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Please!!!!!. Silence your cell phones. Be considerate of your neighbor. Welcome. Automotive/Repair & Fleet Management 18 May 2010 RNO 9:00-12:00 23 June 2010 LV 9:00-12:00. Presented by:. Who’s Looking?. State Fire Marshal and/ or Local Fire Dept. Repair Shop. Air Quality.
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Please!!!!! • Silence your cell phones. • Be considerate of your neighbor.
Welcome Automotive/Repair & Fleet Management 18 May 2010 RNO 9:00-12:00 23 June 2010 LV 9:00-12:00 Presented by:
Who’s Looking? State Fire Marshal and/ or Local Fire Dept. Repair Shop Air Quality Worker Safety OSHA Wastewater Discharge Hazardous Waste Federal EPA & NDEP/County Refer to the Environmental, Health, and Safety Agencies listing!
Why Do You Need An Environmental Compass?? • To prevent spills, leaks, or accidents that could harm the environment or your business. • To make common sense decisions that will save you money. • To have a safer working place for you and your employees.
A Walk About Hazardous Waste
Elements of Hazardous Waste Management • Waste Determination. • Generator Status. • On-Site Management. • Spill Response. • Record Keeping.
Generator Status • CUMULATIVE OF ALL HAZARDOUS WASTES PER MONTH. • Do not count exempted wastes: Used Oil, Oil Filters, Antifreeze, Lead Acid Batteries. • DO NOT “AVERAGE”. • Generator status can change monthly…manage your business accordingly.
TOOLS FOR MAKING A WASTE DETERMINATION • Material Safety Data Sheets (MSDS). • Product Manufacturer. • Process Knowledge. • Environmental Laboratories. • Business Environmental Program.
Is It A Hazardous Waste? • Four Questions to ask: • Is it a solid waste? • Is it exempt or excluded? • Is it listed? • Is it characteristic? * Asking these questions should keep mistakes in identifying hazardous waste to a minimum (40 CFR §262.11).
Identify if the Waste is a Solid Waste • A Solid Waste May be a Solid, Liquid, or Gas. • A material is a solid waste if it is “Discarded”: • Abandoned; • Burned; • Recycled. • A material must be a Solid Waste before it can be a Hazardous Waste.
If you answer NO to question #1 • Stop!! You do not have a hazardous waste!
Exclusions/Exempt • Domestic Sewage. • Industrial Wastewaters covered under the Clean Water Act. • Irrigation Return Flows. • Household Hazardous Waste. • 40 CFR §261.4 for complete list.
Waste Determination • Now determine if the waste is: • Listed? • Characteristic? • Both Listed & Characteristic? • Keep All Determinations on File. • Even if the waste is non-hazardous.
Is it Listed? • F LIST - Wastes From Non-Specific Sources Such as Solvents, Still bottoms, and Plating Wastes. • K LIST – Specific Wastes From the Chemical Manufacturing Industry. • P, U LISTS – Discarded and/ or, Off-Specification Chemical Products, Container Residues and Spill residues. • P - ACUTE HAZARDOUS WASTE. • U - TOXIC HAZARDOUS WASTE.
4 Hazardous Characteristics A hazardous waste can be defined by one or more of the following: Ignitability = D001 Corrosivity = D002 Reactivity = D003 Toxicity = D004 –D043
Characteristics of Hazardous Waste • IGNITABILITY • FLASHPOINT LESS THAN 140º F • EPA Hazardous Waste Code D001 • Paint thinner, gasoline, alcohol, solvents
Characteristics of Hazardous Waste • CORROSIVITY • pH< 2 or pH > 12.5 • EPA Hazardous Waste Code D002 • Hydrochloric acid, sodium hydroxide
Characteristics of Hazardous Waste • REACTIVITY- • NORMALLY UNSTABLE, EXPLOSIVE, REACTS VIOLENTLY WITH WATER OR FORMS TOXIC GASES. • EPA Hazardous Waste Code D003. • Cyanide or sulfide bearing waste when • Exposed to pH conditions between 2 and 12.5. • Can generate toxic gasses.
Characteristics of Hazardous Waste • TOXICITY- • LABORATORY ANALYSIS. • TCLP. • 7-11. • EPA Hazardous Waste Code D004 - D043.
