"P2 Opportunities Checklist for Vehicle Maintenance Activities" - California

P2 Opportunities Checklist for Vehicle Maintenance Activities is a legal document that was released by the California Department of Toxic Substances Control - a government authority operating within California.

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Date:______________
P2 Opportunities Checklist for Vehicle Maintenance
Activities
Facility Name:____________________________________________________________________________________________
Facility Address:__________________________________________________________________________________________
Hazardous Materials
Yes
No
Compliance and P2 Opportunities
Controls
A complete inventory is critical to reducing the overall
Do you have a hazardous
number of hazardous materials stored in your shop.
material inventory of all
An inventory will enable shop managers to evaluate
hazardous materials stored
and possibly reduce the number of hazardous
at your shop?
materials maintained at the shop.
Owners may be able to reduce hazardous materials
permit fees, which are sometimes calculated by the
number of hazardous materials stored at a facility.
A “high and low” level is established by; determining a
Is a “high and low” amount
“high” level (the highest amount of material a shop will
designated for each
use in a 30 day period), and a “low” level (generally a
hazardous material identified
number for which the supply will not run out until a new
in your inventory?
order is received.)
A shop can eliminate overstocking and waste due to
confusion.
Checking inventory against HIGH/LOW quantity limits
Is your hazardous materials
will help determine excesses or shortages
inventory updated monthly?
Rotate containers on shelf so that hazardous materials
Do you use a “first-in first-
nearing expiration are placed at front of shelves. This
out” policy to prevent
will eliminate hazardous materials from becoming
materials from deteriorating
hazardous waste and requiring disposal.
in storage?
You may generate unnecessary hazardous waste if you
Do you maintain and enforce
use supplies for purposes other than their intended uses.
a clear policy of using
For example, don’t use parts cleaning solvents to clean
hazardous materials only for
your floors.
their intended purpose?
Shop Cleanup
Management
Fluid drainage of vehicles should occur only at
Are drip pans or other spill
designated locations that are set up to capture any spills
prevention methods used at
that would occur.
fluid transfer points.
Dry shop methods for spills within the service bay will
Do you use a dry shop
help to eliminate contaminated absorbents generated
method for cleanup of spills
from spill cleanups. Contaminated absorbents represent
in your shop area?
a considerable cost and waste generation total for many
auto repair activities.
Page 1 of 8
Date:______________
P2 Opportunities Checklist for Vehicle Maintenance
Activities
Facility Name:____________________________________________________________________________________________
Facility Address:__________________________________________________________________________________________
Hazardous Materials
Yes
No
Compliance and P2 Opportunities
Controls
A complete inventory is critical to reducing the overall
Do you have a hazardous
number of hazardous materials stored in your shop.
material inventory of all
An inventory will enable shop managers to evaluate
hazardous materials stored
and possibly reduce the number of hazardous
at your shop?
materials maintained at the shop.
Owners may be able to reduce hazardous materials
permit fees, which are sometimes calculated by the
number of hazardous materials stored at a facility.
A “high and low” level is established by; determining a
Is a “high and low” amount
“high” level (the highest amount of material a shop will
designated for each
use in a 30 day period), and a “low” level (generally a
hazardous material identified
number for which the supply will not run out until a new
in your inventory?
order is received.)
A shop can eliminate overstocking and waste due to
confusion.
Checking inventory against HIGH/LOW quantity limits
Is your hazardous materials
will help determine excesses or shortages
inventory updated monthly?
Rotate containers on shelf so that hazardous materials
Do you use a “first-in first-
nearing expiration are placed at front of shelves. This
out” policy to prevent
will eliminate hazardous materials from becoming
materials from deteriorating
hazardous waste and requiring disposal.
in storage?
You may generate unnecessary hazardous waste if you
Do you maintain and enforce
use supplies for purposes other than their intended uses.
a clear policy of using
For example, don’t use parts cleaning solvents to clean
hazardous materials only for
your floors.
their intended purpose?
Shop Cleanup
Management
Fluid drainage of vehicles should occur only at
Are drip pans or other spill
designated locations that are set up to capture any spills
prevention methods used at
that would occur.
fluid transfer points.
