POLLUTION PREVENTION IN AUTOMOTIVE SERVICE

TUNE UP YOUR SHOP TO REDUCE WASTE AND

SIMPLIFY COMPLIANCE

REPRINTED Z?lZOM THE COLORADO DEPARTMENT OF HEALTH AUTQMOTNE SERVZC'E ASSOCIAllON

.POLLUTION P R E V E " PARTNERSHIP WORKSHOP

Compliled by: Recom Applied Solutions, Incorporded

TABLE OF CONTENTS

SECTION TITLE

*

1. INTRODUCTION

2, INVENTORY OF HAZARDOUS WASTE

3, POTENTIAL PROBLEM PRODUCTS

4. ANSWERS TO AUTOMOTIVE SERVICE MANAGER QUESTIONS

5. AUTOMOTIVE WASTE MINIMIZATION

6, MANAGING HAZARDOUS WASTE

INTRODUCTION. -

Environmental Regulations Can Save Your Business Money

by Greg Mears Recom Applied Solutions, Incorporated

Traditional views have it that environmental regulation of the private sector means significant additional operating costs for business and industry. No doubt this is the* case for businesses that insist on conducting "business as usual". Standard operating practices of the past are nowadays the targets of environmental laws. These laws manifest themselves in many ways to impact a business' operating costs: taxation on the use of toxic chemicals, permit fees, waste disposal costs, mandated pollution control technology, Eind time devoted to understanding and complying with regulations. In addition, compliance is no longer solely the concern of large polluting manufacturing industries. The scope of enforcement has widened to include industries comprised mostly of small businesses, such as the automotive seMce, printing, and dry cleaning industries.

The financial impact which environmental regulations have on your business depends to a large degree on the chemicals and solvents you use plus the technologies you employ. The use of old line, "industry standard chemicals, solvents and production equipment can entail numerous complicated and expensive compliance responsibilities. Hazardous and toxic substances used in inefficient and wasteful processes have played a major role in the development of environmental regulations. Unfortunately, the relatively inexpensive cost of traditional technology perpetuates its continued use and does not adequately represent its true cost to your business, let alone society.

Today's regulatory environment offers many cost-saving opportunities for those who are proactive about change rather than reactive. The news is full of stones of companies realizing cost savings on the scale of millions of dollars per year. They are doing so by voluntarily evaluating their processes from the viewpoint that reducing hazardous substance usage, " i h g waste and inefficiency, preventing pollution, and enhancing safety are not only good for employees and the environment, but also makes good business sense.

The automotive service industry stands to capitalize on new ideas and technologies as well. For example, service shops can save a lot of money on disposal costs and reduce liability by " k h g hazardous waste generation due to parts washing. Traditional parts washers use hazadous, ignitable cleaning solvents with only crude filter systems requiring periodic replacement of spent solvent. The contaminated solvent is considered a hazardous waste causing the shop owner to be regulated as a generator of hazardous waste and to assume liability for its disposal. Next generation parts washers are now available that not only clean with non-toxic and non-regulated solvents, but

also incorporate highly efficient filtering systems to extend solvent life, eliminate the need for spent solvent replacement and drastically reduce hazardous waste generation.

Auto body shops can minimize waste by looking for ways to recycle and reuse spent paint gun cleaner. Portable reclamation and vacuum distillation units can be very effective at recovering spent solvents for reuse. Although capital costs may initially appear prohibitive for such equipment, consider the rising costs of hazardobs waste disposal. With disposal costs averaging $200-$300 per 55- gallons of waste, and rising, a distiller can easily pay for itself in the first year alone.

Looking for ways to substitute hazardous for non-hazardous substances can also have its financial rewards. Non-hazardous solvents and aerosols can reduce air emissions of CFCs and volatile organic compounds (VOCs) and decrease employee safety and training responsibilities for employers. Most ozone- depleting products also come now with additional taxes by the federal government that must be paid by the users.

