ECAR Fact Sheet for Michigan
Vehicle Crusher

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources
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The
following fact sheet was prepared by the ECAR Center staff. Once
prepared, each ECAR Center fact sheet undergoes a review process
with the applicable state environmental agency(ies). You can check
on the status of the review process here.
Please read the disclaimer on the status page. While we have tried
to present a summary of the essential information on this topic,
you should be aware that other items, such as local regulations,
may apply to you.
What You Need to Know
The
main environmental concerns in vehicle crushing operations is letting
any fluids still in the vehicle get away from
you and dealing with dust issues. If fluids are allowed to drain
into the soil, or to get into a drain where they are not supposed
to be, you could be in for trouble. And even if the fluids are contained
in the crushing area, you need to be sure they won't get washed
away by stormwater.
If
the fluids are hazardous wastes, special handling and disposal rules will apply to
them.
Regulations
There
are no environmental regulations that specifically govern the design
and operation of vehicle crushing operations. However, if vehicle
crushing is not performed properly, vehicle fluids will drain to
the soil, and excess dust gets into the air, which is prohibited.
Also, allowing vehicle fluids to be carried away by stormwater is
prohibited. Therefore, auto-recycling facilities should implement
the best management practices listed below to help prevent these
types of environmental violations from occurring at their vehicle
crushing operations.
Fluids
collected during oil crushing operations should be managed as hazardous waste unless a hazardous waste determination has been made
that proves that the fluids are non-hazardous. A hazardous waste
determination involves collecting samples of the fluid and having
the samples analyzed at a laboratory. Fluids that are not hazardous
waste are managed as liquid industrial waste in Michigan.
Facility
needs to determine if fugitive dust control is necessary. See
AQD information and guidance "Managing
Fugitive Dust: A Guide for Compliance with the Air Regulatory Requirements
for Particulate Matter Generation"
Links
to the Regulations. Use
the following links to view the regulations pertaining to hazardous
waste determinations and management.
Federal EPA Standards Applicable
to Generators of Hazardous Waste
Michigan’s Natural Resources and
Environmental Protection (Act 451), Part 121 regarding Liquid Industrial
Waste
Michigan’s Natural Resources and
Environmental Protection (Act 451), Part 111 regarding Hazardous
Waste Management and administrative rules
Michigan’s Natural Resources and
Environmental Protection (Act 451), Part 55 regarding Air Pollution
Control and administrative rules
Self-Audit
Checklist
When
an inspector comes to your facility, there are certain things he
or she checks to see if you are in compliance with environmental
regulations. It makes good sense for you to perform a "self-audit"
and catch and correct problems before they result in penalties.
Also, there are some compliance incentives associated with self-audits
(see Audit Policy Page).
Use
the following list to audit your vehicle crusher management procedures.
- Do
vehicle fluids escape to the soil from vehicle crushing operations?
Verify that the soil surrounding vehicle crushing operations
does not show signs of vehicle fluid spills. If there are signs
of fluid spills, such as stained soil or dead vegetation, then
remediation may be necessary.
- Are
fluids generated from vehicle crushing properly managed and
disposed of? Verify that fluids were properly managed and
disposed/recycled as hazardous waste or that a hazardous waste
determination was made that indicates it is a non-hazardous
waste. If the waste is non-hazardous, verify that it is properly
managed as liquid industrial waste.
- How
much dust is created by crushing and from loading, off-loading,
conveying, storage, transportation, or other site operations?Does facility have any required
air permit or dust control plan?
Best
Management Practices (BMPs)
Most regulations tell you what you have to do to be in compliance,
but they don’t explain how to do it. That’s where "best
management practices" come into play. BMPs are proven methods
that help you to get into compliance and stay there. The following
BMPs are recommended for vehicle crusher management procedures.
- Vehicles
should be adequately drained prior to crushing in order to minimize
the volume of waste fluids to manage. Fluids such as fuel, used
oil, transmission fluid, antifreeze, etc. should be stored in
separate containers that are clearly labeled.
- Vehicle
crushers should be situated on a bermed or self-contained impervious
surface, preferably under a roof and protected from the weather.
The floor surface should be sloped to contain fluids. Position
crushers toward the center of the surface or concrete pad rather
than along the edge.
- Mobile
crushers should always be situated on an impervious surface or
heavy duty plastic sheeting. Containers designed to be fitted
to the crusher can help capture fluids.
- Maintain
disposal receipts from mobile crusher operators for all wastes
generated and transported off-site for disposal.
For
dust control:
- Establish a speed limit for all vehicles using the area.
- Apply
water, spray-on adhesives, or synthetic/organic treatments to
potential dust area.
- Establish
a truck and wheel wash at the entrance/exit to the property.
- Provide an area of crushed
stone or gravel at the entrance/exit of the property to assist
in dislodging PM.
- Clean
up trackage and spillage from unpaved roads onto paved roads immediately.
- Turn
unpaved areas into paved areas where feasible.
- Develop
procedures & operating practices for timely review of housekeeping
activities to exposed or active surfaces.
Contacts
- For
more information, contact MDEQ’s Environmental Assistance Center
at 1-800-662-9278.
- For
reporting spills/releases and pollution emergencies, contact:
1-800-292-4706.
Related
ECAR Fact Sheets
- Hazardous
Wastes
Other
Relevant Resources
None.
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