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Top 10 Lessons Learned from Dealership EPA Inspections

Date post: 17-Nov-2014
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Top 10 Lessons Learned from Dealership EPA Inspections
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Top 10 Lessons Learned from Dealership EPA Inspections
Transcript
Page 1: Top 10 Lessons Learned from Dealership EPA Inspections

Top 10 Lessons Learned from Dealership EPA Inspections

Page 2: Top 10 Lessons Learned from Dealership EPA Inspections

Speakers

Moderator Presenter

Chuck ElliottSE District Manager

[email protected]

Becky RossMarketing Manager

[email protected]

Page 3: Top 10 Lessons Learned from Dealership EPA Inspections

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

Page 4: Top 10 Lessons Learned from Dealership EPA Inspections

Top 10 Lessons Learned from Recent Dealership

EPA Inspections

Chuck Elliott, CHMMKPA SE District Manager

Page 5: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 6: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

10 •Most States will not let you put Undeployed

Airbags in the Trash

Page 7: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 8: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 9: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

9 •Most States will not allow you to Deploy Airbags.

Page 10: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 11: Top 10 Lessons Learned from Dealership EPA Inspections

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

Page 12: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 13: Top 10 Lessons Learned from Dealership EPA Inspections

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.

Page 14: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

8 •HW Containers must be Closed

at all times.

Page 15: Top 10 Lessons Learned from Dealership EPA Inspections

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

Page 16: Top 10 Lessons Learned from Dealership EPA Inspections

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

Page 17: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

7 •Educate your Staff about what items cannot be put in the Trash

Page 18: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 19: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 20: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 21: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

6 •ALL Containers MUST be Labeled

Page 22: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 23: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

5 •Know where your

Compliance Plans are Located.

Page 24: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

The Inspector You?

Page 25: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 26: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 27: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

4 •Know how to Manage Waste

Shipments Paperwork

Page 28: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 29: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 30: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 31: Top 10 Lessons Learned from Dealership EPA Inspections

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

Page 32: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

3 •Make sure you are using the correct EPA Hazardous Waste ID#

Page 33: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 34: Top 10 Lessons Learned from Dealership EPA Inspections

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.

Page 35: Top 10 Lessons Learned from Dealership EPA Inspections

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 #?

Page 36: Top 10 Lessons Learned from Dealership EPA Inspections

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

Page 37: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

http://www.epa.gov/enviro/facts/rcrainfo/search.html

Page 38: Top 10 Lessons Learned from Dealership EPA Inspections

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

Page 39: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

2•Know (and Understand)

your EPA Hazardous

Waste Generator

Status

Page 40: Top 10 Lessons Learned from Dealership EPA Inspections

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!)

Page 41: Top 10 Lessons Learned from Dealership EPA Inspections

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

Page 42: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

1•When

Regulators show up contact

your KPA Engineer

Immediately!

Page 43: Top 10 Lessons Learned from Dealership EPA Inspections

Top Ten Things I Learned from an EPA Inspection

Page 44: Top 10 Lessons Learned from Dealership EPA Inspections

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

Page 45: Top 10 Lessons Learned from Dealership EPA Inspections

Questions and Answers

– KPA CONFIDENTIAL –

QUESTIONS?

Page 46: Top 10 Lessons Learned from Dealership EPA Inspections

Contact Information

– KPA CONFIDENTIAL –

The recorded webinar and presentation slides will be emailed to you today.

www.kpaonline.com

[email protected]

866-356-1735


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