United States Office of EPA/625/7-91/013
Environmental Protection Research and Development October 1991
Agency Washington, DC 20460
Guides to Pollution
Prevention
The Automotive Repair Industry
For Display Only
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EPA/625/7-91/013
October 1991
Guides to Pollution Prevention
The Automotive Repair Industry
Risk Reduction Engineering Laboratory
and
Center for Environmental Research Information
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, OH 45268
$3} Printed on Recycled Paper
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Notice
This report has been subjected to the U.S. Environmental Protection Agency's peer and
administrative review and approved for publication. Mention of trade names or commercial
products does not constitute endorsement or recommendation for use.
This document is intended as advisory guidance only to automotive repair businesses in
developing approaches for pollution prevention. Compliance with environmental and
occupational safety and health laws is the responsibility of each individual business and is
not the focus of mis document
Worksheets are provided for conducting waste minimization assessments of automotive
repair shops. Users are encouraged to duplicate portions of this publication as needed to
implement a waste minimization program.
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Foreword
This report provides many waste minimization options for wastes generated by the
automotive repair industry. Significant quantities of waste can be eliminated or avoided by
establishing proper waste automotive fluid management practices, operating equipment
properly (e.g., solvent sinks, hot tanks and jet spray washers), avoiding spills, and using
detergents in place of solvents, Useof drip tray sand collection of solidresiduesfrom cleaning
further controls waste discharges.
In addition to waste minimization, segregation of solvent and aqueous waste by small
to medium size repair shops must be promoted. Many of these small businesses generate less
than 10 gallons of waste per month. These quantities can cost more for disposal than the
original purchase price. Waste motor oils are often used as the vehicle for solvent waste
disposal. Aqueous wastes often contain hazardous levels of grease, oil, and heavy metals.
Many small shops dispose of this waste into the municipal sewer. Use of a service company
to supply cleaning chemicals and remove waste materials is becoming an economical option.
HI
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Contents
Notice.......... ii
Foreword iii
Acknowledgments vi
1. Introduction 1
Overview of Waste Minimization 1
Waste Minimization Opportunity Assessments 1
References 3
2. Automotive Repair Industry Profile 5
Industry Description 5
Overview of Waste Generation .<. 5
References 7
3. Waste Minimization Options for Automotive Repair Shops 9
Shop Cleanup ., 9
Parts Cleaning 11
Automotive Maintenance 13
References , 13
4. Waste Minimization Assessment Worksheets ;.... 15
Appendix A. Automotive Repair Shop Assessments: Case Studies of Shops A, B, and C 26
Appendix B. Where to Get Help: Further Information on Pollution Prevention 39
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Acknowledgments
This guide is based in part on waste minimization assessments conducted by Wesley
M. Toy, for the California Department of Health Services (DHS) under the direction of
Benjamin Fries, DHS Toxic Substances Control Program, Alternate Technology Division.
Additional information was taken from waste minimization assessments performed by
Jacobs Engineering Group Inc. (Jacobs) for the City of Santa Monica (CSM), under the
direction of Brian Johnson, CSM Water/Wastewater Division, Department of General
Services. Michael Callahan and David Shoemaker of Jacobs edited and developed this
version of the waste minimization assessment guide, under subcontract to PEI Associates
(USEPA contract 68-D8-0112). Teresa Harten of the U.S. Environmental Protection
Agency, Office of Research and Development, Risk Reduction Engineering Laboratory,
was the project officer responsible for the preparation and review of this document Wesley
M. Toy, Moonyean Kistler of the Automotive Service Councils of California, and Carol
Bartels of D & L Automotive Repair served as reviewers.
VI
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Section 1
Introduction
This guide is designed to provide automotive repair fa-
cilities with waste minimization options appropriate for the
industry. It also provides worksheets designed to be used for a
•waste minimization assessment of an automotive repair facil-
ity, to develop an understanding of the facility's waste gener-
ating processes and to suggest ways that the waste may be
reduced.
The guide is designed primarily for use by operators of
automotive repair shops. Others who may find this document
useful are operators of vehicle fleets, regulatory agency repre-
sentatives, and consultants. In the following sections of this
report you will find:
• An overview of the automotive repair industry
(Section 2);
• Waste minimization options for automotive repairers
(Section 3);
• Waste minimization assessment worksheets
(Section 4);
• Appendices containing:
Case studies of two automotive repair shops
and one parts washer lease and service com-
pany. Also included are completed waste
minimization assessment worksheets for a
hypothetical shop.
Where to get help: Regional EPA offices and
other sources.
The worksheets and the list of waste minimization op-
tions were developed through assessments of two Northern
California-area automotive repair facilities and one Northern
California parts washer lease and service company as com-
missioned by the California Department of Health Services
(CDHS 1987). The firms' operations, and waste generation
and management practices were surveyed, and their existing
and potential waste minimization options were characterized.
Economic analyses were performed on selected options. Ad-
ditional information was developed from the assessment of
three Southern California automotive repair facilities com-
missioned by the City of Santa Monica Department of Gen-
eral Services (CSM 1989).
Overview of Waste Minimization
Waste minimization is a policy specifically mandated by
the U.S. Congress in the 1984 Hazardous and Solid Wastes
Amendments to the Resource Conservation and Recovery Act
(RCRA). As the federal agency responsible for writing regu-
lations under RCRA, the U.S. Environmental Protection
Agency (EPA) has an interest in ensuring that new methods
and approaches are developed for minimizing hazardous waste
and that such information is made available to the industries
concerned. This guide is one of the approaches EPA is using
to provide industry-specific information about hazardous waste
minimization. The options and procedures outlined can also
be used in efforts to minimize other wastes generated in a
business.
In the working definition used by EPA, waste minimiza-
tion consists of source reduction and recycling. Of the two
approaches, source reduction is considered environmentally
preferable to recycling. While a few states consider treatment
of waste an approach to waste minimization, EPA does not
and thus treatment is not addressed in this guide.
Waste Minimization Opportunity Assessments
EPA has developed a general manual for waste minimi-
zation in industry. The Waste Minimization Opportunity As-
sessment Manual (USEPA 1988) tells how to conduct a waste
minimization assessment and develop options for reducing
hazardous waste generation. It explains the management strat-
egies needed to incorporate waste minimization into company
policies and structure, how to establish a company-wide waste
minimization program, conduct assessments, implement op-
tions, and make the program an on-going one.
A Waste Minimization Opportunity Assessment (WMOA)
is a systematic procedure for identifying ways to reduce or
eliminate waste. The four phases of a waste minimization
opportunity assessment are: planning and organization, as-
sessment, feasibility analysis, and implementation. The steps
involved in conducting a waste minimization assessment are
illustrated in Figure 1, and presented in more detail below.
Briefly the assessment consists of a careful review of a plant's
operations and waste streams and the selection of specific
areas to assess. After a particular waste stream or area is
established as the WMOA focus, a number of options with the
potential to minimize waste are developed and screened. The
technical and economic feasibility of the selected options are
then evaluated. Finally, the most promising options are se-
lected for implementation.
1
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The Recognized Need to Minimize Waste
Planning and Organization Phase
Gat management commitment
Set overall assessment program goals
Organize assessment program task force
Assessment Organization &
Commitment to Proceed
i
Astoasment Phase
Collect process and site data
Prioritize and select assessment targets
Select people for assessment teams
Review data and inspect site
Generate options
Screen and select options for further study
Assessment Report of
Selected Options
Feasibility Analysis Phase
Technical evaluation
Economic evaluation
Select options for implementation
Final Report, Including
Recommended Options
Implementation Phase
Justify projects and obtain funding
Installation (equipment)
Implementation (procedure)
Evaluate performance
Successfully Implemented
Waste Minimization Projects
Figure 1. The waste minimization assessment procedure.
Select New Assessment
Targets and Reevaluate
Previous Options
Repeat the Process
Planning and Organization
Essential elements of planning and organization for waste
minimization are: getting management commitment; setting
waste minimization goals; and organizing an assessment task
force.
Assessment Phase
The assessment phase involves a number of steps:
1. Collect process data
2. Prioritize and select assessment targets
3. Select assessment team
4. Review data and inspect site
5. Generate options
6. Screen and select options for feasibility study
Collect process data. The waste streams at a shop should
be identified and characterized. Information about waste
streams may be available on hazardous waste manifests, Na-
tional Pollutant Discharge Elimination System (NPDES) re-
ports, routine sampling programs and other sources.
Developing a basic understanding of the processes that
generate waste is essential to waste minimization. Flow dia-
grams should be prepared to identify the quantity, types and
rates of waste generated. Also, preparing material balances for
various processes can be useful in tracking various process
components and identifying losses or emissions that may have
been unaccounted for previously.
Prioritize and select assessment targets. Ideally, all waste
streams should be evaluated for potential waste minimization
opportunities. With limited resources, however, a plant man-
ager may need to concentrate waste minimization efforts in a
specific area. Such considerations as quantity of waste, haz-
ardous properties of the waste, regulations, safety of employ-
ees, economics, and other characteristics need to be evaluated
in selecting a target stream.
Select assessment team. The team should include people
with direct responsibility and knowledge of the particular
waste stream or area of the shop or plant
Review data and inspect site. The assessment team evalu-
ates process data in advance of the inspection. The inspection
should follow the target process from the point where raw
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materials enter the shop or plant to the points where products
and wastes leave. The team should identify the suspected
sources of waste. This may include the production process;
maintenance operations; and storage areas for raw materials,
finished product, and work in progress. The inspection may
result in the formation of preliminary conclusions about waste
minimization opportunities. Full confirmation of these con-
clusions may require additional data collection, analysis, and/
or site visits.
Generate options. The objective of this step is to generate
a comprehensive set of waste minimization options for further
consideration. Since technical and economic concerns will be
considered in the later feasibility step, no options are ruled out
at this time. Information from the site inspection, as well as
trade associations, government agencies, technical and trade
reports, equipment vendors, consultants, and plant engineers
and operators may serve as sources of ideas for waste minimi-
zation options.
Both source reduction and recycling options should be
considered. Source reduction may be accomplished through
good operating practices, technology changes, input material
changes, and product changes. Recycling includes use and
reuse of waste, and reclamation.
Screen and select options for further study. This screen-
ing process is intended to select the most promising options
for full technical and economic feasibility study. Through
either an informal review or a quantitative decision-making
process, options that appear marginal, impractical or inferior
are eliminated from consideration.
Feasibility Analysis
An option must be shown to be technically and economi-
cally feasible in order to merit serious consideration for
adoption. A technical evaluation determines whether a pro-
posed option will work in a specific application. Both process
and equipment changes need to be assessed for their overall
effects on waste quantity and product quality. Also, any new
products developed through process and/or raw material
changes need to be tested for market acceptance.
An economic evaluation is carried out using standard
measures of profitability, such as payback period, return on
investment, and net present value. As in any project, the cost
elements of a waste minimization project can be broken down
into capital costs and economic costs. Savings and changes in
revenue also need to be considered.
Implementation
An option that passes both technical and economic feasi-
bility reviews should then be implemented. It is then up to the
assessment team, with management support, to continue the
process of tracking wastes and identifying opportunities for
waste minimization, throughout a facility and by way of
periodic reassessments. Either such ongoing reassessments or
an initial investigation of waste minimization opportunities
can be conducted using this manual.
References
Calif. DHS. 1987. Waste audit study: automotive repairs.
Report prepared by Wesley M. Toy, PJ2. Saratoga,
Calif., for the California Department of Health Ser-
vices, Alternative Technology Section, Toxic Sub-
stances Control Division. May 1987.
CSM. 1989. Hazardous waste minimization audits of
automotive repair and refinishing facilities. Prepared
by Jacobs Engineering Group Inc., Pasadena, Calif.,
for the City of Santa Monica Department of General
Services. September 1989.
USEPA. 1988. Waste minimization opportunity assess-
ments manual. EPA 625/7-88/003. Prepared by Jacobs
Engineering Group Inc., Pasadena, Calif., for the
Hazardous Waste Engineering Research Laboratory,
Cincinnati, OH.
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Section 2
Automotive Repair Industry Profile
Industry Description
The automotive repair industry is composed of three
primary segments: automotive repair shops; new car
dealerships; and diesel engine repair shops. These three seg-
ments produce significant solvent wastes, aqueous wastes,
and sludges which require disposal as hazardous waste. Of
small quantity generators of hazardous waste located in the
United States, automotive repair leads in number of genera-
tors and in quantity of total waste produced (USEPA 1985).
Autobody shops and paint shops are covered by a another
guide in the pollution prevention guide series (USEPA 199 Ib).
