Pollution Prevention Training for Automotive Service …0 Used oil 0 Spent solvents t Other waste...

101 ;bulureJI

ACRONYM LIST

CAA

CERCLA

CESQG

CFC

CFR

CWA

DO1

DOT

EO

EPA

'EPCRA

'FFCA

FIFRA

FP

HRS

HSWA

HMTA

LDR

LQG

MCL

MSDS

NCP

NEPA

NESHAP

Clean Air Act.

Comprehensive Environmental Response, Compensation and Liability Act

Conditionally Exempt Small Quantity Generator

Chlorofluorocarbons

Code of Federal Regulations

Clean Water Act

Department of the Interior

Department of Transportation

Executive Orders

Environmental Protection Agency

Emergency Planning and Community Right-to-Know

Federal Facility Compliance Act

Federal Insecticide, Fungicide and Rodenticide Act

Flash Point

Hazard Ranking Score

Hazardous and Solid Waste Amendments

Hazardous Materials Transportation Act

Land Disposal Restrictions

Large Quantity Generator

Maximum Contaminant Level

Material Safety Data Sheet

National Contingency Plan

National Environmental Policy Act

National Emission Standards for Hazardous Air Pollutants

Environmental Management for the Automotive Industry

Introduction

The following curriculum has been produced to encourage educators, industry and regulatory agencies to build a partnership and promote environmental compliance through education. After completing this course the student will be able to

0 Describe the environmental laws which impact the automotive industry.

0 Describe the liabilities associated with regulatory compliance.

0 Describe the following management standards: 0 Proper container management 0 Proper labeling and marking 0 Pollution preventiodwaste minimization

Spill prevention and clean-up procedures 0 Proper disposal

Recycling and re-use options

For the following waste streams: 0 Used oil 0 Spent solvents t Other waste fluids

Solid waste 0 Paint waste related material

0 Describe the purpose of a self-environmental audit, and how to implement the pogram in an automotive sesvicdcollision repair shop.

0 Complete an environmental audit of an automotive repaidcollisior: repair facility

The long term objectives of this curriculum is to:

0 Protect the environment.

Reduce waste generation.

0 Increase envirom-ental compliance with the applicable state and federal environmental laws and regulations.

0 Prevent future liability associated with non-compliance and improper disposal of hazardous wastes.

0 Improve profitability of an operation through pollution prevention techmques and practices.

Summary

The traditional approach of regulating only major industry groups has also long passed us by. Environmental rules affect neighborhood dry cleaners, liquor stores, and even automotive services and collision repair shops. In this regulatory setting, one can only wonder if “failsafe” management of compliance is indeed, an achievable objective. Yet, the penalties for not complying are far too intimidating to risk anything but extreme diligence towards meeting standards and applying “good management practices.” Civil penalties of up to $25,000 per day are possible. The general theory is that in this day of increased litigation and possible criminal suits, it is better to know your liabilities than to remain oblivious to them. A shop owner must understand that environmental compliance is as important as managing his business. As per a former U.S. EPA General Counsel: “Management ignorance is no defense!”

Table of Contents

Unit 1 Introduction to Environmental Laws and Regulations . . . . . . . . . . . . . . . . . . . . . . . 2

Unit 2 Worker Health and Safety Laws . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Unit 3 Chemical Discharge Control Laws . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

Unit 4 Waste Management and Disposal Laws . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

Unit 5 Regulations Governing Hazardous Waste Transportation . . . . . . . . . . . . . . . . . . . 62

Unit 6 Management Standards for Used Oil Generators . . . . . . . . . . . . . . . . . . . . . . . . . 72

.. Unit 7 Management Standards for Spent Solvent Generators . . . . . . . . . . . . . . . . . . . . . . 88

Unit 8 Management Standards for Waste Paint Generators . . . . . . . . . . . . . . . . . . . . . . 106

Unit 9 Management Standards for Other Waste Fluids -Generated by the Automotive Industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 122

Unit 10 Management Standards for Solid Waste Generated by the Automotive Industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 136

Unit 1 1 The Environmental Audit Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 154

Appendix A Environmental Compliance Self-Audit Sample Checklist

Appendix €3 State and Regional Contact Phone Number List

Appendix C MSDS Information

Introduction To Environmental Laws and Regulations

Student’s Guide

Table of Contents

Unit Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

1 . 0

2.0

3.0

4.0

c-

5.0

Objectives . . . . . . . . . . . . . . . . . . . . . . . . . 4 Unitoverview . . . . . . . . . . . . . . . . . . . . . . 4

Introduction . . . . . . . . . . . . . . . . . . . . . . . . 6

Environmental Background . . . . . . . . . . . . . . 6

Training Requirements . . . . . . . . . . . . . . . . . 9

Federal and State Regulatory Agencies . . . . . . 10 4.1 Statutes . . . . . . . . . . . . . . . . . . . . . 10 4.2 Regulations . . . . . . . . . . . . . . . . . . 11 4.3 Permits . . . . . . . . . . . . . . . . . . . . . 11 4.4 Civil and Criminal Enforcement . . . . . 12

Obtaining Information . . . . . . . . . . . . . . . . 13

Page 2

a

Introduction to Environmental Laws and Regulations

Unit Overview

0 bjectives

After completing this session, you should be able to:

0 List the four major categories environmental laws,

of

0 List which Acts are under each category,

Briefly describe seven environmental laws, 0

0 Define and discuss the terms “statute” and “regulation, ”

0 Discuss permitting and criminal enforcement.

Unit Overview

This unit provides an introduction to environmental laws and regulations. It includes a brief summary of statutes, regulations, permitting, civil and criminal enforcement.

Page 4

INTRODUCTION TO ENVIRONMENTAL LAWS AND REGULATIONS

1.0 INTRODUCTION

The automotive service industry generates the following waste streams:

a Solvents Used oil

a Other waste fluids a Solid waste (tires, scrap metal, etc.)

Paint waste and paint waste related materials a

2.0 ENVIRONMENTAL BACKGROUND c-

Congress has enacted a number of laws to protect human health and the environment. These laws cover such items as:

discharge of pollutants into the air, water and onto land; worker safety and training requirements;

requirements ; requirements for generation, treatment, storage, and disposal of hazardous wastes; and chemical use

and community right-to-how.

These laws can be generally categorized into four major groups :

0 Chemical Use Laws-These include the Toxic Substance Control Act (TSCA), Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and the Occupational Safety and Health Act (OSHA).

0 Chemical Discharge Control Laws-These include the Clean Air Act (CAA), the Clean Water Act (CWA) and the Safe Drinking Water Act (SDWA).

Page 6

0 Waste Disposal Laws-These include the Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and its amendments under the Superfund Amendment and Reauthorization Act (SARA).

0 Chemical Transportation Laws-The primary regulatory authority comes under the Hazardous Materials Transportation Act (HMTA) with additional requirements covered under portions of RCR4.

Each of these relevant laws is described briefly below and in more detail in the following sections.

Laws which affect the automotivekollision repair shop owner include:

0 Toxic Substance Control Act (TSCA) Asbestos is regulated under this law, as a hazardous substance, as well as PCB’s.

0 Occupational Safety and Health Act (OSHA)-This law governs worker protection and mandates safety training for employees worlung with hazardous materials.

0 Clean Air Act (CAA)-This Act controls discharges of pollutants into the air. The Act regulates both stationary and mobile sources of pollution.

0 Clean Water Act (CWA)--This Act controls the discharges of pollutants into surface water

through National Pollution Discharge Elimination System (NPDES) permits.

Page 7

0

a

Safe Drinking Water Act (SDWA)-This Act established Federal primary and secondary

standards for drinking w a t e r , p r o t e c t s groundwater resources through the Underground Injection Control program

(UIC), and restrictions on floor sumps/drains and sand traps.

0 Resource Conservation and Recovery Act

waste (Subtitl

0

0

(RCRA)-The four environmental programs established under RCRA include: hazardous waste (Subtitle C) which requires the tracking and management of hazardous waste from cradle-to-grave, solid waste (Subtitle D), underground storage tanks (Subtitle I) and medical

e J).

CERCLA-The law commonly called "Superfund" is the Comprehensive Environmental

Response, Compensation and Liability Act (CERCLA) of 1980. This

-_ Act requires cleanup of releases of hazardous substances into air, water, ground water, and on land. The Act also requires that

any release of "reportable quantities" of hazardous substances be reported to the National Response Center.

Superfund Amendment and Reauthorization Act (SARA) - This amendment of 1986

reauthorized CERCLA and added major amendments to the Act. A portion of SARA (Title III) provides a

framework for emergency planning and community-right-to-know information.

Page 8

a

0

3.0

Hazardous Materials Transportation Act (HMTA)-The Department of Transportation

(DOT) regulates the transportation of hazardous waste through the HMTA. The law s p e c i f i e s

packaging, marking, labeling, and shipping requirements for hazardous materials. RCRA contains additional requirements for hazardous waste transportation.

TRAINING REQUIREMENTS

A major reason for noncompliance with environmental regulations is the lack of adequate training. Inadequate training may result in releases of pollutants into the environment, improper treatment operations, violations of permit conditions, fines, and injury or death to operating personnel and innocent people. Pollution prevention training should be taught during all facets of

environmental training .... from Hazard Communication Standards through decontamination procedures for hazardous waste operations and emergency response.

There are a number of regulations that require specific training for employees working with hazardous materials and waste.

These include:

0 OSHA Standards 29 CFR 1910; EPA Regulations 40 CFR 262.34; and DOT Carrier Regulations 49 CFR 177.

It is important to understand the basis of the regulations. Environmental compliance, safety, and pollution prevention is EVERYONE'S RESPONSIBILITY.

Page 9

4.0 FEDERAL AND STATE REGULATORY AGENCIES

The laws regulating environmental pollutants, hazardous materials and hazardous waste management are Federal laws passed by Congress and enforced by Federal agencies. Most environmental laws are administered by ‘the U . S . Environmental Protection Agency (EPA). However, other agencies play a role in hazardous

materials regulation. For example, the US. Occupational Safety and Health Administration (OSHA) regulates workplace safety under the Occupational Safety and Health Act.

A

Most environmental laws are not enforced solely by the Federal government. Most states have established their own environmental enforcement programs. These programs are usually s d a r to the Federal program, meeting the minimum Federal requirements, and providing additional regulations where the state believes an issue should receive treatment different from the Federal standard.

The state program must be at least as stringent as the Federal program, and may be more stringent. While the Federal agency retains the right to enforce the laws, you will most likely deal with the state agency on a day-today basis.

If authorized, the state is the primary enforcement agency; issuing permits, enfoxing regulations, and assessing penalties against the regulated community.

4.1 statutes

When people speak about laws, they are usually referring to mtutes. Statutes are laws which are passed by a legislature. They can be Federal laws, passed by the U.S. Congress; state laws, passed by the state legislature; or local laws, passed by a city council. Federal statutes are compiled in the U.S. Code. RCRA, OSHA, and CERCLA are examples of environmental laws passed by the U.S. Congress.

Page 10

Statutes vary in their scope and detail. Some laws are broad policy declarations, such as the National Environmental Policy Act (NEPA). In NEPA, Congress declared the Federal government's policy to operate its programs in a manner that allows man and nature to exist in productive harmony. Under the Clean Air Act (CAA), on the other hand, Congress listed 189 specific air pollutants which had to be regulated under very strict timetables. While NEPA provided broad policy objectives, the Clean Air Act provided a very detailed program for regulating air emissions of specifically identified chemicals.

4.2 Regulations

Regardless of an environmental statute's specificity, it usually requires the agency responsible for enforcing the law to issue reeulations. These regulations " fme tune" the legislation, providing the regulated community with specific guidance on activities which are allowed, and on those which are prohibited.

Agencies such as the EPA or OSHA possess expertise in the field of their regulation. The agency, after receiving public input, issues detailed regulations designed to implement the program set forth in the statute. Regulations provide very specific infomation, such as lists, definitions, testing protocol and permit requirements. Federal regulations are compiled in the Code of Federal Regulations (CFR).

Regulations h ave the full for ce and effect of law -- if you violate an environmental regulation, you may be subject to the administrative, civil, and/or criminal penalties provided for violating the statute itself.

4.3 Permits

A distinctive feature of environmental law is its extensive use of permits. Permits can be viewed as a set of laws or regulations that apply to a specific facility or person. Many environmental laws require persons who engage in regulated activities to obtain a permit. The Clean Water Act, for example, requires permits for all discharges of pollutants to surface waters of the United States. The Clean Air Act may

Page 11

a

require a permit for the discharge of volatile organic compounds (VOCs).

Permits effectively translate broad regulations into site- specific, step-by-step instructions. Permits usually impose a broad range of responsibilities on the permittee, from training requirements, to groundwater monitoring, to the manner in which the facility may be closed.

Violation of a permit carries the same penalties as violation of the law under which the permit was issued.

4.4 Civil and Criminal Enforcement

Most environmental laws provide regulators with an arsenal of enforcement tools, giving them a broad range of enforcement options. These options include:

-_. .

Do nothing

Warning letter

Widespread publicity

Administrative enforcement

Civil action

Revoke or deny permit

Criminal prosecution

Several factors influence that choice, including:

0 The environmental harm or harm to people which resulted from the violation can affect the choice of enforcement action. If a violation causes widespread " h a t i o n , demonstrated injury to human health, or an expensive cleanup, the regulatory agency is likely to respond with an aggressive enforcement action.

Page 12

0 The intent of the violator also affects the enforcement option. Criminal proceedings are usually accompanied by claims that the defendant's actions were reckless or deliberate, and involved some form of conscious wrongdoing.

0 The defendant's history of compliance or noncompliance affects the enforcement action. First time "paperwork" violations are rarely the subject of criminal prosecutions or permit revocation. This does not mean that papenvork violations are viewed as minor -- the record keeping and reporting requirements are central to the success of most regulatory programs. However, first time violations are more likely to be dealt with in the administrative system. Chronic violators of regulations or permits face increasingly severe penalties.

Most enforcement actions target permit holders, which are usually companies and corporations. However, individuals can also be the target of criminal enforcement actions. The U.S. Justice Department's Environmental Crimes Section has acquired over 700 criminal indictments since its inception in 1987. Of those indictments, pearlv 500 were aga - inst 1-s.

5.0 0 B T A I " G IWORMATION

One can obtain specific regulatory information from various sources. These include:

0 The Code of Federal Regulations (CFR) -29 CFR (Labor); -4.0 CFR (Protection of Environment); -49 CFR (Transportation); and

Page 13

c-

The Code of Federal Regulations is available in many different formats. Most county or college libraries contain copies of the CFRs, and they are also available through several vendors or the Government Printing Office.

CFRs are also available , at no charge, over the Internet. Since the Internet addresses are constantly changing, use a worldwide web search engine keyed with the words “CFR, Code of Federal Regulations,” to locate a host site.

State and local laws and regulations A list of state contact phone numbers for each hazardous waste generated is provided in the appendix.

Page 14

1.

2.

3.

4.

5 .

6 .

7.

8.

9.

10.

Review Questions

List the four major categories of environmental laws.

List which Acts are under each category.

Briefly describe seven environmental laws.

Define the term “statute.

Explain the purpose of permits.

Which are more stringent, state or federal regulations?

List the factors which influence criminal enforcement and penalties.

Define the term “regulation.

List the laws which are more likely to impact the automotive industry.

List the acronyms for each of the laws which are more likely to impact the automotive industry.

Page 15

Unit 1 Quiz

What I have learned about

Environmental Laws

1. Which law has the primary goal to pro health and the environment? a. SARA b. CERCLA c. HSWA d. RCRA

ect human

2. Which of the following is NOT a chemical use law? a. SDWA b. FIFRA c. TSCA d. OSHA

3. Which of the following laws is NOT a chemical discharge law? a. CERCLA b. CAA c. CWA d. SDWA

4. Which of the following is NOT a waste disposal law? a. RCRA b. CERCLA c. CAA d. SARA

5 . Which of the following is NOT a chemical transportation law? a. HMTA b. CERCLA c. RCRA

Page 16

c.

6 . Which law controls discharges of pollutants into surface waters? a. RCRA b. CWA c. SDWA d. CAA

7. Which law requires tracking of hazardous chemicals’from “cradle to grave?” a. SARA b. CERCLA c. OSHA d. RCRA

8. Which law provides for emergency response and community right to know regulations? a. CERCLA b. RCRA c. S A R A Title I11 d. OSHA

Page 17

unit 2

Worker Health and Safety

Student's Gbide

Table of Contents

Unit Overview. . . . . . . . . . . . . . . . . . . . . . . . . . 20 Objectives . . . . . . . . . . . . . . . . . . . . . 20 Unit Overview . . . . . . . . . . . . . . . . . . 20

1 .o Introduction . . . . . . . . . . . . . . . . . . . . 22

2.0 Occupational Safety and Health Act (OSHA) 22 2.1 Hazard Communication Standard . . 22 2.2 Work Practices and Engineering Controls

for Automotive Brake and Clutch Operations . . . . . . . . . . . . . . . . 24

Page 18

Worker Health and Safety Regulations

Unit Overview

Objectives


Describe OSHA,

Describe the Hazard Commuri,cation Standard,

Describe the rule for work practices and engineering controls for automotive brake and clutch operations.

Unit Overview This unit provides an overview of the Occupational Health and Safety Act, including hazard communication standard, and brake and clutch operations.

Page 20

WORKER HEALTH AND SAFETY

1.0 INTRODUCTION

Worker health and safety regulations that govern automotive service operations include the hazard communication standard and work practices and engineering controls for automotive brake and clutch operations.

2.0 OCCUPATIONAL HEALTH AND SAFETY ACT (OSHA)

The goal of the Occupational Safety and Health Act of 1970 is to ensure safe and healthful working conditions for workers of firms with greater than 10 employees. The Occupational Safety and Health - . . - - - -. - - . - -. . -

THE BEST WAY Administration was established within - the Labor Department to administer the law.

2.1 Hazard Communication Standard

In 1983, OSHA issued the Hazard Communication Standard (29 CFR 1910.1200). Since then, this regulation has become the source of OSHA's #1 violation. Workplaces where employees are exposed to hazardous chemicals, are required to have a written plan which describes how the standard will be implemented in that facility. The written plan must list the chemicals present at the site, who is responsible for the various aspects of the program, and where and how the written materials will be made available to employees. The key components of the Hazard Communication Standard include the following:

e Hazard assessment - The standard requires all manufacturers and importers of chemicals to determine if a hazard is posed by the product they sell. This information must be provided to their customers in the form of an Material Safety Data Sheet. Employers must use this information to develop a written hazard communication program under the standard. The program must include a

Page 22

list of the hazardous substances used in the workplace and a plan for informing workers and contractors of these hazards.

Material Safety Data Sheets (MSDS) - OSHA requires chemical manufacturers and importers to provide a MSDS with each chemical they sell. An MSDS must give the identity of the chemical, the physi& and chemical characteristics, and the physical and health hazards posed by the chemical. Employers must keep a copy of the MSDS for each chemical used in the workplace and the MSDS must be accessible to employees at all times. See appendix for sample MSDS.

Employee training - Employers are required to train workers in hazardous material handling and where the MSDS's can be found. The training must include information about the hazards of the chemicals used in their work area and about

safety measures employees can take to protect themselves from these hazards. This training must be updated as new chemicals or hazards

are added to the facility, or as employees are moved between work areas.

Labeling of all containers - Provisions 'for labeling all containers must be included in the written program. Every container of hazardous

materials coming into a facility must be labeled with the chemical name, hazard warnings, and name and address of the manufacturer or importer. Some companies use an internal labeling system, which is

permissible as long as the chemical and hazards are clearly identified.

Page 23

0 Extensive record keeping - An annual log of occupational and health issues , including illness and injury, must be kept. Many types of serious injuries and any deaths are required to be reported to OSHA immediately.

2.2 Work Practices and Engineering Controls for Automotive Brake and Clutch Operations

There are more than 150,000 full-time brake and clutch mechanics working with asbestos-containing brake shoes and clutch facings in the United States. New regulations mandate effective asbestos control measures in brake and clutch inspection, disassembly, repair, and assembly operations to further protect workers against unnecessary exposure to asbestos. Proper use of these engineering controls and work practices will reduce employees asbestos exposure to below the permissible exposure level.

c-

These regulations require operations to use one of the following OSHA asbestos dust control procedures.

0 The negative pressure enclosed cylinder/HEPA vacuum system method requirements are as follows:

0 The brake and clutch operation area should be enclosed to prevent the release of asbestos fibers into the workers breathing zone.

0 The enclosure, sleeves and port should be thoroughly inspected for leaks each time before work begins.

0 The enclosure shall allow the worker to clearly see the operation and provide impermeable sleeves through which the employee can handle parts.

Page 24

a A HEPA vacuum should be used to keep the enclosure under negative pressure, to loosen the asbestos residue from the brake and clutch parts, and to clean-up the enclosure.

a The vacuum filter should be wetted with a fine mist of water before removal and placed in an properly labeled impermeable container.

The low pressure/wet cleaning method requires the following:

a Catch basin placed under the brake assembly.

a Water containing an organic solvent should be allowed to flow over the brake assembly to prevent asbestos containing brake dust from becoming airborne.

Equivalent method

a See CFR 29 1915.1001 Appx. L

The wet method requires the following:

a The wet method may only be used in shops where no more than 5 pairs of brakes or clutches are serviced per week.

a A spray bottle or other implement capable of delivering a fine mist of water or other system capable of delivery water at low pressure can be used to thoroughly wet parts.

a The components should be wiped clean with a cloth.

Page 25

The cloth should then be handled as an asbestoscontaining waste, or laundered in way to prevent release of asbestos fibers.

Page 26

Review Questions

1.

2.

3.

4.

What is the goal of OSHA?

Describe the Hazard Communication Standard.

Which automotive parts contain asbestos?

Name the asbestos control measures required by OSHA for automotive brake repair operations.

Page 27

r. .

Unit 2 Quiz


Worker Health and Safety

1. OSHA was designed to ensure healthful working conditions for firms with greater than employees. a. 50 b. 100 C. 1 d. 10

2. Which of the following is required under the Hazard Communication Standard? a. SARA b. MSDS C. OSHA d. PCB’s

3. . W c h of the following is NOT a key component of the Hazard Communication Standard? a. Hazard assessment b. Labeling C. Asbestos controls d. Employee training

4. Which of the following is U T an asbestos control measure? a. Enclosed cylinder/HEPA vacuum method b. Wet method c. Low pressure wet method d. The face mask method

Page 28

unit 3

Chemical Discharge Control Laws

Student’s Guide

Table of Contents

Unit Overview . . . . . . . . . . . . . . . . . . . . . . . . . . 32 Objectives . . . . . . . . . . . . . . . . . . . . . 32 Unit Overview . . . . . . . . . . . . . . . . . . 32

Introduction . . . . . . . . . . . . . . . . . . . . 34

c. ,

1 .o

2.0

3.0

4.0

Clean Air Act (CAA) . . . . . . . . . . . .

Clean Water Act (CWA) . . . . . . . . . .

Safe Drinking Water Act (SDWA) . . . .

34

36

38

Page 30

Chemical Discharge Control Laws

Unit Overview

0 bj ectives


List major provisions of the CAA,

Discuss how the CAA regulations impact the automotive industry,

List the three major portions of the CWA,

List the requirements of the CWA as they pertain to the automotive industry ,

Describe the national drinking water standards and guidelines set forth in the SDWA.

Unit Overview

This unit discusses and defines chemical discharge controls laws, including the CAA, CWA, and the SDWA.

