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Page 1: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Page 2: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Introduction

Kelly Dale Taylor

Environmental Compliance Manager

Safety-Kleen Systems, Inc.

Phone: 608.298.6420

Email: [email protected]

Page 3: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Managing Waste……………

Page 4: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Is It

Page 5: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Or Is It

Page 6: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Why Does it Matter????

Hazardous Waste must be managed

differently from “non-hazardous”

wastes

It must be sent to a properly licensed

facility for disposal

It cannot be put in with “normal” trash

Page 7: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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What Agencies Decide??

The U.S. Environmental Protection Agency (EPA or sometimes USEPA)

is an agency of the federal government charged with protecting human

health and the environment

o Wisconsin is “Authorized” by the Federal EPA to enforce their regulations

(WI Dept of Natural Resources – WI DNR)

o States may adopt the federal regulations

o States may make their own laws

o These may be more stringent, but at no time can the laws be more lenient

than the federal law

Page 9: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Page 10: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Environmental Legislation

Cradle to Grave

The generator is responsible for all

waste – from the point of generation

to final disposal

Regardless of who has the waste..

Remember –

Compliance

Liability

Page 11: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Why Does Compliance Matter?

Minimizes the possibility of spills

Minimizes the possibility of

regulatory fines and violations when

your friendly regulatory shows up

Public perception; good citizen

Cost

Page 12: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Liability

• Minimize cleanup liability. If hazardous and non-

hazardous wastes are disposed improperly,

generators must share the costs of remediating

sites (“Superfund” sites).

• A company having good records of proper

hazardous waste management can reduce or

eliminate the amount of money it has to pay.

Page 13: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Environmental Legislation

Resource Conservation and

Recovery Act (RCRA) - 1976, 1984

This law focuses on the management of

hazardous waste from the point of generation

to the point of disposal ~ Cradle to Grave

Page 14: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Solid Waste is any material -- liquid, solid, or gas

–- that is ready to be discarded by the generator

The material can no longer be used for its

originally intended purpose, maybe because it

has become contaminated or has been used in

some process, it’s off-spec, out-of-date, or you

just don’t need it anymore

Page 15: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Page 16: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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What is Hazardous Waste?

Waste that has a Characteristic

OR

Waste that is on a List

Page 17: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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RCRA Characteristic Codes

Defines the chemical properties of

the waste.

Ignitability

Corrosivity

Reactivity

Toxicity

Page 18: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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A liquid with a flash point less than

140°F

Examples: gasoline, benzene,

alcohols, acetone, paint thinner

Is ignitable waste generated in your work area?

D001

FLASH POINT: The minimum

temperature at which a

liquid gives off a vapor in

sufficient concentration to

ignite if an ignition source

is present

Page 19: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Ignitable Solid

To exhibit the characteristic the waste must meet both parts of the defnition:

1. Cause fire thru friction etc.; and

2. Burn vigorously & persistently

Example - magnesium tape, and other thermally unstable solids that spontaneously ignite (includes some paint booth filters)

D001

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Page 20: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Chemical/Material Flash Point

(Typical) in ◦F

Gasoline -45

Paint /Lacquer Thinner 20 (or less)

Acetone (Nail Polish Remover) -20

Mineral Spirits (Petroleum Naphtha) 105 – 150

Diesel Fuel 126

Kerosene 100 - 162

Ethanol 62

Jet Fuel 140

Page 21: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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A liquid with a pH less than or equal to 2.0

or greater than or equal to 12.5

A liquid that corrodes steel at a rate greater

than 0.25” per year

D002

Page 22: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Page 23: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Examples of corrosive wastes:

Hydrochloric acid, nitric acid, sulfuric acid; ammonium hydroxide, sodium hydroxide

Wastes are corrosive because they are either highly acidic or highly basic.

