Best Management Practices (BMPs) should be thought of as “good housekeeping” practices. Listed below are several procedures and ideas to operate a facility and minimize the risk associated with hazardous materials/waste management. They are written to assist marine repair facilities with compliance of State & Federal regulations.
To the right of the waste heading you will find references to the respective federal and state law. Federal laws for waste management can be found in the Resource Conservation and Recovery Act (RCRA) - 40 Code of Federal Regulations (CFR) 260-266, 268, 270-273, 279, 280-282, and 148. State laws for waste management can be found in Florida Administrative Code (FAC) 62-730 and various Florida Statutes (F.S.). State laws on waste management are typical more stringent than federal laws.
Types of Waste:
1. Lead Acid Batteries: 40 CFR 273.13 | FAC 62-730.185 | F.S. 403.8055
Batteries need to be stored on an impervious surface, in an area shielded from the weather. Best Management Practices dictate storage of batteries, indoors, on a wooden pallet over acid-resistant material. If any cores are missing caps or are cracked, place them in an acid-resistant plastic container, along with neutralizing material for leak absorption. Prevent acid from reaching soil and surface waters. This will reduce cost for contamination clean up and limit potential penalties.
If you currently use your battery supplier to dispose of spent batteries, be sure that the supplier documents the number of cores removed on your receipt. If you are not using your battery supplier to recycle batteries, you may take your used cores to a scrap metal dealer. Again, secure a receipt noting the number of cores that were recycled. Keep receipts ON SITE for a minimum of three years.
When your batteries are recycled, they are not counted towards your facility’s hazardous waste totals and do not increase your generator status.
2. Used Oil: 40 CFR 279 | FAC 62-710 | F.S. 403.7545
To ease the burden of managing too many storage containers, used oil should be stored in one above ground storage tank (AST), if possible. If it is necessary for you to use 55-gallon drums as storage containers, they must be in good condition. 40 CFR 279.22(b) states: containers and aboveground storage tanks used to store used oil at generator facilities must be in good condition (no severe rusting, apparent structural defects or deterioration) and not leaking. Drums must also be Department of Transportation (DOT) approved. Used oil containers that are not double walled must be placed within a secondary containment system. The secondary containment system must have the capacity to hold 110% of the volume of the largest container within the containment system. Your used oil containment area should have a sealed oil-resistant coating and be under cover. This will prevent rain from entering the storage area, mixing with oil and, subsequently, becoming contaminated. Make sure that all containers are capped when you are not transferring used oil from temporary containers. This provides additional assurance that water will not enter the container and contaminate the oil.
The storage container and any fill pipes to the storage container must be labeled “Used Oil”. The “Used Oil” signage must be visible from all approaches on the container (i.e. on each side). If you are using drums, each individual drum must be labeled. Receipts from the used oil hauler must be kept on site for a minimum of three years. When selecting a used oil hauler, be sure to check with the Florida Department of Environmental Protection about the company’s record of compliance.
3. Parts Cleaning Machines: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
There are a multitude of choices when it comes to parts
washers. The most regulated systems are those that use chlorinated solvents or chemicals with low flash points. It is advisable to investigate other non-hazardous systems. The less regulated systems may allow you to manage your parts washing operations without relying on another company to haul the waste away monthly. This may reduce the amount of waste that you haul monthly, thereby reducing your generator status and lowering your level of regulatory requirements (saving time and money).
If it is more cost effective for your business to utilize a parts washer with a low flash point, there are some options to reduce your waste generation.
· You can reduce the amount of liquid in your parts washer and shorten the interval between hauling to accomplish this. This is important because of the way generator status is calculated.
· For instance, if you have a 30-gallon parts washer hauled every three months, you will be a Small Quantity Generator (SQG). A SQG is defined as a business that generates between 220 – 2200 lbs. of hazardous waste in a given month. A 30-gallon parts washer exceeds 220 pounds. Unfortunately, the regulations do not allow for the fact that it took your business three full months before the liquid became a waste. Once the parts washing solution can no longer be used it is a waste and counts towards that month’s hazardous waste generation. Once you become a SQG, your business is subject to a higher level of regulation.
· A solution to this dilemma is to reduce your parts washer to a 15-gallon size and increase your hauling to once every six weeks, if necessary. This could reduce your business to Conditionally Exempt Small Quantity Generator (CESQG) status provided that waste from other waste streams does not exceed the monthly 220lb limit, and will lower the amount of regulatory requirements you are required to comply with. A CESQG is defined as a business that generates less than 220 lbs. per month of hazardous waste.
