MANAGING HAZARDOUS WASTES
A GUIDE FOR AUTOMOTIVE MACHINE SHOPS
WASHINGTON STATE DEPARTMENT OF ECOLOGY
* * *
The Department of Ecology wishes to recognize the many automotive
associations listed on the back cover and the automotive
businesses who contributed their time and expertise in creating
this booklet.
While this booklet summarizes some of the requirements for
generators of automotive wastes under the Dangerous Waste
Regulations (Chapter 173-303 WAC), it does not replace them.
Always refer to the regulations themselves for more detail or
call a hazardous waste specialist at your nearest Ecology
regional office.
* * *
WHY SHOULD AUTOMOTIVE MACHINE SHOPS PAY ATTENTION TO THEIR
WASTES?
Automotive machine shops across the state regularly generate
hazardous wastes. Parts cleaning, machining and other activities
in your machine shop produce hazardous wastes such as spent hot
tank solution, dirty rinsewater, spent solvents and sludges from
all of these.
If improperly managed, these wastes may threaten the safety of
you and your co-workers, damage the environment, or put your
entire community at risk. Hazardous wastes can cause cancer and
nerve damage and pollute drinking water supplies.
Your role in protecting public health and the environment is
vital. Machine shop hazardous wastes don't belong on the ground,
down the drain or in the dumpster. Good hazardous waste
management practices are important for many reasons:
* You will ensure that you're in compliance with hazardous
waste regulations and avoid costly penalties.
* You may save money by finding ways to reduce or recycle your
wastes.
* You will be joining other machine shops in Washington state
that are taking pride in maintaining a clean and healthy
environment.
* You may gain customers who know they have made a wise choice
when selecting a shop that protects the environment.
* * *
AUTOMOTIVE MACHINE SHOP WASTES PRACTICAL DO'S AND DON'TS
Some common wastes generated by automotive machine shops are
described below, along with do's and don'ts for managing them
safely and in compliance with the regulations. Make sure you
find out what size of generator you are and what responsibilities
you have, beginning on page 14.
Spent Hot Tank Solution
Whether a dip tank or a spray cabinet style, hot tanks used for
cleaning oily/greasy parts aren't changed very often. When they
are, the sludge and tank solution typically become hazardous
waste due to heavy metal content and their corrosive nature.
Do's
* Extend "tank" life by pre-scraping buildup from large parts
or pre-cleaning with pressurized water. This may extend the
life of the tank by several months, but make sure the waste
water meets local sewer limits if it is disposal to the sewer.
* If you plan to evaporate hot tank solution to reduce weight
and volume, see discussion on page 10.
* Accumulate all sludge in a closed, marked container and
dispose of as hazardous waste.
* Cut down on amount of caustic wastes and long term costs by
using alternate methods of cleaning such as ovens.
Don'ts
* Don't dispose of spent hot tank solution down any drain or
on the ground.
* Don't put hot tank sludge into the dumpster on the ground.
* Don't forget to check with a regional Ecology hazardous
waste specialist (see back cover) if you want to neutralize
and/or separate metals from the solution.
Rinse Water and Rinse Water Sludge
Rinse water from parts cleaning and rinse water sludge is
typically hazardous because of heavy metal content. Excess oil
and grease is also a water quality concern.
Do's
* Reuse rinse water by using a recirculating spray cabinet
system with a filter.
* Add dirty rinse water as make up water in the hot tank (in
which case the rinse water isn't a waste).
* If you plan to evaporate hazardous rinse water to reduce its
weight and volume, see discussion on page 10.
* If any rinse water enters the sewer, get permission from
your local sewer utility - for example, if you take engine
parts out of a hot tank and hose them off directly to a
sewer drain.
* Close off any drains leading to storm sewers, dry wells, or
septic systems.
Don'ts
* Don't dispose of rinse water into any storm drain, septic
system or dry well. This can lead to water contamination and
liability problems for you.
* Don't put rinse water sludge into the dumpster or on the
ground.
* Don't forget to accumulate rinse water sludge in sturdy,
closed containers and dispose of as a hazardous waste.
_________________________________________________________________
Check with your sewer utility or city engineering department to
find out for sure where your drains lead - most outside drains
and some inside drains don't go to a sewage treatment plant, but
instead are storm drains that lead directly to a stream, lake or
ditch or to drywells which may contaminate ground water.
