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**About this guide:**

The Maryland Department of the Environment (MDE) recognizes that there
are many environmental requirements that both automotive mechanical
repair facilities and body shops face. This workbook provides the
information needed to help you understand and comply with state and
federal environmental regulations. As the facility owner or their
authorized representative, you have a responsibility to manage the
facility in a safe and environmentally sound manner. This means that
state and federal requirements should be met. MDE also knows that the
issues are different for the different types of businesses. To make this
workbook more useful for you, it is organized into two books: one for
mechanical repair and the other for body repair.

In addition to the workbook, MDE is also providing a self-audit
compliance assistance tool for MD facilities. This tool, called a
self-certification, may be used by the facility managers and/or owners
to perform a self-audit. Completion of the self-certification form is
VOLUNTARY. It is NOT required. The form provides most of the questions
that an inspector would ask while visiting your facility. More
importantly, the self-certification tool also provides the answers that
they would expect to find if the shop were in compliance and/or
utilizing best practices for auto shops in Maryland. The questions are
divided into certain types of activities. Not all of these activities
will apply to all shops. There is an applicability question at the
beginning of each section. If that section does not apply to your
facility, you may answer that applicability question and skip to the
next section as directed. If you did not receive a copy of the
self-certification form with this workbook, it is available from MDE by
calling the Environmental Permits Service Center at 410-537-3772 or
1-800-633-6101 extension 3772.

## Which book do I use?

Use the **Mechanical Repair book** if your facility engages in any of
the following:

1.  Tires (used tires/changing tires)

2.  Oil (changing oil)

3.  Batteries (taking out old batteries)

4.  Hazardous wastes

5.  Vehicle wash water

Use the **Auto Body book** if your facility engages in any of the
following:

1.  Painting

2.  Hazardous wastes

3.  Vehicle wash water

If your business does both mechanical repair and auto body types of work
you need to use both books. For example, if you are a have a body shop,
but you also engage in tire repair you will need to refer to the used
tire portion of the mechanical repair facility section.

##  MECHANICAL REPAIR 

1.  **Air Issues** 5

    1.  How to Handle Degreasing and Parts Cleaners 5

    2.  Repairing Air Conditioning Units 6

    3.  Emissions Repair 6

2.  **Waste Issues** 6

    1.  What are Hazardous Wastes? 7

    2.  How can I tell if my wastes are hazardous? 7

    3.  I'm a hazardous waste generator-what do I need to do? 10

    4.  Hazardous Waste Storage -- Container Management 11

    5.  Hazardous Waste Storage- Tanks 14

    6.  Hazardous Waste Storage- Containment 14

    7.  Container Labeling Requirements 15

    8.  Offering Hazardous Waste for Shipment Licensed Transporters, EPA
        ID Numbers and Waste Manifests 16

    9.  How to Handle Degreasing/Parts Cleaners 18

    10. What to do with Used Radiator Coolant/Antifreeze 19

    11. What to do with excess gasoline 19

    12. How to Handle Lubricating Oil 19

    13. What to do with motor oil filters 20

    14. How to handle used batteries 21

    15. Underground Storage Tanks 21

    16. Above Ground Storage Tanks 23

    17. How to store and dispose of scrap tires 24

3.  **Water Issues** 25

    1.  Floor Drains 26

    2.  Vehicle Wash Water 26

4.  **Best Practices** 26

    1.  Used Radiator Coolant/Antifreeze 27

    2.  Aerosol Sprays 27

    3.  Aqueous Parts Washers 28

    4.  Running a Dry Shop 29

    5.  Good Storage Practices 30

    6.  Environmental Management Systems 30

# 

# MECHANICAL REPAIR

# Section 1.0-Air Issues

When we think of air pollution, we usually think of smoke billowing from
factory smokestacks. However, air pollution can be generated from many
types of industrial processes, even without the visual presence of
billowing smoke. Car repair shops can thus impact air quality. Although
such pollution does not generally take the form of billowing smoke,
these emissions are nonetheless detrimental to the environment.

Air pollution generated by mechanical repair shops generally comes from
the solvents found in parts washers, various cleaners, and degreasers.
These solvents can contain volatile organic compounds (VOC) and other
air pollutants.

## 

## 

## 

## 

## 

## 1.1 How to Handle Degreasing and Parts Cleaners

**MDE Air Regulations For Solvent Degreasers (parts washers):**

> **1.** You must use a solvent that has a vapor pressure of 1mm of
> mercury (0.019 psia) or lower. The vapor pressure can be found on the
> MSDS for a material.
>
> **2.** You must have written good operating practices for your
> degreaser that includes the use of covers to reduce evaporation and
> reducing the time and frequency of parts cleaning. Your good operating
> practices must be displayed where the person using the parts washer
> can read it.
>
> **3.** You must keep monthly solvent usage records.
>
> **4.** You cannot use a **halogenated volatile organic compound
> (HVOC)** solvent such as ***tetrachloroethylene*** in a liquid
> degreaser is prohibited.

## 1.2 Repairing Air Conditioning Units

The **1990 Clean Air Act** requires auto repair shops to recapture and
recycle chlorofluorocarbons (CFCs), either on or off-site.

> **1.** You **must be** certified to deal with air conditioners. This
> certification is available from the US EPA. Call **(800) 296-1996**
> for more information.
>
> **2.** You **must** use Environmental Protection Agency (EPA) approved
> CFC recovery and recycling equipment.

a.  Information on EPA approved **CFC recovery and recycling equipment**
    can be obtained by calling the **EPA** at **(800) 296-1996**.

> **3.** You **should** encourage customers to have air conditioner
> leaks repaired to prevent CFCs from leaking into the environment.

### 1.3 Emissions Repair

> **1.** You and your shop **must** be certified by the Maryland
> Department of the Environment (MDE) to work on vehicle emission
> equipment.
>
> **2.** To obtain more information on emission equipment certification,
> contact **MDE Mobile Sources Control Program** at **(410) 537-3270**.

# Section 2.0-Waste Issues

As a business owner, you must manage your wastes in a safe and
environmentally responsible manner. Federal and State regulations place
the burden on you to properly dispose of the waste. The handling of many
of the wastes that repair shops generate (e.g. removed car parts, scrap
tires, hazardous wastes, etc.) is regulated by the Maryland Department
of the Environment (MDE). By choosing products that are less hazardous,
and minimizing the amount of waste that you generate, you reduce your
liability. This section describes the definition, rules, and regulations
for both hazardous and non-hazardous wastes.

## 2.1 What Are Hazardous Wastes?

Hazardous Wastes are substances that contribute to an increase in
illness and mortality, and threaten the environment if not managed
correctly. Hazardous wastes typically generated by auto repair shops can
contain elevated levels of heavy metals such as cadmium, chromium,
mercury, and lead. Hazardous wastes may also include spent solvents from
degreasing and other shop clean up materials. If these wastes are
allowed to contaminate absorbents, sanding dust, rags, oils or other
materials, these contaminated materials also become hazardous wastes. A
certified hauler must be used to ship hazardous wastes off-site for
treatment, storage, disposal, or recycling. The hauler will then deliver
the waste to the appropriate facility.

**2.2 How can I tell if my wastes are hazardous?**

Wastes are considered hazardous either because they are listed in the
regulations as hazardous by the chemical or process that generates them
or because they have one of the characteristics that is considered
hazardous. You are responsible for determining if the waste you generate
is hazardous waste. You can apply your knowledge of the materials you
use to make this determination.

If you think a waste might be hazardous but you\'re not sure, you can
either assume it is hazardous and handle it that way or have it tested
to determine if it has any hazardous characteristics. Local laboratories
and even some hazardous waste disposal companies can test your waste for
the hazardous characteristics using approved methods. The test result
for the waste stream will apply as long as you continue to use the same
chemicals and process. Save the test results because a hazardous waste
inspector may want to know how you determined your waste was hazardous.
These steps are detailed below. Your vendors may also be helpful in
providing information about their products.

**1.** At an auto repair facility, the following **commonly generated
waste**

**materials** **should be** investigated for characterization as a
**hazardous waste**:

a.  Solvents such as parts cleaners

b.  Sludge or "bottoms" from a solvent recycling unit (still)

c.  Automotive fluids,

**2.** Determine if the waste is as a hazardous waste by calling the
**Maryland Department of the** **Environment (MDE)** at **(410)
537-3344**. U.S. Environmental Protection Agency (EPA) also lists
hazardous wastes in the Code of Federal Regulations, 40 CFR 261 Subpart
D.

**3. If the waste is not listed in COMAR or CFR:** Determine if the
waste exhibits one of the four characteristics of hazardous wastes:
ignitability, corrosivity, reactivity, or toxicity\--**detailed in 40
CFR 261 Subpart C**.

**a.** Using knowledge of the characteristics of the waste

-   Examples of knowledge that may apply to your hazardous waste
    determination include material safety data sheets (MSDS), product
    labels, or other information from the manufacturer or trade
    associations. The MSDS for a material is supplied by your jobber or
    vendor, and provides information on the chemical and physical
    properties of the material, and methods for proper handling,
    storage, and disposal.

OR

> **b.** Testing the waste

-   **Ignitability:** Ignitable wastes create fires under certain
    conditions or are spontaneously combustible, and have a flash point
    less than 60 °C (140 °F). Examples include waste oils from oil
    replacement; spent solvents from paint removal, car washing, and
    degreasing; and methanol used for paint removal. The waste code for
    these materials is D001

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-   **Corrosivity:** Corrosive wastes are acids or bases that are
    capable of corroding metal containers, such as storage tanks, drums,
    and barrels. Battery acid is a good example. Phosphoric,
    hydrochloric, and hydrofluoric acids used in the vehicle maintenance
    industry for parts cleaning and degreasing are also examples. The
    waste code for these materials is D002.

    -   **Reactivity:** Reactive wastes are unstable under "normal"
        conditions. They can cause explosions, toxic fumes, gases, or
        vapors when mixed with water. Examples include lithium-sulfur
        batteries and explosives. The waste code for these materials is
        D003

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-   **Toxicity:** The test for the toxicity characteristic is called the
    Toxicity Characteristic Leaching Procedure (TCLP). The TCLP tells a
    generator whether or not the waste can release hazardous metal or
    organic constituents in amounts above the State regulatory limits
    under conditions that simulate disposal of the waste in a landfill.
    A laboratory performs TCLP. A waste sample may be submitted for
    analysis to a laboratory that performs the TCLP. Once the TCLP
    results are known, if the materials in the waste stay the same, no
    further testing is necessary

**IMPORTANT: If you have any questions about whether or not your waste
is hazardous after reading this section, please call the Maryland
Department of the Environment (MDE) at (410) 537-3345.**

The following table is provided to help you characterize your wastes and
lists some of the common wastes you may generate.

