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Environmental Compliance,Pollution Prevention andSelf-Assessment Guide

forVehicle Maintenance Shops

June 2003

(Originally published March 1998)

New York State Department of Environmental ConservationPollution Prevention Unit

George E. Pataki, Governor Erin M. Crotty, Commissioner

TABLE OF CONTENTS

INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Industry Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Section I - Regulations Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Air Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Open Burning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Auto Body Shops . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Permitting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Exemptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Record Keeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6How To Calculate Your VOC Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Water Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Permitting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Pretreatment Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Nonpoint Source Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Storm Water Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Safe Drinking Water Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Hazardous Waste Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Hazardous Waste Determination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Hazardous Waste Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Conditionally Exempt Small Quantity Generator . . . . . . . . . . . . . . . . . . 11Small Quantity Generator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Storing Hazardous Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Large Quantity Generator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Universal Waste Rules . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Proper Handling and Storage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Lamp Crushers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Solid Waste Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15Petroleum and Chemical Bulk Storage Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

EPA Tank Deadline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16DEC Tank Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16Storage Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16Chemical Bulk Storage Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17Petroleum Bulk Storage Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18When to Report a Spill? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Section II - Waste Stream Management and Pollution Prevention . . . . . . . . . . . . . . 20Absorbents and Floor Dry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21Pollution Prevention Tips . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Aerosol Cans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21Pollution Prevention Tips . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Antifreeze . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22Recycling of Antifreeze . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22Storing Antifreeze . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22Pollution Prevention Tips . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Floor Drains and Wastewater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23Pollution Prevention Tips . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Fluorescent Bulb and other Hazardous Lamps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Gasoline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Lead Acid Batteries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25Pollution Prevention Tips . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Painting Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26Pollution Prevention Tips . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Parts Cleaning and Degreasing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26Types of Parts Washers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Aqueous Cleaners . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27Hot Soap Washers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28Semi-Aqueous Cleaners . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28Solvent Distillation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Pollution Prevention Tips . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29Refrigerants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29Certification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29Pollution Prevention Tips . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Shop Towels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30Pollution Prevention Tips . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

Used Electronics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

Scrap Metal Exemption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31Resale and Repair of Units . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Used Fuel Filters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

If you have any questions or comments regardingany portion of this publication, please contact:NYS Department of Environmental ConservationPollution Prevention Unit625 Broadway, 4th FloorAlbany, NY 12233-1750Phone: (800) 462-6553 in New York StatePhone: (518) 402-9469 outside New York StateFax: (518) 402-9168

Used Oil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Used Oil Storage Tanks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32Transporting Used Oil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32Accepting Used Oil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33Used Oil Space Heaters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33Used Oil Filters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33Brake Fluids . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

Pollution Prevention Tips . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34Waste Tires . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35Commonly Asked Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Section III - The Environmental Self-Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38Self-Assessment Checklists . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Materials Handling and Storage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39Parts Cleaning and Degreasing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42Maintenance and Repair Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44Body Repair and Painting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48Shop Cleanup . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

Section IV - Resource Guide . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52New York State Department of Environmental Conservation . . . . . . . . . . . . . . . . . . . . 52NYSDEC Regional Offices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53State and Local Assistance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54US Environmental Protection Agency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55New York State Permitted Household Hazardous Waste Facilities . . . . . . . . . . . . . . . . 56Resources on the Internet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58

Environmental Compliance, Pollution Prevention, and June 2003Self-Assessment Guide for Vehicle Maintenance Shops 1

INTRODUCTION

This guide was originally publishedin March 1998 and was revised on June2003. This revised guide:• eliminated the section on automobile

recyclers,• updated and added information on

several waste streams, and• updated or modified regulatory

requirementsfor all sections.

We have published aseparate manual for theautomobile recyclingindustry. The manualentitled,“EnvironmentalCompliance and Pollution Prevention Guidefor Automobile Recyclers,” can bedownloaded from the DEC website at:www.dec.state.ny.us/website/ppu/ p2pub.html.

This vehicle maintenance complianceguide is being offered by the PollutionPrevention Unit to assist businesses andinstitutions in New York State withenvironmental regulations, better wastemanagement and waste minimizationmethods. It was developed as a supplementto the manual Environmental Complianceand Pollution Prevention for Small QuantityGenerators which is intended for any smalland medium size business and institutionsthat generates hazardous waste. If yourbusiness or institution generates hazardouswaste, that manual will give you a goodoverview of the hazardous waste regulationsalong with a summary of otherenvironmental regulations that may pertainto your operation.

Also included in this guide is an Environmental Self-Assessment Checklist,

which is intended to help your business orinstitution achieve the maximumperformance from your day to day operationas well as prevent pollution and identifyopportunities for additional pollutionprevention measures. For the most part,smaller businesses and institutions are tryingto comply with applicable regulations andwould be willing to implement pollutionprevention measures if information couldbe presented to them in a format that is easyto understand. In an effort to assist those businesses and institutions that operatevehicle maintenance or auto body shops,DEC is offering this manual to provideinformation on how to properly managewastes that are generated at these facilities.This guide is divided into four sections:# Section I- A summary of DEC

regulations as they pertain to theautomotive repair and maintenanceindustry.

# Section II- A summary ofrequirements for waste streams thatmay be generated by the automotiveindustry. In addition it will give somepollution prevention tips for eachwaste stream mentioned.

# Section III - Environmental self-assessment checklist

# Section IV - A resource guide that willassist the automotive industry withnames and addresses of technicalassistance providers.Preventing waste is better than

managing it. If your company generates lesswaste, you will have less waste to manageand dispose of, resulting in lower disposalfees. If your business generates less waste,you reduce your risk of spills and dischargesthat contaminate the environment; you also

http://www.dec.state.ny.us/website/ppu/p2pub.html


reduce your liability risk.When you and your employees

familiarize yourselves with this guide, yourvehicle maintenance shop should have acompetitive advantage as far as knowing theregulations and the latest pollutionprevention techniques. Keep this manualwhere it will be available to your employeesso they can refer to it as needed.

INDUSTRY OVERVIEWThe motor vehicle and vehicle

maintenance industry accounts for asubstantial percentage of direct and indirectemployment in the U.S. According to theEPA publication, Profile of the MotorVehicle Assembly Industry, the U.S.automotive industry isthe largestmanufacturingindustry in NorthAmerica and accountsfor approximately fourpercent of the grossnational product (GNP). Also, according tothe American Automobile ManufacturersAssociation (AAMA), the U.S. was the thirdlargest producer of cars in the world, behindEurope and Asia respectively.

In New York State, there areapproximately 27,350 vehicle maintenanceor body repair shops that have the potentialto generate a variety of waste steams.

The automotive industry can bedivided into several categories whichinclude:

Vehicle Maintenance ShopsVehicle maintenance shops include

such businesses as new and used car dealers,service stations, municipal garages, fleetmanagement facilities and other similaroperations. Regulation requirements for

these shops will be covered in this manual.

Auto Body ShopsAuto body shops, or collision shops,

include any facility that conducts spraypainting operations on vehicles. Regulationsand pollution prevention opportunities forthese shops will be covered in this manual.

Vehicle Manufacturing IndustryThe vehicle manufacturing industry will

not be discussed in this manual. Thisindustry includes automobile manufacturersor businesses involved in motor vehicleassembly and involves such processes asmetal fabricating, metal finishing anddegreasing.

These processes could result inadditional air and water regulatoryrequirements that vehicle maintenanceshops and auto body shops would notnormally need to comply with.

Metal fabricating involves shaping ofmetal components such as automotive parts,fenders, hubcaps, and body parts. Metalfinishing is the process by which metal isprepared and properly cleaned beforeapplying the finished coated material. Thedegreasing operation is used to removecutting oils and other unwanted materialsfrom metals so that a final coating can beapplied.

Automobile Parts StoresThe automobile parts industry includes

businesses that engage in the retail sale ofnew or used automobile parts. This industrywill not be discussed in this manual unless itis also engaged in vehicle maintenance orrepair.

The automotive industry is responsiblefor generating a variety of air and waterpollution and solid and hazardous wastes.


The air issues are mainly with volatileorganic compound (VOC) emissions fromspray painting operations and freon from airconditioning systems. However, the issuessurrounding air toxics could arise from theuse of two-component urethane basedcoatings containing isocyanates.

The two main water quality issues arestorm water management and illegaldischarges from floor drains.

The solid and hazardous waste issuesare, by far, the biggest concerns facing theautomotive industry. There are many typesof fluids generated as part of this industrysector, and it is important that vehiclemaintenance shops try to use goodmanagement practices when handlingwastes.

Some topics that will be covered in thismanual are the following:

Used oilUsed antifreezeParts cleaners and degreasersUsed oil filtersShop towelsFloor drainsStorm water managementUnderground storage tanksAboveground storage tanksLead-acid batteriesTiresUsed oil-fired space heatersWastewater and sludgesRefrigerantsSpray painting operationsAbsorbentsSpill cleanupUsed fuel filtersAutomobile recyclersFluorescent bulbsUsed electronicsAir bagsMercury switches


Air Regulations

Regulations InformationAir permit requirements can be found in6 NYCRR Part 201, while the VOClimitations are provided in 6 NYCRRPart 228. Automotive facilities shouldalso address the requirements of 6NYCRR Part 226, Solvent MetalCleaning Processes, and 40 CFR Part63 Subpart T.

Section I - Regulations Overview

OPEN BURNINGNew York State law prohibits the

burning of rubbish for salvage and alsoprohibits the burning of rubbish generatedon site by commercial activities.

AUTO BODY SHOPSThis section will primarily pertain to

auto body shops, collision shops, or anyshop conducting spray painting operations.These shops will be referred to as auto bodyshops.

Volatile organic compounds (VOCs)are commonly found inemissions from the automotivepainting/finishing process andcome from the paint mixing,paint spraying, surfacepreparation and equipmentcleanup. Ground-level ozone, amajor component of “smog” is formed in theatmosphere by reactions of VOC and oxidesof nitrogen (NOx) in the presence ofsunlight. High levels of ground-level ozonecan endanger public health and damagecrops and forest. DEC regulates VOCsunder 6 NYCRR Part 228 (Surface CoatingProcesses) and 40 CFR Part 59 (NationalVolatile Organic Compounds EmissionStandards for Automobile RefinishCoatings).

The VOC content of these materials isfound on their respective material safetydata sheets (MSDSs). Call the productmanufacturer or your distributor if you needcopies of these MSDSs.

The National Emission Standards forHazardous Air Pollutants (NESHAPs), 40CFR Part 63 Subpart T, regulates

halogenated solvent cleaning machine thatuses any solvent containing methylenechloride, perchloroethylene,trichloroethylene, 1,1,1-trichloroethane,carbon tetrachloride, or chloroform, or anycombination of these halogenated HAPsolvents in a total concentration greater than5 percent by weight as a cleaning and/ordrying agent. The concentration of thesesolvents may be determined using EPAmethod 18, material safety data sheets, orengineering calculations.

Wipe cleaning activities, such as usingrags containing halogenated solvents orspray cleaner containing halogenatedsolvents are not covered under theprovisions of this Subpart.

Some of the more common hazardousair pollutants (HAPs) that are found inautomotive painting materials are:

1,1,1-trichloroethane1,1,2-trichloroethaneEthyl benzeneMethanol

Methylene chlorideMethyl isobutyl ketoneTetrachloroethyleneTrichloroethyleneTolueneXylene


PERMITTING REQUIREMENTSThe information in this section will

help you to determine if your shop willrequire an air permit or registration. The airpermit program is regulated under Title 6New York Codes, Rules, and Regulations,Part 201 (6 NYCRR Part 201). Your VOCcontrol requirements will be regulated under6 NYCRR Part 228, Surface CoatingProcess.

If you operate an auto body shop inNew York State, you may be required toobtain an air permit or registration. All autobody shops in the New York CityMetropolitan Area (New York City,Westchester, Rockland, Nassau, and SuffolkCounties) and the Lower Orange CountyMetropolitan Area (Towns of BloomingGrove, Chester, Highlands, Monroe,Tuxedo, Warwick, and Woodbury) mustobtain an air permit or registration no matterhow much surface coating (e.g., paints,solvents) they use. Shops outside the NewYork City Metropolitan Area mustdetermine if they need an air permit orregistration and, in addition, they shoulddetermine if Part 228 applies to them.

If your shop is not exempt from 6NYCRR Part 201, as described below, yourshop will need to obtain a Minor FacilityRegistration, State Facility Permit, or a TitleV Permit.

ExemptionsIf your auto body shop is not located in

the New York City Metropolitan Area orLower Orange County MetropolitanArea, and you meet the followingconditions, you are exempt from 6 NYCRRPart 201 registration or permittingrequirements and from 6 NYCRR Part 228VOC requirements if:# Your facility uses fewer than 25 gallons

per month collectively of paints,lacquers, makeup solvents, and cleanupsolvents, and;

# Your facility performs all abrasivecleaning and surface coating operationsin an enclosed building and theemissions are exhausted to appropriateemission control devices.

Minor Facility Registration

New York City Metropolitan AreaBusinesses whose total annual actual

VOC emissions are not greater than 12.5tons per 12 month period; whose individualactual HAP emissions are not greater than 5tons per 12 month period; whose combinedHAP emissions are not greater than 12.5tons per 12 month period or 5 tons of totalVOC emissions for those sources seeking acap to avoid the applicable requirements of6 NYCRR Section 228.7.

All Other AreasBusinesses whose total annual VOC

emissions are greater than 25 tons per 12month period; whose individual actual HAPemissions are not greater than 5 tons per 12month period; whose combined HAPemissions are not greater than 12.5 tons per12 month period or 5 tons of total VOCemissions for those sources seeking a cap toavoid the applicable requirements of 6NYCRR Section 228.7.NOTE:

Sources subject to 40 CFR Part 63Subpart T, regulations for metal degreasing,and emit one or more of the following:methylene chloride, methyl chloroform,chloroform, trichloroethylene,perchloroethylene, can obtain a registrationand are deferred from Title V permittinguntil December 9, 1999. These sources mustsubmit a Title V permit by December 9,2000.


State Facility Permit

New York City Metropolitan AreaBusinesses whose actual VOC

emissions are under 25 tons per year butover 12.5 tons per year and require apermitting cap to limit them as such; orbusinesses who are subject to 6 NYCRRSection 228.7, Table 1, and need to remainbelow 10 tons per year actual emissions ofVOC. Businesses whose individual andcombined HAP emissions are below 10 tonsand 25 tons per year, respectively.

All Other AreasBusinesses whose actual VOC

emissions are under 50 tons per year butover 25 tons per year and require apermitting cap to limit them as such; orbusinesses who are subject to 6 NYCRRSection 228.7, Table 1, and need to remainbelow 10 tons per year actual emissions ofVOC. Businesses whose individual andcombined HAP emissions are below 10 tonsand 25 tons per year, respectively.

Title V Facility PermitBusinesses who meet the major source

applicability thresholds as defined by 6NYCRR Part 201-2.1. Businesses subject to40 CFR Part 63 Subpart T see note underminor facility registrations on page 5.

RECORD KEEPINGGenerally speaking, just

about all auto body shops inupstate New York are exemptfrom minor facility registration orair permitting requirements.However, you should maintainrecords of your VOC emissionrates even if you use fewer than25 gallons per month.