D002

Page 24: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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The reactivity characteristic (D003) applies to

the following waste

Normally unstable and readily undergoes violent

change without detonating

–Reacts violently or forms potentially explosive

mixtures with water

–Releases toxic gases when mixed with water

Page 25: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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The toxicity characteristic (TC) is

based on the potential of a waste to

contaminate groundwater as it

leaches through a landfill

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TCLP Metals Regulatory

Level TCLP Volatiles Regulatory

Level TCLP Semi-Volatiles Regulatory

Level

D004 Arsenic 5 D018 Benzene 0.05 D023 O-Cresol 200

D005 Barium 100 D019 Carbon tetrachloride 0.5 D024 m-Cresol 200

D006 Cadmium 1 D021 Chlorobenzene 100 D025 p-Cresol 200

D007 Chromium 5 D022 Chloroform 6 D026 Cresol 200

D008 Lead 5 D028 1,2-Dichloroethane 0.3 D027 1,4-Dichlorobenzene 7.5

D009 Mercury 0.2 D029 1,1-Dichloroethene 0.7 D030 2,4-Dinitrotoluene 0.13

D010 Selenium 1 D035 Methyl ethyl ketone 200 D032 Hexachlorobenzene 0.13

D011 Silver 5 D039 Tetrachloroethene 37 D033 Hexachlorobutadiene 0.5

TCLP Pesticides D040 Trichloroethene

0.5 D034 Hexachloroethane

3

D020 Chlordane 0.03 D043 Vinyl chloride 0.2 D036 Nitrobenzene 2

D012 Endrin 0.02 D037 Pentachlorophenol 100

D031 Heptachlor 0.008 TCLP Herbicides D038 Pyridine 5

D013 Lindane 0.4 D016 2,4-D 10 D041 2,4,5-Trichlorophenol 400

D014 Methoxychlor 10 D017 2,4,5-TP (Silvex) 1 D042 2,4,6-Trichlorophenol 2

D015 Toxaphene 0.5

Page 27: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Listed Wastes

Waste Type Regulatory

Citation

Description

Non-

Specific

Sources

40 CFR 261.31

(F-List)

These are generic wastes,

commonly produced by

manufacturing and industrial

processes. Wastes on this list

include spent halogenated

solvents, wastewater sludge

from electroplating, and

treatment residues. Common F-wastes: paint

thinners, halogenated degreasers,

1-1 triclor, perc, tetracloroethylene

Page 28: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Industry and

EPA

hazardous

waste No.

Hazardous Waste Hazard

Code

F001

The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene,

methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent

solvent mixtures/blends used in degreasing containing, before use, a total of ten percent or more (by

volume) of one or more of the above halogenated solvents or those solvents listed in F002, F004, and

F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures

(T)

F002

The following spent halogenated solvents: Tetrachloroethylene, methylene chloride, trichloroethylene,

1,1,1-trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2-trifluoroethane, ortho-dichlorobenzene,

trichlorofluoromethane, and 1,1,2-trichloroethane; all spent solvent mixtures/blends containing, before

use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those

listed in F001, F004, or F005; and still bottoms from the recovery of these spent solvents and spent

solvent mixtures

(T)

F003

The following spent non-halogenated solvents: Xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether,

methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends

containing, before use, only the above spent non-halogenated solvents; and all spent solvent

mixtures/blends containing, before use, one or more of the above non-halogenated solvents, and, a total of

ten percent or more (by volume) of one or more of those solvents listed in F001, F002, F004, and F005;

and still bottoms from the recovery of these spent solvents and spent solvent mixtures

(I)*

F004

The following spent non-halogenated solvents: Cresols and cresylic acid, and nitrobenzene; all spent

solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more

of the above non-halogenated solvents or those solvents listed in F001, F002, and F005; and still bottoms

from the recovery of these spent solvents and spent solvent mixtures

(T)

F005

The following spent non-halogenated solvents: Toluene, methyl ethyl ketone, carbon disulfide, isobutanol,

pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent solvent mixtures/blends containing,

before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated

solvents or those solvents listed in F001, F002, or F004; and still bottoms from the recovery of these

spent solvents and spent solvent mixtures

(I,T)

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Listed Wastes

Waste Type Regulatory

Citation

Description

Specific

Sources

40 CFR

261.32

(K-List)

This list consists of wastes from

specifically-identified industries,

such as wood-preserving,

petroleum refining, and

chemical manufacturing. These

wastes usually include sludges,

wastewaters, spent catalysts,

and pigment residues.

