Recycler - Plastic

Stormwater that comes in contact with stored stockpiles of plastics to be recycled, plastic resin pellets, and powder coloring for plastics can collect microplastic particles, including polypropylene, polyvinyl chloride, polyester, etc., and become contaminated. If the stormwater run-off is not properly controlled, contained, and pre-treated before discharge into sanitary or storm drainage systems, it could impact groundwater, surface water quality, and aquatic systems. Microplastics display nutritive algae that organisms up the food chain require.

Plastics have several toxic constituents, among which are phthalates, polyfluorinated chemicals, bisphenol A (BPA), brominated flame retardants, and antimony trioxide, which can leach out to have adverse effects on the environment and public health. Plastic recyclers sell to manufacturers that use their plastic to make new items. As part of the product supply chain, plastic recyclers could be drawn into product pollution suits and face the potential for liability and defense costs.

Accidental releases of plastic pellet products can occur during transportation or loading/unloading. Spilled plastic pellets can migrate into municipal sewers or waterways. Once in the environment, the pellets are persistent. They can be ingested and harm wildlife, leading to potential natural resource damage, cleanup liability, and third-party claims.

The chemicals used to break down waste plastics or the component chemicals created can leak or spill during use, storage, or loading/unloading. Releases can impact the environment at the site or migrate off-site in groundwater or stormwater. Cleanup, third-party claims, or natural resource damage claims can result.

Hazardous air emissions can be generated from various operations and equipment used at plastic recycling facilities. Particulate matter air emissions can be generated from material handling and finishing operations. Volatile organic compounds and hazardous air pollutant emissions can result from chemical processing or extrusion operations. Also, air emissions can emanate from boilers, vehicles, and powered equipment, such as forklifts, trucks, and cranes. Boilers and internal combustion vehicles are often powered by diesel or propane, which can emit carbon monoxide gas. Air emissions not properly controlled or exceeding permit limits can lead to violations or third-party injury claims.

Aboveground or underground storage tanks may store wastewater, products, gasoline, diesel fuel, lubricants, motor oils, coolants, hydraulic fluids, heating oils, or other chemicals at plastic recycling facilities. Spills or leaks of chemicals may occur during storage, during loading/unloading, during use, or from equipment. These releases can impact soil or groundwater, migrate to surface water bodies or drinking water sources, or impact indoor air through vapor intrusion.

Some chemicals and materials used, stored, or produced at plastics recycling facilities may be flammable and could cause a fire that spreads and releases other contained materials. A fire at a facility could emit toxic fumes and smoke from the materials stored or due to a mix of materials resulting from the fire. Firefighting solutions such as water or foam could create contaminated run-off that spreads to nearby storm drains or properties, resulting in environmental cleanup and tort liability.

Plastic containers that are recycled may have contained pesticides, chemicals, wastes, etc., in the past. The Federal Drug Administration (FDA) has identified a concern about recycling these containers. They have indicated that contaminants from the chemicals held may be present in recycled plastics. They also encouraged testing for possible surrogate contaminants to ensure they are not present in end-use consumer products. If present, consumers could be exposed to harmful contaminants, which may lead to product pollution liability suits against the recycler.