Introduction Kelly Dale Taylor Environmental Compliance Manager Safety-Kleen Systems, Inc.

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2 Introduction Kelly Dale Taylor Environmental Compliance Manager Safety-Kleen Systems, Inc. Phone:

3 Managing Waste 3

4 Is It 4

5 Or Is It 5

6 Why Does it Matter???? Hazardous Waste must be managed differently from non-hazardous wastes It must be sent to a properly licensed facility for disposal It cannot be put in with normal trash 6

7 What Agencies Decide?? The U.S. Environmental Protection Agency (EPA or sometimes USEPA) is an agency of the federal government charged with protecting human health and the environment o Wisconsin is Authorized by the Federal EPA to enforce their regulations (WI Dept of Natural Resources WI DNR) o States may adopt the federal regulations o States may make their own laws o These may be more stringent, but at no time can the laws be more lenient than the federal law 7

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10 Environmental Legislation Cradle to Grave The generator is responsible for all waste from the point of generation to final disposal Regardless of who has the waste.. Remember Compliance Liability 10

11 Why Does Compliance Matter? Minimizes the possibility of spills Minimizes the possibility of regulatory fines and violations when your friendly regulatory shows up Public perception; good citizen Cost 11

12 Liability Minimize cleanup liability. If hazardous and nonhazardous wastes are disposed improperly, generators must share the costs of remediating sites ( Superfund sites). A company having good records of proper hazardous waste management can reduce or eliminate the amount of money it has to pay. 12

13 Environmental Legislation Resource Conservation and Recovery Act (RCRA) , 1984 This law focuses on the management of hazardous waste from the point of generation to the point of disposal ~ Cradle to Grave 13

14 Solid Waste is any material -- liquid, solid, or gas - that is ready to be discarded by the generator The material can no longer be used for its originally intended purpose, maybe because it has become contaminated or has been used in some process, it s off-spec, out-of-date, or you just don t need it anymore 14

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16 What is Hazardous Waste? Waste that has a Characteristic OR Waste that is on a List 16

17 RCRA Characteristic Codes Defines the chemical properties of the waste. Ignitability Corrosivity Reactivity Toxicity 17

18 A liquid with a flash point less than 140 F Examples: gasoline, benzene, alcohols, acetone, paint thinner Is ignitable waste generated in your work area? D001 FLASH POINT: The minimum temperature at which a liquid gives off a vapor in sufficient concentration to ignite if an ignition source is present 18

19 Ignitable Solid To exhibit the characteristic the waste must meet both parts of the defnition: 1. Cause fire thru friction etc.; and 2. Burn vigorously & persistently Example - magnesium tape, and other thermally unstable solids that spontaneously ignite (includes some paint booth filters) D

20 Chemical/Material Flash Point (Typical) in F Gasoline -45 Paint /Lacquer Thinner 20 (or less) Acetone (Nail Polish Remover) -20 Mineral Spirits (Petroleum Naphtha) Diesel Fuel 126 Kerosene Ethanol 62 Jet Fuel

21 A liquid with a ph less than or equal to 2.0 or greater than or equal to 12.5 A liquid that corrodes steel at a rate greater than 0.25 per year D002 21

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23 Examples of corrosive wastes: Hydrochloric acid, nitric acid, sulfuric acid; ammonium hydroxide, sodium hydroxide Wastes are corrosive because they are either highly acidic or highly basic. D002 23

24 The reactivity characteristic (D003) applies to the following waste Normally unstable and readily undergoes violent change without detonating Reacts violently or forms potentially explosive mixtures with water Releases toxic gases when mixed with water 24

25 The toxicity characteristic (TC) is based on the potential of a waste to contaminate groundwater as it leaches through a landfill 25

