Hazardous Waste Issues
Associated with
Municipal Operations
September 25, 2014
Dan Sowry
Environmental Specialist
Office of Compliance Assistance and Pollution
Prevention
Topics
Hazardous Waste Issues
- Hazardous waste categories
- Common hazardous waste
- Proper management
What to Expect During an
Inspection
Waste Disposal
Must determine if each type of waste
is hazardous or not:
If non-hazardous
recycle or put in dumpster.
If hazardous
recycle or store for pickup by hazardous
waste or universal waste transporter.
Ohio EPA commonly cites facilities for failing to determine if
wastes are hazardous – automatic enforcement referral to
Attorney General’s Office if found in trash.
Managing your waste:
It’s all about the dumpster
Don’t throw any
waste into the
dumpster unless
you have
confirmed and
demonstrated
that it is NOT a
hazardous
waste.
3 Generator Categories:
Conditionally Exempt Small Quantity Generator
(CESQG)
• less than 220 lbs/month (about ½ of a 55-gallon drum)
• Most facilities fall into this category
Small Quantity Generator (SQG)
 220 to 2,200 lbs/month (½ up to 5, 55-gallon drums)
Large Quantity Generator (LQG)
 over 2,200 lbs/month (over 5, 55-gallon drums)
Determining Your Category
• Total weight of hazardous waste that you generate (create)
in any given month of the calendar year;
– For example: Hazardous waste that you generate between
November 1st and November 30th
AND
• Total amount of hazardous waste on-site at any given time
(only for CESQGs and SQGs)
NOTE: Generator categories are NOT determined by the
weight of waste shipped off-site.
Conditionally Exempt
Small Quantity Generator
Large Quantity Generator
Less Regulations
More Regulations
What are my requirements?
• CESQG
– Determine and document if your waste is hazardous
– If hazardous, send to permitted hw facility
– Don’t store more than 5, 55-gallon drums – EVER!
• SQG - Same as CESQG and…
–
–
–
–
–
Move hazardous waste off-site within 6 months
Must have ID #
Must clearly label containers “Hazardous Waste”
Must manifest hazardous waste off-site
Must inspect and maintain emergency equipment “as necessary”
in hw storage area (must keep inspection records)
– Must inspect and log hw container storage area “at least weekly”
(must keep inspection records)
epa.ohio.gov/portals/32/pdf/gen_handbook.pdf
U.S. EPA Identification
Number* (12-digit)
• CESQGs - Not Required – but…
• Waste hauler might want you to have one
• SQGs and LQGs – Required
• Site specific, identifies company that created
the waste
• No fee – just fill out 9029 Site ID form
• epa.ohio.gov/portals/32/pdf/WasteActivityBook.pdf
• Need help? Call me!
614-728-8575
Typical Garage Wastes
Aerosol Cans
Shop Towels & Rags
Fluorescent Lights
Used Oil & Oil Filters
Floor Dry
Used Batteries
Electronics
Shop Towels & Rags
Management options:
• Recycle (Best Option!!!)
– Laundry service – clean and return
• Disposal
– Must evaluate
• Used to clean up solvent spill –listed hazardous waste
• Can contain hazardous contaminants (ex, metals and
organics)
– If hazardous, must go to permitted hazardous waste facility
– If non-hazardous and you have documentation to prove it,
they can go in dumpster (not recommended!)
Note: Do not burn!!!
Fluorescent Lights
Management options:
• Recycle (Best Option!!!)
– Manage as Universal Waste
•
•
•
•
Doesn’t count towards hazardous waste category
Date and package in same box (keep flaps closed)
Label as “Universal Waste Lamps”
Contact recycler for pick-up
• Disposal
– Must evaluate
• Usually hazardous for mercury and other heavy metals
– If hazardous, must go to permitted hazardous waste facility
– If non-hazardous and you have documentation to prove it, can
go in dumpster (not recommended)
Note: Do not recommend crushing your bulbs
Used Oil & Oil Filters
Management options:
• Recycle (Used Oil)
– Label your containers with the words “Used Oil”
– Send to used oil recycler
• Used oil processors/re-refiners
• Used oil burners (not space heaters)
– Burn your used oil in your used oil space heater
– Send to another business to be burned in their space heater
• Must have analysis that shows the oil meets certain specifications
• Do not mix used oil with anything
• Recycle (Used Oil Filters)
– Hot drain
– Recycle as scrap metal
– Tern-plated filter
Floor Dry
Management options:
• Manage as Used Oil
– Contains free-flowing used oil and
no solvents
– Used oil burners (not space heaters) may burn
as fuel if floor dry is combustible
• Disposal
– Cannot contain free-flowing oil (drip test)
– If hazardous due to organics or solvents, must go to permitted
hazardous waste facility
– If non-hazardous and you have documentation to prove it, can go in
trash (cannot contain free-flowing oil)
Used Batteries
Management options:
• Recycle
– Manage as Universal Waste
• Doesn’t count towards hazardous waste category
• Date & label storage area “Universal Waste Batteries”
• Contact recycler for pick-up
– Manage under Lead Acid Battery Rule
• Doesn’t count towards your hazardous waste category
• Exchange with battery supplier
– Give them a Land Disposal Restriction (LDR) one-time notice
(only required if you’re a SQG or LQG)
Electronics
Management options:
• Recycle (Best Option!!!)
– Free recycling drop-off locations
– epa.ohio.gov/ocapp/Recycle.aspx
• Disposal
– Usually hazardous for lead
– If hazardous - must go to permitted hazardous waste
facility
– If non-hazardous and you have documentation to prove
it, can go in dumpster (not recommended!!!)
EPA inspections
Who visits you?
• Could be inspector for only haz
waste, only water pollution, or
only air pollution - don’t
assume it’s comprehensive!
Why do they show up?
• Complaint investigations
– most common reason why
businesses are inspected!!!
• Priorities: annual, biennial, or
special sector initiatives
What do they want?
• Check compliance with Ohio’s
environmental rules
Avoid complaints …
• Minimize or
eliminate
odors & dust
to nearby
homes
• Follow the
rules
Questions?