By keeping these records, you will:# Show proof of compliance with

applicable DEC air requirements.# Be able to determine if your shop needs

any registrations or permits.# Be prepared to provide information to

any Regional DEC inspectors if, andwhen, they call to visit your shop.

# Help your shop toward implementing apollution prevention program.

One of the easiest ways to keep recordsof your VOC emissions is by keeping yourpurchase order invoices for all the paints,lacquers, solvents, or additives used by yourshop. Don’t forget to obtain a copy of theMSDS for each of the materials that youpurchase. If requested, most manufacturerswill fax or mail copies of MSDSs within aday or two.

HOW TO CALCULATE YOURVOC EMISSIONS

In order to determine what type ofregistration or permit your shop requires,you will need to know your total VOCemissions. To calculate your VOCemissions, you need to know your totalannual usage of paints, lacquers, makeupsolvents, and cleanup solvents. Asdiscussed in the previous section, thisinformation can be obtained from yourpurchase order records. Also, if any otheradditives or solvents are used in your shopthat contain VOCs, such as isopropylalcohol, the emissions from these materialsshould be accounted for in your calculations.

VOCs are equal to the annual usage rateof the materials applied, times the VOCcontent at the time of application.

Here’s how to calculate your totalannual VOC emissions for paints, lacquers,makeup solvents, and cleanup solvents:


Multiply your annual usage rate (gallons)of paints, lacquers, makeup solvents, andcleanup solvents by the density in poundsper gallon (from MSDS or technical datasheet) of paints, lacquers, makeupsolvents, and cleanup solvents by theweight fraction of VOCs in paints,lacquers, makeup solvents, and cleanupsolvents.

Note: Density = specific gravity X 8.34lbs./gal. Weight fraction is the percent byweight divided by 100 which can beobtained from the MSDS or technical datasheet.

Here is an example of how an autobody shop calculated some of their VOCemissions:

Example: Mr. Fix It Auto Body Shop uses130 gallons a year of paints and lacquers, 52gallons/year of thinners, and 20 gallons/yearof cleanup solvents. The Material SafetyData Sheets (MSDSs) lists the VOC contentat: paints and lacquers - 5.0 pounds/gallon,thinners - 6.5 pounds/gallon, and cleanupsolvents - 7.0 pounds/gallon.

VOC = Annual Usage x VOCContent at Application

Paints and LacquersAnnual Usage = 130 gallons

VOC Content = 5.0 pounds/gallonVOC = (130 gallons/year) (5.0pounds/gallon)

VOC = 650 pounds/year

ThinnersAnnual Usage = 52 gallons

VOC Content = 6.5 pounds/gallon

VOC = (52 gallons/year) (6.5 pounds/year)VOC = 339 pounds/year

Cleanup SolventsAnnual Usage = 20 gallons

VOC Content = 7.0 pounds/gallonVOC = (20 gallons/year) (7.0

pounds/gallon)VOC = 140 pounds/year

Total VOC EmissionsMr. Fix It Auto Body Shop’s total annualVOC emissions is 650 + 339 + 140 = 1129pounds.

In addition to the paints, lacquers,thinners, and cleanup solvents, your shopwill probably be working with primers,multi-coating, precoat, and specialtycoatings. You should check the MSDS forthe VOC content of these materials.

If you are a body shop with fewer than100 employees and need assistance incomputing your VOC emissions, finding outwhat registration/permits you need, orwhether 6 NYCRR Part 228 applies to yourshop, call the Small Business AssistanceProgram (SBAP) at (800) 780-7227. TheSBAP is a non-regulatory program thatprovides free confidential technicalassistance to help small businesses achievevoluntary compliance under the Clean AirAct.


Water Regulations

Regulations InformationIt is illegal to discharge directly to surfaceor groundwaters without a SPDES permit.Industrial discharges to septic systems arealso illegal.

RememberBefore discharging antifreeze, oil and grease,

solvents, acids, alkalides, or any other wastes

generated at your shop, check with your local

POTW.

PERMITTING REQUIREMENTSIf your shop directly discharges

wastewater into surface or groundwaters,then you are required to obtain a StatePollutant Discharge Elimination System(SPDES) Permit. These permits areregulated under 6 NYCRR Parts 750-758.

A SPDES permit will list all pollutantsyour facility is discharging into surface orgroundwater that DEC determines necessaryto address. It may contain limits, actionlevels or monitoring for each pollutant.Limits applied to your discharge will be themore stringent of either technology-basedlimits (sometimes referred to as bestavailable technology or BAT limits), orwater quality limits. Water quality limits arecalculated according to the classificationand ambient standards assigned to thespecific water body receiving the discharge. All surface waters and groundwaters in NYSare classified according to the best usage,e.g., drinking water or fish propagation.

To make certain you are complyingwith your permit limits, you may berequired to sample your discharge andsubmit monitoring reports. Contact yourregional DEC office for information onobtaining a SPDES permit.

PRETREATMENT PROGRAMIn most instances, vehicle maintenance

shops, auto body shops, automobilerecyclers, and scrap metal yards will requiresome form of pretreatment prior to dischargeinto a municipal sewer system. If youdischarge wastewater directly into amunicipal sewer system, you should checkwith your local publicly owned treatmentworks (POTW) for discharge requirements. There may be certain restrictions, in additionto pretreatment requirements, for thedischarge of wastewater into POTWs.

NONPOINT SOURCE PROGRAMIf you are involved in local passenger

transportation or involved in trucking andwarehousing you might have a nonpointsource discharge that could be regulated bya SPDES general permit.

Nonpoint source discharges include:inactive hazardous waste sites, leakingabove ground or underground storage tanks,contaminated soil, septic systems, and stormwater run-off.

Stormwater ManagementIn 1987 under the Clean Water Act,

EPA established a program to address stormwater discharges associated with industrialactivity. The term “storm water dischargeassociated with industrial activity” refers toa storm water discharge from one of 11categories of industrial activity defined in 40CFR 122.26. Six of the categories are


Hazardous Waste Regulations

ReminderIf you do not have acopy of the manualE n v i r o n m e n t a lCompliance andPollution Preventionfor Small QuantityGenerators, you canget your copy bycalling DEC at (518)402-9469.

defined by SIC codes while the other fiveare identified through narrative descriptionsof the regulated industrial activity. Thecategory that pertains to businessesdiscussed in this manual is:# Category viii: Facilities classified as

SIC code 40-railroad transportation;SIC code 41-local passengertransportation; SIC code 42-truckingand warehousing (except publicwarehousing and storage); SIC code 43-U.S. Postal Service; SIC code 44-watertransportation; SIC code 45-transportation by air; and SIC code5171-petroleum bulk storage stationsand terminals. It should be noted thatthe federal National PollutantDischarge Elimination System(NPDES) regulations state that: “Onlythose portions of the facility that areeither involved in vehicle maintenance(including rehabilitations, lubrication,mechanical repairs, fueling, andpainting), equipment cleaningoperations, airport deicing operations,or which are otherwise identified in[...the other groups of activities...] are(discharges) associated with industrialactivity.If your business is in category viii, you

must:# First, develop a “Storm Water

Pollution Prevention Plan.” In orderto do this, you must obtain a copy of theSPDES General Permit for StormWater Discharges. You can get a copyby calling your DEC Regional office(see Section IV for the location of yourregional office). The Storm WaterPollution Prevention Plan can bewritten by yourself or you can hire aconsultant.

# Second, submit a “Notice of Intent,”Transfer or Termination (NOITT) to:

Storm Water, General Permits,NYSDEC, Division of Water, Bureauof Water Permits, 625 Broadway,Albany, New York 12233-3505.

Call DEC at (518) 402-8098 if youhave any questions on the storm watermanagement program.

SAFE DRINKING WATER ACTThe Safe Drinking Water Act (SDWA)

authorizes EPA to protect undergroundsources of drinking water through thecontrol of underground injection of liquidwastes. EPA accomplishes this by thefederal Underground Injection Control(UIC) program. Under this program EPArequires owners and operators of facilitiesthat discharge non-sanitary wastewaters togroundwater to (1) either close the cesspool,drywell or septic system, or (2) obtain apermit under the UIC program. This sectionis included to let the vehicle maintenanceindustry be aware that floor drains shouldnot have a direct discharge to the ground orgroundwater. This could be considered anunderground injection and would constitutea violation of the SDWA unless authorizedby a UIC permit. For further information onfloor drains, see Section III.

The New YorkState hazardouswaste regulations arecovered under 6NYCRR Parts 370-374 and 376 andapply to any businessin the automotiveindustry thatgenerates hazardouswaste. This includes,


but is not limited to, vehicle maintenanceshops, auto body shops, automobilerecyclers, and service stations.

No matter what wastes you dispose of,it is your responsibility to determine thetype and quantity of hazardous waste yougenerate and properly manage it. Sincedisposal fees for hazardous waste can bevery expensive, it would be in your bestinterest to practice good hazardous wastemanagement. Call the Bureau of HazardousWaste Regulations at (518) 402-8633 forassistance with managing your hazardouswaste. Also, refer to Section IV for moreinformation on technical assistanceproviders.

Here are some hazardous wastescommonly generated by auto body shopsand vehicle maintenance shops:# Heavy metal wastes# Ignitable wastes# Solvent wastes# Toxic wastes# Still bottoms# Paint wastes# Acids/bases# Rags

HAZARDOUS WASTEDETERMINATION

If you generate waste at your facility,you should determine which wastes arehazardous. As a good management practice,you should always keep solid waste separatefrom your hazardous wastes. This willreduce or eliminate the mixing and/orcontamination of wastes which couldincrease your disposal costs.

One way to make a hazardous waste determination is to see if your waste is listedin the New York State regulations, 6NYCRR Part 371. If your waste is listed inPart 371, it is automatically a hazardouswaste. Even if your waste is not listed, itwould still be a hazardous waste if itexhibits one of the hazardous waste

characteristics of ignitability, corrosivity,reactivity, or toxicity found in 6 NYCRRPart 371 and described further below.

You can also apply your knowledge ofthe waste to determine if it exhibits ahazardous characteristic. You must have abasis for making this determination such asmaterial safety data sheets (MSDSs) or pastanalytical results. MSDSs may containimportant information such as ignitability(flashpoint), corrosivity, or reactivity forsubstances or chemicals that you use in yourshop. Please note that MSDSs only describethe new product. During use, a non-hazardous product could become hazardousby mixing or contamination.

KNOWLEDGEIf you are certain that a specific waste that yougenerate is not a hazardous waste because of yourknowledge about this waste, then you can dispose ofthis waste as a solid waste. However, it is yourresponsibility to make this determination and youwill be liable for any illegal disposal of hazardouswaste if your determination is not correct.

The term hazardous wastedetermination will be mentioned throughoutsection III of the manual. If your vehiclemaintenance shop generates hazardouswaste, you should understand the term sinceit applies to most of the waste streamsmentioned in that section.

If you generate a waste at your shopthat is not listed in 6 NYCRR Section 371.4of the hazardous waste regulations, youmust then determine if that waste ishazardous for any of the following fourcharacteristics: ignitability, corrosivity,reactivity, and toxicity.

IgnitabilityIf your liquid waste has a flashpoint of

less than 140E F, it is hazardous. Examplesinclude: certain parts cleaners, paintsolvents, waste kerosene, and wastegasoline.


Did You Know?As a CESQG, youcan transport up to220 lbs per month ofyour own waste to aN Y S a p p r o v e dfacility.

CorrosivityIf your waste has a pH of 2.0 or lower,

or a pH of 12.5 or higher, it is hazardous.Examples include: lead-acid batteries,certain rust removers, caustic partsdegreaser, and acid or alkaline cleaningsolutions.

ReactivityIf your waste is unstable and undergoes

violent chemical reaction spontaneously orreacts violently with air or water, it ishazardous.

ToxicityIf your waste is not ignitable, corrosive

or reactive, then it might have to be testedfor toxicity according to the methodsexplained in 6 NYCRR Part 371.3(e) or inthe federal regulations, 40 CFR Part 261.Examples include: certain painting wastes,paint booth filters, floor sweepings, usedshop towels or rags, oily wastes, oilabsorbents, floor drain and sump sludge, andused antifreeze.

A toxicity test is done by having arepresentative sample of the waste tested bya certified lab where it is analyzed using atoxicity characteristic leaching procedure(TCLP) test. To download a list of certifiedlabs in New York State, go to the website:www.wadsworth.org/labcert/elap/elap.html. If any of the allowable levels are exceeded,then the waste is a hazardous waste.

HAZARDOUS WASTECATEGORIES

Once you have determined that yourbusiness generates hazardous waste, then itis necessary todetermine yourhazardouswastegenerator-category. Depending onthe quantity andtype of waste

generated, and the amount of waste stored,you will be in one of the followingcategories: Conditionally Exempt SmallQuantity Generator (CESQG), SmallQuantity Generator (SQG), or LargeQuantity Generator (LQG).

Conditionally Exempt SmallQuantity Generator

A conditionally exempt small quantitygenerator (CESQG):# Generates no more than 220 pounds

(approximately 26 gallons) ofhazardous waste per calendar month,

# Generates no more than 2.2 pounds ofacute hazardous waste per calendarmonth, and

# Stores no more than 2,200 pounds ofhazardous waste or 2.2 pounds of acutehazardous waste on site at any time.

A CESQG Must Comply With TheFollowing:# Identify its hazardous waste.# Comply with storage quantity limits.# Ensure proper treatment and/or disposal

of its waste.# Ensure delivery of the waste to a

treatment or disposal facility bybringing no more than 220 pounds ofhazardous waste to the authorizedtreatment or disposal facility; or byhaving the waste transported by a 6NYCRR Part 364 permitted hazardouswaste transporter.

A CESQG must ensure delivery of itshazardous waste to an offsite treatmentor disposal facility that is:# A state or federally regulated hazardous

waste management treatment, storageor disposal facility.

# A facility permitted by NYS to managemunicipal or industrial solid waste andauthorized to receive CESQGhazardous waste.

http://www.wadsworth.org/labcert/elap/elap.html


# A facility that uses, reuses orlegitimately recycles the waste.

# A permitted household hazardous wastecollection facility that accepts CESQGwaste. See Section IV for a list ofparticipating municipalities.

Small Quantity GeneratorA small quantity generator:

# Generates between 220 pounds and2,200 pounds of hazardous waste percalendar month,

# Generates less than 2.2pounds of acute hazardouswaste per calendar month,and

# Stores less than 13,200pounds of hazardouswaste or 2.2 pounds of acute hazardouswaste on site at any time.

A SQG Must Do The Following:# Obtain an EPA Identification Number

by calling EPA at (212) 637-4106.# Use a hazardous waste manifest form.# Use a 6 NYCRR Part 364 permitted

hazardous waste transporter.# Limit on-site storage. Waste must be

shipped within 180 days ofaccumulation (or 270 days if thetreatment, storage, or disposal facility isgreater than 200 miles away.)

# Follow emergency preparedness andresponse requirements.

# Adhere to land disposal restrictions.

Small quantity generators cannot transporttheir own waste. They must use a 6 NYCRRPart 364 permitted transporter.

