Ohio Hazardous Waste

A Publication of Ohio EPA, Division of Hazardous Waste Management

Spring 2003

f your business generatesand/or transports used oiloff-site to be burned for

energy recovery, you may besubject to the used oil regulationsfound in Ohio Administrative Code(OAC) Chapter 3745-279. HowOhio’s used oil regulations apply togenerators, transporters, andburners of used oil that is going tobe burned for energy recoverydepends on whether or not theused oil meets the specificationsfound in OAC rule 3745-279-11(see http://www.epa.state.oh.us/dhwm/dhwmrules/279-11.pdf). For used oil to be considered“on-specification” fuel, itsconstituent levels must be ator below (except forflash point) the follow-ing levels:

• 5 ppm or less ofarsenic

• 2 ppm or less ofcadmium

• 10 ppm or less ofchromium

• 100 ppm or less oflead

Are You Transporting Used Oil Off-Siteto be Burned for Energy Recovery?

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continued on page 2...

• 1000 F minimum flash point

• 4,000 ppm or less of total halo-gens

• less than 2 ppm PCBs.

Used oil that has been provento meet these specifications and isburned for energy recovery is notsubject to Ohio’s used oil require-ments. However, the person mak-ing the claim that the used oilmeets the specifications mustkeep records of the analysis thatthe used oil meets the specifica-tion and a record of all shipments.Used oil which does not meet thespecifications is called “off-specifi-

cation” used oil.Off-specification used oil

transported off-site to an-other business that burns itfor energy recovery must be

burned in a boiler oran industrialfurnace as de-scribed in OAC rule3745-279-61 (seehttp://www.epa.state.oh.us/dhwm/dhwmrules/27961.htm). Off-specification used

oil transported off-site to anotherperson’s business cannot beburned for energy recovery in aspace heater. Therefore it is important forused oil generators that self-transport their used oil to beburned for energy recovery off-siteto know the energy recoverydevice(s) used to burn the used oil.However, you can burn off-specifi-cation used oil that you generate orthat is generated by household do-it-yourselfers in a space heaterthat you own, provided that thespace heater has a capacity of lessthan 0.5 million BTU per hour andyou vent it to the outside air. Youcan also burn used oil that yougenerate at other businesses youown. Additionally, you can transportamounts of 55 gallons or lesswithout complying with the used oiltransporter requirements. But ifyou transport more than 55 gallonsat a time, you must comply withthe used oil transporter require-ments in OAC rules 3745-279-40through 3745-279-47 (see http://www.epa.state.oh.us/dhwm/dhwmrules/index1.htm).

2.

ebris generated fromconstruction, renovation ordemolition of buildings (with

a few exceptions) that is destinedfor disposal is a waste as defined inOhio’s hazardous waste rules.Anyone who generates a wastemust evaluate that waste to deter-mine if it is a hazardous waste. Ifthe debris is generated from re-modeling or demolition of a house-hold, it is exempt from regulationas a hazardous waste and may bedisposed of in a construction anddemolition debris (C&DD) landfill.In addition, wastes generatedduring the abatement of lead-basedpaint at households is exempt fromregulation as a hazardous waste(please see our fact sheet on leadabatement wastes at http://www.epa.state.oh.us/dhwm/pdf/Lead AbatementFactsheet.pdf). You must evaluate non-household waste generated fromdemolition, renovation or construc-tion before disposal. Your evalua-tion may include any knowledgeyou have concerning the materialsthat were used in construction ofthe building and analyses of repre-sentative samples of the waste. If you would like more informa-tion about waste evaluation pleasesee the Summer 2002 “Ask theInspector” article at http://www.epa.state.oh.us/dhwm/pdf/Summer2002Notifier.pdf. If you would like to know moreabout representative sampling of

construction, demoli-tion and renovationwaste please refer to

the following Web sites:

• ASTM Standard E 1908-97: Standard Guide for SampleSelection of Debris Waste from

a Building Renovation or LeadAbatement Project for ToxicityCharacteristic Leaching Procedure (TCLP) Testing for Leachable Lead (Pb) at http://www.astm.org/

