ARE YOU A

SMALL QUANTITY

GENERATOR?

Thomas C. Jorling Commissioner

MAY 1993 NYS Department of Environmental Conservation

Division of Hazardous Substances Regulation

ARE YOU A SMALL QUANTITY GENERATOR? 1

COUNTING YOUR HAZARDOUS WASTE 7

CATEGORIES OF HAZARDOUS WASTE GENERATORS 8

ACCUMULATION LIMITATION 11

STORAGE REQUIREMENTS 12

EMERGENCY PREPAREDNESS AND RESPONSE 13

YOUR EPA IDENTIFICATION NUMBER 14

THE MANIFEST SYSTEM 17

RECLAMATION EXEMPTION 20

TRANSPORT REQUIREMENTS 21

USING A HAZARDOUS WASTE BROKER 21

LAND DISPOSAL RESTRICTIONS 23

POLLUTION PREVENTION TIPS 24

TECHNICAL ASSISTANCE PROGRAMS 26

APPENDIX A 28

APPENDIX B 30

TABLES

TABLE 1: TYPICAL WASTE STREAMS GENERATED BY SMALL QUANTITY GENERATORS 4-6

TABLE 2: COUNTING YOUR HAZARDOUS WASTE 7

FIGURES

FIGURE 1: NOTIFICATION OF HAZARDOUS WASTE ACTIVITY FORM 15-16

FIGURE 2: ROUTING OF THE 8 PAGE MANIFEST FORM 18

FIGURE 3: NYS HAZARDOUS WASTE MANIFEST FORM 19

FOREWORD

In 1976, the United States Congress passed the Resource Conservation and Recovery Act (RCRA) to protect human health and the environment from damage resulting from improper handling of hazardous waste. This federal law sought to control the management of hazardous waste from its point of generation to its ultimate disposal, from cradle to grave.

Initially, the focus was on large companies which produced the greatest proportion of hazardous waste. Businesses producing less than 1000 kilograms (2,200 pounds) of hazardous waste per month were not required to comply with most of the requirements applicable to larger generators of hazardous waste.

More recently, attention has focused on potential health and environmental problems which could result from mismanagement of a large number of Small Quantity Generators (SQG) of hazardous waste, those generating between 100 and 1000 kilograms of hazardous waste per month. In 1984 Congress passed amendments to RCRA which expanded the scope of the law to include Small Quantity Generators.

The United States Environmental Protection Agency (EPA), in response to the revised federal legislation, adopted regulations applicable to Small Quantity Generators in 1986. To comply with the regulations adopted by the EPA, New York State adopted its own regulations for Small Quantity Generators.

This booklet is intended as a guide for Small Quantity Generators in New York State. It presents a description of New York State regulations, as well as some new federal regulations.

In this May 1993 edition, the following changes have been made:

- generator annual report requirement has been deleted for small quantity generators;

list of the Toxicity Characteristic Leaching Procedure (TCLP) wastes has been added;

requirements for conditionally exempt generators are described; and,

description of some other environmental programs has been added.

In addition, supplements are available for the following business types:

vehicle maintenance and repair;

dry cleaners;

printing ;

photofinishing;

degreasing and parts cleaning;

painting contractors and decorative painters; and,

x-ray development.

You may call the New York State Department of Environmental Conservation (DEC) at 1-800-462-6553 to obtain copies of these publications.

I Director Division of Hazardous Substances Regulation

ARE YOU A SMALL QUANTITY GENERATOR?

If you generate between 100 and 1000 kilograms of hazardous waste per month or store between 100 and 1000 kilograms of hazardous waste at any time, you are a Small Quantity Generator (SQG).

A waste is hazardous if it is listed in Part 371 of the NYS Codes, Rules and Regulations (6NYCRR Part 371). Even if a waste is not listed, it is still considered to be hazardous if it has one or more of the following characteristics:

Ignitability

It catches fire easily. Ignitable wastes include many organic solvents and some paint wastes and strong oxidizing agents. A liquid waste is ignitable if it has a flash point of less than 60°C (140°F).

Corrosivity

It dissolves metals and other materials, or burns the skin. Corrosive wastes include waste rust removers, waste acid or alkaline cleaning fluids, and waste battery acid. Any liquid that has a pH of 2.0 or lower or 12.5 or higher is corrosive.

Reactivity

It undergoes violent chemical reaction with water. Reactive wastes include those which can generate toxic gases or fumes.

A waste sample is tested and shows EP (extraction procedure) toxicity. EP toxic wastes contain high concentrations of heavy metals such as mercury, cadmium, lead or certain pesticides that could contaminate groundwater.

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EP - Toxicity

TABLE 1 TYPICAL WASTE STREAMS GENERATED BY SMALL QUANTITY GENERATORS*

(continued)

Funeral Services

Furniture/Wood Manufacturing and Refinishing

Laboratories

Laundries and Dry Cleaners

Metal Manufacturing

Motor Freight Terminals and Railroad Transportation

Other Manufacturing: 1) Textiles 2) Plastics 3) Leather

Pesticide End Users and Application Services

Photographic and X-Ray Processors

Solvents Formaldehyde

Ignitable Wastes Solvents

Acids/Bases Heavy Metals/Inorganics Ignitable Wastes Reactives Solvents

Dry Cleaning Filtration Residues Solvents

Acids/Bases Cyanide Wastes Heavy Metals/Inorganics Ignitable Wastes Reactives Solvents Spent Plating Wastes

Acids/Bases Heavy Metals/Inorganics Ignitable Wastes Lead-Acid Batteries Solvents

Heavy Metals/Inorganics Solvents

Heavy Metals/Inorganics Pesticides Solvents

Acids/Bases Heavy Metals/Inorganics

*Additional information on typical waste streams is found in Appendix B of this handbook.

