hazardous waste reduction - p2 infohouse · waste reduction program in lieu of contracting these...

HAZARDOUS WASTE REDUCTION:

CALIFORMA CITIES A STEP-BY STEP GUIDEBOOK FOR

Prepared by:

The City of Anaheim Public Utilities Department

Edward K. Aghjayan, General Manager

Prepared for:

California Environmental Protection Agency Department of Toxic Substances Control

June 1992

WE’VE CHANGED!

On July 17, 1991, the Caiifornia Environmentai Protection Agency officially came into existence and the Toxic Substances Control Program became t i e Department of Toxic Substances Control under that Agency. The Toxics Program is no longer affiliated with the Department of Health Services or the Health and Welfare Agency. The wording within this particular document has not been changed to indicate this new affiiiation. The new mailing address follows:

Department of Toxic Substances Control

400 P Street, 4th Floor P.O. Box 806

Sacramento, CA 95812-0806

Office of Pollution Prevention and Technology Development

(91 6) 322-3670

Page Project Abstract .................................................................................................................................................................... 5 ~howledgements .............................................................................................................................................................. 5 Disclaimer ............................................................................................................................................................................. 5

Introduction .................................................................................................................................................................... 7

1.1.1 project Summary .............................................................................................................................................. 7

1.1 3 REommend&om .................................................................................................................. ......................... 7 What is a Hazardous Waste? .......................................................................................................................................... 9 2.1 what Makes a Waste a Hazardous Waste? ......................................................................................................... 9 2 3 Why is Hazardous Waste Regulated? ................................................................................................................ 11 2.3 Summary of Federal Hazatdous Waste Regulations ......................................................................................... 11 2.3.1 Accumulating Hazardous Waste .................................................................................................................... 11 2.33 . Hazardous Waste Storage ............................................................................................................................... 12 2.3.3 Hazardous Waste Determination .................................................................................................................... 13 2.3.4 Transporting a Hazardous Waste Offsite ........................................................................................................ 13 2.4 Summary of California Hazardous Waste Regulations .................................................................................. 15 2.4.1 Accumulating Hazardous Waste .................................................................................................................... 15 2.4.2 Hazardous Waste Storage ............................................................................................................................... 20 2.4.3 Hazardous Waste Determination .................................................................................................................... 20 2.4.4 Transporting a Hazardous Waste Offsite ........................................................................................................ 20

Hazardous Waste Reduction ......................................................................................................................................... 21 3.1 Description of Typical City Opemtions and Organizational Structure .......................................................... 21 3.2 Typical Hazardous Wastes Generated by Cities ............................................................................................. 21 Hazardous Waste Reduction Program Overview ......................................................................................................... 23 4.1 Why Should You Reduce Your Hazardous Waste? ....................................................................................... 23 4.2 Defining Hazardous Waste Reduction ............................................................................................................ 23 4.3 Overview of LRgislation On Waste Reduction ............................................................................................... 24 4.4 Senate Bill 14 Requirements .......................................................................................................................... 24 4.5 Approach to Hazardous Waste Reduction ...................................................................................................... 26

Step 1 : Developing Your Hazardous Waste Reduction Program ............................................................................... 29

1.1 Executive Summary ......................................................................................................................................... 7

1.12 Conclusions ....................................................................................................................................................... 7

5.1 5.2 52.1 5.22 5.2.3 5.3 5.3.1 5.32 5.4

Management Commitment ............................................................................................................................. 29 Department and Employee Involvement ........................................................................................................ 29

Depamnent Incentive Programs ..................................................................................................................... 30 Communication ................................................................................................................................................ 30

Your Community ............................................................................................................................................ 30 Objectives of your program ........................................................................................................................... 32

Recognition ..................................................................................................................................................... 29 Employee Incentive Programs ........................................................................................................................ 29

Employees ...................................................................................................................................................... 30

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5.5 Step 2 Facility and Pmes Assessments ................................................................................................................... 33 6.1 Objective of Conducting Assessments ........................................................................................................... 33 6.2 -paring for the Assessment ......................................................................................................................... 33 6.3 Waste Reduction Numbers and Setting Up a Data Base of Waste Streams ................................................... 34 6.4 General Assessmenu by Department ............................................................................................................. 34 6.4.1 Electric Utilities Department .......................................................................................................................... 34 6.4.2 Water Utilities Deptment ............................................................................................................................. 34 6.43 Facilities/Street Maintenance .......................................................................................................................... 37 6.4.4 Fleet Maintenance ........................................................................................................................................... 37 6.45 Parks and Recreation .................................................................................................................................... 37 6.4.6 Convention Center ........................................................................................................................................ 41 6.4.7 Stadium ......................................................................................................................................................... 41 6.4.8 Reprographics ............................................................................................................................................... 41 6.4.9 Fire Department ............................................................................................................................................ 41 6.4.10 Police Department ........................................................................................................................................ 41 6.4.1 1 Golf Course ................................................................................................................................................... 45 6.4.12 Sewage Treatment Plant ............................................................................................................................... 45

7.1 7.1.1 W h e ~ to Begin ............................................................................................................................................. 47 7.1 2 Resources and Assistance Available ............................................................................................................ 48 7.13 Hazardous Waste Reduction Alternatives and Hierarchy for Selection ...................................................... 51 7.1.4 Establishing a Waste Minimization Work Group ......................................................................................... 51 7.2 Hazardous Waste Reduction Alternative Number 1: Housekeeping or Inventory Controls ...................... 51 7.2.1 How to Recognize You Have a Housekeeping Problem .............................................................................. 52 7.22 Advantages ................................................................................................................................................... 52 7.23 Other Considerations ...................................................................................... .............................................. 54 7.2.4 Typical Housekeeping Controls ................................................................................................................... 54 7.25 Typical Inventory Controls ........................................................................................................................... 54 7.3 Hazardous Waste Reduction Alternatives Numbers 2 and 3:

Substituting a Nonhazardous or Less Hazardous Material for a Hazardous Material ................................. 54 73.1 Considerations .............................................................................................................................................. 56 73.2 Advantages ................................................................................................................................................... 56 7.3.3 Other Considerations .................................................................................................................................... 56 73.4 Advantages ................................................................................................................................................... 57 7.35 Other Considerations .................................................................................................................................... 57 7.4 Waste Reduction Alternative Number4: Onsite Recycling ......................................................................... 57 7.4.1 Advantages ................................................................................................................................................... 57 7.4.2 Other Considerations .................................................................................................................................... 58 $5 Waste Reduction Alternative NumbeQ: Offsite Recycling ........................................................................ 58 75.1 Advantages ................................................................................................................................................... 58 75.2 Other Considerations .................................................................................................................................... 58

procedures for Getting Startcd ........................................................................................................................ 32 6

7 Step 3: Available Hazardous Waste Reduction Alternatives ................................................................................... 47 Developing a Method for Evaluating Hazardous Waste Reduction Alternatives ........................................ 47

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6 7.6.1 7.6.2

8 Step4: 8.1 8.2 8.3 8.4 8.5 8.6 8.7 8.7.1 '

8.72 9 step5:

9.1 9.2 9.3

10 Step6 10.1 102 10.2.1 10.22

Waste Reduction Altemative Number 6 Rwess Elimination ................................................................... 58 Advantages ................................................................................................................................................... 58 Other Considerations .................................................................................................................................... 58

Overview of the Process ............................................................................................................................... 59 Evaluating Waste Streams for Hazardous Waste Reduction Potential ......................................................... 59

Which of the Materials Used at Your Facility Are Hazardous? ................................................................... 59 Which of the Processes at Your Facility Use Hazardous Materials? .......................................................... 59 What Hazardous Wastes Are Generated From These Processes? ................................................................ 60 What Waste Types Are Generated at Your Facility? ................................................................................... 60 What Two or Thm Waste Streams Are Generated Most? .......................................................................... 60 Evaluating Your Hazardous Waste Reduction Alte.tives ........................................................................ 60 Evaluation Procedure ................................................................................................................................... 60 How to Complete Checklists ....................................................................................................................... 62

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Implementing Waste Reduction Strategies .................................................................................................. 65 Implementation Considerations .................................................................................................................... 65

Establishing an Evaluation Plan to Monitor and Track Progress ................................................................. 66 Hazardous Material Purchase Management Program ................................................................................... 67

Implementation Plan ..................................................................................................................................... 65

Purpose ......................................................................................................................................................... 67 Strategies Available ...................................................................................................................................... 67 Implement a Hazardous Material Purchase and Management Program ....................................................... 67 Implement a Central Hazardous Material Purchase and Management Program .......................................... 68

11 Differences Between Senate Bill (SB 14) and This Guidebook ................................................................................. 71 11 . Differences .................................................................................................................................................... 71 112 Do You Need to Comply with Senate Bill 14 (SB 14)? .............................................................................. 71 11.3 How to Adjust This Guidebook to Comply with Senate Bill 14 (SB 14) ................................................... 72

12 Conclusions ................................................................................................................................................................ 75 A p d i x A List of Definitions ................................................................................................................................. A-1 Appendix B . List of Hazardous Chemicals ................................................................................................................ B-1

State MUS Waste Codes .............................................................................................................. C.1 A p d i x C . Appendix D . Appendix E .

Example: City of Anaheim Implementation of Hazardous Waste Reduction Rogram ...................... D-1 Hazardous Waste Assessment Questionnaire ....................................................................................... E-1

Appendix F . Some Reduction Checklists ................................................................................................................ F-1 Appendix G . Some Reduction Summary Checklist ................................................................................................ G-1 Tables

6-1 Organizing Waste Reduction Information ...................................................................................................... 35 6-2 Department Locators ....................................................................................................................................... 36 6-3 Waste Types .................................................................................................................................................... 36 6 4 Typical Processes Performed at an Electrical Utilities Department ................................................................ 37 6-5 6-6 6-7 6-8

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Typical Processes Mormed at a Water Utilities Department ....................................................................... 38 Typical Processes Performed at a Facilitiesfitreet Maintenance Depanment ................................................ 38 Typical Processes Performed at a Fleet Maintenance Department ................................................................. 39 Typical Processes Performed at a Parks and Recreation Deparunent ............................................................. 40

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9 6- 10 Typical Recesses Performed at a Stadium ..................................................................................................... 42 6-11 6-12 6-13 6-14 6-15 7-1 11-1

Fisurts 2-1 California Environmental Protection Agency Department of Toxic Substances Conwl Regional Offices .. 10 2-2 Example: Hazardous Waste Label ................................................................................................................. 12 2-3 24a) Hazard Class Labels ........................................................................................................................................ 16 24b) Additional Hazard Class Markings and Labels .............................................................................................. 17 2-5(a) Placards ........................................................................................................................................................... 18 2-5(b) Placards ........................................................................................................................................................... 19 4-1 Waste Minimization Techniques .................................................................................................................... 25 4-2 5-1 Example: Press Release .................................................................................................................................. 31 7-1 Example: Weekly Inspection Checklist ......................................................................................................... 53 7-2 Hamdous Waste Disposal Proceduns ........................................................................................................... 55

Typical Processes Performed at a Convention Center Department ................................................................ 41

Typical Proctsscs Performed at a Reprographics Department ....................................................................... 43 Typical Rocesses Performed at a Fire Depmnent ........................................................................................ 44 Typical procesSes Performed at a Police Department ..................................................................................... 44 Typical Processes Performed at a Golf Course ............................................................................................... 45 Typical procesSes Performed at a Sewage Treaunent Plant ............................................................................ 46 Guide to Household procedures and Less Hazardous Alternatives ................................................................ 49 Comparison of This Guidebook and SB14 ..................................................................................................... 73

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Example: Hazardous Wastc Manifest ............................................................................................................ 14

Overall Hazardous Waste Reduction Approach .............................................................................................. 27

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Hazar&lcs Waste Reductwn: A Stepby-Step Guide- book for California Cities is designed to facilitate the reduction of hazardous materials used and the hazatdous wastea typically generated by city operations. This guidebook outlines the essential elements of a success- fulwastereductionprogramandwalltstheuserthrough the steps the city can take to implement the program’s multimedia approach. ?he guidebook provides a series of “user-friendly” checklists for evalmfhghaeardous- waste generating processes and identifying waste reduction altematives.

Although this guidebook focuses on city operations, it can be useful for any local government in implementing a hazardous waste reduction program.

David Wrighf California EPA Department of Toxic Substances Convol

John Hills, City of Anaheim Public Utilities Department Environmental Services Division

Sharon Lien, City of Anaheim Public Utilities Department Environmental Services Division

Patricia OHara, CH2M HILL, Los Angeles Office

Jeff Hendrix, CH2M HILL, Los Angeles Office

Renu Gupta. CH2M HILL, Los Angeles Office

Sharon Jones, CH2M HILL, Los Angeles Office

Liz McDargh, CH2M HILL, Los Angeles Office

ThisreportwassubmittcdinfulfiUmentofGrant Award #89-0116 by the City of Anaheim, Public Utilities Department under the sponsorship of the California EPA, Department of Toxic Substances Control. Work was completed as of August 1991.

The statements and conclusions of this report axe those of the Grantee and not necessarily those of the State of Califomia. The mention of commercial products, their source,or their use in connection with material reported herein is not to be construed as either an actual or implied endorsement of such products.

This guidebook was submitted by the City of Anaheim to the California P A , Department of Toxic Substances Control. Neither the City of Anaheim, nor any persons acting on its behalf; a) makes any warranty or represen- tation, expressed or implied, with respect to the accu- racy, completeness or usefulness of the information contained in this guidebook, or that the use of any information. cost estimate, apparatus, method or process disclosed in this report, may not infringe privately owned rights; or b) assumes any liabilities with the respect to use of, or damage resulting from the use of, any information, cost estimate. apparatus, method, or process disclosed in this guidebook, including conse- quentialorother indirectorcontingent liabilities whether due to the negligence of the City of Anaheim, or otherwise. Any person, entity, or third party using this guidebook or its contents or relying therein does so at its own risk and does hereby release, defend, and indem- nify the City of Anaheim from and against any liability, cost or expense such person, entity, or rhird party may incur as a result of said use, or reliance.

All text pertaining to law and regulations contained within this guidebook are provided for general information only. That information is not reliable for use as a legal reference. The generator must contact the appm priate legal sources and regulatory authorities for up-to- date regulatov requirements. and their interpretation and implementation.

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Chapter 1 INTRODUCTION

1.1 Executive Summary

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The City of Anaheim, Public Utilities Department, Environmental Services Division, under the direction of the California Environmental Protection Agency, Department of Toxic Substance Control, developed this guidebook to assist cities in implementing intemal hazardous waste reduction programs.

1.1.1 Project Summary

The goal of this project was to provide a user-friendly document that can be easily utilized by any city to implement a hazardous waste reduction program. This document provides cities with a consolidated d d p - tion of the types of hazardous wastes that can be generated in the operation and maintenance of a city, identifies alternatives to materials or processes that generate hazardous wastes, and establishes a system to monitor and review the types of materials used prior to purchase. The step-by-step snategy outlined in this guidebook allows each department/division to utilize existing personnel resources to develop a hazardous waste reduction program in lieu of contracting these ~ M c e s , which may be difficult due to budget limita- tions. This approach is more readily accepted by both the management (for fmancial and administrative reasons) and the workers, because it requires their participation in the actual program development process. A list of definitions of terms used in this guidebook is provided in Appendix A.

1.13 Conclusions

reduction process needs to be user-friendly and developed for use by the "end-user" employees, since these employees will most likely by responsible for the implementation of the program.

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Each of these elements plays an important part both during the development of your hazardous waste reduction program and through the entire process of implementation.

1.13 Recommendations

The information and recommendations provided in this guidebook are based upon the achievements and problems encountered by the City of Anaheim during the administration of this project. It is important to consider the key elements described above during the development of a hazardous waste program for your city. This guidebook is designed to provide you with a starting block to develop an individualized hazardous waste reduction program that will meet the needs of your city.

During the development of the hazardous waste reduction program in the City of Anaheim, it became evident that the following essential elements were necessary for a successful program:

Management commitment. In order for the program to be effective, a strong commitment from top management must be communicated to employees.

Employee involvement and education. Each department needs to be involved in the development process of the program. Employee education related to the identification of hazardous wastes, hazardous wastcmanagementreq~ments,and hazardous waste reduction techniques will encourage involvement and support of your program.

User-friendly program. The hazardous waste

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Chapter 2 WHAT IS HAZARDOUS WASTE?

Chapter

When first developing a source

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reduction or waste minimization program for your department, it is important that you have a basic understanding of what makes a waste a hazardous waste and also what makes a mate ria la hazardous mate^ Youshouldbeawarethat both the federal and state regulations concerning hazardous wastes are complicated and cannot be fully explained in this manual. The discussion presented here is to help you get started identifying what hazardous materials you may currently be using and what hazardous wastes may be generated from your use of these products.

This chapter is designed to assist you in identifying the hazardous materials you currently use, possible hazardous wastes you may be generating from your use of these materials, and other sources of information that are available to you if you have further questions about your materials or wastes.

The organization of this chapter is as follows:

Section 2.1 What Makes a Waste a Hazardous Waste? This section briefly describes hazardous materials and how you can tell ifa waste your department is generating is considered a hazardous waste.

Section 2.2 Why is Hazardous Waste Regulated? This section describes why some of your wastes need to be managed according to special federal and state regulations.

Section 2.3 Summary of Federal Hazardous Waste Regulations. This section briefly summarizes the federal regulations concerning the handling andover- all management of hazardous wastes.

Section2.4 Summary of CalifomiaHazardous Waste Regulations. This section briefly summarizes the state regulations concerning the handling and overall management of hazardous wastes.

2.1 What Makes a Waste a Hazardous Waste?

Step 1 - What is a waste? You have a waste when: The material can no longer be used for its intended Purpo=

The material is scheduled to be thrown away.

The material will be transported away from your facility to be recycled, incinerated, or disposed. ~

Step 2 - Did you use a h ” s m & l ? The second step is to determine if the waste originated from a hazardous material. There are several ways to determine if the materials you use are hazardous materials. TableB-1 (see AppendixB) listsmaterialsthatthestate of California considers to be hazardous or extremely hazardous. Some of the more! commonly used chemi- calsappearinbold. Ifonemmoreof thesechemicalsare found in your inventory, their use may result in the generationofahazardous waste.Youcanfindoutabout the hazardous characteristics OJ the chemicals in your inventory by looking at the Material Safely Data Sheet (MSDS) for each material. An MSDS should be available for all the materials you use at your facility. If an MSDS is not available, contact the manufacturer to have one sent to you.

If a waste is generated from the use of a hazardous material, you probably have generated a hazardous Waste.

Step 3 - What if the chemical is not listed on Table B-l? If you have a waste that did not Originate from a material containing one of the chemicals listed in Table B- 1. you need to review Table B-2 (see Appendix B) to determine if your waste is listed under one of the common categories of hazardous wastes. The State of California has compiled this list to include wastes the state considers to be hazardous but not necessarily due to the presence of a chemical listed in Table B-1.

If you have a waste that fits one of these categories, you have a hazardous waste.

Step 4 - What if the waste does not fit any of the Table B-2 categories? If you have a waste that is not listed in either Table B-1 or B-2 and you are not sure if it is hazardous, you can contact your regional office of the CalifomiaEnvironmentalalection Agency (EPA), Department of Toxic Substances Control for clatifica- tion. The offices and the phone numbers of the duty officers are shown in Figure 2- 1 and listed below: .~

Region #1 10151 Croydon Way Sacramento, CA 95826 Duty Officer 916/855-7773

Includes Siskiyou, Modoc, Trinity, Shasta, Lassen, Tehama, Plumas, Butte, Glenn, Lake Colusa, Sutter, Yuba, S i m , Nevada, Placer, El Dorado, Amador,

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California Department of Toxic Substances Control

Regional Off ices

includes the area south of the 91 (Artesia) Freeway Dept. of Toxic Substances Control 245 West Broadway, Suite 350 Long Beach, CA 90802

Rev. 9/93

Sacramento, Yolo, Alpine, Tuolumne. Mon0,Calavexas. San Joaquin, Stanislaus, Merced, Mariposa, Madera, Fresno, Kings,Tulare, In yo, Kern, San Luis Obispo and eastern Solano Counties

Region #2 700 Heinz Avenue, Building F. Second Floor Berkeley, CA 947 10 Duty Officer 4 15/54@3739

Includes Del Norte, Humboldt, Mendocino. Sonoma, Nap, Marin, westem Solano, Contra Casta, San Fran-. cisco, Alameda, San Mat-, Santa Clara, Santa C w , San Benito, and Monterey Counties

Region #3 1405 North San Femando Boulevard Burbank,CA 91504 Duty Officer 818/567-3000

Includes Santa Barbara, Ventura. and Northem Los Angeles Counties

Region #4 245 West Broadway - Third Floor Long Beach, CA 90802 Duty Officer 213/590-4968

Includes southern Los Angeles, San Bernardino, Orange, Riverside, San Diego, and Imperial Counties.

The duty officer can advise you on how to determine if you have a hazardous waste and on proper handling procedures. As a generator ofwaste, it is your responsibility to designate it hazardous or nonhazardous. You may need to test your waste to make this designa- tion. The Department of Toxic Substances Control can advise you on testing requirements.

2.2 WhyisHazardoowWasteRegulated?

You are required to handle your hazardous wastes according to specific federal and state regulations for several reasons:

Wastes considered hazardous need to be handled in a manner that protects not only the people handling the wastes but also any other person who may come in contact with it.

Wastes considered hazardous need to be disposed of in a manner that will prevent them from affecting our environment. In other words, we do not want these wastes entering the air, soil. or our lakes, rivers, or groundwater all of which may be our source of

drinking water.

Wastes considered hazardous need to be properly labelled to prevent the accidental mixing of wastes that are incompatible. Mixing of incompatible wastes can result in fires, explosions, or the generation of a toxic gas. For example, mixing ammonia and chlorine bleach results in the generation of chlorine gas, which is toxic to most living things including hu- IIWlS.

Wastes considered hmudous n& to be managed in a manner that will p n m t the accidental spill or leak of the waste to the immcdiatc or the smunding area.

Wastes considered hazadous need to be transported in a manner that minimizes the possibility of an accidental spil! or releaso, of the waste.

It is important to fmt recogrh which of your materials are hazardous and second which of your wastes are hazardous &v ae to prevent tlie mishan- dling of these ha r . cus wastes.

2.3 Summary of Federal Hazardous Waste Regulations

The Federal Hamdous Waste Regulations are found in the Code of Federal Regulations (40 CFR) Sections 260 through 280. This section briefly summarizes some of the basic aspects of hazardous waste management and is not intended tobe a substitute for the regulations. The following appliestofacilitiesthatstorr: hazardouswastes for less than90 days.

You can purchase a copj of the Waste Regulations by contacting:

Superintendent of Documents U.S. Government Printing Office Washington, D.C. 20402 2Om83-3238

Federal Hazardous

2.3.1 Accumulating Hazardous Wastes

You are allowed to accumulate up to 55 gallons of hazardous waste, or one. quart of acutely hazardous waste, the mint of fl-4 ’ as long as the accumulation is done under the supervision of the operator of the process that generates the waste. Once you have accumulated 55 gallons, the waste must be msported to a designated hazardous waste storage

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area. Once the waste is moved to this storage area, you have 90 days to recycle or otherwise dispose of it. The cont;tiner(s) used to accumulate wastes must be labelled “Hazardous Waste“ or with other words that identify the contents of the accumulation container. You can accumulate in as many containers as you wish, but once 55 gallons have been accumulated, all 55 gallons must be moved to the hazardous waste storage area within 3 days of reaching the 55-gallon limit.

2.3.2 Hazardous Waste Storage

YOU are allowed to Store hazardous waste in the hazardous waste storage area for up to 90 days. Before you can store hazardous waste, you must have a U.S. Environ- mental Protection Agency (USEPA) Identification Number. This number can be obtained from the Califor-

nia EPA, Department of Toxic Substances Control (see Section 2.1 for phone numbers). Once waste is brought to this area, it must be labelled with the following infomation:

The words “HAZARDOUS WASTE”

The date the waste was brought into the storage area

Name and address of your facility

Your EPA Identification Number

An example hazardous waste label is shown in Figm 2-2

?he storage area should have limited access. All the labels should be attached to the cantainers and printed

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HAZARDOUS WASTE I STATE AND FEDERAL LAW PROHIBITS IMPROPER DISPOSAL

IF FOUND. CONTACT THE NEAREST POLICE. OR PUBLIC SAFETY AUTHORITY. OR THE US. ENVIRONMENTAL PROTECTION AGENCY

OR THE CALIFORNIA DEPARTMENT OF HEALTH SERVICES

PROPER D.0 T. SHIPPING NAME UN or NA* GENERATOR INFORMATION: NAMF ADDRESS

CITY STA-P

€PA MANIFEST / to N O . / m U M E M NO

CA ACCUMUUTiON 1 WASTE NO. START DATE €PA

WASTE NO CONTENTS. COMPOSITION:

C S W D 3 LlOUlD I 3 CORROSIVE C RUCtlVlTY 5 OTHER PHYSIC& STATE: nAURDOUS PROPERTIES: 3 FLAMMABLE f TOXIC

HANDLE WITH CARE! CONTAINS HAZARDOUS OR TOXIC WASTES

FIGURE 2-2 EXAMPLE HAZARDOUS WASTE LABEL

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on a label of contrasting color to the drum. All labels should be clearly visible (facing outward in plain view). The area should be paved and constructed to prevent spills or leaks from leaving the area. Wastes that are not compatible should be separated, and spills and leaks should be prevented from mixing. The area should be clearly posted as containing hazardous wastes. Workers in this area should have access to an alann system or communication device in the event of an accident. Workers handling hazardous wastes should have completed training courses in the proper handling and management of hazardous waste. Waste specific fire extinguishers should be located nearby.

If hazardous wastes are stored at your facility for more than 90 days, your facility will be considered a regular treatment, storage.0rdisposa.l facility (TSDF). ATSDF must obtain additional permits and comply with extremely strict state and federal regulations. Therefore, it is important that hazardous wastes are not stored at your facility for more than 90 days.

2.3.3 Hazardbus Waste Determination

According to federal regulations, many wastes are considered hazardous due to the mixing of a hazardous waste with a nonhazardous waste. For example:

If you used an absorbent material (such as sawdust, oilsorb, or kitty litter) to contain or clean up spills of

. a hazardous material, that absorbent is considered a hazardous waste and is subject to all the requirements of a hazardous waste.

If you apply a solvent or degreaser with a rag, Q-tip, or wipe, the used rags, Q-tips, and wipes may be considered hazardous waste.

If you rinse out a container that previously held a hazardous material, the water used to rinse the container is considered a hazardous waste.

If you store a hazardous material or waste in an underground or above ground tank, the sludge at the bottom of the tank must be managed as a hazardous waste once it is removed from the tank.

If you use a degreaser at your facility and the solvent used is a hazardous material, when you clean out the taik the sludge would be considered a hazardous Waste.

If you spill a hazardous material that reaches unpaved

soil, the affected soil would be considered a hazardous waste and must be managed as a hazardous waste once it has been excavated. If you plan to dispose of a parially used or full container of a hazardous mate- ~1,thematerialshouldbedispos~ofasahazardous Waste.

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Along with the criteria listed in Section 2.1 and above, some wastes can be considered hazardous due to the way the waste behaves under normal conditions. It is not necessary that these wastes contain one of the components of Table B- 1 or be described by Table B-2. Wastes are considered hazardous when they:

Catch fire easily under normal conditions (Ignit- able). Wastes can be considered hazardous due to their ability to cause a fire.

Cause damage to human skin (Corrosive). Some wastes, especially acids and caustics, m3y cause damage to human tissue when they come into contact with it.

React violently, causing fms or explodons, when exposed to air, water, or beat (Reactive). For example, compressed gas cylinders or empty amsol containers may explode if the tempmittre is high enough or if they are punctured.

Are considered toxic to humans (Toxic). The federal regulations contain a list of compounds, mostly metals and organic chemicals, that if present in your waste above specified levels, could make your waste a hazardous waste. A lot of paints may contain metals such as chromium, lead, or mercury that are above these levels. The paints would then be considered hazardous waste.

All wastes detecnincd to be hazardous under the federal regulationsare assignedaFederal Hazardous Waste Code. These codes are then entered on the manifest when the waste is transported offsite.

2.3.4 Transporting a Hazardbus Waste Offsite

Whenever you transport a ha7ardous waste offsite you are required to complete a hazardous waste manifest. The manifest is a one-page multiple carbon form. An example is shown in Figure 2-3. The State of California specifies the manifest form that should be used. You must make sure that the transporter has a USEPA Identification Number before offering your waste for transport. Preparation of the manifest is yourresponsi-

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FIGURE 2-3 EXAMPLE HAZARDOUS WASTE MANIFEST

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bility and it must be signed by a person at your facility. You must designate at least one -sal facility (land-

2.4 S u m m y of California Hamdous fill, recycler, incinerator, etc.) on the manifest. This Waste Regulations disposal facility mustalsohaveaUSEPAIdentification Number. Assure that enough copiesof the manifest are prepared (six if the waste is going to a disposallrecy- cling site in Califomia) and-

waste has - as Dlanned. Copies of the manifest should be retained by your facility for a minimum of 3 years. It recommended to retain copies of the manifests for much longer periods of time. since it is

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your only rccofd of hazardous waste.rlispQsrrtr .

Before transporting containers offsite. they need to be properly labelled and marked. Labelling includes fixing the appropriate Department of Transportation (DOT) label@) (Le., Flammable, Corrosive) to each container. Marking usually involves fixing a bright yellow hazardous waste label to each container. This hazardous waste lakl needs to include the following information:

The following words:

HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environ- mental Protection Agency.

Your facility name, address, and the manifest document number

The label shown in Figure 2-2 can also be used to fulfill these requirements.

Many times, marking (using the hazardous waste label) and the labelling requirements for storing hazardous wastes are both satisfied by the bright yellow label fixed to the drum as it enters the hazardous waste storage area. However, you still need the appropriate hazard class label($ (Le.. Flammable, Corrosive) in addition to the bright yellow label. Example hazard class labels are shown in Figures 2 4 a ) and 24(b).

Before allowing the registered transporter to remove hazardous wastes from your facility, you need to assure that the proper placards are present on the vehicle. Placards are diamond-shaped signs fured to the outside of the transporter's truck instead of the containers. Placarding (i.e., Flammable Liquid, Corrosive, etc.) is your responsibility. You need to supply the proper placards to the transporter if he is not displaying them. Example placards ae shown in Figures 2-5(a) and 2-33].

