ohio

Distribution of the Uniform Hazardous Waste Manifest in Ohio

In an earlier article I summarized the responsibilities of a hazardous waste generator for the completion and distribution of the Uniform Hazardous Waste Manifest (Manifest).  Read: Use and Distribution of the Uniform Hazardous Waste Manifest.  That article dealt only with the Federal regulations of the U.S. Environmental Protection Agency (EPA).  In this article – and those that follow – I will detail the requirements of individual states regarding the distribution of the Manifest.  Since the regulations of a state with an authorized hazardous waste program must be at least as strict as those of the EPA and can be more strict (state regulations can’t be less strict than Federal regulations), state regulations may require more than those of the EPA.

In this article:  Ohio!

State regulatory agency:Logo for Ohio EPA

Ohio Environmental Protection Agency (Ohio EPA).

Manifest copy distribution in Ohio:

  • Page 1 (top copy): “Designated facility to destination State (if required)”.
  • Page 2: “Designated facility to generator State (if required)”.
  • Page 3: “Designated facility to generator”.
  • Page 4: “Designated Facility’s copy”.
  • Page 5: “Transporter’s copy”.
  • Page 6 (bottom copy): “Generator’s initial copy”

State requirements to modify the EPA-required manifest copy distribution outlined above:

None.  The Ohio EPA does not require the designated facility to submit copies to it no matter if the designated facility is within Ohio (page 1) or out-of-state (page 2).  Pages 1 and 2 are not required to be used by either EPA or Ohio EPA and therefore will likely be retained or destroyed by the designated facility.

Additional state requirements for the management of the uniform hazardous waste manifest:

None.  Ohio EPA follows the Federal rule for the Exception Report.  And, Ohio EPA also follows the Federal rule for the Waste Minimization Certification.

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Q&A: Disposal of Used X-Ray Lamps

This question was posted on a Yahoo Group, of which I am a member, back on January 22, 2016:

A very happy Friday to all.

Here is an interesting one.

I have five used X-ray Lamps to dispose of.

Ohio makes this difficult.

The Ohio Department of Health claims that Ohio EPA has declared the lamps a Hazardous Waste.

They actually state that the lamps con only be disposed of by “approved Vendors”.

They have a web page with a list of these Vendors.

These vendors are running a scam by way overpricing the disposal citing ODH, Ohio EPA rules and requirements.

I have seen prices from $125.00-$425.00/lamp.

This is complete Client Abuse.

Ohio EPA has no idea what ODH is doing about this.

The lamps are not a Hazardous Waste. (Ohio EPA confirms this)

The lamps are X-ray emitters only if energized.

There is no lead.

We might have silver since the electrical contact need to be of a higher temperature material than lead.

We might have a beryllium ring as part of the structure.  This is not a hazardous waste nor is it dangerous unless we have the dust form.

The lamps have one of the noble gasses inside and they are under pressure.

Dropping or banging one can cause the lamp to shatter and explode.

I am looking for a vendor that can dispose of the used X-ray lamps in a safe and economical manor.

Any ideas would be useful.

I had five lamps, this is down to four lamps and a bunch of pieces.

These puppies are heavy and slippery.

I can legally destroy these items myself.  I would rather not do that.  But I can be persuaded.

HELP!!!

Normally many others reply to these questions before I get a chance but this time I was right there with an answer:

The lamps you describe may be a hazardous waste due to the presences of silver.  The presence of a concentration of silver in the leachate (aka: extract) created by the waste equal to or greater than 5 mg/L (same as parts per million) would require the D011 hazardous waste code for the characteristic of toxicity per 40 CFR 261.24.  40 CFR is the federal regulation and not the state of Ohio but Ohio EPA has incorporated this federal regulation into its own.

The presence of D011 and other toxins can be determined by analysis with the Toxicity Characteristic Leachate Procedure (TCLP).  Or, as the generator of the waste you may assume that it contains silver at toxic levels.
However, federal and state regulations allow you to manage a lamp or bulb that is a hazardous waste as a universal waste.  This article of mine summarizes the universal waste regulations of Ohio and Kentucky.
I am not certain but I don’t think the Ohio Department of Health regulates the management or disposal of hazardous waste or universal waste.  That is the responsibility of the USEPA & the Ohio EPA.
I see three options:
  1. Determine conclusively that it is not a hazardous waste.  Best outcome but may be difficult to prove.
  2. Manage as a hazardous waste.  Easiest to do but highest cost and regulatory burden.
  3. Manage as a universal waste.  Easy to do and may be an inexpensive disposal if you can find a universal waste recycler willing to take them.
I hope this helps.  Please don’t hesitate to contact me with any questions.
Daniel Stoehr
Daniels Training Services

Hazardous Waste Report Reminder for Ohio Businesses

From the Ohio Environmental Protection Agency Division of Materials and Waste Management:

In February of 2013, the Division of Materials and Waste Management (DMWM) changed the requirements for submitting the Hazardous Waste Report from annual to biennial. Generator and TSD data has since only been collected for odd numbered years and is due by March 1st for the following year. Please do not submit reports for 2014 as data for even numbered years is no longer required. If you need to submit a report prior to 2016 for the 2015 calendar year, please contact us.

