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Home My WebLink About20050911.tiff BOARD OF COUNTY COMMISSIONERS' SIGN POSTING CERTIFICATE THE LAST DAY TO POST THE SIGN IS 3 I Zo'b .i THE SIGN SHALL BE POSTED ADJACENT TO AND VISIBLE FROM A PUBLICALLY MAINTAINED ROAD RIGHT- OF-WAY. IN THE EVENT THE PROPERTY BEING CONSIDERED FOR A SPECIAL REVIEW IS NOT ADJACENT TO A PUBLICALLY MAINTAINED ROAD RIGHT-OF-WAY, THE DEPARTMENT OF PLANNING SERVICES SHALL POST ONE SIGN IN THE MOST PROMINENT PLACE ON THE PROPERTY AND POST A SECOND SIGN AT THE POINT AT WHICH THE DRIVEWAY (ACCESS DRIVE) INTERSECTS A PUBLICALLY MAINTAINED ROAD RIGHT-OF-WAY. I, Jacqueline Hatch, HEREBY CERTIFY UNDERyale,LTIES OF PERJURY THAT THE SIGN WAS POSTED ON THE PROPERTY AT LEAS TF irTr.EN DAYS BEFORE THE BOARD OF COMMISSIONERS HEARING FOR LiS < - I `/93 IN THE AGRICULTURAL ZONE DISTRICT. (Q.Afc frit / 64-rz-l-/- Jacqueline Hatch Signature of Person Posting Sign STATE OF COLORADO ) ss. COUNTY OF WELD The foregoing instrument was subscribed an. • • to me this :LO day of t 1 IL,rI t A 1 , 2005. WITNESS my hand and official seal. ar,edit 1�NY FV�,'t ' s r lETNANT S, * 1M SA 'r, ,k SAL"' ;o N'tary -ublic .."itt s C My Commission Expires: C It_f L Lii:j44,4zitr;,,i-i!"4 tr. FS i1 Q05 ` 041 / " '''"" 517.1:7—<, c.a °, t..,:,.. i " % Rik ACtwz_... A' _.', -" .�..wt,..,.... w 'PUBLIC. s' 1 ; CONCERNING '-.�" _- __ . � "'' T$IS PROPE; l BE NELD AT �.. • Yt' '.'1"*";,...!. ''. 1 �Y."•-.W_ ;i0....... : 10tG 'r--47.w.. 41: •. . TTT M1 Av• s h 7• ctt , i.vi • i O, w",,,, •,.,,,- CI! , x 4 I-• { 1 ,w. 4 Ii `� """�.`.,' NT OF ��.. . a � , }� - ,. a- `. . ti ' 'u' Cdr `� " - 4' 4' .,. SAT I h , % zrr,� ,may l n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . •. •. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I t . irr l , a ,APp , i / �1 , r r r . i \ I r , I �� i ! I : , ,; I, . I (v x "f r- 1 ,r4-'4,' 5 .� fir ;. ,Ar 11/4 WO ryl 4f, 4 It o,t/ l � EXHIBIT I F use 4,493 i .., -_.;4hyw v:4.1 _. a t_y lt. 1 • 7 i Q .,),.. .l i� I A • 4 ' x { -, .µ3ist • .-4.,'.4 Y a, ,y.. r ta.K Y ktr • -r+•.1, ."It }. , 99 y }S T ..A o :^`a` 4—� ..yn. 5 � s➢ v M11G+cC�Y� rM ,. � ..�y�_�,-"��. ° try *t * .4, t < w'S�ZIa'3. ;"J. yS5.A ys�•}+_�I.3 ♦' b T3�F: � .... . - • t 1 5+y 1 • V is a h • ..3,i - y ll h . 4 —., ,it-h, A:OVI7� k,',.4"4 n,, �tj .. �.,; " f - ....4%,.,4 ► S. t5 Ati Y1ter__.. 4Tàj/ . .. . ors ENVIRONMENTAL IMPACTS OF AUTO SALVAGE FACILITIES AND THEIR REGULATION November 2000 Andrew A. Dzurik, Ph.D., P.E. Florida State University State University System of Florida Florida Center for Solid and Hazardous Waste Management University of Florida 2207-D NW 1311 Street Gainesville, FL 32609 www.floridacenter.org Report#00-II t _ E, P State University System of Florida Florida Center for Solid and Hazardous Waste Management PROJECT SUMMARY trfOrTI '1MYETTTAiLIMPACT1413 "ALTro SA VMIE FACT TIES 'AND THEIR N PYcrSCUM', tt4VBSTKGATORS: Attthe A: Dzfg FAMU-FSU College of Engineering TABLE OF CONTENTS 1. INTRODUCTION 1 Objective#1 2 Objective#2 3 Objective#3 3 2. AUTOMOBILE SALVAGE YARD OPERATIONS 3 3. STATE REGULATIONS AND STANDARDS 4 A. Groundwater Clean-up Target Levels 5 B. Natural Attenuation Default Source Concentration 6 C. Soil Clean-up Target Levels 7 D. Leachability-Based Soil Clean-up Target Levels 8 4. REVIEW OF PUBLIC RECORDS 8 5. FACTORS AFFECTING ENVIRONMENTAL CONTAMINATION 12 A. Fate and Transport of Contaminants 12 B. Mobility 14 C. Geology 16 6. SOIL ANALYTICAL RESULTS 19 A. Organic Compounds 19 B. Metals 25 7. GROUNDWATER ANALYTICAL RESULTS 28 A. Organic Compounds 28 B. Metals 33 8. SOUTHEASTERN STATES SALVAGE YARD REGULATIONS 37 9. CONCLUSION 38 REFERENCES 45 APPENDICES 48 A. Pollution Prevention Practices -Louisiana -Arkansas -North Carolina -Automotive Recyclers Association -Broward County B. Figures C. FDEP: Best Management Practices for Auto Salvage Yards LIST OF TABLES Table I-Summary of Automobile Salvage Facilities Evaluated 9 Table 2- VOCs Which Exceeded FDEP Soil Cleanup Target Levels (Industrial or Residential) and Leachability Standards 20 Table 3- Semi-Volatiles Which Exceeded FDEP Soil Cleanup Target Levels (Industrial or Residential) and Leachability Standards 22 Table 4-Number of Samples that Exceeded FDEP Soil Cleanup Target Levels (Industrial and Residential) and Leachability Standards for TRPH 23 Table 5- Number of Samples that Exceeded FDEP Soil Cleanup Target Levels (Industrial or Residential) and Leachability Standards for Lead 25 Table 6-Number of Samples that Exceeded FDEP Soil Cleanup Target Levels Levels (Industrial or Residential) and Leachability Standards for Arsenic 28 Table 7- VOCs Which Exceeded FDEP Groundwater Cleanup Target Levels and Natural Attenuation Standards 30 Table 8- Binary Equilibrium of Solubilities of Certain Components of Gasoline in Water(25° C) 30 Table 9- Semi-Volatiles Which Exceeded FDEP Groundwater Cleanup Target Levels and Natural Attenuation Standards 32 Table 10-Number of Samples that Exceeded FDEP Groundwater Cleanup Target Levels or Natural Attenuation Standards for TRPH 33 Table II-Number of Samples that Exceeded FDEP Groundwater Cleanup Target Levels or Natural Attenuation Standards for Lead 34 Table 12-Number of Samples that Exceeded FDEP Groundwater Cleanup Target Levels or Natural Attenuation Standards for Chromium 34 Table 13-Number of Samples that Exceeded FDEP Groundwater Cleanup Target Levels or Natural Attenuation Standards for Cadmium 35 Table 14-Number of Samples that Exceeded FDEP Groundwater Cleanup Target Levels or Natural Attenuation Standards for Arsenic 36 Table 15- Some Known Health Effects Upon Exposure to Specific Contaminants 43 LIST OF FIGURES Figure 1-Average TRPH Soil Concentrations Relating to Specific Dismantling, Crushing and Storage Practices APP B Figure 2-Average Lead Soil Concentrations Relating to Specific Dismantling, Crushing and Storage Practices APP B Figure 3-Average Arsenic Soil Concentrations Relating to Specific Dismantling, Crushing and Storage Practices APP B Figure 4-Average TCLP Lead Soil Concentrations Relating to Specific Dismantling, Crushing and Storage Practices APP B Figure 5-Average Benzene Soil Concentrations Relating to Specific Dismantling, Crushing and Storage Practices APP B Figure 6-Average Toluene Soil Concentrations Relating to Specific Dismantling, Crushing and Storage Practices APP B Figure 7-Average Ethylbenzene Soil Concentrations Relating to Specific Dismantling, Crushing and Storage Practices APP B Figure 8-Average Naphthalene Soil Concentrations Relating to Specific Dismantling, Crushing and Storage Practices APP B Figure 9-Average Xylene Soil Concentrations Relating to Specific Dismantling, Crushing and Storage Practices APP B Figure 10-Average Soil Concentrations within Dismantling, Crushing and Storage Areas vs. Target Levels and Leachability Standards APP B Figure 11-Average Soil Concentrations within Dismantling, Crushing and Storage Areas vs. Target Levels and Leachability Standards APP B Figure I2-Average Soil Concentrations at Various Depths within Dismantling, Crushing and Storage Areas APP B Figure I3-Average Benzene Soil Concentrations within Dismantling, Crushing and Storage Areas vs. Target Levels and Leachability Standards APP B Figure 14-Average TRPH Soil Concentrations within Dismantling, Crushing and Storage Areas vs. Target Levels and Leachability Standards APP B Figure 15-Average Arsenic Soil Concentrations within Dismantling, Crushing and Storage Areas vs. Target Levels and Leachability Standards APP B Figure 16-Average Lead Soil Concentrations within Dismantling, Crushing and Storage Areas vs. Target Levels and Leachability Standards APP B Figure 17-Average TCLP Lead Lead Soil Concentrations within Dismantling, Crushing and Storage Areas vs. RCRA Regulatory Level APP B Figure I8-Average Groundwater Concentrations within Dismantling, Crushing and Storage Areas vs. Target Levels and Natural Attenuation Standards APP B Figure I9-Average Groundwater Concentrations within Dismantling, Crushing and Storage Areas vs. Target Levels and Natural Attenuation Standards APP B Figure 20-Average TRPH Groundwater Concentrations within Dismantling, Crushing and Storage Areas vs. Target Levels and Natural Attenuation Standards for TRPH APP B Figure 21-Average Lead Groundwater Concentrations within Dismantling, iii Crushing and Storage Areas vs. Target Levels and Natural Attenuation Standards for Lead APP B Figure 22-Average Benzene Groundwater Concentrations within Dismantling, Crushing and Storage Areas vs. Target Levels and Natural Attenuation Standards for Benzene APP B Figure 23-Average Benzene Groundwater Concentrations within Dismantling, Crushing and Storage Practices APP B Figure 24-Average Naphthalene Groundwater Concentrations within Dismantling, Crushing and Storage Practices APP B Figure 25-Average Lead Groundwater Concentrations within Dismantling, Crushing and Storage Practices APP B Figure 26-Average MTBE Groundwater Concentrations within Dismantling, Crushing and Storage Practices APP B Figure 27-Average Cadmium Groundwater Concentrations within Dismantling, Crushing and Storage Practices APP B Figure 28-Average Chromium Groundwater Concentrations within Dismantling, Crushing and Storage Practices APP B r iv ACRONYMS AND ABBREVIATIONS AJGUAP All Japanese-German Used Auto Parts ARCO Atlantic Richfield Corporation BDL Below Detection Limit BPSS Bureau of Petroleum Storage Systems CAP Contamination Assessment Plan CAR Contamination Assessment Report CARA Contamination Assessment Report Addendum DERM Department of Environmental Resources Management ECD Engineering Concepts in Design, Inc. Eh Negative Oxidation/Reduction Potential EPC Environmental Protection Commission EP Extraction Procedure EPA Environmental Protection Agency ERC Environmental Regulatory Compliance, Inc. ETG Environmental Technologies Group, Inc. FAC Florida Administrative Code FDEP Florida Department of Environmental Protection FDER Florida Department of Environmental Regulation FLO-PRO Florida Residual Petroleum Organic Method FS Florida Statutes GC Gas Chromatography Hg Mercury HHWCC Household Hazardous Waste Collection Center HPLC High Performance Liquid Chromatography IRA Initial Remedial Action IRAP Initial Remedial Action Plan IRIS Integrated Risk Information System LPCAR Limited Preliminary Contamination Assessment Report MCPHU Martin County Public Health Unit mg/kg Milligrams per Kilograms mg/L Milligrams per Liter MTBE Methyl Tertiary Butyl Ether MS Mass Spectrometry MW Monitoring Well NAB National Ambulance Builders OVA Organic Vapor Analyzer PCAP Preliminary Contamination Assessment Plan PCAR Preliminary Contamination Assessment Report ppm Parts Per Million PG Professional Geologist PZ Piezometer RAP Remedial Action Plan V RCRA Resource Conservation and Recovery Act SB Soil Boring SS Sediment Samples SW Surface Water TCLP Toxicity Characteristic Leaching Procedure TRPH Total Recoverable Petroleum Hydrocarbons ug/kg Micrograms per Kilogram ug/L Micrograms per Liter UES Universal Engineering Sciences USEPA United States Environmental Protection Agency VOCs Volatile Organic Compounds r-. vi Key Words: salvage yard,junkyard, automobile recycling facility, soil contamination, groundwater contamination, best management practices ABSTRACT Automobile salvage facilities in the United States serve as home to items of great recycling value such as junked automobiles and other scrap metal-generating equipment. Ma> o1.14C.e faciht>;c§,areM1si 54,.clicectly cathrlamicsa..,f. .:_. _: �r� piottA.Aiit paint. ..g anderticath. .7ftese sites are potential soureestoferrvireterteresi-nortcem, eniseeiedirreteted-toneesoil.su gftuaxlw.ltercoalaali^ beet. To date, in Florida and other southeastern states, these facilities have had few regulatory controls placed upon them. As a result of this, potential contamination can arise from the wide range of hazardous materials that comprise junked automobiles. A record review indicates that the majority of automobile salvage yards in Florida do not take the necessary precautions to protect soil and groundwater. ritid and b.uulldwatei d9fI minatl?lrrtttai.te.specific.dicuaantling,gCusiiuugaad,sto age,practices at automobile salvage, yard, i3 detailed * y. r Since groundwater analytical data from assessment activities indicated contamination/ihrisessibiestiseSpe4twel4e4wireenternieminegAtserneleraLs. Ingestion et d.;t Ertl contact with Eft.. coritutlnilaty l'saki and foil ii.C.)irOeult-nar wasure, to earcinagenir anti msitagroiS ccopouads. Automobile salvage yard owners and operators must minimize or eliminate these discharges to protect human health and the environment. To ensure and promote environmental compliance, FDEP has prepared and provided a document entitled Best Management Practices for Automobile Salvage Yards. vii EXECUTIVE SUMMARY In January 1999, various state and county environmental regulatory agencies throughout Florida were visited to determine current and past environmental compliance at automobile salvage yards. To assist in this environmental evaluation of the automobile salvage industry, records detailing recent site inspections and remedial actions were obtained from each office. In March 1999, records were obtained detailing site inspections and remedial actions within Dade County and compliance evaluation inspections were obtained for Northwest Florida. This report details findings regarding the extent and nature of soil and groundwater contamination at automobile salvage yards. A record review and site inspections revealed a wide range of recycling and salvaging practices which determined the environmental conditions at each facility. Some automobile salvage yards are committed to protecting the environment. Their practices appear to have a minimal or no deleterious effect on human health or the environment. Unforttulately,the majority of automobile salvageyards are contaminating -. ..sod-antlintamdwater. Consequently, these facilities need to improve certain practices to eliminate or minimize the release of contaminants to the environment.-4mpre red:.., practices inctude'changing-the manner irrwhich used oil, waste antifreeze, gasoline, petroleum products and hazardous substances are removed from automobiles and stored of-site. ^ With some exceptions, most amt aVrV ttble'tiF5ktd.swsef used oil and/or t tttok u„t ptedttelsrnu the-mound. Soil contamination at automobile salvage yards is usually localized. Impacted operational areas include areas used for dismantling and crushing automobiles, usable parts storage and automotive fluid storage. SIMtrattterselaiknetiragekw*have Contaminants which exceeded Florida Department of Environmental Protection (FDEP) soil or groundwater clean-up target levels or other standards include han,.toluerke, ethy It,cttzcnc, xylcnes,naplu(alexte„l,,2,q,Irimeshylleena. };3 fi'ttit,,.,tlty1Sonaci e, beetze("dJGi` ttitte;Ytretity.kortiasy.butylether(11EnF4i,„totcl reoeverabter tteleum hydrocar'bbnsal rin tadtt,.w„r, . Groundwater contamination relates to soil type, soil composition and depth to groundwater. Since sandy soil is prevalent in Florida and groundwater is relatively close to the surface in most areas, it is very likely that significant discharges of used oil, waste antifreeze, gasoline and petroleum products are impacting groundwater. The extent of contamination at automobile salvage yards also relates to the level of activity, years in operation, historical land uses and amount of visual staining observed. Automobile salvage yards with soil and groundwater contamination are currently undergoing or have completed site remediation in accordance with state and local requirements. Unfortunately, the majority of automobile salvage yards requiring cleanup do not have the financial resources available to conduct assessments and remediation. viii Since soil and groundwater data indicate environmental contamination, automobile salvage yards need to minimize or eliminate discharges of used oil, waste antifreeze, gasoline and petroleum products on the ground. The best method to encourage improved practices is to provide training and technical assistance in proper waste management procedures and environmental rules and regulations. FDEP has prepared a document entitled Best Management Practices for Automobile Salvage Yards to assist in training efforts. ix Title: ENVIRONMENTAL IMPACTS OF AUTO SALVAGE FACILITIES AND THEIR REGULATION I. INTRODUCTION AND OBJECTIVES Automobile salvage facilities in the United States have formed an integral part of the landscape, covering large land areas and having wide distribution throughout both rural and urban environments. Many of these facilities are sited directly on the land's surface without any protective paving underneath. As potential sources of environmental concern, especially related to surface soil, subsurface soil, surface water, sediment and groundwater contamination, salvage yards have in the past and will continue to be in the future, a major target of regulatory control and involvement. For many years these types of facilities have stored and stockpiled items of great recycling value such as junked automobiles and other scrap metal- generating equipment. Tn date se facilities have lagd few rewwtatery u,,,t,u6 Wtaced uponthem....Aseasseeuk.caL,this;potenh sicoaninntian can m ise front the wide ranbc-of mae.'oL y , ,.petrnleum.pitaduets,such garicF- as tint; diese ei melecsib j..power.steering fluid,-and-brake-Bind; en iateeeMentsand additiv3wchlorefluoru carbons(EFespfiomaireenditiouirg systems metolssechairow<chromium...lead,copper,andtlantinitun battery.aci& joke arid-chutctt tirmtt,.,;• .u+ereuy switches;.plastics, 6.: ami'othtrtnateika6. Potential sources of environmental contamination from automobile salvage facilities usually do not consist exclusively of scrapped automobiles. Often a variety of waste products such as scrap metal, fluids from heavy electrical equipment(motors, transformers, and capacitors)that could contain polychlorinated biphenyls (PCBs), appliances, heating and air conditioning systems, hot water tanks, and other heavy waste materials can be found in salvage yards. The.effect of stormwater-remeff from Neese.wilissiesdingdoatiftitratiewintawitc surface soil, culwatrface.soils and ultimately to groundwater is- primary-enrironmenttal concern from these facilities. ka....11:..srepillinworetwiesiereerttreseirmterialir canpotentiattreattsenottreocilaMiaeneketheritimertienitemtiategials.todrelckaStAt,nio thaair,-groundwater,surface water;rAd mentS ap,Clsites[1its. The regulatory effort aimed at these types of potential contamination needs to be concentrated and practiced throughout the State of Florida. This requires the involvement of the Florida Department of Environmental Protection (FDEP), the Water Management Districts, and the local and