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Hazardous Waste Management for Automotive Service Operations

This article – originally published in AWARE in the spring of 1997, and updated to reflect changes in the law since – summarizes important rules and offers some suggestions for dealing with hazardous wastes that might be generated at your Toyota or Lexus dealership. Because this topic is every bit as important today as it was in 1997, we thought this AWARE article was "Worth Repeating."

EPA regulations cover a wide range of potentially hazardous wastes from automotive service operations. The best practice, of course, is to reduce or eliminate as many of these hazardous wastes as possible so that your dealership can become a "conditionally exempt small quantity generator." In most states, this allows you to generate up to 220 lb. per month.

Important State Variations

Several states have significant differences in what they regulate as a hazardous waste. Storage and quantity limits and whether to use a federal uniform manifest or a state manifest form also vary. Check with your state agency on specific regulations for your state. Links to these agencies can be found on the EAN website under State Contacts.

Summary of Federal Requirements

To properly identify and manage your hazardous wastes, you will need to:

  • Understand what EPA defines as a hazardous waste and the potentially hazardous wastes generated at your dealership.
  • Determine your generator status by calculating the maximum amount of hazardous wastes generated in a month.
  • Provide proper EPA notification of hazardous waste generator activity.
  • Verify that your hazardous wastes are properly stored and transported and disposed/treated at an EPA-permitted facility.
  • Prepare manifests and maintain proper records.

What is Hazardous Waste?

Although 17 pages of fine print in the Code of Federal Regulations are devoted to defining hazardous waste, we will attempt to cover the high points here.

A material (solid, liquid or gas) that is to be discarded is a regulated hazardous waste, by EPA definition, if it is a characteristic or listed waste. A material is a characteristic hazardous waste if it is ignitable, corrosive, and reactive or exhibits toxicity characteristic.

Do not mix a listed hazardous waste with a non-hazardous waste, or the resultant mixture will be a hazardous waste. Mixing a characteristic hazardous waste with a non-hazardous waste results in a hazardous waste only if the mixture exhibits a characteristic.

Listed Wastes. Two types of listed wastes (both spent solvents) are commonly found in vehicle maintenance shops:

  • Spent halogenated solvents which are used in degreasing and contain chlorinated compounds
  • Spent non-halogenated solvents which contain xylene, methanol, ethyl ether, methyl isobutyl ketone

Ignitable Wastes. An ignitable waste is one which has a flash point of less than 140°F such as:

  • Parts cleaning solvents
  • Kerosene
  • Paint thinner

Corrosive Wastes. A corrosive waste is a liquid that has a pH less than2.0—an acid—or greater than 12.5—a caustic. Common examples are:

  • Aluminum brighteners and cleaners
  • Battery acid
  • Many floor cleaners
  • Caustic paint strippers

Reactive Wastes. Reactive wastes include cyanide- or sulfide -containing materials or any waste which will spontaneously combustor form explosive gases when mixed with water, air or other materials.

Toxicity Characteristic (TC) Wastes. A waste is also considered hazardous if the results of a Toxicity Characteristic Leachate Procedure (TCLP) test indicate concentrations above regulatory levels of certain chemicals. The following wastes can potentially, but not necessarily, be defined as a hazardous waste under the TC rule:

  • Water that has been in contact with gasoline, used motor oil or other hydrocarbon products
  • Water and sludge that have accumulated in the bottom of fuel storage tanks, used oil tanks or other vessels
  • Spent solvents that contain chlorine or fluorine or that may have been contaminated with Benzene, lead, cadmium or other TC compound
  • Debris contaminated with used oil, diesel fuel or gasoline such as shop rags, absorbents or other debris containing hazardous substances
  • Water and sludge from the clean-out of shop floor drains, pipes and oil-water separators (OWSs)
  • Spent antifreeze
  • Paint wastes, including paint booth filters
  • Fluorescent bulbs, mercury-vapor lamps and other mercury containing parts such as thermostats

Waste Survey

Conduct a survey of all wastes generated throughout a typical one-year period. Estimate maximum monthly amounts, in pounds, of each waste category, determine the total number of pounds of hazardous waste generated per month and determine the hazardous waste code for each waste.

Generator Status

Conditionally Exempt Small Quantity Generator (CESQG). If you generate no more than 220 lbs (100 kg) of hazardous waste per month, you are a CESQG.

This status allows you to store no more than 2,200 lb. with no storage time limits. You must send your hazardous wastes to an EPA-permitted facility or a facility approved by your state to receive industrial/municipal wastes.

