Checklists: Hazardous Waste
Hazardous Waste Information
Shop Tour Stop #1
The following questions and guidance are taken from the
Consolidated Screening Checklist for Automotive Repair Facilities Guidebook.
A √ next to a response in the guide indicates that is the preferred response in terms of environmental compliance. If you select a response without a √, you may still be in compliance; however, you should verify that you are in compliance by contacting the appropriate federal or state regulatory agency and discussing your activity with them.
WASTE MANAGEMENT
Identifying Hazardous Waste
An automotive repair shop with service and maintenance activities is likely to create hazardous wastes. Therefore, it is important that the facility identify and properly manage hazardous wastes to protect itself, coworkers, others in the community, and the environment. As a waste generator, the repair shop is responsible for hazardous waste management, from generation to final disposal. A facility can be held liable for any mismanagement of its wastes, even after the wastes leave the facility. It is important for every facility to know what wastes are created during maintenance and repair and whether they are hazardous wastes or not. Table 1 provides information on typical wastes created in an automotive service and repair shop.
Typical Wastes Generated at Automotive Repair Shops and Typical Category by Waste Management Method What is Hazardous Waste?
To be considered hazardous waste, materials must first meet EPA’s definition of solid waste. Solid waste is discarded material, such as garbage, refuse, and sludge, and includes solids, semi-solids, liquids, or contained gaseous materials. Solid wastes that meet the following criteria are considered hazardous and subject to hazardous waste regulations under the Resource Conservation and Recovery Act (RCRA):
- Listed waste.Wastes are listed as hazardous because they are known to be harmful to human health and the environment when not managed properly, regardless of their concentrations. There are some wastes called acutely hazardous wastes that are dangerous even if they are managed properly. An example of acutely hazardous waste are some pesticides that can be fatal to humans even in low doses.
- Listed wastes may be found in some spent cleaning solvents. These include:
- Spent halogenated solvents that contain chlorinated compounds
- Spent nonhalogenated solvents that contain xylene, methanol, ethyl ether or methyl isobutyl ketone
- Listed wastes may be found in some spent cleaning solvents. These include:
- Characteristic waste.If your waste does not appear as a listed hazardous waste, it still might be considered hazardous if it demonstrates one or more of the following characteristics:
- Ignitable: Ignitable wastes (flashpoint <140° F) can create fire under certain conditions (e.g., temperature, pressure) or are spontaneously combustible (40 CFR 261.21). Examples include used paints, degreasers, oils and solvents.
- Corrosive: Corrosive wastes (pH less than 2 or greater than 12.5) are acids or bases that are capable of corroding metal, such as storage tanks, containers, drums, and barrels (40 CFR 261.22). Examples include rust removers, acid or alkaline cleaning fluids, and battery acid.
- Reactive: Reactive wastes are unstable and explode or produce toxic fumes, gases, and vapors when mixed with water (40 CFR 261.23). Examples include lithium-sulfide batteries and explosives.
- Toxic: Toxic wastes are harmful or fatal when ingested or absorbed, or leach toxic chemicals into the soil or groundwater when disposed of on land (40 CFR 261.24). Examples include wastes that contain high concentrations of heavy metals, such as cadmium, lead, or mercury.
The repair shop can determine if its waste is toxic by having it tested using the Toxicity Characteristic Leaching Procedure (TCLP), or by process knowledge. The TCLP is designed to replicate the leaching process and other effects that occur when wastes are buried in a typical municipal landfill. If the leachate from the waste contains any of the regulated contaminants at concentrations equal to or greater than the regulatory levels, then the waste exhibits the toxicity characteristic. Process knowledgeis detailed information on wastes obtained from existing published or documented waste analysis data or studies conducted on hazardous wastes generated by similar processes. For example, EPA’s listed hazardous wastes, as discussed above, can be used as process knowledge.
