?

Sponsored By: partment of Environmental Quality, Waste Reduction Section

Presented by:

m Bellevue. WA

Program Funded by a U.S. EPA RITTA Grant

i , TABLE OF CONTENTS

Redudng Hazardous Waste: Oregon Hazardous Waste Regulations

and the Vehicle Maintenance Industry

M m r a wastb ReszIfatory summary Identifjring Hazardous Wastes Vehicle Maintenance Wastes Regulatory Status

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Vehicle Maintenance Shops and Waste Reduction Techniques Industry Summary 2- 1 Processes and Waste Produced 2-1 -Oil and Grease Removal 2-1 -Engine, Parts, and Equipment Cleaning 2-1 -Auto Body Repair and Paint Shops 2-3 -Solution Replacement 2-3 -Other Wastes 2-4

Waste Reduction Techniques 2-4 -Introduction 2-4 -Source Reduction and Recycling 2-5

2-10 Waste Reduction for Specific Waste Types

Summary Table of Regulatory Requirements

References and Information Sources

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SUAaMARY of OREGON HAwlRDOUS WASTE REGULATIONS for the VEHICLE MAINTENANCE INDUSTRY

The entire scope of hazardous waste handling, from "cradle-to-grave" including generation, storage, transportation, treatment and disposal, is governed by the Resource Conservation and Recovery Act (RCRA).

RCRA provides for managing, tracking, regulating and minimizing wastes. It also includes measures for proper training.

The U.S. Environmental Protection Agency (EPA) oversees RCRA and develops the federal RCRA regulations that set the standard for the nation. Final control of RCRA programs can be given to individual states provided the state develops a hazardous waste program at least as stringent as the established federal program. Oregon's hazardous waste program is run by the Oregon Department of Environmental Quality (DEQ). The regulations are found in the Hazardous Waste Management Rules, Oregon Administrative Rules Chapter 340, Division 100 to 100 and 120 and the Code of Federal Regulations (CFR) Part 260 through 272.

Complying with RCRA requirements includes following Department of Transportation (DOT) regulations for hazardous materials. DOT regulations cover labeling, placarding and other handling requirements, for the safe transportation of hazardous wastes.

Oregon's Toxics Use Reduction and Hazardous Waste Reduction Act was enacted by the 1989 Oregon Legislature. The Act requhes all facilities that are toxics users or hazardous waste generators to develop a waste reduction plan and monitor its progress. The object of the plan is to outline the methods and defhe the goals for reducing amounts of toxics used and hazardous waste generated. House Bill 3515 does contain guidelines on what should be included in the plan.

DEQ is required to provide technical assistance to those affected by the Act. Technical assistance will be based upon a number of factors, including amounts and toxicity of hazardous substances released, potential for current and hture toxics use reduction, and level of risk to public health and the environment caused by exposure to the toxic substance. Assistance will include information databases, telephone hotline assistance, training workshops in toxics use and reduction, a technical publications library, and evaluation and recognition programs.

House Bill 3515 provides funding for programs under the Act, with additional funding provided through surcharges on users of toxic substances and generators of hazardous wastes.

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The following discussion is only a summary of the Oregon hazardous waste regulations. Those requirements which apply to the typical vehicle maintenance business are highlighted. You can contact the DEQ at (503) 229-5913 or (800) 452-4011 for additional information.

Identifsring Hazardous Wastes

Businesses in the vehicle maintenance industry generate several different types of waste. I t is the responsibility of each business to determine whether their waste is regulated as hazardous or non- hazardous. In general, a hazardous waste is any discarded materials which, if improperly disposed of, may pose a threat to human health or the environment. Under RCRA, a waste is considered hazardous if it is specifically listed in the regulations (40 CFR Part 261) or possesses one of the following characteristics:

Ignitability, 0EP Toxicity,

Corrosivity, or Reactivity.

Tests should be conducted if it is unclear whether or not a waste possesses one or more of the above characteristics.

The EP toxicity characteristic test will be replaced by the Toxic Characteristic Leaching Procedure (TCLP) starting on March 29, 1991.

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A waste is designated an acutely hazardous waste (AHW] if it is fatal, or causes serious irreversible damage, to humans in low doses when taken orally, inhaled or absorbed through contact with the skin. Substances such as arsenic, cyanide, Parathion and strychnine are included on this list.

Characteristics of Hazardous Waste

Ignitable: Substances that burn or combust at a temperature less than 140' F are considered ignitable (flammable). They can be liquids, solids, flammable gases or oxidizers. Non-liquid ignitables are capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture or spontaneous chemical changes. Typical ignitable substances in the vehicle maintenance industry are methyl ethyl ketone (found in paint products) and solvents used for parts cleaning. These substances can yield dangerous wastes that pose a fire hazard.

EP Toxic: Wastes are EP Toxic if, after they have been subjected to a chemical extraction procedure (EP), the leachate is found to contain

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high concentrations of heavy metals or specific pesticides. Toxic wastes can cause illnesses such as cancer, kidney damage, birth defects and blood disease. Paint sludge from recycling of solvents is EP Toxic.