_________________________________________________________________
Aluminum Parts Cleaner
Often a 5-gallon bucket of carburator cleaner is used to clean
aluminum parts. This spent solvent, typically methylene
chloride, is toxic, persistent and carcinogenic. If another
solution is used, such as hot vat aluminum cleaner or a
multipurpose cleaner, the spent solution will still typically be
hazardous for heavy metals or corrosivity.
Do's
* Switch to a non-chlorinated solvent for aluminum parts
cleaning.
* Accumulate all sludge and dispose of as hazardous waste.
* Consider installing an affordable solvent recycling still,
or have a firm pick up your waste solvent for off-site
recycling.
* If you do use a chlorinated solvent, consider using the
dirty but still useable solvent in your valve tumbler or
elsewhere.
Don'ts
* Don't dispose of spent aluminum cleaner down any storm
drain, septic system or dry well.
* Don't dispose of spent aluminum cleaner, especially cold
tank carb cleaner, down the sewer.
* Don't put aluminum cleaner sludge into the dumpster or on
the ground.
Oven and Tumbler Residue
If you use an oven and tumbler to clean parts, the waste will
typically be hazardous due to heavy metals. Unless you have test
results that show otherwise, dispose of these residues as
hazardous waste.
Do's
* Determine through testing whether these wastes are
hazardous. (See page 10 for more information about testing.)
* Keep copies of test results.
Solvent Tanks and Other Solvents
Parts washer solvent tanks used for cleaning smaller parts and
tools are often provided by waste haulers. Solvents provided
include mineral spirits, Stoddard solvent, xylene, petroleum
naphtha, etc. and they become hazardous wastes the moment the
waste hauler exchanges the waste tank with a fresh tank. These
spent solvents are hazardous because they are ignitable and/or
toxic. Other solvents, such as those used for spot cleaning or
in valve tumblers, are typically hazardous too.
Do's
* Consider using less hazardous solvents or switching to a
spray cabinet parts washer that doesn't use solvent.
* Consider purchasing your own solvent still and recycling
solvent on site. (Sludges, filters and still bottoms
generated from on-site solvent recycling are typically
hazardous.)
* Make sure solvent is actually too dirty to use anymore
before it is exchanged for new solvent.
* If you recycle on-site, keep a log of dates, recycled
amounts and batch make-up amounts.
* Install a filter on your solvent sink to greatly increase
the life of the solvent.
Don'ts
* Don't dispose of spent solvents to drains, the air, or the
ground.
* Don't mix solvents with any other waste and keep different
types of solvents in separate, labeled, closed containers.
* Don't get solvents near used oil.
* Don't evaporate solvents as a means of disposal.
Machining Coolants and Sludges
Machining coolants and sludges created when honing or grinding
parts may or may not be hazardous, depending on the type of fluid
and parts machined It is the generator's responsibility to
determine if these wastes are hazardous.
Do's
* Use water-based coolants that don't contain chlorinated
compounds.
* Determine through your own knowledge or testing whether
these wastes are hazardous. (See page 10 for discussion on
testing.)
* If the sludge isn't hazardous, ask your scrap metal dealer
if they'll take the metal grinding wastes in it, along with your
filters.
* If you're using cutting oils when machining, ask your waste
oil handler if you can dispose of these to your used oil
container.
Don'ts
* Don't forget to keep copies of test results or waste
profiles.
* Don't put this sludge in the dumpster unless you know it
isn't hazardous.
* Don't forget to collect sludge in separate, marked
containers and dispose of properly if hazardous waste.
Glass Bead Dust and Steel Shot Residue
Because the nature of dust from glass bead blasters and residue
from steel shot machines varies from shop to shop, it is the
shop's responsibility to determine if these wastes are hazardous.
If they are, it will most likely be for high lead or cadmium
content.
Do's
* Determine through your own knowledge or testing whether
these wastes are hazardous. (See page 10 for discussion on
testing.)
* If hazardous, collect residue in a separate container and
dispose of as hazardous waste.
Don'ts
* Don't forget to keep copies of test results or waste
profiles.
* Don't put this waste in the dumpster unless you know it
isn't hazardous.
Used Oil
EPA's recent decision not to list used oil as a hazardous waste
means little change in the way machine shops in Washington state
need to manage used oil. Used oil isn't regulated as a hazardous
waste unless it has been mixed or contaminated with hazardous
wastes such as solvents, or it isn't recycled. (Recycling
includes burning for energy recovery.)
Do's
* Keep used oil in a separate container marked "USED OIL
ONLY".
