'MRCC offers the Small Business Technicat flssistance Frogram WWP) because small businesses have trouble finding and umlerstand'mg environmental rules. Smalf businesses with tewer than 100 employees can receive free, confidential services and information by contacting the SBTAP office.

Small Business Technical Assistance Program Texas Natural Resource Conservation Commission P.O. Box 13087 Austin, Texas 7871 1-3087 Hotline 1-800-447-2827 Phone (512) 239-1064 Fax (512) 239-1055

Please note that this guide provides an outline of certain environmental requirements that may affect an autobody shop and is not intended to Offer legal advice. This guide is intended as advisory guidance only and is not intended as a substitute for reading the law or regulations.

his booklet is a guide to what Texans in the autobody WHY DO I NEED THIS business need to know to keep our air, water and soil clean BOOKLET? and to comply with state and federal laws. It was produced

by the Texas Natural Resource Conservation Commission’s Small Business Technical Assistance Program, or SmAP which was created to provide help to businesses like yours. You may deal with the SBTAP in confidence. The information you share with us and the questions you ask will not be provided to any regulatory or enforcement program.

Pollution is one of the nation’s primary health and environ- mental concerns. A significant amount of pollution in Texas is created by small businesses. New state and federal laws are aimed at reducing your contributions to that pollution problem, thus you may need to do more than you are currently doing to comply with the law.

Complying with the law is not a choice - i t j your responsi- bility Failure to comply may subject you to penalties. Let us help you avoid those penalties by providing the information you need. And remember, a clean operation means better health for you, your employees and your community

We also o a r tips about how to reduce or prevent pollution. These tips could help you save money or reduce your emissions to the point that pollution laws don’t f i c t you.

You may find after reading this booklet that you need addi- tiond information. We have provided a postage-paid reply

HOW CAN I GET THE INFORMATION I NEED?

card to help you request the relevant publications and a toll- free telephone number in case you have specific questions that aren’t answered here.

Several air regulations relating to permits may apply to auto- body shops. One kind gives permission to construct or modify a facility If you meet certain sets of requirements, you may be able to claim a formal exemption from this permitting process. Another kind lists the fkderal requirements under which the hcility must operate. Federal air permits are discussed in a later section. To find out more about state air permits, read below.

WHAT AIR REGULATIONS APPLY TO ME?

DO YOU HAVE ANY AIR PERMITS NOW? If you already have a “Permit to Construct” be sure to read

1

DO VOLUME OF BUSINESS AND GROSS SALES HAVE

ANYTHING TO DO WITH MY NEED FOR AN AIR PERMIT?

DO I NEED STATE AIR PERMITS?

WHAT IS A STANDARD EXEMPTION?

carefully the section on what to do if you plan to modify or change your facility

If you do not have any permits, read ALL of the following information.

No. The date of construction or the date of the last change you made to your faciity or your processes and the amount of chemicals you use in your processes will determine if you need a permit.

WAS YOUR FACILITY IN OPERATION BEFORE 911 /7l ? If your facility was in operation bqbe September I, 1971 and you can prove that you have not modified or changed any methods of operation, then you may want to claim that your facility is grandfithered (exempt) from permit requirements. If you are interested in more infbrmation about what you need to do to claim that you are grandfathered ... CALL US at 1-800-447-2827

If your facility was in operation before September I, 1971, and you HAVE modified or changed any method of operation since that date, then you need to meet the same requirements as if your facility began operating after 9/1/71. Your facility will need a permit OR it may qualify for one or more standard exemptions.

Read on for more about Standard Exemptions.

DID YOUR FAGIUTY BEGIN OPERATION AFTER 911 /7l ? If your facility began operation after September 1, 1971, then you need to meet certain requirements for controlling air emissions. Your facility will need a permit OR it may qualify for one or more standard exemptions.

Read on for more about Standard Exemptions.

A standard exemption o&rs an alternative to the air permit process for businesses that are constructed and operated under certain conditions. When a business commits to these condi- tions, the facility will not be making a significant contribution to air pollution and thus does not require a permit.

e

Most small businesses try to meet the conditions of standard exemptions instead of going through the more complex and costly permit process. However, your facility may not qualify b r a standard exemption, or may qualify for standard exemptions for some operations and need a permit for others.

