Scrap Metal and Motor Vehicle Salvage Yards

This checklist highlights the major environmental requirements that apply to metal scrap facilities and automotive recycling facilities. This checklist is intended to help you determine whether you may have environmental compliance issues that need to be addressed, and to help you find the appropriate contact person in the regulatory community if you have questions. It does not, however, cover every possible requirement, and should not be used as your only source of information on environmental regulations. This checklist is a starting point to identify areas where you can improve compliance.

(1) Used Oil

Are you draining motor cores on a paved area with a roof, and using drip pans, trays or buckets to collect the oil and transfer it to storage?
Are your used oil storage containers in good condition? Do you keep them securely closed at all times?
Are your used oil storage containers clearly labeled with the words “USED OIL”?
Are your used oil storage containers kept in an area that has secondary containment (walls, dikes, or curbs) to catch potential spills or leaks?
Do you always clean up spills of oil when they occur, and do you have the appropriate equipment to do this with?
Do you have used oil shipped to an approved location for recycling or disposal?
Do you maintain records of the used oil you have recycled or disposed?
Have you checked with your used oil disposal company about whether hydraulic oils and other oils may be combined with the used motor oil?

If you answered “no” to any of the questions in this section, then you may have a compliance problem with regard to your handling of used oils. Please contact PADEP’s Southeast Regional Office (Waste Management or Water Management; see the telephone numbers in the contact list below) to discuss this issue.

(2) Oil Filters
If you remove used oil filters from salvage vehicles:

Is used oil properly removed from filters before they are recycled or disposed of?
Are you following EPA’s guidelines for hot draining oil filters?
Do you have used oil filters recycled as scrap metal?

For questions about the proper handling of used oil filters, please contact PADEP’s Waste Management Program (see telephone number in the contact list below).

(3) Antifreeze

Are your used antifreeze containers in good condition, and are they kept in an area that has secondary containment to catch potential spills or leaks?
Do you make sure that antifreeze is not mixed with other fluids?
Are containers of used antifreeze clearly labeled?
Do you send used antifreeze off-site for recycling or disposal?
Do you keep records of the used antifreeze that you send offsite for disposal?

If you answered “no” to any of the questions in this section, then you may have a compliance problem with regard to your handling of used antifreeze. Please contact PADEP’s Southeast Regional Office (Waste Management or Water Management; see telephone number in the contact list below) to discuss this issue.

(4) Hazardous Waste

Have you considered all of the waste materials that are generated at your business to determine whether they meet the regulatory definition of hazardous waste?
Do you have your waste evaluation information in your files?
If you ever generate hazardous waste, is it always sent to an EPA permitted disposal company or recycling company?
Are all hazardous wastes transported by a licensed hazardous waste transporter?
Do you know how much hazardous waste you generate in a month?
Do you know if you need a hazardous waste identification number?
Do you know if you are complying with all of the Pennsylvania hazardous waste generator requirements?

If you answered “no” to any of the questions in this section, then you may have a compliance problem with regard to the handling of hazardous wastes. Please contact PADEP’s Waste Management Program (see telephone number in the contact list below) to discuss this issue.

(5) Used Tires

Are used tires lying scattered around your facility instead of being neatly stacked?
Do you have more than 500 hundred tires stored outside and in the open?
Do you have more than 1,500 tires in enclosed storage?

If you answered “yes” to any of the questions in this section, then you may have a compliance problem with regard to your handling of scrap tires. Please contact PADEP’s Waste ManagementProgram (see telephone number in the contact list below) to discuss this issue.

(6) Lead-Acid Batteries

Are lead-acid automotive batteries stored on-site in a manner that will prevent leaks or spills?
Do you segregate cracked or leaking batteries and place them into a secure container?
Do you send lead acid batteries off-site to a recycling company, or to be disposed at a permitted facility?
Do you keep records of these shipments of batteries?

If you answered “no” to any of the questions in this section, then you may have a compliance problem with regard to the handling of automotive batteries. Please contact PADEP’s Waste Management Program (see telephone number in the contact list below) to discuss this issue.

