The primary regulatory issues at an auto salvage yard facility are:

• Fluid storage
• Waste fluid storage
• Storage tanks--above ground and under ground
• Fugitive air emissions--evaporating fuel, refrigerants
• Contaminated stormwater
• Chlorofluorocarbon (CFC) recovery licensure and training
• Improper disposal
• Tire storage and disposal

The two most important regulatory issues for salvage yards are fluid management and contaminated stormwater. Other environmental issues such as air emissions do exist, but are less significant in terms of scope and impact.

Some of the fluid management issues include fluids such as oil, antifreeze, brake fluid, windshield wiper solvent, etc. being improperly removed or not removed at all from the vehicle prior to storing in the salvage yard area. Fluids commonly leak from the deteriorating vehicles and spill out onto the ground contaminating the water and soil. This is particularly troublesome with regard to stormwater contamination.

The following are regulations that commonly apply to salvage operations. Each business practice varies and not all regulations necessarily apply. The owner/operator is responsible for complying with all applicable requirements of the federal, state, and local government environmental laws.

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Hazardous Waste Regulations

Federal Hazardous Waste Codes 40 CFR Part 260--263
Manifest 40 CFR Part 263.20

State Hazardous Waste Codes (See State Regulations Locator at http://www.envcap.org/statetools/srt/srt.html)
For most or all federal regulations summarized in this Topic Hub, state specific requirements that may differ are also applicable. Additionally, county or municipal regulations may also apply.

Resource Conservation and Recovery Act (RCRA) 40CFR Part 240 - 299
http://www.epa.gov/docs/epacfr40/chapt-I.info/

Comprehensive Emergency Response, Compensation and Liability Act (CERCLA) 40CFR Part 305
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=c04205bae07b5c13cb2b04c94c77cd7d&rgn=div5&view=text&node=40:25.0.1.1.5&idno=40

Hazardous Materials Generation 40 CFR Part 262
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=c04205bae07b5c13cb2b04c94c77cd7d&rgn=div5&view=text&node=40:23.0.1.1.3&idno=40

Hazardous Materials Transportation 49 CFR Part 171-180
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?sid=04c092dd30d0e4095cb9273991e60652&c=ecfr&tpl=/ecfrbrowse/Title49/49cfrv2_02.tpl

Emergency Planning & Community Right to Know Act (EPCRA), also known as Title III of the Superfund Amendments & Reauthorization Act (SARA)
http://www.epa.gov/emergencies/content/epcra/index.htm

Common substances found at a salvage yard that if released into the environment (air, water, or land) must be reported to the local emergency authorities as well as the state and federal EPA:

• Lead sulfate ? Car Batteries, (Reportable Quantity, or RQ, is 100 lbs or liquid content of about 8 car batteries)
• Sodium azide ? Air Bag Cartridges. (RQ is 1000 lbs or the contents of about 500 ? 1000 cartridges)
• Mercury ? Switches (1 lb of mercury)
• Ethylene Glycol ? Approximately 1 quart (RQ is 1 pound)

Canada: Regulations for the Management of Hazardous Waste
http://www.on.ec.gc.ca/pollution/fpd/hazwaste/intro-e.html

Canada: Environmental Protection Act RRO 1990 Regulation 347
http://www.e-laws.gov.on.ca/html/regs/english/elaws_regs_900347_e.htm

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Oil Waste Regulations

U.S. EPA Used Oil Management ? See 40CFR Part 279
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=4fd28cb246cbc9cc4de0db1e41d68bef&rgn=div5&view=text&node=40:24.0.1.1.8&idno=40

National Oil and Hazardous Substances Pollution Contingency Plan 40CFR Part 300
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=a504ab586b5ae6aa64826fd2ce0c805b&rgn=div5&view=text&node=40:25.0.1.1.1&idno=40

Salvage facilities are considered waste oil generators because they are businesses that handle used oil through commercial or industrial operations or from the maintenance of vehicles and equipment.