Corrosiue: Corrosive wastes are acidic liquids (pH less than or equal to 2). alkaline liquids (pH greater than or equal to 12.5) or liquids that corrode steel at a rate greater than 0.25 inches per year. These wastes can dissolve most materials: specialized containers are necessary to resist corrosion. Corrosives may dissolve the skin and lungs and extreme care must be used when handling them. Acids, potash, and naval jelly used in rust removal are corrosive materials.

Reactive: Reactive wastes are very unstable and readily, rapidly or violently change when mixed with or exposed to water, heat, pressure or other materials. These wastes, especially cyanide or sulfide compounds, may generate toxic gases under mildly acidic or alkaline conditions. Chromic acids, perchlorates and peroxides are common reactive substances. Wastes produced from reactive substances are hazardous because they may explode or spontaneously ignite in air or water. Reactive wastes are typically not generated by the vehicle maintenance industry.

Vehicle Maintenance Wastes

Vehicle maintenance is a varied industry, and generates a variety of wastes. Solvents used for parts cleaning make up a large portion of these wastes, some of which are chlorinated solvents such as methylene chloride (toxic, persistent) and trichloroethane, Solvents are often designated as ignitable. Lead-acid batteries, which are often replaced in vehicle maintenance shops, contain sulfuric acid which is designated corrosive. However, as long as the sulfuric acid is kept in the battery and the battery is recycled, the acid (and battery) does not have to be managed as a hazardous waste.

An Oregon law passed in 1989 prohibits disposal of lead-acid batteries by any method other than recycling. Battery retailers and wholesalers are required to take back used batteries for recycling.

Automotive paint and body work shops have waste streams dominated by paint and thinner wastes. Methyl ethyl ketone is designated toxic as well as ignitable. Acids and potash used for oil and grease removal are corrosive, as is naval jelly used in rust removal. Thinners are usually ignitable, but designations and waste codes vary with constituents of the thinners.

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Used oil and waste antifreeze may or may not be hazardous depending on characteristics.

The table below provides hazardous waste codes. The correct DOT shipping name for a specific waste should be verified with your transporter or the regional offices of the federal Department of Transportation (DOT) or the state offices of the Public Utility Commission (PUC) prior to completion of the hazardous waste manifest. Items listed are examples only, and other DOT descriptions and identification codes may be applicable in some circumstances.

Waste materials generated as a result of various vehicle maintenance operations include:

WAS= TYPE WASTE CODE

Wastes fitom oil and grease removal

- acids

- causticsoda - carburetor cleaners - chlorinated solvents - ignitable degreasers - mineral spirit solvents - petroleum naphtha - petroleum distillates - 1 , 1.1 -trichloroethane

- potash DO02 DO02 DO02 F002 or F004 F O O 1 DO0 1 DO0 1 DO0 1 DO0 1 F O O l

wastes from paint prepaiation

- white spirits, varsol

- enamel reducers - methyl ethyl ketone (MEK) - mineral spirits - petroleum distillates - Still bottoms from solvent recycling

- alcohols

Paintwastes

- acrylic and alkyd paints - enamels and epoxy paints - lacquers - most paints with toxic metals

DO0 1 DO0 1 DO0 1 F005 DO0 1 DO0 1 FOO1, F002, F003, F004 or FOOS

DO0 1 DO0 1 DO0 1 DO08 or DO07

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- Still bottoms from solvent recycling

Auto painting equipment cleaning, paint removal, stripping

acetone alcohols enamel reducers methyl ethyl ketone (MEK) methylene chloride mineral spirits petroleum distillates vm&p naphtha toluene white spirits xylene Still bottoms from solvent recycling

Rust removal

- acids - navaljelly

Used lead-acid batteries

- sulfitrlc acid - lead dross/scrap

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FOO1, F002, F003, F004 or F005

F003 DO01 DO0 1 F005 F002 DO0 1 DO0 1 DO0 1 F005 DO0 1 F003 FOO1, F002, F003, F004 or F005

DO02 DO02

DO02 DO08

Generators of waste should be careful not to pour liquid hazardous waste down the drain or dispose of solid hazardous waste in the dumpster.

Waste Oil

Waste oils that are recycled are not currently considered a hazardous waste in Oregon, nor are they an EPA listed hazardous waste, unless they are mixed with other waste that is designated as hazardous under state or federal laws, or if they exhibit a hazardous characteristic. However, some regulations regarding used oils exist, and they should be managed properly.

Recycling of used oil is a service provided by collectors of used oil. Most used oil recycling services currently charge the generator a fee

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to pick up the oil due to the low price of oil and the cost of recycling. However, even with the charge, recycling of used oil can be an economically and environmentally sound way to dispose of waste oils. Generators using this type of service should determine from the service what the find disposition of the oil will be and verify that the oil will be handled in an environmentally safe and legal manner.

Used oil generated by a business may be bumed on-site in a commercial space heater. Used oil may not be collected from other generators, unless the used oil is generated as a household waste (Le., do-it-yourself oil changers), or unless the person delivering the oil is a registered used oil marketer and has certified that the oil meets certain quality specifications.

