Top 10 Lessons Learned from
Dealership EPA Inspections
Speakers
Moderator Presenter
Chuck Elliott
SE District Manager
404-626-6310
celliott@kpaonline.com
Becky Ross
Marketing Ma...
Questions
• If you have questions during
the presentation, please
submit them using the
“Questions” feature
• Questions wi...
Top 10 Lessons Learned
from Recent Dealership
EPA Inspections
Chuck Elliott, CHMM
KPA SE District Manager
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
10
• Most States will not let
you put Undeployed
Airbags in the Trash
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
9
• Most States will not
allow you to Deploy
Airbags.
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
So what are my airbag disposal options?
Reuse Them
Dispose of Them as Ha...
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
Key Points:
You can’t throw undeployed airbags in the trash.
You can’t d...
Top Ten Things I Learned from an EPA Inspection
8
• HW Containers must be
Closed at all times.
Top Ten Things I Learned from an EPA Inspection
1. Open Containers Lead to more
Frequent and Larger Spills
2. Open Contain...
Top Ten Things I Learned from an EPA Inspection
Are these Containers “Closed”?
“The chosen lids were found incapable of se...
Top Ten Things I Learned from an EPA Inspection
7
• Educate your Staff about
what items cannot be put
in the Trash
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
6
• ALL Containers MUST
be Labeled
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
5
• Know where your
Compliance Plans are
Located.
Top Ten Things I Learned from an EPA Inspection
The Inspector You?
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
4
• Know how to Manage
Waste Shipments
Paperwork
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
Hazardous Waste Manifests
Fill them out completely and accurately
Ensure...
Top Ten Things I Learned from an EPA Inspection
3
• Make sure you are using
the correct EPA
Hazardous Waste ID#
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
EPA Hazardous Waste Generator ID #
Are assigned to an ADDRESS, not to a b...
Top Ten Things I Learned from an EPA Inspection
EPA Hazardous Waste Generator ID #
Are assigned to an ADDRESS, not to a b...
Top Ten Things I Learned from an EPA Inspection
How do I know if I have an EPA Hazardous Waste
Generator ID#?
1. Check you...
Top Ten Things I Learned from an EPA Inspection
http://www.epa.gov/enviro/facts/rcrainfo/search.html
Top Ten Things I Learned from an EPA Inspection
How do I know if I need an EPA
Hazardous Waste Generator ID#?
You need an ...
Top Ten Things I Learned from an EPA Inspection
2
• Know (and Understand)
your EPA Hazardous
Waste Generator Status
Top Ten Things I Learned from an EPA Inspection
Know (and Understand) your EPA Hazardous
Waste Generator Status
Conditiona...
Top Ten Things I Learned from an EPA Inspection
Out of Control
Way Too Much
Too Much
Just About Right
CESQG
SQG
LQG
EPA Pr...
Top Ten Things I Learned from an EPA Inspection
1
• When Regulators show
up contact your KPA
Engineer Immediately!
Top Ten Things I Learned from an EPA Inspection
Top Ten Things I Learned from an EPA Inspection
1 • When Regulators show up contact your KPA Engineer Immediately!
2 • Kno...
Questions and Answers
– KPA CONFIDENTIAL –
QUESTIONS?
Contact Information
– KPA CONFIDENTIAL –
The recorded webinar and presentation slides
will be emailed to you today.
www.kp...
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Top 10 Lessons Learned from Dealership EPA Inspections

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Top 10 Lessons Learned from Dealership EPA Inspections

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  • The EPA is headquartered in Washington DC, but they have 10 large regional offices throughout the United States. Recently in the SE region we have had some hazardous waste inspectors from the Atlanta regional office visit some of our dealerships. After going through this process we have learned some things that will be very useful for our clients and other dealerships to know, not just in the SE, but these would typically apply to all of the regions. Lets look at what we have to share now…
  • #10Most States will not let you put undeployed airbags in the trash.Many states have their own rules or guidance about airbags, but these often conflict with what the EPA is actually enforcing.
  • Previously people thought the airbags were hazardous waste because of the sodium azide used as a propellant. Most airbags manufacturers stop using sodium azide in their airbags, but now the EPA is currently claiming that undeployed airbags are hazardous waste because they have the characteristic of being a reactive material.
  • So if you remove an undeployed airbag from a vehicle, what are you supposed to do with it? The OEMs will sell you a kit that you can use to deploy the airbag yourself, with the assumption that once it is deployed, it is no longer hazardous and can be thrown in the trash. This is the logic that most of the dealerships throughout the country are using, unfortunately the EPA has a problem with this idea also. And that takes us to our next issue…
  • #9Most states (and the EPA) will not allow you to deploy airbags yourself. They consider that hazardous waste treatment, and you must have a permit for that.