• Evaluation strategies on theWashington State Departmentof Ecology Web site at http://www.ecy.wa.gov/programs/hwtr/ demodebris/pages2/sample plans.html#Screen/

Lead-based paint is the mostcommon contaminant found inbuildings that could cause waste tobe defined as hazardous. Othercomponents that may also behazardous and should be removedprior to demolition are fluorescentlamps and thermostats that con-tain mercury, another hazardousconstituent. We suggest that youconsider having both of thesecomponents recycled. Olderflourescent light fixtures maycontain ballasts that contain PCBs.Steel structural components, leadpipes and electrical componentsmay also be recycled as scrapmetal without regulation under thehazardous waste rules. When yourecycle these items you are subjectto fewer regulations. We have also recently becomeaware that a polymer marketed asTARTAN® by the 3M companycontains mercury that can poten-tially be hazardous waste becauseof its mercury content. This poly-mer was used in the 1970s and1980s for gymnasium floors andtracks. If you are demolishing aschool or recreation center, youshould take care to evaluate anygymnasium floors that are present.

Can Construction,Renovation or DemolitionDebris be a Hazardous Waste?

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Used Oilcontinued from page 1

If your business transportsused oil off-site to a used oil burneror a used oil processor/rerefiner,you are a used oil transporter. As aused oil transporter, you mustobtain a U.S. EPA identificationnumber from Ohio EPA, determineif the used oil is on- or off-specifi-cation, comply with all Departmentof Transportation requirements,manage all residues from trans-porting, and retain all records ofshipments and deliveries. It ispossible, however, to transport usedoil and not be subject to theserequirements if you are transport-ing used oil on-site, or if you arethe generator of the used oil andare transporting less than 55gallons of used oil to a collectioncenter or aggregation point. If you transport or have some-one else transport a shipment ofoff-specification used oil directly toa used oil burner, you are a usedoil fuel marketer. Used oil fuelmarketers must obtain a U.S. EPAidentification number from OhioEPA, must only initiate shipmentsto a used oil burner that has a U.S.EPA identification number, mustonly send shipments to a used oilburner who burns the used oil inan industrial furnace or boiler, andmust keep records of each ship-ment of used oil to that burner. For additional information onOhio’s used oil regulations, pleasecall (614) 644-2917 and ask tospeak with someone in the regula-tory and information services unitor visit our Web page to view ourthree used oil fact sheets at http://www.epa.state.oh.us/dhwm.

3.

n the past few years, manybusinesses have replacedpaper record keeping with

electronic record keeping. Re-cently, hazardous waste inspectorshave been receiving some ques-tions from waste handlers andfacilities regarding electronicrecord keeping. Most questionshave focused on the acceptability ofstoring compliance records elec-tronically.

Background

Currently, Ohio EPA acceptsGenerator Annual Reports, FacilityAnnual Reports and Annual GroundWater Monitoring Reports elec-tronically in a prescribed format.Some handlers continue to trackand document compliance-relatedactivities on paper, others use amix of both paper and electronicrecord keeping. Some treatment,storage and disposal (TSD) facilitiesare using bar-coding systems thatallow our inspectors to determinethe location and disposition of aspecific container within a regu-lated unit as required by theoperating record rule. According to hazardous wastefield inspectors, some of the elec-tronically-maintained recordsinclude:

• waste analysis records(waste profiles, analytical labora-tory reports for TSD facilities)

• waste evaluation records(analytical laboratory reports,material safety data sheets(MSDS) for waste handlers)

• waste inventory records(logs for tracking the duration ofwastes being stored, barcodingsystems for track-ing wastes man-aged at a TSDfacility)

• personnel training records(dates of required annual train-ing and list of attendees)

• inspection records (inspec-tion of regulated units andrequired emergency equipment)

• waste shipment records(manifests, land disposal restric-tion (LDR) notifications, tolling agreements)

• customer information (typeof industry, facility contacts,billing invoices for TSD facili-ties)

• ground water monitoringdata (quarterly and annualreport information)

Current ElectronicRegulatory Initiatives

There are currently severalregulatory initiatives addressingelectronic record keeping thatwaste handlers, facilities andinspectors should keep updated onbecause they may impact howrecords are maintained in thefuture.

