United States
Environmental Protection
Agency
EPA-910-K-13-001 I www.epa.gov
Used Oil and Hazardous
Waste Management
For Auto and Aircraft Repair Shops in Alaska
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Used Oil and Hazardous
Waste Management
For Auto and Aircraft Repair Shops in Alaska
Used oil can contain toxic chemicals and heavy metals and is insoluble in water. It's slow to degrade
and sticks to everything from beach sand to bird feathers, polluting drinking water sources and
harming humans, wildlife, and aquatic life. Hazardous waste can be even more toxic, even in small
volumes. Toxic chemicals in hazardous wastes can accumulate in the tissues of animals that consume
contaminated water and ultimately end up in the food we eat. To reduce the risks of pollution to our
water and land, the US Environmental Protection Agency (EPA) has established rules for managing
used oil and hazardous waste.
Proper waste management will reduce risks to human health and the environment and your risk of
being fined for not following EPA regulations. This guide will help you avoid some of the more
common waste management problems. Unfortunately, it does not cover all the information you will
need to ensure you are in compliance with applicable regulations.
Questions?
If you have questions about used oil and hazardous waste management that are not addressed in this
guide, a useful reference is EPA's Consolidated Screening Checklist for Automotive Repair Facilities
Guidebook (EPA 305-B-03-004): www.epa.gov/Compliance/resources/publications/assistance/
sectors/autoguide 1297 .pdf
If you still have questions, contact:
• EPA Region 10 office: www.epa.gov/region 10/engine_repair_waste.html
• CCARGreenLink ® Compliance Assistance Center: www.ccar-greenlink.org
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
January 2013
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Disclaimer
This guide was developed to provide automotive and aircraft repair shops in Alaska with a summary of how to avoid the
issues and problems EPA inspectors see most often during inspections. It is not intended to create rights for any party,
nor does it replace any federal regulations or statutory requirements. It does not identify all of the requirements in the
waste management regulations. Automotive and aircraft repair shops should not rely on this document to determine full
compliance with the regulations. This guide presents a "best management practices" approach to waste management with
the intent to simplify complex rules. There may be exclusions or regulatory relief that applies to you that is not covered
in this guide. To learn more, see 40 CFR 260-262, 266, 268, 273 and 279 and www.epa.gov/lawsregs/laws/rcra.html. You
are responsible for complying with all applicable federal used oil and hazardous waste regulations. In addition, your shop
is responsible for knowing and complying with any state, local, and tribal requirements that may apply. If you run a shop
outside of Alaska, check with the hazardous waste agency in your state to learn about the regulations that apply to you.
Hazardous waste and used oil management rules may be amended in the future. The contents of this guide are current as
of December 2012.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Test your Knowledge
Do you know what to do with shop rags, aerosol cans, used oil, and other wastes that come from your
shop? Test your knowledge. The answers are on the next page.
1. I can label containers of used oil with the words:
a. Waste
b. Waste Oil
c. Used Oil
d. Any of the above
2. Used oil that I generate at my shop can be burned in a space heater in my shop.
a. true
b. false
3. The maximum number of gallons of used oil I can transport to a collection center in my car
or truck is:
a. 20
b. 35
c. 55
4. Used shop rags should be:
a. Burned
b. Recycled
c. Laundered
d. Thrown in the garbage
5. I can recycle empty, depressurized aerosol cans.
a. true
b. false
6. My hazardous waste generator class is determined by the amount of hazardous waste my
shop generates:
a. per day
b. per month
c. per year
7. It is okay to burn used shop rags if they have used oil on them.
a. true
b. false
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
January 2013
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Answers:
1. C. Used oil containers should only contain used oil and need to be labeled as "used oil." It is
important not to label containers with other words such as "waste oil" because the regulations
require it to be labeled as "used oil" and the company that receives your waste may assume
that the oil is contaminated with other waste. Used oil that is not contaminated with other
waste can be recycled.
2. True. Used oil can be burned in your shop if you generated the used oil and if the heater has a
maximum capacity of 500,000 Btu per hour and combustion gases from the heater are vented
to the outside air. Check the rating on the heater. Used oil that someone else generated can
be burned in your shop without a permit only if it is from a household do-it-yourself used
oil generator or if the oil meets used oil specifications found in Table 3 of this guide. See the
section of this guide related to burning used oil.
3. C. You can transport 55 gallons in your car or truck to a collection center. If you transport
more than 55 gallons at a time then you become a used oil transporter and are required to
notify EPA that you are a transporter of used oil, obtain an EPA RCRA ID number, and
comply with rules for used oil transporters.
4. It depends on what is on them and whether they are dripping1 wet. See Table 2 and the Shop
Rag section of this guide.
5. True. Pressurized aerosol cans cannot be thrown in the trash. Aerosol cans should be
punctured safely with a puncturing device and drained into a container. EPA recommends that
empty, depressurized cans be recycled as scrap metal.