Table 1: Hazardous Waste Identification

+-------------------+-------------------+-----------------------------+
| **Waste**         | **Is it           | **Why?**                    |
|                   | Hazardous?**      |                             |
|                   |                   |                             |
|                   | **Listed or       |                             |
|                   | Characteristic?** |                             |
+-------------------+-------------------+-----------------------------+
| Waste Sanding     | It **may** be a   | Sanding dust should be      |
| Dust              | characteristic    | tested to determine whether |
|                   | waste             | it contains trace metals or |
|                   |                   | organics, which would cause |
|                   |                   | it to fail the toxicity     |
|                   |                   | characteristic.             |
+-------------------+-------------------+-----------------------------+
| Waste Motor Oil   | Yes, it **may     | Waste oil may have levels   |
|                   | be**              | of lead and/or benzene,     |
|                   | characteristic    | which fails the toxicity    |
|                   | waste and it may  | characteristic. If shop     |
|                   | be a MD Hazardous | chooses not to test, it     |
|                   | Waste             | must be handled as a MD     |
|                   |                   | Hazardous Waste             |
+-------------------+-------------------+-----------------------------+
| Waste Anti-Freeze | No unless it is   | It does not meet any of the |
|                   | contaminated with | definitions.                |
|                   | metals or other   |                             |
|                   | fluids            |                             |
+-------------------+-------------------+-----------------------------+
| Absorbent         | Yes, a            | Absorbents soaked with      |
| Materials, such   | characteristic    | materials that are          |
| as Speedi-Dry     | waste             | considered hazardous waste  |
| Contaminated with |                   | also are considered         |
| Hazardous Waste   |                   | hazardous waste.            |
+-------------------+-------------------+-----------------------------+
| Shop Towels/Rags  | Yes, a            | Absorbents soaked with      |
| Contaminated with | characteristic    | materials that are          |
| Hazardous Waste   | waste             | considered hazardous waste  |
|                   | (**unless)**      | also are considered         |
|                   |                   | hazardous waste. But, in    |
|                   |                   | the case of rags/towels, if |
|                   |                   | they are not soaked         |
|                   |                   | (dripping) and they meet    |
|                   |                   | the following conditions,,  |
|                   |                   | they are not considered     |
|                   |                   | hazardous waste: 1. They    |
|                   |                   | must be laundered at an     |
|                   |                   | appropriate facility.       |
|                   |                   |                             |
|                   |                   | 2\. They must be stored in  |
|                   |                   | containers away from a      |
|                   |                   | source of ignition.         |
|                   |                   |                             |
|                   |                   | 3\. No other waste can be   |
|                   |                   | mixed with rags.            |
+-------------------+-------------------+-----------------------------+

### 2.3 I'm a hazardous waste generator -- what do I need to 

### do?

Use the worksheet below to determine your generator status.

  ------------------------ ----------------------- ----------------------
  Waste                    Amount generated in one Amount Stored (pounds)
                           month (pounds)          

                                                   

                                                   

                                                   

                                                   

  Total Quantities                                 
  ------------------------ ----------------------- ----------------------

If the total in either column is greater than 220 pounds you must have
an EPA hazardous waste generator ID number and you must meet all the
record keeping, training, and reporting requirements. If you store less
than 1,100 pounds of hazardous waste and you generate less than 2,200
pounds then you can store the waste for up to 180 days before you send
it for disposal. If you have more then those amounts then you must send
your waste for disposal within 90 days. This is summarized in the table
below.

+----------------+-----------------+----------------+-----------------+
| ##             | #### Wa         | ##             | #### Stora      |
| ## Waste gener | ste accumulated | ## I.D. Needed | ge time allowed |
| ated per month |                 |                |                 |
+----------------+-----------------+----------------+-----------------+
| #### \<220 lb  | #### \<220 lbs  | #### No        | ####            |
+----------------+-----------------+----------------+-----------------+
| #### Betwee    | #### \<1100     | #### Yes       | #### 180 Days   |
| n 220 and 2200 |                 |                |                 |
+----------------+-----------------+----------------+-----------------+
|                | #### \>= 1100   | #### Yes       | #### 90 Days    |
+----------------+-----------------+----------------+-----------------+
| #### \>=2200   | #### Any Amount | #### Yes       | #### 90 Days    |
+----------------+-----------------+----------------+-----------------+

**1.** A generator **may** accumulate hazardous waste on-site for **90
days**

> provided that the waste is placed in containers.

**2.** You **should** create a "**90-day storage area**" where full
containers **(typically** **55-gallon drums)** of waste can be stored.

**3.** These drums **must be** shipped off-site using a licensed waste
transporter

within 90 days.

**4.** You **can** accumulate up to 55 gallons of waste in containers
according to the

Satellite Accumulation provisions described below:

## a. "Satellite" or Workstation Accumulation- the State and Federal 

## Hazardous Waste Regulations (specifically 40 CFR 262.34(c)(1)) allow a 

## generator to accumulate up to 55 gallons of hazardous waste with no 

## storage time limit provided that the container is:

> **i.** At or near the point of generation;
>
> **ii.** Under control of the operator;

iii. In good condition;

iv. Kept closed except when adding or removing waste;

v.  Handled or stored so as not to cause a rupture or leak;

vi. Arranged to accommodate the storage of chemically incompatible
    wastes; and

vii. Labeled with the words Hazardous Waste.

**b.** When filled, the generator **must** move the 55 gallon container
to a

> designated hazardous waste storage area within 3 days. The full
> containers

then incur the 90-day time limit for proper disposition (i.e. the 90-day

> "clock" begins ticking) and must also meet the complete labeling
>
> requirements described in the Container Labeling.

![](media/image2.png){width="1.4583333333333333in"
height="1.7979166666666666in"}**2.4 Hazardous Waste Storage -- Container
Management**

As described in the previous section, an

auto body shop may accumulate hazardous waste on

site for 90 days provided that the waste is placed in

containers, usually drums, and these containers are managed according to
40 CFR 265 Subpart I - Use and

Management of Containers.

The **7 Criteria** for proper container Management (as listed in Subpart
I) with reference to actions that shops can take to remain in compliance
are:

> **1.** **You must use containers that are in good condition**. This
> means no holes, dents or rust.

-   *Auto body shops should review the condition of their containers and
    ensure that the facility and employees are capable of containing a
    leak. Spill kits are readily available and should be considered.
    Salvage drums (drums which can be used to house an entire leaking
    drum) are an additional safety feature to consider for your site.*

> **2. Compatibility of waste with container -** You must use containers
> that won't react with the waste. Do not use plastic drums for solvents
> or thinners that can dissolve the plastic. Also, since these fluids
> are ignitable, you should be sure these drums are electrically
> grounded
>
> **3. Management of containers.** -- You must keep hazardous waste
> containers closed except when you are adding or removing waste. You
> must take precautions to prevent damaging the container.

-   *Facilities should ensure that containers are closed except when it
    is necessary to add or remove waste. Items such as funnels with
    lids, or simply securing the drum cap (bung), etc. can be used.
    Consider posting instructions in the area.*

-   *Also, drums of material are sometimes observed stored in areas
    outside the facility or in far corners of the property. Outdoor
    storage is generally not recommended. Auto body shops should
    consider moving containers inside. If left outdoors, shops should
    protect the storage area from the movement of cars/trucks within the
    yard. A storage shed or a fenced and covered area should be
    considered. Commercially available hazardous waste storage lockers
    are another option.*

> **4. Inspections.** -You must inspect your hazardous waste storage
> area at least weekly. You must record these inspections on an
> inspection log and keep these logs for at least three years. A sample
> inspection log form is included for your use.

-   *Auto body shops should implement a weekly inspection of the storage
    area looking for leaks or deterioration of hazardous waste
    containers. This program must be documented. Consider hanging a
    clipboard on the wall with the checklist and inspection log.
    Included on the following page is a checklist of items for your use
    to perform the inspection. Record these inspections in an inspection
    log and keep these records for at least three (3) years from the
    date of inspection.*

> **5. Special requirements for ignitable or reactive waste** --

Containers holding ignitable or reactive waste must be located at least
50

feet from the facility's property line.

> **6. General requirements for ignitable, reactive, or incompatible
> wastes.** The owner or operator must take precautions to prevent
> accidental ignition or reaction of ignitable or reactive waste. This
> waste must be separated and protected from sources of ignition or
> reaction including but not limited to: Open flames, smoking, cutting
> and welding, hot surfaces, frictional heat, sparks (static,
> electrical, or mechanical), spontaneous ignition (e.g., from
> heat-producing chemical reactions), and radiant heat. While ignitable
> or reactive waste is being handled, the owner or operator must confine
> smoking and open flame to specially designated locations. ''No
> Smoking'' signs must be conspicuously placed wherever there is a
> hazard from ignitable or reactive waste.

-   *Auto body shops generate ignitable waste and thus should locate the
    90-day storage area to comply with the above requirements. Auto body
    shops should separate the storage area from open flames, sparks, and
    other sources of ignition. Shops should also post "No Smoking" signs
    in the storage area. Drums containing ignitable wastes must also be
    electrically grounded.*

> **General requirements for ignitable, reactive, or incompatible**

**wastes**. Where specifically required by other sections of this part,
the

treatment, storage, or disposal of ignitable or reactive waste, and the

mixture or commingling of incompatible wastes, or incompatible wastes
and

materials, must be conducted so that it does not: (1) Generate extreme
heat

or pressure, fire or explosion, or violent reaction; (2) Produce
uncontrolled

toxic mists, fumes, dusts, or gases in sufficient quantities to threaten
human

health; (3) Produce uncontrolled flammable fumes or gases in sufficient

quantities to pose a risk of fire or explosions; (4) Damage the
structural

integrity of the device or facility containing the waste; or (5) Through
other

like means threaten human health or the environment.

