fife 8MMI
A Survey of
Household Hazardous Wastes
and Related Collection Programs
•tan
S, Liferaiy (PL-12JI
77 Wist Jackson Boulevard. 12ft How
II.
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' $7 •
ACKNOWLEDGMENTS
This report was prepared for the Special Wastes Branch, Office of Solid
Wasta, United States Environmental Protection Agency by SCS Engineers under
contract 68-01-6621. The EPA Project Manager was Gerri Dorian. SCS personnel
involved with this project were Gary L. Mitchell, Deana M. Demichelis, Jeffrey
D. Marshall, and Sabra F. Flaherty.
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DISCLAIMER
This report has been reviewed by the Office of Solid Waste, U.S.
Environmental Protection Agency, and approved for publication. Approval does
not signify that the contents necessarily reflect the views and policies of the
U.S. Environmental Protection Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.
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TABLE OF CONTENTS
Section 1 - Executive Summary 1- 1
Definition 1- 2
Presence in Wastestream 1- 2
Impacts 1- 3
Collection Programs 1- 3
Section 2 - Analysis Methodology 2- 1
General Purposes and Project Constraints 2- 1
Definition 2- 2
Presence in Wastestream 2- 3
Impact on Sol id Waste Management 2- 4
Local and State Collection Programs and Case Studies 2- 5
Summary 2- 6
Section 3 - Definitions 3- 1
Background 3- 1
Definition of Household Hazardous Wastes 3- 2
Criteria for Household Hazardous Wastes 3- 3
Other Definitions of Household Hazardous Wastes 3-13
References 3-17
Section 4 - Presence in Wastestream '. 4- 1
Residential Waste Generation and Composition 4- 1
Household Hazardous Wastes 4- 6
References 4-11
Section 5 - Impacts on Solid Waste Management
and the Environment 5- 1
Storage and Collection 5- 1
Hauling and Disposal 5- 4
Environmental Impacts 5- 5
References 5- 7
Section 6 - Special Collection Programs 6- 1
Goal s and Types 6- 1
Local Programs 6- 1
References 6- 6
Section 7 - State Programs 7- 1
Vermont 7- 1
Connecticut 7- 2
Florida 7- 2
Rhode Island 7- 4
Washington 7- 5
Minnesota 7- 5
References 7- 6
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TABLE OF CONTENTS (Continued)
Section 8 - Major Issues 8- 1
Liability 8-1
Degree of Regulation 8- 3
Reference 8- 3
Appendix A - 40 CFR Parts 261.33 (e) and (f) A- 1
Appendix B - 40 CFR Parts 261.21 Through 261.24 B- 1
Appendix C - Directory to Programs C- 1
Appendix D - Case Studies of Household Hazardous Waste
Collection Programs. D- 1
Albuquerque, New Mexico D- 2
Fairfax County, Virginia D-14
State of Florida , D-26
Appendix E - Memoranda and Letters Related to Liability of
Collection Programs E- 1
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LIST OF EXHIBITS
Section 3 - Definitions
Exhibit 3-1 - Household Hazardous Wastes and Their
Hazardous Components 3- 5
Exhibit 3-2 - Other Household Items That May
Be Hazardous 3- 9
Exhibit 3-3 - Comparison of Household Hazardous
Waste Lists 3-14
Exhibit 3-4 - Example Wastes Identified for Community
Collection Day Programs 3-16
Section 4 - Presence in Wastestream
Exhibit 4-1 - Residential Waste Generation Rates 4- 1.
Exhibit 4-2 - Residential Waste Composition 4- 4
Exhibit 4-3 - Albuquerque, NM Residents' Perceptions
of the Hazards Associated with
Selected Toxic Substances 4-10
Appendix D - Case Studies of Household Hazardous Waste
Collection Programs
Albuquerque, New Mexico
Exhibit 1 - Example of Albuquerque, New Mexico's
Publicity Materials D- 4
Exhibit 2 - Diagram of Albuquerque, NM Household
Hazardous Waste Collection Site D- 8
Exhibit 3 - Participation and Results, Albuquerque, NM.. D-12
Exhibit 4 - Cost Summary, Albuquerque, NM D-13
Fairfax County, Virginia
Exhibit 1 - Example of Fairfax County, Virginia Flyers.. D-15
Exhibit 2 - Typical Site Plan, Fairfax County, VA D-18
Exhibit 3 - Summary of Fairfax County, Virginia D-21
Exhibit 4 - Participation and Results,
Farifax County, VA D-23
Exhibit 5 - Cost Summary Fairfax County, Virginia D-24
State of Florida
Exhibit 1 - Example Publicity Materials,
State of Florida D-27
Exhibit 2 - Typical Collection Site, State of Florida... D-31
Exhibit 3 - Collection Period Costs D-34
Exhibit 4 - Daily Operations Costs for Florida
Collection Sites D-35
Exhibit 5 - "Amnesty Day" Collection Totals
(May 1984 - June 1985) D-37
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SECTION 1
EXECUTIVE SUMMARY
This report contains the results of the only known comprehensive
nationwide study of household hazardous waste (HHW). The study was conducted
to identify existing information on the types and quantities of HHW present in
the residential wastestream. A proposed definition for HHW was developed when
none were found (other than open-ended lists used in HHW collection programs).
Existing collection programs operating at State and local levels were
identified and described. Detailed lists of programs are included in an
appendix as are case studies of three collection programs. This report refers
to safeguards associated with waste disposal rather than the degree to which an
item may injure someone or affect their health while the item is in the home.
Interest in HHW began in 1981 and 1982. Virtually all activity on this
topic has been related to collection programs. These programs enlist
homeowners' cooperation in taking HHW to collection centers where the wastes
are identified, packaged, and transported to permitted hazardous waste disposal
facilities. A major element of all programs has been public education related
to identification of HHW and developing an awareness of the environmental
consequences of improper disposal.
These collection programs are very similar to early recycling efforts in
the 1970's. They are inspired by similar environmentally-related concerns.
They rely on public cooperation and include public education elements. Overall
participation is low and costs for recovery of each pound of hazardous waste
are high when all costs are included.
Collection programs provide many benefits beyond the collection and
disposal of HHW. All include public education elements that identify HHW.
Additionally, proper ways to store the wastes are often presented along with
identification of less hazardous substitutes. The potential environmental and
safety impacts of improper use and disposal are also highlighted. Collection
programs increase the public's awareness of HHW in the home and encourage safer
use and proper disposal. Although not quantifiable at present, the public
certainly is more aware of HHW and likely is disposing of these materials in
more environmentally acceptable ways now than prior to collection efforts.
Current Federal regulations exempt household hazardous waste from the
regulations applicable to other types of hazardous waste. Refuse from homes,
apartments, motels, and hotels may contain wastes that would otherwise be
considered hazardous; however, current regulations allow them to be disposed
with mixed municipal (non-hazardous) waste. New attention was focused on HHW
with the passage of the Hazardous and Solid Waste Amendments of 1984 (HSWA). In
these amendments, Congress recognized that homes, along with small commercial
generators, may be sources of hazardous constituents that have and will enter
municipal sanitary landfills. The interest in the potential impact of these
waste and constituents was expressed in several sections of the HSWA.
1-1
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DEFINITION
During the course of this project, no rigorous definition of household
hazardous wastes was found. The only approach to identifying these wastes
consisted of lists of generic products used by sponsors of HHW collection
programs. A definition of household hazardous wastes was developed as follows:
Household Hazardous Wastes: Solid wastes discarded from homes or
similar sources as listed in 40 CFR 261.4 (b)(l) that are either
hazardous wastes as listed by EPA in 40 CFR, Parts 261.33 (e) or (f),
or wastes that exhibit any of the following characteristics as defined
in 40 CFR Parts 261.21 through 261.24: ignitability, corrbsivity,
reactivity, and EP toxicity.
Lists of household products that are hazardous or may be hazardous were
prepared based on the above definition. The lists were developed without the
benefit of laboratory testing. Products considered household hazardous wastes
include the following:
Drain openers
Oven cleaners
Wood and metal cleaners and polishes
Automotive oil and fuel additives
Grease and rust solvents
Carburetor and fuel injection cleaners
Air conditioning refrigerants
Starter fluids
Paint thinners
Paint strippers and removers
Adhesives
Herbicides
Pesticides
Fungicides/wood preservatives
It should be noted that not all examples of the above products should be
considered hazardous or even suspected as being hazardous. For example, some
oven cleaners were considered to fail the corrosivity test while others may
or may not fail that test, while still other oven cleaners would probably not
fail any of the tests. The above list should not be considered complete.
PRESENCE IN WASTESTREAM
There is very little knowledge about the presence of HHW in the
residential wastestream. Only three attempts at quantifying HHW have been
identified. One was based on a public opinion survey and two were limited
waste characterization projects. Results indicate that HHW is a small portion
of all residential waste, less than 1 percent. However, the projects vary
widely in their actual estimates. The public opinion survey resulted in an
estimate of 1 percent (1,000 ppm), while the characterization studies indicated
as little as 15 ppm. None of the quantification projects could be considered
statistically valid.
1-2
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Federal Register / Vol. 51. No. 215 / Thursday. November 6. 1986 / Notices
40353
DEPARTMENT OF EDUCATION
National Board of the Fund for the
Improvement of Postsecondary
Educational: Meeting
AGENCY: National Board of (he-fund for
tlie Improvement of Postsecondary
Education. ED.
ACTION: Notice of meeting.
SUMMARY: This notice sets forth the
proposed agenda of a forthcoming
meeting of the National Board of the
Fund for the Improvement of
Postsecondary Education. This notice
also describes the functions of the
Board. Notice of this meeting is required
under the Federal Advisory Committee
Act (Pub. L. 92-463), section 10{a)(2)).
DATE: December 4,1986 at 9:00 a.m.
through December 6,1986 at 12:00 p.m.
ADDRESS: Washington Hilton. 1919
Connecticut Avenue, NW., Washington,
DC 20009.
FOR FURTHER INFORMATION CONTACT
Charles Karelis, Director, Fund for the
Improvement of Postsecondary
Education, 7th & D Streets. SW.,
Washington. DC 20202 (202) 245-8091.
SUPPLEMENTARY INFORMATION: The
National Board of the Fund for the
Improvement of Postsecondary
Education is established under section
1003 of the Higher Education
Amendments of 1980, Title X (20 U.S.C.
1135a-l). The National Board of the
Fund is established to "advise the
Secretary and the Director of the Fund
for the Improvement of Postsecondary
Education ... on the selection of
projects under consideration for support
by the Fund in its competitions."
The meeting of the National Board
will be open to the public. The proposed
agenda includes:
—An orientation and introduction of
new Board members;
—A discussion and review of the past
year
—Development and discussion of
policies and priorities for the coining
year.
—Observation and participation in the
Fund for the Improvement of
Postsecondary Education Annual
Project Directors' Meeting.
Records shall be kept of all Board
proceedings, and shall be available for
public inspection at the Fund for the
Improvement of Postsecondary
Education, 7th & D Streets, SW.. Room
3100, Washington, DC 20202 from the
hours of 8:00 a.m. to 4 30 p.m. weekdays,
except Federal Holidays.
C. Ronald Kimberling,
Assistant Secretary for Postsecondary
Education.
[FR Doc 86-25098 Filed 11-5-86; 8:45 am]
BILLING CODE 4000-01-M
ACTION: Notice of availability, of r>jr':r:=;
on household hazardous w -iste and s' r.e
solid waste (subtitle D'
DEPARTMENT OF ENERGY
Energy Information Administration
Renewal of the Charter of The
American Statistical Association
Committee on Energy Statistics
Pursuant to the Federal Advisory
Committee Act (Pub. L. 92-163), I hereby
certify that the renewal of the charter of
the American Statistical Association
Committee on Energy Statistics is in the
public interest in connection with the
performance of duties imposed on the
Department of Energy by law. This
determination follows consultation with
the Committee Management Secretariat
of the General Services Administration,
pursuant to 41 CFR Subpart 101-6.1007.
The purpose of the committee is to
provide advice on a continuing basis to
the Administrator of the Energy
Information Administration (EIA),
including:
1. Periodic reviews of elements of EIA
information collection and analysis
programs and the provision of
recommendations;
2. Advice on priorities of technical
and methodological issues in the
planning, operation, and review of EIA
statistical programs; and
3. Advice on matters concerning
improved energy modeling and
forecasting tools, particularly regarding
their functioning, relevancy, and results.
Further information concerning this
committee can be obtained from Gloria
Decker (202-252-8990).
Dated: October 31,1986.
Charles Tiemey,
Advisory Committee Management Officer.
[FR Doc. 86-25127 Filed 11-15-88; 8:45 am]
MLLJMQ CODE *M»-«t-M
ENVmONMENTAL PROTECTION
AGENCY
[SWH-FRL-3106-5]
Sottd Wast* Disposal; Household
Hazardous Waste; State Programs
AGENCY: Environmental Protection
Agency.
SUMMARY: The U.S. Environmental
Protection Agency (EPA) is today
announcing the availability of two
reports. The first report is entitled "A
Survey of Household Hazardous Waste
and Related Collection Programs." This
report defines household hazardous
waste (HHW); summarizes existing
information regarding the presence of
HHW in residential waste; and
discusses the impacts of HHW on
homeowners, solid waste collection and
disposal personnel, and the
environment. Information about HHW
collection programs conducted at the
State and local levels is also included in
the report. The second report is entitled
"Census of State and Territorial Subtitle
D Non-Hazardous Waste Programs."
This report summarizes the results of a
mail survey of State and Territorial non-
hazardous (solid) waste regulatory
programs. Data from all the States and
six Territories are reported. State
organization and available resources for
Subtitle D programs are given. Numbers
and basic characteristics of landfills.
land application units, and surface
impoundments are included, as well as
information on regulations and
enforcement patterns.
ADDRESS: The reports are available for
viewing at all EPA libraries and in the
EPA RCRA docket room. U.S.
Environmental Protection Agency. 401 M
Street, SW., Washington, DC 20460, from
9:30 a.m. to 3.30 p.m., Monday thru
Friday, except legal holidays; telephone:
(202) 475-9327. The public may copy a
maximum of 50 pages of material from
any one regulatory docket at no cost.
Additional copies cost 20 cents per page.
Limited copies of the HHW report are
available, while supplies last from the
EPA RCRA/Superfund Hotline at (800)
424-9346 ((202) 382-3000 in Washington,
DC). These documents are available for
purchase from the National Technical
Information Service (NTIS). U.S.
Department of Commerce, Springfield,
VA 22161. at (703) 487-4600: "A Survey
of Household Hazardous Waste and
Related Collection Programs" (EPA/ 530-
SW-86-03a NTIS No.: PB-87-108-072,
$18.95 hardcopy, $6.50 microfiche) and
"A Census of State and Territorial
Subtitle D Non-Hazardous Waste
Programs" (EPA/530-SW-86-039, NTIS
No.: PB-87-108-080, $24.95 hardcopy,
$6.50 microfiche).
FOR FURTHER INFORMATION CONTACT
For general information, call the RCRA
Hotline at (800) 424-9348 ((202) 382-3000
in Washington, DC). For technical
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, 40334
Federal Register / Vol. 51. No. 215 / Thursday. November 6. 1986 / Notices
iff '-Tid'.ion en 'h» HHW reoor' -or.'ir*.
GL-"> Do-ian. Otf.ce of Solid Waste
IWH-56V£,. U 5 E.iv.ronrr.p-'il
Protection Au°nc\ 401 M Street. SU .
Washington. DC :0460, (202) 382-4688
For information on the State Survey
report, contact Allen Geswem. (202^"*"
3S2-4C87. a: the barre address. ...^ '
SUPPLEMENTARY INFORMATION: In.l9r9.
under the authonf, of sections
1008|d)(3! and 4004(3) of Subtitle D of
the Resource Conservation and
Recovery Act (RCRA), EPA promulgated
the "Criteria for Classification of Solid
Waste Disposal Facilities and Practices"
(40 CFR Part 257). These Criteria include
environmental performance standards
that are used for determining which
solid waste disposal facilities and
practices pose a reasonable probability
of adverse effects on human health or
the envircnment. Those facilities that
violate the Criteria are deemed "open
dumps." The Criteria are enforced by
the States or through citizen suits.
In 1984. Congress passed the
Hazardous and Solid Waste
Amendments (HSWA), which include
several major provisions regarding the
solid waste regulatory program. The
Amendments, require EPA to submit a
report to Congress by November 8,1987,
that addresses whether the current
Criteria (40 CFR Part 257) are adequate
to protect human health and the
environment, and whether additional
authorities are needed to enforce the
Criteria Further, EPA is required to
rev.se the Criteria by March 31,1988, for
facilities that may receive hazardous
household waste or small quantity
generator (SQG) hazardous waste.
HWSA also requires the States to have
a permit program for the existing
Criteria by November 1987, and to have
a revised permit program 18 months
after the revised Criteria are
promulgated.
In response to these statutory
mandates, the Agency is currently
gathering extensive data for both the
report to Congress and the Criteria
revisions. The two report* being made
publicly available today are the result of
two of these data collection.efforts.
Household Hazardous Watte Report
The report entitled, "A Survey of
Household Hazardous Waste and
Related Collection Programs," contains
the results of a study of household
hazardous waste that addressed the
following topics: (1) The definition of
HHW; (2) the quantities of HHW in the
municipal waste of stream: (3) the
impacts of HHW on homeowners, solid
waste collection and disposal personnel.
and the environmental: and (4) HHW
collection programs conducted at the
State and local le\ els Included :n 'he
re'. ?w of collection programs w ^s an
examination of the liability of operators
and sponsors of HHW collection
programs under RCRA and the
Comprehensive Environmental
Response. Compensation, and Liability
Act of 1980(CERCLA).
As part of the study, a standard
definition of HHW was developed. Lists
of household products that may be
considered household hazardous
wastes, when discarded, were prepared
based on this definition. For example,
certain products within the following
broad classes of materials could be
considered HHW when discarded: drain
openers, oven cleaners, wood and metal
cleaners and polishes, automotive oil
and fuel additives, grease and rust
solvents, carburetor and fuel injection
cleaners, air conditioning refrigerants,
starter fluids, paint thinners, paint
strippers and removers, adhesives,
herbicides, pesticides and fungicides/
wood preservatives. The report
describes the criteria used in the
definition and the limitations of the
analysis. The study also found that there
is very little data on the quantities of
HHW in residential wastes. However,
the limited studies conducted to date
indicate that HHW is a small portion of
all residential wastes.
The key results regarding the impacts
of HHW on the environment, refuse
personnel, and homeowners are
summarized in the report. Although
homeowners are assumed to have been
injured due to the presence of HHW in
their homes, no data were available to
show a direct correlation. However, a
number of communities across the
nation have reported injuries to
sanitation workers that have been
caused by HHW. These indicences are
often associated with materials that
splash or spill during compaction,
containers that explode, or materials
that emit toxic fumes.
Much recent activity has focused on
HHW collection programs. These
programs enlist homeowners'
cooperation in taking HHW to collection
centers where the wastes are identified,
packaged, and transported to secure
waste disposal facilities. The number of
these programs has grown rapidly, with
over 30 States having conducted a
collection program. Information on these
programs, gathered from several
sources, is summarized in the report.
A major element of all programs has
been public education related to
identification of HHW and developing
an awareness of the environmental
consequences of improper disposal.
Problems current!) asscc a'-d \s •'•>
those prosrarr.s ;ncludp rel :;\
participation, high disposal cos's irJ
sponsor liability concerns.
State Survey Report
The report entitled, "Census of State
and Territorial Subtitle D Non-
Hazardous Waste Programs."
summarizes the findings of a mail
survey of State and Territorial non-
hazardous waste regulatory programs.
The survey focused on three key areas:
(1) State organization and resources: (2)
number and characteristics of landfills.
land application units, and surface
impoundments; and (3) characteristics of
the regulatory program (e.g., regulations.
inspections, violations).
The report is organized in six major
parts. Part I contains the introduction to
the report the study methodology, and a
description of the statistical reliability of
the data. Part II describes State
organizational structures and resources
for the Subtitle D program. Part III
provides information on the total
number and basic characteristics
(owership, acreage, amount of waste
received, monitoring systems, design
and operational controls) of Subtitle D
waste facilities. Part IV provides data
on Subtitle D regulatory programs.
including information on regulation and
enforcement patterns. Part V contains
information with respect to the number
and quantity of Subtitle D facilities that
receive exempted small quantity
generator hazardous waste. Part VI
provides a summary and conclusions of
the report.
There are four appendices to the -
report Appendix A provides the
responses to a survey question
concerning Statewide landfill capacity
problems. Appendix B contains data
tables with estimates of landfill tipping
fees. The cover letters that accompanied
the questionnaire are in Appendix C.
Appendix D is a copy of the
questionnaire used for the survey.
Examples of some of the key survey
results contained in the report are as
follows:
(1) Approximately 227,000 Subtitle D
facilities are located at 120,000
establishment:
(2) The total number of Subtitle 0
disposal facilities includes: 16,416
landfills (of which 9,300 are municipal
waste landfills), 18,889 land application
units (LAUs), and 191.822 surface
impoundments:
(3) Roughly 16 percent of all Subtitle D
facilities, or 36,000. are reported to
receive hazardous wastes from
households or small quantity generators;
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Federal R-gister / Vol. 51. No. 215 / Thursday, November 6, 1986 / Notices
40355
(4) Very few facil.ties have extensive
design and operational controls and
very few facilities have systems to
monitor releases, and
(5) State Subtitle D regulations and
resources vary by State and Territory.
Ddted October 27, 1986 *~
J.W. McGraw, -:«-
•\c!:ng Assistant Administrator- Office of
So.'iJ Waste and Emergency Response.
(FR Doc 86-25101 Filed 11-5-66; 8 45 am]
BILLING CODE 856O-SO-M
FEDERAL RESERVE SYSTEM
Change in Bank Control Notice-,
Acquisition of Banks or Bank Holding
Companies
The notificants listed in this notice
have applied for the Board's approval
under the Change in Bank Control Act
(12 U.S.C. 1817(j) and I 225.41 of the
Board's Regulation Y (12 CFR 225.41) to
acquire a bank or bank holding
company. The factors that are
considered in acting on the notices are
set forth in paragraph 7 of the Act (12
U.S.C. 1817(|)(7).
The notices are available for
immediate inspection at the Federal
Reserve Bank indicated. Once the
notices have been accepted for
processing, they will also be available
for inspection at the offices of the Board
of Governors. Interested persons may
express their views in writing to the
Reserve Bank indicated for that notice
or to the offices of the Board of
Governors.
Comments regarding these
applications must be received not later
than November 21,1986.
A. Federal Reserve Bank of St Louis
(Randall C. Sumner, Vice President) 411
Locust Street, St. Louis. Missouri 63166:
1. The Citizens National Bank of
Bow/ing Green Employee Stock
Ownership Plan and Related Trust,
Bowling Green, Kentucky; to acquirt
16.58 percent of the voting shares of
Trans Financial Bancorp, Inc.. Bowling
Green, Kentucky, and thereby indirectly
acquire The Citizens National Bank of
Bowling Green, Bowling Green,
Kentucky.
B. Federal Reserve Bonk of
Minneapolis (James M. Lyon, Vice
•President) 250 Marquette Avenue.
Minneapolis. Minnesota 55480:
1. Arnold B. Chace, Jr., Malcolm G.
Chace, III. Malcolm G. Chace III Trust,
Malcolm G. Chace. Jr. Trust, Jane Chace
Trust, Jonathan Chace Clay Trust, Eliot
Chace Trust. Christian Nolen Trust,
Arnold B. Chace III Trust, Leigh Fibers,
Inc.. and William R. Oimeling to acquire
83.2 percent of the voting shares of
Escrow Corporation of America, Inc.,
Pennock, Minnesota, and thereby
indirectly acquire State Bank of
Pennock, Pennock. Minnesota; and
Heritage Bank. National Association.
Willmar, Minnesota.
2. David G. Smith, to acquire 51.13
percent, and Keith G. Eltreim, to acquire
48.87 percent of the voting shares of
Jasper Investment Company, Inc.,
jasper. Minnesota, and thereby
indirectly acquire Jasper State Bank,
Jasper, Minnesota.
Board of Governors of the Federal Reserve
System. October 31,1986.
James McAfee,
Associate Secretory of the Board.
[FR Doc. 86-25064 Filed 11-5-86; 8:45 am)
BIUJNQ CODE «210-01-*
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Public Health Service
National Toxicology Program, Board
of Scientific Counselors, Meeting
Pursuant to Pub. L. 92-463, notice is
hereby given of a meeting of the
National Toxicology Program (NTP)
Board of Scientific Counselors, U.S.
Public Health Service, in the Conference
Center, Building 101, South Campus,
National Institute of Environmental
Health Sciences, Research Triangle
Park, North Carolina, on November 25,
1986.
The meeting will be open to the public
from 8:30 a.m. until adjournment on
November 25. The preliminary agenda
with approximate times are as follows:
8:30 a.m.-9:00 a.m.—Report of the
Director
9:00 a.m.-9:30 a.m.—Overview of the
NIEHS Intramural Research Program
9:30 a.m.-10:00 a.m.—Overview of the
NTP
10:15 a.m.-ll:45 a.m.—Review of
Chemicals Nominated for NTP
Studies.
(Ten chemicals will be reviewed. Of
these, Five were reviewed by the NTP
Chemical Education Committee (CEC)
on April 29,1986, and listed in the
Federal Register, Volume 51, No. Ill, p.
21020, June 10.1986: (1) Cobalt
naphthenate; (2) Di(2-ethylhexyl)
sebecate: (3) Methylcyclopentadienyl
manganese tricarbonyl; (4) 2-
Methylquinoline; and (5) 4-
Methylquinoline. The remaining five
chemicals, which are benzodiazepine
drugs, were reviewed by the CEC on
September 16,1986, and listed in the
Federal Register, Volume 51, No. 197, pp.
36479-36480, October 10.1986: (1)
Chlordiazepoxide; (2) Clorazepate; (3)
Diazepam; (4) Flurazepam: and (5)
Oxazepam.)
12 30 p m.-t 45 p m —MEMS Ce",.. .:
and Genetic Toxicoiosv 3rdr.<-'- —5r "-
term Assay Evaluation
I. Introduction.
II. Comparison of//? Vitro Assav
Results with Rodent Carcmogenicity
III, Comparative Evaluation of Short-
term In Vivo Assay.
IV. Statistical Aspects.
V. Strategies for Testing and Other
Implications of the Evaluation.
The Executive Secretary, Dr. Larry G
Hart, Office of the Director, National
Toxicology Program. P.O. Box 12233.
Research Triangle Park, North Carolina
27709, telephone (919) 541-3971, FTS
629-3971, will have available a roster of
Board members and other program
information prior to the meeting and
summary minutes subsequent to the
meeting.
Dated: October 30.1986.
David P. Rail,
Director, National Toxicology Prog'-c-n
(FR Doc. 86-25087 Filed 11-5-tfO. 8 45 anj
BILLING CODE 4140-01-M
Restablishments
Pursuant to the Federal Advisory
Committee Act. Pub. L. 92-463 (5 L'.S C ,
Appendix 2). the Office of the Assistant
Secretary for Health announces the
reestablishment by the Secretary.
DHHS, with concurrence by the Genera!
Services Administration, of the
following advisory committees:
Designation: Health Care Technology
Study Section.
Purpose: The Study Section shall
advise the Secretary and make
recommendations to the Director,
National Center for Health Services
Research and Health Care Technology
Assessment, on research grant
applications in medicine, technology
assessment, the information sciences,
decision sciences (operations research,
industrial engineering, health care
administration), communications
technology, bioengineering, and related
fields as applied to hospital-based
ambulatory, and community health care.
The members of this Study Section shall
survey, as scientific leaders, the status
of research in their fields.
Designation: Health Services
Research and Developmental Grants
Review Committee.
Purpose: The Committee shall advise
the Secretary and make
recommendations to the Director,
National Center for Health Services
Research and Health Care Technology
Assessment, on research grant
applications of two general types. One
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IMPACTS
Limited information indicates that HHW have been found in the environment.
Indirect evidence suggests that HHW contributes to ground-water contamination
detected at a number of municipal disposal sites.
Although people certainly have been injured due to the presence of
hazardous waste in their homes, no data were available to show a correlation.
Impacts on refuse collectors and disposal personnel are easier to document.
Several communities across the nation have reported injuries to sanitation
workers that have been caused by HHW. These are often associated with
materials that splash or spill during compaction, containers that explode, or
emission of toxic fumes. Household hazardous wastes are considered as a prime
suspect in fires on collection trucks or at landfills.
COLLECTION PROGRAMS
Collection programs for household hazardous waste are operated at both the
local and state levels. Beginning only 3 to 4 years ago these activities have
grown rapidly in popularity. A directory of 100 communities that have
conducted programs is appended to this report. Nearly 200 collection programs
may be operated in 1986. Collection programs have many positive attributes.
Education" of the public and increased awareness of the presence of hazardous
materials in the home are major assets of these programs. Removal of these
wastes from long term, improper storage certainly reduces the potential for
injury or accident. The disposal of these wastes in permitted hazardous waste
facilities reduces potential impact on the environment.
Participation rates in HHW collection programs have been low. Few
programs can boast participation of even 1 percent of households in the
community, and several programs report participation less than 0.2 percent.
Quantities collected typically range from 20 to 40 pounds per contributing
household. This may represent several years accumulation of wastes. Thus
future collection efforts in the same area may result in even lower quantities
per participant household, assuming the same households participate.
Unit costs for these collection programs are extremely high. Cost data
are scarce and most program sponsors do not include factors for fringe
benefits, overhead, and other indirect costs or donated materials or services.
Relatively complete cost estimates (although based on several estimates)
indicate that a well publicized program with high participation costs well over
$2.00 per pound of HHW collected. Programs with limited publicity and low
participation may cost over $9.00 per pound ($18,000 per ton).
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SECTION 2
ANALYSIS METHODOLOGY
GENERAL PURPOSES AND PROJECT CONSTRAINTS
The overall purpose of this project was to conduct a survey of information
related to the topic of household hazardous wastes (HHW). This report refers
to safeguards associated with waste disposal rather than the degree to which an
item may injure someone or affect their health while the item is in the home.
The information collected was to be reviewed and summarized to provide general
information and some specific examples of activities on this topic. The
project was not intended to be a complete compilation of all information on the
topic, nor a listing and discussion of all known collection or regulatory
programs. Four general areas were to be addressed in the project, as follows:
t Definition - What are household hazardous wastes and how are they/could
they be defined?
