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Top 10 Lessons Learned from Dealership EPA Inspections
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Top 10 Lessons Learned from Dealership EPA Inspections
Speakers
Moderator Presenter
Chuck ElliottSE District Manager
404-626-6310celliott@kpaonline.com
Becky RossMarketing Manager
303-228-8753bross@kpaonline.com
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
Top 10 Lessons Learned from Recent Dealership
EPA Inspections
Chuck Elliott, CHMMKPA 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 ThemDispose of Them as Hazardous WA$TERecycle Them
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 deploy the airbags yourself.Contact your KPA Engineer or your dealership’s consultant for state specific guidance and assistance.
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 Containers release Hazardous Pollutants into the Air
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
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 ManifestsFill them out completely and accuratelyEnsure you match up the original and final copiesIf you don’t get the final copy back within 30 days contact the facilityYou must contact the state agency if you still do not have it after 45 daysUse pounds instead of gallons to measure the amounts of waste shipped
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 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.
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 #?
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
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 ID # if you Generate
>220 lb/month (1/2 drum) of HW
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
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!)
Top Ten Things I Learned from an EPA Inspection
Out of Control
Way Too Much
Too Much
Just About Right
CESQGSQG
LQG
EPA Pressure / Regulatory Requirements
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
•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
Questions and Answers
– KPA CONFIDENTIAL –
QUESTIONS?
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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