Page 32

CHEMICAL DISCHARGE CONTROL LAWS

1 .o INTRODUCTION

The regulations that govern the discharge of chemicals by the automotive industry into the environment include the Clean Air Act (CAA), Clean Water Act (CWA), and the Safe Drinking Water Act (SDWA). The CAA regulations govern air emissions for solvents, paint booths and fuel storage systems. The CWA and SDWA govern discharges into storm drains, to sewage treatment plants and into septic systems and leach fields. The regulations are discussed further in the following sections.

r - .

2.0 CLEAN AIR ACT (CAA)

The Clean Air Act (CAA) limits emissions of air pollutants from both stationary and mobile sources. The specific regulations for the CAA are located in 40 CFR 50-80. The Clean Air Act of 1990 consisted of amendments to the original act, which

was established in the 1970's. The major provisions of the CAA include:

0 Established National Ambient Air Quality Standards;

0 Regulation of Hazardous Air Pollutants (HAPS);

0 Establishment of pollution performance standards and;

0 Approved State Implemented Programs (SIP).

The CAA required EPA to identify air pollutants that were potentially hazardous to human health and the environment. The act also required EPA to establish national air quality standards for pollutants that are harmful to human health (primary standards) and for those that are harmful to the environment (seconda~~ standards). These National Ambient Air Quality Standards (NAAQS) set standards for six (6)

Page 34

criteria pollutants: total suspended solids, sulfur dioxide, carbon monoxide, nitrogen oxide, ozone and lead.

The Clean Air Act also established standards for regulating Hazardous Air Pollutants (HAPS). HAPs are known to produce adverse health effects at low levels of exposure. Under the new CAA, the EPA and states are developing regulations for 189 HAPS. These new regulations will require sources to adopt Maximum Achievable Control Technology, or MACT standards. Facilities which previously were regulated may be subject to stringent new technology based standards.

Under the Act, the EPA gives the regulatory authority for implementation of the CAA to the states, if the states adopt EPA-approved plans for controlling air pollution. The regulation of air pollution by states is carried out through State Implementation Plans.

This law has a major impact on collision repair facilities. Many of the painting materials used by collision repair operations contain volatile organic compounds (VOCs). These VOCs have been identified as a component in ground level ozone production (smog). In addition, some of the VOCs used in painting materials are also Hazardous Air Pollutants (HAPs) and are now covered under the Air Toxins program. The most common HAPs found in automotive painting materials include toluene, xylene and methyl ethyl ketone. Paints and thinners may contain other VOCs .

Federal and state regulations generally require operators of automotive refinishing facilities to submit a form to the state

agency describing the facilities operations and estimated emissions. Most state environmental agencies have a hotline or assistance center which can help a shop owner determine it’s regulated status. Facilities which emit in excess of 10 tons of HAPs per year are strictly regulated under CAA provisions. Shops emitting less than 10

tons per year are typically regulated by the state air pollution control division. Emissions and permitting requirements vary by state. It is necessary to contact the state which the facility is located for specific emissions and permitting information.

w Page 35

The new regulations also impact vehicle maintenance shops that repair or service air conditioning systems. Technicians are required to be trained and certified by an EPA-approved organization and registered with the State. Technicians that remove CFCs from air conditioners must use either recoverjhecycle or recovery-only equipment approved by the EPA. Recoveryhecycle equipment has the ability to purify used refrigerant and directly return the refrigerant to the automobile' s air conditioner. Recovery-only equipment transfers the refrigerant to a holding tank. By law technicians must either recycle the used refrigerant on-site or send the CFCs to an off-site, EPA certified reclamation facility.

3.0 CLEAN WATER ACT (CWA)

The Clean Water Act (CWA) provides regulations for discharges into surface waters from all types of sources (municipal, industrial and non- point sources). The specific regulations for the CWA are located in 40 CFR 100-140 and

-* . .-

400-470.

The Act set an ultimate goal to eliminate all discharges into surface water. Until the ultimate goal can be achieved, an interim goal was established to make all surface waters fishable and swimmable. The three major portions of the CWA include: effluent guidelines, water quality standards, and discharges of oil and hazardous substances into surface water.

With proper management of fluids and solid wastes, automotive service operations should not have significant discharges of wastewater to sanitary sewers. In general, any and all waste water discharges must receive prior approval from local wastewater authorities. Either the municipal entity that owns the sanitary sewer lines or the receiving wastewater treatment plant must be notified. Specific requirements may vary from municipality to municipality.

Spent fluids such as oil, solvent, brake fluid, transmission fluid and gasoline must be managed as solid or hazardous

Page 36

waste and either recycled or disposed of off-site. These fluids are normally p r o w from sanitary sewers. Discharges of antifreeze may (check with the local authority) be allowed if quantities are not too large. However, recycling the antifreeze is preferred.

Water quality standards were also established by the EPA for protection of surface waters. EPA has encouraged each state to adopt the national standards or establish more stringent standards to protect all types of surface waters.

Stormwater permits are required for larger vehicle maintenance shops under the transportation categories of SIC codes 4100 - 4199 and 4200 - 4299. However, automotive repair, services, and parking which furnish such services to the general public (SIC code 7500) are not included. Effluent from vehicle washing mv not enter storm se wers or other state waters without a discharge permit.

The third major provision of the CWA established procedures for cleanup of spills of oils and hazardous materials into surface waters. This section of the CWA overlaps with the reportable quantities (RQs) and National Contingency Plan outlined in the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Spills of oils and hazardous materials exceeding the RQ of that material must be reported to the National Response Center. The lead agency for the spill cleanup is either the EPA for inland areas or the U.S. Coast Guard for navigable waters.

The CWA also includes requirements for Spill Prevention, Control and Countermeasure (SPCC) plans for facilities with any tank over 660 gallons or with total oil storage capacity in excess of 1,320 gallons above ground or 42,000 gallons below ground.

An SPCC plan must address engineering provisions included in the design and construction of storage facilities to prevent oil spills. The plan must address steps to be taken to control a spill on-site. Emergency procedures for spills which extend off-site or to surface waters must also be outlined in the plan. SPCC plans are required tobe in place no later than 6 months after startup of the facility, and fully implemented within 12

.

Page 37

months. The SPCC plans must be certified by a registered professional engineer and updated every 3 years. The Oil Pollution Act of 1990 made SPCC planning requirements more stringent, and requires plans for facilities storing hazardous pollutants other than oil.

4.0 SAFE DRINKING WATER ACT (SDWA)

The Safe Drinking Water Act (SDWA) established minimum national drinking water standards and guidelines for protecting groundwater. The specific regulations for the SDWA are located in 40 CFR 140-149.

Under the SDWA, both primary and c. secondary standards were established

for drinking water. Primary standards are for those parameters which, if exceeded, have adverse human health effects. The primary drinking water standards set maximum contaminant levels (MCLs) for a variety of inorganic substances, organic substances, and radio nuclides.

Waste oil may contain levels of benzene and other volatile organic compounds. Waste solvents typically contain a high percentage of chlorinated hydrocarbons. Samples of these fluids typically show levels of these chemicals above MCL levels.

EPA requires service stations owners and operators to inventory injection wells and provide this information of their State UIC Program. Owners or operators who can demonstrate that their well does not threaten underground drinking water sources can apply for a Class V UIC permit.

Page 38

1.

2.

3.

4.

5 .

6 .

7.

8.

Review Questions

Define stationary and mobile sources of air pollutants.

List the major provisions of the CAA.

List the 6 criteria pollutants under the CAA.

List the four general areas of the 1990 Amendments of the CAA.

List the three sources of discharge into surface waters.

List the three major provisions of the CWA.

Describe a NPDES permit.

What are the two major provisions of the SDWA?

Page 39

Unit 3 Quiz

What I have learned about Chemical Discharge

Control Laws

1. Which of the following is NOT a major provision of the CAA? a. Establish National Ambient Air Quality

Standards b. Regulation of hazardous air pollutants c . Establishment of pollution performance

standards d . Approved Federal Implemented Programs

2. Which of the following is NOT a criteria pollutant (NAAQS)? a. Sulfur dioxide b. Ozone c . Mercury d. Lead

3. How many hazardous air pollutants (HAPS) are regulated by the EPA? a. 6 b. Thousands c. 189 d. 1,602

4. Shops which emit in excess of 10 tons of HAPS per year are regulated a. By thestate b. Under CAA provisions c. Under Volatile Organic Compounds d. Bythecounty

Page 40

5 .

6 .

7.

8.

New CFC regulations require a. Technicians to be certified b. Technicians to be approved by the EPA c. Technicians to remove CFCs d. Equipment to be registered with the state

Which of the following is NOT a major provision of the CWA? a. M i n i " national drinking water standards b. Effluent guidelines c. Water quality standards d. Discharges of oil and hazardous substances

into surface water

Which law regulates discharges with a NPDES permit? a. CAA b. SDWA c. CWA d. APEN

Which of the following is BOT a provision under the SDWA? a. Establish minimum drinking water standards b. Establish mini" swimming water standards c. Establish guidelines for protecting

groundwater d. UICprogram

Page 41

unit 4

Waste Management and Disposal Laws

Student’s Guide

Table of Contents

Unit Overview . . . . . . . . . . . . . . . . . . . . . . . . . . 44 Objectives . . . . . . . . . . . . . . . . . . . . . 44 Unit Overview . . . . . . . . . . . . . . . . . . 44

1 .o Introduction . . . . . . . . . . . . . . . . . . . . 46

2.0 Resource Conservation and Recovery Act (RCRA) . . . . . . . . . . . . . . . . . . . . . . 46 2.1 Hazardous Waste Management . . . 49

2.1.1 Identification and Permitting 50 2.1.2 Tracking System . . . . . . 54 2.1 .3 Land Disposal

Restrictions . . . . . . . . . . 54

3.0 Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) . . . . . . . . . . . . . . . . . . . 55

4.0 Superfund Amendment and Reauthorization Act (SARA) . . . . . . . . . . . . . . . . . . . . . 56

Page 42


Unit Overview

Objectives


a List the primary goals of RCRA,

0 Describe the three key elements of the hazardous waste management under RCRA,

0 List the standards applicable to generators of hazardous waste,

0 List the provisions of CERCLA,

List the provisions of SARA Title III.

Unit Overview

This unit provides an overview of the waste management and disposal laws including RCRA, CERCLA and SARA.

Page 44

WASTE MANAGEMENT AND DISPOSAL LAWS

1.0 INTRODUCTION

The regulations that govern waste management and disposal include the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and it’s amendments Superfund Amendments and Reauthorization Act (SARA) Title III. RCR4 regulations have the greatest impact on automotive shops of all the environmental laws because it governs

hazardous waste generators. RCRA also includes regulations governing underground storage systems.

c.

CERCLA provides a system for identification and clean-up of abandoned hazardous waste sites. In addition it established reportable quantities (RQ) for chemicals and reporting requirements for releases of those chemicals. CERCLA also establishes strict joint and severable liability for owners of contaminated properties. A major portion of SARA provides a framework for emergency planning and requires chemical inventory information to be provided to the public. These regulations are explained in more detail in the following sections.

2.0 RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)

The first comprehensive federal effort to deal with hazardous waste came with the passage of the Resource Conservation and Recovery Act of 1976 (RCRA). The Act regulates anyone engaged in the generation, transportation, treatment, storage, or disposal of hazardous waste.

Page 46

The primary goals of RCRA are:

8 To protect human health and the environment,

0 To conserve energy and natural resources,

To reduce the amount of waste generated,

0

8 To ensure that wastes are managed in an environmentally sound manner.

Congress revised RCRA in 1980 and again in 1984. The 1984 amendments-referred to as the Hazardous and Solid Waste Amendment (HSWA)-significantly expanded the scope of RCRA. The specific regulations for RCRA are located in 40 CFR 240-280.

RCRA's Environmental Protection Programs--The Big Four

The four environmental protection programs established to meet the broad goals set under RCRA include:

8 Solid waste,

8 Hazardous waste,

8 Underground storage tanks, and

8 Medical waste.

Subtitle C - The Hazardous Waste Program

One of the primary differences between Subtitle C and Subtitle D is the type of waste each regulates. Subtitle C regulates only hazardous waste, a subset of solid waste, whereas the subtitle D program primarily manages nonhazardous solid waste, Le. trash.

Subtitle C of the Act establishes a program to manage hazardous waste from "cradle-to-grave." The objective of the

Subtitle C program is to ensure that hazardous waste is handled in a manner that protects human health and the environment. Subtitle C regulates the generation and transportation as well as treatment, storage and disposal of hazardous waste. As of June 1989, the EPA has on record more than 7,000 treatment, storage and disposal facilities; 17,000 transporters; and about 180,000 large and small quantity generators.

The Subtitle C program has resulted in perhaps the most comprehensive regulations EPA has ever developed. The first step is to identify those solid wastes that are "hazardous" and then establish various administrative requirements for the three categories of hazardous waste handlers: generators, transporters, and owners or operators of treatment, storage and disposal (TSD) facilities. In addition, the Subtitle C regulations set technical standards for the design and safe operation of TSDs, and management requirements of the generators. These standards are designed to "he the release of hazardous wastes into the environment.

c.

FU btitle D - The Sol id Waste

Subtitle D of the Act requires states to develop and implement solid waste management plans. These plans, among other things, are intended to promote recycling of solid wastes and require closing or upgrading of all environmentally unsound landfills. Due to increased volumes of solid waste, solid waste management has become a key issue facing many localities and states. In recognition of this problem, Congress directed EPA in the HSWA to take an active role with the states in solving the difficult problem of solid waste management.

btitle I -- The Undermound Stor= T& promam

Subtitle I of the Act regulates petroleum products and hazardous substances stored in underground storage tanks (UST). The regulations governing UST's are covered in 40 CFR 280-281. This program is similar to the Subtitle C program in that it may be delegated to the states. In fact, most UST programs are now implemented by the states. The objective of Subtitle I is to prevent leakage to groundwater

Page 48

from UST's and to clean up past releases. Under Subtitle I, EPA has developed performance standards for new tanks and regulations for leak detection, prevention, closure and financial responsibility, and corrective action at all UST sites.

Subtitle J - The Med ical Waste Program

Congress recently added Subtitle J to RCRA to address the problem of medical waste mismanagement.

2.1 Hazardous Waste Management

EPA designed the RCRA regulations to ensure proper management of hazardous waste from the moment the waste is generated until it is destroyed or disposed of. This step-by- step management approach enables EPA and the state to monitor and control hazardous waste at every point in the waste cycle, thereby protecting human health and the environment. The approach to controlling hazardous waste from generation to disposal has three (3) key elements.

Identification and Permitting System-The EPA has established an identification system for generators and transporters of hazardous waste. Through this identification system, EPA issues an ID number to all facilities that manage hazardous waste. In addition, facilities that treat, store, or dispose of hazardous waste are required to obtain a "permit" for these activities.

Tracking System-The tracking system involves the use of a Uniform Hazardous Waste Manifest which tracks the waste from its generation (cradle) to its final destruction or disposal (grave).

Land Disposal Restrictions-The EPA has set restrictions on land disposal of certain waste.

Page 49

2.1.1 Identification and L isting of Haza rdous W a e /40 CFR 261)

This part identifies those wastes subject to regulations as hazardous wastes; it identifies and defines the characteristics which constitute hazardous waste.

Many chemicals used at automotive facilities are hazardous materials; however, they do not become hazardous waste until they are used and discarded or declared a waste. RCRA regulates waste and recycled products; it has no impact on unused materials or materials being processed. Only when recycled or discarded do materials fall under RCRA regulation.

Wastes can be RCRA hazardous wastes in two ways - they can be listed wastes (they appear on an EPA list) or they can be characteristic wastes (they possess a hazardous chemical property.) A waste is RCRA hazardous if it exhibits any of the following characteristics according to Federal standards:

0 Ignitability-Ignitable wastes can create fires under certain conditions (Flash Point I 140" F). Examples include liquids such as low flash point stoddard solvent and paint solvents.

0

0

Codvity-corrosive wastes include those that are strongly acidic @H I 2.0), or alkaline @H 2 12.5), and those that are capable of corroding steel. Examples include sulfuric acid, sodium hydroxide, and hydrochloric acid.

Reactivity-Reactive wastes are unstable under normal conditions. They can create explosions andor toxic fumes, gases, and vapors when mixed with water. Cyanides, sulfides, and explosives are examples of reactive wastes.

Page 50

0 Toxiaty-Toxic wastes are harmful or fatal when ingested, inhaled, or absorbed into the body. The characteristic of toxicity is identified by analysis of liquid from a laboratory procedure called the Toxicity Characteristic Leaching Procedure (TCLP). If materials

contain pesticides such as DDT, organic compounds such as benzene, or metals such as chromium, they may be toxic.

EPA has already determined that some specific wastes are hazardous. These wastes are now incorporated into "listed wastes" published by the EPA. All "listed" wastes are presumed to be hazardous, regardless of their concentrations and must be handled accordingly. These lists include:

0 F List-Hazardous wastes from non-specific sources (including most solvents used in automotive maintenance and most paint solvents);

0 K List--Hazardous wastes from specific sources;

0 P List-Listed acute hazardous wastes; and

0 U List-Listed toxic wastes.

F and K wastes are "process wastes" - they are generally created when the generator uses chemicals in a process, such as degreasing or electroplating. P and U wastes are discarded commercial products, created when the generator throws away unwed product because they are unsuitable for it's needs (expired shelf life, or soils contaminated by a P or U listed waste etc.)

ous waste i4uxEua These regulations establish standards for generators of hazardous wastes. Relevant subparts include the following:

Page 51

0

0

0

0

0

Hazardous Waste Determination. A persodfacility who generates waste must determine if that waste is a hazardous waste.

EPA Identification Number. A generator must not treat, store, dispose, transport, or offer for transportation any hazardous waste without having received an EPA identification number from the Administrator of the P A .

The Manifest. A generator who transports, or offers for transportation, hazardous waste for off- site treatment, storage, or disposal must prepare a Uniform Hazardous Waste Manifest (EPA Form 8700-22 and when necessary, EPA Form 8700- 22A).

Pre-Transportation Requirements. A number of pre-transportation requirements are necessary and include proper packaging, labeling, marking, and placarding.

Accumulation Times. The accumulation times refer to the time waste may be accumulated on site without a treatment, storage and/or disposal permit. These accumulation times allow generators to accumulate batches of waste for shipment. The time requirements are based on the generator status, with larger generators being required to ship more often than smaller ones.

a Large-Quautity Generators (LQG) - LQG's generate more than lo00 kilograms (about 2,200 pounds or 300 gallons) or more of hazardous waste or more than 1 kilogram of acutely hazardous waste (P List) in a calendar month. IQG's may not accumulate waste for more than 90 days. This is the total quantity of waste generated, not per waste S t r e a m .

a Small-Quantity Generators (SQG) -

Page 52

V

SQG's generate more than 100 and less that lo00 kilograms of hazardous waste and no more than 1 kilogram of acutely hazardous waste (P List) in any month. SQG's may not accumulate waste for more than 180 days. Small-quantity generators are allowed a m a y extension ifthewastemustbetransportedmorethan 200 miles to a treatment, storage, or disposal facility.

0 Conditionally Exempt Small Quantity Generator (CESQG) - CESQG's generate less than 100 kilograms of hazardous waste and no more than 1 kilogram of acutely hazardous waste in any calendar month. There is no accumulation time limit for CESQG's. CESQG's may not accumulate more than lo00 kilograms of hazardous waste on site at any one time.

Satellite Accumulation Areas. RCRA regulations allow satellite accumulation areas to be setup neara waste stream source. The date of accumulation is not recorded until the satellite drum is full. Specific regulations vary as to when the start accumulation date must be placed on a drum of hazardous waste. All waste generated on-site must be removed within the allotted time.

Waste Management on Site. RCRA has very specific requirements for managing hazardous waste on site. Consainers must be clearly marked with the words "Hazardous Waste". Containers must be in good condition, stored in a safe and secure location, kept closed except when filling or emptying, and inspected weekly. Incompatible waste cannot be stored in the same container.

Page 53

0 Recordkeeping and Reporting Requirements. EPA requires the generator to keep copies of manifests, weekly inspections (drums), biennial reports, exception reports, any test results, and waste analyses for a period of three years. Land disposal restriction certifications and

notifications must be kept for 5 years.

2.1.2 Track inpavstem (Crad le-to-Gra ve Con-

RCRA requires that hazardous waste be regulated from the time it is created (cradle), through its transportation, treatment, and final disposal (grave). The key component of the "cradle-to-grave" system is the Uniform Hazardous Waste Manifest, the tracking document for the hazardous waste.

. . 2.1.3 Land Dimosal -n (40 CFR 268)

The Land Disposal Restriction (LDR) regulations 'are a direct result of the Hazardous and Solid Waste Amendments (HSWA) of 1984. These amendments required EPA to examine all hazardous waste to determine if any should be banned from land disposal. The amendments prohibited land- disposal of untreated hazardous waste unless EPA finds that there will be "no migration of hazardous constituents.. .for as long as the wastes remain hazardous." Waste that is determined not to pose a health or environmental threat may continue to be dqmsed of on land. If a waste is banned from land disposal, it must be treated and rendered less hazardous before it can be disposed of on land.

The LDR requires the treatment of these wastes prior to land disposal. The basic purpose of the land disposal restrictions is to discourage activities that involve placing untreated materials or waste in or on the land when a better treatment or destruction method exists.

The stringent requirements; set forth in the HSWA affect each facility. A generator must know exactly what is in each waste stream. Waste must be tested and a "Land Disposal Restriction Notification from the Generator" must be

Page 54

submitted to the disposal facility verifying that constituents that have been land banned are in the waste. These procedures have become more difficult with the inclusion of the TCLP (Toxicity Characteristic Leaching Procedure).

Generators must be aware that their wastes may have to be disposed in some manner other than land disposal. Materials disposed on land may require pre-treatment, which will significantly escalate disposal costs. Land disposal may also create tremendous future clean-up costs if leaks occur.

Used Oil Remiations (40 C m

Used oil generators are also regulated under the provision of the Resource Conservation and Recovery Act. These regulations include generator definitions, exemptions, specifications, self-transportation, tolling agreements, and burning in on-site space heaters. Unit 6 discusses used oil management standards in detail.

3.0 COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT (CERCLA)

The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980 provides a system for identifying and cleaning up hazardous substances that

- 2. - , are released into any part of the environment (air, water, ground water, and land). The specific regulations for

300. Provisions of the law include the

. , ,i . ,-’-

I . - .r -, . r the CERCLA are located in 40 CFR - /

following.

0 National Contingency Plan (NCP)-Establishes procedures for cleanup of hazardous materials Spills.

0 National Riority List (NPL)-A list of abandoned or uncontrolled hazardous waste sites which is updated annually.

Page 55

0 Reporting and Responding to Discharges-Spills or releases into the

environment of regulated amounts of hazardous substance must be reported immediately to the National e? Response Center (1-800-424-

8802). The center notifies all appropriate government agencies to coordinate response activities.

0 Reportable Quantities-The National Response Center must be immediately notified if a hazardous substance is released in greater than the regulated reportable quantity (RQ) of that substance. The RQ may be from 1 to 5,000 pounds depending on the substance. The list of RQ's is located in 40 CFR 302.

0 Emergency Response Arrangements-After the National Response Center is notified of a hazardous materials release which exceeds the RQ, the lead responsibility for dealing with the release is immediately assumed by either the U. S . Coast Guard or the EPA, depending on the location and type of release. State/local agencies should also be included in assuming response responsibilities.

