State of Ohio, Environmental Protection Agency
Office of Pollution
Prevention
Fact Sheet #35, June 1997
This fact sheet outlines pollution prevention options and hazardous waste management requirements for automotive repair facilities. By implementing pollution prevention, automotive repair facilities will not only better comply with environmental regulations, but also reduce operating costs, improve worker safety, and enhance their shops' image in their communities.
Most automotive repair facilities generate spent solvents, lead-acid batteries, used antifreeze, absorbents, used oil, used oil filters, parts cleaning wastes, shop cleaning wastes, aerosol cans, paints, refrigerants, tires and various engine and auto body parts. These wastes can be created by replacing automotive fluids, maintaining parts and repairing equipment.
The Resource Conservation and Recovery Act (RCRA) is a federal environmental law that regulates solid and hazardous wastes from generation through disposal. Hazardous wastes are classified into two categories: listed and characteristic. Characteristic hazardous wastes exhibit one or more of the four hazardous characteristics (ignitability, corrosivity, reactivity and toxicity). Listed hazardous wastes are specifically listed by name or process in the Code of Federal Regulations Chapter 261, and in Ohio's Hazardous Waste Management Rules, Ohio Administrative Code Chapter 3745-51.
Every automotive repair facility that generates a hazardous waste is considered a generator. Hazardous waste generators must abide by certain environmental laws and regulations. Don't panic if you generate hazardous wastes. Most automotive repair facilities produce hazardous wastes. If you intend to dispose of (landfill or incinerate) shop wastes, you must first determine whether the wastes are hazardous wastes. This can be decided through knowledge of the waste stream (material safety data sheet) or appropriate analytical testing.
Serious Hazardous Waste Violations
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Pollution prevention uses source reduction and as a second choice, environmentally sound recycling to reduce or eliminate hazardous waste and other pollution at the source. Pollution prevention includes good operating practices, material substitutions, process changes and recycling. Pollution prevention addresses all waste streams (solid and hazardous waste, air and water).
There are many pollution prevention opportunities available for automotive repair facilities. If you currently generate a hazardous waste or any other type of waste, pollution prevention can help you reduce or eliminate that waste. (See Table I - Guide to Managing Auto Repair Shop Wastes)
U.S. EPA estimated that 1.2 billion gallons of used oil were generated by the commercial sector in 1988. Although a large portion was either burned for energy recovery or recycled, millions of gallons were disposed in landfills, applied to roadways, incinerated, or illegally disposed of. The mismanagement of used oil has resulted in significant damage to the environment and costly cleanup.
Used oil includes motor oil, brake and transmission fluid, and hydraulic oil. Used oil that has not been mixed with a hazardous waste and is recycled is not subject to Ohio's hazardous waste requirements.
In a temperate climate such as Ohio, many automotive repair facilities manage their used oil in the winter by burning it in auxiliary heating units known generically as space heaters. If you burn used oil in a space heater, it is important to distinguish between the two types of used oil, off-specification and on-specification used oil. The burner must determine the specification status of his/her used oil. This generally means having the oil tested or analyzed.
Although Ohio does not regulate burning on-specification used oil in a space heater under its hazardous waste or used oil guidelines, this activity may require an air permit, or its equivalent, from Ohio's air pollution control program (see below). Off-specification used oil is more contaminated with certain chemicals than on-specification used oil, so its burning warrants special control.
A business may burn its off-specification used oil in a space heater, provided the following conditions are satisfied:
Contact the Ohio EPA's Division of Air Pollution Control at (614) 644-2270 for more information.
Off-site recycling services are commonly available for auto repair shops that generate used oil. Most used oil recycling services will charge a fee for pick-up and to cover costs associated with recycling. However, off-site recycling of used oil is often the most economical and environmentally sound way of handling used oil.
To ensure that used oil can be recycled, do not add chlorinated solvents or other wastes to used oil. Keep used oil segregated to prevent contamination from other waste streams.
Used Oil Facts
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Used oil filters may be hazardous wastes because of chemicals which are present in the filter. Used oil filters are not hazardous wastes if they are recycled as scrap metal, or if they are non-terne plated and "hot-drained"by one or a combination of the following methods:
Used oil recovered from filters can be recycled in addition to the metal from the spent metal filter cases.
