Characteristic Hazardous Wastes 4 categories of characteristic hazardous wastes: 4 categories of characteristic hazardous wastes: � Ignitable Ignitable � Corrosive Corrosive � Reactive Reactive � Toxic Toxic
Ignitable Hazardous Wastes Ignitable Hazardous Wastes � Flash point <140 F Flash point <140 F � Usually a liquid Usually a liquid � D001 D001 hazardous waste code hazardous waste code � Examples include: Examples include: � Paint waste Paint waste � Degreasers Degreasers � Solvents S l S l Solvents t t
Corrosive Hazardous Wastes Corrosive Hazardous Wastes � pH < 2 or pH > 12 5 � pH < 2 or pH > 12.5 pH < 2 or pH > 12 5 pH < 2 or pH > 12.5 � Usually a liquid � Usually a liquid Usually a liquid Usually a liquid � D002 D002 hazardous waste code hazardous waste code � Examples include: Examples include: p � Waste acids Waste acids � Alkaline cleaning fluids Alkaline cleaning fluids � Waste battery acids Waste battery acids
Reactive Hazardous Wastes Reactive Hazardous Wastes � Explosive, unstable, reacts violently with water Explosive, unstable, reacts violently with water � D003 D003 hazardous waste code hazardous waste code � Examples include: Examples include: � Waste bleaches Waste bleaches � Other oxidizers Other oxidizers
Toxic Hazardous Wastes Toxic Hazardous Wastes � Contain toxic constituents above regulatory levels Contain toxic constituents above regulatory levels � Heavy metals, insecticides, herbicides and other Heavy metals, insecticides, herbicides and other organics organics � Determined by D t Determined by Toxicity Characteristic Leaching D t i i d b d b T Toxicity Characteristic Leaching T i it Ch i it Ch t t i ti L i ti L hi hi Procedure Procedure (TCLP) (TCLP) � D004 through D043 � D004 through D043 D004 through D043 hazardous waste codes D004 through D043 hazardous waste codes hazardous waste codes hazardous waste codes � Examples include: Examples include: � Electronic equipment containing lead � Electronic equipment containing lead Electronic equipment containing lead Electronic equipment containing lead � Spent foundry sand Spent foundry sand � Air emission control dust Air emission control dust
Toxic Hazardous Waste Examples E l Ohio EPA Contaminant CAS No. Regulatory H Hazardous d Level (mg/l) L l ( /l) Waste No. D004 D004 Arsenic Arsenic 7440-38-2 7440 38 2 5 0 5.0 D005 Barium 7440-39-3 100.0 D006 D006 Cadmium Cadmium 7440 43 9 7440-43-9 1 0 1.0 D007 Chromium 7440-47-3 5.0 D008 D008 Lead Lead 7439 92 1 7439-92-1 5 0 5.0 D009 Mercury 7439-97-6 0.2 D010 D010 Selenium Selenium 7782 49 2 7782-49-2 1.0 1.0 D011 Silver 7440-22-4 5.0
Do I Have A Hazardous Waste? Do I Have A Hazardous Waste? Has your business generated a waste? Yes Yes Is it excluded? Yes You do not have a hazardous waste. No You have a listed hazardous You have a listed hazardous Is the waste on Ohio EPA’s Is the waste on Ohio EPA s Yes Yes waste F, K, P or U lists? No No Does the waste have any hazardous waste characteristics? Does the waste have any hazardous waste characteristics? hazardous waste characteristics? Yes Yes You have a listed and No Yes characteristic hazardous waste You have a characteristic Not a hazardous hazardous waste waste
G Generator Categories t C t i
Generator Categories Generator Categories Ohio has three ha ardo s Ohio has three ha ardo s Ohio has three hazardous waste generator Ohio has three hazardous waste generator aste generator aste generator categories: categories: � Conditionally Exempt Small Quantity Generators Conditionally Exempt Small Quantity Generators ( (CESQGs CESQGs); ); ); ); � Small Quantity Generators ( Small Quantity Generators (SQGs SQGs); and ); and � Large Quantity Generators ( Large Quantity Generators (LQGs LQGs). ).
Determining Your Category g g y � Total weight of hazardous waste that you generate Total weight of hazardous waste that you generate (produce) in any given month of the calendar year; (produce) in any given month of the calendar year; (produce) in any given month of the calendar year; (produce) in any given month of the calendar year; � For example: Hazardous waste that you generate For example: Hazardous waste that you generate st and October 31 between October 1 between October 1 st and October 31 st st AND � Total amount of hazardous waste on Total amount of hazardous waste on- -site at any given site at any given time (only pertains to time (only pertains to CESQGs CESQGs and and SQGs SQGs) NOTE: NOTE: Generator categories are Generator categories are NOT NOT determined by the determined by the weight of waste shipped off weight of waste shipped off-site weight of waste shipped off weight of waste shipped off site. site site.