However, if you normally submit other reports or data with your annual report that are not part of that report (e.g., the ground water monitoring annual report required by OAC 3745-65-94) please be aware that the frequency of these reports or data has not changed.

If you have any questions about this, or any other reporting issues, please contact Thomas Babb at 614-914-2527 or through email at thomas.babb@epa.ohio.gov

Don’t Wait! Register now for the Ohio EPA’s 8th Annual Compliance Assistance Conference

Every person (business or government agency) subject to the regulations of the Ohio EPA should attend the Compliance Assistance Conference hosted by the Ohio EPA scheduled for September 23rd & 24th.  The Conference should have something for everyone who needs to know about the environmental protection regulations of the OH EPA.  While a large part of the Conference is directed toward businesses that need to know the basic requirements of environmental regulatory compliance, the agenda also includes advanced topics such as air permitting requirements for Major Sources (Title V) and an in-depth look at the regulations pertaining to the management of hazardous waste.

The general agenda for the two-day conference covers a variety of environmental compliance-related topics, including:

  •  EPCRA, TRI and RMP Reporting
  • Air Permitting Basics and Reporting
  • Preparing for an Ohio EPA Inspection
  • Hazardous Waste Requirements – Basic and Advanced Sessions
  • Understanding Source Water Protection Areas and How to Protect Them *NEW*
  • SPCC Requirements – Basic Overview and In-Depth Course *NEW*
  • Reporting When Things Go Wrong
  • Solid Waste Basics and Recycling Opportunities
  • NPDES Permits and Electronic (e-DMR) Reporting and GIS Capabilities at Ohio EPA *REVISED*
  • Ohio EPA’s new eDoc Management System *NEW*
  • Major Source/Title V Permitting and New Source Review (NSR)
  • Effectively Communicating with Ohio EPA – Strategies for Success *NEW*
  • Storm Water Requirements for Industrial Activity *REVISED*
  • Wetland Requirements for Construction . . . and much more!

A special multi-session course is being offered this year on SPCC (Spill Prevention Control & Countermeasure) requirements, presented by an expert from US EPA.

If you require assistance completing minor source air permit applications, the Conference offers a hands-on session on this topic.

Also included new breakout sessions and new speakers to the line-up.

During the general session, business leaders will share their insight as to how they’ve gone above and beyond to meet their compliance obligations and implement sustainable business practices.

All this, and the fee is only $135/person for both days!

Be sure to attend my one day Hazardous Waste (RCRA) & HazMat Employee (USDOT) training seminar on September 25th in Columbus, OH!

Get your HazMat Employee & RCRA certification.
Hazardous Waste Personnel training, HazMat Employee Training

High-quality RCRA and HazMat Employee training

 

 

 

To view the complete conference agenda and register for the event, visit Ohio EPA’s Compliance Conference website at http://epa.ohio.gov/compliance_conference.aspx.

For more information contact:
Laurie Stevenson
Ohio EPA, Director’s Office
Deputy Director, Business Relations
614.644.2344
laurie.stevenson@epa.ohio.gov

Ohio Environmental Protection Agency Division of Materials and Waste Management

The reporting season has begun for the 2013 Hazardous Waste Report, which this year is due on March 3, 2014.  You only have four weeks to finalize and submit your reports to the Ohio EPA detailing your 2013 hazardous waste activities.  Please consider submitting your report as soon as possible. High numbers of users can slow down the posting process online causing many delays during the last week prior to the due date.  This report is required of any facility that generated 2000 pounds or more of hazardous waste (or 2.2 pounds or more of acute hazardous waste) in any calendar month in 2013.

The only changes for the 2013 report are changes to some of the Management Method Codes and to the Waste Minimization Codes.  You can see a list of these changes on pages 2 to 3, 29 to 30 and 62 in the Hazardous Waste Report Instructions. If you are filing a paper report or importing data files make sure that you are using correct and up to date codes or your report will fail data validation.

If you are considering filing electronically for the first time please make sure that the facility’s Responsible Official has requested a PIN and then associated their account with the facility once that PIN has been activated.  These activities take time to complete and waiting until the last minute may result in a late submission.  The software has many features that help you prepare the report quickly and more accurately than on paper. The software allows the user to validate some of the information provided in the report which helps to reduce the possibility of violations. It also includes the ability to copy a previous year’s report as a starting point for a new report, even if you haven’t filed electronically in the past.

If your facility’s report was filed electronically for 2011 but there have been personnel changes, it’s time to have new users get eBiz accounts and/or PINs or terminate access rights for users no longer involved with the facility’s report.  For information on removing preparers or Responsible Officials, see “Changing Roles in eBiz” on the Report web page.