Claiming TNRCC standard exemptions does not mean that a facility isn’t required to comply with all other fideral, state and local air laws or other environmental regulations. Standard exemp- tions simply exempt you from having to obtain an air permit.

If you meet the conditions of a standard exemption, then you can “claim” that exemption. Some of the standard exemptions require you to register your claim by filling out a TNRCC form. Other standard exemptions do not require a form but you are responsible for keeping records that verify your claim that your facility meets the conditions.

WHAT IF I AM NOT ABLE TO CLAIM A STANDARD EXEMPTION? If you don’t meet the conditions of a standard exemption, you may not claim the exemption. You must modify your facility to meet the exemption or obtain a permit. After you have requested and received detailed information about the standard exemptions described below, you will be instructed about how to apply for a permit if you find that you can’t claim the exemptions.

Also, if you are a Major Source of Volatile Organic Com- pounds, or VOCs, you may not claim a standard exemption. If you use more than 4,000 total gallons of chemicals, you may be a major source of VOCs. Read on for more information about Major Sources. If you think you “ught be a Major Source, ask SBTAP to help you calculate your yearly emissions of VOCs.

An autobody shop may want to pursue several standard exemp- tions, depending on the kind of operation, location, volume of chemicals and other fictors. These questions will help you find out what standard exemptions you may want to look at further.

DO YOU PAINT OR REFINISH CARS, VANS, UGHT OR HEAVY TRUCKS, MOTORCYCLES OR OTHER VEHICLE BODY PARTS, BODIES OR CABS? If you have not already claimed a standard exemption or obtained a permit for these operations by May 3, 1994, you may claim the standard exemption for autobody shops if you meet all the conditions. Even if you have already claimed another

WHAT STANDARD EXEMPTIONS MAY APPLY TO MY BUSINESS?

8

standard exemption, you may want to claim the new autobody shop standard exemption because it could reduce your paperwork. If you are interested in the conditions you must meet fbr these operations ... ASK FOR INFO - STANDARD EXEMPTION 124

If you have already claimed and qualified for Standard Exemp- tion 89 befbre March 15,1985 or for Standard Exemption 75 before May 4, 1994, you may continue to operate until you plan to make changes in your operation or ficility that do not meet the conditions of these standard exemptions. However, you have until December 31,1994 to look at the new Standard Exemption 124 and choose to claim it instead. You may find that Standard Exemption 124 reduces your record- keeping requirements. If you are interested in what conditions you had to meet to qualify for these exemptio ns... ASK FOR INFO - STANDARD EXEMPTION 75 (ifoperating before May 4,1334) ASK FOR INFO - STANDARD FXEMPTION 89 (if operating before March 15,1985).

DO YOU USE HAND-HELD OR MANUALLY OPERATED EQUIPMENT FOR: buffing, polishing, carving, cutting, drilling, machining, routing, sanding, sawing, surfice grinding or turning of ceramic art work, ceramic precision parts, leather, metals, plastics, fiber board, masonry, carbon, glass, graphite or wood? If you are interested in what conditions you must meet to qualify for a standard exemption to use this equipmen t... ASK FOR INFO - SWDARD EXEMPTION 40

DO YOU DO MECHANICAL WORK ON ENGINES OR TRANSMIS- SIONS, OR DO PARTS WASHING OR OTHER DEGREASING OPERA- TIONS IN ADDITION TO PAINT AND BODY WORK? If you are interested in what conditions you must meet fbr these operatio ns... ASK FOR INFO - STANDARD EXEMPTION 107

DO YOU USE POLYESTEWSTYRENE CO-POLYMER RESINS, STYRENE MONOMERS OR ACETONE FOR REPAIRING FIBERGLASS BODIES? If you are interested in what conditions you must meet fbr using these sub stances... ASK FOR INFO - STWDARD ExEMMloN 113

DOES YOUR FACILITY DO ABRASIVE BLAST-CLEANING OPERATIONS INDOORS OR OUTDOORS? If you want details on the conditions you must meet to

4

qualify for a standard exemption br these operation s... ASK FOR INFO - STANDARD ExEhilMlON 102

WHAT HAPPENS IF I 6ET THE DETAILED INFORMATION ABOUT STANDARD EXEMPTIONS AND DISCOVER THAT I DON’T MEET THE CONDITIONS NECESSARY TO CLAIM THE EXEMPTION? You will then be directed to more detailed information about how to modify your facility to meet the conditions of the stan- dard exemption or how to obtain a permit for your operations.

