DEP Hazardous Waste Program
Why a need for regulations
Following WWII, manufacturing was booming and large
volumes of toxic waste were generated. The waste was
disposed on ground or burned without controls
• Problems started developing
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Water polluted
Air pollution
Dying species
Health problems
• Several sites became legendary
– They help cause the creation of environmental protection
laws
Some sites became legendary
• Love Canal
• Cuyahoga River
• Valley of the drums
• Times Beach
Love Canal, Niagara NY
15 acres along Niagara River
1890, constructed 3000ft by 60ft canal – went bankrupt
1920, purchased by Hooker Chemical
1920 – 1953, used as a landfill by Hooker Chemical and the city.
1953, sold to the city’s board of education ($1.00)
Deed stated not to dig within the area of the canal
1954, Board of Ed built schools and housing (1000)
Disregarded warning on deed
Chemicals seeped into basements and storm drains
Drums popping up in ball fields and yards
Residents started complaining
1978, years of residents complaints forced evacuation of several city blocks
2010, a few city blocks still restricted
Cuyahoga River, Cleveland OH
1936 – 1969, used as an industrial sewer
Numerous fires from waste chemicals floating on the river
Referred to as the “dead river”.
No signs of life in the river
1952, large fire damaging boats and buildings
1969, last large fire
Earth movement and Clean Water Act of 1970 put an end
to industrial dumping
Valley of the Drums, Brooks KY
13 acre site, gravel pits owned by A. L. Taylor
1967 – 1977, took in over 38,000 drums of waste
from area paint and coating manufacturers
11,000 drums buried and/or burned
27,000 drums stored on the soil
1980, EPA begins cleanup
Times Beach, MI
Small town of 2000 with 21 miles of un-paved roads
1971 – 1972, Sixty two horse die at area stables.
Russell Bliss was hired to sprayed waste oil for dust control
1972 – 1976, Times Beach hires Russell Bliss
Spray waste oil on roads for dust control
1977, EPA begins investigation into horse deaths
Oil came from NE Pharmaceutical and Chemical Corp
Made Agent Orange (2,4,5T and 2,4D)
Contains dioxin
Russell Bliss picked up waste oil
1983, EPA purchases the town and evacuates residents
1996 – 1997, incinerate 26,000 tons of dioxin contaminated soil
from Times Beach and local stables
Current – Town park (still polluted)
Hazardous Waste Laws
• Title 40 of the Code of Federal Regulations, Parts
260 – 280
Cradle to Grave
“you generate a waste, you own it forever”
Enforcement
• Civil –
– $25,000 per day per violation
• Criminal –
– $50,000 per day per violation
– Up to five years in prison
Civil Cases
• Home Depot (9 stores)
– $425,000.00 & corporation wide compliance program in CT
• Light Sources
– $857,000.00 & clean up mercury release
• Kaman Aerospace
– $420,000.00
Criminal
• Phoenix Products
– $250,000.00
– Probation
• Mike Fretaus and U Haul
– $60,000.00
– 1 year prison
• Sound Mfg
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$100,000.00 and $1,000,000.00 cash bond (clean up)
3 years prison (suspended on appeal)
1 year home confinement
Clean up completed in January 2010
Questions
Hazardous Waste Management Regulations
As a generator of HW, you must:
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Determine if each solid waste is HW
Properly manage & store the waste
Inspect waste & emergency response equipment
Plan for Emergency responses
Train employees
Preparing for off-site shipment
Keep records
Determination if Waste is Hazardous
Can use knowledge of the chemicals and process that
generates the waste, analytical testing, or both
• 1st – is the waste a solid waste
– i.e. is it discarded
• 2nd – is the solid waste excluded
– If no,
• 3rd – is the solid waste a hazardous waste
What’s a Solid Waste
• Discarded material –
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Spent material
Sludge
By-product
Commercial chemical product
Scrap metal
That’s discarded –
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Burned/incinerated
Recycled/reclaimed
Accumulated speculatively
Used in a manner constituting disposal*
*placed on land or water
Solid Waste Example
disposed
discarded
reused
burned
What’s a Hazardous Waste
A hazardous waste is a solid waste that is
• listed as a hazardous wastes
and/or
• Exhibits a characteristic of a hazardous waste
• Two sub-categories
Used oil
Universal waste
Exclusions
•
Waste fuel reused as a fuel
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•
gasoline sent off-site for fuel blending
Effective substitute for a commercial chemical
product, provided the product is not used in a
manner constituting disposal or burned.