* Place your container in a secure area and train your
technicians to keep it secure.
* Make sure used oil is tested to be "on spec" if you receive
(or give) oil for burning from another business.
* Keep records of used oil testing and shipments.
* If you're using an oil skimmer when cleaning parts, ask your
waste oil handler if you can add this oil to your used oil
container.
* Contact your nearest Ecology regional office (see back
cover) for guidance on used oil burners.
Don'ts
* Don't ever dispose of used oil to a storm drain, septic
tank, dry well, sewer or dumpster.
* Don't accidentally contaminate used oil by mixing it with
even small amounts of brake cleaner or carb cleaner. This
could turn the whole load into a hazardous waste.
* Don't pour used oil on the ground, even for dust
suppression.
* Don't mix used oil with incompatible wastes such as brake
fluid, power steering fluid or used antifreeze.
* Don't mix your used oil or "do-it-yourselfer" used oil with
any other waste if you plan to burn it in your shop for heating.
Shop Towels
If your shop towels are handled according to the advice below,
they do not need to be managed and counted as a hazardous waste.
If your towels are being disposed of they are hazardous waste if
they fail any hazardous waste tests (ignitable, toxic, etc.).
Do's
* Use cloth towels which can be cleaned and reused.
* When possible, use less hazardous cleaning solvents (ones
without chlorinated compounds).
* See if the laundry/recycling facility you use is meeting
local sewer discharge limits. Laundries/recyclers that discharge
their waste water to a drain field should be avoided.
* Keep waste shop towels in a closed container marked
"CONTAMINATED SHOP TOWELS ONLY".
Don'ts
* Don't throw dirty towels into your dumpster.
* Don't saturate towels. If you do, wring them out and reuse
the liquid.
* Try not to use disposable paper towels or rags.
* Don't dispose of solvents by pouring them into containers of
used shop towels.
Sump Sludges
Sludges from your sump or oil/water separator may be a hazardous
waste. You'll need to test the sludge at a professional
laboratory to determine if it is hazardous, or save the cost of
testing and assume it is hazardous and manage it accordingly.
Do's
* Have the sludge tested when pumped out (see page 10). Keep
test records.
* If the sludge is a hazardous waste, send it to a hazardous
waste management facility.
Don'ts
* Don't put hazardous sludge in the dumpster or on the ground.
* Don't use a septic tank pumping service to remove this
sludge. There is no legal, environmentally safe way for
these services to dispose of the waste if it is hazardous.
Floor Cleaning Waste Water
If floors are kept generally clean to begin with and a non-toxic
floor cleaner is used, wash water from floor cleaning shouldn't
typically be hazardous. However, wash water may contain heavy
metals and grease that need to be treated before discharging to
the sewer.
Do's
* Keep your floors clean to begin with. Catch leaks before
they hit the floor and place in appropriate waste container.
* Clean small, non-chlorinated spills immediately with
absorbent. Sweep and save for reuse until absorbing ability
is gone. It can then go in the dumpster (with local landfill
approval).
* Receive permission from your local sewer utility for your
floor cleaning wastes to enter the sewer.
Don'ts
* Don't use absorbants to clean-up chlorinated solvents and
then dispose to the dumpster. These are hazardous wastes.
* Don't let floor cleaning waste water go to an outside or
inside storm drain, dry well, or septic system.
_________________________________________________________________
Check with your sewer utility or city engineering department to
find out for sure where your drains lead - most outside drains
and some inside drains don't go to a sewage treatment plant, but
instead are storm drains that lead directly to a stream, lake or
ditch or to drywells which may contaminate ground water.
_________________________________________________________________
Paints
If you use spray cans to paint blocks and you use up the entire
can, they can be disposed of in the dumpster (with local landfill
approval). Cans that still have product in them should be
handled as hazardous waste; paint filters, overspray on paper,
and any chips/dust residue should not go in the dumpster unless
you're sure they are not hazardous waste.
Spent Rust Inhibitor
For those shops with a rust inhibitor dip tank, any spent
inhibitor is toxic and should be disposed of as a hazardous
waste.
IMPORTANT TOPICS
Evaporators
If certain conditions are met, evaporator units designed to
reduce the weight and volume of some wastes by removing water are
an allowable technology.
To use an evaporator, there are several things you need to do:
* Call a hazardous waste specialists at your nearest Ecology
regional office to discuss your particular evaporator use;
* Use only inorganic wastes in evaporator units. Inorganic
wastes that might be evaporated include spent caustics,
rinsewaters and water-based machining coolants.