There are several types of kderal air permits required of busi- nesses that federal rules define as “major sources.” In addition to getting a Federal Operating Permit, a Major Source may be requkd by other fided regulations to meet certain control requirements.

To be a Major Source, a facility must use large amounts of substances listed as hazardous air pollutants, or HAPS, or emit large amounts of volatile organic compounds, or VOCs, from the paints it uses. Most autobody shops do not use enough paints, coatings or solvents to qualify as a “Major Source” in either category

However, you should look at your operation to determine your situation.

DO ANY OF YOUR COATIN68 CONTAIN THESE HAZARDOUS AIR POLLUTANTS? w methanol w toluene

xylene w methyl isobutyl ketone (MIBK) w ;ethyl ethyl ketone (MEK) w methylene chloride and 1-14 trichloreoethane w phenol

ethyl benzene w glycol ethers w styrene w hexane If you use at least 20,000 pounds (3,000 or more gallons) per year of materds containing these pollutants, you may need to know more about how to calculate the exact amount that would make you a “Major Source” of hazardous air pollutants. Ifyou use these amounts... ASK FOR INFO - MAJOR SOURCE H A P S

DO I NEED A FEDERAL AIR PERMIT?

5

DO YOU USE A TOTAL OF AT LEAST 50,000 POUNDS (4,000 OR MORE GALLONS) OF CHEMICALS EACH YEAR? If you use a total of at least 50,000 pounds (4,000 or more gallons) of all chemicals each year, you may need to know more about how to calculate the exact amount that would make you a “Major Source” of volatile organic compounds. If you are using any chemicals in the amounts above... ASK FOR INFO - MAJOR SOURCE VOC

DO DIFFERENT LIMITS APPLY TO DIFFERENT

COUNTIES?

“If you can smell it, there are pollutants going into the air.” This is a simple statement that describes what happens when

you paint or use certain chemicals. You emit what scientists call volatile organic compounds, or VOCs. VOCs contribute to air pollution. In counties where the air pollution has already reached excessive levels (called non-attainment areas) the limitations on VOCs are more severe. Those limitations may include paint VOC content, spray gun types and gun cleaners.

ARE YOU LOCATED IN ONE OF THESE COUNTIES? w Brazoria* Harris*

Chambers* w Jegrson w Collin w Liberty*

Dallas w Montgomery* w Denton Nueces

El Paso w Orange Fort Bend* m-krarlt

w Galveston* Victoria Greg w Waller*

w

If yes, there are special limitations and regulations that apply to you. THESE SPECIAL LIMIVCIONS APPY TO THESE

TIONS OR PERMITS YOU MAY HAVE BEEN GRANTED. THEY APPY EVEN IF YOU ARE GRANDFATHERED. Ifyour business is located in one of these counties...

COUNTIES R E W L E S S OF ANY STANDARD EXEMP-

ASK FOR INFO - NON-ATTAINMENT REGULATION V

*In addition, if your hcility is located in the Houston area, in one of the counties noted with an asterisk? additional special requirements may apply to you. For Srmation on requirements br living or working in these counties... ASK FOR INFO - NON-AlTMNMENT GENERAL

Many of the permits and standard exemptions require that you keep records to verify your compliance with them. Each of the specific information packages we provide includes record- keep- ing instructions related to any standard exemption or permit. If you have any questions about what records you should be keeping.. CALL US AT 1-800-447-2827

The General Rules of TNRCC provide guidance on how every business can control air pollution. The following rules apply to the autobody industry:

Don’t Be a Nuisance Your facility is not allowed to create emissions, including odors, that adversely affect human health or welfae, animal life, vegetation or property

You must maintain pollution control equipment in good working order and operate it properly Notify TNRCC at least 10 days before any planned maintenance, start-up or shutdown that wdl cause excessive emissions. Technical plans for maintenance activities may be requested by TNRCC.

If your facility uses at least 3,500 gallons of chemicals per year, you may have to report emissions to TNRCC. As with some of the other requirements, the county in which your business is located will determine what level of emissions you must report.

Good Housekeeping and Maintenance

Emissions Inventory Requirements

If you need to know more about these general requirements ... CALL US AT 1-800-447-2827

WHAT RECORDS DO I NEED TO KEEP?

