vermont's environmental regulations · this guide was developed by the vermont department of...

EADEADENVIRONMENTALA S S I S T A N C ED I V I S I O N

Vermont Ag ency of Natural Resour cesDepar tment of En vir onmental Conser vation

VERMONT'SENVIRONMENTAL

REGULATIONS

AN AUTOBODY REPAIRTECHNICIAN’S GUIDE TO...

This Guide was developed by the Vermont Department of Environmental Conservation’s EnvironmentalAssistance Division (EAD). This project was funded in part by a U.S. Environmental Protection Agencygrant (BG991255-98). Funding was also provided by the Vermont Small Business DevelopmentCenter (VTSBDC) through a USEPA grant (CX-82811601). EAD provides confidential, non-regulatoryassistance to Vermont companies. Services include: on-site compliance and waste reductionassessments, workshops, seminars, written materials, and information and research on pollutionprevention and environmental compliance.

Spring 2002

Authorization for use or reproduction is freely granted.

This document is printed on Processed Chlorine Free (PCF) paperthat is 100% recycled and contains 100% post-consumer content.


Vermont Ag ency of Natural Resour cesDepar tment of En vir onmental Conser vation

VERMONT'SENVIRONMENTAL

REGULATIONS

AN AUTOBODY REPAIRTECHNICIAN’S GUIDE TO...

Photo © Kathryn Sauber, 2002

TABLE OF CONTENTS

Intr oductionEnvironmental Assistance.....................................................................................................1How To Use This Guide ......................................................................................................... 1Ten Tips for Environmental Success .....................................................................................2

Self-Audit Chec klistsHazardous Wastes ................................................................................................................4Wastewater Discharges ...................................................................................................... 15Air Pollution .........................................................................................................................19Pollution Prevention & Best Management Practices ...........................................................25

Fact SheetsUsed Oil .......................................................................................................................... FS 1Used Oil Burning............................................................................................................. FS 2Oily Wastes ..................................................................................................................... FS 3Shop Rags ...................................................................................................................... FS 4Oil Filters ......................................................................................................................... FS 5Antifreeze ........................................................................................................................ FS 6Parts Cleaning Solvent ................................................................................................... FS 7Paints and Thinners ........................................................................................................ FS 8Spills ............................................................................................................................... FS 9Floor Drains .................................................................................................................. FS 10Dust Control & Management......................................................................................... FS 11Scrap Tires .................................................................................................................... FS 12Lead-Acid Batteries ...................................................................................................... FS 13Refrigerants .................................................................................................................. FS 14Recyclable Materials ..................................................................................................... FS 15

AppendicesAppendix A ..................................................... Notification of Regulated Waste Activity FormAppendix B .................................................................................. Hazardous Waste ManifestAppendix C ..........................................................Commonly Used Hazardous Waste CodesAppendix D ............................................................ Hazardous Waste Generation WorksheetAppendix E ...................................................................Environmental Analysis LaboratoriesAppendix F .................................................................................. Calculating VOC EmissionsAppendix G ................................................. Municipal Wastewater Treatment Plant ContactsAppendix H ........................................... How to Read a Material Safety Data Sheet (MSDS)Appendix I ................................................ Additional Information and Assistance Resources

An Autobody Repair Technician’s Guide to Vermont’s Environmental Regulations TABLE

OF

CONTENTS

An Autobody Repair Technician’s Guide to Vermont’s Environmental Regulations INTRODUCTION

INTRODUCTION

This environmental compliance assistance Guide is a step-by-step, self audit checklist to compliancewith Vermont’s laws and regulations on solid and hazardous wastes, wastewater disposal, and airpollution. It covers most all of the autobody repair operations that take place in a typical shop. Becauseautobody shops deal with many hazardous materials, there are many regulatory concerns with properdisposal...Can I do this?...What are my options?...Is this regulated?

This Guide has been developed with the small business in mind. We have tried to make it clear andconcise, yet with enough detail so that most of your questions will be answered right here. This Guidewill not only help you understand environmental regulations, but will also help you reduce wastes,minimize some regulatory requirements and reduce your shop’s impact on the environment.

If you need more help, or a person to talk to, you can call the Environmental Assistance Hotline. On-site help is also available through the Small Business Compliance Assistance Program at this samenumber.

The Environmental Assistance DivisionThe Environmental Assistance Division is a non-regulatory group within the Department ofEnvironmental Conservation (DEC). The Division houses both a Small Business ComplianceAssistance Program as well as a Pollution Prevention Technical Assistance Program. Services availableinclude: phone assistance, on-site assistance, workshops and seminars, and various publicationson pollution prevention. Services are provided at no cost and the information resulting from theservices is not made available to regulatory programs within the DEC.

How To Use This GuideInformation in the Guide is divided into three sections. The first section consists of ComplianceChecklists which are based on the type of waste that is generated: hazardous waste, wastewaterdischarges and air pollution. Questions are presented in a yes/no checklist format so that if you cananswer “yes” to a question, you are likely to be in compliance with that requirement. An answer of “no”could indicate a potential problem that you should investigate further.

If available at your business, the following information resources will help you in completing thechecklist questions:

➙ purchase and/or material usage records for the last 12 months,➙ material inventories for the last 12 months,➙ material safety data sheets (MSDS) for all products you use,➙ hazardous waste shipment manifests, and➙ currently held state or local permits, such as wastewater discharge permits.

ENVI

RONM

ENTAL ASSISTANCE HOTLINE

1-800-974-9559

ENVIRONMENTAL ASSISTANCE SERVICES

HTTP://WWW.ANR.STATE.VT.US/DEC/EAD/EADHOME

➙ ENVIRONMENTAL COMPLIANCE ASSISTANCE➙ WASTE PREVENTION/REDUCTION ASSISTANCE➙ CLEANER TECHNOLOGIES/PROCESSES RESEARCH

1

The second section contains Fact Sheets for wastes and environmental issues commonly found inautobody repair shops. The Fact Sheets provide information about regulatory issues, pollutionprevention, and best management practices that you might want to explore further. The final section,the Appendices , contains additional information that we think you’ll find useful, such as sampleregulatory forms and resource lists.

If you are not sure whether a particular practice or activity at your business meets the regulations,please contact the Environmental Assistance Division (EAD) and we will get answers for you. Youmay also request a free and confidential (non-regulatory) on-site compliance assistance visit bycontacting EAD’s Small Business Compliance Assistance Program.

An Autobody Repair Technician’s Guide to Vermont’s Environmental RegulationsINTRODUCTION

TIPS FOR ENVIRONMENTAL SUCCESS

Pollution Prevention - The First Step to Compliance

The less waste you generate in the first place, the less there is to be regulated and the easier your job will beto maintain compliance. You will also save money, improve health in the workplace and contribute toenvironmental protection. Switching to less toxic products and solvents is a good way to help prevent pollution.

Keep every receipt, bill of lading, and hazardous waste manifest related to the purchase of materials anddisposal of waste. Accurate records, filed by year and easily accessible, will help you keep better track ofmaterial use and waste management. If you are inspected, good recordkeeping can minimize the time andeffort necessary to evaluate compliance. Good recordkeeping can also expedite a property sale or loan.

More often than not, employees have good ideas on how to generate less waste. Reward them! If theirideas save the company money, consider giving them a percentage of the savings. Make sure youremployees know that you welcome their ideas.

Hazardous materials in floor drain discharges can lead to local ground water and soil contamination orproblems at your local treatment plant. Some shops use closeable covers or plugs on their floor drains asa best management practice. Floor drains that discharge to on-site subsurface systems should either beclosed or connected to a holding tank which can be periodically pumped and the water disposed of properly.

Maintain Good Records

Involve Your Employees

Minimize Your Use and Need for Floor Drains

Learn to Read an MSDS and Avoid Toxic Materials

Material Safety Data Sheets (MSDSs) are documents that should be provided with most of the chemicalproducts that you buy. They give you important environmental, health, and work place safety information.Requesting and reviewing an MSDS before making a purchase could help you avoid problems down theroad. Gathering MSDSs is a necessary first step in determining your emissions of VOCs (volatile organiccompounds) and HACs (hazardous air contaminants) - two common classes of air pollutants and can behelpful in making hazardous waste determinations.

2

Often times, training is looked upon as unproductive overhead; you can’t sell training like you can aproduct. However, proper spray techniques can significantly reduce raw material and waste disposalcosts. A well-trained staff produces finished work more efficiently, creates less waste, spills less, andhas fewer accidents. These add up to increased profits in the long run.

Nothing can get you into trouble faster than sloppy waste management. Segregating wastes in differentcontainers increases the potential (and value) of a material for recycling, or conversely lessens treatmentand disposal costs if there is no market for recycling.

Hazardous substances should never be handled like regular trash. Liquid wastes (hazardous or not) aregenerally banned from Vermont landfills as are oily wastes. Reduce volume by segregating and managingrecyclables separately. Contact your local solid waste management district for recycling information andassistance or call the Recycling Hotline at (800) 932-7100.

Wastewater from industrial processes such as auto refinishing is regulated based on volume, contaminantspresent and discharge point. If your facility has floor drains that collect waters from car washing andother sources, you should know where this wastewater goes. See the Wastewater Discharges section ofthis guide and the Floor Drain fact sheet for more details.

As burdensome as environmental regulations may seem, they were created to protect you, youremployees, and your community. Don’t be afraid to use the technical resources available to you - we arehere to help you understand and comply with the regulations and look for waste prevention opportunities.Call us! We offer free, confidential assistance ranging from answering an anonymous question over thephone to providing you with a team of experts for on-site assistance.

Train Your Staff

Label Waste Containers and Store Them in One Spot

Don't Throw It in the Dumpster

Know Where Your Wastewater Goes

Ask for Help!

An Autobody Repair Technician’s Guide to Vermont’s Environmental Regulations INTRODUCTION

3

ENVI

RONM

ENTAL ASSISTANCEHOTLINE

1-800-974-9559

An Autobody Repair Technician’s Guide to Vermont’s Environmental RegulationsHAZARDOUS

WASTE

4

HAZARDOUS WASTES

Autobody repair operations typically produce a variety of liquid andsolid wastes. This section of the Guide provides information thatwill help you to identify which of those wastes may be regulated ashazardous wastes and describes how they need to be managed.

Does My Shop Generate Hazar dous Waste?

Bodyshop owners are responsible for knowing if the wastes theygenerate are hazardous wastes. Before you throw anything into adumpster, you are required to determine if the material you aredisposing of is subject to regulation as hazardous waste. TheVermont Hazardous Waste Management Regulations (VHWMR)identifies those wastes that are regulated as hazardous wastes in Vermont. A waste is a hazardouswaste if it is included on one or more of five hazardous waste lists (referred to as “listed wastes” ) orexhibits one or more of four hazardous waste characteristics (referred to as “characteristic wastes” ).

All hazardous wastes are identified by a hazardous waste code. The waste code consists of a capitalletter(s) followed by a number (i.e. VT02, D001, F002, K095, U237, or P003). The letter part of thecode indicates whether the waste is found on a hazardous waste list or if it is a characteristic hazardouswaste; the number following the letter(s) describes the specific type of waste (see Figure 1). Somewastes may be identified by more than one code. An example is waste gun cleaning solvent containingxylene that exhibits a hazardous waste characteristic (D001, ignitability) and is also a listed hazardouswaste (F003, because the xylene is being used for its solvent properties).

Figure 1: Hazardous Waste Code Examples

02

003

D 001

D 008

The characters “VT” identify thewaste as being a “Vermont-Listed” hazardous waste.

The numbers “02” identify thehazardous waste specifically as“waste containing greater than5% by weight of petroleumdistillates...”.

The numbers “001” identifies thespecific hazardous wastecharacteristic as “ignitability”.

The character “D” identifies thewaste as being a “characteristic”hazardous waste.

The character “F” identifies thewaste as being an “F-Listed”hazardous waste.

The numbers “003” identifies thehazardous waste specifically as“spent non-halogenated solvents:xylene, acetone...”.

The character “D” identifies thewaste as being a “characteristic”hazardous waste.

The numbers “008” identifies thespecific hazardous wastecharacteristic as “toxicity” andthe toxic contaminant as “Lead”.

VT

F

Listed Wastes

A waste is listed as a hazardous waste because it has been shown to be harmful to health and/or theenvironment when not managed properly. Of the five hazardous waste lists, the two that are mostapplicable to wastes generated by autobody shops are:

These are wastes that have been designated by the State of Vermont as hazardouswastes (the other lists contain Federally mandated hazardous wastes). Some of thewastes generated by autobody shops are found on the VT list. Examples include: oilyabsorbents (Vermont hazardous waste code VT02) and spent antifreeze (Vermonthazardous waste code VT08).

Many of the wastes generated in a typical autobody shop are hazardous because theyare F-listed solvents. These wastes are identified by the F003 and/or the F005 hazardouswaste codes (see Appendix C for a list of commonly used hazardous waste codes inautobody repair shops).

There are other hazardous waste “lists” including; K, P, and U which will not be discussed in thisguide because they seldom apply to wastes generated by autobody shops. More information onthese lists can be found in the “Vermont Hazardous Waste Management Regulations” (VHWMR) ,the “Conditionally Exempt Generator Handbook” , and for larger generators, the “GeneratorHandbook” . If you have questions or would like to request any of these publications, visit the WasteManagement Division (WMD) web site at http://www.anr.state.vt.us/dec/wmd.htm or contact the WMDat 1-802-241-3888 or EAD at 1-800-974-9559.

Characteristic Wastes

Characteristic hazardous wastes are wastes that exhibit one or more of the following four hazardouswaste characteristics; ignitability, corrosivity, reactivity, or toxicity. Of the four characteristics, the followingthree are the most applicable to wastes generated in autobody repair operations:

Wastes that have a flashpoint of less than 140oF or are at risk of spontaneous combustionare said to exhibit the characteristic of ignitability. Examples include: paint thinners,solvent-based metal cleaners, gun cleaning solvent, and paint filters. Ignitable wastesare identified by the hazardous waste code D001.

Wastes that are liquid and have a pH less than 2 or greater than or equal to 12.5 orthat corrode steel at a rate greater than 0.25 inch per year are said to exhibit thecharacteristic of corrosivity. Some etching-type metal cleaners have a pH less than 2.Corrosive wastes are identified by the hazardous waste code D002.

Wastes containing small amounts of any one of eight (8) metals or thirty-two (32)organic contaminants may exhibit the toxicity characteristic. To determine if a wastecontains enough of one of these contaminants to exhibit the toxicity characteristic, thegenerator can either rely on knowledge of the materials and/or the process generatingthe waste or submit a sample of the waste for laboratory analysis. The sample is analyzed

An Autobody Repair Technician’s Guide to Vermont’s Environmental Regulations HAZARDOUS

WASTE

5

VE

RMONT LISTED

HAZARDOUS WASTE

S

F - LISTED

HAZARDOUS WASTE

S

Ignitability

Corrosivity

To x i c i t y

using a procedure referred to as the Toxic CharacteristicLeaching Procedure (TCLP). The waste is hazardous ifthe concentration of any of these contaminants exceedsan amount specified in the regulations. A waste thatexhibits the characteristic of toxicity would be identifiedby one or more of the hazardous waste codes of D004through D043 depending on the toxic contaminant(s)which cause it to exhibit the toxicity characteristic. Toxiccontaminants found in automotive coatings are typicallyheavy metals such as lead, chromium, cadmium, orbarium. For example, a waste paint that contained greaterthan 5.0 milligrams per liter of lead would exhibit thetoxicity characteristic and would be identified by the wastecode D008.

Acutely Hazardous Wastes

A waste is an “acutely hazardous waste” if it is a commercial chemicalproduct having the generic name listed in Appendix IV of the VermontHazardous Waste Management Regulations. The term “commercialchemical product” refers to a chemical substance which is manufacturedor formulated for commercial or manufacturing use which consists ofthe commercially pure grade of the chemical, any technical grades ofthe chemical that are produced or marketed, and all formulations inwhich the chemical is the sole active ingredient. It does not refer to amaterial, such as a process waste, that merely contains one or more ofthe substances listed. Autobody repair shops don’t typically generateany acutely hazardous wastes, however, a copy of the list of acutelyhazardous wastes can be obtained by contacting EAD at 1-800-974-9559.

Making a Hazardous Waste Determination

It is the responsibility of the generator of a waste to determine whether it is a regulated hazardouswaste. As the flow diagram in Figure 2 shows, the fir st step in making a hazardous waste determinationis simply deciding if the material is a “waste” . The regulations define a waste as any materialwhich is “discarded”. It is important to note that the regulations include recycling in their definition ofdiscarded. This means that even materials which are recycled either on or off-site are wastes and, assuch, may also be regulated as hazardous wastes.

Hazardous waste determinations should be made as soon as you are finished using a materialbecause the properties of the material may change over time, affecting any subsequent hazardouswaste determination.

The second step in the hazardous waste determination process involves deciding whether or notthe waste meets the regulator y definition of a hazar dous waste . As stated previously, this can be

6

StartHazardous

WasteDetermination

Is thematerial

awaste?

Is thewaste listed

in theVHWMR?

Is thewaste ignitable,

corrosive,reactive,or toxic?

Waste is ahazardous waste.

Material is NOTregulated as a

hazardous waste.


hazardous waste.

NO

YES

YES

NO

YES

NO

Do theVHWMR provide

an exemptionfor thewaste?

YES

NO


hazardous wastebut may requirespecial handling

to meet exemption.

Figure 2: Hazardous WasteDetermination Flow Diagram


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based on general knowledge of the process and materials generating the waste, and/or laboratoryanalysis of the waste. This information would be used in conjuction with the lists of hazardous wastesand definitions of hazardous waste characteristics given in the VHWMRs to make a final determination.

The final step in the hazardous waste determination process is to determine if a waste is e xcludedor exempted fr om regulation as a hazardous waste. The VHWMRs contain exemptions for some ofthe wastes typically generated by autobody shops. Examples include: used oil, scrap metal, antifreeze,oil filters, and lead-acid batteries. Each of these exemptions require that the waste meet and bemanaged in accordance with certain criteria (see Fact Sheets for details).

Knowledge of Process/Materials

The regulations allow generators to use their knowledge of the process and materials creating thewaste to determine if it is either a listed or characteristic hazardous waste. Resources that will beuseful in making such a determination include; information provided on raw material and productlabels and material safety data sheets (MSDS). A complete listing of the wastes that are regulated ashazardous waste in Vermont, along with detailed definitions, may be found in Subchapter 2 of theVermont Hazardous Waste Management Regulations.

Laboratory Analysis

If a waste is not specifically listed or if sufficient information is not available to determine whether awaste is a hazardous waste, it is necessary to have a laboratory analyze a sample of the waste (seeAppendix D for a list of analytical laboratories). Such analyses can determine whether the waste ishazardous because it exhibits one of the four characteristics (ignitability, corrosivity, reactivity, ortoxicity) or if it exceeds a concentration threshold for some contaminant of concern. You can reducethe cost of laboratory analysis by providing the lab with as much information as possible about thewaste. This will enable the lab to perform only those tests needed to determine if the waste is hazardous.For example, if you know the only potentially hazardous contaminant in a waste is chromium, thereis no need to test for lead. Contact the Waste Management Division about less expensive alternativesto TCLP analysis (i.e. totals analysis).

