Hazardous Waste Minimization Checklist and Assessment Manual for Auto Paint Shops CALIFORNIA DEPARTMENT OF TOXIC SUBSTANCES CONTROL JULY 1992
ACKNOWLEDGEMENTS This document was prepared by the California Department of Toxic Substances Control. The Department expresses appreciation to J. Rodney Marsh, Julio Nuno, and Carol Votaw of SCS Engineers for preparation of the Waste Audit Study-Automotive Paint Shops. DISCLAIMER The mention of commercial products, commercial services, their sources and/or their use in connection with material reported herein is not to be construed as actual or implied endorsement of such products or services.
TABLE OF CONTENTS
I. Introduction Hazardous waste has become a major issue throughout the nation. Problems arise during its generation, transportation, and disposal. The preferred method of hazardous waste management is one that takes into account pollution prevention. Pollution prevention is simply an ethic that says the hazardous waste manager should control releases of polluting elements to the environment as much as possible. This includes the air, water, and land. Waste minimization is an aspect of pollution prevention. Waste minimization includes source reduction and recycling. This means finding ways to generate less waste and then recycling the remaining wastes whenever possible. The purpose of this handbook is to provide the information auto paint shops need to minimize their hazardous waste. It intends to promote voluntary waste minimization and pollution prevention. However, many benefits can arise from implementing the suggestions in this handbook. Waste minimization can help your company achieve compliance with regulatory requirements, lessen time and money spent in managing hazardous wastes, and decrease short- and long-term liabilities. In some instances, it might even allow small quantity generators to drop out of the regulatory loop altogether. The waste streams that are addressed in this handbook are the major wastes generated in auto paint shops. They include: solvents (including thinners), paint wastes, catalysts, and, other wastes including freon and antifreeze. This handbook is intended to be used by the auto paint shop manager and shared with the shop s employees. It is organized in two parts. The first part of the handbook is intended for all shop personnel. It consists of the Waste Minimization Checklist which includes general suggestions for reducing hazardous waste. To emphasize the use of the checklist, the shop manager may wish to make copies of this section and distribute them to the employees. The second part is to assist the manager or foreman in conducting a more in-depth analysis of possible waste minimization options. It consists of an Economic Analysis Worksheet and Technical Options Worksheet. The implementation of ideas set forth in this manual may aid in decreasing your waste management costs by using sound environmental practices.
Il. Waste Minimization Checklist for Auto Paint Shops SOURCE REDUCTION Source reduction means generating less hazardous wastes by preventive means. If less hazardous waste is generated, then there will be less hazardous waste to manage. For auto paint shops, source reduction can be achieved using several approaches: controlling inventory and material usage employee training storing waste properly modifying equipment The preferred answers are in bold print and comments are provided next to the checkmark. Controlling Inventory and Material Usage: 1. Do you purchase only what you need so that you don t end up with expired materials? 2. Do you have a first-in, first-out material usage policy? Purchase only the amount of materials that you know you will be using in the near future. Taking advantage of volume discounts for material purchases can lead to stockpiling of hazardous materials. These materials in turn may require costly hazardous waste disposal. Keeping only necessary materials on hand also helps encourage careful use. Using materials that have closing expiration dates first will allow you to avoid needing to dispose of outdated materials. 3. Do you conduct periodic inspections of materials in storage? Periodic inspections will help you detect corroding containers and avoid expiring materials. 4. Are material inventories computerized? Do you track the usage of raw materials? Tracking is a good tool for hazardous materials management. It will help you order only what is necessary, use the materials with the oldest expiration dates first, and make inefficient operations and use of materials more obvious.
5. Do you limit raw material access? 6. Are employees encouraged to promote good housekeeping practices? Limiting access to raw materials can help to encourage conservation of material use. It will also give the shop foreman an opportunity to monitor material use. However, in smaller shops where the foreman or owner can monitor the employees, access to materials does not necessarily need to be limited. The foreman or owner can make verbal or written comments on materials use and suggested limits. Preventing and controlling leaks, careful product transfer, and careful drum transport are good housekeeping methods that are all effective means of waste minimization. Employees should be encouraged to handle and maintain materials and equipment conscientiously. 7. When cleaning your spray gun, do you save the unused paint from the gun and feed tube? 8. Do you follow manufacturer-suggested methods for cleaning and using your spray gun? The method for saving the paint left in the spray gun depends on the type of gun you use. In general, if you are using a suction-feed gun, you can loosen the cap, close the spray hole, and then pull the trigger to force paint back into the can. Whether you have a suction-fed or pressure-fed gun, you should be able to return the unused paint by blowing back. This is important because it saves thinner that is used to clean the spray guns. (It also saves a little paint.) It is important to follow manufacturer s suggested procedures. They are intended to maximize efficiency and minimize waste.
