Fluid Removal & Spill Hazards
Automotive fuels and fluids are present in vehicles and must be removed before dismantling, shredding, or storing vehicles. Leaks and spills can occur during removal or if these chemicals are not adequately removed from vehicles. These leaks or spills could impact soil or groundwater or be carried in stormwater to sewer or stormwater drains and discharged to surface water.
Storage Tanks
Waste fuels, fluids removed from vehicles, fresh oils, lubricants, and other chemicals used in equipment at auto recycling facilities may be stored in aboveground or underground storage tanks or reservoirs within on-site equipment. Leaks or spills during storage, loading, or unloading can contaminate soil, groundwater, or surface water. Releases to surface water may cause damage to natural resources or negatively impact local drinking water sources.
Component Removal & Hazardous Materials
Batteries, mercury switches, and airbag cartridges must all be removed from vehicles before dismantling or shredding. Batteries are toxic and corrosive and can easily ignite or explode. Lead and sulfuric acid can be released from batteries. Mishandling or breakage of mercury switches can result in the release of mercury. Airbag cartridges contain an explosive chemical, sodium azide, which can burn unprotected skin and severely irritate the lungs if inhaled, potentially injuring third parties. All of these materials must be appropriately handled and stored on-site, or releases could occur that damage the environment or injure third parties.
Chlorofluorocarbons
Chlorofluorocarbons may be present in motor vehicle air conditioners. It is illegal to vent or release these refrigerants into the environment, and an auto recycler can be fined for improper handling or release of these refrigerants.
Stormwater Run-off
Outdoor storage of vehicles or vehicle parts, such as tires, engine blocks, mufflers, chrome bumpers, batteries, and other parts, may occur at auto recycling facilities. Stormwater coming into contact may contain oil and grease, heavy metals, arsenic, and particulates. If contact is not minimized or stormwater is not properly managed, run-off from storage areas can impact soil, groundwater, or surface waters.
PFAS & Heavy Metals in Shredder Residue
Non-metal parts of vehicles, called auto fluff or shredder residue, have been found to contain petroleum hydrocarbons, mercury, lead, cadmium, chromium, arsenic, polyvinyl chloride, and PCBs. Also, more recently, auto shredder residue has been idenfied as a source of per-and polyfluoroalkyl substances (PFAS). If not properly stored, toxic substances within these materials may leach into surrounding soil and groundwater or stormwater. This residue may also be flammable and can catch fire, resulting in emissions of numerous air pollutants and polluted run-off.
Hazardous Waste Management
Auto recycling facilities handle many hazardous or regulated wastes, including shredder residue, batteries, mercury switches, waste fuels, waste fluids, etc. These facilities are often subject to hazardous waste generator requirements and must properly store, contain, label, and dispose of these materials; otherwise, they may receive regulatory fines. As generators, these facilities would retain “cradle to grave” liability for waste disposal at non-owned disposal sites.
Air Emissions
End-of-life vehicles may be shredded at an auto recycling facility. The pulverizing and shredding of scrap metal can generate particulates, volatile organic compounds (VOCs), hazardous air pollutant emissions, and nuisance odors. If emissions are not properly controlled, regulatory violations could be levied against the facility, and bodily injury claims could result.
Gas-Torch Operations & Explosion Risks
Some parts or vehicles may not be shredded but may be cut with gas torches. Gas-cutting torches involve the storage of flammable and explosive gases on-site. Gas tanks must be inspected, tested, and appropriately stored and handled. Fires related to these operations can produce toxic smoke and polluted run-off.
Tires
Tires removed from vehicles accepted at auto recycling facilities may be stockpiled on-site. Degrading tires releases plastic polymers that can migrate from stormwater to surface waters. Burning tires are very hard to extinguish and can impact the environment. Stockpiled tires are also an excellent breeding ground for mosquitoes and vermin, which can impact third parties.
Degreasing Equipment & Solvent Releases
Degreasing equipment may be used at auto recycling facilities to clean metal parts. Chlorinated solvents may be used or were used in the past. A release of solvents can migrate to and contaminate the environment.
Wastewater Management
Wastewater may be generated from vehicle washing, washing down floors, flushing radiators, and other operations at an auto recycling facility. These wastewaters may contain pollutants and must be appropriately stored, handled, and pretreated before discharge or off-site disposal. Mishandling, leaks, or wastewater spills can occur and impact the environment.
Accidental Spills During Transport
Leaks and spills can occur during the transport of new or used automotive fluids due to improper cargo securement, a loose valve, or vehicle upsets or overturn. Additionally, leaks or spills of automotive fluids can occur during the transport of vehicles to be processed. These releases could impact the environment or harm third parties.
Environmental Pollution Liability Can Provide Coverage For
On-site cleanup of new and pre-existing pollution conditions
Off -site cleanup of new and pre-existing pollution conditions
Both sudden and gradual pollution conditions
Third-party claims for bodily injury and property damage
Defense of third-party claims
Business interruption resulting from pollution conditions
Aboveground and underground storage tanks
First and third-party transportation pollution liability
Loading and unloading
Non-owned disposal sites
Products pollution
Crisis/reputation management
Illicit abandonment
Natural resource damage