Vehicle and Equipment Maintenance - InfoHousesave you money. Waste reduction is ... Gasoline mixed with water ... identified by informationon MSDS or on the results of a toxicity test

VEHICLE & kQlJ lPMENT

MAI NTE NANCE 2"" EDITION

A Waste-Reduction and Management Resource

LINCOLN-LANCASTER COUNTY HEALTH DEPARTMENT 31 40 "N" STREET LINCOLN, N E 6851 0 M. JANE FORD, HEALTH DIRECTOR July 1997

ACKNOWLEDGMENTS The first edition of this work was published in August 1991 and was a project

of Jon Dorsey and Mike Halferty, intems from the University of Nebraska. This second edition reflects updated information, includes some agency name changes, and contains more recent references to new businesses and contact data.

Edition I All the shops that initially agreed to be interviewed by the University of Ne-

braska intems working on this project deserve a great amount of credit. This document would not be possible without their help. Lincoln-Lancaster County Health Department personnel, both those currently employed and those who worked on gathering and certifying the original information provided invaluable assistance. The people who developed the first edition of this checklist include: Dick Slama, Connie Kube, Harry Le Duc, Pat Wortman, and David Wisch. Funding for publishing and distributing this booklet is provided by the Nebraska Department of Envi- ronmental Quality (NDEQ).

from the Hazardous Waste Reduction Checklist: Automotive Repair Shops (1 988), Toxic Substance Control Division, Califomia Department of Health Services. (Copies of this checklist can be obtained by calling the Alternative Technologies Section of the California Department of Health Services at 91 6-324-1 807.)

Portions of this original material were taken directly from or were adapted

Edition 2 This edition represents a second, extensive revision of the checklist. A very

special thank you to Phil Rooney, Ph.D. (Community Health Educator 11) for editing and publishing this second edition. Thank you to Beth Mann and Brock Hoegh (Intems in the Special Waste Program) for assisting with updating waste recycling service provider listings. Thank you to Jim Hadley, P.E.; John Steinauer (both Environmental Engineers 11); and to Chris Shcroeder (Environmental Engineer I) for commenting on the pollution prevention and waste reduction technical portions of this checklist.

Angela Maruhn, Environmental Engineer I1 Pollution Prevention-Air Quality Section

DISCLAIMER The mention of commercial products, commercial

services, their sources, or their use in connection with material contained in this document is not to be construed as an actual or implied endorsement of said products or services. Some are mentioned for purposes of illustration and by example only.

TABLE OF CONTENTS

Introduction ............................................................... The Purpose of This Resource .................................................... How to Use This Resource ......................................................... Types of Waste ........................................................................... How to Handle Waste ................................................................. Pollution PreventiodWaste Reduction .......................................

Checklist ...................................................................

Storing Products and Wastes ...................................................... Preventing and Cleaning Up Spills .............................................

Shop Rags and Wipes ........................................................

Managing Water-Based (Aqueous) Cleaning Solution Waste ...

Purchasing and Inventorying Materials ......................................

Managing Solvent Waste ............................................................

Cleaning Solutions for Vehicle Maintenance Shops .................. Managing Used Antifreeze ......................................................... Managing Air Conditioning System Wastes .............................. Managing Used Oil. Oil Filters. and Contaminated Fuel ...........

Burning Oil is Not Recycling ............................................ Used Oil Filters ..................................................................

Managing Miscellaneous Repair and Shop Wastes ...................

Hazardous Lighting Waste Disposal ................................. Trap Wastes ....................................................................... Guidelines for Disposing of Semi-Liquid Wastes .............

Worker Safety & Right-To-Know .............................................. Emergency Planning & Community Right-To-Know ................

Batteries .............................................................................

Appendix ................................................................... Contacts ...................................................................................... Inserts

Recycling Services Waste Management and Disposal Services Internet Information Resources

3 3 3 4 6 8

13 13 36 21 25 27 32 36 40 44 47 47 50 52 53 61 65 69 73 76

79 79

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ABBREVIATIONS AND SPECIAL TERMS

Most terms and expressions are explained in the text of this document. Most abbreviations are given in parentheses after the term or name is spelled out. For convenience, some of the more common terms are listed here.

characteristic Any one of four categories used to define hazardous waste or materials: toxicity, corrosivity, ignitablity, or reactivity; or a material or a waste that shows one or more of these characteristics.

Chlorinated A material whose name contains the letters “chlor” or “chloro,” such as “methylene chloride” or “trichloroethane.”

Halogenated

Listed

A material that contains fluorine, chlorine, or bromine.

Hazardous material(s) named (listed) on one of four RCRA lists either because the material has characteristics of a hazardous waste or because its components have been shown to be harmful to human health and the environment.

LLCHD

MSDS

NDEQ

OSHA

P2

Lincoln-Lancaster County Health Department.

Material Safety Data Sheet.

Nebraska Department of Environmental Quality.

Occupational Safety and Health Administration.

Pollution prevention (also called waste reduction, waste minimization, source reduction, or source minimization) is a behavior or process that reduces or eliminates pollution before it begins; P2 might include material purchasing choices, material substitutions, or process or equipment changes.

RCRA Resource Conservation and Recovery Act.

USEPA (EPA) United States Environmental Protection Agency.

Lin’coln-Lancaster County Health Department

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c- THE PURPOSE OF THIS RESOURCE

Using the checklist and the information provided in this booklet might save you money. Waste reduction is one of the best ways to reduce costs and simplify special and hazardous waste management efforts. Waste reduction also decreases your liability and protects the environment. The waste reduction resource provides you, the vehicle or equipment repair shop owner or manager, with information that will help you reduce the amount of hazardous and special waste generated in your shop.

The appendix of this booklet includes a list of other resources for your information. In addition, it includes lists of waste management and recycling service providers.

Follow the Table of Contents to guide you through the sections of this booklet that apply to your business. Read the introduction to each section carefblly before completing it. Owners of small, one-person shops might need to spend only a few minutes in each section of the resource. Owners or managers of larger shops will want to take more time due to their added variety and volume of wastes. If your shop moves, grows, or changes its services, go over the resource again to

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see if any new waste reduction strategies or regulations apply to your new situation.

This document identifies and describes some regulations that apply to vehicle or equipment maintenance shops. This information is provided to help you identify the regulations that apply to your shop and to guide you in complying with them. Contact the Lincoln-Lancaster County Health Department (LLCHD) at (402) 441-6238 for additional information about regulations specific to your business.

This is not a regulatory document. You will only need to complete the sections that apply to your shop. You willfind it most helpful to keep the document in yourfiles for future reference.

TYPES OF WASTE

Identifying the type or types of waste that your business generates and disposes of is important. Such identification helps you determine what waste reduction and waste management options exist for your business. You can also identify which wastes are the most numerous and which are costing you the most money to discard. The following definitions will help you to identify the types of waste generated in your shop.

Solid Waste-Defined in the Resource Conservation and Recovery Act (RCRA) as “garbage, refhe, or sludge or any other waste material.” According to RCRA, a solid waste can be a solid, a semisolid, a liquid, or a contained gas.

Special Waste-A solid or liquid waste that requires special handling “because of its quantity, concentration, or physical or chemical or infectious characteristics” according to RCRA.

Hazardous Waste-Special waste that “may cause, or significantly contribute to, an increase in mortality or an

Lincoln-Lancaster County Health Department 5

increase in serious irreversible, or incapacitating reversible, illness; or pose a substantial present or potential hazard to human health and environment when improperly treated, stored, transported, or disposed, or otherwise managed,” according to RCRA. The LLCHD does not regulate hazardous waste. For more information contact the Nebraska Department of Environmental Quality (NDEQ) at (402) 47 1-42 17.

Wastes in the Shop

c- Most vehicle or equipment maintenance and repair shops generate some types of special or hazardous wastes. The list below identifies some of the common kinds of wastes generated. S means the waste is a “special waste”; H means the waste is a “hazardous waste”; S/H means the waste might be either type of waste.

S Used oil, lubricants, greases, hydraulic fluids

H Used solvents, thinners, degreasers

S/H Used alkaline, water-based, detergent parts-cleaning solution

S/H Mud or sand trap waste

H Parts-cleaning tank sludge

S Used antifkeeze

H

H

H

H

S

H

H

S

S/H

Used lead acid batteries

Fluorescent lighting waste

Spilled gasoline or diesel fuel

Gasoline mixed with water

Empty refrigerant containers

Refrigerant @.e., fkeon)

Lead wheel weights

Used oil filters

Shop rags contaminated with other wastes

Hazardous Wastes

In general, a waste is hazardous if it is listed as hazardous in RCRA. This is a “listed hazardous waste.” It can also be classified as a hazardous waste if it exhibits one or more of the characteristics

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described in RCRA. If it is toxic, corrosive, ignitable, or reactive according to the definitions in RCRA, a waste is said to be a “characteristic hazardous waste .”

If you mix hazardous material or waste with nonhazardous materials or waste, the entire load is considered hazardous. This concept is called the “mixture rule.” For example, when you use floor-dry to clean up a hazardous spill in your shop, the floor-dry becomes a hazardous waste. Some materials (either hazardous or nonhazardous) can react with hazardous materials causing a fire or an explosion. For this reason, it is important to segregate your wastes. That is, keep hazardous materials separate from nonhazardous materials.

For help in determining if your waste is a hazardous or a special waste, call the LLCHD at (402) 441-6238.

How TO HANDLE WASTE

Every business generates waste. Businesses that generate hazardous wastes have to take special precautions. Use the chart on the next page to guide you in your proper special or hazardous waste management.

Businesses are responsible for proving that their waste is not hazardous. Local governments reserve the right to be stricter than federal or state agencies when determining whether wastes are acceptable to be landfilled, treated at waste water treatment facilities, applied to the land, or incinerated.

You can find out about local regulations by calling the LLCHD at (402) 441-6238. To obtain information about or copies of state regulations, call the NDEQ at (402) 471-3557.

7 Lincoln-Lancaster County Health Department

Waste Handling Flowchart

Go through thisflow chart, following each step for each waste type you generate in your business or shop.

Complete a Special Waste Inventory for each Business Facility.

Make Operational Changes or

Material Substitutions

YeS

Contact Dispose of Any

Quantity at a Generate 2220 Licensed

Hazardous Waste Pounds in One Disposal Facility. 47 1-42 17.

No * Waste is a listed waste or has characteristics of a hazardous waste; also identified by informationon MSDS or on the results of a toxicity test

In Nebraska, businesses that generate special or hazardous waste must obtain a special waste permit before disposing of the waste in a licensed Nebraska landfill. To help Lincoln and Lancaster County businesses determine whether their wastes are special or hazardous wastes (or both), the LLCHD requires businesses to complete a Special Waste Inventory. Permits to dispose of the waste in the Lincoln landfill, in the wastewater treatment plant, by land application, or by incineration may be obtainedfiom the LLCHD If you plan to dispose of the waste in a landfill other than Lincoln's city landfill, contact NDEQ at (402) 471-4210.

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POLLUTION PREVENTION / WASTE REDUCTION

This booklet is dedicated to the principle of Pollution Prevention (P2), which is also called waste reduction. This principle holds that it is cheaper, easier, safer, and better to manage, clean up, or dispose of waste if there is less of it and if it is not hazardous.

Therefore, the first step in managing wastes is to reduce the amount or the toxicity of the waste a business generates. It is easier to grasp this concept if you think of a ranking of waste management options or decisions. Going from the best choice at the top to the least desirable choice at the bottom, the ranking of waste management choices is usually called the “Waste Management Hierarchy.”

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Tbe Waste Management Wierarcby

The Waste Management Hierarchy, or list in order of preferred option, looks like this:

0 Reduce c5r

0 Reuse dl

0 Recycle

0 Treat

0 Discard

The concept of the hierarchy is that it is best to reduce the amount of material you purchase or use so there is less waste generated. This method is sometimes called “source reduction.” You can also reduce storage problems and costs, handling costs, and disposal fees by reducing the amount of material you purchase.

The ideal practice is to substitute less-hazardous or less-toxic materials for those that pose a threat to human health and the environment. You might need to or might decide to change processes

Liricoln-Lancaster County Health Department 9

in order to use less-hazardous materials or to use the materials you currently purchase more effectively.

