Vehicle Repair Shops
Tribal governments may operate, maintain, and purchase motor vehicles and equipment to perform government services. Vehicles range from school buses, fire engines, snowplows, and heavy construction equipment to automobiles used by police and fire departments and government officials. Equipment may include pumps, tools, and boilers.
Vehicle Repair Shops
Vehicle repair shops conduct several activities that could affect the environment; these activities may be regulated under the following federal environmental laws:
- Fluid changes - RCRA, SDWA, and CWA
- Parts washing - RCRA, CAA, and CWA
- Battery maintenance - RCRA and CWA
- Air conditioner repair - CAA
- Vehicle and shop floor washing - CWA
- Exhaust system repair and replacement - CAA
- Painting - RCRA and CAA
- Outdoor material storage - CWA and RCRA
Changing Vehicle Fluids
Changing vehicle fluids includes oil, transmission, and break lubrication, as well as antifreeze. Changing fluids also involves storing both new and waste fluids and managing or disposing of waste fluids. Fluids generally are drained from the vehicle to a pan or bucket placed below the vehicle. Full pans or buckets are then dumped into a larger container, such as a 55-gallon drum, UST, or AST, prior to off-site disposal. The potential environmental impacts from fluid changes are soil and water contamination from spills or improper disposal. Disposal of these fluids by infiltration through shallow disposal systems is prohibited by the SDWA's Class V rule.
Storage of new materials may be regulated under the SPCC provisions of the CWA, which require development of a spill prevention plan that generally includes a requirement to provide secondary containment for all tanks and drums. Storage, recycling, and disposal of waste fluids are regulated under the used oil provisions of RCRA. The used oil provisions require used oil to be stored in structurally sound containers labeled with the words "used oil only" and ultimately recycled or burned for heat. Fluids disposed of or spilled in floor drains or surface drains or otherwise released from the facility property are regulated under the NPDES, pretreatment, or stormwater provisions of the CWA. These provisions require notifying EPA or the treatment plant about oil spills, complying with permit provisions, and preventing untreated fluids from reaching surface waters. Fluids stored in underground tanks are regulated under the UST provisions of RCRA, which require that the tanks maintain spill prevention and leak detection devices and be made of specified structurally sound materials.
Washing Vehicle Parts
Washing vehicle parts consists of immersing the small parts, such as nuts, bolts, or carburetor pieces, into a solvent bath of chemical or water-based solvent or spraying them with a chemical or citrus-based solvent. Washing vehicle parts also may include spraying shop rags with solvent and rubbing the solvent on the part to clean it. Chemical solvent washers often consist of a metal sink attached to a 20-gallon drum of solvent. When the solvent is no longer usable, the drum is replaced. Water-based solvent washers consist of an enclosed bath with high-pressure sprayers. The use of chemical solvent washers is regulated under the cold solvent bath section of the CAA, which requires sink lids to be kept closed and specifies additional practices to minimize the release of hazardous air pollutants. The disposal and recycling of used chemical solvent are regulated under RCRA, which specifies disposal methods. The disposal of wastewater from water-based solvent washers is prohibited from injection under the SDWA and may be regulated under the pretreatment program or NPDES programs of the CWA. The disposal of solvent-contaminated rags may be regulated under RCRA.
Maintaining Vehicle Batteries
Maintaining vehicle batteries includes testing, changing, storing, and disposing of new and used vehicle batteries. The storage of batteries may be regulated under the NPDES stormwater provisions of the CWA, which require that batteries be contained and covered to prevent potential leaks from coming in contact with stormwater. Disposal of batteries may be regulated under RCRA, which requires that batteries either be returned to a supplier or recycler or meet stringent disposal requirements.
Repairing Air Conditioners
Repairing vehicle air conditioners includes adding, removing, and recycling CFC refrigerants, as well as performing general maintenance on vehicle air conditioners. These activities are regulated under the CAA provisions designed to prevent ozone depletion by requiring the capture and recovery of used refrigerants, the use of certified recycling equipment, and the training and certification of operators.
