State University System of Florida

Florida Center for Solid and Hazardous Waste Management

PROJECT SUMMARY

OBJECTIVES

The objectives of the proposed project are to: (1) provide quantifiable estimates of the impacts of automobile recycling and salvage yards on Florida’s air, soil and groundwater, (2) investigate and determine how other states regulate these facilities; (3) obtain and review existing soil and groundwater contamination data gathered at actual contaminated junkyards; (4) develop and collect soil and groundwater contamination data at selected sites; (5) use data identified in the previous objectives to make estimates of the impacts of automobile and salvage yards on Florida’s air, soils and groundwater; (6) investigate and determine how other states regulate these facilities.

RATIONALE

The proposed project’s overall goal is to determine if the vast majority of automobile salvage yards cause contamination, the typical contaminants of concern found, and the media affected (surface soil, subsurface soil, surface water, sediment, and groundwater). It is also the outcome of this research to prepare a Best Management Practices Manual to be used by the regulatory agencies to provide direction in regulating these facilities. It is also anticipated that salvage yard owners and operators will use this Manual to reduce their potential environmental liability and provide pollution prevention techniques that could provide a major cost savings in the future.

ACCOMPLISHMENTS

It is the intent of the principal investigator to meet regularly with the regulatory agencies, other academic institutions and salvage yard owners to update the progress of the proposed project. The researchers will develop a Technical Advisory Group and have at least three meetings to discuss the technical aspects of the proposed project. A meeting summary will be prepared and distributed to all interested parties. A logical deliverable of the proposed project will be the submission and publication of the results in a peer-reviewed technical journal.

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Title: ENVIRONMENTAL IMPACTS OF AUTO SALVAGE FACILITIES

AND THEIR REGULATION

Automobile salvage facilities in the United States have formed an integral part of the landscape, covering large land areas having wide distribution throughout both rural and urban environments. Many of these facilities are sited directly on the land’s surface without any protective paving underneath. Using the more common term, junk yards, in fact, are a part of the American culture and the basis for numerous songs and stories.

As potential sources of environmental concern, especially related to surface soil, subsurface soil, surface water, sediment and groundwater contamination, they have in the past and will continue to be in the future, a major target of regulatory control and involvement. For many years these types of facilities have stored and stockpiled items of great recycling value such as junked automobiles and other scrap metal-generating equipment. To date, these facilities have had few regulatory controls placed upon them. As a result of this, potential contamination can arise from the wide range of materials that comprise junked automobiles; specifically, petroleum products such as gasoline, diesel fuel, motor oil, transmission fluid, power steering fluid, and brake fluid; engine coolants and additives; chlorofluorocarbons (CFCs) from air conditioning systems; metals such as iron, chromium, lead, copper, and aluminum; battery acid; brake and clutch linings; rubber; inflation cartridges from air bags; mercury switches; plastics, fabrics and other materials. Potential sources of environmental contamination from automobile salvage facilities usually do not consist exclusively of scrapped automobiles. Often a variety of waste products such as scrap metal, fluids from heavy electrical equipment (motors, transformers, and capacitors) that could contain polychlorinated biphenyls (PCBs), appliances, heating and air conditioning systems, hot water tanks, and other heavy waste materials can be found in salvage yards.

The effect of stormwater runoff from these units leading to infiltration into site surface soils, subsurface soils and ultimately to groundwater is the primary environmental concern from these facilities. As a result of the improper handling, spilling or emitting these materials into the environment; oil, coolant, CFCs and other hazardous materials can potentially be released into the air, groundwater, surface water, sediments and site soils.

The regulatory effort aimed at these types of potential contamination needs to be concentrated and practiced throughout the State of Florida. This requires the involvement of the Florida Department of Environmental Protection (FDEP), the Water Management Districts, and the local and municipal environmental regulatory and planning boards. Since only certain agencies provide environmental regulation of these facilities (e.g.,Broward County Department of Natural Resources), the need for consistently regulating these facilities state-wide is urgent.

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One of the major difficulties in the regulation of automobile salvage yards is the fact that these facilities operate in widely different manners. There have been differences in the type of scrap materials accepted, recycling options employed, level and type of efforts used to minimize the threat of potential spills to the environment, and general disposal practices used. This in turn, shows the need to categorize and group these facilities and provide a means for the regulatory agencies to make an informed decision using engineering judgment when deciding sampling strategies, improvement of operating practices and the magnitude of the environmental liability associated with these facilities.