municipal environmental regulatory and planning boards. Since only certain agencies provide environmental regulation of these facilities(e.g., Broward County Department of Natural Resources), the need for consistently regulating these facilities statewide is urgent. One of the major difficulties in the regulation of automobile salvage yards is the fact that these facilities operate in widely different manners. There have been differences in the type of scrap materials accepted, recycling options employed, the use of Best r Management Practices (BMPs) to minimize the threat of potential spills to the environment and general disposal practices used. This in turn, shows the need to categorize and group these facilities and provide a means for the regulatory agencies to make an informed decision using engineering judgment when deciding sampling strategies, improvement of operating practices and the magnitude of the environmental liability associated with these facilities. As an outgrowth of this research, these facilities can be provided with regulatory compliance and pollution prevention strategies to ensure that their facilities minimize the threat of fines from the agencies. Additionally, lkr .firilllies c p be anned of the ` potenii l c $ost savings minimizing tr=�*soot and.dicpncal 'Mere is also the concern that these facilities could, only in extreme cases, become listed on the Comprehensive Environmental Response, Compensation and Liability Act's (CERCLA) National Priorities List of"Superfund" sites. It would be a benefit to extend this research to identify sites that have the greatest possibility of being listed as Superfund sites, so they can begin the process of full-scale assessment of their site. The project's overall goal is to determine if automobile salvage yards cause contamination, the typical contaminants of concern found, and the media affected (surface soil, subsurface soil, surface water, sediment, and groundwater). The objectives of the project are to: 1. rm Ide crunnettertrTritirinmcimameambeivitereerffrfrartgabage,, 2. Investigate and determine how other states regulate these facilities; and 3. Provide a BMP manual to aid automobile salvage and recycling facilities in minimizing their effects on the environment. The paragraphs below will convey the rationale used in accomplishing each objective. Objective# I Many factors contribute to the sensitivity of Florida's environment. They include: (I) the majority of potable water used in Florida is from groundwater sources, (2) the upper zone of the shallow aquifer is mainly under water table conditions, (3) the depth to groundwater from below land surface is small, and (4)the nature of the sandy soil and karst topography characterize most of the subsurface of Florida. These unique properties taken in combination contribute to the highly sensitive nature of the environment and present ease for chemicals to move quickly and potentially cause excessive groundwater contamination. 'tut tnitomobil ..l.l.ab..;_'d re'syelmg i ;CI a itV nVt'liart }ALL', armammia in thetiefklittstirdettltirlMtten-verwitiMgAimirAiiimmiak This objective is concerned with determining the characteristics of these materials, their chemical partitioning into separate, distinct phases, the specific fraction that would likely remain in the air, non- aqueous and adsorbed phase, and the fate and transport of these contaminants when released into the environment. 2 !", Objective#2 This objective will determine: (a) how the salvage industry in other southeastern states provide compliance with state regulations; (b) if they implement waste minimization and pollution prevention programs; and (c) the relationship between the facilities, the regulatory agencies and the community. Objective# 3 One of the most useful ways for owners and operators of automobile salvage and recycling facilities to begin thinking about the impacts of hazardous discharges of their operation on human health and the environment is to provide a manual that instructs them in the major ways they can prevent these hazardous constituents from entering the environment. This objective will be to provide a BMP Manual to help salvage yard owners and operators minimize the threat of environmental contamination from their facilities. II. AUTOMOBILE SALVAGE YARD OPERATIONS Automobile salvage yards conduct a wide range of recycling and salvaging practices that determine the environmental conditions at each yard. il...ycht.b a v i mpact environmental qua,�}(,j'04ierepe€s:,,;Ristication evhibtted.by an individual .fllyage.yarSliavma effeettsritstsreiretiowatal itditi_ons. Whosiss-sinikaassakas.isoperalakatompbile.reaches a welhoperate4-autemobile salvage"faeiii , it is imnialiattly dmined-of autemutive•flwidcoctakendirectlyt9 the yase.fer storage.=The draining of automotive fluids into containers or other storage devices minimizes or eliminates the release of fluids to the ground. LInferti.t.sowe avhit impacts.tha,eairotanent. Draining may involve the puncture or suction pumping of gas tanks, puncture or gravity drainage of fuel or other hydraulic lines and radiators, plug removal and subsequent drainage of oil pans and engines, and suction pumping of other components which hold automotive fluids. Lifts, racks,jacks, inoperable automobiles and other devices may be used to accomplish draining. Drainage occurs over bare ground or on concrete pads, indoors or outdoors. Drained automotive fluids are reused, recycled or properly or improperly disposed of. Samaasiiiiiaimitiwitet.orteitraiLateetetesestirefietitt Consequently, they are left in the automobile during crushing and disposed to the ground. The level of dismantling varies at each facility. At the majority of salvage yards, usable parts are not removed from the automobile until needed. Facility personnel or customers remove parts. Some facilities immediately dismantle automobiles upon arrival at the facility. Parts are usually tagged, separated, inventoried on paper or computer and stored. Parts are stored on bare ground, racks, concrete slabs, shelves or other structures. Storage is done indoors or outdoors. Dismantling operations are accomplished within a central area or building or throughout the salvage yard. Dismantling may occur over bare 3 ground or on bermed or unbermed concrete pads. Some facilities discharge automotive fluids on the ground from unbermed concrete pads. Since used automotive parts can be greasy, grimy or oily, soil contamination is a common problem for salvage yards that store parts on bare ground. Parts that contribute to soil and groundwater contamination include engine blocks, transmissions, axles and gas tanks. Lead-acid batteries removed during dismantling can affect environmental conditions when stored on bare ground. Automobile crushing is necessary to remove automobiles that have no economic value to the salvage yard owner or operator. Salvage yards use a variety of methods to crush unwanted automobiles. eraailctte altos, aatagasaatevetertrustrerr two-king balls, forklifts and Otlai., a iivy ccluiliilltfittwith permanent crushers, unwanted automobiles can be crushed on a continual basis. 4.14e sore on a concrete grarftged solely fui eYgshinge accomplished with spill control and secondary containment measures (drip pans, catchment basins, absorbents and other environmental control systems) in place. Some permanent crushers are installed with built-in fluid collection systems. Residues or fluids collected during crushing are containerized and shipped of site for proper disposal. Siima lad litics.sluaRl1tro(.At•3dtciXexu.*tieanff n£5luids afil9meOreporlyvaawileisisasycleaarradiersailertnithingalixiiiks. iclvage fsuililics'fitai'trintrnet-wi444 e4taecteshersererstrawiytimtad o .tmm�l+".lec,nnau..as-uee.dedtaiiiisr-Teissirett where crushing.oeeni,inu ally voriuc with even4.$or ti ii,ob -orris ersysuth ovcr bare gmtnitt with itb etWitonttteut442unt'2t i^pi9ce.S4.,Pr t�i,l.�e,_�d�{i,s�c,,h�.�?t Gta_utnmotive..%sicv to the grow=P"Tiw nttnt of c iitairdnatiarr from` ushing,uctivitie,s in rac.-- wham --taterfretirkfrareivefreaise4. Other mobile crushers crush over bare ground with environmental controls (earthen berms with synthetic tarpaulins and manufactured catchment basins) in place. Contaminated soils generated from crushing are either properly disposed of at off-site landfills or hazardous waste facilities or placed in crushed automobiles for improper disposal. Soma '=ltortlnbJ.lg, e g • ct ysiz. 3;Iiietrattoplitgtratterftteltiod-of ei usliingantonuibttcs iiivolces the Ust of bat, kl;fl,, t,t-tm,a b.; tunnirrg the using These %y.,,.,Ldarc5 itypitattyYfo not train fluids pcilu'_t9,Environmental contamination is most likely to be present in dismantling and crushing areas. These areas may involve the improper handling or disposal of automotive fluids to the ground. ieeuat thttt�remaining in or witWarnntart efs d,partsare a III. STATE REGULATIONS AND STANDARDS To determine if discharges of used oil, waste antifreeze, gasoline and petroleum products are impacting soil and groundwater resources at automobile salvage yards, 4 contaminants indicated within the laboratory data must be compared to rules, standards or target levels. The rules, standards or target levels are based on direct human exposure. FDEP has developed risked-based clean-up target levels for chemicals of concern found in soil and groundwater. Soil and groundwater target levels or standards are found in the following rules: • Chapter 62-770, Florida Administrative Code (F.A.C.)- Petroleum Contamination Site Cleanup Criteria. Chapter 62-770, F.A.C. applies to any cleanup of a site contaminated with petroleum or petroleum products. This chapter was amended September23, 1997 • Chapter 62-785, F.A.C.- Brownfields Cleanup Criteria. Chapter 62-785 applies to any cleanup of a brownfields site or sites within a designated brownfields area. This chapter became effective July 6, 1998. • Chapter 62-777, F.A.C.-Contaminant Cleanup Target Levels. Chapter 62-777 is currently being proposed. It will address the cleanup of contamination and specifically reference Chapter 62-713, F.A.C (Soil Treatment Facilities), Chapter 62- 770, F.A.C. (Petroleum Contamination Site Cleanup Criteria), Chapter 62-782, F.A.C. (Dry- cleaning Solvent Cleanup Criteria)and Chapter 62-785, F.A.C (Brownfields Cleanup Criteria). Although not every contaminated site has been designated as a brownfields site, FDEP uses the soil and groundwater target levels found in Chapter 62-785, F.A.C. to determine if cleanup is required. Chapter 62-785, F.A.C. has incorporated numerical standards promulgated in Chapters 62-520, F.A.C. (Groundwater Classes, Standards and Exemptions, Chapter 62-550, F.A.C. (Drinking Water Standards, Monitoring and Reporting) or cleanup target levels based on the minimum criteria specified in Chapters 62-520 and 62-550, F.A.C. FDEP uses the soil and groundwater target levels in Chapter 62-785, F.A.C. because several numerical values for chemicals of concern have been updated since the amendment of Chapter 62-770, F.A.C. Once Chapter 62-777, F.A.C. becomes effective, FDEP will use the soil and groundwater cleanup target levels found in that chapter. A. Groundwater Clean-up Target Levels Clean-up target levels for groundwater are found in Table 1 of Chapter 69-785 F.A.C. Clean-up target levels for chemicals of concern in groundwater are derived based on direct human contact. The following criteria were used: • The minimum criteria specified in Chapters 62-520, F.A.C or 62-550, F.A.C. • The toxicity criteria specified in Chapter 62-302.530, F.A.C. • Alternative cleanup target levels, if established. • The following two equations: 1. GWCTL= LRL x Wt x CF [SF] x Wconsp. r 5 Where: GWCTL = Groundwater Cleanup Target Level (ug/L) LRL = Lifetime Risk Level = 1x10-6 Wt=Avg. Body Weight(use 70 kg) CF=Conversion Factor (use 1000 ug/mg) SF= Cancer potency slope factor- IRIS Wconsp= Avg water consumption (use 2 L/day) 2. GWCTL= RfDo x Wt x RSC x CF Wconsp. Where: RfDo=Chronic Oral Reference Dose-IRIS RSC=Relative Source Contribution Factor(20%) When the applicable minimum criteria for groundwater were established, the following factors were considered: • Calculations using a lifetime excess cancer risk level of I X 10-6 • A hazard quotient of one or less • Best achievable detection limits • Naturally occurring background concentrations • Nuisance, organoleptic and aesthetic considerations Cleanup target levels for each chemical of concern found in groundwater are the applicable state water quality standards or alternative cleanup target levels. Groundwater cleanup target levels found in Table I of Chapter 62-785, F.A.C. were used to determine if groundwater is contaminated above risked-based levels. B. Natural Attenuation Default Source Concentrations In some cases, monitoring of natural attenuation is an appropriate strategy for site rehabilitation. Natural attenuation allows natural processes to contain the spread of contamination and reduce the concentrations of contaminants.Natural attenuation processes may include adsorption, biodegradation, chemical reactions with subsurface materials, diffusion, dispersion and volatilization'. Natural attenuation may be used in the following cases: • Free product must not exist • Fire or explosive hazards from the release of non-aqueous phase liquids must not be present • Contaminated soil is not present except when it can be demonstrated that all exceedences of applicable soil-leachability cleanup target levels do not contribute to groundwater contamination at concentrations that pose a threat to human health, public safety and the environment • Groundwater contaminants above background concentrations or applicable cleanup 6 standards are not migrating beyond the temporary point of compliance or migrating vertically • Each contaminant and its transformation products are conducive to natural attenuation • Overall, data shows an overall decrease in the contamination • In five years or less, the site is anticipated to achieve no further action criteria as the result of natural attenuation • Background concentrations or the applicable cleanup target levels are not exceeded at the temporary point of compliance • Contaminant concentrations do not exceed Natural Attenuation Default Source Concentrations (Natural Attenuation standards) To evaluate if natural attenuation is an appropriate site rehabilitation method, FDEP finalized guidelines in May 1998. The document, published by FDEP's Bureau of Petroleum Storage Systems, is BPSS-I I,Natural Attenuation Evaluation Procedures. This report will identify automobile salvage yards above Natural Attenuation standards. Sites above Natural Attenuation standards exceeded concentrations listed in Table V of Chapter 62-785, F.A.C. No other criteria were used to determine if natural attenuation is an appropriate site rehabilitation method. Groundwater above Natural Attenuation standards must be rehabilitated using approved innovative technologies. C. Soil Clean-up Target Levels Cleanup target levels for soil are found in Table 11 of Chapter 62-785, F.A.C. Cleanup target levels for chemicals of concern in soil are based on direct human contact and migration of these chemicals from soil to groundwater. The following criteria were used in developing soil cleanup target levels: • Calculations using a lifetime excess cancer risk level of 1 X 10-6 • A hazard quotient of one or less • Best achievable detection limits In addition, the methodology presented in the Technical Report: Development of Soil Clean-up Target Levels for Chapter 62-785,F.A.C., Final Report dated Apri130, 1998 was used. The approach used in calculating soil cleanup target levels was based on methodologies developed and described by USEPA Soil Screening Guidance and the USEPA Region IX Preliminary Remediation Goals2. Soil cleanup target levels are based on direct exposure from residential and industrial land uses rather than from indirect pathways that include the consumption of plants and animals as a food source2. Cleanup target levels for chemicals of concern in soils not found in Table 11 of Chapter 62-785, F.A.C are based on the following:I • Calculations using a lifetime excess cancer risk level of 1 X 10-6 • A hazard quotient of I or less • Best achievable detection limits • Naturally occurring background concentrations • Figures 4, 5, 6, 7 and 8 found in Chapter 62-785, F.A.C. Alternative cleanup target levels for each chemical of concern found in soil may be established. Soil cleanup target levels found in Table Il of Chapter 62-785, F.A.C. were used to determine if soils are contaminated above residential or industrial soil cleanup target levels. D. Leachability-Based Soil Clean-up Target Levels Leachability-based soil cleanup target levels are also found in Table II of Chapter 62-785, F.A.C. Leachability-based soil cleanup target levels for protecting groundwater are based on groundwater cleanup target levels or alternative cleanup target levels for ground-water, if established. This report will identify automobile salvage yards that exceeded leachability-based soil cleanup target levels based on groundwater criteria. Site rehabilitation of soils should be initiated for sites that exceeded leachability-based soil cleanup target levels. Soil and groundwater data will be reviewed and information detailing contaminants of concern will be provided. IV. REVIEW OF PUBLIC RECORDS In January 1999, various state and county environmental regulatory agencies were visited throughout Florida to determine current and past environmental compliance at automobile salvage yards. To assist in the environmental evaluation of the automobile salvage industry, records detailing site inspections and remedial actions were obtained from each office. Records were obtained from the following agencies and offices: • Florida Department of Environmental Protection- West Palm Beach • Florida Department of Environmental Protection- Orlando • Environmental Protection Commission of Hillsborough County- Tampa • Broward County Department of Natural Resource Protection- Fort Lauderdale • Palm Beach County Department of Environmental Resources Management- West Palm Beach The information and data obtained from each agency or office describes automobile salvage operations. Soil and groundwater data from thirty-four automobile salvage yards are detailed in this report. Each yard recycles or dismantles usable parts for sale and/or crushes unwanted automobiles on-site. Soil and groundwater samples had been collected by the agencies to determine the extent and nature of soil or groundwater contamination. No background samples were collected. Soil data were compared to soil cleanup target levels and leachability standards. Groundwater data were compared to groundwater cleanup target levels and natural attenuation standards. Contamination observed at each yard relates to the improper handling of automotive fluids during dismantling, crushing, or storage activities. Each yard was required to complete a contamination assessment to determine the extent and nature of soil or groundwater contamination. Table l identifies characteristics of each of thirty-four facilities. 