WHAT GENERAL TNRCC STATE REGULATIONS APPLY?

W Your facility must not give off visible emissions or fine parti- cles of matter, such as from paint spray or sandblasting. If t h s type of matter can be seen coming from your facility, you need to know more about how these emissions are regulated. If you need to know more about visible emissions and particulate matter... CALL US AT 1-800-447-2827

7

WHAT IF I PLAN TO If you plan to change any process, method of operation or , I ” * I

MAKE CHANGES TO MY OPERATION?

equipment, you must first consider if you can still meet a11 the conditions of your standard exemption or permit. Changes may trigger the need for a permit or permit amendment. When you need information on how these proposed changes might a f k your status... CALL US AT 1-800-447-2827

WHAT IF I’M IN VIOLATION?

WHAT SHOULD I DO IF I DISCOVER THAT I HAVE VIOLATED THE LAW IN THE PAST OR THAT MY CURRENT OPERATIONS ARE IN VIOLATION OF THE LAW? You should notify TNRCC as soon as possible. It is always better to report your own violations than to be the subject of a complaint or to have violations be discovered during an inspec- tion by TNRCC. In many instances, small businesses will not face fines or sanctions for their first violation if they make good hth efforts to report problems as soon as they are aware of them and if they develop a TNRCC-approved plan to correct the problems. FOR CONmDENTIAL ASSISTXNCE CALL 1-800-447-2827

WHAT DO I DO WITH UNUSED CHEMICALS.

COATINGS AND’ WASTE MATERIALS?

This section will take you through a step-by-step procedure for hazardous waste management. By following these steps, you ensure that your business complies with federal and state haz- ardous waste laws and you help your business to do its share to protect our state‘s natural resources. After following the steps described in this section, you should be able to answer two basic questions about your waste activity: “Do I produce hazardous waste?” and, if the answer is yes, “How much hazardous waste do I produce?” The answers to these two questions will tell you what requirements apply to you.

DO I PRODUCE HAZARDOUS WASTE?

The term “hazardous” means more than just toxic or dangerous to our health. It also refers to specific kinds of waste defined as hazardous by the Environmental Protection Agency. Hazardous wastes are regulated by the EPA and TNRCC, so it is important to know which wastes are hazardous.

A facility (which can be a one-person operation or a com- pany of any size) that produces hazardous waste is rekrred to as

8

a hazardous waste “generator.’) The law holds the generator responsible for determining whether or not hazardous waste is generated at his or her facility Before you can determine if your facility generates hazardous waste, you must first know what a “waste’) is. A waste is any solid, liquid or contained gas that you no longer use and that you either recycle, throw away or store until you have enough for treatment or disposal. A hazardous waste is any waste that possesses one or more physical “characteristics” defined in the law as hazardous or that is “listed” as a hazardous waste in the EPA regulations. Listed wastes are considered the most toxic. The distinctions between listed and characteristic are important to you, the generator, only for the purpose of identifying the waste. As an autobody shop, you probably produce characteristically hazardous waste, but may also produce listed waste. A waste can be both listed and characteristically hazardous.

The generator is responsible for looking at each waste gerierated at the facility and determining if it is hazardous or not. This can be done in one of three ways:

1. Compare the waste to the EPA list and to the EPA-defined characteristics for hazardous waste.

2. Use your knowledge of the waste and what went into it to compare the waste to the lists and characteristics. Th~s method is called “process knowledge,)’ and you may use any information you have including product labels, etc.

3. Arrange for a chemical analysis to determine whether the waste is hazardous or not.

Some e%rt and possibly some expense are required to make a hazardous waste determination on each waste. However, this determination only has to be done once. A new hazardous waste determination does not have to be done unless a new waste is generated.