Reuse what you cannot reduce, what you absolutely must have. For example, rather than allowing oil to spill from a machine or leak or collecting the oil in a pan and discarding it, you can pour the oil back into the machine. Many times solvents, oils, and rinse water can be reused. Sometimes, you might need to add equipment to operating systems in order to reuse or extend the life of materials you use.

Recycle what you cannot reuse. Recycling breaks the material down into smaller parts or reprocesses it into separate components. This new material is then reformed into new products. Most people are familiar with the concept of recycling paper or cans. Many materials (such as motor oil, antifreeze, some solvents, and steel) can be recycled.

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Treat hazardous or special materials that you cannot recycle before you dispose of them. Treatment removes some or all of the hazardous materials fiom the basic material. Treatment can also chemically change the components of a waste so they are no longer hazardous. How much hazardous material is removed depends on a number of factors. For example, waste water containing solvents and sludge should be treated. Water treatment might be able to remove all the sludge and most of the solvents. The treated water can then be sent to a stream or body of water.

Discard or dispose of wastes that have been treated or that do not need to be treated only if you have no other option. Sometimes, you will need to complete a Special Waste Inventory and obtain a Special Waste Disposal Permit before you will be allowed to dispose of certain wastes. Disposal is always the last and least preferred choice.

The Best Way

The LLCHD encourages business owners to look at pollution prevention (P2) or waste reduction as the best waste management

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choice you can make. Waste reduction or pollution prevention (P2) protects your health and the health of your workers as well as our environment. It can also reduce your costs in three important ways.

First, since you will not be producing as much waste, the chances of improper disposal or accidental spill (and the resulting risks and costs of environmental cleanup) are reduced.

Second, less waste can also mean less exposure to hazardous substances for your employees. You can reduce insurance costs and health care costs by providing a safer workplace.

Third, less waste (especially less hazardous or special waste) means that you have less waste to discard. You can reduce and perhaps eliminate disposal permit fees and other costs (such as storage and hauling).

The LLCHD encourages business owners to explore options that will reduce the amount of wastes generated. We have a team of experts who can assist you in analyzing your business and recommending options. Although we do not endorse and do not recommend particular outside resources, the appendix of this booklet includes a partial list of consultants and other agencies that can help you with your particular concerns.

Organizing Your Waste Reduction Efforts

To be successful, you must organize your waste reduction program or efforts. It will not be difficult to organize your efforts, but it might take some time when you start. The following eight principles of waste reduction can help you organize your efforts.

P Be committed to waste reduction. Make it a real priority in your business.

Lincoln-Lancaster County Health Department 1 1

P Know the types of hazardous materials you use, the types of hazardous waste you generate, how you generate that waste (what process produces which waste), and how much waste you generate.

P Employ good housekeeping (such as properly storing materials, properly handling materials, repairing and replacing equipment as needed, and monitoring material use) in order to reduce spills and other losses that cost you money.

> Store different types of waste in separate, clearly labeled containers. Make sure that all containers are leakproof and properly closed or sealed. Take care when filling containers with hazardous material to reduce the risk of spills. Obtain a Material Safety Data Sheet (MSDS) from suppliers for all materials you use.

P Train all employees in hazardous waste m- handling and the waste reduction methods specific to your business.

k Be aware of the hazardous materials rules and any other environmental or waste

- - management regulations that apply to you. Assign an employee to keep track of regulations. Have this contact person maintain a file of hazardous material information, pertinent telephone numbers (of suppliers, consultants, and regulatory agencies), and a short record of telephone calls (such as the date of the contact, with whom the contact person spoke, and what topics were discussed).

> Keep up-to-date on new technologies for waste reduction. The University of Nebraska-Lincoln’s Engineering Department, LLCHD, and NDEQ are good sources of information about new technologies. Trade

12 Vehicle Bz Equipment Maintenance

magazines, newsletters, trade associations, and vendors are also good sources of information.

Use this manual to guide you in your efforts to organize your waste management records and begin better management practices. You will find practical guidelines and useful tips throughout this resource. If you have any questions about the material presented in this booklet or if you wish to have further information, call the LLCHD at (402) 441-8040.

* * * * *


CHECKUST

Check orfill in the response below each question. If your answer is NOT in bold, capital letters, refer to the right-hand column for information on how to reduce or handle your waste products.

A. PURCHASING AND INVENTORYING MATERIALS Raw materials are the chemicals and other materials that you obtain or use in your business, If you allow these supplies to become too old to be used, they can become hazardous waste. A properly managedhventoly can greatly reduce operating costs.

1. Do you minimize your stock to keep supplies from becoming too old to be used? 0 YES 0 No b Do not stockpile perishable supplies. These

perishables can include some solvents that degrade when exposed to sunlight or materials that evaporate or harden when exposed to air such as some waxes or paints. Perform inventories annually to prevent the accumulation of supplies that might become obsolete due to changes in business procedures and processes.

a 14 Vehicle er Equipment Maintenance

2. How often do you inventory supplies in order to identify and reduce unnecessary accumulation?

B Order smaller quantities of materials and use up the materials as they come in. You can easily rotate and maintain your stock by labeling, dating, and inspecting new material containers as they are received. Keep simple records or the dates of receipt and use these to reduce overstock and material degradation. Conduct a full-scale inventory of raw materials each year.

3. If your shop keeps large amounts of supplies, do you use a first-in, first-out material usage policy to prevent materials from deteriorating in storage? 0 YES 0 No % Use the oldest stock3rst. This is the ‘tfirst-in,

first-out ” policy. This policy will help prevent the accumulation of outdated material.

4. Do you maintain and enforce a clear policy of using raw materials and supplies only for their intended purposes? 0 YES 0 No % Some products are not meant to be used for

certain jobs. For example, do not use a parts- cleaning solvent to clean your shopfloor. Solvents are expensive. Using them for purposes other than parts cleaning will result


in added costs to your business. In addition, if the solvent contains a listed substance (one that is named by RCRA as being hazardous) or contains a substance that has hazardous characteristics, any used solvent and any waste that comes into contact with the solvent can also become hazardous. It is also a good idea to use materials that have the least amount of hazardous or toxic substances in them that will do the cleaning job needed.

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a 16 Vehicle 8T Equipment Maintenance

B. STORING PRODUCTS AND

WASTES Additional hazardous waste might be generated ifraw materials or hazardous wastes are stored improperly. Store these items in closed containers. A locked covered, indoor area with a concrete floor and curbs for spill containment would be an ideal place for hazardous material and waste storage. It is good practice for any business to check the storage area weekly to make sure no leah have occurred and to keep a record of these inspections. Weekly inspections are required ifyou generate 220 pounds of more of hazardous waste in a month.

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1 . How are hazardous wastes and raw materials stored?

Hazardous Raw Wastes Materials

INDOORS b In Lincoln, contact the Bureau of Fire

Prevention at 441 - 7291 for information about the requirements for storing waste oil and flammable materials. Ifyou live three or more miles outside the Lincoln City limits in Lancaster County, contact the State Fire Marshal at 471-2027. Call the NDEQ at 471- 421 7 for information about other hazardous waste storage requirements.

Outdoors

COVERED

Uncovered % A covered storage area is important because

rain water can increase the volume of waste or contaminate raw materials. Also, exposure to sunlight can change the characteristics of raw materials or dangerously raise the pressure inside sealed containers. Keep individual containers closed to prevent evaporation, spills, or contamination.


Hazardous Wastes

DIKED CONCRETE SURFACE

Undiked Concrete Surface

Asphalt Surface

Dirt Surface

Raw Materials

% Concrete is better than asphalt or dirt, and a diked pad or recessedfloor area contains spills more eflectively than aflat area. A sloping concrete pad wouldJirrther enhance spill containment. Protect sanitary sewer drains from spilled material. A diked concrete pad built outside should have a drain valve and oil trap that removes rain water while holding petroleum products. Contact the LLCHD at 441 -6238 before disposing of petroleum-contaminated water.

LOCKED

Unlocked % Unscrupulous individuals can deposit hazardous

wastes in unlocked containers, increasing disposal costs. Also, unauthorized persons may enter the storage area and harm themselves or spill the waste.

2. Are storage areas inspected weekly to ensure that containers are not leaking and are stored properly? 0 YES 0 No

Do you keep a log of inspections? 0 YES 0 No % Weekly inspections ofler the best protection

against leaks and spills. In some cases, such inspections are required by law. A good time to inspect storage areas is during raw materials inventory. Check containers for leaks and proper labeling. Keeping a log helps you ensure that all inspections and repairs are

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performed in a timely manner and on a regular schedule.

3 . Are different waste types stored in separate containers? 0 YES 0 No % Waste reduction requires that you separate

wastes. Mixed wastes cost more to recycle, if they can be recycled at all. Further, disposal of mixed wastes costs more, Check Material Safety Data Sheets (MSDSes) to ensure that incompatible raw materials and wastes are note stored together.

4. How long are large quantities of hazardous wastes (such as chlorinated or flammable solvents) usually stored?

Do you keep a log of hazardous waste storage (quantities and length of time)? 0 YES 0 No % Between 220 and 2200 pounds of hazardous

waste in containers labeled “Hazardous Waste” may be stored for up to 180 days. Afer 180 days, a hazardous waste storage permit will be required. The container is dated and the time period begins once 220pounds (about 25 gallons) of hazardous waste has been collected. Those businesses generating more than 2200 pounds of hazardous waste in a month may store the waste on-site for 90 days. Contact the NDEQ at 471-421 7 for other


storage requirements. Keeping a log of the amount of waste you store and for how long you store it will help you reduce the amount of waste on hand and ensure that you do not keep it on site longer than you should.

5. Do you have an underground storage tank (UST)? 0 Yes 0 NO rb All underground storage tanks (USTs) need to

be registered with the State Fire Marshal at 471 -2027. Businesses in Lincoln may register their USTs through the city’s Bureau of Fire Prevention at 441-7291. Ifyou plan to have the tank removed, you also need to contact the Bureau of Fire Prevention at 441 - 7291. Ifvou live three or more miles outside the Lincoln City Limits in Lancaster County, contact the State Fire Marshal’s ofice at 471-2027. Also contact NDEQ at 471-421 7 ifhazardous waste is stored in the underground tank.

6. Are pesticides stored in the shop? 0 Yes 0 NO rb Pesticides must be stored in a separate area.

Do not store them where they might come in contact with other raw materials such as oil or antij-eeze or where employees or customers might be accidentally exposed to risk.

7. Are all containers, including A

DANGEROUS v nonhazardous material and waste containers, labeled? I l l YES 0 No rb Labeling all containers can prevent many

problems. Costly mistakes can be made ifthe wrong chemicals are used. Ifyou store waste in unlabeled containers, you run the risk of mixing hazardous and nonhazardous wastes,

I I

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Vehicle Equipment Maintenante

increasing the amount of hazardous waste and increasing disposal costs. Any unlabeled container whose contents cannot be identijied should be treated as hazardous waste until proven otherwise. Spilled material@om unlabeled containers should also be treated as hazardous wuste until proven otherwise. Always clearly label hazardous waste containers “Hazardous Waste. ’’

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Lirrcoln-Lancaster County Health Department 21

C. PREVENTING AND CLEANING UP SPILLS g a hazardous raw material or hazardous waste is spilled then absorbed with floor-dry or some other absorbent, the material used to dry up the spill can become a hazardous waste. It might be subject to hazardous waste regulations. Also, washwater used on floors can become hazardous if the floors are heavily stained with a hazardous waste or the resulting washwater has the characteristics of a hazardous waste. Reduce this type of waste by handling all materials carefilly to reduce spills. Wipe up small spills immediately with a mop, absorbent pillow or pad, or a rag. You should use a roller press or other device to squeeze out and collect the liquid for recycling. Dirty rags usually can be laundered. During repairs, use a drip pan anytime you expect drips or leaks to occur. Keep a rag handy to catch small drips and leaks. c- .