26 TCLP Metals Regulatory Level TCLP Volatiles Regulatory Level TCLP Semi-Volatiles Regulatory Level D004 Arsenic 5 D018 Benzene 0.05 D023 O-Cresol 200 D005 Barium 100 D019 Carbon tetrachloride 0.5 D024 m-cresol 200 D006 Cadmium 1 D021 Chlorobenzene 100 D025 p-cresol 200 D007 Chromium 5 D022 Chloroform 6 D026 Cresol 200 D008 Lead 5 D028 1,2-Dichloroethane 0.3 D027 1,4-Dichlorobenzene 7.5 D009 Mercury 0.2 D029 1,1-Dichloroethene 0.7 D030 2,4-Dinitrotoluene 0.13 D010 Selenium 1 D035 Methyl ethyl ketone 200 D032 Hexachlorobenzene 0.13 D011 Silver 5 D039 Tetrachloroethene 37 D033 Hexachlorobutadiene 0.5 TCLP Pesticides D040 Trichloroethene 0.5 D034 Hexachloroethane D020 Chlordane 0.03 D043 Vinyl chloride 0.2 D036 Nitrobenzene 2 D012 Endrin 0.02 D037 Pentachlorophenol 100 D031 Heptachlor TCLP Herbicides D038 Pyridine 5 D013 Lindane 0.4 D016 2,4-D 10 D041 2,4,5-Trichlorophenol 400 D014 Methoxychlor 10 D017 2,4,5-TP (Silvex) 1 D042 2,4,6-Trichlorophenol 2 D015 Toxaphene

27 Listed Wastes Waste Type Non- Specific Sources Regulatory Citation 40 CFR (F-List) Common F-wastes: paint thinners, halogenated degreasers, 1-1 triclor, perc, tetracloroethylene Description These are generic wastes, commonly produced by manufacturing and industrial processes. Wastes on this list include spent halogenated solvents, wastewater sludge from electroplating, and treatment residues. 27

28 Industry and EPA hazardous waste No. F001 F002 Hazardous Waste The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures The following spent halogenated solvents: Tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2-trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2-trichloroethane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those listed in F001, F004, or F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures Hazard Code (T) (T) F003 F004 The following spent non-halogenated solvents: Xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends containing, before use, only the above spent non-halogenated solvents; and all spent solvent mixtures/blends containing, before use, one or more of the above non-halogenated solvents, and, a total of ten percent or more (by volume) of one or more of those solvents listed in F001, F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures The following spent non-halogenated solvents: Cresols and cresylic acid, and nitrobenzene; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures (I)* (T) F005 The following spent non-halogenated solvents: Toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, or F004; and still bottoms from the recovery of these spent solvents and spent solvent mixtures (I,T) 28

29 Listed Wastes Waste Type Specific Sources Regulatory Citation 40 CFR (K-List) Description This list consists of wastes from specifically-identified industries, such as wood-preserving, petroleum refining, and chemical manufacturing. These wastes usually include sludges, wastewaters, spent catalysts, and pigment residues. 29

30 Listed Wastes Waste Type Commercial Chemical Products Regulatory Citation 40 CFR (P, U-Lists) Description These are specific chemical products used in agriculture, laboratories, and other commercial operations. This list includes chloroform, DDT, and sodium cyanide. 30

31 A single waste stream can appear on more than one list, as well as exhibit one or more of the hazardous characteristics. Generators must identify all applicable hazardous EPA waste codes. 31

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34 Universal Waste Rule A waste must be a hazardous waste before it can be a universal waste. The Universal Waste Rules (UWR) are intended to promote recycling as well as proper disposal by easing certain regulatory requirements. 34

35 Universal Wastes Waste is still hazardous but classified as universal waste as industry and EPA are better equipped to manage the waste Provides regulatory relief»usually paperwork-related (i.e. manifesting)»don t have to count towards generator status»don t have to pay fee for UW generated 35

36 Universal Waste Rule 36

37 Universal Waste-Bulbs State hazardous waste regulations prohibit businesses and institutions from disposing of waste bulbs in landfills if the bulbs contain heavy metals that exceed hazardous waste regulatory limits. 37