Uniform ElectronicTransactions Act (UETA) As of December 2002, 41 stateshave enacted UETA. UETA becameeffective in Ohio in 2000. Thepurpose of UETA is to provide forthe regulation of electronic recordsand electronic signatures. It giveselectronic signatures and recordsthe same validity and enforceabil-ity as manual signatures andpaper-based transactions if therequirements of the law are met.

The Ohio Department ofAdministrativeServices (DAS)promulgated OACrule 123:3-01-1 to

clarify the obligations of stateagencies under the statute. Thestatute and rule together establisha security procedure which re-quires state agencies to reportelectronic transactions to DAS,conduct a security assessment ofeach set of proposed similar elec-tronic transactions, use minimumtechnology standards and/orsecurity procedures that areappropriate for the levels of secu-rity as determined by the securityassessment, obtain DAS approvalfor its proposed procedures or seeka waiver, and establish and main-tain documented security policiesand procedures. UETA applies tomany transactions between partieswho agree to conduct their busi-ness electronically. However, the rule applies onlyto electronic transactions involvinga state agency which also: facili-tate access to restricted informa-tion; purchase, sell or lease goods,services or construction; transferfunds; facilitate the submission ofan electronic record or electronicsignature required or accepted by astate agency; or create recordsupon which the state of Ohio oranother person will reasonably relyincluding but not limited to formalcommunication, letters, notices,directives, policies, guidelines andany other record that is formallyissued under a signature.

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Electronic Records

continued on page 4...

4.

Cross-Media ElectronicReporting & Record KeepingProposed Rule (CROMERR) This proposed rule wouldprovide the legal framework forelectronic reporting and recordkeeping under most of U.S. EPA’senvironmental regulations. Theinitial proposed rule commentperiod ended February 27, 2002.Under CROMERR, U.S. EPA willhave to approve each state systemfor managing electronic reports,presenting each state with thepotential of having to revise oreven replace existing systems. However, CROMERR will notcreate any new authority for U.S.EPA oversight of state programs.After analyzing initial commentson the proposed rule, U.S. EPAdecided to separate the electronicreporting from the electronicrecord keeping. Currently, thestates and U.S. EPA are focusing ondeveloping guidance addressingthe electronic reporting aspect. After addressing the electronicreporting, they will move on to theelectronic record keeping issues.May 2003 is the target date forpromulgating the electronic report-ing rule. Implementation guidancewill be made available for review bystate participants shortly after thefinal rule is published.

Electronic ManifestingProposed Rule On May 22, 2001, U.S. EPAproposed a rule giving waste han-dlers who are required to use themanifest form the option to com-plete, send, and store this informa-tion electronically. This rule alsoproposed changes to the manifest.U.S. EPA proposed these changes toreduce the paperwork burdenrelated to the hazardous wastemanifest provisions, and in re-sponse to many requests tostreamline and update the hazard-ous waste tracking system. Thepublic comment on this rule endedJuly 30, 2001.

Currently, the rule is beingsplit into two parts. The first part,that addresses changes to themanifest is expected to be finalizedin late 2003. The portion address-ing electronic manifesting isundergoing more analysis and isexpected to be finalized in late2004 or early 2005. It is important to note thatonce CROMERR is finalized, theremay be discrepancies betweenUETA and CROMERR that will needto be resolved.

CommonlyAsked Questions

1. Can a waste handler/TSDfacility store compliance recordselectronically?

Yes, this is an acceptableformat to demonstrate compliancewith OAC requirements. Howeverthe handler must be able to pro-duce a hard copy of documentsrequired to be kept upon the re-quest of Ohio EPA, unless Ohio EPAhas, prior to accepting the elec-tronic record, had the transactionapproved or waived by DAS.

