Recycler - Scrap Metal

Waste fuels and fluids removed from vehicles and fresh oils, lubricants, hydraulic fluids, and other chemicals used in on-site equipment may be stored in aboveground or underground storage tanks, reservoirs within on-site equipment, or containers. Leaks or spills during storage, loading, or unloading can contaminate soil, groundwater, or surface water. Reactions between incompatible materials can result in toxic fumes, fires, or explosions, potentially injuring third parties.

Chlorofluorocarbons and other refrigerants may be present in vehicles, air conditioners, refrigerators, and other equipment received at a scrap metal recycling facility. As greenhouse gases, it is illegal to vent or release these refrigerants into the environment, and a recycler can be fined for improper handling or release of these refrigerants.

Fire hazards exist from metal cutting processes, combustible or explosive components in recycled materials, and processing operations at scrap metal recycling facilities. Flammable and explosive gases may also be stored on-site for cutting metals. Gas tanks must be inspected, tested, and appropriately stored and handled. Fires related to these operations can produce toxic smoke and polluted run-off.

Metals brought to the facility could be radioactive. Radioactive metal scrap may come from oil and gas operations, military applications, discarded medical equipment, building or storage material from nuclear power plants, or smoke detectors (which can contain trace amounts of Americium). If not properly identified and removed from the scrap metal stream, they can cause contamination at the recycler’s facility, impact downstream processing or smelter facilities, or harm third parties.

Outdoor stockpiles of scrap can undergo weathering. Scrap metals may contain a variety of heavy metal constituents, and coatings, non-metal parts, lubricants, degreasers, paints, and other contaminants may be present in these materials. Weathering of these materials may occur, and pollutants, including heavy metals, PCBs, oil and grease, particulates, etc., can leach into soil and groundwater. Suppose stormwater comes into contact with stockpiles of scrap, and it is not properly controlled, contained, or pre-treated before discharge. In that case, it can carry pollutants to sanitary systems and storm drains or discharge directly into surface waters, potentially harming natural resources. Stormwater discharges from scrap metal facilities are regulated, and exceedances of discharge criteria can also result in regulatory violations and fines.

Processes such as cleaning, plasma, torch cutting, baling, compaction, crushing, hydraulic shearing, or shredding produce small particulates, shavings, and fumes. When metals are ground, blasted, roasted, or melted, toxic fumes or metal dust are produced and distributed in the air. High temperatures from melting metal, organic material, and chlorine can produce dioxins that attach to dust particles. Chemical processes such as high-temperature chlorination, electrorefining, plating, leaching, chemical separation, and dissolution may also produce hazardous emissions of metal fumes and vapors, organic vapors, and acid gases. If air emissions are not properly controlled, regulatory violations and fines could be levied against the company, and third parties could be injured.

Scrap metal recycling facilities handle many hazardous or regulated wastes, including 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 be subject to regulatory violations and fines. As generators, these facilities would retain “cradle-to-grave” liability for the waste they dispose of at non-owned disposal sites.

Chemicals used and wastes generated by scrap metal facilities and the scrap metals themselves may be transported by or on behalf of these facilities. During transportation, loading, and unloading, leaks and spills could occur due to improper cargo securement, a loose valve, or vehicle upsets or overturns. These leaks or spills can result in environmental liability for the scrap metal facility.