38 Universal Waste-Bulbs Safe Handling and Storage Place waste bulbs in the box in which replacement bulbs arrived or in cartons provided by a bulb handler or recycler. Label cartons and boxes with the words "Universal Waste Lamps, Waste Lamps or Used Lamps. Store bulbs in a safe place to prevent breakage and mark the storage area appropriately. 38

39 Universal Waste-Bulbs Green bulbs may be non-hazardous, but they still contain mercury. Mercury, even at very low levels, can become air-borne and be deposited into the environment, such as lakes and other water bodies Green fluorescent bulbs should not be disposed as a general solid waste unless the generator can document that the waste is non-hazardous and contains no mercury 39

40 Universal Waste-Bulbs Bulbs broken incidental to handling (accidently) can still be managed as UW Lamps that are intentionally crushed can NOT be managed as UW this is considered treatment in most states (plus there may be serious safety issues) All crushed bulbs must be managed as hazardous waste 40

41 Good, bad, or ugly???? 41

42 Good, bad, or ugly???? 42

43 Universal Waste-Batteries 43

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45 Properly Packaged? Photo courtesy of Interstate Batteries 45

46 Universal Waste Rule There is no relief from required DOT labeling/placarding All wastes must be packaged per DOT requirements 46 46

47 Universal Waste Rule Mercury-Containing Equipment Mercury-containing equipment consists of devices, items, or articles (excluding batteries and lamps) that contain varying amounts of elemental mercury that is integral to their functions. Some commonly recognized devices are:» thermostats, barometers, manometers, temperature and pressure gauges, and mercury switches, such as light switches in automobiles. 47

48 Universal Waste Rule Accumulation time Accumulate UW for no more than one year from the date you generated or received the UW at your site. Mark the UW with the generated or received date or keep records to verify how long you have accumulated it. Must be safely stored in a closed container 48

49 Basic Waste Requirements WI DNR uses enforcement discretion and has reduced regulations for: Used Antifreeze» Must go for legitimate reclamation / reuse Scrap Electronics» State law prohibits businesses or institutions from disposing of any electronics that contain hazardous materials in municipal solid waste landfills or incinerators.» If businesses and institutions do not recycle electronic equipment, they are subject to state solid and hazardous waste management rules and may require licenses from the DNR for transportation and treatment, storage or disposal of the equipment. 49

50 Electronics to recycle The following electronics can no longer be put in the trash in Wisconsin, or sent to Wisconsin landfills and incinerators. These items should be reused, donated or recycled. Televisions Computers (desktop, laptop, netbook and tablet computers) Desktop printers (including those that scan, fax and/or copy) Computer monitors Other computer accessories (including mice, keyboards and speakers) 50

51 Electronics to recycle Continued list.. DVD players, VCRs and DVRs Fax machines Cell phones Major appliances, including air conditioners, clothes washers and dryers, dishwashers, refrigerators, freezers, stoves, ovens, dehumidifiers, furnaces, boilers, water heaters and microwave ovens 51

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55 REMEMBER CRADLE TO GRAVE 55

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58 Basic Waste Requirements Used Oil Exempt from hazardous waste rules IF the waste is reused/reclaimed Used oil includes: motor oils, greases, emulsions, machine shop coolants, heating media, brake fluids, transmission fluids, other hydraulic fluids, electrical insulating oils, metalworking fluids, and refrigeration oils. 58

59 Basic Waste Requirements Used oil does not include: fuel product storage tank bottoms, fuel product spill cleanup material, other waste that results from oil that has not been used, animal and vegetable oils and greases, antifreeze, and materials used as cleaning agents or only for their solvent properties. 59

60 Basic Waste Requirements Do NOT mix other wastes in with your used oil If used oil is mixed with hazardous waste, the entire mixture may be regulated as hazardous waste. Used oil containing more than 1,000 parts per million (ppm) total halogens is presumed to be a hazardous waste because it has been mixed with listed halogenated hazardous waste. 60