Universal Waste Rule
In 1995, EPA issued the Universal Waste Rule as an amendment to the hazardous waste program to reduce the regulatory burden on businesses by providing an alternative and less stringent set of management standards for certain types of wastes that potentially would be hazardous under the hazardous waste program: (1) batteries (e.g., nickel cadmium, small sealed lead acid) that are spent (i.e., will not be reclaimed or regenerated at a battery recycling/reclamation facility); (2) pesticides that have been suspended or canceled, including those that are part of a voluntary or mandatory recall under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA); and (3) mercury thermostats including temperature control devices containing metallic mercury. Check with the state regulatory agency to see if it has adopted the Universal Waste Rule. For more information, check the website: www.epa.gov/epaoswer/hazwaste/id/univwast.htm
Does the facility generate hazardous waste?
Yes–Facility has tested or used process knowledge to determine it does generate hazardous waste. See Table 1 for common hazardous automotive wastes generated by auto repair facilities.
No–Facility has determined that it does not generate hazardous waste.
N/A / Not determined–Facility has made no determination. Note: Facility must immediately conduct a waste determination to determine if it is generating a hazardous waste.How much hazardous waste does the facility generate per month?
Generation occurs when a substance becomes a waste. When determining the volume of waste generated, only waste that is in a container or other unit waiting to be disposed of is considered generated. Thus, solvent stored in a drum waiting for disposal or recycling is generated, while solvent in a parts washer that is currently in use is not yet a waste and the facility has not generated it.
The facility generates: (Select one)
- No more than 220 lbs (100 kg) of hazardous waste per month. This is approximately of a 55-gallon drum or less of hazardous waste in any month. In this case, the facility is a conditionally exempt small quantity generator (CESQG) and an EPA identification (ID) number is not required.
- Between 220 lbs (100 kg) and 2,200 lbs (1,000 kg) of hazardous waste per month. In this case, the facility generates more than of a 55 gallon drum of hazardous waste, but less than 5 (five) 55-gallon drums of hazardous waste in any month. In this case, the facility is a small quantity generator (SQG) must and must have an EPA ID number.
- Over 2,200 lbs (1,000 kg) of hazardous waste per month. In this case, the facility generates approximately 5 (five) 55-gallon drums or more of hazardous waste in any month. In this case, the facility is a large quantity generator (LQG) and must have an EPA ID number.
The total weight of hazardous waste generated includes waste (1) defined as hazardous by EPA regulations, (2) determined to be hazardous by the facility, and (3) not otherwise exempt from counting. For example, used oil that has not been mixed with anything and is destined for recycling does not have to be counted. Generators who periodically exceed or fall below their normal generation limits in any given calendar month are called episodic generators. If the amount of waste generated in a given calendar month causes the generator to become a different type of generator, the generator is responsible for complying with all applicable requirements of that category for all waste generated during that calendar month. For example, if a generator produces 300 kg of hazardous waste in March, that waste is subject to SQG requirements. If the same generator produces 1,500 kg of hazardous waste in April, that waste is subject to LQG requirements.
Does the facility have an EPA hazardous waste generator ID number?
If the facility is an SQG or LQG, federal law requires that it have an EPA hazardous waste generator ID number. This requirement applies even to episodic generators who may fall into the SQG or LQG categories for only one month. This number must appear on all hazardous waste manifests. It is usually placed near the top of the form under the heading, “Generator ID #. The hazardous waste number is an alphanumeric number. The identification number begins with the state postal abbreviation followed by a single letter describing the company’s waste activity, (e.g., D=Disposal, T=Transporter, etc.) and nine digits (e.g., NYG123456789). CESQGs are not required to obtain an identification number under federal law. Contact the state or EPA regional office to obtain a copy of EPA form 8700-12 Notification of Hazardous Waste Activity. For additional help, call the RCRA/UST, Superfund, EPCRA Hotline at (800) 424-9346.
Yes–Facility has obtained a hazardous waste ID number from the state regulatory agency or EPA. √
No–Facility has not obtained an hazardous waste ID number.
N/A–Facility is a CESQG. No hazardous waste ID number required.Does the facility have hazardous waste manifests or shipping papers on file?
For SQGs and LQGs that ship hazardous waste off-site, a Uniform Hazardous Waste Manifest must accompany each hazardous waste shipment. The manifest documents the shipment type, quantity, origin, and destination, and must accompany each hazardous waste shipment. Manifests must be kept for 3 years. Contact the state regulatory agency for a Uniform Hazardous Waste Manifest form. CESQGs are not required to use manifests.