* Don't use organic solutions, such as solvents, paints or
oils in evaporators;
* Leave some water content in the remaining sludge -- don't
"over cook" evaporator wastes;
* Dispose of remaining sludge properly -- it will typically be
hazardous;
* Include a comment on your Form 2 that you are a generator
evaporating waste;
* Report on your annual report (Form 4) the amounts of
hazardous wastes present prior to evaporation and the remaining
hazardous sludge.
Other things to consider include:
* Incorporating secondary containment around the evaporator to
catch a spill;
* Condensing evaporator steam and reusing it in your caustic
or rinse water tanks;
* Calling your local air quality authority to approve
evaporator use.
Testing
Sometimes sending a sample of waste to a laboratory for analysis
is the only way to determine if the waste is hazardous.
Important tests for machine shops include those for pH, volatile
organics, total petroleum hydrocarbons and heavy metals. If you
test a waste once, and continue to use the same industrial
process, you may apply those test results when designating future
batches of the same waste. For example, if you test your spent
machining coolant sludge once and find it to be non-hazardous,
you may use this knowledge for future disposal of this waste. If
you need testing done, request Ecology's Hazardous Waste Service
Directory or ask your association for help in locating a
reputable lab.
Pollution Prevention Planning Requirements
If you generate more than 2,640 pounds of hazardous waste per
year (this is an average of 220 lbs/month), you are required to
prepare a pollution prevention plan and pay a planning fee. (See
pages 13-14 to determine the amount of waste you generate.)
For more information, contact your nearest Ecology waste
reduction and recycling specialist at: Bellevue (206) 649-7000,
Olympia (206) 664-0475, Spokane (509) 456-6172 or Yakima (509)
575-2490.
WHY NOT REDUCE AND RECYCLE YOUR WASTES?
Reducing hazardous waste in your machine shop makes good business
sense. Reducing waste, before you generate it, can help you to:
* avoid longterm liability concerns associated with generating
hazardous wastes,
* save on hazardous waste management costs, and
* help create a healthier, safer work environment.
It may not be as hard as you think. A good place to start is to
walk through your shop and review all of the processes which use
toxic chemicals or generate hazardous waste. Pages 2 to 9 in
this book will help you determine which wastes are likely to be
hazardous.
As you consider each process, ask yourself if you can change the
process in some way so that it doesn't produce hazardous waste.
Some options to think about are:
Substituting a less toxic raw material
* Use pressurized water or initial preclean instead of caustic
jet spray.
* Use a non-chlorinated multi purpose cleaner to replace carb
cleaner for cleaning aluminum. Always ask for an MSDS before
ordering any new product. Biodegradable does not necessarily
mean environmentally safe, or that the product is exempt from
regulations. Safe products that are mixed with hazardous
substances, like oil or heavy metals, may need to be handled
as hazardous waste.
Use good operating practices
* Solvent losses due to evaporation, equipment leaks or spills
and inappropriate usage can range from 25-40%. Keep lids on
all dip tanks which use solvents. Use dirty solvent first
when cleaning parts. Increase drip time over tanks to allow
cleaning solutions to completely drain back into cleaning tank.
Change your process
* Investigate the use of an oven to bake off grease instead of
using a caustic hot tank. While this system may be a big
expense at first, it can save you money in the long run by
reducing your use of chemicals, hazardous waste disposal costs
and liability.
* Use a filter on parts washers to extend the life of the
solvent.
* Reuse spent rinsewater as makeup in your hot tank.
Recycle wastes and waste water which you can't reduce
* Contract for a recycling service to pick up used solvent.
* Consider an on-site distillation unit to recycle spent
solvents.
YOUR REQUIREMENTS AS A GENERATOR
Machine shops become Regulated Generators when they generate more
than 220 lbs. of hazardous waste per month or batch or ever have
more than 220 lbs. of hazardous waste on-site. Shops that
generate less are Small Quantity Generators. 220 lbs. is about
one half of a 55-gallon drum. Answer the following questions
about the amount of hazardous waste your shop generates to
determine your requirements as a generator. Remember: Solvents,
hot tank solutions and other substances are not wastes until the
day they are no longer usable.
HOT TANK SOLUTION & SLUDGE ______lbs.
(multiply the gallons of each batch disposed of x 8)
RINSE WATER AND RINSE WATER SLUDGE ______lbs.