4.0 SUPERFUND AMENDMENT AND REAUTHORIZATION ACT (SARA)

The Superfund Amendment and Reauthorization Act (SARA) of 1986 made major changes in the original law. A major portion of

Response and Community Right-to-

m 4 SARA (Title III-Emergency

Know) provides a framework for emergency planning and requires that inventory information be provided to the public. Special provisions of Title III include the following.

Page 56

Emergency Planning-The Emergency Planning Section of EPA is designated to develop emergency response and preparedness capabilities of state and local governments through better coordination and planning, especially within the local community.

Emergency Release-Facilities must immediately notify police, fire, and emergency preparedness agencies if a release in excess of the reportable quantities (RQ) value of a hazardous substance occurs into the environment.

Hazardous Chemical Inventory Reporting-This section requires a facility to submit a hazardous chemical inventory form to the local emergency planning committee, the state emergency planning commission, and the local fire department. This list must include those materials required to have Material Safety Data Sheets (MSDS) under the OSHA Hazard Communication Standard and those that were present at the facility during the previous calendar year if above specified Threshold Planning Quantities (TPQ). For instance, this section would apply to facilities that have chlorine gas (TPQ is 100 pounds).

Toxic Release Inventory Reporting-This section requires facilities that emit specified toxic chemicals to report the release and complete an annual Toxic Chemical Release Form (Form R). The purpose of this reporting requirement is to inform the public and regulatory agencies about routine releases of toxic chemicals into the environment. The data will assist in research and development of regulations, guidelines, standards, and local emergency planning.

Page 57

1.

2.

3 .

4.

5 .

6.

7.

8.

9.

10.

Review Questions

List the primary goals of RCRA.

List the “Big Four” environmental protection programs under RCRA.

List the three key elements of controlling hazardous waste under RCRA.

List the four characteristics of a hazardous waste under RCRA.

Describe F, K, P and U listed hazardous waste.

List the standards applicable to a generator of hazardous waste.

Define LQG, SQG and CESQG.

List the provisions of CERCLA.

Describe the difference between SARA and SARA Title III.

List the special provisions of SARA Title III.

Page 58

1.

2.

3 .

4.

5 .

Unit 4 Quiz



Which law has the primary goal to protect human health and the environment? a. SARA b. CERCLA c. HSWA d. RCRA

Which of the following is NOT one of the “Big Four” under RCRA? a. Hazardous waste program b. The solid waste program c. The liquid waste program d. The underground storage tank program

Which law requires a manifest to track waste from “cradle to grave?’ a. CERCLA b. RCRA c. SARA d. SARA Title III

Which of the following is NOT a hazardous waste characteristic? a. Radioactivity b. Ignitability c. Reactivity d. Toxicity

Which of the following laws regulate used oil? S A R A Title III b. RCRA c. CERCLA d. HSWA

6 .

7.

8.

9.

10.

W c h list includes most solvents used in the automotive industry? a. K List b. F List c. P List d. U List

Which law established requirements for releases of chemicals? a. SARA b. CERCLA c. OSHA d. RCRA

Which law provides for emergency response and community right to know regulations? a. CERCLA b. RCRA c. SARA Title III d. OSHA

Which of the following is NOT a container management requirement? a. Clearly marked "Hazardous Waste" b. Good condition c. Kept closed d. Inspected monthly

Generators are not required to obtain an EPA identification number? a. True b. False

P

Page 60

unit 5

Regulations Governing Hazardous Waste Transportation

Student’s Guide

Table of Contents

Unit Overview . . . . . . . . . . . . . . . . . Objectives . . . . . . . . . . . .

. . . . . .

. . . . . . . 6 4 . 6 4

Unit Overview . . . . . . . . . . . . . . . . . . 64

1 .o Introduction . . . . . . . . . . . . . . . . . . . . 66

2.0 EPA Hazardous Waste Transportation Regulations . . . . . . . . . . . . . . . . . . . . 66

3 .O DOT Hazardous Waste Transportation Requirements . . . . . . . . . . . . . . . . . . . 67

Page 62


Unit Overview

Objectives

After completing t h i s session, you should be able to:

Name the two agencies that regulate the transportation of hazardous waste,

List the general requirements by the EPA to transport hazardous waste,

List the requirements set forth by DOT for transporting hazardous waste.

Unit Overview

This unit provides an overview of the EPA and DOT regulations governing the transportation of hazardous waste.

Page 64

REGULATIONS GOVERNING HAZARDOUS WASTE TRANSPORTATION

1.0 INTRODUCTION

In 1975, Congress passed the Hazardous Materials Transportation Act

- 1- (HMTA) which gave the DOT author& to r e g u l a t e t h e transportation of hazardous materials.

The specific regulations for the HMTA are located in 49 CFR 106-107 and 171-179. Since approximately 1980, both the EPA and DOT govern the transportation of hazardous waste. The transportation of hazardous waste is therefore covered by two sets of regulations:

*

0 EPA regulations (40 CFR Part 263); and

0 DOT regulations (49 CFR Parts 171 and following).

These two sets of regulations are complementary, but not identical. The EPA has expressly adopted certain DOT regulations governing the transportation of hazardous materials. The EPA and DOT worked together to develop these standards to avoid conflicting requirements.

2.0 EPA HAZARDOUS WASTE TRANSPORTATION REGULATIONS

The EPA regulations are designed to track hazardous waste and to avoid spills or other releases of hazardous waste during transportation, and to ensure that any spills are quickly and thoroughly cleaned up.

The EPA standards apply to hazardous waste transporters within the United States which are covered under RCRA 40 CFR Part 263 (Standards Applicable to Transporters of Hazardous Waste).

Page 66

In general, these regulations require the following:

e EPA Identification Numbers-Transporters are required to obtain an EPA Identification Number.

e Manifest System and Recordkeeping-The transporter must operate under the manifest system and keep copies of all manifests received for at least three years.

e Hazardous Waste Discharges-Transporters must take immediate action to clean up any spills that occur during transportation, and, if required by the size or nature of the incident (see CERCLA reportable quantities), report to the NRC and the DOT.

Establishment of requirements for markings, labels, and placards

3.0 DOT HAZARDOUS WASTE TRANSPORTATION REQUIREMENTS

In 1975, the Hazardous Materials Transportation Act (HMTA) was passed. This legislation consolidated the DOT’S regulatory authority over hazardous materials and clarified it’s regulatory and enforcement responsibilities.

Inspection and enforcement

Page 67

-

The regulations goveming the transportation of hazardous materials are set forth in:

a 49 CFR

Part 171, General Information, Regulations and Definitions

Part 172, Hazardous Materials Tables and Hazardous Materials Communication Regulations

Part 173, General Requirements for Shipments and Packaging

Part 177, Carriage by Public Highway (Driver Training, Loading and Unloading, Segregation and Separation and Accidents)

0 Part 178, Specifications for packaging

Extensive revisions to these regulations, commonly called HM-181, were adopted in late 1991 and will become mandatory in phases with full implementation in 1996. Most of these regulatory changes pertain to packaging standards and material classification.

The special training requirements for transporters of hazardous material/waste is regulated under DOT regulation 49 CFR 172 Subpart H and 177.816, EPA regulation 40 CFR 3 11, and OSHA regulation 29 CFR 1910.120. All of these regulations involve specific training requirements for those persons engaged in the handling and/or transportation of hazardous materialjwaste.

Page 68

Review Questions

Name the two agencies that regulate transportation of hazardous waste.

What are the EPA regulations regarding transportation of hazardous waste designed to do?

List the three requirements by the EPA to transport hazardous waste.

List the five general areas of transportation of hazardous waste that the DOT governs.

Describe HMTA.

Page 69

Unit 5 Quiz



1. Which of the following acts regulates transportation of hazardous materials? a. SARA b. CERCLA c. HSWA d. HMTA

2. Which of the following is NOT an issue the EPA regulates regarding transportation of hazardous materials? a. ID number b. Placarding c. Manifest system d. Hazardous waste discharges during

transportation

3. Which of the following is the DOT is responsible for? a. Classification of hazardous materials b. ID numbers c. Manifests d . Hazardous waste discharges during

transportation

4. Which of the following is DOT NOT responsible for? a. Safety standards for containers b. Inspections c. Manifests d. Enforcement

Page 70

5 . Which of the following does NOT regulate training requirements for transporters of hazardous waste? a. DOT b. OSHA c. RCRA d. EPA

.

Unit 6

Management Standards for

Used Oil Generators

Student’s Guide

Table of Contents

. Unitoverview . . . . . . . . . . . . . . . . . . . . . . . . . . 74 Objectives . . . . . . . . . . . . . . . . . . . . . 74 Unit Overview . . . . . . . . . . . . . . . . . . 74

1 . 0 Introduction . . . . . . . . . . . . . . . . . . . . 76

2.0 Definitions . . . . . . . . . . . . . . . . . . . . 77 2.1 UsedOil . . . . . . . . . . . . . . . . . 77 2.2 Used Oil Generator . . . . . . . . . . 77

3.0 Used Oil Regulations . . . . . . . . . . . . . . 78

3.2 Storage Requirements . . . . . . . . . 78 3.3 Transporting Used Oil . . . . . . . . . 79

3.1 Hazardous Waste Determination . . 78

4.0 Managing Used Oil . . . . . . . . . . . . . . . 79 4.1 Recycling . . . . . . . . . . . . . . . . . 79

4.1.1 On-site Recovery . . . . . . 80 4.1.2 Off-site Recovery . . . . . . 81

4.2 Used Oil Filters . . . . . . . . . . . . . 82 4.2.1 Tern-Plated Filters . . . . . 82 4.2.2 Hot Draining Methods . . . 83 4.2.3 Recycling Used Filters . . 83

. 5.0 Spill Prevention and Clean-up . . . . . . . . 83

Page 72

Management Standards for Used Oil Generators

Unit Overview

Objectives


0 Define used oil and used oil generator,

0 Understand how to make a hazardous waste determination ,

0 List the storage requirements for used oil,

e Describe an on-site energy recovery method,

0 List reasons why recycling used oil is a better option than disposal,

e List the requirements used oil filters must meet to be exempt from hazardous waste classification,

e Describe spill prevention and proper clean-up methods.

Unit Overview

This unit discusses all management standards required for used oil generators including regulations, recycling options, and spill prevention and clean-up procedures.

Page 74

MANAGEMENT STANDARDS FOR USED OIL GENERATORS

1.0 INTRODUCTION

The EPA estimates that 1.2 billion gallons of waste oil are generated annually in the United States. It is estimated that

50% of used oil is burned as fuel while 30% is discharged to land or to sewer systems. Used oil contaminated with chlorinated solvents has resulted in many companies being assessed large fines in excess of 1 million dollars, and has implicated other companies as respo'nsible parties in "Superfund" cleanups resulting

in many millions of dollars.

0 Used oil from a single oil change can ruin a million gallons of fresh water.

0 One gallon of used oil will yield 2.5 quarts of lubricating oil. It takes 42 gallons of crude oil to do the same.

0

0

0

0

If the do-it-yourself oil changers recycled their oil, it would save the United states 1.3 million barrels of oil per day.

Used oil is the largest single source of pollution in our nation's waterways.

Used oil can contain toxic substances such as arsenic, benzene, cadmium, lead, and zinc, which can contaminate our groundwater.

One quart of oil is enough to create a two acre oil slick on surface water.

Page 76

-

2.0 DEFINITIONS

2.1 Used Oil

Oil systems perfonn two important functions. They lubricate moving parts and aid in cooling the engine by reducing friction and removing heat from the cylinders. Used oils are the largest component of the spent vehicle fluid waste stream.

The definition of used oil is:

Any oil refined from crude oil or synthetic oil which has been contaminated by physical or chemical impurities as a result of being utilized.

Examples of used oil include:

0 Hydraulic fluid

0 Piston engine crankcase oils 0 Motor oil

e Lubricants e Emulsions e Oil coolants e Transmission fluid

Used oil is not waste oil. Waste oil comes from such sources as virgin fuel storage tank bottoms or virgin fuel oil spill clean-up residue.

2.2 Used Oil Generator

A used oil generator is any business which produces used oil through commercial or industrial operations. Examples of used oil generators include:

a Vehicle/fleet repair shops and service stations

0 Public transportation authorities

Metal working industries

Page 77

3.0 USED OIL REGULATIONS

Used oil generators are regulated under the provision of the Resource Conversation and Recovery Act. These regulations include generator definitions, RCRA exempt ions, specifications, _ _ transportation, tolling agreements, and

burning in on-site space heaters.

3.1 Hazardous Waste Determination

Used oil is prohibited from being disposed of in a landfill, via a dumpster or directly on the ground, and remains exempt from hazardous waste requirements as long as it is recycled or used for energy recovery.

.

If used oil is mixed with characteristic or listed waste (such as halogenated solvents), then the entire mixture becomes hazardous waste. Extreme caution must be exercised in the management of used oil to insure that hazardous waste does not come in contact with used oil.

3.2 Storage Requirements

Storage of used oil must be in units subject to regulation, such as double-walled above ground tanks for large quantities or drums for smaller quantities. All containers storing used oil must be in good condition. Tanks or containers cannot have signs of severe rusting or structural defects. All tanks, fill pipes, drip pans, roll around containers, or any other container which is utilized to store used oil must be clearly labeled with the words "Used Oil. I' Keep lids and bung hole covers tightly sealed on barrels to prevent entry of rain water or other materials into the container.

Floors and secondary containment are required for storage, processing, burning and transfer areas. They must be constructed of material that oil cannot penetrate, such as cement, clay, asphalt, steel or plastic. Storage areas must be equipped with berms, dikes, or retaining walls to prevent spills from contaminating soil, groundwater, or Surface water.

.

Page 78

All leaks or spills must be contained and cleaned up as soon as possible, and measures must be taken to prevent future releases.

Store used oil containers away from hazardous waste storage areas to prevent cross contamination. Remember, if hazardous waste is mixed with used oil, it renders the entire mixture hazardous and must be

disposed of properly.

3.3 Transporting Used Oil

Manifests are not required for shipments of used oil which is to be recycled. Used oil which is disposed of rather than recycled must be manifested, transported, and disposed of as a hazardous waste.

The regulations allow a generator to self transport less than 55 gallons in a personal or company vehicle to an approved collection center.

MANAGING USED OIL I 4*0 Annual oil waste stream volumes have a wide range from 55 gallons to over 70,000 gallons for large fleet maintenance shops, therefore proper management of used oil is essential.

4.1 Recycling

Several options are available for the recycling of used oil, including hydraulic and transmission fluid. These options include:

9 On-site energy recovery I t3% Off-site energy recovery Q Recycle to use as a crude lubricant

Used oil remains exempt from hazardous waste requirements as long as it is recycled or used for energy recovery. It is important not to mix used oil with any other fluids such as antifreeze, chlorinated solvents, gas, degreasers or thinners.

Page 79

This could make purposes.

used oil unacceptable for recycling

4.1.1 On-Site Enerm Reco vew

Burning used oil in an on-site used oil furnace is an acceptable management practice in some areas which can reduce both disposal costs, long term liability and reduces heating costs. Regulations require used oil burners be rated at less than 500,000 British Thermal Units @Tu's) per hour, and gases from the burner be vented to the outdoors. The heater may only be used to bum used oil generated on site or accepted directly from do-it-yourself oil changers.

Several used oil burners offer both heating systems and hot water applications so that year round energy recovery can be accomplished. During the winter, the used oil can be used as a fuel for heat, and during the summer the system can be used to generate hot water for washing and other applications. The up-front expenditures for these systems are easily offset by saving the used oil shipment fees, and the possible liabilities that may be incurred with off-site transportation and recycling.

Oil which is burned in a used.oi1 furnace needs to meet on- specification used oil requirements. The requirements are listed in the following table.

On-Specification Used Oil

Parameters Levels Arsenic 5 PPm Cadmium 2 PPm chromium 10 PPm Lead 100 PPm

Total Halogens 1OOo PPm Flash point 100" F

Note: A level of halogens up to 4,000 ppm is allowed if it can be proven that hazardous waste has not been mixed with the used oil.

Page 80

Off-specification used oil means that the oil exceeds one or more of the above listed parameters. Used oil is considered to be off-specification unless there are laboratory results or other documents to show it is either on-specification used oil or a hazardous waste. It is important to test a representative sample of the used oil being burned and save the results. A shop must keep records of used oil analyses for a m i n i " of three years. The burning of off-specification oil is acceptable provided the provisions of 40 CFR 279, Part 279.23 and Subpart G, Part 279.61 are met.

Used oil burners typically have a filtering stage prior to the burning stage. Solids filtered out may exhibit RCRA toxicity or ignitability characteristics and will need to be tested and handled appropriately.

Check with your local or state regulatory agency to determine if burning used oil is an acceptable method of energy recovery in your area. The CAA restricts burning used oil in non-attainment areas or it may require

special permitting.

4.1.2 Off-Site Ene r g Recovery

Off-site energy recovery through fuel blending and supplemental fuel programs is the most common method for used oil recycling currently utilized by the automotive service industry.

To dispose of used oil off-site for energy recovery, contact a local EPA permitted used oil recovery contractor. Most contractors will pick up used oil at the generator's site and transport it to their facility. Typically, a mini" pick-up fee or a charge per gallon is assessed to the generator.

Generators should carefully select their used oil recovery contractor, since a poorly managed used oil recovery company can cause the generator to be liable for clean-up costs and penalties. Generators should request copies of the used oil recovery company's permits, proof of insurance, SPCC plan, and operating records. The generator should also check with the state or local permitting agency to determine

Page 81

if the used oil recovery company has had any environmental law violations. If practical, the generator should also inspect the company's transfer and storage facilities.

4.2 Used Oil filters

Filters are utilized to remove particulates (debris) from fuel, lubrication, or control (transmission and hydraulic) systems of vehicles. Used oil filters are excluded from hazardous waste requirements if they meet the following criteria:

0 Non-terne plated, and

0 Punctured through the anti-drain back valve or the filter dome end and hot-drained, or

0 Hot-drained and crushed, or

0 Dismantled and hot-drained, or

0 Any other equivalent hot-draining method.

4.2.1 Terne-Plated Filters

To increase the life of filters and to provide for corrosion resistance, some manufacturers plate filters with a lead and tin coating on the internal surface. This type of filter is called a terne-plated filter. Terne-plated filters are now typically only found on heavy equipment, and most heavy equipment operations are discontinuing their purchase. The problem associated with terne-plated filters is the high levels of lead and tin, causing it to fail the TCLP tests for toxicity (exceeding 5 ppm). To determine the levels of leadkin, teme-plated filters must be tested, and if failure of TCLP occurs, they must be handled in accordance with hazardous waste regulations. Repair shops may also check with the filter manufacturer to detennine if the frlter material contains lead. When the repair shop is certain the filter does not contain more than 5 ppm of lead, it may be disposed of in a solid waste landfill in accordance with the EPA regulations listed above.

Page 82

4.2.2 Hot-Draining

The EPA requires that filters be gravity hot-drained for a mini” of twelve hours. Engines must be brought up to or near operating temperature before removal of the filter. It must then be gravity “hot drained” for a minimum of twelve hours after removal. After hotdraining, used filters must not exhibit free liquids when turned drain plate down. Some states require that used oil filters also pass a paint filter test for free liquids prior to disposal. Check with your state regulatory agency for specific information about used oil filter management in your area.

4.2.3 Recvc ling. Used F ilters

Generators are encouraged to recycle the recyclable elements of the oil filter, such as the canister, gasket, and filter paper. The scrap metal recycling exemption under RCRA is applicable to used oil filters if they are recycled. Recycling also eliminates the need to determine if used oil filters are tem-plated are non-teme plated. An undrained or uncrushed oil filter may contain too much oil to qualify for the scrap metal exemption; however, the fdter may be shipped off-site for crushing under the used oil filter exemption, providing the oil is collected for recycling.

Some recyclers of used filters reqUire the filters to be crushed, others will not accept crushed filters. Several commercial fiter crushers are available. In addition, very effective filter crushers have been designed and built from spare parts by on- site maintenance personnel.

5.0 SPILL PREVENTION AND CLEAN-UP

Good housekeeping practices are the best prevention against spills. Use pans and pads under vehicles to contain all fluids being

‘: drained. If the collected fluid will be moved to a larger storage tank, collect the fluid in a mobile tank until full, then transport it to the storage area.

Page 83

Floor dry is commonly used in automotive shops. The saturated floor dry must not show any free liquids to be disposed of as a solid waste. Some states do not allow oil saturated floor dry to be disposed of in landfills. Check with your state regulatory agency to determine if this is an accepted practice in your area.

Oil drips and spills may be cleaned up with the use of specially designed squeegees , mops, and absorbent pads which can be wrung out, reused, and the oil recycled.

Double walled tanks should be used to store large quantities of fluids. Storage tanks should be located close by to reduce accidents, and should be located away from areas where vehicles could accidentally collide into them which could result in a spill.

It is a good management practice to seal off all floor drains throughout your facility and make your operation a dry shop. Take the recycling approach and use a wet-vac or a dry recovery method for spills, thereby preventing any spills from leaving your shop area.

Training employees in the proper methods for cleaning up minor spills and drips can minimize hazardous waste disposal costs.

Page 84

Review Questions

Define used oil.

Define used oil generator.

Describe how to make a used oil hazardous waste determination.

List used oil storage requirements.

Describe an on-site energy recovery operation.

Why should automotive service centers recycle used oil.

List the requirements for used oil filters to be considered exempt from hazardous waste classification.

Describe hot draining.

Describe spill prevention methods for used oil.

Describe clean-up procedures for spilled used oil.

Page 85

Unit 6 Quiz

1.

2.

3.

4.

5

What I have Learned About Managing Used Oil

Which of the following in an example of hazardous waste? a. New antifreeze b. New motor oil c. Used motor oil d. Used motor oil mixed with halogenated

solvents

Which of the following is NOT an example of a used oil generator? a. Vehiclelfleet repair shops b. Restaurant c. Public transportation authorities d. Metal working industries

Used oil remains exempt from hazardous waste requirements as long as it is a. Not very dirty b. Recycled c. Stored correctly d. Used oil is never exempt from hazardous

waste requirements

Used oil containers must NOT be a. In good condition b. Labeled with the words ‘used oil’ c. Open at all times d. Stored on secondary containment

On-site energy recovery a. Is very costly b. Saves hazardous waste disposal costs c. Is very dangerous d. Provides clean oil that can be reused in

engines

Page 86

Used oil filters are exempt from hazardous waste requirements if they a. Are Terne plated b. Punctured correctly and hot drained c. Are NOT drained d. Used oil filters are always exempt from

hazardous waste requirements

Spill prevention methods DO NOT include a. Placing storage tanks away from areas where

vehicles could collide into them b. Locating storage areas far away from workers

to prevent possible accidents c. Use pans under engines and parts d. Vacuum up oil or pour directly into storage

container

.