2. How should I handle enforce-ment and/or compliance e-mailcorrespondences?

Submittals regarding compli-ance or enforcement must be madeon paper, and any e-mail ex-changed regarding enforcement orcompliance or contracting mattersmust be followed by hard copy. Paper copies are currently themost widely used format in whichcompliance-related information issupplied to our inspectors. Cur-rently, file cabinets containingpaper copies remain the primarydata management system for theAgency. When the public completes afile review, hard copies of alldocuments should be in the file for

review. It is anticipated that thiswill change over time with theimplementation of Ohio EPA’selectronic information manage-ment system. While Ohio EPA cannot dictateto a facility the manner in which itstores its business records, theAgency cannot engage in certainelectronic transactions withoutcomplying with the DAS approval orwaiver procedure. Any facility that requests“paperless” maintenance of itsoperating record, for example,needs to be informed that untilOhio EPA has obtained the appro-priate DAS approval or waiver, thefacility will still be required tosubmit a paper copy on request.Until the application of UETA andits rule are fully understood andimplemented, our approach willcontinue to be to require submit-tals of paper copies in complianceor enforcement matters, and thatany e-mail exchanged regardingenforcement, compliance or con-tracting matters be followed by hardcopy. DHWM will continue to monitorthe development of various federaland state initiatives and theimpacts they may have on ourcurrent information managementsystems, as well as those plannedfor the future. As new rules andprocedures are adopted we willkeep you updated. Please contactJeff Mayhugh or Helen Miller at(614)644-2917 or your inspectorwith any questions.

Electronic Recordscontinued from page 1

5.

n 2000, the Division ofHazardous Waste Manage-ment (DHWM) and the Office

of Pollution Prevention (OPP)conducted a Pollution Prevention(P2) Assessment at Mill’s Pride, amanufacturer of hardwood kitchencabinets located in Waverly, Ohio.The assessment focused on thecompany’s coating applicationprocesses which generated largequantities of hazardous wastespent solvents and coatings, as wellas spent rags and paint filters. A recent followup call to thecompany revealed that several P2projects were implemented in mid-2002 as a result of our assessment,and that the company will haverealized a savings of approximately$472,000 in the first year aftermaking improvements. These aresummarized below. Ohio EPA identified five sug-gestions for improving efficiency onseveral of Mill’s Pride’s coatinglines by decreasing over spray oncabinet parts that were beingcoated. Based on these sugges-tions, Mill’s Pride chose to installnew reciprocators on one of theircoating lines. The reciprocators are a compo-nent of the spray gun thathas an electric eyewhich “reads” theedges of the boards,automatically shuttingoff the spray at the edgeof the board. Thisdecreases the amountof over spray that occurson the coating line. As a result, Mill’sPride has increased

Generator Estimates Savingsof $472,000 by Implementing P2

the transfer efficiency oftheir coating processby an estimated 35percent, resulting ina similar reductionin the volume of wastegenerated by the com-pany, as well as decreas-ing the volume of rawmaterials the company has topurchase for coating and cleanup. Mill’s Pride is now generating33 fewer drums of hazardous wastesolvents and coatings each month,for an estimated savings of $27,720per year in hazardous waste dis-posal costs. The purchase of 35percent less stain, top coat, andsealer amount to a savings of$432,000 per year. Total annualsavings from waste disposal andraw materials as a result of install-ing new reciprocators is approxi-mately $460,000 per year. The estimated environmentalbenefit of reducing coating lossesis a 30 percent reduction in totalannual volatile organic compound(VOC) emissions, or an annualreduction of 137 tons of VOCs. Ohio EPA also suggested thatMill’s Pride replace disposablefilters used in two paint boothswith reusable filters, and replace

disposable rags used forcleanup with reusable

rags. Together, thesetwo waste streamsresulted in thegeneration and

disposal of 14 drumsof hazardous wasteper month. Thecompany found anindustrial launderer

who recovers spentsolvent from rags. Mill’s Pride alsopurchased plasticreusable filters forone manual paintbooth although they

found they were unableto apply reusable filters

to the other booth due tothe moisture content of theircoatings. As a result of thesechanges in rag and filter use, andthe increased life of the disposablefilters due to decreased over spray,the company now manifests onlyfive drums of hazardous paintfilters per month, and has esti-mated that it saves $11,600 peryear in purchase and disposalcosts. Mill’s Pride continues toevaluate alternative cleaningsolvents. Alternative solventscould increase environmentalbenefits by decreasing air emis-sions, as well as decrease operat-ing and disposal costs. Also, based on recommenda-tions made in the P2 assessmentreport, Mill’s Pride has formed a“continuous improvement” workteam which meets once per weekwith the goal of looking at allproduction processes in order toreduce costs and waste. The teamis actively working to identifyfurther reductions in solventlosses, waste generation and otherlosses on the finish line.

