REGULATORY
REVIEW
REDUCING GARAGE
WASTES
RELEVANT
RESOURCES
United States Solid Waste and
Environmental Protection Emergency
Agency Response
EPA530-K-99-004
June 1999
www.epa.gov/osw
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CONTENTS
Foreword 1
Frequently Asked Questions About RCRA 2
The Life Cycle of a Typical Vehicle Maintenance Waste 6
Requirements for Regulated Vehicle Maintenance Facilities 8
Reduce or Minimize the Hazardous Wastes You Generate 10
Other Environmental Laws Affecting the Vehicle Maintenance Industry 14
Contacts and Resources 16
FOR MORE INFORMATION CALL:
RCRA Hotline
U. S. Environmental Protection Agency
800 424-9346 or TDD 800 553-7672.
In the Washington, DC, area: 703 412-9810
or TDD 703 412-3323.
® Printed on paper that contains at least 30 percent postconsumer fiber.
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FOREWORD
Whether you are tuning an engine, replacing a battery,
changing the oil, or doing body work, your vehicle
maintenance operations probably generate hazardous
wastes. That means you must follow regulations issued by the U.S.
Environmental Protection Agency (EPA or the Agency) under a law
called the Resource Conservation and Recovery Act (RCRA). Under
RCRA, you are required to follow certain practices and procedures
associated with the safe management of hazardous waste. RCRA in
Focus provides an overview of the basic federal regulations covering
wastes that are likely to be hazardous in your business. It also provides
recycling and pollution prevention options to help businesses decrease
the amount of hazardous waste they produce.
VEHICLE MAINTENANCE
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FREQUENTLY ASKED QUESTIONS
ABOUT RCRA
STATE
REQUIREMENTS
Yau may be regulated
by both your state
hazardous •waste agency
and EPA. RCRA allows
states to receive legal per-
mission, known as autho-
rization, to implement the
RCRA hazardous waste
program.
You must always con-
tact your state authority
to determine •which state
requirements apply to
your business. To oper-
ate a hazardous •waste
program, a state's regula-
tions must be consistent
•with, and at least as
stringent as, the federal
program. Some states
adopt more stringent
requirements for facili-
ties handling hazardous
waste, •which are consid-
ered part of the autho-
rized program.
MORE
QUESTIONS?
Call the RCRA
Hotline at
800 424-9346 or TDD
800 533-7672 for
additional information
about RCRA rules and
regulations. In the
Washington, DC, area,
call 703 412-9810 or
TDD 703 412-3323.
What Is RCRA?
RCRA is a federal law that encourages environmentally sound methods for managing commer-
cial and industrial waste as •well as household and municipal waste. It regulates facilities that gener-
ate, transport, treat, store, or dispose of hazardous •waste. The vast majority of vehicle maintenance
facilities are considered hazardous waste generators, rather than treatment, storage, and disposal
facilities (TSDFs), •which are subject to more rigorous regulations.
The term "RCRA" is often used interchangeably to refer to the law, the regulations, and EPA
policy and guidance. The law describes the •waste management program mandated by Congress that
gave EPA authority to develop the RCRA program. EPA regulations carry out the Congressional
intent by providing explicit, legally enforceable requirements for waste management. EPAguidance
documents and policy directives clarify issues related to the implementation of the regulations.
All of the RCRA hazardous waste regulations can be found in the Code of Federal Regulations
(CFR), Title 40, Parts 260 to 279. The CFR can be accessed at or pur-
chased through the U.S. Government Printing Office (GPO).
Who Is Regulated?
Any vehicle maintenance facility that generates •waste is potentially subject to RCRA hazardous
waste requirements. You must conduct tests required by the regulations or use your knowledge of
and familiarity with the wastes you generate to determine •whether it is hazardous waste (as opposed
to other types of waste). You might be subject to substantial civil and criminal penalties if you fail to
properly or completely identify hazardous •waste generated at your business.
What Is Hazardous Waste?
To be considered hazardous waste, a material first must be classified as a solid waste. EPA defines
solid waste as garbage, refuse, sludge, or other discarded material (including solids, semisolids, liq-
uids, and contained gaseous materials). If your •waste is considered solid waste, you must then deter-
mine if it is hazardous •waste. Wastes are defined as hazardous by EPA if they are specifically named
on one of four lists of hazardous •wastes (listed wastes) or if they exhibit one of four characteristics
(characteristic wastes). Each type of RCRA hazardous waste is given a unique hazardous •waste code
using the letters D, F, K, P, or U and three digits (e.g., D001, F005, P039). See pages 10 to 13 for
additional information on vehicle maintenance waste codes.
Listed Wastes. Wastes are listed as hazardous because they are known to be harmful to human
health and the environment •when not managed properly, regardless of their concentrations. The
lists include the following three types of •waste:
• Non-Specific Source Wastes. These are material-specific •wastes, such as solvents, generated
by several different industries. Waste codes range from F001 to F039. Examples include methy-
lene chloride and trichloroethylene generated in the vehicle maintenance industry during car and
parts washing, degreasing, and paint removal.
• Specific Source Wastes. These are wastes from specifically identified industries. Waste codes range
from K001 to K161. Vehicle maintenance facilities typically do not generate specific source •wastes.
• Discarded Commercial Chemical Products. Off-specification products, container residuals,
spill residue runoff, or active ingredients that have spilled or are unused and that have been, or
are intended to be, discarded. Waste codes range from P001 to P205 and U001 to U411.
RCRA IN FOCUS
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Characteristic Wastes. Even if your •waste does not appear on one of the hazardous •waste lists, it
still might be regulated as hazardous •waste if it exhibits one or more of the following characteristics:
• Ignitability. Ignitable •wastes create fires under certain conditions or are spontaneously com-
bustible, and have a flash point less than 60 °C (140 °F). Examples include •waste oils from oil
replacement; spent solvents from paint removal, car •washing, and degreasing; and methanol used
for paint removal. The •waste code for these materials is D001.