Conditionally Exempt Small Quantity Generators (CESQGs) Y You are a You are a CESQG CESQG if you: CESQG CESQG if if you: if � generate no more than 220 pounds of hazardous � generate no more than 220 pounds of hazardous generate no more than 220 pounds of hazardous generate no more than 220 pounds of hazardous waste per waste per month month; ; AND � never accumulate more than 2,200 pounds of hazardous waste on your property y y Note: Note: 220 pounds is about 220 pounds is about half half of a 55 of a 55- -gallon drum gallon drum 2,200 pounds is about 2,200 pounds is about five 2 200 pounds is about 2 200 pounds is about five five 55 five 55 55 gallon drums 55-gallon drums gallon drums gallon drums
What If I Go Over The CESQG Limits? � Generate more than 220 pounds of HW/month Generate more than 220 pounds of HW/month � you become either an SQG or an LQG for that month � Accumulate more than 2,200 pounds of HW at Accumulate more than 2,200 pounds of HW at any given time any given time � you become an you become an LQG LQG until that HW until that HW is moved off is moved off- -site site
Small Quantity Generators (SQGs) You are an You are an SQG SQG if you: if you: � generate more than 220 pounds but less than generate more than 220 pounds but less than 2,200 pounds of hazardous waste/month; and 2,200 pounds of hazardous waste/month; and � never accumulate over 13,200 pounds of never accumulate over 13,200 pounds of hazardous waste on hazardous waste on- -site. site.
What If I Go Over The SQG Limits? � Generate more than 2,200 pounds of hazardous Generate more than 2,200 pounds of hazardous waste in a calendar month waste in a calendar month � you become an you become an LQG LQG until that hazardous waste is until that hazardous waste is moved off moved off- -site site � Accumulate over 13,200 pounds of hazardous Accumulate over 13,200 pounds of hazardous waste on waste on-site waste on waste on-site site site � you become a treatment, storage and disposal facility you become a treatment, storage and disposal facility (TSDF TSDF) and must have a hazardous waste installation ) and must have a hazardous waste installation and operation and operation permit permit
Large Quantity Generators (LQGs) You are an You are an LQG LQG if you: if you: � generate 2,200 or more pounds of hazardous generate 2,200 or more pounds of hazardous waste/month waste/month Note: Note: LQGs do not have a limit on volume of LQGs do not have a limit on volume of h h hazardous waste stored on- hazardous waste stored on d d t t t t d d -site site it it
What If I Change Generator Categories? � Termed Termed episodic generation � Must manage your hazardous waste under all applicable generator requirements for hazardous wastes generated that month for as long as that waste remains on-site � If you reach LQG status at any time during the calendar year, you must file an annual report l d fil l
G Generator Requirements t R i t
Determining Your Generator Determining Your Generator Requirements � CESQGs follow OAC rule 3745-51-05 � SQGs and LQGs follow OAC Ch Chapter 3745-52 t 3745 52
Generator Requirements Generator Requirements Summary Table � Management requirements � OAC references � CESQG, SQG, or LQG compliance requirement Q , Q , Q p q
Hazardous Waste Determination � Determine if your waste is hazardous waste � OAC rule 3745-52-11 � Failure to properly evaluate your waste may lead to unsafe conditions or violations from improper to unsafe conditions or violations from improper management
Remember This! Remember This! Remember This! Remember This! Don’t throw any Don’t throw any waste into the waste into the dumpster unless dumpster unless dumpster unless dumpster unless you have you have confirmed confirmed and and demonstrated demonstrated that it is that it is NOT NOT a a hazardous hazardous waste. waste.