6. B. Generator class is determined by amount of waste generated per month. Your class can
also change if you exceed the maximum amount of waste accumulated at your shop for your
generator class. For more information see Table 1 in the Determine Your Hazardous Waste
Generator Class section of this guide.
7. It depends on whether or not the rags have also been used to soak up hazardous waste
solvents or other hazardous waste. If the rag has only been used to clean up used oil, then
yes, you can burn the rag in a space heater in your shop. If the rag also has hazardous waste
on it, then the rag cannot be burned in your shop. You can launder your used rags instead of
burning them (see the What to Do With Shop Waste section of this guide).
1 Any time the word "dripping" is used in this document, it means 'Visible signs of free flowing" as specified in the RCRA used oil
regulations.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Key Steps in Used Oil and
Hazardous Waste Management
Whether you are new to the business or if you have run an engine repair shop for years, it is useful to
review these steps to ensure you have a good system for managing used oil and hazardous waste:
1. Identify all of the wastes in your shop and determine if they are hazardous waste, universal
waste, used oil, or waste that can be disposed of in the garbage
2. Count by weight all the hazardous waste that your shop generates each month and keep a
record of your calculation
3. Set up a good container system with labels for your different types of waste and train
everyone in your shop on the system
4. Determine what your options are for recycling or disposing of each of your wastes
5. Look at ways to reduce your waste and to reduce the hazards of your waste
Don't stop at these steps alone. The rest of this guide will tell you more about how to properly manage
your different types of waste.
Different Types of Waste
There are three main categories of waste that are
discussed in this guide:
1. Hazardous waste
2. Used oil
3. Universal waste
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
January 2013
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Identify All of the Hazardous
Waste in Your Shop
To safely manage the wastes in your shop and to ensure you are in compliance, it is important to
determine if a waste you have is a hazardous waste. Wastes that exhibit one or more of the following
TRIG characteristics are hazardous waste:
Toxic: Waste that is toxic is harmful when taken into the body. It may leach toxic chemicals
into the soil or groundwater when disposed of on the land. Examples include wastes that contain
benzene, trichloroethylene, perchlorethylene or metals, such as chromium, cadmium, lead, or
mercury. These may be found in used cleaning solvents. The metals may also be found in used
antifreeze. To determine if your waste exhibits the toxicity characteristic, have it tested by an
environmental laboratory that uses the Toxicity Characteristic Leaching Procedure (TCLP)
if you can't otherwise reliably make a determination based on existing information about the
waste. For a complete list of toxic characteristic wastes, see the appendix of this guide.
Reactive: Waste that is reactive is unstable or undergoes a rapid, violent chemical reaction
when in contact with water or other materials. Examples of wastes that may be reactive include
fireworks, explosives, and sodium metal.
Ignitable: Waste that is ignitable includes most liquid waste that has a flash point2 of less than
140 degrees Fahrenheit, non-liquid waste that can create fire under certain conditions (e.g.,
temperature, pressure), and waste that is spontaneously combustible. Degreasers and solvents
may be ignitable.
Corrosive: Water-based liquid waste is corrosive if it has a pH less than or equal to 2 or
greater than or equal to 12.5. This includes liquid waste that corrodes steel at a specified rate.
Shop wastes that may be corrosive include acid cleaning fluids, alkaline cleaning fluids, and
battery acid.
The flash point for any hazardous material is listed on the Material Safety Data Sheet (MSDS) that is provided from your product
vendor. However, depending on how it was used and what it might have been mixed or contaminated with, the waste material
may have a different flash point. Flash point is determined in the lab using a specially designed instrument to measure ignition
temperature.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Tools for Hazardous Waste
Identification
Know which of your wastes are hazardous
waste, used oil, or universal waste so you can
manage them properly
Examine all of the waste in your shop to determine which ones
exhibit one or more of the TRIG characteristics. To help you
determine if your waste qualifies as hazardous waste, use the
following three sources of information:
1. Reference the Environmental Management section
of the Material Safety Data Sheet (MSDS) for the
product to see if, when wasted, the unused product
is a hazardous waste. The MSDS may contain actual
waste codes or information about the characteristics
of the waste that will help you determine if it is
hazardous. If you don't have an MSDS, they are
available online on the manufacturer's website. Since
the format for MSDSs are different, the MSDS may
not give you the information that you need. Also, be
aware that it is possible that your waste may become
hazardous through its use. Some products become
hazardous as wastes because they have become more
concentrated or pick up chemicals through use. For example, antifreeze may pick up lead
from the solder in the radiator and cooling system. So, the MSDS may not give you all the
information you need.
2. Look at the product label to determine if the waste contains chemicals that are on the Toxic
Characteristic Leaching Procedure (TCLP) list (see the appendix of this guide). Be aware
that product labels do not necessarily list all of the ingredients and the ingredients may have
different names than what is on the TCLP list.
3. Review EPA's lists of hazardous waste, at www.epa.gov/osw/hazard/wastetypes/listed.htm.
These lists are organized by use or by industry and contain common materials that exhibit the
TRIG characteristics. Some used solvents are on the F list and some unused products may be
on the U or P lists when disposed of. The lists will not include all of the hazardous waste that
may be in your shop. There may be wastes in your shop that exhibit the TRIG characteristics
that are not on these lists.
