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?