How Muc h Hazardous Waste Does My Business Generate Eac h Month?

The amount of regulation your shop is subject to depends on the amout of hazardous waste yougenerate per month and/or the quantity of hazardous waste on-site at any given time. Therefore, it isvery important that all of the wastes your facility generates be identified, characterized (as hazardous/non-hazardous) and quantified (pounds per month). Creating a list of all of the potentially hazardouswastes generated at your facility also makes good business sense. An inventory of wastes will:

➙ Identify areas to reduce waste, costs, and your business’ regulatory burden.➙ Help you determine the extent to which your business is regulated.➙ Allow you to determine your generator status.


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7

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Table 1: Somewastes typicallygenerated duringautobody repairthat may behazardous


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8

Creating a Hazardous Waste Inventory

Autobody repair operations result in the creation of a number of wastes. Many of these wastes aresubject to regulation as hazardous wastes. Table 1 on the preceeding page lists some wastes typicallygenerated by autobody shops that may be subject to regulation as hazardous wastes. The table alsoprovides an indication of whether the waste is hazardous because it is listed and/or exhibits acharacteristic, and some of the waste codes that might be used to identify the waste (It is importantto note that the regulations contain conditional exemptions for some of the wastes shown in thetable).

An example of a hazardous waste identification and quantification worksheet is shown in Table 2(Appendix D contains a blank worksheet for your use). The following instructions refer to Table 2 andare provided to assist you in performing a hazardous waste inventory:

STEP 1: Identify and list in the “Waste Name” column any “potentially hazardous wastes”generated at your facility. (Table 1 on the preceeding page shows some of the potentiallyhazardous wastes typically generated by autobody repair shops.)

STEP 2: For each of the wastes listed, if you have an MSDS for the product(s) before use, checkthe “MSDS” column. An MSDS can be helpful in making a hazardous wastedetermination, possibly eliminating the need for costly lab analysis. It is important toremember that an MSDS will not account for any contaminants picked up during theuse of a product.

STEP 3: For each of the wastes listed, if laboratory analysis has been done and results areavailable, check the “Lab Analysis” column. Laboratory analysis is often necessary

Waste Name

Hazardous Waste Determination

MS

DS

Ava

ilab

le

Lab

Ana

lysi

s A

vaila

ble

VT-

List

ed

F-L

iste

d

Igni

tabi

lity

Cor

rosi

vity

Toxi

city

Exe

mpt

Non

-Haz

ardo

us

Haz

ardo

us

Mon

thly

Qua

ntity

(pou

nds)

Paint Filters

ListedWaste

CharacteristicWaste

Still Bottoms

XF003,F005

D001

D001 X

X 5

Oil Soaked Sorbents

15

X VT02 X 80

Petroleum Naphtha Solvent X VT02 D001 X 105

Antifreeze X VT08 X

Spray Booth Filters X F003,F005 X 30

Monthly Hazardous Waste Generation 235

Table 2: Hazardous waste quantification worksheet


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9

when available information is not sufficient to determine whether or not a waste exhibitsa hazardous waste characteristic.

STEP 4: For each of the wastes listed, use the VT and F hazardous waste lists to determine ifthe waste is a listed waste. If the waste is listed, enter the designated hazardouswastecode(s) in the appropriate “Listed Waste” column. It is important that you knowthe hazardous waste codes for all of the hazardous wastes that you generate. Thesecodes are used on the “Notification of Regulated Waste Activity” form and hazardouswaste manifests.

STEP 5: For each of the wastes listed, determine whether or not the waste exhibits one of thehazardous characteristics (ignitability, corrosivity, or toxicity). Use the definitions forignitability and corrosivity given in the earlier section, “Characteristic Wastes”. To makea toxicity determination, see the list of toxic contaminants and their associatedconcentration limits in Appendix C (Note: This is only a partial list, a complete list canbe found in Section 7-208 of the VHWMR). It will be useful to have any pertinent MSDSor lab analyses available. If it is determined that the waste exhibits a hazardous wastecharacteristic, enter the appropriate waste code(s) in the “Characteristic Waste” column.

STEP 6: For each of the wastes that were determined to be a “Listed” or a “Characteristic”waste, check the Fact Sheets section of this guide and/or contact EAD or the WasteManagement Division to see if the regulations contain an exemption that might beapplicable. If an exemption exists and the waste meets and is being managed inaccordance with any exemption criteria, place a check in the Exempt column.

STEP 7: For each waste that was determined to be neither a “Listed” or “Characteristic” wasteor that was determined to be hazardous but is being managed in accordance with anexemption, place a check in the “Non-Hazardous” column.

STEP 8: For each of the wastes that were determined to be hazardous and no exemption applies,show the quantity (in pounds) of the waste generated per month in the “Monthly Quantity”column. This will assist you in determining your generator status.

STEP 9: The final step is to establish the total pounds per month of the wastes that weredetermined to be hazardous at the bottom of the “Monthly Quantity” column. This numberis important when determining your “generator status”.

What is the “Generator Status” of My Business?

Hazardous waste generator status is based on the quantity of hazardous waste generated at yourbusiness each month and the quantity of hazardous waste that is accumulated on-site. The followingchart will help you determine your generator status. It shows the three categories of hazardouswaste generators in Vermont from least to most regulated. Because generator status is based on thequantity of hazardous waste generated in a calendar month and not the quantity shipped in amonth, it is important that you track or estimate monthly generation .


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YOU ARE A CONDITIONALLY EXEMPT GENERATOR IF YOU...CEG

YOU ARE A SMALL QUANTITY GENERATOR IF YOU...SQG

YOU ARE A LARGE QUANTITY GENERATOR IF YOU...LQG

☞ generate greater than or equal to 220 lbs. but less than 2,200 lbs. in a calendar month;(this is approximately between ½ and 5 full 55 gallon drums of water); and

☞ generate less than 2.2 lbs. of acutely hazardous waste in a calendar month; and☞ never accumulate more than 13,200 pounds of hazardous waste at any one time.

☞ generate less than 220 lbs. of hazardous waste in a calendar month (220 lbs. is about1/2 of a 55 gallon drum of water); and

☞ generate less than 2.2 lbs. of acutely hazardous waste in a calendar month; and☞ never accumulate more than 2,200 lbs. of hazardous waste at any time.

☞ generate greater than 2,200 lbs. of hazardous waste in a calendar month (this isapproximately greater than 5 full 55 gallon drums of water); or

☞ generate greater than 2.2 lbs. of acutely hazardous waste in a calendar month; or☞ accumulate more than 13,200 lbs. of hazardous waste at any one time.

What Hazar dous Waste Regulations is My Business Subject To?

The hazardous waste regulatory requirements that apply to your business are determined by yourgenerator status. The result is that businesses that create more hazardous waste are subject tomore regulation. Most autobody shops in Vermont are CEGs, the least regulated generator category.The remainder of this section of the Guide is comprised of a checklist that will help you determine ifyou are complying with the hazardous waste regulations as they apply to CEGs . If you havedetermined that your shop is either a SQG or LQG, we may be able to help you reduce the amountof waste you generate to CEG levels. If it is not possible for your shop to reduce its waste generationto CEG levels, we can help you understand the additional regulatory requirements that affect yourshop.

NOTE: The following Checkl is t only appl ies to shops that areclassif ied as Conditionally Exempt Generators (CEG) ofhazardous waste.

HAZARDOUS WASTESELF-AUDIT CHECKLISTQuestions are presented in a yes/no checklist format so that if you can answer “yes” to a question, you are likely to be incompliance with that requirement. An answer of “no” could indicate a potential problem that you should investigate further.

Generator Status & Reporting

1. We have determined which of our wastes are hazardous and which are not.

Yes ❑❑❑❑❑ No ❑❑❑❑❑


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11

2. We have calculated our monthly hazardous waste generation and have determined our generatorstatus.

Yes ❑❑❑❑❑ No ❑❑❑❑❑ N/A ❑❑❑❑❑

3. We have filed a “Notification of Regulated Waste Activity” form with the Waste ManagementDivision. We also understand that the form must be resubmitted any time information containedon the form changes.

Yes ❑❑❑❑❑ No ❑❑❑❑❑

4. We are aware of the requirement to report any discharge or release of petroleum to theenvironment which exceeds two gallons (or any amount of a hazardous material that poses athreat to human health or the environment). See the “Spills” Fact Sheet for information on how toreport a spill.

Yes ❑❑❑❑❑ No ❑❑❑❑❑

Container Management and Storage

1. As a CEG, we do not store more than 2,200 pounds of hazardous waste on-site at any one time.

Yes ❑ No ❑ N/A ❑

2. Hazardous wastes are stored in containers that are in good condition and are compatible withthe wastes being stored in them.


WASTE

MA NA GEMENT A business producing any amount of hazardous waste or handling used oil is required to file a “Notificationof Regulated Waste Activity” form with the Waste Management Division (WMD). After submitting the form,

your shop will receive a unique identification number called an EPA Identification Number. A temporary numbercan be assigned if you need to ship hazardous waste before a permanent number can be obtained. SeeAppendix A for more information on the Notification form.

WASTE

MA NA GEMENT A word of CAUTION! If you accumulate more than 2,200 pounds of hazardous waste at any one time(roughly five 55-gallon drums) you are subject to all of the requirements of either an SQG or an LQG,

depending on how much hazardous waste you have accumulated.

WASTE

MA NA GEMENT Labeling waste containers and segregating waste streams prevents mixing of incompatible wastes.Segregating your wastes can also make it easier to recycle and may lower disposal costs. Periodically

inspect ALL hazardous waste containers.


WASTE

12

3. We keep containers holding hazardous waste closed except when it is necessary to add orremove waste.

Yes ❑ No ❑

4. We label all of our hazardous waste containers with the words “Hazardous Waste” and otherwords that identify the contents.

Yes ❑ No ❑

5. We label all of our containers holding used oil with the words “Used Oil”.


6. Containers holding ignitable wastes (e.g. parts cleaning solvents and thinners) are stored atleast 50 feet from the property line.


7. Hazardous wastes and used oil are accumulated and stored on an impervious surface.

Yes ❑ No ❑

8. Any hazardous wastes or used oil containers that are stored outside are placed on an impervioussurface and protected from rain and snow.


9. Only hazardous wastes that are not subject to freezing and expansion are stored outdoors.


WASTE

MA NA GEMENT A drum mounted funnel must be covered for a container to be considered closed. Allowing waste solventto evaporate is illegal disposal of a hazardous waste. Covered waste containers reduce fire and explosion

hazards and assures that employees breathe less vapors and that your shop emits less pollution.

WASTE

MA NA GEMENT Store liquid wastes away from floor drains. Store hazardous wastes in one place so you can keep bettertrack of them.


WASTE

13

10. We manage the following specific wastes in accordance with the fact sheets contained in thisGuide.

Used Oil Yes ❑ No ❑ N/A ❑Used Oil Burning Yes ❑ No ❑ N/A ❑Oily Wastes Yes ❑ No ❑ N/A ❑Shop Rags Yes ❑ No ❑ N/A ❑Oil Filters Yes ❑ No ❑ N/A ❑Antifreeze Yes ❑ No ❑ N/A ❑Parts Cleaning Solvent Yes ❑ No ❑ N/A ❑Paints & Thinners Yes ❑ No ❑ N/A ❑Spills Yes ❑ No ❑ N/A ❑Floor Drains Yes ❑ No ❑ N/A ❑Dust Control & Management Yes ❑ No ❑ N/A ❑Scrap Tires Yes ❑ No ❑ N/A ❑Lead-Acid Batteries Yes ❑ No ❑ N/A ❑Refrigerants Yes ❑ No ❑ N/A ❑

Waste Transport and Disposal

1. We ship hazardous wastes to certified treatment, storage or disposal facilities (TSDF) usinglicensed hazardous waste transporters and a hazardous waste manifest. (A list of certifiedtransporters can be obtained by calling the Environmental Assistance Division at 1-800-974-9559)


2. As a CEG, we self-transport hazardous wastes to certified treatment, storage, or disposal facilities;to municipal CEG hazardous waste collection sites or to generator facilities we own.

Yes ❑ No ❑ N/A ❑WASTE

MA NA GEMENT US Department of Transportation hazardous materials transportation regulations will still apply to yourvehicle and what it carries. For more information call the Vermont Agency of Transportation, Department of

Motor Vehicles Commercial Vehicle Enforcement Unit at 802-828-2078.


WASTE

14

WASTEWATER DISCHARGES

How Are Wastewater Disc harges Regulated?

All facilities generate some type of wastewater. Wastewaterdischarges are regulated by the Department of EnvironmentalConservation’s (DEC) Wastewater Management Division (WWMD)in Waterbury and through five Regional Offices (see Appendix I forthe Regional Office serving your area). Wastewater can begenerated from bathroom and kitchen facilities (known as sanitarywastewater), from manufacturing or other processes (known asprocess or non-sanitary wastewater), or it can be a combination ofsanitary and process wastewater. Under no circumstances shouldhazardous materials be discharged to any type of wastewatersystem. Liquid wastes that contain hazardous constituents mustbe collected and handled as a hazardous waste.

Wastewater is discharged to a municipal wastewater treatment plant, an on-site subsurface system(e.g. septic system or dry well), or in very limited circumstances, to the surface of the ground. Howwastewater is regulated depends on a number of factors including: whether the discharge is sanitary,process, or combined wastewater, the contaminants present in the discharge, the volume of thedischarge, and whether the wastewater is being discharged to an on-site subsurface system, amunicipal treatment plant or on the surface of the ground.

How Are Disc harges To A Municipal Se wer System Regulated?

Sanitary Wastewater Discharges Only

DEC requires a wastewater disposal permit for any sanitary discharge from a business or otherpublic building to a municipal wastewater treatment plant unless the discharge began prior to 1970and the system has not been modified since 1970. For more information, contact the WWMD RegionalOffice serving your area (see Appendix I).

Process Wastewater Discharges

Shops that discharge non-sanitary wastewater (e.g. floor drain wastewater, mop water, or any process-related wastewater) to a wastewater treatment plant must notify the WWMD, the operator of themunicipal plant, and the person responsible for administering the local sewer ordinance. Dependingon the volume and make-up of the discharge, the shop might be required to obtain a “pretreatment”permit from the WWMD. It is unlikely that such a permit would be required for “mop water” or othertypically low risk discharge, but it is always necessary to make the required notifications, and toobtain approval (in writing, if possible) for the discharge. The municipality may require that non-sanitary wastewater pass through an oil/water separator before discharge to the treatment plant. Formore information, contact the WWMD Regional Office serving your area.

An Autobody Repair Technician’s Guide to Vermont’s Environmental Regulations WASTEWATER

DISCHARGES

15

How are Disc harges to an On-Site System Regulated?

Sanitary Wastewater Discharges

Any strictly sanitary discharges from a business or public building requires a permit unless thedischarge began prior to 1970 and the system has not been modified since 1970. Contact the WWMDRegional Office serving your area for more information on obtaining a wastewater disposal permit fora sanitary discharge.

Process Wastewater Discharges

All shops with existing discharges of non-sanitary wastewater to subsurface systems (e.g. septicsystems, dry wells and holding tanks) must inform the WWMD Regional Office of the discharge. Thespecifics of the discharge are reviewed by an engineer in the regional office who determines whetheror not the discharge is allowable. This review process applies to any discharge of process wastewater,whether the wastewater is a combination of sanitary and non-sanitary wastewaters (a “combinedwaste”) or is disposed in an on-site system that is separate from sanitary wastewater (e.g. a dry well).Both of these situations would require an Underground Injection Control (UIC) Permit.

Although, under limited circumstances, a shop might be able to obtain a permit to discharge processwastewater on-site, the potential liability of such a practice should be given serious consideration.Even a small quantity of certain materials can contaminate groundwater. If persons nearby (or yourshop) depend on groundwater, you have the potential to contaminate their drinking water supply.

The Depar tment of En vir onmental Conser vation discoura gesthe disc harge of an y non-sanitar y waste water to the subsurface .

Discharges to the Ground (Daylighting) of Non-Sanitary Wastewater

Daylighting is the practice of discharging floor drain or other process wastewater to the groundsurface. Daylighting of floor drain wastewater is prohibited if the water originates in either vehiclemaintenance (including body work) or washbays. Note that daylighting might be approved by theWWMD if all of the following apply:

➙ the wastewater doesn’t discharge directly to surface water (e.g. a stream, pond, wetland);➙ the discharge is infrequent and of low volume; and➙ the discharge doesn’t contain hazardous materials or waste.

Floor Drains

Floor drains that discharge to a subsurface disposal system (e.g. septic system or dry well) must beregistered as an underground injection control (UIC) well with the WWMD in Waterbury (see AppendixI). The registration process consists of completing a Floor Drain Registration Form (Form UIC-A) forreview by a WWMD engineer who will determine whether or not a UIC permit is required. Pleaserefer to the Floor Drain Fact Sheet for more information.

An Autobody Repair Technician’s Guide to Vermont’s Environmental RegulationsWASTEWATER

DISCHARGES

16

WASTEWATER DISCHARGESSELF-AUDIT CHECKLISTQuestions are presented in a yes/no checklist format so that if you can answer “yes” to a question, you are likely to be incompliance with that requirement. An answer of “no” could indicate a potential problem that you should investigate further.

General

1. We have identified the discharge points of all of our floor drains.


2. We do not dispose of any used oil, antifreeze, solvents, paints or other hazardous materialsthrough our sinks or floor drains.


3. Our shop has obtained a permit issued by the appropriate Regional Office of the WastewaterManagement Division for sanitary wastewater disposal - unless the discharge began prior to1970 and no modifications to the system have occurred since that time.


Shops Discharging to Municipal (or private) Wastewater Treatment Plants(shops with on-site systems go to “Shops Disc harging to On-Site Subsurface Systems” )

1. Our shop discharges floor drain wastewater to a wastewater treatment plant (WWTP) and wehave received approval for the discharge from the local sewer authority and Vermont’s WastewaterManagement Division.


WASTEWATER

DISCHA RGES Permanently close, or at least securely plug, floor drains in vehicle repair areas when not needed toprevent the accidental discharge of spilled hazardous materials (i.e. oil, antifreeze, solvents, paints, etc.) to

the environment. Train employees in proper spill response and have spill response equipment readily available.

WASTEWATER

DISCHA RGES Except for the stated condition, all discharges of sanitary wastewater from any public building require aWastewater Disposal permit.

WASTEWATER

DISCHA RGES Some local sewer ordinances may require that floor drain wastewater pass through an oil/water separatorprior to discharge to the sewer system. Contact your local sewer authority for more information (see Appendix

G for contact information).

An Autobody Repair Technician’s Guide to Vermont’s Environmental Regulations WASTEWATER

DISCHARGES

17

Shops Discharging to On-Site Subsurface Systems

1. Our shop discharges a combination of sanitary and process wastewater to an on-site subsurfacesystem (i.e. septic system, leachfield, drywell, etc.) and we have completed an UndergroundInjection Control (UIC) registration form and submitted it to the DEC’s Wastewater ManagementDivision in Waterbury for review.