Throughout the industry new technologies are arising which can enable one to go beyond mere compliance to enjoy the cost savings and competitive edge that is possible when a shop is exempt from regulation. Those who are proactive and make changes for their own benefit wil l reap the rewards. And for those that do not? David Wann, a policy analyst for the P A , puts it simply by saying, "Let's face it, we either go with the flow or we don't go."

Vehicle Repair Shops BACKGROUND

Vehicle repair shops generate wastes through typical operations such as fluid replacement or parts washing. Some common waste types include:

Waste oil, lubricants and transmission fluids

Dirty caustic parts washing detergent solution

Parts cleaning tank sludge

Oily waste sump sludge

Used antifreeze

Old auto batteries

Some of these wastes may be classified as hazardous. A n y amount of haz- ardous waste must be managed properly in accordance with state and federal hazardous waste regulations.

WASTE REDUCTION Hazardous wastes generated by vehicle repair shops can be reduced by

changing practices and equipment or by recycling. Waste reduction can reduce the costs of managing hazardous waste and complying with regula- tions. The following is a list of some common waste reduction methods for vehicle repair shops. #

This Fact Sheet on Po~uriOn Prweruion p d Waste Reduction m Vehicle Rmair

PoUuim Preverdon and ‘Vasse Redia- tion Program, Colorado D e p a m of H&, to paride colorado vehick repair shops highhghts of proven source reduction and recycling practices.

was prepared the staff of the BEGIN AT THE Tor

e The shop’s owner or m m g e r must be committed to waste reduction and

Establish training programs for employees in waste reduction, hazardous

Establish incentive programs to encourage employees to design and use

pass that commitment on to the employees.

material handling, and emergency response.

new waste reduction ideas.

COLORADO O F A H E A L T H D I.: P A KT 51 E ST August 1991

WASTE ASSESSMENTS

fundamental steps: Conduct a Waste Assessment, consisting of the following

Form an assessment team.

* Identify processes and wastes produced.

r-

Evaluate existing waste control and reduction methods.

Research altemative technologies.

Evaluate feasibility of waste reduction options.

Implement measures to reduce wastes.

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IMPROVE PROCEDURES AND SEGREGATE WASTES

Become a good housekeeper, because it is the easiest and often the cheapest way to reduce waste.

Designate weather protected raw material and hazardous waste storage areas with spill containment. Keep the areas clean and organized and give one person the responsibility for maintaining the areas.

Label containers and keep lids in place to reduce evaporation, prevent contact with rainfall, and avoid spills.

Use a “first in, first out’ policy for raw materials to keep them from becoming too old to be used. Order in appropriate sizes. Give one per- son responsibility for maintaining and distributing raw materials.

Segregate waste streams for recycling and treatment, and keep non-haz- ardous material from becoming contaminated.

Prevent and contain spills and leaks.

Contain and collect asbestos dust from brake jobs for disposal.

f

USE DIFFERENT RAW ~ T E R I A L S Use recycled (rerefined or refiltered) perroleum products (oil, transmis-

Use waterless hand cleaners. Replace solvent-based compounds with detergent-based and water-based

sion fluid, antifreeze, hydraulic fluid).

.

compounds.

f-- i

2 Pollution Prevention and Waste Reduction

MODIFY PROCESSES Pre-rinse parts before using the hot tank or jet spray washer.

Remove parts slowly after immersion in solvent solution to prevent spillage.

Install drip trays or racks near solvent sinks, hot tanks, and jet spray washers to drain cleaned parts. Collect drainage and return it to the parts washing equipment.

Use drip pans to catch drips when changing fluids or working on dam- aged vehicles.

Don’t leave the solvent stream running, and cover or plug solvent sinks when not in use to prevent evaporation.

Place parts cleaning equipment in a convenient location, near the ser- vice bays to reduce drips and spills.

Use water-based pressure washing systems instead of parts washers that use solvents.

RECYCLING SERVICES Lease or purchase solvent sinks, and purchase solvent recovery equip-

Lease or purchase hot tanks or jet spray washers, and purchase aqueous

Contract with an oil recycler for waste oil collection and recycling.

