Questions and Answers from the Special June 10 th 2004 Philadelphia Automotive Recyclers Environmental Compliance Workshop, Holiday Inn, Philadelphia, Pa.

The City of Philadelphia, Pennsylvania Department of Environmental Protection (PaDEP), United States Environmental Protection Agency (USEPA), Pennsylvania Automotive Recycling Trade Society, (PARTS) and the Southwest Philadelphia Scrap Dealers Association thank the 85 businesses and 10 vendors that participated at the seminar. Some of the important questions and answers that surfaced are as follows:

1. When do I require a dumpster license?

Dumpsters with a capacity in excess of 1 cubic yard are subject to a license. If located on private property, a one-time application/license fee of $50 is required. Dumpsters located in a public way require an annual license of $300 per year, and require Right of Way approval from the City Streets Department. The license application is available on-line at www.phila.gov. Filing of the license must be done either by mail or in person at the Concourse of the Municipal Services Building, 1401 John F. Kennedy Boulevard, Department of Licenses and Inspections.

2. How can I store gas tanks?

Gasoline tanks must be purged and free of vapors. They must be stored in an orderly manner in an area free of weeds and trash.

3. When Do I need a City Hazardous Material Handling License?

Anyone in a commercial business storing more than 10 gallons of a flammable liquid or 25 gallons of a combustible liquid must have a hazardous materials handling license, which is obtained from the City Department of Licenses and Inspections.

4. How high can I store cars?

No auto salvage business can store cars more than 20 feet high.

5. Generally, what are the PaDEP requirements for storing items found at an auto salvage yard?

Generally, batteries, waste fluids, waste tires and trash must ALL be stored in a manner that prevents release to the environment in accordance with applicable rules and regulations (e.g. batteries should be kept upright, off the ground and protected from the elements.) All wastes should be recycled or disposed of properly, with disposal records maintained.

6. Do a need a State Stormwater Management Permit for my auto salvage yard?

Yes, all auto salvage yards should obtain a state stormwater discharge permit from the Pennsylvania Department of Environmental Protection. The application for a Stormwater permit is called a “Notice of Intent,” or NOI. All NOIs should be accompanied by a site plan, showing the site location, including nearby roads and waterways.

7. If I obtain a PaDEP Stormwater Discharge permit, will that make it more likely that I will be be inspected by the state?

No. You are just as likely to be inspected if you do have a permit, or if you don’t. If you do get inspected, it will be much better for you if you do get the permit, since a salvage yard that fails to get the permit is in violation of State and Federal laws.

8. What is a “PPC Plan?"

A Pollution Prevention and Containment Plan (PPC) is a short description of the business operation, and what the business does to prevent pollution from occurring, and the steps it will take to contain pollution when it does occur. A salvage yard’s PPC Plan does not have to be submitted to PaDEP, unless PaDEP makes a specific request to review it. The PPC Plan may be the single most important thing a business can do to be in compliance with their Stormwater discharge permit.

9. Do I need to be concerned about sewage disposal?

All auto salvage operators must have some type of system for sewage disposal that is in accordance with the State sewage regulations and permitted by the City on behalf of the State. This can either be a connection to the municipal sewer line if that is available, a holding tank which is designed in accordance with State regulations if the lot has access to running water under pressure, or portable toilet(s) if the lot does not have access to running water under pressure. Regardless of the type of onlot sewage system, each lot must hold a State sewage permit issued by the City, through the City Department of Public Health, Environmental health Services, Environmental Engineering Section.

10. What about Fire Protection?

Obviously, you should call 911 whenever there is a fire involved. Also, the City has adopted that portion of the International Fire Code which will require you to keep fire lanes open of not less that 20 feet wide to enable City fire apparatus to get to any possible incident scene.