FACT SHEET
Tips for Managing Hazardous Waste in Radiator Repair Shops
PURPOSE
Radiator Repair Shops commonly generate haz-ardous
waste, such as lead. This guide is intended to
help radiator repair shops stay in compliance with
hazardous waste regulations and provides recom-mendations
to reduce hazardous waste contamina-tion
caused by repair shops. In turn, the proper man-agement
of hazardous waste may help repair shops
save money through more innovative ways to reduce
and/or recycle the waste generated and prevent the
assessment of fines that could result from improper
management. This guide is not intended to be used as
a substitute for the actual regulations.
WHAT IS HAZARDOUS WASTE AND WHY IS
IT REGULATED?
Hazardous waste has properties that make it dan-gerous
or capable of having a harmful effect on human
health or the environment. Determining what is a
hazardous waste, whether your radiator shop gener-ates
it, and how much is generated is fundamental.
Hazardous waste exists in many forms, including
liquids, solids, gases and sludges. The most common
waste generated by radiator repair shops is lead. A
generator determines whether a substance is a haz-ardous
waste by running tests or using knowledge of
the processes that generate the waste. For more
information on how to determine if your shop generates
hazardous waste, consult the RCRA Code of Federal
Regulations Web site at: http://www.gpoaccess.gov/
nara/index.html or www.ccar-greenlink.org.
WHAT IS RCRA?
RCRA is the Resource Conservation and Recovery
Act. Its primary goals are to protect human health and
the environment from the potential hazards of waste
disposal, to conserve energy and natural resources, to
reduce the amount of waste generated, and to ensure
that wastes are managed in an environmentally sound
manner. The federal regulations relating to hazardous
waste management may be found in Title 40 of the
Code of Federal Regulations (CFR).
Classification of Generators
Once a radiator shop has determined that it generates hazardous waste, it must determine its classification as a generator:
Conditionally Exempt Small
Quantity Generator (CESQG)
• Generate no more than 220
lb.of waste in any calendar
month
• Accumulate no more than
2,200 lb. of waste onsite at
any time
• Waste must be delivered to a
permitted off-site treatment
and/or disposal facility
Small Quantity Generator
(SQG)
• Generate between 220
and 2,200 lb. of waste in
any calendar month
• Accumulate no more than
13,328 lb. of waste onsite at
any time
• If one-half to five 55-gallon
containers of hazardous waste
are generated each month
• Waste must be delivered to a
permitted off-site treatment
and/or disposal facility
Large Quantity Generator
(LQG)
• Generate more than 2,200 lb.
of hazardous waste in any
calendar month
• Five or more 55-gallon
containers of hazardous waste
generated in any calendar
month
• Waste must be delivered to a
permitted off-site treatment
and/or disposal facility
ADDITIONAL INFORMATION
For more information regarding managing hazardous
waste in radiator shops, please contact:
ADEQ Inspections and Compliance Section
1110 West Washington Street
Phoenix, Arizona 85007
(602) 771-4673 or
toll free at (800) 234-5677 Ext. 771-4673
Hearing impaired persons call
ADEQ's TDD line: (602) 771-4829
Also see Managing Hazardous Waste - A Handbook for
Small Business, www.azdeq.gov/environ/waste/
hazwaste/download/managehw.pdf.
Do’s and Don’ts for Radiator Shops
DO DON’T
• Use lead-free solder
• Learn which wastes are generated from your
radiator shop
• Install drip pans throughout the shop
• Use propylene glycol antifreeze instead of
ethylene glycol antifreeze
• Mark containers of old antifreeze with “waste
antifreeze” and “toxic”
• Use a high-pressure, low-flow water spray
system for the flushing booth
• Collect/reuse rinse water for the boil-out tank
• Recycle solder drippings
• Solder in a place that allows for catching drips
before they fall into the tank
• Use only minimum required chemicals for the
processes
• Close all containers holding hazardous waste
during storage
• Date and label each container with the words
“Hazardous Waste”
• Allow for aisle space in hazardous waste
storage area
• Have proper equipment and communication
systems in the hazardous waste storage area
• Inspect storage area weekly
• Ship and manifest all hazardous waste using a
licensed hazardous waste transporter
• Allow sludge to dry in open containers
• Discard antifreeze or any waste into the land,
septic systems, storm drains, drywell or surface
water without proper permitting
• Throw contaminated rags, gloves or towels in
the trash
• Throw floor sweep into the trash
• Use an electric band on containers holding
sludge
• Use thermal treatment (heat) of any kind to
dry sludge
• Use a tank to dry sludge unless the tank meets
all of the CFR tank regulations for your generator
class
• Dispose of glass bead dust, chips, metal
shavings, or dust residue unless certain it is
determined not a hazardous waste
• Mix used oil with any other waste. The waste
should be kept separate from the oil
• Store containers of liquid hazardous waste
outdoors unless they are closed and placed on
a paved and waterproof surface
Publication Number: FS 06-17
Although CESQGs are not required to perform some of the above, it is strongly recommended.