If you still are not able to determine if the waste you have qualifies as hazardous waste, you can send
a sample of your waste to an environmental laboratory. The lab will tell you how to properly obtain a
sample to send to the lab.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
January 2013
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Determine Your Hazardous
Waste Generator Size
(or Generator Class)
If any of your wastes are hazardous waste, then you are a "hazardous waste generator," and you'll
need to determine your "generator class" to know which EPA requirements apply to you. A generator
class is an EPA designation that is based on the amount of hazardous waste your shop generates in one
month. Your generator class could change from month to month. The three classifications are:
1. Conditionally-Exempt Small Quantity Generators (CESQG) = less than 220 Ibs/month
2. Small Quantity Generators (SQG) = between 220 Ibs/month and 2,200 Ibs/month
3. Large Quantity Generators (LQG) = greater than 2,200 Ibs/month
To accumulate hazardous waste without having to get an EPA permit, you have to:
• Identify all the hazardous wastes in your shop,
• Not exceed the maximum amount of hazardous waste that may be kept at your shop, and
• Meet standards for managing hazardous waste at your shop.
Table 1 shows the quantities, time limits allowed and some of the other requirements for each
generator class that need to be met to accumulate hazardous waste without a permit. If you would like
more information on generator classification or hazardous waste management rules, visit the EPA's
Hazardous Waste Regulations webpage, at www.epa.gov/epawaste/hazard/refdocs.htm.
Hal I Full =
-225Ibs
55 gal drum
Is your shop a CESQG?
CESQGs generate less
than 220 Ibs of hazardous
waste per month.
Weigh the hazardous waste
you generate each month
to determine your generator
class and follow the rules
for your generator class.
55 gal drum
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Table 1: Specific quantity limits and summary of management standards for each generator
class
Conditionally Exempt
Small Quantity
Generators
(CESQGs)
Small Quantity Generators
(SQGs)
Large Quantity
Generators
(LQGs)
How much hazardous
waste can 1 generate
per month?
Do 1 need an EPA ID
number?
How much hazardous
waste can 1 accumulate
at my shop?
How long can the
hazardous waste stay at
my shop?
Is a manifest required
when 1 ship hazardous
waste to a hazardous
waste facility?
Do 1 need emergency
response equipment
and a contingency
plan?
Do 1 need to do
weekly inspections
of hazardous waste
containers and tanks?
Do 1 need a hazardous
waste training program
for me and my staff?
< 220 Ib/month
< 2.2 Ib/month of acute*
hazardous waste
< 220 Ib/month of
acute* spill residue or
soil
No
< 2,200 Ib
< 2.2 Ib acute*
< 220 Ib of acute* spill
residue or soil
No time limits if you
don't exceed the
quantity limits stated
above
No
No, but it is a good idea
to have these no matter
what size generator
you are
No
No (EPA recommends
that you train your staff
on waste management)
220-2,200 Ib/month
< 2.2 Ib/month of acute* hazardous
waste
< 220 Ib/month of acute* spill
residue or soil
Yes
<1 3,227 Ib
< 2.2 Ib acute*
< 220 Ib of acute* spill residue or soil
180 day or less
or
270 days or less
if greater than 200 miles from
Treatment Storage and Disposal
facility (this currently applies in all of
Alaska)
Yes
Yes, you need emergency
equipment.
Test and maintain your equipment,
have a communication or alarm
system, have adequate aisle space
around containers, and make
arrangements with local authorities.
No, you do not need a contingency
plan.
Yes (EPA recommends that you
keep a log of inspections done)
Yes, training that ensures that
employees are familiar with waste
handling and the shop's emergency
procedures
> 2,200 Ib/month
> 2.2 Ib/month of acute*
hazardous waste
> 220 Ib/month of acute*
spill residue or soil
Yes
No Limit
90 days or less
Yes
Yes, emergency
equipment and a
contingency plan are
needed for responding to
fires, spills and releases
Yes (EPA recommends
that you keep a log of
inspections done)
Yes, initial training upon
employment and an
annual refresher
Acute hazardous wastes are discarded chemical products that can be fatal to humans or animals at low doses. EPA uses the P list to
identify the chemicals that are acute hazardous waste. Generally in an auto or aircraft repair shop, P-listed chemicals are often found
in pesticides used to control insects or rodents. For a list of acute hazardous waste see www.epa.gov/osw/hazard/wastetypes/listed.
htm.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Hazardous Waste Containers
and Tanks
It is very important that you label and store all the hazardous waste in your shop properly so that you
don't endanger anyone who may come in contact with your waste or anyone who receives your waste
after it leaves your shop. EPA could fine you if you do not properly label and store hazardous waste.
Label hazardous waste containers
It is a best practice for shops in any generator
class to label your hazardous waste containers.