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Listed Wastes

Waste Type Regulatory

Citation

Description

Commercial

Chemical

Products

40 CFR

261.33

(P, U-Lists)

These are specific chemical

products used in agriculture,

laboratories, and other

commercial operations. This list

includes chloroform, DDT, and

sodium cyanide.

Page 31: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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A single waste stream can

appear on more than one list, as

well as exhibit one or more of the

hazardous characteristics.

Generators must identify all

applicable hazardous EPA waste

codes.

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Page 33: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Page 34: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Universal Waste Rule

A waste must be a hazardous waste

before it can be a universal waste.

The Universal Waste Rules (UWR) are

intended to promote recycling as well

as proper disposal by easing certain

regulatory requirements.

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Universal Wastes

Waste is still hazardous but classified as “universal waste” as industry and EPA are better equipped to manage the waste

Provides regulatory relief

»Usually paperwork-related (i.e. manifesting)

»Don’t have to count towards generator status

»Don’t have to pay fee for UW generated

Page 36: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Universal Waste Rule

Page 37: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Universal Waste-Bulbs

State hazardous waste regulations

prohibit businesses and institutions

from disposing of waste bulbs in

landfills if the bulbs contain heavy

metals that exceed hazardous

waste regulatory limits.

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Universal Waste-Bulbs

Safe Handling and Storage

Place waste bulbs in the box in which replacement

bulbs arrived or in cartons provided by a bulb

handler or recycler.

Label cartons and boxes with the words "Universal

Waste Lamps”, “Waste Lamps” or “Used Lamps”.

Store bulbs in a safe place

to prevent breakage and

mark the storage area appropriately.

Page 39: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Universal Waste-Bulbs

“Green” bulbs may be non-hazardous, but they

still contain mercury. Mercury, even at very low

levels, can become air-borne and be deposited

into the environment, such as lakes and other

water bodies

Green fluorescent bulbs should not be disposed

as a general solid waste unless the generator can

document that the waste is non-hazardous and

contains no mercury

Page 40: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Universal Waste-Bulbs

Bulbs broken incidental to handling (accidently)

can still be managed as UW

Lamps that are intentionally crushed can NOT

be managed as UW – this is considered

treatment in most states (plus there may be

serious safety issues)

All crushed bulbs must be managed as

hazardous waste

Page 41: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Good, bad, or ugly????

Page 42: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Good, bad, or ugly????

Page 44: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Page 45: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Properly Packaged?

Photo courtesy of

Interstate Batteries

Page 46: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Universal Waste Rule

–There is no relief from required DOT

labeling/placarding

–All wastes must be packaged per DOT

requirements

46

Page 47: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Universal Waste Rule

Mercury-Containing Equipment – Mercury-containing equipment consists of devices,

items, or articles (excluding batteries and lamps) that contain varying amounts of elemental mercury that is integral to their functions.

– Some commonly recognized devices are:

» thermostats, barometers, manometers, temperature and pressure gauges, and mercury switches, such as light switches in automobiles.

Page 48: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Universal Waste Rule

Accumulation time

–Accumulate UW for no more than one year from

the date you generated or received the UW at

your site.

–Mark the UW with the generated or received

date or keep records to verify how long you

have accumulated it.