Small Quantity Generator (SQG). If you generate between 220 and 2200 lb.per month, you are an SQG.

SQGs can accumulate no more than 13,228 lbs. (6,000 kg) of hazardous waste on site and can keep waste no longer than 180 days without a permit. You can accumulate this amount of waste for up to 270 days if you must transport it more than 200 miles away for recovery, treatment, or disposal. You must send your hazardous wastes to a licensed hazardous waste facility.

Most automobile dealerships are either CESQGs or SQGs. If you generate 2,200 lb. per month or more, or if you store 13,200 lb. or more, you become a large quantity generator (LQG) and are subject to more stringent rules. Remember, certain states have stricter rules.

EPA Notification

Facilities that generate more than 220 lb. of hazardous waste within anyone calendar month must notify the EPA of their activity by using the EPA Notification of Regulated Waste Activity form.

Hazardous Waste Storage

The following hazardous waste storage requirements apply to SQGs and LQGs, but are also good practice for CEGs:

  • Always store wastes in drums or containers that are compatible with the materials being stored.
  • Clearly mark each container with the words "HAZARDOUS WASTE" and the date you began to collect the waste in that container.
  • Keep containers in good condition, handle them carefully, and immediately replace leaking ones. Inspect daily.
  • Keep the container closed except when you fill or empty them.
  • Make sure containers used for storage of ignitable or reactive wastes are placed at least 50 ft. from your property line. Place visible "No Smoking" signs in these areas. Electrically ground both storage and filling containers.
  • Never store in the same container wastes that may react together and cause a fire, explosion, corrosion, leak or other release. Incompatible wastes stored in close proximity must be properly separated.

Manifests/Transportation

The EPA requires a state or federally approved manifest document be completed prior to the shipment of hazardous wastes. Generators are required to prepare hazardous waste shipments with the proper container and labels.

Reporting and Recordkeeping

All generators must keep the following records for a minimum of threeyears, although an indefinite retention time is recommended:

  • Manifests and copies from destination facilities
  • Notices of land disposal restriction
  • Exception reports
  • Laboratory test results

For SQGs and LQGs, a biennial report of hazardous waste activity is due to the EPA region March 1 of even numbered years

Designating an Emergency Coordinator

SQGs and LQGs are required to designate an emergency coordinator. LQGs must prepare a written contingency plan that describes equipment and procedures to follow in the event of a spill or other emergency involving hazardous waste. Employees should be trained in proper and safe hazardous waste handling, storage, and disposal if these activities are part of their duties.

Minimizing Hazardous Wastes

Wherever possible, eliminate or reduce hazardous wastes. SQGs and LQGs are required to certify efforts to minimize hazardous waste generation in the biennial report and in manifests.

To reduce the amount of hazardous wastes you generate:

  • Eliminate certain hazardous products from your product inventory and substitute safer ones.
  • Switch to a mineral spirit-based parts cleaning solvent with a flashpoint above 140° F. Use continuous recirculation and filtration equipment to extend solvent life. Consider the use of water-based parts cleaning equipment.
  • Do not mix non-hazardous wastes with hazardous wastes.
  • Never mix solvents or other potentially characteristic hazardous wastes with used oil unless you can document that this is NOT a violation of state and federal rules.
  • Avoid leaks and spills. Clean-up materials may also be hazardous.
  • Empty all containers and aerosol cans prior to disposal. Use all of the product.
  • Avoid using more hazardous substances than you need for a particular job.
  • Take immediate action when a release or threatened release of a hazardous substance or waste is suspected or confirmed.

Conclusion

Review your policies and procedures for managing hazardous wastes at your dealership. Perhaps you can find ways to reduce or eliminate some of these wastes and save on the costs of their disposal. Always check your state waste agencies for regulations which may be more stringent than federal regulations.

For more information on this subject, follow this link to the Code of Federal Regulations at 40 CFR 260-262, or consult your state/local waste regulatory agency.

Attention Service Managers

Today, more than ever before, recycling and other environmental management issues are at the center of every dealership’s daily service activities. The EAN program is designed to help your dealership in its efforts to properly collect, store, and dispose of hazardous waste streams.

As a matter of good environmental management policy, every dealership should conduct periodic self audits of environmental management practices. For more information about performing a self audit of your hazardous waste management practices, follow this link to an excerpt from the Consolidated Screening Checklist for Automotive Repair Facilities Guidebook.