Dry shop methods for spills within the service bay will
Do you use a dry shop
help to eliminate contaminated absorbents generated
method for cleanup of spills
from spill cleanups. Contaminated absorbents represent
in your shop area?
a considerable cost and waste generation total for many
auto repair activities.
Page 1 of 8
Facility Name:___________________________________________________________________________________________
Shop Cleanup
Yes
No
Management (con’t)
Closing off all drains within the service bays will help to
Are all drains and sumps
prevent illegal discharges occurring from spills to the
within the service bay areas
storm water and sanitary sewer systems
closed?
Oil caddies help to eliminate the potential for oil spill
Are oil caddies used for the
occurrences during fluid drainages and the
collection and transportation
transportation and pouring oils form oil pans into used oil
of used oils to collection
storage containers.
points.
Funnel lids used on storage drums at your waste
Are funnel lids used on
accumulation points will help eliminate spills by
drums that liquid wastes are
technicians at waste storage areas and improve its
poured into?
appearance.
Storage
Yes
No
Are hazardous materials
A covered storage area is important because
storage lockers or storage
rainwater can increase your waste volumes and
racks located indoors or
contaminate your raw materials. Also, exposure to
under cover?
sunlight can change the characteristic o f your
hazardous materials or raise the pressure inside
sealed containers to dangerous levels.
Are all storage areas
Secondary containment prevents spill runoff and
provided with secondary
minimizes spill contamination of soil and water.
§ 30 gallons of diesel or oil can easily contaminate
containment?
over 10 cubic yard of soil under certain
conditions.
§
Open containers are a spill hazard. It is a regulatory
Are all containers closed
requirement to keep all containers (raw materials
when not in use?
and wastes) closed when not in use.
§ Waste management and waste minimization
Are your personnel trained in
proper hazardous material
plans will not work unless your personnel are
and waste handling and
trained.
storage techniques?
Do you conduct a weekly
Hazardous waste storage areas are required to be
inspection of all your
inspected weekly to determine if:
§ containers are properly marked
hazardous waste
§ containers are in good shape
accumulation areas?
§ wastes are properly segregated
§ spills have not occurred
§ Waste reduction requires waste segregation.
Are hazardous wastes
§ Mixed waste can lower the recycle value of your
segregated and clearly
marked?
wastes.
§ Chlorinated solvents in your used oil will cost
you additional money and prohibit your waste
from being recycled.
Page 2 of 8
Facility Name:____________________________________________________________________________________________
§ Areas must be secured to prevent sabotage or
Is your hazardous waste and
hazardous materials storage
midnight dumping to your collection area.
area within a secured area?
Maintenance Practices
Yes
No
Does you use a battery
Several vendors provide a service to supply
exchange service?
businesses with new batteries and pick up your
used batteries on an exchange basis.
§ This will eliminate storage of lead-acid batteries
at your facility and reduce waste batteries as a
waste stream..
Is your spent antifreeze
You can recycle antifreeze at your shop using
recycled onsite or
various methods:
§ You can purchase your own ASTM certified
transported offsite for
recycling?
equipment and recycle onsite (large generators).
§ You can contract for a recycler to transport
recycled antifreeze to you in exchange for your
spent antifreeze.
§ You can hire a recycler to recycle your
antifreeze onsite using portable equipment.
§ The average cost for an on-site recycler to come
onto your facility and recycle antifreeze is
$2.50/gal. * This is lower than the cost to
purchase virgin antifreeze and it also eliminates
the cost for disposal and transportation.
§ You can contract a laundry service to supply
Do you use an industrial
laundry service or shop rag
clean rags and collect dirty one for washing.
§ In most cases this will allow you to reduced
contract for your dirty rags?
contaminated rags that require disposal as a hazardous
waste?
Do you recycle your radiator
If your shop is primari ly a radiator shop, using a
flush water?
closed loop, recirculating flush system will eliminate
your wastewater discharges and associated
industrial wastewater permits and sampling
requirements.
When servicing brakes do
Use of solvents in cleaning and degreasing
you use a wet cleaning brake
operations is becoming prohibited in many areas in
system that recirculates and
California.
