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 waste management. They are written to assist mechanical repair facilities that generate similar types of materials/waste.
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 disposed. 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 (no visible leaks). 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 that uses low flash point, there are some options to reduce your waste generation. You may be able to reduce the amount of liquid in your parts washer and shorten the interval between hauling. The reason that this is suggested is 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 will reduce your business to Conditionally Exempt Small Quantity Generator (CESQG) status, and will lower the amount of regulatory requirements to which you are subject. 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 1,000 ppm 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.
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 ingredients in aerosol cleaners that make them regulated. Avoid using chlorinated cleaners. They can cross-contaminate other waste streams. There are other regulated ingredients in products, so read labels and MSDS carefully.
A container is considered empty if the pressure inside the can is the same as the atmospheric pressure outside the can, with all material dispersed. Once an aerosol can is “empty” it can be disposed of in your normal trash. 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
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 haul them as a hazardous waste and manifest 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. There is also less paperwork involved with this option. Waste antifreeze must be stored in separate waste containers and properly labeled. These containers should be marked “used antifreeze” for recycled antifreeze or “hazardous waste” 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. 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). Receipts from the recycler or the hazardous waste hauler should be kept for a three-year minimum. For facilities that recycle their own anti-freeze documentation needs to be kept in the form of a logbook with date, and amounts recycled.
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 or (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 a recyclable item. 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 wastes into the same storage container, they may be reactive 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. 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 if this material is going to the county incinerator WTE. Do not use absorbents for spills involving gasoline, diesel, antifreeze, battery acid etc. For small spills, drips and/or dribbles, use rags provided by your rag service. Absorbents will not change the fact that a spilled hazardous substance is a hazardous waste, and must be disposed of accordingly. Heat-treated peat moss and other absorbents should be used for large spills and/or emergency spills. 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. Do not discharge freon to the atmosphere. 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 for a three-year minimum.
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. 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)
Draining the filter and crushing it to minimize the amount of used fuel in the filter element is recommended. Fuel filters may be stored in the same container as oil filters and can be managed in two basic ways; they can be hauled to the WTE by you or by a licensed hauler. No filters can be disposed of in a landfill. The filters should be drained and crushed. Not only does this minimize the volume of used fuel inside the filter, but it also reduces the amount of free liquid in the collection drum for the filters. (Check with your filter hauler before crushing). 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. 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.
12. Fluorescent Bulbs: 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
*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 can 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 costs 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 wastes.
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 that show proper disposal of waste materials to a bookkeeper. They are required to remain on site for a minimum of three years. This includes contracts with hazardous waste haulers.
Do not take the word of any sales person who will not supply MSDS 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 (i.e., 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. This is only for Conditionally Exempt Small Quantity Generators (CESQG’s) Get this in writing from your used oil 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 and Rehabilitative Services, 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 Environmental Services Department, Natural Resources Division, and Pollution Prevention Program at (239) 652-6126. We are here to serve your interest in the proper management of hazardous waste.