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PROCEEDINGS OF THE SEVENTH NATIONAL -
UNITED STATES ENVIRONMENTAL
^PROTECTION AGENCY
CONFERENCE ON
HOUSEHOLD HAZARDOUS
WASTE MANAGEMENT
DECEMBER 8-12,1992
MINNEAPOLIS, MINNESOTA
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PROCEEDINGS OF THE SEVENTH NATIONAL
UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY
CONFERENCE ON
HOUSEHOLD HAZARDOUS
WASTE MANAGEMENT
DECEMBER 8-12, 1992
MINNEAPOLIS, MINNESOTA
Sponsored by
U.S. Environmental Protection Agency
Co-Sponsored by
Minnesota Pollution Control Agency
EPA Headquarters Library
Conference Managed by
Waste Watch Center
and
SWANA
Proceedings Prepared by
The Waste Watch Center
16 Haverhill Street, Andover, MA 01810
January 1993
Printed on Recycled Paper
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Waste Watch Center
The Waste Watch Center r(WWC), specializes in education, consensus building
and policy development to promote improved integrated solid and hazardous waste
management, pollution prevention, recycling, waste minimization and household
hazardous waste management (HHWM). WWC president, Dana Duxbury, is also
president of Dana Duxbury & Associates, which formerly managed this conference.
SWANA
j T
SWANA, an association of solid waste management professionals, provides a
vehicle for information exchange among those in the solid waste management field
Disclaimer
Although the information in this document has been funded wholly or in part by the
United States Environmental Protection Agency under Grant 901909-01 to SWANA,
Silver Spring, MD, and Waste Watch Center (WWC), Andover, MA, it may not
necessarily reflect the views of the Agency and no official endorsement should be inferred.
The report is a compendium of presentations made at the seventh annual Household
Hazardous Waste Management Conference. The texts have been submitted by the speakers
themselves and, except where noted, have not been summarized or edited by WWC. The
speeches do not necessarily reflect the position of U.S. EPA, WWC, or SWANA.
Management and regulation of HHW is a rapidly evolving issue; information presented at
the conference was accurate and up to date at the time of presentation.
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U.S. ENVIRONMENTAL PROTECTION AGENCY
HOUSEHOLD HAZARDOUS WASTE MANAGEMENT CONFERENCE
DECEMBER 8-12, 1992 MINNEAPOLIS, MINNESOTA
CONTENTS
Opening Plenary Session Page
Keynote: HHW and Municipal Solid Waste — Terry Grogan, U.S. EPA, DC 1
Design for the Environment — Walter Stahel, The Product Life Institute, Switzerland 6
Implications of Mercury in MSW Incinerator Emissions — Mike Winka, NJ DEP & Energy, NJ 12
New Initiatives in Science Education — Herbert Thier, CEPUP-University of California, CA 33
An Overview of CESQG Issues — David Galvin, Seatde Metro, WA 37
Source Reduction Priorities — Philip Dickey, Washington Toxics Coalition,.WA 42
Luncheon Speaker: Legislative Initiatives to Reduce the Toxicity of Municipal Solid Waste
— Representative Jean Wagenius, MN 51
CONCURRENT WORKSHOPS 1 A-D
Workshop 1-A - How To's
Why Establish an HHW Program — David Galvin, Seattle Metro, WA 63t
Getting Organized — Suzanna Rumon, Laidlaw Environmental NE, MA 71
Collection & Program Options — Walter Haas, MPCA, MN *
Home Storage Survey — Michael Bender, Central Vermont Regional Planning Commission, VT 74
EPA Indoor Air Program — Jim Darr, OPPT, U.S. EPA . 76
Workshop 1-B - Paint I
Paint Re-use and Recycling Collection Options — Carolyn Dann, WWC, MA 79
Sorting & Testing — George Kinney, Dakota County, MN 83
Reprocessing Paint — A New Method — Scott Herbert, The Green Paint Company, MA 86
Workshop 1-C - Household Batteries I
NiCad Collection and Recycling — Norm England, Portable/Rechargeable Battery Association, GA .... 92
Primary Battery Reformulation, Collection and Recycling
— Terry Telzrow, Eveready Battery Company, OH 98
A California Study — Fernando Berton, California Integrated Waste Management Board, CA Ill
Hennepin County's Collection Program — Cheryl Lofrano-Zaske, Hennepin County, MN 119
Workshop 1-D - Other Problem Wastes
Medical Wastes: San Francisco Safe Needle Disposal Program — Brad Drda, Sanitary Fill Co., CA .. 121
White Goods — Catherine Wilt, University of Tennessee, TN 125
Refrigerant Recovery — Paul Smith, Sanitary Fill Co., CA '.. 128
Aerosol Contents Study — Greg Crawford, Steel Can Recycling Institute, PA 131
CONCURRENT WORKSHOPS 2 A-E
Workshop 2-A - How To's
* Not available at time of publication
t Reprinted from the Proceedings of the Sixth National Conference on Household Hazardous Waste
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Liability — John Fogarty, U.S. EPA, DC 140t
RCRA & HHW — Charlotte Mooney, OSW, U.S. EPA, DC I43t
Workshop 2-B - Paint H Market Issues
Marketing Recycled Paint — Anne Thorson, Washington County Public Health, MN 146
A Paint Re-use and Recycling Consensus — Tracy Bone, OSW, U.S. EPA, WA 154
GSA's Procurement Process — Carolyn Dann, WWC, MA . 155
Latex Paint Waste Treatment/Recycling by Pyrolysis
— Phil Farina, Environmental Purification Industries, OH 158
Workshop 2-C • Household Batteries U: Recycling in the U.S.
INMETCO's Nickel-Cadmium Recycling System — John Patterson, INMETCO, PA 161
Mercury Refining — Alan Wilds, Mercury Refining, NY 168
A New US. Battery Recycling Facility — Bill Meador, R&R Resource Recovery, TX 172
Workshop 2-D - Fluorescent Lamps
Fluorescent Lamp Recycling hi the U.S. — Dana Duxbury, WWC, MA 176
Lamp Maker Initiatives — Beverly Grimm, GE Lighting, OH 181
New Developments in Europe — Christer Sundberg, MRT System AB, Sweden 182
Workshop 2-E - Collection Case Studies I
Programs in Florida — Jan Kleman, DER, FL 185
The EPA Region 8 Program — Brian Rimar, Region 8 U.S. EPA, CO 192
The Delaware Pilots — Julie Wilke, Delaware Solid Waste Authority, DE 194
Texas One-Days — Ingrid Dierlam, Texas Water Commission, TX 203
CONCURRENT WORKSHOPS 3 A-E
Workshop 3-A - How To's
Developing an RFP — LeeAnn Merashoff, Laidlaw Environmental Services (ME), MA 208
Site Selection — AJ. Novak, Chemical Waste Management, IL 213
Permitting and Plan Approval — Sharon Rehder, NY DEC, NY 215
Negotiating a Contract — Liz McCormick, Laidlaw Environmental Services, SC 218
Workshop 3-B - Pesticide Use, Collection and Reduction
Overview of Farm Pesticide Collection Programs — Chuck Cubbage, Department of Agriculture, MI . 229
National Home & Garden Pesticide Use Survey — Tracy Bone, U.S. EPA, DC 238
Minnesota's Farm Pesticide Program's — Larry Palmer, Department of Agriculture, MN . 239
Workshop 3-C - Education I — Schools: Implementation and Evaluation
Environmental Education in the Schools: Minnesota's Experience
— Shirley Dougherty Department of Education, MN 243
Integrating HHW into an Environmental Curriculum — Sarah Dewey, HHWP, MO 245
Evaluating Effectiveness — Shirley Niemeyer, University of Nebraska-Lincoln, NB 249*
Workshop 3-D - Used Oil & Filters
EPA's Management Standards — Charlotte Mooney, OSW, U.S. EPA, DC 254f
Washington State's Program — Bill Green, Department of Ecology, WA 258
API's Program — Craig Campbell, API, DC 267
Workshop 3-E - Waste Management I: Waste Types and Management
Waste Types and Quantities — George Kinney, Dakota County, MN 271
Which HHW Is Reusable / Recyclable? — Brian Johnson, Santa Monica, CA 273
Identifying HHW — Deanna Seaman, Norcal, CA 279
Recycling Antifreeze — Rick Bowen, First Brands Corp., CT 283
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CONCURRENT WORKSHOPS 4 A-E
Workshop 4-A - How To's
Load Checking — Kalhy Kendall-Witkovski, Des Moines Metro Solid Waste, IA 300
Developing a Budget — Rachel Rosenzweig, Lancaster County, PA 308
Funding Via EPA's Enforcement Efforts — Brian Rimar, Region 8 U.S. EPA, CO 312
Creative Use of State Enforcement Efforts
— Judi Frantz, California Department of Health Services, CA 314
Workshop 4-B - CESQG I
Overview — Ned Brooks, MPCA, MN 319
Federal Overview — Charlotte Mooney, OSW, U.S. EPA, DC 321f
Overview of State Definitions, Laws, Regulations, etc. — Dana Duxbury, WWC, MA 325
Workshop 4-C - Education II — General Public
Changing Attitudes, Knowledge and Behavior
— Shirley Niemeyer, University of Nebraska - Lincoln, NE 333
Neighborhood Education — Lilias Jones, Eco Solutions, CO 338
Measuring the Effectiveness of an Education Program — Paula Kehoe, San Francisco, CA 342
Workshop 4-D - Source Reduction I: Labeling
"Chronic Hazard Labeling Guidelines" — Chuck Jacobson, Consumer Product Safety Comm., DC ... 346
Scientific Certification Systems Product Evaluation — Kai Hagen, Scientific Cert. Systems, CA .... 351t
Green Seal's Labeling Progress: Used Oil and Household Cleaners — Jim Dougherty, Green Seal, DC 359
Constituent Labeling — Philip Dickey, Washington Toxics Coalition, WA 361
Workshop 4-E - Waste Management D: Options
Incineration — Robert Coffey, Rollins, DE " 371
Fuels Blending — Joe Foley, Chemical Waste Management, IL 378
Treatment — Earl Finder, U.S. Filter Recovery Systems, Inc., MN *
Landfills — Loren Alexander, Chemical Waste Management, IL 380
Luncheon Speaker: A Common Vision for Our Environmental Future
— Hubert Humphrey III, Attorney General, State of Minnesota 385
CONCURRENT WORKSHOPS 5 A-D
Workshop 5-A - How To's
Health & Safety Concerns — Judy Orttung, San Bernardino, CA 391
Managing Costs — Martha Beck, Ingham County Health Department, MI 396
Personnel & Training — Donna Portner, MPCA, MN 402
Managing and Integrating HHW into All the Media Offices — Leslie Goldsmith, MPCA, MN 406
Workshop 5-B - CESQG U — Collection Program Case Studies
Kitsap County — Annie Bringloe, Kitsap County, WA *
Duluth's Pilot — Ned Brooks, MPCA, MN 408
Anchorage — Bill Kryger, Anchorage and Tom Poliquin, Northwest EnviroService, AK 410
Windham — Jan Ameen, Windham Solid Waste District, VT 421
Workshop 5-C - Collection Case Studies H
TVA's Program — Terry Kiraly, Tennessee Valley Authority, TN ..." *
Leeds, England — Elaine Kerrell, SWAP, England; Sonia Heaven, University of Southampton 427
Alachua County — Jill Parker, Alachua County, FL; Wilson Anthony, Quadrex Environmental, FL . . . . 437
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Workshop 5-D - Source Reduction II: How to Measure Results
Surveys — Lois Kaufman, Environmental Resource Associates, NJ 439
Scanning for Consumer Behavior — Adam Portner, Information Resources, Inc., NJ 443
Four Season Sorting — John Ikeda.and Susan Mitchell, MPCA, MN 446
Measuring Effectiveness of HHW Collection, Education and Source Reduction
Programs — Isao Kobashi, Santa Clara Department of Planning and Development, CA 464
CONCURRENT WORKSHOPS 6 A-D
Workshop 6-A - Rural Programs
Overview of Issues — Lola Schoenrich, Minnesota Project, MN 468
Eastern Washington State's Program — Bill Green, Department of Ecology, WA 477
Workshop 6-B - CESQG m — Information
Target Criteria for Ranking Businesses — David Galvin, Seattle Metro, WA 481
Sources of Information — Anne Moser, Seattle Metro, WA 486
Great Lakes Technical Resource Library: A Source of Pollution Prevention Documentation
— David Liebl, University of Wisconsin, WI 491
Workshop 6-C - Permanent Programs I
Training Requirements and Technical Assistance — Leslie Goldsmith, MPCA, MN 492
Types of Permanent Facilities — Carolyn Dann, WWC, MA 496
Mobile Permanent Programs — Jennifer Holliday, Chittenden Solid Waste District, VT 500
Regulatory Requirements — Judi Ftantz, California Department of Health Services, CA 303
Workshop 6-D - Source Reduction in — Availability & Effectiveness of Alternatives
Cleaning Products — Wanda Olson, Minnesota Extension, MN 506
Household Pesticide IPM — Subi Subrramanyam, University of Minnesota, MN 513
Artist Materials — Angela Babin, Safety in the Arts, NY 521
CONCURRENT WORKSHOPS 7 A-D
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Workshop 7-A - Waste Management HI: Controlling the Destiny of Your Waste
Writing an RFP and Contract
Program Manager's Perspective — Jim Gruber, Hartford, VT 526
Contractor's Perspective — Eric Laut, Chemical Waste Management, IL 531
Waste Tracking — George Kinney, Dakota County, MN 539
Workshop 7-B - CESQG IV — Technical Assistance
State Roundtable — Robert Style, WRITAR, MN 540
MnTAP — Donna Peterson, Minnesota Technical Assistance Program, MN 548
MA Program — Grace Caner, OTA, MA 553
Workshop 7-C - Permanent Programs n — Case Studies
Orange County, CA — Jaimy Jackson and Jim Pfaff, Orange County, CA 556
Portland, OR — Sam Chandler, Portland METRO, OR 568
Rochester, NY — Ed Harding, Monroe County Solid Waste, NY 577
Workshop 7-D • Source Reduction IV: Reformulation
Removing Mercury from Household Batteries — Terry Telzrow, Eveready, OH ; ., . 586
Removing Solvents from Latex Paint — David Maurer, Glidden Paint Company, OH 598
Low Hazard Paint Strippers — Nancy Walsh and Carlos Lopez, 3M, MN 600
Appendices
Appendix I - Final Agenda 602
Appendix n - Final List of Speakers 611
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Appendix ID - Speaker's Biographical Sketches 621
Appendix IV - List of Attendees 629
Appendix V - Poster Session Participants ; 641
Appendix VI - National Listing of HHW Programs •* 643
Appendix VII - HHW Management State Contacts 670
Appendix Vm - Permanent HHW Management Program Managers 676
Appendix IX - Collection Program Contractors 687
Appendix X - WWC Publications Order Form 693
- HHWM VII Audio Tape Order Form 695
- U.S. EPA Order Form 696
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REMARKS BY SYLVIA LOWRANCE
AT EPA'S 7TH ANNNUAL HOUSEHOLD HAZARDOUS WASTE CONFERENCE
' MINNEAPOLIS, MINNESOTA
DECEMBER 9, 1992
INTRODUCTION
I'd like to welcome you to EPA's 7th Annual Household
Hazardous Waste Conference.
Over the past seven years, as we have explored ways of
managing household hazardous waste, we have seen many positive
changes in the management of both municipal solid waste and
household hazardous waste.
The most significant of those changes has been that of
approach. T.S. Elliott once wrote:
"We shall not cease from exploration,
and the end of all our exploring
will be to arrive where we started
and know the place for the first time."
We have gone from a "what do we do with this trash" philosophy
to a more holistic approach of "what can we do create less trash" -
- from an end of pipe approach to an entire process reassessment.
SOURCE REDUCTION AND RECYCLING
That change in approach has been evident in our handling of
municipal solid waste. In the Agenda for Action—our long term
strategy for handling municipal solid waste—we have placed source
reduction and recycling at the top of our preferred methods of
waste management.
Our latest report on municipal solid waste, published every
two years, is a graphic example of why we feel that a shift in
approach is necessary to meet the ever escalating volume of
municipal solid waste. The report shows a jump of close to 16
million tons more being generated annually—for a new total of 196
million tons. The average American now throws away 4.3 pounds of
garbage a day.
And as the generation of municipal solid waste continues to
increase, the capacity to handle it is decreasing. Many
landfills and combustors have closed, and new disposal facilities
are often difficult to site.
LANDFILL RULES
Last year we issued new municipal solid waste landfill rules
that will result in major changes in the way many landfills are
operated, designed and located. These rules were based on a
Congressional mandate to write criteria for facilities that receive
either household hazardous waste or small quantity generator
hazardous waste.
Among other things, the rule establishes operating criteria to
ensure that citizens and the surrounding environment are protected
from risks caused by^unsafe operating practices.
We have also established design criteria that ensure that ground
water adjacent to our nation's landfills will be free of
contaminants.
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To ensure that ground water is protected in the event that
the engineered containment system were to fail, the regulations
require that ground-water monitoring be conducted. If for some
reason, a significant release has occurred and ground water has
been contaminated, the rule requires that the contamination be
cleaned up.
We think that the rule will result in increased public
confidence in landfills and the siting process. But, we also
expect that the rule will promote increased local government focus
on source reduction and recycling.
RULES CLARIFICATION ON CESQG WASTE
And while we are on the subject of increasing source reduction
and recycling, I know that one of the major issues you were looking
to EPA for help on was to make sure our Hazardous Waste Regulations
didn't prevent you from using Household Hazardous Waste Collection
programs to collect Conditionally Exempt Small^Quantitiy Generator
Waste. We heard your concerns—loud and clear. So we went back,
looked carefully at the hazardous waste regulations, and we think
we have been able to address your concerns.
In July of this year, we sent a memorandum to our Waste
Management Division Directors across the country clarifying
hazardous waste regulations to allow state-approved household
hazardous waste collection programs to mix such waste with
conditionally exempt small quantity generator waste.
That memorandum makes it clear that state-approved Household
Hazardous Waste collection programs can accept Conditonally Exempt
Small Quantity Generator waste without becoming fully regulated
under the hazardous waste program. EPA believes this will bring
more Conditionally Exempt Small Quantity Generator waste into
Household Hazardous Waste Collection Programs—which in turn—will
increase the amount that is recycled or reused.
SOURCE REDUCTION AND RECYCLING GOOD FOR ECONOMY
But getting back to the big picture, source reduction and
recycling are good for the economy. They reduce costs of disposal,
substitute for new inputs of virgin materials, reduce energy costs,
provide revenues from the sale of recyclables, and give firms a
market and public image bonus. They also conserve valuable natural
resources.
MUNICIPAL SOLID WASTE CHALLENGE PROGRAM
In line with that spirit of conserving natural resources, I'm
pleased to take the opportunity afforded by this conference to
announce a major new initiative—a voluntary municipal solid waste
challenge program for businesses. The program will focus on on
high volume wastes such as office, packaging, and cafeteria wastes.
This program will be a first—bringing together for the first
time in one national challenge program—source reduction,
recycling, and procurement of recycled content and source-reduced
products.
Initially, we will target Service 500 companies such as
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banks, phone companies, retailers, and airlines. But in two to
five years, we would like to expand our audience to manufacturing
businesses, hospitals and other institutions, and state and local
governments.
We anticipate announcing the program officially and accepting
our first participants next Summer.
SOURCE REDUCTION AND RECYLING OF HOUSEHOLD HAZARDOUS WASTE
2£ We believe that this focus on source reduction and recycling
is the direction of the future in terms of household hazardous
waste as well. Starting with one day household hazardous waste
collection programs that focused primarily on safely collecting and
disposing of household hazardous waste in hazardous waste landfills
or other facilities, we are now moving to programs that try to
identify and implement innovative ways of handling household
hazardous waste and educate the public on source reduction.
SOURCE REDUCTION
Source reduction is EPA's top priority method of municipal
solid waste management. It means reducing the amount or toxicity
of materials or products—that is—preventing waste from being
created. We must turn to this as our ultimate means of waste
reduction because even a growing recycling rate has not prevented
the increase in waste generation.
TOXICS REDUCTION PROGRAM
The goal of EPA's Municipal Solid Waste Toxics Reduction
Program is to promote the voluntary reduction of hazardous
compounds in products by:
o providing information on the amounts and sources of these
compounds in MSW;
o facilitiating dialogue with industry on possible
reductions and alternatives to hazardous compounds, and
' o highlighting successful examples of toxicity reduction by
businesses and manufacturers.
EPA recently issued reports on sources of mercury in
municipal solid waste, and on technically feasible substitutes for
lead and cadmium in products.
We are now looking at what further compounds warrant attention
and have initially identified six volatile organic compounds for
further research. Our next step is to look at the sources of these
compounds and then develop educational tools and have discussions
with industry about the potential for voluntary reductions.
PUBLIC EDUCATION
EPA's toxic reduction program focuses on providing information
and incentives to people through education, outreach, and technical
research, rather than regulation.
EPA believes it is important to educate consumers on the
proper managment of wastes generated in the home. Knowledge about
household products can lead to improved storage, use, and disposal
of these products or the use of safer alternatives.
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POWER OF PUBLIC OPINION
The bottom line for waste and toxicity reduction—and that
includes safer alternatives for household hazardous waste—is
public opinion.
And, the power of consumer choice has just begun to stir. In
the long term, it has perhaps the most profound potential for
solving the problem of what to do with household hazardous waste.
Among the findings of a recent Roper Poll are that the
public's opinion of the seriousness of the solid waste issue in the
local community has risen by 16 percentage points in three years.
As to what the public view is of the relationship between the
environment and economic development — 92 percent believe we can
find a good balance between economic progress and the environment.
Also, the poll finds that environmentalism is still "in" in
1992 — ranking third after physical fitness and walking. And that
a "good description of American people" that ranks eight
descriptive qualities shows that the highest ranked descriptor at
56 percent is "concerned about the environment" while the lowest
ranked at 40 percent is "polite."
While they may-not be polite about it, Americans are finding
that, as consumers, their opinions count.
BUSINESS AND INDUSTRY'S ROLE
In the same poll run by Roper, 70 percent of those polled said
that business had a definite responsibility for environmental
protection. However, only 35 percent thought that they were
fulfilling it fully/fairly well.
Business and industry are discovering that they have an
important leadership role in identifying opportunities to reduce or
eliminate toxic components or unnessessary waste production in
their products. For both environmental and economic reasons,
source reduction approaches are being adopted by many
manufacturers.
THE FUTURE
The power of public opinion, the power of innovation and
acceptance of environmental leadership by industry are beginning to
combine as a potent force for change in the future. Someday,
perhaps there will no longer be a need for household hazardous
waste programs.
NEW PUBLICATIONS \
In the meantime, EPA plans to continue to provide -public
outreach and guidance for the safe handling of household hazardous
wastes. A "how to" guide for setting up a household hazardous
waste collection program has been developed and will be published
early in 1993.
This handbook will cover many aspects of implementing
household hazardous waste programs such as selecting wastes and
collection methods, managing collected wastes, publicizing the
program, estimating costs, and selecting a contractor.
Also, we recently issued a Revised Consumer Handbook that
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outlines many practical steps the consumer can take to reduce the
amount and toxicity of garbage.
Another handbook being developed by EPA concerns setting up
household battery collection programs. -. This publication is
designed to help communities determine whether establishing a
program to collect used dry cell batteries is1 right for them. It
is organized around -10 key issues related to setting up and running
a collection program.
Also available early next year will be a flyer on the proper
management and disposal of household hazardous waste. We hope
that making publications such as these available will be helpful to
those communities and citizens involved in the safe management•of
household hazardous waste. If you are interested in getting copies
of the publications I've mentioned today, I'm told that there are
sign up sheets being made available here at the conference to
ensure that you get copies.
GRANT TO STUDY PAINT RECYCLING
EPA has also recently funded a grant to study the recycling of
one of the largest volume materials received by collection programs
— paint.' Many collection programs try to recycle as much "waste"
as possible. More paint is accepted at household hazardous waste
collections than any other material, and 50 to 90 percent of that
paint is in good enough condition to be useable. It, therefore, is
a material with an excellent potential for reuse and recycling.
With that potential in mind, EPA has funded a grant to the
Waste Watch Center for the Paint Recycling and Reuse Project. It's
goal is to initiate activities throughout the country to identify
cost-effective, environmentally sensitive approaches to managing
leftover paints; to seek consensus on management options; and to
encourage the establishment of and participation in paint recycling.
and reuse programs.
USED OIL
Another large volume waste received by collection programs is
used oil. Few Americans realize the enormity of the motor oil
disposal problem in the United States. EPA estimates that do-it-
yourself auto mechanics annually dump about sixteen times more oil
into drains and sewers than was spilled by the Exxon Valdez.
EPA continues to support local efforts to collect and recycle
used oil through public education. We have produced pamphlets for
do-it-yourselfers and service stations, other publications explain
how to set up recycling programs for used oil, provide a regularly
updated State Used Oil Contact List for do-it-yourselfers to direct
them to local sources of information on collection centers, and
report on recent national activities in used oil recycling in the
form of periodic bulletins.
If you are interested in getting any of these publications
call the RCRA/SUPERFUND HOTLINE. (1-800-424-9346)
CONCLUSION
Source reduction and recycling are are leading us to solid
waste solutions that are long term rather than short term, they
are sound because they are based on the ultimate goal of
eliminating the problem rather than putting off it's solution.
They are taking us back to square one', and we are seeing it for the
first time.
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Design for Environment
Walter R.Stahel, The Product-Life Institute, Geneva, Switzerland
The Product-Life Institute in Geneva is primarily concerned with waste prevention, in all areas.
I shall try to show in the next 20 minutes that waste prevention, wherever it is feasible, is a better and
cheaper solution than waste management, and how you perhaps can foster waste prevention yourself.
What is Hazardous Household Waste? It could be anything in your household, from the
wristwatch you wear (with its battery) to the roses (from Columbia, full with herbicides) you buy for
your spouse on Christmas.
It is also just the tip of the iceberg: for each pound of product you buy, you created on
average 5 pounds of industrial waste, and 20 pound of mining waste. So think twice before you buy it!
These figures are a rule of the thumb, but have been confirmed in several case studies. For
example, a 1992 study by a German research institute analyzing the waste stream in the production of
the new S-cIass Mercedes, the "first recyclable car" in the world has found that two tons of recyclable
car are faced with 52 tons of industrial waste.
How can you avoid hazardous waste in the household and elsewhere? The main keys are
probably management determination and closed loops on the material and product level.
Waste prevention is first of all a problem of management decisions: Look at the example of
General Dynamics" Pomona division: From 10,840 tons of hazardous waste in 1984, to 238 tons in
1989, This development was triggered by the CEO stating that he wanted to go to zero waste in five
years, and that managers in future would be judged on waste prevention before anything else!
It can be shown that clean production technologies often lead to changes in technologies that
result in "cleaner products". You can therefore influence the amount of hazardous household waste to
some degree by choosing products from green companies in your purchases.
Secondly, in production processes waste prevention is linked to clean technologies used in
closed loops: using the example of waste-free paint processes, you could use powder coatings for e.g.
white goods (Miele Germany), or overspray recovery in wet spray painting (water in closed loop,
waste paint is recovered with ultrafiltration for re-use as paint; Unicolor AG, Switzerland).
The problem with most of these clean technologies is that they cannot be scaled down to the
needs of small businesses and households!
However, there are technologies that can profit small business and DIY, such as water-based
glues and varnishes for woodwork (Ebnoether AG, Switzerland). These products are not only better for
the environment, but also for you, as worker and resident of the space. Spray cans for hairspray cannot
be replaced in professional use by hand-pumps because the hairdresser would not have any fingers left
after the first day. Here a small ultrasonic hair lacquer applicator in the form of a handheld battery-
powered appliance can do miracles, again for the environment as well as for you health, as it uses no
CFC or other gas. It also uses less product than spray cans, so most lacquer ends up on the hair of the
client instead of in the nose of the hairdresser(Wella AG, Germany).
Dry cleaning fluids and other waste chemicals in small quantities are a typical problem for
many small companies. Mandatory take-back legislation has proved a very efficient approach for small
waste quantities in Germany, and I believe some U.S. Companies such as Safety-Kleen, Inc.,
headquartered near Chicago, is offering the same solution as a service to its clients. This shows that
industry in a free market environment can voluntarily implement good solutions without waiting for
legislation to be passed first, if management objectives are redirected toward environmental protection.
I shall jump packaging, as it is not a hazardous household waste problem. It is, however, an
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I
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! The 12 FactJ of Ecological Design
I The following list suggests source reduction and recycling opportunities for
industrial design and redesign.
!
i L Make it durable.
!2. Make it easy to repair.
3. Design it so it can be remanufactured.
4. Design it so it can be reused .
IS. Use recycled materials.
6. Use commonly recyclable materials.
7. Make it simple to separate the recyclable componmis o: 2 proouc: irorr.
the non-recyclabie components.
IS. Eliminate the toxic/probiematic componems'o:' a produa or mak; them
easy to replace or remove before disposal
9. Make products more energ\vresourc; efficient
10. Use product design to educate or. ;h; snvironm;m.
111. Work toward designing source reduction-inducing products u.;. products
that eliminate the need for subsequent waste |.
11. Adiust product design to reduce packaging.
^Measured Results
1 General Dynamics Pomona Division
Total Siaza
1985 1986 1987 1988
'igure 1: The re-use loop and the re-cycling loop
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g Figure
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RESOURCES^ BASE MATERIALS
.2
UTILIZATION
WASTE
£.- loop 1 :waste prevention, long-life products and product-life extension
loop 2 :waste reduction, recycling of materials
2 : The self-replenishing system of product re-use and recycling services.
manufoct or ing use
f —•"*- ^\
waste
basi c
material
production
v i rgin
resources
replenishing loops
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independence of the life-times of
inter-compatible systems, products
and components
(oop 1: re-use of goods
loop 2: repair* of goods
loop 3: reconditioning/rebuilding ot goods
loop 4: recycling of raw materials
Stahel, Walter and Reday, Genevifcve (1976/1980) Jobs for Tomorrow, the potential for substituting
manpower for energy, report to the Commission of the EC / Vantage Press, New York, N.Y..
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excellent example to show the efficiency of prevention approaches based on take-back legislation as is
the case in Germany.,The European Communities have introduced a similar take-back directive for
packaging that will soon become mandatory in most European countries.
Pollution prevention in utilization has many faces: long-life products such as the new Philips
induction lamp, an energy saving lamp that will last 60,000 hours (compared to 8,000 hours of a
regular energy lamp) illustrate the trade-off between waste volume and toxicity that sometimes has to
be made. Refutable cartridges for e.g. laser printers and photocopiers are not only a prevention of
toxic waste, but also economically very interesting once somebody has broken the taboo of doing it (to
the grief of the manufacturers that make most money selling consumables such as cartridges, not
products). Minimum use is another strategy, such as restricted towel changes in hotels (changing them
only every second day is now standard practice in Europe), or switching of computers in offices
outside office hours, which is the case for 5 out of every 6 hours over the year (EPA's energy star
program is helping in this respect, a lot).
Electronic appliances are found in increasing numbers in households and small businesses,
such as copiers and fax machines. Most of these appliances use disposable cartridges and technical
modules that are short lived, because they are the main cash-flows of the producer. Most of these
cartridges and modules can, however, easily be checked and refilled. In some cases, a key component
of the module also needs to be replaced by a long-life component. In Europe, the refilling business for
e.g. toner cartridges has today become so profitable that there are not only voluntary take-back systems
in place, but customers are offered cash up to $10 to give the spent module to one shop rather than
another.
Buying utilization instead of buying products is a strategy of delegating the hazardous waste
problem to an expert, i.e. the company that rents you e.g. the photocopier. Again it can be shown that
the renter will adapt by designing the machine in a way that the waste is greatly reduced, as
component change is now a cost factor, no longer a profit factor!
Buying utilization also works for e.g. motor oil. Some modem motor oil will safely run for
20,000 or 30,000 miles, so what you need from the oil company is a quality check every 5,000 miles,
not an oil change. Mobil Oil Germany is offering this service in Europe; I believe Safety Kleen in
Chicago is offering a similar service.
Product-life extension and recycling are primarily problems of demand, not supply. So buy
rebuilt products whenever you can, such as retreaded tires: they save 65% of the energy needed to
produce a new tire, save tire waste and are cheaper!
The same goes for materials. The recent take-back legislation for packaging in Germany,
managed by Dual System, has shown the gigantic quantities of materials mat flood the recycling
market and have nowhere to go! Try to buy goods made from recycled materials whenever you can in
order to help to close the material loop.
Clean repair technologies is the last example I would like to mention here: Lufthansa
developed a method "Aquastripping" that allows to strip the paint off an aircraft using a special
shower, which relies exclusively on water in a closed circuit. It saves 99% of waste, the only waste
being the old paint, no chemicals, no hazard for the people doing the work. And it saves Lufthansa
about 8-million DM a year. The same process could be adapted for stripping the paint off cars and
most other products. But, again, the technology may be too expensive for small businesses, except if
they share the equipment.
Retro-distribution, i.e. returning a hazardous waste through the distribution chain that delivered
it (shop, distributor, importer, manufacturer) may be the best approach to dispose safely of hazardous
waste. It certainly is the best strategy to make sure that the manufacturer is going to improve the
recyclability of the next generation of products, as he has to pay for the recycling or disposal of the
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company has ever dared to copy.
A three year total satisfaction
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It applies to ail pur machines
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And it means that if you're
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We believe it says a great deal .
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waste! It also leads to strategies of product-life extension, such as the rebuilding of products and the
re-use of components for purely economic reasons, which are also ecologically sane. In Switzerland,
we return Pharmaceuticals to drugstores that will sort them out in still usable medicine for the Red
Cross, and the rest for incineration. In Germany, batteries, motor oil, drycleaning chemicals, CFCs,
packaging, tires, all go back to any shop that sells them. In the future, many other products including
white goods, electronics and cars will also have to be returned to the shops rather than turned into the
municipal waste stream. The legal base for this is the German Waste Law of 1986, giving parliament
the power to pass acts for the take-back of individual product groups. It is interesting to note here that
the draft (1992) of the new German waste law is called: Law for an economy in cycles!
The underlying principles of all these examples can be summarized as follows:
start at the beginning: before investing in expensive recycling technology, do everything you
can to prevent the waste or to make it less toxic. In Switzerland, we have build, at great expense in
research time and investment, a plant to recycle batteries containing heavy metals, only to find that
industry in the meantime has found ways to make batteries without heavy metals which can be easily
be recycled in a different way. So we have a white elephant that enables the recycling, at high energy
and financial cost, of the batteries of the past. The plant can still be used to recycle the batteries in
landfills from the past, but it should serve as a lesson to all of you: do first everything you can
upstream before investing in end-of-pipe technology. Rechargeable batteries in small household
appliances now use a technology based on hydrogen, so the cadmium recycling could also be a short-
lived business. (Technically speaking: nickel metal hydride batteries as already used in large
appliances such as laptop computers. Their price today is almost the same as nickel-cadmium
batteries.) If companies do not follow this rule of always starting to tackle a waste problem at the
beginning, waste managers and recyclers may find themselves becoming an obstacle to progress in
order to safeguard their investments!
use products and processes based on renewable resources, such as water, wherever you can.
use the smallest possible loops (the least effort): long-life goods, re-use of goods and
components, repair, rebuild and upgrade goods wherever possible before recycling. Make products last
as long as you can and you prevent waste at the source and at the end.
close me product liability or product responsibility loop from cradle back to cradle! Bring your
old goods and your waste back to the shop that sold it to you. The shop will return it to the
manufacturers and they will learn how to improve them with regard to re-use or recycling. Buy
performance instead of goods, where feasible, by leasing or renting goods.
promote and buy products that follow ecological design principles: IDSA, the Industrial
Designer Society of America, has published 12 facts of ecological design, to promote source reduction
and recycling opportunities for industrial design and redesign, in the following order make it durable,
make it easy to repair, design it so it can be remanufactured, design it so it can be reused, use recycled
materials, make it simple to separate the recyclable components of a product from the non-recyclable
ones, eliminate the toxic/problematic components of a product or make them easy to replace or remove
before disposal, make products more energy/resource efficient, use product design to educate on the
environment, work toward designing source reduction-inducing products, adjust product design to
reduce packaging (see Innovation special 1992, IDSA).
Sustainability: once you have closed the waste loops, and eliminated toxicity from the
products, you can still improve the environment by aiming for higher resource efficiency:
sharing goods is one strategy that has a substantial waste prevention and resource saving
potential. Van and car pooling saves space on highways. Commercial washing machines in
laundromats use, per wash-cycle, 40 times less resources than household washing machines, in
production, maintenance and recycling (also less water, energy and detergents in washing), according
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to a study we have done for one of the German State governments. The optimal strategy in this case is
therefore designing and attractive "textile care center," or multifunctional service center which includes
the function of a laundromat, that has advantages over the washing machine at home. The snag is, of
course, that the companies which sell washing machines normally have no knowledge nor will to
design and operate attractive service centers! High volume photocopiers in shared use are more energy
and resource efficient per copy than small machines.
multifunctional products have a similar effect. Siemens AG in Germany presented a new
equipment this Summer that was heralded as the smallest FAX in the world. It is, however, not only a
fax machine, it is also a printer, scanner and copier. And it uses as much energy as a small light bulb
and does therefore not need a fan. It is also better for your health, as it does not use laser technology,
so there is no ozone, no toner dust. As it can do the job of four machines, it uses per page only 25%
of the resource input of a "normal" machine.
system solutions is the third strategy for higher resource efficiency. Most of these system
solutions are of technical nature, but here is a non-technical one: Lufthansa has greatly reduced the
waste on its domestic flights by substituting a generous hot and cold pre-flight buffet for its passengers
for in-flight food. You eat as much as you like, or nothing if you prefer, or three sweets and no salad,
using china plates, glasses and steel cutlery that can all be washed and re-used.
And a last advice: do not hesitate to be lazy! The EPA study on lawnmowers has clearly
shown that people who refuse to mow the lawn are not lazy, but environmentally conscious. And the
Swiss battery recycling case has shown that you should not invest in end-of-pipe technology before
everything has been done to solve the problem upstream, or you may be accused of mismanaging
funds, or you may even become an obstacle to progress in order to perpetuate your "resources", i.e..
hazardous waste. It is sometimes better to delegate a problem and let the person deal with it who
created the problem in the first place: take-back legislation will great encourage manufacturers of
products that end up as hazardous waste to reconsider the economics of disposal v. product redesign!
And remember If waste can be prevented, it will be a better and in the long run cheaper
solution than waste management. So make sure you are among the best in order to give your company
or state a competitive advantage in the future.
laiifr
environmentally
conscious/,. 7
BIT MMC LUCMMCH FOB THC ATUMTA CONSTITUnOM
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A DIFFERENT VIEWPOINT
CLEANING DP THE WASTE STREAM
Michael Winka, Executive Assistant
New Jersey Department of Environmental Protection and Energy
Division of Solid Waste Management
CN-414
Trenton, New Jersey 08625-0414
I would like to present a different view point for the need
for implementing household hazardous waste (HHW) and small
quantity generator (SQG) waste programs. Most HHW programs are
implemented with the goal of minimizing future CERCLA*
liability. This is a noble cause and HHW programs go a long
way to controlling and minimizing future CERCLA liability.
However, State and local government programs can not implement
this goal alone. To truly minimize future CERCLA liability
requires a concerted effort by the federal government and
industry to focus on source reduction. This federal/industry
action is currently ongoing. It is sometimes stimulated by
State legislative actions such as the battery bill to reduce
the mercury content in batteries and the toxic package
reduction act to reduce cadmium, chromium, mercury and lead in
packaging that are currently in place in a number of different
States; and Minnesota's Mercury Reduction Act.1'2'3 However,
source reduction efforts require time to implement, time for
industry to retool in a cost efficient manner. In the interim
and to manage those discarded consumer products that can not be
further source reduced requires the implementation of a HHW
program.
New Jersey's HHW program goals are the implementation of a
statewide program to "clean-up" the solid waste stream in order
to maximize its reuse. This reuse includes energy recovery,
materials recovery but more importantly producing compost from
the solid waste. New Jersey defines its HHW program beyond
simply managing discarded consumer products that are defined as
HHW or SQG waste. It includes that small volume of solid waste
that could negatively impact our ability to reuse the solid
waste. New Jersey's program includes HHW, SQG waste and other
discarded products that, while not meeting the definition of
hazardous waste, impart a negative quality to the solid waste.
This negative quality prohibits -us, in some cases, from reusing
the solid waste as fuel or compost or maximizing our markets
*Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) of 1980 as amended. This Act provides
for liability, compensation, clean-up and emergency response
for hazardous substances released into the environment and the
clean-up of inactive hazardous waste disposal sites.
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-ft •*-•»?«• >-•
for these solid waste derived products. It should be pointed
out that it is not any one individual product or manufacturer
that causes this problem, but the sum total of their small
individual product contributions. Adding up these small
individual product contributions prevents the full reuse of the
solid waste stream for fuel or compost. It renders the solid
waste solely to the status of garbage, fit for nothing but
landfilling.
If landfilling were the only available disposal option,
given the current design, construction and operational
requirements for today's landfill; the need for a HHW program
would.be less. However, in order to fully implement the
mandated requirements of the Resource Conservation and Recovery
Act (RCRA), a small quantity of discarded consumer products
which contain hazardous substances that could negatively impact
on the quality of the solid waste for reuse, have to be
eliminated or managed separately. The overall goal of the
solid waste program is to work with industries to develop
source reduction initiatives, particularly toxic use reduction
programs, for the discarded consumer products that they
manufacture. However, in the interim and for those consumer
products which have a technology limit to further source
reduction, we need to develop a source separation system to
manage those products apart from the solid waste disposal
stream. The HHW program is an integral part of those source
separation systems.
This paper will discuss one heavy metal, mercury in the
solid waste stream, through the development of and the findings
and recommendations of the New Jersey Mercury Emissions Task
Force. In addition, some of the cost implementations of the
Task Force recommendations and an alternate solution to manage
discarded consumer products through the HHW Program are
discussed.
It should be noted that the Nev Jersey Mercury Emissions
Task Force Report is a New Jersey Department of Environmental
Protection and Energy policy document-., it would be
inappropriate to view it, at this stage, as the basis for
specific regulations or facility permit modifications which may
be required to implement the recommendations and goals of the
Report.
On September 19, 1991, camden County Board of Chosen
Freeholders, pursuant to the County Environmental Health Act,
N.J.S.A. 26:3A2-21 et seq., adopted a resolution proposing a
mercury emission standard of .025 pounds per hour for each
source of mercury within the county.* This resolution was
*The County Environmental Health Act is a program that
delegates certain environmental programs and enforcement
activities to New Jersey's counties.
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reviewed by the Commissioner of the New Jersey Department of
Environmental Protection and on December 10, 1991, the
Commissioner issued an. Order which disapproved the resolution
of the Camden County Freeholders. As set forth in Figure l,
the disapproval of this resolution was based primarily on the
following reasons:
1. Insufficient technical and scientific analysis to
support the proposed mercury standard;
2. Conflict with the Camden County Solid Waste
Management Plan, since the proposed date of
December 16, 1991 for implementation of the
proposed standard would have necessitated the
immediate shutdown of the South Camden Resource
Recovery Facility without demonstrated risk to
public health; and
3. Inconsistencies with Section 27 of the County .
Environmental Health Act and the approved
interagency agreement between the DEPE and Camden
County Department of Health on the issue of
delegated authority. The interagency agreement
did not delegate authority to the Camden County
Department of Health to regulate the control of
air pollution through standard setting
procedures.
In the December 10th Order, the Commissioner acknowledged
the importance of addressing the issue of setting a mercury
emission standard and deemed it appropriate for the Department
to begin the process of developing a statewide standard. In
particular, the Order addressed the need for reducing mercury
emissions from MSW incinerators through the implementation of a
battery separation program and the installation of air
pollution control equipment. The Order mandated the Department
to provide an active public participation process to assist in
the development of the statewide standard. The Task Force was
set up with two groups. The health and environmental issues
section and a technical and regulatory issues section. I will
first describe the technical and regulatory issues followed by
the environmental and health issues. All data summarized and
presented in this paper, are described and referenced in detail
in the New Jersey Mercury Emission Task Force Report.4
Figure 2 represents the anthroprogenic mercury emission
sources in New Jersey. The figure presents both the high and
low estimate and the medium or weighed average, where
sufficient data is available. As can be seen from the figure,
the highest source of mercury emissions are from MSW
incinerators. This is followed by fuel oil use for commercial,
residential, transportation, utility and industrial uses,
sludge incinerators and coal utility power plants. This
distribution of anthroprogenic sources is particular to New
Jersey based on the amount of municipal solid waste that we
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incinerate within the State and the use of fuel oil and coal by
utility power plants for electrical generation. The
distribution of sources will be different for other State's
depending on their MSW combustion, fuel use and coal use for
electrical generation. On an international level the mercury
emissions from coal burning power plants is actually the
largest anthroprogenic source of mercury to the atmosphere.
After identifying the various anthroprogenic sources of
mercury emissions, the technical subcommittee then concentrated
on the individual sources to understand where the mercury was
coming from for those individual sources. In the solid waste
stream, the mercury in municipal solid waste and the
bulky/industrial solid waste streams were evaluated.
To determine the mercury in the municipal solid waste, the
data developed by Franklin Associates in their USEPA report
Characterization of Products Containing Mercury and Municipal
Solid Waste in the United States 1970 to 20QO (USEPA Mercury
Report)was used.9As can be seen from Equation 1 in Figure 3,
the amount of mercury in the New Jersey MSW stream is a direct
apportionment of the quantity of mercury determined by the
USEPA Mercury Report for the U.S. MSW stream. Knowing the
mercury content in the New Jersey MSW stream, we can calculate
the amount of mercury in the other waste stream, the
bulky/industrial waste stream in New Jersey.
This was done by first determining the average lifetime of
an average discarded consumer product. The average lifetime of
a product is the time between when it is manufactured,
purchased, used and then disposed. The average lifetime was
calculated using the data presented in the USEPA Mercury
Report. This was accomplished by summing up the average
lifetime of the individual discarded consumer products
multiplied by the percent mercury that each individual product
contributes to the total municipal solid waste stream. As can
be seen in Equation 2 of Figure 3, the average lifetime of
discarded consumer products is 4 years. This means the mercury
content in today's MSW was generated from a consumptive use of
mercury 4 years ago or the mercury content in the 1992 MSW
stream was generated by a 1988 mercury consumptive use. Using
this information, the quality of mercury in the
bulky/industrial waste stream can be estimated.
To determine the quality of mercury in the bulky/industrial
waste stream, the mercury content in municipal solid waste in
year 4 was subtracted from the total consumptive use of mercury
in year 0. The total consumptive use of mercury was obtained
from the U.S. Bureau of Mines data on mercury use. The
remaining quantity of mercury in year 0 was then corrected to
account for mercury containing products that are managed as
hazardous waste and then apportioned to the New Jersey
bulky/industrial waste stream.
15
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As can be seen from Figure 3, the mercury in the municipal
solid waste stream in New Jersey is equal to 0.0048 pounds per
ton and the mercury in the bulky/industrial waste stream is
equal to 0.0089 pounds per ton. It was determined, by
evaluating the through-put data of the four operational
district MSW incinerators in New Jersey, that the RRFs process
on average 95% municipal solid waste and 5% bulky/industrial
solid waste. By using the calculated quantities of mercury on
a pound per ton basis and the distribution of the different
waste types, the mercury in the processible solid waste stream
in New Jersey resource recovery facilities was determined to be
equal to 0.005 pounds per ton.*
As can be seen from Figures 4 and 5, in the 1992 disposal
stream, prior to the effects of the New Jersey Dry Cell Battery
Management Act, mercury from batteries represented the single
largest source of mercury in the solid waste stream. This is
followed by the quantity of mercury from fluorescent lights,
fever thermometers and mercury switches. Figure 4 was
generated by apportioning the data from the USEPA Mercury
Report to the New Jersey municipal waste stream. It should be
noted that the USEPA Mercury Report represents an average
quantity on a national level. Each individual State, while
similar to that distribution, will have individual differences
in the municipal waste stream. One particular note, in most
coastal States, the number of mercury switches will be higher
than the national average.6 The USEPA Mercury Report does not
consider all sources of mercury switches other than mercury
light switches (and thermostats). There is a considerable
amount of mercury that will be generated by the disposal of the
total quantity of mercury switches in the waste stream. In
addition, it is this discarded consumer product that may result
in the spiking of mercury concentrations in stack test data in
mass burn RRFs.
From the quantity of mercury in the processible waste
stream, the potential flue gas concentrations of mercury can be
calculated. This would represent the uncontrolled emissions of
mercury within the flue gas stream in resource recovery
facilities. As can be seen from Figure 6 there is good but not
exact correlation between the calculated uncontrolled emissions
and the actual uncontrolled emissions determined through stack
testing of the resource recovery facilities. It should be
noted that the stack test data is from 1991-1992 data and must
be correct to a 1992 timeframe. The difference between the
calculated potential flue gas concentration and the actual
measured uncontrolled emissions is a result of the
*This paper uses the terms MSW incinerator and resource
recovery facilities interchangeable. A resource recovery can
be a materials recovery (including compost) facility or an
energy recovery facility. The four New Jersey MSW incinerators
also recovery energy from the combustion of the solid waste
used as a fuel.
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differences between New Jersey's particular mercury content in
the waste stream and the mercury content of the average
national solid waste stream. As can be seen from the potential
flue gas concentration and the actual stack test data, the
current New Jersey resource recovery facilities operate with a
degree of mercury control within their current air quality
control system.
Another aspect of the analysis the waste stream is to
evaluate the current source reduction programs that are being
implemented in New Jersey. As a result of the New Jersey's Dry
Cell Battery Management Act N.J.S.A. 13:lE-99.59 et seq. and
the Toxic Packaging Reduction Act N.J.S.A. 13:lE-99.44 et seq..
mercury content in the municipal solid waste will be reduced
over the next several years.
Figures 7 and 8 represents the estimated reduction in the
mercury content in the municipal solid waste stream over the
next three years as a result of the Battery Act and the Toxic
Packaging Reduction Act. These figures were calculated using
the data in the USEPA Mercury Report by transposing the effects
of industry source reduction in place in New Jersey. As can be
seen by Figures 7 and 8, the mercury in the New Jersey
municipal solid waste stream will be reduced by 60 to 75% over
the next three years. The most dramatic reduction in the
mercury content in the solid waste stream will be from the
reduction of mercury in alkaline batteries. The overall
reduction in mercury in the municipal solid waste stream, as a
result of the New Jersey Dry Cell Battery Management Act will
be over 80%.
The New Jersey Dry Cell Battery Management Act, N.J.S.A.
13:lE-99.59 et seq. requires that the mercury content of
batteries be less than or equal to 250 parts per million as of
January 1, 1992. Given that the average life of the battery is
two to three years, we are now starting to see the affects of
that reduced level of mercury in alkaline batteries in the
municipal waste stream.* In addition, because of the 250 ppm
limit on batteries, consumer mercury oxide batteries are
prohibited from sale in the State of New Jersey. Institutional
mercury oxide batteries are permitted to be sold in the State
of New Jersey•provided the battery manufacturer submits and
receives approval from the New Jersey Department of
Environmental Protection and Energy for a Battery Management
Plan. The Battery Manufacturers Plan must designate their
collection, transportation, processing and management system
*The USEPA Mercury Report estimated a three year life for
batteries from production to disposal. One year between
production and use and two years between use and disposal. The
battery manufacturers estimated a two year life. One year
between production and use and one year between use and
disposal.
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for the mercury oxide batteries. The battery manufacturers
would be liable for the:cost of the overall system.
•»'
Two actions will be taken by the battery manufacturers that
will result in additional mercury reduction over, that required
by the Dry Cell Battery Management Act as follows:
1. The alkaline battery manufacturers had committed
to reducing the mercury content in alkaline
batteries to 1 ppm by the end of 1993. This will
reduce to almost zero (0.01 tons by the end of
1995 for New Jersey), the mercury content in the
municipal solid waste stream from alkaline and
carbon zinc batteries.
2. The institutional mercury oxide battery
manufacturers have decided not to submit a
management plan in the State of New Jersey. They
have opted rather not to sell their products in
. -. the State of New Jersey. However, these
batteries will still be available for sale in
other States.
As can be seen by Figures 7 and 8, the above two actions
will result in the reduction of the mercury content from
batteries to essentially zero. These actions will result in
fluorescent lamps and switches being the number one source of
mercury in the municipal solid waste stream. The mercury
content in these consumer products cannot be reduced at the
source beyond a technological limit, otherwise they would no
longer properly or efficiently operate. We as a society have
made a decision that we need these products. Therefore, if we
need to reduce the mercury content in solid waste it may be
necessary to establish a Battery Act program for fluorescent
bulbs, switches and other mercury containing products which
source separates them from the solid waste disposal stream.
Figure 9 translates the numbers in terms of reduction
resulting from the Dry Cell Battery Management Act and the
Toxic Packaging Reduction Act and calculates the potential flue
gas concentration in the New Jersey RRFs over the next three
years. As can be seen by Figure 9, there is a significant
reduction in the mercury content and flue gas concentration
from resource recovery facilities.
t
Another method of calculating the mercury in the solid
waste stream is to perform a mercury balance between the
mercury in emissions and the total mercury in residual ash in
the MSW incinerators. Figure 10 presents a mercury balance for
the Camden and Warren County resource recovery facilities.
Table 1 of Figure 10 presents the minimum, maximum and average
concentrations of the total mercury in parts per million
(mg/kg)and pounds per ton. The average mercury content from
stack test data from both the Warren County and Camden County
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resource recovery facilities in pounds per ton is added to the
average residual ash total mercury concentration. As can be
seen in this particular mercury balance, the total mercury of
.the Caaden County RRF is 0.0098 pounds per ton and of the
Warren County RRF is 0.00308 pounds per ton. These numbers do
not agree with the materials flow balance calculation of
mercury in the processible waste stream of 0.005 pounds per ton
calculated from the data in the USEPA Mercury Report. As with
the stack test data, the residual ash data is from 1990 through
1992and needs to be corrected to a 1992 timeframe for an
equivalent analysis.
The total mercury content in the residual ash for both the
Camden County and Warren County Facilities are from data
reported by the facilities as part of their residual ash
testing program. The New Jersey Department of Environmental
Protection and Energy (NJDEPE) is performing a research project
utilizing Warren County's resource recovery residual ash. As a
part of our research, we determined the total mercury content
of the residual ash two orders a magnitude higher than that
reported by the Warren County resource recovery facility. The
data for the New Jersey ash research project was generated by
the Department's Division of Environmental Quality Laboratories
and quality controlled by the State University of New York at
Stonybrook's Environmental Laboratory. The Department's data
indicates that the total mercury content in the Warren County
resource recovery residual ash is 4 ppm. From the results of
the research project we"have determined that sample preparation
and the type of mineral acid used in the "total" leaching test
has an impact on the test's results. When you add the 4 ppm
total mercury content in the residual ash to the average stack
testing data for the Warren County resource recovery facility
you get agreement with the Camden County resource recovery
total mercury content.
The difference between the mercury content calculated by
the mass balance method and the mercury content calculated by
the materials flow method may be the differential between New
Jersey's particular waste stream content for mercury and the
average national content or a longer lag time between
production, use and disposal. One of the products that adds to
this differential in the New Jersey waste stream is mercury
switches. New Jersey, as well as a number of other coastal
states have a large population of pleasure boats. Each one of
these pleasure boats has a bilge pump and those bilge pumps are
operated by mercury switches. The average maintenance time on
the mercury switches is on the order of one to two years. This
factor increases the number of mercury switches that will be
found in the New Jersey and any other coastal states municipal
solid waste stream. This possible explanation was developed by
the Florida Department of Environmental Regulations in their
Mercury Report and by discussions with New Jersey mercury
switch manufacturers.6
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The other component -of the Mercury Emissions Task Force was
to evaluate the health and environmental issues. The work of
this subcommitte was divided in three steps were:
1. To review existing information in the scientific
literature to determine the scope of the
potential problem and to identify ways to focus
the risk assessment;
2. To establish a level of risk above which exposure
to mercury should be limited; and
3. To evaluate and develop fate and transport models
which could be used to estimate the mercury
exposure that may result from the emission of
mercury from a stationary source.
The health and environment subcommittee undertook an
extensive review of the literature concerning mercury in the
environment, particularly focusing on background levels, health
effects data and exposure assessment models. This review leads
to the conclusion that global mercury emissions, deposition and
bioaccumulation are important aspects of the overall mercury
problem. Ambient air concentrations of mercury in remote
locations appear to be increasing. Nationwide data suggest
that existing levels of mercury in tuna, swordfish, shark and
other fish may lead to human ingestion of mercury in excess of
safe levels for a small segment of the population. Although
the existing literature was reviewed extensively and discussed
within the subcommittee, there remains a substantial amount of
uncertainty regarding the level of global mercury
contamination, its effect on the residents of New Jersey and
the contribution of New Jersey sources to this contamination.
Additional data currently being developed are needed to explore
this issue more thoroughly.
The toxicological assessment began with an evaluation of
limits and standards established by the U.S. Environmental
Protection Agency (EPA). A Reference Concentration (RfC),
which is designed to protect against adverse health effects
from inhalation of elemental mercury, has been established by
the EPA at 0.3 micrograms of mercury per cubic meter of air
(ug/m3). A Reference Dose (RfD), which is designed to protect
against adverse health effects from ingestion of methylmercury,
was previously established by the EPA at 0.3 micrograms of
mercury per kilogram of weight per day (ug/kg/day); this RfD,
however, has recently been withdrawn by the EPA for
re-evaluation.
The subcommittee reviewed the EPA RfD, as well as
toxicological literature, in considering a daily level of
intake of methylmercury which would be sufficiently protective
of the human health of the most sensitive portion of the New
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Jersey population. Based upon an analysis of the toxicological
literature of health effects in children associated with in
utero exposure to mercury ingested by expectant mothers, and
computer modeling of current background exposure, a proposed
Acceptable Daily Intake (ADI) of 0.07 ug/kg/day has been
developed by NJDEPE health and environment subcommittee, it
should be noted that the Agency for Toxic Substances and
Disease Registry (ATSDR) of the U.S. Department of Health and
Human Services has proposed a minimal risk level (MRL) of
methylmercury of 0.04 ug/kg/day. This was also based on an
analysis of in utero neurological^development; this proposal
postdated the analysis which led to the proposed New Jersey ADI
of 0.07 ug/kg/day.
A variety of fate and transport models were reviewed.
Mercury exposure through inhalation predicted with all of these
models indicates a large margin of safety between predicted
exposure and the current EPA Reference Concentration of 0.3
ug/m3. A generic model was developed by the NJDEPE health and
environment subcommittee and presented in Volume II of the
preliminary report. This generic model, which addresses
deposition to soil and water and bioaccumulation in fish,
employs restrictive assumptions and suggests that the potential
exists for increase in human ingestion of methylmercury.
Site-specific modeling, however, generally predicts lower
levels of exposure to mercury than the generic modeling
method. This is to be expected, since more realistic
assumptions can be used when the site is known. Therefore,
where available, site-specific data are preferable for review
of the impacts of a specific source. The task force decided to
start with MSW incinerators because they are a major new source
of mercury emissions in New Jersey.
The recommendations of the health and environmental
subcommittee were as follows:
1. The ADI of 0.07 ug/kg/day derived in this report should be
considered as the health basis for the establishment of a
mercury emissions standard. This ADI is preliminary,
pending completion of the peer review reports and an
analysis of those reports by the NJDEPE.
2. A review of the derivation of the ADI is underway by a
panel of external reviewers, which includes experts in the
fields of toxicology and risk assessment from academic and
medical institutions and government agencies.
3. By the year 2000, mercury emissions from MSW incinerators
should be reduced by greater than 95% of current levels,
through a combination of waste management practices and
emission controls.
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4. The DEPE should review national studies that have been
mandated by section;112(n)1 of the Clean Air Act Amendments
when they become available, and consider how their
conclusions should be incorporated into the New Jersey
program. This mandate requires EPA to perform studies on
mercury emissions from various sources, such as electric
utilities and MSW combustors. A report on these studies is
due to Congress in November 1994.
5. The NJDEPE should work with environmental agencies at the
federal and regional levels to explore global contamination
issues and encourage mercury reductions on a global,
national and regional level. In addition, the contribution
of New Jersey mercury emissions to mercury levels in
saltwater fish should be investigated.
6. Additional source categories, such as fuel combustion
plants, auto emissions, land application of sludge, sewage
sludge digesters and leaching and gas venting of mercury
from landfills, should be considered for modeling and
possible emission reduction.
In addition to the above recommendations and goals, the
following research activities should be developed or expanded
to provide a better understanding of the nature of actual and
potential mercury exposure in New Jersey:
* A workshop on mercury modeling techniques and model
inputs should be held to identify improvements that can be
made in the mercury model algorithms and assumptions
contained in the DEPE generic model.
* Stack test data should be collected to identify the
form of mercury that is emitted from MSW facilities
including landfills and its behavior in the atmosphere.
* Mercury concentration data for fish in New Jersey need
to be developed. A pilot project for freshwater fish has
just started. Following the pilot study, the DEPE should
implement a routine fish monitoring program. Data on
mercury concentration in water and sediments should also be
collected.
* An analysis of fish consumption patterns in New
Jersey, particularly consumption of fish caught locally,
should be performed.
* Research should be undertaken to define more precisely
a mercury RfD for the in utero developmental neurological
endpoint.
* The potential additive toxicity of inorganic and
organic mercury exposures should be further investigated.
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* Other exposure pathways (e.g. vegetable ingestion,
drinking water) should be evaluated.
* The DEPE should explore the relative contribution of
in-state vs. out-of-state sources with respect to New
Jersey exposures to mercury.
* Ecological impacts have not been adequately
investigated/ largely due to lack of predictive data.
Additional information on ecological effects is needed.
The task force recommends a two-phase standard for the
reduction of mercury emissions from municipal solid waste
incinerators:
1. By December 31, 1995, a mercury emissions standard of
65 ug/dscm should be achieved for all MSW incinerators
operating in New Jersey.
2. By January 1, 2000, a mercury emissions standard of 28
ug/dscm should be achieved for all MSW incinerators
operating in New Jersey.
Implementing the Standard
These standards can .be achieved by implementing the
following actions:
* Operators of MSW incinerators should install air
pollution control devices that reduce mercury
emissions.
* The NJDEPE should require counties to modify their
solid waste management plans .to include separation of
mercury-containing objects from the waste stream — at
a minimum, by January 1994, this should include
batteries and by January 1995, fluorescent light bulbs
— for each county that sends its solid waste to
incinerators.
* Operators of MSW incinerators should improve waste
management practices at their facilities to screen
incoming waste for bulk quantities of wastes that are
known to or which the operator suspects to contain
mercury and thereby prevent large amounts of these
waste materials from being incinerated.
* The NJDEPE should ensure that the manufacturers of
batteries comply with the requirements of the "Dry
Cell Battery Management Act." The requirements of
this act, and the proposed mercury reduction plans by
battery manufacturers, can result in a 70% to 80%
reduction of mercury in New Jersey's solid waste
stream by 1995.
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* The NJDEPE should ensure that the manufacturers of
packaging comply with the requirements of the "Toxic
Packaging Reduction Act."
* The state should take actions that will result in
further reduction, recycling and separation of waste
materials containing mercury. These management
options should be implemented by working with the
product manufacturers and, where necessary, developing
regulations or promoting legislation to ensure that
proper management practices occur. At a minimum, by
January 1995, the state should develop and implement a
program for the separation of fluorescent light bulbs
from all waste streams sent to incinerators.
If the Task Force recommendations for mercury limits for
MSW incinerators are to be implemented a 95 percent or greater
reduction in 1991/1992 mercury flue gas concentration is
needed. This reduction cannot be implemented with any one
individual strategy. Some air quality control technologies
have been measured in the 90+ percent range. However, that
reduction depends on a number of factors mainly the initial
flue gas concentration and will guarantee an 80 percent
reduction to a specific limit. Other control technologies
while highly efficient are either costly to install and/or
operate. Source reduction will achieve 'greater than 80 percent
reduction. However, that reduction will take time to fully
realize in the solid waste stream. Air quality control
technology and source reduction strategies cannot achieve the
necessary reduction in a timely and cost effective manner.
Only a concerted effort that includes source separation
programs for mercury containing discarded products can achieve
the recommended limits. The most effective source separation
efforts are through the permanent HHW programs.
While the focus of the Task Force was to establish mercury
emission standards, as can be seen by Figure 13 cadmium and
lead are under going the same level of review to establish
clean-up levels in soils and end-use compost standards. New
Jersey has currently proposed soil standards for all metals and
organics through its site remediation program. These soil
standards for residential use will be lower then the current
action levels implemented by the NJDEPE for guidance in
clean-ups. In addition, the Department is evaluating compost
standards for sewage sludge compost. Figure 13 delineates the
Class A and Class B standards for cadmium and lead. While the
standards are still in draft form, they are considerably lower
than the current standards for cadmium and lead.
Figures 14 and 15 present a very general economic
evaluation of the cost of source reduction and source
separation of heavy metals containing products versus the
addition of air quality control technology on the backend of
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the resource recovery facility. Figure 14 calculates the
number of pounds of batteries in each of the counties. It also
presents the cost for managing those batteries in a commingled
fashion. This cost includes the cost of collection, processing,
the commingled batteries and than processing the separate
battery chemistries. This cost does not include the cost of
shipment to the processing facility. The NJDEPE was quoted a
price by a battery processor including all those costs of $1.25
per pound. In addition to this cost, there would be an FOB
charge to the processing facilities which are located in
different areas of the U.S.
Figure 14 represents the cost to the four resource recovery
counties at $3.9 million. It also estimates the statewide cost
to process the total quantity of batteries in the State at
$10.9 million. Given that there are approximately 108 million
batteries used and disposed of in New Jersey, the cost for
collection and processing batteries would result in
approximately a $0.10 per cell additional cost plus a shipment
cost.
Figure 15 represents the approximate cost for air quality
control technologies for mercury, cadmium, lead and additional
residual ash testing as an added cost per ton of waste
processed. The majority of the cost is the cost of mercury
control which would result from the add on of new air quality
control technology and its additional 0 & M cost. The cost of
cadmium and lead control are estimated from existing air
quality control technology.
As can be seen by Figure 15 the total cost for air quality
control technology for mercury, cadmium'and lead and residual
ash testing is approximately $5.6 million. It should be noted
that the addition of mercury, cadmium and lead in the solid
waste stream is not solely the result of batteries. The cost
of air quality control technology should be evenly distributed
over all heavy metal-containing products. To be a more
appropriate analysis the cost of air quality control technology
should be apportioned to the various sources of mercury in the
solid waste stream. In addition the cost of disposal of the
ash containing heavy metals, the treatment and disposal of the
leachate from ash landfills and the sludge it produces should
be included in the economic analysis. Further, the add on
mercury control technology will control more than just mercury
in the flue gas stream. ••. -
To put'this on a consumer level, New Jersey generates
approximately 15 million tons of solid waste per year. This is
equivalent to approximately 1.8 tons per person per year. New
Jersey residents recycle approximately 5,0% of their waste,
which leaves approximately 0.9 tons per person for disposal.
It costs $4.25 per ton to manage mercury, cadmium and lead
through the air quality control system in resource recovery
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facilities. That results in a-cost of approximately $3.83 per
person per year to manage those metals on the back-end of a
facility. New Jersey residents use, on average, approximately
13 batteries per person per year or approximately 1 pound of
batteries per person per year. At a cost of $0.10 per battery
to manage them in the front-end through source separation would
result in a cost of $1.30 per person per year or a cost
differential of approximately $2.53 per person per year.
While the above evaluation is a very rough back of the
envelope estimate of the costs, it is clear that their will be
a cost to managing discarded consumer products that contain
heavy metals. The decision that must be made is at what point
do we want to incur that cost and what is the most efficient
system to manage those costs. It is clear that managing
materials in the front end are less costly then to try to
control them through the facility in the back-end.
While the above impacts were evaluated for mercury within
massburn RRFs or MSW incinerators there will be similar health
and environmental issue when other heavy metal containing
products are evaluated in terms of their impact on solid waste
reuse. A good starting point is the USEPA report
Characterization of ProductsContainingLeadand Cadmium in
Municipal Solid waste in the United States. 1970 to 2000f
prepared by Franklin Associates Ltd., dated 1989. The issues
of heavy metal containing products that are eventually
discarded into the solid waste stream are even more critical
when the solid waste, including sludge, is to be composted.
Unlike MSW incinerators which could be modified to retrofit for
additional air quality control equipment, once the heavy metals
are in the end use compost there is virtually no cost-effective
technology to remove them. Given the above impacts, the
potential costs and the mandated goals to reuse solid waste,
HHW programs can serve to efficiently and in a cost-effective
manner manage those discarded consumer products in the solid
waste stream that impart a negative quality to the solid waste
and impede our ability to fully reuse the waste.
To implement this program requires everybody's help. It is
a new way of doing business in environmental management, it is
evident that to leave these products in the waste stream
results in a problem. It restricts our ability to fully reuse
the solid waste. This problem is not the result of any one
individual product or any one individual product manufacturer
but, the collective and cumulative impact of heavy metals in
discarded consumer products. The quantities of which can be an
order of magnitude above residual background concentrations.
This problem is magnified because of the volume reduction
function of the end use technologies for the reuse of solid
waste. This volume reduction serves to increase that
concentration of heavy metals through the process.
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•••,- »!.-<••« ,..:tr?(*,?';<'.
- fa. •>•< •
We, industry and the regulatory community need to work
together to resolve this problem. We as regulators of the.
management of solid waste have to better communicate the
problem and not develop overly perscriptive regulatory
programs. It is also evident that to maintain a clean
environment and to resolve this problem1 we need to maintain a
strong US manufacturing base. We do not'need to simply develop
regulatory programs that result in putting business out of
business. From the product manufacturers side we need to
understand the technology, the product, how a product is
developed and finally how a product is distributed. With that
full understanding, we can assist each other in putting
together a system that is not overly perscriptive and is
implemented in the most cost-effective manner. HHW facilities
can serve as that system. Those heavy metal-containing
products which cannot be further source reduced can most
effectively utilize the HHW program.
Source reduction and HHW source separation programs are a
new way of doing business in environmental management. As with
any new program or new discovery, there is an initial inertia
against implementation of that program. Inertia is a very big
force in this universe, a body at rest tends to stay at rest.
There is a cry to maintain the status quo of how we do business
or a cry against a new discovery. However, it is time to move
into the full implementation of source reduction and permanent
HHW facility to manage source separated discarded products.
Moving the management of solid waste up front to a materials
management issue is the most cost effective way of managing the
materials before they become solid waste. In addition, it
allows us to implement the goals of the Resource Conservation
and Recovery Act to fully reuse that solid waste as a fuel or a
compost material.
In my assessment source reduction coupled with a permanent
HHW program are equivalent to Christopher Columbus' discovery
of the new world. However, as opposed to Christopher Columbus'
discovery which expanded the world, source reduction and HHW
source separation programs will actually result in a decrease
in the regulatory world. Prior to Christopher Columbus'
discovery Spain's motto was "Ne Plus Ultra" or there is no more
beyond. Spain was proud of the fact that they were on the edge
of the world. It gave them a specific place in the world.
When Christopher Columbus came back to Spain, it changed that
position. Spain could have maintained the status quo, ignored
Columbus' discovery given in to the inertia against this
discovery and kept its place in the world with its motto.
However, Spain accepted this new discovery and its new position
in the world. It seized the opportunities that the discovery
presented by a minor change in their philosophy and motto by
simply dropping the "Ne" in their motto. Their motto to this
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day reads "Plus Ultra", there is much more beyond. All
industry and private enterprise need to do is adopt a very
simply philosophy change to include materials management of the
products they manufacture from production through disposal.
Private enterprise is always asking for government to get
out of the way. This is one program that we can deliver that
we are asking private enterprise to come in, step in and take
the lead. For those flat worlders who do not believe in source
reduction and HHW source separation programs all we ask is that
you overcome your inertia and seize the opportunities that will
make themselves available from source reduction and HHW source
separation programs.
ACKNOWLEDGEMENT
The findings and recommendations of the NJDEPE Task Force
on Mercury Emission Standard Setting are the collective work of
all the Task Force member including both the public members and
NJDEPE staff.
REFERENCE
«•
1. N.J.S.A. 13:lE-99.59 New Jersey Dry Cell Battery Management
Act.
2. N.J.S.A. 13:lE-99.44 New Jersey Toxic Packaging Reduction
Act.
3. Minnesota Statutes section 115.01, subdivision 8
Fluorescent and High Intensity Discharge Lamps; Report and
section 116.92 Mercury Emissions Reduction.
4. NJDEPE The Findings and Recommendations of the Task Force
on Mercury Emissions Standard Setting - Preliminary Report
September 1992, Interim Report December 1992.
5. USEPA Characterization of Products Containing Mercury in
Municipal Solid Waste in the United States 1970 to 2000 OSW
# EPA 530-R-92-013 April 1992.
6. Florida DER Mercury Emissions to the Atmosphere in Florida
- final report 91166cl August 1992.
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figure 1 '' .''•-•- •'..'•
MERCURY EMISSIONS TASK FORCE
1.NJDEPE PETITIONED BY CAMDEN COUNTY THROUGH CEHA
TOESTABUSHAPOINTSOURCESTANDARDFOR
MffiCURY CONTROLTO 5Q/ig/dscm
2. NJDEPE REJECTED STANDARD:
INSUFFICIENTTECHNICALAND SCIENT1RC
ANALYSIS TO SUPPORT STANDARD
3.iNCONSIST0fTWrTHCEHA:
NO DELEGATION OF AUTHORfTYTO CAMDEN
TO REGULATE AIR POIM10N THROUGH
STANDARD SETTING
4.ESTABUSHMENTOFAMERCURYEMISSIONSTF '
A. HEALTH & ENVIRONMENTAL ISSUES
B. TECHNICAL & REGULATORY ISSUES
figure ;
MERCURY IN PROCESSIBLE SOLID WASTE
STREAM IN NEW JERSEY'S RRF'S
MERCURY IN MSW IN NEW JERSEY
NJHg.M= USHg.M * 1'153 *
MERCURY IN B/ISW IN NEW JERSEY
Eq.l
= (US
CyMr0
Eq.2
* 0.70 * 1.153 * 0.031
Eq.3
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= 0.0048 IbsAon
- 0.0089 Ibs/ton
* MERCURY IN PSW IN NEW JERSEY RRFs
MSW = 95% B/ISW « 5%
= 0.005 IbsAon
&gure3
Anthropogenic Mercury Emissions in NJ
to the atmosphere; estimated by source
High Etaroa-
J
«ItytM
.
ndiaUitf
Ml flUlM
i j i i ; iui * ' ' "™ : ; • ' i '
r • '
^^Sl^^^^^^}^^^^^^^sBw 4 i i . ;
: •: ; ; '• '• 'N : , m, : ' •
fiSSfl. | jjisji 1 , " 4;. |i •
j 1 1 " i •
j^^^0s*csfi^isi K - '• ' * -
i : i « ill!' , is Eatimatw
s»Mi&&S8a i^ i ' , wjyliiuda
: :i;>- '; , sufficient d;
, i i ;• i • ,
median or
100 ' 1000 WOOD
Us Total HjA'r., Range of Estimates
NOTE: Ruigi* of aarcuzy «Biuionc to the atnospher* Iroa
other potential sourc*c arc not given because available
dare wa> considered insufficient. Based on tbi limited
data available, tne possibility exists that emissions
fron eanbuction of natural gas and gasoline could be
significant.
Figure 4
Mercury In Consumer Products In
The New Jersey MSW Stream
Product 1992
Batteries
Alkaline*
Mercury Oxide**
Others
Battery subtotal
Electric Lighting
Fluorescent Lamps
High Intensity Lamps
Lighting Subtotal
Paint Residues
Fever Thermometers
Thermostats
Pigment
Dental Uses
. Special Paper Coating
Mercury Light Switches
TOTAL
Tons Percent
8.23 48.3
5.86 34.4
0.16 0.9
14.25 83.6
1.05 6.1
0.03 0.2
1.08 6.3
'0.37 2.2
0.59 3.5
0.35 - 2.0
0.23 1.4
0.13 0.7
0.02 0.1
0.04 0.3
17.05 100.0
Main contribution from residential MSW
Mam contribution from inniurional MSW
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Mercury In Consumer Products In
The New Jersey MSW Stream
Mercury Content In New Jersey RRFs
Product
Batteries
Alkaline -
Mercury Oxide •
Others Batteries • | 0.16
Electric Lighting
Fluorescent Lamps -
High Intensity Lamps -
Paint Residues
Fever Thermometer*
Thermostats
Pigment
Dental Uses
Special Paper Coating
Mercury- Light Switches
Permit
Sack Potential Flue Gas
Facility
CamdenRKF
Essex RRF
Gloucester RRF
Warren RRF
* Data (ran Chapter 6
Limits
0.08
0.053
0.12
0.05
Test Concentrations 1
0.033 0.074 1
0.021
0.042
0.016
0.155
0.063
0.043
r
1
1
i
** Nomirul througrt-txit operating M 100% on-line ivsibbiliry with 100% mercury
wlialteation without controls. •
Fiwe
Rfrhrrim Of Mercury In Discarded Consumer
Products In The New Jersey MSW Stream Resulmm
From Cuttcnt Source Reduction Pnjfeifrms ^1
I
Product 19931 1994 U 19951
0 1
Tons
10
Figure?
Reduction Of Mercury In Discarded
Consumer Products In The New Jersey MSW Stream
Resulting From Current Source Reduction Programs
Product
1993
1994 1995
Batteries
Alkaline
Mercury-Oxide
Others
Battery Subtotal
Electric Lighting
Fluorescent Lamps
High Intensity Lamps
Lighting Subtotal
1.49
2.17
0.15
3.81
1.09
0.03
1.12
— Tons —
1.58
1.06
0.14
2.78
1.13
0.03
1.16
1.69
0.14
0.13
1.96
1.17
0.04
1.21
Batteries
Alkaline -
Mercury Oxide -
Others Batteries'
Electric Lighting
Fluorescent Lamps -
High Intensity Lamps -
Paint Residues
Fever Thermometers
Thermostats
Pigment
Dental Uses
Special Paper Coating
Mercury Light Switches
tm~
5
=
^m
••-^_—
i^H
•M
1^1^
•M
1^
i
E^—M*
^
r
M
•K
^
L
1
1
1
I
^iV
1
1
0 .25 .50 .75 1.0 U 2.0 2.5 3.0 33 4 ™
Tons . •
Figure?
Potential Flue Gas Concentrations In New Jersey
RRF's With Source Reduction Program
Paint Residue
Fever Thermometers
Thermostats
Pigments
Dental Uses
Special Paper Coating
Mercury Light Switches '
0.27
• 0.59
0.33
0.17
0.12
0.01
0.05
0.18
0.59
0.31
0.11
0.11
0.01
0.06
0.08
0.60
0.29
0.05
0.10
0.00
0.06
Total
6.47
S.31
4.35
30
Facility Permit Limit
pounds/hr/unit
Year
Camden RRF
Essex RRF
Gloucester RRF
Warren RRF
0.08
0.053
0.012
0.05
PC
1992
0.074
0.155
0.063
0.043
itential Flue Gai
Concentrations
pounds/hr/unit
1993 1994
0.031
0.063
0.028
0.017
0.025
0.053
0.023
0.013
s*
1995
0.022
0.044
0-019
0.009
!
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figure 10
RRF MERCURY MASS BALANCE
TOTAL MERCURY IN RRF RESIDUAL ASH
FACILITY
GAMDEN CO. RRF
WARREN CO. RRF
MiN. MAX. AVG. N
mg/kg
(*/ton)
0.035
0.00007
O.Ot
0.00002
7.7
0.0154
0.81
0.0016
3.05
0.0061
0.041
0.00008
114
130
MERCURY EMISSIONS IN RRF
FACIUTY
CAMDENCO. RftF
WARREN CO. RRF
PERMIT STACK
LIMITS TESTS
Ibs/ton
0.0055 O.OO37
o.oos
O.OO3
MERCURY BALANCE IN RRF
FACIUTY RESIDUAL ASH EMISSIONS TOTAL
CAMDENCO.HRF O.OO61 O.OO37 O.OO98
WARREN CO. RHF O.OOOO8 O.OO3 O.OO3O8
figure 11
RISK ASSESSMENT
USEPA
Mercury
RfC
RiD
Methhylmercury
0.3 ^g/kg/day
NJDEPE-DSR
RECOMMENDED
Methhyimercury
ADI 0.07^g/kg/day
DHHS-ATSDR
PROPOSED
Methhylmercury
MRL
0.04^g/kg/day
figure 12
FATE & TRANSPORT MODELLING
FOR MSW INCINERATION
r t.
* The ADI should be considered as
the health basis for the mercury
emissions standard
* Limit source contributions to
insignificant levels in terms
of methylmercury ingestion
less than 1% of ADI
* Reduce mercury emissions from
MSW incinerators to less than
95 % of current levels
figure 13
OTHER HEALTH RISK
BASED STANDARDS
SOIL STANDARDS
ACTION LEVELS SOIL STANDARDS
CADMIUM 3
LEAD 250
1
100
SLUDGE COMPbST
CLASS A CLASS B USEPA NJDEPE
CADMIUM 20 40
LEAD 2400 4800
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figure 14
COST
SOURCE REDUCTION
CAMDEN
ESSEX
BERGEN
WARREN
SOMERSET
BATTERIESflbs)
564,728
873,477
926,247
258,226
103,292
269,454
HUNTERDON 119,005
TOTAL
3,114,429
COST(1.25/lb)
$ 705,910
1,091,846
1,157,809
322,782
129,115
336,817
148,757
3,893,036
STATEWIDE 8,676,379
10,845,000
figure 15
AIR QUALITY CONTROL TECHNOLOGIES
FACILITY CAPACITY MERCURY
(NC*0.85) ($3.00/ton)
CAMDEN 325,763 977,289
ESSEX 698,062 2,094,186
GLOUC 178,393 535,179
WARREN 124100 372,300
TOTAL ($)
CADMIUM LEAD RATEST TOTAL
($0.50/ton) ($0.50/ton) ($0.25Aon) ($}
162,882 162,882 81,441 1,384,494
349,031 349,031 174,516 2,966,764
89,197 89,197 44,598 758,171
62,050 62,050 31,025 527,425
3,978,954 663,160 663,160 331,580 5,636,854
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Developing An Effective Education Program In Schools
Dr. Herbert D. Thier, Director
SEPUP, Lawrence Hall of Science
University of California at Berkeley
It's really a privilege to be here and to have this opportunity to talk to this Convention which
represents such a diverse combination of groups, Institutions, and individuals. My goals this
morning are three fold. First I want to discuss some general principles related to bringing edu-
cational programs of the kind you are interested in, into, the schools. Then I want to briefly
introduce you to the goals and objectives of the Science Education for Public Understanding Pro-
gram (SEPUP). Finally I want to share with you some of the draft national standards for science
education in the United States.
I would like to start off by talking about what I consider the three C's of developing an ef-
fective school education program, Consult, Create, and Cooperate. By consult I don't mean go out
and hire a group of consultants, I rather mean consult with the group you want to work with the
schools. The schools are a complex social institution. Schools in each state operate differently and
schools in each community operate differently. One way to approach the schools of course is to go
to the local board of education or the board at the state level. Five or six years later you may be
able to start thinking about implementing your program. The other approach is to find yourself a
strong champion who is in the schools, who knows the schools, and becomes a real part of your
group. That is what I mean by a consultant. Talk with the group you want to affect, discuss with
them their realities and their needs and interests. Work with them so that what you create meets their
needs and objectives while accomplishing the goals you have set for the program.
By create I mean change in public education is a creative act. It takes intensive work, it
takes collaboration between experts in the subject matter and how to deliver it. If also requires an
understanding of the community in which you want to implement the new educational materials.
Many of you are experts and work very effectively with organized and disorganized community
groups. I want to suggest to you that the school is an equally complex social system. Therefore, to
bring about real changes in the schools requires the kind of careful thinking you give to beginning
a program in your own communities.
Lastly cooperate. There is little or no need to reinvent the wheel. You are experts in what
you do so don't try to become experts in everything. Cooperate, and collaborate so that people in
education can work together with you to develop very strong productive programs that will help
accomplish your objectives for the schools.
I would now like to talk about what I call the difference between public education and pub-
lic information. Providing a brochure, or a one day speaker, or an assembly in a school is an
excellent form of public information. There's absolutely nothing wrong with it and its a very pro-
ductive thing to do to introduce your program to a community. However it is not public education.
Episodic intervention whether in the form of a single visit or a brochure, will never become inte-
grated into the actual curriculum of the school. If you really want to change the way young people
think, you need to provide them with meaningful interactive experiences related to their interests.
Remember our fourth graders this year will vote in the first presidential election of the 21st century.
When you think this way, you begin to look at our only renewable resource, the young in a
very different way. You realize that, we need to integrate these issues we are so concerned about into
the ongoing curriculum of the school. However, neither I nor you can do that. The best that either
of us can do, is to design effective instructional materials. That is we can design something that gets
learners actively involved so they know what's happening and the consider the issues involved.
The curriculum is something that requires a teacher, because curriculum is truly the inter-
action between the knowledgeable teacher or other instructional leader and the student. No matter
how good the material may be, unless you have a competent instructional leader concerned with the
group they are working with, little will happen. This is why we need the teacher's input to ac-
complish productive education especially in the area of issue oriented science because we not only
.want to change, what students know, but how they act.
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You can not do it with teaching machines, television, etc. alone, not even computers.
Technological advances can help but they cannot replace human interaction if you want to change
thinking and action. The unique role that the concerned adult can play in facilitating learning and
understanding, is what makes the difference.
At this point, I want to briefly introduce you to the program I have the privilege of direct-
ing. It started in California as a small state program some nine years ago. Today the Science Edu-
cation for Public Understanding Program, (SEPUP) is active in every state in the United States. It is
also active in Australia, Spain. We have just changed the name from chemical education (CEPUP) to
science education (SEPUP) for public understanding to reflect our expansion to a wide variety of
new topics.
The National Science Foundation has funded a new grant for the next phase of our project.
The name change reflects the expansion of topics we will address, including physical, earth, and life
sciences. SEPUP will develop two year long courses for the early secondary school grades (7-10)
that will emphasize'an integrated approach to teaching issue-oriented science. The new SEPUP
courses will continue the activity-based approach of CEPUP. Interdisciplinary aspects will be
enhanced as the program continues to make the concepts and techniques of science relevant to the
real-world experiences of the learner. In a science curriculum either course will be able to stand
alone, be used in sequence, or serve as a resource for those who wish to prepare a customized course
to respond to local needs. The first course will be available for extended field test usage in
September 1994.
Course One:
A capstone course for the middle/junior high school
Our first yearlong course will focus on concrete and experience-based issues that impact
either the student's personal lives or their local community. We expect to adapt more than half of
the material for this course from existing modules, such as Chemical Survey, Solutions and Pollu-
tion, Risk Comparison, Determining Threshold Limits, Chemicals in Foods: Additives, Investigating
Groundwater: The Fruitvale Story, Toxic Waste, and Plastics in Our Lives. The course will be
carefully constructed to develop thematic connections to enhance student learning. It will entail
modification and resequencing, as well as preparation of background and connecting activities, to
provide an integrated experience for the learner. Additional materials will include activities that
encourage students to interrelate their learning from several modules, and to become more in-
dependent in their design, analysis and written and oral reporting of laboratory experiences.
Among the additional topics under consideration for the first course are radiation and
health, including concerns about the electromagnetic fields associated with high voltage transmission
lines, individual and local responses to energy issues, and water quality. Issues involving over-the-
counter and prescription drugs will be dealt with in a new unit on pharmacology and dosage, which
will be closely interwoven with material from the existing Determining Threshold Limits module. '
Course Two:
Science for citizenship in the 21st century
The second course will stress more abstract issues; those that have global implications and
involve difficult trade-offs. A major theme will be "sustainable development," the international
U.N.-sponsored goal for environmentally responsible development.
Most of the material for this course will be developed in the next two years. Topics under
consideration include comparing environmental health risks, biotechnology, global implications of
energy sources, and global atmospheric changes. Approximately a third of the second course will
be adapted from current or soon-to-be-available modules such as The Waste Hierarchy, Island
Factory, Investigating Hazardous Wastes, Refrigeration, and Air Pollution.
The basis for the whole SEPUP program is the fact that rather than anxiously demanding
answers it is essential that people learn to ask pertinent questions, also obtain evidence and use it as
the basis of decision making. They also need to understand the limitations associated with scientific
evidence.
The goals of our program are 1: To promote the use of scientific principles, processes and
evidence in public decision making. 2: To contribute to improving the quality of science education
in America. 3: To provide school and community groups education experiences focusing on
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chemicals, the rest of science and their interaction with people and the environment. And especially
4, To enhance the role of science teachers as school and community leaders. If there's one thing
you take home from this talk, think about the science teachers in your own community as allied
partners who can work with you, in delivering highly effective community education in schools and
other places.
Our newest module which will be published in 1993 is on a topic that I'm sure is of high
interest to this group. It focuses on the students exploration of the safe and effective use of house-
hold chemicals, as they investigate questions such as: how much of a household chemical is enough?
Would two household chemicals mixed together work better than .one? How do they work in the
first place? What we try, to get the students to understand in this module is the concept of rate, and
the concept of product interaction. The fact that if a little bit works, a lot doesn't necessarily work a
lot better. We are also interested in getting the students to consider some of the very unique and
interesting issues we face in relation to an expanded definition of household disposal issues. For
example in California, I can go out and buy many products like acetone in my local hardware store.
I can buy as much as I like, but it is illegal for me to dispose of these same products in the state of
California.
As we see the issue the whole concept of household hazardous chemicals has to be ex-
panded greatly beyond household hazardous chemicals to community hazardous chemicals.
Community hazardous chemicals include all substances identified as hazardous and currently un-
regulated like the acetone in my example. The regulations for large business's are increasing, but
there's a large area of unregulated usage going on, where we need not only rules and regulations, but
public understanding to bring about public policy. This unregulated area includes the home, hobby
and home or small business use of substances that have been identified as hazardous.
As one example of the kind of activities that we develop for students and adults, in SEPUP
imagine that you come up to the check out counter at the supermarket and they ask you whether
you want a bag made out of paper of plastic. We begin our Plastic in Your Lives module by holding
up a paper bag and a plastic bag in the classroom. We ask students which one .they prefer and they
have a chance to vote, by placing a piece of paper with one reason for their choice into the ap-
propriate bag. Think about this activity for yourself.
How many people here would vote for plastic? How many would vote for paper? How
many would vote for neither? Most of the students vote for paper at the beginning of the module.
We then take diem through an understanding what polymers are and the very important pan they
play in our society. We also discuss the various environmental issues related to the use of polymers
in our society. We come back at the end of the module to consider energy and total life cycle issues
to show that both paper and plastic bags have their advantages and disadvantages. When you look at
the energy needed to make them and what really happens to both in land fills, it becomes clear there
are very few advantages to either one. And lo and behold many of the students on their own come
up with the European concept of a reusable bag.
Finally I would like to present to you excerpts from the work of the National Committee on
Science Education Standards and Assessment, which is working under the leadership of the National
Research Council in cooperation with the major scientific and educational organizations in this
country to develop a set of standards, for science education in the United States. The excerpts
presented are from the November 1992 preliminary report of the group.
Considering our common interests I have focused on the pan of the document related to the
reasons for having standards and the standards for the application of science to decision making.
First the committee identifies some of the purposes and uses of standards as follows:
"Standards for science curriculum, teaching, and assessment will be integrated in a single
document. The standards will specify criteria to judge the quality of school science and to guide the
future development of the science education enterprise."