• Corrosivity. Corrosive •wastes are acids or bases that are capable of corroding metal containers,
such as storage tanks, drums, and barrels. Battery acid is a good example. Phosphoric, hydrochlo-
ric, and hydrofluoric acids used in the vehicle maintenance industry for parts cleaning and
degreasing are also examples. The •waste code for these materials is D002.
• Reactivity. Reactive •wastes are unstable under "normal" conditions. They can cause explosions,
toxic fumes, gases, or vapors •when mixed with •water. Examples include lithium-sulfur batteries
and explosives. The •waste code for these materials is D003.
• Toxicity. Toxic •wastes are harmful or fatal •when ingested or absorbed. When toxic •wastes are
disposed of on land, contaminated liquid may drain (leach) from the •waste and pollute ground
•water. Toxicity is defined through a laboratory procedure called the Toxicity Characteristic
Leaching Procedure (TCLP). Certain •wastes used in the vehicle maintenance industry for rust-
proofing, painting, paint removal and parts •washing and degreasing may be considered toxic.
The •waste codes for these materials range from D004 to D043.
How Are Generators Regulated?
If your vehicle maintenance business generates hazardous •waste, you must manage it according
to regulations for your specific generator type. Hazardous •waste generators are divided into three
categories, according to how much they generate in a calendar month:
• Large Quantity Generators (LQGs). LQGs generate greater than or equal to 1,000 kg
(approximately 2,200 Ibs) of hazardous waste per month, or greater than 1 kg (approximately 2.2
Ibs) of acutely hazardous •waste per month.
• Small Quantity Generators (SQGs). SQGs generate more than 100 kg (approximately 220
Ibs) but less than 1,000 kg (2,200 Ibs) of hazardous waste per month.
• Conditionally-Exempt Small Quantity Generators (CESQGs). CESQGs generate less
than or equal to 100 kg (220 Ibs) of hazardous waste per month, and less than or equal to 1 kg
(2.2 Ibs) of acutely hazardous waste per month.
Some states do not recognize the CESQG class. Contact your state environmental agency to find
out if the CESQG status is recognized. To find your appropriate state contact, call the RCRA
Hotline at 800 424-9346.
Under the federal RCRA requirements, your generator status might change from one month to
the next as the quantity of waste you generate changes. You must comply with •whichever standard
is applicable for a given month. In many cases, small businesses that fall into different generator cat-
egories at different times choose to always satisfy the more stringent requirements (usually state
requirements) to simplify compliance. Generators must "count" the amount of waste generated
during a calendar month, •which involves adding up the total weight of all quantities of characteristic
and listed waste generated at a particular facility. Certain •wastes, such as those that are reclaimed or
recycled continuously on site, are not counted under the federal regulations.
AM I REGULATED BY
RCRA OR
SUPERFUND?
RCRA regulates the
treatment, storage, and
disposal of hazardous waste
being generated now and in
the future. Superfund •was
created to pay for the
identification, inspection,
investigation, ranking, and
cleanup of abandoned or
uncontrolled hazardous
•waste sites that people
responsible for contamina-
tion are unable or unwilling
to clean up. Call the RCRA
Hotline for more informa-
tion.
HOW ARE
UNDERGROUND
STORAGE TANKS
REGULATED?
If your vehicle mainte-
nance facility stores
petroleum on the premises
in underground storage
tanks (USTs), you are sub-
ject to the RCRA regula-
tions for USTs. Regulatory
requirements for USTs
include instituting measures
for corrosion protection,
preventing spills and over-
fills, and implementating
leak detection program that
provides monitoring for
leaks at least once every 30
days. Vehicle maintenance
facilities subject to the UST
regulations should contact
the Hotline or their state
environmental agency for
further guidance on UST
requirements.
VEHICLE MAINTENANCE
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REPORTING
REQUIREMENTS
FOR GASOLINE
AND DIESEL FUEL
Under the Emergency
Planning and Com-
munity Right-to-Know
Act (EPCRA), retail gas
stations are required to
report the quantities of
gasoline and diesel fuel
that are stored in under-
ground storage tanks
•when they reach a certain
level.
continued
Do Exclusions Exist?
The RCRA regulations contain many exclusions for •wastes and •waste management practices that
are not considered to be hazardous. Several exclusions and exemptions pertain specifically to the
vehicle maintenance industry. Some states, however, do not recognize the federal exclusions.
As part of your solvent recovery operations, you probably generate wastewaters containing trace
amounts of solvents. These wastewaters are typically discharged to a publicly owned treatment
works (POTWs) and, therefore, are not considered hazardous waste. The following table provides a
description of the exclusions and exemptions that are potentially applicable to the vehicle mainte-
nance industry. Check •with your implementing agency (state or EPA Region) for information about
additional requirements or special conditions to the exclusions and exemptions.
Exclusions and Exemptions Description
Domestic Sewage
Exclusion
Wastewater Treatment Unit
Exemption
Mixtures of domestic sewage and other wastes that pass
through a sewer system to a POTW for treatment are
excluded from the definition of solid waste. Generators are
encouraged to contact their local POTW to find out •what
regulations may apply.
A tank system used to store or treat wastewater as part of an
onsite wastewater treatment facility with a National Pollutant
Discharge Elimination System (NPDES) permit or subject
to pretreatment standards is exempt from the RCRA regula-
tions.
How Is Used Oil Handled?
RCRA contains special provisions for the management of used oil destined for recycling. These
management standards apply to oil refined from crude oil or any synthetic oil that has become con-
taminated through use by chemical or physical impurities. Used oil that •will be recycled is subject
to special management standards, rather than the hazardous waste standards, unless it is treated as a
waste (i.e., you decide to send the used oil for treatment and disposal rather than recycling).
Vehicle maintenance facilities are likely to be regulated only as used oil generators. Vehicle mainte-
nance facilities might generate used oil from changing oil for their customers, from onsite equip-
ment, or from "do-it-yourselfers" •who change their own oil.