The most common activities performed at automotive
repair shops include replacement of automotive fluids (e.g.,
motor oil, radiator coolant, transmission fluid, brake fluid),
replacement of non-repairable equipment (e.g., brake shoes/
pads, shocks, batteries, belts, mufflers, electrical components,
water pumps), and repair of fixable equipment (e.g., brake
calipers/rotors/drums, alternators, fuel pumps, carburetors,
power train components). Equipment removed for repair often
requires cleaning. Cleaning is performed to allow for better
visual inspection of the parts and to remove contaminated
lubricants/greases that would lead to early failure of the
repaired part Clean lubricants/greases are applied to the parts
(if needed) during reassembly. Repairable parts are often
replaced with new or commercially rebuilt parts at the discre-
tion of the customer. Most repairable parts that are not fixed at
the shop and many non-repairable parts are sold to automotive
part remanufacturers.
Overview of Waste Generation
The major waste generating activities that occur in auto-
motive repair and servicing include: clean up of the shop area,
cleaning of parts in order to perform repairs, scheduled car
Table 1. Typical Automotive Repair Wastes
Operation Waste Material
Shop Cleanup
Parts Cleaning
Out-dated Supplies
Dirty Rags and Sawdust
Alkaline Floor Cleaner
Clarifier Sludge
Solvents
Ar Emissions
Aqueous Cleaners
Dirty Baths
Auto Maintenance Motor Oil
Transmission Fluid
Engine Coolant
Batteries
Brakes
Refrigerant
Solvents, caustic cleaners, automotive fluids (oils, alcohols, ethyleneglycol, acids).
Oil and grease, heavy metals, solvents.
Caustics, oil and grease, heavy metals.
Oil and grease, heavy metals.
Petroleum distillates, aromatic hydrocarbons, mineral spirits, naphtha, chlorinated
compounds, oi and grease, heavy metals.
See solvents.
Adds and alkalis, oil and grease, heavy metals, blended heavy oils, heavy metals.
See aqueous cleaners.
Blended mineral oil, heavy metals.
Blended mineral oil, heavy metals.
Ethyleneglycol, lead.
Sulfurk add, lead.
Asbestos.
CFC-12
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maintenance (replacement of engine oil, oil filters, transmis-
sion fluid, radiator fluids), and nonscheduled maintenance/
repair (replacement of spent batteries, worn brakes, shocks,
tires, etc.). Table 1 provides a description of materials and
wastes. Additional information regarding waste generation is
presented in the following sections.
Shop Cleanup Wastes
The amount of sawdust, rags, and wash-down waste
generated during shop cleanup is a direct function of the care
employees take in preventing spills and leaks of the automo-
bile fluids handled. Waste management practices for these are
discussed below.
Dirty rags. Rags are often used to cleanup a liquid spill or
to wipe off grease from a part being repaired. Dirty rags are
typically disposed of in the trash. To reduce the costs and
liability associated with disposal of dirty rags which might be
classified as hazardous, some shops are investigating the use
of leasing arrangements in which a laundry service picks up
the dirty rags, cleans them, and returns them to the shop.
Sawdust. Sawdust is commonly used to absorb a spill of
raw materials or hazardous wastes. Depending on the material
absorbed, used sawdust might be classified as a hazardous
waste and be subject to hazardous waste regulations. Most
shops currently dispose of this waste in the trash.
Area washdowns. Alkaline floor cleaners are used to
remove oil and grease from shop floors. Shop operators
should strive to employ the least hazardous type of floor
cleaner available. To reduce the need for and use of alkaline
cleaners, well run shops pay careful attention to the preven-
tion of leaks and spills. For facilities with clarifiers, discharge
of cleaner can upset the operation of the clarifier by forming
oil emulsions. Sludge removed from the clarifier might re-
quire disposal as a hazardous waste depending on its composi-
tion.
Parts Cleaning
Parts cleaning often involves the use of a parts washer.
Washers can be categorized as solvent parts washers, hot
tanks, jet spray washers, ultrasonic cleaners, and steam clean-
ers. The devices used primarily in this industry are solvent
parts washers, hot tanks, and jet spray washers. Ultrasonic
cleaners have not been adapted to handle the waste loading
found in the industry. The use of steam cleaning requires an
investment in water treatment and steam generator equipment
A brief discussion of solvent parts washers and hot tank/jet
spray washers follows.
A solvent parts washer recirculates solvent continuously
from the solvent drum to the solvent wash tray where the parts
are cleaned. Solvent is normally replaced with fresh solvent
on a monthly basis. The solvents used for parts cleaning
contain petroleum-based ingredients or mineral spirits. Car-
buretor cleaner contains methylene chloride.
Air emissions occur when the solvent is sprayed onto
parts placed in the wash tray and when parts are improperly
drained of solvent Many air quality control districts specify
that equipment cannot be designed so as to provide a fine
spray mist (which leads to high evaporation rates) and that
parts must be properly drained before removal from the
washer. For washers in which the solvent bath is always
exposed to the atmosphere (i.e. wash tanks), lids must be kept
closed whenever the tank is not in use. Add-on emission
control devices are extremely rare.
Electrically heated hot tanks are also used to clean parts.
Parts are placed in a tank of hot aqueous detergent or caustic
solution to achieve cleaning. Air or mechanical agitation is
employed to increase cleaning' efficiency. Jet spray washers
also use hot aqueous solutions for cleaning, but in this appli-
cation, rotating jets spray the parts with cleaner. Both hot
tanks and jet sprays are usually serviced monthly by removing
the spent cleaner and sludge and recharging the washer with
fresh detergent Disposal of 10 to 80 gallons of cleaning
solution per device on a monthly basis is typical of most
operations. Sludge that accumulates in the waste sump of the
pressure spray cleaning bays and in area wash-down clarifiers
is often taken off site to a local municipal landfill.
Scheduled Car Maintenance
The amount of waste oil, lube oil, transmission fluid, oil
filters, and engine coolant handled by each shop is a direct
function of the number of cars serviced. Since rules and
regulations regarding the proper management and disposal of
these wastes vary from state to state, readers should check
with their appropriate agencies.
Waste oil. Waste oil is regulated as a hazardous waste in
several states and must be transported by a licensed hazardous
waste hauler to a licensed treatment facility. Many shops store
waste oil, dirty lube oils and greases, and transmission fluids
in underground tanks for pick up by an off-site recycler.
Oil filters. Oil filters are typically drained of oil and are
then disposed of as nonhazardous waste. Because some shops
in the California DHS assessments have had trouble with oil
filters continuing to leak and drip oil in their trash dumpsters,
they are investigating the use of special oil filter receptacles
that would be picked up and handled by their waste oil hauler.
Engine coolant. Engine coolant may be regulated as a
hazardous waste because it contains ethylene glycpl (toxic)
and detectable concentrations of benzene, toluene, lead, zinc,
arsenic, mercury and copper accumulated from the cooling
system. Spent radiator solution is generated at 30 to 100
gallons per month by medium-sized to large repair shops and
is commonly collected, stored, and disposed of as a hazardous
waste. Many smaller shops sewer this waste.
Nonscheduled Maintenance and Repair
Nonscheduled maintenance and repair is required when
automotive parts fail due to routine wear, damage, or neglect
Typical wastes include broken belts and hoses, tires, batteries,
brake pads and shoes, water pumps, fuel pumps, carburetors,
mufflers, and others. The first step in reducing or avoiding the
generation of these wastes is for customers to follow routine
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scheduled maintenance as specified by the automobile manu- References
facturers and to practice good driving techniques. Both of _ ... ____ • _ „, .
these can reduce wear and tear on the automobile. Calrf-DHS-1987-Waste audtt 5tudy: automotive repairs.
Report prepared by Wesley M. Toy, PJE. Saratoga,
Many of the broken parts removed from an automobile c.alif., for the California Department of Health Ser-
that are not cost-effective to repair are sold to parts **«• Alternative Technology Section, Toxic Sub-
remanufaeturers. Such parts include brake shoes and pads, stances Control Division. May 1987.
master cylinders, water pumps, fuel pumps, alternators, com- -.„», „„„„ „ .... .. ,
pressors, engines, transmissions, and many others. Worn tires CSM- 1989- Hazardous waste minimization audits of
can sometimes be recapped, but the demand for recapped tires automotive repair and refausfungfacilities. Prepared
is limited. There is also a limited market for rebuilt batteries. by Jacobs Engineering Group Inc., Pasadena^Calif.,
Most tires are landfilled while spent batteries are often sold to for *« Clty of Santa *£5** Depart"161* °f General
a smelter for the recovery of lead. Cracked or broken batteries Services. September 1989.
should be managed as a hazardous waste.
USEPA. 1985. Survey of small quantity generators. U.S.
Environmental Protection Agency Office of Solid
Waste and Emergency Response. Washington, D.C.
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Section 3
Waste Minimization Options for Automotive Repair Shops
This section discusses recommended waste minimization
methods for automotive repair shops. These methods come
from accounts published in the open literature and through
industry contacts. The primary waste streams associated with
automotive repair are listed in Table 2 along with recom-
mended waste minimization options. Typical waste streams
are shop clean up wastes, parts cleaning wastes, and automo-
tive maintenance wastes.
The waste minimization options listed in Table 2 can be
classified generally as source reduction (which can be achieved
through material substitution, process or equipment modifica-
tion, or better operating practices) or as recycling. Better
operating practices are procedural or institutional policies that
result in a reduction in waste. They include:
• Waste stream segregation
• Personnel practices
Management initiatives
Employee training
Employee incentives
• Procedural measures
Documentation
Material handling and storage
Material tracking and inventory control
Scheduling
• Loss prevention practices
Spill prevention
Preventive maintenance
Emergency preparedness
• Accounting practices
Apportion waste management costs to depart-
ments that generate the waste.
Better operating practices apply to all waste streams. In
addition, specific better operating practices that apply to cer-
tain waste streams are identified in the appropriate sections
that follow.
Shop Cleanup
The human aspects of industrial activity can be very
important in waste reduction. Often termed "good operating
practices" or "good housekeeping," these methods can be
very effective in reducing the amount of shop clean up wastes
generated. Typical wastes include outdated supplies, dirty
rags, sawdust, area washdowns, and clarifier sludges.
Good housekeeping methods include improved employee
training, management initiatives to increase employee aware-
ness of the need for and benefits of waste minimization, and
requiring increased use of preventive maintenance in an effort
to reduce the number of leaks and spills that occur. Additional
ways to reduce or minimize waste include:
Improve inventory control
Use first-in, first-out (FIFO) policy
Minimize storage quantities
Increase storage area inspections
Conduct employee training
Employ spill containment techniques
In one survey of automotive repair businesses (CSM
1989), all shops assessed used computerized inventory con-
trol; however, none reported the use of rigid control to maxi-
mize the use of supplies. This suggests that workers were free
to obtain supplies at will. Workers should be made to return
empty containers of materials before they are issued new
supplies. This type of policy has been reported to be effective
in reducing the solvent use at several automotive refinishing
businesses. For more information, refer to the EPA pollution
prevention guide for automotive refinishers (USEPA 1991).
Cleanup wastes can be minimized by improving spill
containment techniques and by implementing policies to re-
duce spillage. When a spill of raw material or hazardous waste
occurs, sawdust (or some other adsorbent) may be used to
adsorb it Depending on the nature of the spilled material, the
sawdust may become a hazardous waste and be subject to all
hazardous waste regulations. If floors are heavily soiled with
oil and other hazardous materials when washed, then large
quantities of wash water may acquire hazardous waste classi-
fication. Ways to reduce spillage include:
Award program for worker with cleanest bay. Awards
should be based on the care a mechanic takes in preventing
spills as well as the worker's efficiency of cleanup after a
spill. At some facilities, work bays out of sight of the cus-
tomer tend to be dirtier than bays in sight Special attention
should be given to inspection of areas where the general
feeling might be "out of sight out of mind".
Use of drip trays. To assist workers in keeping their
assigned bays clean, drip pans should be provided and used.
Most shops do not use drip pans and the occurrence of fluids
leaking from automobiles and parts placed on the floor is
common. By using drip pans, shop floors will remain cleaner
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Table 2. Waste Minimization Methods for Vie Automotive Repair Industry
Activity Waste
Waste Minimization Options
Shop Cleanup Out-dated Supplies
Ditty Rags and Sawdust
Akaline Floor Cleaner
Clarifier Sludges
Parts Cleaning Solvent Baths/Air
Emissions
Computerize inventory control, use first-in, first-out policy, minimize storage quantities, and perform
routine storage area inspections.
