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Automotive Repair Shops Case Study – ME 4171 – 1 – Automotive Repair Shops In the following, you will be given a case study which was performed by a consulting firm in the late eighties regarding the waste generated by automotive repair shops in California. A lot of you will have had experience with automotive body repair, or at least know somebody who had such an experience. You don’t have to go far to find examples of these shops in your town. In the following, we will take a look at some issues related to the sustainability of this type of industry. INDUSTRY PROFILE DESCRIPTION OF INDUSTRY The specific companies audited in this study were selected from the industry classifications which include top and body shops and paint shops. The establishments in this industry are engaged in general automotive and body repair with particular focus on collision repair and painting. These shops are distributed throughout the state. The heaviest concentrations are near urban centers and in industrial areas. The majority of these establishments are small in size with an average of 7 employees. Of the 6 audited companies, 1 had less than 5 employees, 3 had between 5 and 10 employees, and 2 had over 10 employees. In a previous study conducted by SCS Engineers (1982), automotive paint and body shops were included as part of a larger small-quantity hazardous waste generator study. Of the 24 companies representing this industry, 17 had between 1 and 10 employees; the remaining 7 had between 11 and 25 employees. The automotive paint and body industry can be divided into two distinct subsets. The first consists of shops that work only on collision repair, frame and front-end adjustments, and body painting. These companies generate paint-associated hazardous wastes almost entirely. These wastes include toxic and ignitable thinners, toxic paint wastes, paint sludges and oil- and solventcontaminated rags, empty cans with paint and thinner residues, and contaminated paint booth filters. The second group of shops do mechanical work as well as collision repair. In addition to the above-noted wastes, these shops produce hazardous waste streams which include waste oils, oil filters, engine/hydraulic fluids, antifreeze, and corrosive wastes from lead batteries. Very few automotive paint and body shops conduct mechanical work in conjunction with collision repair. WASTE GENERATION To perform collision repair, body shops use a wide range of equipment, chemicals, and raw materials. Available services include welding, filling dents with plastics or fiberglass, body section adjustments, alignments, and painting. Body repair work cannot be performed without the use of welding equipment such as blow torches. This equipment is used extensively in body shops and has various uses, including welding, cutting, and heating to shrink and expand metals, to forge or shape metal, and to solder. A welding and cutting job requires equipment such as an oxygen cylinder, acetylene cylinder, welding torch, regulators, and steel filler rods. The flame produced when the two gases are mixed together is hot enough to melt, bond, and repair most commercial metals. Question: Automotive Repair Shops Case Study – ME 4171 – 2 – 1) Do you anticipate hazardous wastes generated through welding? To repair both minor and major auto body damage, hydraulic equipment and hand tools are used to restore damaged sections, assemblies, and parts to their original positions and shapes. Equipment such as jacks and lifts generates enormous pulling and pushing capacities. These heavy machines can straighten bent frames, align hoods and fenders, and adjust panels. Oil is essential to the proper operation of these machines. Regular fluid changes and repair to equipment generate spent fluids, which are recycled with other waste oil generated on site. Question: 2) Do you expect the equipment oil and lubricants to be a significant portion of waste generated? 3) Give an estimate of how much engine oil a car uses during its life span. 4) What is cheaper, to overhaul/recondition a worn car engine which is burning oil or just add motor oil? What is better for the environment? 