USED OIL GENERATORS
A used oil generator is any person, by site, •who first causes used oil to become subject to
regulation.
Used oil standards require generators to comply with basic storage requirements. Used oil can
only be stored in containers and tanks that are in good condition (free of any visible leaks, structural
damage, or deterioration). Containers, aboveground tanks, and fill pipes used to transfer used oil
into underground storage tanks need to be clearly marked with the words "Used Oil" to prevent
mixing of used oil •with hazardous waste or other materials. In the event of a release from one of
RCRA IN FOCUS
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these units to the environment, the generator must comply with the response measures, •which
include stopping and containing the release, properly managing any used oil or contaminated mate-
rials, and repairing or replacing the leaking container or tank. Generators of used oil have no time
or quantity limitations on storing used oil because it is a marketable commodity. Generators can
burn their own used oil and used oil generated by household "do-it-yourselfers" in onsite used-oil
fired space heaters without complying with regulations for used oil burners.
People who change their own oil at home, and generators who mix diesel fuel and used oil to be
used in their own vehicles as a fuel, are not subject to RCRA used oil regulations. Mixers may have
to comply with Clean Air Act requirements.
OFFSITE SHIPMENTS OF USED OIL
Generators are allowed to transport their own used oil as long as: (1) generators bring the used
oil to either an approved collection center or self-owned or -operated collection point; (2) the used
oil is delivered in shipments of 55 gallons or less; and (3) the used oil is transported in a vehicle
owned by the generator or an employee of the generator. If not self-transporting, generators must
ensure that their used oil is transported by a transporter who has obtained an EPA identification
number.
USED OIL FUEL MARKETERS
Generators may also be considered used oil fuel marketers if they either (1) direct a shipment of
off-specification used oil from that facility to a used oil burner or (2) first claim that the used oil
going to be burned for energy recovery meets the specification requirements. Most generators do
not act as used oil fuel marketers, so they are not required to determine whether their used oil
meets the fuel specification.
For more information on the federal used oil requirements, call the RCRA Hotline. Be aware
that some states have different requirements than the federal government. Vehicle maintenance
facility owners should check with their state environmental agency for more information on the
used oil management standards in their state.
REPORTING
REQUIREMENTS
continued
The public and emer-
gency personnel are gen-
erally aware that gas
stations store significant
amounts of gasoline and
diesel fuel and that there
are hazards associated
with these materials. The
location of these stations
is generally common
knowledge and the pub-
lic is usually welcome on
site. In addition, gasoline
and diesel fuel stored in
underground storage
tanks are subject to
RCRA handling stan-
dards and reporting
requirements. Because
the goals of EPCRA (see
page 15 for more infor-
mation) are satisfied by
these conditions, EPA
believes that these sub-
stances do not need to be
routinely reported under
EPCRA when amounts
do not exceed specified
limits and are stored in
underground storage
tanks at retail gas stations.
VEHICLE MAINTENANCE
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THE LIFE CYCLE
OF A TYPICAL
VEHICLE
MAINTENANCE
WASTE
Yu've just finished some radiator repair •work and
arts •washing at your business. You now have haz-
rdous •wastes to manage. You are a small business
that performs this type of service on a regular basis. You
know it is time to learn about the regulations and comply
•with them.
This example details a typical waste life cycle at a vehicle
maintenance facility. The life cycle presents the hazardous
waste management requirements for an SQG from waste
generation to shipment off site. Other waste life cycles
could be different depending on the waste, the type of
waste management units used, and the facility generator
status.
SEND WASTE OFF SITE
FOR TREATMENT,
STORAGE, OR
DISPOSAL
Using a licensed hazardous
•waste transporter, ship the
radiator repair and parts
•washing waste to a RCRA
hazardous waste TSDF
accompanied by the appro-
priate manifest and land
disposal restrictions notifi-
cation and certification.
Optional destinations for
solvents include a haz-
ardous waste incinerator
that •will landfill the incin-
erator ash, a hazardous
•waste fuel blender •who •will
blend the solvents with
other •wastes and then burn
them for energy recovery in
a boiler or industrial fur-
nace, or a facility that •will
recycle the solvents.
IDENTIFY WASTE
By running tests or using
your knowledge of waste,
identify •whether the waste is
hazardous. Based on these
analyses, you determine that
your radiator repair and parts
washing •wastes include waste
codes D001, D002, D008,
D018, F001, and F002. Keep
all records of test results,
waste analyses, and other
determinations made in the
hazardous waste identification
process for 3 years.
PREPARE APPROPRIATE
NOTIFICATION AND
CERTIFICATION
Ensure that all hazardous
waste sent off site for treat-
ment, storage, or disposal is
accompanied by appropriate
land disposal restrictions
(LDRs) program notifications
and certifications. (See page 9
for a description of LDRs.)
COUNT WASTE
As a second step, determine
how much hazardous waste
you have produced in a cal-
endar month. You do not
need to count wastes dis-
charged in compliance with
the Clean Water Act directly
to a public sewer leading to a
POTW or waste recycled
only in an onsite process
according to standards.
PREPARE HAZARDOUS
WASTE MANIFEST
Send a manifest along with
all hazardous waste sent off
site to a TSDF and keep a
copy on site for 3 years. The
manifest contains a certifica-
tion stating that your facility
has a program in place to
reduce the volume and toxici-
ty of •waste generated to the
degree economically practica-
ble.
6
RCRA IN FOCUS
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DETERMINE
GENERATOR STATUS
Based on •waste counting,
determine your generator
status. In this case, your
vehicle maintenance
facility produces between
100 and 1,000 kg (220 to
2,200 Ibs) each month,
making it an SQG. If the
amount of •waste you
generate fluctuates from
month to month, you
may wish to satisfy the
more stringent require-
ments each month to
simplify compliance.
FOLLOW U.S.
DEPARTMENT OF
TRANSPORTATION (DOT)
PACKAGING STANDARDS
Before shipping •waste off site
for treatment, storage or dis-
posal, you should package,
label, and mark •waste con-
tainers in accordance with all
applicable DOT require-
ments. Call the DOT
Hotline at 800 467-4922 for
information.