?he California hazardous waste regulations are found in the California Code of Regulations (CCR), Title 22, Division 4.5 and the California hazardous waste stat- utes are found in the California Health and Safety Code (HSiSC). Division 20, Chapter 65. The state regulations are often more complex than the federal regulations.Thissectionbrieflysu"arizessomeof thebasic aspects of hazardous waste management as they diffa from the federal regulations. This section is not intended to be a substitute for the state regulations. The following appliestofacilitiesthatstoretlazard~wastts for less than 90 days.

In general, the federal regulations have been i n c o p ratedintothestateregulations.Manyaspectsofthestate regulations are more strict than the federal. This section highlights the additional state requirements for the items discussed in Section 1.3 above.

You can purchase a copy of the California Hazardous Waste Regulations by contacting:

Barclays Law Publishers 400 Oyster Point Boulevard Post Office Box 3066 South San Francisco, CA 94080 (4W244-6611)

2.4.1 Accumulating Hazardous Wastes s vou toob-SF.PqlQeatlflEilMI1 . .

Number if v-ate m o w w a n e state also allows you to accumulate up to 55 gallons of hazardous waste, or one quart of exmmely hazardous waste, near the point of generation as long as the accumulation is done under the supervision of the operator of the process that generates the waste. The state adds one additional limitation to the accumulation of hazardous or extremely hazardous wastes. mlv take to one vear to accum-

r one of wemelv hazardous hazardous waste o The federal regulations do not specify a time

limit for accumulation. Once you have accumulated 55 gallons or the one-year time limitation is reached, the waste must be transported to a designated hazardoils waste storage area.

~

-

L__

The container(s) used to accumulate wastes must be labelled "Hazardous Waste" or with others words that identify the contents of the accumulation container and

15

DOMESTIC LABELING

I

General Guidelines on Use of Labels (CFR, Tltle 49, Transportation, Parts 100-177)

0 Labels IllusIraled above are normally lor dornesric shipmenfs. However, "e ek carders may requhe Ihe use of lnlernallonal Civil Avlalbn Organlzalion (ICAO) labels.

0 Domeslk Wamlng Labels may display UN Class Number, Division Number (and CompaUbUity Group lor Explosives only) ISec. 172.407(~)]. Any person who oflers a hazardous tpalerial lor transportation MUST label h e package, Y requked iSec. 172.400(e)].

0 The Hazardous Materials Tables. Sec. 172.101 and 172.102. iden- Wy the proper Iabells) lor the hazardous materials listed.

0 Labells). when rewired. musl be Drinted on or aflixed lo the sur- lace 01 h e package near uw pmpir shlpplng name pet. 172.406(a)l.

0 When Iwo or more dillerenl labels ate reqtnred. &splay them ne*l

0 Labels may be affixed lo packages (even when nol required by lo each olher 1-c. 172.406(c)].

regulalums) provided each label represents a hazard ol the mrler- la1 In lhe package IseC. 172.401).

Check (he Approprlrle Regulmtlonr Donnrlk or I n l e m l h l Shlpmnt

HAZARDOUS MATERIALS WARNING LABELS FIQURE 2-4(a) HAZARDCLASSLABELS

I I I

I I

suoipas 6u!6ey3ed pue (s)(aqel paJlnbaJ 'Jaq -unu uoiie3ijiiuapi 'ssep piezeq 'aueu 6uiddiqs JadOJd aut Ajiiuapi '10 ~ ' Z L L pue

L O I ' Z L L uoiizias 'salqel sleiiaieyy snopiezeH aql + J ~ H aqi u! uoipas aieiid -0Jdde aui 08 siapi ueii y3ea y i i ~ UMO~S iaqunu uoyzias ayl s p ~ a i e u r snopie -zeu to l~odsueil aui oi Guiuieuad slaqei pue s6uiyieu ieuoiiippe ~ a j e ale a ~ a ~

Ald HI 3

S l 3 R V l IJNllClNVH

SI 01 C 1 I 1 6 01 S a

SI L 9 E a i

UN or NA ldentlficatlon Numbers MUST BE DISPLAYED ON TANK CARS. A CARGO TANKS. PORTABLE TANKS AND

BULK PACKAGINGS

ORANGEPANELS

Appropriale Placafd mu* be used.

When hazardous materials are transpocled m Tank Cars (Section 172 330). Cargo Tanks (Seclm 172.328). Portable Tanks (%elm 172.326) or Bulk Pachagngs (secllon 172.331 J. UN or H A numbers musl be displayed on placards. or- panels or. when aulhaized, plan, while square-on-point conlq uralon. UN (Uruled Nalmns) M NA (No~lh American) numbers are lound in the Hazardous Malerials Tables. Seclms 172.101 and 172.102. Idenlilkalwn numbe~s may no( be displayed on "POISON GAS." "RADIOACTIVE." or "EXPLOSIVE A:' "EXPLOSIVE 8." "BLASTING AGENTS." or "DANGEROUS placards. (See Seclion 172.334 J In lieu d tho orange panel. iderUihcali nu-s may be placed on plain whlla sqmrMn-pOinl con- tiguralm when W e is no placard spmlied (or lhe hazard dass (0.0.. OAM-A. 8. C. D. or E) OI where UMI u3snliticalon "I may MI be displayed on me placard. See Seclion 172.336(b) lot ad- dilional pmn*ars and specikalkms.

played m lha kwer QW(MI d each placard (see Seclron 172.332 (cN3)). When lhe denlikalion number is displayed on a placard lhe UN hazard class number musl be dis-

Spealicalms 01 size .nd coloc d lhe Orange Psnel can be (wnd n section 172 332(b) NA numbers are usedonly in tho USA and Canada.

Addltlonal Placarding Guidelines

A A Iranswct velnde M lremhl conlamer MwIIa im two 01 &e ctassos 01 miten& requtnng anetCrm placardrspeahsdn Tabk2maybeplacarded DANGEROUS in place d Ihe v a l e placards speclhed lor each 01 hose ddSs€iS 01 malerial spe- afied m Table 2 However. when 5OOO pounds or m e d one class d material IS baded lhe" a1 one lnadng IaoLly. the placard spealpd (oc Mal class must be applied Thts excuplion pcovtded UI

Secuon 172 504(b). does nul a m lo poltable tanks lMk M Cargo 1-S

CAUTION Check each shipmenl lor c-ance with the aplwopnala har~dous malwtals regula-

Labeling. Placarding. Daamenlahon - pia IO tions - - CkrSifkaW. P m . Muking.

on- IO^ -1.

FIGURE 2-5(b) PLACARDS

I j l

in w-n beo;ln, You can accumulate as many different types of wastes in as many containers as you wish, but once 55 gallons have been accumulated or the one-year time limit is reached, all waste must be moved to the hazardous containerstorage area within 3 days.

Chemical toilet waste

Empty containers with hazardous residues

Polychlorinated biphenyls (PCBs)

Oily rags 2.4.2 Hazardous Waste Storage

Used02 The state also allows you to store hazardous waste in the onsite hazardous waste storage area for up to 90 days. The requirements listed in Section 2.3 for the FederaI‘ Hazardous Waste Regulations are similar to the state regulations. However, state regulations require that storage areas be clearly posted in both English and Spanish.

2.4.3 Hazardous Waste Determination

All wastes considered to be hazardous under the federal regulations are also considered hazardous under the state regulations. The state, however, considers many more chemicals and categories of wastes to be hazardous. Table B- 1 and Table B-2 are based on the State of California requirements.

All of the information listed in Section 2.3 for hazardous waste determination also applies to the State of Califomia regulations. Wastes that the state considers hazardous, but the federal government does not, include:

Asbestos

Ashes (many wastes form toxic or corrosive compounds during combustion)

All wastes considered hazardous according to the State of California regulations are assigned a California Haz- ardous Waste Code. A waste may have a federal and a state hazardous waste code or it may only have a state code. State codes are also entered on the manifest, when a waste is transported offsite. Califmia Hazardous Waste Codes are given in Table C-1 (see Appendix C).

2.4.4 Transporting a Hazardous Waste Offde

Whenever you transport a hazardous waste offsite you are required to complete a hazardous waste manifest. California has its own hazardous waste manifest form which yw are required to use for wastes tranmd within California Copies of the California Uniform Hazardous Waste Manifest are available f” the De- partment of Toxic Substances Control. Figure 2-3 is an example California Uniform Hazardous Waste Mani- fest. For wastes transported to other states, you may need to complete one of their manifests. You need to contact other states where you transport hazardous wastes to determine their requirements.

All the information listed in Section 2.3 for transporting a hazardous waste offsite also applies to the State of Califomia regulations.

20

- Chapter 3

CITIES A N D WASTE REDUCTION

Chapter 3

3.1 Description of -pica1 City Operations and Organizational Structure

This manual was prepared for use by cities based on a typical city organizational structure. Information used in the preparation of this manual was derived from sources at a typical city of approximately 250,000 residents having the following organizational structure:

Convention center

Electric utility facilities

Facilities/street maintenance

Firedepartment

Fleet maintenance

Golfcourses

Parksandrecreation

Police department

Reprographics

Sewage treatment plant

Stadium

Water utility facilities

Some significant characteristics of the typical city include:

Most departments operate independently.

Material purchasing, ordering, and waste disposal may not be centrally controlled but performed by each department separately.

Many departments generate similar wastes.

The management of hazardous waste may not be consistent from department to department.

3.2 Typical Wastes Generated by Cities

The following is alisting of typical wastes generated by typical cities departments which may be hazardous:

Aerosol Cans Asbestos Contaminated Soil Empty Solvent Containers Empty Pesticide Containers Empty Freon Containers Excess Solvent Florescent Light Fixtures Hydraulic Fluid Lab Packs Lead Dust Oil Containing Absorbent Oil Sludge Oil Containing Sawdust Oil Contaminated Water Oil Filters Oily Rags Paint cans Paint Filters PCB Sampling Debris Solvent Laden Wipes Solvent Laden Rags Waste Sulfuric Acid Waste Ferric Chloride Waste Dyes Waste Tires Waste Diesel Fuel Waste Motor Oil Waste Antifreeze Waste Paint Thinner Waste Paint Waste Solvents Waste Batteries Waste Lubricant Waste Refrigerant Waste Brake Cleaner wastecarburemcleaner Waste Lacquer

This is not a complete listing of wastes generated by cities but rathera sample of the types of wastes typically generated. This list is meant to familiarize you with types of waste that may be considered hazardous waste as applicable to a city.

21

- Chapter 4

HAZARDOUS WASTE REDUCTION PROGRAM OVERVIEW

Chapter 4

4.1 Why Should You Reduce Your Hazardous Waste?

There are many benefits to reducing the amount of hazardous waste you generate. Some of the benefits include:

Saving money. The cost of disposing of hazardous wastes continues to rise. Less waste to dispose of will free money for other operations within your department Reducing the amount of material you use wil l decrease the cost of purchasing hazardous materials, personnel training, and protective equipment.

Improving worker safety. Decreasing the amount of hazardous waste means your workers do not have to handle as much waste. This decreases the chances of an exposure which could lead to sick days or worker’s compensation.

Decreasing liability. Less waste means less paper- work to prepare, submit, or retain. You also decrease your chances of being fined for incorrect labelling or storing of hazardous wastes and the long-term liabilities associated with the cleanup of past hazardous waste disposal sites.

Improving the environment. Producing less waste decreases the chances of an accidental release to the environment or the incorrect disposal of the hazardous waste. It also provides an example to the community of your commitment to protect the environment.

To quote the California EPA, Department of Toxic Substances Control: “...the Department strongly recommends that you take this opportunity to prepare a source reduction plan for your city and make yourself an exemplar for industry to model. Also, as you probably know, some reduction measures usually prove cost effective with large savings incurred through simple good housekeeping efforts.”

4.2 I)efining Hazardous Waste Reduction

A hazardous waste reduction program consists of two elements: source reduction and hazardous waste minimization.

Source reduction means one of the following:

Any action which causes a net reduction in the generation of hazardous waste.

Any action taken before the hezatdous waste is generated that results in a lessening of the properties which cause it to be classified as a hazardous waste.

“Source reduction” includes, but is not limited to, al l of the following:

“Input change” which means a change in raw materials or feedstocks used in a production process or operalion so as to reduce, avoid, or eliminate the generation of hazardous waste.

“Operational improvement” which means improved site management so as to reduce, avoid, or eliminate the generation of hazardous waste.

“production process change” which means a change in a process, method, or technique which is used to produce a product or desired result, including the return of materials or their components, for reuse within the existirig processes or operations, so as to reduce, avoid, or eliminate the generation of hazardous waste.

“‘Product reformulation” which means changes in design, composition, or specifications of end products, including product substitution, so as to reduce, avoid, or eliminate the generation of hazardous waste.

“Source reduction” does not include any of the following:

Actions taken after a hazardous waste is generated.

Actions that merely concentrate the constituents of a hazardous waste toreduce its volume or that dilute the hazardouswastetOFeduceitshazarQusCharactenshcs . .

Actions that merely shift hazardous wastes from one environmental medium to another environmental medium. -

Treatment.

The best way to evaluate the applicability of source reduction methods is to first determine what hazardous wastes you generate and the process which generates them. For each process and hazardous waste generated, you need to ask yourself:

-

Can I eliminate this process without affecting the operation of this department?

23

Can I substitute a nonhazardous material for the hazardous material currently being used in the process?

Can I substitute a less hazardous material for the hazardous material currently being used in the process?

Can the waste be reused in the same process without affecting the quality of the process? Can we recycle this waste onsite and reuse it in the same process?

Cantheprocessbechangedtobemademoreeffkient in its use of the hazardous material?

Can I order only the quantity of material I need to perform this process?

Hazardous waste minimization refers to any method used to reduce the amount of hazardous wastes that need to be disposed (see Figure 4-1). Therefore, source reduction is considered a part of waste minimization. Source reduction is the preferred method because it avoids the generation of hazardous wastes.

Another popular hazardous waste minimization technique, as shown in Figure 4- 1 , is recycling. Recycling can be performed onsite or offsite. In general, recycling includes:

Using the waste stream from one process as an input s t r m for another process

Recirculating the waste stream from a process to supplement its input stream

Reclaiming a spent material for reuse in the same process or a different process

Other methods of hazardous waste minimization would include treating the hazardous waste after it is generated in order to minimize the amount that needs to be disposed.

For each hazardous waste generated that does not have a possible source reduction method, you need to ask yourself:

Can the waste be used as an input material at another department?

Can the waste be sent to an outside recycler?

Can the waste be sent offsite for reclamation?

Can I retum unused materials to the manufacturer?

Can I substitute a recyclable material for the nonrecyclable material currently used?

~

4.3 Overview of Legislation on Waste Reduction

Currently, waste reduction legislation exists in various forms at both the state! and federal level. As it becomes more expensive to comply with regulations covering air, water, and landdisposal of hazardous wastes, waste reduction is becoming an attractive alternative. In fact, some of the recent amendments to these regulations specify source reduction or pollutiori prevention as the fmt option.

Both federal and state legislation require the waste generator tocertify (by signing) on the manifest that the generating facility has a waste reduction program in place. In other words, when you sign the manifest, you are certifying that you have a waste reduction program at your facility. However, the existing legislation does not define specific goals or programs, therefore, the type of waste reduction program is up to you. Also, at both the state and federal level, each large quantity generator has to submit a report to the California EPA, Department of Toxic Substances Contro1,at least every 2 years. This report should discuss the generator’s accomplishments in changing the volume and toxicity of hazardous waste during the reporting period. This report is typically prepared as part of the biennial report required by large quantity generators.

The State! of California has gone a step further than the federal government by approving Senate Bill 14 (SB 14), which requires that generators prepare waste reduction plans. These plans must evaluate a generator’s waste streams for source reduction options according to set criteria. The requirements of SB 14 are discussed in more detail in Section 4.4 and Chapter 11.

~

4.4 Senate Bill 14 Requirements __

The State of California has approved SB 14, which enacts the Hazardous Waste Source Reduction and ManagementReview Act of 1989.The objectivesof SB 14 are to reduce the overall generation of hazardous wastes, reduce the release of chemicals into the

24

WASTE MINIMIZATION TECHNIQUES i

I RECYCLING I ONSITUOFFSITE

I

SOURCE REDUCTION uuu I

I

I I SOURCE CONTROL ' PRODUCT

L

SUBSTITUTION

€3- GOOD HOUSEKEEPING

PRACTICES - Wart. stream a rogatlon Invanlory contry Em byoo lnlnl SplPVleok p e v o X n Schodullng lmprovrrnrni I INPUT MATERIAL

MODIFICATION InpuI purMcr1ton hpul rubsllluUon

I

TECHNOLOGY MODIFICATION lmprovd controls Pmasr modlflallonr

Walor Energy c o n s o r ( k n consewailon Equlp"1 chMg.s

FIGURE 4-1 WASTE MINIMIZATION TECHNIQUES Wrm: U.S. EPA Repod lo Congrass on lha Mlnimlrallon d Hazardous Wasle. 1986.

environment, and to document hazardous waste management information.

Some of the key features of SB 14 include:

SB 14 applies to facilities that generate 12,000 or more kilograms (26,400 pounds) of hazardous waste or 12 lcilograms (26.4 pounds) or more of extremely hazardous waste per year. Thresholds apply to nonexempted hazardous wastes.

Generators are required to prepare both a,Source. Reduction Evaluation Review and Plan (Plan), and Plan Summary on or before September 1,1991, and every 4 years thereafter.

The generatar must certify that the plan will be implemented.

Generators are required to prepare both a Hazardous Waste Management Performance Report (Report) andReportSu”aryonorbeforeSeptember1,1991, and every 4 years thereafter.

A copy of the Plan, Plan Summary, Report, and Report Summary must be available for public review and submission to the California EPA. if required

The Plan must include an estimate of the total quantity of hazardous waste generated at the facility. For the waste streams that account for more than 5 percent of the total quantity of hazardous waste (waste streams are determined by California Hazardous Waste Codes), the generator must list and evaluate applicable and avail-

able source reduction methods. The generator must look for source reduction method If no viable some reduction method can be identified, the geneeator need to docmented it. However, the generator may choosc ___

to consider other waste minimization methods (i.e.,

~

recycling). ~

The Report should describe current hazardous waste management practices during the last entire calendar year and how these practices have changed since the selected baseline year. Initially, the baseline year should beaiullcalendaryearpriorto 1991 in whichsubstantial wastegenerationandonsiteandoffsitehazardwswaste management data are available. Specifically, the Report should include: quantities of wastes managed for the c m n t year and baseline year; a description of current hazardous waste management practices: an assessment of each management practice implemented since the baseline year and its affect on the quantity of hazardous waste generated, a description of source reduction, recycling, and freatment methods preViously implemented; a description of factors affecting the management of hazardous wastes since the baseline year and an assessment of the net effect in reducing the volume of wastes for land disposal.

4.5 Approach to Hazardous Waste Reduction

Figure 4-2 illustrates the generalized approach you can take in developing your hazardous waste reduction program. Appendix D describes the program developed for the City of Anaheim.

26

Y

--

Offslte Recycllng

Checkllst No. 5

CHAPTER 5

Developlng

Program

Conduct a Faclllty

Assessment

SECTION 6.2

t

c

Obtaln Management Commltment

SECTION 5.1

Get Employees Involved

SECTION 5.2

mmunlcat Ion

SECTION 5.3

. Deflne Your

Objectives

SECTION 5.4

B

CHAPTER 7

Develop Your Hazardous

Waste Reductlon

Alternatlves

4

Process CHAPTER 9

Implement

Selected

Ellmlnatlon

Checkllst No. 6 Your I I \

Reduce Volume or Toxlclty

Checklist No. 3 Establlsh a

Mlnlmlzatlon Work Group I

SECTION 7.1.4

Get Outslde Asslstance

SECTION 7.1.2

CHAPTER 6

Scope Your Hlerarchy for Selection

Nonhazardous Materlal

Checkllst No. 2

Housekee Ingor Inventory bntrols

Checklist No. 1

Evaluate '-4 Alternatlves Your I

Alternatlves "i CHAPTER 10

~

Develop Hazardous Materlals

Purchaslng and

Management Plan

1 Save $

4 Improve Worker Safety

4 Decrease Llablllty + Im rove

gur Environment

FIGURE 4-2 OVERALL HAZARDOUS WASTE REDUCTION APPROACH

I ' I

I

Chapter 5 - Step 6 w DEVELOPING YOUR HAZARDOUS

WASTE REDUCTION PROGRAM

ChaDter 5

Now that you are aware of the importance of a waste reduction program, you need to establish your own interdepartmental hazardous waste reduction program specific to the individual needs of your city.

5.1 Management Commitment

A starting block and an essential element for a successful hazardous waste reduction program is a strong commitment from management. In order to gain management support you may have todo some"markebing" and explain thebenefits of yourprogram. Here are some recommendations:

A hazardous waste reduction program can minimize employee exposure to hazardous materials, reduce offsite disposal costs, and decrease long-term fmancial liability. '

A hazardous waste reduction program can be an excellent way to encourage employees to become involved in the improvement of city operations.

A proactive program such as this can foster positive public relations with the community.

Once you have commitment from the top-level, you needmanagement tocommunicate their commitment to city employees. Here are some ways:

Allocation of resources, personnel, or dollars to the administration of the program

Article(s) in the city or department newsletters sup- porting the program

Attendance by top-level management at program planning meetings

Site visits by top-level management to facilities that perform industrial operations to discuss processes and possible strategies

It is essential that the management commitment is reinfbrced regularly, otherwise, the program could lose its momentum and not achieve the results you antici- pated. To ensure continued support, keep management informed of program status and any problems you may be experiencing.

5.2 Department and Employee Involvement

A hazardous waste reduction program requires participation from all levels of your city organization. It is important to include both the employees who manage operations and employees who perform processes and operationsinthedevelopmentoftheprogram.If,during the planning process, the individual needs and problems

, of each department can be considered prior to the implementation of the program, each department wi l l be more receptive to implementing changes that need to take placein theiroperations. In fact, you willbe relying oneachdepartment'semployees torecommendhazard- ouswastereductionstrategies'soitisimportantthatyou involve them in the development stage.

5.2.1 Recognition

Recognition is an excellent motivational tool to get employees involved in a program. Here are some sugges tions:

Openly honor employees at staff meetings or at the job site who make successful hazardous waste reduction suggestions before their fellow employees.

Recognize these employees in your press releases and newsletters.

Start a Hazardous Waste Reduction Employee of the Month program and post their picture and name at the entrance to city hall or their department.

5.2.2 Employee Incentive Progrants

An employee incentive program is a good mechanism to start your employees thinking about waste reduction within their area of expertise and also to involve many people in the program from the start. Here are some ideas:

___

-~

Monetary reward or compensatory time-off for successful implementation of a hazardous waste reduction technique

-

Monetary reward for best hazardous waste reduction suggestion of the month

29

prizes for the best hvydous waste reduction suggestion (You may be able to get prizes donated by your community businesses)

Monthly achievement awards, signed and presented by the mayor or city manager, for the most successful hazaraous waste reduction technique

5.23. Department Incentive Programs

On a larger scale. you may find it beneficial to set up a depamnent incentive prognm. Here are some ideas to encourage positive competition between departments:

A party, lunch, or dinner provided for the department with the highest hazardous waste reduction over a 6- month Mod

A trophy or pIaque for the department with the highest hazardous waste reduction for the month

Speciai Achievement Award for the department with the most successful hazardous waste reduction program

5.3 Communication

Letting people know about your hazardous waste reduction efforts is a vital part of your hazardous waste reductionprogram.Yourobjectiveisto informbothcity employees and your community that you are implementing a program that benefits both the city and the environment.

5.3.1 Employees

Management. As discussed in Section 5.1. it is important to communicate with management and keep them informed of the progress of your program to get their conunued support. Therefore, you may want to develop a quanerly progress report which could outline the following:

Summary of program status

Achievements during the last quarter

Problems encountered and possible solutions

Activities planned for next quarter

Employees. Many cities and/or depments publish

newsletters to disseminate information to employees. You may be able to utilize an existing newsletter, perhaps develop an “Environmental Comer”: which could include information on your program as well as providing household recycling and environmental protection tips; orstananewsletterofyourown toadvertise your program and keep employees up to date on the progress. A newsletter can be used a number of ways, for example:

. Request employee suggestions for hazardous waste reduction strategies within their area of expertise. You can print names of employees who contribute to the program, their ideas, and describe how their suggestion has helped achieve waste reduction.

Use the newsletters to disseminate information on upcoming meetings and incentives available for hazardous waste reduction suggestions.

Disseminate information through a newsletter to employees concerning proven hazardous ware reduction techniques. Your program can only be successful if employees are awm, of what to dc and what their responsibilities are to make hazardous waste reduction successful.

5.32 Your Community

Environmental awareness throughout the country is higher than ever before. Establishing a program in your city toreduce theamount of waste you generate not only benefits you, but also provides your community with a positive image of your city and provides local businesses with an incentive to s m t a program of their own. Keep in mind that many large and small businesses in your city can benefit from the experience aid knowledge you gain from implementing your tazardous waste reduction program. Let your communiry know what you are doing. how you plan to proceed with your program, what results you expeck and where they can obtain additional information.

Nothing can generate support and keep a program moving forward like positive publicity. Here are a few ways to get publicity flowing:

,

Local newspapers (see Figure 5-1 for an example press release)

Local cable TV stations

Flyers (printed on recycled paper)

30

(...) will examine ways to reduce waste

Over the next year, (...) will study how to reduce the amount of hazardous waste produced in (...) and will publish the findings.

City staff will identifjl types of waste generated in the city-- waste oil, cleaners, solvents, paints, and other substances- then will study ways of reducing the waste by recycling or switching to products that generate less hazardous waste.

Reducing the wastes will cut pollution and save the city money in disposal costs and long-term liability, said city General Manager XXXXXXX.

(...) = Your City's Name

FIGURE 5-1 EXAMPLE PRESS RELEASE

Periodidly distributing the progress of your program to local politicians and businesses

Rescntations at city council meetings or other community meetings. These gatherings will provide a forum to share your waste reduction techniques to your community and allow for comments and suggestions

Remember to always stress the positive aspects of your program and the benefits it will provide for the entire city. Invite business members and residents of your city to participate. Just as your knowledge and experience can benefit their business, they may also have suggestions to help you with your program.

5.4 Objectives of Your Program

The objectives of your hazardous waste reduction program are:

Identify all hazardous wastes generated at your facility.

Determine which processes contribute the greatest amount of hazardous wastes at your facility.

Evaluate as many of your processes as possible for applicable source reduction or waste minimidon a l d v e s starting with the pmctss generating the most waste and continuing the evaluation of pro- cessesindescendhgorderaccording totheamountof hazardous waste they produce.

Determine which source reduction or waste minimi- zationalternativeismostappropriateforeachp~ess evaluated.

Implement the selected source reduction or waste minimization alternative.

5.5 Procedures for Getting Started

There are several items you should keep in mind when beginning your hazardous waste reduction program:

~

~

You need to get approval and a firm commitment for financial assistance from your upper management as discussed in Section 5.1.

You need to i n f m your department of the commitment firom upper management for a successful program. Everyone should know that this project is a priorityandthatuppermanagement isbehind youand needs your support in finding solutions.

You need to set up a communication program to let everyonein thedepanmentknow what the program is all about. Everyone should be invited to participate. The most successful program will allow input from as many people involved in your hazardous waste producing processes as possible. This includes the workers as well as the technical personnel.

You will need to conduct an assessment of your department to determine what processes and waste streams are present in your department as early in the planning stages as possible. You will need to gather as much process information as possible during this assessment and also determine what department personnel will be helpful for future tasks.

You will need to prepare a schedule of activities to be distributed throughout your department It may be beneficial to assign responsibilities to specific tasks with specific due dates.

32

- _ Chapter 6

FACILITY AND PROCESS ASSESSMENTS

Chapter 6 Step

This chapter will help you perform the assessment of your department to determine what types of hazardous materials you use and what processes are generating your hazardous wastes. This chapter is organized as follows:

Section 6.1 Objective of Conducting Assessments. Why you need to perform an assessment.

Section 6.2 Preparing for the Assessment. How you perform the assessment and what information you need to gather.

Section 6.3 Waste Reduction Numbers and Setting Up a Data Base of Waste Streams. How you can organize the information you gather during the assessment to help determine appropriate hazardous waste reduction techniques.

Section 6.4 General Assessments by Department. What to look for if your department is:

- Convention center - Electric utility facilities - Facilitiedstreet maintenance -Fire department

- Parks and recreation - Police department - Reprographics - Sewage treatment plant - Stadium - Water utility facilities

- Golf C O U ~ S ~

6.1 Objective of Conducting Assessments

The purpose of the assessment is to gather the back- ground information you will need to determine appropriate hazardous waste reduction techniques for your department. In order to evaluate waste reduction alternatives, you need to know the following for your department:

e

e

e

The types of materials used and the processes in which the materials are used. ~

The types of wastes generated from use of these IllaterialS.

The processes or operations that generate waste and the types and quantities of waste they generate.

How wastes are handled, s a d , and disposed.

How materials are ordered, distributed, and invento- ried.

Whether certain nonhazardous wastes are being handled as hazardous wastes.

Whether certain hazardous wastes are being handled as nonhazardous wastes.

Spill cleanup equipment and procedures.

General assessment of housekeeping procedures.

Whether materials are present that are not currently being used.

Whether existing waste minimization measures are being implemented by some employees.

6.2 Preparing for the Assessment

There are several things you can do to prepare for and perform a successful assessriient of your facility:

Set up interviews with employees knowledgeable about the materials and processes used within your department who can provide the data you need.

Prepare a standadized questionaire you can use or distribute toemployees to maintain consistency in the information you gather, both in content and format. A sample questionaire is provided in Appendix E. __

Survey the facility and note all materials you see and their location.

Note how your department handles hazardous wastes.

33

6.3

Note the appearance of the workplace and areas where hazardous wastes are generated and stored.

- Are hazardous wastes properly labelled in accumulation and storage areas? (See Section 2.4.)

- Are employees taking proper precautions when handling hazardlous wastes?

- Do employees who handle hazardous wastes have adequate training? (See your Safety Manager.)

- Are hazardous waste storage areas properly labelled and constructed?

Question employees on handling, storage, and disposal procedures for hazardous wastes.

- Are hazardous wastes being mishandled as nonhazardous waste? Do you generate a hazardous waqte and there is no documentation of its disposal?

Check to see if chemicals with expired shelf lives are being stored within the facility.

Review all the records concerning hazardous materials and hazardous wastes:

- Are MSDSs available for all chemicals used?

- Are hazardous waste manifests available for at least the past 3 years?

- Do you have a USEPA Identification Number and is it used correctly on hazardous waste documentation? Are you using the right number?

- Do the transporters and disposal facilities you use for your hazardous wastes have their own USEPA Identification Numbers?