61 Basic Waste Requirements Do NOT mix other wastes in with your used oil, such as: Gasoline Paint Thinner Antifreeze Chlorinated Solvents Engine Degreasers 61

62 Basic Waste Requirements Do NOT mix other wastes in with your used oil Even if the waste is non-hazardous, mixing it with your used oil may make it unacceptable for your used oil hauler This could cost you lots of $$ 62

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65 Used Oil Filters Wisconsin statute (s (4m) bans ALL automotive engine oil filters from landfill disposal. Includes any vehicle propelled by an internal combustion engine Example: cars, trucks, bus, motorcycle, snowmobile, boats, planes, ATVs Ban includes households 65

66 Used Oil Filters Used Oil Filters from other sources such as a hydraulic system are not covered under the statute, but it s recommended they also be recycled. WHY are these not included in the ban?????? 66

67 Used Oil Absorbents Wisconsin statute (s (4m) bans ALL oil absorbent materials that contain free-flowing oil or that may be hazardous waste Includes absorbent materials containing petroleum-derived or synthetic oil from machines and equipment used in manufacturing and industrial operations, or unused oil spills 67

68 Used Oil Absorbents There is an EXEMPTION from the ban IF: The oil has been drained so that no visible signs of free-flowing oil remain in or on the absorbent materials, AND The oil absorbents materials are not haz waste 68

69 Can an oil filter or absorbent material be processed or recycled to the point that it is no longer subject to the landfill ban? The statute prohibits any disposal of used oil filters in a solid waste disposal facility, including drained or shredded filters. Absorbent materials that have been drained so that no visible signs of free-flowing oil remain in or on the oil absorbent materials and that are not hazardous waste are not subject to the ban. Absorbents that have been laundered or cleaned to remove oils are also allowed to be disposed of in a landfill. 69

70 How can used oil filters be recycled or managed? Used oil filters may be drained by hot draining, crushing, or puncturing the filters at the generator site. The resulting oil drained from the filters has to be managed according to the requirements in ch. NR 679, Wis. Adm. Code. The metal filters can then be sent to a metal recycler or reclaimer. The paper portion of the filters can be burned for energy recovery at an approved facility. 70

71 How can absorbent materials be recycled or managed? Some companies that supply clean absorbents pick up used oil absorbents for cleaning and reuse. Used oil recovered from absorbents must be re-refined or burned for energy recovery according to the requirements in ch. NR 679. Granular absorbents may be recycled or burned for energy recovery at an approved facility. Cloth absorbent should be reused (after laundering) as long as possible and may also be burned for energy recovery. Absorbents may also be treated in DNR approved bio-piles. 71

72 Would absorbent material used to contain or clean up a spill of gasoline or diesel fuel be subject to s (4m)? Absorbent material used to clean up gasoline or diesel fuel is not subject to s (4m) since the landfill ban is only for absorbent materials containing free-flowing oil. A waste determination must be made 72

73 Does the NR prohibition on landfill disposal of materials containing freeflowing oil apply? Yes Wisconsin Act 152 allows for landfill disposal of materials containing used oil as long as the used oil has been properly drained or removed so that no visible signs of free-flowing oil remain and the absorbent materials are not hazardous. This is consistent with NR (2)(b). 73

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76 You Must Store the Wastes Properly RCRA and OSHA require that all containers used to store waste be properly marked and labeled as soon as ANY waste is placed in the container Containers must be compatible with contents and meet applicable DOT Packaging Standards Containers must be marked with the words Hazardous Waste Containers must be marked with the date waste was first added to the container Containers must be inspected regularly to ensure there is no leaking or damage The container must be closed except when adding/removing waste 76

