling of Scrap and Waste Materials, WPDES Permit No. WI-S058831) and the automotive recyclers (Dismantling of Vehicle for Parts Selling and Salvage, WPDES Permit No. WI-S059145).

Formation of and membership in a CCP is voluntary. The CCP organization and its member's work together to maintain environmental compliance with the storm water permit. Cooperative Compliance Programs help their members maintain compliance by providing professional assistance and training. The CCP also audits its members and submits compliance reports to the DNR.

The Storm Water CCP, First of Its Kind in Wisconsin

The storm water CCP program is a "pilot" program focusing on innovative, cooperative approaches. Advantages of a CCP over the traditional command and control approach include:

What You Need to Do

Step 1. Apply for a Storm Water Permit

To obtain coverage under the storm water permit, you must submit an Industrial Facility Notice of Intent (PDF) (DNR Form 3400-163) to the Department.

Permit coverage is not conferred until the Department sends a letter to the applicant granting permit coverage.

Step 2. Meet the Requirements of the Storm Water Permit

One of two storm water permits will apply to you depending on your industrial classification. How these permits apply to your facility will vary depending on whether or not you elect to participate in a Cooperative Compliance Program. Thus, your next step is deciding whether you want to join a CCP or proceed on your own to meet the requirements of the storm water permit. Check the links below for more information about the storm water permit requirement and CCP.

For Auto Recyclers:

For Scrap and Waster Recyclers:

DNR Contacts for Storm Water Permit and CCP

Questions regarding the storm water permit or the CCP can be directed to the DNR's regional storm water contact for the county in which the facility is located.

For programmatic questions about the Storm Water CCP contact Jim Bertolacini, storm water coordinator, at (608) 264-8971 or Mark Harings, auto and scrap recycling sector specialist, at (715) 831-3263.


Last Revised: Friday January 16 2009