"Standards for science content will specify what all students should attain for:
1 a limited number of fundamental subject matter understandings;
2 the ability to inquire;
3 the ability and inclination to use scientific knowledge and reasoning when making
decisions;
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4 an awareness of how science is practiced and of the interactions of science, technology,
and society."
"A knowledge of science is an essential pan of an individual's abilities to:
1 function well and make informed decisions in the home, community, and workplace;
2 continue to learn for personal, professional, and civic reasons;
3 understand the relatedness of the spheres of human activity and the influences of culture
and context on human understanding."
"Therefore, school science programs must provide experiences that:
1 are personally and socially relevant;
2 call for a wide range of knowledge, methods, and approaches to analyze personal and
societal issues critically;
3 encourage students to act in ways that reflect their understanding of the impact of
scientific knowledge on their lives, society, and the world;
4 encourage students' appreciation of the scientific endeavor and their excitement and
pleasure in its pursuit;
5 develop in students an appreciation of the beauty and order of the natural world."
Then under the area of application of science the committee identifies the following goals
for a student at the end of twelfth grade:
By the end of grade 12, all students should have developed the following decision-making
skills. They should be able to:
I identify and state clearly an issue of personal, civic, national, or global significance that
is of high interest to them. The statement must be in a form that requires a decision; for example:
"How will the county dispose of its garbage after the present landfill has reached capacity?"
2 identify important dimensions of the issue such as the -scientific, political, ethical,
cultural, technological, and economic impacts.
3 gather information about the scientific and technological aspects of the issue, including
relevant principles, concepts, and data.
4 generate a set of alternative solutions that address all dimensions of the issue.
5 evaluate each proposed solution in light of its scientific and technological aspects and
recognize when as incomplete knowledge base may result in uncertainty and ambiguity.
Finally the document summarizes the relationship between science and public decision making with
the following statement: "Scientific understanding is an essential, but not a sufficient, ingredient for
decision-making; however, science alone cannot provide the decision. It can help to clarify some of
the issues and to determine scientific or technological feasibility. Nevertheless, in the end, social,
political, economic, and ethical values will influence the decision significantly."
This new set of standards will make it easier for those of us who are concerned about em-
phasizing societal issues in the science program to work together. As we "Consult", "Cooperate", and
"Create" together we can develop very strong and meaningful science materials that deal with the
societal issues of interest to the community while at the same time deal with the fundamental science
concepts involved. Students as a result will have in addition to the understanding of the science, the
knowledge of how to use the findings of science as a basis for decision making. This is what I call
the "Civics for the 21st century, because it will empower the individual to use evidence and reason
instead of propaganda and emotionalism as the basis for their decision making about these science
related issues that are so important to the future of our society.
Further information about the national standard for science education can be obtained by
contacting them at:
NCSESA Critique & Consensus
National Research Council
2101 Constitution Avenue, NW
HA 486
Washington, DC 20418
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TO BE OR NOT TO BE ... A CESQG:
An overview of issues regarding conditionally-exempt
small quantity generators
Dave Galvin
Hazardous Waste Management Program
Seattle Metro
1. INTRODUCTION/DEFINITIONS:
Hazardous chemicals are used by all segments of modern
society: industries, small businesses, governmental
services, households. Hazardous wastes are likewise
produced by everyone, but regulatorily they are pigeon-holed
differently and, in some cases up until now, ignored.
A shelf of various products in a home basement and a shelf
in a small business might look virtually the same and
contain many of the same materials. Yet the very small
business has the potential to use, store and throw away-
hazardous substances in greater concentrations and amounts
than the typical household. Home hobbies blend into
working-out-of-the-home businesses to further gray the
distinctions in household versus business as well as in
chemical and waste types. And"to even further complicate
the arena and make life more interesting for management
programs, a surprising amount of working-out-of-the-home
business is done "under the table," with no business
licenses for identification or tracking nor any taxes paid.
This latter issue makes for great challenges for local
programs wishing to address the very small business wastes.
There is a long continuum of waste generators, from the
large industries that are fully regulated, known in some
circles as "LQGS" or large quantity generators, through
various epithets and their accompanying acronyms for medium
quantity generators ("MQGs"), small (but still regulated)
quantity generators ("SQGs"), to the."very small quantity
generators" ("VSQGs") or the term gaining most usage now:
the "conditionally-exempt small quantity generators"
("CESQGs").
The federal Resource Conservation and Recovery Act (RCRA)
defines (in 40 CFR 261.5) these entities as those businesses
that produce less than 100 kg (220 Ibs.) of wastes that meet
one of the various definitions of hazardous per month or
batch, and which store no more than 1000 kg (2200 Ibs.) of
these wastes total. 'It is O.K. by RCRA for CESQG hazardous
wastes to go into municipal solid waste .provided that the
state so designates MSW facilities as acceptable for these
small quantities of hazardous wastes.
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As more and more communities across the country develop some
type of program to address household hazardous wastes, CESQG
hazardous wastes tend to be the ones that have slipped and
continue to slip through the cracks.
2. KEY POINTS;
I would like to cover some issues relating to CESQG
hazardous wastes, in order to convince you that:
1. CESQG wastes are a big deal (much bigger than HKW);
and.
2. Every program that addresses HHW should also be
addressing CESQGs.
3. SOME FACTS. FIGURES. ESTIMATES AND CHARACTERISTICS OF
CESOG5:
First, some "factoids" (including quantitative estimates)
that will be useful to the discussion. Conditionally-exempt
small quantity generators can be large or small businesses;
they tend to be "small" and so we usually talk about small
businesses and small quantity generators interchangeably.
They also can include local government agencies, schools and
other entities that are not usually thought of as small
businesses. In Washington state, 90 percent of all
businesses are "small" by state standards (50 or fewer
employees). Another amazing statistic is that four out of .
five small businesses fail within five years: there is
incredible turnover in 'these entities that we might be
trying to reach.
Typical small businesses that are potential CESQGs include:
Vehicle maintenance
- auto service & repair
- auto body repair
Construction and contracting
Printing and graphic arts
Laundries and dry cleaners
Photofinishing
Pesticide application
Furniture/wood manufacturing and refinishing
Cleaning agents and cosmetics
Dental offices
Laboratories
You-name-it ...
Part of the challenge of addressing CESQG businesses lies in
the numbers present in any area. They are everywhere and in
numbers that make contact or enforcement a daunting task. In
the Seattle-King County metropolitan area, for example,
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there are 50,000+ licensed businesses. Ninety percent are
"small", which equals 45,000 small businesses. By Standard
Industrial Classification (SIC code) and waste analyses, we
estimate that 20,000 of these 45,000 are potentially
significant CESQGs. So,' in a metropolitan area of 1.6
million-people, there is 1 CESQG business for every 75
people.
Some other estimates I have seen include Massachusetts, with
a population of 6 million and an estimate of only 13,500
CESQGs statewide (1 CESQG for every 450 people); and
Vermont, with a population of 500,000 and an estimate of
"more than 4,000" (2,500 - 12,000) (1 "ESQG" for every 125
people). One might be able to use some of these estimates
or methods to predict at least the upper and lower extremes
of numbers of small businesses for any given population.
Typical CESQG wastes include a wide variety of substances:
Spent,solvents
- halogenated
- non-halogenated
Heavy metals
Ignitable wastes
Acids/bases
Paints and paint sludges.
Like household hazardous wastes, CESQG wastes are small by
individual generator but become an issue because of the
number of generators throwing these wastes into the
municipal waste streams or the environment: the cumulative
effect. Our program in the Seattle-King County area
estimates that CESQG wastes are twice the tonnage of
household hazardous wastes and are therefore a more
significant waste stream to deal with. Our municipal solid
waste and wastewater data led us to estimate that CESQGs
produce 13,000 tons of hazardous waste in our area; with an
estimate of 20,000 CESQGs, this means that each one on
average produces 1400 Ibs./year (2/3rds of a ton) or 119
Ibs./month. These estimates pass the "uh-huh" test and,
again, could be used by other programs to help estimate the
magnitude of the problem before them.
Other, less tangible characteristics of CESQG businesses
include some of the following: the top priority of any small
business is staying open, serving customers -- the
environment or hazardous waste in particular may be way down
the list of worries or concerns on any given day. or year;
small businesses by nature have few staff, none of whom have
regulatory or waste management expertise; resources (both
money and staff time) are lacking. These are all
significant factors to consider when attempting to address
small business1 hazardous wastes.
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4. ISSUES:
I would like to highlight seven major issues that programs
need to address when considering the plight of
conditionally-exempt small quantity generators:
1. Gray areas of regulations. Definitions vary state
to state as to what is a conditionally-exempt SQG or even if
any exemption exists. Such individual businesses are hard
to identify. Even in states that "regulate to zero", there
is very little enforcement or compliance activity. .
2. Threshold not absolute. Businesses swing above and
below the magic 220 pound line, on an ongoing basis or month
to month. In addition, in an economic downturn," businesses
may dip below the line only to cross back over when the
economy picks up. Within any given business type, some may
be fully regulated while others may fall below the
regulatory threshold.
3. The shadow of CERCIA lurks. No matter who you are,
if you cause a problem, you are liable. CERCLA does not
recognize the conditional exemption that RCRA allows.
4. Small businesses need help, not more regulation.
The ten most frightening words in the English language to a
small business are, "I'm from the government and I'm here to
help you." Our task, however, is just that: awareness
raising, technical assistance, generic and site-specific
advice. These are the things small generators need, not
regulation,
5. [Corollary] You could never hire an army big enough
to regulate even if you wanted tol There are simply too
many of these small businesses out there and they change so
frequently that the traditional approach used with larger
industries simply will not work.
6. Services for CESQGs are few and far between.
Advice, technical assistance; Most such services are aimed
at LQGs and SQGs (even all the existing pollution prevention
programs around the country). Few if any services are
currently available that focus attention on the true CE- or
very small generators. Collection and waste handling:
Getting tiny amounts of waste picked up is often very
expensive and/or next to impossible to arrange. And in some
states (Rhode Island and Maine, as examples) CESQGs cannot
legally transport their wastes. (California, Massachusetts
and Minnesota have revised their laws to allow for self-
transport.) Even when pick-up or drop-off services are
available, they are usually only in urban or metropolitan
areas, not rural. Lastly, most HHW collection services do
not allow CESQG participation. These are substantial
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obstacles to overcome, whether from the perspective of the
small business or from that of the local program trying to
address their wastes.
7. The Objective is behavior change. We have got to
motivate,, make it easy, and reinforce good behavior. How do
we best motivate small businesses to do what they don't
legally have to?
5. SUMMARY;
In summary, I would like to make the following key points:
1. CESQGs are the last major source of hazardous waste
into. MSW, sewers and environment that is not being
addressed.
2. Programs that are currently focusing on HHW should
also address .CESQGs.
3. CESQGs need help (education, technical assistance),
not more regulation.
4. Our ultimate objective is behavior change.
I encourage all programs to THINK BIG WHILE DEALING SMALL!
And to deal in the conditionally-exempt small quantity
generator businesses to programs that help solve their
hazardous waste management problems.
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Priorities for Source Reduction
Philip Dickey
Household Toxics Project Director, Washington Toxics Coalition
Seattle, WA
Introduction
In this paper, I would like to set the tone for the source reduction portion of this
conference. According to Dana Duxbury's statistics, in 1991 there were 802 collection
"events," including 96 permanent collection programs.1 The number of programs has risen
dramatically as local governments seek to remove hazardous materials from municipal
waste streams and homeowners' basements. However, we are still looking at the tip of the
iceberg. In Seattle, where collections have taken place for many years and a second
permanent collection site is about to open, 30,000 customers were served in the most recent
year. That may seem like alot, but it represents only 5% of the households in the county. At
a program cost of $2 million, the cost per vehicle works out to between $60 and $70.2
When faced with the cost of serving 100% of the population, source reduction looks
attractive.
Over the years, source reduction has increasingly been recognized as the most desirable
method for preventing both solid and hazardous waste. Despite its obvious importance,
source reduction is often given Up service but seldom receives the priority it deserves. If we
are to move ahead, we must define our goals, set priorities, and evaluate the results.
What do we mean by source reduction? To define source reduction of hazardous
products, we need to examine all three terms: source, reduction, and hazardous products.
Depending upon one's point of view, the source of household toxics could be the
homeowner, the retailer, or the manufacturer. All three of these groups have a vital role to
play in source reduction, and all three therefore can and should be considered part of the
source. Reduction refers to a decrease in the hazardous properties and/or the volume of the
products used or disposed of. The hazardous properties can include toxicity, flammability,
corrosivity, reactivity, or environmental effects. All are important. Hazardous products
include any products which pose health or environmental risks during use or storage or
which would be considered as a hazardous waste by a household hazardous waste
collection program. Combining these elements we come up with a working definition:
"source reduction of hazardous household products is a decrease in the quantity or
hazardousness of products which can cause health or environmental effects during
manufacture, use, or disposal."
Setting Goals
Figure 1 shows what I might call Ptolemy's view of the household hazardous waste
(HHW) universe. The diagram shows the relationships between HHW and a number of
closely related fields. HHW is pictured at the center because it is the theme of this
conference and thus is the common element linking our interests. Many of us may have
different views of HHW and different reasons for being at this conference. Regardless of
your individual perspectives, however, there are two reasons for examining this diagram.
The first is to help see the broad picture of the multitude of reasons why source reduction is
important. The second is to remind us that reductions in one area can lead to increases in
another. It does not help to remove hazardous waste from the solid waste stream if that
waste ends up causing problems in the liquid waste stream or in the air. These so-called
cross-media shifts are not really waste reduction at all.
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By looking at Figure 1, we can see what some of the broad goals of source reduction
should be. Source reduction should seek to decrease the purchase, use, and disposal of
hazardous products which:
cause accidents or illness;
contribute to indoor air quality problems;
pose risks to wastewater treatment (i.e. to workers, equipment, or effluent, sludge,
and air quality);
pose risks in solid waste management (incineration, landfill, goundwater);
contaminate surface and groundwater through runoff or improper disposal;
cause depletion of the ozone layer;
kill birds, bees, fish, and other beneficial organisms; and
require special and expensive means of collection.
Figure 1.
Accidents
Illnesses
Indoor
Air
Pollution
Wastewater
Management
Household
Hazardous
Waste
Solid Waste
Management
and
Groundwater
Quality
Other:
ozone depletion
greenhouse effect
birds, bees, bugs
.These are broad, general goals. Within any particular source reduction program,
whether it be a program of education, reformulation, or reduction in product use, it is
important to define limited, attainable objectives for each area affected by tile program.
Thus, if the program addresses indoor air pollution, specific targets might include ambient
air or product concentrations of particular pollutants, or a 30% reduction in the use of a
certain type of product in a given number of homes.
At the same time, however, when evaluating the effectiveness of a source reduction
strategy, one must look broadly at all possible health and environmental effects. A gain in
one area may be offset by a loss in another. When manufacturers reformulated typewriter
correction fluids to replace the carcinogen trichloroethylene, they replaced it with methyl
chloroform, an ozone depleting chemical that now must be phased out by the year 2002.3
Indoor air quality was improved at the expense of the outdoor environment, and, in effect,
one type of cancer was traded for another.
Availability of Alternatives
Table I lists the major types of hazardous products, the typical problem constituents,
and some available alternatives. This list is not exhaustive, but it is intended to give a
qualitative picture of the extent to which hazardous products are currently replaceable if a
consumer wished to do so. The situation is far from static, as new products are being
developed every day.
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It is clear from looking at this table that the availability of suitable alternatives varies
widely across the product categories. For the most hazardous types of cleaners, effective
alternatives are widely available. Corrosive drain, oven, and toilet bowl cleaners are easily
replaced. Toxic spot removers can also largely be avoided, although potentially many
different products may be needed, depending upon the types of spots and stains. For
metals, some non-hazardous cleaners are available in the marketplace, and some of the do-
it-yourself recipies also work remarkably well. Chlorine bleach can be replaced in some
laundry applications, particularly for colored loads,but none of the alternatives has the
disinfecting ability or extreme whitening power of chlorine bleach. Dishwasher detergents
without chlorine bleach and phosphates have been on the market for several years, but
some of these products have not performed well under varying water source conditions. It
seems that some research and testing is still needed in this area. Generally, however, a
knowledgeable consumer could quite easily avoid most of the extremely hazardous cleaning
products by making careful choices. Of all of the product categories considered here,
cleaning products are the most likely to be disposable through the wastewater treatment
system and least likely to require special collection.
Polishes and waxes are usually hazardous if they contain petroleum distillates, which
make them both flammable and toxic, particularly through aspiration into the lungs, and
unsuitable for disposal in wastewater. Polishes used over large surface areas, such as
floors, can be sources of indoor air pollution.4 Furniture polishes based upon vegetable or
mineral oils are significantly less dangerous. Acrylic floor polishes also eliminate the
flammability hazard and reduce the vapor hazard. Solid shoe polishes are less hazardous
than aerosols because of their physical form, but they are still a disposal problem. Some
alternatives exist, but most of the major brands would be considered hazardous for disposal
purposes.
Paints make up one of the major volume items in hazardous waste collections. As the
variety and quality of latex paints continue to improve, most oil-based paints can be
replaced with these less hazardous alternatives. For some special purposes, oil based paints
are still necessary, but their use is decreasing. Latex paints are becoming even more
environmentally friendly, the removal of mercury having been closely followed by the
development of solvent-free paints. (One of these paints will be discussed in the panel on
case studies of reformulated products.) These paints are quite new, and customers are not
yet aware of their existence or advantages. As oil-based paints are replaced, the need for
thinners and brush cleaners is eliminated at the same time. Paint strippers are among the
most hazardous products in the home. Recent development of water soluble strippers based
upon dibasic acid esters provides a viable alternative to strippers based on methylene
chloride, acetone, toluene, and methanol. The fact that at least six brands are now available
indicates considerable interest in these products. The development of this type of paint
stripper will also be a subject of the product reformulation case studies.
In my view, all pest control products, whether hazardous or not, should be used in the
context of an Integrated Pest Control (IPM) approach, which not only minimizes the
hazards by requiring that least-toxic controls be given priority, but also maximizes the
chance for success. The question of alternatives should not be "what [single] product can I
substitute for malathion," but rather "what less-toxic tools are available." Generally, the
variety of physical controls is impressive, including traps, barriers, and other inventive
systems, and new products continue to come on the market. While not all problems
ultimately can be solved without toxic chemicals, an extremely high reduction in either
quantity or toxicity is quite possible in many cases. The main,problems in pest control are
educating the consumer about the IPM approach, overcoming the extreme convenience of
chemical pesticides, and making alternative products more available and competitively
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priced. Chemical pesticides currently benefit from an unfair advantage: their disposal and
environmental costs are not factored into the sales price. Research needs to continue on less
toxic, more selective pest controls, but these will also have to be evaluated in the context of
an EPM approach. A less-toxic or more selective chemical is still a chemical, and chemicals
receive lowest priority in IPM. An additional problem in evaluating the suitability of a
pesticide as a safer alternative is the presence of undisclosed "inert" ingredients. Many
pyrethrin formulations, for example, contain the solvent methyl chloroform, whose
damaging environmental effects counterbalance any environmental advantages of the active
ingredient. Given the complexity of this field, it is clear that a considerable burden will rest
with the consumer, and good pesticide education is very important.
With automotive products we come to the first major category in which relatively few
alternatives are available. Motor fuel and motor oil, like brake fluid, transmission fluid, and
many other petroleum-based fluids are currently not directly replacable. The culprit appears
to be the modern automobile itself, and management of the fluids appears to be the only
choice. Recycling is absolutely essential, but it is not source reduction. Reduction in miles
driven, and hence fluids used, is a form of source reduction, but its large scale
implementation often depends upon many external factors, such as availability of public
transit. The only automotive fluid for which there is a direct replacement is antifreeze.
Propylene glycol antifreezes are clearly less toxic, at least before the corrosion inhibitors
are added. The major factor blocking widespread acceptance of PG antifreeze as a suitable
alternative is the fact that it is not currently being recycled.
Few alternatives are available for adhesives, particularly those with special properties,
such as adhesion to unusual surfaces, flexibility, super high strength, or instant bonding.
The most replaceable hazardous glue is probably rubber cement, which may be replaced by
glue sticks, white glues, pastes, and electric waxers, depending upon the application. There
are some safer alternatives to traditional contact cement as well. But for epoxies, model
cements, and instant glues, options are limited.
Art and hobby supplies constitute a difficult area as well, because of the variety of
materials, some fairly exotic. Clearly, some materials are much safer than others, and many
choices exist. For the child or casual nobbiest or craftsperson it is imperative to base the
choice of materials heavily on the basis of safety, and choices like using primarily water-.
based art materials need not be overly restrictive. Unfortunately the recent loss (due to
budget cuts) of the California Art Materials List is a major blow to those of us trying to
identify the least toxic art products. The Art and Craft Materials Institute (ACMI) ratings are
useful, but they do not coincide exactly with the old California listing. For professional
artists working at home, it is more difficult to envision artistic decisions based solely upon
safety considerations, when specific media offer unique properties and results. Yet health
concerns are very important in the arts and crafts business, and mere protective equipment
is not enough. Research is necessary into safer dyes, pigments, solvents, and other media
to achieve safer materials with essentially the same artistic properties as the traditional ones.
A number of other miscellaneous products are easily replaced with less hazardous
alternatives. Charcoal lighter fluid is completely unnecessary nowadays, with the
proliferation of chimney devices that start fires more quickly, reliably, and safely from a
single sheet of newspaper. Apparently most consumers are not yet aware of these devices.
Directions and Priorities for the Future
On the last day of the 1991 conference in Seattle, a group of attendees came together in
a discussion group to talk about toxicity reduction. Some of the ideas that came out of that
group are worth reviewing here at the start of the 1992 conference because they seem to
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point in a constructive direction. The group outlined a four part strategy, which I have
paraphrased below.
Phase'l
• Identify hazardous constituents that are present in indoor air, municipal solid waste,
leachate, incinerator ash, incinerator emissions, MSW compost, wastewater and
POTW sludge
• Identify constituents of concern during use and storage
Phase 2
• Prioritize the hazardous constituents based on toxicity, impact on public health, and
the environment
• Identify the products which contain these constituents
Phase 3
Work with manufacturers to encourage product reformulation
• Develop educational strategies and legislative remedies based on the targeted
products
Phase 4
• Use Life Cycle Analysis to develop lists of safer substitute products
• Identify and implement effective education methods
Obviously this program is very ambitious, but some of the specific actions suggested
here have already begun. A good deal of evidence required for Phase 1 already exists at the
federal, state, and local government level, although it needs to be collected to identify gaps
and to see the whole picture. The approach that is being used at EPA5 to address indoor air
pollutants seems a good model for identifying constituents of concern, as well as for setting
priorities for source reduction.
Phase 2 is the difficult part. One of the most important roles for the government can be
setting priorities for hazardous waste reduction based upon human and environmental
health risks. This methodology should include environmental factors such as ozone
depletion potential, smog production, toxicity to environmental organisms, groundwater
pollution, etc. Estimates should also be made of synergistic interactions that may occur
with likely co-pollutants. When pesticides are involved, inert ingredients should be fully
taken into account. These risk assessments should not be used to predict actual quantitative
risks or safety factors, because the state of the art is not adequate to do that, but they can be
used to compare risks for the purpose of setting priorities for action. EPA has also analyzed
a great number of consumer products for hydrocarbons of special concern in indoor air
pollution.6 Surveys such as this need to be extended to identify products which contain all
targeted constituents of concern.
Possible actions which may arise from this analysis include working with
manufacturers to encourage specific reductions, banning certain ingredients, setting
incentives or taxes to facilitate finding alternatives for certain types of products or
ingredients, and additional restrictions on sales or labeling of products. For manufacturers
the goal continues to be to find safer alternatives, particularly in areas where few exist or
most products remain extremely hazardous, such as adhesives, paints, automotive
products, art materials, and pesticides. Lately there seems to have been an epidemic of so-
called "green cleaners," but this is not really the area in which we need the most research.
In fact, with the exception of paint strippers and enzyme-based drain cleaners, it almost
seems as though the number of new "green" products seems to be inversely proportional to
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the need for the products: We probably don't need any more "green" window cleaners or
dishwashing liquids, but we could certainly use some less toxic adhesives, phosphate-free
dishwasher detergents on the mass-market, and special purpose paints.
At the same time, as alternative products are introduced, the hazardous products they
replace need to be removed from the marketplace. Why do we still have lye-based drain
cleaners on the market when so many alternatives are available?
Retailers need to become more educated about the products they sell, and how their
disposal can be a tremendous environmental and economic burden. Selection of which
products to sell should take into account the hazards of the products, and safer alternatives
.should at least be offered side by side, giving the consumer a choice and helping to provide
markets for these products while achieving some education at the same time. Perhaps we
should make more effort to bring retailers into this conference so that they can begin to
better understand the issues and the challenges we all face.
In a market economy, however, the consumer has the real power and the real
responsibility. Given the right products, the right prices, sufficient availability, honest
informative labels, and some basic knowledge, the consumer must do the rest. A product
isn't going to remain on the market for long if it doesn't sell. Education about safer
alternatives needs to get more specific and it needs to reach beyond the 10% or so of the
population which is already quite informed. Phase 4 can involve many players, including
non-profit organizations, cooperative extension, local governments, and retailers. Third
party certifiers have a vital role in helping consumers sort out product claims. Finally,
consumer behavior needs to be measured for signs of progress.
Even without detailed risk assessments, some priorities are obvious. I submit that the
following types of products are high priority candidates for source reduction:
• Products considered extremely toxic, extremely flammable, corrosive, or highly
reactive
• Products containing known or suspected human carcinogens
• Products containing ingredients toxic to reproductive system, nervous system, etc.
• Products containing ingredients which are persistent in the environment
• Products which contain ingredients which bioaccumulate or bioconcentrate
• Products containing chemicals likely to leach into groundwater
• Products containing chemicals with major impacts on surface water (e.g.
phosphates)
• Products containing pesticides which are particularly toxic to harmless or beneficial
organisms
• Products containing ozone-depleting chemicals
Measurement
Once we have defined source reduction and set specific goals and priorities, we need to
have a way of measuring it to see if we are making progress. Up until now, most people
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have used primarily indirect ways to measure HHW reduction or they have not measured it
at all. We need to get more sophisticated and more precise in our measuring tools.
There are really only three ways to measure source reduction. One is to measure what
people buy. The second is to measure what they throw away. The third is to ask consumers
what they buy or throw away. By themselves, surveys are notoriously unreliable because
what people say is often not in accord with what they do. Surveys are best used in
conjunction with direct measurements.
Sorting of garbage to determine the content of hazardous products is underway, and
results from Minneapolis will be reported at this converence. Surveys are being utilized to
measure what consumers say they do or will do. We have not really tackled product
purchasing statistics, however. Direct measurement of source reduction can be done by
monitoring the hazardous chemicals which go into and out of industries, stores, and
homes. More effort needs to be put into obtaining and interpreting these numbers.
References
1. Duxbury, Dana and Associates. National Listing of Household Hazardous Waste
Management Programs. 1991.
2. Galvin, David. Personal Communication.
3. Clean Air Act. §603.
4. Tichenor, B., and Mason, M. "Organic Emissions from Consumer Products and
Building Materials to the Indoor Environment." JAPCA 38:264-268 (1988).
5. Cinalli, C. and Darr, J. "Screening Indoor Air Risks in the Office of Toxic Substances"
Existing Chemicals Program." Proceedings of the Sixth National EPA Conference on
Household Hazardous Waste Management, p 596. (Dec 3-7, 1991).
6. Sack, T. and Steele, D. "Indoor Air Pollutants from Household Product Sources."
EPA/600/4-91/025. (1991).
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™ National Household Hazardous Waste Conference (12/92)
v?
• Speech by Minnesota State Representative Jean Wagenius
• I appreciate the opportunity to talk about reducing the toxicity
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of the household hazardous waste stream.
• In the recent past government managed the household waste stream
as a convenience to its constituents and to keep our commons neat
• and tidy. It wasn't much of a trick as long as our waste stream
was chicken bones and coffee grounds — just collect the stuff
| and use it for fill for wetlands or gullies.
™ In the 70's we had landfill operators cover garbage to keep the
• flies and accompanying possibilities for disease down; we called
these new landfills sanitary. In the 1980's we found that
I sanitary was a cruel misnomer. The state of the art landfills of
the 1970's as well as all those that had gone before were leaking
an extraordinarily toxic mix into the groundwater.
Like most, Minnesota's response was to build incinerators and to
require clay liners and leachate collection systems for both ash
and regular landfills.
The potential neighbors of these new incinerators and landfills
have responded by saying "No, we don't want them". Government,
the managers of waste and the industry which produces the
products that end up in the garbage have dismissed the neighbors
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calling them NIMBY'S and,-in my judgement, are both blaming the
victims and blinding themselves to solutions.
Truthfully you would have to be somewhat irrational to just
accept a landfill next door. Of 150ish landfills in Minnesota,
63 are on the state's superfund list — some of these are open
and operating — and of those not on the superfund list,
everyone in the field believes that when they are tested, they
too will end up on superfund. The average cost of containment,
not cleanup, just containment, is $4.2 million dollars, so the
/
total estimate for containing the ground water pollution is
between $250 and $450 million dollars. Just to put that in
context, understand that we consume about 2% of the GNP. We are
scheduled to run out of superfund money at the end of the fiscal
year. As a neighbor of a potential new landfill, would you
really trust a system that has a projected budget shortfall of
$700 million, little money in superfund and over a hundred
leaking landfills?
Our state, like most others is planning new state of the art
facilities to manage our growing waste pile. In 1988 the
Minneapolis/St. Paul Metropolitan area paid $16.7 million just in
financing for the capital costs for facilities. The projected
cost for capital financing in the year 2011 is 81 million - 5
times as much. As you know capital costs are only a small part
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of the bill. And folks here are already complaining about
escalating.garbage bills.
• With both the clean up of old facilities and the building of new
facilities it is the toxins, not the volume, that is skyrocketing
| our costs. While not everything in the waste stream is toxic,
M everything that is burned, buried or composted has to be treated
as if it were toxic. In other words, some toxins are
• contaminating the whole disposal. stream and are driving our
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costs.
£ I want to give you an idea about the amount of toxicity coming
* - into our municipal waste stream and I'll do it in two ways. One
• way is to look at waste composition.
• The Minnesota Pollution Control Agency is in the process of
studying our waste composition. Based on preliminary results
• they have determined that .1% of the municipal solid waste stream
• is household hazardous waste. The .1% does not include
batteries, container weight or the toxins in things that are not
• regarded as household hazardous wastes — like the cadmium or
lead in inks on waste paper and plastic.
• Even so, based on the .1% figure, there were 5 million pounds of
household hazardous waste in our municipal waste stream in 1991.
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Remember we only consume about 2% of GNP. About half of the 5
million pounds went into our landfills. .,
Thus, an average sized landfill will receive about 48,000 pounds
of household hazardous waste each year and 1,200,000 pounds over
a 25 year lifetime. Clearly that is sufficient reason to manage
all waste as if it were hazardous.
Another way of looking at toxicity in our waste stream is to look
at what is ending up in the ground water around a landfill. We
have identified about 30 toxins that show up in the leachate of
at least 1/2 of the landfills which have been tested. We call
them priority toxics. These toxics would be familiar to you:
arsenic, cadmium, mercury, toluene, benzene, methyl chloride,
etc. Our Office of Waste Management has culled through the
products containing these priority toxins and determined that 89
million.Ibs of them are used in the products Minnesotan's buy
each year. Remember again, we consume roughly 2% of the GNP, so
that gives you a rough idea of how much is out there — how much
is not being managed in the industrial waste stream.
It is instructive at this point to give you a rough comparison of
the amounts of these priority toxins that are released by
industry and those that we use. Using the Minnesota Toxic
Release Inventory data for 1990, the staff of the Legislative
Commission on Waste Management compared the aggregate Minnesota
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• use of each of the priority toxics to totals of industry releases
• for each toxin. In almost every case we used substantially more
than industry released.
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For example, industry released approximately 7,900 Ibs of
8 arsenic, we used more than 225,000 Ibs. Industry released almost
• 500,000 Ibs of lead, we used more than 4 times as much. Industry
didn't release any methyl chloride, we used 160,000 Ibs.
I Industry released 13,000,000 Ibs of toluene, but we used more
than twice that. And my final example, industry released 220,000
J Ibs of benzene, we used 6,400,000 Ibs.
™ One of the conclusions I draw from these figures is that as a
• society, we are not facing a major source of our pollution
problems — that is use for our household products — and until
8 we do so, our waste management problem will be acute.
" I think government has 3 options: 1. to ban toxins on a case by
• case basis, 2. to collect them in the household hazardous waste
stream or to have the producer of the toxic product collect them,
• and 3. to label or tax them to try and discourage them.
• I'll briefly tell you about the experience Minnesota has had with
• each option: Several years ago Minnesota adopted the CONEG
proposal to ban four toxics (lead, mercury, cadmium and
• hexavalent chromium) from packaging. The ban not only limits
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toxicity but makes recycling of packaging easier. We then took
the CONEG proposal the next step and banned the four toxics from
other things like paints, dyes and fungicides.
In each of the last three years I was the chief House author of
legislation dealing with mercury and in each bill there.were some
bans.
I will tell you about them in some detail to show you that while
bans are worthwhile for some things that are so harmful to
Minnesota in particular, it is just too time consuming to.rely on
them as a general strategy.
Hennepin County began burning waste in late 1989 in a state of
the art waste to energy burner with a state imposed mercury
emissions standard of .002 Ibs. of mercury per ton. Given the
size of the burner, it can permissibly emit 2 Ibs. of mercury per
day. Keep this standard in mind. When the burner began it was
operating under the strictest standard in the nation. It is also
woefully inadequate.
Studies in both Wisconsin and Minnesota have documented mercury's
harm. A Minnesota study found pervasive evidence that high
levels of mercury contamination of fish are not natural and are
increasing; these studies were done on some of our most remote
and pristine lakes.
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The mercury is coining primarily from the atmosphere and is
• entering the atmosphere from three main sources: combustion of
coal for electric power, mercury additives to paint and waste
• incineration. The average annual increase of mercury since 1930
has been about 3% per year, 5% since 1970.
I
I The study found that even the smallest amount of mercury in a
'
lake is capable of causing harm. Concentration of only 2 parts
• per trillion can trigger a fish consumption advisory. In some
Minnesota lakes mercury concentration is high enough in fish to
I harm or even kill mink, otters and loons. A May 1991 report from
the Minnesota Department of Health, advises eating fish from 310
• lakes only once per week because of mercury. The advisory was
posted on 95% of lakes that were tested.
I
I
• Dr. Carl Watrus, from the University of Wisconsin, reported to us
that he found that 1/2 gram, or the amount of mercury that would
fit in an "0" on a printed page is enough to contaminate a 30 to
• 40 acre lake. Compare that to the 2 Ibs a day that the Hennepin
County burner can emit or to the 1000 Ibs per year that NSP emits
• from its stacks in producing 70% of Minnesota's electricity.
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In 1990 Senator Greg Dahl and I proposed legislation limiting the
amount of mercury in household batteries. At that time batteries
were the number one contributors of mercury in the waste stream.
I found about that through sheer luck. Manufacturers were
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anything but straight forward. Obfuscation would be a kind word.
However a persistent college intern found someone at the Dept. of
Interior Bureau of Mines who kept track-of where mined mercury
was sent and from there we were able to piece together industry's
use of mercury.
Manufacturers never told us that several European countries had
already limited the amount of mercury in alkaline batteries,
because European countries had "dead" lakes and had determined
that much of the mercury came from waste incinerators which in
turn came from alkaline batteries.
In our first battery law we adopted the 1993 European/Canadian
standard of no more than .025% mercury by weight for alkaline
batteries. This went into effect in February 1992. For
Minnesota, that meant 500 Ibs. of mercury rather than 11,000 Ibs.
We also required that when manufacturers sell four types of
batteries to government or industry they either arrange for the
processing of the used batteries or take them back themselves.
The four are mercury, lead, silver and nickel cadmium. In bur
second battery law we required the elimination^ of all mercury in
alkaline batteries by 1996. We also adopted the European limit
for mercury in button cells.
However, mercury in button cells remains a problem. While the
amount in each cell is very small, the cells are ubiquitous.
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Both the number and the small size made them hard to collect.
The better solution, for us is for manufacturers to eliminate the
mercury. To their credit, Everready has already developed and is
marketing a zinc air button cell with no added mercury. We will
have a bill this year proposing that as the standard for all
button cells sold in Minnesota beginning in 1997.
Rayovac, at this point, is opposing the statutory deadline. If, '
however, we don't impose a statutory standard, companies like
Everready that would be willing to do the necessary research and
development and conversion of equipment would be put at a
competitive disadvantage. Put another way, the most polluting
x
company would be allowed to set the industry standard. And
Minnesota taxpayers would have to pick up the expense of
collection and disposing of button batteries.
In the process of working with mercury in batteries, we found out
about rechargeable household batteries. That brings me to the
second of the options for government: collect household
hazardous waste or have the producer do it. Rechargeable
batteries come in two forms: nickel cadmium and sealed lead acid.
They are a disposal problem no matter how you do it. Moreover
cadmium shows up in the groundwater under our unlined landfills,
in the leachate of our lined landfills and is one of the reasons
the Hennepin County burner is sending its ash to a hazardous
waste site. Cadmium is far more leachable once burned.
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Moreover, our counties who want to compost say that one hi-cad
can ruin a whole batch. Our office of Waste Management estimates
that the battery industry used 1,470 tori's of cadmium in 1990.
That means that 28 tons is coming into my state (remember we
consume 2%) each year.
EPA has told us that the projected increase of Ni-cads is
straight up and to get them out of our waste stream. What EPA
didn't tell us was how to pay for the disposal. While Europe and
Japan have facilities for recycling cadmium, there is no facility
in the U.S. Thus, if we told our counties they had to get ni-
cads out, they would have to send them to a hazardous waste site
at state expense which would essentially amount to a huge state'
subsidy to users. This is the major problem with the collection
strategy: who pays for counties collecting household hazardous
waste?
There are those who would argue that garbage is a state function,
and we should just raise our garbage rates. I see two problems:
one is that besides the initial cost of a separate collection and
disposal system, the state assumes liability when we send
hazardous material to a hazardous waste site. Both costs are
just too much to assume. Secondly, it is fundamentally unfair to
our citizens who end up paying for the handling of someone else's
very expensive pollution.
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Another way of looking at the economic issue here is this:
government socializes the costs of things we want to encourage.
•
Education is a prime example. If we socialize the cost of
I collecting toxins we only encourage them. Our policies need to
be set to discourage, not encourage them.
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_ So given all that, we passed legislation in 1991 banning
• rechargeable batteries from the waste stream and requiring the
• manufacturers of rechargeables to design and pay for a collection
program which can be reasonably expected to collect 90% of the
• batteries. The date is 1994 but beginning this last spring, the
industry was required to begin pilot programs, each of which can
be reasonably expected to collect 90% of the batteries.
Companies that don't participate can't sell batteries in the
state.
I
The real advantage from a recycling point of view is that
m industry will now have an incentive to recycle its cadmium -
• because it is aggregating it. If our own counties were to'
collect, they could only dispose.
I
Unfortunately, it is the taxpayer and not the user who is paying
| now. If you have ever watched a tax committee struggle with an
issue, you would know that those who scream the loudest are those
who are enjoying a government subsidy and are in danger of losing
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it. In this case it is the product manufacturer not the end user
who is screaming.
I have talked to my constituents many times about this issue.
They firmly believe in the polluter pays principal even when they
are users themselves. As a user they can control the amount of
money they spend; they know it is more difficult to contain the
costs they are paying as a taxpayer.
Thus I believe it is just a matter of time before we tax
polluters in consumer products and those who defend the present
system of subsidizing those who pollute are doing so at their
political risk.
-END-
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Why Household Hazardous Waste Management
is Needed
by
David V. Galvin
Senior Water Quality Planner
Municipality of Metropolitan Seattle (Metro)
Seattle, Washington
Why worry about the disposal of hazardous household
products? Anyone who has worked at an HHW collection
probably has some answer to that question, based on the
sheer quantities, variety and age of items that get turned
in when people are given the opportunity.
People use a lot of hazardous consumer products and often
misuse them, as the three examples in Figure 1 show. When
old or unwanted amounts are thrown away, they retain their
hazardous characteristics and can pose problems in the waste
stream and in the environment.
I would like to briefly review potential problems or areas
of concern resulting from the improper handling of household
hazardous wastes, following the outline in Table 1.
*• Municipal Solid Waste!
Americans produce about 160 million tons of solid waste per
year, of which ten percent is recycled, ten percent is
incinerated and 80 percent (130 million tons) is landfilled
(EPA, 1989). Those quantities figure out to be 1300 pounds
per person per year or 3.5 pounds per person per day; 3500
pounds or 1.7 tons per household per year. That's a lot of
garbage.
Amidst the paper, orange rinds, glass and cans, how much is
hazardous? Various solid waste sorts have all tended to
find that 0.3 to 0.5 percent by weight of municipal solid
waste is identifiable items that can be labeled household
hazardous wastes (see Cal Recovery Systems, 1985; Rathje et
al., 1987). The Seattle-King County area has settled on a
figure of 0.33 percent for planning purposes (Local
Hazardous Waste Management Plan for Seattle-King County,
1989). Dana Duxbury, in a recent Waste Age article
(Duxbury, 1989), uses a figure of 0.5 percent as a national
average. What is the significance of a level of 1/3 to 1/2
of 1 percent in municipal solid waste? This is subject to
plenty of dispute or difference of interpretation. The EPA-
funded study in Marin County, CA, and New Orleans, LA,
(Rathje et al., 1987) "concluded, "There are significant
amounts of hazardous wastes in household garbage, and even
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the most conservative estimates of the amount discarded for
a large community are substantial.... It represents a
significant quantity...."
So why worry?
a. Worker injuries. Municipal or private workers who
pick up household rubbish are exposed to a variety of things
when they dump the containers into their trucks or deal with
the refuse at transfer stations or landfills. There have
been a number of incidents of injuries to workers, but no.
national statistics are kept, to my knowledge. A California
study in 1982 found that three percent of all refuse
collection workers in the state were injured due to contact
with HHW mixed in with trash and garbage.
b. Ecruipment damage. Garbage trucks, shredders and
other solid waste handling equipment have been damaged from
explosions and fires resulting from the chemistry in
household t.rash. Again, national statistics are scarce, but
numerous incidents have been reported, including at
virtually every operation that involves a shredder (Popp et
al., 1985).
c* Landfills. Eighty percent of America's municipal
solid waste is landfilled. EPA's Subtitle D .report (EPA,
1986a) concluded that:
-.more than half of all active landfills in the
U.S. are municipal;
- less than half of these municipal landfills have
runon/runoff controls;
* - only 1/4 of municipal landfills have groundwater
monitoring systems;
- only 15 percent of municipal landfills have
liners, either clay soil or synthetic; and
- only 5 percent of municipal landfills have
leachate collection systems.
Twenty percent of all National Priority List ("Superfund")
sites are old municipal landfills.
Leachate from landfills can be contaminated with HHW
chemicals. A number of studies have well documented
hazardous metals and organic chemicals in municipal
leachate, even those far from industrial sources (see Dunlap
et al., 1977; Sabel and Clark, 1984). These and related
studies implicate consumer products as sources of these
contaminants.
Municipal landfills have also been found to produce
hazardous air emissions, including vinyl chloride, a known
human carcinogen, at levels violating health standards (Wood
and Porter, 1986; Battelle Pacific Northwest Labs, 1987).
The source of vinyl chloride appears to be bacterial action
on chlorinated solvents such as TCE within the landfill.
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d. Incineration/resource recovery. Up. to ten percent
of municipal solid waste is now burned. Concerns have been
expressed about the dioxins and furans that are produced in
incineration. Major concerns related to HHW involve heavy
metals, especially mercury up the stack and lead and cadmium
in the ash. The dominant source of these metals in
municipal solid waste is household and automobile batteries
(Franklin Associates, 1989). At the Danish hazardous waste
incinerator in Kommunekemi, every drum of HHW is opened and
inspected to remove all batteries and other potential
mercury sources. If this is done at a hazardous waste
incinerator with state of the art controls, what should we
expect at municipal incinerators?
II. Domestic Wastevaters:
The advent of keeping human wastes from being tossed out the
window and instead carrying them away with water was a great
public health benefit — at least at first. However,-today
domestic wastewaters carry more than just human wastes;
many modern consumer products-are either designed to go down
the drain or, because they are liquid, get disposed down the
drain. Domestic wastewater consists of 99.9 percent water
by weight and only 0.02 - 0.03 percent suspended solids,
plus even less of other things. However, that doesn't mean
sewage is sgueeky clean. Relatively small concentrations of
chemicals can be quite significant in the liquid waste
stream.
A number of studies have documented heavy metals and organic
chemicals in domestic wastewaters (see Levins et al., 1979;
Gurnham et al., 1979; EPA, 1982; Cooley et al., 1984; EPA,
1986b). These chemicals include cadmium, lead, mercury,
nickel and other metals, plus solvents, paint thinners and
degreasers such as tri- and tetrachloroethylene, methylene
chloride, benzene, and toluene, pesticides such as DDT and
lindane, and plastic components known as phthalate esters.
So why worry?
a. On—site systems — septic tanks and drain fields.
About one-third of all U.S. housing units use septic tanks,
cesspool or other forms of on-site wastewater disposal.
Human, organic wastes can be decomposed in these systems,
with soil used as a final filter , but they are not designed
to handle hazardous chemicals. On-site systems are
concentrated in the U.S. Northeast, with lesser
concentrations in Florida, southern California and the
Northwest.
Studies have found organic chemicals passing right through
septic tanks and drainfields into groundwater (Tomson et
al., 1983; DeWalle et al., 1985; Kolega et al., 1985;
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Kolega, 1989). An EPA study ("EPA, 1984) concluded, "Only 40
percent of existing septic tank systems function
properly....[O]f^all groundwater pollution sources, septic
tank systems and cesspools rank highest in total volume of
wastewater discharged directly to soils overlying
groundwater and they are the most frequently reported
sources of contamination."
•*•
^*.-
*; b. Municipal sewerage systems. Publicly-owned sewage
treatment systems often have industries and commercial^
businesses plumbed into them, but usually their predominant
customers are households. Sewerage systems employ at a
minimum primary treatment, which relies on gravity settling
of solids, and usually secondary treatment, which uses
bacteria to further break down organic materials; some
systems also have tertiary or advanced treatment to remove
specific problems such as nutrients. None of these treatment
processes were designed specifically for hazardous
chemicals. Some do in fact "treat" certain hazardous
chemicals, but do so for the most part by shifting them into
another medium such as air or solids. . .
All studies that have looked at contributions of chemicals'
into municipal 'sewerage systems have documented residential
sources of heavy metals and organics (see previous
references). Relative contributions will vary .a lot
depending on the mix of industries and businesses in the
sewerage area, but all systems receive major input from
households and can't afford to ignore these sources to keep
effluent quality and sludge quality high. While most
effects are cumulative from many small sources, it doesn't
take much of some things to cause real havoc to a sewage
treatment plant. For example, a pint jar of mercury was
turned in at one of the Seattle area HHW Round-Ups. If this
single household's accumulation had instead been dumped down
the drain, it would have contaminated our whole system,
causing violations of effluent limits and contaminating
sludge, even in Seattle's largest, 125-million-gallons-per-
day plant.
III. Other Avenues to the Environment;
a. Storm drains. Urban runoff carries lots of junk off
road surfaces into local rivers, lakes or bays. But people
also tend to dump all kinds of things down catch basins,
gutters or street drains — out of sight is out of mind.
This is an especially common avenue for used motor oil and
antifreeze, but also for such things as pesticides, car wash
water, gasoline, brake fluid, paint rinse water, masonry
acid rinses and just about every other liquid waste from an
outdoor activity. Explosions have occurred, in drain pipes,
usually from gasoline dumping. Fish kills and water
pollution are the more common result, since most storm
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drains discharge directly into the nearest body of water
without any treatment.
b. Holes in the around. Similar to storm drain
dumping, many HHWs are simply disposed on or in the ground.
Used motor oil, old, liquid pesticides and paints are
commonly handled this way, with resulting opportunities for
the wastes to be washed through the soil directly into
groundwater. This practice coupled with the vulnerability
of its groundwater was one of the driving concerns which
resulted in establishment of Florida's HHW Amnesty Days
program.
IV. Long-term Storage:
As we all know, many products sit on the shelves for years
or even decades. Any HHW collection well illustrates this
point. Why worry?
a. Poisonings. Safety in the home, especially for
young children, is a reason for concern about stockpiles of
hazardous products, especially old, often more dangerous
items. Twenty-five percent of Seattle Poison Center's calls
and 30 percent of Minnesota's poison calls relate to
hazardous products.
b. Indoor air pollution. Recent studies have concluded
that indoor household air is often much more contaminated
than ambient outdoor air. While there are many reasons for
this and many sources of the various indoor air pollutants,
hazardous consumer products are an identified source for
organic chemical vapors and other contaminants.
c. Fires. Fire safety is an additional reason for
concern. Spontaneous fires have been traced back to old
products such as volatile solvents, old gasoline and exotic
chemicals such as picric acid being stored in homes.
Firefighters are becoming increasingly aware of and
concerned about their exposure to fumes in the event of a
fire. Previously this concern was limited to industrial
fires, but increasingly it reflects awareness of the myriad
of chemicals stored in the average house.
Summary;
Why are household hazardous waste management programs
needed? There is a lot of HHW out there and it can cause
human safety concerns as well as environmental concerns. It
is becomming increasingly accepted that it would be a whole
lot better to manage HHW separately from the regular
municipal waste streams. Programs are needed that will
manage HHW safely and properly in order to minimize actual
and potential problems from the current mismanagement of
HHW.
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References;
Cal Recovery Systems, Inc. 1985. Characterization and
Impacts of Non-regulated Hazardous Wastes in Municipal Solid
Waste of King County. Seattle WA: Puget Sound Council of
Governments.
Cooley et al. 1984. Toxicant Pretreatment Planning Study
Technical Report A2: Collection System Evaluation. Seattle,
WA: Metro.
DeWalle et al. 1985., Determination of Toxic Chemicals in
Effluent from Household Septic Tanks. Cincinnati, Ohio:
U.S. EPA 1600/2-85-050 [NTIS #PB85-196798].
Dunlap et al. 1977. "Isolation and identification of organic
contaminants in ground water." Pp. 453-477 in
Identification and Analysis of Organic Pollutants in Water,
L. Keith (ed.), Ann Arbor, MI: Ann Arbor Science.
Duxbury. 1989. "A look at HHW management trends." Waste
Age, October, 1989, pp. 80-86.
EPA. 1982. Fate of Priority Pollutants in Publicly Owned
Treatment Works, Final Report. Washington, D.C.: U.S. EPA
1440/1-82-303.
EPA. 1984. Evaluation of Septic Tank System Effects on
Ground Water Quality. Ada, Oklahoma: U.S. EPA #600/2-84-
107r.
EPA. 1986a. Subtitle D Study, Phase I Report. Washington,
D.C.: U.S. EPA 153O-SW-86-054.
EPA. 1986b. Report to Congress on the Discharge of Hazardous
Wastes to Publicly Owned Treatment Works ("The Domestic
Sewage Study"). Washington, D.C.: U.S. EPA #530-SW-86-004
[NTIS #PB86-184017],
EPA. 1989. The Solid Waste Dilemma: An Agenda for Action.
Washington, D.C.: U.S. EPA #530-SW-89-oi9.
Franklin Associates, Ltd. 1989. Characterization of Products
Containing Lead and Cadmium in Municipal Solid Waste in the
United states, 1970 to 2000. Prairie Village, Kansas:
Franklin Associates (for U.S. EPA).
Gurnham et al. 1979. Control of Heavy Metal Content of
Municipal Wastewater Sludges. Washington, D.C.: National
Science Foundation.
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Kolega. 1989. "Impact of Toxic Chemicals to Ground Water."
Paper presented at the Sixth Northwest On-Site Wastewater
Treatment Short Course, University of Washington, Seattle,
September 19, 1989.
Kolega et al. 1985. Contribution of Toxic Chemicals to
Groundwater for Domestic On-Site Sewage Disposal Systems.
Storrs, CT: Connecticut Institute of Water Resources,
Levins et al. 1979. Sources of Toxic Pollutants Found in .
Influents to Sewage Treatment Plants (6 Vols.). Cincinnati,
Ohio: U.S. EPA #440/4-81.
Local Hazardous Waste Management Plan for Seattle-King
County. 1989. Seattle WA: King County, Metro, city of
Seattle and Seattle-King County Department of Public Health.
Popp et al. 1985. Decision-making in Local Government: the.
Resource Recovery Alternative. Lancaster, PA: Technomic.
Rathje et al. 1987. A Characterization of Hazardous
Household Wastes in Marin County, California, and New
Orleans, Louisiana. Las Vegas, NV: U.S. EPA.
Sabel and Clark. 1984. "Volatile organic compounds as
indicators of municipal solid waste leachate contamination."
Waste Management and Research 2: 119-130.
Tomson et al. 1983. Characterization of Soil Disposal
Leachates. Cincinnati, Ohio: U.S. EPA.
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Environmental Protection Agency
Household Hazardous Waste Conference
Minneapolis, Minnesota - December 8-12, 1992
Speech Presented by:
Suzanna Rutnon - Household Hazardous Waste Specialist
Laidlaw Environmental Services, N.E.
North Andover, Massachusetts
Getting organized:
In getting organized, there are as many different types of organizational outlines as
there are projects. We're going to outline the general methods of organizing Household
Hazardous Waste Management Programs (HHWMP's) that will best suit your needs and help
you avoid many of the pit-falls which we have been identified by the other speakers this
morning.
This discussion will assume that siting, liability and insurance issues have been
resolved. This assumption is not meant to imply that these are not serious issues, but rather to
indicate that the commitment to deal successfully with these musfot guaranteed by the top
level decision makers before\h& public commitment of any valuable time or money.
Once it has been decided that siting and liability issues can be resolved, then you can raise
the expectations of the public.
Two things to keep in mind as you run into your own roadblocks doing this first phase:
1) PERSEVERE!!! YOU ARE DOING THE RIGHT THING!
2) DO YOUR FOOTWORK
Starting out:
The most important first step is to set goals! We can assume that the overall goal is to
implement a comprehensive HHWMP program. For those who have never done collections,
participation in "One-Days" or pilot "permanent" programs will demonstrate that there is a
siting demand for these programs. The demand will show that permanent collection programs
are an essential component of integrated waste management.
For those who have years of experience with one-days, our goal will be to open a
permanent collection center. This means data collection and a lot of work with local, regional
and State regulators. This is the work that I want to talk to you about today.
After the goals have been determined, you must garner support for these goals. All
successful public service programs start with the pubic; usually there is a great deal of
grassroots pressure that goes into getting a municipal or regional government motivated to
become involved with hazardous waste. Often, this means that groups like the League of
Women Voters, Conservation Commission, or Recycling Committee have been communicating
with the relevant elected official or Solid Waste Manager/Public Works Chief or Health Dept.
for several years.
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In areas where permanent management programs are being pursued, one-day
collections will often been institutionalized for many years. In either case, the primary issue is
to set up clear lines of COMMUNICATION.
Communication works best if there is ONE contact person. Once this "Point Person"
(HazWaste Coordinator) has been identified, it is important to let everyone know who that
person is and what his/her responsibilities are. The HazWaste Coordinator has the
responsibility for bringing people to (he table and to making sure that all the details have been
addressed.
Who do you need at this decision making table?
1. Regulators- Fire Marshall, Health Department, Building inspector
2) Opinion Leaders (Environmental/Non-Profit) - Button Pushers, activists
3) Political Leaders - not necessarily only Chief Elected Officials
4) Facility Neighbors - anyone affected by the siting of a HHW site
5} Employees - Both contractor and organizer
6) Customers - Those who will use the facility
7) Local Media - Environment or local beat reporters
8) Local Businesses - Hardware stores, grocery stores, etc.*
Once lines of communication have been established, start using them! This often means
setting up regularly scheduled meetings with representatives from the various organizations
whose support is needed to reach your goals. Monthly meetings of this HHWP committee will
be more productive if clearly defined group goals as well as specific tasks for individuals are
identified on a monthly basis.
It is important that some guidelines be established which delegate decision making
power and guidance responsibilities. For example, the Chief Elected Officials (CEOs) will
almost always have final approval if the programs are funded through public monies. The
CEOs representatives, who attend the-regularly scheduled meetings, may take responsibility
for assisting the operators and program organizers in making decisions identifying how
designated funds can be used for non-operational aspects of the program, i.e. education and
volunteer coordination.
Most often. CEO's can't spend a lot of time on the project. This may not be the case
for small communities, but is virtually always true. Since many committee members will be
volunteers from the ranks of municipal employees and have other jobs, it is important to
carefully decide tasks.
You will want to make releases, generic articles for local papers and trade publications
as well as environmental or non-profit news letters. As long as the HazWaste Coordinator is
the contact who gels all the information and draft releases.
* Generally speaking, large chain stores are not willing to commit the time or energy needed lo
reach customers to tell them that products that they may be buying need special disposal
methods and that they should consider not buying the products or purchasing less/non toxic
alternatives. Smaller, locally owned businesses tend to support these programs in a much
more substantial way because they are long-term members of the community. ,.
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There should be a message that the program is being set up to reduce the hazardous
constituent of the solid waste stream and help residents (and if your program has advanced lo
this stage, small businesses) handle their hazardous waste in a way that will protect the
environment. It is hard for those of use here to understand, but it is true that the general public,
as well as many solid waste professionals in the Waste to Energy Incineration business, still
fight the concept of integrated waste management including the separation of hazardous wastes
from the municipal solid waste stream. Knowing this - you must do the footwork here - by
getting all your ducks in order before going to the general public with the plan to implement a
household hazardous collection program. Nothing can do more damage to this important pro-
environment program than to have a Sierra Club representative or the leader of a local
environmental coalition being quoted as saying that there should be "no hazardous waste dump
allowed".
Some of the principle concepts that should be used to marked the HazWaste Collection
program concept need to be clearly verbalized by every member of the Household Hazardous
Waste Planning Committee.
1) Working to protect the environment and remove hazardous products and remove
hazardous products from the waste stream and residential homes. .Make solid waste
collection and disposal safer and cleaner.
2) Working to educate the public to reduce their dependence of Household Products.
3) Program will meet or surpass the regulatory demands placed on industrial or
commercial waste collection programs: Safely Operated
4) The program will become a part of the way people handle their household
hazardous waste each day.
In closing: Keep a record of what you do and who helps you - thank them and
celebrate your success. Reinforce your program each operating season by thanking all of those
who helped you reach your goals and asking them how to improve their program for the next
operating season.
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"HOME STORAGE SURVEY"
Michael T. Bender — Central Vermont Regional Planning Commission
While developing an unregulated hazardous waste management plan, Central Vermont Regional
Planning Commission (CVRPC) initiated a "Home Storage Survey" in December of 1991 to determine
the types and amounts of household hazardous products found in Vermont homes and quantities of
household hazardous waste (HHW) likely to need disposal. The study's overall purpose was to develop
household generation coefficients that could be used by CVRPC and others, including the State of
Vermont and perhaps other states, to project HHW management program costs.
CVRPC contracted with Catamount Consulting Group, Inc. to perform the study. The study was
co-sponsored by the National Paint and Coatings Association, the Portable Rechargeable Battery
Association, the Massachusetts Paint Council and Sherwin-Williams Paints and funded, in pan, by the
State of Vermont. Technical assistance was provided by the study cosponsors, and the American
Petroleum Institute. In some cases, the cosponsors also provided specific product definitions or examples
of specific products in order to assist surveyors in more accurately identifying specific categories of
household hazardous products and wastes.
A total of 501 households were surveyed out of the Vermont population of 210,000 permanent
households with 80% homeowners and 20% renters. Selection of households was based on the 1990 U.S.
Census. Representative surveys were taken to reflect the following size towns: less than 2,500 (32%);
between 2,500 and 5,000 (26%); between 5,000 and 10,000 (18%) and greater man 10,000 (24%).
About two-thirds of the households contacted by the surveyors agreed to participate in the survey
and were sent a survey questionnaire in advance of the home visit by the surveyor. The duration of the
household surveys ranged from one-half hour to four hours depending upon the level of interest of the
participant and the amount and variety of household hazardous products and wastes that were present.
The survey questionnaire was divided into two sections; data collection of household hazardous
products and wastes, and consumer attitudes. HHW was described in the questionnaire as:
"Many types of products used in the home, workshop, garage, or for hobbies may be
toxic, ignitable, corrosive, or may react with other materials to create a hazard. When
these products are thrown away, they may become household hazardous waste."
Data survey questions were divided into five categories of HHW; vehicle maintenance, paint and
paint products, dry cell batteries, and general household products which comprised the rest Consumer
questions attempted to gauge the following:
1) support for a disposal fee at point of purchase; and
2) die amount participants would be willing to pay.
Almost everyone surveyed was cooperative in providing the requested infonnatioa This may be
attributed, in part, to participants interest in winning one often $100 cash prizes (furnished by the national
manufacturers and associations) awarded after the survey was completed. Many households also expressed
interest in becoming more aware of what household products are hazardous, and how and where to
properly manage and dispose of HHW.
RESULTS
What follows are the highlights of the study findings. Overall, the results indicate mat
Vermonters generate less HHW than previous estimates. In most of the larger quantity HHW categories
(i.e. paint, oil, batteries), households in Vermont generate substantially less than indicated in other national
or state estimates.
Data Collection
Although the average Vermont household buys as much paint as the national average, households
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in Vermont appear to have less paint left over. Survey results indicate that Vermonters annually generate
around 3 pounds of waste paint compared to the Vermont Waste Paint Report estimate of 10 pounds and
other State study estimates ranging from 7 to 15 pounds or more of waste paint per household per year.
Results also indicate that, on average, Vermont households have an average of 3.6 gallons of paint in
storage for 4.6 years with over 70% of the paint in storage being latex.
Under the vehicle maintenance category, the survey indicates that the average Vermont household
annually generates 2 gallons of used oil and 2.4 oil filters, which is consistent with national estimates.
While die national estimates for those who change their own oil is around 50%, the survey results found
that only about 30% of Vermont households changed their own oil. Of those surveyed, 31% have lead acid
batteries currently in storage. In addition, the study found that around 120,000 vehicle maintenance
products found in household storage are likely to be disposed before they are emptied.
Vermont households purchase 16 dry cell batteries each year or 30% less than national estimates.
About 80% of the batteries found in Vermont households are alkalines, 13% are button batteries, 3% are
rechargeables and less than 1% are lithium batteries. Survey results also found that the average household
contains more than 2 but less than 3 appliances with rechargeable batteries. Power tools accounted for one-
quarter of rechargeable battery uses, while flashlights were one-fifth and telephones and electric razors
comprised one-eighth of the rechargeable battery powered uses.
Almost all of the households (89%) surveyed had pesticides in storage. Of the those surveyed,
63% indicated that they had household pesticides, 34% had yard pesticides, 35% had garden pesticides,
and 11% had pesticides for other uses. Results of the survey estimate that over 1 million containers of
pesticides are present in Vermont homes or an average of 4.3 containers of pesticides per household.
Rounding out the list of HHW categories, general household products was made up of a wide
variety of home maintenance and use items ranging from cleansers and polishes to disinfectants and spent
fluorescent lights; and are too numerous to mention here. One noteworthy result was that 97% of the
households surveyed had fluorescent lights in their homes. On average, there are over 3 million general
product containers in Vermont homes.
Consumer Attitudes
The majority of those surveyed expressed an interest in participating in BMW collection programs
and a willingness to pay at point of purchase for the costs of proper management and disposal. Nearly half
of those surveyed would be willing to pay a fee on the purchase of batteries to provide for proper
management while over 60% supported a deposit refund system or a curbside program for the collection
of dry cell batteries.
Of the survey respondents, 70% indicated that they would support a fee of $.50 per gallon to pay
for the proper management of paint Over 70% would also be willing to participate in a deposit/return
system to cover the costs of a paint management program. Almost 50% of those survey also supported
a deposit/refund system to support the cost of a used oil management program.
CONCLUSION
Survey results indicate that although Vermont households have large quantities of household
hazardous products and waste in storage, Vermonters generally appear to purchase and have less in storage
than national or state estimates. Many of those surveyed expressed an interest in properly managing their
HHW. Almost one-quarter have already participated in at least one paint drop and swap program.
A large percentage also appeared willing to pay a fee or deposit to fund a HHW management
program. Although difficult to enact, advanced disposal fees or deposit/refund systems may be necessary
to cover costs of more aggressive and comprehensive HHW management programs in the future.
To receive a copy of the study, "Household Hazardous Waste: A Vermont Perspective," mail your
request and $5.00 to CVRPC, 26 State St., Montpelier, VT. 05602.
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SCREENING CONSUMER PRODUCTS FOR INDOOR AIR RISKS
James F. Darr, Christina A. Cinalli, Pauline K. Johnston, Ph.D.
U.S. Environmental Protection Agency, Washington, D.C.
BACKGROUND AND PURPOSE
The U.S. Environmental Protection Agency has identified indoor air as a major pathway of
human exposure to numerous chemicals. The Office of Pollution Prevention and Toxics (OPPT) at
EPA is engaged in two major projects to screen indoor air risks:
1) The Indoor Air Cluster makes use of existing data on product composition and emission
rates in order to do screening-level risk assessments on various product categories. The
products being evaluated in the project are primarily household consumer products.
2) The Indoor Air Source Characterization Project (IASCP) is a long-term data development effort
by OPPT, the Office of Air and Radiation, and the Office of Research and Development that will
attempt to better define the exposures and risks encountered in indoor air. The IASCP will
evaluate building materials, furnishings, and equipment as well as consumer products.
The overall goal of both projects is to set priorities for subsequent actions in the areas of testing,
pollution prevention and risk management
INDOOR AIR SOURCE CHARACTERIZATION PROJECT
A major component of the IASCP is the development of a "Source Ranking Database." The
purpose of the Source Ranking Database is to provide a mechanism for systematically reviewing a large
number of potential indoor air sources and assigning priorities for further evaluation. The basic elements
of the database will include:
• A product categorization scheme
• Exposure-related data such as:
— Quantities used — Populations exposed
• Hazard information such as:
Duration and frequency of exposure
— Qualitative judgments on effects of concern
— Benchmark values like reference doses, unit risks, irritant levels
• An approach for combining hazard and exposure elements to arrive at an overall ranking for the
product categories.
Database rankings focus OR product categories as the unit of primary interest Product categories
that rank high will undergo further assessment to characterize risks and to define important data gaps. The
theme of this approach is that the identification of risks involving common use and exposure patterns win
allow EPA to make decisions on entire groups of chemicals and products that share common concerns.
The first product category selected for evaluation in the IASCP is "interior architectural coatings."
This category was selected by professional judgment rather than through the Source Ranking Database,
which is still under development There was strong consensus among EPA staff and management that
interior architectural coatings are an important category for evaluation because of their frequency and
volume of use in indoor environments and their inherent exposure potential as a "wet source."
Because of the lASCP's orientation toward data development, assessment of current analytical
methods is a key component of the project EPA has conducted an initial evaluation of test methods that
could be used to assess emissions from interior architectural coatings. Methods for both total volatiles
and specific volatiles were reviewed. The initial study assessed seven analytical methods by evaluating
each method's performance in the analysis of one latex paint and one alkyd paint. The seven methods
are listed below:
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• ASTM methods for volatiles and water
• Gravimetric method developed by Research Triangle Institute
* Direct analysis by gas chromatography/mass spectrometry
• Purge and trap method
• Static headspace method
• Small jar dynamic headspace method
• Small chamber dynamic emissions method
Considerations of accuracy, versatility, cost, and the utility of the resultant data point toward three
methods for further evaluation the ASTM method for volatiles, direct analysis, and the small chamber
method.
AEROSOL SPRAY PAINT CLUSTER
Aerosol spray paints were selected for review from the Indoor Air Cluster because of the inherent
exposure potential associated with such products and because sufficient data were available to support a
screening-level risk assessment. The scope of OPPT's assessment was limited to single-use pressurized
cans. Other spray painting operations, such as the use of an air compressor to aerosolize paint, were not
included in the assessment.
A market study conducted by OPPT estimated that 136 million pounds of spray paint were
produced by over 30 U.S. manufacturers in 1990. Aerosol spray paints consist of four major components:
1) binders (usually alkyd resins)
2) colorants (inorganic and organic pigments)
3) solvents (usually aliphatic and aromatic hydrocarbons, chlorinated hydrocarbons)
4) propellants (usually butane or isobutane)
The market study identified over 80 chemicals and chemical classes that are commonly used in
spray paints.
HAZARD SCREENING
Readily available toxicity data were compiled whenever possible and all well-defined chemicals
were reviewed by lexicologists on OPPT's Structure-Activity Team (SAT). The SAT assigned a "high,
medium, low" level of concern to each chemical based on available data, known structure-activity
relationships, and professional judgment. The toxicologic endpoints considered by the SAT included acute
and chronic toxicity (target organ effects), oncogenicity, mutagenicity, neurotoxicity, and irritancy.
Absorption by all routes of exposure was also considered. The SAT rated 16 chemicals as being of
moderate to high concern. Quantitative indicators of toxicity in the form of cancer potency values (oral
slope factors1 or inhalation unit risk3) were available for five chemicals; Reference Doses or Reference
Concentrations were available for 14 chemicals, nine of which are moderate or high concern chemicals.
EPA defines a Reference Dose as "an estimate (with uncertainty spanning perhaps an order of magnitude)
of a daily exposure to the human population (including sensitive subgroups) that is likely to be without
appreciable risk of deleterious effects during a lifetime." It is expressed as a mg/kg/day dose. A
Reference Concentration is a comparable value for inhalation exposures, expressed in mg/m3.
EXPOSURE AND RISK SCREENING
Exposures were estimated for both occupational and consumer settings. The exposure assessment
included the following routes: 1) inhalation of vapor components such as solvents and propellants, 2)
inhalation of paint solids and resins such as colorants and binders, 3) dermal exposure to paint solids and
lin terms of lifetime risk per mg/kg/day lifetime average
daily dose
2lifetime risk per Jig/m3 lifetime inhalation exposure
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other non-volatile components through incidental contact
The study estimated that about one million U.S. workers in eight industry sectors are routinely
exposed to aerosol spray paints. Ranges of exposure were developed by categorizing workers into five
groups according to estimated usage. The highest estimated usage was two cans per day and the lowest
was one can per four months. Both short- and long-term exposures were estimated: 24-hour dose, average
daily dose (ADD) during a 40-yr working lifetime, and lifetime (70-yr) average daily dose (LADD).
Similarly, central tendency (mean or median) and high end (>90* percentile) levels were estimated
for consumer exposures. These estimates were developed by constructing scenarios in which major input
parameters vary. The variables included: inhalation rate, exposure frequency and duration, quantity of pro-
duct used per event, percent of time event takes place indoors, time spent in room after event Four scen-
arios were used in estimating central tendency exposures, another four in estimating high end exposures.
Carcinogenic risks were evaluated by estimating upper-bound individual lifetime risks. Because
data were not available to enumerate persons exposed in each exposure group, population risks could not
be estimated. Non-carcinogens were evaluated by calculating a "hazard index," which is the ratio of the
ADD or LADD to a RfD or RfC. A hazard index value greater than one is assumed to present a potential
concern. Hazard index values below one are assumed to represent minimal concern. Consideration of
risks from both cancer and other chronic effects led to the identification of the following chemicals as
presenting a relatively high concern: methylene chloride, diethylene glycol dimethyl ether, toluene,
propylene oxide, hexane, ethylene glycol dimethyl ether, cadmium orange/red lithopone, lead molybdate,
lead sulfate, lead chromate, molybdate orange, and chromium lead molybdate oxide. Risk estimates for
some of these chemicals are shown in the table below.
Preliminary Risk Estimates
Chemical
methylene chloride
Cd orange/red lithopone
CrPbMo oxide
Toluene
Hexane
Hazard quotient
Occ. range
0.25 - 40
0.28 - 44
84 - 13500
70 - 11000
Consumer high end
0.21 - 0.56
0.46 - 1.3
70 - 191
58- 160
Upper bound cancer risk
Occ. range
1E-05-
2E-03
6E-04-
8E-02
4E-03-
5E-01
•
Consumer
high end
2E-05-
6E-05
1E-03 - .
4E-03
1E-02-
3E-Q2
LIMITATIONS
The exposure and risk estimates described above should be regarded as only rough, screening-level estimates because of
many uncertainties and limitations in both the data itself and the models employed. Most of the product composition data
are several years old and it is not known if these data are representative of today's market Furthermore, there are
significant differences in accuracy in chemical concentration data for different chemicals and among the different data
sources used in this assessment. The exposure modeling relied heavily on extrapolations from generic data and
assumptions based on professional judgment
CONCLUSIONS
Exposure and risk estimates should be refined for the highest concern chemicals and products within the aerosol •
spray paint cluster. Source reduction options should then be identified and evaluated for high concern product categories. I
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Recycled Paint Collection Methods
Carolyn Dann — Waste Watch Center
Paint collection can be accomplished through a variety of methods. I will be reviewing methods currently
in use by programs around the country, such as:
Re-Use Areas/Drop & Swaps
HHW Program Collections
• Specialty Collections, such as "Recyclables Only" or Paint Only Collections
Retail Store Collection and
• Curbside Collection.
Each of these approaches makes sense under certain circumstances and to determine which makes the best
sense for any program we must also look at the recycling method to be used and the end markets to be
targeted for the recycled paint. The variety of approaches to paint recycling is as great or greater than the
variety of collection methods. Paint "recycling" can mean the paint is:
• given away as is, in its original container,
• consolidated and sometimes filtered and stirred and even sorted by shades by the HHW
program for giving away in bulk;
• reworked by a paint manufacturer who takes drums of consolidated paint, filters, tests, and
repackages;
• blended with wash water from manufacturing virgin paint, as part of a waste minimization
effort, to make a low-quality graffiti abatement paint;
• consolidated by the HHW programs and blended with virgin materials by a paint
manufacturer to produce higher quality, greater variety of colors and textures (fiat, semi-
gloss, and primer);
• taken in individual containers to the manufacturer where they consolidate as required for
their batches and rework, if necessary;
• removing solvents and liquids from solvent-based paint (SBP) and/or latex paint (LP) and
burning the solids in a rotary kiln to purify the solids into an ash that can be used in the
manufacture of paint;
* sent for use as a supplemental fuel, a fuel in a cement kiln, or other energy recovery
process.
Each of these methods is likely to produce different types or qualities of recycled paint. The "drop &
swap" paint may be high quality, assuming the original paint was high quality, but it is often available
in limited quantities. Paint bulked by collection programs is a mix of high and lower quality paints and
can produce larger quantities of paint but of lower quality. The paint mixed with wash water is probably
the lowest quality paint discussed here but is appropriate for graffiti abatement, especially in an area that
needs frequent repainting. The paint taken and reworked by a paint manufacturer will be higher quality
than if it were just consolidated by the collection program. The degree of effort and amount of virgin
materials put into the recycled paint will determine its final quality, price, and potential markets. The
judgement of the manufacturer is important in determining the right level of reworking. Manufacturers
that are willing to take individual cans and do their own consolidation can control the quality the most
accurately and create products tailored to specific uses. Scott Herbert will speak more about that in his
presentation. Most of the recycling done to date has involved LP, not SBP. The SBP has been recycled
via rotary kiln to recover the solids and/or via energy recovery. Philip Morley's study in Seattle
concluded that recycling SBP was technically feasible but that the product of their procedure was a low-
quality SBP. He concluded that for a SBP to sell it had to be of high-quality and therefore did not
recommend recycling SBP through a system such as used in Seattle.
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Many of these programs are being considered at HHW programs throughout the country. We have held
discussions with representatives of the paint industry, which Tracey wiE discuss further, and we found that
two things are vital in discussing paint recycling with paint manufacturers: payment and testing.
We found that many manufacturers were much more interested in talking with us once we mentioned that
HHW programs are currently paying for the service of recycling. Various approaches to sharing the costs
are being used.
• In California (Matin Co.), programs frequently pay $2.50-3.00 per gallon to have a
manufacturer reprocess LP and the community commits to take it back. Sometimes they
(Sacramento Co.) find a manufacturer with a retail outlet who will offer it for sale and
only that which does not sell within 90 days is taken back by the community.
• In Canada, the plan was to have the communities buy the paint back after the
manufacturers had reprocessed it. I have heard mat this has not worked out well for
reasons that are not clear to me but have something to do with the price.
• Some communities pay the manufacturers an additional amount-to market the paints for
them, rather than taking it back themselves. (Marin Co.)
In San Mateo Co., CA, the county pays $2.85/g to have the paint reprocessed but there
is sufficient local demand that there is no extra cost to market it.
In Portland, OR, as part of developing a relationship and a workable system with a paint
manufacturer, the County pays for the testing of the paint, provides it free to a local
manufacturer who then reworks it and sells it to contractors for use in multi-family
housing.
There are several testing and sorting protocols that exist. These are important to manufacturers because
they can provide some assurance that contaminated paint will not be brought into their facility and also
that the recycled paint will be safe for sale. By collecting paint through an HHW program which uses a
strict sorting protocol and tests the paint, manufacturers can be assured that questionable paint is
segregated out and sent for disposal rather than recycling. Testing should include more than enough tests
at the start and can then be cut back as the program and manufacturer and others gain confidence in the
system. Some testing may be done before processing and some may be done after processing to ensure
that the product meets the safety and quality standards. The product testing done on batches of recycled
paint typically includes:
* testing for metals (Pb, Hg, Cr,...)
• Volative Organics Analysis to determine the quantities of benzene, toluene and other
solvents that require specific listing on labels and hazard warnings,
• Ethylene glycol test.
Portland OR has recently been able to drop their ethylene glycol test because they were getting such low
results that they were comfortable that it would not be a problem.
NPCA recommends that testing include:
• metals,
• PCBs, and formaldehyde, and
• bacterial tests.
The need to test incoming paint materials depends upon the collection system and sorting protocol used.
"Use UP" Programs
"Use Up" programs can come in a variety of forms. The most commonly known form is a Drop & Swap
program. This is a temporary program that can either be a part of an HHW collection event or a separate
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event. In either case, the residents usually bring containers of leftover paint and leave it for others to pick
up who want paint Most programs leave the paint in the original containers (as in Vermont). Other
programs do some consolidation of the paint and then make it available to others (as done in Thurston
Co., WA) Vermont supports these programs by making guidelines available for communities interested
in setting up events and the State of Vermont has purchased some equipment used at drop & swaps to be
available for use by the communities. Thurston Co., WA advertised their event in the paper and solicited
users of paint. Through this they developed more demand than they could satisfy.
"Use Up" programs can also become a consistent feature of collection events, as in Marin Co., CA, where
they have a monthly HHW collection event
A third variation of "Use Up" programs is a permanent site for reusable materials. Both Seattle, WA and
San Francisco, CA have set up programs of this sort. In Seattle, WA, there is a community-based center
that rents home repair equipment and tools at a low or minimal cost to residents. To this program they
have added leftover materials, such as roofing materials, paints, lumber, etc. In San Francisco, CA, the
HHW collection facility has a space set aside that is open to the public three days per week where
residents can get usable materials that have been received at the HHW collection program.
Low-Tech Recycling
There are even more variations on this theme than on the Use Up programs. In one case, in Montpelier,
VT, collection of paint takes place at a retail store. The store manager accepts back containers of paint
if it is still liquid, in its original container, and appears uncontaminated. The people bringing back paint
pay a small fee ($1 per gallon) to drop off paint which then can be credited towards the purchase of
recycled paint The manager stores the paint by color range until there is enough to make a five gallon
batch. He then sells the recycled paint.
A more typical low-tech recycling program involves collection through HHW collection programs or
through specialty collections (such as "Recyclables Only Collections; Battery, Oil, and Paint Collections
or BOP Drops; or Paint Only Collections). In these programs the program can either take the individual
containers to the manufacturer (as is done in San Mateo Co., CA and Fresno, CA and in Manchaug, MA
by the Green Paint Co.) or consolidate the paint into 55-gallon drums and deliver it to a manufacturer.
If the program does the consolidation, a sorting protocol is very important Testing and sorting will be
discussed further by George Kinney but the basic sorting involves sorting solvent-based paint (SBP) from
latex paint (LP). They are further sorted into light and dark colors and, for LP, into interior and exterior.
The manufacturer's role can involve a number of additional steps depending on how the paint will be used
or marketed. The manufacturers blend and filter the paint and in one case. Major Paint Co. of CA, they
add their wash water from the production of new paint Sometimes other additives are added to make the
paint meet some minimum standards, then it is tested by batch for metals and VOCs, repackaged into 55-
gallon, 5-gallon, or sometimes 1-gallon containers. The marketing involves either the manufacturer giving
the paint away at the direction of the county, the county taking back the paint, or selling it at a low cost
to non-profits and local governments.
High-Tech Recycling
Collection of paint to be used in "high-tech" recycling can be done through HHW programs, through
specialty collections or by curbside collection. Marin Co, CA just completed a six-month pilot program
testing the efficacy of curbside collection. Their program encouraged residents to put up to five gallons
of either used oil or leftover paint or a combination into a box at the curb that was picked up by the refuse
hauler. They are evaluating the results at this time., but it appears that they had roughly 25% of the
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residents who used the service to collect paint With these collection methods, as above, some programs
send the individual containers directly to the manufacturer and some consolidate the paint themselves.
The manufacturer does the blending, filtering, and upgrading, as required. In some cases, the manufacturer
adds virgin materials to improve the quality of the end-product Frequently, with high-tech recycling, the
manufacturer will tint the batch to produce a greater range of color options. The paint is then repackaged
and marketed. In Marin Co, CA, they have made some paint available to government purchasers through
the GSA. In Portland, OR, the manufacturer sells the paint to contractors. In Sacramento Co., CA, the
County took back the paint except for paint that sold within 90 days through the manufacturer's retail
outlets.
How To Set UP Your Own Program
Based on our review of collection and recycling methods and on discussion with paint industry
representatives, we have some encouraging news. Paint recycling seems to be a viable option in many
areas. In your area, it is important to identify the potential manufacturers who might be interested in
working with you. This can be done by looking primarily for smaller manufacturers and specifically for
those without computerized or automated facilities. Another approach would be to solicit interest through
the American Paint Journal or local trade organization.
Your program will be received best if you have also done some marketing to local government users and
other potential users. The local governments can understand the benefit to them of not paying to treat the
paint as HHW and therefore may be more willing to accept recycled paint, even on an experimental basis.
State and Federal governments will be harder to reach for reason I will discuss in the next Paint Session.-
Potential government users include graffiti abatement groups, multi-family housing associations (wherever
turnover is high and frequent repainting is required), and local government building and maintenance
departments responsible for warehouses, garages, and maintenance facilities. Other users could include
non-profit groups, theater groups, and contractors.
Another important step is to identify to the manufacturers what the potential sorting and testing protocols
are that you are willing to use. This is important in sharing the risks and costs with the manufacturers.
The manufacturers should be able to give some direction on markets they can find and what level of
adjusting is necessary for those markets. Testing costs can run high at first (between $1 and $3 per gallon
depending on batch size) but should be done extensively at first until all parties develop adequate comfort
that the contamination levels are well within acceptable ranges for the products being produced.
If you are interested in setting up a paint recycling program and want more specifics, please call us; we
are happy to help. Thank you.
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PAINT TESTING AND SORTING
George Kinney
Environmental Supervisor, Dakota County, Minnesota
Paint and used oil vie for the title of highest volume waste brought to HHW collec-tion sites. Typically,
each car at a one-day collection event in my county, Dakota County, MN, brought in about 2 gallons of
latex paint and one and one-half gallons of solvent-based. At a 1,000 car collection event, this translates
to over 60 drums of waste paint! This quantity of paint often overwhelms collection organizers, who shy
away from collections rather than ever have to deal with the tremendous quanti-ties involved, and the
staffing required to properly handle the waste.
The ratio between latex and solvent-based waste paints brought to collection events will vary due
to the age of the community and the region of the country. In our area, latex to solvent-based usually
follows a rough 3:2 ratio, until an event collection is held in an old community, in which the ratio may
be reversed. In southern Cali-fomia, most paint is latex.
Collecting the paint gets HHW out of the residences, but then what? Shipping the paint with a
hazardous waste management firm to proper treatment and disposal facilities is expensive due to the large
amounts of waste handled, as well as the per gallon costs.
.The first step in every paint management program is sorting. This is usually done on site,
frequently while the resident is waiting, in order to return empty cans or other solid waste. During the
sorting process, water-based paints are separated from solvent-based, and unacceptable wastes are removed
from either category to be packed separately. These include Penta and other pentachlorophenol-containing
wood preservatives, adhesives and mastics that are typically sold in cans very similar to paint cans, joint
compounds and other non-paint materials. Some collection programs keep certain non-paints, such as
latex grout additives, with the paints. Unacceptable wastes are removed and packed according to
hazardous constituents present.
After sorting, most programs have an on-site exchange program, where very good, nearly full cans
of paint are given away to the general public on an as-is basis. Most programs stir the paint to ensure
its quality before placing for disposal. In some instances, only latex is offered for giveaway, many other
programs include oil-based paints and stains. The paint not placed in the exchange area will be managed
in one of several ways.
Solvent based paints
Solvent-based paints contain hazardous constituents. If generated by a regulated business, these
waste paints would be handled as hazardous waste. In Minnesota, our state rules regulate all collectors
of HHW as hazardous waste generators, and we must follow the state and federal hazardous waste
regulations upon collection. Several other collection programs manage collected HHW as though the
federal regulations apply.
The preferred management method for solvent-based paints in most programs I contacted is fuel
blending. Fuel blending is a process of mixing high BTU-value solvents from a variety of sources to get
a consistent feed mixture for a usable fuel. In our area, waste solvent-based paints, thinners and other
flammable solvents are sent to be used as fuels in lime kilns.
In many programs, and in our Minnesota programs, all oil-based paint is tested for the presence
of PCB's after bulking. PCB's, banned in industrial applications since the 1970's, were used as
plasticizers in several types of solvent-based paint systems. These included marine and swimming pool
paints and industrial paints needing a hard resin finish. The Minnesota experience shows levels of PCB's
in bulked 55-gallon drums ranging from below detection limits to above 300 mg/1 PCB. Ire waste
management firm and hazardous waste facility used by your program will require certain testing
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parameters and frequency. Usually, solvent based paints to be fuel blended undergo a waste profile
initially, consisting of metals testing and analysis for other parameters required under the facility's EPA
permit. , .
Latex paints
After sorting latex paint cans from other paints and non-paints, several successful paint recycling
programs re-sort the paint again. The visual inspection done next by Metro of Portland, San Mateo,
Ondanaga, and others consists of inspecting the can and label for old labels, presence of lead or mercury,
rusty, dented cans, and very old product These cans would be rejected. Next in many programs, the cans
are opened to check for mold, freezing or hardened paint, which would also be rejected. The remaining
paints would be sorted by whatever color sorting schemes in use by the program. Paint may then be
reblended by a variety of means.
SORTING PROTOCOL
HOUSEHOLD HAZARDOUS WASTE
Waste
Type
Old Paint
Exterior Non-White
Latex Paint
Solvent-Based Other
Non-Latex
Red, Orange, Yellows
Sour Paint
Frozen Paint
Solidified Paint or
Excessive Levels of Solid
or Semi-Solid Components
Unknowns and Non-
Paint Items
Recognition
Traits
Label Style
Label Style wording
"Exterior"
Label, Order, Looks
Color
Odor
Looks "Cottage Cheese"
Looks
Odor, Looks
CASE HISTORIES
Reason to
Exclude
Risk of Heavy metals, biological
activity, chemical reactions
Mercury
Contaminant
Heavy Metals
/
Biological Activity
Separated Solids are Out of Suspension
Not Mixable
Contaminants
METRO, Portland
Contact: Jim Quinn (503) 221-1646
METRO has one permanent facility, and is preparing a second. Approximately 230 vehicles/week use the
site, bringing nearly 3 gallons of latex and another 3 gallons of oil-base paint and flammable liquids.
Latex is sorted following the above decision matrix, eliminating old or rusty cans, moldy; hard paints, and
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obvious frozen paint If the age of the labels indicate old paint, it is eliminated, as it may have higher
metals levels. Similarly, paints that'state high lead content are rejected, as are any paints labelled "mildew
resistant". The individual cans are then stirred with a paddle on a drill to check for a smooth creamy
consistency. Lumpy paints are rejected. Only 46% of received material is retained.
The latex cans are then sorted into 6 categories and bulked into 55 gallon drums, passing through
screening to remove paint skins. The colors are interior white, off white, gray, brown, green, and
mushroom. Paint is frequently taken at this point by local nonprofits and governments. The remainder
is given to a local paint manufacturer (free) who finely screens the paint, blends in 300 to 700 gallon
batches, may tint if desired, homogenizes and cans the paints. The paint is sold to contractors, primarily
at this point to paint apartment buildings. To date, 1200 gallons have been sold, with between 4000 and
6000 gallons given away to the nonprofits and governments.
The discarded latex paint is separated into the high Pb and Hg fraction and the bad paint fraction.
The high metals paint is handled as hazardous waste, while the unacceptable paint is solidified and
landfilled. The oil-based paint is separated into the liquid fraction and solids fraction. The liquids are
sent to a fuel-blen-der, and the solids are sent to a Vancouver, B.C. firm that ashes the solids, and sells
the remaining ash (primarily pigments) to a paint manufacturer.
Tucson/Pima County
Contact: Anna Spitz (602) 740-3037
The collection program receives HHW at the main site every Friday and Saturday, with monthly
outreaches - event collections at four other sites. The program usually averages 600-700/month.
Approximately 20-25% of the latex paint must be discarded due to mold or other reasons. The paint is
sorted into four colors; white, pastel, light gray and chocolate brown. It is stirred in the can and is bulked
into 55 gallon drums. It is stirred, and then removed to 5 gallon pails. The paint is given to nonprofit
and neighborhood associations only.
Snohomish County
Contact: Dave Shea (206) 388-6493
Four HHW roundups are done each spring and fall. Latex cans are inspected visually by volunteers or
County work release workers. Paint is discarded if the label may indicate high metals, is old, or is
unreadable. Cans are opened, checked for mold, etc., and stirred by hand to check consistency. Paint is
mixed into 4 gallon pails to a wide variety of colors and gloss. Cans are labelled with specially developed
labels. During 1992, the eight collection events served 7,298 vehicles, with 12,543 gallons of latex
swapped and 2,820 gallons disposed. The unacceptable latex is mixed into "ecology blocks" used as road
barriers and retention walls.
San Mateo County
Contact: Rick Miller (414) 363-4356
The best looking cans of latex paint received at the monthly collections are placed on the free shelving
and given away. The remainder of the usable latex paints are shrink wrapped and shipped to Early
American Paints for processing. The company checks viscosity, pH and adjusts the color of the mixed
product, Navajo White and "dark"(beige, gray or brown). The product is packaged into 5 gallon buckets,
arid is given to non-profits. The County's cost is $2.85/gallon for the remanufacturing of the paint. In
the past two years and 8 months, the program has recycled nearly 30,000 gallons of paint through the free
shelving and processing.
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REPROCESSING PAINT: . A NEW METHOD
M. SCOTT HERBERT
PRESIOENT/H2O COATINGS, INC./THE GREEN PAINT COMPANY
MANCHAUG, MASSACHUSETTS 01526
Imagine opening your morning newspaper to read .that chemical
companies dumped seven million gallons of paint in New
England. What would be the fate of
company officials responsible would
bars. Enormous fines and penalties
Suffice it to say that a problem of
exist.
these companies? The
probabl.y end up behind
would be assessed.
major proportions, would
According to a recent study, the problem does exist. An
estimated seven million gallons of paint are stored in New
England households. What happens when those homeowners
decide to dispose of all this paint?