If used oil does not meet quality specifications, it is known as "off spec" oil. A generator may bum his owq off spec oil if the heater is designed to have a maximum capacity of 500,000 BTU and is vented to the outside. A generator may not bum off-spec oil collected from other generators unless it is received from do-it-yourself oil changers who generate used oil as household waste. Because used oil frequently contains high amounts of water, sludge and ash-forming components, it should be burned only in specially designed boilers.

The RCRA regulations have established concentration limits for specific constituents in the waste oil. Used oil is off-specification if any of these concentration limits are exceeded:

Arsenic Cadmium 2 ppm maximum chromium 10 ppm maximum Lead 100 ppm maximum Flash Point looo F mini"

.Total Halogens 4000 ppm maximum

5 parts per million (ppm) maximum

If used oil is mixed with a listed or characteristic hazardous waste, it may result in the entire mixture being regulated as a hazardous waste, This may mean that the generator of the used oil is no longer a small generator, and thus would be subject to the requirements of large generators, and the fuel burning requirements for hazardous waste incinerators.

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Regulatory Status

The more waste produced and/or accumulated by a vehicle maintenance shop, the more regulatory requirements must be met. Each company must comply with the requirements set for its generator category. Hazardous waste generators are allowed to temporarily accumulate hazardous waste on site without a storage permit. However, accumulatfon time and quantity vary depending on the company's generator status as described below:

Fully Regulated Generators Generates or accumulates 2,200 lbs. (approximately gallon drums) or more of hazardous waste, or 2.2 lbs. or acutely hazardous waste per month.

Small Quantim Generators

five 55 more of

Generates between 220 lbs. (approximately half of one 55 gallon drum) and 2,200 lbs. of hazardous waste per month and never accumulates more than 13,200 lbs. at any time.

Conditionally Exempt Generators Generates less than 220 lbs. of hazardous waste and less than 2.2 lbs. of acutely hazardous waste per month and never accumulates more than 2200 lbs. of hazardous waste and 2.2 lbs. of acutely hazardous waste at any time.

An outline of the Hazardous Waste Generator Requirements of each generator category is attached.

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THE VEHICLE MAINTENANCE INDUSTRY

Industrysammnrrr

The vehicle maintenance industry is comprised primarily of four segments. The main segment, automotive repair shops, encompasses a wide range of services including machine shops, transmission repair, brake and muffler shops, and radiator service. The other three segments include new car dealerships, diesel engine repair shops, and automotive paint and body work shops.

The majority of the businesses in this industry are classified as small quantity generators (SQGs) of hazardous waste. SQGs, as defined by the Environmental Protection Agency (EPA), generate at least 220 pounds of hazardous waste per month, but less than 2,200 pounds per month. Despite this small quantity designation, a report issued by EPA's Office of Solid Waste shows this industry leads all others in numbers of generators, and is the largest producer of hazardous waste material among all small quantity generators.

Typical operations in the vehicle maintenance industry that produce hazardous wastes fall into four categories:

Oil and grease removal:

Engine, parts, and equipment cleaning:

Auto body repair and auto painting: and

. Solution replacement.

Processes and wastes produced in each category are summarized below.

Oil and Grease Removal

Degreasers are used in oil and grease removal, as well as for engine parts cleaning, and equipment cleaning. Such materials include carburetor cleaners, engine cleaners, varsol, solvents, acids, caustics, and cleaning fluids. Degreasers can contain the following ingredients:

Enane Parts and EauiDment Cleaning

There are different types of parts washers, but the vehicle maintenance industry primarily uses solvent parts washers, hot tanks, pressure cleaning chambers, and jet spray washers.

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washe r Solvent parts washers and solvent sinks recirculate solvent continuously from the solvent drum to the solvent wash tray where the parts are cleaned. A variety of solvents are used, including methylene chloride or trichloroethane. Spent solvent is periodically recharged with fresh solvent.

Waste solvents are generated primarily from parts washers and carburetor cleaners. Waste solvents may also contain sludge generated during the cleaning process.

* H o t Tank Hot tanks containing caustic solutions are used by auto, heavy equipment and radiator repair shops. An aqueous solution is electrically heated to enhance the penetrating action for dissolving grime on parts or removing deposits from the inside of radiators. The tank may be equipped with air or mechanical agitation. Hot tanks are serviced periodically by removing partial amounts of liquid and sludge and recharging the solution with detergent. Caustic soda is used for hot tanks which clean ferrous-based metals. Detergent based cleaners are used for hot tanks which clean aluminum-based metals.

Hot tank cleaning produces a sludge composed of solids which settle to the bottom of the tanks as parts are cleaned. Some of the sludge generated from cleaning older radiators may contain heavy metals such as lead, zinc, and copper. The bulk of the material is sand and fine sediment.

Pressure Cleanina Chamber The pressure cleaning chamber is a self-contained bath with recirculating and/or agitated compartments. Cleaning solutions similar to those used in the hot tank are used in the pressure chamber, generating similar wastes.

Jet Swrau Washer The jet spray washer uses an electrically heated aqueous wash

solution. Parts are suspended in the washer and rotating water jets spray the parts to clean them. Like hot tanks, jet spray washers are serviced periodically by removing partial amounts of liquid and sludge and recharging the solution with detergent.