1. Do you keep a record of how much money you spend on cleaning up spills and in disposing of the resulting wastes?

No ’ Spills can occur at any time in the best run shop. 0 Yes Hang a clipboard in a convenient spot to record when a spill occurred and why it occurred. Use this information to identifi spill prevention options that might help your shop. Many of these options are listed throughout this checklist. Options include locating parts-cleaning equipment near service bays while in use and allowing cleaned parts to drain thoroughly. Remember, minimizing spills reduces the

b. If “yes;’ what generation ofpotentially hazardous floor waste. materials are spilled?

22 Vehicle i?~ Equipment Maintenance

la. How often do spills occur?

2. What measures has your business taken to reduce the amount of materials being spilled?

3. Are employees trained in proper techniques for handling and storing raw materials and hazardous wastes? 0 YES 0 No % The amount of waste generated by spills can be

reduced ifemployees are trained to handle and store hazardous materials properly. The Occupational Safety and Health Administration (OSHA) requires that employees receive this training. The NDEQ also requires separate training for businesses generating 220 pounds (about 25 gallons) or more of hazardous waste a month. Some consultingJirms o#er employee training as part of their package of services. You can also check with trade associations and hazardous waste haulers for additional information.


4. Do your employees use cost-effective cleanup techniques? 0 YES 0 No b Avoid usingfloor-dry or cat litter boxfiller.

These materials increase the volume and weight of wastes that you must dispose of They also can make your shop even more messy. In addition, they can pose respiratory health hazards. Absorbent pads are better because they do not need to be swept up as ‘)7oor-dry” does. They also reduce costs because they can be wrung out using drum-mounted rollers. Therefore, they can be reused.

5. If you use floor-dry, do you reuse partially used floor-dry? 0 YES 0 No ’% Ifyou reuse partly saturatedfloor-dry you will

cut down on the amount of waste floor-dry you generate. You will also reduce the costs associated with waste disposal. A large barrel and a series of screens can be used to remove metals (such as nuts and bolts) that are swept up with the floor-dry.

You can also use the screens to separate saturated floor-dry Jom partially saturated floor-dry. Use a coarse screen on top of the stack to screen out materials such as nuts and bolts. Use a second, finer screen to separate the coarse, saturatedfloor-dry J m the finer, drier floor-dry. Ifyou place an opening above the second screen, you can remove the coarse, saturatedfloor-dry for possible disposal or reuse. Place an opening at the base of the drum to remove and reuse the fine, partially saturatedfloor-dry. Report the floor-dry you are discarding on a Special Waste Inventory. A permit is required to dispose offloor-dry.

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6. Are spilled materials and cleanup materials disposed of properly? 0 YES 0 No b You might need to obtain a special waste

permit before you dispose of spilled material. Contact the LLCHD at 441 -6238. Spilled material that becomes waste might be hazardous ifthe material is listed under RCRA or exhibits a characteristic of a hazardous

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waste. Small or Large Quantity Generators of hazardous waste must store and dispose of the spilled hazardous material according to state and federal regulations. Contact NDEQ at 471 -421 7 for.further information.

A permit to dispose of absorbents contaminated with oils, lubricants, or greases is less costly than a permit to dispose of absorbents contaminated with solvents, thinners, strippers, or degreasers. An absorbent that is contaminated with any of the latter wastes must be characterized (tested). I f it is determined that the waste is a hazardous waste, it cannot be disposed of in Lincoln's landfill. ('it is not tested, it is assumed to be hazardous.) Call the LLCHD Special Waste Program at 441 -6238 for assistance in characterizing your waste.

7. Do you use a laundry service to clean dirty rags (and uniforms)? 0 YES 0 No b Ifspilled material is recyclable, squeeze the

rags through a press to collect the liquid. Store the recovered liquid with similar fluids that you are planning to recycle. Rags used to clean up hazardous materials might need to be treated as hazardous waste. Rags should be listed in a Special Waste Inventory.

Lintoln-Lancaster County Health Department 25

Shop Rags and Wipes

Soiled paper and cloth shop rags could be either hazardous or special wastes.

Rags contaminated with solvents, thinners, degreasers, or strippers must be tested before you can dispose of them. This test will characterize (identify the content or nature of the material on the rags) the waste and determine whether or not it shows any of the four characteristics of a hazardous waste: toxicity, ignitability, corrosivity, or reactivity. Any waste that is not characterized is assumed to be hazardous. No quantity of a hazardous waste can be disposed of in Lincoln ’s landfill. If the test shows that the waste is not hazardous, it is a special waste. You will need to obtain a special waste disposal permit from the LLCHD in order to dispose of any quantity of those rags in Lincoln’s landfill.

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Rags contaminated with oils, lubricants, or greases are special wastes. You will need to obtain a special waste disposal permit from the LLCHD in order to dispose of any quantity of those rags in Lincoln’s landfill.

The staff of the LLCHD can help you characterize your wastes. Contact the Special Waste Program at 44 1-623 8 for information and assistance. You will also need to call that number to obtain a Special Waste Inventory and Permit Application Form. You will need to complete the inventory, and may be required to submit the results of a waste characterization test, prior to obtaining a disposal permit.

GEITING Our OF THE REGULATORY REQUIREMENT

You can avoid permit requirements by laundering or using a dry- cleaning or linen service to clean shop rags. The rags can then be reused. The LLCHD staff strongly recommends that businesses review their housekeeping methods and look for ways to become more efficient.

26 Vehicle M Equipment Maintenance

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One good way of reducing the amount of waste a business generates is to look for opportunities to reduce the number of spills and the amount of material spilled. These changes can be accomplished by more careful handling and storage of materials. Another good way to reduce waste is to reuse towels and other wipes as often and for as long as possible.

Perhaps the best method for reducing the risk of hazardous material spills and the amount of hazardous or special waste a business generates is to use less hazardous materials. By reducing the amount or the toxicity of materials purchased and used, a business can save money and get out from under regulatory burdens. If a business does not have hazardous materials on hand, there is no hazardous waste to handle. The LLCHD Technical Assistance Program (TAP) can provide assistance in discovering alternatives. Call the TAP staff at 44 1-623 5 to discuss these options and issues.

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D. MANAGING SOLVENT WASTE Parts cleaning operations usually generate hazardous waste in the form of sink mineral spirits and dip tank or immersion (carburetor) cleaner solvents. Other solvents generated might include spray degreasers, alkaline/detergent water-based solvents, and paint thinners. Some of these solvents contain chlorinated materials. The chemical names of chlorinated materials contain the syllable “chlor ” or “chloro ” as in “trichloroethane ” and “methylene chloride. ” These materials have been found in some samples takenfiom wells in Lancaster County. Ifsolvents become waste due to spills or because they were used for purposes other than cleaning or degreasing parts or removing paints, unnecessary additional waste might be generated. You need to also be aware that some of the materials or equipment you use can create air emissions. Therefore, your business might be subject to various air regulations. LLCHD staff members who can he& you identifi and deal with those issues are listed in the Appendix to this booklet.

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1 . Do you use any of the following three pieces of equipment to clean vehicle/equipment parts?

Yes No % Asolventtank contains a pump that circulates the solvent. A solvent tank that drains directly into a waste storage drum is safer to use than a dunk bucket, dunk basket, or dip tank that you have to empty yourselJ: Remember to turn ogthe solvent tank and close the lid when you are not using it. rfvou leave

Solvent Dip the tank running, solvent vapor will enter the Tank ~~ shop ’s air, creating a potential health hazard

and wasting material (costing you money). r f you cover the tank when you are not using it, you can prevent evaporation, reduce risk, and cut costs.

Solvent Tank

Solvent Basket

If you answered yes to any of the choices above, answer the following questions. If you answered no, go to Section E: “Water-Based (Aqueous) Cleaning Solution Waste.”

28 Vehicle ~r Equipment Maintenance

2. Do you use parts- cleaning solvent for purposes other than cleaning parts? 0 Yes 0 NO % Solventsare

expensive. Use them only for their intended purposes. Do not waste parts-cleaning solvent on floors and never use them to clean hands. Some solvents used on hands can be hazardous to human health. Don 't use solvent to start a stove j r e . The solvent vapors might cause an explosion.

3. Do you use a solvent tank rather than a dunk bucket or a dip tank when cleaning parts with mineral spirits? 0 YES 0 No b A solvent tank cleans parts more effectively

and is easier to use for scrubbing or soaking parts than a bucket. It is less likely that solvents will be spilled or will evaporate if you use a solvent tank. Ifvou use a solvent supply and maintenance service, raw material purchases, tank maintenance, and waste removal costs are open included in the price. This service could be costly. Some equipment leasing services provide raw material and remove waste for the equipment you own or lease @om them. Contact solvent waste removal companies for more information on leasingparts- cleaning equipment. (Call the LLCHD at 441-8040 for the latest list.)

a Lincoln-Lancaster County Health Department 29

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4. Have you placed solvent tanks near the service bays to minimize spills? 0 YES 0 No ’b Place parts-cleaning equipment near the

service bays to reduce drips and spills. Remember, minimizing spills helps to reduce the amount of solvent lost and the amount of used floor-dry absorbent and detergent floor wash that you generate.

5. Do you drain cleaned parts in the tank for a few minutes after cleaning to minimize the amount of solvent that drips on the floor? 0 YES 0 No ‘b If the solvent tank must be used continuously,

place an inexpensive steel tray or pan next to the sink. Drain the parts in the tray for a few minutes aper cleaning them and empty the solvent that remains in the tray back into the sink. Another option would be to place a rack over the tank and place parts on it to drain back into the sink.

6. When removing parts fiom a dip tank or bath, do you pull them out slowly? 0 YES 0 No ’b Removingpartsfiom solvent baths too

quickly will cause splashes and will allow rapid evaporation. Removing them slowly allows solvent to be ‘>pulled ” fiom the part due to tension on the surface of the solvent.

30 Vehicle tx Equipment Maintenawe

7. Do youuse chlorinated solvent in a dunk bucket to clean carburetors? 0 Yes 0 NO B Chlorinated solvents used in traditional

carburetor and brake cleaners, such as methylene chloride and perchloroethylene, are suspected to cause cancer in humans or to pose other health risks. These chemicals have been found in groundwater samples taken @om some wells in Lancaster County. Use a mineral spirits solvent with ujlash point above 140 degrees F to clean carburetors. Add an agitator with a sealable lid to the bucket to help clean parts quickly and easily without endangering employees or the environment. Keep the lid on the dip tank or dunk bucket when not in use.

8. If you use a solvent tank, do you keep it covered when you are not using it? 0 YES 0 No % Keeping a lid on an otherwise open tank

will help prevent evaporation, especially if the tank is heated. Using a sliding lid instead of one that lijis up will be more eflective.

9. Does a hazardous waste hauler collect your solvent waste for recycling or treatment? 0 YES 0 No % A hazardous waste hauler might need to

remove your used solvent for recycling or treatment. Contact the LLCHD ut 441 -6238 before disposing ofpotentially hazardous material.

Lincctn-Lancaster County Health Department 31

10. Do you own on-site recovery equipment such as a distillation unit or a solvent filtering system? 0 YES I2 No Fb Any shop that owns its parts-cleaning

equipment should consider installing and using a solvent recovery unit. However, the sludge and used filters might be hazardous wastes. Contact the LLCHD at 441 -6238 for information on how to dispose of these wastes properly.

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11. Do youuse chlorinated spray degreasers? 0 Yes 0 NO Fb Avoid using chlorinated solvents when

possible. When cleaning carburetor or brake parts, put a small amount of a mineral spirits solvent with a flash point greater than 140 degrees F in a drip pan. Initially, cover the brake parts with the solvent to contain the loose asbestos. Then brush the solvent on to increase its cleaning power. Collect all the solvent in the drip pan and return it to the solvent tank when you areJinished cleaning the parts. Another alternative is to use terpene-based cleaners. These are less hazardous than solvent-based cleaners.

* * * * *

I I

32 Vehicle tx Equipment Maintenawe

E. MANAGING WATER-BASED (AQUEOUS) CLEANING SOLUTION WASTE

Aqueous waste refers to water-based detergent washes and waste sump solid that might be hazardous because they are strongly alkaline (pH 2 12.5), that contain high concentrations of “heavy” metals, or have been contaminated with hazardous solvents. These wastes are @pically generated by engine parts-washing equipment.