Waste Reduction Numbers and Setting Up a Data Base of Waste Streams

After you complete your assessment you need to organize the information collected in a useful format to start evaluating waste reduction alternatives. Table 6-1 has been prepared to assist you in this organization.

You can assign WRNs to each waste stream to help track individual waste streams through this process. If your city will track waste reduction progress by means of a data base, your number should also identify your department. For example:

EU-001-PW

could stand for:

EU = Electric Utilities Department (Department lOCatOr)

001 =Waste Stream Number 1 PW = Paint Waste (waste type)

Tables 6-2 and 6-3 show additional department locator and waste type examples.

6.4 General Assessments by Department

This section is organized by department to provide assistance on what to look for and what types of information may be available during your assessment of the department. This section is based on previous assessments performed at various municipal departments and should be used as aguideline for your assessment. You should add and delete information, as appropriate, during your actual assessment. The materials you list in Table 6- 1 should be specific and not generic categories as listed below in some cases.

6.4.1 Electric Utilities Department

A typical electric utilities department might perf" the following operations:

Repair and maintenance of transformers

Repair and maintenance of substations

Table 64 illustrates typical processes performed at an electrical utilitiesdepartment,applicablematerials used in each process. and potential wastes generated.

6.4.2 Water Utilities Department

A typical water utilities department might perform the following operations:

Repair and maintenance of water meters

34

w cn

c

Material Used

MSDS Available

? YES NO

I

H-

I I

Table 6-1 Organizing Waste Reduction In format ion Department

I I I Waste

Generated ?

YES NO

Frocess Generating

Waste

Is Waste Hazardous

2 YES NO

Quantity Generated Per Year

Waste Reduction Number

I 1

Table 6-2 Department Locators

Department Name

Electric Utilities Water Utilities Fleet Maintenance Parks and Recreation Convention Center Stadium Reprographics Fire Department Police Department Golf Course Sewage Treatment Plant

Locator

EU W FM PR cc ST RG FD PD GC SP

Waste Type

Paint Waste used oil Asbestos Waste Solvent Oily Rags Rags with Oil and Solvent Empty Containers Waste Pesticides Solvent Sludge Paint Thinners PCBs

Table 6-3 Waste

Code

PW uo AS ws OR RS EC WP ss PT PB

‘pes*

Waste Type

Oil Filters Paint Filters Absorbent with Oil Expired Chemicals Lab Packs Diesel Fuel Inks Trichloroethane Trichloroethylene Chlorinated Solvents Lead Dust

Code

OF PF A 0 XC LP DF IK TA TE CS LD

*Note: Your waste type codes can be as general or specific as you prefer as illus- trated in the table above. More than one waste stream can have the same waste type code because several processes may generate the same waste type.

I Table 6 4 Typical Processes Performed at an Electrical Utilities Department

Material

Solvent degreaser

Paint thinner

paints

Lubricants (aerosol)

Rags

Repair and maintenance of water pumps at water production facilities

Process

Transformer oil change

Transformer cleaning

painting trahsformerlsubstations

Painting transformers

Lubricating moving parts

Transit pipe dismantling

Cleaning

Table 6-5 illustrates typical processes perfomed at a water utilities department, materials used in each process, if applicable, and wastes generated.

4.43 Facilifies/steet Maintenance

AtypWkilities/smt maintenancedepartment might perform the following operations:

. Facility repair and maintenance

Facility painting

Waste Generated

FCB-conuuninatcd oil

Broken glass

PCBcontaminated syringes

PCBcontaminated gloves

Waste solvents, waste containers, rags

Waste containen, waste thinners, rags

Waste containem

Aerosol cans

Asbestos waste

Oily rags, rags with solvents

Vehicle maintenance and pair

Vehiclepainting

Table 6-7 illustrates typical processes performed at a fleet maintenance department, materials used in each process, if applicable, and wastes generated.

6.4.5 Parks and Recreation

A typical parks and recreation department might perform the following operations:

Pesticide, herbicide. and fertilizer application

Painting benches and structures Minor street maintenance

Maintaining trees, vegetation Table 6-6 illustrates typical processes perfomed at a facilitiedstreet maintenancedepartment, mateaialsused in each process, if applicable, and wastes gem.rated.

6.4.4 Fleet Maintenance

A typical fleet maintenance department might perform the following operations:

Steam clean vehicles and equipment

provide materials for d o n programs

Table 6-8 illustrates typical processes performed at a parks and recreation department. materials used in each process, if applicable, and wastes generated.

37

Table 6-5 Typical Processes Performed at a Water Utilities Department

Material

Degreasing solvent Desiccant Hand cream

PrOeeSS Waste Generated

Water meter cleaning Rags with solvent Drying of water meter parts Empty containers Cleaning oilv/dirtV hands Wastewaterhns

Super nonbutyl cleaner Dry moly lubricant Glass cleaner stop rust Corrosion retardant, part primer Hydraulic oil Paintthinner Cutting oil

I I Transit pipe removal I Asbestoswaste

Cleaning parts Empty containers, rags Lubricant parts Empty containers, rags

Parts cleaning Parts maintenance Water turbines Paint water meters Rass Metal cutting machine Asbestos waste

Cleaning Rags Empty aemsol cans, rags Empty aerosol cans, rags Waste hydraulic oil, rags

I I Solvent Pump repair I Contaminatedrags

Dry silicone Ready mix joint compound Electrical parts cleaner

Table 6-6 Typical Processes Performed at a Facilities/

Street Maintenance Department

Seal parts

Clean parts

Empty small containers, rags Empty small containers, rags Waste small containers, rags

I I

Silicone FreOn Refrigerant

Material

Seal parts Air conditioning Waste small containers Air conditioninn

Waste small containers, rags

Waste small aerosol cans

Process

Insecticide Lubricants

Waste Generated

Applied to manholes Parts

Waste small containers Waste small emDtv containers. raps

Drain cleaner Spray paints

Cleaning Empty small containers Painting Waste aerosol cans, rags

Paint thinner Filters from paint booth

I Odor destroyers

Painting Waste thinner, rags Painting Waste filters

I Applied to manholes ~ -1 --W&Lsmall empty containers

Lacquer thinner Paints Silicone lubricants Tar foundation compound Fluorescent light fixtures Contact cleaner

Painting Painting Empty containers, brushes, rags Lubricant Tar Repair Waste empty bags Changing Fixtures Clearing Waste aerosol cans. rags

Waste 5-gallon empty containers, rags

Waste small aerosol cans, rags

Broken or unbroken light fmtures

I 1 waste aerosol cans, rags

38

I

Table 6-7 Typical Processes Performed at a Fleet Maintenance Department

Material ROCeSS Waste Generated

Antifreeze Radiator flushhopping off Waste antifreeze

Lube oil Engine oil Waste oil, rags

Oil filters Engine oil change Crushed oil filters ~ ____ ~~

Car batteries

m!v==r

Cleaners

Lubricants

paints

Carburetor cleaner

Dead battery removal Spent batteries

Cleaning Rags, empty containers

Cleaning Rags, empty containers

Lubricate pats Aemsol cans, rags

Vehicle painting

Clean carburetor

Paints, 5-gallon empty containers, brushes,

Empty small cans, rags

rags

I Motorcycle oil I Oilchanges I oilyrags I

~~ ~

Sodium hydroxide

Nonchlorinated brake parts cleaner

Floorcleaning Wastewater

Brake parts cleaner Rags

39

Thinners Vehicle painting Waste thinner, rags

SWP Steam cleaning Wastewater

Fast flush Cooling system Empty small cans I

Metal cutting oil

Fuel treatment

Starting fluids

Lube oils I

Metal cutting Metal cuttings, rags

Fuel injector cleaner

Carburetor Empty small cans, rags

Lubricating empty parts Rags

Empty small cans ~

~

~

Table 6-8 Typical Processes Performed at a Parks and Recreation Department

Material process Waste Generated - Cleaners Cleaning vehicles, bathrooms Rags, wastewater

Solvents Cleaning Rags, empty containers

Deodorized kerosene Steam cleaning Wastewater, rags

Lubricants Lubricate engine parts, Rags, empty small containers mower parts trimmer parts

Brake cleaner Clean brakes Rags, empty small containers

Anti-comsion treatment Parts treatment primer Rags, empty small containers

Chlorine Pool treatment Empty containers

Gasoline (leaded) Mowershehicle fuel Rags

Diesel fuel Mowershehicle fuel Rags

Paint Bench painting Empty 5-gallon containers, brushes, rags ~~~ ~

I

Detergent Steam cleaner

Herbicides Landscape treatment

Insecticide Landscape treatment

Fungicides Landscape treatment ~ ~ ~

Bathroom disinfectants

PVC pipe thread seal

~ ~ ~~~~

Bathroom cleanup

Sprinkler system repair

Wastewater

PVC primer

Surface disinfectants

Woodwork glue

1

~~

Sprinkler system repair

Cleaning

Woodwork

Empty containers

Paintlthinners

Hydraulic fluid

Bar and drain oil

Glass cleaner

Small empty containers, Gigs ~~ I

Benchedfacility painting Empty containers, rags

Tree saw Empty containers, rags

Sterilize tools Empty conkhers, rags

Mirror and window cleaning Empty containers, rags

Empty containers

Empty containers, rags

40

Table 6-9 Typical Processes Performed at a Convention Center Department

Material Process I Waste Generated

I I Adhesives I ~raffitiremova~ I Empty containers, rags

Graffiai remover

Cleaners

Floor cleaners

Potassium hydroxide

Pesticides

CFC 113

~~~ ~

Graffiti removal

General cleaning

Cleaning floors

Chiller room Waste containers

Landscape application Empty containers

Refrigeration Waste containers

Empty aerosol containers. rags

Empty containers, rags, wastewater

Oil flow (unused materials)

Remodeling Asbestos

I ~~~ ~

Unknown

Acids ~

Abandoned after convention Off specification chemical products

I Bathmomcleaning I Empty containers, rags I

6.4.6 Convention Center

A typical convention center might perform the following operations:

Facility repair and painting

Cleaning

Table 6-9 illustrates typical processes performed at a convention center department, materials used in each process, if applicable, and wastes generated.

6.4.7 Stadium

A typical stadium might perform the following operations:

Facility repair and cleaning

Cleaning

Table 6- 10 illustrates typical processes performed at a stadium, materials used in each process, if applicable, and wastes generated.

6.4.8 Reprographics

A typical reprographics department might perform the following operations:

Printing and reproduction

Table 6-1 1 illustrates typical proccsses performed at a reprographics department, materials used in each process, if applicable, and wastes generated.

6.4.9 Fire Department

A typical fire department might perform the following operations:

Hazardous material response

Fireresponse

Minor facility and equipment maintenance

Table 6- 12 illustrates typical processes pedonned at a fire department, materials used in each process, if applicable, and wastes generated.

6.4.1 0 Police Department

A typical police department might perform the following operations:

Photography laboratory

Helicopter maintenance and repair

Table 6- 13 illustrates typical processes performed at a police department, materials used in each process, if applicable, and wastes generated.

__I_

~

41

Material

Ammonia

Chlorine 1 Fungus cleaner/disinfectant I Wastewater

Process Waste Generated

Cleaning Wastewater, empty containers, rags

~ ~~~~ ____

Degreaser

Chemical window cleaners

Vinegar and water

Graffiti remover

Air freshener (indoor)

Hydrochloric acid

Diesel fuel

Insecticide

Gum remover

Disinfectant

Laundry detergent

paints I paintingstructures I Empty cans (5-gallon). rags, brushes

~ ~ ~ ~~

Cleaning with rags Rags

Indoor window cleaning Rags

Outdoor window cleaning Rags

Sprayed on graffiti Rags

Spray botde application Rags

Bathroom cleaners Wastewater, rags

Vehicle power

Grounds maintenance Empty bags

Spill cleanup, adsorbents, rags

Remove gum

Cleaning Empty 55-gallon drums, mgs

Laundering Wastewater, containers

Empty cans (small), rags

I Thinners I Paintingstructures 1 Empty drums (55-gallon), rags

I Stucco I stucco I Empty bags, rags

42

Table 6-11 Typical Processes Performed at a Reprographics Department

~

Material Process I Waste Generated

I Developer

Fixer Reproduction process waste fixer

Rubber rejuvenator Reproduction process Empty containers, rags

Isopropyl alcohol PreSSeS Empty containers, rags

Quickwash Clean rollers Solution, empty containers

Typewash Washdown rollers Solution, empty Containers, rags

paint painting Waste paints, empty containers, rags

Anti-skin ink spray Reproduction Empty small containers

Reducing varnish Reproduction Empty small containers

Liquid cobalt drier Reproduction Empty small containers

Blanket release coating Reproduction Empty small containers

Gloss binding varnish Reproduction Empty small containers

Silicone sprays Stop ink from sticking Empty small containers, rags

Cylinder cleaner and desensitizer Reproduction Empty small containers

Blanket doctor Reproduction Empty small containers, rags

Blanket conditioner Reproduction Empty small containers, rags

L

I Reproduction process I Waste developer

43

Table 6-12 Typical Processes Performed at a Fire Department

~ ~

Safety-Solv

Simple Green

I Material ~ ~ ~~ ~~ ~ ~~~~ ~

Clean driveways Wastewater, brushes

General Cleaning Rags

I Waste Generated

~

Flares

Dust control

Bleach

Hydroclean

Ansulite

Fogging compound

I

~ ~ _ _ _ _ ~

Emergency alert Empty containers

Dust control during fm Empty containers

Laundering Empty 5-gallon containers, rags

General cleaning plllposes Empty 5-gallon containers, rags

Put out fires Empty bws

Windshields Empty containers

Material

Ammunition

~~

Off specification paint and empty paint I I I containers, brushes, rags Paints (petroleum distillates) Stenciling, truck touch-up

Process

Shooting

Photo developing chemicals

Various chemicals

Freon

Table 6-13 Typical Processes Performed at a Police Department

Photo processing Waste materials

Cooling towers - maintenance Empty containers

Air conditioning Empty containers ~ ~ ~~ ~ ~~

Spray solvents Cleaning

Mace Police operations

Stoddard solvent Heliport floor cleaning

Confiscated materials I Miscellaneous chemicals

~ ~ ~


Offspecification mace

Waste Stoddard solvent, mop

Waste Generated

Waste lead, lead dust

Miscellaneous offspecification or discarded chemicals*

44

6.4.11 Golf Course 6.4.12 Sewage Treatment Plant A typical sewage treatment plant might perform the following operations:

Wastewater treatment

Table 6-15 illustrates typical processes performed at a sewage treatment plant, materials used in each process, if applicable, and wastes generated.

A typical golf course might perform the following

Fertilizer, insectide, herbicide and fungicide applica-

operations:

tion

Golf cadfacilities maintenance

Material Process

Oil Vehicle maintenance

Grease Vehicle maintenance

Hexbicides Grounds maintenance

Fungicides Grounds maintenance

Insecticides Grounds maintenance

Hydraulic oil, emulsifier Cleanup fluid leaks and spills on turf grass

Vehicle maintenance and golf markers Paint

Oil Oil spill cleanup

Table 6-14 illustrates typical processes performed at a golf course, materials used in each process, if applicable, and wastes generated.

Waste Generated

Waste oil, rags


Empty containers

Empty containers

Empty Containers

Wastewntainers,wasteemulsifier,rags

Empty cans and aerosol containers, brushes, rags

Waste absorbent, rags

45

Material

Paint thinner

Paint

Lab packs

Oil

ROCeSS Waste Generated

Painting Waste paint thinner, rags

Painting

Offspecification - Paint

Machinery and vehicle maintenance

Waste intake filters, brushes, empty containers, rags

Waste lab packs

Oil contaminated water, rags

I Freon I Oilandgreasetest I wastefreon I Solvents

I ~nalytical process - COD test I Waste dyes, rags

~ ~~~~

General cleaning Waste solvents, rags

1 Recycling system

Construction and remodeling

I I I Oil sludge

Asbestos

46

Chapter 7 Step 6 w AVAILABLE HAZARDOUS WASTE

REDUCTION ALTERNATIVES

Chapter 7 Step

This chapter will assist you in developing hazardous waste reduction alternatives for hazardous materials and waste streams identifed and information collec ted during your assessment. This chapter is organized as follows:

Section 7.1 Developing a Method for Evaluating Waste Reduction Alternatives. This section . discusses how you use the information you have organized during Chapter 6 to begin your evaluation of hazardous waste reduction alternatives including: where you can get help in identifying waste reduction methods; what types of hazardous waste reduction alternatives youshouldconsider for each waste s&eam; and how you can establish a Waste Minimization Work Group consisting of knowledgeable individu- als who can assist you in your evaluations.

Section 7.2 Waste Reduction Alternative Number 1 - Housekeeping or Inventory Controls. Can you

minimize the wastes you produce just by changing the way you order materials or handle your wastes? This section will describe how you can recognize if you havea housekeepingproblem; what some of the advantages and disadvantages of

considering this hazardous waste reduction altemative are; and some examples of housekeeping controls and inventory controls for you to consider.

Section 7.3 Waste Reduction Alternative Number 2 - Substituting a Nonhazardous Material for a Hazardous Mate- rial. Can you use nonhazardous materials in place of some of the hazardous materials you are currently using? This section will provide some advantagesanddisadvantages

for you to consider when evaluating the appropriate- ness of this altemative. Some typical nonhazardous material substitutes are also included.

@ Section 7.4 Waste Reduction Alternative Number

3 -Substituting Materials that Re- duce the Volume or Toxicity of the Wastes You Generate. Can you substitute a material you currently use with one that is less hazardous for employees to use or

0

\

generates less wastes? This section will provide -

advantages and disadvantages you should consider when evaluating this hazardous waste reduction altemative. Some typical material substitutions are also m Section 7.5 Waste Reduction Alternative Number

4 - Onsite Recycling. Does your department generate a waste in suffi- cient quantity that can be recycled within your department? This section wil l provide advantages and dis- m advantages for you to consider when

evaluating this altemative and some typical onsite recycling techniques.

Section 7.6 Waste Reduction AlternativeNumber ~~~~, Recycling. Does your department generate a hazardous waste that could be sent to an offsite recycler?

This section will provide some advantages anddisad- vantages for you to consider when evaluating this altemative and some typical offsite recycling techniques.

Section 7.7 Waste Reduction Alternative Number 6 - Process Elimination. Does your department currently generate a hazardous waste from a process that could be eliminated without impacting the way your department does business? @ This section will provide advantages

and disadvantages for you to consider when evaluating this hazardous waste reduction alternative. Some examples of process elimination are also included.

7.1 Developing a Method for Evaluating Hazardous Waste Reduction Alternatives

7.1.1 Where to Begin

Your department may generate a wide variety of wastes from a wide variety of processes. The evaluation of all

47

of these waste screams is a large task that can appear to be overwhelming. To begin your evaluation, review Table 6-2 to determine which processes are generating the largestamount of hazardous wastes. Choose twoor three of these waste streams for evaluation. Once you have completed these evaluations, you can go back and evaluate a few more waste streams. Eventually you will have addmsed all of your waste streams.

For those hazardous materials you use that do not generate a wastc sueam (see Table 6-1). Le., when the material is completely used up in the process, yo0 may want to evaluate the possibility of substituting a nonhazardousmawial.Review thelistsofnonhazardous material substitutions (Table 7-1) to determine if any apply. Substituting a nonhazardous material can provide your depamnent many benefits, even though the process or operation does not result in any waste. Some of thew benefits are as follows:

Lcss rigid storage requirements.

Decnased chance of producing a hazardous waste if the material is not used before its expiration date.

7.12 Resources and Assistance Available

Whenever you need assistance in your evaluation of one or more of the hazardous waste reduction alternative described h Sections 7.2 through 7.7, there are several resources available that you should use as often as possible:

California EPA Department of Toxic Substances Control 400 'P" S m t Sacramento, CA 95814 916l324-1807 or 916/322-2822

The Department ofToxic Substances Control has knowledgeable personnel available to answer questions you may have about each of the waste reduction alternatives you need to evaluate for each waste stream. They L&I provide useful information conceming proven waste reduction methods. The Department provides waste reduction guidance and advice to many types of indus- mes throughout the state of Califomia This is a re- some you should not overlook.

Local Businesses. Find out what local businessesare doing to reduce their hazardous waste generation. Many businesses in your area probably perform the Same types of operations as your department Deter- mine their successes and failures in hazardous waste reduction techniques. Ltam from what others have already done.

Local Sanitation District. Since yoursanitation district is concerned with the types of chemicals that are processed through its treatment plans it may be able topvide you with a listing of materials that are safer for you to use in your processes and easier on its operations.

. California Environmental Business Resources Assistance Center (CEBRAC) Anaheim Education Center of Fullerton College 100 S. Anaheim Avenuc Anaheim, CA 92805 800/352-5225

CEBRAC provides advice to Califomia small businesses concerning compliance with state and South Coast Air Quality Management District (SCAQMD) environmental regulations. The Center is sponsored by Califomia Community Colleges, the sw Department of Commerce's Small Business Office and the Small Business Assistance Center of the SCAQMD.

Your Regional Omce of the California EPA, De- partment of Toxic Substances ControL Your Re- gional office of the Department of Toxic Substances Control is an excellent source of information and advice for all your environmental concuns. Phone numbers and areas of jurisdiction are provided in Section 1.1 of this document.

Your Local Government Commission.Contact your local govemment commission to obtain publications and other information for local govemments concerning waste minimization. such as nontoxic substitutions for household chemicals. Your local govemment commission can refer you to applicable, available, and current literature.

Your Local Health Agency. Contact your local health agency to determine what information it can provide on material substitution or hazardous waste reduction methods. It may be able to direct you to businesses in your area that have successfully implemented waste reduction methods that could benefit

48

P v,

Instead of... Use ...

Drain Openers

Ovcn Clcsrncrs

Wood Cleancrs/Polishcs

Toilet Bowl Cleaners

Abrasive Clcancrs

Ammonia Cleaners

Bleach Cleaners

Copper Cleaners

Silver Polish

Motor Oils

Disin feclants

Synthetic, long lasting oils.

~~

Plungcr; flush with boiling water, 1/4 cup blking soda, and 2 02. vinegar.

Baking soda and wam

1 part lemon juice, 2 p m olive or vegetable oil

Brush with baking soda; mild detergent

Rub area with 1/2 lemon dipped in borax, rinse dry

Vinegar, salt and water mix for surfaces. Baking soda and water for the bathmom.

For laundry, 1/2 cup white vinegar, baking soda, or borax.

Vinegar and salt

Mix 1 quart warm water, 1 rsp baking soda, I tsp salt. Place silver and a piece of aluminum foil into solution

1/2 cup borax in 1 gallon of water. <

Automotive Products

~~~

Oil-Based Paints

Suippcrs

Wood Prcscrvative

~ ~~ ~~ ~

Latex or watcr based paint. Sandpapcr, heat gun, scrapper. wire brushing, mcthylcne chloride/phcnol frce strippen.

Rol-rcsislant wood or prcucald wood

Table 7-1 Guide to Household Products and Less Hazardous Alternatives Sheet 2 of 2

Aemds

Perfumes

Instead of... Use...

Pump spray hairspray, shaving soap.

Alcohol-free products

Herbicides

Rodenticides

Insecticides

Fertilizer

Lawn and Garden Products

Strong hoeing or hand weeding: keep grass short.

9 For Rats and Mice: Live traps, remove food supply, cover holes and drains.

For Roaches: Mix bbnc acid and powdered cacao: baking soda and powdered sugar. Do not use boric acid if pets are present.

For Ants: Chili powder and cream of tartar at point of entry.

For Other Insects: Insecticidal soaps, import predatars such as ladybugs, ground

Compost food waste: do not compost near wells or bodies of water.

beetles or praying mantis, remove plant debris or wood from garden.

Personal Care Products

I Batteries

Pool Chemicals

Solar power. mechanical watches, rechargeable batteries, AC adapters, nonportable equipment

Ozone or UV tight systems

For fleas. herbal collars, ointments, or place Eucalyptus leaves in bed; add Brewers yeast to pets diet. I Pet Roducts

PhOtoprocess ing Chemicals I Switch from film to video equipment

I 1

Your program,

Your Safety Manager. When considering the safety factors involved in selection of a hazardous waste reduction alternative. consult your safety manager. Make your safety manager a part of your program.

7.1.3 Hazardous Waste Reduction Alternatives and Hierarchy for Selection

The waste reduction altematives you need to consider for each of the two or three waste streams you have identified for evaluation are:

Housekeeping or inventory controls

Substituting a nonhazardous material fora hazardous material

Substituting a material that reduces the volume or toxicity of the wastes your department generates

Onsite recycling

Offsite recycling

Process elimination

These hazardous waste reduction alternatives are listed in the order of ease of implementation, benefit from result, and cost of implementation. Within each altemative you may determine that several different waste reduction methods apply. When this is the case, each method should be evaluated separately. Sections 7.2 through 7.7 will describe each of these alternatives in detail. Chapter 8 will step you through the evaluation process.

Your selection of a specific hazardous waste reduction method will depend on several factors:

Cost of implementation

Costsavings

Ease of implementation

Worker health and safety

Federal, state, and local regulations

Overall waste reduction potential

. City policies and procedures

7.1.4 Establishing a Waste Mininabtion Work Group

Set up a work group whose responsibility is to evaluate and select hazardous waste reduction methods. The following types of personnel could be involved:

Upper management, a person who can determine the administrative implications of waste reduction methods and also assure that you get the upper level support and fmancial resources you need to cany out theP~gram.

Workers from your department, people who know the processes and operations and can help you determine the feasibility of implementing waste reduction methods.

Purchasing representative, a person who m advise you and help in obtaining purchases of materials you may need for your hazardous waste reduction program, especially inventory control measures.

Department manager, aperson who can assure that implementation of the hazardous waste reduction methods is properly implemented at the department level.

Waste Disposal Coordinator, a person responsible for storing and preparing waste for offsite disposal/ recycle.

Health and Safety represeutative,aperson whocan advise you on possible safety impacts Oi benefits to employees.

The board should meet frequently to assess the p r o m progress and review the possibility of evaluating additional waste streams for waste reduction methods.

7.2 Hazardous Waste Reduction Alternative Number 1: Housekeeping and Inventory Controls

a Affect on operations Housekeeping and inventory controls are some of the

51

easiest hazardous wa3tereduction altematives to implement as well as one of the least expensive. It can be as simple as changing the way you handle waste orchang- ing the way you order materials. Implementing these controls may include training your personnel in better handling and procurement procedures.

7.2.1 How to Recognize you Have a Housekeeping Problem

The following is a listing of items to look for to identify possible housekeeping problems:

Do YQU have designated areas where wastes are accumulated? If you designate areas for waste accumulation and label containers appropriately as to which wastes should be accumulated there, you can avoid mixing different waste types and, more impor- tantly, you can avoid mixing nonhazardous wastes with hazardous wastes. Train employees to use these containers and in the importance of keeping different wastes separated. For example:

- Do not mix oily waste with solvent containing wastes.

- Do not discard rags used to clean parts with solvents with rags used for other purposes.

- Do not throw trash, such as soda cans, in hazardous waste accumulation containers. - Do not mix adsorbents used to collect oil spills and leaks with regular oily wastes (especially if your waste oil is sent offsite for recycling).

- Do not accurnulate used oils in empty solvent or pesticide containers. Remember, all hazardous waste accumulation containers should be kept covered at all times. Keep accumulation areas clean and uncluttered.

Do you store hazardous materials in designated areas? Keep your hazardous materials stored in designated areas. When not using hazardous materials, return them to the storage area. Avoid possible spills or contamination of hazardous materials by keeping containers closed and at their designated storage areas when not in use. Keep yow material storage area and your waste storage areas separate. Have MSDSs available near the point of storage for all the hazardous materials you use.

before discarding them? Use your hazardous materials according to manufacturer’s instructions. You do not have to discard hazardous materials until they can no longer be used for their intended purpose. For example:

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~

- Do not discard rags until you can no longer effectively use them.

~~ - Do not diswd degreasing solvents until they no longer effectively clean products.

- Do not discard hazardous materials until the container is empty: change motor oil and oil fiters only when necessary.

- Use one container of material at a time, and when the container is empty. open a new one.

- When using solvents and rags for cleaning, only apply solvent to rag just prior to use and keep the solvent container covered.

Are you currently storing materials that you do not use? Inspect all the material storage areas to see if material is present that is no longer used. You should make it standard procedure in your department to only store those materials that are used in your operations. Materials past their expiration date are considered wastes and must be properly disposed. You should consider finding a market or specific business that may be able to use your unused materials. Check the California Waste Exchange listing available from the Califomia EPA Department of Toxic Substances Control (see Section 7.1.2) for possible users.

Do you order more material than your department can use? During your inspection, check to see if materials are expiring before being used. It may initially appear to be cost effective to order materials in bulk. However, when you factor in the cost of disposing of the material you were unable to use before the expiration date, buying in bulk may not seem so favorable. -~

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7.2.2 Advantages -

The advantage of housekeeping and inventory controls as a hazardous waste reduction alternative include:

. Easy to implement. Do you completely use your hazardous materials

52

HAZARDOUS WASTE STORAGE AREA WEEKLY INSPECTION CHECKLIST

SITE:

A. DRUM INVENTORY 1. Total number of drums in use. 2. Have any drums been stored past the 90 day storage limfn

(If so, list drum number and contents on reverse side)

B. STORAGE AREA 1. Storage area neat C orderly? 2. Adequate aisle space? 3. Area secured from unauthorized entry? 4. Warning signs posted2 5. Area free of spills and leaks? 6. Berms/containment area .in good conditlon? 7. Ignitable wastes stored 50 feet from property line? 8. Incompatible wastes segregated?

C. DRUM LABELING 1. Drums labeled with the words "hazardous waste? 2. Name/address of generator on labels? 3. Contents of drums on label? 4. Hazardous properties on drums? (e.g. flammable) 5. Accumulation date on drums 6. EPA identification number on drums?

D. DRUMSTATUS 1. Drums in good conditlon? 2. Uds/caps in place and secure? 3. Waste compatible with containers? 4. Drums containing ignitable wastes grounded?

E. EMERGENCY EQUIPMENT 1. Eye wash/shower in working order? 2. Spill containment/flrefightlng equipment available? 3. Communication/alann system in working order? 4. Contingency plan available?

YES NO

COMMENTS

COMPLETED BY: DATEmME:

FIGURE 7-1 EXAMPLE WEEKLY INSPECTION CHECKLIST

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Cost-effective. being followed and general housekeeping is improving. Figure 7-1 is an example Inspection Checklist. . Increased worker safety by training workers to prop-

erly handle wastes to avoid mixing, and by keeping the work area cleaner and less cluttered.

9 Storing less materials in your department.

e Decreasing the chance of accidental spills or leaks.