An outgrowth of this research we will provide these facilities with regulatory compliance and pollution prevention strategies to ensure that their facilities minimize the threat of fines from the agencies. Additionally, these facilities will be informed of the potential cost savings by minimizing treatment and disposal costs of their wastes. There is also the concern that these facilities could, only in extreme cases, become listed on the Comprehensive Environmental Response, Compensation and Liability Act’s (CERCLA) National Priorities List of "Superfund" sites. It will be a benefit of this research to identify sites that have the greatest possibility of being listed as Superfund sites, so they can begin the process of selecting an environmental consultant to help them begin full-scale assessment of their site. We will also target facilities due to their practices and operation, that may be discharging hazardous constituents into the environment, and create an awareness of the options available to them to minimize the threat of regulatory enforcement actions. We will make every attempt to meet with the regulatory agencies, the salvage yard owners and interested parties; recommend a future course of action, and suggest ways of improving operations.

The project’s overall goal is to determine if the vast majority of automobile salvage yards cause contamination, the typical contaminants of concern found, and the media affected (surface soil, subsurface soil, surface water, sediment, and groundwater). The objectives of the proposed project are to : (1) obtain and review existing soil and groundwater contamination data; (2) develop and collect soil and groundwater contamination data at selected sites; (3) use data identified in the preceding objectives to make estimates of the impacts of automobile and salvage yards on Florida’s air, soils and groundwater; (4) investigate and determine how other states regulate these facilities. The paragraphs below will convey the rationale used in accomplishing each objective.

There is a fair amount of data available throughout the state on soil and groundwater contamination from automobile oils, anti-freeze, etc. that needs to be reviewed as part of estimating environmental impacts. Unfortunately, this data is found under different filing schemes at different agencies. For example, some data on one type of contamination may be collected in some jurisdictions under the heading of auto recycling facilities, while others may

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have it under oil leaks, and others as leaking underground tanks. We need to carefully review the

existing literature and available data and attempt to make consistent estimates of the extent nature

and magnitude of environmental impacts from auto recycling facilities.

In addition to existing data sets, we will sample auto recycling facilities at two distinctly different locations in north Florida in order to make a direct measurement and estimate of contamination from these sample facilities. The samples to be collected and analyzed will be done under A/QC plan which will be completed in the first two months of the project.

There are many factors that contribute to the sensitivity of Florida’s environment. They include: (1) the fact that the majority of potable water used in Florida is from groundwater sources, (2) the upper zone of the shallow aquifer is mainly under water table conditions, (3) the depth to groundwater from below land surface is small, and (4) the nature of the sandy soil that characterize most of the subsurface of Florida. These unique properties taken in combination contribute to the highly sensitive nature of the environment and present an ease for chemicals to

move quickly and potentially cause large groundwater contamination. Most automobile salvage and recycling facilities do not have precise accounts of the amounts of fluids drained from salvaged automobiles, chemicals found in these fluids or documentation regarding their disposal. This objective is concerned with determining the characteristics of these materials, their chemical partitioning into separate, distinct phases, the specific fraction that would likely remain in the air, non-aqueous and adsorbed phase, and the fate and transport of these contaminants when released into the environment. To accomplish this objective, we will use existing and original data (see objectives 1 and 2 above) to prepare a plan for making estimates of environmental impacts. As a comparison, we will use knowledge gained from the literature review vis a vis the impacts estimated from existing and original data.

Other states have developed regulatory strategies regarding automobile salvage and recycling yards. This objective will determine: (a) how the salvage industry in these states provide compliance with the local, state and federal regulations; (b) if they implement waste minimization and pollution prevention programs; and (c) the relationship between the facilities, the regulatory agencies and the community.

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Several distinct tasks are required to achieve the objectives identified. The following paragraphs identify the scientific procedures employed and a plan of work that will be used in producing data on which to base conclusions and recommendations.

Perform a literature review on the subject of salvage yards, especially with respect to the environmental effects and liabilities associated with their operation. Also included will be a review of legislation in other states relating to salvage yard operations. In addition to searching the legal literature through Lexus/Nexus at the Florida State University libraries, we will prepare a survey of all states to verify that we have current information on salvage yard regulations in each state.

This review will include all enforcement actions by local, state and/or federal agencies brought against automobile salvage and recycling facilities. Evidence of negative publicity by citizen action groups or environmental justice groups on salvage yard owners will also be researched to provide the current regulatory and perceived atmosphere of these facilities by the

general public.

In addition to the activities described above, it is anticipated that the Principal Investigator and the graduate assistant will physically go to the South District and the Tallahassee Office of the Florida Department of Environmental Protection, meet with FDEP staff, and perform a comprehensive records search. It is hoped that FDEP field people will become advocates for, and lend their extensive knowledge and experience to, the proposed project. Based on this search we will document groundwater contamination at automobile salvage and recycling facilities especially in Broward and Dade County and the Water Management Districts. During telephone conversations between the researchers and the Broward County Department of Natural Resources, it came to our attention that Broward County is involved in many salvage yard assessments and remediation. Since they have a database of such cases, we will begin with a visit to their office and research the project files.