• Quantities - How much household hazardous waste is generated?
a Impacts - What are the safety and environmental impacts related to
management of household hazardous wastes?
• Collection programs - What are some of the ways that local communities
and states are regulating and collecting these wastes?
The project had some limitations and constraints. These could generally
be described as funding and time. During conduct of the project it was found
that interest and .activities in HHW were growing rapidly. Interest at the
local, state, and Federal level was expanding and more and more states were
becoming interested in potential collection programs and legislation. The
number of local collection programs also greatly accelerated, thus during the
time frame of the project, the topic area was expanding so rapidly that the
project and this resulting report could not keep pace. Information collection
efforts had to cease at some point, even though new developments in the area
were continually being identified.
The project was a survey, with little provision made for original research
work. Thus, efforts primarily focused on the collection of existing
information either through printed materials or interviews with people active
in household hazardous wastes. The general purpose of the project added
constraints that should be clearly identified. These may be best described as
the things that the project and this report are not:
• It is not a complete discussion of (or even identification of) all
state or local HHW collection programs.
• It is not a compendium of conclusions and recommendations from these
collection programs. •
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• It is not a how-to-do-it manual to aid organizers of collection
efforts.
• It is not related to impacts on health or safety in the home.
The remainder of this section is devoted to presenting the methodologies
used throughout the project. It is divided generally in the same manner as the
entire report. Descriptions of what was done, quality assurance (follow-up)
measures that were used, and rationale are discussed.
DEFINITION
One of the purposes of the project was to develop a recommended definition
for household hazardous wastes. Initial steps in this effort were the review
of previously developed definitions and the EPA regulations related to HHW.
Early definitions were associated with local collection programs and were found
to not be true definitions, but essentially lists of household materials
accepted and therefore considered hazardous. Federal regulations related to
the definition of hazardous waste and the exclusion of household waste were
studied to provide precedents for a definition. State regulations and
definitions were not identified nor reviewed.
The definition, developed and presented in Section 3, was based on the
EPA's definitions of listed and characteristic hazardous wastes in 40 CFR 261.
This approach was considered consistent with the identification of hazardous
wastes from commercial generators. Additionally, use of the EPA
characteristics (corrosivity, reactivity, ignitability, and EP toxicity) allow
the incorporation of the related tests as the criteria against which the
household wastes could be tested.
In order to provide more specific examples of the definition, attempts
were made to identify categories of household materials that would meet the
definition. The approach involved the application of the knowledge of chemical
and environmental engineers to readily available information regarding
household products. Engineers visited grocery, drug, automotive, and variety
stores to obtain information about the composition of products that might fit
the definitions. Product labels were reviewed to identify major components of
these products. The components were compared against EPA listed hazardous
wastes (discarded commercial chemical products, etc.) as listed in 40 CFR
261.33. Chemical engineers applied their knowledge of the EPA characteristic
tests to the known ingredients to identify those products that almost certainly
or possibly would fail any one. Product labeling often provided little or no
information. Commonly only one or two ingredients were listed and usually no
percentage of composition was reported. This lack of label information was
supplemented by chemists' knowledge of the general formulation of such products
as paint thinners, drain openers, and engine additives. Where necessary,
information about these ingredients was obtained through standard chemical and
chemical engineering reference books.
Identification of types of household products considered hazardous was
strictly based upon best scientific judgement. Funding and time constraints of
the project precluded laboratory testing. Likewise, due to these constraints,
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no effort could be made to contact individual manufacturers of a product or
group of products to determine if the products had been tested against any of
the characteristic hazardous waste tests or to obtain other specific
information.
The lack of information about some types of materials put them into a gray
area. These materials that may be hazardous wastes are separately listed in
Exhibit 3-2. This second category was necessary solely due to project
constraints against actual testing. However, any testing program to completely
identify all materials meeting the hazardous household wastes definition would
be prohibitively expensive.
PRESENCE IN WASTESTREAM
The next major element of the project involved identification of informa-
tion reporting the quantity of the household hazardous waste in residential
wastes. No actual measurements of HHW quantitites were conducted in this
project. Reports on previous SCS Engineers'waste composition projects were
reviewed; however, no information was found in them related to specific
identification of HHW.
Known leaders in HHW collection efforts were contacted for information
about the presence of HHW in residential wastes. Through these contacts and
attendance of an EPA-sponsored solid waste conference, three organizations were
recognized as having past or present involvement with identifying these
wastes. Contact was made with each to fully understand their approach. Written
material was obtained from the organizations to the degree possible and was
reviewed thoroughly. To acquire additional information, personnel directly
involved with household waste characterization were interviewed by telephone.
The limited amount of information and resultant small number of data points led
to the decision to visit each of these organizations.
Interviews were conducted in person with representatives of each of the
three groups. One organization was the Los Angeles County Sanitation
Districts. The Districts had conducted two quantification projects that were
related to identifying hazardous waste coming to disposal sites. The data were
not directly related to residential sources; however, some inferences could be
made.
The second organization was the Environmental Health and Energy Department
of the City of Albuquerque, New Mexico. The Department had conducted a public
opinion survey regarding household hazardous waste. Estimates of the types and
quantities of these wastes in Albuquerque were based almost exclusively on the
opinions of the residents surveyed.
The third organization was the Anthropology Department at the University
of Arizona. Members of the Department have been conducting waste
characterization studies for several years. In the last 2 years, household
hazardous wastes have been identified and their presence has been noted in the
composition studies. No quantitative data were available at the time of the
interview.
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Essentially no defendable data were available relating the quantities of
hazardous wastes coming from homes and similar sources. The Los Angeles County
and Albuquerque projects resulted in estimates that could only put the data
into the broadest of perspectives. The Albuquerque data indicated household
hazardous waste was likely less than 1 percant of the residential wastestream
while the Los Angeles County information pointed toward a much smaller number
(approximately 0.00147 percent). Although these numbers are orders of
magnitude different from one another, it was inferred that they indicate that
HHW are likely a small (and probably a very small) percent of the residential
wastestream. The data were considered to be so tenuous that no attempt was
made to project nationwide quantities.
The interest in household hazardous waste has resulted in current waste
composition studies, including these waste types. The University of Arizona's
Department of Anthropology is continuing its work; the resulting quantitative
data should be available in the near future. Similarly, SCS Engineers is
conducting a waste composition study at six locations throughout the State of
Michigan. The definition of household hazardous waste developed in this report
is being used and these wastes are being identified throughout the conduct of
this project. These data will also likely be available at the conclusion of
the Michigan project.
IMPACT ON SOLID WASTE MANAGEMENT
Collection of information related to the impacts of household hazardous
waste on overall solid waste management, and on the environment, as well as
information about the HHW collection programs was initially obtained through a
series of telephone contacts. Organizational leaders of collection programs
were contacted and requests made for any reports related to the topic. Program
sponsors and others involved with household hazardous waste enthusiastically
responded providing reports and also providing the names and telephone numbers
of other involved individuals. This approach of contacting one person,
obtaining the information that they had available, and then asking for another
lead was used with good success. Frequently,
directed back to a small group of key individuals.
contacts, fewer and fewer new names were being
indicated that the truly significant individuals
hazardous wastes nationwide had been contacted.
project
After a
added to
the
in
interviewers were
number of telephone
the list. This
area of household
The reports and other written information as well as information provided
verbally was reviewed. Any reports that associated household hazardous waste
with injuries or other impacts on homeowners, sanitation workers, or on the
environment were noted. Follow-up telephone calls were used in some instances
to clarify the written materials and to provide details and up-to-the-minute
interpretations.
Information on environmental impacts was particularly scarce. Telephone
contacts with authors or others identified in these reports were used to obtain
all pertinent information. Even then only a very small number of reports
associated with potential environmental impacts could be identified. This is
likely because there appears to be no nationwide reporting network, nor any
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other organized means of identifying environmental, safety, or health impacts
associated with household hazardous wastes.
LOCAL AND STATE COLLECTION PROGRAMS AND CASE STUDIES
Initial efforts of information collection focused on obtaining as many
written reports, news articles, and similar items as possible. Often this
included the names of people actively involved with household hazardous waste
collection efforts. Key individuals were contacted by telephone to obtain more
detailed information about specific programs. The information collection
effort identified the rapidly changing and growing nature of household
hazardous waste programs. The number of states and communities interested in
this topic seem to be growing exponentially. Thus, information about every
state program and all the variations on local collection efforts could not be
included. Consequently, for this report, early state and local programs were
selected to provide some insight related to the history of interest in this
topic. Similarly, programs that represented typical approaches were highlight-
ed and described in order to provide information about the majority of these
efforts.
Detailed case studies of three programs were developed. One state
program (Florida) and two local collection programs (Albuquerque, NM and
Fairfax County, VA) were prepared. The Florida case study was based on written
reports and extensive telephone contact supplemented by collection of
population data for Florida that were used in estimating participation rates.
The two local collection program case studies involved direct observation
of the collection efforts. Project personnel coordinated with Albuquerque and
Fairfax County staff. All available written materials were obtained and
reviewed prior to the site visits. During the collection efforts, project
personnel were on hand to observe all aspects. Data were obtained from project
sponsors as available regarding numbers of participants, quantities of waste
collected, results of public opinion surveys, and program costs. In some
instances, these data were not available or only partially supplied. Best
engineering economic judgement was used to estimate missing cost elements.
Efforts were made to include estimates for all elements of the case study
collection programs. This included items that are often not considered,
especially when a governmental organization is involved. Therefore, estimates
were included for cost factors such as personnel overhead and fringe benefits
and the reasonable value of donated services and equipment.
A major weakness in the evaluation of the two local case studies and
other local programs is the lack of information concerning the effectiveness
and impact of public education. Public education is a major element of all
household hazardous waste collection programs. It certainly contributes to the
participation in the collection effort itself, and the degree of participation
is one measure of its effectiveness. However, there are many more, potentially
far-reaching benefits from these educational efforts. These benefits include:
safer management of household products prior to disposal; shifts in buying
habits from hazardous products to those that are non-hazardous; and a general
increased awareness of the environmental impact of home activities. Review of
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information regarding the case study locations and contacts with other program
sponsors nationwide indicated that there was no known effort to assess these
less tangible benefits.
SUMMARY
The methodology of this project essentially consisted of collecting
currently available published and unpublished information on the topic of
household hazardous waste. Scientific judgement was applied to EPA regulations
resulting in a definition of household hazardous waste. Knowledge of chemistry
was used to evaluate numerous types of household products to identify which
groups should be included in the category. No testing was possible due to
funding and time constraints.
Similarly, existing information was collected and reported as it related
to the impact of household hazardous waste and the approaches used to improve
their management and collection. Information available from written reports
and collected through the conduct of case studies was used to develop estimates
of quantifiable aspects of these programs such as participation rates,
quantities recovered per participant, and collection costs. Non-quantifiable
benefits were only identified.
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SECTION 3
DEFINITIONS
BACKGROUND
What are household hazardous wastes? The Environmental Protection Agency
(EPA) has not officially or completely defined the term in any regulations or
publications to date. Materials that are excluded from regulation as hazardous
wastes are identified in 40 CFR 261.4. One category is identified as household
waste. The regulations define household waste as including any waste materials
derived from households, including single and multiple residences, hotels,
motels, and other similar sources (40 CFR 261.4 (b)(l)). In the preamble to the
proposed hazardous waste regulations, EPA stated that "this exemption is based
on Congressional intent to exempt from the hazardous waste regulations those
wastes generated by consumers in their households, and not on the absence of
hazard from the waste." In fact, in the preamble to its final rule, EPA stated
that it was not attempting to pass judgement on the health and environmental
risks associated with these wastes.
•
On a related topic, the Agency discusses residues of hazardous waste in
empty containers (40 CFR 261.7). That regulation indicates that hazardous
wastes remaining in "empty" containers (residues up to one inch deep in the
bottom of the container) are not subject to regulation under Parts 261 through
265 and other parts of 40 CFR associated with the management of hazardous
waste. Thus, no regulations identify any household wastes as being hazardous
requiring regulated management from the point of generation through
transportation and on to final disposal at a permitted hazardous waste
facility.
However, several commonly-used household products would be classified as
hazardous wastes if they were generated by a commercial operation that exceeded
the small quantity generator limitation (i.e. less than 100 kg per month). In
other words, these materials are legally not hazardous because they are
generated in homes and in locations very similar to homes such as hotels and
motels. The same materials discarded from a large manufacturing or commercial
facility would be hazardous wastes and subject to all EPA RCRA Subtitle C
regulatory requirements.
Several organizations have attempted to define household hazardous wastes
(HHW) by listing items considered hazardous. These efforts have most commonly
been associated with community efforts to collect hazardous wastes from
homeowners. During these programs, which are discussed in more detail later in
this report, organizing personnel have used their best judgement and that of
preceeding similar programs to identify, for potential participants, those
types of household items considered hazardous. These lists or definitions often
may have been developed primarily to collect materials that could be harmful to
homeowners with secondary considerations given to environmental protection.
Impressions of what household items are and are not hazardous vary widely.
Householders often are ignorant of or underestimate the types and quantities
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of hazardous waste generated in homes. The City of Albuquerque conducted a
house-to-house residential survey in 1982. A total of 386 households were
visited to determine public awareness of HHW (1). One of the initial questions
requested the respondent to name as many different types of HHW as possible.
Twelve percent could not name any and therefore apparently felt that no
household items were considered hazardous. Forty percent of the respondents
could not name more than one type of material. In a follow-on question, the
respondents were asked to indicate the degree of hazard presented by specific
named types of household items. In addition to wastes such as drain openers
and paint thinner, the list included shampoo, mouthwash, and sawdust. At least
1 percent of homeowners identified these three items as extremely hazardous;
while three percent said poisons and pesticides were not hazardous.
Until now, there has been no known attempt to write a definition of a
household hazardous waste. The lists developed by organizations conducting
collection programs are a form of definition; however, they vary from place to
place and at best are educated guesses as to what materials should be included
in the universe of household hazardous waste. Although use of the listing
approach expedites identification of the wastes, providing helpful service to
the homeowners, it does not address the generic definition of household
hazardous waste. In this report, development of such a definition is necessary
to understand the nature and scope of household hazardous waste management.
DEFINITION OF HOUSEHOLD HAZARDOUS WASTES
In an attempt to define hazardous materials that could be disposed by
households, a fairly thorough investigation of products and their ingredients
was performed. This investigation consisted of visits to supermarkets, drug
stores, variety stores, and specialty stores (e.g., automotive supply, photo
supply) followed by qualitative evaluations by chemical and environmental
engineers. Laboratory testing was not performed because the wide range of
products and constituents would require a prohibitively expensive testing
program. Results of the investigation indicated that commercial products
generally fall into one of the following three categories:
• Items that are obviously hazardous;
t Items that are suspected to be hazardous; or
t Items that are obviously non-hazardous.
A definition of household hazardous waste was developed primarily based on
the EPA definition of household waste and the EPA classifications of hazardous
waste in the Resource Conservation and Recovery Act (RCRA) and associated
regulations. The definition is as follows:
Household Hazardous Wastes: Solid wastes discarded from homes or
similar sources as listed in 40 CFR 261.4 (b)(l) that are either
hazardous wastes as listed by EPA in 40 CFR, Parts 261.33 (e) or (f),
or wastes that exhibit any of the following characteristics as defined
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in 40 CFR Parts 261.21 through 261.24: ignitability, corrosivity,
reactivity, and EP toxicity.
The following section discusses the criteria for household hazardous wastes and
presents examples of products that meet the above definition. Note that the
above definition is based solely on Federal regulations and definitions. States
may have more stringent regulations. In those situations, any existing local
regulations and/or definitions should be applied.
CRITERIA FOR HOUSEHOLD HAZARDOUS WASTES
As stated in the definition, a household waste is considered hazardous if
it is a listed hazardous waste (discarded commercial product, etc.) or if it
exhibits any of four hazardous characteristics. The applicable hazardous waste
lists appear in 40 CFR Parts 261.33 (e) and (f). Copies of the lists are
included as Apendix A. Compounds appearing in 40 CFR 261.33 (e) have been
listed by EPA because of their acute toxicity, unless otherwise indicated on
the list by the letters T (toxicity) or R (reactivity). This list is commonly
referred to as the "acute" list or the "P" list because the hazardous waste
number for each of the compounds begins with the letter P.
Compounds appearing in 40 CFR 261.33 (f) are listed for toxicity unless
otherwise designated. This is commonly referred to as the "U" list because the
hazardous waste number for each of these materials begins with the letter U.
In accordance with the guidelines for hazardous wastes (see comment
following 40 CFR 261.33 (d)), a household waste is hazardous if "it consists of
the commercially pure grade" of a compound appearing on the P list or U list,
or if it consists of "any technical grades of the chemical that are produced or
marketed", or if it is a "formulation in which the chemical is the sole active
ingredient." This is particularly applicable to pesticides and herbicides.
While these products can be distributed in relatively concentrated forms for
industrial purposes, the commercial formulations purchased by the homeowner are
often diluted. Because the pesticides are the sole active ingredients in the
diluted formulations, these products are considered household hazardous wastes.
If a product contains a listed chemical, but this chemical is not the sole
active ingredient, then the product is not considered hazardous (unless the
product also exhibits any of the characteristics).
The four characteristics that can result in a waste being considered
hazardous are ignitability, corrosivity, reactivity, and EP toxicity. EPA has
developed definitions for each of these characteristics. These definitions
primarily specify standard test methods to be used to determine if a waste
exhibits one of the characteristics. Appendix B contains the EPA definitions
of these properties from 40 CFR Parts 261.21 through 261.24. A waste
exhibiting any of these properties is commonly called a "characteristic"
hazardous waste. Products exhibiting these characteristics often display
warnings on the labels such as "flammable", "combustable", "poison", "skin and
eye irritant", "injurious to eyes and skin", "harmful if swallowed", etc. The
lack of such a label, however, is no guarantee that the product is
non-hazardous.
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Exhibit 3-1 presents the generic types of wastes that can be considered
hazardous in accordance with the definition and information about the
constituents that make them hazardous. If the product appears in Exhibit 3-1
because it exhibits one of the four characteristic properties, the
characteristic that caused the product to be classified as hazardous is
indicated. If a product is considered hazardous because it is composed of a
listed compound, that is also noted in Exhibit 3-1.
While the generic types of products appearing in Exhibit 3-1 are those
that are most often hazardous, exceptions may exist. For example, the majority
of oven cleaners are hazardous due to their corrosivity. A few specific types
of oven cleaners, however, are composed of compounds that are either not
corrosive or are not present in sufficient concentration such that the
commercial product is corrosive in accordance with the EPA definition. These
products are the exception and not the rule. Exhibit 3-1 should not be
considered a complete list of the types of products that meet the definition of
household hazardous waste. Project schedule and funding limitations precluded
actual testing of any product, let alone all oven cleaners, etc.
In addition to the generic classifications, e.g. drain openers, or oven
cleaners, the specific chemical ingredient(s) that cause the waste to be
hazardous are identified in Exhibit 3-1. Also included are the specific
hazardous waste numbers for compounds appearing on the P list or U list, and/or
the property that causes the compound to be a characteristic waste (i.e,
ignitability, reactivity, corrosivity, or EP toxicity).
It must be realized that not all of the components listed in Exhibit 3-1
under a specific generic product type will exist in every product of that type.
For example, not every paint thinner contains all nine components listed under
the paint thinner category. The listed components are all ignitable compounds
that have been found in one or more of a variety of paint thinners. Each of
the listed compounds that are components of particular brand(s) of paint
thinner will contribute to the ignitability of the product. Sufficient
quantities of the components exist in most paint thinners that the mixture (the
product) is ignitable.
In reviewing the results of the product survey, it was found that many
products contain compounds that, when pure, would undoubtedly be considered
characteristic hazardous wastes. When these compounds are sufficiently
diluted, they no longer meet the criteria (e.g., pH for corrosivity, flash
point for ignitability) set forth in the EPA definitions. Unfortunately, few
commercial products list complete compositions, including both the components
and percentages. Usually, the label either lists components in descending
order of concentration (without giving the concentration), lists only the
primary components, or lists no information at all. There are many products
that may be characteristic hazardous wastes because of the components that are
listed on product labels or are commonly known to be ingredients. It is
uncertain, however, if these components are present in sufficient concentration
for the product to be hazardous. Exhibit 3-2 lists the generic types of wastes
that fall into this category, and the characteristic(s) that they may exhibit.
Exhibit 3-2 also provides the characteristic components that are likely present
in sufficient concentration such that the product may be a hazardous waste.
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EXHIBIT 3-1. HOUSEHOLD HAZARDOUS WASTES
AND THEIR HAZARDOUS COMPONENTS
I. HOUSEHOLD CLEANERS
A. Drain Openers; (C)*
1. Sodium Hydroxide; Lye; Caustic Soda; (C)
B. Oven Cleaners; (C)
1. Sodium Hydroxide; Lye; Caustic Soda; (C)
C. Wood and Metal Cleaners and Polishes; (I)
1. Petroleum Distillates; (I)
2. Petroleum Naptha; (I)
3. Turpentine; (I)
4. Isopropyl Alcohol; Isopropanol; (I)
II. AUTOMOTIVE PRODUCTS
A. Oil and Fuel Additives; (I)
1. Xylene; Xylol, Dimethyl benzene; (I), (U239)
2. Petroleum Distillates; (I)
3. Mineral Spirits; (I)
4. Methyl Alcohol; Methanol; (I), (U154)
5. Ethyl Ether; (I), (U117)
6. Secondary Butly Alcohol; Secondary Butanol; (I)
B. Grease and Rust Solvents; (I)
1. Petroleum Distillates; (I)
2. Cresylic Acid; Cresol; (I), (U052)
C. Carburetor and Fuel Injection Cleaners; (I)
1. Toluene; Toluol; (I), (U220)
2. Methyl Ethyl Ketone; MEK; Butanone; (I,T), (U159)
3. Methanol; Methyl Alcohol; (I), (U154)
4. Methyl Chloride; Chloromethane; (I,T), (U045)
5. Xylene; Xylol; Dimethyl benzene; (I), (U239)
6. Acetone; (I), (U002)
7. Diacetone Alcohol; (I)
D. Air Conditioning Refrigerants; (Listed)
1. Freon 12; Dichlorodifluoromethane; (U075)
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EXHIBIT 3-1 (continued)
II. AUTOMOTIVE PRODUCTS (continued)
E. Starter Fluids; (I or Listed)
1. Petroleum Distillates; (I)
2. Ethyl Ether; (I), (U117)
III. HOME MAINTENANCE AND IMPROVEMENT PRODUCTS
A. Paint Thinners; (I)
1. Mineral Spirits; (I)
2. Acetone; (I), (U002)
3. Petroleum Distillates; (I)
4. Methanol; Methyl Alcohol; (I), (U154)
5. Toluene; Toluol; (I), (U220)
6. Methyl Ethyl Ketone; MEK; Butanone; (I,T), (U159)
7. Turpentine; (I)
8. Isopropyl Alcohol; Isopropanol; (I)
• ' 9. Methyl Isobutyl Ketone; Isopropylacetone; (I), (U161)
B. Paint Strippers and Removers; (I)
1. Acetone; (I), (U002)
2. Toluene; Toluol; (I), (U220)
3. Petroleum Distillates; (I)
4. Methanol; Methyl Alcohol; (I)
C. Adhesives; (I)
1. Methyl Ethyl Ketone; MEK; Butanone; (I), (U159)
2. Petroleum Distillates; (I)
3. Acetone; (I) (U002)
4. Butyl Acetate, (I)
5. Mineral Spirits; (I)
6. Xylene, Xylol; Dimethyl benzene; (I), (U239)
7. Petroleum Naptha; (I)
8. Tetrahydrofuran; (I), (U213)
9. Isobutylacetate; (I)
10. Toluene; Toluol; (I), (U220)
11. Acyrlic Acid; (I), (U008)
12. Hexane; n-Hexane; (I)
13. Allyl isothiocyanate; Ally! isosulfocyanate;
mustard oil; (I)
14. Cyclohexane; (I) (U056)
15. Formaldehyde; (I), (U122)
16. Ethylene dichloride; 1,2-dichloroethane; (I), (U077)
17. Ethylidene Dichloride; 1,1,-Dichloroethane; (I), (U076)
3-6
-------
EXHIBIT 3-1 (Continued)
IV. LAWN AND GARDEN PRODUCTS
A. Herbicides; ( E or Listed)
1. 2,4-D: (E), (D016)
2. Si 1 vex; (U233)
3. 2,4,5-T; (U232)
B. Pesticides; (E or Listed)
1. Acrolein; (P003)
2. Aldicarb; (P007)
3. Aldrin; (P004)
4. Arsenic Acid; (P010)
5. Aziridine; Ehyleneimine; (P054)
6. Chlordane; (U036)
7. Creosote; (U051)
8. 2,4-D; (E), (D016)
9. ODD; (U060)
10. DDT; (U061)
11. Dieldrin; (P037)
12. Dimethoate; (P044)
13. Dinoseb; (P020)
14. Disulfoton; (P039)
15. Endosulfan; (P050)
16. Endrin; (P051)
17. Heptachlor; (P059)
18. Lindane; (U129)
19. Methoxychlor; (U247)
20. Methyl Parathion; (P071)
21. Parathion; (P089)
22. Pentachlorophenol; (U242)
23. Phorate: (P094)
24. Silvex; (U233)
25. 2,4,5-T; (U232)
26. Toxaphene; (P123)
27. Trichlorophenol; (U230, U231)
28. Warfarin; (P001)
3-7
-------
EXHIBIT 3-1 (Continued)
C. Fungicides/Wood Preservatives; (Listed)
1. Pentachlorophenol; (U242)
2. Trichlorophenol; (U230, U231)
*I: Ignitable per 40 CFR Part 261.21
C: Corrosive per 40 CFR Part 261.22
E: EP Toxic per 40 CFR Part 261.24
Listed: Listed in 40 CFR Part 261.33 (e) or (f)
D###: EPA hazardous waste number for a specific constitutent failing
the EP Toxicity Test, per 40 CFR Part 261.24
P###: EPA hazardous waste number for a specific acute hazardous waste
appearing in 40 CFR Part 261.33 (e)
U###: EPA hazardous waste number for a specific hazardous waste
appearing in 40 CFR Part 261.33 (f)
Note: Components listed must be present to such a degree that they re-
sult in the failure of a characteristic test by the generic item.
Important Note: Not all examples of any generic type shown above are
considered hazardous household wastes, e.g. some oven
cleaners will not fail the corrosivity test.
3-8
-------
EXHIBIT 3-2. OTHER HOUSEHOLD ITEMS
THAT MAY BE HAZARDOUS
I. HOUSEHOLD CLEANERS
A. Drain Openers; (C)*
1. Sodium Hydroxide; Lye; Caustic Soda; (C)
2. Potassium Hydroxide; (C)
3. Sulfuric Acid; (C)
4. Hydrogen Chloride; Hydrochloric Acid; Muriatic Acid; (C)
B. Oven Cleaners; (C)
1. Sodium Hydroxide; Lye; Caustic Soda; (C)
C. Toilet Bowl Cleaners (C)
1. Hydrogen Chloride, Hydrochloric Acid; Muriatic Acid; (C)
2. Sodium Acid Sulfate; (C)
D. General Purpose Cleaners; (C or I)
1. Oxalic Acid; (C)
2. Sodium Hydroxide; (C)
3. Ethyl Alcohol; (I)
E. Disinfectants; (C or I)
1. Sodium Salt of 0-phenyl phenol; Dowicide A; Natriphene; (C)
2. Pine Oil; (I)
3. Isopropyl Alcohol; Isopropanol; (I)
4. Ethanol; Ethyl Alcohol; (I)
II. AUTOMOTIVE PRODUCTS
A. Lubricating Fluids; (I or E)
1. Petroleum Distillates; (I)
2. Lead; (E)
B. Radiator Fluids and Additives
1. Morpholine; Tetrahydro-l,4-oxazine; (I)
3-9
-------
EXHIBIT 3-2 (Continued)
II. AUTOMOTIVE PRODUCTS (Continued)
C. Waxes, Polishes and Cleaners; (I or C)
1. Petroleum Distillates; (I)
2. Phosphoric Acid; (C)
D. Grease and Rust Solvents; (C)
1. Phosphoric Acid; (C)
2. Potassium Hydroxide; Caustic Potash; (C)
E. Body Putty; (I)
1. Toluene; Toluol; (I), (U220)
2. Butyl Acetate; (I)
3. Styrene; Vinyl Benzene; (I)
F. Transmission Additives; (I)
1. Xylene; Xylol; Dimethyl benzene; (I)
III. HONE MAINTENANCE AND IMPROVEMENT PRODUCTS
A. Paints; (I)
1. Xylene; Xylol; Dimethyl benzene; (I), (U239)
2. Toluene; Toluol; (I), (U220)
3. Propane; (I)
4. Vinyl Acetate; (I)
5. Amyl Acetate; (I)
6. Vinyl Toluene; Methyl Styrene; (I)
B. Paint Removers and Strippers; (C)
1. Hydrogen Chloride; Hydrochloric Acid; Muriatic Acid; (C)
C. ' Stains, Varnishes, and Sealants; (I)
1. Mineral Spirits; (I)
2. Petroleum Distillates; (I)
3-10
-------
EXHIBIT 3-2 (Continued)
IV. MISCELLANEOUS
A. Batteries; (C or E)
1. Sulfuric Acid; (C)
2. Mercury; (E)
3. Mercuric Oxide; (E)
4. Potassium Hydroxide; (C)
5. Sodium Hydroxide; (C)
6. Silver Oxide; (E)
7. Silver; (E)
8. Lead; (E).
9. Lead Peroxide; (E)
10. Lead sulfate; (E)
B. Fingernail Polish Removers; (I)
1. Acetone; (I), (U002)
2. Ethyl Acetate; (I), (U112)
C. Pool Chemicals; (R)
1. Sodium Dichloro-S-triazinetrione; (R)
D. Photo Processing Chemicals; (E, C, or I)
1. Silver; (E)
2. Selenium; (E)
3. Sulfuric Acid; (C)
4. Heptane; (I)
E. Electronic Items; (E)
1. Electrical Solder
a. Lead; (E)
b. Silver; (E)
2. Switches
a. Mercury; (E)
3-11
-------
EXHIBIT 3-2 (Continued)
IV. MISCELLANEOUS (Continued)
E. Electronic Items; (E) (Continued)
3. Floodlights
a. Mercury Vapor; (E)
*I: Ignitable per 40 CFR Part 261.21
C: Corrosive per 40 CFR Part 261.22
E: EP Toxic per 40 CFR Part 261.24
R: Reactive per 40 CFR Part 261-23
U###: EPA hazardous waste number for a specific hazardous waste
appearing in 40 CFR Part 261.33 (f)
Note: Components listed are examples of those likely to be found in
each generic type of item. The percentages of these components
in these items vary from one brand to another and thus the
components may result in the item being hazardous. However not
all examples of each generic type listed contain the listed
components (or other hazardous components) and these examples
would not likely fail any of the characteristic tests.