5) What is an important motivation for reconditioning worn equipment which leaks oil? 6) How does this relate to sustainability? When dented, some areas on an automobile body are not accessible for repair with the use of hydraulic equipment. These areas can be repaired with plastic or fiberglass body filling. These are used by adding a hardener or catalyst to the filler material and layering it in the area of the dent. The material, which is mixed on a glass or steel plate, is applied to the damaged area. To reduce generation of residual waste materials, a conservative quantity of material is mixed. Once the dent has been completely filled, the excess dried material is sanded down flush with the rest of the body. This process does not generate extra material, because the entire quantity that is mixed is applied to the dented areas. The major residual waste generated is fiberglass and plastic dust which collects on the floor during sanding operations. This material is collected and deposited into refuse dumpsters. Minor quantities are rinsed into drains during routine washdowns. Question: 7) What is a big concern in repairing cars with fiberglass filling? 8) If you were told that it was a hazardous process, what would you do to prove or disprove this statement? The largest amounts of hazardous waste are generated from service and painting operations. Services conducted in conjunction with body repair can include oil changes, fluid replenishment, and radiator repairs. These activities generate hazardous wastes such as waste oil, oil filters, engine and hydraulic fluids, wastes from radiator flushings, used batteries, and contaminated rags. Paint operations generate the largest volume of hazardous wastes for this industry through the use of chemicals such as paint thinners and reducers, and the paint itself. Paint is sprayed under pressure onto automobile surfaces via a medium of paint thinner. Once the paint is applied, the thinner evaporates and the paint dries and hardens. A significant portion of the product evaporates during the painting process, resulting in less waste generated than product used. This accounts for the large discrepancy between the amounts of raw material thinner purchased and the amount of waste thinner generated. In addition to use as a carrier for Automotive Repair Shops Case Study – ME 4171 – 3 – applied paint, paint thinner is also used as a solvent to clean equipment. According to a study conducted by TRW (1979), the total amount of hazardous waste generated by the targeted industry throughout the nation was estimated to be 1.8 million pounds per month (820,000 kilograms per month), with an average generation rate of 77 pounds per month (35 kilograms per month) per generator. This figure, however, also includes wastes generated by the tire retreading and repair shops. Therefore, the generation rate would be somewhat lower, because rubber/tire wastes and toxic fluid wastes would not be included. Waste thinner generation rates from data collected by SCS Engineers (1982) range between 0.8 and 200 gallons per month. Monthly waste generation rates for the audited companies, shown in Table 4-1, range between 5 and 37 gallons per month. TABLE 4-1. MONTHLY HAZARDOUS WASTE GENERATION FOR AUDITED COMPANIES Company No. Employed Business Volume (No. Cars) Thinnet/ Paint Sludge (gal) * Empty Paint Cans Trans. Fluid (gal) Hydraulic Fluid (gal) Anti- Freeze (gal) Oil (gal) A 6 50-75 5 5-7 0 0 0 6 B 13 100 37 5-10 0 0 0 0 C 13 55 20 20-30 2 2 8 7 D 9 30-40 30 25-35 0 0 0 0 E 7 30 17 25-30 0 0 1-2 14 F 3 25 5 25 0 0 0 0 * Thinner/paint sludge also includes additives of hardeners, catalysts, and reducers. Question: 9) If the data in table 4-1 would have been reported by the companies, which company would you send an audit team to check their data? 10) Based on the data given in the table, create a graph and estimate the amount of waste generated by a company that has a business volume of 145 cars. 11) How can you account for the discrepancies in number of paint cans between company B and companies C, D, E, and F. WASTE RECYCLING Excess paint, paint sludge, and thinner mixtures are poured into 55- gallon drums or other containers for storage. The paint sludges and solids settle to the bottom, leaving a liquid layer of thinners on the top. The waste drum is subsequently removed by a hauler to a reclamation or disposal facility. With the exception of one company which reclaims wastes on site, all of the audited companies utilize the services of a reclamation facility for the removal of wastes. This service is part of a turnkey operation provided by the paint and thinner supplier. The purchase of chemicals includes the cost of delivery, waste hauling, recycling, and disposal. The service removes the wastes at the same time that it delivers the new product. The service will remove the supernatant from the waste drum using a pump truck (with sludge removed on a less frequent basis), or will haul the entire drum away. The Automotive Repair Shops Case Study – ME 4171 – 4 – waste is hauled to a licensed treatment, storage, and disposal (TSD) facility for reclamation. The service collects from a number of small-quantity hazardous waste generators in a given area. This renders reclamation economically feasible for this industrial segment. The one company that did not use an off-site treatment service had recently installed on-site recycling equipment for thinnet and paint wastes. Question: 12) Why would the service of a reclamation facility be advantageous for most companies? 