  • So I should just get a permit, right? No, the facilities that have hazardous waste treatment permits look like this and the permits are very complicated and not intended for a automotive dealership.
  • So what options does that leave you? Reuse ThemDispose of Them as Hazardous WA$TERecycle Them
  • KPA has recently set up an airbag recycling program for our clients. Other options are to contact your current hazardous waste vendor or consultant about options they can provide for you.
  • So Remember these key points:You can’t throw undeployed airbags in the trash.You can’t deploy the airbags yourself.Contact your KPA engineer or your dealership’s consultant for state specific guidance and assistance. Let’s look at our next issue…
  • #8Hazardous Waste containers must be kept closed at all times.
  • All HW containers must be kept closed at all times unless you are in the process of actually adding waste. There are 2 main concerns here:One is that open containers usually lead to more frequent and larger spills. Two is that the fumes coming off of hazardous waste are usually hazardous to your health and the health of your coworkers.
  • Another key point to consider here is what does the EPA mean by closed? So let’s look at these pictures here and try to decide if the containers are closed. In the first 2 pictures the EPA inspector is holding the funnel lid open, so obviously it is not closed. But the point that the inspector was trying to make is that if you have a bunch of waste around the rim of a funnel, you are not going to get a good seal and they will not consider that a closed container. We have learned recently that the EPA goes beyond what their regulations say on this issue. The third picture has a funnel with a latch for the lid. The EPA also claims that this is an open container whenever that latch is not being used. So just remember to keep these containers completely closed at all times…lets move on to #7…
  • #7Educate your staff about what items can and cannot be thrown in the ordinary trash.
  • #7If the EPA audits your dealership, any good inspector will put on a pair of gloves and start digging through your trash. Not just your trash cans but possibly your dumpster out back. Any kind of dried spills on your dumpster or trash cans will indicate to the inspector that you probably have been throwing potentially hazardous wastes into these containers, so try to keep them clean and get some new containers if they look too bad.
  • What you can and can’t throw in the trash is going to vary depending on where you live, so it is best to contact your KPA Engineer or your dealership’s consultant about what the local rules are. That being said here a couple of more things to keep in mind…
  • Don’t put liquids, gels or pastes in the trash, these items will catch the EPA’s attention right away. Use these products up completely, leave absolutely nothing left in the container and then it is usually safe to throw the empty container away. Aerosol cans in particular must be empty. The inspector usually pulls these out of the trash and attempts to spray them. If anything comes out, product or even just some remaining propellant, the EPA will almost always issue you a violation for this. Enough about your trash…let’s move on to issue #6.
  • #6All containers must be labeled. This one is a lot easier said than done.
  • This is especially true of used oil containers and unlabeled drums. The EPA like to focus in on these. Many states specifically say that used oil containers must be labeled “USED OIL” – mislabeling it as “waste oil” or “recycled oil” often results in the EPA issuing a violation.
  • #5Know where your compliance plans and documents are located.
  • The EPA or OSHA or any other inspector is probably going to ask for them, so you don’t want to look like you have no idea what they are talking about.
  • An EPA inspector is typically going to be looking for waste disposal documentation, required training documents and any written plans required for your specific location and situation, such as a Spill Prevention Plan or an Emergency Contingency Plan. There are several similar OSHA documents and plans that you need to be able to locate, and they are also kept in the same locations for KPA clients.
  • If you are a KPA client, most of these documents will be located in your Yellow Box. Most of your written plans are located in the Yellow KPA Binders and recently, KPA has begun uploading many of these documents and required plans to our client’s mykpaonline.com documents folder for quick access as needed. Lets move on to issue #4…
  • #4Know how to manage your waste shipments’ paperwork.
  • Not only is it important to know where the paperwork is, it is just as important that you know how to manage it.
  • The most important part of this paperwork is your hazardous waste manifests.
  • When you ship off a load of hazardous waste the transporter leaves you a copy of the manifest at the dealership. When the shipment reaches the disposal facility, the transporter gets the disposal facility to sign the manifest and then this facility is supposed to mail a copy of the manifest back to the dealership to acknowledge that your shipment has been received.