Washing Vehicles and Shop Floors
Washing vehicles and shop floors including spraying water and detergent on vehicles and floors and discharging the washwater through a drain to a septic tank is prohibited under SDWA. Some facilities may dump used washwater on the ground outside of the facility, which is generally improper. Washing vehicles and shop floors may be regulated under the pretreatment program or NPDES program of the CWA. These sections may require the facility to obtain permits, install oil and water separators, or comply with other provisions designed to prevent contaminated wastewater from reaching the environment.
Repairing or Replacing Exhaust Systems
Repairing or replacing exhaust systems consists of repairing or replacing catalytic converters. Any work that affects vehicle emissions is regulated under the CAA, which requires that records be kept of all converter repair and replacement, and specifies procedures for ensuring that removed converters are properly replaced.
Vehicle painting includes overall body painting, touch up, paint and thinner mixing, and unusable paint and thinner disposal. Vehicle painting often is conducted in an enclosed room or booth that has positive pressure ventilation to ensure that paint fumes leave the room, rather than being inhaled by the painter. To minimize air pollution, air filters are placed in the vents and changed regularly. Vehicle painting also includes changing and disposing of these filters. If significant quantities of paints containing hazardous materials are used or if the tribal government is located in a designated geographic area, air emissions from painting operations may be regulated under the CAA, which may specify the type of ventilation system required and the frequency for changing the filters. The disposal of air filters used to filter emissions from paints containing hazardous materials, disposal of many unusable paints, and disposal of spent thinners is regulated under RCRA. Preparing a vehicle for painting (e.g., stripping, sanding) may also be regulated under RCRA because such activities may result in the generation of a hazardous waste.
Storing Materials Outside
Due to space and safety concerns, many vehicle repair shops store drums of used and new fluids, hazardous materials, batteries, vehicle parts, or other wastes outside of the shop. The storage of any materials that could reach waterways through spills or stormwater runoff are regulated under the NPDES direct discharge or stormwater discharge provisions of the CWA, which require that the facility prevent these materials from coming in contact with stormwater.
Tribal governments operate and maintain vehicle-fueling stations to provide fuel to their vehicles. Because these activities could affect the environment, they are regulated under environmental laws and regulations, as indicated below.
- Fuel storage - CWA and RCRA
- Fuel dispensing - CAA
- Disposal of spilled unusable fuel - RCRA and SDW
Vehicle fuels, including gasoline, kerosene, and diesel fuel, are stored in underground or aboveground storage tanks that are connected by piping to a fuel-dispensing unit. The operation and maintenance of these tanks may be regulated under the SPCC section of the CWA, which requires development and implementation of spill prevention plans and secondary containment for aboveground tanks, and/or under the UST section of RCRA, which specifies structural, monitoring, and leak detection requirements for underground tanks.
Fuel dispensing units used at tribal government facilities are similar or identical to those used at retail service stations and could emit organic vapors to the atmosphere. In some areas, dispensing is regulated under the CAA, which may require the dispensing units to have vapor recovery systems at the point of fueling and at the location where the aboveground or underground fuel storage tanks are filled. In addition, fuel-dispensing units are required to dispense fuel at a prescribed gallons-per-minute rate to prevent spills.
Disposal of Unusable Fuel
In the course of fueling or fuel loading operations, fuel may be spilled. Fuel that cannot be dispensed into a vehicle for use must be disposed of properly. The disposal of this fuel may be regulated under RCRA, which sets requirements for handling, storage, and ultimate disposal of hazardous wastes. A repair shop may be required to report any spill to tribal authorities.
Purchasing includes the acquisition of vehicles, equipment, and materials. The purchasing of clean fuel vehicles for tribal governments with large vehicle fleets may be regulated under the CAA. Other purchasing decisions, such as the purchase of hazardous or water-based solvent, can directly impact whether the fleet operations are subject to additional environmental requirements.