> **Special requirements for incompatible wastes.** --You must take
> steps to prevent the mixing of incompatible wastes. Incompatible
> wastes are wastes that can react with each other to produce toxic or
> flammable fumes, or heat, or other dangerous by-products. One example
> from car repair is the acid from car batteries and waste solvents.
>
> Potentially incompatible materials at auto body shops are car
> batteries and ignitables. They should be stored separately to comply
> with this requirement. Otherwise, the wastes generated by body shops
> are generally all ignitable and can be stored in the same area.
>
> **7. Air emission standards.**

-   *Auto body shops should ensure that waste is stored in DOT-approved
    containers and that these containers remain closed when not being
    filled.*

-   *Note: A hazardous waste generator must package the waste in
    accordance with DOT requirements as well. They can be found in 49
    CFR 173, 178, and 179. These regulations are not reviewed in detail
    here. But, there are many training seminars available which detail
    the specific requirements. Basically, shops must ensure that they
    are using DOT-approved containers in good condition that are
    compatible with the material being shipped.*

**2.5 Hazardous Waste Storage- Tanks**

The storage of hazardous wastes in tanks is strictly regulated. The
tanks must meet stringent design standards including having the design
and installation certified by a registered professional engineer. The
tanks must have leak detection equipment and they must be inspected
daily. Small businesses like body shops and repair shops typically do
not generate enough hazardous waste for a tank to be useful. These
businesses can usually store their waste in drums or other containers
more easily then in a tank.

**2.6 Hazardous Waste Storage- Containment**

In addition to the container requirements listed in the previous
section, the area in which hazardous wastes are stored (the 90-day
storage area) **must have a secondary containment system** which is
capable of containing a leak or spill.

**This containment system must be designed and operated as follows:**

> **1.** A base that is free of cracks or gaps and is sufficiently
> impervious to
>
> contain leaks, spills, and accumulated precipitation until the
> collected
>
> material is detected and removed **must** underlie the containers;
>
> **2.** The base **must be** sloped or the containment system **must
> be** otherwise
>
> designed and operated to drain and remove liquids resulting from
> leaks,
>
> spills, or precipitation, unless the containers are elevated (on
> wooden
>
> pallets, for example) or are otherwise protected from contact with
>
> accumulated liquids;
>
> **3.** The containment system **must have** sufficient capacity to
> contain 10% of
>
> the volume of containers or the volume of the largest container, which
>
> ever is greater. Containers that do not contain free liquids need not
> be
>
> considered in this determination;
>
> **4.** Run-on into the containment system **must be** prevented unless
> the
>
> collection system has sufficient excess capacity in addition to that
>
> required in #3 above to contain any run-on which might enter the
> system;
>
> and
>
> **5.** Spilled or leaked waste and accumulated precipitation **must
> be** removed
>
> from the sump or collection area in as timely a manner as is necessary
> to
>
> prevent overflow of the collection system. (If the collected material
> is a
>
> hazardous waste, it must be managed as a hazardous waste in accordance
>
> with all applicable requirements.)

Auto body shops that generate hazardous waste should immediately
construct and/or purchase a containment system in accordance with the
requirements listed above if they do not already have one in place. Note
that storage lockers and pallets are commercially available which should
comply with these requirements.

![](media/image3.png){width="2.4305555555555554in"
height="0.9319444444444445in"}

**2.7 Container Labeling Requirements**

Each container in the hazardous waste storage area **must be** labeled
with the following information:

> **1.** The words: **HAZARDOUS WASTE** - Federal Law Prohibits Improper
>
> Disposal. If found, contact the nearest police or public safety
> authority or
>
> the U.S. Environmental Protection Agency.
>
> **2.** The Generator's Name and Address.
>
> **3.** The generic shipping name of the principle hazardous waste
> component, if
>
> the proper DOT shipping name is not descriptive.
>
> **4.** The EPA waste code.
>
> **5.** Date of containerization. (The date that the 90 day "clock"
> begins ticking.)
>
> **6.** The hazardous waste manifest document number.
>
> **7.** DOT hazard label.

![](media/image4.png){width="5.878472222222222in" height="2.225in"}

These labels are readily available from lab safety catalogs or from your
waste transporter. DOT hazard labels depend on the material in the
container. The Class 3 "Flammable Liquid" label will be used for many of
the 25 materials shipped from body shops.

Each "Satellite" Accumulation container must be labeled with the words
Hazardous Waste. However, if the container is ultimately moved to the
storage area to be the shipping container, then it must have all of the
items listed above (the company's name, address, DOT descriptive
shipping name, and the EPA waste code).

![](media/image5.png){width="1.3055555555555556in"
height="1.4305555555555556in"}The hazardous waste generator is also
responsible to ensure that the vehicle transporting its hazardous waste
is licensed in MD and has the correct placards. Placards are similar in
shape and color to the hazard labels, but are larger and must be on all
four sides of the vehicle. If the vehicle does not have the correct
placards, it is the generator's responsibility to placard the truck
correctly, though this generally is not necessary with competent waste
transporters.

![](media/image6.bmp)

**2.8 Offering Hazardous Waste for Shipment Licensed Transporters, EPA
ID Numbers and Waste Manifests**

> **1.** You will **need** a licensed hazardous waste transporter to
> remove your
>
> hazardous waste.
>
> **2.** Your transporter **will provide** you with a manifest for each
> shipment, which
>
> may be preprinted, except for your signature.
>
> **3.** Make sure you check the manifest carefully for accuracy with
> regard to
>
> your EPA ID number, amount and type of wastes.

#### 

#### EPA Identification Numbers

An auto body shop must not generate, store, or offer for transportation,
hazardous waste without having received an EPA identification number.
Shops also must not offer its hazardous waste to commercial transporters
or to treatment, storage, or disposal facilities that have not received
an EPA identification number, and the Transporter must have a valid
Maryland Hazardous Waste Transporter Permit as indicated by an official
sticker on the vehicle. To obtain an EPA ID Number, contact MDE at (410)
537-3344 and indicate that you are requesting an EPA ID Number for
Hazardous Waste.

## 

## Hazardous Waste Manifests

> Shipping hazardous wastes **requires** using a hazardous waste
> manifest.
>
> **Hazardous Waste Manifest (See Figure on next page):** An important
> tracking document that makes it possible for you to show that your
> hazardous waste has been disposed of properly. The transporter will
> sign for the hazardous waste and leave a copy of the manifest with
> you. The disposal facility will then send you a signed copy showing
> that they received it. **You will need to keep both copies in your
> file for each shipment.**

![](media/image7.wmf)

## 2.9 How to Handle Degreasing/Parts Cleaners

Hazardous wastes can be generated when an organic solvent (i.e. cleanser
that is chlorinated) is used to clean parts. To dispose of possible
hazardous wastes generated by use of organic solvents for parts
cleaners:

> **1.** Use an on-site solvent recycling unit however the residue
> (still bottoms) will be a hazardous waste, **or**
>
> **2.** Contract with a solvent service company, **or**
>
> **3.** Call the **Maryland Department of the Environment (MDE)** at
> **(410) 537-**
>
> **3345** for details on other methods of hazardous waste disposal.

Use of water-based (aqueous parts cleansers) parts washing systems
rather than organic solvent cleansers is best. More information about
water-based (aqueous) parts washing systems can be found in the "**Best
Practices**" section of this manual on page 17.

## 2.10 What to Do with Used Radiator Coolant/Antifreeze

The best way to get rid of used antifreeze is by recycling it. **Do
not** pour antifreeze into drains or sewers, or on the ground. Used
antifreeze may contain heavy metals above regulatory levels and be a
hazardous waste. If you determine that it is hazardous, call **(410)
537-3344** for an **EPA ID number** and a **hazardous waste**
**manifest** before sending it for recycling or disposal. See Section
4.1 for more information on recycling options.

## 2.11 What to Do with Excess Gasoline

## Waste gasoline must be handled as a hazardous waste if it is flammable or if it contains benzene at a concentration greater than the regulatory limit of 0.5 parts per million.

## 

## 2.12 How to Handle Lubricating Oil

Maryland's used oil regulations are very similar to the federal
regulations. These regulations cover the proper handling, storage, and
disposal of both used oil and used oil filters.

> **1.** You must store used oil in containers that are marked "**Used
> Oil**".
>
> **2.** You must use containers that are in good condition, which means
> no holes, dents or rust and must be managed to prevent spills.
>
> **3.** It is **important** that **[only used oil]{.underline}** is
> placed in the containers. Mixing other products or wastes with your
> used oil may cause the used oil to be considered a hazardous waste and
> increase the cost for disposal.
>
> **4.** If you plan to store used oil in an aboveground or underground
> storage tank, there are specific State requirements for the
> construction and testing of these tanks.
>
> **5.** You should take steps to prevent any spills or leaks of used
> oil. Oil absorbent materials should be kept on hand to use in case of
> any spills. In the event that you do have a leak or spill of used oil,
> you must stop the leak, clean up the used oil and notify MDE by
> calling (866) 633-4686.
>
> **6.** Depending on the total quantity of oil stored at your site, you
> may be **required** to have a federal **Spill Prevention, Control and
> Countermeasures (SPCC) Plan**.
>
> **7.** As a used oil generator you are required to use a transporter
> with a 12-digit EPA identification (ID) number. The transporter may
> require the oil be tested to ensure that it is not considered a
> hazardous waste. The transporter will ultimately take the oil for
> processing.
>
> **\*\*\****Environmentally the best choice for recycling used oil is a
> company that re-refines the oil to produce lubricating oil. This helps
> the environment because it takes less energy to re-refine used oil
> into lubricating oil than to use crude oil and it also takes much less
> used oil than crude oil to produce lubricating oil\*\*\**

## 2.13 What to Do With Motor Oil Filters

There are two types of oil filters, terne and non-terne plated, that car
repair shops might see. Terne is an alloy of lead and tin and is used to
plate some oil filters for heavy-duty vehicles like construction
equipment. Light duty vehicles typically use non-terne plated filters.
Used oil filters that are non-terne plated are exempted from regulation
as hazardous wastes if you do the following after they are removed:

1.  puncture the dome end or anti-drainback valve and allow to drain for
    12 hours at 60 degrees F or higher; or

2.  allow to drain for 12 hours at 60 degrees F or higher, then crush
    the filter; or

3.  dismantle the filter and allow to drain for 12 hours at 60 degrees F
    or higher.

