Air Indoor Resources
Air Indoor Resources
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Air Indoor Resources - Hazardous Waste Management
Common School Wastes
Aerosol Cans – Punctured
and empty aerosol cans are exempt from the hazardous waste
rules, allowing them to be recycled as scrap metal. It is recommended
that all fluids be used up, cans punctured, and excess material
drained in order to recycle aerosol cans for scrap metal. If
a spray can malfunctions, consider returning it to the manufacturer.
Antifreeze – Antifreeze
consists of water, ethylene glycol, or propylene glycol. When
in product form it is not considered hazardous; however, used
antifreeze can become contaminated with heavy metal, benzene,
and solvents, rendering it a hazardous waste. Used antifreeze
must minimally be tested for lead, benzene, tetrachlorethylene,
and trichloroethylenes using the Toxic Characteristic Leaching
Procedure (TCLP); see “Characteristic Waste” discussion. Used
antifreeze must go for recycling or proper hazardous waste
disposal. If it does not pass the TCLP, it must be handled
as a hazardous waste.
Used antifreeze can be recycled using distillation, filtration, or ion exchange processes. A log documenting the volume of recycled antifreeze is required. Alternately, it can be shipped to a permitted recycling facility. Burning used antifreeze for energy recovery is not considered recycling. Used antifreeze cannot legally be poured down the sewer. Storage containers or drums of spent antifreeze are required to be marked “Used Antifreeze.” If under contract, most companies will accept spent antifreeze for recycling at no cost or very little cost.
Best Management Practices for Managing Used Antifreeze at Vehicle Repair Facilities (PDF) is a helpful publication.
Ballasts – Light
ballast capacitors marked “PCB” are a hazardous waste and must
go for proper disposal. If the capacitor has a blue label marked “non-PCB,” it
can go into the municipal solid waste.
Batteries – The
most common maintenance battery is the lead acid battery for
machinery and vehicles. Guidance for indoor storage recommends
stacking batteries on wooden pallets on an impervious surface.
Stack batteries less than four high to eliminate cracked-cap
issues. Guidance for outdoor storage recommends secondary containment
away from high-traffic areas and covered from the elements.
Keep spill-kit equipment near storage, especially a container of baking soda to neutralize acid releases. Broken batteries should be stored in a closed, airtight, acid-resistant storage container.
Lead acid batteries can be returned to the retailer for a fee or a clause can be incorporated into the battery contract for battery exchange. Florida does not host a permitted lead reclamation facility; therefore, all lead waste must leave the state for recycling. For batteries to be considered an exempt material, a “core charge” must be cited on a receipt. An outline for the disposal method for a variety of batteries is “Where Do I Recycle Rechargeable Batteries?”
Brake Fluid – Contaminated
with chlorinated solvents, brake fluid is considered a hazardous
waste. Most used oils transporters allow nonhazardous brake
fluid to be added to the used oil.
Compressed Tanks – Although
compressed tanks are not usually under the jurisdiction of
the EPA, they are worth mentioning since most automotive shops
are out of compliance. Under 29 CFR Occupation Safety and Health
Administration, 1910.101, “Compressed Gas,” and
C-6-1968, Compressed Gas Association pamphlet, the following
are the compressed gas tank management requirements:
- Transport cylinders using a cylinder cart and a safety cap;
- Store cylinder upright and secured with approved lock-down devices;
- Use correct pressure regulator for the specific gas;
- Do not store cylinder with regulator in place;
- Mark cylinder with chemical name;
- Label cylinder to indicate if the container is empty or full (optional); and
- If in active use, keep the hose unwound and the tank
cart placed near a work station.
Electronic Equipment - DEP
recycling information for electronic equipment is found on
Electronics Main Web Page. In particular, computer monitors
and televisions, due to their lead content, must be discarded
properly. Precious metals such as gold and silver are also
recovered from used electronic items. No unusable electronic
equipment should be placed in the dumpster or donated to a
Empty Drums – All
the contents must be removed by inverting and draining, shaking,
and scraping, and then the containers can be crushed, punctured,
or shredded and discarded as scrap metal. All stored empty
drums must be clean, dry, bung-closed, and turned on their
sides to inhibit water collection as they sit. Frequently,
contractors will exchange drums that held virgin product. The
drums can also be picked up by companies that recondition used
drums. If the drums contained non-hazardous waste or used oil,
they can be burned by a municipal foundry that conducts scrap
Floor Dry – If
it holds non-hazardous oil or fluid, small amounts of floor
dry can be bagged and placed in the dumpster, but this method
of disposal requires written verification to the solid waste
hauler. Otherwise absorbents that come in contact with hazardous
waste must be managed as RCRA hazardous waste. This waste can
be very costly to dispose of since it is very heavy. Some new
methods of recycling floor dry are available through composting
or distillation and refortification of the fine particles.