OBTAIN EPA
IDENTIFICATION
NUMBER
To identify your business as a
hazardous waste generator,
obtain an EPA identification
number by submitting Form
8700-12 (Notification of
Regulated Waste Activity),
•which can be obtained from
your state hazardous waste
agency. Remember, your
state requirements might be
different.
CONTRACT WITH
HAZARDOUS WASTE
TRANSPORTER
To send •waste off site to a
TSDF, contract •with a regis-
tered hazardous waste trans-
porter. To locate a reliable
transporter, contact a col-
league to obtain a reference.
PLACE WASTE IN
ACCUMULATION UNIT
When the •waste is generated,
place it in the appropriate
accumulation unit. Mark
accumulation tanks and con-
tainers with the date the
waste was placed in the unit
as well as the words
"Hazardous Waste." Ensure
that containers are not rusty
or leaking, are stored in areas
•with adequate ventilation
and drainage, and are kept
closed except to add or
remove waste. You may store
your radiator repair and parts
washing •wastes in the same
container provided they are
compatible.
IMPLEMENT
PERSONNEL TRAINING
Be sure your personnel are
thoroughly familiar with haz-
ardous waste handling and
emergency response proce-
dures.
IMPLEMENT EMERGENCY
PREPAREDNESS AND PRE-
VENTION REQUIREMENTS
Check to be sure that emergen-
cy preparedness and prevention
requirements are met. These
include identifying an emergen-
cy response coordinator and
notifying local emergency
response authorities. Post emer-
gency response information near
the telephone.
IMPLEMENT
CONTINGENCY
PROCEDURES
Ensure that a contingency
plan is prepared in accordance
•with standards to minimize
hazards from fires, explo-
sions, and unplanned releases.
Keep a copy of the contingen-
cy plan on site.
VEHICLE MAINTENANCE
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REQUIREMENTS FOR REGULATED VEHICLE MAINTENANCE FACILITIES
The following table presents an overview of the federal RCRA regulatory requirements for vehicle maintenance facilities that are either LQGs, SQGs, or CESQGs.
As noted, your state might have different or more stringent requirements.
RCRA REGULATORY REQUIREMENTS
REGULATORY
REQUIREMENT
EPA Identification
Number
Hazardous Waste
Identification
Used Oil Standards
Waste Counting
Accumulation Area
LQGs SQGs CESQGs
Other Accumulation
Areas (Time and
Quantity Limits)
Accumulation Unit
Requirements
Air Emissions
Preparedness and
Prevention
IMPLEMENTATION EXPLANATION
Obtain an EPA identification number for each facility within your company. EPA and states use this 12-character identification
number to track hazardous waste activities.
Obtain an EPA identification number by submitting form 8700-12 (Notification of Regulated Waste Activity), which is provided
by your state hazardous waste agency. This is a one-time notification. Contact your state regarding the need for renotification if
circumstances at your facility change.
Identify whether you generate hazardous waste to determine if you are subject to the RCRA hazardous waste regulations. Test
procedures are described in "Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods, SW-846," or tests can
be performed by a local laboratory.
If you generate used oil, you are subject to a separate set of management standards from the hazardous waste management standards,
if the used oil will be recycled. If used oil is to be treated and disposed of, perform the hazardous waste identification step listed above.
Determine how much hazardous waste you generate to determine your generator status.
You can accumulate waste in a "satellite accumulation area" with minimal regulatory burden. This area must be at or near the point of
generation and under the control of the operator of the process generating the waste.
There is no time limit on accumulation in the satellite accumulation area for waste under 55 gallons.
There is a 55-gallon accumulation limit in the satellite accumulation area. Excess waste beyond the 55-gallon limit must be
moved from the satellite accumulation area within 3 days.
You must accumulate the waste in containers.
Waste containers must be marked with the words "Hazardous Waste" or other words that identify their contents.
This waste is exempt from other accumulation provisions while in the satellite accumulation area.
If waste accumulation does not meet the requirements for satellite accumulation, it is subject to more stringent requirements.
LQGs can accumulate waste on site for up to 90 days without a permit. SQGs can accumulate waste for 180 days, or 270 days
if the SQG must transport the waste more than 200 miles to a destination facility.
Begin counting accumulation time when waste is first generated or removed from satellite accumulation area.
Waste must be put in an exempt unit, recycled, or sent off site within the proper time period stated above.
If an LQG or SQG accumulates wastes beyond the allotted time period, the facility is fully subject to the requirements of a hazardous
waste storage facility unless granted an exemption. SQGs cannot accumulate more than 6,000 kg of hazardous waste at any time.
CESQGs cannot accumulate more than 1,000 kg of hazardous waste, more than 1 kg of acutely hazardous waste, or 100 kg of
spill residue from acutely hazardous waste at any time.
Accumulate waste only in units that are in good condition, remain closed except when adding or removing, are inspected at least
weekly, are compatible with the types of waste, and meet special standards for ignitable waste and incompatible reactive waste.
LQGs can use accumulation tanks and containers that have been assessed for integrity, have a secondary containment sys-
tem, and are inspected each operating day. (SQGs can use certain accumulation tanks and containers).
LQGs can use containment buildings.
For all units, the date that the accumulation period begins must be clearly marked and visible on each container. All containers
and tanks must be clearly marked or labeled with the words "Hazardous Waste," and accumulation units must be shut down and
closed permanently in accordance with standards at the end of the unit life.
LQGs and SQGs can treat their waste without a RCRA storage permit in accumulation units that meet standards.
LQGs must comply with organic air emissions requirements.
LQGs and SQGs must comply with preparedness and prevention requirements, including the following:
An adequate internal alarm or communications system.
A device capable of summoning emergency personnel.
