by MAURA KELLER
The auto recycling industry has become highly regulated in the U.S. by government environmental regulatory agencies, on the federal, state, county and municipal levels.
When end-of-life vehicles are recycled by shredding via shredder plants, there is a large amount of residue left over. Referred to as automotive shredder residue or ASR, it contains mostly non-metallic materials like plastics, rubber, wood, paper, textile, leather or glass. The primary organic and inorganic chemical constituents of concern found in ASR include: polychlorinated biphenyl (PCBs), metals such as lead and cadmium and total petroleum hydrocarbons (TPH). In addition, lower levels of volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs) may also be found.
Dan Flynn, litigation partner at Dinsmore and Shohl LLP, who focuses on OSHA matters, said there are a number of key issues and challenges pertaining to auto shredder residue faced by recyclers. The exact composition of ASR will vary based by vehicle, as well as the dismantling and recovery procedures of the salvage facility where the vehicle was shredded. If not properly stored and disposed of, toxic substances within the ASR may leach into surrounding soil and groundwater. And depending upon its composition, ASR may also be flammable.
“ASR can pose safety and environmental hazards that recyclers need to manage,” Flynn said. The biggest debate often associated with managing ASR is whether to dispose of the non-metallic ASR generated in recycling operations or whether the non-metallic ASR can be economically recycled for another use.
“OSHA standards play a role in how ASR is managed because the ASR often contains a number of contaminants regulated under OSHA’s general air contaminant standard – the z-listed contaminants – and chemical-specific standards, such as lead,” Flynn said. Recyclers that have robust safety and industrial hygiene programs, however, are generally able to ensure that all of their employees can manage ASR in a safe and healthful manner.
Over the years, recyclers have been able to move forward with plastic recycling operations with increasing certainty that the feedstock and operations will comply with EPA’s regulations.
“Recyclers are now coming up with various innovative ways to capture more of the ferrous and nonferrous metal from the recycling operations and ways to recycle the plastics found in ASR,” Flynn said.
Environmentally Speaking
ASR, also called auto fluff, has long been deposited into landfills, resulting in millions of tons of waste each year. According to the EPA, approximately 75 percent (by weight) of a vehicle is composed of metals that are recycled. The remainder – auto shredder fluff is disposed of primarily in landfills.
In fact, the U.S. EPA stated that approximately one million tons of ASR could be recovered for fuel, which would reduce carbon dioxide emissions and conserve around one million tons of coal each year, as well as avoid landfilling, resulting in an annual savings of $20 million.
Of course, many hazardous chemicals are used in the manufacturing and maintenance of automobiles. According to the Blue Ridge Environmental Defense League in North Carolina, a review of ASR auto fluff by the Ecology Center in Michigan found several toxic contaminants in fluff. Studies completed by the German EPA and the U.S. EPA report that auto fluff contains mercury, lead, cadmium, chromium, arsenic, polyvinyl chloride and PCBs. The state of California considers auto fluff a hazardous waste requiring special disposal.
An EPA study of emissions from fires at ASR landfills and stockpiles, stated, “A number of these stockpiles have caught fire, resulting in the emission of numerous air pollutants.” This study concluded that, “substantial quantities of air pollutants are emitted.” and “cadmium, copper, lead and zinc were found in significant quantities.”
That’s why, the EPA is pushing vehicle manufacturers to design vehicles with recovery in mind and to reduce toxic and hazardous constituents in vehicle shredding.
The top environmental concerns are whether polychlorinated biphenyls (PCBs) potentially contained in the plastics found in ASR are excluded from the Toxic Substances Control Act (TSCA)’s regulations. The EPA banned the manufacture of PCBs in 1979 after research linked PCBs to cancer and other health threats to the immune, reproductive, nervous, and endocrine systems.
Section 6(e) of the Toxic Substances Control Act generally prohibits the manufacture, processing, distribution, and use of polychlorinated biphenyls (PCBs), but a list of “excluded PCB products” have been classified by EPA as suitable for use, processing, and distribution. Those products must typically have concentrations of PCBs less than 50 parts per million (40 C.F.R. pt. 761.20(a) and (c)).
“Recyclers can utilize the Voluntary Procedures for Recycling Plastics from Shredder Residue set forth by the Institute of Scrap Recycling Industries, Inc. and approved by the EPA,” Flynn said. “If recyclers choose to implement other procedures, they must be able to demonstrate that the feedstock and residue consists only of excluded polychlorinated biphenyls (PCB) products.”
Back in 2013, the EPA was approached by the Institute of Scrap Recycling Industries, Inc. regarding separation, recycling, use and distribution of recycled plastics from shredder residue recovered from metals recycling facilities. After finalizing an interpretation of regulations governing the management and recycling of polychlorinated biphenyls, the EPA provided interpretations that will allow for plastics to be recovered during the recycling process as long as the materials do not contain levels of PCBs exceeding 50 parts per million. This new interpretation may reduce the amount of ASR that is landfilled each year by more than one million tons and may also help improve the material recovery rate for end of life vehicles to more than 90 percent.
Specially, the EPA report stated, “EPA is adopting the generic 50 ppm exclusion for the processing, distribution in commerce, and use, based on the Agency’s determination that the use, processing, and distribution in commerce of products with less than 50 ppm PCB concentration will not generally present an unreasonable risk of injury to health or the environment.”
And on the state level, more attention is being paid to ASR regulations and recycling of ASR components. Recyclers and scientists have been searching for ways to recycle and reuse ASR. Currently several states allow the use of ASR as an alternative daily landfill cover, which limits odors and prevents trash from blowing away.
In Carroll, County, Indiana, for example, a new facility is taking shape whereby plastic components within ASR will be converted into diesel fuel. GEP Fuel & Energy Indiana and its partner U.S. Energy Logistics recently broke ground on the $350 million facility, which will house both a recycling center and a plastics-to-renewable diesel refinery. Local officials expect the facility to create more than 250 jobs by 2020.
At the Carroll County facility Camden Recycling, LLC will focus on recycling plastic car parts, making it the largest auto plastic recycling center in the country – and the first-ever in the U.S. to convert plastic into fuel.
Because ASR is full of plastics, which are made of petroleum, it also has the potential for use as a fuel supplement in cement kilns.
The California Department of Toxic Substances Control (DTSC) also has developed a method for processing ASR for use as fuel for cement kilns. According to the DTSC, the process results in a mix of ASR that has a heating value of about 13,240 Btu per pound, which is higher than most types of coal. The DTSC also found that processing and using all of California’s ASR for cement kilns would save automobile recyclers and shredders $20 million per year by avoiding landfill costs and would save cement manufacturers $50 million each year through reduced energy costs.
Published in the July 2018 Edition