U.S. EPA Identification Number � Only required for SQGs and LQGs � CESQGs are not required to obtain U.S. EPA ID numbers numbers � U S EPA ID numbers are site specific � U.S. EPA ID numbers are site specific
How Do I Obtain A U.S. EPA Identification Number? � Print a copy of EPA Form 9029 from DHWM’s Web site � Print a copy of EPA Form 9029 from DHWM s Web site or call (614) 644-2977 and ask for a copy of the Notification of Regulated Waste Activity booklet � Complete the form in its entirety using the � Complete the form in its entirety using the instructions provided � Mail the completed and signed original EPA form 9029 to: Ohio EPA – DHWM Regulatory and Information Services Regulatory and Information Services P.O. Box 1049 Columbus, Ohio 43216-1049
How Long May I Accumulate (store) HW On-site? � CESQGs CESQGs do not have any storage time limits do not have any storage time limits � SQGs SQGs can store hazardous waste on can store hazardous waste on- -site for up site for up to to 180 days 180 days; HOWEVER, if transporting a ; HOWEVER, if transporting a distance of 200 miles or more, can store for up distance of 200 miles or more, can store for up f f f f to 270 days (30 day extension available) to 270 days (30 day extension available) � LQGs LQGs can store hazardous waste on can store hazardous waste on- -site site for up to for up to 90 days for up to for up to 90 days 90 days (30 day extension available) 90 days (30 day extension available) (30 day extension available) (30 day extension available)
What is Treatment? What is Treatment? � Defined in Ohio Administrative Code rule Defined in Ohio Administrative Code rule 3745 3745- -50 50- -10(A)(125) 10(A)(125) � Treatment Treatment: any method, technique or process, : any method, technique or process, designed to render waste non designed to render waste non- -hazardous, less hazardous, less- - hazardous; safer to transport, store or dispose of; hazardous; safer to transport, store or dispose of; or amenable for recovery, amendable for or amenable for recovery, amendable for bl bl f f d bl d bl f f storage or reduced in volume. storage or reduced in volume.
May I Treat My Hazardous Waste On-site? � Some forms of treatment by generators are allowed without a hazardous waste permit: � N � Neutralization t li ti � Polymerization � St bili � Stabilization ti � Wastewater treatment � See “Generator Treatment” guidance document � See Generator Treatment guidance document � Consult with us if you wish to treat your hazardous waste waste
What Is Satellite Accumulation? � Satellite accumulation – term for the temporary storage of hazardous waste near where it is g generated � Found in Ohio Administrative Code (OAC) rule 3745-52-34(C) � Only applies to SQGs and LQGs � Use of this rule reduces some regulatory requirements for storage areas
What Requirements Apply to Satellite Accumulation Areas? � Up to 55 gallons of HW in containers at or near each point of generation � Containers must be under control of the operator of the process which generated the waste of the process which generated the waste � Containers must be compatible with waste and in C t i t b tibl ith t d i good condition – not leaking
What Requirements Apply to Satellite Accumulation Areas? � Containers must be marked with the words “Hazardous Waste” (or other words that identify Hazardous Waste (or other words that identify contents) � Containers must remain closed except when adding or removing hazardous waste g g
What Happens When I Reach The 55-Gallon Limit? � Place the date on the container when it happened Place the date on the container when it happened � Move the container to your centralized storage Move the container to your centralized storage area (i.e., 90 or 180/270 day area) within three area (i e area (i e area (i.e., 90 or 180/270 day area) within 90 or 180/270 day area) within 90 or 180/270 day area) within three three three days days of the date that you place on the container of the date that you place on the container � Begin complying with the Begin complying with the SQG SQG or or LQG LQG hazardous waste accumulation hazardous waste accumulation requirements requirements
What Are The Container What Are The Container Management Requirements? Management Requirements? � Found in Ohio Administrative Code (OAC) rules Found in Ohio Administrative Code (OAC) rules 3745 3745- -66 66- -70 70 through through 3745 g 3745- -66 66- -77 77 � They only apply to They only apply to SQGs y y y y pp y pp y SQGs and Q and LQGs LQGs Q � though not required, these preventative measures g q , p are good for CESQGs to follow
What Are The Container M Management Requirements For t R i t F SQGs and LQGs? � Must be in good condition g � Compatible with the hazardous waste and area � Clearly labeled as “Hazardous Waste” Clearly labeled as Hazardous Waste � Closed (lids) � Conduct weekly inspections � Conduct weekly inspections
What Are The Container M Management Requirements For t R i t F SQGs and LQGs? � Label storage start date � Maintain aisle space � Ignitable/reactive located 15 meters from facility’s property line � U.S. EPA air emission standards (LQGs only)
What Are The Tank Management What Are The Tank Management Requirements? Requirements? � They only apply to They only apply to SQGs SQGs and and LQGs LQGs � though not required, these preventative measures are good for CESQGs to follow � Found in Ohio Administrative Code (OAC) rules Found in Ohio Administrative Code (OAC) rules 3745 3745 66 3745 3745-66 66-90 66 90 90 th 90 through th through 3745 h 3745 h 3745 66 3745-66 66 101 66-101 101 101
