An Overview of Ohios An Overview of Ohios Hazardous Waste - PowerPoint PPT Presentation

P or U Listed Hazardous Wastes  Must be an Must be an unused unused commercial chemical product commercial chemical product  Examples of P listed hazardous wastes: Examples of P listed hazardous wastes:  Copper cyanide  Copper cyanide Copper cyanide – P029 Copper cyanide – P029 P029 P029  Phosgene Phosgene – – P095 P095  Examples of U listed hazardous wastes: Examples of U listed hazardous wastes:  Creosote Creosote – – U051 U051  Lindane shampoo Lindane shampoo – – U129 U129

Steps To Properly Steps To Properly Evaluate Your Waste rd – Determine if your waste exhibits a 3 rd Determine if your waste exhibits a characteristic characteristic characteristic characteristic

Characteristic Hazardous Wastes 4 categories of characteristic hazardous wastes: 4 categories of characteristic hazardous wastes:  Ignitable Ignitable - - OAC rule OAC rule 3745 3745- -51 51- -21 21  Corrosive Corrosive - - OAC rule OAC rule 3745 3745- -51 51- -22 22  Reactive Reactive - - OAC rule OAC rule 3745 3745- -51 51- -23 23  Toxic Toxic - - OAC rule OAC rule 3745 3745- -51 51- -24 24

Ignitable Hazardous Wastes D001 waste code  A  Aqueous solution & flash point <140 F (except solution A Aqueous solution & flash point <140 F (except solution l ti l ti & fl & fl h h i t <140 F ( i t <140 F ( t t l ti l ti <24% alcohol) <24% alcohol)  Flammable compressed gas Flammable compressed gas  Solid that spontaneously ignites & burns vigorously  Solid that spontaneously ignites & burns vigorously Solid that spontaneously ignites & burns vigorously Solid that spontaneously ignites & burns vigorously  Oxidizer as defined DOT rules Oxidizer as defined DOT rules  Examples include: Examples include:  Solvents/degreasers S l S l Solvents/degreasers t /d t /d  Magnesium swarf Magnesium swarf

Corrosive Hazardous Wastes D002 waste code  Aqueous solution; pH < 2 or pH > 12.5 Aqueous solution; pH < 2 or pH > 12.5  Liquid that corrodes steel at a specified rate Liquid that corrodes steel at a specified rate  Examples include: Examples include:  Acids Acids  Alkaline cleaning fluids Alkaline cleaning fluids  Waste battery acids Waste battery acids

Reactive Hazardous Wastes D003 waste code  Explosive, unstable, reacts violently with water or Explosive, unstable, reacts violently with water or generates toxic gas generates toxic gas generates toxic gas generates toxic gas  Examples include:  Examples include: Examples include: Examples include:  Dynamite Dynamite  Waste bleaches  Waste bleaches Waste bleaches Waste bleaches

Toxic Hazardous Wastes D004 –D043 waste codes  Contain toxic constituents above regulatory levels Contain toxic constituents above regulatory levels  8 metals; 32 organics 8 metals; 32 organics  D t  Determined by D t Determined by Toxicity Characteristic Leaching Procedure i i d b d b T T Toxicity Characteristic Leaching Procedure i it Ch i it Ch t t i ti L i ti L hi hi P P d d (TCLP) (TCLP)  Examples include: Examples include:  Electronic equipment, nutrient supplements Electronic equipment, nutrient supplements Spent foundry sand, clay poker chips, Spent foundry sand, clay poker chips, insecticides insecticides

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? Determine your business Not a hazardous Not a hazardous Yes Yes h has created a waste. t d t waste . I t is excluded? No No Does the waste D h You have a I s the waste on Ohio have any listed Yes hazardous EPA’s F, K, P or U hazardous waste lists? waste characteristics? characteristics? No Yes Does the waste have any Yes Yes You have a listed You have a listed hazardous waste and characteristic characteristics? hazardous waste You have a No characteristic characteristic Not a hazardous hazardous waste waste

Generator Categories i C t t G

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 (SQGs); and Small Quantity Generators (SQGs); and  Large Quantity Generators (LQGs). Large Quantity Generators (LQGs).

