Hazardous and Solid Waste Issues

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Hazardous and Solid Waste Issues

• Kathy Hotovec
• Compliance Assistance Coordinator
• Hazardous Materials Waste Management Division
• Colorado Department of Public Health
  Environment
• kathy.hotovec_at_state.co.us
• 303-692-3343

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Hazardous Waste

• Two ways to be hazardous waste
• Characteristic
• - Ignitable - Corrosive
• - Reactive - Toxic
• Listed
• F wastes common to many sectors K wastes
  from specific sectorsP unused chemical
  products (acute) U unused chemical products
  ( Need not be sole active ingredient)

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Three Generator Categories

• Based on amount of hazardous waste generated per
  month AND/OR amount stored onsite at one time
• More waste more requirements

CESQG
SQG
LQG
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Conditionally Exempt Small Quantity Generator
(CESQG)

• Less than 100 kilograms generated in any calendar
  month ( ½ of a 55-gallon drum)
• No more than 1,000 kilograms onsite at one time
  ( 5 55-gallon drums)
• Less than 1 kilogram acutely hazardous waste
  generated in a month or accumulated onsite at one
  time (lt 2.2 pounds or 1 quart)

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CESQG Requirements

• Make hazardous waste determination on all wastes
• Obtain EPA I.D. number if generate more than 3
  gallons per year of certain solvents (F001, F002,
  F004, F005)
• Annual generator fee
• Must complete and submit a self-certification
  checklist if notified to do so

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CESQG Requirements

• Must maintain and operate facility in a manner to
  minimize possibility of release
• Can treat hazardous waste onsite or must ensure
  delivery to a permitted treatment, storage or
  disposal facility
• Solid waste landfills in Colorado are not
  permitted to accept hazardous waste (residential
  waste excepted)
• No onsite disposal

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Small Quantity Generator (SQG)

• Generates between 100 and 1,000 kilograms of
  waste in any calendar month ( ½ of a 55-gallon
  drum up to 5 55-gallon drums)
• Never accumulates more than 6,000 kilograms of
  waste onsite ( 30 55-gallon drums)
• Less than 1 kilogram acutely hazardous waste
  generated in a month or accumulated onsite at one
  time (lt 2.2 pounds or 1 quart)

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SQG Requirements

• Make hazardous waste determination on all wastes
• Obtain an EPA I.D. number
• Annual generator and commission fees,
  notification fee
• Waste accumulation time limit
• 180 days (270 days if destination facility is
  over 200 miles away)

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SQG Requirements

• Container and tank management
• Not leaking, good condition, labeled and dated,
  kept closed, compatibility, stored in manner to
  prevent release, fix problems, inspections
• Preparedness and prevention
• Emergency coordinator, telephone posting,
  response plans and equipment, aisle space,
  arrangements with local responders

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SQG Requirements

• Training and documentation
• Waste management and emergency response relative
  to job, performance based, documentation of
  training
• Shipping, manifests and Land Disposal Restriction
  (LDR) requirements
• Keep records for 3 years
• Must complete and submit a self-certification
  checklist when notified to do so

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Large Quantity Generator (LQG)

• Generates more than 1,000 kilograms of hazardous
  waste in any calendar month (gt5 55-gallon
  drums)
• Accumulates more than 6,000 kilograms of
  hazardous waste onsite (gt30 55-gallon drums)
• More than 1 kilogram acutely hazardous waste
  generated in a month or accumulated onsite at one
  time (gt2.2 pounds or 1 quart)

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LQG Requirements

• Hazardous waste determination on all wastes
• Obtain an EPA I.D. number
• Annual generator and commission fees,
  notification fee
• Waste accumulation time limit - 90 days

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LQG Requirements

• Container management
• Not leaking, good condition, labeled and dated,
  kept closed, compatibility, stored in manner to
  prevent release, fix problems, inspections
• Tank management
• Not leaking, good condition, labeled and dated
  (or keep log), no open top tanks, compatibility,
  stored in manner to prevent release, fix
  problems, inspections

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LQG Requirements

• Preparedness and prevention
• Response plans and equipment, aisle space,
  arrangements with local responders
• Written contingency plan
• Emergency response coordinator info, list of
  equipment, evacuation plan, list of all hazardous
  waste accumulation areas, specify fire protection
  district, specify LEPC, provide copies, must be
  current