9. Do you have set methods for cleaning painting equipment such as nozzles? Are they cleaned immediately after completing the task? Is there a scheduled maintenance and cleaning program? In some instances, having a scheduled maintenance and cleaning program for nozzles and other painting equipment (and parts) can have a profound impact on reducing hazardous wastes. Painting equipment should be cleaned immediately in order to reduce the amount of solvent that will be necessary to clean the part. 10. Do you plan your paint mixing so that you will only use the necessary paints and solvents? Planning is the key to using paints in an efficient manner. Plan your mixing so that you use only the necessary paints and thinners. A properly sized container will also reduce waste. Employee Training: 11. Have the shop s employees received waste minimization and waste management training? Employees need to be trained in how to handle hazardous materials in a way that minimizes waste. Written instructions remind employees of waste minimization and allow them to review the instructions when necessary. Letting employees know of their specific responsibilities will also help them understand their role in waste minimization. They should be made aware of the importance of pollution prevention. In some cases, chemical suppliers have training films that can be used for employee training. Waste Containment and Storage: 12. Do you collect leaking oils, antifreeze, and other fluids from automobiles? Use drip pans and containment areas so that you will not have to use an absorbent to soak up spills. Absorbent contaminated with oil or other hazardous fluids must be handled and disposed as a hazardous waste. Collecting and containing any leaking fluids also means that you will not have to wash a spill into the drain which can pollute water. 4
13. Do solvent, thinner, and Significant amounts of materials can evaporate waste containers have when lids are left off cans and drums. Most tightly fitting lids to prevent solvents and thinners evaporate much faster than evaporation? water. When these materials evaporate, they pollute the air. 14. Are the proper tools and procedures available to move drums safely? Powered equipment or handtrucks should be used to move drums so as to prevent damage or punctures. Under no circumstances should drums be tipped or rolled, even when empty. Negligent transport procedures will cause drum damage, particularly to seams, which could lead to leaks or ruptures during future use. Drums should also be capped tightly before they are moved. 15. Are the different wastes kept separated? Keep wastes segregated so that they may be more easily recycled. Two or more types of wastes that are separately recyclable may not be recyclable if they are mixed during storage. In this case, you will have to dispose of them as hazardous waste at a much higher cost to you. Additionally, commingling of wastes may be illegal, or may cause a chemical or thermal reaction if the wastes are incompatible. 16. Do you have a plan for storing your hazardous chemicals? 17. Do you give away your excess paints to customers for touchups? Keep hazardous chemicals segregated by hazard classes in order to minimize fire danger. Use the appropriate containers in order to minimize leaks. Build concrete dikes around the storage area or use other types of secondary containment to ensure that leaks will be contained. Passing along small amounts of excess paint for customer touch ups will not only make your customer happy, it will reduce the amount of waste that you will have to dispose. 5
Equipment modification: 18. Do you have a variety of sprayer cup sizes to prevent overmixing? Using the proper cup size allows more complete use of materials. It also means that you have to clean a smaller cup, thereby using less thinner. 19. Have you considered using electrostatic paint guns or low volume, high pressure paint guns to reduce the amount of overspray? Using an efficient sprayer can help you save paint, reduce costs, and reduce the amount of pollutants that escape into the air. 20. Do you pay attention to adjusting your paint mix to the proper spraying viscosity before applying the coats? Proper viscosity is vital to achieving a good finish. This will mean less repainting and therefore less waste. RECYCLING The majority of waste products generated by the auto body and painting industry are reusable or recyclable. These wastes include paint and thinner wastes, used oil, car batteries, and soiled rags. Paints used in this industry contain pigments which are compounds of cadmium, chromium, zinc, and lead. Contaminated thinner containing paint sludge is generated from paint operations as a result of equipment cleanup, spills, off-spec paints, and excess paint. 1. Are thinners and other Some spent thinners and solvents can be used solvents saved and reused directly for other purposes before being sent to a whenever possible? recycler. For example, color-contaminated thinner may be reused as an undercoating paint thinner. Also, some spent solvents may be used for equipment and parts cleaning. These solvents may be 6