After the non-terne filters are drained using one of these procedures,
the filters can be crushed both to remove more oil and to reduce the
volume of the filters. The filters may be disposed of as solid waste,
however MDE recommends contracting with a company that recycles the
metal and reclaims any oil that may still be in them after they are
crushed. Oil filter crushing machines are commercially available.

## 2.14 How to Handle Used Batteries

**1.** Intact used batteries, including lead-acid and nicad, **should
be** recycled.

**2.** Leaking lead-acid batteries **are** hazardous waste.

**3.** Stored batteries **should be** checked frequently for lead-acid
leakage.

## 2.15 Underground Storage Tanks (UST)

###  Some car repair shops have underground storage tanks (USTs) that they use to store used oil or other liquids. USTs have strict requirements you must follow that are designed to prevent leaks and to quickly detect any leaks that might happen. This workbook does not cover the requirements for gasoline USTs at gas stations.

### If you have an underground storage tank (UST) at your facility you must have:

### Overfill protection

### Corrosion Protection

### Leak detection

-   Evidence of financial responsibility

**[Overfill Protection]{.underline}**:

You must have one of the following devices on your underground storage
tank (UST) to keep you from overfilling the tank:

-   Automatic shutoff devices

-   Overfill alarms

-   Ball float valves

**[Corrosion Protection]{.underline}**

You must have one of the following to prevent your underground storage
tank (UST) from corroding:

-   Steel tank with corrosion-resistant coating and cathodic protection

-   Tank made on noncorrodible material, such as the ACT100 tank, or
    tank enclosed in noncorrodible material

-   Uncoated steel tank with cathodic protection system

-   Uncoated steel tank with cathodic protection and interior lining of
    noncorrodible material.

The piping for your UST must also be protected from corrosion.

**[Leak Detection]{.underline}**

You must have a method of detecting if your underground storage tank
(UST) is leaking. The method you must use depends on the size of your
UST and what you store in it. For a used oil UST you may be allowed to
use manual tank gauging (MTG) depending on the size of the tank as
explained below.

-   UST system must be out-of-service for a period of 36 hours to
    properly perform MTG. MTG does not satisfy release detection for
    piping. 

```{=html}
<!-- -->
```
-   USTs of 600 gallons or less -- MTG fulfills the release detection
    requirement

-   USTs of 601 gallons to 2,000 gallons -- MTG and precision testing
    every 5 years fulfills the release detection requirement 

-   USTs over 2,000 gallons -- MTG cannot be used to fulfill requirement

**How to perform Manual Tank Gauging (MTG)**

1.  Have a good measuring stick capable of measuring the level of oil
    over the full range of the tank's height and can measure to the
    nearest 1/8 inch.

2.  Take a liquid level measurement at the beginning and ending of a
    period of at least 36 hours during which liquid may not be added to
    or removed from the tank.

3.  The level measurement shall be based on an average of two
    consecutive stick readings.

4.  A release is indicated and must be reported to MDE at (410) 537-3442
    if the variation between the beginning and ending measurements
    exceeds the weekly or monthly standards in the following table.

  ----------------------- ----------------------- -----------------------
  Tank Capacity           Weekly Standard         Monthly Standard
                                                  (average of four tests)

  550 gallons or less     10 gallons              5 gallons

  551 -- 1,000 gallons    13 gallons              7 gallons

  1,001 -- 2,000 gallons  26 gallons              13 gallons
  ----------------------- ----------------------- -----------------------

**[Evidence of financial responsibility]{.underline}**

You are required to have the financial capability to clean up any leaks
from your UST. This is usually accomplished through insurance coverage.

## 2.16 Above Ground Storage Tanks (AST)

Some repair shops store new oil, used oils or other fluids in above
ground storage tanks (AST). ASTs are regulated by MDE as described
below.

**1.** You must use a tank that meets design standards that are
specified in the regulations. These include National Fire Protection
Association (NFPA) standards and American Petroleum Institute (API)
standards.

**2.** You should be able to see the vent line from the fill location or
have another means of preventing overfilling the tank.

**3.** You must clean up and report any oil spills.

## 

## 2.17 How to Store and Dispose of Scrap Tires

Scrap tires are defined in the regulations as any tire or part of a tire
that is no longer suitable for its intended purpose because of wear,
damage or defect. The tires you remove from a customer's car are
considered scrap tires. Scrap tires can cause environmental problems if
they are not handled properly so MDE regulates the generation,
transportation and disposal of them.

**Your facility will need one of the following scrap tire licenses**

> **1. General License**-allows you to accumulate **up to 50** scrap
> tires on site at any time.
>
> **2. Secondary License**-allows you to accumulate **up to 1500** scrap
> tires on site.
>
> This license is **required** if you expect to have **more than 50**
> scrap tires at your facility at any one time.

**3. Primary License**- allows you to accumulate **more than 1500**
scrap tires.

> Repair shops do not typically use the Primary License.

**Application for the scrap tire collection facility license requires
you to:**

> **1.** Provide information on the hauler and the facility where your
> scrap tires will be delivered. MDE's Scrap Tire Program can provide
> you with a list of approved scrap tire haulers and scrap tire
> acceptance facilities that you can contact to handle your scrap tires.
>
> **2.** Keep track of:
>
> **a.** The number and types (auto or truck) of scrap tires that you
> ship
>
> **b.** Which haulers you use to transport them, and
>
> **c.** What facility you send them to.
>
> **d.** Keep these records on hand for at least three years so they are
>
> available for an inspector.
>
> **3.** You must handle your scrap tires in a way that prevents them
> from causing a health or environmental hazard such as discharges to
> air or water, or infestation by insects or rodents.

**[Scrap Tire Hauling]{.underline}**

If you want to haul your own scrap tires, you must have a Scrap Tire
Hauler License. You must have a Scrap Tire Hauler License if you
transport more than five scrap tires in a year. You must provide the
following information on the application for the Scrap Tire Hauler
License:

1\. The vehicle information (registration number, VIN Number, vehicle
owner) for each vehicle you will use to haul scrap tires.

2\. A list of the zip codes or a map of the area you will be serving.

3\. A list of the facilities that you are picking up the scrap tires
from and a list of where you are taking them.

Once you have your Scrap Tire Hauler License there are several
requirements you will need to meet.

> 1\. You must have the scrap tire hauler identification number
> displayed on all vehicles you use to haul scrap tires.
>
> 2\. You must notify MDE when you make any changes in which vehicles
> you use to haul scrap tires.
>
> 3\. You must keep records of the scrap tires collected and where you
> take them. You must keep these records for three years.
>
> 4\. You must submit a report to MDE on February 1 and August 1 of each
> year that provides information on how many scrap tires you hauled,
> where you hauled them from, and where you delivered them.

# Section 3.0-Water Issues

Car repair shops can have an impact on the local water quality. When you
steam clean engines or wash cars you can send detergents, oil and grease
and other contaminants into the storm drains or other waterways. In
addition spills or leaks of anti-freeze, oil, other automotive fluids,
or even spilled cleaners can damage water quality if they are washed
down the drain instead of cleaned up properly. The best practices
section 4.4 -- Running a Dry Shop on page 29 has tips on how to clean
the floors to minimize this. Body shops face two main issues with water
pollution: floor drains in the shop floor and proper handling of water
from washing vehicles.

**3.1 Floor Drains:**

> It is a **requirement** in Baltimore City and other jurisdictions for
> floor drains to be **sealed** to prevent spills from being discharged
> to the sanitary or storm sewer system.

**3.2** Vehicle Wash Water:

**1.** The discharge of vehicle wash water **requires a permit** if the
wastewater is

disposed of:

**a.** Onto the ground;

**b.** Into a subsurface disposal system such as a septic system or
seepage

pit; or

**c.** Into a surface water body or storm drain.

**2.** Disposal of vehicle wash water to the sanitary sewer requires an
agreement with the local wastewater treatment plant. This agreement is
known as a pretreatment permit.

**3.** You will be required to sample your wastewater discharge and have
it analyzed. The results of this analysis will determine what treatment
is necessary before you can discharge to the sewer system. Your permit
may require regular sampling and analysis to show you are complying with
the permit's conditions.

**4.** If you are washing cars, ask your supplier about soap metering
systems. Soap metering systems meter the appropriate amount of soap
directly into the washing system, thus significantly reducing your soap
usage and saving you money.

# 

# Section 4.0-Best Practices

Remember that neatness counts. Cleaning up any leaks or drips
immediately and using the proper containers and absorbents can help
prevent contamination of the environment. Keeping your shop clean and
organized is a good way to show you are concerned about the health and
safety of your employees and the environment. It is also a good idea to
check your environmental compliance on a regular basis. Using a
checklist like the one provided as part of this package is a good way to
stay in compliance with Maryland's environmental regulations.

## 

## 4.1 Used Radiator Coolant/Antifreeze

MDE recommends recycling your antifreeze instead of sending it for
disposal. There are three options for recycling your antifreeze.

> **1) On-Site Recycling:** used antifreeze is recycled in units
> purchased by the facility, located on site, and operated by facility
> employees.
>
> **2) Mobile Recycling Service:** a van or truck equipped with a
> recycling unit visits the facility and recycles used antifreeze on
> site.
>
> **3) Off-Site Recycling:** used antifreeze is transported to a
> specialized recycling company; these services can also supply the
> facility with recycled antifreeze.

All waste antifreeze recycling methods involve two steps: 1) removing
contaminants either by filtration, distillation, reverse osmosis, or ion
exchange and 2) restoring critical antifreeze properties with additives.
Additives typically contain chemicals that raise and stabilize pH,
inhibit rust and corrosion, reduce water scaling, and slow the breakdown
of ethylene glycol.

### 4.2 Aerosol Sprays

Aerosol spray cans contain propellants in addition to the ingredients
you actually want. Some of these propellants may be volatile organic
compounds (VOCs) or chemicals that are not good for the environment.

**1.** Replace aerosol spray cans with refillable spray bottles. This
will save you

money in the long run if you use a lot of aerosol cans. You can buy the

products in bulk and fill individual spray bottles as needed.

**2.** There are a variety of spray bottles available ranging from
simple pumps to

> stainless steel bottles that can be pressurized with compressed air.
> Using alternatives such as these can save you money because you are
> only paying for the product not for the propellant that is used in
> aerosol cans.