Oil spills should NOT be cleaned up with a. Specially designed squeegees b. Specially designed mops c. Specially designed absorbent pads d. Shoprags

Page 87

unit 7

Management Standards For

Spent Solvent Generators

Student’s Guide

Table of Contents

. Unit Overview . . . . . . . . . . . . . . . . . . . . . . . . . . 90 Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . 90 Unit Overview . . . . . . . . . . . . . . . . . . . . . . . 90

1 . 0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . 92 1 . 1 Common Solvent Use . . . . . . . . . . . . . . 92

2.0 Regulations . . . . . . . . . . . . . . . . . . . . . . . . . 93 2.1 Hazardous Waste Determination . . . . . . . 93

3 . 0 Pollution Prevention . . . . . . . . . . . . . . . . . . . 95 3.1 SpillPrevention . . . . . . . . . . . . . . . . . 96

4.0 Recycling . . . . . . . . . . . . . . . . . . . . . . . . . . 97 4.1 Off-site Recycling . . . . . . . . . . . . . . . . 97 4.2 On-site Recycling . . . . . . . . . . . . . . . . 97

4.2.1 Gravity Separation . . . . . . . . . . . 97 4.2.2 Distillation . . . . . . . . . . . . . . . . 97

5.0 Alternatives to Solvents . . . . . . . . . . . . . . . . . 98 5.1 Aqueous Cleaners . . . . . . . . . . . . . . . . 98

5.3 MechanicallAbrasive Cleaners . . . . . . . . 100 5.2 Semi Aqueous Cleaners . . . . . . . . . . . . 99

. 6.0 Paint Strippers and Thinners . . . . . . . . . . . . . . 101

Page 88

Management Standards For

Spent Solvent Generators

Unit Overview

0 bj ectives

After completing t h i s session, you should be able to:

0 Understand how to do a hazardous waste determination,

0 Describe the two categories of hazardous spent solvents,

0 List pollution prevention methods for solvents used for degreasing,

0 Describe two on-site recycling methods,

0 List and discuss three alternatives to solvent usage,

0 Discuss waste " i n t i o n techniques for paint strippers and thinners.

Unit Overview

This unit discusses and describes regulations, pollution prevention, recycling methods, and alternatives to solvent use.

Page 90

MANAGEMENT STANDARDS FOR SPENT SOLVENT GENERATORS

1.0 INTRODUCTION

Spent solvents are the largest hazardous waste stream created by the automotive industry.

Spent solvents are dangerous and/or hazardous because they:

b Can persist in the environment for long periods of time.

b Can move easily and seep through landfill liners and contaminate groundwater.

b Can dissolve other toxic compounds and carry them into the environment.

b Evaporate quickly, causing air pollution problems.

Vapors can be inhaled leading to health problems such as cancer.

1.1 Common Solvent Use

A variety of solvents (or degreasers) are used throughout most automotive vehicle and heavy equipment maintenance programs. The waste solvents from parts cleaning often represent the largest single source of hazardous waste from vehicle maintenance and repair operations.

Automotive service operations should make every effort to reduce the use of solvents, particularly halogenated solvents.

Some of the halogenated solvents most commonly used at automotive service operations include:

. Trichloroethylene (TCE), 1,1,1 Trichloroethane (TCA) and 1,1,2 Triflouroethane (CFC 113).

Page 92

2.0 REGULATIONS

Spent solvent waste can be hazardous due to its ignitability, toxicity characteristics, or because it contains listed chemicals. Solvent use and disposal is regulated under RCRA, CAA, and SDWA. As mandated by RCRA, solvents may NEVER be placed in a dumpster, and the SDWA mandates that

solvents are restricted from being discharged to sewer systems. Waste solvents must be recycled or disposed of through an EPA permitted third party for energy recovery or incineration. Solvent filters and residues must also be handled as hazardous waste.

RCRA mandates that spent solvents be stored in metal containers, which are properly labeled, in good condition, and remain closed at all times (except when in use).

For more information concerning container management and the disposal of hazardous waste (spent solvents), please refer to the RCRA regulations found in chapter four.

Check with your state regulatory agency for air permit requirements for VOC emissions related to solvent usage.

2.1 Hazardous Waste Determination

The EPA has devised a system to help solvent users determine if their spent solvents are hazardous waste. Spent solvents which have been determined to be hazardous waste must either possess a hazardous characteristic or property; or be specifically listed by the EPA as hazardous waste.

Characteristic Solvents:

0 Exhibit a flash point below 140 degrees F or 60 degrees C. The MSDS will state the flash point of the solvent prior to use. These solvents are considered ignitable hazardous waste.

Page 93

r

0 Fails a TCLP test for toxicity (e.i., may contain sufficient concentrations of benzene or lead) A list of chemicals and maximum concentrations allowable under the toxicity characteristic are found in 40 CFR 261.24.

0 Listed by Chemical Name and Use

0 A complete roster of solvents are listed in 40 CFR, part 261.31 (Under categories FOOl, F002, F003, F004, and F005)

The EPA has already determined that some specific wastes are hazardous. These wastes are now incorporated into “listed” wastes published by the EPA, and all “listed” wastes are presumed to be hazardous. It is relatively easy to determine whether a spent solvent is a listed hazardous waste. First check the MSDS to see if the ingredients in the solvent are listed, and that the before-use concentration exceeds 10% by volume. Generally, solvent mixtures containing less than 10% by volume of the listed chemicals PRIOR to use are not considered hazardous waste. The 10% rule applies only to unused, fresh solvent. Even if the listed solvents are diluted below 10% during use, the entire mixture now becomes hazardous waste and must be handled appropriately.

.

Several of the common solvents used in the automotive industry and their corresponding F List code include:

0 F List-Hazardous wastes from non-specific sources (including most solvents used in automotive maintenance and most paint solvents);

FOOl Spent halogenated solvents used in degreasing, examples include:

0 tetrachloroethylene e trichloroethylene e methylene chloride

1 , 1 , 1 -trichloroethane

Page 94

F002

m3

FOO4

F005

Spent halogenated solvents, examples include:

0 tetrachloroethylene 0 methylene chloride 0 chlorobenzene

Spent non-halogenated solvents, examples include:

0 xylene

0 ethyl acetate 0 methyl isobutyl ketone

0 acetone


0 cresols 0 cresylis acid


toluene 0 methyl ethyl ketone 0 isobutanol

3.0 POLLUTION PREVENTION

Many opportunities are available to reduce, reuse, recycle, substitute, or eliminate solvent usage.

Do not clean parts unnecessarily

Use prec1eani.q methods such as wire brushing or wiping

he-rinse in a separate partially spent solvent

Use solvents only for cleaning parts

Use drip trays or racks to drain cleaned parts

Allow cleaned parts to drain inside the solvent sink

Page 95

Use the solvent to the ultimate degree

Locate sinks, dip tanks or solvent buckets in a convenient area to "ize dripping and prevent accidental spillage

Turn off solvent stream and cover when not in use

Solvent sinks should be fitted with filters to extend the life of the solvent

Use water-based or citrus-based dillmonine cleaner instead of solvents

Use an on-site solvent recovery unit, this may be cheaper in the long run than off-site recycling

Cleaning can be done in stages to minimize the use of hazardous solvents. For example, a non-hazardous solvent can be used for basic cleaning and the chlorinated solvent used only to remove the residue from the non-hazardous solvent. However, " k i n g the different types of solvents used at a facility will promote recycling by preventing cross- contamination and maintaining waste stream integrity.

3.1 Spill Prevention

Reducing spills is an easy and inexpensive way to save money and reduce the amount of hazardous waste generated. Always transfer solvents and other VOC's by pumping from one container to another using transfer hoses or hard plumbed

lines. Do not clean up solvent spills with shop rags. Remember: if rags contact a "listed waste" then the rags are now a hazardous waste by the mixture rule, and must be handled as hazardous waste. Therefore, disposable rags or wipes should

not be used to absorb hazardous waste spills.

Page 96

4.0 RECYCLING

Solvents may never be placed in a dumpster and should not be 0 discharged into sewer systems. Waste

% solvents may ONLY be disposed of through 0 energy recovery or incineration. A number of recycling options are available which reduce

t? 0

Q disposal costs.

4.1 Off-Site Recycling

Small generators who find it unprofitable to recycle contaminated solvents on-site can send spent solvents to commercial recyclers. Generally, solvent recyclers will reprocess 70 to 80 percent of the solvents into reusable products and sell them back to the generator. You are responsible for any damages or cleanup costs resulting from the accidental release of your spent solvent, so exercise caution when choosing a solvent recycling fm. Make sure the facility returns your manifests to you promptly and keep them forever. All of your empty drums should also be returned to you.

4.2 On-Site Recycling

Gravity separation and distillation are the most common on- site recycling methods.

4.2.1 Gravitv S w

Gravity separation is an inexpensive and easy way to recycle waste solvents. Simply put the solvent sludge mixture into an approved container and allow it to separate under settling conditions. The solvent on the surface can be retrieved and reused, however, the sludge must be disposed of as hazardous waste.

. . . 4.2.2 istillatim

For both large and small quantity generators, an on-site distillation unit may provide a more cost-effective alternative to off-site recycling. The distillation of all high-grade solvent wastes can virtually eliminate the need to purchase lower

Page 97

quality solvents for use in preliminary painting operations and cleanup. Simple heating and condensing units remove impurities from the solvent waste stream, resulting in a cleaned, reusable solvent and a sludge.

For example, from five gallons of paint and solvent waste, the operator can generate four and a half gallons of reclaimed solvent and only one half gallon of sludge that must be disposed of as a hazardous waste.

5.0 ALTERNATNES TO SOLVENTS

The alternatives to solvents in cleaning applications can be classified into four categories.

0 Not cleaning the product or accomplishmg the cleaning process without a solvent

0 Use aqueous (water based) cleaning formulas

0 Use various alternative processes

0 Use a chemical alternative

Degreasing alternatives which do not contain halogenated @ solvents include: aqueous cleaners, semi-

t& &J aqueous (emulsion) cleaners, @ mechanical/abrasive cleaners, and

supercritical C02 cleaners. Changing to 72: one or more of these alternatives is cost

effective when compared with the total cost of solvent management, and to

potential liability.

The most desirable option, but the one that is not likely to be widely accepted, is not cleaning at all.

5.1 Aqueous Cleaners

. Aqueous cleaning refers to a wide range of methods that use water, detergents, acids, and alkaline compounds to displace soil rather than dissolving it in organic compounds.

Page 98

Industrial parts washers provide a promising alternative to solvent cleaners. These washers clean parts using hot water and a surfactant and/or detergent. Most units have an oil- water separator, filters, and sludge collectors. Washers come in various sizes, with the large size capable of handling most parts typically cleaned during vehicle maintenance. The water from the hot water parts washers is recycled within the unit. Many automotive service operations are using these washers and are very satisfied with the results.

Advantages of aqueous industrial parts washers include:

Lower chemical cost

Lower rate of consumption

Lower toxicity

Not flammable or explosive

Oils, and grease can be removed very effectively

Less hazardous waste is generated

5.2 Semi-Aqueous Cleaners

Semi-Aqueous cleaners are products that can be dissolved in water and applied in a manner similar to aqueous cleaners. They can also be applied in concentrated form and rinsed with water. They are called semi-aqueous because they can be used in either fom. Terpenes are semi-aqueous cleaners that may include surfactants, emulsifiers, rust inhibitors, and other additives. Citrus and pine-based terpenes can substitute for CFC-113 and TCA. Both have good cleaning abilities, especially for the removal of heavy grease, carbonized oils, tars, waxes and soils.

Water cleaning fomulations with low levels of additives should be selected where possible. The MSDS of water-based cleaners should be examined thoroughly. Formulations with the components listed under "hazardous ingredients" should be rejected.

Page 99

Cleaners with more neutral pHs should be chosen. If the pH of the concentrate is higher than about 12, the cleaner should not be selected.

Advantages of semi-aqueous cleaners include:

a Compatible with most metals and plastics

a Less vapor loss

a Low viscosity

a Low foaming

a Prevents etching of metals

a Inhibits formation of white residue

a Rinsed with room temperature water

a Generally not corrosive

a Less hazardous waste is generated

Disadvantages include:

a Many of these cleaners harm water quality. Check with local officials to see if the local wastewater treatment plant can accept discharges from such cleaning processes.

5.3 Mechanical/Abrasive Cleaners

Mecharidabrasive cleaning methods include the use of dry wipes, wire brushing, and centrifuges to pre-clean parts. You can use small bake-off ovens to burn dirt or grease, leaving a dry residue that can be brushed or blasted off. Large oven- type devices are available that bake off greases and other residues on large parts such as engine blocks.

Advantages of mechanical cleaners include:

a Small volume of liquid waste

Page 100

Disadvantages include:

0 Bake-off ovens include increased air emissions

0 Need abrasive blasting equipment

6.0 PAINT STRIPPERS AND THINNERS

Paint strippers are used to remove the paint and primer from vehicles and equipment in preparation for repainting. Paint thinners are also used for washing painting equipment and thinning viscous paint.

In reducing solvent use, greater attention should be paid to the methods employed in equipment cleaning. The practice of frUing the cup with solvent, stirring until the paint dissolves, and then repeating the procedure as needed should be discouraged. This solvent-laden paint waste can be significantly reduced by following a staged cleaning procedure.

Paint gun cleaning units can be used to recover solvent for reuse and prevent air emissions. Paint gun cleaners separate paint solids from the solvent and then the solvent is reused. Compared to traditional gun cleaning methods, gun cleaners are beneficial because they reduce raw materials usage, disposal costs, and shop air emissions.

Different types of paint strippers are used depending on the required task. Highly caustic paint strippers are commonly used for stripping the lacquers and enamels used on trucks and heavy equipment. Paint strippers and thinners used for facility maintenance may vary from toxic to more "environmentally friendly " products.

Some paint strippers and thinners are considered hazardous due to their flammability and their chemical constituents (xylene, methylene chloride). Paint strippers used to strip enamels and lacquers from vehicles are often ammonia-based and highly caustic.

Page 101

Waste streams from paint stripping operations may include paint sludge, primer waste, paint stripper/thinner containers, spent solvents/thinners used in paint removal, and cleaning of paint equipment and air emission of VOC's.

The most common disposal method for these types of waste include: disposal at licensed hazardous waste landftlls, recycling off-site (through vendors) of the solvents, and fuel blending for the flammable wastes.

Several alternatives to traditional solventkhemical paint stripping are now available. Plastic media blasting (PMB) may be applicable for some operations. PMB utilizes the concept of sand blasting with the substitution of a plastic for the sand. Paint stripping by PMB is a promising alternative to solvent stripping and is being widely utilized by the Department of Defense for removing paint from aircraft. The spent plastic can be separated from the paint chips and be recycled. The process does produce a small amount of waste (dry paint) but solvents and rinse water are completely eliminated. Also available are glass bead blasting and cryogenic stripping. The use of carbon dioxide pellets have been demonstrated to substantially reduce solvent wastes from paint stripping operations. Shop owners should investigate the available alternatives and determine if they are a viable option.

Page 102

1.

2.

3.

4.

5 .

6 .

7.

8.

9.

Review Questions

Why are solvents considered dangerous to the environment and human health?

Why are most spent solvents a hazardous waste?

Name the two categories of hazardous spent solvents?

Where are hazardous spent solvents listed in 40 CFR?

What does LQG, SQG and CESQG stand for, and describe each?

List the requirements for spent solvent container management.

List pollution prevention methods for degreasing solvents.

Describe gravity separation and distillation.

List three alternatives to solvent use.

10. Describe why a paint gun cleaner should be used.

Page 103

Unit 7 Quiz


Managing Spent Solvents

1. What is the largest waste stream created by the automotive industry? a. Spent solvents I

b. Used oil C. Paint d. Tires

. 2. Spent solvents are NOT a. Ignitable b. Toxic C. Listed hazardous waste d. Caustic

3. Spent solvents are listed in 40 CFR, Part 261.31 under a. F List b. K List C. P List d. U List

4. A small quantity generator meets all of the following requirements except a. Generates >lo0 kilograms of hazardous waste

per month b. Generates > lo00 kilograms of hazardous waste

per month c. Generates no more than 1 kilogram of acutely

hazardous waste per month d. May accumulate waste up to 6000 Kilograms

Page 104

5 . Which of the following is a storage requirement for spent solvents? a. b. c. d.

Remain open to allow evaporation Must be stored on drip pads Must be visually inspected once a month Must be clearly marked “Spent Solvent”

6. To reduce solvent use a.

b. c.

d.

Always begin the cleaning process by dipping into solvent first Use drip trays and racks Locate sinks, dip tanks far away from workers to prevent work hazards Allow cleaned parts to dry on disposable towels

7.

8.

On-site recycling includes a. b. Using gravity separation c. d.

Burning solvent for energy recovery

Allowing spent solvents to evaporate Using spent solvent for kerosene lamps to provide lighting

Which of the following is NOT an alternative to solvent use? a. Aqueous cleaners b . Semi-aqueous cleaners C. Chlorinated cleaners d. Plastic media blasting

Page 105

unit 8 Management Standards

for Waste Paint Generators

Table of Contents

Unit Overview . . . . . . . . . . . . . . . . . . . . . . . . . 108 Objectives . . . . . . . . . . . . . . . . . . . . . . . . . 108 Unit Overview . . . . . . . . . . . . . . . . . . . . . . 108

1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . 110

2.0 Paint Process . . . . . . . . . . . . . . . . . . . . . . . 110

3 . 0 Paint Equipment . . . . . . . . . . . . . . . . . . . . . 112

4.0 Paint Application Techniques . . . . . . . . . . . . 113

5 . 0 Equipment Cleaning Processes . . . . . . . . . . . . 113

6.0 Paint Booth Filters . . . . . . . . . . . . . . . . . . . 114

7.0 Waste Minimization Opportunities . . . . . . . . . 114

Page 106

Management Standards for

Waste Paint Generators

Unit Overview

Objectives


Explain what environmental laws regulate painting operations,

0 List several “less toxic” versions of paints, primers, and sealers,

b Describe the new types of spray equipment available and the benefits of using this equipment,

0 Explain why proper training and techniques are important in reducing paint waste and VOC emissions,

0 Describe waste minimization techniques which can decrease hazardous waste and air emissions.

Unit Overview

This unit describes and discusses environmental laws which regulate paint waste, ”less toxic” alternatives, new types of paint equipment, proper disposal of paint waste, and waste minimization techniques available to shops which engage in painting operations.

Page 108

MANAGEMENT STANDARDS FOR WASTE PAINT GENERATORS

1.0 INTRODUCTION

Ninety percent of toxic releases from the automobile industry occur primarily from surface coating and painting operations. These operations generate waste regulated under the Clean Air Act (CAA) and the Resource Conservation and

Recovery Act (RCRA).

Hazardous waste streams which must be managed according to RCRA regulations can include leftover paint, paint sludge, primer waste, paint containers, spent solventlthinners from paint removal and cleaning of painting equipment, and spray paint booth filters.

c-

Under the CAA, chemicals known as volatile organic compounds (VOCs) and hazardous air pollutants (HAPS) are targeted for regulation and control. These chemicals are found in many solvents used in the painting industry. The EPA has estimated that the automobile refinishing industry is responsible for over 287,000 tons of VOCs released in the United States every year. As much as 20 lbs of organic solvents may be emitted during the surface coating of just one medium-sized automobile.

Some paints are considered hazardous due to the heavy metals they may contain, including arsenic, lead, cadmium, chromium and zinc. Certain types of paints may contain hazardous solvents. Many paints, primers, lacquers and enamels are flammable.

2.0 PAINT PROCESS

... The paint process consists of surface preparation, some type of undercoating or prep coat, and a topcoat or surface coat and possibly a clear coat. Different types of paints and solvents are used, depending upon the task to be completed. . .~ .

Page 110

r -

Before painting, the vehicles are cleaned to remove dirt, tar, grease, and grime. Dirt and grime should be washed from the vehicle using soap and water, or a waterborne cleaner. Solvents should be used sparingly, if at all.

The undercoat is defined as all materials applied directly over the substrate and includes prep coats, primer-surfacers, primer-sealers , and sealers. These can release significant volumes of VOCs. Many different types of primers are available and have varying features. Some of the newer primers are water-based and contain reduced VOCs. Epoxy primers are widely used and can be solvent or water based. Products such as epoxy primers or self-etching primers may lessen the need for additional surface coating operations. Some epoxy primers may have a pot life of as little as 6-8 hours, whch may increase the amount of waste generated if not used carefully. Some of these primers and primer- surfacers contain lead and chrome, and their activators may contain isocyantes. Primer-sealers used should be low VOC single component waterborne, Waterborne epoxy primers, or urethane.

Sealers are applied prior to the topcoat, if needed, to provide adhesion, seal sanded surfaces, and fill minor imperfections. Sealers are usually lacquer, enamel, or urethane. When choosing a sealer, be sure the sealer color can be covered by the next coating, or choose a tintable sealer.

Topcoats can be either solid color paints or metallics. Solid color paints are made up of solvents, binders, and opaque pigments that produce the color. Metallic paints also include solvents, binders, color pigments, and small metallic, polychrome, or mica flakes to refract light.

High-solids paint or clears contain chemicals such as glycol esters, esters, and ketones, which keep more of the solids in suspension with less solvent. These paints allow for better coverage with fewer coats. High-solid clear coats can also be used to topcoat color coats. In general, avoid the use of lacquer based topcoats and use topcoats that require less than three coats to achieve adequate coverage, such as polyurethane or urethane. Waterborne basecoats are also a good choice to " i z e the hazardous waste and VOCs.

Page 111

3.0 PAINTEQUIPMENT

The transfer efficiency of a conventional spray gun is 20 to 40 percent. Many of the newer spray - - application systems have transfer efficiencies of greater than 65 percent. With higher efficiency transfer systems, more paint is applied to the car, less is

wasted and less VOCs are emitted.

The hgh-volume/low-pressure (HVLP) turbine spray guns have reportedly achieved the highest transfer efficiencies so far at 80 to 90 percent. The first stage uses columns of low pressure air to cause turbulence within the paint. The air used for the atomization is heated and originates from a high- volume turbine driven blower. This mixture is then transferred to the gun using large diameter air lines. Drawbacks to this system include the high cost, cumbersome to use, and does not work well with metallic finishes.

c.

A more versatile, less expensive gun is the high-volume/low- pressure (HVLP) spray gun. This type of gun has a transfer efficiency ranging from 55 to 75 percent. These guns require a large volume of air, usually at least a 5 horsepower compressor, but are cheaper

. than the turbines or auxiliary air supplies needed for the HVLP turbine spray guns. Drawbacks to this system include slower application rates, more difficult to blend topcoats, and does not work well with

metallic topcoats. Several versions of HVLP systems include HVLP spray guns with a pressurized cup attachment which increases transfer efficiencies, HVLP gravity fed spray guns which work well with high solids and water-based paints, or HVLP siphon fed spray guns. Some manufacturers sell conversion kits to make a conventional spray gun into an HVLP siphon fed gun.

Low-pressure/low-volume spray technology, which uses less than half the required compressed air for HVLP systems, has also been developed with transfer efficiencies ranging from 55 to 75 percent.

Page 112

The new technology spray equipment available can considerably increase transfer efficiencies and decrease waste generated. Check with the paint and gun manufacturer to determine which gun will work best for the type of work and the different types of paints to be used at your shop.

4.0 PAINT APPLICATION TECHNIQUES

Proper training in the correct use of the different types of spray equipment is essential. Check with the paint and/or spray gun manufacturer to determine the fluid tip/air cap combination and gun settings that should be used with the different types of coatings to be sprayed. Setting the pressure at a higher rate than recommended will increase over

spray and decrease the transfer efficiency of the spray gun.

Certain application techniques can also decrease the amount of waste and VOCs generated. For most jobs, the spray gun should be held perpendicular to the surface being sprayed, using parallel strokes. Use a 50 percent overlap for each pass and feather the trigger at the beginning and end of each pass. When painting small and medium sized panels, make each pass the full length of the panel. If blending is necessary, blend as small an area as possible.