Unfortunately, consumers don't have too many choices when it,
comes to dealing with these products. They can wait fqr
that four hours a year when a household hazardous waste
collection is held in their community, set the paint out to:
dry, or throw it in the trash. None of th'ese options make
it easy for the homeowner to get rid of old paint. . ,.. --
Household paints fall into two general categories—latex and.
solvent-based. - Latex paint, for the most part,' is -. ,
considered non-hazardous, but regulations and •-•_ •
recommendations for disposal vary by locality. Solvent-based
paint is invariably considered hazardous. In reality,; both
types may contain hazardous ingredients, whether in the
liquid or solid state. Solvent-based paint prior to 1972 .
often contained lead pigments as a primary constituent."' -,.
Latex paints, even the newer ones, may contain, mercury even
when dried. In the liquid state latex paint often contains
ethylene glycols and glycol ethers. • -.,...-
Source reduction is, of course, a necessary part of the.
solution, but source reduction does not get the paint out of
the basements! Paint swaps of one type or another do help, .
but they are very labor intensive and cumbersome. .
Realistically, these kinds of programs can on.ly address a
very small part of the problem. Just try to picture your
Aunt Emma searching through mountains of paint cans for a
moonlight mauve paint to match her living room wall.!
Waste disposal through household hazardous waste collection
days is expensive to the point of being unaffordable to'many
communities. With a response rate of only 1-2%, it.too is
reaching only the very smallest tip of the iceberg. When
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you also consider that disposal Is lower on the EPA
hierarchy, It makes for an even less desirable alternative.
The GREEN PAINT COMPANY Is founded on the•relativaly new
idea of recycling waste paints and stains. We are the only
third-party private company that, to our knowledge, takes a-
comprehensive approach to paint recycling. That, is, we are
looking at the whole picture of collection, reprocessing and
marketing in an comprehensive manner. •
COLLECTION
Let's talk about an integral part of our plan—collection.
The collection method dictates what types and quality of
recycled product we can produce. Most collections are done
by bulking paint at the site of collection. Let's take the.
easiest sorting protocol of all: Put all the latex in one
drum and all the solvent-based in another. The result of
mixing all the colors is a dull gray. The manufacturer gets
the two drums back to the factory and guess what he makes?
Utility gray latex and utility gray solvent-based—two •
products with marginal performance and marginal economic
value.
Let me show you by illustration just how important this
point is. I have here a number of drinks—some fruit juices-
and some milk drinks. Let's say for our purposes that the
milks are latex and the juices are sol vent-based. If we mix
them all together we get one big mess that is -of no., _
marketable value. If we mix all the juices and all the
milks, we may have a product of very low economic value that
someone may want to buy. But if we take all the chocolate
milk or all the chocolate and coffee milk and mix them . •
together, we come up with mocha, a product of relatively
high value. 'That is our objective with paint 'recycl-ing.
We run our paint col lect.ion days just like household
hazardous waste collections—the difference being that,we
col.lect only paint. We send a truck on site with a crew
that collects the paint and removes it from the site the
same day.
Our fee for this service is generally one-third or even one-
fourth of the cost of disposal. We have successfully
experimented with user fees at our collections. Surveys- .
show that consumers are willing to pay reasonable fees for
this kind of service. Given.the current constraints on-
municipal budgets, user fees are the only alternative for
some communities.
Our recycling permit with the Department of Environmental
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Protection requires us to operate within the same parameters
as a hazardous, waste contractor1 when doing a household
hazardous waste collection. The town must file with DEP 30
days prior to the collection date. .It must also submit a
site plan. We are required to retain a spill contractor and
provide the same site precautions as a hazardous waste
contractor. We are also required to report to DEP the
quantities collected from each site. We cover all the
bases.
We are also licensed to accept paint at our factory from any
very small quantity generators. This of course includes
most painting contractors. Our goal is .to arrange to take
their paint regularly and assist them with compliance.' For
an annual fee we will take all of their waste -paint as long
as they remain in the VSQG category and have registered as
such with the Department of Environmental Protection. •
What is unique about our operation is that we bring the
paint back to the factory in the original containers. A.
preliminary sort is done on-site into three basic .
categories:' All latex, oil paints, and oil stains, this •
reduces labor costs and time on-site. ' •,.
From what we have observed we can recycle about 35% of the.-
paints homeowners bring to a collection. We don't accept "
all paints. We have a list of paints and stains we don't,
accept, and among those are paints containing lead, r,or''
stains containing creosote. • . ' • .
REPROCESSING
Back at the factory the paint is further sorted.. .We view _-
sorting as the most critical step of the whole operation.;. :
Obviously we don't want solvent-based paint mixed in with
latex paint and vice-versa, as this could spoil the';entire
batch. As a result we specially trained key.personnel, to
supervise the sorting process. . - ;' '.
\ *
Once the paints are sorted and enough volume is accumulated
we are ready to make a batch. The appropriate containers
are then emptied into our batching tanks. Our final -sort
takes place at this point where we eliminate any defective
paints such as frozen latex.
Some of you might be wondering what happens to-the empty
cans. We recycle them. The steel industry is way ahead of
the paint industry and has been involved in recycling for
quite some time. Some steel mills are more" than happy to
take the empty paint cans as long as they meet their
requirements.
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After the paint is processed, it is tested. Each type of
paint has its own set of specifications. A floor paint, for
example, requires different properties than a wall paint.
Small amounts of virgin material may be added to bring the
paint within our specifications.
When the lab is satisfied that the paint meets quality
specifications, a sample is taken for chemical analysis.
Since we are not using virgin raw material, this is a
necessary step to insure that the final product does not
contain dangerous levels of contamination. Each batch is
tested, at a minimum, for heavy metals such as lead,
mercury, and chromium. Solvent-based paints are also tested
for PCBs and toxic solvents. This testing exceeds the types
'of testing normally done with virgin paint.
Contamination is generally an issue that pops up when
discussing the recycling of paints. PCBs, heavy metals,
etc., have all been found in paint'collected at household.
hazardous waste collection days. Careful sorting el-iminates
this problem. For example, marine paints often contain
PCBs. We don't accept these types of paints for recycling.
When we come across them on site, we simply recommend -that
they be held for a-HHW collection.
Once the paint meets our acceptable standards, we package it
and market it as a high-quality product. To our knowledge-, <
we have the highest recycled content on the market. . Some of
our paints will be 100X post-consumer .recycled .content. .'On ,
average we expect to fall wi.thin 90-95* recycled material.
MARKETING - .
From a marketing standpoint, we believe the public is' ready •
for recycled paint. With 22% of consumers being "premium;
green" we don't expect to have any difficulty selling o.yr .'. '
products. "Premium green" describes those consumers.who are
willing to pay a premium price for environmentally- -
responsible products. Of course, we are aware that we.have
to convince buyers that recycled paint is quality paint.
Our goal is also to work with companies and municipalities
in promoting recycled paint. Many companies are members of
the National Coalition for Recycling. Their corporate
policies reflect an attitude which encourages the use of
recycled products. '.•'.'-
We would also like to involve-municipal.!ties that have
collections in purchasing or specifying recycled paint for
some of their own use. . For our part, we are willing to give
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Incentives to those communities that are working with us to
develop this market. Right.now the market for recycled
paints is minima] but-growing daily.
Successful marketing is critical to the whole process, since
you can ultimately only recycle as much as you can sell--
unless, of course, you consider a warehouse full of partial
paint cans a real business. Municipalities-can assist in
this vital arena by helping us promote recycled paint. We
believe that demonstration sites and projects will be
extremely helpful in getting across the idea of product
quality and performance.
Retailers of paint products can also play a role in
developing this market. Our objective is to recruit .
community-conscious retailers who could.help subsidize
collections and then sell the recycled product. The
retailer would thus gain numerous benefits by helping to
perform a real service for the community. -
ISSUES .
There are some areas that need to be addressed going'
forward. Certainly, the whole area of collection needs -
work. Regulations vary -from state to state and tMs can
cause some problems. But the real culprit is.-that-1-2X •
response rate to HHW collections days. We want; to get/those.
seven million gallons out.of our New England •.basements! . In
order to go forward, we need that supply. THE GREEN PAINT
COMPANY is committed to develop strategies in coope'ratioh
with local communities • to .get all that paint out: of the
basements. .; '•: ' .
Permanent collection si tes are certainly a/step. in. the right
direction. Anything that makes it more convenient; for the-
homeowner should increase the response rate'. .Regular. . -
curbside collections should do even more to get the. old :
paint out. In Massachusetts we have set up. a .program" with
painting contractors whereby they can deliver their leftover
paints to us on a regular basis. As long as they are\VSQGs
they can transport their own waste paint up- to certain
limits. Part of. our job is educating the contractors",,
making them aware of the regulations surrounding the-
products they handle, and encourage them to register with -
DEP as VSQGs. '
When addressing the area of collections,, some regulations.
may have to be altered. For example, in one New England-
state we are not allowed by regulation "to pick up or take
paint even from VSQGs. When receiving paint from this state
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we have to engage a hazardous waste contractor which defeats
to some extent the-goal of recycling. It results in higher
costs simply because a middleman is involved.
Our recycling permit requires us to submit monthly as well
as annual reports to DEP. The primary purpose of these
reports is to prevent any speculative accumulation of waste
paint. The bottom line is that we take in no more than we
can realistically sell. Since we have no. interest in
becoming a Superfund.. si te, we welcome this kind of
monitoring. In fact, we consider it a benefit.and a-great
selling point to tell pur customers that we are regulated
and required to report to DEP.
Education is a key ingredient to any successful recycling
program. The National Paint and Coatings Association and •
the paint industry can play an important role. A recycling
statement or symbol on their labels wou-ld be a very positive
step in lending their "stamp of approval" to recycled
products. In the long term, proper education is in the best
interest of the industry since mandated recycling would'.' ",
remain as the only viable alternative. We welcome the- •' "
opportunity to work with them on these issue.s. . .. -;
Government agencies can also assist in developing this; "
market. By participating in -testing programs government .can
help get the word out by supporting recycled products; .-They
can also begin to specify these items in purchasing - . -
programs. - . ' . - ' ; - •" •.' •• '' ;
Our ultimate goal is to. develop.a broad 'market; for recycled
paint. By emphasizing quality recycled products we" be-lteve'
that we are taking a significant step in this1 direction-. ---.1
Only through programs that make economic sense will.we be -
able to drive down the cost of collection and make .i t eaisy',".
and economical for consumers to get all that;paint -out;, of. . ,'
the basements and garages of America. ' " ' -:". - -,
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Nickel Cadmium Battery Collection and Recycling
Norm England, President Portable Rechargeable Battery Association
As the old man walked down a Spanish beach at dawn, he saw ahead
of him what he thought to be a dancer. A young man was running across
the sand rhythmically, bending down to pick up a stranded starfish and
throw it far into the sea. The old man gazed in wonder as the young man
again and again threw the small starfish from the sand to the water. The
old man approached him and asked why he spent so much energy doing
what seemed a waste of time. The young main explained that the stranded
starfish would die if left until the morning sun.
"But there must be thousands of miles of beach and miiiions of
starfish. How can your efforts make any difference?"
The young man looked down at the small starfish in his hand and as
he threw it to safety in the sea, sard, "It makes a difference to this one."
Today I would like to speak to you about an organization that was
formed to help make a difference. The organization is The Portable
Rechargeable Battery Association (PRBA). It was formed to help facilitate
the collection and reclamation of small sealed rechargeable batteries. It
founded in June of 1991 by five company's: Gates Energy Products, Inc.;
Panasonic Industrial Company; Saft America, Inc.; Sanyo Energy (USA)
Corporation; and Varta Batteries, Inc.; all producers of rechargeable nickel
cadmium batteries.
Our membership has since expanded to over one hundred and fifteen
company's including: American Telephone and Telegraph; Motorola, Skil;
Black and Decker; Tandy Corporation and Compaq Computer Corporation to
name a few.
In order to be quite clear and avoid any misconceptions, I believe it is
necessary to define what I mean with regard to NiCd recycling. This will
also explain why the Portable Rechargeable Battery Association is so
interested in recycling all types of nickel cadmium batteries.
Currently, most uses for cadmium are dissipative; therefore, not much
old scrap is available for recycling. Exceptions are the recycling of some
cadmium bearing alloys and batteries. Cadmium from spent nickel-cadmium
batteries and cadmium alloys can be recovered using a pyrometallurgical or
hydrometallurgical process. Most of the battery recycling plants employ
pyromettalurgical processes. Large cadmium batteries, normally heavier
than 1 to 2 kilograms, are emptied of the electrolyte, dismantled
mechanically, the separators removed together with the plastic casings, and
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the cadmium is recovered by distillation of the plates in specially designed
furnaces. The plastic casings and separators of the small sealed batteries
are burned off at a lower temperature prior to a higher temperature
treatment required for volatilization and condensation of cadmium content.
This process eliminates the need to use landfill space and the risk of leaking
of heavy metals. With cadmium recycled 100% from nickel cadmium
batteries, the supply of cadmium will be stable and the industry will reduce
its requirements to use virgin material.
Again, I am referring to an industrial process intended to separate the
constituents of nickel cadmium batteries for further processing and
refinement into usable raw materials for new products. These processes
meet stringent emission limits.
Cadmium from spent batteries is being recovered in France, Japan,
Sweden, and South Korea. Currently Denmark, Germany, the Netherlands,
and the United Kingdom are planning to develop recycling facilities.
In 1990, INMETCO, located in Ellwood City, PA, started recovering
cadmium from industrial type Ni-Cd batteries, mainly used in the railroad and
telecommunications industries. INMETCO is a PRBA member company, and
is working with the membership and other end users to recycle spent
batteries. They have the capacity to process 10,000 tons of spent batteries
per year and they do accept household batteries. In 1991, INMETCO
recycled approximately 56,000 tons of metal bearing waste, including 500
tons of nickel cadmium batteries.
Saft Nife Greenville has state and federal permits to receive, store and
recycle spent batteries. For the time being, spent nickel cadmium batteries
are shipped under hazardous waste manifest and EPA permit to the Saft Nife
facilities in Sweden for recycling.
In Sweden, the batteries are processed in the following way:
For industrial batteries, the cells are dismantled and the
electrodes separated. The positive electrodes, containing nickel,
iron and sometimes graphite, are sold to steelworks for stainless
steel manufacturing. The negative electrodes, containing mainly
cadmium and iron, are rinsed in water and then placed in a topping
furnace where the cadmium is distilled. The cadmium can then be
used as raw material in the production of new electrodes. The battery
containers, if steel, are washed and sold to steelworks, if plastic jars,
they are cleaned, ground to granules and used in new products.
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For sealed portable batteries, spent battery packs are first
dismantled and plastic components removed. The cells are then sent
to a furnace to be treated in a two-step process. In the first step, the
electrolyte and electrode separators are vaporized into gaseous
forms, which are then "washed." In the second step, the temperature
is increased to distill the cadmium. The cadmium is recovered in a
pure enough form that can be directly reused in the manufacturing of
new batteries. Residues from the distillation containing steel and
nickel are sent to the steelworks for the manufacture of stainless steel.
The recycling of nickel cadmiun batteries results in the recovery of
nickel, cadmium, steel and plastic.
Mercury Refining Company, Inc. (MERECO) in Latham, New York, has
been involved in metals recovery from mercuric oxide and silver oxide button
cells for over thirty-five years. MERECO accepts all types of household
batteries; however, only the mercuric oxide and silver oxide cells are
processed to reclaim metals. Nickel-cadmium batteries are accepted by
MERECO. These batteries are sent to another facility for processing.
Tested and tried recycling processes for recovery of the constituents
of all kinds of nickel cadmium batteries are available today! The problems
are to collect and sort portable sealed consumer batteries, which count for
the majority of cadmium being produced today.
PRBA is working diligently to urge the Office of Management and
Budget to proceed with its review of the U.S. Environmental Protection
Agency's proposed "universal waste rule" to be codified at 40 C.F.R. Part
273. This draft rule would establish special collection system regulations for
used NiCd batteries and other products.
This proposed rule will facilitate the recycling of significant quantities
of household hazardous waste, which would otherwise be discarded in the
municipal solid waste stream in many states. Under current law, household
hazardous wastes disposed of by consumers and not commingled with non-
household waste are exempt from the Resource Conservation and Recovery
Act's (RCRA's) Subtitle C requirements.
Under current rules implementing RCRA, state and local entities that
collect and separate used batteries; recalled, cancelled, or suspended
pesticides; fluorescent light bulbs for recycling are subject to hazardous
waste management regulation under Subtitle C, unless they are able to
certify that these are household wastes and have not been commingled with
non-household wastes. This has presented major obstacles to the collection
and reclamation of these materials from consumers and has prevented their
capture from the municipal solid waste stream.
As the majority of these waste materials are derived from the
municipal solid waste stream, the inability to establish viable collection and
recycling programs without first obtaining hazardous waste treatment,
storage and disposal permits has severely hindered state and local
community efforts to separate and remove toxic constituents from the
municipal solid waste.
The proposed regulations would establish a special collection system
and provide a less burdensome alternative than current regulations for the
management of these wastes. Elimination of unnecessary and burdensome
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, ,,** ,.!•:*•¥- •* >#**• " iV-V-X1'.;
RCRA regulations will allow sate and local communities, as welt as industry,
to establish feasible and effective collection and recycling programs. These
efforts will improve public health and protect the environment by removing
sources of mercury, cadmium and other metals from the municipal solid
waste stream.
PRBA was successful in obtaining the support of six (6) U.S.
Senator's, Senator's Jeffords, Rockefeller, Duronberger, Lautenberg, Breuax,
and Byrd, who wrote to OMB on November 17th, urging OMB to release the
rule promptly to facilitate its immediate publication in the Federal Register.
PRBA is attempting to design and implement collection systems that
will assure the purest possible stream of used Ni-Cd batteries to the final
reclamation facility. It so happens that the Ni-Cd industry in the U.S. has
one rather unique feature: We estimate that up to 70% of all Ni-Cds sold to
Original Equipment Manufacturers (OEM's) are sold to only ten companies.
Where appropriate and feasible, we want to work with our OEM's to develop
reverse distribution collection programs.
We are also testing Focused Retail programs. There are a number of
Ni-Cd only Points of Sales. For example, video camcorder packs, portable
telephone replacement packs, power tool replacement packs are sold,
generally, at Ni-Cd only Points of Sale. Both Household Hazardous Waste
Management Programs and Curbside Collection Programs are infrastructures
that already exist, and we are attempting to develop piggy-back programs,
where feasible, although these two particular methods seem to present
greater educationally challenges, as consumers may find it difficult to
distinguish between Ni-Cds and other types of batteries.
PRBA formulated and implemented a Four Part Pilot Battery Collection
Program in Minnesota, as required by Minnesota Law. This program was
initiated in April of this year, and despite numerous obstacles, we have
collected approximately 2,500 pounds of batteries in the first six months of
the program. This was accomplished without one of the key elements of
the program in place. That element was the collection on batteries through
existing or new county collection programs in nine counties. We are
continuing our efforts to get these parts of our program up and running.
PRBA has executed the contract with Hennepin County and is working
out modifications with the Western Lake Superior Sanitary District and
should be able to finalize the contractual agreements within the next week
or two. Once the contracts have been signed, the P.R. activities will begin
and we anticipate that there wilt be a tremendous increase in call to our toll
free 800 number. A vast majority of the consumers can be directed to the
various county collection locations, utilizing their zip codes. The
convenience of this program will create a sharp increase in the pounds of
batteries collected.
Of the 2,500 pounds collected thus far, most were returned through
reverse distribution to member company service centers or authorized
service centers. A small amount were returned through member company
prepaid mailback programs.
I anticipate in the next six months, several companies will implement
collection programs at retail locations, the Minnesota Consolidation Point for
used rechargeable batteries will be operational and our publicity programs
will be in place, generating increased consumer response.
95
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PRBA, also, has a pilot collection program operating in Vermont.
Working with the Vermont Agency of Natural Resources and the Central
Vermont Public Service Corporation, rechargeable batteries are being
collected at thirteen (13) CVPSC offices throughout the state. Each office
has a collection box, PRBA poster, and brochures explaining the program.
Brochures have also been given to solid waste districts for distribution and
discussions are currently taking place to expand the program to an additional
200 drop-off points.
In mid-October, PRBA submitted its "Joint Battery Management Plan"
to the New Jersey Department of Environmental Protection and Energy
(DEPE).
An overly broad interpretation by the New Jersey Department of
Environmental Protection and Energy (DEPE) of the state's 1992 Dry Cell
Battery Management Act may result in a ban on the sale of nickel-cadmium
or sealed lead rechargeable batteries in mid-January 1993. PRBA is
working hard to avoid this result, but it appears that negotiations with the
DEPE to thwart the ban will go down to the wire.
The New Jersey statute requires that producers of rechargeable dry
cell batteries submit battery management plans for state approval in order to
be exempt from the ban. Further, the statute stipulates that no person -
whether a distributor, wholesaler or retailer - may sell the batteries covered
by the Act after mid-January 1993, if the DEPE has not approved the
submitted plans. To be considered for approval, plans must address
"collection, transportation, recycling or proper disposal" of used batteries.
In order to meet its members' needs, the PRBA Operating and
Recycling committees developed a plan similar to the Minnesota program.
Additionally, PRBA representatives have been serving on New Jersey's Dry
Cell Battery Advisory Council since March. Over the past nine months,
agreement seems to have been reached with the DEPE on most of the plan
elements PRBA has in mind. 'However, major disagreement still exists about
who should bear the cost of transportation from the generators to a
collection facility .
PRBA submitted a plan on behalf of its membership that I believe fully
complies with - and, indeed, even exceeds - minimum statutory
requirements. We are continuing to work to persuade the DEPE to
reconsider its view. PRBA and individual battery cell manufacturers are also
exploring the possibility of obtaining relief from the New Jersey legislature.
If all else fails, PRBA's legal counsel has been asked to consider how an
unfavorable final DEPE interpretation might be challenged in court.
96
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VN : • Statewide Educational Campaign
The campaign will include television and radio public service
announcements, newspaper advertising, in-store posters, railroad and bus
posters and bill stuffers.
*•*,
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Cell manufacturers anticipate contr
ollection center and will be responsible 1
^cycling of batteries.
u z
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The rechargeable nickel-cadmium battery represents a battery system
that most people are simply not very conscious of or very mindful of: Our
image of a battery seems to be pretty much limited to that black, box-like
device that sometimes fails to start our car or the small cylindrical or square-
ex
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Operation is estimated to begin in !
shaped objects that we generally buy on impulse for our childrens' toys, our
flashlights, portable radios, or smoke detectors.
Collection from Consumers
•
To better appreciate the Ni-Cd, we need, perhaps to focus more
1 on a specifically on individual applications for a brief moment: video cameras,
cational portable power tools and appliances, portable audio equipment. In essence
Ni-Cds have made enormous contributions to the current affluent and
comfortable lifestyles that so many of us now enjoy. Other important
wi" applications include emergency lighting, police and emergency dependable
and plat quiet, behind-the scenes roles in our response to life-threatening
emergencies.
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For counties collecting all batteries
RBA collection center will pick up from .
jgular basis, pay for pick up cost, and d
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They are extremely economical
jon Nothing need be thrown away.
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fie PRBA collection center.
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97
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. Primary Battery Reformulation, Collection and Recycling
Terry Telzrow, Eveready Battery Company, Ohio
The news' headlines say, "BATTERY INDUSTRY GETS RECOGNITION FROM
THE FEDERAL EPA FOR LEADERSHIP ROLE IN APPLYING THE PRINCIPLE OF
SOURCE REDUCTION"- to make primary batteries environmentally benign.
By the end of 1992, it seems all common primary household batteries-AAA, AA, C,
D, and 9V--will be produced with no added mercury in the United States, Europe, and
Japan.
The mercuric oxide system is being phased out and replaced with the environmentally
acceptable zinc-air system.
Are we through?
What about the conservation issue?
What about recycling?
EVEREADY BATTERY CO. is not philosophically opposed to recycling! We are,
however, opposed to blindly accepting that recycling today with today's technologies will
benefit society or our customers.
You will see that those technologies that are in the advanced state of development
and many of those in pilot programs are extremely energy consumptive and costly. It
doesn't make sense to us to expend 2 to 10 times the energy to recover battery materials
that are in abundance, as compared to extracting these materials from their natural sources.
98
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_ Let's look at these emerging technologies. The more 'advanced' ones are compared
in detail from available data. The pilot project technologies do not have available data for
I detailed comparison; but on the surface, they do not appear to offer any real breakthrough.
Figure 1 lists the known technologies. Figure 2 briefly describes these technologies.
| Figure 3 provides schematics of the proposed technologies. Figure 4, 5, and 6 show more
m detail. Schematics of some of the other processes are also available but not provided here.
• Energy consumption is a real concern. Figure 7 compares the Batrec (Sumitomo),
• Recytec, and Nuova Samim processes based on primary energy. These values might well
be actually higher than shown, once the processes are up and running.
I Figure 8 compares primary versus metered energy consumption. Figure 9
compares these energy requirements to the energy needed, to extract an equivalent amount
of zinc metal from existing mines.
I
_ However, zinc is not the only material expected to be recovered. Figure 10 makes
the comparison assuming the process will recover zinc, mercury, and ferromanganese.
I
M Figure 11 provides the energy necessary for the primary metal production of these
same materials for comparison purposes.
I
• We believe there must be improvements in the technologies to reduce the energy
consumption much closer to a 1-to-l ratio before one considers mass recycling of the—now
• environmentally benign-batteries.
-------
What about costs? Our estimates, in U.S.$/KGm are as follows:
Batrec $2.82 - $8.25
Recytec $2.44 - $5.07
Nuova Samim (") $0.85 - $0.93 (Swiss)
Nuova Samim (') $0.85 - $1.00 (Italy)
(*) The difference is accounted for by labor rates and tax rates.
The large range is due to including items like maintenance expense, depreciation, and the
variable value of the recovered materials.
Once can clearly see, from Figure 12, the impact the differing technologies have on
costs. Energy costs and depreciation vary widely.
While it appears that Nuova Samim energy costs are very low, one must compare the
costs on the same basis (gas versus electrical). See Figure 13.
On an annual basis, the costs, to process 100% of the past consumer batteries, would
range from $450MM down to $150MM. If collection of post consumer batteries were only
at a 40% level, then these costs would range from S180MM down to S60MM annually.
Capital costs in U.S.$ to build each facility, follows:
2000MT Batrec (Sumitomo)
3000MT Recytec
20,OOOMT Nuova Samim
$25MM
$16MM
$19MM
None of the costs above include collection of the post consumer batteries or their
transportation to a "recycling" facility.
100
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1
1
1
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1
1
1
1
1
1
1
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1
It doesn't make sense to us!
What needs to be done?
• '
On October 1, there was a joint press release, Berne, Switzerland, which stated that
the European, Americans, and Japanese have joined together to study the feasibility of
recycling household batteries with a
technology that is energy efficient and cost effective.
This study will be supported by the International Consulting Firm of A. D. Little and by
Japanese Clean Japan Center.
Please note that even after all these advanced technology and costly studies, the
results may show-it still doesn't make sense.
Battery Recycling
Company Location
BATREC AQ - Switzerland
RECYTEC Switzerland
NUOVA SAMIM Italy
Status
Start-up scheduled for
June, 1992
Start-up In 4Q91.
Start-up scheduled for
mid-1992. Start-up
delayed Indefinitely,
VOEST-ALPINE Austria 'Pilot plant/lab"
TNO Netherlands "Pilot plant* for Nl-Cd and
primary celts.
BASALT U. S.
INDUSTRIES
MOLTEN METAL U. S.
TECHNOLOGY
ANSALDO S.p.A. Italy
DETOX INTER. U. S.
500 ton plant "-
In operation.
•n
Patent and technology §
33
only "
Patent position
Patent position.
101
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FIGURE 2
TECMlSTOX^OCS-r ESS
NUOVA SAMIM
Thermal - Pyrolysis at 600-700"c.
Byproduct gases are burned at 1100"C.
Batteries are converted to feedstock
for existing metal recovery plant.
RECYTBC
Thermal/plating. Pyrolysis at 550"c.
followed by magnetic separation of ferrous
components and plating of other metals.
SUMITOMO
(BATREC)
Thermal - No Ni-Cd or Pb-acid batteries.
Shaft and melting furnace >750*C. Zinc
recovered by carbothermic reduction and
vapor condensation. Iron and manganese
recovered as FeMn alloy.
BASALT INDUSTRIES
Shredding, drying, and physical
separation, components sold for recovery.
TNO
Hydrometallurgical - Leachate followed by
electrolysis or precipitation.
VOEST-ALPINE
Thermal/plating. Sorting, magnetic
separation followed by pyrolysis. Acid
leach and plating for zinc recovery.
MOLTEN METAL
TECHNOLOGIES
Catalytic extraction in molten iron bath.
Technology & patents on recovery of wastes
in molten metal baths.
ANSALDO S.p.A.
Catalytic extraction in molten iron bath.
Patent on disposal of batteries in a
molten iron bath.
DETOX INTERNATIONAL
Catalytic extraction in molten aluminum
bath. Patent on disposal of wastes in
molten metal bath.
102
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FIGURE 4
SPENT DRY-CELLS OVERALL TREATMENT
PROCESS FLOW CHART
NO SORTED
DRY CELLS
WATER
n
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T
A
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L
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ATMOSPHERE
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— METALLIC
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PYROLYSIS
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TREATMENT
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TREATMENT
,
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CARBON
UNIT
1 DEMERCUfilZED
1 MATERIAL
SCREENING
OVER ^ V
SIZE SEf
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FINES Zn DUST Mn OXIDES
Ni
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Zn SCRAPS
ZnO CdO PbD
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PLA
m- STEAM
»_ MERCURY
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+- ATMOSPHERE
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CLEANING
Zn Cd Pb AS METALS
SLAG'
NUDVA SAMIM
E.N.I, group
ROME - ITALY
104
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FIGURE 5
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Xf
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FIGURE 6
CO
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LU
O
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LU
LU
106
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FIGURE 7
Battery Recycling
Total Primary Energy, MJ/MT Batteries
CO
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111
Nuov* Samim
Sumitomo
Recylec
FIGURE 8
BATTERY RECYCLING
PRIMARY & METERED ENERGY REQUIREMENTS
CO
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cc
01
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NUOVA SAMIM SUMITOMO
RECYTEC
107
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FIGURE 3
BATTERY RECYCLING
Primary Energy Requirement, MJ/Kg Zn
•5
*:
-5
S1
o
111
500
450
400
350
300
250
200
150
100
50-
0-
Total
TouJ
=?; Baneiy
, Refining
iisi Mi™9
rocessing
Virgin Zinc •
Nuova Samim
Sumitomo
-m
Hecytec
—-.1
10
PRIMARY ENERGY COMPARISON
EQUIVALENT ENERGY/MT SCRAP BATTERIES
108
co 8°ir
yj ij
fX 7Q-^
uj 'S? ii
< 60-
m
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« 40-
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i
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Samlm
Sumitomo B«cytac Zn
Hg F*-Mn-C
-Primary Matala
Total
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FIGURE II
t
Primary Energy Comparison
Primary Metal Production, MJ/Kg Metal
60r
50-
2 40
E>
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C
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Battery Waste Management: A California Study
Fernando Berton, Manager HHW Section CIWMB
INTRODUCTION
The management of household batteries in the solid waste stream is
a very complex matter, particularly in California. Because
household batteries comprise only 0.005 percent by weight of
California's municipal solid waste, the concern over household
batteries is not with the volume, but with the amount and toxicity
of their heavy metal components. However, millions of household
batteries are sold annually in California.
Because millions of batteries are sold annually in California,
there was concern as to how these batteries were being managed.
The result was the passage of Assembly Bill 3530 during the 1991
Regular Session of the Legislature. This legislative bill required
the California Integrated Waste Management Board (Board) to conduct
a study on the disposal and potential recyclability of household
batteries. The overall purpose of the study was to:
Identify potential risks of used household batteries
in the waste stream.
Assess waste management options available to reduce
potential risks caused by household batteries. These
options include:
Source- Reduction
Reuse
Alternative methods of disposal
Recycling
Develop policy recommendations regarding household
batteries. . .
The information-contained in the Study will be used for future
legislative proposals in the next Regular Session of the California
Legislature.
STUDY METHODOLOGY
In .conducting this study of household batteries and developing
recommendations for legislation, we utilized the following methods
to research and analyze household battery issues:
Collected and reviewed background documents of the battery
industry and battery collection programs, including:
- Operating data, where available, of current local
collection and processing programs, including information
on numbers of household batteries collected, and
operating and start-up costs of collection programs.
Conducted a review of current legislation, including:
111
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Source reduction requirements which must be fulfilled
by manufacturers '
Collection, processing or recycling programs which are
to be managed by municipalitities and other local
agencies
Examined historical battery sales data and projected
sales based on industry and consumer trends
Assessed the relative contribution of toxic metals in
household batteries to the solid waste stream, including
identifying other sources of metals and the relative
proportion contributed by household batteries
Identified the potential pathways from a variety of waste
management processes which metals from household
batteries can enter the environment, including
landfilling, incineration, composting, collection and
transfer, and recycling
Determined whether used household batteries are
considered hazardous waste, and the extent which
hazardous waste regulations apply to household battery
waste management
Assessed the state of battery design and technology,
including the identification of new battery developments
or types, the stage of development, degree of
substitution within current battery types, and potential
toxic metals contained in new battery designs
Reviewed the roles of local and state government and
household battery manufacturers in battery waste
management
BATTERY SALES IN CALIFORNIA
To understand the breadth of the potential problem with the
management of household batteries, it was necessary to obtain sales
figures specific for California. The data used was provided by the
National Electrical Manufacturers Association to derive California
household battery projections through the year 2000.
In 1985, California's population was 11.1% of the nation's
population. This percentage increased to 12.0% in 1990, and by the
year 2000, census projections indicate that California's population
will be 12.6% of the total United States population. According to
the Study, population growth between 1985 and 2000 accounts for
approximately 25% of the growth in household battery sales within
California.
112
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For sales forecasts in the Study, it was conservatively assumed,
for the lack of better information, that 8% of alkaline, 32% of
carbon-zinc, and 35% of nickel-cadmium battery sales will be to
non-residential consumers. This is significant since a relatively
large number of both primary and secondary batteries are consumed
and disposed by non-residential users. The following table
presents estimates for household battery sales by type and size for
the period between 1985 and .the year 2000. Projected sales data
are adjusted from national figures to represent those batteries
purchased and used in California. This is accomplished by
prorating national sales data for each year based on California
population projections relative to the population of the United
States. Annual Sales of Household Batteries in California
(Millions of Batteries)
Cjtition-Zinc
0
C
SuSWUI
Button Ctb
M»rcunc a*Ot
Zinc Air
Ulhurn
Subtotal
TOTAL
SIS
32
312 335 358 388, 4l
!f HIST! 3881 388
233
IDS
VSR .48*ffiffi WK •.«••: 38J' wi'
479 498 Sit 54$ SK 609 MS
Sales of Household Batteries
in California By Type
0 f [— ~j - - -j i j i j •- j j i i j i j-
19SS 1936 19B7 1988 1989 1990 1991 IMS 1993 1994 1995 13M 1997 1998 1999 2000
113
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CLASSIFICATION OF HOUSEHOLD BATTERIES AS HAZARDOUS WASTE
Household batteries contain metals which are known to have adverse
effects on human health and the environment. Mercury and cadmium
are toxic metals of primary concern in household batteries.
However, nickel, silver, and zinc are' regulated metals in
California. As a result, regulatory criteria for determining
whether batteries are hazardous or not differs in California than
in other parts of the country. California's criteria for hazardous
waste is more restrictive than federal requirements. In addition
to the Toxicity Characteristic Leaching Procedure(TCLP), California
also has requirements under the Waste Extraction Test (WET), which
is used to determine the hazardousness of waste.
While low-mercury alkaline and carbon-zinc batteries could pass the
TCLP test, according to the California Department of Toxic
Substances Control (DTSC), these batteries could possibly fail the
WET limits for zinc and possibly mercury. While data are not
available on the performance of each battery type using the WET
procedure, the DTSC considers all types of household batteries to
be hazardous and equally subject to hazardous waste regulation.
In addition to the more stringent criteria for defining hazardous
waste, California does not have the household waste exclusion from
hazardous waste designation. In order to facilitate the collection
and reclamation of household batteries, the State of California
enacted the Management of Small Household Batteries Act of 1989.
The Act provides that any collection location or intermediate
collection that receives, or any person that transports used
household batteries, is exempt from the requirements regarding the
receipt, storage, and transport of hazardous waste if the batteries
are sent to a metal reclamation facility for the purpose of metal
recovery. There are only two facilities that reclaim metals and
they are located on the East Coast and do not accept the
predominant type of battery sold or collected in California
(alkaline). Most existing household battery collection programs
dispose of household batteries in a hazardous waste landfill.
Therefore, the exemptions provided for by the Act would not apply
to these efforts and the collection, storage, and transport of the
batteries would be subject to hazardous waste regulation.
The specific requirements for handling hazardous waste are complex
and suffice it to say that because of the complexity of these
regulations, requirements to handle collected household batteries
as hazardous waste may inhibit the establishment of household
battery collection programs.
CURRENT DISPOSAL METHODS FOR HOUSEHOLD BATTERIES
As stated before, millions of household batteries are sold annually
in California. It would be safe to say that the majority of these
batteries are being illegally disposed of in California. There axe
currently no specialized collection programs aimed at household
batteries. Any collection of batteries . is currently being
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accomplished by utilizing existing HHW collection programs.
Unfortunately there is no data available on the number of batteries
collected at collection events but it would be safe to say that it
is minuscule.
ECONOMICS OF HOUSEHOLD BATTERY COLLECTION AND DISPOSAL
The cost of collection and disposal of household batteries as
hazardous waste may presently cost on the order of up to $4,000 a
ton in California. This includes approximately $2,000 a ton for
collection and $2,000 a ton for disposal. The cost per ton to
collect and reclaim the applicable metal from household batteries
is generally equal to, or greater than, the $4,000 per ton figure.
The development and implementation of"household battery collection
and disposal programs in California can create an additional
financial burden on local governments. For a community of 100,000
people with a household diversion rate of only 10 percent, the
annual costs for collection and disposal of just household
batteries as hazardous waste could equal $20,000 or more.
The cost to dispose of household batteries as hazardous waste will
be the same for each type of battery. The exception to this may be
lithium batteries. Because of the potential for lithium in its
metallic state to react violently with water, some. battery
collection program operators report that these cells should be
deactivated prior to disposal. Reported costs for deactivating
lithium batteries range from $4 to $15 per pound or $8/000 to
$30,000 per ton of batteries.
Since mercury and cadmium are the major metals of concern in
household batteries, it is illustrative to examine the costs for
diverting these metals from the waste stream through battery
collection and disposal. Each battery type contains varying
amounts of mercury and cadmium. "The following table shows the
approximate cost incurred of removing a single pound of mercury and
cadmium from batteries.
Cost of Diverting Metals From Municipal Solid Waste
Through the Collection and Disposal of Household Batteries
Battery Type
Alkaline
Carbon- Zinc
Mercuric Oxide
Silver Oxide
ZincAir
Nickel-Cadmium
Metal of
Concern
Meinuy
Mercury
Mercury
Mere my
Mercury
Cadmium
Cost of
Metal Metal Diversions/
Content ($/lb of metal)
0.025%
0.0001%
37%
1%
2%
12.5%
$8.000
$2,000,000
$5
$200
$100
$16
a/ Assumes £4,000 per ion household battery hazardous waste collection and disposal
costs.
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The following table shows the number of batteries required to be
diverted for each pound of the applicable metal avoided. These
data indicate that it would require over nine million carbon-zinc
batteries to be collected in order to divert a pound of mercury
from the municipal solid waste stream.
Number of Batteries Collected
For Each Pound of
Hazardous Material Diverted
Batter]' Type
Alkaline
Carton-Zinc
Mercuric Oxide *
Silver Oxide
Zinc Air
Niciei-Cjdmium
Metal of
Concern
Mercury
Mercury
Mercury
Mercury
Mercury
Cadmium
Metal
Content
0.025%
0.0001%
37%
1%
ZS
12.5%
Average
Weight
Per
Battery^/
(Crams)
46
49
2
I
2
.44
Required
Number of
Batteries
Diverted
(Batteries/
Pound of
Metal)
39,391
9.244.897
612
45.300
11,325
82
3/ 453 grams per pound Avoirdupois Weight. ,
Given the current financial pressures on local governments, the
costs of collecting and disposing each type of battery, the varying
metal content levels for each type of household battery, the need
for cost-effective and pragmatic approach in the management of
battery waste, and the evidence that nickel-cadmium batteries may
pose a relatively larger potential risk to health and the
environment, an appropriate battery management strategy .may require
targeted efforts directed primarily at nickel-cadmium batteries.
RECOMMENDED HOUSEHOLD BATTERY WASTE MANAGEMENT STRATEGIES
As a result of the research and findings of the Battery Study,
specific recommendations included. Some of the recommendations
will require new legislation and regulations and some
recommendations may require modifications to existing State
regulations. The following are five major recommendations of the
Battery Study.
1. Develop Specific Legislation for Household Battery Management
It is recommended that California develop broad based
legislation for regulation of household batteries. This kind
of legislation is similar to what is already occurring in
other states. Recommended legislative general provisions
include (1) mercury content limitations, (2) standardized
product labelling requirements, (3) a targeted battery product
ban, and (4) specifications that batteries be removable from
products.
The following table contains specific provisions for recommended
household battery legislation:
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Recommended Household Battery Legislation
Battery
Type
General
Provision
Specific
Provision
Carbon Zinc Mercury Content Limitation
All Button
Cells
Product Labelling
2.
3.
Alkaline Mercury Content Limitation Limit mercury content in alkaline
batteries to 0.025 percent, by
weight, by July 1993
Alkaline Mercury Content Limitation Limit mercury content in alkaline
batteries to 0.0001 percent, by
weight, by January 1996
Limit mercury content in carbon-
zinc batteries to 0.0001 percent, by
weight, by July 1993
Require button cell batteries and
packaging to identify the type of
battery and need for proper disposal
by July 1993
Ban sale of mercuric oxide button
cell batteries by January 1996
Require nickel-cadmium batteries
and packaging to identify the type
of battery and need for proper •
disposal by July 1993
Require battery-operated products
using nickel-cadmium batteries and
packaging to identify battery type
used and the need for proper
disposal by July 1993
Require that all battery-operated
products using nickel-cadmium
batteries to be manufactured so that
the batteries are easily removeabie
by the consumer
Facilitate Dialogue With Department of Toxic Substances
Control and Battery Industry
The Board will act as facilitator between the Battery Industry
and the Department of Toxic Substances Control to discuss
topics that affect the management of household batteries.
Such include the regulation of zinc in California, permitting
and transportation issues, labelling, etc.
Review and Revise Existing California Regulations Which Affect
Household Batteries
Regulations that affect household battery management in
California should be reviewed to determine if they act as an
impediment to local governments and private industries who
need to collect, store, and transport household batteries for
proper hazardous waste disposal.
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Mercuric Oxide Product Ban
Nickel- • Product Labelling
Cadmium
Nickel- Product Labelling
Cadmium
Nickel- Batteries Removable from
Cadmium Products
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4. Develop and Implement Statewide Education Program for
Hazardous Household Batteries
The State should develop and implement a statewide education
program on the various types of household batteries, and the
special requirements for disposal. The education program
should include the following areas:
»• Description of the various types of household batteries
> The varying contribution of toxic metals in different
battery types
* Proper disposal of button cells and nickel-cadmium
batteries
The State needs to help relay a consistent message to
California consumers regarding the collection and disposal
of household batteries. If consumers are advised to collect
certain -household batteries, there needs to be provided a
proper form of disposal.
5. Further Develop Hazardous Household Battery Collection and
Disposal Strategies
Existing HHW programs sponsored by local governments should
be the present primary mechanism for household battery
collection. These battery collection programs should focus
on the required collection and handling of nickel-cadmium
and button cell batteries. However, if additional battery
collection efforts are considered necessary, such as a
community with a waste-to-energy facility or a mixed-waste
compost operation, then collection programs should encompass
retail outlets and curbside collection programs.
The ultimate decision on what type of household batteries to
collect may affect decisions on how best to collect batteries.
Return to retailer collection may be highly suited for button cell
batteries and nickel-cadmium batteries where consumers are looking
for a specific type and replacement battery.
The Household Battery Waste Management Study provides much more
detail than the paper you just read. If you would like to obtain
a copy of the Battery Study, submit a written request to the
following address:
Fernando Berton, Manager
Household Hazardous Waste Section
California Integrated Waste Management Board
8800 Cal Center Drive
Sacramento, CA 95826
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Hennepin County's Battery Program
Cheryl Lofrano-Zaske
.Planner, Hennepin County Department
Department of Environmental Management
Hennepin County has a population of over 1 million or approximately one quarter of
Minnesota's population. Hennepin County has 47 communities, with the City of
Minneapolis being its largest community and County seat. An integrated solid waste
management system is utilized which includes transfer stations, a waste to energy
plant and refuse derived fuel plants, household hazardous waste collection center and
recycling centers. Programs include recycling, hazardous waste, solid waste,
conservation and problem materials. Problem material management includes
household hazardous waste, liquid mercury items, fluorescent tubes, high intensity
discharge lamps, consumer electronics, major appliances, and the Hennepin County
battery program. There are three main methods for battery collection in the Hennepin
County program:
1. Button Batteries: Collected at over 500 retail and public drop-off locations.
Program started in 1989 and has collected approximately 2,000 pounds of
batteries. Batteries are collected in small Hennepin County boxes and
transported to central collection site by common carrier.
2. Mixed Household Batteries: Collected at over 1 50 collection sites and curbside
in the City of Minneapolis. Program started fall of 1990 and has collected over
175 tons of batteries. Batteries are collected in 7 or 33 gallon size collection
containers. Containers are transported to the central collection site by People
Unlimited, a non-profit organization.
3. Rechargeable Appliances: Collected at the recycling and transfer station in
Brooklyn Park. The batteries are removed from the appliance and are managed
with the mixed household batteries.
The central collection site for the batteries is Hennepin County Vocational Services,
a rehabilitiation facility serving people with disabilities. The batteries at the central
site are sorted by chemical composition and packaged for disposal and are managed
in accordance to the hazardous waste rules.
Sorted Battery Categories Management Method
Alkaline hazardous waste landfill
Carbon-Zinc and Zinc-Air hazardous waste landfill
Nickel Cadmium send for metal reclamation
Lead-Acid ; send for metal reclamation
Button Batteries send for metal reclamation and disposal
Lithium hazardous waste incineration
Mercury send for metal reclamation
Silver send for metal reclamation
If you would like information on our programs, please contact Hennepin County
Environmental Management, 417 North Fifth Street, Minneapolis, Minnesota 55401-
1 309. 12/08/93
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Hennepin County
Residential Battery Collection and Disposal by Shipments
1990
1991
1992 as of 11 /30 Totals (2/90 - 11 /92)
Alkaline
Zn/Carbon
Nicd
Merc./button
Lithium
Lead Acid
(non vehicle)
All Batteries
38.16%
32.52%
22.98%
6.33%
0.00%
0.00%
100.00%
1,760 Ibs.
UOO Ibs.
1.060 Ibs.
292 Ibs.
0 Ibs.
0 !bs.
4,612 ibs.
.17.24%
34.74%
6.89%
0.57%
0.00%
0.56%
100.00%
81,089 Ibs.
49.215 Ibs.
9,757 Ibs.
803 Ibs.
0 Ibs.
. 800 Ibs.
241.664 tbs.
62.20%
31.71%
2.75%
0.00%
1.08%
2.27%
100.00%
124.196 Ibs.
63,308 Ibs.
5,483 Ibs.
0 Ibs.
2.148 Ibs.
4,540 Ibs.
199,675 Ibs.
59.85%
32.96%
4.71%
032%
0.62%
1.54%
100.00%
•
207,045 Ibs.
114.023 Ibs.
16300 Ibs.
1,095 ibs.
2.148 Ibs.
5340 Ibs.
345,951 Ibs.
172.98 tons
.Hennepin County
Residential Battery Costs for Processing and Disposal
Collection
Sorting
Disposal
Totals
1990
1991
1992
(as of I VI 5/92)
Totals
Unknown
S5.S55
$5,001
$10.856
$970
$26.742
$36,614
$64326
$1.500
$74,892
$107387
$183.779
$2.470
$107,489
$149.002
$258.961
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SAN FRANCISCO'S SAFE NEEDLE DISPOSAL PROGRAM
Brad Drda and Karen Barnett Ph.D.
Sanitary Fill Company —San Francisco, CA 94134
Of all the hazards associated with the collection and disposal of solid waste in San Francisco, the
garbage workers' greatest fear is the possibility of being stuck by a used hypodermic needle hidden in the
trash. Diabetics and other home treatment patients use an estimated 15,000 to 20,000 needles every day in
the City and drug addicts are thought to account for as many as 10,000 more. All used needles, if disposed
of improperly, have the potential to stick and possibly infect anyone with whom they come into contact.
Sanitary Fill Company, owner and operator of the San Francisco Solid Waste Transfer & Recycling
Center, and the San Francisco Household Hazardous Waste Collection Facility (HHWCF), is committed,
along with the City and County of San Francisco, to protect its workers from injury and disease by reduc-
ing the number of used needles entering the municipal waste stream.
The Problem
According to a 1990 EPA report to congress on medical waste management, approximately 1.4 billion
needles and lancets, collectively known as sharps, are used and discarded into domestic waste streams
each year. Laid end to end, 1.4 billion 4.5" insulin syringes would circle the globe four times at the equa-
tor. Efforts to curb rising health care costs are resulting in shorter hospital stays which in turn leads to an
increased reliance on home health care alternatives, and an increase in the number of sharps and other
home generated medical wastes.
Traditionally, used sharps from the home have been disposed of in the regular garbage. Some are
flushed into the sewer system where they endanger plumbers and city workers. A survey of San Francisco
garbage workers found that 80% of survey respondents reported having found sharps and other medical
waste in the garbage.
Health and Safety Hazards of Needle Sticks
Discarded needles can be infectious because they may contain small amounts of blood. If the blood
on a needle contains a viable pathogen then a stick from that needle has the potential to transmit disease.
Two bloodbome pathogens are of special concern: Hepatitis B Virus (HBV); and the Human
Immunodeficiency Virus (HIV) which causes AIDS.Other diseases capable of transmission by needle
stick are hepatitis C, hepatitis non-A non-B and malaria.
The hepatitis B virus causes a severe, potentially fatal liver disease that causes destruction of liver
cells, extreme weakness and yellowing of the skin. People who are fortunate enough to recover from a
painful bout with HBV face an increased risk of liver cancer later in life. HBV is found in virtually all
body secretions and excretions of infected individuals and can be transmitted sexually. Some people who
recover from the disease go on to become chronic carriers, and pregnant women infected with the virus
may pass it on to their babies.
The Human Immunodeficiency Virus that causes AIDS can also be transmitted through a needle
stick, though this is considered very unlikely for garbage workers because the HIV virus dies so quickly
once it leaves the body of an infected person. A study of healthcare workers who accidentally stuck them-
selves with infected needles found the more resilient hepatitis B virus was 66 times more likely to cause
an infection than the relatively fragile HTV.
Realistically, a garbage worker would have to come into contact with an infectious needle moments
after it was used for HIV infection to be remotely possible. Exposure to air and the cool, dry conditions of
a garbage receptacle, relative to the human body, quickly destroy the HIV and render it non-infectious.
But regardless of the small probability of contracting HIV from a needle in the trash the average garbage
worker may perceive this risk to be great and perception cannot be taken for granted. One of the reasons
Magic Johnson gave for retiring from professional basketball after cutting his arm-in a pre-season game
was an acknowledgment of the perception of risk, justified or not, that other players felt while playing on
the same court. The concept of risk is abstract, but the anxiety and emotional suffering of a needle stuck
worker and his or her family as they wait for symptoms is very real.
At present, there are no federal regulations regarding the disposal of medical waste from any source.
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California regulates medical waste from hospitals and clinics but sharps and other medical waste gener-
ated in the home are specifically exempt. In lieu of disposal regulations, the EPA has published guidelines
recommending that needles, syringes, lancets and other sharps from the home be placed in tightly closed,
hard plastic or metal containers before disposal in household trash receptacles. This is an improvement
over loose needles discarded in the trash, but it is an imperfect solution because needle containers often
break when they are compacted in the back of a garbage truck and needles may scatter throughout the
load. Once dispersed, these needles again pose a threat to collection, vehicle maintenance and landfill
workers.
j
Needle Collection in San Francisco
The San Francisco Household Hazardous Waste Collection Facility began accepting medical waste
from San Francisco residents shortly after it opened in 1988. The facility, located at the southern bound-
ary of the city, accepts waste delivered by residents eight hours a day, three days a week. Medical waste is
stored at the facility for pick-up by a licensed hauler for destructive incineration.
In order to make safe sharps disposal more convenient, and thus increase the number of sharps col-
lected, Sanitary Fill and the two local garbage collection companies created the Residential Needle
Collection Program. For a nominal fee of $5.00, a customer may arrange for a red plastic sharps container
to be delivered to their home. When the container is full, the customer contacts the garbage company and
a collector retrieves it for incineration. Sanitary Fill Company informs residents of these provisions for
safe needle disposal through flyers and other garbage company public outreach programs. We also con-
tacted local hospitals and asked them to contact their diabetic and home care patients about safe needle
disposal.
Waste Acceptance Control Program
Sanitary Fill Company developed the Waste Acceptance Control Program (WACP), in 1987 to keep
hazardous waste from entering of the city's waste stream. The WACP also works to eliminate needles
from the waste stream by conducting waste inspections, training employees, and developing community
education and outreach programs. As with other hazardous wastes, when WACP technicians discover
sharps during waste inspection, or receive a report of sharps from a garbage collector, they contact the
sharps user, if possible, and help arrange for a safe disposal alternative.
Hepatitis B Inoculations
In response to employee concern, the San Francisco Garbage Companies made hepatitis B inocula-
tions available, free of charge, to all of their employees who may potentially come into contact with nee-
dles in the solid waste stream. This group included collection workers, materials handlers, mechanics and
hazardous waste program staff. Trainings were held for all eligible employees to explain the risk associ-
ated with needle sticks and to answer questions about HBV vaccinations. Workers were encouraged to
avail themselves of the vaccine but the choice was left to them. A majority of workers signed up for the
series of three injections.
The San Francisco Safe Needle Collection Program (SFSNCP), inaugurated on July 1,1991, is the
culmination of our efforts to remove sharps from the waste stream. The goal of the program is to
provide San Francisco residents with convenient, free needle collection and disposal available at the same
locations where they purchase their needles and medicine. The Program enables City residents to pick up
free plastic sharps containers at 34 pharmacies throughout the City and return them, when full, to any one
of the same locations. The pharmacies temporarily store the filled containers and call designated, licensed
medical waste haulers for pick-up and disposal.
The SFSNCP is the result of a creative coalition of civic officials and solid waste and health care
professionals working together for a common goal. Members of the coalition encompass a broad range of
knowledge and experience from every aspect of a medical sharp's "life cycle," including its manufacture,
distribution, use, disposal and regulation.
The coalition was assembled by Mel Seid, a medical waste inspector for the San Francisco
Department of Public Health, Seid had experience working with the garbage companies resolving medical
waste incidents at the Solid Waste Transfer and Recycling Center and was well versed on the hazards
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sharps pose to garbage workers. Emphasizing the concepts of volunteerism and public/private partnership,
Seid used his contacts in the medical community to bring to the table players with a stake in the problem.
The members of the task force included the following:
• The Office of the Chief Administrative Officer (CAO), City & County of San Francisco. This office
is involved in overseeing all aspects of solid waste management in the City. Initially, the CAO committed
$15,000 for the development and distribution of educational materials during the pilot phase of the pro-
gram. Later, the CAO committed funds to purchase sharps containers on an ongoing basis. This year's
supply of sharps containers will cost approximately $12,000.
* Sanitary Fill's Waste Acceptance Control Program. With direct experience managing hazards in the
garbage, the WACP staff provided insight into local waste handling procedures and represented the inter-
ests of the garbage workers at risk. After the pilot phase, Sanitary Fill assumed responsibility for the ad-
ministration of the program.
• Sharps Container Companies: Becton-Dickinson; Sage; and American Environmental. These
companies manufacture sharps and/or sharps containers, integral elements of both the problem, and the
solution. The companies donated sharps containers for the six month pilot phase of the program. They
divided the program outlet locations amongst themselves and delivered the containers using their normal
systems of distribution.
• Walgreen's Pharmacy. With 27 stores, Walgreen's is the largest pharmacy chain in San Francisco and
is the logical place to anchor a point-of-purchase collection program. Walgreen's, along with 5 public
health centers and 2 hospital pharmacies, distributed empty containers and program information, collected
and stored full containers and contacted haulers for disposal. Walgreen's also contributed $1000 to help
start the program.
• Waste Haulers: Integrated Environmental Services (IES), American Environmental (AE) and
Browning Ferris Industries (BFI). These companies provide collection, treatment and disposal at no
cost during the pilot phase. IES and BFI agreed to continue donating their services on an ongoing basis.
• The American Diabetes Association and the San Francisco Bay Area Association of Diabetes
Educators. These non-profit groups helped coordinate the program and educate ^the public regarding
sharps disposal. They also provided critical insight into the practical needs of diabetics who are the needle
program's largest target audience.
The program started with a six month pilot phase from July 1 to December 31,1991. During this phase,
operational difficulties were ironed out and data were collected for evaluation.
Public Education
Program outreach, sponsored by the CAO's office, and pre-program education for pharmacy staff
started on June 1, one month before the pilot program's start date. A promotional brochure entitled "Don't
Needle Your Garbage Collector or the Environment" was printed in English, Spanish and Chinese and
distributed at all Program outlets. The American Diabetes Association and the San Francisco Bay Area
Association of Diabetic Educators addressed their constituencies in newsletters and through other estab-
lished avenues of communication. Public Service Announcements were written and bus placards were
posted referring people to Walgreen's for containers and brochures explaining the program.
The participation of a prominent company such as Walgreen's with its high visibility and large num-
ber of locations in San Francisco was crucial to the success of the program. Walgreen's serves as a hub
for the distribution of both information and containers. Some people refer to the San Francisco Safe
Needle Collection Program as the "Walgreen's Program," which underscores the public relations benefit
that accrues to companies that donate products and services for the public good. Medical supply compa-
nies and haulers trying to dispel the negative associations between their products and reported instances of
medical waste washing up on the nation's beaches may also be interested in the public relations benefits
of participating in such programs. All of the companies and agencies that donated time, service and prod-
ucts to the Program continue to receive recognition in press releases and printed promotional materials.
The program was introduced to the media at a press conference featuring a garbageman who had been
stuck by a needle. The strong emotional appeal of the garbageman's story attracted representatives from
major local television, radio and print media working in English, Chinese and Spanish. Newsweek and
several national medical journals picked up the story and ran it nationwide. The excellent coverage that
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attended the press conference was an auspicious beginning and invaluable to the quick success of the pro-
gram.
Pilot Phase Results
By the end of the six month pilot phase of the program, 3,413 sharps containers had been distributed
throughout the city and 1,224 (36%) returned. Possible explanations for the low rate of return are: some
containers were not yet full (in order to save money, some needle users re-use syringes two or more
times); some full containers were stored in homes before being returned to an outlet pharmacy. In an ef-
fort to encourage the return of containers to Program outlets, stickers were produced and affixed to the
containers instructing people to return them when full.
Encouraged by the number of participants during the first six months, the coalition looked for ways to
institutionalize the Program and make it permanent. Walgreen's, and the other Program outlets were sat-
isfied with the structure of the Program as it was established and were committed to continued participa-
tion. One of the haulers, American Environmental, dropped out of the Program but the remaining two,
LES and BFI agreed to split AE's collection points in half and continue to service all Program outlets for
free. A problem arose when the sharps container companies decided they could no longer provide free
containers on an indefinite basis. A source of revenue had to be found to purchase containers for the pro-
gram to continue.
Having come this far, Sanitary Fill Company and the CAO's office refused to let the Program die for
lack of resources. Sanitary Fill incorporated administration of the program into the WACP and the CAO
committed funds for containers.
By making needle disposal both convenient and free, the San Francisco Safe Needle Collection
Program is safely managing a significant number of used needles that otherwise might have endangered
public health. From the garbage companies' point of view, the truest measure of success of the San
Francisco Safe Needle Collection Program can be seen in the faces of the garbage workers. They are
grateful for the serious consideration and resources that the Program coalition has focused on a problem
that, for the longest time, they have had to bear alone.
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WHITE GOODS: STATE MANAGEMENT ISSUES AND PROBLEMS
Catherine A. Wilt
Energy, Environment and Resources Center
University of Tennessee, KnoxviUe
White goods are one of the category of so-called "problem wastes" named for the difficult
environmental and management problems that they cause. White goods are any large appliances such as
refrigerators, freezers, air conditioners, stoves, microwave ovens, washers, dryers, garbage disposals, etc.
The U.S. Environmental Protection Agency estimates that as much as three million tons of the annual
waste stream is made of white goods, with less than a ten percent recycling rate.
Compared to the other problem wastes such as used tires, waste oil, lead-acid batteries and
household hazardous wastes, the problems associated with white goods can be more nebulous. Since
appliances are bulky, they take up considerable landfill space. They also pose an aesthetic concern,
particularly in rural areas of the country where they are dumped in ditches or beside bams. The primary
environmental issues of white goods management are the toxic constituents present in some white goods
which are released with improper disposal. Items such as air conditioners, furnace blowers, refrigerators
•and freezers manufactured or repaired prior to 1979 have electrical capacitors which contain
polychlorinated biphenyls (PCBs), a known carcinogen. When capacitors are not removed prior to
recycling or disposal, the capacitors can crack'and contaminate landfills or the metal by-products created
in scrap recycling operations. This is currently a peak time to consider white goods management since
many of the appliances in question are reaching the end of their useful lifespan and are requiring disposal
options. Further, white goods with refrigeration systems contain chlorofluorocarbons (CFCs) and
hydrochlorofluorocarbons (HCFCs) which have been linked to stratospheric ozone depletion; these
chemicals now need special management according to the Clean Air Act.
Historically, most consumers and communities dealt with older appliances by taking them to
landfills, or. relying on local scrap dealers to accept them and segregate them into the second-hand
appliance market or process mem into scrap metal. Appliances contain large quantities of steel and are
an excellent source of ferrous scrap metal; In order to recover the steel and scrap metal in appliances,
they must be shredded with equipment akin to automobile shredders. Once shredded, the stainless steel
and nonferrous metals can be separated from non-metallic components such as plastic, rubber and glass.
However, when white goods are improperly processed several problems arise. White goods with
PCB-contaminated capacitors can taint leftover metal wastes, or "fluff," to unacceptable high levels. As
the regulatory atmosphere surrounding white goods management became more strict, most small scrap
dealers found themselves unable to comply with federal regulations. In a 1988 bulletin to all its
constituents, the Institute of Scrap Recycling Industries (ISRI) stated:
"For environmental reasons, the Board recommends that the industry:
1. Discontinue receiving and processing through any means all appliances and fluorescent light
fixtures unless the processor has taken steps to ensure that, as far as possible, no PCB capacitors
or ballasts are present in a material when processed.
2. Refuse to market or handle any commodities containing appliances or fluorescent lighting
fixtures unless steps have been taken to ensure that, so far as .possible, no PCBs are present in the
commodities."
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State Issues -
As the problems inherent with white goods management are pushed to the forefront, several states
have taken the lead in requiring appropriate management for these items. Thirteen states including
Connecticut, Florida, Illinois, Louisiana, Massachusetts," Minnesota, Missouri, North Carolina, North
Dakota, Oregon, South Carolina, Vermont and Wisconsin have legislated requirements for white goods
management. However, many programs have met with varying degrees of success due to the potential
liability problems associated with their management. The extent of many states' programs is to simply
restrict appliance disposal from landfills, with no promulgated rules or regulations to define alternate
disposal. •
Connecticut
Connecticut legislated requirements under their 1988 Mandatory Recycling Act that ban the
disposal of scrap metals. State regulations define scrap metal as "used or discarded items of predominately
ferrous metals, aluminum, brass, copper, lead, chromium, tin, nickel or alloys thereof, including but not
limited to, white goods and metal food containers." Scrap metals, including white goods, have been
banned from landfills and incinerators since January, 1991.
The responsibility for collection and segregation of white goods and the removal of capacitors and
refrigerants falls upon towns in Connecticut. The state Department of Environmental Protection has
developed an education and training program to train individuals to identify, locate, remove and dispose
of PCB capacitors. Capacitors are placed in 55-gallon drums (it takes about three years for most
Connecticut towns to fill a barrel) until filled; at that point the drum is sent to a facility permitted under
the Toxic Substances Control Act. The cost per barrel for disposal is approximately $900. If contractors
are hired to clip capacitors themselves, they charge approximately $5-10 per appliance.
An agreement with New England's largest utility has given another option to Connecticut citizens.
Northeast Utilities* (NU) made an offer to remove and recycle old appliances at no cost to their utility
customers. NU contracted with Appliance Recycling Centers of America, Inc. (ARCA) of StPaul to build
a new facility in Hartford, Connecticut; the ARCA facility takes customer calls, receives appliances, strips
capacitors and removes refrigerants. In 1991, NU and ARCA removed and recycled over 14,000
appliances, recycled 6,000 pounds of CFCS and providing more than 1,200 tons of scrap metal. The
program also saved NU an estimated 14 million kilowatts.
Florida
An estimated three million used refrigerators, stoves and other appliances are generated annually
in Florida. White goods have been prohibited from landfill disposal since January, 1990. Under Florida's
program, it is the financial responsibility of counties to appropriately manage white goods. They are
stored in designated areas at landfills until they can be picked up for recycling. Most counties in Florida
contract with commercial waste handling companies to handle their white goods.
Maine
While Maine does not specifically ban the disposal of white goods, they do charge an advanced
disposal fee of $5 on all appliances weighing more than ten pounds. The revenues go to a designated fund
to finance the state's solid waste projects.
Missouri
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Over one million appliances are disposed of in Missouri annually. Effective January, 1991, all
major appliances were banned from landfill disposal in Missouri. As a portion of Missouri's .waste
management law, SB 530, the Department of Natural Resources (DNR) recommends that citizens contact
second-hand stores or appliance repair facilities if their appliance is in working condition. If the appliance
is in irreparable condition, the DNR has compiled a list of appliance collection centers around the state
that will take white goods.
North Carolina
In accordance with North Carolina's Solid Waste Management Act of 1991, white goods cannot
be landfilled after January, 1991.
As a component of the solid waste stream, cities and counties in North Carolina are responsible for
management of white goods. There are no state funds available to assist communities in developing white
goods management programs; however, the state Department of Environment, Health, and Natural
Resources has prepared an informational bulletin to assist the development of recycling programs.
North Dakota
No major appliance shall be collected or transported for disposal to any disposal facility unless
that facility is permitted for intermediate storage and recycling of the materials. White goods, as well as
-all other special wastes, must be included in district solid waste management plans.
South Carolina
As part of the South Carolina Solid Waste Policy and Management Act of 1991, several conditions
were placed on the management of white goods. In 1994, it will be illegal to include white goods with
other municipal solid waste intended for transport to a disposal facility. Since November, 1991, an
advanced disposal fee of $2 has been imposed for each appliance delivered by wholesalers to any retail
outlet in the state. Regulations governing the proper management of white goods are expected in early
1993.
Wisconsin
Wisconsin's 1989 Recycling Act 335 established prohibitions on landfilling or burning white
goods as of January, 1991. The law also directs local governments to implement solid waste management
plans that comply with that ban. If managed as part of an "effective recycling program," state grants are
available for the creation of programs that recycle components of the waste stream, including white goods.
According to state officials, almost all of the approximately 500,000 appliances generated in Wisconsin
annually are recycled either by contracts with ARCA or other appliance recycling centers.
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Refrigerant Recovery
Paul Smith — Sanitary Fill Company — San Francisco, CA
INTRODUCTION ;'
Sanitary Fill Company (SFC), a subsidiary of Norcal Waste Systems, Inc., owns and operates the San
Francisco Solid Waste Transfer and Recycling Center (SFSWTRQ which receives and manages San
Francisco's municipal solid waste. The facility receives debris at two sites on property: The Public Dis-
posal Area, which serves as a dumping area for the public, and the Recycling Pad, which is adjacent to the
Transfer Station and where recyclable materials from construction and demolition loads are segregated
from garbage that goes into the Transfer Station Pit and then to landfill. SFC also receives white goods
(household appliances) which largely consist of refrigerators. Most refrigerants used in refrigerators
contain chlorofluorocarbons (CFCs), known ozone depleters. This paper will describe SFC's new pro-
gram which was designed to safely and cost-effectively remove CFCs from refrigerators brought for dis-
posal.
CHLOROFLUOROCARBONS
CFCs were developed in the 1930s as the result of a long search for the perfect coolant for ice-free
refrigeration. Tests were conducted since the early 1800s with a variety of chemicals that easily changed
from a liquid to a gas, but most had serious drawbacks. Ammonia was tried but it could cause serious
acute health problems (including death) if it leaked, and sulfur dioxide was tested, but its unpleasant smell
made it a bad choice.
Freon seemed like the perfect answer. The fluorine atoms make the compound stable and inert,
whereas other coolants degrade over time. Other advantages of freon were that it is non-corrosive, non-
flammable and relatively non-toxic.
It wasn't until the mid-1970s that CFCs were found to have a harmful effect on the atmosphere's
ozone layer, which protects humans and animals on earth from skin cancer, blindness, and weakened
immune systems. A hole in the ozone is also believed to damage the marine food chain.
A 1987 U.N. environmental agreement called for a 50 percent reduction in the production of ozone-
depleting compounds by 1998, and it was subsequently agreed to phase out CFCs altogether by the year
2000. With recent scientific evidence though, the time for elimination of CFCs and carbon tetrachloride
has been moved up to Jan. 1,1996, four years ahead of schedule. Halons are scheduled,to be eliminated
by 1994, four years ahead of schedule, and methyl chloroform is to be banned by 1996, nine years earlier
than previously agreed.
CLEAN AIR ACT
Effective July 1,1992, section 608 of the Clean Air Act prohibits individuals from knowingly venting
ozone-depleting compounds used as refrigerants into the atmosphere while maintaining, servicing, repair-
ing or disposing of air conditioning or refrigeration equipment. Technicians releasing "de minimus"
quantities of refrigerant in the course of making good faith attempts to recapture and recycle or safely dis-
pose of refrigerants are not subject to the prohibition.
The government is currently developing criteria for certifying technicians and equipment involved in
servicing refrigerators and air conditioners, but these proposed regulations are not a part of the Clean Air
Act's rule on venting refrigerants. They will only take effect if the EPA publishes a final rule on them.
PROGRAM DEVELOPMENT
Sanitary Fill has begun an in-house program to extract and recover refrigerants in a timely manner
when refrigerators are received at the facility. This program was developed by the company's Waste
Acceptance Control Program (WACP), one of the three hazardous waste programs at SFC. The main
purpose of the WACP is to keep prohibited waste out of the municipal solid waste stream, thereby
preventing its eventual disposal in landfill. Because of the training and technical expertise of its staff, the
WACP is responsible for addressing special waste issues such as refrigerant recovery that arise at Sanitary
Fill or any of Norcal's San Francisco garbage companies.
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EQUIPMENT
Many different companies manufacture fireon recovery equipment. Sanitary Fill purchased a Katy In-
struments K-3337 Refrigerant Recovery System in part because its weight (16 pounds.) and size (16" x
16" x 16") satisfied our requirement for mobility. Since the company receives refrigerators at two loca-
tions that are about 100 yards apart at different elevations, a light, compact recovery unit was needed. To
transport the unit, SFC purchased a used utility cart (golf cart) and mounted the recovery equipment on
the back. The following is a complete list of equipment used in the refrigerant recovery process:
• Gasoline-powered utility cart
• Katy Instruments K-3337 Refrigerant Recovery System (mounted on gasoline-powered utility cart)
• Manifold and gauge set with hoses
• Vacuum pump
« Piercing valve with control valve
• Tool kit including hammer, screwdriver set, Allen wrench set, and open end wrench set
• Two 25-pound and one 50-pound refrigerant storage cylinders with 80% shut down sensor
• Container for waste compressor oil
• Tool box for storage of loose equipment
• J/B DV-85-142 series deep vacuum pump
PROGRAM COSTS
The initial capital investment in the Refrigerant Recovery Program was less expensive than
anticipated. The cost of the equipment and used utility cart combined were less than $2,000. The filters,
which cost $5-$ 10 each, used in the recovery unit can process approximately 100 pounds of refrigerant
before a new filter is needed.
SAFETY
The WACP is responsible for training the technicians who perform the refrigerant recovery. These
technicians are given instruction on the hazards of refrigerants including routes of exposure, protective
clothing, and eye protection. Refrigerants are hazardous, but the risks of handling freon are minimal if
done properly. Freon can cause frostbite on contact with unprotected skin or blindness if splashed into
the eyes. Fluorocarbon vapors are heavier than air and tend to accumulate in low lying areas. They
replace the breathable air in an enclosed area and can cause a loss of consciousness, cardiac arrest, or even
death if inhaled.
Technicians performing refrigerant recovery are required to wear a full face shield, gloves, long
sleeve shirt} work pants, and^ steel-toed boots. Neither respirators nor self-contained breathing apparatus
is necessary since the recovery process is only done outdoors in well-ventilated areas.
Although most refrigerators processed through the facility contain only a small amount of refrigerant
and relatively low pressure, the technician assumes that each refrigerator is fully charged and may have
20 pounds of pressure in the coil where the piercing valve is attached. The refrigerants are stored in
DOT-approved cylinders marked for the specific type of refrigerant (R-12 or R-22) and the cylinders are
not filled to capacity in order to allow for increases in pressure.
Occasionally, the facility receives ammonia-cooled refrigerators. These can be identified by an
evaporation tray on top of the refrigerator, and a condenser larger than those on most refrigerators.
Ammonia-cooled refrigerators are generally about forty or fifty years old and can be extremely hazardous
if not identified properly. Handling an ammonia-cooled refrigerator the same way as a CFC-cooled
refrigerator can cause serious acute health problems, including death.
PROCEDURES
Appliances containing refrigerants are unloaded at SFC's Recycling Pad or Public Disposal Area and
put in an upright position to facilitate oil and CFC separation. It is preferable that appliances stay upright
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for at least twenty-four hours but removal can still be accomplished upon receipt of the appliance.
Refrigerants can be drained as either a liquid or a vapor. The recovery procedures are as follows:
I. SFC Material Handlers inspect the identification plate on the appliance to determine the refrigerant
type. Two types of refrigerants are used in small appliances, R-12 and R-22, and at no time should
they be mixed in the same cylinder (contaminated cylinders cannot be recycled and must be destroyed).
All cylinders used for collection should be labeled with the refrigerant type. If an appliance contains
an unknown type of refrigerant, a WACP staff person will be called to assist in identifying the
refrigerant.
2. If the collection cylinder on the refrigerant recovery unit is empty, attach the vacuum pump to the blue
or red valve to produce a negative vacuum. This maximizes the full storage capacity of die cylinder.
This step is not performed if the collection cylinder is already partially full.
3. Connect the yellow overfill protector cable to the storage tank. The unit will turn off automatically and
the TANK FULL light will indicate when the cylinder fills to 80% of its capacity. The overfill protec-
tor cable must be connected for the unit to operate.
4. Attach a hose to the suction access port on the appliance's refrigeration system and attach the other end
of the hose to the suction valve on the recovery unit. This hose should be attached to a manifold gauge
to monitor the recovery pressures in the system, The high and low side of the manifold gauge set can
be used to recover refrigerant from two points on the appliance simultaneously.
5. Connect a second hose from the discharge valve on the recovery unit to the blue valve. The blue valve
is the liquid port and allows the recovered refrigerant vapor to bubble up through any cold liquid in the
cylinder and facilitates the transfer of heat. This hose should be kept as short as possible to reduce re-
frigerant emissions when it is disconnected.
6. Open all valves in the line except the DISCHARGE and VAPOR valves on the recovery unit
7. Turn the POWER switch on, then open the DISCHARGE valve and the SUCTION valve. Opening the
DISCHARGE valve before turning the unit on causes pressure to build against the compressor. The
pressure between the unit compressor and the recovery cylinder must be equal before the unit can start.
8. The refrigerant recovery should continue until the pressure in me unit is reduced below zero. The unit
must then be turned off manually by first turning off the POWER switch then closing both the SUC-
TION and DISCHARGE valves. If the unit is left on when the pressure is below zero, the cylinder will
fill with air.
9. When the 25 pound cylinder mounted on the cart has been filled to 80 percent capacity, the refrigerant
is transferred to a 50 pound cylinder for transportation to a local recycling facility.
SUMMARY
SFC developed the Refrigerant Recovery Program to meet the company's needs for mobility,
versatility, and cost-effectiveness. Other organizations such as disposal, recycling, auto repair or
refrigeration companies that have not had to address the issue of freon recovery before the change in the
Clean Air Act may find a similar program equally successful.
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HOUSTON AEROSOL CAN RECYCLING EVALUATION
Greg Crawford, Vice President of Recycling Operations
Steel Can Recycling Institute, Pittsburgh, Pennsylvania
The Steel Can Recycling Institute (SCRI) is an industry association dedicated to promoting and
sustaining steel can recycling. Supported by six domestic and two Canadian steel companies and the
American Iron and Steel Institute (AISI), SCRI has fostered the nationwide growth of steel can recycling.
Through its seven regional recycling managers, SCRI offers assistance to communities and recyclers to
ensure that steel can recycling is implemented in their programs.
For the past four years, SCRI's efforts have focused on building the steel can recycling infrastructure.
Initially concentrating on steel food and beverage cans, SCRI has achieved a 1991 steel can recycling rate
of 34%. The 1992 rate is expected to be even higher.
In the last two years, the recycling focus has broadened to encompass steel general purpose cans,
which include paint and aerosol cans. These containers comprise more than 10% of the total steel can
population. By their recycling, more materials are diverted from the landfill and additional steel scrap is
made available to the steel industry.
SCRI recommends that residential empty paint and aerosol cans be recycled along with food and
beverage cans in curbside and voluntary drop-off programs. SCRI also recommends that aggregate
quantities of full or partially full paint and aerosol cans be processed appropriately so that the scrap steel
can be recovered. The seven regional managers have been meeting with local recycling officials, curbside
operators and recycling processors throughout the United States to secure their participation in this new
and highly positive initiative. As might be expected, many questions were asked and answers given
before commitments have been obtained. Progress was slow at first because there were very few peer
referrals available. This has fortunately changed over the last year as more and more communities
improve their recycling programs by adding empty paint and aerosol cans to the mix.
Amid the earliest of these initiatives was the Houston, Texas curbside recycling program, which
unexpectedly required an aerosol can recycling evaluation. This paper provides an overview of the Texas
steel aerosol can recycling program final report submitted to the Texas Waste Commission (TWC). The
report was approved by the TWC on December 21, 1992. The issues, findings and conclusions of the
report strongly support the advocacy of recycling empty steel aerosol cans together with food, beverage
and empty paint cans.
THE HOUSTON AEROSOL CAN RECYCLING EVALUATION
Early in January 1991, the Steel Can Recycling Institute (SCRI) and the city of Houston reached an
agreement to begin accepting empty steel aerosol cans as part of the city's curbside recycling program.
The collection was set to begin in April 1991. The motivation for the inclusion of aerosol cans was
threefold. First was to prevent them from being landfilled, thus saving landfill space and achieving a cost
avoidance. Second was to reduce the cost and increase die effectiveness of household hazardous waste
collection and disposal by eliminating empty containers from unnecessary and inappropriate inclusion.
Third was to increase the flow of steel can scrap to the steel industry for recycling.
The implementation of the program was postponed after questions were raised as to whether or not
the empty aerosol cans should be treated as a hazardous waste under Texas Water Commission (TWC)
and Texas Administrative Code (TAG) regulations.
An operations plan was prepared by SCRI and approved by the TWC and city of Houston. It was to
evaluate a sample of steel aerosol cans collected on each Tuesday through the city's curbside recycling
program over a period of six weeks. The purpose of the evaluation was to demonstrate the desirability of
recycling steel aerosol cans in a curbside recycling program as well as validate the absence of potential
safety issues involved in collection and processing. The operations plan provided an initial public
education program to advise residents on the preparation instructions for recycling steel aerosol cans.
The city would collect the aerosol cans along with the other recyclables and bring them to the city's Post
Oak Intermediate Processing Facility. The aerosol cans collected on Tuesdays were separated from the
other steel cans for evaluation. Those aerosol cans collected on Mondays, Thursdays and Fridays were
routinely processed with other steel food and beverage cans and shipped to a local scrap dealer for sale to
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the steel industry.
The evaluation process provided that the aerosol cans be numbered, coded by product type, weighed
and emptied. Through a series of measurements, three residual levels were determined: the product
residual, the propellant residual and the combined residual. The collection and evaluation began on
August 4,1992 and concluded on September 8,1992. '"
ACKNOWLEDGMENTS .
The curbside aerosol can evaluation was conducted by Dr. Kenneth Voss, Vice President of Palmer of-
Houston. Dr. Voss spent 19 years as a chemist with S. C. Johnson Wax, for which he was Director of
Research and Development. He served on the Board of Directors for the Chemical Specialties
Manufacturers Association and served as the Vice Chair for their Aerosol Division. Dr. .Voss has served
on the Scientific Affairs Committee of the Cosmetic, Toiletries and Fragrance Association. He also holds
several patents in the aerosol industry.
The statistical analysis of the evaluation data was conducted by Dr. Joe Ensor, a partner in Empirical
Science, a consulting firm in Houston. Dr. Ensor received his B. S. and M.S. in Mathematics from
Arkansas State University and his Ph.D. in Statistics from Texas A&M University in 1989. He has served
as a Visiting Teaching Professor at Rice University as well as the University of Houston. Most recently,
he served as an Assistant Epidemiologist, Department of Patient Studies at the University of Texas M. D.
Anderson Cancer Center in Houston.
The Steel Can Recycling Institute appreciates the support provided by Mr. Ulysses Ford and Mr. Ed
Chen at the city of Houston during the preparation and execution of the operations plan.
The Steel Can Recycling Institute is also grateful to the Texas Water Commission and the Texas
Department of Health who were instrumental in the preparation and approval of the Operations Plan and
review of the final report.
EVALUATION AND ANALYSIS SUMMARY
A total of 1,722 aerosol cans were evaluated from cans collected on Tuesdays. During this period, as
many as 5,000 additional aerosol cans were routinely collected on Mondays, Thursdays and Fridays.
They were not evaluated but, instead, were shipped with other steel food and beverage cans to a local
scrap dealer for processing and shipment to the steel industry.
The following is the evaluation and analysis of residual amounts in the aerosol cans collected on
Tuesdays. They are shown by product code as described in Appendix A.
PRODUCT
CAN CODE
100
200
300
400
500
600
700
800
TOTALS
TOTAL NUMBER OF MEAN COMBINED
CANS COLLECTED RESIDUAL - PERCENT*
252
161
642
297
6
268
72
24
1,722
2.48%
4.56%
2.52%
3.59%
2.79%
1.20%
3.09%
1.21%
2.69%
MEDIAN COMBINED
RESIDUAL - PERCENT*
1.18%
2.06%
1.28%
1.57%
.77%
0.00%
2.02%
.85%
1.18%
* Includes product and propellant residuals.
The mean combined residual of product and propellant is 2.69%, well below the 3% established by
the 40 Code of Federal Regulations, §261.7 (b)(l)(iii)(A). The credibility of the 2.69% is firmly
established by the statistical procedure of the "standard error." The "standard error" provides a level of
confidence that if the total population of curbside aerosol cans could have been tested at once, the results
would be similar. Using two "standard errors," it is statistically established that the level of confidence is
97.75% that if all curbside aerosol cans could have been tested at once, the true mean combined residual
would not be more than 2.95%.
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When reviewing the standard deviation of 5.49%, it is observed that the data points are fairly spread
out, suggesting that an examination of the median might provide a better estimate of the data than the
mean. The median combined residual, or center point of the data, is 1.18%. This means that half of the
data has a mean combined residual below 1.18%, while the other half is greater. The significance of this
is amplified when the top 2% and 5% of the combined residuals are trimmed or isolated from the sample.
Trimming the top 2% and 5% removes those cans that are not representative of the empty can population
and would be considered statistical anomalies. This trimmed data reinforces that very few cans appear as
full or partially full, while the normal condition is empty or nearly empty. It is a truly rare occasion that a
full or partially full can appear in the collection, and such cans were demonstrated as being safely
processed without incident within the mix of all steel cans.
COMBINED RESIDUAL
MEAN . 2.69% MEDIAN 1.18% STANDARD DEVIATION 5.49%
TRIMMED 2% 2.10% TRIMMED 2% 1.18% TRIMMED 2% 2.71%
TRIMMED 5% 1.76% TRIMMED 5% 1.13% TRIMMED 5% 1.99%
When the results on the mean, median and standard deviation are examined with the top 2% and 5%
trimmed, the extent to which they are affected by a few, non-representative cans with high combined
residual levels becomes clear. The median remains largely unchanged, but the mean changes noticeably.
This suggests that the sample contains a very few cans with an unusually large amount of residual which
is not characteristic of the vast majority of cans.
Two other important points should be considered beyond just the statistical data presented. The first
is the fact that the collection and evaluation of the aerosol cans began within two weeks of the distribution
of the public education information, providing consumers little time to be exposed to the program. This
can be seen in the week to week mean combined residuals. Secondly, during the last three weeks, a
marked and consistent reduction in the mean can be seen. In other words, it would appear that residents
began to respond to the instructions requiring the aerosol cans to be empty. Even without further
reduction, the typical aerosol can is virtually empty.
EVALUATION & ANALYSIS DETAIL
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The city of Houston collected the commingled curbside recyclables from the individual resi-
dences and brought them to the Post Oak Intermediate Processing Facility (IPF). Among the recyclables
collected were steel food and beverage cans as well as the emptied aerosol cans.
After unloading at the IPF, the steel and aluminum cans were run through a conveyer system with a
magnetic head pulley at one end. The magnet pulled off all the steel cans and dropped them into bins
under the conveyor. After they were magnetically separated, several employees removed the aerosol cans
from the other steel cans collected on Tuesdays. The aerosol cans were placed into separate bins for
transport to Palmer of Houston for evaluation. All aerosol cans collected, regardless of condition, were
sent for evaluation.
The aerosol cans collected and separated from the other steel cans on Tuesdays were transported to
Palmer of Houston by city personnel. The cans then underwent a seven step process to determine the
residual levels. This process is outlined below.
1. Each can was individually numbered.
2. The net product weight as printed on the can was recorded.
3. The aerosol can was weighed to determine a gross weight of the can and its contents.
4. A small hole was punctured in the dome of the can to allow the remaining propellam to
escape.
5. The can was weighed again to determine an intermediate weight.
6. The top of the can was removed and the contents emptied.
7. The can was weighed again to determine the final weight.
A sample data collection sheet is at Appendix B. Data was. entered into a spreadsheet program in
order to calculate the following information. A sample data spreadsheet can be seen at Appendix C.
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• Propellant Residual Weight was determined by subtracting the intermediate weight from the
gross weight.
• Product Residual Weight was determined by subtracting the final can weight from the
intermediate can weight
« Combined Residual Weight was determined by subtracting the final can weight from the
gross weight and dividing this difference by the net product weight as printed on the can.
This process was continued for the six week evaluation on a week to week basis. At the conclusion of
each weekly evaluation, the data was entered into the spreadsheet computer program. After the results of
the sixth week were entered, the total compilation of data was presented to Dr. Ensor for statistical
evaluation. His statistical analysis and discussion appear in Appendix D. The percent combined residual
mean is presented graphically at Appendix E, demonstrating the 2,69 percent mean. The percent
combined residual by percent is also presented graphically at Appendix E, showing that about 78% of all
aerosol cans collected and evaluated were very empty with three percent or less residual.
As noted earlier, in addition to the evaluation of the 1,722 cans collected on Tuesdays, as many as
5,000 aerosol cans were collected on Mondays, Thursdays and Fridays along with other steel food and
beverage cans and were sent without incident to a local scrap dealer for processing and shipment to the
steel industry.
CONCLUSIONS
The mean combined residual falls well below the 3% specified by 40 CFR §261.7 (b)(l)(iii)(A). It
has been shown that if all curbside aerosol cans could have been taken for evaluation at once, there would
be a 97.75% confidence that the true mean would also fall below 3%.
Additional statistical evaluation shows that the data is closely distributed around a median combined
residual of 1.18% and has a mean of 2.69% with only a few cans over 3%. It has been demonstrated that
collection and processing has occurred without incident fulfilling the objectives of the operations plan.
Thus, it was recommended to the TWC and subsequently approved mat steel aerosol cans be recycled.
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Appendix A
Chemical Specialties Manufacturers Association, Inc.
Food and Non-Food Aerosol Can Product Classification
100 INSECT SPRAYS
101 Space insecticides
102 Residual insecticides (personal and surface repellents, moth proofers, etc.)
200 PAINTS AND VARNISHES
201 Paints, primers and varnishes
202 Other related products (strippers, graffiti removers, snow and other decorative products)
300 HOUSEHOLD PRODUCTS
301 Room deodorants and disinfectants
302 Cleaners (glass, oven, rug, fabric, wall and tile, etc.)
303 Laundry products (starch, fabric finish, pre-wash, etc.)
304 Waxes and polishes
305 Other household products (shoe polishes, dyes, leather dressings, fuels, drain openers,
anti-stats, caulking and sealing compounds)
400 PERSONAL PRODUCTS
401 Shaving lather
402 Hair sprays
403 Other hair products
404 Medicinals and Pharmaceuticals (vaporizers, fungicides, bum treatments, antiseptics,
contraceptives, etc.)
40S Colognes, perfume, etc. and after-shaves
405 Personal deodorants, antiperspirants, powders and deodorant colognes
406 Other personal products (suntan preparations, lotions, breath fresheners)
500 ANIMAL PRODUCTS
501 . Veterinarian and pet products (shampoos, insecticides, repellents, etc.)
600 AUTOMOTIVE. INDUSTRIAL AND MISC. HOUSEHOLD LUBES
601 Refrigerants
602 Windshield and lock spray de-icers
603 Cleaners (auto upholstery, leather, vinyl, tire, etc.)
604 Engine degreasers
605 Lubricants and silicones (penetrating oils, demoisturizers, rust proofing)
606 Spray undercoating
607 Tire inflator and sealants
608 Cart) and choke cleaners
609 Brake cleaners
610 Engine starting fluid
611 Other automotive and industrial products (adhesives, etc.)
700 FOOD PRODUCTS
701 All types (including pan sprays)
800 MISCELLANEOUS
801 Other products not listed above
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Appendix B
Aerosol Can Data Collection Log
Inspection Date: P/
Page <£ of /7
Aerosol
Can
Code
Net
Product
Weight*
(oz.)
Gross
Can
Weight
(02.)
Inter- Final Residual
mediate Weight Weight
Weight (oz.) (oz.)
" 3Q3
" 30?
'3o\
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(03>n.
( (2_or
Qi^i
to&xt c
jCfl^ ^
ID
q
cteaj 3F)
LVfc
.ioS"
*S* Product weight as printed on the cati
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Appendix C
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Appendix D
Trimmed Analysis of Combined Residual
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MEAN .
TRIMMED 2%
TRIMMED 5%
MEDIAN
TRIMMED 2%
TRIMMED 5%
ST. DEV.
TRIMMED 2%
TRIMMED 5%
TOTAL
2.69%
2.10%
1.76%
1.18%
1.18%
1.13%
5.49%
2.71%
1.99%
WEEK 1
2.55%
2.11%
1.66%
1.18%
1.13%
1.10%
4.32%
2.89%
1.66%
WEEK 2 .