**3.** Be careful about maintaining the labels on the spray bottles.

## 4.3 Aqueous Parts Washers

Aqueous (water-based) parts washers, which are becoming more common, can
replace solvent-based parts washers. Aqueous (water-based) parts washers
reduce air pollution by using detergents to clean parts instead of
solvents. Using water-based parts washers also reduces the amount of
waste generated by your shop. Using an aqueous parts washer instead of a
solvent-based parts washer also has benefits for you as a worker.
Aqueous cleaners contain a lower percentage of volatile organic
compounds (VOCs) than solvent-based cleaners, thus decreasing the
exposure of harmful agents to the worker.

Aqueous cleaners rely on heat, detergents, and agitation to clean the
parts. There are a number of different types of aqueous part washers
available and it is important to select the right system for your needs.

Two of the most common types of aqueous parts washers are **sink top
washers** and **spray cabinet washers**.

**1. Sink top units:**

**a.** Similar in appearance to solvent units.

> **b.** In addition to the detergent, the solutions in these units have
> microbes
>
> that degrade the oils that are removed from the parts and filters them
> to remove larger particles.

**c.** Filtration process can significantly extend the life of the
solution with

> some businesses reporting a solution life of over two years. The
> extension of the life of the solution means that you buy less of it
> and thus save money.

**d.** Generate used solution and used filters as waste.

**e.** Waste must be tested to determine whether or not it is hazardous.

**f.** Wastes **should never** be disposed of in the sewers or a septic
system.

**2. Spray cabinet washers:**

**a.** Similar to an industrial dishwasher.

**b.** Available in various sizes depending on your needs.

**c.** Use high temperature and high-pressure water solution to clean
the

> parts.

**d.** Runs unattended. Employees can spend their time on other tasks
while

> the parts washer runs.

Aqueous parts washers have been used successfully in a wide variety of
applications in different industries including car repair. There are
special units that are designed for brake washing. In addition to the
environmental benefits, many companies have found that they have saved
money using the aqueous parts washers.

## 4.4 Running a dry shop

A dry shop is one that uses no water or very little water to clean the
floors.

**How To Run a Dry Shop:**

> **1**. Do not wash the floors or use wet mops to clean up spills.

**2.** Clean up small spills with rags. Do not saturate the rags.

> **3.** If the spills are solvents or gasoline, use appropriate
> absorbents to clean
>
> the spill and dispose of the absorbents as hazardous waste.
>
> **4.** Use hydrophobic mops and absorbents to absorb oil. Hydrophobic
> mops do not absorb water.

## 4.4 Good Storage Practices

1.  Wastes should be stored in separate containers and clearly labeled
    for contents prior to recycling or disposal.

2.  Use proper tools and procedures to move drums-this will reduce the
    possibility of leaks and spills.

3.  Store materials like thinners, solvents, cleaners and oil and
    antifreeze in an area that has secondary containment. This will
    prevent any spills or leaks from contaminating your floors or drains
    and will make them easier to clean up.

4.  MDE recommends that you minimize the number and amount of stored
    materials.

5.  Use first-in-first out (FIFO) policy to reduce storage time. This
    will reduce materials that are out of date.

### 4.5 Environmental Management Systems

Environmental management systems (EMS) help businesses identify and
manage their environmental impacts. Environmental management systems can
range in difficulty, but most systems have some elements in common. Even
a small business can use some of the elements of an EMS to improve their
environmental performance. The basic elements of an EMS for a small
business could include:

-   A written environmental policy;

-   Waste minimization and recycling plans that are specific to the
    business;

-   Training on the program for new employees; and

-   A commitment to look for ways to continue to improve.

Environmental management systems (EMS) are simply a method for
maintaining environmental compliance and improving the environmental
performance of your business. Rather than looking solely at
environmental regulatory requirements and how to satisfy them, EMSs
encourage organizations to identify environmental impacts, set specific
goals, train staff, and monitor performance. Small businesses can
benefit from this approach by communicating with employees on
environmental policies and goals and by using the EMS model of continual
improvement to track progress and improve operational efficiency. In
addition, the non-regulated aspects considered by EMSs, such as energy,
water and raw material consumption, greenhouse gas emissions, solid
waste, and non-point source pollution all present opportunities to save
considerable money and prevent future liability.

![](media/image8.jpeg){width="6.652777777777778in"
height="8.040972222222223in"}

**About this guide:**

The Maryland Department of the Environment (MDE) recognizes that there
are many environmental requirements that both automotive mechanical
repair facilities and body shops face. This workbook provides the
information needed to help you understand and comply with state and
federal environmental regulations. As the facility owner or their
authorized representative, you have a responsibility to manage the
facility in a safe and environmentally sound manner. This means that
state and federal requirements should be met. MDE also knows that the
issues are different for the different types of businesses. To make this
workbook more useful for you, it is organized into two books: one for
mechanical repair and the other for body repair.

In addition to the workbook, MDE is also providing a self-audit
compliance assistance tool for MD facilities. This tool, called a
self-certification, may be used by the facility managers and/or owners
to perform a self-audit. Completion of the self-certification form is
VOLUNTARY. It is NOT required. The form provides most of the questions
that an inspector would ask while visiting your facility. More
importantly, the self-certification tool also provides the answers that
they would expect to find if the shop were in compliance and/or
utilizing best practices for auto shops in Maryland. The questions are
divided into certain types of activities. Not all of these activities
will apply to all shops. There is an applicability question at the
beginning of each section. If that section does not apply to your
facility, you may answer that applicability question and skip to the
next section as directed. If you did not receive a copy of the
self-certification form with this workbook, it is available from MDE by
calling the Environmental Permits Service Center at 410-537-3772 or
1-800-633-6101 extension 3772.

## Which book do I use?

The auto body book covers the following: air quality issues related to
painting, hazardous waste, and vehicle washwater. Use the **Auto Body
book** if your facility engages in any of the following:

1.  Painting

2.  Hazardous wastes

3.  Vehicle wash water

The mechanical repair book covers the following: used tires, used oil,
used batteries, hazardous waste, and vehicle washwater. Use the
**Mechanical Repair book** if your facility engages in any of the
following:

1.  Tires (used tires/changing tires)

2.  Oil (changing oil)

3.  Batteries (taking out old batteries)

4.  Hazardous wastes

5.  Vehicle wash water

If your business does both mechanical repair and auto body types of work
you need to use both books. For example, if you are a have a body shop,
but you also engage in tire repair you will need to refer to the used
tire portion of the mechanical repair facility section.

**BODY SHOPS**

**1.0 Air Pollution Control** 5

> 1.1 Surface Preparation-Fugitive Dust 5
>
> 1.2 Surface Preparation and Cleanup 6
>
> 1.3 Required Compliant Coatings 7
>
> 1.4 Re-painting Cars-Paint Application: Spray Guns and Paint Booths 7
>
> 1.5 Spray Guns 8
>
> 1.6 Equipment Cleaning 9
>
> 1.7 Storage Requirements 9

**2.0 Waste Issues** 10

> 2.1 How can I tell if my wastes are hazardous? 10
>
> 2.2 Hazardous Waste Accumulation and Storage Time Limit 12
>
> 2.3 Hazardous Waste Storage 14
>
> 2.4 Hazardous Waste Storage -- Tanks 17
>
> 2.5 Hazardous Waste Storage-Containment 17
>
> 2.6 Container Labeling Requirements 18
>
> 2.7 Offering Hazardous Waste for Shipment-Licensed 19
>
> Transporters, EPA ID Numbers and Waste Manifests
>
> 2.8 Land Disposal Restrictions 21

**3.0 Water Issues** 22

> 3.1 Floor Drains 22
>
> 3.2 Vehicle Wash Water 22

**4.0 Best Practices** 23

> 4.1 How to Avoid Paint Waste 24
>
> 4.2 Good Storage Practices 24
>
> 4.3 Running a Dry Shop 24
>
> 4.4 Environmental Management Systems 25

# BODY SHOPS

# Section 1.0-AIR POLLUTION CONTROL

#  

When we think of air pollution, the first thing that generally comes to
mind is smoke billowing from factory smokestacks. However, air pollution
can be generated from many types of industrial processes, even without
the visual presence of billowing smoke. Auto body shops play a role in
generating air pollution. Although such pollution does not take the form
of billowing smoke, these emissions are nonetheless detrimental to the
health of the shop worker, neighbors and the environment.

Air pollution from auto body shop operations is generated from three
main activities; surface preparation, surface coating, and cleanup. Each
of these activities can be performed by various methods, and each
carries its share of environmental requirements.

You are not allowed to cause a nuisance due to odors or dust. A nuisance
means that your operations are interfering with the reasonable enjoyment
of someone else's property. Typical nuisances for body shops are paint
dust blowing off site, overspray, and odors from the painting operation.
The information and practices in the following sections can reduce the
chances of these nuisances occurring.

**1.1 Surface Preparation --Fugitive Dust**

Surface preparation and resurfacing operations conducted on vehicles are
regulated by the Maryland Department of the Environment (MDE).

If your shop uses disc sanders to remove paint, chances are good that,
unless the sander has a dust collection device, dust generated from the
sander could travel beyond the property of your shop, which is
prohibited by MDE. Shop fans that exhaust to the outside may be a
primary means for sanding dust to travel outside of the property line.
Also, leaving the doors of your shop opened to the outside (commonly
done during the warmer weather) presents another opportunity for sanding
dust to travel off the property line. Research has shown that sanding
dust contains toxic metals, such as lead, arsenic, cadmium, and
chromium. Exposure to these metals can cause adverse health affects,
making it very important that sanding dust be controlled. By using a
disc sander in combination with a dust collection unit, your body shop
can significantly reduce potential occupational and environmental health
risks associated with sanding dust generated during surface preparation.

When used properly, vacuum units (also referred to as "dustless vacs" or
"ventilated sanders") can control up to 90% of sanding dust generated
from the disc sanding operation. A vacuum-sanding unit features a
sanding disc that is perforated with a series of holes. As sanding dust
is generated, it is vacuumed through the holes. The dust moves through a
hose that is attached to the sanding unit; it then travels to a
collection unit where it is stored until it can be disposed of properly.

