Compliant fluid recovery and disposal processes are not to be overlooked in professional auto recycling operations. And they can also be efficient with an eye on the details.
The news reads, auto wreckers settle with environmental watchdog, seek permit extension … where the settlement marks the end of a multi-year process. Fines and attorney fees result in the hundreds of thousands of dollars, and a $10,000 a year ongoing environmental management cost is levied just stay in business.
Notice the keywords multi-year process and the large ongoing fines. Making no judgment on this true case whatsoever as to its validity, all I ask you is, can your operation afford that? Not just the financial aspect, but the time spent in defense?
While some actions will be taken despite the best laid compliance plans, with environmental watchdogs and regulators potentially lurking behind your security fence, sometimes things fall through the cracks and expose your liability. Luckily resources like the ECARCenter.org website has information for your overall compliance, state by state.
While there are many things to consider to protect you from fines, headlines or, worst case, court, proper fluid evacuation and storage responsibilities are mission critical as an auto recycler.
As a great resource, the ARA Certified Automotive Recyclers (CAR) program has just produced a guide on Fluid Evacuation and Storage best practices. It covers Fluid Removal & Dismantling (Storage Containers, Spill Supplies & Cleanup); Used Oil (Removal, Storage & Disposal); Antifreeze (Removal, Storage & Disposal) and Fuel (Removal, Storage & Disposal). While the guide is 12-pages of critical, need-to-know information that can be downloaded at https://a-r-a.org/best-practices/programs/car-gold-seal/ to help keep you compliant, we dig deeper into fuel evacuation tips, trends and processes that aim to keep you efficient without jeopardizing the rules and regs.
When considering effective and compliant fluid recovery, who better to ask than experts who work daily to assist recyclers set up and equip their facilities for it. They have seen it all, from excellent to ugly, ordinary to dangerous, and are lending their observations and expertise to Automotive Recycling magazine to help you evaluate your practices.
The CAR Fluid Evacuation & Storage Guide states, “Fluid removal and dismantling should take place under cover (roof) such as inside the shop and on an impervious surface to minimize potential for accidental release of fluids from drips and spills. New and recyclable fluids should be stored, transported, disposed of, handled, and used in ways that prevent exposure to the environment.” In theory, this seems a reasonable process, yet there are many ways this can go awry.
What are the biggest issues that auto recyclers fail to do or consider when setting up their fluid evacuation systems or procedures?
“The biggest mistake dismantlers make in our experience,” says Adrian Piece of AutoDrain, “is to under-specify their systems to minimize costs and then have to invest simply to meet existing capacity. We advise all customers to consider their business in terms of growth before specifying a depollution system.”
“Storage, by far, is the biggest issue, followed by fuel diversion and implementation of best management practices,” notes Greg Lamb of Lamb Fuels, a fluid recovery company. “Storage tank size specifically! We recommend at least double your expected volume for a period of two weeks. The bigger, the better. However, most customers undersize, attempting to stay under the threshold of local or state ordinances for the permitting of above-ground storage tanks. Fluid storage is one of the most overlooked and under-prioritized infrastructure item.”
“When calculating tank size, it is important to consider,” notes Lamb, “how many cars will the customer process at most every two weeks? This is important because we estimate that salvage vehicles contain approximately 5 gallons each. If the customer expects to process 50 cars per day, 6 days a week, that’s 1,500 gallons a week, or a 6,000-gallon tank! That also equals peace of mind and you never slow down processing.”
“Also, how frequently does the customer plan to have the tank serviced and what is the ability of the vendor?” Lamb asks. “Most customers do not want vendors or service providers in their yards longer than necessary, and neither do we. This impacts tank size.”
Lamb has noticed that this year the industry has experienced a huge volume increase of fluids in just about every region and these volumes increases occurred relatively quickly. “That has a downstream effect on the capacity of your storage tanks,” he says. “They fill faster. But, if your fluid recovery service is on a regularly scheduled route, that means your tank could overfill before your service provider can get there. When you build your depollution system oversize your storage tank.”
Another factor to consider is efficiency and flow along with safety and cleanliness. “The less you have to move a vehicle,” says Mason Smith of Crow Environmental, “the more efficient and less chance of damage. Also, the less one handles the fluids, the better. A system that pumps straight into proper storage tank is not only cleaner, in my opinion, but more efficient than lifting buckets or carts to empty every time they get full.”
“The biggest issue I see,” says Dan Pralle of Lonewolf Petro, a fluid recovery company, “is not accounting properly for rainwater. Facilities that do not have a roof over the dismantling area often contend with the overflowing of secondary containment and the cost of evacuating the contaminated rainwater.” This, of course, can lead to citations and fines, and even bad press should it be made public.
Safety is a main concern for proper installation and use of depollution systems.