What Are The SQG Tank What Are The SQG Tank Management Requirements? Management Requirements? � Good condition � Good condition Good condition Good condition � Compatible with waste and area Compatible with waste and area C C tibl tibl ith ith t t d d � Labeled as “Hazardous Waste” Labeled as “Hazardous Waste” � Accumulation start date Accumulation start date � Daily inspections Daily inspections
What Are The LQG Tank What Are The LQG Tank M M Management Requirements? Management Requirements? t R t R i i t ? t ? � Good condition Good condition � Compatible with waste and area � Compatible with waste and area Compatible with waste and area Compatible with waste and area � Labeled as “Hazardous Waste” Labeled as “Hazardous Waste” � Accumulation start date � Accumulation start date Accumulation start date Accumulation start date � Daily inspections Daily inspections � U S EPA air emission standards apply � U.S. EPA air emission standards apply U S EPA air emission standards apply U.S. EPA air emission standards apply � Secondary containment Secondary containment
What Am I Required To Do Before What Am I Required To Do Before I Ship My HW Off I Ship My HW Off- -site? site? Termed “Pretransport” – Found in OAC rules 3745-52-30 to 3745-52-32 CESQGs are not required to prepare a manifest CESQGs are not required to prepare a manifest SQGs and LQGs must prepare manifest and � Package your HW Package your HW � Label each package of HW � Mark each package of HW � Placard or offer the initial transporter the appropriate placards � C � Contact Public Utilities Commission of Ohio for more t t P bli Utiliti C i i f Ohi f information
Does My Business Need Does My Business Need P Personnel Training? Personnel Training? P l T l T i i i i ? ? � Ohio Administrative Code rule Ohio Administrative Code rule 3745 3745- -65 65- -16 16 � CESQGs CESQGs are not required to conduct personnel are not required to conduct personnel training training t t i i i i � SQGs SQGs must ensure that all employees are must ensure that all employees are thoroughly familiar with proper waste handling thoroughly familiar with proper waste handling thoroughly familiar with proper waste handling thoroughly familiar with proper waste handling and emergency procedures and emergency procedures � LQGs LQGs must conduct classroom instruction or Q must conduct classroom instruction or on on- -the the- -job personnel training for facility job personnel training for facility employees and maintain documentation employees and maintain documentation of personnel training of personnel training of personnel training of personnel training
How Do I Prepare For How Do I Prepare For Emergencies? Emergencies? Found in OAC rules Found in OAC rules Found in OAC rules 3745 Found in OAC rules 3745 3745-65 3745 65 65 30 65-30 30 to 30 to to 3745 to 3745 3745 65 3745-65 65-37 65 37 37 37 No requirements for No requirements for CESQGs CESQGs SQGs SQGs and and LQGs LQGs must: must: � Maintain emergency equipment on Maintain emergency equipment on- -site site � Maintain and operate your facility to minimize the Maintain and operate your facility to minimize the possibility of emergencies possibility of emergencies � Test and maintain your emergency equipment and T T Test and maintain your emergency equipment and t t d d i t i i t i i i t t d d record the inspections in a log record the inspections in a log � Maintain adequate aisle space � Maintain adequate aisle space Maintain adequate aisle space Maintain adequate aisle space � Make arrangements with local emergency authorities Make arrangements with local emergency authorities
When Do I Need Emergency When Do I Need Emergency Procedures & A Contingency Plan? Procedures & A Contingency Plan? � SQGs SQG SQG SQGs – at least one employee on at least one employee on- t l t l t t l l -site or on site or on- it it -call to call to ll t ll t respond to all emergencies respond to all emergencies � LQGs LQGs – prepare and maintain a prepare and maintain a written contingency plan written contingency plan � Maintain all reports of contingency plan Maintain all reports of contingency plan implementation on implementation on- -file and report the incidents to file and report the incidents to Ohio EPA Ohio EPA Ohio EPA Ohio EPA � A copy of your contingency plan must be A copy of your contingency plan must be maintained at your facility & submitted to local maintained at your facility & submitted to local police, fire, hospitals, emergency response teams police, fire, hospitals, emergency response teams and Ohio EPA and Ohio EPA
What Are My Recordkeeping What Are My Recordkeeping Requirements? Requirements? Requirements? Requirements? � Found in OAC rule � Found in OAC rule Found in OAC rule 3745 Found in OAC rule 3745 3745 52 3745-52 52 40 52-40 40 40 � CESQGs � CESQGs CESQGs SQGs CESQGs, , SQGs SQGs and SQGs and and LQGs and LQGs LQGs must keep a copy of LQGs must keep a copy of must keep a copy of must keep a copy of the following for at least 3 years: the following for at least 3 years: � Test results; Test results; � Waste evaluation; and/or Waste evaluation; and/or � Waste determinations Waste determinations