If you are a SQG or LQG you need to place a
label on your containers that includes:
• the words "hazardous waste," and
• the date the first waste was put into the
container (the accumulation start date
or ASD). If the container is in a satellite
accumulation area, the accumulation start
date is the date the container becomes full.
Hazardous Waste
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Place labels on your hazardous waste storage containers to
identify the contents of the container and the date you started
accumulating the waste.
Storage in a satellite accumulation
area
Your shop may temporarily accumulate waste
in a satellite accumulation area. This is an area
close to where hazardous waste is generated
that is supervised by whoever in your shop
generates the hazardous wastes. A maximum of
55 gallons of hazardous waste, and one quart of
acute hazardous waste, can be accumulated in
the satellite area.
Label the containers in the satellite area. To
accumulate your waste, use containers that are
made of materials that are compatible with the
waste, in good condition, and that remain closed
unless you are adding waste to them. Once you
have collected 55 gallons, mark the date the
container became full on the container. You may
then temporarily hold the waste in the satellite
area for three days before moving it to your
hazardous waste storage area, or shipping it to
an offsite hazardous waste facility. Hazardous
waste containers may rupture in severe weather
conditions. It is best to store them indoors.
It is best to not mix your hazardous
waste with non-hazardous waste. A
drop of hazardous waste in a drum
of non-hazardous waste can make
the whole drum hazardous waste.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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What to Do With Shop Waste
Table 2 and the following sections will give you information on how to manage common wastes that
may be found in your shop. For more information on how to manage used oil and universal waste, see
those sections of this guide.
Table 2: Waste categories and how to recycle or dispose of specific types of waste
Category of waste if not
Type of waste mixed with hazardous What you can do with it
wastes
Used oil
Shop rags used to only
clean up used oil
Shop rags used to clean
up solvents that are
hazardous waste
Shop rags used to clean
up solvents that are not
hazardous waste
Used oil filters
Terne-plated used oil
filters. These are oil filters
that contain lead that are
most often found in large
semi trucks.
Used fuel filters
Oil spill absorbent
material
Used transmission fluid
Used brake fluid
Used antifreeze
Used tires
Alkaline batteries
Used oil
Used oil if they are
dripping3 with used oil
Hazardous waste
Solid waste
Not categorized
Solid waste. They may
be hazardous waste.
Many are hazardous
waste. Some may not
be.
Used oil or solid waste
Used oil
Used oil
Nonhazardous waste if
it is properly recycled at
your shop
Nonhazardous solid
waste
Typically a
nonhazardous waste
Recycle or burn (see used oil section of this guide)
Wring any dripping oil out of the rag into a used oil container.
Either launder the rags at an industrial facility or burn them in
your shop for heat.
Wring any dripping solvent out of the rag into a hazardous
waste container. Launder the rags at an industrial laundry or
ship them to a hazardous waste facility.
Wring any dripping solvent out of the rag into a waste solvent
container. Launder the rags at an industrial facility.
Hot drain any used oil into a used oil container. Recycle or
dispose in trash. If they are not drained, then they are classified
as used oil and you should send the filters to a used oil recycler.
Hot drain the oil filter into a used oil container. If it is hazardous
waste, then send the filter to a hazardous waste facility. If it is
not hazardous waste, the filters can be disposed of in the trash.
Drain the fuel filter into a container. Reuse the fuel if possible.
Manage the filter as hazardous waste unless you can determine
that the filter is not hazardous waste.
If the absorbent material is dripping with used oil, then it can be
recycled or burned as used oil. If it is not dripping with used oil
and it is not hazardous waste, then it can be burned or disposed
of in the trash.
Recycle or burn in your shop for heat
Recycle or burn in your shop for heat
Recycle. Antifreeze is deadly to animals. Be careful that animals
can't get to any antifreeze that is in your shop.
Recycle, retread or resell
Recommend you manage as universal waste (see universal
section of this guide). If the batteries are hazardous waste, then
manage them as universal waste or as hazardous waste
3 Any time the word "dripping" is used in this document, it means 'Visible signs of free flowing" as specified in the RCRA used oil regulations.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
January 2013
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Category of waste if not
Type of waste mixed with hazardous What you can do with it
wastes
Lead-acid batteries
Used brake pads
Used solvents and
cleaning agents
Solvent spill absorbent
material
Waste fuels and gasoline
Spilled or unusable paints
and thinners
Aerosol cans
Universal or hazardous
waste
Hazardous waste or
solid waste
Many are hazardous
waste. Some may not
be.
Solid waste. May be
hazardous waste.
Many are hazardous
waste. Some may not
be.
Many are hazardous
waste. Some may not
be.
Many are hazardous
waste. Some may not
be.
Reclaim the batteries through regeneration by taking them back
to your vendor, manage them as universal waste, or manage
them as hazardous waste.
Brake pads often contain copper which can be very harmful to
fish. It is a best practice to manage the used brake pads the
same as hazardous waste. Used brake pads may be disposed
in the trash if they are not hazardous waste.
If hazardous waste, filter or distill the waste and reuse it onsite,
or send the waste to a recycler or a hazardous waste facility. If it
is not hazardous waste, recycle it onsite or offsite.