3-K
-------
Again, there will be exceptions to the products listed in Exhibits 3-2.
For example, not all general purpose cleaners are considered to be household
hazardous wastes. Also, not all general purpose cleaners containing oxalic
acid are corrosive. Some of these cleaners, however, may contain oxalic acid
in sufficient concentrations that they are corrosive according to the EPA
definition. Since product labels seldom give the percentages of these
ingredients, a cleaner containing an unknown concentration of oxalic acid may
be a household hazardous waste. In most cases where the product label supplies
the composition, a more reliable decision can be made as to whether the waste
exhibits any of the characteristics.
A review of Exhibits 3-1 and 3-2 indicates that there is some overlap.
Some drain openers, for example, are known to contain sufficient sodium
hydroxide to be corrosive. This is known because the label gives the
composition. This type of product is a household hazardous waste (Exhibit
3-1). Other drain openers list sodium hydroxide, and a variety of other
corrosive ingredients, but do not provide content percentages. Accordingly,
these appear on the list of items that may be hazardous, (Exhibit 3-2).
These exhibits should not be considered exhaustive lists of hazardous or
possibly hazardous household wastes. They are based on the best judgement of
chemical and environmental engineers, the results of the product component
survey, and on the properties of these components.
OTHER DEFINITIONS OF HOUSEHOLD HAZARDOUS WASTES
Several definitions of household hazardous wastes have been developed by
the organizations conducting waste surveys or operating HHW collection
programs. Invariably, these definitions are in the form of lists. The lists
usually include generic types of materials followed by specific examples.
Additionally, the collection programs often include a list of materials that
are not accepted. These lists of non-acceptable items are often developed to
reduce the potential danger to the personnel conducting the program and to the
homeowners transporting the materials to the collection center. Materials
usually excluded are explosives, gas cylinders, and unknown materials.
Exhibit 3-3 contains lists of generic household hazardous wastes and a few
examples as identified by organizations conducting household hazardous waste
surveys. The definitions contain virtually the same generic types of
materials. These are related to household cleaning and maintenance, automotive
products, paint products, pesticides, and miscellaneous products. The
University of Arizona and the Los Angeles County lists (definitions) are very
similar to one another and are the most comprehensive of the first four shown.
They both were used in waste composition studies. The thrust of the Los
Angeles County survey was primarily to identify industrial or commerical-type
products that might be hazardous. Some of the specific items identified were
not actually considered hazardous, e.g., suntan oil and skin cream, by the
Sanitation Districts. The Albuquerque list was used in a house-to-house survey
and not in a waste composition study. The Mother Earth News list was developed
primarily to advise its readers of potential chemical dangers to human health
in the home. . It was not directed toward wastes and it was restricted to
3-13
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EXHIBIT 3-3. COMPARISON OF HOUSEHOLD HAZARDOUS WASTE LISTS
CO
I
University of
Arizona (1 )
Household and Laundry
Cleaners and Maintenance
- toilet bowl cleaners
- drain openers
- laundry and dish cleaners
- furniture, floor , and
metal cleaners and polish
- oven cleaner
Automotive Maintenance
- oil
- anti -freeze
- engine treatments
- degreasers and solvents
Paint and Glue
- oil -based paint
and thinner
- stains
- glue
- solvents and paint removers
Plant, Yard and Pet
- fertilizers
- pesticides and herbicides
Other
- batteries
- nail polish and remover
Los Angeles County, CA
Sanitation Dist. (2)
Household and Cleaning
Products
- bleach
- drain opener
- window cleaners
- metal polish
- oven cleaner
- charcoal lighter
- glue
Automotive Products
- motor oi 1
- oil filters
- radiator sealers
- anti -freeze
- brake fluid
Paint Products
- paint
- paint thinner
Insecticides, Pesticides
Herbicides
- insect sprays
- germicides
- weed killers
Personal Iten..
- butane fuel
- hair spray
- suntan oil
- deodorant
Other
- Freon 12
- peroxide
City of Mother Wastes Listed in Exhibit 3-2
Albuquerque, Earth and Markedly Different from
NM (3) News (k) U of Az or LA County Lists
Household Products Utility Room
- cleaners " drain, toilet bowl
- polishes and window cleaners
- drain openers - oven cleaners
. glue - laundry products
- pesticides
Automotive ~ shoe care products
- motor oil " furniture polish
- anti -freeze - refrigerants
Paint ProHnchs Kitchen
- n*tr,t-* ~ preservatives
- Solvents and ' emulsifiers
thinners " flavoring/colorings
- pots and pans
- dinnerware
Plant, Yard and Pet
- weed killers fiathroom
- np
-------
materials in the home not including maintenance, hobby, or yard-related items.
Interestingly, it did identify constituents of building materials, such as
asbestos, as being hazardous.
It is interesting to note some of the items that were excluded from these
lists. Of the three survey programs, none specifically identified swimming
pool chemicals as a hazardous waste even though these areas certainly have many
home swimming pools. Similarly, none specified photographic chemicals or
electronic equipment. These three types of materials were likely excluded
because they were overlooked rather than because they were consciously
identified and then judged not to be hazardous. Exclusion through neglect is
common when definitions are developed through the use of lists or examples.
This should not be considered a major defect of the survey programs and merely
identifies a weakness in the entire topic area of household hazardous waste. It
is primarily due to the fact that researchers or other organizations have
become involved with the topic independent of one another. While the resultant
definitions generally concur with one another there are some differences
primarily re-lated to those types of materials that have been excluded just
because they were not considered as candidates.
Probably the most surprising group of materials to be included in most of
the lists are selected personal care items. It is unusual to think of
materials that are applied directly to the body as being hazardous. However
through reviewing product labels and through other research, some personal care
items have been listed and included in Exhibit 3-2. The inclusion of personal
care items is most often due to the presence of sufficient amounts of alcohols
(or other flammable volatiles) so that the product is considered ignitable.
Fingernail polish and polish remover were identified as a hazardous waste by
the University of Arizona. In its house-to-house survey, the City of
Albuquerque, New Mexico included mouthwash and shampoo with at least a few
respondents considering these items as hazardous to one degree or another and a
small number even considered these to be extremely hazardous.
The last column in Exhibit 3-3 relates the list in Exhibit 3-2 to the
University of Arizona and Los Angeles County lists. The last column indicates
additional types household items that may be hazardous wastes, primarily in
the areas of Automotive Products and the Other category. The only deletion
suggested in the last column is latex paints. Some surveys and possibly some
collection programs identify latex paints as hazardous. However, collection
programs usually do not accept latex paints because they are not likely
hazardous.
The types of wastes accepted during selected collection programs are
listed in Exhibit 3-4. Invariably, these lists are shorter than the lists
shown in Exhibit 3-3. The lists may be shorter because they were primarily
developed by program sponsors who were not technically oriented or did not have
access to the survey lists shown in Exhibit 3-3.
Most collection program sponsors indicate that they will accept nearly
anything that is delivered. Usually the collection programs are operated by
professional hazardous waste personnel who are capable of identifying and
3-15
-------
EXHIBIT 3-4
EXAMPLE WASTES IDENTIFIED FOR COMMUNITY COLLECTION DAY PROGRAMS
Fairfax County, Virginia
Albuquerque, New Mexico
Andover. Massachusetts
CO ;
I I
cr>
Solvents, spot removers
Pesticides
Oil-based paints and
thinners
Wood preservatives
Pool and photo chemicals
Chemistry sets
Flammable liquids including
gasoline and kerosene
Exclusions
- Latex paints
- Explosives
- Biologically active wastes
- Radioactive wastes
- Gas Cylinders
- Asbestos
- Waste oil
- Unkowns
Cleaning fluids, bleach,
ammonia
Solvents
Insecticides, herbicides,
fungicides
Paint, thinner, stripper
Wood preservatives
Brake Fluid, anti-freeze
Swimming pool chemicals
Anything else you would not
want your child to get into.
Exclusions
- Motor oil: direct to recycling
locations
- Biologicals
- Explosives
- Asbestos
Furniture Polish and
strippers
Paints and thinners
Solvents
Pesticides, herbicides
Fertilizer
Waste oil
Photo chemicals
Exlusions
- None identified
-------
properly handling a wide variety of waste materials. Wastes that are obviously
nonhazardous are collected together and hauled to the municipal disposal site.
REFERENCES
1. Residential Hazardous/Toxic Waste Survey, City of Albuquerque Environmental
Health and Energy Department, Albuquerque, NM, 1983.
2. Stecher, P.G., Finkel, M.J., Siegmund, O.H., Szafranski, B.M., Editors, The
Merck Index of Chemicals and Drums, Seventh Edition, Merck & Co., Inc.
, Rahway, N.J., 1960.
3. Weast, R.C., Editor, CRC Handbook of Chemistry and Physics, 60th Edition
CRC Press, Inc., Boca Raton, Florida, 1979.
4. National Fire Protection Association, Fire Protection Guide on Hazardous
Materials, Seventh Edition, 1978, Sections FPI, 325M, and 49.
5. Hammer, W., Occupational Safety Management and Engineering, Second Edition,
Prentice Hall, Inc., Englewood Cliffs, N.J., 1981, page 402.
6. Mother's Guide to Hazardous Household Substances, The Mother Earth News,
May/June 1984.
7. SCS Engineers, Disposal of Dilute Pesticide Solutions, EPA Contract No.
68-01-4729, November 1978, pages 8-10, 23, 49.
8. Davidson, J.M. et a!., University of Florida, EPA-600/2-80-124:
Adsorption, Movement, and Biological Degradation of Large
Concentrations of Selected Pesticides in Soils, Grant No. R803849,
August 1980, page 10.
9. SCS Engineers, Selected Biodegradation Techniques for Treatment and/or
Ultimate Disposal of Organic Materials, EPA Contract No. 68-03-2479,
March 1979, page 348.
3-17
-------
SECTION 4
PRESENCE IN WASTESTREAM
RESIDENTIAL WASTE GENERATION AND COMPOSITION
Generation Rates
How much solid waste does each person generate every day and what is the
composition of that waste? These questions have been asked since the early
1970's and even before when interest in solid waste management increased
dramatically. To this day, neither question has been answered completely or
conclusively. To answer these questions, much work remains to be done. Reasons
for ambiguous or differing answers include the fact that there is no "standard"
definition of residential wastes and the fact that refuse composition varies
from one season to the next. Similarly, there have been changes in waste
generation practices over the past 10 to 15 years that likely have impacted on
the amount and types of waste discarded.
Estimates of waste generation rates have varied widely. In the early
1970's, a commonly used figure was 5 pounds per person per day. This figure
was quickly found to be too large. It probably included all solid waste
collected in a community divided by the population of that community. The
waste quantity thus included industrial and commercial as well as the
residential refuse. Other estimates of residential waste generation rates fall
to 1 pound per person per day.
A primary difficulty in the estimation of waste generation rates is
defining what types of waste should and should not be included. All solid
wastes generated by householders should be included. Using that definition,
several types of wastes would be counted that normally would be excluded from
consideration. These include: garbage that is disposed by garbage grinders;
wastes that are disposed of on the owners' property such as grass clippings,
leaves, and composted materials; and waste materials that are source separated
for recycling. Bulky wastes such as furniture and appliances that require
special collection also should be included.
For purposes of this report, the wastes of concern should include all
those normally collected by municipal or private haulers and disposed in
sanitary landfills or through similar means. Essentially, this means that the
residential wastestream is whatever is put out in the trash can. Even this
varies across the country and throughout the year. Yard trimmings is a type of
waste with great variability. Locations in the South generate much more yard
waste than in other parts of the country. Around the year, there are changes in
waste generation rates. Summer is normally the time with highest waste
generation due to landscaping work and a general higher level of recreational
and other activities. Thus, any survey to estimate waste generation rates
should take into account seasonal as well as geographic variations.
The results of several waste generation surveys are shown in Exhibit 4-1.
They range in time from 1973 to 1985. The data indicate a range of generation
4-1
-------
EXHIBIT 4-1. RESIDENTIAL WASTE GENERATION RATES
Location/Year
Santa Clara County,
CA, 1977
San Francisco, CA
1977
Alameda County, CA
1977
Contra Costa County,
CA 1977
City of Tulsa, OK,
1985
Milwaukee, WI, 1978
Marin County, CA, 1980
Tucson, AZ, 1973-1980
North Santa Clara
Ib/oerson/dav Comments
3.3
3.3
2.3
3.5
2.8
1.1 Based on 3.0 person/household.
Does not include yard waste.
1.3 Base on 3,0 person/household.
1.1 Based on 3.0 person/household.
1.8 Northern portion of Santa Clara
County, CA 1983
Dorchester County, MD
1980
2.0
County.
Rural county. Includes wastes
identified as residential or
institutional and hauled to
municipal landfill.
SOURCES:
1. Survey of Solid waste Quantity and Composition in the San Francisco Bay
Area, SCS Engineers, Long Beach, CA, 1978.
2. Municipal Solid Waste Generation in Tulsa, Oklahoma, SCS Engineers,
Covington, KY, 1985.
3. The Milwaukee Garbage Project, Dr. William L. Rathje and Dr. Barry
Thompson, published by The Solid waste Council of the Paper Industry,
American Paper Institute, Washington, D.C, 1981.
4. Comprehensive Waste Characterization on a Quarterly Basis, J.C. Glaub and
G.M. Savage, Cal Recovery Systems, Inc., Richmond, CA, undated.
5. Dorchester County, Maryland Solid Waste Management Plan, SCS Engineers,
Reston, VA, 1980.
•2
-------
rates from
residential
included in
1.1 to 3.5 Ibs per person per day. All
refuse. Thus, wastes from commercial
the calculation of the generation rates.
proport to include only
establishments were not
Even the most closely
controlled surveys can include assumptions or data that are erroneous. The
source of refuse is sometimes uncertain since haulers sometimes collect both
commercial and residential waste using the same truck. Likewise, population
estimates or estimates of the number of persons per household are subject to
error and even slight differences, particularly in the number of persons in the
household. This can result in dramatic differences in calculated generation
rates.
The National Solid Waste Management Association (NSWMA) reported- average
residential waste generation in its "Technical Bulletin 85-6, Basic Data: Solid
Waste Amounts, Composition, and Management Systems". It estimates a solid
waste generation rate of 2.5 to 3.5 Ibs per person per day. The first five
entries in Exhibit 4-1 generally support that range. The range of 2.5 to 3.5
Ib per person per day appears to be accurate enough for large-scale planning
purposes and general reports covering wide geographic areas. Exceptions
definitely occur from place to place and throughout the year in any one
location.
Composition
Residential waste composition data are • scarce. Most reports of
composition are based upon visual observations and intuition rather than the
manual sorting and weighing of refuse and its components. Even weighing
programs have their limitations and the results are difficult to extrapolate
accurately.
Until the early 1970's, there was little interest in solid waste
composition. Early waste composition waste studies were motivated by interest
in recycling. Thus, the composition studies of the 1970's generally focused on
identifying recyclable materials. These included various grades of paper,
glass, usually aluminum and other metals separately, and sometimes wood and
plastics. Other components were considered as "others".
In the the late 1970's interests shifted toward the recovery of energy
from municipal waste through incineration. This caused a change in the
approach to waste composition studies. These studies stressed both the size
and general characteristics of the waste related to their energy recovery
potential. In general, the solid wastes were categorized as combustibles,
magnetics, non-ferrous metals, glass, and others. The presence of combustibles
gave incinerator planners information on the energy content of the refuse. The
presence of metals indicated what portions of the wastestream could be
separated by magnetic means or what waste portions might cause problems with
incinerator operations. Likewise, glass was seen as a problem material for
incinerator operations and its presence was usually identified.
Thus, the limited information bank on residential waste characteristics is
not consistent; nor are surveys easily comparable to one another. Exhibit 4-2
includes waste composition information from 10 locations. The studies were
4-3
-------
EXHIBIT 4-2. RESIDENTIAL WASTE COMPOSITION*
Santa Clara County
CA 19771
Santa Clara County,
CA 19842
San Francisco, CA
19771
St. John's Landfill
Portland, OR 19793
Rossman's Landfill
Portland, OR 19793
St. Louis, MO 19814
Los Angeles, CA
1981-825
Dearborn, MI
19796
San Diego County
CA, 19817
Burbank, CA
19808
Newsprint
12.2
13.0
10.8
10.3
8.1
N/A
6.3
8.1
9.1
7.9
Corrugated
3.1
14.9
6.6
3.9
5.1
N/A
4.0
N/A
5.5
4.8
Ferrous
Metal
4.8
3.4
4.4
7.1
6.6
4.4
6.3
3.1
4.0
3.7
Non- Ferrous
Metal (mostly
aluminum) .
1.0
0.9
1.0
N/A
N/A
1.1
2.0
0.3
1.0
1.4
Glass
7.7
7.7
7.3
N/A
N/A
7.4
4.3
3.3
8.8
6.8
Plastic
5.9
6.6
4.6
N/A
N/A
N/A
2.2
5.4
10.6
N/A
Organ ics
67.3
51.7
65.0
71.8
73.9
N/A
56.8
73.0
53.6
71.9
Misc.
Inorganics
N/A**
1.8
N/A
6.9
6.3
N/A
17.1
6.8
7.4
3.5
* Percent by weight
** Not Available
-------
EXHIBIT 4-2 (continued)
Sources:
1. Survey of Solid Waste Quantity and Composition in the San Francisco Bay Area, SCS Engineers,
Long Beach, CA, 1978.
2. Comprehensive Waste Characterization on a Quarterly Basis, J.C. Glaub and G.M. Savage, Cal
Recovery Systems, Inc.
3. Solid Waste Characteristics and Flow in the Portland Metropolitan Service District, SCS
Engineers, Long Beach, CA 1980.
4. Solid Waste Sampling Program St. Louis Resource Recovery Project, SCS Engineers, Long
Beach, CA, 1982.
5. Unpublished Data, Bureau of Sanitation, City of Los Angeles, CA.
6. A Comprehensive Municipal Refuse Characterization Program, Proceedings of the 1980 National
Waste Processing Conferences, American Society of Mechanical Engineers, May 1982.
7. An Applied Statistical Approach to Refuse Composition Sampling, A Comprehansive Municipal
refuse Characterization Program, Proceedings of the 1980 National Waste Processing
Conferences, American Society of Mechanical Engineers, May 1982.
8. Municipal Waste Characterization, Burbank California, SCS Engineers, Long Beach, CA 1980.
-------
conducted over the timeframe 1977 through 1984. .Although other data are
available, some are prior to 1970 and most support the figures shown. The data
seem to indicate fairly consistent composition from one location in the country
to another and over the seven-year time span represented. The most consistent
results include the following:
Material Percent bv Weight
Newsprint 8-12%
Corrugated 4-6%
Ferrous Metal 3-5%
Aluminum 1%
Glass 7-8%
Plastic 5-7%
The remainder primarily consists of other organic wastes. These include
other types of paper products, wood, yard debris, food wastes, rubber, and
leather which make up some 65 percent of the entire residential wastestream.
There has been a resurgence of interest in solid waste composition for
purposes of overall solid waste management planning including resource
recovery. SCS Engineers began an extensive solid waste composition study in
Michigan in February 1986. Wastes delivered to six disposal sites are being
manually sorted. The sites are located throughout the state and represent
urban and rural areas'. Composition surveys will be conducted four times in 12
months in order to account for seasonal variations.
HOUSEHOLD HAZARDOUS WASTES
Only three attempts at quantifying amounts of hazardous wastes coming
from households have been identified. Each has used a different approach and,
not surprisingly, the results of each are different from one another. The
small number of projects focusing on quantities of HHW reflects the relatively
recent nature of interest in this topic and the relatively large amount of
effort required to conduct a waste composition program.
The Los Angeles County Sanitation Districts conducted a limited
characterization study in 1979 (1). The purpose of the study was to estimate
the types and quantities of industrial-type wastes including both hazardous and
non-hazardous materials received at landfills and one transfer station in
Southern California. The first step in the effort was to identify these
wastes. The Districts developed the list of items of i-nterest as shown in
Section 3. Manual sorting and characterization of 155 tons of refuse were
included in the program. This program involved both a count of the number of
containers associated with HHW and measurement of the quantity of their
contents. More than 90 percent of the containers were considered empty.
The presence of hazardous wastes from all sources was found to be quite
low. The Districts estimated that notably less than 1 percent of all refuse
received at these facilities was hazardous. The majority of these wastes came
from commercial/industrial-type sources. It was estimated that less than 20
4-6
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percent of all hazardous waste entering the sites came from residential
sources.
In a more recent effort, the Los Angeles County Sanitation Districts have
been systematically sorting loads of refuse to identify hazardous waste. Since
California has a zero small quantity generator exemption, all commercial
sources of hazardous waste are legally required to dispose of those wastes in
permitted hazardous waste facilities. Thus, the thrust of the program is to
identify commercial violators. In 1984 and 1985, 5 to 6 refuse trucks per day
were inspected for hazardous wastes. The programs were conducted at four Los
Angeles County landfills and one transfer station. The inspectors were
primarily interested in identifying commercial-size quantities of hazardous
wastes and, therefore, typically looked for containers larger than one gallon
in size or for entire boxes full of hazardous wastes. Nearly 3,500 loads of
refuse representing some 15,000 tons of waste were searched in 1984. Results
indicated total hazardous waste to represent only 0.00147 percent of the tota.l
amount of waste delivered to these facilities.(2) Expressed in another way,
total hazardous waste was about 15 parts per million in the entire mixed
municipal waste stream including commercial as well as residential sources.
The Sanitation Districts caution against a comparison of results between
the 1979 and 1984 projects. In 1979, some 155 tons of refuse were sorted with
hazardous waste estimated at much less than 1 percent. The 1984 sorting
involved some 15,000 tons with hazardous waste estimated at 0.00147 percent.
Hazardous waste disposed 'at these municipal sites had not necessarily decreased
during this period. The data are too limited to draw any definite conclusions
regarding the exact presence of household hazardous waste, generation rates, or
trends in generation. A third approach in determining composition of
household hazardous wastes is described subsequently as part of the discussion
of the Albuquerque, NM residential hazardous waste survey.
Composition of Household Hazardous Wastes
Los Angeles County--
The 1979 project conducted in Los Angeles County involved waste
characterization to identify commercial and industrial-type wastes that might
be hazardous. The following are general results from that survey:(1)
• Household and cleaning 40.0 percent
products
• Automotive products 30.1 percent
(includes oil and antifreeze)
• Personal items 16.4 percent
• Paint and allied 7.5 percent
products
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• Insecticides, pesticides 2.5 percent
and herbicides
t Other 3.5 percent
University of Arizona--
The Department of Anthropology at the University of Arizona in Tucson has
conducted detailed residential refuse characterization from 1973 through the
present. During the two most recent years, efforts were focused on identifying
HHW. The types of items identified as hazardous were listed in Section 3. The
primary thrust of the characterization studies have been to count the number of
containers that could have or do contain hazardous waste. Future work will
involve determining the amounts of residue typically found in these containers.
One of the interesting results of this project is the estimate of the large
number of such containers discarded by each household every year. The project
was conducted in both Tucson, AZ and Marin County, CA near San Francisco. The
comparative results are as follows:(3)
Tucson. AZ Marin County, CA
Number of individual pickups
characterized 1,345 144
Hazardous waste items 1,195 160
Tons of refuse not including
yard waste 13.1 2.1
Hazardous waste items per ton 91 76
The University of Arizona indicates that about 100 hazardous items
(containers) are discarded per household each year. Thus, the some 120,000
households in Tucson generate approximately 11 million of these hazardous items
annually.(3) Again, essentially no research has been done to quantify the
contents of these containers; just to count them. The researchers caution that
their samples have been small and that extrapolating the data is crude, at
best. The actual degree of hazard represented by these materials and the
quantity of the materials going into the municipal landfills are quite
uncertain. As these hazardous materials continue to accumulate in landfills
the issue of a safety threshold becomes an increasingly vital public concern. A
better estimate of the potential environmental damage awaits a more thorough
determination of the presence of household hazardous waste as well as the types
and characteristics of these wastes.
City of Albuquerque, NM --
Albuquerque depends entirely upon ground water for its muncipal water
supply. After one of its wells became contaminated, the City undertook
industrial and residential hazardous waste surveys attempting to identify the
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source of contamination. The residential survey took an entirely different
approach from that used in Los Angeles or by the Univeristy of Arizona.
In January 1983, a house-to-house survey was conducted to obtain
information on waste generation habits.(4) The City's Environmental Health and
Energy Department identified 386 households to be included in the survey. These
households were divided amoung the four quandrants of the city in proportion to
population. Three basic questions were asked:
t What are household hazardous wastes?
• How hazardous are certain wastes?
t How much of each of these wastes did you dispose last year, and °how
were they disposed?
The first question was asked in a completely unassisted manner. The
interviewer asked the householder to identify as many of general types of
household hazardous wastes as they could. Twelve percent of the respondents
could not name any household hazardous wastes and an additional 28 percent
could only name one. Thus, without prompting, 40 percent of the householders
could not name more than one hazardous household waste. The most commonly
identified item was the group of household cleaners with over 60 percent of the
respondents identifying that type.(4)
The next question requested the householder to rate the degree of hazard
associated with selected items. Twelve household items frequently considered
hazardous were included in the list. Additionally, shampoo, sawdust and
mouthwash were included as "ringers". The respondents were asked to give their
opinion of an item's hazardous nature by responding in terms of a five point
scale, ranging from not hazardous to extremely hazardous. The results of the
survey are shown in Exhibit 4-3.
Interestingly, 3 percent of the respondents considered pesticides and
poisions not hazardous and 25 percent did not think motor oil was hazardous. On
the other end of the scale, 1 percent of the surveyed population thought that
mouthwash was extremely hazardous and 2 percent thought that both shampoo and
sawdust were extremely hazardous. The results indicate a wide range of
opinions as to what types of household items are and are not considered
hazardous.
The next step in the survey was an attempt to quantify the amounts of 12
hazardous items generated and disposed of by homeowners in Albuquerque. The
interviewer asked each person to estimate the quantity of each of 12 items that
they disposed during the past 12 months. Additionally respondents were
questioned about their method of disposal (e.g., putting the item out for city
refuse collection, pouring the substance down the sewer, hauling it to the
landfill, or using other land disposal methods). The results indicated that
the vast majority of HHW disposed in Albuquerque was automotive related. Waste
motor oil and antifreeze combined amounted to approximately 75 percent of the
total.(4) This is in contrast to household cleaners and polishes that amounted
to only about 2 percent of the total.
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EXHIBIT 4-3
ALBUQUERQUE, NM RESIDENTS'
PERCEPTIONS OF THE HAZARDS ASSOCIATED WITH
SELECTED TOXIC SUBSTANCES
Substance
Pesticides
Poisons
Household Cleaners
Household Pol ishes •
Drain Openers
Motor Oil
Antifreeze
Paints
Weed Killers
Ferti 1 izers
Glues
Shampoos
Sawdust
Mouthwasnes
Solvents or Thinners
1
Not
Hazardous
3%
3%
12%
25%
2%
25%
11%
11%
*%
18%
26%
61%
68%
80%
5%
2
Slightly
Hazardous
4%
1%
20%
30%
4%
20%
10%
15%
7%
21%
22%
20%
19%
U%
11%
Degree of
3
Hazardous
12%
7%
31%
27%
10%
33%
2*%
22%
13%
28%
16%
13%
7%
5%
H%
Hazard
4
Very
Hazardous
21%
15%
22%
10%
16%
12%
30%
18%
20%
15%
U%
4%
3%
1%
23%
5
Extreme 1 y
Hazardous
60%
7*%
1-6%
9%
68%
10%
25%
33%
56%
16%
22%
2%
2%
1%
46%
Source: Reference
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The Albuquerque survey included an estimate of HHW quantities generated
each year. Survey results, extrapolated a city population of 96,300 dwelling
units, yield an estimated 1.6 million pounds (800 tons) of HHW annually.(4)
Assuming 3.0 persons per dwelling unit and daily overall residential waste
generation rates of 2.5 to 3.5 Ib per person, the presence of HHW in
Albuquerque residential waste was approximately 0.5 percent.
The reader is cautioned not to interpret these results as indicative of
nationwide trends or to make other projections based on the results of the Los
Angeles or Albuquerque data. While the Los Angeles programs involved weighing,
they focused on commercial-size containers and, therefore, may have
underestimated the proportion of total household waste that is HHW. The
Albuquerque survey was based entirely on residents' responses and memories.
Neither could be called statistically accurate for numerous reasons. The
results should only be used to estimate, in the most general way, the types and
amounts of HHW. The lack of more substantial documentation of HHW generation
is definitely a data gap.
REFERENCES
1. Hand Sorting Fact Sheet, Los Angeles County Sanitation Districts, Solid
Waste Management Department, Whittier, CA, 1979.
2. Unnannounced Search Summary 1984, Los Angeles County Sanitation Districts,
Solid Waste Management Department, Whittier, CA 1984.
3. Preliminary Results from Household Phase Research, Department of
Anthropology, University of Arizona, Tucson, AZ, 1985.
4. Residential Hazardous/Toxic Waste Survey, Environmental Health and Energy
Department, City of Albuquerque, NM, 1983.
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SECTION 5
IMPACTS ON SOLID WASTE MANAGEMENT AND THE ENVIRONMENT
STORAGE AND COLLECTION
Impacts on the Public
The presence of HHW in the residential wastestream certainly has some
impact on not only the householder but also on refuse collection and disposal
personnel. In the vast majority of instances, disposal of hazardous waste from
homes likely does not harm anyone directly. However, there have been instances
across the country in which people have been injured by HHW.
Homeowners are probably the group most often affected. When hazardous
household products are misused or improperly stored or disposed, residents are
the ones most likely exposed to the dangers, and they will be subject to the
longest term exposure. Children and pets are also often present and they may
be particularly susceptable to the hazards posed by some household products.