Arrange for spent battery collection and recycling, or take spent batter- ies to a storage or recycling facility.

Arrange for spent antifreeze solution collection and recycling or treat- ment. Under some conditions, variances are issued for disposal of spent antifreeze to the sewer system. Contact your local sanitary district or county environmental health agency co determine if this is allowed in your community.

ment if cost-effective.

treatment equipment if cost-e ffec tive.

Use a laundry service to clean d i m rags used to clean small spills.

3

ADDITIONAL PUBLICATIONS AVAILABLE y-2.

FROM COLORADO PPWRP (I,

p, I

Hazar R Califomia Depart of Health Services, 1989.

fiazardous Waste Reduction Assesst-" Ha ndbook for Automotive Repair Shoos, Califomia Department of Health Services, 1989.

Fact Sheet: Radiator Service Firms, North Carolina Pollution Prevention Pays Program, 1989.

FURTHER ASSISTANCE Contact the Colorado PPWRP (303) 331-4430 or 331-4841 for assis-

tance with your waste assessments or for further information.

c

The Pollution Prevention and Waste Reduction

Program

of Health Colorado Department

4210 East 11th Avenue Room 260

Denver, Colorado 80220 or call (303) 331-4430

['

COLORADO Pollution Prevention and Waste Reduction 4

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DE PART M ENT O F A HEALTH

INVENTORY OF 4

HAZARDOUS WASTE

INVENTORY i

H LOR INATED SOLVENTS brake clean liquid & aerosol

i

TQ491 ISSPER MONTH

'. Complete the following inventory for you shop to see the amount of hazardous substances you use per month/year.

AROMATIC SOLVENTS

Please estimate monthly amounts (lbs or gal) purchased or brought on- site.

TOTAL LBS PER MONTH

Carburetor cleaner (x 12 Ibs per gallon)

Gasket remover

Penetrating oil

Paint stripper

Aerosol Cans

Moisture displacement/e_lectrical point contact cleaner

Dry Lubes

Vapor degreaser

Freon

Freon filter

.

Metal prepping compound

Cab cleaner-aerosol

Lacquer thinner i

TOTAL LBS PER MONTH 1

Paints

Antifreeze (x 8 Ibs per gallon)

Transmission filters 4

Fuel filters

Contaminated fuel

Parts Washer solvent (“e At5QAUcf4PARTSWASHERP(PILlUYHOLOSd0LBSOFSOLMHT;

OTHER I TOTAL LBS PER MONTH I

s

Rags, paper & cloth

Oil absorbent

Brake fluid

Oil filters

Contaminated sump waste

Aerosol gasket sealant

Floor cleaning waste

Hot tank fluid

OTHER I TOTAL LBS PER MONTH /--

I I TOTAL LBS IN ONE MONTH

\ + 1 i ’ 1 I

I

2

3 I

5

6 ~

7

0

9

10

i . .

.’-. I ’

As we will see in the following sections, all these hazardous substances have the potential t o become regulated hazardous wastes. The point here is that the

NOTES I

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/

MAJOR SOLVENTS IN THE AUTOMOTIVE INDUSTRY

Weightwolume Factors

- weight (lb) (2)

Compound dcm3 lb/ft3 lb/gal(1) of 55 gal. drum

gasoline ether ethyl alcohol acetone J m ~ e n e water trichloroethane chloroform Freon-113 carbon tetrachloride

.690

.736

.791

.792 399 1 .oo 1.339 1.489 1.564 1.594

43.0 45.9 49.4 49.4 56.1 62.4 83.59 92.96 97.61 99.5 1

5.74 6.12 6.58 6.59 7.48 8.32 11.17 12.43 13.01 13.26

316 337 362 362 411 458 614 684 716 729

(l) Conversions: 1 m3 = 264.2 gal 1 ft3 = 7.48 gal

(2) Temp. 20°C

POTENTIAL *

PROBLEM PRODUCTS

Potential Problem Products

The following automotive products are known t o typically contain chlorinated solvents that can cause the spent products t o be considered hazardous waste or can cause major cross contamination problems in your shop for used oil or for parts cleaning solutions.