What Are SQG’s Additional What Are SQG’s Additional Recordkeeping Requirements? R R Recordkeeping Requirements? dk dk i i R R i i t ? t ? � Additionally, Additi Additi Additionally, SQGs ll ll SQG SQG SQGs must keep a copy of these for at must keep a copy of these for at t k t k f th f th f f t t least 3 years: least 3 years: � Weekly container inspections; Weekly container inspections; � All manifests; and All manifests; and � Land disposal restriction notifications, Land disposal restriction notifications, certifications and waste analysis data certifications and waste analysis data
What Are LQG’s Additional What Are LQG’s Additional Recordkeeping Requirements? Recordkeeping Requirements? � LQGs LQGs must keep a copy of these for at least 3 years: must keep a copy of these for at least 3 years: � Everything mentioned in the previous two slides; Everything mentioned in the previous two slides; � Personnel training documents; Personnel training documents; � Annual reports; and � Annual reports; and Annual reports; and Annual reports; and � Daily tank inspection logs � Daily tank inspection logs Daily tank inspection logs Daily tank inspection logs
What Are My Manifesting What Are My Manifesting R R Requirements? Requirements? i i t ? t ? � Manifests Manifests are HW tracking documents are HW tracking documents � Found in OAC rules Found in OAC rules 3745 3745- -52 52- -20 20 to to 3745 3745- -52 52- -23 23 � Only Only SQGs SQGs and and LQGs LQGs must manifest their HW must manifest their HW � Each person who transports, stores, treats or disposes must sign & retain a copy � Must receive signed copy of your manifest from � Must receive signed copy of your manifest from the final destination facility � Each transporter must have a copy for their p py records � Destination facility must have a copy
What Is An Exception Report? What Is An Exception Report? � Fo nd in OAC r le � Found in OAC rule Found in OAC rule 3745 Fo nd in OAC r le 3745 3745 52 3745-52 52-42 52 42 42 42 � Exception reports are part of the RCRA manifest Exception reports are part of the RCRA manifest tracking system tracking system tracking system tracking system � After you send waste off After you send waste off- -site for disposal, the site for disposal, the TSDF is required to return to you a copy of TSDF TSDF is required to return to you a copy of TSDF is required to return to you a copy of is required to return to you a copy of the original manifest the original manifest � If you don t receive the manifest from the � If you don't receive the manifest from the If you don t receive the manifest from the TSDF If you don't receive the manifest from the TSDF TSDF TSDF, , then you must submit an exception report to Ohio then you must submit an exception report to Ohio EPA EPA
Am I Required To File An Am I Required To File An E Exception Report? Exception Report? E ti ti R R t? t? � CESQGs � CESQGs CESQGs - Not Required CESQGs Not Required Not Required Not Required � SQGs SQGs – Required Required � If you do not receive a copy of the manifest signed If you do not receive a copy of the manifest signed by the designated facility within 60 days: Send exception report to Ohio EPA � LQGs LQGs – Required Required � If you do not receive a copy of the signed manifest within 35 days: Contact transporter and/or the within 35 days: Contact transporter and/or the designated facility � If you do not receive a copy of the signed manifest within 45 days: Send exception report to Ohio EPA
What Are The Land Disposal What Are The Land Disposal What Are The Land Disposal What Are The Land Disposal Restrictions (LDRs)? Restrictions (LDRs)? � Found in OAC Chapter Found in OAC Chapter 3745 3745- -270 270 � These only apply to � These only apply to These only apply to SQGs These only apply to SQGs SQGs and SQGs and and LQGs and LQGs LQGs LQGs � Standards Standards developed to ensure that toxic developed to ensure that toxic constituents present in hazardous waste are constituents present in hazardous waste are p p properly treated before land disposal properly treated before land disposal � Under LDRs, generators need to complete a Under LDRs, generators need to complete a notification (one notification (one-time) which accompanies manifest notification (one notification (one time) which accompanies manifest time) which accompanies manifest time) which accompanies manifest to TSD facility to TSD facility � TSDFs treat your HW to meet LDRs TSDFs treat your HW to meet LDRs y
Do I File an Annual Report? Do I File an Annual Report? p � Ohio Administrative Code rule Ohio Administrative Code rule 3745 3745- -52 52- -41 41 � Only Only LQGs LQGs file annual reports file annual reports � Report provides Ohio EPA and U.S. EPA with data concerning your facility’s hazardous waste concerning your facility’s hazardous waste generation, management and waste minimization activities � Due by March 1 st
Lamp Management Lamp Management Lamp Management Lamp Management
What We Will Cover What We Will Cover What We Will Cover What We Will Cover � Background information Background information � UW handler categories UW handler categories � Green Green- -tipped lamps tipped lamps � Crushing Crushing � Packaging/Labeling Packaging/Labeling � Storage Storage � Notification Notification � Manifesting Manifesting � Transportation Transportation � Recordkeeping Recordkeeping
Background Background � What are the UW rules? What are the UW rules? � What is a lamp? What is a lamp?