(multiply the gallons of each batch disposed of
from a recirculating spray cabinet x 8 lbs/gallon)
RINSE WATER ______lbs.
(multiple the gallons of water per month sprayed
directly on parts that goes down a drain, or on
the ground x 8)
ALUMINUM PARTS CLEANER ______lbs.
(multiply the gallons of each batch disposed of x 12)
PARTS WASHER SOLVENT TANK ______lbs.
(multiply the gallons changed with each service
from waste hauler x 8)
OTHER SPENT SOLVENT ______lbs.
(multiple the gallons disposed of per month x 8)
OVEN AND TUMBLER RESIDUE ______lbs.
(pound of ash per month)
GLASS BEAD DUST OR STEEL SHOT RESIDUE ______lbs.
(pounds of dust per disposal, if hazardous)
SPENT COOLANTS AND SLUDGE ______lbs.
(pounds of sludge per disposal, if hazardous)
SUMP SLUDGES ______lbs.
(pounds of sludge per disposal, if hazardous)
PAINT WASTES ______lbs.
(pounds of hazardous waste by products per month)
SPENT RUST INHIBITOR ______lbs.
(multiply the gallons of each batch disposed
of x 8)
CONTAINERS OF KNOWN HAZARDOUS, UNKNOWN OR
UNMARKED CONTENTS ON THE PREMISES ______lbs.
(multiply the gallons on site x 8)
OTHER HAZARDOUS WASTES ON SITE ______lbs.
(pounds on site)
TOTAL __________
* If any one answer or combination of answers totals over 220
lbs., you are a Regulated Generator required to meet
compliance Steps 1-10 discussed below.
* You are a Small Quantity Generator if you always generate
less than 220 lbs. of hazardous waste per month or batch and
always dispose of the waste before you accumulate more than
220 lbs. Small quantity generators are required to comply
only with Steps 1 and 8 (and 3 if you already have an active
EPA/State ID Number).
STEP 1 -- IDENTIFY YOUR WASTE AND GENERATOR STATUS
You must determine if any of your wastes are regulated as
hazardous wastes by following the "designation" procedures in the
Dangerous Waste Regulations. First look for each of your wastes
on the Discarded Chemical Products and Dangerous Waste Sources
Lists in the regulations. This is where you'll find listed
wastes. Then, if the waste is not on the lists, determine if it
exhibits any of the hazardous waste characteristics
(ignitability, corrosivity, reactivity, leachability). Waste
mixtures (for which you know some or all of the constituents and
concentrations) must also be evaluated using available data to
see if they meet the criteria of toxicity, persistence, or
carcinogenicity.
To see how machine shop wastes fit into the state's different
hazardous waste categories, turn to page X (after Steps 1-10).
Determine your generator status (see pages 10-11). Request "Step
by Step" Fact Sheet #1 for more help in designating your wastes
(see page 19).
STEP 2 -- OBTAIN A GENERATOR IDENTIFICATION NUMBER
If you are a regulated generator, you are required to notify
Ecology of your hazardous waste activities and obtain a site-
specific EPA/State Identification Number using Form 2 (available
from Ecology). Many hazardous waste haulers and management
facilities are also required to have an Identification Number.
They may not accept your waste if you don't have an
Identification Number - even if you're a Small Quantity Generator
and aren't legally required to have one.
STEP 3 -- REPORT ANNUALLY
If you have an active EPA/State Identification Number, you must
submit an annual report (using Ecology's Form 4) by March 1 of
each year, even if you have not generated waste in that year.
Record your hazardous waste activities for the previous calendar
year on this report, including how much waste you've generated or
accumulated on-site and waste you've sent off-site.
To assist generators, Annual Report workshops are typically held
at various locations in the state in February.
STEP 4 -- PERFORM PREVENTIVE MAINTENANCE
Hazardous wastes must be handled in a manner that prevents leaks,
spills, fires and explosions. Develop and follow a written
inspection schedule for all hazardous waste storage areas,
containers and tanks and include all emergency, safety and
monitoring equipment on-site.
Keep the necessary emergency equipment (such as fire
extinguishers and telephones) on hand and accessible to
employees. You must regularly test and maintain all your
emergency equipment. Notify local authorities (such as police,
fire departments and local hospital) of the characteristics of
hazardous waste generated at your site, as well as the facility
layout and access routes.