If hazardous waste, send the absorbent material to a recycler
or hazardous waste facility. If it is not hazardous waste, and the
absorbent material is soggy, then add more absorbent material
until all the solvent is absorbed. Once absorbed, dispose in the
trash.
If the waste fuel is hazardous waste, send it to a hazardous
waste facility. If it is not hazardous waste, recycle it.
Depends on the paint or thinner. If paint or thinner that is not
hazardous waste is spilled, clean it up (or let the paint dry
out) and put the waste in the trash. If the paint or thinner is
hazardous waste, use absorbents to pick up the entire spill and
send the absorbents to a hazardous waste facility.
Depressurize the cans safely with an aerosol can puncturing
device. If the contents are hazardous waste, empty them into
a hazardous waste container. Once the can is empty, it can be
recycled as scrap metal.
Used Shop Rags and Towels
EPA recommends that you keep rags that you
use to clean up used oil separate from rags used
to clean up other liquid wastes. If you have a
used rag that only contains used oil, wring
any dripping oil out of the rag into a used oil
container and send it to an industrial laundry.
You may also burn the rag for heat in a used oil
burner in your shop.
If your used rag was used to clean up any
hazardous waste, then put the rag in a properly
labeled closed container and determine if it is
hazardous waste. If it is hazardous waste, either
send it to an industrial laundry or a hazardous
waste facility. Make sure that hazardous waste is
not dripping from the rag to prevent accidental
spills.
Used Absorbents
Absorbents (such as sand or kitty litter) used
to clean up oil spills can be placed in the trash
if there is no free flowing oil in them and if
the spilled oil is not hazardous waste. If they
are used to clean up fuel or other spills, the
absorbents may be hazardous waste depending
on the nature of the fuel or material spilled.
Determine the makeup of the materials in your
shop to determine if the fuel or material exhibits
the TRIG characteristics or would be a listed
hazardous waste (see the section of this guide
on how to identify all the hazardous waste in
your shop). It is important to identify all of the
hazardous wastes in your shop so, among other
things, you know how to clean up a potential
spill safely. If the spilled material contains
hazardous waste then count the used absorbents
in determining your generator class and manage
the material as a hazardous waste.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
January 2013
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Used Fuel Filters
Drain fuel filters just as you would drain used oil filters. Fuel filters should be drained into a waste fuel
container. Reuse that fuel if possible.
Once drained, used fuel filters should be placed in a labeled, metal, closed container and sent offsite as
a hazardous waste. Count the filter weight in the waste generated per month calculation that determines
your generator class (see Table 1). Your generator class will determine how long you can accumulate
used fuel filters without a permit.
If you don't want to manage fuel filters as hazardous waste, you will have to determine that they are
not hazardous waste, which may require sending a sample to a lab to determine whether the residues
are hazardous waste. If the filter proves to be non-hazardous you may dispose of it in the trash. If
gasoline went through the filter, the filter will contain benzene and may be a hazardous waste.
Used Antifreeze
Drain and replace antifreeze in areas where
there are no connections to storm drains or
municipal sewers. Stop spills before they reach
the shop's floor drains. You should collect and
store antifreeze in separate containers and not
mix it with other fluids.
Used antifreeze should be recycled whenever
possible. Your spent antifreeze may become
hazardous waste if it picked up metals from the
cooling system. It is a best practice to reclaim
used antifreeze, such as in a closed loop system
that connects directly to the radiator, filters the
antifreeze, and returns it directly back into the
radiator.
USED ANTIFREEZE OHU
i N£ • ^ L
t NO USED OIL
i NO HAZARDOUS WASTES-NO SOLVENTS
CLEAN UP ALL SPILLS
Antifreeze is deadly to animals. Be careful that animals can t get
to any antifreeze that is in your shop.
Antifreeze that is not recycled has to be disposed of. You will need to determine if it is a hazardous
waste to know how to dispose of it properly. If you know that the antifreeze likely picked up metals
from the cooling system, it is likely a hazardous waste. If it is a hazardous waste, count it toward your
generator class and manage it as a hazardous waste (store it in a closed container, label the container,
etc.) or recycle it. See Table 1 to find out how long you can accumulate hazardous waste without a
permit based on your generator classification.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Lead-Acid Batteries
Lead-acid batteries will typically exhibit the
hazardous waste characteristics of corrosivity
and toxicity for lead, and thus are hazardous
waste. There are three options for managing
lead-acid batteries:
1. Reclaim the batteries through
regeneration by taking them back to
your vendor or another recycler
2. Manage them as universal waste (see
the universal waste management
section)
3. Manage them as hazardous waste
Store your spent lead-acid batteries in containers
that will not react with battery acid if it leaks.