2. Our shop discharges floor drain or other process wastewater separate from our sanitarywastewater to a drywell or leachfield and have completed and submitted an Underground InjectionControl (UIC) registration form and submitted it to the DEC’s Wastewater Management Divisionin Waterbury for review.


Shops Daylighting Floor Drain Wastewater

1. Our shop daylights only wastewater that is the result of snowmelt and this snowmelt occurs onlyin areas physically separated from areas in which vehicle maintenance or washing is performed.


WASTEWATER

DISCHA RGES Any on-site discharge of non-sanitary wastewater to a subsurface system must be permitted by the Waste-water Management Division’s UIC program. Future regulations are anticipated that will ultimately require

the permanent closure of any floor drains that discharge to a drywell or septic system (see the Floor DrainsFact Sheet).

WASTEWATER

DISCHA RGES Floor drain discharges that are not registered with the DEC’s Wastewater Management Division must beclosed. Information from floor drain registrations will be used to determine whether or not the discharge

requires a permit.

WASTEWATER

DISCHA RGES Wastewater from floor drains that originate in vehicle repair or washing areas are prohibited from beingdischarged onto the ground. Floor drains from these areas need to be re-routed to discharge to either; a

municipal wastewater treatment plant or connected to a holding tank for periodic disposal.

An Autobody Repair Technician’s Guide to Vermont’s Environmental RegulationsWASTEWATER

DISCHARGES

18

AIR POLLUTION

What Autobod y Repair Activities Create Air P ollution?

Autobody shops create air pollution from three main activities: surfacepreparation, surface coating and equipment clean-up. The pollutantsof concern resulting from these activities include: particulate matterin the form of sanding and/or sandblasting dust and coating overspray,strong odors from solvents contained in coatings and equimentcleaning solvents, and volatile organic compounds (VOCs) andhazardous air contaminants (HACs) also contained in coatingmaterials and cleaning solvents. All of these pollutants are regulatedunder Vermont’s Air Pollution Control Regulations.

Dust & Mist

Surface preparation and resurfacing operations such as sanding and sandblasting produce dust. Researchhas shown that sanding or sandblasting dust can contain toxic metals, such as lead, arsenic, cadmiumand chromium. Exposure to these metals can cause adverse health affects and any dust that leaves yourproperty can become a nuisance to your neighbors and a regulatory problem for your business. For all ofthese reasons, it is important that sanding dust be controlled. Using a disc sander in combination with adust collection unit will ensure a safer, healthier workplace and reduce the potential for complaints fromneighbors. When used properly, vacuum units (dustless vacs or ventilated sanders) can control up to 90%of sanding dust generated from disc sanding operations.

Another form of particulate in autobody shops is overspray of paint particles from coating operations.Some coatings contain toxic heavy metals such as lead, chromium, barium and titanium. Overspraycontaining these metals can be exhausted from your spray booth or room and cause adverse healthaffects in the surrounding community.

Volatile Organic Compounds

Most autobody surface preparation,paints, thinners, paint strippers andequipment cleaning solvents containhydrocarbon-based compounds thatevaporate easily into the air. Once in theair, these volatile organic compounds(VOCs) combine with other pollutants andreact with nitrogen oxides in the presenceof sunlight to form “ground-level ozone”,also known as smog. In order to reducethe formation of smog caused byemissions from autobody repairoperations, Federal regulations limit the Figure 3.

Coating CategoryVOC Content(pounds/gallon)

AIRPOLLUTION

CO

MPLIA NT COATING

S In 1999, the U.S. EPA adopted regulations limiting theVOC content of coatings used by auto refinishers. The

maximum allowable VOC limits for auto refinish coatings soldin the U.S. are:

Pretreatment Wash Pimer ...................................6.5Primer/Primer Surfacer ........................................4.8Primer Sealer ......................................................4.6Single/2-Stage Topcoat ........................................5.0Topcoats of 3 or More Stages ..............................5.2Multi-Colored Topcoat ..........................................5.7Specialty Coatings...............................................7.0

Note: These limits are for coatings “as applied”(after mixing with reducers and hardeners).

An Autobody Repair Technician’s Guide to Vermont’s Environmental Regulations AIR

POLLUTION

19

VOC content of auto refinishing materials that can be sold for usein the U.S. (see Figure 3). Most coatings are not purchased ready-to-spray but require mixing prior to use. Coating suppliers typicallyprovide product data sheets with detailed mixing instructions toensure that coatings “ready-to-spray” will meet the required VOClimits.

Hazardous Air Contaminants

Many autobody surface preparation, paints, thinners, paintstrippers and equipment cleaning solvents contain toxicingredients which have the potential of being released to theair (see Figure 4.). These “air toxics” can exist as either gases(e.g. toluene) or particulate matter (e.g. chromium). These toxicair pollutants, referred to in the Air Pollution Control Regulations as Hazardous Air Contaminants(HACs), are regulated because they are known or suspected to cause cancer or have other short orlong term health effects. The vast majority of HACs listed in the Air Pollution Control Regulationshave an associated “action level” and “hazardous ambient air standard”. The action level is the rate ofemissions (in pounds per 8 hours) at which air pollution control requirements are triggered for anindividual contaminant. The hazardous ambient air standard is the highest acceptable concentrationof any HAC in the air at ground level at the property line of your shop. Hazardous ambient air standardsare established to protect public health.

How Are Air P ollutants Fr om Autobod y Activities Regulated?

The primary air pollution regulatory concern for autobody shops is related to strong solvent odors,dust and other particulate (e.g. paint solids) leaving the property and creating a public nuisance.VOC and HAC emissions only become a regulatory issue if certain thresholds are exceeded. Typically,autobody shops either don’t spray enough VOC and/or HAC containing materials to exceed thesethresholds or equipment and operating practices are sufficient to keep emissions below regulatorythresholds. However, it is important to be aware of these thresholds and to estimate your emissionsto ensure you are operating in compliance with the regulations and not adversely impacting theenvironment or public health.

Volatile Organic Compounds (VOCs)

The Air Pollution Control Regulations currently regulate VOC emissions based either on industrycategory or by quantity emitted. Aside from the Federal limits on VOC content of coatings, there arecurrently no regulations in Vermont specifically addressing VOC emissions from autobody repairshops. VOC emissions are only regulated in Vermont if they exceed certain thresholds. Permits arerequired when they exceed 10 tons per year. Although no autobody shops in Vermont come close toemitting that amount, VOC emissions can still become a regulatory concern for an autobody shop intwo ways. First, if the sum of all air contaminants released to the outside air, from any source, totalsmore than 5 tons per year, the regulations require that source to register with Vermont’s Air Pollution

AIR

POLL UTION

Figure 4.

To learn more about thechemicals you use, including how

hazardous they are and theconcentration of VOCs and HACsthey contain, you need tounderstand the information providedby your coating suppliers on thematerial safety data sheets (MSDS)for all of the materials you use. TheMSDS combined with the list ofHACs provides key information tohelp you determine how you mightbe regulated in Vermont.

An Autobody Repair Technician’s Guide to Vermont’s Environmental RegulationsAIR

POLLUTION

20

Control Division (APCD). This would include all air contaminants that are actually released to theoutside of your shop including sanding or sandblasting dust, paint solids from overspray, VOCs,HACs, and combustion by-products from building heating systems. Most autobody repair shopsdon’t emit 5 tons of air contaminants per year. The best way to determine if your shop is required toregister is to estimate your annual emissions of VOCs, since they represent the largest portion ofoverall emissions from most shops (instructions for calculating your VOC emissions are provided inAppendix F). If you determine that your VOC emissions alone are nearly 5 tons per year, then youshould contact the Air Pollution Control Division at 802-241-3840 to register. VOC emissions canalso become a regulatory concern for your shop if they result in nuisance odor complaints fromneighbors (see the “Nuisance, Odor and Particulate” section for details).

Hazardous Air Contaminants (HACs)

HACs become a regulatory issue when it is determined that the emission rate of a contaminantexceeds the action level set for it in the regulations. When this occurs, it means that measures mayneed to be taken to reduce emissions of the contaminant. Most autobody shops don’t spray enoughmaterial to exceed these thresholds for most of the HACs contained in autobody refinishing materials.For example, toluene is a HAC that is typically found in auto refinishing materials at relatively highconcentrations. Since the action level for toluene is currently set at 464 lbs/8 hr, a shop would haveto spray a very large volume of coating to exceed that level.

However, the action levels for some HACs are relatively low and the release of even a small amountcan result in an exceedance of an action level and possibly a hazardous ambient air standard (ashort list of these HACs is shown below). “Hazardous Ambient Air Standards” are set to protectpublic health and are based on the relative toxicity of the individual HAC. For example, chromium (VI)

The following is a list of HACs commonly found in coatings and other materials used in autobodyrepair shops and their associated Action Levels. The Action Level refers to the amount of the HACactually released to the environment.

VolatilesDiphenylmethane Diisocyanate ............................................................................................... 0.025Hexamethylene Diisocyanate .................................................................................................. 0.004Methylene Chloride ................................................................................................................... 0.16Methyl Ethyl Ketone Peroxide .................................................................................................... 0.631,2,4 Trimethylbenzene............................................................................................................ 0.013

SolidsBarium (Total) .............................................................................................................................. 1.0Chromium (VI) Compounds............................................................................................. 0.0000071Chromium (III) Compounds ....................................................................................................... 0.01Cobalt Compounds ............................................................................................................... 0.0062Lead Compounds .................................................................................................................... 0.014Nickel Compounds .............................................................................................................. 0.00026Titanium Dioxide ....................................................................................................................... 12.0

NOTE: This is not a complete list of HACs nor is it a complete list of HACs contained in autobodyrefinishing materials. This abbreviated list includes HACs found in autobody refinishing materials forwhich the action levels are relatively low, making it more likely that the use of even small quantitieswill result in an exceedance. These values are periodically updated based on the latest health relatedinformation, so check with the Air Pollution Control Division for the most recent values.

AIR

POLL UTION

Action Level(lbs/8 hr)

Figure 5.


POLLUTION

21

is a HAC found in some automotive coatings, usually present as lead chromate. The action level forchromium is 0.0000071 lbs/8 hr, so the potential for exceeding the action level and possibly thehazardous ambient air standard for chromium can be quite high. If you do exceed an action level, youwould likely be required to implement pollution prevention if your shop is not already doing so (see“Recommended Operating Practices” below). You could also be required to look at reformulating toless toxic coatings. A list of other HACs typically present in autobody refinishing materials is providedbelow (see Figure 5.).The most cost effective method of dealing with the issue of HAC emissions isto practice pollution prevention. The recommended operating practices listed below will help eliminateor reduce HAC emissions to levels below regulatory thresholds.

Nuisance, Odor, and Particulate Matter

Air pollution related regulatory issues at autobody shops are most often discovered as a result ofcomplaints from neighbors of strong odors or particulate emissions. The Air Pollution ControlRegulations contain broad prohibitions against creating a public nuisance, objectionable odors leavingyour property, and particulate emissions. If you do any autobody work outside that has the potentialto create dust (like grinding, sanding or sandblasting), make sure that you take appropriate steps tocontain it. The recommended operating practices listed below will help reduce your shop’s impact onthe surrounding community and prevent potential regulatory problems.

RECOMMENDED

OPERATING PRA CTI

CES

➀➀➀➀➀ Use only high volume low pressure (“HVLP”) spray equipment, or equivalent, to apply coatings andfinishes. Operators of the HVLP equipment should be adequately trained on the proper use andsetting of the equipment. The use of conventional spray guns results in unnecessary overspraywhich wastes paint, clogs filters faster, and increases air pollution.

➁➁➁➁➁ Use only coatings and finishes that comply with Federal standards for Volatile Organic Compoundcontent for autobody refinish coatings. When available, heavy metal free coatings or coatings withthe lowest metal contents should be used since these compounds are highly toxic.

➂➂➂➂➂ Perform autobody refinishing only within a properly designed spray booth equipped with an oversprayfiltration system. Frequently inspect the filters so that the system does not become clogged andineffective. Do not bypass the system by removing filters or creating holes in the filtering system toallow air to pass through without being filtered.

➃➃➃➃➃ The booth exhaust should be discharged vertically above the roofline of the building. No horizontaldischarges are recommended. The height of the stack discharge must be sufficient to avoid theexhaust being circulated adjacent to the building due to building downwash effects or drawn intonearby building intakes. A height of four (4) feet above the peak of the roof is an absolute minimum.However, site specific conditions may warrant a higher stack if buildings are located nearby whichare above the discharge. The stack must not be equipped with any device that would impede theupward discharge of the exhaust air (i.e. no raincaps). Other techniques may be employed to reducethe introduction of water and snow into the exhaust system, such as butterfly caps or stack sleeves.

➄➄➄➄➄ Be aware of the surroundings near the discharge. Avoid discharging directly into or impacting areasthat might be frequented by people, such as sidewalks or backyards.

RECOMMENDED OPERATING PRACTICES TO REDUCE AIR POLLUTION


POLLUTION

22

AIR POLLUTIONSELF-AUDIT CHECKLISTQuestions are presented in a yes/no checklist format so that if you can answer “yes” to a question, you are likely to be incompliance with that requirement. An answer of “no” could indicate a potential problem that you should investigate further.

1. We maintain purchase and/or usage records to document the quantity of material we use thatcontains VOCs and HACs in each year.

Yes ❑❑❑❑❑ No ❑❑❑❑❑

2. We keep the MSDS for all materials we use that contain VOCs and/or HACs.

Yes ❑❑❑❑❑ No ❑❑❑❑❑ N/A ❑❑❑❑❑

3. Whenever parts are not being handled, we close the cover on any cleaning equipment, such asgun washers and parts cleaning sinks, that uses a VOC-containing solvent.

Yes ❑❑❑❑❑ No ❑❑❑❑❑

4. We have completed a VOC emission calculation for all VOC-containing products used at ourfacility.

Yes ❑❑❑❑❑ No ❑❑❑❑❑

5. Our VOC calculations show that our actual VOC emissions from the facility are below 5 tons peryear. If not, we have informed the Air Pollution Control Division’s Planning Section.

Yes ❑❑❑❑❑ No ❑❑❑❑❑

You should keep your records for at least five years.

AIR

POLL UTION

You should keep your MSDSs for at least five years.

AIR

POLL UTION

AIR

POLL UTION Always cover containers that hold a volatile material to prevent evaporation. Evaporation is a waste of rawmaterials and increases worker exposure to hazardous and/or toxic compounds.

AIR

POLL UTION Details on how to perform VOC emission calculations are contained in Appendix F. Call the DEC AirPollution Control Division at (802) 241-3840 with any questions.


POLLUTION

23

6. Our facility is below the “action level”, for all hazardous air contaminants (HACs). If not, we haveinformed the Air Pollution Control Division’s Field Services Section.

Yes ❑❑❑❑❑ No ❑❑❑❑❑AIR

POLL UTION Due to the many site specific variables and complexity involved in calculating HAC emissions, an examplehas not been provided in this guide. However, assistance is available either from the DEC Air Pollution

Control Division at (802) 241-3840 or the Environmental Assistance Division at (800) 974-9559.


POLLUTION

24

POLLUTION PREVENTION &BEST MANAGEMENT PRACTICES

What Is Pollution Pre vention And Ho w Can My Shop Benefit Fr om It?

Pollution Prevention (P2) is the use of materials, processes, or practices that reduce or eliminate thegeneration of waste or pollution. How do you start preventing pollution in your shop? P2 begins byunderstanding what goes on in your shop: the processes that are used, the materials that arepurchased, and the waste and pollutants that are created. This section of the guide has been designedto help you identify opportunities to reduce waste, air and water pollution, promote a safer, healthierworking environment and reduce costs (see Appendix I for additional pollution prevention resources).

Some of the benefits of practicing Pollution Prevention...

Benefits ofPollution

Prevention

Reduced Regulatory Burden

Reduced Operating Costs

○ ○ ○ ○ ○

Healthier Work Environment

Decreased Liability

Increased Efficiency

○ ○ ○ ○ ○

Lower Waste Management &Disposal Costs

○ ○ ○ ○ ○

Enhanced Business Image○ ○ ○ ○ ○Reduced Chemical Purchases

POLLUTION PREVENTIONSELF-AUDIT CHECKLIST

Materials Purchasing, Inventory & StorageThe following is a series of questions designed to help explain good materials management practices that canhelp you reduce waste, prevent pollution and reduce costs.

1. Do you review MSDS sheets for products before making a purchase and choose less hazardous/toxic materials where alternatives exist?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

An Autobody Repair Technician’s Guide to Vermont’s Environmental Regulations POLLUTION

PREVENTION

25

2. Is your inventory used in a first-in first-out order?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

3. Are outdated materials returned to the supplier when possible?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

4. Does your current inventory system adequately prevent waste generation?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

5. Is the dispensing of raw materials supervised and controlled?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

6. Do you limit access to material storage areas?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

POLLUTION

PREVENTION This is probably the most important thing you can do. Purchasing less hazardous/toxic materials promotesa safer, heathier, working environment for your employees. Also, materials that contain less hazardous/

toxic ingredients can result in reduced hazardous waste generation, and air and water pollution. For example,if you spray coatings containing heavy metals such as lead or chromium, the overspray trapped in your boothfilters may require that you manage the filters as a hazardous waste. If you don’t spray coatings containingheavy metals, your filters are less likely to be hazardous.

POLLUTION

PREVENTION Using materials in the order they are received in your shop helps reduce the generation of hazardouswaste due to product shelf-life expiration or obsolescence.

POLLUTION

PREVENTION Some coating suppliers will accept expired materials provided they are not very old and can be reformulated.If possible, this would reduce your disposal costs and would allow for recycling of the material.

POLLUTION

PREVENTION A computerized inventory system can help prevent the purchase of materials already on hand, reducingwaste related to expired materials. Computerized inventory tracking can also help identify where material is

being used excessively.

POLLUTION

PREVENTION Supervising dispensing and/or limiting access to materials allows you to monitor use of materials todetermine whether a waste problem is related to the work practices of an individual worker(s) or if it is a

problem shop wide related to equipment or work practices.

An Autobody Repair Technician’s Guide to Vermont’s Environmental RegulationsPOLLUTION

PREVENTION

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Surface Preparation & Paint Mixing & ApplicationThe following is a series of questions designed to help explain surface preparation and paint mixing andapplication techniques that will help you make more efficient use of materials, reduce waste and promote ahealthier work environment in your shop.

1. Do you use good housekeeping practices?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

2. Do you use a vacuum sanding system?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

3. Do you do any wet sanding?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

4. Do you use a broom or vacuum to clean up around sanding jobs?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

5. Do you use solvents for paint stripping in your shop?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

POLLUTION

PREVENTION Instituting good housekeeping practices (such as mixing only as much paint as you need, using easy-to-clean paint cups, and keeping lids closed) will help reduce wastes, HAC and VOC emissions and promote

a safer, healthier, work environment.

POLLUTION

PREVENTION To contain all sanding and paint debris, use a vacuum sanding system. This would promote a healthierwork environment and possibly extend the life of your sandpaper. Before disposing of sanding dust, determine

whether the waste is hazardous.

POLLUTION

PREVENTION When wet sanding, allow the wastes to dry, then sweep them up and dispose of them. Before disposing ofwet sanding waste, determine whether the waste is hazardous.