Storing Hazardous Waste# Keep the waste in a separate storage

area which is labeled “HazardousWaste Storage Area.” Containersholding ignitable of reactive hazardouswaste should be stored at least 50 feet

from the property line.# Label all containers

properly. Containersshould be clearly labeled“Hazardous Waste”. Also, signs indicating“Do Not Enter” and“No Smoking” shouldbe clearly posted.

# Mark each container with the date you began collecting waste in thatcontainer.

# Use proper containment (pallets withbuilt-in spill containment or berms) incase of leaks.

# Keep containers closed when not in use.# Keep containers in good condition and

periodically inspect for leaks, cracks orrust.

# Label containers with the name of thewaste.The above is a summary of the

requirements for SQG’s. For moreinformation on small quantity generators,request a copy of the manual, EnvironmentalCompliance and Pollution Prevention forSmall Quantity Generators by calling (518)402-9163. Complete requirements forSQG’s can be found in 6 NYCRR Parts 370-374 and 376 or you can download a copyfrom the DEC website at: www.dec.state.ny.us/website/ dshm/regs/370parts.htm

Large Quantity GeneratorIf the facility generates more than 2,200

lbs. of hazardous waste or 2.2 pounds ofacute hazardous waste per month, or storemore than 13,200 pounds of hazardouswaste, or 2.2 pounds of acute hazardouswaste, including hazardous wastes fromother operations on the same site, then thefacility is a Large Quantity Generator(LQG). Large Quantity Generators are fullyregulated under 6 NYCRR Parts 370-374and 376 and are not covered in this manual.LQGs can obtain a copy of the regulations

http://www.dec.state.ny.us/website/dshm/regs/370parts.htm


by calling (518) 402-8633, or you candownload a copy from the DEC website at: www.dec.state.ny.us/website/dshm/regs/ 370parts.htm

UNIVERSAL WASTE RULESTo streamline the hazardous waste

regulations for hazardous wastes that aregenerated by large numbers of sources inrelatively small quantities, USEPA issuedthe Universal Waste Rule in 1995. Theuniversal waste regulations govern thecollection and management of widelygenerated wastes. In NYS, hazardouswastes which can be managed as universalwaste currently include batteries, certainpesticides, thermostats, and lamps. Theseregulations were designed to reduce theamount of hazardous waste items in themunicipal solid waste stream; encourage therecycling and proper disposal of somecommon hazardous wastes; and reduce theregulatory burden on the regulatedcommunity. Universal wastes are generatedin a wide variety of settings includinghouseholds, schools, office buildings, andmedical facilities, in addition to theindustrial settings usually associated withhazardous wastes. Universal wastes includesuch items as hazardous batteries, hazardousmercury-containing thermostats, certainpesticides, and hazardous lamps. Althoughhandlers of universal wastes must meet lessstringent standards for storing, transporting,and collecting wastes, the wastes mustcomply with full hazardous wasterequirements for final recycling, treatment,or disposal. This approach removes thesewastes from municipal landfills andincinerators, which provides strongersafeguards for public health and theenvironment.

BatteriesBatteries included are nickel-cadmium

(Ni-Cd), certain lithium, small sealed

lead-acid batteries, and batteries that exhibithazardous waste characteristics. These maybe found in many common items in thebusiness and home, including electronicequipment, mobile telephones, portablecomputers, and emergency backup lighting.

Mercury ThermostatsMercury thermostats are located in

many buildings including offices, schools,industrial facilities, and homes.

PesticidesAgricultural pesticides that are recalled

under certain conditions and unusedpesticides that are collected and managed aspart of a waste pesticide collection program. Pesticides may be unwanted for a number ofreasons, such as being banned, obsolete,damaged or no longer needed due tochanges in cropping patterns or otherfactors.

Hazardous LampsExamples of common universal waste

hazardous lamps include, but are not limitedto, fluorescent lights, high intensitydischarge, neon, mercury vapor, highpressure sodium, and metal halide lamps. Many used lamps are considered hazardouswastes under the Resource Conservation andRecovery Act (RCRA) because of thepresence of mercury or occasionally lead.

REQUIREMENTSIf your waste includes hazardous

batteries, pesticides, thermostats, or lamps,you must decide whether or not you willmanage them as universal waste. You maychoose between traditional hazardous wasteregulations or universal waste rulestandards. However, flip-flopping betweenthe two sets in order to avoid meetingrequirements of one or both sets ofregulations is not allowed. For example,storage time limits exist for both

http://www.dec.state.ny.us/website/dshm/regs/370parts.htm


management scenarios. Flip-floppingbetween regulations will not extend storagetime.

If you decide to manage these wastesunder the traditional hazardous wasteregulations, you must count them indetermining whether you are a conditionallyexempt small quantity generator (CESQG),a small quantity generator (SQG) or a largequantity generator (LQG). They must alsobe reported on the generator annual report ifyou are required to file an annual report. Universal wastes are not counted for thepurpose of determining generator category,and need not be reported on your hazardouswaste report.

PROPER HANDLING ANDSTORAGE

If your facility manages any of theabove mentioned universal wastes at yoursite, then you are either a small quantityhandler or a large quantity handler ofuniversal waste. A small quantity handler ofuniversal waste is any facility that handlesless than 5,000 kg (11,000 lbs) of totaluniversal wastes on site at any time. Requirements include packaging in a way tominimize breakage; immediately cleaningup any leaks or spills; employee training,and properly labeling containers. A largequantity handler of universal waste handles5,000 kg (11,000 lbs) or more of totaluniversal wastes on site at any time.Requirements include EPA notification;packaging in a way to minimize breakage;immediately cleaning up any leaks or spills;employee training, and properly labelingcontainers; and complying with recordkeeping and reporting requirements. Bothhandlers can store universal waste up toone year on site.

Universal waste transporters must meetapplicable DOT standards; comply withrecord keeping and reporting requirements;and comply with applicable requirements of

6 NYCRR Part 364 if transporting morethan 500 lbs of total universal waste in anyshipment. Common carriers can transport upto 500 lbs of universal waste in anyshipment.

Destination facilities must comply withall applicable requirements of 6 NYCRRParts 370 through 374-3 and 376, includingnotification of hazardous waste activity andobtaining a Part 373 hazardous wastepermit, if applicable.

LAMP CRUSHERSLamps being managed under the

universal waste rule may not be crushed. Ifyou wish to crush your lamps, you will needto manage the lamps under the traditionalhazardous waste regulations. This willrequire that you count the weight of thelamps toward determining hazardous wastegenerator category, and you will be requiredto meet applicable generator, transporter andtransfer facility standards. Crushing isconsidered a form of hazardous wastetreatment, and under ordinary hazardouswaste generator regulations, hazardouswaste lamps may only be crushed if theprocess is exempt from hazardous wastetreatment regulations (6 NYCRR373-1.1(d)(1)). The common exemptionsthat might be used are the on-site treatmentby a conditionally exempt small quantitygenerator; the first step of a recyclingprocess, if the lamps will be directed to amercury recycler; or the treatment in thetank or container in which the lamps arebeing stored. Generators who wish to useone of the latter two exemptions should seekspecific guidance from the Bureau ofHazardous Waste Regulation at (518) 402-8633. The crushed lamps are usuallyconsidered hazardous waste for mercury,and sometimes for lead, and must behandled and disposed of via normalhazardous waste requirements.


Solid Waste Regulations

Petroleum and ChemicalBulk Storage Regulations

In 1988 the Solid Waste ManagementAct put emphasis on waste reduction, reuseand recycling as primary solid wastemanagement methods.

Every vehicle maintenance shop shouldbe aware of what items they are discardingand how they are disposing of them. Thebest way to do this is to develop a solidwaste management disposal plan for yourshop. The first step in developing your planis to conduct a waste audit of your business. A waste audit will show where you can improve your purchasing practices and helpidentify potential waste reduction andrecycling options. Also, a waste audit willhelp you get accurate information on thenature and quantity of your waste.Businesses that implement waste reduction,reuse and recycling have benefitted byreducing costs.

Here are some waste reduction andrecycling strategies your company canadopt:# Use reusable shipping containers and

pallets.# Use minimal or reusable packaging.# Purchase reusable products and supplies.# Recycle your office paper.# Make sure your employees practice waste

reduction and recycling methods.

If you need a copy of the Waste AuditReference Manual call the DEC Bureau ofWaste Reduction & Recycling at (518) 402-8678.

Materials generated on or off-site whichhave no recycling value must be disposed ofat a permitted solid waste managementfacility.

Nonmetallic materials used to constructvehicles are considered solid wastes if theyare not destined for recycling. Thesematerials cannot be disposed of at the

dismantling facility by burial orincineration.

EPA TANK DEADLINEAs of December 22, 1998, all

underground storage tanks (USTs) greaterthan 110 gallons (except those tanks usedfor on-site heating oil) should have beenupgraded to meet EPA standards forcorrosion protection and overfill. Tanks thatweren’t properly upgraded should be closed.If your facility has not upgraded or closedyour underground storage tanks to meetEPA requirements you should contact yourregional DEC office.

Part 598 establishes the upgraderequirements for USTs with a deadline ofDecember 22, 1998 (the same as EPA’sUST program) and for ASTs with a deadlineof December 22, 1999. Facilities constructedafter February 11, 1995 must meet thestandards for all new or substantiallymodified facilities (Part 599). Theinstallation of a new tank, even areplacement tank, is considered a substantialmodification. Repairs and replacements toancillary piping, vents, gauges, pumps, etc.,are not considered substantial modifications.

USTs are required to be (1) corrosionresistant, which consists of cathodically-protected steel, fiberglass-reinforced plastic,or a combination of both, and must have (2)secondary containment with interstitialmonitoring for leak detection.

If the tank is not double-walled, it mustbe installed inside an excavation liner tocontain any releases. All USTs must beequipped with spill and overfill preventiondevices to include high-level alarms orautomatic shutoff devices, spill catchmentbasins at the fill-port, and secondarycontainment for the transfer station.


Underground piping must be corrosionresistant and have secondary containmentwith interstitial monitoring.

As of December 22, 1999, all ASTsshould have been upgraded. Tanks incontact with soil must be cathodicallyprotected. Tanks constructed of materialswhich could melt when exposed to fire mustbe protected from fire. All ASTs must havesecondary containment and be equippedwith a product level gauge and either a high-level alarm, a high level trip, or an overflowto a catch tank. The storage tank must beequipped with valves to control the flow ofproduct for each tank connection.

DEC TANK REQUIREMENTSIn addition to the EPA upgrading

requirements for underground tanks asdiscussed above, DEC has establishedstandards for both above ground andunderground petroleum storage facilitieswith a capacity of more than 1,100 gallons.(See 6 NYCRR 612-614). Further, allunderground tanks and any stationaryaboveground tanks of 185 gallons or morewhich store a hazardous substance and non-stationary tanks storing 2,200 pounds ormore of a hazardous substance, or a mixturethereof, for a period of ninety days or more,are subject to the technical standards of 6NYCRR Parts 598 and 599. Antifreeze(ethylene or propylene glycol) is a regulatedhazardous substance.

Both petroleum and hazardoussubstance tanks must be registered withDEC. For more information and a copy ofthese regulations, call (518) 402-9549.

STORAGE REQUIREMENTSAny tank storing used oil, no matter

what the size, is subject to petroleum bulkstorage requirements, including registrationwith DEC. Drums do not have to beregistered. You can obtain a copy of theregistration form from our website at:

www.dec.state.ny.us/ website/der/bulkstor/forms/index.html

If you are storing non-hazardousantifreeze in a tank greater than 185 gallons,the chemical bulk storage program requiresthat this tank be registered. Drums that areused to store non hazardous antifreeze donot have to be registered. You can obtain acopy of the registration form from ourwebsite at the address listed in the aboveparagraph.

Secondary ContainmentSecondary containment is any structure

which is designed to prevent leaks and spillsfrom reaching the land or water outside thecontainment area. All aboveground tankswith a capacity of 10,000 gallons or moremust be equipped with secondarycontainment. All aboveground tanks smallerthan 10,000 gallons are required to beequipped with secondary containment if it isreasonably expected that the facility iswithin close proximity to ground or surfacewaters of the state. Facilities within 500 feetof the following resources may beconsidered presumptive evidence of being inclose proximity to ground or surface waters:# perennial or intermittent stream;# public or private well;# primary or principal aquifer;# wetlands as defined in 6 NYCRR 664;# lake, pond, estuary, etc.; or# storm drain.

CHEMICAL BULK STORAGEPROGRAM

New York’s chemical bulk storage(CBS) program addresses both underground(UST) and aboveground storage tanks(AST) containing regulated hazardoussubstances. In 1986, the state legislaturepassed the Hazardous Substance BulkStorage Act, which required DEC toestablish a program for preventing therelease of hazardous substances into the

http://www.dec.state.ny.us/website/der/bulkstor/forms/index.html


environment. Phase I (6 NYCRR Parts 595,596, and 597) of the CBS regulations wasadopted on July 15, 1988 and established alist (Part 597) of chemicals to be regulated.These regulations (Part 596) required theregistration of ASTs that exceed 185-galloncapacity and all USTs that store any of thesehazardous substances either singularly or incombination.

Phase II was adopted on August 11,1994. This phase modified Parts 595, 596,and 597 and established minimumrequirements and schedules in Parts 598 and599 for the design, construction, installation,operation, maintenance, repair, monitoring,testing, and inspection of storage facilities.

Secondary Containment atTransfer Stations

A transfer station is an area where pipesor hoses are connected and disconnected toempty or fill a storage tank. This includesrailways, roads, containment basins, curbs,collection sumps, and impervious padswhere a vehicle or container is located tooff-load or to receive a hazardous substance,where a coupling to a transfer line is madefor the purpose of hazardous substancetransfer, or where a system to collect andcontain spills resulting from transfer islocated. As of December 22, 1999, alltransfers of hazardous substances at aregistered facility must occur within atransfer station equipped with permanentlyinstalled secondary containment. The goalof the program is to control any release frombulk storage systems and transfer operationsand to reduce/eliminate releases to soil,surface water, and groundwater.

Spill Prevention Report (SPR)The SPR is considered to be the

cornerstone of the CBS regulations and wasrequired by August 11, 1996. The majorelements of the SPR require a listing of allspills over the previous five-year period, an

assessment of the causes of those spills, acompliance assessment of bulk storageoperations, records of inspections, a spillresponse plan, and management’s signatureindicating acceptance and approval of thereport. A proper SPR can minimize andeliminate injury, loss of life, hospitalization,subsequent remediation, and reduce overallliability.

PETROLEUM BULK STORAGEPROGRAM

In 1983, the State Legislature enactedArticle 17, Title 10 of the EnvironmentalConservation Law, entitled "Control of theBulk Storage of Petroleum." The Lawapplies both to Underground Storage Tanks(USTs) and aboveground storage tanks(ASTs), or groupings of such tanks with acombined storage capacity of more than1,100 gallons. Exempted from this lawbecause they are regulated under otherprograms are: oil production facilities;facilities licensed under the Navigation Law;and, facilities regulated under the NaturalGas Act.