Who are UW handlers? Who are UW handlers? � UW handlers are persons who UW handlers are persons who � Generate Generate � Receive and Receive and � Store (but do not treat, dispose of or recycle UW Store (but do not treat, dispose of or recycle UW generated elsewhere) generated elsewhere) � UW handlers cannot treat dispose of or recycle � UW handlers cannot treat, dispose of or recycle UW handlers cannot treat dispose of or recycle UW handlers cannot treat, dispose of or recycle UW UW UW Destination Facilities UW Destination Facilities – – must have a permit must have a permit
What are the UW handler categories? � Two categories: Two categories: � Small quantity handlers Small quantity handlers � Accumulates onsite less than 5,000 kilograms Accumulates onsite less than 5,000 kilograms (11,023 pounds) of UW (not by type) at any time. (11,023 pounds) of UW (not by type) at any time. � Large quantity handlers � Large quantity handlers Large quantity handlers Large quantity handlers � Accumulates onsite more than 5,000 kilograms Accumulates onsite more than 5,000 kilograms (11,023 pounds) of UW (not by type) at any time. (11,023 pounds) of UW (not by type) at any time. ** do not confuse these categories with the ** do not confuse these categories with the hazardous waste generator categories hazardous waste generator categories g g g g (CESQGs, SQGs and LQGs) (CESQGs, SQGs and LQGs)
What about those What about those green-tipped lamps? � They still contain mercury They still contain mercury – – though not above though not above regulatory levels (.2 mg/L) regulatory levels (.2 mg/L) regulatory levels ( 2 mg/L) regulatory levels ( 2 mg/L) � We encourage recycling rather than disposal � We encourage recycling rather than disposal We encourage recycling rather than disposal We encourage recycling rather than disposal � If disposed must evaluate and retain � If disposed, must evaluate and retain If disposed must evaluate and retain If disposed, must evaluate and retain documentation for three years documentation for three years
Can I use a lamp crusher Can I use a lamp crusher to crush my lamps? � UWR prohibits handlers UWR prohibits handlers from crushing lamps from crushing lamps from crushing lamps from crushing lamps � If you crush your lamps, � If you crush your lamps If you crush your lamps If you crush your lamps, you must manage them you must manage them under the under the hazardous waste hazardous waste requirements requirements
What are the packaging What are the packaging requirements for UW lamps? � Must be designed to Must be designed to contain potential contain potential contain potential contain potential releases releases � Accidentally broken Accidentally broken y or damaged lamps or damaged lamps can be managed as can be managed as UW UW � Warning about Warning about mercury mercury…
What are the labeling requirements for UW lamps? � Must be clearly marked Must be clearly marked � “Universal Waste Lamps”; “Universal Waste Lamps”; Universal Waste Lamps ; Universal Waste Lamps ; “Waste Lamps”; or “Waste Lamps”; or “Used Lamps” “Used Lamps” � Be able to demonstrate Be able to demonstrate accumulation time accumulation time
How long can I accumulate my How long can I accumulate my UW lamps? � Up to one year on Up to one year on- -site site regardless of your handler regardless of your handler category category � If greater than one year is If greater than one year is required, you must be required, you must be able to prove why it is able to prove why it is bl bl t t h it i h it i necessary necessary
Am I required to notify Ohio EPA Am I required to notify Ohio EPA of my UW activities? � Small quantity handlers are NOT required to notify Small quantity handlers are NOT required to notify Ohio EPA or to obtain a U S EPA identification Ohio EPA or to obtain a U S EPA identification Ohio EPA or to obtain a U.S. EPA identification Ohio EPA or to obtain a U.S. EPA identification number number � Large quantity handlers are required to notify and Large quantity handlers are required to notify and obtain a U.S. EPA identification number obtain a U.S. EPA identification number obtain a U.S. EPA identification number obtain a U.S. EPA identification number (unless you already have one) (unless you already have one)
Must I manifest my UW lamps? Must I manifest my UW lamps? NO NO � UW handlers are not required to manifest their UW handlers are not required to manifest their q off- off -site shipments of UW site shipments of UW � UW handlers, however, must ensure delivery to UW handlers, however, must ensure delivery to another UW handler or to a permitted another UW handler or to a permitted destination facility destination facility