5.0 EQUIPMENT CLEANING PROCESSES

Roper cleaning and maintenance of equipment is essential in achieving a high quality finish, especially with the newer high transfer efficiency spray guns. These guns are highly susceptible to dried paint or other obstructions. Guns can be cleaned manually or with a mechanical gun wash system.

Before cleaning, be sure all remaining paint is removed from the cup and the siphon tube. Rinse the paint cup with a small amount of solvent. This solvent can be saved and used to thin paint of the same color. Then pour clean solvent into the cup and spray the solvent through the gun to clean out the gun. The spray should be done in an enclosed backdrop to capture the solvent and limit air emissions.

Page 113

a

Mechanical gun washers are becoming more popular as a safe, effective means of cleaning spray equipment. The paint cup is removed and rinsed with solvent, then the disassembled gun is placed in a gun washer. The washing takes place in a closed system, trapping the solvents and emissions. The solvent can then be fitered and reused. Sludges from the gun washers should be tested and handled accordingly. Some solvent manufacturers are offering low VOC gun wash solvent to further reduce emissions from cleaning operations.

6.0 PAINT BOOTH FILTERS

Paint booth filters are paper-based or fiber material that require changing. Waste filters must be tested to determine if they are hazardous waste. All wet filters are considered hazardous due to their ignitability. Therefore, allow paint filters to dry completely before disposal. To reduce solid waste, use a drum compactor to place as many filters as possible into a drum for disposal. Non-hazardous fiters usually can be disposed of as residual waste in an approved landfill. Check with your state regulatory agency for restrictions in your area.

c.

Paint booth filters become hazardous from the hazardous paints which they absorb. Try to use as many paints as possible which are not hazardous to reduce your hazardous filter waste. Some shops segregate booths as hazardous and non -hazardous, keeping the filters separate and disposing of them accordingly.

If possible, consider the installation of reusable filters. These filters use a solid or a liquid medium which allows for their separation and reuse. The latest generation of Styrofoam paint filters can be cleaned and reused repeatedly.

7.0 WASTE MINIMIZATION OPPORTUNITIES

Many waste minimization opportunities exist for shops engaging in painting operations. These options include: inventory control, purchasing controls, housekeeping practices, material segregation and waste exchange are applicable to other waste streams.

Page 114

0

0

0

Inventory Control - Rigid inventory control provides an effective means of source reduction. The shop owner/manager may monitor employee operations and make verbal or written comments on product usage. Access to storage areas can be limited, forcing the employee to stretch the use of raw materials farther. This also allows the use of raw materials to be better monitored.

Purchasing Control - Monitoring purchases ensures only the correct quantity and type of material is ordered and delivered to the facility. F’urchasing control also effects purchasing choices so it becomes possible to evaluate the possibility of substituting less hazardous products.

Housekeeping Practices - Basic housekeeping techniques can be very effective as a means of source reduction. Specific approaches to drum location, materials transfer methods, leak collection, and drum transfer can effectively limit product loss.

The potential for accidental spills and leaks is highest at the point of transfer of thinners from bulk drum storage to process equipment. Spigots or pumps should always be used to transfer waste materials to storage containers. Material should never be poured directly from drums to smaller containers.

Evaporation is a material loss that can be controlled through the use of tight-fitting lids. The reduction of evaporation will increase the amount of available material and result in lower solvent purchase costs.

Another great opportunity for collision repair operations is the utilization of ventilated sanders (orbital and reciprocating types). The use of unventilated sanders can easily result in workers being exposed to levels of dust in excess of OSHA standards. The use of ventilated sanders greatly reduces the volume of dust, keeps the shop cleaner and reduces cleaning requirements, and improves worker health and safety.

Page 115

0

0

0

0

Mix Materials According to Need - Only the amount of paint needed for the job should be mixed up. Leftover paint may be classified as a hazardous waste and need to be disposed of accordingly. Using the smallest cup size possible can be an effective means of source reduction in two important ways. It would limit over mixing of paint to be used on a specific project, and decrease the amount of solvent needed for equipment cleanup when doing spot painting and small jobs.

Switch to Water-Based Paints and Primers - Water- based products reduce VOC emissions. The availability of water-based paints for the automotive refinishing industry is still limited. The automotive paint manufacturing industry is working on the development of water-based paint formulations, but it will still be several years before they become widely available. However, water-borne primers are readily available. These type of paints and primers also reduce the amount of hazardous waste due to the limited amount of solvent in the paints. Other benefits include reduced personal health and safety concerns due to the reduces solvent usage and the reduction in hazardous waste from equipment cleanup.

Switch From Lacquer to Enamel-Based Paints - Lacquer paints may contain 70 to 90 volume percent solvent while enamels contain 55 to 75 volume percent solvent. The use of the enamel-based paints can result in a si@& reduction of VOC emissions when compared to lacquer based paints.

Consume all Paints and Materials - All paints and materials should be completely used up. This applies to both paint cans and aerosol containers. Paint containers are considered empty if they contain less than 1" of product, or when all pourable material is removed. Empty aerosol containers should be drained and depressurized properly. A waste determination must be carried out to see if the containers are hazardous. A better alternative is to recycle the metal paint containers.

Page 116

Paint Strippers - Several alternatives exist to traditional paint stripping methods which utilize solvents. Plastic media blasting utilizes plastic beads to strip the paint. Cryogenic methods of paint Stripping have also been tried with success. Both of these methods greatly reduce waste generated.

Waste Exchange - Excess paint and waste thinners can be listed in waste exchange programs. Waste exchanges are clearinghouse organizations that manage or arrange the transfer of waste between companies or industries.

Solvent Recovery, Distillation and Recycling - Solvent recovery or distillation devices offer the shop several options. Distillation of the waste paint, paint thinners and spent solvents produces a solvent which may not have the specification to be used in a painting application, but rather it could be used to clean guns, lines, nozzles and possible prep for the metal prior to applying the undercoat.

Solvent/paint thinner recycling reduces the amount of waste which must be disposed of in accordance with the regulations. Therefore, reducing the shops liability generally associated with hazardous waste disposal. Using reclaimed solvent reduces the cost of new material that is being purchased for gun cleaning and metal prep.

Page 117

1

2 .

3.

4.

5 . c.

6.

7 .

8.

Review Questions

Wastes generated by the automotive painting industry are regulated primarily by which two environmental laws?

List two methods to reduce paint use.

List two “less toxic” types of waste paint.

List two types of spray gun equipment and their transfer efficiencies.

Explain how proper painting techniques can reduce VOC emissions.

Explain proper cleaning methods for spray painting equipment.

List four waste minimization options that can be used to reduce hazardous waste generated by painting operations.

Explain why solvent distillation units may be a good option for shops with painting operations.

Page 118

a

1.

2.

3.

4.

Unit 8 Quiz

What I have Learned about

Management Standards for Waste Paint Generators

Paint application wastes include: a. Leftover paints b. Dirty thinner and solvents C.

d. All of the above VOC emissions into the air

Ways to reduce losses from evaporation and/or spillage include: a. b. c.

d. All of the above

Use tight fitting lids on all storage containers Use spigots to transfer paints and solvents Never pour paint or thinner from large containers to small containers

Setting the air pressure on the spray guns at a higher than recommended setting will: a. b. c. d. Lower VOC emissions

Get the job done faster Produce more over spray and VOC emissions Make the paint dry faster

Empty paint drums are not considered a hazardous waste if a. b. c. d. BandC

They are always considered a hazardous waste The drum contains less than 1 inch of material When all pourable product is removed

Page 119

5 . Some mechanical paint stripping methods which have been substituted for solvent stripping and include: a. Sandblasting b. c. d. All of the above

Glass or plastic bead blasting Cryogenic stripping using carbon dioxide pellets

6 . Many solvents used in the paint industry are considered hazardous waste due to their flammability. a. ' True b. False

7. The transfer efficiency of spray guns is a function of a. Operator skill and training b. Proper air pressure setting c. Size of paint cup d. A and B

8. Keeping the spray gun perpendicular to the surface and at the correct distance from the surface being painted will improve the transfer efficiency of a spray gun. a. True b. False

9. Wet paint filters can be considered hazardous due to their ignitability . a. True b. False

10. Replacing lacquer with enamel based paints can reduce VOC emissions. a. True b. False

Page 120

c .

unit 9 Management Standards For

Other Waste Fluids Generated by the Automotive

Industry

Student’s Guide

Table of Contents


1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . 126

2.0 Gasoline and Diesel Fuel . . . . . . . . . . . . . . . 126

3.0 Antifreeze . . . . . . . . . . . . . . . . . . . . . . . . . 127

4.0 CFC’s (Freon) . . . . . . . . . . . . . . . . . . . . . . 128

5 . 0 Transmission and Hydraulic Fluids . . . . . . . . . 129

6.0 Stormwater . . . . . . . . . . . . . . . . . . . . . . . . . 129

7.0 Wastewater . . . . . . . . . . . . . . . . . . . . . . . . 130

Page 122

Management Standards For Other Waste Fluids

Unit Overview

0 bj ectives


0 List the waste fluids generated by the automotive service industry,

0 Describe the proper storage of waste fluids,

0 Discuss how CFC’s cause the depletion of the ozone layer, and list technician requirements

0 List measures and controls to prevent and minimize wastewaster and stormwater run-off,

Unit Overview

This unit discusses and describes regulations, pollution prevention and recycling methods for gasoline, antifreeze, CFC’s, transmission fluids and other waste fluids generated by the automotive industry.

Page 124

MANAGEMENT STANDARDS FOR OTHER WASTE FLUIDS

1.0 INTRODUCTION

The following automotive fluids or derived fluids are typically generated at automotive service facilities:

Gasoline & diesel fuel

Antifreeze

Freon (R12)

Transmission, hydraulic and brake fluids

Wastewater

Stormwater runoff from storage and spill areas

Automotive fluids recovered from vehicles such as gasoline and diesel fuels, antifreeze, and other petroleum based fluids must be stored:

Separately

In leakproof containers (such as drums or above ground storage tanks).

Containers must remain closed when not in use.

On curbed, impermeable, concrete surfaces, with secondary containment to capture any spilled fluid.

2.0 GASOLINE AND DIESEL FUEL

Spent fuels to be discarded are considered hazardous waste because they contain a significant amount of hazardous materials including benzene, toluene, xylene, other hydrocarbons , chlorinated compounds, and they exhibit a low flash point.

Page 126

They must be handled stored, transported and disposed of according to hazardous waste requirements.

Store spent fuels in appropriately labeled, double walled tanks on a curbed surface with spill controls, including impermeable secondary containment and absorbents. If waste fuels are transported off-site, they must be manifested, and transported by a waste hauler.

Minimize spent fuel disposal costs by reusing for "inferior" processes, such as power lawn mowers and snow blowers.

3.0 ANTIFREEZE

Antifreeze is a listed toxic substance under Section 313 of the Superfund Amendments and Reauthorization Act (SARA) of 1986. The engine coolant may be regulated as a hazardous waste because it contains ethylene glycol and detectable concentrations of benzene, toluene, lead, zinc, arsenic, mercury and copper which accumulate from the cooling system. Antifreeze is toxic if ingested in large enough quantities. Some fleet maintenance operations have switched from ethylene glycol to propylene glycol which is a less toxic form of antifreeze.

Antifi-eeze should NOT be disposed of in sewers, leach fields, dry wells or onto the ground. Contaminated stormwater run off into surface water is detrimental to fish, because it lowers the biological oxygen demand (BOD) in the water causing fish and other aquatic life to suffocate.

It is recommended to reclaim and reuse antifreeze on-site through a special recycling unit. Antifreeze to be reused should be recycled through a distillation or micro filtration unit, tested for strength, pH and reconditioned. However, if reused directly, such as pouring from one radiator to another, antifreeze is not a hazardous waste, as it has not yet become a "waste.

Store used antifreeze in closed, well labeled containers on a curbed surface with spill controls, including secondary containment and absorbents. If waste antifreeze is transported j off-site, it may need to be manifested as a hazardous waste.

Page 127

4.0 CFCs (Freon)

Scientists worldwide have concluded that chloroflourocarbons (CFCs, also known by the trade name Freon or CFC-12) deplete the ozone layer. When allowed to escape, these chemicals drift above the earths surface to the stratospheric ozone layer. The ozone is a layer of gas that protects us from the sun's powerful ultraviolet (UV) radiation.

The depletion of the ozone layer allows more W radiation to reach Earth, which can cause a rise in cases of skin cancer and cataracts. Also, increased radiation could damage important food crops and marine ecosystems.

c. On November 15, 1990, the President signed the Clean Air Act Amendments, which include requirements for stratospheric ozone protection and production phaseout requirements for Freon. Section 609 of the Act covers the servicing of motor vehicle air conditioners, and section 608 establishes a "safe disposal program'' to ensure removal of refrigerants from vehicles and other appliances before disposal.

Although the production of CFC's stopped at the end of 1995, there are no restrictions on the use of CFC's in existing equipment and certified technicians may legally work on such units. However, it is recommended to retrofit old CFC-12 air conditioning systems to use the alternative refrigerant HFC- 134a whenever possible.

Technicians are required to be trained and certified by an approved EPA organization and registered with the state. All equipment used for refrigerant removal must also be approved by the EPA. The certification requirements for equipment and technicians covers repairs, CFC removal, charging existing air conditioners, servicing of any form, and work on a l l vehicles whether on or off-road. By law technicians must either recycle used refrigerant on-site or send it to an off-site, EPA certified reclamation facility.

Page 128

5.0 TRANSMISSION, HYDRAULIC and BRAKE FLUIDS

Transmission and hydraulic fluids are not typically segregated but are blended with used oil. This mixture can then be recycled off-site or used for energy recovery in used oil furnaces.

Brake fluid should be kept in a separate, marked, closed container and recycled or disposed of properly. Brake fluid may or may not be hazardous, depending on the additives. Most often, brake fluid becomes hazardous when it is contaminated with chlorinated solvents from spray can brake cleaner. Determine through testing if your brake fluid is hazardous and manage it accordingly.

6.0 STORMWATER

Stormwater may contain a mixture of various materials, contaminants, or hazardous wastes which are carried off-site by precipitation runoff and into sewers and surface waters or adjoining property. A simple

facility to come into compliance with management practice which may help a

stormwater regulations is the prevention of spills.

Facilities should attempt to keep any contamination localized. A drainage ditch can be designed to collect all storm water moff. The runoff should then be collected in a holding pond or sump, treated and released. A sandtrap and oil skimmer is recommended before discharge to the local sewer.

The measures and controls to prevent or minimize pollution in stormwater include:

Good housekeeping of industrial areas exposed to stormwater;

Spill response procedures to minimize the impact of spills;

Use oil/water separators; and

Page 129

Maximize recycling of materials.

Use spill prevention procedures such as:

. Draining automotive fluids carefully and only indoors;

Drain fluid over an impermeable surface;

. Utilize proper drains and sumps;

Train employees on pollution prevention measures and controls and record keeping; and

Use only approved storage tanks or containers

7.0 WASTEWATER c.

Frequency of washing floors is the largest generator of wastewater at most facilities. The need for regular washing of the shop floor is debatable, and cleaning a floor with water may not be necessary. Waterless floor cleaning will likely achieve your objectives

f RL if the following steps are followed:

Thorough washing of vehicles prior to maintenance and/or repair;

Use of portable containers to catch fluids as they are drained from vehicles or as they drip from components under repair;

Use of absorbents to catch any inadvertent fluid spills;

Thorough sweeping of the floor immediately after a vehicle leaves the shop; and

The shop area floor drains could be covered with rubber mats to discourage unnecessary washing and to prevent unauthorized dumping into the drains.

If floors must be washed, spot wash them with a mop. This will generate a minimal amount of liquid waste as compared

Page 130

to washing the entire floor. Another option is a mobile floor washer that recycles fluids as it washes a floor.

Pretreatment of wastewater varies but usually include traps that catch solids and oil skimmers. The traps are cleaned out on a periodic basis either through a contracted vacuum service that dispose of the waste off site or by operations personnel where the solids are scooped out and landfilled off-site.

Both solids and liquids should be analyzed on an annual basis for hazardous constituents. The wastewater and associated solids are typically non-hazardous. Samples should be taken on a point-source basis; so that a particular waste stream that might generate a hazardous waste is identified prior to mixing with a non-hazardous waste.

Vehicles are often washed prior to maintenance, and washed as needed for appearance. The vehicle washing waste stream consists of hot water, detergents grease, oil, and solids. Many facilities use a high pressure water spray to facilitate the cleaning process.

Water-based parts washers are used at some operations. Parts washers use water, detergent (usually a biodegradable type), and sometimes a surfactant. Most washers have an oil skimmer and a sediment trap.

Reducing water usage can greatly reduce charges associated with waste water discharges.

Page 131

1.

2.

3.

4.

5 .

6 .

7.

s.

9.

Review Questions

List the requirements for storing waste fluids.

List the storage requirements for spent fuels.

List the storage requirements for used antifreeze?

Describe how antifreeze can be recycled.

List the requirements for technicians repairing, etc. vehicle air conditioners.

Describe how used transmission, hydraulic and brake fluids are managed.

Describe why stom water runoff is potentially hazardous.

Describe techniques to prevent or m W e storm water run-off

Describe waste water and list several minimization techniques.

Page 132

1.

2.

3.

4.

5 .

Unit 9 Quiz


Managing Waste Fluids

Which of the following is NOT a waste fluid generated by the automotive industry? a. Gasoline b. Antifreeze C. Mineral oil d. Wastewater

To "ize disposal costs for spent fuels, a shop should a. b. Mix with good fuel C.

d.

Use the fuel in vehicles

Pour it down the drain Use in lawn mowers and snow blowers, etc.

Which of the following is NOT true about antifreeze? a. Listed as a toxic substance under SARA b. Is not a hazardous waste c. Has a pleasing taste d . Recyclable

CFC's (Freon) are regulated by a. b. The Clean Water Act C. The President d. OSHA

The Clean Air Act Amendments

Which of the following is TRUE about transmission and hydraulic fluids a. Can be mixed with used oil b. Cannot be recycled on-site C. Must be sent off-site for incineration d. Can be dumped in a landfill

Page 133

6 .

7.

Which of the following is NOT a technique used to minimize storm water run-off a. Good housekeeping of industrial areas exposed to

stormwater b. Store all containers directly on the ground (soil) c. Used oil/water separators d. Use spill prevention procedures

Which of the following is NOT a technique used to minimize waste water a. Thorough washing of vehicles prior to

maintenance and/or repair; b. Use of portable containers to catch fluids as they

are drained from vehicles c. Use of absorbents to catch any inadvertent fluid

spills d. Thorough sweeping of the floor once a week

Page 134

unit 10

c . Unit Overview . . . . . . . . . . . . . . . . . . . . . . . . . 138

Objectives . . . . . . . . . . . . . . . . . . . . . . . . . 138 Unit Overview . . . . . . . . . . . . . . . . . . . . . . 138

1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . 140

2.0 Scrap Metal . . . . . . . . . . . . . . . . . . . . . . . . 140

3.0 Tires . . . . . . . . . . . . . . . . . . . . . . . . . . . . 140

4.0 Shop Rags . . . . . . . . . . . . . . . . . . . . . . . . 141

5.0 Paper . . . . . . . . . . . . . . . . . . . . . . . . . . . . 142

6.0 Wooden Pallets . . . . . . . . . . . . . . . . . . . . . 142

7.0 Shop and Vehicle Clean-up Waste . . . . . . . . . 143

8.0 Batteries . . . . . . . . . . . . . . . . . . . . . . . . . . 144

9.0 Waste Filters . . . . . . . . . . . . . . . . . . . . . . . 145 9.1 Paint Booth Filters . . . . . . . . . . . . . . . 146

10.0 Glass . . . . . . . . . . . . . . . . . . . . . . . 146

11.0 Asbestos Containing Waste . . . . . . . . . 147 11.1 HEPA Vacuum Filters . . . . . . . . . . . . 147 11.2 Container Management . . . . . . . . . . . . 148

12.0 Pressurized Spray Cans . . . . . . . . . . . . 148

Management Standards For Solid Waste

Generated by Automotive Industry

Student’s Guide

Table of Contents

Page 136

c.

Page 137

Management Standards For Solid Waste

Unit Overview

Objectives

After completing this session, you should be ab1 to:

List several types of solid waste generated by the automotive industry,

List storage requirements for solid wastes generated by the automotive industry,

List recycling options for solid wastes generated by the automotive industry

Describe why it is beneficial to use a rag laundry service,

Discuss a variety of floor dry options and their proper use and disposal requirements,

Unit Overview

This unit discusses and describes regulations, pollution prevention and recycling methods for shop rags, scrap metal, batteries, filters, tees and other solid waste.

Page 138

MANAGEMENT STANDARDS FOR SOLID WASTE

1.0 INTRODUCTION

Vehicle repair and collision repair operations generate various types of solid wastes that include:

* - . Scrap metal

c. ._ - - b Paint booth filters WASTE DISPOSAL Glass

b Spray cans

Some of the waste types (i.e. batteries) could be classified as hazardous waste if not properly stored and discarded. Most of these wastes can be discarded as solid waste. However, with increasing costs for land disposal of solid waste, it becomes necessary for shop owners to reduce solid waste generation to increase profitability.

2.0 SCRAPMETAL

The automotive industry generates several types of scrap metal. The scrap metal includes broken parts, cuttings from machine shops, radiators, chassis and a l u " cans.

Most operations typically recycle scrap metal utilizing off-site vendors. However, increased returns on metal recycling could be achieved by segregating out different types of metal (i.e. aluminum, copper, ferrous iron etc.)

3.0 WASTETJRES

Vehicle repair operations generate light vehicle tires and on occasion large tires from heavy equipment and trucks. Disposing of tires is becoming increasingly difficult and expensive as some states have enacted bans on landfilling

Page 140

tires. Some states may require waste disposal facilities to be registered. Check with your state agency for requirements in your area, and only contract with those facilities which are in compliance. Due to landfill restrictions, check to see of your vendor will take back tires for retreading.

When improperly managed, waste tires pose a threat to public health and the environment. They are the preferred breeding

ground for mosquitoes, which may carry diseases, and tire piles are a serious f r e hazard. It is recommended to store tires indoors or keep tire piles covered to prevent entrapment of water. Some states have accumulation limits, require permits for tire storage or other restrictions. Be

sure to check with your state agency for the waste tire regulations in your area.

Several new uses for old tires are currently being evaluated. Shredded tires are being used in construction projects to replace conventional fill materials in some instances. Several examples of where this material may be used is in road bed construction, building constructions, and landscaping. Shredded tires have also been incorporated into asphalt, almost doubling the durability and lifetime of the road surface. However, the cost of this process is about double that of ordinary asphalt.

Shredded tires are also being used as a fuel for power plants and cement kilns. Studies by several power plants have shown that using shredded tires mixed with coal has actually decreased air emissions for lead, particulate, and nitrogen oxides. The biggest drawback to this technology is the cost of a machine to shred the tires to a 1" X 1" size. This makes these options costly for a company simply looking to dispose of their old tires.

4.0 SHOPRAGS

Rags are needed in maintenance facilities for parts cleaning, drying, and for cleaning small drips or spills. Shops should not use disposable rags or wipes of any kind, especially paper towels, newspapers, paper wipes and disposable tissue. Cloth

Page 141

rags which can be laundered through a commercial laundry service are considered “recycled” rather than a hazardous waste. Using only cloth rags can virtually eliminate hazardous rag waste disposal costs and liabilities.