Under 6 NYCRR 612-614 passed in1985, owners were required to registerstorage facilities with DEC by December 27,1986. Facilities must re-register every fiveyears. Registration fees vary from $50 to$250 per facility, depending on capacity.Some 114,000 tanks, holding a total ofnearly 4.4 billion gallons, are registered inNew York. New facilities must be registeredbefore being placed into service. DEC mustbe notified 30 days prior to substantialmodifications.

Nassau, Suffolk, Rockland,Westchester, and Cortland Countiesadminister the program in these localities,pursuant to delegation from DEC. Becausethese counties may have more stringentrequirements than the State, owners andoperators should contact the county to learnof specific local requirements.


All facilities regulated under Article 17,Title 10 must meet certain handling andstorage requirements established by DEC.Existing USTs and ASTs must observe rulesfor color coding of fill ports, shutoff valves,gauges and check valves. Abovegroundtanks must be provided with secondarycontainment (i.e., berms or other devices tocontain spills). Operators of USTs mustkeep daily inventory records (and maintainthem for five years) and notify DEC and thetank owner within 48 hours of unexplainedinventory losses. They must also test tanksand pipes every five years or monitor theinterstitial space of double- walledequipment. Operators of ASTs mustconduct monthly visual inspections. Every10 years they must clean out the tanks,remove the sludge from the bottom, inspectfor structural integrity and test for tightness.

Tanks that are temporarilyout-of-service (30 days or more) must bedrained of product to the lowest draw offpoint. Fill lines and gauge openings must becapped or plugged. Inspection andregistration must continue. Those tanks thatare permanently out-of- service must beemptied of liquid, sludge and vapors andmust either be removed or filled with solidinert material, such as sand or concreteslurry. DEC must be notified 30 days priorto filling or removal.

Part 614 applies to all new andmodified facilities. New USTs must eitherbe made of fiberglass reinforced plastic;cathodically protected steel (to protectagainst the corrosion caused by contactbetween steel and soil); or steel clad withfiberglass reinforced plastic. Secondarycontainment such as a double-walled tank, avault, a cut-off wall or imperviousunderlayment must be provided. Double-walled tanks must have the interstitial spacemonitored for leaks. If one of the othersecondary containment options is chosen, anin-tank monitoring system, or one or moreobservations wells can be used. New ASTs

must be constructed of steel. If their bottomrests on the ground, the tank must havecathodic protection. An impermeablebarrier must be installed under the tankbottom, with monitoring between the barrierand the bottom. New underground pipingsystems must be designed with a 30-year lifeexpectancy. If made of steel, they must becathodically protected. Pipes may beconstructed of fiberglass- reinforced plasticor other equivalent non-corrodible materials.

WHEN TO REPORT A SPILL?Reporting spills is a crucial first step in

the response process. There may be severaldifferent state, local, and federal laws andregulations that require spillers to reportpetroleum and hazardous materials spills.

Hazardous SubstancesAssociated with each regulated

hazardous substance under Part 597 is aReportable Quantity (RQ), one for a releaseto air and one for a release to land/water.Appropriate parties are required to takeprompt remedial action to protect humanhealth and the environment in the event of aspill. A spill that exceeds the RQ but iscontained by effective secondarycontainment, and which is cleaned up within24 hours, is not reportable unless it couldresult in a fire or explosion or pose a healthrisk to adjacent parties. When a spill cannotbe contained, it becomes a release to theenvironment. When a release exceeds theRQ for that substance, the facility mustreport the release to the DEC Spill Hotline(800) 457-7362 within two hours ofdiscovery. Part 595 applies to all releases,including those from chemical processtanks, chemical fires, explosions, and non-registered facilities.

Petroleum ProductsPetroleum spills must be reported to

DEC unless they meet all of the followingcriteria:1. The spill is known to be < 5 gallons.2. The spill is contained and under the

control of the spiller.3. The spill has not and will not reach

the State’s water or any land.4. The spill is cleaned up within two

hours of discovery.

All reportable spills must be reportedto the DEC spills Hotline at 1-800-457-7362.

___________________________________________________________________________________________________________________Environmental Compliance, Pollution Prevention, and June 2003Self-Assessment Guide for Vehicle Maintenance Shops 19

Section II - Waste Stream Management and Pollution Prevention

(If you have not read section II of this manual,Regulations, you should do so in order tofamiliarize yourself with the requirements andconditions for hazardous waste generators).

To assist the vehicle maintenanceindustry in complying with environmentalrequirements, this section discusses somebest management practices for the wastestreams that are typically generated in thisindustry. Each waste stream listed will givethe reader an interpretation of the DECregulatory requirement and the preferredwaste management techniques that shopsshould use when disposing of their waste. Ifyou require more information, refer toSection I, the Regulations Overview.

Also included in this section aresome pollution prevention methods that canbe used to minimize each of the wastestreams discussed. The term pollutionprevention (P2) refers to the elimination orreduction in volume or toxicity of wasteprior to generation or prior to recycling,treatment or release to the environment.Pollution prevention can also be referred toas waste reduction, waste minimization, orsource reduction. An effective pollutionprevention program can:# Reduce the risk of criminal and civil

liability.

# information about the material.# Inspect all shipments and return all

unacceptable or damaged materials;especially those items that couldbecome hazardous wastes once theyare signed for.

# Practice preventive maintenance ofequipment.

# Cover solvent tanks when not in useto reduce evaporation.

# Improve purchasing and inventory methods to ensure that materials do not exceed shelf life. Date all rawmaterials and chemicals and use thefirst-in, first-out method of inventorycontrol. Expired and outdatedmaterials that can’t be used createwaste.

# Turn off electrical equipment such aslights and copiers when not in use.

Remember, the first step inestablishing a pollution prevention programat the facility is to implement employeeawareness. One way this can be achieved isby offering training sessions on regulatorycompliance and waste minimization so thatthe employees can familiarize themselveswith the proper waste managementstrategies.

____________________________________________________________________________________________________________________Environmental Compliance, Pollution Prevention, and June 2003Self-Assessment Guide for Vehicle Maintenance Shops 20

Absorbents and Floor DryEven if the shop only generates a smallamount of waste, keep in mind that there arethousands of shops that generate a smallamount. Together, these shops generate alarge amount of waste that must be managedproperly.

All hazardous waste generators thatare required to manifest their hazardouswaste are subject to the EnvironmentalConservation Law (ECL) 27-0907. Thesegenerators must sign a certification on themanifest form that, “the generator ofhazardous waste has in place a program toreduce the volume or quantity of toxicity ofsuch waste to the degree determined by thegenerator to be economically practical.” Agood source of guidance is the “HazardousWaste Reduction Plan - GuidanceDocument,” available from the HazardousWaste Reduction Section of the Division ofSolid and Hazardous Materials at (518) 402-8610.

The following discussions by waste streamwill include a summary of the regulatoryrequirements for that particular waste. If therequirements state that a hazardous wastedetermination must be made, then you willhave to determine if your waste can bedisposed of as a hazardous waste or as asolid waste. If you need assistance indetermining how to manage any of thefollowing waste streams, you can call theBureau of Hazardous Waste Regulation at(518) 402-8633.

REGULATORYREQUIREMENTS

A hazardous waste determinationmust be made on all absorbent pads or floordry material that is used to clean up spills. Ifyour facility has a spill that could beharmful to public health or the environment,you must contact DEC immediately at (800)457-7362.

POLLUTION PREVENTION TIPSGood housekeeping practices are the

best way to minimize spills. The fewerspills that occur, the less absorbents, floordry or other absorbent material will beneeded to clean up these spills. Here aresome tips to help you prevent spills at yourshop:# Train your employees. Since

employees are the ones who createthe spills, make sure that eachemployee is taught the importance ofspill prevention.

# If you must use absorbents, makesure to purchase absorbent materialthat can be reused. Absorbent“socks” for example, can be usedabout 10 times.

# Make sure all of your tanks or drumsthat contain liquids have some kindof containment in case of a leak orspill.

# After wiping up a spill withabsorbents or mop, drain excessliquids into the waste container forthat particular waste. For example, ifyou are cleaning up an antifreezespill, squeeze the excess antifreeze inthe container marked ANTIFREEZE.


Aerosol Cans

Antifreeze

# Use shop towels to wipe up small spills,then send your shop towels to belaundered.

# You may want to consider an awardprogram for employees that keep theirwork areas clean or for workers whocome up with good pollution preventionideas.

AlertBefore discarding absorbents or floor dryinto dumpsters, make sure you arecomplying with all the necessary DECregulations.


Aerosol cans that have not beenemptied can be considered a hazardouswaste due to the leftover propellant. Inaddition, the material inside the can, such ascarburetor cleaner, brake cleaner, ordegreasers, can be hazardous. Therefore, ifaerosol cans are not empty, a hazardouswaste determination must be made beforedisposal.

POLLUTION PREVENTION TIPSHere are some tips on the management

of aerosol cans:# Replace aerosol cans by using refillable

spray canisters.# If aerosol cans are used, utilize all the

material and propellant in the can. Cansthat are empty and are at or nearatmospheric pressure, are no longerconsidered hazardous wastes.

# Use the contents of each can beforestarting a new one.

# If you get a defective aerosol can thatcan’t be used, try to return it to yourvendor, otherwise, handle it as

hazardous.# Recycle empty cans or bring them to a

scrap metal yard.# Buy a puncturing system that will

render all cans empty.


Antifreeze usually contains ethylene orpropylene glycol, corrosion inhibitors, andfoam controllers, and is usually diluted to 50percent concentration with water in motorvehicles. Ethylene or propylene glycol, themain ingredients of antifreeze, are not, whenused, listed hazardous wastes. Antifreezemay become hazardous when contaminantssuch as heavy metals, fuel, and solvents getmixed in when circulating through theengine and cooling systems of theautomobile. Therefore, if you are disposingof antifreeze, a hazardous wastedetermination must be made unless the usedantifreeze is recycled by a totally enclosedsystem that hooks up to the vehicle’s coolantsystem, and in which no used antifreezeexits the system.

Recycling of AntifreezeHere are some tips about recycling

antifreeze:# If your shop reuses its antifreeze that is

recycled on site, you can save moneyon disposal fees.

# If a mobile unit recycles your antifreezeat your shop, you will be eligible for arecycling exemption provided that themobile unit complies with theprovisions for proper containment asstated in 6 NYCRR 373-1.1(d)(1)(vii)(a-b) and 373-2.9(f). Thestorage of hazardous waste prior torecycling is not exempt from the


ALERTIt is illegal andd a n g e r o u s t odischarge antifreezeto septic systems orto outdoors.

Floor Drains andWastewater

hazardous waste requirements.

Storing AntifreezeStorage of new or non-hazardous

antifreeze is regulated by the DEC ChemicalBulk Storage Program (CBS) because it isclassified as a hazardous substance. If virginor used non-hazardous antifreeze is stored ina tank with a capacity of 185 gallons orgreater in an above ground tank, or anyamount is stored in an underground tank, thesite must register with DEC and complywith CBS regulations. As with the storageof used oil, secondary containment isrequired for the storage of antifreeze inabove ground tanks.

POLLUTION PREVENTION TIPSHere are some tips on managing your

antifreeze:# Segregate you antifreeze from other

wastes.# Store antifreeze in closed containers

labeled “ANTIFREEZE.”# When removing

good antifreeze dueto servicing, save itand return it to thesystem whenrepairs are finished.Also, whenremoving goodantifreeze, use drippans and try to avoid spills.

# Consider the purchase of an antifreezerecycling unit. It has been proven thatrecycled antifreeze does perform aswell as new antifreeze as long as theinhibitors are replaced and theantifoaming agent is added.

# Do not discharge antifreeze to septictanks or to the outdoors. Prior approvalfrom your local publicly ownedtreatment works is needed in order todischarge antifreeze to the sewersystem.

# Make sure your antifreeze storage tanksor drums have proper containment incase there is a leak or spill.


As discussed in Section I, theEnvironmental Conservation Law prohibitsthe discharge of pollutants into surface orgroundwaters without a State PollutantDischarge Elimination System (SPDES)Permit. The Safe Drinking Water Act, underthe Underground Injection Control programadministered by EPA was designed toprevent contamination of groundwaterresulting from operation of injection wells. In addition, the disposal of hazardous wasteillegally is a violation of the federalResource Conservation and Recovery Act(RCRA).

Wastewater from automotive shopsmay contain heavy metals, antifreeze,solvents, oil and grease, gasoline, and othermaterials that could be hazardous.

If you have floor drains in your shop,you must meet the following requirements:# Make sure they are connected to a

public sewer system. In most casesfloor drains may be connected to apublicly owned treatment works(POTW), however, the owner shouldrefer to the Local Codes EnforcementOfficer and the Sewer Use Ordinancebefore making any new connections.Some municipalities restrict floordrains from being connected to thesewer system depending on the type ofoperation. Also, you may be requiredby your POTW to connect an oil/waterseparator between the floor drains andthe sewer system. Oil/water separators


Fluorescent Bulbs and OtherHazardous Lamps

should be checked on a monthly basisto make sure they are working properly.This includes cleaning out the sludgeannually, test it for toxicity and thendispose of it properly. If you are aconditionally exempt small quantitygenerator (CESQG), you can transportthis sludge to an approved facility. Thisincludes transporting dried sludge toyour local landfill. Prior approval isneeded. See Section IV for locations ofthe household hazardous wastecollection facilities.

# Make sure they are connected to somekind of holding tank where thewastewater can be pumped out andtreated or disposed properly. Allwastewater should be hauled away by aDEC 6 NYCRR Part 364 permittedwaste transporter to avoid any liability.

POLLUTION PREVENTION TIPSWastewater is generated at vehicle

maintenance shops from washing floors andvehicles. By minimizing the amount ofwastewater that is generated, you can reducethe amount of wastewater and sludge thatmust be managed or discharged. Here aresome tips that could help you minimize yourgeneration of wastewater:

# Use dry floor cleaning methods. Thisincludes sweeping and vacuuming.

# Train employees to use waterefficiently.

# Use only non-toxic soaps to cleanfloors and vehicles instead of hazardousmaterials.

# Prevent drips and spills from reachingthe floor.

# If a small spill does occur, clean itimmediately with shop towels or mops.This was discussed in the shop towelsection. Never clean spills by hosingthem down with water.

# Perform vehicle maintenance work inareas where there are no floor drains. If

floor drains are present, seal them offduring work to prevent spills fromentering the drains.

# Never have floor drains wherehazardous materials are stored.

# If you collect your wastewater in aholding tank, try to reuse it wheneverpossible.

# Your may want to consider buying awater recycling unit in order to treatyour wastewater on site.

# If your wastewater is nonhazardous,you may want to purchase evaporatingequipment to evaporate yourwastewater. It should be noted thatevaporators may require an air permitor registration, and evaporator bottomsmay be a hazardous waste.

# Wash your vehicles at an offsitecommercial car wash.

# Don’t use degreasing solvents to cleanengines. Most engine degreasers arehazardous and should not be dischargedinto a POTW. Even if you usenonhazardous degreasers, the oil andgrease concentration may exceed thelimit allowed by your POTW.