Can I transport my own Can I transport my own UW lamps? YES YES - deliver only to another UW handler, a UW deliver only to another UW handler, a UW y y transfer facility or to a permitted UW transfer facility or to a permitted UW destination facility destination facility - must follow all DOT requirements must follow all DOT requirements - responsible for spills and clean up responsible for spills and clean up
Can I take or send my lamps Can I take or send my lamps to any lamp recycler? No No UW handlers must UW handlers must ensure delivery to ensure delivery to ensure delivery to ensure delivery to another UW handler another UW handler or to a permitted or to a permitted or to a permitted or to a permitted destination facility destination facility
What are my recordkeeping What are my recordkeeping requirements? � No recordkeeping requirements for small quantity No recordkeeping requirements for small quantity handlers of UW handlers of UW � Large quantity handlers of UW must retain on Large quantity handlers of UW must retain on- - and off-site shipment records for at least three and off and off site shipment records for at least three and off site shipment records for at least three site shipment records for at least three years years � Name and address Name and address � Quantity of each type of UW Quantity of each type of UW � Date of shipment Date of shipment
Most Commonly Most Commonly Cited Violations
Most Commonly Cited Violations � Failure to evaluate your waste � Not filing your annual report correctly Not filing your annual report correctly � Not properly managing containers or maintaining Not properly managing containers or maintaining an inspection log an inspection log p p g g � Not testing or maintaining emergency equipment Not testing or maintaining emergency equipment g g g g g g y y q p q p � Not labeling used oil containers, tanks or fill pipes Not labeling used oil containers, tanks or fill pipes
Key Point With Waste Evaluation Don’t throw any Don’t throw any waste into the waste into the dumpster unless dumpster unless dumpster unless dumpster unless you have you have confirmed confirmed and and demonstrated demonstrated that it is that it is NOT NOT a a hazardous hazardous waste. waste.
Avoiding Annual Reporting Violations � Ohio Administrative Code rule Ohi Ohio Administrative Code rule 3745 Ohi Ad Ad i i t i i t ti ti C d C d l l 3745 3745 52 3745-52 52 41 52-41 41 41 � Due by March 1 � Due by March 1 Due by March 1 st Due by March 1 st st st � Only report hazardous waste; not universal waste or Only report hazardous waste; not universal waste or used oil used oil � Check accuracy and completeness � Check accuracy and completeness Check accuracy and completeness Check accuracy and completeness � Questions? Contact Tammy Heffelfinger at � Questions? Contact Tammy Heffelfinger at Questions? Contact Tammy Heffelfinger at Questions? Contact Tammy Heffelfinger at 614 614- -644 644- -2954 2954
Container Management � Ohio Administrative Code rules Ohio Administrative Code rules 3745 3745- -66 66- -73 and 3745 73 and 3745- -66 66- -74 74 � Keep containers closed while in storage Keep containers closed while in storage � Do not open, handle or store containers in a manner Do not open, handle or store containers in a manner that will cause them to rupture or leak that will cause them to rupture or leak � Conduct inspections of container storage areas, at Conduct inspections of container storage areas, at least weekly, looking for signs of leaks or least weekly, looking for signs of leaks or least weekly, looking for signs of leaks or least weekly, looking for signs of leaks or deterioration deterioration � Record inspections in a R R Record inspections in a log d i d i ti ti i i l log or summary or summary
Emergency Equipment Emergency Equipment � Ohio Administrative Code rule � Ohio Administrative Code rule Ohio Administrative Code rule 3745 Ohio Administrative Code rule 3745 3745-65 3745 65 65-33 65 33 33 33 � Alarm systems fire protection equipment spill � Alarm systems, fire protection equipment, spill Alarm systems fire protection equipment spill Alarm systems, fire protection equipment, spill control equipment and decontamination control equipment and decontamination equipment must be tested and maintained equipment must be tested and maintained as q p q p as necessary necessary to ensure proper operation in time of to ensure proper operation in time of emergency emergency � Record inspections in Record inspections in log log or or summary summary
Avoiding Used Oil Violations Avoiding Used Oil Violations � Ohio Administrati e Code Chapter � Ohio Administrative Code Chapter Ohio Administrati e Code Chapter 3745 Ohio Administrative Code Chapter 3745 3745 279 3745-279 279 279 � Labeling L b li L b li Labeling – “Used Oil” “Used Oil” “U “U d Oil” d Oil” � Do Do Not Not Label as “Waste Oil” or “Hazardous Waste” Label as “Waste Oil” or “Hazardous Waste” � Storage Storage – – Tanks or Containers Tanks or Containers � Releases Releases