77 You Must Store the Wastes Properly If storing in Bulk Containers (over 110 gl) specific secondary containment requirements must be met May be subject to:» Spill Prevention Control & Countermeasure (SPCC) Plan ~ US EPA Clean Water Act» Storm Water Pollution Prevention Plan ~ US EPA Clean Water Act» Wisconsin Dept. of Agriculture, Trade and Consumer Protection: Bureau of Weights and Measures: Storage Tank Regulation 77

78 SPCC Plan Required if a facility has the capacity to store any petroleum product exceeding the following quantities 1320 gallons in aboveground storage containers (containers less than 55 gl. capacity do not count towards threshold) OR An underground storage capacity greater than 42,000 gallons 78 78

79 Storm Water Pollution Prevention Plan Required by Clean Water Act SWPPP Prevents chemical discharges from entering the lakes and oceans from stormwater drains Each facility must have its own plan Severe fines and penalties if a discharge enters the stormwater drain. Requirement based on SIC/NAICS code 79 79

80 You Must Store the Wastes Properly Wisconsin does not require secondary containment for your waste drums. Use good container management practices 80

81 You Must Store the Wastes Properly Keep incompatible wastes separate and on impermeable surfaces Do not keep containers of incompatible wastes near each other. Ensure that they are labeled properly to avoid any accidental mixing.» Do not keep containers of liquid hazardous waste on a surface that has a floor drain» Keep hazardous wastes indoors if at all possible» If you must keep hazardous waste outside, secure the area with a locked fence or putting it inside a locked shed. Store on containment pallets if possible» Keep ignitable waste out of direct sunlight as well as away from the property line. 81

82 To Tie It All Up You must know if the waste you generate is regulated (hazardous) under RCRA You must segregate (keep separate) your waste streams You must store all wastes properly (both haz and non-haz) You must know what wastes cannot be put into the normal trash Haz Waste Scrap Electronics Used Oil Filters and Oil-Containing Absorbents Scrap/Used bulbs and batteries 82

83 What are typical hazardous wastes at marinas? Leftover paint Cleaners such as spent degreasers and aqueous detergents Used oil Used antifreeze Test tank water (if it's been tested as hazardous) Bilge wastewater 83

84 How can we reduce the amount of waste generated at our facility? Separate your hazardous and solid wastes. This will eliminate excess volumes of hazardous material generated, by distinguishing those that can be discarded as solid waste. Do not mix your waste oil and gasoline. Do not mix your cloth wipes with your hazardous waste. Keep used Speedi-Dri separate from hazardous wastes. Train your employees on the proper process techniques to reduce needless spills. Purchase only the amount of product needed. Reuse test tank water. 84

85 Spill Prevention Use only containers (drums and tanks) of good integrity Make sure contents are compatible with the containers If possible, store on or in containment structures Use good container management (keeping drums closed at all times, keep out of way of traffic) Employee training 85

86 Leaks and Spills When a spill occurs, the response action required to mitigate varies depending on whether the spill is on land or on water 86

87 Where Will to Spilled Material Go? 87

88 Spill On Land Response: Containment and Follow Up Attempt to stop the release at its source Contain material released to the environment Recover or clean up the spilled material Clean up the spill area Restock Spill Kit Supplies Arrange for proper disposal of waste materials Emergency coordinator makes notifications and reports to outside agencies Review Emergency Response Plans to evaluate and improve response 88

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94 Spill On Water Response: When spills reach the water, mechanical containment and recovery equipment used to collect spilled material Booms - contain and absorb the spilled material Barriers prevent the movement and dispersing of spilled materials Skimmers collect the spilled materials from the top of the surface water Chemical and Biological methods are federally regulated and are most often not used in fresh water environments 94

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101 So It Happened What Else? Wisconsin s spill reporting regulations are located in Wisconsin Administrative Code NR 706. The WI DNR website contains numerous guidance documents that contain valuable information about complying with spill reporting requirements