§ Aqueous brake washing machines have been
filters the water based
solution?
successfully tested by many shops and are an
economical advantage to using aerosol cans for
brake cleaning.
Page 3 of 8
Facility Name:____________________________________________________________________________________________
Parts Cleaning
Check with your local Air Quality Management
Districts to see whether they have recently adopted
Yes
No
regulations to prohibit solvent based part washers in
your area.
Have solvent parts washing
Aqueous cleaners are non-flammable, safer to use,
equipment been switched
reduce air pollution and can last longer than solvent
out for aqueous based
based products. Spray cabinets and ultrasonic
cleaning equipment?
aqueous units also save on labor and cost.
Are solvent tanks placed at
Minimizing drips and spills helps to reduce the
convenient locations near
amount of solution you lose and reduces the
work areas to reduce drips
amount of spills around the work area.
and spills?
Do you pre rinse or wipe off
Cleaning excessive sludge and oil off parts before
dirty engine parts?
cleaning in your hot tank will extend the life of your
solution.
• Wipe of excess grease using mechanical
cleaning methods, including wire brushing
• Consider two stage parts washers with filtration
units to extend cleaning solution life.
Does your partwasher have
Allowing solvent time to drain from the parts will
a rack to allow parts to drain
prevent spills when they are taken to the work area.
into the sink for a few
Loss of fluid is also reduced when as much fluid as
minutes after cleaning?
possible is allow to drain back into the cleaning
tank.
Is your parts cleaning tank
A lid on an open tank will help prevent evaporation,
kept closed when not in use?
especially if the tank is heated.
Does a hazardous waste
Aqueous wastes from your parts washers generally
hauler collect parts washer
tend to become hazardous waste after a period of
waste for recycling or
use and require transportation off-site by a licensed
treatment?
hauler. Disposal of parts washer solutions to oil
water separators, or any drains is not permitted.
Do you own onsite recovery
Shops that have multiple parts washers or generate
equipment, such as a
large amounts of contaminated aqueous wastes
distillation or evaporation
may find it economically feasible to purchase on-
unit?
site equipment that can treat or recycle aqueous
waste to significantly reduce waste disposal costs.
Parts Cleaning
Yes
No
Do you use a detergent
Caustic solutions are considered hazardous. Many
based cleaning solution
aqueous solutions display less toxic characteristics
instead of a caustic solution
and can be disposed of at a lower price.
when you are cleaning
Page 4 of 8
Facility Name:____________________________________________________________________________________________
aluminum engine parts?
Does your parts washer
When purchasing parts washer tanks consider
remove the sludge and
systems with recirculating and filtration systems
• Partswasher equipped with mechanical filtering
solids from your solution and
reactivate the remaining
for sludge and oil skimming options allow the
solution for reuse?
operator to extend solution life (up to one to two
years for some systems). Skimmed oil can be
recycled with your used oil, and sludge should
be disposed of separately.
Do you lease your own hot
Purchasing your own cleaning tanks can be an
tank(s) or jet spray
economical advantage to continuously paying for
washer(s)?
leased equipment and services. Operators who
own their own tanks are allowed more options for
the management of their waste and pollution
prevention opportunities. Sources for information
on equipment and service suppliers can be
obtained in the DTSC P2 web directory.
Vehicle Washing
Yes
No
Have you identified the
Owner operators of shops need to know where all
location and destination of all
open drains on a property flow to, whether it is the
drains and sumps on your
storm sewer, sanitary sewer or local surface waters.
property?
Is the use of detergents
Emulsifying detergents inhibit the separation of oil
prohibited at the washrack?
and water which is necessary for the operation of
the oil water separator to prevent oil discharges to
the sanitary sewer or other waterways.
Is your washrack and other
Local agencies require treatment of your waste
areas where vehicle cleaning
wash water if it is disposed of to the sanitary sewer
occurs connected to an oil-
for treatment at a municipal sanitary treatment
water separator?
facility.
Is any water in the washing
Recycling and reuse of wash rack water can reduce
process recycled?
or eliminate the need for i ndustrial waste water
permits and sampling requirements.
Page 5 of 8