Fuel Filters – Most
fuel filters are handled as a hazardous waste. Metal fuel filters
can be handled with the used oil filters if drained for at
least 24 hours and dried. Glass filters are managed separately
and require waste determination; if non-hazardous, they can
be disposed of in the dumpster or recycled with other glass.
Mercury/Fluorescent Lamps – Refer
to the Florida Department of Education's Mercury
Eliminiation in Florida Schools web site to review guidance
on storage, management, and disposal of mercury-containing
devices, and to review the Florida State Contract for Mercury
Recycling. Store lamps to prevent breaking and label each container “Spent
Mercury-Containing Lamps.” Lamps should not be stored
for over one year. Do not break or crush lamps unless using
a machine designed for this function. You may also want to
visit Florida Department of Environmental Protection's Registered
Handlers of Mercury Containing Lamps and Devices web page.
Paints – Latex
paint not containing any hazardous metals per the Material
Safety Data Sheet is considered nonhazardous. Oil-based paints
are considered hazardous for solvents and metals, but the brushes,
rollers, and applicators are not; they can go to the landfill
Rags – All
disposable shop towels, wipes, or rags that come in contact
with a regulated solvent may qualify as a hazardous waste.
Store these rags in a fire-retardant container with a self-closing
lid labeled “Used Shop Towels.” It is best to contract
with a laundry service that maintains a National Pollution
Discharge Elimination System (NPDES) permit. Keep metal shavings
and overwhelming odors from emanating out of the rags, and
the rag-laundering partnership will go smoothly. An accountability
system should be set up to track whether rags are being thrown
into the municipal trash or not being returned from the launderer.
Solvent Cleaning – Many
parts washer fluids, degreasers, and spray-on solvents can
be hazardous due to flash point (over 140° F) or contamination
with heavy metals. Filtration and distillation reduce the amount
of hazardous waste and at the same time recycle the solvent
for reuse, but are only cost-effective when large amounts of
spent solvent are generated. There are other methods that use
microbes in aqueous detergents to generate biodegradable, nontoxic,
noncaustic by-products without having to change out the parts
Alternatively, if you are a Conditionally Exempt Small Quantity Generator (CESQG), you can use a solution that has a flash point that exceeds 140° F and contains less than 1,000 ppm halogens (mainly chlorine), which allows this non-hazardous waste to be directly added to your used oil. For this type of disposal, it may be necessary to conduct a mini-TCLP (metals only) to qualify material as a non-hazardous waste. The Environmental Compliance for Automotive Recyclers hosts a fact sheet for Florida Solvent Cleaning.
Smoke Detectors – Smoke
detectors commonly contain a small amount of Americium 241,
a radioactive material. Detectors’ normal life span is
approximately ten years. The only way to be sure a smoke detector
is still working is to test the detector with artificial smoke.
Many detector companies will accept spent detectors. The majority
of detectors are manufactured by First Alert Corporation, which
will accept old detectors via mail to First Alert, Radioactive
Waste Disposal, 780 McClure Road, Aurora, Il, 60504-2495or
call 1-800-323-9005. Most other smoke detectors are
manufactured by a Canadian firm called American Sensors,
which can be contacted at 1-800-387-4219. It is recommended
to return these detectors by surface rather than air mail.
Storage Area Inspections – Small
Quantity Generators (see “Generator Size Determination”)
are required to document storage area container inspections.
CESQGs are not required to document such inspections, but are
also encouraged to inspect containers for:
Drum Closed? Storage Time Limit OK? Cracks in Floor? Drum Labeled Correctly? Accumulation Limit OK? Outdoor Area Secure? Label Visible? Spills or Leaks? Outdoor Area Shaded?
