Cleanup of Contaminated Areas

Aaron D. Green, Project Manager

Remediation Branch

IDEM’s Office of Land Quality

Key Topics of Discussion

• What are some of the potential contaminants associated with the auto salvage industry?

• How can these contaminants affect the environment?

• How can I prevent the release(s) of contaminants?

Key Topics of Discussion (continued)

• What do I do if there is a release of contaminants?

• Why should I be concerned if there is a release of contaminants?

Potential Contaminants Associated with the Auto Salvage Industry

• Fuels: Diesel and Gasoline

• Oils: Motor Oils, Differential Oils, Transmission Fluids, Brake Fluids, etc.

Potential Contaminants Associated with the Auto Salvage Industry

(continued)

• Other Potential Contaminants Include: Antifreeze, Windshield Washing Fluid, Refrigerants, Fluff from Crushing Activities, etc.

• Metals: Lead, Mercury, etc.

Environmental Media Potentially Affected by the Release of Contaminants

Potentially affected media include: 1) Surface Soils; 2) Subsurface Soils; 3) Groundwater; 4)

Surface Waters; 5) Sediments; and 6) Air

Spill PreventionI. Use designated vehicle staging areas for fluid

removal, parts removal, and vehicle crushing activities.

A. The staging area should at a minimum consist of a bermed impervious surface such as a concrete pad; and would preferably be covered.

B. These staging areas would reduce the migration of spilled fluids (contaminants) to the environment.

Spill Prevention (continued)

II. Ideally all automotive fluids should be removed from the vehicle at the staging area prior to storage or crushing activities. These collected fluids would then either be recycled or properly disposed.

III. All fluid storage areas should be structurally sound and would ideally have secondary containment.

Spill ResponseSpill Contingency Planning

I. Provide employee training

A. Educate your employees as to the importance of promptly addressing spills.

B. Educate your employees how to safely

and efficiently cleanups spills when spills

occur.

Spill ResponseSpill Contingency Planning (continued)

II. Provide spill response equipment (i.e. spill kit); which should include the minimum:

A. Oil absorbents - oil dry, absorbent pads, etc.

B. Shovels & brooms

C. Designated containers to contain spilled material and used absorbents.

Spill Cleanups

When a spill occurs:I. Immediately contain all fluids

using an absorbent material such as oil dry, kitty litter, or oil absorbent pads.

The material outlined in this section is intended to provide recommendations on how to properly and promptly respond to small volume spills as spills occur, and is intended to be specific to those type of spills which are commonly encountered during automotive repair or disassembly.

Spill CleanupsWhen a spill occurs (continued):

II. Immediately remove contaminated soils and as a precaution remove 6” to 8” of soil

beyond visible contamination.

III. Properly containerize and label all contaminated soils and used absorbent

material. This material should not contain free flowing liquids; if needed, use additional absorbent material to absorb free liquids.

Spill CleanupsWhen a spill occurs (continued):

IV. Properly dispose all contaminated soils and used absorbent materials.

A. Perform a waste determination to determine appropriate method of disposal.

B. Depending on the results of the waste determination properly dispose of material via:

1. A licensed chemical waste disposal contractor; or

2. Municipal landfill, provided you receive the landfill’s prior approval.

Spill Reporting

I. Spills that exceed reportable quantity. This will be chemical specific.

II. Spills to surface waters.

III. Spills which present a threat or have caused damage to human health and/or the environment.

IV. Spills for which a spill response has not been performed.

You are required to report spills to IDEM for:

Report Spills and Environmental Emergencies to

IDEM’s Spill Line1-888-233-7745

Available 24 hrs

Addressing Extensive Contamination/Long Term Cleanups

• There maybe instances in which you encounter extensive contamination which in most cases resulted from neglecting spills and not promptly performing spill cleanups; or in some instances the contamination may be associated with the illicit dumping of contaminants.

• In these instances long term cleanup/remediation maybe required.

• Pursuant to the Spill Rule (327 IAC 2.61) upon discovery of historical

contamination (i.e. “spill”) you are required to report the spill/historical contamination to IDEM.

– Remember “Any spill for which a spill response has not been done” is considered a reportable spill; and

– in most instances it will not be known whether the historical contamination resulted from a spill which exceeded the “reportable quantity” and is therefore required to reported.

– Failure to report historical contamination upon discovery can result in enforcement actions and civil penalties being assessed by IDEM.

What are my responsibilities as an owner/operator if I encounter historical contamination?

• Pursuant to IDEM’s authority under the:

– Spill Rule (327 IAC 2-6.1);

– Petroleum Releases Statute (IC 13-24-1); and/or

– Hazardous Substances Statute (IC 13-25-1)

the owner/operator of a facility which has had a release of contaminants (either recent or historical) is responsible for the cleanup efforts and can be held liable for damages associated with the release.

Historical Contamination (continued)

• Information on IDEM’s cleanup (remediation) requirements and

guidance can be found at:

http://www.in.gov/idem/land/remediation/

• Specific program areas within IDEM’s Remediation Branch which may be of specific interest to auto salvage facilities with extensive contamination:– Voluntary Remediation Program (VRP)

http://www.in.gov/idem/land/vrp/index.html

– Remedial Response Program

http://www.in.gov/idem/land/statecleanup/rrprogram.html

Historical Contamination (continued)

Why should you attempt to prevent spills and provide spill responses for

those spills which occur?

• Protect human health and the environment.

• Avoid possible enforcement actions being taken by local, state, and/or federal environmental regulatory agencies.

• Avoid costly remediation associated with neglected spills/releases.

• Protect your company’s investments and maintain property value.

Neglected Releases • These type of poor

management practices can lead to enforcement actions, civil penalties, and/or costly remediation efforts.

Remediation PhotosEnvironmental Testing

Remediation PhotosContaminated Soil Removal