Although your rags are being laundered, you must always keep solvent coated rags separate from other used rags. Remember: if rags contact a “listed waste” then the rag is now a hazardous waste by the mixture rule and must be handled as hazardous waste until they

leave your facility. Solvent contaminated rags should be drummed in a labeled, sealed waste container to prevent evaporation and possible ignition.

Good housekeeping practices and a rag laundry service seem to be the best minimization options available at this time.

c.

5.0 PAPER

Paper from office and computer printer areas is usually recycled. However, most paper at vehicle repair and collision repair operations is disposed of in a dumpster and landfilled off-site. Check with your waste hauler too see if they offer a paper recycling program.

With increasing costs of tipping fees at landfills, recycling and trash compactors will become cost effective for dealing with the large volume of tape and masking materials used by collision repair operations.

6.0 WOODEN PALLETS

Wooden pallets are typically broken down and used for a variety of uses on-site or landfilled off-site. Some vendors will take back wooden materials for re-use. In addition, some larger operations have contracted to have wood materials shredded and utilized as landscaping mulch.

Page 142

c. .

7.0 SHOP a d VEHICLE CLEAN-UP WASTE

Most vehicle repair operations utilize a form of floor dry to absorb minor spills and leaks in maintenance areas. If strict precautions are taken to avoid any hazardous materials fiom being spilled, most floor dry would not be considered a hazardous waste. Remember, any floor dry

used to absorb a hazardous material, such as spilled solvent, becomes a hazardous waste by the mixture rule, and must be disposed of in accordance with hazardous waste regulations.

Good housekeeping practices, such as changing leaky spigots or valves, and using extra care when changing vehicle fluids can alleviate the need for the floor dry.

Care should also be taken not to use more absorbent material than is necessary, and multiple applications of absorbents should be incorporated into operational procedures to insure it is utilized to its maximum potential. To increase the useful life of floor dry, a screening device can be built which allows for more than one application of the floor dry. The used absorbent is passed through a sieve that is placed over a container (Le., a used, clean 55 gallon drum). The material is allowed to dry in the container prior to reuse. Generally the typical number of reuses is estimated at between two and three applications. The absorbent can then be disposed of in the appropriate manner.

Another option utilized by a large fleet maintenance operation is to utilize used oil/grease absorbent as an additive with aggregate by an asphalt plant to make new paving material.

There are three types of absorbents now available: natural, mineral and synthetics. Natural and mineral absorbents are considered absorbents because the liquid penetrates their fibers. Synthetic absorbents are considered adsorbents because they don't allow liquid penetration into their fibers.

Natural absorbents which include cotton, peat, sawdust, and corncobs have widespread use due to their low cost and most are usually disposed of in a landfill, although some states have banned saturated sorbents in landfills due to leaching

Page 143

problems. Certain types of natural absorbents also have the advantage of incineration for energy recovery if they meet RCRA standards.

Mineral absorbents, which include vermiculites such as clay pellets, are used by most operations to clean up spilled fluids in shop areas. Mineral absorbents have very widespread use due to their low initial cost and ease of disposal, usually in a landfil. However, check with your vendor when purchasing floor dry to see if they offer a more "environmentally friendly" absorbent. For example, the use of non-clay containing absorbents enhance the bioremediation of the organic contaminant, while clay containing absorbents tend to hinder the breakdown of hydrocarbons.

Synthetic absorbents such as polypropylene and polyurethane are becoming increasing popular because of their high absorbency and the fact that certain types can be wrung out and reused and the recovered fluids recycled or burned for energy recovery. This can cut down on the disposal costs of absorbents, offsetting the higher cost of the synthetic adsorbents. Synthetic fibers come in different types such as socks, rolls, and pads. Some can be wrung out and reused more than 15 times.

c-

8.0 BATTERIES

Spent batteries are generated by automotive vehicles and light and heavy duty trucks. On a weight basis, spent lead batteries can be one of the larger categories of hazardous waste generated at a fleet maintenance operation. Used lead batteries are exempt from regulation as a hazardous waste if they are recycled or re-conditioned for reuse.

Licensed recyclers typically pay for battery recycling and most operations return their vehicle batteries to the vendor for recycling. Most vendors have a one for one exchange program allowing customers to return as many batteries as they have purchased.

Whether batteries are stored indoors or outdoors, it is advisable to store them in plastic covered, acid resistant, leak proof bins, and set on a non-reactive impermeable surface.

Page 1 4 4

c. .

It is recommended not to stack batteries more than 4 or 5 high, in order to minimize spills or breakage during storage or transport. Secondary containment is recommended.

9.0 WASTE OIL, TRANSMISSION and FUEL FILTERS

Used oil filters are excluded from hazardous waste requirements if they meet the following criteria:

Non-terne plated, and

Punctured through the anti-drain back valve or the filter dome end and hot-drained, or

Hot-drained and crushed, or

Dismantled and hot-drained, or

Any other equivalent hot-draining method.

Generators are encouraged to recycle the recyclable elements of used oil filters, such as the canister, gasket, and filter paper. The RCRA scrap metal exemption is applicable to used oil Nters if they are recycled. Recycling also eliminates the need to determine if the filter is terne plated or non-terne plated. Undrained or uncrushed filters may contain too much oil to qualify for the scrap metal exemption. These filters may be shipped off-site for crushing and recycling under the used oil exemption, providing the oil is also collected for recycling.

Some recyclers of used filters require the filters to be crushed, others will not accept crushed filters. Several commercially available filter crushers are available. In addition, several very effective filter crushers have been designed and built from spare parts by on-site maintenance personnel.

Refer to unit six for more detailed information on used oil filters.

Page 145

Transmission and fuel filters should be handled like used oil filters. In most staes, they may currently be discarded in the dumpster as long as they are thoroughly drained, they are exempt from hazardous waste requirements if they are recycled or properly disposed of in a landfill or hazardous waste facility. Check with your state agency to determine the regualtions in your area

‘9.1 Paint Booth Filters

Paint booth filters are paper-based or fiber material that require changing. Waste filters must be tested to determine if they are hazardous waste. All wet filters are considered hazardous due to their ignitability. Therefore, allow paint filters to dry completely before disposal. Non-hazardous filters usually can be disposed of as residual waste in an approved landfill. To reduce solid waste, use a drum compactor to place as many filters as possible into a drum for disposal. Again, filters must be dry to avoid ignition. Check with your state regulatory agency for restrictions in your area.

c.

Paint booth filters become hazardous from the hazardous paints which they absorb. Try to use as many paints as possible which are not hazardous to reduce your hazardous filter waste. Segregate booths as hazardous and non - hazardous, keeping the filters separate and disposing of them accordingly.

If possible, consider the installation of reusable filters. These filters use a solid or a liquid medium which allows for their separation and reuse. The latest generation of Styrofoam paint filters can be cleaned and reused repeatedly.

10.0 GLASS

Automotive glass, consisting of both the safety front windshield glass and the tempered side glass, in good condition may be removed, stored and resold. If storage allows, it is advisable to salvage and store as much intact glass as possible. Broken automotive glass cannot be recycled into container glass and has no known market. Automotive glass has a structural contaminant which makes the recycled

Page 146

glass bottles too weak. Therefore, a load of recyclable container glass could be rejected for recycling due to the presence of automotive glass. Otherwise, glass may be used in road base, as a fdler in asphalt, or as an aggregate in leach fields and drainage systems. Further research in the design and manufacture of recyclable automotive glass is a needed to solve this problem.

11.0 ASBESTOS C 0 N T A I ” G WASTE

Brake shoes and clutches contain asbestos, however, it does not meet the EPA defrntion of “friable.” The EPA’s definition of friable is when an asbestos containing material can be “crumbled or reduced to powder by hand pressure. ” Therefore, brake shoes and clutches may be discarded into the dumpster .

Rather than disposing of brake shoes it is recommended to recycled them. Most vendors will take back used brake shoes and return them to the manufacturer where they are re-lined for re-use. This option will avoid disposal costs, and reduce possible future liability associated with the disposal of a toxic substance.

11.1 HEPA Vacuum Filters

Some automotive shops use the HEPA vacuum method to protect workers form airborne asbestos fibers during brake shoe and clutch repair operations. HEPA vacuum filters must be replaced on a regular basis, however, they contain asbestos and are regulated as a toxic substance under TSCA. Therefore, proper handling and disposal of the filters is necessary to avoid worker exposure and possible future liability.

To keep asbestos fibers from becoming airborne, HEPA vacuum filters should be wetted with a fine mist of water before removal and placed into a double lined 6 mil polyethylene plastic bag and disposed of in a “asbestos only” waste container.

Page 147

11.2 Container Management

Automotive shops should designate a drum or other rigid container as an “asbestos only” waste container. The container should be “double 1ined”with 6 mil polyethylene plastic bags, and properly labeled. The container should remain closed except when in use. After the container becomes full or when the deadline for accumulation time has been reached (check with your state regulatory agency for accumulation time limits) the waste must be disposed of in an EPA designated landfill.

OSHA regulations require that warning labels be affixed to all products containing asbestos or to their containers. Labels must be affixed to each side of the container and one on top with the following information: -- .

DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD

. In addition to the OSHA labeling requirements, the United States Department of Transportation ( DOT) requires the following label to be affixed to asbestos containing waste containers for transport:

RQ Hazardous Substance Solid, N.O.S. (asbestos) ORM-E, NA-9188

12.0 PRESSURIZED SPRAY CANS

Brake cleaner and carburetor cleaner are often packaged in pressurized spray cans. When empty, these spray cans are not considered hazardous waste. However, partially empty spray cans may be regulated as hazardous wastes because they contain ignitable, chlorinated solvents. The proper management of pressurized spray cans is a s follows:

Page 148

Use up the contents of an entire spray can before starting another

Make sure the can is completely empty before discarding

If a spray can malfunctions, return it to your supplier or handle it as hazardous waste

Consider phasing out the use of spray cans in your shop

Use mechanical spray cans when possible

Page 149

Review Questions

1.

2.

3.

4.

5 .

6 .

7.

8.

9.

List the storage requirements for tires.

When are rags considered a hazardous waste?

What can a shop do to eliminate wooden pallet waste?

What are the disposal requirements for asbestos containing waste?

Are batteries considered a hazardous waste?

What options are available for used batteries?

Are used oil filters a hazardous waste?

Are paint booth filters a hazardous waste?

Describe hot draining.

10. Is automotive glass recyclable?

11. When is a spray can considered hazardous waste?

Page 150

Unit 10 Quiz


Managing Solid Waste

1. Which of the following is NOT true about waste tires? a. They pose a threat to public health b. They should be stored indoors or covered c. They should be burned d. They can be recycled

2. Shop rags are NOT a hazardous waste if a. They are picked up by a rag laundry service b. They come into contact with listed waste c. They are used to clean up hazardous waste spills d. They are used to wipe parts cleaned with

chlorinated solvents

Which of the following is NOT true about wooden pallets? a. They can be recycled into mulch for landscaping

purposes b. They can be returned to the vendor for re-use c. They cannot be land-filled off site d. They can be broken down and used for other

purposes on-site

Which of the following is HOT a type of floor dry? a. Natural b. Mineral c. Animal d. Synthetic

3 . Batteries are exempt from being classified as a hazardous waste if they are a. Drained before disposal b. Re-conditioned for re-use c. Die-Hard d. Are sealed batteries

Page 151

6 . Used oil filters are considered hazardous waste if they a. Are Tern-plated b. Are drained c. Are crushed d. Are recycled

7. Automotive glass can be recycled if a. The glass is crushed into very small pieces fiist b. The glass is not tinted c. The glass is from the side windows of a vehcle d. Automotive glass is not recyclable

8. Which of the following is NOT a labeling requirement for asbestos waste containers? a. DANGER b. AVOID CREATING DUST c. CONTAINS ASBESTOS FIBERS d. TOXICWASTE

c- .

9. Spray cans are NOT hazardous waste at the time of disposal if a. They are new b. They are empty c. They have the lid on tight d. They are half full

Page 152

unit 11

The Environmental Audit Process

Student’s Guide

Table of Contents


1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . 158

2.0 To Prepare for the Audit . . . . . . . . . . . . . . . 159

. . . .

2.1 Identify Waste Streams . . . . . . . . . . . . 159 2.2 Determine Regulations that

Impact Your Shop . . . . . . . . . . . . . . . 160 2.3 Determine the Requirements of

the Regulations . . . . . . . . . . . . . . . . . 161 2.3.1 OSHA . . . . . . . . . . . . . . . . . . 161 2.3.2 CAA . . . . . . . . . . . . . . . . . . . 162 2.3.3 CWA . . . . . . . . . . . . . . . . . . 163 2.3.4 SDWA . . . . . . . . . . . . . . . . . 164 2.3.5 RCRA . . . . . . . . . . . . . . . . . . 164 2.3.6 SARA . . . . . . . . . . . . . . . . . . 167 2.3.7 HMTA . . . . . . . . . . . . . . . . . 168

3.0 The Self Audit . . . . . . . . . . . . . . . . . . . . . . 168

4.0 The Official Audit . . . . . . . . . . . . . . . . . . . 170

5.0 Post-Audit Procedures . . . . . . . . . . . . . . . . . 171

Page 154

c. .

The Environmental Audit Process

Unit Overview

Objectives

After completing th is session, you should be able to:

0 List the objectives of an audit program,

0 List the most common waste streams in the automotive industry,

0 List the regulations that impact the automotive industry,

0 Describe the general requirements of each regulation,

0 Describe and conduct a self-audit check,

0 Describe the activities that take place during an official audit,

0 Describe the post-audit procedures,

Unit Overview

This unit discusses and describes each step of an audit process including, identifying waste streams, determine regulations , creating a self audit checklist and the official audit procedure.

Page 156

THE ENVIRONMENTAL AUDIT PROCESS

1.0 INTRODUCTION

Managing compliance in today’s regulatory setting has become an almost overwhelming exercise, involving more and more regulations, and affecting more and more organizations. Hazardous wastes and hazardous materials are now tightly controlled, and in the near future, more expansive controls will likely be based on meeting global, not national,

objectives.

One of the objectives of business is to assure minimal liability in compliance related matters and to do so in the most efficient and cost effective way. One solution to this problem is the development of a formal environmental audit program that evaluates compliance. Through the audit program the facility owner/operator will achieve two goals:

c.

1) The operator will gain a greater understanding of how the hazardous waste is generated and managed allowing them to evaluate ways to minimize that waste that is being generated, and

2) The operator will better understand the regulations that impact the shop as the facility audit is completed by using this format, questions regarding regulations will arise, by attaining answers to those questions the operator will better understand the regulations governing the management of hazardous waste.

Precisely defining environmental audits is a difficult exercise. The EPA defines the environmental audit as “a systematic, documented, periodic and objective review by regulated entities of facility operations and practices related to meeting environmental requirements.” An audit may be as simple as completing a daily or weekly checklist. Audits need to become a part of the regular day to day business practices of the facility. The shop owner should not view the environmental regulations governing the management of hazardous waste as burdensome, rather as part of the

Page 158

business, much like buying parts, charging for labor, and billing clients. The shop owner should take the same care in managing their hazardous waste as they do when estimating a repair.

Audit programs are typically designed to meet one or more of the following objectives:

Assurance of compliance

Understanding the liabilities associated with hazardous waste management

Reduce liabilities for the company and its officials

Gain a better understanding of the regulatory requirements

Understanding the cost associated with environmental compliance

Gaining a different perspective when looking for pollution preventiodwaste minimization opportunities

Increase environmental awareness

Track accountability of managers and shop personnel

2.0 TO PREPARE FOR THE AUDIT

2.1 Identify Waste Streams

The major waste s t r e a m generated by the automotive services industry are in conjunction with their vehicle maintenance and collision repair operations. Primary consideration should be given to waste streams that meet the following criteria:

Hazardous Waste.

Waste which poses a significant risk to human health and/or the environment other than what is technically defined as a hazardous waste.

Page 159

a

Waste generated and/or released in high volumes.

c. .

Waste that has a high cost associated with treatment, storage and/or disposal.

The most common waste streams generated by vehicle maintenance and collision repair operations that meet the above criteria include:

Used Oil - Used engine oil, transmission fluids, hydraulic fluids and used oil filters

Spent Solvents - These waste streams typically include chlorinated solvents, (i.e. Brake and Carb cleaner, or electrical contact cleaner), stoddard solvents typically used in a parts washer, or any other hazardous substances used for their solvent properties.

Other Waste Fluids - These waste streams include antifreeze, refrigerants, fuel, storm water, and waste water.

Paint Waste - Collision repair shops generate wastes primarily from painting operations and typically include: waste paint, paint thinner waste, paint filters and volatile organic compounds (VOC's) emissions from painting operations.

Solid Waste - These include rejected metal parts, old tires, shop rags, filters which have been deemed as non- hazardous, batteries when properly recycled, glass, and paper waste.

2.2 Determine Regulations that Impact Your Shop

Once a shop has identified it's waste streams, the next step is to determine which regulations impact the shop. Each of the relevant laws are listed below and are described in more detail in the following section.

Occupational Safety and Health Act (OSHA)

Clean Air Act (CAA)

Page 160

Clean Water Act (CWA)

Safe Drinking Water Act (SDWA)

Resource Conservation and Recovery Act (RCRA)

Superfund Amendment and Reauthorization Act (SARA)

Hazardous Materials Transportation Act (HMTA) .

2.3 Determine The Requirements of the Regulations

2.3.1

This law governs worker protection, safety training for employees working with hazardous materials and the workers’ right-to-know about the chemicals they are being exposed to.

Health and safety standards include:

Occupational S afety and Health Act (OSHA) *

0 Safe work practices and processes

0 Automotive brake repair operations

0 General worker protection, (eye and

0 Welding and machinery safety

hearing protection standards)

0 General industrial standards

0 Safety on working and walking surfaces

0 Ventilation in work areas and spray

0 Fire protection

0 Electrical safety

booths

Page 161

Hazard Communication Standard

0 Labeling - Every container of hazardous materials in the workplace must be labeled with the chemical name and with hazard warnings.

Material Safety Data Sheets (MSDS)- Employers must keep a copy of the MSDS for each chemical used in the workplace and the MSDS’s must be accessible to employees at all times.

0 Employee information and training - Employers are required to train workers in hazardous material handling and be informed as to where the MSDS can be found. c.

0 Other Provisions

0 Recordkeeping and reporting - An a n n d log of occupational and health issues including illness and injury must be kept.

2.3.2 Clean AI ‘r Act (CAA)

This Act controls discharges of pollutants into the air. The act regulates both stationary and mobile sources of pollution. The Act also regulates the use and reuse of refrigerant from air conditioning units. The Clean Air Act also establishes areas where there is a high frequency of days during which particular area exceeds the national standards for clean air. Some of these areas include Los Angles, CA, Salt Lake City, UT and Denver, CO. Each shop owner must check with the state regulatory agency listed in the appendix of this module to determine if their area is in an “Ozone Non-attainment Area” or other special area which has a more stringent set of requirements regarding air emissions from their shop.

Page 162

Volatile Organic Compounds (VOC’s)

Ozone Non-attainment areas

e Collision repair shops must check with the State Regulatory Agency in which the facility is located to determine if special permits are required for emissions of Volatile Organic Compounds (VOCS).

e State provisions MAY also require the use of special equipment such as High Volume Low Pressure (HVLP) equipment.

CFC’s

Technicians must:

0 Be trained and certified by an EPA- approved organization

0 Be registered with the state

e Use recovery/recycle or recovery only equipment which has been approved by the EPA

2.3.3 Clean Water Act tCWAl

This Act controls the discharges of pollutants into surface water through National Pollution Discharge Elimination System permits.

With the proper management of fluids and solid wastes automotive service operations should not have significant discharges of wastewater to Surface waters or to the sewer system .

Stonn water permits are required for larger vehicle maintenance shops under the following SIC codes 4100-4199 and 4200-4299.

Page 163

Shops are required to have Spill Plan Contingency Countermeasures (SPCC) plans if your facility has:

0 Tanks over 660 gallons capacity

Total oil storage capacity in excess of 1,320 0

gallons above ground

0 40,000 gallons below ground

Check with your local Privately Owned Treatment Works (POTW) facility to discuss what you may discharge into the sewer system, and keep copies of correspondence and lab analyses tests.

c- 2.3.4 Safe Drinkinp Wate r Act ( S DWA)

The Act established federal primary and secondary standards for drinking water and protects groundwater resources through the Underground Injection Control Program. Relevant regulated systems at automotive operations include septic systems, leach fields and infiltration systems. Chemicals and waste fluids are prohibited from being discharged to these systems.

2.3.5 Resource Co nservat ion and Recoverv Act CRCRA)

The four environmental programs established under RCRA include: hazardous waste (Subtitle C) which requires the tracking and management of hazardous waste from cradle-to- grave, solid waste (Subtitle D), underground storage tanks (Subtitle I) and medical waste (Subtitle J).

RCRA is the law that covers all management activities regarding generators of hazardous waste. Almost all state regulatory agencies have adopted the RCRA program. In adopting the program, the states may have made specific changes which are more stringent than the federal regulations. Contact the state regulatory agency contact listed in the appendix of this module for the state-specific changes. The Act establishes all the regulations which track hazardous waste from the point of generation to disposal.

Page 164

These include:

Obtaining an EPA Identification Number Generators of hazardous waste must obtain an EPA I.D. number from the state in which the facility is located or from the EPA Regional Office.

The Manifest System The manifest system is the tracking tool that is required any time a generator transports or offers for transport hazardous waste. This document must be completed with specific information including the name and location of the facility to which the waste is being shipped, generator and waste identification information.

Pre-transportation Requirements Proper packaging, labeling, marking, and placarding.

Accumulation Times These times establish how long a generator can accumulate hazardous waste on site without obtaining a RCRA permit. A large quantity generator (LQG), (generates greater than 1000 kilograms of hazardous waste in a calendar month,) can accumulate waste on site for up to 90 days without an extension or a RCRA storage pennit. A small quantity generator (SQG) can accumulate hazardous waste on-site for up to 180 days. If the disposal facility is more than 200 miles from the generating facility, the small quantity generator can accumulate hazardous waste on-site for up to 270 days, without an extension or a RCRA permit. The SQG cannot have more than 6000 kg of waste on site at any time. A conditionally exempt small quantity generator (CESQG) may accumulate up to lo00 kilograms of hazardous waste on-site before the waste becomes regulated under federal law. The CESQG cannot have more than lo00 kg of waste on site at any time. Some states impose a more stringent set of requirements on the CESQG than the federal regulations. The facility operator needs to check with the state regulatory agency where the facility is located to determine if that state has imposed a more stringent set of requirements.

Page 165

Satellite Accumulation Areas RCRA regulations allow satellite accumulation areas to be set up near a waste stream source. The date of accumulation is not recorded on the satellite accumulation area drum until it full and/or moved to the main hazardous waste storage room.

A Satellite Accumulation Area must meet these four criteria:

0 At or near the source of generation

0 Under operator control

0 Less than 55 gallons

0 Properly labeled and managed

It is important to note that all waste being accumulated in the satellite accumulation area must be counted towards the generator’s monthly quantity. This is one area where states tend to differ greatly, and it is important to contact the state to gain an understanding of the state specific differences.