8 Table 1: Summary of Automobile Salvage Facilities Evaluated Facility Soil Groundwater Enforcement Action Contamination of Contamination of Concern Concern Snake Road Auto Total Halogens, TRPH, Benzene, Cadmium and Considering feasibility of Salvage, Inc.,Stuart Barium, Cadmium, Chromium. Slightly quarterly monitoring for Martin County Total Chromium, Lead impacted by volatile & one year and Xylenes extractable organic compounds Wooten's Thousand of Lead, Benzene, Xylene, Lead, Benzene and Contamination & Parts, Lake Park Oil and grease Total Xylenes remediation activities are Palm Beach County on-going Barney's Junkyard TRPH, Arsenic and Arsenic, Chromium, Data Not Available Rivera Beach Ethylbenzene Lead and TRPH Palm Beach County Everything TRPH and Lead No samples were taken Preparing consent order Automotive, Inc that requires paying a Delray Beach civil penalty, assess and Palm Beach County remediate site P& L Salvage TRPH, Arsenic and No samples were taken Contaminated soils were West Palm Beach Lead excavated & disposed of Palm Beach County properly. Additional assessment/remediation not required ABCAR Auto Parts Contaminants were Cadmium and Lead Requested completion of Stuart below applicable were at cleanup target CAB and CAR. Pursuing Martin County standards levels assessment/remediation activities Oleander Auto No samples taken No samples taken Pursuing Salvage assessment/remediation Fort Pierce activities St. Lucie County Holly Hill Salvage and Arsenic, Benzene, Not known if Holly Hill Ordered to perform Junk, Holly Hill Benzo(a)pyrene and contributed to surface corrective actions and Volusia County Lead water contamination perform additional due to presence of assessment/remediation Industrial park in activities vicinity M & M Auto parts and Lead(RCRA levels) and Chromium, Lead and Improve management Salvage, Sanford TRPH Benzene practices, pay a civil Seminole County penalty, perform corrective actions. On- going action. 9 Foster's Auto No data available due to Benzene, Cadmium and Required to conduct Crushing, Inc. impenetrable layers of Lead monitoring Orlando debris Orange County I Titusville Auto TRPH and Lead(RCRA I Benzo(a)anthracene and Required to monitor Salvage, Inc. levels) TRPH TRPH levels Titusville Brevard County Smitty's Auto Lead(RCRA levels) and I Arsenic, Chromium and Excavated all visibly Wrecking, Apopka Arsenic Lead stained soils, but is yet to Orange County be disposed properly U-Pull It/ABC Auto Boring tests met the Lead Data Not available Parts, Tampa definition of Hillsborough County "excessively contaminated soils" Evan's Auto Brokers/ Data Not Available Required to conduct Old U.S 41, Tampa additional assessment Hillsborough County I All Japanese-German Benzo(a)pyrene, Heavy Surface water(TRPH& Currently reviewing the Used Auto Parts oil and TRPH Fluoranthene) completeness of PCAP Tampa Hillsborough County Linebaugh Auto Indeno(1,2,3,- Data Not Available Contaminated soils / Salvage, Tampa c,d)pyrene and Heavy wastes were properly Hillsborough County fuel oil disposed Kempton's U-Pull It TRPH and Lead Lead Contaminated soil was Used Auto Parts excavated and properly Tampa disposed Hillsborough County Interamerican Used i Data Not Available Benzene Assessment/remediation Auto Parts, Opa Locka activities are on-going Dade County Dafcik Auto Crushing Oil and grease above All analytical results ' Status of case no known Miami Dade county standards were below detection Dade County level Joe's Junkyard Oil and grease above Data Not Available Assessment/remediation Homestead Dade county standards activities are on-going Dade County to All Parts of Miami, Oil, grease, heavy Benzene, Cadmium, Assessment/remediation Inc., Medley metals and phenols Lead, MTBE, Total activities are on-going Dade County above Dade county Xylenes, Toluene, standards. Total ethylbenzene and Xylenes, Toluene and naphtalene ethylbenzene Auto Connection Lead exceeded RCRA Lead Assessment/remediation Foreign Parts activities are on-going Opa Locka Dade County Lima Parts Unlimited, Oil and grease above Data Not Available Ordered to properly clean Inc., Opa Locka Dade county standards. storm drains and to cease Dade County Lead, Cadmium and discharge into the drains Chromium exceeded RCRA levels Best Used Auto Parts Benzene, Xylene, Total' Benzene, Cadmium, Assessment/remediation Miami Phenols, Toluene, Lead, Toluene, Xylene, activities are on-going Dade County ethylbenzene and TRPH and MTBE chlorometane Brother's Auto Parts Oil, grease, heavy Data Not Available Sold to Lima Parts which and Salvage, Inc. metals and petrol is required to obtain a Opa Locka products above Dade variance to operate on the Dade County county standards site Sailer's Auto Salvage, Oil and grease above Lead Installation of a Inc., Opa Locka Dade county standards monitoring well and Dade County samples are to be collected quarterly for I year 'Pensacola Import Auto TRPH, Benzene, Data not available, but Required to pay a civil Salvage, Inc. Xylenes, Toluene, ' fluids on the ground penalty and to reimburse Pensacola ethylbenzene, pose a significant threat ', FDEP for investigative Escambia County naphtalene, total to ground water costs. Case is still on- xylenes and benzyl going phthalate Fairfield Auto Parts 1,2,4 trimethylbenzene Data Not Available Case is on-going Pensacola & 1,3,5 Escambia County trimethylbenzene, benzene, Toluene, TRPH, ethylbenzenes, ! xylenes, naphtalene, isopropybenzene r-- All States Auto Arsenic, Lead, 4,4-DD, Data Not Available Ordered to post an Salvage, Inc. Benzene, ethylbenzene, $80,000 bond, remove all St. Petersburg Xylene and Toluene personal property, Pinellas County automobiles, auto-parts, scrap metal and all visually contaminated soils Sam's Recycling and Benzene, Toluene, Benzene, Ethylbenzene, Remediation activities Junkyard Xylene, naphtalene, MTBE, Toluene, Total and monitoring are on- Pompano Beach ethylbenzene, Xylene, Total VOA and going Broward County methylterbutylether and Naphtalene 1,2,4 trimethylbenzene Affordable No Sample Taken No Sample Taken Disposed of 1,300 pounds Lake Worth of soil and asphalt Palm Beach County contaminated with petroleum E & II Auto Crushing Data Not Available Data Not Available Conditionally exempt Orlando small quantity generator Orange County in compliance at inspection time but should obtain an EPA ID number Foster's Auto Part, Inc.' Data Not Available Data Not Available Required to repair Deland concrete pad and Volusia County contaminated soils to be excavated and disposed properly. Should obtain EPA 1D number The Junkyard Data Not Available Data Not Available Contaminated soils to be Orlando collected and disposed Orange County immediately and properly. FDEP must be notified before the installation of concrete pad. Should obtain EPA ID number V. FACTORS AFFECTING ENVIRONMENTAL CONTAMINATION A. Fate and Transport of Contaminants The fate and transport of used oil, gasoline, petroleum products and metals in the environment depends on the following: • Physical and chemical properties of the contaminant • Structure and composition of the subsurface environment ,r. 12 Contaminant transport depends on soil permeability and the viscosity of the contaminant3. Vertical movement is due to gravity. Lateral movement is attributed to adhesive forces (capillary forces) between the contaminant and soil and rock particles3. Contaminant migration within soil relates to the amount discharged and the specific gravity of the contaminant. In addition, the depth to an impermeable layer or the water table influences migration. Contaminants within the unsaturated zone (soil above the water table) exist in the following phases: • Trapped in soil pore spaces (adhesion) • Adsorbed (solutes of contaminants) onto soil particles (adsorption) • Vapor in the soil's air voids (volatilization) • Dissolved in the interstitial water (dissolution) Vertical movement within the unsaturated zone is impeded when the contaminant is below the residual saturation level or reaches an impermeable layer or groundwater3. In addition, vertical movement is impeded within the capillary zone if the contaminant has a lower density than water;. When a contaminant reaches the water table, lateral movement occurs in all directions. This phenomenon, known as mounding occurs for a short distance4. After mounding is completed, the contaminant follows the direction of groundwater flow4. In the capillary zone, interstitial water increases resulting in increased dissolution and decreased volatilization. To better understand fate and transport, adsorption, leachability, volatilization and dissolution will be discussed. 1. Adsorption One of the most important processes determining how organic contaminants are transported in the subsurface is adsorption. Adsorption is defined as the adherence of atoms, ions or molecules of a gas or liquid to the surface of another substance. If a contaminant is strongly adsorbed to soil, the contaminant is relatively immobile and will not migrate within the soil. If the contaminant is weakly adsorbed, it is relatively mobile and may contaminate groundwater. The degree of adsorption also affects volatilization, hydrolysis and biodegradation. 2. Leachability Leachate production occurs when contaminants are dissolved within the unsaturated zone. Leachate is produced when rainwater infiltrates contaminated soil or when the water table fluctuates. Water table fluctuations allow contaminants to extend over the entire range of fluctuations3. This entire range is referred to as the smear zone. Seasonal fluctuations may mobilize contaminants in soils. Consequently, contaminant levels may vary3. Leachability within soils relates to the contaminant's solubility in water. Solubility is defined as the ability or tendency of one substance to blend uniformly with another°. 13 Solubility relates to the dissolution, adsorption and biodegradation of a contaminant in water. Advection and dispersion is how dissolved contaminants migrate through groundwater'. Most semi-volatiles, pesticides and PCBs are immobile in soils due to a low solubility and high affinity for organic carbon. VOCs are relatively mobile and have a moderate affinity for organic carbons. 3. Volatilization Another mechanism by which contaminants can be transported is volatilization. Volatilization of contaminants within the unsaturated zone depends on soil and environmental conditions and the vapor pressure of the contaminant. The physical process largely responsible for transporting gases through soil is diffusions. Vapor pressure provides an indication on the extent that a contaminant will volatilize. Henry's Law describes the solubility of a gas in liquid. Henry's Law states that the partial pressure of a gas above a liquid is proportional to the concentration of the chemical in the liquid8. Soil and environmental conditions influence the vapor pressure of a contaminant. Soil conditions that affect vapor pressure include water content, clay content, grain size, soil air permeability and soil air-filled porosity9. Environmental conditions that affect vapor pressures include temperature, wind speed, evaporation rate and rainfalls. Since vapor pressure relates to volatilization, benzene and MTBE are easily transported through the unsaturated zone to groundwater. 4. Dissolution Dissolution is the dissolving of contaminants to solutes in soils or groundwater. Dissolution is based on the individual contaminant, surface area and migration rate of water within soils or groundwater B. Mobility Solubility and adsorption ability of a metal determines its mobility. Solubility and adsorption depends on pH, Eh, climatic factors, organic carbon and soil composition10. Fine-grained particles provide greater surface area for the adsorption of inorganic contaminants'I. The mobility of metals is influenced by oxidation/reduction potential, ionic strength, ionic speciation and ion exchange capacities relating to the hydrate ionic radius. Certain chemical and physical processes within the subsurface influence the migration of metals. However, mobility of metals decreases with the presence of anions".�. In addition, a higher valence number increases the mobility of metals I°. 14 1. Lead In surface water, lead occurs in many different forms and tends to form insoluble compounds with naturally occurring anions (hydroxide sulfide, carbonate and sulfate)'. Lead may also form complexes with organic matter or be adsorbed by sediments. Solubility of lead depends on its form, pH, temperature and salt content. Natural lead compounds have a relatively low solubility. Inorganic lead is usually adsorbed in soil depending on soil composition, soil type, pH and organic content. Lead may leach from acidic soils if organic or clay content is low10. Organolead compounds may degrade in soil and leach to groundwater. Natural concentrations of lead appear in soils within certain areas of Florida4. 2. Chromium Chemical speciation determines the fate and transport of chromium. In groundwater, chromium is present as trivalent or hexavalent chromium depending on the presence of reducing agents. Chromium speciation in groundwater depends on oxidation/reduction potential and pH conditions. Hexavalent chromium is relatively soluble and prevalent in high oxidation conditions. Trivalent chromium is prevalent under reducing conditions13. Hexavalent chromium reacts with reducing agents to form trivalent chromium. Oxidizing conditions are generally found in shallow aquifers and reducing conditions generally exist in deeper groundwater14. Acidic conditions aid in the reduction of hexavalent chromium to trivalent chromium13. The adsorption of hexavalent chromium within soil is not a significant fate pathwa/2. Fate processes of trivalent chromium include reactions with aqueous hydroxide ions to form an insoluble precipitate (chromium hydroxide) and absorption of dissolved chromium to soil particulates and sediments12. Hexavalent chromium is relatively mobile in soils and groundwater. The migration of trivalent chromium to groundwater is limited due to strong adsorption to soils. Natural concentrations of chromium appear in soil within certain areas of Florida4. 3. Cadmium Cadmium is a trace metal introduced into the environment from cadmium-rich rocks and human activity. In surface waters, cadmium H occurs as a constituent of inorganics(halides, sulfides and oxides)13. Cadmium may strongly adsorb to many types of surfaces. The transport of cadmium within soils may occur through co-precipitation with iron, aluminum and manganese oxides13. The presence of cadmium relates to pH, oxidation/reduction potential, water hardness and other complexing agents. 4. Mercury Mercury is a trace metal commonly found in sulfide mineral cinnabar. In the r• 15 environment, it is present in three oxidation states (Hg°, Hg+and Hg2'). Natural mercury concentrations in soils within the United States range from less than 0.010 mg/kg to 4.6 mg/kg2°. The average mercury concentration is approximately 0.090 mg/kg2 . Mercury may strongly adsorb to many types of surfaces. The adsorption of mercury to sediments allows transport by sediment mobilization. Mercury adsorption onto sediments may be the most important process of determining the fate of mercury in water 2. Metallic mercury may enter the atmosphere by volatilization. Microorganisms under anaerobic and aerobic conditions methylate mercury. Since organomercury compounds are more volatile than inorganic mercury compounds, methylation may result in a net increase in mercury volatilit))3. 5. Arsenic Arsenic is introduced into the environment from arsenic-rich rocks and human activity. It occurs in four valence states (-3, 0, +3, and +5). The +3 and +5 valence states are the most prevalent forms of arsenic in minerals and natural waters. The range of natural soil concentrations of arsenic in the conterminous United States is less than 0.1 mg/kg to 100 mg/kis. The average concentration is 5 mg/kg's. Arsenic is mobile in the environment under low pH conditions. It is transported primarily through water and air. Arsenic is adsorbed by clays, organic matter, aluminum hydroxides and iron oxides12. Arsenic has a strong affinity for sulfur and readily adsorbs and co-precipitates with other metal sulfides13. 6. Barium Barium is an alkaline earth element. The majority of barium found in nature is within barite and witherite6. When barium contamination is indicated, it is not known if the observed barium is naturally occurring or a contaminant introduced into the environment. The mineral forms of barium are relatively insoluble. However, many barium salts are soluble in water and acid. Barium ions are rapidly precipitated or removed from solution by adsorption and sedimentation e. Most natural waters have sufficient sulfate and carbonate to precipitate barium out of solution as a relatively insoluble, non-toxic compound'. The major transport mechanism of soluble barium salts is leaching into groundwater. Barium mobility in groundwater and surface waters decreases as barium is precipitated out of solution by carbonate and sulfate'°. C. Geology The structure and composition of the underlying soils influence the physical and chemical processes that occur in the subsurface environment. Automobile salvage yards within the following counties exceeded soil and groundwater cleanup target goals, t6 Natural Attenuation standards or leachability standards. A description of each county's soil type is provided. 1. Palm Beach and Dade Counties 18,19 Formations found in Palm Beach and Dade Counties include the following: • Hawthorn Group- A complex series of the phosphate-bearing Miocene sediments. The carbonate sediments of the Hawthorn Group are Primarily fine-grained sands with mixtures of clay, silt, sand and phosphate. Dolostone and limestone are the dominant sediment types. • Caloosahatchee Formation-This formation consists of fossiliferous quartz sand with variable amounts of carbonate matrix interbedded with variably sandy Shelly limestones. • Fort Thompson Formation- This formation consists of interbedded shell beds and limestone. The shell beds are variably sandy. • Anastasia Formation-This formation consists of interbedded quartz sands and coquinoid limestones. The sand beds consist of fine to medium-grained, variably fossiliferous, calcareous, quartz sand. 2. Martin County 20 Martin County is divided into the following three physiographic subdivisions: • Coastal Ridge- Soils consist of deep, excessively drained sands with highly variable slopes. • Broad and Sandy Flatlands- Soils are nearly level, sandy and wet. They have sandy subsoil that is weakly cemented with organic matte. Limestone is below the soil in many places. • Everglades Marsh- Soils are very poorly drained organic and mineral soils. Sandy soil is scattered over many areas of limestone. The Everglades Marsh is adjacent to Lake Okeechobee. 