used in a counter-current rinsing system. The idea is to use the more contaminated solutions to clean dirty equipment and the less contaminated solvents to get relatively clean equipment ready for their next use. 2. Do you reuse paints? Compatible leftover paints can be mixed and used as undercoating. 3. Are oils and antifreeze collected and recycled? These liquids should be collected, kept separated, and recycled. All can be recycled back into useable products. (Refer to the Waste Exchange Directory or recyclers directory.) 4. Do you make use of a milkrun recycler? There may be a company in your area that specializes in recycling oils, antifreeze, or other automotive fluids. Check your local yellow pages under recycling, or order a copy of the California Waste Exchange s Directory of Industrial Recyclers from the Department of Toxic Substances Control. (See the last page of this handbook for ordering information.) 5. Do you use reusable containers? Disposable containers with hazardous material residues (other than paint cans with a thin dry coating of paint) must be disposed as hazardous wastes. 6. Is there an opportunity to recover your solvents by distilling them? Distillation is a well-established process for recycling solvents. For some shops, it is economical to do this onsite. See the economic evaluation worksheet (p. 11) to determine the benefits and costs for your company. 7
7. Have you considered reclaiming your solvents by gravity separation? 8. Do you review waste exchange catalogs to see if there are materials your shop uses that are another industry s waste product? Gravity separation is an inexpensive form of resource recovery that is relatively easy to implement. This may be done onsite or offsite. Thinners reclaimed using this process can be used as a wash thinner. Wash thinners can be used for primer coats, undercoating, or for equipment cleaning. One industry s waste can be another industry s input material, and is usually available at reduced costs or free. For example, you may be able to pick up a solvent from an electronics manufacturer that may be considered unusable by the electronics industry, but very usable for parts and paint equipment cleaning. In this way, you can do your part to protect the environment and save money at the same time. 9. Do you send used batteries to a recycler? Used batteries contain lead oxides and sulfuric acid, both of which are hazardous. These batteries can be recycled by having them picked up by battery suppliers, or you can bring them to battery wholesalers yourself without hazardous waste manifesting or special registration. III. Technical Options Worksheet After working through the checklist, use this worksheet to evaluate your options. As you can see, we have left the cost-effectiveness factor up to you. The values that have been pre-assigned are our best judgement of the proposed technique. You should feel free to change these based upon your specific needs and situation. Use the Economic Worksheet in the next section to assist you in estimating cost effectiveness. We recommend that you use your final calculation for the payback period as your primary guide for rating the cost effectiveness. Use a rating from one to five. Give the Cost Effectiveness a high rating if you decide that the option you are considering will pay back in a short period of time. If you decide that it is not cost-effective or would take too long to pay back, give it a low rating. Add the lines to total the rating for each technique you investigate. Use these ratings to help you decide which techniques are good for your company by selecting the ones with the highest ratings for final consideration. 8
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IV. Economic Worksheet This worksheet can be used to calculate rough estimates of projected costs, savings, and payback periods associated with each waste minimization option. These worksheets do not take into account amortization, depreciation, or tax factors. Waste Minimization Option: Equipment Installation Utilities Production Down Time Construction Materials Other Implementation Costs: lmplementation Costs= Capital lnvestment Annual Operating Cost Savings 11
V. Additional Publications Handling and Transport of Spent Lead-Acid Storage Batteries for Recycling (1991) Used Oil Filters: Handling, Storage, and Transport for Recycling (1992) Directory of Industrial Recyclers (1992) Used Oil: Handling, Storage, and Transport for Recycling (1992) VI. Further Information For further information write or call: Department of Toxic Substances Control P.O. Box 806 Sacramento, CA 95812-0806 (916) 324-1807 For information about your regulatory requirements, contact the DTSC Regional Office nearest you: Region 1 Sacramento (916) 855-7700 Fresno (209) 297-3901 Region 2 Berkeley (5 10) 540-2122 Region 3 Burbank (8 18) 567-3000 Region 4 Long Beach (213) 590-4868 The Federal government also regulates hazardous wastes. For information call: Environmental Protection Agency Region IX 75 Hawthorne Street San Francisco, CA 94105 (415) 744-1500 In addition to the State and Federal agencies listed above, some local agencies have jurisdiction over certain aspects of hazardous materials and waste management. These include sanitation districts, air quality management districts, regional water pollution control boards, and fire departments. 12 92 82979
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