Some salvage facilities are also classified as collection centers or aggregation points. Collection centers and aggregation points are facilities that accept small amounts of used oil and store it until enough is collected to ship it elsewhere for recycling. Collection centers typically accept used oil from multiple sources that include both businesses and individuals. Aggregation points collect oil only from places run by the same owner or operator and from individuals.

Businesses that generate or handle used oil must follow specific management standards developed by U.S. EPA and implemented by EPA and the states. There are certain good housekeeping practices that salvage facilities must follow. The management standards are designed to ensure the safe handling of used oil, to maximize recycling, and to minimize disposal. The standards apply to all used oil handlers, regardless of the amount of the oil they handle. Although different used oil handlers may have specific requirements, the following requirements are common to all types of handlers. These requirements relate to storage and to cleaning up leaks and spills, as follows.

• All containers and tanks of must be labeled ?Used Oil?
• Containers and tanks must be in good condition. Oil should not be stored in containers that exhibit structural defects, rust leaks or evidence of deterioration.
• As long as they are labeled and in good condition, tanks and containers storing used oil do not need to be Resource Conservation and Recovery Act (RCRA) permitted. However storage tanks may be required to be permitted or licensed under other regulations.
• Storage of used oil in lagoons, pits, or surface impoundments that are not permitted under RCRA is prohibited.

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Waste Tires

State or local environmental regulations governing the storage of used tires apply.

Illinois
Title 35: Subtitle G: Waste Disposal Part 848 Management of Used and Waste Tires
http://www.ilga.gov/commission/jcar/admincode/035/03500848sections.html

Indiana
IC 13-20-13 Chapter 13. Regulation of Waste Tire Storage Sites
http://www.in.gov/legislative/ic/code/title13/ar20/ch13.pdf

Michigan
MI Natural Resources and Environmental Protection Act, Act 451 of 1994 Part 169?Scrap Tires
http://www.legislature.mi.gov/(S(tv5oml55wqkzp0ing0xb5h30))/mileg.aspx?page=getobject&objectname=mcl-451-1994-II-5-169

Minnesota
Chapter 9220 Minnesota Pollution Control Agency Waste Tire Programs
http://www.revisor.leg.state.mn.us/arule/9220/

New York
Chapter IV Quality Services Subpart 360-13
http://www.dec.state.ny.us/website/regs/subpart360_13.html

Ohio
Ohio Administrative Code Rule 3745-27-60 General Storage and Handling of Scrap Tires
http://www.epa.state.oh.us/dsiwm/document/currentrule/3745-27-60_current.pdf

Ohio Administrative Code Rule 3745-27-78 Beneficial Use of Scrap Tires
http://www.epa.state.oh.us/dsiwm/document/currentrule/3745-27-78_current.pdf

Scrap Tires are Banned from Landfills
http://www.epa.state.oh.us/pic/nr/1997/march/scraptir.html

Ontario
Environmental Protection Act RRO 1990 Regulation 347
http://www.e-laws.gov.on.ca/html/regs/english/elaws_regs_900347_e.htm

Pennsylvania
HB 1929 Waste Tire Recycling Act
http://www.palrb.us/pamphletlaws/19001999/1996/0/act/0190.pdf

Wisconsin
Dismantling of Vehicles for Parts Selling and Salvage Storm Water Associated with Industrial Activity WPDES Permit No. S059145-1
http://www.dnr.state.wi.us/org/caer/cea/assistance/scrap/stormwater/auto/memo.pdf

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Open Burning Restrictions

Illinois
Title 35: Subtitle B: Air Pollution Chapter I: Pollution Control Board Subchapter i: Open Burning Part 237 Open Burning
http://www.ilga.gov/commission/jcar/admincode/035/03500237sections.html

Indiana
Open Burning Variances
http://www.in.gov/idem/5889.htm

Michigan
Open Burning Information
http://www.michigan.gov/deq/0,1607,7-135-3307_3668_4148-65250--CI,00.html

Minnesota
Minnesota Statutes 2003, 88.171 Open Burning Prohibitions
http://www.revisor.leg.state.mn.us/stats/88/171.html