Use good housekeeping measures to reduce spills and leaks. Lease rags from a laundry cleaning
service.
Use good housekeeping measures to reduce spills and leaks such as award program for worker with
cleanest bay, use of drip trays under leaking cars and removed parts, and proper storage of waste
materials (use of pallet/containment systems and installation of self-closing non-leak safety faucets
on portable waste oil drums).
Use good housekeeping measures to reduce spills and leaks.
Don t flush dust or floor sweepings to the clarrtier unit.
Use less hazardous or safer solvents.
Determine how clean parts need to be. Use solvents properly, dontuseto clean floors.
Increase cleaning efficiency.
Monitor solvent composiion.
Operate solvent sinks properly, use drip trays and allow more drainage time. Keep lids closed when
not in use.
Contract with a service company to maintain solvent sinks.
Install on-site solvent recovery equipment.
Aqueous Baths
Switch from caustic to detergent-based cleaning solutions.
Use dryprecleaning methods such as wire brushing.
Maintain solution quality by monitoring composition.
Maintain equipment in proper working order.
FiRer solids from the bath on a continuous basis.
Screen solids before they reach Vie waste sump.
Employ two-stage parts cleaning sequence.
Install or convert free running rinses to still rinse.
Use a hot tank or jet spray washer lease service.
Switch to bake-off ovens.
Automotive
Maintenance
Spent Fluid (Oil, Coolant,
and Transmission Fluids)
CFC-12
Store all wastes properly and keep segregated to promote the potential for recycling.
Give or sell to a parts remanufacturer.
If unbroken, seS batteries to an off-site recycter.
Purchase recycling system to recover refrigerant.
and hence less frequent cleaning of the floors should be
required. Added benefits would be a reduction in use of rags
and adsorbent to clean the floors, and a safer work environ-
ment
Proper storage of waste materials. Waste materials should
always be kept segregated and stored in proper containers.
Storage areas should be termed or diked so that accidental
spills can be contained. This is especially important for spent
battery storage. Batteries may be stored in the parts supply
room awaiting pick up. If these were to leak, the resulting acid
spill could be dangerous. For shops with limited space, com-
bination pallet/containment systems are available.
Another option for reducing leaks and spills is the use of
self-closing non-leak safety faucets on the portable waste oil
collection tanks. Leaking valves should be replaced as soon as
possible whenever leaking is noticed. If immediate replace-
ment of the valve is not feasible, then a small collection cup
should be hung under the valve to catch drippings. Accidental
opening of the valve, which might occur if the valve handle
were kicked or hit, can be prevented by using padlockable
valves and inserting lock pins.
10
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Parts Cleaning
The recommended strategy for developing effective waste
minimization options for parts cleaning operations relies on
systematic exploration of the following sequence of steps:
1. Avoid the need to clean.
2. Select the least hazardous cleaner.
3. Maximize cleaning efficiency.
4. Segregate cleaning wastes.
5. Maximize recycling and reuse.
This strategy is consistent with the multi-media approach
and general emphasis of reducing the waste at the source. The
following sections discuss waste minimization options for
users of solvents and aqueous cleaners.
Solvents
Solvent wastes were among the first to be banned from
land disposal by the EPA. The 1984 RCRA amendments
specify five categories of solvent waste (F-001 to F-005)
which are banned from land disposal effective November
1986 (RCRA 3004 (e)(l)). Due to the diverse problems asso-
ciated with solvent use, solvents should always be used only
when no other cleaner is suitable for the job. The major ways
to avoid or reduce the generation of solvent waste include
eliminating the need to use solvent; finding adequate substi-
tutes for solvents; minimizing losses associated with solvent
use; and segregation, recycle, recovery, and reuse of waste
solvents.
Product reformulation or substitution. The auto repair
industry has reformulated carburetor cleaner compound to
exclude the use of 1,1,1 trichloroethane (FCA), which had
been used typically in 5 percent concentrations with methyl-
ene chloride and cresylic acid. TCA is a known toxic sub-
stance and irritant absorbed through the skin.
Another potential substitution that is increasing in use is
terpene cleaners in place of Stoddard solvent The terpene
cleaners are available commercially in neat form or as water
solutions with surfactants, emulsifiers, rust inhibitors, and
other additives. Terpenes have tested favorably as substitutes
for halogenated solvents for removal of heavy greases, oily
deposits, and carbonized oils. Reported disadvantages of ter-
penes include inability to separate long chain aliphatic oils for
recycling of the cleaning solution both in neat form and in
aqueous emulsions. Ultrafiltration to remove oil is not viable
for recycle and is only useful for treating dilute emulsions
prior to wastewater treatment Recovery by distillation is
impractical since terpenes boil around 340°F, which means
that many light oils would be carried over with the solvent
Energy cost for distillation recovery, even with vacuum assist,
would be high.
Determine how clean parts need to be. Before using a
solvent or aqueous cleaner, one should determine whether
cleaning is necessary and just how clean a part needs to be.
Rigorous chemical cleaning should only be performed when
parts require it (e.g., bearings, engine internals, etc.). Station-
ary structural members typically require cleaning only for
inspection.
Use solvents properly. Solvent should never be used for
the general cleaning of shop floors, and should only be used in
a well-maintained self-contained cleaning system. When not
in use, all solvent cleaning tanks must be covered and/or drain
plugs closed. Solvent losses due to inappropriate usage, equip-
ment leaks or spills, and evaporation can range from 25 to 40
percent of total solvent usage. Cans of spray cleaner should
only be used when parts cannot be removed from the car and
the placement of a cleaning sink or a pan under the part to
catch drippage is not feasible.
Increase cleaning efficiency. The need to dispose of or
replace dirty solvent can often be reduced by increasing the
degree of cleaning efficiency. While cold cleaning operations
can be successfully performed at up to 10 percent soil solids
content, solvent baths are often replaced when the contamina-
tion level reaches two to three percent, due to slow cleaning
action. A simple way to increase cleaning efficiency is to
employ manual brushing. Manual brushing is extremely ef-
fective at removing caked-on solids and is a common
precleaning technique. Use of ultrasonic or mechanical agita-
tion also increases the cleaning efficiency.
Monitor solvent composition. Because decisions to re-
place dirty solvent are made arbitrarily, much solvent is
disposed of prematurely. Solvent monitoring may be per-
formed to ensure that solvent is replaced only when it is truly
dirty. In the dry cleaning industry, the level of solvent con-
tamination is monitored by measuring the transmittance of
light through a sample of dirty solvent Work performed by
the military on monitoring the quality of Stoddard solvent
used for cleaning showed that light transmittance, as mea-
sured by visible absorbance at 500 nanometers (nm), was a
reliable indicator of contamination. Solvent replacement was
required when light transmittance dropped below 25 percent
• Operate solvent sinks properly. Improper use of solvent
sinks can lead to excessive solvent losses and increased waste
generation. To reduce solvent losses and waste generation,
solvent sinks should be operated properly. Ways to reduce
losses include using a solvent sink with recirculating base
tank as opposed to a rinse tank or open bucket, placing of
sinks in a convenient location, removing parts slowly after
immersion to reduce drippage, installing drip trays or racks to
drain cleaned parts, allowing more drainage time over the sink
after withdrawal, and turning off the solvent stream, covering
or plugging sink when not in use.
Contract with a solvent service company. For a monthly
fee, solvent service companies will pickup duty solvent, clean
and maintain the solvent sink, and refill the sink with clean
solvent Depending on the arrangement, solvent sinks may be
owned by the shop or leased from the solvent service com-
pany. The cost for contracting with a solvent service company
is often less than the combined cost of solvent purchase, tank
maintenance, and waste disposal. Safety-Kleen Corp. and
Safe-Way Chemical Company as well as others offer this
service. Over 95 percent of automotive repair operations have
some type of solvent sink. The use of solvent sinks for parts
washing either on an owned or leased basis is being accepted
as general good practice.
11
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Safety-Kleen, a nationally-franchised organization, re-
covers for reuse approximately 10,000 gallons of solvent per
month in the San Francisco Bay area alone. Duty solvent is
taken to the recycling facility, where it is distilled and re-
turned to the users. Safe-Way Chemical Company sells waste
solvent to solvent recovery operations such as Solvent Ser-
vices of San Jose, where a waste fuel is produced by distilla-
tion.
In addition to cleaning solvent, both companies offer
similar services for carburetor cleaner. Safety-Kleen recovers
carburetor cleaner for reuse by distillation. Product fees charged
include pickup and disposal of spent solutions. Safe-Way
Chemical sends waste carburetor cleaner for solvent recovery
to Solvent Services, where a lacquer wash is produced. Lac-
quer wash is used in paint stripping, among other uses.
Install on-site solvent recovery equipment. Purchase of
an on-site solvent recovery system is often viewed as a viable
waste minimization option for solvent wastes. Recent prices
(August 1990) for 5 and IS gallon batch stills designed to
process Stoddard solvent are $3,600 and $12,500 respec-
tively. These stills utilize a bag liner (for ease of cleaning) and
microprocessor control. Based on the results of the California
DHS assessments, the low volume of solvent normally used at
most small to medium repair operations does not justify the
added expense of on-site solvent recovery equipment and
maintenance costs. For large operations that do generate sig-
nificant volumes of solvent, labor costs to operate the equip-
ment and additional costs for disposal of waste residues are
not competitive with current solvent sink lease and mainte-
nance service operations. Given the poor economics of this
option, not to mention the increased liabilities and regulatory
requirements which may be associated with on-site recycling,
this option would be viable only for a few automotive repair
facilities.
Aqueous Cleaners
Aqueous cleaning comprises a wide range of methods
that use water, detergents, acids, and alkaline compounds to
displace soil rather than dissolving it in organic solvent.
Aqueous cleaning has been found to be a viable substitute for
many parts cleaning operations currently using solvents. Its
principle disadvantage is that the parts are wet after cleaning
and carbon steel parts rust easily in this environment. Tech-
niques for reducing wastes from aqueous cleaning include:
Switch to bake-off ovens. Small bake-off ovens are being
adopted for use in this industry to replace caustic cleaners.
Bake-off ovens are designed to pyrolize the dirt and grease,
leaving a dry residue that can be brushed off. In most cases,
abrasive blasting of the parts is required to remove all of the
residue. The advantage of a bake-off oven is that it produces a
small volume of dry solid wastes compared to a large volume
of liquidx waste. Disadvantages of bake-off ovens include
potential for increased air emissions, need for abrasive blast-
ing equipment, and potential distortion or alteration of the part
shape.
Switch to detergent-based cleaners. Many shops are
switching from solvent or caustic-based cleaners to less haz-
ardous detergent-based cleaners. Operators should check that
the type of cleaner used consists of surfactants that are good
detergents but are poor emulsifiers (stable oil emulsions limit
reuse of the cleaner and hasten its disposal). Agitation of the
bath during use keeps the solids in suspension. Following
prolonged periods of inactivity, however, the oily solids sepa-
rate via flotation or settle to form a bottom sludge. Solution
strength is maintained and bath life prolonged by removing
these solids frequently.
Use dry precleaning (wire brushing). To reduce the load-
ing of dut and grime on chemical cleaners and reduce the
generation of chemical-laden sludge, the use of dry wipes and
wire brushing to pre-clean the part prior to soaking should be
considered. While these methods would not be appropriate for
precision cleaning, they can be used to remove the bulk of the
dirt and grime from external surfaces.
Maintain solution quality. In addition to dut loading,
excessive consumption of alkaline cleaner can also be caused
by using air for agitation and hard water for make-up. Air
agitation introduces carbon dioxide which reacts with alkali,
and use of hard water can result in the formation of paniculate
solid sludge. In some applications, the decrease in cleaner
effectiveness due to carbon dioxide and hard water salts can
equal the decrease due to soil loading. Mechanical agitation
by means of jet sprays and use of demineralized water for
make-up is preferred. Analytical checks of solution strengths,
performed by the operator using simple titration techniques,
should be made routinely. The correction of solution strength
by making small and frequent additions is more effective than
making a few large additions.
Maintain equipment in good working order. Rack sys-
tems should be maintained in good condition, free from
cracks, rust, and corrosion which can flake off and contami-
nate the bath. Metal tanks should be properly coated with
protective finishes both inside and out. Spray nozzles should
be inspected regularly to avoid clogging. A still rinse follow-
ing the cleaning tank is a good way to avoid the loss of cleaner
and reduce the discharge of contaminants to the sewer.