3. Seminole,Volusia and Brevard Counties 1s,21 Seminole, Volusia and Brevard Counties are underlain by four major geologic units. At the surface to a depth of approximately 35 to 50 feet below land surface, Pleistocene and recent age deposits exist. These geologic units consist of fine to medium grain sands with discontinuous interbedded lenses of silty and clayey sand. Beneath the Pleistocene and Recent age deposits, the Hawthorn formation is present to a depth of approximately 150 feet below land surface. Beneath the Hawthorn formation lies the Ocala Group, a fine, soft to medium hard granular, porous limestone. The thickness of this unit is estimated to be approximately 75 to 100 feet. Underlying the Ocala Group is the Avon Park Limestone formation and dolomite limestone. 17 4. Orange County 22 Upper Eocene limestone units of the Ocala Group underlie Orange County. Sedimentary deposits underneath the Upper Eocene limestone units are the Hawthorn formation. The carbonate sediments of the Hawthorn formation are primarily fine- grained sands with mixtures of clay, silt, sand and phosphate. Dolostone and limestone are the dominant sediment types. The clayey sand contains silt, fine to coarse sand and gravel bound by a matrix of clay. Unconsolidated sand blankets Orange County. This sand consists of medium to fine sand and silt and does not contain clay or shell fragments. 5. Hillsborough County 23 The major lithologic units in Hillsborough County consist of Holocene and Pleistocene age units of unconsolidated fine-grained surficial sands with some interbedded clay layers. Underlying the surficial sands are Pleistocene age units of undifferentiated deposits consisting primarily of clayey and pebbly sands. The lithologic unit beneath the clay and sand consists of Upper Miocene age units of carbonates, sand and clay. All lithologic units were deposited upon the thick sequence of carbonates of the Florida plateau. The Florida plateau consists of precipitated deposits of limestone and dolomite that contain shells and shell fragments of marine origin. 6. Pinellas County 24 The geology of Pinellas County is a sedimentary system of horizontal units. Beginning at the land surface, sands and clays of the recent age to Hawthorn formation exist. Below these units, limestones of the Tampa, Suwannee and Ocala formations are present. Underlying these units, dolostones and limestones of the Avon Park and Lake City formations exist. Soils at All States Auto Salvage, Inc. primarily consisted of fine to medium grained sands. 7. Escambia County 18,25 Escambia County is underlain with Mesozoic and Cenozoic sedimentary rocks. The oldest known sediments encountered consist of Jurassic quartzitic sandstone and gray shale. The youngest sediments are Pleistocene and Holocene undifferentiated sands, clayey sands and alluvium26. The soils of Escambia County can be described as having a high infiltration rate and low runoff potential when thoroughly wet. They consist of deep, well drained to excessively drained sands or gravely sands and have a high rate of water transmission. The sand and gravel aquifer of Escambia County is the primary source for domestic and industrial water use in the region. This surficial aquifer is comprised of thick beds of sand and gravel with discontinuous interbedded clay and silt layers. It overlies the Intermediate system, which is comprised of low permeability sand, clay and silt layers. Beneath the confining clay unit is the Floridan aquifer. This aquifer system is composed primarily of limestone and dolomite. 18 The sand and gravel aquifer consists of three different zones of permeability. In descending order, they include the surficial zone, low permeability zone and main producing zone27. The surficial zone is mostly very fine to very coarse sand with variable amounts of clay. The low permeability zone is an underlying confining layer of low permeability clay and silt. The main producing zone is comprised of coarse sand and gravel at the base of the aquifer. Confined or semiconfined conditions may be present in the main producing zone when the overlying confining clays are continuous and widespread. VI. SOIL ANALYTICAL RESULTS 3ires*eetlt in disrmtnapIllimilliftfirmleiiiiiiI Therefore, environmental impacts at individual automobile salvage yards are unique and relate to operational and physical factors. Analytical results for soils are presented for organic compounds and metals. Soil data is biased since only soils visually impacted with used oil, gasoline and petroleum products were collected for analysis. eac `"finds will A. Organic Compounds for sedrffrOrgM"ftIC compound;Tettri-Tolatil. and grease. Each group of organic compounds will be discussed separately. The following test methods are used to determine the presence of organic compounds: 28,2930 • EPA Method 8260A-Volatile Organic Compounds by GC/MS: Capillary Column Technique (Priority Pollutant Volatile Organics) • EPA Method 8250- Priority Pollutant Extractable Organics • EPA Method 625- Semi-Volatile Compounds • EPA Method 8270B- Semi-Volatile Organic Compounds by GC/MS: Technique (Priority Pollutant Extractable Organics) • EPA Method 8100- Polynuclear Aromatic Hydrocarbons • EPA Method 8310- Polynuclear Aromatic Hydrocarbons- HPLC • Florida Residual Petroleum Organic Method (FLO-PRO) for TRPH • EPA Method 8010 B- Halogenated Volatiles Organics- GC • EPA Method 8020 A- Aromatic Volatile Organics- GC • EPA Method 8021 A-Halogenated Volatiles- GC • EPA Method 9071- Oil and Grease • EPA Method 9073- TRPH 1. Volatile Organic Compounds Unleaded gasoline and other petroleum fuels contain volatile organic compounds (VOCs). Other VOCs that include methanol and ethanol are added to gasoline to enhance 19 combustion. Not every sample was analyzed for VOCs. SOWNINIPlemialiWealeikatilielicilitlirlifgefff.teturage frpesoniaLyt: target levelsilexissisiahttifresidential) or e"d trilitym ' of VOCs detected are constituents of gasoline andpetroieuepriStaishdi list of contaminants and the number of samples that exceeded FDEP soil cleanup target levels (industrial or residential) and leachability standards for VOCs is provided in Table 2. Other VOCs detected include n-butylbenzene, n-propylbenzene, sec-butylbenzene, p-- isopropyltoluene and 1,2,4 trichlorobenzene. All contaminants except for sec- butylbenzene and p-isopropyltoluene are constituents of unleaded gasoline31. Soil samples collected from areas where leaking gasoline tanks were stored indicated high VOCs concentrations. In addition, the highest VOC concentrations were from soil samples immediately collected from areas where gasoline and petroleum products were discharged on the ground. Soil samples immediately collected after discharges at Fairfield Auto Parts indicated that ethylbenzene, 1,2,4-trimethylbenzene and 1,3,5- trimethylbenzene exceeded FDEP soil cleanup target levels for industrial and residential sites. In addition, benzene exceeded industrial and residential cleanup target goals at Fairfield Auto Parts. When soil data from Fairfield Auto Parts is compared with other soil data, it appears that VOCs in soils volatilize or degrade over time. Soil data indicated that higher VOC concentrations correlate to the number of VOCs or other contaminants present within a sample. Finally, methylene chloride was used at Holly Hill Salvage and Junk as a parts-washer solvent. Table 2. VOCs Which Exceeded FDEP Soil Cleanup Target Levels (Industrial or Residential) and Leachability Standards: Contaminant Industrial Residential Leachability Methylene Chloride 0 0 5 Benzene 6 7 12 Toluene 0 1 I1 Ethylbenzene 1 1 14 Xylene 6 5 18 1,2,4 Trimethylbenzene 2 2 5 1,3,5 Trimethylbenzene 1 2 3 Isopropylbenzene 0 0 2 Phenol 0 0 1 Chloromethane 0 0 1 Nine soil samples collected from the surface had levels above FDEP cleanup target levels and leachability standards. In addition, seven samples collected at two feet below land surface had levels above FDEP cleanup target levels and leachability standards. VOCs above soil cleanup target levels and leachability standards were detected in four samples collected at four feet below land surface. Therefore, the vertical movement of VOCs appears to be limited at the majority of the sites. VOCs are likely 20 volatilizing or degrading due to their vapor pressures. However, two facilities had elevated concentrations of VOCs at the surface and at four feet below land surface. As a result, automobile salvage yards discharging large amounts of gasoline and petroleum products on the ground are very likely impacting groundwater in areas with high water tables. Finally, heavy VOCs are more mobile and affect more drinking water wells than lighter VOCs1 I. Soil analytical data indicated that VOCs exceeded FDEP soil cleanup target levels (industrial and residential) at the following four automobile salvage yards: • Holly Hill Salvage and Junk in Holly Hill, Volusia County • Best Used Auto Parts in Miami, Dade County • Pensacola Import Auto Salvage in Pensacola, Escambia County • Fairfield in Pensacola, Escambia County VOCs exceeded leachability standards at the following eight automobile salvage yards: • Holly Hill Salvage and Junk in Holly Hill, Volusia County • All States Auto Salvage, Inc. in St. Petersburg, Pinellas County • Wooten's Thousands of Parts in Lake Park, Palm Beach County • Barney's Junkyard in Rivera Beach, Palm Beach County • All Parts of Miami, Inc. in Medley, Dade County • Best Used Auto Parts in Miami, Dade County • Pensacola Import Auto Salvage in Pensacola, Escambia County • Fairfield in Pensacola, Escambia County Four sites that exceeded FDEP soil cleanup target levels and leachability standards for also had VOCs above cleanup target levels and Natural Attenuation standards. Since the majority of sites did not collect soil and groundwater, it is not possible to determine if both media are contaminated at each site. Soil data indicates that sites exceeding leachability standards are probably impacting groundwater. 2. Semi-Volatile Organic Compounds Unleaded gasoline and other petroleum fuels also contain semi-volatile organic compounds (semi-volatiles). One hundred and fifteen soil samples were collected. Not every sample was analyzed for semi-volatile compounds. Soil samples were collected in dismantling, crushing and storage areas. Soil analytical results indicated that semi-volatiles exceeded FDEP soil cleanup target levels(industrial or residential)and leachability standards within 16 samples. The majority of semi-volatiles detected are constituents of gasoline and used oil. A list of contaminants and the number of samples that exceeded FDEP soil cleanup target levels (industrial or residential) and leachability standards for semi-volatiles is shown in Table 3. 21 Table 3. Semi-Volatiles Which Exceeded FDEP Soil Cleanup Target Levels (Industrial or Residential) and Leachability Standards: Contaminant Industrial Residential Leachability Naphthalene 0 5 10 Benzo(a)pyrene 1l 4 4, 4'-DDD 1 1 1 4, 4'-DDE 0 I I Indeno(1,2,3-cd) 1 1 0 PyTene Bis(2-ethyl 1 2 3 Hexvl)phthalate Butyl benzyl 0 0 1 Phthalate 1-Methyl 0 - 0 1 naphthalene 2-Methyl 0 0 I 1 naphthalene Other semi-volatiles detected within soil samples include acenaphthylene, acenaphthene, anthracene, benzo(b)fluoranthene, benzo(ghi)perylene, benzo(a)anthracene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, fluoranthene, fluorene, phenanthrene, pyrene and d-n-octyl phthalate. The majority of these contaminants are constituents of gasoline, used oil and diesel fuel;. Soil samples collected from crushing and dismantling areas and areas where leaking gas tanks were stored indicated the highest semi-volatile concentrations. Napthalene exceeded leachability standards in 10 out of 16 samples. At Pensacola Import Auto Salvage, napthalene was detected at two feet below land surface (three samples) and four feet below land surface (two samples). In addition, napthalene was indicated at two and four feet below land surface at All Parts of Miami, Inc. and on the surface at Holly Hill Salvage and Junk and Fairfield Auto Parts. Benzo(a)pyrene exceeded leachability standards in four out of 16 samples. Semi-volatile compounds were detected between two and four feet below land surface in 10 out of 16 samples. Consequently, it appears that the vertical movement of semi-volatiles in groundwater is limited at the majority of sites. The only automobile salvage yard that exceeded soil and groundwater cleanup target levels, Natural Attenuation standards and leachability standards for semi-volatiles was Best Used Auto Parts in Miami. A reason why semi-volatiles may not be detected in soil samples is due to a high detection limit and their immobility in soils". Bis(2-ethylhexyl) phthalate and butyl benzyl phthalate may be laboratory contaminants since they are only detected in a couple of samples. Soil analytical data indicated that semi-volatiles exceeded FDEP soil cleanup target levels (industrial and residential) at the following five automobile salvage yards: • Holly Hill Salvage and Junk in Holly Hill, Volusia County • All States Auto Salvage, Inc. in St. Petersburg, Pinellas County 22 • All Japanese-German Used Auto Parts in Tampa, Hillsborough County • Linebaugh Auto Salvage in Tampa, Hillsborough County • Pensacola Import Auto Salvage, Inc. in Pensacola, Escambia County Semi-volatiles exceeded leachability standards at the following five automobile salvage yards: • Holly Hill Salvage and Junk in Holly Hill, Volusia County • All States Auto Salvage, Inc. in St. Petersburg, Pinellas County • All Parts of Miami, Inc. in Medley, Dade County • Pensacola Import Auto Salvage in Pensacola, Escambia County • Fairfield in Pensacola, Escambia County 3. Total Recoverable Petroleum Hydrocarbons and Oil and Grease The presence of TRPH is determined with the Florida Residual Petroleum Organic Method (FLO-PRO). This method was designed to measure concentrations of petroleum hydrocarbons in the alkane range of C8-C4032. It does not differentiate between gasoline and oil contamination. However, it does detect other organic compounds, which include chlorinated hydrocarbons, phenols and phthalate esters. Since FLO-PRO indicates the presence of petroleum hydrocarbons, it is a good indicator to determine if used oil or petroleum products have been discharged on the ground. Used oil, diesel fuel and heavy oil are considered TRPH. EPA Methods 418.1 and 9073 were previously used to analyze for TRPH. One hundred and fifteen soil samples were collected.Not every sample was analyzed for TRPH. Table 4 shows the number of samples that exceeded FDEP soil cleanup target levels (industrial and residential) and leachability standards for TRPH. Table 4. Number of samples that exceeded FDEP soil cleanup target levels (industrial and residential) and leachability standards for TRPH Contaminant Industrial I Residential Leachability TRPH 35 39 39 Soil analytical data indicated that TRPH exceeded FDEP soil cleanup target levels (industrial and residential) at the following thirteen automobile salvage yards: • M & M Auto Parts and Salvage in Sanford, Seminole County • All States Auto Salvage, Inc. in St. Petersburg, Pinellas County • Barney's Junkyard in Riviera Beach, Palm Beach County • Evan's Auto Brokers/Old U.S. 41 Used Auto Parts in Tampa, Hillsborough County • Titusville Auto Salvage, Inc. in Titusville, Brevard County • All Japanese-German Used Auto Parts in Tampa, Hillsborough County • Linebaugh Auto Salvage in Tampa, Hillsborough County • Everything Automotive, Inc. in Delray Beach, Palm Beach County 23 • P& L Salvage in West Palm Beach, Palm Beach County • Kempton's U-Pull It Used Auto Parts, Inc. in Tampa, Hillsborough County • Auto Connection Foreign Parts, Inc. in Opa Locka, Dade County • Pensacola Import Auto Salvage in Pensacola, Escambia County • Fairfield Auto Parts in Pensacola, Escambia County TRPH exceeded leachability standards at the following twelve automobile salvage yards: • M & M Auto Parts and Salvage in Sanford, Seminole County • All States Auto Salvage, Inc. in St. Petersburg, Pinellas County • Barney's Junkyard in Riviera Beach, Palm Beach County • Evan's Auto Brokers/Old U.S. 41 Used Auto Parts in Tampa, Hillsborough County • Titusville Auto Salvage, Inc. in Titusville, Brevard County • All Japanese-German Used Auto Parts in Tampa, Hillsborough County • Linebaugh Auto Salvage in Tampa, Hillsborough County • Everything Automotive, Inc. in Delray Beach, Palm Beach County • P & L Salvage in West Palm Beach, Palm Beach County • Kempton's U-Pull It Used Auto Parts, Inc. in Tampa, Hillsborough County • Pensacola Import Auto Salvage in Pensacola, Escambia County • Fairfield Auto Parts in Pensacola, Escambia County Soil analytical data indicated that TRPH compounds are the most common contaminants detected at automobile salvage yards. TRPH compounds were indicated in dismantling, crushing, storage and other areas contaminated with used oil and petroleum products. Surface soils were visibly stained with used oil at all 34 automobile salvage yards. The extent of soil contamination varied from site to site. Soil contamination was most prevalent in dismantling and storage areas. EPA Method 9071 determines the presence of oil and grease in soils. This method differentiates between oil and grease, and other petroleum hydrocarbons. Analytical results indicated that oil and grease was above background levels in 37 samples. Soil cleanup target levels and leachability standards do not exist for oil and grease. Oil and grease is commonly found at the surface but not at four feet below land surface. Consequently, it appears that the vertical movement of oil and grease is limited. However, heavy oil contamination and shallow groundwater conditions may result in used oil migrating to groundwater. Soil type and grain size determines vertical migration. Soils with low permeability may adsorb contaminants since lower soil permeability impedes contaminant migration. Studies indicate that ctarysaro aide tcrabbdtit _ contain m ' as It appears that the size of an automobile salvage yard does not determine the extent of TRPH contamination. TRPH contamination relates to individual automobile salvage yard practices within dismantling, crushing and storage areas. In addition, TRPH ,r 24 and oil and grease are transported off-site with