If you have any questions, including questions or concerns about getting started in eBiz, please contact:

USDOT and USEPA regulations require training for personnel who handle hazardous waste or work with hazardous materials

State and Federal regulations require the training of HazMat Employees and Hazardous Waste Personnel

 

Thomas Babb, Hazardous Waste Report Coordinator
thomas.babb@epa.ohio.gov

(614) 914-2527

View the 2013 Hazardous Waste Report Reminder from the Ohio EPA here.

If you are a Large Quantity Generator of hazardous waste you will be required to submit a hazardous waste report to your state or the USEPA either every other year (biennially) or annually.  In addition to submitting the hazardous waste report a Large Quantity Generator of hazardous waste must also complete initial and annual hazardous waste personnel training for all Facility Personnel involved in the generation, handling, management, disposal, treatment, or off-site shipment of hazardous waste.  Contact me for training or for a free consultation.

The Identification and Management of Universal Waste in Kentucky and Ohio

Generator Treatment of Hazardous Waste in Ohio

In an earlier article I summarized the US EPA regulations regarding onsite treatment of hazardous waste by a generator.  The Ohio EPA have their own regulations pertaining to this subject; they largely follow the US EPA but with some important differences.

Treatment is defined in the Ohio Administrative Code at 3745-50-10(A) as any method, technique or process – including neutralization – designed to change the physical, chemical or biological character or composition of any hazardous waste to:

  • Neutralize the waste.
  • Recover energy or material resources from the waste.
  • Render the waste nonhazardous or less hazardous.
  • Make the waste safer to transport, store or dispose.
  • Make the waste easier to recover or store.
  • Reduce the volume of waste.

Pursuant to 3745-52-10(C) of the OAC a generator is allowed to treat their own hazardous waste without a permit provided they comply with 3745-52-34.  These are the standard management requirements for the accumulation of hazardous waste; they include:  labeling, closed container, onsite accumulation time limit, training, inspections, etc.  3745-52-10(C) does not specify a generator status, therefore it applies to all generators of hazardous waste:  Large Quantity Generator, Small Quantity Generator, & Conditionally Exempt Small Quantity Generator.  If treating hazardous waste, an LQG or SQG must comply with the regulations applicable to their generator status.  Where Ohio differs from the US EPA is that a CESQG that treats its waste must comply with the regulations of an LQG.

Acceptable forms of onsite treatment for a hazardous waste generator in Ohio include, but are not limited to:

  • Stabilization:  Mixing a characteristic hazardous waste (D008 Toxicity for Lead) with cement to stabilize the lead.
  • Wastewater Treatment:  A variety of methods may be used to remove a hazardous constituent from a wastestream if the wastewater treatment unit and its discharge is permitted under the Clean Water Act.
  • Neutralization:  Mixing an acidic waste (D002 Corrosivity) with an alkaline material to neutralize it, or vice versa.
  • Polymerization:  A resin (D001 Ignitable) may be mixed with its reactant to cause a polymerization reaction creating a solid nonhazardous waste.
  • Evaporation:  Evaporation of an aqueous (water-based) waste that does not contain volatile organic compounds.  Any release of a hazardous waste, such as VOC’s, to the air is disposal and not allowed without a permit.

The following must also be considered before conducting hazardous waste treatment without a permit in Ohio:

  • The waste must be generated onsite.
  • Acceptable units for onsite treatment of hazardous waste are limited to:  Containers, Tanks, and Containment Buildings.
  • The Federal RCRA air emission standards may apply, refer to:  40 CFR 265, Subpart AA, BB, or CC.
  • Thermal treatment (incineration) is not allowed.  This includes treatment at ambient temperatures, eg. leaving solvent-soaked rags to dry.  Refer to the description of Evaporation above.
  • The closed container requirements do not apply to a hazardous waste undergoing treatment in a container.

The Ohio land disposal restrictions of 3745-270 present an additional treatment standard – beyond the determination of hazardous or non-hazardous – that must be met before the waste may be land disposed.  This means that if you intend to treat your hazardous waste to make it non-hazardous you must also decide if your treatment will meet the LDR.

  • If not treated to meet the LDR:  Then the waste will have to be treated to meet the LDR’s before land disposal.
  • If treated to meet the LDR:  Then you must comply with the requirements of 3745-270, which include:
    • Develop a written Waste Analysis Plan [3745-270-07(A)(5)].
    • Comply with the notification and certification requirements [3745-270-07(A)].

This information is based on the regulations of the Ohio EPA, the Federal regulations and those of your State will differ.  Check with your State for its interpretation of these regulations.

Additional information is available from the Ohio EPA:  DHWM Guidance Document – Generator Treatment.

As always, please don’t hesitate to contact me if you have any questions about the RCRA regulations (Federal or State) or those of the US DOT for the transportation of hazardous materials.