Ohio
Before You Light It Know Ohio?s Open Burning Regulations
http://www.epa.state.oh.us/pic/facts/openburn.html

Pennsylvania
Open Burning Information
http://www.dep.state.pa.us/dep/deputate/airwaste/aq/openburn/openburn.htm

Wisconsin
Chapter NR 429 Malodorous Emissions and Open Burning
http://www.legis.state.wi.us/rsb/code/nr/nr429.pdf

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Refrigerant Recovery and Recycling

Refrigerant Recovery and Recycling Requirements? 402 CFR Part 82
http://www.access.gpo.gov/nara/cfr/waisidx_02/40cfr82_02.html

Section 608 of the Clean Air Act of 1990 as amended
http://www.epa.gov/ozone/title6/608/608fact.html

Any CFC used as refrigerant must be recovered from small appliances. The CFC must not be vented into the atmosphere. This rule applies to salvage facilities.

EPA requires that:

• At least 90% of the refrigerant in the appliance must be recovered when its compressor is running or 80% of the refrigerant must be recovered when the compressor is not running.
• The refrigerant is removed to 4 inches of mercury or less.
• If a facility is receiving an appliance that has had the refrigerant removed, the source of that appliance provides a signed verification statement that the refrigerant has been removed according to EPA minimum standards (above).

U.S. EPA requires that persons recovering refrigerant from equipment certify to EPA that they have acquired recovery equipment and that they are complying with the applicable requirements of the federal regulations addressing refrigerant requirements. The certification must be signed by the owner of the equipment or another responsible facility representative and sent to the EPA regional office. If the salvage yard is only disposing of small appliances, they are not required to obtain technician certification.

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Stormwater Discharge Permit

The stormwater discharge permit system was put in place because stormwater runoff picks up pollutants such as oil, antifreeze, etc. on equipment and spills on or in the ground. The contaminated stormwater can pollute lakes and streams. As a result, the 1987 amendments to the Clean Water Act required the United States Environmental Protection Agency (U.S. EPA) to address storm water runoff. See 40CFR 122.49 (http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=4fd28cb246cbc9cc4de0db1e41d68bef&rgn=div8&view=text&node=40:19.0.1.1.12.3.6.9&idno=40).

As a result U.S. EPA has developed a multi-sector general stormwater permit requirement for specific industry categories. Automobile salvage yards are one of the industry groups covered under this permit requirement. Each of the Great Lakes states administers the stormwater permit program on behalf of U.S. EPA.

Stormwater contamination is one of the primary environmental concerns at automotive salvage facilities. The pollutants of greatest concern from salvage activities are sediment (suspended solids), especially in unpaved facilities, automobile fluids (fuel, antifreeze, hydraulic fluid, transmission fluid, brake fluid, and power steering fluid) and metals (lead, iron, mercury and aluminum).

The best way to comply with the terms and conditions of these permits is through pollution prevention. By controlling or eliminating the opportunity for stormwater to be contaminated by the salvage yard facility, the less cost and effort will be involved with compliance. Additionally, pollution prevention activities will reduce the risk of a costly enforcement action against the salvage yard.

See your state regulatory agency for specific information about the stormwater permitting and control program.

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Local POTW Wastewater Permit

In addition to obtaining state wastewater discharge permits, many county or municipal governments require salvage yards to obtain a discharge permit. Commonly the Publicly Owned Treatment Works (POTW) administers the program. Check with your local POTW or local government office to inquire about permit requirements.

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Underground Storage Tanks (UST)

If your shop maintains an underground storage tank (UST) for used oil, motor oil, or fuel (gasoline, diesel, kerosene) you are probably subject to UST regulations. Leaking USTs can contaminate groundwater. The federal requirements for UST?s are 40CFR Part 280 and 40CFR Part 281, although codification of individual state and territorial programs is found in 40 CFR Parts 282.50-282.105. The list of hazardous substances is in 40 CFR Part 302.4. See http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?&c=ecfr&tpl=/ecfrbrowse/Title40/40tab_02.tpl for access to the various parts of 40 CFR. For the requirements that apply to your UST, call your State or local agency.