stormwater runoff. Therefore, neighboring properties are being impacted with stormwater run-off. B. Metals Metals are introduced into the environment within dismantling, crushing and storage areas. The primary metals of concern at automobile salvage yards include lead, chromium, cadmium, mercury, arsenic and barium. These metals are toxic and mobile within the environment. Other metals found in soil include selenium, copper and zinc. These metals did not exceed FDEP groundwater cleanup target levels or Natural Attenuation standards. Copper and zinc have minimal human health effects. Test methods used to determine the presence of metals include the following: 30 • EPA Methods 6010, 7060 or 7061 —Total Arsenic • EPA Methods 6010, 7080 or 7081 —Total Barium • EPA Methods 6010, 7130 or 7131 —Total Cadmium • EPA Methods 6010, 7190 or 7091 —Total Chromium • EPA Methods 6010 or 7421 --Total Lead • EPA Method 7421 —Total Mercury • EPA Method 1311 —Toxicity Characteristic Leaching Procedure 1. Lead J 09d is found ;" u--d acid+betteciea;•tire we heater cores, Icad,.d guaolinc, &aaolino additi3,a, softie( aitby, and other-automobile part56'34. Lead is introduced into the environment from dismantling, crushing and storage activities. Lead is toxic by ingestion and inhalation of dust or fumes°. There is inadequate evidence to determine if lead is carcinogenic to humans35. Soil samples were collected in dismantling, crushing and storage areas. Soil analytical results indicated that lead was present in 75 out of 115 samples. Fourteen samples exceeded FDEP soil cleanup target levels for industrial and residential sites. In addition, 30 samples exceeded 100 mg/kg. Therefore, a TCLP is required to determine if lead is above leachability standards. Table 5 shows the number of samples that exceeded FDEP cleanup target levels (industrial and residential) and leachability standards for lead. Table 5. Number of samples that exceeded FDEP soil cleanup target levels (industrial or residential) and leachability standards for lead Contaminant Industrial Residential Leachability Lead 5 9 30 Soil analytical data indicated that lead exceeded FDEP soil cleanup target levels (industrial or residential) at the following five automobile salvage yards: • All States Auto Salvage, Inc. in St. Petersburg, Pinellas County • Wooten's Thousands of Parts in Lake Park, Palm Beach County • Evan's Auto Brokers/Old U.S. 41 Used Auto Parts in Tampa, Hillsborough County 25 • Everything Automotive, Inc. in Delray Beach, Palm Beach County • Kempton's U-Pull It Used Auto Parts, Inc. in Tampa, Hillsborough County Lead concentrations above FDEP soil cleanup target levels (industrial or residential) ranged from 505 mg/kg at Wooten's Thousands of Parts to 4130 mg/kg at All States Auto Salvage, Inc. In addition, 12 samples were hazardous for lead under RCRA. Lead concentrations ranged from 7.33 mg/L at Lima Parts to 624 mg/L at Auto Connection Foreign Parts. Seventeen out of twenty-nine automobile salvage yards exceeded soil cleanup target levels, leachability standards or RCRA regulatory levels for lead. Soil analytical results indicated lead in 24 samples collected from the surface. Lead was indicated in five soil samples collected one foot below land surface. Eight automobile salvage yards exceeded soil and groundwater cleanup target levels, Natural Attenuation standards or leachability standards for lead. Eleven automobiles salvage yards exceeded groundwater cleanup target levels and Natural Attenuation standards for lead. Since the majority of sites did not collect both soil and groundwater, it is not possible to determine if both media are contaminated at each site. Although soil data indicated that lead is not migrating beyond two feet below land surface,groundwater data indicates that imp Lead concentrations appear to be highest in areas where gasoline was discharged from gas tanks. Lead levels indicated at some automobile salvage yards may be natural concentrations. 2. Chromium Chromih'rn is found in alloys and tweteetivest.patasaiwitevaient chromium is a human carcinogen. Analytical results indicated that chromium was present in 45 of 115 samples. Five samples collected from Lima Parts are hazardous under RCRA since they exceeded the regulatory level of 5.0 mg/L for lead. One sample exceeded 100 mg/kg. Therefore, a TCLP is required to determine if lead is above leachability standards. The remaining 39 samples did not exceeded FDEP soil cleanup target levels for industrial and residential sites, leachability standards or RCRA regulatory levels. Analytical results from Lima Parts indicated chromium at two to six feet below land surface. Chromium concentrations ranged from 14.6 mg/L to 51.5 mg/L. Groundwater analytical data indicated that four automobile salvage yards exceeded groundwater target levels and Natural Attenuation standards for chromium. Therefore, chromium it rcitt;•...lymotritetrillteChromium levels indicated at some automobile salvage yards may be natural concentrations. 26 /'•-• 3. Cadmium Cadmium is found in coattnge,ailoys.nse t'tatteries and elcutrodesb.-446,very toxic an&a Miuian rarcinogptt, Analytical results indicated that cadmium was present in 48 of 115 samples. Five samples collected from Lima Parts are hazardous under RCRA since they exceeded the regulatory level of 1.0 mg/L for cadmium. The remaining 43 samples did not exceed FDEP soil cleanup target levels for industrial and residential sites. leachability standards or RCRA regulatory levels. Analytical results from Lima Parts indicated cadmium at two to six feet below land surface. Cadmium concentrations ranged from 2.28 mg/L to 12.9 mg/L. Groundwater analytical data indicated that six automobile salvage yards exceeded groundwater target levels and Natural Attenuation standards for cadmium. Jae -cadmium is.clatiniy .r.6bde ar aeils. 4. Mercury and lamps. Mercury is very toxic and is released to the environment during crushing activities. The majority of sites did-m > afire for-mercury. Analytical results indicated that mercury was present within 23 samples. However, no samples exceeded FDEP soil cleanup target levels for industrial and residential sites, leachability standards or RCRA regulatory levels for mercury. Mercury concentrations ranged from .00102 mg/kg at Holly Hill Salvage and Junk to 0.36 mg/kg at Everything Automotive, Inc. Analytical results from Everything Automotive, Inc. also indicated high concentrations of mercury within the crushing area. Soil data indicated that mercury was higher at one foot than at the surface in five out of six samples. .Ti Laos mr.retitfis-reiativety mdbflplrrs ts. Mercury levels indicated at some automobile salvage yards may be natural concentrations. 5. Arsenic Amenie-iit-fetinilin battery grids;cable sheaths; alloying additives and-spi. tal sy(de{s°. Arsenic is likely introduced into the environment during dismantling, crushing and storage activities. Arsenic-containing pesticides and herbicides were historically used for weed control.feiP.A.hac ctassifie arsenic as.a.human carcinogen and mutagen6. Soil analytical results indicated arsenic in 21 out of 115 samples. Seventeen samples exceeded FDEP soil cleanup target levels for industrial and residential sites. Table 6 shows the number of samples that exceeded FDEP soil cleanup target levels (industrial and residential) and leachability standards for arsenic. 27 Table 6. Number of samples that exceeded FDEP soil cleanup target levels (industrial or residential) and leachability standards for arsenic Contaminant I Industrial Residential Leachability Arsenic 7 17 0 Soil analytical data indicated that arsenic exceeded FDEP soil cleanup target levels (industrial or residential) at the following five automobile salvage yards: • Holly Hill Salvage and Junk in Holly Hill, Volusia County • All States Auto Salvage, Inc. in St. Petersburg, Pinellas County • Barney's Junkyard in Riviera Beach, Palm Beach County • Smitty's Auto Wrecking in Apopka, Orange County • P & L Salvage in West Palm Beach, Palm Beach County Arsenic concentrations above FDEP soil cleanup target levels for industrial and residential sites ranged from 0.805 mg/kg at Holly Hill Salvage and Junk to 79.1 mg/kg at All States Auto Salvage, Inc. No samples were determined to be hazardous under RCRA. Groundwater analytical data indicated that three automobile salvage yards exceeded groundwater cleanup target levels and Natural Attenuation standards for arsenic. Ttt tthrtt, it , _ tl.etc-- r in -"tr'.ivel,ambite.wititin soils. Arsenic levels indicated at some automobile salvage yards might be natural concentrations. 6. Barium -Banumis-€etindSclugpalhtnelaibtlemsts6. It appears that the presence of barium indicates other metal contamination at automobile salvage yards. Analytical results indicated that barium was present within 18 samples. However, no samples exceeded FDEP soil cleanup target levels for industrial and residential sites, leachability standards or RCRA regulatory levels for barium. Barium is an alkaline earth element found in ores of barite and witherite6. Therefore, it is not known if the observed barium is naturally occurring or a contaminant introduced into the environment. No sites indicated any groundwater contamination with barium. It appears that barium has no significant impact to the environment. VII. GROUNDWATER ANALYTICAL RESULTS Analytical results for groundwater are presented for organic compounds and metals. Analytical results for each class of compounds will be discussed separately. A. Organic Compounds Groundwater samples were collected from monitoring wells on or near automobile salvage yards. Surface water samples were collected from neighboring bodies of water. Samples were analyzed for volatile organic compounds, semi-volatile organic compounds and TRPH. Test methods used to determine the presence of organic 28 r•••• compounds include the following: 2&29,30 • EPA Method 8260A- Volatile Organic Compounds by GC/MS: Capillary Column Technique (Priority Pollutant Volatile Organics) • EPA Method 8250- Priority Pollutant Extractable Organics • EPA Method 624- Purgable Organics in Waters • EPA Method 8270B- Semi-Volatile Organic Compounds by GC/MS: Technique(Priority Pollutant Extractable Organics) • EPA Method 8310- Polynuclear Aromatic Hydrocarbons- HPLC • EPA Method 625- Semi-Volatile Compounds • EPA Method 601- Purgable Halocarbons • EPA Method 602- Purgable Aromatics • EPA Method 610- Polynuclear Aromatic Hydrocarbons • EPA Method 8020 A- Aromatic Volatile Organics- GC • EPA Method 8021 A- Halogenated Volatiles- GC • EPA Method 8100- Polynuclear Aromatic Hydrocarbons • Florida Residual Petroleum Organic Method (FLO-PRO) for TRPH • EPA Method 502.2-Volatile Organic Compounds in water by Purge and Trap: Capillary Column/GC in series • EPA Method 503.1-Halogenated Volatiles by GC • EPA Method 418-TRPH 1. Volatile Organic Compounds Unleaded gasoline and other petroleum fuels contain volatile organic compounds (VOCs). Other VOCs that include methanol and ethanol are added to gasoline to enhance combustion. Seventy-nine groundwater samples were collected. Groundwater samples were collected from permanent or temporary monitoring wells. Analytical results indicated that 22 groundwater samples exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for VOCs. VOCs detected above FDEP groundwater cleanup target levels or Natural Attenuation standards included benzene, toluene, ethylbenzene, xylenes, methyl tertiary butyl ether(MTBE), trichloroethylene, 1.2,4 trimethylbenzene and 1,3,5 trimethylbenzene. A list of contaminants and the number of samples that exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards are provided in Table 7. All contaminants are constituents of unleaded gasoline except for trichloroethylene. Trichloroethylene was detected at ABCAR Auto Parts. The source of trichloroethylene may be from a neighboring dry-cleaning establishment. Benzene and MTBE were the most common contaminants found in groundwater. 29 Table 7. VOCs Which Exceeded FDEP Groundwater CleanupTarget Levels and Natural Attenuation Standards: Contaminant Cleanup Natural Target Attenuation Levels Benzene 22 7 Toluene 0 Ethylbenzene I 2 Xylene 0 2 1,2,4 1 1 Trimethylbenzene 1,3,5 I I Trimethylbenzene MTBE 7 Trichloroethylene 1 0 2. Benzene and MTBE iS a cor stihtcnrat'gaa l:, and pctiuktmi products. It is highly toxic and flammable. Benzene is very mobileaciii4Ailliellnelliefir has olassified benzene as a human carcinogen. Benzene that does not volatilize may leach to groundwater. In addition, biodegradation is a significant fate of benzene in soils. Benzene biodegrades to phenol anaerobically�H. A first order biodegradation rate of 10 mg/kg/day has been recorded R. MTBE,an octane-booster solely produced as a gasoline-additive;was-devetoped by ARCO in the 1960's and comme:Gaily sold u. 1979 36. Spur xumpt9ly IQ%, ufthe-rmtion ga;oline c'ipply 36. MTBE is the largest constituent of gasoline and may be blended up to 11% by volume. MTBE is soluble in water at 4.3%. Binary equilibrium solubilities of certain components of gasoline in water are provided in Table 8 37. Table 8. Binary Equilibrium of Solubilities of CertainComponents of Gasoline in Water (25° C) Contamin Mg/L % Relative ant to Benzene Benzene 1780 0.18 1 Toluene 515 0.05 0.3 Ethylbenz 167 0.02 0.1 ene m-Xylene 170 0.02 0.1 MTBE I 43000 I 4.3 I 24 0 30 Gasoline causes groundwater contamination by entering the unsaturated zone and water table within the vicinity of a discharge. When rainwater percolates into the soil and enters groundwater, it degrades gasoline constituents in proportion to their solubilities. The adsorption of organics in groundwater is inversely proportional to their solubilities 36 • Pn`I hindrk 36' &iitsc n i(tlf, nrtnrtw'rar contamination plurues, _e�,than-other gn nlinr ntc 36 Other VOCs detected within groundwater include chlorobenzene, phenol tetrachloroethylene and chloroform. Chlorobenzene is a constituent of phenol and pesticides and phenol is a constituent of solvents 6. Tetrachloroethylene was also detected at ABCAR Auto Parts. The source of tetrachloroethylene may be from a neighboring dry-cleaning establishment. Chloroform is likely to be a laboratory contaminant. Groundwater analytical data indicated that VOCs exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards at the following six automobile salvage yards: • Snake Road Auto Salvage, Inc. in Stuart, Martin County • Wooten's Thousands of Parts in Lake Park, Palm Beach County • Foster's Auto Crushing, Inc. in Orlando, Orange County • ABCAR Auto Parts in Stuart, Martin County • All Parts of Miami, Inc. in Medley, Dade County • Best Used Auto Parts in Miami, Dade County 3. Semi-Volatile Organic Compounds Unleaded gasoline and other petroleum fuels also contain semi-volatile compounds. Seventy-nine groundwater samples were collected. Groundwater samples were collected from permanent or temporary monitoring wells. Analytical results indicated semi-volatiles exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards in seven samples. Semi-volatiles detected above FDEP groundwater cleanup target levels or Natural Attenuation standards include napthalene, dimethylphenol and benzo(a)anthracene. A list of contaminants and the number of samples that exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for semi-volatiles are provided in Table 9. Naphthalene and dimethylphenol are constituents of unleaded gasoline and dicsct f®I'-NnpldLalene is insoluble anddirnethylphenol is slightly-selublo-M-i atcr6. Betla.are toxic by ingestuwb.-Bemco(a)athcacene is aconstituent o€used.aiL 31 Table 9. Semi-Volatiles Which Exceeded FDEP Groundwater Cleanup Target Levels and Natural Attenuation Standards: Contaminant Cleanup I Natural Target Attenuation Levels Naphthalene 5 2 Dimethylphenol 1 0 Benzo(a)anthracene 1 I Other semi-volatiles detected include acenaphthene, anthracene and benzyl butyl phthalate. These contaminants did not exceed FDEP groundwater cleanup target levels or Natural Attenuation Standards. Anthracene is a constituent of unleaded gasoline and acenaphthene is commonly found in pesticides and fungicides6. Benzyl butyl phthalate is thought to be a laboratory contaminant or was introduced to groundwater during sampling. Benzyl butyl phthalate is a constituent of glue that is used to seal monitoring wells 1. Groundwater analytical data indicated that semi-volatiles exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards at the following five automobile salvage yards: • Snake Road Auto Salvage, Inc. in Stuart, Martin County • Wooten's Thousands of Parts in Lake Park, Palm Beach County • Titusville Auto Salvage, Inc. in Titusville, Brevard County • All Parts of Miami, Inc. in Medley, Dade County • Best Used Auto Parts in Miami, Dade County 4. Total Recoverable Petroleum Hydrocarbons The presence of TRPH is determined FLO-PRO method. This method was designed to measure concentrations of petroleum hydrocarbons in the alkane range of C8- C4032. It does not differentiate between gasoline and oil contamination. However, it does detect other organic compounds that include chlorinated hydrocarbons, phenols and phthalate esters. Since FLO-PRO indicates the presence of petroleum hydrocarbons, it is a good indicator to determine if used oil or petroleum products have been discharged on the ground. Used oil, diesel fuel and heavy oil are considered TRPH. EPA Methods 418.1 and 9073 were previously used to analyze for TRPH. Analytical results indicated that TRPH exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards in five samples. Table 10 shows the number of samples that exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for TRPH. 32 Table 10. Number of samples that exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for TRPH Contaminant I Cleanup Target Natural Levels Attenuation TRPH 5 1_-_ Groundwater analytical data indicated that TRPH exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards at the following three automobile salvage yards: • Barney's Junkyard in Riviera Beach, Palm Beach County • Titusville Auto Salvage, Inc. in Titusville, Brevard County • Best Used Auto Parts in Miami, Dade County Soil analytical data indicated that TRPH compounds were the most common contaminants detected at automobile salvage yards. Consequently, it is not surprising that TRPH exceeded FDEP groundwater cleanup target levels and Natural Attenuation standards at certain automobile salvage yards. Two of the three automobile salvage yards that exceeded groundwater cleanup target levels and Natural Attenuation standards also exceeded soil cleanup target levels and leachability standards. B. Metals .