Generating a smaller quantity of wastes by reducing the amount of material you use. Less waste will need to be handled, transported, and disposed. ,

. Need to transport less hazardous material to your facility.

Easier preparation of the Hazardous Waste Manifest sinceaccumulation areas are labeled and uncluttered.

Reduce the chance of being fined for improper management of hazardous wastes.

7.23 Other Considerations

When evaluating housekeeping and inventory controls asa waste reduction altemative, you should also cons ik

You may need to change the way you order materials.

You may need to change the way employees use matesials.

You may need to change the way employ& handle Wastes.

7.2.4 Typical Housekeeping Controls

Examples of housekeeping controls include:

Purchase covered containers for the accumulation of oily rags and rags with solvenu.

Provide hazardous materiaishazardous waste management mining for employees.

. Preparestandardlabelstobeusedonhazardouswaste accumulation containers. This should bean easy task for those wastes you routinely generate.

Start inspecting your department on a regular basis (weekly) to assure that housekeeping controls are

Keep materials stored in locked areas. Assign one person the responsibility for assuring new materials are distributed only when previously distributed materials are spent.

Post signs instructing employees on proper housekeeping procedures (e.g., CONTAINER MUST BE KEPT COVERED). Figure 7-2 is an example of easy-teunderstand housekeeping guidance that can be posted.

7.215 Typical Inventory Controls

Examples of inventory controls include: Order only those materials used by the department.

Order materials in quantities that can be fully used before the expiration date.

Adopt the FIFO (fmt in-fmt out) rule while using materials in stock.

Dispose of all materials currentiy stored that are not being used. If the materials have not expired, try to give it to another deparmrent that uses this material instead of disposing of i t Many universities or other schools will take unexpired chemicals for their labo- ratories.

After implemenfing housekeeping controls, track the amount of materials used and adjust ordering accord- ingly.

7.3 Hazardous Waste Reduction Alternatives Numbers 2 and A

3: Substituting a Non- ~

hazardous or Less Hazardous Material for a Hazardous Material

If practical substitutions exist, these alternatives can also be very easy to implement. To be successful, substitutions of nonhazardous or less hazardous materials for hazardous materials should be coordinated through your facility’s purchasing group. This may include developing a list of suitable nonhazardous and/

54

~ E M p T y - PLACE IN

AEROSOL CANS I I\ f . P Y C E IN DRUM LABELED EMpTY-I SMALL SPRAY CANS"

IF EMPTY AND DRY, PLACE' IN TRASH DUMSTER. IF NOT EMPTY AND DRY,

DRAIN LIQUID INTO DRUM LABELED

AND TRAYS TRASH DUMPSTER IF NOT DRY, PLACE IN DRUM LABELED

"LARGE PAINT CANS" PAINT CONTAINERS 'PAINT RELATED WASTC ,

\ P \

b CONTAl N E RS k #

WASTE SOLVENTS OR DEGREASERS DRAIN LIQUID INTO

(E.G. SS-BO. 'WASTE SOLVENTS DRUM LABELED

FULLBACK, SS-25 ZEP SOLV/SAFE)

L I / / / /

I WASTE PAINT

DRAIN LlPUlD INTO DRUM LABELED

'PAINT RELATED WASTE"

THINNERS OR REMOVERS I (E.G. TURPENTINE 1-1

ENAMEL REDUCER

PLACE IN DRUM PCB CONTAMINATED -

CONTAMINATED

OIL, GREASE,

PLACE IN DRUM AND LABEL DRUM WITH

CONTENTS (E.G. DIESEL AND ABSORBENT)

SPILL RESIDUE

OVER 5 GALLONS

I RETURN TO SUPPLIER

IF POSSIBLE. If NOT, PLACE IN

HAZARDOUS WASTE STORAGE AREA AND NOTIFY

ENVIRONMENTAL SERVICES

5 GALLONS OR LESS

I 1 AFTER DRAINING, PLACE

EMPTY CONTAINER IN DRUM LABELED

"LARGE PAINT CANS"

FIGURE 7-2 HAZARDOUS WASTE DISPOSAL PROCEDURES

ti: \FlGURES\LAO32253.WM\WASTEPRO.DWG

I ' I I ! I

or less hazardous materials that may be purchased, evaluating each purchase requisition to see if nonhazardous or less hazardous altematives exist, and restricting the purchase of hazardous materials if suitable nonhazarQus or less hazardous materials exist.

7.3.1 Considerations

For this hazardous waste reduction alternative to prove practical at your facility, the material that is acting as a substitute should essentially provide the same function as the material being substituted. The following questions need to be asked:

Will the substitute work as well?

Will the substitute generate a different type of waste stream or release?

Will the substitute require purchasing additional equipment?

Will the substitute require additional maintenance?

Will the substitute cost more?

. Will the substitute result in releases to the air, water, or land?

. Will the substitute violate any legal or regulatory requirements?

Will the substitute violate any maintenance specifications?

There are two anxu where substituting a nonhazardous or less hazardous material for a hazardous material have met with some success - paints and solvents. Table 5-1 lists some examples of substitutions that may prove practical at your facility. Many of these substitutions will require field testing at your facility to determine if they will adequately meet your n&.

Water-based detergents and surfactants may be effective in replacing hazardous solvents for many heavy-duty cleaning applications, such as removing gmses and oils from parts, as well as performing general housekeeping such as washing greasy floors, walls, etc. Sometimes washing the parts with high pressure hot or cold water or steam works as effectively as solvents.

7.33 Advantages

. Use of these substitutes will result in less hazardous waste generation.

. Potential purchase cost of these substitutes may be less than those for solvents.

Useofthesesubstitutes willresultinincreased worker health and safety.

Use of these substitutes will reduce the emissions of Volatile Organic Compounds (VOCs).

Some of the substitutions are biodegradable.


Detergents are used throughout industry, but are not suitable for cleaning electrical and elecmnic components.

Some substitutions may leave a film that can be critical on certain types of equipment

There may be increased drying time with some substitutions.

Someof the substitutionsthat acommercially available are known carcinogens.

For many of the available substitutions. the cleaning value has not becn well established.

Some of the substitutions are ozone depleters.

Alternative paint and stripper formulations such as water-based paints or strippers, high solids paints, alternative organic-based paints and strippers, and powder coatings have been used in industry as substitutes for solvent-based paints. Water-based paints are available in commercial industry. Applications in- elude painting furnishings, and facility and building maintenance where wrfaces only need moderate protection and where uccornrivc requirements are most important. High-solids low-solvent-based paints are becoming more widely used in industry. Commercially available dry powder minting methods include the electrostatic dry powcicr mctnod and the fluidized bed

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method. The dry powder methods are reported to offer enhanced surface protection. better coverage, and reduction in solvent emission. nK dry powder methods also reduce hazardous waste, eliminate wastewater, use less paint and lower overall cost per square foot of painted surface (Higgins, Thomas, 1989. Hazardous Waste Minimization Handbook. Lewishblishers, Inc. Chelsea, Michigan.)

alloys cannot be subjected to these conditions.

Alternative paint strippers for metal surface applications are generally not as effective as conventional strippers.

Organic and water-based strippers may take longer to loosen paint and lacquers than solvent-based strip Pers.

7.3.4 Advantages 7.4 Hazardous Waste Reduction

Dry powder techniques are readily adaptable to cur-. rent production methods and are easily learned by painting personnel.

Water-based paints eliminate the need for hazardous solvents and subsequent hazardous disposal costs.

Powder coating reduces the use of clean-up solvents.

Powder coating eliminates the use of paint thinners.

. Water-based paints generally cost less than solvent- based paints.

Water-based paints and Strippers reduce employee exposure to VOCs.

High solids solvent-based paints have substantially less VOC emissions than standard solvent-based paints.

Dry powder painting techniques do not use solvents and therefore completely eliminate air emissions of VOCs, reduce clean-up solvent use, and eliminate paint thinner use.

Some strippers are recyclable.

7.3.5 Other Considetations

Slow working strippers do not dry easily.

Water-based coatings typically have longer drying times than solvent-based paints.

Water-based paints do not last as long as solvent- based paints, so they require an increased painting frequency.

Dry powder painting requires that the items to be painted withstand a curing process of approximately 350 degrees Fahrenheit for 30 minutes. Aluminum

Alternative Number 4:

1691 Onsite Recycling P - I

The objective behind onsite recycling is to take a waste materialandrecycleitonsitesothatitcanbeuseasaraw material in a facility’s processes. Onsite recycling typically involves some investment in capital equipment and additional personnel, which makes it m m difficult to implement than the previous alternatives considered. This investment may prove worthwhile at your facility depending on the amount of wastes that can be recycled. Another consideration is the centralization of the onsite recycling. In other words, one maintenance shop may not generate enough used oil to make onsite recycling economically feasible. However, if used oil from al l of the maintenance shops and vehicle repair amas at a facility were brought to a centralized onsite recycling unit, this option may prove feasible.

Examples of some situations where onsite recycling has been successful:

oilrecycling

Solvent recycling

Empty container recycling

7.4.1 Advantages

Reduced liability since the waste is not being transported offsite.

Elimination of manifesting requirements.

Reduction of raw material costs if the recycled mate- rialscanbeusedassubstitutesinsomeofthefacility’s processes.

Reduction of disposal costs since waste is not being disposed of offsite.

57

7.42 Other Considerations 7.52 Other Considerations

. Capital and operating costs incurred for the recycling equipment.

M a y need to obtain hamdous waste facility permits from the USEPA and the California EPA since your facility will be treating the waste onsite (depends on the waste stream and recycling method)

May rcsult in increased health and safety concems for employees who will have to operate equipment.

M a y ~ a l n ~ ~ ~ a l e f a l n m a n o t h e ? .

Creates potential for releases to other media.

7.5 Hazardous Waste Reduction Alternative Number 5: Offsite Recycling

m @ @ @ The objective behind offsite recycling is to transport a waste material to an offsite recycling facility. Offsite recycling does not typically involve any investment in capital equipment and additional personnel. Some ar- rangements may inc1ude"roundmpping." Le., the recycling facility r e m s the recycled material back to the generator for use.

Examples of some situations where offsite recycling has been successful:

Oil recycling

Solvent recycling

Empty container recycling

Oil and/or solvent contaminated rag laundering

7.5.1 Advantages

. May reduce raw material costs if the recycled mate- rialsareretumedtothefacilityforuseinitsprocesses.

. Reduced disposal costs. The cost for offsite recycling varies with market conditions. However, the costs are typically not more than the transportation costs. In some instances the recycler may pay the generator for Lhe waste.

Less liability than disposing of the waste at a hazardous waste facility.

. Increased liability since the waste is being transported offsite.

Requires manifesting.

May transform hazardous waste from one form to another.

. Creates potential for releases to other media.

7.6 Hazardous Waste Reduction

@ Alternative Number 6: Process Elimination

Tie objective behind this hazardous wasw reduction alternative is to eliminate unnecessary processes that generate hazardous wastes. This will probably be the most difficult alternative to implement since most of your facility's processes are probably necessary to your daily operation. However, it may prove worthwhile to think about some routine operations where the frequency may be changed. For example, does your facility change the oil in all pieces of equipment at the same time even if an oil change may be unnecessary for some equipment? Is it necessary to clean according to the current frequency or can you reduce how often you perform general facility cleaning? How often do you repaint park tenches. and is it necessary? Can you use concrete benches rather than wooden benches? Can small quantities of leftover paints of different colors be mixed and used for painting new surfaces?

7.4.1 Advantages

Eliminates the waste stream entirely. This reduces liability, improves worker health and safecy and pre- vents releases to other media.


May be difficult to implement

May result in costs for replacements.

May decrease the public's satisfaction with the city.

58

- Chapter 8 WASTE STREAMS FOR

HAZARDOUS WASTE REDUCTION POTENTIAL

This chapter will describe the process for evaluating hazardous waste reduction alternatives for your waste streams.

8.1 Overview of the Process

The entire waste reduction evaiuatiori process can be. .. summarized by the following itemized list:

1. Determine what materials your department uses.

2. Determine which materials used at your department are considered hazardous materials.

3. Determine which processes in your department use hazardous materials.

4. Determine which processes that use hazardous materials generate a waste.

5.Detemine the waste types generated from these PrOCeSSeS.

6. Determine which two or three waste types are generated at your department in the largest quantities, and what processes generate them.

7. Evaluate waste reduction methods for each of the two or three waste types identified by considering each of the six waste reduction alternatives.

8.2 Which of the Materials Used at Your Facility are Hazardous?

To determine which materials used at your facility are hazardous, review the MSDS for each material. If a chemical listed in Table B-1 is present in the material, it is considered hazardous. Typical hazardous materials used by municipalities include:

Ammonia Chlorine

Antifreeze CrankcaseOil

Asphalt Developer

CarBaaeries Die@ Fuel

FemcChloride

Fixer

FloorSmpper

Fungicides

Gasoline

Glass Cleaner

Grease

Herbicides

Hydraulic Oil

Hydrochloric Acid

Insecticide

Isopropyl Alcohol

Kerosene

Lubricants, e.8.. W W O

Lubricating Oil

PaintThinner

Paints

PVC Containing Material

Sodium Hypcchlorite

Sodium Hydroxide

SolventDegreaxr

Sulfuric Acid

In Table 6-1, list all the materials used at your facility that are considered hazardous.

8.3 Which of the Processes at Your Facility Use Hazardous MateriaIs?

In Table 6- 1, after each hazardous material identified, list the processes at your facility in which the material is used. Typical processes uscd by municipalities include:

AsphaltRepair

Demoli tion/Conshuc tion

Equipment Parts DegreasingKleaning

Equipment Lubrication

Facility Cleaning

Facility and Equipment Painting

Grounds Maintenance

59

~boratoqAnalyses Waste Caustics

LawnTreatment

PoolTreatment

UsedOil

Waste Solvents

Pump Repair

Reproduction

steamcleaning

Street Maintenance

Vehicle Maintenance

Wastewater Flocculation

8.4 What Hazardous Wastes are Generated From These Processes?

In Table 6-1, after each process description, list the waste that is generated from use of that material in that process. Typical wastes generated by municipalities include:

AerosolCans

Asbestos Contaminated Debris

Contaminated Wastewater/Rinsewater

Empty Containers (paint, oil, solvent, pesticide)

Offspecification MateWChemicals (paints, solvents)

Oil Contaminated RagdAbsorbent

8.5 What Waste n p e s are Generated at Your Facility?

InTable6-1,aftereach wastegenerated,assignaWRN to each waste. Each WRN will include a description of the waste type. Many pesses will generate the same waste type. You can evaluate all processes that generate the same waste type at the same time. In other words, a waste stream is a combination of all wastes b m pre cesses that generate the same waste type. For example, if you use several types of spray solvents that each generate waste rags, each WRN may contain the waste type RS (solvent laden rags). The combination of these three wastes would be one waste stream designated as RS M solvent laden rags. Typical waste types generated at your facility are listed in Section 6.3.

8.6 What ’itvo or Three Waste Streams are Generated Most?

From Table 6-1, combine all like waste types. For example, add all the annual quantities generated for RS, OW, AS, etc., into waste types designated as RS, OW, AS, etc. Choose the two or three waste types that constitute the largest amount of the total of the hazardous wastes that your department generates. These are the waste types you will be evaluating first for hazardous waste reduction methods.

8.7 Evaluating Your Hazardous Waste Reduction Alternatives

Oil Filters 8.7.1 Evaluation Procedure

OiVSolvent contaminated Water

Paint Filters

PCB Containing Oil

Solvent Contaminated RagdAbsorbent

UsedBatteries

Waste Acids

Now that you have identified the two or three largest waste types, the processes that generate them, and the materials that contribute to these wastes, you are ready to decide how best to reduce these waste streams. You can use this section of the manual to decide if there are any other ways to handle hazardous materials at your facility that may reduce the amount of hazardous waste you generate. As was stated in Chapter 7, there are various ways to reduce your hazardous waste. Some of

___

these ways are better than others. When evaluating waste reduction alternatives, these are some of the considerations you must address:

Has the alternative changed the waste so that it is no longer hazardous or is less hazardous?

For example, the paint shop may decide to substitute water based paint for solvent based paints. The solvent in the paint is one of the components that makes the paint hazardous becauseof itsvolatility and ignitability. By using water based paints, the hazard from solvents is eliminated.

Are there any technical problems that will prevent you from changing your current waste management practices to the selected alternative?

For example, an equipment maintenance p u p may decide to substitute a water based detergent for a halogenated solvent that has been used to clean electronic parts. Cleaning of electronic parts must not result in any debris remaining on the parts. In this instance, water based solvents have not proved to be suitable for cleaning electronic parts, although they are effective in other cleaning applications.

Is the selected alternative going to result in higher costs for your facility?

For example, your facility may decide to recycle its solvents onsite. This alternative will result in the purchase of solvent recycling equipment, action to comply with regulatory requirements, and perhaps the implementation of additional health and safety requirements for your workers. Depending on how much solvent your facility generates, this alternative could be too costly, or may in fact prove to be cost-effective.

Will the selected alternative transfer the waste to another media?

For example, your vehicle maintenance shop may decide to Mse containers that previously contained oil so that the containers can be thrown in the trash. Though the containers can then be managed as nonhazardous waste, the rinsewater will now contain oil residue. Depending on your local sanitation districts, the shop may not be allowed to discharge your rinsewater into the sanitary sewer without further treatment

Will the selected alternative reduce the quality of the service or the quality of the product your

facility provides? ~

Forexample,theparksandrecreationdepartment might decide to reduce the amount of empty insecticide containers it generates by reducing the frequency for spray- ing the grounds. Will this alternative mean that the park's landscaping will deteriorate, resulting in un- happy citizens?

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Will theselectedalternative put your employees in danger?

For example, if your facility decides that it is cost- effective to recycle solvents onsite, will this mean that your employees will be exposed to increased health and safety concems. 'Ihese concems may cause you to eliminate this alternative. or your facility may decide that the waste reduction obtained justifies additional employee health and safety uaining and equipment,

Will the selected alternative comply with existing regulations?

For example. if your facility decides that washing containers is the selected alternative, there are various regulatory considerations such as: whether a permit is needed from the California EPA for the drum washing facility, what options are available for disposal of the rinsewater, will permits be needed from the local air district, and will safety regulations be violated.

. Will the selected alternative require employee training?

For example, if the selected alternative requires the purchase and operation of new equipment. employees will need to be trained in its use. Again, the cost of providing training has to be weighed against the benefit from waste reduction.

Will you have to hire someone with more experience to evaluate hazardous waste reduction methods?

For example, if the waste that you are trying to reduce is generated from a process that you are unfamiliar with, it may become necessary to either hire someone or retain consulting services.

This manual provides a sequenceof checklists (Appen- dix F) to help you decide which waste reduction alternative or combination of altematives is best for each of the two or three largest waste types that you selected for

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61

evaluation. These checklists first ask you abouz your cunent hazardous waste reduction practices. Answers of"yes" mean that you arealready using that alternative to reduce your hazardous waste. Answers of "no" mean that the hazardous waste reduction alternative may be used at your facility. To help you decide yes or no, there are some additional items on the checklist to consider which ask the questions that were discussed above. Remember that you can get help answering some of the above questions by referring to the list of resources provided in Section 7.12.

Each of the two or three largest waste types that you selected has to be evaluatedseparately. If you have used oil (UO), waste solvent (WS), and oily rags (OR) as your three major waste types, you need to evaluate UO using the sequence of checklists, then evaluate WS using the sequence of checklists, and then evaluate OR using the sequence of checklists. Six checklists make up the sequence of checklists. one for each of the following hazardous wastereduction alternatives that may workat your facility.

Checklist No. 1 Source Elimination by Housekeeping or Inventory Controls

This altemative can prevent the facility from generating the haz A ardous waste by organizing and

controlling hazardous materials. This source reduction alternative is discussed in more detail in Chapter 7.

Checklist No. 2 Substitution of Non hazardous Materials

'Ihisalteanativecorrsistsofusing a material that is not hazardous in place of a hazardous material

that is currently being used. This hazardous waste reduction alternative is discussed in more detail in Chapter 7.

@ Checklist No. 3

0 4 4 Substitution of a Material

that Reduces Volume or

ous: however, the amount of waste that you produce is less or the toxicity of the waste that you produce is less. This hazardous waste reduction alternative is discussed in more detail in Chapter 7.

Checklist No. 4 Onsite Recycling

This alternative consists of recy cling the hazardous waste at your facility sothat you do not have to send it offsite. Sending wastes

offsite may eventually result in liability for your facility. This hazardous waste reduction alternative is discussed in more detail in Chapter 7.

Checklist No. 5 Offsite Recycling I ! A \

alternative consists of

waste to a facility offsite sending the hazardom

t&&llrecyclei~ By recycling, youmay bepreventing any future liabiity for your facility. This hazardous waste reduction alternative is discussed in more detail in Chapter 7.

Checklist No. 6 Elimination of the Proces.

This alternative consists of deciding if the facility really needs to perform the operation or umess which uraduces the

waste. ~ o t e that this will rarely be the case. ws hazardous waste reduction aitemative is discussed in more detail in Chapter 7.

Each of these hazardous waste reduction alternatives is discussed in more detail in Chapter 5. In addition, the checklists refer you to more detailed sections in Chapter 5. Keep in mind that these waste reduction alternatives are listed in the most preferred order, 1 through 6. Source elimination by housekeeping is usually an easier and less expensive altemative to implement than offsite recycling. However, each facility will be different, and the checklist is intended to guide you towards selecting the best choice. Selecting the best altemative will depend on your answers to the questions on the checklist. You may not need to use al l six checklists since you may find that one checklist provides you with a hazardous waste reduction altemative that is best for your facility. However. it is suggested that even if you do not use al l six checklists. you follow the order listed above.

8.7.2 How to Complete Checklists

To complete the checklists follow the simple procedure described below:

1. Check*).es" if you are M y doing theproceciure listed.

62

2. Check‘ho” if you are not doing the procedure listed.

3. Check‘NfA” if the procedure does not apply to your facility.

4. If you checked “yes” for a procedure, you do not need to check off the questions going across the rest of the Page.

5. Ifyouckked“no,” you should continue and answer the questions asked for that procedure such as, ‘Will the method change the waste so that it is nonhazardous?” (“Yes” or “No”). Again. not all of these items will apply to each waste reduction procedure. If the item does not apply, leave it blank.

6. After completing the checklist, there is a space at the bottom for you to comment whether or not certain parts of the hazardous waste reduction altemative will work, and how. Complete this section using the answers on the checklist.

Remember, you do not have to check every item, rather, you should check what works best for your facility. If you do not check every item, it is still important for you

to go through the entire checklist since some of the options may not be obvious to you until you read them.

Thesechecklistsdonotaddresseverything you need ~

at your facility. Use the extra spaces to make the checklist specific to your needs. You know your facility best.

___

Once the checklists have been completed, you can select the hazardous waste reduction altemative or combination of alternatives that best meets the needs of your facility. Keep in mind that the primary aim is to reduce the amount of hazardous wastes, but you must consider other factors such as implementability, cost effectiveness, legality, and quality control. Your answers to the various columns on the checklist should help you to make these decisions.

Many of the typical processes and hazardous materials used within cities have been evaluated using the checklist and criteria discussed above. Some general recommendations are listed below. These should help you to select the best hazardous waste reduction method or combination of methods for your facility.

63

Chapter 9 WASTE

REDUCTION STRATEGIES

Chapter 9 Step

9.1 Implementation Considerations

At this point you have probably selected a combination of waste reduction methods that you feel can be implemented at your facility. You have also completed the source reduction summary checklist (Appendix G), which lists the various selected methods along with an implementation date for each method. During your evaluation of these methods, you have already thought about the many factors that could affect your ability to implement these methods. In fact,before these methods can be implemented you are probably going to have to make some changes in the way your facility currently operates. In any event, some coordination will be required before these selected hazardous waste reduction methods can be implemented. For example, you may have to:

Train employees on new procedures or new equipment

Change your current purchasing procedures

Purchase new equipment

Purchase different materials (less hazardous ‘or nonhazardous)

Develop and submit annual budget and capital improvement program budget requests

Develop and submit personnel requests

Initiate the bidding procedure for any capital pur- Chases

Develop a phased approach for introducing these new methods and new materials into your facility

9.2 Implementation Plan

Most of your selected waste reduction methods probably cannot be implemented immediately and will re- quireapenodduring whichvariousconsiderations (like those listed in Section 7.1) can be addressed. This time period will vary depending on the objectives that need to be achieved. For example, if a budget request has to be approved by your city council, that may take a longer time than if you have to train your employees in-house on good housekeeping techniques. However, remember that employee habits cannot be changed ovemight, and may require some sort of a phase-in period.

Therefore, the next step in the hazardous waste reduction process is to develop an implementation plan. This plan is basically a timetable for implementation of all selected hazardous waste reduction methods, and can be as detailed as you need it to be. This plan should be based on all the information you have gathered regarding budgeting, personnel needs. training periods, bid process,etc. Ataminimum it should include thefollow- ing:

Prioritization of hazardous waste reduction methods

Short-term versus long-term objectives

Responsible groups (both within andoutside thecity)

Start and end dates for implementation

Key dates or milestones for more complicated hazardous waste reduction methods

The implementation plan should not be considered the final step but should be updated and revised as you begin implementing the hazardous waste reduction program. Once you start, you may find that some implementation schedules need to be lengthened while others can be reduced. You should also include input from those responsible for budgetary, personnel and adminisvative matters, as well as the waste minimization work group. These representatives may have a better idea of the many factors that can affect the implementation process.

Even if very few changes are needed, you will need to project how long it will take to implement your selected waste reduction methods based on the various obstacles

documented in an implementation plan, which will be described in the next section.

~

you need to overcome. This projection is typically -__

65

Itisalsoimportant for you toincludein yourimplemen- ration plan a period where. potentially viable hazardous waste reduction measures can be further evaluated, since there may not have been enough time to do this in the evaluation phase of your hazardous waste reduction program. These potentially viable measures may be something to consider in your long range hazardous waste reduction program. Hazardous waste reduction planning does not end with this implementation plan but is a continuous process.

9.3 Establishing an Evaluation Plan to Monitor alid Rack Progress

An essential aspect of every new program is the period needed to evaluate and monitor its progress. This evaluation phase is intended to let you know if you are meeting your objectives, and, if not, provide ideas on how you can meet them. As mentioned before. hazardous waste reduction planning is a continuous process. You need to constantly evaluate the success of your selected hazardous waste reduction methods. If your objectives are not being met, then you should adjust the waste reduction program. If your objectives are being met, then you need to be aware of it so that your facility can take credit for asieffectiveprogram. This evaluation plan should include at a minimum:

Measurable Performance Goals by which hazardous waste reduction can be compared, e.g., pounds of hazardous waste manifested, disposal cost reduc- tions, etc. These measures need to allow for changes that may cause uncontrollable increases such as disposal cost increases by the disposal contractor, market fluctuations, and facility gmwth.

Waste Minimization Coordinator whose responsibility is to measure hazardous waste reduction progress.

Implementation schedule including defined review periods. Review will probably be continuous: however, you may have short-term and medium- term goals that you would like to meet.

~

___

Flexibility to revisit and modify the implementation plan based on the results of the evaluation (i.e., stop if alternative is not effective, or modify schedule to accommodatechanges in operation). Review progress of implementation often and make changes when necessary.

~

Methods of communicating progress to those responsible. In other words, your employees need to know how they are doing.

Estimates of the costs involved in implementation as well as the expected payback period.

Chapter 10 -_

MATERIAL PURCHASE AND MANAGEMENT PROGRAM

This chapter presents the purpose of a hazardous material purchase and management program (HMPMF') and some strategies for setting up such a program in your department or for your city.

Based on an assessment at another city, the following infonnation was collected. Various deparunents within the city purchased their own hazardous materials. Ma- terials were purchased by personnel on an as-needed basis.Itemswerepurchasedatlocalstoresthroughopen purchase orders. Purchase orders were required to be approved by the superintendent or department head. Some items were also obtained from the central warehouse. Them were no procedures by which various departments could share or transfer hazardous materials. If the material procurement procedures described abovearepresentatyourcity,thefollowingsuggestions for a HMPMP may be evaluated and refined to best fit your needs.

10.1 Purpose

"he purpose of an HMPMP is to enable you to do the following:

Minimize the amount of hazardous materials purchased and kept in storage.

Reduce the quantity of unused materials thrown away as hazardous waste, because the materials could not be used before its shelf life expired.

Standardize the types of materials purchased and used in different departments so that surplus materials can be distributed for use by other departments that need them.

Reduce thenumber of suppliers from whom materials axe purchased. If a large quantity of supplies are purchased from a limited number of vendors, they may take back surplus inventory at no cost Encour- age purchasing department to award contracts to suppliers who are willing to take back surplus inventory.

Monitor the health and safety aspects of materials uscd You cannot limit the potential for an employee to be exposed to a hazardous chemical if you do not monitor what materials they are using.

Implementation of such a program can have the following advantages:

0

0

e

0

0

10.2

Reduced material purchasing cost by limiting the amount of items bought.

Reduced hazardous waste handling and dispoial cost. because less materials will end up as waste.

Improved employee health and safety, since employees will be exposed to reduced amounts of hazardous materials and hazardous waste

Reduced liability from potential employee exposure and reduced long-tenn financial liability from disposal site clean up.

Reduced potential for fines from impropermanage- ment of materials and waste

Strategies Available

In this section. two strategies are presented for setting up a HMPMP for your city:

Section 10.2.1--Implement an HMPIvlP at Each De- partment

Section 10.2.2-Implement a Central HMPMP

10.2.1 Implement a Hazardous Material Purchase and Management Program bt Each Department

Individual departments in your city may not have a formal HMPMP. Materials may be purchased by indi- viduals on an as-needed basis. All purchase orders may be approved by the superintendent or department head. If these procurement procedures are currently used at your city, you may want to consider implementing an HMPNP at each department.

A department W M P may include the following activities:

Individual groups within a department would submit to the department manager a list of hazardous materials, including brand names, and estimated annual quantities used by the group. For each item, chemical

67

compositions would also be provided.

The department manager or a person designated by the manager would review and evaluate the lists for the following

- Suggestions for substituting hazardous materials with less hazardous or nonhazardous items.

- Apprupriateness of the quantities being used. Some groups may be over-stocking hazardous materials, andthendiscardingthemassurplusinventory.Records on hazardous wastes generated in previous years may be reviewed to identify groups that usually discard unused materials. Also, groups that overstock inventory may be idenaed during site assessments.

- Possibility of standardization of the types of materials used by departments within the city. This will allow trading of materials between departments, and prevent surplus inventory from being handled as hazardous waste. Comparison of lists from various departments will also help to identify departments that are implementing waste minimization measures by using less hazardous materials for similar operations. Some materials that may be easy to standardize include solvents, paints, paint thinners, and cleaners, since these items are used by most departments.