Container Management

0 Clearly marked with the words “Hazardous Waste”

0 In good condition

0 Stored in a safe and secure location

0 Kept closed except when filling or emptying

0 Inspected weekly

0 Incompatible waste cannot be stored in the same container

Page 166

Recordkeeping and Reporting Requirements

The EPA requires that the following records are kept for a period of three years:

Manifests

Weekly inspections (drums)

Biennial reports

Exception reports

Any test results

Waste analyses

All Land Disposal Restriction (LDR) paperwork must be kept for a period of five years:

Waste Analysis for LDR

Certification of Treatment Standards

Notification that the waste is a LDR waste and that the waste meets the treatment standards

0 Waste Minimization and Pollution Prevention

Generators of hazardous waste must make some effort to minimize the amount of waste that they generate each year. This effort must be in some type of plan, most commonly known as a Waste Minimization Plan. The plan should describe the types of procedure changes that the generator has made to reduce the volume or toxicity of the waste generated. This activity is mandated and agreed upon every time a generator signs a Uniform Hazardous Waste Manifest.

Page 167

a

2.3.6 &"fund Amendment and Reauthorization Act SARA)

This amendment of 1986 reauthorized CERCLA with major amendments to the Act. A portion of SARA (Title 111) provides a framework for emergency planning and community right-to-know information with respect to the inventory of chemicals stored and used at the facility. A hazardous chemical inventory must be submitted to the emergency planning committee, state emergency planning commission and the local fire department. The list includes:

0 Materials required to have MSDS's

Materials that are present in excess of the Threshold Planning Quantity (TPQ)

0 Toxic release inventory report

2.3.7 Hazardous Materials Transportat ion Act 0

The Department of Transportation (DOT) regulates the transportation of hazardous waste through the HMTA. The law specifies packaging, marking, labeling, and shipping requirements for hazardous materials. RCRA contains additional requirements for hazardous waste transportation which include a manifest system and recordkeeping.

3.0 THE SELF-AUDIT

Self-auditing can improve facility performance before the regulatory inspector arrives. It can help focus managers' attention to current and upcoming regulations, and generate protocols and checklists that help facilities manage themselves better. The audit will help establish time lines for management activities associated with shipping and disposal of hazardous waste as well as other environmental compliance issues. The self-audit should become as much a part of your day-to-day business practices as reviewing your inventory of parts or paint.

Page 168

c-

Although, environmental laws do not require environmental auditing programs, ultimate responsibility for facilities environmental compliance lies with the owner or operator of the facility. This creates a strong incentive to implement an environmental auditing program to ensure facility compliance. It’s better to manage problems before they surface than to face legal liabilities that could have been avoided.

After you have identified your waste streams and determined which regulations pertain to your shop, you should create an audit checklist form which encompasses all the aspects of compliance.

To assist you in creating this form we suggest the following:

Obtain sample checklists available through state regulatory agency, local authorities or the U. S. EPA.

Obtain fact sheets from the National Environmental Compliance Assistance Center (NECAC) via the Internet at http://www.hazmat.frcc.cccoes.edu or through your local trade association.

Talk with other business ownerdmanagers who have previously experienced an audit, take their ideas and incorporate them into your checklist.

Question regulatory agencies about their auditlinspection procedures. Feel free to call your state, local or federal regulatory agency to ask questions to determine if your facility is in compliance. Incorporate their answers into your checklist. There is a list of state contacts listed in the appendix.

Regulatory agencies generally assign a staff member as the inspector, however, third party or contract auditors are also an option. Most auto service and collision repair facilities are small shops and are generally visited on a periodic basis. These visits are generally conducted by one or two regulators. If your facility is being audited by a regulatory agency it is important to take good notes and write down all of the questions and answers that are discussed during the audit. Some shop owners use a voice-activated tape recorder to

Page 169

http://www.hazmat.frcc.cccoes.edu

ensure that they record all the information discussed during the audit. Notification to other parties when using such a device is not required under federal law, but is generally considered a common courtesy. Once you have all the information discussed in the audit, formulate that information into your own self-audit checklist.

See appendix A for a sample checklist.

4.0 THE OFFICIAL AUDIT

Before the audit, a pre-visit questionnaire is sometimes provided to the facility manager so that he may prepare himself and his staff. Most regulatory agencies have an unannounced inspection policy, which allows the regulators to show up on-site at any time during regular business hours and request permission to enter and inspect the facility. On- site activities during an audit will include three primary functions:

C. .

Recordsldwunent review

e

e

e

0

e

0

0

0

e

0

Notification of hazardous waste activity Manifest and land disposal restriction notification certifications Tolling agreements Bi-annual reports Lab analyses of waste streams Regulatory correspondence Waste " iza t iodpol lu t ion prevention plans Employee training records Pertinent telephone numbers Spill Prevention Contingencies and Countermeasures plan (SPCC)

Staff interviews

e Owner e Manager 0 Employees

Page 170

0 Physical inspection of facilities

Employee rights notification posters Accessibility of MSDS’s Storage/accumulation areas Labeling Correct dating procedures Condition of containers Secondary containment Check for spills, releases, odors etc.

An audit debriefing should be conducted before the auditorlaudit team leaves the site. During this review the facility should get clarification on all issues that were discussed during the audit. Additionally, the facility owner or operator should ask the regulators about any discrepancies found during the audit. The facility should request a copy of the inspection report when it has been written, as well as copies of any photos and test results from samples taken during the inspection. The facility owner should be sure to write down the names of all the inspectors that were involved and the agency which they represent in the inspection, or get business cards from the members of the audit team.

This debriefing serves three useful purposes:

Provides an opportunity to review audit findings before they are written in a report

Provides an opportunity to identify additional data or information needed to complete the audit process

Provides an opportunity to reveal operations or conditions that pose an imminent health or safety hazard to personnel or public

5.0 POST-AUDIT PROCEDURES

After the auditodaudit team has completed the actual audit, a report must be written and will typically include a discussion of the audit process, an overview of the facility, an executive summary, and a presentation of findings and recommendations.

Page 171

The report will address both regulatory and procedural findings. Findings are classified as significant, major, or minor.

With the report being complete, an audit follow-up must be conducted. This is a crucial part of the entire process. Without the follow-up, the program is likely to fail. Approaches to follow-up actions on audit fmdings vary among companies. The audit process is not complete unless some formal measures are instituted to ensure that each of the audits’ findings and recommendations is being addressed. All corrective actions do not have to take place immediately, particularly if a large capital expenditure is required. However, as long as the facility management has a schedule for completion, this will demonstrate a good faith effort to comply.

Page 172

1.

2.

3.

4.

5 .

6 .

7.

8.

9.

Review Questions

List the objectives of an audit program.

List the waste streams in the automotive industry that are regulated.

List the regulations that impact the automotive industry.

Describe the purpose of a self-audit.

Describe a self-audit checklist.

List the required records or documents that an auditor will examine.

What is an audit debriefing?

What is an audit report?

Why must an audit follow-up be conducted?

Page 173

1.

2.

3.

4.

5 .

Unit 11 Quiz


The Audit Process

Which of the following is NOT an objective of self audit programs? a. Protection against liability b. Increased environmental awareness c. Assurance of compliance d. To assess fines

Primary consideration should be given to waste streams that a. Are hazardous waste b. Can be landfilled c. d.

Are produced in low volumes That are inexpensive to treat, store or dispose of

Which of the following regulations would be most likely to impact an automotivekollision repair shop? a. FIFRA b. SARATITLEIII C. OSHA and RCRA d. CERCLA

Environmental laws require environmental audit programs. a. True b. False

The self audit checklist should incorporate as many different aspects of the environmental regulations as possible, as well as information from regulatory agencies, trade associations and previous environmental inspections. a. True b. False

Page 175

6. Which of the following is NOT a record or document reviewed during the official audit? a. Tolling agreements b. A pre-visit questionnaire c. Employee training records d. Manifests

7. Employees may be interviewed during an official audit. a. True b. False

8. An audit debriefing should take place? a. Before the audit b. During the official audit C. d. During the self-audit

Before the official audit team leaves

9. The self-audit should be performed approximately once a year? a. True b. False

10. When must tanks, drums or containers that hold hazardous waste be closed? a. Just prior to shipment b. c.

d.

Overnight when the facility is closed All the time, except when material is being added to the unit After they leave the satellite accumulation area

Page 176

APPENDIX

APPENDIX A

Environmental Compliance Self Audit Checklist for Collision Repair shops

This checklist is to give the operator of a collision repair facility an overview of how the environmental regulations impact the actual management practices in a collision repair facility. This checklist was designed to follow the federal regulation for generators of hazardous waste as those regulations relate to the collision repair industry. It is important to know that the federal regulations are standard across the United States and that the individual State regulations vary from state to state. The federal regulations mandate that if a state has a hazardous waste program, them that program must be at least as stringent as the federal hazardous waste regulations Most states have added additional regulations to their particular program which make the state program more stringent than the federal program. Included in the appendix of this module is an outline of the federal regulations for each specific category of generator of hazardous waste included in that appendix is a form letter which can be sent to the individual state regulatory agency requesting that the state identifjr the differences between the federal -- program and the state program where the collision repair facility resides. Additionally, included on the back of fact sheets is a state contact list with all the telephone numbers for the regulators that oversee each particular program. This list may be used to gather this differences, discussed above, between the federal and state program. The NECAC World Wide Web site also offers a limited list of state contacts were questions can be E-mailed to state regulatory agencies

Self Audit Checklist for Generators of Hazardous Waste

Records Review

0

0

.. .

0

0

0

0

Waste Determination process and records Copies of all analytical results showing that the shop has completed a hazardous waste determination, include in this portion of the records review all correspondence with the disposal facility as well as all correspondence from the analytical laboratory.

If the facility is relying strictly on “process knowledge”, which I S applyrng knowledge ojthe hauudous characteristic of the wmte in light of the materials or the process used, keep a written record of the materials used as well as the MSDS for those materials, and a written explanation of the rationale used in making this determination.

Notification of Hazardous waste activity (EPA Form 8700-12) Make a copy of the completed form prior to sending the form in and retain this copy in your records in the event of a discrepancy between the regulatory agency and your records

Written Waste Minimization/ Pollution Prevention Plan Federal Law requires that a generator of hazardous waste have in place a plan which will minimize the quantity and toxicity of the waste generated at the facility The regulation do not require that this be a written plan, however, if an employee is questioned during the inspection they should have good knowledge of the waste minimization practices used at the facility

Employee Training Records Federal law requires that employees who work at a facility that generates hazardous waste be familiar with the procedures and precautions of handling the hazardous waste or receive some training on the safe handling practices of managing hazardous waste. All types of training and sources of information should be documented in the employee training files

Confirmation and Receipt of a EPA Identification Number Keep a copy of the form that you receive From the Agency with your EPA 1 D Number, to ensure that your always have the correct assigned number This will also assist the inspector in verifjrlng their records with the facility being inspected

Uniform Hazardous Waste Manifest

A generator who transports, or offers for transportation, hazardous waste for offsite treatment, storage, or disposal must prepare a manifest, OMB Control Number 2050-0039 on EPA form 8700-22. Some states have designed their own manifest which conforms to EPA regulations for transporting hazardous waste, if you state require the use of a state manifest or if the receiving disposal facility require the use of the state manifest in which the disposal facility is located the generator must use the appropriate state manifest Check the state contact list on the Internet contact list to obtain state specific regulatory information

0

0

0

0

0

Completing the Uniform Hazardous Waste Manifest Check to ensure that all the required blocks on the manifest have been properly completed. This is a generator responsibility, nul a transporter responsibility. The transporter assumes no liability if the manifest is incorrectly completed. There is a sample manifest in the appendix to this module, complete with a block by block instruction guide.

Tracking all waste shipped off site via Hazardous Waste Manifest Check to see that the manifest tracking log sheet has been completely filled out and if a manifest has not returned within the required time frames that copies of all correspondence relating to the search for the manifest are attached to the manifest tracking log sheet. This includes the exception reporting requirements for both small quantity and large quantity generators.

Tolling or Reclamation Agreement If the shop is using a solvent recycling company, who picks up the spent solvent in their company vehicles, and recycle the solvent, ensure that all copies to the reclamation agreement or tolling agreement are maintainer for a period of at least three years.

Posting of telephone number for emergency notification Telephone numbers for emergency notification are required to be posted next to all telephones. These numbers should include the local fire department, or response team that will be used in the event of a fire or release of hazardous material. The facility response personnel that will be responding and overseeing the management of the spill or response.

Biennial reporting requirement for large quantity generators of hazardous waste

Section A - EPA Identification No.

--

1 Does generator have and EPA I.D. Number?(262.12)

#

Section B - Manifest

1 Does generator ship waste off-site? (262.20)

a b.

If no, does the generator do on site treatment of Hazardous waste? If yes, identi@ primary off-site facility(s)

2 Does the generator use a Uniform Manifest? (262.20)

a If no, is generator a small quantity generator ( generating between 100 and 1000 kilograms of hazardous waste in a calendar month? (SQGs are only exempt if the waste is reclaimed through a tolling agreement)

b. If yes, does manifest include the following information? (Appendix 262)

1 Manifest document Number 2 Generator’ name, mailing address, telephone no. 3 Generator EPA I D number 4 Transporter name(s) and EPA I. D. Number(s) 5 a Facility name, address, and EPA I. D. Number

b C

Waste information required by DOT - Shipping name, quantity (weightNolume), containers type and number of containers

Is the following certification on each manifest form?

Alternate facility name, address, and EPA I.D. Number Instructions to return the waste to the generator if undeliverable to the facilities listed on the manifest

6

7 Emergency information (optional) 8

“This is to certify that the above named materials are [properly classified, described, packaged, marked and labeled and are in proper condition for transportation according to the applicable national and international regulations ”

Does generator retain copies of all manifests? (262 40) a 1

2 Who signed for generator?

9 Did generator sign and date all copies of the manifest?

Name , Title

b. 1. Did generator obtain handwritten signature and date of acceptance from initial transporter?

2. Who signed and dated for the transporter? (262.23)

Name , Title

c.

d.

e.

Does the generator retain one copy of the manifest signed by generator and initial transporter? (262 40) Do returned copies of manifest include facility owner/operator signature and date of acceptance? (262 40) Does the generator retain copies for 3 years? (262.40)

Section C - Hazardous Waste Determination (40 CFR 262.1 1)

I Does generator generate a solid waste(s) listed in Subpart D of the Hazardous Waste Regulations? List waste and Quantities including the EPA waste identification number c-

2 Does the generator generate solid waste(s) listed in Subpart C that exhibit hazardous characteristics (corrosivity, ignitability, reactivity, TCLP)?

List waste and quantities including the EPA waste identification number

3 . Does he generator determine characteristics by testing or by applying knowledge of process which generates the waste?

a

Are there any other solid waste generated by the generator?

If determination was made by testing list the test method used.

4.

he

a If yes, did the generator test all wastes to determine whether or no they are hazardous?

Section D - Pretransport Requirements

1 Does the generator package waste in accordance with 49 CFR 173, 178, and 179 (DOT requirements)’ (262.30)

2 a Are containers to be shipped leaking or corroding7 b C

Describe the condition of the containers Is there evidence of heat generation from incompatible wastes in the containers?

3

4 c.

5

Does the generator follow the DOT labeling requirements in accordance with 4 9 CFR7

Does the generator mark each package in accordance with 49 CFR 1727

Is each container or 1 10 gallons or less marked with the following label? “HAZARDOUS WASTE - Federal law prohibits improper disposal If found, contact the nearest police or public safety authority or the U S Environmental Protection Agency

Generators name(s) and Addressees(es)

Manifest document number

6 Does the generator have placards to offer to transporters for each of the hazardous waste streams generated at the facility?

7 Accumulation time (262.34)

a Are containers used to temporarily store waste before transport?

1 If yes, is each container clearly dated: Are the containers clearly dated with a start accumulation date?

2 Does the generator inspect all containers for leakage or corrosion7 Are the containers inspected weekly, is there a weekly inspection log that has been signed by the individual who inspected the containers?

b Does the generator locate containers holding ignitable or reactive waste at least 15 meters (50 feet) from the facility’s property line? (265 176 - Special requirements for ignitable and reactive hazardous waste)

C Does the facility use tanks for accumulation of hazardous waste’

d. Are the containers labeled in accordance with the DOT requirements outlined above7

e Does the generator comply with the requirements for personnel training7

Section E - Record keeping and Records (40 CFR 262.40)

1 Does the generator keep the following reports for three (3) years?

a b

C Exception reports d Test results

Manifest or signed copies from designated facilities? Biennial Reports ( for large quantity generators only - greater than 1000 kilograms of hazardous waste in a calendar month)

c- 2 Where are the records kept (at the facility or elsewhere?

3 Who is in charge of the record keeping?

Name and Title

Section F - Special Conditions

1 Has the primary exporter received from or transported to a foreign source any hazardous waste?

a b C

If yes, has the facility filed a notice with the Regional Administrator? Is this waste manifested and signed by a foreign consignee? If the generator transported hazardous waste out of the country, has he received confirmation of delivered shipment?

c. . APPENDIX B

a

r .

APPENDIX C

COLORADO MSDS FACT SHEET

C O L O R A D O

MaIumI- P R O G R A M

DOES YOUR BUSINESS GENERATE HAZARDOUS WASTES? DID YOU KNOW YOU ARE RESPONSIBLE FOR

DETERMINING IF M E WASTES YOU PRODUCE ARE HAZARDOUS AND, IF SO, ENSURING THAT THEY ARE

HANDLED PROPERLfl AS ENVIRONMENTAL REGULATIONS CONTINUE TO EXPAND IN SCOPE AND

INFLUENCE, IT IS INCREASINGLY IMPORTANT FOR BUSINESSES TODAY TO BE PRO-ACTIVE IN MANAGING

THE MATERIALS THEY USE AND THE WASTES THEY GENERATE. THREE IMPORTANT ELEMENTS OF A PRO-

ACTIVE BUSINESS ARE:

0 KNOW THE REGULATIONS. STAY ABREAST OF THE LATEST STATE AND FEDERAL

DEVELOPMENTS.

KNOW THE MATFRIALS YOU USE. A MATERIAL SAFEn DATA S H E n (MSDS) CAN BE ONE

TOOL FOR LEARNING ABOUT M E PRODUCTS YOU USE, AND THE WASTES YOU GENERATE.

MINIMIZE O R PREVENT WASTES. ALWAYS BE SEARCHING FOR WAYS YOU CAN REDUCE THE

AMOUNTS O F HAZARDOUS CHEMICALS YOU USE, AND LOOKING FOR NON-HAZARDOUS

ALTERNATIVES.

8

8

THIS FACT SHEET WAS CREATED TO HELP YOU UNDERSTAND THE MSDS. BUT IT IS IMPORTANT TO

REALIZE THAT THE MSDS IS NOT ALWAYS A COMPL€IE SOURCE OF INFORMATION ABOUT PRODUCT

DISPOSAL PmcncEs. To FIND om MORE -our THE CHEMICALS YOU USE, AND WHAT TO DO WITH

THEM WHEN THEY BECOME WASTE, CONTACT THE COLORADO DEPARTMENT OF PUBLIC HEALTH AND

ENVIRONMENT'S POLLUTION PREVENTION PROGRAM AT (303)692-3309.

PRODUCT -EL. SOME

PRODU- MAY QUALVY Ei

NOH-TO=. 3UT MAY mu coNTAlP4 wIz*RDous

ALL SE"

SDS a w o e mE PRODUCT, AND munv

#A Do N O T CoNSIoa Mz MSDS THE WnOlEKIURCL

PRECAUTIONARY ADVICE.

OF HAZAR-US INFO ABOUT

A PRODUCT.

A kT€RUL s*rrn DATA SHEEr (k'l-sm) IS USUALLY A ONE- OR TWO-PACE W C U M E M

THAT PROVIW A VARIEW OF INFORMATION -OUT ANY PRODUCT YOU PURCHASE. ALL W W U S CHEMICAL MANUFACTURERS AND DISTRIBUTORS ARE REOUIRED BY THE

O c c u P A n o w S m AND HEALTH Acr (OSHA) TO PROVIDE AN MSDS. HOWEVER.

THOROUGHNESS OF m E MANUFACTURER. wrr rr IS UP TO YOU TO ASSURE you WVE

THE OUALllY OF THIS INFORMATION MAY VARY SIGNIFICANTLY DEPENDING UPON THE

MDS'S ON FILE AT THE WORKPLACE FOR EVERY PRODUCT YOU USE.

IF AN MSDs WAS NOT PROVIDED WITH THE PRODUCT ITSELF. YOU MAY OBTAIN A COPY

BY WRmNC TO THE MANUFACTURER OR THE DISTRIBUTOR. EMP-YERS WHO USE.

-RE OR MANUFACTURE HAZAFZDOUS MATERIALS ARE REQUIRED BY U W TO MAHE THE

MSDS AVAILABLE TO ALL EMPLOYEES WHO COULD BE MPOSED TO THE MATERIAL.

FINES HAVE BEEN *sSESSED ON SMALL BUSINESSES BY OSHA FOR FAILURE TO HAVE

COMPLEE MSDS RECORDS AVAILABLE: TO EMPLOYEES.

THERE ARE TWO IMPORTANT THINGS TO LOOK FOR WHEN RECEIVING *N MSDS:

0 CHECK TO SEE THAT m E MSDS E W R ~ wmi YOUR INTENDED USE OF WE

PROW IN MIND. FOR WPLE. IF A PRODUCT IS x) BE SPRAYED. BUT THE

I

I MSDS ONLY DESCRIBES THE CHARACTERISTICS OF THE PRODUCT IN

POWDERED OR UOUID FORM, REOUEST ADDmONAL INFORMATION.

@ CHECK THE MTE THAT THE MSDS w* PREPARED. IF IT DOES NOT PROVIDE

A PREPARATION DATE, OR IF IS SEVERAL WARS O W , REOUEST AN UPDATED

I

C. .

I THE INFORMATION ON THE I MATERIAL is nAzARDous..

MSDS WILL HELP mu DETERMINE WHETHER WASTE

CONTAINING ANY OF THE

W NOT TAKE INTO

DERATION EXPOSURE

I ENVIRONMENT.

M W U R E M E RfSK FROM

-SURE.

CANNOT BE

2. SOME WASTES ARE

EXAMPLE. s n u B O ~ M

RES1OUES FROM

DRV2+EAHING OPERATIONS).

ALTHOUGH THERE IS NO STANDARD MSDS PROCEDURE OR STRUCTURE, ALL MSDS'S MUST CONTAIN THE SAME BASIC INFORMATION. THERE ARE EIGHT MAIN SECTIONS, DESCRIBED BELOW. IT MAY BE USEFUL TO LOOK AT THE SAMPLE MSDS (INCLUDED) WHILE READING THIS FACT SHEET.

0 MATERIAL MANUFACTURER AND IDEKnRCATlON HERE YOU WILL FIND THE NAME, ADDRESS AND EMERGENCY TELEPHONE NUMBER OF THE PRODUCT'S MANUFACTURER. THE CHEMICAL NAME (OR, MORE COMMONLY. m E TRADE NAME) OF THE PRODUCT IS GIVEN. IF THE PRODUCT IS A MIXTURE OF SEVERAL CHEMICALS. ONLY IT5 TRADE NAME WILL BE LISTED. O F E N A CHEMICAL ABSTRACT

PRODUCT IN HANDBOOKS. YOU CAN ALSO DETrRMlNE WHEN THE MSDS WLS PREPARED. SERVICE NUMBER WILL BE LISTED. THIS NUMBER FACUTATES RESEARCH ABOUT THE

e HAZARDOUS INGREDIWTS/IDCNTllY INFORMATION bSlS M E PRODUCT INGREDIENTS WHICH HAVE BEEN DETERMINED TO BE HAZARDOUS. THE PERCENTAGE. BY WEIGHT, OF EACH INGREDIENT IS LISTED, USING THE CHEMICAL OR COMMON NAME. DOES m U R MSDS GIVE THE CONCENTRATION LEVEL AT WHICH THE MATERIAL COULD POSE A HEALTH HAZARD? Tnis INFORMATION IS BASED ON RESEARCH USING tEsT ANIMALS IN LABORATORY MPERIMENTS. ONE ABBREVIATION YOU MAY SEE IN M I S SECnON IS THE THRESHOLD LIMIT VALUE mv). THERE ARE THREE TYPES OF nv's :

0 TIME WEK)HTED AVEFUOE (TLv/IwA) THE RECOMMENDED EXPOSURE CONCENTR4nON FOR A NORMU 8-UR WORKDAY. 40t iOUR WORKWEEK. IF THE MSDS LISTS ONLY TLV. TT USUALLY REFERS TO mts VALUE.