1. Do you use any of the following four pieces of equipment for engine parts-cleaning operations?

Jet Spray Yes No ’b Ifyou answered “yes ” to any of these choices, Washer - - you probably generate caustic aqueous waste,

aqueous detergent waste, andor waste sump solids.

Hot Tank

Spray Cleaner

Steam Cleaner

If you answered yes to any of the choices above, answer the following questions. If you answered y10, go to Section F: “Cooling System Waste.”

Lincoln-Lancaster County Health Department

a 33

2. Could you replace aqueous cleaning equipment (such as hot tanks and jet spray washers) with a dry system (such as a high temperature oven)? 0 YES 0 No Eb

3.

In larger shops, a high temperature “burnout” oven might more economically remove dirt, oil, and grease @om parts. The oven burns oflthe oil, and then burns oflthe airborne particles before they can be released into the atmosphere. The dry ash residue le@ on the parts is removed with shot-blasters (machines that bombard the parts with small glass beads or metal shot). This method could reduce the volume of waste produced. The residue might be hazardous, however, and must be listed in a Special Waste Inventory.

You might find it useful to ask yourselJ “How clean is Clem? How clean does this part really NEED to be? Can I use plain water to get this part clean enough? ” The answers to these questions can save you time and money.

Do you use a detergent-based cleaning solution instead of a caustic- based solution when cleaning aluminum engine parts? 0 YES 0 No b Caustic solutions can etch or pit aluminum

substrates or surfaces. However, f y o u use a detergent-only solution, the waste solution might contain oil and/or hazardous elements such as “heavy” metals: lead, chromium, cadmium, etc. You might have to have the waste tested to prove it is nonhazardous before you

34 Vehicle 82 Equipment Maintenance

will be allowed to dispose of it. Pre-washing parts can reduce contamination of the washing solution. Another option is to use two hot tanks. One could contain detergent solution only for cleaning aluminum engine parts. The other could contain a caustic solution for cleaning other types of engine parts.

4. Do you use drip trays on hot tanks to minimize the amount of waste spilled on the floor? 0 YES 0 No 'b Place an inexpensive stainless steel tray or

pan next to the tank and drain parts in the tray for a few minutes after cleaning. Carefully empty any detergent or caustic solution remaining in the tray back into the tank.

5. Have you placed hot tanks and/or jet spray washers near service bays? 0 YES 0 No B Designate a set of bays for hot tank or jet

spray parts-cleaning operations. Place the equipment near these bays. This arrangement will help reduce spills and drips and reduce jloor cleaning waste.

6 . Do you rinse dirty engine parts (use a two-stage cleaning process)? 0 YES 0 No 'b To extend the life of the cleaning solution and

to clean parts faster, consider using an extra tank that would contain previously used solution for rinsing most of the dirt and grime oflthe parts. You might also consider using a non-heated tank with partially used solution for prerinsing parts. Another option would be


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7.

to use jet sprayers with a low suds detergent. Removing large solid material f iom parts before rinsing them with solvent or detergent will also help reduce rinse water or used solvent wastes.

You could also use a countercurrent rinsing process. The cleaner water f iom tanks farther down the system can be used to replace dirtier water. The illustration below shows a countercurrent tank system in operation.

Direction part moves b ! _ _ _ ~ ~ _ ~

Countercurrent water flow

\ -. -----

e-

E' '\

\ -. ------

'\ I

Dirtiest Tank Cleanest Tank

Do you remove sludge and solids from the hot tank and reactivate the solution for reuse? 0 YES 0 No % Ifthe hot tank does not have heating elements

on its base, you can remove solids to extend the life of the cleaning solution. Ifthe cleaning solution becomes weak, you could add more detergent or caustic material as needed. Follow the manufacturer 's directions carefully. Some equipment leasing services will provide this maintenance service for the tanks leasedfiom them. Complete a Special Waste Inventory before disposing of the caustic solution or sludge. Contact the LLCHD at 441 -6238 for permit and disposal information.

36 Vehicle 8~ Equipment Mainteaance

8. Does your system screen out solids before they reach the mudsand trap in the floor drain? 0 YES 0 No b Sludge and solids are major contaminants

@om vehicle maintenance shops. If they enter the sewer system they could damage water treatment equipment and pollute the environment. To reduce mudsand trap cleaning costs, contain solids before they reach the drain. Contact the LLCHD at 441- 6238 before disposing of sludge or solids @om these traps.

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9. Do you lease one or more hot tanks? 0 YES 0 No b A leased system might be easier to use

because detergent compounds, tank maintenance, and waste management are

10. Do you lease one or included in the price of the service. Leasing equipment open appeals to small and more jet spray medium sized shops because equipment

washers? purchases can be costly. Make sure that 0 YES 0 No hazardous waste is disposed ofproperly.

1 1. Do you own one or more hot tanks? 0 YES 0 No b Many larger shopsprefer to purchase

equipment for cleaning engine parts. However, make sure that handling, storing, transporting, and treating waste and materials are performed in a safe and legal manner. Contact the LLCHD at 441-6238 for one or more jet

spray washers? information. Some equipment leasing 0 YES 0 No services will provide raw material supply and

waste removal services for tanks you own. You can contact the LLCHD at 441 -8040 for a list of waste transportation companies.

12. Doyouown


13. Does a hazardous waste hauler collect your aqueous waste for transport to a recycling or treatment center? 0 Yes 0 No B The aqueous waste generated in your hot tank

might be hazardous. Contact the LLCHD at 441 -6238 before treating or disposing of aqueous waste and for a list of hazardous waste haulers.

c- . 14. Do you own on-site aqueous waste treatment equipment? 0 YES 0 No B Ifyour shop is large and you own your hot

tank or jet spray washer equipment, buying and using an on-site waste treatment system (such as an oil/water separator) might be cheaper than disposing of the waste of-site. Treating the waste could be a regulated activity. Contact the LLCHD at 441-6238 and NDEQ at 471-4200 before deciding on any on- site treatment method. Also contact equipment vendors and dealers for additional information.

Cleaning Solutions for Vehicle Maintenance Shops

All businesses want to save money. Believe it or not, there are ways to save money and reduce safety, health, and environmental risks from cleaning vehicle parts. Potential alternative methods for cleaning carburetors, diesel injection pumps (cold cleaning), and brakes and alternative processes for parts-washer stations are listed below.

38 Vehicle 8~ Equipment Maintenance

COLD CLEANING BUCKETS (FOR CARBURETORS, DIESEL INJECTION PUMPS & MOTORS, AND OTHER ITEMS WITH SMALL INTERNAL PASSAGEWAYS.)

X

X

X

X

X

Switch to a non-chlorinated cleaner. Use one that has a flashpoint greater than 140 degrees F (is less flammable). Methylene chloride, the active ingredient in the “old” carb cleaner, is not required for carbon varnish removal.

Use an agitated bucket. Agitation makes up for the lower cleaning strength of many lower-risk cleaners.

Use a separate product that has been formulated specifically for paint stripping this task often. Non-chlorinated paint stripper formulations are effective on many paints; they often contain a solvent called N-methylpyrollidone (NMP).

Wear gloves when handling any carb cleaner or paint stripper; check your vendor’s MSDS for glove recommendations.

If you choose to use chlorinated carburetor cleaners, contact LLCHD for information on Clean Air Act compliance.

PARTS-WASHER STATIONS (SOLVENT FAUCETS)

Safety, Health, & Environment

X Switch to a solvent with a flashpoint greater than 140 degrees F (one that is less-flammable) and that poses lower health-risks compared to either petroleum naphthas, Stoddard Solvent, or typical chlorinated solvents.

Cost Reduction

Use filters and traps to reduce the solvent change-out frequency. A small volume of filter and trap waste is generated compared to a large volume of solvent. Most vendors indicate

Lincpln-Lancaster County Health Department 39

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that filters can be wrung-out and placed in the trash-beware of contaminating your parts washer with chlorinated brake or carb cleaner. Contamination could make your filters hazardous waste. Oils from traps are often treated as used oil; again beware of cross contamination that would make this oil hazardous waste.

rt Perform maintenance on machinery yourself if the vendor does not provide maintenance service in Nebraska. This self- maintenance includes changing filters and adding water or more solvent to the machine. Self-maintenance may cost less than contracting a solvent service to perform these tasks.

* * * * *

40 Vehicle 8L Equipment Maintenance

F. MANAGING USED ANTIFREEZE Businesses that provide air-conditioning or radiator service generate waste antifieeze, empty repigerant containers, or waste radiator flush-water. Ifyour shop does not provide such services go to Section J: “Worker Safety & Right-To-Know. ”

1. Do you recycle radiator flush water? 0 YES 0 No % Ifvour shop is primarily a radiator shop,

installing a radiator flush booth might help reduce the amount of wastewater you generate. The wastewater generator should check with the wastewater treatment plant (441 -7967) before discharging the flushwater to the sanitary sewer.

2. Does a recycling or equipment leasing service collect your used antifreeze solution or do you recycle or reuse it yourself?

a RECYCLE 0 reuse 0 sanitary sewer 0 other

Some equipment leasing firms will collect additional waste streams, such as used antifieeze, as part of their service. Call the LLCHD (441-8040) for a list of companies that collect used antipeeze. Ask these companies about any additional services they will perform ifyou are considering using an equipment leasing firm or purchasing recycling equipment.

b

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Managing Used Antifreeze

Commercially available antifreeze usually contains either ethylene glycol or propylene glycol. These chemicals lower the freezing point and raise the boiling point of the water in a vehicle’s radiator. During its life in your car, antifreeze may become contaminated with metal particles and grit. Antifreeze breaks down over time and forms acids which corrode your vehicle’s cooling system.

Many states and municipalities actively discourage dumping used antifreeze into the drain. Although no laws have yet been passed, this practice is also discouraged in Lancaster County.

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REDUCE

You can reduce the amount of antifreeze you use by checking the radiator, the reservoir, and all hoses of your vehicle carefully for leaks and repair any you find. If you notice a puddle of greenish liquid under the front end of your vehicle, you may have a leak.

Do not change antifreeze as often as you might think. As long as a chemical analysis or an antifreeze tester reveals that your antifreeze is doing its job, refrain from draining and replacing it. Maintaining the chemical quality of your cooling system can help keep your engine from corroding.

Avoid overfilling your radiator or reservoir. Most reservoirs are marked to indicate proper levels. Excess antifreeze may run out the overflow hose onto the ground. As your vehicle’s motor runs, heated antifreeze expands and may run out the overflow hose

REUSE AND RECYCLE

Your vehicle is the best reuser of antifreeze. Unless the antifreeze has become contaminated or been chemically broken down so that it no longer protects your vehicle, it can be used.

42 Vehicle E Equipment Maintenance

Occasionally, however, you may need to drain the antifreeze from your vehicle and replace it with new. Recycle the antifreeze so that others might reuse it. Recycling preserves valuable resources, protects the environment, and reduces costs.

Carefblly drain used antifreeze into a clean container with a lid. Keep the antifreeze free of contaminants such as gasoline, oil, and dirt. Clearly label the container “poison” and “used antifreeze.”

Transport it to a local antifreeze recycling facility or have a local pickup service do so for you. If you choose to take used antifreeze to one of the sites listed on the back of this form, please call ahead to determine whether the site still accepts antifreeze, have special instructions for you, or charge a fee for their services. Some recyclers will come to your business to collect the antifreeze. Some of these businesses charge less and can reduce your waste transportation costs.

The prominent recycling methods for used antifreeze are distillation, ion exchange, andfiltrution. Distillation and ion exchange restore the antifreeze to a high level of purity. Filtration is the lowest cost alternative and can be performed in-house by many automotive repair shops. Since filtration does not purifL or concentrate the antifreeze, filtrated antifreeze should not be diluted a second time. Filtration cannot remove contaminants dissolved in the antifreeze. It is the least preferred recycling method.

Because of antifreeze’s toxic nature, LLCHD strongly discourages pouring it straight down the drain. Recycling is the best option.

HAZARDOUS WASTE FACILITY

Used antifreeze could be classified as a hazardous waste, in part, because of its toxicity. It may be classified as a 008 (containing lead) or a 0 18 (containing benzene) type waste. Therefore, some individuals and businesses would rather have a professional hazardous waste facility handle the substance.