STEP 5 -- PROPERLY ACCUMULATE HAZARDOUS WASTE
Machine shops that generate less than 2,200 lbs. per month or
batch can accumulate their hazardous waste for up to 180 days
from the date it is first generated before they must manage it
on-site or send it to an appropriate facility. Generators of
2,200 lbs. or more per month may only accumulate wastes for 90
days.
While accumulating your wastes, you must follow requirements for
safe and proper storage, labeling and management of wastes:
* Establish and clearly mark an accumulation area. Don't have
wastes scattered all over your shop. If constructed after
September 30, 1986, your accumulation area must have a
containment system, such as a diked concrete area, that is
capable of holding leaks and spills.
* Place the waste in an appropriate container and mark it
with:
- the words "Hazardous Waste" or "Dangerous Waste" (some
generators find it more convenient to use hazardous
waste labels);
- a label identifying the waste's major risk(s) (for
example, "ignitable"); and
- the accumulation start date (when you first put the
waste in the container).
* Comply with the requirements for preventive maintenance,
emergency planning and container management summarized in
Steps 4, 6, and 7 of the Guide.
STEP 6 -- PLAN FOR EMERGENCIES
There must be an emergency coordinator on the premises or on call
at all times who is familiar with the operations and activities
at the site and has the authority to commit the resources
necessary to deal with a hazardous waste emergency. In a small
shop, this will probably be the owner or manager.
Planning for emergencies can help prevent a small spill from
turning into a dangerous and expensive contamination problem.
Make sure you train your employees to know how to react to
different types of emergencies in your shop.
STEP 7 -- USE PROPER CONTAINERS AND MANAGE THEM CORRECTLY
Many hazardous waste incidents and work-related injuries are
linked to improper or unsafe container management. To avoid
these preventable accidents:
* Accumulate your wastes in containers which are sturdy,
compatible, leak-proof, properly labeled, and kept closed
unless waste is being added or removed;
* Do not accumulate incompatible wastes in the same container
or in the same areas;
* Store reactive and ignitable wastes according to the Uniform
Fire Code;
* Maintain a minimum aisle space of 30 inches between
container rows; and
* Inspect containers and storage areas at least once a week,
keeping a log of inspections.
STEP 8 -- ARRANGE FOR PROPER TRANSPORTATION AND DISPOSAL
As a generator of hazardous waste, you are responsible for
following regulations for the safe transportation and disposal of
your waste, even after it leaves your premises. Before
transporting hazardous waste off-site, you need to make sure it
is packaged, labeled and marked in accordance with U.S.
Department of Transportation hazardous material regulations.
Call (206) 753-6427.
Regulated Generators must hire a transporter that has an
EPA/State Identification Number and ensure wastes are handled at
a permitted hazardous waste treatment, storage or disposal (TSD)
facility or at a facility that legitimately recycles or reclaims
hazardous waste. Small Quantity Generators can transport their
own wastes or make sure they are sent to a:
* permitted hazardous waste facility;
* legitimate recycler;
* facility permitted to handle moderate risk waste; or
* a permitted solid waste facility, if allowed by the local
health department.
STEP 9 -- MANIFEST SHIPMENTS OF HAZARDOUS WASTE
To ship hazardous wastes off-site, Regulated Generators must
prepare a Uniform Hazardous Waste Manifest Form which identifies
the contents of the shipment, the transporters used and the
permitted facility receiving the wastes. This form accompanies
the waste from the site where it is generated to its ultimate
resting place and back to you for your records. If you are a
Regulated Generator your waste hauler needs to use a manifest and
not just issue a bill of lading or receipt.
Some hazardous wastes are restricted from land disposal unless
they meet specific treatment standards. If you send your waste
off-site for disposal, you must prepare and sign a certificate
which states that either your waste is not restricted from land
disposal or that it meets the treatment standards outlined in the
regulations. This land disposal restriction certificate is
attached to the manifest form for the shipment.
Often the waste hauler fills out these forms and you just sign
them. You should carefully check all information before signing.
If a signed return copy of the manifest has not been received
from the waste management facility within 35 days of the shipment
date, you must try to determine what has happened. Submit an
exception report documenting your efforts to Ecology if you have
not received the last copy of the manifest form within 45 days of
the shipment date.