0 SHORTTERM -UR€ LIMIT mv/mu THE RECOMMENDED D(WSURE CONCENTRATlON ABOVE THE TwA FOR A LlMmD NUMBER OF I S-MINUTE EXPOSURE PERIODS.

0 CEILING EXPOSURE LIMIT a V / c ) THE RECOMMENDED EXPOSURE CONCENTRATION THAT SHOULD NOT BE EXCEEDED AT ANY nME DURING THE WORK PERIOD.

8 PHYSICAL AND CHEMICAL DATA DESCRIBES M E PHYSICAL CHARACTERISTICS OF THE PRODUCT, SUCH AS THE EVAPORATION RATE; WHETHER IT IS SOLID. LIQUID OR GAS AT ROOM TEMPERATURE; IF IT IS SOLUBLE IN WATER.

0 FIRE AND EXPLOSION HAZARD DATA DESCRIBES THE CIRCUMSTANCES UNDER WHICH THE PRODUCT MAY IGNITE OR 6XPLODE. WHAT IS THE FLASH POINT. THE IDWEST TEMPERATURE AT WHICH THE MATERIAL CAN RELEASE ENOUGH FUMMABLE VAPOR TO IGNITE? WHAT ARE RECOMMENDED DC~NGUISHING MEDIA? Is SPECIAL PROTECTIVE EQUIPMENT REQUIRED?

8 REAClMWDATA TELLS HOW THE PRODUCT WILL R U C T UNDER PARTICULAR ENVIRONMENTAL CONDITIONS. WILL IT DECOMWSE OVER TIME? WILL HEAT OR SUNLIGHT CAUSE A DINGEROUS RELCnON, PRODUCING A TOXIC OR FUHMABLE SUaSTANCE? -0 TELLS WHICH CHEMICAL5 ARE INCOMPATIBLE Wrrn THE PRODUCT AND SHOULD NOT COME INTO CONTACT WITH IT. REFER TO THIS SECTION WHEN CHOOSING SAFE STORAGE CONDITIONS.

(B HEALTHHAZARD PROVIDES A COMBINED ESTIMATE OF THE TOTAL KNOWN HAURDS OF THE PRODUCT. AND DESCRIBES ROUTES OF MPOSURE AND EFFECTS OF SHORT AND WNG-TERM EXPOSURE. INDICATES IF THE PRODUCT IS LISTED ON THE NATIONAL TOXICOIBGY PROGRAM (NTP) ANNUAL REPORT ON CARCINOGENS. O R IS A POTENTIAL CARCINOGEN ACCORDING TO THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER OR BY THE OCCUPATIONAL SAFEn AND H w m ADMINISTRATION.

e PRECAUIIONS FOR SAFE HANDLING AND USE TELLS THE SIFEST KNOWN WAYS TO HANDLE THE MATERIAL. ARE THERE SPECIAL PROCEDURES FDR CLUNlNG UP SPILLS OR Lwcs? HOW SHOULD YOU DISPOSE OF THE PRODUCT? ALSO PROVIDES INFORMATION THAT MIGHT NOT BE LISTED ELSEWHERE. SUCH AS STORAGE INFORMATION AND CLE4NING OR DISPOSING OF CONTAMINATED CIDTnlNG.

0 CONTROLMEASURES DESCRIBES PERSONAL PROTECTIVE EQUIPMENT. WORK PRACTICES. AND VENlllATION PROCEDURES TO USE WHEN WORKING WITH THE PRODUCT. ARE SPECIAL GLOVES OR RESPIRATORY PROTECTlON RECOMMENDED? IS PROTECTIVE EYEWEAR SUGGESTED?

2

f?AZARDOUS SUESTANCES MAY ENTER THE BODY ZHROUGU ONE OR MORE OF

d INGESnON - EATING OR

INHUTION - BREATWNG

THE MSDS IS NOT ALWAYS THE BEST SOURCE OF INFORMATION FOR D€ERMlNlNG WHEMER A PRODUCT IS HAZARDOUS. SOMETIMES A MATERIAL MAY NOT BE DESCRIBED AS HAZARDOUS IN THE MSDS. BUT IS IN FACT REGULATED BY STATE OR FEDERAL LAW IT MAY BE A CHARAClERI-C WASTE OR A U S E D W B T E UNDER THE RESOURCE CoNSERVAllON AND RECOVERY ACT (RCRA) YOU SHOULD BECOME FAMILIAR WITH THE FOLLOWING CONCEPTS.

a. CHARACERISnC WASTES IGNITME w m - (DO0 I ) A LIOUID WASTE wim A FWH POINT LESS IAN IAo°F; OR. A NON-UOUID WASTE WHICH IS CAPABLE, UNDER STANDARD

TEMPERATURE AND PRESSURE OF CAUSING FIRE THROUGH FRICTION, A0SORPllON OF MOISNRE. OR SPONTANEOUS CHEMICAL CHANGES AND. WHEN IGNITED, 6URNS VIGOROUSLY. THERE ARE ALSO OXIDIZING W A m s WHICH ADD OXYGEN TO A FIRE. oXlDlZlNG SUBSTANCES OfTEN HAVE PER AT THE BEGINNING OF M E NAME, OXIDE AT THE END OF ITS NAME, OR A E IN ITS CHEMICAL "E. CORROSIVE WSTE - (DO021 A WATER-WED WASTE HAVING A PH OF LESS 0 THAN O R EQUAL TO 2.0 (STRONG ACIDS) OR GREATER M A N OR EQUAL TO t 2.5 (STRONG LIASES); ALSO. ANY UQUlD ABLE TO CORRODE 1/4 INCH OF

STEEL PER YEAR.

0 REACTIVE WASTE - (0003) AN UNSTABLE OR EXPLOSIVE WASTE WHICH REACTS VIOLENTLY IN THE PRESENCE OF WATER AND SULFIDE. OR CYANIDE EEARING WASTES WHICH, WHEN MPOSED TO PH CONDITIONS BETWEEN 2.9 AND 12.5. UBER*TE TOXIC VAPORS.

0 TOXlCm CHARACTERISTIC W a T E - ( D 0 0 4 - D O 4 3 ) A WASTE WHICH

RELELSES TOXIC MITAIS. PESTICIDES OR VOLATllE ORGANIC CHEMICALS ABOVE CERTAIN UMKS UNDER ACIDIC CONDITIONS.

LlSlEDWASTES SPECIFIC MATERIU CONTROLLED UNDER R C W . e F-LIST - HAZARDOUS WASTES FROM NON-SPECIFIC SOURCES s u a AS:

-Foe I : SPENT HALOGENATED SOLVENTS USED IN DEGRWING SUCH AS TRICHLDRO-E. MPZIWYLENE CHLORIDE. I , I , I IR ICHLORONANE AND CARBON TITRACHLORIDE;

-F002: SPENT HALOGENATED SOLVENTS SUCH AS THOSE ABOVE. BUT NOT USED c5 DEGREASERS; OTHER EXAMPLES ARE I , I .Z-TRlCHLORO- I .2.2- TRIFLlJOROET).(ANE AND CHLOROBENZENE;

-Foo3: SPENT NONHALOGENATED. IGNITAELE-ONLY SOLVENTS SUCH AS -NE. ACEION€. METnANOL. AND METHYL I S O B U M KETONE;

-F004: SPENT n*rLDGENAT€D SOLVENTS SUCH CRESOLS. CESWC ACID AND NITROBENZENE;

-F005: SPENT NONHAU3GENATED SOLVENTS SUCH 6 TOUJENE. M€WY'L €WYL -NE ( M W . CARBON DISULFIDE AND EENZENE;

SFJENT SOLVENT MMNRE/ELENDS COHTUNING I 0% BEFORE USE OF FOO I , F002. FoO4 AND/OR f-5; AND.

-DlSTlUTlON EO'rrOMS FROM RECOVERING SOLVENTS.

e K-LIST - HAZARDOUS WASTE FROM SPECIFIC SOURCES SUCH *s CERTAIN

pLAnw MTH SOLUTIONS; WASTEWATER TREATMENT SLUDGE. AND WASTES FROM THE HEAT TREATMENT OF METALS.

e P AND u-~isrs - DISCARDED COMMERCIAL c n E w c A L PRODUCTS. OFF-

SPEClflCATION PRODUCTS. CONTAINERS AND/OR SPILL RESIDUES.

3

I

THE FOLWWING IS A UST OF TERMS AND AEBREVIATIONS COMMONLY FOUND ON THE MSDS OR ASSOCIATED WWH

HAZARDOUS MATERIALS.

AESORIWON - THE PROCESS BY WHICH A SUBSTANCE CAN BE READILY TAKEN INTO A BODY.

CHEMICALS CAN BE ABSORBED THROUGH UNBROKEN SKIN. FOR INSTANCE. SOMl

R WATER, REACTTO RE BE USED TO N

H& M E A B l u T I

-BASED SOLUTION.

G W H Z H STRONGLY 1 NG nssue.

W U t D WITH A

OUNT OF A SUBSTAN R, SOILOR LIQUID.

ON OF. OR 1RROlERSLBl.E ALTERATION5

SlVE CAUSTICS ARE SOMUM HYDROXlOL

€ST TEMPERANRE AT WH

CHEMICAL OTHER THAN B M N G 1VE THAT CONTAINS OXYGEN AXD MAY START OR SS.151 3UMBUSION IN OTHER MATERIAS. EXAMPLES ARE CHROMIC ACID, CONCENTRATED NllRIC ACED, AND WTASSIUh "MANGANATE.

)EL - PERMISSIBLE EXPOSURE LIMIT - THE SAFE EXPOSURE W E L SET BY THE OCCUPATIONAL SAFf3Y AND HUT+ -MINETRATION. (SEE ALSO. lLV)

=H - A SYMBOL USED TO OUANTIFT THE LEML OF ACIDIW 0 3ASES NEAR 1 3 . A PH LEVEL OF 7 1NDtCATES NEUlRAUlY.

ILIWNTTY. STRONG ACIDS HAVE A PH NEAR 1 , -NE

?EAClWRY - THE AlSluTT OF A MATERIAL TO UNDERGO CHEMICAL REACTlON Wmr THE RElEASE OF ENERGY OR HEAT.

4

I

POTASSIUM HYDROXIDE, PELLETS (various grades) 1310583

'CMEM~CAL NAME ANOIOR SYNONYM

Potassium Hydroxide. Synonyms: Potassium Hydroxide, dty solid, flake, bead or granular; caustic potash: potash lye.

MOLECULAR WENimT

KOH 56.1 1

FORMULA

ADDRESS (No. STREET C I T Y . STATE 4N0 L I P COO€l

GENERAL CHEMICAL CORPORATION CN 1829 Morristown, NJ. 07960- 1829

CONT*CT PUONE NUMBER LAST ISSUE O A R

October 1986 Director of Environmental Matters (201) 455.5630

I 1 POTASSIUM HYDROXIDE, PELLETS

e

EMERCENCV PHON& NuMeEa

(201) 455-3700

Eyes: Immediately flush with large amounts of water for at least 15 minutes, holding eyelids apart to facilitate irri- gation. Utmost speed i s essential. Call a physician. I f none is available, irrigate another 3U minutes before moving patient to a medial facility. Have an ophthamologist make an evaluation of eye injury.

Skin: Immediately flush under safety shower. If wearing goggles, flush head and face thorougt~ly before removing Its. Next, wash viaim's hands until all chemical is removed (indicated by disappearance of soapiness).

R n remove contaminated clothing and shoes. Call a physician. Continue washing for O(K or two hours and remove to a medical facility if a physician is not available.

Inhalation: Remove to fresh air. If breathing h difficult,or if victim i s cyanotic (blue skin), give oxygen i f qualifnd operator is available. Arrange for medical help.

Ingestion: Do not induce vomiting. I f possible. k " i a te l y give large quantities of water or milk. T h i s may be followed with dilute vinegar or fruit juice to neutralize alkali. Arrange for immediate medical help.

-

Inhalation of mistordust can injure the entire respiratory tract with painful and corrosiveaction on tissue. Irritancy estimated to become noticeable at 2 mg/cum. in air. Concentrations of 200 mglcum. are immediately dangerous - pulmonary edema (fatal a t highter levels) may occur.

Severe and rapid corrosive burns of mouth. gullet and gastrointestinal tract will result, if swallowed. Effects indude sewre pain, difficulty in breathing, vomiting, diarrhea, collapse. Some effects may be delayed. Estimated average fatal dose (LO50 terminology): 5 g. (human, adult) - Ref. (c).

Severe and rapid corrosion from contact. Extent of damage depends on duration of contact. Even dilute solutions exert a destructive effect, following prolonged contact. Mist of solutions is extremely corrosive.

Contact rapidly =uses severe damage. Permanent corneal damage almost inevitably results. Even dilute solutions may produce similar effects, although less rapidly. Mist of solutions i s extremely corrosive.

EYES

PERMlSSlBLE CONCENTRATION AIR BIOLOGICAL . No OSHA/TWA established.

ACGIH/TLV: 2 mglcu.m. (ceiling value).

(SEE SECTION J )

None established.

UNUSUAL CHRONIC l O X l C l T Y

None reported.

CPl-?)r. c.c I . . . ^ . .

F L A S H M I N T N.A OC

Not flammable. OOPEN CLIP DCLOSEO CUP

AUTO ICNI 1lON TEMP€AA 1UR E OC FLAMMABLE LIMITS IN AIR 1% BY V0L. j

Not applicable. LOWER - Not applicable UPPER - Not applicable

nANoL"C 00 not gct in eyes on skin or on clothing. Avoid brathing dust or mist, i f generated. Keep container closed when not in use. Use with adequate ventilation. Wash thoroughly after handling. When making rolutions, add slowly to surface to avoid splattering. using sufficient I agitation and cooling. Avoid handling conditions that may lead to spills, leaks, ejections, or to the formation of dust or mist W a r protective clothing.

*f IRE EXTINGUISWING AGENTS IIECOUULNO€O

If involved in a fire. flood with water. taking care not to splash or scatter th is material. and keeping it away from common mctais (see Section C, above).

FIRE EXTlNCUlSHlNC AGENTS TO AVOID

Carbon dioxide, because it reacts exothermically with this material.

SPECIAL C IRE F ICHTING PRECAUTIONS

Firefighters should wear selfcontained, NIOSH-appioved breathing apparatus and iuil protective clothing, including eye protection and boots. Material can mel t in a fire a n d molten material can react violently with small amoonp of water (spatter- ing or misting). and with certain common metals to liberate f lammabk hydrogen gas.

No particular problem with the pellets as sold. However, i f made into a solution or i f ground up and m is t of dust b generated, provide local exhaust ventilation to meet TLV requirements. In the absence of mist or dust, natural ventilation may be adequate. venti lat ion facilities should be corrorion-resistant. (continued - see Section K.)

. V E N T l U f M N

STORAX€ I

Store in closed containers in a dry. well-ventilated area separate from acids. peroxides. metals. easily ignitible materials and other incompatibles. Protect against moisture and water: protect against physical damage. (continued - see Section K.1

aunvp personnel need protection against inhalation and/or skin and eye contact hazards. Dry product can be promptly shoveled up for recovery or disposal. (CAUTION? Avoid dusting and skin or eye contac t Also, delay in clean-up may al low absorption of moisture from the atmosphere, increasing c leanup difficulties.) Wet trace residues witb water and neutralize with dilute acid (preferably acetic acid) to remove. final traces. (Sodium bicarbonate may also be used to partially neutralize.) Finally, rinse area with water; at tempt to keep out of sewer. Any release t o the environment of this product may be subject to federal and/or state reporting requirements. Check with appropriate agencies.

Worktrs should not be permitted to handle this material without proper training and drilling in the constant use o f protective safety equipment. Equipment used with solutions of th is material should not be made of soft iron. copper. tin. aluminum, zinc or alloys of these metals. All equipment should be frequently inspected for leaks and.any potential problems.

t SPILL OCr LEA% (ALWAVS MAA CEASONAL PROTECTIVE EWIPMENT -SECTION El

SPECIAL: PRECAU TlONS/PROCEOUR€S/ LABEL INSTRUCTIONS SIGNAL WORD - DANGER!

REYIRAfORV ?ROTECTIOU

In the absence of dust or mist, none generally required. For concentrations above the TLV, NIOSH-approved respiratory protection should be used: (1) for dust or mis t up to 5 times the TLV, use a high-efficiency particulate respirator with half facepiece; (2) for higher concentrations, use a high-efficiency particulate respirator with a full facepiece.

Wear chemical safety goggles i f there is any possibility of contact with liquid or mist with the eyes. Add a face shield if there is any possibility o f contact with liquid with face. Do not wear contact lenses i f handling liquid br dusty solid material.

ErEs ANO FACE

HANOS. ARMS. AND 6001

Wear neoprene or rubber gloves and full protective c lothing (apron. boots, etc.) i f there i s any possibility o f contact with pellets. dust or liquid or mist f rom solutions. Contaminated d o t h i n g should be removed promptly and washed before reuse.

OTHER CLOTHING AN0 EOUIPMENT

.Hard hat, undcr same conditions as for gloves. boots and protective clothing. Provide eyewash stations, quick-drench showers and washing facilities accessible t o areas of use and handling. Arrange for neutralization supplies and equipment and abundant running wa tcr.

YAT€RIAL I S (AT NORMAL CONOITIONSI:

YAUROOUS K)LYMERIZAT(ON

0 MAY OCCUR a WILL NOTOCCUR

o m u l o 8 SOLI0 0 GAS

n BOILING POINT 132Ooc

CONOlTlOM TO AVOID

None known.

MELTING POINT (83% KOH) '3600C *wries with water content

SOLUEILITI IN WATER r * b y ~ c l

505 @ 10°C.

E V A M R A T I O N R A T E iauwAcmatm - 110 ( E I ~ C I - 110

Negligible a t ambient conditions.

APCEARANCE A N 0 OOOR

White pellets, hygroscopic; odorless.

SPECIFIC GRAVITY I M g - I1

(solid) 2.044 (83% KOH)

0.1M solution: 135

IS VOLATILES 8 Y VOLUME I& W.CI

Negligible at ambient conditions.

VAPOR DENSITY (AIR - 11

Not applicable. Negligible vapor a t ombien t amdi tions.

VAPOR PRESSURE h " m g r t W C l O t"3la

Negligible.

37d81LITY CONOlTlOM TO AVOID

0 UNSTABLE H STABLE 0

None, other than prolonged exposure to air. - Reacts with carbon dioxide from the air to form potassium carbonate.

I I N ~ P A T l c l l L I T Y WATERIALS TO AVO101

Common metals a d their alloys (sea Section C); acids and their anhydridexeasily oxidizable compounds. including explosives. aldehydes and unsaturated organics: nitrocarbons and chlorocarbons. Strong exothermic reaction with water or moisture (generates much heat).

HAZAROOUS OECOuPOSlTlON PAOWCTS

I I

M. x MAtERlAL OR COMPONEN1lCA.S. #

Not applicable.

1C124-525 (1 1/84) 3

~

HAZARO DATA (SEE SECT. J)

- PROPRIETARY - TRADE SECF

-OEG~AOI.ILITVIAOUATIC TOXICITY OCTANOLIWATER PARTITION COEFFlCtENl

Unknown. Degradability - N.A. (inorganic).

7 ,

1000 (I 40 CFA 116417 0 If SO A € P M T A B L L O U A N T I T Y

NO

€?A UAZAROOUS SUBSTANCE' (CLEAN WATER ACT SECT, 31 I )

' WUTP OIYOUL UCTWOOS toisrosEa MUST COUPCV wtrw F EOERAL. STATE ANO LOCAL OCSCOSAL OR OISCHARCE ami

I€ IIYISIImLE CONCENTRATION RE C ER € MCES

TLV: ACGlH 1985-86 List. "Threshold Limit Values and Biological Exposure Indices". = e

Waste Potassium Hydroxide pellets may be handled by first reducing to an aqueous solution by adding to water with o r e , neutralizing as per Spill or Leak procudures (Section 0 ) and flushed to sewer with lots of water (requlations pcmittinq).oc

.disposed o f through a licensed contractor. Since disposal may be subject to federal, state or local regulations ( t P A corrosive waste, aqueous form), users should review their operations in terms of applicable federal. state and local laws and regulations. then consult with appropriate regulatory agencies before Qischarging or disposing of waste material.

' W R A STATUS OF URUSEO MATERIAL IF OISCAROEO HAZARDOUS WASTE NUMBER: (IF APPLICABLE) .o CFR 26 1 In mI1.t lorm. as sold. not a "hazardous wastd':* N.A.

0002 In aauoous solution. an EPA *'hazardous wasla.' (corrorlvr).

J

REGULATORY STANOAR05 0 0 T. CLASSIF I U f l O N : Corrosive material 4 9 C F I 113

1.0. No.: UN1813 DOT classification: Hazardous Materials Table. 49 CFA 172.101.

Section 0 - PRECAUTIONS/PROCEDURES - continued

VENTILATION - continued

In the event hydrogen gas is generated (see Section C), a severe ventilation problem is rapidly innodoced. CO2, coupled with l o u l ventilation or respiratory protection, is probably the best emergency action. In th is situation, ventilation facility must also be explosion-resistant if such an emergency i s likely to happen.

STORAGE - Continued Drains for storage or use areas for this material should have retention basins for pH adjustment and dilutions of spills and f lush ing before discharge.

6 0 s FILE NO. GC-3002

TCRONYh4 LIST

NPDES

NPL

NRC

OSHA

PCB

PEL

PMN

PPA

PPE

P2

RCRA

c.

RQ

SARA

SDWA

so

SQG

SPCC

TCLP

TPQ

TSCA

TSD

UIC

UST

WMOA

National Pollution Discharge Elimination System

National Priority List

National Response Center

Occupational Safety and Health Act

Polychlorinated Biphenols

Permissible Exposure Limits

Premanufacturing Notification

Pollution Prevention Act

Personal Protective Equipment

Pollution Prevention

Resource Conservation and Recovery Act

Reportable Quantity

Superfund Amendment and Reauthorization Act

Safe Drinking Water Act

Secretarial Orders

Small Quantity Generator

Spill Prevention Control and Countermeasures

Toxic Characteristic Leaching Procedure

Threshold Planning Quantity

Toxic Substance Control Act

Treatment, Storage and Disposal

Underground Injection Control

Underground Storage Tank

Waste Minimization Opportunity Assessment

Pollution Prevention Training for Automotive Service …0 Used oil 0 Spent solvents t Other waste...

Documents

Transcript of Pollution Prevention Training for Automotive Service …0 Used oil 0 Spent solvents t Other waste...