Written by: Donna Goodman,DHWM-SEDO and Debbie Hannah,Mills Pride

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6.

Will my facility becited for potential

violations if we have fireextinguishers but no watersupply in our hazardous wastestorage building?”

Not necessarily. According toOhio Administrative Code (OAC)rule 3745-65-31 (see http://www.epa.state.oh.us/dhwm/dhwmrules/6531.htm), all facilitiesmust be maintained and operatedin such a way to prevent releasesof hazardous waste to the air, soil,or surface water which couldthreaten human health or theenvironment. OAC rule 3745-65-32specifies required equipmentincluding communication systems(alarms), phones or two-way radios,fire extinguishers, spill controlequipment, and water spraysystems unless none of the haz-ards posed by the hazardous wastehandled at the facility require aparticular kind of safety equipment(see http://www.epa.state.oh.us/dhwm/dhwmrules/6532.htm). For instance, if yourhazardous waste reactsviolently with water,overhead water sprin-klers would onlyworsen the situa-tion. In thiscase, if fireextinguish-ers are tobe usedin lieu ofwatersprinklers butin conjunctionwith other equip-ment, the fireextinguishers must becompatible with thehazardous waste managedat your facility.

Does the registered,independent Professional

Engineer (PE) who is requiredto certify such items ashazardous waste tankassessments and closurecertifications need to beregistered in Ohio?

Yes, the engineer required tocertify the construction, repair oroperation of certain hazardouswaste management units and thecompletion of closure must beregistered with Ohio’s Engineersand Surveyors Board. According toOhio law, “no person shall practiceor offer to practice the profession ofengineering. . .unless such personhas been registered. . .under thischapter. . ..”, (Ohio Revised Code(ORC) section 4733). Additionally,the definition of “professionalengineer” provided in Ohio lawincludes the criteria that such aperson be registered under ORCsection 4733. It is important tonote that the “practice of engineer-ing” is a defined term under ORC

4733.01. Furthermore, due to the

passage of Ohio H.B. 337(effective August 7, 2002 ),

all public agencies inOhio have the author-

ity and responsibil-ity to reject

engineeringplans notprepared by a

PE. Thisprovision of Ohio

law can be foundin ORC section

4733.23. For moreinformation on PE re-

quirements, please contactOhio’s Engineers and Sur-

veyors Board (614-466-3651,www.ohiopeps.org/).

How can I verify if aPE is registered to practice

in Ohio?

Ohio’s Engineers and Survey-ors Board maintains a list of regis-tered engineers and surveyors. Bycontacting the state board at thenumber provided above or via theboard’s Web page, you can learn if aperson is registered in Ohio as aPE.

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7.

Background

In July 2002, Central DistrictOffice’s (CDO) Division of Hazard-ous Waste Mangement (DHWM), incooperation with Ohio EPA’s SmallBusiness Assistance Office (SBAO)and the Ohio Auto and TruckRecyclers Association (OATRA),began a campaign to inspect andprovide compliance assistance toowners and operators of vehiclesalvage yards. Although facilitiesin this sector are rarely subject tohazardous waste inspections, theyhave significant potential forenvironmental harm if waste ispoorly managed. As a first step, SBAO tried toidentify the universe of salvageyards, using resources such as theyellow pages on CD-ROM andDHWM inspection records. Inaddition, Ohio’s Bureau of MotorVehicles (BMV) provided a mailinglist from their database of licensedvehicle salvage yards (771 state-wide, 69 in the Central Ohio area.) During the development of theinitiative, DHWM and SBAO staffmet with OATRA leadership andtoured three salvage yards. Infor-mation gathered from the initialsite visits was used to create anin-house training session to helpfamiliarize the inspection staffwith the auto recycling industry.As part of this training, DHWMcoordinated information sessionswith program staff from the divi-sions of solid and infectious wastemanagement (DSIWM), air pollu-tion control (DAPC), and surfacewater (DSW). These sessionsprovided the DHWM inspectors withsome basic cross-training to iden-tify potential compliance issuesrelated to scrap tires, air and stormwater management.