For self protection, examine MSDSs for all such products in your shop. Also examine MSDSs for all proposed product purchases before allowing them on-site. If a product contains any one of these problem chemicals as a main ingredient or in concentrations greater than IO%, it would be advantageous to find alternatives to its use.

PRODUCT

Brake Cleaner

PROBLEM INGREDIENTS

1,1,1 Trichloroethane (TCA, Trich) Perchloroethylene (PERC)

Parts Washing Solvent Stoddard solvent / Mineral Spirits - Toluene - Xylene - Benzene - 1,1,1 Trichloroethane

Gasket Remover Methylene Chloride

Paint Stripper Methylene Chloride

Carburetor Cleaner (aero s 01) Toluene

Methyl Ethyl Ketone (MEK)

Xylene

PRODUCT

Oil Additives/ Treatments

Carburetor Cleaner/ Cold Tank

Moisture Displacer

Aerosol Grease

.- Moisture Sealants .

Dry Lubricants

Contact Point Cleaner

i -~ PROBLEM INGREDIENTS

Chlorinated Paraffins

Methylene Chloride Cresylic Acid Dichloro Benzene

1,1,1 Trichloroethane

1, I, 1 Trichlo roethane Methylene Chloride

1,1,1 Trichloroethane

1,1,1 Trichloroethane Methylene Chloride

1,1,1 Trichloroethane

ELIMINATE CHLORINATED SOLVENTS FROM YOUR SHOP! Vehicle Maintenance Chemicals and Their Hazards Common Automotive Chemicals and Their Hazards

Brake Cleaner 1,1,1 Trichloroethane Perchlorethylene

Methylene Chloride I Cold Tank Cart, Cleaner

Parts Washer Solvent Stoddard Solvent, Toluene, Xylene, 1,1,1 Trichloroethane, Tetra Chloroethylene

Gasket Remover ,I Methylene Chloride

Electrical Safety 1,1,1 Trichloroethane Solvent

Antifreeze

Hot Tank Cleaner Sodium Hydroxide, Lead, Chrome

Steam Clean Soap Sdium Hydroxide, 2-butox yethano

Spot Removers 1,1,1 Trichloroethane

Tar Remover Toluene

Lacquer Wash M.E.K. & Toluene

Prep sol

Paint Stripper

Stoddard Solvent, Toluene

Methylene Chloride

Cancer

I Cancer E.H.W.

Nerve Damage, Some D.W. Carcinogenic Compounds

Cancer E.H.W. I Possible Carcinogenic E.H.W. Cardiac Sensitizer

Toxic Possible D.W.

Caustic Possible E.H.W.

Systemic Toxin Possible D.W.

Possible Carcinogenic E.H.W. Cardiac Sensitizer

Possible Carcinogen D.W.

Liver & Kidney New T.C.L.P. Damage Listed D.W. Possible Carcinogenic

Nerve Damage D.W. Possible Carcinogenic

Cancer E.H.W.

Liver & Kidney D.W. Damage

ANSWERS TO AUTOMOTIVE

SERVICE MANAGER QUESTIONS

Answers to Automotive Service Manager Questions

Through consultation with various enforcement offices of the Colorado Department of Health, the following general guidance has been issued in response to many of the automobile service industry's most important environmental concerns.

NOTE: These responses have been issued as general guidance and may not apply to your situation.

Fluids Management

Is waste oil regulated as a hazardous waste?

Waste oil is not regulated as a hazardous waste if it is not mixed with hazardous wastes (solvents, antifreeze etc.) and if it is disposed of through a recycler (energy recovery). Waste oil may not be disposed of in a dumpster. If waste oil is disposed of via incineration or landfilling it is considered hazardous waste and must be manifested.

How is waste antifreeze regulated?