Patntina Owerations Paint thinners, enamel reducers, solvents, strong acids, and strong caustics are used to clean spray booths, spray guns, and brushes. Wastes generated by the painting process are described in the following section.

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Auto body repair and paint shops use rust removers, paints, and paint removers and thinners as part of their operations. Rust removers can contain naval jelly and strong acids or caustics. Paint can contain enamels, lacquers, epoxies, alkyds (synthetic resins used in paints, varnishes, etc.), acrylics and primers. Paint removers and thinners can contain solvents, enamel reducers, strong acids, and strong caustics.

e paint ThznnerS Paint thinner for both enamel and lacquer paints is mixed with paint and generally consumed in the painting process. Waste paint thinner is generated piimarily as a result of cleaning paint spray guns and other equipment. On-site distillation systems used for reclaiming spent thinner produce a paint sludge often referred to as "still bottoms". Still bottoms consist of residual thinners and paint residues. The paint residues may contain zinc, chromium, cadmium, lead, nickel, and mercury used as pigments and additives in the paint.

Paint Restdues Paint residues are generated from incomplete use of a container of paint and as a result of paint sticking to the bottom and sides of a container after pouring or pumping the product. If the paint was mixed with thinner in its original container, residual thinners would also be present. Paint residues may contain heavy metals used as paint pigments and additives. , I

Paint Booth Ftlters Paint booths are used in many auto body facilities as well as some of the larger vehicle maintenance facilities. The booths provide a controlled environment for collection of overspray from vehicle painting. Air from the paint booth passes through a filtering system to remove suspended paint particles and organic vapors. These filters eventually become clogged with paint and solvent and need to be cleaned or replaced.

Solution Redacement

Used antifreeze, motor oil, brake fluid, transmission fluid and power unit fluids are generated when vehicle solutions are replaced. These may contain ethylene glycol and petroleum distillates, respectively.

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Other Wastes

.Batteries Lead-acid batteries are replaced when they have been damaged or can no longer hold a charge. These batteries usually contain sulfuric acid with dissolved lead and lead dross/scrap.

0 Sb;r , RggS Shop rags are used throughout the vehicle maintenance industry. The rags become soiled with oil, grease, solvents, and paint. Such rags could be considered hazardous waste if contaminated with a listed hazardous waste or if they retain the hazardous characteristic of the waste, such as ignitability or EP toxicity.

Empty product containers and drums may contain residual solvents, paints, and paint thinners.

Containers

WASTE REDUCTION TECHNI$UES . Introduction

Minimizing the production of hazardous wastes in your vehicle maintenance business makes sense because it can help you to:

* reduce operating costs by using less raw materials:

avoid expensive hazardous waste transportation and disposal costs:

reduce your regulatory requirements, saving time and money:

improve workplace health and safety:

reduce the liabilities associated with the transportation, treatment and disposal of hazardous waste: and

reduce potential damage to the environment. . Federal and state regulations require that hazardous waste generators (of greater than than 220 IbsJmonth) must manage their wastes in accordance with the appropriate hazardous waste regulations and certify that they have a program in place to minimize the volume and/or toxicity of hazardous wastes. The EPA defines waste minimization as both source reduction and recycling.

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Source Reductfoq Source reduction includes good housekeeping techniques, raw material substitution, and changes in processes which reduce the amount of hazardous wastes produced at the source of generation. For example, replacing solvents with aqueous cleaners in hot tanks and jet spray washers have proven effective in reducing the generation of hazardous wastes from parts cleaning equipment. Use of drip trays and collection of solid residues from cleaning further controls waste discharges . l 3 a f € u ? Recycling includes the recovery and reuse of hazardous wastes such as spent solvents. Solvent recovery can be accomplished on-site by using a solvent distillation unit, or off-site by having a recycler pick up waste solvent.

Source Reduction and Recvclhg

There are many ways to reduce the amount of hazardous waste produced in your vehicle maintenance business without buying new equipment, Improved "housekeeping" practices ean minimize the chance of material losses. They can be as simple as keeping records of hazardous materials purchased to avoid overstocking or as complex as changing management's perspective on the substitution of raw materials to ones which are less hazardous. Reducing the amount of hazardous waste leaving your operation generally means a cost savings for the business.

Source reduction and recycling practices include:

1. Management Initiative 2. Employee Training 3. Good Housekeeping Practices and Improved Operating

4. Leak and Spill Prevention 5. Raw Materials Substitution 6. Waste Stream Segregation 7. Use of Waste Exchanges

Practices

The majority of waste products generated by the vehicle maintenance industry are reusable or recyclable. These wastes include antifreeze, paint and thinner wastes, used oil, car batteries, soiled rags, and CFCs used in air conditioning units. Most recycling techniques will be discussed below by specific waste type or vehicle maintenance process.

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1. Manuement Initiative

Management support is critical to any waste reduction program. If there is not enough visible support from management, employees will see little incentive to look for waste reduction opportunities and the waste reduction program will not be as effective as it could be. Employee incentive programs such as awards for waste reduction ideas can help foster awareness of waste reduction policies, goals, and benefits.