Another important item that should be maintained regu-
larly is the float valve that supplies make-up water to tanks of
heated cleaning solutions. While maintaining an adequate
level is necessary, it is also imperative that the valve does not
leak and result in dilution of the cleaner. In addition to
maintenance, routine analytical checks of solution strength is
a good way to detect slow leaks. Decreases in solution strength
during a time when the tank has not been used is a sure
indication of a leaking valve (provided that the tank is not
leaking).
Screen solids before they reach the waste sump. The
majority of the heavy metal residue, oil and grease removed
from the hot tank operations occurs after the actual hot tank
use. The heavier concentrations of solid residues are found in
the waste sump. Standard practice currently is to use a high-
velocity spray wand to dislodge these solids into the sump.
Proper capture and disposal of these wastes is necessary. This
can be done by use of a solids collection tray with overflow to
the sump or periodic cleanout of the sump by a waste hauler
for disposal at a Class I landfill.
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Two-stage parts cleaning. Use of a two-stage parts clean-
ing arrangement can help to reduce the amount of spent
cleaning solution requiring disposal. In a single-stage washer,
cleaning solution must be replaced when it can no longer
remove or dissolve all of the surface contamination on the
part In a two-stage washer, dirty solution is used to mechani-
cally dislodge bulk contamination from the part followed by
the use of clean solution. When the clean solution can no
longer be used in the second stage, it is used to replace the
dirty solution in the first stage.
Install or convert free running rinses to still rinse. Install-
ing a still rinsing tank immediately after an aqueous cleaning
tank allows for cleaner recovery and lowered rinsewater dis-
charges. In such a system, the workplace is immersed in the
still rinse tank following the cleaning operation. Since the still
rinse has no free running inflow or outflow of water, cleaner
concentration builds up in it As water evaporates from the
healed cleaning system, water from the still rinse is used as
make-up. Fresh water is then added to the still rinse. In the
case of radiator cleaning, use of a still rinse following the boil-
out tank is an effective way of reducing heavy metal discharge
(most notably lead) to the sewer.
Use a lease service. Similar to solvent lease arrange-
ments, some companies offer a leasing service for hot tanks
and jet spray washers. Hot tank arrangements include monthly
leasing of a hot tank and monthly general maintenance service
with removal of 10 gallons of solution and sludge and re-
charge of solution with caustic or alkaline detergent and
make-up water. Jet spray washer arrangements include monthly
leasing of a jet spray and monthly general maintenance ser-
vice with removal of 10 gallons of solution-and sludge and
recharge of solution with caustic or alkaline detergent and
make-up water.
Automotive Maintenance
To minimize problems associated with disposal of main-
tenance wastes, automotive repair shops should manage wastes
properly. Proper management includes keeping all incompat-
ible wastes segregated and contracting with appropriate recy-
clers and waste handlers. Viable options include:
Solvent segregation. Proper manifesting and recovery of
spent solvent solutions can only occur if small and medium-
size repair operations segregate solvent wastes in suitable
storage containers. Current practice at many operations is to
commingle the wastes with the waste oil. This practice should
be discouraged.
Carburetor cleaner segregation. Similarly, carburetor
cleaner is often mixed with waste oils. Carburetor cleaner is a
corrosive liquid and contains chlorinated compounds. This
waste should be accumulated separately for proper waste
management in a suitable container or system.
Spent antifreeze solution and waste motor oils recycling.
Both spent antifreeze solution and waste motor oils are gener-
ated in substantial quantity at both medium-size and large
automotive repair operations. Proper compliance may require
collection of these wastes by a registered hazardous waste
hauler. Several companies offer off-site recycling services.
Spent lead-acid battery recycling. On a weight basis,
spent lead-acid batteries are one of the largest categories of
hazardous wastes generated. Recyclers pay auto repair busi-
nesses between $1.00 and $1.50 per battery recycled. Spent
batteries are either rebuilt for resale or sent to a processor for
material salvage. One in six batteries received is rebuildable.
Recover and recycle CFC-12. Rather than venting refrig-
erant to the atmosphere during air conditioning servicing,
recovery and recycling systems are available (MACS 1989).
The shops assessed in the Santa Monica study (CSM 1989)
reported that the cost of an on-site recovery and recycling
system was $3400. Assuming that it is possible to recover 20
ounces per air conditioner and that the cost of refrigerant is
$30 per gallon, a recycling system will pay for itself after
servicing approximately 750 air conditioners.
Consumer education. Another way to minimize the gen-
eration of automotive maintenance wastes is through promo-
tion of good consumer practices by public agencies and the
automotive industry. Consumers should be encouraged to
follow specified maintenance schedules and not have service
performed needlessly. Simple test methods should be devel-
oped to determine if automotive fluids are being replaced
prematurely. This could avoid unnecessary fluid changes. Use
of synthetic lube oils, which reportedly last 10,000 to 15,000
miles before requiring replacement, could also be a viable
waste reduction measure.
References
Calif. DHS. 1988a. Hazardous waste reduction assess-
ment handbook, automotive repair shops. California
Department of Health Services, Toxic Substances
Control Division, Alternative Technology Section.
October 1988.
Calif. DHS. 19&8b. Hazardous waste reduction checklist:
automotive repair shops. California Department of
Health Services, Toxic Substances Control Division,
Alternative Technology Section. October 1988.
Calif. DHS. 1987. Waste audit study: Automotive repairs.
Prepared by Wesley M. Toy, P.E. Saratoga, Calif.,
for the California Department of Health Services,
Toxic Substances Control Division, Alternative Tech-
nology Section. May 1987.
CSM 1989. Hazardous waste minimization audits of au-
tomotive repair and refinishing facilities. Prepared
by Jacobs Engineering Group Inc., Pasadena, Calif.,
for the City of Santa Monica Department of General
Services. September 1989.
MACS 1989. Diagnostic ale service & refrigerant recy-
cling procedures manual. Prepared by the Mobile
Air Conditioning Society and published in Chiltons
Motor/Age, Vol. 108, No. 8, August 1989.
USEPA. 1991. Guides to pollution prevention: automo-
tive refinishing industry. Prepared by Jacobs Engi-
neering Group Inc., Pasadena Calif., for the U.S.
Environmental Protection Agency, Office of Research
and Development Cincinnati, OH.
13
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Section 4
Waste Minimization Assessment Worksheets
The worksheets provided in this section are intended to
assist auto repair shops in systematically evaluating waste
generating processes and in identifying waste minimization
opportunities. These worksheets include only the waste mini-
mization assessment phase of the procedure described in the
Waste Minimization Opportunity Assessments Manual. A com-
prehensive waste minimization assessment includes a plan-
ning and organizational step, an assessment step that includes
gathering background data and information, a feasibility study
on specific waste minimization options, and an implementa-
tion phase. For a full description of waste minimization as-
sessment procedures please refer to the manual. Table 3 lists
the worksheets included in this section. After completing the
worksheets, the assessment team should evaluate the appli-
cable waste minimization options and develop an implemen-
tation plan.
Table 3. Lift of Waste Minimization Assessment Worksheets
Number We
Description
1.
2a.
2b.
3.
4a.
4b.
S.
6a.
6b.
7.
Waste Sources
Waste Minimization:
Material Handling
Waste Minimization:
Material Handling
Option Generation:
Material Handling
Waste Minimization:
Parts Cleaning
Waste Minimization:
Parts Cleaning
Option Generation:
Parts Cleaning
Waste Minimization:
Waste Handling
Waste Minimization:
Waste Handling
Option Generation:
Typical wastes generated at automotive repair shops due to shop clean-up, parts
cleaning, and maintenance and repair operations.
Questionnaire on procedures used tor handling drums, containers arid packages.
Questionnaire on procedures used tor bulk liquid handling.
Waste minimization options for material handling operations.
Questionnaire on use of solvents and aqueous cleaners.
Continuation of questionnaire on use of aqueous cleaners.
Waste minimization options for parts cleaning operations.
Questionnaire on handling of waste automotive fluids and other automotive wastes.
Questionnaire on handling of waste due to shop dean-up.
Waste minimization options for waste handling.
Waste Handling
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WORKSHEET
1
Waste Minimization Assessment
Pro] No
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Sheet 1 Of
WASTE SOURCES
Shop Clean-Up
Obsolete raw materials
Spills & leaks (liquids & powders)
Dirty rags & adsorbent
Area wash water
Clarifier sludges
Container disposal
Pipeline/tank drainage
Evaporative losses
Parts Cleaning
Spent solvent cleaner
Spent carburetor and brake cleaner
Evaporative losses
Leaks and spills (solvents)
Spent alkaline cleaner
Leaks and spills (alkali)
Rinse water discharge
Sludges and filter wastes
Maintenance and Repair
Motor nil
Oil filters
Gaarandluhaoil
Transmission fluid
RrakA fluid ' '
Radiator coolant
Brakes (asbestos)
Radiators /laadl
Rattmrias (laari and, acid)
Junk parts
1 Page 1 at 10
Significance at Shop
Low
Medium
•
High
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0 WASTE MINIMIZATION:
«* Material Handling
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heel 1 of 2 Page 2 of 10
A. DRUMS, CONTAINERS, AND PACKAGES
Are drums, packages and containers inspected for damage before being accepted? Q yes Q no
Are employees trained in ways to safely handle the types of drums and packages received? Q yes Q no
Are they properly trained in handling ot spilled raw materials? Q yes Q no
Is there a formal personnel (raining program on raw material handling, spill prevention
proper storage techniques, and waste handling procedures? Q Ves Q no
Describe handling procedures for damaged items:
How oflan is training given anri hy whom?
Is obsolete raw material returned to (he supplier?
Is inventory used in first-in first-out order?
Is the inventory system computerized?
Does the current inventory control system adequately prevent waste generation?
What information does the system track? . ,_.
Q yes Q no
Q yes Q no
Q yes Q no
Q yes Q no
Are stored items protected from damage, contamination, or exposure to rain,
snow, sun and heat?
Is the dispensing of raw materials supervised and controlled?
Are users required to return empty containers before being issued new supplies?
Do you maintain and enforce a clear policy of using raw materials only for their
intended use?
Q yes Q no
Q yes Q no
Q yes Q no
Q yes Q no
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WORKSHEET
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WASTE MINIMIZATION:
Material Handling
B. BULK LIQUIDS HANDLING
What safeguards are in place to prevent spills and avoid ground contamination during the filling of storage tanks?
High level shutdown/alarms Q
Flow totalizers with cutoff Q
Secondary containment
Other
Describe the system:.
Are air emissions from solvent storage tanks controlled by means of:
Conservation vents
.Nitrogen blanketing
Absorber/Condenser
Other vapor loss control system
Q yes
Q yes
Q yes
Q yes
Q no
Q no
Q no
Q no
Describe the system:-
Are all storage tanks routinely monitored for leaks? If yes, describe procedure and monitoring frequency for
above-ground/vaulted tanks:
Underground tanks :-
How are the liquids in these tanks dispensed to the users? (i.e., in small containers or hard piped.).
What measures are employed to prevent the spillage of liquids being dispensed?-
When a spill of liquid occurs in the facility, what cleanup methods are employed (e.g., wet or dry)? Also discuss the way
in which the resulting wastes are handled: : ••
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Sheet 1 of 1 Page 4 of 10
WORKSHEET OPTION GENERATION:
3 Material Handling
Meeting Format (e.g., brainstorming, nominal group techni
Meeting Coordinator
que)
Meeting Participants
Suggested Waste Minimization Options
A. Drums, Containers, and Packages
Raw Material Inspection
Proper Storage/Handling
Return Obsolete Material to Supplier
Minimize Inventory
Computerize Inventory
Formal Training
Waste Segregation
B. Bulk Liquids Handling
High Level Shutdown/ Alarm
Flow Totalizers with Cutoff
Secondary Containment
Air Emission Control
Leak Monitoring
Currently
Done Y/N?
•
Rationale/Remarks on Option
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Waste Minimization Assessment
Proj. No.
WORKSHEET WASTE MINIMIZATION:
43 Parts Cleaning
A. SOLVENTS
Do you use parts cleaning solvent for uses other than cleaning parts?
Have you established guidelines as to
when parts should be cleaned with solvents?
Oo you use solvent sinks instead of pails or dunk buckets?
Are solvent sinks and/or buckets located near service bays?
Oo you allow cleaned parts to drain inside the sink for a few minutes to minimize
dripping of residual solvent onto the shop floor?
Are you careful when immersing and removing parts from the solvent bath so as
not to create splashes?
Do you keep all solvent sinks/buckets
Do you lease your solvent sinks?
If yes. does your lease include solvent
covered when not in use?
supply and spent solvent waste handling?
