Workshop D Sustainability/RCRA Permitting Best Practices … Benefiting from Ohio’s New Specific Universal Waste Rule Wednesday, July 25, 2018 1 p.m. to 2:30 p.m.
Biographical Information Tim W. McDaniel, CIH, CSP, EHS Manager, Navistar, Inc. 6125 Urbana Rd., Springfield, OH 45502 937-390-4024 Tim.mcdaniel@navistar.com Tim started his career with the Regional Air Pollution Control Agency in Dayton, Ohio in 1985 as an inspector and permit writer. After two years he went to work at Navistar, first as a contract consultant and then with Navistar full-time in 1989. He was promoted to Environmental Manager and then EHS Manager. During this time Navistar has received awards from US EPA and Ohio EPA for pollution prevention. The Springfield Assembly Plant has been registered to ISO 14001 since 2003. Tim’s current responsibilities include ISO 14001, regulatory participation in Ohio and environmental management at the Springfield Assembly Plant. He also serves on the Clark County Solid Waste Management District Policy Committee and the Clark County LEPC. Tim is a graduate of Eastern Kentucky University with a B.S. In Environmental Resources and he received both an MS and MA from Indiana University in Environmental Science and Ecology, respectively. Christa Oerly Russell, Senior Engineer, Trinity Consultants Trinity Consultants, 5829 Haverford Avenue, Indianapolis, IN 46220 317-695-4644 crussell@trinityconsultants.com Christa has more than 39 years of experience in environmental compliance, regulatory permitting, solid and hazardous waste management, and in industrial coatings and cement manufacturing. Christa began her environmental career in 1979 with Missouri DNR in air permitting and expanded her regulatory experience with IDEM working predominantly in solid and hazardous waste permitting and compliance. Christa’s regulatory experience was followed in 1991 by a position as corporate Manager of Environmental Affairs for an industrial coatings manufacturer and included multimedia compliance responsibilities for 26 manufacturing facilities in the U.S. and Canada. In 1998 Christa joined Lone Star Cement Company as corporate Director of Environmental Compliance with compliance responsibilities for multiple cement plants and terminals. During her time in industry, Christa was also active in numerous industry work groups, including participation on several cement industry and coatings industry association committees. Christa served for several years as a Director on the Board of the Indiana Air and Waste Management Association as Programs Committee Chair. Christa joined Schreiber Yonley & Associates (SYA) in 2004 as a Senior Engineer working primarily with air permitting and emissions control technology evaluations for the cement industry and performing multimedia audits and providing assistance with RCRA compliance. SYA became part of Trinity Consultants in 2014 Christa has a Bachelor of Science degree in Chemical Engineering from the University of Missouri. Mitch Mathews, Manager, Haz. Waste Compliance, Ohio EPA PO Box 1049, Columbus, OH 43216-1049 614-644-2953 mitchell.mathews@epa.ohio.gov Mitch is the Manager for Hazardous Waste Compliance for the Ohio EPA, Division of Environmental Response and Revitalization (DERR). DERR oversees investigation and cleanup of contaminated sites; permitting, inspection, compliance and reporting of hazardous waste sites; and provides assistance and guidance for the voluntary cleanup and reuse of brownfield sites.