1.2 Surface Preparation and Cleanup---Control of

**Volatile Organic Compounds (VOCs) and Toxic Air**

**Contaminants**

A majority of auto body paints, solvents used for mixing paint, and
solvents used for cleaning equipment contain **volatile organic
compounds** (**VOCs**). Toxic Air Contaminants are specifically listed
in the air pollution control regulations and have been confirmed to
cause acute or chronic health effects. (Methylene chloride, commonly
found in paint strippers, is a listed Toxic Air Contaminant.)

> **1.** Facilities are **not allowed** to emit more than a threshold
> quantity of a
>
> Toxic Air Contaminant without a permit and possibly a control device.
>
> **2.** Specific **actions** that auto body shops **must take** to
> comply with VOC and
>
> Toxic Air Contaminant Regulations are explained in the following
> sections.

## 1.3 Required Compliant Coatings

You must use paints that meet the VOC content standard as listed in the
table below. The MSDS for a paint will usually list the VOC content.

+-----------------------------------+-----------------------------------+
| ##                                | ##                                |
|                                   | Maximum VOC Content lb/gal (kg/l) |
+-----------------------------------+-----------------------------------+
| ## Pre-treatment                  | ## 6.5 (0.78)                     |
+-----------------------------------+-----------------------------------+
| ## Pre-coat                       | ## 5.5 (0.66)                     |
+-----------------------------------+-----------------------------------+
| ## Primer Surface                 | ## 4.8 (0.58)                     |
+-----------------------------------+-----------------------------------+
| ## Primer Sealer                  | ## 4.6 (0.55)                     |
+-----------------------------------+-----------------------------------+
| ## Topcoat                        | ## 5.0 (0.60)                     |
+-----------------------------------+-----------------------------------+
| ## Multi-stage Coating System     | ## 5.2 (0.63)                     |
+-----------------------------------+-----------------------------------+
| ## Specialty Coating              | ## 7.0 (0.84)                     |
+-----------------------------------+-----------------------------------+

These standards are for the paint as it is applied, so do not use extra
thinner or other solvents when you mix the paint. One concern is the
level of volatile organic compounds found in the paint. Maryland has
strict regulation concerning the legal amount of volatile organic
compound in paint. **Suppliers in Maryland sell only paints that meet
this strict regulatory standard.**

**1.4 Repainting Cars-Paint Application: Spray Guns and**

**Spray Booths**

Auto body painting is regulated by the Maryland Department of the
Environment (MDE) through **permits** and **registrations**.

**1.** You must have an Air Quality Permit to Construct for equipment
installed *after* **July 1, 1988**.

**2.** You must have an Air Quality Registration for all equipment
installed *before* **July 1, 1988.**

**3.** You must get an air quality permit to construct before beginning
operation of new equipment.

**4.** Any changes to the equipment or processes used **may require** a
new permit.

**5.** All auto body shops must meet emissions requirements. It is very
difficult to meet the emissions requirements if you do not have a paint
booth. Maryland Department of the Environment (MDE) recommends that auto
body shops purchase paint spray booths to meet MDE rules and improve
product quality.

**7.** Upon receipt of your permit **make sure** you read it and
understand it. Your permit will have information on the records you need
to keep and the conditions you need to meet. Typically your permit will
require you to keep records on paint purchases and usage.

### 8. You must have written operating practices for your operation. These practices should address proper operation and maintenance of your equipment, such as filter changes, spray gun cleaning, and spray gun maintenance. You should also include any other practices you follow to minimize emissions. Vendor literature and owner's manuals for your equipment is a good place to start

1.5 Spray Guns

The Code of Maryland Regulations (COMAR 26.11.19.23) requires the use of
a controlled air spray system \[such as High Volume Low Pressure (HVLP)
or Low Volume Low Pressure (LVLP)\] for all vehicle refinishing.

HVLP and gravity feed combination spray guns are the most efficient of
the controlled air spray systems. Follow the manufacturer's instructions
for using these systems to avoid paint waste.

The advantages of using high-efficiency transfer equipment include:

> **1.** Reduced paint use
>
> **2.** Reduced spray booth maintenance requirements,
>
> **3.** Less frequent filter replacement

**4.** Minimal waste disposal

1.6 Equipment Cleaning

> **1.** You must clean your paint spray guns in enclosed containers or
> in VOC recycling equipment if you use a VOC solvent like lacquer
> thinner to clean your paint guns. You may also use other paint gun
> cleaning methods that reduce or eliminate VOC emissions.
>
> **2.** Used thinner can be collected and re-used several times.
>
> **3.** Spent thinner may be classified as a hazardous waste, see the
> waste section for details.
>
> **4.** Use an on-site solvent recycling unit or contract with an
> off-site recycling service**.**

**For more information on registered recycling companies, call the
Maryland Department of the Environment (MDE) at (410) 537-3345.**

1.7 Storage Requirements

> **1. You must store** cleanup and surface preparation materials that
> contain volatile organic compounds (VOCs) in closed metal containers.
>
> **2. You must store** any cloth or paper items contaminated with VOCs
> in
>
> closed metal containers.

##   {#section-25 .unnumbered}

## Section 2.0-Waste Issues 

As a business owner, you must manage your hazardous wastes in a safe and
environmentally responsible manner. Federal and State regulations place
the burden on you, as the generator, to properly dispose of the waste.
You retain responsibility even when other companies handle and dispose
of your waste. By choosing products that are less hazardous, and
minimizing the amount that you generate, you reduce your liability. This
section describes the rules and regulations for hazardous waste
management specifically as they pertain to an auto body shop.

**2.1 How Can I Tell If My Wastes Are Hazardous?**

**1.** At an auto refinishing facility, the following **commonly
generated waste**

**materials** **should be** **considered as possible sources of**
**hazardous waste**:

> **a.** Waste paint stripper and paint which has been stripped from
> vehicles

a.  Solvents such as waste gun cleaners and waste thinners

b.  Waste paint (unused or expired paint)

c.  Sludge or "bottoms" from a solvent recycling unit (still)

d.  Automotive fluids,

e.  Spent filters from the spray booth

**2.** Determine if the waste is listed in the **Code of Maryland
Regulations (COMAR)** by calling the **Maryland Department of the**
**Environment (MDE)** at **(410) 537-3344**, or by reviewing **COMAR
26.13.02.15-.19**. U.S. Environmental Protection Agency (EPA) also lists
hazardous wastes in the Code of Federal Regulations, 40 CFR 261 Subpart
D.

**3. If the waste is not listed in COMAR or CFR:** Determine if the
waste exhibits one of the four characteristics of hazardous wastes:
ignitability, corrosivity, reactivity, or toxicity\--**detailed in 40
CFR 261 Subpart C**.

**a.** Using knowledge of the characteristics of the waste

-   Examples of knowledge that may apply to your hazardous waste
    determination include material safety data sheets (MSDS), product
    labels, or other information from the manufacturer or trade
    associations. The MSDS for a material is supplied by your jobber or
    vendor, and provides information on the chemical and physical
    properties of the material, and methods for proper handling,
    storage, and disposal.