13) Can you name some reasons as to why one company would choose to install an on-site recycling equipment? 14) Would you recommend installation of recycling equipment for all companies? 15) Given a 90% recycling efficiency, estimate the residual waste generated by these 6 companies over 10 years? Focus on paint / thinner sludge only. Other studies suggest that the use of recycling in this industry has not been typical in the past. In a study conducted by SCS Engineers (1982) in which all companies in a limited area were contacted, most companies in the automotive paint and body industry were disposing of wastes with conventional refuse, pouring wastes on soil, or allowing wastes to evaporate. Three of the 24 companies surveyed were recycling wastes. However, this practice was limited to waste oils. Question: 16) Can you suggest reasons for this discrepancy between the two studies regarding recycling? WASTE STORAGE The industry uses basically two methods of chemical and hazardous waste storage. In some shops, all of the thinners, new chemicals, and wastes are stored together in a designated covered area. The drums are placed on asphalt, concrete, or steel floors. The remaining shops store their drums indoors, but scatter them around the shop at the points of highest use. In some studies, improper storage and soil contamination have been noted as being indigenous to the automotive painting and body repair business (SCS Engineers, 1982). No evidence of drum storage outdoors or on open soil was observed during the audits. This greatly reduces the potential for accidental or intended soil contamination. While none of the shops visited used drum cradles or stands, all of the companies used some type of spigot or pump as well as lids to reduce product spillage and evaporation. All companies participating in the hazardous waste audit had an average of between two and seven drums containing chemicals and/or hazardous wastes on site. Although most of the contacts interviewed expressed a willingness to operate within industry regulations set by the state, hazardous waste storage ceilings were often ignored or unknown. Most of the smaller operators use waste inventory as a means of determining when to call their recycler. In the smaller shops, however, it often takes up to 6 months to fill a 55-gallon drum with waste thinners and paints. Although a 90-day limit for storage of hazardous wastes is imposed under current hazardous waste regulations, the time period for calculating the 90-day limit for generators of less than 100 kilograms per month begins when 100 kilograms of hazardous waste are accumulated. If more than 100 kilograms are generated in any calendar month, the time period begins when any Automotive Repair Shops Case Study – ME 4171 – 5 – amount of waste begins to accumulate. With the exception of one shop, all audited operations generated less than 100 kilograms of hazardous waste per month. Waste storage for up to or beyond 90 days must meet federal, state, and sometimes local regulations. Question: 17) Name a situation where storage for more than 90 days may be necessary. WASTE DISPOSAL Several studies have cited prevalent disposal practices within the industry. These include waste thinners being discharged into the sewer or disposed of on open ground, and paint cans and filters being disposed of in on-site solid waste dumpsters (SCS Engineers, 1982). During the course of our audits, there was no evidence of large-quantity thinner discharges into the sewer or onto open ground. One shop owner admitted to pouring waste oil along one side of his facility as a means of weed control; however, he discontinued this practice some years ago when the DHS warned him of the associated hazards. Question: 18) What are some of the associated hazards associated with using thinner as weed killer? During the interviews the largest potential for waste disposal mismanagement was found in the handling of paint cans with associated residues, paint equipment filters, oil filters, and small amounts of engine fluids. Almost without exception, the cans and filters were disposed of in on-site refuse dumpsters, to be removed during weekly municipal waste collections. When small amounts of engine fluid were generated, they were allowed to drain onto the floor. These include anti-freeze from damaged radiators, brake fluids, transmission fluids, etc. The residues were then either absorbed with a type of floor drying agent which was subsequently disposed of in the dumpster, or rinsed down drains or sewers without prior treatment during routine washdowns. Due predominantly to economic reasons and ease of operation, none of the establishments visited used landfills for disposal of waste paint, thinner, and reducer. All of the audited facilities utilized waste recycling, as discussed earlier. Question: 19) What are some economic reasons for not using a landfill for disposing paint, thinner and reducer? 