–Must be safely stored in a closed container

Page 49: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Basic Waste Requirements

WI DNR uses enforcement discretion and has reduced

regulations for:

– Used Antifreeze

» Must go for legitimate reclamation / reuse

– Scrap Electronics

» State law prohibits businesses or institutions from disposing of any

electronics that contain hazardous materials in municipal solid

waste landfills or incinerators.

» If businesses and institutions do not recycle electronic equipment,

they are subject to state solid and hazardous waste management

rules and may require licenses from the DNR for transportation

and treatment, storage or disposal of the equipment.

Page 50: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Electronics to recycle

The following electronics can no longer be put in the trash in Wisconsin, or sent to Wisconsin landfills and incinerators. These items should be reused, donated or recycled.

Televisions

Computers (desktop, laptop, netbook and tablet computers)

Desktop printers (including those that scan, fax and/or copy)

Computer monitors

Other computer accessories (including mice, keyboards and speakers)

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Electronics to recycle

Continued list…..

DVD players, VCRs and DVRs

Fax machines

Cell phones

Major appliances, including air conditioners, clothes washers

and dryers, dishwashers, refrigerators, freezers, stoves,

ovens, dehumidifiers, furnaces, boilers, water heaters and

microwave ovens

Page 52: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Liability - Regardless

Page 53: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Page 54: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Page 55: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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REMEMBER

CRADLE TO GRAVE

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Page 57: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Page 58: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Basic Waste Requirements

Used Oil Exempt from hazardous waste rules IF the waste is

reused/reclaimed

Used oil includes: motor oils, greases,

emulsions, machine shop coolants, heating media,

brake fluids, transmission fluids, other hydraulic

fluids, electrical insulating oils, metalworking fluids,

and refrigeration oils.

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Basic Waste Requirements

Used oil does not include: fuel product

storage tank bottoms, fuel product spill cleanup

material, other waste that results from oil that has not

been used, animal and vegetable oils and greases,

antifreeze, and materials used as cleaning agents or

only for their solvent properties.

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Basic Waste Requirements

Do NOT mix other wastes in with

your used oil If used oil is mixed with hazardous waste, the entire

mixture may be regulated as hazardous waste.

Used oil containing more than 1,000 parts per million

(ppm) total halogens is presumed to be a hazardous

waste because it has been mixed with listed

halogenated hazardous waste.

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Basic Waste Requirements

Do NOT mix other wastes in with

your used oil, such as: –Gasoline

–Paint Thinner

–Antifreeze

–Chlorinated Solvents

–Engine Degreasers

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Basic Waste Requirements

Do NOT mix other wastes in with

your used oil

Even if the waste is non-hazardous,

mixing it with your used oil may make it

unacceptable for your used oil hauler

This could cost you lots of $$

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Page 64: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Used Oil Filters

Wisconsin statute (s. 287.08(4m) bans

ALL “automotive engine oil” filters from

landfill disposal.

Includes any vehicle propelled by an

internal combustion engine

Example: cars, trucks, bus, motorcycle,

snowmobile, boats, planes, ATVs

Ban includes households

Page 66: Introduction...F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride,

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Used Oil Filters

Used Oil Filters from other sources such

as a hydraulic system are not covered

under the statute, but it’s recommended

they also be recycled.

WHY are these not included in the ban??????

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Used Oil Absorbents

Wisconsin statute (s. 287.08(4m) bans

ALL oil absorbent materials that contain

free-flowing oil or that may be hazardous

waste

Includes absorbent materials containing

petroleum-derived or synthetic oil from

machines and equipment used in

manufacturing and industrial operations, or

unused oil spills

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Used Oil Absorbents

There is an EXEMPTION from the ban

IF:

The oil has been drained so that no visible signs

of free-flowing oil remain in or on the absorbent

materials, AND

The oil absorbents materials are not haz waste

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http://dnr.wi.gov/files/pdf/pubs/wa/wa1503.pdf

Can an oil filter or absorbent material be

processed or recycled to the point that it

is no longer subject to the landfill ban?