3.06%
2.26%
1.83%
1.18%
1.18%
1.12%
5.98%
2.96%
2.10%
WEEKS
2.65%
2.36%
1.72%
1.18%
1.16%
1.12%
4.09%
3.30%
2.16%
WEEK 4
2.89%
2.13%
1.99%
1.47%
1.44%
1.44%
6.46%
2.15%
1.85%
WEEK 5
2.60%
1.89%
1.67%
1.16%
1.10%
1.06%
5.62%
2.46%
1.92%
WEEK 6 •
2.38% •
1.96% I
1.68% T
1.13% I
1.12% »
1.04% [
5.26% 1
2.60% T
2.00% 1
Obviously, trimming the top 2% or 5% of the percentage of combined residual has an enormous effect on thfl|
mean (the arithmetic mean or average of a population is simply the sum of the measurements divided by the number of
measurements). To illustrate the large amount of skew ness in the data, compare the standard deviation of the raw datl
and the top 2% trimmed data. The standard deviation is reduced by 50% (5.49 vs. 2.71). If one compares the medi
of the different methods, one sees almost no change even between the raw data and the top 5% trimmed data. Sin
the mean is greatly affected by extremely large (or small) observations and the median is not, the median is preferre
new
I
in locating the center of skewed distributions (i.e., distributions thai are asymmetric and tail off rapidly to the right
or left). This mandates using the median to measure the center of the distribution of percentage of combined residuaM
because the median measures the point in the data in which exactly half of the ranked data lies below and half above.
The estimated mean of the percentage of combined residual is 2.69%. This estimate plus twice the standard error,
i
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I
does not exceed the 3% level. Recall, when the standard deviation of a statistic is estimated from the data, the result il
called the standard error of the statistic. One realizes that 2.69% is only a point estimate of the true mean percentage
of combined residual; that is, it only an unbiased estimate of the true mean percentage of combined residual. LargB,
sample theory .of statistics tells us that the probability that the true mean is actually more that 2 standard error
above the point estimate is only .0225. Hence, there is only a very small chance that the true mean residual is 3?
more.
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Appendix E
Percent Combined Residual
Ds% Trim Mean D2% Trim Mean HMean
Percent Combined Residual
50%
Percent Residual
— 2.69, M.
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FEDERAL LIABILITY ISSUES FOR HHW COLLECTION PROGRAMS
John Fogarty - U.S. EPA Office of Enforcement
(The views expressed herein do not necessarily represent the official position of EPA)
Introduction
o The principal Federal laws governing liability for household hazardous waste (HHW) are the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the
Resource Conservation and Recovery Act (RCRA).
o f There are other laws and liability issues that will affect HHW collection programs, such as
local siting regulations, compensation for workers' injuries, accidental spills, etc. As a matter
of Federal environmental law, however, RCRA and CERCLA are the two laws of primary
importance for municipal liability purposes.
The HHW Liability Problem
o All municipal wastes present a potential liability problem for municipalities because of the
small percentage of hazardous constituents ordinarily contained in such wastes. While there is
always a liability potential for these wastes no matter how disposed, there are steps that can be
taken which will minimize that risk.
o The clear message of the structure of the Federal laws is that HHW collection programs, by
diverting hazardous wastes out of the municipal waste stream (and away from CERCLA
liability) and into RCRA-permitted facilities, are the best thing that can be done to minimize
potential Federal liability.
o Under RCRA municipalities are basically exempt from liability for HHW, while under
CERCLA municipalities are generally liable for their hazardous wastes. Therefore, by
diverting the wastes into the RCRA system the potential for liability is diminished.
Under RCRA, wastes are classified as hazardous, in which case they must be disposed of in
accordance with Subtitle C requirements for hazardous waste facilities, or classified as non-
hazardous, in which case the less stringent disposal requirements of Subtitle D apply.
Most importantly RCRA liability purposes, HHW is unconditionally exempt from the
definition of hazardous wastes subject to the Subtitle C disposal requirements.
HHW is exempted not .because the wastes are not hazardous, but because the source of the
wastes is households (which includes single and multi-family residences, hotels, campgrounds,
etc.). For the exemption to apply, the wastes must be derived from these sources only. The
same substances, if derived from commercial or other sources, are classified as hazardous
wastes under RCRA.
While RCRA does not require that the hazardous constituents be separated out of the
municipal wastestream, not doing so is risky.
The risk is presented by the potential for CERCLA liability where the HHW is disposed of in
municipal landfills regulated under Subtitle D. The exclusion of HHW from the definition of
hazardous wastes applies only to RCRA-it does not translate into an exclusion under
CERCLA.1 Under CERCLA, it is the hazardous character of the substance, and not its
source, that is important. If the hazardous constituents of household wastes are not separated
out from the municipal wastestream, the potential for CERCLA liability increases.
1 In recent CERCLA litigation the RCRA exclusion has been unsuccessfully argued to provide an exemption
from CERCLA liability. See B.F. Goodrich v. Murtha. 754 F. Supp. 960 (D. Conn. 1991).
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CERCLA
o Management and collection of HHW under RCRA can be a complex and sometimes expensive
undertaking. However, if municipal wastes cause or contribute to an environmental problem,
the potential for liability under CERCLA is far greater than under RCRA.
o Under CERCLA, If there is a problem, there are several key liability principles that mean a
potentially large exposure for a municipality:
.-. j* o 1st: The principle of strict, joint and several liability for all costs of cleanup. Of the
1200-plus CERCLA sites on the National Priorities List for cleanup, about 25% are
-;7; municipal landfills. The cost to remediate these, landfills usually runs into the tens of
millions of dollars.
o 2di Standard "reopeners" in CERCLA settlement agreements-which require additional
work if the initial cleanup is insufficient-mean that a cloud of potential liability will
remain even after court settlement.
o 3rd: Under best circumstances, a municipality may be treated as a de minimis
contributor of waste, or may be required to pay a proportionately smaller amount
under an allocation scheme with other contributors of waste. However, because of the
usually high costs to remediate municipal landfills, even a de minimis settlement can
be expensive.
o 4th: Under an EPA policy issued December 12, 1989 (Vol. 54 Federal Register, page
51071), EPA ordinarily does not prosecute municipalities under CERCLA where the
only evidence of disposal by a municipality is of solid wastes. However, the EPA
Policy does not affect contribution or third-party actions, and the number of such cases
is increasing. EPA has recently undertaken a "municipal initiative" to protect cities
and towns from unfair lawsuits filed against them by private parties for MSW.
o If the hazardous component of municipal wastes are diverted into the RCRA wastestream, the
potential for liability diminishes.
RCRA & HHW Collection Programs
o The liability issues for HHW collection programs center on how the waste is collected and
* packaged for disposal. In general, to minimize both the legal and environmental risks, it is
recommended that HHW be handled in the same manner as any fully regulated RCRA Subtitle
C waste.
o After this, the biggest liability challenge is to ensure,that the waste being collected is in fact
from households, and is of a type and quantity expected to be used by households. The
exclusion for HHW does not apply to wastes from small businesses or other small generators
of hazardous wastes, because these wastes are not from households. These commercially-
derived wastes are considered hazardous and are subject to the RCRA Subtitle C requirements.
o Once collected, to minimize legal and environmental threats it is recommended that HHW be
disposed of in a properly permitted RCRA hazardous waste facility. Occasionally die RCRA
facility accepting the HHW will want the collection program sponsor to sign the RCRA
manifests showing the sponsor as the generator. This is not required by RCRA and the
collection sponsor cannot legally be considered to have generated a RCRA hazardous waste
because HHW exempted under RCRA. Therefore, it is permissible to sign the manifests when
requested because doing so will not change the fact that HHW is an exempted waste, nor does
it alter a sponsoring municipality's liability.
o Some more aggressive HHW collection programs accept hazardous wastes from small
businesses, schools, and other entities that generate small quantities of hazardous wastes.
"Small quantity generators" (SQGs) are defined as those that generate less than 100 kg/month
(220 Ibs/month). Wastes from SQGs are considered hazardous under RCRA, but if disposed of
in a Subtitle C hazardous waste facility they are conditionally exempt from some of the RCRA
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permitting and manifesting requirements. It also means that if the HHW collec-tion program
is sending its wastes to a Subtitle C facility, it can also accept the SQG wastes.
o If both HHW and SQG wastes are collected, they must not be mixed. If mixed, a new waste
is created, and both the unconditional exemption for HHW and the conditional exemption for
SQG wastes do not apply. If mixed, the program sponsor may be considered to be a waste
generator subject to some or all of the Subtitle C requirements, and fully liable on that basis.
Limiting the Liability Potential
o Under CERCLA, a municipality is largely without protection from liability for its disposal of
hazardous substances. Under RCRA, in the case of a failure of the facility containing HHW
and SQG wastes, there are several protective layers insulating a municipality from liability.
o HHW collection programs divert hazardous wastes to a facility that is designed to handle such
wastes. Consequently, it is unlikely that an environmental problem will be created in the first
instance.
o If there is a facility failure and environmental harm, the owner or operator of the RCRA
facility is primarily liable, and the RCRA structure is intended to ensure that the
owner/operator is sufficiently well-funded to afford the necessary cleanup activities.
o Even if the RCRA owner/operator cannot undertake cleanup, the RCRA system has financial
assurances built in to it so that closure funds should be available.
o Therefore, by diverting HHW from disposal in ordinary solid waste landfills and instead
arranging for such wastes to be disposed of in a reputable RCRA Subtitle C facility, a
municipality will minimize the potential liability it faces for HHW.
Special Note for Permanently-Sited HHW Collection Facilities--
Emergencv Planning & Community Right-to-Know Act (SARA Title IIP
o EPCRA was enacted in response to the 1984 Bhopal, India chemical disaster in which over
2000 people were killed as the result of a leak of methyl isocyanate from a Union Carbide
fertilizer plant. EPCRA establishes a network of state and local system of emergency response
teams (Local Emergency Planning Committees or LEPCs, and State Emergency Response
Commissions, or SERCs) to enable communities to better respond to a chemical hazard
emergency. LEPCs are made up of community representatives, including the local
community's emergency responders (citizens, police, fire, hospital officials, etc.).
o EPCRA requires periodic reporting by certain covered "facilities" of the presence, location, and
quantities of listed "extremely hazardous substances" (EHSs).
o Although there is little chance that a permanently-sited HHW collection facility will aggregate
sufficient quantities of EHSs to trigger the EPCRA reporting requirements, because hazardous
substances (even in small quantities) may present some danger, it is advised that information
about the HHW facility be provided to the SERC and LEPC so that local authorities can
include the facility in their emergency response plans.
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The Resource Conservation and Recovery Act and Household Hazardous Waste
Charlotte Mooney
U.S. Environmental Protection Agency, Washington, D.C.
I. Introduction
x_ The Resource Conservation and Recovery Act (RCRA), which was signed into law in 1976, was
enacted to address a problem that more and more communities were recognizing as a serious dilemma:
how to safely dispose of increasing volumes of municipal and industrial wastes generated by our society.
Subtitle D of the statute assists states in developing plans for management of primarily nonhazardous
municipal waste. Subtitle C of RCRA directs the Environmental Protection Agency (EPA) to develop
federal regulations controlling management of hazardous waste. This paper describes how household
hazardous waste (HHW) is addressed under the Subtitle C regulations and how the hazardous waste
regulations may affect collection programs.
2. History of the Household Hazardous Waste Exclusion
In 1980 EPA first promulgated a comprehensive set of regulations governing hazardous waste
management from "cradle to grave," or from the waste's point of generation through storage,
transportation, treatment, and final disposal. These regulations set up a two track system for identifying
which wastes are regulated as hazardous. First, a number of industrial wastes were specifically listed as
hazardous. Second, four characteristics were defined to identify nonlisted hazardous wastes. The four
characteristics are ignitability, corrosivity, reactivity, and toxicity. Wastes that exhibit these characteristics
are regulated as hazardous wastes.
As part of the 1980 regulations, however, a number of wastes were specifically excluded from
being considered regulated hazardous wastes. Household waste was one of these excluded wastes. The
regulatory exclusion, which has been expanded somewhat since 1980, is found in Section 261.4(bXO of
Tide 40 of the Code of Federal Regulations (CFR) and reads as follows:
§ 261.4(b) Solid wastes which are not hazardous wastes. The following solid wastes are
not hazardous wastes:
r (1) Household waste, including household waste that has been collected, transported,
£ stored, treated, disposed, recovered (e.g., refuse-derived fuel) or reused. "Household
waste" means any material (including garbage, trash and sanitary wastes in septic tanks)
derived from households (including single and multiple residences, hotels and motels,
bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds and day use
recreation areas)....
The regulation goes on to address the status of wastes and residues managed by resource recovery
facilities.
The household waste exclusion was not expressly identified as an exclusion in the statute as were
many of the other exclusions promulgated in 1980. However, the fact that Congress did not intend for
household waste to be regulated as hazardous was documented in the Senate Report for RCRA which
reads, in part:
[The hazardous waste program] is not to be used to control the disposal of substances
used in households or to extend control over general municipal wastes (used on the
presence of such substances. (S. Rep. No. 94-988, 94th Congress. 2nd Session at 16)
It should be noted that the common term "household hazardous waste" may be somewhat
confusing -- in that household waste is specifically excluded from the regulatory definition of hazardous
waste. Thus, HHW actually is not hazardous waste in the regulatory sense, although it may nevertheless
be dangerous or pose a threat to human health or the environment.
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3. Scope of the Household Hazardous Waste Exclusion
EPA has interpreted the 40 CFR 261.4(b)(l) household waste exclusion to include materials that
meet both of two criteria: first, they must be generated by individuals on the premises of a temporary or
permanent residence for individuals; second, they must be composed primarily of materials found in the
wastes generated by consumers in their homes.
The first criterion limits household waste to materials generated at single and multiple residences,
hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic areas and day-use
recreation areas. Wastes generated by establishments such as retail stores, office buildings, restaurants,
shopping centers, and small commercial operations clearly are not generated on the premises of a residence
for individuals, and thus are not excluded under the household waste exclusion. If these wastes are listed
or exhibit characteristics they must be managed in compliance with the Subtitle C hazardous waste
regulations. The second criterion limits household waste to materials composed primarily of materials
found in wastes generated by consumers in their homes.
Since household wastes are specifically excluded from being considered hazardous wastes by 40
CFR 261.4(b)(l), they are not regulated as hazardous waste even if they exhibit any of the four
characteristics, i.e., if they exhibit the characteristics of ignitability, corrosivity, reactivity, or toxicity.
Thus, the same wastes that would be regulated as hazardous when generated by a nonhousehold (i.e.,
commercial or industrial) establishment, are not regulated as hazardous when generated by a household.
Examples of such wastes that may be generated in both household and nonhousehold settings include
pesticides, photographic chemicals, pool maintenance chemicals, and cleaning solutions, each of which
may exhibit the characteristics of toxicity, corrosivity, and/or ignitability.
4. Managing Household Hazardous Wastes
Since 40 CFR 261.4(b)(l) excludes household waste from the definition of hazardous waste, HHW
is not subject to the hazardous waste regulations throughout all phases of its management Consequently,
the householder generating the waste is not subject to the hazardous waste generator regulations (40 CFR
Pan 262), any persons or organizations transporting the waste are not subject to the hazardous waste
transporter regulations (40 CFR 263), and any persons or organizations treating, storing, or disposing of
the waste are not subject to the hazardous waste treatment, storage, and disposal facility regulations (40
CFR Parts 264 and 265). In addition, household waste is not subject to the land disposal restrictions
regulations (40 CFR Part 268) which require that hazardous wastes be treated to meet specified standards
prior to any land disposal.
Thus, household hazardous waste collection programs collecting, storing, treating, transporting,
and disposing of household waste are not required to comply with the hazardous waste regulations as long
as they ensure that all waste collected actually is household waste.
EPA however, recommends that programs collecting HHW nevertheless manage the collected
HHW as hazardous waste.1 Management as hazardous waste is recommended to ensure the greater level
of protection provided by Subtitle C controls. The Agency recommends that program managers follow
the following waste management hierarchy: first, reuse and recycle as much waste as possible; second,
treat in a hazardous waste treatment facility; and third, dispose of remaining waste in a hazardous waste
disposal facility. The Agency further recommends the use of licensed hazardous waste transporters who
will properly identify, label, manifest, and transport the collected waste from the collection location to
treatment or disposal facilities.
HHW collection programs that decide to avoid any requirement to comply with Subtitle C
regulations by managing only waste excluded under the household waste exclusion should develop and
implement procedures to ensure that all received waste is actually household waste. Because the exclusion
'Letter dated November 1,1988 from J. Winston Porter, Assistant Administrator for Solid Waste and Emergency
Response, U.S. EPA, to Waste Management Division Directors, Regions I-X.
144
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is based on the source of the material, determining whether a specific waste is covered by the 40 CFR
26l.4(b)(l) household waste exclusion may be difficult if the origin of the waste is not identified. This
difficulty highlights the importance of educating users of household hazardous waste collection programs,
and of checking the origin of waste received. Without questioning individuals bringing waste to a
collection program it may be impossible to. verify that- the waste is actually household (rather than
commercial or industrial) waste.
& The following examples illustrate this difficulty.
s* • Spent photographic solutions generated by a recreational photographer in his or her home
are household waste and are excluded from the hazardous waste regulations, because they
are generated by an individual at a.residence, and could be considered similar to wastes
generated by a consumer at home in the course of daily living.
• Spent photographic solutions generated by a recreational photographer while using rented
space and equipment at a professional photographic studio are not household waste
because they are not generated at a residence, but at a commercial place of business.
• Spent photographic solutions generated by a small photo developing shop in a shopping
mall are not household waste because they are not generated at a residence, but at a
commercial place of business.
As can be seen from these examples, distinguishing between excluded household wastes and
nonexcluded wastes is not necessarily easy. Thus, programs planning to manage only exempt household
waste should educate their staff, as well as users of the programs, in the kinds of wastes that can be
accepted and those that can not. Such programs should develop and implement procedures to identify and
accept only household wastes.
5. State Regulations
Although household waste is excluded from the federal hazardous waste regulations, in many
states the hazardous waste program is implemented by state agencies, using state regulatory analogues
rather than the federal regulations. Thus, HHW collection programs should check with their state
hazardous waste regulatory agencies to determine whether there are any additional requirements under state
hazardous waste regulations.
i In addition, program managers should be aware that nonhazardous waste (solid waste) management
~may be regulated by states under state law. Thus, there may be state solid waste management regulations
that are applicable to the management of HHW within the state.
145
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Marketing Recycled Paint
Anne Thorson, Environmental Health Specialist
Washington County Department of Public Health, Stillwater, Minnesota
«
Before you can begin marketing recycled paint, you must first have an understanding of what
marketing is. Markets is defined as "sets of actual or potential buyers who have a willingness and the
means to purchase and demand products". First of all, there has to be a demand or a need for the recycled
product If there is not a use or demand for the material, recycling will not work.
Successful marketing depends on your knowledge of what and how much is coming in (or supply)
and what and how much is going out (demand). You have to know what you are going to get in and what
people want. (Attachment A) On the supply end of market development, you must know where your
supply is coming from (HHW Collections, VSQG), how much will be coming in and in what form it will
arrive in. On the demand end, you must identify end users of the paint, what they want in terms of type
of paint and color, how often they will need it, what size of container they want the paint in and the cost
(free or for a price).
The type of collection method and the type of recycling process you use depends on the resources
available, and the commitment to recycling in the local area. There are many ways to market recycled
paint, depending on how elaborate the recycling process is. It can be as simple as a give away or reuse
program. This can occur at one day collections or at permanent HHW facilities. Paint can be
consolidated into 5 gallon pails or it can remain in gallon or quart containers. End users include: painting
contractors, waste haulers, small businesses, golf courses, homeowners, 4-H groups, cities, or counties.
It is important to locate end users of paint before a one day collection, so you're not stuck with good paint
at the end of the day - especially if you do not have a place to store it. In Ithaca NY, the Recycling
Coordinator sent letters to potential paint users before the collection. The letter offered them the
opportunity to receive free, good quality paint. Reservations for paint were taken, and the number of
orders exceeded the amount of paint that came into the collection. Contact: Barbara Hotchkiss, Tompkins
County, 607-273-6632)
At permanent sites, usable paint can be offered to people on a regular basis - orders can also be
taken and filled as needed. Tri-County Solid Waste Management Commission in St. Cloud, MN has a
Product Exchange at their permanent HHW facility. Residents and businesses are invited to take, free of
charge, what they wish from the product exchange. Over 2445 gallons of paint have been reused at Tri-
County's Product Exchange. A staff person at Tri-County Solid Waste Commission actively markets the
paint and other materials to residents and groups such as the Children's Home, St. Cloud Housing
Coalition, recycling and waste haulers, schools, greenhouses, wildlife and conservation groups, senior
citizen centers and farms. (Contact: Kent Dahlquist, Tri-County Solid Waste, 612-255-6142)
A city in New Hampshire is setting up a clearinghouse for paint and other usable materials. The
city doesn't actually handle the material, but tells residents to call the Public Works Department if they
have usable material to give away. They enter the information into a data base - if someone calls in
wanting paint, they given them the donor's telephone number. (Contact: Town of Exeter, Department
of Public Works, 603-778-0591)
Some communities are offering a more sophisticated approach to paint recycling. In Portland
Oregon, staff at the HHW facility follow a very detailed sorting protocol. Following sorting, the paint
is poured into 55 gallon drums after it has been screened and filtered. Currently they are offering this
paint to government agencies and non-profit organizations, such as:
-Project 2000 - Low income housing -Arbor Neighborhood Association - Grafitti removal
-Historic Kenton Hotel - paint interior rooms -Salvation Army
-Grant's Pass Gospel Mission - exterior of 3 church buildings
-Yamhill County Fairgrounds - Fairground buildings
146
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Between 5 and 10 different colors are available. The new county office building will be painted
with recycled paint, (Attachment B) Portland is also working with a local paint manufacturer. The
manufacturer accepts usable paint in 55 gallon drums from the HHW facility at no charge. He may or
may not add virgin material to the paint, depending on the quality of the paint. The paint is then sold to
contractors for $5.00/gallon (in 5 gallon buckets) or for $6.00/gallon (in 2 gallon buckets). The paint is
being used by contractors as a primer or surface paint. Portland's program is an example of how
government and private industry can work together to produce and market recycled paint (Contact: Jim
Quinn, Portland METRO, 503-221-1646)
The State of California is considered by many to be leaders in the area of paint recycling. In the
Sacramento area, recycled paint has been used to paint bus benches, forestry service buildings, fairgrounds,
apartment buildings and other items that have to be painted routinely. Recycled paint is also used to cover
up graffiti. They view recycled paint as a "utility" paint, not as a substitute for virgin paint. The
government primarly markets the paint. (Contact: Masood Mesbah, California Department of General
Services, 916-445-1846)
Marin County, California is working with a local paint manufacturer. The paint is consolidated
into 55 gallon drums (no sorting by color takes place) and is transported to Standard Brands Paint
Company. Standard Brands then transports the paint to their Southern California paint manufacturing plant
where the paint is combined with wash water generated from plant operations. Chemicals are then added
to produce a basic recycled paint. The basic paint is either given away to the community or is used by
Major Paint as a "base" for producing recycled product lines for exterior use. "Cycle II" Recycled Latex
Paint is available in flat, semi-gloss and as a primer. (Attachment C,D) Latex flat is available in 11
colors, semi-gloss in 9 colors and 1 color is available in the primer. The County of Marin gave away
3,713 gallons of recycled paint to 19 businesses, 62 individuals and 23 federal, state and local government
agencies, in exchange for providing feedback on the performance of the paint. All responses received to
date have indicated they are satisfied with the overall performance of the paint. Standard Brands is
currently selling the Cycle II paint in retail stores. Marin County and Standard Brands is another example
of government and private industry producing and marketing recycled paint. (Contact: Gina Purin, Marin
County 415-499-6647 or Hubert Kim, Major Paint Company, 310-542-7701)
A fairly new recycling paint company is now operational in Massachusetts. The Green Paint
Company accepts latex and oil paint in original containers. Once the paint arrives at the factory, it is
sorted by trained staff. The paint then goes through a reformulation process and is available in a quality
form. The Green Paint Company intends to market the paint to four sources:
The first market is those businesses that are "into recycling", as they have already demonstrated
a commitment to use recycled products.
The second market will be businesses that have expressed an interest in promoting recycling
through their association with organizations involved in recycling, such as the National Recycling
Coalition.
The third targeted group is federal, state and local governments - they are under pressure to "buy
recycled". They are also a large user of paint products. :
The fourth market is the mass merchandise store. Once the word catches on that recycled paint
is good, homeowners will want to purchase the paint at the retail level.
The Green Paint Company is the first private company to take a comprehensive approach to paint
recycling - as primary recyclers they will collect, process and market a quality, recycled post-consumer
product (Contact: Steve Greenberg, Green Paint Company, 508-655-8560)
In summary, remember that it is vital to have a need or demand for the recycled product. You
can't sell ice to an eskimo. People will not buy it if it the wrong color or finish. Find out what the needs
are and know who will buy or use it. The actual marketing can be done by the government agency, the
paint manufacturer, or a combination of both.
147
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Actacnmeru .-.
PLAN FOR MARKETING RECYCLED PAINT
•SUPPLY-
SuppIi er
HHW COLLECTIONS
VSQG's
How Much Will They
Supply?
In What Form?
ORIGINAL CONTAINERS
OR 55 GALLONS DRUMS
•DEMAND-
Who Will Use
It?
Contractors
Farms
Parks
Homeowners
Businesses
Non-profit
Organizations
Cities
Counties
Schools
What Do They
Want?
Latex or Oil
- Flat
- Semi -gloss
- Primer
- Interior
- Exterior
Colors
How Much and
How Often Do
They Need?
Size of
Container
1 Gallon
5 Gallons
55 Gallons
Cost
148
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SMAJOR BUNT COMPANY
SEAL BLACK
NET! FIVE GALLONS (li.SW'LTreiB)
I Exterior/Interior Finish
j. .
I Recycled Latex Paint
I Quick Dry Formula
I Excellent Coverage
Major Paint Company is proud to introduce Cycle n Recycled Latex Paint, the latest
addition to our line of quality paint products.
Cycle II contains me POST-CONSUMER LATEX PAINT from community . .
household hazardous waste programs. - ' .'
It is a high quality coating for exterior and interior surfaces, including concrete,
wood, masonry and textured walls. Cycle II flat and semi-gloss finishes are
durable, washable and stain resistant. Thei semi-gloss finish is also reinforced to
prevent flash rust.-' , ....
Cycle II Latex Primer is designed as a stain blocking and flash rust inhibiting appli-
cation for use on wood and metal surfaces. It can be used as a, general purpose
primer on all surfaces.
/ - \ m m
Cycle II line is available in 1 1 colors for flat, 9 for semi-gloss, and 1 for primer.
-v
Cycle II complies with all pertinent Federal, State and Local Regulations.
For additional information, please call 31*0* 542 • 7701 ext2167.
Printed on Recycled Paper
153
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PAINT REUSE AND RECYCLING CONSENSUS MEETING
Tracy Bone
Paint, by volume, is -the largest wastestream brought into
household hazardous waste collection programs (HHWCP). Much of
the paint is either useable (40 to 90 %} and/or of low
environmental concern (as compared to HHW in general). Disposal
(as a hazardous waste) is the largest cost of a HHWCP. In the
interest of reducing the disposal costs of HHWCPs and
facilitating resource recovery of our resources, EPA has targeted
paint as a wastestream to be considered for innovative management
strategies.
Several communities around the country have found ways to
manage the paint they collet other than as a hazardous waste.
EPA brought these people as well as representatives from the
paint industry together to identify and discuss the barriers to
paint management.
The group quickly and unilaterally agreed that source
reduction is the most important tool for solving the excess paint
problem. Several paint manufacturers are considering putting on
their paint labels language to indicate that the consumer should,
"buy only what you need, use it up if possible, and give away any
paint that can not be used up." 'HHWCP managers agree that they
must continue to push source reduction through their community
outreach mechanisms.
Toxicity reduction (through paint reformulation) and source
reduction education have made and will continue to make great
strides in reducing the excess paint problem. However, there
will continue to be, to some extent, excess paint for HHWCPs to
deal with. While waste-to- energy incineration is a management
option for some paints and some HHWCPs, this is not an options
for some programs. The discussion then turned to paint
recycling, specifically discussed were the existing programs and
the barriers to paint recycling.
Industry representatives pointed out some of their concerns
connected with paint recycling: contamination of manufacturing
equipment,•product 'liability, consumer satisfaction, labeling,
permitting, marketability, and disposal of wastes created during
or received for paint reprocessing. Additional barriers brought
up by HHWCP sponsors included: color availability, cost to the
•program and consumer, cost of contamination testing and paint
sorting protocols. The group then broke into 3 smaller
discussion groups: Markets and Funding, Regulatory Barriers, and
Technical Barriers.
There were several points that came out in the summary session:
Source reduction deserves highest priority in any paint
waste management plan;
HHWCPs are a' better collection strategy than for paint to be
returned directly to the manufacturer or distributor;
There are acceptable sorting protocols available (they need
to be made widely available);
Testing for contaminants is necessary in many cases,
however, .it must not be prohibitively expensive;
Recycling should not be mandatory for every paint
manufacturer — smaller non-automated paint firms are the
best candidates;
There is no single type of paint recycling program that will
ensure success — the program should be designed at the
local/regional level with input from local paint
manufacturers and distributors.
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Government Procurement Procedures
for Recycled Paints
Carolyn Dann — The Waste Watch Center
Military and Non-Military Procurement
There are two major groups of buyers within the Federal government procurement system: the Defense
Logistics Agency (DLA) and the General Services Administration (GSA). The DLA orders military-
related supplies such as guns, tanks, and airplanes, and supplies that are critical for them, including paint
for airplanes and tanks. The military may also use more household-variety supplies but these are
purchased through the GSA, such as chairs, toilet paper, and general building paint Other agencies within
the Federal government also contract with GSA to supply them with their basic supplies.
Public Building Services and Federal Supply Services
Within GSA, there are two groups that both supply materials and both can order paint, the Public Building
Service (PBS) and the Federal Supply Service (FSS). The PBS is responsible for providing real estate
for other Federal agencies. This group contracts for the maintenance of the buildings and grounds for the
1,600 or more buildings owned by the Federal government and the roughly 5,500 other buildings that are
leased by the Federal government These buildings can include offices, warehouses and a wide variety
of other types of buildings. Potentially, PBS could require the use of reformulated paints in its
maintenance contracts.
The FSS is the group that contracts for general goods and services that are used by agencies, military
bases, and other groups within the Federal government. The FSS is responsible for setting up contracts
for and developing and maintaining specifications for thousand of commercial, common use items
including paint. FSS negotiates and sets up large contracts for items and purchasing agents throughout all
Federal agencies can then use these large contracts to buy what they need. A group that needs paint, for
example, can order it off a GSA supply list by referring to its National Stock Number (NSN), which for
the category of products known as latex paints is NSN-8010. The NSN numbers refer to specific types
of paint that have been tested and are known to have met a certain set of specifications. FSS stores many
items in large warehouses and ships to customer agencies. Other items are shipped directly from the
vendor to the ordering agency.
The procedure for ordering involves entering a request into a computer system by using the NSN number.
The system sends all paint requests to a certain computer listing which gets transferred to a paint supply
warehouse that ships the requested quantity of the particular product to the requesting group's warehouse.
The request for recycled paint has to originate with the requesting group; just having an supply of recycled
paint available does not necessarily mean that anyone will use it As it true with the rest of the world,
someone must create a demand for the product. We have just recently contacted people within the
military to notify them that this recycled paint is available through FSS and to encourage them to use it
for certain types of projects.
The procedure for supplying paint to the FSS involves developing and testing a type of recycled paint
against existing specifications, TTP-19 (LP) and TTP-29 (SBP). If the recycled paint meets these
specifications, the manufacturer should contact the Paint and Chemical Commodities Supply Center
(Patricia Pearson, 206-931-1720) in Auburn, WA and ask to get on the bidders list for the next paint
procurement. The bidding often is for large quantities and it may not be feasible for a recycled paint
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manufacturer to supply enough but getting the requests for proposals will give them "the option. The
government will contract with the bidder with the lowest price that is reasonably able to provide the
requested product.
*
One important factor in getting a recycled paint product listed by the FSS is shelf life. The government
needs to have products that have at least a two-year shelf life. The Major Paints Cycle II paint has been
guaranteed by the company to have a three-year shelf -life or they will take it back. If a company can
not guarantee a two-year shelf-life, they can agree to accept it back.
Another procurement approach is also available to government purchasers. They can buy their supplies
directly and locally by buying off a schedule. In this case, the NSN numbers are not used. A schedule
is a contract that the government has arranged with certain suppliers to provide a specified type of product
at an agreed-upon price. GSA puts out a listing of contractors that have products that meet certain
specifications and have negotiated a price for the government. The manufacturer needs to submit certain
forms and certifications and agree to give their best price to the government purchasers. Then the
manufacturer can market to the purchasing people and they can buy it from the manufacturer directly. This
avoids the need to get materials shipped into the warehouse. It may be more suitable for recycled paint
than the FSS system because it is often the chosen route for smaller purchases.
For purchases under $5,000, the agencies can buy in any way they wish. This again requires marketing
to the purchasing people.
Market Demand Within Government Agencies
Whichever way is used, marketing is required to create the demand. The military bases with engineering
and construction battalions are prime targets for marketing efforts because they are responsible for building
maintenance and construction on the base. Also bases with young troops or where the housing turns over
quickly require frequent repainting. These painting projects do not require paint that will withstand 10
years of exposure; they need to be painted every year or two because of the wear and tear from people
and equipment moving in and out and damaging or marking the walls.
It is important to consider, however, that FSS does not have a captive selling market. FSS operates as
a semi-independent business, i.e., it is responsible for generating its own source of income for personnel
and operating expenses. Other Federal agencies are not required to use FSS as their source of supply,
Consequently, FSS cannot commit Federal dollars to contract for items that other agencies won't buy.
This means that getting into the FSS supply system is not the end; recycled paint needs to be marketed
to the purchasers and users.
To date, only one paint manufacturer, Major Paint Company in California, has had its recycled paint tested
and listed. The paint did not meet the color and percent solids requirements of the existing standard for
virgin paint but, on a pilot test basis, the paint was assigned an NSN number and is available in a limited
area. It can now be ordered in California, Nevada, Utah, Washington, Oregon, and Idaho through the FSS.
Procurement Preferences and Specifications
Many people have thought that providing a government "preference" for recycled paint would be helpful.
The GSAJiowever, has argued that this is not the best approach. Creating and implementing preference
systems for recycled products is very time-consuming and cumbersome. The primary difficulty is being
able to verify that a product is, in fact, made from recycled materials because it is not readily observable.
At this point in time, recycled paint can be offered at prices that are lower than prices for virgin paint,
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Recommendations to Help Promote Use of Recycled Paint
In general, one step towards increasing the use of recycled paint would be the development of standards.
The Federal government is required to use non-government standards if they are available for the purpose.
For common painting tasks that would lend themselves to the use of recycled paint, a recycled paint
standard could be developed. It would have to be developed with input from manufacturers to ensure that
their output would conform to the specifications. The American Society for Testing Materials (ASTM)
is one group that develops specifications and could assist in this process. Once developed, the standards
could be reviewed by the American National Standards Institute (ANSI). The ANSI serves to review
standards to ensure that they can be met by enough manufacturers to provide competition. If so, they will
certify the standard as a national standard. In addition, it would be smart to start to develop local markets
within the government units that also pay for the disposal of HHW. Since they will benefit from diverting
paint from the waste stream, they may be willing to provide uses for the paint
We, at the WWC, have asked for a listing of the types of uses for paint used by the Department of
Defense. From this, we will be seeking to develop some demonstration projects using recycled paint.
Recycled paint demonstrations have been done in California and need to be expanded elsewhere. After
the demonstration projects, we need publicity. This can come through the governments publications,
Marketips. through professional journals, through the electronic system, Multi-Use File For Interagency
News (MUFFIN) and through the general press and publications.
I
• which is already a good incentive. In addition, many parts of the government are trying to find recycled
products to use wherever possible, so the preference may not be necessary at all.
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Options for Disposal of Latex Paint Wastes Collected at HHW Collections
Philip Farina, Environmental Purification Industries
The management of household hazardous waste is becoming more
and more sophisticated as various counties begin to hold special
waste drop off days or develop permanent hazardous waste drop off
sites. The popularity of special waste drop off days is also
growing with the public who have been searching for what to do
with these household hazardous wastes. As this market grows, the
waste stream managers are pushed even harder to find new
technologies for recycling or reuse of the materials collected or
to find safer and more efficient methods of disposal.
One stream which seems.to be growing in volume throughout
the county is unused household latex paint kept in thousand of
garages and basements. This material comes in various forms,
from unused virgin paint to "cottage cheese" material - the
result of freezing and.thawing of formulated paints. The scope
of the problem continues to grow as more and more home owners
look for environmentally safe methods of disposing of their paint
waste.
In a recent survey of 15 counties on the East Coast who have
set up permanent waste collection sites, it was determined that
paint waste was the largest single stream collected at most of
the sites. This is good since it shows the public's concern for
the environment, but what are the options available to the waste
stream managers for reuse, recycle or disposal of such collected
volumes?
The first option readily available is the reuse of the paint
as paint for low income housing, public service buildings (as
primer) or just giving the material away to be used as a primer
or other low tolerance use.
This can be effective for some quantity of directly reusable
material but more often as not the collected material cannot be
directly reused as it may be contaminated or has otherwise de-
emulsified and is thus unusable.
One disposal option for such unusable material has been to
landfill. This must be considered as a least desirable option as
the waste was originally collected to keep it out of the landfill
in the first place 1 This is however, the lowest cost option for
the disposal of both can and contents, but should again be
considered as less than desirable.
Another frequently used option is "Fuel Blending". In fuel
blending we use the energy derived from the paint material as a
fuel for a cement kiln which is used to manufacture Portland
cement. This is a good use for the material since it does derive
some benefit from the waste, however there-are some limitations
involved in fuel blending.
The most important limitation for fuel blending material is
that the raw waste must possess a minimum of 5,000 BTU/lb. before
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it can be blended into fuel. In most cases this can be met with
high solvent borne paints but is not seen with latex paints which
use water instead of solvent as a carrier. In most states, we
are seeing a dramatic shift toward water born paints, so the fuel
blend option may be limited in the future.
Another.common option - but a very expensive one - is
incineration. Here the material is simply thermally destroyed
with the resulting ash going into a hazardous waste landfill.
The cost for such service may exceed $8.00/gallon but for many
counties this has been the only option.
A new technology - PYROLYSIS - has been developed to handle
low BTU value latex paint waste, which takes paint sludge and
related materials and processes them into a non-hazardous inert
filler material which is then recycled.
This proven technology was developed by Haden Environmental
Corporation and is known as the Haden DryPure Process. The first
plant is operated by Environmental Purification Industries and is
located in Toledo, Ohio. How does this technology work?
The EPI DryPure schematic (see figure 1) slows the process
flow of material from a sludge into the dry powder - EPI-
PURE.Material is received at the facility in drums, roll off
boxes, vac truck or tank trucks. The material must be debris
free as debris cannot be processed by the system. The material
is tested at the facility and is off-loaded directly into the
receiving hoppers (1). The material is pumped via V-Ram (for
solids) or diaphragm (for liquids) into the dryer (2).
The thermal fluid dryer consists of two hollow, auger like
screw conveyors that run horizontally and slowly convey the
sludge from one end of the dryer to the other in a continuous
process. (3) The screw conveyors, which contain an oil heated
to 550°F, come into contact with the paint sludge in what can be
described as a "frying reaction". As the sludge passes through
the dryer and is heated, water vapor and other volatile liquids,
such as volatile organic compounds (VOC's) that are contained in
the paint sludge are driven off as the paint sludge is cured (4).
These gasses are collected in a vapor dome and are transferred'
into a waste heat boiler. These materials are destroyed in the
boiler which is fueled by natural gas and is heated to over
1600°F (5). The heat generated from burning the VOC's is also
recycled by routing it to an air to oil heat exchanger (6), where
the heated oil is then pumped into the holoflite screws of the
dryer, making for an efficient closed loop system.
The solids material from the dryer is conveyed to a
vibrating screen, (7) which separates the larger particles to be
re-routed back into the dryer for further processing (8). The
fully cured material - which has the consistency of find sand -
is collected in forty cubic foot bags for shipment to an end
user.
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The resultant material - EPI-PURE™ is then sampled and
subjected to a series of tests to verify that the material is
fully cured. Uncured powder is reprocessed through the dryer
ensuring all material recycled is both fully cured and safe.
The final cured material is an inert, non-hazardous, light
weight material that is currently being used as a filler
replacement for roof mastic and cement block markets. The
material is also being tested for use in brick as a replacement
for other filler materials.
This method of recycling paint waste does indeed end the
paint waste liability cycle by creating a new reusable product
from a waste stream.
In an environmentally conscious society we can offer a paint
waste recycling program which is both environmentally sound and
economically efficient.
EPIDRYPURE SCHEMATIC
["5""] All vapors are combusted at 1600° F
'—' in Boiler for 2 ,.
second dwell lime.
Vapors from drying sludge
are vented to Boiler.
rr-i 600°F oil drculating
through auger flights and
dryer jacket cures sludge
into dry powder.
SLUDGE TRANSFER
t
OIL
V-rom solids pump
transfers sludge into dryer.
rnuTiwr.l—I
CIRCULATING
PUMP
rr~l Air to oil heo! exchanger uses heat
'—' generated by boiler lo heal oil fed
lo dryer flights and jacket.
Cured powder is
screened into 1500
Ib. bulk bags.
~j~~| Sludge is unloaded
into hoppers.
Conveyor recycles any
oveisiie or anew
back lo dryer.
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INMETCO's Nickel-Cadmium Recycling System
John A. Patterson
Marketing and Sales Representitive
INMETCO
P.O. Box 720
245 Portersville Road
Ellwood City, PA 16117
INMETCO is the leading recycler of metal waste in North America. In 1992, approximately
57,500 tons of nickel, chromium and iron bearing wastes, including approximately 1,350 tons of
nickel-cadmium and nickel-iron batteries.
INMETCO recycles all types of nickel cadmium batteries, including large industrial cells and AAA,
AA, C and D cells. Landfill liability is eliminated, and valuable, non-renewable resources are
preserved.
INMETCO is a TSD (EPA I.D. Number PAD-087561015) secondary metals reclamation facility
which actively reclaims nickel, chromium and iron from hazardous and non hazardous wastes. As
part of our technology, the process uses the only smelting furnace in North America dedicated to
the recovery of nickel, chrome and iron, while producing a stainless steel remelt alloy used by
virtually all of the U.S. Specialty Steel manufacturers plus customers in Canada, Europe and
Japan.
INMETCO is a wholly owned subsidiary of Inco Ltd., one of the world's largest nickel
companies. The Ellwood City, Pennsylvania facility operates a RCRA Part-B permitted hazardous
waste storage facility. INMETCO received its Part-B Hazardous Waste Storage Permit
#PADQ87561015 from the Pennsylvania Department of Environmental Resources on November 6,
1992.
Being a true reclaimer and recycler who has been in operation since 1978, we meet all state and
federal requirements for insurance, while providing an environmentally sound approach to the
processing and reclaiming of valuable metals.
The process lends itself to the recovery of nickel, chrome and iron from a variety of waste types
and forms, such as solutions, solids or dusts. With the present process we have the ability to use
other materials, such as spent carbon and carbon bricks, magnesium swarf, metallic grindings,
chrome-magnesium refractories, and spent nickel-cadmium and nickel-iron batteries to name a few.
RECYCLING METAL BEARING WASTES
THROUGH PYROMETALLURGICAL TECHNOLOGY
R. H. Hanewald , M. E. Schweers, J. C. Onuska
INMETCO
245 Portersville Road
Ellwood City, PA 16117
ABSTRACT
The pyrometallurgical process is a solution to the problem of recycling nickel, chromium
bearing refractories from.the glass manufacturing industry. This process eliminates the need for
stabilization and land disposal by reclaiming these metals for further use. In this paper, the steps
of the pyrometallurgical process (1) feed preparation,
(2) reduction and (3) smelting and casting are examined in detail. The recovery of the metal and
non-metal components of the wastes is explained.
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INTRODUCTION
The pyrometallurgical process upon which this-paper focuses was developed by INCO in
its research facilities in the mid-1970's. This process, after pilot testing, led to the building of a
facility in Ellwood City, Pennsylvania, which began commercially reclaiming stainless steel waste
known as flue dust, mill scale and swarf beginning in 1978.
Since 1978, the process1 waste feed specifications broadened to accept other waste streams
such as nickel and chromium containing plating cakes, and nickel and chromium containing plating
solutions. In 1991, approximately 50,000 metric tons of waste, including approximately 234
metric tons of chromium-bearing refractory brick were recycled resulting in the production of over
21,000 metric tons of metal.
PYRQMETALLURGICAL PROCESS OVERVIEW
The pyrometallurgical process consists of three basic steps: 1) feed preparation, blending
and pelletizing; 2) reduction; and 3) smelting and casting. (See Figure 1)
FIGURE 1: STEPS IN THE PYROMETALLURGICAL PROCESS
Operation , Equipment Used
1. Feed Preparation
2. Reduction
3. Smelting
4. Casting
Pelletizing Disc
Rotary Hearth Furnace
Electric Arc Furnace
Pig Caster
The equipment used is relatively well known in the primary metal producing industry. The
feed preparation equipment is specifically suited to the feed material from die specialty steel
industry, utilizing a rod mill for mill scale and a table feeder and rotary breaker for the swarf. For
blending, mass flow bins with electronic speed controls are employed to move the finely prepared
material, via a screw feeder, to the covered conveyor and into screw conveyors. The screw
conveyor discharge is .carried by conveyor to a 4.3 m diameter pelletizing disc where water is
added and the pellets formed (approximately 1.2 cm in diameter). The first reduction step is
carried out in a 16.7 m diameter Rotary Hearth Furnace. Smelting and final reduction is
accomplished in a 6.3 MVA, 6.4 m diameter Submerged Arc Electric Furnace. Casting is
performed by pouring the hot metal from a 12 metric ton ladle into a twin strand pig caster. Pig
weight is about 14 kg.
The first step in the process involves receiving the various wastes and pretreating them,
where necessary, to insure a uniform size material. These pretreated wastes are stored in separate
silos from which they are fed at a carefully controlled rate. The wastes are blended with coke or
coal and water in a screw conveyor. The mixture proceeds to a disc pelletizer which produces
green waste pellets strong enough to resist disintegration in the subsequent thermal operations.
Since the pellets are not going to be tumbled in the reduction process, the strength requirement is
minimal.
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The second major step in the process is the partial reduction of the metal oxides in a Rotary
Hearth Furnace. In this furnace, some of the carbon in the pellets react with oxygen in the waste to
produce reduced metal. A portion of the Zinc, Lead and Halogens contained in the flue dust are
exhausted into the off-gas treatment system. Hot, metallic, sintered pellets are transferred in sealed
containers to the Electric Arc Smelting Furnace where the third major operation is performed. In
this stage, the pellet is melted and chromium oxides are reduced by the residual carbon in the pellet.
Lime, silica, alumina and magnesia separate to form a liquid slag which assists in cleansing the
metal bath. Metal and slag are tapped periodically from the furnace. The metal is cast from a
refractory lined ladle into pigs which are sold to the steel mills. The slag is treated in a special area
in order to obtain a sized material that can be used locally as fill or ballast. The process water is
treated and yields a filter cake that is recycled in a separate processing plant to recover the Zinc
values.
Currently, one plant using the pyrometallurgical process is capable of treating 50,000
metric tons of raw material per year. At this feed rate, the plant can produce 21,000 metric tons of
pig metal with a composition similar to that shown in Table 1.
TABLE 1: TYPICAL METAL ANALYSIS
Ni - 8.5 Co - 0.42
Cr - 14.1 S - 0.27
Fe - 69.5 C - 3.7
Mn - 1.6 Si - 0.1
Mo - 0.99 N P - 0.05
Cu - 0.76
PLATING & SURFACE FINISHING INDUSTRY WASTE PROCESSING
The pyrometallurgical process has been modified to recover metals from plating and surface
finishing wastes such as nickel and chromium containing solutions and nickel and chromium
containing filter cakes. Table 2 and Table 3 list the typical values for nickel, chromium, iron, pH,
copper and phosphorus for liquids that may be recycled via the pyrometallurgical process. Table 4
lists typical composition of nickel and chromium containing cakes that may be recycled
pyrometallurgically.
TABLE 2: CHEMICAL ANALYSIS OF CHROMIC ACID
Client
Mill# jjH
1 1.00
2 1.00
3 1.00
Fe
(ppm)
4870
8760
14000
Ni
(ppml
215
64
32
Cr
fppm)
98400
161000
132600
Cu
(ppm)
162
224
1210
Co
(EEin)
65
12
5
P
(ppnQ
50
14
16
TABLE 3: CHEMICAL ANALYSIS OF NICKEL SOLUTIONS
Client
Mill# EH
1 1.20
2 13.22
3 1.38
Fe
fppm)
3160
9
65
Ni
(ppm)
33000
23200
57600
Cr
(ppml
63
32
131
: Cu
(ppm)
17
4
' 174
Co
(ppm)
19
460
33
P
(ppm)
6
40
53
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TABLE 4: CHEMICAL ANALYSIS OF CHROMIUM AND NICKEL CONTAINING CAKES
%Mo %Pb %Zn %Cu %MgQ %Ni %Co
Client
MU1# %Cd
1
2
3
0.03
0.07
0.07
dent
Mill# %Fe
1
2
3
20.04
34.59
34.08
0.12
0.22
0.35
4.22
11.28
8.42
0.04
0.1
0.19
0.02
0.16
0.5
0.16
1.04
0.92
24.61
0.8
13.04
0.11
0.33
0.44
%Cr %Mn %CaO %SiQ2
1.6
0.96
3.37
0.50
7.12
2.02
%P
0.026
0.023
0.036
2.29
4.66
3.74
%A12Q3
0.5
0.21
0.68
0.08
0.16
0.37
Lol
63.3
56.8
0.2
In order to guarantee the quality of the product known as stainless steel temelt alloy "pigs",
the concentration of elements such as phosphorus and copper in the wastes must be relatively low.
Nickel and chromium containing liquids such as waste nickel stripper solutions, waste
chromic acids and rinse waters are used to produce pellets from dry, metal bearing waste. These
liquids are pumped at a controlled rate to the pelletizing disk. (The deck of the disk is made of
corrosion resistant 316 stainless steel.) Here they agglomerate or pelletize dry, metal bearing waste
forming "green pellets". The green pellets are approximately 1 cm in diameter. They are
transferred by conveyor to the Rotary Hearth Furnace. Wet filter cakes bypass the pelletizing disc.
In order to feed filter cakes, a 3.3 m table feeder is used to feed several 8.5 m long and .62 m in
diameter ribbon flight screw conveyors that mix carbon fines and filter cake prior to delivery to the
Rotary Hearth Furnace.
In the Rotary Hearth Furnace, the carbon that has been added to the waste reacts with the
nickel and iron hydroxides for purposes of reduction prior to transfer to the Electric Arc Furnace.
The basic reaction is shown in Figure 2.
FIGURE 2: SIMPLIFIED REDUCTION REACTION
Ni + Fe
Note that about half the lead and zinc will fume off along with a portion of the halogens which are
captured by a wet scrubber and removed in a waste water treatment plant.
In the Electric Submerged Arc Smelting Furnace, the waste materials are smelted to extract
nickel, chromium and iron. Because it requires higher processing temperatures, chromium oxide
is not reduced in the Rotary Hearth Furnace. However, this is easily accomplished in the Electric
Furnace where the metal temperatures reach 1600° C. At this temperature, a slag bath and a
nickeVchromium/iron bath are formed. As was explained earlier, metal and slag are tapped
periodically from the furnace. Molten metal is cast into pigs weighing approximately 14 kg using a
twin strand pig caster. The non-hazardous slag is poured into thin sheets, cooled, sized by
crushing and screening, and then sold as fill and construction aggregate.
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RECOVERIES
Through the reduction and reclaiming steps, the pyrometallurgical process is highly
efficient in the recovery of metallics. Some actual recovery values are indicated in Table 5.
TABLES: TYPICAL METAL RECOVERIES
Hi Mo Co £r. F£ Mn
98% 92% 97% 86% 96% 60%
While achieving the above metal recoveries, also removed are Zn, Pb and most of the Sulfur.
COMPOSITIONAL CONTROL
The customers, the specialty steel producers that provide the larger percentage of the raw
material used at the plant, desire a quality remelt alloy that can be used to produce material similar
to type 304 stainless steel (18% Cr - 8% Ni - balance Fe). When Molybdenum is present, the pig
could be used for the manufacture of the higher valued type 316 stainless.
A quality control group has developed the necessary procedures to sample the various
nickel-containing waste liquids and solids that are processed here. This insures complete and
accurate chemistry control. This group specifies what material can be used in our process, as well
as the processing circuit to be employed and the consumption rate.
The procedure is to analyze each lot or truckload as it arrives at the plant. The material is
then assigned to a particular storage bunkered area based on its Nickel and Chromium content.
The contents of the various bunkers are carefully blended to produce a mix with satisfactory
processing characteristics and uniform alloy content. Any shortfall in Nickel content from the
target level is made up by adding nickel alloy wastes. The Electric Arc Furnace contains a heel of
about 120 metric tons of hot metal which helps smooth out product compositional fluctuations.
RESOURCE RECOVERY PLANT WASTES
A resource recovery plant is, of course, subject to the same environmental concerns as the
industry it serves. The plant does not landfill any residues from its process. The non-hazardous
slag co-product passes the EPA TCLP test, does not leach, and is sold the same as other slags have
been since the turn of the century.
The gaseous effluent from the Rotary Hearth Furnace contains significant quantities of
Zinc, Lead and Halogens. A wet gas scrubbing system was specified to treat this effluent. The
scrubber water is treated to meet all the applicable quality standards. After treatment, it is
discharged to the municipal sewage treatment system. The treatment system produces about 2,000
metric tons per year of an alkaline filter cake containing significant quantities of Zinc and Lead.
The plant recycles this cake through a secondary zinc producer. The Electric Furnace is attached to
a standard baghouse for collecting the remainder of the zinc and lead. (See Table 6 for
compositional information.)
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TABLE 6: BY-PRODUCT COMPOSITION
Constituent Composition Weight %
SiO2 + Al2 03
CaO -i- MgO
F
a
Pb
Zn
Fe
Cr
Scrubber
Filter Cake
7%
13%
3%
0.5%
6%
22%
9%
3%
EF Baghouse
Dust
3%
5%
1%
9%
4%
28%
2%
0.5%
The slag that is generated is poured from the ladle, while still molten, down a ramp into a
thin layer. This is cooled and broken up with a front end loader. The broken slag is screened and
sized. This sized material is chemically inert and is sold for roadway beds and construction
material. Table 7 gives the analysis of this slag.
TABLE 7: 1990 CHEMICAL ANALYSIS OF SLAG CO-PRODUCT
SiO2
MgO
Cr203
25%
18%
5%
CaO
AI2O3
31%
10%
3%
FINAL COMMENTS ON THE PYROMETALLURGICAL PROCESS
This paper is presented to demonstrate how the process works with plating as well as other
metal bearing materials. Over 1800 tons of nickel, 3000 tons of chromium and 16,000 tons of iron
are annually recovered and recycled. These non-renewable resources are kept from landfills. The
environment is improved by processing hazardous wastes into non-hazardous valuable, recyclable
remelt alloy.
RECYCLING PROGRAMS FOR MANUFACTURERS, DISTRIBUTORS & USERS OF
NICKEL-CADMIUM BATTERIES
ESfMETCO has developed several types of nickel-cadmium (Ni-Od) battery recycling programs to
serve the needs of manufacturers, distributors and users of Ni-Cd battery products. Examples of
three such programs are listed below.
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Mail Back Program
Ni-Cd batteries and battery packs are delivered to INMETCO directly from the Ni-Cd user via
U.S. Postal Service, 4th class mail or UPS. The mailers are provided by the
manufacturer/distributor of the Ni-Cd battery power product. It is our understanding that under the
United States law, only conditionally exempt small quantity generators "CESQG's" (facilities
generating less than 220 Ibs. per month of hazardous waste) or households may ship used Ni-Cd's
in this manner.
The manufacturer/distributor of Ni-Cd battery powered products is responsible for the cost of
shipping.
A sample mailer is available upon request to the Sales/Marketing Department.
Reverse Distribution Program
In this program, the service centers of the Ni-Cd battery powered product manufacturer/distributor
serve as the collection sites for used Ni-Cd's. It is our understanding that if the service centers
qualify as CESQG's, they may ship these used batteries to INMETCO via 4th class mail or UPS,
under U.S. law.
The Ni-Cd batteries are to be shipped in packages weighing approximately 20 to 70 Ibs., meeting
the specifications of the shipper. The manufacturer/distributor is responsible for the cost of the
shipping.
Large Quanity Generator Program
This program id for manufacturer/distributors of Ni-Cd battery products that collect large quantities
of Ni-Cd's at one central facility. The Ni-Cd batteries are packaged and transported according to
INMETCO's "Nickel-Cadmium Battery Processing Conditions", available upon request. The
manufacturer/distributor is responsible for freight to INMETCO's facilities.
The cost to recycle Ni-Cd batteries under this program is on a graduated scale.
For assistance with your Nickel-Cadmium battery disposal needs please contact our
Sales/Marketing Staff, 412-758-5515.
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.U.S. HOUSEHOLD BATTERY RECYCLING: MERCURY REFINING
ALAN WILDS
Vice President Marketing and Sales
Mercury Refining Company, Inc., Latham, New York 12110
Is it too early to think in terms of a success story? In 1984
the amount of mercury being sold domestically as a component
in batteries for all markets was more than 2 million pounds
[1]. By 1991 this is reported to have been reduced to 156
thousand pounds. The consumer market represents about half
these numbers; one million and 80 thousand pounds,
respectively.
The reduction continues. All the major US manufacturers state
that their batteries (both alkaline and zinc/carbon) either
already do not or will not contain any added mercury by 1993.
The same is true of the manufacturers in Europe and Japan.
The only possible remaining sources of mercury into the
domestic battery market may be from the so called cheap
battery manufacturers (Singapore and Hong Kong, for example;
and this may not be a fact) and the mercury button hearing
aid batteries.
Thus a very small percentage of household batteries now
contain added mercury of any concentration and the trend
continues downwards.
In 1992, Dayid Kurd [2] estimated the domestic market for Dry
Cell Batteries to be:
zinc/carbon
zinc/alkaline
zinc/air
nickel/cadmium
silver cells
lithium batteries
zinc/mercury
TOTAL
19.7%
63.5%
3.4%
9.4%
2.6%
0.2%
1.2%
100.0%
Several others have reported on the battery market breakdown
and the -mix does not substantially change (certainly Mercury
Refining Company [MERECO] internal information supports these
data).
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The single domestic consumer market for mercury batteries is
the hearing aid battery. This is a very tiny battery and is
being replaced by the zinc/air cell. Several States have
programs in place which will affect the availability of
mercury in the remaining market, for example:
CA [3] is suggesting a prohibition effective in 1996.
NJ [4] has an exemption for hearing aid batteries until 1996.
VT is already requiring the recycling of batteries.
MN has already established a program to collect consumer
batteries.
NY [5] will publish the results of the Battery Task Force at
the beginning of 1993.
Many of the other States either already have regulations in
place, are enacting the necessary legislation or are watching
the existing State programs, with a view to introducing their
own.
Based upon these facts, it may not be unreasonable to assume
that mercury from the consumer battery market will be
virtually eliminated ..as a source entering the market during
1996. It will therefore decrease in the waste stream shortly
thereafter with the potential to effectively become zero.
MERECO has the capability to reclaim and refine mercury from
the consumer batteries and other mercury bearing waste
streams. The company was established in 1955 to do just
that. At the time, the market for mercury was supported by
the US Government. The price was high enough to enable the
waste mercury batteries to be purchased, packaged, shipped
and the mercury reclaimed without cost to the generator. The
declining value of mercury coupled with the increasing costs
of regulation has meant that customers now have to pay for
the recycling service.
The method employed is retorting. This process has been known
for a long time and is essentially a distillation process.
The mercury batteries are loaded into a chamber, heated and
the mercury vaporized. The vapors are collected and
condensed.
Mercury batteries are received into the facility, usually in
drums or fiber boxes. Since these batteries are from the
domestic waste stream (and predominantly from New York
State), they are not now hazardous waste, in New York State.
Consequently, they are not accompanied by a manifest.
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The batteries are sorted, manually, by type. When about 1,000
pounds have been accumulated, the mercury batteries are
prepared for retorting by placing them into retort pans. Each
pan holds about 14 gallons or 250 pounds of mercury button
cells. Four pans are loaded into the retort, the door closed
and sealed (it is important that the door be effectively
sealed to eliminate the possibility of mercury vapor entering
the environment).
The re-circulating cooling fluid in the condenser is checked
to ensure that the vapors produced in the process will be
cooled. The retort chamber can now be heated.
Indirect heat, in this case by natural gas, is applied to
heat tiles below the retort chamber. Heat is transferred to
the chamber and the batteries are forced to open. The
expansion due to heat actually causes them to explode.
Volatile materials are driven off in the heating process (for
example water from the electrolyte and mercury). As the
temperature inside the retort approaches the boiling point of
mercury metal (356 deg C or 673 deg F) the mercury evaporates
and is driven from the retort. It is collected by the
condenser and returned to the liquid state. The mercury is
collected at the outlet from the condenser.
The chamber continues to be heated towards its maximum of 750
deg C (1400 deg F), in order to continue the process of
reclaiming all the mercury contained within a battery. For
example, mercuric oxide (the major component of a mercury
battery) decomposes at 500 deg C (932 deg F).
Once all the mercury has been expelled from the material, the
heat is shut off and the chamber with its contents is flushed
with cold air or nitrogen. This assures that any resident
mercury vapor in the retort passes through the condenser. It
also increases the rate of cooling. Once the retort has
cooled it is opened and the pans removed.
The residual material, typically metal cases, glass seals and
salts, is sampled and drummed. Samples are analyzed on a
statistical basis to prove the complete removal of mercury.
The drummed waste is sent to a secure land-fill for disposal.
The collected mercury metal is further treated prior to sale.
The treatment consists of distillation and various chemical
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washes, with and without agitation, to remove all
contaminating species.
Mercury is sold as two grades: prime virgin quality and
triple distilled. The prime virgin grade is at least 99.9%
pure, and is the purity obtained directly from the retorting
of cinnabar (an ore which is.mainly mercury sulfide). MERECO
warrants its mercury as being at least as pure as prime
virgin.
Triple distilled mercury is a higher grade of mercury
achieved through multiple distillation steps and chemical
washing of the refined mercury from the retorting process.
Its purity is at least 99.99% and may exceed 99.9999%.
The lower purity mercury has applications in the manufacture
of mercury compounds and in the chlor/alkali process. The
higher grade mercury is used in mercury vapor lamps, dental
amalgams, mercury in glass devices and fluorescent tubes.
Thus, mercury has been used in batteries for many years. As a
result of environmental contamination (and in some instances
human health effects), there has been a major drive to
eliminate mercury from the domestic (and world-wide) market.
Since 1984, there has been a steady but dramatic decline in
the quantity of mercury being used in domestic batteries.
States are passing legislation banning mercury from the
domestic market during 1996. The battery manufacturers have
been cooperating with the effort to reduce the mercury
content of their products while minimizing any impact on
performance. Mercury Refining is working to reclaim as much
mercury from the domestic consumer battery market to further
lessen the impact of mercury in the environment.
Is it too early to claim a success for the control of mercury
entering the environment from the domestic consumer battery?
The end certainly seems to be in sight.
REFERENCES
[1] Barnett, B. M. (1992) Battery Waste Management
Perspectives. Presented at the 4th International Seminar
on Battery Waste Management, Deerfield Beach, FL
[2] Kurd, D. (1992) Feasibility Study for Implementation of
Consumer Dry Cell Battery Recycling as an Alternative to
Disposal. R2B2, NY
[3] Ernst & Young (1992) Household Battery Waste Management
Study. Report, California Environmental Protection Agency
[4] Winka, M. (1992) Dry Cell Battery Management Act (S-3157)
State of New Jersey Department of Environmental
Protection and Energy
[5] Nosenchuck, N. H. (1992) Waste Battery Management in New
York. Presented at the 4th International Seminar on
Battery Waste Management, Deerfield Beach, FL
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A New U.S. Battery Recycling Facility
W.R. Meador, Recovery and Reclamation, Inc.
Recovery and Reel amat-ion, Inc. (RRI) -is primarily involved in the
collection and distribution of recycled materials from the recycling of
industrial and household batteries. Since 1990 RRI has received new,
used and obsolete batteries containing hazardous and non-hazardous
material and processed them through the facility, recycling all and/or
portions of the batteries and reselling these materials to.third party
dealers who use the recycled materials as Feed-Stock to produce
commercial products.
RRI manages the battery recycling facility in a manner in which no
product or material becomes a waste and thereby needing off-site
disposal. All by-products are sold as recycled material to commercial
end-users as Feed-Stock material or is used within the facility as
complimentary products, for processing batteries and/or their subsequent
by-products. Again, there is no off-site disposal of any waste
material .
RRI has made application to the Texas Water Commission {TWO, the
lead agency for the Environmental Protection Agency (EPA), for a Part
"B" Storage Facility Permit, which is very near completion. The EPA
has assigned the facility permit number to RRI's facility and TWC
representatives assure RRI that the permit will be completed and in our
possession by the first of February, 1993. The Permit Application
covers the existing facility and the planned storage and containment
facility. The facility units at RRI are:
1.) Zinc-Carbon - Industrial wet electrolyte type storage batteries
2.) Alkaline - 1 for Known Levels of Mercury being "0" (Household)
3.) Alkaline - 2 for Unknown Levels of Mercury (Household)
3.) Lithium - Household / commercial / military types
4.) Ni-Cad / Ni-Fe - Industrial ,
5.) Storage Warehouse (Part "B" Building).
The EPA does not presently regulate the actual process of
"Recycling" (with the exception of certain uses constituting disposal),
only the Storage, Transportation, and Generation that proceeds it. RRI
was not forced or even asked to acquire a Part "B" permit, but applied
voluntarily in order to meet possible future regulations and to satisfy
current and potential client concerns.
•LAND USE AT AND NEAR FACILITY:
The RRI facility is located in a light industrial area near Pecos,
Texas. Environmental due diligence has shown that the potential for
environmental risk is low due to any contamination from past uses and
low potential due to present uses based on current practices and
evaluations of operations at the facility. Surrounding land uses are
excellent for the operations as all surrounding industrial lands are
abandoned or undeveloped. Soil types, depth to potable, water and lack
of sensitive receptors in the area tend to limit the potential for
environmental risk.
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g . Additionally, the facility has in place processes and.are
addressing additional systems due to the application for the Part "B"
• permit that should limit any other potential environmental risks.
• These systems include the "SPCC" plan and "Pollution Prevention Plan"
™ for the NPDES permit.
• The facility is, fenced on all sides by a six (61) tall security
fence with two (2) strands of barbed wire. Access to the facility is
• controlled by gates that are locked when the facility is closed and
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monitored when open.
There are no storm or process sewers located in the RRI facility,
and there is no waste water generated or discharged in the facility
operations.
I In the vicinity of the RRI facility, the topography is flat to
gentle sloping to the south and west. The facility is not-located in
the 100 year floodplain. Also, from se i smi c - studi es , the closest- fault
M is over eight (8) miles to the East of the facility.
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In addition to introductory training, operators receive on the job
•refresher training that includes a review of the introductory material,
instruction in changes in operational procedures, the use, repair, and
inspection of new facility equipment, and additions to or changes in
(m environmental regulations.
EMPLOYEE TRAINING AND SUPERVISION:
Supervision of employees within the various plants located within
the facility is handled primarily by individual plant foremen. The
plant foremen train the employees in the various tasks necessary to
operate the individual plant equipment and process the particular
batteries for each individual plant. Safety and environmental concerns
are addressed on a regular basis by specially trained environmental
supervisors and outside consultants. Regular safety meetings are held
on site for all employees as well as OSHA CFR 1910.120 Haz-Mat training
is conducted for all employees, these being 24 Hr. ,-cert i f i ed training
and B Hr. refresher course.
The RRI training program is designed to ensure . that personnel are
able to operate the plant safely and efficiently and to respond
effectively to emergencies. Employees are educated in the nature of
materials being handled, the regulatory requirements for normal
facility operations, and proper procedures to follow in emergency
situations. Personnel training provides instruction in- all elements of
preparedness and prevention, contingency plan and emergency procedures,
inspection requirements, and standard operation and emergency equipment
use.
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COLLECTION AND TRANSPORTATION:
Batteries that arrive at the RRI facility come to RRI from all
over the United States, Canada and Overseas at this time. The bulk of
these batteries arrive via trucks in either Totes, Gaylords or D.O.T.
approved 55 gal. drums containing the bat%teries. In the past, leased
trucks and drivers made the pick-up and delivery of batteries to the
RRI facility. However, RRI's own drivers and trucks make the rounds to
the various clients picking up batteries and delivering them to the
Pecos, Texas facility. RRI's trucking company is called Recovery &
Reclamation Trucking, Inc.(RRT). RRT has an EPA Haz-Waste
Transportation Permit and an ICC Contract Waste Carriers permit (excl.
Radioactive and Explosive). Batteries do still arrive at the facility
by other contract carriers for clients and their agents.
The schedule for the various pick-up points varies on an as needed
basis.
RECLAMATION PROCESS:
The majority of the processes used to reclaim the various battery
types that arrive at the RRI facility are proprietary. Batteries that
contain liquid electrolyte are drained and the electrolyte is used
within the facility for additional battery type processes or is
neut rali zed.
The various metals and plastic components are separated by —
mechanical or manual procedures. After separation, the components are •
recycled and/or used in preparation of different battery types or sold ™
to various metal and plastic scrap dealers.
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Each battery type that is handled in the facility is processed in
its own plant,, (ie. Lithium in the Lithium plant, Alkaline in the
Alkaline plant.) There is no cross processing of battery types or m
components. • I
INSPECTIONS:
RRI maintains an open door facility regarding inspections. In •
fact, it is a prerequisite that a representative for a new client visit
the facility prior to RRI's acceptance of that clients batteries. •
RRI's facility has been inspected by many Federal and State |
authorities as well as Environmental Firms across the U.S.. Many of the
major battery manufactures and their technical representatives have _
also been to Pecos, Texas to inspect our facility. You have an open •
invitation to visit anytime. , *
TYPES OF BATTERIES COLLECTED AND RECYCLED: •
Currently, RRI collects, reclaims, and recycles Alkaline, Lithium,
Nickel-Cadmium, Nickel-Iron, and Zinc-Carbon. RRI can transport and •
ship to third parties Lead-Acid, Mercuric Oxide and Silver Oxide ^
batteries. A Lead-Acid facility is in the planning stages and will be
constructed sometime in late 1993 or early 1994. —
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CONCERNING STATE AND FEDERAL 'PERMITS:
The current EPA 1.0. number (Part "B" Permit) for Recovery and
Reclamation, Inc. is TXD 988 077 640. The current State of Texas I.D.
Number Recovery & Reclamation, Inc.s, Solid Waste facility is # 52085.
Should you have any questions regarding Recovery and Reclamation, Inc.,
you can call the District office of the TWC in Odessa, Texas and speak
to an Inspector. Their office number is 915-362-6997. In addition, the
facility has received a EPA NPDES General Permit # TXROOB476.
The DOT and Hazardous Waste code numbers for batteries handled at
Recovery and Reclamation, Inc. facility include:
D-002, D-003, D-004, D-005, D-006, D-007, D-008, D009, D-010, D-011.
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"BATTERY-PAK SYSTEM":
Recently, Recovery and Reclamation, Inc. has started a new program
called the "BATTERY-PAK SYSTEM".. This is a program that is designed to
offer companies with large or small amounts of household batteries a
method of collection, storage, transportation and recycling through one
source.
The "heart" of the program is a color coded, 0.0.T. approved
container that simplifies the over all process of battery management.
By maintaining specific battery streams in specific colored shipping
containers, Recovery and Reclamation, Inc. is able to quickly process
the containers of batteries to the appropriate plant, in a safe and
permitted facility.
And you no longer have to store truck loads of batteries to gain
transportation cost savings. Because the storage container is the
shipping container as well. Additionally, you are provided with all
necessary labels, instructions and prepaid shipping container designed
for the individual battery type at your plant or facility. Also,
recycling costs are included the cost of each container sent,.
Once the container is filled, all that needs to be done by your staff',
is to call RRI and the container will be picked up by the shipper. Its
that simple.
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U.S. Fluorescent Light Recycling Activities
Dana Duxbury
Waste Watch Center
'During the past year there has been a great deal of activity
relating to fluorescent light recycling within the U.S.
Environmental Protection Agency (EPA), certain states,
manufacturers, and recyclers. Studies, passage of laws, proposed
position papers, building of new recycling facilities, and
proposed regulations all occurred.
National Level
At the national level, a variety of activities are under way at
EPA - they tested fluorescent lights according to the newer
Toxicity Characteristic Leaching Procedure ' (TCLP) and found that
over 50 percent of the bulbs tested as a hazardous waste.
Because of this, these bulbs would have to be managed as a
hazardous waste. In order to prevent the Agency's Green Lights
program {a .program designed to reduce our energy usage by
conserving energy .through converting to energy efficient
fluorescent lights) from .meeting resistance because of the cost
of .managing these bulbs as a hazardous waste and the regulatory
demands which would follow from this decision, EPA developed and
sent to the Office of Management and Budget (OMB) a Universal
Waste Rule which would allow fluorescent light bulbs to be
transported and managed as a recyclable waste not a hazardous
waste. At this time, this proposal is still in OMB. This
recommendation is a similar t'ype of scheme that has been
developed to encourage reclying of car batteries, another waste
which would test under TCLP as a hazardous waste.
The manufacturers trade association, the National Electrical
Manufacturers Association, developed a position paper which
advocated that these bulbs not be put into a solid waste
incinerator, but that EPA undertake studies to determine if they
can be put into a solid waste landfill.
State Level Activity
Minnesota has been most active in this issue producing a policy
statement that forbid fluorescent light bulbs from being put into
the solid waste steam stating that they could instead be stored,
managed as a hazardous waste or recycled. They just completed a
draft study .on fluorescent lights, will finalize the study and
possibly propose new legislation.
Two new recycling facilities opened during 1992 in Minnesota with
a third one about to open. In Allentown, Pennsylvania another new
recycling facility opened with at least four other new ones
proposed to open in 1993. These join the three already open in
California.
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Each of the states is requiring different permitting procedures
for these facilities. In Pennsylvania the state issued a
recycling permit, in California they have issued hazardous waste
R & D permits and in Minnesota there is no state permit
requirement only a license from the County.
Recvcler Survey
During the fall, the Waste Watch Center (WWC) developed a
questionnaire to identify how the existing -seven fluorescent
light recyclers differed or were similar. Attached to this speech
is a listing of the firms to whom the questionnaire was sent. Six
of the seven firms which received the questionnaire replied and
their answers will .be summarized below. They were Advanced
Environmental Recycling Corp (AERC), Lighting Resources (LC),
Mercury Technologies Corp. (MTC), MTC of Minnesota MTCMN),
Mercury Recovery Systems (MRS), and Recyclytes (R).
1} Briefly describe your company.
From 7,000 to 32,000 sq ft {AERC) were being utilized for the
recycling of the bulbs with from 3-15 employees.
2) When did you enter the business?
Two of the California companies ((MTC) and (MRS) began operations
in 1986 and the third California company (LR) opened in-1990.
All the others opened in 1992.
3) Are you an equipment manufacturer or both?
AERC, LR, MTC, and R identified themselves as both.
4) Briefly describe you recycling process.
AERC crushes the lamps, separates the glass.and metal, separates
the mercury from the phosphor powder and then recovers the
mercury through triple distillation.
LR sucks out the phosphor powders and the mercury before the
lamps are crushed.
MTC and MTCMN use a similar process as AERC and they both send
their mercury to AERC for triple distillation.
MRS uses a similar method as AERC and send their phosphor powders
for distillation.
R crushes the lamps first as do all but one of the firms above
and sends the mercury to a distiller.
5) What local, state and federal permits did your facility
require?
AERC was required to get a Pennsylvania recycling permit issued
under the authority of Title 25, Section 261.
LR, MTC and MRS all had to get a state of California R&D variance
for treatment. • .
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MTCMN and R were not required to get,a state permit but were
required to get a license from the county.
6) What wastes in what volume can you handle annually and if
currently in operation, how much are you processing?
AERC has 2 machines with'the capacity of processing 10-12,000
lamps per day.
LR can process several hundred thousand per month and when they
have their four facilities open they-project they will be able to
process 63 million per year.
MTC is permitted to process 5 million per year with 12-15,000 per
shift.
MTCMN has no permit limit, but must process them within 24 hours.
MRS can process 21,600,000 feet of lamps "annually '
R can process 1,000,000 lamps per month when they become .
operational at their full capacity and are processing 120,000
lamps per month now.
7) What are the products and by-products?
AERC stated they were recycling the endcaps (metal), glass triple
distilled mercury and the phosphor powder with plant scrap as a
by-product.
LR stated that they are recycling the glass, mercury, aluminum
tungsten and cardboard.
MTC stated the same as AERC plus cardboard.
MTCMN the same as above.
MRS stated that they are recycling glass, metal tips, cardboard
and mercury.
R stated it was recycling glass, metal, mercury and mercury free
powder.
8} Do you produce marketable recycled products from fluorescent
tubes, what are the value and end markets of the end products?
AERC stated that the powder has re-use applications.
LR stated that they are selling the glass for $45/ton, the
aluminum for $.26/lb and the cardboard for $35/ton.
MTC and MTCMN stated that they were both looking at what' to do
with the phosphor powders.
MRS stated the are getting $50/ton for glass, $35/ton for
cardboard and $.03/lb for mercury.
R stated that they are getting $.05-.10/lb for glass, $.10/lb for
metal and $2/lb for mercury.
9) Do any by-products require disposal and what are the costs and
requirements?
AERC stated that their plant scraps are incinerated at a
permitted facility.
LR stated that their phosphor powders are manifested and sent to
a Class 1 landfill at $100/drum because they contain cadmium.
MTC and MTCMN landfill plant scrap.
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R said that their is' a market for mercury and that the other
things can be landfilled.
10) Do you recover mercury? What percent? and how pure?
All of the plants said they recover mercury. They all stated
that over 99 per cent was recovered and that it was 98 percent or
higher in purity.
11) How much residual mercury remains in the glass? metal and
powder?
Answers ranged from non-detectable to £..2 mg/1 or £ 20 mg/kg in
the glass. In the metal and powder, LR stated that there were no
detectable levels, MTC MTCMN stated that the level was.^20 mg/kg,
R stated that there were 3.5 lb/640 Ib of powder (<1 per cent).
12) Are there residual levels in other mercury -bearing products
that you are recycling?
This question was not applicable since none of the firms are
recycling other mercury bearing products at this time.
13) Are there mercury bearing emissions from your process?
All of the companies stated that there are emissions but they are
"carbon filtered", below any regulated level of time weighted
averages taken every two hours", "negligible below OSHA REd 0.
05 mg", "less that 0.01 per cent from the near-by power plant,
and are at "non-detectable levels".
14) Are there other emissions?
All answered no.
15) How well proven is your recycling system?
AERC, MTC and MTCMN answered that their had been four years of
development work.
LR said their system was highly tested and MRS stated that they
are in their second year of testing.
16) What is the total cost of your system? .
None of the firms provided this information.
17) What storage procedures do you recommend?
All recommended packing them in the cardboard boxes that the new
ones come in.
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FLUORESCENT LIGHT RECYCLERS IN
OPERATION -1992-
Advanced Environmental Recycling Corp. Lighting Resources, Inc.
2591 Mitchell Avenue
Allentown, PA 18103
Robert M. Blanchfield
V.P. Corporate Development
800-554-2372 P
215-797-7696 F
386 S. Gordon Street
Pomona, CA 91766
John M.'Chilcott
President
800-572-9253 P
714-623-1338 F
Mercury Recovery Services
2021 S. Myrtle
Monrovia, CA 91016
Bob Roberts
President
813-303-2053
S18-358-2703
Mercury Technologies Corporation
30677 Huntwood Avenue
Hayward, CA 94544-7021
Paul Abernathy
Executive Vice President
707-745-5173 P
707-745-2332 F
Mercury Technologies of MN, Inc. RecycleLights
Fine City industrial Park P.O. Box 13 2010 East Hennepin Avenue
Fine City, MN 55063-0013 Minneapolis, MN 55413-2799
Raymond Kite Keith Thorndyke
President ' • 612-378-9568 P
612-629-7888 P 612-378-1179 F
612-629-7799 F
Resource Recycling
7253 Washington Ave
Edina, MN 55358
Paul Mehl
©Derations Manaaer
701-234-9102
701-280-1690
South
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Fluorescent Lamps: Lamp Maker Initiatives
National Electrical Manufacturers Association
Beverly Grimm, GE Lighting
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Net Environmental Impact Of
Efficient Lamps Is Positive
• "Discharge" Lamps containing Mercury have Highest Energy Efficienc;
(Light Output/Wan)
• Fuels used to Produce Electricity Contain Mercury
- Coat, Oil, Gas
* Various Authors' Estimates put NET Hg Releases from use of
Incandescent Lamps at 3X - 4X the NET Releases from use of
Fluorescent Lamps
- Major Release due to Energy Use - not Manufacture,'Disposal
* Other Pollutants are avoided by Saving Energy (Source: U.S. EPA)
•TlCWH = 726g Carbon Dioxide
5.3g Sulfur Dioxide
2.8g NOX
Source Reduction Programs
• Manufacturers Independently Committed to
Reducing Mercury Content of Lamps
Average Mercury/
4 ft., 1 1/2" Diameter
Lamp (U.S. Mfrs.)
Industry Concerns:
Lamp Reclamation Technology
i Full Recovery of Hg Iron Lamps oeing done to Limited &ctent Toaay
- Net Result is Volume Reduction, but most Hg still Disposed or Stock Piled: not Reused
- Users should Carefully Evaluate Reclamation Technologies
• Occupational Exposure must be Controlled
• Recovered Glass and Metal still contain Hg
- Safety of these Materials in Reuse Applications has not been Studied
• I4o Comprehensive Review of Comparative Environmental. Health.
Safety Impact of Various Disposal Methods
Insufficient Data to Determine Which is the
Environmentally Best Disposal Method
Disposal In MODERN, QUALITY Landfills Appears To
Be A Responsible SHORT TERM Management Option
1985
1990
1995 Projection
48.2 mg
41.6 mg
27.0 mg
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Industry Goals For Lamp Management Policy
• Environmentally Responsible Management of Spent Lamps
* Reduce Mercury Content to Lowest Feasible Level
- Phased Source Reduction Plan
• Infrastructure in Place before any Disposal Mandates
Become Effective
* National System - Limited State Variations
• Lamps not Classified Hazardous Waste when Properly Managed
e Available Leachate/Gas Condertsate Data suggest Hg not an Issue in
Landfills (Source: BF1. Waste Management Inc.)
- Hg Levels in Leachate Below Maximum Contaminant Level for Drinking Water
• - Gas Condensate Levels Below Detection Limit
e Quality Landfills with Liners and Laachate Collection/Monitoring
are Available in Most Areas of trie U.S.
• Source Separation Could be Avoided in most Locations
Fluorescent Lamp Waste Management
Proposed Legislation
• No Incineration
- Incinerators Widely Cited as Source of Hg Pollution
• Effective Control Technologies exist but not Widely Applied
• Source Reduction Standards
• Phased Reductions
• Product Labeling
• EPA Study of Lamp Waste Management Alternatives
• Interim Requirements: Quality Landfill or Recycle
• Define State Authority
• Suggested Regulatory Actions Are Exactly Parallel
• Goal is For Federal Program to Coordinate State Actions
Mercury Use In Fluorescent And HID Lamps Progress On Policy Implementation
* Mercury an Essential Component of Lamp Operation
- "Mercury Free" Lamps not Technically Feasible at this time
- Mercury Levels affect Lamp Life
* Mercury used in Lamps Represents a Smalt Part
of Total Mercury Potentially entering Environment
- Global Releases from Natural Sources 7.000 T/YR
* Global Releases from Coal. Oil and Gas Combustion 3.000 T/VR
- Global Releases from other Manmade Sources 3.000 T/YR
- Use in U.S. Lamp Production • ~ 30 T/YR
• Lamps account lor at Most 0.2% of Total Mercury Releases
• Secured Sponsorship for RCRA Amendment • Working
to Gain Support in U.S. Congress - wilt be Active
in 1993 Session
• Presented Regulatory Proposal to EPA to
Favorable Response—Following up with Futher Meetings
- EPA continues to Affirm Conceptual Agreement
- EPA has Agreed to Take Leadership Role in States
• Implementing State Strategies Consistent with Federal
Legislative/Regulatory Approach
- Supported CA Study Bill
- Worked with Florida Legislators to Mirror
Federal Proposal
• Supporting Minnesota Study Team
- Working with Minnesota PCA
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Fluorescent Lamps: New Developments in Europe
Christer Sundberg — MRT System, AB
Classification concerning Fluorescent
tubes in Europe
Recommendations to legislate collection and treatment of
fluorescent tubes was announced in Europe 1990.
A number of countries within EC and EFTA had already
stared collection or have up till now adopted to that
recommendations.
Such countries are:
The Nordic Countries
(SE.DK.FI.NOi
Germany
The Netherlands
Switzerland
Austria '
New directives are introduced in Belgium, Luxembourg and
France.
A part from the above countries, some laws are valid in
different regions or cities for collection of tubes.
E.g. Italy. The northern provinces have city laws that
classifies fluorescent tubes as dangerous city waste and
oblige the selective collection, for Instance Milan region law
37 from 198S.
Furthermore, most of the fluorescent tube manufacturers are
processing the scrap material from their production as such
treatment in general is required by the authorities.
Future directives within the
European Communities (EC)
* A proposal for a Council Directive on landfill of waste
was submitted by the Commission on April 23th. 1991,
code No. SVC 190/01.
* The proposed Directives has been presented January 13th.
1992, to the European Parliament.
* Now each Country Parliament are making preparations for
an approval.
* A second hearing will then take place in the European
Parliament in the beginning of 1993 and thereafter a
final approval to the Directives will take place.
The time frame for each country to adopt to the Council Directives
is five years. It is estimated by the technical commissioners and
the members of the European Parliament
that the directives will be implemented in most of the EC
countries within two years.
The proposed Council Directives states
the following criteria for landfilling
* The Hg limit for Municipal waste (Household waste to
ordinary landfill; is 2 g,' ton.
(Scrapped and crushed fluorescent tubes reaches approx.
150 - 200 g/ton i.
* The Hg limit for Industrial waste (Special deponi) is
100 g / ton. •
Secondly the leachate limit lace, to German DIN 38414/S4
from Oct. 1984) is 0.02 mg / litre - 0.1 mg / litre.
Within this limit the waste is considered as Hazardous
Waste and must go to Special landfill.
Above the 0.1 mg/ litre limit, the waste must be treated.
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This means that fluorescent tubes obviously must be
treated as the above limits are exceeded.
As landfilling of Hg contaminated waste is limited to
two (2) ppm for Municipal waste, the treated glass and
metals from fluorescent cubes can be a subject of Special
landfill if "less sophisticated and unqualified system and
technologies" are used. This could involve high deposal
costs, if such end products are not recyclable or exceed the limit.
In this connection it is most likely so that higher demands
V.
also will occur in the future on the recyclable material.
E.g. limits of foreign material in the glass fraction, etc.
Concerning the Mercurial fluorescent
powder different legislations are valid
In general, untreated powder cannot be landfilled anywhere
at any site. . •
Some countries allow temporary storage like e.g. the
Netherlands where AVR in Rotterdam have an unlimited
temporary storage permit.
Some bundeslander in Germany also allow temporary
storage in Salt mines.
As such storage, without any doubt is risky and dangerous
an independent European institute are at the moment
evaluating different technologies, both concerning
fluorescent tube recycling in general and how to deal with
the mercurial powder.
Most likely, well proven distillation technology will be
required.
Another qualified guess is that systems that creates a
mercury sludge from their process must find a solution to
this problem.'
Present situation in some
European countries
Legislation or recommendation
Percentage and number of treated tubes
* Technology available
E.g. - Nordic Countries fSE, DK, FI, NO)
Germany . Austria
The Netherlands . Belgium, Luxembourg, France
Switzerland . Eastern Europe
The Nordic Countries
Sweden: Collection and recycling recommended.
Approx. 5 million tubes or 40 % are treated in a
MRT Crush and Sieve Piantplus distillers.
Denmark: Collection and recycling legislated from Jan, 1st. 1993
Tubes from the Municipality of Copenhagen are pre-
crushed and shipped to the MRT Plant in Sweden.
Approx. 20 % of the consumed tubes are processed.
Finland: Collection legislated.
10 % of the consumed tubes are shipped to MRT,
Sweden. Another 10 % are treated in a MRT
installation in Finland.
Aquatechnic processes another 10 ck.
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Consumption in Eurcoe: Apcrox. 470 m/Bion
Collected in'mentoneo cmima: Aoprax. 75 moan
Additional volume collected in BENELUX.
France. Italy UK: Approx. s • 10 million
Gives percent collected ol
Approx: 20 %
r^T
So appro*. 30 <7c in total are processed of the Finnish
tubes.
Norway: Collection recommended.-
Approx 5 -10 9c of the consumed tubes are collected
and shipped to MRT, Sweden.
Lamp manufacturers
Manufacturers in Sweden and Finland are using MRT technology
for processing the scrap material from their production.
General market information about the Nordic Countries
Approx. 35 - 40 million tubes are consumed annually in the Nordic
Countries. Of those, roughly 25 - 30 % are collected and treated. A
big growth is expected volumewise during 1993 -1994 and will
probably reach 50 %. This is due to that a new marketing concept
is introduced and legislations will be adopted.
Germany
Approx. 90 collectors ace. to ZVEI (Zentralverbank
Electronicindustri) of which approx. 13 also have recycling
facilities.
Legislation: Collection and storage in general.
Treatment and Recycling legislated in several
bundeslander.
Technology No. of
used plants
(estimate)
MRT 5 End cut technology, crushers and distillers.
Glass and metal recycling.
Kuhl 3 Crushing and metal recycling.
Prolux 1 End cut technology, glass recycling.
Herborn 1 Crushing. No recycling.
Aqua 1 Crushing and washing of mixed glass and
metals from powder. Limited recycling
possibilities.
Osram 2 End cut technology. Glass recycling.
Approx. 50 million consumed tubes are collected which is approx.
40 % of the total volume. A rough estimation is that 35 - 40 million
of those tubes are treated at present.
Manufacturers are using recycling technology.
E.g. Osram use their own End cut technology in order to recycle
glass.
Sylvania use MRT distillers for internal scrap material from
production.
General market information about Germany
Biggest growth in Europe. Many contracts signed or under
negotiation for installation during 1993 -1994.
Germany environmental authorities, require waste owners or
producers to take care of the waste generated from their products
by using a green label.
Marketing concept introduced by one Lamp manufacturer to take
back the old tube when selling a new lamp.
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The Netherlands
40 - 50 % of all consumed fluorescent tubes are collected
and treated tapprox. 7 million our of 15 million).
Legislation: Fluorescent tubes classified as chemical/toxic waste.
Collection required.
Technology used.
Rasters: The major volume is collected under the logistic
control of LumenEx/PNEM. The company uses a
Kuster crush and sieve installation which partly is
designed and based upon the patented MRT sieving
technology. Kusters is a licensee of the MRT
technique for that installation.
MRT: Ecotechniek uses MRT end cut technology.