Determining Your Category g g y  Total weight of hazardous waste that the entire facility Total weight of hazardous waste that the entire facility generates (produces) in any given month of the generates (produces) in any given month of the generates (produces) in any given month of the generates (produces) in any given month of the calendar year; calendar year;  For example: Hazardous waste that you generate For example: Hazardous waste that you generate st and October 31 between October 1 st 1 t and October 31 st 31 t st b t b t between October 1 O t b O t b 1 d O t b d O t b 31 AND AND  Total amount of hazardous waste on Total amount of hazardous waste on- -site at any given site at any given ti time (only pertains to CESQGs and SQGs) time (only pertains to CESQGs and SQGs) ti ( ( l l t i t i t t CESQG CESQG d SQG ) d SQG ) NOTE: NOTE: Generator categories are NOTE: NOTE: Generator categories are Generator categories are NOT Generator categories are NOT NOT determined by the NOT determined by the determined by the determined by the weight of waste shipped off weight of waste shipped off- -site or by averaging. site or by averaging.

Determining Your Category Cont. Determining Your Category Cont. OAC rule OAC rule 3745 3745- -51 51- -05 05 – Special requirements for Special requirements for hazardous waste generated by conditionally hazardous waste generated by conditionally exempt small quantity generators. exempt small quantity generators.

Conditionally Exempt Small Quantity Generators (CESQGs) Y You are a You are a CESQG if you: CESQG if CESQG if CESQG if you:  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 in a calendar waste in a calendar month month; ; AND  never accumulate more than 2,200 pounds of hazardous waste on your property y y Note: 220 pounds is about Note: 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 five 2 200 pounds is about 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 SQG until that HW you become an SQG until that HW is moved off is moved off- -site site

Small Quantity Generators (SQGs) You are an SQG if you: You are an SQG 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, or you will become site, or you will become subject to permitting subject to permitting

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 until that hazardous waste is LQG 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) and must have a hazardous waste installation (TSDF) and must have a hazardous waste installation and operation and operation permit permit

Large Quantity Generators (LQGs) You are an LQG if you: You are an LQG 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 the amount of LQGs do not have a limit on the amount of h hazardous waste stored on- hazardous waste stored on h d d t t t t d d -site site it it

What If I Change Generator Categories?  Often termed Often 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

Generator Requirements t i R t G

Determining Your Generator Determining Your Generator Requirements  CESQGs follow OAC rule 3745-51-05(F) th through (J) h (J)  SQGs and LQGs follow OAC SQG d LQG f ll OAC Chapter 3745-52 (which references other rules) l )

Generator Requirements Generator Requirements Summary Table  Management requirements  OAC references  CESQG, SQG, or LQG compliance requirement Q , Q , Q p q  DHMW has a Web-page on Hazardous Waste  DHMW has a Web page on Hazardous Waste Generator Requirements

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?  US EPA Form 9029 from DHWM’s Web site or call  US EPA Form 9029 from DHWM s Web site or call (614) 644-2977 - Notification of Regulated Waste Activity Booklet  Form and instructions  Form and instructions  Revised in 2009 – always use most current form  Mail the completed and signed original EPA form 9029  Mail the completed and signed original EPA form 9029 to: Ohio EPA – DHWM Regulatory and Information Services P.O. Box 1049 Columbus Ohio 43216 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 Satellite Accumulation?  Satellite accumulation – term for the temporary storage of hazardous waste near where it is g generated  Found in OAC rule 3745-52-34(C)  Only applies to SQGs and LQGs  Use of this rule reduces some regulatory g y requirements for storage areas  Satellite Accumulation Guidance Document

What Requirements Apply to Satellite Accumulation Areas?  Up to 55 gallons of hazardous waste 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., 90/180 day area) within area (i.e., 90/180 day area) within three days three days of of the date that you place on the container the date that you place on the container  Begin complying with the B B Begin complying with the SQG i i l i l i ith th ith th SQG or SQG SQG or LQG LQG hazardous LQG h LQG hazardous h d d waste accumulation requirements waste accumulation requirements  Place new date on container when it arrives at central  Place new date on container when it arrives at central Place new date on container when it arrives at central Place new date on container when it arrives at central accumulation area (start of 90/180 day timeframe) accumulation area (start of 90/180 day timeframe)