The nature of some HHW also increases their potential damage to homeowners
over a period of time. Materials that are used infrequently are often stored
in closets, basements, or garages for long periods of time. Materials such as
paint thinners, solvents, fertilizers, and others may react with their
containers over the years, causing the containers to deteriorate. This further
increases the potential danger to homeowners.
There are no known studies or tabulations of injuries or illnesses to
homeowners related to HHW. However, burns from acids, respiratory problems
from volatile solvents, and other health impacts have certainly been caused or
aggravated by HHW. These incidents are not specifically reported as being
associated with the storage or disposal of hazardous waste but are lumped
together in general categories such as household accidents.
The special collection programs for household hazardous waste are
certainly directed in part at reducing the potential hazard to homeowners.
Educational aspects of the programs help the public identify HHW, provide
guidance related to the safe use of these materials, identify substitutes that
are less hazardous, and describe safe disposal methods. The collection aspects
of these programs result in removing pesticides, solvents, and other materials
that may be stored improperly over long periods of time. This definitely
reduces the chance of illness or injury. Of course, the actions associated
with the collection programs, i.e., homeowners collecting the materials and
transporting them to the collection location, certainly increase the potential
for exposure. However, this is for a relatively short period of time.
Refuse Collection
Refuse collection personnel are also affected by household hazardous
waste. Little has been done in the way of documenting injuries to refuse
collectors associated with the handling of these materials; however, some
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cities and organizations are aware of the potential and are trying to protect
sanitation workers. The Governmental Refuse Collection and Disposal
Association (GRCDA) has conducted a series of workshops across the country to
alert public waste management personnel to the presence of hazardous waste and
the related dangers. These workshops focus on both the presence of hazardous
waste from small commercial and industrial sources as well as from residential
sources. Tips have been provided as to how refuse collectors can identify
suspected hazardous waste and what to do when some of these material are found.
Public and private refuse haulers usually provide some form of safety
training to their employees. Usually this is associated with safety around the
collection vehicle and potential injuries associated with routine collection
activities. However, some cities are providing training associated with
hazardous waste.
• The City of Tempe, Arizona has implemented an extensive program related to
household hazardous wastes.(1) The program involves the Public Works
Department and the Fire Department. Public education, as well as planning for
hazardous waste incidents are elements of the program. The City is providing
education to its citizens to increase their awareness of what are hazardous
wastes and what to do with them. Announcements on cable television, the radio,
and in newspapers list commmon types of HHW. Suggestions are provided
regarding what not to do with them, e.g., mixing of certain materials or
dumping them down the sewer.
Additionally, Tempe provides a special pick-up service for HHW. Homeowners
who think they might have some hazardous wastes may call for the pick-up
service. In response to a call, a refuse supervisor and a fire inspector visit
the home to identify the material. If it is hazardous, it is removed, stored,
and eventually disposed via a hazardous waste contractor.
Training is also provided to City refuse collectors and street personnel
regarding hazardous wastes. This is conducted in conjunction with the fire
department and focuses on hazardous spills as well as HHW. Collectors are
trained to detect potential hazards and to respond appropriately. When a
suspicious item is identified, refuse collectors radio the dispatcher who then
informs the refuse and fire inspectors. The inspectors identify the .material
and, if it is determined to be hazardous, they isolate it from residents and
buildings as much as possible. If the waste is in one of the residential
automated collection containers, the entire container (up to 300 gal.) is
placed into a special overpacked drum the City has available for such
situations.
The training is thorough and, periodically, all personnel go through
refresher training. All new personnel receive the HHW training. Monthly and
quarterly safety meetings are used to update all personnel. To further
reinforce the training, the City periodically conducts simulated hazardous
waste incidents. Responses of personnel are evaluated and improved techniques
are developed and implemented. City personnel know of no other similar training
program in the country.
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The training and response programs were developed to minimize the impact
of improper storage and disposal of both household and commercial hazardous
wastes. Tempe personnel were concerned that the reduction of the small
quantity generator exclusion to 100 kg. per month would encourage owners of
small businesses to illegally dispose of their hazardous wastes in residential
containers. This may occur in Tempe where residential collection is fully
automated using 90 and 300 gallon containers.
Refuse collectors have been injured by HHW. The number and severity of
accidents, injuries, or health impacts associated strictly with HHW are
difficult to identify. The information is often vague and is not
centrally-located.(2) In most instances, injuries related to HHW have to be
inferred. However, the Association of Bay Area Governments in California
performed a study on inappropriate disposal of hazardous wastes from small
quantity generators and noted cases of injuries from inappropriate disposal of
HHW.(2) Most of the injuries occurred while the waste was being emptied or
compacted. Some of the incidents that have affected refuse collectors include:
• Serious injury to one refuse collector has been directly related to
HHW. A refuse worker in San Diego, CA lost his sight when hazardous
waste from a residence spilled on his face. The hauling firm notified
the residents of the injury and identified wastes that should not be
discarded in residential waste. The San Diego Environmental Health
Department was barraged with phone
A task force was formed that subs
program.(3)
inquiries on how to dispose of HHW.
equently developed the current City
A private firm in Lemon Grove, CA reported a number of incidents in
which swimming pool chemicals splashed on collection personnel during
the compaction of residential refuse. One worker lost 50 percent of
the use of his left eye.(2)
Used motor oil caused severe eye irritation of three disposal personnel
in Lemon Grove, CA. (2)
Severe eye irritation in one incident was caused by contact with paint
thinner also in Lemon Grove, CA.(2)
Some 42 incidents have been reported in Los Angeles County, CA related
to HHW. Injuries to refuse collectors have been caused primarily by
oil, battery acids, swimming pool chemicals, paints, and solvents.(4)
A refuse collector in Sacramento County, CA lost his sight when
splashed by swimming pool acid during compaction.(4)
At least three injuries per month occur in San Francisco, CA, caused by
exploding aerosol cans.(4)
A caustic material in residential refuse caused severe skin irritation
to a refuse collector in Roscoe, IL.(2)
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• A sealed container of ammonia burst under compaction and sprayed a
refuse collector's eyes and face in Boyne City, MI.(2)
HAULING AND DISPOSAL
Household hazardous wastes can also have negative impacts on the hauling
and disposal of refuse. A number of these wastes, particularly automotive
products, are ignitable. Therefore, it is certainly possible that some of them
have caused fires in refuse collection trucks. Fires in packer trucks are not
unusual. Personnel from the City of Tempe, Arizona report an average of five
such fires in the City's residential packers each year.(l) They believe there
are only two likely causes: hot ashes from barbecues or fireplaces, or
chemicals (HHW). Investigations have not identified the numbers of fires
attributable to each type of waste. However, if only one packer fire per year
in the city of 170,000 is caused by HHW and this number is extrapolated to the
entire country, HHW are a significant source of property loss and potential
injury or health impacts.
Personnel at a transfer station, landfill, or other disposal site may also
be injured by HHW. The activities of unloading, spreading, and compacting
refuse often cause containers to rupture and contents to be sprayed into the
air. Injuries and accidents at the disposal site have been reported for both
haulers and landfill personnel. Again, little tabulated- information is
available. However, reports from disposal site supervisory personnel indicated
that incidents related to hazardous wastes occur, but rather infrequently. This
relatively low level of reported incidents may be due to the perceived minor
nature of these events when they occur. Only accidents that require special
care such as the use of a respirator or something more than simple first aid
are likely to receive recognition as being related to HHW. Furthermore, a
landfill is a relatively accident-prone area and numerous cuts and burns occur
that are not related to hazardous waste.
The unusual or dramatic events related to hazardous waste are often
remembered. Some landfill personnel report gas cylinders in refuse that
rupture when the dozer runs over them, blowing off the end of the cylinder and
propelling it several yards. Other incidents are often associated with people
hauling their own wastes and unloading the vehicles by hand. Other types of
concerns includes inhalation of dust and vapors from HHW.
Some specific incidents involving disposal personnel have been associated
with HHW. Many are fires in packer trucks or at landfills. Although it is
difficult to prove the relationship between these events and HHW, intuitively
there is a connection.
• In Ashland, MA, a load caught fire while being unloaded at the
landfill. (2)
• In Evansville, IN, a load caused a fire that took four hours to
extinguish.(2)
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• A collection vehicle caught fire and was destroyed in Michigan from
flammable waste in the load.(2)
t A resource recovery facility was severely damaged by a fire from a
small container of flammable material in Wisconsin.(2) Explosions at
refuse shredders are often blamed on solvents in the residential waste.
• Three persons were hospitalized with rashes and respiratory problems at
a transfer station in Lexington, KY.(2)
• In Downers Grove, IL, chlorine tablets caused a fire in a truck.(4)
It is impossible to designate HHW as the sole cause of the injuries to
refuse collectors, landfill operators, or to collection and landfill equipment.
Factors such as the wide range of waste collected and the lack of detail in the
reported incidents preclude any definitive conclusions. While the presence of
household hazardous waste has no reportable or measured association with worker
safety, certainly it has an impact. Any steps to reduce the amount of these
materials being handled by haulers or disposal personnel will reduce these
hazards to them.
ENVIRONMENTAL IMPACTS
Does household hazardous waste have any impact on the environment? During
the conduct of this project, no documented cases were identified of
environmental impacts caused solely by HHW. However, this does not mean that
HHW do not impact the environment. There appears to be no nationwide reporting
procedure that includes information relating HHW to the environment. Thus, only
a scattering of individual reports were obtained.
HHW have been detected in surface water and in sewage in Seattle, WA.(5) A
study of urban streams in Seattle indicated that residents were disposing of
pesticides improperly such that they were migrating into the surface water.
Concurrently, analysis of wastewater indicated that some contaminants were from
homeowners disposing of HHW via the sanitary sewer system. Although no
environmental impacts were discovered, these incidents certainly verify the
presence of HHW in the environment and point to potential damage to ecosystems.
These studies led to implementation of the HHW collection program in the
Seattle area.(6)
Indirect evidence indicates that HHW may contribute to ground-water
contamination. More than 12 former municipal waste disposal sites are on the
National Priorities (Superfund) List of sites with contamination requiring
near-term corrective action. In the past, these sites received HHW and
commercial/industrial wastes (likely including hazardous wastes) in addition to
household refuse. The present ground-water contamination indicates that
industrial (or HHW) chemicals are the source of the problem. However no direct
proof exists that HHW are the only pollutants. This same situation is likely
present at many active municipal solid waste landfills.
The limited data from Los Angeles County and Albuquerque noted in Section
4, indicate that HHW makes up much less than 1 percent of the residential
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wastestream and it may be as little as 15 parts per million. Thus, these
materials are relatively rare and their impact on the environment may be
somewhat insulated by the presence of non-hazardous refuse. The landfill
environment may reduce the hazard of these materials. The actions of disposal
likely cause dispersion and at least brief exposure to the atmosphere. This
likely leads to evaporation of some liquids and the dispersion of the wastes
throughout a greater volume than in the closed container. Both situations
could lead to accelerated chemical or biological activity reducing the
hazardous nature of some of the materials.
Some hazardous constituents will persist in the environment for long
periods of time. They are candidates for migration into the air, ground water,
and surface water. Good management of a sanitary landfill will minimize the
impact of HHW on the environment. However, there certainly is some potential
for negative impact. Constituents from hazardous wastes can be leached as
water percolates through the refuse. Some HHW are volatile. The constituents
may become a part of the landfill gas being generated through decomposition of
organic materials. The gas may migrate and pose a health threat if found in
high enough concentrations. Another possibility is contamination of the ground
water through contact with landfill gas contaminated from household hazardous
waste.
In summary, there appears to be impacts on human health and the
environment from household hazardous waste. These impacts begin with the
homeowner and extend to the refuse collection and disposal activities. In
addition, after disposal in a landfill environment, HHW can contribute to
contamination of air, subsurface gas, ground water, and surface water. The
number and severity of accidents, injuries, or health impacts has not been
identified or tabulated. Intuitively, the overall impact of HHW is probably not
great. The amount of hazardous wastes in the residential waste stream is
probably small; however, even that is uncertain at this point. Only a few
household products are considered hazardous wastes as defined in Section 3 and
listed in Exhibit 3-1; granted, the list is not exhaustive. The majority of
suspected household hazardous wastes are not pure substances; thus, their
degree of hazard is less and probably much less than the same quantity of the
pure hazardous constituent, i.e., those constituents in industrial wastes
destined for management at a RCRA Subtitle C facility. A better estimate of
the potential environmental damage awaits a more thorough determination of the
presence of hazardous waste in the residential waste stream as well as the
types and characteristics of these wastes. Similarly documentation of any
environmental impacts that can be tied to HHW could shed light on this
question.
Possibly the greatest impact is on those in contact with these wastes.
This ranges from the homeowner to disposal site personnel. By definition,
these materials are wastes, and therefore may not be handled with extreme care.
Likewise their nature and the ways in which they are used and stored lead to
exposure and potential injury. Thus, any program designed to reduce the amount
of HHW from generator to disposal and to reduce the amount being stored by
homeowners should be beneficial to all concerned.
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REFERENCES
1. Personal Communication, Ronald L. Ottwell, Construction and Operations
Superintendent, Public Works Department, City of Tempe, AZ, October 29,
1985.
2. Association of Bay Area Governments, "Evidence of Inappropriate Disposal
of Hazardous Waste From Small Quantity Generators", Technical Memo No.
11 from L. Jackson Russel and N. Knappenberger, April 1984, p. 11.
3. Personal Communication, Diane Takvorian, San Diego Department of
Environmental Health, San Diego, CA, November 1, 1985.
4. Household Hazardous Waste: Solving The Disposal Dilemma, Golden Empire
Health Planning Center, Sacramento, CA, 1984.
5. Personal Communication, David Galvin, Seattle Metro, Seattle, WA,
• November 12, 1985.
6. White Hat Hazwaste Programs Target Homeowners, Small Shops, Waste Age,
May 1984, pp 83-84.
5-7
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SECTION 6
SPECIAL COLLECTION PROGRAMS
GOALS AND TYPES
Programs to collect household hazardous waste are operated at the local
and state level. Both local and state-wide HHW programs generally have five
goals:
• Increase general public awareness of the hazardous materials found in
most homes and how these materials may impact on human health and the
environment;
• Educate residents as to the best methods of HHW disposal;
• Remove HHW from homes, thus reducing exposure and potential injury;
0 Reduce danger to refuse collectors and other sanitation workers; and
• Provide proper disposal for HHW.
State-level programs are discussed in "the next section of this report. The
remainder of this section focuses on locally-sponsored and operated HHW
collection programs.
LOCAL PROGRAMS
Public Education
Public education is an important aspect of every local HHW collection
program. It focuses on several aspects to:
• Make the public aware of the presence of hazardous materials in the
home and consequences of improper use and disposal;
• Identify substitutes that are less hazardous;
• Encourage better home management practices such as buying only the
amount of hazardous material that is needed at any one time;
t Identify proper storage and disposal methods; and
• Promote participation in HHW collection and recycling programs.
The impacts of the educational aspects of collection programs are
difficult to assess. Thus, they may be overlooked. Only the participation in
the collection program gives a quantitative indication of the effectiveness of
public education efforts. Certainly, public health and safety benefits are
derived from these programs; however, no existing method to identify or
evaluate the improvement was noted during this project.
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Public education takes many forms. The appended case studies of
collection programs include discussions and examples of publicity and
educational materials. Some of the techniques that have been effective
include:
• Posters, handouts, and special lesson units in schools;
• Public service announcements on radio, TV, and cable TV;
• Inserts in utility bills;
• Meetings with civic organizations;
• Videotape and audio-slide presentations; and
• Endorsements and proclamations by local officials.
Collection program participation appears to be directly proportional to
the amount of publicity and educational material used. The Albuquerque program
began with an extensive public education effort 6 months prior to actual
collection. Numerous approaches were used including many meetings with
citizens' groups. Albquerque had very good participation, as noted in the
appended case study. In contrast, the Fairfax County, Virginia collection
program was conducted only 6 weeks after official approval. Public education
was limited, and participation was low. Details are in the appended case
study.
No attempt has been made to assess the impact of public education related
to HHW on the residents of Albuquerque or Fairfax County. However, it is
intuitive that Albuquerque citizens are generally better informed about HHW
than citizens of Fairfax County, and that the latter group know more about HHW
than residents of an area where a collection program has never been conducted.
Types of Collection Programs
Over the past three years more than 100 locally-sponsored household
hazardous waste collection programs have been conducted. In size, these have
ranged from a town or city to an entire county. Most of the local programs use
the collection site approach. In this approach, participants are asked to haul
their HHW to the collection site for centralized identification, packaging, and
shipment to a permitted hazardous waste facility. A few local programs have
provided service at the residents' homes. These have included community-wide
programs in which all residents could request curbside or backdoor collection
service and those programs that limited this level of service to the elderly or
handicapped as adjuncts to community collection site efforts.
Collection Sites
The collection site service is the most popular approach to HHW
collection. Basically, this involves selecting one or more collection sites,
setting a date, making the public aware of the service, and then conducting the
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program. The collection site approach requires the participating homeowners to
identify the HHW, haul the wastes to the collection site, and then (sometimes)
unload the materials as directed. This is nearly identical to the operation of
a recycling center with participants hauling recyclables to a central location.
There are several variations on numbers of sites and lengths of programs.
The most common is one site for one period of time (not repeated in the near
future). The time period ranges from 1 to 5 days. Examples of the single
location approach include many of the Massachusetts programs, Palo Alto, CA,
and Albuquerque, NM.(l) This approach is most applicable to small communities
and is less expensive than others.
Another variation involves using multiple sites either simultaneously or
in sequence. Two or more collection sites are constructed and operated. They
could be operated concurrently as was done in Fairfax, County, VA.(2) They
could be operated at different times from one another. In Sacramento, CA, an
urban collection site was operated on one Saturday and a suburban site on the
next.(3) Multiple sites are advantageous to large areas and may encourage
participation. Multiple sites are expensive, especially if operated
simultaneously, because multiple, trained crews must be employed.
Collection site programs are usually operated once. Some have been
repeated. The City of Palo Alto, CA, is researching the implementation of a
permanent collection site at a recycling service center located near a
municipal landfill. However, it would not be operated on a year-round basis,
due to the prohibitive cost.(3) San Bernardino County, CA, started a 12-month
pilot collection program in November of 1984. It involves continuous operation
of collection sites at two fire stations. If the program is judged successful
and desirable, it may be expanded to 10 or more fire stations and become a
permanent county function.(4)(5)
Door-to-Door Collection
Some communities have opted to use a door-to-door or curbside pick-up
approach. One community (Gresham, OR) attempted a one-day, curbside collection
of HHW from all residents. The approach was similar to curbside collection of
refuse or recyclables. However, the program was poorly publicized and
participation was minimal.(6)
San Diego, CA, is an example of a scheduled, on-demand collection program.
The City scheduled collection of HHW for specific days in different areas.
Householders were to telephone if they desired service and a specific
appointment was made.(7)
There are no known examples of continuous, on-demand programs in which a
resident may telephone at any time to schedule collection of HHW. However, the
Albuquerque, NM, program provided on-demand collection in conjunction with the
collection site operations. The phone-in service was restricted to residents
with transportation problems, the elderly, or the disabled.(8) Several other
collection site programs have provided this service, but only as part of a
collection site operation.
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Advice
Some communities provide advice to residents concerning proper disposal
methods for HHW. Usually, this guidance is offered in the form of a telephone
service that advises residents as to whether or not a particular waste is
hazardous. In addition, the service provides instruction regarding proper
disposal methods, and informs residents if any collection program is planned
or is in operation. For example, a telephone referral service is provided in
Cuyahoga County, Ohio (Cleveland area). Citizens use a publicized hotline
number to call the County Council on Hazardous Materials for instructions
concerning the proper disposal of HHW. If the waste in question is hazardous,
the citizen is told to take it to a commercial hazardous waste management firm
contracted by the Council to accept HHW. The program will operate through
September 1986 on grant funds from the U.S. Environmental Protection Agency. If
local resources are available, it will be extended.(9)
Sponsorship
Organizations within the local government often sponsor the collection
programs. These include departments or agencies related to environmental
protection, health, sanitation, or energy. The funds for these programs
usually come from allocations of general funds and monetary and service
donations from the community.
• •
In addition, public interest groups sponsor some collection programs. The
most active single organization across the country is the League of Women
Voters. The League frequently acts as a community catalyst for the initiation
of collection programs. It has helped organize collection programs in over 80
towns in Massachusetts alone and numerous other localities across the nation.
Funds for programs sponsored by public interest groups come from the groups
themselves and are often supplemented with donations from individuals or other
service organizations. Quite often, services are donated such as the use of a
collection site, the use of equipment, or the availability of chemical
expertise to identify wastes. Similarly, local governments will often make
allocations of funds to these programs.
Private firms also sponsor local collection efforts. Sponsors have most
frequently included commercial hazardous waste management firms and chemical
manufacturers. Programs sponsored by these organizations are usually developed
to promote the public image of the sponsor, in addition to collection of the
hazardous waste. Funds are sometimes strictly those of the sponsoring company,
but may also include donations of services and monetary contributions from
public service groups or even governments, public interest groups, and private
organizations.
Brief History
It is hard to pinpoi.nt the actual "first" household hazardous waste
collection program. Many programs seem to have begun simultaneously. The
first exclusively household hazardous waste collection day resulted from the
efforts of the League of Women Voters in Lexington, MA. It took place on
October 30, 1982. A total of 93 households participated in the collection day,
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and 770 gallons of HHW were collected at a cost of $1,600. Since then, an
increasing number of communities in Massachusetts have held collection days. In
1983, 14 communities collected nearly 20,000 gallons of HHW. The total cost for
these collection days was about $37,000. In 1984, 31 communities collected
over 46,000 gallons of waste at an estimated cost of nearly $108,000.(10) In
1985, over 80 communities in the State have or will hold HHW collection
days.(11) The State of Massachusetts Department of Environmental Management
has announced a $400,000 grant to sponsor a state-wide program.
In Seattle, WA, a program was also begun in 1982 and was sponsored by the
King County Health Department. This county-wide collection program allowed
citizens to make an appointment to bring in pesticides and old wood
preservatives. County sanitarians conducted the program and were responsible
for receiving and manifesting the materials. This has since become an ongoing
program.(6)
Another Seattle, WA, program was sponsored by Seattle-Metro in 1982. The
results of a study revealed that a large percentage of the waste that was
contaminating the water supply was of residential origin.(12)(13) This
prompted Seattle-Metro to sponsor an educational program aimed at the public,
governmental agencies, educational institutions, waste haulers, and environ-
mental groups. Initially, participation in the collection program was poor,
yielding 500 gallons of waste annually. Since the program began more
aggressive publicity of the collection efforts, participation has increased.
Over 3000 gallons of waste were collected in 1985.(14)
Probably the very first collection program that included HHW and
commercial small quantity generator waste was a program conducted by the State
of Alaska Department of Environmental Conservation in 1982. Wastes were
collected from 41 small businesses and government agencies (small quantity
generators) and 48 households in Fairbanks and Anchorage. The 7,000 pounds of
waste collected in the 12-day program was transported to Oregon and disposed in
a hazardous waste landfill.(6)
As early as 1981, the Marion County Health Department in Lebanon, KY,
sponsored a program to collect pesticides from residents, small businesses,
schools, and agricultural firms during a 5-day program. The total quantity
collected amounted to 1,400 Ibs of solid chemicals and 500 Ibs of liquids at a
total cost of $1,200. Funding for this project was provided by local
government sources.(12) Other states and communities have followed, designing
programs to their specific needs; (e.g, the State of Virginia sponsored a
program in 1983 to collect hazardous waste from community colleges, senior and
junior high schools).(15)
The State of Oregon Department of Environmental Quality (in conjunction
with the local fire department) sponsored a unique door-to-door program in
Gresham, OR, in 1983. Department of Environmental Quality personnel and
firefighters visited each home on a pre-designated day. Because the community
was not notified as to the time of day the collection would take place, the
participation rate was very poor.(6) It was the first HHW collection program
in which the wastes were collected from the residents at their homes.
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Many household hazardous waste collection day programs have been sponsored
by various organizations throughout California. Between 1982 and 1984,
collection programs were conducted in several cities including Sacramento, Palo
Alto, and Red!and. All of these programs required residents to deliver the
wastes to a collection center.(12)
Subsequent to these examples of early HHW collection efforts, similar pro-
grams have spread to many states and numerous communities. Appendix C lists
collection programs. The list is not complete due to the rapidly changing num-
ber of programs and the lack of a central clearing house for data related to
HHW.
The idea of household hazardous waste collection is not limited to the
United States. Other countries such as Canada and Denmark which have permanent
regional collection sites. West Germany, and Australia also have become
involved and aware of the potential environmental contamination from household
hazardous wastes.(11)
REFERENCES
1. Personal Communication, Loreen Russell, Associate of Bay Area
Governments, Berkeley, CA, July 31, 1985.
2. Personal Communication, Robin Byrd, Department of Public Works,
Wastewater Treatment Dept., Fairfax, VA, September 26, 1985.
3. Personal Communication, Miriam Gensemer, Southern California Association
of Governments, Los Angeles, CA, August 1, 1985.
4. Personal Communication, Judy Orttung, San Bernardino County Health Dept.,
San Bernardino, CA, July 31, 1985.
5. Personal Communication, Judy Orttung, San Bernardino County Health
Department, San Bernardino, CA, October 31, 1985.
6. Household Hazardous Waste Solving the Disposal Dilemma - Program Design,
Gina Purin, Golden Empire Health Planning Center, Sacramento, CA, 1985
p. 8-24.
7. Personal Communication, Diane Takvorian, San Diego Department of
Environmental Health, San Diego, CA, September 5, 1985.
8. Personal Communication, Donna Lacombe, City of Albuquerque, Environmental
Health and Energy Department, Albuquerque, NM, October 18, 1985.
9. Personal Communication, Ken Westlake, U.S. Environmental Protection
Agency , Region V, Chicago, IL, February 20, 1986.
10. Worksheet: Massachusetts Household Hazardous Waste Collections for 1982,
1983, and 1984, Dana Duxbury, League of Women Voters, Boston, MA.
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11. Personal Communication, Dana Duxbury, League of Women Voters, Boston,
MA, September 4, 1985.
12. Examples of Household and Small Business Hazardous Waste Disposal
Programs Implemented in the U.S. and Canada, K.P. Lindstrom and Golden
Empire Health Planning Center.
13. Personal Communication, Susan Ridgely, Minnesota Pollution Control
Department, St. Paul, MN, November 1, 1985.
14. Personal Communication, David Galvin, Seattle-Metro, Seattle, WA, March
25, 1986.
15. Personal Communication, Dana Duxbury, League of Women Voters, Boston,
MA, September 4, 1985.
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SECTION 7
STATE PROGRAMS
Several states have become involved in household hazardous wastes. Up to
26 states may be in various stages of studying the issues related to HHW,
drafting legislation or regulations, planning collection programs, providing
grants to local communities, or establishing state-level collection
efforts (1). At least four states are known to have active programs. These
include Vermont, Connecticut, Florida, and Rhode Island. These state programs
fall into two categories: grants to local collection efforts and
state-operated collection programs. These states are among the earliest to
become involved in the topic; their programs are some of the most mature, and
are briefly described below. Activities in Washington and Minnesota are also
included.
Each of these state programs includes elements of public education and
publicity, either conducted at the state level or by the local sponsoring
organizations. No information has been available as to the impact of these
programs, other than the resultant participation in the collection efforts.
However, it is intuitive that safety and environmental benefits resulted from
these programs.
VERMONT
Vermont's interest in HHW started in its General Assembly. It directed
the State's Agency for Environmental Conservation to study methods of
collection and to prepare a report. During the study, the Agency identified a
proposed HHW collection program in Hartford, VT and nearby Hanover, NH. The
Agency decided to provide a grant to cover most of the program's costs.(2)
Several organizations became involved with the program. Each was
responsible for various aspects of the effort. Participants included the
following:(2)
• Town of Hartford, VT - supplied the collection site;
• Upper Valley and Lake Seneca Council - provided overall coordination
including planning, subcontracting, co-sponsor participation, and any
reports;
t New England Marine Contractors, Inc. - served as the hazardous waste
disposal contractor;
t Upper Valley Hazardous Waste Committee - was involved in the publicity
and conducting the survey of participants; and
• Vermont Department of Agriculture - provided technical assistance and
personnel to inventory and assess pesticides.
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The Agency for Environmental Conservation assessed the results of the
Hartford program. Participation and cost data are presented in later sections
of this report. The Agency is considering a grant for a program in another
area. If that program is conducted and considered successful, Vermont will
assess the feasibility of a permanent HHW collection program.
The outcome of the Hartford Collection Day represents the total efforts of
the Vermont program to date. The grant from the Agency of Environmental
Conservation was $4,300. No estimate is available for the value of the
services provided by the Vermont Department of Agriculture and the other groups
noted above. Participation and quantities recovered are listed below.
Duration: one day
Number of participants: 110
Number of households in area: 16,000
Participation rate (110/16,000 x 100): 0.7%
Weight of waste collected: ' 3,000 Ibs
Amount of waste per participant: 27 Ibs
Costs: reported costs of $5,000
Cost per pound of waste: $1.67 based on reported cost of $5,000
CONNECTICUT
Connecticut's program, operated by its Department of Environmental
Protection, is very similar to Vermont's. It was developed in response to
interest by several communities. Funds for the grant project were appropriated
through the State of Connecticut legislature as a part of the Department of
Environmental Conservation's annual budget. It provides grants to local
communities that operate HHW collection projects. The state grants pay 50
percent of the collection and disposal costs. All other costs are borne by the
community through public funds or donations. Communities must apply for the
grants. To date, 50 towns will receive grant funds for the first collection
programs to be held in the spring of 1986 (3).
Connecticut provides written guidelines pertaining to HHW collection days.
However, it does not want to get involved with regulation of HHW. The expense,
difficulty in enforcement, and lack of manpower are some of the reasons
cited (3).
FLORIDA
Florida was the first state to fund and operate a HHW collection program.
Given the name "Amnesty Days", the Florida program involves more than just HHW.
It includes small businesses and institutions as well as residential sources.
The former sources may use the collection program without getting involved with
the legal requirements of manifests, etc.