Lamp manufacturers
The manufacturer Philips uses both a Kuster installation and the
MRT end cut and distiller technology for processing the scrap
material from the production. F
General market information about the NethcrlanH*
Although, enough treatment capacity exists for processing and
separation of glass, metal and powder from all consumed tubes.
negotiations are to be continued with several companies for MRT
installations. One reason is that LumenEx only accept 10 000
tubes as the minimum volume to be collected. Secondly, no
distillers are installed yet for treatment of the fluorescent powder.
This is yet stored in AVR in Rotterdam under a temporary permit.
Switzerland
Approx. 40 % of the annual consumed volume of fluorescent tubes
are collected (4 million out of 10 millioni.
Legislation: Two documents have to be considered
TVA (Technische Verordnung uber Abfalle)
WS (Verordnung uber den Verkehr rait
Sonderabfallen). WS stipulated that
fluorescent tubes are to be considered as
hazardous waste when exceeding 12 pieces.
Hardest regulations in Europe:
Limit for Hg content in residue for landfllling:
0.01 ing/1 (leachatej.
Technology used:
- MBT End cut technology, crusher. Std distiller,
(used by Sovag/ Superior distiller. Recycling of all material
glass, metals, phosphor and mercury.
- Fairtec AG Crushing, washing. The glass and metal volume
goes partly to end users and partly to
Sondermulldeponi. Mercury- sludge created
which must be further treated.
- Recymet Crushing and sieving. Glass and metal cleaned
in dilute fiuoroboric acid and shipped to end
users or special landfill. Mercurial powder
stored, but is said to be cleaned by chemical and
electrochemical processes in the future. Mercury
should then be removed from fluorofaoric acid by
reaction with zinc or aluminium pellets and
thereafter distilled to remove mercury.
- SM Recycling Crashing and -.hereafter heating of all material
in a thermal process. Mercury trapped in silver
impregnated carbon filters. Thereafter the
material is separated into glass, metal and
powder. Glass and metals to end users. Mercury
niters and powder stored or exported due to the
mercury content.
General market information about Switzerland
The total recycling capacity is several times bigger than the need
for processing the annual consumed volume.
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The four companies use the same end user of the glass (Isover)
which use it for glass fibre insulation. Metals delivered to different
scrap dealers.
All the companies, except Sovag using the MRT technology, have
problems with the mercurial materials after the process. Recvmet
have partly been stopped this autumn for redesign work and
modifications on the electrochemical process, etc. SM Recycling
will probably make an agreement with Sovag to process the filters
in MRT distillers.
Sovag have had an increase in volume of waste the last year due
to that they have the complete technology for recovery of the mei
The volume increase concerning collection of tubes in Switzerland
has not developed as expected due to that less than 12 pcs are not
considered as hazardous. However, this limit is under review.
Austria
HI
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The major portion of the S million consumed tubes per annum are
today collected.
Legislation: Classified as special waste and collection
required. Similar waste laws as Switzerland.
More strict emission limits.
Technology used:
- MRT Crush and sieve system and distillers.
Recycling of glass, metal and mercury.
- Others Minor collection of tubes is done in western
Austria and shipped to south Germany.
Genera] market information about Austria
The major volume of tubes will in the future be treated by the
MRT plant located in Vienna.
Belgium, Luxembourg and France
In those three countries collection has started, but still it is of
course a minor volume of all consumed tubes.
Legislation and technology:
In Belgium; fluorescent tubes are classified as
toxic waste and at least one bigger system will
be installed using a crush, and sieve system and
MRT distillers.
In Luxembourg, fluorescent tubes are classified
as chemical waste. As the collection volume is
limited a smaller installation will take place
next year.
In France, two new directives will become valid
soon concerning collection points and industrial
waste. In the so called white book, is also stated
that a percentage of waste generated must be
recycled. Fluorescent tubes and other mercurial
products are of great concern. Plants of different
brands will be introduced and installed soon.
General market information
Those countries will soon, or have already, adopted to the EC-
directives. However, collection and treatment facilities are not yet
so established as e.g. in Germany. The Netherlands, Switzerland, etc.
Eastern Europe
MRT System AB has a strong market position in those countries
and have sold systems to the main lamp manufacturers like:
Philips in Poland
Tungsram / GE in Hungary
Tesla in Czechoslovakia
Different technologies are used like MRT crushers, crush and
sieves, end cut technology and distillers.
Lamp manufacturers are required to process their scrap material
from the production.
Soon, collection of consumed tubes will start in some of those
countries and further equipment will be installed during 1993 - 1994.
The legislation will most likely follow the EC directives.
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Collection Case Studies - Programs in Florida
by Jan Kleman
Hazardous Waste Management Section
Florida Department of Environmental Regulation
Florida has taken on the challenge.of household hazardous
waste (HHW) and conditionally exempt small quantity generator
(CESQG) waste management with great success. 42 of our 67
counties have either constructed or are planning construction of
permanent HHW collection centers. Approximately 10 additional
counties plan to hold mobile collections during the coming year.
With all of these programs in place, it is anticipated that in
1993, 78% of Florida's counties will be providing free
collections to households and cost effective collection
opportunities for CESQGs.
I'll be showing you slides of our permanent facilities and
describing the different methods of operation for Florida's local
HHW collection centers, but first, I want to tell you how we got
where we are today. There are three factors - need, legislation
and funding, that have each played an important role in assuring
the establishment of Florida's network of local HHW collection
centers. First, we've had the need. Florida is an
environmentally sensitive peninsula, extremely vulnerable to
groundwater pollution. Mismanagement of hazardous waste, even
from households, poses a real threat to our drinking water.
Second, we've had legislation to establish programs for managing
household, CESQG and SQG wastes. Our 1983 Water Quality
Assurance Act gave.Florida comprehensive groundwater protection
programs. One program, Amnesty Days, provided a free mobile
hazardous waste collection to each county, twice, and helped gain
public acceptance for permanent local HHW collection centers.
And third, our Water Quality Assurance Trust Fund provides the
funding for Florida's groundwater protection programs including
construction of permanent collection centers. This Fund is
replenished by an excise tax on products determined to be
potential groundwater pollutants (petroleum products, pesticides,
ammonia, chlorine, solvents and car batteries).
1985 legislation established Florida's Hazardous Waste
Collection Center Grant Program and our first permanent centers
were completed in 1987. The grant provides up to $100,000 per
county for costs associated with construction of one or more
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safe, secure HHW collection centers. Any remaining money may be
used for collection center operation. Participating counties are
required to operate their centers for 2 years after construction,
offering a minimum of 2 advertised collections per year that are
free to households and available to CESQGs for a reduced fee.
The counties must contract with licensed, insured, qualified
hazardous waste management companies, responsible for assuring
the proper and most appropriate management of the waste. And
finally, the county is responsible for working with its
contractor to establish expanded "milk-run" pick up services to
SQGs.
Permanent collection centers in Florida are generally
located at landfills and consist of pre-fab steel buildings that
are specifically designed for hazardous waste storage. The
buildings have 2 or 3 bays, each capable of holding 15 55-gallon
drums, and can have optional shelving. They are complete turnkey
structures with spill containment reservoirs and sump pumps along
with necessary and optional safety features such as an emergency
shower and eyewash.
Pre-fab sheds are used for storage of equipment and trailers
are used for office space. Some type of roofing is encouraged.
It may be a canopy, permanent tent or pole barn. There are
designated areas for storing lead acid batteries and work areas
for bulking different waste streams such as used motor oil,
antifreeze, flammable sludges and pourable flammables. At some
collection centers, freon and motor case oil are extracted from
white goods, aerosols are managed by capturing the propellant and
draining the contents of the cans, and certain wastes are
rendered non-hazardous. For example, one project manager can
neutralize pool chlorine at a treatment cost of 50 cents per bag.
She also destroys certain organophosphate pesticides such as
malathion, parathion and dog dips such as dermiton and paramite,
by hydrolizing them with soda ash.
About 25% of our local programs are run by project managers
with chemistry degrees and past work experience as field chemists
with hazardous waste management companies. There is a trend
among these experts to hold collection events without their
contracted hazardous waste management companies on site.
Instead, other county project managers and folks with chemical
management backgrounds such as chemistry teachers, are hired to
help out on the collection day, segregating wastes for temporary
storage in the appropriate bays of the collection center storage
building. The project manager then takes several days or weeks
after a big collection event to sort and consolidate wastes,
bulking certain waste streams for management by subcontractors.
Project -managers for 4 of our counties have been given special
permission by their contractors to lab pack. Once a project
manager has done all that he or she can, the main contractor is
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called in to identify any unknowns, lab pack if necessary and
transport remaining wastes to permitted storage areas to await
further management.
Our local collection center plan of operation is varied,
ranging from some sites being open daily to by-appointment-only
collections. 20 of Florida's counties meet the Duxbury
definition of a "permanent" collection center by being open l or
more days per month. Some counties only accept householdfcand
CESQG waste during big advertised collection events held once or
twice a year, either at the collection center or at a mobile
site. During 1992, there have been 79 such events consisting of
115 collection days. I have handouts available on plans of
operation for Florida's sites, a summary of collection activity
in Florida for this year and a project manager's contact list.
Although some counties hold mobile events, most collections
are held at the permanent centers. Therefore, we encourage 2-
lane driveways leading to and from a collection center and
adequate space for the contractor to bring in trucks and
equipment. The traffic flow works best if it moves in one
direction along a U-shaped or circular driveway. As a
participant waits for off-loading in front of the collection
center, he is greeted by county staff and asked to answer a few
questions on a participation sheet. After the contractor has
taken possession of the hazardous wastes that it will be
managing, the participant continues along the driveway to other
off-loading points. Latex paint, lead-acid batteries, used motor
oil and recyclable wastes will be taken from the participant by
county staff at different drop-off points.
Opportunities for continued education and networking for
Florida's project managers and collection center staff are
important. Therefore, an annual spring meeting is held where all
participants are encouraged to exchange ideas 'and war stories.
This past May's meeting included a 1-day site safety class and a
day of presentations by project managers on their individual
success stories and innovative specialty waste management
programs such .as curbside household battery collections, local
bio-hazardous management, SQG educational programs, public
awareness programs and cost-saving strategies. Copies of the
agenda for that meeting are available. This spring's meeting
will be held at the Jacksonville facility and the focus will be
on hands-on management of HHW including identification, sorting
and bulking compatible wastes.
The Grant Program was expanded 3 years ago to help our
smaller counties who cannot afford to support and fund a full- .
time collection center. The Cooperative Collection Center
Arrangement Grant is now available for the smaller county to hold
a collection for which the State will pay for 75% of the cost.
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The smaller county pairs off with a larger county experienced
with HHW management. The larger county receives funding for
assisting the smaller county in holding its collection. I have
the legislation on both grant opportunities available to you.
In summary, Florida has a well-established HHW and CESQG
collection and management infrastructure. By the end of 1993, it
is anticipated that 78% of Florida's counties will be holding
'some type of collection opportunity for their residents. It is a
pleasure to share Florida's success story with you.
Jan Kleman
Environmental Specialist
Hazardous Waste Management Section
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, Florida 32399-2400
(904)488-0300
ATTACHMENT
1992 Summary
HHW Collection Activity in Florida
COLLECTION ACTIVITY AT LOCALLY-SPONSORED PERMANENT HHW
COLLECTION CENTERS FUNDED FROM THE HOUSEHOLD HAZARDOUS
WASTE COLLECTION CENTER GRANT -42 COUNTIES
Alachua County - Collection Center is open daily, by
appointment only. In addition, an average of 2 major
collection events per year.
Brevard County - Collection Center is open 1 day per week. In
^ addition, an average of 2 highly advertised collection events
per year.
Broward•County - Average of 2 highly advertised collection
events per year.
Charlotte County - Collection Center is open 6 days per week.
In addition, an average of 12 major collection events per year,
Citrus County - Average of 2 major collection events per year.
Clay County - Average of 2 major collection events per year.
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Collier County - Collection Center is open 1 day per week. In
addition, an average of 2 major collection events per year.
Dade__ County - Average of 2 major collect in events per year.
DeSoto County - Average of' 2 major collection events per year.
Duval County - Collection Center is open 2 days per month, by
appointment only. In addition, 2 major collection events per
year.
Escambia County - Ceased collection activity after contractual
committments: for funding were met.
Hamilton County - Average of 2 major collection events per
year.
Hardee County - Average of 2 major collection events per year.
Hendrv County - Average of 2 major collection events per year.
Hernando County — Average of 2 major collection events per
year.
Highlands County - Average of 2 major collection events per
year.
St. Johns County - An average of 2 major collection events per
year.
St. Lucie County - Collection Center is open 6 days per week.
In addition, an average of 2 major collection events per year.
Sarasota County - Both Collection Centers are open 1 day per
week. In addition, an average of 4 major collection events per
year.
Seminole County - Both Collection Centers are open daily. In
addition, an average of I major collection event per year.
Suwannee County - Site construction is delayed until January,
1993, pending permitting of a new landfill site..
Volusia County - Collection Center is open daily. In addition,
an average of 2 major collection events per year.
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County Sposored Collection Events in Florida
79 HIGHLYADVERTISED MOBILE EVENTS— 115 COLLECTION DAYS
Date Location (County) No. Davs
1/92 Charlotte
1/92 Hillsborough
2/92 " ' Charlotte
2/92 Highlands
2/92 Hillsborough
2/92 • pasco
2/92 Sarasota
3/92 Charlotte
3/92 Hillsborough
4/92 Alachua
4/92 Brevard
4/92 Charlotte
4/92 Clay
4/92 Dade
4/92 Desoto
4/92 Duval
4/92 Hamilton
4/92 Hillsborough
4/92 Qrange
4/92 Sarasota
4/92 Seminqle
5/92 Broward
5/92 Charlotte
5/92 Hillsborough
5/92 Leon
5/92 Marion
5/92 Putnam
5/92 St. Lucie
5/92 Volusia
6/92 Charlotte
6/92 Citrus
6/92 Collier
6/92 Hillsborough
6/92 Lee
7/92 Charlotte
7/92 Hillsborough
8/92 Charlotte
8/92 Indian River
8/92 Hillsborough
9/92 -Charlotte
9/92 Levy - Co-op
9/92 Polk
9/92 Orange
9/92 Hillsborough
9/92 Lee
9/92 Alachua
9/92 Lake
9/92 Monroe
9/92 Clay
1991 summary of Locally-Sponsored HHW Collection Events in
Florida: 67 counties; 79 collection events; 115 collection days,
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3
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2
1
1
2
1
1
2
1
2
1 .
4
1
1
2
1
2
1
1
1
2
1 .
1 .
1
2
2
1
2
3
2
2
1
Date
10/92
10/92
10/92
10/92
10/92
10/92
10/92
10/92
10/92
10/92
11/92
11/92
11/92
11/92
11/92
' 11/92
11/92
11/92
11/92
11/92
11/92
11/92
11/92
11/92
12/92
12/92
12/92
, 12/92
12/92
12/92
Location(CountvL No. .Days
Glades - Co-op 1
Brevard 3
Duval 1
Hillsborough 1
Okeechobee - Co-op 1
Volusia 4
Flagler - Co-op 1
Charlotte 1
Leon 1
Okaloosa 2
Sarasota 2
Charlotte 1
Dade 2
Hendry 2
Duval 1
DeSoto 1 •
Highlands 1
Putnam 1
Lee 1
Manatee 2
Hillsborough 1
Marion 1
Hamilton 1
Madison ' 1
St. Lucie 1
Citrus 1
St. Johns 1
Lee 2
Charlotte 1
Hillsborough 1
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October 1992
FLORIDA RESIDENTS "
CALL YOUR COUNTY FOR HOUSEHOLD
HAZARDOUS WASTE COLLECTION INFORMATION
The following counties are participating in the Florida Hazardous Waste
Collection Center Grant Program which provided up to $100,000 funding per
county for establishing and operating one or more local hazardous waste
collection centers.
COUNTY
Alachua
Brevard
Broward
Charlotte
Citrus
Clay
Collier
Dade
DeSoto
Duval
Escambia
Flagler
Glades
Hamilton
Hardee
Hendry
Hernando
Highlands
Hillsborough
Indian River
Lake
Lee
Leon
Levy •
Madison
Manatee
Marion
Martin
Monroe
Okaloosa
Okeechobee
Orange
Orange
Osceola
Palm Beach
Pasco
Pinellas
Polk
Putnam
St. Johns
St. Lucie
Sarasota
Seminole
Suwannee
Volusia
CONTACT
Chris Bird
Rita DiStasio
Al Gomez
Jim Thomson
Cathy Winter
Greg Pitts
Keeth.Kipp
Cindy Dwyer
Anne Alley
Steve Waterman
Charles Miller
John Schwabb
Ed Jablonwski
Jim Smith
J. R. Prestridge
Jim Kulczy
Frank Wentzel
Christy Reed
Steve Young
Stacy Strickland
David Crowe
Rick 'Clontz
Rosemary Bottcher
Billy Cobb
Jerome Thompson
Cari Walz
Norman Render
Dana Hansen
Ron Stack
Jim Reece
David Rivera
Dan Carrington
Juan Martinez
Chris Pappas
Dave Gregory
Farouk EL-Shamy
-Martha Gray
•John Kolek
Joe Battillo
Steve Marsh
Freddie Cordero
Dennis Laabs
John Hauserman
Lester Baxter
Susan Gaze
PHONE
904/336-2442
407/633-2161
305/765-9202
813/639-1802
904/746-5000
904/284-6374
813/732-2507
305/594-1585
813/993-4826
904/630-0973
904/968-6628
904/439-3778
813/675-0124
904/792-1020
813/773-5089
813/675-5253
904/754-4037
813/655-1626
813/272-6674
407/569-0050
904/742-8427
813/335-2432
904/922-0400
904/489-4311
904/973-2611
813/792-8811
904/620-3430
407/288-5700
305/292-4432
904/698-5774
813/763-9312
407/836-7400
407/249-6266
407/847-4481
407/687-1100
813/847-8041
813/892-7720
813/533-1205
904/329-0396
904/923-9027.
407/468-1768
813/364-4488
407/322-7605
904/362-3992
904/239-7766
SUNCOM
SC 625-2442
Ext.249
SC 737-1255
SC 827-6374
SC 751-2507
SC 735-4252
SC 543-6655
SC 224-1394
SC 659-9619
SC 527-5423
SC 667-3430
SC 472-4439
SC 698-5774
SC 356-7400
SC 596-1145
SC 569-1205
SC 869-0395
SC 259-1768
SC 522-4488
SC 355-2000
PROPER HAZARDOUS WASTE MANAGEMENT
For information on the Hazardous-Waste Collection Center Grant Program or on
establishing local hazardous waste management programs, call the Department
of Environmental Regulation at 904/488-0300, extension 48.
To find out where you can recycle or dispose of used oil in your area, call
the Department of Environmental Regulation toll free number, 1-800-741-4337.
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Workshop 2-E - Collection Case Studies I
The EPA Region VIII Program
Brian Rimar, U.S. EPA Region VIII . -
* Why HouseholdHazardous Waste (HHW) Programs Are Promoted
- In the 1990 U.S.. Environmental Protection Agency (EPA)
Municipal Solid Waste (MSW) Conference Dana Duxbury gave a slide
presentation on the status of HHW programs. When a slide showing
the locations of programs in the U.S. was shown, EPA Region VIII
(North Dakota, South Dakota, Montana, Wyoming, Utah, and
Colorado) looked like the hole of a donut. Only Larimer and
Jefferson Counties, Colorado, had regular programs.
- It.was easy to convince management in the solid waste
section that HHW programs would be beneficial and should be
promoted. Source reduction was and is one of the section
priorities.
* Proj ect Funding And Pjromotion
- First the.region needed a way for local MSW professionals
to share knowledge, meet national experts, and obtain useful
information on how to initiate a program. This was accomplished
through a conference in March 1991, co-sponsored by EPA Region
VIII and Boulder County, Colorado. Following the one day
conference the Missouri Household Hazardous Waste Project offered
two sessions of "From Awareness To Action : A Household
Hazardous Waste Issues Training Course". All events were very
well attended; We believed that with the conference and the
training course that the basic knowledge had been offered.on how
to .start a collection program and/or education program.
- Agenda for Action Grants provided another avenue of
support. These are competitive grants available to tribal,
state, and local governments and not-for-profit organizations.
These grants can be used for a wide variety of MSW work, but
cannot be used for capital purchases or normal operations and
maintenance.
* Current Grants
- The Clean Water Fund of North Dakota has received funding
for the "Pollution Prevention Begins At Home" education project.
Similar to previous Clean Water Fund campaigns in New Jersey and
Minnesota, this program will give'public demonstrations in malls,
to community groups, the media, and migrant farmworkers.
- Also in North Dakota EPA is funding a joint project
between the state government and the Association for Retarded
Citizens. One aspect of the program is a planned HHW exchange.
-, The Colorado League of Women Voters is working with Agenda
For Action grant funds on a statewide HHW public education
program. The league is giving point-of-sale demos on low or non-
toxic alternatives, airing HHW education videos on PBS, and
providing used oil collection information where motor oil is
sold.
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- The newest HHW grant in Region VIII has been awarded to
the Junior League of Sioux Falls, South Dakota. The planned
program includes a statewide education campaign, a paint
collection, and the production of a paint collection how-to
videotape.
* Problems
.- We have been successful in raising awareness of HHW
•issues. Unfortunately, this comes at a time when the regional
Agenda For Action grants have been cut.
- Grantees should be prepared to use the grants when they
are rewarded. A grant for assistance in siting a permanent -
collection facility was cancelled when the local government was
politically unable to make the siting decision..
- There are limitations to the EPA grants. They cannot be
used for capital costs, or normal operations and maintenance.
Most regional offices are looking for a realistic workplan that
produces a unique deliverable. Each region has a different
system for choosing grantees, some use open competition, others
use the funds to support organizations with proven records.
- As collection programs increased so did the regulatory
questions. The EPA hazardous waste management staff, or RCRA C
sections, were unfamiliar .with some of the HHW issues. When
asking for HHW management guidance from regulatory agencies be
sure you are dealing with an individual who has experience.
* FUTURE
- The number of collection programs is growing throughout
the region. Some are funded by increased landfill tipping fees,
such as the program in the City and County of Salt Lake, Utati.
Some programs have expanded into Conditionally Exempt Small
Quantity Generator (CESQG) waste collection, such as El Paso
County, Colorado.
- We will be encouraging, more programs funded by
supplemental environmental projects (SEP's). SEP's use fines
from enforcement actions under a variety of environmental
statutes, i.e. CERCLA, RCRA, CWA, SARA, etc., to fund pollution
prevention projects. The City and County of Denver, Colorado, is
currently working on a SEP to fund a HHW education project and
start-up costs for a paint reprocessing facility.
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CLEAN HOUSE
DSWA'S Pilot HHS
Julie .
Project
Delaware Solid
Dover
EXECUTIV
Between November 1, 1991,
Solid Waste Authority sponsored .
and disposal of household hazarc
month pilot program, named Clea:
different methods of HHS collec
drop-off center operated in Su
collection van operated in Kent <
statewide $2.00 per ton surcharg
A total of 32,764 pounds
were collected from 304 people
pounds of HHS and 29,567 pounds
people through the door-to-doo:
participation rate was 0.4% of
County.
Contractor costs, including
were $191,519.46 in Kent County,
Other costs; including publi<
$108,231.92 in Kent County and $
total cost of the program was $5
The Delaware Solid Waste
(3) municipal solid waste landf:
Reclamation Plant, which process«
ferrous metals, a refuse-derived
Authority also owns two (2) tran:
Delaware, a state-wide voluntary
A household waste composit
hazardous substances to be 0.58
About half of the 791,000 tons o:
estimated to be from househol<
percentage of Delaware's solid v;
of 2,400 tons of HHS enterinc
significant.
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Through state legislation in June of 1990, the Authority was
directed by the General Assembly to develop "a program to source
separate materials from the solid waste stream which are harmful to
the environment for purposes of separate authorized disposal."
PLANNING
In response to the legislation, the Authority began developing
the scope of an HHS management program. Among the many issues that
were addressed in the planning process were the type of program,
staffing, operating hours, contractor pricing structure, type and
location of storage facilities, and funding.
Type of program
A variety of existing programs were reviewed throughout the
United States and Europe, including one-day clean-up events,
multiple events, fixed drop-off facilities, mobile drop-off
facilities, and home chemical collection.
These programs were evaluated based on factors such as price
and participation rates. It was found that European home chemical
collections are successful in diverting a high amount of HHS from
the regular solid waste stream. Because an operating home chemical
collection program could not be identified in the United States,
the Authority decided to evaluate door-to-door collection through
direct experience, a six-month pilot program comparing door-to-door
collection with operating a drop-off center.
Staffing and operating hours
Since the Authority generally contracts with private companies
to operate its facilities and programs; the HHS pilot program was
staffed by a hazardous waste contractor. A single company was
contracted for staffing the collection program, as well as for
transportation and disposal of the HHS.
Since safety considerations were' a priority, operation of
each program required a minimum of two (2) staff people for safety,
and each was required to be trained in hazardous materials handling
techniques, chemical compatibility, first aid, and spill response.
Full-time operating hours, including Saturday hours, were
established to handle a potentially high participation rate and to
make the program as convenient as possible for the public.
Although considered, no evening hours were scheduled for both
safety considerations and collection-van navigation.
Contractor pricing structure
Contract pricing was developed with a single unit price (per
pound) for HHS transportation and disposal fees, and a fixed
monthly fee for collection services, including program staffing,
hotline service, equipment, and supplies.
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Type and locationof storage facilities
Temporary storage facilities were located at the landfills for
a number of reasons, including of existing truck scales, security,
and site availability. Uncomplicated temporary storage facilities
with prefabricated storage building were selected for minimal
construction time and future flexibility.
Funding
A critical aspect to a successful HHS management program is
funding. The Authority does not rely on taxes to operate its
facilities or programs; however, a funding mechanism was provided
in the legislation creating the HHS management program. A $2.00
per ton surcharge was added to the solid waste disposal (tipping)
fees at the Authority's facilities.
SELECTING A CONTRACTOR
The Authority issued a Request for Proposals for HHS
collection and disposal services, resulting in the receipt of five
.(5) proposals. . Clean Harbors of Kingston, Inc. was selected.
Their proposal presented an excellent operations plan and
demonstrated substantial experience in household hazardous
substance collection programs.
TEMPORARY STORAGE FACILITIES
Facilities were constructed for temporary HHS storage at two
of the Authority's landfills, the Southern Solid Waste Management
Center (SSWMC) and the Central Solid Waste Management Center
(CSWMC). These facilities each consisted of a hazardous materials
storage building and oil storage tank located on a large concrete
work area, surrounded by chain-link fencing. The contractor
provided portable equipment-storage buildings at each site and a
trailer to accommodate its personnel at the SSWMC.
The prefabricated hazardous materials storage buildings were
supplied by the contractor. Each 22 ft. by 8 ft. building is
separated into three (3) storage areas and is constructed with a
separate secondary-containment sump to contain any spilled liquids.
Other features included explosion-relief panels, mechanical
ventilation, fire suppression systems, heating, air-conditioning
and lighting. The area of the concrete pad at the CSWMC was 1,400
square feet. The concrete pad at the SSWMC was larger, 3,100
square feet, to accommodate the contractor's office trailer.
METHODS
The pilot program, named Clean House/Clean Earth, began
operation in two (2) Delaware counties on November 1, 1991. Door-
to-door collection by appointment served Kent County, and a staffed
drop-off center served Sussex County. The following briefly
describes the pilot program operation.
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Collection and drop-off
Door-to-door collection service by appointment was provided to
Kent County residents who called the toll-free hotline. Two (2)
full-time hazardous waste professionals operated a small van/box
truck to provide the door-to-door service. Materials were
collected, packaged, documented on a bill of lading, and brought
back to a temporary storage facility at the CSWMC. Household
collections were scheduled from Tuesday through Saturday between
the hours of 7:00 a.m. and 3:30 ip.m.
A drop-off center was located at the SSWMC in Sussex County to
accept HHS from Sussex County residents. Collection staff were on-
hand during the hours of 7:00 a.m. to 3:30 p.m., Tuesday through
Saturday. Two (2) staff members were provided during the first two
(2) months of the program, but due to moderate participation
levels, staffing at the SSWMC for the remainder of the program was
reduced to one (1).
Materials accepted
Common materials collected included paints, solvents,
automotive fluids, and pesticides. Provisions were also made for
certain highly dangerous materials such as radioactive, shock
sensitive, explosive, infectious, and dioxin-related (pentachlor-
ophenol) wastes. While not a hazardous waste, oil was also
collected by the contractor and disposed by a local oil recycler.
Latex paint was not collected because it is not generally
considered hazardous. Asbestos was not collected because an
existing disposal option is available at the Cherry Island Landfill
in Wilmington, Delaware.
Hazardous substances were collected from households as well as
agricultural-waste generators. Although limited exceptions were
made, most commercial and institutional generators of hazardous
materials were excluded from the collection program.
Temporary storage facility operation
Although no permits were required for the construction of the
temporary storage facilities, a U. S. EPA identification number was
obtained for each facility.. Once the HHS was accepted at each
facility, the Authority became the generator of the waste. The
contractor maintained an inventory of the types and quantities of
HHS stored and routinely performed facility inspections.
The contractor consolidated most paint, solvent, antifreeze,
and oil into larger containers to reduce transportation and
disposal costs. Empty containers were disposed as non-hazardous
solid waste.
Contractor project coordination was provided by a full-time
Project Manager. The Project Manager answered the toll-free
telephone hotline, scheduled appointments, prepared hazardous waste
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manifests, generated monthly reports, and provided supervision for
other staff. His office was located at the SSWMC, and he provided
assistance to the drop-off center staff when needed.
Advertising
Program publicity was coordinated by the Authority's public
information officer. The program's slogan was "Don't pitch out,
pitch in." Consultants were used to develop an attractive logo as
well as the layouts for print advertisements.
Extensive advertising was used to inform the public about the
HHS- management program. Radio, newspapers, and television were
utilized with both paid advertising and public service announce-
ments. Press releases and articles were also distributed to the
media, and posters were sent to local businesses. Radio and
newspaper were emphasized, including weekly newspaper advertise-
ments, and three (3) radio advertisements per day on each local
radio station.
In addition, two unique publicity events were held in April.
Three (3) Delaware radio stations held remote broadcasts at the
SSWMC to encourage an "early spring cleaning" prior to the end of
the pilot program. Landfill tours and T-shirts were also offered
to participants during the radio remote broadcasts.
RESULTS
HHS quantities
A total of 77,742 pounds of hazardous materials and 41,394
pounds of motor oil were collected through the Clean House program.
Ninety-one percent (91%) of HHS collected were pesticides, paint,
solvents, fuel, and oil. Very small quantities of highly dangerous
materials, such as shock sensitive, explosive, and infectious
materials, were collected, while no radioactive waste was seen
during the six-month program. 762 pounds of pentachlorophenol is
currently in storage due to the lack of an Authority-approved
disposal option. Table 1 presents the total quantity and types of
HHS collected during the pilot program.
Similar types of HHS were collected in each county. Pest-
icides were the largest component of HHS collected. Paint and
solvents were also commonly collected. Motor oil, which is not
considered hazardous in Delaware, was collected in large quantities
in both counties. Figure 1 presents each percentage of the major
types of HHS collected during the pilot program.
A total of 32,764 pounds of HHS and 11,827 pounds of oil
were collected from 304 people at the Drop-off center in Sussex
County. 44,978 pounds of HHS and 29,567 pounds of oil were
collected from 503 people through the door-to-door service in Kent
County. Agricultural waste accounted for approximately twenty-
three (23) percent of the hazardous substances in Sussex County and
sixteen (16) percent in Kent County. Each agricultural participant
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disposed of a much higher -/amount of HHS than the average household
participant.
Oil and small household batteries are also collected through
Recycle Delaware. 67,173 gallons of oil and 35,520 pounds of
batteries were collected from all three counties in Delaware from
unattended state recycling centers in FY 92.
Participation rate
The HHS pilot program results show a significantly higher
participation rate in Kent County than in Sussex County. The total
participation represents a rate of 0.4% of the 74,253 households in
Sussex County and 1.2% of the 42,106 households in Kent County. It
should be noted, however, that although the number of households in
Kent County is less than in Sussex County, the actual population is
similar.
Table 2 provides a monthly participation breakdown.The highest
monthly participation occurred during April, the last month of the
program. The highest daily participation also occurred in April.
In Sussex County, one of the radio-remote broadcasts brought in 48
participants in one day. In Kent County, the highest was 16
participants served on any one day.
Disposal
All of the HHS collected in the program was packaged, shipped,
and disposed in a manner similar to that of industrial hazardous
waste. The contractor was required to transport all the HHS by
hazardous waste haulers and dispose of it at Authority-approved
treatment, storage, or disposal facilities.
The contractor was required to fully track and document all
shipping and disposal activities. The contractor must provide
shipping manifests, facility routing information, and evidence of
destruction, such as "certificates of disposal," prior to payment
for disposal services.
cost
The contract cost to the Authority was $18,675 per month for
HHS collection in Kent County, $16,175 per month for HHS collection
services in Sussex County, and $1.77 per pound of HHS for disposal
services. The Sussex County collection price was reduced by
$200.00 per operating day when the contractor's staff was decreased
in Sussex County.
Due to higher fixed costs and a higher participation rate, the
collection and disposal cost was higher for Kent County than for
Sussex County. The six-month collection and disposal cost was
$191,519 for Kent -County and $135,635 for Sussex County. The
average collection and disposal cost per pound was $4.27 in Kent
County, and $4.23 in Sussex County. In any single month, the
average collection and disposal cost per pound was the lowest in
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April at $3.05 per pound for KentjCounty and $3.39 per pound for
Sussex County, because the participation rate increased and
contractor efficiency improved. This information is shown in Table
3. Quantities identified in Table 3 include only materials
disposed by the contractor, and do not include pentachlorophenol or
oil.
Although contractor cost was the greatest expense of the pilot
program, other significant costs included HHS storage facility
construction and program publicity.
The total cost of construction for the drop-off center at the
SSWMC was $63,864.25 and for the temporary storage facility at
CSWMC was $61,639.61. Construction at SSWMC was higher because
a larger concrete area was required to accommodate the contractor's
trailer. The most costly expenditure for the facilities was the
purchase of the storage buildings ($38,000 for each site).
The total publicity cost was $90,549.48. Paid radio
advertising cost $40,614.98, and radio stations also provided
public service announcements at no cost. Paid newspaper advertising
cost $33,069.98, and free newspaper advertising was gained as a
result of the preparation and distribution of news and information
releases. Other publicity expenditures included a television
commercial ($2,550), photographs ($1,685.97), printing and copying
($1,750), and consulting services and miscellaneous publicity
expenses ($10,879.28.)
Miscellaneous program expenditures included oil recycling,
electric utilities, and safety supplies. The total cost of the
pilot program was $546,220.19. A cost summary can be found in
Table 4.
Table 5 provides information on average cost and amounts
collected per participant. The average participant disposed of
89.3 pounds of HHS and 58.8 pounds of motor oil in Kent County; and
105.5 pounds of HHS and 3.8.9 pounds of motor oil in Sussex County.
Although the door-to-door program had a higher total cost, it
collected a higher quantity of HHS, resulting in a lower program
cost per pound. The total program cost per pound of HHS and oil
collected was $4.03 in Kent County and $5.61 per pound in Sussex
County.
CONCLUSION
Based upon participation rate and cost per participant, the
door-to-door collection program was more successful than the drop-
off program. Door-to-door collection yielded a greater
participation rate than the drop-off center. In addition, its
collection and disposal cost per pound was similar to that of the
drop-off center, and its overall program cost per pound was
significantly less. However, higher participation generated more
HHS requiring disposal, resulting in higher total program cost for
the door-to-door collection program.
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Figure 1. Pilot program summary
-Solvents (15.3%)
Oil (34.7%)
Other (8.9%)
Paint (15.4%)
Pesticides (25.5%)
Figure 2. Monthly Participation
NOV
DEC
JAN FEB
Month
MAR
APR
- Table 1. HHS and Oil Quantity Summary
Clean House/Clean Earth
Six-month Pilot Program Summary
Quantities of material collected (pounds)
Type
Solvents
Pesticides
Corrosive liquids
Aerosols/Cylinders
Other
'Oil-with P.CBs v ''•''''•>*.' '•'":l';;.\~ -»P
Recyclable oil
TOTAL
Sussex Co..
6,426
14,770
": "" '258'"
""213
117
11,827
44,591
Kent Co.
11,844
15*653
2,546
r~5&
1,813
29,567
74,545
TOTAL
18,270
30yi23
2*804
J.73.1!.
1,930
41,394
119,136
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Ingrld Dierlam
AUSTIN, TEXAS; EVOLUTION OF A TEXAS HOUSEHOLD HAZARDOUS WASTE
COLLECTION PROGRAM
1
I HOUSEHOLD HAZARDOUS WASTE CONFERENCE TALK .
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• Thank you for inviting me to speak at this conference.
.m Today, I'd like to describe the history of Austin's household
• hazardous waste collection program - from one-day a year collection
events to the permanent collection facility which is presently
• opened one Saturday every other month. I will also speak to the
Texas Water Commission's role in household hazardous waste
J| collection and other community hazardous waste management in Texas.
™ Some background on myself: I have worked for the City of Austin on
• its household hazardous waste collection program and helped develop
and implement the permament cpllection facility. 'l am currently
g working with the Texas Water Commission in the Community Hazardous
Waste Management Unit of Community Support on statewide HHWC
efforts.
in April of 1986, after 12 long months of planning, the City of
Austin, held the first household hazardous waste collection in
Texas. Funding for this collection- came from the City's Water and
Wastewater Department and the Solid Waste Department. Grassroots
support came from League of Women Voters, Sierra Club, Audubon
Society, Fire Department, local remodeling contractors and City and
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State agencies, including the Texas Water Commission.
This first collection was held on a Saturday in April at 2
locations: one was in the parking lot of a local park, the other
was in the parking lot of the Texas Department of Health. 450
t ,
households participated, 150 (55 gallon drums) or 33,000 pounds of
household hazardous waste was diverted from the municipal waste
stream, 500 gallons of latex paint was recycled, 50 automotive
batteries and 600 gallons of waste oil were collected. (I have a
few copies of all of these numbers here with me today.)
The next year, 1987, sites were changed to a parking lot of a local
high school and a parking lot of a local middle school. The number
of households participating went up to 650, while the amount of
4
wastes decreased to 120 (55) gallon drums or 26,400 pounds. The
amount of batteries quadrupeled to 216 and the amount of waste oil
&
little more than doubled to 1300 gallons.
In 1988, the City again had two collection sites: the high school
and a parking lot of a City swimming pool. Keep in mind that the
pool was not yet opened for the season and all wastes were offsite
by Monday morning. The amount of household participating increased
to 1,070 and 167 (55) gallon drums of wastes were collected. 1500
gallons of latex paint was collected for use by housing
rehabilitation groups and the amount of batteries collected went up
to 600.
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• Because of the increase in participation, the city increased the
• number of collection points to 3 for the 1989. one was again held
in the parking lot of a swimming pool, one in the parking lot of a
• ^baseball complex (this was the county site) and the third.in the
s parking lot of a high school football stadium. This last location
I was by far the best one for the one-day collections due to the
« enormous size of the parking lot. A total of 1,260 households came
* out to these sites to participate dropping off 260 (55) gallon
• drums of hazardous waste. 3,400 gallons of waste oil were also
collected.
I
_ For the 1990 collection, the city went back to the 2 location
• option: the swimming pool parking lot and the stadium parking lot.
• The county site did not have as much participation as the City
thought it would have, so it was dropped. This collection turned
•I out to be the city's largest one-day collection with 1,800
households participating. 380 (55 gallon) drums of hazardous waste
• was collected (going up from 260 drums collected in 1989), 2,002
• gallons of latex paint went to local housing rehabilitation groups
and 3,850 gallons of waste oil was collected. This was the City's
• last one-day collection event.
• Since the first collection, the City had been taking information
• from the participants in the form of a survey. When the question
"How often should this service be provided?" was asked,
• participants told the City that at the very least, collections
should be made available twice a year. The City was also manning
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an Environmental Hotline, which deals with questions from citizens
on household hazardous waste disposal to environmental complaints.
Persons running the hotline were overrun with questions on
household hazardous waste disposal and the need for more collection
times. Because of the citizens response to the survey and the
response on the hotline, the City felt that it was time to expand
the program and began planning for a more permanent collection
facility.
On October 19, 1991, the City of Austin held its first collection
at the permanent collection facility. This was the first facility
of its kind in Texas and lots of trails were blazed through its
opening.
The facility has 2 (1000 gallon) waste oil tanks, a 3 compartment
hazardous materials storage building, 3 storage sheds, an office,
a paint and battery staging area as well as an area for packaging
of household hazardous wastes. This operation is done under a tent
which is put up prior to each collection.
At the present time, the facility is opened one Saturday every
other month from 9:00 to 3:00 and by appointment on the Friday
preceeding the collection. For 1993, the City plans on adding 18
summer evening collection, to avoid the heat during the day.
Eventually, the City hopes to expand the program to have
collections either weekly or monthly on Thursday, Fridays and
Saturdays. The City also plans on moving the site to another City
facility where areas of the facility, like the packaging area, can
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be done under permanent cover.
• The Texas Water Commission's role in household hazardous waste
collection in Texas is expanding. The Commission has regulatory
• authority over collections and reviews operational plans and
approves or denies them. Any entity wishing to hold a collection
• must send this plan to us prior to the collection. The Commission
g has also been directed to administer grants for household hazardous
waste collection. This year, we have awarded $1.6 million in
• grants to 7 entities. This money came from the municipal solid
waste fund created by the tipping fees paid at municipal landfills.
| This money was directed back to municipalities through a bill from
— the Texas Senate. This bill mandated that this grant money could
™ not be used for disposal of household hazardous wastes, only for
• the collection- end of it. We hope to have additional money next
year, so more grants can be awarded.
The City of Austin has been a model for household hazardous waste
• collection in Texas, starting the first one-day collections and now
establishing the first permanent collection facility in Texas.
j§ We at the Commission- expect to have many more cities in Texas
follow Austin's lead.
In March of this year, the Texas Water Commission was delegated the
responsibility for authorization of household hazardous waste
collections. This responsibility was given to the Community
Hazardous Waste Management Unit of the Community Support Program.
In addition, to household hazardous .waste collection program
management, this unit also organizes and conducts 2 to 4 waste
pesticide collections a year and will be conducting around 35 empty
pesticide container recycling programs. Our current staff level is
4 persons for the entire state of Texas, so we've got our work cut
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Service Center
SEttVICES
Environmental. Protection Agency
Household Hazardous Waste Conference
Minneapolis, Minnesota - December 8-12, 1992
Speech Presented By:
LeeAnn Merashoff - Field Service Manager
DEVELOPING AN RFP
1. INTRODUCTION
Our Hazardous Waste Management firm has responded to literally
hundreds of RFP's, or Request for Proposals There are basically
two ways contractors can respond to RFPs - The "Technical
Approach" where we write a technical, logical response to the
RFP, or the "osmosis approach" - placing the paper on your head
and hoping the vibrations tell you what is needed as a response
to this RFP.
Basically an RFP conveys information that is organized in such
a way that you get useful information in return. You want to
give just the right amount of information - too much or too
little and you might get the "osmosis approach" to the
response.
2. There are several steps to developing a good RFP - lets
start with the very first -
First make sure you know what your state, municipal or local
. legal requirements are for bidding. Don't assume anything
about this issue until you've done your research, - it
will pay off later if you know accurately what you have to do,
to have you RFP legally acceptable.
For example: do you need to go out for competitive bids, or
can you accept technical proposals for a special "service."
Find out if there is a certain kind of proposal or bid that" you
LaiQlaw Environmental Services (North East!. Inc.
221 Sutton Street North Andover. Massacnusetts 018^5 Phone 508.683.1Q02 Fax 508.794.9665
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have to do. We've seen programs cancelled because the wrong bid
form was used. Prepare a checklist of legal requirements and
review it often. The next most important thing to do is to ask
in the RFP for a demonstration of the firms qualifications.
This will include references - but don't just ask for
references - ask for the contact's phone numbers and names and
also for a description of the types of programs - this will be
important when you're trying to evaluate the proposals.
Ask for background on the firm - this will vary depending
much you know about your bidders. You really want to know
•
what's behind the proposal, in terms of financial strength,
• contractual commitment and historical precedence.
Once These are out of the way, and these are two very
• important elements - you can move on to the more "common"
elements of good RFPs. These include:
m 1. A Description of the program
• This description could be a narrative; clearly, concisely
written , that gives a brief background on the program
development. State goals such as "providing an educational
opportunity for participant." State if you are targeting
certain waste streams, or a certain population group.
Further, this description should include:
* When the collections will be held
* Where the collections will be held
•
* Who is in charge of it, with phone number
• * who is participating - number of households in the
the population base
• * When the proposal is due
* Special conditions for the program - "because of the
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unique setting - it has -been determined that no
bulking can.occur on site." •-•
* Provide a checklist of documents that must be
returned to you with the bid - avoid having people
make assumptions. State "The following documents
must be included with the proposal
* List the evaluation criteria.
Lets fact it - one of the reasons we send out an RFP is to be
able to compare responses. The best way to get back comparable
proposals is to list the evaluation criteria:
Very simply: "The proposals will be evaluated on":
(Example)
1. Completeness
2. Evidence of Compliance and Liability
Protection
3. Prices
Also include: Time and date of Prebid Meeting, if any. List
any insurance Requirements you may have. Ask for evidence of
documentation of the workers training and experience. Ask for
a sample work plan for the type of program you are planning.
Don't give them one. This will give you some idea of their
ability in health, safety, site set up, etc... The exception
here is for a permanent program where you may have certain
documents already prepared. Ask for any wastes which will be
excluded. Ask for a description of liability protection or
what type of indemnification they will provide. Ask how the
waste will be tracked and handled after it leaves you site.
All of the above can be done in 3 pages for a one day program,
and 15-20 pages for a permanent program.
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Some Uncommon Elements:
Things
If you
a copy
people don't usually ask for but should:
have a contract that you are required to use, include:
for review and ask for any exceptions to be noted.
Include information about your budget, if possible.
Ask for details on the ultimate disposal of
each waste type.
State how long you expect this bid to be good for "Prices must
remain
in effect for "
Comparing Costs
The best way to get cost responses back so that they can be
easily
compared is to prepare a simple sheet on pricing in the
form of a simple chart for disposal costs -
This chart could
be laid out as follows:
tIST COLLECTION
Description of
Acceptable Waste
Example
1. oil Based
Paints
2. Acids/Based
3.
4.
5.
6.
7.
8.
Packaging 'size of Acutual Quantity
Method Container of Waste
Consolidation 55gal 50 gal
Labpacked 55gal 20 gal or
300 Ibs
Disposal Price Par
Method container
fuels $300.00
blending
Treatment $350.00
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For Labor, and Materials costs;
Again a simple Chart
Item
Unit
Cost
Description
per collection
day of per hour
Example Set-Up
Labor/Materials
Per Day
$2,500.00
All inclusive
This leaves some flexibility for the potential vendors to show you
some possibly better options.
Finally some tips or hints for a successful RFP...
1. proofread your RFP.
2. Keep it Simple.
Include a checklist of required forms.
Ask for feedback or an evaluation on the RFP from responders.
Allow approximately 2 weeks after a pre bid meeting for a one
day - 3 to 4 weeks after the prebid meeting for a permanent
program, for the response to be prepared.
Double check you mailing list to potential vendors. Follow up
that they received it.
Thank you.
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Site Selection
A. J. Novak
Project Development Manager
Chemical Waste Management, Inc.
Geneva, Illinois
How to select a. site for a one day household hazardous waste
collection. Below is a list of parameters, ail of which
should be reviewed and considered for the specific needs of'
your program.
1. Location
o Proximity to the population being served. (30% -
90% of participants will travel 8-10 miles)
o Recoqnizable to the population beina served.
2. Natural Attributes
o Size - Amole work area
Ability to queue traffic
o Cover - Protection from the elements usina pcie
barns or qaraqes as the work area.
Ability to set up .canopv tents to cover
the work area.
o Surface - Asphalt or concrete base preferred.
- Relatively level work area.
- Sewers should be away from the work area,
or diked.
3. Availability - If at all possible, no other activities
should be scheduled at the site which, can
conflict with the collection.
4. Liability - Review and understand the insurance
policies of the program sponsor,'the land
owner, and the contractor.
Safety
o
Adequate ventilation in work area, aspecialiv if
bulking.
Spill protection and fire prevention equipment
should "be on site.
Safety station should be on site with first aid
supplies.
A site contingency plan should be prepared prior to
the collection identifying emergency contact phone
numbers.
Permitting
o
Check with local regulators to identify if
permits are required.
any
Work with your contractor and local regulators to
understand if federal and/or state hazardous waste
identification numbers are required. (The process
of applying for USEPA or state hazardous waste
•identi'f ication numbers typically takes four weeks.)
Check with the site land owner to identify if the
above information exists, and if it can be used for
this program.
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II. How to select a site for a continuous household hazardous
waste collection.
All of the parameters considered for a one day collection
apply to a continuous collection program.
Mobility or Portability - Will your program be moved to
multiple sites throughout your community to provide
more/better service.
III
3. Storage - Will your community
collection and storage area.
have a centralized
o Types - Build a facility
- . Retro-fit an existing facility
Purchase a facility
o Capacity- Evaluate the size of the community being
serviced.
- Evaluate the frequency of . collections
versus the frequency of waste removals.
o Permitting - requirements for a HHW storage
facility may be different from those of a one
day collection. Check with .your local
regulators.
Examples of commonly used collection sites.
o School Parking Lots
o Community Event Centers
o Municipal Properties
Public Works garages
- Fire or Police Department parking lots
Local Airports
Fair Grounds or Parks
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o Local Business or Corporation Parking Lots
IV. Selecting a site for your Program.
l. Identify your needs and the program goals.
2.. Compromise. You may not find a site with all of the
attributes you desire. Based upon your needs, select a
site which best satisfies your requirements.
3. Plan site logistics specifically. Walk the site, mark
areas for delivered supplies, and clearly identify
traffic and work areas.•
4. Have Fun.
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HOUSEHOLD HAZARDOUS WASTE COLLECTION PROGRAM
PERMITTING AND PLAN APPROVAL
Sharon A. Rehder
New York State Department of Environmental Conservation
As of November, 1992, household hazardous waste (HHW)
collection day programs have been held in every state, and
permanent facilities have been sited in 24 states. The
tremendous growth in the popularity of these programs over the
past ten years has caused many state environmental regulatory
agencies to develop HHW regulatory programs or policies.
The federal government regulates waste under the Resource
Conservation and Recovery Act (RCRA). Hazardous waste is defined
and regulated under Subtitle c of RCRA, while solid waste is
regulated under Subtitle D. Subtitle C contains stringent
permitting.standards for hazardous waste treatment, storage, and
disposal facilities, but specifically exempts waste from
households from the definition of hazardous waste. All household
waste is regulated under Subtitle D, which does not specifically
address HHW. A few states classify collected HHW as a hazardous
waste and subject these wastes to many of the requirements
contained within Subtitle C.
The absence of federal requirements has left each individual
state to establish its own regulatory program, and these vary
widely. In many states, the regulatory programs are still
evolving, as the states develop laws, policies, guidelines, or
regulations in response to the activities of local collection
program sponsors. Some states that have had a number of
collection activities have firmly established regulations or
policies.
Most states now require some level of state regulatory
review. Permits are most often required for permanent
facilities. In those few states where HHW has been designated as
a hazardous waste, perma'nent facilities must meet stringent
hazardous waste permitting requirements. In other states, HHW is
a solid waste and solid waste permits are required. These solid
waste permits often contain conditions similar to those imposed
on hazardous waste storage facilities, but are often much easier
to obtain.
Typical permit applications contain a detailed description
of how the facility will be constructed, operated, and closed.
The typical contents of a permit application are given in Figure
1. The standard application form, which may only be one page
long, must be accompanied by site plans, maps, an operations
manual, and emergency contingency plans as attachments. These
materials are reviewed in detail. In New York, for example, it
often takes six months before the state deems the application to
be complete. .During this time, the application will probably
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undergo several rounds of changes. The final document will
contain an operations manual which must be followed once the
facility begins operation. When the application is complete, a
public notice must be sent out and a 30 day public comment period
is established. The state will then issue a construction permit
and will likely inspect the facility .before an operating permit
is issued. States may subsequently conduct yearly inspections.
Plans are often required for single day collection programs,
or for permanent facilities in states which do not require a
permit. Plans contain many of the same categories of information
that permit applications do, but are less formal and detailed,
and do not require the services of a professional engineer.
Plans are usually approved more quickly than permit applications.
If a state has permit-by-rule regulations, then a detailed
application does not need to be submitted. These states have
regulations which determine how the facility is to be constructed
and operated. The collection program sponsors must notify the
state that they are going to operate a facility, and that it will
be in compliance with all applicable regulations. The program is
then deemed to have a permit. Other states may issue variances
from permitting if the state has not yet revised its regulations
to accommodate HHW programs. Variances are often issued on a
case-by-case basis.
Several states that do not have regulations which require a
permit or plan to conduct a HHW collection program will require a
detailed plan as part of a funding application. By accepting or
rejecting the application for funding, the state has the
opportunity to review the plan and ensure the safety of the
programs. If the State environmental agency does not issue a
permit or approval of any kind, other agencies, such as the local
health department, may have HHW requirements. It is also
important that any applicable fire, electrical, and building
codes, OSHA regulations, and siting requirements be followed.
In the past, many states have been reluctant to allow HHW
program sponsors to accept hazardous waste from conditionally
exempt small quantity generators (CESQGs). It was not clear
whether the regulations would allow HHW and CESQG waste to be
mixed at a facility without triggering some Subtitle C
requirements. A July 22, 1992 memorandum from the United States
Environmental Protection Agency states that the two waste streams
may be mixed without incurring additional regulatory
requirements. Program sponsors should ask their state hazardous
waste program representatives if CESQG wastes may be accepted at
HHW programs. If these wastes are accepted, procedures need to
be in place to verify that the businesses which bring waste to
the facility are CESQGs.
The wide array of laws and regulations throughout the
country can make the establishment of a HHW collection program ,
very confusing. Many states are willing to meet with program
sponsors early in the planning phase to discuss specific
requirements. When planning a permanent facility, program
sponsors should also meet with local building and fire inspectors
to ensure that their plans are going to pass inspection and be
allowed to open.
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ITEMSCOMMONLY ADDRESSED IN A HOUSEHOLD HAZARDOUS WASTE
Figure T PERMANENT FACILITY PERMIT APPLICATION
Site plans and area maps, including engineering
drawings of:
• Site layout
• Waste management areas
• Property boundaries and adjacent land uses
• Utilities
Scope of program
What will be collected
Who may participate
Days and hours of operation
Registration procedures
Anticipated participation and quantities
Facility Design
• Layout of receiving, sorting, short term storage
areas
• Where on site will each waste type be collected,
handled, and stored
• Capacity of storage areas
• Building materials, use of impermeable surfaces
• Containment systems, including use of subfloorings
or berms
• Adequate aisle space for safe handling and
emergency response
Waste Management
Sorting/segregation procedures
Packaging methods
Materials which will be consolidated
On-site log or tracking forms
Ultimate disposition of materials: reuse,
recycling, treatment, or disposal
Any disposal facilities that will receive waste
Storage duration (many states limit to 90 days)
Transportation and manifesting procedures
USEPA ID number, if required
Procedures for unknowns
Health and Safety
Contingency plan
Location and listing of safety equipment
Fire suppression
Ventilation
Spill prevention and control
Personnel/Training
• List of job titles and tasks '
• Training received by each job title (many states
require 40 hours of OSHA training)
• Documentation of training
Other
Inspection logs and schedule
Site security
Closure plans
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NEGOTIATING THE CONTRACT
Elizabeth M. McCormick1
Virtually every type of household hazardous waste collection program requires the use of a
contractor to perform some service. Typically, a one day program asks a contractor to
unload cars, segregate and package waste, transport and dispose of collected wastes, and
provide supplies and services such as protective clothing, spill control equipment, and
contingency planning. A permanent program may only have the contractor transport and
dispose of collected wastes, or may ask for training and supplies as well. Regardless of the
type of program and extent of contractor participation, a program sponsor wants to obtain
the best available services at the most reasonable price. This generally means using the
competitive bidding process to evaluate possible contractors. The competitive bidding
process includes three main elements: a Request for Proposal (RFP) prepared by the
program sponsor, Proposals submitted by potential contractors, and the Contract negotiated
between the program sponsor and successful bidder.
The RFP and proposal are being covered by other speakers today. This paper will
concentrate on the key elements of contracts and provide a sample contract which could be
modified for different programs.
Program sponsors are often told to begin planning at least 6-9 months before their collection
program. This is also the time to begin working on the RFP and contractor selection
process. It may take a month or more to prepare the RFP, then at least two weeks
(preferably more, perhaps four to six weeks) for contractors to review the RFP and prepare
proposals, two weeks or moie for sponsors to review proposals, and another two weeks to
finalize the contract negotiations. Pre-bid conferences and RFP addenda may extend these
times. Some states such as California, Pennsylvania, and New York then review plans for
the program, including the contractor. Allow time for revisions at each step of the process.
Ideally the contractor selection should be complete and the contract signed several weeks
before the collection program. This allows the sponsor to work closely with the contractor
during the final, often hectic, days leading up to the collection.
Once the sponsor has an outline of their technical requirements, the local legal and
purchasing departments must be contacted. Many local governments have specific
requirements which must be included with all purchases. This may include equal
employment opportunity programs, bid and performance bonds, anti-apartheid policies,
insurance, public right-to-know, minority subcontracting, or other requirements. Legal and
purchasing departments may also be willing to perform some of the work associated with the
competitive bidding process, such as arranging pre-bid conferences or handling financial
arrangements. Occasionally a draft contract may be included in the RFP, or the sponsor
1 Manager, Household Hazardous Waste, Laidlaw Environmental Services Inc.
P.O. Box 210799, Columbia, South Carolina 29221; 800-845-1019 or 803-798-2993.
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may request that potential contractors submit their own contracts. Frequently the contract
is not addressed until a sponsor has reviewed proposals and made a preliminary contractor
selection. Any contract should be reviewed by the sponsor's legal counsel. Although most
programs go very smoothly, the contract forms the basis for conflict resolution if things
don't go well. It is a critical element of any HHW program.
A. IDENTIFICATION OF PARTIES
The agreement should identify the full legal name of each party to the contract. Most
contracts include two parties, the sponsor and the contractor. Some programs include
multiple groups as sponsors, for example when two or more municipalities pool their
resources to conduct a more extensive program than either could do alone. In such
cases, the sponsors could all be parties to the agreement, or they could prepare two
separate contracts - one an "intergovernmental agreement" between themselves
outlining cost allocations, responsibilities, and designating a single lead agency, and
one between the lead agency and the contractor. Both approaches have been used
successfully.
B. RECITATIONS
These are the "whereas" statements which describe why the parties are entering into
the agreement. They are usually brief and are sometimes omitted.
"WHEREAS the Sponsor desires to conduct a Household Hazardous Waste
Collection Program to provide a safe, convenient place where citizens of the
community can dispose of stored household hazardous wastes, and
WHEREAS the Sponsor desires to hire a professional contractor
knowledgeable and experienced in conducting such a waste disposal program,
and
WHEREAS the Contractor has represented that it is staffed with personnel
knowledgeable and experienced in conducting such a waste disposal
program."
SCOPE OF WORK
This section describes the work to be performed and the responsibilities of each party
in performing that work. To save space, the RFP and proposal are often
incorporated by reference, with the acknowledgement that the contract governs any
discrepancies between the RFP, proposal, and contract. ^
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D. TIME OF PERFORMANCE AND CONTRACT PERIOD
How long will the contract be in force? For a single collection, for multiple
collections, a year or rhore? Do you want the option of extending the contract by
mutual consent of the parties? This could be an advantage, allowing the sponsor to
work with a contractor for a period of time, then avoid the bidding process if
performance is satisfactory. At the same time, the sponsor is not locked into a long
term relationship with an unsatisfactory contractor.
E. TERMINATION
There may be reasons why either party wishes to terminate an agreement. For
example, a government agency may not be allocated funds for the program. This
section may either list specific causes for termination or provide a simple clause
allowing termination with no specific reason given. Termination without a specified
condition is called "for convenience" and the type which requires reasons is called
"for cause." For convenience is more common, because it is impossible to predict
in advance all the reasons which may cause a sponsor to wish to terminate the
agreement.
F. EXCUSE OF PERFORMANCE
This is also called a "force majeure" clause. The agreement may be suspended or
a scheduled date extended in the event of extenuating circumstances such as war, riot,
storms, etc. The paragraph may list many possible reasons, but should also include
a generic statement such as ".. .any other event beyond the reasonable control of such
party; which event prevents the delivery, transportation, acceptance, treatment,
incineration, or disposal of the waste."
G. PAYMENT
How will the sponsor pay for the program? When are invoices due, and will late
fees be assessed? How will invoice conflicts be resolved? What about unusual fees
or expenses which could not have been anticipated by either party prior to the
program? Many program sponsors have a fixed budget and choose to include "not
to exceed" language which requires the contractor to do periodic estimates of the
costs incurred during the program and to stop accepting waste when the fixed limit
is approached.
H. GENERATOR
Who will be the "generator" of the collected waste? Usually the sponsor acts as the
generator of record, but some states such as Massachusetts and Pennsylvania require
- the contractor to assume this role. Sponsors in other states may also prefer to have
the contractor's name on the manifests as generator. Program sponsors should
recognize that naming the contractor as generator does not automatically relieve the
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sponsor of potential Superfund liability. The sponsor should look to the
indemnification, insurance, and overall financial strength and qualifications of the
contractor for true liability protection.
I. LICENSES
. Most one day or mobile programs require few if any licenses and permits other than
a temporary generator ID and transporter permits. Permanent programs may have
more elaborate requirements - building permits, special use permits, fire district
approvals, etc. Who is responsible for these?
J. INSURANCE AND PERFORMANCE BOND
This section should describe the insurance agreed to by the sponsor and contractor,
including workers' compensation, general and automobile liability, and proof, of
environmental impairment liability for the disposal sites. Programs typically request
that workers' compensations be at that state's statutory limits, general liability for
bodily injury and property damage limits of $1,000,000 - 5,000,000, and automobile
liability for bodily injury and property damage limits of $1,000,000 - 5,000,000.
The federal Department of Transportation requires motor carriers transporting
hazardous materials to. carry an "MCS-90" endorsement of up to $5,000,000. This
endorsement includes environmental restoration coverage for accidents during
transportation. Hazardous waste treatment, storage, and disposal facilities must carry
environmental impairment liability insurance of $1,000,000 per occurrence,
$2,000,000 annual aggregate for sudden accidental occurrences, and facilities with
land contact such as landfills, lagoons,, or waste piles must also carry $3,000,000 per
occurrence, $6,000,000 annual aggregate for non-sudden events such as gradual
groundwater contamination. Be realistic in this section - asking for unusual or
excessive insurance coverages may limit the number of possible contractors who can
bid on a program.
A performance bond guarantees the performance of the project in accordance with
the contract, and provides a mechanism for the sponsor to recover funds if the
contractor fails to perform. Many programs do not require performance bonds. If
a bond is required, the amounts of bid and performance bonds may be determined by
local purchasing department policies. In any case, the amount should reflect the
amount of time, effort, and expense the sponsor may incur. The performance bond
may be set at the estimated cost of the collection program, but should not be set
much higher. Bond companies don't simply pay out the entire face value of the
bond, they pay for the sponsor's actual loss up to the face value. They also charge
a fee for the bond, based on a percentage of the face value. The percentage is
usually a reflection of the contractor's reputation and loss history. Contractors with
good performance records pay lower premiums than contractors with poor or average
records.. For these reasons, requesting a $250,000 performance bond for a $50,000
project simply wastes bond premium money while not providing the sponsor with any
additional protection.
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SAMPLE HOUSEHOLD HAZARDOUS WASTE COLLECTION AGREEMENT
This Agreement, dated this
day of
1992 by and between
(the Sponsor) and Laidlaw Environmental Services (TS), Inc., a Delaware
corporation, (LES), states as follows:
WHEREAS the Sponsor desires to conduct a Household Hazardous Waste Collection
Program to provide a safe, convenient place where citizens of can dispose of
stored household hazardous wastes, and
WHEREAS the Sponsor desires to hire a professional contractor knowledgeable and
experienced in conducting such a waste disposal program, and
WHEREAS LES has represented that it is staffed with personnel knowledgeable and
experienced in conducting such a waste disposal program.
WITNESSETH:
Now, therefore, in consideration of the mutual promises and benefits of this
Agreement, the Sponsor and LES agree as follows:
1. Employment of LES. The Sponsor agrees to hire LES and LES agrees to act
as the Sponsor's contractor to conduct the Household Hazardous Waste Collection Program
on ;, 1992.
2. Scope of Services. LES shall perform in a good and professional manner the
services identified in the Sponsor's Request for Proposal dated , 1992, as modified
by LES's Proposal dated , 1992, copies of which are attached hereto and
incorporated by Leference, as well as the services listed in this Agreement. Any conflict
between the terms of this Agreement and the terms of the Request for Proposal or the
Proposal will be governed by the terms of this Agreement.
a. LES shall have present at the collection site employees or agents of
LES as described in the Proposal trained in the identification of hazardous and acutely
hazardous wastes (collectively "Wastes") as defined by federal or (state) laws or regulations,
and such materials and equipment as are necessary to handle, containerize, label, load and
transport such Wastes from the Sponsor's service area in a manner conforming to (state) and
federal laws and regulations.
b. LES shall accept Wastes, for transportation and disposal from the
Sponsor service area, only from such individuals as are designated by a Sponsor
representative present at the site as being residents of the Sponsor service area, and only in
such amounts as are approved by such representative.
c. Except as provided in Paragraphs d and e below, LES disclaims all
responsibility for and assumes no liability for the following Wastes which it will neither
handle at the site nor accept for disposal-
Compressed Gas Cylinders, Explosives or Shock Sensitive Materials and
Ammunition, Unknown Materials, Radioactive Materials, Infectious or
Biologically Active Materials, Dioxin, Tri, Tetra- and Pentachlorophenols and
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K. TITLE TO WASTE
When, if ever, does tide to collected waste pass from program participant to sponsor
to contractor? Title basically describes who "owns" the waste and has the benefits
(and risks) of ownership, such as responsibility tor properly handling it. including
responding to spills, etc.
L. WARRANTY
What warranties or guarantees'are the panics providing? Typically the contractor
warrants or guarantees that they will perform correcdy. and the sponsor warrants that
they are legally able to enter into the agreement.
•VI. INDEMNIFICATION
This is one of the most important elements of the contract, and often one of the most
difficult to finalize. The indemnification language describes who will pay for what
if things go wrong, particularly if one parry comes to harm as a result of the other's
actions. Program sponsors occasionally try to distance themselves from any
responsibility for the program and ask that the contractor provide an indemnification
for anything which happens, even if it is caused by the sponsor's personnel. This
approach is seldom accepted by the contractor. More commonly, the panics agree
to allocate costs based upon the extent to which they contributed to the problem.
When the sponsor is a government agency, they must be sure to check applicable
state statutes, which may limit or describe the terms under which a state or local
government agency may indemnify the contractor. In these cases, the phrase 'to the
extent allowed by law" is inserted in the sponsor's portion of the indemnification.
N. MODIFICATION
The panics may wish to modify the agreement, for example to add additional sites
or change the scope of work. The agreement should include a mechanism tor doing
so.
O. NOTICES Where should invoices, reports, or other notices be sent?
P. GOVERNING LAW
The parties should agree that the contract will be governed by the laws of a particular
state, usually the state where the program occurs.
Q. MISCELLANEOUS
Contracts usually include clauses on whether or not the contractor may be considered
the sponsor's "agent": separation of clauses, so that'if one or more paragraphs is
ruled invalid the rest of the agreement will remain in effect; whether or not the
panics may assign their interests to others: non-discrimination clauses: and of course.
any specific local purchasing requirements such as anti-apartheid statements.
R. SIGNATURES
The agreement must be properly executed by authorized representatives of all parties.
Some government agencies may have specific formats for contract execution which
must-be followed. Usually enough copies of the agreement are prepared that each
party may have their own fully executed document with original signatures.
The enclosed sample agreement is for a one day household hazardous waste collection
agreement. It could easily be modified for use by other types of HHW program by changing
the scope of work, changing the time of performance to a contract period, and adding
additional licenses or permits if necessary.
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their Chlorophenoxy derivative Acids, Esters, Ethers, amine and other Salts
(i.e., Sodium Pentachlorophenate, 2,4,5-T, Silvex and 2,4,5-TP).
d. Dioxin associated wastes from households only will be handled by LES
through incineration and the Sponsor will compensate LES for packaging, transportation, and
disposal in accordance with the fee schedule.
e. If a citizen brings any Waste chemical listed in Paragraph c other than
those listed in Paragraph d to the collection station, and if the Sponsor decides to accept the
Waste, LES will package the material for the Sponsor and the Sponsor will compensate LES
for packaging services in accordance with the fee schedule in the Proposal. Further
management and disposal of such material shall be the sole responsibility of the Sponsor.
3. Time of Performance. LES shall begin the services to be performed under
this Agreement upon Notice to Proceed from the Sponsor, and shall undertake such services
to assure readiness for and successful completion of the Household Hazardous Waste
Collection Program.
4. Termination. Either party may terminate this Agreement upon sixty (60) days
prior written notice to the other, provided that such termination shall be without prejudice
to any other remedy the party may have. In the event of termination, any work in progress
will continue to completion unless specified otherwise in the notice of termination. The.
Sponsor shall pay for any such work in progress that is completed by LES and accepted by
the Sponsor.
5. Excuse of Performance. The Sponsor's obligation to deliver and LES's
obligation to accept for servicing any waste pursuant to this Agreement may be suspended
by either party in the event of: act of God, war, riot, fire, explosion, accident, flood,
sabotage; lack of adequate fuel, power, raw material, labor, containers, or transportation
facilities; compliance with governmental requests, laws, regulations, orders or actions;
revocation or modification of governmental permits or other required licenses or approvals;
breakage or failure of machinery or apparatus; national defense requirements or any other
event beyond the reasonable control of such party; labor trouble, strike, lockout or
injunction (provided that neither party shall be required to settle a labor dispute against its
own best judgment); which event prevents the delivery^ transportation, acceptance,
treatment, incineration, or disposal of the waste.
6. Compensation and Payment. The Sponsor agrees to pay LES for its services
in accordance with the price and terms of payment set forth in the attachments to this
Agreement. Payment terms are net 30 days from invoice. Interest will be charged at the
rate of 1.5% per month on all amounts outstanding more than 30 days. The interest will be
calculated on the number, of days in excess of 30 days past the invoice date to the date
payment is received at LES. The Sponsor is responsible for notifying LES of any questions
concerning an invoice. In addition, the Sponsor shall be responsible for collection agency
or legal fees incurred in collecting payment of an invoice. The Sponsor shall reimburse LES
for taxes, tariffs, fees, surcharges, or other charges imposed by legislation or regulations
enacted or promulgated after the execution date of this Agreement and levied specifically
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upon the transportation, treatment, storage, incineration or disposal of the waste upon thirty
(30) days written notice of such change in legislation and upon submission by LES of
evidence that such.charges have been levied or paid.
7. Generator. The Sponsor shall be deemed to be the "Generator", for
recordkeeping and paperwork purposes, of all Wastes accepted by LES during the Household
Hazardous Waste Program from residents of the Sponsor's service area.
8. Licenses. LES certifies, that on the day of collection, it will have:
a. Valid Environmental Protection Agency (" EPA") identificationnumbers
for transportation and storage of hazardous and acutely hazardous wastes; and
b. A valid (state) permit for transportation of hazardous wastes.
9. Insurance. LES shall procure and maintain, at its expense during the term of
this Agreement, at least the following insurance covering the services to be performed under
this Agreement: (a) Worker's Compensation - $1,000,000 or statutory; (b) Employer's
Liability - $5,000,000 per occurrence; (c) General Liability .(bodily injury and property
damage) - $5,000,000 per occurrence, $10,000,000 annual aggregate combined single limit;
(d) Automobile Liability - $5,000,00 per occurrence combined single limit; (e)
Environmental Impairment Liability for sudden accidental occurrences, for LES Service's
facility - $1,000,000 per occurrence, $2,000,000 annual aggregate; (f) MCS-90 Endorsement
for hazardous materials transportation - $5,000,000. At least 10 days before the first
collection day, LES shall provide the Sponsor with a Certificate of Insurance showing
coverages a, b, c and d above, naming the Sponsor as certificate holder and noting the
Sponsor's interest. LES shall also provide copies of documents demonstrating coverages e
and f above.
10. Title to Waste. Title to all identified Waste accepted bv LES at the site from
residents of the Sponsor's service area for transport and disposal by LES shall pass directly
from such residents to LES at the time of its acceptance.
11. Warranty. LES warrants that it understands the currently known hazards and
suspected hazards which are presented to persons, property and the environment by the
transportation, treatment and disposal of Wastes. LES further warrants that it will perform
all services under this Agreement in a safe, efficient, and lawful manner using industry-
accepted practices, and in full compliance with all applicable state and federal laws and
regulations. Sponsor warrants that it is in compliance with all applicable state and federal
laws governing its activities under this Agreement, and that it is under no legal restraint or
order which would prohibit transfer of possession or title of collected wastes to LES or
prohibit the servicing of such waste or LES's performance of services under this Agreement.
Sponsor will cooperate and/or assist LES, as requested, with its defense, negotiation,
adjustment and or settlement of a claim against Sponsor.
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12. Indemnification. I
a. LES shall indemnify, hold harmless and defend the Sponsor from and
against any and all liabilities, claims, penalties, fines, forfeitures, suits and the costs and •
expenses incident thereto (including cost of defense, settlement, and reasonable attorney's ^
fees) which may be alleged against the Sponsor or which the Sponsor may incur, become
responsible for, or pay out as a result of death or bodily injury to any person, destruction I
or damage to any property, contamination of or adverse effects on the environment, or any •
violation or alleged violation of governmental laws, regulations or orders, to the extent that
such damage was caused by LES's or LES's agents' negligent, willful or intentional act or .1
omission, breach of contract or a failure of LES's warranties to be true, accurate or ™
complete.
b. To the extent allowed by law, the Sponsor shall indemnify, hold •
harmless and defend LES from and against any and all liabilities, claims, penalties, fines,
forfeitures, suits and the costs and expenses incident thereto (including cost of defense, _
settlement, and reasonable attorney's fees) which may be alleged against LES or which LES I
may incur, become responsible for, or pay out as a result of death or bodily injury to any
person, destruction or damage to any property, contamination of or adverse effects on the _
environment, or any violation or alleged • violation of governmental laws, regulations or I
orders, to the extent that such damage was caused by the Sponsor's or the Sponsor's agents'
negligent, willful or intentional act or omission, breach of contract or a failure of the m
Sponsor's warranties to be true, accurate or complete. , I
13. Independent Contractor. LES is and shall perform this agreement as an
independent contractor and, as such, shall have and maintain complete control over all of its
employees and operations. Neither LES nor anyone employed by it shall be, represent, act,
purport to act, or be deemed to be the agent, representative, employee or servant of the
Sponsor.
I
14. Modification. No modification of this Agreement shall be binding on LES or •
the Sponsor unless set out in writing signed by both parties, except however that the Price •
List may be modified by LES providing thirty (30) days written notice to the Sponsor.
15. Headings. The titles of the paragraphs of this Agreement are inserted for •
convenience of reference only and shall be disregarded in construing or interpreting the
provisions of this Agreement. - I
16. Completeness of Agreement. This Agreement and any documents incorporated
by reference herein contain all the terms and conditions agreed to by the Sponsor and LES, •
and no other agreements, oral or otherwise, regarding the subject matter of this Agreement *
or any pan thereof shall have any'validity or bind any of the parties hereto.
17. When Rights and Remedies Not Waived. In no event shall the making by the
Sponsor of any payment to LES constitute or be construed as a waiver by the Sponsor of any _
breach of covenant, or any default which may then exist, on the part of LES, and the making I
of any such payment by the Sponsor while any such breach or default exist shall in no way
impair or prejudice any right or remedy available to the Sponsor with respect to such breach _
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or default. Any waiver by either party of any provision or condition of this Agreement shall
not be construed or decreed to be a waiver of any other provision or condition of this
Agreement, nor a waiver of a subsequent breach of the same provision or condition, unless
such waiver be expressed in writing by the party to be bound.
18. Personnel. LES represents that it has, or will secure at its own expense, all
personnel required in performing the services under this Agreement. LES is and shall
perform this agreement as an independent contractor, and as such, shall have and maintain
complete control over all its employees and operation.
19. Non-Discrimination Provision. During the performance of this Agreement,
LES agrees as follows: • .. •
a. LES will not discriminate against any employee or applicant for
employment because of race, religion, color, sex or national origin, except where religion,
sex or national origin is a bona fide occupational qualification reasonably necessary to the
normal operation of LES. LES agrees to post in conspicuous places, available to employees
and applicants for employment, notices setting forth the provisions of the nondiscrimination
clause.
b. LES, in all solicitations or advertisements for employees placed by or
on behalf of LES, will state that LES is an equal opportunity employer.
c. Notices, advertisements and solicitations placed in accordance with
federal law, rule or regulation shall be deemed sufficient for the purpose of meeting the
requirements of this section.
20. Notices. Any notices, bills, invoices or reports required by this Agreement
shall be sufficient if sent by the parties in the United States mail, postage paid, to the address
noted below:
If to the Sponsor:
If to LES: Laidlaw Environmental Services Inc.
Sponsor shall give written notice to LES of a claim for indemnification under paragraph 12
of this Agreement within fifteen (15) days following Sponsor's first knowledge of the event
or occurrence which gives rise to that claim. Upon receipt of notice, and determination by
LES that Sponsor hss a valid claim for indemnification, LES shall have the right to retain
counsel to defend, negotiate, adjust, and/or settle a claim against Sponsor and LES will pay
reasonable attorney's fees and other litigation expenses. LES has no obligation to indemnify
Sponsor when Sponsor does not provide timely notice of a claim allowing LES the timely
opportunity to defend, negotiate, adjust, and/or settle the claim.
21. Governing Law. The Sponsor and LES agree that the validity and
construction of this Agreement shall be governed by the laws of (state), except where
preempted by federal law.
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22. Assignment. The Sponsor and LES bind themselves and any" successors and •
assigns to this Agreement. LES shall not assign, sublet, or transfer its interest in this
Agreement without written consent of the Sponsor, Nothing herein shall be construed as •
creating any personal liability on the part of any officer or agent of the Sponsor, nor shall •
it be construed as giving any rights or benefits hereunder to anyone other than the Sponsor
and LES. •
23. Patent Infringement Disclaimer. LES disclaims any and all liability for past,
present or future patent infringement relating to any apparatus, process, design, product, -I
composition or structure which is made, constructed, used, sold, practiced or supplied by ™
LES for the purpose of fulfilling the terms of this Agreement. LES does not represent and
expressly does not warrant that any apparatus, process, design, product, composition, or •
structure which is made, constructed, used, sold, practiced or supplied by LES does not
infringe any issued or future United States or foreign patent. Sponsor may not seek _
indemnification from LES for any damages, attorneys fees or costs as a result of a claim of •
patent infringement brought against it relating to any apparatus, process, design, product,
composition or structure which was made, constructed, used, sold, practiced or supplied by _
LES. . |
IN WITNESS WHEREOF, • , and LES have executed this Agreement as •
of the date first written above. |
SPONSOR •
BY:__ I
TITLE:
I
LAIDLAW ENVIRONMENTAL SERVICES (TS), INC
BY:
TITLE:
Corporate Seal:
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1992 UPDATE FOR STATE AGRICULTURAL PESTICIDE COLLECTIONS
Charles P. Cubbage, Agriculture Environmental Coordinator
Michigan Department of Agriculture
October 16, 1992 V__x
ALABAMA
Dr. Bloch, Pesticide Division (205) 242-2656
Update/Fall 1992 As of this time, Alabama has not conducted any collections of unusable pesticides.
They have asked for funding from legislature for a 1993-94 collectioa Are also working with Soil
Conservation Service which has federal funds that may become available for collection of farm pesticides.
Has a very successful and active pesticide container collection program
ALASKA
Ms. Rose Lombard!, Department of Environmental Health (907) 745-3236
Update/Fall 1992 Pesticide collections are held in many of the larger communities, usually once a month.
Collections will take household waste and farm pesticides. Pesticides are collected and stored at an
approved facility. They are then transported to the lower states for disposal. Funded by the legislature.
ARIZONA
Sheila Burgan, Department of Environmental Services (602) 542-3579
Update/Fall 1992 In 1990, Arizona worked with Ciba-Geigy Corp. to set up pick up points for return
of recalled pesticides back to the manufacturer. No other pesticide collections are anticipated at this time.
ARKANSAS
Charles Flowers, Department of Agriculture (501) 225-1898
Update/Fall 1992 The state of Arkansas will conduct their first farm pesticide collection in December
1992. Federal, state, and private industry are working together to make this collection successful. It will
encompass one county that engages in many different types of fanning. Funding of $150,000-185,000
has been set aside for the collection. Registrations forms have been sent out to potential participants. The
collection is for one day, 7:00 AM to 5:00 PM, with no scheduling. Chemical Waste Management will
be the waste hauler.
CALIFORNIA
Rich Loder, Department of Pesticide Regulation (916) 654-0606
Update/Fall 1992 The state of California does not have a program for collecting farm pesticides. Many
of the counties and cities have annual and monthly collections for household waste and small amounts of
farm pesticides. Some high agricultural counties have annual farm pesticide collections which have been
very successful. Also, many agricultural counties are starting to get into recycling of pesticide containers.
Programs are funded by county and city funds.
COLORADO
Agus Campbell, Department of Health/Hazardous Waste Division (303) 692-3320
Update/Fall 1992 Several counties have household hazardous waste collections. They do not accept farm
pesticides, only household-type pesticides. No state pesticide collection programs are planned at this time.
CONNECTICUT
Brad Robinson, Department of Environmental Regulations (203) 566-5148
Update/Fall 1992 Due to budget restraints, funding not available. Last pesticide collection June 1990.
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DELAWARE
Grier Stayton, Department of Agriculture (302) 739-4811
Update/Fall 1992 The state of Delaware conducted a household hazardous waste collection in two
counties in 1992. This collection was open to farmers with no limitation on types or amounts of pesticides
accepted. A total of 30,423 Ibs. of pesticides were collected for disposal. Contractor signed the manifest
for waste. Funding provided by landfill "tipping fees" collected at disposal sites. No fund is available
for future collections at this time.
FLORIDA
Greg Lee, Department of Environmental Regulation (904) 488-0190
Update/Fall 1992 The state of Florida has 23 counties that have an on-going household hazardous waste
collection, with only small amounts of farm pesticides eligible. The legislature has approved a grant for
a pilot program for a farm pesticide collection in three counties in late fall of 1993. They hope to get
permanent funding for future programs.
GEORGIA
Lora Schroeder, Department of Agriculture/Entomology and Pesticide Division
(404) 656^*958
Update/Fall 1992 The state of Georgia does not have a farm pesticide collection program. However,
they are starting to recycle pesticide containers.
HAWAII
Robert Boesch, Department of Pesticide Regulation (808) 973-9401
Update/Fall 1992 The state of Hawaii has not had any farm pesticide coDections since 1987. This year
a collection of several hundred pounds of pesticides damaged during the hurricane were collected for
disposal. They do have household hazardous waste collections, but will not take pesticides from
commercial farms. At this time, they have no. plans for future farm pesticide collections.
IDAHO
Bob Hayes, Department of Agriculture (208) 334-3243
Update/Fall 1992 As of October, the state of Idaho has issued a request for quotations from contractors
and are planning an April 1, 1993 farm pesticide collection. State and local government and private
industry are cooperating in the project. Funding level had not yet been established. The collection
process will include a pre-registration requirement listing types and amounts of pesticides for disposal.
ILLINOIS
Dana Weatherby, Department of Agriculture/Division of Natural Resources
(217)7858-2427 Update/Fall 1992
The state of Illinois had two collections in 1990-91 by the Department of Agriculture, Division of Natural
Resources. No charge to participants. Most of the pesticides were banned or old and unusable. The state
signed the manifest for aU pesticides collected. Approximately 14,000 Ibs. of pesticides were collected
for disposal. There will be a meeting with Farmers Home Administration for possible grant funding for
a collection in 1993.
INDIANA
Ann Piechota, (317) 494-9545, Purdue University, Agricultural Point Source Prevention Program and Dave
Scott or Kevin Neal, Indiana State Chemists Office
Update/Fail 1992 The state of Indiana has participated in the Lake Michigan Clean Sweep program
funded by EPA as part of the Lakes Management Plant (LaMP) program for Great Lakes protection. The
$20,000 collection netted 4,300 Ibs. (combined liquid and solid) from two counties with 35 participants.
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Costs ran $5.00/lb. A number of factors kept the participation lower than expected; however, carryover
of funds ($30,000) will allow a repeat collection in 1993. A fall survey is planned. Previously
unreported, 1990 Allen and DeKalb County collections served 62 participants and netted 3,800 Ibs. and
560 gallons, also taking in waste oil. .The city of Indianapolis has a household hazardous waste collection
which will accept small amounts of pesticides.
IOWA
Scott Cahall, Department of Natural Resources (515) 281-8263
Update/Fall 1992 In 1992, the state of Iowa conducted 20 household/farm pesticide collections
throughout the state. Approximately 9,000 people participated, collecting 203,152 Ibs. of toxic waste (over
100,000 Ibs. in farm pesticides). One grower brought in 5,000 Ibs. of DDT for disposal. Also, they were
informed that one participant had buried 2-50 gallon drums of DDT, dug them up and brought them to
a collection site for proper disposal. The waste hauler was the generator and there was no manifesting
by growers.
KANSAS
Gary Bontz, Department of Agriculture (913) 296-2142
Update/Fall 1992 The state of Kansas has received an EPA grant for the collection of farm pesticide
waste. The collection will be conducted in four counties in May of 1993. The state is working with local
government to facilitate die collections. Participants must register to participate, listing types and amounts
of pesticides for disposal. Collection will be held at designated local hazardous waste facilities in each
county. Funding for future programs is being pursued through state government at this time.
KENTUCKY
Ron Egnew, Director, Pesticide Division (502) 564-7274
Update/Fall 1992 The state of Kentucky has passed a law providing for agricultural chemical collections,
however, no funding is associated with the act With assistance from TVA and EPA, a 1991 pilot project
in two counties collected 42,395 gallons of unwanted farm pesticides from 80 farmers. A group of
fanners and business people formed a corporation and signed as the generator. Post collection reaction
is that the corporation formation is not the best way to approach generator status.
LOUISIANA
Larry LeJeune, Department of Agriculture and Forestry (504) 925-3789
Update/Fall 1992 In 1990, the state conducted a widespread pilot project collecting several tons of
unusable pesticides, such as DDT, lead arsenate, dinoseb, chlordane and aldrin. The state served as the
generator and signed the manifest. No manifesting was required by participants. Participants filled out
a collection request form indicating amounts and types of products for disposal. Participants were
assigned time of arrival for disposal at the site.
MAINE
Henry Jennings, Pesticide Control Division (207) 289-2731
Update/Fall 1992 The state of Maine funded a pick up for the removal of dinoseb and 2.45T. Products
were collected by the state and transported to Tennessee and Texas. A total of 2,100 gallons of Dinoseb
and 420 gallons of 2.45T was shipped to EPA storage facilities. They are working with private industry
and federal government hoping for a farm pesticide collection in 1993.
MARYLAND
Dennis Howard, Department of Agriculture, Pesticide Registration (410) 841-5700
Update/Fall 1992 The state of Maryland has increased their chemical product registration fees.
Hopefully, in the future some of the fee increase monies will be used for pesticide collections.
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MASSACHUSETTS |
Tara Zadeh, Department of Environmental Regulations (617) 727-3020
Update/Fall 1992 The state of Massachusetts has not planned any future collections. Ms. Zadeh stated •
there has been no indication that the need for a future collection is warranted. Also, a large part of the |
collection in 1990 was educating farmers on purchasing, use, and storage. All farmers that participated
in the 1990 collection were required to attend a pesticide educational training seminar for which they also «
received pesticide certification credits. •
MICHIGAN -
Charles Cubbage, Department of Agriculture (517)373-9744 I
Update/Fall 1992 The Department of Agriculture participated with EPA in the Lake Michigan "Clean m
Sweep" program as part of EPA's LaMP program for the Great Lakes. The $223,000 program at 8
collection sites served 23 counties and collected 37 tons of unusable pesticides from 330 participants. •,
EPA funding helped to leverage cooperative but separately funded county and commodity group ™
collections. Disposal costs ran $173,000. EPA/MDA funding of $140,000 was used in grants to county
or regional cooperative extension service or health department offices. In-kind services amounted to I
$50,000 with cash match of $33,000 "from county, commodity groups, and private cash donations. Pre- •
registration assured safe delivery and cost control. Paperwork was simplified by EPA's revised process
for assigning collection site ID numbers and MDA assuming generator status. •
MINNESOTA
Larry Palmer, Department of Agriculture (612) 297-7082 •
Update/Fall 1992 The state of Minnesota is conducting on-going farm pesticide collections. Funding |
has been made available through product registration fees. In 1991-92, they collected approximately
120,000 Ibs. of unusable pesticides; over 50% was cancelled or banned products. All participants were •
required to fill out registration forms prior to collection day. Participants are allowed to bring in only •
products and amounts that have been agreed to on the pre-registration form. All participants must sign
a disclosure form at the time of collection. Department of Agriculture signs the manifest. .
MISSISSIPPI ™
Robert McCarty, Department of Agriculture (601) 325-3390
Update/Fall 1992 The state of Mississippi is working on a statewide collection program. They will be •
having a pilot program in 1993 which will encompass two counties. Survey forms have been sent out to '
farmers and retailers and will be returned to the cooperative extension service for processing. This is a
joint effort of federal, state, and private agencies. •
MISSOURI
June Sullens, Department of Natural Resources (314)751-3176 fl
Update/Fall 1992 The state of Missouri lost their funding for the 1991 farm pesticide collection project. •
They are still trying to get funds from the legislature for future collections. Some local communities have
household collections and will take small amounts of farm pesticides. B
MONTANA
Dale Rubrite, Dept. of Agriculture (406)444-0510 George Algard,DepL of Agriculture (406)444-5423 •
Update/Fall 1992 In 1992, the state of Montana conducted a statewide survey of commercial and private •
farms to assess the amounts and types of products that would be offered for disposal. The response was
very poor, less than 1%. Mr. Algard felt there were many farmers who did not want to identify •
themselves as having banned or cancelled products, feeling that enforcement action may be taken against g
them. The department has asked the legislature for funding and would like to conduct a collection in the
near future. Mr. Algard feels there are products that need to be collected for properly disposal. •
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NEBRASKA
Rich Reiman, Department of Agriculture (402).471-2394
Update/Fall 1992 In 1991 and 1992, the state of Nebraska conducted a recycling program for plastic pes-
ticide containers from faims and aerial applicators. This program has been very successful. Concept of
a pesticide collection of hazardous materials has been discussed but have not been able to obtain funding.
NEVADA
Chuck Moses, Department of Agriculture (702) 688-1180
Update/Fall 1992 Nevada has not conducted any farm pesticide collections. They have worked with some
farmers, helping them find uses for registered pesticides they are no longer able to use. Clark County has
two household collections each year and has been taking small amounts of farm pesticides. Mr. Moses
stated they are trying to get an increase in product registration fees that will help fund a statewide farm
pesticide collection. They are hoping for a collection in 1994.
NEW HAMPSHIRE
Kathy Schmitt, Department of Environmental Regulations (603) 271-3550
Update/Fall 1992 New Hampshire's Waste Management Department has set up several household
hazardous waste collections. These sites will take small amounts of farm pesticides but are not set up for
any large quantities. There is a need for a farm pesticide collection but funding is not available.