A Few Auto Repair Related Wastes that May Require Analysis • Sand/Oil Separator Sludge. • Solvents, High-Flash Or Aqueous Cleaning & Degreasing Solutions. • Paints. • Paint Booth Exhaust Filters. • Beads, Sand blast media, or sanding residue
TCLP Testing • Measures the potential to seep or "leach" into groundwater if a waste is landfill disposed. • 40 parameters, specific regulatory limit for each. Examples from the 40 CFR §261.24 Table 1
Universal Waste • Streamlines collection and management standards for certain hazardous waste streams: • Batteries; • Recalled/suspended pesticides; • Mercury thermostats; • Used fluorescent, neon, mercury vapor, sodium and HID lamps.
Universal Waste • Intent is to encourage recycling. • Does not count toward generator status. • Shows attempt to reduce the volume and toxicity of hazardous waste.
A Walk About F-tubs
Bulb Crushing is not Universal Waste Bulb crushing is considered treatment. Is not allowed to be managed under Universal Waste. A business that uses a bulb crusher must follow 40 CFR §262 & all hazardous waste regulations. This will count toward the monthly generator status. Mercury control device is required. Waste determination of uncrushed bulbs.
Mercury Containing Equipment • Mercury Containing Equipment (MCE) is: • Thermostats; • Barometers; • Manometers; • Temperature and pressure gauges; and • Mercury switches.
Vehicle Switch Removal • Which vehicles contain mercury? • Not all vehicles contain mercury switches, and many phased them out. American vehicles manufactured before 2001 & foreign cars before 1992. • Where are the mercury switches located? • Most often found in car’s hoods/trunks. • Are there alternatives to mercury switches? • Yes: ball bearing to trigger the electrical connection.
Vehicle Switch Removal • What should I do if I break a mercury switch or capsule? • Harmful if inhaled, ingested or handled. • Clean small spills on nonporous surface by wiping up and sealing the cloth in a plastic bag. • Purchase a mercury spill kit. • Never use a vacuum to clean up spill. • Never use a broom to sweep the mercury.
Other/Exempt Wastes Streams • Specific types of waste are not regulated as hazardous waste provided that they are managed properly. Examples include: • Automotive Batteries; • Wipers and Rags; • Used Antifreeze; • Used Oil; • Oil Filters.
A Walk About Batteries
Automotive Batteries • If picked up for recycling, not considered hazardous waste. • Keep receipts on file to document recycling. • If cracked, prepare a waste determination prior to disposal (D002, D008). • Remember to store in a cool, dry, and safe place!
A Walk About Rags
Wipers and Rags • If disposed, you must determine if they are hazardous waste: • Listed solvents; • Toxic characteristics.
On-site Management Strategiesfor Fluids • Used Oil. • Used Antifreeze. • Spent Solvents. • Paint and paint related wastes. • Sand/oil separator waste.
A Walk About Used Oil Used Oil Filters
Used Oil • Label as “USED OIL”. • Do not mix with hazardous waste. • Contaminated Fuels – keep separate from used oil. • Can self transport up to 55 gallons to a recycler. • Does not count toward generator status.
Management Suggestions for Used Oil • Secondary Containment. • Keep drums or containers out of the environment. • Drum Funnels/ KEEP CLOSED. • Give preference to companies who re-refine your used oil. • On-site used oil furnaces. • Secondary Oil Filtration.
Oil Analysis Program • Decrease the amount of oil purchased/ waste. • Double oil life. • Reduce labor.
Re-refined Oil QUICK FACTS: • Re-refined oil is the same quality as virgin oil and carries the API seal of certification. • It takes 1 gal of used oil to make 2½ qts of re-refined oil. It takes 42 gals of crude to make the same 2½ qts of virgin oil. • Recycling oil, could save the US 1.3M bbls/day.
Synthetic Transmission Fluid & Gear Oil • Synthetic transmission fluid has extended service intervals 3 x’s that of normal fluid, reducing downtime and maintenance costs. • Synthetic gear oil is the only gear lube now used for all vehicles, reducing down time and improving lubrication. • Antifreeze is collected and sent to recycling.
Oil Filters • Puncture the dome end. • “Hot Drain” (60 F), minimum of 12 hours. • Once punctured and drained, can be thrown to the trash. • Don’t have to crush the filters. • Fuel and other filters are not exempt.
Reusable Oil Filters • Applicable for fleet applications, and others. • Reduce on-site filter inventory. • Can last the lifetime of the vehicle. • Eliminates used oil filter management.
A Walk About Used Antifreeze
Used Antifreeze • If recycled, no waste determination needed. • Does not count toward generator status. • Keep receipts for at least 3 years. • Can Self transport up to 350 gallons.