Prtrtahlo firo r^rtntrrtl oni linmont
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Contingency Plan
Personnel Training
DOT Packaging
Offsite Management
of Waste
Onsite Management
of Waste
Manifest
Land Disposal
Restrictions
Notification
Hazardous Waste
Minimization
Biennial Report
Recordkeeping
Adequate water pressure to operate fire control systems.
Adequate testing and maintenance of all emergency systems.
Access to communication or alarm systems during waste handling activities.
Adequate aisle space for emergency response.
An arrangement with local emergency response authorities.
LQG facilities must prepare a facility contingency plan in accordance with regulations.
The contingency plan must be designed to minimize hazards from fires, explosions, or any unplanned release of hazardous
waste or constituents.
A copy of the contingency plan must be kept on site and an additional copy must be submitted to all local emergency services providers.
LQGs and SQGs must have an emergency coordinator on site or on call at all times to respond to emergencies.
Emergency response information must be posted next to the telephone.
In the event of a fire, explosion, or release that could threaten human health outside the facility, or when a spill has reached
surface water, the emergency coordinator must notify the National Response Center at 800 424-8802.
LQGs must have a personnel training program in accordance with regulatory standards.
Training must instruct facility personnel about hazardous waste management procedures and emergency response.
Training must be completed within 6 months from the applicability of requirements.
The facility must undertake an annual review of initial training.
SQGs must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant
to their responsibilities.
Before being transported, waste must be packaged, labeled, and marked in accordance with applicable DOT requirements.
Call the DOT hazardous materials information line at 202 366-4488 for information.
Hazardous waste sent off site for handling may only be sent to a hazardous waste TSDF or recycling facility unless otherwise exempt
CESQGs: See onsite management of waste below.
CESQGs may either treat waste on site, if the generator qualifies as one of the following types of facilities, or ensure delivery of
waste to one of the following types of facilities: permitted RCRATSDF; interim status TSDF; state-authorized to handle haz-
ardous waste; permitted, licensed, or registered by state to handle municipal solid waste according to standards;permitted,
licensed, or registered by state to handle non-municipal waste; if managed after January 12, 1998, facility is permitted,
licensed, or registered by state to handle non-hazardous waste in accordance with standards; facility beneficially uses or
reuses, or legitimately recycles or reclaims its waste; facility treats its waste prior to beneficial use, reuse, or legitimate recy-
cling or reclamation; or a universal waste handler in accordance with standards.
Hazardous waste sent off site must be accompanied by a manifest, a multipage form that documents the waste's progress
through treatment, storage, and disposal. It can be obtained from your state agency.
The manifest must have enough copies to provide the generator, each transporter, and the destination facility with one copy for
their records and a second copy to be returned to the generator after completion by the destination facility operator.
SQGs that have a contractual agreement with a waste reclaimer that specifies the types and frequencies of shipments do not
need to manifest the wastes if they retain a copy of the agreement in their files.
Waste must meet certain treatment standards under the LDR program. Waste must be treated to reduce the hazardous con-
stituents to levels set by EPA or the waste must be treated using a specified technology. All waste sent off site for
treatment, storage, and disposal must be accompanied by appropriate LDR program notifications and certifications. There are
no required forms, but these papers must indicate whether or not wastes meet treatment standards, or whether the waste is
excluded from the definition of hazardous or solid waste or is otherwise exempt.
To encourage generators to produce less hazardous waste, LQGs are required to have a program in place to reduce the vol-
ume and toxicity of waste generated to the degree economically practicable, and must select a currently available treatment,
storage, or disposal method that minimizes present and future threats.
LQGs and SQGs must sign a certification of hazardous waste minimization on the manifest.
SQGs must make a good faith effort to minimize waste generation and to select the best available waste management method
that they can afford.
LQGs must submit biennial reports of waste generation and management activity by March 1 of every even-numbered year.
EPA, other agencies, and the public use this information to track trends in hazardous waste management.
LQGs must maintain personnel training records until the facility closes.
LQGs must keep copies of each biennial report for 3 years.
LQGs and SQGs must keep a copy of each manifest for 3 years.
LQGs and SQGs must keep records of test results, waste analyses, and other hazardous waste determinations for 3 years.
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REDUCE OR MINIMIZE THE
HAZARDOUS WASTES You GENERATE
The following
examples show
hazardous wastes typi-
cally generated by the
vehicle maintenance
industry and provide
suggestions for how to
recycle, treat, or
dispose of them
according to federal
regulations.
PROCESS
Chemicals Used
and/or Generated
Possible RCRA
Waste Codes
Potential Pollution
Prevention Methods
PROCESS
Chemicals Used
and/or Generated
Possible RCRA
Waste Codes
Potential Recycling
Treatment and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Chemicals Used
and/or Generated
Possible RCRA
Waste Codes
-•—.^^ ecycling and pollution prevention measures can significantly reduce your regulatory
• burden and may save your facility considerable money. This section presents informa-
^F tion on hazardous wastes typically generated by various vehicle maintenance activities
and provides suggestions for how to recycle them or implement pollution prevention
.^L. ^^measures. This list might not cover all chemicals used or wastes produced by the vehi-
cle maintenance industry. Consult the hazardous waste lists and characteristics to determine if you
generate other hazardous wastes.
Only the federal hazardous waste codes are provided here. Your state might have different codes
for some waste streams. You should check with your state hazardous waste authority for additional
waste codes and requirements.
Air Conditioner Maintenance
Dichlorodifluoromethane (CFC-12).
U075 (if unused).
Reclaim spent CFCs.
Battery Replacement
Lead dross, zinc, copper, and spent sulfuric acid
D002 and D008.
Arrange for spent battery collection and recycling.
Ship waste using a registered transporter to a hazardous waste TSDF for treatment and
disposal.
Install longer life batteries.
D006, D007, and D008
10
RCRA IN FOCUS
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Potential Recycling,
Treatment, and
Disposal Methods
PROCESS
Chemicals Used
and/or Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Send parts to be rebuilt or recycled as scrap metal.
Sweep or vacuum dust for proper disposal.
Methylene chloride, trichloroethylene, aromatic, and chlorinated hydrocarbons.