Prepared By
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Sheet 1 of 2 Page 5 of 10
3 yes Q no
U yes Q no
D yes Q no
D yes Q no
3 yes Q no
D yes Q no
D yes Q no
3 yes Q no
3 yes Q no
If you own your solvent sinks, does a registered waste hauler collect your dirty solvent
for recycling or treatment? U yes Q no
Do you own on-site solvent recovery e
If yes. how are the treatment residues
quipment such as a distillation unit?
hanrilori?
3 yes Q no
What other methods are you using to i
•educe solvent use/waste?
B. AQUEOUS CLEANERS
Do you use dry pre-cleaning methods
loading on the aqueous cleaner?
such as baking and/or wire brushing to reduce
3 yes Q no
Have you switched from caustic-based cleaning solutions to detergent-based cleaners? 3 yes Q no
Do you use drip trays on hot tanks to minimize the amount of cleaner dripped on the floor? Q yes Q no
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e. Waste Minimization Assessment p
f^
Pro]. No. fl
-. WASTE MINIMIZATION:
^" Parts Cleaning
•
B. AQUEOUS CLEANERS (continued)
Are the hot tanks/jet spray washers located near the service bays?
Do you pre-rinse dirty engine parts in a tank of dirty cleaning solution so as to reduce
loading oh the clean tank?
Oo you routinely monitor solution composition and make adjustment accordingly?
Oo you routinely remove sludge and solids from the tank?
Are sludge and solids screened out before they reach the waste sump?
Have you installed still rinses or converted free running rinses to still rinses? This
water can be used as make-up to your cleaner bath.
Oo you use demineralized water for your cleaning bath make-up ?
Is your cleaning tank agitated?
Oo you lease your hot tank(s)/jet spray washer(s)?
If yes, do you use mechanical agitation instead of air agitation?
Oo you own your hot tanks/jet spray washer(s)?
Do you own on-site aqueous waste treatment equipment?
Does a hazardous waste hauler collect aqueous waste for recycling or treatment?
If not. how is your waste handled and disposed of?
repared By
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heet 1 of 2 Page 6 of 10
Q yes G no
•
Q yes Q no
Q yes G no
Q yes Q no
Q yes Q no
G yes Q no
Q yes G no
G yes Q no
G yes Q no
G yes G no
G yes G no
G yes G no
G yes G no
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Waste Minimization Assessment
Proj. No.
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Sheet 1 of 1 Paae 7 of 10
OPTION GENERATION:
Parts Cleaning
Meeting Format (e.g., brainstorming, nominal group techn
Meeting Coordinator
Meeting Participants
ique)
Suggested Waste Minimization Options
A. Solvents
Proper solvent use
Established guidelines
Use solvent sinks
Careful drainage
Cover tanks
Lease equipment/service
Recycle solvent
B. Aqueous Cleaners
Dry pre-cleaning
Use detergents
Drip trays
Pre-rinse parts
Monitor solution
Remove sludge and solids
Employ still rinse
Use demineralized water
Use mechanical agitation
Lease equipment
Currently
Done Y/N?
Rationale/Remarks on Option
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p. Waate Minimization Aaaeaament p
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~ WASTE MINIMIZATION:
O« Waste Handling
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heet 1 of 2 Page 8 of 10
A. AUTOMOTIVE FLUIDS
For facilities servicing fleet vehicles, do you test fluid quality to determine when automotive
fluids should be changed? 3 yes 3 no
When fluids must be drained to service a part, are they stored in a clean container
so they may be used to refill the vehicle? 3 yes Q no
Have you had experience using any longer lasting synthetic motor oils? 3 yes 3 no
If yes. please discuss:
Are all waste fluids kept segregated? Q yes Q no
If no, have you notified your waste hauler or recycler? Q yes 3 no
Have you ever had a load of waste fluid rejected by a hauler or recycler because of
cross contamination? 3 yes 3 no
Please describe how you store and dispose of waste fluids (motor and lube oils, greases,
transmission fluids and spent anti-freezes)
B. OTHER WASTES
Are removed oil filters drained before disposal? 3 yes 3 no
Do you dispose of filters in the trash? 3 yes 3 no
If yes. have you contacted your waste oil hauler about alternative means of disposal? 3 yes 3 no
If yes, what was the response?
Does a battery collector remove your used batteries? 3 yes 3 no
Do you take used batteries to a storage or recycling facility? 3 yes 3 no
When replacing brakes, do you contain loose asbestos waste that may be released? 3 yes Q no
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WORKSHEET
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WASTE MINIMIZATION:
Waste Handling
B. OTHER WASTES (continued)
Do you use a collection/recycling system to service air conditioning units?
Do you sell or give worn parts to a re-manufacturer?
Do you have any suggestions for reducing other wastes?
C. SHOP CLEAN-UP
Are drip pans placed under leaking cars to reduce the need for floor cleaning?
Are dirty parts removed and placed on a drip pan instead of directly on the shop floor?
Are all work bays kept clean and neat?
Do your workers wipe up small spills of fluids as soon as they occur?
Do you have an award program for workers who keep their work bays clean
(i.e.: prevent leaks and spills)?
Do you use a laundry service to clean your rags and uniforms?
Do you use a biodegradible detergent for cleaning shop floors?
Have you tried using a steam cleaner in place of chemical cleaners?
Do you discharge area washdown wastewater to a POTW or industrial sewer,
instead of to the storm drain?
If no. how is this waste handled?
Q yes G no
Q yes G no
G yes
G yes
G yes
G yes
G yes
G yes
G yes
G yes
G no
G no
G no
G no
G no
G no
G no
G no
G yes G no
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Prepared By
Checked By
Sheet 1 Of 10 Pane 10 of 10
OPTION GENERATION:
Waste Handling
\
Meeting Format (e.g., brainstorming, nominal group techn
Meeting Coordinator
Meeting Participants
iquet
Suggested Waste Minimization Options
A. Automotive Fluids
Test fluid quality
Store fluids for reuse
Use longer lasting fluids
Keep wastes segregated
Send to recycler
V
B. Other Wastes
Drain filters and dispose properly
Recycle batteries
Collect asbestos dust
Collect/recycle refrigerant
Sell or give parts to re-manufacturer
C. Shop Clean-up
Use drip pans
Wipe up spills (cotton rags)
Keep bays dean
Award program
Use laundry service
Use biodegradible detergents
Use steam cleaners
Currently
Done Y/N?
Rationale/Remarks on Option
hlm/auto-rep/wsT
25
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Appendix A
Automotive Repair Shop Assessments
Case Studies of Shops A, B, and C
In 1987, the California Department of Health Services
(DHS) commissioned a waste minimization study of automo-
tive repair shops. The objectives of the waste minimization
assessments were to:
• Gather site-specific information concerning the gen-
eration, handling, storage, treatment, and disposal of
hazardous waste;
• Evaluate existing waste reduction practices;
• Develop recommendations for waste reduction
through source control, treatment, and recycling tech-
niques; and
• Assess costs and benefits of existing and recom-
mended waste reduction techniques.
The first step in conducting the assessments was selecting
and contacting several shops to solicit voluntary participation
in the study. Selection emphasized small businesses, which
generally lack the financial and/or internal technical resources
to perform a waste reduction assessment
This appendix presents a summary of the assessments
performed at three sites (here identified as Shops A, B, and
C). Shop A is an auto repair shop, shop B is a new car
dealership, and shop C is a parts washing lease and service
company. The third shop was included in the study because it
services a large segment of the automotive repair industry.
The original assessments may be obtained from Mr. Benjamin
Fries at:
California Department of Health Services
Alternative Technology Division
Toxic Substances Control Program
714/744 "P" Street
Sacramento, CA 94234-7320
(916) 324-1807
Following the assessments is an example set of com-
pleted waste minimization assessment worksheets. Informa-
tion presented in these worksheets is for a hypothetical
automotive repair shop. The answers to each question are
based on the author's experience regarding industry practices.
Shop A Assessment
Shop A is representative of many small to medium sized
auto repair shops. With IS years of auto engine repair and
maintenance experience, it represents an established auto
repair shop. The firm services approximately 20 cars per week
and uses one jet spray washer, 2 solvent buckets, and 1
carburetor cleaner bucket Shop A has 6 general maintenance
bays. Of the 20 cars per week serviced, 60 percent are for
transmission maintenance, 20 percent are for brake service, 10
.percent are for engine repair, and 10 percent are other.
Chemical Usage
Monthly chemical and raw material usage at Shop A
amounts to 10 gallons of parts cleaning solvent 25 pounds of
alkaline detergent, 8 gallons of carburetor cleaner, 11 gallons
of antifreeze solution, 60 gallons of engine oil, 2 bags (100
pounds) of sawdust and 3 lead-acid batteries.
Waste Generation
Monthly waste generation amounts at Shop A include 7
gallons of spent solvent 90 gallons of aqueous detergent 8
gallons of carburetor cleaner, 32 gallons of spent antifreeze,
55 gallons of waste engine oil, 110 pounds of spent sawdust,
and 3 spent lead-acid batteries. Spent acid batteries are cur-
rently being sent to a spent lead-acid battery processor.
Waste Minimization—Current Practices and
Recommendations
The following recommendations are suggested for waste
minimization at Shop A:
1. The most hazardous waste generated, aqueous deter-
gent wastes, is produced by the jet spray washer. The
current practice of servicing by the equipment leas-
ing company should be continued to properly dis-
pose and manifest wastes shipped off-site. The jet
spray washer in use provides good containment and
recovery of aqueous wastes high in heavy metal
contaminants.
2. Spent motor oils are stored in 8 miscellaneous con-
tainers ranging in size from 5 to 30 gallons. Spent oil
should be stored in one properly-designed container
26
-------
to avoid spills to the pavement and runoff to the
storm sewer. Waste engine oils are presently shipped
off-site by a licensed waste handler. Isolation of
spent solvent wastes and carburetor cleaner is neces-
sary to avoid contamination of waste oils.
3. Clean-up and maintenance of the back parts storage
and rear driveway service area will prevent oil and
grease run-off to the storm sewer.
4. Use solvent equipment leasing and maintenance ser-
vice. Costs range from $34 to $38 per month for a
sink with a recirculation system and spent solvent
pick-up and fresh solvent recharge. Current cost for
solvent purchase and disposal is $33 per month
excluding maintenance and transportation costs. Use
of on-site solvent recovery equipment is not recom-
mended at this level of solvent use.
5. The current method of disposal of carburetor cleaner
with the waste oil is unacceptable. Options include
purchase of the product from a supplier who pro-
vides disposal of the spent cleaner or disposal of the
spent solution at a toxic substances disposal facility.
6. Spent antifreeze solution should be accumulated in
SS-gallon drums and processed as a hazardous waste.
7. Sawdust should be properly disposed of as a diluted
hazardous waste. Options would include use of an
aqueous detergent-based cleaner and avoidance of
leaks and spills.
Shop B Assessment
Shop B is a large automotive dealership in Northern
California which services 500 cars and trucks per month in its
repair shop. Shop B uses two hot tanks, 10 solvent sinks, and
2 carburetor cleaners. Shop B has 25 general car maintenance
bays, 5 wheel alignment bays, and 9 auto painting bays. Of the
500 cars and tracks serviced each month, 30 to 35 percent are
for warranty repair work (light duty, noise), 25 percent are for
periodic maintenance, 10 to 12 percent are for engine repair,
10 percent are for tune-ups, and 16 to 18 percent are for other
(transmission, brakes, front-end, etc.).
Chemical Usage
Monthly chemical and raw material usage amounts to
100 gallons of parts cleaning solvent, 10 pounds of alkaline
detergent, 7 pounds of caustic soda, 10 gallons of carburetor
cleaner, 40 gallons of antifreeze solution, 330 gallons of
engine oil, 10 bags (500 pounds) of sawdust, and 10 lead-acid
batteries.
Waste Generation
Monthly waste generation amounts at Shop B include 80
gallons of spent solvent, 10 gallons of aqueous detergent
waste, 10 gallons of caustic detergent waste, 10 gallons of
carburetor cleaner, 100 gallons of spent antifreeze solution,
300 gallons of waste engine oil, 550 pounds of spent sawdust,
and 10 spent lead-acid batteries.
Waste Minimization—Current Practices and
Recommendations
The following recommendations are suggested for waste
minimization at Shop B:
1. General practice of leasing of solvent parts washers,
hot tanks, and agitator-type carburetor cleaners and
contracting for monthly maintenance with chemical
removal and fresh chemical make-up should be con-
tinued to minimize losses and maintain solution qual-
ity. Manifesting is being performed by equipment
service companies.
2. Spent antifreeze solution is being properly disposed
of by a waste management service.