The collection program was established by Florida's Water Quality
Assurance Act of 1983. It directed the Department of Environmental Regulation
to establish and conduct Amnesty Day programs throughout the State. Funds come
from a Water Quality Assurance Trust Fund. Limitations on expenses include a 5
percent ceiling on administrative costs and the same limit on public education.
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The remainder pays for the actual collection and disposal activities which are
contracted.
Extensive publicity was used to inform Florida residents and businesses
about the Amnesty Day Program. This included television announcements, radio
public service announcements, pamphlets, films, newspaper ads, and electric and
water bill inserts. Also many organizations such as the Florida League of
Cities, State Association of County governments, Florida Fireman's Association,
Gulf Power and other organizations enclosed Amnesty Day information in their
newsletters. As the first state-level program, Amnesty Day not only received
intense media coverage within Florida, but the program was also covered by
prestigious publications such as the New York Times, The Wall Street Journal,
and even the National Geographic.
Operations
Two mobile collection facilities are used in Florida. They consist of
semi-trailers containing small laboratories and storage space for the wastes
collected. A hazardous waste contractor provides the trailers and all other
services directly related to the collections. The contractor also hauls the
wastes to permitted disposal facilities.
The collection facilities are set up in two locations simultaneously. They
may be in the same county if warranted by the population, or in two different
counties. Each facility is operated from 1 to 6 days at each location, again
depending on population and anticipated participation from businesses. The
entire Amnesty Day program is based on a three-year cycle with the provision of
at least one collection day per county during a three-year period. More
details about the Florida program are included in the appended case study.
Results
Amnesty Days had completed three phases through June 1985. Summary
results of the three phases are noted below (4)(5).
• Average weight of waste collected: 701,400 Ibs = 351 tons
• Number of participants: 7,000 (includes businesses and institutions)
• Weight of waste per participant: 100 Ibs.
• Area and population served: 28 counties with a 1980 population of
7,259,700 living in 2,787,800 households, representing 42 percent of
Florida's counties and 74 percent of its population.
• Household participation rates assuming each "participant" represented a
household: 7,000/2,787,800 = 0.25 percent
• Range of household participation rates: 0.10 to 1.8 percent
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• Estimated cost: $2,200,000 (6)
• Cost per pound of waste: $3.14
RHODE ISLAND
Rhode Island's program is similar to the one in Florida.(7) It is called
Household Toxic Cleanup Day and is sponsored by the Rhode Island Department of
Environmental Management, (DEM) Air and Hazardous Materials Section. A
contracted hazardous waste management firm operates one-day Cleanup Days at
five locations in the State, and disposes of the collected wastes. This
program, occurring annually over" the past two years, includes participation by
educational institutions and local government agencies, in addition to
households. It is designed and operated by the DEM and is funded by a bond
issue. The annual program will be repeated until the funds are exhausted. At
that time, another bond referendum will be voted upon.
There is also an on-demand program in Rhode Island. Depending upon the
situation, as deemed by the DEM, a caller will either be told to store his HHW
until the next collection day or, in an emergency situation, DEM personnel will
collect the HHW from the home and dispose of it. An emergency situation is
declared when a resident moves out of state, or if the type of waste is
considered too dangerous for household storage. Such dangerous materials
include laboratory chemicals, explosives, and radioactive waste. (6)
Operations
The DEM completely funds, designs, and supervises the HHW collection days.
Only the handling, packaging, transportation, and disposal of the HHW are
performed by a hazardous waste contractor. The DEM identifies the program
locations based on the number of requests from towns in the state. Collection
sites are always located on state-owned property, usually at schools or
equipment yards.
Personnel at all of the collection sites consist of DEM staff or the
contracted disposal firm employees. Volunteers are not used. When a
participant enters a site, a DEM employee obtains identification information
about the participant and removes the waste from the vehicle. The waste is
moved to the processing area where contractor personnel identify, sort, and
package the materials.
The DEM accepts all HHW delivered to the site without a quantity limit. A
unique aspect of the program is the method of sorting the wastes.
Pharmaceuticals are given to a drug control agency; explosives and highly
reactive wastes are given to the local fire marshal!; fertilizer and
nonhazardous pesticides are given to a local nursery for reuse; and waste oil
is recycled by the State at maintenance garages. The State plans to continue
this program format, and has no plans for a permanent transfer and storage
facility.
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Results
Results of the most recent collection day were available and are shown
below.(7)
• Number of participants: 350 (includes schools and local government
agencies)
Amount of liquid waste collected: 4600 gal (est 34,500 Ib)
Amount of solid waste collected: 300 Ibs
Population served: 20,000
Weight of waste per participant: 99 Ibs.
Expendables, disposal: $15,000 per day
Cost per pound of waste: $0.43
Note that the above costs do not include administrative costs of the entire
State program that should be allocated to this specific collection day, nor are
publicity costs included.
WASHINGTON
One continuous HHW collection prcfgram is being conducted in the Seattle
metropolitan area of Washington. (8) Six permanent storage and transfer
stations are located throughout the area. Operations are on-demand. Residents
telephone a local health department office and make arrangements to take the
HHW to the nearest location. The resident is met at the site and the waste is
accepted, identified, and stored. Periodically, a contracted hazardous waste
hauler collects the wastes and transports them to a permitted disposal site.
Currently, the services of both the hauler and the disposal site are donated to
the program.
The Health Department assumes the role of generator. Its personnel fill
out the manifest and the department is responsible for the wastes until they
leave the collection site. Participation in the program has been reported as
light. A total of only 4 to 5 hours is expended at all collection sites each
week.(8)
In September 1985, a law was passed in Washington State that requires
County governments to develop and operate programs to manage both HHW and
hazardous wastes from small quantity generators. Regulations for these programs
are now being developed. Additionally, the State is setting up a telephone
hot-line to provide advice related to HHW.
MINNESOTA
The State of Minnesota is conducting a two-year study of HHW.(9) The
study will be conducted in three phases and will assess the operations and
effectiveness of local collection programs. In the first phase, the State
provides funds for local HHW collection programs and may plan and operate some
programs. At other locations State funds will be used by local governments or
private firms to operate programs. In addition, publicity and public education
portions of the State's HHW program are funded by a U.S. Environmental
Protection Grant of $25,000 (under RCRA, Section 8001 FY 1985 grant). Minnesota
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will conduct programs in urban, rural, and suburban areas. Objectives of the
two-year study are to:
t Identify the types of wastes brought to HHW collection days;
• Compare geographically the types and amounts of wastes, e.g.
- Urban vs rural and
- Geographic regions within the State;
• Identify the types of people who participate in HHW collection days;
and
• Conduct before and after interviews to determine behavioral changes.
In the second phase, HHW collection programs will be repeated in selected
locations. Participation rates and waste quantitities will be identified and
compared to initial programs. Funding for repeated programs will be shared
between the State and the local communities. Data collected during the first
two phases will be analyzed in the third phase. Results of the study will be
presented to the Minnesota Legislature and used as the basis for future
decisions related to HHW collection programs.
REFERENCES
1. Personal Communication, Dana Duxbury, Tufts University Center for
Environmental Managert, Medford, MA, February 18, 1986.
2. Methods and Programs for the Collection and Disposal of Household
Quantities of Hazardous Waste - January 10, 1985, State of
Vermont Department of Environmental Conservation, Montpelier, VT.
3. Personal Communication, Leslie Lewis, Connecticut Department of
Environmental Protection, Hartford, CT, October 29, 1985.
4. Amnesty Day Collection Totals, Florida Department of Environmental
Regulation, Tallahassee, FL, 1985.
5. County and City Data Book, 1983, U.S. Department of the Census, U.S.
Government Printing Office, 1983.
6. Personal Communication, Jan Keeman, Florida Department of Environmental
Regulation, Tallahassee, FL, November 1, 1985.
7. Personal Communication, John Hartley, Rhode Island Department of
Environmental Management, November 5, 1985.
8. Personal Communication, David Galvin, Seattle-Metro, Seattle, WA,
November 6, 1985.
9. Personal Communication, Susan Ridgely, Minnesota Pollution Control Agency,
St. Paul, MN, November 1, 1985.
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SECTION 8
MAJOR ISSUES
LIABILITY
Hazardous waste regulations and liability are the first and foremost
issues of concern to any organization contemplating a household hazardous waste
collection program. Homeowners and others generating household hazardous waste
are not required to comply with the Federal RCRA regulations regarding
manifesting and other activities associated with hazardous waste. However,
State regulations may differ from Federal regulations and compliance with local
restrictions is also a consideration for organizers of HHW collection programs.
From the Federal standpoint, RCRA does not address HHW collection
programs, nor are any limits set above which HHW become regulated under its
Subtitle C (hazardous waste) regulations. A memo interpreting RCRA and CERCLA
liability associated with HHW collection programs is included in Appendix E.
areas of concern for liability associated with HHW
t General liability including
There are two
collection programs:
- Collection program personnel;
- The public participating in the program;
- Property damage that might occur at the collection site; and
- Damage, injuries, or other incidents that might occur while the
waste is being transported from the collection site.
t CERCLA liability related to potential future impacts caused by the
ultimate disposal site.
General Liability
Program sponsors usually want to minimize their liability. In the
majority of instances, a hazardous waste management contractor is utilized to
operate the collection site. Thus, the contractor takes on the liability
associated with operating the collection site at least in terms of the
personnel and site being under its control.
This is
Some liability exposure usually remains with the program sponsor. ,.,.- ,„
often associated with liability for the actions of its employees or members and
liability associated with the collection site if the site is owned by the
sponsoring agency, e.g., the high school parking lot used in the •- ' " ••"
by
Fairfax, VA
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program. These aspects of liability are usually protected by insurance carried
by the sponsor.
For programs conducted by municipal or county governments, public
liability insurance provides coverage or is extended by a special rider.
Counties with programs covered by liability insurance include those in Marion
County, KY and Bernallio County, NM as well as Fairfax County, VA. In a
collection program in Sacramento, CA, the hazardous waste contractor added the
collection program sponsors to its own liability insurance policy that insured
the sponsors as well as the contractor against lawsuits. Insurance costs are a
portion of the overall program costs and are included in contractors' bids. In
some instances, the sponsoring agency does not have public liability insurance
that could be expanded to include collection day activities.
Two states have become involved in the question of liability. In the
program operated by the State of Florida, the State has considered itself
liable only for its own employees. Thus, the hazardous waste contractor must
carry public liability insurance for any damage that might occur at the
collection sites or during transport of the wastes. In Massachusetts, the
Department of Environmental Quality requires that any community planning to
hold a HHW collection program obtain Department approval of the firm
transporting the waste with the transporter being required to be liable for
transportation accidents and spills. The transporters must carry insurance for
bodily injury, property damage, and environments! restoration.
In general, collection program sponsors want to minimize their liability
exposure. Usually this is done by hiring a waste contractor to which as much
liability is transferred as is possible. This approach minimizes the number of
organizations potentially involved with litigation and minimizes the direct
liability of the sponsoring agency.
CERCLA Liability
An issue of concern for many communities planning HHW collection programs
relates to long-term liability related to the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA or Superfund). In general,
if a waste disposal site (hazardous or non-hazardous) is identified as a
significant source of pollution and listed as a Superfund site for clean-up,
sources of the waste as well as the owner or operator of the site could be
liable for clean-up costs. HHW collection program sponsors thus could be the
target of related law suits including citizens' suits. Some communities have
cancelled plans for collection programs because of this issue.(1)
Concern about the potential liability of HHW programs under both CERCLA
and RCRA led to preparation of a memo from the EPA Office of Solid Waste's
Waste Management and Economics Division. That memo and others on the same
topic are included in Appendix E. The memo content relating to CERCLA
liability is summarized briefly in the following paragraph.
Household wastes containing hazardous substances as delineated in CERCLA
Sections 101(14) and 102(a) are considered hazardous under CERCLA and,.
therefore, are subject to CERCLA liability (Section 107). Similarly, HHW
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consisting of any of the substances listed in Table 302.4 of 40 CFR Part 302
definitely would be classified as a hazardous substance. Although the HHW
quantities generated by collection programs are relatively small, as compared
to wastes generated by SQGs and the larger commercial sources, any amount is
subject to CERCLA liability. This poses a problem for collection programs in
that the waste sources, e.g. the communities, could become liable if a landfill
used for HHW disposal eventually becomes a CERCLA site. EPA is still
evaluating its CERCLA enforcement policy regarding this issue (see Appendix E).
DEGREE OF REGULATION
Currently, there appears to be a very low degree of regulation from State
and local governments regarding household hazardous waste collection programs.
However, as the collection programs increase in number, their visibility
increases. More States are developing interests in HHW than previously and it
is likely that State legislation and local ordinances will increase. City and
county governments often pass resolutions establishing public HHW collection
programs or at least acknowledging those planned by public service groups or
private organizations. This often does nothing more than identify the concept,
and give sanction to the use of public facilities, equipment, and personnel
during the program.
The State of Florida has passed laws specifically addressing the
collection of household hazardous waste. This is done under the Amnesty Day
Program legislation and is more fully described in the Florida case study in
Appendix D. The Florida law requires that a State agency provide collection
service to each county in the State within a three-year period. This law is
the basis for the appropriation of funds and the establishment of staff
positions to manage this program. Other States may have laws or regulations,
including those directed at hazardous wastes, that indirectly regulate HHW.
REFERENCE
1. Personal Communication, Dana Duxbury, Tufts University Center for Envir-
onmental Managment, Medford, MA, February 18, 1986.
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APPENDIX A
40 CFR PARTS 261.33 (e) AND (f)
A-l
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ro
} 261.33
I2C1.U Diiordtd canmcrcUl chemical
producU, off-ipecincatlon •peclu, con-
Ulaer reiUuci, and iplll reiUuc*
thereof.
The following maUrlaU or Itenu are
hazardous wastes when they are dis-
carded or Intended to be discarded as
described In 1261.2UXJMI). when they
are burned for purposes of energy re-
covery In lieu of their original Intend-
ed use. when they are used to produce
fuels in lieu of their original Intended
use. when they are applied to the land
In lieu of their original Intended use.
or whet the? are contained in prod-
ucts that are applied to the land In
lieu of their original Intended use.
(a) Any commercial chemical prod-
uct, or manufacturing chemical Inter-
mediate having the generic name
listed In paragraph (e) or (ft of this
section.
40 CM Ch. I (7-1-iS Edition)
chemical Intermediates referred to In
paragraphs (a) through (d) of this sec-
tion, are Identified as acute hazardous
wastes (H) and are subject to be the
small quantity exclusion defined In
Environmental Protection Agency
S 261.33
tCommtxt: fat the convenience of the regu-
lated community the primary huardoiu
properties of these materials have been Indi-
cated by the letters T (Toilcltyt. uul R (Re-
activity). Abience of a letter Indicate* that
the compound only I* luted for acute toxlcl-
•M
These wastes and their correspond-
ing EPA Hazardous Waste Numbers
are:
..
Mil.
MM
Mil.
POM .
POM...
Mil
P024
Mil .
M2I-
POtt...
HI4..
PHIS .
Ml* .
Ml*
PMI..
pin .
PI03
mi
wza
pool.
Mil
Mtt
P0!4 .
POH
M2I
P0»
Aceuntle. t auto-
Ac**: ecU. »«»o-. wdM MI
»(e*lie-AMoi
end Mb. .ten piMOTI M
••eler VIM 03X
l-Acelrl-I-Mam
MM Kcoliol
venedMe
I
e«Ue
Amnlc M arid*
Aillne. JMt*
4 <**»<>-
•teuenemlne. 4-nlfee*
BxqKMnU*
Cemfitwne. ocucNofO-
CwbenMdoMtifiolc edd
Ceriwn^OilaU.
CMaflM cyeride
POU.
PI I*.
POM
POU
POU
POM.
MM .
POOI .
POM
POM
Mil
PHI
Pill
MM .
POM
PMI
O.O.OWh|l CHqiumx
IJ-DlrmSnt I linitVMoHtuuniiro. O-
llr^MVMnotc.bon^l odm.
aaOBMOV OiMArapMnnl pteejAora-
cedd.MTeMV*etar
E(h4Wi*». I.l-tenll
Etwnemlne. Hae*«MMrgea.
I.44.I<*MK.
1.41 ^rHnmi«ii»m.Milln»>.
Hxcuy luMnui |H.n
U«Nwi*. o«|Ua4cMQi(
Mrtun.. WrMMo-ID)
POM
MM
POM .
ran.
POI2
Mil
POM
MI4 ..
Mil.
Mil.
Ml*..
Mil
Mil...
Ml*.
Mil. .
MU
MM..
posa
MM.
Mil .
pair .
MM
MM .
MM...
H4* .
P04I
M20
POM..
Ml* .
POOI.
POU
MM .
MM..
POM .
PMI...
P044
M41...
POM .
POM
H40
PIIO
MM
PIOI...
Mil .
MM
PMI
Mil.
PIOI
POOI
POM.
PM?...
PIOI .
MM
ran
PHI
PIOI
PI04
(MM hplrun*
eMu-HvMhiONoi
Nickel Munf
Mckilc«end>
Mcmhe end MM
MMceride
MtrooMdkM*
Nttog«i|IV| add»
mKtoMMfm
IMort«»>»
l-OneUqrcMI i I Itapune 2.34c«tx»ylc
•dd
PtnlNoii
PlMnal. 2-crdahw)|(-4>dlnHie-
Pimci. 1.4-djmio-
PlMnal. I.4.atMko-.
Ph»m4 dfcMwoerWie
Plwirlr
nmftauxMMtc ecu. O.Oam.lhyl HI
PhosctwraSuaflc edd. t^rlf mei^ltlliya
eelet
HmfhaOHaKi KM. O.O4M*M S-
fatlylMotflMllyl Ml4f
HmfnaaHak edd. O.OHMhrl O- p>ieiU|l
KM, O.OnirMeiil O-liHIit-
" vfelMnyll..!*
Pkattene. MreMV
~ lUwkm crenkto
Potaukn eh«r crerlde
onrlliato.
PigpenenHe. KNoo-
PiopemnMe. l«rdra
lAl-PiopeMiM. Mnl
.
PraiwnlilcoM
IP««>4n.|«l
UPnWyMnMne
PyfOfilicwphQrtc KM. Mi««ihv« tsttr
SMMtottfM
-------
40 CFR Ch. I (7-1-U Edition)
Environmental Protection Agency
§ 261.33
PIM
PI07
PIM
POM
PIM .
PIM
PIM
PIM
Pill .
PII2
eoti
PII3
PI 13
PIM
PUS
PMS
P04I
POM. .
PIM .
POM
P072
P093
PI23
Pllt
PI20
PI20.
POOI
PI2I
PI22
PI22
Sadkim cfmU
SkoMhni tHUt
StryctmH. iM Mta
Sulhric KU. IU*iniW
IhUumO) Mtorfto
ThMknUII
INolmx
TMnKrttfcu
IMoplMnol
TMouM.
IMauiM. pMn*
Vciudbnl pcnkwkte
V«»dlum(V) otkta
ZhccymiU
ZhcphOiptiU>|R.D
the phoipnu.. .tan p
km atMUf Mn 10*
(f) The commercial chemical prod-
ucts, manufacturing chemical Interme-
diates, or off specification commercial
chemical products referred to In para-
graphs «n«<™«ly4 |H II
Scntww, llyijroqr-
.
Bmxii. 1 neKll-l 2.44UU-
1-inMhil !.•
Swim. l.2fl
*X*,4f.Cf~*
.
BWIM. nHio- g.T)
BMUMM, iMnUcMwo-
Bwnnuulloiilc KD ditoAU |C.B|
Bwivw. 1.2 4.S ukKMna-
e«u«i», U
0234
UUI
U202
UI20
U022
0022
UU7
UU3
UOU
UOU
11021
U07J
UMI
UOM.
UOM
U02J
U244 ..
UOM
U24>
U22» .
U030..
UIM
Ulll .
UIU.
UIU.
uon .
UOM...
UOJI .
UIM...
UOM..
IHJi
um .
Ulll..
UI1J
U2I»
UMI..
U2I»
UIU..
UM3
mil...
11033 ..
UOM..
UOM..
UOM...
UOM...
U03I ..
UOM
UMI.
U042
UMI...
UM*.
UMt
U012
UMO..
UMI
UOU
UOU...
UOU .
U06S .
U24(..
Ulll .
UOU.
UMI..
UIM
UOU
U240
UOU
phw*.
1.1.2.3.4.
l«uUnmln.. N4»*4N
4 IBta(2-cNMv*M*»>l
f SuunoM iwodk .
J.44O. Mb vd MHO
OMnomydn
UOM
UI33
U22I
UOB3
UOM
UOM
UOM
UMI
UM2
U070
U07I
U072
U073
U074
0075
UIM
UOU
UMI
U07I
UOII
U02S
UMI
UOU.
U240
UM4 .
UOU
UIM
UI4I
UMO.
UMI
UOM
UMS.
UOM
UOU
UIOI
0102
UIOI
UIM.
UIM.
UIOI
UIM
UIM .
UIM.
Ulll
UOOI
UIM
UM7
UOII .
UOII
UIM
UI3I.
0024
000)
Ulll
U02I
UIM
ODD
DOT
O.CKNoiaaculirdio-t.34 nwtfMMto 2H
cydofcuulc dl
Dwmmololum*
O*>«1J[..I> Until. .c.n.
1.2 51 OlwiixilhiK*!.
1.2 I.B ObMUOpyfMI.
I.2-HMOI1IO-3 dilcMopiofKn*
Mufti pHIullta
8 (2 3 aataiM^ A topiapvllMocMiiiml.
3.3-
l,4O«Hl
>44«tM*«.T)
OOiaat»ai>na>ft»at
acHam dytaail itcNaoMIwi*
CkcMaa itplwiil McMnoMMn.
1.2 OlcMaii»lh|tM>.
2.4 OkMBtapnml
2i4CkcM«opl«no>yKMc ud.
1.1 DkHonvrapm
l21.4Ckvo.t4luUn.ll.il
1.4 Dwh|l«i> donitl
l.4Okuwi>
1.2
EIMMIPI
E»M«, I.I dsJitao
EMM. UdkNara-
l.lftovvOttonM
EtMn*. I
ElMnMUM 0. tl
ttm*. 1,1 KU|«li(2-cnara-
Etwt.. p«iUcHon>-
-------
S 261.33
40 Ctt Ch. I (7-l-M Cdlli.n)
Environmental Protection Agency
§241.33
Huwdouc
WnUNo
U2M
U20»
1811
U247
U227
U043
O042
U07I
U07I
U2IO
UI73
U004
UOM
UII2
Ulll
U2M
UOM
UIM
U067
U077
UIIS .
Ulll
UII7
U07I
Ulll .
UIM .
UI20
UI22
UI24
UI25
UI47
ui25 .
UI2«
U2M
UI2fl
UIU.
UI27
UI2I
UI2I .
UIM
UI3I
UIM
U243
UI33
IIOM
UOM
UOM
uioe
UI34
UIM
UI35
UOM
U136
Ulll
UI37
Ur.ll
UIW
UMl
UI42
UI43
U144
UH5 .
UMl
UI47
Elton.. I.I.I 2 MKMon^
Ettiw.. 1.1.2.2 MildllOfO-
Elhm.
phw*
Eton.. t.l.2-McNan>-
UIM
UISI
UIU
I.I.I. MCMU04.2 kWMtxxi UM2
UOM .
U045
ElMn.. l.l-dfcNor*
Elm. «v».|.24iMof»
EtfMn.. l.l.*.2tolrKMarti».
Eltanol. l.KMevMialu,
E0.no->.. I pt»n«l
EFl»
Fuiwi. Mrinydii>. M
FwknlW
H.«KNaraUiu«i.
HuKMoobiUdw.
a H«MH>4N'i«ia-
HMKNOfMNUMW
Hydwin.* .
Hyakuln.. l.24Mtiyt
Hydfukx. l.24aMh|t
ItyioOuonc Kid (C.T)
MrdrogmoJU.
HrdfOfMiwU.. I IfMDv^
toctulil tfcoMI (1,1)
tooukota
K«|XMI.
lutaoipln.
Mitoic h(«uid>
MMonamrH.
U07I..
UIM
Ulll...
Ulll ..
UIM
UIM..
UM4 ..
Ultl ..
UI23..
UOM.
UIM ..
UIU...
U247..
U-54
U02I
UIM
U04I..
UIM.
U22«
UI57 .
UI32
UOM.
UOM.
UI22
UIM
UIM.
UIU
UII3.
Ulll .
UIM
UOII
UOM
11165
U047
UIM
0239
UIM
UII7
UIM
UII7
UIM
UOM
Ulll
UIIO
UI7I
UI72
UI73
UI74
Ulll
UI7I
UI77
UI7I
UMiKnknM.IJ.Tl
UMnnt. ditoiinnliuiiy.
UMUix. dbono-
UMhw.. dlcMao-
tWhim. dkMoiixMuom.
U.HIW.. toUO-
U4»4«lMullo«fc KM. Mh)l MW
IMteM. MiKMna.
U«lw>Mnol HT)
MMtand. Mbama-
kMtan.. tlcUora-
UMtiu*. McMofolua^
UMhmate KU (C.T|
I.M.I.I.'.»«cU
MMho^cMx
Uwhyl^cohom
UMhyl cMc»ld> d,IJ
1.1)
3jT IMh||lnriita|1.4,»McMl>0|*«o*
UMiytoru bartd.
UMlyl .liyl k«u» (I)
U«*i|l Mhyl kUan. (wtuktt (R.I)
U.«V kobuy tMuno M
4 UMhrl 2«K»il|ai|l|.7J.I.WMtlVilw
M.ll WHyi»o«y ImWhMy.
. 1.3 1(33 d
N tMlOW H fKomiWMO.
N MttOiO N «n>Mu
NNHioiaNin.lhyUu
N MttuoN IDMIiHuMhM.
«t««Mln>IWl.. nidi f.
UFMKlmC)
UOIS .
SMFOH
UOM
U2M
UIM
UIM
UIM.
(OM .
SMF027
UM;
1OM
U2M
uaio .
Phm* 1-cMuo-
Ftml. l.44ct*»o-
Mm* M-dfcMom.
Ft-not 2.4
Ftunai; 4-rttB.
F"H«el*»»
PMnol l.3.4.(M-
FMnal t,4>UM»-
Finn*. ».4.«-McMo«o-
IKHUltaVtoMlpp...
FtKMftiiiifc «d* LMd Ml
FMMIc il*r>hU.
IFfco**
IP.op.urtf>. m
H>iot»n«*i.. N prop* ft
mi)
UJI4 ..
Utlt
U2I*. .
UJI7 .. .
U2lt....
UIM . .
mil
U24«
U220.
UUI
tail
u»
UOII ..
ion
intr
U22«
U22I. .
UUI
(VOM-». I n»o- a)
.
Uftopvx BAan.
1 rVopin* M-dlmmo-.
I4*N|M|M. l.l.2.3.3.1ti
.
I fnttcac tdd W
f.T>
Do
Co..
U234
UIM .
U2M . .
U2M ..
ma? .
uat
UMl
U244 ..
U2M
usoo
hofHonlc KU. ItfAB-
4.4'
SVaptoMlocfcl
SuHunc Kid. OmMhyl
Sufc. |*o^*M« |R|
S<*u umta IH.T)
I4.SI
IJAS-TMKNoiiOm
1 I.I.I I
LUJ-I
tMIKMOIOMIIylHK
ll>0ui«| cMorkto
JOuKf dtmfimt |B I)
O-Tfilulitns hychocNorid*
IH 1.2.4 Tnuol J-vnlns
l.l.l-TikMoioMIwi*
IlkM«04«WllM
Irtclfc
«.4.».Trlclili»0|4Mnil
2.4.1 IncMoicvl^iul
>.4.S.rrlcHl»i|>li«xnyKMc »c«l
I J.S-IHOUM. 2.4.1 UmWixf
liW2 3<*b,oa>o(.owO ptoipli.
UK!. UUM2<:
Vlnfl cMcrtd.
. .
iw» « 1(3.4 1 HnMru
FyiUn.
P MM.
4(IH|IVImlo1non.. .1. J at^tolnnrti^I
tow-
d., Mtfvdro-IMkMC).
••lul.
tlllrfcm icM
StfMuni dhdkito IH.T)
<4* FR 7»63». 1*841. Nov. J4. 1680. u
amended at 4« FR 11411. May 20. IMI: 4*
FR ll»23. May 10. IBM: <9 FR CIS. Jan. 4.
1M6: 60 FR 2000. Jan. 14. 1(161
Erricrivi Dtn NOTE At 60 FR <6t, Jan.
4. IDlt. 128133 Introductory le«l wu re-
vlaed. effective July 6. l»86. At 60 FR 2000.
Jan. 14.1N(. the table In paragraph (f) wu
amended by revlalng certain haiardoua
waate numbera, effective July 16. IDAS. For
the convenience of the uier. the aupeneded
Introductory lest (publlahed at 41 FR
11010. Sept. 91. IBg4i. and enlrlei In the
paragraph (f I table, are act out below:
-------
§ 261.33
I1CI.11 DUcanltl rammcrcUl ckeulol ftal-
ucU. off-tpcclncftllon «p«cles. coMlaliMff resi-
due! and iplll r««lduM (hereof.
The (allowing n»terl>U or llenu ue hu-
>rdou< wute* II utd when they »re dltetrd-
ed or Intended la be discarded unleu they
«re excluded under 11 JOT JO ind 2M.U «nd
Ibled In Appendix IX.
Huvdou*
wMtaNo.
Ftauataofht
UU1 ............ PMnal
U2I2 ....... Ptand. IA4.I UtKNora-.
UJIJ .... FlimA ».<.«Hd*)ro
U£K> .......... . Ftaaol. 1.44 MtMof*
U21I
| UZH ........ S*..,
Ul
t»32 ............ H 6-1
t.l.4.*.TMt«Maro|*«id.
U230
tail ....... .... »,<.«- MdJoo|
-------
APPENDIX B
40 CFR PARTS 261.21 THROUGH 261.24
B-l
-------
9 MI.II
DO
I
ro
Ck«*et»lilk«rigiiliahuUy.
(a> A solid waste exhlblU the charac-
teristic of Ignltablllty If a representa-
tive sample of the waste has any of
the following; properties:
(I) It U a liquid, other than an aque-
ous solution containing less than 24
percent alcohol by volume and has
flash point less than «0'C (HOT), as
determined by a Pensky-Uartens
Closed Cup Tester, using the test
method specified In ASTM Standard
D 93-19 or D »3 80 (Incorporated by
reference, see 1 260.11). or a Setaflash
Closed Cup Tester, using the test
method specified In A8TU Standard
• D-3278-76 (Incorporated by reference.
see 1 280. 1 1 >, or as determined by an
equivalent test method approved by
the Administrator under procedures
set forth In 1 1 260.20 and 260.21.
