Michelle emailed me a few days ago (February 28th) to remind me that I had an article due to her on March 1st. At that point I commenced panicking because not only had I not started writing, I did not have a topic in mind. So, I called Theresa Bordenkecher at IDEM hoping that she had some inspiration for an article topic. We chatted for awhile and I asked her what fault she sees the most at salvage yards. She responded “Paperwork”. There’s my inspiration.
From our experience working with auto recyclers, paperwork is often the aspect of business that is in need of the most tweaking when we are hired by a new client. There are a few exceptions but all-in-all the recordkeeping systems are not complete, organized or user-friendly. We have developed a system that seems to work well to help our folks keep track of the necessary information in a simple, user-friendly manner. For the sake of discussion we are going to start with storm water.
Storm water permits run on a five-year cycle. There are various requirements throughout the permit cycle (Table 1). All are requirements. Only some are actually submitted to IDEM. Items in gray are documents that are submitted to IDEM – the NOI and SWPPP Checklist in year one only, and the Discharge Monitoring Report and Annual Report in years one through five. Items not in gray are equally important because they contain information needed to fill out the State Forms (gray lines) and are items an IDEM inspector can look for during a site visit. From our experience, the items in gray get done and the others often fall by the wayside.
Mercury switch recovery is similar (Table 2). There are two forms that are submitted to IDEM – the Vendor Information Form and the Claim for Payment Form. The Vendor Information form is used by the Auditor of the State of Indiana to direct deposit funds to your account for each mercury switch you turn in for recycling. The Claim for Payment Form is just that, a form requesting payment for the switches you recovered. The Vendor Information Form is sent in once (assuming your pertinent information does not change) and the Claim for Payment Form gets sent in with each bucket (at least annually). In addition to the two forms that are submittal requirements you are expected to maintain records of Annual Mercury Safety Training. An example Annual Mercury Safety Training Roster is located in the Appendices section of IDEM’s Auto Salvage Recyclers Environmental Self-Audit Workbook and Checklist (Orange Book). You are required to accurately complete the ‘Universal Waste’ label and affix it to the exterior of the bucket. This allows you to track the date you received the bucket and determines your one year point. Universal Waste regulations state that mercury should not be stored on site for greater than one year. You are required to maintain on site records of the total number of vehicles processed during the year, the total number of vehicles that contained mercury switches and the total number of switches collected. An IDEM inspector may request to see this information on a site visit but you are not required to mail it in.
Removal of refrigerants from end-of-life vehicles and proper documentation is also a requirement (Table 3). The only form that you are expected to send in is the USEPA’s Refrigerant Recovery Device Certification Form. This form describes and certifies the equipment you utilize for Freon recovery (lists of approved devices are available on the EPA’s website). On site documentation requirements include tracking vehicles that refrigerant is removed from as well as tracking vehicles that arrive on site without refrigerant. This includes tracking who removed, or verified removal of Freon, the date, make, model and year of the vehicle from which it was removed. An example of both forms is contained in the Orange Book. Records of employee training should be maintained on site and records of the recycler that takes your Freon should also be maintained.
For the remaining waste products generated on site it is important to maintain internal records of the disposition of each waste stream (Table 4). If you sell windshield wiper fluid to customers, maintain receipts. If you burn waste oil, find a way to track this activity. If a recycler buys your used fluids ensure that you get a manifest and maintain a copy with your environmental records. Recycling tires and batteries should both be tracked as well. Documentation is your friend!
The tables shown above are not intended to be an exhaustive list of all documentation a particular auto recycler should maintain. The intent of the tables is to demonstrate that there are two types of documentation requirements that are part of your environmental compliance program. The first set is the forms that actually get submitted to IDEM (gray line items). The second set is those that you maintain on site and make available to IDEM upon request or during an inspection. If you study each of the tables you will notice that there are more white lines than gray lines. There are more requirements for internal tracking than there are requirements that are submitted to IDEM. None of the requirements is particularly difficult. The difficulty is keeping up with the large number of requirements and developing a system that makes the compliance program run effectively.
A complete, organized and user-friendly recordkeeping system can look many different ways. Different systems work for different people. The system we use involves a three inch binder for each yard that we call the “Supporting Documentation” binder. Inside the binder are all of the sections listed above and space to store all of the pertinent documents. It works well that if you sell a drum of used oil, you turn to the used oil tab of your binder and store a copy of the receipt in that section. We keep redundant copies of the binders at our office so if something is lost or damaged we can recreate our clients’ system. We perform quarterly update checks to ensure that recordkeeping is up-to-date. Getting all of the required forms to IDEM is a good start. We encourage you to keep records of all activities so that in the event you are asked you can produce documentation to support your processes.
This article was originally featured in the April/May 2012 issue of ARI Magazine.