The statute prohibits any disposal of used oil filters in a solid waste

disposal facility, including drained or shredded filters.

Absorbent materials that have been drained so that no visible signs of

free-flowing oil remain in or on the oil absorbent materials and that are

not hazardous waste are not subject to the ban.

Absorbents that have been laundered or cleaned to remove oils are also

allowed to be disposed of in a landfill.

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http://dnr.wi.gov/files/pdf/pubs/wa/wa1503.pdf

How can used oil filters be recycled or

managed?

Used oil filters may be drained by hot draining, crushing, or puncturing

the filters at the generator site.

The resulting oil drained from the filters has to be managed according to

the requirements in ch. NR 679, Wis. Adm. Code.

The metal filters can then be sent to a metal recycler or reclaimer. The

paper portion of the filters can be burned for energy recovery at an

approved facility.

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http://dnr.wi.gov/files/pdf/pubs/wa/wa1503.pdf

How can absorbent materials be recycled

or managed?

Some companies that supply clean absorbents pick up used oil

absorbents for cleaning and reuse.

– Used oil recovered from absorbents must be re-refined or burned for energy

recovery according to the requirements in ch. NR 679.

Granular absorbents may be recycled or burned for energy recovery at an

approved facility.

Cloth absorbent should be reused (after laundering) as long as possible

and may also be burned for energy recovery.

Absorbents may also be treated in DNR approved bio-piles.

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http://dnr.wi.gov/files/pdf/pubs/wa/wa1503.pdf

Would absorbent material used to contain

or clean up a spill of gasoline or diesel

fuel be subject to s. 287.07(4m)?

Absorbent material used to clean up gasoline or

diesel fuel is not subject to s. 287.07(4m) since the

landfill ban is only for absorbent materials

containing free-flowing oil.

A waste determination must be made

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http://dnr.wi.gov/files/pdf/pubs/wa/wa1503.pdf

Does the NR 679.81 prohibition on landfill

disposal of materials containing free-

flowing oil apply?

Yes. 2011 Wisconsin Act 152 allows for landfill

disposal of materials containing used oil as long as

the used oil has been properly drained or removed

so that no visible signs of free-flowing oil remain and

the absorbent materials are not hazardous. This is

consistent with NR 679.81(2)(b).

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You Must Store the Wastes Properly

RCRA and OSHA require that all containers used to store

waste be properly marked and labeled as soon as ANY

waste is placed in the container

– Containers must be compatible with contents and meet applicable DOT

Packaging Standards

– Containers must be marked with the words “Hazardous Waste”

– Containers must be marked with the date waste was first added to

the container

– Containers must be inspected regularly to ensure there is no leaking

or damage

– The container must be closed except when adding/removing waste

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You Must Store the Wastes Properly

– If storing in Bulk Containers (over 110 gl) –

specific secondary containment requirements

must be met

–May be subject to: » Spill Prevention Control & Countermeasure (SPCC) Plan ~ US

EPA Clean Water Act

» Storm Water Pollution Prevention Plan ~ US EPA Clean Water Act

» Wisconsin Dept. of Agriculture, Trade and Consumer Protection:

Bureau of Weights and Measures: Storage Tank Regulation

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SPCC Plan

Required if a facility has the capacity to store any

petroleum product exceeding the following quantities

1320 gallons in aboveground storage containers –

(containers less than 55 gl. capacity do not count

towards threshold)

OR

An underground storage capacity

greater than 42,000 gallons

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Storm Water Pollution

Prevention Plan

Prevents chemical discharges from entering the lakes and oceans from stormwater drains

Each facility must have its own plan

Severe fines and penalties if a discharge enters the stormwater drain.

Requirement based on SIC/NAICS code

Required by Clean Water Act

SWPPP

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You Must Store the Wastes Properly

Wisconsin does not require secondary containment for your waste drums.

Use good container management practices

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You Must Store the Wastes Properly

Keep incompatible wastes separate and on impermeable surfaces

Do not keep containers of incompatible wastes near each other. Ensure that they are labeled properly to avoid any accidental mixing.