Some antifreeze may meet the toxicity characteristic for hazardous waste due to lead content. Check with the manufacturer or have a TCLP test done t o be certain. If antifreeze is t o be re-used without undergoing treatment or recovery it is not regulated as a hazardous waste and does not need t o be manifested. If treatment or recovery is necessary prior t o re-use, or if disposed of, a hazardous waste determination must be made or it must be assumed t o be hazardous. If the antifreeze is hazardous waste it must be-manifested if sent off-site t o be recycled, recovered o r disposed of.

How must waste brake fluid and transmission fluid be managed?

These waste fluids are usually not considered hazardous waste. They may not be disposed of in a dumpster, and they require permission from local waste water authorities in order t o be sewered. If they cannot be recycled or re-used, consider combining them with waste oil for energy recoGery. Check with waste oil vendor before doing this however.

How must off-specification or contaminated ,paint be managed?

Many waste paints are hazardous waste due to the toxicity characteristic (concentration of metals or solvents). In either case, wet paint may not be put in the dumpster, and requires permission from local waste water authorities prior to sewering. Only dry, non-hazardous paint may be placed in a dumpster. Otherwise, it must be disposed of via energy recovery, incineration o r land disposal after solidification. It may potentially be acceptable in waste oil if non-hazardous and accepted by oil recycler.

How must waste solvents be managed?

Almost all waste solvents are hazardous waste (ignitability o r listed chemicals) and must be manifested for disposal. They may never be placed in the dumpster and should not be sewered. Waste solvents may be disposed of through energy recovery or incineration. Keep segregated on- site to avoid cross-contamination of non-hazardous wastes. Especially avoid contamination of waste oil.

Solid Materials Management

How must used oil filters, transmission filters and fuel filters be managed?

These filters may not be disposed of in a dumpster if they still contain fluids. AI1 fluid must be drained from the filters. The dry filters ma i then either be recycled as scrap metal or disposed of in a dumpster. If wet filters are disposed of in a dumpster it may be considered illegal disposal of hazardous waste.

How should used batteries be managed?

.Used car batteries a re considered hazardous waste unless they are recovered and re-used. They are prohibited from dumpsters. If disposed of without being recovered they must be manifested and regulated as hazardous waste. Used dry cell batteries may be hazardous if they contain mercury. Check the MSDS or contact the manufacturer. If they do not contain mercury they may be disposed of in a dumpster, otherwise an alternative method must be found.

How must dirty rags be managed?

Non-disposable rags that are picked up by laundry services for re-use are not regulated as hazardous waste to date. A waste determination must be made for rags that are not re-used but disposed of in a dumpster or through incineration. Solvent-contaminated rags are considered hazardous waste if they are disposed of rather than laundered and contain listed hazardous wastes. Other liquid wastes should not be added t o dirty rags as a disposal method.

When is a container empty and fit for disposal?

Product containers are considered empty when, (1) all wastes have been removed that can be removed using commonly employed practices, (2) no more than one inch of waste remains at the bottom of the container, (3) no more than 3% of the product remains in containers that are less than 110 gallons in size. Containers not considered empty may be regulated as hazardous waste depending on the type of waste remaining. Emjty containers may be disposed of in dumpsters, returned t o suppliers for reconditioning or sold as scrap metal.

Recycling

Is waste that is recycled and re-used considered hazardous waste?

Yes, if the waste must be treated in some way in order to be re-used. For example, if antifreeze is hazardous waste and is removed from site by a vendor and is treated by the vendor prior t o re-use, the generator is regulated and must sign a manifest. If the substance may be used again without undergoing treatment it% not a hazardous waste but rather a usable product.

Di s p o s a1

When a parts washer is serviced, who is the waste generator?

The user of the parts washer is considered the waste generator, and is responsible for the waste's proper disposal.

Once a waste leaves site, who is liable for its management and disposal?

The generator of the waste is liable for up to 30 years for the waste's management and disposal.

Air Pollution

Are body shops and garages required to obtain air pollution emission permits?

Only those facilities engaged in spray painting and paint gun cleaning with solvents need apply for an air pollution permit. Permits are required 'for sources that emit over one (1) ton of volatile organic compounds per year. Applications must be submitted t o the Colorado Department of Health's Air Pollution Control Division, or the local county health department.