-� Metals are introduced into the environment within dismantling, crushing and storage areas. The primary metals of concern at automobile salvage yards include lead, chromium, cadmium, mercury, arsenic and barium. These metals are toxic and mobile within the environment. Other metals found in soil include selenium, copper and zinc. These metals did not exceed FDEP groundwater cleanup target levels or Natural Attenuation standards. Copper and zinc have minimal human health effects. Test methods used to determine the presence of metals include the following: 29.30 • EPA Methods 200.7, 206.2, 206.3, 6010, 7060 or 7061-Total Arsenic • EPA Methods 200.7, 208.1, 208.2, 6010, 7080 or 7081-Total Barium • EPA Methods 200.7, 213.1, 213.2, 6010, 7130 or 7131-TotalCadmium • EPA Methods 200.7, 218.2, 6010 or 7191-Total Chromium • EPA Methods 200.7, 200.8, 239.2, 6010 or 7421-Total Lead • EPA Methods 245.1 or 7421 -Total Mercury • EPA Method 1311-Toxicity Characteristic Leaching Procedure 1. Lead Analytical results indicated that 37 out of 79 groundwater samples exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for lead. Table 11 shows the number of samples that exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for lead. .r 33 Table 11. Number of samples that exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for lead Contaminant Cleanup Target Natural Levels Attenuation Lead 37 23 Groundwater analytical data indicated that lead exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards at the following eleven automobile salvage yards: • Foster Auto Crushing, Inc. in Orlando, Orange County • U-Pull It/ABC Auto Parts in Tampa, Hillsborough County • Barney's Junkyard in Riviera Beach, Palm Beach County • Titusville Auto Salvage, Inc. in Titusville, Brevard County • Smitty's Auto Wrecking in Apopka, Orange County • Kempton's U-Pull It Used Auto Parts, Inc. in Tampa, Hillsborough County • ABCAR Auto Parts in Stuart, Martin County • All Parts of Miami, Inc. in Medley, Dade County • Auto Connection Foreign Parts in Opa Locka, Dade County • Sailer's Auto Salvage, Inc. in Opa Locka, Dade County • Best Used Auto Parts in Miami, Dade County Lead concentrations above FDEP groundwater clean-up target levels and Natural Attenuation standards ranged from 18.2 ug/L at Foster's Auto Crushing, Inc. to 6.4 mg/L at Sailer's Auto Salvage, Inc. Consequently, lead is relatively mobile-in soils. In addition, fitasstozanditunesize4 sand., wore present at-all-automobile salvage yards indicating-lead contamination.Since sand exhibits high permeability and has a small surface area for adsorption, lead is likely to migrate to grve„dwatet. Groundwater is less than ten feet below land surface at the majority of sites. Lead may also be introduced to groundwater samples. Turbid samples may indicate lead in groundwater samples'I. 2. Chromium Analytical results indicated that chromium exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards in five samples. Table 12 shows the number of samples that exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for chromium. Table 12. Number of samples that exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for chromium Contaminant Cleanup Target Natural Levels Attenuation Chromium 5 1 Groundwater analytical data indicated that chromium exceeded FDEP 34 groundwater cleanup target levels or Natural Attenuation standards at the following four automobile salvage yards: • Snake Road Auto Salvage, Inc. in Stuart, Martin County • Barney's Junkyard in Rivera Beach, Palm Beach County • Titusville Auto Salvage, Inc. in Titusville, Brevard County • Smitty's Auto Wrecking in Apopka, Orange County Chromium concentrations above FDEP groundwater cleanup target levels or Natural Attenuation standards ranged from 0.104 mg/L at Titusville Auto Salvage. Inc. to 3.26 mg/L at Snake Road Auto Salvage, Inc. CTfsegtrentty c11Thmiext..is relatively_ mobile in mar 'n addition, fine to medium-sized sands were present at all automobile salvage yards indicating chromium contamination. Since sand evhihrtc h g{a pen e36ility c1,rfa0e gsea,for adsorptioa, chromium is likely to migrate to groundwater Groundwater is less than ten feet below land surface at the majority of sites. Chromium may also be introduced to groundwater samples. Turbid samples may indicate chromium in groundwater samples" 3. Cadmium Analytical results indicated that cadmium exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards in eight samples. Table 13 shows the number of samples that exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for cadmium. Table 13. Number of samples that exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for cadmium Contaminant Cleanup Target Natural Levels Attenuation Cadmium 8 4 I Groundwater analytical data indicated that chromium exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards at the following six automobile salvage yards: • Snake Road Auto Salvage, Inc. in Stuart, Martin County • Foster's Auto Crushing, Inc. in Orlando, Orange County • Titusville Auto Salvage, Inc. in Titusville, Brevard County • ABCAR Auto Parts in Stuart, Martin County • All Parts of Miami, Inc. in Medley, Dade County • Best Used Auto Parts in Miami, Dade County Cadmium concentrations above FDEP groundwater cleanup target levels or Natural Attenuation standards ranged from 0.009 mg/L at Best Used Auto Parts to 3.0 mg/L at Snake Road Auto Salvage, Inc. Copse , mm is re a !S. In addition, fine to medium-sized sands were present at al I automobile salvage 35 yards indicating cadmium contamination. iiiie sand exhibitshiglapennrahility and has a small surface azea fer.adsecptien, cadmit,.n is likely to migrate to.groundwater. Groundwater is less than ten feet below land surface at the majority of sites. Cadmium may also be introduced to groundwater samples. Turbid samples may indicate cadmium in groundwater samples". 4. Mercury Analytical results indicated that mercury was present within three samples. However, no samples exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for mercury. Mercury concentrations ranged from at 0.42 ug/L at ABCAR Auto Parts to 0.0014 mg/L at Barney's Junkyard:- ince mrrcttry was indicated in groundwater, it appears that it,.is-relativelymobile,in soils. 5. Arsenic Analytical results indicated that arsenic exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards in three samples. Table 14 shows the number of samples that exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for arsenic. Table 14. Number of samples that exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards for arsenic Contaminant Cleanup Target I Natural n Levels Attenuation Arsenic 3 Groundwater analytical data indicated that arsenic exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards at the following three automobile salvage yards: • Barney's Junkyard in Riviera Beach, Palm Beach County • Titusville Auto Salvage, Inc. in Titusville, Brevard County • Smitty's Auto Wrecking in Apopka, Orange County Arsenic concentrations above FDEP groundwater cleanup target levels or Natural Attenuation standards ranged from 0.071 mg/L at Titusville Auto Salvage, Inc. to 0.6 mg/L at Barney's Junkyard.tonsequently, arsenic is relatively mobile in soils. In addition, fine to medium-sized sands were present at all automobile salvage yards indicating arsenic contamination. SinreslrfettrlittvitstigtrpermeabiLity and has a small surface area for adsorption, arsenic is likely to ..Groundwater is less than ten feet below land surface at the majority of sites. Arsenic may also be introduced to groundwater samples. Turbid samples may indicate arsenic in groundwater samples'I. Natural arsenic concentrations in soils may be leaching to groundwater. te."` 36 6. Barium Analytical results indicated that barium was present within six samples. However, no samples exceeded FDEP groundwater cleanup target levels or Natural Attenuation standards. Barium concentrations within groundwater ranged from 35 ug/L at ABCAR Auto Parts to 991 ug/L at Titusville Auto Salvage, Inc. Barium is found in spark-plug alloys and lubricants, but it appears that barium has no significant impact to human health and the environment. The presence of barium apparently is an indicator of other metal contamination at salvage yards. VIII. SOUTHEASTERN STATES SALVAGE YARD REGULATIONS In an attempt to determine how other southeastern states salvage yards comply with state regulations, an Internet search was performed on the following state environmental agencies: Georgia DNR, Alabama DEM, Mississippi DNR, Louisiana DEQ, Texas NRCC, South Carolina DOE,North Carolina DENR, Virginia DEQ, Tennessee DEC, and Arkansas DEQ. For those web pages that have search engines built into them, key words such as `automobile salvage facilities', `automobile salvage yards', `automobile recycling' and `junkyards' were searched. For those states that do not have search engines within the environmental agency's web site, the state regulations were reviewed online for solid waste management and recycling links. Much information was found on the regulation of scrap tire management in Georgia, Mississippi, North Carolina, Virginia, and Tennessee. In most cases, however, little was found that directly addressed automobile junkyards in terms of how we address them in this paper. Several states, such as Alabama, Mississippi, South Carolina, and Virginia addressed standards for owners and operators of hazardous waste treatment, storage, and disposal facilities. However, no standards were set as to whether junkyards could be indirectly considered a hazardous waste storage facility. Some states specifically addressed automobile recycling programs. Georgia, Alabama, and Tennessee addressed standards for recycling of things such as antifreeze, used oil, and batteries. Louisiana's environmental regulations specifically addressed automotive repair shops38. These standards happen to address many similar issues as junkyards. These standards are given in Appendix A. There were only a few states that specifically addressed the issues involved in this paper. Tennessee DEC, for instance, specifically exempts junkyards from regulations for non-hazardous waste. Arkansas DEQ also exempts junkyards from regulations on solid waste material recovery facilities and material recycling facilities39. This exemption can be reviewed in Appendix A. North Carolina has prepared Pollution Prevention Tips: Waste Reduction Options:Automobile Salvage Yards, which directly addresses tips for model junkyard operations40. Although these are not standards, they could go a long way in providing outreach between environmental agencies and junkyard owners and operators. This document can be viewed in Appendix A. 37 Overall,the search for southeastern states regulations for junkyards proved to be discouraging with respect to the proven knowledge that junkyards have a great deal of adverse impact on the environment. Perhaps a more in-depth search would prove positive; it is obvious, though, that junkyards in southeastern states is not a hot issue. Other items of interest regarding Best Management Practices were found in the web search and are also included in Appendix A. One is Stormwater Best Management Practices for the Automotive Recycling Industry, prepared by the national Automotive Recyclers Association". Another document included is Pollution Prevention and Best Management Practices for Automobile and Other Salvage Facilities, prepared by the Pollution Prevention and Remediation Programs Division in Fort Lauderdale, Florida42. Rather than preparing another set of BMPs as a part of this project,these two sets of BMPs should provide ample guidance for auto salvage yard owners and operators. Again, these Best Management Practices are of extreme value in providing outreach to those junkyard owners and operators who need guidance in developing better strategies for junkyard operations. IX. CONCLUSION Dismantling, crushing and storage practices relating to automobile recycling and salvaging vary widely. The record review indicates that the majority of automobile salvage yards do not take the necessary precautions to protect soil and groundwater. Some yards are impacting the environment by discharging automotive fluids on the ground during dismantling, crushing and storage activities. The following conclusions relate to soil and groundwater contamination indicated at the automobile salvage yards detailed in this study. Figures 1-28 are located in Appendix B. A. General Conclusions Regarding Soil and Groundwater Contamination within Dismantling,Crushing and Storage Areas • ^fonstituenls ofgasoliue and petroleum products, used oil and metals are impacting soil and grdundw ' gures). • Automobile salvage yards that discharge automotive fluids on bare ground during dismantling activities have the highest average soil concentrations of TRPH, lead, TCLP lead and arsenic when compared to other practices (Figures I, 2, 3, and 4). • Automobile salvage yards that discharge automotive fluids on bare ground during crushing activities have the highest average soil concentrations of benzene, toluene, ethylbenzene and naphthalene when compared to other practices (Figures 5, 6, 7 and 8). • Satomobih, salvag . yards tfial dis6Tiaige aiTomotive fluids oft r nrrete diving crushing activities have the highest average soil concentrations of xylene when compared to other practices(Figure 9). • Automobile salvage yards that discharge automotive fluids on concrete during dismantling activities have the lowest average soil concentrations of toluene, ethylbenzene, xylene and naphthalene when compared to other practices (Figures 7 through 9). r 38 • Automobile salvage yards that discharge automotive fluids on concrete during crushing activities have the lowest average soil concentrations of TRPH and TCLP lead. (Figures 1 and 4). • Automobile salvage yards that store automotive parts on the ground have the lowest average soil concentrations of benzene and arsenic. (Figures 3 and 5). • Soil contamination indicated within crushing areas relates to gasoline discharges. Benzene, toluene, ethylbenzene, xylene and naphthalene concentrations were highest in these areas. • Soil contamination indicated within dismantling areas relates to discharges of petroleum products and metal-bearing chemicals or wastes. TRPH, lead, TCLP lead and arsenic concentrations were highest in these areas. • All-34 automobile salvage yards had soils visually contaminated with used oil. Heavy may impact groundwater. • The pry found in soil at automobile salvage yards include benzene, tc,IuLue, xylene, ethylbenzene, 1,2,4 trimethyibeozene, TRPH,lead, arsenic, cadmium -mitt chromium. SemcaufdttlOblle salvagL yards had suits that exceeded RCRA regulatory levelsfor Ladiuiuur, chromium and lead. • All 24 automobile salvage yards which exceeded soil or groundwater cleanup target levels,Natural Attenuation standards or leachability standards had soils consisting of fine to medium-grained sands. • The chemical and physical properties of each contaminant may relate to the extent of groundwater contamination. • In this study, the majority of automobile salvage yards exhibiting groundwater contamination had groundwater less than ten feet below land surface. • The primary contaminants found in groundwater at automobile salvage yards inolude benzene, MTBE, naphthalene, TRPH, lead, cadmium,cluumium and arsenic. • Groundwater contamination indicated within storage areas relates to discharges of metal-bearing chemicals or wastes. Lead, cadmium and chromium concentrations were highest in these areas. • Groundwater contamination indicated within crushing areas relates to gasoline discharges. Benzene, MTBE and naphthalene concentrations were highest in these areas. • Lead contamination of groundwater may relate to historic discharges of leaded gasoline on bare ground. • The historic application of arsenic trioxide as a pesticide and herbicide may relate to groundwater contamination. • Metal contamination of groundwater may relate to natural concentrations of metals in soils leaching to groundwater. • Turbid samples may indicate a false positive for groundwater contamination. B. Specific Conclusions Regarding Soil Concentrations within Dismantling, Crushing and Storage Areas • Average concentrations of toluene, naphthalene, ethylbenzene and xylene (EPA 39 Methods 8260, 8270 or 8020) for all sample depths exceeded leachability standards but not residential and industrial target levels for soil (Figures 10 and 11). • Average 1,2,4 trimethylbenzene concentrations (EPA Method 8260) for samples collected at 0'to 2' exceeded residential and industrial target levels and leachability standards for soil (Figures 11 and 12). • Average 1,2,4 trimethylbenzene concentrations (EPA Method 8260) for samples collected at 2' and below exceeded leachability standards but not residential and industrial target levels for soil (Figures 11 and 12). • The highest average concentrations of toluene, ethylbenzene, xylene and 1,2,4 trimethylbenzene (EPA Methods 8260, 8270 or 8020) were indicated in soils collected at 0'to 2' (Figure 12). • The highest average concentrations of naphthalene (EPA Method 8270) were indicated in soils collected at 2' and below (Figure 12). • Average concentrations oftoluene, ethylbenzene, xylene and 1,2,4 trimethylbenzene (EPA Methods 8260, 8270 or 8020) decreased as soil depths increased below land surface (Figure 12). • The lowest average concentrations of toluene, ethylbenzene, xylene and 1,2,4 trimethylbenzene (EPA Methods 8260, 8270 or 8020) were indicated in soils collected at 2'and below(Figure 12). • Average benzene concentrations (EPA Methods 8260 or 8020)for all sample depths exceeded residential and industrial target levels and leachability standards for soil (Figure 13). • The highest average benzene concentrations(EPA Methods 8260 or 8020)were indicated in soils collected at 0'to 2' (Figure 13). • Average TRPH concentrations (FLO-PRO Method or EPA Method 9073) for all sample depths exceeded residential and industrial target levels and leachability standards for soil (Figure 14). • The highest average TRPH concentrations (FLO-PRO Method) were indicated in soils collected at 0'to 2'(Figure 14). • Average arsenic concentrations(EPA Method 6010) for all sample depths exceeded residential and industrial target levels but not leachability standards for soil (Figure 15). • The highest average arsenic concentrations (EPA Methods 6010) were indicated in soils collected at 0'to 2' (Figure 15). • Average arsenic concentrations(EPA Method 6010) for samples collected at 2' and below exceeded residential target levels but not industrial target levels and leachability standards for soil (Figure 15). • Average lead concentrations(EPA Method 6010) for all sample depths exceeded leachability standards but not residential and industrial target levels for soil (Figure 16). • The highest average lead concentrations (EPA Methods 6010) were indicated in soils collected at 0'to 2' (Figure 16). • Average lead concentrations (EPA Method 6010) for samples collected at 2' and below exceeded leachability standards but not residential and industrial target levels (Figure 16). 