NEW JERSEY
Ralph Smith, Environmental Protection Division (609) 530-4134
Update/Fall 1992 All collections of hazardous waste (pesticides, etc.) are done by individual counties.
Most counties have on-going collections, usually two per year. Collections are funded by county taxes.
All people residing in the county can participate but there is a limitation on amounts per participant.
Commercial businesses are excluded from participating. Mr. Smith feels the counties are doing a good
job of removing hazardous waste from homeowners and farmers for proper disposal.
NEW MEXICO
Connie Matthews, Division of Pesticide Management (505) 646-2133
Update/Fall 1992 The state of New Mexico feels there is a need for a farm pesticide collection but
funding has not been available.
NEW YORK
Frank Hegener, Pesticide Division (518) 457-2087
Update/Fall 1992 There is currently a Pesticide Association of New York made up of industry and pesti-
cide users that is in the planning stages of setting up a farm hazardous waste collection possibly in 1994.
NORTH CAROLINA
William McClellan, Pesticide Division (919) 733-7366
Update/Fall 1992 North Carolina has been collecting unusable or banned pesticides for over ten years.
Their program is unique from other states. Pesticides are picked up by state inspectors and transported
to an approved storage facility. Approximately twice per year, contracts are made with waste haulers for
pick up. State is the generator and signs the manifest.
NORTH DAKOTA
Ted Keller and Jack Peterson, Department of Agriculture (701) 224-4756
Update/Fall 1992 The state of North Dakota had three farm pesticide collections in 1992. Most of the
products were banned, cancelled or unusable pesticides. 386 people participated and over 80,000 Ibs. of
pesticides were removed from the environment for proper disposal. Each participant filled out a transfer
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form signing the pesticide over to the State of North Dakota. The state declared it to be a hazardous
waste and became the generator, signing the manifest. There was no reluctance on the fanner's part to
sign the transfer forms. The cost of the collections were $400,000. Average cost was approximately •
SS.OO/lb. Funding for the project came from product registration fees. Mr. Peterson stated it was such •
a positive program he would expect it to be continued as long as heeded.
OHIO I
Larry Burger, Department of Agriculture (614) 866-6361
Update/Fall 1992 The state of Ohio will be conducting their first farm pesticide collection which will
encompass two counties. Survey and registration forms have been sent out and returned for review. The •
total funding for the collection is $100,000 which was funded by pesticide fees (product registration, *
licenses, etc.). Fanners will be scheduled to bring their products to a designated site. The department will
be the generator and sign the manifest. Chemical Waste Management will be the contractor and has •
proposed a bid $6.00/lb. for product disposed of by for incineration, and $2.30/lb. for products disposed •
of in landfills. Collection will be conducted in January 1993.
OKLAHOMA I
Kevin Holly, Department of Agriculture (405) 521-3864
Update/Fall 1992 The state of Oklahoma held several meetings and agreed on the need for a collection, •
but no funding is available at this time. Q
OREGON •
Rick Voilpo, Department of Environmental Quality (503) 229-6590 |
Update/Fall 1992 The state of Oregon had their first collection in 1992. They collected 20,000 Ibs. of
banned or unusable pesticides from 43 participants. Many of the products were very old, such as lead M
arsenate and DDT. Growers pre-registered with county extension offices, listed amounts and types of I
pesticides for disposal. No cost to participants and the state signed the manifest Funding was provided
from tipping fees collected at solid waste sites. First collection was very well received. Hoping to have —
another in 1993. Also, the state has an on-going plastic and metal pesticide container recycling project •
that has been very successful. *
PENNSYLVANIA •
Dave Bingaman, Department of Agriculture (717) 787-4843 . *
Update/Fall 1992 The state of Pennsylvania will be conducting their first collection in late fall of 1992.
They will be collecting farm pesticides from 6 .counties in 1992 and 8 counties in 1993. They informed I
the farm community through news bulletins, flyers, and meetings. Their contract is set up so that ™
pesticides will be picked up at the farms by the waste hauler. The hauler will be the generator and sign
the manifest. State inspectors have visited all farms and identified all pesticide waste and total amounts.
The cost of the 1992 pick up will be $125,000-$150,000. Cost is approximately $4.50-$5.00/lb. The
pesticide collection is funded through product registration fees with no charge to participants.
RHODE ISLAND
Liz Duquay, Department of Environmental Regulations (401) 277-2781
Update/Fall 1992 Due to budget restraints, funding for pesticide collections have been cut.
SOUTH CAROLINA
Bob Bellenger, Department of Entomology (803) 656-5042
Update/Fall 1992 The state of South Carolina sent out surveys to several high agricultural counties to
determine the amount, type of products, and condition of containers of pesticide waste that farmers are
holding for disposal. They did not ask growers to identify themselves and the response was excellent -
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75% returned. They realize the need for a collection and hope to have their first in 1993.
SOUTH DAKOTA
Department of Agriculture (605) 773-3724
Update/Fall 1992 The state of South Dakota has acquired funding through product registration fees for
a collection in 1993. They have sent out surveys to determine types and quantities of pesticides in need
of disposal. Hopefully, from the survey they will be able to determine what groups should be involved
in the program — should it be confined to farmers only or to include dealers and homeowners. They know
there is a need for a collection and the survey should be very helpful in planning the collection.
TENNESSEE
Nox Writhe, Department of Agriculture (615) 360-0130
Update/Fall 1992 The state of Tennessee is in the planning stages for a farm pesticide collection for mid
summer of 1993. Funding has been made available through product registration fees.
TEXAS
D. Wilcox, Water Commission (512) 463-8535
Leslie Smith, Department of Agriculture (512) 425-1620
Update/Fall 1992 The state of Texas has 4 collection encompassing 32 counties. Collection was for
private applicators within the counties. Approximately 150 farms participated and approximately 97 tons
of pesticides were collected. Sites were set up as a one-day collection from 8:00 to 3:00. No registration
was required, first come/first served. (This method was used because farmers would not register as having
banned pesticides for fear of having enforcement action taken against them.) Dow Chemical will do some
of the disposal at no cost to the state. No charge to participants and the state signed the manifest for
disposal. They are planning to have collection in 1993. Funding provided by state legislature.
UTAH
Mark Quilter, Department of Agriculture (801) 538-7123
Update/Fall 1992 Surveys have been sent out and the state of Utah is planning a farm pesticide
collection in the spring of 1993.
VERMONT
Allen Kamatz, Department of Agriculture (802)828-2431
Update/Fall 1992 The state of Vermont has finalized an agreement by committee to increase product
registration fees to support and conduct a farm pesticide and household collection. Product registration
fees will generate $90,000-$100,000 per year to support a four year program to educate and collect
pesticides from users. Sites will be set up throughout the state. Applicants will be required to register
to participate with no charge to the participants. Contractor will be the generator.
VIRGINIA
Dan Schweitzer, Department of Agriculture (804) 786-3798
Update/Fall 1992 In 1992, Virginia conducted their second farm pesticide collection encompassing 5
counties. A total of 191 farmers participated and 57,000 Ibs. of pesticide waste was collected. Most of
the products were cancelled or banned pesticides, such as DDT, chlordane, and dieldrih.
WASHINGTON
Joe Hoffman, Department of Agriculture, Pesticide Division (206) 902-2047
Update/Fall 1992 The state of Washington has been conducting farm pesticide collections since 1988.
They have on-going collections each year. In 1992, they conducted five regional collections encompassing
12 counties. A total of 80,784 Ibs. of pesticide waste was collected from 277 participants. All participants
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must pre-register, listing types and amounts of pesticides- for disposal. The chemicals are not declared a
hazardous waste until the participants sign a release form at the site. At this time, the state takes
possession of the chemicals and is the generator and signs the manifest Since the state started collecting
pesticides in 1988, they have had 17 regional collections covering approximately one-half of the state,
collecting 150.8 tons of pesticide waste from 962 participants for disposal. Funding for next year will be
approximately $450,000 generated from a sales tax (.7%) on wholesale dealers of hazardous waste
chemicals. We should all be so lucky!
WEST VIRGINIA
Robert Frame, Department of Agriculture (304) 348-2209
Update/Fail 1992 The state of West Virginia has not conducted any farm pesticide collections due to
budget cutbacks in the department They are looking at EPA grants or increasing product registration fees
to fund future farm pesticide collections.
WISCONSIN
Dave Frederickson, Department of Agriculture (606) 267-4509
Update/Fall 1992 In the fall of 1990, the State of Wisconsin had collections in 3 counties, collecting
39,000 Ibs. of unusable farm pesticides from 270 participants for proper disposal. In 1990, due to lack
of funds, many farmers could not participate. Approximately 2,400 Ibs. of waste could not be collected
for disposal. This year, the state is participating with EPA in the Lake Michigan "Clean Sweep" program
as part of EPA "s LaMP program for the Great Lakes. Wisconsin's EPA share is $90,000. The legislature
approved a new annual appropriation of $500,000 for a permanent program capable of serving 12-20
counties per year - impressive! There will be 2 collections this fall with 13 planned for the spring and
8 more in the fall of 1993.
WYOMING
Tim Link, Department of Waste Management (307) 777-7752
Update/Fall 1992 Conducted a rural pesticide collection program in Wyoming County this year. Some
counties have sponsored household hazardous waste collections and local ranchers have disposed of some
banned pesticides at these locations. Farmers will be required to fill out survey forms and will be taken
by appointment only. The state will take on the responsibility of generator and sign the manifests.
U.S. AGRICULTURAL PESTICIDE COLLECTIONS
MASS.
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U.S. Agricultural Pesticide Collection Programs
1992 Status
STATE
STATUS
GENERATOR NOTES
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
FLORIDA
GEORGIA
HAWAH
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS .
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
None
Ongoing
None
92Dec
Ongoing
None
90
92 .
Ongoing
None
87
93 Planning
90-91
92
92
93
91
91
88/90
None
90
88/90-93
91-93
93
90/HHW
86
None
None
90/HHW
Ongoing
County
94 Planning
74-92
88-92
93
None
92
. 92-93
90-91
93 Planning
93 Planning
93 Planning
90/92
93 Planning
91-93
92
88-93
None
90/92-93
92
City
State
County
Contractor
County
State
State
Contractor
Non Profit Corp
State
State/Participant
County/State
State
State
State
State
Contractor
Contractor
State
State
State
State
Need$
• -Need$
NeedS
Need$
Want one
Need$
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U.S. EPA'S NATIONAL HOME AND GARDEN PESTICIDE USE SURVEY
(Tracy Bone for) Ed Brandt
Office of Pesticide Programs
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EPA's Office of Pesticide Programs identified a need for use
and safety data on home and garden pesticides to support the •
reregistration of these products. The National Home and Garden P
Pesticide-Use Survey is a one-time, cross-sectional survey of the
use of pesticides.in a and around homes in the United States. •
The study was designed as a national, probability-based sample of |
households with interviews conducted in person at the residence.
Interviewers visited 2,078 residences from a total of 29 _
different states. ' •
A few of the survey results are summarized below:
90 % of single family residences have at least one pesticide •
product in storage as do 70 % of multi-family residences;
22 % had more than five products in storage; •
15 - 30 % of the pesticide products had last been used over
a year ago; •
75 % of households without children under the age of 5 had
pesticides insecurely stored (not locked or within reach of •
children), and 47 % of households with children under the p
age of 5 stored pesticides insecurely;
10 % of households disposed of leftover pesticides and only
2 to 3 % of them used a HHWCP as the method of disposal;
6 % of all households had pesticides in storage that they
.did not know how to dispose of safely;
Many households have products in storage that have been
cancelled by EPA (l million households with chlordane;
150,000 with DDT; 70,000 with heptachlor and 85,000 with
silvex).
For a copy of this report and/or executive summary call (703)308-
8111 or call NTIS (800)553-6847.
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THE MINNESOTA WASTE PESTICIDE COLLECTION PROGRAM
PROGRAM SUMMARY - DECEMBER 1, 1992
Lany Palmer and Joseph Spitzmueller
Minnesota Department of Agriculture - Agronomy Services Division
Waste Pesticide and Container Disposal Unit
90 West Plato Blvd. - St. Paul, Minnesota 55107-2094
Telephone (612) 297-7102
ISSUE. An estimated 3.5 million pounds of waste pesticides are currently stored in
Minnesota. The occurance of unusable or waste pesticide is not peculiar to any
county or region. Waste pesticides commonly accumulate on farms and at businesses
using pesticides. Since the Waste Pesticide Collection Program began operating in
1990, thousands of pesticide end users have disposed of waste pesticide, are awaiting
an opportunity to dispose of waste pesticides, or have contacted the Minnesota
Department of Agriculture about disposal options. In a survey taken in 1988, 29%
of Minnesota fanners indicated they store old and deteriorated pesticides.
WASTE PESTICIDES. Fungicides, insecticides, herbicides and other pesticides
become waste in a variety of manners. The physical nature of a product may change
in storage. Government or industry may cancel or ban a product's use. These
actions render a pesticide unusable and generate waste pesticide.
INTRODUCTION. Minnesota Department of Agriculture's (MDA) Waste Pesticide
Collection Program began operation in July 1990. Authorized by the Comprehensive
Ground Water Act of 1989, its goal is to rid Minnesota of waste pesticides.
Approximately one-half of the pesticides collected are banned and canceled
pesticides, the remainder are unusable. The 115,000 pounds of waste pesticides
collected to date have been destroyed at a hazardous waste incinerator at a disposal
cost of $560,062. Funding is derived from pesticide registration fees collected by the
MDA. The MDA program is designed for farmers and businesses using pesticides.
More than 1,000 pesticide users from throughout Minnesota have voluntarily
participated in this program.
OBJECTIVES. The objectives of the waste pesticide collection program are to:
» raise awareness of the amount of waste pesticides stored in the state;
+ increase understanding of problems related to pesticide storage and disposal;
* provide a safe and affordable means for disposing of waste pesticides; and
* reduce or eliminate waste pesticide accumulation in the future.
LEGISLATION AND REGULATION. Although few pesticides have hazardous
waste characteristics or are listed wastes, the inherent hazards associated with
pesticides dictate hazardous waste disposal procedures. Hazardous waste disposal
is complex. Hazardous waste generators must obtain an identification number and
comply with hazardous waste transporter regulations. Hazardous waste disposal is
also very expensive. The cost of disposal often far exceeds the original cost of the
pesticide.
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The complexities and high cost of hazardous waste disposal are barriers to proper
disposal. Many pesticide users do not understand hazardous waste regulations,
cannot afford proper disposal, and therefore do not comply. .Alternatives for •
pesticide users with waste pesticides are storage or improper disposal. *
COLLECTION PROCESS/ State and local officials and other interested individuals •
work to plan collection events. A collection is designed to meet the needs of the •
area, county or individuals to be served.
The vast majority of waste pesticides collected are brought to "central-site" •
collections. Sites for central collections are chosen because of their convenience and
accessibility for a county or region participating in the program. Central-site •
collections are estimated to remove 20 to 25% of the waste pesticide stored in the •
area. Participants are required to transport waste to the collection site. To promote
safety, much effort is invested into safe handling and safe transport information •
preceding the collection. •
A few collections have occurred directly at the site of pesticide storage. On-site •
collections are used when large quantities of waste exist or when the pesticide •
containers are in poor condition and cannot be safely transported from the site.
Collection participants must preregister prior to the collection. Preregistration of £
waste prior to the collection occurs up to a previously announced cut-off date.
Information gathered through preregistration assists in planning the collection and •'
management of the collection site, and also provides for a safer and more orderly p
collection. Preregistration is an excellent tool in providing for budgeting purposes.
PARTICIPATION. More than 70% percent of collection participants come from |
farms. Each participant transports an average of 115 pounds of waste pesticides to
the collection site for disposal. The MDA secures all necessary federal and state •
hazardous waste identification numbers and becomes the generator for the waste |
collected.
Participants can dispose of up to 150 Ibs. of waste pesticide at no cost to themselves.
Participants disposing of larger amounts must share disposal cost with the MDA.
A "Disclosure for Waste Pesticide Disposal Management Plan" form is completed for
and signed by each participant. With this information the MDA is able to identify
all program participants and waste collected.
ELIGIBLE AND INELIGIBLE WASTE. Although, most waste pesticides can be
collected for disposal through this program, some pesticides are not eligible for
collection. The identity of unknown compounds can be determined, but at great
expense. Only a few unknowns are analyzed and collected each year. Other wastes
cannot be incinerated because they contain dioxins. Uncollected waste pesticides
will remain in storage with the generator. Non-pesticide materials are not eligible
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for disposal through the program. Materials such as pesticide contaminated
substances (oil, wood, soil), clean or unclean empty pesticide containers, and
pesticide contaminated rinsate are ineligible.
HAZARDOUS WASTE CONTRACTOR. A licensed hazardous waste service
company assists the MDA in conducting waste pesticide collections. The contractor
is present at all collections and acts in accordance with all applicable state and
federal regulations. The hazardous waste service company responsibilities include
handling, documenting, packaging, transporting, and disposing of all waste pesticides
collected.
VOLUNTEERS. Volunteers for each collection event are recruited locally and help
maintain a smooth traffic flow at the collection site. Each volunteer is required to
attend a "Right-to-Know" training session conducted by the MDA before working at
the collection.
PARTICIPATION. Collected pesticides are weighed in their container to arrive at
the participant's total poundage. Nearly 90% of participants dispose .of waste
pesticides without cost to themselves. Disposal of 150 pounds or less is free to most
participants. For quantities of 151 pounds up to 300 pounds participants pay $1.00
_ per pound. For quantities of 301 pounds up to 1,000 pounds participants pay $3.00
• per pound. For quantities of 1,001 pounds up to 2,200 pounds participants pay $6.00
- per pound. Waste will not be accepted from persons with quantities greater than
2,200 pounds. Government agencies and political subdivisions may participate in the
• collection program, however, these participants will pay $7.00 for the disposal of
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each pound.
PROGRAM SAFETY. A primary goal of the collection program is to operate in a
safe and efficient manner. Exposure to physical and chemical hazards at the
collection sites are minimized to reduce the risks of participants, volunteers and
workers. No injuries or releases of waste pesticides have occurred as a result of
program operation.
The hazardous waste service company personnel on-site are trained to handle most
emergencies that may arise at a collection site.
If an extraordinary emergency arose at a collection, emergency responders in the
• area would be notified. The MDA routinely provides these responders with a
™ detailed description of the activities and names of responsible parties at each
collection site prior to the collection.
Air quality monitoring at collection sites has demonstrated that the risk of chemical
exposure at the collection site is small. Collection sites will continue to be
monitored to assure site worker's personal safety.
COLLECTION SUMMARY. Of the 115,000 pounds of pesticides collected, more
herbicides have been collected than any other kind of pesticide. Insecticides
containing DDT have been the most commonly collected pesticide equalling about
12% of total amount collected.
Herbicides with the active ingredient dinoseb and pesticide containing inorganic
arsenicals are the next most commonly collected pesticides.
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CONCLUSION. Large amounts of waste pesticide are stored in Minnesota, and |
waste pesticides continue to be generated. This large and growing pool of potential
environmental contaminates is an important environmental safety and human health _
issue demanding attention. Assigning responsibility for the existing problem is •
difficult, however, because of the many factors involved in waste pesticide *
accumulation. Pesticide users are reluctant to undertake full responsibility and
related expense. They continue to store waste pesticides as the least difficult option. tt
Storage, while an improvement over improper disposal, is not a long term solution.
Often waste pesticides are old and the container is in bad shape, or the pesticide •
itself is corrosive and the container is deteriorating. Without proper and timely |.
action, these containers are likely to spill or leak and necessitate clean-ups that will
result in a costly remediation. , m
While site inspections and enforcement occur and may cause some end-users to
properly dispose of waste pesticides, it is impossible to continuously inspect the _
estimated 90,000 farms in Minnesota and the businesses using pesticides. Pesticide •
end-users need sufficient motivation to take waste pesticides from their storage areas ™
and dispose of them properly. The key to the success of the Minnesota Waste
Pesticide Collection Program is providing a safe, effective and simple method for ff
end-users to dispose of waste pesticides. •
7
REFERENCE: Minnesota Pesticide Control, Chapter 18B 8
18B.065 [WASTE PESTICIDE COLLECTION PROGRAM.] |
Subdivision 1. [COLLECTION AND DISPOSAL.] The commissioner of
agriculture shall establish and operate a program to collect waste pesticides. The •*
program shall be made available to pesticide end users whose waste generating J
activity occurs in this state.
Subd. 2 [IMPLEMENTATION.] (a) The commissioner may obtain a United _
States Environmental Protection Agency hazardous waste identification number to •
manage the waste pesticides collected.
(b) The commissioner may limit the type and quantity of waste pesticides
accepted for collection and may assess pesticide end users for portions of the costs I
incurred. •
Subd. 3. [INFORMATION AND EDUCATION.] The commissioner shall
provide informational and educational materials regarding waste pesticides and the •
proper management of waste pesticides to the public. •
Subd. 4. [CONSULTATION WITH POLLUTION CONTROL AGENCY.] The
commissioner shall develop the program in this section in consultation and •
cooperation with the pollution control agency. |
Subd. 5. [WASTE PESTICIDE COLLECTION ACCOUNT.] A waste
pesticide account is established in the state treasury. Assessments collected under _
subdivision 2 shall be deposited in the state treasury and credited to the waste •
pesticide account. Money in the account is appropriated to the commissioner to pay
for costs incurred to implement the waste pesticide collection program.
Subd. 6. [RULES] The commissioner may adopt rules to administer this I
section. ™
Subd. 7. [COOPERATIVE AGREEMENTS] The commissioner may enter into
cooperative agreements with state agencies and local units of government for •
administration of the waste pesticide collection program. m
18B.26, Subd. 3. [APPLICATION FEE.] (A)....Of the amount collected after |
calendar year 1990, $600,000 per year must be credited to the waste pesticide
account under section 18B.06S, subdivision 5...... •
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WORKING WITH THE K-12 SYSTEM IN MINNESOTA
by Shirley M. Dougherty/ Director,
Office of Environmental Education
Effective delivery of hazardous waste education to K-12 students
requires some knowledge -of the general requirements and practices
for all education and special requirements for environmental
education. I will describe and highlight areas of Minnesota's
requirements, structure .and avenues of access to the schools and
teachers and for working within the established system.
Since 1969 Minnesota has .been addressing environmental education
(EE). In'1990, a "second generation" state program of BE was
initiated with the passage of the 1990 Minnesota Environmental
Education Act. The 1990 EE. Act built on the .lessons learned from
the past and projected needs for the future.
The 1990 EE Act established seven goals for all EE programs, "an
Office of' Environmental Education (OEE) and an Environmental
Education Advisory Board. For the public (X-12) school system,
the EE Act required all schools to have an environmental education
program which is outcome-based, multidisciplinary, and integrated
into all subject areas.
•The Minnesota State Board of Education adopted learner goals for EE
in 1990 and model' environmental learner outcomes in 1991. Model .K-
12 currica, based on the requirements of the EE Act are being
developed by the Minnesota Department of Education (MDE) (available
July 1*. 1993).
The Office of Environmental Education (OEE) is part of the
Department of Education and oversees all EE programs, formal and
informal. To provide access to the K-12 system, the OEE has
established Environmental Education Teacher Contacts in each of the
over 2100 schools in Minnesota. Access to EE contacts is available
through OEE or the principal of each school who assigns the
contacts.
In addition, OEE has established an EE Bulletin Board on Minnesota
Quick Link, a computer hook-up between each school and the
Department of Education. Information is added to the bulletin
board by OSE and Quick Link users. To access the bulletin board,
contact OEE.
OEE. also is establishing a data bank of resources which will be
available to teachers through Minnesota Quick Link system.
The EE Resources Data Bank includes both people and material
resources and is available to all persons. It is intended as a
bridge between those who need resources and those who have them.
Over 5,000 entries of persons, organizations, programs and
materials are included to date. The bank includes both Minnesota
and out of state entries and is continually updated. If you wish
your resources to be included, a four-page self- categorization
form will.be sent to you.
Beyond the .Department of Education, Minnesota has. other state
agency assistance for working with teachers. The Office of Waste
Management (OWM) has a Clearinghouse for waste management
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resources. The Minnesota Pollution Control Agency (MPCA),
regulator of hazardous wastes, has an education component as part
of its program.
The OWM Clearinghouse is heavily used by K-12 teachers and has the
added benefit of being familiar to local solid waste county
coordinators. This may be the first place contacted when a teacher
searching for resources begins at the local level.
MPCA personnel with the hazardous waste program can provide
invaluable assistance and insights for working with teachers and
schools. They have had experience with obtaining access to the K-
12 system and developing appropriate materials for use in •the
schools.
The state library system also provides access to teachers through
computer data bases and special collections. In Minnesota, the
PALS computer system (Public Automated Library System) is used and .
has links to many data systems. MDE is cataloguing curricula and
other information housed in its library for access by teachers.
ECOL, an environmental repository library housed in the Minneapolis
public library is also an excellent access point to teachers, .
Additionally, the environmental agencies all have libraries where
environmental resources are housed and made available.
Outside the state system, access to the Minnesota K-12 teacher is
also provided by the Environmental Resource Directory.
The Directory is published by the Earth Day Network, a consortion
o£ private and public organisations dedicated to keeping earth day
alive every day and every year through environmental education.
This Directory is sent to schools every year and is highly regarded
by teachers as a locator of resources.
Although each school district is autonomous, sooner or later each
school in Minnesota will be developing environmental learner
outcomes and an environmental education program which is
multidiscipiinary and integrated. Each teacher will be developing
unit and lesson plans which align within the program. Materials
and resources which are based on the goals of the 1990
Environmental Education Act and which are outcome-based will
greatly assist the K-12 educators. Knowledge of the relationship
between your resource, the EE goals and MDE model environmental
learner outcomes will assist you when seeking to work within the K-
12 system, Forethought and ideas on how your resource could be
integrated into established subject areas (science, mathematics,
English, etc.) would be beneficial to both parties.
Important points to consider when working with the K-12 system:
Use the established avenues of contact with schools, both at
the local (principal of school, EE Contact) and state level
(OEE,. Office of- Waste Management, MPCA Haaardous Waste
. Program).
Be familiar both with the general requirements, practices and
methods for education and with environmental education
requirements which schools and teachers are working to
implement (legislated, State Board of Education, Department of
Education)
Develop resources which assist the schools with meeting the
requirements (outcome-based,• multi-disciplinary and
integrated) and know how they relate
List and/or provide resources to access points and delivery
systems used by teachers (OEE, libraries, directories, data
banks) '
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A SCATTERSHOT APPROACH TO YOUTH EDUCATION:
Integrating HHW into Environmental Curriculum
Sarah Dewey
Program Development Specialist
Household Hazardous Waste Project
1031 E. Battlefield, Suite 214, Springfield MO 65807
417/889-5000
Dana Duxbury asked us to identify the magic bullet of youth education. HHWP's approach to youth
education did not find a magic bullet capable of infiltrating the stone walls of academia. Rather, we
used a shotgun approach to scatter our message widely and found that at least some hit the target au-
dience of youth and youth educators. We have provided information on household hazardous wastes
to Missourians, including youth audiences, for the past 6 years. Our program is unique in that it is not
linked to a waste management system. Our goal is to raise awareness of the environmental and health
effects from the use, storage and disposal of household hazardous products.
WHY TARGET YOUTH
Youth are a very important audience to include in outreach efforts because they are future consumers
and citizens, a focus for the community, and conduits of information to the home. Many youth have
a sense of environmental stewardship that can be fostered for their home environment. Youth can
have input into what types of products are used at home and how these products are used and dis-
posed of. The study of household hazardous products provides more opportunities for realized ac-
tions on the part of youth than, for example, protecting the rainforest, which although worthy, is a
very distant goal.
It is critically important to provide information on household hazardous products to youth because
youth are much more susceptible to harm from these products than adults. Characteristics of youth
that make them at higher risk include:
• higher metabolism, so they absorb more toxic substances;
• faster breathing rates, so they inhale more toxins relative to body size;
• lower body weights, so they have more toxins per pound of body; and
• developing immune systems, organ systems, and brain and nervous systems.
Youth are also at risk because of their frequent contact with their environment when playing in the
dirt, in the water, and on floors and carpets. As a result, they have more opportunities to be exposed
to toxins in the environment. In addition, children often have cuts and abrasions which makes skin
absorption of toxins more likely. Finally, youth may not understand the risks from household haz-
ardous products. It is estimated by the Center for Disease Control that 1 out of 10 children, age six or
less, will be injured by a household hazardous product. Youth need to be able to recognize the haz-
ards of these products and how to protect themselves.
STALKING YOUTH AUDIENCES
Youth audiences can be approached in both school and non-school settings. Teachers have a very
tight schedule. In Missouri, teachers are constrained to present the information covered in the
Missouri Mastery Aptitude Tests. These tests limit the amount of additional materials teachers are able
to add to their syllabuses. Some of this material may be better suited for the more relaxed atmosphere
of a youth group, such as 4-H, Scouts or environmental/science clubs. Involving both teachers and
other youth educators strengthens your outreach efforts.
Opportunities to Address Youth and Youth Educators
Art Hazards and Techniques Workshops
Camps
Classrooms
Daycare Providers Training Workshops
District Teacher's Association Conferences
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Earth Day Celebrations
Educational Clearinghouses
Environmental Issues Conferences
4-H, Scouts, and other Youth Group Meetings
Health and other speciality Teachers Conferences
National Education Association Conferences
Newsletters, Newspapers and Magazines
Radio and Television Programs
Science and Math Teachers Conferences
Waste Management Conferences
Water Quality Conferences
Presentations. Presentations are often requested for classrooms, youth workshops and youth groups
at every age level. Household hazardous waste issues can be linked to the following subjects: art, bi-
ology, chemistry, communications, consumer studies, geology, health, science, shop, solid waste, and
water quality.
HHWP was invited to talk with the 7-9 grade gifted students in Springfield. Their class was
addressing the water quality of a urban creek as part of their community problem-solving ex-
ercise. After the presentation, the students identified excess nutrient run-off from yard care
products as being responsible for biological oxygen depletion in the creek. The resulting
media coverage of their work did much to educate the community and city planners. For an-
other project, some of the students created safer alternative hair spray from citrus and mar-
keted it to their classmates!
The Park Board of a neighboring town included household hazardous waste issues in its
summer day camp programs on water quality and stream clean-ups.
Train others to make presentations. If you and your office have limited resources available for pre-
sentations, spread your resources farther by training volunteers to provide this information.
We have trained 275 people about household hazardous waste issues in Missouri, Many of
them provide presentations, demonstrations and workshops to their local schools and youth
groups. We give them line masters for making overheads, handouts they can copy, and in-
struction on how to provide information on household hazardous wastes in a 30 minute pre-
sentation.
4-H offers a summer camp called "Earthlink." The issue of household hazardous waste was
presented to junior and senior high school aged campers. They, in turn, use the information
in their communities by presenting programs to other 4-H members. There are a number of
programs for youth on environmental issues that can be linked to household hazardous
wastes.
Train youth educators. There are a variety of youth educator audiences interested in your informa-
tion. Get your program on the circuit as a willing presenter to youth educator audiences. With educa-
tional materials and training, youth educators are more comfortable in presenting new issues. From
the workshop, they can modify the information to suit their audience.
Pollution Solutions is an annual conference designed to provide youth educators with current
environmental information, curricula and learning activities. The conference in 1992 was at-
tended by 122 youth educators from southern Missouri. There were three workshop tracks
available for the teachers to attend: waste (where household hazardous waste was placed), wa-
ter, and energy. HHWP presented a talk introducing the topic, discussing the role youth edu-
cators could play in their local waste district's ability to meet recent state laws on solid waste
management, and describing available household hazardous waste curricula and activities.
The conference was held on a teachers meeting day, so that the teachers could attend without
missing class. Participants received educational materials as part of the $20.00 registration fee.
The conference was co-sponsored by Junior League of Springfield, Ozarks Recycling
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Association, Southwest Missouri District Science Teachers Association, and Springfield Public
Schools. Many state and local organizations also donated printing costs and educational ma-
terials. After the conference, volunteers from the Junior League of Springfield and the
. League of Women Voters provided presentations on the 4-Rs (Reduce, Reuse, Recycle, and
Refuse) to area classrooms. Last year, over 1500 youth received this presentation.
Another conference HHWP presented at is Interface, an annual conference for all Missouri
mathematics and science teachers for K-12. Last year, 1700 teachers attended. It is sponsored
by the Department of Education. There are a variety of offerings the teachers can select, in-
cluding information on environmental issues to the use of technology in the classroom.
Educational materials. There are a number of excellent educational materials that address household
hazardous waste. In other words, there is no need to reinvent the wheel. Last year, the California
^Department of Toxic Substances Control and HHWP updated the annotated bibliography, Tools for
the Environmental Teacher. This describes over 50 curriculum and learning activities for grades K-12
from North America. Using the bibliography, appropriate curricula can be identified for modifica-
tion. For example, agencies in Missouri, Vermont and California have excerpted and modified activi-
ties from other programs to be included in their materials. Once educational materials have been de-
veloped or selected, they must be distributed to youth educators. The best way to have the materials
used is to provide them in conjunction with some training, such as at presentations or workshops. But
there are other routes to materials distribution.
In order to reach youth educators who could not attend our workshops, we distributed our
educational and informational materials to educational clearinghouses and to each public li-
brary in Missouri. A list of toxic art supplies developed by California was distributed to every
school in Missouri. "Hidden Holiday Hazards," a description of common poisonous materials
special to the holidays, was distributed to all state daycare operators by the Department of
Health. We also submitted articles to state teachers' journals and other periodicals.
Another way for your information to reach youth audiences is directly through materials marketed to
youth. There are media outlets, such as newsletters and radio shows, that are directed towards youth.
Try to get your materials, information and availability reported by these outlets. As a result of our
coverage in youth publications, we have received a great number of requests from youth on how to
make the world a better place and how they can play a role in the future of their planet's health. It is
exciting and encouraging to hear their interest and concern.
Educational Programs. One way to attract interest in household hazardous waste issues is to provide
an intact program that the youth educator only needs to plug into. Teachers, in particular, have a va-
riety of demands and may welcome a break from the routine, if the program is provided by someone
else or if the teacher is provided with sufficient materials that require very little preparation time.
HHWP and the Missouri Energy Resources Program (MERP), an educational clearinghouse in
St. Louis, developed a Safer Altematives/HHW Kit available to Missouri youth educators for
the cost of replacing the materials. Youth work at stations and clean dirty or corroded house-
hold products using alternative products they make from recipe cards. The recipes are given
to the youth and many of the products they make can be taken home. The kit also contains
background materials, educational activities, and a video.
HHWP is developing the Missouri Storm Drain Stenciling Project. It will provide youth and
environmental groups with stencils bearing the message "Dump No Waste, Drains to Streams"
and an illustration of a bass. Also in the kits are educational and informational materials.
Activities will include mapping the fate of materials dumped into storm drains, determining
the jurisdiction of the storm drains and obtaining permission to stencil, and investigating the
types of wastes found around storm drains. In order to receive the free stencils and educa-
tional materials, the sponsor must agree to return an evaluation and provide a written plan for
the continued use of the stenciling materials. This statewide program, in cooperation with
University Extension 4-H and the Missouri Department of Natural Resources, has recently
been funded and will begin in March 1993.
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HOW TO HIT YOUR MARK
I believe that every time you make personal contact with .youth, you have been successful. Every time
you connect and help an interested youth educator, you have been successful. Work from where you
are. If your program or interest is local, focus at the local level. If you work regionally, focus on both
local and regional levels.
Youth often have deep feelings for the environmental consequences of our actions. This is from a
letter I received from Erin, who was 16 when she wrote to me: "I would like any information that
would help me understand what is happening to our environment. If you have any ideas that I could
do to make a difference, I would appreciate it. I feel that it is important to help make this planet the
best it could possibly be." Foster and encourage this environmental concern in our youth and include
them in the resolution of our problems. If you cannot find the magic bullet, use an educational shot-
gun approach. Set your sights on the future generation and aim far and wide.
The Household Hazardous Waste Project is a program of the University of Missouri Extension
System, in cooperation with the Environmental Improvement and Energy Resources Authority.
CONTACTS
California Department of Toxic Substances Control, Education and Information Unit, PO Box 806,
Sacramento, CA 95812-0806. Contact: Melinda Fox, 916/322-0476.
Missouri Energy Resource Project, 7838 Big Bend Blvd. Webster Groves, MO 63119, 314/962-7752.
Pollution Solutions Conference, 1616 E Olive, Springfield, MO 65802. Contact: Sondra Goodman,
Coordinator, 417/869-9922.
University Extension 4-H Earthlink Camp, 210 Whitten, Columbia, MO 65211. Contact: Barry Link,
314/882-4012.
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* Th'is speech was not available at press time.
* 249-253
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Agency iC3-3CSj
Otlca oi Solid Wast*
v°/EPA Environmental
Fact Sheet
Comments Requested on
New Options for Listing and
Managing Used Oii
This notice discusses options regarding listing used oil as a waste,
management standards for used oil handlers, and possible future
incentives for encouraging used oil recycling. Through this notice, the
Agency is trying to determine the most practical methods for regulating
and managing used oil to protect human health and the environment
while encouraging and promoting recylcing of this valuable resource.
Background
In November 1985, the Environmental Protection Agency (EPA)
proposed to list ail used oils as hazardous waste. At that time, the
Agency also proposed management standards to control the collection,
transportation, and recycling of all used oils. Due to the potential
stigma that might be attached to a hazardous waste, in 1986 EPA
issued a decision not to list as hazardous used oil that is being
recycled. The Agency thought that listing could discourage recycling,
resulting in increased incidences of improper disposal of used oil. This
decision was legally challenged in 1988. and the court ruled that EPA
must make a listing determination for used oil based on the statutory
criteria for listing, which relate to whether a material is toxic.
Since the 1988 decision. EPA has been collecting and analyzing new
data on the composition of various types of used oils, the management
of used oils, and the potential impact of used oils on human health and
the environment when mismanaged. EPA believes it is important to
consider the effects of other regulations issued since 1988, as well. The
Toxicity Characteristic (TC) rule, issued in 1990. subjects many more
wastes to federal hazardous regulations, including certain categories of
used oil being disposed. Subsequent to 1988. EPA also has issued
regulations on hazardous waste storage tanks and underground
storage tanks. The Oil Pollution Act was passed in 1990. and the more
specific Spill Prevention Control Countermeasure requirements are
being developed. These laws and regulations all affect used oil
management and disposal.
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•
Action
°Us-
Listing Options
• Option One; This option, which was originally proposed in 1985,
would list all used oil as hazardous. This option would include used
I oils that are contaminated after use and oil that may not be
hazardous at the point of generation or contaminated after use.
I Option Two: This second option would list only those categories of
• used oil that are typically and frequently hazardous based on their
toxicity at the point of generation, rather than after collection and
I likely contamination. Oils that may be listed under this option are
* those from gasoline-powered engines. These include used oils from
automotive crankcases, marine engines, and piston-engine
• airplanes.
Option Three: This option would be to not list any used oils as
• hazardous and rely on management standards to address the types
• of mismanagement that have historically occurred with used oil,
such as contamination with hazardous waste due to mixing, road
• oiling, releases, and spills associated with storage and
* transportation.
| If this approach is adopted, used oil handlers would still be
required to test oil destined for disposal for hazardous
I characteristics. Characteristic hazardous waste must be disposed
according to hazardous waste management regulations;
characteristic hazardous used oil that is recycled is subject to the
• proposed management standards,
If used oil is listed as hazardous, certain exemptions and
(exclusions may apply to: nonhazardous wastewaters mixed with small
amounts of used oil: industrial wipers (such as shop towels and rags);
sorptive minerals (such as absorbent clay used to clean up spills)
• mixed with used oil; used oil filters and parts that are recycled;
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used shock absorbers (including the used oil) that are recycled; and
distillation bottoms recycled for the manufacture of asphalt.
A number of other materials may be mixed with used oil in small
quantities. To determine whether or not these mixtures are hazardous,
the Agency is proposing a qualitative test. If one drop of listed used oil
can flow from the mixture, the waste would be considered hazardous. If
adopted, this "one-drop philosophy" will allow used oil handlers to
drain all free-flowing used oil from mixtures, and dispose of the waste
in municipal solid waste facilities.
Options for Management Standards
EPA believes that used oils pose hazards to human health and the
environment, and therefore need to be managed safely. The
mismanagement of used oil can contaminate air, water, and soil.
Contamination primarily occurs from improper storage in containers
and tanks, disposal in unlined impoundments or landfills, burning of
used oil mixed with hazardous waste, improper storage practices at
used oil han
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used oil being disposed is destined for recycling. In Phase.II. the
I Agency may consider additional management standards and controls
/or used oil, if needed,
I EPA proposes that the management standards Include a recycling
presumption. Under this presumption, all used oil handers would be
subject to the same management standards unless their used oil is not
I recyclable. By eliminating the, distinction between small and large
quantity generators all used oils would be collected and recycled.
I When they comply with the used oil management standards, certain
* generators—including service station dealers—would be exempt from
Comprehensive. Environmental Response, and Liability Act (CERCLA)
• requirements for off-site releases of used oil.
The-Agency recognizes that certain nonhazardous used oils cannot
• be recycled and will require disposal. To ensure that disposal occurs in
* an environmentally safe manner. EPA is considering four approaches to
control the disposal of nonrecyclable, nonhazardous used oil:
I — Allow hazardous, nonrecyclable used oil disposal in hazardous
waste landfills.
— Allow disposal of nonhazardous used oil in municipal
solid waste facilities after a demonstration that the used oil is not
hazardous and not recyclable.
— Allow limited disposal of nonhazardous used oil if the disposal
facility is in compliance with certain design and operating criteria
that will be developed by EPA at a later date.
I — Ban land disposal of nonhazardous used oil.
In addition to used oil management standards, this notice discusses
I possible future approaches for promoting the collection and recycling of
used oil generated by people who change their own oil.
m Contact
For additional information or to order a copy of the Federal Register
notice, contact the RCRA Hotline. Monday-Friday. 8:30 a.m. to 7:30
p.m. EST. The national, toll-free number is (800) 424-9346: TDD (800)
553-7672 (hearing impaired): in Washington. D.C.. the number is (703)
920-9810. TDD (703) 486-3323.
Copies of documents applicable to this rulemaking may be obtained
by writing: RCRA Information Center (R1C). U.S. Environmental
Protection Agency. Office of Solid Waste (OS-305). 401 M Street SW.
Washington. D.C. 20460.
| Contact
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USED OIL AND FILTERS:
WASHINGTON STATE'S PROGRAMS , •
By
William P. Green
Washington State Department of Ecology
As in many areas of the country, Washington has seen the shrinkage -in
its used oil collection system over the past decade. This system, based
on voluntary participation of businesses, usually gas stations, was
deemed to be inadequate to meet the needs of the state, due to the
withdrawal of many service providers. Businesses withdrew because of
fears of liability for spills, contaminated loads, and long-term CERCLA
liability. This was articulated in Washington's 1990 Problem Waste
Study, Volume 3, Used Oil.
To address this reduction of service, the legislature enacted the Used
Oil Recycling Act of 1991, now coded as chapter 70.951 of the Revised
Code of Washington (RCW) . This act forms the basis for the current
activities in used oil going on within the state. Two of the goals of
the act are:
the provision of convenient collection service for all citizens of
the state, and
lure a re-refiner of used oil to establish a site within the state
through the maintenance of a stable, yet substantial used oil
supply.
The methodology selected to bolster the number and convenience of sites
was through the state's moderate risk waste system implemented by local
governments. Moderate risk waste is the combination of household
hazardous waste and conditionally exempt small business waste. It is
important to note that in placing used oil under the moderate risk waste
stream, this is not to be construed that Washington has declared used
oil a hazardous waste. The use of the moderate risk waste stream is for
administrative purposes only. Not all MRW streams are hazardous.
f
Local governments are required to aaend their moderate risk waste (MRW)
plans to provide for convenient collection of used oil. Each planning
area will set collection and re-refining goals for 1992 through 1996.
The goal for 1996 will be 80%. Ecology was required to1 prepare guide-
lines on the amendments and the various requirements of the law.
In addition to establishing or augmenting the current collection system,
local governments are responsible to provide education to general' public
on the advantages and the availabilities for used oil recycling. Local
governments are required to pass and enforce an ordinance requiring
retailers of used oil to.post sign encouraging recycling and providing
the location of the nearest recycling facility.
To describe the actual development of the guidelines and the subsequent
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amendments, let me introduce you to Cascade County, Washington. Cascade
County is a hypothetical jurisdiction, which sits astride the Cascade
Mountains. It was designed by Ecology staff for illustrative purposes
in the development of the used oil amendments. Throughout the remainder
of my presentation, you will see different sections of the used oil
amendment for Cascade County.
In the development of the guidelines, we encountered two major issues:
How do we include currents efforts in meeting the requirements of
the new law?
What is convenient?
Required for all submissions of amendments is a checklist of the
requirements ("Appendix C") prepared by Ecology. Ecology amended the
checklist to provide for references to two documents, the current plan
and the amendment. If a .current effort met a requirement, the county
only needed to reference on the checklist to be in compliance.
To provide guidance on convenience, Ecology gave the counties a choice
to use two options, one planning based, the other based on standards.
In the first, "the "Service Area Designation" approach, counties
basically look at where the people are located, and where they go to
complete routine tasks, such as shopping, school, or other public
services. Oil collection facilities should be cited in such a vay that
all citizens will have at least one available at one of the routine
places they go.
In the second, the "Benchmark" approach several specific options were
made availableL depending on whether the county-is urban or rural in
nature. For urban counties, three benchmarks are acceptable:
Curbside used oil recycling (three of our counties have already
implemented this),
90% of the population is within two miles of an oil collection
facility, or
there is an oil collection facility for every 10,000 residents.
For rural counties, two benchmarks are available:
there is an oil facility at each solid waste handling facility,
and one in each town of 2000 or greater that is more than five
miles from an alternate oil facility, or
there is an oil facility in each town of 1000 or more that is more
than five miles away from am alternate oil collection facility.
Out of these options, it is estimated the between 200 and 500 new
oil collection facilities will be sited and/or constructed in the
state by 1996.
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As part of the moderate risk waste system, these efforts are eligible
for Ecology's MRW assistance program, both technical and financial. _
Special funds (about $3 million) were set aside in the summer of 1992, •
for developing each county's used oil amendment. *
Finally, training was provided to Ecology staff and local government •
staff. In this half-day training, the flexibility granted to local |
government in solving their used oil problem was emphasized. Local
government staff were provided with three documents: ' •
Ecology's "Used Oil Recycling Amendment Guidelines for Local
Hazardous Waste Plans; Publication No. 92-38",
"(Model) Used Oil Recycling Amendment to the Local Hazardous Waste •
Plan for Cascade County, Washington, July 1992", and
"A Guidebook for Implementing Curbside and Drop-Off Used Motor Oil p
Collection Programs" by the Washington Citizens for Recycling in
behalf of the American Petroleum Institute. _
In addition, Ecology has been working with the Western States Petroleum *
Association in behalf of the counties. Goals of this contact include
greater private participation in oil collection, and more convenient re- •
refining opportunities for the counties. Meetings directly between •
association members and local governments are being considered for early
next year. Already two auto parts store, Schuck's'and Al's as well as m
Texaco service stations are operating sites jointly with local •
jurisdictions.
In support of local efforts, the legislature assigned Ecology to develop •
and implement a state-wide education program. Ecology is also to •
develop management standards for used oil collection facilities (which
may be classified as limited moderate risk waste facilities, and thus •
require no permit). Ecology is also to promulgate rules governing |
transporters and processors of used oil. These rules will be
incorporated in the state's dangerous waste regulations.
Several prohibitions regarding the disposal of used oil were included in
the act, the violation of which is a misdemeanor (punishable by 90 days
in the county jail, $1000 fine or both). These prohibitions include:
the use of oil for dust suppression or weed abatement, effective
January 1, 1992;
the use of absorbent-based oil-changing kits, effective July 1,
1992; and
the disposal of oil in a municipal solid waste landfill or any
other facility not managed in conformance with the Act.
The Act focussed on used oil from households. Although not required,
counties are encouraged to address other issues related to used oil.
Such issues may include used oil filter, antifreeze, and used oil from
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small businesses, as appropriate to the jurisdiction. If included in an
approved used oil amendment, projects related to these issues are
eligible for Ecology support.
So, what do we get from all this paperwork? First of all, we get the
used oil collection and re-refining goals. Of what use are these? We
can take these numbers to the petroleum industry as a stable feedstock
for the new re-refinery to be established in the state. Right now, our
estimates are that we will be ready to re-refine some seven to ten
million gallons by 1996. That's a lot of oil.
We have a planned and centrally (at the local level) implemented used
oil system. This provides stability in used oil collection. If one
vendor drops out, then another will be found to take his/her place.
This provides consistent service to the public, avoiding the fallout of
the 1980's, as well as (again) stable feedstock for the re-refiner. It
also provides information for budgeting of resources to maintain the
system, in case of market fluctuations.
Finally, it provides a thorough and hands-on analysis of the used oil
system in the state. Counties are requested to present in their
amendments any impediments to the proper management of used oil. The
state has committed resources to the reduction or elimination of these
impediments. Through an identical process in the moderate risk waste
plans, many impediments were identified and about 50% have been
eliminated by state and local policy development, information sharing,
and, as necessary, legislation.
In the end, our efforts in used oil in Washington mimic our efforts with
household hazardous waste. Enough planning to establish a local-state
partnership to move this waste stream out of our lakes and streams and
other water bodies: especially the Columbia River and Puget Sound.
There is a radio ad that Metro of Seattle ran which said: "There was an
oil spill in Puget Sound today...and its source was you and me." We
hope to change that.
CASCADE COUNTY
Hl«hw«y 71 PMHIc Cntt HlghMV 73
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APPENDIX A USED OIL RECYCLING AMENDMENT ELEMENTS CHECKLIST
#
A-l
A- 2
A- 3
A-4
A-5
A-6
A-7
A- 8
B-l
B-2
C-l
C-2
C-3
C-4
C-5
C-6
Element
Household Used Oil Generation and
Management
Existing and already -planned
Collection Services
Needs for upgrading the Used Oil
Collection Services
Opportunities to expand or
upgrade household used oil
collection services
Used Oil Education resources
Used oil hauling and markets
Financing of used oil efforts
Other needs related to used oil
Collection and reduction, reuse,
and re -refining goals for 1993 *
1996 (two goals)
Number of used oil collection
sites needed for adequate service
Improvements to used oil
collection services
Marketing strategy for household
oil
Program for used oil education
Enforcement strategy for signage
ordinances, including ordinance
development
Implementation Schedule and
annual budgets for all used oil
activities
-
Roles and Responsibilites matrix
for all jurisdictions involved in
used oil management
Ref. in
plan
4-5
5-1, 7-5
7-1
7-1
7-7
Ref. in
amendment
A-l
A-l
A-2
A- 2
A- 3
A-3
A-3
A-3
Coll: A- 5
also A- 8
Ref: A- 8
A-5
A-5
A-6
App C
Guideline
A-6
OK*
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APPENDIX B SAMPLES OF SERVICE LEVEL DETERMINATIONS
RURAL SCENARIO-CASCADE COUNTY (pop. 75,000)
Cascade county is a rural Washington county, t map of which is shown at right. Cascade county has one
major city, Mountaintop, with 35,000 people. The rest of the population resides in smaller towns or in
unicorporated (agricultural) areas. The population of Cascade county is divided as follows:
Mountaintop
Eastgate
Crestvicw
Warfield
Blue Lake
Hill Lake
Marsh Lake
Highlands
Eelgras City
Unincorporated
35,000
5,000
4400
1,900
1,500
1,200
900
800
600
23,600
All of the above cities have commercial districts. In addition, there is a separate regional mall in
Mountaintop. The landfill is located near Eastgate, and the self-haul rate, is 30% (about equal to the
unincorporated population). Eastgate and Blue Lake are contiguous, as are Highlands and Eelgrass Cry.
Year Recycling
Goal
1993 25%
1994 40%(xl.25)
1995 60%
1996 80%
Service %
(as % of pop.)
na
50%
75%
100%
Population
Served
na
38,000
63,000
75,000
Option One
Year Proposed Sites Pop. Served
1994 Two sites Mountaintop 35,000
(Downtown and mall)
Crestview _ 4.500
Total 39,500
1995 Eastgate Landfill (self-haul) 23.600
Total 63,100
1996 Eastgate-Blue Lake 6400
Warfield 1.900
Hill Lake 1,200
Marsh Lake 900
HighJands-Eclgrass dry , 1.400
Total 75,000
TOTAL SITES » 9
Option Two
Proposed sites
Solid Waste Stations
Cities over 2000
Mountaintop
Eastgate
Crestview
Towns 1000 - 2000
. Warfield
Blue Lake*
Hill Lake
35,000
5,000
4400
1,900
1400
1,200
•Contiguous to Eastgate
Solid Waste + Cities over 2000
» 4 sites
Cities and towns over 1000
= 5 sites
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PARTC
RECOMMENDED PROGRAMS AND ACTIONS
1. improvements to used oil collection services
The county has set the following collection goals {based on total household
used oil generated = 160,000 gallons/year):
Year
1993
1994
1995
1996
Goal
25%
40%
60%
80%.
Gallons
40,000
56,000
96,000
128,000
In order to reach these goals, the county has set the secondary goal to service
the following populations:
Year
1993
1994
1995
1996
%Pop
33%
50%
75%-
100%
Population
25,000
37,500
63,000
75,000.
The following facilities are proposed:
1992
1993
1994
1995
Current facilities at 10%
Marsh Lake
Execute interiocal
Eastgate Landfill MRW facility
for Unincorporated County
Mountaintop
Upgrade Joe's Auto Supply
New facility at Transfer Station
Crestview
Upgrade Bob's Snowmobile
Highlands-Eelgrass City
Upgrade PUD, move to Rotary
Total
Population Population
Served
7,500
900
23,600
35,000
4,500
1,400
Served
(900)
(24,500)
(59,500)
(65,400)
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1996
Hill Lake
New PUD facility
Eastgate-Blue Lake
Mike's Gas-n-Go
Warfield
Construct fadlty at Rodeo Club
1,200
6,500
1,900
(75,000)
Total Number of Sites = 8
An upgrade will be the installation of a 250 above-ground storage tank,
including secondary containment and barriers. Tanks at the Eastgate Landfill
and the Mountaintop Transfer Station will be 1000 gallons. Minimum
maintenance of a station includes intermittent monitoring (full-time staff will be
provided at the landfill and transfer station), keeping the area dean, and
notifying the county when a pick-up is needed.
2. Marketing of Used Oil
The High School shall receive first preference for the used oil. This will
absorb 75% of the collected oil in the first year. A determined effort by
the county will lead to a re-refining rate of only 55% by 1996 (see note
below). There are several impediments which prevent Cascade County
from achieving the 80% re-refining goat as required by in the guidelines:
Used oil is being diverted to the High School. The school's used
on burner is the only source of heat for the building. Conversion
to a more conventional system would take many years to finance.
Emission tests have shown no adverse effects of the used oil.
There is an 85 cent per gallon price differential to re-refine used
oil. Re-refining used oil will cost the county between $125,000 -
$150,000 over the life of the plan.
The hauler for re-refining only has a capacity of 100,000 gallons
per year. In 1996, he will be running at 88% of capacity, which is
difficult in such a remote area as Cascade County, where roads
may be dosed for extended periods during the winter.
[NOTE: In this example, Cascade County could not reach the 80% goal by
1996. This was the example selected by Ecology In order to Illustrate the
content and format of an impediments section. It Is expected that all
counties will make determined efforts to meet or exceed the 80% goal by
1996.]
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Appendix C Sample Implementation Schedule: Cascade County
SITES
Eastgate
Landfill
Mountaintop
Mountain Mall
Crestview
(etc.)
•
•
Education
Ordinance
1993
10/1
3/i — >
Develop ->
1994
3/1
6/1
Imnlomftnt ^
1995
6/1
1996
-
The numbers below are only to illustrate the format of the table.
Budget
Education
Ordinance
Site
Development
Collection
Reserve
Total
1993
included
$10,000
2000
3400
9000
24,400
1994
in current
$5000
3000
16,000
12,500
36,500
1995
MRW efforts
$5000
2000
51,000
21,000
79,000
1996
_ _
$5000
6000
88,000
28,000
127,000
1993
RECYCUNG GOALS
1994 1995 1996
25% (rate)
40,000 GAL
40%
56,000 GAL
Total
60%
96,000 GAL
80%
128,000 GAL
in region = 160,000 gal
Projected galionage of used oil collected including end use
Year
1992*
1993
1994
1995
1996
volumes
Collected
16,000
40,000
56,000
96,000
128,000
10%
25%
40%
60%
80%
High School
12.000
30,000
30,000
30,000
30,000
7.5%
18%
'18%
18%
18%
Energy Rec.
4,000
6,000
10,000
16,000
10,000
2.5%
4%
7%
10%
7%
Re-refining
0
4,000
16,000
50,000
88,000
0
3%
10%
32%
55%
are in gallons. *From estimates in moderate risk waste plan.
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API's Used Oil Program
/
Craig Campbell
Thank you ...
It is a pleasure to be with you to discuss the petroleum industry's perspectives on used oil.
During our time together, I plan to cover several areas: •
1. Discuss the industry's role in solving the problem.
2. Give you some background information to help define the scope of the problem
3. Communicate our position on the key used oil issues.
4. Highlight the components of the petroleum industry used oil program.
Let's start with the petroleum industry's role. While some of you may be familiar with the used
oil problem, my guess is that few have had the opportunity to hear our thoughts on how best to solve it.
So right up front, I want to emphasize that this is a very important issue for us and I want to clearly
establish two fundamental reasons for the member companies of API making used oil a top priority.
First and foremost, we want to demonstrate that we are serious about protecting the environment.
The key word is demonstrate and we are anxious to do that.
Secondly, we recognize that no one group working alone can significantly impact this problem.
In fact, successfully managing used oil will require a great deal of cooperation. Oil companies, regulators,
legislators, local governments, retailers, educators, recyclers, re-refiners, generators and I think most
importantly, the Do It Yourselfer (DIY) -- all must work in harmony to make a used oil management
system work. Accordingly, we want to be proactive, involved, and use our resources in the development
of initiatives that result in the collection and recycling of used oil. In other words, we want to be part of
the solution.
Having established the industry's role, I would like to present some background regarding the
scope of the used oil problem.
Any discussion of this subject should include all generators of used oil but for our purpose today,
we can divide them into 3 broad categories: industrial users, commercial vehicles, and personal vehicles.
For the most part, we believe that in the industrial and most commercial sectors used oil generated
is being managed properly and recycled.
Our focus therefore is on oil identified for use in personal vehicles. This product is essentially
purchased one of two ways: installed (service stations, car dealers, Quick Lubes) or over the counter
(discount store, grocery store, auto parts store). The over the counter sales include oil sold to those
individuals who prefer to change their own oil -- the DIYer. I might add that the DIY oil is not limited
to automobiles. Oil changed in lawn mowers, boats and snowmobiles for example, are included in the
scope of the problem.
Typically automotive oil that is changed at a service facility is placed into a storage tank.
Periodically, the proprietor calls a collector and the product is picked up and recycled.
The DIYer, on the other hand, faces a more difficult problem when deciding what to do with his
used oil. If proper disposal is neither convenient nor important to him, that oil may end up in landfills,
backyards, or sewers, polluting both the soil and water. . '
Each year, it is estimated that DIY oil changers generate about 200 million gallons of used auto-
motive oil. While some state and local governments have collection programs, our concern is that only
a small percentage, perhaps as little as 10% of the DIYers used oil is being collected and recycled.
However, to be fair, mere are several impediments to proper collection and recycling of DIYer
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used oil including the lack of convenient used oil collection centers, the absence of coordinated
information and education programs which motivate the DIYer and concerns about liability issues.
The petroleum industry has developed a policy statement which defines our position and recom-
mended actions for collection and management of used oil. Three basic points summarize our thoughts:
1. We encourage and support state initiatives to promote public and private sector collection
and education.
2. We support legislative and regulatory initiatives that set environmentally protective and
cost effective management standards for recycling used oil.
3. We recommend that used oil not be declared a hazardous waste.
Now I'd like to take a couple of minutes and expand on these points.
You'll note that we've identified the states as the principal focus for these initiatives. We chose
this path because state programs have several advantages.
1. They can be tailored to meet unique circumstances and demographics.
2. They can take advantage of local resources.
3. They are not subject to changes in the marketplace and therefore form a permanent core
of collection facilities.
And as you will see later in my remarks, this approach is gaining acceptance.
The other points that 1 would like to expand on involve our views regarding the classification of
used oil and management standards. The API and its member companies oppose listing used oil as a
hazardous waste for several reasons:
1. Used oil destined for recycling is a resource, not a waste. It has value in the marketplace
and as a source of energy.
2. Listing would increase the liability associated with handling used oil and thereby
reduce the value of the commodity
create a stigma which could discourage participation in collection and recycling.
and unnecessarily increase the cost of collection and management.
Put simply, listing appears only to make the collection and recycling of used oil more difficult and
expensive - certainly counter-productive to the program we are trying to initiate. Alternatively,
environmentally protective and cost effective management standards wifl ensure responsible management
of used oil while not discouraging its collection and recycling.
Today while neither the U.S. Environmental Protection Agency nor Congress has decided how
used oil should be regulated and managed, both groups are seriously considering the issue. It is our hope
that our government leaders see the wisdom of not listing used oil.
During the balance of my time today, I am going to review the API Used Oil Program which was
developed to promote the Industry positions just discussed. This program, which consists of
communication, legislation development, implementation, outreach and company programs is endorsed and
managed by a 19 member Used Oil Working Group.
The first component is program communication. This involves industry presentations to public
policy groups, legislators and other interested organizations to promote the need for used oil collection
and recycling. Focusing efforts in this area enables the API to communicate industry's position on used
oil recycling to the public and to involve the petroleum industry in promoting model legislation and
program development To support this effort, API has developed and disseminated the Policy Statement
mentioned earlier, a general information brochure; and a Q & A Program Sheet.
The second element of our program consists of legislation development. By working with state
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legislators in conjunction with our State Petroleum Councils, we arc assisting the states in developing
effective legislation to increase the collection of used oil on a permanent basis. The API Used Oil
Working Group has developed state model statutory language for used oil which emphasizes collection,
education, management standards, and funding.
Because adoption of these objectives is such an important pan of our program, I am going to
discuss them in more detail. «.
First Collection. From an environmental perspective, we view this as the most critical and perhaps
the most difficult component of a used oil program. The focus here should be the DIY and therefore,
convenience becomes the key factor.
Accordingly, the model bill encourages the establishment of permanent used oil collection facilities
at public sites as the primary collection effort To complement this core of sites, the private sector is also
encouraged to accept used oil from the public. The incentive for participation comes in two forms. First,
used oil collectors are indemnified from expenses associated with the disposal of used oil that has been
contaminated and therefore, non-recyclable. Second, grants are made available for the establishment and
maintenance of public used oil collection facilities and for programs that support other types of used oil
collection and recycling. An example would be curbside collection; which provides the ultimate
convenience to the DIYer and which we feel holds a great deal of promise as being the most effective way
to secure high residential participation.
The second objective of the model bill involves education. For used oil recycling to work, people
must not only know where it can be dropped off, they must first want to dispose of it properly. At a
minimum, public awareness programs should include a toll-free telephone number for used oil recycling
information, appropriate signage indicating the location of used oil collection sites and some material for
the classroom to ensure good habits are learned early by future DIYers.
Enforceable management standards which address collection, handling, transportation storage and
recycling of used, oil, comprise the next important component of our Model Bill. This ensures only
responsible individuals are involved in handling used oil. While we encourage penalties for improper
disposal of used oil, we feel legislation should exempt used oil collection facilities from liability for spills
and releases as long as the collection facility does not knowingly violate the applicable used oil
management standards.
the final objective of our Model Bill which I will discuss is funding. Obviously implementing
and administering this program requires financial backing. Since improper disposal is a societal problem,
ideally used oil programs would be supported by state general funds. However, since these resources are
typically strained, the petroleum industry supports an environmental fee assessed on automotive oil sold
in the state in bulk and packaged form. However, we feel strongly that the fee not confer a competitive
advantage to a particular oil industry segment and should only be collected on sales for consumption in
the affected state.
To complete my discussion of legislation development, I would like to make a couple final points.
First, we have a consensus from the 19 members of the Used Oil Working Group to promote the Model
Bill I just described as an industry position. This can be significant when working with legislators and
regulators.
Second, the model bill is currently being reviewed by the Council of State Government's
Suggested State Legislation Committee for inclusion in the publication, Suggested State Legislation. If
approved, this endorsement will give our program added profile and exposure. (Discuss EPA Award,
NACO, SSEB if appropriate).
And finally, in 1991, South Carolina, Texas, California, and Louisiana passed legislation very
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similar to our model bill and other states are currently studying its components.
The third element of our used oil program involves working with municipal managers, regulators,
and in some cases, tax administrators to implement their programs. Specifically, to assist with
implementation, we will use three publications: The first will explain how to set up curbside and drop-off •
collection programs including how to select the type of program best suited for your particular area. The |
document is based on national surveys of existing programs and will include examples of budgets, '
procedures, equipment and model programs that are currently working. •
The second publication will address the question of end-use for used oil by examining the various •
alternatives in terms of environmental impact, energy balance, geographic practicality, and economics. This
should prove useful to the recycling coordinator faced with deciding on options for end-use. •
Finally, the third publication will consist of a public relations kit containing a model public *
relations campaign and camera-ready materials which can be personalized for the respective municipality.
This will provide local governments with a graphically consistent way to promote their programs at •
minimal cost and to inform the public how and where to properly dispose of used motor oil. I
The fourth component, outreach, involves an effort to establish a leadership position and serve as
a focal point by developing educational/reference materials on all phases of the issue and cultivating •
coalitions with other interested groups. Individual companies provide speakers to communicate our "
program to interested parties with different perspectives. By doing so, API is able to reach a broad
audience and work with other groups interested in being part of the solution, (e.g. Association of •
Petroleum Re-refiners, National Oil Recyclers Association, and the Household Hazardous Waste •
Conference.)
To further our outreach efforts, we are developing a' Digest of State Used Oil Statutes and •
Regulations which is a synopsis of used oil recycling legislation and regulation in all 50 states. In _
addition, we have assembled a Used Oil Bibliography which lists publications, magazines, government
documents and state contacts that deal with used oil. I
Finally, and most importantly, our member companies are promoting the collection of used DIYer
oil and in some cases, are investigating recycling options for the proper end use of used oil. Ten member _
companies have, in the past year, formally announced voluntary used oil collection programs in 39 states I
and the District of Columbia with over 5,500 locations accepting used oil from the public. This is up from
approximately 800 locations in early 1991. Other API member companies are studying the issue and we
expect expansion and new program announcements in the near future. I
In Houston, Texas, five companies have donated the resources necessary to initiate a used oil
curbside collection demonstration in Houston, Texas. This pilot project will serve approximately 30,000 _
homes and become operational in April, 1992. I
In addition to actually collecting DIY used oil, our member companies actively support state and
local government efforts to collect and recycle used oil, reinforcing the notion that public and private •
entities working cooperatively can have a great impact on bringing improperly disposed used oil into a |
management system.
Looking ahead there is obviously a lot to do to bring a program of this size to maturity. For our
part, the agenda is simple, we want used oil managed, not polluting the environment and we are anxious
to work with all interested parties to achieve that end.
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WASTE TYPES AND QUANTITIES
George Kinney, Environmental Supervisor, Dakota County, Minnesota
During this talk I'd like to focus on the HHW that could be expected in a new program. I'll
also talk on factors that affect turnout
If you're setting up a collection for the first time in an area, review the demographics of the
community. Older communities will have more HHW, and more expensive HHW. Rural communities
will have a different mix of wastes than an urban area, and the suburbs will bring in lawn chemicals
and five gallon pails of water-based driveway sealer in great numbers! Just as important" is the wealth
of the community. We see more wastes, and less action at the exchange areas, in the more affluent
communities than in the more modest communities. In our area, some of the more modest are also
rural, and they may have more uses for many of the chemicals on the exchange tables.
How extensive is the collection program?
Several types of collection programs are in existence across the country. Some collect only
paint at certain events, others collect all chemicals except paint. There are good reasons to follow
either model.
In Dakota County, MN, we have had many event collections that included tires, and in a few
instances, white goods, neither of which could be considered HHW. Presently, our collection site at
Gopher Smelting and Refining in Eagan, open twice a week, takes, in addition to "mainstream" HHW,
tires, used oil, and auto batteries. Both Gopher Smelting and Aptus, our other permanent site, also
take household batteries. Recently we began taking fluorescent tubes. Our belief is that, as the
County, we must be responsive to the needs of the public, and if that includes a tire drop-off for a
reasonable fee, we should make an effort to include that service. By being extensive, we believe we
will attract residents to the program who would otherwise not feel they had enough wastes to take the
time to come. Back in 1985 and 1986 we worked with a contractor that would not take aerosol cans.
We notified the public to not bring in aerosols. We received a good number of aerosol cans, some
inserted into half-full cans of paint, many others hidden in plastic bags in the bottom of boxes.
Another reason for Dakota County's emphasis on offering to act as a disposal site for tires, oil
and batteries, which could be dropped at service stations (for a higher fee), is that it gives us a chance
to disseminate additional materials to those using the site. Our experience is that three to four per cent
of our households have brought HHW to event collections or permanent sites annually since 1989. In
1990, 15% of the users surveyed indicated they were repeat users of HHW sites. That number is now
between 20 and 25%. The number of new users, perhaps 3,000 household this year, will have greater
awareness of HHW, and how to avoid creating additional HHW, as a result of using our sites.
How frequently does truly dangerous waste arrive?
This is a frequent question asked of those of us doing HHW work. The simple answer is
"infrequently", to the metro area of the Twin Cities, we probably have one or two incidents of picric
acid, high explosives, etc., annually. .More frequent items, such as potentially peroxidized ethers or
blasting agents, homemade black powder, or old shells and cartridges, occur with enough regularity to
keep staff aware of possible danger. • • '
What conies in?
Paint and used oil are our two largest waste streams. The "average" vehicle delivers the
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following to one of our sites:
HHW Approx Quantity
3 gallons
1.5-2 gallons
2 cans
Used oil
Oil-based paints
Aerosols
Acids
Poisons
HHW
Latex paint
Flamm. liquid
Chlorinated pests, etc.
Corrosive solids
RW.SoLids
Quantity
2.5-3 gallons
0.5-1 gallons
1-2 quarts
6 ounces
1 ounce
< 1 pint
1 ounce
These numbers have changed somewhat over time. Initially, every early HHW collection had
r^^^^^^^^^^^S^^^.
1/17/88
330 (2.02)
330 (2.02)
55 (.34)
138 (.85)
32 (.20)
45 (.28)
50 (.31)
50 (.31)
55 (.34)
163
4/25/92
605 (1.48)
1100 (1.48)
220 (.54)
120 (.29)
10 (.02)
163 (.34)
21 (.40)
9 (.022)
275 (.67)
409
5/30/92
459 (2.05)
880 (3.65)
220 (.91)
117 (.48)
20 (.083)
112 (.46)
27 (.11)
25 (.10)
165 (.68)
241
Household Hazardous Waste
(Amount per Vehicle)
Waste Type
Oil Base Paint (Gallons)
Latex Paint (Gallons)
Fuels (Gallons)
Pest. Chlor. (Gallons)
Acids (Gallons)
Corrosive Solids 888 (Pounds) 45 (.28)
Poisons (Pounds)
HW Solids
Aerosols (Gallons)
Vehicles
Data from collection events held several years ago show some differences with collections held
today in our County. Fewer older chemicals of all types are seen, with more material of recent
vintage, and especially paints and fiammables are delivered. This may indicate a certain "market
penetration", and maturation of the program.
As everyone who participates in HHW collections knows, the average citizen has some
misconceptions about what is hazardous. Every collection event will have stories of homeowners
waiting in line with empty bottles of rug shampoo or floor wax. As awareness is spread throughout
the community, the homeowners will understand what can be flushed to the sewer or septic system
and what must be saved for the collection event,
Regional differences
In much of our County, which is the fastest growing county in Minnesota, latex paint is
discarded at a 3:2 ratio over oil-based paint. In the oldest sections of the County, however, the two
are discarded evenly, and in sections of St. Paul, oil-based was received at collections in greater '
amounts than latex. The age of the community will also determine the quantities and types of
hazardous chemicals received, such as old, banned pesticides and solvent cleaners.
The new suburbs also yield other types of waste not seen frequently in established
communities, such as construction adhesives, tile mastics, frozen latex driveway sealers, and caulks.
The age of paint is younger than in the established areas. Rural areas may bring in older HHW, from
families cleaning out old storage buildings, etc.
In Minnesota, latex products freeze if left in unheated areas. This translates into a lot of
ruined latex paint and other products that might otherwise not be candidates for HHW. This is
certainly not the case in warmer sections of the country.
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Fear Not the Waste Exchange
Brian J. Johnson
Environmental Programs Coordinator
City of Santa Monica
Introduction
Whether by enlightened decision making or regulatory
mandate, local governments now find themselves implementing
programs to segregate and manage household hazardous waste.
Early on, program managers are confronted with the
staggering budget impacts of program implementation. The
per unit cost for disposal of containers of household
hazardous waste often times meets or exceeds the original
cost of the product. Indeed, the greater success a program
experiences, the greater the cost (at least until such time
that public education in this issue surpasses public
chemical consumption). This conundrum places us in the
unenviable position of striving to deliver the greatest
service while knowing that the better we do, the deeper we
sink into the swamp of fiscal despair.
Today, I intend to describe and sell to you a program
activity which contributes to greater program success and
potentially substantial cost savings. The activity is the
materials exchange (also known as the waste exchange).
Simply giving away, under controlled conditions, the usable
products in their original containers that come to your
program rather than paying to recycle or dispose of them
off-site.
Liability
Before presenting the rather compelling results of Santa
Monica's materials exchange program, lets discuss the "L"
word, liability. To do this, we shall momentarily expand
our perspective to construct a path of reason down which we
may lead skeptical risk managers and nay-saying government
attorneys to a clearer understanding of our purpose;
Liability in our industry, like energy, once created cannot
be destroyed, it can only be transferred. We now know that,
due to the public health and environmental hazards created
by the existence of household hazardous waste in the solid
waste stream, liability is created. If we choose to ignore
this waste stream; as has been done until recently, the
liability follows the generator (the city or county) to the
solid waste landfill (which is not designed to contain
hazardous waste). When the landfill leaks its contents and
requires remedial attention, generator liability becomes
fully realized. We endeavor to reduce this looming
liability by establishing mechanisms to divert the household
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hazardous waste component from solid waste landfills via
collection programs and load checking.
Liability is then transferred to the collection program, H
because you come to possess the harmful waste. As the waste I
is subsequently transported from your program (often long •
distance) and. disposed, your liability is comingled with
that of other generators and becomes inextricably tied to •
the fate of the disposal facility, til death do you part. |
We hope to believe that this is a more defensible management
of the liability created by the wastes. «
Alternatively, by undertaking a waste exchange, there is a
transfer of liability exposure from disposal to the
individual using the product, as the possibility exists that I
someone may become harmed by a misused or mislabelled •
material. We acknowledge that the waste exchange is not
without liability; therefore, participants are asked to sign
a liability waiver as shown in Attachment 5.
I
One is, therefore, confronted with a choice between the _
superfund liability of disposal, where your fate is forever I
in the hands of the waste management company and its ™
practices, or, the short term liability that virtually
dissipates with the individual's use of the material. That •
which should tip the decision scale in favor of the waste I
exchange is not only the environmental and economic
benefits, which will be detailed below, but also the «
reduction in liability exposure which evaporates (or •
volatilizes) with the use of the product. .
I believe that we, in this industry, have largely failed to fl
inform and explain to risk managers and councils the •
totality of environmental liability of hazardous waste
management and to identify mechanisms to minimize long term ' •
exposure. |
Waste Exchange Implementation .
Successful waste exchange programs are not created *
overnight. Risk managers must be won over and consistent
markets found. A strategy which has proven successful in I
our program was the planning for a small beginning to I
develop a history of need and safety and later expansion
once these conditions are established. •
We began by offering only paint products to City employees,
which, over time, enjoyed moderate success. We found that _
our participants then wanted additional products. In •
response, we slowly expanded to non-paint items such as ™
automotive products, cleaners and selected pesticides. Upon
establishing a history of safety, we then opened our doors •
to other participants, including residents, Boy Scout |
troops,.artists, contractors (particularly those who
specialize in low income contracting), performing arts •
cooperatives (such as equity waiver theatre), a private high •
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school, neighborhood associations, and an abused women's
home. Please see Attachment 1 for a copy of user groups and
materials.
Program safety is of paramount concern in our facility.
Protocols have been developed to determine which materials -
may be exchanged. Every container is opened to verify
contents and ensure the integrity of the material, unless
the container is brand new and sealed. The container must
be in good condition and have an original and readable
label. Unknowns and any suspicious material is excluded
from the exchange, as are paints which appear older than 10
years. Banned materials such as pesticides (DDT), wood
. preservatives (containing pentachlorophenol) and asbestos
containing materials (roofing tars, topping compounds) are
excluded as well. We include few pesticides and oxidizers
in the exchange due to philosophical or safety concerns. We
provide special orders for individuals who request certain
products and who have time to wait for a material (although
most orders are filled within two weeks).
Currently, we are able to divert the following percentage of
incoming materials into the exchange program:
paint and paint products - 60%
corrosives - 10%
pesticides .- 20%
automotive products - 100%
home products (cleaners) - 50%
oxidizers - 0%
construction products - 5%
Fiscal Impact
The City of Santa Monica currently budgets $248,000/year for
the operation of the Household Hazardous Waste Collection
Facility. Of this amount, approximately $56,000 is spent on
transportation recycling/disposal of the waste and $54,800
is spent for materials and supplies. Based upon the current
diversion rates, it is extrapolated that the materials
exchange allows the avoidance of approximately $44,000
dollars in disposal costs, and perhaps another $15,000 in
materials per year. This savings is greater than 20% of" the
program's entire budget. Please see Attachments 2, 3, and 4
for graphic representations of these statistics.
Summary
To date, our closest brush with liability was two
contractors scuffling over a five gallon bucket of paint.
We are saving over $50,000 per year in avoided disposal
fees. These avoided costs have allowed the funding of our
growing public education program (including production of a
one hour documentary on household hazardous waste issues).
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We are re-introducing carefully selected and screened . •
household hazardous materials into the market for originally
intended use by individuals -who otherwise may not be able to •
purchase them. Over 76,000 pounds of household hazardous I
materials .are exchanged rather than purchased each year,
thereby slowing down the hazardous materials production
continuum. •
We have, thus far, minimized the city's long term liability
by significantly reducing the volume of hazardous waste _
being managed off-site by disposal facilities. If any of •
these sound like positive steps for your program, I. •
recommend implementation of a measured and controlled
materials exchange. •
ATTACHMENT 1
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CITY OF SANTA MONICA
ENVIRONMENTAL PROGRAMS DIVISION
HOUSEHOLD MATERIALS EXCHANGE PROGRAM —
Below, please find a list of individuals and groups which
regularly receive household hazardous materials from the City's fl
household hazardous materials collection program. Included is a J
list of the types of materials each group commonly.receives.
Boy Scouts: white gas, small propane cylinders (camp stove fl
size), paint, thinner, kerosene, pet care products. •
Artists: paint, thinner, acid, roofing tar, stains, adhesives, m
spray paints. •
Contractor/Handyman (specializing in repairs in low income
areas): paint, thinner, stain, varnish, construction adhesive, •
roofing tar, pesticides. ' |
Performing Arts Cooperative: paint, stain, thinner. ,_
Private High School (Gang member rehabilitation program): paint, •
thinner.
Abused Women's Home: personal care products (hair spray, nail •
polish), paint.
Neighborhood Association: paint, thinner. • I
Private and Public Graffiti Removal Programs: paint, thinner.
Private citizens and City employees: paint, thinner, stain, •
varnish, pesticides, pool chemicals.
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CITY OF SANTA MONICA
HHW COLLECTION PROGRAM
Volume of Materials Dropped-Off Annually
Paint 65%
CITY OF SANTA MONICA
HHW COLLECTION PROGRAM
Materials Reclamation Performance
Reclaim 44%
Corr/Oxid 12%
Batteries 3%
Aerosols 8%
Pesticides 7%
Paint Related 5%
Dispose/Treat 28%
Recycle 28%
174,000 Pounds Annually
3,000 Participants
174,000 Pounds Annually
CITY OF SANTA MONICA
HHW COLLECTION PROGRAM
Materials Reclamation Costs Savings
Total Program Costs $248,767
Cost of Disposal/Treatment/Recycling $56,172
Cost Savings from Reclamation Efforts $44,000
Based on FY 1991-92 Actual Costs
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Identifying Household Hazardous Waste
Deanna Seaman
Environmental Compliance Specialist
Norcal Waste Systems, Inc.
Whether you manage your Household Hazardous Waste (HHW) through a series of one day collection
events, a small hazardous waste storage bin in a small rural community or through a large permanent pro-
gram open multiple days per week in an urban setting, it is important to characterize your waste streams.
I would like to convince you to identify most of the constituents of your waste streams so that your
program can enjoy cost savings from fully knowing exactly what comes into your program and what goes
out either through a jeuse program or on a manifest I will also discuss methods for handling unknown
HHW as well as some commercially available methods for analyzing unknowns in your own lab.
•H
If the waste streams are not properly characterized, incompatible materials could be shipped in the same
drum creating a large potential for a shipping incident. If two incompatible containers open and mix
during shipment, a chemical reaction can take place. Depending on the size of the reaction, this could
create a dangerous and expensive incident. Putting incompatible containers in the same drum also limits
the disposal options available to the Treatment, Storage, and Disposal Facility (TSDF), assuming the
material makes the trip with out incident If an aerosol is in the same drum with some paint and some
flammable solid and if the TSDF chooses not to repack the drum, the only disposal option available, is
destructive incineration because of the aerosol. Another option available to the TSDF is to reject such
.a drum and bill the program for the return and later re-shipping. This means the program which sent the
drum incurs the cost of shipment three times plus the cost of repacking the drum properly and increased
scrutiny from the TSDF. The best way to prevent problems with drum/waste stream constituents is to look
carefully at the drum inventory sheets and pull any incompatible or questionable items for further
identification.
Another reason to fully characterize the program waste streams is to maximize the reuse program: If you
know exactly what comes into your program on a regular basis, then you can target groups or
organizations which would benefit from some of the products your program routinely receives. For
example, if your largest waste stream is organic poison, perhaps you should look at what types of poisons
you get in, the condition of the containers and labels, and see how full the average container is. Once you
have gathered this information, then the list can be distributed .to ornamental horticulture programs or
agricultural schools. I mention these two options because they are fairly safe users; they know how to
apply which pesticide for which type of pest In our programs, we do not put out Extremely Hazardous
or controlled pesticides to minimize liability.
Other groups which could benefit from products in your waste streams include janitorial and cleaning
services which do not use alternative products and pool cleaning services. I mention pool cleaning
services because tiiey can use the calcium hypochlorite which is typically very expensive to ship and treat
or incinerate. By circulating your list of waste stream products to these groups, you make them aware
that your program exists, cut down on your disposal costs, and cut down on the groups' product costs.
Thus the time spent accumulating such data is well spent and can quickly be recouped from the savings
realized through the reuse program.
A word about liability would be appropriate. Liability always exists in these programs simply because
we collect the waste. There are ways to minimize the liability especially in the reuse programs: first is
a product liability waiver, second is handing out instructions for use of a product, for example the
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Roundup™ booklet; and third is to hand out the MSDS with the product when it is available, some ™
programs have even made up generic MSDSs for product categories which serves to minimize liability.
The final reason I will mention to identify your HHW is to properly categorize the containers of "GOK" •
(God Only Knows) that we all get into our programs. These containers of GOK typically make up 1%
of the container volume; so for every one hundred containers, there will be one container of GOK. There •
are a variety of ways to handle unknown containers and if your program accepts them, they must be IB
properly identified to prevent incidents during shipment and to ensure that the selected TSDF can properly
manage the container. ' •
One method to deal with containers of GOK is to send them back with the participant. This option saves
the cost of identifying the container but incurs many risks. Once the participant has been sent back on •
the road with the container of GOK, there is a high probability that the participant will be less than |
pleased and might dispose of it illegally. If your program also manages highway spills, the container has
become your problem once again, but in a manner that puts the public and environment at greater risk for —
exposure than if you had accepted it when the participant first brought it in. Or maybe the participant •
takes the container home and leaves it in the basement for the next generation to deal with. In either
scenario, the program has lost some good will from these participants. So, while little cost is incurred in
dollars, the cost to the environment and community good will is great. I
Once a program has accepted unknown waste, the program can ask its transportation, disposal, or operator
contractor to analyze the waste. This management option costs anywhere from $35-$45 dollars per 8
unknown. The advantages to this option include proper shipment classification and subsequent •
management of the container. The disadvantages include the high cost and the analysts may not be done'
to the level established by the program. ' •
If the above management options seem costly, the program can consider analyzing the unknowns in house.
This is my preferred option because the program, which has all the liability for the waste streams, can •
analyze the unknown to the level which will minimize liability and ensure that the unknown ends up in |
the appropriate hazard class and drum.
Unknown identification doesn't have to be a complicated process. In many cases a program worker can |
quiz the participant about the container. Asking such questions as "What is it, what was it used for, how
long has the container been in the garage?" can yield valuable clues about the container's contents. Many m
times the resident will know what the container holds and save the program and the chemist a lot of work. I
Any information the staff may glean from the participant should be clearly marked on the container with
either a magic marker or a grease pencil. This will decrease the time the program chemist needs to _
identify the waste and place it in a compatible waste stream. I
The time of waste receipt is also a good time to screen participants for businesses, since most variance _
or permit conditions require that no business waste be accepted during hours the program is open to I
residents of the area. A person coming in with paint speckled coveralls, a similarly speckled tarp folding *
back to reveal 70 gallons of paint, and Joe's Painting on the side of the truck, is probably bringing in
waste from the business. Not all business waste, especially waste from Conditionally Exempt Small I
Quantity Generator (CESQG) sources, is as obvious. Large quantities of any one particular waste can be ™
a clue that the waste might be from a business, containers marked "Industrial" or "Professional Use Only"
are typically business waste, and large containers over the five gallon size are typically of business origin. I
Once such a waste has been identified, every effort should be made to provide the generator with disposal •
options because the generator has shown some effort to dispose of the waste properly. It is extremely
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important not to make the process seem insurmountable because we want this waste managed properly.
Some container types give fairly accurate clues about their contents. Photochemicals typically come in
brown plastic jugs and a simple pH test will reveal whether it is developer (pH = 9-11) or a fixer (pH=2-
5). This knowledge will decrease the time the chemist spends on these unknowns. A spray bottle usually
contains a dilute pesticide or a cleaning solution, rectangular metal containers often contain solvents and
sometimes contain concentrated cleaners. A clear container can also reveal information about its contents.
A clear soapy fluid is probably nothing more exotic than soap. Occasionally, a visual check of the
contents will clue the staff that the contents are not what is advertised on the bottle. In this case, the
program really is dealing with an unknown because by that time, the participant is usually long gone.
Bleach bottles are also easy to identify but they usually do not contain bleach when they arrive at a
program site; typically they contain oil. I suggest to our program personnel that they open all bleach
containers to make sure they contain bleach.
There are other instances in which containers should always be opened and checked. When the container
label is torn or missing the container needs identification. If the container is leaking, the contents must
be checked to ensure the waste is not put into an incompatible container; for instance, a hydrocarbon
solvent will eat through most plastic containers. Some times a bottle of HHW must be opened because
the label lists neither the ingredients nor its intended use and thus gives no clue as to the appropriate
hazard class. A good example is Drano. Depending on the formulation the container might be an
inorganic base (product contains lye or sodium hydroxide), an oxidizer (product contains calcium
hypochlorite), or an inorganic acid (product contains hydrochloric acid). In this case a simple pH and
oxidizer test would be enough to pack the container in the appropriate drum.
Another container type which should always be opened is food containers. The chances that a participant
is actually bringing in soda in the soda bottle are slim to zero. Food containers are used for such a wide
variety of products it is difficult to generalize what they might contain when they come through the
program. One caveat is necessary however, participants have been known to bring in the corn relish that
grandmother jarred in the thirties under the assumption that anything which has sat around that long must
be hazardous. It is not necessary to dispose of corn relish as hazardous waste. Many types of products
do not need to be treated as hazardous waste and in the interest of keeping costs down, check with the
local Solid Waste Authority and Publicly Owned Treatment Works to see what products can safely be
disposed in the local landfill or sewer system.
Once you have determined you have an unknown which must be handled as hazardous waste, and you
have decided to handle it in house, there are several methods to analyze unknown wastes. One well
known system is Hazcat™ which is a system designed to analyze spills on the highways. It works best
with pure compounds although with a thorough understanding of the system, can be used for mixtures.
The system uses three charts, one for solids, one for liquids, and yet another for gases. While this system
does work fairly well for pure compounds, for those compounds which are mixtures of many chemicals,
the system tends not to work as well or as rapidly and requires a much more thorough understanding of
the system and the chemistry behind it
Firecat™ is a spin off of Hazcat™ and I have been unable at this point to find any more information
about it except to say that it was designed for use by fire fighters trained in hazardous materials response
and is a quicker version of Hazcat™ with many of the redundancies removed.
Most TDSFs also have some analysis scheme on site for analysis of unknowns. Most of these companies
only analyze the waste to the point they need to adequately characterize the waste for final disposal.
These analysis methods usually include at a minimum; pH test for corrosivity, oxidizer/peroxide tests for
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reactivity, water solubility for flammability (those compounds which are not water soluble are typically •
flammable) or alternatively, a char test, and a metals screen if the waste is slated for treatment or
incineration. •
Sanitary Fill Company, a Norcal Waste Systems, Inc. Subsidiary, developed a waste analysis system called
the Waste Identification and Classification System (WICT™). Based on the waste streams produced at •
the San Francisco Household Hazardous Waste Collection Facility, WICT™ is designed to take an I
unknown container and identify its hazard class and its chemical constituents thereby insuring the
unknown ends up in a compatible waste stream. The system uses many of the same wet chemistry tests M
utilized in the Hazcat™ system but the WICT™ uses only one chart. Depending on the Treatment Storage I
Disposal Facility (TSDF) requirements, the WICT™ can identify upwards of six chemical constituents in
a product by use of six easy wet chemistry tests, draeger tubes, and a set of thirteen reagents in an anion _
and cation chart. The method usually costs about $5.00 per unknown depending on the number of draeger I
tubes used during the analysis (draeger tubes cost about $3.00 apiece.) The advantages to this system are *
its quick and easy steps to determine the waste stream of the unknown; its ability to handle and identify
mixtures; and its acceptance at many of TSDFs in the country. I
What ever system the program uses, it is important to get written approval from the TSDF. If they do
not accept a particular analysis scheme, then as far as they are concerned, the program still has unknowns I
which require special handling. Often it only takes a training session from the program manager to con- M
vince the TSDF personnel that the analysis scheme your program is using adequately characterizes the
waste. •
Finally, to minimize your liability, it is important to characterize your waste stream and identify the
constituents. With this knowledge in hand your program can maximize its reuse program thereby •
minimizing disposal dollars while making sure all containers which are being shipped out as hazardous
waste are in an appropriate drum. With all containers in an appropriate drum the program ensures that
all drums will be accepted by the TSDF and that the TSDF will be able to dispose or treat the program's
waste in a method that will minimize dollars and long term liability.
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SPEECH BY
MR. RJ. BOWEN
PRESIDENT, PRESTONE TECHNOLOGY SYSTEMS, INC.
