Hazardous Waste Issues Associated with

Municipal Operations

Dan SowryEnvironmental SpecialistOffice of Compliance Assistance and Pollution Prevention

September 25, 2014

Topics

Hazardous Waste Issues- Hazardous waste categories- Common hazardous waste

- Proper management

What to Expect During an Inspection

Waste Disposal

Must determine if each type of waste is hazardous or not:

If non-hazardous recycle or put in dumpster.

If hazardous recycle or store for pickup by hazardous waste or universal waste transporter.

Ohio EPA commonly cites facilities for failing to determine if wastes are hazardous – automatic enforcement referral to

Attorney General’s Office if found in trash.

Managing your waste: It’s all about the dumpster

Don’t throw any waste into the dumpster unless you have

confirmed and

demonstrated that it is NOT a hazardous

waste.

3 Generator Categories:

Conditionally Exempt Small Quantity Generator (CESQG)

• less than 220 lbs/month (about ½ of a 55-gallon drum)• Most facilities fall into this category

Small Quantity Generator (SQG) 220 to 2,200 lbs/month (½ up to 5, 55-gallon drums)

Large Quantity Generator (LQG) over 2,200 lbs/month (over 5, 55-gallon drums)

Determining Your Category

• Total weight of hazardous waste that you generate (create) in any given month of the calendar year;– For example: Hazardous waste that you generate between

November 1st and November 30th

AND

• Total amount of hazardous waste on-site at any given time (only for CESQGs and SQGs)

NOTE: Generator categories are NOT determined by theweight of waste shipped off-site.

Less Regulations

More Regulations

Large Quantity Generator

Conditionally ExemptSmall Quantity Generator

What are my requirements?• CESQG

– Determine and document if your waste is hazardous– If hazardous, send to permitted hw facility– Don’t store more than 5, 55-gallon drums – EVER!

• SQG - Same as CESQG and…– Move hazardous waste off-site within 6 months– Must have ID # – Must clearly label containers “Hazardous Waste”– Must manifest hazardous waste off-site– Must inspect and maintain emergency equipment “as necessary”

in hw storage area (must keep inspection records)– Must inspect and log hw container storage area “at least weekly”

(must keep inspection records)

epa.ohio.gov/portals/32/pdf/gen_handbook.pdf

U.S. EPA Identification Number* (12-digit)

• CESQGs - Not Required – but…• Waste hauler might want you to have one

• SQGs and LQGs – Required • Site specific, identifies company that created

the waste• No fee – just fill out 9029 Site ID form• epa.ohio.gov/portals/32/pdf/WasteActivityBook.pdf• Need help? Call me! 614-728-8575

Typical Garage Wastes

Aerosol CansShop Towels & RagsFluorescent LightsUsed Oil & Oil FiltersFloor DryUsed BatteriesElectronics

Management options:•Recycle (Best Option!!!)

– Laundry service – clean and return•Disposal

– Must evaluate • Used to clean up solvent spill –listed hazardous waste• Can contain hazardous contaminants (ex, metals and

organics)– If hazardous, must go to permitted hazardous waste facility– If non-hazardous and you have documentation to prove it,

they can go in dumpster (not recommended!)

Note: Do not burn!!!

Shop Towels & Rags

Management options:•Recycle (Best Option!!!)

– Manage as Universal Waste• Doesn’t count towards hazardous waste category• Date and package in same box (keep flaps closed)• Label as “Universal Waste Lamps”• Contact recycler for pick-up

•Disposal– Must evaluate

• Usually hazardous for mercury and other heavy metals

– If hazardous, must go to permitted hazardous waste facility– If non-hazardous and you have documentation to prove it, can

go in dumpster (not recommended)

Note: Do not recommend crushing your bulbs

Fluorescent Lights

Management options:•Recycle (Used Oil)

– Label your containers with the words “Used Oil”– Send to used oil recycler

• Used oil processors/re-refiners• Used oil burners (not space heaters)

– Burn your used oil in your used oil space heater– Send to another business to be burned in their space heater

• Must have analysis that shows the oil meets certain specifications• Do not mix used oil with anything

•Recycle (Used Oil Filters)– Hot drain– Recycle as scrap metal– Tern-plated filter

Used Oil & Oil Filters

Management options:•Manage as Used Oil

– Contains free-flowing used oil and no solvents

– Used oil burners (not space heaters) may burnas fuel if floor dry is combustible

•Disposal– Cannot contain free-flowing oil (drip test)– If hazardous due to organics or solvents, must go to permitted

hazardous waste facility– If non-hazardous and you have documentation to prove it, can go in

trash (cannot contain free-flowing oil)

Floor Dry

Management options:•Recycle –Manage as Universal Waste

• Doesn’t count towards hazardous waste category• Date & label storage area “Universal Waste Batteries”• Contact recycler for pick-up

–Manage under Lead Acid Battery Rule• Doesn’t count towards your hazardous waste category• Exchange with battery supplier

– Give them a Land Disposal Restriction (LDR) one-time notice

(only required if you’re a SQG or LQG)

Used Batteries

Management options:•Recycle (Best Option!!!)– Free recycling drop-off locations– epa.ohio.gov/ocapp/Recycle.aspx

•Disposal – Usually hazardous for lead– If hazardous - must go to permitted hazardous waste

facility– If non-hazardous and you have documentation to prove

it, can go in dumpster (not recommended!!!)

Electronics

EPA inspectionsWho visits you?•Could be inspector for only haz waste, only water pollution, or only air pollution - don’t assume it’s comprehensive!

Why do they show up?•Complaint investigations

– most common reason why businesses are inspected!!!

•Priorities: annual, biennial, or special sector initiatives

What do they want?•Check compliance with Ohio’s environmental rules

Avoid complaints …

• Minimize or eliminate odors & dust to nearby homes

• Follow the rules

Questions?