» Do not keep containers of liquid hazardous waste on a surface that has a floor drain

» Keep hazardous wastes indoors if at all possible

» If you must keep hazardous waste outside, secure the area with a locked fence or putting it inside a locked shed. Store on containment pallets if possible

» Keep ignitable waste out of direct sunlight as well as away from the property line.

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To Tie It All Up

You must know if the waste you generate is regulated

(hazardous) under RCRA

You must segregate (keep separate) your waste streams

You must store all wastes properly (both haz and non-haz)

You must know what wastes cannot be put into the normal

trash

– Haz Waste

– Scrap Electronics

– Used Oil Filters and Oil-Containing Absorbents

– Scrap/Used bulbs and batteries

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What are typical hazardous wastes at marinas?

Leftover paint

Cleaners such as spent degreasers and aqueous

detergents

Used oil

Used antifreeze

Test tank water (if it's been tested as hazardous)

Bilge wastewater

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How can we reduce the amount of waste

generated at our facility?

Separate your hazardous and solid wastes. This will

eliminate excess volumes of hazardous material generated,

by distinguishing those that can be discarded as solid waste.

Do not mix your waste oil and gasoline.

Do not mix your cloth wipes with your hazardous waste.

Keep used Speedi-Dri separate from hazardous wastes.

Train your employees on the proper process techniques to

reduce needless spills.

Purchase only the amount of product needed.

Reuse test tank water.

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Spill Prevention

Use only containers (drums and tanks) of good

integrity

Make sure contents are compatible with the

containers

If possible, store on or in containment structures

Use good container management (keeping drums

closed at all times, keep out of way of traffic)

Employee training

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Leaks and Spills

–When a spill occurs, the

response action required to

mitigate varies depending on

whether the spill is on land or on

water

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Where Will to Spilled Material Go?

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Containment and Follow Up – Attempt to stop the release at its source

– Contain material released to the environment

– Recover or clean up the spilled material

– Clean up the spill area

– Restock Spill Kit Supplies

– Arrange for proper disposal of waste materials

– Emergency coordinator makes notifications and reports to outside agencies

– Review Emergency Response Plans to evaluate and improve response

Spill On Land Response:

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“It” Happens

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When spills reach the water, mechanical containment and recovery equipment used to collect spilled material

– Booms - contain and absorb the spilled material

– Barriers – prevent the movement and dispersing of spilled materials

– Skimmers – collect the spilled materials from the top of the surface water

– Chemical and Biological methods are federally regulated and are most often not used in fresh water environments

Spill On Water Response:

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So “It” Happened – What Else?

Wisconsin’s spill reporting regulations are located in

Wisconsin Administrative Code NR 706. The WI DNR

website contains numerous guidance documents that contain

valuable information about complying with spill reporting

requirements.

http://dnr.wi.gov/files/PDF/pubs/rr/RR558.pdf

http://dnr.wi.gov/topic/Spills/documents/coordinators.pdf

http://dnr.wi.gov/topic/Spills/Define.html

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What is a spill?

Spill are discharges of hazardous

substances that adversely impact, or

threaten to adversely impact, human

health, welfare or the environment

and require an immediate response.

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Do I have to report my spill?

Your spill is reportable to the DNR if:

you have not immediately cleaned up the spill;

Note: Has it evaporated or been cleaned up in accordance with NR700-

726?

there is an impact to human health;

Note: An evacuation is considered a threat to human health.

there is an impact to the environment;

Note: Water of the state includes a threat or spill into a sanitary sewer,

storm sewer, and/or surface water.

there is a fire, explosion or safety hazard;

Note: A slippery road condition is considered a safety hazard.

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Do I have to report my spill?

the spill was NOT released to Secondary Containment; and

Note: Secondary containment means a containment structure that is

impervious to the material released.

the spill was more than the reportable quantities listed below.