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Spent plastic bead blast media (removing paint from air craft)
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Used in water resistant concrete block (Sealtech block)
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Applied above ground – not solid waste
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Applied on the ground – is solid waste
Fly ash used to make zinc powder (electric plant emission control)
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Used for galvanizing – not solid waste (US Zinc)
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Used in plant food – is solid waste (Bay Zinc)
Waste Codes
• All hazardous wastes are identified by a “waste code”
• (except for used oil and universal waste)
• The listed waste codes
• F, K, U, P
• (Example – F001 spent halogenated solvent)
• The characteristic waste codes
• D waste codes
• (Example – D008 lead)
Reasons for Waste Codes
National statistical information
Observe trends in waste generation
Pollution prevention programs
Eliminate/reduce large volume waste types
Hazard recognition
Waste codes represent specific hazards
Listed Hazardous Waste
• Three Lists (developed in 1976)
– Non-specific source list
• Waste from a process that any business can do
– Specific source list
• Waste from specifically listed types of businesses
– Commercial chemical product list
• Waste that is a specifically listed type of chemical product
Facts about Listed HW
Reasons for Listing
Ignitable
(I)
Corrosive
(C)
Reactive
(R)
Acutely Hazardous (H)
Toxic
(T)
Mixture Rule
– mixing a listed waste with any
other solid waste makes the
entire mixture a listed waste!
– not dependent on amount
(one drop, one gallon, etc).
– not dependent on the source
(intentional mixing, accidental
mixing).
– Can cause an inexpensive
waste to become more
expensive when shipped offsite
Non-specific source
“F” Waste Codes
Waste from generic sources:
F001 – F039
• Solvents (F001 – F005)
• Metal finishing (F006 – F019)
• Pesticides/wood preservative [dioxin] (F020 - F035)
F001 (T) Spent halogenated solvent used in
degreasing
• Carb cleaner
• Brake cleaner
• Contact cleaner
• tetrachloroethylene,
trichloroethylene,
methylene chloride,
1,1,1 trichloroethane,
carbon tetrachloride,
chlorinated
fluorocarbons
• still bottoms from
recovery of spent
solvents
F002 (T) the following spent halogenated
solvents
• Paint stripper
• Tire cleaner
• Lab analysis
• tetrachloroethylene,
trichloroethylene,
methylene chloride,
1,1,1 trichloroethane,
carbon tetrachloride,
chlorinated
fluorocarbons
• still bottoms from
recovery of spent
solvents
Halogens
Chemical with the word chlor or fluor in its name
Perchloroethylene (1.6)
Trichloroethylene (1.46)
methylene chloride (1.33)
“HEAVIER THAN WATER”
IMPROPER TREATMENT = DIOXINS
F003 (I) The following spent nonhalogenated solvents
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Paint stripper
Carb cleaner
Brake cleaner
Electric contact cleaner
Lab analysis
• xylene, acetone, ethyl
acetate, ethyl benzene,
ethyl ether, methyl
isobutyl ketone, butyl
alcohol, cyclohexanone,
methanol
• still bottoms from
recovery of spent
solvents
F005 (I)(T) The following spent nonhalogenated solvents
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Carb cleaner
Brake cleaner
Paint stripper
Gasket remover
Electric contact cleaner
Lab analysis
• toluene, methyl ethyl
ketone, carbon
disulfide, isobutanol,
pyridine, benzene, 2ethoxyethanol, 2nitropropane
• still bottoms from
recovery of spent
solvents
Specific Source
“K” Waste Codes
Waste from specifically identified industrial
sources:
K001 – K160
• Refineries (K048, K170)
• Pharmaceutical (K084, K101)
• Foundry (K061, K069)
• Explosives (K044, K45)
Example
Industry and EPA
hazardous waste
No.
