August 25, 2010, 10:30-12:30
Presented by Christina Coffel
Oklahoma Department of Environmental Quality
Land Protection Division
Hazardous Waste Compliance Section
Safety & Comfort First
 Public Announcement (PA) will
alert for all emergencies. In the
event of a fire, exit out the front
door, gather in the north
parking lot for a head count.
 No smoking on DEQ grounds.
You can smoke across the street.
 Vending Machines: Located on
the 7th floor, after exiting the
elevators, go east to the end of
the hall. Break room is on the
right.
North 
Generator status--------------------------LQG, SQG, CESQG
Generation points-------Main location vs. remote locations
Silver reclamation --------------------Minimum level 5 mg/L
Transporter issues----------------Should facility be notified
Reclamation documentation---Manifest use requirements
Rinse water discharge----Authorized discharge points only
RCRA
1. Waste Determinations:
 You need to make waste determinations for all
waste generated by the facility. Determinations
made by either testing or knowledge of process.
Is it a solid waste?
If yes,
Is it a hazardous waste?
If yes,
Is it a characteristic waste or a listed waste or both?
If yes,
Are there any exemptions that apply?
Waste Determinations

Point of Generation:
Waste becomes subject to regulation when:
 It is removed from the manufacturing process unit,
OR
 90 days after the unit is taken out of service if the waste
remains in an inactive unit…”

Apply to both mobile and stationary units.
Waste film—may exhibit the toxicity characteristic for
silver (D011)
Waste solutions –may exhibit the toxicity characteristic for
silver & possibly for corrosivity(D002).
 Waste Fixer
 Waste Developer
 Waste Rinse Water
If vehicle maintenance performed on site:
 Used Batteries--may exhibit the toxicity
characteristic for corrosive and lead (D002 &Doo
 Used Antifreeze (60/40 Hazardous Guidance)
 Used Oil & Used Filters
 Used
Fluorescent Lamps-- may exhibit the toxicity
characteristic for mercury (D009)
Waste Film
 Usually contains silver above the RCRA limit of 5.0 mg/L
using TCLP.
 Can recycled under the precious metals exemption, 40
CFR 266 Subpart F.
 Hazardous waste determination:
 Can either test film (TCLP) to determine level (make
sure test is a representative sample of all possible
exposures for accurate silver levels)
 OR, assume it will exhibit the toxicity characteristic for
silver.
 OR, use knowledge of process—supporting
information/documentation required.
Waste Solutions
Waste Fixer & Waste Developer & Waste Rinse Water
 Can be separated in process to reduce quantity of HW generated or
combined into one waste container.
 Silver recovery unit must be used as per the manufacturers
instructions.
 Periodic testing should occur to ensure recovery unit is operating at optimum
levels.
 After recovery, the waste waters should be below RCRA limit of 5
mg/L silver.
 May need more than one recovery unit to accomplish this.
 Recovery cartridges are considered a sludge if going for recovery, not a RCRA
waste
so you don’t have to count their weight in your monthly generation amounts (see
future slide)
 If you use test strips, verify the range of the strip!
Used Lamps
 Lamps qualify to be managed under the Universal Waste




(UW) regulations which are less stringent than the full
hazardous waste regulations.
UW containers must be compatible, labeled, and dated
with an accumulation start date or tracking system.
One year storage limit vs. 90-day (LQG), or 180-day
(SQG).
No manifest usage required. Bill of Lading sufficient or
internal tracking system.
Does require UW employee training.
Vehicle Wastes
Used Oil (UO) & Used Filters