A search of specific operations common to the majority of facilities will be undertaken to accurately categorize the types of fluids generated and provide an order of magnitude analysis of the volume of hazardous constituents generated and potentially disposed of each year. The chemical literature will also be searched to provide accurate estimates of the composition of the various chemicals used in the industry and to provide their characteristics once discharged into the surface soils, subsurface soils, surface water, sediment and groundwater. This will enable the reviewers to ascertain the most common pathways of environmental contaminants and their ultimate deposition (i.e., do the chemicals float on the water table or sink to the lowest confining layer).

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The objective of this task is to estimate the effects of automobile salvage and recycling yards on the environment in Florida. This will require identification of all salvage yards by type, size and location. Through this identification we will determine which facilities are for automobile salvage only, which have automobiles and other waste materials, and which have salvage

operations excluding the recycling and handling of used automobiles. We will seek the assistance of salvage trade organizations (i.e., Automotive Recyclers Association); and regulatory bodies (i.e., state agencies and water management districts) that have jurisdiction over the regulation of salvage operations.

Following this determination, we will estimate the probable environmental effects of these yards by using environmental emission factors applied to the scale and type of yard being estimated. We will verify estimates of the waste generation factors by detailed on-site investigation of at least two salvage yards in north Florida to determine the contaminants of concern and fate and transport of these chemicals in the environment and determine their effect on human health and the environment.

This task will consist of two options; Option 1 will consist of performing a United States Geological Survey water well search encompassing a 2-mile radius of the facilities being investigated. This search will determine if any potable water wells (or environmental wells if applicable) exist near the property. These data will determine background water quality, and any impacts of the salvage yards on the groundwater at the site.

In addition to the USGS water well search, we will perform a limited sampling event to determine the impact of environmental contamination from the site, if any. Although site conditions will dictate the extent of the sampling, we envision the collection of a surface soil and subsurface soil sample located in an area of visual staining or if not present from an anticipated "hot spot". This is a location that is likely to act as an entry point for chemicals into the subsurface.

This sampling will be undertaken by manual hand-augering methods to collect the samples. A portion of the samples will be placed into a glass jar, allowed to equilibrate, kept at a temperature of 25°C, and the headspace sampled using a Flame Ionization Detector (FID). This device is used as an Organic Vapor Analyzer (OVA). Although purely used as a screening tool, the FID will provide a measure of gross hydrocarbon contamination. Composite samples will be taken every 2 feet below land surface, and the interval registering the highest OVA reading on the FID, or if the samples do not register on the OVA, the sample just above the water table will be taken and submitted to an approved environmental laboratory for analysis.

The analysis depends on the expected contaminants of concern, but it is estimated that the sample collected will be analyzed for benzene, toluene, ethylbenzene, and total xylenes (BTEX), oil and grease, Volatile Organic Compounds (VOCs) and metals. Before and after each sampling

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event, all downhole equipment will be deconned with Alconox, alcohol and water. In addition to the surface and subsurface soil sample, a stormwater runoff sample will attempt to be collected to determine how much potential contamination is likely to leave the site and possibly contaminate adjacent property. This water sample will be taken similarly to a grab surface water sample, and be analyzed for the usual water quality parameters and the same constituents outlined for the soil.

Option 2 will consist of all the activities in Option 1, and will include the investigation of possible groundwater contamination from the investigated sites. Since this will be a temporary sampling event, and the depth to groundwater is not anticipated to be greater than 10 feet, we believe that a Geoprobe® or Hydropunch® will suffice to install and sample a temporary groundwater well. The advantage of these devices is that all subsurface soil samples can be collected while the well is being installed. Thus hand-augering to obtain soil samples will not be required. The groundwater sample taken from the temporary monitoring well will also be dependent on the contaminants of concern, but will likely be the same as the soil sampling indicated in Option 1.

All sampling and analysis will follow the A/QC plan prepared early in the project.

Task # 3

The third task will be to prepare a final research report which synthesizes the information obtained in the study and gives recommendations regarding potential environmental contam-ination from auto recycling facilities. Among the items that might be covered in a list of findings and recommendations are:

• Stormwater management considerations
• An incoming vehicle inspection inventory program
• Proper removal and handling of automobile fluids associated with salvage
• Inventory control, including rubber, plastics and metal
• Yard maintenance
• Waste stream separation
• Leak Prevention
• Reclaimed materials
• Spill Prevention Control and Countermeasures (SPCC) plans
• Erosion and sediment control measurement

This information would provide findings that could be useful to regulatory agencies as well as to owners and operators of salvage yards regarding proper handling and maintenance operations and potential liability concerns associated with their work.