(7) Wastewater Discharges

Do you have any floor drains or stormwater inlets on the property?
Do you steam-clean or pressure wash engines (or other vehicle parts) on your site?
Is there an oil-water separator on the property?
Does your wastewater flow outside onto the ground?
Do you ever put materials like oil, solvent, paints or chemicals into your drains?

If you answered “yes” to any of the questions in this section, then you may have a compliance problem with regard to the handling of wastewater. Please contact PADEP’s Water Management Program (see telephone number in the contact list below) to discuss this issue.

(8) Storm Water Permits

Do you have a storm water discharge permit from PADEP for your salvage yard?
Do you have a storm water pollution prevention plan?
Have you considered the impact that your operation may have on the pollution of nearby waterways, and are you taking steps to make sure that pollution does not run off your site?

If you answered “no” to any of the questions in this section, then you may have a compliance problem with regard to stormwater discharge permits. Please contact PADEP’s Water Management Program (see telephone number in the contact list below) to discuss this issue.

(9) Sites located next to a River or Creek

Does the property on which you operate have a creek or a river running through it, or along any of its borders?
Do you have any vehicle carcasses, piles of motor vehicle parts, or piles of other material located near the stream bank?
Is there less than ten feet of clear ground between the closest vehicle carcass or pile and the edge of the river bank?

If you answered “yes” to any of the questions in this section, then you may have a compliance problem with regard to potential pollution of waterways. Please contact PADEP’s Water Management Program (see telephone number in the contact list below) to discuss this issue.

(10) Storage Tanks

Are you aware of the registration requirements for aboveground storage tanks (ASTs) and underground storage tanks (USTs)?
Can you document that your storage tanks meet the appropriate technical requirements for spill and overfill prevention; leak detection; corrosion protection; and third-party inspections?

If you answered “no” to any of the questions in this section, then you may have a compliance problem with regard to storage tanks. Please contact PADEP’s Storage Tanks Program (see telephone number in the contact list below) to discuss this issue.

(11) Air Pollution Control

Do you have anything that has stacks, vents or dust collectors?
Do you have a paint spray booth or solvent degreasing tanks?
Do you do any autobody work, including surface preparation, sanding, priming, painting, touch-ups?
Do you have a boiler, furnace or space heater?
Do you have any processes that produce visible dust, smoke or odors?
Do you crush or shred vehicles?
Do you do any metal smelting at your business?

If you answered “yes” to any of the questions in the contact list below, you may need an air permit for these activities. Please contact the Source Registration Section of Air Management Services at (215) 685-7572.

(12) Mercury Switches

Are you aware that many vehicles have switches that contain hazardous metallic mercury?
Do you check vehicles that come into your yard for the possible presence of mercury-containing switches?

If you answered “no” to either of the questions in this section, then you should become aware of the hazards of mercury and the need for proper handling. Please contact PADEP’s Waste Management Program (see telephone number in the contact list below) to discuss this issue. You may also get reimbursed for switches by joining the Mercury Switch Removal Program by contacting the Pennsylvania Automotive Recycling Trade Society at 717-763-1777.

(13) Freon Recovery
If you remove air conditioner refrigerants from salvage vehicles:

Are your freon recovery technicians certified by U.S. EPA?
Do your technicians use U.S. EPA-approved refrigerant recovery equipment?
Do you recycle refrigerant on-site or send it to an approved reclamation facility?
Do you make sure that refrigerants are not vented into the air?

If you answered “no” to any of the questions in this section, then you may be violating federal regulations on the handling of CFCs. For information on how to comply with the regulations, please contact Dick Eaton of EPA, Region 3, at 304-234-0265.

A list of some agency contacts and their phone numbers:
PA Department of Environmental Protection (PADEP)       484-250-5900 (main number)
            Water Management                                                       484-250-5970
            Waste Management                                                      484-250-5960
            Storage Tanks Program                                               484-250-5960
City of Philadelphia Air Management Services                    215-685-7572

City of Philadelphia L and I – C&I Fire Unit 215-685-3712

Complaints 215-686-2463

City of Philadelphia Water Department 215-685-4948

U.S. Environmental Protection Agency - 215-814-5141

Business Assistance Center or 800-228-8711