What is Treatment? What is Treatment?  Defined in OAC rule Defined in OAC rule 3745 3745- -50 50- -10(A)(125) 10(A)(125)  Treatment  Treatment Treatment - any method, technique or process, Treatment any method, technique or process, any method technique or process any method technique or process designed to: designed to:  render waste non render waste non- -hazardous hazardous  less  less less hazardous less-hazardous hazardous hazardous  safer to transport, store or dispose of safer to transport, store or dispose of  amenable for recovery amenable for recovery  amendable for storage amendable for storage d bl d bl f f t t   reduced in volume reduced in volume  Generator Treatment Guidance Document Generator Treatment Guidance Document

May I Treat My Hazardous Waste On-site?  Many forms allowed by generators without a hazardous waste permit:  Neutralization  Neutralization  Polymerization  Stabilization  Wastewater treatment  W t t t t t  Forms not allowed by generators include:  Thermal treatment (incineration, certain evaporators) e a t eat e t ( c e at o , ce ta e apo ato s)  Land disposal (surface impoundments, landfills)  Consult with us if you wish to treat your hazardous waste waste

Tanks vs. Containers Tanks vs. Containers  OAC rule OAC rule 3745 3745- -50 50- -10 10 defines these units defines these units  A A container container is any is any portable device y p portable device in which a in which a material is stored, transported, treated, disposed material is stored, transported, treated, disposed of or otherwise handled. of or otherwise handled.  A A tank tank is a is a stationary device stationary device , designed to contain , designed to contain an accumulation of hazardous waste, which is an accumulation of hazardous waste, which is constructed primarily of non constructed primarily of non- t t t d t d i i il il f f -earthen materials earthen materials th th t t i l i l (wood, concrete, steel, plastic) that provides (wood, concrete, steel, plastic) that provides structural support structural support structural support. structural support.

What Are The Container What Are The Container Management Requirements? Management Requirements?  Found in OAC rules Found in OAC rules 3745 3745 3745-66 3745 66 66-70 66 70 70 through 70 through through 3745 through 3745 3745-66 3745 66 66 77 66-77 77 77  They only apply to  They only apply to They only apply to SQGs They only apply to SQGs SQGs and SQGs and and LQGs and LQGs LQGs LQGs  though not required, these preventative measures are good for CESQGs to follow g

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  Visibly labeled as “Hazardous Waste” Visibly 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 (as part of Preparedness and Prevention)  Ignitable/reactive located 15 meters (50 feet) from facility’s property line  U.S. EPA air emission standards (i.e. AA, BB, U S EPA i i i t d d (i AA BB CC) (LQGs only)

What Are The Tank Management What Are The Tank Management Requirements? Requirements?  They only apply to  The onl appl to The onl appl to SQGs They only apply to SQGs SQGs and SQGs and and LQGs and LQGs LQGs LQGs  though not required, these preventative measures are good for CESQGs to follow are good for CESQGs to follow  Found in OAC rules  Found in OAC rules Found in OAC rules Found in OAC rules 3745 3745- -66 66- -90 90 through through 3745 3745- -66 66- -101 101  Large Quantity Generator Tank System Requirements Requirements

What Are The SQG Tank What Are The SQG Tank Management Requirements? Management Requirements?  Be able to show  Be able to show Be able to show - emptied/overturned once every 180 days Be able to show emptied/overturned once every 180 days emptied/overturned once every 180 days emptied/overturned once every 180 days  OAC rule OAC rule 3745 3745- -66 66- -101 101 specific to SQGs specific to SQGs  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”  Daily inspections (rule specifies) Daily inspections (rule specifies)  R  Remove all hazardous waste from site when facility closes R Remove all hazardous waste from site when facility closes ll h ll h d d t t f f it it h h f f ilit ilit l l

What Are The LQG Tank What Are The LQG Tank M M Management Requirements? Management Requirements? t R t R i i t ? t ?  Be able to show Be able to show - - emptied/overturned once emptied/overturned once p every 90 days every 90 days  Good condition Good condition  Compatible with waste and area Compatible with waste and area  Labeled as “Hazardous Waste” Labeled as “Hazardous Waste”  Daily inspections Daily inspections