(2) It Is not a liquid and Is capable.
under standard temperature and pres-
sure, of causing fire through friction,
absorption of moisture or spontaneous
chemical changes and, when Ignited,
burns so vigorously and persistently
that It creates a hazard.
13} It Is an Ignltable compressed gas
as defined In 4* CFR 179.300 and as
determined by the test methods de-
scribed In that regulation or equiva-
lent test methods approved by the Ad-
ministrator under il 260.20 and 260.21.
(4) It Is an oxldlzer as defined In 41
CFR 173.151.
(b) A solid waste that exhibits the
characteristic of Ignltablllty. but Is not
listed as a hazardous waste In Subpart
D. has the EPA Hazardous Waste
Number of D001.
146 FR Hill. May It, IM0. M amended at
48 FR 3B147. July 7. 1MI1
IMI.n CharacUrlitleafcBmnlvlty.
(a) A solid waste exhibits the charac-
teristic of corroslvlty If a representa-
tive sample of the waste has either of
the following properties:
(1) It Is aqueous and has a pU less
than or equal to 2 or greater than or
equal to 12.S, as determined by a pH
meter using either an EPA test
method or an equivalent test method
approved by the Administrator under
the procedures set forth In || 280.20
and 260.21. The EPA teat method for
pH U specified as Method 5.2 In "Test
40 C« Ch. I (7-1-15 fdilion)
Methods for the Evaluation of Solid
Waste.* Physical/Chemical Methods"
(Incorporated by reference, see
1260.11).
(2) It Is a liquid and corrodes steel
(8AE 1020) at a rate greater than 6.35
mm (0.350 Inch) per year at a test tem-
perature of 55'C <130't*> as determined
by the test method specified In NACE
(National Association of Corrosion En-
gineers) Standard TM-01-6B as stand-
ardized In "Test Methods for the Eval-
uation of Solid W:*te. Physical/
Chemical Methods" (Incorporated by
reference, see 1260.11) or an equiva-
lent test method approved by the Ad-
ministrator under the procedures set
forth In || 260.20 and 260.21.
A solid waste that exhlblU the
characteristic of corroslvlty. but Is not
listed as a hazardous waste In Subparl
D. has the EPA Hazardous Waste
Number of D002.
141 FR 111 I*. May I*. ISM. u amended >l
4lHt3»347.Juiy1. till!
I UI.Z3 Cluneleriillc at rcacUtlly.
(a) A solid waste exhlblU the charac-
teristic of reactivity If a representative
sample of the waste has any of the fol-
lowing properties:
(1) It Is normally unstable and read-
ily undergoes violent change without
detonating.
(2) It reacU violently with water.
(3) It forms potentially explosive
mixtures with water.
(4) When mixed with water, It gener-
ates toxic gases, vapors or fumes In a
quantity sufficient to present a danger
to human health or the environment
(ft) It Is a cyanide or sulflde bearing
waste which, when exposed to pH con-
ditions between 2 and 12.6, can gener-
ate'toxic gases, vapors or fumes In a
quantity sufficient to present a danger
to human health or the environment
(6) It Is capable of detonation or ex
plosive reaction If It la subjected to a
strong Initiating source or If healnl
under confinement.
(7) It Is readily capable of delun*
tlon or explosive decomposition or ir
action at standard temperature anil
pressure.
(8) It Is a forbidden explosive as dr
lined In 41 CFR 113.61. or a Class A
explosive as defined In 4> CPR 173 S3
Environmental Protection Agency
or a Class B explosive as defined In 48
CFR 173.86.
(b) A solid waste that exhlblU the
characteristic of reactivity, but Is not
listed as a hazardous waste In Subpart
D, has the EPA Hazardous Waste
Number of D003.
I Ml M CharaclerUlk of EP loiklly.
(a) A solid waste exhlblU the charac-
teristic of EP toxlclty If. using the test
methods described In Appendix II or
equivalent methods approved by the
Administrator under the procedures
set forth In 11260.20 and 260.21. the
extract from a representative sample
of the waste contains any of the con-
tamlnanU listed In Table -I at a con-
centration equal to or greater than the
respective value given In that Table.
Where the waste contains less than O.B
percent filterable solids, the waste
Itself, after filtering. Is considered to
be the extract for the purposes of this
section.
(b) A solid waste that exhlblU the
characteristic of EP toxlclty. but Is not
listed as a hazardous waste In Subpart
D, has the EPA Hazardous Waste
Number specified In Table I which cor-
responds to the toxic contaminant
causing It to be hazardous.
TABLE I—MAXIMUM CONCENTRATION OF CON-
TAMINANTS FOB CHARACTERISTIC of EP
TOXtCITY
EPA
ooor..
Om
000*.
DOW
Mil.
0011
Ml)
MM
II.I.1.4.IO.
Unlm (l.t 1.4.6.<*u«- <**»-
(1.1.1-TikMoro-
WET
TABLE I—MAXIMUM CONCENTRATION of CON-
TAMINANTS FOR CHARACIEHISTK or EP
TOXICITV—Continued
».4.»1I> b*»» (I.l.SIiicMa
•sep
loot
to
• 0
>a
• t
10
to
OOJ
• 4
too
-------
APPENDIX C
DIRECTORY TO PROGRAMS
C-l
-------
DIRECTORY TO PROGRAMS
State
Sponsoring/Administrating Organization
Contact Name/No.
Alabama
Alaska
California
Colorado
Connecticut
Waste Management
Emmelle, AL 35459
Alaska Department of Environmental
Conservartion
600 East 38th Street
Anchorage, AK 99508
League of Women Voters
132 Anita Court
Redlands, CA 92373
Golden Empire Health Planning Center
2100 21st Street
Sacramento, CA 95818
City of Palo Alto
Water Control District
2501 Embarcardero Mall
Palo Alto, CA 94303
San Diego Environmental Health
Coalition
P.O. Box 8426
San Diego, CA 92102
Environmental Health Services
San Bernardino County
385 N. Arrowhead
San Bernardino, CA 92415
Department of Health (Tri-County Area)
Fort Collins, CA 80521
(Joint Funding with Department of
Environmental Protection)
Conservation Commission/Health Department
Mansfield, CT 06250
Conservation Commission
Ridgefield, CT 06877
Gordon Kinna
(205) 652-6721
Jim Sweeney
(907) 564-1336
Joan Dotson
(714) 793-1164
Gina Purin
(916) 731-5050
Pete Burnes
(415) 329-2117
Chris Walker
(619) 235-0281
Steve Van Stockum
(714) 383-7170
Danny Stubbs/GSX
(808) 251-1227
Leslie Lewis
(203) 566-3489
Steve Brown
(203) 438-8653
Lillian Willis
(203) 438-8653
C-2
-------
State
Sponsoring/Administrating Organization
Contact Name/No.
Connecticut
(continued)
Florida
Towns of Weston and Westport
(joint venture)
Weston Board of Selectman and
Westport Fire Department, CT 06880
Health Department
Town of Greenwich
Greenwich, CT 06830
Conservation Commission and Town of
Williston
(joint venture)
Ridgefield, CT 06877
Conservation Commission
Manchester, CT "06040
Conservation Commission
Farmington, CT 06032
Conservation Commission/League
of Women Voters
Southington, CT 06489
Bershire-Litchfield Environmental Council
Towns of Salisbury and Sharon, CT 06068
Northwest Connecticut Regional Planning
Agency
P.O. Box 198
Brooklyn, CT 06234
(special task force to sponsor an 8 town
program-still in planning stages)
Department of Environmental Regulation
Solid and Hazardous Waste Section
2600 Blairstone Road
Tallahassee, FL 32301
Helen Speck
Bd. of Selectman
(203) 222-2682
Fire Department
(203) 227-4161
Bob Brown
(203) 222-7848
Lillian Willis
(203) 438-8653
Art Glaeser
(203) 647-3560
Steve Kushner
(203) 673-8237
Joanne Foster
LWV
(203) 628-2004
Victoria
Givotovsky
(203) 435-2004
Nancy Kriz
(203) 774-1253
Jan Kleman
(904) 487-3892
Indiana
GSX Corporation, Inc.
Marion County, IN
Danny Stubbs/GSX
(800) 251-1227
C-3'
-------
State
Sponsoring/Administrating Organization
Contact Name/No.
Indiana
(continued)
Kentucky
6SX Corporation, Inc.
Zionsville, IN
Louisville Sewer District
4522 Algonquian Parkway
Louisville, KY 40211
Marion County Health Department
516 N. Spawlding
Lebanon, KY 40033
Danny Stubbs/GSX
(800) 251-1227
John Weil
(502) 587-0591
Keith Brock
(502) 692-3393
Louisiana
Maryland
Massachusetts
Dow Chemical Corporation
Plaquemine, LA 70764
GSX Corporation, Incorporated
Laurel, MD 20707
League of Women Voters
8 Winter Street
Boston, MA 02108
- Cape Cod (all 15 towns)
- Martha's Vineyard (all 6 towns)
- Cohassett
- Plymouth
- Mattapoisett
- Wareham
- Marshfield
- Duxbury
- Marion
- Brockton
- Easton
- Attleborough
- Westport
- Fairhaven
- Taunton
- Raynham
- Seekonk
- Dartmouth
- Northborough
- Southborough
- Marl borough
- Watertown
- Newton
- Lexington
Jerry Martin
(504) 389-1696
Mora Bartletti
(800) 638-4440
Dana Duxbury
(617) 475-8881
C-4
-------
State
Sponsori ng/Admi ni strati ng Organi zati on
Contact Name/No.
Massachusetts
(continued)
Michigan
- Concord
- Lincoln
- Westford
- Acton
- Andover
- Pepperell
- Hoi den
- Oxford
- Ashby
- Lunenburg
- Fitchburg
- Townsend
- Amherst
- Northampton
- Longmeadow
- Easthampton
- Pel ham
- Westfield
- Wilbraham
- Franklin County (all 26 towns)
- Dal ton
- North Adams
- Williamstown
- South Berskshire County (all 16 towns)
Dow Chemical Corporation
Midland Division
2020 HHD Center
Midland, MI 48640
Bobby Weaver
(517) 636-3413
6SX, Incorporated
Traverse City, MI
49684
Danny Stubbs/GSX
(800) 251-1227
Kalamazoo County Department
Of Planning
201 W. Kalamazoo Avenue
Kalmazoo, MI 49007
Contractor: Drug & Laboratory Disposal
Plainwell, Michigan 49080
Dean Holub
(616) 384-8112
(616) 685-9824
C-5
-------
State
Sponsori ng/Admi ni strati ng Organi zati on
Contact Name/No,
Michigan
(continued)
Kent County Department of Public Works
1500 Scribner Avenue, NW
Grand Rapids, MI 49504
Contractor: Mid-America Environment
Service, Inc.
Ingham County Health Department
5303 S. Cedar Street, Box 30161
Lansing, MI 48909
Contractor: Drug & Laboratory Disposal
Plainwell, MI 49080
Oakland County Health Department
1200 North Telegraph
Pontiac, MI 48053
Contractor: Wayne State University
Environmental Health & Safety Department
Washtenaw County Health Department
P.O. Box 8645
Ann Harbor, MI 48107
Contractor: Wayne State'University
Environmental Health & Safety Department
Wayne County Health Department
3669 Metro Place Mall
Wayne, MI 48184
Contractor: Wayne State University
Environmental Health & Safety Department
Curt Kemppainen
(312) 841-7020
Robert Godbold
(517) 887-6988
(616) 685-9824
Ron Grimes
(313) 858-1322
(313) 577-1200
Barry Johnson
(313) 992-2492
Bruce Davis
(313) 326-4900
(313) 577-1200
Minnesota
Minnesota Waste Management Board
123 Thorson Community Center
7232 58th Avenue
North Crystal, MN 55428
Wayne Sames
(612) 536-0816
Missouri
Monsanto, State of Missouri, League of
Women Voters
Missouri Environmental Coalition
League of Women Voters
6665 Del mar Room 304
St. Louis, MO 63130
Leonore Loeb
(314) 727-8674
New Jersey
New Jersey Hazardous Waste Advisement
Commission (pesticides only)
Shirley Schifmann
(609) 292-1250
C-6
-------
State
Sponsori ng/Admi ni strati ng Organi zati on
Contact Name/No.
New Jersey
(continued)
New Mexico
New York
North Carolina
Ohio
Rhode Island
League of Women Voters
Bridgewater County, NJ
League of Women Voters
Flemington, NJ 08822
City of Albuquerque
Environmental Health and Energy
Department
Hazardous Waste Program
P.O. Box 1293
924 Park Avenue, S.W.
Albuquerque, NM 87103
CECOS International, Incorporated
9303 Montgomery Road
Cinncinati, OH 45242
(collection held in Buffalo)
GSX, Incorporation
Reidsville, NC 27320
CECOS, International
9303 Montgomery Road
Cincinnati, OH 45242
League of Women Voters
2777 Blackfriar N. W.
Canton, OH 44708
Council on Hazardous Materials
4115 Bridge Avenue
Cleveland, OH 44113
Cuyahoga County
Division of Community Services
6100 W. Canal Road
Valley View, OH 44125
Department of Environmental Management
Air & Hazardous Materials
Cannon Building
75 Davis Street
Providence, RI 02908
Linda Patchept
(201) 649-4541
Kelly Martin
(201) 649-4541,
Donna Lacombe
(505) 766-7434
Jose B.R. Anglada
(505) 766-7434
Laura Evans
(513) 793-3090
Mark Johnson
(800) 334-5953
Laura Evans
(513) 793-3090
Patricia Starr
(216) 400-3657
Bob Staib
(216) 961-4646
Floyd Kincy
(216) 524-6320
John Hartley
(401) 277-2797
C-7
-------
State
Sponsoring/Administrating Organization
Contact Name/No.
GSX, Incorporated
Greenbriar, TN 37073
Montshier Museum of Science
45 Lyme Road
Hanover, NH 03755
Department of Wastewater Treatment
Commonwealth of Virginia
County of Fairfax
Department of Public Works
10640 Page Avenue
Fairfax, VA 22030
GSX, Incorporated
Roanoke, VA
Washington Metro
821 Second Avenue
Seattle, WA 98104
Tacoma-Pierce County Health Department
3679 S. "D" Street
Tacoma, WA 98408
Seattle/King County Health Department
400 Yesler Building
Seattle, WA 98104
Danny Stubbs/GSX
(800) 251-1227
Margy Erdman
(603) 643-5672
Robin Byrd
(703) 691-3381
Tennessee
Vermont
Virginia
Washington
Nick Culian
(919) 342-6106
David Galvin
(206) 447-5878
Doug Pierce
(206) 591-6571
Wally Swofford
(206) 587-2722
Cheri Zehner
(206) 587-4632
Wisconsin
Brown County Emergency Government
P.O. Box 1600
Green Bay, WI 54305
Contractor: GSX
City of Kenosha
625 52nd Street
Kenosha, WI 53140
Contractor: GSX
City of Madison Public Health Department
210 Monona Avenue
Madison, WI 53710
Contractor: GSX
Colette Mesiter
Blum
(414) 436-3393
George Zimmer
(414) 8170
Jill Schmidt
(608) 266-4843
C-8
-------
State Sponsoring/Administrating Organization Contact Name/No.
WisconsinDepartment of Natural ResourcesBarbara Zellmer
(continued) Box 7921 (608) 266-7017
Madison, WI 53707
GSX, Incorporated Danny Stubbs/GSX
(800) 251-1227
- Madison County
- Kenosha County
- Marathon County
- Manitowak County
- Brown County
- Manitowoc County Jeff Beyer
- Solid Waste Department (414) 683-4085
- 1010 S. 8th Street
- Maniltowoc, WI 54220
- Contractor: GSX
C-9
-------
APPENDIX D
CASE STUDIES OF
HOUSEHOLD HAZARDOUS WASTE
COLLECTION PROGRAMS
0-1
-------
ALBUQUERQUE, NEW MEXICO
INTRODUCTION
In 1980, two municipal wells were shut down by the Water Resources
Department in the City of Albuquerque due to a high concentration of organic
pollutants.(l) Improper disposal of HHW was suspected as a cause. The
Environmental Health and Energy Department of the City of Albuquerque began a
study to determine the possible causes of the pollution. The results of the
1982 residential portion of a hazardous waste study revealed that there was a
need for increased public education on the subject of HHW. This became the
main goal of a HHW collection program. In December of 1984, the City Council
of Albuquerque passed a special appropriations bill to fund a collection
program.(2) Additional monies were provided by the Bernalillo County
Commission.(3)
The collection program was scheduled for the five-day period, October
18-22, 1985. This included one weekend to encourage participation. A local
chemical firm donated the use of its facility as the collection site. The site
was in an industrial portion of Albuquerque and had good physical security. A
hazardous waste management firm was contracted to identify, package, transport
and dispose of the wastes collected.
PUBLICITY
The City began an extensive public education program on the hazards of HHW
and the effect on the environment from improper disposal of these wastes. The
efforts began nearly 6 months prior to the collection days, and required nearly
the full-time efforts of the program coordinator. Publicity involved three
general approaches:
t Public presentations
t Printed material
• Radio and television announcements
The program coordinator developed an audio-slide presentation that
stressed environmental concerns related to HHW, helped residents identify
wastes, and explained the planned collection program. Although the slide show
was based on one developed by the League of Women Voters in Massachusetts,
local slides and a local news reporter as narrator were effective steps to
customize the material. The presentation was given at meetings of over 150
local organizations such as Lions and Women's Clubs. Each attendee was also
given a refrigerator magnet as a reminder of the dates and location of the
collection program.
Printed material included the usual posters, flyers, and other handout
materials. Announcements were also posted on 40 municipal buses. Inserts were
put into water bills in both July and September. Thus, virtually everyone in
Albuquerque was at least exposed to written material announcing the
D-2
-------
collection effort. Other media publicity included radio and public service
announcements. A 60-second animated TV spot was broadcast on local stations.
Examples of the publicity materials appear in Exhibit 1.
' The City gave the program an official kick-off with a news conference
covered by all local television stations and newspapers. Additionally, the
mayor issued an executive order proclaiming October 18-22, 1985 as "Hazardous
Waste-Wise Days".(5)
CONTRACTOR SELECTION
Each prospective contractor was to submit a proposal by April 6, 1985.
Proposals were to include copies of all insurance coverage, state and Federal
registrations, and a detailed breakdown of all costs associated with this
program. Criteria for the selection of the contractor included past experience
in this type of program and ability to comply with State and Federal
environmental and transportation laws, cost-effectivness of the management of
all areas of the project, and proper insurance coverage.(4)
CONTRACTOR'S AND AGENCY'S RESPONSIBLITIES
The contractor's responsibilities included all those services needed to
collect, analyze, package, transport and dispose of the HHW.(4) This included
identification of an unknown substance by appropriate means. Materials
including drums, overpacks and absorbent were also the responsibility of the
contractor. Other equipment including safety equipment for personnel, first
aid equipment and drum pumping equipment were also required. The contractor
maintained a daily log of all accepted wastes and any compatability or other
types of tests run on the HHW.
The City of Albuquerque provided the personnel for reception, inventory,
public information, participant interviews, and administration. Others not
on-site, but aware of the project in case of an incident were the Fire
Department and the Police Department.
Equipment provided by the City included the Environmental Improvement
Division's Hazards Van, drum handling equipment including a forklift and
operator, labels, eyewash and shower, wooden pallets, emergency spill
materials, tables, chairs, and traffic routing equipment.
COLLECTION SITE
The site was located at the Rinchem Corporation, a chemical transportation
company in the northeast quandrant of the city. A diagram of the collection
site is in Exhibit 2. Rinchem Corporation donated the use of its property. The
site is a secure area surrounded by a tall fence with a gate that was locked
when the collection site was not open. This eliminated the need to hire a
security guard. It was also located far enough away from congested areas to
minimize traffic hazards. Signs directing traffic to the site were placed in
such a way that they were visible to any traffic approaching the site from any
conceivable direction. This included all cross streets as well as the main
thoroughfares.
0-3
-------
EXHIBIT 1. EXAMPLE OF ALBUQUERQUE, MEW MEXICO'S PUBLICITY MATERIALS
THE
PROBLEM
pctfkldtt «ul Mh« koinekoM p«i*K»> CM po«uH
l |iou«l«Uii| mttu It tram tnMn4»««( An nllnulcd I •
mma* pouMfa of kitudow wnM •>« keln| teneuMrf amuoV k»
kouMkoUi M AftwiuiHiu*. Abou) 1.4 «*)• Dounh ol Alt w«M m
b«li>| diipoinl ol (oiprafttilr Into Ike uolUfy bndkl and t»»t. truxnt.
of J.iojoi ml open IBXO. Ikui iiK»«lii« Ike IknM to p-J*c k*n«l» IM IMltl 14 IK »»..!«K lln-
timimiimrnl |IIWAI<| j tlrjn «*o*uitnnirnl lnrf.iv
WHAT ARE
HAZARDOUS
MATERIALS?
HaiatdDut maleiiati bickio* conov>e. leacllve. lonilable and
•uHiuk dul CM pietcnl a dueal to pubk keakk and ufcly.
envkonmenl. You piulubV ka« tome In yow kom* - on tkefcn In
yow taiage. In Ike cabhteH. and • «oik and rtou«r ike*. lket« »4
be accepted al Ik* Afcuqueniu* HJIt-C r*+a
• Canned o> on«iMled (ntecttcidn
*nd to.le
ly. »nd «w
tkefcn III
• nnei 01 un«>MlcMU|tl 4t» MlMH
• OU painl. DM* Dinnen
• Wood picteivaNwn
• Ink* iuJ Md MUlie«le
• S»lmmln| pool ckrmlcM
• CleMl«| luidt. Mcicket. Md immonU
r«W m«l mokK oJ to • bcjl iMicknf M*
WHY IS
PROPER
DISPOSAL
IMPORTANT?
fiouet dhlioul (KOtnH polkilioii ol ik* 1*11 temlUv* en*.
okkk It tuiriplibb to froundMUi coMMitaWMi. Ov »»••*"*" *
tk* *»•/ «»l«f w kne, M M< kw* to k* »*nr twtickV* ol t). kn-
piopM dhpoul ol kauidout koiiKkold w.Mct - tuck M buiytnej «M
wan* - pietMn Ike poUMUl lx to»lc wkHMtn to i*«k ditoUnf
palm'pound down Ik* dial*. «ke» wukipted rtwuhmdl ol iinel »ve«.
pox a «neal to ** walei wppty fouling waue doM koutekoU dialm
ahml Ike m>>eilal H |ri Mo •>« t*»a(e Iwaknenl ptanl Of rou< tepM
lurt> and cvenwaly Into ftoundwalei. Sevna,* lieatmeM olanlt «* not
dettaned to Km kaiaidoul maMriah. Haiantoul mtttitit In kouKkuM
baik h laten to «S« landlll «kkk CM Jk~ to.k ckemkak) to icack
. *K« Ik* landM h not dn!.ned kM kalMkwi matte dlipow!
HOW SHOULD I
TRANSPORT MY
HAZARDOUS
WASTE?
l Iveiy eftM tkouU be made to IdeMnV ** malenal
and male tuie Ike Mt aie UtM II conulneii aie kiailnf, pack hi a
lai|ei contain*! and vt* M aktoikeM nuWilal tuck M cat Mel to wak
up leakt fw e.jmpto. plac* a oar-qfua conUkief In • cltin on* i»«o«
paml CM availaMe al total palnl itoiet and unaund »«» abwiUnl
nuleilal to»« » dMI*i*M
or «•»*•»• nuttitek Mttlko. IM lonotMeiM uota|*. Mon m a cool
diy plic* Many ckcnucah. eiprcully tmt In caidbnaid packa|u>i, CM
akioib moiilui*
H..HwC
pnojecr
OCT 18-22 1985
9-6 DAILY
766-7434
BINCHIM CO. It39 Hdllh Nf
•HOUSEHOLD HAZARDOUS
WASTE COLLECTION
REFRIGERATOR MAGNET
-------
EXHIBIT 1 (Continued)
HAZARDOUS WASTE IN MY HOME
HOW TO IDENTIFY A
HAZARDOUS WASTE PRODUCT
a
i
01
1. Why should I be concerned with household hazardous waste?
To protect your family and pets.
To protect our environment.
To reduce the amount of hazardous waste generated.
2. What are household hazardous wastes?
Substances which are toxic, corrosive, or ftamable and
capable of causing serious Illness or hana to IUMHS,
domestic livestock, wildlife, or the environment.
While Most packages offer adequate instructions on the
storage and use of these potentially dangeroui Materials.
they rarely contain instructions on how to dispose of the*.
3. What can I do. . .
when buying toxic Materials?
Read the label carefully.
Buy only as much as you need.
Use up all the Materials for their Intended purpose.
Keep separate froM groceries, i.e., carry in car trunk.
in the event of spillage of toxic Materials?
Sweep or shovel dust and powders into a plastic bag.
Spread sand, sawdust, or cat litter on liquids to absorb
spillage and then shovel Into plastic bag.
with unused toxic Materials?
Must not be thrown in the trash.
Must not be flushed down the drain or toilets.
Must not be burned.
Store In safe place In the original labeled container.
ENVIRONMENTAL SERVICES DIVISION "
tNVIRONMENTALKEALTH 8 tNERCY DEPARTMENT
ALBUQUERQUE, NEW MEXICO
Check '.he label on the container. Look for key words: CORROSIVE.
POISON. FLAMMABLE. COMBUSTIBLE. CAUSTIC. VOLATILE, EXPLOSIVE. OR
OXIOIZER. Federal law requires products to be labelled with their
contents and any dangers about then.
The following Is a partial list of household hazardous wastes and
their toxic effects:
Drain Openers Corrosive
Oven Cl eaners Corros < ve
Toilet Bowl Cleaners Corrosive
AMMnU I Ammonia Based Cleaners Corrosive
Ly« ; Corrosive
Pool Acids Corrosive
Photographic Chemicals Corrosive
Floor ft Furniture Polish Flamiable
Spot Remover/Ory Cleaning Fluids Flainable
Disinfectants Flammable
Rug/Upholstery Cleaner FlaianabIe/Corrosive
Air Freshener Flamnable/Irritant
Aerosols Flamnable
Automotive Waste Oil Flammable
Brake Fluid Flanraable
TranSMlsslon Fluid Flamnable
01 esel Fuel Flanwabl e
Enamel/Oil Base Paint Fl amnabl e
Paint Solvents or Thlnners Flamnable
Glass Cleaners Irritant
Anti-Freeze Poison
Pesticides ,.Poison
Chlorine Oxldlzer
ENVIRONMENTAL SERVICES DIVISION
ENVIRONMENTAL HEALTH & ENERGY DEPARTMENT
ALBUQUERQUE, NEW MEXICO
-------
EXHIBIT 1 (Continued)
Why should I recycle used oil?
Recycle Your
Used Motor Oil.
It makes good sense)
o
en
Recycling
Protects Our Environment
and
Conserves Enerqy
It protects our environment OH dumped down
the sewer, in the trash, or on the ground can
eventually find its way Into our water supply
used oil contains many contaminants some
harmful to human health
How difficult is it to collect
used oil for recycling?
if s very simple. Drain your oil into a clean con-
tainer with a tight fitting cap (one gallon
plastic milk tug) Do not mix the recovered oil
with any other liquids Make sure it is free from
dirt leaves or other debris
Where do I take my used oil to
have it recycled?
Take your used oil to any location listed on this
brochure
Why do so many businesses
want used motor oil?
Used oil. the kind that is changed from autos
lawn mowers and motorcycles is a valuable
resource Every gallon recycled is one less gal
Ion that must be produced from a dwindling
world supply and one less that must be im
ported Recycling also saves energy Only about
half as much energy is required to rec vcle used
oil than is needed to produce new oil
-------
EXHIBIT 1 (Continued)
SUBSTITUTES FOR COMMON HOUSEHOLD HAZARDOUS PRODUCTS
PRODUCT
Household Cleaners
Drain Openers
Oven Cleaners
o
i
Toilet Bowl Cleaners
F1oor/Furniture Polishers
Amnonta A Armonl a-based
Cleaners
Glass Cleaners
Chlorine Bleach
Disinfectants
Rug S Upholstery Cleaners
ALTERNATIVES
Pour boiling Mater down the drain a couple
of tines a week as a preventatlve
measure. Unclog drains with a metal snakt
or plunger.
Keep oven clean as you use it. Ovens can
be cleaned with diluted ammonia or baking
soda. Nix 3 tablespoons washing soda with
one quart of war* water. Sprinkle salt on
spills when they are warm then scrub. For
baked on grease, put 1/4 cup ammonia in
oven overnight to loosen, then scrub with
baking soda.
A general household cleaner or baking soda
can be used. 1/2 cup of bleach can be
used as a cleaner or use a pumice stone
for hard water spots.
Light, soapy water to clean and • soft
cloth to shine. Melt 1 tbsp of Carnauba
Hex Into 2 cups mineral oil or dissolve 1
tsp lemon oil into 1 pint of mineral oil
or rub crushed raw nuts on the woM for an
oily polish. Use a soft cloth and
mayonnaise.
Vinegar with salt and water Is a good
general surface cleaner. Dissolved baking
soda does well in the bathroom and for
cleaning coffee pots, chrome, copper and
tile. Well-diluted ammonia is a good
general household cleaner.
Warm water and vinegar in an 8-to-1
solution. Use cornstarch and water. Use
lemon juice and dry with a soft cloth.
Never mix with ammonia products. Baking
soda and water is a safer cleaner.
Dilute bleach: 1/4 cup to 1 qt water.
Dry cornstarch sprinkled on rug and
vacuumed up or use soap-based non-aerosol
rug shampoos. Always wear gloves.
Air Fresheners
Copper Cleaner
Silver Cleaner
Paint Products
Paints
Paint Solvents S Thinners
Pesticides
Ant Control
Bug Spray
Flea Repellent
Rat Poison
Snail/Slug Bait
Roach Spray
Mothballs
Houseplant Insecticides
An open box of baking soda In thj
refrigerator. Set vinegar out In opei
dish.
Pour vinegar and salt over copper and rub.
Soak silver in 1 qt warm water continuing
1 tsp baking soda, 1 tsp salt, and a piece
of aluminum foil.