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TABLE 1

TYPICAL WASTE STREAMS GENERATED BY SMALL QUANTITY GENERATORS*

(continued)

Printing and Allied Industries Acids/Bases Heavy Metals/Inorganics Ink Sludges Spent Plating Wastes Solvents

Vehicle Maintenance Acids/Bases Heavy Metals/Inorganics Ignitable Wastes Lead-Acid Batteries Solvents

Wood Preserving Preserving Agents

* Additional information on typical waste streams is found in Appendix B of this handbook.

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COUNTING YOUR HAZARDOUS WASTE

one 55 gallon drum = about 200 kilograms of hazardous waste

1000 kilograms = 2,200 pounds = about 275 gallons

100 kilograms = 220 pounds = about 28 gallons

To determine the quantity of hazardous waste you generate per month, refer to Table 2, which identifies which wastes must be included in your monthly tally and which wastes may be excluded from your monthly total:

TABLE 2 COUNTING YOUR HAZARDOUS WASTE

Do Count

You do count all quantities of "Listed" and "Characteristic" hazardous wastes (defined on page 2) that you:

* Accumulate on-site for any period of time prior to subsequent management.

* Package and transport off-site

* Place directly in a regulated on-site treatment or disposal unit.

* Generate as still bottoms or sludges and remove from product storage tanks.

Don' t Count

You do not have to count wastes that:

* Are specifically exempted from counting. Examples of these exempted wastes are:

spent lead-acid batteries that will be sent off-site for reclamation.

used oil that has not been mixed with hazardous waste.

* May be left in the bottom of containers that have been completely emptied through conventional means, for example, by pouring or pumping. Containers that held an acute hazardous waste must be more thoroughly cleaned.

* Are left as residue in the bottom of product storage tanks, if the residue is not removed from the product tank.

* You reclaim continuously on-site without storing the waste prior to reclamation.

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CATEGORIES OF HAZARDOUS WASTE GENERATORS

The four categories of hazardous waste generators are:

1. Conditionally Exempt Generators who meet all of the following conditions:

a. Generate less than 100 kilograms per month of listed and/or characteristic hazardous waste.

b. Generate less than 1 kilogram per month of acutely hazardous waste.

c. Store less than 100 kilograms of listed and/or characteristic hazardous waste.

d. Store less than 1 kilogram of acutely hazardous waste

2. Category 2 Small Quantity Generators meet all of the following conditions:

a. Generate less than 100 kilograms per month of listed and/or characteristic hazardous waste.

b. Generate less than 1 kilogram per month of acutely hazardous waste.

c. Store less than 1000 kilograms of listed and/or characteristic hazardous waste.

d. Store less than 1 kilogram of acutely hazardous waste.

3. Category 3 Small Quantity Generators meet all of the following conditions:

a. Generate more than 100 but less than 1000 kilograms per month of listed and/or characteristic hazardous waste.

b. Generate less than 1 kilogram per month of acutely hazardous waste.

C. Store less than 1000 kilograms of listed and/or characteristic hazardous waste.

d. Store less than 1 kilogram of acutely hazardous waste.

4. Fully Regulated Generators meet any of the following conditions:

a. Generate more than 1000 kilograms per month of listed and/or characteristic hazardous waste.

b. Generate more than 1 kilogram per month of acutely hazardous waste.

c. Store more than 1000 kilograms of listed and/or characteristic hazardous waste.

d. Store more than 1 kilogram of acutely hazardous waste

Fully regulated generators are not covered in this manual. Fully regulated generators can obtain a copy of the regulations by calling (518) 485-8988.

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CATEGORY 1: CONDITIONALLY EXEMPT GENERATORS

If your business is classified as conditionally exempt, there are only three things to keep in mind:

1. Identifying Your Hazardous Waste: Conditionally exempt generators are responsible for knowing which of their wastes would be classified as hazardous and what the correct waste codes are for the hazardous wastes.

2. Disposal: Conditionally exempt generators have several disposal options

a. Recycling the waste yourself; there are also a few treatment options such as totally enclosed treatment and elementary neutralization. Please call the Small Quantity Generator/Household Hazardous Waste (SQG/HHW) Hotline at 1-800-462-6553 if you need more information on hazardous waste treatment.

b. Send the waste to an authorized hazardous waste treatment, storage or disposal (TSD) facility. You can get a list of TSD facilities that do business in New York State by calling the SQG/HHW Hotline at 1-800- 462-6553 (in the Albany area or out of State, call 518-457-4105).

c. Take the waste to a permitted, licensed or registered municipal or industrial solid waste facility if they can take it. For example, some landfills will take dry paints and still bottoms. Sewage treatment plants may be willing and able to treat many print shop wastes. Municipal incinerators may be able to take waste materials such as paint thinners, and some solvent formulations. Prior approval from the facility is needed.

3. Transportation: Conditionally exempt generators have two options for getting their wastes to a disposer or recycler:

a. Use a NYS Part 364 Permitted Hauler

Part 364 haulers must meet certain conditions in order to receive permits: they must have a certain amount of liability insurance to cover cleanup of spills or accidents; the permits specify the types of waste that can be hauled and where the wastes may be hauled. The permits are renewed annually. You can call 518-457-3254 to find out if your hauler is permitted to haul your waste. Your local DEC office or the SQG/HHW Hotline can also help you to locate a hauler in your area.

b. Haul The Waste Yourself

If your company is a conditionally exempt generator, then you can legally haul the waste yourself within New York State. Some localities have additional requirements.

NOTE: It is both illegal and dangerous to put hazardous waste in the trash dumpster. This practice can harm the people who unknowingly handle the waste.

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CATEGORY 2 SMALL QUANTITY GENERATORS

Category 2 Small Quantity Generators must comply with only the following storage requirements:

1. Use tanks that are properly sheltered and protected to prevent spillage, seepage, or other discharge of hazardous waste into storm or sanitary sewers or into ground or surface waters.