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Milestones

The milestone chart shown below outlines the time frame within which each of the major tasks will be performed and objectives achieved.

The deliverables provided are solutions to the problem of identifying environmental impacts of automobile salvage facilities and their regulation. The set of deliverables that will be provided by the results of this project are presented in the paragraphs below.

As specified in the Florida Center for Solid and Hazardous Waste Management’s Style Guide, this deliverable will consist of monthly progress reports. These reports will specify the objectives met and reference the time line submitted with this proposal. The report will quantify all stages of the project that have been completed, and specify what we are planning to investigate during the next month.

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As stated elsewhere in this proposal, a Technical Advisory Group (TAG) will be formed to increase our exposure to unfamiliar parts of the problem in locales around the state. Thus, this deliverable will be the preparation of a summary of each of our TAG meetings. It is anticipated that this will comprise three such reports.

A draft technical report will be prepared and submitted to the Center approximately 2 months prior to the completion of the final report. This draft report will:

• Provide an estimate of the current environmental effects of automobile salvage and recycling yards,
• Summarize the regulatory actions of other states regarding salvage facilities in their states and any enforcement penalties levied,
• Synthesize these actions, identifying costs of implementing these actions; and,
• Recommend those that may be the most suitable for adoption in Florida.

The final deliverable will consist of a final technical report.

It is expected by the Principal Investigator that the result of the project will be an affirmative answer to the question of whether automobile salvage and recycling facilities contribute to and/or cause environmental contamination. It is anticipated that the reviewers will be able to ascertain the contaminants of concern that are the major threat to soil, surface water, sediment and groundwater at these facilities. Based on the literature search and the analytical results obtained, we will be able to accurately predict, based on the type of facility, which contaminants would most likely be present, and prepare a simple sampling and analysis protocol so the salvage yard owners and operators can economically assess their sites.

It is also hoped that if contamination is suspected and confirmed on these sites, our final report will outline some simple disposal options and describe the regulatory framework in which a contaminated site operates. We also expect to provide Best Management Practices for these facilities that are effective, economically feasible, practical and easy to implement. We will recommend to the owners and operators of automobile salvage and recycling facilities, ways to minimize environmental liability by describing vehicle dismantling fluid management techniques, parts cleaning operations, vehicle crushing activities and preventive maintenance of the sites. A generic Spill Prevention Control and Countermeasures (SPCC) Plan will be developed to identify procedures to collect, dispose of, clean up, or recycle spilled or leaked fluids.

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Two groups of end users are envisioned for this project, (1) state, municipal and local governments, and (2) private salvage yard owners and operators. The government user benefits would be to those who are involved in the preparation of legislation to address the effects of salvage yards on the environment and to those who prepare regulations and standards relating to the salvage industry. The final technical report would help to identify what other states have done and to indicate if new legislation and regulatory action is needed in Florida.

Private sector benefits are intended for salvage yard owners and operators in Florida through the study which would help to identify potential environmental effects of their operations, and would provide recommendations and guidelines for improved operations of those yards in order to minimize adverse environmental impacts. The findings of this study might be used by others to prepare a Best Management Practices (BMP) Manual which would be used by the industry even in the absence of new legislation or regulations.

One of the most important outcomes of Center-sponsored research, is the dissemination of interim results and findings. Since the Florida State University is located in the capital of the State of Florida, and the College of Engineering is a joint venture with the Florida Agricultural and Mechanical University, communication and the transfer of information between the College and other major universities will be via e-mail. In addition, the coordination of at least three conference calls between the principal investigators, the Technical Advisory Group, the state regulatory agencies, and any interested salvage yard owners or operators will be conducted to update interested parties on the nature of our results.

Related work has been conducted by the researchers on stormwater runoff, water quality analysis, environmental impacts of petroleum and solvent contaminated sites.

Possible outgrowths of this research include the targeting of the most contaminated sites based on our field visits and literature search, and performing additional sampling to characterize the full extent of the environmental contamination. This would give the reviewers a more complete picture of the threat of contamination from salvage yards.

The proposed budget anticipates a major amount of work to be done in summer 1998, especially by Tim Kelly, research assistant. The majority of the budget is for personnel costs that are necessary for obtaining and analyzing information. Field work to be done in north Florida.