D001, F002, D040, U080, and U228.
Filter and reuse wastewaters.
Collect wastewaters and ship off site using a registered transporter to a hazardous
waste TSDF for treatment and disposal.
Pretreat (if necessary) and discharge wastewaters following Clean Air Act requirements.
se a grit separator before discharging wastewaters.
Oil and Fluid Replacement
Used oil, oil filters, and fuel filters contaminated with cadmium, chromium, lead, benzopy-
rene; ethylene glycol (antifreeze) contaminated with lead; petroleum distillates; and chlorinated
hydrocarbons.
D001, D006, D007, and D008.
Store fluids separately to make it easier to recycle.
Recycle used oil and antifreeze.
Recycle drained oil filters and fuel filters as scrap metal.
Ship hazardous waste using a registered transporter to a hazardous waste TSDF for
treatment and disposal.
Use drip pans to prevent contamination of the floor and subsequent floor-cleaning solutions.
Use a long-lasting, high-performance oil that needs less frequent changing.
Use fluids (e.g., brake, transmission, etc.) that do not contain chlorinated hydrocarbons.
Rustproofing, Painting, and Paint Removal
Spent halogenated and nonhalogenated solvents such as acetone, toluene, benzene,
xylene, methanol, methylene chloride, isopropyl alcohol; waste paint thinner and paint; paint
filters; and spent rags and wipes.
D001, D035, F002, and F003.
Keep waste paint and paint sludge separate from waste thinner.
Collect rustproofing drippage and dispose of properly.
Collect hazardous waste and ship it using a registered transporter to a hazardous waste
TSDF for treatment and disposal.
Reclaim solvents and paint thinners on site (small stills are available in a variety of vol-
umes), or send for recycling.
Give leftover paint to the customer.
Use recyclable paint filters.
VEHICLE MAINTENANCE
11
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Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
Use mechanical paint stripping methods such as plastic blast media instead of solvents.
Use high transfer efficiency equipment (e.g., equipment with a low over-spray) to reduce
air emissions.
Replace chlorinated solvents with nonchlorinated products.
Use water-based paint when possible (the number of less hazardous paint choices is increasing).
Parts Washing and Degreasing
Benzene, phosphoric acid, hydrochloric acid, hydrofluoric acid, sodium hydroxide, heavy
metals, petroleum distillates, and spent rags and wipes.
D001, D002, D018, D008, and FOOL
Ship hazardous waste using a registered transporter to a hazardous waste TSDF for
treatment and disposal.
Reclaim used solvents on site, or contract with a recycling facility.
Reuse solvents; for example, rinse with used solvent followed by a small amount of
fresh solvent.
Don't over-clean parts and use as little solvent as necessary.
Keep solvent containers sealed when possible to prevent volatilization and reduce emissions.
Use a self-contained recirculating solvent sink. Contract with a solvent service company
to take sludges and used solvent and maintain the sink.
Substitute aqueous or alkaline cleaners instead of hazardous solvents.
Use steam cleaners, heat baths, or high-pressure washing units instead of units using solvents.
These methods can also be used to preclean, lessening solvent use and contamination.
Preclean parts with dry rags or brushes to limit use and contamination of solvents, then
reuse rags and solvents.
Install a drip rack over cleaning tanks to confine drips to the cleaning process.
Allow more drainage time.
Skim off petroleum contaminants and reuse rinse waters.
Various solvents and petroleum products potentially outdated or off-specification.
D001 and FOOL
Ship off-specification and outdated products using a registered transporter to a haz-
ardous waste TSDF for treatment and disposal.
Reclaim/reuse off specification products.
Use a first in, first out policy in storage areas to prevent materials from becoming
outdated.
Computerize inventory control.
Routinely inspect storage areas.
Comply with UST design standards and monitoring to prevent leaks.
12
RCRA IN FOCUS
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PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
Zinc chloride (coolant), chlorinated solvents, and lead solder.
D001, D002, D008, and F002.
Collect and reclaim solvents. Store them separately, do not contaminate.
Ship hazardous waste using a registered transporter to a hazardous waste TSDF for
treatment and disposal.
Adjust process to reduce solvent use (e.g., use compressed air to blow out residual
alkaline solution after removing from boil-out tank, then collect and return to tank).
Employ lead-free or reduced lead solder.
Use a recyclable type of radiator fluid and collect flushing liquid for reuse.
Ship scrap tires using a registered hauler to a scrap tire processor, such as a licensed
energy recovery facility, or a reuse, retreading or recycling facility.
Ship scrap tires using an appropriate hauler to a permitted, nonhazardous waste landfill.
Be sure the landfill accepts tires.
Shop Cleanup
Used oil and drain or sump sludges contaminated with metals, petroleum, solvents, and
spent rags and wipes.
Properly store wastes in hazardous waste accumulation tanks or containers.
Ship hazardous waste using a registered transporter to a hazardous waste TSDF for
treatment and disposal.
Use good housekeeping practices to prevent contaminants from reaching the floor
(drip pans, worker training and incentives, proper containers for wastes).
Use less hazardous cleaners (biodegradable when possible).
Do not use solvents for cleaning floors.
Avoid disposing of partially used rags or absorbents. Use them to their limit.
VEHICLE MAINTENANCE
13
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CFR GUIDE TO
HAZARDOUS
WASTE
REGULATIONS
To review the
RCRA regulations
referred to in this docu-
ment, consult the fol-
lowing citations in Title
40 of the Code of Federal
Regulations:
Part 260—Hazardous
waste management sys-
tem: general.
Part 261—Identification
and listing of hazardous
waste.
Part 262—Standards
applicable to generators
of hazardous waste.
Part 263—Standards
applicable to transporters
of hazardous waste.
Part 264—Standards for
owners and operators of
hazardous waste and
specific types of haz-
ardous waste manage-
ment facilities.
Part 265—Interim status
standards for owners and
operators of hazardous
waste TSDFs.