# Brush snow and ice off vehicles beforebringing them into the shop for service.


Currently, most waste fluorescent bulbs(referred to hereafter as “fluorescent lamps”)are hazardous wastes due to their mercurycontent. Other examples of lamps that, whenspent, are commonly classified as hazardouswaste include high-intensity discharge(HID), neon, mercury vapor, high pressuresodium and metal halide lamps. The U.S.Environmental Protection Agency (USEPA)


Gasoline

Lead Acid Batteries

added hazardous waste lamps to theUniversal Waste Rule (64 FR 36465 -36490) in 1999, and DEC adopted theseregulations on March 15, 2002. Handlers ofhazardous waste lamps are able to choosebetween handling their lamps under thetraditional regulatory scheme or as universalwastes. However, once you declare yourlamps universal wastes, you must continueto handle them as universal wastes. Jumping back and forth between thetraditional RCRA approach and theUniversal Waste Rule in order to avoid anyrequirements is prohibited. If a handler ofhazardous waste lamps fails to comply withthe Universal Waste standards, they may beconsidered to be in violation of existinghazardous waste laws and regulations.

Most facilities in the automotiveindustry are considered small quantityhandlers of universal waste defined ashandlers of less than 5,000 kg or 11,000 lbs.of total universal wastes (hazardousbatteries, certain hazardous pesticides,hazardous thermostats, or hazardous lamps,calculated collectively) on site at any time.The requirements for small quantityhandlers of universal waste (includingfluorescent lamps) require that lamps:• be packaged in a way to minimize

breakage,• any broken lamps are immediately

cleaned up,• containers are properly labeled, and• broken bulbs should be managed as

hazardous waste.

More information on handling offluorescent lamps and universal wastes canbe found at our web site at:www.dec.state.ny.us/website/dshm/ hzwstman/bulbs2.htm. You can also contactthe Bureau of Hazardous Waste Regulationat (518) 402-8633.


Waste gasoline is regulated as ahazardous waste if it is sent for disposal. Itis not considered a hazardous waste if it isrecycled or burned as a fuel. However, youcan not mix gasoline with used oil to burn inused oil space heaters. Waste gasolineshould be stored in properly grounded,labeled and closed containers on animpermeable surface with propercontainment. For more information on thehazardous waste regulations, download acopy of the manual, “EnvironmentalCompliance and Pollution Prevention Guidefor Small Quantity Generators” at the DECwebsite:www.dec.state.ny.us/website/ppu/p2pub.htmlor call the Pollution Prevention Unit at

(518) 402-9469.


If your lead acid batteries are recycled,they do not have to be managed ashazardous waste, but are still subject tolimited hazardous waste regulations. If leadacid batteries are not recycled, they must bemanaged under the traditional regulatoryscheme as non-exempt hazardous waste.

POLLUTION PREVENTION TIPSHere are some tips on storing lead acid

batteries:# Indoor storage is recommended for

lead-acid batteries.# Store batteries on an acid-resistant rack

or tub.

http://www.dec.state.ny.us/website/dshm/hzwstman/bulbs2.htm

http://www.dec.state.ny.us/website/ppu/p2pub.html


Painting Operations

# Batteries stored outside should bestored on impermeable surfaces andshould have secondary containment.Also, it is recommended that batteriesbe covered to prevent acid run-off.

# Keep a neutralizing agent such asbaking soda nearby, in case of a leaksor spills. If a spill does occur, the wastemust be treated as a hazardous waste.

# When stacking batteries, make surethey are stored so that any fluid fromleaking batteries will not be released tothe environment.

# Electrolyte fluid in spent batteriescontains a sufficient quantity of lead tomake it a hazardous waste. This fluid ifdischarged onto the ground willfrequently make the soil which absorbsit a hazardous waste.

# Use an authorized recycler.


If you operate a body shop and conductspray painting operations, a hazardous wastedetermination must be made on waste paint,solvents/thinners, paint sludge, primerwaste, and spray booth filters. The paintsand paint sludges may be hazardous if theycontain heavy metals, such as arsenic, leadand chromium. The solvents may becharacteristically hazardous due to theirignitability or they could be a listedhazardous waste. Also, many primers,lacquers, and enamels are flammable.

During spray painting operations,volatile organic compounds (VOCs) andhazardous air pollutants (HAP) are releasedinto the environment. These pollutants areregulated under the Clean Air Act. To learnmore about these requirements, refer to

Section I, under the Air Regulations.

POLLUTION PREVENTION TIPSHere are some tips on ways to minimize

your waste from spray painting operations:# Train employees on paint application

techniques. Proper training in thecorrect use of applying paint can reduceyour waste and VOC emissions.

# Make sure your shop uses high-volume/low-pressure (HVLP) sprayguns. These spray guns have transferefficiencies of about 60 to 80 percent.

# Train employees on the proper cleaningand maintenance of equipment. This isessential in achieving a high qualityfinish, especially in the new spray guns.

# Do all spray painting in an enclosedspray booth equipped with filters.

# When cleaning spray guns withsolvents, use smaller diameter tubing sothat you will use less solvent.

# The solvent that is used to clean sprayguns can be reused to thin paint of thesame color.

# If possible, switch to water-based paintsand primers.

# Switch from lacquer to enamel-basedpaints. Lacquer paints may contain 70to 90 percent solvent by volume, whileenamels contain 55 to 75 percentsolvent by volume.

# Use solvents with low or no VOCcontent.

# Give leftover paints that won’t be usedto customers for touch up.

# Purchase a small solvent distillationunit in order to recycle your paintthinners and solvents.


Parts Cleaning andDegreasing


Spent solvents are the largest hazardouswaste stream created by the automotiveindustry. Spent solvents are dangerous toworkers because they are toxic and theyemit harmful vapors. If your shop still uses aparts washing system that contains ahazardous solvent, you may be generatinglisted hazardous wastes which will haveEPA Hazardous Waste Codes of F001-F005.In addition, many solvents may behazardous because of ignitability which willhave an EPA Hazardous Waste Code ofD001.

When using hazardous solvents in yourparts washing system, you are required tokeep track of the amount of spent solventgenerated each month and dispose of themas hazardous waste. The following are someof the common spent halogenated and non-halogenated solvents used in degreasingoperations that are considered hazardous:

Tetrachloroethylene (Perchloroethylene)Methyl isobutyl ketone (MIBK)Chlorinated fluorocarbonsTrichlorofluoromethaneCarbon tetrachlorideOrtho-dichlorobenzeneMethylene chloride1,1,1-trichloroethaneMethyl ethyl ketone (MEK)MethanolIsobutanolTolueneAcetoneXyleneBenzene

If your shop uses any of the above partswashing solvents or degreasers, or any otherhazardous solvent not listed above, youshould make every effort to replace yourparts washer or degreaser withnonhazardous substitutes as soon aspossible.

TYPES OF PARTS WASHERSThere are many opportunities available

to minimize or eliminate your generation ofhazardous solvents. One of your firstchoices should be to use a nonhazardous orless hazardous parts cleaning system. Hereare some tips you should follow beforepurchasing or leasing your parts washer:# Buy a parts washer with a lid rather

than an open bucket or pan. This willreduce evaporation or spillage of thesolvent.

# Instead of leasing, purchase your ownparts washer. Service agreements tendto change your solvents more often,which generates more waste. Also, ifyou are a conditionally exempt smallquantity generator, you can transportyour spent solvent and sludge to anapproved facility. See Section II formore details.

# Talk to other shops to find out whichsystem works best. This will save youtime and money trying to decide whichsystem is best for your shop.

# When a supplier or vendor lets youdemo a parts washer, make sure youspecify that he takes away the wholeunit, including the spent solvent andany still-usable solvent if you decidenot to buy the unit.

# Buy a parts washer with a drain shelfthat fits inside the basin. This allowssolvent to drain from parts prior toremoving them from the washer.

# Buy a parts washer with a filtering unitthat will extend the life of the solventby filtering out contaminants.Remember, when discarding the filters,


a hazardous waste determination mustbe made prior to disposal.

# Parts washers that are heated seem towork better than unheated units.

The following are some types of partswashers available:

Aqueous CleanersAqueous cleaning refers to the use of water,detergents, acids, and alkaline compoundsrather than organic solvents. Aqueouscleaners are one of the most popular choicesfor degreasing parts at automotive shops andare a good alternative to the petroleum-based and halogenated solvents. Some of thebenefits include:# Less risk of hazardous exposure and

more environmentally friendly.# Not flammable or explosive.# Oils and greases can be removed more

effectively.# Potential savings in disposal costs,

since used aqueous parts cleaning watermay be eligible for discharge into apublic sewer system. Prior approval isneeded. Check with your publiclyowned treatment works (POTW) forrequirements.

Hot Soap WashersHot soap or jet spray washers are like

dishwashers that clean parts. They usedetergent and hot water to remove oil,grease, and dirt. Employees like hot soapwashers because they can clean partsautomatically while they perform otherduties in the shop. Other benefits of hot soapwashers include:# Eliminates employee exposure to

hazardous solvents.# Less employee time spent on parts

washing.# Not flammable or explosive.# Little or no hazardous waste generated.# Potential savings in disposal costs,

since used aqueous parts cleaning watermay be eligible for discharge intopublic sewer system. Prior approval isneeded. Check with your publiclyowned treatment works (POTW) forrequirements.

The sludge from oil, grease, dirt andother contaminants should be cleaned outfrequently. Prior to disposal, you must makea hazardous waste determination on thesludge. Nonhazardous sludge can be hauledby a septic tank company, or if dry, taken toa landfill. If you are a conditionally exemptsmall quantity generator CESQG), driedsludge that is considered hazardous can betaken to a landfill as long as you get priorapproval from the landfill operator. Checkwith your local landfill for requirements.

Semi-Aqueous CleanersThese cleaners are also called: less

toxic solvents, less hazardous solvents, non-halogenated solvents, petroleum-basedsolvents or terpene solvents.

Semi-aqueous cleaners are productsthat can be dissolved in water or applied in aconcentrated form. They are called semi-aqueous because they can be applied eitherway. Terpenes are hydrocarbons derivedfrom wood or citrus fruits, usually orange orlemon peel oils. Even though most of thesemi-aqueous cleaners are not ozonedepleters, they are highly toxic to aquaticlife, some have a high cost and they maystill be hazardous wastes when spent. Ahazardous waste determination should bemade prior to disposal.

Solvent DistillationIf hazardous solvents must be used at

your shop, then you may want to considerpurchasing a solvent distillation unit torecycle your solvents. For example, if yourshop generates five gallons of paint andsolvent waste, you may be able to reclaim


Refrigerants

four and a half gallons of solvent. Thiswould leave you with only one half gallonof sludge that must be disposed of ashazardous waste. This sludge that isgenerated is called “still bottoms.” Solventis reclaimed by heating spent solvent to itsboiling point in a “still” and then cooled,which produces nearly pure liquid solventthat can be reused. Spent solvent need onlybe counted the first time that it is generatedin a calendar month if it is reclaimed andreused on site. If spent solvents are counted,then still bottoms don’t need to be countedfor the purpose of determining generatorcategory, but do need to be managed as ahazardous waste.

POLLUTION PREVENTION TIPSHere are some pollution prevention tips

on managing your degreasing operations:# Wipe off parts with a rag or wire brush

before soaking in parts washer.# Do not clean parts unnecessarily.# If possible, try to maintain two parts

washers so that you can use one for pre-rinsing.

# If your parts washer doesn’t have a dripshelf inside the tub, use a drip tray todrain cleaned parts.

# Turn off solvent stream and cover theunit when not in use. Also, if your unitis equipped with a heating element, turnit off at the end of the day.


By the end of 1995 all manufacturersshould have stopped production of therefrigerant R-12. Federal regulations statethat it is illegal to vent refrigerants to theatmosphere and require that refrigerantrecycling equipment must be used when

servicing vehicle air conditioners. Whenspent refrigerant is recovered, it must beproperly labeled.

Do no vent refrigerants to theatmosphere.

CERTIFICATIONAnyone in New York State who works

on vehicle air conditioning systems must becertified. You can obtain a list of EPAapproved Section 609 certifyingorganizations by calling (800) 296-1996, orby e-mailing:http://www.epa.gov/ozone/title6/609. Also,the New York State Department of MotorVehicles, Division of Vehicle Safety,Technical Training Unit offers a coursecalled, Systems Training and AirConditioning (STAC). That course goesbeyond the certification requirements forservicing, handling, recycling, andretrofitting procedures for motor vehicle airconditioning. STAC provides training indiagnosing and repairing vehicle airconditioning, mechanical, electrical andelectronic systems. For more information onthis and other courses, call the NYS

Department of Motor Vehicles at (518) 474-4279 or fax (518) 473-9903.

POLLUTION PREVENTION TIPSHere are some tips to help you better

manage refrigerants:# Use only approved reclaiming and

recycling units when recharging orremoving refrigerants.

# Remove and recover refrigerants fromsystem before servicing vehicle.

# Avoid mixing R-12 and 134a sincecontaminated refrigerant can’t be putback into the vehicle and must be sentto a refrigerant recycling facility.

http://www.epa.gov/ozone/title6/609


Shop Towels

Used Electronics

# Do not use alternative refrigerantscontaining liquified petroleum (LP).These refrigerants not only causecontamination, but pose a significanthealth risk due to explosions.

# Be sure to use the proper O-rings,lubricants, etc. when retrofittingautomobile air conditioning systems.

# Don’t allow freon to mix with oil priorto reclamation or recycling.

# Keep technician certification andshipment manifests on-site for at leastthree years.

# When retrofitting, relabel and install theproper fittings to prevent accidentalcontamination of the system with otherrefrigerants. The label should belocated under the hood. That identifiesthe type of refrigerant used. Otherwise,a device is available that will identifythe type of refrigerants in a system.

# If you have a crushing operation,refrigerants should be removed prior tocrushing or shredding.


Industrial rags (also known as shoptowels) or soiled clothing, which arecontaminated with listed or characteristichazardous wastes, do not have to bemanaged as hazardous wastes when sent to acommercial, non-commercial laundry, or drycleaner to be cleaned and then returned tothe owner. The following conditions must bemet:# There is no exemption for rags or soiled

clothing contaminated beyondsaturation (containing free liquids). Anyrags or soiled clothing containing freeliquids will be subject to full regulation.

# Rags and soiled clothing must be

managed in accordance with 6 NYCRRPart 372 and Subpart 373-1 until thematerials are sent for laundering andcounted as wastes generated andaccumulated for the purpose ofdetermining generator category. If youare required to submit an annualhazardous waste report to DEC, youmust report all hazardous waste rags onthis report.All rags and soiled clothing that contain

flammable materials must be stored andtransported in fire proof containers.


shop towels:# Send your shop towels to a laundry or

dry cleaning service. You only have tomanage your shop towels in accordancewith the hazardous waste regulationsuntil they leave your shop.

# If your shop is large enough, you mayconsider purchasing a centrifuge tocollect and recycle excess solvent fromyour shop towels. Most laundries willnot accept saturated shop towels.Centrifuges may be costly, which wouldnot make this a cost-effective purchasefor small maintenance shops.

# Store your shop towels in metal safetycans to reduce the risk of fires. If yourshop towels contain solvents, theyshould be stored in a double-bottomdrum to allow the solvent to drip whereit can be collected.


Due to technology’s rapid development,electronic equipment quickly becomes outof date. Owners of computers and electronic


equipment have three disposal options:# Resale, donation or repair of units.# Dismantling and recycling of units.# Disposal of units.