3. Steam cleaning waste sump should be properly dis-
posed of to a Class I type of disposal site due to a'
high heavy metals content
4. Current practice of containment and recirculation of
solvent in parts washers provides minimum solvent
losses. Solvent sinks are serviced on a monthly basis.
Further economy could be achieved by use of an on-
site solvent recovery device, depending on cost of
labor.
5. The current practice of hot tank lease and mainte-
nance provides minimum losses and maintains solu-
tion activity.
Shop C Assessment
Shop C leases solvent sinks and parts washing equipment
to over 700 auto repair firms, ranging from large dealerships
to small repair shops. The company sells the solvents and
detergents used in its equipment, and recovers, processes, and
disposes of the waste materials produced. Shop C services 450
hot.tanks, 50 jet sprayers, and 460 solvent sinks. Periodic
maintenance of leased equipment is based upon:
• Hot Tanks and Jet Sprays:
Removal of an average of 10 gallons of spent mate-
rial from a 60 gallon batch of aqueous solution,
replenishment with water and recharge with 8-10 Ib
of alkali or detergent compounds.
• Solvent Sinks:
Removal of 7-8 gallons of spent solvent solution and
replacement of 10 gallons of fresh solvent
The volume of liquid required in each device to suspend
waste materials is dependent upon the type and degree of use,
and the frequency of servicing. The existing pattern of use for
hot tanks is primarily on a monthly service basis (75%).
Solvent sinks are serviced in the following proportions: 63%
monthly, 25% bimonthly, 12% every 3 months.
27
-------
Chemical Usage
Monthly chemical and raw materials supplied by Shop C
to their customers include 3700 gallons of parts cleaning
solvent, 1500 pounds of alkaline detergent, 500 pounds of
caustic detergent, and 30 gallons of carburetor cleaner.
Waste Generation
Monthly waste collection by Shop C amounts to 2200
gallons of spent solvent, 2000 gallons of aqueous and caustic
waste, and 13 gallons of carburetor cleaner.
Waste Minimization—Current Practices and
Recommendations
1. Drip trays should be provided oh solvent sinks to
increase recovery of spent solvents. Anticipated in-
crease in solvent recovery is expected to be 500
gallons per month.
2. Provide drip pan/cool down tray for parts cleaned in
hot tanks. Benefits would be improved repair shop
cleanliness and increased solvent recovery.
3. Repair fractured concrete pad to prevent ground
water contamination. Provide curbing and contain-
ment of run-off wastes from site for processing by
waste volume reduction.
4. The current method used to dispose of waste solvent
solutions by off-site processing fuel use could be
improved by installing on-site solvent recovery equip-
ment Anticipated benefits are recovery of 2000 gal-
lons per month of spent solvent and lower solvent
material costs.
5. Thecurrentmethodusedtodisposeofaqueouswastes,
separation of solids followed by municipal sewer
discharge, is unacceptable. The planned installation
of seven aqueous waste evaporation concentrators
should solve mis problem. Anticipated impacts are
compliance with local municipal sewer discharge
codes, lower off-site disposal costs, and increased
equipment and labor costs.
28
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Firm A^fl ^T0 - .
Site _ft^.YTow^ — U S>f> ...
Date ..
WORKSHEET
1
Wast* Minimization Assessment
Proi No
Prepared By
Checked By
Sheet 1 of
1 Dana 1 nf 1C\
WASTE SOURCES
Shop Clean-Up
Obsolete raw materials
Spills & leaks (llaulds & powders)
Dlrtv raqs & sawdust
Area wash water
Clarlfler sludaes
Container disposal
Pipeline/tank dralnaae
Evaporative losses
Parts Cleaning
Spent solvent cleaner
Spent carburetor and brake cleaner
Evaporative losses
Leaks and spills (solvents)
Spent alkaline cleaner
Leaks and spills (alkali)
Rinse water discharge
Sludaes and filter wastes
Maintenance and Repair
Motor oil
nil flltara
Qaaf and luh* all
"Tranvmlsalon fluid
Brake fluid
RaHlntnr coolant
Rrake.q faabaaiasl
Radlatnra (l«ad)
Rattorlas (laad and acid)
Junk parts
Significance at Shop
Low
X
X
^
A No^
X
XNoM
X
Medium
X
6
:
High
X
X
X
XHorf
XKioU
XK)6(0
X tOoiJ
X
i
f
£
X
x
X
X
X T>OK]
X
X
X
T forMfc
X
X
9/90
29
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Firm B ^ ^ Rufo Waste Minimization Assessment p
sita AMyTouM USA C
na»a "0|. NO. s
0 WASTE MINIMIZATION:
^3 Material Handling
repared By
hacked By
heet 1 of 2 Page 2 of 10
A. DRUMS, CONTAINERS, AND PACKAGES
Are drums, packages and containers inspected for damage before being accepted? Jo. yes G no
Are employees trained in ways to safely handle the types of drums and packages received? & yes G no
Are they properly trained in handling of spilled raw materials? JZ} yes G no
Is there a formal personnel training program on raw material handling, spill prevention
proper storage techniques, and waste handling procedures? G yes J2j no
Oasrriha handling procedures for damaged items: KloT ftCC£fiTft>. ^£7W/\)/<./£/£
How «*»«« « training git/an and by whom? Qu)>J fA VJtltH fV £.£&££>
Is obsolete raw material returned to the supplier?
Is inventory used in (irst-in first-out order?
Is the inventory system computerized?
Does the current inventory control system adequately prevent waste generation?
What information does the system track'
G yes $ no
ft yes Q no
G yes X) no
]2i yes Q no
Are stored items protected from damage, contamination, or exposure to rain,
snow, sun and heat?
Is the dispensing of raw materials supervised and controlled?
Are users required to return empty containers before being issued new supplies?
Do you maintain and enforce a clear policy of using raw materials only for their
intended use?
US) yes Q no
G yes $ no
Q yes & no
& yes Q no
htm/outo-f op/w*2a 9/90
30
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Firm A*/^ AofO Waste Minimization Assessment p
sit,, AMVTOUM US^ c
21 Hroj.No. S
0 WASTE MINIMIZATION:
^3 Material Handling
repared By
necked By
heet 1 of 2 Page 2 of 10
A. DRUMS, CONTAINERS, AND PACKAGES
Are drums, packages and containers inspected for damage before being accepted? Jo. yes Q no
Are employees trained in ways to safely handle the types of drums and packages received? & yes Q no
Are they properly trained in handling of spilled raw materials? (Zj yes Q no
Is there a formal personnel training program on raw material handling, spill prevention
proper storage techniques, and waste handling procedures? Q yes % no
Oa^rihA handling procedures for damaged items: f\) oT ftccef Tf£> . R £ TWA) £ £> To -So/>/L/££
How Often i$ lining giwon and by u/h«m? Qf^ M £ A . VJ H tfj fJ £.££>£&
Is obsolete raw material returned to the supplier?
Is inventory used in first-in first-out order?
Is the inventory system computerized?
Does the current inventory control system adequately prevent waste generation?
What information doos the system track9
Q yes {S no
& yes Q no
Q yes IK) no
ft yes Q no
Are stored items protected from damage, contamination, or exposure to rain,
snow, sun and heat?
Is the dispensing of raw materials supervised and controlled?
Are users required to return empty containers before being issued new supplies?
Do you maintain and enforce a clear policy of using raw materials only for their
intended use?
£) yes Q no
Q yes ft no
Q yes (& no
& yes Q no
htm/outo-f ep/w»2a 9/90
31
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ci,« Ar# Pluto
gjtt AMVTOoJAi (Js.fi
Data »•
WORKSHEET
3
Wast* Minimization Assessment
Proj No
Prepared By
Checked By
Sheet 1 of 1 Page 4 of 10
OPTION GENERATION:
Material Handling
Meeting Format (e.g., bralnstormlng, nominal group technl
Meeting Coordinator
Meeting Participants
que)
Suggested Waste Minimization Options
A. Drums, Containers, and Packages
Raw Material Inspection
Proper Storage/Handling
Return Obsolete Material to Supplier
Minimize Inventory
Computerize Inventory
Formal Training
Waste Segregation
B. Bulk Liquids Handling
High Level Shutdown/Alarm
Flow Totalizers with Cutoff
Secondary Containment
Air Emission Control
Leak Monitoring
Currently
Done Y/N?
r
Y
N
Y
14
M
Y
Y
Y
Y
Y
Y
Rationale/Remarks on Option
O&c AH. fl\fiTt(-i*LS (Doiciay
MOT Mfftoeo
S>*AIX 6Xoor" • 2. MttHA***-*
$ OUAJCA
fOCO GrAiOU/>J6 7>KM< jM$r
-------
Firm fl * A ROTO Waste Minimization Assessment
Site p)KiVTO^d O^A
nata Proj. No.
WORKSHEET WASTE MINIMIZATION:
43 Parts Cleaning
A. SOLVENTS
Do you use parts cleaning solvent for uses other than cleaning parts?
Have you established guidelines as to when parts should be cleaned with solvents?
Do you use solvent sinks instead of pails or dunk buckets?
Are solvent sinks and/or buckets located near service bays?
Do you allow cleaned parts to drain inside the sink for a few minutes to minimize
dripping of residual solvent onto the shop floor?
Are you careful when immersing and removing parts from the solvent bath so as
not to create splashes?
Do you keep all solvent sinks/buckets covered when not in use?
Do you lease your solvent sinks?
If yes, does your lease include solvent supply and spent solvent waste handling?
Prepared By
Checked By
SheetJ. of J2_ Page _S_of.HL
G yes
tt yes
$4 yes
)& yes
W yes
$ yes
W yes
& yes
Myw
]& no
G no
G no
G no
G no
G no
G no
G no
G no
If you own your solvent sinks, does a registered waste hauler collect your dirty solvent
for recycling or treatment?
Do you own on-site solvent recovery equipment such as a distillation unit?
If yes, hnvw ara tha treatment raftiduaa hanrilari? ...
G yea
G yes
G no
G no
What other methods are you usinq to reduce solvent use/waste?
B. AQUEOUS CLEANERS /\|/fl
Do you use dry pre-cleaning methods such as baking and/or wire brushing to reduce
loading on the aqueous cleaner? G yea
Have you switched from caustic-based cleaning solutions to detergent-based cleaners? G yes
Do you use drip trays on hot tanks to minimize the amount of cleaner dripped on the floor? G yes
G no
G no
G no
33
-------
,-i-_ A *f\ A u ro Waste Minimization Assessment p
Site n N 1 T0 "•> ^ * V^A. _ , C
^e n ,.vw i^n Rroj No s
- . WASTE MINIMIZATION:
^ *J Parts Cleaning
B. AQUEOUS CLEANERS (continued) f\j //)
Are the hot tanks/jet spray washers located near the service bays?
Do you pre-rinse dirty engine parts in a tank of dirty cleaning solution so as to reduce
loading on the clean tank?
Do you routinely monitor solution composition and make adjustment accordingly?
Do you routinely remove sludge and solids from the tank?
Are sludge and solids screened out before they reach the waste sump?
Have you installed still rinses or converted free running rinses to still rinses? This
water can be used as make-up to your cleaner bath.
Do you use demineralized water for your cleaning bath make-up ?
Is your cleaning tank agitated?
Do you lease your hot tank(s)/jet spray washer(s)?
If yes, do you use mechanical agitation instead of air agitation?
Do you own your hot tanks/jet spray washer(s)?
Do you own on-site aqueous waste treatment equipment?
Does a hazardous waste hauler collect aqueous waste for recycling or treatment?
If not, how is your waata handled and disposed of?
reparedBy
hacked By
heet 1 of 2 Page 6 of 10
•
Q yes 1) no
Q yes 3 no
Q yes Q no
Q yes Q no
Q yes Q no
Q yes Q no
Q yes Q no
Q yes Q no
Q yes Q no
Q yes Q no
Q yes Q no
Q yes Q no
Q yes G no
htm/OLito-f «p/wWb 9/90
34
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Pirm PttA AoTo Waste Minimization Assessment
Site AMV TttuJKi 0£fl
nata Proi- No.
Prepared By
Checked By
Sheet 1 of 1 Pane 7 of 10
WORKSHEET OPTION GENERATION:
£ Parts Cleaning
Meeting Format (e.g., bralnstormlng, nominal group techn
Meeting Coordinator
Ique)
Meeting Participants
Suggested Waste Minimization Options
A. Solvents
Proper solvent use
Established guidelines
Use solvent sinks
Careful drainage
Cover tanks
Lease equipment/service
Recycle solvent
B. Aqueous Cleaners
Dry. pre-cleaning
Use detergents
Drip trays
Pre-rinse parts
Monitor solution
Remove sludge and solids
Employ still rinse
Use demineralized water
Use mechanical agitation
Lease equipment
Currently
Done Y/N?
