Waste Management Areas
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![old-oil-filter](https://erscompliance.com/wp-content/uploads/2017/07/old-oil-filter.jpg)
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Parts Cleaners & Used Solvents
Dealership service operations clean various kinds of equipment using solvents. Dealerships must follow EPA waste management regulations for “waste” or “spent” solvents.
Brake Washer
Dealership service operations clean various kinds of equipment using solvents. Dealerships must follow EPA waste management regulations for “waste” or “spent” solvents.All owners and operators of solvent cleaning equipment that use these solvents must submit an initial notification report to their state or local air quality authority. This report must include information on each solvent cleaning machine and control equipment, and the yearly estimated consumption of each halogenated solvent used. Additional NESHAP requirements depend on the type of solvent cleaning machine (e.g., batch vapor, in-line) that a shop uses.
AC Recharger
One of the largest uses of CFC-12 in the U.S. is as a refrigerant in motor vehicle air conditioners (MVACs). Section 609 of the Act gives EPA the authority to establish requirements to prevent the release of refrigerants during the servicing of MVACs and to require recycling of refrigerants. Strict regulations are enforced on the methods of extraction and recharging, the recover/ recycle equipment that cleans the refrigerant and even the Technicians who repair or service CFC-12 motor vehicle air conditioners must be trained and certified by an EPA-approved organization.
Battery Chargers/ Batteries
There are many types of used batteries with different disposal requirements. Some of these batteries may be classified as hazardous waste.
Engine Oil Extractor
Dealership repair shops must recycle or reclaim the used oil. Used oils are regulated under the Used Oil Standards, and are typically not classified as hazardous wastes under the federal program. However, some states may have stricter management and disposal requirements and consider waste oil Hazardous wastes.. ERS Knows the applicable states used oil disposal requirements. Dealerships must maintain all records on their used oil storage and recycling activities.If the dealership transports more than 55 gallons of used oil off site to an approved used oil collection center, it is required to (1) have an EPA ID number and (2) be licensed as a used oil transporter.
Coolant/Antifreeze Extractor & Drain
To avoid having to manage and dispose of used antifreeze as a hazardous waste, a facility can reclaim used antifreeze in a closed loop system that connects directly to the radiator, filters the antifreeze, and returns it directly back into the vehicle. EPA does not consider such reclaimed material to be a solid waste. Thus, even though the antifreeze may be hazardous, it is not a hazardous waste because the antifreeze is returned to its original use as a coolant. Non-closed systems are available that connect to a used antifreeze storage drum. However, because these are not closed loop systems, the antifreeze in the drum may be considered a hazardous waste and must be stored according to the hazardous waste regulations.
Used Oil Filters
Used oil filters are exempt from federal hazardous waste requirements as long as the filters:
- Are not terne-plated. Terne is an alloy of tin and lead. The lead in the terneplating makes the filters hazardous.
- Have been properly drained (i.e., hot-drained) of used oil.
According to federal regulations, a facility can dispose of filters as solid waste (in some states) provided that the filter has been hot-drained to remove residual used oil. This means that no matter what draining option is used, one should remove the filter from a warm engine and drain it immediately. Four distinct methods of hot-draining can be used.
Fuel Filters (Other Than Oil)
Although not covered by the used oil requirements, used fuel filters not containing oil should be handled in the same manner as oil filters, except that the drained fuel should be separated. If the fuel filters are not drained, the entire filter must be disposed of as a hazardous waste. See the hazardous waste fact sheet series for more details on handling waste fuels that are considered hazardous waste.