2. Keep containers and tanks holding hazardous waste closed during storage except to add or remove waste.

3. Store containers and tanks to avoid rupture or leakage.

4. Inspect containers and tanks at least quarterly for leaks or damage.

5. Use tanks that are designed, constructed or operated in accordance with whichever the following requirements are in effect in the municipality where the facility is located:

a. The State Uniform Fire Protection and Building Code Title 9 (b) NYCRR, Subchapter C, including the National Fire Protection Association Flammable and Combustible Liquids Code (NFPA-30); or

b. The applicable building and fire codes

In addition, Category 2 Small Quantity Generators must:

1. Obtain an EPA Identification Number (pages 14-16).

2. Manifest their hazardous waste (pages 17-20).

3. Use a licensed transporter (page 21).

4. Have waste sent only to TSDFs authorized to accept hazardous waste.

5. Pre-arrange waste transport and disposal.

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CATEGORY 3 SMALL QUANTITY GENERATORS

Category 3 Small Quantity Generators must comply with all of the following requirements:

1. Accumulation limitations (page 11).

2. Storage requirements (pages 12).

3. Emergency Preparedness and Response (pages 13).

4. Obtain an EPA Identification Number (pages 14-16).

5. Manifest their hazardous waste (pages 17-20).

6. Use a licensed transporter (pages 21).

7. Have waste sent only to TSDFs authorized to accept hazardous waste.

8. Pre-arrange waste transport and disposal.

9. Land disposal restrictions (page 23).

ACCUMULATION LIMITATION

Category 3 Small Quantity Generators may store up to 1000 kilograms (2,200 pounds) of listed and/or characteristic hazardous waste on-site for up to 180 days or for up to 270 days if the waste must be shipped to a treatment, storage or disposal facility that is located over 200 miles away. Small quantity generators may store no more than 1 kilogram of acutely hazardous waste on-site for any length of time.

If a Category 3 Small Quantity Generator exceeds the 180 or 270 day limit for accumulating waste, he may request an extension. Extensions of up to 30 days may be granted by this Department if the waste must remain on-site due to unforeseen, temporary, or uncontrollable circumstances.

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STORAGE REQUIREMENTS

Category 3 Small Quantity Generators who generate 100 to 1000 kilograms (220 to 2,200 pounds) of hazardous waste per month and who store waste on-site must follow certain common sense rules to protect human health and the environment and to reduce the likelihood of damages or injuries caused by leaks or spills of hazardous wastes.

1.

2.

3.

4.

5.

6.

7.

a.

9.

If

1.

2.

3.

4.

If you store hazardous waste in containers, you must:

Clearly mark each container with the words "HAZARDOUS WASTE," and with the date you began collecting waste in that container.

Keep containers in good condition, handle them carefully, and replace any leaking ones.

Not store hazardous waste in a container if it may cause rupture, leaks, corrosion, or other failure.

Keep containers closed except when you fill or empty them.

Inspect containers for leaks and corrosion every week.

Separate and protect reactive or ignitable waste from sources of ignition or reaction.

Ensure that the waste being placed in a container will not react with the container itself or with any residue of waste previously held in the container.

Never store in the same container wastes that could react together to cause fires, leaks, or other releases.

Separate by a dike, berm, wall or other device containers of waste which are incompatible with other containers of waste stored nearby.

you store waste in tanks, you must:

Never store hazardous waste in a tank if it may cause rupture, leaks, corrosion or otherwise cause the tank to fail.

Uncovered tanks must be operated to ensure at lease 60 centimeters (two feet) of space at the top of the tank, unless the tank is equipped with a containment structure, a drainage control system, or a diversion structure with a capacity that equals or exceeds the volume of the top 60 centimeters of the tank.

Where hazardous waste is continuously fed into a tank, the tank must be equipped with a means to stop the inflow, such as a waste feed cut-off system or a by-pass system to a stand-by tank.

Discharge control equipment must be inspected once each operating day to ensure that it is in good working order.

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5.

6.

7.

8.

9.

10

Data from monitoring equipment must be gathered once each operating day to ensure that the tank is being operated according to its design.

To ensure compliance with number two above, the level of waste in the tank must be inspected once each operating day.

The construction materials of the tank must be inspected at least once a week to detect corrosion or leaking of fixtures or seams.

The construction material of discharge confinement structures and the area immediately surrounding discharge confinement structures must be inspected weekly to detect erosion or obvious signs of leakage.

Incompatible wastes, or incompatible wastes and materials must not be placed in the same tank.

Hazardous waste must not be placed in an unwashed tank which previously held an incompatible waste or material.

EMERGENCY PREPAREDNESS AND RESPONSE

Category 3 Small Quantity Generators who generate 100 to 1000 kilograms (220 to 2,200 pounds) of hazardous waste per month must also comply with the following requirements:

1. At least one employee must be designated as the Emergency Coordinator. The Emergency Coordinator must be on call or on the premises at all times to coordinate all emergency response measures.

2. The generator must post the following information next to the telephone:

a. the name and telephone number or the Emergency Coordinator;

b. the location of fire extinguishers and spill control material, and if present, the fire alarm; and

c. the telephone number of the fire department, unless the facility has a direct alarm.

3. Employees must be familiar with proper waste handling and emergency response procedures relevant to their responsibilities during normal facility operation and emergencies.

4. In the event of a fire, the Emergency Coordinator or his designee must call the fire department or attempt to extinguish the fire with a fire extinguisher.

5. In the event of a spill, the Emergency Coordinator or his designee must attempt to contain the spill and, as soon as is practicable, to clean up any resultant contamination.