DHWM developed a specialchecklist to help the inspectorsgather data on various aspects ofenvironmental compliance, includ-ing management of automotivefluids, batteries, tires, and waste-water. In addition, SBAO developedand published a compliance guide,“Environmental Compliance Guidefor Motor Vehicle Salvage Yards”(October, 2001). Before any inspec-tions were conducted, the SBAO dida mass mailing of the complianceguidebook to salvage yards state-wide. Finally, Ohio EPA’s ChrisCotton and SBAO’s LaurieStevenson and Kirk Nofzingerproduced a video titled “Best Man-agement Practices for the AutoRecycling Industry,” which wasfunded by a grant from the OhioEnvironmental Education Fund.

Motor Vehicle Salvage Yard Initiative

The video will be distributed di-rectly to salvage yards statewide asanother compliance tool. It promotes simple, low-costbest management practices (BMPs)that can be used at salvage yards toachieve environmental complianceand stay profitable.

Table 1: Salvage Yard Statistics

Material Initiative Results

Used Oil 60% had labeling violations; 12% had release violationsand completed cleanup after the inspection; 48% do notremove and/or drain oil filters

Fuel All facilities drained and reused fuel from vehicles

MercurySwitches NO SALVAGE YARD COLLECTED MERCURY SWITCHES

Tires 52% resell or recycle all of their scrap tires; 20% resellsome tires but shred the rest with the vehicles; 28%report shredding all incoming tires with the vehicles

Batteries All facilities recycled batteries, however, there weresome labeling/containment issues

Storm waterPermits Not enough information was collected to determine if

sites had obtained requisite storm water permits

8.

Inspection Results

Inspectors targeted 40 out ofthe 69 licensed salvage facilitiesfor inspection. To date, DHWMinspectors have visited 33 vehiclesalvage yards. Of these, 25 re-ceived full compliance evaluationinspections. The other facilitieswere closed or not operating activesalvage facilities. Table 1 on page 7presents a summary of the findingsof DHWM’s inspections to date.Violations were found at 60 percentof the facilities inspected. Themost common compliance issuesincluded improper used oilcontainer labeling and used oilreleases to the environment. SBAO’s mailing of the guide-book appeared to have somebenefit in increasing awareness ofthe regulations. A number ofsalvage yard owners mentionedreceiving it prior to their inspec-tion and some had already takensteps to improve their compliancebased on information in the guide-book. However, CDO estimates thatmany of central Ohio’s salvageyards are not licensed throughBMV. In addition, OATRA, whichalso provides environmental com-pliance information, representsonly 20 percent of the industry,with approximately 120 members.It’s anticipated that salvage yardswhich are not licensed or affiliatedwith OATRA receive little or noenvironmental compliance infor-mation. DHWM expects theirincidence of non-compliance withenvironmental rules would behigher. One of the goals of the initia-tive was to identify where vehicledismantling was occurring (indoorsversus outdoors) and to promotevehicle dismantling inside build-ings through discussions duringthe inspection. Inspectors foundthat 40 percent of the sites visitedwere already working inside.

Over half (56 percent) of thefacilities inspected by CDO, how-ever, conducted at least someportion of their dismantling/fluiddrainage process outside in anuncovered area. Additionally, atleast seven of these sites wereconducting such activities overunpaved areas. The graph aboveprovides information regarding thelocation of dismantling operationsat these facilities.

Future Plans

Over the next several months,DHWM will be inspecting theremaining Central Ohio salvageyards. Inspectors will also berevisiting some salvage yards thatwere already inspected in an effortto determine the effectiveness andlasting impact of the initiative.DHWM hopes that in addition tocorrecting violations, many salvageyard owners have become moreaware of the importance of envi-ronmental compliance and goodfluid/waste management prac-tices. As many are finding, compli-ance is not very costly and inreality it makes good businesssense!