Must CFCs from auto air conditioners be recovered?

CFC recovery is not a state law. However, it is mandatory in some cities and counties in the state. The city and county of Denver, city of Boulder and city of Fort Collins have CFC recycling laws.

Car Washing

Is effluent from car washing regulated?

Car washing effluent i's prohibited in storm sewers without a permit. Permission from local waste water authorities is required for discharges to sewers.

oil is the largest single source of oil pollution in U.S. waterways. Most

dumped by "do-it-yourselfers".

In 1960, service stations performed 90% of automotive oil changes. Today about 60% of automotive oil is changed at home and much is dumped in storm drains, poured on the ground or sent to a landfill with the trash.

In Colorado, more than a million gallons of used motor oil is thrown away each year.

Every two weeks, "do-it yourselfers" pour used motor oil down sewers in amounts equal to that spilled by the Exxon Valdez. Thah approxi- mately 240 million gallons each year. (American Pettoleurn Institute)

THE USED OIL PROBLEM

One pint of oil can produce a slick of approxi- mately one acre on water.

Used oil may contain toxic chemicals which are harmful to the environment and public health.

Discarding oil wastes a valuable resource.

Improper disposal of oil directly on the ground, down a storm sewer, or in the trash threatens the quality of our water and environment.

WHAT TO DO WITH USED MOTOR OIL

NO ! Waste oil dis- posed of in landfills or dumped on the ground can seep into the ground-

water, which may contaminate wells or surface

NO ! When dumped into storm drains or gutters, oil may be camed into lakes and streams

NO ! Using waste oil to control dust on roads or al- lowing a car to leak oil poses a threat to the environment.

Oil can seep into groundwater or be carried by rain and snowmelt as runoff into lakes, streams or wetlands.

YES ! RECYCLE YOUR USED OIL! ! ! Oil is a valuable resource which can be reused

WHY RECYCLE ? ?

It takes 42 gallons of crude oil to produce 2.5 quarts of new lubricating oil. Just one gallon of used oil can be re-refined into the same 2.5 quarts.

Recycling used oil could reduce national petroleum imports by 25.5 million barrels of oil per year.

Recycling used oil can significantly reduce the amount of oil which reaches Boulder's ground and surface water.

,

HOW TO RECYCLE

After you have changed the oil in your car, truck or other motor vehicle, pour the waste oil into an unbreakable container, seal, it, label it and take i t to a used oil collection/recycling center.

A used plastic milk jug with a cap works well as a container.

Do not mix any other materials with used oils.

Have your car serviced to prevent or stop oil leaks.

d

when properly cleaned.

MANAGING *

YOUR WASTE

Logging Hazardous Wastes

The following hazardous waste inventory forms are designed to help shop owners and managers determine their hazardous waste generator category and can also help control the amount of hazardous wastes generated and accumulated on-site.

Each week you should log the generation of each type of hazardous waste listed on the form. Approximate weights in pounds are appropriate since this is a planning tool rather than a reporting document. if used diligently, this tool can be a major aid in maintaining your lowest possible hazardous waste generator category, be it conditionally-exempt or small quantity generator.

'NOTE: The wastes that are listed 'are considered potential hazardous wastes. You should only log those wastes that you know to be hazardous.

GUIDELINES FOR LOGGING WASTES: i ) %< ,:

0 . Always use pounds as your unit of measure. Refer t o MSDS sheets for conversion from gallons to pounds.

Always accumulate and carry forward the weight in week one into week two, and from week two into subsequent weeks.

At the end of the calendar month add up the total amount of hazardous waste generated and determine your generator category.

All the hazardous waste generated in a month must be managed according t o the regulations applicable t o conditionally-exempt, small quantity o r large quantity generators. For example, if 200 pounds are generated in April, all that waste is managed by conditionally-exempt regulations. If'in May 300 pounds are generated, all of May's waste is managed according to small quantity regulations.