Ohio-Specific Universal Wastes
Ohio-Specific Universal Wastes Mitch Mathews Hazardous Waste Program, Ohio EPA June 13, 2018 Mitchell.mathews@epa.ohio.gov
Webinar Segments Advantages of Universal waste program Brief overview of the Universal Waste (UW) standards Issues of confusion Question and answer session
Universal Waste Rules General - Advantages Promotes the proper disposal of the designated wastes UWs do not count toward a generator’s monthly HW generation rate Generator is not required to determine if UW is a hazardous waste (assumption is that the waste is hazardous) Recycling of UW is encouraged (but not required) No hazardous waste manifesting required in Ohio
Universal Waste Rule Ohio-specific wastes Non-empty aerosol containers Antifreeze Paint Paint-related wastes
Ohio-Specific Universal Wastes Definitions Aerosol containers: • non-openable and non-refillable; holds substance under pressure; uses propellant gas to deliver a product; does not include gas cylinders Antifreeze: • Ethylene or propylene glycol used in heat transfer equipment or to winterize equipment
Ohio-Specific Universal Wastes Definitions Paint : • Pigment or unpigmented powder coating • Pigmented/unpigmented mixture of binder and suitable liquid • Generated from commercial, industrial, mining, agricultural and post-consumer activities • Forms an adhering coating on a surface upon drying or through the use of heat Intended to include products commonly known as paint that are used to decorate, protect, convey a design or image and applied in a very thin coat
Ohio-Specific Universal Wastes Definitions Substances that are NOT paint – Adhesives – Stucco/cement based coatings – Geotextiles and geomembranes – Surface leveling products – Insulation products – Spray foams – Petroleum asphalt products – Ingredients used to make paint (solvent, binder, pigment/colorant, part A epoxy, part B hardener)
Ohio-Specific Universal Wastes Definitions Paint-related Wastes: • A material legitimately contaminated with paint • Produced from packaging of paint, wholesale/retail operations, paint manufacturing, paint application and removal activities • Wastes that are NOT paint-related wastes – Demolition debris – Ingredients used to make paint (solvent, binder, pigment/colorant, part A epoxy, part B hardener) – Spill cleanup materials
Universal Waste Entities General Overview Small quantity handler UW (SQHUW) – Generates or stores <5000 kg of UW (total) Large quantity handler UW (LQHUW) – Generates or stores >5000 kg of UW (total) UW Transporter Destination facility – Is a permitted HW facility and treats UW in a way other than allowed under the handler rules
Universal Waste UW Management Provisions Tank & container standards Labeling requirement Accumulation time limit up to one-yr Training requirement Spill cleanup requirement Notification requirement LQHUW/destination facility Tracking requirement for LQHUWs/destination facility Transportation per DOT requirements Waste specific management standards
Antifreeze Develop written procedure to prevent commingling w/ other wastes Use dedicated collection and storage units Antifreeze, subsequent to generation, mixed w/used oil is classified as a used oil Handlers can recycle antifreeze
Aerosol Containers UW Satellite accumulation area for aerosol containers Handler may puncture, drain & crush aerosol containers Contents removed from containers is not a universal waste and must be evaluated to determine whether it is HW – please recycle container
Paint & paint-related wastes Handler may puncture, drain & crush containers of paint – Collected paint is still a universal waste Any handler can recycle UW paint waste Only the handler that generated UW paint-related wastes can reclaim the paint-related wastes on-site (e.g., spent solvent contaminated with paint) – Residual from reclamation is not a UW; determine if waste is a HW – it may be listed HW
Issues of Confusion
Issues of Confusion UWs are a unique group of hazardous wastes subject to less burdensome generator and transporter requirements The universal waste program is an optional regulatory program If the waste is not hazardous waste, it is not required to be managed as a hazardous waste or a universal waste
Issues of Confusion UW is classified as hazardous waste at the destination facility where the waste is treated & subject to full regulation under the hazardous waste rules LDRs apply to the treatment of UWs; destination facility will likely ask handler for waste information A destination facility may also be a handler – Storage or treatment per UW rules of incoming waste = handler – Treatment of waste = destination facility
Issues of Confusion Listed hazardous waste codes may apply to treatment residuals of certain UWs Use manifest for Ohio-specific UWs shipped out of Ohio and designated as HW in receiving state – Note waste is UW on line #14 of manifest – Michigan has UW antifreeze Move UW satellite accumulation container of aerosol cans to central collection area when full and date container; one year time period begins
Issues of Confusion Aerosol containers are not categorically designated a D003 in Ohio Aerosol cans of paint can be a UW aerosol container or UW paint waste How can Ohio adopt less stringent rules as compared to U.S. EPA?
Federal & State Rule Updates • Ohio Rulemaking – E-manifest rules – Generator Improvements rules – Contaminated Apparel and Wipes rule • Federal Rulemaking – UW aerosol can rule – Ignitability Characteristic (new ASTM method) – Pharmaceutical rule (final) – Definition of Solid Waste (aka - hazardous waste recycling rules)
Information Resources Hazardous Waste Compliance Assurance and Inspection Support Section (614) 644-2924. Guidance document and Question & Answer document http://epa.ohio.gov/derr/hazwaste/universalwaste
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