One of the challenges that stillremains is getting compliance-related information to those facili-ties which are currently notlicensed and/or not affiliated withOATRA. These facilities mayultimately be identified throughOhio EPA’s complaint inspectionprocess or discovered while inspec-tors are in the field. Once identi-fied, our compliance resources canbe made available to them. Additional information aboutthe initiative can be obtained fromLundy Adelsberger in DHWM/CDOat 614-728-3879. If you would liketo receive copies of the complianceguide or video, contact SBAO at614-728-8573 or 800-329-7518.OATRA’s Columbus, Ohio phonenumber is 614-469-0677.

Num

ber o

f Fac

ilitie

s

Salvage Yard Vehicle DismantlingLocation of Fluid Drainage Operations

Inside,paved

Outside,covered,

paved

Outside,uncovered,

unpaved

Combinationinside and

outsideuncovered

Totalnumber withsome portion

outsideuncovered

9.

The Division of HazardousWaste Management (DHWM) hasdeveloped a data validation processto help inspectors evaluate analyti-cal data submitted by laboratoriesused by the regulated communityas well as the DHWM contractedlab. While this guidance is mainlyintended for DHWM’s inspectors,you may find it valuable for yourdata collection activities. DHWMuses environmental data from anumber of sources to support itsdecision-making processes. Forexample, DHWM often reviewswaste evaluation data that will beused to make decisions on how toproperly manage waste. Datagenerated by other activities thatmay require data validation in-clude data from site closure activi-ties and facilities undergoingcorrective action. Data validation may seem torequire a great deal of chemistryknowledge. Actually, it is a processfor reviewing data generated by alaboratory and accepting it, qualify-ing it or rejecting it on the basis ofestablished criteria. The criteriaused to assess data are based uponeither Quality Control require-ments defined by the laboratory orrequirements defined by U.S. EPA.Data validation is therefore animportant part of a Data QualityObjective process that is necessaryto assure that data is generatedand is acceptable for its intendedpurpose. In order to meet the needsof DHWM’s inspectors, DHWMdeveloped a Tier I Data ValidationManual.

DHWM’s Data Validation Process DHWM’s guidance contem-plates a three-tiered process forexamining analyses of volatile andsemi-volatile organic compoundsand inorganic elements in waste,soil and water matrices. The Tier Ievaluation examines environmen-tal data for technical holding timesand common Quality Assurance/Quality Control (QA/QC) param-eters such as laboratory blank andmatrix spike results. Of particularinterest in this tier are sections onhow to examine data generatedfrom hazardous waste characteris-tic tests, such as the ToxicityCharacteristic Leaching Procedure(TCLP). A Tier II evaluation, currentlyin development, will consist ofexamining additional QA/QCinformation beyond the Tier Ievaluation. The Tier II evaluationwill review calibration and labora-tory control sample information.Tier III will be required on an asneed basis and is primarily in-tended for litigation support. Theactivities in this tier will consist ofexpert witness testimony. The DHWM guidance currentlyavailable for review consists of amanual and appendixes that cover

the first tier of the data validationprocess. A checklist is included inthe appendixes that can aid areviewer through the Tier I pro-cess. In the future, a Tier II check-list will be available for comment. The guidance, Tier I DataValidation Manual is available byaccessing DHWM’s Web page athttp://www.epa.ohio.gov/dhwmInquiries concerning the availabil-ity of the document should be madeto Angela Scott-Owens at 614-644-2944. Comments may be submittedto the attention of Erik Hagen,Ohio EPA, DHWM, 122 South FrontStreet, Columbus, Ohio, 43216-1049.

Bob Taft, GovernorChris Jones, Director

EditorLarry Benintend

Editorial AssistantCathryn E. Grote

ContributorsPam Allen, Kit Arthur,

Paula Canter, Rose Connelly,Karen Hale, Andy Kubalak, Ed Lim,

Jeff Mayhugh, Helen Miller,Kim Reinbold and Hillary Solomon

Graphic DesignerYvonne Foster-Smith

Ohio EPA is anEqual Opportunity Employer

Printed on Recycled Paper

Ohio Hazardous Waste