Solid plastic containers are preferred. The
storage area should be covered to protect the
batteries from weather. The storage area should
not have floor drains and should be designed
to prevent spills or leaks from reaching soil or
surface waters near your shop. In the design
of your storage area consider incorporating
secondary spill containers such as berms, tanks,
and basins that catch leaks. If acid leaks from
a battery, these secondary containment devices
will contain the spill. If there is a spill of battery
acid, you should immediately neutralize the acid
with baking soda or soda ash and manage the
waste soda as hazardous waste. If your batteries
are stored in a way that allows releases of battery
acid or lead to the environment, the EPA may
consider them as being illegally disposed.
Lead-acid batteries should be stored in closed, plastic
containers. The storage area should be protected from weather
and be designed so that any accidental spill does not reach a
pervious surface.
\
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Aerosol Cans
Any aerosol can that is pressurized and not
punctured may be considered hazardous waste.
It is a best practice to use all the contents of an
aerosol can. Do not throw full, partially-full or
pressurized spray cans into the dumpster.
Examine the contents of the can and figure out
if any of the chemicals in the can are toxic,
reactive, corrosive, or ignitable to see if the
waste in the can is hazardous waste. Certain
aerosol brake cleaners and carburetor cleaners
can be hazardous waste.
If it is hazardous waste, place full, partially-full,
or pressurized empty aerosol cans in a closed
container, such as a drum or five gallon pail, and
send to a permitted hazardous waste facility.
Label and date the container with the date that
you started storing cans in it.
You can depressurize and drain your hazardous
waste aerosol cans. Use an aerosol can
puncturing device to safely drain the contents of
the can into a hazardous waste container. Once
your steel aerosol can is completely empty and
depressurized you may send the can to a scrap
metal recycling facility.
To avoid cross-contamination of other wastes,
do not use spray cans over solvent tanks, parts
washers, used oil containers, or any other waste
containers.
If your hazardous waste spray can malfunctions
(for example, if the tip breaks off), send the
can to a permitted hazardous waste handler or
consider returning it to your supplier.
Certain aerosol brake cleaners
and carburetor cleaners can be
hazardous waste.
Use an aerosol can
puncturing device, for
example this one mounted
over a hazardous waste
drum, to safely drain the
contents of your aerosol cans
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
January 2013
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Used Solvents
Used solvent may be a hazardous waste or a
non hazardous waste. For example, a spent
chlorinated solvent, such as 1,1,1 tricholorethane
brake cleaner with 10% or more tricholorethane
before use, is a hazardous waste. High flash
point mineral spirits used in some parts washers
are not usually hazardous waste. If your used
solvent is a hazardous waste, you can recycle
it in your shop, send it to a recycler, or manage
it as hazardous waste (proper storage, labeling,
and sending it offsite to a hazardous waste
facility). You can recycle your solvents with a
distillation unit.
Residues from reclaiming waste solvents may
be hazardous waste, so make sure you take the
time to determine whether or not the wastes you
have are hazardous waste and manage them
accordingly.
Determine if the spent solvent from your parts washer is a
hazardous waste.
If you recycle waste in your shop (for example, by
distilling it), be aware that the left over waste from
the process may be a hazardous waste.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Used Oil Management
Simple labels on containers can satisfy used oil labeling
requirements. Label used oil containers with the words "Used
Oil."
Your shop certainly generates used lubricating oils. If these oils are sent off for recycling or burned,
they are regulated under EPA's used oil regulations. Used oil should not be mixed with other types of
waste, especially hazardous wastes. Household do-it-yourself used oil, meaning the used oil that is
generated by an individual from their personal vehicle, is not subject to the used oil regulations.
Label your used oil containers and tanks with
the words "Used Oil." Do not label them "Waste
Oil." Some common wastes that can be managed
as used oil include:
• used crank case oil and rags that are
dripping4 with oil (see the used shop rag
section)
• used oil niters that are not drained
• oil spill absorbent material that is dripping
with oil
• used transmission fluid
• used brake fluid
Used oil filters should be gravity hot drained
into a used oil container. Once they are properly
drained, they can be recycled as scrap metal or if
they are not hazardous waste, they can be placed
in the trash. Terne-plated used oil filters contain
lead and need to be managed as hazardous waste.
See the hazardous waste section of this guide to
see what to do with them.
Your used oil will generally be classified as
hazardous waste if:
Puncture
- It is mixed with hazardous waste, or ^^^^^^ Here
• The total halogens (fluorine, chlorine,
bromine, or iodine) in your used oil exceed
1000 ppm (there are exceptions. See the
next section on hazardous waste in your
used oil).
Review the hazardous waste section of this guide for some general information on management of
used oil that is hazardous waste.
Puncture
Here
Dome End
Antidrain
Back
Seal
4 Any time the word "dripping" is used in this document, it means 'Visible signs of free flowing" as specified in the RCRA used oil regulations.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Hazardous waste in your used oil
If you are a Conditionally Exempt Small
Quantity Generator (that is, if you generate 220
pounds of hazardous waste or less per month),
you may mix hazardous waste with your used
oil and manage the mixture as used oil.
If you are a Small Quantity or Large Quantity
Generator (see Table 1), mixing hazardous
waste with your used oil may require that the
entire mixture be managed as hazardous waste.