Part 266—Standards for
the management of spe-
cific hazardous wastes
and specific types of
hazardous waste man-
agement facilities.
continued
OTHER ENVIRONMENTAL LAWS
AFFECTING THE VEHICLE
MAINTENANCE INDUSTRY
THE CLEAN WATER ACT
The Water Pollution Control Act, commonly known as the Clean Water Act (CWA), is the fed-
eral program designed to restore and maintain the integrity of the nation's surface •waters. CWA
controls direct discharges to surface •waters (e.g., through a pipe) from industrial processes or
stormwater systems associated with an industrial activity. It also regulates indirect discharges, or
discharges to publicly owned treatment works (POTWs) through a public sewer system, by
requiring industrial facilities to pretreat their waste before discharging to a public sewer. Industrial
pollutants from the vehicle maintenance industry that the CWA may regulate include toluene,
trichloroethylene, and metals such as lead and cadmium.
CWA Resources:
• 40 CFR Parts 100 to 129 and 400 to 503
• EPA Office of Water home page:
• EPA Office of Water: 202 260-5700
• Your state water authority, regional EPA office, and your local POTW
Oil Pollution Prevention Under the CWA
The Oil Pollution Prevention regulations were promulgated under the authority of the CWA.
These regulations establish requirements for facilities to prevent oil spills from reaching the navigable
waters of the United States or adjoining shorelines. The regulations apply to non-transportation-relat-
ed facilities with a specific aboveground or underground oil storage capacity that, because of their loca-
tion, can reasonably be expected to discharge oil into the navigable waters of the United States.
Vehicle maintenance facilities may be subject to spill prevention control countermeasures
(SPCC) under the CWA. A facility is subject to SPCC if it has 1,320 gallons or more of above-
ground storage capacity (or 660 gallons or greater oil storage capacity in a single container). Vehicle
maintenance facilities subject to SPCC must develop an SPCC Plan, •which includes provisions
for appropriate containment or diversionary structures to prevents spills of oil from reaching
navigable waters.
Oil Pollution Prevention Regulation Resources:
• 40 CFR Part 112
• Internet access:
THE CLEAN AIR ACT
The Clean Air Act (CAA) regulates air pollution. It includes national emission standards for new
stationary sources within particular industrial categories. It also includes national emission standards
for hazardous air pollutants, •which are designed to control the emissions of particular hazardous air
pollutants (HAPs). Vehicle maintenance facilities might have to comply with NESHAP regulations
if they use halogenated solvent cleaning machines. The CAA also seeks to prevent the accidental
release of certain hazardous chemicals and to minimize the consequences of such releases.
CAA Resources:
• 40 CFR Parts 50 to 99
• Control Technology Center, Office of Air Quality, Planning and Standards, EPA, general infor-
mation: 919 541-0800, publications: 919 541-2777
• Internet access:
COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND
LIABILITY ACT (CERCLA OR SUPERFUND)
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
of 1980, commonly known as Superfund, authorizes EPA to respond to releases, or threatened
14
RCRA IN FOCUS
-------
releases, of hazardous substances that might endanger public health, •welfare, or the environment, that
might come from any source. Superfund also grants EPA the authority to force parties responsible for envi-
ronmental contamination to clean it up or to reimburse response costs incurred by EPA If vehicle mainte-
nance facility operators or their landlords, for instance, are responsible for ethylene glycol contamination by
having ethylene- glycol-containing wastewater leak through sewer pipes, they may be held liable. The person
in charge at your business must report to the National Response Center (phone: 800 424-8802) any
release of a hazardous substance that exceeds a designated "reportable quantity" for that substance
within a 24-hour period.
Superfund Resources:
• Internet access:
THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT
The Superfund Amendments and Reauthorization Act (SARA) of 1986 created the Emergency
Planning and Community Right-to-Know Act (EPCRA). This law was designed to improve com-
munity access to information about potential chemical hazards and to facilitate the development of
chemical emergency response plans by state and local governments. The EPCRA regulations estab-
lish several types of reporting obligations for facilities that store or manage specified chemicals over
certain quantities. A release of methylene chloride into the environment from a vehicle maintenance
facility exceeding 1,000 Ibs within a 24-hour period would require an emergency release notifica-
tion, for example. Many of the chemicals used by vehicle maintenance facilities, such as ethylene
glycol, toluene, and trichloroethylene, may be considered hazardous chemicals by the Occupational
Safety and Health Administration as well. These are subject to additional requirements under
EPCRA.
EPCRA Resources:
• 40 CFR Parts 350 to 372
• The State Emergency Response Commission (contact available from RCRA Hotline)
• Internet access: and
SAFE DRINKING WATER ACT
The Safe Drinking Water Act (SDWA) mandates that EPA establish regulations to protect human
health from contaminants present in drinking water. Under the authority of the SDWA, EPA developed
national drinking water standards and created a joint federal-state system to ensure compliance with
these standards. EPA also regulates underground injection of liquid wastes under the SDWA to pro-
tect underground sources of drinking water.
SDWA Resources:
• 40 CFR Parts 141 to 148
• SDWA Hotline: 800 426-4791
• Internet access:
TOXIC SUBSTANCES CONTROL ACT
The Toxic Substances Control Act (TSCA) allows EPA to collect data on chemicals to evaluate,
assess, mitigate, and control risks that might be posed by their manufacture, processing, and use.
The vehicle maintenance industry is required to report information as necessary to allow EPA to
develop and maintain this inventory.
TSCA Resources:
• 40 CFR Parts 702 to 799
• TSCA Hotline: 202 554-1404
• Internet access:
CFR GUIDE
continued
Part 268—Land disposal
restrictions.
Part 270—EPA adminis-
tered permit programs:
the Hazardous Waste
Permit Program.
Part 271—Requirements
for authorization of state
hazardous waste
programs.
Part 272—Approved
state hazardous waste
management programs.
Part 273—Standards for
universal waste manage-
ment.
Part 279—Standards for
the management of used
oil.
See the regulations at
.