  • It is very important that you match up both copies of your manifest. If you are never getting these back, it probably means that they are being sent to the accounting department along with the invoice. Be sure to let them know you need to have these copies for your records. If you don’t get anything from the disposal facility, you need to contact them prior to 45 days from the shipment. After 45 days you need to report it to your state’s environmental compliance program. Also let your waste vendor know you want to ship you waste off by pounds, not gallons. The reason for this is that if you ship by the gallon they are going to report it by the size of the container. If your containers are not full, this will exaggerate the amount of waste you are actually generating. We will see why this can be a problem shortly, let’s move on to issue #3…
  • #3Make sure you are using the correct EPA Hazardous Waste ID#
  • Using the wrong ID# on your manifest would be like filling out your tax return with the wrong social security #. That is pretty straight forward, just make sure you put the correct # in the highlighted box you see here.
  • A couple of other things about your EPA Hazardous Waste Generator ID # that you should be aware of… (read slide)
  • I am sure these points probably made many of you think of a few important questions, like:How do I know if I have a #?How do I know if I need a #?
  • Let’s look at the first question…(read slide)
  • This is the website you want to go to and search for your facility by their ID# or by the address. It is not the most user-friendly website, so if you don’t find it right away keep trying.Now onto the second question…
  • How do I know if I need an EPA Hazardous Waste Generator ID#?That is a really tough question. The simplest answer is that if you generate more than 220 lbs/month of HW, you need to have an ID#.But this is the EPA, so it can’t just be that simple. Let’s look at this in more detail…which brings us to issue #2…
  • #2Know and Understand what your EPA Hazardous Waste Status is.This can get a little tricky…but we are almost done, so lets just jump right into it.
  • The EPA classifies HW generators into 1 of 3 levels based on the amount of HW they generator in a month.Let’s look at these different levels…(review slide)Ideally you want to be a CESQG, let’s look at the reasoning behind that…
  • The #1 thing we have learned from some recent inspections…When a regulator shows up at your facility call your KPA Engineer immediately!Tell the inspector you will be right with them, then call your KPA Engineer for guidance.
  • The KPA Engineer will try to come to your facility right away if possible. If they are too far away they can walk you through the inspection and help you answer the EPA’s or any other inspectors questions. Just as important they can warn you what not to say…Use your cell phone, program your KPA Engineer’s # in there, and ask them for a backup # of their supervisor in case you can’t get them right away.Keep in mind that all of this presentation is based on the Federal EPA regulations, your state my have some more specific requirements that you need to be aware of – your local KPA Engineer is going to be the best source for that information.
  • Top 10 Lessons Learned from Dealership EPA Inspections

    1. 1. Top 10 Lessons Learned from Dealership EPA Inspections
    2. 2. Speakers Moderator Presenter Chuck Elliott SE District Manager 404-626-6310 celliott@kpaonline.com Becky Ross Marketing Manager 303-228-8753 bross@kpaonline.com
    3. 3. Questions • If you have questions during the presentation, please submit them using the “Questions” feature • Questions will be answered at the end of the webinar
    4. 4. Top 10 Lessons Learned from Recent Dealership EPA Inspections Chuck Elliott, CHMM KPA SE District Manager
    5. 5. Top Ten Things I Learned from an EPA Inspection
    6. 6. Top Ten Things I Learned from an EPA Inspection 10 • Most States will not let you put Undeployed Airbags in the Trash
    7. 7. Top Ten Things I Learned from an EPA Inspection
    8. 8. Top Ten Things I Learned from an EPA Inspection
    9. 9. Top Ten Things I Learned from an EPA Inspection 9 • Most States will not allow you to Deploy Airbags.
    10. 10. Top Ten Things I Learned from an EPA Inspection
    11. 11. Top Ten Things I Learned from an EPA Inspection So what are my airbag disposal options? Reuse Them Dispose of Them as Hazardous WA$TE Recycle Them
    12. 12. Top Ten Things I Learned from an EPA Inspection
    13. 13. Top Ten Things I Learned from an EPA Inspection Key Points: You can’t throw undeployed airbags in the trash. You can’t deploy the airbags yourself. Contact your KPA Engineer or your dealership’s consultant for state specific guidance and assistance.
    14. 14. Top Ten Things I Learned from an EPA Inspection 8 • HW Containers must be Closed at all times.
    15. 15. Top Ten Things I Learned from an EPA Inspection 1. Open Containers Lead to more Frequent and Larger Spills 2. Open Containers release Hazardous Pollutants into the Air
    16. 16. Top Ten Things I Learned from an EPA Inspection Are these Containers “Closed”? “The chosen lids were found incapable of sealing to prevent spillage when tipped.” – quote from the EPA
    17. 17. Top Ten Things I Learned from an EPA Inspection 7 • Educate your Staff about what items cannot be put in the Trash
    18. 18. Top Ten Things I Learned from an EPA Inspection
    19. 19. Top Ten Things I Learned from an EPA Inspection
    20. 20. Top Ten Things I Learned from an EPA Inspection
    21. 21. Top Ten Things I Learned from an EPA Inspection 6 • ALL Containers MUST be Labeled
    22. 22. Top Ten Things I Learned from an EPA Inspection
    23. 23. Top Ten Things I Learned from an EPA Inspection 5 • Know where your Compliance Plans are Located.