What Are The LQG Tank What Are The LQG Tank Management Requirements? Management Requirements?  Secondary containment Secondary containment  Leak detection system Leak detection system  Tank system assessment/certification Tank system assessment/certification  Closure Closure Cl Cl  U.S. EPA air emission standards (i.e. AA, BB, CC) U S EPA i i i t d d (i AA BB CC)

What Am I Required To Do When I What Am I Required To Do When I Ship My HW Off Ship My HW Off- -site? site? Found in OAC rules 3745-52-30 to 3745-52-33 CESQGs are not required to prepare a manifest SQGs and LQGs must prepare manifest and SQG d LQG t if t d  Package your HW  Label each package of HW  Label each package of HW  Mark each package of HW  Placard or offer the initial transporter the appropriate p pp p placards  Contact Public Utilities Commission of Ohio for more i f information (800-686-7826) ti (800 686 7826)

Does My Business Need Does My Business Need P P Personnel Training? Personnel Training? l T l T i i i i ? ?  OAC rules OAC rules 3745 3745- -65 65- -16 16 and and 3745 3745- -52 52- -34 34  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 must  ensure that all employees are thoroughly familiar with  ensure that all employees are thoroughly familiar with ensure that all employees are thoroughly familiar with ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures proper waste handling and emergency procedures  LQGs LQGs must must  conduct classroom instruction or on conduct classroom instruction or on- -the the- -job personnel job personnel training for facility employees training for facility employees  conduct annual refreshers  conduct annual refreshers conduct annual refreshers conduct annual refreshers  maintain documentation of personnel training maintain documentation 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 and SQGs SQGs and SQGs and LQGs and LQGs LQGs must: LQGs must: 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 Test and maintain your emergency equipment and record the inspections in a log record the inspections in a log record the inspections in a log record the inspections in a log  Maintain adequate aisle space Maintain adequate aisle space  Movement of personnel and emergency response equipment Movement of personnel and emergency response equipment p p g g y y p p q q p p  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  SQGs  SQGs SQGs and SQGs and and LQGs and LQGs LQGs must keep a copy of the LQGs must keep a copy of the must keep a copy of the must keep a copy of the following for at least 3 years: following for at least 3 years:  Test results  Test results Test results Test results  Waste evaluation Waste evaluation  CESQG must be able to show that they CESQG must be able to show that they evaluated their waste evaluated their waste

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  Revised form Revised form – – US EPA has info where to get them US EPA has info where to get them  Found in OAC rules F F Found in OAC rules 3745 d i d i OAC OAC l l 3745 3745 52 3745-52 52 20 52-20 20 t 20 to to 3745 3745-52 3745 3745 52 52 23 52-23 23 23  Only Only SQGs SQGs and and LQGs LQGs must manifest their HW must manifest their HW  E  Each person who transports, stores, treats or h h disposes must sign & retain a copy  Must receive signed copy of your manifest from the  Must receive signed copy of your manifest from the final destination facility  Each transporter must have a copy for their 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

Rejected Loads Rejected Loads  A shipment of hazardous waste that cannot be A shipment of hazardous waste that cannot be accepted because: accepted because:  Facility permit restriction, or  Facility permit restriction or Facility permit restriction or Facility permit restriction, or  Capacity limitations Capacity limitations  Includes all shipments in whole or in part regardless Includes all shipments in whole or in part regardless whether the manifest has been signed whether the manifest has been signed  Generators Generators can store rejected loads or residues sent can store rejected loads or residues sent back to them for 90 or 180 days depending on the back to them for 90 or 180 days depending on the back to them for 90 or 180 days depending on the back to them for 90 or 180 days depending on the amount of hazardous waste on amount of hazardous waste on- -site during the site during the calendar month the rejected load/residue was calendar month the rejected load/residue was received received i i d d

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 SQGs SQGs and and LQGs LQGs  Standards developed to ensure that toxic constituents Standards developed to ensure that toxic constituents present in hazardous waste are properly treated before present in hazardous waste are properly treated before land disposal land disposal  Land Disposal Restrictions (An Overview)  Land Disposal Restrictions (An Overview) Land Disposal Restrictions (An Overview) Land Disposal Restrictions (An Overview)

