ACHIEVING SOLID WASTE COMPLIANCE: The Many Regulations that Apply to Solid Waste Activities Ramon Rivera Omid Rabbani, P.E., PMP
SOLID WASTE MANAGEMENT Landfills Biohazardous Medical Waste Composting Transfer Stations Special Waste Waste Tires Lead-Acid Batteries Septage haulers Used Oil
Solid Waste Landfills Municipal Landfills Statutory Requirements, requiring solid waste facility plan (A.R.S. Title 49, Chapter 4, Article 4) Criteria for Municipal Solid Waste Landfills (40CFR258) Solid Waste Facility Plan Review Fee (A.A.C. Title 18, Chapter 13, Article 7) Landfill Registration Fee (A.A.C. Title 18, Chapter 13, Article 21) Master Facility Plan Approval (MFPA) (valid for the life of the facility) Type I, Type II, Type III, and Type IV Changes Non-Municipal Landfills Statutory Requirements, requiring solid waste facility plan (A.R.S. Title 49, Chapter 4, Article 4) Criteria for Non-Municipal Solid Waste Landfills (40CFR257) Solid Waste Facility Plan Review Fee (A.A.C. Title 18, Chapter 13, Article 7) Landfill Registration Fee (A.A.C. Title 18, Chapter 13, Article 21) Aquifer Protection Permit (APP) (A.A.C.18-13 Article 2, 40CFR257) Minor, Significant, and Type Other amendments General Permit for Non-Municipal Landfills at Mining Operations Statutory Requirements, alternative to solid waste facility plan-gp (A.R.S. 49-762) NOI to Operate AAC R18-13-801; Deadline for existing facilities November 9, 2016. Authority to Operate (ATO) under the General Permit
Common concerns found at landfills Windblown Litter. Insufficient amount of Daily Cover. Erosion on Landfill Slopes. Water/Gas monitoring records not available on or near the Landfill. Training records not available during inspection. Master Facility Plan Approval (MFPA) or Aquifer Protection Permit(APP) not available during inspection.
Windblown Litter Continuous control of on-site windblown litter may be the best way to avoid off-site windblown litter.
Insufficient Daily Cover Insufficient Daily Cover usually leads to a permit violation, and can cause control of windblown litter to be more difficult.
Erosion of Landfill Slopes Erosion of landfill Slopes to the point where solid waste is exposed and the solid waste is moving away from the Landfill due to precipitation and wind usually leads to a violation.
Biohazardous Medical Waste (BHMW) BHMW Transporters Statutory authority (A.R.S. Title 49, Chapter 4) (A.R.S 49-761) A.A.C. Title 18, Chapter 13, Article 14 Transportation Management Plan (TMP) Vehicles Inspection Transportation License (valid for 5 years) BHMW Facilities (Treatment, Storage, and Transfer) Statutory Requirements, requiring solid waste facility plan (A.R.S. Title 49, Chapter 4) (A.R.S 49-762) A.A.C. Title 18, Chapter 13, Article 14 Facility Plan submittal Facility Plan Approval
Biohazardous Medical Waste Transporter
Medical Sharps Medical Sharps R18-13-1419 Medical sharps shall be handled as follows: 1. A generator who treats biohazardous medical waste on site shall place medical sharps in a sharps container after rendering them incapable of creating a stick hazard by using an encapsulation agent or any other process that prevents a stick hazard. Medical sharps encapsulated or processed in this manner are considered to be solid waste.
