1. Pollution Prevention/Small Quantity Generator Program GOAL:To provide educational assistance to any business with local, state and/or federal regulatory compliance requirements.

2. Mechanical Repair Facilities Typical Waste Streams Facility Assessment to Determine Generator Classification Best Management Practices (BMP’s) for Waste Streams Pollution Prevention Other Resources/Services

3. Typical Waste Streams of Mechanical Repair Facilities Parts Washer(s) Lead Acid Batteries Anti-freeze Tire Weights Used Oil Aerosols Rags Oil/Fuel Filters A/C Repair Absorbent Material Facility’s Maintenance

4. Facility Assessment to Determine Generator Status Characteristics of Hazardous Waste 40CFR Part 261 n Ignitable: Flash Point of 140ºF or less and/or aqueous solution with an alcohol content of 24 % or greater. n Corrosive: Liquid solution with a pH of 12.5. n Reactive: Undergoes violent chemical reaction to water, heat, shock, or pressure. n Toxicity: Includes eight heavy metals and thirty-one organic chemicals including ten pesticides.(TCLP) n There are over 500 specific hazardous waste listed in 40CFR Part 261.

5. Facility Classifications: n Conditionally Exempt Small Quantity Generator (CESQG): In one month a facility generates less than 220lbs. or less than 2.2lbs. of an acute hazardous waste. 40CFR 261.5 n Small Quantity Generator (SQG): In one month a facility generates more then 220lbs but less than 2200lbs. 40CFR 262 n Large Quantity Generator (LQG): In one month a facility generates more than 2200lbs., and/or more than 2.2lbs. of an acute hazardous waste. 40CFR262 Note: An acute hazardous waste is a P-listed waste such as arsenic and cyanide compounds.

6. Best Management Practices Parts Washer(s) - Parts washers need to be managed in a manner consistent with the fluid contained in the unit (petroleum/aqueous). To avoid cross contamination, any aerosols/fluids used to pre-clean a part must be compatible with the solvent utilized in the parts cleaning machine. Lead Acid Batteries- Store on impervious surface. Utilize a acid resistant container for leaky battery in temporary storage with base to neutralize any acid that may leak out. Keep records for three year minimum.

7. Best Management Practices Antifreeze- Recycle on site. This will reduce the liability of hauling on public roadways. Recycling will save you money in new product purchasing and hazardous waste disposal. Choosing the proper recycling unit is the key to a quality useable product for your fleet. Training the recycling unit operator to provide a consistent product is also very important. Records should be kept on site for a three year minimum. Containers should be marked properly. One container with the words “Used Antifreeze” the other “Recycled Antifreeze”.

8. Best Management Practices Tire Weights- Lead or steel tire weights should be recycled. Tire weights should be kept in a separate containers marked “Used Tire Weights” A log book should be kept with receipts documenting the recycling practice. Used Oil- Used oil should be stored in a compatible container or tank. The container or tank must be marked “USED OIL”. Containers should be stored in a sealed concrete roofed containment system to prevent rain water contamination. Inspect containers frequently to verify integrity. Disposal records should be kept on site for a three year minimum. Note: Less containers means less liability.

9. Best Management Practices Aerosols- Aerosol cans can be disposed of as a solid waste if they meet the “Definition of Empty” (40CFR261.7). No product should be left in the can, and no propellant. If Aerosols are not empty, product knowledge will dictate disposal method. Chlorinated solvents should never be utilized. They cause cross contamination of other waste streams. Conversion to a none-aerosol system will reduce the cost of product purchase, use, and employee exposure.

10. Best Management Practices Rags- Management of rags is dictated by how they are used. Rag services offer recycling of rags for businesses that utilize hazardous materials in processes. Using this type of service allows the rags to be handled under recycling rules. Disposable rags require a hazardous waste determination to be performed. Oil/Fuel Filters- In Florida, once these two types of filters are drained of fluids, they can be disposed of through a solid waste system that utilizes them as fuel for Waste To Energy plants. This method requires documentation from the transporter and WTE plant. Otherwise you must contain them and document proper disposal through a transporter.

