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III.H. Vehicle/Equipment Maintenance
Local governments are responsible for operating, maintaining and purchasing motor vehicles and equipment to perform government services. Vehicles used range from school busses, fire engines, snow plows, and heavy construction equipment to automobiles used by building inspectors, police departments, and government officials. Equipment may include items such as pumps, tools, and boilers. Local government fleet operations include vehicle repair shops, fueling stations, and purchasing operations. (Note: While this section discusses vehicle maintenance specifically, many of the regulated activities apply to equipment maintenance, also.)
Vehicle repair shops conduct several activities that have the potential to impact the environment and are regulated under U.S. environmental laws and regulations. As indicated below, these activities include changing fluids such as oil and antifreeze, washing parts, maintaining batteries, repairing air conditioners, washing vehicles and shop floors, repairing and replacing exhaust systems, painting vehicle bodies, and storing materials outdoors. Most of these activities may be regulated both under the hazardous waste or used oil provisions of RCRA, and the NPDES, pretreatment, or storm water provisions of the CWA, while some are regulated under the CAA.
Exhibit 55. Vehicle Repair Shop Activities
(photo from CCAR-Greenlink)
Each of these activities is regulated under a section of EPA environmental regulations.
· Activities with aspects regulated under RCRA:
- Changing vehicle fluids
- Washing vehicle parts
- Disposing used batteries
- Painting vehicles
· Activities with aspects regulated under the CWA:
- Changing vehicle fluids
- Washing vehicles and shop floors
- Storing materials outside (including batteries)
· Activities with aspects regulated under the CAA:
- Vehicle painting
- Repairing air conditioners
- Repairing exhaust systems
- Washing vehicle parts.
More detail on the specific activities related to vehicle repair shops and the respective regulations are presented below.
Changing Vehicle Fluids
Changing vehicle fluids includes oil, transmission and break lubrication, and antifreeze changes. Changing vehicle fluids also includes storage of both new and waste fluids, and management or disposal 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 aboveground storage tank prior to off-site disposal. The potential environmental impacts from fluid changes are soil and water contamination from spills or improper disposal. 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 providing 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 that used oil is stored in structurally sound containers labeled with the words "used oil only", and ultimately recycled or burned for heat. Fluids disposed or spilled in floor drains, surface drains, or otherwise released from facility property, are regulated under the NPDES, pretreatment, or storm water provisions of the CWA. These provisions require notification of EPA, the state, or a local treatment plant, complying with permit provisions, and prevention of 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. 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. Disposal and recycling of used chemical solvent is regulated under RCRA, which specifies disposal methods. Disposal of wastewater from water-based solvent washers may be regulated under the pretreatment program or NPDES section of the CWA. 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. Storage of batteries may be regulated under the storm water provisions of the CWA which requires that batteries be contained and covered to prevent potential leaks from coming in contact with storm water. 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, and performing general maintenance on vehicle air conditioners. These activities are regulated under the CAA which is 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 all operators.
Washing Vehicles and Shop Floors
Washing vehicles and shop floors includes spraying water and detergent on vehicles and floors, and discharging the washwater through a drain to a septic tank, POTW, or waterway. Some facilities may dump used washwater on the ground outside of the facility. Washing vehicles and shop floors may be regulated under the pretreatment program or NPDES section of the Clean Water Act. 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 assuring removed converters are properly replaced.
Painting Vehicles
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 which has positive pressure ventilation to assure 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 these filters. If significant quantities of paints containing hazardous materials are used, or if the local 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, and the frequency at which filters must be changed. Disposal of air filters used to filter emissions from paints containing hazardous materials, disposal of many unusable paints, and disposal of spent thinners are regulated under RCRA. Preparing a vehicle for painting (e.g., stripping, sanding) may also be regulated under RCRA is that such activities may result in 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. Storage of any materials that potentially may reach waterways through spills or storm water runoff are regulated under the NPDES or storm water provisions of the Clean Water Act which require that the facility prevent these materials from coming in contact with storm water.
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