MANAGEMENT MONITORING FORM Month

MANAGEMENT MONITORING FORM Month

PRODUCT WEEK 2

WEEK 4

WEEK 3

WEEK 5

Brake Fluid

DATE 1 1 1 1 1 1

Ant if reeze

1 1 1 1 1 1 1 1 DATE

Carburetor Clean

1 1 1 1 DATE - Aerosois

1 1 1 1 1 1 1 1 DATE

Parts Washer Solvent Changed-Out

1 1

1 1

1 1 I I .

I 1

1 1 DATE Rags

1 1

Waste Oil

1 1 1 1 I . ! DATE

Contaminated Sump Waste

1 1 1 1 1 1 DATE

PRIOR MONTHS TOTAL

TOTAL .... .e......

a

POLLUTION PREVENTION IN PAINTING OPERATIONS *

REDUCE WASTE AND

SIMPLIFY COMPLIANCE

REPRXNTED FROM W E MINNESOTA TECHNICAL, ASSISTANCE PROGRAM

. . . . is available from MnTAP.

. ..

WASTE MiNLMIZATION CHECKLIST FOR PAINTING OPERATIONS

Waste minimization is the reduction in quantity or toxicity of hazardous waste that is generated, treated, S* -ed, or disposed. It includes both source reduction activities (activities that reduce the amount of

d e oenerated) as well as recycling activities (activities that recover part or all of a waste stream). Hazardous waste (as well as other waste and emissions) generated by painting operations can be minimized by handling and storing materials properly, following better operating procedures, modifying processes, and recycling. The following is a list of common waste minimization techniques that can help reduce the quantity of hazardous wastes generated.

MANAGEMENT STRATEGIES I Develop a written statement of commitment to waste minimization Set specific reduction goals (e.g., 50% reduction in hazardous waste) Perform a waste audit Set up a training program for employees on hazardous materials handling and

hazardous waste " i z a t i o n 7 .

i I Set up an incentive program to solicit waste minimization ideas from employees t

IHANDLING AND S T O ~ G MATERLALS i

Institute inventory control Designate a place for raw hazardous materials and for hazardous waste,

Label all materials properly and keep covered to prevent spills i E Use a first-idfist-out policy for paints and other materials and a void over-purchasing

with spill containment and weather protection 70 I 1 Return expired paints and other materials to the suppLier Segregate wastes

Keep hazardous waste separate from non-hazardous waste - E Keep recyclable waste separate from non-recycla ble waste Work on spill and leak prevention

Inspect tanks, pips, valves, and seals for leaks and repair them Provide for adequate capacity in tanks and vessels Keep a record of spills and note why they happen

i i ! !PAINT STRIPPING OPERATIONS

I 1-1 Replace solvent s,tnpper 6th aqueous detersent or pressurized water I I Use non-phenolic solvents

---I PROCESS MODIFICATION Plastic media blasting and cryogenic coating removal High pressure water blasting @o wer washing) Hot caustic/salt baths

Painting Operations Waste MininizzIion Checklist, page 2

Segregate waste streams Lnspect parts before painting Minimize the number of colors used when painting Paint with light colors before dark ones to " i z e the number of coats needed Dedicate tanks to certain colors/paint &pes (e.g., white paint) to minimize clean-up Operate spray equipment properly: spray pepndicular to surface and

YJNTING OPERATIONS

Dry powder coating systems Electrocoa ting X g h Volume Low Pressure (HVLP) spray guns Electrostatic spray guns

ZQUIPMENT CLEANING OPERATIONS

Use less solvent for cleaning - avoid unnecessary cleaning Use spent ("dirty") solvent to initially clean painting equipment Use hot, pressurized water in place of solvents

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RECYCLING

Distill spent solvents/thinners on-site Recycle solvents/thinners via a solvent recycling senice Rework off-specification/left-over paint products into new products Follow spill cleanup methods that allow for recycling of spilled paint Explore waste exchange possibilities for off'iiication/out-of&te/lefi-over materials

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