Once the group lists are finalized, h e department manager or person designated by the department manager would only approve purchase nrders for the listed materials and quantities. The lists would be updated on a regular basis. Purchase orders that differ from the approved list would require additional review and approval.

Purchase orders requesting bulk quantities of hazardous materials should be reviewed carefully. It is generally not cost-effective to bulkorder items to get discounts. Disposal costs typically far exceed the savings from bulk discounts. Items that have short shelf-lives must be purchased in limited quantities.

The first-in-fmt-out rule must be followed when using stocked materials (Le., place newly ordered materials behind in-stock items on shelves so the older materials are used first).

. Implement a shelf-life program at each department.

Before shelf-life expiration, every attempt must be made to make these materials available to other departments for use.

Employees must be made aware of the department HMPMP, and be encouraged to provide suggestions on improving the program and making it easier to implement

10.23 Implement a Central Hazardous Material Purchase and Management Program

A central HMPMP may be implemented in addition to the department HMPMP. At present, each department may be purchasing materials primarily from local stores, with limited items being supplied by the central warehouse. It may be that, because of low turn over, many hazardous materials stocked at a central warehouse may have expired shelf-lives.

Elements of a central HMPMP may include the following:

All departments would fmt attempt to fill purchase requisitions through the warehouse before going to an outside vendor.

The warehouse would maintain an inventory of hazardous materials based on the demand in the previous 3- or 6-month period. A high and low limit may be established for each item. Items would be purchased only if the inventory went below the low limit. Mate- rials would not be stocked above the high limit

Each department would supply the warehouse with listsofapproved materialsandquantitiesasdescribed in Section 10.2.1.

The warehouse would work with the departments to standardize the types of materials used.

The warehouse would maintain lists of surplus inventory at departments, and fill purchase requisitions by using up this inventory rather than reordering the items.

A shelf-life program and first-in-fmt-out program would be implemented by the warehouse to minimize shelf-life expiration of stocked items.

Whencontracting with suppliewhewarehousewould attempt to establish agreements where the supplier

68

will reclaim surplus materials and empty containers.

The warehouse may consider using a computerized material uacking program for continuous monitoring of inventory on-hand, and to track materials supplied to various departments. The program may also be used to monitor material shelf-lives.

Ihe strategies for setting up an HMPMP discussed abovemayneedtobefurthwrefinedsothataworkable program may be implemented at your city.

69

_I_ Chapter 11 DIFFERENCES BETWEEN SENATE BILL 14

(SB 14) AND THIS GUIDEBOOK

Chapter 11

from stationary equipment) This chapter is organized as follows:

Section 11.1 Differences. This section describes how use of this guidebook differs from SB 14 guidance when prepating your waste reduction program.

Section 11.2 Do You Need To Comply With. SB 141 ’Ibis section will describe how you can determine if SB 14 applies to your department.

Section 113 How To Adjust this Guidebook to Comply With SB 14. This section describes how this guidebook can help you comply with SB 14.

The infomation that is provided in this chapter is consistent with the guidelines for compliance with SB 14 that were in effect at the time of publication of this Guidebook’. Current guidelines can be obtained from the California EPA, Department of Toxic Substances Control (see Figure 2-1).

11.1 Differences

Table 11-1 following illustrates some of the major diffetencesbetweenthisguidebookandSB 141tqknmts.

ll.2 Do You Need to Comply With SB 14?

To determine if SB 14 applies to you, respond to the

1. Are any of the following exempted wastes present in

following:

Table 6-l?

PCBs or PCB-containing material

Asbestos

Infectious waste

Automotive Fluids (motor oil, hydraulic fluid, antifreeze, etc., &om vehicles; does not include oils

~

‘Guidance Manual for the Hazardous Waste Source Reduc- tion and Management Review Act of 1989, D e p r m n t of Health Services, Toxic Substances Control Program, Alter- native Technology Division.

Lead acid batteries

Wastes from site clean up and mitigation activities,

Samples and evidence from enforcement actions

Formation fluids and solids from oil, gas, geothermal exploration, and field development

Household hazardous wastes, wastes from household collection events, and wastes separated at community land!Xls

including remedial investigations

Waste pesticides and pesticide containers collected

Demolition wastehajor renovation waste

by county agricultural commissioners

Spent munitions and ordnance

Decommissioned utility poles

Yes: Which Exempted Wastes do you generate?:

GotoItem2

No: Go to Item 3 - 2. Cross out all the wastes listed in 1 above from Table

6-1

Go to Item 3.

3. Total the column “Waste Generated per year” h m Table 6- 1.

~

Enter Hazardous/Extremely Hazardous Waste Generated per year:

pounds

71

Go to Item 4.

4. Using Table B- 1. a any of thc hazardous waste in Tabled 1 consideredextremely hazardous ( e x m e l y M O U S ~ t e r i a l S ~ d C S i g I l a t C d w i r h a n ~ [‘I before their name)?

- Yes List your extremely hazardous wa5tt:

Go to Item 5

No: Go toItem8 7

5. Total aU wastes that arc extremely hazardous wastes in Table 6-1.

Ester Total Extremely Hazardous Waste: - pounds Go to Item 6.

6. Do you genaatc mort than 26.4 pounds of exucmely hazardouswastcpwycar?

- Y e s STOP!! You are required to comply with SB 14 (Go to Section 113)

- No: GotoItemf

7. Subtract the total in Item 5 from the mtal in Im 3.

pounds HazardouslExtremely Hazardous .Waste Generated (It- 3)

Genenrtcd (Item 5)

Subtract - pounds Extremely Harardous Waste

- pwnds Hazardous Waste Generated per year

COtoItun8.

8. Is the number of pounds listcd in Item 7 greater than 26*4oopounds?

- Yes: STOP!! with SB 14. (See Section 113)

You are required to comply

No: SB 14. Go to Item 9.

You are required to comply with -

9.You now have the oppomnity to develop your own hazardous waste rtduction program. in your own way. Set an exampk. Tlhking and successNly implementing hazardous waste minimization, no matter how much you generate, may entice small

tively. small generators arc significanL busintsses and h o ~ h o l d s to follow suit. C o k -

11.3 How to Adjust This Guidebook to Comply With SB 14

If yau have determined f” the analysis in Section 1lZabovethatyouneedtocomplywithSB 14nquire- mcnts, you can use the information you gatha during the development of your hazardous waste reduction prow using this guidebook to assia you in comply- ing with SB 14.

Here isone way youcan use this manual to comply with SB 14:

Complete Chapters 1 to 6 of this Guidebook

. Determine if SB 14 applies by using Section 11.3 abovc.

Rcfcr to SB 14 Guidance manual available from the California EPA, Department of Toxic Subsranccs Control (see Section 7.1.2). “Guidance Manual for the Hazardous Waste Source Reduction and Manage- ment Review Act of 1989.”

With the infanation gatherd thus far9 you can organize your data as recommended in this guidance document to detamine which waste streams to evaiuate.

F d l y . you can use this Guidebook U) help in your evaluationof source d u c t i o n altcmatives.TheCali- fomiaEPA guidance manual will help you with the format of your document, but not with the some reduction evaluations. __

~

SB 14 also requires you to document hazardous mattriavharardous wastemanagementpmccdurcsat your facility. Following this Guidebook’s assessment checklist will help you gather the information you need to complete this document

72

4 w

Item

Applicability

Approach

Evaluation Criteria

Table 11-1 Comparison of This Guidebook and SB 14 Sheet 1of 2

This Guidebook

Applies to all California cities regardless of Ihe amount of waste they generate.

Helps cities organize and tabulate data for all waste streams generated to select two or three major streams to evaluate. Once these waste sWams have been evaluated, and reduction techniques successfully implemented, other, smaller waste streams can be evaluated.