WHAT ARE LISTED AND ACUTELY HAZARDOUS WASTES? More than 400 discarded chemical products and wastes from specific processes are listed as hazardous wastes in the EPA regu- lations. If your waste appears on one of these lists, or is mixed with any of the wastes on these lists, it is hazardous. Examples are certain degreasing solvents like carburetor cleaner, some pes- ticides, certain paint thinners (depending on their ingredients) and specific manufacturing wastes. This list also includes many

9

“acutely” hazardous wastes like sodium cyanide. If you generate any of these kinds of waste, you have hazardous waste. To obtain a description of listed wastes... ASK FOR INFO - LISTED HAZARDOUS WASTE

10

WHAT ARE CHARACTERISTIC HAZARDOUS WASTES? Wastes that have one or more of the following characteristics: ignitability, reactivity, corrosiveness or toxicity, are considered characteristic hazardous wastes. Examples are paint wastes, cer- tain paint thinners (depending on their ingredients), degreasing solvents and battery acids. If you generate any of these kinds of wastes, you have hazardous waste. To obtain a description of characteristic waste... ASK FOR INFO - CHARACTJWSTIC HAZARDOUS WASTE

Automotive shops and paint and body shops typically generate hazardous wastes. Examples of these wastes are: batteries to be disposed 06 carburetor cleaner, gasoline, parts cleaning solvent, paints, paint wastes and thinners. If you generate any of these wastes, you have hazardous waste and you must continue read- ing. 16 however, you determine after comparing all your wastes to the listed and characteristic wastes, that your business does NOT generate hazardous waste, you do not need to proceed further into this section, because you are not subject to any hazardous waste laws.

WHAT 1s MY GENERATOR STATUS?

The next step is to determine how much hazardous waste you generate per month by adding together the quantities of each kind of waste generated each month. A monthly average is sufficient if the amounts vary from one month to the next.

Your ‘generator status” rekrs to how much hazardous waste your business produces per calendar month. The amount you produce determines what requirements apply to you. There are three kinds of hazardous waste generators, depending on the amount of hazardous waste generated. In general, Conditionally Exempt Small Quantity Generators, or CESQGs, do not have to notify or report to a regulatory agency but Small Quantity Generators, or SQGs, and Large Quantity Generators, or LQGs, must report to a regulatory agency Most automotive and body shops will fall into the category of either CESQGs or SQGs.

WHAT IS A CONDITIONALLY EXEMPT SMALL QUANTITY GENERATOR? CESQGs generate no more than 100 kilograms of hazardous waste (220 pounds or about one-half of a 55-gallon drum of liquid waste) and no more than one kilogram (one quart) of “acute1y”hazardous waste per month. Ifyou are a CESQG, you do not have to notify, register or report to the EPA or TNRCC, as long as you do not store more than 1,OOO l u l o p s (2,200 pounds) on site at any one time. Simply have your waste picked up by a hazardous waste transporter who is registered with the state. Note: Many transporters will not accept your waste unless you show them EPA and TNRCC registration numbers, regardless of your generator status. If you do not have registration numbers, simply use “CESQG” as your TNRCC registration number and EPA i.d. number so that the transporter can fill out the paperwork. If you have any questions or need to contact an approved transporter. .. CALL US AT 1-800-447-2827

WHAT IS A SMALL QUANTITY GENERATOR? SQGs generate between 100 kilograms of hazardous waste (220 pounds or about one-half of a 55-dlon drum of liquid waste) and 1,000 kilograms (2,200 pounds or about five 55-gallon drums) and no more than one kilogram (one quart) of “acutely” hazardous waste per month. SQGs may accumulate up to 13,200 pounds of hazardous waste and store it on site for as long as six months before it must be hauled off-site by a registered transporter.

WHAT IS A LARGE QUANTITY GENERATOR? LQGs generate at least 1,000 kilograms of hazardous waste (2,200 pounds or about five drums of liquid waste) and more than one kilogram (one quart) of “acutely” hazardous waste per month. A LQG may accumulate any amount of hazardous waste on site but may only store it br up to three months befbre it must be hauled off-site by a registered transporter.

DO I HAVE TO NOTIFY THE STATE ABOUT MY HAZARDOUS WASTE? If you decide, based on the quantity of hazardous waste you generate each month, that you are a Small Quantity Generator or a Large Quantity Generator, you must notify the EPA and TNRCC about your hazardous waste activity I t however, you are a Conditionally Exempt Small Quantity Generator, you are exempt from notification requirements. Notification involves filling out specific forms and assigning “waste codes” to each waste you produce. Waste codes are numbers that physically describe the wastes.

11

12

For specific instructions about how to notify and assign waste codes. . .

All generators of hazardous waste (CESQGs, SQGs and LQGs) must continue reading for storage and disposal requirements.

ASK FOR INFO - NOTIFICATION AND WASTE CODES

HOW Do I STORE AND DISPOSE OF

HAZARDOUS WASTE?