Resources
E-Mail Updates E-Mail Updates � Permitting � Permitting Permitting Permitting � Enforcement Enforcement � Rules � Rules Rules Rules � General/Guidance General/Guidance � Annual Reports Annual Reports p � The The Notifier Notifier � Cessation of Regulated Operations (CRO) Cessation of Regulated Operations (CRO) g g p p ( ( ) ) News News www.epa.state.oh.us/ocapp/emailform.html www.epa.state.oh.us/ocapp/emailform.html t t t t h h / / / / ilf ilf ht ht l l
Answer Place Answer Place l � Search for answers to your questions Search for answers to your questions � Ask a question via e Ask a question via e- -mail mail � Automatically provides answers based on Automatically provides answers based on information in database information in database http://ohioepa.custhelp.com http://ohioepa.custhelp.com ttp //o ttp //o oepa cust e p co oepa cust e p co
Forms Lists and Checklists Forms, Lists and Checklists � Updated and current versions Updated and current versions � Includes Includes � Notification form (EPA 9029) Notification form (EPA 9029) � Annual Report Forms Annual Report Forms � Permit Application Forms Permit Application Forms � Permit Modification/Renewal Checklists Permit Modification/Renewal Checklists � Compliance Checklists Compliance Checklists � Universal Waste and Used Oil Forms Universal Waste and Used Oil Forms � CRO Forms CRO Forms www.epa.state.oh.us/dhwm/formslistchklist.html www.epa.state.oh.us/dhwm/formslistchklist.html
Publications, Guidance Documents, Fact Sheets � O � Organized alphabetically by topic O Organized alphabetically by topic i i d d l h b ti l h b ti ll ll b b t t i i � Each topic section offers information in different formats Each topic section offers information in different formats including: including: � U.S. EPA web based information U.S. EPA web based information � Guidance Documents � Guidance Documents Guidance Documents Guidance Documents � Notifier Articles Notifier Articles � Fact Sheets Fact Sheets � Recyclers Lists Recyclers Lists � Forms and Checklists Forms and Checklists www.epa.state.oh.us/dhwm/guideancedocs.html www.epa.state.oh.us/dhwm/guideancedocs.html
Guidance Documents Guidance Documents � Intended to cover information that pertains to a large � Intended to cover information that pertains to a large Intended to cover information that pertains to a large Intended to cover information that pertains to a large group of people group of people � Listed alphabetically Listed alphabetically � Most current and updated versions Most current and updated versions www.epa.state.oh.us/dhwm/guidancedocuments.html www.epa.state.oh.us/dhwm/guidancedocuments.html t t t t h h /dh /dh / / id id d d t t ht ht l l
Search Written Regulatory Interpretations � Written regulatory responses to questions Written regulatory responses to questions received received � Click on months for most recent Click on months for most recent correspondence correspondence www.epa.state.oh.us/dhwm/search.html www.epa.state.oh.us/dhwm/search.html
Recyclers Lists Recyclers Lists � DHWM’s Recyclers Lists available here: DHWM’s Recyclers Lists available here: � www.epa.state.oh.us/dhwm/guideancedocs.html# www.epa.state.oh.us/dhwm/guideancedocs.html# recycleList recycleList � Also available from OCAPP Also available from OCAPP � Ohio EPA s Office of Compliance Assistance and � Ohio EPA’s Office of Compliance Assistance and Ohio EPA’s Office of Compliance Assistance and Ohio EPA s Office of Compliance Assistance and Pollution Prevention Pollution Prevention � www epa state oh us/ocapp/p2/wastex html � www.epa.state.oh.us/ocapp/p2/wastex.html www epa state oh us/ocapp/p2/wastex html www.epa.state.oh.us/ocapp/p2/wastex.html
The Notifier The Notifier � DHWM’s quarterly newsletter DHWM’s quarterly newsletter � Available on the Web Available on the Web � Use the list Use the list- -serve to get updates serve to get updates www.epa.state.oh.us/dhwm/newsletter.html www.epa.state.oh.us/dhwm/newsletter.html
Ohio’s Hazardous Waste Rules Ohio s Hazardous Waste Rules � A ailable on o r Web page � Available on our Web page A ailable on o r Web page Available on our Web page � Most current and updated versions M M Most current and updated versions t t t t d d d t d d t d i i � Can access the Ohio Revised Code as well Can access the Ohio Revised Code as well as the Ohio Administrative Code as the Ohio Administrative Code www.epa.state.oh.us/dhwm/laws_regs.html www.epa.state.oh.us/dhwm/laws_regs.html
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