Automotive Repair and Refinishing Environmental Compliance
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Intern Information
Name:
Jennifer Werkelin
Address:
1500A Lafayette Rd.. #112
Portsmouth NH 03801
Phone:
603-964-8232
E-mail:
werkelin@christa.unh.edu
Facility Information
Name:
State of New Hampshire
Department of Environmental Services
Air Resources Division
Small Business Technical Assistance Program
Address:
64 North Main St
PO Box 2033
Concord NH 03301-2033
Contact:
Rudolph A. Cartier, Jr. P.E.
Small Business Ombudsman
Phone:
800-837-0656
Fax:
603-271-1381
E-mail:
cartier@desarsb.mv.com
Table of Contents
Executive Summary
page 4
Introduction/Background
page 4
Goals and Objectives
page 4
Approach
page 4
Chemical Uses/Releases/Wastes
page 5
Work Accomplished and Project Results
page 5
Pollution Prevention Benefits
page 6
Recommendations for Future Efforts
page 6
References
page 6
Appendix Contents
page 7
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Executive Summary
The Department of Environmental Services (DES) has targeted non-reporting automotive repair
and refinishing businesses. This summer, at the request of the business owner, the Small
Business Technical Assistance Program (SBTAP) will perform on-site evaluations to inform the
owner of potential environmental compliance issues. The purpose of this approach is to assist
small business owners in becoming aware of environmental responsibilities and potential
“solutions” before an unannounced inspection is performed by the State.
Introduction/Background
SBTAP is a program run through DES designed to aid small businesses in environmental
compliance. The services performed by the program are free to the business owner. SBTAP
provides resources to attain compliance and instill pollution prevention ideology.
The automotive repair and refinishing industry is subject to many different regulations, especially
to those dealing with hazardous wastes. The focus of the year long effort by SBTAP is to
educate shop owners. This has included the creation of a comprehensive guide to laws affecting
the shops and suggestions for best management practices.
Goals and Objectives
This summer SBTAP will attempt to visit one hundred auto body repair and refinishing
businesses. An effort will be made to contact vendors to research pollution prevention
opportunities and hazardous waste treatment and disposal.
Approach
The Automotive Repair and Refinishing Environmental Compliance Manual (manual) was
offered to over 1700 shops in New Hampshire through a mass mailing. (See Appendix for letter)
The opportunity for an evaluation was given to the business owner to compliment and
demonstrate practices and procedures which are outlined in a compliance manual that is available
to the shops, free of charge. Some shop owners, when requesting a manual, inquired about the
on-site evaluations. A list of shops requesting on-site evaluations was made and the shop was
contacted to set up an appointment. Once the appointment was made a pre-evaluation checklist
and a conformation letter were sent to the shop. (See appendix for pre-evaluation) An evaluation
checklist was created based upon the manual and it was used as a guideline for each evaluation
that was conducted. (See appendix for checklist) A detailed report of the evaluation was written
and sent back to the shop operator. (See appendix for sample report)
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Chemical Uses/Releases/Wastes
The materials, equipment, and issues on-site will depend upon the function of the facility. The
following materials will be examined: aerosol cans, antifreeze, asbestos, batteries, Freon, paint,
paint waste, washing solvents, shop wipes, used oil, oily wastes, and used tires. The following
equipment will be examined: storage tanks, sumps and floor drains. The following issues will
be addressed: hazardous waste storage and disposal, permitting, spills, wastewater, OSHA, and
EPCRA.
Work Accomplished and Project Results
The project was extremely successful. Over 500 manuals have been sent out. The goal of 100
on-site evaluations was met and exceeded. Many vendors were contacted and a large base of
information was collected.
The first weeks of the project included the mailing of the requested manuals. An approach to the
contact and procedure for evaluations had to be created. Ali Etebari and I spent a good amount
of time discussing issues found in the manual and how we were going to communicate with the
shop owners. Andrew Meyer of the Waste Management Division, DES graciously took Ali and I
on two unannounced enforcement inspections. The following week Ali and I started to complete
two evaluations together, each day. A goal of eight evaluations per week was set. Thursdays
were set aside for reports and setting up appointments at DES in Concord.
Once Ali and I felt comfortable with evaluations we set out on our own. This allowed us to
complete 16 evaluations weekly. The following eight weeks were filled with on-site evaluations,
two evaluations were completed daily.
Rudy also asked Ali and I to create a response post card. The card was printed and will be used
to gauge the responses to the manual. (See appendix card) The response card took a long time to
get clearance, and because of the large response to the manual, more cards need to be printed
already.
I also had the opportunity to contact vendors to learn about what services they could offer to the
shops. Safety-Kleen, Cycle-Solve, Clean Harbors, Technical Chemical Company, and Total
Waste Management were all contacted. I toured Total Waste Management in Newington. I
invited Dave Riva of Cycle-Solve to talk to Ali Etebari, Melissa Waleryzak (DES P3) and
myself.
One of the issues that arose during the summer was clarification of laws and regulations. Many
people within DES were contacted and gave information on the following subjects: EPA
Identification Numbers, asbestos, over spray paper, floor drains, Freon, and antifreeze recyclers.
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Some research was done regarding above ground storage tanks laws and integrated contingency
plans.
Pollution Prevention Benefits
In the auto repair and refinishing business there are many opportunities for pollution prevention.
These include source reduction and recycling. In some cases some of the materials that are
recovered can be reused, this means a savings for the business owner, or even a profit. In most
cases these businesses are small and are not aware of the compliance issues that affect them.
This program is designed to increase awareness and help to obtain compliance.
Recommendations for Future Efforts
Since I will be included in the future efforts, I know the following will be happening. In the next
few months the SBTAP will be setting up workshops for shop owners. Best management
practices will be created for auto body shop spray booth operations. Updates to the manual will
be created and mailed.
References
Rudolph Cartier, Jr., DES SBTAP
Donald Littlefield, Total Waste Management
Mitchell Locker, DES WS&PCD
Andrew Meyer, DES WMD
Tom Phoenix, Safety-Kleen
Dave Riva, Cycle-Solve
Peter Sullivan, Intern, GE
Melissa Waleryzak, DES P3
Miles Walker, Intern, PolyClad
Karen Way, DES Reporting
Robert White, DES ARD
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Appendix
Manual and On-site Offer Letter
Pre-evaluation Checklist
Evaluation Checklist
Sample Report
Response Post Card
page A1
page A2
page A3
page A7
page A11
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