Hazardous Wastes at Airports

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Hazardous Wastes at Airports
Kathryn Stewart [phone] kathryn.stewart_at_sta
te.co.us
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Introduction

• Hazardous Wastes Regulations
• Conditionally Exempt Small Quantity Generator
• Small Quantity Generator
• Large Quantity Generator
• Used Oil
• Universal Wastes

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Types of Businesses at Airports can be in all 3
categories

• Conditionally Exempt Generators CESQGs
• Small Quantity GeneratorsSQGs
• Large Quantity GeneratorsLQGs

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Hazardous WasteGenerator Categories

• Conditionally Exempt Generator
• Less than 220 pounds per month in your busiest
  month of the year
• Small Quantity Generator
• Between 220 pounds and 2200 pounds per month in
  your busiest month of the year
• Large Quantity Generator
• Over 2200 pounds per month

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CESQG Requirements

• ID all hazardous waste
• Dispose of hazardous waste legally
• Notify 3 gallons for solvent wastes with codes
  F001, F002, F004, and F005
• Minimize the possibility of a release
• Self-Certification Checklist
• Never have over 2200 pounds (about 5 55-gallon
  drums) on site

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SQG Requirements

• All CESQG Requirements
• Notify the Division
• Post Emergency Information
• Label your containers
• Keep Containers Closed
• Weekly Inspections
• Incompatible wastes must be segregated
• Hazardous Waste Training
• Hazardous Waste Training Documentation
• Record Keeping Requirements
• 180 days accumulation time

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LQG Requirements

• All SQG Requirements
• Annual Hazardous Waste Training
• More Training Documentation
• More Record Keeping Requirements
• Written Contingency Plans
• 90 Days Accumulation Time

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Identify Hazardous Waste

• Key to compliance

• Defines generator status

• Do you count it? If so when?
• Most common reason for a violation

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Are Old Products Waste?

• Are your containers leaking?

• Is there still a use for the material?

• Is the material expired?
• Do you have old spray cans or paint cans?

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Are these still products?
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Bead blast machine
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Solvent Contaminated Rags
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(No Transcript)
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Hazardous Waste In TrashLiquid Reducer
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Hazardous Waste Debris In Trash
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Paint Booth Filters
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Treatment and Rinse Tanks
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Drains?
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Waste Water Treatment Unit
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Waste Water Treatment Unit Sludge
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Paint Storage in Cabinets
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Parts Washers-In Process?Must Count When Picked
Up.
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Other Common Violations

• Hazardous Waste Labels
• Open Containers
• Drums In Poor Condition or Leaking
• Incompatible Wastes
• Aisle Space

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Hazardous Waste Labels
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Hazardous Waste Label With Accumulation Start Date
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(No Transcript)
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Open Container?
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Open Containers?
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Open Container?No Hazardous Waste Label?
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Storage Area-Aisle Space
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Leaks-Floor Stains
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Recycling Unit
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Leaking Drum?Weekly Inspections?Failure to
Minimize Release? Illegal Disposal?
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Weekly Inspection log
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Hazardous Waste Training

• Documentation
• Required
• and also is a
• Performance Based
• Evaluation

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Training Sign-In Sheet
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Emergency Phone Posting
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Manifests
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Land Disposal Restriction Form
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Used Oil Generator Requirements

• Mark or label tanks and containers as Used Oil
• Must be kept closed if stored outside
• Containers in good condition
• Clean up releases

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Used Oil
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OPEN USED OIL CONTAINERS
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Cleanup Releases of Used Oil
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Universal Wastes
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Colorado Universal Wastes

• Batteries
• Agricultural pesticides
• Mercury-containing devices
• Aerosol Cans
• Lamps (sodium, halogen, mercury)
• Electronic devices and components

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Electronic EquipmentThe Environmental Risk
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Universal WasteManagement Practices

• Label - Waste Lamps, Used Battery, or
  Universal Waste
• Minimize potential for releases or exposures
• Keep shipping records
• Ship to another universal waste handler, a
  destination facility (treatment, disposal, or
  recycling)

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Container label
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Bad accumulation practices
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The device or component is assumed to be a waste
if it is stored in a manner inconsistent with it
being a product or commodity with value.
Waste
Product
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What is a legitimate recycler?

• For all recycling activities, the premise is that
  legitimate reclamation or reuse is taking place.
• Some recyclers may claim that they are
  recycling in order to avoid being subject to
  state regulation, when in fact their activities
  are not legitimate recycling.

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Legitimate recyclers will

• provide information on how they manage the
  equipment.
• provide information on how they process the
  equipment.
• provide documentation on where various components
  or devices are sent for reuse, disposal or
  materials recovery.
• generally charge a fee for their services.

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Generators Assistance Program