How to Manage HW Without Triggering the Transfer Act

Report
How to Manage Hazardous Waste Without
Triggering the Transfer Act
Annual CMTA Marine Trades Exposition
October 5, 2010
CESQGs:
You will not trigger the Transfer Act
if you generate less than 100kg of
hazardous waste in any one month.
What is a Hazardous Waste?
• First it must be a waste, something that you
have no use for and want to get rid of
• The Hazardous Waste Regulations do not
apply to products and materials you
legitimately intend to use
• Wastes are hazardous if: 1) they are on a list
of hazardous wastes (Listed Wastes) or, 2) they
exhibit a characteristic of a hazardous waste
(Characteristic Wastes)
What is a Listed Hazardous Waste?
•
It is a waste from Non-Specific Sources (“F” Listed Wastes)-such as:
– Waste Paint Thinners used for cleaning – F005
– Waste Carburetor cleaners and “Brake Klean” containing more than 10% of certain chlorinated
solvents – F002
– Rags with acetone and other non-halogenated solvents – F003
– Rags with paint thinners – F005
– Rags with carburetor cleaners and “Brake Klean” – F002
•
It is a commercial chemical product or off-specification chemical product you wish
to dispose of or recycle (“U” Listed Waste)-such as:
– Unused acetone – U002
– Unused MEK – U159
•
It is an acutely hazardous commercial chemical product or off-specification
chemical product you wish to dispose of or recycle (“P” Listed Waste):
– Not typically generated at marinas or boatyards
•
It is a waste from Specific Sources (“K” Listed Wastes)
– Not typically generated at marinas or boatyards
What is a Characteristic Hazardous Waste?
• Ignitable Waste (liquid waste with a Flash Point of < 140% F)
– D001: includes waste paint thinners, some parts washer fluids
• Corrosive Waste (liquid with a pH of <2 and > 12.5)
– D002: Spent or unwanted battery acid (if not recycled with batteries),
possibly other acids
• Reactive Waste (contains certain levels of cyanide or sulfide, is air
or water reactive)
– D003: Not typically generated at marinas or boatyards
• Toxic Waste by Toxicity Characteristic Leaching Procedure (TCLP)
– D004 through D043: May include waste paint thinners, antifreeze,
lead dust and bottom sanding dust, sand blasting grit
Waste Antifreeze
• Waste Antifreeze should be nonhazardous waste unless
contaminated with gasoline or oil
• Make sure that there is no floating
oil in drum before collecting sample
– if there is, mop it off with a
pad and put the pad in the oily
waste drum
Waste Paint Thinners
• We know that waste paint thinners are RCRA
hazardous wastes: F003, F005, D001
• We also know that waste carburetor cleaner and
other halogenated solvents are compatible, so we
added F002
• It may also contain benzene and MEK, so we added
D018 and D035
• We don’t know what metals might be in the paint.
Therefore we will test the waste paint thinners
once for the RCRA 8 metals by TCLP to find out if
any exceed the RCRA thresholds
• We do not need to test for the other Toxicity
Characteristic compounds because:
– We have used generator knowledge to identify the
volatile and semi-volatile compounds in the waste
– The TCLP Herbicides are not in paint and thinners
– The TCLP Pesticides are not in paint and thinners
Waste Paint Solids
•
•
•
•
•
•
We know that the paints are not Ignitable if they are
solid – Don’t test for flashpoint
We know that the paints are not Corrosive – Don’t
test for pH
We know that the paints are not air and water
reactive (the boats are not exploding) and the waste
does not contain reactive cyanide and sulfides. We
don’t know what metals might be in the paint
Therefore we will test the waste paint once for the
RCRA 8 metals by TCLP to find out if any exceed the
RCRA thresholds
We don’t have data to prove that volatile and semivolatile compounds aren’t present above the RCRA
thresholds
Therefore we will test the waste paint once for the
RCRA volatile and semi-volatile compounds to find
out if any exceed the RCRA thresholds
– The TCLP Herbicides are not in paint, don’t test
for them
– The TCLP Pesticides are not in paint, don’t test for
them
Waste Solvent and Gasoline
Contaminated Rags
• We know that rags will contain
waste paint thinners : F003, F005,
D001
• We also know that rags may
contain waste carburetor cleaner
and other halogenated solvents so
we added F002
• Rags may also contain MEK so we
added D035
• Rags with gasoline will contain
benzene so we added D018
• We added D001 for Ignitability in
case the rags have free liquids
Bottom Paint Sanding Dust
• We know from industry-wide
testing that bottom paint
sanding dust is almost always
non-hazardous waste
• EXCEPT some of the dust is
RCRA hazardous for lead – D008
(probably from keels)
• Test each batch for lead by TCLP
to confirm tat the dust is nonhazardous before shipping
Lead Dust
• Dust from sanding lead keels,
faring keels will be RCRA
hazardous manage as D008
• No testing needed
• Keep this waste separate from
other bottom sanding dust
Waste Blasting Grit
• From boat bottoms
(Fiberglass boats, relatively
new) – test for lead by TCLP
• From bead blasters,
commercial vessels, old
oddball boats – test for
RCRA 8 Metals by TCLP
Oily Waste
• Oily waste should be nonhazardous waste unless
contaminated with other
materials
Items EXEMPT from the
Hazardous Waste Regulations:
•
Scrap metal that is recycled
- Lead keels, chunks of lead (not dust)
- zincs
- scrap steel
- EMPTY drained oil filters
- EMPTY drained metal gasoline filters
•
Off-specification gasoline that is used for a
fuel
–
–
•
Don’t label as a waste!
Get proof from receiving facility that the
gasoline is being used for fuel
EMPTY containers
–
They are exempt when all material “that can
be removed by using the practices commonly
employed to remove materials from that type
of container, e.g. pouring, pumping and
aspirating and” … “no more than 3% by
weight of the total capacity of the container
remains in the container or inner liner if the
container is less than or equal to 110 gallons
in size”
Items that are Regulated
Differently
• Used oil - regulated under the
Used Oil section of RCRA – Test
each load for total halogens
• Used Batteries – Manage under
the Universal Waste Regulations –
have used batteries picked up for
recycling, keep them on
secondary containment, under
cover and away from trash and
combustibles
– Note: If a battery is broken or
leaking, it is a Hazardous Waste
Document, Document, Document
• When you have completed the waste
determination for each waste stream your
waste management company should provide
you with a written waste determination
• You need to update your waste
determinations annually and document them
• Always double check hazardous waste
manifest before signing
Uniform Hazardous Waste Manifest
Questions?

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