20) Can you name some other reasons? 21) Would burning the thinner and oil for, say, shop heating be a good idea? WASTE MANAGEMENT In a previous study done by SCS Engineers (1982) as part of a small-quantity hazardous waste generator study, data were gathered from the auto body industry to determine the amount of money that individual companies would budget for hazardous waste management. At the time of the 1982 study, no company was spending in excess of 0 to 5 percent of its budget on hazardous waste management. Although most expressed the desire to avoid penalties associated with hazardous waste storage and removal, few were willing to absorb the extra costs involved. Our interviews showed that most operators thought the laws governing their industry to be confusing and ambiguous. It Automotive Repair Shops Case Study – ME 4171 – 6 – was the consensus of the operators that regulatory language needs to be simplified, and that industry updates should be distributed on an annual basis. Questions: 22) What would it take to distribute updates on an annual basis? 23) Can you give suggestions to simplify the language? CLOSING QUESTIONS: 24) In the preceding text, which major waste stream was more or less neglected? 25) What are some incentives for waste reduction? 26) What are categories and options for waste reduction? 27) Consider the situation in Atlanta. Make an assessment of the amount of waste generated until the year 2000 by automotive repair shops in the Atlanta area. First, try to perform such an assessment without making any phone calls. Next, try to verify your findings. 28) As a “sustainable solution”, would it be feasible to group repair shops together in “Car Health Maintenance Organizations” analogous to medical HMOs? Automotive Repair Shops Case Study – ME 4171 – 7 – Appendix A Synopsis of the Small Quantity Generators Regulations Facilities producing between 220 and 2200 pounds (100 and 1000 kilograms) of hazardous wastes per month are subject to the Small Quantity Generator regulations. These regulations will require waste producing facility to: 1) Identify the hazardous wastes produced. 2) Obtain an EPA identification number. 3) Ship hazardous wastes for treatment, storage, or disposal in EPA approved facilities. The shipment will have to meet the requirements set by the Federal Department of Transportation for hazardous wastes. In addition the shipment will have to be accompanied by a manifest containing the generator's name and address, the shippers name, and the name and address of the receiving facility. 4) The hazardous wastes should be offered, at least every 180 days, to shippers and disposal facilities with an EPA identification number. In Alaska, because there are no EPA certified hazardous waste disposal sites within 200 miles, the wastes can be stored for 270 days. The maximum weight of the wastes being stored, however, cannot exceed 13,200 pounds. 5) Finally, the waste generator should keep a copy of the shipping manifest for three years. Automotive Repair Shops Case Study – ME 4171 – 8 – APPENDIX B – LIABILITY ISSUES The following text highlights liability issues, regulations, and two actual cases. It provides a quick summary and introduction to the legislation involved. It is taken from “Managing and Recycling Solvents – North Carolina Practices, Facilities, and Regulations”, by Jerome Kohl, Phillip Moses, and Brooke Triplett, Industrial Extension Service, School of Engineering, North Carolina State University, Raleigh, North Carolina, December 1984. Liability 1. Superfund The Superfund law of December 1980 - CERCLA - authorizes the Federal Government (through the EPA) to respond directly to releases (or threatened releases) of hazardous substances and pollutants or contaminants that may endanger public health or welfare. Costs are to be covered by a more than $7.6 billion fund, 86% of which is financed by taxes on the manufacture or import of certain chemicals and petroleum, the remainder coming from general revenues (as of October 1, 1984, this act is up for extension with the provision