11. Best Management Practices A/C Repair- Make sure the machine utilized is approved. The best type of machine for this procedure is a recovery/recycling machine that extracts the freon cleans it and places it back into the repaired unit. Keep logs documenting the process. Absorbents- There are different types of absorbents on the market. Pads, clay, and organic types are the most common. The material being absorbed will dictate disposal requirement. If incineration will be the disposal method, materials with lower ash content is more desirable.

12. Best Management Practices Facility Maintenance- A variety of wastes are generated from facility maintenance: Mercury containing devices and lamps, paint and paint solvent, wastewater from mopping shop floors, NiCd Batteries from emergency lighting. etc. Paint solvents can be eliminated by using Latex Paint whenever possible. Mop water should be TCLP tested and an approval letter from your local POTW should be acquired before discharge to sanitary sewer system. Mercury containing devices and lamps should be disposed of through recycling under the Universal Waste Rule.

13. Other Resources and Services n USEPA Web Page n FLDEP Web Page n National Pollution Prevention Roundtable n Lee County P²/SQG Program n Florida Pollution Prevention Roundtable n Consultants n Competitors n Product Manufacturers

14. Introducing... Pollution Prevention Technology Source Reduction Product Substitution Process Elimination/Outsourcing Reuse Recycle Key: Management Commitment, Employee Input/Training What? When? How?

15. Pollution Prevention Technology For Fleet Maintenance Operations

16. What, When, How, To Start n Regulatory / Internal Policy Requirements n Planning n Purchasing Review n Phases n Funding n Benefits n Lee County Specifics

17. REGULATORY / INTERNAL POLICY REQUIREMENTS n Federal Law Requires Facility’s to Reduce Hazardous Waste Generation Amounts n Most State’s Require Reductions of Hazardous Waste Generation n Some Municipality’s Require Internal Departmental Waste Reductions In Standard Operating Procedures

18. PLANNING n Meet With Directors and Discuss What, When, and How to Start n WHAT- Regulatory Direction to Embrace: RCRA, OSHA, CWA/NPDES, CAA n WHEN- Priorities and Funding n HOW- Small Builds to Large

19. PURCHASING REVIEW n Know what is utilized and the effects. n What comes through the front door exits somewhere. n Research alternatives with specific goals. n Centralize control of P2 Purchasing. n Document/Track Your Decisions. n Complete cost is the life of the product.

20. PHASES n Set priorities and build team concept. n Schedule process changes to meet priorities. n Utilize existing knowledge to incorporate process changes. n Cross-train employees on each new process. n Document and track start to finish changes. n Calculate savings from existing SOP’s.

21. FUNDING n Utilize existing funds. n Re-invest savings from phased changes. n Re-direct funds from regulatory labor cost. n Partner with approved vendor to field test products. n Share success with management and convince them to invest more.

22. BENEFITS n Reduced regulatory requirements and non- compliance penalty potential. n Safer / healthier working environment for workers. n Reduced operations budget. n Better public relations.

23. LEE COUNTY SPECIFICS n Product Substitution n Process Changes n Out Sourcing

24. PRODUCT SUBSTITUTION n Buy approved products in bulk and utilize refillable containers. n Use quality recyclable products. n Self managed parts washers. n Brake cleaning product and procedural change in process. n Recyclable shop rags. n Eliminate all chlorinated solvents.

25. PROCESS CHANGES n Onsite recycling of anti-freeze. n Self managed parts washing system. n Refillable spray containers. n Steam cleaning system. n Recyclable shop rags. n Metal recycling. n Purchasing/Product Control

26. OUT SOURCING n Carburetor cleaning. n Vehicle painting. n Modular rebuilds n Manufacture recalls n Equipment modifications n Facility Maintenance