Hazardous waste
Hazard
code
Wood Preservation
K001
Bottom sediment sludge from treatment of wastewater
from wood preserving process that uses creosote
and/or pentachlorophenol
(T)
Inorganic Pigments
K002
Wastewater treatment sludge from the production of
chrome yellow and orange pigments
(T)
Organic Chemicals
K013
Bottom stream from the acetonitrile column in the
production of acrylonitrile
(T, R)
Explosives
K044
Wastewater treatment sludge from the manufacturing
and processing of explosives
(R)
Commercial Chemical Product
“U” & “P” Waste Codes
Solvents
Pesticides
Pharmaceuticals
Chemical ingredients
Commercial Chemical Product Waste
• Waste chemical product that is unused
• pure or technical grade of chemical
• sole active ingredient
• no longer needed or wanted
off-specification
old/outdated
Commercial Chemical Product Waste
• Spilled virgin chemical products
Commercial Chemical Product
“P” Listed Waste
“acutely hazardous”
P001 - P205(H)
- Methyl parathion P071
- Nicotine P075
– Epinephrine P042
– Methyl isocyanate P064
– Empty containers of “P” listed materials not triple
rinsed
– Rinsate from rinsing empty containers
Commercial Chemical Product
“U” Listed Waste
U001 – U411(T)
– Acetone U002 (I)
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Methylene chloride U080
2,4-D U240
Isopropanol U140 (I)
Methyl ethyl ketone U159 (I)
DDT U061
Warfarin U248
Acetyl chloride U006 (C, R)
Questions
?
Characteristic Hazardous Waste
Four types
“D” waste codes
– Ignitable (D001)
– Corrosive (D002)
– Reactive (D003)
– Toxicity Characteristic (D004-D043)
Some Facts about Characteristic Waste
• Some characteristics are based on physical
properties
• flash point
• pH (acid or alkali)
• compressed or pressurized gases
• oxidizer
Some Facts about Characteristic Waste
• Some characteristics are based on concentration
limits
• milligrams per liter (mg/L)
• test method “Toxicity Characteristic Leaching
Procedure”
• limits range between 0.008 to 400 mg/L
note: one percent (1%) equals 10,000 ppm
Some Facts about Characteristic Waste
• Everything discarded, must determine if it exhibits a
characteristic of a hazardous waste
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Paper (masking materials, sandpaper, coveralls)
Tires
Chemicals (used & un-used)
Light bulbs/tubes
Electronic devices (computers, cell phones, TV)
Scrap metal
Paint (liquid or solid)
Contaminated debris (paint brushes, speedi dry, dust)
Ignitable Characteristic
“D001”
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Liquid with a flash point less than 140 Deg. F
Oxidizers
Ignitable compressed gases
Not a liquid – fire through friction, moisture,
spontaneous chemical change, & burns vigorously
and persistently
Ignitable Examples
• Liquid – flash point less than 140
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Mineral spirits
Gasoline
Contact cement
Aerosol paint
• Oxidizers
– Nitric acid
– Fiberglass resin hardener (MEKP)
• Ignitable compressed gas
– Acetylene
– Propane
• Not a liquid
– Aluminum fines
– Magnesium
Corrosive Characteristic
“D002”
• Aqueous liquid, pH less than 2 or greater than 12.5.
• A liquid that corrodes steel at greater than 0.025
inches per year at 130 degrees F.