Land Disposal Restrictions Land Disposal Restrictions Treatment Standards Treatment Standards  Given as treatment technology or numeric level  Specified for all listed and characteristic hazardous wastes hazardous wastes  Must be met prior to hazardous waste being M t b t i t h d t b i land disposed

Land Disposal Restrictions Land Disposal Restrictions Land Disposal Restrictions Land Disposal Restrictions Regulatory Status of Treated Regulatory Status of Treated Hazardous Waste Hazardous Waste  Treated Treated listed listed hazardous wastes hazardous wastes must still be must still be managed managed & & disposed of under hazardous disposed of under hazardous waste waste rules t rules l l  T  Treated T Treated characteristic t d t d h characteristic hazardous wastes h t t i ti h i ti h hazardous wastes are d d t t are no longer defined as no longer defined as hazardous wastes hazardous wastes  Disposal regulated under non Disposal regulated under non-hazardous waste Disposal regulated under non Disposal regulated under non hazardous waste hazardous waste hazardous waste program program

Land Disposal Restrictions Land Disposal Restrictions Land Disposal Restrictions Land Disposal Restrictions General Requirements General Requirements  Waste Waste analysis plan analysis plan (if (if hazardous waste hazardous waste is treated to is treated to meet LDRs) meet LDRs)  Notification requirements Notification requirements  Verification of treatment Verification of treatment  Recordkeeping R R Recordkeeping dk dk i i  Certification Certification  If not subject to LDRs keep record as to why not If not subject to LDRs keep record as to why not  WWTP elementary neutralization metals recovery  WWTP, elementary neutralization, metals recovery… WWTP elementary neutralization metals recovery WWTP, elementary neutralization, metals recovery…

Must I File an Annual Report? Must I File an Annual Report? p  OAC rule OAC rule 3745 3745- -52 52- -41 41  Only Only LQGs LQGs file annual reports file annual reports  Includes episodic generators who became LQGs Includes episodic generators who became LQGs  Report provides Ohio EPA and U S EPA with  Report provides Ohio EPA and U.S. EPA with data concerning your facility’s hazardous waste generation, management and waste minimization activities i i i ti ti iti  Due by March 1 st  Due by March 1 st

LAMPS AND BATTERIES LAMPS AND BATTERIES LAMPS AND BATTERIES LAMPS AND BATTERIES Can I throw them in the trash? Can I throw them in the trash?

What’s the big deal about What’s the big deal about What s the big deal about What s the big deal about fluorescent lamps and batteries? fluorescent lamps and batteries?  The evils of mercury The evils of mercury  Other goodies in lamps  Other goodies in lamps Other goodies in lamps Other goodies in lamps  A broken lamp means escaped mercury A broken lamp means escaped mercury  Different types of batteries contain different Diff Diff Different types of batteries contain different t t t t f b tt f b tt i i t i t i diff diff t t chemicals chemicals

What’s in those batteries? What’s in those batteries?  Single use alkaline Single use alkaline  Zinc, Manganese Dioxide Zinc, Manganese Dioxide and Potassium Hydroxide and Potassium Hydroxide  Rechargeable Rechargeable  Nickel Cadmium, Nickel Metal Hydride, Nickel Cadmium, Nickel Metal Hydride, Lithium Ion, Lead Acid and Small Sealed Lead Lithium Ion, Lead Acid and Small Sealed Lead

So can I throw them in the trash? So can I throw them in the trash? So can I throw them in the trash? So can I throw them in the trash?  Mercury, cadmium and lead in lamps and batteries Mercury, cadmium and lead in lamps and batteries often make them hazardous waste often make them hazardous waste  You’ll have to evaluate them to be sure they aren’t You’ll have to evaluate them to be sure they aren’t hazardous hazardous hazardous hazardous  You can use reliable data  You can use reliable data You can use reliable data You can use reliable data supplied by others or have supplied by others or have them tested them tested them tested them tested

Is there an alternative to throwing Is there an alternative to throwing Is there an alternative to throwing Is there an alternative to throwing them in the trash? them in the trash?  Mercury, glass and metal in lamps can be Mercury, glass and metal in lamps can be recovered and recycled recovered and recycled recovered and recycled recovered and recycled  Metals in hazardous and non Metals in hazardous and non- -hazardous hazardous batteries can be recovered and used in batteries can be recovered and used in new batteries and making steel new batteries and making steel