POLLUTION

PREVENTION Use of a broom or a vacuum with proper dust-collecting filters instead of using water and solvents to cleanhelp to prevent wastewater from becoming contaminated (and possibly hazardous). Before disposing of any

collected material, determine whether the waste is hazardous.


PREVENTION

27

POLLUTION

PREVENTION Chemical paint stripping produces a large volume of liquid waste which may be hazardous and releaseVOCs and HACs in your shop. Some chemical strippers contain methylene chloride. Methylene chloride is

a HAC and has a very low action level of 0.16 lbs/8 hr due to its high toxicity. One commercially available paintstripper contains 67% by weight of methylene chloride. The use of only 3.8 ounces of this particular stripperin an 8 hour period could result in an exceedance of the action level.

6. Do you follow these practices during surface preparation to minimize air emissions?

CleaningAlways wash dirt and grime from the vehicle using a soap andwater mixture.

Use waterborne cleaners when possible.

If, due to heavy contamination, waterborne cleaners proveunsatisfactory, use solvent based cleaners for the initial cleaning.For secondary cleaning operations, use the waterborneproducts.

If waterborne cleaners prove unsatisfactory due to substratemakeup, use solvent based cleaners sparingly.

Prep CoatsUse versatile products such as epoxy primers or self-etchingprimers. The use of these products may alleviate the need foradditional surface coating operations such as primer-surfacingor primer sealing.

If a self-etching primner or epoxy primer is not desirable, use awash primer, or metal conditioner, conversion coating system.

Avoid zinc-phosphate primers with high VOC content.

Primer-SurfacersUse a properly operating primer gun with the correct fluid tip/aircap combination for your particular type of primer-surfacer.

Use low VOC waterborne primer-surfacer products.

If the curing time of waterborne products proves unsatisfactory,consider the use of versatile urethane primers.

To reduce VOC emissions, limit material costs, and achieve abetter quality product, perform body work using a minimalamount of primer-surfacer.

If a colored sealer is not used, make sure the primer-surfacer isa color that can be easily covered with the desired topcoat.

Primer SealersUse low VOC primer-sealers such as single componentwaterborne primers or waterborne epoxy primers.

Use low VOC urethane primer-sealers as an alternative whenpossible.

Always choose a color of primer-sealer that can be easily coveredwith the topcoat to be sprayed, or chose a tintable and tint it toan easily covered shade.

















PREVENTION

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SealersChoose the proper sealer for each specific job.

If filling capabilities are required, use a primer-sealer in place ofa sealer.

TopcoatsMix color coats in-house, making certain the formula for theproper shade of the specific color is used. This will help avoidthe need for blending the finish to achieve a satisfactory colormatch.

Keep good records of paint match information, including spray-out cards and detailed notes.

Avoid the use of lacquer-based topcoats.

Choose low VOC topcoats that require fewer than three coatsto achieve adequate coverage (polyurethane or urethane).

Apply only the number of coats needed to achieve a qualityfinish.

Use high solids/low VOC clears to topcoat color coats.

Keep the use of paint additives to a minimum.

When available, use waterborne basecoats.

7. Do you require your operators to be trained in paint application techniques?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

8. Are you concerned about the application efficiency of your spray guns?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

9. Do you mix just enough paint to complete a job?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

10. Do you follow these practices when spraying materials to reduce air emissions?

Select the suggested air pressure and tip sizes for the specificproduct and equipment being used.

Always hold the gun perpendicular to the surface being sprayed,using parallel strokes. Never arc the gun.

Feather the trigger at the beginning and end of each pass.











POLLUTION

PREVENTION The transfer efficiency of a traditional air-atomized spray gun is reported to be about 30% while that of anHVLP spray gun is approximately 65%. The use of equipment with a higher transfer efficiency not only reduces

the environmental impact of operations, it also improves working conditions and reduces material costs.





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29

Use a 50% overlap for each pass. (Note: This technique mayneed to be altered slightly when applying high metallic, highsolids basecoats and some three stage systems.)

When painting small and medium sized panels, make each passthe full length of the panel.

With larger panels, use a comfortable stroke, with a 4 - 5” overlapof the strokes.

If blending is necessary, keep the blend area as small as possiblewithout jeopardizing the appearance of the blend.

Spray the border edges of the substrate first (banding). This willassure all edges are covered without extending the spray patternwell beyond the borders of the object.

Use color hiding power labels to determine the thickness of theof the applied film. These markers will also indicate whenadequate coverage has been achieved.

Painting Equipment CleanupThe following is a series of questions designed to help explain paint equipment cleanup techniques that willhelp you reduce waste and promote a healthier work environment in your shop.

1. Do you use a mechanical gun cleaning system?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

2. Do you use low VOC cleaning solvents?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

3. If you do manually clean spray equipment, do you capture the sprayed cleaning solvent in acontainer for possible reuse and/or proper disposal?

Yes ❑❑❑❑❑ No ❑❑❑❑❑







POLLUTION

PREVENTION Manual cleaning of spray gun systems can be time consuming and result in the release of excessiveamounts of VOCs and HACs into the environment. Manual cleaning also unnecessarilly exposes the operator

to large quantities of potentially dangerous solvents. Mechanical cleaning systems free up operators to performother tasks, reduce waste and air emissions and promote a safer, healthier workplace.

POLLUTION

PREVENTION Cleaning spray equipment by spraying cleaning solvent through the gun into the air without capturing thesolvent constitutes illegal disposal of hazardous waste. Spraying cleaning solvent into booth filters may

make the booth filters an F-listed hazardous waste depending on the solvent(s) being used. These practicesalso waste solvent that could be reused for a first (rough) cleaning in subsequent equipment cleanup.


PREVENTION

30

4. Do you use mechanical methods to clear passageways (e.g. broom straw, cleaning broach, or asoft wood toothpick)?

Yes ❑❑❑❑❑ No ❑❑❑❑❑

5. If you generate large quantities of spray system cleaning solvent, have you evaluated the economicfeasibility of purchasing an on-site solvent recycling system?

Yes ❑❑❑❑❑ No ❑❑❑❑❑POLLUTION

PREVENTION For more information on small solvent recycling systems or assistance in determining if solvent recyclingmakes economic sense for your shop, contact EAD at 800-974-9559.


PREVENTION

31

FACT SHEETS

Used Oil ..........................................................................................................FS 1Used Oil Burning .............................................................................................FS 2Oily Wastes .....................................................................................................FS 3Shop Rags ......................................................................................................FS 4Oil Filters .........................................................................................................FS 5Antifreeze ........................................................................................................FS 6Parts Cleaning Solvent ....................................................................................FS 7Paints and Thinners .........................................................................................FS 8Spills ................................................................................................................FS 9Floor Drains ...................................................................................................FS 10Dust Control & Management .........................................................................FS 11Scrap Tires ....................................................................................................FS 12Lead Acid Batteries .......................................................................................FS 13Refrigerants ...................................................................................................FS 14Recyclable Materials .....................................................................................FS 15

An Autobody Repair Technician’s Guide to Vermont’s Environmental Regulations FACT

SHEETS

Envir onmental Assistance DivisionVermont Ag ency of Natural Resour cesDepar tment of En vir onmental Conser vation103 South Main Street, Waterb ury, VT 05671-0411

E-mail: [email protected] .state .vt.usWeb Site at http://www .anr.state .vt.us/dec/dec.htm

EAD Hotline 800-974-9559, 802-241-3589 (out of state)

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Used OilUsed OilEADEADENVIRONMENTALA S S I S T A N C ED I V I S I O N

An Envir onmental Mana gement Fact Sheet f or Autobod y Repair Shops on...An Environmental Management Fact Sheet for Autobody Repair Shops on...

How Is It Regulated?

Used oil is regulated under the “Used Oil Management Standards” in Subchapter 8 of theVermont Hazardous Waste Management Regulations. Used oil that is managed in accordancewith the Used Oil Management Standards is not considered hazardous waste and should notbe counted when determining your generator status. It is not required that you ship “Used Oil”under a manifest. However, if you choose to use a manifest, or your transporter requires it, thematerial should be identified on the manifest by the VT99 waste code for non-hazardous waste.“Used Oil” might include the following wastes generated in a autobody repair shop:

➙ vehicle crankcase oils➙ transmission fluids➙ power steering fluids

What Can Be Done With it?

➙ Send it off-site to be fuel-blended and burned for energy recovery OR to be re-refined forreuse as a lubricant.

➙ Reuse it to lubricate chains, tools and other machinery. Don’t let it drip on the ground.➙ Burn it on-site as a fuel in a waste oil space heater.

(see Used Oil Burning Fact Sheet for additional information)➙ Give or sell it to others as a fuel to burn in a waste oil space heater.

(see Used Oil Burning Fact Sheet for additional information)

What Can’t Be Done With It?

➙ Used oil cannot be disposed of in a Vermont landfill.(check with the Solid Waste District in your area to see if they have a collection program for small businesses)

➙ Used oil cannot be applied to roads for dust control.➙ Used oil cannot be mixed with a hazardous waste with the exception that used oil may

be mixed with waste that is hazardous solely because it exhibits the characteristic ofignitability (e.g. ignitable-only mineral spirits), provided that the resultant mixture doesnot exhibit the characteristic of ignitability.

How Do I Store Used Oil?

If stored above-ground, ensure that tanks or containers are:➙ in good condition and made of or lined with compatible materials,➙ kept closed except when adding or removing used oil,➙ labeled with the words “Used Oil”,➙ located on an impervious surface within a structure that sheds rain and snow,

You must also adhere to the following requirements:➙ up to 1,320 gallons may be stored on-site before arrangements to ship must be made

and no single container can exceed 660 gallons capacity. An amount greater than thiscan only be stored above-ground IF:1) all applicable Spill Prevention, Control and Countermeasure requirements of 40CFR

Part 112 are met;2) oil is not stored on-site longer than 180 days;3) each container is marked to identify the date it became full.

➙ tanks located outdoors must be equipped with secondary containment able to hold 110%of the tank’s volume.

If stored in an Underground Storage Tank , contact the UST Program (241-3888) to obtain a permit.

How Do I Transport Used Oil?

Used oil generators can self-transport up to 55 gallons at any one time in a Department ofTransportation approved container without obtaining a permit. “Used oil transporters” of more than55 gallons must complete a Notification of Regulated Waste Activity Form and obtain a permit. Callthe Waste Management Division (241-3888) for more information.

Page 2 Used Oil: A Fact Sheet f or Autobod y Repair Shops




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Used Oil BurningUsed Oil BurningHow Is It Regulated?

All activities related to the burning of used oil are regulated under Subchapter 8 of the VermontHazardous Waste Management Regulations (VHWMR) and Section 5-211(2) of the Air PollutionControl Regulations. Used oil burning activities include: burning used oil generated at yourfacility, burning used oil generated by others, and giving or selling your used oil to another

burner. If you are involved in any of these activities,you must notify the Waste Management Division.Notification is done using the Notification of RegulatedWaste Acitivity Form (see Appendix A). This fact sheetonly addresses the burning of used oil in small fuelburning equipment, defined as having a maximumoperating heat input equal to or less than 500,000BTU/hr (the use of “pot burners” or “vaporizing burners”is prohibited). Burning in larger equipment is subjectto more stringent regulation.

NOTE: other types of used oil (e.g. hydraulic fluids,compressor oils, etc) may be burned provided permissionis first obtained from the Waste Management Division (WMD).Decisions are based on a review of any relevant materialsafety data sheets and a description of the processgenerating the used oil.

Burners Of Specification Used Oil

The types of used oil that may be burned in small fuel burning space heaters are vehiclecrankcase and machine gearbox oil which meets the “specifications” shown in the table above.Specification used oil from the following sources can be burned in small fuel burning equipment:

☞ used oil generated on site,

☞ used oil generated off-site from either “do-it-yourselfers” (used oil generated by households)or from facilities owned or operated by the burner,

☞ used oil generated off-site from facilities not owned by the used oil burner provided:

➙ the “marketer” (defined on the following page) of the used oil demonstrates that theused oil meets specifications;

➙ the facility accepting the used oil retains records which show the amount of used oilaccepted, specification testing results, and the name, address and telephone numberof the marketer for a period of three years; and

➙ the facility accepting the used oil has notified the Waste Management Division of itsstatus as a used oil collection facility.

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Used Oil Burning: A Fact Sheet f or Autobod y Repair Shops

Burners of used oil in small fuel burning equipment must also comply with the following requirements:

☞ The combustion efficiency of the equipment must be at least 99 percent while burning waste oil.☞ The combustion gases from burning used oil must be vented to ambient air. It is also suggested

that stacks not be equipped with any device that would impede the upward discharge of theexhaust gases (i.e. no raincaps).

☞ Emissions of visible air contaminants must not have a shade or density greater than 20%opacity for more than a period or periods totaling six minutes in any hour. At no time should thevisible emissions exceed 60% opacity.

☞ Used oil generators that burn their own used oil on-site, or that burn off-site generated used oilreceived in shipments less than or equal to 55 gallons in volume, must initially test the used oilfrom each source for total halogens . A field screening test kit may be used to assure that nomore than 1,000 parts per million (ppm) of total halogens are present in the used oil. If there isreason to believe that any of the remaining specifications would not be met by a volume of usedoil (e.g. >500 ppm chlorine), the used oil generator must test the used oil for any suspectedconstituents or properties.

☞ Used oil marketers offering used oil fuel to burners in shipments greater than 55 gallons mustinitially test the used oil and maintain copies of analytical and testing results to establish thatthe oil meets each of the specifications.

☞ Used oil fuel from a specific source must be re-tested if there is reason to believe that thequality of the used oil - or the process that generates the used oil - has changed such that thespecifications would not be met.

☞ A facility burning used oil fuel shall maintain records documenting the amount of used oil fuelburned on-site. These records shall be retained for a period of three years.

☞ No more than one space heater may be connected to an above-ground storage tank (VOSHA).

Specification Used Oil Marketers

A used oil “marketer” is any entity that either directs used oil fuel from their facility to a used oil burneror who first claims that used oil (intended to be burned for energy recovery) meets the used oil fuelspecifications. Anyone who gives, sells, or otherwise provides used oil to someone else to be usedfor fuel blending or burning is considered to be a marketer. Marketers must complete a Notification ofRegulated waste Activity form. Used oil marketers initiating or accepting a shipment of used oil fuelmust maintain the following records for a minimum of three years:

☞ Copies of all analytical and test results applicable to the shipment of used oil fuel, and/ordocumentation of total halogen field screening results;

☞ An operating log for all shipments of used oil fuel that includes the following information:➙ the name, EPA identification number, and address of the facility to which used oil fuel is

sent or from which used oil fuel is received;➙ the quantity of used oil fuel shipped or received;➙ the date of shipment or delivery; and➙ name, EPA identification number, and address of the transporter.

Contact the Environmental Assistance Division at 1-800-974-9559




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Oily WastesOily WastesHow Are They Regulated?

Oily wastes are a typically generated at autobody shops. Under the Vermont Hazardous WasteManagement Regulations (VHWMR) any waste (solid or liquid) containing greater than 5% byweight of petroleum distillates having a melting point of less than 100oF is considered to behazardous. Some possible sources of oily wastes in a typical autobody repair shop are:

➙ oil soaked sorbents (pads, booms or granular)➙ sludge/grit from floor drain troughs➙ sludge/grit from oil/water separators➙ floor sweepings

Any waste materials which contain 5% or more by weight of oil (with the exception of vegetable-based oil) must be managed as a hazardous waste. Where you are unsure as to the amount ofoil in these wastes, a one time test of the material for total petroleum hydrocarbons (TPH) canbe done to determine the level of oil present. Copies of the test results should be kept on file.For solids like pads or granular material, the weight of uncontaminated material can be comparedwith its weight after use to determine if there has been at least a 5% increase. (Note: Granularabsorbents are manufactured to absorb up to 300% - 500% its own weight of oil.)

Oil that can be drained, separated, or removed from any of the above materials can be managedas a “used oil” (see Used Oil fact sheet) and therefore would not have to be managed as ahazardous waste. In the case of oily wastewater, while the separated oil may be managed as aused oil, the remaining oil-contaminated water cannot be, and probably would need to beanalyzed to determine if the 5% by weight petroleum threshold has been exceeded. Evenwhere analysis indicated petroleum distillate content of less than 5% (non-hazardous) it wouldnot be possible to discharge this wastewater to a municipal treatment plant without permissionof the local authority (see the Wastewater Discharges compliance checklist).

Best Mana gement Practices

When it comes to minimizing or even eliminating oily waste generation, the rule of thumb issimply to practice good housekeeping, including a preventive maintenance program to minimizethe chance for leaks and spills.

In many cases, oily wastes are generated in unnecessarily large volumes and can be reducedby some relatively simple source reduction methods. The following are a few suggestions tohelp reduce oily wastes:

Oily Wastes: A Fact Sheet f or Autobod y Repair Shops

➙ Identify the circumstances that result in oil reaching the shop floor (necessitating the useof sorbents and contaminating floor sweepings and floor drain catch basin grit) anddevelop a spill prevention plan that addresses each of these circumstances includingmeasures that can be taken to prevent their occurrence.

➙ It is impossible to prevent all spills from occurring. When a significant volume of oil isspilled, pick it up with a wet-vac or a squeegee and dust pan and put it in with your usedoil. The use of sorbent materials only increases the volume of waste and results in awaste that now must be managed as a hazardous waste.

➙ Wipe up drips and small quantities of oil with launderable shop rags (see the Shop RagsFact Sheet).

➙ Use drip pans, funnels, drain trays, etc. to prevent oil and other fluids from reaching theshop floor.

➙ Where sorbents must be used, try wringable/reusable sorbent pads or socks, or granulartype sorbents that have a high absorbency to weight ratio. Sorbents from which oils canbe removed so that they can be reused don’t have to be managed as a hazardous wasteuntil such time that they must be disposed of. If granular type sorbents must be used,make sure they are completely used prior to disposal. Partially used sorbents may bestored in a secondary container for reuse.

➙ Preventing oil from getting on the floor is the best way to prevent floor sweepings fromhaving to be handled as a hazardous waste. Clean floors regularly to remove dirt beforeit has a chance to become contaminated and don’t sweep dirt into troughs or basins.




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Shop RagsShop RagsHow Are They Regulated?

Wipers, shop towels and other reusable absorbents that are contaminated with “listed” hazardouswaste or that exhibit a hazardous waste “characteristic” (see Hazardous Waste compliancechecklist) are by policy considered to be exempt from the provisions of the Vermont HazardousWaste Management Regulations if:

☞ shop towels or absorbents are picked up, cleaned and delivered back to the customerunder a contractual agreement with a commercial laundering service which uses eithera solvent-based dry cleaning or a water-based laundering process to clean the wipers/absorbents; and ,

☞ hazardous waste has not been disposed of onto the wipers and free liquid hazardouswaste is not present; and ,

☞ hazardous waste-contaminated reusable absorbents that are on-site must be:

➙ stored in closed bags or containers on an impervious surface in a roofed enclosureso as to be protected from the elements; and

➙ containers labeled as “Used Rags or Absorbents Destined for Laundering”; and➙ the laundering facility properly manages all residuals and waste from the laundering

process.