VICE PRESIDENT, AUTOMOTIVE PRODUCTS DIVISION,
FIRST BRANDS CORPORATION
DANBURY, CONNECTICUT
FOR
U.S. EPA SEVENTH NATIONAL HOUSEHOLD
HAZARDOUS WASTE MANAGEMENT CONFERENCE
DECEMBER 8-12, 1992
MINNEAPOLIS, MINNESOTA
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FIRST BRANDS CORPORATION IS A BILLION DOLLAR
INTERNATIONAL CONSUMER PRODUCTS COMPANY THAT
MARKETS PRESTONE, STP AND SIMONIZ AUTOMOTIVE PRODUCTS,
GLAD AND GLAD-LOCK WRAP AND BAGS AND SCOOP-AWAY CAT
LITTER. THESE WELL-KNOWN AND SUCCESSFUL BRANDS ENJOY
LONG HISTORIES WITH CONSUMERS WHO HAVE COME TO RELY
ON THEIR QUALITY, CONVENIENCE AND DEPENDABILITY.
FIRST BRANDS HAS MAINTAINED THESE BUSINESSES BY
CONTINUALLY MEETING EMERGING CONSUMER NEEDS AND
CLOSELY MONITORING CRITICAL ISSUES THAT COULD IMPACT
THEIR PERFORMANCES. ONE OF THE MOST IMPORTANT ISSUES
OF OUR TIME IS CONCERN FOR THE ENVIRONMENT.
t
ALL OF US IN THIS ROOM TODAY KNOW ENVIRONMENTAL ISSUES
ARE SIGNIFICANTLY IMPACTING CONSUMERS AND THE BUSINESS
COMMUNITY. BY VIEWING ENVIRONMENTAL ISSUES AS
OPPORTUNITIES, FIRST BRANDS HAS FOUND THAT DOING GOOD
FOR THE ENVIRONMENT CAN ALSO BE GOOD FOR BUSINESS.
A GOOD EXAMPLE OF WHERE OUR COMPANY IS PRACTICING THIS
BELIEF IS IN THE AREA OF ANTIFREEZE RECYCLING. PRESTONE
TECHNOLOGY SYSTEMS, INC. IS A SUBSIDIARY FIRST BRANDS
FORMED NEARLY A YEAR AGO TO IMPLEMENT WHAT WE BELIEVE
t
(
—continued—
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ARE THE MOST APPROPRIATE ANSWERS FOR RECYCLING
ANTIFREEZE IN NORTH AMERICA TODAY. BUT BEFORE I OUTLINE
THE SPECIFICS OF WHAT PRESTONE TECHNOLOGY SYSTEMS IS
DOING, I THINK IT WOULD BE HELPFUL TO GIVE YOU SOME
BACKGROUND ON ANTIFREEZE AND ITS PROPERTIES.
THE MAIN INGREDIENT IN PRESTONE ANTIFREEZE, AND INDEED
IN MOST ANTIFREEZE SOLD TODAY, IS ETHYLENE GLYCOL.
ETHYLENE GLYCOL IS TOXIC, BUT IT IS ALSO READILY
BIODEGRADABLE. IT GIVES ANTIFREEZE THE ABILITY TO
PREVENT ENGINES FROM FREEZING DURING COLD WEATHER AND
FROM BOILING OVER IN HOT. PRESTONE ALSO CONTAINS A
PATENTED INHIBITOR PACKAGE TO HELP PROTECT VEHICLE
COOLING SYSTEMS FROM RUST AND CORROSION.
IF LEFT UNCHECKED, THESE CONDITIONS CAN REDUCE A
COOLING SYSTEM'S EFFICDZNCY AND EVENTUALLY LEAD TO
ENGINE FAILURE. IN FACT, MOST ROADSIDE BREAKDOWNS
CAUSED BY COOLING SYSTEM MALFUNCTION ARE DUE TO A LACK
OF REGULAR MAINTENANCE. THIS IS WHY PRESTONE ADVISES
VEHICLE OWNERS TO DRAIN AND REFILL THEIR COOLING
SYSTEMS ONCE A YEAR.
—continued—
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ANTIFREEZE IS AN INVALUABLE FUNCTIONAL FLUID IN A
VEHICLE, AND EVERY YEAR APPROXIMATELY 200 MILLION
GALLONS OF IT ARE SOLD THROUGHOUT NORTH AMERICA. WHEN
THIS ANTIFREEZE IS BLENDED WITH WATER TO INSTALL IN A
VEHICLE, TWICE AS MUCH USED ANTD7REEZE SOLUTION IS
GENERATED, OR ABOUT 400 MILLION GALLONS.
HOW THIS USED MATERIAL IS HANDLED HAS BECOME A GROWING
CONCERN OF CONSUMERS, ENVIRONMENTAL ORGANIZATIONS
AND STATE AND LOCAL GOVERNMENTS. SOME STATES ARE NOW
REVDIWING AND EVEN ENACTING LEGISLATION THAT
SPECIFICALLY ADDRESSES THE HANDLING AND DISPOSAL OF USED
ANTIFREEZE. THEIR CONCERN IS VALID BECAUSE,
UNFORTUNATELY, USED ANTIFREEZE IS OFTEN DISPOSED OF
IMPROPERLY INTO A STORM DRAIN SYSTEM, OR IT'S DRAINED
ONTO THE GROUND OR STREET.
AT FIRST BRANDS, WE BELIEVE USED ANTIFREEZE IS A RESOURCE
TO BE RECYCLED AND NOT A WASTE TO THROW AWAY. FOR THIS
REASON, WE SUPPORT PROPER HANDLING AND DISPOSAL OF USED
ANTD7REEZE BY THE CONSUMER AND, WHEN NECESSARY,
APPROPRIATE LEGISLATION. WE VIEW RECYCLING AS AN
ENVIRONMENTALLY PRACTICAL LONG-TERM ALTERNATIVE TO
IMPROPER DISPOSAL METHODS, BECAUSE RECYCLING:
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- SAVES RESOURCES USED TO PRODUCE NEW ANTIFREEZE;
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- REDUCES THE DEMAND FOR RAW MATERIALS, AND
- HELPS CONTRIBUTE TO THE OVERALL SOLUTIONS OF OUR
COUNTRY'S ENVIRONMENTAL ISSUES
THERE IS AN ISSUE CURRENTLY INFLUENCING THE FUTURE
PROGRESS OF RECYCLING. IT FOCUSES ON HOW USED ANTIFREEZE
MAY CONTAIN CONTAMINANTS, SUCH AS LEAD, WHICH COMES
FROM THE LEAD SOLDER USED IN SOME VEHICLE RADIATORS. IF
THE USED ANTD7REEZE FROM THESE VEHICLES IS DISPOSED OF
IMPROPERLY, IT COULD POSE A THREAT TO THE ENVIRONMENT.
HOWEVER, OUR RESEARCH INDICATES THAT THE LEAD CONTENT
IN USED ANTIFREEZE IS AN ISSUE IN LESS THAN 20 PERCENT OF
THE CASES TODAY. AND, AS MORE AUTOMOBILE
MANUFACTURERS CONVERT TO ALL-ALUMINUM RADIATORS, THIS
PERCENTAGE WILL SIGNIFICANTLY DECREASE OVER TIME.
FURTHERMORE, WE DON'T BELIEVE USED COOLANT DISPOSAL
INFRASTRUCTURE DEVELOPMENT SHOULD BE CENTERED AROUND
THE LEAD-CONTENT ISSUE BECAUSE IT'S NOT THE PRIMARY
LONG-TERM PROBLEM.
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FROM OUR PERSPECTIVE, FIRST BRANDS BELIEVES THIS
SUBJECT TO HAZARDOUS WASTE REGULATION.
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COUNTRY'S SOLID WASTE DISPOSAL CONCERNS CAN BE BEST
ADDRESSED BY RECYCLING USED ANTIFREEZE, REGARDLESS OF I
WHETHER OR NOT THE MATERIAL CONTAINS ENOUGH LEAD TO
CLASSIFY IT AS A HAZARDOUS WASTE. MOREOVER, WE FEEL I
USED ANTIFREEZE THAT1 S DESTINED TO BE RECYCLED SHOULD •
NOT BE CONSIDERED A WASTE, AND THEREFORE SHOULD NOT BE
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WE WOULD RATHER SEE USED ANTIFREEZE BE ALLOWED TO BE I
HANDLED, TRANSPORTED AND RECONDITIONED IN THE MOST •
SAFE, ECONOMICAL AND EFFICIENT MEANS AVAILABLE. WE ™
BELIEVE CLASSIFYING IT AS A HAZARDOUS WASTE WILL DETER I
THE SUCCESSFUL DEVELOPMENT OF A SOUND ANTIFREEZE
RECYCLING INFRASTRUCTURE. |
RESOLVING THIS ISSUE NOW IS IMPORTANT BECAUSE ANTIFREEZE "
RECYCLING IS BECOMING A VIABLE BUSINESS CATEGORY. •
PRESTONE TECHNOLOGY SYSTEMS HAS BEEN IMPLEMENTING ITS
BUSINESS PLAN IN THIS CATEGORY ACCORDING TO FIRST BRANDS' |
BLUEPRINT FOR ANTIFREEZE RECYCLING. IT FOCUSES ON TWO _
METHODS: ON-SITE AND OFF-SITE. •
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THE QN-SITE METHOD ADDRESSES THE AUTOMOTIVE AND HEAVY-
DUTY/FLEET VEHICLE SERVICE MARKETS. THE BLUEPRINT'S OFF-
SITE METHOD ADDRESSES CONSUMER DO-IT-YOURSELFERS. LET'S
TAKE A QUICK LOOK AT THE OFF-SITE METHOD FIRST.
IN THE OFF-SITE METHOD, A CONSUMER DRAINS AND REFILLS
THE VEHICLE'S COOLING SYSTEM AND TAKES THE USED
ANTIFREEZE TO A MUNICIPAL DROP-OFF CENTER LOCATED IN
THE COMMUNITY. AN APPROVED HAULER THEN COLLECTS THE
USED MATERIAL FROM THE DROP-OFF SITE AND TRANSPORTS IT
TO A CENTRALIZED RECYCLING FACILITY.
TO HELP CONSUMERS PARTICIPATE IN THIS METHOD, FIRST
BRANDS SELLS A PATENTED DO-IT-YOURSELF KIT CALLED THE
PRESTONE ANTD7REEZE/COOLANT REPLACEMENT SYSTEM. IT
COMES WITH ALL THE TOOLS NEEDED TO DRAIN AND REFILL THE
COOLING SYSTEM USING AN ORDINARY GARDEN HOSE. AN
IMPORTANT FEATURE OF THE SYSTEM IS ITS FIVE-GALLON
PLASTIC CONTAINER THAT CONSUMERS CAN USE TO
CONVENIENTLY CARRY THE USED ANTIFREEZE TO A DROP-OFF
SITE.
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FOR THE OFF-SITE METHOD TO BE SUCCESSFUL, MUNICIPALITIES
AND RESIDENTS MUST JOINTLY SEEK AND SUPPORT A RECYCLING
PROGRAM. MANY MUNICIPALITIES CURRENTLY RUN OTHER
RECYCLING PROGRAMS, AND WE BELIEVE THESE COULD BE
EASILY EXPANDED TO INCLUDE USED ANTIFREEZE.
TO DEMONSTRATE HOW THE OFF-SITE METHOD WORKS, WE ARE
CURRENTLY OPERATING AN OFF-SITE PILOT PROGRAM THAT
ULTIMATELY WILL INVOLVE MORE THAN FOUR MILLION
RESIDENTS. THE AREAS PARTICIPATING IN THE PROGRAM ARE:
- THE CALIFORNIA COUNTIES OF SAN MATEO AND SANTA CLARA;
- THE CONNECTICUT CITIES OF DANBURY AND NEWTOWN, AND
- THE STATE OF RHODE ISLAND
IN EACH OF THESE REGIONS, WE HAVE SUPPLIED EDUCATIONAL
MATERIALS TO RESIDENTS AND HAVE HELPED MUNICIPAL
OFFICIALS LOCATE DROP-OFF SITES AND ESTABLISH THEIR
ANTIFREEZE RECYCLING PROGRAMS.
THE DATA WE ARE CURRENTLY COLLECTING AND ANALYZING
FROM EACH OF OUR PILOT PROGRAM REGIONS COVERS
COLLECTION RATES, DEMOGRAPHIC INFORMATION AND
CONTAINERIZATION METHODS. EVENTUALLY, WE EXPECT TO
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TABULATE THIS INFORMATION, ANALYZE IT, AND PUBLISH THE
PROGRAM'S RESULTS IN THE FORM OF A WHITE PAPER. THIS
DOCUMENT WILL BE AVAILABLE FOR COMMUNITIES SEEKING TO
ORGANIZE AND OPERATE SUCCESSFUL ANTIFREEZE RECYCLING
PROGRAMS.
IT IS OUR INTENT TO SERVE AS AN ARCHITECT IN THE OFF-SITE
PLAN TO HELP EVENTUALLY CHANGE CONSUMERS' BEHAVIOR
ABOUT THE PROPER HANDLING OF USED ANTIFREEZE. OFF-SITE
ANTIFREEZE RECYCLING CAN SUCCEED, BUT IT WILL REQUIRE
THE ENCOURAGEMENT AND SUPPORT OF MUNICD7ALITDZS AND
CONSUMERS ACROSS NORTH AMERICA.
BUT NOT EVERYONE CHANGES HIS OR HER OWN ANTIFREEZE;
THERE ARE MILLIONS OF CONSUMERS WHO TAKE THEIR VEHICLES
TO AUTOMOTIVE SERVICE CENTERS TO HAVE THE PROCEDURE
DONE. AND, THERE IS ANOTHER LARGE GROUP OF HEAVY-
DUTY/FLEET VEHICLE AND NEW CAR DEALERSHIP OPERATIONS
WHICH HAVE THEIR OWN SPECD7IC NEEDS WHEN IT COMES TO
RECYCLING USED ANTD7REEZE. IN TOTAL, THERE ARE ABOUT
220,000 OUTLETS IN THESE MARKETS. FOR THEM, WE BELIEVE ON-
SITE RECYCLING IS THE BEST ANSWER.
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THE DRIVING FORCES BEHIND OUR SUCCESSFUL ON-SITE EFFORTS
ARE TWO KEY BUSINESS ALLIANCES, WHICH ARE NOW IN PLACE.
THE FIRST IS AN ALLIANCE WITH THE ROBINAIR DIVISION OF SPX
CORPORATION OF MUSKEGON, MICHIGAN. SPX IS A VERY LARGE
INTERNATIONAL COMPANY THAT PRODUCES AND MARKETS
AUTOMOTIVE SERVICE EQUIPMENT THROUGHOUT THE WORLD.
MANY OF YOU MAY KNOW THE COMPANY THROUGH ITS BEAR
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AUTOMOTIVE, KENT MOORE AND OTC DIVISIONS.
SPX IS PRODUCING AND MARKETING A UNIQUE TWO-STAGE, ON-
SITE PRESTONE RECYCLING SYSTEM THAT WAS INVENTED AND
PATENTED BY PTS. AN SPX SUBSIDIARY WILL ALSO MARKET THIS
SYSTEM IN EUROPE. THE SYSTEM IS BEING SOLD UNDER THE
PRESTONE PRO'S CHOICE EQUIPMENT TRADEMARK AND CONSISTS
OF TWO SEPARATE UNITS:
- THE PRESTONE PROFILL COOLANT EXCHANGER, AND
- THE PRESTONE PROCLEAN COOLANT RECYCLER.
THE PRESTONE PROFILL COOLANT EXCHANGER
SIMULTANEOUSLY DRAINS USED ANTIFREEZE FROM A VEHICLE
AND INSTALLS FRESH PRODUCT. THE ADVANTAGES OF THE
PRESTONE PROFILL UNIT ARE:
- IT'S FAST, TAKING ONLY 12-15 MINUTES PER CAR;
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- IT'S EFFICIENT, REMOVING UP TO 95 PERCENT OF THE
COOLANT;
- IT'S ECOLOGICALLY SOUND, BECAUSE IT DOES NOT GENERATE
ADDITIONAL FLUSH WATER, AND
- IT WORKS ON EVERY CAR.
THE COLLECTED USED ANTIFREEZE IS THEN PRETREATED,
RECONDITIONED AND RE-INHD3ITED INTO A FULLY FORMULATED
AND FULLY BUFFERED ANTIFREEZE IN THE PRESTONE PROCLEAN
COOLANT RECYCLER. AFTER THIS PROCESS, THE ANTIFREEZE
CAN BE REUSED IMMEDIATELY IN A VEHICLE.
SEVERAL CRITICAL ADVANCES IN CHEMICAL TECHNOLOGY,
PIONEERED BY PTS, ENABLE OUR PRESTONE RECYCLER TO
PRODUCE HIGH QUALITY RECYCLED ANTIFREEZE THAT MEETS
ALL THE PERFORMANCE STANDARDS OF AMERICAN SOCIETY OF
TESTING AND MATERIALS AND THE SOCIETY OF AUTOMOTIVE
ENGINEERS FOR NEW ANTIFREEZE. IT ALSO MEETS GENERAL
MOTORS' STANDARDS FOR RECYCLED ANTIFREEZE. WE ARE
CURRENTLY MARKETING THIS PATENTED CHEMICAL SYSTEM
UNDER THE PRESTONE PROCHEM TRADEMARK.
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LET ME BRIEFLY EXPLAIN HOW OUR COOLANT RECYCLER WORKS.
THE FIRST STEP INVOLVES CHEMICALLY PRETREATING THE USED
ANTIFREEZE. BY ADDING PRESTONE PRECLEAN CHEMICALS, ALL
CONTAMINANTS AND HEAVY METALS LIKE LEAD ARE TRAPPED INTO
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A SOLID, CLAY-LIKE MASS, WHICH IS NOT HAZARDOUS ACCORDING
TO FEDERAL EPA TEST STANDARDS AND IN MOST CASES CAN
SIMPLY BE DISCARDED.
AFTER THE PRETREATMENT STEP, THE MATERIAL IS RUN
THROUGH A COMPLEX FILTRATION CHAIN TO CLEAN IT FURTHER.
THE THIRD STEP INVOLVES ADDING PATENTED PRESTONE
RECHARGE CHEMICALS TO RE-INHIBIT THE USED ANTIFREEZE.
RE-INHIBITING IS ESSENTIAL TO RESTORING THE RECYCLED
MATERIAL'S RUST AND CORROSION CAPABILITIES TO THOSE OF
NEW ANTIFREEZE. THE PRESTONE ADJUSTER ADDITIVE MAY BE
ADDED AS THE LAST STEP TO HELP BRING THE RECYCLED
ANTIFREEZE'S FREEZE POINT WITHIN RECOMMENDED LEVELS IF
NECESSARY.
IMPORTANT TO THE SUCCESS OF THIS PROCESS IS THE PATENTED
CUSTOM RE-INHIBITOR PACKAGE. IT HAS PLAYED A LEADING
ROLE IN THE ADVANCEMENT OF OUR BUSINESS. FOR YEARS OUR
INDUSTRY WAS UNABLE TO FORMULATE A CUSTOM CHEMICAL
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ADDITIVE PACKAGE THAT COULD RE-INHIBIT ALL THE WIDELY
• VARYING CONDITIONS OF USED ANTIFREEZE FOUND FROM
VEHICLE TO VEHICLE.
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- THE CUSTOM CHEMICAL RE-INHIBITOR PACKAGE WE DEVELOPED
* EFFECTIVELY ADDRESSES THIS NEED BY ENABLING ALL
• RECYCLED ANTIFREEZE TO MEET INDUSTRY CORROSION AND
RUST PROTECTION PERFORMANCE STANDARDS FOR FRESH
| PRODUCT. THESE INCLUDE STANDARDS SET BY THE SAE AND
m ASTM. IN ADDITION, OUR RE-INHIBITOR PACKAGE IS EFFECTIVE
" WITHOUT USING NITRITES, WHICH CAN BE HARMFUL.
AS I SAID EARLIER, ANTIFREEZE RECYCLING TECHNOLOGY IS
| . CURRENTLY OFFERED BY SEVERAL OTHER COMPANIES. BUT
GENERAL MOTORS HAS ONLY LENT ITS ENDORSEMENT TO SEVEN
• ON-SITE RECYCLING SYSTEMS, AND WE'RE PROUD TO BE THE RE-
• INHIBITOR SUPPLER TO THE MAJORITY OF THEM. WE ARE ALSO
WORKING CLOSELY WITH OTHER ORIGINAL EQUIPMENT
I MANUFACTURERS AS THEY DEVELOP AND EVALUATE THEIR OWN
STANDARDS FOR RECYCLED ANTIFREEZE.
• OUR RE-INHIBITOR PACKAGE AND PRESTONE RECYCLING SYSTEM
SERVE AS THE CORE OF PRESTONE TECHNOLOGY SYSTEMS' ON-
| SITE ANTIFREEZE RECYCLING BUSINESS.
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ADDITIONALLY, WE WILL SUPPLY OUR CUSTOM RE-INHIBITOR
PACKAGES TO OTHER SELECT RECYCLING EQUIPMENT
COMPANIES; HOWEVER, WE WILL ONLY SUPPLY COMPANIES
USING ANTIFREEZE RECYCLING METHODS THAT MEET OUR
STRICT REQUIREMENTS.
HOW IS OUR SYSTEM DIFFERENT FROM THE OTHERS? BESIDES
THE CHEMICAL PRETREATMENT AND THE CUSTOM RE-INHIBITING
FEATURE, THE PRESTONE RECYCLING SYSTEM IS A TOTAL
SYSTEM THAT OFFERS AN EFFECTIVE AND EFFICIENT METHOD OF
REMOVAL OF USED ANTIFREEZE FROM THE VEHICLE, AS WELL AS
A CONSISTENT, STABLE AND BUFFERED PRODUCT THAT EXCEEDS
ALL INDUSTRY PERFORMANCE STANDARDS.
ANOTHER INNOVATION IN OUR ON-SITE RECYCLING BUSINESS
ACTIVITY IS REPRESENTED BY MOBILE ANTIFREEZE RECYCLING.
THIS IS A RESULT OF AN AGREEMENT BETWEEN PRESTONE
TECHNOLOGY SYSTEMS AND AMERICAN FLUID TECHNOLOGY.
MOBILE RECYCLING IS A NEW AND EXCITING DIMENSION IN ON-
SITE ANTIFREEZE RECYCLING. MORE THAN 50 MOBILE
ANTIFREEZE RECYCLING FRANCHISE TERRITORIES HAVE
ALREADY BEEN SOLD AND WE ANTICIPATE THAT THIS NUMBER
WILL INCREASE SIGNIFICANTLY IN THE NEXT YEAR.
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THE FRANCHISES CONSIST OF MOBILE ANTIFREEZE RECYCLING
VANS OPERATING UNDER THE PRESTONE AND AFT BRAND NAMES.
THE VANS FEATURE PRESTONE RECYCLING EQUIPMENT AND
EXCLUSIVELY USE THE PRESTONE RECYCLING INHIBITOR
FORMULAS THAT ARE SIMILAR TO THOSE I DISCUSSED EARLIER.
THIS RECYCLING TECHNOLOGY IS OWNED BY PTS AND FEATURES
AN EXCLUSIVE CENTRD7UGE PROCESS. EACH VAN CAN RECYCLE
UP TO 300 GALLONS OF USED ANTIFREEZE ON SITE EVERY HOUR
AT A COMMERCIAL FACILITY, RETURNING TO THE CUSTOMER A
FULLY RECYCLED PRODUCT THAT EXCEEDS INDUSTRY
PERFORMANCE STANDARDS AND IS READY FOR REUSE.
FOR COMMERCIAL AUTOMOTIVE SERVICE FACILITIES THAT
COLLECT ANTIFREEZE BUT DON'T EMPLOY ON-SITE EQUIPMENT,
RECYCLING THEIR COLLECTED MATERIAL IS AS EASY AS PICKING
UP THE PHONE AND CALLING THE NEAREST FRANCHISE SERVICE.
THE FRANCHISES OFFER SERVICE FACILITIES MANY UNIQUE
ADVANTAGES:
- THEY DO NOT REQUIRE CAPITAL INVESTMENT;
- THERE ARE NO EXPENDITURES FOR LABOR AND MAINTENANCE;
- THE ON-SITE SYSTEM REDUCES DISPOSABLE WASTE BY UP TO 99
PERCENT, AND
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- THE RECYCLED ANTIFREEZE PRODUCED IS GUARANTEED TO
EXCEED ALL INDUSTRY PERFORMANCE STANDARDS FOR NEW
PRODUCT.
PRESTONE TECHNOLOGY SYSTEMS IS RAPIDLY MOVING FORWARD
IN ITS EFFORT TO HELP MAKE ANTIFREEZE RECYCLING A
WIDESPREAD PRACTICE THROUGHOUT NORTH AMERICA. THE
RESULTS SO FAR ARE ENCOURAGING;
- ORDERS ARE CONTINUING TO COME IN FOR OUR ON-SITE
SYSTEM;
- THE MOBILE RECYCLING FRANCHISES ARE GROWING IN
NUMBER EVERY MONTH, AND
- OUR PILOT PROGRAM ACTIVITIES ARE INSTILLING THE
CONCEPT OF ANTIFREEZE RECYCLING AND HELPING TO CHANGE
CONSUMER BEHAVIOR.
WE BELIEVE THAT, WHEN IT COMES TO SOLID WASTE DISPOSAL
ISSUES, THE BUSINESS COMMUNITY HAS THE RESOURCES TO
IDENTDjY AND DEVELOP REAL SOLUTIONS. THE RECENT
TECHNICAL AND BUSINESS ACHIEVEMENTS OF PRESTONE
TECHNOLOGY SYSTEMS PORTRAY HOW THIS PHILOSOPHY CAN BE
PUT TO WORK ON A PRACTICAL SCALE. WE HAVE TAKEN A
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LEADERSHIP ROLE IN ANTIFREEZE RECYCLING AND CAN SAY
WITH PRIDE THAT IT IS BENEFITING THE ENVIRONMENT, WHILE
ALSO SERVING AS AN INNOVATIVE CATALYST FOR ECONOMIC
GROWTH.
I APPRECIATE YOUR ATTENTION THIS MORNING. IF ANYONE HAS
QUESTIONS, I WOULD BE HAPPY TO ANSWER THEM FOR YOU AT
THIS TIME...
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LOAD INSPECTION - HOW TO TRAIN EMPLOYEES
Kathy Kendall-Witkovski
Waste Management Administrator
Des Moines Metropolitan Area Solid Waste Agency
Des Moines, Iowa
1.
Introduction
Recently, 40 CFR Subpart C, Parts 257 and 258 were
finally published September 11, 1991 in the Federal
Register. The proposed rule was published in August, 1988
and every state with the exception of a few were drafted
changes in landfill operations that would meet the proposed
criteria. The rule we more commonly know as "Subtitle D".
The portion of the rule I propose to discuss today is:
258.20 Procedures for excluding the receipt
of hazardous waste.
(a) Owners or operators of all MSWLF units must
implement a program at the facility for detecting and
preventing the disposal of regulated hazardous wastes as
defined in Part 261 of this title and polychlorinated
biphenyls (PCB) wastes as defined in Part 761 of this title.
This program must include, at a minimum:
(1) Random inspections of incoming loads unless
the owner or operator takes other steps to ensure that
incoming loads do not contain regulated hazardous wastes or
PCB wastes;
(2) Records of any inspections;
(3) Training of facility personnel to recognize
regulated hazardous waste and PCB wastes; and
(4) Notification of state Director of authorized
States under Subtitle C of RCRA or the EPA Regional
Administrator if in an unauthorized State if a regulated
hazardous waste or PCB waste is discovered at the facility.
(b) For purposes of this section, regulated hazardous
waste means a solid waste that is a hazardous waste, as
defined in 40 CFR 261.3, that is not excluded from
regulation as a hazardous waste under 40 CFR 261.4(b) or was
not generated by a conditionally exempt, small quantity
generator as defined in §261.f of this title.
1.1 How to Get Started
The Des Moines Metropolitan Area Solid Waste Agency
recognized early that the rule would be final in the near
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future. Requests had also been made by our union landfill
employees to provide some hazardous waste and first aid
training through their Union Contract. Since the Agency has
worked for the past several years with the HazMat Team and
the Des Moines Fire Department, we contacted the HazMat
Specialist to see if he could provide the training program.
The Specialist agreed to provide the training over a four-
hour period.
Subtitle D was still in the proposed stages so that
authorization for training fell under SARA Title I,. §126
which states that employees must train the employees with
regard to chemical releases. Our employees were told' that
their training would only cover the "First Responder
Awareness Level".
Under the awareness level, they may:
1.
2.
3.
Why?
DISCOVER A RELEASE;
MAKE NOTIFICATION; and
TAKE NO OTHER ACTION EXCEPT TO MOVE TO A SAFE
AREA.
1. NO PROTECTION (PROTECTIVE CLOTHING); and
2. AVOID CONTACT OF EXPOSURE.
First responders at the awareness level are individuals.
who are likely to witness or discover a hazardous substance
release and who have been trained to initiate an emergency
response sequence by notifying the proper authorities of the
release. They would take no further action beyond notifying
the authorities of the release. First responders at the
awareness level shall have sufficient training or have had
sufficient experience to objectively demonstrate competency
in the following areas:
2.1 An understanding of what hazardous materials are
and the risks associated with them in an accident.
2.2 An understanding of the potential outcomes
associated with an emergency created when hazardous
materials are present.
2.3 The ability to recognize the presence of hazardous
materials in an emergency.
2.4 The ability to identify the hazardous materials,
if possible.
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2_.,5 An understanding of the role of the first
responder awareness individual in the employer's emergency
response plan including site security and control and the
United States Department of Transportation's Emergency
Response Guidebook.
2.6 The ability to realize the need for additional
resources and to make appropriate notifications to the
communication center.
3. First Responder Operations Level
First responders at the operations level are
individuals who respond to releases or potential releases of
hazardous substances as part of the initial response to the
site for the purpose of protecting nearby persons, property,
or the environment from the effects of the release. They
are trained to respond in a defensive fashion without
actually trying to stop the release. Their function is to
contain the release from a safe distance, keep it from
spreading, and prevent exposures. First responders at the
operations level shall have received at least 8 hours of
training or have had sufficient experience to objectively
demonstrate competency in the following areas in addition to
those listed for the awareness level-and the employer shall
so certify:
3.1 Knowledge of the basic hazard and .risk assessment
techniques.
3.2 Know how to select and use\ personal protective
equipment provided to the first responder operations level.
3.3 An understanding of basic hazardous materials
terms.
3.4 Know how to perform basic control, containment
and/or confinement operations within the capabilities of the
resources and personal protective equipment available with
their unit.
3.5 Know how to implement basic decontamination
procedures.
3.6 An understanding of the relevant standard
operating procedures and termination procedures.
4.
What are Hazardous Materials?
A general definition of a hazardous material is any
substance that jumps out of its container at you when
something goes wrong and hurts or harms the things it
touches or impinges upon.
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The General Department of Transportation
classifications and examples are listed in Table I below,
GENERAL CHARACTERISTICS AND EXAMPLES OF
HAZARDOUS MATERIALS
GENERAL CATEGORY
DOT CLASSIFICATIONS
Eiploalv**
Class A Explosive
Class B Explosive
Class C Explosive
Blasting Agents
Compr»»»»d Qttta
Flammable Gas
Nonflammable Gas.
Special Forma •
Liquified
Cryogenic
Gas in solution
Flammable Liquid*
Pyrophonc Liquids
.Flammable Liquids
Combustible Liquid
Flammable Solid*
Flammable Solid
Water Reactive
• Spontaneously
Combustible
Oiidlzlng Material*
Ond'jer
Organic Peroxide
Pol*onou» Material*
Class A Poison
Class B Poison
Imiant
Eliologic Agent
Radioactive Material!
Radioactive >
Radioactive II
Radioactive HI
Corrottve Material*
Corrosive
Olhar
ORW A
ORM8
OFIMC
ORM D
ORME
EXAMPLES
Dynamite. TNT. Slack Powder
Propeilant Powders. Rocket Motors
Common Fireworks. Small Arms
Ammunition
Nilro Carbo Nitrate
Acetylene, Butane. Hydrogen. Propane
Carbon Dioxide. Sulfur Dioxide
Butane. LNG. Nitrogen. Propane
Ethyiene. Hydrogen. Nitrogen
Acetylene
Aluminum Alkyls; Alkyl Soranes
Acetone. Gasoline. Methyl Alcohol
Fuel Oil. Sloddard Solvent
Magnesium. Titanium
Calcium Carbide. Sodium Hydride
Phosphorus. Sodium, Potassium
Lithium Peroxide
• Beozoyt Peroxide. Peracetic Acid
Arsine, Hydrocyanic Acid. Phosgene
Aniline. Arsenic. Methyl Bromide
Tear Gas. x/yi Bromide
Anthrax, Botulism. Rabies. Tetnus
Plutonium. Cobalt. Uranium.
Uranium Hexafluonde
AGIOS — Hyflrocnlone Acid. Oleum
Sulfunc Acid
Bases - Caustic Soda. Caustic Potash
Dry Ice. Carbon Tetrachlonde
Quicklime. Metallic Mercury
Battery Pans. Bleaching Powder
Consumer Commodities
Hazardous Substances and Wastes
GENERAL HAZARDOUS PROPERTIES
Sensitive to heal and shock •
Contamination could cause explosion
Thermal and mechanical impact
BLEVE potential
Flammability hazard
Liquified gases - cold temperatures -
frostbite — expansion ratio high
Flammabiltty
Explosion potention
BLEVE
Vapor'air
Potentially corrosive, toxic
thermally unstable
Readily ignite and bum explosively.
some spontaneously
Water reactive potentials
Tone and corrosive potentials
Supply oxygen to support combustion of
normally nonflammable materials
Explosively sensitive to heat, shock.
fnction
Potentially toxic
Harm from inhalation, ingestion.
absorption
Fiammabi'ity potential
Harm - internal and external
Contaminates -
Immediate area
Smoke, clothing, water •
Harm - disintegration ol tissues.
external
Ox id .zing effect
Splatte- potential
Nomous
Corrosive
5.
Detection of a Hazardous Material
There are six sets of clues in detecting a hazardous
waste. Those clues are as follows:
Occupancy and Location - where did the truck come from,
i.e., hospital, manufacturing
plant, etc?
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Container Shape -
Markings and Colors -
Placards and Labels -
Shipping.Papers -
Senses -
drums, cylinders, canisters,
lead boxes
some companies color code
their containers, i.e., red
(flammable) and yellow
(corrosive)
poison, flammable liquids,
corrosive (see Attachment 1)
manifests
hear hissing noises, see
vapors, feel cold sensations,
smell odors
Under the six sets of clues, the risk to the employee
runs from low (at #1) to high (at #6) . The closer the
employee gets to a substance for identification, the higher
the risk of contamination.
5.1 There are•three words affixed to certain labels
which can assist your staff in determining a hazardous
waste. Those are:
CAUTION - Mildly toxic . .
WARNING - Moderately toxic
DANGER - Highly toxic
Department of Transportation's Emergency Response
Guidebook
We at the Des Moines Metropolitan Area Solid Waste
Agency felt it was important for our employees to learn how
to use the DOT Emergency Response Guidebook. If they are
close enough to read a label and ingredients, the Guidebook
can help them understand the hazards. It will also give
information for evacuation and isolation for not only
employee protection but also for haulers and the general
public. Each of our trained employees has a personal
pocket-size Guidebook for his/her use plus an additional
Guidebook in the possession of the working foreman and
another at the main shop.
Some of the new placards are color coded, either in a
bar code or a diamond shape:
/*~\s FLAMMABLE
/ X
/ RED
HEALTH
REACTIVE
SPECIAL
INFORMATION
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7 .
Steps to Follow after a Hazardous Substance is
Discovered . /
Detect
t
Identify
t
Follow Safety Plan or Leave the Area
(upwind, uphill, safe distance)
I
Isolate Area
t
Notify Proper Authorities
(Call 911)
7.1 Your Safety Plan Should Include the Following;
1. Who is in charge?
2. What evacuation-procedures must you follow?
3. Who will provide the waste identification
information?
4. How will you isolate the area?
Your safety plan should also include telephone numbers
of fire protection, police protection, local.HazMat team,
and the closest emergency hospital to the site. Also, you
should make sure that all of these agencies are aware of
your plan and know how they will work with you.
7.2 Waste Identification Form
You need to develop a form to gather information to
help identify your waste. Those forms .may include, but are
not limited to, some of the 'following:
Container size_
Label
Container shape_
Active ingredients
Manufacturer name
Shipping information_
Liquid /Sol id_
Color
Odor observed, if any
Vapors identified
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All of this information may help your HazMat team or
fire protection specialist identify the waste and provide
you with information for safety.
8.
Conclusion
I am not sure that the specific training provided for
our landfill and transfer station employees was the extent
and intent of the Environmental Protection Agency in
§258.20. However, I do feel that we have offered a level of
protection for our employees and the public and private
sectors that utilize the landfill and transfer station as
well as keep hazardous wastes out.
After our training this summer, our sense of smell
detected a strong solvent odor emanating from several drums
of paint sludge which had been approved for disposal based
on the TCLP analysis. Upon further investigation, it was
determined that the drums did not meet the specifications
the company had noted. We have now developed a disposal
process with this company prior to any additional acceptance
of their paint sludge.
For us, the program and training has proved invaluable;
and we shall continue to expand and elaborate in areas where
needed. Perhaps more training programs will be made
available by the State or Federal Governments that
specifically address this portion of the Rule.
In addition, the Des Moines Metropolitan Area Solid
Waste Agency operates a special waste authorization program
in conjunction with the Iowa Department of Natural
Resources' program. I have the opportunity to' review TCLP
tests, MSDS sheets, and letters containing knowledge of
process from our commercial and industrial-manufacturers.
We can accept, reject, or require special handling of any
specialized waste at our facility.
9.
other Programs in Other States
There are several load inspection programs effectively
operating in other states. For example, Ada County, Idaho,
under the direction of David Neal, has developed a program
that pulls household hazardous wastes from their load
inspection program. In one week they may recover 150
gallons of latex paint, 20-30 gallons of oil based paint, 15
gallons of solvents and thinners, 15 gallons of general
household hazardous waste, and 40 lead acid batteries. Once
a year, they have a household hazardous waste cleanup day,
much like our annual Toxic Cleanup Day. A local paint
manufacturer blends the latex paints for reuse, and they are
working to blend the oil based paint as well. Training for
Mr. Meal's staff was conducted through an EPA 40-hour
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course. The course is entitled "Hazardous Materials
Incident Response/Personal Protection and Safety". A well
thought of recommendation"from David Neal was to have your
inspection staff undergo vaccination for Hepatitis B and
have regular Tetanus shots.
Daytona Beach, Florida, under the.direction of Linda
Lee Anderson, has solicited the cooperation of area waste
haulers to provide stickers on trash cans indicating "Your
refuse service cannot take pollutants". There is a
telephone number listed for individuals to call for
information on proper disposal of their unacceptable
materials.
In California, under the Amendments to Title 23 of the
California Code of Regulations, solid waste disposal
facilities are required to implement a periodic load
checking program. The essential elements of the program
very closely follow §258.20 of Subtitle D. This program is
more closely aligned to the intent of the Federal Rule.
As we all embark into a load inspection program, we
need to keep two things in mind: 1) the program should be
designed to further eliminate the potential for further
environmental pollution entering landfills; and 2) the
program should be designed to protect the health, safety,
and welfare of employees and the public. Hopefully, we can
share these experiences with others.
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Household Hazardous Waste Budgeting: From One-days to Permanent Facilities
t
Rachel Rosenzweig
Household Hazardous Waste Manager
Lancaster County Solid Waste Management Authority
1299 Harrisburg Pike Lancaster, PA 17604 (717)397-9968
When planning a Household Hazardous Waste (HHW) program, whether it be for a one-day event, a B
mobile program or a fixed facility, the key component is just that: planning. Any HHW program
developer, coordinator or manager will tell anyone who is thinking of sponsoring an HHW program that •
planning is paramount to a successful program. And one very important aspect of having a successful 0
program is having the sufficient funding to pay for everything you want to accomplish. As it is said, "if
you've got the money, we've got the goods". The following information may be used as a basic guideline .•
to most of the expenditures that will be incurred for an HHW program. Whether you do a one-day per J
year program or have a five-day per week fixed facility, there are certain costs that will be common to
all HHW programs. Some of these include the following: g
1. Development costs:
Before you take in your first can of paint or first jar of Malathion you have to have a program that can _
properly manage such items. For entities that choose to develop either mobile or permanent facilities, they •
will likely incur the costs of consultants and engineers. They will work with you on developing both an
Operational Plan under which the program will run, as well as design a facility that will properly house _
stored materials until they are handled by a licensed hazardous waste hauler. In addition, there will also I
be legal fees to consider as RFQs and RFPs are drawn up to choose the most qualified vendor to handle '
materials collected. While these costs are generally not part of an annual HHW budget, they have to come
from somewhere, so make sure you've got the funds set aside. I
2. Waste Management costs;
This category will more than likely be the costliest item on your annual budget. It is not uncommon for •
waste management costs to range from $50,000 to $200,000 whether it be a one-day, mobile or permanent m
program. These costs will be directly related to the number of participants served and what they bring
in. For example, out of a budget of approximately $326,000 for the Lancaster County Solid Waste •
Management Authority's (LCSWMA) permanent HHW Facility, $200,000 is dedicated to covering I
disposal costs which equates to 61% of our budget. These costs can oftentimes be directly related to
publicity efforts. The more money dedicated towards publicizing the program, the more people will •
respond, which will result in more materials needing to be properly managed, resulting in more money |
needing to be spent.
3. Publicity; £
For one-day programs in particular, publicizing in the newspaper, on the radio and TV, and with flyers
and posters are some of the more popular ways of getting the word out. Additional publicity methods •
include inserting information into tax or utility bills, or paychecks (if a company will agree to it), getting •
into the schools and sending flyers home with the kids, etc. For permanent programs, incorporating the
program's pertinent information such as days and hours of operation, materials accepted and not accepted, _
etc. can be included in the overall information package of environmental management developed by the I
sponsoring agency, as well as advertising in newspaper ads and articles; TV PSAs; disseminating '
information at town and environmental fairs; public presentations; etc. Mobile programs will want to
combine both one-day and permanent program publicity efforts as they are somewhat of a "permanent •
program on wheels". •
4. Staffing; I
Another key area to budget for is staffing. For one-day programs, it is not unusual to have a score of •
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volunteers helping out by directing traffic, giving participants questionnaires, etc., jobs that do not require
technical expertise. Fortunately for the organizers, these much needed people don't get paid and are
usually glad to help out. A few slices of pizza and some sodas generally help keep everybody happy.
Staffing costs for one-day programs are usually the labor costs of the hazardous waste hauling company's
staff and these costs are usually included in the total disposal fee or as a separate set-up and tear-down
fee. For permanent programs, staffing costs will vary according to the number of staff employed at the
facility, as well as the number of days per week the facility is operational. For example, LCSWMA's
sfacility is open five (5) days per week, two (2) evenings per week and two (2) Saturdays per month, which
'has resulted in the need to budget for a minimum of 7.5 hours of overtime each week. In addition, with
'permanent programs that have a full-time staff, benefits must also be taken into account Included are
items such as worker's comp, insurance, hpspitalization, pension contributions, physicals, as well as a
clothing allowance and uniforms. Out of our annual HHW budget, total costs for two (2) full-time
employees run about 31% of our budget Mobile facility programs that employ their own staff should take
into consideration the same costs as a permanent program.
Training for staff must also be considered, as it is imperative to have trained employees handling
materials. LCSWMA incorporates both initial, as well as annual update training into the contract held
with the hazardous waste vendor. If this is not feasible, there are training courses which generally run
in the hundreds of dollars, available for hazardous waste site workers.
5. Siting for a One-day Program:
If hosting a one-day program, the sponsoring agency will want to obtain a site that is large enough to
accommodate the event and relatively central to the overall area being served. Some possibilities are
county-owned properties, such as parks and fire training schools, and school parking lots. However, these
sites may not be free .of charge and their costs must be taken into consideration when budgeting. For
example, the County Fire School in Mercer County, NJ charges the Mercer County Improvement
Authority $750 per clean-up event to use its site. In addition, any site used, whether for a one-day, mobile
or permanent program, may require additional insurance and/or permits, which often have associated fees.
Each state agency will have its own rules and regulations to abide by.
•6. Developing a Mobile or Permanent Facility:
^Permanent programs are usually situated in a building or structure dedicated to HHW. Therefore, whether
for a new or retrofitted building, certain aspects have to be considered along with their associated costs.
Included are:
s
1. Consultants' or Engineering costs
2. Construction costs, which may include the following items: ,
• main storage areas (either pre-fab buildings or concrete block walls) '
• fire-suppression system
• ventilation equipment (heating, air supply/exhaust, fume hood)
• explosion-proof lighting
* blast-relief panels
• smoke detection units
• three-hour fire-rated walls and fire doors
• shower and eye-wash station(s) .
• epoxy flooring
» painting
• containment units/bays and grating
« extra drum storage area
• waste oil handling area
• trash/waste disposal costs
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• lab area for unknowns testing
• office space
• employee locker room and restrooms
• security system (fencing, alarms, etc.)
When considering the purchase of either prefabricated buildings or the construction of a permanent facility,
the costs per square foot can range from the low end of $22 for modified trailers to over $250 per square
foot for some fixed facilities. While these figures would be considered part of the capital costs and
therefore amortized over the life of a program, they must be considered in budgeting for a HHW program.
7. Capital costs:
While one-day HHW programs have no actual capital costs, there are certain items that can be amortized
over the life of the program for either a mobile or permanent program. The largest cost will obviously
be the mobile unit(s) or fixed facility that is utilized or constructed. Other items such as work tables,
chairs, push carts, drum dollies, pallet jacks, a paint can crushing machine, a Self Contained Breathing
Apparatus (SCBA), a dumpster, reference materials, storage cabinets, shelving units, grounding rods and
cables, step ladders and lab equipment are some of the more common items that are considered to be
capital costs.
8. Supplies and Equipment:
This category, unlike capital costs, include those items that have an ongoing need to be replenished. It
is important to have sufficient quantities of such supplies "on hand as they are often used on a daily basis.
Some of the more common items needed for any HHW program whether it be for a mobile or permanent
program include the following:
A. Safety supplies:
* tyvek suits
* respirators and cartridges
• gloves (nitrite and leather)
• first aid and burn kits
boots
safety glasses/goggles
fire extinguishers
gas meter (optional)
• mercury spill kit
• clean rags
B. Spill clean-up/containment:
• absorbent
• booms/spill pads
• plastic for walls and floor covering
• plastic bags for leaking containers (various sizes)
C. Containers:
• empty drums (various sizes) and labels
• containment/sample jars (various sizes)
• 5-gallon buckets wi(h lids for battery disposal
• overpack drums and oversized "dish" bins for leaking containers
• QC rods
• barricade tape
• pallets/plywood
D. Tools and Operating Equipment:
• brooms, shovel, dust pan
• consolidation funnels for drums
• pH paper/chlor-d-tect kits
• duct tape (!!!)
• various tools: screwdrivers, pliers, drum wrench, hammer, scoops, spatulas/spoonalas
E. Office Supplies:
• clipboards and pens
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* copying capabilities for forms and/or questionnaires
• marker pens for writing on steel drums
F. Other:
* clock
• HHW wheels/public information sheets and handouts
i» signs for doors and walls, interior and exterior of facility
•i**
rActual costs;
When all of the costs to hosting an HHW program are added together, their total costs are high when
compared to "regular MSW" waste management practices. In fact, the cost per participant may also seem
quite high. For example, LCSWMA's cost per household serviced in 1991 was almost $100 based on our
actual operating expenses of $227,000 and just under 2,300 participants serviced. On the whole, this
figure seems to be evolving into the national average of cost per participant whether for one-day or
permanent programs. While it was initially anticipated that permanent programs would lower costs per
participant over time, it appears that they .actually cost about the same as a one-day program per
participant However, it is hoped that as participants make return visits to permanent HHW facilities with
less material per visit, costs (mainly those for disposal) will go down. It should also be kept in mind that
for their costs, permanent programs, unlike one-day events, provide ongoing availability to the public.
When planning an HHW program, another one of the key elements is to estimate the number of
participants that will be serviced annually by the amount of material anticipated to be received. By using
the national average of serving approximately 2% - 5% of an area's population and with each participant
bringing in approximately 100 Ibs. of HHW, the budgeting process for the amount of space needed, the
number of staff to be employed, as well as the amount of supplies and equipment required can be
determined more easily. In addition, publicity efforts will also be directly related to the anticipated cost
per participant serviced and the actual amount of funding you have available to you. For example, if you
discover that your funding will exceed anticipated costs, you might be able to allocate a bit more to
publicity efforts, which will in turn affect both your participation rates, as well as your waste management
practices and costs.
Cost reduction efforts:
In an effort to reduce the expenses associated with the various methods and costs of waste management
for HHW, which include incineration, landfilling, neutralization and wastewater treatment, some
communities have ambitiously initiated waste reduction efforts in the form of waste exchanges. For
example, the City of Santa Monica, CA has reduced the amount of materials being handled by their
hazardous waste vendor by 40 %. Recycling certain items such as used motor oil, antifreeze, lead-acid
batteries and Ni-cad and buttoncell household batteries is another simple way to reduce disposal costs.
Quite.a few communities on the West Coast have found recycling outlets for both their waste oil-based
and latex paint streams and give the refurbished paint to anti-graffiti groups or other non-profit groups.
A few HHW programs have begun using aerosol can puncturing units to empty the contents of partially
full cans, which has not only resulted in the savings of quite a lot of money when compared to their
previous method of disposal, but also created a revenue in their ferrous metal value. For example,
LCSWMA's permanent HHW program has incorporated the use of such a unit and now pays only $115
to dispose of the contents of 3 to 4 55-gallon drums which would have cost $495 a piece to dispose of
"the old way".
In summation, an HHW program can run the gamut of possible costs, from the low of just a few thousand
dollars for specialized clean-ups such as an "oil-only" clean-up day to managing a million dollar plus
budget. Either way, the most important fact to consider is the need to plan and develop both a program
and a budget that will fit your community's needs and abilities.
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Workshop 4-A - How To's
Funding Via EPA's Enforcement Efforts
Brian Rimar, U.S. EPA Region VIII
* Much of the information contained in this presentation is found
in "Pollution Prevention Through Compliance arid Enforcement",
available from the U.S. Environmental Protection Agency (EPA)
Office of Pesticides and Toxic Substances, (202) 260-3807.
* History
- In 1990 Congress passed the Pollution Prevention Act,
calling for pollution prevention (P2) to be a national objective.
- The EPA Office of Enforcement has issued a policy
statement which encourages compliance and enforcement programs to
use the settlement process to identify and implement P2
activities.
* Process
- EPA can require the violator to use P2 to redress the
original violation or to include supplemental environmental
projects (SEP's), previously called environmentally beneficial
expenditures.
- Violations and penalties can fall under a variety of
environmental statutes; CERCLA, EPCRA, RCRA, CWA, SDWA, FIFRA,
TSCA, SARA, etc.
- As part of a settlement agreement a defendant might agree
to conduct a project which reduces risks posed to human health
and the environment.
- Many agreements with SEP's include a change of industrial
process or a material substitution. However, the acceptable
range of SEP's is widening to include P2 programs such as
household hazardous waste (HHW) collections, HHW reprocessing,
and HHW education programs.
* Case Studies
- Longmont Foods Inc. of Colorado will be sending the solid
waste from their slaughter house to a bio-gas project rather than
a landfill, under a SEP.
- City and County of Denver, Colorado, will fund a HHW
education program and partially fund start-up costs for a paint.
reprocessing facility. This SEP was funded by fines from a
CERCLA consent decree violation.
- Disneyland of California instituted waste minimization
measures and educated their employees on hazardous waste
reduction following a RCRA violation.
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* How To Access SEP's
- Most of the EPA regional offices have a Regional
Enforcement Officer and/or a database of current enforcement
actions under all statutes. This information may provide
enforcement cases where SEP's would be appropriate.
— - If you are familiar with a particular enforcement case,
work with the EPA project manager or compliance officer to
encourage a SEP. In some EPA programs a SEP counts as an extra
I'bean" for the EPA employee.
- Make the SEP easy for the EPA. Many project officers are
not familiar with the details of a HHW project, don't expect them
to do the leg-work to initiate a program.
- Realize the limitations of SEP's. Some enforcement
actions may not be appropriate for this program. Attorneys from
both EPA and the Department of Justice may not be familiar with
the program, work with them on potential projects.
- Don't forget to promote the positive benefits of a SEP,
such as good media coverage for the violator, or increased
cooperation between EPA and local governments.
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>F STATE ENFORCI
by
Judi Frantz
California Environmental Protection Agency
Department of Toxic Substances Control
When hazardous waste facilities are found to be out of
compliance with governing laws and regulations, the responsible
regulatory agency has several options for obtaining compliance.
When the hazardous waste .facility happens to be a household
hazardous waste (HHW) facility, it can put the responsible
regulatory agency in a very difficult and awkward situation.
Criminal, civil and administrative actions are the most
common regulatory actions taken to obtain compliance. Criminal
actions are taken for the most severe violations, i.e., knowingly
endangering public health and the environment. These types of
violations usually result in court actions that focus on
imprisonment of the violator and cessation of facility
operations.
Is that what a regulatory agency really wants to do to a pr«q**«»
as beneficial as a household hazardous waste collection facility?
Civil and administrative actions are used for violations of
a less severe nature, i.e., storage or incompatible wastes,
improper drum labeling, recordkeeping violations, etc., And are
an excellent opportunity for negotiating a mutually agreeable
settlement prior to filing, the action with a court of law. This
"settlement agreement" is a legal document that usually lists
conditions for mitigating the violations, and may contain
provisions for paying fines and implementing some form of
pollution prevention. The settlement agreement can also provide
a vehicle to obtain compliance without shutting down the
operation(s) of a HHW facility. California has now used this
approach in it's first enforcement case involving a HHW facility.
The settlement agreement process;
The settlement agreement process is a two-step process: 1)
the corrective action order and complaint for penalty, and 2) the
settlement agreement and order. The corrective action order
notifies the facility that it is in violation of specific laws or
regulations, identifies those laws or regulations, and lists the
specific violations. A schedule of compliance listing the
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specific actions that must be implemented is also included.
Correction of the violations is mandatory, and it not typically
given monetary credit in "the settlement agreement.
The ^next step is the assessment of a penalty. Monetary
penalties are typically assessed as a punitive deterrent for
future violations. The penalty (or fine) is imposed in addition
to the requirement to correct the violation, and is the
"bargaining chip" that can be negotiated for conducting
supplemental environmental enhancement or pollution prevention
projects. The penalty is usually based on the seriousness of the
violations and must be defendable by the regulatory agency.
Penalties are sometimes calculated by estimating the monetary
savings that the facility accrued as a result of being out of
compliance, i.e. if a facility stored hazardous waste onsite for
longer than 90 days without filing for a permit, the facility may
have "saved" $50,000 in transportation and disposal costs. Thus
the penalty could be assessed at $5.0,000. And — here comes the
interesting part — some portion of that penalty can be
negotiated for the performance of some form of environmental
enhancement or pollution prevention activities. Such
negotiations usually occur during a hearing provided to each
violator.
Without getting too far afield here, I want to mention that
there is debate among some governmental agencies to the effect
that allowing environmental enhancement or pollution prevention
activities to be negotiated as part of a penalty may reward a
facility for being in violation. Other arguments center around
the need to collect fines to support regulatory programs, and
others still argue that they don't have the time or resources to
perform supplemental environmental projects in the settlement
agreement process. . These arguments are classic institutional
barriers to pollution prevention that must be overcome in order
to assure that industries do everything possible to eliminate or
reduce the generation of hazardous waste.
But the option of negotiating part of the penalty into
environmental enhancement or pollution prevention activities does
help solve several unique problems that are faced when
enforcement action must be taken against a household hazardous
waste facility, such as:
1) We, the State, encourage and support these very .
beneficial programs; we really don't want to shut them
down.
2) We are dealing with another governmental agency - in
California all of these facilities are operated by
local cities and counties.
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3) Getting actual dollars in fines and penalties out of
financially strapped local government agencies is like
pulling hens teeth!
4) We, the State, cannot hold facilities operated by
another governmental agency to a different standard
than we do any other hazardous waste industry.
5) While closing down a household hazardous waste facility
is the last thing we want to do, we do have to ensure
that they are run safely and in accordance with all
laws and regulations.
So how does it work?
Our first, but unfortunately not last, experience occurred
approximately two and a half years ago and involved the city of
Santa Monica, which up until then one of our premier and stellar
HHW facilities. We received a complaint, and upon investigating
found that several serious violations were, in fact, occurring.
Instead of safely and properly managing the HHW received, the HHW
was being stockpiled. The facility was filled to capacity, and
an adjacent building was also filled - literally to the rafters.
I assured Brian Johnson that I would stress the fact that
this all occurred under the previous administration - and I'm
more than happy to do that.
What had happened was the staff working at the Santa Monica
facility were reassigned to other duties, but the facility itself
was not closed and HHW continued to arrive. The end result was a
tremendous stockpiling of all of the HHW as well as all of the
emergency clean up wastes accumulated during the same period of
time.
• Because of the risk involved, the first thing we had to do
was shut down the facility; then we issued an order for all of
the hazardous waste to be removed — the facility could not re-
open until this had been done. Those two actions do not, by any
means, constitute anything creative on our part. But what
happened next did.
In assessing a penalty and discussing the proposed fine with
city officials, it became immediately apparent that we had to
take a different approach. To be perfectly honest, the city's
response to the proposed penalty was to tell us politely to take
a flying leap! They said they absolutely would not pay the
proposed $325,000 fine; they also said it was o.k. with them if
the facility never re-opened.
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That certainly left us with a dilemma: how to get a fine or
penalty — or the equivalent of one — out of them and get their
facility back on-line?!?!
Ultimately, the brainstorming sessions resulted in a
proposal that was creative: Have the city pay-a minimal fine,
but also require them to finance, organize and conduct an
educational program on the proper management and operation of a
household hazardous waste collection program or facility. The
proposal, if accepted, would accomplish several things:
1) We would recpver enough in the actual penalty to cover
the $13,250 cost of our investigation;
2) Their facility could re-open;
3) Additional penalty value of approximately $25,000 would
be covered in the educational program;
4) Equally important, the educational program would
provide a real benefit to other local governmental
agencies throughout California who were planning or
already operating a HHW program;
5) And possibly most important of all, the city thought
they were getting a bargain!
There were many specific conditions included in the
settlement agreement language: the education program had to
begin within six months of the settlement agreement date; it had
to consist of classroom instruction at an accredited college or
university; it had to include an internship program; there was a
target audience o.f other municipalities; the city had to make
"reasonable" efforts to advertise or otherwise publicize the
program; and they had to submit to us for review and approval
both a written proposal and the curriculum for the program. We
put them on "probation" and beefed up our inspection schedule as ,
well.
The results?
The city accepted the proposal, the settlement agreement was
signed, the facility re-opened, the $13,250 fine was'paid, and
the education program was held at Santa Monica City College with
approximately 45 "students" in attendance who paid no fees or
tuition for the four-day- course. In the end, the program
actually cost the city closer to $35,000.
Two additional benefits that we had not anticipated also
occurred: (1) the HHW facility was transferred from the city's
Department of General Services and now reports directly to the
city manager; and (2) Brian Johnson became general manager of
Santa Monica's HHW program. There haven't been any problems at
the facility since.
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Are we, the State, happy with the results?
In a word, yes.
Have there been any other violations at any other household
hazardous waste facilities in California?
Yes. In fact, there is one case currently pending where a
facility operated illegally for six months, another where some
filled drums were accidentally "overlooked" for several months
instead of being transported to a TSDF, and yet another where
some unauthorized waste was accepted. In the case where the
facility operated illegally for six months, the facility has
since received it's authorization to operate, but the enforcement
action for the previous violations is yet to be resolved. We are
currently looking at options for creative terms, including ideas
gleaned from the local agency's household hazardous waste element
in their general plan, such as:
1) Requiring the facility to accept cesqg waste, which
they currently do not do, but plan to do at some
unspecified date in the future.
2) Requiring the local agency to implement their k-12 HHW
education program now rather than in three years as is
currently planned.
3) Requiring the local agency to conduct an agricultural
pesticide collection program for banned, restricted or
outdated pesticides from commercial growers in their
jurisdiction.
4) Requiring the local agency to conduct one-day HHW
collection events in the areas of their jurisdiction
not served by their permanent HHW facility.
5) Requiring the local agency to expedite their plan and
schedule for a mobile HHW collection unit to serve the
other areas of their jurisdiction.
Will we use creative settlement terms in future enforcement cases
against HHW facilities?
Absolutely. Even though we are increasing our efforts to
provide more regulatory assistance to household hazardous waste
facilities and programs, we know this is not a perfect world. As
more HHW facilities come on-line, we can probably expect more
problem situations to occur now and then. Over-zealous
inspectors will undoubtedly be a contributing factor as well.
And when needed, we will try creative terms and conditions
because they can turn a very difficult enforcement case into a
win-win situation for us all.
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COMPONENTS OF A COMPREHENSIVE CESQG PROGRAM
Ned Brooks, Minnesota Pollution Control Agency
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OVERVIEW OF PRIMARY COMPONENTS j
Identification of generators |
Education and assistance
Compliance and enforcement
Off-site waste management '
Evaluation
CESQGHHW MANAGEMENT PROGRAMS
Similarities <
Large population :
Regulation or lack of
Waste, waste management
Education needs, goals '
Federal/state/local involvement
Differences i
Waste, waste management
CESQG - business activity '
Regulation . ;
IDENTIFICATION OF CESQGS
Important and difficult |
Passive
Voluntary i
Obtain ID number for disposal
Active
Mailing to list of likely generators
SIC
Telephone book ,
Business license/Tax ilD
Marketing lists I
Work with trade groups i
Door-to-door survey '
CESQG EDUCATION AND ASSISTANCE
CESQGS need information on:
Identification of hazardous waste
Waste management |
Reduction |
Tools: !
Printed material
Workshops, seminars, meetings
Telephone advice i
Site visits/consultations |
CESQG EDUCATION AND ASSISTANCE '
CESQGS need information on: j
Identification of hazardous waste
Waste management >
Reduction I
Tools:
Printed material
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Workshops, seminars, meetings
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Telephone advice
Site visits/consultations
Suggestions:
Emphasize benefits business
Be concise, specific
Involve business groups, suppliers
CESQG COMPLIANCE THROUGH ENFORCEMENT
Compliance through education preferred
Some CESQGS will not respond to education alone
Enforcement action may be required as a result of:
Complaint investigations
Regular inspections
Fear of enforcement strong deterrent
The word will get around
OFF-SITE CESQG WASTE MANAGEMENT METHODS
Municipal waste streams
Licensed transporter delivers to permitted facility
CESQG self transport to collection site
Temporary
Permanent
Combined HHW/CESQG
Consolidate with other businesses
OFF-SITE WASTE MANAGEMENT - RECYCLING, TREATMENT, DISPOSAL
Barriers:
Lack of services available
Lack of knowledge of services ..
Transport, analytical, disposal too costly
Too complex, bureaucratic
Regulation of CESQGS does not allow self transport
Lack of regulation - no incentive
CESQG COLLECTION - FEDERAL REQUIREMENTS
Not regulated as a HW program per RCRA
No permit or ID number required
No accumulation limit
Self transport is allowed
No limit on storage time
No subtitle C permit
HHW/CESQG same facility, same drum
CESQG COLLECTION PROGRAM ISSUES
Must keep S/LQGS out
Who is the generator, especially if combined with HHW?
Can liability still be traced back to CESQG?
To what level are costs subsidized?
Transport to site
Safety
Regulated by MNDOT as a hazardous material?
Role of reduction
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Household Hazardous Waste Collection Programs Managing Nonhousehold Hazardous Wastes: An
Overview of RCRA Regulations
Charlotte Mooney
U.S. Environmental Protection Agency, Washington, D.C.
1. Introduction
Municipalities and other managers of household hazardous waste (HHW) collection programs are
expressing interest in collecting hazardous waste from small businesses that generate small quantities of
hazardous waste. Collection program managers considering managing hazardous waste generated by
businesses, commercial operations, and industries should be aware that such waste is not excluded from
the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations under the household
waste exclusion (40 CFR §261.4(b)(l)) and may be subject to additional requirements.
Managers of programs considering collecting nonhousehold hazardous waste should become
familiar with state regulations governing the management of such waste, or if in nonauthorized states, the
federal regulations. (Most state regulatory programs are based on, and are similar to, the federal program.)
This paper discusses the federal regulations governing management of such waste by HHW collection
programs.
2. Conditionally Exempt Small Quantity Generator Hazardous Waste
In general, hazardous waste generated by nonhousehold establishments is subject to the full
hazardous regulatory program set forth in Parts 260 through 272 of Title 40 of the Code of Federal
Regulations (CFR). There are regulations' governing hazardous waste generators (40 CFR Part 262),
hazardous waste transporters (40 CFR 263), persons treating, storing, or disposing of hazardous waste (40
CFR Parts 264 and 265), and permits for persons managing'hazardous waste (40 CFR Part 270). In
addition there are land disposal restrictions regulations (40 CFR Part 268) which require that hazardous
wastes be treated to meet specified standards prior to land disposal.
However, under the federal regulations, there is a conditional exemption provided for hazardous
waste generated by generators known as Conditionally Exempt Small Quantity Generators (CESQGs).
These CESQGs are nonhouseholds (e.g., retail stores, office buildings, restaurants, shopping centers, small
commercial or industrial operations) that generate 100 kilograms or less of hazardous waste per month
(kg/mo)1, and/or 1 kg/mo or less of acutely hazardous waste (or 100 kg/mo of acutely hazardous waste
spill residues). The procedure used to calculate the amount of hazardous waste generated per month is
set forth in 40 CFR §261.5, paragraphs (c), (d), and (e). The calculation requires the generator to total
all hazardous wastes generated within the month, except several specific wastes which are not counted.
Those wastes not included in the calculation are:
Used oil that is recycled on-site or sent off-site for recycling;
• Spent lead-acid batteries that are reclaimed;
Hazardous waste that is not subject to regulation or that is subject only to requirements
for waste identification, EPA Identification Numbers, and Biennial Reports (e.g., a
hazardous spent solvent that is reclaimed at the generator's site immediately after
generation without any storage prior to reclamation);
Hazardous waste that has already been counted once including waste removed from on-
site storage or waste produced by on-site treatment (including reclamation); and
'Translated from weight to volume, 100 kg of hazardous wastes that have a density similar to water occupy about
one-half of a 55-gallon drum (or the volume of approximately 27 gallons of water). 100 kg of paints probably lake
up slightly less volume, while 100 kg of hydrocarbon liquids such as nonhalogenated solvents probably take up
slightly more volume.
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Hazardous spent materials that are generated, reclaimed, and subsequently reused on-site,
so long as such spent materials have been counted once.
Under the federal hazardous waste regulations, hazardous waste generated by CESQGs is subject
only to the limited requirements set forth in 40 CFR §261.5, rather than the full hazardous waste
' regulations, provided the CESQG complies with the following requirements:
1) CESQGs must follow the waste identification procedures of 40 CFR §262.11 to determine
whether their wastes are hazardous, and to determine what the appropriate waste codes
are for the wastes (§26l.5(f)0) and (g)(l));
2) CESQGs may not accumulate greater than 1,000 kg of hazardous waste (or 1 kg of
acutely hazardous waste or 100 kg of acutely hazardous waste spill residues) on-site at
. any time (§261.5(0(2) and (g)(2)); and
3) . CESQGs must either treat or dispose of their hazardous wastes in an on-site facility or
ensure delivery to an off-site treatment, storage, or disposal facility, either of which, if
located in the U.S.. is:
A) Permitted to manage hazardous waste under Part 270 of the federal
hazardous waste regulations;
B) Granted interim status to manage hazardous waste under Parts 265 and
270 of the federal hazardous waste regulations;
C) Authorized to manage hazardous waste by a state with a hazardous waste
management program approved under Part 271 of the federal hazardous
waste regulations;
D) Permitted, licensed, or registered by a state to manage municipal or
industrial solid waste; or
E) A facility which:
a) Beneficially uses or reuses, or legitimately recycles or reclaims
its waste; or
b) Treats its waste prior to beneficial reuse, or legitimate recycling
or reclamation. (§261.5(0(3) and (g)(3))
Under the third requirement, CESQGs may take their hazardous waste to a HHW collection
program (or to any other waste collection or management facility) that is not a permitted or interim status
hazardous waste management facility if the program meets criteria D and/or E listed above. In other
words, for CESQGs to take their waste to a collection program, the program must either use, reuse, or
recycle the waste or be permitted, licensed, or registered by the state to manage municipal or industrial
solid waste. Some states may have programs set up to permit, license, or register HHW collection
programs. Other states may not have formal programs developed. EPA has stated, however, that this
requirement was not intended to impose on states any particular procedure for approval of such facilities.
All that is required under the regulations is that, the state have some mechanism for approving facilities
that manage CESQG waste. EPA has confirmed that any mechanism the state chooses is acceptable to
meet this requirement. Thus, an exchange of letters could be an appropriate way to achieve "registration"
of a facility, if that is the procedure selected by the state for this purpose (the term registration is not
defined in the regulations). (See attached letter dated October 9, 1986 from Mark A. Greenwood,
Assistant General Counsel, U.S. EPA, to Joan H. Peck, Chief, Waste Evaluation Unit, State of Michigan
Department of Natural Resources.) .
It is important that programs planning to accept CESQG waste work closely with the appropriate
state agency to identify the procedures necessary for compliance with 40 CFR §261.5. To demonstrate
compliance, programs may wish to maintain documentation of the state "registration," such as a copy of
a permit or letter. CESQGs may also request copies of such documentation to verify that they have taken
their hazardous waste to a facility that meets the requirements of 40 CFR 261.5(0(3) and (g)(3).
As long as a collection program accepting CESQG waste has met the requirements for receipt of
CESQG waste (i.e., recycling or state permitting, licensing, or "registration"), there are no additional
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requirements specified for management of CESQG waste under the federal hazardous waste regulations.2
Thus, there is no limit on the amount of CESQG waste that may be managed at the collection facility or
the length of time waste may remain at the facility, and there are no requirements applicable to
transportation of the waste3.
It should be cautioned, however, that there are several provisions that restrict management of
mixtures of other wastes and CESQG waste under the CESQG regulations. This issue is discussed further
in Section 3 of this paper.
»
3. Management of Fully Regulated Hazardous Waste
HHW collection programs considering collection of CESQG waste should be aware of the
regulations governing management of waste generated by fully regulated generators (those that generate
more than 100 kg/mo of hazardous waste, more than 1 kg/mo of acutely hazardous waste, or more than
100 kg/mo of acutely hazardous waste spill residues). Most importantly, all fully regulated generators
must transport their waste using a hazardous waste manifest, may only send their waste to permitted or
interim status hazardous waste management facilities or certain recycling facilities,4 and must fully
comply with the land disposal restrictions program. Thus, collection programs that are not permitted
or interim status hazardous waste management facilities (or certain recycling facilities) may not
accept hazardous waste from generators who generate greater than 100 kg/mo.
To protect themselves from unknowing illegal management of fully regulated hazardous waste,
collection programs may develop procedures to ensure that all waste accepted actually is CESQG waste.
A full understanding of the-hazardous waste regulations will assist in developing successful procedures,
as will an awareness of the difficulties inherent in distinguishing waste generated by CESQGs from mat
generated by fully regulated generators. Specifically, such wastes may be physically and chemically
identical; the classification is based only on the generator's waste generation rate. Thus, collection
programs will be relying on information provided by generators to ensure that only CESQG waste is
accepted. Therefore, it is in the collection programs' interest to verify that generators from whom CESQG
wastes are accepted understand the hazardous waste regulations. Collection programs may also want to
discuss with their legal counsel whether it may be appropriate to obtain from generators documentation
of their generator category.
'Collection programs may find that it is necessary to assist generators in determining whether they
are CESQGs or fully regulated generators. In this educational role, program operators also have an
opportunity to make generators aware of waste minimization practices that may allow them to reduce their
waste generation enough to remain under the CESQG limits. Thus, generators whose past practices have
generated larger hazardous waste quantities could alter their operations so that they generate smaller
amounts and are regulated under the limited CESQG regulations (rather than the full hazardous waste
regulations).
4. Management of CESQG Waste Mixtures
The CESQG regulations contain three provisions addressing management of mixtures of CESQG
collection program must of course comply with any requirements imposed under the stale permitting,
licensing, or registration.
3For both generators and collection programs, as long as packaging and transport is in compliance with applicable
Department of Transportation (DOT) regulations, use of manifests and hazardous waste transporters is not required.
Thus, if in compliance with DOT requirements, CESQGs may transport waste to a collection program themselves.
4 Or, for hazardous waste regulated only within the state, to certain out-of-state facilities. See the definition of
"designated facility" in 40 CFR 260.10.
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waste and other wastes (e.g., wastes that have been poured or placed into the same drum or container with
CESQG wastes). First, 40 CFR §261.5(0 states that CESQG waste mixed with waste that exceeds a
quantity limit (i.e., >100 k/mo of hazardous waste, >1 kg/mo of acutely hazardous waste, or >100 kg/mo
of acutely hazardous waste spill residues), is subject to full regulation. Thus, a facility managing mixtures
of CESQG waste and fully regulated waste would be subject to the full hazardous waste regulations (40
CFR Parts 262 through 272), rather than the CESQG regulations of 40 CFR §261.5.
Second, 40 CFR §261.5(j) specifies that mixtures of CESQG waste and used oil that are to be
burned for energy recovery are subject to the used oil burned for energy regulations set forth in Subpart
E of 40 CFR Part 266.
Third, 40 CFR §261.5(h) states that CESQG waste "may be mixed with non-hazardous waste and
remain subject to [the CESQG] reduced .requirements even though the resultant mixture exceeds the
quantity limitations identified in [the 40 CFR §261.5 CESQG regulations], unless the mixture meets any
of the characteristics of hazardous waste identified in [40 CFR Part 261] Subpart C." (Note that
HHW is excluded from the definition of hazardous waste and is thus, by definition, non-hazardous waste.)
EPA is currently developing guidance on how programs that manage CESQG waste together with
HHW may comply with die federal hazardous waste regulations. This guidance should be available in
1992. Programs interested in managing both HHW and CESQG should contact their state, and if in a state
not authorized to implement the hazardous waste program, their EPA Regional Office, to obtain further
information.
5. State Regulations
This paper reviews the federal regulatory requirements for HHW collection programs considering
collecting hazardous waste not excluded under the household waste exclusion. It must be emphasized,
however, that in many states the hazardous waste program is implemented by state agencies, using state
regulatory analogs rather than the federal regulations. Some states may not have a CESQG exclusion, may
use different quantity cut-offs, or may have different requirements for management of CESQG waste.
Thus, HHW collection programs should check with their state hazardous waste regulatory agencies to
identify any additional requirements under state hazardous waste regulations.
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OVERVIEW OF STATE CESQG DEFINITIONS, LAWS AND REGULATIONS
DANA DUXBURY
WASTE WATCH CENTER
*' Introduction
Under Section 261.5 of Title 40 of the Code of Federal Regulations, a CESQG is
conditionally exempt from the full hazardous waste regulations if they meet certain
requirements. In 40 CFR 261.5(f)(3) and g(3), CESQGs must send their waste to either a
federally permitted or interim status hazardous waste management facility, a state
authorized hazardous waste management facility, a recycling facility , or a facility
permitted, licensed, or registered by a state to manage municipal or industrial solid
waste.
Each state which has been authorized under RCRA to implement the Federal
statue has the ability to develop more stringent regulations. For the 0-100 kilogram per
month generator, some states have developed more stringent regulations including not
giving them any conditional exemptions from managing their waste as a hazardous waste
(which would not allow them to send their waste to a solid waste management facility)
and have often called them by another term. Consequently, in this document when we
refer to these generators at the state level we will describe them as "0-100 kilogram per
month hazardous waste generators" not CESQGs. When we refer to RCRA, we will use
the term CESQG.
State Issues
Certain states (California, Minnesota and Washington) are developing aggressive
very small quantity hazardous waste generator and/or combined HHW/very small
quantity generator programs to facilitate the identification, education, and technical
assistance to these generators as well as to encourage collection and proper management
of their hazardous wastes. Collection of the 0-100 kilogram per month generator waste is
being advocated and facilitated in some states even though such a generator is not
regulated as a Subtitle C hazardous waste generator in the state (WA) as well as in
states where they regulate down to zero (California and Minnesota). California and
Minnesota recently revised regulations, making it simpler and less expensive for the very
small quantity generator to participate.
Collection programs for very small quantity generators are still subject to state
regulations and must be permitted by the state in some manner. Some states that have
developed guidelines or regulations for one-day and/or permanent collection programs
treat HHW and very small quantity generator wastes as solid waste and, therefore, the
collection programs are also considered to be solid waste programs. The guidelines or
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regulations for these "solid waste" facilities, however, require that the wastes be
managed as though they are regulated hazardous wastes: identified; separated by hazard
class; labeled and manifested, and sent for reuse, recycling, or to a hazardous waste
facility - not a solid waste facility. Personnel need to receive hazardous materials
training, and safety plans are required.
Some states are passing laws preventing the disposal of both HHW and very
small hazardous waste quantity generator waste with municipal solid waste (MSW).
Wastewater treatment facility regulations are also limiting what can be poured down the
drain into the sewer system.
New England State Issues. Laws. Regulations that Apply
A. Massachusetts
The State of Massachusetts defines generators of less than 100 kilograms per
month (previously 20-100 kilograms per month) of hazardous wastes (and no acutely
hazardous waste) as "Very Small Quantity Generators" (VSQGs) This definition is
within the Hazardous Waste Management Regulations at 310 CMR 30.353. In CMR
30.390-392, the State codes Special Provisions for Accumulation of Household Hazardous
Waste and/or Hazardous Waste Generated by Very Small Quantity Generators. These
regulations allow VSQGs to participate at 1-day collections and HHW collection centers,
but unlike the households, require the VSQGs to register and obtain a receipt for their
wastes. The VSQGs are allowed to self-transport their wastes, up to 55 gallons at one
time. (The VSQG may also choose to use a licensed transporter, in which case they do
need an ID number for their manifest. The VSQG who self-transports does not need an
ID number .) The VSQGs are permitted to take their hazardous waste to another
generator, to a recycling facility, or to a treatment, storage or disposal facility (TSDF).
In Massachusetts, there are 24 TSDFs (15 of which are commercial), 640 LQGs,
3200 SQGs, and 13,500 VSQGs (including those handling just used oil), and 20
inspectors. The new multi-media facility master file enables the state to encourage
source reduction and proper management. Licensed transporters typically provide milk-
run service for oil, parts cleaners and dentists for silver recycling. The Upper
Blackstone Waste Water Treatment Facility has a new program to accept for recycling
silver, oil, and antifreeze from households and VSQGs. Licensed transporters are one
network through which the State informs the regulated community. The transporters
will also educate businesses on proper preparation, segregation, packaging, and storage
of wastes until collected. It was noted that one trade association and one regional
economic development agency had offered to facilitate the set-up of collections for their
members and local businesses but both had been discouraged by the fear of becoming a
liable party if anything should go wrong.
B. New Hampshire
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The State of New Hampshire defines hazardous waste generators of less than 100
kilograms per month as "Small Quantity Generators" (SQGs). Those generators of
greater than 100 kilograms per month are "Full Quantity Generators" (FQGs). The
generators of less than 100 kilograms per month have an extended storage time, and
may self-transport up to 20 gallons to a permitted facility. New Hampshire's policy is to
not permit SQG wastes at HHW collections. SQGs are regulated under the New
1 Hampshire Hazardous Waste Rules (New Hampshire Code of Administrative Rules,
sr Env-Wm 500). The State of New Hampshire Department of Environmental Services
offers a non-regulatory waste reduction and pollution prevention program to both SQGs
and FQGs. The program provides hazardous waste generators suggestions for waste
reduction and offers on-site inspections to help industry decrease the production of
hazardous wastes.
New Hampshire has no TSDFs, 115 FQGs, and 2318 SQGs and 5 inspectors.
They use funds from fees on hazardous waste ($0.03/1 b on non-recycled waste and used
oil sent for energy recovery) and fines to provide HHW grants for collection programs
and education. The funds (about $200,000 per year) have been used mostly on collection
events to date but could be used for permanent facilities also.
C. Vermont
t
The State of Vermont funded surveys in each region to identify conditionally
exempt small quantity generators (ESQGs) and quantify the types of waste they
generate. Businesses are regulated if they generate more than 100 kilograms per month
of hazardous wastes, as defined by RCRA, listed by RCRA, or as defined by Vermont.
The State has developed a Guidance Document & Application Form for
Unregulated Hazardous Waste Facilities. ESQGs are permitted to self-transport and
send hazardous waste to solid waste facilities certified to accept such wastes. Special
provisions for HHW facilities accepting ESQG wastes include:
• procedures for recording information about ESQGs such as name, types
and quantities of wastes brought and dates;
containers of wastes from ESQGs must be removed within 90 days from
the time the container is filled;
proof that Vermont's Hazardous Materials Management Division (HMMD)
has been notified of hazardous waste activity, that they have given a
generator identification number, that they have been notified of reuse or
recycling activities and any additional requirements have been satisfied;
• procedures for collecting a tax on the quantity of hazardous waste
generated, based on the destination for the waste, as follows:
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1. Hazardous waste to be reclaimed, recycled or recovered for
beneficial purposes shall be taxed at $0.11 per gallon of liquid, or
$0.01 & 4/10 per pound of solid;
2. Hazardous waste destined for treatment shall be taxed at $0.22 per
gallon of liquid or $0.02 & 8/10 per pound of solid;
3. Hazardous waste destined for long-term storage shall be taxed at
$0.33 per gallon of liquid of $0.04 and 2/10 per pound of solid;
4. Hazardous waste destined for land disposal or land treatment shall
be taxed at $0.44 per gallon of liquid or $0.05 & 6/10 per pound of
solid.
• Measures to ensure hazardous waste are packaged and labeled in
accordance with Department of Motor Vehicles (DMV) regulations before
they are transported off-site.
• Measures'to ensure that waste shall only be offered to transporters or TSD
facilities that have an identification number.
Procedures for manifesting waste shipments, storage of manifests for up to
three years, and submittal of "exception reports" to HMMD if copies of
completed manifest forms are not received within 45 days.
• Submittal of annual reports to the Agency of Natural Resources (ANR).
» Provisions in the closure plan to ensure removal of all wastes to a facility
licensed to handle that waste, written notice prior to closure to ANR, and
that certification of closure will be completed in accordance with the
regulations within 90 days after completion of closure.
In addition to these provisions, Vermont has banned certain unregulated hazardous
wastes from being disposed of in landfills. There are 75-80 LQGs, 400-500 SQGs and
they recently surveyed VSQGs and estimate there are 2500-12000 ESGQs and 2
inspectors: One TSDF is permitted to accept non-manifested ESQG waste. Funding for
collection programs has come from surcharges on solid waste facilities (currently all
landfills) in the state. Also, private landfill owners and district surcharges provide
additional funding. The Associated Industries of Vermont fund and sponsor a
WasteCap program and the Vermont Pollution Prevention Division funds a Retired
Engineers And Professionals (REAP) program. The WasteCap and REAP programs
provide source reduction education to businesses. The Montshire Museum facilitates
meetings of the Upper Valley Compliance Officers Network (UVCON) which helps share
information about source reduction and compliance issues. Another information sharing
opportunity is the Burlington Area meeting of loss control specialists.
D.
Maine
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Maine regulates all businesses generating hazardous waste; those generating up to
100 kilograms per months are "SQGs". The SQGs are required to package, label,
manifest, use a hazardous waste transporter and hazardous waste facilities for
management of their hazardous waste. The SQG waste is not exempt from the proper
hazardous waste treatment and disposal requirements of larger quantity generators and
~ is therefore not allowed to be mixed with household hazardous waste and disposed of in
^inappropriate Subtitle D facilities. Maine also has a strict storage limit for SQGs which
«;permits storage of up to only 100 kilograms. The SQGs do not have the requirements
for developing personnel training and hazardous waste contingency plans, daily
inspection logs and annual reporting required of regulated generators under RCRA.
Generator seminars have been offered every two years, sometimes with specific emphasis
on targeted audiences such as auto body shops, dry cleaners, and boat yards. Since a
significant majority of the businesses in Maine fall under the 100 kilograms per month
limit, most of the state's business waste would be conditionally exempt if the state
followed the RCRA exemptions. The State of Maine recommends milk-runs to pre-
registered SQGs since they are prohibited from transporting their own waste to a
central site. Maine has approximately 10 TSDFs, 110 LQGs, and 1100 SQGs (by the
RCRA definition, i.e., those generating 100-1000 kilograms per month) and 5-10,000
SQGs (using the State definition, equivalent to RCRA CESQGs, I.e., those generating
under 100 kilograms per month) and 6 inspectors.
The Maine Waste Management Agency has mandated that the State offer HHW
collections by 1995 (revised from 1992 in original, due to lack of funding). They
attempted to pass a hazardous materials tax but it did not pass. There appears to be
some inconsistency between the mandates for the solid waste and the hazardous waste
regulations.
E. Rhode Island
Rhode Island regulates all businesses generating hazardous waste, small and large
are all referred to as "generators". All generators are required to package, label,
manifest, use a hazardous waste transporter and hazardous waste facilities for.
management of their hazardous waste. The small businesses are not allowed to dispose
of their hazardous waste with the municipal or industrial solid waste stream, nor can
they participate in collection events or collection facilities geared for HHW. Since a
significant majority of the businesses in Rhode Island fall under the 100 kilograms per
month category, most of the state's business waste would be conditionally exempt if the
state followed the RCRA exemptions. The State allows them to accumulate 1 drum's
worth of hazardous waste before the 90-day storage limit begins. The State maintains a
computer tracking system which lists all known generators. Generators get onto the list
through having a hazardous waste pickup by a contractor, through reporting by others
(including competitors) and waste haulers, or through inspections done by the
enforcement people.
Rhode Island has 3 TSDFs, 80-100 LQGs, and 4,000 other generators. The
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TSDFs are regulated as hazardous waste generators.
F. Connecticut
The State of Connecticut has exemptions for businesses that generate less than
100 kilograms per month of hazardous waste but they do not allow all of the options
allowed by RCRA. Specifically, Connecticut does not allow CESQGs to send their
wastes to MSW facilities. The only options are TSDFs. Currently, the Connecticut
regulations do not allow CESQG wastes to go to a HHW facility or collection event.
The HHW programs would require a hazardous waste special permit to accept CESQG •
wastes. A future option would be to change the regulations for SW permits to allow J
CESQG wastes.
Connecticut has 12 permitted, commercial TSDFs. They estimate, based on 1991 |
report filings, that the state has approximately 475 LQGs, at least 1400 SQGs, an
undetermined number of CESQGs, and currently have 7 inspectors. They have no •
required notification for small businesses or exact figures on the number of CESQGs. |
HazWaste Central is looking into opening to CESQGs in the future. They have found
that there are more frequent CESQG business closings due to economic difficulties. •
Types of Programs in Existence
I
A. Very small quantity generators at separate time as HHW event collection •
(Marin County) •
The State of California regulates all generators of hazardous waste, including I
those who generate less than 100 kilograms per month. The smallest quantity •
generators are defined as very small quantity generators (VSQGs). They have, however, **
amended their regulatory requirements to enable HHW programs to collect and manage I
HHW and wastes from the VSQGs. Specifically, the State has required HHW collection "
programs to allow participation by VSQGs, has expanded the exemption from tax, fee,
permit, and reporting requirements to cover programs accepting HHW and VSQG . I
wastes, and has required that HHW and VSQG wastes be addressed in the solid waste
planning processes. _
Marin County, California ran separate events for collection of VSQG wastes.
The County held the events at the same site as the HHW collections and used the same •
EPA Identification number. Businesses were required to call for appointments and to I
pay for the costs of transportation and disposal of their wastes. The County set up a
phone line with a recorded message for businesses to leave information on the type and •
amounts of wastes they wished to bring to the collection. The County staff would call |
back with appointment times and cost information and follow-up with a confirmation
letter and further information. There were six different collection days, each at
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different locations. Four appointments were scheduled for each 15 minutes. Compared
to the household collection, the VSQGs brought in slightly more (96 Ibs per business)
than the average-household (77 Ibs per household). Nearly half of the participating
VSQGs were from construction-related businesses. Other businesses were schools,
nurseries, printers, artists, and various others. The costs charged to VSQGs ranged
from $4 per gallon for latex paint, $7 per gallon for wastes to be sent for burning as
supplemental fuel, and $10 per gallon or approximately $1 per pound for wastes
requiring chemical treatment, to $5.50 per pound or $44 per gallon for destructive
incineration.
B. VSQGs in separate lines at event collection (Santa Barbara)
In this program, the VSQGs are served at the same time as residents, but they
use a separate line to permit additional time for the additional requirements of handling
the VSQG wastes.
C. CESQGs at a permanent facility (Anchorage)
In Alaska, very small quantity generators of hazardous waste are called CESQGs
and their regulations mirror RCRA. Anchorage Alaska's permanent HHW facility
accepts CESQG wastes (they are not regulated by the State as hazardous waste
generators). The participation by CESQGs has increased from 262 (11 percent of total
participation) to 376 CESQGs (15 percent) in the calendar year. The average quantity
of wastes received from the CESQGs (683.4 Ibs including antifreeze, motor oil and
batteries, which are not subject to the 220 Ibs/month limit) is considerably larger than
the average amount per household (74.5 Ibs). This is reflected in the fact that overall, 43
percent of their waste is from CESQGs, although only 15 percent of their participants
are CESQGs.
The fees charged CESQGs range from $.05 per pound for latex paint, $.50 per
pound for solvent-based paints and related materials to $1.00 per pound and from $.70
to $1.00 per gallon for oils and fuels. They also offer pickup service for an additional
fee of $10 per household and $25 per CESQG, although they have recommended raising
the pickup fee to reflect actual costs.
D. Very small quantity generators at a commercial TSDF (Seattle)
The State of Washington considers HHW and very small quantity generator
waste "Moderate Risk Waste" (MWR). The state does not regulate businesses that
generate less than 100 kilograms per month of hazardous waste as a fully regulated
generator but, it has a requirement for including HHW and very small quantity
generator wastes in the solid waste planning process.
In Seattle, at Burlington Environmental's TSDF, pre-registered very small
quantity generators which self transport their waste are given 15-minute appointments
and pay $10/gal or $l/pound or a $15 minimum to bring their hazardous waste. The
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facility is open for very small quantity generators on the last Tuesday and/or Wednesday
of each month. They have had a increase in participation from 6-10 per month in the
first six months to 45-50 per month. The average cost is $125 per very small quantity
generator and they are getting a large number of repeaters; 30 percent of the 1990
customers use the facility every other month. The company's concerns include ensuring
that these generators meet DOT regulations and tracking them.
E. Specialized collections only for select very small quantity generators (farm
pesticide collections)
States with significant farming populations, such as Michigan and Vermont, have
held specialized collection events for farmers in order to collect unwanted and out-of-
date pesticides.
F. Identification & Technical Assistance
In Seattle, Washington, Seattle's METRO has developed an aggressive program
to identify and assist the very small businesses generating hazardous waste which are
called in Washington State, along with HHW, Moderate Risk Waste Generators and are
not subject to state hazardous waste regulations. As mentioned earlier, the counties and
localities are required to develop a solid waste plan identifying how this waste will kept
out of the solid waste stream and what collection and source reduction efforts will be
developed. They cite the need for information about identification of hazardous waste,
waste management options and pollution prevention opportunities. They have also
discovered that there are a great many unidentified very small businesses operating
evenings .or week-ends. They are gathering detailed information about two small
business types, automotive and silk screen printers, to determine how the City can be of
further assistance.