Y
Y
X
X
V
X
hi
N/A
Rationale/Remarks on Option
i
35
-------
Firm
Site
Date
A
O.Sn
Wast* Minimization Assessment
Proj. No.
Prepared By
Checked By .
Sheet J_ of _2_ Page_i_of 10
WORKSHEET
6a
WASTE MINIMIZATION:
Waste Handling
A. AUTOMOTIVE FLUIDS
For facilities servicing fleet vehicles, do you test fluid quality to determine when automotive
fluids should be changed?
When fluids must be drained to service a part, are they stored in a clean container
so they may be used to refill the vehicle?
Have you had experience using any longer lasting synthetic motor oils?
If yes, please discuss:
Q yes G no
Q yes
Q yes
Are all waste fluids kept segregated?
If no, have you notified your waste hauler or recycler?
Have you ever had a load of waste fluid rejected by a hauler or recycler because of
cross contamination?
Please describe how you store and dispose of waste fluids (motor and lube oils, greases,
transmission fluids and spent anti-freezes) Q As To
B. OTHER WASTES
Are removal oil filters drained before disposal?
;
Do you dispose of filters in the trash?
If yes, have you contacted your waste oil hauler about alternative means of disposal?
If yes, what was the) response?
Does a battery collector remove your used batteries?
Do you take used batteries to a storage or recycling facility?
When replacing brakes, do you contain loose asbestos waste that may be released?
no
no
Q no
no
$ yes Q no
)Z4 yes Q no
Q yes ft no
^ yes Q no
Q yes 2) no
ft yes Q no
36
-------
Fjrm Pi 4 A AuTo Watt* Minimization AM**«m*nt p
Sita PlN-/TOVj»^ L)SA n C
nl nN7' ^ *n Hro,.No. 3
WASTE MINIMIZATION:
OD Waste Handling
B. OTHER WASTES (continued)
Oo you use a collection/recycling system to service air conditioning units?
Do you sell or give worn parts to a re-manufacturer?
Do you have any suaaestions for reducing other wastes?
reparedBy
hecked By
heat 1 of 2 Page 9 of 10
Q yes & no
JS) yes 3 no
C. SHOP CLEAN-UP
Are drip pans placed under leaking cars to reduce the need for floor cleaning? Q yes & no
Are dirty parts removed and placed on a drip pan instead of directly on the shop floor? & yes Q no
Are all work bays kept clean and neat? (Zi yes Q no
Oo your workers wipe up small spills of fluids as soon as they occur? (2) yes Q no
Oo you have an award program for workers who keep their work bays clean
(i.e.: prevent leaks and spills)? Q yes JS) no
Oo you use a laundry service to clean your rags and uniforms? Q yes $3 no
Do you use a biodegradible detergent for cleaning shop floors? T>o«r K*J«-J Q yes Q no
Have you tried using a steam cleaner in place of chemical cleaners? Q yes ]& no
Do you discharge area washdown wastewater to a POTW or industrial sewer,
instead of to the storm drain? Q yes J4 no
If no. how is this wast* handled? r\u*Ji I>OUJM .s.7fcer ?o f£(.. )
37
-------
Pirm A* A /^u'o Waste Minimization Assessment ,
gift p\-MfTOu.O 05 A
Dato P^j No
Prepared By
Checked By
Sheet 1 of 10 Pace 10 of 10
WORKSHEET OPTION GENERATION:
"7 Waste Handling
Meeting Format (e.g., bralnstormlng, nominal group techn
Meeting Coordinator
Iquel
Meeting Participants
Suggested Waste Minimization Options
A. Automotive Fluids
Test fluid quality
Store fluids for reuse
Use longer lasting fluids
Keep wastes segregated
Send to recycler
B. Other Wastes
Drain Filters and dispose properly
Recycle batteries
Collect asbestos dust
Collect/recycle refrigerant
Sell or give parts to re-manufacturer
C. Shop Clean-up
Use drip pans
Wipe up spills (cotton rags)
Keep bays clean
Award program
Use laundry service
Use biodegradible detergents
Use steam cleaners
Discharge to POTW/industrial sewer
Currently
Done Y/N?
rt
IS)
tsi
1
y
X
V
v
M
X
Y
Y
Y
K
^
N
Ki
rt
Rationale/Remarks on Option
Cos70M«£ QtDtte U3o/<
MIGHT POOL FLOID
Mio-^r f^ccfoMc/oo To Cji~
£x/)<5AiJ'«€ •
U)it-(_ T/Y
U)|(_U COAiS/Ofr^
Mcto To c^6c<
T5erf/-0-tfA»r os6 /s »i/\»oX
£xr°e*JS/U6 /Mor rtfQoi
-------
Appendix B
Where to Get Help
Further Information on Pollution Prevention
Additional information on source reduction, reuse and
recycling approaches to pollution prevention is available in
EPA reports listed in this section, and through state programs
and regional EPA offices (listed below) that offer technical
and/or financial assistance in the areas of pollution prevention
and treatment
Waste exchanges have been established in some areas of
the U.S. to put waste generators in contact with potential users
of the. waste. Twenty-four exchanges operating in the U.S. and
Canada are listed.
U.S. EPA Reports on Waste Minimization
Waste Minimization Opportunity Assessment Manual. EPA/
625/7-88/003.*"
Waste Minimization Audit Report: Case Studies of Corrosive
and Heavy Metal Waste Minimization Audit at a
Specialty Steel Manufacturing Complex. Executive
Summary. NTIS No. PB88-107180*
Waste Minimization Audit Report: Case Studies of Minimi-
zation of Solvent Waste for Parts Cleaning and from
Electronic Capacitor Manufacturing Operation.
Executive Summary. NTIS No. PB87-227013*
Waste Minimization Audit Report: Case Studies of Minimi-
zation of Cyanide Wastes from Electroplating Opera-
tions. Executive Summary. NTIS No. PB87-229662.*
Report to Congress: Waste Minimization, Vols.Iandll.
EPA/530-SW-86-033 and -034 (Washington,
D.C.:U.S£PA,1986).M
Waste Minimization - Issues and Options, Vols. I-III EPA/
530-SW-86-041 through -043. (Washington, D.C.:
U.S.EPA.1986."
Executive Summaiy available from EPA, CERI Publication! Unit, 26
West Martin Lather King Drive, Cincinnati, OH, 45268; full report
available from the National Technical Information Service (NTIS), U.S.
Department of Commerce, Springfield, VA 22161.
Available from the National Technical Information Service as a five-
volume set, NTIS No.PB-87-114328.
' Available from EPA, CERI Publications Unit, 26 West Martin Luther
King Drive, Cincinnati, OH 45268. (513) 569-7562.
The Guides to Pollution Prevention manuals'" describe
waste minimization options for specific industries. This is a
continuing series which currently includes the following titles:
Guides to Pollution Prevention Paint Manufacturing
Industry. EPA/625/7-90/005
Guides to Pollution Prevention The Pesticide Formulating
Industry. EPA/625/7-90/004
Guides to Pollution Prevention The Commercial Printing
Industry. EPA/625/7-90/008
Guides to Pollution Prevention The Fabricated Metal
Industry. EPA/625/7-90/006
Guides to Pollution Prevention For Selected Hospital Waste
Streams. EPA/625/7-90/009
Guides to Pollution Prevention Research and Educational
Institutions. EPA/625/7-90/010
Guides to Pollution Prevention The Printed Circuit Board
Manufacturing Industry. EPA/625/7-90/007
Guides to Pollution Prevention The Pharmaceutical Indus-
try. EPA/625/7-91/017
Guides to Pollution Prevention The Photoprocessing
Industry. EPA/625/7-91/012
Guides to Pollution Prevention The Fiberglass Reinforced
and Composite Plastic Industry. EPA/625/7-91/014
Guides to Pollution Prevention The Automotive Reflnishing
Industry. EPA/625/7-91/016
Guides to Pollution Prevention The Marine Repair Industry.
EPA/625/7-91/015
U.S. EPA Pollution Prevention Information Clearinghouse
(PPIC): Electronic Information Exchange System
(EIESh-User Guide, Version 1.1. EPA/600/9-89/086
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Waste Reduction Technical/Financial
Assistance Programs
The EPA Pollution Prevention Information Clearinghouse
(PPIC) was established to encourage waste reduction through
technology transfer, education, and public awareness. PPIC
collects and disseminates technical and other information
about pollution prevention through a telephone hotline and an
electronic information exchange network. Indexed bibliogra- Arkansas
Alaska
Alaska Health Project
Waste Reduction Assistance Program
431 West Seventh Avenue, Suite 101
Anchorage, AK 99501
(907) 276-2864
phies and abstracts of reports, publications, and case studies
about pollution prevention are available. PPIC also lists a
calendar of pertinent conferences and seminars; information
about activities abroad and a directory of waste exchanges. Its
Pollution Prevention Information Exchange System (PIES)
can be accessed electronically 24 hours a day without fees.
For more information contact:
PIES Technical Assistance
Science Applications International Corp.
8400 Westpark Drive
McLean, VA 22102
(703) 821-4800
or
U.S. Environmental Protection Agency
401M Street S.W.