If you intend to manage your used antifreeze as a hazardous waste, contact the Nebraska Department of Environmental Quality (NDEQ) at 47 1-42 17 for further assistance.

TREAT

The largest antifreeze treatment facility in Lincoln is the Theresa Street Treatment Plant. The facility begins breaking down antifreeze in the plant’s treatment works and discharges the treated antifreeze into Salt Creek. (Antifreeze poured into a drain connected to a storm sewer or a septic tank is not treated at all.)

DISCHARGE TO S A N I T A R Y SEWER

Discharging diluted spent coolant at a rate of no more than five gallons per day per facility to a sanitary sewer is allowed in Lincoln. If you discharge your used antifreeze to the sanitary sewer, it should be diluted in a 3: 1 water and antifreeze mixture (3 gal. water to 1 gal. antifreeze). Used antifreeze that is poured into the sanitary sewer goes to the Lincoln Waste Water Treatment Plant. No Special Waste Disposal Permit is required for this method of disposal.

DISPOSE

Disposal is not considered an appropriate option for managing used antifreeze. Used antifreeze, like all bulk liquids, has been banned from landfills. A Special Waste Disposal Permit is required in order to transport used antifreeze to the Lincoln Waste Water Treatment Plant.

* * * * *


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G. MANAGING AIR CONDITIONING SYSTEM WASTES

Businesses that provide air-conditioning service generate empty ref igerant containers or might generate waste@eon. @-your shop does not provide such services go to Section J: ‘‘Worker Safety & Right-To-Know. I’

1 . Do you repair a n d or recharge air- conditioning units? 0 Yes 0 No b &”you answered “no” go to Section J:

Worker Safety & Right-To-Know. Ifyou answered “yes ’ complete the remaining questions about how you handle cooling system wastes.

2. What size container is the refrigerant dispensed from? 0 12 or 14 ounce cans 0 OTHERSIZES (20, 30, OR 50 LB. TANKS) % The 12 and 14 ounce containers of the

ozone-destroying coolant CFC-12 are no longer produced or distributed. All CFC-12 distributed today is distributed in the larger containers. The remaining refrigerant is released whenever a partially used I2 or 14 ounce container is disconnectedpom the filling device. Soon even the larger containers will be obsolete because CFC-12 is no longer manufactured in the United States.

a Lincoln-Lancaster County Health Department 45

3. Do you recycle empty, used refrigerant containers with your salvage metal? cl YES 0 No b To avoid any possibility of rej-igerant

leaching into the groundwater at a landfill, open or remove the valve once the container is empty and recycle it with your salvageable metal. Twelve or fourteen ounce containers can also be recycled with other salvageable metal ifthey are empty. Do not use standard disposable 30-pound canisters to collect andor store used rej-igerant for later reclaiming by a recycling machine. Specially designed containers for storing rej-igerant are included with recycling machines.

4. Do you check air- conditioning systems for refrigerant leaks before you recharge them? 0 YES 0 No b It is not a good practice to add coolant to a

leaking air-conditioning system or to add coolant to any system without checking for leahfirst. Since 1992, it has been illegal to allow CFCs to escape into the atmosphere. Ifcustomers reficse to submit their air- conditioning systems to a check, you should reficse to recharge the system. By now, most of the public should be aware of the harmful egects that leaking cooling systems have on human health and the environment. You can help educate those who do not know or understand.

46 Vehicle Sr Equipment Maintenance

5. Do you recycle refrigerant ? 0 YES Ll No B Refiigerant costs have fluctuated over the

years, but most costs have increased due to the burdens of federal regulation and taxes. The lack of a good alternative coolant might make it economical (or even proflitable) for you to purchase and use a repigerant recycling unit. Since 1992, businesses that provide air- conditioning service have been required to purchase such equipment. Further, legislation has made it mandatory that shop technicians be licensed to do repairs on air-conditioning systems.

The LLCHD (441-8040) has a current list of recyclers that accept empty, depressurized containers.

* * * * *


H. MANAGING USED OIL, OIL FILTERS, AND

CONTAMINATED FUEL Because using oil is nearb unavoidable in the United States, recycling and reusing* are the best waste reduction activities people can engage in. Reducing spills will also help reduce the amount of unnecessav waste.

1. Does an oil recycler collect your waste oil? 0 YES 0 No ’% Recycling is the preferred option for managing

waste oil. When the price of oil is high, some oil recyclers willpay for waste oil. Shops typically combine transmission oil with other waste oils. Before you mix oils, ask your oil recycler.

2. Do you use a waste oil burner? 0 YES 0 No ‘% Waste oil burners can be excellent sources of

heat for your shop. Contact the LLCHD (441 - 6238) and NDEQ (4 71 -421 7) for regulations governing the burning of waste oil. A special waste permit is required ifyou want to incinerate used oil in a waste oil furnace.

* A new device is available from some companies that allows you to drain three or more used one-quart oil bottles into another bottle. This racklike device attaches to a wall and allows the oil to flow downhill, collecting in another bottle for use. The time for draining may take several hours. However, you can open recover and use about a quart of oil from several “empty” one-quart oil bottles.


3. Do you accept used oil from individuals? 0 YES 0 No b Monitor what is placed in your waste oil tank.

Check all used oil that customers bring in to you. You are responsible for disposal costs if your oil is mixed with a hazardous material or waste. Ifvou believe a hazardous material or waste has been mixed with your used oil, contact the LLCHD at 441 -6238.

4. Do you generate waste oil filters? 0 Yes 0 NO ’% Used oilfilters can contain up to 5 ounces of

oil aJter they have been drained for 24 hours. Puncturing the filter around the base will allow some of the trapped oil to escape and be collected. Filter crushers, which remove 80- 100% of the p e e oil, should be purchased and used. The collected oil should be recycled. Once you have punctured or crushed the filter, you should be able to recycle the metalfilters along with other scrap metal. Contact the LLCHD at 441-6238 or local salvage yards for addirional information. Recycled oil and oil filters are exempt *om hazardous waste regulations. Call the LLCHD 441-8040 for a list of recyclers.

Burning Oil is Not Recycfing

Many people believe that burning used oil in their boilers or furnaces is recycling because used oil is reused and heat energy is recovered. However, engineers and waste management regulators consider burning used oil to use the released heat to be a form of treatment. State and federal environmental agencies govern many waste treatment processes including the appropriate methods for burning used oil.


If businesses choose to comply with the following rules, they can avoid the more burdensome hazardous waste regulations.

P The heater must meet requirements approved by the Nebraska Department of Environmental Quality and the EPA to bum waste oil. (A wood stove will not be approved for this method of treatment.) The burner can only burn used oil that has been generated by the owner or operator of the burner, a conditionally exempt small quantity generator (one who disposes of no more than 100 lbs per month of hazardous wastes), or a household. Solvents, degreasers, strippers, and other chemical products must not be used as fuels.

P The heater must not have a maximum capacity greater than 0.5 million Btu per hour. The combustion gases from the heater must be appropriately vented to the ambient (outside) air.

49

Because this treatment involves the release of pollutants and potentially harmful materials into our community’s air, the LLCHD requires businesses that intend to burn used oil on site to report this activity on the annual Special Waste Inventory and Permit Application. Used oil is Waste Type # 12, and a $15 disposal permit is required. All of the management practices for used oil must be included on the Special Waste Inventory and Permit Application form.

Any approved OH-site management method can be reported as “recycling,” and no permit is required. However, the off-site management location must have a current special waste permit if it is located in Lancaster County. Used oil that is managed by shipping it off-site for re-refining, for mixing with fuel oil for burning, or for incinerating in a commercial unit must be reported to LLCHD on the inventory form.

50

Used Oil Filters

Vehicle 8L Equipment Maintenance

Used oil filters are unavoidable by-products of routine automotive maintenance, but how they are managed is left up to you. The EPA has conditionally exempted used oil filters from hazardous waste regulations providing thefilters are non-terne-plated. Terne is a lead-tin alloy that causes used filters to exhibit the toxicity characteristics for lead. Heavy duty oil filters-such as those found in tractors, buses, construction equipment and industrial machinery-are sometimes terne-plated.

DISPOSAL

Used oil filters may be disposed at the Lancaster County landfill if they meet the following provisions: 0 The filter is a non-terne-plated filter.

8 The filter contains no free-liquid @e., it has been crushed or punctured and

0 The filter is removed when the vehicle is at operating temperature then drained

drained or dismantled and drained).

for 12 hours.

Research has shown that draining and crushing used oil filters removes more of the contained oil than puncturing and draining or draining alone. If filters are drained, they should be placed on a draining rack at a slight angle to ensure adequate drainage. Dismantling filters allows the components to be separated and recycled or disposed of separately. There are products on the market that allow quick and easy draining, crushing and dismantling.

A Special Waste Disposal Permit is required in order to dispose of any quantity of drained, used oil filters in Lincoln’s landfill.


RECYCLING

A number of area companies pick up used oil filters for recycling. The companies vary in the fees they charge for service and the manner in which they want the filters prepared for pickup. The Lincoln-Lancaster County Health Department (LLCHD) can provide businesses with a list of recyclers so they can use an environmentally sound method of managing used oil filters.

HANDLING WASTE OIL

Used motor oil has been shown to cause cancer in laboratory mice. Although the study is not conclusive, substances found to cause cancer in laboratory animals may also cause cancer in humans. Therefore, people who handle used motor oil on a regular basis should take precautions to guard against the possibility of exposure.

The Lincoln-Lancaster County Health Department (LLCHD) makes the following recommendations.

J

J

J

J

Ixl

Ixl

DOs DO follow work practices that minimize the amount of skin exposed and the length of time used oil stays on skin.

DO thoroughly wash used oil off skin as soon as possible with soap and water. A waterless hand cleaner can be used when soap and water are not available. Always apply skin cream afler using waterless hand cleaner to replace the skin’s natural protective oils.

DO wash oil-soaked clothing before wearing it again. Wearing oil-soaked clothing causes continuous contact and irritation.

DO use gloves made from nitrile, Neoprene, Viton, or other material that oil cannot penetrate.

DO NOTs

DO NOT use kerosene, thinners, or solvents to remove used motor oil from the skin. They remove the skin’s natural oils and can cause dryness, irritation, and possibly more serious toxic effects.

DO NOT put oily rags in pockets or tuck them under a belt; this practice can cause continuous skin contact.

* * * * *

52 Vehicle H Equipment Mainteriance

I. MANAGING MISCELLANEOUS REPAIR AND SHOP WASTES

Because using batteries, and other automotive supplies is nearly unavoidable in the United States, recycling is open the best waste reduction activity people can engage in. Reducing spills will also help reduce the amount of unnecessary waste. Whenever possible, you should select

. . and use less hazardous or less toxic materials. Not only are they safer to use, it is usually less 'expensive to dispose of them. You can reduce regulatory compliance concerns as well as waste storage and transportation costs.

1 . Does a battery collector remove your used batteries? 0 YES 0 No % Lead-acid batteries must be recycled. Battery

collectors o$en pick up used batteries a$er you have collected a certain number. Sometimes a battery collector will pay for intact lead-acid batteries. Some new battery distributors will also take used batteries on a turnkey basis.

2. Do you take used batteries to a storage or recycling facility? 0 YES 0 No % Call the LLCHD (441-8040) for a list of

battery recyclers. Contact the Department of Transportation (4 71 -4567) for information on how to transport the batteries safely. Ifyou recycle batteries on-site, contact the NDEQ (471 -421 7) for information regarding hazardous waste storage laws.

Lintoh-Lancaster County Health Department

Batteries

53

Mercury, lead, cadmium, and silver are toxic metals found in many batteries. These metals can accumulate in living tissue and cause adverse health and environmental affects. Although the amount of toxic metals in each battery is small, so many batteries are disposed of each year that the amount of toxic metals from all the batteries is quite significant. When hazardous batteries are disposed of in a landfill or incinerator, the mercury, lead, cadmium, or silver can contaminate air, surface water, and ground water.

.SPENT LEAD-ACID BATTERIES

If not managed properly, spent lead-acid batteries (SLABs) might leak or spill, causing lead andor acid contamination of the soil and ground water. People who generate, collect, or accumulate SLABs must follow proper storage and containment practices.