Additionally, if you use mineral spirits to wash parts AND your business is defined as a CESQG, FDEP states that you may place mineral spirits in with your used oil. Written permission from the used oil hauler must be kept on file at your facility. An FDEP memo dated June 23rd 1992 states that mineral spirits can be mixed with used oil under the following conditions. (1) The mixture cannot contain more than 1,000ppm halogens and, does not exhibit the ignitability characteristic (flash point less than 140° F). (2) The mixture is not determined to be hazardous waste through laboratory testing for toxicity characteristic (heavy metals). If the above conditions are met the mixture may be hauled as used oil destined for recycling. It is never suggested to use chlorinated solvents. Chlorinated solvents can cross-contaminate your waste stream and cause recyclable waste to become hazardous waste.
Reduce solvent waste by replacing only when necessary.
Replace acetone and other solvents with non-hazardous solvents, i.e. Propylene carbonate or dibasic ester (DBE).
Recycle solvents wastes on site by letting the sludge settle to the bottom and reusing the top half that is clean.
Use a two stage cleaning process (dirty solvent first followed by a clean rinse)
Use self-closing funnels or lids, this help to reduce spills and evaporation of the solvent.
4. Aerosol Cleaners: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
There are many different kinds of aerosol cleaners that promise that they are “environmentally friendly”. Read the label and consult the Material Safety Data Sheet for the listing of active ingredients. If any of the ingredients contain the word “chlor”, the aerosol contains chlorinated solvents. Chlorinated solvents are one of the main regulated ingredients in aerosol cleaners. Avoid using chlorinated cleaners. They can cross-contaminate other waste streams. There are other regulated ingredients in products, so read labels and MSDS carefully.
Once an aerosol can is “empty”, by federal definition, it can be disposed of in your normal trash. The definition of “empty” is the point at which the atmospheric pressure inside the can is the same as the pressure outside the can, with all material dispersed. If the container cannot be emptied, it must be treated as hazardous waste if any regulated material remains inside.
You may want to look at purchasing cleaners in bulk that use reusable containers. These reusable containers can be pressurized with your own air compressor. This will save cost in purchase of materials and reduce the number of disposed containers.
5. Waste/Used Antifreeze: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
Waste antifreeze must be stored in separate waste containers and properly labeled. These containers should be marked “used antifreeze” for recycled antifreeze or “waste antifreeze” for antifreeze that is hauled as hazardous waste. Before disposal as waste antifreeze, a waste determination must be performed. This will require testing utilizing TCLP for heavy metals. Depending on the test result, it may be hazardous waste and will require you to have the appropriate hauler remove this waste with proper documentation (manifesting). Keep the receipt showing proper disposal for a minimum of three years.
Recycling anti-freeze on site is the preferred management practice. Recycling on site reduces your monthly hazardous waste totals and can minimize the regulations that you are required to comply with by reducing your generator status. Recycling on site is done three different ways depending on the quality of the antifreeze and the amount generated.
(1) Antifreeze should be put back into the vehicle that it was taken out of whenever possible.
(2) Recycling this waste on site with a machine owned by the facility is another option. If you own your own antifreeze-recycling machine you will have filters that will need to be changed occasionally. These filters build up heavy metals over time and should have a waste determination preformed on them before disposal, or simply be handled as a hazardous waste and manifested as such. A logbook should be kept with the amount of antifreeze recycled and the date, which should be kept for a minimum of three years.
(3) There are several contractors that will come to your site to recycle your antifreeze. This service works well for all types of facilities, from Large Quantity Generators to Conditionally Exempt Small Quantity Generators. Even if you decide that you don’t want the recycled product you can have the recycling contractor haul it for cheaper than it would cost to have it hauled by a hazardous waste hauler. Make sure that anti-freeze is not stored in a container that cannot be completely emptied because any sludge will sink to the bottom of the container. Once in the container, the sludge may not be able to be removed if it is a large tank. A container with a wide opening is preferred (55gal. drum with an open top that clamps on and meets DOT standards).
6. Used Oil Filters: 40 CFR 279 | FAC 62-710 | F.S. 403.7545
There are limited options available for disposing of this type of waste. You can no longer dispose of used oil filters into the solid waste stream. All filters should be completely drained of any free flowing oil (crushed preferably) and placed into a marked container with a secure lid.
You can dispose of these filters in two basic ways:
(1) After containerizing the filters they can be hauled to the Waste to Energy facility
(2) You can contract with a hauler to have them haul the filters to the WTE.