“I sometimes hear, ‘We have always done it this way and never had a problem,’ yet we get calls from facilities that have had fires which have either been near misses or have burned their building to the ground,” says Nigel Dove of Vortex Solutions. “There are many excuses given for not putting in professional systems, especially in the full-service sector where a lower number of vehicles are processed. The most common reason is ‘we sell the gas tanks.’ In reality, how many tanks are sold and how much revenue does it raise against the cost of losing the facility or worse, someone’s life?”
Auto recyclers looking to improve their systems should look at their facility first and identify any danger areas such as tank placement. “Is it safe to store gasoline inside a building? We would say never,” says Dove, “unless the tank vents to the outside because gas fumes are heavier than air, which can risk an explosion inside the building.” Does the storage tank meet local fire codes or is it compliant with UL 142 or even better UL 2085?
Other considerations are whether to de-fuel vehicles inside the building or outside, and what does the chosen system accommodate. Also, fuel will continue to drip from an emptied fuel tank especially on gravity drain systems, and some believe that it is better to contain this gas in a drip pan that the operator walks on and that it will evaporate. “Over time it will,” says Dove, “but while operators are working on it they are at risk of fire and explosions from their tool’s spark.”
“For self-service operators, throughput is the key to a good system, handling the vehicles as few times as possible,” Dove says. “In some yards, the pick and bucket is still the preferred method, but environmentally puddles of dripping gas and oil mix to stain the ground.”
“Using a vacuum system to actively suck the fluids out greatly increases the efficiency of fluid removal, and also safety,” suggests Bruce Henderson of SEDA Environmental LLC. “Also, using a drill creates a large and clean hole as it cuts away any fuel tank material so the fuels can be extracted in a very fast and safe manner. Beware, though, that there are drills that do not have safety certifications on them and will not pass inspections by fire marshals. Ask your supplier for the UL/ATEX certification on their drill or spike, crucial in the event of an incident for your insurance.”
With safety a big concern, efficiency is also important for auto recyclers. How can auto recyclers improve their efficiency in this function?
“There are a lot of aspects to take in to account,” says SEDA’s Bruce Henderson, “but I would say proper preparation makes all the difference in safe and compliant fluid evacuation.” His tips include:
• Remove the battery for safety reasons, as damaged wiring could cause a fire, for example, and removing the battery also makes (SRS controlled) airbags and safety restraint systems safer to work around.
• On older cars with mechanical heater switches, he recommends to switch or slide the controllers to hot air to open any piping behind the dashboard so it can also be recovered while draining the antifreeze.
• Remove the caps of the different fluids you extract (gas/diesel, oils, radiator, antifreeze reservoir, power steering, brake fluid, wiper fluid) which enhances the flow of fluids while draining them from the bottom of the vehicle, especially with a high volume vacuum system. Removing the fuel filler cap beforehand lets the operators identify the fuel he is going to recover.
• Remove the skid plate from any vehicle that has them is crucial, not because they are impenetrable but because there is a gap between the skid plate and the fuel tanks. When penetrated, the fuel will spill everywhere, causing all sorts of hazards.
• Remove the wheels. The ELV is easier to place on the rack and everything is more accessible.
“Tilt the ELV slightly to one side on a drainage rack to help the fluids go to one end of the tank(s), especially with fuel tanks, it helps you recover more fluid,” Henderson says. “Remember also that tanks with baffles in them may require multiple holes drilled (depending on the make and model).” Also, he notes that using a two-post rack makes vehicle undersides more accessible with the working space not dictated by metal posts and the worker can move more freely.
“Plan to depollute and dismantle in the manner most suitable for your volume,” suggests Adrian Piece, AutoDrain. “For example in lower volume businesses, it’s practical to depollute and dismantle in the same bay; larger setups require thought to be given as the depollution process might be as low as 20 minutes of process time, while dismantling might extend to some hours. The key is to avoid bottlenecks.”
Moving the vehicle the least amount possible is suggested by Mason Smith, Crow Environmental. “Have a station where once the vehicle is loaded, it can be inventoried, de-polluted and dismantled for the parts needed. This also allows your front-end loader or other equipment to be available for other things in the yard. A depollution unit is an expensive piece of equipment to be used as a ‘lift/rack’ or to be waiting while fluids under the hood are being removed so that the vehicle can then be lifted into a rack. Therefore a station with a lift is more efficient, in my opinion, with less moving of the vehicle.”
“The most efficient places I have seen have multiple bays for dismantling,” says Dan Pralle of Lonewolf. “Cars are staged as others are draining.” If space allows in the facility, this is an option to consider.
“Training, training, and more training is needed and establish a process that maintains a quality recovered fluid or fuel product in the end,” says Greg Lamb of Lamb Fuels. “The actions taken throughout the entire process have a significant effect on the outcome of fuel quality. Depollution systems are an essential tool in that process. Specifically, those with the ability to visually inspect and then divert contaminated fuel and water to alternative storage tanks. This will save customers waste disposal expenses.”
Extractions and Removal Options Abound
Each of our experts offers different systems and services where they safety, compliance and ease of use as benefits. We asked how their system work bests.