SLABs may be stored either indoors or outdoors. Indoors means “in a building having a roof and a least three walls that are permanently attached to an impermeable floor that lies directly on the ground.” Anything else is considered outdoors. Semitrailers and sheds without floors do not qualifl as indoor storage areas.

Indoor Storage

Store SLABs on a non-reactive, curbed, and impermeable surface. Such a surface will help ensure that acid and lead will not corrode or pass through the containment area and leak into the soil or ground water. Curbing will prevent leaks or spills from running off the edge of the containment area.

~ If your storage area has a floor drain, you may

0 place the batteries in a plastic tub or other container that will provide adequate containment of a spill or leak,

54 Vehicle M Equipment Maintenance

0 seal the floor drain, or

0 place a dike or berm around the floor drain.

Outdoor Storage

Even if you store SLABS outdoors, you should place them on a non- reactive, curbed, and impermeable surface. Construct the storage area in such a way that rain, snow, and draining water are prevented from entering the area.

Inspecting Batteries

Periodically inspect stored batteries, looking for cracks or leaks. Because SLABS stored outdoors have a greater possibility of cracking and leaking (due to freezing and thawing) they should be inspected more often than batteries that are stored indoors.

Place cracked or leaking batteries in an acid-resistant, leakproof, closed container. Report any uncontained spills by calling the Nebraska Department of Environmental Quality at 47 1-4258.

Recycling and Keeping Records

The best method of managing spent lead-acid batteries is to recycle them. The appendix of this booklet contains a list of haulers and recyclers who can assist you in this effort.

It is a good idea to keep records of all batteries in your possession. These records should include when the battery went into storage (or when you acquired it), any cracks or leaks detected, when the battery was picked up by the recycling company or the transportation company, and who picked up or who recycled the battery. You might wish to include other pertinent information.

Lincaln-Lancaster County Health Department

SPENT DRY-CELL BATTERIES

55

There are eight different types of batteries, each with its own chemistry and characteristics. Because proper management of a battery depends on the type of battery, you will want to pay special attention to the types of batteries you buy and use. Information about the type of battery can be found on the battery label. The vendor who sells you batteries can also identify battery types.

The eight battery types are: a *

a * a a a * a

A1 kaline

Carbon zinc

Nickel cadmium

Sealed lead-acid

Mercury or Mercuric oxide

Silver or Silver oxide

Lithium

Zinc air

Sizes and Shapes

Most batteries come in several different shapes and sizes, including A, AA, AAA, C, D, 6V, 9V, coin or button shaped, and battery packs (a series of battery cells connected together and usually encased in

~ plastic).

56

Characteristics

Vehicle Equipment Maintenance

Some batteries are hazardous to the environment because of the amount of mercury, lead, cadmium, or silver they contain. Others are not hazardous because they do not contain any of these toxic metals or they contain such tiny amounts that they do not pose a significant environmental threat. Some batteries are single use while others are rechargeable and can be used many times. Some batteries can (and should) be recycled, some cannot. A comparison is given in the table labeled “Battery Hazards and Characteristics’’ on page 62.

Management of Nonhazardous Batteries

The types of batteries identified as nonhazardous in “Battery Hazards and Characteristics’’ may generally be disposed of as an industrial solid waste. I f you have questions or are unsure of your disposal options, call the LLCHD at 441-8040.

Management of Hazardous Batteries

Batteries identified as hazardous in “Battery Hazards and Characteristics’’ should be managed as hazardous wastes. Refer to the appendix for a list of service providers.

Storage

Store batteries in a vented, nonmetal container. A plastic bucket or sturdy cardboard box might serve the purpose. Do not place an airtight lid on the container because gases that normally vent from batteries might be trapped, increasing the risk of explosion.

Label all battery storage containers, “Batteries for Recycling” or “Hazardous Waste Batteries.’’

Inspect battery containers regularly to ensure that they are not leaking or broken. If you find broken or leaking containers, put the batteries in


new containers. You are not required to document inspections of battery containers; however, you might find it useful to do so.

Waste Reduction Tips

-4 Avoid using batteries whenever possible by purchasing tools and equipment that do not require batteries.

Q Avoid buying tools or equipment with nonremovable, rechargeable batteries.

-4 Use rechargeable batteries whenever possible.

Adapted from Managing Used Dry-Cell Batteries and Spent Lead Acid Batteries-Requirements for Transporters and Spent Lead Acid Batteries-Requirements for Generators, Minnesota Pollution Control Agency.

58

Hazardous or Recyclable or Nonhazardous Nomcydable

Vehicle Sr Equipment Maintenance

RechalgeaMe or Nonrechargeable

Battery Hazards and Characteristics

Nonhazardous

Type of Battery

Alkaline

Carbon Zinc

Lithium, Smal I

~

Nonrecyclable

Lithium, Large

Mercuric Oxide

Nonhazardous

Nonhazardous

Nickel Cadmium

Nonrecyclable Nonrechargeable

Nonrecyclable Nonrechargeable Rechargeable

Sealed Lead Acid

~

Potentially hazardous for reactivity.

Silver Oxide

Nonrecyclable

Wet-Lead Acid

Hazardous for cadmium (Cd)

Zinc Air

Recyclable Rechargeable

Hazardous for silver (Ag)

Recyclable Nonrechageable

Nonrechargeable

Nonrechargeable Rechargeable

Nomechargeable

lead (Pb) I

Nonrechargeable

Notes

Most commonly used & recogpized batter).

often labeled General Purpose Heavy Duty or Classic

Small= 9 volts or less; often labeled Li or Cr.

Large= more than 9 volt% if harardous, waste code: DO03

Marked with

waste code: Do09

"+" symbol;

Labeled Ni-cd; waste d e : DO07

P b d d waste code: Do08

Waste code: Do1 1

Most commonly know as vehicle batteries.

Usually button size, identi@ by pin hole.


3. Do you collect and contain asbestos waste when replacing brake shoes to ensure the dust is not released into the air? q d

lung cancer. Some !, ' 0 YES 0 No % Asbestosdustcauses 'il I/ i

equipment leasing companies provide asbestos collection systems. This equipment contains the asbestos dust in a solvent solution that the company collects and recycles. Use mineral spirits with a flash point of I40 degrees F. Never spray the brake with a high-pressure stream of water or air. The spray will blow many of the fibers into the shop's air. Wet down loose asbestos dust before sweeping the shopfloor. I fa vacuum is used to contain the asbestos dust, use a system with a high eficiency particulate air (HEPA) filter. Standard and wet/dry vacuums will not contain asbestos dust.

4. Do you contract with a vehicle waste service to remove used hydraulic fluids? 0 YES 0 No % Used hydraulicJluid must be collected by a

vehicle waste service contractor. The appendix contains a list of service providers.

5. Do you store tires in a way to reduce the hazard of fire and the accumulation of water? 0 YES 0 No % Tires stored outside are breeding grounds for

disease-carrying mosquitos and can pose afire

60 Vehicle 81[ Equipment Maintenance

6. Do you recycle lead wheel balance weights? 0 YES 0 No

hazard. Cover the tires to keep out rain. All tires should be stored in a way that keeps out pests and moisture. Stockpiles that have more than 500 tires must include fire lanes. When storing large quantities of tires in Lincoln, contact the Bureau of Fire Prevention (441 - 7791). Ifyou live three or more miles outside the Lincoln city limits in Lancaster County, contact the State Fire Marshal (4 71 -202 7). You can also obtain information about tire recycling by calling the Lincoln Recycling Ofice (441 - 7043).

% Separate the lead@om other salvageable metals. Salvage yards will collect lead for recycling.

7. Do you contract with a hazardous waste hauler to dispose of used fuel filters? 0 YES 0 No % Used fuel filters are hazardous wastes. No

quantity can be disposed of in Lincoln’s landfill. See the appendix for a list of hazardous waste disposal service providers.

8. Do you handle dirty fuel? 0 YES 0 No % Dirty fuel might be a hazardous waste ifthe

contaminants include solvents, thinners, paints, or other products that are, by themselves, hazardous wastes. Contact the LLCHD at 441- 6238 for assistance with characterizing this waste type. Refer to the list of hazardous waste service providers in the appendix of this book.


9. Do you recycle used fluorescent tubes and other hazardous lighting wastes? 0 YES 0 No % See the information that follows for proper

management practices related to hazardous lighting wastes.

Hazardous Lighting Waste Disposal

MERCURY HAZARDS

Under current federal law, fluorescent tube lamps, high- intensity discharge (HID-speci fically high pressure sodium, metal -- -%

halide, and mercury vapor) lamps, and other types of lamps that contain mercury or other hazardous or toxic components may be considered hazardous waste. Although these lamps can contain a variety of heavy metals and other toxic substances, mercury is the primary hazardous substance found in all of these lamps.

When lamp tubes break, heavy metals (such as mercury vapors) contaminate the air. When these lamp tubes are landfilled, hazardous materials can also leach into groundwater. Thus, as either airborne or waterborne substances, these heavy metals pose significant threats to human and animal health.

~

62 Vehicle & Equipment Maintenance

Inhaling mercury vapor is a common cause of mercury poisoning in humans. The psychological symptoms of mercury poisoning include depression, irritability, nervousness, personality changes, or other emotional disturbances. Physical symptoms of mercury poisoning include inflammation of the gums and mouth, insomnia, excessive salivation, loose teeth, kidney damage, muscle tremors, and death.

The heavy metals and other toxins contained in fluorescent and HID lamps pose significant threats to exposed humans and animals. These metals can cause the waste to be classified hazardous. The LLCHD does not allow businesses to dispose of hazardous waste in municipal landfills in Lancaster County. A state law banning such wastes from all landfills will go into effect on Sept. 1,1996.

POLICIES GOVERNING DISPOSAL

Lamp wastes containing mercury are considered hazardous and must be tested to prove they are not hazardous. According to Title 128-Rules and Regulations Governing Hazardous Waste Management in Nebraska, waste generators - are responsible for obtaining the proper tests. They can make this determination by having an environmental laboratory conduct a Toxicity Characteristic Leaching Procedure (TCLP) on a representative sample of each lighting type.

The TCLP simulates how the hazardous components contained in a waste material would leach into the soil or groundwater when exposed to normal environmental conditions. The techniques that must be used when taking samples and conducting a TCLP can be found in Title 40 Code of Federal Regulations (40 CFR), Part 26 1, Appendices I and I1 (respectively). (A copy may be found in the Lincoln City Library.)


Waste materials containing chemicals at or above the threshold concentrations listed in the TCLP are regulated as hazardous waste. Research has shown that most spent fluorescent light tubes tested by TCLP contain concentrations of 0.2 mg/L or more of mercury. This is the concentration level at which a waste is defined as hazardous.

As a precaution, the Lincoln-Lancaster County Health Department (LLCHD) considers all fluorescent lamp waste that has not been tested to be hazardous. This action protects your business by assuring you that your waste is properly managed. In this way we help you avoid potential legal actions by federal and state agencies.

The Lincoln-Lancaster County Health Department classifies lighting wastes that contain concentrations of 25% through 100% of the threshold concentration of any chemical that is listed in the TCLP as “special wastes.” According to Title 1 32-Integrated Solid Waste Management Regulations, special waste must be disposed of in a permitted solid waste disposal facility. However, on September 1, 1996, a ban on unregulated hazardous waste entering the landfill will go into effect. (Fluorescent lighting tubes generated by households are exempt from the above regulations and may be taken to a Household Hazardous Waste Collection for recycling.)

All businesses must submit an annual Special Waste Inventory to the LLCHD. In addition, businesses wishing to dispose of 43 lbs. per month or more of lamp wastes in the Lincoln landfill must obtain a Special Waste Disposal Permit. To obtain a permit, businesses must submit a Special Waste Inventory/Permit Application to the LLCHD along with the results from a TCLP analysis of a representative sample of the waste.

~ DISPOSAL OPTIONS

The LLCHD and the Nebraska Department of Environmental Quality recommend that large and small quantity generators dispose of these


lamp wastes as hazardous waste. Businesses with hazardous waste have two disposal options: 9 contract with a RCRA-permitted hazardous waste

disposal facility to remove unbroken waste tubes, or

9 take unbroken tubes to a permitted lamp recycler.