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6 . In the event of an emergency threatening public health outside the facility or when the generator is aware that a spill has reached surface water, the generator must immediately notify the National Response Center at ( 8 0 0 ) 424-8802 and the Department at ( 5 1 8 ) 457-7362 with the following information:

a. the name, address and EPA identification number of the generator; b. the date, time and type of incident; c. the quantity and type of hazardous waste involved; d. the extent of injuries, if any; and e. the estimated quantity and disposition of recovered materials.

YOUR EPA IDENTIFICATION NUMBER

If your business generates more than 100 kilograms (220 pounds) of hazardous waste in any calendar month, or stores more that 100 kilograms (220 pounds) of hazardous waste at any time, you will need to obtain an EPA Identification Number. Transporters and facilities that store, treat or dispose of regulated quantities of hazardous waste must also have EPA Identification Numbers. These twelve-character identification numbers uniquely identify hazardous waste generators, transporters, and TSDFs. They allow tracking of hazardous waste from its point of origin to its ultimate point of disposal.

To obtain your EPA Identification Number, call or write the EPA Region II Office at the address given below and ask for a copy of EPA Form 8700- 12, "Notification of Hazardous Waste Activity." You will be sent a booklet containing the two-page form and instructions for filling it out. Figure 1 is a sample copy of the completed notification form to show you the kinds of information required.

Fill in the form with the same kinds of information shown in the sample form in Figure 1. To complete item X of the form, you need to identify your hazardous waste number. Appendix B contains some common hazardous waste numbers. If you do not understand the information in Appendix B, or if you cannot match your wastes with those listed, contact the Small Quantity Generator/Household Hazardous Waste Hotline at 1- 800- 462- 6553.

Complete one copy of the form for each of your plant sites or business locations where you generate or handle hazardous wastes. Each site or location will receive its own EPA Identification Number.

Lastly, make sure your form is filled out completely and correctly and sign the certification in item XI. Submit the form to the EPA Region II office. You will be assigned an EPA Identification Number unique to the site identified on your form. Use this number on all hazardous waste shipping papers. You should notify EPA at the address given below if the plant site or business location is moved or if the name of the facility changes.

EPA Region II Office 26 Federal Plaza New York, NY 10278 ( 2 1 2 ) 264-9883

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FIGURE 1

15

FIGURE 1

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THE MANIFEST SYSTEM

The hazardous waste manifest is a multicopy shipping document that you must fill out and use to accompany your hazardous waste shipments.

All categories of generators except conditionally exempt generators who do not store over 100 kilograms (220 pounds) must manifest their hazardous waste shipments. The manifest form is designed so that shipments of hazardous waste can be tracked from their point of generation to their final destination.

The hazardous waste generator, the transporter and the designated facility must each sign this document and keep a copy. The designated facility operator must also send a copy back to you, the generator, so that you can be sure that your shipment arrived. You must keep this copy, which bears the signatures of the transporter and the designated facility operator, on file for three years.

Figure 2 illustrates where the eight pages of the hazardous waste manifest are distributed. The hazardous waste manifest should be properly filled out and signed by the generator. When the transporter signs and dates the manifest he givers copy 3, 4 and 8 to the generator. The generator mails copy 3 to the state where the designated facility is located and copy 4 to the state where he is located. He keeps copy number 8 for his records. The transporter takes copies 1,2,5,6 and 7 with him to the designated facility where someone will verity acceptance of the shipment and sign and date the manifest. The representative from the designated facility will then give copy 7 to the transporter for his records. He keeps number 6 for his own records. He then mails copy 1 to the state where the designated facility is located, copy 2 to the state where the generator is located, and copy 5 is mailed back to the generator, who must retain it along with the copy 8 he already has for a period of three years.

If you do not receive a signed copy from the designated hazardous waste management facility within 15 days, you must contact the transporter and/or the disposal facility to find out why. It is important to remember that just because you have shipped the hazardous waste off your site and it is no longer in your possession, your liability has not ended. You are potentially liable for any mismanagement of your hazardous waste. The manifest will help you to track your waste during shipment and make sure it arrives at the proper destination.

You can obtain blank copies of the manifest from several sources. To determine which source you should use, use this system:

1. If the state to which you are shipping your waste has its own manifest form, use that manifest form.

2. If the state to which you are shipping your waste does not have its own manifest, use the manifest of the state in which your waste was generated.

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FIGURE 2

Routing of the 8 Page Manifest

18

FIGURE 3

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New York State has its own manifest form. A sample NYS Hazardous Waste Manifest form is presented in Figure 3. When you sign the certification in item 16 you are personally confirming that:

1. The manifest is complete and accurately describes the shipment.

2. The shipment is ready for transport

3. You have considered whether, given your budget, your waste management arrangements are the best to reduce the amount and hazardous nature of your wastes.

If you are a generator in New York State, you may obtain NYS manifest forms from the NYS Environmental Conservation Regional Office nearest to you, see Appendix A. If you are a generator outside NYS who wishes to ship to a facility in NYS, you may obtain manifest forms from the Central Office of the NYS Environmental Conservation Department by calling (518)457-6858.

RECLAMATION EXEMPTION

Category 2 and 3 Small Quantity Generators do not have to manifest wastes designated for reclamation when the waste is reclaimed under a contractual agreement if:

1. The waste type and frequency of shipments are specified.

2. The vehicle is owned and operated by the reclaimer.

3. The reclaimer complies with part 364 waste transporter requirements.

4. The generator records the hazardous waste codes, the quantities shipped, and the shipment dates.

5. The generator keeps a copy of the reclamation agreement for at least three years after termination or expiration of the agreement.

Transporters servicing small quantity generators need not manifest their shipments providing that the transporter also abides by the five requirements listed above. In addition, transporters must also record the generators EPA Identification Number. Also, the transporter must carry these records when hauling waste to the reclamation facility.