The recommended BMP for draining and crushing filters is to “hot drain” the filter for 24 hours. Hot draining filters will minimize the volume of used oil inside the filter, and crushing them will reduce the amount of space used in the container. This can save you quite a bit of money if you are having a private hauler take them. (Check with your filter hauler before crushing). Do not crush filters by driving a vehicle over them! Label all drums “Used Oil Filters” and keep all receipts from the hauler a minimum of three years to show proof of proper disposal. Store the drum with lid closed inside a containment area to eliminate contamination from rain.
7. Shop Rags: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
Do not use disposable shop rags in certain processes at your facility. If you do use disposable rags and they are contaminated, they must be hauled as hazardous waste. To avoid this problem contracting with a uniform service may be a better option for limiting your liability. Contracting with a company that will supply you with clean rags on a regular basis may be expensive, but it could save you money in fines for improper disposal of hazardous waste. These contractors are permitted by state and local agencies to wash the rags, which are considered recyclable items. Used rags should be placed into a closed-lid container, which is properly labeled for the rag service. They will then pick up and launder the rags. Make sure that you receive receipts, which will serve as your documentation. Keep all receipts for a minimum of three years. Use shop rags instead of absorbent for small drips and dribbles. Do not mix rags together with different waste into the same storage container, they may react to one another and become a fire hazard.
8. Absorbent Material: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
Absorbent materials are needed when spills occur. If your facility utilizes a rag service try to use your rags for any spills that occur. If you must use absorbent materials these materials must have a waste determination performed on them before they can be disposed. The types, and amounts of spilled material, will determine how you need to dispose of the absorbent material used. As a general rule: use absorbent materials for oil spills only, or for emergency situations where nothing else is available. Heat-treated peat moss is the preferred absorbent. Do not use absorbents for spills involving gasoline, diesel, antifreeze, battery acid etc. Absorbents will not change the fact that a spilled hazardous substance is a hazardous waste, and must be disposed of accordingly. The substance being absorbed will dictate disposal requirements. If you have further questions about this waste, please call to verify proper disposal.
9. Air Conditioning Repair: 40 CFR 82 | FAC 62-281 | F.S. 403.061
The procedure for this type of operation depends on the type of machine you have. A system that captures, recycles, and places the freon back into the system being serviced is preferable to a system that merely catches freon and places it into a container for shipment off site. A logbook should be kept on amounts of Freon reclaimed and used to charge machines. A total accounting of all Freon bought, charged into systems, and reclaimed should be a part of your everyday best management practices. Do not discharge Freon to the atmosphere.
If your current system is being upgraded be sure to recycle any mercury thermostats that are replaced.
Make sure your equipment is registered with the Florida Department of Environmental Protection (FDEP) and the employee has the proper training to perform the work (ASE Certified).
All associated paperwork for this operation must be kept on site. Any records pertaining to reclamation and disposal need to be kept on site for a minimum of three years.
10. Waste Fuel Filters: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721 OR 40 CFR 279 | FAC 62-710 | F.S. 403.7545
These types of filters can include in-line gasoline and/or diesel filters, fuel/water separator filters, and fuel dispenser filters. There are limited options available to you for disposing of this type of waste. The filters can be drained of all free flowing fuel and placed in a container that is properly marked and has a tight fitting lid to keep fumes from escaping. No filters can be disposed of in a landfill. If your facility generates small numbers of these filters you can dispose of them in the same container as your used oil filters. If you generate large numbers of fuel filters store them separately in a drum with a tight fitting lid to minimize the threat of explosion.
Drain all residues from filters. Residues from fuel filters can be disposed of in your used oil, as long as the used oil is being recycled, and does not change the ignitablity characteristic of the mixture. (Fed. Reg., Vol. 50, No.280, Nov., 29,1985,p.49179)
Label the drums Used Fuel Filters and keep the receipts from the hauler a minimum of three years to show proper disposal. Store the drum with lid closed inside a containment area to eliminate contamination from rain.
11. Fluorescent Bulbs and Devices (Thermometers, thermostats, bilge switches, etc): 40 CFR 273.13 | FAC 62-737 | F.S. 403.7186
Fluorescent bulbs/devices are considered hazardous waste because they contain the element Mercury. However, if you recycle your Fluorescent bulbs/devices, they do not qualify as hazardous. Please call the SQG program for a list of fluorescent bulb recyclers and handling instructions. Caution: if a supplier tells you that their bulbs are environmentally safe remember that they are trying to sell you a product, and that they may not be familiar with the State and Local regulations that pertain to the proper recycling or disposal of these mercury-containing bulbs. Lamps or devices with any mercury must be recycled.