(Lists of RCRA-permitted hazardous waste disposal companies and lamp recycling companies can be obtainedkom the LLCHD by

calling 441 -8040.)

If the business chooses the disposal option, the LLCHD can assist conditionally exempt small quantity generators in selecting a RCRA- permitted vendor that can remove hazardous waste. (A conditionally exempt small quantity generator is a business that generates a total of 100 kilograms or less per month of hazardous wastes.) In most cases, recycling is the better alternative. Recycling allows for the recovery of usable materials while reducing the amount of waste that ends up in a sanitary landfill.

The ALTO bulb is another fluorescent lighting option. ALTO bulbs contain about one-quarter of the mercury that other fluorescent bulbs contain. Therefore they, along with other nonhazardous lamp wastes, may go to a permitted sanitary landfill as apermitted special waste. Nonetheless, the LLCHD also recommends recycling these lamps in order to collect the mercury and prevent its migration into the environment.

AVOID DISPOSAL PROBLEMS

Individuals and businesses should consider purchasing less-hazardous lighting equipment when installing new fixtures, replacing spent equipment or burned out bulbs, or upgrading existing lighting systems.

The EPA’s Green Lights Program promotes energy efficient lighting technologies. These lighting elements will lower electricity bills,


increase energy efficiency, and improve lighting quality. Contact the Green Lights Program at (202) 775-6650.

10. Do you use a 55- gallon drum in the mudsand trap to catch gravel, sand, and other heavy

0 Yes 0 NO b Do not place a 55 gallon drum in the mudsand trap. The traps are designed to fill with sand and dirt on the bottom and with oils and grease in the top at about the same rate. Just removing the gravel and sand will result in a buildup of oil and grease that will eventually enter the sewer and create problems. lfyou have an older metal trap, replace it.

objects?

Trap Wastes

The Lincoln-Lancaster County Health Department (LLCHD) often uses the terms traps and sumps to mean the same thing. Other terms used in the Uniform Plumbing Code (UPC), in regulations, or by contractors and installers are: interceptors, grit basins, sediment bowls (or basins), or settling tanks.

All of these installations are intended to ensure that waste water is ~ properly handled and treated. According to the UPC, “liquid wastes

containing grease, flammable wastes, sand, solids, and other materials [may be] harmful to a building’s drainage system, the public sewer, or the sewage-treatment plant or process” (section 6.1.1). Traps are

66 Vehicle 8I Equipment Maintenance

designed to restrict the flow of wastewater contaminants-such as sludge, debris, oil, soil, sand, or gravel-but to allow the free flow of the water itself.

Trap Structure and Maintenance

A trap has three basic parts. First, there is a pipe or drain (or both) that allows water to flow into the tank. This pipe or drain is called the inlet, and the water that enters through it is called the influent. Second, there is the tank, basin, or bowl itself. This is the area in which the water collects, scum and oils rise to the surface, and

Inlet Outlet

sediments, heavy chemicals, and petroleum-contaminated particles sink to the bottom. Third, there is the pipe that leads from the tank to the sanitary sewer. It should not empty into a storm drain, septic tank, septic lagoon, gutter, or storm sewer. This pipe is called the outlet, and the water that exits through it is called the efluent. Some outlets include a baffle or filter to prevent the release of scum or solids that are suspended in the top layer of the trap waste contents.

~ Any trap must be maintained in order to operate in an efficient manner. Maintenance includes periodically removing accumulated scum, oil, grease, solids, or other settled, suspended, or floating debris. These contaminants will occur in one or more of the layers


within the tank: floating on the water’s surface, suspended within the water, or collected at the bottom of the tank.

Many traps will have a layer of scum floating on the water surface. This layer should remain above theflow Zine (the level at which water may flow out of the tank) so that it is not released with the effluent. You should periodically check the level of scum in the tank to ensure that too much does not build up. Occasionally, this scum will include a film of oil. You should remove this oil occasionally. This oil should be reported as a special waste and disposed of properly.

Below the scum layer, the tank contains a relatively large body of water. Water collects here to let sediments settle. As the sediments settle, the water should be clearer at the flow line. If a trap is hnctioning properly, only water that is free of scum, oil, or solids should flow out the trap through the outlet.

The layer of accumulated solids, petroleum-contaminated particles, heavy chemicals, and sediments that have settled to the bottom of the tank is known as sludge. You will need to remove this sludge periodically. If a trap is not properly maintained, the sludge level will get too high, and solid or semisolid wastes may be released with the effluent into sewer lines.

Regular pumping and removal of scum and sludge are the most important tank maintenance practices you can employ.

Trap Wasre is a Special Waste

Liquid and solid wastes generated by cleaning out and maintaining traps are special wastes. An inventory of these wastes must be submitted to the LLCHD. In addition, businesses must apply for a

~ Special Waste Disposal Permit from the LLCHD in order to dispose of the waste in the municipal landfill. For special waste types 1-5, a free permit will be issued through the wastewater treatment plant. This permitting process will be handled by the licensed liquid waste hauler.

68 Vehicle 8T Equipment Maintenance

When you apply for a permit, you will be required to submit the results of one or more laboratory tests conducted on a representative sample of the waste. These analytical testing methods that must be conducted in order to landfill trap wastes are contained in the third edition of Test Methods for Evaluating Solid Waste, Physical Chemical Methods, EPA publication S W-846. The municipal wastewater treatment plant will require different testing procedures. EPA-approved laboratories that can conduct these tests are listed in the yellow pages of your telephone book under “Engineers- Consulting,” “Engineers-Environmental,” or “Engineers-Hazardous and Industrial Waste.” Wastes generated in traps are classified into one or more of the following special waste type categories. b Mud or Sand Sumps or Trap Waste-This type of waste normally collects in

properly maintained traps in areas such as floor drains, motor vehicle wash bays, and process floors. This type of trap often has multiple floor drains. The trap should be designed to prevent sand and other solid materials from ob- structing the sewer system. This waste type category does not include the oils and greases separated out by means of a sump or oil/water separator or wastes heavily contaminated with petroleum or other products that are found in improperly maintained traps. Those oils and greases must be reported as separate waste types. In order to transport this waste to the Theresa Street Wastewater Treatment Plant, contact a liquid waste hauler. The liquid waste hauler will handle permitting requirements. (See the list of liquid waste haulers that pump traps and are currently licensed in Lancaster County at the end of this fact sheet.) In order to receive a Special Waste Permit to landfill this type of waste, you must dewater it. The waste must pass the Paint Filter Liquids Test (EPA SW- 846 Method 9095). In addition, include the results of a Total (8 Heavy) Metals analysis (EPA SW-846 Method 6010). You may need to have a Toxic Charac- teristic Leaching Procedure (TCLP) performed on a waste sample. This procedure is discussed in Title 40, Code of Federal Regulations (40 CFR) in Section 261.24 and in Appendix I1 of Section 261. You will also need to have a Total Recoverable Petroleum Hydrocarbons (TFWH) analysis (EPA Method 41 8.1) conducted on waste samples.

b Petroleum Type Grease Trap Waste. This type of waste normally collects in properly maintained traps in areas such as vehicle service and repair garages, some gasoline stations, grease pits, oiVwater separators, industries that use

.

I 1


petroleum products in their processes, water treatment separators, sumps, and floor drain systems. Other types of activities might also produce petroleum type grease trap waste. This waste type is often incorrectly classified as “Mud or Sand Sumps Trap Waste.” For wastes containing free liquids, contact a liquid waste hauler to transport this waste to the Theresa Street Wastewater Treatment Plant. Telephone the wastewater treatment plant at (402) 44 1-7967 for information regarding any additional testing that must be conducted prior to transportation to the municipal wastewater treatment plant. (See the list of liquid waste haulers that pump traps and are currently licensed in Lancaster County at the end of this fact sheet.) Dewatered waste oil may be collected by a waste oil recycler. You may obtain information about oil recyclers by calling the LLCHD at (402) 441-8040. In order to receive a Special Waste Permit to landfill this type of waste, you must dewater the waste. The waste must pass the Paint Filter Liquids Test (EPA SW-846 Method 9095). In addition, include the results of a Total (8 Heavy) Metals analysis (EPA SW-846 Method 6010). You may need to have a Toxic Characteristic Leaching Procedure (TCLP) performed on a waste sample. This procedure is discussed in Title 40, Code of Federal Regulations (40 CFR) in Section 261.24 and in Appendix I1 of Section 261. You will also need to have Total Recoverable Petroleum Hydrocarbons (TRPH) analysis (EPA Method 418.1) conducted on waste samples. In addition, a Closed-Cup Flashpoint analysis must be conducted on a representative sample of the waste. The results of these analyses must be submitted along with your Special Waste Inventory/ Permit Application form.

Guidelines for Disposing of Semi-Liquid Wastes

Disposal Considerations

Special Waste Types 1-5 and other types of wastes that are listed on the Special Waste Inventory/Permit Application Form may be separated (Le., dewatered, etc.) into liquid and solid fractions. The liquid waste haulers will initiate the reviewing and permitting process

70 Vehicle 8t Equipment Maintenance

in order to dispose of the liquid fraction of Special Waste Types 1-5 at the Theresa Street Wastewater Treatment Plant.

Depending upon the hazardous nature of the waste material, the Special Waste Inventory/Permit Application must be reviewed and approved by Nebraska Department of Environmental Quality (NDEQ), the Lincoln-Lancaster County Health Department (LLCHD), and/or the Lincoln Public Works and Utilities Department (PWUD) for a permit to be issued. To dispose of the fraction that contains no free liquids by taking it to a municipal solid waste landfill or transfer station, a Special Waste Inventorypermit Application must be submitted to LLCHD. This Special Waste Inventory/Permit Application must be reviewed and approved by NDEQ, LLCHD, and PWUD in order for a permit to be issued.

A special waste permit to landfill dewatered Special Waste Types 1-5 is only valid if the waste contains no free liquids (as indicated by the Paint Filter Liquids Test Method 9095 [see the back of this sheet]). For waste types other than 1-5, a Special Waste InventoryRermit Application must be submitted for each fraction to LLCHD for review and approval regardless whether the waste (or any fraction of the waste) contains free liquids.

When classifying your wastes, refer to the Uniform Plumbing Code (UPC), the product Material Safety Data Sheets (MSDS), and/or the results obtained from testing the waste material. Information from or a copy of one or more of these documents will be requested by the permit application reviewers.

Liquid Waste Haulers

When selecting a hauler for your waste materials, it is important to note that liquid waste haulers and refuse (solid waste) haulers are licensed on an annual basis. The licenses are issued based on the types of wastes their equipment is designed to haul. Liquid waste and

~


refuse haulers’ annual permits expire on May 3 1 each year. Call the LLCHD for a list of currently licensed haulers.

PAINT FILTER LIQUIDS TEST

Method 9095

Your waste must pass the paint filter test to be allowed in the landfill, and it can not contain any free liquids.

Because liquids move quickly through the soil and-if toxic-have the possibility of contaminating groundwater, they are no longer -permitted in landfills. The paint filter test, or EPA Test Method # 9095, is a simple straining test that ensures no free liquids enter the landfill. The details of the test can be found in Test Methods for Evaluating Solid Wastes, Physical/Chemical Methods (EPA publication no. SW-846). The test is required according to regulations found in 40 Code of Federal Regulations (40 CFR) sections 264.3 14 (c) and 265.3 14 (d).

> Toperform the test, obtain a conical paint filter (mesh number 60- fine mesh), available at most hardware stores. You should also have a glass funnel with a support to hold the filter vertical. This holder may be a metal ring clamped to a vertical rod. It may be necessary to add a fluted glass funnel to further support the paint filter.

The setup (see illustration on next page) should also include a container to catch any liquid that may drip from the filter. Ideally, the container should be a graduated cylinder. The cylinder should be large enough to hold 100 mL of material. Using such a cylinder will allow you to measure and accurately assess how much liquid is in the waste material. The cylinder should be fluted, or have a large, open mouth to

~ allow the free flow of any liquid in the waste.