Ranks evaluation criteria from source reduction (the most favorable altemative) tooff-site recycling (the least favorable altemative) to help municipalities reduce the amount of hazardous waste they generate. While source reduction is favored, evaluations in this document are not limited to some reduction. Other waste minimization teehniques are considered. The goal of the waste reduction program is to minimize the amount of hazardous wastes disposed in landfills and to enjoy all the associated benefits of reducing the amount of hazardousmakxialsand wastes yourdepartment isrequired to manage. Process elimination is considered, since all processes and wastes are considered, in your evaluation. Small processes may sometimes be eliminated witliout affecting operations at your facility.

~~~

SB 14

Applies to all generators of greater than 12,000 kilograms (26.400 pounds) of hazardous waste per year or 12 kilograms (26.4 pounds) of extremely hazardous waste per year.

Helps applicable generators organize and tabulate data for all their waste streams. Your waste streams are then separated into hazadous and extremely hazardcn~~ wastes. Ex- emptedwasfestreams;rreremovedfnnn~nsideration.You then evaluate the remaining waste streams that contribute five percent or more, by volume or weight, to the total of hazardous or extremely hazardous waste routinely generated per year. Therefore, not all waste streams need to be evaluated.

Concentrates on some reduction alternatives for the major waste streams at a facility. If no source reduction alternatives are availawe, recycling or treatment are viable alternatives.

Item

Reporring

Legal Requirements

Table 11-1 Comparison of This Guidebook and SB 14 Sheet 2of 2

This Guidebook

Ha. no requirements for report pparation. How you document your successes and failures is up to you. Completed tables and checklists as well as a written implementation plan can m e as your documentation. However, well documented and publicized successes win points with the public.

Is not the result of federal or state regulation (even though it will help you to meet SB 14 requirements). You are using this guide because you are aware of, and understand the importance of, waste minimization, and you want to do all youcantominimizethehazardouswastesgeneratedbyyour department and city.

SB 14

Requires the preparation of two documents. The f m t document contains your selection of major wastes streams: describes the processes at your facility, the soutce reduction evaluations, and the selected altemative(s): and provides a schedule for implementation. "his document is referred to as the Source Reduction Evaluation Review and Plan. The second document contains current hamdous matezials/hazardous waste management procedures, concentrating on what steps, other than those just selected, you are taking to minimize wastes at your facility. This document is called the Hazardous Waste Management Perfmance Report. Each is updated every 4years. Both document. require summaries up front.

Hasaninitialregulatorydeadlineof September 1,1991.The two documents must be updated every 4years. If you are required to comply with SB 14 (see Applicability above or Section 11.2 blow), you should prepare the two required documentsby September 1,1991 andevery2yearsthed- ter. SB 14 carries a potential S 1,oOO per day fine for failure to implement the plan according to the stated schedule. However, SB 14 is flexible in allowing the amendment of the plan (schedule).

- Chapter 12 -

CONCLUSIONS

Chapter 12

lhis Guidebook has ScNcd to introduce you to the conceptsofsourccreducrionandhazardouswastcmini- -on. and has discussed how these conccpls may relate to the options in your city or depanmart. In addition,thisGuidebookhaspresentedtoyouasix-stcp process for establishing an intadepanmental hazardous waste reduction program in your city. An example of implementing ahambus waste reductionpm~

‘ispnsenudinAppcndixD.

With this infomation in hand, your dcparrmcnt and your city can forge ah& D develop a hazardous waste reduction program that is tailored to your operational and management stylc. This p r o p will surtly im- p” your works safety, dcnease your long-term liability costs, improve the environment, and SAVE YOU MONEY! h ’ t these good rc8so11s to bcgin your program TODAY?

75

1

s i

i

3

Appendix A LIST OF DEFINITIONS

,

Appendix A

List of Definitions

Chlorinated Solvent Hazardous Waste Minimization

A liquid compound or mixture of compounds capable of dissolving or dispersing one or more other substances whichcontainschlorineasoneof itsconstituents. Some examples are 1,l ,I-trichloroethane (TCA), tetnxhloroethylene (perchloroethylene, PCE), aichle methylene (TCE), freons, 1,1,2-trichloroethane, methylene chloride, chlorobenzene.

Empty Container

A container that previously held a hazardous material or hazardous waste is considered empty when all m a t e rial or waste that can be removed using typical methods for that container (i.e., pouring, pumping, or aspirating) has beenremoved,and holdsnomore than the following amounts of residue:

Hazardous waste minimization refers to any method used toreduce theamount of hazardous wastes that need to be disposed. Source reduction is considered a part of waste minimization.

Hazardous Waste Reduction Alternative

Options which can be used to redue the quantity of hazardous waste generated, or lessen the properties which make the waste hazardous. These include housekeeping or inventory controls, substitution of a nonhazardous material, substitution of a less hazardous material, onsite or offsite recycling, and process elimination.

Hazardous Waste Stream

No more than 2.5 centimeters (1 inch) on the bottom

. No more than the following quantity based on the

The total quantity of similar hazardous wastes generated by one or more processes at a facility (i.e., waste oils, chlorinated solvents, oily rags, etc.)

volume of the container: Housekeeping - 3 percent by weight if the container volume is less

thanoreq~tollOgallOns

gmter than 110 gallons

The way that hazardous materials are handled, used. or Stored.

Input Change - 0.3 percent by weight if the container volume is

Environmental Protection Agency (EPA) Identification Number

A raw material or feedstock change thatreduces, avoids, or eliminates the hazardous materials that enter the production process and thus reduces the amount of hazardous wastes generated by that process. The number assigned by the Califomia EPA or the U.S.

EPA to each generator, transporter or rreatment, storage, or disposal facility. In California, all generators, regardless of quantity, must apply and obtain an EPA Identifcation Number before they can generate any hazardous waste.

Inventory Control

Management of ordering, purchasing, and allocation procedures for hazardous materials.

Generator Nonchlorinated Solvent

Any person or facility whose act or process produces a waste that is considered hazardous under Federal or State of Califomia regulations.

A liquid compound or mixture of compounds capable of dissolving or dispersing one or more other substances which does not contain chlorine as one of its constituents. Some examples are benzene, toluene, xylene, PD-

butyl alcohol, methyl ethyl ketone (MEK), cyclohexanone, isoburanol.

____

Hazwdous Waste Assessment 680, Stoddard solvent, terpenes, methanol, acetone, -

An evaluation of a department or facility to detemine what types of hazardous materials you use, hazardous wastespruduced,whatprocessesgeneratedthesewastes, and how the wastes are managed and disposed of.

A- 1

Operational Improvements

Refmements made to the procedures used to perform a taskortasksthatreduwhequantityofhazardouswaste gcncratcd f” the activity. Examples include loss prevention, waste sepgation, production scheduling, maintenance operations, and overall site management.

Production Process Change

A h g e in the operating paramcused to perfmu a proccss. Changes include equipment modirications: changes in process operating conditions such as tem- peratm, pnssun, e&.: process or plant automation: or the return of materials or their components for reuse within existing processes.

Product Refonnulation

A change in the raw materials used to make a product or thc composition or specification of the final product.

Recycling

processing a hazarQus waste so that it can be re- claimedorreused as araw material.

Source Redudon

Source reduction means any action which causes a net reduction in the genaation of a havvdous waste by red~ingtheamountofrawmaterialusedintheproccss or any action taken before a hazardous waste is gena- ated that results in the lessening of the propaties which cause it to be classified as a hazardous waste.

Waste Reduction Number

A number which is used toorganizeand track hazardous waste sueam information. This number identifies each waste sueam according to location of generation andwastttype.

A-2

Appendix B LIST OF HAZARDOUS CHEMICALS

Table B-la Listing of Hazardous Chemicals Page 1 of 11

1 Acetaldehyde 2 Acetic Acid 3 Acetone, Propanone 4 *Acetone cyanohydrin 5 Acetonitrile 6 2-Acetylaminofluorene 7 Acetyl benzoyl peroxide 8 *Acetyl chloride 9 Acetyl peroxide 10 Acridine 11 *Acrolein, Aqualin 12 *Acrylonitrile 13 *Adiponitrile 14 'Aldrin; 1,2,3,4,10,1 O-Hexachloro-

1,4,4a,5,8,8a-hexahydro- 1,4,5,8-endo-exodimethanonaphthalene

15 *Alkyl aluminum chloride 16 *Alkyl aluminum compounds 17 Allyl alcohol, 2-Propensl -ol 18 Allyl bromide, 3-Bromopropene 19 Allyl chloride, 3-Chloropropene 20 Allyl zhlorocarbonate, Allyl chloroformate 21 *Allyl trichlorosilane 22 Aluminum (powder) 23A Aluminum chloride 238 *Aluminum chloride (anhydrous) 24 25 26 27 28 29 30 31 32

33 34 35 36 37 38 39 40 41 42

Aluminum fluoride Aluminum nitrate *Aluminum phosphide, PHOSTOXIN *4-AminodiphenylI 4-ADP *2-Aminopyridine *Ammonium arsenate *Ammonium bifluoride Ammonium chromate Ammonium dichromate, Ammonium

Ammonium fluoride Ammonium hydroxide Ammonium molybdate Ammonium nitrate Ammonium perchlorate Ammonium permanganate Ammonium persulfate Ammonium picrate Ammonium sulfide n-Amyl acetate, 1 -Acetoxypentane (and

bichromate

43

44

45 46

47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75

76 n 78 79 80 81 82

isomers)

isomers)

isomers)

isomers)

nAmylamine, 1 -Aminopentane (and

n-Amyl chloride, 1 -Chloropentane (and

n-Amylene, 1 -Pentene (and isomers) nAmyl mercaptan, 1 -Pentanethiol (and

n-Amyl nitriie, nPentyl nitrite (and isomers) *Amyl trichlorosilane (and isomers) Aniline, Aminobenzene Anisoyl chloride Anthracene Antimony Antimony compounds *Antimony pentachloride *Antimony pentafluoride Antimony pentasulfide Antimony potassium tartrate Antimony sulfate, Antimony trisulfate Antimony trichloride, Antimony chloride Antimony trifluoride, Antimony fluoride Antimony trioxide, Antimony oxide Antimony trisulfide, Antimony sulfide *Arsenic *Arsenic acid and salts +Arsenic compounds *Arsenic pentaselenide *Arsenic pentoxide, Arsenic oxide *Arsenic sulfide, Arsenic disulfide *Arsenic tribromide, Arsenic bromide *Arsenic trichloride, Arsenic chloride *Arsenic triiodide, Arsenic iodide *Arsenic trioxide, Arsenic oxide *Arsenious acid and salts *Arsines Asbestos (including chrysotile, amosite,

crocidolite, tremolite, anthophyllite, and act inolie)

*AZODRIN, 3-Hydroxy-N-ciscrotonamide Barium Barium azide Barium Bromide Barium carbonate Barium chlorate Barium chloride

B- 1

83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 1 00 101 102

103 104 1 05 1 06 1 07 1 08 1 09 110 111

112 113 114 115 116 117 118 119 1 20

121

122

Table 6-1 Listing of Hazardous Chemicals Page2of 11

Barium chromate Ceresan liquid Barium citrate 124 Bismuth chromate Barium compounds (soluble) *Barium cyanide dimethylphosphate Barium fluoride 126 *Boranes Barium fluosilicate 127 *Bordeaux arsenites Barium hydroxide Barium iodide 129 *Boron trifluoride Barium manganate 130 Bromic acid Barium nitrate 131 *Bromine Barium oxide, Barium monoxide Barium perchlorate 133 *Bromine trifluoride Barium permanganate 134 *Brucine, Dimethoxystrychnine Barium peroxide 135 1,2,4-Butanetriol trinitrate Barium phosphate 136 n-Butyl acetate, 1 -Acetoxybutane (and Barium stearate isomers) Barium sulfide 137 n-Butyl alcohol, 1-Butanol (and isomers) Barium sulfiie 138 nSutyl amine, 1 Aminobutane (and Benzene isomers)

*Benzene hexachloride, BHC; 1,2,3,4,5,6- 139 n-Butyl formate (and isomers) Hexachlorocyclohexane 140 ten-Butyl hydroperoxide (and isomers)

*Benzenephosphorous dichloride 141 *n-Butyllihium (and isomers) Benzene sulfonic acid 142 nButyl mercaptan, 1 -6utanethiol (and

*Benzidine and sat& isomers) *Benzotrifluoride, Trifluoromethylbenzene 143 ten-Butyl peroxyacetate, ten-Butyl *Benzoyl chloride peracetate Benzoyl peroxide, Dibenzoyl peroxide 144 ten-Butyl peroxybenzoate, tert-Butyl Benzyl bromide, alpha-bromotoluene perbenzoate Benzyl chloride, alpha-chlorotoluene 145 tert-Butyl peroxypivalate

*Benzyl chlorocarbonate, Benzyl . . , 146 *n-Butyltrichlorosilane chloroformate 147 para-tea-Butyl toluene

*Beryllium 148 n-Butyraldehyde, n-Butanal (and isomers) *Beryllium chloride *Beryllium compounds 150 *Cadmium (powder) *Beryllium copper 151 Cadmium chloride *Beryllium fluoride 152 *Cadmium compounds *Beryllium hydride 153 *Cadmium cyanide *Beryllium hydroxide 154 Cadmium fluoride *Beryllium oxide 155 Cadmium nitrate *BIDRIB, Dicrotophos, 3-(Dimethylamino)-l- 156 Cadmium oxide

methyl-3-oxo-1 -propenyldimethy I 157 Cadmium phosphate phosphate 158 Cadmium sulfate

* bis(Chloromethyl)ether, 159 *Calcium Dichloromethylether, BCME

Bismuth 161 *Calcium arsenite *hisfMethvlmercuriclsulfate. CERNVET. 162 *Calcium carbide

125 *BOMYL, Dimethyl 3-hydroxyglutaconate

128 *Boron trichloride, Trichloroborane

132 *Bromine pentafluoride

149 *Cacodylic acid, Dimethylarsinic acid

160 *Calcium arsenate, PENSAL

123 ,-- ~ ~ -

8-2

Table B-1 Usting of Hazardous Chemicals Page 3 of 11

163 164 165 166 1 67 168

169 170 171 172 1 73 1 74 1 75 1 76 177

178 179 1 80

181

1 82

183

184 185 1 86 187 188 189

190 191 1 92

Calcium chlorate Calcium chlorite Calcium fluoride

*Calcium hydride Calcium hydroxide, Hydrated lime

*Calcium hypochlorite, Calcium oxychloride (dry)

Calcium molybdate Calclum nitrate, Lime nitrate, Nitrocalcite Calcium oxide, Ume Calcium permanganate. Calcium peroxide, Calcium dioxide

*Calcium phosphide Calcium resinate Caprylyl peroxide, Octyl peroxide

*Carbanolate, BANOL, 2-Chloro4,5- dimethylphenyl methylcarbamate

Carbon disulfide, Carbon bisulfide Carbon tetrachloride, Tetrachloromethane *Carbophenothion, TFIITHION, S[ [(4-

Chlorophenyl)thio]methyl]O, 0-diethyl phosphorodithioate

Chloral hydrate, Trichloroacetaldehyde (hydrated)

*Chlordan: 1 ,2,4,5,6,7,8,8-0ctachloro4,7- methano3a,4,7,7a-tetrahydro-indane

*Chlorfenvinphos, Compound 4072,2- Chloro-I -(2,4-dichlorophenyl)vinyldiethyl phosphate

*Chlorine *Chlorine dioxide *Chlorine pentafluoride *Chlorine trifluoride *C hloroacetaldehyde *alpha-Chloroacetophenone, Phenyl

chloromethyl ketone *Chloroacetyl chloride Chlorobenzene para-Chlorobenzoyl peroxide

198 Chromic acid, Chromium trioxide, Chromic

199 Chromic chloride, Chromium trichloride 200 Chromic fluoride, Chromium trifluoride 201 Chromic hydroxide, Chromium hydroxide 202 Chromic oxide, Chromium oxide 203 Chromic sulfate, Chromium sulfate 204 Chromium compounds 205 *Chromyl chloride, Chlorochromic

anhydride 206 Coban (powder) 207 Cobalt compounds 208 Cobaltous bromide, Cobalt bromide 209 Cobaltous chloride, Cobalt chloride 210 Cobaltous nitrate, Cobalt nitrate 21 1 Cobaltous resinate, Cobalt resinate 212 Cobaltous sulfate, Cobalt sulfate 213 Cocculus, Fishberry, Picrotoxin 21 5 *Copper acetoarsenite, Paris green 21 6 Copper acetylide 217 *Copper arsenate, Cupric arsenate 218 *Copper arsenite, Cupric arsenite 219 Copper chloride, Cupric chloride 220 Copper chlorotetrazole 221 Copper compounds 222 *Copper cyanide 223 Copper nitrate, Cupric nitrate 224 Copper sulfate, Cupric sulfate, Blue vitriol 225 *Coroxon: ortho,ortho-Diethylortho-(%

chloro-4-methylcoumarin-7-yl phosphate 226 *Coumafuryl, FUMARIN, 3-[1-(2-Furanyi)-3-

oxobutyl)l4hydroxy-2H-l -benzopyran-2- one

227 *Coumatetralyl, BAYER 25634, RACUMIN 57,4-Hydroxy-3-(1,2,3,4-tetrahydro-I - naphthalenyl)-2H-l -benzopyran-2-one

228 *Crimidine, CASTRIX, 2-Chlor0-4-

229 *Crotonaldehyde, 2-Butenal

anhydride

1 93 *ortho-Chlorobenzylidene malonitrile, OCMB 230 Cumene, Isopropyl benzene 194 Chloroform 231 Cumene hydroperoxide: alpha, alpha- 195 *Chloropicrin, Chlorpicrin, Dimethylbenzyl hydroperoxide

Trichloronitromethane 232 Cupriethylene diamine 196 *Chlorosulfonic acid 197 Chlorosrtho-toluidine, 2-Amino-4- 234 Cyanoacetic acid, Malonic nitrile

chlorotoluene 235 *Cyanogen

233 *Cyanide salts

6-3

Table B-1 Listing of Hazardous Chemicals Page4of 11

236 Cyanogen bromide, Bromine cyanide 237 Cyanuric triazide 238 Cycloheptane 239 Cyclohexane 240 Cyclohexanone peroxide 241 *Cyclohexenyltrichlorosilane 242 *Cycloheximide, ACTlDlONE 243 *Cyclohexyltrichlorosilane 244 Cyclopentane 245 Cyclopentanol 246 Cyclopentene 247 DDT; 1,l , 1 -Trichloro-2,2-

bis(ch1orophenyl)ethane 248 *DDVP, Dichlorvos, VAPONA, Dimethyl

dichlorovinyl phosphate 249 *Decaborane 250 DECAUN, Decahydronaphthalene 251 *Demeton, SYSTOX 252 *DemetonS-methyl sulfone,

(ethylsulfonyl)ethyl]O,Odimethyl phosphorothioate

253 Diazodinitrophenol, DDNP, 2-Diazo4,6- dinitrobenzene-1 -oxide

254 *Diborane, Diboron hexahydride 255 *1 ,2-Dibromo3-chloropropanel DBCP,

256 nDibuty1 ether, Butyl ether (and isomers) 257 Dichlorobenzene (ortho, meta, para) 258 *3,3-Dichlorobenzidine and salts, DCB 259 1,2-Dichloroethylene; 1,9-Dichloroethene 260 Dichloroethyl ether, Dichloroether 261 Dichloroisocyanuric acid, Dichloro-S-

262 Dichloromethane, Methylene chloride 263 *2,4-Dichlorophenoxyacetic acid: 2,4-D 264 1 ,2-Dichloropropane, Propylene dichloride 265 1,3-DichIoropropylene; 1,3-DichIoropropene 266 Dicumyl peroxide 267 *Dieldrin; 1,2,3,4,10,1O-Hexachloro-6,7-

epoxy-i ,4,4a,5,6,7,8,8a-octahydro-l,4- endo, exo-5.8-dimet hanonaphthalene

268 *Diethylaluminum chloride, Aluminum diethyl monochloride, DEAC

269 Diethylamine 270 *Diethyl chlorovinyl phosphate, Compound

METAISOSYSTOXSULFON, S-(2-

FUMAZONE, NEMAGON

triazine-2,4,6-trione

1836 271 *Diethyldichlorosilane 272 Diethylene glycol dinitrate 273 Diethylene triamine 274 *O,O-Diethyla-(isopropylthiomethyl)

275 *Diethylzinc, Zinc ethyl 276 *Difluorophosphoric acid 277 *Diglycidyl ether, bi~(2~3-Epoxypropyl)ether 278 Diisopropylbenzene hydroperoxide 279 Diisopropyl peroxydicarbonate, Isopropyl

percarbonate 280 *Dimefox, HANANE, PENTOX 14,

Tetramethylphosphoro-diamidic fluoride 281 Dimethylamine, DMA 282 *Dimethylaminoazobenzene, Methyl yellow 283 *Dimethyldichlorosilane,

Dichlorodimethylsilane 284 2,5-Dimethylhexane-2,5-Dihydroperoxide 285 *1,1 -Dimethylhydrazine, UDMH 286 *Dimethyl sulfate, Methyl sulfate 287 *Dimethyl sulfide, Methyl sulfide 288 2,4Dinitroaniline 289 *Dinitribenzene (ortho, meta, para) 290 Dinitrochlorobenzene, 1 -Chloro-2,4-

291 *4,6-Dinitro-ortho-cresol, DNPC, SINOX,

292 *Dinitrophenol (2,3-; 2,4-; 2,6- isomers) 293- 2&Dinitrophenylhydr&ine 294 Dinitrotoluene (2,4-; 3,4-; 35- isomers) 295 'DINOSEB; 2,4-Dinitro-6-sec-b~Q4phenol 296 1 ,&Dioxane; lI4-Diethylene dioxide 297 *Dioxathion, DELNAV; S,S-lI4-dioxane-2,3-

diyl-bis(0,O-diethyl phosphorodithioate) 298 Dipentaerythritol hexanitrate 299 *Diphenyl, Biphenyl, Phenylbenzene 300 Diphenylamine, DPA, N-Phenylaniline 301 *Diphenylamine chloroarsine, Phenarsazine

302 *Diphenyldichlorosilane 303 Dipicrylamine, Hexanitrodiphenyl amine 304 Dipropyl ether 305 *Disulfoton, DISYSTON; 0,O-Diethyl S-[2-

306 *Dodecyltrichlorosilane

phosphorodithioate

dinitrobenzene

EGETOL 30

chloride

(ethylthio)ethyl) phosphorodithioate

Table B-1 Usting of Hazardous Chemicals Page 5 of 11

307 *DOWCO-139, ZECTRAN, Mexacarbate, 4- (Dimethylamino)-3,5-dimethylphenyl methylcarbamate

309 'DYFONATE, Fonofos, 0-Ethyl*- phenylethyl phosphonodithioate

31 0 *Endosulfan, THIODAN; 6,7,8,9,10,10- Hexachloro-l,5,5a,6,9,9a-hexahydro-6,9- methano-2,4,3-bento-dioxatpin-3-oxide

31 1 'Endothal, 7-0xabicyclo[2.2.1] heptane-2,3- dicarboxylic acid

312 *Endothion, EXOTHION, S-[(S-Methoxy-4- oxo4H-pyran-2-yl)-methyl]O,O-dimethyl phosphorothioate

epoxy-l,4,4,4a,5,6,7,8,8a-octahydro-l,4- endo-endo-5,8-dimethanonaphthalene

31 4 Epichlorohydrin, Chloropropylene oxide ,. 315 *EPN; 0-Ethyl 0-para-nitrophenyl

phenylphosphonothioate 31 6 *Ethion, NIALATE; O,O,O',O'-TetraethylS,S-

methylenediphos-phorodithioate 317 Ethyl acetate 318 Ethyl alcohol, Ethanol 31 9 Ethylamine, Aminoethane 320 Ethylbenzene, Phenylethane 321 Ethyl butyrate, Ethyl butanoate 322 Ethyl chloride, Chloroethane 323 *Ethyl chloroformate, Ethyl chlorocarbonate 324 *Ethyldichloroarsine, Dichloroethylarsine 325 *Ethyldichlorosilane 326 *Ethylene cyanohydrin, beta-

Hydroxypropionitrile 327 Ethylene diamine 328 Ethylene dibromide; 1 ,a-Dibromoethane 329 Ethylene dichloride; 1,2-DichIoroethane 330 *Ethyleneimine; Aziridine, El 331 Ethylene oxide, Epoxyethane 332 Ethyl ether, Diethyl ether 333 Ethyl formate 334 *Ethyl mercaptan, Ethanethiol 335 Ethyl nitrate 336 Ethyl nitrite 337 *Ethylphenyldichlorosilane 338 Ethyl propionate 339 *Ethyltrichlorosilane 340 *Fensulfothion, BAYER 251 41 , DASANIT,

31 3 *Endrin; 1,2,3,4,10,1 O-Hexachloro-6,7-

O,O,-Diethyl-O-[4-(methylsulfinyl)phenyl] phosphorothioate

341 *Ferric arsenate 342 Ferric chloride, Iron (111) chloride 343 *Ferrous arsenate, Iron arsenate 344 *Fluoboric acid, Fluoroboric acid 345 Fluoride salts 346 *Fluorine 347 *Fluoroacetanilide, AFL 1082 348 *Fluoroacetic acid and salts, Compound

349 *Fluorosulfonic acid, Fluosulfonic acid 350 Formaldehyde, Methanal 351 Formic acid, Methanoic acid 352 Fulminate of mercury, Mercuric cyanate 353 *FURADAN, NIA 10,242, Carbofuran; 2,3-

Dihydro-2,2-dimethyl-7-benzofuranyl- methylcarbamate

1 080

354 Furan, Furfuran 355 Gasoline 356 *OB, 0-Isopropyl methyl phosphoryl

fluoride 357 Glutaraldehyde 358 Glycerolmonolactate trinitrate 359 Glycol dinitrate, Ethylene glycol dinitrate 360 Gold fulminate, Gold cyanate 361 Guanidine nitrate 362 Guanyl nitrosaminoguanylidene hydrazine 363 *Guthion; O,O-DimethylS4-oxo-l ,2,3-

benzotriazin3(4H)-ylmethyl phosphorodithioate

364 Hafnium 365 *Heptachlor; i ,4,5,6,7,8,8-Heptachloro-

3a,4,7,7a-tetrahydro4,7-methanoindene 366 n-Heptane (and isomers) 367 1-Heptene (and isomers) 368 *Hexadecyltrichlorosilane 369 Hexaethyl tetraphosphate, HETP 370 Hexafluorophosphoric acid 371 Hexamethylenediamine; 1,6-Diaminohexane 372 n-Hexane (and isomers) 373 1-Hexene (and isomers) 374 n-Hexylamine, 1 -Aminohexane (and

375 *Hexyltrichlorosilane 376 *Hydrazine, Diamine

isomers)

B-5

Table B-1 Listing of Hazardous Chemicals Page 6 of 11

377 Hydrazine azide 41 9 *Lewisite, beta-Chlorovinyldichloroarsine 378 Hydrazoic acid, Hydrogen azide 420 *Lithium 379 *Hydriodic acid, Hydrogen iodide 421 *Lithium aluminum hydride, LAH 380 *Hydrobromic acid, Hydrogen bromide 381 *Hydrochloric acid, Hydrogen chloride, 423 *Lithium ferrosilicon

Muriatic acid 424 *Lithium hydride 382 *Hydrocyanic acid, Hydrogen cyanide 383 *Hydrofluoric acid, Hydrogen fluoride 426 Lithium peroxide 384 Hydrofluosilicic acid, Fluosilicic acid 427 Lithium silicon 385 Hydrogen peroxide 428 *London purple, Mixture of arsenic trioxide, 386 *Hydrogen selenide 387 *Hydrogen sulfide 429 *Magnesium 388 *Hypochlorite compounds 430 *Magnesium arsenate 389 Indium 431 *Magnesium arsenite 390 Indium compounds 432 Magnesium chlorate 391 Iodine monochloride 433 Magnesium nitrate 392 Isooctane; 2,2,4-Trimethylpentane 434 Magnesium perchlorate 393 lsooctene (mixture of isomers) 435 Magnesium peroxide, Magnesium dioxide 394 Isopentane, 2-Methylbutane 436 *Maleic anhydride 395 Isoprene, P-Methyl-l,3-butadiene 437 Manganese (powder) 396 Isopropanol, Isopropyl alcohol, 438 Manganese acetate

2-Propanol 439 *Manganese arsenate, Manganous 397 Isopropyl acetate arsenate 399 Isopropylamine, 2Aminopropane 440 Manganese bromide, Manganous bromide 400 Isopropyl chloride, 2-Chloropropane 441 Manganese chloride, Manganous chloride 401 Isopropyl ether, Diisopropyl ether 442 Manganese methylcyclopentadienyl

404 *meta-Isopropylpheny I-N-methy Icarbamate, 443 Manganese nitrate, Manganous nitrate Ac 5,727 444 Mannitol hexanitrate, Nitromannite

octahydro-l,2,4-metheno-2H-cyclobuta- carbonyl N-methyl carbamoyl-methyl) (cd)pentalen-2-one, Chlorecone phosphorodiihioate

422 *Lithium amide

425 *Lithium hypochlorite

aniline, lime, and ferrous oxide

402 Isopropyl mercaptan, PPropanethiol tricarbonyi

405A*Kepone;l,l a,3,3a4,5,5a,5b,6-Decachloro- 445 *MECARBAM; 0,O-Diethyl S-(N9thOxy-

4058 Lauroyl peroxide, Di-ndodecyl peroxide 406 Lead compounds 4,6dinitrophenyI acetate 407 Lead acetate 447 para-Menthane hydroperoxide, Para- 408 *Lead arsenate, Lead orthoarsenate menthane hydroperoxide 409 *Lead arsenite 448 Mercuric acetate, Mercury acetate 410 Lead azide 449 Mercuric ammonium chloride, Mercury 411 Lead carbonate ammonium chloride 412 Lead chlorite 450 Mercuric benzoate, Mercury benzoate 413 *Lead cyanide 451 Mercuric bromide, Mercury bromide 41 4 Lead 2,edinitroresorcinate 452 *Mercuric chloride, Mercury chloride 41 5 Lead mononitroresorcinate 453 *Mercuric cyanide, Mercury cyanide 416 Lead nitrate 454 Mercuric iodide, Mercury iodide 417 Lead oxide 455 Mercuric nitrate, Mercury nitrate 41 8 Lead styphnate, Lead trinitroresorcinate 456 Mercuric oleate, Mercury oleate

446 *Medinoterb acetate, 2-tert-Butyl-5-methyI-

6-6


457 Mercuric oxide (red and yellow) 496 *Methyldichlorosilane 458 Mercuric oxycyanide 497 *4,4-Methylene bis(2chloroaniline), MOCA 459 Mercuric-potassium iodide, Mayer's 498 Methyl ethyl ether

reagent 499 Methyl ethyl ketone, 2-Butanone 460 Mercuric salicylate, Salicylated mercury 500 Methyl ethyl ketone peroxide 461 Mercuric subsulfate, Mercuric dioxysulfate 501 Methyl formate 462 Mercuric sulfate, Mercury sulfate 502 *Methyl hydrazine, Monomethyl hydrazine, 463 Mercuric thiocyanide, Mercury thiocyanate MMH 464 Mercurol, Mercury nucleate 503 *Methyl isocyanate 465 Mercurous bromide 504 Methyl isopropenyl ketone, 3-Methyl& 466 Mercurous gluconate butene-2-one 467 Mercurous iodide 505 *Methylmagnesium bromide 468 Mercurous nitrate 506 *Methylmagnesium chloride 469 Mercurous oxide 507 *Methylmagnesium iodide 470 Mercurous sulfate, Mercury bisulfate 508 Methyl mercaptan, Methanethiol 472 *Mercury 509 Methyl methacrylate (monomer) 473 *Mercury compounds 474 Metal carbonyls nitrophenylphosphorothioate 475 *Metal hydrides 51 1 Methyl propionate 476 Metal powders 51 2 *Methyltrichlorosilane 477A*Methomyl, LANNATE, S-Methyl-N-((methyl- 513 Methyl valerate, Methyl pentanoate (and

carbamoyl) oxy) thioacet imidate isomers) 4778 *Methoxychlor, 1,1,1 -Trichloro-2,2-bis(p- 514 Methyl vinyl ketone, 3-Butene-2-one

51 0 *Methyl parathion; 0,O-Dimethyl-O-para-

478

479 480

481 482 483 484 485 486 487 488 489 490 491 492

493 494 495

methoxyphenyl)ethane, CHEMFLORM, MARIATE

*Methoxyethylmercuric chloride, AGALLOL, ARETAN

Methyl acetate Methyl acetone (Mixture of acetone, methyl

acetate, and methyl alcohol) Methyl alcohol, methanol

*Methylaluminum sesquibromide *Methylaluminum sesquichloride Methylamine, Aminomethane N-Methylaniline *Methyl bromide, Bromomethane 2-Methyl-1 -butene 3-Methyl-1 -butene Methyl butyl ether (and isomers) Methyl butyrate (and isomers) Methyl chloride, Chloromethane *Methyl chloroformate, Methyl chloro-

*Methyl chloromethyl ether, CMME Methylcyclohexane

*Methyldichloroarsine

carbonate

8-7

51 5A *Mevinph&, PHOSDRIN, P-Carbomethoxy- 1 -methylvinyl dimethyl phosphate

51 58 *Mirex; 1,l ~22,3,3a,4,5,5,Sal5b,6 Dodecachlorooctahydro-l,3&metheno- 1 H-cyclobuta(cd) pentalene, Dechlorane

51 6 *MOCAP, O-EthylS,S-dipropyl Phosphorodithioate

517 Molybdenum (powder) 51 8 Molybdenum trioxide, Molybdenum

519 Molybdic acid and salts 520 Monochloroacetic acid, Chloracetic acid,

MCA 521 Monochloroacetone, Chloroacetone, 1 -

Chloro-2-propanone 522 Monofluorophosphoric acid 523 Naphtha (of petroleum or coal tar origin),

Petroleum ether, Petroleum naphtha 524 Naphthalene 525 *alpha-Naphthylamine, 1 -NA 526 *beta-Naphthylamine, 2-NA 527 "hexane, 2,2-Dimethylbutane 528 Nickel (powder)

anhydride

Table 6-1 Listing of Hazardous Chemicals Page 8 of 11

529 Nickel acetate 530 Nickel antimonide 531 *Nickel arsenate, Nicke.ms arsenate 532 *Nickel carbonyl, Nickel tetracarbonyl 533 Nickel chloride, Nickelous chloride 534 *Nickel cyanide 535 Nickel nitrate, Nickelous nitrate 536 Nickel selenide 537 Nickel sulfate 538 Nicotine, beta-pyridyl-alpha-N-methyl

539 Nicotine salts 540 Nltrlc acid 541 Nitroaniline, Nitraniline (ortho, meta, para) 542 *Nitrobemoll Nitrobenzene 543 *4-Nitrobiphenyl1 4-NBP 544 Nitro carbo nitrate 545 Nitrocellulose, Cellulose nitrate, Guncotton,

pyrrolidine

Pyroxylin, Collodion, pyroxylin (nitrocellulose) in ether and alcohol

546 Nitrochlorobenzene, Chlomitrobenzene (ortho, meta, para)

547 Nitrogen mustard 548 Nitrogen tetroxide, Nitrogen dioxide 549 Nitroglycerin, Trinitroglycerin 550 Nitrohydrochloric acid, Aqua regia 551 *Nitrophenol (ortho, meta, para) 552 *N-Nitrosodimethylamine, Dimethyl

553 Nitrosoguanidine 554 Nitrostarch, Starch nitrate 555 Nitroxylol, Nitroxylene, Dimethyl-

556 1 -Nonene, 1 -Nonylene (and isomers) 557 *Nonyltrichlorosilane 558 *Octadecyltrichlorosilane 559 n-Octane (and isomers) 560 1 -Octene, 1 -Caprylene 561 *Octyltrichlorosilane 563 *Oleum, Fuming sulfuric acid 565 Osmium compounds 566 Oxalic acid 567 *Oxygen difluoride 568 *Para-oxon, MINTACOL; 0,O-Diethyl-O-

569 *Parathion; 0,O-Diethyl-O-para-nitrophenyl

nitrosoamine

nitrobenzene (2,4-; 3,4-;, 2,s- isomers)

para-nitrophenylphosphate

phosphorothioate 570A *Pentaborane 5708 Pentachlorophena , PCP, DOWlClDE 7 571 Pentaerythrite tetranitrate, Pentaerythritol

572 nPentane (and isomers) 573 a-pentanone, Methyl propyl ketone (and

isomers) 574 Peracetic acid, Peroxyacetic acid 575 Perchloric acid 576 Perchloroethylene, Tetrachloroethylene 577 *Perchloromethyl mercaptan, Trichloro-

578 Perchloryl fluoride 580 Phenol, Carbolic acid 581 *Phenyldichloroarsine 582 *Phenylenediamine, Diaminobenzene

(ortho, meta, para) 583 Phenylhydrazine hydrochloride 584 *Phenylphenol, Orthozenol, DOWlClDE 1 585 *Phenyltrichlorosilane 586 *Phorate, THIMET; 0,O-Diethyla-[(Ethyl-

thio)methyl] phosphorodthioate 587 *Phosfolan, CYOLAN, 2-(Diethoxy-

phosphiny1imino)-1 ,Sdthiolane 588 *Phosgene, Carbonyl chloride 589 *Phosphamidon, DIMECRON, 2-Chloro-2-

diethylcarbamoyl-1 -methylvinyl dimethyl phosphate

590 *Phosphine, Hydrogen phosphide 591 Phosphoric acid 592 Phosphoric anhydride, Phosphorus

pentoxide 593 Phosphorus (amorphous, red) 594 *Phosphorus (red or yellow) 595 *Phosphorus oxybromide, Phosphoryl

596 *Phosphorus oxychloride, Phosphoryl

597 *Phosphorus pentachloride, Phosphoric

598 *Phosphorus pentasulfide, Phosphoric

599 *Phosphorus sesquisulfide, Tetra-

600 'Phosphorus tribromide

tetranitrate

methylsulfenyl chloride

bromide

chloride

chloride ___

sulfide

phosphorus trisulfide ~

8-8

Table 8-1 Listing of Hazardous Chemicals Page 9 of 11

601 *Phosphorus trichloride 602 Picramide, Trinitroaniline 603 Picric acid, Trinitriphenol 604 Picryl chloride, 2-Chloro-lI3,5-trinitro-

605 *Platinum compounds 606 *Polychlorinated biphenyls, PCB, Askarel,

AROCLOR, CHLORUCTOL, INERTEEN, PYRANOL

607 Polyvinyl nitrate 608 POTASAN: Ol0-DiethyLO-(4-methyl-

609 *Potassium 61 0 *Potassium arsenate 61 1 *Potassium arsenite 612 *Potassium bdluoride, Potassium acid

613 Potassium binoxalate, Potassium acid

61 4 Potassium bromate 615 *Potassium cyanide 61 6 Potassium dichloroisocyanurate 61 7 Potassium dichromate, Potassium

bichromate 619 Potassium fluoride 620 *Potassium hydride 621 Potassium hydroxide, Caustic potash 622 Potassium nitrate, Saltpeter 623 Potassium nitrite 624 Potassium oxalate 625 Potassium perchlorate 626 Potassium permanganate 627 Potassium peroxide 628 Potassium sulfide 629 *Propargyl bromide, 3-Bromo-1 -propyne 630 *beta-Propiolactone, BPL 631 Propionaldehyde, Propanal 632 Propionic acid, Propanoic acid 633 n-Propyl acetate 634 n-Propyl alcohol, 1 -Propanol 635 nPropylamine (and isomers) 636 *Propyleneimine, 2-Methylaziridine 637 Propylene oxide 638 nPropyl formate 639 nPropy1 mercaptan, 1 -Propanethi01 640 *n-Propyltrichlorosilane

benzene

umbelliferone) phosphorothioate

fluoride

oxalate