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Travel budget is essentially for attending meetings with the Center, and for site visits to public agencies and to selected automobile salvage yards. In particular, we plan to visit Broward and Dade Counties and several selected counties that appear to have significant information on auto salvage yards. Additional funding that is needed for preparation of a A/QC plan and for detailed site sampling and analysis will come directly through a separate contract with the Florida Department of Environmental Regulation.

Principal Investigator Co-Principal Investigator

Andrew Dzurik, Ph.D., P.E. Danuta Leszczynska, Ph.D.

Florida State University Florida State University

FAMU/FSU College of Engineering FAMU/FSU College of Engineering

2525 Pottsdamer Road 2525 Pottsdamer Road

Tallahassee, Florida 32310-6046 Tallahassee, Florida 32310-6046

e-mail: dzurik@eng.fsu.edu e-mail: danuta@eng.fsu.edu

FUNDED RESEARCH

TITLE: Design and Monitoring of a Delaware Sand Filter for Stormwater Runoff

FUNDING AGENCY: Florida Department of Environmental Protection

TOTAL FUNDING: $70,000

DURATION: 12/97 - 12/99

INVESTIGATOR COMMITMENT TO PROJECT

Name %Time

PROPOSALS PENDING

TITLE (This proposal)

FUNDING AGENCY

TOTAL FUNDING

DURATION

INVESTIGATOR COMMITMENT TO PROJECT

Name % Time

Summary of all past funding received:

Dr. Dzurik has received substantial research funding through FSU since 1969. Included are research grants from the U.S. Army Corps of Engineers, USDOT, Florida Sea Grant, Florida DEP, and Florida Dept. Of Community Affairs. Dr. Leszczynska has had considerable research funding through her faculty position at Wroclaw Technical University (Poland). Over the past ten years in the U.S., she has done research funded to UF Department of Environmental Engineering Sciences, and has received funding from the U.S. Army Corps of Engineers - Vicksburg, and Florida DEP.

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To strengthen the relationship between industry, regulatory agencies and the university, a Technical Advisory Group (TAG) will be formed for this proposed project. This TAG will be composed of a diverse group of environmental professionals working in academia, industry and the regulatory agencies that have a vested interest in determining the environmental impacts from salvage yards in the State of Florida.

It is hoped that members could include:

Rodney DeHan – Groundwater Division, Florida Department of Environmental Protection-Tallahassee

William Hinckley – Bureau Chief, Bureau of Solid and Hazardous Waste Management, Florida Department of Environmental Protection-Tallahassee

Tracy Mattson, The Institute of Scrap Recycling Facilities

Brian Cherry – Groundwater Division, Florida Department of Environmental Protection-Jacksonville

Ernie Frey - Groundwater Division, Florida Department of Environmental Protection-Jacksonville

Dr. Joseph Delfino, Chair, Department of Environmental Engineering Sciences, UF

Suggested peer reviewers will not be determined for a couple of weeks, but a listing of potential reviewers are offered below:

Mr. Robert C. Lunardini, P.E., ABB Environmental Services, Inc., 2590 Executive Center Circle East, Tallahassee, Florida 32301

Dr. Joseph Delfino, Chair, Dept. Of Environmental Engineering Sciences, Univ. Of Florida

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Broward County Department of Natural Resources Protection. 1995. Technical Bulletin 95-01.

"Pollution Prevention and Best Management Practices for Automobile and Other Salvage Facilities Operating in Broward County, Florida." Provides information on a best management practices program in attempt to get all salvage yards in compliance with environmental regulations relating to their operations and to encourage improved operations by a long-list of BMPs.

McCutcheon Update, "EPA Issues Stormwater Permit-by-Rule for 29 Industry Groups, " 1995.

Identifies 29 industries including automobile salvage yards.

North Carolina Department of Environmental Health and Natural Resources, "Waste Reduction Options for Auto Salvage Yards", A handbook for salvage yard operators to reduce their potential environmental effects.

North Carolina Department of Natural Resources and Community Development, January 1990.

"Pollution Prevention Tips: Waste Reduction Options: Automobile Salvage yards." Means of reducing environmental effects of salvage yards and improving their operating procedures.

Texas Department of Commerce, "Salvage Yard: Regulatory Information." Discusses state regulations affecting the automobile salvage industry.

United States Environmental Protection Agency, region 1, "EPA Fines Auto Salvage Yard, Targets Others," June 18, 1997. Summarizes EPA efforts to enforce permit provisions on the NPDES stormwater permit program and ways to reduce environmental damage from stormwater runoff of automobile salvage yards.

Virginia Waste Minimization Program, "Fact Sheet: A Success Story on Waste Minimization in an Auto Salvage Yard." Discusses a program for reducing environmental damage at automobile salvage facilities.

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