Pollution Prevention in Vehicle/Equipment Maintenance
Pollution prevention opportunities abound in the area of vehicle and equipment maintenance. Usually, three factors contribute to the level of success of a pollution prevention plan. The first factor involves auditing current procedures, researching pollution prevention opportunities, and committing to make appropriate and beneficial changes. This step requires researching alternative products and funding equipment purchases. The second factor is funding. Generally, present funding can be reappropriated in a phased plan to purchase new equipment, products, and/or contract services. The third factor deals with the regulatory requirements and contract services available based on the facility's location. Some facilities base their decisions for a pollution prevention plan on the regulatory requirements contained in RCRA, OSHA, and/or tribal regulations.
Pollution prevention technology implemented under this approach will enhance the safety of workers, improve regulatory compliance, and may lower the operating costs of the facility. There are many options for pollution prevention, depending on the waste stream's characteristics and regulatory requirements. Some of the best ideas for pollution prevention can come from mechanics who perform the tasks every day, but changing old habits is the key to pollution prevention success.
Typical Wastes Generated
- Cleaning solvents
- Used/soiled shop rags
- Unrecovered Freon from air conditioners
- Scrap metal
Parts Cleaning Systems
There are many different types of parts cleaning systems. Some utilize a pump to circulate cleaning solvent/solutions. These machines can be managed by the facility or contracted to a service that maintains the system and hauls away any generated wastes. The type of system and the solvent/solution (e.g., organic based, aqueous, citrus based) used in the system will determine the applicable regulatory management requirements and pollution prevention opportunities. Some systems have a distiller to clean the solvent and a reservoir tank to hold the waste that is "cooked" out, while others utilize filters to extract impurities. Protecting the integrity of the cleaning solvent/solution in order to extend its life and reduce disposal quantities is pollution prevention. For example, it may be possible to avoid reaching a regulated threshold by managing system use, including purchasing a different system or altering filter types. Also, there are aqueous-, semi-aqueous, and citrus-based systems that offer unique opportunities for pollution prevention. With any of these types of systems, it is important not to introduce any non-compatible solvents/solutions into them that would cause them to become regulated hazardous waste.
Some Factors to Consider in a Filtered System
- Utilizes non-chlorinated solvents in the system
- Has a high flash point solvent of more than 140 degrees
- Has a closing lid for when the system is not being used to reduce evaporation and air emissions
- Can meet all regulatory requirements regarding disposal of filters
- Meets OSHA safety requirements
Some Factors for Aqueous Solution Systems
The system cleans to the standard required for the part to function properly; There will be minimal regulatory restrictions if disposal of the solution is required; and A balance needs to be maintained for the bioremediation in the system to work properly.
Key Tips. Maintain the solution/solvent integrity to extend the solution/solvent life and increase the frequency of filter replacement to reduce disposal costs of solvent/solution. Let the part sit in the washbasin and drip dry to reduce solvent "drag out" loss. Choosing aqueous systems may reduce regulatory requirements all together.
Chlorinated solvents/solutions should not be used in any application to clean parts. Avoid using any aerosol cleaning products that are not RCRA approved. The use of these types of solvents/solutions can cross contaminate fluids and make them regulated under RCRA and increase OSHA requirements. Solvent/solutions purchased in bulk and applied with self-pressurizing applicators will reduce the use of the product and waste containers. Pre-cleaning with a putty knife and wire brush and utilizing recyclable shop rags will also reduce disposal cost and excess use of solvents/solutions. Verify compatibility of the with the parts washer's solvent/solution. Aqueous solutions may be the best option when utilized properly. There are pre-cleaning solvents/solutions that can affect the parts washing tank if, after use, further cleaning of a part is required in that system. Eliminate overuse and set standards on the amount of cleaning required for the particular part to function properly.
