Last week, ISRI participated in EPA’s Vehicle Waste Management and Disposal Workshop, sponsored by the National Homeland Security Research Center (NHSRC) in EPA's Office of Research and Development.
EPA has held similar workshops every several years since 2002. ISRI participated for the first time last week and provided remarks during the Industry Perspective session at the end of the workshop, along with the American Insurance Association (AIA) and Automotive Recyclers Association (ARA).
The workshop focused on addressing the large quantity of vehicles expected to be contaminated in the aftermath of a disaster event, such as a flood, hurricane, earthquake, dirty (nuclear) bomb, nuclear attack, chemical attack (e.g., ricin), or biological attack (e.g., anthrax). There is great interest in recycling as many, and as much, of the contaminated vehicles as possible because (1) landfilling them (with or without decontamination) would be hugely expensive, pose other risks, and take up a lot of landfill space elsewhere and (2) the quantity of contaminated vehicles represents a huge amount of value that should be preserved as much as possible.
As detailed in some presentations, the NHSRC and groups within the U.S. Geologic Survey, Department of Agriculture, and Department of Defense have been developing plans, equipment, and predictive tools for managing contaminated material (not only vehicles) in the aftermath disaster events. For planning purposes, it is important to know how much and what kind of contaminated material to expect, where it is likely to be found, how it can be moved (safely and quickly), and where to stage or store it. Decontamination and decontamination levels (i.e., how clean is clean?) are key issues. Government and the private sector have important roles and should work together to the extent possible.
Even before the Industry Perspective session at the end, it was clear that government needs to have a good disaster response plan that incorporates lessons learned from (at least) Hurricane Sandy and Fukushima. Being unorganized is a threat multiplier. Key relationships, including with the private sector, need to be made in advance.
During the Industry session, AIA discussed vehicle insurance issues, including the National Motor Vehicle Title Information System (NMVTIS). While a vehicle title can be stamped to indicate potential flood damage, there is no title stamp for potentially “radioactive” or “biohazardous.” There is great concern, for instance, about resale of a “disaster” vehicle that has not been adequately decontaminated from anthrax. Anthrax could reside in the AC system, air filter, or other vehicle system, waiting to be airborne again. ARA spoke about vehicle dismantling and parts harvesting. ISRI explained the industry, noting that recyclers are not in the waste management business. ISRI pointed out a host of potential regulatory (not just RCRA) and liability issues under post-disaster conditions. ISRI also emphasized that recyclers will not accept anything for recycling, especially radioactive and biohazardous material.
Government attendees came away with a better understanding of the recycling industry, especially for vehicles, and its operational capabilities and needs. They realize that they have to work closely with the recycling industry to achieve their post-disaster objectives. While next steps are unclear, it seems that ISRI is now on their radar.
Questions about EPA’s Vehicle Waste Management and Disposal Workshop should be directed to David Wagger, Chief Scientist/Director of Environmental Management at (202) 662-8533.