Similarly, this exemption extends to TSDFs accepting waste for reclamation. TSDFs may accept unmanifested waste for reclamation if the waste is being reclaimed in accordance with a contractual agreement. The TSDF must record the following information for each shipment:

1. The name, address and EPA Identification Number of the generator.

2. The quantities, waste types and shipment dates.

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The TSDF must retain these records for three years after expiration or termination of the agreement. Lastly, the TSDF must submit quarterly summaries of waste accepted for reclamation to this Department's Manifest Section.

TRANSPORT REQUIREMENTS

Category 3 Small Quantity Generators in NYS may accumulate up to 1000 kilograms (2,200 pounds) of hazardous waste for up to 180 days or for up to 270 days if they must ship to a TSDF over 200 miles away. Transporters of hazardous waste in NYS must possess NYS Part 364 Waste Transporter Permits and may only transport hazardous wastes to TSDFs which are authorized to accept hazardous waste. Since generators of hazardous waste may be held responsible for mismanagement of their waste after it has left their premises, it is advisable for generators to ensure that they use only duly authorized transporters and TSDFs.

Probably the best way to select a permitted waste transporter and TSDF is to contact the Waste Transporter Permit Section of the NYSDEC at (518) 457-3254. Section personnel will be able to provide you with computer generated listings of currently permitted waste transporters of designated types of hazardous waste from which you may select the transporter who is best able to fulfill your specific needs. Similar listings of TSDFs may also be obtained.

You should contact the hauler and the TSDF to verify that they have EPA Identification Numbers and that they can and will handle your waste. Also, make sure that they have current permits, adequate insurance, and that the hauler's vehicles are in good condition. Choosing a transporter and a TSDF may take some time, therefore try to begin your search well ahead of the time you will need to ship your waste.

When you prepare hazardous waste for shipment, you must put the waste in containers acceptable for transportation and make sure the containers are properly labelled. To determine labelling requirements for your wastes, contact this Department, your transporter, or your TSDF.

USING A HAZARDOUS WASTE BROKER

Many businesses use brokers to arrange the details of transportation and disposal of their hazardous waste. The broker may be independent; in other cases, the transporter or the Treatment, Storage or Disposal Facility (TSDF) acts as a broker.

Using a broker may facilitate waste disposal. However, as the generator of the waste, you retain responsibility for its transportation and treatment or disposal.

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When dealing with brokers, it remains your responsibility to ensure that :

a. You have written communication from the ultimate designated treatment, storage or disposal facility for the particular wastes being offered for shipment stating that the facility is authorized and has the capacity to accept the hazardous waste set forth on the manifest and that the facility will assure that the ultimate disposal method is followed;

b. You have written communication that the designated transporter is authorized to deliver the waste to the facility on the manifest;

c. Copies of the manifest are distributed as shown on the New York State Manifest form (described on page 15 of this manual). When an out-of-state manifest does not have sufficient sheets for full notification of shipment and receipt, make additional copies; and

d. Your shipment papers contain the notifications and certifications required by the Federal Land Disposal Regulations.

In order to ensure that your waste is handled properly, you should also consider requesting the following information or taking the following steps:

a. Request copies of all waste analyses done on samples of your wastes.

b. Request a certificate of treatment or disposal for the waste from the ultimate disposal facility; this should be consistent with the method shown on the manifest or the exception report.

c. Call the NYSDEC office in your region on a periodic basis to verify that the transporter and treatment or disposal facility have the proper waste handling permits.

d. When the hauler arrives at your site to pick up your wastes, ask to see a copy of his or her Part 364 permit. Licensed 364 haulers must keep a copy of the permit in each truck. Look for the following information on the permit:

the license plate number of the vehicle; the expiration date of the permit; the types of wastes that the hauler can take; and the companies to which the hauler can take your waste.

This information should be consistent with the information shown on the manifest.

e. Check with the Better Business Bureau or Chamber of Commerce to see if there are records of complaints or problems against the hauler or treatment facility. Your colleagues or associations may also have information about haulers or treatment facilities in your area.

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LAND DISPOSAL RESTRICTIONS

In 1984, Congress passed into law restrictions (called "Land Ban") requiring treatment of many hazardous wastes before disposal into landfills. Examples of wastes that must be treated before they can be landfilled include used solvents, metal wastes, cyanide-containing wastes, and other types of hazardous wastes.

Since November 1988, small quantity generators that generate more than 100 kilograms of hazardous waste in any calendar month have been affected by the Land Ban provisions. The provisions include:

1. Waste Analysis

Does the waste stream contain substances listed in the landban rules?

What are the concentrations of the substances in the waste?

Which landban treatment standards or prohibition levels apply?

Must the waste be treated prior to land disposal, or does it already meet the applicable treatment standard or prohibition level?

2. Notification To Treatment, Storage Or Disposal Facility

The notification must include:

the hazardous waste code(s);

the applicable treatment standard;

the manifest number associated with the waste shipment;

the waste analysis data (if available); and

a specific certification statement

3. Record Keeping

Maintain the following for at least five (5) years:

waste analysis records;

notifications to treatment, storage and disposal facilities; and

certification statements.

If a broker, hauler or facility handles your paperwork for you, use the above section as a checklist to ensure that all landban requirements are met. Keep copies of all paperwork that you sign.

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POLLUTION PREVENTION

Waste reduction methods can be used by all businesses. These methods help to protect the environment by reducing the amount of hazardous waste that needs to be disposed of by landfilling and incineration. Most businesses have found that pollution prevention can save a substantial amount of money in raw material costs and/or avoided disposal costs.

The first step towards pollution prevention is becoming aware of which chemicals you use at your business. For example, by monitoring your use of different chemicals you may recognize opportunities to switch to less- hazardous materials. The following are some pollution prevention tips.

