September/October 1996
The road to environmental compliance need not be cluttered with expensive and complex solutions. Here are some simple maneuvers that can help you navigate the regulatory track, with special emphasis on controlling storm water runoff.
By Robin K. Wiener
Many recyclers view environmental compliance as a Herculean task rife with obstacles that are expensive and burdensome to overcome.
But achieving compliance doesn’t have to be difficult or expensive, and compliance measures don’t have to entail added construction or outside help, even when dealing with storm water runoff management—one of the biggest environmental issues facing recyclers today.
The truth is there are plenty of simple, inexpensive steps you can take to enhance your compliance efforts. The key is to start with these elementary suggestions and then move on to more comprehensive, sophisticated ones later.
Keeping It Out
The most basic line of defense in environmental compliance is source control—identifying those materials that, if improperly managed, could present a threat to human health and the environment, and preventing them from entering your facility in the first place. In fact, given that incoming scrap can come from many sources and you may know little about the material before it arrives at your facility, source control is not only basic, it’s essential to keeping your plant clean.
The first step to developing a source control program is to determine what material is coming from what sources. This process may take some time and effort, but it is a relatively inexpensive control measure that can have a significant effect on your compliance efforts. With this information, you’re ready to identify those materials that pose the most significant threat to your facility, keeping in mind that the list will be site-specific. Don’t neglect to also consider materials that you can handle efficiently and in compliance with all applicable legal requirements and formulate a plan to minimize the risks associated with dealing with those materials.
Once you determine which materials you are willing and unwilling to accept, post conspicuous warning signs at every entrance that plainly list the unacceptable items. If possible, clearly outline on the signs the penalties that suppliers could face if they ship prohibited material.
In addition to posting signs, it’s a good idea to meet with your suppliers to specify the conditions under which you will purchase scrap. To address problems related to oily scrap, for instance, you may require that oil pans be removed and transmissions and rear-ends be drained of fluid prior to shipment to your facility. You may also decide to reject obsolete and undrained industrial machinery, or perhaps ask suppliers to spin-dry turnings to reduce residual oil content.
For added protection, you might also consider incorporating indemnity and other risk-shifting language into contracts with your suppliers, wherein they agree to comply with your standards and indemnify you from and against damages that could result from a breach of contract. In such instances, you should make your suppliers aware that hazardous substances, if present in the materials they send to you for recycling, could make them liable for future on- and off-site cleanups.
You could also use market-based economic incentives to enhance the effectiveness of your source control program and recover some of your environmental compliance costs. For example, you could charge suppliers the cost of disposing of fluid from oily scrap or impose deductions for tires in loads.
Another way to control what comes into your plant is to control what goes out of your suppliers’ plants. If you leave containers at supplier sites, one way to accomplish this goal is to require that the containers be kept covered as much as possible, thus minimizing the chance for storm water to collect in the container and mix with residual fluids on the scrap. (When storm water mixes with fluids, the total volume of fluids to be managed increases, thereby increasing your costs of management and disposal.)
Some processors address this problem by using weep or drain holes in the bottoms of containers to discourage suppliers from shipping excess fluids along with scrap. This is not necessarily a good idea, however, since potentially hazardous fluids can leak out during transport or unloading at your facility.
The last, but certainly not least, step to developing an effective source control program is to continually educate your employees on your firm’s source control procedures and explain the potential cost and liability if unacceptable materials enter the facility. Without the concerted effort of all personnel, no environmental compliance effort can succeed—not source control, not spill cleanup, nor proper handling of potentially hazardous material, nor any other critical practice.
Maintaining Equipment
Materials from suppliers aren’t the only things that can cause environmental concerns. Fluids from your own vehicles, shears, balers, shredders, and other machinery can also pose environmental threats, yet they are easy to overlook in your quest for compliance.
To counter potential problems from on-site equipment, implement a preventive maintenance program that helps identify and detect conditions that could cause the release of oils, hydraulic fluids, grease, and/or fuel.
At a minimum, your preventive maintenance program should include regular visual inspection and testing of vehicles and equipment for leaks, spills, and malfunctioning, worn, or corroded parts, as well as regular inspections of valves, hoses, seals, and your fluid containment system. In addition, you can help detect and prevent problems by listening and feeling for vibrations and peculiar sounds emanating from machinery and repairing leaks and worn parts before they fail. For additional guidance, refer to your equipment and vehicle maintenance manuals or contact vendors for recommended maintenance and service schedules.
In addition to preventive maintenance, you may want to consider installing curbed containment areas around stationary equipment to minimize storm water risks if a leak occurs. Containing leaked fluid and preventing it from mixing with storm water minimizes the total volume of fluid that must be managed and disposed of, thus decreasing your costs in this area.