STEP 10 -- KEEP RECORDS OF HAZARDOUS WASTE ACTIVITIES
There are a number of records, reports and forms machine shops
must prepare under the Dangerous Waste Regulations and keep on
the premises for at least five years, including annual reports,
manifest forms, exceptions reports, and land disposal restriction
certificates. Keep copies of notification reports (Form 2),
inspection records, results from waste analyses or tests, and on-
site recycling records for as long as you are in business.
MACHINE SHOP HAZARDOUS WASTES BY WASTE CATEGORY
The following table shows where typical machine shop wastes fall
in the state's hazardous waste categories. Your wastes may be
different, depending on the chemicals and processes you use.
Testing may be necessary to determine whether certain wastes are
hazardous.
Major Category Hazardous Waste Type Machine Shop Examples
_________________________________________________________________
Listed Wastes Discarded Chemical not typically generated
Products by machine shops
Dangerous Waste cold tank carb cleaner
Sources (methylene chloride)
other chlorinated
solvents
Characteristic Ignitable spent valve tumbler
Wastes solvent
Corrosive spent hot tank solution
and sludge
spent rinsewater and
sludge
Reactive not typically generated
by machine shops
Toxicity spent hot tank solution
Characteristic (TCLP) and sludge
spent rinsewater and
sludge
glass bead blaster dust
(possible)
grinding coolant sludge
(possible)
paint wastes
steel shot residue
(possible)
Criteria Toxic rust inhibitor
Wastes
Persistent methylene chloride from
aluminum parts cleaning
other solvents with word
"chlor" as part of main
ingredients
Carcinogenic methylene chloride in
carb cleaner
_________________________________________________________________
WHERE TO GET MORE HELP
It's your responsibility to safely manage wastes generated at
your facility. Don't be afraid to ask for help. Ecology can
help you keep up-to-date and in compliance with the regulations.
For additional information and assistance, contact the nearest
Ecology Regional Office and ask for a Hazardous Waste Specialist.
To receive any of the following publications, contact Ecology's
Publications Office at (206) 438-7472.
Clean Air Washington Information Packet
(1992, #FA 92-13)
Discussion on the Toxicity Characteristic Rule
(1990)
Ecology's Solid and Hazardous Waste Program
(1991, #91-BR-2)
Guide for Hazardous Waste Generators
(1990, #90-51)
Hazardous Waste - Helping Small Business Understand the Law
(1990)
Handling Hazardous Waste: A Resource Guide for Automotive Repair
Shops
(25p.)
Is Water Quality Going Down the Drain in Your Garage?
(1991, #91-BR-8)
Moderate Risk Waste: At Home, At Work
(1991, #90-BR-16)
Regulation of Hazardous Waste Being Recycled
(Feb. 1992, #91-46, 23p.)
Shoptalk,
a quarterly newsletter for hazardous waste generators
Step by Step: fact Sheets for Hazardous Waste Generators,
includes Glossary, Subject Index, and Services Directory
(1991, #91-12a-S)
Success Through Waste Reduction - Proven Techniques from
Washington Businesses
(1990, #90-22)
The Dangerous Waste Regulations
(Chapter 173-303-WAC)
Vehicle Repair Tool Box Guide to Hazardous Waste Management
(1992, 30p.)
Waste Reduction for Your Business
(1989, 32p.)
Waste Reduction for Vehicle Maintenance Shops
(Feb. 1992, 25p.)
DEPARTMENT OF ECOLOGY REGIONAL OFFICES
Northwest Regional Office
3190 160th Avenue SE
Bellevue, WA 98008
(206) 649-7000
Southwest Regional Office
7272 Cleanwater Lane
P.O. Box 47775
Olympia, WA 98504-7775
(206) 753-2353
Central Regional Office
106 S Sixth Avenue
Yakima, WA 9989022-3387
(509) 575-2490
Eastern Regional Office
North 4601 Monroe
Suite 100
Spokane, WA 99205-1295
For questions relating to waste reduction and recycling tips and
techniques, you can call 1-800-RECYCLE. Information is available
on equipment, services or process changes that can help you
reduce and recycle your hazardous waste.
You can also get help for specific waste reduction problems in
your facility by calling your nearest Ecology regional office and
asking for a toxic reduction specialist. (See phone numbers
above.)
Automotive Service Association
Autobody Craftsman Association
Washington State Auto Dealers Association
Auto United Trades Organization
Washington Automotive Wholesalers
Northwest Tire Dealers Association
Automotive Engine Rebuilders Association
Production Engine Remanufacturers Association
National Automotive Radiator Service Association
Last Updated: March 31, 1997