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LQG Requirements

• Training and documentation
• Classroom and on-the-job
• Job descriptions, required training,
  documentation of training

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LQG Requirements

• Shipping, manifests and Land Disposal Restriction
  (LDR) requirements
• Record keeping requirements and reporting
• Keep records for 3 years
• Biennial report
• Due during even-numbered year reporting on
  previous odd-numbered year

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Common CESQG/SQG/LQG ViolationLack of Waste
Determination

• Results in improper waste disposal
• Inadequate waste analysis, inappropriate use of
  the MSDS or inadequately documented process
  knowledge
• May result in unsafe site conditions
• Possible enforcement action

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Are You Keeping an Eye on Your Trash?
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Ignoring It Wont Make It Go Away
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Common CESQG/SQG Violation Too Much Waste

• Too much generated per calendar month
• AND/OR
• Too much onsite at one time or for too long (SQG)

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If the Generation Limit is Exceeded

• You are now the next level up of hazardous waste
  generator and must meet all those requirements
  including increased
• Notification and fees
• Time limits, management requirements
• Training
• Documentation and reporting
• Possible enforcement action

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If the Accumulation Limit is Exceeded

• You are subject to the requirements of the next
  level up of hazardous waste generator (CESQG)
• You are an un-permitted storage facility (i.e.,
  likely enforcement action) (SQG)

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SQG Violation - No Phone Postings

• Post emergency response information by the
  telephone
• Name/phone number of the emergency coordinator
• Location of fire extinguishers and alarms
• Location of spill response equipment
• Phone number for the Fire Department

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Common Violation - Inadequate or No Training

• Personnel must be trained on waste handling and
  emergency procedures
• Need hazardous waste specific training
• OSHA hazard communication training usually is NOT
  adequate

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Open Container Violation
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Container Options
Liquids
Solids
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Labeling Violation
Adequate
10/1/08
Inadequate
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Containers in Poor Condition
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Aisle Space
Adequate
Inadequate
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Failure to Conduct Inspections
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Inadequate Record Keeping
Manifests properly completed, signed and
returned
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Universal Waste Management
Mercury-containinglamps
Batteries
Aerosolcans
Pesticides
Computers and otherelectronic devices
Mercury-containing devices
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Universal Waste Regulations

• Provides less stringent management standards for
  six widely generated wastes
• Discourage illegal disposal
• Encourage recycling
• Universal Wastes are still hazardous wastes
• Can choose to manage as universal waste or under
  the full hazardous waste regulations

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Batteries

• Batteries that contain mercury and other metals
  may also be reactive
• Ni-cad, silver-oxide, mercury-oxide, lithium,
  zinc-air, and some alkaline and zinc-carbon
• Local battery recyclers
• Mail-back programs

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Vehicle Batteries

• Can be managed under Part 267 Subpart G
• Picked up when new batteries delivered

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Pesticides

• Recalled and banned pesticides
• Collected as part of a waste pesticide collection
  program (e.g. CHEMSWEEP at [phone] )

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Mercury-containing Devices

• Products that contain elemental mercury that acts
  as a conductor of temperature, pressure or
  electricity
• Thermometers, thermostats, pressure gauges,
  electrical switches, etc.
• Local hazardous waste companies
• Mail-back programs for small devices
• Out-of-state mercury recyclers

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Aerosol Cans

• Cans that still contain product and contents
  are hazardous waste
• Puncture and drain cans
• Dispose of contents as hazardous waste
• Recycle or dispose of cans

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Mercury-containing Lamps

• Lighting devices that contain mercury
• Fluorescent, compact fluorescent, high intensity
  discharge (HID), neon, mercury vapor, high
  pressure sodium, metal halide lamps, etc.
• Toxicity test-compliant lamps are clearly marked
  and can be recycled (preferred) or disposed of as
  solid waste (acceptable)
• Local lighting contractors
• Mail-back programs
• Out-of-state lamp recyclers

