Hazardous Waste Issues Associated with Municipal Operations Dan Sowry Environmental Specialist Office 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 1 st and November 30 th AND Total amount of hazardous waste on-site at any given time (only for CESQGs and SQGs) NOTE: Generator categories are NOT determined by the weight of waste shipped off-site.

Less Regulations More Regulations Large Quantity Generator Conditionally Exempt Small 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!

Typical Garage Wastes  Aerosol Cans  Shop Towels & Rags  Fluorescent Lights  Used Oil & Oil Filters  Floor Dry  Used Batteries  Electronics

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 burn as 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 inspections Who 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?