What do I need to do if I recycle? What do I need to do if I recycle? What do I need to do if I recycle? What do I need to do if I recycle?  Choice of complying with more complicated Choice of complying with more complicated hazardous waste rules or the simpler hazardous waste rules or the simpler p universal waste rules universal waste rules  No hazardous waste regulations to comply No hazardous waste regulations to comply with if the waste isn’t hazardous with if the waste isn’t hazardous with if the waste isn t hazardous with if the waste isn t hazardous

Universal Waste Management Universal Waste Management System System  Designed to encourage collection and recycling Designed to encourage collection and recycling of wastes from wide variety of sources including of wastes from wide variety of sources including households and small businesses households and small businesses  Includes wastes that pose low hazards Includes wastes that pose low hazards  Wastes can be safely managed under less Wastes can be safely managed under less restrictive rules than other hazardous wastes restrictive rules than other hazardous wastes

What is the Universal Waste What is the Universal Waste R l ? R l ? Rule? Rule?  Streamlined hazardous waste management St Streamlined hazardous waste management St li li d h d h d d t t t t system system  For widely generated hazardous wastes For widely generated hazardous wastes  Currently hazardous lamps, batteries, Currently hazardous lamps, batteries, recalled pesticides and thermostats can be recalled pesticides and thermostats can be universal wastes (UW) in Ohio universal wastes (UW) in Ohio

Where can I find the rules? Where can I find the rules?  Ohio Administrative Code (OAC) chapter Ohio Administrative Code (OAC) chapter 3745 3745- - 273 273 Small handler rules are OAC rules 3745 rules are OAC rules 3745- -273 273- -10 10  Small handler th th through 3745 through 3745-273 h 3745 h 3745 273 273-20 273 20 20 20 Large handler rules are OAC rules 3745 Large handler rules are OAC rules 3745 rules are OAC rules 3745-273 rules are OAC rules 3745 273 273 30 273-30 30 30  Large handler  Large handler through 3745 through 3745- -273 273- -40 40

Universal Waste Requirements Universal Waste Requirements Universal Waste Requirements Universal Waste Requirements  Do not have to count UW toward hazardous  Do not have to count UW toward hazardous Do not have to count UW toward hazardous Do not have to count UW toward hazardous waste generator status waste generator status Small Quantity Handler of UW if you accumulate of UW if you accumulate  Small Quantity Handler less than 11000 lbs. of UW (collectively) at any less than 11000 lbs. of UW (collectively) at any ti ti time time Large Quantity Handler of UW if you accumulate Large Quantity Handler of UW if you accumulate of UW if you accumulate of UW if you accumulate  Large Quantity Handler  Large Quantity Handler 11000 lbs. or more of UW waste at any time 11000 lbs. or more of UW waste at any time

Small Handlers Small Handlers  Must send UW to another handler or a destination facility Must send UW to another handler or a destination facility  Can receive and accumulate UW from other handlers Can receive and accumulate UW from other handlers  Cannot dispose, dilute or treat except as specified in rule Cannot dispose, dilute or treat except as specified in rule for each type of UW f f for each type of UW f f  Not required to notify and get an ID number  Not required to notify and get an ID number Not required to notify and get an ID number Not required to notify and get an ID number

Small Handler Small Handler  Label or mark the UW (or container) to identify type of UW  Label or mark the UW (or container) to identify type of UW Label or mark the UW (or container) to identify type of UW Label or mark the UW (or container) to identify type of UW as specified in OAC rule 3745 as specified in OAC rule 3745- -273 273- -14 14  Manage UW to prevent releases to environment Manage UW to prevent releases to environment  Must keep records to demonstrate how long UW has been Must keep records to demonstrate how long UW has been accumulated; accumulate accumulated; accumulate < < 1 year 1 year  Inform employees of proper handling and emergency Inform employees of proper handling and emergency procedures procedures p