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Drum Top Bulb Crushers

• Allowed as long as you have and follow a written
  procedure
• Completely enclosed system with filters
• Operation and maintenance of equipment
• Precautions to protect workers
• Personal protective equipment, air monitoring,
  changes to ventilation system
• Worker training
• Waste management and disposal
• Filters are not universal waste

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Electronic Devices and Components

• Electronic devices that contain
  circuit boards or circuitry that exhibit
  toxicity characteristics for heavy metals like
  lead, chromium, mercury, cadmium or silver
• CPUs, monitors, laptops, computer peripherals,
  cell phones, TVs

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Electronics are Different

• Generally a waste when original generator can no
  longer use it
• Computers and some electronics may not be useful
  to original generator, but can still be used by
  someone else for intended purpose
• May not be a waste yet

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If They are Disposed

• If original generator sends their computers and
  electronic equipment for disposal, it is a waste
  and the hazardous waste regulations apply to the
  generator

Hazardous Waste
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If They are Recycled

• If original generator sends their electronic
  equipment to a legitimate recycler, the recycler
  is the one that determines if it will be reused
  or recycled for materials recovery
• If reused, is not a waste and regulations dont
  apply yet
• If recycled for materials recovery, is a waste
  and regulations apply to recycler

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Is it a Waste?

• Must manage in a manner consistent with a product
  having value if they want to claim that it is not
  a waste

Product
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Universal Waste Handlers

• Those that manage Universal Wastes are called
  handlers
• Handler status is unrelated to generator status
• Generators, consolidation facilities,
  transporters
• Small quantity handler if lt5,000 kg of universal
  wastes onsite at one time

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Requirements for Small Quantity Handlers

• Accumulation time - one year
• Staff training
• Contain and cleanup releases
• Label item or accumulation container
• Ship to another universal waste handler or to a
  recycling, treatment, or disposal facility

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(Non) Requirements forSmall Quantity Handlers

• Not required to notify
• Not required to keep records
• Not required to use hazardous waste manifest
• Not required to use hazardous waste transporter

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Prohibitions

• Universal wastes are still hazardous wastes
• No onsite disposal
• No disposal in a solid waste landfill

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Recyclers

• www.cdphe.state.co.us/hm/mercury/hgrecyclers.pdf
• www.cdphe.state.co.us/hm/electronics/erecyclers.pd
  f
• Variety of mailback options
• www.grainger.com
• www.veoliaes-ts.com/RecyclePak
• www.recyclekit.com
• www.aircycle.com/store/products.aspx?categoryid23
  6
• www.wmlamptracker.com
• www.cleanharbors.com

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Solid Waste

• Recycling (newspapers, cans, bottles)
• Asbestos in soil
• Beneficial use of recycled inert materials
• Composting of food wastes

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Asbestos in Soil

• Contaminants remaining from building removal
• Old contaminated fill
• Potential health risks when disturbed

• Proper management necessary to prevent exposure
  if it will be disturbed

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Beneficial Use

• Reclaimed asphalt paving used as aggregate in hot
  mixasphalt paving
• Crushed concrete used to replace virgin
  aggregate in concrete paving, crushed
  aggregate surfacing, road base, structural fill
• Recycled concrete used in structural elements
  and paving

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Beneficial Use Examples

• Stapleton International Airport
• 6.5 million tons of concrete and asphalt from
  runways, taxiways, aprons, hangers, towers
• Reused about 1/3 of aggregates in redevelopment
  of new Stapleton community
• Also used at DIA, Buckley, E-470 and Rocky
  Mountain Arsenal National Wildlife Refuge
• Central Wisconsin Airport
• Coal combustion products from Wausau-Mosinee
  Paper and Wisconsin Public Service power plant as
  fill for runway overrun area

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Composting of Food Waste

• Portland, OR airport
• January 2003 initiated food waste collection in
  kitchen and prep stations
• November 2007 added food waste collection bins in
  food court
• Diverted 165 tons of food waste in 2007 and 98
  tons as of June 2008
• www.findacomposter.com

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Customer Technical Assistance

• Phone [phone] or 888-569-1832 ext 3320
• Email comments.hmwmd_at_state.co.us
• Web www.cdphe.state.co.us/hm/
• Guidance documents
• Compliance aids
• Generator Assistance Program (GAP)