By conducting a waste reduction assessment, management can determine their shop's waste, reduction potential. An assessment consists of the following fundamental steps:

Identify a te& leader:

Identify shop processes where chemicals are used and wastes are produced:

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EvaIuate existing waste management and reduction methods:

Research alternative technologies:

Evaluate feasibility of waste reduction options:

Implement measures to reduce wastes: and

Periodically evaluate your waste reduction program.

2. Emnlovee Training

Employee training is an important part of your waste reduction program. The personnel responsible for operating and monitoring equipment, loading and unloading hazardous materials and purchasing, storing and transferring chemicals should be trained in safe operating procedures, including the handling of hazardous wastes and proper equipment use.

Employees should be trained before they star t working with hazardous materials and trained on-the-job any time new procedures are implemented on new equipment or materials are used. Employees should also be made aware of the hazards of the materials they will work with by reviewing the Materials Safety Data Sheet (MSDS) prepared for each chemical and through training required under federal and state occupational safety and health regulauons. This awareness will help identify their personal responsibility in maintaining safe practices which help minimize hazardous waste production.

Training should also be given on hazardous substance spiU prevention, such as how to detect leaks in any of the systems used in the vehicle

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maintenance operation. Techniques for minimizing the pbtential for a release of hazardous substances should be emphasized.

Employees should be cautioned not to accept a sample product from a vendor (e,g., a new solvent or paint thinner) because it may become a hazardous waste when discarded or may generate a hazardous waste if used, Employees should be trained to read the label and MSDS sheet and understand what is in the product and how to use it. The selection process should have worker safety as a top priority.

Employee training should address the waste disposal costs and liabilities that your company incurs as a generator of hazardous waste. Understanding the causes of solvent loss and waste generation as they relate to their individual areas of responsibilily will promote employee participation in your waste reduction efforts.

3. Good Housekeeping Tips

The following steps can help improve shop operations:

available so you know what you're working with. label all raw material containers and have MSDS sheets readily

Use drip pans to collect oils and fluids.

*Squeegee excess cleaning solutions from parts, drip pans, or the floor before cleaning or applying any absorbent material.

Reduce drag-out and material losses from degreasers and cleaning tanks by' allowing cleaning solutions to completely drain back into cleaning tank.

*Tightly seal all bungs and lids on solvent containers, to reduce evaporation, spillage and contamination with water, dirt or other materials.

Caution when handling and transporting containers of hazardous materials. Make certain that the equipment used to transport the containers is in good condition and that safety standards are observed.

Drain solvents, paint, and paint thinners from their containers to ensure that the container is legally empty and therefore not a hazardous waste. Product containers should not be reused unless th5y have been adequately rinsed and are used to store the same or other compatible materials.

Monitor material consumption and purchase in appropriate amounts to avoid product waste.

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Consider waste management costs before buying new materials and equipment.

4. Minimize SD ills and Leakg

Spilling and leaking of hazardous substances can create hazardous wastes which must be properly managed. If the material used in the clean up, such as water or absorbent, is contaminated with the hazardous substance, it must be discarded as a hazardous waste. Quick response to a spill can minimize the amount of spill material, including any contaminated soil or water. Therefore, spill and leak prevention are important ways of reducing your hazardous waste generation.

Spills can be prevented by:

Identlfjling areas where spills or leaks might occur and taking precautionary measures:

Using all equipment properly:

Checking containers and equipment regularly to see if they are leaking: and

Handling all containers of hazardous materials properly.

Using containers and/or shelving that are "shake" proof. I

Spills can be mfnimized by:

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*Using drip catchers Using dry absorbents, not water Enclosing storage areas wtth berms and dikes

Material Substitutio n

One way to reduce waste generation is to use less toxic raw materials or products which reduce waste generated. For example:

Use high performance, longer-lasting oils:

Use recycled (refined or refiltered) petroleum products (oil, transmission fluid, antifreeze, hydraulic fluid):

Use waterless hand cleaners:

Replace solvent based compounds with detergent-based and water-based compounds: and

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Avoid using halogenated compounds (chlorines, fluorines) to help reduce the potential for contamination of used oil.

6. Waste Stream SeIrrwtion

It is important not to mix different waste streams. Once a non- hazardous waste is contaminated with a haz-ardous waste listed in the regulations, the entire waste stream becomes a "listed" hazardous waste and must be managed as such. A mixing of two non-hazardous wastes could result in the formation of a waste that exhibits a hazardous characteristic.

Waste stream segregation helps make waste recycling easier. The following steps can help facilitate recycling and reduce the amount of hazardous waste diposed of:

never mix used oil with any hazardous waste:

keep solvents, aqueous cleaners and carburetor wastes separate: and

keep chlorinated solvents separate from non-chlorinated solvents.

7. w Waste exchanges or materials exchanges provide another management alternative. Materials exchanges are organizations that manage or arrange the transfer of wastes between businesses, such that one producer's waste material or feedstock might be another business's feedstock. #

For a copy of the latest catalogues, contact:

PME Pacific Materials Exchange S, 3707 Godfrey Blvd, Spokane WA 98204 Bob Smee (509) 623-4244

IMEX Industrial Material Exchange 172 20th Ave. Seattle, WA.