Brushing Up on Housekeeping
Even with the most stringent source control and preventive maintenance programs, no scrap recycling facility can be completely fortified against all environmental intruders. It’s important, therefore, to implement a housekeeping system to help minimize environmental problems and enhance the safety of your operation.
Make a Clean Sweep. The most basic of housekeeping tasks is routine sweeping of your facility, a procedure that will become natural over time—if you require your employees to do it and tell them how important it is to keep debris from building up.
And sweeping is, indeed, vital. Particles that accumulate on pavement, for instance, are easily carried away by storm water if not cleaned up before it rains and can present other environmental worries as well as operational problems like flat tires.
Control Sediment and Erosion. Sweeping is also an important component of sediment control, which, in turn, is another simple way to control storm water runoff. In this regard, unpaved roadways, scrap storage areas, and paved surfaces should be kept free of accumulated sediment and the swept-up sediment and dust should be placed in a covered, watertight container until sent for proper disposal.
Hand in hand with sediment control goes erosion control, which can help you achieve storm water compliance. One easy way to address this issue is to plant grass or other vegetation wherever feasible in your facility. Since steep slopes on your site tend to be particularly vulnerable to erosion, it makes sense to concentrate on these spots, but flat areas are certainly subject to erosion as well, so plant vegetation here too if possible.
Fences of different varieties can also be effective at controlling dust and sediment as well as erosion, plus they have the added benefit of minimizing the chance of “midnight dumping” of materials at your facility. A silt fence made of fabric, in particular, can help control the movement of sand, silt, soil, and small metal particles throughout your facility.
Go Under Cover. Another crucial step to responsible housekeeping is ensuring proper storage of potentially problematic materials. This doesn’t mean you have to enclose your entire facility, simply that selected materials should be protected from the elements wherever practical.
Toward this end, with storm water compliance in mind, first determine which materials contain residual fluids that could pose potential storm water problems if exposed to precipitation and designate a covered storage area for these materials. Another option is to store such materials in a contained area that provides for proper collection of fluids. As examples, lead-acid batteries, turnings, and borings can be kept under a roofed area of your facility or under a lean-to structure that will protect them from the elements, while also protecting you from storm water problems.
Taking Care Of Oils
Containing and collecting free-flowing residual fluids from oily scrap is an essential component of the environmental compliance agenda for many scrap recyclers. After all, oily scrap poses potentially significant contamination risks to soil, storm water, and groundwater. What’s more, the concern is not only with the residual oil itself, but also with the heavy metals and other contaminants that are all too frequently trapped in the used oil and have the potential to be carried into soil and storm water along with the oil.
Oily scrap can come in many forms—from turnings, cuttings, and borings containing emulsified cutting oils and coolants to automobile hulks and parts containing motor oil, antifreeze, and brake and transmission fluid. The first key to minimizing the worrisome fluids associated with this scrap is, again, source control.
The complementary strategy is to contain and collect any free-flowing oils that do enter your plant so they then can be properly managed. There are a number of ways to do so.
One method is to store oily scrap in metal containers such as old railcars or roll-off containers and then drain the oil collected at the bottom into sealed containers or used oil tanks for proper management.
A more elaborate approach to handling oily scrap is to contain it on reinforced concrete pads with curbs and berms to capture and contain fluids and a sloping design that channels fluids to a trough leading to a collection sump. The disadvantage of this approach is that the concrete can crack relatively quickly due to the equipment and operational stress associated with scrap processing, so it may be necessary to use a liner or barrier under the concrete pad to capture fluids that might leak through any cracks.
Regardless of the collection and containment method you choose, you’ll also need to manage accumulated oils and other fluids in accordance with environmental regulations. And that means sending them to a waste oil recycler, a commercial wastewater treatment plant, a publicly owned treatment works, or a sanitary sewer system—or running them through your own on-site treatment system.
If you decide to pursue on-site treatment, you can select from several different approaches.
In the case of used oil, some of the most common methods of treatment are settling, filtration, and evaporation systems, with the recovered oil being properly disposed of or sold for recycling.
When dealing with oil or grease in wastewater or storm water, you might want to consider installing simple oil-water separators, which use gravity to separate the water from the oil fraction. Generally, the oily waste is retained in a holding tank and oils and other materials less dense than water float to the surface and are skimmed off. Be aware, however, that conventional baffle-type or coalescing-type separators are not effective in removing emulsified or soluble oils.
A more complex avenue for treating oily wastewater is ultrafiltration. In this type of system, oily wastewater is pressure-driven across membranes that separate particles down to 0.005 microns in size. Separated oils and solids are concentrated and removed from the system, and the treated wastewater, or effluent, is then discharged to a sanitary or storm sewer system. (A word of caution: Before discharging fluids to a public treatment works or sanitary sewer system, check with the system operator as there may be discharge limits, fees, or even permits required for effluent discharges.)