102 What is a spill? Spill are discharges of hazardous substances that adversely impact, or threaten to adversely impact, human health, welfare or the environment and require an immediate response. 102

103 Do I have to report my spill? Your spill is reportable to the DNR if: you have not immediately cleaned up the spill; Note: Has it evaporated or been cleaned up in accordance with NR ? there is an impact to human health; Note: An evacuation is considered a threat to human health. there is an impact to the environment; Note: Water of the state includes a threat or spill into a sanitary sewer, storm sewer, and/or surface water. there is a fire, explosion or safety hazard; Note: A slippery road condition is considered a safety hazard. 103

104 Do I have to report my spill? the spill was NOT released to Secondary Containment; and Note: Secondary containment means a containment structure that is impervious to the material released. the spill was more than the reportable quantities listed below. Reportable quantities (Federal CERCLA; Hazardous Substances) 104

105 Do I have to report my spill? If your spill is more than the amounts listed below, you must report it to the DNR. Petroleum compounds» Petroleum product completely contained on an impervious surface» Less than 1 gallon of gasoline or light grade petroleum product onto a pervious surface or runs off an impervious surface.» Less than 5 gallons of medium or heavy grade petroleum products onto a pervious surface or runs off an impervious surface. 105

106 Do I have to report my spill? Remember, reporting a spill is always in your best interest it can minimize potential legal consequences, protect you from future false accusations, and establish a record on your follow-up activities cleaning up the spill. 106

107 Do I have to report my spill? Not reporting spills is where problems start. If you have general questions about spill reporting, call your regional DNR office and ask for the spill coordinator. They can assist you in your spill-related questions. 107

108 For Information

109 SAFETY-KLEEN LEGACY For 50 years, Safety-Kleen s entire business model has revolved around keeping North American companies Green Safety-Kleen is the Green Enabler by providing its customers with sustainable oil, waste and solvent closed-loop recycling solutions Recycle valuable renewable resources Protect valuable water resources Lower greenhouse gas emissions Cost-savings realized from recycled products rather than virgin products 109

110 NORTH AMERICA S LARGEST INFRASTRUCTURE Consistent, effective solutions across the United States, Canada & Puerto Rico through Safety-Kleen s vast network of resources 2 Oil Re-Refineries 20 Oil Terminals 158 Branches 9 Recycling Centers 2,900 Vehicles 1,000 Railcars 4,300+ Employees Over 50 EH&S Professionals 110

111 Madison, WI 3715 Lexington Ave Kaukauna, WI 2100 Badger Road Waukesha, WI 2200 S. West Avenue

112 LARGEST BASE OIL RE-REFINER IN THE WORLD Operated under robust technical services and quality control Approximately 75% of re-refining capacity in North America Primary products are base and blended lubricants Direct terminal sales of up to 51 million gallons to local fuel markets 112

113 PARTS CLEANING Placement, maintenance and service of parts washers and associated cleaning fluids Service representatives collect used solvent and aqueous solutions and replenish machines at regular service intervals Safety-Kleen is the largest collector and recycler of used solvent in North America Service more than 217,000 parts washers on a recurring basis More than 755,000 parts cleaning services annually On-going new product innovations with 4-in-1 aqueous technology (Q3) 113

114 CONTAINERIZED WASTE SERVICES Customers contract for removal of containerized waste Containerized liquid and solid materials including a variety of hazardous and industrial wastes Service includes flexible collection schedules, paperwork preparation, container inspection and loading Waste is either recycled or disposed of in accordance with regulations applicable to the waste type More than 80% of all containerized waste streams are recycled 114

115 OTHER SERVICES Allied Products Sales of complementary products to Company s existing customer base Cleaner/degreasers, glass cleaners, hand cleaners, absorbents, mats and spill kits Windshield washer fluid Recycled antifreeze Penetrant & Lubricant Other Services Bulk shipping Tolling Metals recovery Imaging Dry cleaning Sales from recovered chemicals 115

116 Questions? 116