of additional funds). This fund is reimbursable: the EPA takes legal action to recover its cleanup costs from those subsequently identified as responsible for the release. Anyone liable for a release who fails to take ordered action is (under specified conditions) liable for punitive damages equal to 3 times the government's response costs. EPA's enforcement effort seeks to ensure that responsible, private parties finance cleanup actions when possible. Direct government action, when called for, can take the following forms: - Immediate removals, when a prompt response is needed to prevent harm to public health, welfare or the environment. - Planned removals, when an expedited, but not necessarily immediate, response is needed to minimize increases in danger or exposure that would otherwise occur, if response were delayed. - Remedial actions, which are longer-term and usually more expensive, aimed at permanent remedies. Remedial actions may be taken only at sites which are indicated on EPA's National Priorities List. Sites on the National Priorities List were ranked by the MITRE Corporation. The ranking is based on 3 things: the toxicity of the substance involved, the closeness of the site to humans, and the possible pathways of the substance into the environment (such as soil, water and air). The present list ranks over 400 sites nationwide. 2. Summary of Generator Liability a. RCRA Under RCRA's "cradle to grave" philosophy a generator is never relieved of responsibility for his hazardous waste. If a treater, storer, disposer (TSD), or transporter spills hazardous wastes, or if hazardous wastes are released into the environment (leaks, leaching, etc.) then the generator can be held liable for any damages and cleanup costs that the TSD or transporter cannot pay. The generator does not have to be proven negligent in order to be held liable for his hazardous wastes. This is called Strict Liability "liability without fault". b. Joint and Several Liability Under Superfund Automotive Repair Shops Case Study – ME 4171 – 9 – If hazardous wastes are released into the environment from a TSD site then all the generators who have used that site are "jointly and severally" liable for the cleanup costs and resultant damages that the TSD facility cannot pay. This means that if a generator has contributed only a small amount of wastes to a facility where a cleanup is needed, that generator can be forced to pay for a much larger part of the mess than his particular wastes were responsible for. In some cases, he can be held responsible for all of the mess. Thus, even if ~ generator sends only a small amount of hazardous wastes off-site, he must be very prudent in choosing a TSD facility since the generator may be held liable for the TSD's mistakes. Presently, legal courts are moving toward applying "apportionment" procedures to this problem but for now, the above holds true. 3. Multiple Generator Sites At Superfund sites where multiple generators have been named by the EPA as having contributed hazardous wastes to the site (potentially responsible parties), the agency has so far pursued the following line of action. a. If the owner/operator of the facility does not agree to clean up the site, or if immediate removal of wastes is required and there is no time to identify the responsible parties, the EPA cleans up the site. After the cleanup is completed, the EPA sues the owners, operators and generators for cleanup, administration and court costs. b. The EPA can order the owners or operators of a facility to perform an immediate removal of hazardous substances because of imminent danger to public health, welfare or the environment. If the facility fails to clean itself up without "good cause" as an excuse, then the EPA removes the hazardous substances and sues the responsible parties (which may include the generators as well as the owner/operator of the facility) for punitive damages equal to three times the cost of EPA's response. Examples of EPA cleanups under Superfund in the southeast and cost recovery from generators are: Lenoir Refining Lenoir Refining Company was located in Lenoir, North Carolina. The facility occupied three acres of land and consisted of a small office, a warehouse, a drum storage area and a third building housing solvent distillation equipment. Lenoir Refining Company would pick up spent solvent from local furniture manufacturers to be distilled and returned to the manufacturers. The spent solvent backlog and still bottoms were drummed and stored in an outdoor uncovered area. Over the years, a backlog of an estimated 750-1000 drums accumulated on the site. Many of the drums were uncovered or deteriorating and leaking. Few