BMW Transportation and Disposal Generators must use an ADEQ-registered transporter. Transporters must register and submit an application and Transportation Management Plan to ADEQ for approval. Transporters must deliver BMW to an ADEQapproved biohazardous medical waste storage, transfer, treatment or disposal facility within 24 hours of collection or refrigerate the waste for not more than 90 days Biohazardous medical waste facilities must apply for Solid Waste Facility Plan approval Directory of ADEQ-approved, Arizona Biohazardous Medical Waste Handlers http://www.azdeq.gov/environ/waste/solid/biohaz_waste.html
Composting A.R.S. A.R.S. 49-762 A.A.C. R18-13-312 (3) SW Notice 49-762.07* Facility Name and mailing address Legal description Description of waste management (storage, treatment, measures taken to protect environment and public health) Site layout *onsite single family household waste composting is exempt from filing the facility notice per A.R.S. 49-701.29(p). APP (if required) or Determination of Applicability (DoA)
Transfer Stations Daily throughput of >180 Cubic Yards (CY) Self-certification (A.R.S. 49-762.01) A.A.C. R18-13-501 ADEQ Registration, subject to registration and annual fees Daily throughput of <180 CY SW Notice 49-762.07 BMP No fees
Effective use of signs to achieve compliance Conspicuously posted and clearly readable signs can be used to direct costumers about were to properly place solid waste and recyclable materials.
On-Site Litter Fences, nets and daily pickup of on-site litter will help to reduce off-site windblown litter.
Special Waste Statutory Requirements, Special Waste Management (A.R.S. Title 49, Chapter 4, Article 9) PCS (petroleum contaminated soils) Shredding motor vehicles A.A.C. R18-13-1301 through 1307 Generator Manifesting requirements (A.A.C. R18-13-1302) ADEQ Special Waste ID number Complete and sign the Generator portion of manifest Shipper signature, retain the generator s copy of the manifest. Send a copy to ADEQ within 14 days If a copy was not received by the generator within 35 days, contact the destination facility. Submit an exception report to ADEQ if the facility signed copy of the manifest was not received within 45 days. Retain the copy a legible copy of the signed manifest (signed by the facility) for three (3) years from the date of acceptance. Shipper Manifesting requirements (A.A.C. R18-13-1303) ADEQ Special Waste ID Number Transport only waste accompanied by the manifest Deliver the waste to the receiving facility Receiving Facility Manifesting requirements (A.A.C. R18-13-1304) ADEQ Special Waste ID Number Accept only signed and completed manifests accompanied the shipment Send a copy of signed manifest to the generator and ADEQ within 30 days of the delivery Upon discovery of a significant manifest discrepancy contact the generator and shipper to reconcile the discrepancy. If cannot be resolved within 15 days, submit a letter to ADEQ within 5 days explain the discrepancy and attempt to reconcile. Best Management Practices for Waste from Shredding Motor Vehicles (A.A.C. R18-13-1307)
Special Waste
Waste Tires Statutory Requirements: A.R.S. Title 44, Chapter 9, Article 8 (Waste Tire Disposal) A.R.S. Title 49, Chapter 4, Article 4 (Regulation of Solid Waste) Rules: A.A.C. Title 18, Chapter 13, Article 12 (Waste Tires) 100< OUTS (Outdoor Used Tire Sites) 500< WTCS (Waste Tire Collection Site) <5000 <12 m >12 m Best Management Practices (A.R.S. 49-762.02) Facility Plan Approval (A.R.S. 49-762) WTCS >5000 (A.A.C. R18-13-501) <12 m >12 m Self Certification (A.R.S. 49-762.05) Facility Plan Approval (A.R.S. 49-762)
Waste/Used Tire Management
Waste/Used Tire Storage Requirements Facilities that store 100 or more used motor vehicle tires outdoors must: Restrict smoking within 50 feet of the tire storage area. No Smoking signs shall be posted in suitable and conspicuous locations. Place Class 2A-10BC type fire extinguishers 75 feet travel distance from any point of a tire pile at well-marked locations Store tires in piles that: Do not exceed 20 feet in height Are not within 3 feet of the property line Have at least 20 feet wide access routes, free of debris and vegetation. Have a maximum grid system of 50 feet by 150 feet Do not exceed 6 feet in height if stored within 3 to 10 feet of the property line.
Lead-Acid Batteries A.R.S Title 44, Chapter 9, Article 9 (Sale and Disposal of Batteries) A.R.S. 44-1322: the disposal of lead acid batteries in incinerators and landfills is prohibited. Deliver to A lead acid battery retailer or wholesaler; A permitted secondary lead smelter; A battery manufacturer; or, A collection or recycling facility authorized by the ADEQ.
