In the first part of this series, which appeared in the April/May 1998 issue, we discussed the identification and classification of hazardous waste. In this article, we’ll look at the classification of waste generators and waste-handling techniques and provide tips on preparing for an emergency and choosing a disposal firm.
Conditionally Exempt Small-Quantity Generator (CESQG)
Small-Quantity Generator (SQG)
Large-Quantity Generator (LQG) (Some states do not distinguish between CESQGs and SQGs) To determine which category describes your status, you must measure the wastes listed below on a monthly basis:
Hazardous wastes generated that have accumulated on site.
Hazardous wastes generated and transported off-site for treatment, storage or disposal.
Hazardous sludges or water removed from fuel or waste oil storage tanks.
Used waste oil that has been mixed with a listed hazardous waste.
Used waste oil that is not to be recycled.
Waste water in rack or lift pits, and oil/water separators that have hazardous waste in them.
Sludges from floor drains or traps that have hazardous wastes in them. Do not include any specifically exempted materials (such as lead-acid batteries) that will be reclaimed, used oil that will be recycled under the used-oil provision or materials that are reclaimed continuously on site without storage, such as antifreeze recycling.
It’s possible that you could fall into one of three categories:
Don’t waste these tips
How do you manage hazardous and special wastes? Keep the following tips in mind. To ensure proper handling of your wastes, read and follow all applicable federal, state and local regulations.
Used oil that is recycled, re-refined, reprocessed or burned for energy is exempt from federal rules for classification as a hazardous waste. Keep your collection tanks or drums closed and labeled, in good condition and secure. Inspect frequently for leaks, corrosion or spillage. Never mix other liquids such as solvents, flammables, antifreeze or water with used oil. Do not dispose of used oil in sewers, drains, waste dumpsters or on the ground, or use as dust or weed control. Have procedures that minimize spillage on the shop floors. Immediately clean up all spills of used oil. Use a transporter who is properly licensed and registered with the state. Keep a record of all used oil generation and disposal.
Used oil filters
Properly drained used oil filters are not subject to federal hazardous waste rules. EPA defines proper draining of filters as: Puncturing the filter dome and draining hot — at above room temperature to near engine operating temperature. Filters should be drained for a minimum of 24 hours. Be sure to check state regulations and local landfill bans.
For waste antifreeze, the regulatory or best-management requirements are as follows: Store used antifreeze in an appropriate container. Keep the container closed, labeled and secure. Inspect frequently for leaks, corrosion or spillage. Label container with the words "Used Antifreeze." Never mix other liquids such as oil, solvents and flammables with used antifreeze. Used antifreeze should be recycled. Keep a file of all waste antifreeze generation and disposal records.