1. Housekeeping Methods

Don't mix hazardous wastes with non-hazardous wastes, since this increases the amount of waste that must be disposed of as a hazardous waste.

Use drip pans for equipment cleaning to avoid having to clean up spills.

Keep containers of solvents, paint thinners and other materials closed when not in use to avoid losing valuable raw materials to the air.

Keep different types of wastes separate since this practice may increase the possibility of recycling.

Preventive maintenance of equipment should be practiced to reduce spills or leaks of materials which may then need to be disposed of as hazardous wastes.

2. Inventory Control

Some materials break down over extended storage time and thus may become hazardous wastes. To avoid having to dispose of unused materials, incorporate the following into your supply procedures:

Order materials on an as-needed basis.

Mark purchase date on containers and use older materials first.

Control access to materials that will become hazardous wastes when spent so that these materials are not used unnecessarily when a substitute would work as well.

Don't use solvents if there are effective substitutes such as detergents (e.g., hand cleaning, floor cleaning).

Try to use one multipurpose solvent rather than several different solvents; this will increase the recycling potential of the spent solvent.

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3. Employee Training

Training employees about the efficient use of chemicals that may, when used, become hazardous wastes can help to reduce the amount of waste that needs to be disposed of. Examples include stressing the need to use the minimal amount of paint thinner to get the job done; reusing solvent until it is no longer useable; and using spent solvent as paint thinner.

4. Purchasing Practices

Material Safety Data Sheets (MSDSs) provide valuable information regarding the contents of commercial products such as paints, solvents and inks. They also provide information that will enable you to determine if, when disposed of, a material will be a hazardous waste. Obtaining copies of MSDSs from your vendors prior to purchase will allow you to have more control over whether or not your company will generate hazardous waste.

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TECHNICAL AND REGULATORY ASSISTANCE PROGRAMS

The following organizations publish information, conduct or speak at workshops and conferences, and provide telephone, written and on-site information and assistance to generators on better management of hazardous waste :

DEC'S Hazardous Waste Compliance Unit

Toll-free hotline 1-800-462-6553 (normal business hours) Albany area or out of New York State, call (518) 457-4105 50 Wolf Road Albany, NY 12233-7253

NYS Environmental Facilities Corporation

Industrial Materials Recycling Program (518) 457-4138 50 Wolf Road Albany, NY 12205

Assistance is confidential.

Also coordinates a waste exchange to assist generators of waste to find companies that can use the materials in their feedstock.

Erie County Hazardous Waste Minimization Program

Richard R. Rutkowski (716) 858-6370 Department of Environment and Planning Division of Environmental Compliance Services 95 Franklin Street, Room 1077 Buffalo, NY 14202

Assistance to public and private sector businesses in the Erie County metropolitan area.

Suffolk County Water Authority

(516) 563-0308 Watershed Oversight and Protection Department Sunrise Highway and Pond Road P.O. Box 38 Oakdale, Long Island, New York 11769

Confidential assistance to businesses in Suffolk county.

Some federal programs are described below:

EPA Asbestos/Small Business Ombudsman 1-800-368-5888

Answers to questions on asbestos; clearinghouse of publications; referral to other EPA phone numbers; represent small business interests regarding environmental regulations and laws.

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RCRA/SUPERFUND HOTLINE 1-800-424-9346

- Answer questions regarding federal hazardous waste regulations.

Your county or town Department of Health, Public Works Office, or Environmental Management Council may also be able to provide you with information on local regulations and issues.

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APPENDIX A

FEDERAL GOVERNMENT CONTACTS

RCRA/Superfund Hotline

(in Washington, D.C.: 557-1938 1-800-424-9346

EPA Small Business Ombudsman Hotline: 1-800-368-5888

National Response Center

(in Washington, D.C.: 426-2675 1-800-424-8802

EPA Region II Office 26 Federal Plaza New York, NY 10278 (212) 264-9883

NEW YORK STATE CONTACTS

ENVIRONMENTAL CONSERVATION DEPARTMENT

CENTRAL OFFICE

New York State Department of Environmental Conservation Hazardous Waste Compliance Unit 50 Wolf Road Albany, NY 12233-7253

Small Quantity Generator/Household Hazardous Waste Hotline: (800) 462-6553 (Normal business hours)

(518) 485-8988

REGIONAL OFFICES

REGION 1 - (NASSAU & SUFFOLK COUNTIES) NYS Department of Environmental Conservation Building 40 SUNY at Stony Brook Stony Brook, NY 11794 (516) 751-4078

REGION 2 - (BRONX, KINGS, NEW YORK, QUEENS & RICHMOND COUNTIES) NYS Department of Environmental Conservation Region 2 Headquarters Hunters Point Plaza Long Island City, NY 11101 (718) 482-4900

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REGION 3 - (DUTCHESS, ORANGE, PUTNAM, ROCKLAND, SULLIVAN, ULSTER & WESTCHESTER COUNTIES)

NYS Department of Environmental Conservation Region 3 Headquarters 21 South Putt Corners Road New Paltz, NY 12561-1696 (914) 255-5453

REGION 4 - (ALBANY, COLUMBIA, DELAWARE, GREENE, MONTGOMERY, OTSEGO, RENSSELAER, SCHENECTADY & SCHOHARIE COUNTIES)

NYS Department of Environmental Conservation Region 4 Headquarters 2176 Guilderland Avenue Schenectady, NY 12306 (518) 382-0680

REGION 5 - (CLINTON, ESSEX, FRANKLIN, FULTON, HAMILTON, SARATOGA, WARREN & WASHINGTON COUNTIES)

NYS Department of Environmental Conservation Region 5 Headquarters Route 86 Ray Brook, NY 12977 (518) 891-1379