Use latex
possible.
or water-based paints if
Latex and water-based paints do
require thlnners.
not
Sprinkle cream of tartar In front of the
ant's path.
Place screens on windows and doirs.
Brewers yeast tablets-taken dally give the
skin a scent that mosqultos seem to avoid.
Place eucalyptus seeds and leaves around
the area where the animal sleeps. A
bandana soaked in penny royal tea will
repel fleas.
Put a screen over drains. Use
mechanical-snap mouse traps.
Place a shallow pan with beer In the
Infested area. Overturn claypots. The
snails will take shelter In them during
the sunny days and they can be collected
and removed.
Chopped bay leaves and cucumber skins, or
boric acid, or 1 part borax and 1 part
brown sugar set out In dishes.
Spread newspapers around closets or put
clothes in cedar chests or place cedar
chips around clothes.
Soapy water on leaves—then rinse.
ENVIRONMENTAL SERVICES DIVISION
ENVIRONMENTAL HEALTH 8 ENERGY DEPARTMENT
ALBUQUERQUE/ NEW MEXICO
-------
EXHIBIT 2. DIAGRAM OF ALBUQUERQUE, NM
HOUSEHOLD HAZARDOUS WASTE COLLECTION SITE
HHW Staff—«-T~l
Trailer [J
SQC and Institution
Drop Off Area-r
CSX Supply — •— J
Trailer J
Sorting Table — J
SQG and n
Institution! J
Interviewu
Area
Vermiculite Storage
Trailer
Rinchem Bldg.
/ / / / / ^-—Participant
/ / / / / / Parkin9
/ ' f / f ' Area
O
i
00
Waste Oil
Tank
HHW Interviewer's
Seating Area
Locking
A A A AAA
Empty Drums '•Education Trailer
A
A
A
A
A
Bushes
>fsx.\-r*+~- •»• w^— v**Ty^p^jy
HHW Staff-
Directing
Traffic and
Distributing
Information
A
A
A
Participapt
Overflow Parking
Area
HHW Staff
Parking
Area
HHW Staff-^
Directing Traffic
Fencing-
-------
The contractor's facility consisted of a single trailer with a canopy over
processing tables. Tables were set up along the length of the trailer for
processing of the HHW and testing any unknown substance. Another table, used
for reception of the waste, prevented non-contractor personnel from- entering
the processing area. Two other trailers, one for contractor supplies and the
other for storage of the bags of vermiculite for waste packaging were located
nearby.
Other features of the collection site were a waste-oil tank located a safe
distance from the processing area. Only City personnel were permitted near it.
The education trailer was located next to the processing area. Participants
could safely view overall collection activities and get additional information
on HHW. At one end of the trailer a table contained flyers and information
about household hazardous waste, including information about alternative,
non-hazardous substitutions for household chemicals and cleaners. Additional
information concerning the HHW situation as it pertains to Albuquerque
including oil recycling together with a list of oil recycling locations in the
Albuquerque area was also located on the table. At the other end of the
trailer, the slide/tape presentation was shown 1;o every participant that
entered the trailer. Personnel were available in the trailer to answer any
questions relating to HHW. If a question could not be answered by the
personnel in the trailer, an attempt was made to locate someone on-site who
could answer the question, or the participant was referred to the agency or
person that would be able to assist him/her. A sample of the educational
material is in Exhibit 2. Also on-site was the EID (Environmental Improvement
Division) Hazards Van with facilities to cleanup any spill that might have
occurred.
OPERATIONS
At the entrance to the site, a City employee routed traffic to the
entrance of the collection area. At that point, another City employee gave the
participant some general printed information on HHW and then directed him/her
to a parking area. The participant was then interviewed and the waste
inventoried. A City employee then removed the waste from the participant's
vehicle and moved the waste to the processing site. The participant was given
the option of visiting the education/information van, or leaving the site. If
a participant had a large quantity of waste or was a small quantity generator,
he was routed directly to the processing area. The wastes were inventoried and
the participant was interviewed.
Small commercial generators and institutions were encouraged to
participate. Receipt and processing of these wastes were completely separate
from the HHW areas. Up to two 55-gallon drums of wastes were accepted at no
charge from these sources. For more wastes, a discounted fee was charged by
the contractor.(3)
A special feature of the Albuquerque program was a call-in service for
some residents. Those who were elderly, handicapped, or had transportation
difficulties could telephone the City for a special pick-up. City employees
collected the wastes and hauled them back to the collection site.
D-9
-------
WASTE TYPES
Program publicity identified the wastes that would be accepted and those
that would not. Accepted wastes included:(4)
Pesticides
Poisons
Household Cleaners and Polishes
Drain Openers
Paints
Solvents/Thinners
Wood Preservatives
Furniture Strippers
Waste excluded from the collection program are as follows:
Radioactive
Biological
Explosives
Ammunition
Motor Oil
Gas Cylinders
Facilities were available on-site to process these wastes if a participant
brought them:(3)
• Radioactive wastes were returned to manufacturers (e.g. stereo record
cleaner, smoke alarm).
t Explosives and ammunition were placed in a "bomb box" that was on-site.
These were then given to the Police Department for disposal.
t Motor oil was put into a 550 gallon tank on-site. An oil recycling
firm provided the tank and emptied it when necessary.
• Aerosol cans were packed to be transported to an appropriate disposal
facility.
LIABILITY
Several forms of insurance were involved. The owner of the collection
site carried public liability insurance for activities on the property. The
contractor carried its own insurance covering its employees during any period
of time that the waste was handled. Also the contractor carried comprehensive
general liability insurance for the equipment in use, including any vehicles.
The City of Albuquerque employees were insured by the City's insurance policy.
The fact that participants did not handle the wastes while at the collection
site was an operational decision that reduced the possibility of an incident or
accident.
D-10
-------
RESULTS AND COSTS
Results of the Albuquerque collection program are shown in Exhibit 3. Over
1,000 households participated (about 0.8 percent of the households in the
area). Some 66 other generators also participated including 57 commercial
sources and nine schools. Over 59 tons of waste were collected with 39 percent
coming from households and 61 percent from other sources.
Each household contributed about 46 Ib of waste while each commercial
source brought in nearly 1,100 Ibs. This latter figure is the equivalent of
about 146 gallons. Thus, although the program was primarily directed towards
homeowners, most of the waste came from other sources.
Total program costs were estimated at about $146,500 as shown in Exhibit
4. This includes actual costs and estimated value of donations of the use of
the collection site, donated labor, and volunteer labor. Exhibit 4 also
includes cost factors for fringe benefits for City employees and for overall
administration. These are costs that are often not included in other cost
estimates of HHW collection programs.
Cost per pound of waste received was calculated as $1.24 based on total
costs and total waste. There was no separate accounting of costs related to
HHW and the other generators. However, the thrust of the program from
inception was toward the homeowners. The program would have cost Albuquerque
nearly the same if only HHW were accepted. If 90 percent of the costs were
associated with HHW aspects, the cost to collect each pound of HHW would have
been $2.85 ($146,525 x 0.9/$46,215 Ib).
REFERENCES
(1) Residential Hazardous/Toxic Waste Survey, City of Albuquerque
Environmental Health and Energy Department, Albuquerque, NM, 1983.
(2) Press Conference Announcement, Councilor Nadyne Bicknell, City Council
Albuquerque, Albuquerque, NM, July 17, 1985.
(3) Personal Communication, Donna Lacombe, Environmental Health and Energy
Department, City of Albuquerque, Albuquerque, NM, October 19, 1985.
(4) Household/Small Quantity Generator Hazardous Waste Collection Project
Request for Proposal, Nubmer 85-1219-J, City of Albuquerque,
Albuquerque, NM, April 5, 1985.
(5) Executive Order, Mayor Harry E. Kenney, Mayor, City of Albuquerque, NM,
October 18, 1985.
(6) Personal Communiation, Donna Lacombe, Environmental Health and Energy
Department, City of Albuquerque, Albuquerque, NM, October 29, 1986.
0-11
-------
EXHIBIT 3. PARTICIPATION AND RESULTS, ALBUQUERQUE, NM
• Duration: 5 days (October 18-22, 1985)
• Locations: 1
• Participants
-- -Households: 1,005 (including 7 call in for pick-up)
-- Schools: 9
-- Commercial small quantity generators: 57
• Household Participation Rate: 0.77% (1,005/130,000 households in area
x 100)
• Waste Collected
-- Households: 46,215 Ib.
-- Others : 72,285 Ib.
-- Total : 118,500 Ib.
-- Waste Oil : 750 gal. (approx 4,500 Ib.)
• Waste per Participant
-- Households: 46 Ib.
-- Others : 1,095 Ib.
• Total Costs: $146,525
• Cost per Pound of Waste: $1.24 (total costs/total waste).
Source: Reference 6
D-12
-------
EXHIBIT 4. COST SUMMARY, ALBUQUERQUE, NM
COSTS
Hazardous waste contractor $ 72,000
Salaries of City employees 48,000
Benefits for City employees (est) 20% 9,600
Administration and overhead (est) 1,000
Publicity 11,900
Subtotal " $142,500
DONATIONS
Volunteer labor (90 firs x $15/hr) $ 1,350
Use of facility and forklift (est) 2,000
Donated labor (45 hrs x $15/hr) 675
Subtotal $ 4,025
TOTAL COSTS $146,525
Source: Reference 6
D-13
-------
FAIRFAX COUNTY, VIRGINIA
INTRODUCTION
In 1983, the Fairfax County Board of Supervisors formed a Hazardous
Materials Core Group to study the problem of household hazardous waste in the
County. After researching the current household hazardous waste management
alternatives, the concept of the "clean-up day" seemed to be the most
effective. The Department of Public Works, Division of Wastewater Treatment
was directed by the County Board of Supervisors, to coordinate a collection day
that was scheduled for October 26, 1985.(1)
The goals of the "clean-up day" were to provide for the disposal of
residential household hazardous waste, gather information on types and
quantities of each waste from every participant to determine the feasibility
of future projects, to divert the disposal of household hazardous waste from
the municipal wastestream, and to increase public awareness of the
environmental dangers of household hazardous waste.
The County Board of Supervisors approved the implementation of a "Fairfax
County Household Hazardous Waste Clean-Up Day" on September 16, 1985 (about six
weeks prior to the event). " GSX was selected as the hazardous waste contractor
to collect and dispose of the household hazardous waste.(1) Criteria used in
the evaluation for the selection of the contractor included the following:(2)
t The contractor must have had previous experience in household hazardous
waste collection days.
• The contractor must take the responsiblity as a generator.
• The contractor must show the existence of a safety plan.
PUBLICITY
Publicity for the HHW collection day was managed by the Fairfax County
Office of Public Affairs. The County made a valiant effort to publicize this
event. Due to time contraints and missed deadlines, the advertising did not
seem to reach a large part of Fairfax County. Eleven different groups were
targeted to receive flyers and posters. These included libraries, government
agencies, retail outlets, and schools. News releases were issued to the media
on two different occasions prior to the collection day. A public service
announcement was also released to the local cable television station.
Additionally, an article appeared in the Fairfax County (Government's) Weekly
Agenda. A number of community groups distributed flyers. Flyers and brochures
were also distributed by County staff at local social events and farmers'
markets throughout the area.(3) Examples of the flyer and brochure appear in
Exhibit 1.
D-14
-------
EXHIBIT 1. EXAMPLE OF FAIRFAX COUNTY, VIRGINIA FLYERS
Bring your leftover...
* Pesticides (chlordane.
malathion. DDT. arsenic)
• Paint thinners and solvents
• Oil based paints (no latex)
pour into one can and crush
empties
• Chemistry sets
• Wood preservatives, stains and
varnishes
• Photographic and pool
chemicals
• Fertilizers
• Rodent and weed killers
?t*t Disposal for County Rasidjmts
NO BUSINESS WASTE ACCEPTED
FOR MORE INFORMATION
CALL 451-7783. Health Dtpt
Fairfax County
HOUSEHOLD
HAZARDOUS
WASTES
CLEANUP
DAY
Rain or Shine
Saturday. October 26
9 a.m. to 3 p.m.
Oakton High School
2900 Sutton Road
Vienna, Va.
or
Edison High School
5801 Franconia Road
Alexandria. Va.
D-15
-------
EXHIBIT 1 (Continued)
THE PROBLEM
YO
WHAT WILL HOT aeACCXPTCD
QUESTIONS A ANSWERS
. Thay may Bamac.
ca*y awaTrhaynMiga tram malatnaar
f.nrnivm men aa Mad and mcury.
noujn JiamaaM ot vagua lunaaniy
sucn aa caomunv and on c ma na»ar
nousanoia Hazardous wtstf on
• (audt « TrtcnM«oaavana1 mat
nay go oy naato (TCS.
So—
malarial saMy. Tha> contractor u
licanaad by m* faoaral govanvnanl
to do thM.
out Mr tna rataa* MirMKK «• not any
aaangar n paaoia. BM « andt M>
iaacMdora>aiaaa«ig>aaokl Ustad matanala mat VMM
not b* aceaptad. Wa also raiarv*
tna ngnt to rafuaa *om« umoanafwd
products.
u a "—**•*""* waaia * gwan a a
licamart and anrtanmnal nandw.« can
aa racydad lor luam rauaa. naumMtad,
or prapariy conaanad. dlapoiad or da*
nrayad.
Plaaaa packaq* ttw coruamar in
a piaane garoa^a bag so it vn« not
spat dumg your np to IP* Oaan-Up
Day SIM.
f YOU W*MT MOM
MFORMATION. CMJ.
unar o Ma daan-Op Day lor FREE.
PROPER 06POSAL.
• O* bawd pama (NO LATEX)
pom MO ana can and aua* »
• BaMiylkiidi
U you haw now 5 gaama ol *qud «
75 pounds ol sokd wasMa. plaaia cat
451-7783 In advanea lo maka ananga-
mama Iw unposal.
Fairfax County
HOUSEHOLD HAZARDOUS
WASTE CLEAN UP DAY
Han or Sim
DAY: SaMday. Oclobaf 28.1996
TIME: 9 a.m. to 3 pm.
LOCATIONS. OakionHlghScnoot
290OSuMonRoad
Vtama.Va.
EdawnHIgM School
SBOt Ftancoma Hoad
Alaundna.Va.
Edaon Hgh School
D-16
-------
SITE LOCATION
In the original plan, three collection sites were selected, to be operated
simultaneously. These were to be located in the southern, central and western
parts of the County. The recommendation by the contractor and prohibitive
costs, led to the selection of two sites, Edison High School in Springfield
(southern area) and Oakton High School in Oakton (west-central area). (1)
OPERATIONS
The collection site operations were similar at both sites. The
participant entered the collection site and drove around a series of traffic
cones to the disposal area. No traffic direction was evident at either site.
This caused considerable confusion. Moreover, vehicles that were at the
schools for other events drove to the disposal area. A diagram of the
collection site appears in Exhibit 2. After arriving at the collection point,
the participant was greeted by a County employee for an interview. The wastes
were removed from the car by a County employee (in most instances) and moved to
the processing area. GSX personnel then sorted, packed, and manifested the HHW
for transportation and disposal. Fairfax County Police, Virginia Department of
Emergency Services, and GSX staff were on-site in the event an incident
occurred. Additionally, refuse staff were on-site to collect and dispose of
any normal refuse brought to the site.
The types of waste accepted at this household hazardous waste collection
day included: pesticides (including chlordane, malathion, DDT, arsenic); weed
and rodent killers; fertilizers; paint thinners and solvents; degreasers;
swimming pool chemicals; wood preservatives (including stains, varnishes);
photographic chemicals; spot removers; chemistry sets; unused flammable liquids
(gasoline, kerosene); oil-based paints; and batteries. Wastes excluded from the
program (though accepted if brought to the site) included: biologically active
wastes, radioactive wastes, normal refuse, asbestos, used motor oil,
explosives, cylinders of compressed gas, shock-sensitive materials, dioxins,
and kepones. Any unknown materials were screened by County personnel before
being accepted. If the county did not accept the unknown material, GSX noted
the incident in the daily log. Small quantity generators and businesses were
also excluded from the HHW collection day. Any small quantity generator or
small business that attempted to participate was rejected.
LIABILITY
Several forms of liability insurance were involved. Limited liability was
accepted by the County of Fairfax. This included its employees and the
physical collection site (land, buildings). As the generator, the contractor
was liable for any incidents occuring during the sorting, packaging,
transportation or disposal of the wastes. The Department of Emergency Services
personnel were insured against liability by the Commonwealth of Virginia.
D-17
-------
EXHIBIT 2. TYPICAL SITE PLAN, FAIRFAX COUNTY, VA
I
t-
00
Edison High School
-Packed Drums
/CSX Supply
Trailer
I I
rHHW Staff Table
^"^ Sorting/Manifesting
t> t> (> Tables
Participant Drop/Off Are
-HHW Staff Parking
> 0
'Fencing-
-------
RESULTS AND COSTS
A total of 251 households particpated in the household hazardous waste
collection day out of approximately 223,000 total households in the County. The
greatest amount of wastes collected included oil-based paint and pesticides.
Latex paints brought to the collection site, were disposed of in a refuse
container and transported to the landfill. The same procedure was used for
aerosal cans. Waste oil was taken to Fairfax County's vehicle maintenance yard
for recycling.
Results of the on-site survey indicate that 60 percent of the participants
would have continued to store the wastes if the HHW collection day had not
occurred. Likewise, a majority (55 percent) said they would participate in an
annual household hazardous waste collection day. A summary tabulation of the
participant survey is shown in Exhibit 3.
Participation and quantities recovered are shown in Exhibit 4. The
figures for the quantities recovered and the waste per participant were
estimated due to the lack of data available when this case study was prepared.
The estimate for the total weight of waste collected and the resultant weight
per participant was based on three sources. This consists of a report by the
Agency of Environmental Conservation on the methods and programs for HHW
collection and disposal(4), the data from the Albuquerque HHW Collection
Program, and on-site personal- observations. Using this information, it was
estimated that each household contributed approximately 31 pounds of HHW
(including waste oil).
Cost for the one-day collection program is estimated at nearly $70,400.
Many of the costs are estimates due to the lack of available data. The costs
also include estimated values of volunteer labor, factors for fringe benefits
for County and State employees and administration costs. A cost summary is
shown in Exhibit 5. Cost per pound of HHW collected was estimated at $9.05.
FUTURE PLANS
The County is establishing a one-year pilot project consisting of a
transfer and disposal site at the Lower Potomac Pollution Control Plant at
Lorton, in the extreme southern portion of the County. The wastes will be
collected and stored on-site and periodically transported to a permitted
facility by a hazardous waste transporter.(1) The objective of this pilot
project is to determine the cost-effectiveness and feasibility of a permanently
operating facility. The County will also sponsor another HHW collection day in
the spring. Funding has already been appropriated for the project, however
details have not yet been made available.(l)
REFERENCES
(1) Personal Communication, Robin Byrd, Fairfax County Department of Public
Works, Wastewater Treatment, October 26, 1985.
(2) Fairfax County Request for Proposal, No. 6-0125-20-27, Fairfax County,
Department of Public Works, August 19, 1985.
D-19
-------
(3) Memorandum to J. Hamilton Lambert - Fairfax County Executive from Jean
Van Devanter, Office of Public Affairs, October 22, 1985.
(4) Methods and Programs for the Collection and Disposal of Household
Quantities of Hazardous Waste, State of Vermont. Agency of
Environmental Conservation, Montpelier, VT, January 10, 1985.
D-20
-------
EXHIBIT 3. SUMMARY OF FAIRFAX COUNTY
VIRGINIA PARTICIPANT SURVEY
Edison High School: 116 Participants Oakton High School: 135 Participants
Total Number of Participants: 251
Type of Waste(s) and Amount Delivered:
Type of Waste Number of Containers
Paint and Paint Related Products (Non-Latex Paint,
Turpentine, Varsol, Paint Thinner) 779
Cleaners and Solvents 216
Petroleum Products (Asphalt, Tar, Petroleum
Distillate) 65
Automotive and Fuel (Lighter Fluid, Kerosene,
Oils That Were Mixed) 65
Chemicals and Flammables (Resins, Wood
Preservatives, Xylol, Sealer) 151
Pesticides and Herbicides 682
Corrosives (Acids, Rust Remover) 228
Poisonous (Potassium Cyanate, Copper Sulfate,
Sodium Thiosulfate, Boray) 194
Oxidizers (Potassium Dichromate, Strontium
Ditrate, Nitric Acid) 24
TOTAL CONTAINERS 2,402*
Was this location convient? Yes: 82.3 percent No: 17.6 percent
What would you have done with this waste if this clean-up day had not been
Included it with your household garbage: 15.1 percent
Continued to hold onto and store the wastes: 60.1 percent
Poured it down the sink or toilet: 0.3 percent
Poured it down the storm drain: 0.3 percent
Buried the material: 0.7 percent
Other: 23 percent (Most of which said they would call the County for
disposal information.
D-21
-------
EXHIBIT 3 (Continued)
How often would you use this clean-up day services?
Once a year: 55.6 percent
Twice a year: 25.4 percent
Four times a year: 4.0 percent
Never again: 2.4 percent
Other: 12.5 percent of the participants stated they would use this
service once every other year.
How did you hear about the Household Hazardous Waste Collection Day?
School Brochure: 21.5 percent
Newspapers: 24.1 percent
Cable TV: 1.4 percent
Radio: 2.2 percent
Weekly Agenda: 13.0 percent
Flyers: 7.8 percent
Posters: 20.0 percent
Special Events ("Fairfax Day"): 1.4 percent
Word of Mouth: 2.6 percent
League of Women Voters: 3.3 percent
Employer: 0.3 percent
Homeowners Association: 1.8 percent
* Source: Personal Communication, Robin Byrd, Department of Public Works
Division of Waste Water Treatment, County of Fairfax, Fairfax
Virginia, November 12, 1985.
D-22
-------
EXHIBIT 4. PARTICIPATION AND RESULTS, FAIRFAX COUNTY, VA
• Duration: 1 day (October 26, 1985)
• Locations: 2
t Participants: 251 households
• Participation Rate: 0.11% (251/223,000 households in County x 100)
t Weight of Waste Collected
-- Households: 6,777 pounds*
-- Waste Oil: 1,004 pounds**
• Waste per Participant
-- Household: Approximately 27 pounds*
-- Waste Oil: 4 pounds**
• Total Costs: $70,400 (estimated)
t Cost per Pound of Waste (including oil): $9.05
* Estimate based on the Connecticut/Vermont HHW Collection Day Summary Report
and On-Site Personal Observations.
** Estimate Based on Albuquerque, NM HHW Collection Program Data.
D-23
-------
EXHIBIT 5. COST SUMMARY FAIRFAX COUNTY, VIRGINIA
COSTS
Salaries - County Employees (Planning)
1 Project Manager
11 Staff Members
Salaries - Project Staff (on-site)
2 County Representatives
6 Technicians
2 Policemen
2 Firemen
2 Refuse Workers
3 State Health Employees
140 hrs 0 $15/hour (est)
80 hrs (3 $13/hour (est)
8 hrs @ $15/hour (est)
8 hrs 0 $13/hour (est) •
8 hrs (? $ll/hour (est)
8 hrs 9 $ll/hour (est)
8 hrs 8 $8/hour (est)
8 hrs @ $12/hour (est)
Subtotal Salaries:
22.5 % of salaries:
(Est. 20% of salaries):
200 mi 9 $.20/mi (est)
Benefits for County Employees
Overhead/Administration
Transportation
Flyer Distribution
Travel to Collection Site
Printing/Duplication
10,360 Brochures
187,000 Flyers
686 Posters
Contractor Expenses (2 Crews of 3 Men and 2 Trucks)
Vermiculite
Drums
Salaries
Per Diem ($50/person/day)
Transportation
Disposal
$ 2,100
11,440
240
624
176
176
128
288
$ 15,172
3,414
3,034
40
30
3,200
45,000
-------
EXHIBIT 5 (Continued)
Donated Services (est)
Brochure and Flyer Distribution
League of Women Voters
School Board (through interoffice mail to all schools)
Libraries (through interoffice mail to all libraries)
Fire Station (through interoffice mail to all fire stations 500
Estimated Total Costs: $ 70,390
Sources: Robin Byrd, HHW Project Manager, Department of Public Works, Waste
Water Treatment Division, Fairfax County, Virginia
Fairfax County Fire Department, Fairfax County, Virginia
Fairfax County Police Department, Fairfax County, Virginia
Office of Personnel, Classification Division, Fairfax, County, VA
D-25
-------
STATE OF FLORIDA
In 1983, the Florida Legislature passed the Water Quality Assurance Act to
protect Florida's ground water from further contamination. A provision of this
act mandated that the Department of Environmental Regulation conduct a
hazardous waste collection program entitled Amnesty Days. The program required
two collection periods per year for three years. Each collection period is
from one to six weeks in length. A collection effort is to be conducted at
least once in each county in those three years. The goals of the project are
to collect the greatest amount of waste from schools, small quantity
generators, government agencies, farmers, and households; to educate the public
to make them aware of what is and what is not a hazardous waste; and to
determine the need and feasibility of facilities for storage or disposal of
waste in the State.(1)
The Amnesty Day program is funded by the Water Quality Assurance Trust Fund
which is part of the Coastal Protection Trust Fund.(2) The project is funded
on an annual basis. Ceilings on administrative and publicity costs are each
set at 5 percent of the program funds. The remainder is used for the actual
collection and disposal costs.
The State is responsible for total program coordination and administration.
This includes locating a collection site, setting up collection dates,
contracting a hazardous waste management firm, publicity, and providing on-site
personnel to coordinate activities at the collection station.(3) The State
also maintains a toll-free telephone number for citizens and businesses to use
for any questions reqarding hazardous waste storage and disposal or Amnesty
Days.(5)
PUBLICITY
Publicity is funded by the State. A five-fold approach has been taken
towards educating the public on the Amensty Day program(l):
t Television and radio public service announcements
• Pamphlets targeted at specific groups or organizations
• Films shown on local cable TV stations
t Newspaper advertisements
• Electric and water bill inserts
In addition civic groups and professional organizations include Amnesty Day
information in their newsletters. The State also enlists the help of such
groups as the League of Women Voters to distribute pamphlets and disseminate
information.(3) A sample of some of the publicity materials is shown in
Exhibit 1.
D-26
-------
EXHIBIT 1. EXAMPLE PUBLICITY MATERIALS, STATE OF FLORIDA
1-900-343-OtM
H0W C9ft I £9t IINN9 oMSMV Oft Mfntff
is /iMwrious k> Sun*
FVMIL 32301 lI
!«• altw Mm. Y«
AlfMMIV 0«T* <• no* 111* I^IMHIB MMlM tO
Itnnlft NMInMM inMKMM coMciran KM
>MagMI pilHHmi. II u on. nxn lo. mtli»n IM
tnm« i«im nmn for ••!• md moor MMnMmwm
rw ••» ji__ji rt.
X 0« Mi «WV VMM M VMrfL
Amnesty Days
Amnesty Days
Amnesty Days
Amnesty Days
1-300-342-0184
29OO Stair Sim Rmd
. Flarid* 33301
TMlM
cox at S3.97S
or M.03 o*r cdm » mtarm n>
Ami'tr::.. ./ I '..'
Amnesty Days
Amnesty Days
Amnesty Days
...for tha promt disposal
of hazardous waste...
How you can got involved
•W Imrjortaru- Wriat ar» hazardous materials, and
«vr>r can't/**? f contagion •» I*****, oaefc m • larqor con
twivr antf u*» m «o>efO«m maiengi men 34
cat Hftor ro Mok ue <**ks For«jt«moMr -cMar?
t ono quflft com*n«r M • ehim o«« q«*w ownr
ean •»•!<•»• at local earn ttow «n« winoim*
vMfti aiMoroant matartat
D-27
-------
EXHIBIT 1 (Continued)
How To Participate
You may register for the
Amnesty Days Cooperative Ser-
vices Program by calling the
special toll-free telephone
number established for
"Amnesty Days". (See the toll-
free number below). The infor-
mation operator will register
your name, address and
telephone number, and you will
be contacted to schedule your
service or. you may wish to
register at the "Amnesty Days"
Collection Station. Remember.
the Collection Station will pro-
vide FREE disposal for up to 5 S
gallons or 430 pounds of com-
bined waste per participant, but
if you have more than this
quantity, you will need to use
the.Amnesty Days Cooperative
Services Program.
Additional Information
1-80O-342-O184
Amnesty Days
1-8OO-342-O184
Amnesty Days
Amnesty Days
2600 Blor SUM AMU
i Bond«32301
. ./or the proper disposal
o/hazardous waste
Information & Collection
Station Location
What is "Amnesty Days
Cooperative Services"?
Services Provided
Participant
Fee Schedule
The Amnesty Days Cooperative
Services Program is designed in
conjunction with "Amnesty
Days" to provide for the proper
handling and disposal of haz-
ardous materials which exceed
the limit under the original
"Amnesty Days" program.
Under Section 403.7241 of the
Florida Statutes. "Amnesty
Days" is made available to
dispose of small quantities of
hazardous waste — free of
charge — for homeowners.
fanners, schools, state agen-
cies, and small businesses.
The Amnesty Days Cooperative
Services Program provides not
only active disposal of haz-
ardous waste, but any infor-
mation regarding the "what's",
"Where's", and "why's" of
hazardous waste disposal. Our
objective is. that with proper
information and guidance, you
can gain confidence and under-
standing in dealing effectively
with hazardous waste manage-
ment and disposal.
The Florida contractor for
"Amnesty Days" is Triangle
Resource Industries (TRT). a
division of SCA Chemical Ser-
vices. Inc. (SCA). SCA will offer
special reduced prices for all
services to participants for the
duration of "Amnesty Days". A
schedule of dates and locations
for your area is shown on the
back of this brochure.
SCA and TRI are full-service
hazardous waste management
operations who specialize in
serving small generators,
schools, and research facilities.
This specialization helps us to
better understand your needs
in hazardous waste disposal.
An SCA Program representative
will contact you with an easy-
to-use information service
packet describing all available
services and their costs. We will
assist in evaluating any special
needs. Some areas in which you
may need help include lab
analysis, manifesting, training.
shipping containers, packaging
supplies and labels, licensing
support, health and safety, and
emergency-spill back-up.