Corrosive Examples
• pH less than 2
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Nitric acid (lab)
Sulfuric acid (battery)
Muriatic acid (concrete)
Hydrofluoric (aluminum)
• pH greater than 12.5
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Potassium hydroxide (oven)
Sodium hydroxide (drain)
Ammonium hydroxide (cleaner)
Sodium hypochlorite (bleach)
Reactive Characteristic
“D003”
• Normally unstable
• Reacts violently with water or forms toxic fumes
or vapors
• Capable of detonation or explosion when heated
under confinement or initiating force
Reactive Examples
• Explosives
– Fire works
– Ammunition
– Air bags
• Compressed cylinders
– Aerosol cans
– Propane cylinders
• Metal fines
– Aluminum
• Lithium
– Batteries with a charge
Toxic Characteristic
“D004 – D043”
• 39 elements and compounds
• cause damage to tissue, impair CNS, cause severe illness or death
when ingested, inhaled, or absorbed.
• based on concentration limits (mg/L).
• testing using Toxicity Characteristic Leaching Procedure (TCLP).
Toxic Characteristic
Waste Code
D004
D005
D006
D007
D008
D009
D010
D011
D012
D013
D014
D015
D016
Contaminant
arsenic
barium
cadmium
chromium
lead
mercury
selenium
silver
endrin
lindan
methoxychlor
toxaphene
2,4-D
Limit mg/L
5.0
100.0
1.0
5.0
5.0
0.2
1.0
5.0
0.02
0.4
10.0
0.5
10.0
Toxic Characteristic
Waste code
D017
D018
D019
D020
D021
D022
D023
D024
D025
D026
D027
Contaminant
2,4,5-TP
benzene
carbon tetrachloride
chlordane
chlorobenzene
chloroform
o-cresol
m-cresol
p-cresol
cresol
1,4-dichlorobenzene
Limit mg/L
1.0
0.5
0.5
0.03
100.0
6.0
200.0
200.0
200.0
200.0
7.5
Toxic Characteristic
Waste code
D028
D029
D030
D031
D032
D033
D034
D035
D036
D037
D038
D039
D040
D041
D042
D043
Contaminant
1,2-dichloroethane
1,1-dichloroethylene
2,4-dinitrotoluene
heptachlor
hexachlorobenzene
hexachlorobutadiene
hexachloroethane
methyl ethyl ketone
nitrobenzene
pentachlorophenol
pyridine
tetrachloroethylene
trichloroethylene
2,4,5 trichlorophenol
2,4,6 trichlorophenol
vinyl chloride
Limit mg/L
0.5 mg/L
0.7 mg/L
0.13 mg/L
0.008 mg/L
0.13 mg/L
0.5 mg/L
3 mg/L
200 mg/L
2 mg/L
100 mg/L
5 mg/L
0.7 mg/L
0.7
400.0
2.0
0.2
Questions
Managing Waste in Containers
• Two types
– Satellite containers
– Storage containers
Satellite Containers
– At or near the point of generation
– Under control of the operator (generator of waste)
– Can’t exceed 55-gallons per waste type
– Labeled “hazardous waste”
– Labeled “description of waste”
– Keep closed
– Good condition
Storage Containers
• Not a satellite container
• Keep closed
• Labeled “hazardous waste”
• Labeled “description of waste”
• Labeled “date of accumulation”
• Kept in engineered storage area
• Ship off-site in 180-days
Engineered Storage Area
• Secondary containment
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10% of all containers or 100% of largest
• Impervious base
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Poly spill pallets
Epoxy coated concrete
Sheet metal
• Warning signs
– No smoking signs (flammable or reactive)
• Aisle space
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30 inches between rows of drums
• Secured & 50 feet from property line
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Flammable or reactive
• Separate incompatibles
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Acid from alkali
Flammable from corrosives
Satellite Violations
open
open
Labeled HW
Open, not labeled
Storage Violations
date
Open, containment, labeled (HW, desc, date)
Containment, labeled (HW, desc, date)
Containment, labeled (HW, desc, date)
Inspections
•Schedule
•Describes what to inspect
•Container condition (leaks, damage, bulging)
•Container labeling (words HW, description, date)
•Containment system (damage, signs of leaks/spills)
•Emergency equipment
•Log
•Record observations
•Name of inspector
•Date of inspection
•Time of inspection
•Corrective action
Inspections
• Frequency
– Container areas – weekly
– Safety/emergency equipment - monthly
Emergency Response Plan
Emergency Response Plan