OR **b.** Testing the waste

-   **Ignitability:** Ignitable wastes create fires under certain
    conditions or are spontaneously combustible, and have a flash point
    less than 60 °C (140 °F). Examples include waste oils from oil
    replacement; spent solvents from paint removal, car washing, and
    degreasing; and methanol used for paint removal. The waste code for
    these materials is D001

```{=html}
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```
-   **Corrosivity:** Corrosive wastes are acids or bases that are
    capable of corroding metal containers, such as storage tanks, drums,
    and barrels. Battery acid is a good example. Phosphoric,
    hydrochloric, and hydrofluoric acids used in the vehicle maintenance
    industry for parts cleaning and degreasing are also examples. The
    waste code for these materials is D002.

    -   **Reactivity:** Reactive wastes are unstable under "normal"
        conditions. They can cause explosions, toxic fumes, gases, or
        vapors when mixed with water. Examples include lithium-sulfur
        batteries and explosives. The waste code for these materials is
        D003

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```
-   **Toxicity:** The test for the toxicity characteristic is called the
    Toxicity Characteristic Leaching Procedure (TCLP). The TCLP tells a
    generator whether or not the waste can release hazardous metal or
    organic constituents in amounts above the State regulatory limits
    under conditions that simulate disposal of the waste in a landfill.
    A laboratory performs TCLP. A waste sample may be submitted for
    analysis to a laboratory that performs the TCLP. Once the TCLP
    results are known, if the materials in the waste stay the same, no
    further testing is necessary

The following table is provided to help you characterize your wastes and
lists some of the common wastes you may generate.

+-----------------+-------------------+--------------------------------+
| **Waste**       | **Is it           | **Why?**                       |
|                 | Hazardous?**      |                                |
|                 |                   |                                |
|                 | **Listed or       |                                |
|                 | Characteristic?** |                                |
+-----------------+-------------------+--------------------------------+
| Waste Sanding   | It **may** be a   | Sanding dust should be tested  |
| Dust            | characteristic    | to determine whether it        |
|                 | waste             | contains trace metals or       |
|                 |                   | organics, which would cause it |
|                 |                   | to fail the toxicity           |
|                 |                   | characteristic.                |
+-----------------+-------------------+--------------------------------+
| Waste Motor Oil | Yes, it **may     | Waste oil may have levels of   |
|                 | be**              | lead and/or benzene, which     |
|                 | characteristic    | fails the toxicity             |
|                 | waste and it may  | characteristic. If shop        |
|                 | be a MD Hazardous | chooses not to test, it must   |
|                 | Waste             | be handled as a MD Hazardous   |
|                 |                   | Waste                          |
+-----------------+-------------------+--------------------------------+
| Waste           | No unless it is   | It does not meet any of the    |
| Anti-Freeze     | contaminated with | definitions.                   |
|                 | metals or other   |                                |
|                 | fluids            |                                |
+-----------------+-------------------+--------------------------------+
| Absorbent       | Yes, a            | Absorbents soaked with         |
| Materials, such | characteristic    | materials that are considered  |
| as Speedi-Dry   | waste             | hazardous waste also are       |
| Contaminated    |                   | considered hazardous waste.    |
| with Hazardous  |                   |                                |
| Waste           |                   |                                |
+-----------------+-------------------+--------------------------------+
| Shop            | Yes, a            | Absorbents soaked with         |
| Towels/Rags     | characteristic    | materials that are considered  |
| Contaminated    | waste             | hazardous waste also are       |
| with Hazardous  | (**unless)**      | considered hazardous waste..   |
| Waste           |                   | But, in the case of            |
|                 |                   | rags/towels, if they are not   |
|                 |                   | soaked (dripping) and they     |
|                 |                   | meet the following             |
|                 |                   | conditions,, they are not      |
|                 |                   | considered hazardous waste: 1. |
|                 |                   | They must be laundered at an   |
|                 |                   | appropriate facility.          |
|                 |                   |                                |
|                 |                   | 2\. They must be stored in     |
|                 |                   | containers away from a source  |
|                 |                   | of ignition.                   |
|                 |                   |                                |
|                 |                   | 3\. No other waste can be      |
|                 |                   | mixed with rags                |
+-----------------+-------------------+--------------------------------+

**2.2 Hazardous Waste Accumulation and Storage Time Limit**

### What's My Generator Category?

Use the table below to determine your generator status.

  ------------------------ ----------------------- ----------------------
  Waste                    Amount generated in one Amount Stored (pounds)
                           month (pounds)          

                                                   

                                                   

                                                   

                                                   

  Total Quantities                                 
  ------------------------ ----------------------- ----------------------

If the total in either column is greater than 220 pounds you must have
an EPA hazardous waste generator ID number and you must meet all the
record keeping, training, and reporting requirements. If you store less
than 1,100 pounds of hazardous waste and you generate less than 2,200
pounds then you can store the waste for up to 180 days before you send
it for disposal. If you generate or store more then those amounts then
you must send your waste for disposal within 90 days.

+------------------+---------------+----------------+-----------------+
| #### Wa          | #### Wast     | ##             | #### Stora      |
| ste generated pe | e accumulated | ## I.D. Needed | ge time allowed |
| r month (pounds) |               |                |                 |
+------------------+---------------+----------------+-----------------+
| #### \<220 lb    | #             | #### No        | ####            |
|                  | ### \<220 lbs |                |                 |
+------------------+---------------+----------------+-----------------+
| #### Betw        | #### \<1100   | #### Yes       | #### 180 Days   |
| een 220 and 2200 |               |                |                 |
+------------------+---------------+----------------+-----------------+
|                  | #### \>= 1100 | #### Yes       | #### 90 Days    |
+------------------+---------------+----------------+-----------------+
| #### \>=2200     | ##            | #### Yes       | #### 90 Days    |
|                  | ## Any Amount |                |                 |
+------------------+---------------+----------------+-----------------+

**1.** A generator **may** accumulate hazardous waste on-site for **90
days**

> provided that the waste is placed in containers.

**2.** You **should** create a "**90-day storage area**" where full
containers **(typically** **55-gallon drums)** of waste can be stored.

**3.** These drums **must be** shipped off-site using a licensed waste
transporter

within 90 days.

**4.** You **can** accumulate up to 55 gallons of waste in containers
according to the

Satellite Accumulation provisions described below:

## a. "Satellite" or Workstation Accumulation- the State and Federal 

## Hazardous Waste Regulations (specifically 40 CFR 262.34(c)(1)) allow a 

## generator to accumulate up to 55 gallons of hazardous waste with no 

## storage time limit provided that the container is:

> **i.** At or near the point of generation;
>
> **ii.** Under control of the operator;

iii. In good condition;

iv. Kept closed except when adding or removing waste;

v.  Handled or stored so as not to cause a rupture or leak;

vi. Arranged to accommodate the storage of chemically incompatible
    wastes; and

vii. Labeled with the words Hazardous Waste.

**b.** When filled, the generator **must** move the 55 gallon container
to a

> designated hazardous waste storage area within 3 days. The full
> containers

then incur the 90-day time limit for proper disposition (i.e. the 90-day

> "clock" begins ticking) and must also meet the complete labeling
>
> requirements described in the Container Labeling.

![](media/image2.png){width="1.4583333333333333in"
height="1.7979166666666666in"}

**2.3 Hazardous Waste Storage -- Container Management**

As described in the previous section, an

auto body shop may accumulate hazardous waste on

site for 90 days provided that the waste is placed in

containers, usually drums, and these containers are managed according to
40 CFR 265 Subpart I - Use and

Management of Containers.

The **7 Criteria** for proper container Management (as listed in Subpart
I) with reference to actions that shops can take to remain in compliance
are:

> **1.** You must use containers that are in good condition. This means
> no holes, dents or rust.

-   *Auto body shops should review the condition of their containers and
    ensure that the facility and employees are capable of containing a
    leak. Spill kits are readily available and should be considered.
    Salvage drums (drums which can be used to house an entire leaking
    drum) are an additional safety feature to consider for your site.*

> **2. Compatibility of waste with container -** You must use containers
> that won't react with the waste. Do not use plastic drums for solvents
> or thinners that can dissolve the plastic. Also, since these fluids
> are ignitable, you should be sure these drums are electrically
> grounded
>
> **3. Management of containers.** -- You must keep hazardous waste
> containers closed except when you are adding or removing waste. You
> must take precautions to prevent damaging the container.

-   *Facilities should ensure that containers are closed except when it
    is necessary to add or remove waste. Items such as funnels with
    lids, or simply securing the drum cap (bung), etc. can be used.
    Consider posting instructions in the area.*

-   *Also, drums of material are sometimes observed stored in areas
    outside the facility or in far corners of the property. Outdoor
    storage is generally not recommended. Auto body shops should
    consider moving containers inside. If left outdoors, shops should
    protect the storage area from the movement of cars/trucks within the
    yard. A storage shed or a fenced and covered area should be
    considered to protect the storage area. Commercially available
    hazardous waste storage lockers are another option.*

> **4. Inspections.** -You must inspect your hazardous waste storage
> area at least weekly. You must record these inspections on an
> inspection log and keep these logs for at least three years. A sample
> inspection log form is included for your use.

-   *Auto body shops should implement a weekly inspection of the storage
    area looking for leaks or deterioration of hazardous waste
    containers. This program must be documented. Consider hanging a
    clipboard on the wall with the checklist and inspection log.
    Included on the following page is a checklist of items for your use
    to perform the inspection. Record these inspections in an inspection
    log and keep these records for at least three (3) years from the
    date of inspection.*

> **5. Special requirements for ignitable or reactive waste** --

Containers holding ignitable or reactive waste must be located at least
50

feet from the facility's property line.

> **6. General requirements for ignitable, reactive, or incompatible
> wastes.** The owner or operator must take precautions to prevent
> accidental ignition or reaction of ignitable or reactive waste. This
> waste must be separated and protected from sources of ignition or
> reaction including but not limited to: Open flames, smoking, cutting
> and welding, hot surfaces, frictional heat, sparks (static,
> electrical, or mechanical), spontaneous ignition (e.g., from
> heat-producing chemical reactions), and radiant heat. While ignitable
> or reactive waste is being handled, the owner or operator must confine
> smoking and open flame to specially designated locations. ''No
> Smoking'' signs must be conspicuously placed wherever there is a
> hazard from ignitable or reactive waste.

-   *Auto body shops generate ignitable waste and thus should locate the
    90-day storage area to comply with the above requirements. Auto body
    shops should separate the storage area from open flames, sparks, and
    other sources of ignition. Shops should also post "No Smoking" signs
    in the storage area. Drums containing ignitable wastes must also be
    electrically grounded.*

> **General requirements for ignitable, reactive, or incompatible
> wastes**. Where specifically required by other sections of this part,
> the

treatment, storage, or disposal of ignitable or reactive waste, and the

mixture or commingling of incompatible wastes, or incompatible wastes
and

materials, must be conducted so that it does not: (1) Generate extreme
heat

or pressure, fire or explosion, or violent reaction; (2) Produce
uncontrolled

toxic mists, fumes, dusts, or gases in sufficient quantities to threaten
human

health; (3) Produce uncontrolled flammable fumes or gases in sufficient

quantities to pose a risk of fire or explosions; (4) Damage the
structural

integrity of the device or facility containing the waste; or (5) Through
other

like means threaten human health or the environment.