Septage Haulers Statutory Rule Making Authority (A.R.S. 49-761) Rules (A.A.C title 18, Chapter 13, Article 11) County Inspection ADEQ Registration
Used Oil Statutory Requirements and rule making (A.R.S. Title 49, Chapter 4, Article 7) (Management of Used Oil) 40 C.F.R. 279 Standards for the Management of Used Oil In addition to 40 C.F.R. 279: Used oil collection centers need to be registered with ADEQ A person sending used oil to a burner, for energy recovery, shall certify to the burner that the used oil is tested for compliance with 40 C.F.R. 279. Transporters, processors, Marketers, and refiners shall submit to the department quarterly report within 30 days after the end of the calendar quarter. Burners submit annual reports by February 1 st for the previous calendar year. Used oil fuel marketers and burners shall label all tanks that store on-spec used oil with On-specification used oil A household do it yourselfer used oil generator, shall send used oil to a collection center, marketer, processor, or refiner.
Illegal Ways to Dispose of Used Oil Under A.R.S. 49-803(A), it is illegal to dispose of oil: Into sewers or waters of the state By incineration* On land/bare soil** Dust suppressant *Exemptions: Burning for energy recovery **Exempt : Normal minimal leakage from properly maintained vehicles and equipment
Used Oil Specifications 40 C.F.R. 279.11 The maximum contaminant concentrations, including a limit on the minimum flashpoint (a safety consideration) that a used oil fuel may have, are referred to as the used oil specifications. Note: This specification is for Total Metals, not Total Characteristic Leaching Procedure (TCLP). ** Note: Only for total halogen concentrations 1000 ppm or more for which the presumption of mixing has been successfully rebutted.
Used Oil Reporting Requirements Used Oil Quarterly Reports - A.R.S. 49-802(B)(2) Transporters, marketers, processors and re-refiners Submitted within 30 days of the end of the calendar quarter Submit via e-mail to UsedOil@azdeq.gov
Used Oil Reporting Requirements Used Oil Annual Reports - A.R.S. 49802(B)(3) Burners Submitted by Feb 1 st for the previous calendar year. Submit via e-mail to UsedOil@azdeq.gov
Used Oil Storage and Labeling Requirements Used oil must be stored in tanks or containers that are in good condition (i.e. not leaking) Used oil tanks, containers, and fill pipes from underground storage tanks must be labeled with the words Used Oil.
Used Oil Releases Managers of Used Oil must respond to releases Stop the release Contain the released used oil Repair/replace storage container prior to returning them to service Clean-up used oil and contaminated materials Potentially a Petroleum Contaminated Soil
Contact Information Ray Rivera, Compliance Officer (602) 771-4881 rgr@azdeq.gov Omid Rabbani, Permit Writer (602) 771-4136 or1@azdeq.gov http://www.azdeq.gov/programs/waste-programs/solid-waste-program
Questions?
Ramon Rivera Bio Ramon (Ray) Rivera joined ADEQ Solid Waste Unit in 2013 as an Environmental Scientist and Specialist I in the Waste Programs Division Inspections and Compliance Section. Ray currently is working in the Solid Waste Unit value stream as an Environmental Scientist and Specialist II, which includes compliance, inspection, and data management. Prior to 2013 worked in the Administrative Division of ADEQ for 6 years. Ray has a Bachelor s Degree in Business Management and minored in Biology and Geology.
Omid Rabbani joined ADEQ in 2015 as an Environmental Engineer III in the Waste Programs Division Hazardous and Solid Waste Permits Section. Omid currently is housed in the Solid Waste Unit working in the hazardous and solid waste section value stream which includes permits, compliance, inspection, enforcement and data management. Prior to ADEQ Omid worked three years in the environmental consulting arena. Omid has a Master s Degree in Environmental Engineering and also in Building Engineering and Construction Management. He also is a Professional Engineer in Civil Engineer, and just recently obtained his Project Management Professional Certification.