Ethylene glycol (antifreeze) is a water-soluble compound that has a sweet taste. It may be hazardous waste because of the high levels of lead in it. It is also toxic to fish and wildlife. Handle it very carefully. Store it in a secure area in a closed container that is in good condition. Because animals are attracted to its sweet taste, clean up any spills or discharges at once. Do not store antifreeze next to a floor drain that is connected to a septic system, or by a storm drain discharging into surface waters. Used antifreeze should not be disposed to sanitary sewers and the publicly owned treatment works (POTW).
Antifreeze recycling equipment is commercially available for use by automotive repair facilities. Antifreeze recycling can be a cost-effective way for shops to handle used antifreeze solutions. Antifreeze recycling equipment includes distillation and filtration technologies. These systems can filter solids and remove metal ions from the used antifreeze. Automotive repair facilities also can manage used antifreeze by sending it off-site to an antifreeze recycling facility.
Chlorofluorocarbons (CFCs) have received worldwide attention because they have weakened the ozone, a special layer in the atmosphere protecting Earth from harmful ultraviolet radiation. Refrigerant from motor vehicle air conditioners (MVACs) is one of the largest sources of CFCs in the United States. In addition, certain CFCs used as refrigerants or coolants may be hazardous wastes. Most automotive refrigerants are CFC-12 (also called Freon or R-12).
Do not attempt to service auto air conditioning systems unless you have proper training and certification. For more information, contact Ohio EPA, Division of Air Pollution Control at (614) 644 -2270.
Automotive repair facilities can recycle used refrigerants. Portable, self-contained recycling units are commercially available to recycle CFC-12. The equipment processes the refrigerant through a separator, filter and dryer. The refrigerant can then be returned to the air conditioner after repair is completed. Automotive repair facilities who service a number of air conditioners each year may save money by purchasing a CFC-recycling system. CFCs may also be collected and sent offsite for recycling.
Cleaning engine parts is a common practice in the auto repair shop. Parts cleaning using solvents and parts washers have been a common practice. In general, parts washers do not require a hazardous waste permit. Parts washer solvents are not considered wastes until they are removed from the unit, or unless they remain in the unit over 90 days after the unit ceases operation.
Parts washers are often used in combination and concurrently with on-site solvent recovery units to reclaim spent solvents. This process does not require a hazardous waste permit. Spent solvents that are removed from a parts washer and stored in containers remain wastes prior to reclaiming. Although some parts washer cleaners are nonhazardous as products, they may become heavily contaminated during use and exhibit a hazardous waste characteristic.
All businesses disposing of (not recycling) their solvents must determine if they are hazardous wastes. Be sure you know the types and quantities of ingredients in solvent products before you purchase them. Be aware that complete or adequate product information is not always disclosed on the product label or material safety data sheets.
There are several pollution prevention opportunities related to parts cleaning. First, automotive repair facilities should evaluate the need for cleaning and determine how clean a part needs to be. Mechanical methods including wire or abrasive brushes should be used when appropriate.
Pollution Prevention Tips for Auto Repair Shops
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If parts washers are used, there are a number of ways to reduce hazardous waste generation and to extend the life of cleaning solvents used. For example, automotive repair facilities should consider using a two-stage cleaning system. The first stage should clean the dirtiest parts. The second stage uses cleaner solvent for final cleaning and rinsing. When the cleaning solution in the second stage is no longer effective, it can then be used to replace the solvent in the first stage. Fresh solvent is then used to replace the second stage. Parts washers should have a recirculating feature with built-in filtration to continuously remove dirt and contaminants. Drip racks or trays can help increase drainage from parts to minimize solvent loss. When not in use, lids on parts washers should be kept closed to reduce evaporative solvent loss.
For some larger automotive repair facilities, the use of an on-site solvent distillation unit may be an economically feasible way to recover solvents and significantly reduce solvent waste generation. A solvent distillation unit recovers solvent by heating the cleaning mixture to vaporize the solvent and condense the vapor. Different types of distillation units are currently available.
There are many companies available that provide off-site recycling of cleaning solvents. In addition, many auto repair shops contract with a parts washer service company to help properly maintain washers and manage solvent wastes for off-site recycling.
For some automotive repair facilities, aqueous (detergent-based) cleaning may be an alternative to using parts washers and cleaning solvents. Aqueous cleaning systems are available with a variety of design features including high pressure sprays and immersion baths with ultrasonics to enhance cleaning effectiveness. Aqueous cleaning systems can be designed with equipment to filter out contaminants, return chemicals for cleaning and to recycle water.