“Our depollution systems are modular and can therefore be specified to any volume dismantler,” notes Adrian Piece, AutoDrain. “All of our depollution equipment has been designed to work equally effective as stand alone or within a full depollution bay.”
“Crow Environmental offers two systems; our VDU single bay system is designed for quick fluid extraction,” says Mason Smith. “It can be used for full-serve and self-serve yards as well as scrap yards. A single operator can do about 27 vehicles a day. We also offer the MIDI System, which is designed to go between lifts or racks. We sell many of these to full-service yards where they are dismantling and inventorying the vehicles. The amount it can do depends on how extensive each vehicle is processed. We also offer gasoline/diesel extraction only systems.”
“A well-planned fuel recovery program guided by our Lamb Fuels Best Management Practices is effective for all types of auto recyclers, dismantlers and scrap processors – from the family operators and specialty yards, to large self-serve auto recyclers and mega shredders,” says Lamb. “They are written specifically for fuels, but apply to all recovered fluids from vehicles. If a customer uses our BMP’s and stores their fluids separately, they will operate safer, cleaner, and more organized facilities, and will experience increased revenues and reduced expenses.”
“We have several different systems to meet almost any need of a recycling yard,” says Bruce Henderson, SEDA Environmental LLC, “ranging from our ‘Green Point’ system, a pump and drill method, to our high volume ‘Jumboline’ system that comes with a 10,000 lb. vehicle rack, integrated suction system with double-diaphragm pumps for petrol, diesel, oil, coolant fluid, and windscreen water and ships on its own mobile base that doubles up as a catchment proof platform in the event of a spill. The base has loader pockets so it can be picked up and moved around.”
“See what you like and what will fit your demands,” Nigel Dove, Vortex Solutions. “If the customer likes our designs, but prefers a drill to a punch, then that is what we will fit for them. We have a flexible approach to what companies want, and being first and foremost an engineering company, we can usually satisfy their demands.”
At Lonewolf, they specialize in removing fuels off a recycler’s premise. “We strive to remove your waste or contaminated fuels in a timely manner. Our technology, equipment and highly-skilled employees enable us to adequately satisfy our customers. The services that we offer are eco-friendly and compliant with State and Federal guidelines,” says Dan Pralle.
The Last Drop
The one piece of advice each of our experts offers to auto recyclers is:
“Plan ahead, and allow for growth,” says Henderson.
“Talk to a company with depollution expertise, not just a big catalogue and a keen sales team,” says Pierce.
“Maintain your storage tank,” says Lamb. “The customer must insure any water or other contaminates that accumulate in the tank are removed as quickly and as often as possible to maintain fuel quality and value of your commodity. We use a Fuel Grading Scale when purchasing fuel; when water and other contaminants are present the value of your fuel is reduced.”
“My main piece of advice is to not use floor drains near draining gas, do it on a concrete surface and clean up spills,” says Dove.
“Stronger depollution regulations are coming. They are in the European Market already and it will not be long until they come to the U.S. Be prepared. Be ready. Be ahead of the curve,” says Smith. “While using this type of equipment is not required, it is still a very important piece in the process. Being clean, safe and efficient can be priceless, especially if the DEQ or EPA come inspecting.”
FLUID REMOVAL AND DISMANTLING AREAS
For the 2018 self-audit certification year, the ARA Certified Automotive Recycler program has enhanced guidance on safe fuel removal and storage of all fluids. Fluid removal and dismantling should take place under cover (roof) such as inside the shop and on an impervious surface to minimize potential for accidental release of fluids from drips and spills. Fluid evacuation should be conducted using telescoping drain trays, collection trays, vacuum extraction, or gravity draining away from floor drains.
Keep fluids separated
• Recyclable oils (engine, transmission, brake, and power steering fluids) may be stored together
• Antifreeze should be stored separately
• Fuel should be stored separately
• Solvents and degreasers may not be mixed with oil or fuel
Storage containers must be compatible with the fluids being stored. There is concern that re-used totes should not store gasoline due to incompatibility issues over time. All storage containers, tanks, totes, drums, cans and bottles should be clearly labeled to identify the container’s content, both for safety and compliance reasons.
OSHA’s Hazard Communication Standard or HCS has labeling requirements that display the Globally Harmonized System or GHS of Classification and Labeling of Chemicals identification of chemicals, signal words, pictograms and precautionary statements.
Spill Supplies & Clean up
Every salvage yard should maintain a spill cleanup kit on-site at the facility in the event of an emergency spill. Maintain spill kits that contains appropriate absorbents to handle the volume of fluid present. Place the labeled spill kits where fluids are used or stored. Provide and document training to employees on how to properly manage fluids, prevent spills and leaks, respond and clean up a spill, and dispose of used absorbents.
– These are highlights from the ARA Certified Automotive Recyclers (CAR) guide on Fluid Evacuation & Storage.
Caryn Smith is the editor of Automotive Recycling magazine and has been covering the industry for over 20 years.
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