Waste Regulations for Airports and FBOs

Waste Management SectionJim Harford

Waste Topics for Airports

• Hazardous Waste

• Common Wastes That Might be Hazardous

• Common Violations

• Contacts

Hazardous Waste

• Who’s Affected?– Just about everybody except “households”

• Hazardous Waste Identification– All must identify their wastes regardless of size

Hazardous Waste

• Solid Waste– Any material ----solids, liquids, sludges, and contained gases

disposed, burned, or recycled in a certain manner

Solid Waste is also Hazardous Waste if:

• It is one or more of the following:– Has been specifically listed

– Exhibits any characteristic of a hazardous waste

– Is a mixture of listed waste and non-hazardous waste

Hazardous Waste

Waste Determination Steps

1. Is it excluded?

2. Is it listed as a hazardous waste

3. Does it have characteristics of hazardous waste

– Test or– Apply generator knowledge

4. If it is hazardous waste, check for possible exclusions or restrictions

Hazardous Waste

• Some Exclusions and Exceptions– Household Hazardous Waste– Sewage to Publicly Owned Treatment Works– Use/reuse without reclamation– Used oil if being recycledUsed oil if being recycled– Scrap metal being recycledScrap metal being recycled

– NOTE: Recycling does not automatically remove a waste from haz waste regulation!

Hazardous Waste

• Listed Hazardous Waste– U-listed -- specific unused or off-spec commercial

chemical products• Sole active ingredient

– P-listed -- acutely hazardous -- specific unused or off-spec commercial chemical products

– F-listed -- nonspecific sources • Certain spent solvents and solvent blends

Hazardous Waste

• Characteristic Hazardous Waste– Corrosivity -- pH (strong acids or bases)– Ignitability -- liquid & flash point <140° F– Reactivity -- unstable, capable of explosive

reaction if heated under confinement, etc.– Toxicity -- constituents that, if present in

concentrations greater than specified levels, are considered a threat

• TCLP -- Toxicity Characteristic Leaching Procedure

Hazardous Waste

• Generators of Hazardous Waste– Conditionally Exempt Small Quantity Generator

(CESQG)• 220 lbs. or less per calendar month

• “Easy”

– Small Quantity Generator (SQG)• >220 to <2,200 lbs. per calendar month

• Not Much Fun

– Large Quantity Generator (LQG)• 2,200 lbs. or greater per calendar month

• Don’t Even Go There!

Common Wastes That Might Be Hazardous

• Many Solvents – not all– Spent or disposed– Cleaning & painting– Most ignitable– Many F-listed

• Methylene chloride, toluene, acetone, tetrachloroethylene, etc.

– Parts washers– Aqueous parts washers

Common Wastes That Might Be Hazardous

• Fuel Sampling– Ignitable hazardous waste– Disposing to the ramp is not allowed!– Collect it on the ramp– Collected fuel used/sent off as fuel is not

waste!!

Common Wastes That Might Be Hazardous

• Paint Booths– Spent filters might need to be tested

• Media Blasters– Spent sand, garnet, beads, etc. might need to be

tested

• Used Oil– Can be confusing – let’s talk -----

Used Oil

• Not hazardous waste if recycled or burned for energy recovery– Yes: Engine oil, transmission fluid, gear lube,

cutting oils, hydraulic fluid – No: Antifreeze, brake fluid, or soy oil– Yes: Oil recovered by skimming or evaporation– Prove you’re recycling it

• Oil filters not haz waste if punctured or crushed and hot-drained

Used Oil

• Don’t be “Used Oil Marketer” (unless you want to)– Giving your used oil to a burner makes you a

marketer– Marketers will need to do “specification” test – Used oil space heaters can be a good deal

Common Wastes That Might Be Hazardous

• Batteries– Lead-acid batteries that are recycled not haz waste– Other hazardous waste batteries

• NiCad, mercury, some lithium, silver

• Pesticides– Aerial spraying operations – Many pesticides are listed or characteristic hazardous

waste

• Hazardous Waste Bulbs– HID, fluorescent, high pressure sodium, mercury vapor,

metal halide

• All the above are Universal Waste – Let’s see ---

Universal Waste

• Recycling operations can generate hazardous waste batteries– Managing as UW can help you – Reduced Regulatory Burden

• Generate UW without having to include these wastes when counting hazardous waste weight

• Can accumulate up to one year vice 90 or 180 days

• Do not include lead-acid batteries managed under Title 128, Chapter 7– The old reclamation exemption is better!