Some Factors to Consider in a Self-pressurizing System
- Use of non-chlorinated solvents
- Solvent/solution is compatible with the parts washer
- Solvent/solution's contents affect on RCRA/OSHA regulatory requirements
- Does the manufacturer/supplier offer system product support and/or training?
Key Tips. Utilizing a scraping device and/or wire brush, recyclable shop towels, and a non-regulated RCRA solvent/solution will reduce usage and hazardous waste regulatory requirements. Solvents/solutions with low VOC and low toxic contents produce fewer emissions that are harmful to the employee.
Using manufacturer-specified antifreeze/coolant is required to maintain warranties and extend the life of the vehicle/equipment. Antifreeze/coolant can be recycled in various ways, to manufacture specifications and for reuse on site. The facility should verify that the vehicle/equipment warranty would be honored if this reused antifreeze/coolant were utilized. One method to recondition used antifreeze/coolant is to utilize a mobile service to perform on-site recycling at your facility. Verify that the service is licensed, and have a neutral third party laboratory test results to demonstrate the system works, and guarantees the product. Another approach is to purchase and use an on-site recycling machine. This allows full management of the system's use and the quality of the product it produces. Either one of these will reduce new product purchases and associated RCRA disposal costs, as well as ensure a readily available product.
Some Factors to Consider in Choosing the Best Method for the Facility
- Verify warranty coverage of the vehicle/equipment for the system/service chosen
- Verify disposal approval for filters generated from the recycling system
- See if bulk containers for used/recycled anti-freeze are available and proper storage can be achieved
Key Tip. Whatever method is chosen, tribes should make sure testing and warranties of the system's product are backed, and the manufacturer of the vehicle/equipment allows for the use of the reconditioned anti-freeze/coolant.
Do not use disposable shop rags. Obtain and use reusable rags, contract with a company to deliver clean (reusable) rags and pick up dirty (reusable) rags. Verify that the service selected has an approved method and facility for recycling the rags. The only exception to utilizing a service is if the facility's nonregulated waste is disposed of at a waste-to-energy plant that can incinerate waste rags. Remember, never use chlorinated solvents regardless of the recycling/disposal method.
There are several manufacturers that have different machines that will recover Freon from a system for off-site recycling. Other machines recover and recycle the Freon and then place the recycled Freon back into the repaired unit. These types of machines reduce new Freon purchases and disposal costs associated with the management requirements of the waste stream. If the repair of air conditioners is performed offsite, tribes should verify that the company handles generated waste consistent with applicable regulations.
Some Factors to Look for in Selecting a Machine
- Is regulatory approved and registered?
- Is backed by third party test results verifying efficiency?
- Has factory warranty and supplier training?
There are several types of lubricating oils in the various types of vehicles/equipment in use today. Changing these oils should be performed as determined by use and not according to specific dates. If the vehicle/equipment is underutilized and/or is only needed for a specific task, changing the oils by a timed date is a waste of resources. Synthetic oils generally have a longer span of time for use before a change is required. When choosing the correct lubricant, verify warranty approval and track the miles/hours of use of the product in the vehicle/equipment. Check various disposal options to see if refining of the waste oils is available over fuel blending for incineration. Keep non-compatible oils separate from one another to reduce possible cross contamination and increased disposal cost.
Most replaced parts are made of metal. Some metal parts must be exchanged for the new part when purchased. Many parts can be recycled, saving the facility disposal costs. Lead tire weights, broken engine brackets, nuts and bolts, and body parts are just a few that have value for recycling. Set up places to store the recyclable metal, preferably out of the weather, and contract with a scrap dealer to pick up the recycled parts at the facility on an as needed basis. Some scrap dealers will supply the container to the facility for the storage of the metal to be recycled. The scrap dealer may require separation of the different metals.
For related information visit EPA’s National Indian Country Enforcement and Compliance Assurance Priority site and EPA’s Enforcement and Compliance Assurance Program in Indian country site.