Under this policy exemption, provided that all of the above management requirements are met,reusable absorbents that have been soiled with hazardous waste(s);

➙ do not have to be managed as hazardous waste (although they must be stored asoutlined above),

➙ do not need to be shipped under a manifest to a licensed hazardous waste treatment,storage, or disposal facility,

➙ do not count toward the total monthly on-site generation of hazardous waste.

Generators of contaminated absorbents (managed under this policy exemption) should be awarethat such materials are still considered to be hazardous substances and that liability remainswith the generator in the event of mismanagement or an environmental release. Also, it is thegenerator’s responsibility to meet all Vermont Occupational Safety & Health Act (VOSHA)requirements regarding the safe storage of hazardous materials, including that absorbentscontaminated with an ignitable material be stored in a closed metal container.

NOTE: Rags or other reusable absorbents that are contaminated with a Vermont or Federal“listed” hazardous waste or that exhibit a hazardous “characteristic”, and that are not handledin accordance with this policy, must be managed as hazardous waste.




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Why Are They Regulated?

Used oil filters from businesses are regulated as hazardous wastes because they may containsignificant amounts of waste oil. The oil, its additives and combustion byproducts can contributeto water pollution when released to the environment. Long term exposure to oil and fuelcombustion by-products are suspected to cause cancer.

How Should They Be Managed?

How used oil filters must be managed depends on how they are drained. Non-terne plated oilfilters can be recycled or disposed of as solid waste provided that they are drained by:

➙ crushing,➙ hot-draining and crushing,➙ dismantling and hot-draining,➙ puncturing the filter anti-drain back valve or filter dome end and hot-draining, or➙ any other equivalent hot-draining method that will remove used oil.

Used oil filters that are not drained by one of the above methods must be managed ashazardous waste . Opportunities exist for recycling properly drained filters. Check with scrapyards and local solid waste officials for available recycling opportunities. The DEC encouragesthe recycling of used oil filters whenever possible .

Pollution Pre vention and Best Mana gement Practices

➙ Crush or puncture the dome or anti-drain valve and hot drain filters.➙ Collect oil from filter crushing and manage the same way as engine waste oils.➙ Store drained and crushed filters in a leak proof container until recycled or disposed.➙ Recycle drained or crushed filters with scrap metals.

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Why Is It Regulated?

Antifreeze, which is comprised of ethylene glycol, water, and corrosion inhibitors, is toxic to humansand animals. Used antifreeze may also contain heavy metals that can contaminate soil andgroundwater. Waste antifreeze (ethylene glycol based coolant) is listed as a regulated hazardouswaste in the Vermont Hazardous Waste Management Regulations (VHWMR) and is identified bythe VT08 hazardous waste code. The degree to which antifreeze is regulated varies greatly dependingon how the generator decides to manage the used or waste material. Antifreeze that is reused orrecycled on-site is the least regulated while that which is sent off-site for disposal is the most highlyregulated. The simplest way to reduce your business’ regulatory burden would be to reuse or recycleantifreeze on-site whenever possible.

Used Antifreeze

Antifreeze that has been removed from a vehicle and is to be recycled and/or treated and reusedon-site is considered “used antifreeze”. As such it does not have to be managed as a hazardouswaste provided that the following conditions are met:

☞ The used antifreeze is of sufficient quality that it can be replenished through recyclingand/or treatment and reused,

☞ Containers holding used antifreeze that is to be recycled and/or treated for reuse on-sitemust remain closed except when adding or removing material,

☞ Containers holding used antifreeze which is to be recycled and/or treated for reuse on-site must be marked with words “USED ANTIFREEZE TO BE RECYCLED” .

☞ Any residue resulting from on-site recycling/treatment which exhibits a characteristicmust be managed as a hazardous waste.

☞ At any given time, no more than 275 gallons of used antifreeze that is to be recycled and/or treated for reuse may be stored on-site.

Used antifreeze that is of sufficient quality that it can be reused without recycling and/or treatmentis also considered “used antifreeze”. Giving this material away to customers, employees or otherswho intend to reuse the antifreeze is an acceptable practice. However, due to the potential liabilityinvolved, the generator should exercise caution and ensure that it is being used for a legitimatepurpose.

Waste Antifreeze

Antifreeze that has been removed from a vehicle and is to be shipped off-site for either recyclingor disposal is considered “waste antifreeze”. Waste antifreeze is a Vermont listed hazardouswaste. This material may also be Federally regulated if it exceeds the maximum concentration

Antifreez eAntifreez e

Antifreez e: A Fact Sheet f or Autobod y Repair Shops

limits for certain heavy metals (lead is the primary concern), benzene or other listed “toxic” materials.This determination is made by testing a sample of the waste using a method referred to as the ToxicCharacteristic Leaching Procedure (TCLP). For the purpose of determining the generator status of afacility, only that antifreeze which is not exempted from regulation as a hazardous waste should beincluded. Examples of antifreeze waste that should be counted toward your generator status include;

➙ Antifreeze shipped off-site destined for incineration, fuel blending, or treatment not resultingin reuse.

➙ Antifreeze shipped off-site that exceeds certain concentrations for lead, benzene, orperchloroethylene.

Waste antifreeze is exempt from regulation as a hazardous waste provided that:

☞ It does not exceed the maximum concentrationfor any of the contaminants listed in the tableon the right; and

☞ It is destined for recycling.or

☞ Permission has been obtained from the local sewer authority and Vermont’s WastewaterManagement Division (WWMD) to discharge the waste to a municipal wastewater treatmentfacility. Although it is not required, it would be in the best interest of the discharger of thewaste to obtain this permission in writing and keep a copy on file until the practice isdiscontinued. The DEC strongly discourages the discharge of waste antifreeze to municipalwastewater treatment facilities and encourages the recycling and reuse of this materialwhenever possible.


➙ Test antifreeze for properties such as corrosion inhibition and freeze protection beforereplacing and replace only when necessary.

➙ Substitute less toxic propylene glycol for ethylene glycol where feasible.Note: If disposed of, propylene glycol is not considered a VT08 Vermont regulated waste, however, it mightbe a federally regulated waste if it exceeds the maximum concentration for any of the contaminants listed inthe table above.

➙ Use “extended life” antifreeze products. Some manufacturers of these products claimthat they will last for up to five years or 100,000 miles in automobile engines and up to300,000 miles in heavy duty diesels.

➙ Where the vehicle manufacturer’s warranty allows, use recycled antifreeze.➙ Recycle antifreeze either on-site or off-site. There are a number of technologies available

for on-site recycling of antifreeze including: filtration, distillation and ion exchange. (Formore information on antifreeze recycling equipment, contact EAD)

➙ Don’t mix other vehicle fluid waste with used or waste antifreeze.

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How Is It Regulated?

Parts cleaning is an essential part of vehicle maintenance and repair operations. The extent towhich parts cleaning solvents are regulated varies depending on the type of solvent used and thecontaminants that it collects duringuse. The chart below shows the mostcommonly used parts cleaningsolvents, the characteristic(s) thatmight cause the spent solvent to beregulated as hazardous, and theappropriate hazardous waste code.

If oils and greases can be separatedfrom spent aqueous cleaningsolutions, it may be possible todischarge the aqueous portion to amunicipal wastewater treatmentplant. Prior to discharge, permissionshould be obtained from the local sewer authority and Vermont’s Wastewater ManagementDivision. Although it is not required, it would be in the best interest of the discharger to obtainthis permission in writing and keep a copy on file until the practice is discontinued.

Many shops enter into solvent leasing contracts under which a parts cleaning sink and solventare leased to the shop. It is important to be aware of the fact that, in most cases, the shop isconsidered the generator of any waste solvent removed by the service provider. This meansthat any solvent waste determined to be hazardous counts towards the shop’s monthly total forthe purposes of determining generator status. Some solvent leasing companies have what isreferred to as a “recycle-reuse exemption” for the solvent they lease. If you contract with one ofthese companies, the solvent removed from your sink is not considered hazardous waste becauseit is being recycled in a manner approved by Vermont’s Waste Management Division. This typeof arrangement can be beneficial to your shop because it helps reduce your monthly hazardouswaste generation.

The following requirements apply to all parts cleaning sinks or washers using solvents thatcontain volatile organic compounds (VOCs), such as petroleum naphtha, mineral spirits, andterpenes:

☞ The parts cleaning unit must have a cover and the cover must be kept closed exceptwhen parts are being cleaned.

☞ If parts cleaning solvent is sprayed, the pressure of the spray cannot exceed 10 psi.

Parts Cleaning SolventParts Cleaning Solvent

NOTE 1: A spent petroleum solvent that is hazardous waste ONLYbecause it exhibits the ignitability characteristic may be mixed withUsed Oil providing the resulting mixture is not ignitable.

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Parts Cleaning Solvent: A Fact Sheet f or Autobod y Repair Shops

☞ Only parts that are non-porous and non-absorbent can be washed.

☞ Discontinue operation of the parts cleaner if visible solvent leaks are detected until theleaks are repaired.

☞ Drain cleaned parts until dripping ceases.


➙ Replace hazardous solvents with less/non hazardous solvents or aqueous-basedcleaners. This will not only reduce environmental regulatory burdens but will also improveworker health and safety conditions in your shop. (For more information on alternativeparts cleaning solvents contact EAD.)

➙ Investigate aqueous, microbial parts cleaning solutions. The cleaning chemistry is anaqueous detergent that includes hydrocarbon degrading microbes. The detergent cleansthe parts and the microbes clean the cleaner. This can reduce or eliminate parts cleaningwaste.

➙ Where parts cleaning sinks are leased from a solvent recycling service, ensure that thesolvent is only replaced when it is no longer effectively cleaning parts. Arrange forchangeout of solvent to be done as infrequently as possible.

➙ Use a wire brush, launderable rags or some other mechanical method to remove heavydeposits before cleaning with solvent.

➙ Solvent life can be greatly extended through the use of filtration systems. Purchase orlease equipment that incorporates some type of filtration system (cyclonic, cartridge,etc.) or add filtration to an existing unit. This will extend the solvent’s useful life, reducinghazardous waste generation and the cost of purchasing new solvent.

➙ Never clean parts in your solvent sink using aerosol spray cleaners. Many of these cleanerscontain halogenated or other organic compounds that may cause your spent solvent tobe more strictly regulated.

➙ Don’t leave solvent running and cover parts cleaning equipment when not in use. Thiswill help reduce air emissions and promote a safer, more healthy work environment.




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Paints & Thinner sPaints & Thinner sWhy Are They Regulated?

Painting wastes result from overspray and paint gun cleaning operations. Solvent-based wastepaint is regulated as a hazardous waste because it is toxic or ignitable or both. In addition to thesolvent content, some paints contain heavy metal compounds such as lead, cadmium orchromium that will also cause byproducts (like paint filters) to be hazardous for toxicity. Thinnersused for cleaning equipment often contain solvents such as xylene, methyl ethyl ketone, tolueneand acetone. These waste solvents are also hazardous due to their ignitability and/or toxicity.

How Must They Be Managed?

Paints and thinners must be disposed of as hazardous (See Section on Hazardous Waste). Ifyour facility is a Conditionally Exempt Generators (CEG) of hazardous waste, meaning yourbusiness generates less than 2,640 pounds per year of all hazardous wastes combined, youhave some flexibility in how you manage, store and transport small amounts of hazardouswaste. Check with the Solid Waste District in your area to see if they will take small quantities ofwaste paint and thinner.

Use your MSDS (Material Safety Data Sheets) to help with hazardous waste determinations for“questionable” wastestreams - for example, used paper filters or water-based coatings.

Use of solvent-based paints and thinners also results in the emission of two major types of aircontaminants - VOCs (volatile organic compounds) and particulates (small, air-borne particlesof solid or liquid matter). Vermont’s Air Pollution Control Regulations contain broad authorityprohibiting the discharge of particulates to the air, especially where such emission can result ina public nuisance and/or odor. If total amount of air contaminants emitted by a facility exceeds5 tons per year, the facility must register with the Air Pollution Control Division (241-3840).

What Can’t Be Done With Them ?

Solvent-based paints and thinners cannot be disposed of in the landfill.Solvent-based paints and thinners cannot be discharged to a sewer.Solvent-based paints and thinners cannot be air dried to dispose of VOCs.




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SpillsSpillsWhat Are They?

A spill is an accidental release of a hazardous material to the environment. For example, threegallons of used oil that is spilled on an impermeable garage floor that ends up going down thefloor drain which leads directly to a dry well must be reported, whereas the same three gallons,captured, contained and recovered before it can be released to the environment, does not needto be reported.

When Is Reporting Required?

Any spill of petroleum that results in a release to the environment of 2 gallons or more must bereported as soon as possible to the Waste Management Division at 241-3888 during normalworking hours or by calling the 24-hour emergency number at 244-8721 or 1-800-641-5005.Spills of hazardous materials other than petroleum must be reported where the environmentalrelease exceeds 2 gallons OR any amount that poses a potential threat to health or theenvironment.

In the event of a spill :

☞ Contain the flow of material by using a bucket, barrier, temporary dike, channels or othercontainment vessel to make cleanup and recovery easier. Don’t let it enter floor drains .

☞ Recover liquids for recycling if possible, otherwise properly dispose of. One suggestionis to use an explosion-proof wet vac or squeegee to collect as much of the liquid aspossible. This will minimize the amount of material that has to be placed in the hazardouswaste drum. If you rely on absorbents, (speedi-dri, pads, “magic sorb”, etc) use up asmuch as possible. Contaminated absorbents must be properly disposed of as a hazardouswaste.


☞ Develop a basic spill prevention plan that addresses some of the following items. Involveemployees as they may be the most knowledgeable regarding how and why spillssometimes occur.

☞ Maintain spill control and containment equipment in a designated area.

☞ Instruct employees in proper spill response procedures, including basic safety precautionslike:

Spills: A Fact Sheet f or Autobod y Repair Shops

➙ Minimize touching or walking in spilled material;➙ Minimize inhalation of any resulting gases, vapors or smoke;➙ Wash promptly if skin comes in contact with material.

☞ Post a list of emergency numbers next to the phone.

☞ Use drip trays, funnels or other means when transferring liquids.

☞ Use spring-loaded covers, valves or other positive shut-offs to prevent the accidental dischargeof hazardous materials to floor drains.




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Floor DrainsFloor DrainsHow Are They Regulated?

The discharge of fluid wastes from floor drains to the subsurface (leach field, drywell, etc) isregulated as an Underground Injection Control (UIC) Well. The discharge of fluid wastes fromfloor drains to the ground surface is a practice referred to as day-lighting. In either case, theactivity is regulated by the Wastewater Management Division. Floor drains are subject to theFloor Drain Procedure signed by the Commissioner of the Department of EnvironmentalConservation (DEC) in October, 1993 and the EPA Class V Injection Wells Rule.

Day-lighting

Floor drain discharges to the ground surface are prohibited if the discharges originate fromvehicle maintenance areas or from vehicle washing facilities. However, snow melt from vehiclesin areas where service work is not performed may be day-lighted provided:

➙ a physical barrier is present between snowmelt areas and maintenance areas such as awall or berm; and

➙ no hazardous materials are stored or used in snowmelt areas; and➙ any discharged meltwater will not enter surface water.

Injection Well Prohibition

All floor drains discharging to injection wells pose some risk to groundwater quality. An injectionwell is defined as, “any opening in the ground used as a means of discharging waste”. Accordingly,the construction of a new floor drain in an area where vehicles are serviced or where hazardouschemicals are stored is prohibited unless the floor drain is connected to a public sewer or aholding tank. Permission to connect to a holding tank or the public sewer must be obtained fromthe Wastewater Management Division’s Regional Office prior to construction. If a holding tankis used, the wastewater may be disposed of at a municipal wastewater treatment facility (withthe facility’s approval) or via a certified hazardous waste hauler. In either case, you’ll have totest the wastewater to determine whether or not it meets the definition of ‘hazardous’ in theHazardous Waste Management Rules.

Floor Drain Registration

All businesses with existing floor drains that discharge to the subsurface are required to registertheir floor drains with the Wastewater Management Division in Waterbury, VT. Contact 241-3822to request a registration form. As with new construction, the Regional Office of the WastewaterManagement Division must be contacted if discharging to either a holding tank or public sewer.New injection wells are prohibited nationwide as of April 2000.

Floor Drains: A Fact Sheet f or Autobod y Repair Shops

Future Regulatory Change

In accordance with the EPA Class V Injection Wells Rule dated November 1999, the State of VT hassought delegation and will be authorized to oversee and enforce the new rule. The UIC Section iscurrently developing a procedure which will require the eventual permanent closure of all existingfloor drains unless they are either connected to a wastewater treatment plant or to a holding tank.When the procedure is adopted, registered floor drain owners will be notified of the new requirementand will be given ample opportunity to comply.


➙ Always try to keep floors as clean as possible.➙ Minimize and try to eliminate the use of water for floor cleaning.➙ If you must have floor drains, we recommend using removable drain plugs to ensure that

discharged wastewater is acceptable under the UIC Program standards.




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Dust Contr ol & Mana gementDust Contr ol & Mana gementWhy Is Dust A Concern And How Is It Regulated?

During autobody repair, sanding removes paint from surfaces and smooths body panels repairedwith body filling compounds. Airborne dusts produced during these operations may containhazardous substances, such as lead and chromium from surface coatings and abrasives fromsanding discs, that are harmful to the lungs and nervous system of workers. Dust concentrationsmay also exceed VOSHA standards. Effective control of worker exposure to dusts from sandingoperations on autobody surfaces has been achieved with the use of ventilated mechanicalsanders.

Sanding dust may be a hazardous waste if it contains heavy metals such as lead, chromium,cadmium, or barium at levels that exceed regulatory thresholds. Collected sanding dust shouldbe tested for these metals if they are suspected to be present.

Ventilated SandersRotary/orbital and straight line/reciprocating sanders, equipped withHigh Velocity/Low Volume (HVLV)local exhaust ventilation as part of thetool’s design, are recommendedbecause they have been shown to beeffective in reducing total dust

concentrations during the sanding of body filling compounds. HVLV ventilated sanders have cuttotal dust concentrations to one-tenth the levels produced using unventilated sanders.

The increased cost of sanders equipped with HVLV ventilation is minor compared with non-ventilated sanders. The amount of air used in the ventilation systems is also relatively low. Theuse of ventilated sanders can be enhanced by making them convenient to use. For example,install retractable, flexible hosing to a central vacuum system. Although initial costs for thissystem including an air mover, air cleaners, and duct work can be substantial, the system willhelp eliminate expensive repaints, shorten clean-up time and extend sandpaper life. Mostimportantly, it will promote a healthier work environment.

To Minimize Risk Of Exposure To Dust➙ Always wash your hands before eating.➙ Do not leave food and drink in the work area, as dust can travel and contaminate these

items.➙ Do not smoke in the work area. Besides the potential fire hazard that smoking can cause,

sanding dust contaminated with lead and other contaminants can enter your body throughhand to mouth contact.

A 1998 study conducted of Rhode Island autobody shopworker’s clothing found lead, arsenic, cadmium, chromium

and nickel in the form of sanding dust on their shirts, pantsand boots. These metals can cause adverse health effects. Itis recommended that work clothes be sent out to be launderedby a professional service.