• Identify key employees
• Emergency coordinator
• Alternate coordinator
• Plan for site specific emergencies
• Spills, fires, flooding
• at minimum – must contain releases/spills
• Hazards of your chemicals
• Volume of chemicals (container/tank size)
• Site characteristics
• Floor drains
• Chemicals stored outdoors
• Soil or asphalt
• Possible incompatible materials
• Sources of ignition
Post Emergency Information
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Name and phone # of emergency coordinators
Location of spill response equipment
Location of fire extinguishers and/or pull boxes
Phone number for off-site responders (FD, spill
contractors, DEP)
• Evacuation routes
Responding
• You are required to contain releases
– Train key employees
– keep adequate response equipment on-site
• absorbents (clay litter, pads, pigs, saw dust, sand, rags, etc)
• shovels
• booms (contain spills to water)
• fire extinguishers
• protective gloves
• containers for waste collection
Reporting
– Notify DEP (860-424-3338)
• required for all spills
– Notify national response center (800-4248802)
• impacts water body
• impacts adjacent properties
Employee Training
All employees that have hazardous waste duties
Site coordinators
workers putting waste in containers
worker conducting inspects
responding to emergencies
determining if waste is HW
prepare/sign manifests
Annual training/refresher
specific to worker’s duties involving HW
document training
Off-site Shipment
• Label container with HW Marker
• Use DOT approved containers
• Label with DOT labels
– Corrosive
– Flammable
• Use transporter that has EPA Id. No.
• Send to TSDF that has EPA Id. No.
Off-site Shipment
• Prepare hazardous waste manifest
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Site address
Volume of waste
Description of waste (and waste codes)
Transporter name and EPA Id. No.
Receiving facilities (TSDF) name and EPA Id. No.
Generator signs and dates
• Keep copy for your file
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Transporter signs and dates
Send a copy to the generator state’s DEP
Send a copy to the receiving facility’s state DEP
Receiving facility sends you a signed dated copy after receiving the waste
• Keep copy for your file
Off-site Shipment
• Prepare Land Disposal Restriction Form (land
ban form)
– Done for all waste that does not meet the land
disposal treatment standards
• Generator’s name and address
• Manifest #
• Description of waste
– Hazardous wastes
» Example “lead”
– Underlying pollutants
» Example “nickel”
Record Retention
• Must keep records for three years
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Inspection logs
Training records
Spill reports
Hazardous waste manifests
Land disposal restriction forms
• Must update annually
– Hazardous waste determinations
Questions
The Other Regulated Wastes
Hazardous wastes that can be managed under
reduced requirements specific to the waste type
•Used Oil (40 CFR Part 279)
•Universal Waste (40 CFR Part 273)
Used Oil
“Synthetic or petroleum based oil that has been used
and as a result can no longer be used without
processing”
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Lube oil (gas/diesel powered equipment)
Machining (milling, drilling, grinding, broaching)
Hydraulic oil
Heat transfer fluids
Metal forming (drawing, rolling, extrusion)
Heat treating
• Includes oil contaminated materials (unless drained)
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Oil filters (not drained)
Absorbents
• Does not include animal oil, vegetable oil, or waste
oil
Used Oil
• Presumed to be recycled
– Re-refined
– Burned for energy recovery
• If not recycled, fully regulated HW
– Disposed (placed on ground)
– Incinerated (burned without energy recovery)
Used Oil
• Can exhibit a HW characteristic or be listed HW
• Can mix with an ignitable only HW
• Provided mixture does not exhibit the ignitable characteristic
• Must test for total halogens
• > 1000 ppm halogens - presumed mixed with hazardous waste.