Universal Waste

• Alternate Management Standards for Specified Hazardous Wastes– Hazardous waste lamps– Certain batteries– Thermostats– Certain pesticides

• Reference Title 128 – Nebraska Hazardous Waste Regulations– Chapter 25

Common Wastes That Might Be Hazardous

• Wash Racks, Sumps, Drains– Residues might need testing– Can’t clean out and place elsewhere on the

airport

• Fire Training Wastes– AFFF not hazardous waste, but --- Water Regs– Ignitable liquids might be hazardous waste

Common Wastes That Might Be Hazardous

• Aerosol Spray Cans– Empty cans are reactive hazardous waste– Unless managed as scrap metal

• Scrap Metal– Most scrap metal not hazardous waste– Some otherwise hazardous waste can be

excluded under scrap metal rules

Scrap Metal

• Bits & pieces of metal parts or pieces that may be combined together with bolts or soldering, which when worn or superfluous can be recycled– Radiators, autos, box cars, circuit boards,

pranged aircraft

• “Excluded” scrap metal– Not solid waste when recycled– Processed, Home, & Prompt scrap metal– Example: Crushed auto

Scrap Metal• Scrap metal that is not “excluded”

– Is a solid waste --- subject to– Speculative accumulation, but– Title 128, Chapter 7 exclusions apply– Example: Whole, uncrushed auto

Common Wastes That Might Be Hazardous

• Deicing Fluids– Not waste when “used as intended”– Waste when disposed of– Water regulations are primary concern

• Electronic Wastes– Avionics – most not hazardous– Computers – CRTs are hazardous waste (lead)– Let’s see some more ------

Electronic Waste

• Computers, monitors, radios, TVs, telephones, video games, radar, transponders, etc.

• TVs, monitors, and CRTs are hazardous waste unless going through legitimate refurbishment

• LCDs and plasma screens not yet seen to be hazardous waste

• Mercury switches, NiCad batteries, etc. are usually hazardous waste

Electronic Waste

• Most other electronics are not hazardous waste

• Items that are otherwise hazardous waste, but meet the definition of scrap metal and are being managed as scrap metal will usually be considered to meet the “scrap metal exemption”– Separate circuit boards qualify– Hard drives

Electronic Waste

• Shredded circuit boards– Separate solid waste exclusion

• Containerized to prevent release

• Free of mercury switches and relays

• Free of NiCads and lithium batteries

• PCBs– Regulated by EPA

• EPA Region VII, Dave Phillippi, (913) 551-7395

Common Violations

• Most airports will be CESQGs• Most FBOs will be CESQGs• All of you must find out what category generator

you are

• Most violations are by SQGs and LQGs• Let’s see what these are so you CESQGs can see

what you’re missing!

Common Violations

• Single Most Common Finding

Failure to make hazardous waste determination – Applies to all generators except “households” – Some “solid waste” exclusions (Title 128, Ch 2,

009)– “Mixture Rule” often missed

Violations• Open Containers

– SQG & LQG– Includes Satellite Accumulation Containers

Violations

• Container labeling and dating (Ch 9 & 10)– SQG & LQG– Includes Satellite Accumulation Containers– To date or not to date?– What must the label say?

• Emergency information next to “the” phone (Ch 9)– SQG

Violations

• Used oil “marketing” (Ch 7)– CESQG & SQG & LQG

• Improper Satellite Accumulation– SQG & LQG

• Arrangements with local authorities (Ch 17)– SQG & LQG

Violations

• Failure to notify of regulated waste activity (Ch 4)– SQG & LQG– Changes

• Manifest & Land Disposal Restriction Form recordkeeping (Ch 9, 10 & 20)– SQG & LQG

Violations

• Storage over 90/180 (270) days (Ch 9 & 10)– LQG/SQG

• Improper disposal (Ch 4)– SQG & LQG– CESQG rarely (> 43 lbs/day to a landfill)

• Weekly inspections (Ch 9 & 10)– SQG & LQG

Violations

• Universal Waste– Labeling & Dating– Containers & Closing– The CESQG “Scam”– All in or all out

• By specific universal waste

Waste Information

• Web Sites– http://www.deq.state.ne.us/– Has “The Regs,” Guidance, Forms

• “The Regs!”– Title 128 – Nebraska Hazardous Waste

Regulations – Title 132 – Integrated Solid Waste Management

Regulations

• Waste Compliance Assistance• (402) 471-8308 Jim Harford