Other required information on the inspection log includes date of the inspection, any problems noted, signature by the inspector, and any corrective action taken.
Used Oil – Used
oil must be stored in Department of Transportation (DOT)-approved
containers in good condition visibly displaying the words “Used
Oil.” Used oil containers must be protected from the
elements and stored on an oil-impermeable surface painted with
sealant with secondary containment per 40 CFR 279 and Chapter
62-710, FAC. This also applies to the storage of used oil filters.
Owners or operators who spill or release more than 25 gallons
of petroleum or petroleum products on a pervious surface must
report the discharge to the National Response Center, Florida
DEP, or State Warning Point (see “Emergencies, Training,
The used oil rules allow you to mix used crankcase oil, synthetic oils, brake fluid, transmission fluid, hydraulic oil, power steering fluid, and lubricating greases into one drum or tank, but prohibit the addition of vegetable or animal fats. Avoid contact with solvents, brake cleaner, and carburetor cleaner with oil, and do not mix antifreeze, solvents, gasoline, degreasers, paint, or other automotive fluids with used oil or with solid waste heading to the landfill. Do not spray used oil on roads as a dust retardant or on the ground for weed control.
If used oil is recycled, also known as re-refined, it is not presumed a hazardous waste and the volume or weight is not counted toward generator size; however, local rules may be more stringent. All transporters must be DEP-registered used oil transporters and the recycler must be a state-permitted used oil processor.
For more information, please see:
Used Oil Filters – All
used oil filters (and transmission filters) were banned from
landfills in 1995; however, household filters are exempt from
this ban per Chapter 62-710.850, FAC. Burning them through
a Waste to Energy (WTE) facility for energy recovery and metal
recycling is allowed in certain counties. Otherwise, generators
must drain (24 hours prior to disposal), consolidate, and crush
used oil filters for off-site recycling by a DEP-registered
used oil filter processor. Used oil filters must be stored
in DOT-approved containers in good condition that visibly display
the words “Used Oil Filters.” Containers must be
protected from the elements and stored on an oil impermeable
surface covered with sealant per Chapter 62-710.850(6), FAC.
Tires – Waste
tires should be covered to prevent collection of standing water
when stored in a central location with no more than 1,500 tires
at one time. Burning or burying waste tires is prohibited.
Almost a quarter million tires are scrapped in the United States
each year, with over 80% of the tires now being retreaded,
recycled, or used as fuel.
For more information, please see:
Be careful; there are many instances in which the disposal contractor is not disclosing the actual volume of waste on the disposal manifest. For example, the manifest documents the disposal of a 55-gallon drum of a hazardous waste, but in reality the drum only contained 20 gallons. It is very important to cite the actual volume or weight of the hazardous waste on the manifest and separately outline all non-hazardous waste going to a Treatment, Storage, and Disposal (TSD) facility in Section 14, “Special Handling Instructions and Additional Information,” so that the waste is not counted against your generator size. If this is not done, it may affect your generator size. Generators may only exceed their waste allowance one month out of each year.
Surprisingly, art departments can generate up to 20% of all hazardous waste at a school. Solvents used for oil-based paints and pigments containing lead, cadmium, and chromium can be considered hazardous. If this art waste goes for infrequent disposal through the management of a satellite accumulation site, a mini-TCLP may disqualify it as a hazardous waste.
Additionally, photography laboratories use neutralizers, fixers, and developer solution by-products. Contracts often provide for quarterly or semiannual pickups for disposal. The fixer is hazardous for silver content; the developer can be considered non-hazardous at the end of the development process. Contact your local domestic wastewater treatment facility for more information. DEP’s Photo Shop publication(PDF) is a good resource to review.
During the physical facility inspection, one of the most common violations is leaving the bung open on a drum containing a hazardous waste. This can be rectified by the purchase of a snap lid funnel that can be easily opened and closed while adding or removing waste. Larger versions of these funnels can also accommodate used oil filters so they can drain overnight while also keeping the container closed. Another common violation is poor fluorescent lamp storage and labeling. Lamps should be in a dedicated storage area, out of traffic, organized, and labeled “Used Lamps.” For further information visit DEP’s Currently Register Hazardous Waste Transporters.
325 West Gaines Street
Tallahassee, FL 32399
Phone: (850) 245-9295