Some items (e.g., computer monitors)typically qualify as hazardous waste underDEC’s hazardous waste requirements.However, such hazardous waste may beexempt from regulation under the scrapmetal exemption, provided that they aremanaged in the specified way.

Scrap Metal ExemptionMost discarded electronics which

would qualify as hazardous waste (e.g.,monitors) are considered to containsufficient quantities of scrap metal parts thatthey can be regarded as scrap metalthemselves, and, thus, would be exemptedfrom regulation as hazardous waste if thefollowing conditions are met:# Prior notification [6 NYCRR

371.1(c)(7)]: If the generator is not aconditionally exempt small quantitygenerator (CESQG), both the generatorand subsequent handlers in therecycling process in New York Stateare required to notify DEC, givingcertain basic information, such as thelocations of generating and receivingfacilities. Although written concurrencefrom DEC is not required, DEC willprovide one upon request (provided theelectronics item, in fact, qualifies forthe exemption).

# Scrap metal must ultimately berecycled. The scrap metal exemptionrequires that scrap metal piecesactually be reclaimed from thehazardous electronics and that they berecycled.

Note that the scrap metal exemptioncannot apply to a part separated from thewhole component unless that separated partindependently contains scrap metal pieces

that will ultimately be reclaimed. Forexample, an all-plastic case that wasseparated from a computer monitor could nolonger qualify for the scrap metalexemption, nor could broken cathode raytube (CRT) glass. Note that an item whichqualifies as hazardous scrap metal is still ahazardous waste, but exempted fromregulation if it will be recycled.

Resale and Repair of UnitsElectronic products that are directly resoldor even donated for continued use are notconsidered to be discarded, and, thus, cannotbe subject to the solid or hazardous wasteregulations (i.e., they are still “products”).

Non-working electronic products that areserviced by repair shops repaired and thenreturned to the user are not considered to bewastes.

If non-working electronic products aredismantled and some individual parts (e.g.,disk drives) are found to be operative,reused or marketed for reuse, such parts areconsidered to be products reclaimed fromwaste. Therefore, they are no longerconsidered to be solid or hazardous waste. Any unusable components removed fromthe products as part of a repair process mustbe managed by the repair shop as “ordinary”solid or hazardous waste, unless the partqualify for the scrap metal exemption.

More information on handling of usedelectronics can be found on the DEC website:www.dec.state.ny.us/website/dshm/hzwstman/electron.htm.

http://www.dec.state.ny.us/website/dshm/hzwstman/electron.htm


Used Fuel Filters

Used Oil

RememberAll retention

tanks for usedoil storage

must beregistered with

DEC.


Metal fuel filters that are drained of allfree liquids and taken to scrap metal yardsfor recycling are exempt from the hazardouswaste regulations. Fuel filters cannot bediscarded in dumpsters or in the trash, evenwhen properly drained since they may beconsidered hazardous due to benzene orlead.


Used oil is not regulated as a hazardouswaste if it is recycled or burned for energyrecovery. This means that your used oil, ifnot mixed or contaminatedwith hazardous waste, can bemanaged under the used oilregulations, 6 NYCRRSubparts 360-14 and 374-2.Used oil includes usedcrankcase oil, metal workingoils, gear oil, transmissionfluid, brake fluid, hydraulicfluid, dielectric fluid(excluding PCBs), and tankbottoms from used oil tanksonly.

If you are disposing of any used oilrather than recycling or burning for energyrecovery (i.e., spills, soil contamination,cleanup), or your used oil is mixed withother wastes, then you must make ahazardous waste determination and complywith any applicable hazardous wasteregulations.

Used Oil StorageUsed oil must be stored in a sturdy,

leakproof drums or tanks in compliance withState or local building and fire codes, andthey must be clearly labeled “USED OIL.”In addition, the label for the tanks mustinclude the capacity of the tank. Underground tanks must be labeled at thefill port. All used oil tanks, regardless ofsize, are subject to Petroleum Bulk Storage(Parts 612 - 614) requirements, includingregistration with the DEC. However,registration fees are required only if thestorage capacity of the used oil tank isgreater than 1,100 gallons, and the used oilis burned on site for heating. See section inthis manual on “Petroleum and ChemicalBulk Storage Regulations” for furtherinformation.

Did You Know?# It takes 42 gallons of crude oil to yield

2.5 quarts of lubricating oil.# When used oil is recycled, it takes

about one gallon to yield 2.5 quarts oflubricating oil.

# Used oil from a single oil change cancontaminate a million gallon watersupply for 10,000 people.

# Used oil is the largest single source ofpollution in our nation’s waterways.

# Used oil can contain toxic substancessuch as arsenic, benzene, cadmium,lead, and zinc.

# There are 1.2 billion gallons of wasteoil generated annually in the UnitedStates.

Transporting Used OilYour shop must contract with a Part

364 Permitted waste hauler to pick up yourused oil for recycling or disposal. However,your shop can transport up to 500 pounds(roughly 55 gallons) of used oil, without aPart 364 permit but only to:


# A facility that is also owned by yourcompany, or;

# A facility permitted by DEC to acceptused oil directly from the generators ofthat oil.

Accepting Used OilNew York State mandates that service

and retail establishments accept up to 5gallons per person per day of used oil at nocharge from “do-it-yourselfer (DIY).” A do-it-yourselfer is an individual who changesthe oil in his or her own personal vehicles.You cannot take used oil from otherbusinesses. A service establishment is abusiness that sells at least 500 gallons peryear of new oil and performs servicing onvehicles. A retail establishment is a businessthat sells at least 1000 gallons of new oil peryear, but doesn’t perform any servicing ofvehicles. Every service establishment andretail establishment must post a sign that isopen to public view, stating: “WE ACCEPTUSED OIL FOR RECYCLING AT NOCHARGE.” The sign may also say that usedoil is only accepted during normal businesshours. Service establishments cannot chargeeither do-it-yourself oil changers, orcustomers that have their oil changed, forthe used oil. Service and retailestablishments may require that the used oilbe brought in rigid, screw top containers;and may refuse to accept used oil from DIYsif the used oil is contaminated through otherthan normal and ordinary use.

Used Oil-Fired Space HeatersShops can burn their own used oil and

used oil from do-it-yourselfers in speciallydesigned used oil-fired space heaters as longas the following requirements are met:# The used oil originates from vehicles

serviced at your facility or by DIY’s.# The space heater is rated at less than 0.5

Million British Thermal Units (BTUs)per hour.

# The space heater is vented to theoutside.

# The used oil has not been mixed withany hazardous waste.

# Comply with the provisions of 6NYCRR Part 225-2.

Many vehicle maintenance shopspurchase used oil-fired space heaters andthen find out that they don’t generateenough used oil to keep the space heateroperating throughout the winter. Althoughit may seem desirable to receive use oil fromother vehicle maintenance shops, both theused oil and air regulations imposesignificant restrictions, such as recordkeeping and analytical testing, on thispractice. If you wish to explore thepossibility of burning used oil from otherthan your own or do-it yourself oil changers,please contact the Bureau of HazardousWaste Reduction at (518) 402-8633, or callthe Regional DEC office listed in SectionIV.

Used Oil FiltersTerne plated oil filters are no longer

manufactured in the U.S. for use in privatevehicles. Terne plated oil filters, whichconsists of an alloy of lead and tin, areconsidered a hazardous waste whendisposed. Typically non-terne plated usedoil filters are not considered a hazardouswaste and can be disposed of as a solidwaste if used oil is removed from the filterby one of the following methods:# Puncturing the filter and hot draining

for at least 12 hours at or near engineoperating temperature.

# Hot draining for at least 12 hours at ornear engine operating temperature andthen crushing the filter.

# Hot draining at or near engine operatingtemperature and dismantling filter.

# Any other equivalent method that willremove used oil.


Waste Tires

If one of the above methods has beenperformed, these used oil filters can bedisposed of as a normal solid waste, subjectto town and county requirements. However,the most environmentally preferred methodof disposal is to recycle these filters. Checkwith the local scrap metal yard for morerecycling information.

Brake FluidsBrake fluids are considered used oil and

can be combined with your used oil as longas they don’t contain any solvents, brakecleaners or carburetor cleaners. Remember,brake fluid contaminated with any of thesematerials could cause your used oil tobecome hazardous. If the shop still usesbrake cleaners in an aerosol can, chances arethey may contain chlorinated solvents whichare a hazardous waste. Therefore, the shopshould consider investing in an aqueousbrake cleaning system which will not onlybe safer for employees, but could save theshop money.


used oil:# Store used oil in tanks or closed

containers labeled “USED OIL.” This isalso a requirement under the used oilregulations.

# Do not mix hazardous waste with usedoil. This may contaminate your used oilwith hazardous waste, and therefore,prohibit you from managing it as usedoil.

# Make sure your used oil storage tanksor drums have proper containment incase there is a leak or spill.

# Inspect your used oil storage tanks ordrums on a regular basis for leaks orspills. This is also a regulatoryrequirement.

# Use large drum funnels or fill tubeswhen filling used oil drums.

# Place drip pans underneath leakingvehicles to collect dripping oil. Don’tforget to pour oil from drip pan into theused oil drum.

# Try to prevent spills when servicingvehicles. If spills do occur, clean up oilspills with rags. After wringing out thesaturated ag into the used oil drum, youcan have the rags laundered. Seesection on Shop Towels forrequirements.

# Send used oil for recycling. AlthoughEPA and DEC allow burning in usedoil-fired space heaters as a matter ofeconomics for small (especially rural)businesses, EPA recognizes inpromulgating this allowance that spaceheaters do pollute.

# Recycle your oil filters through a scrapmetal yard or a used oil filter recycler.The service provided by oil filterrecyclers costs approximately $75.00per drum of uncrushed filters.

# Inspect used oil from do-it-yourselfers.Make sure there are no other wastesmixed in with their used oil. This canbe done based on color and consistency.If you do decide to refuse the used oil,as a public service you should providethe DIY with the phone number of thetown or county recycling coordinator sothat the DIY can contact that office foralternative disposal options; or you canhave them call (800) 462-6553.


It is a violation to store more than 1000tires on your premises at any one timewithout obtaining a DEC permit. Forcounting purposes, tires still mounted on avehicle are not considered waste tires until


Commonly Asked Questions

removed from the vehicle, at which pointthey become part of the tire count. Pleasenote that you must include in your totalcount used tires that are being sold whetherstored inside or outside your shop.

New York State passed tire legislationthat becomes effective September 12, 2003,which requires any person or business inNew York State who sells or installs newtires for use on any vehicle and any personor business who sells new motor vehicles tocharge a $2.50 fee for each tire sold. Thetire dealer will be allowed to retain anallowance of twenty-five cents per tire. Thefee must be remitted with a quarterly reportto the NYS Department of Taxation andFinance (DTF).

Waste tires must be removed from yourfacility for disposal by 1) a permitted Part364 Waste Transporter, or 2) you cantransport up to 500 pounds (about 25 tires)of used tires to an approved DEC facilitywithout obtaining a permit.

Whole waste tires are prohibited frombeing landfilled in New York State.

Go to: www.dec.state.ny.us/website/dshm/redrecy/tirereg.htm for a list ofpermitted waste tire storage facilities in NewYork State.

POLLUTION PREVENTION TIPSMaintaining tires properly can help tire

last longer. This can save money onreplacement costs and reduces the numberof tires requiring disposal. Some tips tomake tires last longer:# Use recommended size tire for the

vehicle.# Inflate tires to the recommended

pressure in the owner’s manual.# Keep tires balanced and rotate every

6,000 - 8,000 miles or as recommendedby the manufacture.

# Start and stop the vehicle slowly anddecelerate before corners.

# Drive the speed limit.

When improperly managed, waste tirepiles pose a threat to public health and theenvironment. In addition to providing abreeding ground for mosquitos, which maycarry disease, they are also a serious firehazard.

Here are some tips to help you managewaste tires:# Store as few tires as possible at your

facility. Make sure your tires are hauledaway on a regular basis.

# Keep tires stored indoors, or keep tirepiles covered in order to prevententrapment of water.

# Make sure your hauler is authorized byDEC to transport waste tires. Ask to seehis license and find out where the tiresare being taken.

Q I just cleaned up an oil spill with speedidry, can I throw this waste in thedumpster?

A Not without a hazardous wastedetermination. Used oil that is notdestined for recycling or burning forenergy recovery must have a hazardouswaste determination done beforedisposing of the waste. Generallyspeaking, if absorbents or speedy dryhave any free liquids they should not goin the dumpster, even if they are not ahazardous waste. Most oil spills can beavoided. Have your employees use carewhen handling containers that have thepotential to spill. Other spilledchemicals may be a hazardous waste aswell. If you are in doubt, check withyour DEC office.

Q I have a waste oil burner that is lessthan a half a million BTUs per hour atmy shop. I burn my used oil and that

http://www.dec.state.ny.us/website/dshm/redrecy/tirereg.htm


which is given to me by do-it-yourselfoil changers. My problem is that I donot have enough used oil to burnthroughout the winter months so I havea couple of small shops bring me theirused oil. Is this legal?

A No. Burning used oil other than yourown or from do-it-yourself oil changersthat bring it to your station is illegalunless you obtain the proper permits.

Q A hauler picks up my antifreeze and hetells me that he takes it to a recyclingfacility. Since my antifreeze is beingrecycled, do I need to make a hazardouswaste determination on this waste?

A Yes. Unless your antifreeze is recycledon site by a totally enclosed system thathooks up to the vehicle’s coolantsystem, and in which no used antifreezeexits the system, you must make ahazardous waste determination on yourwaste antifreeze. Used antifreeze thathas been drained from automobiles thatis still useable, as in the case ofautomobile recyclers, can be resold orgiven away as a useable product anddoes not have to be counted as waste.

Q I just purchased a service station in anarea where there are no public sewers.There is a floor drain in the middle ofmy shop but I am not sure where itempties. The only water that emptiesinto this drain is from the few cars thatare washed, or water from the drippingsnow in the wintertime. Are there anyspecial regulations that I have tocomply with?

A If your discharge from this floor draindoes not end up in a public sewer orsome type of holding tank, then there isa good chance you are in violation ofthe Environmental Conservation Law(ECL) for an illegal discharge to

surface or groundwaters. You shoulddetermine where the floor drainsdischarge by using someenvironmentally safe dye or foodcoloring.

Q I have a 500 gallon underground tankthat I use for storage of my used oil. DoI need to comply with the new EPArequirements to upgrade this tank byDecember 22, 1998 even if I burn myused oil to heat my station?

A Yes. Used oil tanks are not exempt.

Q I store my used oil in a 275 gallon tankbut heard from many people that I don’thave to register these tanks because it isunder 1,100 gallons. Does this tankrequire registration by DEC?

A Yes. All used oil retention tanks, nomatter what size must be registeredwith DEC. Drums and containers,however, do not have to be registered.All drums, containers, and tanks mustbe labeled with the words “USEDOIL”, and tanks must also be labeledwith their capacity.

Q I just purchased a degreasing unit thathas a built in distillation unit thatrecycles the mineral spirits so that theycan be reused over and over. The onlywaste that is generated from this unitare still bottoms that I drain offperiodically. Can I discard these stillbottoms with my used oil?