had labels "identifying contents and fumes from the drums were detectable within several yards of the site. The risk of fire, explosion, flooding, and the lack of site security were the major hazards posed by the site. The population within a 1/2-mile radius of the site is approximately 12,000. The site is located on a flood plain. On several occasions, it has been flooded, threatening to wash the drums of solvent and contamination from the soil into a nearby creek and eventually into the Catawba River which is used for recreational purposes and as a drinking water supply for many communities. Despite its hazards, the site was freely accessible to the public with no fence, no warning signs posted and no natural barriers inhibiting access to the site. The organic solvents present on-site were acetone, benzene, ethyl benzene, methyl ethyl ketone, toluene and isopropyl acetate. On October 14, 1982, the EPA began a planned removal action at the Lenoir Refining Company site. A total of 1,301 drums and 160 cubic yards of contaminated soil were removed from the site at a cost of $92,189.54. The EPA Automotive Repair Shops Case Study – ME 4171 – 10 – can charge up to three times the cost of cleanup. After the cleanup was completed, the EPA recovered a total of $113,000.00 from the seven responsible parties: Lenoir Refining Company, Broyhill Manufacturing Company, C.T.S. of Asheville, Ethan Allen, Inc., Lackawanna Leather Company, Southern Cabinet Company, Inc., and Sperry and Hutchinson Furniture, Inc. Bluff Roads The "Bluff Roads" site is near Columbia, South Carolina. The site covers approximately four acres and is within 1/2 mile of a large plant employing more than 800 people around the clock. The topsoil at the Bluff Road site is sandy and quite permeable. The water table is only five feet below the surface. The area is characterized by marshland, creeks and waterways contiguous with the site. From 1974 until 1980, Columbia Organic Chemical Company operated a solvent and industrial waste recycling facility at Bluff Road. In 1980, South Carolina Recycling and Disposal, Inc. (which had also been operating a recycling facility on the site since 1976) took over the site completely and Columbia Organic Chemical Company removed its chemicals and moved off the site. Before the EPA started cleaning up, approximately 7500 drums of volatile organic chemical wastes and other hazardous substances were on the site. Some drums were leaking or uncovered emitting toxic fumes and causing spillage and soil contamination. A large number of drums were stacked tightly together, as many as three high, and few had pallets to protect them from the ground. Solvents stored at the site included xylene, toluene, ethyl ether, isopropyl alcohol, acetone, methyl acetate, benzene, trichloroethylene, carbon tetrachloride, and perchloroethylene. In October, 1977, heavy rainfall caused a chemical reaction with wastes stored in decomposing drums forming a cloud of toxic gases. Fifty people were hospitalized for exposure to these gases. Two fires have broken out at the site; one in 1979 and one in 1982. In 1982, the EPA charged the owners of the site and a group of companies as being liable for the cost of the site cleanup which the EPA estimated at $1,6000,000. RAD Services, a hazardous waste transporter, and twelve other unnamed companies agreed to pay for 75% of the surface cleanup (the fraction of problem wastes attributed to private industry). Seventy-five percent of EPA's cost estimate is $1,200,000, but since RTI performed the cleanup for the companies, the exact cost was not disclosed. The EPA, then funded by the responsible governmental agencies, completed the rest of the surface cleanup. The Eaton Corporation also agreed to pay the EPA $95,000.00 for surface cleanup costs. According to the resulting agreements, if a groundwater cleanup is found to be necessary, the EPA will try to recover the cleanup cost from the other companies named in the suit before trying to recover costs from Eaton, RAD or the twelve unnamed companies. This case has not yet been closed, so no figures have been published. However, if past groundwater cleanups are any indication of what the Bluff Roads site would require, one could guess that, if the court rules in favor of EPA, Monsanto, Allied and EM Corporation could be forced to pay substantially more than have Eaton, RAD and the twelve unnamed companies. . Automotive Repair Shops Case Study – ME 4171 – 1 – Automotive Repair Shops In the following, you will be given. regarding the waste generated by automotive repair shops in California. A lot of you will have had experience with automotive body repair, or at least know somebody