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Waste Reduction and Recycling Methods for Specific Waste Types

Solvent Wasteg

Most spent solvents are generated as a result of parts cleaning, degreasing and cleaning paint application equipment cleaning operations. Solvent losses due to evaporation, equipment leaks or spills and inappropriate usage can range from 25-40%.

Where practical, steam cleaning and pressure washing of equipment and parts should be substituted for solvent parts cleaning. However, steam cleaning and pressure washing are primarily used for rough or preliminary cleaning of parts and equipment. Wastewaters generated from this process-can generally be discharged to the sanitary sewer system depending upon waste content and approval of the local sewerage agency.

Use water-based pressure washing systems instead of parts washers that use solvents:

Increase freeboard on parts washers to prevent solvent evaporation:

*Place hoods on all parts cleaning and carburetor cleaning equipment control solvent evaporation:

Clean tank sludges regularly to maintain fresh solvent: and

Use dirty solvent first when cleaning equipment, followed by fresh solvent to reduce the amount of fresh solvent used.

Solvent test kits can be used to ensure that solvent is replaced only when it is truly dirty.

Consider the use of dry wipes or wire brushing to pre-clean parts prior to soaking.

Distillation and reuse of solvents minimizes the amount of waste solvents which must be managed as hazardous wastes. The distillation process recovers solvents by heating the mixture sufficiently to vaporize the soIvent and then condensing the vapor. This process produces dean solvent and a sludge material often referred to as a "still bottom". Small solvent recycling units are now commercially available for businesses generating low volumes of waste solvents.

Where solvents must be used, businesses may contract with a licensed hazardous waste management service for recycling or disposal of spent solvents, or use solvent sinks which can help reduce the amount of solvents used, and therefore, the generation of solvent wastes.

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A solvent sink that drains directly into a waste storage drum is safer and easier to use than a dunk bucket or dip tank. Remember to turn off the solvent when the sink is not in use. Also, place a plug in the drain of your solvent sink when not in use to prevent evaporation.

No matter which reduction method is used, it is very important to keep spent solvent wastes separate from other waste streams.

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Hot Tan k Wasteg

Both the liquid and the sludges present in hot tanks may be hazardous wastes when disposed of because they may be caustic or contain heavy metals. Options for minimizing the amount of hazardous waste generated from these units include process chemical replacement, elementary neutralization, and sludge dewatering.

Replenishment of caustic chemicals in the hot tank, rather than discharge and replacement of the entire volume of the tank, will aid in minimizing the volume of liquid generated as a hazardous waste. This method involves adding a new solution of caustic to the tank as it becomes ineffective for metal cleaning, instead of discarding the entire volume of the tank. Care must be taken during this process to prevent the caustic solution from becoming too concentrated or dilute. Eventually the caustic solution will become too dirty to work effectively and will need to be totally discharged and replaced. The usefulness of the caustic solution can be prolonged by straining it through cheesecloth or felt, however there is risk of employees resulting from the increased handling of hazardous chemicals.

Sludge dewatering is the process of draining sludges in a basket over the hot tank, or allowing liquids to evaporate prior to drumming the sludge. Dewatering reduces the volume of sludge to be disposed of as a hazardous waste. Sludge dewatering should be used only for hot tank sludges, never for still bottoms of a solvent still. Solvent still bottoms must be treated and disposed of as a hazardous waste.

Radiator Test Tank Wastes

Radiator test tank wastes consist primarily of wastewater and some sludge. The sludge consists primarily of solder drippings, which may contain lead. The generator should determine if the sludge exhibits EP toxicity characteristics for lead. Sludge which exhibits EP toxicity must be managed as hazardous waste. If the sludge is not EP toxic, and sludge has been removed from wastewater, the wastewater may be discharged to the sanitary sewer. Solder in the sludge can be recovered on-site and re-used. If it cannot be reclaimed, non- hazardous sludge may be disposed of at a sanitary landfill if proven non-hazardous.

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Used Oil Iincludes motor oil. transm ission fluid 8r b rake fluid

Used oils that are recycled are not currently considered a hazardous waste, unless they are mixed with another waste that is designated as hazardous under federal or state laws, or they exhibit a hazardous characteristic. Several waste management options are available for managing used oil is that has not been mixed with a listed or characteristic hazardous waste.

Used oil generated by a business may be burned on-site in a commercial space heater. Used oil may not be collected from other generators, unless the used oil is generated as a household waste &e., do-it yourself oil changers), or unless the person delivering the oil is a registered used oil marketer and has certified that the oil meets certain quality specifications.

If used oil does not meet quality specifications, it is known as "off spec" oil. A generator may bum his own off spec oil if the heater is designed to have a maximum capacity of 500,000 BTU and is vented to the outside. Because used oil frequently contains high amounts of water, sludge and ash-forming components, it should be burned only in specially assigned burners.

Recycling of used oil is a service provided by collectors of used oil. Most used oil recycling services currently charge the generator a fee to pick up the oil due to the low price of oil and the cost of recycling. However, even with the charge, recycling of used oil can be an economically and environmentally sound way to dispose of waste oils. Generators using this type of service should determine from the service what the final disposition of the oil will be and v e w that the oil will be handled in an environmentally safe and legal manner.