40 • Average TCLP lead concentrations (EPA Method 131 1) for all soil sample depths exceeded RCRA regulatory levels (Figure 17). • The highest average TCLP lead concentrations (EPA Method 131 1) were indicated in soils collected at 2' and below(Figure 17). • Average TCLP lead concentrations (EPA Method 1311) for samples collected at 0'to 2' did not exceed RCRA regulatory levels for lead (Figure 17). C. Specific Conclusions Regarding Groundwater Concentrations within Dismantling,Crushing and Storage Areas • Average concentrations of MTBE, naphthalene, TRPH, chromium and arsenic for all samples exceeded groundwater clean-up target levels but not natural attenuation standards for groundwater (Figures 18, 19 and 20). • Average concentrations of cadmium, lead and benzene for all samples exceeded groundwater clean-up target levels and natural attenuation standards for groundwater (Figures 19,21 and 22). D. Specific Conclusions Regarding Soil Concentrations Relating to Specific Dismantling,Crushing and Storage Practices • Automobile salvage yards that crushed over bare ground had the highest average concentrations of benzene, toluene, ethylbenzene and naphthalene (EPA Methods 8260, 8270 or 8020)--Figures 5, 6, 7 and 8. • Automobile salvage yards that dismantled over bare ground had the second highest average concentrations of benzene, toluene and naphthalene (EPA Methods 8260, 8270 or 8020)--Figures 5, 6 and 8. • Automobile salvage yards which dismantled over concrete had the lowest average concentrations of toluene, ethylbenzene, xylene and naphthalene (EPA Methods 826 8270 or 8020)--Figures 6, 7, 8 and 9. • Automobile salvage yards that stored automotive parts on bare ground had the lowest average concentrations of benzene (EPA Methods 8260 or 8020) and arsenic(EPA Method 6010)--Figures 3 and 5. • Automobile salvage yards that crushed over concrete had the second highest average concentrations of ethylbenzene (EPA Methods 8260 or 8020) and arsenic (EPA Method 6010)—Figures 3 and 7. • Automobile salvage yards that crushed over concrete had the highest average concentrations of xylene (EPA Methods 8260 or 8020)--Figure 9. • Automobile salvage yards that crushed over bare ground had the second highest average concentrations of xylene (EPA Methods 8260 or 8020) and TCLP lead (EPA Method 1311)--Figures 4 and 9. • Automobile salvage yards which dismantled over bare ground had the highest average concentrations of TRPH (FLO-PRO Method), lead (EPA Method 6010), arsenic(EPA Method 6010) and TCLP lead (EPA Method 131 I)--Figures 1- 4. • Automobile salvage yards that stored automotive parts on bare ground had the second highest average concentrations of TRPH (FLO-PRO Method)--Figure 1. 41 • Automobile salvage yards that crushed over concrete had the lowest average concentrations of TRPH (FLO-PRO Method) and TCLP lead(EPA Method 1311)-- Figure 1. • Automobile salvage yards that dismantled over concrete had the second highest average concentrations of lead (EPA Method 6010)--Figure 2. • Automobile salvage yards that crushed over bare ground had the lowest average concentrations of lead (EPA Method 6010)--Figure 2. E. Specific Conclusions Regarding Groundwater Concentrations Relating to Specific Dismantling, Crushing and Storage Practices • Automobile salvage yards which crushed over concrete had the highest average groundwater concentrations of benzene (EPA Methods 602/8021 or 8260) and naphthalene(EPA Method 8270)--Figures 23 and 24. • Automobile salvage yards which stored automotive parts on bare ground had the second highest average concentrations of benzene (EPA Methods 602/8021 or 826) and naphthalene (EPA Method 8270)--Figures 23 and 24. • Automobile salvage yards which crushed over bare ground had the lowest average concentrations of benzene (EPA Methods 602/8021 or 8260), naphthalene (EPA Method 8270) and lead(EPA Method 239.2)--Figures 23, 24 and 25. • Automobile salvage yards that crushed over bare ground had the highest average concentrations of MTBE(EPA Method 602/8021)--Figure 26. • Automobile salvage yards that dismantled over bare ground had the second highest average concentrations of MTBE (EPA Method 602/8021)--Figure 26. • Automobile salvage yards, which stored automotive parts on bare ground, had the highest average concentrations of lead (EPA Method 239.2), cadmium (EPA Methods 200.7,213.2 and 6010) and chromium (EPA Methods 200.7 and 218.2)--Figures 25, 27 and 28. • Automobile salvage yards that crushed over concrete had the second highest average concentrations of lead(EPA Methods 239.2)--Figure 25. • Automobile salvage yards that crushed over bare ground had the second highest average concentrations of cadmium (EPA Methods 200.7, 213.2 and 6010) and chromium (EPA Methods 200.7 and 218.2)--Figures 27 and 28. • Automobile salvage yards that crushed over concrete had the lowest average concentrations of MTBE (EPA Method 602/8021), cadmium (EPA Methods 200.7, 213.2 and 6010) and chromium (EPA Methods 200.7 and 218.2)--Figures 26, 27 and 28. F. Final Remarks Specific dismantling, crushing and storage practices are impacting soil and groundwater at automobile salvage yards. Unfortunately, the majority of automobile salvage yards exhibiting soil and groundwater contamination are not likely to have the financial resources to assess and remediate soil and groundwater. The majority of automobile salvage yards that are financially capable of assessing or remediating soil and 42 groundwater are unwilling to complete corrective actions. Since soil and groundwater resources are impacted at the majority of the 34 automobile salvage yards detailed in this report, what are the current and future exposures to soil and groundwater contamination? Current exposures to contaminated groundwater include potable and irrigation uses. Some automobile salvage yards have private potable wells. Analytical data for these wells was not available for review. Since groundwater analytical data from assessment activities indicated contamination, it is possible that potable water wells are contaminated at some yards. Therefore, individuals drinking water from potable water wells at some yards known to be contaminated may be consuming metals and other carcinogenic compounds found in petroleum products. In addition, individuals having dermal contact or accidentally ingesting irrigation water contaminated from specific dismantling, crushing and storage practices may be in contact with carcinogenic and mutagenic compounds. Future exposures to contaminated groundwater relate to the construction of potable water wells within a contaminant plume and continued contact with contaminated water. Removing the source of contamination and groundwater remediation may prevent future exposures. Current and future soil exposures to contaminated soil include ingestion, dermal contact and inhalation of wind-blown soil particles. Current exposures are limited to individuals working at or customers pulling parts at automobile salvage yards. Future exposures to contaminated soils relate to the future development of the automobile salvage yard. Individuals likely to be exposed are excavation workers and future tenants. As a final supplement to this report, Table 15 shows some known adverse health effects upon exposure to specific contaminants of concern. Table 15. Some Known Health Effects Upon Exposure to Specific Contaminants,44,4 46, Soil Contaminant of Type of Health Effects Concern contaminant Arsenic Metal Malignant tumors of skin and lungs, cramps, spasms, effects to nervous systems Barium Metal Prolonged stimulant action on muscles, nerve block Benzene VOC Cancer, leukemia, and anemia Cadmium Metal Bronchitis, anemia, gastrointestinal upsets, cancer in rats, affects skin and digestive system Chromium Metal Kidney damage, cancer, lung tumors Ethylbenzene Organic Nervous system, liver, and kidney damage Lead Metal Damage to nervous system, kidneys, reproductive system; cancer in rats Toluene VOC Nervous system, liver, and kidney damage, narcosis, irritation to eyes and respiratory system Xylene Mucous membrane irritant, lung congestion, impairment of kidney functions 43 Since humans are exposed to discharges of carcinogenic and mutagenic compounds relating to specific dismantling, crushing and storage practices, automobile salvage yard owners and operators must minimize or eliminate these discharges. The best method to encourage improved practices is to provide training and technical assistance in proper waste management procedures and environmental rules and regulations. To ensure and promote environmental compliance. FDEP has prepared a document entitled Best Management Practices for Automobile Salvage Yards. This document may be viewed in Appendix C. FDEP intends to conduct compliance assistance visits of automobile salvage yards. These visits will provide technical information on best management practices and environmental regulations. 44 X. REFERENCES 1. Chapter 62-785, Florida Administrative Code, July 6, 1998. 2. Tonner-Navarro, Lisa,N. Christine Halmes and Stephen M. Roberts, Technical Report: Development of Soil Clean-up Target Levels for Chapter 62-785, F.A.C., Final Report dated April 30, 1998. Center for Environmental and Human Toxicology, University of Florida, Gainesville, Florida, April 30, 1998. 3. Guidelines for Assessment of Source Removal of Petroleum Contaminated Soil. Florida Department of Environmental Protection, Bureau of Petroleum Storage Systems, Tallahassee, Florida, May 1998. 4. Personal conversation with Richard M. Markey, P.G., April 1999. 5. Wolsen, Roger L. and Andy Davis. Predicting the Fate and Transport of Organic Compounds in Water: Part 1. HMC, May/June 1990. 6. Lewis, Richard J. Hawley's Condensed Chemical Dictionary, Twelfth Edition. New York: Van Nostrand Reinhold Company, 1993. 7. Transport and Fate of Contaminants in the Subsurface. Center for Environmental Research Information, United States Environmental Protection Agency, Cincinnati, Ohio, September 1989. 8. LeGrega, Michael, PhillipL. Buckingham and Jeffrey C. Evans. Hazardous Waste Management. New York: McGraw-Hill, Inc., 1994. 9. Overview of the Application of Field Screening Techniques for Expediting and Improving LUST Site Investigation and Remediation. United States Environmental Protection Agency Region IV Training Course. United States Environmental .-. Protection Agency. 10. Final Phase II: Remedial Investigation Agrico Chemical Site Pensacola, Florida, Volume III of IV. Houston: Geraghty& Miller, Inc. Environmental Services. 1993. 11. Personal conversation with Michael S. Kennedy, P.G., April, 1999. 12. Water Related Environmental Fate of 129 Priority Pollutants, Volumes I and II. Office of Water Regulations and Standards, United States Environmental Protection Agency, Washington, D.C., 1979. 13. Aproach to the Assessment of Sediment Quality in Florida Coastal Water: Volume 1- Development and Evaluation of Sediment Quality Assessment Guidelines. MacDonald Environmental Sciences, Limited, Ladysmith, British Columbia, Canada, November 1994. 14. Toxicological Profile for Chromium. Public Health Services, Agency for Toxic Substances and Disease Registry, United States Department of Health and Human Services, Atlanta, Georgia, 1992. 15. Element Concentrations in Soil and Other Surficial Materials of the Conterminous United States: Professional Paper 1270. U.S. Geological Survey, Washington, 1984. 16. McKee, J.E. and H.W. Wolf Water Quality Criteria. State Water Quality Control Board, Pub.3-A, Sacramento. California, 1963. 17. Quality Criteria for Water. Office of Water Regulations and Standards, United States Environmental Protection Agency, Washington, D.C., 1986. 18. Scott, Thomas M. and Jacqueline M. Lloyd. Florida's Groundwater Quality Monitoring Program: Hydrogeological Framework. Florida Geological Survey, Tallahassee, Florida, 1991. 45 19. United States Department of Agriculture and University of Florida Agricultural Experiment Stations. Soil Survey of Dade County Area, Florida, 1996. 20. United States Department of Agriculture and University of Florida Agricultural Experiment Stations. Soil Survey of Martin County Area, Florida, 1981. 21. Contamination Assessment Report: M & M Auto Parts and Salvage, Sanford, Florida. Orlando: ESSI Omega, Inc., March 1994. 22. United States Department of Agriculture and University of Florida Agricultural Experiment Stations. Soil Survey of Orange County, Florida, 1989. 23. Preliminary Contamination Assessment Plan: Richards Property, Tampa, Florida. Tampa: Environmental Resources Management-South, Inc., February 1992. 24. Westly, Robert L. Hydrogeology of the Pinellas Peninsula: Pinellas County, Florida. Seaburn and Robertson, Inc., Tampa, Florida. 25. United States Department of Agriculture and University of Florida Agricultural Experiment Stations. Soil Survey of Escambia County Florida, 1960. 26. RCRA Part B Post-Closure Permit Application: Solutia, Inc, Gonzalez, Florida. Tampa: URS Greiner/Woodward Clyde, March 1999. 27. Wilkens, Keithley T., Jeffry R. Wagner and Thomas W. Allen. Technical Report 85- 2: Hydrogeologic Data for the Sand and Gravel Aquifer in Southern Escambia County, Florida. Northwest Florida Water Management District, 1985. 28. Watts, Geoffrey B. Groundwater Monitoring Parameters and Pollution Sources, Third Edition. May 1989. 29. Internet: http://www.speclab.com 30. Chapter 62-770, Florida Administrative Code, September 23, 1997. 31. Watts, Geoffrey B. Groundwater Monitoring Parameters and Pollution Sources, Third Edition, Shreve et al., 1977, Standard Oil Company, 1981 and Verschueren, 1983. 32. Florida Residual Petroleum Organic Method (FL-PRO): Petroleum Cleanup Guidance Document#7. Florida Department of Environmental Protection, Tallahassee, 1996. 33. Effects of Organic Solvents on the Permeability of Clay Soils. Municipal Environmental Research Laboratory Office of Research and Development, United States Environmental Protection Agency, April 1983. 34. Florida Automotive Recyclers Handbook: Reducing and Managing Hazardous Wastes (Draft). Florida Department of Environmental Protection and Florida Center for Solid and Hazardous Waste Management, January 1999. 35. Internet: http://www.atsdr.cdc.gov 36. Garrett, Peter, Marcel Moreau and Jerry D. Lowry. Methyl Tertiary Butyl Ether as a Groundwater Contaminant. Proceedings of Petroleum Hydrocarbons and Organic Chemicals in Groundwater Conference. National Water Well Association,Nov.1986. 37. Introduction to Groundwater: Contamination, Investigation and Remediation Assessment. University of Florida TREE() Center, Gainesville,Florida, 1996. 38. Internet: http://www.deq.state,la.us/osec/latap03.htm 39. Internet: http://www.adeq,state.ar.us/solwaste/main.htm 40. Internet: http://es.epa.gov/techinfo/facts/nc/tips6.html 41. Internet: http://www.source3.com/s31/Autorecyc/stormwater.html 42. Internet: http://www.p2pays.org/ref/01/00780.htm 43. Internet: http://www.castle.net/mystic/pages/multpolI.html 46 44. Internet: http://www.siouxlan.com/water/contm.html 45. Internet: http://www.bae.ncsu.edu/programs/extension/publicat/wqwm/ag473_1.html 46. Internet: http://www.pura.com/contamin.htm 47 APPENDICES 48 MAR. 30. 2005 11 :51AM COPART NO. 7769 P. 1/17 • Corporate Headquarters 4665 Business Center Drive FAx . Fairfield, CA 94534 • • Date: d f 3dit S )01) Nwaber of pages including cover sheet: la 1 COPART AUTO AUCTIONS To- Fr : ier 6FS Patti A.Styes: (707)639-5007 phone: Matthew P.Dudttt (707)639-5014 &117) Fax phone; 3. • Di 9t Gregory R.DePeaquale: 207)639-503 CC: Racepdonist: 907)639-5003 Fax phone: (707)6394099 REMARKS: O Urgent ❑ For your review ❑ Reply ASAP O Please comment RE: • • • • • The document being fluted is intended only for the use.of the individual or rutty to wMch it is addressed,and may contain intimation that is privileged. Confidential, and ekempt from disclosure under applicable law. If the index of this message is not the intended recipient, or the employee or agent responsible for delivering the message to the Intended recipient,you are hereby notified that my dissetninatton,diabnbunhn or copying of this communication is saictty prohibited. If you have received this connnunicadon in ertor,please notify us immediately by telephone and return the original message to us at the above address via this United States Poetal Service. Thank you. MAR. 30. 2005 11 : 51AM C0PART N0. 7769 P. 2/17 ENVIRONMENTAL CHEMICAL SOLUTIONS,INC. Copart Auto Auctions TRAINING OUTLINE Emergency Spill Response -Asphalt and Concrete Small Spill(under 1 gallon) 2 Large Spill(1+gallons) 3 Emergency Spill Response-Rock and Dirt Large Spills (1+gallons) 5 Facility Hydrocarbon Maintenance Fuel Area and Cleaning—Spray Method 7 Floor and Shop Cleaning—Sprayer&Brush Method 8 Asphalt Area Cleaning—Sprayer&Brush Method 9 Yard Rock Surface Stain Cleaning—(Under 3' diameter)— Sprayer Method 10 Truck Bed Cleaning—Sprayer&Brush Method 11 How To Fill FM 186-2 Utility Sprayer 12 Order More Supplies 14 What are the Laws? EPA- Policy 98.48.010 15 EPA-Discharging 98.48.080 15 EPA-Penalties for Violations 90.48.140 15 Training Guide-Revision paCopart05 28 021Aoe 03/24/05 MAR. 30. 2005 11 :51AM COPART NO. 7769 P. 3/17 ENVIRONMENTAL CHEMICAL SOLUTIONS,INC. Copart Auto Auctions Best Available Technology/Best Management Practice Emereencv Shill Response -As halt and to The purpose of this plan is to provide guidance for employees of the Copart Auto Auctions in controlling hydrocarbon spills. A Assess situation. B Be safe. C Contain and clean. D Dispose. Small Spills(Under 1 gallon) 1, For minor hydraulic fluid, gas, oil, or other petroleum product spills, spray or squirt FM 186-2 directly onto the spill or sheen until no product odor remains (approximately 1:1). 2. Work the FM 186-2 into the hydrocarbon with a stiff bristle push broom. Add additional FM 186-2 until the odor of the hydrocarbon has been eliminated. Continue to brush to make sure the mixture is uniform, and then soak up with the pads provided.When the gas smell is gone,the hydrocarbon has been completely neutralized and is now in a nonhazardous form. The absorbents can now soak up the solution and be disposed of as a normal, solid waste. NO PRODUCT IS APPROVED TO APPLY DIRECTLY TO SURFACE WATER SUCH AS STREAMS OR RETENTION PONDS. Training Guide-Revteion per Copan 0528 0214oc 2 03/24/05 MAR. 30. 2005 11 :51AM COPART NO. 7769 P. 4/17 ENVIRONMENTAL CHEMICAL SOLUTIONS, INC. .