Reportable quantities (Federal CERCLA; Hazardous Substances)

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Do I have to report my spill?

If your spill is more than the amounts listed below,

you must report it to the DNR.

–Petroleum compounds

» Petroleum product completely contained on an

impervious surface

» Less than 1 gallon of gasoline or light grade petroleum

product onto a pervious surface or runs off an

impervious surface.

» Less than 5 gallons of medium or heavy grade

petroleum products onto a pervious surface or runs off

an impervious surface.

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Do I have to report my spill?

Remember, reporting a spill is always in your

best interest – it can minimize potential legal

consequences, protect you from future false

accusations, and establish a record on your

follow-up activities cleaning up the spill.

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Do I have to report my spill?

Not reporting spills is where problems start. If

you have general questions about spill

reporting, call your regional DNR office and

ask for the spill coordinator. They can assist

you in your spill-related questions.

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For Information

http://dnr.wi.gov http://dnr.wi.gov/files/pdf/pubs/wa/wa1503.pdf

http://dnr.wi.gov/files/pdf/pubs/wa/wa420.pdf

http://dnr.wi.gov/topic/recycling/bulbs.html

http://dnr.wi.gov/files/PDF/pubs/wa/WA653.pdf

http://dnr.wi.gov/files/PDF/pubs/wa/WA195.pdf

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SAFETY-KLEEN LEGACY

For 50 years, Safety-Kleen’s entire business

model has revolved around keeping North

American companies Green

Safety-Kleen is the Green Enabler by

providing its customers with sustainable oil,

waste and solvent closed-loop recycling

solutions

• Recycle valuable renewable resources

• Protect valuable water resources

• Lower greenhouse gas emissions

• Cost-savings realized from recycled

products rather than virgin products

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NORTH AMERICA’S LARGEST INFRASTRUCTURE

2 Oil Re-Refineries

20 Oil Terminals

158 Branches

9 Recycling Centers

2,900 Vehicles

1,000 Railcars

4,300+ Employees

Over 50 EH&S

Professionals

Consistent, effective solutions across the United States, Canada & Puerto

Rico through Safety-Kleen’s vast network of resources

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Madison, WI

3715 Lexington Ave

608.221.0714

Kaukauna, WI

2100 Badger Road

920.766.4266

Waukesha, WI

2200 S. West Avenue

262.549.3011

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LARGEST BASE OIL

RE-REFINER IN THE WORLD

Operated under robust technical

services and quality control

– Approximately 75% of

re-refining capacity in

North America

– Primary products are base and

blended lubricants

– Direct terminal sales of up to 51

million gallons to local fuel markets

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PARTS CLEANING

Placement, maintenance and service of

parts washers and associated cleaning fluids

– Service representatives collect used solvent

and aqueous solutions and replenish

machines at regular service intervals

– Safety-Kleen is the largest collector and

recycler of used solvent in North America

– Service more than 217,000 parts washers on

a recurring basis

– More than 755,000 parts cleaning

services annually

– On-going new product innovations with

4-in-1 aqueous technology (Q3)

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CONTAINERIZED WASTE SERVICES

Customers contract for removal of

containerized waste

– Containerized liquid and solid

materials including a variety of

hazardous and industrial wastes

– Service includes flexible collection

schedules, paperwork preparation,

container inspection and loading

– Waste is either recycled or disposed

of in accordance with regulations

applicable to the waste type

– More than 80% of all containerized

waste streams are recycled

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OTHER SERVICES

Allied Products

– Sales of complementary products to

Company’s existing customer base

– Cleaner/degreasers, glass cleaners, hand

cleaners, absorbents, mats and spill kits

– Windshield washer fluid

– Recycled antifreeze

– Penetrant & Lubricant

Other Services

– Bulk shipping

– Tolling

– Metals recovery

– Imaging

– Dry cleaning

– Sales from recovered chemicals

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Questions?