- test for halogenated solvents
(100 ppm = HW)
Used Oil
• Must label containers/tanks “Used Oil”
• If stored outdoors –
– On an impervious base
– In secondary containment
• Can be burned in a space heater
• No storage time limits
• No volume limits
– If over 1340-gallons (both used and virgin) must prepare a SPCC plan
Used Oil
• Can self transport to an aggregation area
– Aggregation area owned/operated by the generator
– 55-gallons per trip
• If shipped off-site –
– Ship off-site to facility that has an EPA Id. No.
– Ship using a transporter with EPA Id. No.
– Use a manifest or shipping invoice
Used Oil
• Can be sold as a fuel if “on-specification”
– Needs testing to show its comparable to fuel oil
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BTU value (at least 5,000)
Arsenic 5 ppm or less
Cadmium 2 ppm or less
Chromium 10 ppm or less
Lead 100 ppm or less
Flash point 100 deg. F. minimum
Total halogens 4000 ppm or less
• Can’t be sold for residential fuel (in CT)
Questions
Universal Waste
• Special rule for wastes that are universally
generated
• Are hazardous wastes (listed or characteristic)
– Exception (FIFRA recalled pesticides & waste added by states)
• Can be generated anywhere
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Manufacturing buildings
Office buildings
Hotels
Government buildings
Parking lots
Roadways
Schools
Universal Waste Types
• Mercury containing lamps
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Fluorescent
Metal halide
Mercury vapor
Sodium vapor
• Mercury thermostats
• Batteries
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Lead acid (lead and acid)
NiCad (cadmium)
Mercury cell (mercury)
Silver cell (silver)
Nickel hydride (alkali)
• FIFRA banned pesticides
Universal Waste
• States can add other waste types (HW or non-HW)
– Ct added –
• Mercury containing equipment
• Used electronics
• All types of fluorescent lamps
Universal Waste
• No presumption of recycling
• Store for one year
• Label
– “universal waste batteries”,
– “universal waste lamps”, etc
• Can send to other universal waste generator
Universal Waste
• Can self transport, send through mail, etc
• Use shipping invoice if shipped by transporter
• Becomes fully regulated HW when
– Disposed (such as spilled or broken)
– Burned
Questions
Used oil & handling requirements
Universal Waste & handling requirements
Midnight Dumping
Midnight Dumping
• Try to determine what it is
– Residential
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Milk jug
Antifreeze jug
One-gallon Paint can
Containers of less than 5-gallons
– Waste types
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Oil
Antifreeze
Paint
Gasoline
Midnight Dumping
• Try to determine what it is
– Commercial/business
• Several of same size containers
• Five-gallons and larger
• Labeling such as
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Ship to
Name of supplier
Product name
Flammable, corrosive, etc
Midnight Dumping
• Note container condition and type
– Leaking
– Corroded
– Open
– Steel, poly, fiber
– Size
– Shape
– Labeling
Midnight Dumping
• Call Oil & Chemical Spills (860-424-3338)
– Describe observations
– Give location
• If leaking, secure and contain
• If you feel it is safe, bring it back to your
storage area, label “midnight dumping
waste”
Sources of Assistance
• DEP Compliance Assistance Phone Line
– Toll free 888-424-4193
– RCRA main line 860-424-3023
• David Stokes, DEP Waste Management
– 860-424-3269
A Few Statistics
Unused oil – 29 million gallons spilled to ground
Used oil – 1.4 billon gallons generated
300 million gallons disposed on ground
Used oil filters – 400 million generated
360 million disposed on ground
Used batteries – 70 million generated
14 million disposed on ground (28 million gallons acid)
Fluorescent tubes – 600 million generated
120 million disposed on ground (20,000 pounds mercury)
Spent solvent – 850 million gallons generated
200 million gallons disposed on ground