    24. 24. Top Ten Things I Learned from an EPA Inspection The Inspector You?
    25. 25. Top Ten Things I Learned from an EPA Inspection
    26. 26. Top Ten Things I Learned from an EPA Inspection
    27. 27. Top Ten Things I Learned from an EPA Inspection 4 • Know how to Manage Waste Shipments Paperwork
    28. 28. Top Ten Things I Learned from an EPA Inspection
    29. 29. Top Ten Things I Learned from an EPA Inspection
    30. 30. Top Ten Things I Learned from an EPA Inspection
    31. 31. Top Ten Things I Learned from an EPA Inspection Hazardous Waste Manifests Fill them out completely and accurately Ensure you match up the original and final copies If you don’t get the final copy back within 30 days contact the facility You must contact the state agency if you still do not have it after 45 days Use pounds instead of gallons to measure the amounts of waste shipped
    32. 32. Top Ten Things I Learned from an EPA Inspection 3 • Make sure you are using the correct EPA Hazardous Waste ID#
    33. 33. Top Ten Things I Learned from an EPA Inspection
    34. 34. Top Ten Things I Learned from an EPA Inspection EPA Hazardous Waste Generator ID # Are assigned to an ADDRESS, not to a business. If you move to a new location, they will need a new #. Most dealerships will not be Required to have a # A dealership with a collision center may need one.
    35. 35. Top Ten Things I Learned from an EPA Inspection EPA Hazardous Waste Generator ID # Are assigned to an ADDRESS, not to a business. If you move to a new location, they will need a new #. Most dealerships will not be Required to have a # A dealership with a collision center may need one. 1.How do I know if I have a #? 2.How do I know if I need a #?
    36. 36. Top Ten Things I Learned from an EPA Inspection How do I know if I have an EPA Hazardous Waste Generator ID#? 1. Check your old manifest for an ID# 2. Go online to the EPA’s website and: a) Verify the # from your manifest is listed to your facility at your current address b) Do a search for your address
    37. 37. Top Ten Things I Learned from an EPA Inspection http://www.epa.gov/enviro/facts/rcrainfo/search.html
    38. 38. Top Ten Things I Learned from an EPA Inspection How do I know if I need an EPA Hazardous Waste Generator ID#? You need an ID # if you Generate >220 lb/month (1/2 drum) of HW
    39. 39. Top Ten Things I Learned from an EPA Inspection 2 • Know (and Understand) your EPA Hazardous Waste Generator Status
    40. 40. Top Ten Things I Learned from an EPA Inspection Know (and Understand) your EPA Hazardous Waste Generator Status Conditionally Exempt Small Quantity Generator • Generates less than 220 lbs/month (~ 1/2 drum) • This is where you want to be. Small Quantity Generator • Generates 220 lb -2200 lb/month (1/2 drum - 5 drums) • Not the best place for a dealership to be. Large Quantity Generator • Generates greater than 2200 lb/month (5 drums) • The EPA is probably knocking on your front door right now (quick – hide under your desk!)
    41. 41. Top Ten Things I Learned from an EPA Inspection Out of Control Way Too Much Too Much Just About Right CESQG SQG LQG EPA Pressure / Regulatory Requirements
    42. 42. Top Ten Things I Learned from an EPA Inspection 1 • When Regulators show up contact your KPA Engineer Immediately!
    43. 43. Top Ten Things I Learned from an EPA Inspection
    44. 44. Top Ten Things I Learned from an EPA Inspection 1 • When Regulators show up contact your KPA Engineer Immediately! 2 • Know your EPA Hazardous Waste Generator Status 3 • Make sure you are using the correct EPA Hazardous Waste ID# 4 • Know how to Manage Waste Shipment Paperwork 5 • Know where your Compliance Plans are Located. 6 • ALL Containers must be Labeled 7 • Educate your Staff about what items can not be put in the Trash 8 • HW Containers must be Closed at all times. 9 • Most States will not allow you to Deploy Airbags. 10 • Most States will not let you put Undeployed Airbags in the Trash
    45. 45. Questions and Answers – KPA CONFIDENTIAL – QUESTIONS?
    46. 46. Contact Information – KPA CONFIDENTIAL – The recorded webinar and presentation slides will be emailed to you today. www.kpaonline.com bross@kpaonline.com 866-356-1735
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