-� Copart Auto Auctions Best Available Technology/Best Management Practice Emergency Spill Response-Asphalt and Concrete Larger Spllls(Over 1 gallon) 1. Locate the source and stop the spill.The contaminated area should be cordoned off and customers and others kept out. To reduce the danger of explosion reduce the vapors by spraying l?M 186-2 solution over entire spill area. Containment of spills is a critical first step,both for safety as well as to protect the environment. 2. Health and safety are primary concerns as a large spill is handled.The use of FM 186-2 to reduce the level of volatile hydrocarbon is also an important step. Even though a complete reaction may not take place,the volatile levels will be significantly reduced during an event.The telltale smell of hydrocarbon is the best indicator as to whether the absorbent contains a hazardous or nonhazardous mixture. 3. Sock booms have been provided to surround the spill. It is imperative that the storm water system be protected from any spilled hydrocarbon. If the spill is large enough, surround storm drains with white oilphillic socks. 4. A large spill requires a phone call to your Regional Safety Manager: Robert Polidori 860-573-5446—Cell 860-665-1184 Ext. 260 - Office Jim Long 314-3O3-5772—Cell 608-249-4523—Office Thad Rodgers 916-715-3688—Cell 916-381-0901 —Office Paul Stevenson 214-551-1022—Cell 972-269-4798—Office 5. After protection has been provided for the storm drain system, assess the extent of the spill. If necessary, absorb raw hydrocarbon in white oilphillic pads. These win be placed in regular plastic trash bags. Training Guide-ncviaion per copart 05_28 02I.ax 3 03/24/05 MAR. 30. 2005 11 :52AM COPART NO. 7769 P. 5/17 ENVIRONMENTAL CHEMICAL SOLUTIONS,INC. Copart Auto Auctions Best Available Technology/Best Management Practice mereencv Spill RespQse-Asphalt and Concrete(continued) 6. When the spill is contained,begin cleanup with FM 186-2 to neutralize the hydrocarbon. Again work the FM 186-2 and the hydrocarbon together with a stiff bristle push broom to completely neutralize the hydrocarbon. Then use the pads provided to absorb this material. As before, if the towels smell like FM 186-2,they are no longer a hazardous waste and may be disposed of as a normal solid waste. 7. Once the spill is contained and there is no danger to personnel or to the environment, then cleaning the remainder of the hydrocarbon can take place. The use of FM-186-2 can then provide a thorough cleaning and removal of the remainder of the hydrocarbon. 8. Should the spill originate from a customer's vehicle,efforts should be made to stop the source of the spill(without taking personal risk). Surround the spill and contain as much as possible.Use of the absorbent booms should provide containment and protection for the stormwater system. 9. The choice of absorbent pads is important.The white oilphillic pads will pick up hydrocarbon but not water. These pads can float on the surface of water and selectively soak up gas and oil. The pads provided will soak up water, gas, oil and hydrocarbon treated with FM 186-2. In a rainy environment, the pads provided will fill up completely and soon be overloaded. 10. Place the white pads and booms at strategic points to provide maximum hydrocarbon collection ability. For example,you might place them at the critical points of entering the storm system, or running into the street. Then, use additional white pads to collect as ninth as possible of the unreacted hydrocarbon. The pads provided can then be used to collect unreacted hydrocarbon if necessary, or if time allows, can be used to collect the FM 186-2/hydrocarbon nonhazardous combination. 11. Fill out Deskmaster form: SPILLRCD and send to the safety group. Training Guide-Revision per Copan 05 28_021.doe 4 03/24/05 MAR. 30, 2005 11 :52AM COPART NO. 7769 P. 6/17 ENVIRONMENTAL CHEMICAL SOLUTIONS,INC. Copart Auto Auctions Best Available Technology/Best Management Practice Emergency Spill Response-Rock and Dirt A ASSESS SITUATION. B BE SAFE. C CONTAIN AND CLEAN. D DISPOSE. Large Spills(Over 1 gallon) Hydrocarbon contamination is most commonly found on paved and asphalt areas. There are times when this contamination falls on soil, gravel or other more porous surfaces. In these cases,the use of the hydrocarbon mitigation agent FM 186-2 is the best available technology for this application. The addition of FM 186-2 begins the remediation of the contamination. As with cleaning procedures, the mixing of the FM 186-2 with the hydrocarbon is important In addition, turning of the surface by mechanical action,increases the oxygen level within the substrate. This enhances the natural bacterial growth which is the key to the elimination of the contamination. The following procedure should be followed for maximum results: 1. Assess the extent of the contamination. This involves both the amount and the area that the hydrocarbon reached. 2. Contact Safety Manager: Robert Polidori 86O-573-5446—Cell 860-665-1184 Ext. 26O -Office Jim Long 7O7-718-6838—Cell 608-249-4523—Office Thad Rodgers 916-715-3688—Cell 916-391-O9O1 -Office Paul Stevenson 214-551-1O22—Cell 972-269-4798—Office tnhns Guide-Revision par Copert 05_28_02140e 5 03/24/05 MAR. 30. 2005 11 :52AM COPART N0. 7769 P. 7/17 ENVIRONMENTAL CHEMICAL SOLUTIONS, INC. Copart Auto Auctions Best Available Technology/Best Management Practice 3. Pour 3 gallons of FM 186-2 solution per cubic yard of soil. Apply this evenly over the contaminated area. Emergency Spill Response-Rock and Dirt(continued) 4. Apply one cup lawn fertilizer to the area. (Note: Be sure that the fertilizer does not contain any additional component that inhibits bacterial growth or weed killer.) 5. Add approximately 10 gallons of water to each cubic yard of soil. Keep the soil moist but do not over water. Too much water will slow the remediation process. 6. In one week apply 2 gallons of FM 186-2 per cubic yard of soil and apply this evenly over the contaminated area. 7. Add 10 gallons of water to each cubic yard of soil. Keep the soil moist but do not over water. 8. After 45 days, sample the area and evaluate progress. This can be accomplished by the presence of hydrocarbon odor. 9. Keep area moist and continue to monitor until hydrocarbon odor is no longer present. Water once a week if it doesn't rain for 45 days. 10.Fill out Deslcnaster. IN ALL CASES 1. Do not allow spilled material to run into storm drains, drainage ditches or any other waterways. 2. Call for assistance if spill is too large to absorb with materials at hand. 3. Use Safety Order form for more supplies. Training Guide-Revision per Copan 05 28_021.doe 6 03/24/05 MAR. 30. 2005 11 : 53AM COPART NO. 7769 P. 8/17 ENVIRONMENTAL CHEMICAL SOLUTIONS, INC. Copart Auto Auctions Best Available Technology/Best Management Practice Facility Hydrocarbon Maintenance Fuel Pump Cleaning-Spray Method The best available technology for this method is the hydrocarbon mitigation product FM 186-2. 1. Spray the cleaning solution onto the pump surface. 2. Scrubbing will aid the product's effectiveness in emulsifying the hydrocarbon. 3. After the hydrocarbon has been removed, wipe down the pump surface and dispose of the toweling in any normal manner. r lhiung Guide.Revision pa Caput 05 28_021.dee 7 03/24/05 MAR. 30. 2005 11 :53AM COPART NO. 7769 P. 9/17 ENVIRONMENTAL CHEMICAL SOLUTIONS, INC. Cop art Auto Auction Best Available Technology/Best Management Practice Facility Hydrocarbon Maintenance(continued) Floor and Shop Cleaning-Sprayer& Brush Method The best available technology for this method is the hydrocarbon mitigation product FM 186-2, 1. Spray the area to be cleaned. 2. Using a stiff brush, scrub the hydrocarbon contaminated area. 3. Collect all liquid with the pads provided then they can be disposed of as normal solid waste. • Tailing Guido-Revision per Copan 0S_2g 021.doc 8 03/24/05 MAR. 30. 2005 11 :53AM COPART NO. 7769 P. 10/17 ENVIRONMENTAL CHEMICAL SOLUTIONS, INC. Copart Auto Auctions Best Available Technology/Best Management Practice Facility Hydrocarbon Maintenance(continued) Asphalt Area Cleaning Heavy deposits of various hydrocarbons build up where vehicles stop or park. These deposits are a major source of contamination in the stormwater system which will eventually contaminate our streams and result in severe degradation of water quality. 1. Using a squirt bottle or utility sprayer, spray the area to be cleaned. 2. With a stiff brush, scrub the hydrocarbon contaminated area. 3. Collect all liquid with the pads provided,they then can be disposed of as normal solid waste. Training Guide-Revision pee Copert o5_28_D21.doe 9 03/24/05 MAR. 30. 2005 11 :53AM COPART NO. 7769 P. 11/17 ENVIRONMENTAL CHEMICAL SOLUTIONS, INC. Copart Auto Auctions Best Available Technology/Best Management Practice Facility Hydrocarbon Maintenance(continued) Yard Rock Surface Stain Cleaning(under 3 Foot diameter) Hydrocarbon contamination is most commonly found on paved and asphalt areas. There are times when this contamination falls on soil, gravel or other more porous surfaces. In these cases,the use of the hydrocarbon mitigation agent FM 186-2 is the best available technology for this application. The addition of FM 186-2 begins the remediation of the contamination. As with cleaning procedures, the mixing of the FM 186-2 with the hydrocarbon is important. In addition,turning of the surface by mechanical action,increases the oxygen level within the substrate. This enhances the natural bacterial growth which is the key to the elimination of the contamination. The following procedure should be followed for maximum results: 1. Assess the extent of the contamination. This involves both the amount and the area that the hydrocarbon reached. 2. Apply 3 gallons of FM 186-2 solution per cubic yard of soil. Apply this evenly over the contaminated area. 3. Apply one cup lawn fertilizer (Ammonium Nitrate)to the area for every 3 gallons of FM-186-2. (Note: Be sure that the fertilizer does not contain any additional component that inhibits bacterial growth or weed killer.) 4. Add approximately 10 gallons of water to each cubic yard of soil. Keep the soil moist but do not over water. Too much water will slow the remediation process. 5. In one week apply 2 gallons of FM 186-2 per cubic yard of soil and apply this evenly over the contaminated area, 6. Add 10 gallons of water to each cubic yard of soil. Keep the soil moist but do not over water. Water once a week if it doesn't rain. 7. After 45 days, sample the area and evaluate progress. This can be accomplished by the presence of hydrocarbon odor. 8. Keep area moist and continue to monitor until hydrocarbon odor is no longer present. Training Guide-Revision pa Copart 05 28_021.doe 10 03/24/05 MAR. 30. 2005 11 :53AM COPART NO. 7769 P. 12/17 ENVIRONMENTAL CHEMICAL SOLUTIONS,INC. Copart Auto Auctions Best Available Technology/Best Management Practice Facility Hydrocarbon Maintenance(continued) Truck Bed Cleaning The delivery of vehicles on truck beds results in hydrocarbon build up on the truck bed surfaces. If allowed to build up,this can result in a severe slip hazard. Additionally,the hydrocarbon build up can add to non-point source pollution when this source is exposed to rain and snow. The best available technology for this cleaning is FM 186-2. 1. Spray the truck bed with FM 186-2 solution. Pay special attention to the areas with the most build-up. Brush areas to provide mixing of the contamination with the FM 186-2 solution. 2. Add enough FM 186-2 solution so the smell of hydrocarbon is not evident. The solution should smell like the cleaning solution. You can tell by smelling the brush or pads. Continue to add FM 186-2 solution until all hydrocarbon odor has been eliminated. 3. Soak up the solution with universal pads,paper towels,kitty litter, or any other universal sorbent. This can be disposed of as a normal solid waste in the garbage. Training Guide-Rcviuon par Copan 05_28 021.doc 11 03/24/05 MAR. 30. 2005 11 : 53AM COPART NO. 7769 P. 13/17 ENVIRONMENTAL CHEMICAL SOLUTIONS, INC. Copart Auto Auctions Best Available Technology/Best Management Practice FM1116-2 Utility Suraver Filling Method The goal of this BMP is to outline the steps necessary to properly fill the FM 186-2 utility sprayer. I. Prepare the sprayer for refilling by releasing the internal air pressure. Lift the red circular valve near the top of the sprayer. This should release the pressure. 2. Grasp the black handle and turn counterclockwise. After one-quarter turn, the handle will be out of the pump. This is the pumping position of the handle. Continue to rotate the handle until both the handle and the lower pump begin to come free of the container. It is tight so the sprayer can build up air pressure to operate the unit. Note: Iry here is printed on the black pump base that secures the handle. This is for maintenance purposes. When opening the unit for filling...DO NOT PRY OPEN THE BASE OF THE HANDLE! 3. Continue to turn the black handle until the handle and pump come loose from the base container. 4. Lift the black handle and pump from the container. 5. Fill the container to the 2-gallon mark with FM 186-2 solution. Do this slowly to minimize the formation of foam. 6. Insert the black handle and pump into the filled container. 7. Rotate the black handle clockwise(about one quarter turn)to connect the handle with the pump. Continue to tighten until both are snug. DO NOT OVERTIGHTEN. 8. Now rotate only the handle one-quarter turn. This frees the handle from the lower pump section and now the handle can be raised and lowered to build pressure in the utility spray container, 9, After building the desired pressure, lower the handle into the pump base and rotate one-quarter turn to lock the handle in place. 'framing Guide-Relator per Copan 03_28_021.doc 12 03/24/05 MAR. 30. 2005 11 :54AM COPART NO. 7769 P. 14/17 ENVIRONMENTAL CHEMICAL SOLUTIONS, INC. Copart Auto Auctions Best Available Technology/Best Management Practice FM 186-2 Utility Sprayer Mine Method(continued) 10. The FM 186-2 utility sprayer is now ready for operation, 11. The sprayer can now be picked up by the handle and transported to the application area. 12. Grasp the nozzle ad press the flow control lever to begin applying FM 186-2. The solution stream can be adjusted by turning the spray control fitting that is positioned on the end of the wand, 13. Each sprayer has an attached detailed instruction manual. Please refer to this manual for additional instructions and information. Training Guide-Revision per Cope[05 28_021.doe 13 03/24/05 MAR. 30. 2005 11 : 54AM COPART N0. 7769 P. 15/17 ENVIRONMENTAL CHEMICAL SOLUTIONS, INC. Copart Auto Auctions Best Available Technology/Best Management Practice Ordering Supplies To order supplies use Deskmaster form ESORDER for all supplies needed. 'Ruining Guide•Revision per Cope 05_28_021.doe 14 03/24/05 MAR. 30. 2005 11 :54AM COPART N0. 7769 P. 16/17 ENVIRONMENTAL CHEMICAL SOLUTIONS, INC. Copart Auto Auctions Best Available Technology/Best Management Practice Laws That Affect You Washington State Law. RCW 90.48.010 Policy enunciated "It is declared to be the public policy of the state to maintain the highest possible standards to insure the purity of all waters of the state consistent with public health and public enjoyment thereof,the propagation and protection of wild life,birds, game, fish and other aquatic life, and the industrial development of the state, and to that end require the use of all known available and reasonable methods by industries and others to prevent and control the pollution of the waters of the state. Consistent with this policy,the state will exercise its powers, as fully and as effectively as possible,to retain and secure high quality for all waters of the state. The state in recognition of the federal government's interest in the quality of the navigable water of the United States, of which certain portions thereof are within the jurisdictional limits of this state,proclaims a public policy of working cooperatively with the federal government in a joint effort to extinguish the sources of water quality degradation,while at the same time preserving and vigorously exercising state powers to insure that present and future standards of water quality within the state shall be determined by the citizenry,through and by the efforts of state government, of the state." RCW 90.48.080 Discharge of polluting matter in water prohibited. "It shall'be unlawfhl for any person to throw, run or otherwise discharge into any of the waters of this state, or to cause,permit or suffer to be thrown,run, drained, allowed to seep or otherwise discharged into such waters any organic or inorganic matter that shall cause or tend to cause pollution of such waters according to the determination of the department, as provided for in this chapter". RCW 90.48.140 Penalty. Any person found guilty of willfully violating any of the provisions of this chapter or chapter 90.56.1tCW, or any final written orders or directive of the department or a court in pursuance thereof shall be deemed guilty of a crime, and upon conviction thereof shall be punished by a fine of up to ten thousand dollars and costs of prosecution, or by imprisonment in the county jail for not more than one year, or by both such fine and imprisonment in the discretion of the court. Each day upon which a willful violation of the provisions of this chapter or chapter 90.56 RCW occurs may be deemed a separate and additional violation. Training aurae-Revision per copal o5_Z8_o21.doo 15 03/24/05 MAR. 30, 2005 11 :54AM COPART NO. 7769 P. 17/17 ENVIRONMENTAL CHEMICAL SOLUTIONS, INC. Copart Auto Auctions Best Available Technology/Best Management Practice "Environmental Chemical Solutions, Inc. is an environmental chemical company that provides products and consulting services to assist businesses in complying with environmental regulations. Environmental Chemical Solutions, Inc. is not a law firm and is not qualified to give legal advice. Therefore,nothing contained herein should be considered as legal advice with respect to the interpretation or application of an federal, state or local law,regulation or ordinance. Nothing contained herein should be interpreted to be any sort of representation of what any enforcement agency may or may not do with respect to the application or enforcement of any federal, state, or local law,regulation or ordinance." • Training Guide-keviaion per Copart OJ-2B 021.doc 16 03/24/05 MAR. 30. 2005 12: 07PM COPART NO. 7771 P. 2 • • tabirational Sits,Lk& ° • r S Swam-sS n bin SST -t ENVIRONMENTAL CIiEIL> + :> cw>a>t �e>nr Ytie ��] r� imr to �JYWIF • - Y Evorgmry 1477.0in 1. • tor smx tya.abepa r &ivbeolmatal Cbmlkd SoMdianb lac. P,O.Box 3029 . . Pit**4 • , . 1w trrnCI•SAIQ-OK(477.253.26165) Oma - nWNW 2lbats.'�WixdetAf�BSorfaegaras Eta Grade'Ifittray its Satan,3- 1.2.Madtltav,1_alms It" MV i0aagt D`O.L Class NatnvStad;poxbswdnus . • . 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