As a result of SCA's "Amnesty
Days" involvement, we are of-
fering a minimum 23% reduc-
tion in normal charges for per-
sonnel services, transportation,
disposal, containers, and sup-
plies. To help forecast your
costs. us« the following charts:
(A full fee schedule will be pro-
vided hi the service packet.)
wtut* Disposal a. Transportotton
Wuu Tvos
(aa-gsi.dr.1
Standard Fee Amnesty Fee
liquid**
-llq.
reactive*
»133.0O
1139.00
1133.00
1«.4S/«SJ
144.3O/10
199.0O
$99.OO
399.OO
36.34/4*1
S33.0O'lb
MaMTiol* and Supplies
Item Standard Fee Amnesty Fee
33-gsl steel drams 128.0O
33-^al poly drams 138.0O
39-iiat non-corrosive
solidification drams 144.30
39-gsi corrosive
solidification drams 149. SO
averpacKs 1123.0O
vermiculite 17.30/eg
dram liners ll.30/es.
121. OO
128.30
133.23
S37.0O
S93.73
SS.BOfbg
ll.LO/ea.
Labor and Personnel
Title Standard Fee Amnesty F
Supervisor J43.0O/hr.
Explosives Technician S4O.OO/hr.
Industrial Hygiemst MO.OO/nr.
Field Chemist 333.0O/hr.
Technician 123.0O/nr.
930.00'hr
S27 OO/hr
S27 OOyHr
323.00'hr
11 9. OO/hr
D-28
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CONTRACTOR SELECTION
A request for a proposal was issued by the Department of Regulation (DER)
on January 13, 1984.(4) The award was based on eight criteria:
t Safety plan
• Technical approach and record keeping
• Project organization and management
t Experience
• Personnel assigned and level of effort
t Schedule implementation and estimated level of participation
• Ability to maintain a professional image
• Price
Each of the selection factors were assigned a value ranging from 0 to 15
depending upon the relative importance of the factor. The State then rated.
each factor in each of the submitted proposals the contract was awarded with
the highest numerical score.(4)
CONTRACTOR'S RESPONSIBILITIES
The Contractor was responsible for supplying the personnel, materials,
service, and facilities to accomplish the tasks. This included collecting,
packaging, transporting, and disposing of the hazardous waste. The Contractor
was also responsible for handling a separate accounting of all records and fees
of those businesses and government agencies that disposed of quantities of
hazardous waste above the designated limit. The Contractor was to be bonded or
insured to guarantee responsibility for any liability that may incur in the
collection, packaging, transport or disposal of the hazardous waste.(4)
SITE LOCATION
Florida is divided into several Regional Planning Councils. Each is a
group of counties with similar long-term planning interests. The statute that
established Amnesty Days set the dates for collection programs in each council.
State-level program personnel then select a good location in each council.(3)
The location chosen for a collection site must be situated on a flat, well
drained paved area. This facilitates easy and rapid clean-up of any spill that
might occur. The sight must also be centrally located, easily accessible and
its name must be well-recognized. If possible, it should be publicly-owned
property. Collection sites have included courthouses, county health
departments, city warehouses, airports and libraries.(3)
D-29
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OPERATIONS
The State operates two types of mobile collection facilities.
population and geographic area, the State may operate one or both
facilities within a Regional Planning Council. The larger of
facilities, the main site, consists of the following:
Based
types
the two
on
of
Two semi-trailers
storage space.
separated by a canopy that covers a laboratory and
• Eight chemists and/or industrial hygienists
t One explosives technician
t One Department of Environmenatal Regulation (DER) representative
The satellite site is smaller and consists of one semi-trailer with a canopy,
six chemists and one DER representive. A general site plan is shown in Exhibit
2.(5)
The two facilities operate simultaneously. They may be in the same county
within a Regional Planning Council (if substantiated by population) or in two
different counties. Each facility remains at a collection site for 1 to 6 days
depending on the geographic area to be served and the expected participation
rate.
At the collection site, the participant is directed to a receiving area.
The participant is interviewed to gather general information concerning
disposal habits, type of organization, if the participant would support a
permanent program, and their source of water (e.g., well or public system).
There is also an industrial hygienist on-site to answer any inquiries. The
participant is then routed to the collection area and transfers the waste to
the Contractor. The Contractor sorts, packages, manifests and tests any uknown
wastes in the mini-lab van. Methods to process explosives and reactives, even
though they are listed as unacceptable, are present. An on-site explosives
technician arranges for this disposal of the material. Other wastes not
accepted include those that are biologically active,.gas cylinders, and aerosol
cans.(3)
The Amnesty Days progam allows a participant to dispose of one barrel or
450 pounds of hazardous waste. If that amount is exceeded, the contractor
offers a discounted fee of 25 percent off the regular disposal fee.(6)
After sorting, the wastes are routed to a packaging area separate from the
collection area. There the waste are categorized according to hazard class,
labeled, and manifested. The wastes are then moved to a storage area. The
wastes are transported to the Contractor's fixed transfer and storage facility
to be categorized and shipped to an appropriate, permitted treatment or
disposal facility.
D-30
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EXHIBIT 2. TYPICAL COLLECTION SITE, STATE OF FLORIDA
MOBILE ALL-WEATHER COLLECTION STATION USED
IN THE FLORIDA COLLECTION PROGRAM CALLED "AMNESTY DAYS"
pubic, ares?
explosives
mag. £ van
barrier rope
information tables
Station'Overview
'genen-fors
D-31
-------
COSTS AND RESULTS
The Amnesty Days progam is funded on an annual basis in July from a grant
from the Florida Legislature. The program requires two collection periods per
year for three years. A collection period is from 4 to 6 weeks. There is one
collection period in the fall (October - November) and one in the spring
(May-June.(3) Of the total funds 5 percent has been mandated for
administrative costs and 5 percent for publicity costs. The remaining funds
are used for the actual collection, transportation, and disposal of the
hazardous waste. The costs for each collection period vary considerably.
Factors that cause this variaton include geographical locality, population size
of the county served, and the number of units operating. Also, the State does
not have a policy that excludes other Regional Councils from participating at a
collecton site.(7) Exhibit 3 is a cost overview for each of the four
collection periods that the State has operated thus far.
Costs are calculated on a daily basis for each collection center. If a
county has two collection sites operating simultaneously, the costs are
calculated individually for each site. The Contractor's costs are classified
into three categories. These are operating expenses (salaries, lodging, food)
materials and transportation costs. The cost for the DER representative is
included in the initial 5 percent allocation for administrative costs.(7)
Included in Exhibit 4 are the daily costs, by category, for three counties:
Palm Beach County, Lee County, and Highlands" County. These counties were chosen
to illustrate the differences in operating costs for three different types of
operations and populations.
Palm Beach County has a population of 576,863 with 234,339 households.(8)
The State operated both the main and satellite sites in the county. The main
site operated for 4 days in each of the two locations and the satellite site
operated at one location for 4 days. The total cost for this project was
$179,184 or $22,398 per day. In Lee County, with the population of over
205,266 (82,509 households), the State operated the main site for a period of 5
days. The total costs for this type of operation was $83,693 or $16,739 per
day. Highlands County has a population of 47,526 (18,960 households). A single
satellite site was operated at one location for 4 days. The total costs for
this project was $17,895 or $4,474 per day.
No data is currently available relating the quantities of waste collected
in any one county to costs. Thus, collection costs per pound of HHW cannot be
directly calculated. Exhibit 5 is a tabulation of data on 28 of the 43
counties where collection programs have been conducted. Total cost for these
43 counties is the sum of the funding amounts shown in Exhibit 3 ($2.4
million). Assuming that the remaining 15 counties generated a proportional
amount of HHW, a total of 937,000 Ibs or 469 tons of waste were collected. This
results in a cost of some $2.56 per pound.
Exhibit 5 illustrates the Amnesty Day collection totals for May 1984
through June 1985. Included in this exhibit are the participation rates in
percents for each of the counties where a collection took place. The
participation rates range from 0.07 percent in Dade County to 1.8 percent in
Alachua County. However, the overall participation rate of 0.31 percent
D-32
-------
corresponds with the national participation averages of less than 1 percent of
the population.
REFERENCES
1. The Florida Department of Governmental Regulation Presents Amnesty Days,
Bureau of Operations, Florida Department of Evironmental Regulation.
2. Household Hazardous Waste, Solving the Disposal Dilemma, Golden Empire
Health Planning Center, Sacramenta, CA, 1984.
3. "Personal Communication, Jan Kleman, Amnesty Days Program Coordinator,
Florida Department of Environmental Regulation, November 1, 1985.
4. Request for Proposal, Solicitation No. 8047, Florida Department of
Environmental Regulation, January 13, 1984.
5. "Amnesty Days - How You Can Get Involved", Florida Department of
Environmental Regulations, 1984.
6. "Amnesty Days Cooperative Service Program, Florida Department of
Envionmental Regulation, 1984.
7. Donna Clark, Amnesty Days Information Specialist, Florida Department of
Environmental Regulation, January 15, 1986.
8. County and City Data Book, 1983, U.S. Department of the Census,
U.S. Government Printing Office, 1983.
D-33
-------
EXHIBIT 3. COLLECTION PERIOD COSTS
CO
-pi
Collection
Period
1
2
3
4
Dates Covered
May-June 1984
October-November 1984
May-June 1985
Octob°r-November 1985
Funding Approved
July 1983
July 1984
Date Not Available
July 1985
Funding Amount
$600,000
$800,000
$200,000
$800,000
Geographical
Area Collected
7 Counties
14 Counties
7 Counties
15 Counties
Source:
Personal Communications, Jan Kleman, Florida Department of Environmental Regulation, November 1, 1985.
Personal Communication, Donna Clark, Florida Department of Environmental Regulation, January 15, 1986.
-------
EXHIBIT 4. DAILY OPERATIONS COSTS FOR FLORIDA COLLECTION SITES
GO
en
COUNTY TYPE OF FACILITY LOCATION/DAY OPERATING EXPENSES MATERIALS TRANSPORTATION
(Salaries, Lodging, Food)
Palm Beach
(232,339 Households) Main A/Day 1
A/ Day 2
A/Day 3
A/Day 4
Main B/Day 1
B/Day 2
B/Day 3
B/Day 4
Satellite C/Day 1
C/Day 2
C/Day 3
C/Day 4
$ 4,860
4,860
4,860
4,860
4,860
4,860
4,860
4,860
3,240
3,240
3,240
3,240
$ 2,755
2,625
2,867
3,036
1,374
1,094
1,014
1,891
857
399
322
233
$ 12,172
16,899
20,592
18,612
Subtotal
7,163
6,989
5,598
11,188
Subtotal
4,915
2,303
1,384
1,067
TOTAL
$19,787
24,384
28,319
26,508
98,993
13,397
12,943
11,472
17,939
$55,751
9,012
5,942
4,946
4,540
Subtotal $24,440
Total For Palm Beach County
$179,184
-------
EXHIBIT 4. (Continued)
Co
O>
COUNTY TYPE OF FACILITY
Lee County Main
(82,509 Households)
Total for Lee County
Highlands County Satellite
(18,960 Households)
LOCATION/DAY
A/Day 1
A/ Day 2
A/ Day 3
A/ Day 4
A/ Day 5
A/ Day 1
A/Day 2
A/ Day 3
A/ Day 4
OPERATING EXPENSES
$ 4,860
4,860
4,860
4,860
4,860
$ 3,240
3,240
3,240
3,240
MATERIALS
$ 1,668
1,784
1,814
1,580
2,725
$ 443
544
684
411
TRANSPORTATION
$ 7,464
10,231
7,900
9,419
14,808
$ 1,946
2,241
3,192
1,493
TOTAL
$ 14,022
16,875
14,574
15,859
22,393
$ 83,723
$ 5,629
6,025
7,116
5,144
Total For Highlands County
$ 23,914
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EXHIBIT J, "AMNESTY DAY" COLLECTION TOTALS (MAY 1984 - JUNE 1985)
O I
OJ I
County
Escambia County
Okaloosa County
Santa Rosa County
Walton County
Bay County
Holmes County
Washington County
Brevard County
Orange County
Osceola County
Lake County
Seminole County
Volusia County
Putman County
St. Johns County
Flagler County
Baker County
Duval County
Clay County
Nassau County
Alachua County
Dade County
Broward County
Monroe County
Manatee County
Hillsborough County
Pinellas County
Pasco County
Totals
Number of
Participants
109
201
20
23
130
11
14
454
673
143
172
162
192
46
52
22
11
383
151
54
982
439
629
37
334
293
1100
230
7^067
Amount of Waste
Collected (pounds)
33,195
29,419
9,450
4,145
18,885
3,380
3,030
33,110
63,588
9,679
16,160
13,179
17,785
6,620
8,184
1,377
658
81,249
17,979
9,557
91 ,640
54,982
56,748
2,604
17,282
35,744
55,480
6,340
609,809
Population
(x 1000)
233.8
109.9
56.0
21.3
97.7
14.7
14.5
273.0
471.0
49.3
104.9
179.8
258.8
50.5
51.3
10.9
15.3
571.0
67.1
32.9
151.3
1,625.8
1,018.2
63.2
148.4
647.0
728.5
193.6
7J08.4
Households
(x 1000)
81.1
37.5
18.6
8.0
34.8
5.2
5.2
101.8
170.8
18.6
41.7
63.2
105.8
18.4
18.6
4.4
4.2
208.4
21.6
11.0
54.6
609.8
417.5
26.3
62.0
237.9
319.5
81.3
2,733.2
Participation
Rate %
0.13
0.50
0.10
0.29
0.30
0.21
0.27
0.44
0.39
0.77
0.41
0.26
0.18
0.25
0.28
0.50
0.26
0.18
0.70
0.49
1.8
0.07
0.15
0.14
0.54
0.12
0.34
0.28
0.31
References: • Amnesty Day Collection Totals, Florida Department of Environmental Regulatipns, Tallahasee, Florida, 1985.
• County and City Data Book, 1983, U.S. Department of the Census, U.S. Government Printing Office, 1983.
-------
corresponds with the national participation averages of less than 1 percent of
the population.
REFERENCES
1. The Florida Department of Governmental Regulation Presents Amnesty Days,
Bureau of Operations, Florida Department of Evironmental Regulation.
2. Household Hazardous Waste, Solving the Disposal Dilemma, Golden Empire
Health Planning Center, Sacramento, CA, 1984.
3. Personal Communication, Jan Kleman, Amnesty Days Program Coordinator,
Florida Department of Environmental Regulation, November 1, 1985.
4. Request for Proposal, Solicitation No. 8047, Florida Department of
Environmental Regulation, January 13, 1984.
5. "Amnesty Days - How You Can Get Involved", Florida Department of
Environmental Regulations, 1984.
6. "Amnesty Days Cooperative Service Program, Florida Department of
Envionmental Regulation, 1984.
7. Donna Clark, Amnesty Days Information Specialist, Florida Department of
Environmental Regulation, January 15, 1986.
8. City and County Data Book, 1984.
D-38
-------
APPENDIX E
MEMORANDA AND LETTERS
RELATED TO LIABILITY OF
COLLECTION PROGRAMS
E-l
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE:
JAN 281986
SUBJECT. CERCLA and RCRA Liability of Municipal Sponsors of Household
Hazardous Waste Collection Programs
FROM: John P. Lehman, Director fjJU*/A^^iLf
Waste Management and Economics Division (WH-565)
T0: Basil G. Constantelos, Director
Waste Management Division
Region V
I am responding to your October 29, 1985, memorandum
requesting an Agency policy statement concerning the liability
under the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA) of municipal sponsors of household
hazardous waste collection programs. In addition, this
memorandum clarifies the issue of potential liability under
the Resource Conservation and Recovery Act (RCRA). The
following interpretations are based on discussions of these
issues with the Office of General Counsel (OGC) and the Office
of Enforcement and Compliance Monitoring (OECM).
• In a June 7, 1984, memorandum to the Deputy Administrator,
Lee Thomas (then Assistant Administrator for the Office of
Solid Waste and Emergency Response) clarified the issue of
RCRA liability. This memorandum, which is attached, stated
that household hazardous wastes are by definition exempt from
regulation under Subtitle C of RCRA. Section 261.4(b)(l)
unconditionally exempts household wastes from being designated
as hazardous even when accumulated in quantities that would
otherwise be regulated or when transported, stored, treated,
disposed, recovered, or reused. However, when household
wastes are mixed with hazardous wastes from small quantity
generators, this resulting mixture is subject to the small
quantity generator rules (Section 261.5). In addition,
when household waste is mixed with other regulated hazardous
wastes, the entire mixture becomes subject to full hazardous
waste regulation (Section 261.3(a)(2)). For this reason,
sponsors of household hazardous waste collection programs
should be careful to limit the participation in their programs
to households to avoid the possibility of receiving regulated
hazardous wastes from commercial or industrial sources.
With regard to CERCLA, we cannot offer relief from long-
term liability. CERCLA does not contain any type of exclusion
for household waste or any type of exclusion based on the
amount of waste generated. As a general matter, any waste that
qualifies as a hazardous substance under CERCLA is subject to
the liability provisions of Section 107. Hazardous substances
are both defined under Section 101(14) and designated under
Section 102(a). Therefore, if a household waste contains a
substance that is covered under either section (whether or not
E-2
EPA Form 1320-6 (R«v. 3-76)
-------
it is a RCRA hazardous waste), potential CERCLA liability
would apply regardless of whether the material was picked up
as part of a community's routine trash collection service or
was gathered as part of a special collection day program.
With respect to household hazardous waste, such waste would
clearly qualify as a "hazardous substance" if it contains any
substance listed in Table 302.4 of 40 CFR Part 302.
With regard to enforcement under CERCLA, you noted that
John Skinner, former Director of this office, recently cited
a policy statement in a May 4, 1984, letter (attached) from
Region I Administrator, Michael DeLand, to Dana Duxbury of the
Massachusetts League of Women Voters. This policy statement
relied on enforcement discretion in indicating that EPA had no
intention of taking enforcement action against a Massachusetts
town that sponsored a contracted collection day, if problems
arose in the transportation or disposal of the household
hazardous waste collected during the collection program.
Further clarification was offered by Courtney Price (OECM)
in a memorandum dated May 11, 1984 (attached), to Alvin Aim,
former Deputy Administrator. For the specific case of that
Masssachusetts town, the company collecting and transporting
the wastes and the disposal facility owner or operator would
be considered the responsible parties.
While you are correct in stating that the Agency's general
policy is to not give "no action" assurances in enforcement
matters (see attached Courtney Price memorandum of November 16,
1984), Ms. Price addressed a specific household hazardous
waste collection program in the May 11, 1984, memorandum and
explained their position in the Region I case in Massachusetts.
The decision of "no action" in the Massachusetts case was
based on the facts about that specific program. An important
feature was limiting collections to household hazardous wastes.
No wastes from small commercial businesses were accepted.
Courtney Price indicated that OECM would have to look at the
specific facts of any situation involving wastes from small
businesses to determine whether an exercise of enforcement
discretion would be appropriate.
In our recent discussions with OECM, we have considered
the concept of "no action" as a possible general policy for
sponsor* of household hazardous waste collection programs.
OECM ha* not yet completed their analysis of this issue. They
expect to complete their analysis in the next several weeks
and will supply their policy statement in a separate memorandum.
If you have any questions regarding the issues addressed
in this memorandum, please contact Michael Flynn of my staff
at 382-4489.
Attachments
E-3
-------
«
. I
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
DATE:
SUBJECT- CERCLA Liability to Municipal Sponsors of
' Household Hazardous Waste Collection Programs
FROM:
Basil G. Constantelo
Waste Management 01 vis
TO: John P. Lehman, Director
Waste Management and Economics Division (WH-56b)
I am requesting a definitive Agency policy statement concerning the
CERCLA liability of municipal sponsors of household hazardous waste
collection programs.
Under Section 8001 of RCRA, Region V awarded 17 yrants, totaling
$466,194, to local communities to support household hazardous waste
collection programs. Several grantees (Glen Ellyn, Illinois, the
Northwest Municipal Conference (suburban Chicago), and Shiawassee
County, Michigan) have requested relief from lony-tenn Superfund
liability. They are hesitant to sponsor such programs without
assurances from the United States Environmental Protection Agency
that they will not incur lony-term liability.
During the Headquarters-sponsored HSWA Conference in Washington on
August 1-2, 1985, Dr. John Skinner endorsed a policy statement on this
issue that had been issued by Region I. I have enclosed the letter
— outlining that policy, a May 4, 1984 letter from Region I Administrator
Michael Del and to Ms. Dana Duxbury of the Massachussetts League of
Women Voters. Region I's policy relied on Agency enforcement discretion,
I had solicited a similar policy statement from our Office of Reyional
Counsel (ORC) (see enclosed September lu, 1985, memo to Ms. Mary Gade).
Regional Counsel's response, after conferring with Mr. Steven Leifer of
the Office of General Counsel (OGC) has been one of "no exceptions."
The precedent for this approach is a November 16, 1984 memo from
Ms. Courtney Price (enclosed), which advises against yiving "no action"
assurances in enforcement matters. ORC and OGC recommended chat any
deviation from the Courtney Price memo would have to come from
Headquarters in the form of a policy statement from the Office of
Solid Waste and Emergency Response.
Because several communities have put their household hazardous waste
collection plans on hold while awaiting Agency guidance, a prompt
response would be greatly appreciated.
If you or your staff have any further questions, please contact Ken
Westlake of my staff at FTS 886-7b80.
Enclosures
E-4
EPA FORM 13304 (RtV. 3-79)
-------
»sueeh014
/sign«d/ Lee M. Thomas
t«
Day a
MM ini aerator
'„* • • • -j — -• •
tha Mputy Ad»inUtfator
response to your •avorandua of Nay ?* 1M4»'Z '-'""' '
have looked into tha issue of 1PA support for coasvinity-wida
- Collectlona of household hasardous waate. Z fully agree that
"-* 4isp«**l of household hasardoua waste IB Subtitle C facilities
'^l«prv far able to disposing of these vateriala in aanitary
,:T lajsdfilia and that BPA should support these progravs to the
~ "^ngreateat. axtsnt practicable. ... .,
» I aa soaowhai laaa cartaia aa to tha axtaot
1EPA should bocoaa involvad in tha prograaa aine
of tha Agency's regulatory control undar BGBA*•'.-" -.-'
wastes «ra specifically excluded froa tha definition
-------
KV to 1PA involvamattt in thaaa prograaa,
Mdftr tha circuaataocaa, tha raaponaibility
aad ovarsiehfc appropriataly raata with th«
ttataa. Any aappoct which tha Agancy dacidaa to
•«t«Ml to such program afaould ba giwan on * caaa by caaa
te«i« a4tar a thorough raviaw of tha «p«cific situation and
only at tba roqvoat of individual 8tata». Abaant any
rofiVlAtajry control ahould problaaa ariao* parhapa tha aoat
appropriata couraa for ETA to taka would ba to aiaply
provida clarification on apacific iaauaa whan aakad («»q»»
lmaat
clarification of tha liability iaaua in Haaaaclmaatta}
and to avoid actiona that night vnnacaaaarily diacouraga tha
davalopnant of auch programa*
WH-5€2BtRAxelrad 15/18/84 tS240:x382-5218
E-6
-------
/
^.^-U^. -«~ ft
0 5L
UNfTED STATES ENVIRONMENTAL PM0TECTION AGENCY
MESION I
J, P. KfNNEOY FEOCTA^ BUILDING. BOSTON. MASSACHUSETTS OZJOS
May "4, 1984
Dana Duxbury
Natural Resources Director
League of Wonen Voters of Massachusetts
B Winter Street
Boston, KA 02108
•Dear Dana:
Thank you for your letter of April 17, 1984, concerning the commen-
dable efforts of the League of Ucnen Voters to encourage residential
hazardous waste cleafn-up programs in the Commonwealth of Massachusetts.
Specifically,.your letter raises the question whether a town would
become liable for remedial costs if there is a'release to the environ-
ment of hazardous substances collected during the clean-up either from
the ultimate disposal facility or during transporation to the ultimate
disposal facility.
EPA has reviewed your letter and the accompanying February 9, 1?34,
memorandum from V?illiam F. Cass, Director, Division of Hazardous
Waste, Department of Environmental Quality Engineering (DEQE),
specifying DFCE's policy regarding household hazardous waste collec-
tion days. We believe the DEOE sets forth sound requirements for the
safe and proper handling of hazardous wastes during this collection
effort. Based on our understanding of how the program operates .and
assuming the town adheres to the requirements set forth in Mr. -'Cass's
memorandum, EPA has no intention of taking an enforcement action
against the town under the circumstances described in your letter.
EPA applauds the League's involvement in this effort. The establish-
ment of these collection programs ensures the safe disposal of chemical
that might otherwise be handled improperly. Further, such programs
perform a valuable public education function. We support you in these
endeavors and hope that household hazard waste collection days become
an annual event in every community.
Sincerely yours,
tir
Michael R.
Regional Administrator
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4j\i7=0 3TATSS E^RONMSiVrrAL PROTECTION AGENCY'
WASHINGTON. O.C. 2C460
MAY 11
MEMORANDUM
SUBJECT: Potential EPA InvoLveaenc in "Household Hazardous Waste
Collection Days" ->
/ I
FROM: Courtney M. Price ( .
Assistant Administrator far Inforcement
and Compliance Monitoring
"•« . « 1 «-•< •» T 1 ^ •»
*w : A—v^n l*. A-—
Deputy Administrator
My office recently became aware of hazardous waste collec-
tion cays vhen ve vere" asked by Region I to consider the poten-
tial liability of cctisunities involved in --ase activities.
In gsnsrsl, I*support the ccncept of household hitarcous vasts
collection days and advocate £?A involvement in support of these-
activities. " "
- ' In the specific situation presented to ny office by Region
I,? a .town in Massachusetts sought assurances froc IPA that the
town would not be held liable for any problems that later arose
from disposal of waste through a collection day. My office has
advised Region I that under the specific facts presented by
Massachusetts for their household hazardous waste collection
days, the Agency would1 not intend to take an enforcement action
against the sponsoring coaounity, if a hazard arose during
transportation or later disposal (see attached letter). In
these circumstances, the company collecting and transporting
the wasteland the disposal facility owner or 'operator would
be conti'wrtd che responsible parties.
I should note that the Massachusetts program is
expressly limited to collection of hazardous waste which is
produced, by a household as part of normal household activity.
The Wall Street Journal article that was attached to your May 1,
1984 memorandum indicated that the program in Florida allowed
disposal of waste from small businesses. This office's statement
concerning liability only covered collection of household waste,
an activity of which I fully approve. I feel we would need to
look at the specific facts of a situation involving waste from
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small bust
discretion^
Accacfamenc
:.«o deceraine whecher an exercise of enforceaent
be appropriate under che particular circuascances
£-9
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3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. DC. 20460
161984
Of tICI 0'
tNtO'CEMtmr ANC
MEMORANDUM
SUBJECT: Policy Against "No .Action" Assurances
FROM: Courtney M. Price
Assistant Administrator for En
and Compliance Monitoring
TO: Assistant Administrators
Regional Administrators
General Counsel
Inspector General
This memorandum reaffirms EPA policy against giving
definitive assurances (written or oral) outside the context of
a formal enforcement proceeding that EPA will not proceed with
an enforcement response for a specific individual violation of
an environmental protection statute, regulation, or other
legal requirement.
"No action" promises may erode the credibility of EPA's
enforcement program by creating real or perceived inequities
in the Agency's treatment of the regulated community. This
credibility is vital as a continuing incentive for regulated
parties to comply with environmental protection requirements.
In addition, any commitment not to enforce a legal
requirement against a particular regulated party may severely
hamper later enforcement efforts against that party/ who may.
claim good-faith reliance on that assurance, or against other
parties who claim to be similarly situated.
This policy against definitive no action promises to
parties outside the Agency applies in all contexts, including
assurances requested:
• both prior to and after a violation has been committed;
. • on the basis that a State or local government is
responding to the violation;
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• on the basis that revisions to the underlying legal
requirement are being considered;
0 on the basis that the Agency has determined that the
party is not liable or has a valid defense;
0 on the basis that the violation already has been
corrected (or that a party has promised that it will
correct the violation); or
• on the basis that the violation is not of sufficient
priority to merit Agency action.
The Agency particularly must avoid no action promises
relating either to violations of judicial orders, for which a
court has independent enforcement authority, or to potential
criminal violations, for which prosecutorial discretion rests
with the United States Attorney General.
As a general rule, exceptions to this policy are warranted
only
• where expressly provided by applicable statute or
regulation (e.g., certain upset or bypass situations)
0 in extremely unusual cases in which a no action
assurance is clearly neccessary to serve the public
interest (e.g., to allow action to avoid extreme risks
to public health or safety, or to obtain important
information for research purposes) and which no other
mechanism can address adequately.
Of course, any exceptions which EPA grants rrust be in an area
in which EPA has discretion not to act under applicable law.
This policy in no way is intended to constrain the way in
which EPA discusses and coordinates enforcement plans with
state or local enforcement authorities consistent with normal
working relationships. To the extent that a statement of EPA's
enforcement intent is necessary to help support or conclude an
effective state enforcement effort, EPA can employ language
such as the following:
"EPA encourages State action to resolve violations of
the Act and supports the actions which (State)
is taking to address the violations at issue. To the extent
that the State action tfoes not satisfactorily resolve the
violations, EPA may pursue its own enforcement action."
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1 am requesting that any definitive written or oral no
action commitment receive the advance concurrence of my office.
This was a difficult decision to reach in light of the valid
concerns raised in comments on this policy statement;•neverthe-
less, we concluded that Headquarters concurrence is important
because the precedential implications of providing no actic-n
commitments can extend beyond a single Region. We will attempt
to consult with the relevant program office and respond to any
formal request for concurrence within 10 working days from the
date we receive the request. Naturally, emergency situations
can be handled orally on an expedited basis.
All instances in which an EPA official gives a no action
promise must be documented in the appropriate case file. The
documentation must include an explanation of the reasons
justifying the no action assurance.
Finally, this policy against no action assurances does not
preclude EPA from fully discussing internally the prosecutorial
merit of individual cases or from exercising the discretion it
has under applicable law to decide when and how to respond or
not respond to a given violation, based on the Agency's normal
enforcement priorities.
cc; Associate Enforcement Counsels
OECM Office Directors
Program Compliance Office Directors
Regional Enforcement Contacts
U.S. Environment?! " -'-action Agency y
Region 5,Lii.r?.ry " •"",!)
77 West Jackson L.ou:-vard, 12th Floor
Chicago, 11 6G604-3590
END
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