Yes–Facility has manifests and/or shipping papers on file for hazardous waste transported. √
No–Facility does not have manifests and/or shipping papers for hazardous waste shipments.N/A–Facility does not ship hazardous waste off-site.
Does the facility store hazardous waste in appropriate storage containers?
There are requirements an automotive shop must meet if storing hazardous waste in containers (drums):
- Clearly marked with the words Hazardous Waste and the date when waste is first deposited into the container. Labels for this purpose may be available from the hauler.
- Kept in good condition and stored in a manner that minimizes risks of ruptures, leaks or corrosion.
- Kept closed except when being filled or emptied, except if volatile explosion is possible and emergency ventilation is needed.
- Inspected at least once per week for leaks or corrosion. Note: Some states may require facilities to keep a written record of these inspections. Any problems should be corrected immediately. If any corrections are made, they should be noted in a permanent record and kept on file for at least 3 years.
- Stored in a manner that minimizes the potential for accidental mixing of incompatible materials.
Yes–Facility stores waste in containers that meet the above requirements. √
No–Facility stores waste in containers that do not meet the above requirements.
N/A–Facility does not generate hazardous waste.
Does the facility meet all hazardous waste storage (quantity and time) requirements?A hazardous waste generator can store hazardous waste on-site for a limited time, according to the following requirements:
- LQGS may accumulate any amount of hazardous waste for no more than 90 days and then move it to an approved recovery, treatment, storage or disposal site.
- SQGS can accumulate no more than 13,228 lbs (6,000 kg) of hazardous waste on site for up to 180 days without permit (or up to 270 days if the shop must transport the hazardous waste more than 200 miles away for recovery, treatment or disposal).
- CESQGs have no maximum on-site time limits for storage but cannot accumulate more than 2,200 lbs (1,000 kg) of hazardous wastes or 2.2 lbs (1 kg) of acutely hazardous waste, or 220 lbs (100 kg) of acutely hazardous waste spill residues, at any time.
Yes–Facility complies with all hazardous waste storage quantity and time requirements. √
No–Facility does not comply with all hazardous waste storage quantity and time requirements.
N/A–Facility does not generate hazardous waste.
How does the facility manage/dispose of its hazardous waste?
Ships hazardous waste off-site to:
A RCRA-permitted treatment, storage or disposal facility (TSDF). √
A recycling facility. √
An interim status facility √
or An exempt facility. √
Disposes of hazardous waste on-site and is a RCRA-permitted TSDF.
√ Other–If the shop is not managing its hazardous waste by one of the above methods, the shop is out of compliance and must comply immediately.
N/A–Facility does not generate hazardous waste.
Does the facility have a written contingency plan or basic contingency procedures in place for responding to spills and releases of hazardous wastes?
If an automotive repair shop is an LQG, it must have a written contingency plan that includes the following elements:
- Instructions on what to do in the event of a fire, explosion, or release.
- The arrangements agreed to by local police and fire departments, hospitals, and state and local emergency response teams to provide emergency services.
- The names, addresses, and phone numbers of all persons qualified to act as emergency coordinator.
- Location of all emergency equipment at the facility.
- An evacuation plan.
Although a written contingency plan is not federally required for SQGs or CESQGs, it is strongly recommended.SQGs are required to have basic contingency procedures which include, but not limited to, the following:
- At all times, an emergency coordinator (employee) who is on-call or on-site and is responsible for coordinating all emergency response measures.
- Information posted next to the telephone, including: (1) name and number of the emergency coordinator; (2) locations of the fire extinguishers and spill control material; and (3) telephone number of the fire department.
- Ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures.
It is also important to check with the state and local authorities for any additional contingency plan or emergency preparedness requirements.
Yes–Facility has a written contingency plan or basic contingency procedures. √
No–Facility does not have a written contingency plan or basic contingency procedures in place.N/A–Facility is not an SQG or an LQG and is not required to meet RCRA’s emergency preparedness requirements.
Source: U.S. EPA Office of Enforcement and Compliance Assurance, EPA 305-B-03-004, October 2003.