DUST CONTROL

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MA NA GEMENT




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Scrap TiresScrap TiresWhy Are They Regulated?

Scrap tires are a bulky waste and are hard to handle with normal solid waste equipment. Whenburied in a landfill tires tend to “float” to the surface over time and disrupt landfill covers as wellas landfill gas and leachate collection systems. When stockpiled, large piles of tires are excellentbreeding grounds for mosquitoes and vermin. Although tires by themselves are not hazardous,fires in tire piles are very hard to extinguish and produce both toxic smoke and runoff.

What Can Be Done With Them?

➙ Scrap tires can be shipped for burning as a tire-derived fuel in cement kilns or electricpower plants.

➙ Scrap tires can be retreaded. Retreading usually works best for truck tires.➙ Scrap tires can be shipped to firms that process them to produce crumb rubber or chips.➙ Scrap tires can be used as a construction material - intact for retaining walls or shredded

for use as a lightweight fill.

What Can’t Be Done With Them?

Scrap tires are banned from landfill disposal by Vermont statute and may not be burned as fuelexcept in approved industrial size boilers with special air pollution control equipment.


➙ Re-market tires with more than 30% serviceable tread,➙ Separate highest quality casings for retreading,➙ Store casings in a covered enclosure until shipped.

P2 Oppor tunities For Your Customer s

➙ Regularly check and rotate tires according to manufacturers’ recommendations,➙ Maintain proper wheel alignment, tire balance and pressure to prolong tread life.




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Lead-Acid BatteriesLead-Acid BatteriesWhy Are They Regulated?

Lead-acid batteries are regulated as a hazardous waste because lead from the plates or thelead dissolved in the electrolyte is highly toxic and can contribute to water pollution when releasedto the environment. Also, the sulfuric acid battery electrolyte is highly corrosive and can causebodily injury on contact or react strongly with many materials it touches.


Because lead has value as a scrap metal, both state and federal environmental laws andregulations exempt lead-acid battery collection, reclamation and recycling as long as the bestmanagement practices for handling and storage of spent batteries are followed. Also, Vermontlaw actually encourages lead-acid battery recycling by requiring battery retailers to accept spentbatteries in return for those they sell.

What Can’t Be Done With Them?

Lead-acid batteries are banned from landfill or on-site disposal in Vermont. Batteries whichcannot be reclaimed or recycled must be disposed as a hazardous waste.


➙ Store spent batteries under cover and on an impervious surface.➙ Keep spent batteries from freezing to avoid cracking their cases.➙ Drain cracked or leaking batteries and store waste battery electrolyte as a corrosive

hazardous waste.➙ Store bulk new acid in wood or plastic battery cabinets.➙ Keep a supply of lime or baking soda on hand to neutralize acid spills.➙ Choose a reputable battery recycler.




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Refrig erantsRefrig erantsWhy Are They Regulated?

Freon, also known as R-12 or CFC-12, is a refrigerant used in automobile air conditioners.Commonly released into the air when air conditioners are serviced, freon rises to the stratospherewhere it destroys ozone molecules. Ozone in the upper atmosphere is able to absorb lethallevels of ultraviolet radiation from the sun before those rays can reach the earth’s surface.Overexposure to UV radiation has been determined to cause an increase in skin cancer, cataractsand suppression of the human immune system.


In accord with the Federal Clean Air Act requirements, the production of freon in the UnitedStates has been phased out. However, the use of freon is still permitted, as long as supplies areavailable.

Servicing of air conditioners must be done using approved equipment which meets UnderwritersLaboratories (UL) standard 1963 and the Society of Automotive Engineers (SAE) standardJ1991. Shops must certify to the U.S EPA that they are using approved equipment.

Technician Certification . Technicians who repair or service air conditioners must be certifiedby a U.S. EPA-approved organization. To be certified, technicians must pass a mail-in testdemonstrating their knowledge in the importance of refrigerant containment, the use of equipmentand the effects of ozone depletion. Call the Vermont Environmental Assistance Division at 1-800-974-9559 for the list of approved testing organizations.

Freon must be recycled by being either (1) recovered, treated and returned to the vehicle forreuse or (2) recovered and stored in a holding tank until such time that it is sent to an off-sitereclamation facility.


➙ Retrofit air conditioner to use R-134a instead of R-12 (freon). Lubricants, seals, fittings,etc. used with R-12 are not compatible with systems retrofitted for 134a. When in doubtas to proper retrofitting procedures always consult the air conditioner manufacturer. Motorvehicles, model year 1995 or newer, use R-134a.

Note : Although R-134a is not an ozone depleter, it is a “greenhouse gas” and cannot be ventedto the air. It must also be recovered using specialized equipment dedicated to R-134a.

Refrig erants: A Fact Sheet f or Autobod y Repair Shops

➙ Evacuate and recover refrigerant before servicing to avoid releases.➙ Visually inspect hoses, connections and condenser for leaks. Consider purchase of an electronic

sniffer to detect leaks. Avoid using leak detecting products containing R-12.➙ Encourage customers to repair leaking systems.➙ Don’t mix R-12 and R-134a since contaminated refrigerant must be sent off-site for reclamation.➙ Purchase refrigerant in 15 lb. containers or greater.




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How Are They Regulated?

Over the past decade, the Vermont legislature has enacted laws to reduce the volume of trashgoing to landfills in the state and to help cities and towns save money by recycling. Communitiesare encouraged to adopt ordinances requiring source separation of materials listed in the statute.Common recyclable materials are: (1) cardboard, including corrugated and boxboard (2) glasscontainers (3) compostable yard and food waste (4) newsprint (5) office paper (6) steel andaluminum cans (7) plastic containers made of HDPE and PET. Today, over half of Vermont’spopulation lives in one of the 99 towns with mandatory recycling ordinances. An additional 147towns have some form of recycling on a voluntary basis.

How Should They Be Managed?

Source separated materials are recyclable, just like those that are banned from landfill disposal.Check with your waste hauler, town clerk or solid waste district to find out if your town hasmandatory recycling and what materials can be recycled in your town.

Addison County Solid Waste Management District ........................................... (802) 388-2333Bennington County Regional Commission ........................................................ (802) 375-9964Central Vermont Solid Waste Management District ........................................... (802) 229-9383Chittenden Solid Waste District ......................................................................... (802) 872-8111Greater Upper Valley Solid Waste Management District ................................... (802) 296-3688Lamoille Regional Solid Waste Management District ........................................ (802) 888-7317Londonderry Group ........................................................................................... (802) 824-6304Northeast Kingdom Waste Management District ............................................... (802) 626-3532Northwest Vermont Solid Waste Management District ...................................... (802) 524-5986Rutland County Solid Waste District .................................................................. (802) 775-7209Rutland JMSC/SWAC towns ............................................................................. (802) 235-9353Southern Windsor/Windham County Solid Waste Management District ........... (603) 543-1201Waterbury/Mad River Solid Waste Alliance towns ............................................. (802) 244-7373White River Alliance .......................................................................................... (802) 234-9340Windham Solid Waste Management District ..................................................... (802) 257-0272

What Should Not Be Done With These Materials?

If your community has a mandatory recycling ordinance, you can’t just throw your recyclables inthe trash. Even in towns where recycling is voluntary, it is often costs less to recycle thesematerials than it does to landfill them.

Recyclable MaterialsRecyclable Materials

Recyclable Materials: A Fact Sheet f or Autobod y Repair Shops


➙ Find out which materials must or may be recycled in your town.➙ See if your waste hauler offers separate containers and/or rates for recyclables.➙ Separate and store recyclable materials by type (unless told otherwise).➙ Store recyclable materials where they will stay clean and dry.➙ Choose to purchase or carry products which use less packaging or packaging which can be

recycled locally.➙ Buy in bulk or in returnable containers.➙ Talk with scrap metal dealers. They may pay for some materials and/or pick them up at no

charge.

Related Fact Sheets:TiresLead-Acid BatteriesUsed OilOil Filters

APPENDICES

Appendix A ......................................Notification of Regulated Waste Activity FormAppendix B ...................................................................Hazardous Waste ManifestAppendix C .......... Commonly Used Hazardous Waste Codes for Autobody ShopsAppendix D ............................................ Hazardous Waste Generation WorksheetAppendix E ................................................... Environmental Analysis LaboratoriesAppendix F ..................................................................Calculating VOC EmissionsAppendix G .................................Municipal Wastewater Treatment Plant ContactsAppendix H ............................ How to Read a Material Safety Data Sheet (MSDS)Appendix I ................................ Additional Information and Assistance Resources

An Autobody Repair Technician’s Guide to Vermont’s Environmental Regulations APPENDICES

EXAMPLE

Agency of Natural Resources — Department of Environmental Conservation

VERMONT NOTIFICATION OF REGULATED WASTE ACTIVITY FORMFor Hazardous Waste, Universal Waste, and Used Oil Handlers

1. ❑ First Notification (Provisional ID No, if applicable: VTP-_______-_______-_______)❑ Subsequent Notification (EPA ID No: VT___-_______-_______-_______) (please also complete entire form)

Reason(s) for change (e.g., name change, change of ownership with date, waste streams, regulatory status): _____________________________________________________________________________________________________________________

2. Company Name (as will appear on manifests): _____________________________________________________________

3. Location Address (e.g., 22 Main St - not P.O. Box or rural route No): _______________________________________________City/Town: ______________________________ County: ___________________ Zip Code: __________-_________

4. Mailing Address: ❑ same as 3, above; OR ____________________________________________________________City/Town: ____________________________ State: _____________________ Zip Code: ___________-__________

5. Company Contact Person: (Last Name) ______________________________ (First Name) _________________________Job Title: _____________________________________________________ Phone No: ( _____ ) _______-_________Address: __________________________________________ State: _________________ Zip: _________-_________

6. Name of Legal Property Owner(s): __________________________________________________________________Address: ❑ same as 3, above; OR ❑ same as 4, above; OR ______________________________________________State: _________________ Zip Code: ___________-_______ Phone No: ( _____ ) _______-_________

7. Legal land status: ❑ Private (individual(s)/corp(s)) ❑ Federal ❑ State ❑ County ❑ Municipal ❑ Indian ❑ DistrictLegal facility-owner status: ❑ Private ❑ Federal ❑ State ❑ County ❑ Municipal ❑ Indian ❑ District

8. Does your company own other facilities or have affiliates in Vermont? ❑ Yes ❑ NoIf yes, please list name(s) & location(s): ______________________________________________________________

9. Hazardous Waste Activity (does not include either “used oil” or “universal waste” activities):

a. Generator Status (consider the total amount of hazardous waste generated per month — not the amount shipped):❑ Conditionally Exempt Generator (< 220 pounds/month of hazardous waste and < 2.2 lbs/mo of acutely hazardous waste generated)

❑ Small Quantity Generator (220 to 2,200 pounds/month of hazardous waste and < 2.2 lbs/mo of acutely hazardous waste generated)

❑ Large Quantity Generator (> 2,200 pounds/month of hazardous waste or $ 2.2 lbs/mo of acute hazardous waste generated)

(NOTE: 220 pounds = 100 kilograms; 220 pounds of waste with a density similar to water fills approx. ½ of a 55-gallon drum)

b. Transporter (see instructions before marking this section): ❑ of own waste only ❑ for commercial purposesMode of transportation: ❑ air ❑ rail ❑ highway ❑ water ❑ other: ____________________________

c. Other Activities (please see instructions before marking this section): ❑ hazardous waste transfer facility❑ on-site recycling (e.g., solvent distillation; not antifreeze or silver recovery) ❑ certified treatment, storage or disposal❑ off-site recycling ❑ hazardous waste fuel burner (Note: on-specification used oil is not hazardous waste fuel)

Please give details here: ________________________________________________________________________

✔

✔

✔

✔✔

✔

Type or print clearly in dark ink. If additional sheets are needed, please mark each appended sheet with the informationrequired by lines 2 and 3; each additional sheet should also be signed by an authorized representative and dated, perline 13. Refer to instructions; for further assistance in completing this form, contact the Hazardous Waste Program at 802-241-3888.

[Please continue on reverse side]

Joe’s Autobody Repair, Inc.

454 Over DriveSpringfield Windsor 05555 5555

Environmental Manager 802 123 4567454 Over Drive Vermont 05555 5555

JoeGreen

✔

Joe’s Autobody Repair, Inc.

802 123 4567

APPENDIX

A

Notification of Regulated Waste Activity Form APPENDIX

A

EXAMPLE

Vermont Notification of Regulated Waste Activity Form - Page 2

d. Description of Wastes Generated or Handled:

10. Used Oil Activity (please mark all that apply):a. ❑ Person first claims that used oil fuel meets specifications

b. ❑ Person who directs used oil to a used oil burner - go to e, below (burner(s) name/address: _____________________________

c. ❑ Person who burns used oil on-site - go to h, below ________________________)

d. ❑ Person who directs shipment of used oil to a re-refinery

e. ❑ Used Oil Fuel Marketer: ❑ specification used oil ❑ off-specification used oil❑ hazardous waste fuel ❑ Marketer who directs shipment of used oil to other marketers

f. ❑ Used Oil Collection Facility

g. ❑ Used Oil Transporter

h. ❑ Used Oil Fuel Burner: ❑ specification used oil ❑ off-specification used oil ❑ hazardous waste fuel

Type of equipment used: ❑ space heater (rated @ <0.5 million BTU/hr) ❑ utility boiler❑ industrial boiler ❑ industrial furnace

❑ other (please specify) _____________________________________________________________________________

Is used oil fuel accepted from an off-site locations to be burned on-site? ❑ Yes ❑ NoIf yes, please list the company/ies and address(es) from which used oil is accepted: ___________________________________________________________________________________________________________________________

11. Universal Waste Activity: (e.g., batteries, Hg-lamps, PCB ballasts, pesticides) ❑ large quantity handler ❑ destination facilityType(s) of universal waste handled: __________________________________________________________________

12. Comments: _____________________________________________________________________________________

13. I certify under penalty of law that this document and all attachments were prepared under my direction or supervisionin accordance with a system designed to assure that qualified personnel properly gather and evaluate the informationsubmitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsiblefor gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate andcomplete. I am aware that there are significant penalties for submitting false information, including the possibility offine and imprisonment for knowing violations.

Signature of authorized representative: ______________________________________________ Date: ____________

Name: ____________________________________________ Title: ________________________________________

For assistance in completing this form, contact the Hazardous Waste Program at 802-241-3888Please return completed form to: Waste Management Division; 103 South Main St, West Building; Waterbury VT 05671-0404

noitpircseDetsaWdetalugeR *)s(edoCetsaWetatS/APE etis-nOdetareneGtnuomA)htnom/sdnuoprosnollagni(

lairetaMtnebrosbAdekaoSliO 20TV snollag55

rennihT/tnevloSgninaelCnuG 500F,300F,100D sdnuop051

tnevloSahthpaNmuelorteP 20TV,100D snollag03

* see instructions and attached sheets for frequently-used waste codes; for additional assistance, call 802-241-3888

(rated @ >10million BTU/hr at manufacturing facility) (integral component of manufacturing process)

✔

Joe Green Environmental Manager

11/28/01Joe GreenJoe GreenJoe GreenJoe GreenJoe Green

Notification of Regulated Waste Activity FormAPPENDIX

A

✔

✔

✔

✔

✔

Instructions for Completing theVermont Notification of Regulated Waste Activity Form

Background: The Vermont Hazardous Waste Management Regulations (VHWMR) requires anyone “who gener-ates or who is in control of a waste” in Vermont to determine if that waste is a hazardous waste; the only exceptionis waste produced by household activities. A hazardous waste is any waste which is listed as such in the VHWMRor that is ignitable, corrosive, reactive, or toxic. These broad categories include many of the wastes commonlyproduced by businesses and municipalities. Everyone who manages hazardous waste (e.g., who creates, stores,transports, treats, recycles, or disposes of it) is a “handler” of that waste and is required to submit a notificationform.

Notification Requirement:

✓ Section 7-104 of the VHWMR requires that “Any person who generates or transports hazardouswaste or who owns or operates a . . . facility for the treatment, storage, use, disposal, or recycling ofhazardous waste shall notify the Secretary of such activity” (this includes the generation, marketing,burning, and/or transportation of waste oil, as well as some universal waste management activities).

✓ Hazardous waste handlers are required to maintain an up-to-date notification form with this Divisionwhich accurately describes current waste activity, waste generation at the facility location, and ownershipof the hazardous waste handler. There is no fee for notifying. Notification forms should be submittedprior to conducting any regulated waste activity.

✓ Submittal of a notification form results in a permanent, unique U.S. Environmental Protection Agency(EPA) ID number being issued to that hazardous waste handler’s site of operations.

✓ If a company handles hazardous waste at more than one location, a separate notification and EPA identi-fication number is needed for each (unless they are on adjacent parcels of land with the same land owner).

✓ If a facility no longer handles hazardous waste at a location that has been issued an EPA ID number, theVermont Waste Management Division should be notified in writing. A letter should be submitted thatincludes the handler’s name, address, EPA ID number, and a brief explanation of the change in wastehandling activities.

✓ Notification is required upon transferral of ownership of an entity that was required to notify previouslyfor a hazardous waste activity. Since EPA ID numbers are assigned to waste handler locations, the U.S.EPA ID number will not change if ownership of a facility changes.

Hazardous, universal, and used oil waste managed in the course of doing business, including at municipalities, isregulated by the VHWMR. Although household hazardous waste is exempted per Section 7-203(a), hazardouswaste generated by a business run out of a home is regulated.

Generally, the less hazardous waste generated, the fewer regulations apply. TheVermont Environmental Assistance Division is available to provide free assistance in

reducing the amount or toxicity of hazardous waste produced. In Vermont you can contactthat non-regulatory office by calling 1-800-974-9559.


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Instructions: Pursuant to Section 7-104 of the VHWMR, the attached two-sided Notification of Regulated WasteActivity form must be completed by all hazardous waste handlers in Vermont and submitted to the Vermont WasteManagement Division. Please type or print clearly in dark ink, not pencil. If additional sheets are needed, pleasemark each appended sheet with the information required by lines 2 and 3; each additional sheet should also besigned by an authorized representative and dated, in accordance with line 12. The following instructions complementthe limited instructions that have been included on the notification form:

Line 1: Mark “first notification ” if the handler location either does not have an identification number or if a 12-digit number beginning with the letters “VTP” (used to denote a provisional, or temporary, number) hadbeen issued in the past. The “subsequent notification” section must be completed if the facility hasalready been assigned a permanent ID number and there have been changes to the facility address, theinstallation contact person, facility ownership, or the type or quantity of regulated waste activity. If thefacility ownership has changed, or if an owner has been added, also please include the date of this changeon the “reason for change” line. NOTE: the entire form must be completed when submitting a subsequentnotification.

Line 5: Indicate a person who is responsible for regulated waste activities at the facility location. Generally, thisshould not be a consultant or your facility’s hazardous waste contractor.

Line 7: Choose the best description of who owns the land for the property being notified about. For incorporatedcompanies, mark “private ” even if shares are publicly traded on a stock exchange.