Put a 100 mL or 100 g (about l/2 cup) representative sample of the waste into the paint filter. Let it stand for 5 minutes. If any liquid drips


from the filter, the waste is considered to contain free liquid and can not go in the landfill.

Paint Filter

Funnel

... . .

I ... -..' '. ., Graduated i & --'A- Cylinder

> Ifyour material fails the paintfilter test, separate the liquid portion and handle it as a separate waste. This liquid waste may require firther testing for metals or solvents before disposal.

* * * * *

E


J. WORKER SAFETY 8t RIGHT-TO-KNOW

Training personnel about shop safety and worker right-to-know is required by federal and state law, even ifyou only employ one person. This training will ensure that employees are informed about current materials and material handling techniques. The training also reduces the employer’s liability if a hazardous situation arises. In addition, improperly trained personnel can make mistakes resulting in costly cleanup or injury. The following questions should alert you to some areas of concern that you should be aware ox This list is not complete; there might be many other issues that you will need to consider. The Nebraska Department of Labor (NDL), a nonregulatory agency, oflers fiee health and safety consultation. For more information, contact the NDL at (402) 471-471 7.

1. Have all employees been trained how to use and store chemicals safely (including what to do in case of a hazardous spill or other accident)? 0 YES 0 No ’% Properly trained employees are less likely to

misuse costly products and generate unnecessary waste. The Occupational Safety and Health Administration (OSHA) requires that every individual who has contact with any hazardous chemicals be completely trained. The complete training covers how to handle chemicals properly, how to read and understand a Material Safety Data Sheet (MSDS), what to do in case of an emergency, and what health hazards are associated with

74 Vehicle fit Equipment Maintenance

2. Do you use a written hazard program to inform employees of

each chemical employees are likely to come into contact with on the job. In addition, the NDEQ requires that small and large quantity generators of hazardous waste take hazardous waste hundling training. Employers should keep records of all training forsuture reference.

possible hazards relating to their jobs? 0 YES 0 No '% A writtenhazard

communication program is required by the federal government. This program outlines the procedures used by the employer to convey the hazarak encountered by each employee specijic to each job.

3. Do you have a Material Safety Data Sheet (MSDS) for each chemical used in your business? 0 YES D No '% A business must have MSDSes for all materials

used in the business. Make a list of the materials used. When the list is complete, it should be checked against the MSDSes. Ifyou have any material for which you do not have an M D S , request onefiom the vendor or the manufacturer. File all MSDSes where employees can fieely and easily examine or copy them ifdesired Many businesses keep MsDses organized and labeled in a three-ring binder. The binder may be kept in a supply area or the ofice but it should be available to all employees at all times.


4. Have you labeled all hazardous chemical containers with appropriate identification and warnings? 0 YES 0 No b The hazardous warning can be any type of

message, word, pictures, or nationally or internationally recognized symbols that identi& the hazard of the contents of the container. Labels must be legible, in English, and prominently displayed. (You will probably wish to include warnings in Spanish or Vietnamese or other languages depending on the makeup of your workjorce.) Labels similar to those found on commercial products are suflcient. Ask your safety equipment or material supply vendors if they have labeling products. The Nebraska Safety Council (483- 251 1) can suggest proper labeling procedures andproducts you can buy.

* * * * *

76 Vehicle a Equipment Mainteqnce

K. EMERGENCY PIANNING & COMMUNITY RIGHT- TO-KNOW

In order to store large quantities of hazardous or potentia& hazardous materials such as gasoline, lube oil, ant$-eeze, and lead acid batteries you must meet special notification requirements. Following these notification requirements provides fire departments, local civil defense agencies, emergency planning, and emergency response committees information they need to prepare for potentially hazardous situations.

1 . Do you store more than 126 lead acid batteries ( 1 000 pounds of acid) in your shop area or on your business property? 0 Yes 0 NO ’b Ifyou answered “yes” notifi the Local

Emergency Planning Committee through the local Civil Defense/Emergency Services m c e s at 471-7441 and the State Emergency Response Commission at 471 -421 7.

2. Do you store more than 63 lead acid batteries (500 pounds of acid) in your shop area or on your business property? 0 Yes 0 NO % Ifyou answered “yes ’’ noti& the Local Fire

Department (in Lincoln call 471-7363), the Local Emergency Planning Committee (4 71 - 7441), and the State Emergency Response Commission (4 71 -421 7).


3. Do you store more than 1550 gallons of gasoline in your shop area or on your business property? 0 Yes 0 NO % rfvou answered ‘yes” noti& the Local Fire

Department (in Lincoln call 471-7363), the 1075 gallons of Local Emergency Planning Committee (4 71 -

7441), and the State Emergency Response Commission (471-421 7). The list on the left antifreeze?

0 Yes 0 NO contains examples of the most commonly regulated substances in vehicle equipment

1550 gallons of maintenance and repair shops. Ifvou have petroleum products? questions concerning other products call the

NDEQ at 4 71 -421 7. 0 Yes 0 NO

1550 gallons of motor oil? 0 Yes 0 NO

* * * * *

- 78 Vehicle er Equipment Maintenbnce

I I


- 79

APPENDIX

CONTACTS You can contact any of the following agencies in order to obtain additional information or to have your questions answered. You will not need to provide your name or your business’s name ifyou wish to remain anonymous or seek confidential advice. The Lincoln-Lancaster County Health Department oflers fiee, nonregulatory technical assistance. A technical assistance engineer will visit your shop and explore waste reduction, pollution prevention, and cost cutting options that are available to you. The technical assistance visit is a confidential and nonregulatory service. The technical assistance engineer will not come to your shop unless you ofer an invitation.

For information about this checklist, specific waste types, treatment alternatives, haulers and service providers, or technical assistance and site visits:

LINCOLN-IANCASTER COUNTY HEALTH DEPARTMENT ENVIRONMENTAL HEALTH DIVISION POLLUTION PREVENTION-AIR QUALITY SECTION 3140 “N” STREET (402) 441-8040

The programs and teams of the Environmental Health Division, Pollution Prevention-Air Quality Section are described on the following pages.

80 Vehicle 8l Equipment Maintenance

OUTDOOR AIR QUALITV

The air quality program ensures that the citizens of Lincoln and Lancaster County enjoy clean, safe air. The environmental engineers and other professionals in this program provide the following services:

> PermittingKompIiance-engineers review construction and operating permit applications and conduct on-site inspections to assure the public that local, state, and federal air emissions and asbestos regulations are being obeyed. They identify problem areas and may offer suggestions to correct the problems or recommend the visit of the technical assistance engineer.

> Ambient air monitoring-using sensitive instruments, LLCHD staff test the air quality in Lincoln for carbon monoxide, ozone, and small particulate matter. Staff members review this data daily. Lincoln has maintained good air quality since the early 1990s.

> Technical assistance-a technical assistance engineer can conduct a nonregulatory on-site visit. As a result of this visit, the technical assistance engineer can identify options for preventing pollution, reducing the use of toxic materials, and cutting costs. This is not an inspection and the visit will not lead to a fine or other penalty. All findings are confidential.

> Education and outreach-a trained professional prepares and develops educational and informational materials that describe best management practices and explain regulations and describe management options in clear, easy-to-understand language. Staff members are available to visit your site and conduct or facilitate workshops to help you and your staff understand pollution prevention.

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INDOOR AIR-OCCUPATIONAL HEALTH

The goal of the indoor air program is to minimize health risks posed by airborne and other environmental hazards in worksites, homes, and private and public buildings. Staff use investigative techniques, surveys, and environmental monitoring tools and skills to assess risks. They then abate or reduce those risks by conducting technical assistance visits and promoting pollution prevention.

> Indoor air-an environmental engineer evaluates indoor air quality. The engineer will respond to complaints that involve gases such as carbon monoxide or environmental tobacco smoke, solvent vapors, “sick building syndrome,” and radon. Besides conducting screening tests, the engineer will recommend practices for preventing problems.

> Occupational health-an environmental engineer monitors many other indoor air concerns that might have negative impacts on worker health and safety. As in the above areas, education is a primary activity of the environmental engineer when dealing with occupational health concerns.

POLLUTION PREVENTION

The goal of pollution prevention (P2) is to prevent or stop pollution before it is created thereby reducing public health and environmental risks. The ideal plan is to engage in business practices that do not create waste or pollution or to purchase materials that are less toxic and that can be completely used up rather than discarded.

> Technical assistance-a technical assistance engineer can conduct a nonregulatory on-site visit. As a result of this visit, the technical assistance engineer can identi@ options for preventing pollution, reducing the use of toxic materials, and cutting costs. This is not an inspection and the visit will not lead to a fine or other penalty. All findings are confidential.

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P Household hazardous waste-a community health educator informs citizens about least toxic products and best waste management options and facilitates the scheduling and conduct of collec- tions of hazardous waste materials from households. Through this program, the health department ensures that hazardous materials are safely removed from the household environment.

SPECIAL WASTE

A city ordinance and inter-local agreements require that businesses submit inventories of all special wastes that they generate. Businesses must apply for and obtain a Special Waste Disposal Permit from the LLCHD before they can dispose of any special waste. The goal of the Special Waste Program is to protect the public health by preventing certain types of waste from being discarded in the Lincoln landfill.

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P Special waste inventory and permits-an environmental engineer assists businesses in filling out special waste inventories. This assistance is aimed at helping businesses identie the hazardous, toxic, or other regulated wastes that they discard. (This inventory and related assistance by the engineer often leads to an on-site visit by a technical assistance engineer who recommends pollution prevention practices that will reduce waste and fbture disposal costs.)

> Compliance-an environmental health specialist responds to complaints, and assists businesses to come into compliance with environmental regulations.

P Hazardous Materials Emergencies-the hazardous incident response team responds to spills and accidental or illegal releases of materials that might pose a threat to public health and the environment. The team advises the Lincoln Fire Department concerning public health matters and ensures proper site remedia- tion.


For questions concerning state or iederal Small and Large Quantity Generator regulations, hazardous waste disposal and treatment, or related issues:

NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY P. 0. Box98922 1200 “N” STREET LINCOLN, NE 68508 (402) 47 1 -42 1 7

For questions related to Small Quantity Generators and Large Quantity Generators of hazardous wastes you call the above agencies or:

USEPA, REGION VI1 726 MINNESOTA AVENUE KANSAS CITY, KS 661 01 (91 3) 551-7051

OR THE USEPAs RCRA HOTLINE, (800) 424-9346

For information about OSHA requirements and Worker Right-to-Know contact:

THE STATE OF NEBRASKA DEPARTMENT OF LABOR

DIVISION OF SAFETY 301 CENTENNIAL MALL SOUTH LOWER LEVEL LINCOLN, NE 68509 (402) 471 -471 7

THE NEBRASKA SAFETY COUNCIL 400 VALLEY RD., ROOM 300 LINCOLN, NE 68510 (402) 483-25 1 1

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For help in learning how to handle a hazardous material spill contact:

STATE CIVIL DEFENSE 1300 MILITARY RD. LINCOLN, NE 68508 (402) 473-1 426

For response to a hazardous material spill on the ground of 100 pounds or more o r 25 gallons or more of oil or of any material that might contaminate the groundwater; or Any quantity of oil or hazardous material in a ditch, curb leading to a storm drain, sanitary sewer, body of water, or any other waterway that flows into a body of water contact:

THE NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY EMERGENCY RESPONSE DIVISION (402) 471 -21 86

FOR 24-HOUR ASSISTANCE CALL: (402) 471-4545 (STATE HIGHWAY PATROL)

For information about how to transport hazardous materials contact:

THE NEBRASKA DEPARTMENT OF TRANSPORTATION 1401 BURNHAM LINCOLN, NE 68502 (402) 471 -4567

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LINCOLN-LANCASTER COUNTY HEALTH DEPARTMENT 31 40 "N" STREET LINCOLN, N E 68510

(402) 441 -8040

R R R .ECYCLE

Financing provided through the Waste Reduction and Recycling Incentive Grants Program, Nebraska Department of Environmental Quality.

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Vehicle and Equipment Maintenance - InfoHousesave you money. Waste reduction is ... Gasoline mixed with water ... identified by informationon MSDS or on the results of a toxicity test