Additional Fluorescent Tube Information
12. Discarded Gasoline & Diesel Fuel: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
Fuels removed from vessels that cannot be used must be disposed of as hazardous waste. This includes both proper labeling and documentation of the management activities. Waste gasoline should be stored separately form other wastes. Please consult the hauler’s list provided to you for a list of companies that can legally haul this waste.
13. Bilge Water: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
This substance could have different types of contamination, from leaking fuel lines to oil contaminated water. A hazardous waste determination must be performed to verify the management practice requirements. Dispose of properly as test results dictate.
14. Fuel Dispenser Filters: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
If you are a marina with retail sales of fuels, you must make sure that the filters on the dispensers are properly managed.
If you have a company that performs this service for you, make sure that they document proper disposal of the filters on your receipt. Make sure that you keep all receipts ON SITE for a minimum of three years.
If you perform the service yourself they can be mixed with other fuel filters, and oil filters, and disposed of at the WTE or hauled to another permitted thermal treatment facility. Fuel Filters cannot be disposed of in your dumpster.
15. Storage Areas: 40 CFR 401 | FAC 62-660 | F.S. 403.051
Due to the nature of the business, most marinas are located adjacent or close to water. It is suggested that storage areas be properly contained and monitored for all wastes generated and stored by the facility. Proper storage will save you money in clean up of discharges, potential monetary penalties, and possible employee risk associated with improper storage. For SQGs and/or LQGs documentation (logbook) of storage area inspections is required and, for CESQG’s a logbook is encouraged.
16. Paint Waste: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
Depending on the processes used in your painting service, you will have specific regulations to follow for proper management of paint waste. You should acquire a MSDS for each paint type and color that you use. This is because different constituents are used with different pigment types. Since there are so many procedures with many different variables, please contact the P² Program for assistance.
For marinas that do hull maintenance all paint scraped off hulls should be contained and tested before being disposed. A hazardous waste determination on all bottom paint that is scraped off the hull is absolutely necessary to determine what disposal method is proper.
17. Fabracation: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 | F.S. 403.721
Resin, gel coat and MEK must be disposed of properly. If the process involves a hardener and it is completely “kicked off” or hardened then solid waste disposal is allowed. If the resin does not harden completely it must be disposed of as hazardous waste.
Reduce resin waste by using flow cutters, airless sprayers and power rollers.
*Material Safety Data Sheets are a good start to determine if your waste stream will be hazardous waste. They do have their limitations if they are too vague. MSDS’s do not take into account what process or system the product may be used in or what your management practices are for preventing cross contamination. There is a free tool for you to use that should be received from your supplier of the product. Before purchasing any product, request the MSDS to see what is in it and to help avoid cost associated with the purchase, use, and disposal of the product.
Do not use any chlorinated solvents.
Do not use one container as the “catch all” for all fluid draining procedures. This can cause cross contamination of waste.
Do not store any materials/waste near storm drains, ditches, creeks, rivers, canals or any bodies of water that would be contaminated if a spill occurs.
Do not throw away or send receipts to a bookkeeper that shows your disposal of waste materials. They are required to remain on site for a minimum of three years. This includes contracts with hazardous waste haulers. If it is necessary to send to a different address, make copies for yourself.
Do not take the word of any sales person who will not supply MSDSs for the product he/she is selling. Some will say that the material is biodegradable or environmentally friendly, but the process that you use the material in may contaminate the product and cause it all to be regulated (ie. equipment degreasing and rinsing).
Do not mix any waste with another waste. This will increase your cost for disposal. The most common mistake is to mix the wrong materials together into the used oil. Check with your used oil hauler for what is acceptable to mix together into the bulk used oil container. Get this in writing from your hauler.
Do not dispose of any material into your septic system, sanitary sewer, or storm sewer. If you want to do this you must have written permission from the regulatory agency that permits that particular system. Septic System-Department of Health, Sanitary Sewers-what ever utility district you are in, Storm Sewer-Department of Environmental Protection.
Do not store hazardous waste out of containment areas. Make sure all containers are labeled properly (include dates where necessary).
Do not hesitate asking any questions when it comes to managing your hazardous waste stream. There are no dumb questions; except for the ones you don’t ask!
If you have any questions, please call the Division of Natural Resources Management, Pollution Prevention (P²) Program at (239) 652-6126. We are here to serve your interest in the proper management of hazardous waste.