A Yes, provided that:1. The still bottoms display nohazardous characteristic other thanignitability.

2. If the distillation bottom does exhibitignitability characteristic, the used oil,after being mixed with the distillationbottoms, does not exhibit the


characteristic of ignitability.

3. The distillation bottoms are a usedoil/mineral spirit mixture. If themixture does not exhibit the ignitabilitycharacteristic, it is regulated as a usedoil, and does not require a toxicitycharacteristic leaching procedure(TCLP) test prior to being mixed withthe shop’s used oil.

4. If the still bottoms are an ignitablehazardous waste, they are regulated ashazardous waste until they are mixedwith the used oil. If the vehiclemaintenance shop is not a ConditionallyExempt Small Quantity Generator, thenthe generator would need to place aone-time LDR notification in thegenerator’s files, per 6 NYCRR376.1(g)(1)(vii).

5. Still bottoms that are ignitablehazardous waste are regulated ashazardous waste prior to mixing. Inorder to be exempt from hazardouswaste facility permitting (a long andexpensive process), non-CESQGswould need to meet the treatment-in-containers exemption of 6 NYCRR373-1.1(d)(1)(ix). This would requirethat (a) the oil be added to thehazardous waste container, and (b) thehazardous waste container would haveto be in compliance with the applicablehazardous waste storage requirements.

6. The used oil/still bottoms mixturemust still be recycled as a used oil. Theadditions of the still bottoms cannotcause the oil to be unacceptable to therecycler.


Section III - ENVIRONMENTAL SELF-ASSESSMENT(A quick and easy checklist of pollution prevention measures)

This self-assessment is designed to testa facility’s performance in pollutionprevention, waste reduction and recycling.The following checklist is a guide designedto be used by anyone involved in the day-to-day operations of a vehicle maintenanceshop. This includes facilities such asnew/used car dealerships, service stations,auto body shops, trucking companies,municipal garages, or any organization thatoperates fleets of motor vehicles. Facilitiesare advised to conduct routineself-assessments to identify opportunities toincorporate pollution prevention measuresinto their operations.

You should review each section of theself-assessment with the mechanic ormanager who is most familiar with thatparticular part of the operation. Responses tothe questions should show whetherpotential hazards or polluting activities areoccurring that may be addressed by anoperational change, product substitution orbetter housekeeping.

This self-assessment is only one in aseries of steps that your business should taketo determine its regulatory compliance andto identify suitable methods of wastereduction. The checklist would be mosteffective when used with related tools, suchas workshops and publications. For manysmall facilities, the self-assessment willlikely be as useful as a thermometer wouldbe for a person with a fever: the symptomsmay be measured, but an expert opinion maybe needed to diagnose the problem anddevelop corrective measures.

Progressive facilities will use theenvironmental self-assessment to achievetwo goals: to evaluate current businesspractices and to develop an ongoingprogram in pollution prevention.

Don't be discouraged by the sometimesdifficult process of identifying andaddressing environmental problems. Overthe long haul, the measurable benefits ofconducting and responding to regularenvironmental self-assessments may includereductions in: environmental hazards,exposure to enforcement, fines, insurancerates, waste handling costs and accidents.Benefits may also include an improvedcompliance record, improved worker healthand a better work environment. Intangiblebenefits may include better relations withregulatory agencies, improved employeemorale, favorable publicity and a strongercommunity reputation for integrity.

This environmental self-assessmentshould provide extremely usefulinformation, but there is no guarantee,expressed or implied, that the informationwill identify all possible conditions andopportunities for pollution prevention. Anenvironmental self-assessment can proveworthwhile as a preventive strategy in muchthe same way that an internal financial audithelps your business avoid violations oflocal, state and federal tax laws. It canidentify process changes and housekeepingmeasures that will prevent damage to theenvironment and help your business complywith environmental requirements.

Review each question carefully andcheck the appropriate box. A yes answerindicates that your shop has incorporatedwaste reduction and recycling measures intoits day-to-day activities. A no or can’tdetermine answer indicates that anopportunity to prevent or reduce pollutionmay exist. Take notes on the questions thatreceived a no or can’t determine response.


SELF-ASSESSMENT CHECKLISTS

MATERIALS HANDLING, STORAGE & SPILL PREVENTION

Yes No NotApplicable

Can’tDetermine

Have the employees responsible forpurchasing supplies been trained to manageinventory and identify alternative, less toxicproducts to reduce the amount of hazardouschemicals used in your shop?

“ “ “ “

Do you date all materials and use the first-in,first-out method of inventory control?

“ “ “ “

Do you inspect all shipments of materials attime of delivery and return unacceptable anddamaged materials to the supplier?

“ “ “ “

Have your employees been trained to safelyhandle the types of drums and packagesreceived?

“ “ “ “

Do you purchase bulk liquid products suchas: oil, antifreeze, glass cleaner, windshieldfluid to reduce container waste and eliminatethe use of aerosol containers?

“ “ “ “

Does your shop purchase smaller containersof infrequently used materials?

“ “ “ “

Have your employees been trained on theproper transfer of materials including:pumping, pouring, grounding and bonding?

“ “ “ “

Do you require that employees use funnels totransfer virgin materials and wastes?

“ “ “ “

Do you require employees to return emptycontainers before being issued new supplies?

“ “ “ “

Do you have a designated hazardous wastestorage area?

“ “ “ “

Have your employees been trained in thehazardous waste regulations (e.g., labeling,storage and manifesting requirements) relatedto the job they are doing?

“ “ “ “


Does your shop maintain and make readilyavailable to employees Material Safety DataSheets (MSDS) for all materials used invehicle repair and shop cleanup? (This is anOSHA requirement.)

“ “ “ “

If not stored within the building, does yourshop store all materials and wastes in acovered storage facility?

“ “ “ “

Does your shop store all solvents andautomotive fluids consistent with themanufacturer’s recommendations for storage?

“ “ “ “

Do you return obsolete or out-dated suppliesto the vendor?

“ “ “ “

Does your shop store municipal wastes (e.g.,office and food wastes) separate fromindustrial wastes?

“ “ “ “

Does your shop store all hazardous materialsand empty containers separate fromnonhazardous materials and containers?

“ “ “ “

Does your shop store each of its wastematerials (i.e., oil, antifreeze, cleaningsolvents, and carburetor cleaner) in separatecontainers?

“ “ “ “

Do the virgin/waste materials storage areashave a berm and sump drain to contain spillsand leaks?

“ “ “ “

If your storage area does not have a berm, doyou use a self-contained spills managementmethod such as pallets that have built-in spillcontainment?

“ “ “ “

Have you sealed all floor drains in areas thatare used for the storage of hazardousmaterials?

“ “ “ “

Have your employees been trained to safelyhandle spills?

“ “ “ “


Have your employees been trained in spillreporting requirements? (See Spill Response: Basic Procedures and Requirements forResponsible Parties in New York State,January 1991 for information regarding thesteps to take in the event of a spill ofpetroleum or hazardous substances.)

“ “ “ “


PARTS CLEANING & DEGREASING


Can’tDetermine

Have you explored the use of citrus-based,detergent-based or a hot soap parts cleaningsystem to replace a solvent or caustic-basedsystem?

“ “ “ “

Has your shop established guidelines as towhen parts should be cleaned using solvents?

“ “ “ “

Are your employees encouraged/required tobrush dirty parts to remove caked-on solidsand to improve cleaning efficiency?

“ “ “ “

Do the solvents you use for cleaning have aflash point of more than 140 degrees F?

“ “ “ “

Do you use a self-contained, recirculatingsolvent sink for parts cleaning?

“ “ “ “

Have you installed drip trays or racks on yourparts washers?

“ “ “ “

Do you require solvent cleaning tanks to becovered when not in use?

“ “ “ “

Does your shop use parts washers that have asolvent filtering feature to extend solventlife?

“ “ “ “

If your shop has two (or more) parts washers,do you alternate servicing schedules and usethe washer(s) with contaminated solvent fordirty parts only and use the washer with cleansolvent for final cleaning?

“ “ “ “

Does your shop collect and recycle wastecleaning solvents?

“ “ “ “

If your shop uses halogenated solvents, haveyou considered the purchase of an on-sitesolvent distillation system as a way to recyclethe waste solvent?

“ “ “ “



Can’tDetermine

Does your shop use a zero-discharge partswashers which incorporates a built-indistillation unit?

“ “ “ “

Have you explored the possibility of usingone multi-purpose solvent rather than severaldifferent solvents to increase the potential forreuse and recycling?

“ “ “ “

If you use nonhazardous parts washers haveyou taken steps to prevent contamination andhave you tested the liquid, sludge and filterfor hazardous characteristics?

“ “ “ “

P2 PaysThe U. S. Postal Service operates seven vehicle maintenance facilities in upstate NewYork that maintain a fleet of 4,210 vehicles. Through a pollution prevention program thathas included:

C the replacement of solvent based parts cleaners with non-hazardousaqueous parts washing systems;

C switching from using chlorinated solvents and other hazardouschemicals to aqueous cleaners for cleaning brakes; and

C installing on-site closed loop antifreeze recycling units

the Postal Service has reduced its generation of hazardous waste by 90 percent anddecreased its total waste management cost per vehicle serviced from $7.39 to $4.52. Thishas resulted in an annual savings of $21,364.00.


MAINTENANCE AND REPAIR ACTIVITIES


Can’tDetermine

Oil

Do you require employees to use drip traysto prevent fluids from automobiles, parts andfunnels from leaking onto the shop floor?

“ “ “ “

Do you require that employees place dirtyparts in drip trays instead of directly on theshop floor?

“ “ “ “

Do you require oil filters to hot drain for aminimum of 12 hours to collect all residualoil prior to disposal or recycling?

“ “ “ “

Are your oil filters crushed and sent forrecycling as scrap metal?

“ “ “ “

Does your shop use large drum funnels whentransferring collected oil to waste oil storagecontainers?

“ “ “ “

Does your shop store used oil in closedcontainers that are clearly marked “UsedOil”?

“ “ “ “

Does your shop contract with a permittedwaste transporter for off site recycling ofused oil?

“ “ “ “

Do you conduct a regular inspection ofwaste oil tanks for leaks and spills?

“ “ “ “

Does your shop dispose of transmissionfluid, non-PCB dielectric fluid, gear oil,hydraulic fluid and cutting oil with its wasteoil?

“ “ “ “



Can’tDetermine

Antifreeze

Does your shop drain and save for reuse inthe vehicle that is being repaired, goodantifreeze that has been removed to serviceparts such as the radiator, thermostat orwater pump?

“ “ “ “

Does your shop recycle spent antifreeze onsite?

“ “ “ “

Does your shop contract with a permittedwaste transporter for off-site recycling ofspent antifreeze?

“ “ “ “

Batteries

Do you store waste lead acid batteries onpallets in a well ventilated area that has animpermeable floor and a berm to allow forspill collection and containment or if thearea does not have a berm, are the batteriesstored on pallets that have built-in spillcontainment or in closed containers? (Ifwooden pallets are used they can easilybecome contaminated with sulfuric acid andbecome a hazardous waste.)

“ “ “ “

Does your shop recycle its lead acidbatteries?

“ “ “ “

Does your shop maintain a one for onebattery exchange program with yoursupplier?

“ “ “ “

Do you keep a neutralizing agent near thebattery storage area in case of leaks orspills?

“ “ “ “

Refrigerants

Does your shop use CFC refrigerantrecycling or recovery equipment operated bycertified technicians when servicingautomobile air conditioning systems?

“ “ “ “



Can’tDetermine

Does your shop evacuate/recover refrigerantbefore servicing any system?

“ “ “ “

Are all of your employees aware that it isillegal to vent R-12, R-134a or any otherrefrigerant to the atmosphere?

“ “ “ “

Does your shop have a policy ofencouraging customers to locate and repairleaks rather than just “topping off” a systemthat is not cooling adequately?

“ “ “ “

Does your shop maintain appropriate recordson the purchase/use of refrigerants andnotify EPA of equipment and techniciancertification?

“ “ “ “

Radiators

Has your shop eliminated the use ofaromatic and chlorinated hydrocarbonsolvents in the repair of radiators?

“ “ “ “

Is the boil tank placed in a secure area withsecondary containment?

“ “ “ “

Do you collect the drainage from the boiltank in holding tanks/drums and dispose of itas a hazardous waste if testing shows that itis a hazardous waste?

“ “ “ “

Has your shop eliminated the use of leadsolder or use solder with the lowest leadcontent in the repair of radiators?

“ “ “ “

Miscellaneous

Do you drain fuel filters of all free liquidsand send them for recycling as scrap metal?

“ “ “ “

Does your shop use an aqueous brake washas an alternative to a solvent wash andaerosol solvents?

“ “ “ “



Can’tDetermine

Does your shop require that employees keepcontainers of solvents, paint thinners andother volatile liquids closed when not in use?

“ “ “ “

Do you require that all containers be clearlylabeled with their contents?

“ “ “ “


BODY REPAIR AND PAINTING


Can’tDetermine

Do you require that employees estimatesurface area to be repaired before mixingbody filler and paint?

“ “ “ “

Is all painting done in an enclosed spraybooth?

“ “ “ “

Does your shop use reusable metal orStyrofoam paint filters?

“ “ “ “

Do you require that the spray guns becalibrated on a regular basis?

“ “ “ “

Has your shop investigated the use of paintswith lower volatility, lower metalconcentrations and a higher solids content?

“ “ “ “

Does your shop use more efficient painttransfer equipment such as high-volume/low-pressure or low-volume/low-pressurespray guns?

“ “ “ “

Has your shop reduced the size of the paintcups on the spray guns to reduce thepotential for waste?

“ “ “ “

Does your shop use more efficient paintingprocesses such as electrostatic painting orpowder coating?

“ “ “ “

Are your employees required to scrape outexcess paint before rinsing?

“ “ “ “

Does your shop have fully enclosed stationsfor cleaning spray guns?

“ “ “ “

Do you use small diameter hoses whendispensing solvents for cleaning spray guns?

“ “ “ “

Has your shop calculated its VOC emissionsfrom solvents?

“ “ “ “



Can’tDetermine

Does your shop have a policy of using wastepaint as a rough coat for other applicationssuch as undercoating?

“ “ “ “

Does your shop have a policy of makingleftover paint (enamel or lacquer only)available to the customer for touch-up use?

“ “ “ “

Does your shop segregate waste paint andpaint sludge from waste thinner?

“ “ “ “

Does your shop have a policy of reusingclean-up solvent in the next compatiblebatch of paint?

“ “ “ “

Does your shop have a solvent distillationsystem to recycle its waste solvent?

“ “ “ “

P2 PaysThe City of White Plains operates a 400-vehicle fleet comprising fire apparatus, policecars, motorcycles, bulldozers, dump trucks and street sweepers. The city decided that byincreasing the overall fuel efficiency of the general fleet it could dramatically reduce thegeneration of air pollutants. White Plains accomplished this through a program thatemploys the use of lightweight, yet durable truck body materials (aluminum, fiberglass orgraphite fiber), special order engines and low friction axles.