HOW MUCH WASTE CAN I STORE AT MY FACILITY? w If you are a CESQG, you may store up to 1,000 kilograms (2,200 pounds or about five drums of liquid) on-site for an unlimited amount of time.

W If you are a SQG, you may store up to 6,000 kilograms (13,200 pounds or about 30 drums) on-site for up to six months.

W If you are a LQG, you may store any amount of waste on-site, but you must have a registered hazardous waste transporter dispose of it within three months from the initial date of storage.

No matter how much waste you are allowed to store on-site, you must comply with certain storage laws relating to the con- tainers and physical conditions of the wastes. The purpose of these “container rules” is to ensure maximum satkty for your staff and to protect the areas surrounding the wastes. To obtain specific infbrmation about how to store waste ... ASK FOR INFO - STORING AND DISPOSING OF HAZARDOUS WASTE

HOW DO I DISPOSE OF HAZARDOUS WASTE? Do NOT dispose of hazardous waste yourself; unless you have an EPA permit allowing you to do so. TO ensure that your haz- ardous waste is properly disposed of; you must choose a regis- tered hazardous waste transporter (who will haul the waste) and a permitted waste management facility (that will treat or dispose of it). Many companies provide both services to generators. The most important things you should remember about having your waste shipped off-site for disposal are:

w Choose a transporter and facility that have EPA and TNRCC identification numbers.

w Package and label your wastes properly for shipping.

w Complete the EPA form titled “Uniform Hazardous Waste h f k s t , ” which must accompany the waste shipment from your facility to disposal.

To obtain inbrmation about transporters, labeling and manifedng ... ASK FOR INFO - STORING AND DISPOSING OF HAZARDOUS WASTE

Note: Autobody shops should be careful not to dispose of used automotive engine oil or used oil filters with regular trash that goes to a landfill. It is now illegal in Texas to dispose of automo- tive oil or filters in landfills. Most autobody shops already have arrangements with a transporter to dispose of used oil. You should also make arrangements to properly dispose of used oil filters. If you do not have a waste oil transporter or another appro- priate method to dispose of used oil, or if you need help finding a transporter or collection center h r used filters ... CALL US AT 1-800-447-2827

Most autobody shops do NOT need hazardous waste permits. Permits are issued to Treatment, Storage, Disposal facilities, or TSDs. Remember, if you are a Small Quantity Generator or Large Quantity Generator, you need a registration to produce the waste, but not a permit. A permit is permission from the EPA and TNRCC to store, treat or dispose of your waste on your facility’s property in quantities and fbr time periods that exceed what your generator status allows. You do not need a hazardous waste permit unless you do any of the following:

store your waste longer than your generator status allows;

treat your waste in an attempt to remove its hazardous characteristic in an open container or;

dispose of your waste on your facility’s property.

To obtain information about hazardous waste permits ... CALL US AT 1-800-447-2827

DO I NEED A WASTE PERMIT?

For additional information regarding hazardous waste management and how you can comply with the laws affecting you ... CALL US AT 1-800-447-2827

&y water waste that your business generates, like water from washing vehicles, cooling water or any other water that is an end result of some process, is a waste. As stated earlier, you must make a hazardous waste determination about all of your wastes, using one or more of the three methods described. Dirty water from washing vehicles is probably non-hazardous and can be

WHAT DO I DO WITH DIRTY WATER?

13

14

discarded into the sewers. I t however, you know that you just washed a vehicle or some equipment that was contaminated with a hazardous waste (such as leaded gasoline or wet paint), you must either assume it is hazardous or run lab tests to prove it is not. If you find that you have a water waste that is hazardous, you must follow the procedures for managing hazardous wastes.

Do NOT dump any hazardous waste into any drains or sewer systems unless you have contacted your local wastewater utility and obtained authorization to do so. Some wastes are harrnfd to the collection system and the treatment plant, are not treatable or may be harmful to people working on the system or at the plant.

DO 1 NEED A TEWATER PERMIT?

Typical autobody and paint shops do not discharge wastewater and do NOT need a permit to do so.

You do not need a wastewater permit unless you do any of the following:

discharge pollutants from any source like a pipe, ditch, channel, tunnel or well, into the waters of Texas;

own or operate any facility that treats domestic sewage;

own or operate a farm, fish hatchery or any animal feeding facility

To get information about wastewater permits ...