• Mixing hazardous waste with used oil
complicates management of your wastes.
There are many hazardous wastes that
cannot be mixed with your used oil, for
example, any of EPA's listed wastes.
Depending on the hazardous waste,
burning contaminated used oil may create
air pollutants that are harmful to breathe.
A best practice is to keep your used oil
separate from other wastes.
• If your used oil contains more than 1000
ppm total halogens (fluorine, chlorine,
bromine, or iodine), EPA assumes that it
has been mixed with hazardous waste and
it needs to be managed as a hazardous
waste. If you can demonstrate to EPA that
the halogen is not from hazardous waste
but comes from a nonhazardous source (for
example seawater splashing into the engine
compartment of a seaplane), then you
can manage the oil as used oil and not as
hazardous waste (known as the "Rebuttable
Presumption"). To determine the amount of
halogens in your used oil, there are test kits
available at low costs.
and combustion gases from the heater are vented
to the outside air. You may also burn used oil
given to you by household do-it-yourselfers.
If you ship used oil offsite for burning, make
sure it is transported by a registered used oil
transporter with an EPA ID number and is sent
to a registered used oil burner. If you give your
used oil to someone else to burn and it is not
burned at an industrial used oil burning facility
authorized to burn off-spec used oil (for example,
if you give your used oil to the shop down the
street for burning), make sure that the used oil
meets the specifications in the regulations for
burning without a permit.5
Table 3: Specifications for burning used oil
off-site at non-permitted burners
„ ... . „ . Allowable Level for
Constituent or Property Bum|ng Wjthout g permjt
Arsenic
Cadmium
Chromium
Lead
Flash point6
Total halogens7
5 ppm maximum
2 ppm maximum
10 ppm maximum
100 ppm maximum
100 °F minimum
4,000 ppm maximum
It is a best practice to only burn used oil in the
shop where it was generated. If you send your
used oil to a friend's shop down the street for
burning, you may have to get an EPA ID number
and comply with requirements for a used oil
marketer.
Determine if used oil is on
specification prior to burning
Burning contaminated used oil can be hazardous
to your health. If oil mixed with chlorinated
solvents is burned in your heater, it may emit
harmful dioxins into your shop. You may burn
the oil you generate in your shop in a space
heater at the shop if the heater has a maximum
capacity of not more than 500,000 Btu per hour
Applicable standards for the burning of used oil containing PCBs
are imposed by 40 CFR 761.20(e)
Flash point is determined in a laboratory with a special instrument
that measures ignition temperature.
Total halogens is the total concentration of fluorine, chlorine.
bromine, and/or iodine.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Transporting used oil
You may use your car to transport up to 55 gallons of used oil to a used oil collection center. If you
wish to ship more than 55 gallons of used oil offsite, make sure it is transported by a registered used oil
transporter with an EPA ID number. Used oil may be shipped offsite to a collection center, oil recycler,
re-refiner or burner.
Clean up used oil spills as soon as possible
Always work to prevent spills by keeping machinery, equipment, containers and tanks in good
working order and be careful when transferring used motor oil. Have clean-up materials, such as rags,
absorbents (like kitty litter), booms or sand readily available.
If a spill happens:
• Stop the release of used oil at the source
• Contain spilled used oil such as by spreading sand or other clean-up material (absorbents) over the oil
and surrounding area
• Clean up the used oil and absorbent material by placing it in a container and manage it and other
materials properly (see the section of this guide on what to do with shop waste to learn how to dispose
of absorbent material)
• Repair or replace the defective tank or container before returning it to service
Clean up used oil spills immediately
Did you know that motor oil from one oil
change dumped in a drain or on the ground
can contaminate a million gallons of fresh
water? That means that if we don't recycle it,
we could be drinking it!
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Universal Waste
(e.g. fluorescent tubes, batteries]
Management
To facilitate recycling and reduce illegal disposal, EPA developed a set of less strict requirements for
a subset of hazardous waste called universal waste. Most shops generate some universal waste. You
may choose to manage your universal waste under universal waste standards. For example, mercury
switches, lead acid batteries, flashlight-type batteries and fluorescent lamps may all be managed as
universal waste. If you do not choose to manage these wastes as universal waste and they qualify as
hazardous waste, then you need to manage them to full hazardous waste standards.
There are four main types of universal waste:
1. Most batteries, such as lead acid, flashlight batteries, lithium, NiCad, etc.
2. Some expired pesticides
3. Fluorescent tubes and other non incandescent lights (lamps)8
4. Mercury containing equipment, such as mercury switches
Store all universal wastes in closed containers that are structurally sound and made from materials that
won't react with the waste (such as, don't store lead acid batteries in a container that is made of wood,
cardboard or metal because those materials will dissolve if the acid leaks). Make sure the containers
won't leak.
Universal waste lamps can be stored in the original boxes they
came in as long as the boxes will prevent them from breaking.
Broken lamps must be stored in a closed container.