641 *Prothoate, FOSTION, FAC; 0,O-Diethyl-S-

642 Pyridine 643 *Pyrosuifuryl chloride, Disulfuryl chloride 644 *Quinone: lI4-Benzoquinone 645 Raney nickel 646 *Schradan, Octamethyl pyrophosphor-

amide, OMPA 647A *Selenium 6478 *Selenium compounds 648 *Selenium fluoride 649 *Selenous acid, Selenious acid and salts 650 *Silicon tetrachloride, Silicon chloride 651 *Silver acetylide 652 Silver azide 653 Sliver compounds 654 Silver nitrate 655 Silver styphnate, Silver trinitroresorcinate 656 Silver tetrazene 657 *Sodium 658 Sodium aluminate 659 *Sodium aluminum hydride 660 *Sodium amide, Sodamide 661 *Sodium arsenate 662 *Sodium arsenite 663 Sodium azide 664 *Sodium bfluoride, Sodium acid fluoride 665 Sodium bromate 666 *Sodium cacodylate, Sodium dimethyl

arsenate 667 Sodium carbonate peroxide 668 Sodium chlorate 669 Sodium chlorite 670 Sodium chromate 671 'Sodium cyanide 672 Sodium dichloroisocyanurate 673 Sodium dichromate, Sodium bichromate 674 Sodium fluoride 675 *Sodium hydride 676 Sodium hydrosulfite, Sodium hyposulfne 677 Sodium hydroxide, Caustic soda, Lye 678 *Sodium hypochlorite 679 *Sodium methylate, Sodium methoxide 680 Sodium molybdate 681 Sodium nitrate, Soda niter 682 Sodium nitrite

carboethoxyethyl phosphorodithioate

B-9

Table B-1 Listing of Hazardous Chemicals Page 1Oof 11

683 Sodium oxide, Sodium monoxide 684 Sodium perchlorate 685 Sodium permanganate 686 *Sodium peroxide 687 Sodium picramate 688 *Sodium potassium alloy, NaY Nack 689 *Sodium selenate 690 Sodium sulfide, Sodium hydrosulfide 691 Sodium thiocyanate, Sodium sulfocyanate 692 Stannic chloride, Tin tetrachloride 693 *Strontium arsenate 694 Strontium nitrate 695 Strontium peroxide, Strontium dioxide 696 *Strychnine and salts 697 Styrene, Vinylbenzene 698 Succinic acid peroxide 699 Sulfide salts (soluble) 700 *Sulfotepp, DITHIONE, BUDAFUM, Tetra-

ethyl dithiopyrophosphate, TEDP 701 *Sulfur chloride, Sulfur monochloride 702 *Sulfur mustard 703 *Sulfur pentachloride 704 Sulfur trioxide, Sulfuric anhydride 705 Sulfuric acid, Oil of vitriol, Battery acid 706 Sulfurous acid 707 *Sulfuryl chloride, Sulfonyl chloride 708 *Sulfuryl fluoride, Sulfonyl fluoride 709 *SUPRACIDE, ULTRACIDE, S-[(S-Methoxy-

2-0~0-1,3,4-thiadiazol-3(2H)-yl)methyl]- 0,O-dimethyl phosphorodthioate

71 0 *SURECIDE, Cyanophenphos, 0-para- Cyanophenyl-O-ethyl phenyl phosphono- thioate

71 1 *Tellurium hexafluoride 712 *TELODRIN, Isobenzan; 1,3,4,5,6,7,8,8-

Octachloro-1 ,3,3a,4,7,7a-hexahydro-4,7- methanoisobenzofuran

71 3 *TEMIK, Aldicarb, 2-Methyl-2(methybhio)- propionaldehyde-0-(methylcabamoy I)- oxime

714 *2,3,7,8-Tetrachlorodibenzo-para-dioxin, TCDD, Dioxin

71 5 sym-Tetrachloroethane 717 *Tetraethyl Lead, TEL (and other organic

71 8 *Tetraethyl pyrophosphate, TEPP lead)

71 9A Tetrahydrofuran, THF 71 9B Tetrahydrophthalic anhydride, Memtetra-

hydrophthalic anhydride 720 TETRAUN, Tetrahydronaphthalene 721 Tetramethyl lead, TML 722 *Tetramethyl succinonitrile 723 *Tetranitromethane 724 *Tetrasul, ANIMERT V-1 01 , S-para-Chloro-

phenyl-2,4,5-trichlorophenyl sulfide 725 Tetrazene, 4Amidino-1 -(nitrosamine-

amidino)-1 -tetrazene 726 *Thallium 727 *Thallium compounds 728 *Thallous sulfate, Thallium sulfate, RATOX 729 *Thiocarbonylchloride, Thiophosgene 730 *Thionazin, ZINOPHOS; ),)-Tetramethyl-

731 *Thionyl chloride, Sulfur oxychloride 732 *Thiophosphoryl chloride 733 ’ Thorium (powder) 734 Tin compounds (organic) 735 Titanium (powder) 736 Titanium sulfate 737 *Titanium tetrachloride, Titanic chloride 738 Toluene, Methylbenzene 739 *Toluene-2,4-diisocyanate, TDI 74OA Toluidine, Aminotoluene (ortho, meta,

7408 *Toxaphene, Polychlorocamphene 741 *TFtANID, exo-3-Chloro-endo-6qano-2-

743 1,l ,P-Trichloroethane 744 Trichloroethylene, Trlchloroetheno 745 Trichloroisocyanuric acid 746 *2,4,5-Trichlorophenoxyacetic acid 747 *Trichlorosilane, Silicochloroform 748 Trimethylamine, TMA 749 Trinitroanisole, 2,4,6-Trinitrophenyl methyl

750 1,3,5-Trinitrobenzene 751 2,4,6-Trinitrobenzoic acid 752 Trinitronaphthalene, Naphtite 753 2,4,6-Trinitroresorcinol, Styphnic acid 754 2,4,6-Trinitrotoluene, TNT 755 *tris(l -Aziridinyl)phosphine oxide, Tri-

thiuram monosulfide

Para)

norbomanone-)-(methylcarbamoy1)oxime

ether

ethylenephosphoramide, TEPA

B-10

756 757 758 759 760

761 762 763

764 765 766

767 768 769 770 771 772 773 774


Tungstic acid and salts Turpentlne Uranyl nitrate, Uranium nitrate Urea nitrate n-Valeraldehyde, nPentanal (and

isomers) Vanadic acid salts Vanadium oxytrichloride *Vanadium pentoxide, Vanadic acid

Vanadium tetrachloride Vanadium tetraoxide Vanadium trioxide, Vanadium

sesquioxide Vanadyl sulfate, Vanadium sulfate Vinyl acetate *Vinyl chloride Vinyl ethyl ether Vinylidine chloride, VC Vinyl isopropyl ether *Vinyltrichlorosilane VX, 0-Ethyl methyl phosphoryl N,N-

anhydride

diisopropyl thiochohe

775 'WEPSYN 155, WP 155, Tri- amiphos, para-(5-Amino3-phenyl- 1 H-l,2,4-triazol-l -yl)N,N,N',N'- tetramethyl phosphonic diamide

776 Xylene, Dimethylbenzene (ortho, meta, para)

777 Zinc (powder) 778 Zinc ammonium nitrate 779 *Zinc arsenate 780 *Zinc arsenite 781 Zinc chloride 782 Zinc compounds 783 *Zinc cyanide 784 Zinc nitrate 785 Zinc permanganate 786 Zinc peroxide, Zinc dioxide 787 *Zinc phosphide 788 Zinc sulfate 789 Zirconium (powder) 790 *Zirconium chloride, Zirconium

tetrachloride 791 Zirconium picramate

a Current as of date of publication Table based from 22 CCR Article 9, Section 66680

* denotes an extremely hazardous waste Trademark names are capitalized

Some chemicals commonly used by cities appear in bold

Numbers preceding chemical names are for sequential (alphabetical) reference only. They do not represent waste numbers or waste codes or are in any way associated with the chemical name other than the order in which it appears in this table. Numbers are omitted where chemicals have been removed from this list in the past. "A" and ll6" numbers appear (for example, 740A and 7408) where a chemical has been inserted (added) to the list.

6-1 1

Table B-2 Listing of Common Chemical Names or Categories

Acetylene sludge Acid and water Acid sludge AFU Floc Alkaline caustic liquids Alkaline cleaner Alkaline corrosive battery fluid Alkaline corrosive liquids Asbestos waste Ashes Bag house wastes* Battery acid Beryllium waste Bilge water Boiler cleaning waste Bunker oil Catalyst* Caustic sludge Caustic wastewater Chemical cleaners* Chemical toilet waste* Cleaning solvents Corrosion inhibitor Data processing fluid Drilling fluids* Drilling mud* Dyes* Etching acid liquid or solvent Fly ash Fuel waste Insecticides Laboratory waste* Lime and sulfur sludge Lime and water Lime sludge Lime wastewater Liquid cement * Liquid cleaning compounds*

Mine tailings* Obsolete explosives Oil and water Oil ash Paint (or varnish) remover or stripper Paint thinner Paint waste (or slops Pickling liquor Pigments* Plating waste Printing ink* Retrograde explosives Sludge acid Soda ash Solvents Spent acid Spent caustic Spent (or waste) cyanide solutions Spent mixed acid Spent plating solution Spent sulfuric acid Stripping solution Sulfonation oil Tank bottom sediment* Tank cleaning sludges* Tanning sludges Toxic chemical toilet waste Unrinsed pesticide containers Unwanted or waste pesticides-an

unusable portion of active ingredient or undiluted formulation

Waste chemicals* Waste expoxides* Waste (or slop) oil Weed killer

"Denotes the common name of a waste which would be considered hazardous if it contains a hazardous material.

LAO~~~S\WM\~~O-OSS.S 1 B-12

Appendix C STATE HAZARDOUS WASTE CODES

" Table C-1

State Illrzardous Waste Codes Sheet I of 3

California Restricted Wastes

71 1. Liquid with cyanidcs z I.OW mg/l 725. Liquids with mcrcury L 20

721. Liquids with arsenic z 500 mg/l 726. Liquids with nickel L 134

722. Liquids with cadmium 2: 100 mg/l 727. Liquids with selenium z

723. Liquids with chromium (VI) 2: 500 mg/l 728. Liquids with thallium L

724. Liquids with lead z 500 mg/l 731. Liquids with

mu

m u 100 mg/l

130 mgil

polychlorinated biphenyls z 50 mgA

11 California Nonrestricted Wastes

' 74 I. Liquids with halogcnatcd organic compounds L 1,OH)O m@

Solids or sludges with halogenated organic compounds z 1,CKn) mgkg

Liquids with pH s 2

751.

791.

792. Liquids with pH s 2 with metals

_ _ _ _ _ _ ~ ~ ~ ~ ~~~ -

Waste potentially containing dioxins

121. Alkaline solution (pH 2: 12.5) with metals (antimony, arsenic, barium, beryllium, cadmium, chromium, cobalt, copper, lead, mercury, molybdenum, nickel, selenium, silver, thallium, vanadium, and zinc.

122. Alkaline solution without metals pH L 12.5

123. Unspecified alkaline solution

131. Aqueous solution (2 < pH < 12.5) containing reactive anions (azide, bromate, chlorate, cyanide, fluoride, hypochlorite, nitrite, perchlorate, and sulfide anions)

141. Off-specification, aged, or surplus inorganics

151. Asbestos-containing waste

161. FCC waste

162. Other spent catalyst

I

Table C-1 State tIazardous Waste Codes

132. Aqueous solution with metals (s restricted levels and see H 121)

133. Aqueous solution with total organic residues 10 percent o r 0 more

134. Aqueous solution with total organic residues less than 10 Dercent

135. Unspecificd aqueous solution

Organic

2 I I . Halogenated solvents (chloroform. methyl chloride, Dcrchloroethvlene. etc.

212.

2 13.

Oxygcnated solvents (acetone, butanol, ethyl acetate, etc.)

Hydrocarbon solvents (benxnc, hexane, s tddard, etc.)

i ~ . Unspecified solvent mixture

221.

222. Oilhater separation sludge

223. UnsDecified oil-containing waste

Waste oil and mixed oil

231. Pesticides and other waste associated with pesticide Droduction

232. Pesticides and other waste associated with pesticide I Droduction

241. Tank bottom waste

Sheet 2 01 3

171. Meld! sludge (see 121)

~~

172. Metal dust (see 121) and machining waste

181. Other inorganic solid waste

27 1. Organic monomer waste (includcs unreacred rcsins)

272. Polymeric resin waste

28 1. Ad hesives

291. Latex waste

31 1. Pharmaceutical waste

32 I . Sewage sludge

322. Biological waste other than sewage sludge

331. Off-specification, aged, or surplus organics

341. Organic liquids (nonsolvents) with halogens

342. Organic liquids with metals (see 121)

I 1 l~ I

Table C-1 State €Iazardous Waste Codes

Sheet 3 of 3

251. Still bottoms with halogenated organics 343. Unspecified organic liquid mixture

252. Other still hottom waste 351. Organic solids with halogens

261. Polychlorinated biphenyls and material containing PCBs 352. Other organic solids

41 1.

421. Lime sludee

Alum and gypsum sludge

431. Phosphate sludge

441. Sulfur sludge

481. Tetraethyl lead sludge

491. Unswcified sludee waste

451. Degreasing sludge

461. Paint sludge

471. Paper sludge/pulp

Miscellaneous

51 I. Empty pesticide containers 30 gallons or more 561. Detergent and soap

512. Other empty containers 30 gallons or more 571. Fly ash, bottom ash, and retort ash

513. Empty cwntainers less than 30 gallons 581. Gas scrubber waste

521. Drilling mud 591. Baghouse waste

1 531. Chemical toilet waste

54 1. Photochemicals/photoprocessing waste

551. Laboratow waste chemicals

~~

61 1. Contaminated soil from site cleanum

612. Household wastes

613. Auto shredder waste

I 1 l~ I

Appendix D Example: CITY OF ANAHEIM

IMPLEMENTATION OF HAZARDOUS WASTE REDUCTION PROGRAM

-

Appendix D Example of Implementing a Hazardous

Waste Reduction Program In July 1989, the City of Anaheim (City) began the development of an Internal hazardous waste reduction program through a grant from the California Environ- mental protection Agency. Anaheim designed this as a demonstration project to develop a model program that could be used by other California cities to assist them in their efforts in reducing hazardous waste generated by typical city departments.

This section details the approach Anaheim took as the Cay developed the stepby-step procedures outlined in this guidebook. A flowchart, provided as Attachment No, 1, summarizes the section described below.

1. Introducing the Program

The City of Anaheim felt the success of this type of project was dependent on the Cooperation and commitment exhibited by all levelsof City personnel - from the administrators to the field employees of the many diverse departments within the City. Therefore, the first step was to gain management support and commitment fortheprogram.Thefollowingaretheactivitiesthattook placeduringthepgramdevelopneru:

a. Discussions with City management regarding the key components of the program and the benefit the City would experience as a result of hazardous waste reduction. These discussions gave us an opportunity to gain top-level management support for the program.

b. Presentation of proposed waste reduction program to the Executive Safety Committee.TheExecutive Safety Commiaeeincludesmanagementrepresentatives from each departmenc therefore, each department had the opportunity to become involved in the project.

c. Letter from the City Manager to all department heads describing the program and inviting their panicipa- tion. A copy of the leaet is provided as Attachment No. 2.

d. Press releases were sent out to the local papers and the American Public Power Association to inform the community of the program. A copy of one of the releases is provided as Attachment No. 3.

a. Each department representative was contacted by phone and the program elements specific to their operations were discussed. At that time, an appoint- ment was made for the facility/pmcess assessment

b. A follow-up letter was sent to the department rep- resentativeconfirming theassessment anddescribing the assessment process. A copy of the confirmation letter is provided as Attachment No. 4.

3. Employee Awards Program

In an effort to involve the City employees in the waste reduction process, an employee incentive program was implemented. This program was administered through an existing employee incentive program. Described below are the steps taken in initiating the awards pro- gnun:

a. Requested and received approval from City management to implement the awards program. An attachment of the approval request correspondence is provided as Attachment No. 5.

b. Requested support from local businesses to conaib- ute giftddonations as incentives for employee involvement. Attachment No. 6 is a copy of the letter sent to a local business.

c. Developed a flyer, Attachment No. 7, and distributed it to City employees by inserting it into the City Newsletter and placing it on department bulletin boards.

d. Developed an award selection criteria, Attachment No. 8, and included the following City staff as the selection committee:

Environmental Service Staff

Deputy Fire Marshall - Hazardous Materials

Safety Administrator

e. Once award selections were made, certificates and prizes were presented to the recipients at a luncheon in their honor. An example of the certificate is provided as Attachment No. 9.

2. Initiaiing the Assessment Process 4. Waste Minimization Board

Each department head reviewed the program elements and assigned a representative as the point of contact for the projen ’Ihe following activities continued the process

During the project, the City established a waste minimzation workgroup. The primary objectives of

D- 1

establishing this workgroup were:

a. Evaluate the feasibility of substituting less hazardous or nonhazardous materids for the hazardous materials being used.

b. Evaluate existing processes that generate hazardous wastes and attempt to identify altemative processes that may reduce or eliminate the generation of hazardous wastes.

c. Develop a program to evaluate chemicals prior to purchase.

The workgroup involved representatives from the departments that frequently use chemicals as well as purchasing, safety, and environmental staff. A copy of the letter sent to each department is provided as Attach- ment No. 10.

Each department was given an infarmation sheet to complete on the chemicals used in their operations. When completed, the sheets were returned with the materials safety data sheets so that chemicals and processes could be evaluated by the workgroup and waste reduction opportunities discussed.

The response to the establishment of the workgroup was not as favorable as expected. Many departments found it too time-consuming to complete the forms and provide the MSDSs for the chemicals. In retrospect, this function may have been better facilitated by just using the forum of the Executive Safety Committee, which is made up of City department heads.

5. FacilitylProcess Assessments

The facility/processassessment gave us an opportunity to discuss specific City operations and identify waste generating processes. During the assessment we de- cided that it may be helpful in the development of the guidebook to provide information on what a hazardous waste is and hazardous waste storage requirements. We found that the level of awareness differed in each depamnent. In fact, many depanments had initiated many waste reduction techniques without realizing it. They had made changes and/or substitutions for safety reasons or to comply with other regulatory measures. The assessment process involved the following:

Opening conference with both the management and technical staff. This gave us an opponunily to talk about the department operations. existing h a -

ardous waste management procedures, chemical purchasing procedures, and disposal practices.

Facility walk-through. During the walk-through all chemicals/processes were listed, the general appearance of the work area was noted, and the waste management procedures were reviewed. A sample is provided in Attachment No. 11 questionnaire.

Compiling data. All information gatheredduring the assessment process was input into a data base for easier organization. An example of the data base is shown as Attachment No. 12.

A list of the types of materials and processes reviewed during the facility/process assessments in Anaheim is provided in the Guidebook, Chapter 6, Section 6.4.

6. Evaluating Waste Streams for Waste Reduction Potential

Once all the available waste data were gathered, the checklists forevaluating waste reduction potential were developed. The checklists provided a systematic approach to evaluating the materials and processes in use on City operations.

Attachment 13 providesan example on how the checklists were used to evaluate one Anaheim waste stream.

7. Implementation Plan

Once the checklists were completed, an implementation plan that offered waste reduction potential was developed. The waste streams were consolidated into a format that allowed us to hack the progress of the waste reduction approach.

The Source Reduction Summary Checklist, Aaach- ment 14, was used to develop the implementation plan. The implementation plan for one Anaheim waste stream is provided in Auachment 15.

___ 8. Pmject Summary

During thedevelopment process of thisGuidebookand Anaheim's Waste Reduction Program, many important things were learned about City operations and management structure.

-

The most important elements - ensuring that you have a strong management commitment, involving each department, and developing a "user-friendly'' program.

D-2

have bctn emphasized throughout the Guidebook.

?he C i is planning on continuing the process of

potcntiaLInaddition,thtUtiliticsDcpaxtmcntplanson aying a Hanvdous MaFcrial Purchase Management

evaluatingmataialsandploctssesfoowasttduaion

prosram (HhPW) in the fuaue.

D-3

ATTACHMENT #1

HAZARDOUS WASTE REDUCTION PROGRAM

HAZARDOUS WASTE REDUCTION PROGRAM OVERVIEW

CITY MANAGERS OFFICE FOR REVIEW SUBMITTED TO THE

CITY MANAGER PROVIDES EXECUTIVE SAFETY COMMITTEE (ESC) PROGRAM OVERVIEW AND IMPLEMENTATION PLAN AND REQUESTS

THAT ESC MEMBERS REVIEW OVERVIEW AND PLAN FOR DISCUSSION

I

'

AT NEXT ESC MEETING.

I 1 I

PRESS RELEASES SENT OUT.

OaRVIEW AND PLAN PRESENTED TO AND DISCUSSED WITH ESC. FINAL PLAN

DEVELOPED AND APPROVED

I LETI'ER SENT TO DEPARTMENT HEADS

I I I

EMPLOYEE AWARDS PROCRAb4 k WASTE MINIMIZATION i BOARD INITIATED

ENVIRONMENTAL SERVICES DMSION (ESD)

SCHEDULE ASSESSMENTS. CONTACTS CITY DEPARTMENTS TO

L I I I I

ENVIRONMENTAL SERVICES CONDUCTS

CHEMCIALS AND PROCESSES DEVELOPED FACILITY/PROCESS ASSESSMENTS. DATABASE OF

I I I

~~ ~

WASTE STREAMS EVALUATED FOR WASTE REDUCTION POTENLU. USING CHECKLISTS DEVELOPED

I I I r DEVELOP IMPLEMENTATION PLAN

AND TRACK PROGRESS OF WASI'E REDUCTION APPROACHES

L I

D- 4

AlTACHMENT #2

MEMORANDUM CITY OF ANAHEIM

DATE:

TO: DEPARTMENT HEADS

FROM: CITY MANAGER

SUBJECT: HAZARDOUS WASTE REDUCTION PROGRAM

The C i i has initiated an Hazardous Waste Reduction Program that will 38 administered by stsff of the Utilities Environmental Services Division. By implementing a Hazardous Waste Reduction program the City can minimize employee exposure to hazardous materials; reduce offsite disposal costs; and decrease long-term liability. The goal of the program is to evaluate current materials and process for the potential for reducing the types and volumes of hazardous wastes being generate.

Environmental Services staff will be gathering information on your Department's individual operations that generate hazardous waste by conducting facility/process assessments. Below is a brief summary of the assessment process:

1. Opening conference, which includes an overview of the Program and a discussion of the types of operations to be viewed.

2. Facillty tour of department operations that use chemicals and generate hazardous waste.

3. Interviews with department personnel involved in hazardous waste management.

4. Review of chemical purchase procedures.

5. Review of hazardous waste disposal records.

The time required to perform the assessment will vary depending upon the size and number of facilities and the type of operations conducted.

D- 5

ATACHMENT #2

In order to perform the facility assessments it will be necessary for the Environmental Services staff to review specific environmental records. These records are listed in Attachment A. Please have the records applicable to your operations available to the Assessment Team at the opening conference.

The facilii assessments will be scheduled with each department for the month of November. I look fonnrard to making the Hazardous Waste Management Program a great success for the City and your Department. Please contact the Environmental Sem'ces Manager, Utilities Department, if you have any questions regarding the assessment process.

D-6

ATTACHMENT #2

ATTACHMENT A

HAZARDOUS WASTE REDUCTION PROGRAM

Hazardous waste manifests

Hazardous waste tax records

Hazardous waste biennial reports

Oil recycling records

Inspection records from regulatory agencies

Chemical inventory

Hazardous material disclosure forms

Facilitj drawings

D- 7

AlTACHMENT #3

Anaheim will examine ways to reduce waste

Over the next par, the h d w h , Calif., Public Utilities D e p e a t WS study how to reduce the amount of hazardous waste produced in M d m and will publish the finding^

of wtc genesated in the d-te 03, cfap II, rohrenu. paints, and other sub sncu-then will study ways of redue ing the mte by reqcling or switr)lins to producm &at generate luc hazard-

Rcduag the wastes Win cut pdlu. Lion m d save the city moncyia *sd costs and long-term liabiity, said utilities G u r c d Manager Ed A g h h The sntc Dcpvrmurt ofHal& scl.

vices has awvded Anaheim a $SeOOO paat for &e project, which t erpcacd

WIS selected &om 100 appEariOn~ I .-

Ciy s r a E will idenrify

ous waste.

:

to cost $5seooo. Anrbc'uns proporof

AlTACHMENT #4

P u B LIC UTILITIES DEPARTMENT ENVIRONMENTAL SERVICES DIVISION

M E M O R A N D U M

DATE:

TO: Police Department

FROM: Environmental Services Specialist

SUBJECT: Environmental Assessment Program

This is to confirm’ that a Hazardous Waste Reduction evaluation has been scheduled to begin at your facility on Wednesday, November 28,1990 at 1:OO pm. This evaluation will be performed by myself and the Safety Manager.

Attached, per our discussion, is a copy of the memo from the City Manager describing the Hazardous Waste Reduction Program.

The assessment will be conducted as follows:

* We will provide you with a brief overview of the goals and objectives of the Hazardous Waste Reduction Program.

* We will present the elements of the Hazardous Waste Reduction Grant the City has been awarded by the State Department of Health Services and how your department can participate.

* We will need a brief description your operations that involve any type of chemicals or chemical storage, painting, cleaning and maintenance processes.

* A tour of your facilities, maintenance locations and chemical storage areas. Please have staff available that will be able to answer questions regarding these operations.

* Review of the records described on Attachment B of the memo from the City Manager. Please have them available, as applicable to your operations, at the opening meeting.

I am looking forward to working with you and your staff on this project. If you have any questions, Please feel free to contact me at 533-5767.

Thank you.

D-9

ATTACHMENT #5

PUBLIC UTILITIES DEPARTMENT ENVIRONMENTAL SERVICES DIVISION

M E M O R A N D U M

DATE:

TO: Administrative Services Coordinator

FROM: Environmental Services Manager

SUBJECT: Hazardous Waste Reduction Program

As part of the City's Hazardous Waste Reduction Grant, I am proposing that a Environmental Enhancement Awards Program be developed as an incentive to initiate employee involvement in hazardous waste reduction and pollution prevention. I would like for the City Manager or the Mayor to be involved with this aspect of the Program.

The City of Los Angeles implemented a similar awards program and received several excellent proposals. Employee incentive programs are also identified as a source reduction approach in the recently passed waste minimization legislation, which requires generators to document waste minimization activities.

The attachment outlines the specifics of the proposed program, including the program description, application requirements, and selection criteria.

With your approval, I would like to initiate this program as soon as possible. If you have any questions or would like to discuss this project further, please feel free to contact me.

Thank you.

D- 10

ATACHMENT #6

Dear:

I am writing to your company in order to request your assistance in an awards program the City has initiated.

Anaheim is trying to generate a higher level of environmental awareness and concern among our 4,500 employees. In order to do this, we are initiating Anaheim's Environmental Enhancement Awards Program. Following is a brief description of how the Program will work:

Employees will submit ideas for innovative ways to protect our environment by reducing the amount of hazardous waste generated by City operations. Examples of suggestions are:

The substitution of non-hazardous or less hazardous materials for hazardous materials currently being used.

Process or procedure changes or modifications that reduce or eliminate the generation of hazardous waste.

Identifying recycling opportunities for hazardous materials or hazardous waste.

Employees who submit ideas that are implemented will receive 10% of the first year's estimated savings in addition to the awards that will be offered.

That is where your company comes in. We would like your company to donate a weekend at your hotel to the employee submitting the best idea. Should your company decide to donate a week-end stay at your hotel, a representative of your company would be welcome to participate in the Program's evaluation and award process. In addition, your company would receive considerable publicity and recognition during the Program's advertising campaign.

Please let me know if your company could assist us in this important endeavor. In addition to improving our employees environmental awareness, I feel that this Program has significant potential for enhancing our environment.

AlTACHMENT #6

I would appreciate headng from you at your earliest convenience regarding your pmpany's participation in this endeavor. We hope to initiate the Program on March 8, 1991 and complete the evaluation process by April 1 1991. If you have any questions regarding this Program please call me.

Very truly yours,

Environmental Services Manager

D-12

Participate in ATTACHMENT #7

the City of Anaheim's

The Environmental Enhancement Awards Program has been established, in conjunction with the Employee Involvement Program, to encourage City employees to submit ideas for innovative ways to protect our environment by reducing the amount of hazardous waste generated by City operations. Examples of suggestions are:

The substitution of non-hazardous or less hazardous materials for a hazardous materials currently being used. Process or procedure changes or modifications that reduce or eliminate the generation of hazardous waste.

Identifying recycling opportunities for hazardous materials or @ hazardouswaste.

To submit your idea, complete an Employee Involvement Program (EIP) application and subNt it to Dennis Schmidt, EIPAdministmtor, Room 332, Civic Center. Call 254-4443, to obtain applications.

All applications must be received by May 3,1991.

Employees who submit ideas that are implemented will receive up to 10% of the first year's estimated savings. In addition, the following awards and prizes will be offered:

* Plaque presented by * Get-away Weekends at:

Anaheim Maxiott City Manager Disneyland Tickets Disneyland Hotel

Pan Pacific Hotel Sterling Suites

* California Angels Tickets * LA. Fitness Center Annual

Membership

For more information regarding this program, call John Hills, Environmental Services wer. Public Utilities Department, at 533-5765.

Man-

n-i 7

AITACHMENT #8

ENVIRONMENTAL ENHANCEMENT AWARD JUDGES SCORING' SHEET

JUDGE: 1 NOMINEE ID# I I I F I

I I PROJECT TITLE

Score each award nominee on the following criteria from a scale of 0 to I O for their relative achievements:

CRITERIA SCORE WEIGHT TOTAL SCORE

I.

2.

3.

4.

5.

Multimedia Environmental Impact X (negative = 0; positive = 1 0)

Innovation X (derivative= 0; inventive= 10)

Ap licabilty X (sire specific= 0;applicable to many areas = 1 0)

X Potential for reduction in P negligable= O;significant= I O )

ollution volume

Effect on Droduct or Service quality (worse= O;enhanced= I O )

NOTES:

X

3.0 =

2.0 =

2.0 =

1.5 =

1.5 =

TOTAL SCORE = (maximum = 100) I I :

- . Adapted from City of Los Angeles, HTM Project, Awards Program

3 .I 1 Andy Anaheim

for participation in the Environmental EnhancemenL Awards Proaram. The innovative idea you submitted reflects your commitment to protecting Anaheim's environment today and for the future.

James D. Ruth City Manager

Edward K. Aghjayan General Manager

Public Utilities Department .

t

ATTACHMENT #10

CITY OF ANAHEIM PUBLIC UTI LIT1 ES DEPARTMENT

ENVIRONMENTAL SERVICES DIVISION

MEMORANDUM

DATE:

TO: Those Copied

FROM: Environmental Services Manager

SUBJECT: Hazardous Waste Minimization Board

The Utilities Department is conducting a hazardous waste reduction study which is partially funded through a grant from the State Department of Health Services. The study involves an assessment of the types of hazardous materials which are used within the City, the types of processes which generate hazardous wastes and an evaluation of methods the C i can implement to reduce the amount of hazardous waste which are being generated. As part of the project, the City is establishing a Waste Minimization Workgroup. The primary objectives of the Workgroup are:

1. Evaluate the feasibility of substituting less hazardous or non-hazardous materials for the hazardous materials being used.

2. Evaluate existing processes that generate hazardous wastes and attempt to identify alternative processes that may reduce or eliminate the generation of hazardous wastes.

3. Develop a program to evaluate chemicals prior to purchase.

I would like to invite you, or a representative from your Department, to participate on this Workgroup. The Workgroup will be meeting once a month during the study, which will begin in January and end in June. The first meeting is scheduled for Wednesday, January 30, 1991 at 9:OO am in the Environmental Services Division, First Floor, First Interstate Bank, 222 S. Harbor Blvd.

___

-~

-

AlTACHMENT #10