Line 9a: Section 7-305 of the VHWMR specifies that “a generator is any person, by site, whose act or processproduces hazardous waste or whose act first causes hazardous waste to become subject to regulation.” Awaste is considered to be generated when it is put into a container for disposal or when a determinationhas otherwise been made that a material is a waste; all waste needs to be evaluated to determine whetherit is hazardous or not. A Hazardous Waste Generator Status Comparison Table, comparing the differencesbetween the three categories of hazardous waste generators — Conditionally Exempt (CEGs), SmallQuantity (SQGs), and Large Quantity (LQGs) — is attached to this informational package. Hazardouswaste managed in the course of doing business — including at municipalities and at home-based businesses— is regulated by the VHWMR.

It is important that you figure out your generator status by tracking the amount of hazardous waste generatedper month; status is not based on how much hazardous waste is shipped in that month. Note that materialsthat are generated, reclaimed, and reused at the facility location only need to be counted once.

Line 9b: Do not complete this section if your company plans to hire another company to transport the wastes fromyour generation location. If your facility wishes to be a hazardous waste transporter, this activity requiresa permit — contact the Waste Management Division at 241-3888 for more information. Mark “of ownwaste only” if you wish to transport hazardous waste and you do not meet the provision that allowsconditionally exempt generators to transport their own hazardous waste to an authorized facility or event.

Mark “for commercial purposes” only if you are requesting a permit to transport other peoples’ hazardouswaste.

Line 9c: Mark “hazardous waste transfer facility” only if your facility wishes to be a permitted hazardous wastetransporter that manages hazardous waste for up to ten days on a transfer basis.

Mark “certified treatment, storage or disposal facility” only if your facility plans to engage in anyof the following activities:


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✓ conduct on-site hazardous waste treatment or disposal activities, or

✓ accept hazardous waste from off-site for treatment, storage, or disposal — unless your companyaccepts hazardous waste from a CEG in Vermont that is owned and operated by the same entity asyour company and generator standards are met for the waste storage activities; or,

✓ store hazardous waste for longer than the VHWMR allows generators to store hazardous waste.Allowable time limits for hazardous waste storage are as follows:

CEGs: no time limit provided that no more than 2,200 pounds of hazardous waste, 2.2 pounds (1kilogram) of acutely hazardous waste, or 220 pounds of any residue or contaminated soil, wasteor debris resulting from clean-up of a spill of acutely hazardous waste are accumulated at anyone time

SQGs: full containers — or those with >55 gallons — of hazardous waste, may be stored for up to 180days without requiring certification to store hazardous waste

LQGs: full containers — or those with >55 gallons — of hazardous waste, may be stored for up to 90days without requiring certification to store hazardous waste

Mark “hazardous waste fuel burner”only if hazardous waste or a mixture thereof is burned on-site.Note that the burning of used oil does not make an entity a “hazardous waste fuel burner.” Report used oilactivity in Section 10 of the notification form.

Line 9d: In order to complete this section, evaluate all material that is discarded from the waste handler location todetermine if it is hazardous waste — including manufacturing by-products and off-specification, out-dated, or otherwise unusable products. Waste determination may be based on general knowledge of thematerials and processes, information provided on Material Safety Data Sheets, or it may be necessary toperform laboratory analysis on the waste. Frequently, business associations, chemical suppliers, or productmanufacturers can assist in making a waste determination; however, if you request assistance from thesesources, they may not be aware that Vermont regulates certain wastes as hazardous that are not regulatedas hazardous wastes either Federally or in other states (e.g., “Waste containing greater than 5% by weightof petroleum distillates with melting points of less than 100o F” is a VT02 hazardous waste). There areseven categories of hazardous wastes:

➳ characteristic wastes (defined by waste codes D001 through D043);➳ listed wastes from non-specific sources (waste codes F001 - F039);➳ listed wastes from specific sources (waste codes K001 - K151);➳ commercial chemical products, intermediates, or off-specification products:➳ acutely-hazardous wastes have waste codes P001 - P123;➳ non-acute wastes have waste codes U001 - U359; and➳ Vermont-listed wastes (waste codes VT01 - VT99).

Refer first to the attached list of Frequently-Used State and Federal Hazardous Waste Codes; this includessome of the more common Federal hazardous wastes (with their codes) as well as the seven Vermontlisted hazardous wastes. A complete listing of the Federal codes, with detailed definitions, may be foundin the VHWMR.

Line 10: “Specification used oil” means that the oil has not been mixed with any hazardous waste (except forignitable waste), does not exceed any maximum allowable levels of contaminants, and meets the minimumallowable levels listed in the following table.


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Constituent/Property Allowable Level (parts per million, or ppm, dry weight basis)

Arsenic 5 ppm maximumCadmium 2 ppm maximumChromium 10 ppm maximumChlorine 500 ppm maximumLead 100 ppm maximumFlash Point 140o Fahrenheit minimumTotal Halogens 1000 ppm maximumPolychlorinated biphenyls (PCBs) < 2 ppm maximumNet Heat of Combustion 8000 BTU/lb minimum

Line 10e: The VHWMR § 7-802 defines “marketer” as follows: “any person, with the exception of do-it-yourselfers, who . . . (a) Directs a shipment of used oil fuel from their facility to a used oil burner; or (b)First claims that used oil that is to be burned for energy recovery meets the used oil fuel specificationsset forth in Table 1 of Section 7-812(c).” This means that anyone who gives, sells, or otherwise providesused oil to someone else to be used for fuel blending or burning is considered to be a marketer. Notethat giving or selling used oil to an entity that re-refines the oil is not included in this “marketer”designation.

Line 10h: Mark “space heater” if used oil is burned in a heater designed to have a maximum capacity of not morethan 0.5 million BTUs per hour and combustion gases are vented to the outside ambient air

Mark “utility boiler” if used oil is burned in a device used to produce electric power, steam, or heatedor cooled air (or other gases or fluids) for sale.

Line 11: Mark “large quantity handler” if your facility accumulates a total of 5,000 kilograms (11,000 pounds)or more of universal waste(s) (pesticides, thermostats, polychlorinated biphenyl- (PCB-) containingballasts, or mercury-containing lamps, calculated collectively) at any time. This designation as a largequantity handler is retained through the end of the calendar year in which a total of 5,000 kilograms ormore of universal waste is accumulated.

Mark “destination facility” if your facility treats, disposes of, or recycles a particular category ofuniversal waste. A facility at which a particular category of universal waste is only accumulated is nota destination facility for purposes of managing that category of universal waste.

For additional assistance in completing this notification form, if you are unsure whether the waste you handle ishazardous, or for more information regarding the Hazardous Waste Management Regulations, please contact theVermont Hazardous Waste Management Program at (802) 241-3888 or visit our website at:

http://www.anr.state.vt.us/dec/wmd.htm

The Vermont Environmental Assistance Division is available to provide free assistance in reducing the amountor toxicity of hazardous waste produced. In Vermont, you may contact that non-regulatory office by calling 1-800-974-9559.


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Hazardous Waste Manifest Information

The Hazardous Waste Manifest

A manifest is a multiple copy shipping form that is used to track the movement of a hazardous wastefrom the place of its generation to the place of its final disposal. If the final resting place in this “cradleto grave” system is a hazardous waste landfill, some wastes will need to be accompanied by asecond form to certify they meet certain pre-disposal treatment standards. This form is called theLand Disposal Restriction (LDR) Notification. Every shipment of hazardous waste must beaccompanied by at least a Uniform Hazardous Waste Manifest and possibly by an LDR form.

In most cases, your hazardous waste transporter will help you get your wastes pre-approved fordisposal and will provide you with completely filled out manifests and, if necessary, LDR forms. TheWaste Management Division (WMD) can provide a list of certified transporters. Contact the WMD at802-241-3888.

Although you may only have to sign the manifest, you are still responsible for all of the information onit. It is a good idea to check the form to make sure the information is correct and complete. Instructionson how to complete the form are usually printed on the back. After the transporter has accepted yourwaste he will sign the form and then give you several copies. Make sure you get the right copies. Thecopies are numbered and have printed on them where they are to be sent.

The following sample manifest is for a hypothetical autobody shop in Vermont using a New Jerseyhazardous waste transporter to send its waste to a facility in Ohio. Many states require hazardouswastes being shipped into their state to be reported on their state’s manifest form. Nevertheless, theUS EPA requires all states to use the same basic form. LDR notifications vary by transporter.

Hazardous Waste Manifest APPENDIX

B

EXAMPLE

Please type (or Print) (Form designed for use on elite (12-pitch) typewriter.)

UNIFORM HAZARDOUSWASTE MANIFEST

1. Generator’s US EPA ID No. ManifestDocument No.

2. Page 1of

Information in the shaded areas is notrequired by Federal law, but may be re-quired by State law.

A. State Manifest Document Number

B. Generation Site (if different)

3. Generator’s Name and Mailing Address (where returned manifestes are managed)

4. Generator’s Phone ( )

5. Transporter 1 Company Name

7. Transporter 2 Company Name

6. US EPA ID Number

8. US EPA ID Number

10. US EPA ID Number9. Designated Facility Name and Site Address

11. US DOT Description (Including Proper Shipping Name, Hazard Class, and IDNumber)

a.

b.

c.

d.

12. Containers 13.Total

QuantityNo. Type

14.Unit

Wt/Vol

I.Waste No.

GENERATOR

EPA

EPA

EPA

EPA

STATE

STATE

STATE

STATE

J. Additional Descriptions for Materials Listed Above

a.

b.

c.

d.

K. Handling Codes for Wastes Listed Above

15. Special Handling Instructions and Information Point of Departure or Entry - City, State

16.

If I am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to beeconomically practicable and that I have selected the practicable method of treatment, storage or disposal currently available to me which minimizes the present and futurethreat to human health and the environment; OR, if I am a small quantity operator, I have made a good faith effort to minimize my waste generationand select the best wastemanagement method that is available to me and that I can afford.

Printed/Typed Name

Printed/Typed Name

Printed/Typed Name

Printed/Typed Name

Signature

Signature

Signature

Signature

17. Transporter 1 Acknowledgement of Receipt of Materials

18. Transporter 2 Acknowledgement of Receipt of Materials

19. Discrepancy Indication Space

20. Facility Owner or Operator: Certification of receipt of hazardous materials covered by this manifest except as noted on Item 19.

Month Day Year

Month Day Year

Month Day Year

Month Day Year

. . . . . . . . . . .

. . . . . . . . . . .

. . . . . . . . . . .

VT 0110763

C. Trans. 1 Lic. St. Plate #

E. Trans. 2 Lic. St. Plate #

D. Trans. 1 Phone ( )

F. Trans. 2 Phone ( )

G. State Facility’s ID (not Required)

H. Facility’s Phone ( )

. . . .

. . . .

. . . .

. . . .

. .

. .

. .

. .

.

.

.

.

. ..

. ..

. ..

. ..

. . . . . . . . . . . . . . .

▼

▼

VT

0110763VERMONT AGENCY OF NATURAL RESOURCES

HAZARDOUS MATERIALS MANAGEMENT103 South Main Street

Waterbury, Vermont 05671-0404802-241-3866

V T D 0 1 2 3 4 5 6 7 8

D 0 1 2 3 4 5 6 7 8

D 0 1 2 3 4 5 6 7 8

N J

Fender Bender Autobody, Inc.123 Dingsanddents Drive, Essex, Vermont 05356-1234

802 123-4567

On The Road Transport, Inc.

O H

All Gone, Inc.21 Roadway’s EndCleveland, Ohio 87654

SAME

NJ HOD-123123-4567973

123-4567216

Non-Regulated Material, PER 40 CFR, 49 CFR(State Regulated Waste)

Waste Toluene/Xylene, Flammable Liquid, N.O.S., 3, UN1993,PG II

Waste Petroleum Distillates, N.O.S., 3, UN1268, PG II

0 0 1

0 0 0

0 0 0

D M

D M

D M

Oil Soaked Absorbent Material

Spray Gun Cleaning Solvent(Toluene, Xylene)

Petroleum Naphtha Solvent

0 0 1

0 0 1

0 0 3 56

55

55

P

G

G

F003, F005, D001

D001

VT02

VT02

Sanding Dust(Cadmium, Chromium)

Waste Toxic Solid, Inorganic, N.O.S., 6.1, UN3288, PGII

0 0 1 D M 0 0 2 53 P

0 0 0 0 1 1

Joe Green 9 42 0 1

GENERATOR”S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by propershipping name and are classified, packed, marked, and labeled, and are in all respects in proper condition for transport by highway accordingto applicable international and national government regulations, and all applicable State law and regulations.

Joe GreenJoe GreenJoe GreenJoe GreenJoe Green

D006, D007

TRANSPORTER

FACILITY

Hazardous Waste ManifestAPPENDIX

B

State and Federal Hazardous Waste CodesFrequently-Used in Autobody Repair Shops

This is only a partial list of hazardous waste codes. For a complete listing, refer to the VermontHazardous Waste Management Regulations (VHWMR) and/or contact the Hazardous Waste Sectionof the Waste Management Division at 802-241-3888 or the non-regulatory Environmental AssistanceDivision at 800-974-9559.

CHARACTERISTIC WASTES

Wastes identified by a “D” code are those that are considered hazardous because they exhibit one ormore of the following characteristics; ignitability, corrosivity, reactivity, and/or toxicity. Common “D”coded wastes generated in autobody repair shops are:

D001 - ignitable (flash point of less than ~ 140o F) D002 - corrosive (pH #2 or $12.5)

Other “D” codes for hazardous wastes exhibiting the characteristic of “toxicity” are shown below.Wastes containing any of the materials in this list, in amounts that exceed the concentrations given,are hazardous for toxicity. This is usually determined either through knowledge of the materials andprocesses generating the waste or by subjecting a representative sample of the waste to an analyticaltest called the “Toxicity Characteristic Leaching Procedure (TCLP)”. Autobody repair wastes thatmay need to be identified as “toxic” are spray booth filters (if the filters are covered with a lot ofoverspray from paints that contain heavy metals such as lead, chromium, etc.), sanding dust, andwaste paints.

D005 - Barium (100.0 mg/l) D008 - Lead (5.0 mg/l)D006 - Cadmium (1.0 mg/l) D018 - Benzene (0.5 mg/l)D007 - Chromium (5.0 mg/l) D035 - Methyl ethyl ketone (200.0 mg/l)

LISTED WASTES

The following codes are used for “listed” hazardous wastes. Please note that the following codes areused if the process generating the waste matches the description in the listing, no matter what theconcentration of hazardous constituent is in the total resultant waste (e.g. a disposable rag used toapply a solvent that contains $10% acetone by volume would be coded F003).

“F” Listed WastesF002 The fol lowing spent halogenated solvents ( i f $10% of the unused product):

Tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1 trichloroethane,chlorobenzene, 1,1,2-tr ichloro-1,2,2-tr i f luoro-ethane, or tho-dichlorobenzene,trichlorofluoromethane, and 1,1,2-trichloroethane. Also still bottoms from these spentsolvents and solvent mixtures.

F003 The following spent non-halogenated solvents (if $10% of the unused product): Xylene,acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol,

Commonly Used Hazardous Waste Codes APPENDIX

C

cyclohexanone, and methanol. Also still bottoms from these spent solvents and solventmixtures.

F005 The following spent non-halogenated solvents (if $10% of the unused product): Toluene,metyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, and 2-nitropropane.Also still bottoms from these spent solvents and solvent mixtures.

Vermont Listed Wastes[Note: A Vermont listed hazardous waste that also meets the definition of a Federal hazardous wastemust be identified by its U.S. EPA waste code.]

VT02 Waste containing greater than 5% by weight of petroleum distillates with melting points of lessthan 100oF, including but not limited to kerosene, fuel oil, hydraulic oils, lubricating oils,penetrating oils, tramp oils, quenching oils, and crankcase and automotive oils which havenot been exempted under the VHWMR Section 7-203(14). Note: Waste petroleum distillateswith a flashpoint less than 140oF are classified as D001 (ignitable).

VT08 Waste ethylene glycol based coolants, antifreezes and solutions containing greater than 700ppm of ethylene glycol. (See Antifreeze Fact Sheet for details)

Commonly Used Hazardous Waste CodesAPPENDIX

C

Hazardous W

aste Generation W

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INDEPENDENT VERMONT LABORATORIESJuly, 1999

1. Severn Trent Laboratories55 South Park DriveColchester, Vermont 05446(802) 658-1074

2. I.E.A. (Industrial & Environmental Analysis)P.O. Box 626Essex Junction, Vermont 05452(802) 878-5138

3. Spectrum LabsPO Box 122Montpelier Vermont 05601(802) 223-7088

4. Sci-Test (Dubois & King Lab)P.O. Box 339Route 66Randolph, Vermont O5060(802) 728-3379

5. Endyne Laboratory (Harry Locker)32 James Brown DriveWilliston, Vermont 05495(802) 879-4333

6. Precision Valley Laboratory (Ginny Deyo)113 Clinton AvenueSpringfield, Vermont 05156(802) 885-5157

7. Green Mountain Laboratories (Testing water only, no wastewater)RR 3, Box 5210Montpelier, Vermont 05602(802) 223-1468

8. Aquacheck LabsRR1, Box 489Weathers Field BusinessIntersection 106 and 131Perkinsville Vermont 05151

9. Environmental Waterworks Inc.So. Main Street, Box 18Wilmington VT 05363

10. Eastern Analytical Inc.25 Chenell DriveConcord NH 03301(Performs numerous analyzes for VT Facilities and is NH Certified)

NOTE: There is no wastewater certification program for laboratories in the state of Vermont

Environmental Analysis Laboratories APPENDIX

E

Calculating VOC Emissions APPENDIX

F

How To Calculate VOC Emissions

Calculating VOC Emissions

➀ The first step is to gather the Material Safety Data Sheets (MSDS) for all coating, surface prepand equipment cleaning materials used at your shop. An actual MSDS for a primer manufacturedby Sherwin-Williams, ULTRA-FILL HS Primer P50, is attached for your reference throughout thissection. You may want to refer to Appendix H, “How to Read a Material Safety Data Sheet” for abrief overview of what type of information is contained in each section of an MSDS.

➁ The next step is to determine the total number of gallons of each different type of VOC-containingmaterial you use in a year. Material purchasing records can be used to estimate the gallons peryear of each of the materials you use. You might find it helpful to record your results in a tablesimilar to that included on the following page.

➂ The next step is to find the information you need to determine the VOC content of each of thematerials you use. Hopefully, the MSDS will provide you with the “VOC lbs/gal”.1 If not, you willhave to calculate it using two pieces of information: the coating density (the total weight of onegallon) of the coating and the % volatile (or %VOC) by weight.2 See Section 2 or 3 of the MSDSto find this information. Some compounds are volatile but not considered VOCs, therefore it isbetter to use %VOC by weight, if available. If the MSDS does not provide % VOC you shouldassume that all of the % volatiles are VOCs. You determine the pounds of VOC per gallon bymultiplying the coating density by the % VOC (or volatile) by weight.

For the ULTRA-FILL product, the information needed is contained in Section 2. The VOC contentfor the P50 product is given as 3.82 lbs/gal. You’ll notice that there are two listings for VOCcontent, the first gives the total VOC content and the second gives the VOC content less waterand Federally Exempt Solvents.1

Repeat step three for each of the VOC-containing materials you use.