40 CFR 279
Label Containers “USED OIL”
Use authorized UO Recycler & Transporter
Used Antifreeze:

EPA 60/40 Hazardous Guidance
Vehicle Wastes cont…
Used Batteries
 Can be managed as HW, UW, or under special
exemption: 40 CFR 266 Subpart G
 If core-exchanging, then it is easiest to use the
exemption.
 Generators responsible to ensure proper recycling
is occurring by the company accepting the battery
for recycling-perform due diligence before sending
for recycling
RCRA
2. Generator Status
Determinations:
 You need to determine how much hazardous waste you
will generate each month in order to establish which
hazardous waste generator category you will be in.
Large Quantity Generator (LQG)
generate over 2, 200 pounds HW per month
Small Quantity Generator (SQG)
generates 220 to 2,200 pounds HW per month
Conditionally Exempt Small Quantity Generator (CESQG)
generates 0 to 220 pounds HW per month
Only count the hazardous waste
weight!
Do not count waste that is
managed as Universal Waste.
Do not count Used Oil.
LQGs
2,200 lbs or more HW generated monthly
 Required Notification for an EPA ID#
 Must use a manifest/LDR
 Disposal Plans & Annual Fees
 Quarterly Reports & Biennial Reports
 Written Contingency/Emergency Plans
LQGs cont…
 Notification to local authorities
 Well documented Employee Training Programs
 Documented weekly HW storage inspections
 90-day HW storage limits & NO weight limit for
storage
 Storage containers must be closed, appropriately
labeled, and dated
 Must perform and document weekly storage area
inspections
SQGs
220 lbs –2,200 lbs HW generated monthly
 Required Notification for an EPA ID#
 Must use a manifest /LDR
 Annual Fees
 Written Contingency/Emergency Plans
SQGs cont…
 Notifications to local authorities
 Employee training Programs
 Weekly HW storage inspections
 180-day HW storage limits & no more than
13,228 lbs (6,000 kg) on site at any given time
 Storage containers must be appropriately
closed, labeled, and dated
CESQGs
Up to 220 lbs HW generated monthly
 Not required to notify EPA
 Not required to use a manifest, bill of lading
sufficient
 Destination facility must be authorized to accept
the waste
 Recycling facility must be a legitimate recycler
 Limited to no more than 2,200 lbs HW on site at
any given time
 No time limit for storage
Storage vs. Satellite Accumulation
Definition of CLOSED
Labeling
Accumulation start date
Container Management
 Satellite Accumulation Area
 At or near the point of generation,
 Under the supervision of the operator,
 Not exceeding 55 gallons per SAA,
 Only three day allowance to move full SAA to container storage.
 Storage containers are used to store hazardous waste
awaiting disposal or recycling. Usually stored in a
centralized location.
 The amount of storage is limited by the generator
status. No limit on the number of SAA allowed.
Container Management
 Both types of containers must be closed.
 DEQ defines closed as spill proof and
vapor tight.
 Both containers must be labeled. Storage
with the words “Hazardous Waste”, SAA
with a content identifying label.
Container Management
 Storage containers require an accumulation start
date on the container.
 identifies the first day the container became a storage
container. This date will show how long it has been on
site so as to comply with the generator storage limits
(90-days LQG or 180-days SQG).
 A SAA may become a storage container when it is
deemed full or moved to the container storage area.
 At this point it needs a date and the words “Hazardous
Waste”.
40 CFR 266 Subpart F:
Silver Reclamation
Silver Reclamation Exemption
 Materials that are reclaimed to recover economically
significant amounts of gold, silver, platinum,
palladium, iridium, osmium, rhodium, ruthenium, or
any combination of these.
 Applicable to any persons who generate, transport, or
store recyclable materials that are regulated under this
subpart. Required to:
 Notify EPA
 Use the manifest if a generator, transporter, or someone
who stores.
Silver Reclamation Exemption
 Anyone who stores recycled materials that are regulated
under this part must keep the following records to
document they are not accumulating these materials
speculatively
 Records showing the amount of materials stored at the
beginning of the calendar year;
 The amount of these materials generated or received during
the calendar year; and
 The amount of material remaining at the end of the calendar
year.
 If speculative accumulation occurs, all regulations apply!
 If sent out of the country, specific EPA reporting required.
Generating at a remote location and
transporting the hazardous waste back to
the main location
Transporting Hazardous Waste
Requires:
 EPA notification of activity,
 Licensing from DOT,
 Authorization from OCC.
Knowledge of manifesting requirements
Specific employee/driver training
Transporting Hazardous Waste
If generator is a CESQG:
 Can self transport (limited amounts).
 No HW manifesting required.
 Be very familiar with the CESQG exemption- 40 CFR 261.5
 Be careful with timing of waste generation, this may
affect your generator category. Some CESQGs can
become SQGs based on the timing of waste disposal.
Then all SQG rules apply for that month of SQG
generation.
http://www.deq.state.ok.us/LPDnew/HW/Industrial%20Radiography%20Silver%20Recl%20from%20Xray%20Develpmt%2011-2010.pdf
Hazardous Waste Compliance Section
Mike Edwards, Manager
Christina Coffel, Inspector
Al Coulter, Data Management
Jarrett Keck, Reporting
Any other HWCS member
Facsimile
Phone
(405) 702-5226
(405) 702-5176
(405) 702-5189
(405) 702-5219
(405) 702-5100
(405) 702-5101