The establishment of this Workgroup is essential for the development of an effective Waste Minimization Program within the City. I look foward to your Department's participation in making this program a success. __

If you have any questions, please contact me.

Thank you.

cc: Safety Manager Safety Administrator Purchasing Maintenance Convention Center Stadium Parks Department Police Department Fire Department Utilities Department

D-17

A t t a c h m i t t #11

IfAZARDOUS WASTE ASSESSMENT QUESTIONNAIRE

Sheet 1 of 4

I. GENERAL INFORMATION

De part me nt/Division Name:

DepartmentDivision Address: qm E. a &,J Department/Division Phone:

PQc!+&&ol\

) SSS- 17-3 !I-

Number of employees: 120

Attachment #l l I~AZARDOUS WASTE ASSESSMENT QUESTIONNAIRE

Sheet 2 of 4

3. HAZARDOUS WASTE GENERATED

Physical Generation cost - Rate

7 - ‘Qpe of Waste Source State

; b& oil

? .

4. WASTESTORAGE

Length of cost Storage - Type of Waste Storage Quantity

P N 0

Attachment #11 HAZARDOUS WASTE ASSESSMENT QUESTIONNAIRE

Sheet 3 of 4

5. ONSITE TREATMENT (e.g., neutralizing acids or washing rags at your facility)

End Products cost - ‘Qpe of Waste Treatment Frequency /Quantity)

SlWC d d

6. OFFSITE TREATMENT (e.g., recycling oil offsite, sending used rags to an offsite recycler.)

Who/ cost Frequency - Type of Waste Quantity Treatment Where

b o w

Attac:)uiielit #11 IIAZARDOUS WASTE ASSESSMENT QUESTIONNAIRE

Sheet 4 of 4

I . WASTE DISPOSAL

Method of Type of Waste Where Quantity Frequency

'5"r)l conB;Ap/I

?Y / I

? N w p d /I

/I r)hur$ o i l

F 8. WASTE TRANSPORT

Method of Who Quantity - Type of Waste Disposal Frequency

cost -

Cost -

16-PI-62 :q

A t tachmen t # 1 3

DATE

EVALUATOR:

CIIECKLIST

SOURCE RBDUCIION METllOD NO. 1 IIOUSEKEEPINO OR INVENTORY CONTROL

P a p Id9 I I

ANSWER YES" OR LNO"

Is thb eully done?

ltchnlul be d e lor T obahclcr~ workem?

Wlll thh

Cmn lhb kdonc wllhoul Llrlq

eomeone wlth

cxpcrkncc In ILW.? -

Will lhb i l ve no equal

quallty prodrCl

or r n k e ?

Wlll we be 8bk lo do

lhle wlthoul

cmpluyec tmlnlng?

new

Wlll thb ntiult lo mnnuml

coli1 uvlnge?

Will lhb makc w . ~ k

ksi hrurdoue?

Wlll lhb

nmounl SOURCE

REDUCTION ALTERNATIVE

IIOUSEKEEPING

YCS Y a Y a EXAMPLE X Y u Yu, No . PICKUP m r h d m

TRAsl I required

Dispase or non- haurdocu mta ~ p a n t c l y from haurdocu mrta

R ~ U = usc or

x Y N x Y N X I J N

akorbntr lor cleanup

Clan up all m r i a at work- shop at least dally

Keep point chips and metal s b - iflp Off 6rOUnd '

I

Y Y Y Y

Y Y Y Y Y Y

u\032245\WM\610-002.5 I

m 4

4

D- 24

Attachment 113

EVALUATOR: J - p & ~ ~ # ,

SOURCE REDUCTION METIIOD NO. 1 HOUSEKEEPING OR 1NVIC"ORY CONTROL

ARE #E DOING I T!IISNOW ANSWER YFS" OR "NO"

1 Can Lhb be done Wllhorl Udnl

Wllh experkact In 1I.W.T

molcollc

Wlll lhb glve mn equal

qU8llly P d d

d e e t w

Wlll we be able b do

IhL wllhorl new

CmPbrCC Imlnlw?

Y

Cam we -In dolw &Is? If no, why mot? If ycq wko?

Wlll lhb mull lo annual CaYl

aavlngm?

Y

Wlll Ihb be uk lor worl"?

SOURCE RBINJCflON

ALTERNATIVE Yes

ilally pdlullng materials (dump rlen. drum#, lank, ballwia, ClC.) IO

keep nimmler off

S t a n wasla In rccun?, eovrrrd, pmlected, nurkcd, diked arur

Keep liquld products oc amlaincd wutc la knnad a m which will hold 10% d all m t r l n c n or I lo!% of blgenl container

cover Bll pOtCa-

Y

Y

A t tachmen t # 1 3

CIIEXKWW

SOURCE REDUCTION MEnlOD NO. 1 IlOUSeKEEPlNG OR INVPlTORY CONTROL

Page 4 d 9

ARK WE DOING TI119 NOW? ANSWER YES OR "NW

Wlll we be mbkbdo

thb wllhout

employee I m l n l ~ ?

Iww

N

SOURCE REDUCI'ION

ALTERNATIVE

Wlll lhb

workers? be -it

Y Y

comr( mrte labeling

Make empty con- tainm nonuublc and manage M Y r3

'I Y Do not dltanl

containen unlar n-ry

k p mln lmca reaching whlck mlnlenanee 01 refueling area6

Provlde nhuldl valva on large tanka In m n t d

poairily lull Y Y Y h) Y Y

Y Y Y ' Y

I i l l~ I

Attachment #13

SOURCE REDUCTION MEI'llOD NO. 1 IIOUSEKEEPING OR INVENTORY CONTROL

ARE WE DOlNQ TI119 NOW? ANSWER "YES OR "NO"

I SOURCE

Can lhlr be done WI lhOUl

hlrlng 8 0 ~ O n e

wllh erperlcmc In ILW.?

WUI lhb &e an cqul

quallly producl

or senkc?

Wlll we be abk lo do

lhb WlI l lOUl

employee lmlnlng?

I U W

Wlll lhb mul l In m n u d

cos1 mvlngi?

Can we kgln dol- lhk? Itno, why not? II ye#, when?

Ir lhb Wlll lhb e d l y done?

nuke wash lcchnlul

h828dOUS? 0bS-k)

Wlll lhb redwe unornl

or ~ r r ( c ? REDUCTION

ALTERNATIVE

Keep spill rapnce malcrial onslte

Segregate warla and matulrlr according lo F hazard elrasa

Y Y Y Y Y

Y Y Y rs

r s . t lm an officlrl tnlnlng program for all cmplayecr Involved with hazardour malerials (including spill L =Pence)

Y x

Attachment # 1 3

SOURCE

ALTERNATIVE 1 REDUCMON

CIIECKUSF

WURCE REDUCllON METllOD NO. I IIOUSEKEE?ING OR INVENTORY CONTROL

. P a p 6 o f 9

I ARE WE DOIN0 "Ill8 NOW? : ANSWER YW OR 'NO"

RY CONTROLS

Y Y

Y

can we bqln dol- lbk? I f no, why no@? If

Attachment 1113

SOURCE REDUCTION MIWllOD NO. 1 IIOUSEKEEPINO OR INVENTORY CONTROL

ARE WE DOING I "IIISNOW ANSWER "YES" OR "NO"

CM tblr be done wllboul hirlq

" C O n t

wllh erperkw In 1I.W.t

WIU lhlr glre an

qwllly

Is thb Btl'VkC? kgd?

WIU we be abk b do

wllhoul new

emPbY= lrrlnlng?

hb Can we d o h

thb? Uno, why not? II yes, when?

I s lhb WIU lhb rtdrn " o m 1 or W U ~ T

emlly dune? (no Wlll lhb

lcchnkal k u r e lor OkCWta) norken? U

I

Y d 13 Y Y Y

Y d Y y Y

Attachment # 1 3

CIIECKUSI'

SOURCE REDUCTION MEI'IIOD NO. 1 IIOUSeYEE?lNG OR INVENTORY CONTROL

P a p O d 9

ANSWER ''YES" OR 'NO" M E WE DOING 1 NOW?

Wlll (blr mull I. Wlll lhb

reduce SOURCE REDUCTION

ALTERNATIVE

Wlll Ihb be safe kr W

rcnke? Df \rclr(ct la 1I.W.T

Makeamage- menta lo ~ I u m unwed hurrdou,

emply muinen IO vendor

materirh and Y Y 'I N

Y Y Y Y r3

Y Y Y Y Y Y Y

L ~ 0 3 2 2 4 ~ W ~ l O _ o O Z . S 1

Attachment # 13

DEPARTMEN'P. I #

ARE WE DOING "NlS NOW?

CllECKLlSF

SOURCE REDUCl'lON MEIVIOD NO. I IIOUSEKEEPING OR INVENTORY CONTROL

P a p 9 of 9

ANSWER "YW OR "NO"

WUI Ibh kulcfiw worken?

WUI lbb mnll In annual

C a t

urlngs?

C.n Ihb kbnc WlthOUl

hkl- wmconc

w l t h experknce In II.W.?

Attachment # l 3

SOUKCE

ALTERNATIVE I REDUCTION

UK nonchkrlnaled

than chlorlmled

CIIECKUST

SOURCE REDUCTION MEI'IIOD NO. 2 SUBSTITUTION OF NONIIAZARDOUS MA"EJtU19

I ARE WE DOlNO TllIS NOW?

WWI thb mull lo

uvlnp?

WIU we be abkbdo

lhb wllhoul

new

emplqrcr (rmlnlm? I upcrlcocc In ILW.?

Y I Y

DEPARTMENE

w m m w

SOURCE REDUCI'ION METIIOD NO. 2 SUBSFlTUTlON OF NONIIAWRWUS MATEXIALS

P a p 2 of 3

ARE WE DOING NOW ANSWER YES OR "NO"

Can Ihb k done

wllboul bldw

wlth

In II.W.?

LomCODc

CXpCrkaCC

Wlll lbb 3 v t an equd

producl

unke?

qU8IIIJ

or

WIU we k abkbdo

lhb wlIhouI

employee Imlnlng?

llcW

I s lbb eully done? (no

Mnk.1

Cao we allin

dol- thb? I f no, why nol? If

yes, when?

Wlll Ihb mul l In annul

COS1

u v l l l p ?

Wlll Ihb rrdrcc

onrounl WUI Ihb

be u l e lor WorkrIs?

Y 2' 7 rl

d Y Y

I

LAO3224~WWlO-0OZA.S I

Attachment (113

D A ~ ' I EVALUATOR:

ClIeCKU!3"

SOURCE REDUCTION METllOD NO. 2 SUB!iSTII"ION OF NONIIAZARWUS MATERIALS

ANSWER *YES OR "NO"

Wlll lbb nuke wmLc

krr hazardous?

I

Wlll Ihb be ulc lor wortcm?

Wlll Ibb glvc an cqul qUnll1y prodUc1

or rnkc?

Wlll we be mbk lo do

lhb wllhoul

new employee lrolnlng?

CUI lhlr k dona

wllhorl hlrlng

aomeotw wllh

cxprrlcna In 1I.W.t

I

c8a we begln

dolly lhk? If ne, why

yea, when? -it ir

Attachment #13

ClleCKLlSF

SOURCE REDUCTION MEI'IIOU NO. 3 SUB!STITUTION OF A MATERIAL THAT REDUCES VOLUME OR TOXICITY

ARE WE DOlNO TIIIS NOW ANSWeR "YES OR "NO"

II Wlll we be abk lo do

lhb whDu1

employee Iralnlng?

new

Can Ihb he done wllhoul hldng

mmcone wllh

expcrknce In I1W.t

Y

Wlll Ibb glve m n cqwl

qU81ny produel

or unket -

Y

Wlll lhb mull In a n n 4

COS1

urlnp?

Wlll lhb redwe rmounl

of -le?

rJ

SOURCE REDUCI'IQN

ALTERNATIVE

Wlll thb bc r k for worken? - Yes -

btrblish proadun in ccntmlized pur- chrslng w h m bzrrdoua mrtuirlr purchua am mal- ~ r ~ e d tor p o u i ~ e 8 U b l i t U h (MSDSI, elc.)

Y Y

Y producli wrllable by

section 7.1.1 lo

SUbstIlUlionr for hurrrdwr mrlerlrl

x

Attachment X 13

SOURCE REDUCTION METllOD NO. 3 SUB!RITUTION OF A MATERIAL TlUT REDUCES VOLUME OR TOWCIIY

Pare 2 d 3 P *

ARE WE DOING TI119 NOW? ANSWER 'YES* OR "NO.

Wlll lhh 3*c q u l l l y prodUc1

or

q U . 1

UNkC?

C8o IbL be done, WMhoUt blrlw

" O M

wllh cxpcrlcaec In 1I.W.T

Wlll m be

Ihh rllhod

employcc

8Lk b d0

new

Ir lhb e u l l y dune?

m kchnkal obmlrckr)

Will lhb mull In 8nnul

COB1

urlqp?

Y

Y Y -

Wlll Ihb redun m y n l of rrolc?

WUI IhL be d e lor worken?

REDUCi'ION

Y Y h) Y Y Y hl Y 7- Y Y

I rs Y

I Y I

Attachment #13

I d SimiU EVALUATOR: J

DATE bs. 7, A5 DEPARTMENT: 4

SOURCE REDUtTION METIIOI) NO. 3 SUB,SFlTUTION OF A MATERIAL TIIAT REDUCES VOLUME OR TOXICITY

Page 3 d 3

ARE WE DOING ANSWER "YES OR "NO"

Wlll lhb 3 V C 80

cqu8l qumllly prOduc1

or rcrvkc?

WUI we k mbk'lo do

thb wllhoul

. new employee lmlnlly?

k dome rllhoul Nrlq

comeone wlth

exper2cnce lo i1.W.t

WIN lhlr mult In annual

Cool uv lnga? NIA

Wlll lhla reduce

rmounl or W.CM

Wlll lhb

worken? bc -re for Is lbb

kgd?

Comments:

Attachment X13

DEPARTMEm

WASTESTREAM:

CllECKLIST

SOURCE REDUCTION METIIOD NO. 4 ONSITF: RECYCLING OW TREATMENT

Page 1 d 2

I NU3 WE DOING I TllIS NOW? ANSWER YES" OR "NO"

LA032245\WM\610_002CJ 1

Can lhb be done rllhout hlrlng

wllh esperknce In ILW.?

s o ~ 1 w

Y

EVALUATOR:

SOIJRCE REDUCTION

ALTERNATIVE

Attachment # 13

ARE WE DOING TI119 NOW

Ytr No NIA

SOURCE REDUCTION M m l O D NO. 4 ONSITE REYCWNQ OR TREATMENT

P a p 2 d 2

1 1 In thb cmlly done?

amount or kchnk.1

ANSWER YES" OR "NO"

7

Will l l b l s be SO& for workem?

Wlll thb @ve an e q u l

quality prodUCC

w

Wlll lbb rcvull In annual

COS1

uvinga?

WIU we be able (0 do

thL wlthout

' new ~ cniptoycc

tmlnlng?

Can t u be done wlthout hlrlq

wmcune wllh

crperknce In II.W.7

Commcnlr: I1

NIA - Nol appllcrbb

u\03224S\WhWl0~002C.S 1

A t tac hmen t # 1 3

CIIECKU!S"

SOURCE REDUCTION MeTllOD NO. S OFFSITE RWCLING OR TREATMENT

@@ @ @ @ Page 1 of 3

n ARE WE WIW

TI118 NOW ANSWER "Yes" OR "No*

Ir Ihb raslly done?

lcchnkal (no

0bbIBc.eln) - Will lhb r e d l In ann4

cofl S B V h I p ? -

Will Ihb nub wmsk

ku b.ul.dort

Wlll Ihb k uk lor worbera? - RPUUCT'ION

ALTERNATIVE

Y Y Y Y Y

Y Y Y Y

Attachment # 13

EVALUATOR: DAmm ARE WE W I N G TI116 NOW?

CllECKLlST

SOURCE REDUCTION MEfIIOD NO. 5 OFFSITE RECYCLING OR TREATMENT

Will thb reduce amounl d Wnb?

Is lhh emslly done?

kchnlul

ANSWER "YES" OR "NO"

Wlll thlv be u f e for worltn?

WIU lhb glve an equal

qul l ty produel or UNh?

L

Will lhb result In annual

COS#

WW?

WUI we k able lo do

lhb wlthoul

employee new

tmldafi?

CUI lblr be done wlthoul hldng

wltb expedtmc In ILW.?

I Q W O R O

l~O3224~wh0,610-OO2O.S I

1 I I~ I

Attachment # 13

CIIIXKWSI'

P P N

ARE WE DOING TlIIS N O W

No NIA

>(

SOURCE REDUCTION MeTIlOD NO. 5 OPYSITE R W C U N G OR TREATMENT

Wlll thls nuke waste

km buudow?

I s thb enslly done?

(no kchakrl .bs(rkr)

ANSWER "yes" OR HO"

Wlll Ihb be d e lor workem?

Y

Will thls mull In annual

COS@

M*?

Y

Wlll we be abk b do

lhb wllhaut

employee new

tr8lnlalg?

Can thb k done wlthoul hlrlng

wlth experkncc In ILW.?

8OI))Rone

Attachment #13

SOURCE REDUCTION METIIOI) NO. 6 REhVALIJATION OF PROCES ELIMINATION

ARE WE DOIN0 TI118 NOW? ANSWER "YeS OR "No"

Can lhb be done wlthort hldng

wllh cxpcrltmc In H.W.?

comeone

- Will we be able to do

lhls wllhorl

new cmpluycc Irmlnlng? -

WUI lhb mull In annual

cos1 uvlw? -

Will Ihb reduce mmounl d W a s k t -

Will thls make wade

kso bmrdom?

SOURCE REDUCTION

ALTERNATIVE

Wlll lhla be u l c lor worken? - Is Ihb

Iqd? - Dlrconllnue unneaurry maintenance (e+, acesrhn vchlcle washing, elc.)

On an annual bin, evatuale need for p n r c u a lhal IUC

haurdour malerlrlr hl Y Y v

Y Y Y r

Y Y Y Y

Allcnd lource redudon confer- e n m to find out whac elre a n be done

Y Y Contact government agenda and lmde auoclallon, for help in Idenll-

Y

A t tachmen t # 13

CIIlXKI.1.S"

SOURCE REDUCTION MmIIOU NO.'6 REEVALUATION OF PROCESS ELIMINATION

I PngeZol3

ARE WE DOING TlllS NOW ANSWER YES" OR "NO"

Cmn Ihb k done r!lhnul hlrlq

wllh experknee In ILW.?

S O ~ I I C

Wlll lhk elre an equal qrllly produel

or sewkc?

Wlll we be able (0 do

lhlu wlihoul

new employee lralnlng?

la Ihb t u l l y dom?

lcchnkal ObSIWka)

Wlll (lib mull In annual

cos1 S8Vlll@?

Wlll Ihk ndUCC

amounl d WmSIe?

Wlll Ihb nukc wlsle

kss haurdous?

Wlll lhln bc amk lor wo*rs?

' RWINICTION ALTERNATIVE

Ccmtrncl out ccr- lain pmcenu% lhnl 'use hrznrdcna mnterinln tci mnlraclon who can implcnicnl otlier source trdua kin dlcrnnlivcs. (Noh Ibls opllon ducs not reduce (he quanllty or w r l e pncralcd. and should only bc chacn afler all olhcr nlternntlrcr huve ken

Y Y

Attachment #13

DATE:

EVALUATOR:

CIIECKLIS"

SOURCE REDUCI'ION

ALTERNATIVE

DEPARTMENT

wmsTREAM:

SOURCE REDUCTION METllOD NO. 6 REEVAI.UATION OF PROCBS ELIMINATION

I ARE WE DOlNQ "Ills NOW? ANSWER "YES" OR "NO.

Wlll lhb mmh wule

lesa

I WUI Ihls be ure ror WOrkCl.?

Wlll lhL glve an

qwllly

IIJ 1hL senkc?

I I

Wlll Ibb mull lo mnnlul

cos1 mvlngs?

Wlll we be mbklodo

Ihb Wl lhoUI

employee lralnlng?

I U W

Cmn lblr bc done w11hou1 hlrl-

lomeone wllh

erperlence In lI.W.? F Cocnmencr:

NIA .I Nol applicable

c.0 m all0

lhb? If n@l W C O O ~ T ir

yes, when?

lA03224~WM\s10-002E.S I

Attachment 4 1 4

This page is intended to summarize all viable source reduction alternatives for your facility' This summary will show an overall pictare of possible source reduction methods. The summary can k used to plan the implementation of waste minimirrntion options.

Fiil in the "Source Reduction Aitemative" column with the Source Reduction Method sheet information that have mostly "yes" across the sheet.

YOU may need to make additional copies of this checklist before filling it out, ~

~

n SOURCE REDUCTION SUMMARY CHECKLIST 1 I I!

" I I'

Ii

I

I)-46

Attachment 1 4

"his page is intended to summarize ail viable sour& reduction alternatives for your facility. This summary will show an o v e d picture of possible source reduction methods. The summary can be used to plan the implementation of waste minimization options.

Fill in the "Source Reduction Alternative" column with the Source Reduction Method sheet information that have mostly "yes" across the sheet.

YOU may need to make additional copies of this checklist before tilling it out

II SOURCE REDUCTION SUMMARY CBECKLIST

II

1

1 1

I t I I "

D-47

Attachment # 1 4

This page is intended to surmnarh alI viable source reduction alternatives for your facility, This s o m m a y wil l show an overall picture of possible source reduction methods. The S- can be used to plan the implementation of waste " i m t i o n options.

Fill in the "Soumx Reduction Alternativew column with the Source Reduction Method sheet information that have mostly "ycs" across the sheet.

You may need to make additional copies of this checklist before filling it out.

n SOURCE REDUCITON SUMMARY CHECXLXSI'

I

Attachment # 1 4

This page is intended to summarize all viable source reduction alternatives for your facility. This summary will show an overall picture of possible source reduction methods. The summary can k nsed to plan the implementation of waste minimization options.

Fill in the "Source Reduction Altemative" column with the Source Reduction Method sheet information that have mostly "yes" amss the sheet.

You may need to make additional copies of this checklist before filling it out

I1 SOURCE REDUCI'ION SUMMARY CHECKLIST

5 I " I /

D-49

Attachment # 14.

This page is intended to summarize all viable source reduction altematives for your facility. This summary will show an overall picture of possible source duction methods. The s ~ m m u y can be used to plan the implementation of waste minimization options.

Fill in the "Source Reduction Alternative" column with the Source Reduction Method sheet information that have mostly "yes" acmss the sheet

You m y need to make additional copies of this checklist beforc fiIIing it out

6 1 n I

B-50

Attachment 15 IlMPLEMENTATION PLAN FOR SOURCE REDUCTION

METHODS FOR SOLVENT WASTES

PARKS AND RECREATION DEPARTMENT

A large number of source reduction opportunities have been identified for solvent wastes from parks and recreation department activities. A large number of opportunities to reduce hazardous wastes through housekeeping and inventory controls or material substitutions have been identified. Most of these can be implemented in the short-term simply by identifying the problem to the appropirate personnel. A schedule for implementation is presentated in Table 1.

Long-term goals incude development of an employee incentive program to encourage employee involvement in hazardous waste source reduction and involvement of employees in source reduction conferences. A committee to develop an employee incentive program will be formed by October 7, 1991. The committee will be charged with developing a program by January 1, 1992. Employees will be encouraged by supervisors to attend appropriate source reduction conferences. The safety manager will be charged with notifying supervisors of upcoming conferences.

IJ- 51

8-19-91

9- 16-9 1

9-16-91

9-16-91

Table 1 Implementation Plan for Solvent Waste

Parks and Recreation Department

Source Reduction Method

Housekeeping and inventory controls

Substitution of nonhazardous or less hazardous materials for hazardous materials and onsite/o€fsite recycling

Housekeeping and inventory controls,

Housekeeping and inventory controls

~~

Substitution of nonhazardous or less liazardous materials for liazardous materials.

Implementation Plan

Supervisor will send memo to all staff outlining appropriate housekeeping and inventory procedures to reduce hazardous waste. Use source reduction ;ummary checklist as a guide. Procedures will be implemented immediately.

Purchasing officer will contact vendors to solicit information about possible substitutions. Purchasing Dfficer and safety manager will meet within 1 month to discuss options. New materials will be phased in by B192.

Safety manager will submit budget request for formal training programs in hazardous waste management and source reduction.

~ ~

Safety manager will set up interim training classes for ' personnel in hazardous waste storage areas. Training should include storage area design and waste segregation. Training will begin within 6 weeks and be completed within 3 months.

Purchasing department will form a committee to develop purchasing procedures for maintaining inventory control, recommending material substitutions, and material trading between departments. Committee will meet every 2 weeks. Procedures should be complete within 3 months.

u\O32245\WM\610 OJIASI

1 ' 1

Appendix E HAZARDOUS WASTE

ASSESSMENT QUESTIONNAIRE

-

Figure E-1 HAZARDOUS WASTE ASSESSMENT QUESTIONNAIRE

Sheet 1 of 4

1. GENERAL INFORMATION

DcparuncnI/Divison Namc:

DepartmenVDivison Address:

DepartmenVDivism Phone: ( )

Contact: Title:

Description of Operations: F w

Number of Employees:

2. CHEMICALS USED

chemical us Quantity stored


Sheet 2 of4

3. HAZARDOUS WASTE GENERATED

lhulww? source

4. WASTE STORAGE

lhulww? Storaee

Physical sku

Length of SLorarre

Generation u


Sheet 3 of4

5. ONSITE TREATMENT (e.g., neutralizing acids or washing rags at your facilit)

End Produc~s DRuLlmk Trealmenl Freauencv fshlaQw

6. OFFSITE TREATMENT (e.g., recycling oil offsite, sending used rags to and offsite recycler).

Who/ DEaLWw auantkv Treaunent Where

d 0 d

cr

d

I

d

Appendix F SOURCE REDUCTION CHECKLISTS

IIA'le:

EVALIJATOR:

IIUPARTMBNl

WAS= STREAM:

CHECKLIST \ \ SOURCE REDIJCTION MWHOU NO. 1 A HOUSEKEEPING OR INVENTORY CONTROL

Page I of 9

ARE WE DOING THIS NOW? -

REDUCTION NIA

Will lhb reduce amounl

=IC?

I - Is lhls

Wlll thk easily done?

kss (cehnbl make ms(c (no


Wlll (his k safe lor workerst

Will (his glve an

product Is lhk

Wlll lhk mull in annual

W I SeVingS?

I I Can Ihb

Wlllwebc bcdone abk lo do wllhoul

(his hlrlng Can we

Ilih? I Iny

HOUSEKEEPING

YeS Yes. No YeS YeS YeS YeS YeS YeS YeS Yes - washdown immediately required

DUPAHTMENT:

WASTE STREAM

from accumulat-

devices to collect

men1 CIC. so

Kwer or storm

CHECKLIST

SOURCE REDUCTION MFI1IOD NO. I \ HOUSEKEEPING OR INVENTORY CONTROL

P a p 2 u 1 9 I

I ARE WE DOING THIS NOW? ANSWER "YES" OR "NO"

tA03224S\WM\6l0_ooZ.S 1

-

No

f

DATE.

EVAl.UA’IOR

DEPARTMENT:

WAS’ZE STREAM:

ARE WE DOING THIS NOW?

CIIECKLIST

SOURCE REDUCTION MhTIIOD NO. I \ HOUSEKEEPING OH INVENTORY CONTROL

i”W 3 of Y

WlIl lhb reduce

amount of (IpRle?

Will thb llvLc waste

kss hazardous?

Will lbb be sale lor workers?

ANSWER YES“ OR “NO“

Will lhls &e an equal

quality producl

or service?

Is lbk kgsl?

Will lhls mull in annual

CoBt

savings?

. Can (hlo 1 Willwebe bedone

abk (odo without lhls illdry

wilhoul someone new wllh

employee experkme training? in ILW.?

Can we begin doing this? IInq why nol? II yes, when?

DXII i:

EVALUATOR:

DEPAI~rMI;Nl

WASTE STREAM:

SOURCE REDUCTION

ALTERNATIVE

Keep spill response material t onsite

Segregate wastes and materials according to hazard classes

I lave an official training program for all employees involved w,ith hazirdous materials (including spill =pori=)

\ CHECKLMT

SOURCE REDUCTION MhTIIOD NO. I BOUSEKEEPINC O R INVENTORY CONTROL &

I ARE WE DOING THIS NOW? ANSWER 'YES" OR "NO"

Will this reduce

amoun1 NIA ofwnsle?

1

I Is this

Will thls be smfe lor workers?

Will thin give an equal

quality prOdUet

or servke?

Is lhls kb.p

Will we be abk lo &

lhls without

new employee (mining?

Can (his be done without hiring

someone with

experkme in ILW.?

I .AO3224S\WM\slO-Oo2.5 I

I I I

Can we begin doing this? If no, why not? If yes, when?

DATE:

EVALUATOR

DEPARTMENT:

W A S E STREAM.

REDUCTION ALTERNATIVE

\ CHECKLIm

\ SOURCE REDUCTION MmHOD NO. I HOUSEKEEPING OR INVENTORY CONTROL &

ARE WE DOING THIS NOW? ANSWER 'YES" OR "NO"

. No I NIA

Pare 6 of 9

amount

amount of male-

hamdous mrte-

I liondates 1 1 1 I

7- Will thb

be safe for workers?

INVENTORY CONTROLS

Will this mull In annual

COS1

S9ViIPgSf

Wit1 we be able (0 do

thIs wilhout

new

training?

Can this be done W i l h o l l l

hiring sonuone

wlfh experknee in II.W.?

Can we begln doing ullb? If lM&

why nol? I f yes, when?

I ,~03224S\WMWlO-Oo2.S1

DATE:

EVALUATOR:

DEPARTMENT:

WASTE STREAM.

SOIIRCE REDUCTION

AIXKRNATWE

Foil~nv up with employees regarding status of hazardous materials near expiration date

Implement waste exchange program within department and within City

Don't mix chlorinated brake nuid with used oil

Return unused hazardous materials or samples to vendors

CHECKLIST \ \ SOURCE REDUCTION METHOD NO. I

HOUSEKEEPING OR INVENTORY CONTROL & I'ree 7 of P


Will Ulb teduec amount

n l waste?


Will this give an

Is thb qual Will this easily done? quality

nuke wde (no Will this product lcss technkal k d e lor or

huzardouv? obslreks) workers? m l c e ? Is thb @I?

Will (his result In annual

cos1 savings?

Csn this Wlllwebe bedone abk bdo without

this hiring without someone

n m with employe experlrnce training? In Ii.W.?

<'an we begin doing this? II nu, why not? IC yes, when?

IA032245\wM\610-OO2.5 1

EVALUATOR

DEPARTMENT:

WASTE STREAM:

SOURCE REDUCTION ALTERNATIVE

Make rrrangc- ments lo return unused hazardous materials and ni!pIy containers io rciihr

Register all haurrdous materials hrought onsite by vendon, contractors. elc. through centralized svstem

Include contract language requiring vendon and mn-

ter hazardous materials and be responsible for removal

triiclon to regis-


CHECKLIST \ \ SOURCE REDUCTION MEI'HOD NO. I

HOUSEKEEPING OR 1 " O R Y CONTROL

ANSWER YES" OR "NO"

Will ulls res" In anneal eosl

savings?

Will we be *bdo

lhls wlthout am

emplorcc tmlnlng?

Can thb be donc wlthoul h!ring

rvllh expcrkIlW In H.W.?

S O m "

Can we

w n dfJhl this? IC no, whynot? If yes, when?

I

DATE

EVALUATOR

DEPARTMENT:

WASTE STREAM:

CHIEKUST

SOURCE REDUCTION MlWHOD NO. 1 \ HOUSEKEEPING OR INVENTORY CONTROL & Page 9 of 9 -

ANSWER "YES" OR "NO" ARE WE DOING TRIS NOW?

Is lhb errlly done?

(no kchnkal

Will lhlp be d e hr rrorkem?

Will lhls glvt an equal qmllly pmducl

or scnke?

Is lhlp -I?

.Will lhls resull In annual

COS1

Wlll w t bc ablelodo

(his wllhoul new

emPb= Cralnlng?

Can lhls be done wllhoul hlrln8

someone wlth

expcrlence In H.W.?

Comments:

I N/A = Not aoolicabk

Can we begin dolng lhls? Ifno, why nol? If yen, when?

LA032245\WM\6 IO_OO2.5 1

DA'IE:

EVA1 IJA'I'OH:

DEPARTMENT

wASIEmEAM

SOURCE REDUCTION MeFIlOD NO. 2 SUBSTITUTION OF NONHAZARDOUS MATERIALS

Page 1 of 3 I

ANSWER "YES OR "NO"

Can lhis k done

ntlborl hWng

with upcrknce In H.W.?

MInu?aIIc

Can we

ddng thls? IC no, why

not? If yes, when?

7 c c

DtiPAIWMENIS.

WASTE STUEAM:

SOIJRCE REDUCTION

ALTERNATIVE

Buy nonhazardous materials by using 'l'iihle 7.1, Section 7.1.1 lo select appropriate substitutions for hazardous materials specific to your facility.

Implement employee incentive program for substi- t ution suggest ions

CHECKLIST

SOURCE REI)IJ<TlON MEIIIOI) NO. 2 SUBSTITUTION OF NONHAZARDOUS MATERIALS


Yes No NIA

v Page 2 of 3

ANSWER "YES OR "NO"

Will this reduce

amount of waste?

Is lhlp

Wlll IhJs

lechnical Will this be safe for workers?

Will thls give an equal

quaiity pradwt

or senke?

Is this

Wlll thls result In annual -1

Wlll we be sbkbdo

thls without

new employee

Can thk be done

wlthout haring

sonitone with

experknce In II.W.?

Can we

w n doing this? It no. why not? It

yts, when?

L+AO32245\WM\610_002A.5 1

DATE:

EVALUATOR

DEPARTMENT:

WASTE meAM:

CHECKLISF

SOURCE REDIJCTION METllOD NO. 2 SUBSTITUTION OF NONHAZARDOUS MATEWIALS

SOURCE REDUCTION

ALTERNATIVE

Comments:

N/A = Not applicable

I ARE WE DOING THIS NOW? ANSWER "YES" OR "No"

Can this be Wlll this Wlll we be done

-w cg-1 WUI (his *is hiring Is thb glve an .bleb& without

Wlll thLs Wlll lbls &nr? q-119 nrrlt in wlulou~ someone d u m ? "tcrrrs(t (no Wlll ulb proauec mmul new with

atnoant kss technkal besaklor or lsulls cosl emplgcc cxpc*- Yes No N/A o l w a l t t burdous? obstades) workem? senke? legal? SSVID~S? tmlnlng? lnII.W.?

6

DEPARTMENT.

EVALUATOR WASTE mEAM:

I SOURCE REDUCXION MEIWOD NO. 3

SUBSMTUTION OF A MATERIAL THAT REDUCES VOLUME OR TOXICITY

Page 2 of 3

M E W E DOING THIS NOW? ANSWER "YES" OR "NO"

Coo we W o dolnll

Ihlr? If no. w'trl wl? If

y* rhea?

WIU Ihls redKc "oI d mar?

Wlll Llr bcuklor workem?

SOURCE REDUCIION REDUCIION

No

Implement emplslcc inantive proyam for rubtitution

mteriab rather than water-baaed non-

I

DATE:

EVALUATOR:

DEPARTMENT:

WASTESTREAM:

SOURCE REDUCTION MmIIOD NO. 3 SUBSTITUTION OF A MATERIAL THAT REDUCES VOLUME OR TOXICITY

SOURCE REDUCTION

ALTERNATIVE

I I AREWeDOlNC TIIIS NOW? ANSWER "YES" OR "NO"

Comments: r II I

I

1 NIA = Not applicable

DEPARTMENT:

EVALUATOR WASTE STREAM:

CHECKLISF

SOURCE REDUCTION MEI'IIOD NO. 4 ONSITE KFA=yCLINC OW TREATMENT

Page 1 of 2

ARE WE DOING THIS NOW? ANSWER "YES OR "NO"

Can (his be done wilhoul hiring

mnicone with

exprrkncc in H.W.?

Can we

doing lhb? If no, why nol? I f

yen, when?

k i n Will (his give an equal

quaii(Jr produei

or scrvke?

Wlll we be 8bk lo do

lhis wilhoui

cniployec llcw

training?

Will lhb rcsull in annual

COS1

Wlll Ihb nuke nolc

kss hmardous?

SOURCE REDUCHON

ALTERNATIVE

Will lhb be safe for Is lhb

ksrlt

Use (waste stream) repeatedly, filter M

settk out solids

Purchase rrcyclablc materials instead of nonrecylabla

Recycle empty containers

Obtain variance from Stale uf California EPA from classifying onsite recycling or waslc lmtmcnl as harantous

L~032245\WM\610-Oo2C.S 1

EVALUATOR.

DEPARTMENT:

WASTE STREAM.

CHECKLI!ST

SOURCE REDUCTION METIIOD NO. 4 ONSlTE RFXNCUNG OR TREATMENT

Page 2 of 2

I ARE WE DOING I THISNOW?

reduce

ALTERNATIVE No NIA wasle? REDUCTION amount 01

Wlll lbh nNke wmte

km hazardous?

ANSWER "YES" OR "NO" c WIU lhls

be r l e lor

Wlll (his glve an equal q-lltr prodwl or

Can lhls be done wllhoul hlrlng

someone with

experknee In H.W.?

Can we kg ln bb

thh? lr w, why not? I1 w

wheu?

t3"ents:

N/A = Not amlicable

LAO3224~WM\610_oO2C.5 1

P i;;;

DATL

EVALUATOR

DEPARTMENT:

WASTESTREAM:

SOURCE REDUCTION

I ALTERNATIVE

b u n k all oily or

tainen back to

CHECKLI!TT

SOURCE REDUCI'ION MFIHOD NO. 5 OFFSITE RECYCUNC OR TREATMENT

@@ @ @ @ Paee 1 of 3

I ARE We DOING THIS N O W ANSWER "YES" OR "NO"

Can lhb be done without M m J

rlth apt*- In H.W.?

momeoM

DEPAH'rMENI':

WASTE STREAM:

Will thls give an eqwl

quality productor

scrvicc?

1 CHECKLIW f m

I s l h l s legmi?

SOURCE RRDUCTION MEWOD NO. 5 OFFSITE RECYCLING OR TREATMENT

Page 2 of 3


Will this reduce

amount or WPSM

Will thls M L C Wask

lcss hazardous?

Is this CrSrIy done?

(no technical obslacks)


Will thls be =re for workers?

Will this result In mnnual

cost savings?

Will we bc oble to do

wilhout

employee training?

Can this bc done without hlrlng

someone with

expcrlcnce in II.W.?

Can we

k i n dolng

this? I C nu. why not? I f

Y- when?

LA032245\wM\610_002D.5 1

D A 1 E

EVALUATOR

DEPARTMENT:

WASTE STREAM

SHJRCE REDUCTION MICTIIOD NO. 5 OFFSITE RIKYCLING OR TREATMENT

m @ @ @ Page 3 of 3


No NIA

Wlll lhls


1

unused materials

Can lhls Wlll we be be done abkbdo without

Will Ihh thb hlrlng mull In wlthout someone mnnual new with

cas1 employee experience MVIII~S? lmlnlng? In II.W.?

N/A = No1 rpplicahle

LA03224nWM\610_002D.5 1

I~ I

DATE:

EVALUATOR:

Will this result In annual

cost savings?

DEPARTMENT:

WASIE STREAM:

Can this Will we be be done Can we abk to do wilhout b i n

l h k hiring do@

new with w why without someone this? i f

employee expcrlcnce not? I f training? in H.W.? yes, when?

SOURCE REDUCTION

ALTERNATIVE

Discontinue unnecessary maintenance (e.g., excessive vehicle washing, etc.)

On an annual basis, evaluate need for processes that use hazardous materials

Attend source reduction conferences to find out what else can be done

~ _ _ _ _

Contact govemment agencies and trade associiitions for help in idcnti- fying new procesxs

CHECKLIST

SOURCE WEDII<TI‘I(IN M P X i i O D NO. 6 REEVALUATION OF PROCESS ELIMINATION

I ARE WE DOING THIS NOW? ANSWER YFX” OR “NO”

Will t h k be safe for worlrtro? -

Will this give an equal

quality

or scrvke?

prodllet

I .A03224S\WM\610_002t3.5 1

I i l

I)I<PAKPMRNl - WASTE STREAM

Contract out certain processes thiit

contractors who

(Note: Ihk optlon does not reduce

W H S ~ p*iwnted, and should only be chosen aner all o lhr r alh?motivcs

AWP WE IWING THIS NOW?

CHECKLIST

SOURCE REDIICTION MmIIOD NO. 6 REEVALUATION OF PROCESS ELIMINATION

Wi l l Ihb reduce

amount of wash??

Wlll lhb make waste

less hazardous?

Is lhb e d l y done?

(no Iechnkal obshcks)

ANSWER YKS" OR "NO"

Wl l l (his bc smk tor worlcrs?

Wlll this glve an equal

q u l i t y pruduct

or scrvke?

Wi l l lhis result In annual

cos1 savlngs?

Will we hc ahk 80 do

thb wlthoul

new eniplnyee Iralnlng?

Can this be done wll hout hlrlng

someone with

cxperkncc in Il.W.1

Cion w t hegln dnlnp.

Ihls? I f nn. why nnl? I f

yes, when?

I 1 1 I 1 I

DA'IE.

EVALUATOR

DEPARTMENT:

WASTE STREAM:

.SO1 JRCE REDUCTION

ALTERNATIVE

Comments:

SOURCE REDUCTION METHOD NO. 6 REEVALUATION OF PROCESS ELIMINATION

Pane 3 of 3

I ARE WE DOING THIS NOW? ANSWER 'YES" OR "NO"

Is lhls legal?

Wlll (his mul l la nnnunl

cos1 wvlngs?

Can lhls Wlll we he be done Can we

abk lodo wllhoul W n (his hiring dolng

wilhoui someone lhls? If nm with no. why

employee experience not? If lrnlnlng? In II.W.? yes, when?

I

N/A = Not applicable

LAO32245\WM\610-002E.S 1

I , I

I

Appendix G SOURCE REDUCTION

SUMMARY CHECKLIST

'Ibis pngc is htcnded to summark all viable source reduction dtunatives for your facility. This summary will show and ovQafl picane of possible source reduction methods. The summary can be used to plan the implementation of waste minimizatiocrop~

You may necd to make additional copies of this checklist before filling it OUL

SOURCE REDUCTION SUMMARY CHECKLIST

source ReductiCWl Method Imptementltion

SOURCE REDUCTION ALTERNATIVE Numba Due commenu

commaus:

Fill in thc "Source Reduction Altanative" column with the Source Reduction Method sheet infamarion that have mostly "p" llcfosT the sheet

Evaluator (s):

-= G- 1