recyclers in violation of the Clean Air Act to pay substantial fines and install capture and add-on pollution controls. As part of the EPA’s enforcement alert, the
EPA recommended that owners and opera- tors of shredders take the following steps to minimize VOC emissions and achieve com- pliance with the Clean Air Act:
(1) Follow best pollution prevention prac- tices by depolluting scrap materials before they enter the shredder; (2) Estimate an hourly annual VOC emis-
sion, using appropriate available test data from similar facilities. If estimated total annual or hourly VOC emissions are below, but near the RACT or NSR/PSD thresh- olds for your area, consult with EPA or the state environmental agency and consider conducting a performance test to measure
actual VOC emissions and to develop a facility-specific emission factor; (3) If estimated emissions are over the
RACT or NSR/PSD thresholds, contact EPA or the state environmental agency to discuss a path forward. In some cases, the installa- tion of capture and add-on pollution con- trols may be required.
Automotive recyclers typically evacuate fluids as part of a depollution process prior to dismantling and crushing. The ARA Cer- tified Automotive Recyclers (CAR) Program and affiliated certification programs require members to maintain depollution, fluid evacuation and disposal best-management practices as part of their general business and environmental standards. ARA is mon- itoring the impact that this increased scru- tiny may have for the industry.
Renew or Apply for ARA’s Certification Program Now!
I
f you are participating in the Certified Automotive Recyclers (CAR) Program or want to be – this is a great time to get your audit completed. This year is a self- audit year so why not get it finished sooner rather than later? All audits are now com- puterized. Please email Sue Schauls at sue.
schauls@gmail.com to order and receive your record. New important HVVD protocols are in place.
Get a jump on your competition by certi- fying first in your area. It is a distinguisher between you and other auto recyclers. Guidance information is available at
https://aracertification.com/ and https://
arauniversity.org/ or by emailing Sue Schauls.
12 // September-October 2021
Automotive Recycling
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