FOR MORE
INFORMATION
For additional infor-
mation on any of
these laws, contact the
RCRA Hotline at
800 424-9346 or
703 412-9810 in the
Washington, DC, area.
TDD (hearing
impaired): 800 553-7672
or 703 412-3323 in the
Washington, DC, area.
VEHICLE MAINTENANCE
15
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CONTACTS AND RESOURCES
HOTLINES AND
INFORMATION CENTERS
RCRA Hotline
U.S. Environmental Protection Agency
Phone: 800 424-9346 or
TDD 800 553-7672.
In the Washington, DC, area: 703 412-
9810, or TDD 703 412-3323.
Home page:
Answers questions on matters related to
RCRA solid waste, hazardous waste, and
underground storage tanks, EPCRA, and
CERCLA.
RCRA Information Center
U.S. Environmental Protection Agency
RCRA Information Center (5305W)
401 M Street, SW.
Washington, DC 20460
Phone: 703 603-9230
Fax: 703 603-9234
E-mail: rcra-docket@epa.gov
Holds and provides public access to all
regulatory materials on RCRA and dis-
tributes technical and nontechnical infor-
mation on RCRA issues.
Small Business Ombudsman
Clearinghouse/Hotline
U.S. Environmental Protection Agency
Small Business Ombudsman (2131C)
401 M Street, SW.
Washington, DC 20460
Phone: 800 368-5888
Fax: 202 401-2302
Home page:
Helps private citizens, small businesses,
and smaller communities with questions
on all program aspects within EPA.
EPA Headquarters Library
U.S. Environmental Protection Agency
Headquarters Library
401 M Street, SW, Room 2904
Washington, DC 20460
Phone: 202 260-5921 or 5922
Fax: 202 260-6257
E-mail: library-HQ@epa.gov
Home page:
Maintains environmental reference mate-
rials for EPA staff and the general public,
including books, journals, abstracts,
newsletters, and audiovisual materials
generated by government agencies and the
private sector. Also provides access to
online computer service bulletin boards
and CD-ROM systems.
Pollution Prevention Information
Clearinghouse (PPIC)
U. S. Environmental Protection Agency
Pollution Prevention Clearinghouse
(PPIC)
401 M Street (7409)
Washington, DC 20460
Phone: 202 260-1023
Fax: 202 260-4659
E-mail: ppic@epa.gov
U.S. Department of
Transportation
Hazardous Materials Information Center
Phone: 800 467-4922
Provides information about DOT's
hazardous materials regulations.
U.S. Government Printing
Office
Superintendent of Documents
RO. Box 371954
Pittsburgh, PA 15250-7954
Phone: 202 512-1800
Fax: 202 512-2250
Home page:
Prints and distributes the Code of Federal
Regulations. Title 40, Parts 260 to 299, con-
tains most of the RCRA requirements.
National Response Center
(NRC)
Phone: 800 424-8802
In the event of a fire, explosion, or other
release of hazardous waste that could
threaten human health outside the facility,
call the NRC to report the emergency.
The NRC will evaluate the situation and
help you make appropriate emergency
decisions.
ADDITIONAL INTERNET
ADDRESSES
EPA Home Page
< www.epa.gov>
EPA RCRA Hazardous Waste
Resources
Code of Federal Regulations
Envirosense
(contains technical, policy, and general
information on pollution prevention top-
ics)
Office of Enforcement and
Compliance Assurance
< es .epa.gov/oeca/mfcac.html >
(provides easy to understand compliance
information targeted to specific industry
sectors)
RCRA Online
(searchable database with interpretive
memos and other information written by
EPA to clarify regulations)
Coordinating Committee for
Automotive Repair
(contains
links to more than 25 automotive industry
Internet sites)
-------
OTHER INDUSTRY
CONTACTS
Coordinating Committee for Automotive
Repair
11301 Nail Avenue; Suite 203
Leawood, KS 66211
Phone: 1 888 CRN-LINK (476-5465)
E-mail: ccarinfo@unicom.net
(CCAR is a coalition of the automotive
repair industry representing more than 25
affiliate organizations.)
OTHER RESOURCES
Vehick Maintenance Industry Overview
(EPA530-SW-90-027a) explains some of
the areas of vehicle maintenance that
might generate hazardous waste and lists
ways to minimize the generation of haz-
ardous wastes. This document can be
ordered from the National Center for
Environmental Publications and
Information: 800 490-9198.
Call the RCRA Hotline (800 424-
9346) to order any of the following docu-
ments:
Understanding the Hazardous Waste Ruks:
A Handbook for Small Businesses, 1996
Update (EPA530- K-95-001) provides an
overview to help small business owners
and operators understand how best to
comply with federal hazardous waste
management regulations. This booklet
defines the three categories of hazardous
waste generators and assists small busi-
nesses in determining if federal regula-
tions apply. This document also explains
how to obtain an EPA identification
number, manage waste on site and ship
waste off site.
RCRA: Reducing Risk From Waste
(EPA530-K-97-004) provides a brief
overview of the national RCRA program
and the role of the states. This booklet
defines RCRA hazardous waste and how
the RCRA regulations apply to generators,
transporters, and TSDFs. It focuses on
hazardous waste by also addresses munici-
pal and industrial nonhazardous solid
waste. It provides examples of waste and
waste treatment and disposal methods,
waste minimization tips, links to other
environmental laws related to hazardous
substances, a glossary of terms, and a
guide to the RCRA
sections of the Code of Federal Regulations.
Call the EPA Office of Enforcement
and Compliance (202 564-7032, Everett
Bishop) to order the following:
Consolidated Screening Checklist for
Automotive Repair Facilities Guidebook
(EPA305-8-97-005)This screening check-
list and guidebook provides the basic
information a shop owner and facility
manager needs to know to be in substan-
tial compliance with federal environmen-
tal regulations.
Fuel for Thought...How to Reduce Wastes
at Your Shop (EPA305-K-96-002) lists
practical pollution prevention tips for
vehicle maintenance shops.
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