1 Sometimes the MSDS provides “VOC lbs/gal less water” or “VOC lbs/gal less exempt compounds”. Due to the waythese values are calculated they are not appropriate for calculating actual emissions from the coatings. You shouldcontact your supplier to obtain the actual “VOC lbs/gal”. The other values are provided to show compliance withcertain state or federal requirements that limit the total amount of VOC allowed in a specific coating and preventbringing a coating into compliance simply by “watering” it down with water or another exempt solvent.

2 Note: Sometimes the coating supplier lists specific gravity instead of coating density. You calculate the coating densityin pounds per gallon by multiplying the specific gravity by 8.34 (the weight of a gallon of water). If the specific gravitylisted on the MSDS uses a reference other than water, you need to use the density of that reference compound.Unless specified otherwise, you should assume the specific gravity reference specified is that of water.

Example: if specific gravity = 0.96then the coating density = 0.96 x 8.34 lbs/gal = 8 lbs/gal

➃ The next step is to determine the total pounds of VOC emissions in a year from each material youuse.

Formula: VOC = Gallons x VOC Content

where:

VOC = The actual VOC emissions from the material (in pounds) for the year.Gallons = The total yearly usage of the material in gallons (from Step 2)VOCContent = The VOC density of the material in pounds of VOC per gallon of coating(from Step 3)

ULTRA-FILL Example:

VOC = 85 gallons x 3.82 pounds/gallonVOC = 324.7 pounds of VOC emissions per year

You need to repeat this calculation for each material you use.

➄ The final step is to determine the total amount of VOC emissions from your facility each year .To do this you need to add up all of the individual material calculations you did under Step 4. Thiswill give you total pounds of VOC emissions per year. Then you need to divide this total by 2000(pounds per ton) to obtain your actual VOC emissions in tons per year.

NOTE: If your actual VOC emissions are 5 tons per year or more, you must register with the DECAir Pollution Control Division. Contact them at (802) 241-3840 for more information.

Most autobody shops in Vermont are well below the 5 tons per year threshold for registration.However, it is still a good idea to at least estimate the total annual VOC emissions from your shop.This will help ensure that your shop is in compliance with any regulatory requirements.

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snoissimElatoT )sbl(

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Example of a Table to Record VOC Emission Calculation Information

Calculating VOC EmissionsAPPENDIX

F

Calculating VOC Emissions APPENDIX

F

where:

Gallons Used Each Year = gallons used per year (from purchasing records)

VOC Content = pounds of VOC per gallon of materialobtained either: 1- directly from the MSDS

2- calculated using the total weight of the coating (coating density)multiplied by the %VOC (or % volatile)

VOC Emissions = total VOC emissions from the material per yearColumn 2 multiplied by Column 3Gallons Used Each Year x VOC content

Example: gallons per year x 3.82 pounds VOC per gallon =324.7 pounds of VOC emissions per year

Calculating V

OC

Em

issionsAPPENDIXF

§

150 150<200> <200>

Hexamethylene Diisocyanate(max.)Hexamethylene DiisocyanatePolymer

as Resp.Dustas Resp.Dust

Mg/M3 as Dust[Resp. Fraction]Mg/M3 as Dust[Resp. Fraction]

§

ACGIH OSHA VaporCAS No. Hazardous Ingredients TLV PEL Units Pressure

<STEL> <STEL> (mm Hg)

— Section 2 —ULTRA-FILL II® ULTRA® ULTRA-FILL® HS ULTRA-FILL® HS

(percent by weight) HS Primer-Surfacer Hardener 2.1 VOC Primer 2.1 VOC Hardener

P50 UH200 P22 UH400

108-67-8 1,3,5-Trimethylbenzene 25 25 PPM 10.0 1

95-63-6 1,2,4-Trimethylbenzene 25 25 PPM 2.0 2

590-01-2 n-Butyl Propionate. Not Established 3.4 5 6

123-86-4 n-Butyl Acetate. PPM 10.0 19 53 9

98516-30-4 Ethoxypropyl Acetate. Not Established 2.2 4

108-65-6 1-Methoxy-2-Propanol Acetate Not Established 1.8 2

822-06-0 0.005 PPM 0.05 0.1 0.2

28182-81-2 Not Established 47 94

Proprietary Polyamine Not Established 11

14464-46-1 Cristobalite 0.05 0.05 Mg/M3 1

14807-96-6 Talc 2 2 Mg/M3 4 19

7727-43-7 Barium Sulfate. 10 10[5] 14 26

13463-67-7 Titanium Dioxide. 10 10[5] 16 16

1333-86-4 Carbon Black. 3.5 3.5 Mg/M3 0.6 0.1

[% Barium] [7.8] [15.5]

Zinc Compound. [% Zinc] 7 [3.3]

Weight per Gallon (lbs.) 13.53 8.25 14.41 9.34

VOC (Volatile Organic Compounds) Total - lbs./gal. 3.82 4.36 2.36 0.52

VOC Less Water & Federally Exempt Solvents - lbs./gal. 3.82 4.36 2.36 0.52

Photochemically Reactive Yes No No No

Flash Point (˚F) 82 83 81 100

DOL Storage Category 1C 1C 1C 2

Flammability Classification (Flammable - Combustible) Flam. Flam. Flam. Comb.

HMIS (NFPA) Rating (health - flammability - reactivity) 3* - 3 - 0 3* - 3 - 1 3* - 3 - 0 2* - 2 - 1

PAINT-SAFE® Personal Protection K K K K

Ingredient subject to the reporting requirements of the Superfund Amendments and Reauthorization Act (SARA) Section 313, 40 CFR 372.65 C

ULTRA-FILL® HS Primers P-UREV/4

Material Safety Data Sheet99

Sherwin-Williams Automotive Finishes Corp. Emergency telephone number (216) 566-2917101 Prospect Ave. N.W. Information telephone number (216) 566-2902Cleveland, OH 44115 Date of preparation March 11, 1999

©1999, The Sherwin-Williams Co.

— Section 1 —Product Identification

P-7c

PE

R

C

E

N

T

BY

WE

I

G

H

T

Percent

By

Weight

Municipal Wastewater Treatment FacilityPlant Contacts

tcatnoC/renwOytilicaF #enohP rotarepOfeihC/emaNytilicaF #enohP

foegalliV~grublArekaByrneH

3673-697-208grublA

osurBnotlA0083-697-208

foytiC~erraBwodnaYtreboR

0520-674-208ytiCerraB

uaeluoRhpesoJ1620-674-208

foegalliV~notraBnongaGdlanoR

7474-525-208notraB

reyoMluaP9123-525-208

foegalliV~sllaFswolleBhtimSatreboR

4693-364-208sllaFswolleB

releehWtreboR4403-364-208

fonwoT~notgninneBdruHtrautS

7301-244-208notgninneB

cnalBeLegroeG4454-244-208

fonwoT~nosneBnotlrahCyuG

1162-735-208nosneB

notlrahCyuG1162-735-208

fonwoT~lehteBduolCtrebleD

0439-432-208lehteB

slliMyhtomiT0486-432-208

foegalliV~drofdarBnellAesiuoL

7274-222-208drofdarB

notnrohTelaD0469-222-208

fonwoT~nodnarBnrobnaSruhtrA

5363-742-208nodnarB

akjiCnehpetS0376-742-208

fonwoT~orobelttarBdrallimeRyrreJ

5524-452-208orobelttarB

woDegroeG8132-752-208

fonwoT~retawegdirB.rJeeLnosleN

4333-276-208retawegdirB

)detcartnoC(yrneH-enserfuD4244-327-208

fonwoT~nothgirBepoCleoJ

5044-327-208nothgirB

llezzirFllahsraM4244-327-208

foytiC~notgnilruBsmadAeiruaL

1054-368-208niaMnotgnilruBretsoFnehpetS

5656-268-208


1054-368-208htroNnotgnilruBretsoFnehpetS

4617-268-208


1054-368-208reviRnotgnilruBdoowneerGyraG

8784-368-208

fonwoT~naanaCnosnhoJalasrU

0733-662-208naanaC

llabmiKtreboR3277-662-208

fonwoT~noteltsaCnosdivaDylreveB

9135-864-208noteltsaC

yecarTdrawdE5135-864-208

fonwoT~hsidnevaCcevSdrahciR

1927-622-208hsidnevaC

yelxiPdrawoH3477-622-208

fonwoT~aeslehCnosnhoJCkcaJ

0644-586-208aeslehC

noottaMelaH7277-586-208

fonwoT~retsehCgnidluapSnasuS

3712-578-208retsehC

hcirdooGyrraB5234-578-208

Municipal Wastewater Treatment Plant Contacts APPENDIX

G


1#DFkoorBdloCyeraCatreboR

0640-464-208esaB-koorBdloC

thgirWruhtrA1912-464-208

1#DFkoorBdloCyeraCatreboR

0640-464-208floG-koorBdloC

thgirWruhtrA1435-464-208

fonwoT~ellivnaDyngiveSnoiraM

2533-486-208ellivnaD

rekraPeilseL8012-486-208

foegalliV~sllaFgrubsonElieNcMnehpetS

3444-339-208sllaFgrubsonEsetaGleumaS

9666-339-208

foegalliV~noitcnuJxessEdroffaSselrahC

4496-878-208noitcnuJxessE

sartuJsemaJ3496-878-208

fonwoT~nevaHriaFolliloaPaicirtaP

0103-562-208nevaHriaF

eimaraLreteP4453-562-208

fonwoT~xafriaFllattuNdrawdE

1116-948-208xafriaF

eniVeDydnaR3306-948-208

fonwoT~kciwdraHlliHleinaD

0216-274-208kciwdraH

namloTnosreffeJ9395-274-208

fonwoT~droftraHhsramretuoCsamohT

2263-592-208JRW-droftraHsregoRyrraL

3656-592-208

fonwoT~droftraHgrebeseiRretnuH

2263-592-208eehceuQ

sregoRyrraL8259-592-208

fonwoT~grubseniHrehgallaGniwdE

6902-284-208grubseniH

rehgallaGniwdE0952-284-208

foegalliV~ellivnosreffeJhtimSsinneD

3255-446-208ellivnosreffeJekoorBnnelG

4355-446-208

foegalliV~nosnhoJdoogsOcirE

1162-536-208nosnhoJ

tterraGdlanoD1592-536-208

foegalliV~wolduLgrubredneHnairB

1482-822-208wolduL

telsneerGnaroL1348-822-208

2#tcirtsiDeriFgrubnenuLhtimSydnaR

7177-298-2082#DFgrubnenuL

ybloCnivlaC0877-298-208

fonwoT~nodnyLdoogsOcirE

4385-626-208ellivnodnyL

)detcartnoC(hceThtraE9395-626-208

fonwoT~retsehcnaMnosliWyereffeJ

3131-263-208retsehcnaMieccaBnalA

9333-263-208

foegalliV~dleifhsraMeekruDecnatsnoC

0623-624-208dleifhsraM

.rSeekruDnodroG7523-624-208

fonwoT~yrubelddiMreleehWytteB

1404-883-208yrubelddiM

slleWtreboR4997-883-208

fonwoT~notliM.rJnosleNdeT

5061-398-208notliM

tnuHregoR0711-398-208

foytiC~reileptnoMyarGnehpetS

8059-322-208reileptnoM

reicreMdlanoR1159-322-208

foegalliV~ellivsirroMsrameDlaenO

0736-888-208ellivsirroM

narhcoCleahciM8313-888-208

foytiC~tropweNdraWnhoJ

4212-433-208ytiCtropweN

uaetneraPdivaD6888-433-208

Municipal Wastewater Treatment Plant ContactsAPPENDIX

G

tcatnoC/renwOytilicaF #enohP rotarepOfeihC/emaNytilicaF#enohP

1#DFhcnarBhtroNdnalloHadniL

0657-464-2081#DFhcnarBhtroN

tseWnhoJ0657-464-208

foegalliV~yorThtroNhtrowtneWsemaJ

0074-889-208yorThtroN

wehyaMlecraM7874-889-208

foegalliV~dleifhtroNnoyLmailliW

1216-584-208dleifhtroN

aerivliSyduR5537-584-208

foegalliV~snaelrOxocliWyrraL

4858-457-208snaelrO

nitsuAyrraL0512-457-208

fonwoT~llewrOenotSluaP

1222-849-208llewrO

semaJhtuR2302-849-208

fonwoT~telwaPtteluHdrahciR

9033-523-208telwaPtseW

regloFnahtanoJ7830-546-208

fonwoT~drofsttiPnamroG'OsemaJ

0056-384-208drofsttiP

)vreSsrpOnomiS(ddehSkcaJ7926-384-208

fonwoT~dleifnialPluaPesoR

1648-454-208dleifnialP

tteweJyaJ3717-454-208

foegalliV~yentluoPllahtnesoRsanoJ

3004-782-208yentluoP

yecarTenyaW7279-782-208

fonwoT~rotcorPrenroHdrahciR

3333-954-208rotcorP

wolBddoT1052-954-208

fonwoT~yentuPnelluMsemaJ

2685-783-208yentuP

eugarpSnahtahoJ5434-783-208

fonwoT~hplodnaRsmadAleM

3345-827-208hplodnaR

sargniGnelG9709-827-208

fonwoT~orobsdaeRdrareByrraB

5045-324-208orobsdaeR

sewoHyrraB1867-324-208

foegalliV~drofhciRredinSyraG

2577-848-208drofhciR

revohSyrraG0407-848-208

fonwoT~dnomhciRiksnejdoRdlanoR

8712-434-208dnomhciR

nialrebmahClladneK8712-434-208

fonwoT~notlayoRgninnaMenyaW

7697-367-208notlayoR

engivaLhplaR3308-367-208

foytiC~dnaltuRrennoCnerraW

3181-377-208ytiCdnaltuR

gnilatoHrevorG1581-377-208

fonwoT~etageyRybraDtyoH

5063-757-2082#DFetageyR

niroMffeJ

foegalliV~reviRsnotxaSgniruLesiuoL

6652-968-208reviRsnotxaS

releehWtreboR5272-968-208

fonwoT~enrublehSregniFmailliW

0115-589-2081tnalPenrublehS

nrubhtaRdivaD3353-589-208

fonwoT~enrublehSregniFmailliW

0115-589-2082tnalPenrublehS

nrubhtaRdivaD0073-589-208

fonwoT~nodlehSettelliuorBdrahciR

4252-339-208sgnirpSnodlehS

deeRwerdnA9538-339-208

Municipal Wastewater Treatment Plant Contacts APPENDIX

G


1#DFenrubrehSsiweLdivaD

1423-224-2081#DFenrubrehS

siweLleinaD1383-224-208

foytiC~notgnilruBhtuoSnettihWdlanoD

3597-856-208yawkraPtropriA

noegrelliaBtreboR4697-856-208

foytiC~notgnilruBhtuoSnettihWdlanoD

3597-856-208yaBs’tteltraBnitroFleahciM

5697-856-208

fonwoT~dleifgnirpSgnortSffeJ

4012-588-208dleifgnirpS

dnomEekiM4582-588-208

foytiC~snablAtSiffoiCmailliW

0051-425-208snablAtS

ttelliWnairB9051-425-208

foytiC~snablAtSiffoiCmailliW

0051-425-208rroCsnablAtS

ttelliWnairB7151-425-208

fonwoT~yrubsnhoJtSllaHnhoJ

6293-847-208yrubsnhoJtS

nothguoHyoreL4219-847-208

fonwoT~ewotSnnuDttocS

0537-352-208ewotS

siweLyrogerG5316-352-208

foegalliV~notnawSeugaLegroeG

7933-868-208notnawS

nottarGffeJ1423-868-208

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3662-889-208yaJ/yorT

nilemaHhtenneK6362-889-208

foytiC~sennegreVyelwaHnivleM

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0595-476-208

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6543-754-208niaMkcotsdooW

namtsaEytsuR0191-754-208

fonwoT~kcotsdooWnosnawSpilihP

5764-754-208ellivstfaT

namtsaEllessuR0191-754-208

Municipal Wastewater Treatment Plant ContactsAPPENDIX

G

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The information provided in the table below should help you to understand how a Material SafetyData Sheet (MSDS) is formatted and what kind of information it contains. It is always a good idea toask vendors for a copy of an MSDS for a chemical or product BEFORE actually purchasing theproduct. This will allow you to evaluate the product and compare it to others that perform a similarfunction. By doing this you can select the product or chemical that represents the least hazard toyour employees and will result in the least amount of regulation.

A Quick Guide to Reading a Material Safety Data Sheet

How to Read a Material Safety Data Sheet (MSDS) APPENDIX

H

Information and Assistance Resources

DEPARTMENT OF ENVIRONMENTAL CONSERVATION (DEC)http://www.anr.state.vt.us/dec/dec.htm

Air Pollution ControlEngineering Services Section (Permits) ....................................................... 241-3840

Environmental Assistance DivisionToll-free Pollution Prevention Hotline .................................................. 1-800-974-9559Small Business Compliance Assistance Program .............................. 1-800-974-9559Permit Specialists

Barre .................................................................................................. 476-0195Essex Junction ................................................................................... 879-5676No. Springfield................................................................................... 885-8850Rutland .............................................................................................. 786-5907St. Johnsbury ..................................................................................... 751-0127

Waste Management DivisionHazardous Waste Program........................................................................... 241-3888Solid Waste Program .................................................................................... 241-3444Recycling Hotline ................................................................................ 1-800-932-7100Underground Storage Tank Program ............................................................ 241-3888

Wastewater Management ProgramRegional Offices

Barre .................................................................................................. 476-0190Essex Junction ................................................................................... 879-5656North Springfield ................................................................................ 885-8855Rutland .............................................................................................. 786-5900St. Johnsbury ..................................................................................... 751-0130

Waterbury Central OfficeUnderground Injection Control Program ............................................ 241-4455Pretreatment Discharge Program (to POTW) .................................... 241-3822

BUSINESS ASSISTANCESmall Business Development Center ............................................... 1-800-464-SBDCVermont Manufacturing Extension Center .................................................... 728-1421

Additional Information & Assistance Resources APPENDIX

I

Additional Information & Assistance ResourcesAPPENDIX

I

INTERNET RESOURCESThe following links are provided as additional resources to help autobody refinishers understand the environmentalregulations they may be subject to, reduce the generation of hazardous waste, air and water pollution and promote asafer, healthier work environment. It is important to be aware that any compliance information provided by these sites maybe state specific, Vermont regulations may differ substantially. If you have questions about Vermont environmental regulations,contact the Environmental Assistance Hotline at 800-974-9559.

EPA’s Design for the Environment Autobody Refinishing Project...http://www.epa.gov

Visit the Virtual Collision Repair Shop, Virtual Spray Booth and Virtual Paint Mixing Room at...http://www.ccar-greenlink.org

The Small Business Environmental Home Page contains links to numerous compliance and pollutionprevention fact sheets for autobody refinishers, just choose “Automotive” from the Sector List...http://www.smallbiz-enviroweb.org/pubsector.asp

Enviro$ense is an EPA web site that contains links to over 200 autobody related environmental factsheets. Go to the search page and type autobody in the search box...http://es.epa.gov

vermont's environmental regulations · this guide was developed by the vermont department of...

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