Wastewater discharged from aqueous cleaning systems may be subject to local, state and federal environmental requirements. For additional information, contact Ohio EPA Division of Surface Water at (614) 644-2001.
Floor cleaning wastes, absorbents used for spill or leaks and shop rags are common waste streams generated by shop cleanup activities. Although used absorbents may contain only very small amounts of contaminants, they must be characterized before being disposed of.
Using shop towels instead of absorbents may be a viable option under some circumstances. Used shop towels are not hazardous wastes if they are sent to a launderer/dry cleaner, cleaned and reused. The used towels must not contain free liquid prior to laundering. Hand-operated wringers can be used to recover solvent for reuse from rags and towels.
Like wastewater discharged from aqueous parts cleaning, water from floor and equipment cleaning also may be subject to local, state and federal environmental requirements. In addition, sludge from shop floor sumps may require disposal as a hazardous waste depending on characterization. Automotive repair facilities are encouraged to operate a"dry shop" in order to reduce the generation of floor cleaning related wastewater and floor sump sludge.
Good operating practices including improved housekeeping measures can help automotive repair facilities reduce the generation and disposal of these waste streams. Using drip trays and pans can prevent spills, recover product for reuse, and eliminate the need for floor dry absorbents. Squeegees can also be used to recover product and cleanup spills.
Used engine parts, tires, and batteries are just a few of the other types of wastes generated by auto shops. Generally speaking, these materials are not hazardous wastes if they are recycled and are not contaminated with a hazardous waste. For assistance in managing miscellaneous auto shop wastes, contact Ohio EPA's Division of Hazardous Waste Management at (614) 644-2934.
Table 1: Guide to Managing Auto Repair Shop Wastes | ||
Waste Stream |
Toxic/Hazardous Property |
Pollution Prevention Alternative |
Used Antifreeze |
Ethylene glycol, lead |
Keep antifreeze segregated and consider on-site recycling units or send off-site for recycling. |
Used Oil and Other Engine Fluids |
Heavy metals, used oil, flammables |
Consider non-hazardous alternatives if available. Keep oils/fluids segregated and send off-site for recycling. |
Used Oil Filters |
Used oil |
Drain oil from filters and recycle. Crush filters and send off-site for metal recycling. |
Oil/Water Separator Sludge |
Used oil, grease, spent fuels, heavy metals, solvents |
Minimize generation by using good housekeeping and prevent spills. Use drip pans and dry cleanup methods. |
Spent Fuel |
Benzene, flammables |
Reuse spent fuels, send contaminated spent fuels off-site for recycling |
Lead-Acid Batteries |
Corrosive acid, lead |
Collect batteries and return to vendor or send off-site for recycling |
Aerosol Cans |
Flammables, CFCs, solvents, other toxics |
Evaluate non-hazardous, non-CFC alternatives. Use refillable aerosol containers. |
Used Refrigerants |
CFCs |
Use on-site systems to recover and reuse |
Used Engine Parts |
Heavy metals, public nuisance |
Rebuild on-site or sell to parts remanufacture, recycle off-site for metal scrap. |
Auto Glass, Mirrors, Headlamps |
Lead |
Send off-site for recycling |
Part Washers and Spent Solvents |
Flammables, chlorinated compounds, other toxics |
Evaluate mechanical cleaning methods, including wire brushing. Consider non-hazardous solvent alternatives for parts washers with filtration to extend the life of cleaning solvents. Evaluate water-based (aqueous) cleaning solvents. Contract with a service company to recycle solvents and maintain parts washers. Evaluate on-site wastewater recycling systems. |
Water-based (aqueous) Cleaning |
Wastewater, oil and grease, heavy metals |
Consider on-site wastewater recycling systems |
Shop Towels, Rags, and Absorbents |
May contain flammables, chlorinated compounds, other toxics |
Consider off-site laundry services for rags and shop towels. Minimize generation by improving housekeeping and using drip trays and pans. Use hand-operated wringers to recover solvents for reuse. |
Outdated Supplies |
Hazardous chemicals |
Use an inventory system to keep track of supplies. Minimize purchase of quantities and use a "first-in, first-out" policy. |