REGION 6 - (HERKIMER, JEFFERSON, LEWIS, ONEIDA & ST. LAWRENCE COUNTIES) NYS Department of Environmental Conservation Region 6 Headquarters 317 Washington Street Watertown, NY 13601 (315) 785-2513

REGION 7 - (BROOME, CAYUGA, CHENANGO, CORTLAND, MADISON, ONONDAGA, OSWEGO, TIOGA & TOMPKINS COUNTIES)

NYS Department of Environmental Conservation Region 7 Headquarters 615 Erie Boulevard West Syracuse, NY 13204-2400 (315) 426-7400

REGION 8 - (CHEMUNG, GENESEE, LIVINGSTON, MONROE, ONTARIO, ORLEANS, SCHUYLER, SENECA, STEUBEN, WAYNE & YATES COUNTIES)

NYS Department of Environmental Conservation Region 8 Headquarters 6274 East Avon-Lima Road Avon, NY 14414 (716)226-2466

REGION 9 - (ALLEGANY, CATTARAUGUS, CHAUTAUQUA, ERIE, NIAGARA & WYOMING COUNTIES)

NYS Department of Environmental Conservation Region 9 Headquarters 270 Michigan Avenue Buffalo, NY 14203-2999 (716) 851-7220

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APPENDIX B

EPA HAZARDOUS WASTE NUMBERS FOR WASTE STREAMS COMMONLY GENERATED BY SMALL QUANTITY GENERATORS

The Environmental Protection Agency recognizes that generators of small quantities of hazardous waste, many of which are small businesses, may not be familiar with the manner in which hazardous wastes are identified. This Appendix has been assembled to aid small quantity generators in determining the EPA Hazardous Waste Numbers for their wastes. These numbers are needed to complete the "Notification of Hazardous Waste Activity," Form 8700-12.

This Appendix contains lists of EPA Hazardous Waste Numbers for each waste stream identified in Table 1. Note that acutely hazardous wastes are identified with an asterisk (*).

To Use This Appendix

1. Locate your business type in Table 2. This will help you to identify the waste streams common to your activities.

2. Find each of the waste streams that you identified in Table 2 in the more detailed descriptions in this Appendix. Review the more detailed descriptions of typical wastes to determine which waste streams actually result from your activities.

3. If you determine that you actually do generate a particular waste stream, report the four-digit EPA Hazardous Waste Number in Item X of Form 8700-12, "Notification of Hazardous Waste Activity."

The industries and waste streams described here do not provide a comprehensive list, but rather serve as a guide to potenetial small quantity generators in determinting which of their wastes, if any, are hazardous. If the specific EPA Hazardous Waste Number that should be applied to your waste stream is unclear, please refer to 40 CFR Part 261 (reprinted in the Notification Form 8700-12 package) or 6 NYCRR Part 371 (available by calling the SQG/HHW hotline). In those cases where more than one EPA Hazardous Waste Number is applicable, all should be used. If you have any questions, or if you are unable to determine the proper EPA Hazardous Waste Numbers for your wastes, please contact the New York State SQG/HHW hotline or the USEPA RCRA/Superfund hotline. Both numbers are listed in Appendix A of this manual.

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APPENDIX B (continued) Solvents :

often hazardous. This includes solvents used in degreasing (identified as F001) and paint brush cleaning and distillation residues from reclamation. The following are some commonly used hazardous solvents:

Solvents, spent solvents, solvent mixtures, or solvent still bottoms are

Benzene Carbon Disulfide Carbon Tetrachloride Chlorobenzene Cresols Cresylic Acid 0-Dichlorobenzene E thano1 2-Ethoxyethanol Ethylene Dichloride Isobutanol Isopropanol Kerosene Methyl Ethyl Ketone Methylene Chloride Naphtha Nitrobenzene 2-Nitropropane Petroleum Solvents (Flashpoint less than 140" F) Pyridine 1,1,1-Trichloroethane 1,1,2-Thrichloroethane Tetrachloroethylene (Perchloroethylene) Toluene Trichloroethylene Trichlorofluoromethane Trichlorotrifluoromethane (Valclene) White Spirits

F005, D018 F005 F001, D019 F002, D021 F004, D026 F004 F002, D027 D001 F00 5 D001 F005 D001 D001 F005, D035 F001 or F002 D001 F004, D036 F005 D001

F005, D038 F001 or F002 F00 2 F001, D039

F00 5 F001 or F002; D040 F00 2 F00 2

D001

Acids/Bases:

Acids, bases, or mixtures having a pH less than or equal to 2 or greater than or equal to 12.5, are considered corrosive (for a complete description of corrosive wastes, see 40 CFR Part 261 or 6 NYCRR Part 371). All corrosive materials and solutions have the EPA hazardous Waste Number D002. The following are some of the more commonly used corrosives:

Acetic Acid Ammonium Hydroxide Chromic Acid Hydrobromic Acid Hydrochloric Acid Hydrofluoric Acid

Nitric Acid Oleum Perchloric Acid Phosphoric Acid Potassium Hydroxide Sodium Hydroxide Sulfuric Acid

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APPENDIX B (continued)

Dry Cleaning Filtration Residues:

Cooked powder residue (perchloroethylene plants only), still residues, and spent cartridge filters containing perchloroethylene or valclene are hazardous and have the EPA Hazardous Waste Number F002. Any waste containing 0.7 mg/l or more of perchloroethylene as tested by the TCLP also has the EPA Hazardous Waste Number 0039.

Still residues containing petroleum solvents with a flashpoint less than 140o F are considered hazardous and have the EPA Hazardous Waste Number D001.