Small Handler Small Handler  Contain releases from UW Contain releases from UW  Determine if material from spill cleanup is hazardous Determine if material from spill cleanup is hazardous waste waste waste waste - - if so properly manage it if so properly manage it if so properly manage it if so properly manage it  Must follow DOT rules for shipping UW (e.g., proper Must follow DOT rules for shipping UW (e.g., proper pp g pp g ( ( g , p g , p p p package, label, mark, placard, shipping papers) package, label, mark, placard, shipping papers)  Must make sure receiving handler agrees to accept UW Must make sure receiving handler agrees to accept UW  No tracking requirements  No tracking requirements No tracking requirements No tracking requirements

Large Handler Large Handler Large Handler Large Handler Must comply with small handler requirements and; Must comply with small handler requirements and; p y p y q q ; ;  Notify and obtain an ID number if no previous Notify and obtain an ID number if no previous Notify and obtain an ID number if no previous Notify and obtain an ID number if no previous notification notification  Keep shipping and receipt records for three Keep shipping and receipt records for three years years  Ensure that employees are familiar with proper Ensure that employees are familiar with proper p y p y p p p p handling and emergency procedures handling and emergency procedures

Can I crush my lamps? Can I crush my lamps? Can I crush my lamps? Can I crush my lamps?  You cannot crush your lamps and still comply with Y Y You cannot crush your lamps and still comply with t t h h l l d till d till l l ith ith the universal waste rules the universal waste rules  You can crush your lamps if you comply with full You can crush your lamps if you comply with full hazardous waste rules, e.g., hazardous waste rules, e.g., , , g , g ,  Hazardous waste generator requirements Hazardous waste generator requirements  Manifest Manifest  Send directly to a permitted facility Send directly to a permitted facility

Can I Can I throw Can I Can I throw throw green tip lamps in throw green tip lamps in green tip lamps in green tip lamps in the trash? the trash?  Must evaluate lamps Must evaluate lamps  Must keep evaluation documents Must keep evaluation documents  You can have representative sample of lamps You can have representative sample of lamps analyzed for TCLP metals or use reliable up analyzed for TCLP metals or use reliable up- - to to date manufacturer’s data as all or part of to to-date manufacturer s data as all or part of date manufacturer’s data as all or part of date manufacturer s data as all or part of your evaluation your evaluation

Why recycle green tip lamps? Why recycle green tip lamps? Why recycle green tip lamps? Why recycle green tip lamps?  Keeps mercury from being released to Keeps mercury from being released to environment environment  Conserves resources Conserves resources - - glass, metals glass, metals  Preferred management method in Ohio for Preferred management method in Ohio for g mercury mercury- -containing lamps containing lamps  No need to evaluate them No need to evaluate them

DOT rules for batteries DOT rules for batteries  Batteries destined for recycling need to be Batteries destined for recycling need to be properly packaged per properly packaged per DOT rules DOT rules  Batteries present a fire hazard if they short circuit Batteries present a fire hazard if they short circuit  Terminals must be taped, or batteries placed in Terminals must be taped, or batteries placed in p p , , p p individual bags or original containers individual bags or original containers

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  OAC rule OAC OAC OAC rule 3745 l l 3745-52 3745 52 3745 52 41 52-41 41 41 Due by March 1 st Due by March 1 st st st  Due by March 1  Due by March 1  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 Mary Ann  Questions? Contact Mary Ann Questions? Contact Mary Ann Silagy Questions? Contact Mary Ann Silagy Silagy at Silagy at at at 614 614- -644 644- -2891 2891

Container Management  OAC rules OAC 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 Do not open, handle or store containers in a manner that will cause them to rupture or leak manner that will cause them to rupture or leak  Conduct inspections of container storage Conduct inspections of container storage areas at least weekly looking for signs of areas at least weekly looking for signs of areas, at least weekly, looking for signs of areas, at least weekly, looking for signs of leaks or deterioration leaks or deterioration  Record inspections in a Record inspections in a log log or summary or summary

Emergency Equipment Emergency Equipment  OAC rule  OAC rule OAC rule 3745 OAC 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  OAC Chapter  OAC Chapter OAC Chapter 3745 OAC Chapter 3745 3745-279 3745 279 279 279  Labeling Labeling – “Used Oil” L b li L b li “U “Used Oil” “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 – – Be sure to address Be sure to address

Resources