8 Clean up broken fluorescent lamps safely. For instructions, see www.epa.gov/cfl/cflcleanup.html
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Label your universal waste containers with the words "universal waste" and a description of the
contents such as "lamps" or "batteries."
UNIVERSAL WASTE
amps
Accumulation Start Dale.
UNIVERSAL WASTE
attenes
Accumulation Start Date:
Universal waste labels should include the words "universal waste" and the kind of waste in the container. Include the date that you
started accumulating the waste on the label. That way you will know how long the waste has been stored.
Universal waste should not be stored in your shop for over one year. Ship your universal waste to
a facility with an EPA ID number that processes universal waste. Keep a record of how long all the
universal waste has been stored in your shop.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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EPA Inspections
Automotive or aircraft repair shops that don't follow EPA used oil or hazardous waste management
regulations could be fined. EPA conducts compliance inspections at shops regularly regardless of the
size of the shop. Inspectors most frequently find the following areas of concern at automotive and
aircraft repair shops that could result in an EPA enforcement action:
1. Used oil
a. Improper labeling of used oil tanks or containers
b. Not determining if used oil from other generators other than do-it-yourself
households is "on specification " prior to burning
c. Not cleaning up used oil spills properly
2. Universal waste (fluorescent tubes, batteries, etc.)
a. Storing waste for too long
b. Improper labeling of storage containers
c. Not storing universal waste in the proper containers
3. Hazardous waste identification
a. Not identifying all of the hazardous waste in a shop
b. Not accurately determining how much waste the shop generates
4. Hazardous waste container and tank management
a. Lack of waste management training
b. Lack of emergency response supplies, equipment, and plans
c. Improper labeling of hazardous waste containers (including the accumulation start
date)
When an EPA inspector comes to your shop, you can expect:
• A tour of your shop focusing on the areas where wastes and used oil are generated and managed
• A review of all records
• A discussion of the inspector's findings immediately after the inspection
Inspectors are available any time to answer your questions about hazardous waste management. After
the inspection, your shop will be contacted in writing by the EPA enforcement office notifying you of
any issues identified during the inspection and what you need to do to address them.
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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Appendix: TCLP List
The Toxic Characteristic Leaching Procedure (TCLP) is a laboratory test that assesses whether or
not a waste exhibits the toxicity characteristic that would classify the waste as a hazardous waste. If
you send a sample to the lab for a TCLP test, compare your lab results with the regulatory level for
the given contaminant in the table below. If your lab results meet or exceed the regulatory level, your
waste is considered a hazardous waste.
EPA Hazardous 0 . . . Chemical Abstracts Regulatory Level
... , .. Contaminant „ . .. , ,, ,
Waste No. Service No. (mg/L)
D004
D005
D018
D006
D019
D020
D021
D022
D007
D023
D024
D025
D026
D016
D027
D028
D029
D030
D012
D031
D032
D033
D034
D008
D013
D009
D014
D035
Arsenic
Barium
Benzene
Cadmium
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloroform
Chromium
o-Cresol
m-Cresol
p-Cresol
Cresol (total)
2,4-D
1 ,4-Dichlorobenzene
1 ,2-Dichloroethane
1,1-Dichloroethylene
2,4-Dinitrotoluene
Endrin
Heptachlor (and its epoxide)
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Lead
Lindane
Mercury
Methoxychlor
Methyl ethyl ketone
7440-38-2
7440-39-3
71-43-2
7440-43-9
56-23-5
57-74-9
1 08-90-7
67-66-3
7440-47-3
95-48-7
1 08-39-4
1 06-44-5
94-75-7
1 06-46-7
1 07-06-2
75-35-4
121-14-2
72-20-8
76-44-8
118-74-1
87-68-3
67-72-1
7439-92-1
58-89-9
7439-97-6
72-43-5
78-93-3
5.0
100.0
0.5
1.0
0.5
0.03
100.0
6.0
5.0
200.0
200.0
200.0
200.0
10.0
7.5
0.5
0.7
0.13
0.02
0.008
0.13
0.5
3.0
5.0
0.4
0.2
10.0
200.0
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
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EPA Hazardous „ , Chemical Abstracts Regulatory Level
Waste No. Contaminant Servjce NQ (mg/L)
D036
D037
D038
D010
D011
D039
D015
D040
D041
D042
D017
D043
Nitrobenzene
Pentrachlorophenol
Pyridine
Selenium
Silver
Tetrachloroethyl-ene
Toxaphene
Trichloroethyl-ene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-TP (Silvex)
Vinyl chloride
98-95-3
87-86-5
110-86-1
7782-49-2
7440-22-4
127-18-4
8001-35-2
79-01-6
95-95-4
88-06-2
93-72-1
75-01-4
2.0
100.0
35.0
1.0
5.0
0.7
0.5
0.5
400.0
2.0
1.0
0.2
Used Oil and Hazardous Waste Management for Auto and Aircraft Repair Shops in Alaska
January 2013
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United States
Environmental Protection
Agency
Region 10
1200 Sixth Avenue, Suite 900
Seattle, WA 98101-1128
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