In addition to off-site recycling of motor oils, commercial filtration units are available to filter used hydraulic fluid. Other units are available to filter and blend used diesel crankcase oil for supplemental diesel fuel.

Antifreeze

Waste antifreeze (ethylene glycol) is not yet designated a hazardous waste although disposal to sewer systems is restricted in some areas. Antifreeze may be saved and poured back into the radiator after the repair work is finished. Antifreeze should not be poured down a storm drain under any circumstances.

Antifreeze recycling services are now available in Washington and other states. These services will schedule pickups of waste antifreeze and/or deliveries of new antifreeze every one to three months.

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SDent Lead -Acid Batteries

Off-site recycling of batteries is the most viable alternative for waste minimization. Lead-acid battery reclaimers recycle the used batteries by removing the lead for re-use. In most states, it is illegal to dispose of a vehicle battery except by delivery to a battery dealer or authorized recycler.

& Thinners can either be recycled off-site or on-site through a distillation process. For off-site recycling, generators simply send their waste thinner to commercial recyclers. Commercial recyclers have versatile distillation processes and can handle large volumes and varieties of thinners. Reclaimed thinners are often sold back to the generators after the thinners have been reconstituted.

For on-site recycling and recovery, several altematives are available. Gravity separation is an inexpensive form of resource recovery that is relatively easy to implement. This form of reclamation separates the thinner from the sludge in the mixture. Decanting is another resource recovery method which uses a drum pump and a float valve to retrieve the surface thinner. Thinner reclaimed by decanting can be used as %ash thinner" (Le., thinner used for primer and base coats) as well as to clean equipment. The reclaimed product can also be used to supplement new wash thinner supplies and is even used in parts washers where thinner purity is not critical.

For larger quantities of paint residues and thinners, on-site distillation may provide a more cost-effective alternative. The distillation of all high-grade thinner wastes can virtually eliminate the need for purchasing lower quality thinners for use in preliminary painting operations and cleanup. From 5 gallons of paint and thinner wastes, the distillation process can generate 4.5 gallons of reclaimed thinner and .5 gallons of sludge (this ratio varies depending on operations at individual shops and type of equipment used.

S~rav Gun Cleaning

Gun washers can reduce waste from cleaning paint spray guns by recirculating the thinner used to clean the guns. A regular maintenance schedule is important to obtain optimum results from spray guns.

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EmDtv Conta inerz

Legally empty containers (see definition of "empty" in the Regulatory Summary) do not constitute hazardous waste. Many solvent vendors will accept emptied containers back for refill. Containers recycled in this manner are not regulated as hazardous wastes. If the containers have been adequately rinsed, they may be disposed of at a licensed sanitary landfill. You must check with local authorities for specified restrictions.

If shop rags are not contaminated with a listed hazardous substance and do not exhibit a hazardous characteristic (ignitability, EP toxicity, corrosivity, or reactivity), they may be sent to an industrial laundry service for cleaning. If rags contain any amount of a listed hazardous waste or retains any of the hazardous characteristics (except ignitability), they must be managed as hazardous waste.

The goal of handling solvent-soaked rags is to remove as much of the solvent as possible to reduce the chance of improper disposal and potential environmental and health problems. In reaching this goal, most generators can also reduce their costs for purchasing virgin product and handling hazardous waste solvents.

DS to Reduce Sol vent Left in R a q ~ -

6.'

1. Avoid soaking rags in solvent to clean equipment. Use a plunger or a squeeze bottle filled with solvent to moisten, rather than soak, cleanup rags. A little solvent can go a long way.

2. Set up equipment or procedures to remove as much solvent as possible from rags. Use a hand-operated wringer or a mop wringer to wring solvents out of rags. You can also squeeze solvent out of the rags by hand (use protective gloves) before putting them in the rag container. Remember the extreme fire hazard associated with storing and using solvent soaked rags.

3. Minimize rag use by buying or leasing a parts washer. Make sure that the parts washer you get recirculates & reuses the solvent.

Refrigerant from Air Conditioners

Most refrigerants, including the CFC-12 used in mobile air conditioners, are chlorofluorocarbons, a class of synthetic chemical compounds. When CFCs escape into the atmosphere, such as release into the air during A/C service, they destroy stratospheric ozone.

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Ozone depletion could lead to an increase in skin cancer, damage to the humane immune system, reduced crop yields and harm plant and animal life.

CFC-12 can be recycled. Using certified equipment, a hose is attached to a vehicle’s air conditioner, and the refrigerant is pulled from the vehicle into a holding tank. The refrigerant is then processed through an oil separator, a filter and a dryer. The CFC can then be returned to the ais conditioner after repairs are completed.

As the supply of CFCs is restricted, shops that service A/Cs can expect the price of CFC-12 to increase and the availability to decrease.

References

Alaska Health Project, 1987, Waste Reduction T iDS f0 r Vehicle ReDair Shops.

California Department of Health Services, Alternative Technology Section. Toxic Substances Control Division, January 1987, Waste Audit StudvA utomotive Paint Shops. Steams, Conrad and Schmidt Consulting Engineers, Inc.