Washington, D. C. 20460
Myles E. Morse
Office of Environmental Engineering
and Technology Demonstration
(202) 475-7161
Priscilla Flattery
Pollution Prevention Office
(202)245-3557
The EPA's Office of Solid Waste and Emergency Re-
sponse has a telephone call-in service to answer questions
regarding RCRA and Superfund (CERCLA). The telephone
numbers are:
(800) 242-9346 (outside the District of Columbia)
(202) 382-3000 (in the District of Columbia)
The following programs offer technical and/or financial
assistance for waste minimization and treatment
Alabama
Hazardous Material Management and Resources
Recovery Program
University of Alabama
P.O. Box 6373
Tuscaloosa, AL 35487-6373
(205) 348-8401
Arkansas Industrial Development Commission
One State Capitol Mall
Little Rock, AR 72201
(501) 371-1370
California
Alternative Technology Division
Toxic Substances Control Program
California State Department of Health Services
714/744 P Street
Sacramento, CA 94234-7320
(916) 324-1807
Connecticut
Connecticut Hazardous Waste Management Service
Suite 360
900 Asylum Avenue
Hartford, CT 06105
(203) 244-2007
Connecticut Department of Economic Development
210 Washington Street
Hartford, CT 06106
(203) 566-7196
Florida
Waste Reduction Assistance Program
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee. FL 32399-2400
(904)488-0300
Georgia
Hazardous Waste Technical Assistance Program
Georgia Institute of Technology
Georgia Technical Research Institute
Environmental Health and Safety Division
O'Keefe Building, Room 027
Atlanta, GA 30332
(404) 894-3806
Environmental Protection Division
Georgia Department of Natural Resources
Floyd Towers East, Suite 1154
205 Butler Street
Atlanta, GA 30334
(404) 656-2833
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Guam
Solid and Hazardous Waste Management Program
Guam Environmental Protection Agency
ITCE E. Harmon Plaza, Complex Unit D-107
130 Rojas Street
Harmon. Guam 96911
(671) 646-8863
Illinois
Hazardous Waste Research and Information Center
Illinois Department of Energy and Natural Resources
1808 Woodfield Drive
Savoy, IL 61874
(217)333-8940
Illinois Waste Elimination Research Center
Pritzker Department of Environmental Engineering
Alumni Building, Room 102
Illinois Institute of Technology
3200 South Federal Street
Chicago, EL 60616
(313)567-3535
Indiana
Environmental Management and Education Program
Young Graduate House, Room 120
Purdue University
West Lafayette, IN 47907
(317) 494-5036
Indiana Department of Environmental Management
Office of Technical Assistance P.O. Box 6015
105 South Meridian Street
Indianapolis, IN 46206-6015
(317) 232-8172
Iowa
Center for Industrial Research and Service
205 Engineering Annex
Iowa State University
Ames, IA 50011
(515) 294-3420
Iowa Department of Natural Resources
Air Quality and Solid Waste Protection Bureau
Wallace State Office Building
900 East Grand Avenue
Des Moines, IA 50319-0034
(515) 281-8690
Kansas
Bureau of Waste Management
Department of Health and Environment
Forbesfield, Building 730
Topeka, KS 66620
(913) 269-1607
Kentucky
Division of Waste Management
Natural Resources and Environmental Protection Cabinet
18 Reilly Road
Frankfort, KY 40601
(502) 564-6716
Louisiana
Department of Environmental Quality
Office of Solid and Hazardous Waste
P.O. Box 44307
Baton Rouge, LA 70804
(504) 342-1354
Maryland
Maryland Hazardous Waste Facilities Siting Board
60 West Street, Suite 200 A
Annapolis, MD 21401
(301) 974-3432
Maryland Environmental Service
2020 Industrial Drive
Annapolis, MD 21401
(301) 269-3291
(800) 492-9188 (in Maryland)
Massachusetts
Office of Safe Waste Management
Department of Environmental Management
100 Cambridge Street, Room 1094
Boston, MA 02202
(617) 727-3260
Source Reduction Program
Massachusetts Department of Environmental Quality
Engineering
1 Winter Street
Boston, MA 02108
(617) 292-5982
Michigan
Resource Recovery Section
Department of Natural Resources
P.O. Box 30028
Lansing, MI 48909
(517) 373-0540
Minnesota
Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road
St. Paul, MN 55155
(612) 296-6300
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Minnesota Technical Assistance Program
1313 5th Street SE Suite 207
Minneapolis, MN 55455
(612)627-4555
(800) 247-0015 (in Minnesota)
Missouri
State Environmental Improvement and Energy
Resources Agency
P.O. Box 744
Jefferson City, MO 65102
(314) 751-4919
New Jersey
New Jersey Hazardous Waste Facilities Siting
Commission
Room 614
28 West State Street
Trenton, NJ 08608
(609) 292-1459
(609) 292-1026
Hazardous Waste Advisement Program
Bureau of Regulation and Classification
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
(609) 292-8341
Risk Reduction Unit
Office of Science and Research
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
(609) 984-6070
New York
New York State Environmental Faculties Corporation
50 Wolf Road
Albany, NY 12205
(518)457-3273
North Carolina
Pollution Prevention Pays Program
Department of Natural Resources and Community
Development
P.O. Box 27687
512 North Salisbury Street
Raleigh, NC 27611
(919) 733-7015
Qovemor's Waste Management Board
325 North Salisbury Street
Raleigh, NC 27611
(919) 733-9020
Technical Assistance Unit
Solid and Hazardous Waste Management Branch
North Carolina Department of Human Resources
P.O. Box 2091
306 North Wilmington Street
Raleigh, NC 27602
(919)733-2178
Ohio
Division of Solid and Hazardous Waste Management
Ohio Environmental Protection Agency
P.O. Box 1049
1800 WaterMark Drive
Columbus, OH 43266-1049
(614)481-7200
Ohio Technology Transfer Organization
Suite 200
65 East State Street
Columbus, OH 43266-0330
(614) 466-4286
Oklahoma
Industrial Waste Elimination Program
Oklahoma State Department of Health
P.O. Box 53551
Oklahoma City, OK 73152
(405) 271-7353
Oregon
Oregon Hazardous Waste Reduction Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland, OR 97204
(503) 229-5913
Pennsylvania
Pennsylvania Technical Assistance Program
501 F. Orvis Keller Building
University Park, PA 16802
(814) 865-0427 ;
Center of Hazardous Material Research
320 William Pitt Way
Pittsburgh, PA 15238
(412) 826-5320
Bureau of Waste Management
Pennsylvania Department of Environmental Resources
P.O. Box 2063
Fulton Building
3rd and Locust Streets
Harrisburg,PA17120
(717) 787-6239
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Rhode Island
Ocean State Cleanup and Recycling Program
Rhode Island Department of Environmental Management
9 Hayes Street
Providence, RI02908-5003
(401) 277-3434
(800) 253-2674 (in Rhode Island)
Center for Environmental Studies
Brown University
P.O. Box 1943
135 Angell Street
Providence, RI 02912
(401) 863-3449
Tennessee
Center for Industrial Services
102 Alumni Hall
University of Tennessee
Knoxville,TN 37996
(615) 974-2456
Virginia
Office of Policy and Planning
Virginia Department of Waste Management
llth Floor, Monroe Building
101 North 14th Street
Richmond, VA 23219
(804) 225-2667
Washington
Hazardous Waste Section
Mail Stop PV-11
Washington Department of Ecology
Olympia,WA 98504-8711
(206)459-6322
Wisconsin
Bureau of Solid Waste Management
Wisconsin Department of Natural Resources
P.O. Box 7921
101 South Webster Street
Madison, WI53707
(608) 267-3763
Wyoming
Solid Waste Management Program
Wyoming Department of Environmental Quality
Herchler Building, 4th Floor, West Wing
122 West 25th Street
Cheyenne, WY 82002
(307) 777-7752
Waste Exchanges
Alberta Waste Materials Exchange
Mr. William C. Kay
Alberta Research Council
Post Office Box 8330
Postal Station F
Edmonton, Alberta
CANADA T6H 5X2
(403)450-5408
British Columbia Waste Exchange
Ms. Judy Toth
2150 Maple Street
Vancouver, B.C.
CANADA V6J 3T3
(604) 731-7222
California Waste Exchange
Mr. Robert McCormick
Department of Health Services
Toxic Substances Control Program
Alternative Technology Division
Post Office Box 942732
Sacramento, CA 94234-7320
(916) 324-1807
Canadian Chemical Exchange41
Mr. Philippe LaRoche
P.O. Box 1135
Ste-Adele, Quebec
CANADA JORILO
(514)229-6511
Canadian Waste Materials Exchange
ORTECH International
Dr. Robert Laughlin
2395 Speakman Drive
Mississauga, Ontario
CANADA L5KIB3
(416) 822-4111 (Ext 265)
FAX: (416) 823-1446
Enstar Corporation1"
Mr. J.T. Engster
P.O. Box 189
Latham, NY 12110
(518) 785-0470
Great Lakes Regional Waste Exchange
400 Ann Street N.W., Suite 201A
Grand Rapids, MI 49505
(616) 363-3262
* Far-Profit Wute Information Exchange
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Indiana Waste Exchange
Dr. Lynn A. Carson
Purdue University
School of Civil Engineering
Civil Engineering Building
West Lafayette, IN 47907
(317)494-5036
Industrial Materials Exchange
Mr. Jerry Henderson
172 20th Avenue
Seattle, WA 98122
(206)296-4633
FAX: (206) 296-0188
Industrial Materials Exchange Service
Ms. Diane Shockey
Post Office Box 19276
Springfield, IL 62794-9276
(217) 782-0450
FAX: (217) 524^193
Industrial Waste Information Exchange
Mr. William E. Payne
New Jersey Chamber of Commerce
5 Commerce Street
Newark, NJ 07102
(201) 623-7070
Manitoba Waste Exchange
Mr. James Ferguson
c/o Biomass Energy Institute, Inc.
1329 Niakwa Road
Winnipeg, Manitoba
CANADA R2J3T4
(204)257-3891
Montana Industrial Waste Exchange
Mr. Don Ingles
Montana Chamber of Commerce
P.O. Box 1730
Helena, MT 59624
(406)442-2405
New Hampshire Waste Exchange
Mr. Gary J. Olson
c/oNHRRA
P.O. Box 721
Concord, NH 03301
(603) 224-69%
Northeast Industrial Waste Exchange, Inc.
Mr. Lewis Cutter
90 Presidential Plaza, Suite 122
Syracuse, NY 13202
(315)422-6572
FAX: (315) 422-9051
Ontario Waste Exchange
ORTECH International
Ms. Linda Varangu
2395 Speakman Drive
Mississauga, Ontario
CANADA L5K 1B3
(416) 822-4111 (Ext 512)
FAX: (416) 823-1446
Pacific Materials Exchange
Mr. Bob Smee
South 3707 Godfrey Blvd.
Spokane, WA 99204
(509) 623-4244
Peel Regional Waste Exchange
Mr. Glen Milbury
Regional Municipality of Peel
10 Peel Center Drive
Brampton, Ontario
CANADA L6T4B9
(416) 791-9400
Renew
Ms. Hope Castillo
Texas Water Commission
Post Office Box 13087
Austin, TX 78711-3087
(512)463-7773
FAX: (512) 463-8317
San Francisco Waste Exchange
Ms. Portia Sinnott
2524 Ben venue #35
Berkeley, CA 94704
(415) 548-6659
Southeast Waste Exchange
Ms. Maxie L. May
Urban Institute
UNCC Station
Charlotte, NC 28223
(704) 547-2307
Southern Waste Information Exchange
Mr. Eugene B. Jones
Post Office Box 960
Tallahassee, PL 32302
(800) 441-SWK (7949)
(904) 644-5516
FAX: (904) 574-6704
Tennessee Waste Exchange
Ms. Patti Christian
226 Capital Blvd., Suite 800
Nashville, TN 37202
(615) 256-5141
FAX: (615) 256-6726
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Wastelink, Division of Tencon, Inc.
Ms. Mary E. Malotke
140 Wooster Pike
Milford, OH 45150
(513) 248-0012
FAX: (513) 248-1094
U.S. EPA Regional Offices
Region 1 (VT, NH, ME, MA, CT, RI)
John F. Kennedy Federal Building
Boston, MA 02203
(617) 565-3715
Region 2 (NY, NJ)
26 Federal Plaza
New Yoik, NY 10278
(212) 264-2525
Region 3 (PA, DE, MD, WV, VA)
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800
Region 4 (KY, TN, NC, SC, GA, FL, AL. MS)
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727
Region 5 (WI, MN, MI, EL, IN, OH)
230 South Dearborn Street
Chicago, IL 60604
(312)353-2000
Region 6 (MM, OK, AR, LA, TX)
1445 Ross Avenue
Dallas, TX 75202
(214) 655-6444
Region 7 (NE, KS, MO. IA)
756 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2800
Region 8 (MT, ND, SD, WY, UT, CO)
999 18th Street
Denver, CO 80202-2405
(303)293-1603
Region 9 (CA, NV, AZ, HI)
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1305
Region 10 (AK, WA, OR, ID)
1200 Sixth Avenue
Seattle, WA 98101
(206)442-5810
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TECHNICAL REPORT DATA
(Please read Inttrucnons on the revtne before completing)
REPORT NO.
EPA/625/7-91/013
3. RECIPIENT'S ACCESSION NO.
PB91-227975
4. TITLE AND SUBTITLE
GUIDES TO POLLUTION PREVENTION
THE AUTO REPAIR INDUSTRY
5. REPORT DATE
. Oct.ober. .1391
6. PERFORMING ORGANIZATION CODE
7. AUTHOH(S)
Jacobs Engineering Group, Inc.
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Jacobs Engineering Group, Inc.
Pasadena, California 91101-3063
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D8-0112
12. SPONSORING AGENCY NAME AND ADDRESS
Risk Reduction Engineering Laboratory—Gin., OH
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
13. TYPE OF REPORT AND PERIOD COVERED
Guidance Manual
14. SPONSORING AGENCY CODE
EPA/600/14
IS. SUPPLEMENTARY NOTES
Project Officer: Teresa Harten
FTS: 684-7565 Comm. 513/569-7565
16. ABSTRACT
Automotive maintenance and repair shops generate a variety of waste streams during
activities such as replacing fluids (e.g., motor oil, radiator coolant, transmission
fluid, brake fluid), replacing non-repairable parts (e-9-> brake shoes/pads, shocks,
batteries, belts, mufflers, electrical components, water pumps) and repairing fixable
parts (e.g., brake calipers/rotors/drums, alternators, fuel pumps, carburetors, power
train components). Of small quantity generators of hazardous waste in the nation,
the automotive repair industry leads in number of generators and in quantity of total
waste produced. Many opportunities exist to reduce the oils, sludges, and solvent
and aqueous cleaning wastes that are generated.
This guide describes the typical waste generating processes of the industry as
well as source reduction and/or recycling options for each. The guide also includes
a set of worksheets which take the user step-by-step through an analysis of the on-
site waste generating activities and the possibilities for minimizing each waste.
Besides .its obvious usefulness to owners and operators of auto repair shops, the
guide would also be instructive to environmental consultants serving the automotive
repair industry and government agencies who regulate waste streams generated by these
shops.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a.
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
COS AT) Field/Group
Hazardous materials
Materials recovery
Automative maintenace
waste; automative repair
waste; motor oil recycle
/recovery; pollution pre-
vention waste minimizatior
waste reduction; source
reduction; waste reductior
worksheets
18. DISTRIBUTION STATEMENT
Release to Public
19. SECURITY CLASS iTIui Reparti
Unclassified
21. NO. OF PAGES
i. SECURIJY CLASS (This paiffl
assified
22. PRICE
EPA Form 2220-1 (R««-4-77) PHKVIOUS EDITION is OBSOLETE
46
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