For additional information about hazardous waste management and how you can comply with the laws

CALL US AT 1-800-447-2827

&&g you ... CALL US AT 1-800-447-2827

WHAT IS A POLLUTANT? A pollutant is anythmg whose release into the environment

HOW CAN I PREVENT POLLUTION? . . . ^ ^ . -

could cause harm to an organism or its offspring. Some auto- body shop examples are toxic and ignitable hnners, toxic paint and primer wastes, paint sludge, oil- and solvent-contaminated rags, oil filters, engine and hydraulic fluids, antifreeze and corro- sive waste. The improper disposal of any of these substances into a drainage system or into the air is considered pollution.

WHAT DOES POLLUTION PREVENTION MEAN? Pollution prevention means that pollution should be prevented or reduced at the source whenever possible. By “reduced at the

source,” or source reduction, we mean limiting or stopping pollutants before they go into the environment, thus reducing danger to public health and the environment.

WHY SHOULD I BE CONCERNED ABOUT POUUTION PRWENTION? Pollution prevention is a concern for everyone, including small businesses. By reducing or stopping pollution at its source, you should be able to substantially reduce your costs for materials, pollution controls and liability At the same time, you will reduce risks to your workers’ health and s h t y

You should also be able to reduce substantially your costs by reducing or avoiding regulations. As a general d e , the more you reduce your pollution, the fewer regulations apply to you and the less time you must spend dealing with the government.

Also, on January 1,199Z all small quantity hazardous waste generators will be required to have a source reduction and waste minimization plan.

HOW CAN I PREVENT POLLUTION? Just by asking the question, you have started on the road to cleaning up our environment. The following pointers may help; they have guided many businesses in developing a pollution prevention plan.

1. Identify and evaluate your sources of pollution.

2. Look at short-term and long-term options for preventing pollution. The usefulness of any prevention option will depend on its cost, the degree of environmental hazard the pollutant poses, the potential liability the pollutant represents and your ability to finance improvements.

3. Calculate your current costs for controlling or managing pollutants and compare them with costs to reduce or prevent pollution from each source. By linking prevention costs to the source of pollution, rather than treating these costs as overhead, you can pinpoint which prevention measures will make the most economic sense.

4. Implement a pollution prevention plan that will yield the greatest benefit. Include practices that eliminate the most hazardous pollutants, that reduce the overall amount of pollutants or that reduce or eliminate the pollutants most expensive to manage.

5. Develop record keeping and fdlow-up procedures to track the effectiveness of your plan. Good records of your progress will enable you to share news of your success with the commu- nity (your customers) and to recognize employees who’ve

15

contributed to the prevention effort. Good record keeping will also prepare you to respond to any reporting requirements of state and fideral agencies.

6. Re-assess your operations periodically to identify new opportunities to prevent materials from becoming pollutants. These may include recycling, substituting raw materials or making process or equipment changes.

Z Evaluate the efkctiveness of your pollution prevention plan by conducting a periodic review of its results.

As you develop pollution prevention strategies for your busi- ness, remember:

Pollution prevention starts at the top with YOU, the business owner. Your example will set the tone for your employees. If you're enthusiastic, they will be too.

Your employees will probably be your best resources for preventing pollution. Educate them about your goals and then brainstorm for ideas on how to reduce or eliminate sources of pollution.

This will be a continuous process.

CAN I GET HELP WITH MY POLLUTION

PREVENTION PLAN?

Yes. The Small Business Technical Assistance Office has auto- body shop pollution prevention guides created just for you. Our work is done at no charge and is confidential. CALL US AT 1-800-447-282%

WHAT OTHER ENVIRONMENTAL RULES

MGHT APPLY?

There may be local, city and county agencies that require registrations, inspections, certificates of occupancy, business licenses, etc. Be sure to check with your local fire department. You should be familiar with OSHA (Occupational S&ty and Health Administration) standards as well.

DOES THIS PACKET No, h s booklet is intended as a general guide to state and fid- _ _ _ _ ~~~~-

INCLUDE ALL THE INFORMATION I NEED

To 'ITH additional materials. We have provided a postage-paid reply

eral environmental laws that apply to yo; business. A careful reading of the information found here may reveal that you need

card to help you request additional information. If you have any THE LAW? questions that are not answered here, or if you have questions about any of the information found in this booklet ... CALL US AT 1-800-447-2827

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