Yet another option is to install gas-fired evaporators to reduce the volume of oily fluids from scrap as well as the water used to wash equipment. According to one recycling company that has implemented such a system, it has reduced the company’s volume of fluids more than 98 percent, thus providing substantial savings in disposal costs. Evaporation costs reportedly range from 5 to 10 cents a gallon, which is competitive with conventional treatment systems.
Managing Runoff
To comply with state or federal storm water management rules, your environmental compliance efforts should also encompass measures for removing pollutants from storm water runoff.
One basic way to address this issue is to convert a flat area of land in your facility to a grassed swale—a shallow, sloping ditch that conveys storm water. Swales reduce pollution by filtering sediments from storm water runoff and diverting runoff away from your scrap storage and processing areas. To maintain a grassed swale, keep the area free of debris, sustain its vegetation, and regularly remove any accumulated sediment.
Another possible way to control and manage runoff is to shape earth or concrete into berms, gutters, curbs, or other diversion structures to channel the flow of storm water to a central point within your
facility.
Or, you might want to install inlet filters, which are relatively inexpensive, easy to clean, and have the added benefit of being placed downstream from processing areas at the specific site where storm water leaves your property. One drawback to inlet filters is that they may get torn and could clog in areas of high flow.
If you have enough space on your site, a detention pond can also aid your storm water control efforts. A detention pond is basically a water basin that temporarily holds storm water as sediment and pollutants settle on the bottom. Required maintenance includes monitoring the accumulated sediment and removing buildup of metals and other pollutants as necessary. You will also need to periodically test the accumulated material to make sure it is removed before it reaches toxic levels that would classify it as hazardous waste.
It is also important to properly manage your non-storm water runoff, such as interior floor drain discharges, equipment cooling water, and vehicle wash water that is not authorized to be discharged to a storm drain. Plug any floor drains that are connected to the storm water system and do not wash vehicles or equipment outside without capturing the runoff.
Staying Alert
OK, so your lines of defense are in place and you’ve taken a number of preventive measures to diminish the likelihood of an environmental mishap at your facility. You have nothing to worry about, right?
Wrong.
Environmental problems such as leaks and spills can happen at any time. As a result, you should be prepared to act quickly when—not if—such a situation develops.
To get prepared, examine your facility and identify areas that are potential sources of leaks and spills. Post clear signs in each area indicating which fluids could leak or spill, whether or not they are hazardous or toxic, what safety gear should be worn, and what cleanup procedures should be used. Keep spill cleanup materials near each site, including booms, brooms, rags, oil dry, shovels, and absorbent pads. And make sure all employees understand how important it is to respond to a spill quickly, instructing them that they should stop what they’re doing, contain the spill, and properly dispose of the used absorbent material.
It’s also a good idea to keep drip pans underneath vehicles and equipment during maintenance, with removed parts being placed in a drip pan on a tarp or pad. If machinery is leaking, place a drip pan under it until the leak is repaired and be sure to empty it regularly to avoid spillover. Used oil should be collected in a pan that is large enough to accommodate the entire quantity, then carefully transferred to a used oil storage tank, which should be located in a paved containment area or building.
While environmental compliance may not be easy, it can be easier and less expensive if you follow these and other basic operational and preventive tips. As with recycling, compliance is an ongoing process, one that needs to be continually reviewed and refined to achieve the best, most efficient results. With these tips as a guide, you can get your operations on the right track toward compliance.
ISRI Can Help
ISRI offers several educational resources that provide information on suggested management practices and environmental compliance guidance.
The association’s storm water guidance manual, distributed in January 1996, was sent free to members of the ReMA storm water group. Group members can purchase additional copies for $50, while the cost to non-group ReMA members is $2,000.
Another resource is ISRI’s environmental operating guidelines, a publication that was sent free to all association members in April 1992. Additional copies of this manual are available to ReMA members for $60.
And for more interactive guidance, attend ISRI’s upcoming storm water seminar to be held Sept. 27 at the Omni International Hotel in Cleveland. Members of ISRI’s storm water group can attend the seminar at no charge; the fee for non-group ReMA members is $395.
To register for the seminar or obtain more information on either of the publications, contact ISRI, 202/737-1770 (fax, 202/626-0900).•
—Robin K. Wiener, ReMA director of environmental compliance/assistant counsel, and David Kendziorski, a principal with Camp Dresser & McKee Inc. (Milwaukee)
The road to environmental compliance need not be cluttered with expensive and complex solutions. Here are some simple maneuvers that can help you navigate the regulatory track, with special emphasis on controlling storm water runoff.