> **Special requirements for incompatible wastes.** --You must take
> steps to prevent the mixing of incompatible wastes. Incompatible
> wastes are wastes that can react with each other to produce toxic or
> flammable fumes, or heat, or other dangerous by-products. One example
> from car repair is the acid from car batteries and waste solvents.
>
> Potentially incompatible materials at auto body shops are car
> batteries and ignitables. They should be stored separately to comply
> with this requirement. Otherwise, the wastes generated by body shops
> are generally all ignitable and can be stored in the same area.
>
> **7. Air emission standards.**

-   *Auto body shops should ensure that waste is stored in DOT-approved
    containers and that these containers remain closed when not being
    filled.*

-   *Note: A hazardous waste generator must package the waste in
    accordance with DOT requirements as well. They can be found in 49
    CFR 173, 178, and 179. These regulations are not reviewed in detail
    here. But, there are many training seminars available which detail
    the specific requirements. Basically, shops must ensure that they
    are using DOT-approved containers in good condition that are
    compatible with the material being shipped.*

**2.4 Hazardous Waste Storage- Tanks**

> The storage of hazardous wastes in tanks is strictly regulated. The
> tanks must meet stringent design standards including having the design
> and installation certified by a registered professional engineer. The
> tanks must have leak detection equipment and they must be inspected
> daily. Small businesses like body shops and repair shops typically do
> not generate enough hazardous waste for a tank to be useful. These
> businesses can usually store their waste in drums or other containers
> more easily then in a tank.

**2.5 Hazardous Waste Storage- Containment**

In addition to the container requirements listed in the previous
section, the area in which hazardous wastes are stored (the 90-day
storage area) **must have a secondary containment system** which is
capable of containing a leak or spill.

**This containment system must be designed and operated as follows:**

> **1.** A base that is free of cracks or gaps and is sufficiently
> impervious to
>
> contain leaks, spills, and accumulated precipitation until the
> collected
>
> material is detected and removed **must** underlie the containers;
>
> **2.** The base **must be** sloped or the containment system **must
> be** otherwise
>
> designed and operated to drain and remove liquids resulting from
> leaks,
>
> spills, or precipitation, unless the containers are elevated (on
> wooden
>
> pallets, for example) or are otherwise protected from contact with
>
> accumulated liquids;
>
> **3.** The containment system **must have** sufficient capacity to
> contain 10% of
>
> the volume of containers or the volume of the largest container, which
>
> ever is greater. Containers that do not contain free liquids need not
> be
>
> considered in this determination;
>
> **4.** Run-on into the containment system **must be** prevented unless
> the
>
> collection system has sufficient excess capacity in addition to that
>
> required in #3 above to contain any run-on which might enter the
> system;
>
> and
>
> **5.** Spilled or leaked waste and accumulated precipitation **must
> be** removed
>
> from the sump or collection area in as timely a manner as is necessary
> to
>
> prevent overflow of the collection system. (If the collected material
> is a
>
> hazardous waste, it must be managed as a hazardous waste in accordance
>
> with all applicable requirements.)

Auto body shops that generate hazardous waste should immediately
construct and/or purchase a containment system in accordance with the
requirements listed above if they do not already have one in place. Note
that storage lockers and pallets are commercially available which should
comply with these requirements.

![](media/image3.png){width="2.4305555555555554in"
height="0.9319444444444445in"}

**2.6 Container Labeling Requirements**

Each container in the hazardous waste storage area **must be** labeled
with the following information:

> **1.** The words: **HAZARDOUS WASTE** - Federal Law Prohibits Improper
>
> Disposal. If found, contact the nearest police or public safety
> authority or
>
> the U.S. Environmental Protection Agency.
>
> **2.** The Generator's Name and Address.
>
> **3.** The generic shipping name of the principle hazardous waste
> component, if
>
> the proper DOT shipping name is not descriptive.
>
> **4.** The EPA waste code.
>
> **5.** Date of containerization. (The date that the 90 day "clock"
> begins ticking.)
>
> **6.** The hazardous waste manifest document number.
>
> **7.** DOT hazard label.

![](media/image4.png){width="5.631944444444445in"
height="2.1305555555555555in"}

These labels are readily available from lab safety catalogs or from your
waste transporter. DOT hazard labels depend on the material in the
container. The Class 3 "Flammable Liquid" label will be used for many of
the 25 materials shipped from body shops.

Each "Satellite" Accumulation container must be labeled with the words
Hazardous Waste. However, if the container is ultimately moved to the
storage area to be the shipping container, then it must have all of the
items listed above (the company's name, address, DOT descriptive
shipping name, and the EPA waste code).

![](media/image5.png){width="1.3055555555555556in"
height="1.4305555555555556in"}The hazardous waste generator is also
responsible to ensure that the vehicle transporting its hazardous waste
is licensed in MD and has the correct placards. Placards are similar in
shape and color to the hazard labels, but are larger and must be on all
four sides of the vehicle. If the vehicle does not have the correct
placards, it is the generator's responsibility to placard the truck
correctly, though this generally is not necessary with competent waste
transporters.

![](media/image9.bmp)

**2.7 Offering Hazardous Waste for Shipment Licensed Transporters, EPA
ID Numbers and Waste Manifests**

> **1.** You will **need** a licensed hazardous waste transporter to
> remove your
>
> hazardous waste.
>
> **2.** Your transporter **will provide** you with a manifest for each
> shipment, which
>
> may be preprinted, except for your signature.
>
> **3.** Make sure you check the manifest carefully for accuracy with
> regard to
>
> your EPA ID number, amount and type of wastes.

#### 

#### EPA Identification Numbers

An auto body shop must not generate, store, or offer for transportation,
hazardous waste without having received an EPA identification number.
Shops also must not offer its hazardous waste to commercial transporters
or to treatment, storage, or disposal facilities that have not received
an EPA identification number, and the Transporter must have a valid
Maryland Hazardous Waste Transporter Permit as indicated by an official
sticker on the vehicle. To obtain an EPA ID Number, contact MDE at (410)
537-3344 and indicate that you are requesting an EPA ID Number for
Hazardous Waste.

## 

## Hazardous Waste Manifests

Shipping hazardous wastes **requires** using a hazardous waste manifest.

**Hazardous Waste Manifest (See Figure Below):** An important tracking
document that makes it possible for you to show that your hazardous
waste has been disposed of properly. The transporter will sign for the
hazardous waste and leave a copy of the manifest with you. The disposal
facility will then send you a signed copy showing that they received it.
**You will need to keep both copies in your file for each shipment.**

Figure: Example of Hazardous Waste Manifest

![](media/image10.png){width="6.0368055555555555in"
height="6.486111111111111in"}

**2.8 Land Disposal Restrictions (LDRs)**

Hazardous wastes cannot be disposed of in a landfill unless strict
treatment standards are met. Liquid wastes are banned from land
disposal, so substances generated at auto body shops, such as
ignitables, are incinerated to meet the restrictions. LDRs have
paperwork requirements, so you must also review, sign, and keep a copy
of a document known as a Landfill Disposal Restriction Form, even if
your waste handler fills it out. If your waste is to be land-disposed,
you should make sure you staple your copy of this form to the manifest.

# Section 3.0- WATER ISSUES

Auto body shops can have an impact on the local water quality. When you
steam clean engines or wash cars you can send detergents, oil and grease
and other contaminants into the storm drains or other waterways. In
addition spills or leaks of anti-freeze, oil, other automotive fluids,
or even spilled cleaners can damage water quality if they are washed
down the drain instead of cleaned up properly. The best practices
section on page 21 has tips on how to clean the floors to minimize this.
Body shops face two main issues with water pollution: floor drains in
the shop floor and proper handling of water from washing vehicles.

**3.1 Floor Drains:**

> It is a **requirement** in Baltimore City and other jurisdictions for
> floor drains to be **sealed** to prevent spills from being discharged
> to the sanitary or storm sewer system.

**3.2** Vehicle Wash Water:

**1.** The discharge of vehicle wash water **requires a permit** if the
wastewater is

disposed of:

**a.** Onto the ground;

**b.** Into a subsurface disposal system such as a septic system or
seepage

pit; or

**c.** Into a surface water body or storm drain.

**2.** Disposal of vehicle wash water to the sanitary sewer requires an
agreement with the local wastewater treatment plant. This agreement is
known as a pretreatment permit.

**3.** You will be required to sample your wastewater discharge and have
it analyzed. The results of this analysis will determine what treatment
is necessary before you can discharge to the sewer system. Your permit
may require regular sampling and analysis to show you are complying with
the permit's conditions.

**4.** If you are washing cars, ask your supplier about soap metering
systems. Soap metering systems meter the appropriate amount of soap
directly into the washing system, thus significantly reducing your soap
usage and saving you

**5.** If you are part of a junk or salvage yard operation, you are also
required

> to obtain a storm water permit.

# Section 4.0- Best Practices 

Pollution prevention is based on the concept of preventing the creation
of waste instead of treating or disposing of waste. You may be able to
take steps to reduce the amount of waste you generate and these steps
may reduce your operating costs.

Not all the wastes are obvious and sent out as an individual waste
stream. Over-spray and misadjusted spray guns can generate waste paint.
The more paint that ends up on the car, the less that is wasted and
that's less that you have to buy.

Remember that neatness counts. Cleaning up any leaks or drips
immediately and using the proper containers and absorbents can help
prevent contamination of the environment. Keeping your shop clean and
organized is a good way to show you are concerned about the health and
safety of your employees and the environment. It is also a good idea to
check your environmental compliance on a regular basis. Using a
checklist like the one provided as part of this package is a good way to
stay in compliance with Maryland's environmental regulations.

## 4.1 How to Avoid Paint Waste

1.  The conditions of your air quality permit may require paint mixing
    units, which reduce paint waste. These paint mixing units also
    benefit you by stretching out the life of these expensive paints.

2.  Keep all materials in tightly closed containers.

3.  MDE recommends that you mix paint according to instructions in the
    amount needed for each job.

4.  Use extra mixed paint as undercoat for other jobs or give to the
    customer as touch-up paint.

5.  Keep records of paint use to show where too much paint was mixed for
    the job. Manufacturers, vendors and jobbers will have further
    information about these choices.

## 4.2 Good Storage Practices

1.  Waste paints should be stored in separate containers and clearly
    labeled for contents prior to recycling or disposal.

2.  Use proper tools and procedures to move drums-this will reduce the
    possibility of leaks and spills.

3.  Store materials like thinners, solvents, cleaners and other liquids
    in an area that has secondary containment. This will prevent any
    spills or leaks from contaminating your floors or drains and will
    make them easier to clean up.

4.  MDE recommends that you minimize the number and amount of stored
    materials.

5.  Computerized inventories can help you minimize waste.

6.  Use first-in-first-out (FIFO) policy to reduce storage time. This
    will reduce materials that are out of date.

## 4.3 Running a dry shop

A dry shop is one that uses no water or very little water to clean the
floors.

**How To Run a Dry Shop:**

> **1**. Do not wash the floors or use wet mops to clean up spills.

**2.** Clean up small spills with rags. Do not saturate the rags.

> **3.** If the spills are solvents or gasoline, use appropriate
> absorbents to clean
>
> the spill and dispose of the absorbents as hazardous waste.
>
> **4.** Use hydrophobic mops and absorbents to absorb oil. Hydrophobic
> mops do not absorb water.

### 4.4 Environmental Management Systems

Environmental management systems (EMS) help businesses identify and
manage their environmental impacts. Environmental management systems
(EMS) are simply a method for maintaining environmental compliance and
improving the environmental performance of your business. Rather than
looking solely at environmental regulatory requirements and how to
satisfy them, EMSs encourage organizations to identify environmental
impacts, set specific goals, train staff, and monitor performance. Small
businesses can benefit from this approach by communicating with
employees on environmental policies and goals and by using the EMS model
of continual improvement to track progress and improve operational
efficiency. In addition, the non-regulated aspects considered by EMSs,
such as energy, water and raw material consumption, greenhouse gas
emissions, solid waste, and non-point source pollution all present
opportunities to save money and prevent future liability.

Environmental management systems can range in difficulty, but most
systems have some elements in common. Even a small business can use some
of the elements of an EMS to improve their environmental performance.
The basic elements of an EMS for a small business could include:

-   A written environmental policy;

-   Waste minimization and recycling plans that are specific to the
    business;

-   Training on the program for new employees; and

-   A commitment to look for ways to continue to improve.