California Department of Health Services, Alternative Technology Section, Toxic Substances Control Division, May 1987, Waste Audit Studv Automotive ReDairq. Toy, W. Me, Consulting Engineer.

California Department of Health Services, Alternative Technology Section, Toxic Substances Control Division, October 1988, Hazardo us Waste Reduction Assess ment Handbook Aut omo tive pepair ShoDs.

Minnesota Technical Assistance Program (MnTAP), Auto Bodv ReDair Hazardo us Waste Managgme nt and Reductioq . Factsheet.

Montana Department of Health and Environmental Sciences, June 1988, The Small Quantitv G enerator’s Ha ndbook for Managing RCRA Wastes: Automotive and Heaw EauiDment Maintenance,

Oregon Department of Environmental Quality, Hazardous Waste Program, Vehicle Maintenance and ReDair.

Toy, W. M., October 5, 1988, Waste Minimization in the Automotive Repair Industry. Waste Management.

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"

SUMMARY OF OREGON HAZARDOUS WASTE GENERATOR REQUIRJ3MENTS

PunyRegulatedGmtmtoxa S d Quantity Generatom Conditionally Exempt Generators 22200 ms€m?222hsAHw >22oms~<22oDmsHw < 220 Ibsw. <22IbsAHw

Waste Minimization

CeNfL on each manifest that you

hepare reductton plan by 9-1-91

Each employee who handles

have a waste minimfiation program

Annual progress reports

hazardow waste must be

-regulatory compliance -emergency~P- emergency equipment

thoroughly tratnedin

Contingency Plan Prepar&ess/Prevention requirements Incident reports to EPA Emergency Procedures

(file within 45 days)

(within 45 days of d a n d e r quarter)

Exception Reports

mQuderbRepo*

Expanded Fourth Quarter Report Periodic Survey

M d e s t s (3p) Exception reports (3 yrs) Test results/sample analyses (3 yrs) Tfatning documentation Inspection logs

* . B i d report (3 yrs) Land Disposal Restrictions

Pay appropriate fees

EEY TO ABBEVIATIONS / ACRONYMS Hw Hazardous Waste AHW Acutely Hazardous Waste EPA Environmental Protection Agency DOT Department of Transportation RCRA TSD

Resource Conservation and Recovery k t Treatment Storage and Disposal Facility

Same as fully regulated generator

0 F'repare reduction plan by 9- 1-92

No requirement Annual reports require documentation

Employees must be familiar with No requirement properwaste handling and emergency P=d=

Preparedness / Prevention requirements Emergency procedures

0 No requirement

Exception "letter [file within 60 days)

wthin 45 days of calander quarter) Quarterfy Reports

Expanded Fourth Quarter &port Periodic Survey

Exception "letter" (3 yrs] Test resultsjsample analysis (3 yrs) Inspection log Land Msposal Restriction

Manifests (3 p)

Pay appropriate fees

No requirement

0 No requirement

No requirement

FORMFoli(MATwIwcbll. DEQ at (503) 229-5913 or toll fiee withlnoregon (800) 452-401 1

SUMMARY OF OREGON HAZARDOUS WASTE GENERATOR REQUIRElUENTS

Notification

AccumhtiW

satellite Accumulation

-w

S m a n ~ ~ t y c e n e r a t o r r r >2201bshit<2mbtsHw

Identify all HW on-site Determine pounds per month generated;

Fully--=- 22200bm222bSAHw

Identlfy all HW on-site Determine pounds per month generated; maximum amount accumulated at any me tlme

Notify DEQ to obtain a DEQ/EPA ID #

up t0 90 days In contalners which are

maximum amount accumulated at at any one tirne

Not@ DEQ to obtain a DEQ/EPA ID I

Same as fully regulated generators except: -up to 180 days, 270 days If'ISD is more than 200 miles away (not to exceed 13.200 ".of waste)

-compatible with HW stored closed unless adding/removfng waste -handled to avoid damage

-ignitable or reactive waste stored 5Oft from property line

-incompatibles stored separately Lfmore than 100 containers are used- follow EPA Containment Standards

Segregation

No more than 55 gallons of W Same as l l l y regulated generator OrlqUartAHW

RCRA hazardous waste labels .D<rrlabels

Same as fully regulated generator

storage area weekly Tanks daily Facility for potential HW spdls Emergency prevention/detection quipment

Follow DOT regs for packagbg. labeling marking and placarding Use HW d e s t (complete additional sections) Use transporters and TSD facilities with State/EPA ID#'$ Flle any necessary exception reports Ship or recycle wastes within 90 days Comply with Oregon Public Utility

Same as llly regulated generator

Same as fully regulated generator except. -Letter to EPA In-place of exception report -Ship or recycle wastes within 180 days

(270 days ifTSD is located more than ux) d e s away)

Commission's Transportation Regulations

Identirjr all HW on-site Determine pounds per month generata maximum amount accumulated atanyonethe

Norequirement

Can not accumulate more than 2.200 lbs. Hw or 2.2 lbs. of AHW

Not applicable

DOT labels (if necessaxy]

No inspections requid

No manifest required 0 Use regulated HW facility use licensed sw landfill with permission

..