Replacing steel truck cabs, dump and utility bodies, suspensions, wheels and air/fuel tankswith aluminum and or fiberglass has reduced vehicle weights, increased legal payloadcapacity and significantly increased fuel economy. Significant savings have also beenrealized from decreased maintenance costs because tire and brake lining life wereincreased and because aluminum and fiberglass parts require less frequent maintenanceand have a longer life span than comparable steel parts.


SHOP CLEANUP


Can’tDetermine

Is all vehicle maintenance performed inareas with no floor drains or where the floordrains have been sealed?

“ “ “ “

If your shop has floor drains are theyconnected to an oil/water separator thatdischarges to a municipal sewer system or aholding tank? (Discharge directly togroundwater, surface water or land isillegal.)

“ “ “ “

Are discharges into the sanitary sewerswithin limits established by the sewagetreatment plant?

“ “ “ “

Are the concrete floors of the service bayssealed with an impervious material tofacilitate cleanup without using solvents?

“ “ “ “

Does your shop have an award program forworkers who keep their work bays clean?

“ “ “ “

Does your shop use brooms or other drymethods as the primary means of cleaningthe shop floors?

“ “ “ “

If you clean the shop floors using water, doyou use a biodegradable detergent?

“ “ “ “

Are your employees required to wipe upsmall spills as soon as they occur?

“ “ “ “

Does your shop use dry methods for clean-up of small spills?

“ “ “ “

Are your employees required to pick upabsorbent material as soon as possible afterthe leak or spill has occurred?

“ “ “ “



Can’tDetermine

Do you store your shop towels in a closed,metal safety container?

“ “ “ “

Does your shop send its dirty shop towels toa commercial laundry service for cleaning?

“ “ “ “

Does your shop periodically clean its floordrains and test the sludge to determine if it isa hazardous waste prior to disposal?

“ “ “ “

Does your shop use a commercial car washfor vehicle washing?

“ “ “ “

Are washwaters from vehicle washingdischarged to a dedicated grit separator anddischarged to the municipal sanitary sewer?

“ “ “ “

If your vehicle storage area is uncovereddoes it have a separate storm watercollection system with a grit separator thatdischarges to the municipal sanitary sewer orto a holding tank?

“ “ “ “

Is your shop’s oil/water separator servicedon a regular basis?

“ “ “ “


NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION625 Broadway, Albany, NY 12233

Section IV - Resource GuideThe following organizations provide technical assistance, publish information, conduct or

speak at workshops and conferences, and provide telephone, written and on-site information andassistance to generators on pollution prevention and better management of air, water, solid andhazardous waste issues.

Division of Environmental Permits (DEP)(518) 402-9167Pollution Prevention Unit (PPU)(518) 402-9469This Unit is responsible for the developmentof outreach and compliance assistanceprograms and offers workshops/training,and publications.

Division of Solid & Hazardous MaterialsBureau of Hazardous Waste Management(518) 402-8633Responsible for making hazardous wastedeterminations, reviewing hazardous wastereduction plans, hazardous wastepermitting, and used oil.

Bureau of Solid Waste Reduction &Recycling(518) 402-8678Responsible for the the waste transporterprogram, the waste tire program, thebeneficial use program, compostingprograms, and other solid waste recyclingand waste reduction issues.

Division of Air ResourcesBureau of Stationary Sources(518) 402-8403Responsible for source review, permitting,MACT, NESHAP implementation, and airtoxics assessments.

Division of WaterBureau of Water Permits(518) 402-8111Responsible for managing the StatePollutant Discharge Elimination System(SPDES) permits, the water resourcesprograms, and the municipal water supplypermits.

Division of Environmental RemediationPetroleum and Chemical Bulk Storage(518) 402-9549Responsible for the registration ofabove/underground tanks, conductingworkshops and training, and developingpublications for the petroleum and chemicalbulk storage program.

Spill Response Hotline(800) 457-7362To report releases of petroleum products orhazardous substances to air, land or water.Regulations require reporting within 2hours if certain conditions are not met. Also,the National Response Center should benotified.

Petroleum Bulk Storage Hotline(518) 402-9549Provides technical assistance on chemicaland petroleum above/underground storagetanks.


NYSDEC Regional Offices

REGION 1Nassau & Suffolk CountiesBuilding 40 SUNY at Stony BrookStony Brook, NY 11794(631) 444-0230

REGION 2 Bronx, Kings, New York, Queens andRichmond Counties1 Hunters Point PlazaLong Island City, NY 11101(718) 482-4900

REGION 3Dutchess, Orange, Putnam, Rockland,Sullivan, Ulster & Westchester Counties21 South Putt Corners RoadNew Paltz, NY 12561-1696(845) 256-3054

REGION 4Albany, Columbia, Delaware, Greene,Montgomery, Otsego, Rensselaer,Schenectady & Schoharie Counties1150 North Westcott RoadSchenectady, NY 12306-2014(518) 357-2234

REGION 5Clinton, Essex, Franklin, Fulton, Hamilton,Saratoga, Warren & Washington CountiesRoute 86Ray Brook, NY 12977(518) 897-1242

REGION 6Herkimer, Jefferson, Lewis, Oneida & St.Lawrence Counties317 Washington StreetWatertown, NY 13601(315) 785-2513

REGION 7Broome, Cayuga, Chenango, Cortland,Madison, Onondaga, Oswego, Tioga &Tompkins Counties615 Erie Boulevard WestSyracuse, NY 13204-2400(315) 426-7400

REGION 8Chemung, Genesee, Livingston, Monroe,Ontario, Orleans, Schuyler, Seneca,Steuben, Wayne & Yates Counties6274 East Avon-Lima RoadAvon, NY 14414(585) 226-2466

REGION 9Allegany, Cattaraugus, Chautauqua, Erie,Niagara & Wyoming Counties270 Michigan AvenueBuffalo, NY 14203-2999(716) 851-7220


State and Local Assistance

Suffolk County Water Authority4060 Sunrise HighwayOakdale, New York 11769(631) 589-5200Provides confidential assistance tobusinesses in Suffolk County.

Erie County Office of PollutionPrevention95 Franklin Street, Room 1077Buffalo, NY 14202-3973(716) 858-7674Provides confidential assistance tobusinesses and the private sector in ErieCounty.

NYC Department of EnvironmentalProtection, Environmental EconomicDevelopment Assistance Unit59-17 Junction BoulevardCorona, NY 11368(718) 595-4359Provides assistance to small businesses inNew York City.

The Center for Business and IndustrySUNY at Fredonia, Lagrasso HallFredonia, NY 14063(716) 673-3177Provides assistance for businesses locatedin Chautauqua, Cattaraugus, and Alleganycounties.

Broome County Division of Solid WasteManagementEdwin Crawford County Office Building44 Hawley StreetBinghamton, NY 13902(607) 778-2250Provides assistance to residents andbusinesses in Broome County.

NYS Environmental FacilitiesCorporationSmall Business Assistance Corporation 625 BroadwayAlbany, NY 12205(800) 780-7227(518) 402-7462Provides confidential assistance to smallbusinesses in New York State on issuesregarding the Clean Air Act.

Clean Air Act Small BusinessOmbudsmanEmpire State DevelopmentSmall Business Division633 3rd Avenue, 32nd FloorNew York, NY 10017(800) STATENY or (800) 782-8369Provides confidential assistance to smallbusinesses in New York State on issuesregarding the Clean Air Act.

Your county or town Department of Health,Public Works Office, or EnvironmentalManagement Council may also be able toprovide you with information on localregulations and issues.


US Environmental Protection Agency

Small Business Ombudsman Hotline401 M Street SWWashington, DC 20460Phone: (800) 368-5888Fax: (703) 305-6462Helps private citizens, small businesses, andsmaller communities with questions on allprogram aspects with EPA.

RCRA/Superfund/EPCRA Hotline401 M Street SWWashington, D.C. 20460(800) 424-9346(202) 557-1938Answer questions on matters related to solidwaste, hazardous waste, or undergroundstorage tanks. Also, can be used to orderEPA publications.

EPA Region II OfficeCompliance Assistance & Support Branch290 Broadway, 21st FloorNew York, NY 10007-1866(212) 637-3268Provides compliance and pollutionprevention assistance to EPA Region 2 areabusinesses.

EPA Region II OfficeDivision of Enforcement and ComplianceAssistance - RCRA Compliance Branch290 Broadway, 22nd FloorNew York, NY 10007-1866Phone: (212) 637-4145Fax: (212) 637-4949In addition to conducting RCRA inspectionson small businesses, this office providestechnical assistance on RCRA relatedissues.

EPA HeadquartersOffice of Compliance (2224A)401 M St., SWWashington, DC 20460Phone: (202) 260-1821Fax: (202) 564-0009Regulatory, technical, compliance andpollution prevention assistance.

Department of Transportation HotlineOffice of Hazardous Materials StandardsResearch & Special ProgramsAdministration400 7th Street, SWWashington, DC 20590-0001Phone: (202) 366-4488Fax: 366-3753Technical assistance on matters related toDOT’s hazardous materials transportationregulations.

Pollution Protection InformationClearinghouse (PPIC)PPIC-EPA401 Main Street, SW (3403)Washington, DC 20460Phone: (202) 260-1023Fax: (202) 260-0178E-mail: [email protected] a library and an electronic bulletinboard dedicated to information on pollutionprevention.

National Response Center(800) 424-8802In Washington, D.C. (202) 426-2675To report oil and chemical spills to theFederal Government. This hotline is mannedby the U.S. Coast Guard.


New York State Permitted Household Hazardous Waste Facilities

If you are a Conditionally Exempt Small Quantity Generator and located in one of the followingcounties, you can call the number listed to make arrangements to bring your hazardous waste fordisposal. Appointments are usually required. Some counties are opening their facilities toneighboring counties. If your shop is not located in any of these counties, you may want to callthe closest household hazardous waste collection facility for more details.

Municipally-owned facilities

Broome CountyP.O. Box 1766, Government CenterBinghamton, NY 13902Mr. Brian R. Donnelly (607) 778-6432For Appointment (607) 763-4449Facility location: Broome Co. LandfillMaine, NY

Monroe CountyCity Place50 West Main Street, Suite 7100Rochester, NY 14614Mr. Harry Reiter (716) 760-7610Facility Location: 444 East Henrietta Road

Oneida-Herkimer SW Authority1600 Genesee StreetUtica, NY 13502Mr. William Rabbia (315) 733-1224Facility Location: 1600 Genesee StreetUtica, NY

Rockland Co. SW Management Authority99 Torne Valley RoadHillburn, NY 10931Mr. Ronald C. Delo (845) 753-2200Facility Location: Fireman’s Memorial Dr.Pomona, NY

Schenectady CountyPlanning Department107 Nott Terrace, Suite 303Schenectady, NY 12308-3170

Mr. Jeff Edwards (518) 386-2225For Appointment: 1(800) 494-2273Facility Location: County Farm, Scotia, NY

Tompkins County125 East Court StreetIthaca, NY 14850Mr. Ken Thompson (607) 273-4496Facility Location: 122 Commercial AveIthaca, NY

Town of Brookhaven3233 Route 112Medford, NY 11763Mr. Don Nohs (631) 451-6222Facility Location: Horseblock RoadYaphank, NY

Town of Huntington641 New York AveHuntington, NY 11743Mr. Brian Tuohey (631) 427 6377Facility Location: 641 New York AveHuntington, NY

Town of Tonawanda450 Woodward AveKenmore, NY 14217Mr. John Hedges (716) 875-8822Facility Location: Town Highway GarageNote: Only accepts used oil, antifreeze andlatex paint.


Resources on the Internet

Privately-owned facility

Environmental Products & Services, Inc.532 State Fair Blvd.Syracuse, NY 13204Mr. David Ritter (315) 476-4410 ext. 213Facility Location: State Fair Blvd.

Organization Internet Address

Car Care Council http://www.carcarecouncil.org

Coordinating Committee for Automotive Repair- GreenLink

http://www.ccar-greenlink.org

National Pollution Prevention Roundtable http://es.epa.gov/nppr/

Tellus Institute http://www.tellus.org

Waste Reduction Resource Center http://www.owr.ehnr.state.nc.us/wrrc1.html

NEW YORK STATE Empire State Development Services to Business NYS Department of Environmental Conservation NYS Environmental Facilities Corporation

http://www.empire.state.ny.us/service.html

http://www.dec.state.ny.us

http://www.nysefc.org

U.S. ENVIRONMENTAL PROTECTIONAGENCY Common Sense Initiative Design for the Environment Enviro$en$e Office of Mobile Sources Office of Underground Storage Tanks Small Business Assistance Program Technology Transfer Network

http://www.epa.gov/commonsensehttp://earth2.epa.gov/dforehttp://epa.gov/envirosense/nppr/index.htmlhttp://www.epa.gov/omswwwhttp://www.epa.gov/swerust1/http://www.epa.gov/tnn/sbaphttp://www.epa.gov/tnn

U.S. DEPARTMENT OF ENERGY Pollution Prevention Information Clearinghouse

http://epic.er.doe.gov/epic

PACIFIC NORTHWEST LABORATORIES Green Guide Pollution Prevention Resource Center

http://bbs.pnl.gov:2080/esp/greenguide/http://pprc.pnl.gov/pprc/

http://www.carcarecouncil.org

http://www.ccar-greenlink.org

http://es.epa.gov/nppr/

http://www.tellus.org

http://wrrc.p2pays.org/

http://www.empire.state.ny.us

http://www.dec.state.ny.us

http://www.nysefc.org

http://www.epa.gov/ORD/NRMRL/std/mtb/csi.htm

http://www.epa.gov/opptintr/dfe/projects/index.htm

http://earth2.epa.gov/dfore

http://www.epa.gov/omswww

http://www.epa.gov/swerust1/

http://www.epa.gov/ttn/sbap/

http://www.epa.gov/ttn

http://epic.er.doe.gov/epic

http://www.pnl.gov/esp/greenguide/

http://www.pnl.gov/p2/related.stm


References

Here are some other publications for the automotive industry that you will find useful.

1. Environmental Protection Agency, Profile of the Motor Vehicle Assembly Industry,September 1995, EPA 310-R-95-009.

2. Environmental Protection Agency, Facility Pollution Prevention Guide, May 1992, EPA600-R-92-088.

3. Environmental Protection Agency, Guide to Cleaner Technologies, Alternatives toChlorinated Solvents for Cleaning and Degreasing, February 1994, EPA/625/R-93/016.

4. Environmental Protection Agency, Guides to Pollution Prevention: The AutomotiveRefinishing Industry, October 1991, EPA/625/7-91/016.

5. New York State Department of Environmental Conservation, Environmental Complianceand Pollution Prevention for Small Quantity Generators, March 2003.

6. New York State Department of Environmental Conservation/Empire State Development,The Environmental Self-Audit For Small Businesses, January 1994.

7. Environmental Facilities Corporation, Surface Coaters, An Overview of PollutionPrevention, Rules, and Regulations, January 1997.

8. University of Norther Iowa, Iowa Waste Reduction Center, Vehicle Maintenance PollutionPrevention, 1995.

9. Oregon Department of Environmental Quality, Keep Your Shop In Tune, A BestManagement Practice Guide for Automotive Industries.

10. New Hampshire Department of Environmental Services, Automotive Repair andRefinishing Environmental Compliance Manual, Fall 1996.

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