Heavy Metals/Inorganics:

Heavy metals and other inorganic waste materials exhibit the characteristic of EP Toxicity or TC Toxicity and are considered hazardous if they fail the Extraction Procedure Toxicity Test or the Toxicity Characteristic Leaching Procedure. These wastes may include dusts, solutions, wastewater treatment sludges, paint wastes, waste inks, and other such materials which contain heavy metals/inorganics (note that wastewater treatment sludges from electroplating operations are identified as F006). The following are EP or TC Toxic:

Arsenic Barium Cadmium Chromium Lead Mercury Selenium Silver

D004 D005 D006 D007 D008 D009 D010 D011

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APPENDIX B (continued)

Ignitable Wastes:

Ignitable wastes include any liquids that have a flashpoint less than 140o F, any non-liquids that are capable of causing a fire through friction, absorption of moisture, or spontaneous chemical change, or any ignitable compressed gas as described in 49 CFR 261.300 (for a complete description of ignitable wastes, see 40 CFR Part 261 or 6 NYCRR Part 371). Examples are spent solvents (see also "solvents”), solvent still bottoms, ignitable paint wastes (paint removers, brush cleaners and stripping agents), epoxy resins and adhesives (epoxies, rubber cements and marine glues), and waste inks containing flammable solvents. Unless otherwise specified, all ignitable wastes have the EPA Hazardous Waste Number of D001.

Some commonly used ignitable compounds are

Acetone Benzene n-Butyl Alcohol Chlorobenzene Cyclohexanone Ethyl Acetate Ethylbenzene Ethyl Ether Ethylene Dichloride Methanol Methyl Isobutyl Ketone Petroleum Distillates Xylene

Ink Sludges Containing Chrom ium and

F003 F005, D018 F003 F002, D021 F003 F003 F003 F003 D001 F003 F003 D001 F003

Lead :

This includes solvent washes and sludges, caustic washes and sludges, or water washes and sludges from cleaning tubs and equipment used in the formulation of ink from pigments, driers, soaps and stabilizers containing chromium and lead. All ink sludges have the EPA Hazardous Waste Number K086 and may also have the EPA Hazardous Waste Numbers D007 and/or D008.

Lead-Acid Batteries:

Used lead-acid batteries should only be reported on the notification form if they are not being recycled. Used lead-acid batteries that are recycled do not need to be counted in determining the quantity of waste that you generate per month, nor do they require a hazardous waste manifest when shipped off your premises.

Lead Dross Spend Acids Lead-Acid Batteries

D008 D002 D008

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APPENDIX B (continued)

Pesticides:

The pesticides listed below are hazardous. Wastes marked with an asterisk (*) have been designated acutely hazardous. For a more complete listing, see 40 CFR 261.32 and 261.33 or 6 NYCRR Part 371 for specific listed pesticides, and other wastes, wastewaters, sludges, and by-products from pesticide formulators. (Note that while many of these pesticides are no longer in common use, they are included here for those cases where they may be found in storage).

*Aldicarb *Aldrin Armitrole *Arsenic Pentoxide *Arsenic Trioxide Cacodylic Acid Carbamic Acid, Methylnitroso-Ethyl Ester Chlordane *Copper Cyanides 1,2-Dibromo-3-chloropropane 1,2-Dichloropropane 1,3-Dichloropropene 2,4-Dichlorophenoxy Acetic Acid

DDT *Dieldrin Dimethylcarbamoyl Chloride *Dinitrocresol *Dinoseb Disodium Monomethanearsenate *Disulfoton *Endosulfan *Endrin Ethylmercuric Chloride *Famphur *Heptachlor Hexachlorobenzene Kepone Lindane 2-Methoxy Mercuric Chloride Methoxychlor *Methyl Parathion Monosodium Methanearsenate *Nicotine *Parathion Pentachloronitrobenzene Pentachlorophenol Phenylmercuric Acetate

P070 P004 U011 P011 P012 U136

U178 U036 P029 U066 U083 U084

U240 U061 P037 U097 P047 P020 D004 P039 P050 P051 D009 P097 P059 U127 U142 U129 D009 D014 P071 D004 P075 P089 U185 U242 D009

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APPENDIX B (continued)

*Phorate *Strychnine 2,4,5-Trichlorophenoxy Acetic Acid

2-(2,4,5-Trichlorophenoxy)- Propionic Acid

*Thallium sulfate Thiram *Toxaphene Warfarin

P094 P108

U232

U233 P115 U244 P123 U248

Reactives :

Reactive waste include reactive materials or mixtures which are unstable, react violently with or form explosive mixtures with water, generate toxic gases or vapors when mixed with water (or when exposed to pH conditions between 2 and 12.5 in the case of cyanide or sulfide bearing wastes), or are capable of detonation or explosive reaction when heated or subjected to shock (for a complete description of reactive wastes, see 40 CFR 261.23, Characteristic of reactivity). Unless otherwise specified, all reactive wastes have the EPA Hazardous Waste Number D003. The following materials are commonly considered to be reactive:

Acetyl Chloride Chromic Acid Cyanides Hypochlorites

Organic Peroxides Perchlorates Permanganates Sulfides

Spent Plating and Cyanide Wastes:

Spent plating wastes contain cleaning solutions and plating solutions with caustics, solvents, heavy metals, and cyanides. Cyanide wastes may also be generated from heat treatment operations, pigment production, and manufacturing of anti-caking agents. Plating wastes are generally Hazardous Waste Numbers F006-F009, with F007-F009 containing cyanide. Cyanide heat treating wastes are generally Hazardous Waste Numbers F010-F012. See 40 CFR 261.32 for a more complete description.

Wood Preserving Agents:

The waste water treatment sludges from waste water treatment operations are considered hazardous (EPA Hazardous Waste Number K001 -- bottom sediment sludges from the treatment of waste water processes that use creosote and pentachlorophenol). In addition, unless otherwise indicated, specific wood preserving compounds are:

Chromated Copper Arsenate Creosote Pentachlorophenol

D004 U051 F027

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