G. Other
"Milk runs" are often encouraged by states where the very small quantity
generators are regulated. In this type of collection, a licensed hazardous waste
transporter makes a series of stops at similar small businesses in an area to pick up
their hazardous wastes. Vermont has also allowed communities to collect paint from
these generators at paint drop & swap programs.
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CHANGING CONSERVATION ATTITUDES, KNOWLEDGE AND BEHAVIOR
EPA Conference, Household Hazardous Waste, December, 1992
Shirley Niemeyer, Ph.D., Extension Specialist, University of Nebraska-Lincoln
We are talking about attitude, knowledge and behavior change - but just think about how hard it
is for us to change our own behavior - are we models of what we talk about? Changing attitudes and
behavior is not easy - there are no simple procedures, no "magic formulas". There are lots of theories,
and some controversy, about how attitude and behavior change comes about. The focus today is on a few
of the methods that can be applied to education.
Overview of Attitude and Behavior Change
1. People do not come to us or to educational settings with a blank slate. People come with pre-
conceived ideas, culture, attitudes, existing knowledge and behaviors. What our learners already
know and their existing attitudes influences how the message is received. Consider the audience
receiving the program. How much attitude and behavior change do we think we can bring about?
2. We must feel a sense of responsibility for the behavior change we want to or do bring about. We
have a responsibility to continue to evaluate formally and informally to see where that behavior
change may be leading us as a group or society - in terms of the environment.
Example: Recommendations may be made to make your own cleaner of x and y, but later x and
y may prove to be similar in environmental costs or create a different problem.
3. The behavior change that comes about may not be the one we planned to accomplish.
Example: In 1986, to determine how effective the special household hazardous waste collection
day had been in Marin County, the Garbage Project sorted samples of the garbage before and after
the county's first publicized "Toxics Away" Day. The results were contrary to the behavior
expected. The garbage discarded after the Toxics Away Day contained more than twice as much
hazardous material by weight as the garbage that had been discarded before the collection day.
Probably the intense media campaign to create awareness of the collection day did create
awareness. Because the collection was one day only with no future collection days announced,
many homeowners, newly aware of the hazardous waste in their homes, and having missed the
collection day, may have decided to get rid of their hazardous waste and threw it out:
4. When we design or manage a program - we must look at the big picture - the holistic approach.
Design the program. Consider the needs of the targeted audience and think about the objectives
and how to reach those objectives. Think about what may happen if behavior change does occur -
what are the other issues you will then have to deal with or what may be some unforeseen circum-
stances. Consciously evaluate. Evaluate the behavior or what happened as result of the change.
Bring in others to your team - bring in educators, psychologists - people from different
perspectives and disciplines. It will enrich the designed learning experience and your program.
5. Communication is difficult There are thousands and thousands of competitive messages being
sent to our targeted audiences. Audiences ignore many of the messages - they simply don't see
them or hear them - they tune them out. Before we can bring about behavior change, get their
attention. The message must be processed and evaluated by the learner.
6. Operate with the media • give clear messages as educators. Media may focus on the extreme of
the message about household hazardous waste. Make sure the message is clear about the risks
and benefits. If we dwell on the risks and say nothing about the benefits, the message conveyed
in the media may be the extreme risk to catch attention.
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7. To change behavior, the topic must have some direct relevance to the learner.
8. Behavior may fade - revert back unless it is aided.
Approaches to Encouraging Behavior Change
There are many approaches and theories to attitude, skills and behavior change. In presenting
these seven approaches, the following four aspects are discussed:
Characteristics of approach
• Educational approaches within these seven
• How die outcomes are influenced by other factors
• Examples of each of the seven
The Seven Approaches to Encouraging Behavior Change include:
• Persuasive Communication
• Attitude-Consistent Conservation Behavior - those predisposed to conservation
Material Incentives and Disincentives
Social Incentives and Disincentives
Models of Conservation Behavior - use of role models
Implementation of Intentions - minimizing inhibiting factors to the behavior
• Feedback on Efforts - Effectiveness of efforts
The information discussed is based on work by Cook and Berrenberg (1981) and introduces a
framework or summary of the conservation behavior literature and comparisons across studies. The seven
approaches to encouraging conservation behavior are from common concepts from the research of
behavioral scientists work on energy and water conservation and recycling.
Think about how these methods apply to changing peoples' behavior related to potentially
hazardous household waste. Think of specific examples that apply to your programs.
1. Persuasive Communication
1).
2).
3).
Characteristics: Appeals to fear of disastrous consequences or relates conservation to
achieving valued goals such as personal and family security, or preservation of natural
resources for use in the future. Persuasive communication is often seen in advertisement.
Educational Approaches: Include information about resource shortage - usually in crisis
terms or predictions of negative consequences.
Outcome influenced by: Context of the experience, characteristics of person, and/or
evidence of crisis. Impact could be reduced if the recommended changes in behavior
deviate too far from existing beliefs - if an educator gets too far out in predicting
disastrous consequences - impact may be reduced. Great discrepancies between the
individual's beliefs and those advocated by a communication or message are likely to
reduce attention to the message and may contribute to creating opposing thoughts.
As educators, we need to be careful of fear appeal with children - they can be made aware
of the problem with out being made to feel its fearful, disastrous, their fault or their
responsibility to change the world.
4).
2.
Examples: Pollution of water, air, or soil; cost escalation; that local sewage system will
be impacted; or that they are preserving the natural resources of soil and water by
reducing amount of household hazardous waste used and disposed. Appeals to "your
actions can save natural resources - preserving our heritage of abundance of resources for
our children and future generations".
Attitude-Consistent Conservation Behavior
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1). Characteristics: The person, is already predisposed to pollution reduction actions - the
attitudes and beliefs are consistent or supportive of doing something about the problem.
Positive attitude already exists about environmental responsible behavior.
2). Educational Approaches: Link actions to pro-conservation attitudes. Help people see how
they could put their pro-environmental attitudes into actions.
3). Outcome Influenced By: Whether the situation is supportive of the behavior. Social norms
.may be part of the situation that supports or constrains/prevents the behavior. The learner
may lack knowledge that an action would be consistent with a pro-conservation attitude.
4). Examples: Direct educational messages to opportunities to reduce household hazardous
waste (hhw); use mass media to direct attention to opportunities to reduce or to recycle
potentially hazardous household hazardous products - let the targeted audience know
locations, specific times, etc.
3. . Material (Extrinsic) Incentives/Disincentives ^
1). Characteristics: Materialist rewards are used to encourage conservation and reduce
consumption. Consumption may be reduced • but the people may not have pro-
conservation attitudes. They do it for another reason other than its "good for the
environment". Material incentives or disincentives are used such as money or
convenience. Financial rewards are provided or extra cost charged for larger volumes.
Use of disincentives such as fines or regulations becomes more frequent as the problem
gets worse or a resource crisis deepens. '
2). Educational Approaches: Increase convenience associated with conservation and comfort
associated with conservation; decrease the convenience and comfort resulting from high
level of consumption or waste. .
3). Outcome: Impact on behavior is complex, unpredictable, and the effects of punishment
may be temporary. A dislike for or avoidance of the source of the punishment may result.
Punishment is generally effective only if a positive reinforcement is provided for an
alternative behavior. The positive effects of financial incentives may be small and short-
lived. The variable schedules such as lottery, or irregular schedules show more promise
in that they may contribute to longer periods of behavior change.
Some research suggests that once the incentives are taken away the behavior is likely to
stop (Couch, Garber & Karpus, 1979; Lyben & Bailey, 1979; Pardini & Katzev, 1983-84).
Use of raffles and contests in facilitating paper recycling did increase the recycling during
the period of the raffles and contests, but when the reinforcement of the raffles and
contests were removed, the behavior returned to baseline levels (Witmer, & Geller).
4). Examples: Disincentives: Fines,, pay by volume, pay more for potentially hazardous
products or pay extra for their disposal.
Incentives: Lottery type rewards, drawings of winners for cash prizes for those who have
participated in hhw collection program.
4. Social Incentives/Disincentives
1). Characteristics: They are similar to material incentives/disincentive in motivational role.
People change behavior due to reactions of others (norms). People perform behaviors
based on what others would approve of. Commitment -especially the public commitment
- increases the likelihood that conservation actions will follow. "Public expression of
attitudes increases the performance of behaviors consistent with them" (Kieslter, Mathog,
Pool & Howenstine, 1971; Pallak, Cook, & Sullivan, 1989). Group decision making is
also a social incentive and involves a change in group norm during discussion of the
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problem and its resolution. ,<•
2). Social recognition: Provide social recognition and approval for conservation actions, seek
commitment to others to conserve, have learners participate in group decision making.
3). The outcome is influenced by the degree of public nature of commitment
4). Examples: People sign some son of statement or petition supportive of the desired issue
position. Public recognition through awards or certificates for participation in hhw
collection event, photographs of participants, decal displayed on house or car with
message that this household participates in hhw activity or collection. Have participants
tell others in group or make public statement of plans to start reducing and recycling. At
the end of an educational meeting, have each participant publicly state what she/he plans
to do regarding hhw before the next meeting. Have small community groups meet and
make group-decisions about their recycling/reduction activity.
Example: The boy scouts went around a neighborhood and got people to sign a certificate
that the household supported or recycled products.
.Example: In a larger audience • ask people to stand if they intend to reduce the volume
of potentially hazardous household waste. Ask people as they come through the hhw
collection line to sign a resolution document that they plan to reduce. Everyone signs the
same document so that they canrsee others have signed - publish names in paper if
granted permission to do.
Example: Salimando reports that as more and more households on a block recycle, it
suddenly becomes embarrassing to not recycle. One researcher reported in a study that
almost all the recycling boxes were out in the neighborhood. A car backs quickly out of
the garage, begins to take off to work, returns, runs in to get their recycling box, sets it
out on the curb, and then continues to work. The researcher wondered what could have
been so important to recycle and looked into the box - there was nothing. But the
individual evidently wanted to comply with group norms.
Providing Models of Conservation Behavior
1). Involves dynamics of adopting beliefs and practices of admired individuals, or opinion
leader in community, - the behavior of significant others is copied. Prestigious figures
serve as role models for conservation behavior.
2). Information about/from opinion leaders practices is provided, or participants are exposed
to that person's philosophy, practices, etc. in education.
3). Opinion leader seen as source.
4). Examples: Conduct demonstration plot by opinion leaders or plan media about admired
people who are reducing, recycling hhw waste. Have local neighborhood tours of
example households that reduce hhw, recycle and store products safely.
Research has shown that in some instances in recycling, block leaders can have a
significant effect on recycling (Nielsen and Ellington's (1983).
Facilitating Implementation of Intentions
1). Characteristics: People may already have inclinations toward conservation or reduction,
but are not displaying behavior due to lack of knowledge of appropriate actions or
difficulty in carrying out the actions. They may lack opportunity.
2). Educational Approaches: Minimize the inhibiting effects. Provide information about
what actions can be taken by those known to have conservation intentions.
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3). Opportunities for action/behavior to occur influence the outcome.
4). Example: Information provided about hhw reduction, recycling, using up, safe storage
and disposal, location of nearest oil and/or paint recycling, alternatives to hhw collections
such as reduction, using up, etc.
7. Providing Feedback on Efforts
1). Characteristics: Provide feedback on effectiveness of efforts - can be self feedback or by
others. Feedback may result in improvement. The purpose is to help maintain behavior.
2). Feedback about results of actions
3). Nature and relevance of feedback may influence outcome.
4). Example: Savings resulting, how close to goal set, participants in hhw collections reduce
the amount of hhw to going to landfill by x pounds.
Summary of Seven Methods
Try another method of reaching the same audience or different audiences - you may bring about
behavior change in the new audience or enrich the experience of existing audience and bring about more
behavior change.
We have looked at seven specific approaches to behavior change, now lets briefly look at a few
of the ideas or theories behind them.
Learning Theory Examples
• Classical Conditioning - Pavlov
Instrumental Conditioning
• Hull's Learning Theory - Hull
• Wolpe's Conditioning Theory --Wolpe
Operant Conditioning - Skinner
• Two-Factor Learning Theory - Mowrer
• Cognitive Learning Theory - Tolman
• Social Learning Theory - Bandura
• Cognitive-Field Theory
Cognitive Dissonance - Festinger
• Balance - Heider
Behavior Change Theory Examples
Personal and Situational Constraints, Normative Beliefs and Behavior Change
Cognitive Dissonance
Conclusion
1. The tremendous variability of people and environments makes it difficult to be sure what measures
will be effective in creating change.
2. Practical considerations such as preferences of administration, funding and organizational con-
straints will influence the behavior-change techniques chosen by educators and project directors.
3. The various features, of the situation can affect the performance or nonperformance of a given
behavior. Situational variables can impact on a specific behavior independent of whatever stable
attitudes or dispositions people bring to the situation. People's characteristic traits or attitudes
may influence the behavior in some situations but not in others.
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POLICY IS MADE AT HOME: THE HOME WASTE SURVEY
>•,
Lilias Jones
Director, Eco Solutions, Inc.
400 Irish Drive, Fort Collins, Colorado 80521
(303) 484-9793
The Home Waste Survey is a technique designed to create changes in behavior leading to source reduction
• of wastes at the residential level. It involves sending trained Surveyors into residences to provide
personalized workshops, concluding with specific suggested steps for action. The Waste Survey was
created in response to recycling's failure to keep pace with increased residential waste production and the
literature's indication that individualized in-home programs are more effective in causing behavioral
change than mass media campaigns (Cornwall and Duerr, 1986; Esposito, 1988; Wirka, 1990).
The primary focus of this research is data gathered during a pilot project involving 100 Waste Surveys,
50 each in two differing Minnesota neighborhoods. These are the Phillips neighborhood of Minneapolis,
an ethnically-mixed, low-income area, and the City of Moorhead, an ethnically-homogeneous and fairly
prosperous semi-rural community.
The Survey is a clearly-defined — although rather complex — series of activities developed by Eco
Solutions, a 501(c)(3) non-profit group. The Survey focuses on source reduction of wastes, including
hazardous wastes, but also includes water and energy conservation. The technique is based on the
assumption that provision of face-to-face in-home education, with its lifestyle-specific, personal selling,
and hands-on aspects, will produce greater behavior change than general educational materials or mass
media exhortations.
The process actually begins when a person is recruited to participate in the project. The Survey itself lasts
one to two hours, depending on the resident's interest level, and includes:
*preliminary education on source reduction and on the Waste Survey process;
*a tour of the home, including determination of what waste is produced there and how it is
currently handled;
*an explanation of ways to reduce waste production, dispose of hazardous wastes properly,
recycle, and compost, as well as information on the financial benefits of source reduction and the
effects of waste on the environment;
^encouragement of the resident's existing efforts to reduce solid and hazardous waste production;
•"compilation of specific written steps for action that are appropriate to the resident's current
position and lifestyle; and
*provision of written information on source reduction and vendors of waste-reducing products.
The household is recontacted two to three weeks later to gain answers to follow-up questions, collect data
on Survey results, and encourage further action. Forms developed by Eco Solutions are used for the sign-
up, Survey, suggestion, and follow-up processes.
The primary hypothesis of this research is that the Waste Survey causes changes in behavior that will lead
to source reduction, despite the differences in the two neighborhoods. The secondary hypothesis is that
other variables explain the changes in behavior. Nine variables are considered, including gender of
participants, recycling level, neighborhood, and home ownership.
The primary hypothesis was tested using responses to Survey follow-up questions about the suggested
changes in waste handling behavior. Raw scores revealed that 57% of the suggested steps were reported
This research was prepared using U.S. Environmental Pro tec don Agency funds (Grant No. D995771-01-0). Project contributors
include Dayton Hudson Foundation, Mardag Foundation, Ready Fund of the Tides Foundation, State of Minnesota Office of Waste
Management, and the Unity Avenue Foundation.
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to have been done or started three weeks after Survey performance (See Tables I and II). The responses
were also weighted according to a scale designed to measure the amount of waste reduction resulting from
each household's reported post-Survey efforts.
The raw scores, the weighted scores, and the weighted scores divided by the possible number of steps that
could have been accomplished were then tested statistically. Each was cross-tabulated with neighborhood,
size of residence, number of units in the building, home ownership, gender of Survey participants, and
extent of recycling.
The only relationships that reached statistical significance were those between weighted scores and
neighborhood and between weighted scores divided by possible steps and neighborhood. Both
relationships were weak.
Multiple regression was also performed using the above three scoring variations. The previous six
variables were used, plus additional variables representing possible steps implemented and variations in
gender and recycling. Only two variables reached the .05 significance level: possible steps that could have
been implemented and neighborhood. The model in which both of these reached significance had
weighted scores as a dependent variable and reached an R-square value of .24.
These results indicate that the Waste Survey is an effective technique, despite differences in the two
neighborhoods. In both sets of statistical analysis, neighborhood became significant only when the steps
accomplished were weighted. The reasons for differences by neighborhood are not clear and may be
explained by a number of factors other than physical location. The regression model does indicate that
factors other than those measured are at work.
However, the regression model also indicates that none of the variables measured other than neighborhood
is more important than the Survey process. This leads to rejection of the secondary hypothesis so far as
the other variables measured by the research are concerned and strengthens the finding that the technique
is effective. .
The literature on environmental behavior-change does not provide categorical answers to the questions
remaining from this project. One possible reason for the differences between the two neighborhoods that
was not measured is socioeconomic status, but some studies suggest that personality traits, such as being
curious and desiring to avoid personal harm, are better indicators of ecological concern than
socioeconomic factors. . While some literature shows a strong intrinsic motivation to make environment-
related behavior changes, other studies indicate a need for extrinsic motivators (EPA, 1989, citing Kinnear,
Conn, DeYoung and Kaplan, Larson and Massetti-Miller, and Becker). This requires further study.
Policy recommendations that result from this research include:
The Waste Survey should be used in other locations.
Research methods and analysis should be improved in future efforts, including standardization of the time
spent in each'household, closer tracking of historical factors, measurement of additional demographic
variables, and long-term follow-up for Survey households.
Use and improvement of variables that are weighted to measure actual waste reduced are encouraged over
use of nominal measurement of the absence or presence of behaviors.
Further research on residential source reduction should build on earlier findings supported by this effort.
Previous findings that indicated that providing clear consumer information and letting individuals control
outcomes are important in motivating environment-related behavior change are supported here.
According to this and earlier research, the public does not differentiate recycling from source reduction.
This indicates a need to more carefully distinguish between recycling and reduction when designing waste
policy, and probably a need to study and promote source reduction through avenues that are clearly
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separate from recycling activities.
Opportunities for future research are suggested by the results of this project.
An unexpected finding is the lack of a statistical relationship between a household's level of recycling
activity and its adoption of source reduction behavior. If supported by further research, this may be one
of the project's more significant findings, as these two activities are traditionally treated as if they are
similar in terms of motivation, behavioral components, and program design. The two techniques may
require different approaches to succeed.
There is a need to define the differences between who has an environmental "interest" and who has
environmentally positive "behavior." This information would be useful in targeting all waste-related
behavior-changing efforts.
TABLE I
SUGGESTIONS OFFERED DURING HOME WASTE SURVEYS
PHILLIPS
CATEGORIES OF SUGGESTIONS MQORHEAD NHBHOOD. TOTAL
Paper Reduction
Improve Recycling/
Close the Loop
Packaging Reduction
Hazardous Materials
Reduction
Energy Conservation
Water Conservation
Gardening or Composting
Multi-Use Items Over
Single-Use Items
Transportation
68
59
54
37
41
22
10
7
1
58
53
53
48
31
29
10
10
1
126 (21%)
112(19%)
107 (18%)
85 (14%)
72 (12%)
51 (9%)
20 (3%)
17 (3%)
2
TABLE II
TEN MOST COMMON SUGGESTIONS
MINNEAPOLIS
Move to Low-Toxicity Cleaners (25)
Reduce Direct Mail (24)
Recycle All Paper (23)
Toilet Water Conservation (20) '
Use doth Over Paper in Kitchen (17)
Switch to Compact Flourescent Light Bulbs (15)
Reuse Containers/Bags (10)
Purchase Recycled Paper Products (10)
Use Second Sides of Paper (8)
Replace Single-Use Products with Permanent Products (8)
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MOORHEAD
Reduce Direct Mail (26)
Purchase Food in Bulk (25)
Purchase Permanent Coffee Filter (21)
Recycle All Cardboard and Paper (21)
Purchase Recycled Paper Products (18)
Toilet Water Conservation (17)
Low-Toxicity, Concentrated Detergent in Recyclable Container (16)
Purchase in Larger, Recyclable Containers (9)
Seal Windows (8) x
Minimize Aerosols (8)
SOURCES
Brattesani, Karen A. 1990. Seattle Solid Waste Utility 1990 Waste Reduction Survey. Seattle, WA.:
Solid Waste Utility, Seattle Engineering Department.
Chiles, Jim. 1990. Wash or Waste? A Policy Statement on the Dishware Dilemma. St. Paul, MN.:
Minnesota Office of Waste Management.
Cornwall, Bonnie, and Mark Duerr. 1986. Low-Income Energy Education: Is It An Effective Adjunct
to Traditional ECIP and Weatherization Services. Unpublished Manuscript.
Environmental Protection Agency. 1989. Promoting Source Reduction and Recvclabilitv in the
Marketplace: A Study of Industry and Consumer Response to Promotion of Source Reduced. Recycled.
and Recyclable Products and Packaging. Washington, D.C.: U.S. Environmental Protection Agency.
Esposito, Bonnie. 1988. Client Education: Hi Level Weatherization Demonstration Project. Minneapolis:
Minneapolis Energy Office, Department of Jobs and Training. .
Lake, Celinda C. 1989. Environmental Issues and Democratic Candidacies. In The Rising Tide: Public
Opinion. Policy and Politics. Washington, D.C.: Americans for the Environment, Sierra Club,
National Wildlife Federation.
Ritenbaugh, Cheryl K., and Gail G. Harrison. September/October 1984. Reactivity of Garbage Analysis.
American Behavioral Scientist. 51-70.
Ten Percent Saves $10 Billion. January/February 1991. In Business. 6.
Wirka, Jeanne. 1990. Progress and Trends in Waste Reduction Around the Country: Overview. In Solid
Waste Alternatives Project. Building a Grassroots Strategy: Solid Waste Reduction in Minnesota.
Washington, D.C.: Environmental Action Foundation.
Zimmermann, Elliott. 1988. Solid Waste Management Alternatives: Review of Policy Options to
Encourage Waste Reduction. Springfield, EL.: Illinois Department of Energy and Natural Resources.
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City and County of San Francisco
Department of Public Works
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MEASURING THE EFFECTIVENESS OF A PUBLIC EDUCATION PROGRAM
Paula Kehoe |
Environmental Program Coordinator
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In order to meet increasingly stringent discharge limits for toxic pollutants that are not readily removed I
by conventional wastewater treatment methods, the City and County of San Francisco (City) has developed
the Water Pollution Prevention Program (WPPP). The WPPP is a proactive effort consisting of several _
source reduction strategies aimed at reducing the amount of toxic pollutants discharged into the City's •
combined sewerage system (a combined system collects both street runoff and sanitary wastewater for
treatment prior to discharge). The WPPP's source reduction strategies combines both increased _
enforcement for industries and small businesses and public educational and technical outreach for residents I
and small businesses. ™
In order to achieve an overall reduction in the current pollutant loading to the sewerage system, the I
objectives of the source reduction strategies were as foEows: " •
1. Identifying the pollutants of concern; . •
2. Quantifying the sources of the pollutants of concern (residential, commercial and industrial);
3. Developing source reduction strategies to address the sources of the pollutants of
concern;
4. Implementing source reduction strategies; and
5. Developing means to evaluate source reduction strategies.
PoEutants of Concern
In order to determine the constituents of concern specific to San Francisco, the constituents were based I
on the following criteria:
1. Constituents exceeding discharge permit limits; I
2. Constituents potentially contributing to general receiving water problems;
3. Constituents in compliance but near permit limits; . •
4. Constituents contributing to bioaccumulation, and/or biomagnification; and I
5. Constituents contributing to existing and potential sediment toxicity problems (some of these
constituents may also bioaccumulate and/or biomagnify). •
As a result, the City determined that, regardless of discharge point, its eight constituents of concern are:
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1. Metals, primarily:
Copper (Cu), Lead (Pb), Mercury (Hg), Nickel (Ni), Silver (Ag), Zinc (Zn), Cadmium (Cd)
2. Cyanide
3. Polynuclear Aromatic Hydrocarbons (PAHs)
Pollutant Sources
An evaluation of the contributions of the targeted constituents to the influent loading from four principal
sources was performed. The four sources included the following:
1. Water supply;
2. Residential;
3. Industrial; and
4. Commercial/other.
As shown in the Table 1, it is estimated that the residential loadings into the sewerage system appear to
account for between 6 and SO percent of the loadings for the 6 targeted metals and cyanide found in the
influent.
TABLE 1
ESTIMATED SEWPCP LOADING FROM RESIDENTIAL SOURCES
Parameter
Copper
Lead
Mercury
Nickel
Silver
Zinc
Cyanide
Total Residential
Loadings (a)
16.1
5.63
0.23
4.57
0.49
69.06
2.2
Net Residential
Loadings (b)
(ppd)
7.45
0.23
0.23
4.17
0.46
63.1
2.2
Net Percentage of Influent
Loadings (%)
12
26
44
50
6
35
19
(a) Assumes an average residential flow rate of 25.5 mgd.
(b) Net loadings exclude the estimated contribution from the water supply to the total residential loadings.
Assessing the metal contributions from residential sources provided a means to identify the significant
sources of problem pollutants on which to focus the source reduction strategies.
In order to assess the specific residential products containing the problem pollutants, the WPPP
conducted a test of commonly used household products (shampoo, creme rinse, bath soap and toilet
tissue) for 9 conventional heavy metals. The study indicated that these types of products do not
contribute significant amounts of the City's problem pollutants to the wastewater. * As a result of the
study, the WPPP has begun to target the products that contain the pollutants of concern, such as
paints, photographic wastes, used motor oil, solvents and other automotive products.
1 The significance of product contributed heavy metals for other cities and municipalities may vary and will depend on the
characteristics of the individual Cities' metals wastestreams and also their specific wastewater treatment processes.
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By sampling a select group of businesses, the WPPP was able to qualify the pollutants discharged by •
specific types of businesses. The City is currently targeting automotive service facilities, dentists,
hospitals, laboratories, printers, photoprocessors and commercial gardeners for educational and •
technical assistance. 8
Source Reduction Strategies " •
As part of the WPPP, a Public Education Program has been established which is comprised of
educational and technical outreach activities that focus on the products and disposal practices which •
pose the greatest threat to the City's sewerage system. |
To assist the WPPP with educational outreach programs, a Public Education Plan was developed. The •
Plan consists of strategies and program activities for educating both residents and small businesses •
regarding the importance of protecting public health and the environment from the improper use,
storage and disposal of hazardous products. The plan includes programs activities such as newsletters, _
brochures, fact sheets, utility bill inserts, point of purchase displays, posters, storm drain stencilling •
and small business workshops. The Plan also includes lists of distribution channels, such as T.V.,
radio, newspaper, environmental group and community group contacts.
Implementing Source Reduction Strategies
To better direct public education and outreach measures, a Public Awareness survey was conducted in •
three languages over eight diverse geographical regions of the City. The survey assessed residents use
of toxic materials, perceptions of health risks, normal disposal practices, support and willingness to •
pay for new disposal services and educational programs and the sources of information on I
environmental issues. The results from the survey suggests that awareness of the consequences of
improper disposal tends to reduce its occurrence. . •
The survey also provided guidance on which media to use to reach certain demographic groups in
educational outreach programs. In terms of where respondents received news and information on •
environmental issues, there was meaningful variation according to social class, race/ethnicity and J
environmental activism. Respondents who reported higher income and education levels are more
likely to read newspapers for information on environmental issues; those reporting lower levels of
income and education rely more upon television. The environmental activists interviewed in our
survey clearly rely on neither of these, preferring the information channels provided by their
environmental organizations and activities. This suggests mat both print and broadcast media should
be used selectively, perhaps in joint efforts with environmental groups, to promote citywide awareness
of environmental problems. This survey will be repeated to assess the impacts of outreach programs
on attitudes and behaviors relative to the baseline results.
The WPPP implements public education programs through a variety of community outreach efforts
which target specific products. Some of the programs include: recycle used motor oil campaigns,
healthy house tours, street fairs, speakers bureaus, workshops and school curricula.
Means to Evaluate Source Reduction Strategies
To evaluate the City's public education outreach efforts, we have developed several tools to help
measure the effectiveness of the public education programs that are implemented.
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For example, if the .WPPP conducts a campaign on the proper disposal of household hazardous waste
at the permanent collection facility or used motor oil at the various City locations, the following is
used to evaluate the effectiveness of the outreach:
1. Phone calls or written requests for information on the facility or used oil collection
locations; and
2. Monitors the participation rates at collection centers (Household Hazardous Waste
Collection Facility and used oil collection outlets).
If there is a significant response or increased participation at the collection centers, it appears the
outreach program was successful and additional outreach efforts will incorporate similar strategies.
However, if there is little response or turnout, the methodology will be revised.
When the WPPP attempts to assess the effectiveness of the entire Public Education Program, we use a
different set of tools, such as:
1. Comparisons of the bi-annual public awareness phone survey results;
2. Review the number of illegal dumping and abandoned waste reportings;
3. Compliance and sampling results from small businesses;
4. Analysis of the water pollution control plants influent and effluent quality; and
5. Review of data collected from the City-Wide Collection System (sewer) Monitoring
Program.
Although these measures have been developed, the City is aware that measuring behavioral change is
difficult and no one tool can truly reflect the successes and failures of public education outreach.
However, by-implementing several monitoring tools at the same time, it can help to determine the
outreach programs that actually encourage behavioral change and the ones that do not.
Conclusion
Prior to implementing a public education program, regardless of the media (air, land or water) a
strategy should be developed that focuses on the products that pose the greatest threat. For example,
in San Francisco residents contribute some of the City's pollutants of concern. Used motor oil and
paint products contain these pollutants, thus, one of the City's major residential outreach campaign
targets proper storage and disposal of used motor oil and paint products.
In closing, as part of any public education program, a means to evaluate the effectiveness of the
program should be developed. Although behavioral change is sometimes hard to measure, it is
extremely important to assess a program's ability to reach the general public and promulgate
behavioral change. San Francisco' has opted to conduct annual surveys, monitor catch basins and
review participation rates to evaluate the effectiveness of the public outreach programs and will
continue to modify the outreach strategies based upon the results of these measures.
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I.
II,
HOUSEHOLD HAZARDOUS WASTE MANAGEMENT
SEVENTH NATIONAL CONFERENCE
CONSUMER PRODUCT SAFETY COMMISSION (CPSC)
WASHINGTON, DC 20207
(301) 504-0400 .
Chuck Jacobson
Chronic Hazard Labeling Guidelines
CPSC - The Agency
An independent federal regulatory agency established in
1973 to:
(1) protect the public against unreasonable risks of injury
associated with consumer products;
(2) assist consumers in evaluating the comparative safety
of consumer products;
(3) develop uniform safety standards for consumer products
and to minimize conflicting State and'local regulations;
(4) promote research and investigation into the causes and
prevention of product related deaths, illnesses, and
injuries.
Laws Administered by CPSC:
Consumer Product Safety Act (CPSA), 15 U.S.C. 2051
Federal Hazardous Substances Act (FHSA), 15 U.S.C. 1261
The FHSA was amended 11/18/88 by the Labeling of
Hazardous Art Materia-ls Act (LHAMA) (P.L. 100-695)
which requires the development of chronic hazard
. . guidelines. LHAMA became effective 11/18/90.
Flammable Fabrics Act (FFA), 15 U.S.C. 1191
Poison Prevention Packaging Act (PPPA), 15 U.S.C. 1471
Refrigerator Safety Act (RSA), 15 U.S.C. 1211
All the regulations for the laws administered by CPSC are
in Title 16 of the Code of Federal Regulations (CFR).
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require all producers or repackagers, including importers,
of art materials to:
1. Submit all' art material formulations to a board
certified toxicologist to determine whether an art
material has the potential for producing chronic
adverse health effects. This review must be
repeated at least every 5 years thereafter.
2. Describe in writing and submit to the CPSC the
criteria used to determine whether art materials
have the potential for producing chronic adverse
health effects.
3. Restrict, through marketing or labeling or both,
the use of products which have the potential for
producing chronic adverse health effects, to adults
or children above grade 6.
4. Include, preferably on the label, a conformance
statement on all art materials such as "Conforms to
ASTM D 4236" or a similar statement.
VII. Chronic Toxicity Guidelines.
The Labeling of Hazardous Art Materials amendments required
the Commission to issue guidelines which specify criteria
for determining when any customary or reasonably
foreseeable use of an art material can result in a chronic
hazard.
Chronic hazard guidelines were proposed in the Federal
Register April 17, 1991. A public hearing was held on this
proposal October 17, 1991. The guidelines were finalized
in the Federal Register October 9, 1992 and are now part of
16 CFR 1500. While these guidelines were prepared as a
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hazardous products, both hazardous chemicals and food,
drug, or cosmetic products,,-by children under the age of
five years. The following chemicals commonly found- in and
around households are subject to PPPA standards:
1. Sodium and/or Potassium Hydroxides at levels of 10% in
dry forms or 2% or more in other forms.
2. Turpentine at levels of 10% or more.
3. Methyl Alcohol (methanol) at levels of 4% or more.
4. Sulfuric Acid at levels of 10% or more.
5. Ethylene Glycol at 10% or.more. ,
6. Petroleum distillates, toluene or xylene at levels of
10% or more with a viscosity of less than 100 Saybolt
Universal Seconds at 100 degrees F., in products which are
kindling or lighting fuels or paint solvents.
7.. Glue removers containing more than 500 mg of
acetonitrile per container.
VI. Labeling of Hazardous Art Materials Act (LHAMA)
P.L. 100 695.
LHAMA.was signed into law November 18, 1988, amending the
FHSA by requiring that the labeling requirements of ASTM D-
4236, a voluntary standard, be deemed to be a regulation
issued by CPSC under Section 3(b) of the FHSA. This
amendment became effective November 18, 1990.
t r
The requirements imposed by LHAMA '-are in addition to those
already existing under the FHSA. The amendments will
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III. Products subject to regulation by CPSC.
The term "consumer product" includes any article for sale
to or use by a consumer with the exception of articles
regulated by other federal agencies, such as tobacco
products, motor vehicles for highway use, pesticides,
firearms and ammunition, aircraft, boats, foods, drugs, and
cosmetics. The CPSC does have limited authority over
>
foods, drugs, and cosmetics for special packaging under
the Poison Prevention Packaging Act.
IV. Chemical Labeling Required Under the Federal Hazardous
Substances Act (FHSA).
This law was passed in 1960 to cover household products
presenting the hazards of toxicity, flammability,
corrosiveness, irritation, sensitization, and pressure.
In addition to labeling the law also provides that products
can be banned from interstate commerce if cautionary
labeling is inadequate to protect the public health. The
FHSA also regulates toys and other articles intended for
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use by children which are hazardous.
The existing law and regulations has always required
cautionary labeling for both acute and chronic toxicity.
However, in 1988 the FHSA was amended by the Labeling of
Hazardous Art Materials Act which specifically addresses
chronic hazard labeling for art materials and adds
additional other requirements for the producers of art
materials.
V. Packaging Requirements Under the Poison Prevention
Packaging Act (15 U.S.C. 1471}
The child resistant packaging standards which have been
promulgated are intended to temporarily restrict access to
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result of the art material amendments, they can be used for"
•
•
the evaluation of the potential hazards of any consumer
product.
VIII. Source Reduction and Waste Management.
The safety of the consumer and their family in attempting I
to utilize home preparations in place of commercially
available products. I
Avoid improper mixing of chemicals. Chlorine bleach,
ammonia, and some cleaning chemical can produce very toxic
gases when improperly mixed. If the product does not have
specific instructions for mixing, don't mix it with other
chemical products.
Provide proper storage for hazardous waste products, keep
them out of the reach of children as you would any other
hazardous material.
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Don't purchase more than you need for your foreseeable use.
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•^Scientific Certification Systems
Green Cross Certification Program
Stanley Rhodes
+ Facts About Green Cross +
Neutral Third Party Certification
Not-for-Prolit
Experienced in the Field of Certification
National In Scope
Non-Exclusive
Independent Scientific Standards Board
Verification of
Current Environmental Marketing Claims
Potential Claims in Recycling Arena
Recyclable • Recycled Content • Recycling Rates
Auditing of Sources
of Recycled Material Inputs
Paper
Mill
Broker
Broker
Broker
City of
Los
Angeles
Book
Mftr.
Boy
Scouts
Cclendar
Mftr.
Los
Angeles
Times
Envelope
Converter
Audit Process:
• Evidence of sources and their volumes
• Accounts payable records • Telephone calls
• Plant receiving records • Litters
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Recycled Tonnage Under
Green Cross System
Green Cross: Over 5 million tons
'ota! U.S.: 23.4 million tons
Plastics Aluminum Steel Glass Paper
Energy Use
Ptr caplU tiwgy contumpHon (million 8TU)
Canada
Norway
United States
jni*0o Mr3D tmirdtss
USSR
West Germany
United Kingdom
Japan
China —
0 SO 100 ISO 200 250 300 350
Sours*: World B*nk -
Japan
2.7 times more energy efficient than U.S,
West Germany
1.7 times more energy efficient than U.S.
State-of-the-art
Energy Efficiency
(Determined by product category)
Incandescent bulbs
Compact fluorescent bulbs
Measured as energy savings over
rated lamp life at 80/KWH
;Hfr||^
; Every year, 100 billion food and beveraga
.containers are used In tn» U.S. Most k> mamtga
'
Recycling in
LosAngeJes
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Green Cross Life Cycle Certification
Historical Development of Eco-Labels Environment^ Burdens
/. Raw Materials Consumption
2' EnerSy Consumption
3. Emissions into the Air
4. Emissions into Water
5, Solid Waste Generation
6. Ecological Damage
Comparison of Products
Life Cycle Inventory (LCI)
INPUTS
Energy
> Raw
Materials
> Ecological
Damage
System
OUTPUTS
• Air
Emissions
> Water
Emissions
- Solid
Waste
System Environment
Green Cross
Technical Foundations
and Support
• Interdisciplinary Scientific Staff
• Boustead LCA Model
• SNCLavalin —
Engineering Support
• Good Housekeeping Institute —
Development of Product
Efficacy Protocols
• National Food Laboratory —
Food Analysis
c
I
100% Virgin Piper
Btlnroom TIuiw
• 100% RtcycM Piow
BMiueem T)»u*
PlptrToml
Hiuubl* Cation
KMcnwi TOW.I
Napkin
a a
100% Virgin
TlMh Bag
100% MerdM
TmftBtg
Industrial Processes:
Performance Improvement
Over Time
10Q% —
95-
90-
U-
10-
75-
70-
«3-
M-
33
10
15
Tim*
2S
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';.}
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Scientific Certification Systems
Life Cycle Inventory Steps
Define
Project
Prepare
Flow
Diagrams
Prepare
Inventory
Data Sheets
Site
Inspection(s)
(2-3 visits
per site)
Data
Management
Presentation
of Findings
to Client
la. Identify scope of project — i.e. product(s) to be evaluated.
Ib. Define system(s).
Ic. Define project objectives.
Id. Write Proposal.
le. Identify project manager and client technical teams
2a. Collect existing flow diagrams/schematics from client engineer
2b. Prepare flow diagrams for each component of each system
being examined, including all potential inputs and outputs
3a. Generate inventory data sheets reflecting each component
identified in flow diagrams.
3b. Determine what documentation will be required for
initial documentation review (e.g., invoices for materials purchases)
3c. Determine which site(s) should be physically inspected
4a. Review inventory sheets
4b. Assist in completion of inventory sheets where additional data is needed
4c. Examine technical processes to ensure full consideration of factors
4d. Confirm flow diagrams and make modifications as required
4e. Conduct preliminary review of relevant documentation (e.g., invoices,
accounts receivable), including discussions with client technical team
5a. Prepare data input sheets — Reduction of Raw Data
5b. Input data
5c. Complete initial calculations
5d. Conduct internal SCS technical team review of calculations
5e, Revise input sheets as needed based on review
5f. Input new data as needed
5g. Complete final calculations
5h. Final SCS technical team review
6a. Submit detailed LCI Report, covering project scope, purpose
methodology and assumptions, and summarizing findings
6b. Review findings with client
Certification
7a. Full audit of records, invoices, and support documentation
7b. Sampling and testing to confirm emissions data
7c. Final inspection
7d. Issuance of Environmental Rcpon Card and corresponding Fact Sheet
7e. Development of Quarterly Update Certification Plan
7f. Quarterly Monitoring 3 5 5
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1
Deforestation Concerns
I
• Tropical Forests
• Tropical forests are disappearing at the rate of 100 acres per minute.
• • This trend is due primarily to mining, slash and burn agriculture, logging,
hydroelectric projects, clearing\for plantations, and cattle ranching.
* • Tropical rainforests now cover only 2% of the Earth's surface, yet are
_ home to more than one-half of the world's living species.
• If this trend continues, most of the remaining rainforests will disappear in less
• than a single person's lifetime.
• By early next century, we could lose a million or more species of plants, animals,
I and other organisms - the greatest mass extinction in geologic history,
including the loss of the dinosaurs.
I
Temperate Forests
» • Over a 300 year period (1630 to 1930), about 35% of all temperate forest lands
were cleared.
* • In the U.S. alone, 60,000 acres of ancient forests are being cut per year.
§ • Most severely affected are the national forests of the\Pacific Northwest, from
which 5.5 billion board-feet of timber were harvested in 1987, and Alaska's
ITongass National Forest, where as much as 50%of the most productive forest
land has been logged since 1950.
• • Tree planting and the reforestation of agricultural land has increased forest
* cover in the United States to nearly 3 million square kilometers:
The period of regrowth can be up to 100 years or more.
Replanting has not replaced the native habitat lost
when the virgin forest was harvested.
I
I* The loss of habitat has threatened many native plant and animal species. In the
U.S. alone, 581 different species are now federally designated as threatened or
endangered.
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Definition of Terms
Life Cycle Inventory (LCI)
An objective data-based process of quantifying energy and raw
material requirements, air emissions, waterbome effluents, solid
wastes and other environmental releases throughout the life-cycle
of a product, process or activity.
Life Cycle Analysis (Impact Analysis)
A technical, quantitative and/or qualitative process to characterize
and assess the effects of the environmental loadings identified in
the inventory component. The assessment should address both
ecological and human health considerations, as well as such other
effects as habitat modification and noise pollution!
Life Cycle Assessment (LCA)
An objective process to evaluate the environmental burdens associated
with a product, process or activity by identifying and quantifying energy
and materials used and wastes released to the environment, to assess
the impact of those energy and materials uses and releases on the
environment, and to evaluate and implement opportunities to affect
environmental improvements.
Long Term Program Goals
• Build an independent environmental data base
that is specific to the vendors supplying products
to retailers, institutional buyers, and government
procurement agencies.
• Support buyer efforts to optimize their
environmental choices with coherent, comprehensive
environmental information.
• Help policy makers in their efforts to set down
policy on the most sophisticated basis possible.
• Build a broad consensus on what constitutes
a significant environmental claim or set of claims.
• Educate consumers about the full range of
environmental factors associated various product
and packaging choices.
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Remarks of James B. Dougherty
Vice President and General Counsel
Green Seal, Inc.
Eighth Annual HHW Conference
Minneapolis, MN
December 10,1992
• Green Seal is both a:
Symbol: Green Seal is a symbol of environmentally preferable products.
Seen on a product it means the product has been tested and meets Green Seal's
rigorous environmental standards for that particular type of product; and a
Concept: We believe that the power of the marketplace can be harnessed to
give us a cleaner world. Green Seal is dedicated to improving the quality of our
environment by identifying and promoting products and services that can succeed
in the marketplace while causing significantly less harm to our environment.
• We are not alone: 22 Countries have or are developing a Green Seal-type
program:
Blue Angel in Germany
Canadian Environmental Choice
European Community
All of these programs use a process similar to Green Seal's.
• Green Seal is a response to people's desire to buy products that cause less
harm to our planet. Study after study have reported that 4/5 people want to buy
"green products."
• But consumer confusion remains a problem. Last year, 13% of new products
were labeled "green." A 1991 Gallup Poll found that the Green Seal program would
have more of an impact on consumer purchasing decisions than company claims or
even government guidelines.
• Why should consumers trust Green Seal?
• Non-profit, tax exempt 501(c)(3) organization
• Member of ANSI; we employ time-tested public standard setting
process. All of our standards are subject to public comment before
being issued
Green Seal • 1250 23rd Street NW. Suite 27S > Washington DC 20037-1101 • Telephone [202] 3317337 • Fax |202| 3317S33
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• Balanced leadership: business, environment & consumer interests
• Strict Code of Ethics prohibiting conflicts of interest _
• Other organizations that have teamed up with Green Seal:
• Strategic alliance withUnderwriters Laboratories. _
• Clean Product Center of the University of Tennessee •
The Green Seal Process: •
• Category Selection
• Standard Setting •
• Environmental impact evaluation. J
• Standard setting and public review
• Product Evaluation
• Product Testing by UL or another qualified lab.
• Certification
• Compliance Monitoring •
• Quarterly unannounced inspections and testing •
• Status of program •
• First seals to be awarded in February: 5 brands of tissue product. •
* 14 products undergoing review
• Issued standards covering 31 product categories •
• Standards under development in ten other categories, including: •
Batteries - current draft would establish toxicity limits for Arsenic, Silver, fl
Chromium, Lead, and Cadmium. Would also require compliance with TCLP. •
Lead-acid, nickel-cadmium, and silver-oxide batteries would have to returnable via
a collection/recycled system maintained by the manufacturer, and well labeled;
Paints - current draft standard would prohibit the use of several dozen toxic
substances, such as lead. Standard would also limit volatile organic compounds
(20% for high-gloss, 10% for medium, 5% for flat finish). Compliance with
performance requirements (e.g., opacity, scrubbability, etc.) also required.
Engine Oil Standard (GS-3), published 2/92, requires that base stock contain at least
25% recycled re-refined oil. Base stock must meet limits for several toxic
contaminants. No sulfuric acid sludge may be generated during manufacture.
All Green Seal standards require compliance with CONEG-style packaging
requirements.
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Should All Constituents of Hazardous Products be Listed on the Label?
Philip Dickey
Household Toxics Project Director, Washington Toxics Coalition
Seattle, WA
Introduction
The product label is the consumer's main source of information about the products they
are about to buy. It performs many important functions, including identifying the product
on the store shelf, explaining how to use it, and warning about safety hazards. The label
also contains information on ingredients...sometimes.
Anyone who buys a package of cookies can read the label to find out what ingredients
are in the cookies before buying them. Yet the bulk of the contents of a roach spray in the
next aisle of the store are not disclosed. The reason for this discrepancy lies in the fact that
the two products are regulated by different federal agencies with different rules for product
labeling.
In this talk, I would like to discuss some aspects of the question as to whether or not
complete ingredients lists should be required on products. There are many topics of interest
having to do with product labels, but I will try to confine my remarks to the question of
ingredients lists.
Current Listing of Ingredients
At the present time, consumer products which we might consider are regulated by one
of three federal agencies. These agencies have different requirements for ingredient
disclosure.
1. Pesticides
Consider first pesticides, which are regulated by the Environmental Protection Agency
(EPA) under FIFRA. Some typical household pesticides are lawn and garden insecticides
and herbicides, indoor insect sprays, rat poisons, mothballs, and wood preservatives. They
also include disinfectants and disinfecting cleaners, including chlorine bleach.
EPA's ingredient labeling requires a listing of all active ingredients, with their common
and chemical names, along with the percentage present in the formulation. Consider for
example the label shown in Figure 1. Active ingredients are those which perform the
specific pesticidal function. All other ingredients are termed "inert." The total percentage of
"inert" ingredients is listed on the label, but the identity of the specific chemicals is not
usually disclosed. Of the some 1800 "inert" ingredients currently used in pesticide
formulations, only the approximately 60 "inert" ingredients considered of "lexicological
concern" must be disclosed. Most "inert" ingredients are considered to be of unknown
toxicity. An example of a pesticide with a disclosed inert ingredient is shown in Figure 2.
Figure 1. A Typical Ingredients List for a Pesticide
Active Ingredient
*Chlorpyrifos (0,0-diethyl 0-(3,5,6-trichloro-2-pyridyl) phosphororothioate] 0.50%
Inert Ingredients 99.50%
*DURSBAN™—Reg. TM of Dow Chemical Company for Chlorpyrifos Insecticide
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Figure 2. A Pesticide Label in which an "Inert" Ingredient is Identified
COUMANT
CONTAINS WATER'OIEICACC.ETHANOL.
AMINf • 60PROPYL ALCOHOL • UNOtEAM-
ID£ D£A • OLEAMIOE OEA • PEG-2 COCAM-
INE • TEA-LAURYL SULFATE • POTASSIUM
COCO-HYDROIVZED COLIAGEN • FRA-
GRANCE • LANETH-5 • SODIUM SULHTE *
PPG-40 BUTYL ETHER • ERYTHORBIC
ACID • TETRASOOWM EOTA • P-PHENYl-
ENEDIAMINE * P-AMINOPHENOL •
RESORCINOL • 2-METHYlRESORCINOL • 2- y
CHLORO-P-PHENYlfNECXAMII* SUlfATE •
4-AMW0.2-HYCRO(YTIXUENI
C8EAM DEVELOKR
CONTAINS VWER • HYDROGEN PEROXIDE
• CETEARYl ALCOHOL • C£TEARETM-20 •
MINERAL OIL • SODIUM LAURYL SU.FATE •
METHYLPARABEN • SODIUM PHOSPHATE •
PHOSPHORIC ACID
KVlOtTS COHDITIONIN6 SHAMPOO
CONTAINS WKTER • TRlOECETH-7 CARBOX-
YLIC ACID • COCOAMPHOOIPROPIONATE •
LAURAMIDE OEA • GtYCa STEARATE • FRA-
GRANCE • POirQUATERNlUM-IO • GUAR
HYDROXYPROPYLTRIMONIUM CHLORIDE •
PANTHENOl • CITRIC ACID • OlSOOIUM
EDTA'MfTHYLCHlOROlSOTHlAZaiNONE •
METHYLJSOTHWaiNONE • METHYLPARA-
BEN*PROPYLPARABEN
CAUTION: THIS PRODUCT CONTAINS
INGREDIENTS WHICH MAY CAUSE SKIN
IRRITATION ON CERTAIN INDIVIDUALS AND A
PRELIMINARY TEST ACCORDING TO
ACCOMPANYING DIRECTIONS SHOULD
FIRST BE MAW THIS PRODUCT MUST NOT
BE USED FOR DYEING EYELASHES OR EYE-
BROWS TO DO SO M» CAUSE BLINDNESS
COLOftSIlK IS A REGISTERED TRADEMARK
OFREUON.INC
MADE IN USA
4'RFAft.ON.INC,N.Y,NY 10022 8695-42
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Active Ingredients . mm
'Chlorpyrifos [0,0-diethyl 0-(3,5,6-trichloro-2-pyridyl) phosphororothioate] ............ 0.5000% I
Xylene range aromatic solvent [[[ 0.3000% *
d-trans Allethrin (allyl homolog of Ginerin 1) [[[ 0.0500%
Related compounds .............................................. . ........................................... 0.0036% •
Petroleum Distillates [[[ 4.0000% |
Inert Ingredients** ............................. . [[[ 95.1164%
*Dursban™ — Reg. TM of the Dow Chemical Company for Chlorpyrifos Insecticide
** Includes petroleum distillates •
.2. Food, Drugs, and Personal Care Products •
Products which are put in or on the body are regulated by the Food and Drug . |
Administration. As most of you are probably aware, some aspects of food labeling have
been receiving alot of attention lately, but listing of ingredients is not one of them. —
Currently these products must list all ingredients. Sometimes, particularly on personal care I
products, the list can be pretty long. Figure 3 shows the ingredients list on the box for a ™
hair color product.
Figure 3. Label for a Hair Color 0
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3. Other Consumer Products
Products not covered by EPA or FDA generally fall under the purview of the Consumer
Products Safety Commission. These products include most household cleaners, adhesives,
paints, and automotive products, to name a few.
The labeling requirements for these products are the most difficult to understand and
result in widely varying numbers of ingredients being listed. The law states that if a product
is considered "hazardous" (or "extremely hazardous") by CPSC, it must bear "the common
or usual name or the chemical name ... of the hazardous substance or of each component
which contributes substantially to its hazard, unless the Commission by regulation permits
or requires the use of a recognized generic name." In other words, if a product is
considered hazardous, it must list the constituents responsible for the hazard.
The simplest way for a consumer to determine if a product regulated by CPSC is
hazardous is to look for one of the signal words CAUTION, WARNING, or DANGER: If
these words are present, at least one ingredient should be listed.
The label for a spot remover, shown in Figure 4, indicates that the product is both
flammable and harmful if swallowed. This particular product contains only one ingredient,
naphtha, which is responsible for both hazards.
Figure 4. Product Label for a Spot Remover
DANGER: FLAMMABLE.
HARMFUL OR FATAL IF SWALLOWED.
Contains 100% Naphtha.
RWD.C.OFA.N0.40M
Oo not store or use near heat, sparks, or flame. Use only
with good ventilation • provide constant flow ol fresh
air Avoid repeated or prolonged breathing of vapo-.
Avoid contact with eyes or skin. Close container tightly
after each use and store only with container closed.
KEEP OUT Of THE REACH Of CHILDREN.
FIRST AID: EYES • Flush eyes with water (or at least
15 minutes. IF SWALLOWED • Do not induce vomit-
ing Call physician immediately. SKIN - Remove
contaminated clothing. Flush skin with soap and
water. INHALED - Move user to fresh air. Maintain
respiration.
Call a Poison Center, emergency department, or
physician immediately.
MOTE TO PHYSICIAN: Severe lung aspiration hazard.
U3tNEAHBBEOBRJUg.HCTqc.onic.
The drain cleaner shown in Figure 5 is a multi-ingredient product. It is both corrosive
and chemically reactive. The listed ingredients sodium hydroxide and sodium hypochlorite
are responsible for those hazards. '
Most laundry detergents are eye irritants because they contain both surfactants and
alkaline salts. The three products shown in figure 6 present similar irritation hazards, but
the extent of the ingredients disclosed is quite different. The product on the right lists only
one ingredient.
Finally, products not considered hazardous according to CPSC do not need to list any -
ingredients at all. Examples include most window cleaners, dishwashing liquids, and some
all-purpose cleaners, such as Murphy's Oil Soap.
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Figure 5. Product Label for a Drain Cleaner
LIQUID
Dfdno
DRAIN OPENER
Deodorizes 95 it clears!
CAP INSTRUCTIONS: To Open: Push cap
down white unscrewing. To Lock: Push
down and screw cap on tightly.
•tfesdves hair fast • Loosens food dogs • Won't
harrn disposers, pipes, porcelain, or .septic tanks.
mPOflTANT: READ STORE LABEL KTOflf USWG.
Open carefufty. Do not squeeze bottle. Pour slowly and
avoid splashing. Keep hands, face, and children away from < /
,,-ams while using Drano Clean up spits at once Never use a /3
plunger or pressurized drain pipe opener during or after use of Drano
because Dram may sti be present rf drain ox) not completely dear. Do not
reuse empty container. Rinse container and replace cap before dtanJng.
DIRECTIONS FOR USE:
FOR CLOGGED OR SLOW RUNNING DRAINS
rtk slowly
werfram
m taWE DISPOSER: Follow same directions as for other drains If drain has not cleared,
•;• tjm on disposer yoc^OraY.3 may splash back. Consult plumber.
DANGER: HATFUL IF SWALLOWED. MAY BURN EYES, SKIN AND MUCOUS «*
BRAKES ON CONTACT.Certains 1.7% sodium hydroxide and 6% sodium hypochtorite. Dong
use or mix liquid Drano with ammonti, toilet bowl cleaners, household cleaners or other *an
cleaners. Mixture may release hazardous gases or cause violent eruption from drain. If gases
are released, leave area immediately-ventilate if possible.
FIRST AID: GIVE IMMEDIATELY. EYES: Rinse immediately with water. Remove contw
lenses, men flush eyes with water tor 15 minutes SWALLOWED: Rinse mouth. Drink a gas-
M of milk or water. Do not induce vomiting. SKIN: Remove affected clothing. Rush sto wro»
water for 15 minutes. ' „„._
' THEN CALL POISON CENTER. EMERGENCY ROOM. OR PHYSICIAN AT ONCE
"• = KEEPTJUT OF REACH OF CHILDREN •••
ingreo*ns wjwi soOumrtypocwofrte soflwmftirOroiide.soaiumctiiofide.oofrosor'***'.*]***
Questions about Orino? Call Toll-fret VMO-632-16M. CONTAINS HO PMOSWORW, .
© 1984 THE DRACKETT PRODUCTS COMPANY, CINCINNATI, OHIO45231
U.SA. DISTRIBUTOR »-«**«*• v
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Figure 6. Ingredients Lists for Laundry Detergents
HELPFUL HINTS
OTHER
CLEANING USES
Dash can clean washable sur-
faces such as tile floors and
wails. Just odd ft-Mr cup of Dash
to each gaflon of water. In addi-
tion, Dash can be used on deli-
cate Items, such as hosiery and
lingerie, which are washed by
hand. Best results are achieved
with warm water, gentle action,
and a thorough rinsing.
INGREDIENTS: Cleaning
agents (anionic surfactants),
water softeners (either complex
sodum phosphates or olumlx)*
cates, sodium carbonate),
processing olds (socfum sutfate),
washer protection agents (sodum
silicates), fabric whjtener. soil
suspending agent, colorants and
perfume. "*
The surfactants in Dash are
btodegrodabte.
PHOSPHORUS CON1ENT
If the code stomped into the
bottom of thfe box ueyjns wflh
"0", this Lemon Dash formula
fttfnt leu than 0.5% phot-
phorus by weight, uNch k equiv-
alent to 0.5 grams per 1 cup
use level If to code begins wflh
"L", mis Lemon Dash formula
averages 3.5% phosphorus in tt»
form of phosphates, which H.
equivalent to 3.7 grams per 1
cup use level. If tie code begft
wflh "p", t* lemon Dash form-
ula averages 4.6% phosphorus
which Is equivalent to 4.4 grams
, IMF Y cup uje tovel
*~~** _% -~ ~
STAINS
To help remove stains, make a paste
using about a teaspoon of COLD
POWER and a smalt amount of
water. Place the paste on the
stained area and rub. Wash the item
as usual.
BLEACHING
If you use chlorine bleach, add it
four to six minutes after wash cycle
begins. This gives COLO POWER'S
whitening and brightening system a
better chance to function and allows
the bleach to do its job, too. For safe
and effective cleaning, you may
wish to use AXIOM' BLEACH
ALTERNATIVE in place of chlorine
bleach.
PRE-SOAKING
Soak washioads for at least 1 'hour
using 1 /3 cup of COLD POWER per
gallon of water. For best results,
add 2-3 tablespoons of AXIOM*
BLEACH ALTERNATIVE per gallon
of warm water and soak overnight.
Then wash in COLD POWER as
you normally would.
CAUTION:
Contains carbonate, silicate, and linear
alkylbenzene sulfonate. Avoid contact
with eyes and mucous membranes. Do
not take internally. KEEP OUT OF REACH
OF CHILDREN.
FIRST AID:
In eye* flush 10-15 minutes with water. If
irritation persists, contact a physician.
Internal—give large amount of milk or
water. Contact a physician.
BIODEGRADABLE
CLEANING AGENTS:
The cleaning agents in COLD POWER
are biodegradable. This means that these
ingredients are broken down into simpler
compounds by natural biological action.
This capability helps to eliminate suds and
foaming problems in our lakes and
streams.
SEE BACK PANEL FOR USAGE
AND WASHING INSTRUCTIONS
Woolite
Gentle cyde
powder
Specially made tor the
gentle cycle. Dissolves
quickly. Cleans effec-
tively and safely.
CAUTION: Contains
Alkyl Aryl Sodium
Sulfonate. In case of
eye contact, flush with
water. Call Physician.
KEEP OUT OF REACH
OF CHILDREN
CONTAINS
NO PHOSPHITES
The cleaning agents in
are biodegradable
which allows them to be
broken down into sim-
pler compounds by na-
tural biological action.
This capability helps
eliminate suds and
foaming problems in
our lakes and streams.
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Problems with the Status Quo . . •
The current labeling system, with its different requirements for different types of
products, presents some problems for the consumer, for public interest groups, and for •
local governments. |
1. Consumers have a basic right to know what chemicals they are being exposed to. .
Anyone can read the ingredients on a package of cookies before buying them, but all of •
the ingredients in a pesticide or a claening product are not disclosed. The listing of ™
ingredients on food and drug products is presumably based upon the feeling that
consumers have a right to know what they put in their mouths or on their skin. Why should •
that same right not extend to much more hazardous products that consumers may breathe or I
absorb through their skin when they spray pesticides, paint walls, or clean their house?
These routes of exposure are just as important as ingestion. The issue can be particularly •
important for chemically sensitive individuals, who can react violently to many chemicals I
and need to be aware of products that may cause them harm.
2. Differences between federal requirements for listing ingredients on household products •
are confusing for the consumer; "
The differences between the labeling systems used by the three federal agencies make it
difficult for consumers to compare products in the store. The average consumer is not •
aware of who regulates product labels, so they cannot take these differences into account. p
Products regulated by two different agencies are sometimes side by side on the shelf, and
the consumer may be making a choice between them. Consider, for example, a choice •
between a chlorine bleach and a powdered bleach. Or between a cleaner which is registered ' I
as a disinfectant, like Pine-Sol, and one which is not. The products regulated by EPA will
list fewer ingredients and will lump the rest under "inert" ingredients.
3. Incomplete ingredients lists make it difficult for consumers to practice source reduction 8
by selectively buying the least harmful products.
The listing of ingredients on CPSC regulated products is primarily driven by health •
hazards. Ingredients which pose mainly an environmental risk may not be listed. Consider |
the spot remover called "Just 'n Time." No ingredients are listed on the label. The product
is claimed to be "non-hazardous when used as directed." When I obtained a Material Safety _
Data Sheet for the product, I learned that it contains up to 30% 1,1,1-trichloroethane I
(TCA). TCA is an ozone depleting chemical which will be phased out under both the Clean ™
Air Act and the Montreal Accords. However, a consumer who wishes to do their part to
reduce the use of ozone depleting substances now is hampered from doing so because •
many products do not list ozone depleting chemicals. Similarly, TCA is a common inert •
ingredient in pesticide formulations. I recently learned that a pyrethrin-based insecticide
spray which is often considered a less-hazardous alternative to some kinds of insecticides •
contains TCA as the primary solvent. Not only is it difficult for consumers to find the I
safest product, it is equally difficult for public interest groups, authors of books, and even
local government authorities to find these products.
4. The term "inert" on pesticide labels is misleading. . • •
The word "inert" has many different meanings. According to the dictionary it means:
"without active chemical or other properties, incapable of reacting." I have spoken to many •
individuals about pesticides, and I always ask them what the term "inert" ingredients |
means. I have rarely encountered anyone outside of the technical arena who understood
what this term means. Most consumers interpret it as meaning something like "harmless."
Given the relatively high percentage of "inert" ingredients in many home pesticides, the
result of this nomenclature is that (a) the identity of the bulk of most hazardous pesticides is
kept secret from the purchaser and (b) the potential hazards posed by these ingredients are
cloaked with a benign sounding term which often is not justified,
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5. Some products list ingredients, some list ingredient functions, some list trade names.
Many products go beyond what is required by law and list all or most ingredients.
Unfortunately, since the naming of these extra ingredients is not required by law, their
listing does not conform to any particular standard. As a result, some products merely list
ingredient functions such as "anti-redeposition agent" or "quality control agent." These
"secret agents" are sometimes described in a way that is not particularly enlightening to the
consumer. Other products use trade names which have meaning only to the companies
themselves, such as "Chlorinol" and "Halophor.". These "ingredients" are put on the label
as advertising, to make the product sound powerful or capable. The problem is that the.
consumer succumbs to this marketing pressure without receiving any information. There
are no restrictions to prevent a manufacturer from naming a chemical anything they want to,
thus making a hazardous chemical sound innocuous or even healthful. Which sounds more
dangerous: quaternium 15, Dowicil Q, or l-(3Tchloroallyl)-3,5,7-triaza-l-
azoniaadanamtane chloride? They are all the same thing.
6. Labels and MSDS sheets frequently do not list the same ingredients.
Because of differences in the regulations governing product labels and Material Safety
Data Sheets, the two can give different ingredient information on the same product. Take
Lysol Direct Multi-Purpose Cleaner. This product is regulated by EPA as a pesticide, so its
label follows the EPA format. The ingredients listed on the label are the following:
Aikyl (67% C12, 24% C14, 7% C16,1% C8-C10-C18) Dimethyl benzyl ammonium chlorides. 0.08%
Alkyl (50% C14, 40% C12,10% C16) Dimethyl benzyl ammonium chlorides 0.02%
Inert Ingredients* 99.20%
'Includes detergents arid other grease cutting agents.
The Material Safety Data Sheet for this product lists only one ingredient:
Diethylene Glycol Monobutyl Ether 5.99%
Are we talking about the same product here? Yes, we are, but the quaternary ammonium
chlorides listed on the label do not have to be listed on the MSDS because they make up
less than 1% each of the product. The glycol ether listed on the MSDS does not have to be
listed on the label because it is an "inert" ingredient. The detergents aren't listed anywhere.
The arguments for requiring a listing of constituents on hazardous products can be
summarized as follows:
•t» Consumers have a right to know.
*> A uniform system would make all ingredient labeling consistent across different
product types.
•t* It would enhance motivated citizens' efforts to practice source reduction.
*J» It would get rid of the misleading term "inert" ingredients in pesticides.
•> It would standardize chemical identification, eliminating trade names and vague
descriptions.
»!» It would eliminate some discrepancies between ingredients listed on labels and
MSDSs
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Arguments Against Mandatory Labeling I
Having outlined what I view as the problems caused by the current system of product
ingredient identification, I will now try to enumerate some of the possible arguments •
against listing all ingredients on product labels. r I
1. Listing all ingredients will frighten consumers. _
Most consumers are not knowledgeble about chemicals or toxicology. Manufacturers I
may argue that listing the scientific names of ingredients will not be helpful because ™
consumers will not know what they mean. In fact, seeing complex chemical names may
frighten away consumers who have used a particular product for years. •
The same argument could be made about the ingredients in food or cosmetic products,
yet the ingredients are listed. Consumers who do not understand chemical names can •
ignore them if they wish. Some consumers may be frightened away from some products, I
and perhaps they ought to be frightened away from some products. In the long term, the
listing of chemical ingredients can be educationsl.
2. Listing ingredients requires manufacturers to reveal trade secrets. •
By listing all ingredients in a product, a manufacturer may be forced to reveal trade
secrets. Extensive, expensive research may have gone into developing the products. If the •
ingredients are revealed, competitors could then use that information to reproduce the |
formulas without an equivalent amount of time and effort. This could stifle creativity and
remove incentives to developing new products. _
In some cases, revealing ingredients may mean that trade secrets must be revealed. *
However, merely knowing the identity of ingredients does not necessarily mean that the
entire process is revealed and that a competitor can immediately begin copying a product. In I
practice, companies can often chemically analyze competitors' products and deduce the •
formulas. The extent to which revealing ingredients would be a hardship probably varies
widely among product groups. The manufacturers most likely to be hurt may be small •
companies with only a few products and without the resources to analyze competitors* ' |
products. There still remains the option of taking out a patent on a formula to protect it.
3. Listing ingredients means that a new label must be designed every time a formula is
changed. • .
Product formulas for some types of products change frequently. If the ingredients must
be listed, then each time a formula changes so that an ingredient is added or deleted, a new
label must be designed. This adds expense and may result in the waste of pre-printed
containers or labels. Careful planning of printing runs and container orders would be
required to minimize such problems. •
4. Consumers don't read the labels anvway.
Some surveys have shown that relatively small numbers of consumers read product
labels. If ingredient lists are longer, consumers may be even less likely to read them. On
the other hand, when a consumer is considering buying a new product or changing brands,
they may be much more likely read labels. The presence of advertising information on
labels must indicate that someone thinks consumers will read them.
5. There isn't enough room on the label.
For some products in particularly small containers or those with a large number of
ingredients, there may not be enough room to list all ingredients without a significant
decrease in print size. In those special cases, some creative solutions may be necessary.
Often such products are attached to a cardboard card that may have enough room to hold
the additional information. In some cases, additional shelf labeling may be required.
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How Ingredients Lists Might Look
Let's look then at some possible formats for increased ingredient information. Consider
an imaginary product with the following ingredients: sodium dodecylbenzene sulfonate,
sodium lauryl sulfate, triethanolamine, ethanol, 2-butoxy ethanol, methyl paraben, and
water. Under current CPSC regulations, this product could be labeled as follows:
•\
CAUTION: eye irritant. Contains surfactants.
One way to list the ingredients would be simply to list the chemical names in order of
decreasing percentage by weight or volume:
Ingredients: water, sodium dodecylbenzene sulfonate, sodium lauryl sulfate, ethanol,
2-butoxy ethanoi, triethanolamine, and methyl paraben.
Those who argue that chemical names are meaningless to the average consumer may
prefer to list chemical functions rather than chemical names, thus:
Ingredients: water, surfactants, grease cutters, buffering agent, preservative.
The most informative way to list the ingredients would be to combine the two
approaches. Obviously this would require almost twice as much space on the label.
Ingredients: water, surfactants (sodium dodecylbenzene sulfonate, sodium .lauryl
suifate), grease cutters (ethanol, 2-butoxy ethanol), buffering agent (triethanolamine),
preservative (methyl paraben).
The addition of quantitative data requires still more space.
Ingredients:
Surfactants
sodium dodecylbenzene sulfonate 10%
sodium lauryl sulfate 5%
Grease Cutters
ethanol 15%
2-butoxy ethanol 3%
Buffering Agent
triethanolamine . 10%
/"~s Preservative
methyl paraben 0.2%
Other .
water 56.8%
As another example, consider a spray insecticide. Under current EPA regulations it
would be labeled as follows:
Active Ingredients
Tetramethrin [(1-Cyclohexene-1,2-dicarboximido)methyl 2,2-dimethyl-3-(2-
methylpropenyl)cyclopropanecarboxylate] ...0.05%
Sumtthrin 3-Phenoxybenzyl d-cis and trans 2,2-dimethyl-3-(2-
methylpropenyl)cyclopropanecarboxylate 0.096%
Other isomers 0.04%
Inert Ingredients* 99.850%
*Contains methylene chloride
'o
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A complete listing of the ingredients in the same basic format might look like this:
Insecticidal Ingredients
Other isomers 0.004%
Solvents
1,1,1-trichloroethane ' 40.00%
Methylene chloride ...20.00%
I
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Tetramethrin [{1-Cyclohexene-1,2-dicarboximido)methyl 2,2-dimethy!-3-(2- I
methylpropenyl)cyclopropanecarboxylate] 0.050%
Surnithrin 3-Phenoxybenzyl d-cis and trans 2,2-dimethyl-3-(2-
methylpropenyl)cyclopropanecarboxy)ate 0.096% I
Propellant - •
Isobutane 29.85% I
Conclusion |
The subject of constituent labeling needs to be discussed. There are important issues
here relating to consumer protection, consistency of standards, and source reduction that •
need to be aired. A conflict with the desire for confidentiality is inevitable and makes the I
problem more difficult. It is critical that the various federal agencies involved in regulating
product labels work together to ensure a consistent system across product types. It is
equally critical that more complete ingredients listing not be viewed as an .excuse to avoid I
pursuing better health and environmental safety warnings. •
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THERMAL TREATMENT OF HAZARDOUS WASTE
by Paul E. Fredette, Ph.D. and Robert Coffey
The Thermal Treatment of Hazardous Waste is a very important part of the hazardous waste industry.
It is frequently referred to as incineration or burning but there is much more to it than you might
expect. In reality, it is a sophisticated process used to destroy or demanufacture chemicals and their
byproducts.
Combustion actually consists of numerous complex chemical reactions. To achieve destruction, these
reactions must go to completion which is a function of time, temperature, "and turbulence; the three
"Ts". It often takes as much energy to demanufacture a material as it took to form it.
To illustrate this point, consider the differences between this thermal process and a boiler. A boiler
is a heat exchanger designed to extract heat as quickly and efficiently as possible and to reuse the
energy for other purposes.
By contrast, thermal treatment is designed to maximize the heat/energy environment to achieve 100%
complete combustion, necessary for molecular breakdown and destruction. Since this is,a function of
time, temperature and turbulence, special emphasis is placed on the design to optimize these
characteristics.
Figure 1 demonstrates the temperature ranges typical of such treatment and the following figures will
graphically depict other design considerations.
Profile of
High Temperature Treatment
Figure 1
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There are basically four types of systems used in the industry as reviewed below:
In the liquid injection furnace, shown in
Figure 2, .liquid is injected into a thermal
reactor vessel. This is a long horizontal or
vertical chamber where the combustion process
takes place. In practice, the liquid is atomized
with forced air for maximum surface area. In
addition, forced air enters through peripheral air
ducts to create a spiral or vortex action for
maximum dispersion and turbulence..
Multiple Hearth Furnace
Airfc*
Figure 3
The fluidized bed is limited to homogeneous
materials; gas, liquids, solids. This new
technology is shown in Figure 4.
Liquid Infection Furnace
tend Air
Forced Air Dutt»
l-IU£NK*ay lined
Figure 2
The multiple hearth furnace, as shown in Figure
3, primarily handles liquids and sludges. It can be
modified to process solids.
Fluidized Bed
Extent
Sand
Huu&cd S«nd
AOCB Doon
Bumtr
Figure 4
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The majority of commercial systems utilize a rotary kiln as shown in Figure 5 for the following
reasons:
Rotary Kiln
22507
Howrr,
Stodt
« AmiliayFod
Afertuaer Liquid Waste
ChDiber .
Residence Time
>23«a
22CO-250BT
flexibility — handles gases, liquids,
solids, sludges, drums, packages
maximum residence time for solids to
allow complete destruction
rotating action provides constant
exposure of new surfaces to assure
destruction
after burner provides additional
residence time and temperature for
combustion byrproducts generated in the
kiln
overall exposure time in kiln and
afterburner: > 2.5 seconds
Figure 5
A typical rotary kiln treatment train including the operational components to complete the gas
cleanup process is shown in Figure 6.
Rotary Kiln Treatment Train
• Acid gas removal by neutralization
• Particulate removal (Calvert scrubber)
The primary chemical reaction is where a hydrocarbon waste fuel reacts with oxygen to form water in
the form of steam and carbon dioxide.
HCH (Hydrocarbons) + Oj (Oxygen) - H2O (Steam) + CO, (Carbon Dioxide)
Examples: Solvent Based Paints, Paint Thinners, Nail Polish Remover, Lighter Fluid
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Chlorinated hydrocarbons react with oxygen to form water, carbon dioxide and hydrogen chloride
gas. The HC1 gas is then neutralized in the scrubber to form water and sodium chloride (NaCl) or
common salt.
HC1H (Chlorinated Hydrocarbons) + O2 •* H2O + HCI (Hydrogen Chloride)
HC1 + NaOH (Caustic Soda in Scrubber) - H2O + NaCI (Salt)
Examples: Paint Remover, Carburetor Cleaner, Dry Cleaning Fluid, Freon,
Pharmaceuticals, Pesticides, Aerosols
Particulate Matter Is Removed
by High Energy Scrubbers
Gran
Hair
Putidc Size Removal b in the Sub-Micron Range
Figure 7
•The final gas clean up stage is the particulate
removal. A high energy scrubber removes
particulate matter less than 1 micron in
diameter. Note the comparison to a human hair
shown in Figure 7.
Finally, all facilities are required to continuously monitor the stack for some or all of the following
parameters to assure operation within permit limits for:
Continuous Sampling for
Oxygen*
Carbon monoxide/dioxide
Nitrous oxides
Sulfur oxides
Total hydrocarbon content
Periodic Sampling for
PCBs
Toxic Metals
Particulate Matter
POHC
HCl/Chlorine
* Oxygen is continually controlled at 6 to 8% excess in the stack gases. This is necessary to
assure complete combustion.
The entire process; thermal treatment, gas neutralization and particulate removal system must meet
Destruction and Removal Efficiency (DRE) minimum standards demonstrated via extensive stack
testing prior to receiving a permit:
• RCRA — Hazardous Waste
• TSCA - PCBs
99.99%
99.9999%
Regulations have been developing over a number of years. Heavy industrialization in the '50s and
'60s led to:
• U.S. Environmental Protection Agency (EPA) 1970
• Clean Water Act 1972
• State environmental regulations, led by California 1972
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However, hazardous waste regulations are relatively new. Industrial pollution in the '70s (Love
Canal, et al) led to:
• Resource conservation and Recovery Act (RCRA) 1976
• Toxic Substances Control Act (TSCA) 1976
• Comprehensive Environmental Response and 1980
Compensation Liability Act (CERCLA) or "Superfund"
• Hazardous and Solid'Waste Amendment (HSWA) 1984
As a result, RCRA regulations are rigorously enforced; non-compliance in our industry is met with
serious action.
Fines of $25,000 per day per violation
Criminal charges against violators
Consent decree imposing operational restrictions
Loss of permit
Closure
What does all of this mean to a thermal treatment facility? Figure 8 shows that each stage of the
operation is regulated by one or more federal or state agencies.
Regulatory Controls
t
Mfcr
Figure 8
To put the meaning of these controls into perspective, it
is useful to make a comparison with a very accepted
practice — fireplaces! We all enjoy sitting by a warm
fire, but residential fireplaces produce considerable air
pollution. Based on an EPA study of flue gases the
following pollutants are released each day.*
Carbon monoxide 6,1001bs.
Nitrous oxides 90 Ibs.
Paniculate 1,080 Ibs.
Total hydrocarbons 9,560 Ibs!
Polycyclic organic material 1,300 Ibs.
Assumes 5,000 households burning an average
of 20 Ibs. of firewood.
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Next is a comparison of thermal treatment with some of our accepted living styles —driving and
fireplaces.
Comparison of Daily Emissions
(LbsJDay)
'^:WMS&& V^lg^^^
Emission
Carbon Monoxide
Nitrous Oxides
Paniculate
Hydrocarbons
Vehicles (20,000)
10,345
11,352
1,730
773*
Fireplaces (5,000)
6,100
90
1,080
9,560
Thermal Treatment
Unit (150000
Tons/Yr)
72
600
72
24
* Plus 299 Lbs. of Rubber from Tire Wear - the Equivalent of 12 Tires!
Another look at the relative emissions for each pound of fuel from automobiles, fireplaces and a
thermal treatment unit further demonstrates the effect of process controls and regulations.
Comparison of Lbs, Emitted per Lbs. Consumed
Emission
Carbon Monoxide
Nitrous Oxides
Paniculate
Hydrocarbons
Vehicles (Lb/Lb Gas)
0.042
0.045
0.007
0.003
Fireplace (Lb/Lb
Wood)
0.0610
0.0009
0.0108
0.0956
Thermal Treatment
(Lb/Lb Feed)
0.0000876
0.00073
0.0000876
0.0000292
For Household Hazardous Waste and CESQG programs, segregation is very important to assure that
only non-recyclable material is thermally destroyed. All recyclable materials are sent to appropriate
third party outlets.
• Paint Habitat for Humanity, "exchange table", graffiti control
• Used Oil Re-refiners, recyclers
• Antifreeze Re-refiners
• Batteries Smelters, reclaimers
Non-recyclables are classified into compatible groups, e.g. poisons, acids, bases, etc.
Extensive documentation is required by EPA, DOT and state agencies wherever receiving TSDs are
located.
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Drum inventory sheets contain detailed descriptions of the drum contents.
Hazardous waste manifests provide the paper/record trail from the generator to the
disposer.
Quality control is performed on arrival.
• * All documentation is carefully checked .
• • All drums are inspected and bar coded prior to feeding into the rotary kiln
™ • Any analytical requirements are completed per Waste Acceptance Procedure specified
in the permit
In summary, the thermal treatment process is:
Chemical oxidation through high temperature reactions
Chemical neutralization of acid gases through scrubbing
Physical removal of paniculate matter through scrubbing
High tech with fail-safe controls
Very heavily regulated
The benefits of the process are:
• Hazardous waste is destroyed
* Landfill space is conserved
• Long term liability to generators is essentially nil
• Environment is protected
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The "Fuels Option" for HHW Disposal
Joe Foley, Director Sales Support, CWM, Inc.
As part of a comprehensive Household.Hazardous Waste collection program,
you may be presented with an option to divert a portion of the material to
"fuels". This presentation is designed to answer some basic questions on
fue s. ,9 what is a Hazardous Waste Derived Fuel?
• How is it produced?
• How is it consumed?
• What are the best candidates among HHW for this option?
• How can this option be best applied?
Hazardous Waste Derived Fuels (WDF)
Hazardous Waste Derived Fuel is a generic description for a high btu fuel
product produced from hazardous waste and burned in a regulated industrial
furnace. Within the EPA waste treatment hierarchy, the fuels option is
considered "Energy Recovery" which, although not favored as true recycling,
is more favored than incineration. WDF is used as a direct replacement for
fossil fuel at 28 cement kilns across the US and supplies up to 50% of the
energy needs at these facilities.
In 1992 over one million tons of WDF will be consumed of which only a small
% will come from Household Hazardous Waste Collection. The overwhelming
majority will come approximately 15,000 industrial customers that use and
generate liquid wastes that have energy value.
Producing Waste Derived Fuels
Most high btu materials ultimately consumed as WDF pass through a
commercial fuel blending facility which, is permitted by the EPA, for the storage
of these hazardous materials. Full service fuel blenders are able to receive
hazardous waste materials in a variety of forms but principally bulk tanker loads
of liquids and 55 gallon drums. Received materials are sampled and screened
for their btu value and other constituents, then blended with other materials to
produce a bulk tanker load, usually 4,000 gallons of a WDF that falls within a
pre-set specification.
The role of the blender is to take a wide array of waste materials that vary
greatly in composition and turn them into a homogeneous fuel that can then be
burned safely and with predictable results.
Consuming WDF in Cement Kilns
The vast majority of WDF is consumed by 28 cement kilns permitted to burn
these wastes. During 1992 these facilities have come under a new set of
regulations to ensure the efficient destruction of the waste, that emissions do
not pose a danger to the environment and the products produced are safe.
Attached are two graphics that depict in detail both the compliance issues
relating to cement kiln destruction and the high temperature nature of cement
kilns.
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WASTE DERIVED FUELS
v
COMPONENT FUTURE TREND ECONOMICS
Heat Value >5,000 BTU/lb I >BTU = < Cost
Chlorine Content <10% 4 >CI = > Cost
Metals - Various limits on volatile i Not usually a
metals (Mercury, Lead, Zinc) factor
Viscosity - Pumpable liquids and t < Solids =
sludges
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Landfill Options: Landfill Technology
Loren D. Alexander, CWM, Inc.
Introduction
Landfill disposal remains a necessary waste management option. Certain metal
bearing wastes, treatment residues and pollution control sludges have no other
practical alternative for safe, legal management. Two forms of permitted
landfill space are recognized by EPA as acceptable: Subtitle D for "solid waste"
and non-regulated residential trash and garbage and Subtitle C for industrial
"hazardous wastes". This paper explores the differences between these two
landfill types. The intent is to help buyers of landfill services to understand the
options so sound waste management decisions can be made.
Key points that will be addressed are:
• Historical issues involving landfills.
• Impact of regulations on landfills.
• Differences between Subtitle C and Subtitle D landfills.
• Options for Household Hazardous Waste disposal decision making.
Historical Issues
In 1976, Congress passed the Resource Conservation and Recovery Act
(RCRA) which was the most comprehensive law ever developed in the U.S.
focused on the management of waste materials. RCRA mandated the
Environmental Protection Agency (EPA) to develop a specific set of regulations
to administer and control the objectives of the law. In 1980, EPA finalized and
published these regulations which reside in 40 CFR 260-270. Before 1980,
regulations were unavailable or ineffective at controlling the disposal of solid
and hazardous wastes into landfills.
The landfills constructed pre-1980 often had no consistent construction
guidelines. Use of a single compacted clay liner was typical. Co-disposal of
solid wastes (trash and garbage) and hazardous waste (solvents, sludges)
occurred routinely. Liquids were allowed to be placed in landfills. Controls to
monitor the generation and migration of leachate were limited in scope or non-
existent.
The chemical and biological processes in the landfills were unrecognized and
uncontrolled. Later investigations of these processes have shown that co-
disposal can create potentially harmful environmental conditions. For example,
the decomposition of organic material from consumer garbage can alter the
acidity levels (pH) in the landfill. Food wastes and other organic materials like
wood, paper and petroleum products form organic acids over time. Changing
pH conditions causes metal solubility fluxuations and poses threats to leachate.
Methane gas formation results in potentially ignitable pockets within the landfill.
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These now recognized and evaluated phenomena are key reasons why many
of the sites that have become liabilities for cleanup are old landfills. Liability for
the costs of cleanup of environmental cleanup and restorations were largely
ignored by government and industry using these historical waste management
practices.
Regulatory Impact
In 1980 and the years following, laws, amendments and regulations have
driven measures to end the environmental harm from previous practices.
Impact on the use of landfills as a method of waste management has been
enormous.
RCRA brought new definitions of solid and hazardous wastes. Generators of
wastes were given cradle-to-grave liability for how their wastes were managed.
Waste reduction, waste minimization and recycling were established as
priorities.
Landfjijs^jere categorized as Subtitle C or Subtitle D (a reference to the section
in 4eiNasf where specific requirements are given). Landfills now have tight
specifications on design and construction. Subtitle C (hazardous waste) were
given stringent minimum technology standards including redundant safety
features in liners, leachate collection and groundwater monitoring. In order to
receive hazardous wastes, landfills were required to file detailed and complex
permitting documents covering waste acceptance controls, operations and
closure. New rules banned liquids from all landfills.
One of the most complex subsequent regulations affecting the Subtitle C
landfill is the so-called Landban Regulations. While too broad to cover here, the
intent of landbans was to restrict wastes targeted for landfill to treatment
residuals. The landbans were phased-in starting with the Solvents, Dioxins and
California List bans and carrying through the First-third, Second-third and Third-
third laws on specific EPA waste code categories. Complexity of these
regulations live on at present with the Debris Rule and Soil treatment standards
under development.
Strict liability for the generation and disposal of wastes was handed to industry
through RCRA and historical and future problems were targeted in the
Comprehensive Environmental Response, Compensation and Liability Act of
1980 (CERCLA aka Superfund). The jist of this regulatory imposed liability is
that generators of wastes must be cognizant of the risks involved with
decisions to manage wastes
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Subtitle D and Subtitle C Landfill Differences
The following table provides a detailed look at key differences between solid
waste and hazardous waste landfills.
ITEM
Waste Types
Construction
Waste acceptance
procedures
Operations
Environmental
Controls
Availability
Pricing
SUBTITLE D
"Solid Waste" only
both residential and
industrial.
Many older units still
operate with no
synthetic liner. New
landfills must have a
synthetic liner.
Vary in levels of
complexity. Most sites
receiving industrial
waste require TCLP.
Limited operational
personnel mainly in
active areas of landfill
and maintenance of
equipment.
Older units upgraded
with groundwater
observation wells.
New landfills must
have leachate
collection and
groundwater
monitoring.
Widely available. Over
5,000 in the U.S.
Less expensive
SUBTITLE C
Solid and Hazardous
wastes.
Active and newly
constructed units
must have double
synthetic liners and
double leachate
collection systems.
Rigorous pre-
acceptance profiling
and analytical
requirements as well
as analysis upon
receipt at the facility.
Large administrative,
technical and
laboratory staffs with
complex waste
characterization
responsibilities.
Redundant safety
controls in monitoring
waste compatibility
with double liners,
double leachate
collection,
groundwater
monitoring, strict
operations.
Only 22 in the U.S.
More expensive
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GEOTEXTILS FILTER'
GEONET LEACHATE.
COLLECTION LAYER
M1N. 60 MIL
GEOMEMBRANE
GEOTEXT1LE FIL
GEONET LEACHATE
DETECTION/
COLLECTION LAYER
MIN. 60 MIL/
GEOMEMBRANE
1-FOOT OROTSCT1VE
SOIL LAYER
1 -FOOT GRANULAR
LEACHATE
COLLECTION LAYER
1.5-FOOT COMPACTED
CLAY LAYER
i.rOOT GRANULAR .
LEACHATE
COLLECTION LAYER
3-FOOT COMPACTED
CLAY LAYER
NATIVE CLAYS/SOILS
NOT TO SCALE
CHEMICAL WASTE MANAGEMENT, INC,
DOUBLE LINER SYSTEM
383
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5/4/90
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Since all active Subtitle D landfills are not constructed to the same
specifications, buyers of these services should be aware of the cost/risk trade-
offs. Also, it is important to carefully evaluate the strength of landfill
companies, contractual protections and operating practices at any Subtitle D
or C landfill expected to be used. Figure 1 shows a cross section of a Subtitle
C units redundant safety features. Figure 1 shows the careful design and
construction features built into a Subtitle C landfill liner system.
Operations for Household Hazardous Waste
Typically 90-95% of the wastes collected from a household hazardous waste
cleanup effort can be recycled, reused or destroyed. However, the remaining
5-10% of metal laden wastes or those with lower toxicity need the practical
management option of landfilling.
Household hazardous waste can be landfilled directly into a Subtitle C
hazardous waste unit because the landban provisions of the regulations do not
apply to residential wastes. One notable exception is that no liquids are
allowed in the landfill. Frequently managed wastes into Subtitle C from this
activity is metal bearing paints (i.e. lead), solders, acids and bases. Latex paint
can be reused as a blended primer paint or other non-critical. coating
applications. Oil based paints should be blended for fuel.
Certain wastes can be targeted for Subtitle D disposal such as fertilizers, dried
latex paint, waxes and detergents. It is advisable to weight the risks of
disposal against the CERCLA liability when evaluating individual disposal sites
and the type of waste to be managed.
Summary
Landfill remains an important option for disposal of 5-10% of waste received
in Household Hazardous waste collections. Primarily wastes with metals and
solidified materials are targeted for this management method.
Liability issues need careful evaluation when choosing landfill service.
Significant differences exist between the construction and operation of Subtitle
D and Subtitle C facilities. Subtitle D is often close to all locations with over
5,000 units in the U.S. while Subtitle C landfills number only 22 in the U.S.
However, depending on the type of waste to be managed, the best options can
vary from a cost/risk evaluation.
For most Household Hazardous wastes the recycling, reuse and destruction
methods of managing wastes are the most practical, albeit more expensive,
means available.
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• REMARKS OF HUBERT HUMPHREY III
Attorney General
I to the
• National Household Hazardous
Waste Conference
December 11, 1992
I
Good morning.
I am pleased to be here today with people from across the country who are
^ dedicated to solving our nation's environmental problems.
Your work in improving the management of household hazardous waste is
f important because of the environmental consequences of mismanagement.
But, your work is probably even more important as an educational tool.
I'
Dealing with household hazardous waste brings waste management
problems to our own doorsteps.
m It forces each of us to examine our own activities to see what we can do to
minimize environmental problems.
H It is this self examination
B -- and, hopefully, the attitude changes and the new purchasing decisions
• that follow
I -- that is the key to environmental progress.
_ This culture change is critical because
this country
9 and this planet
m are at a crucial point in their environmental history.
Our lakes, rivers, wetlands, groundwater, air and soil are tremendous assets,
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They are the bank account upon which we draw for:
• food
• drinking water
• economic development
• recreation
•. and the simple pleasures of viewing the wonders of nature.
For decades, though, we have been borrowing from this natural resources
bank.
•' Mercury-tainted fish
• solvent and pesticide contaminated groundwater
• disappearing wetlands
• abandon hazardous waste sites I
• depleted ozone •
• and the potential for dramatic climate change
are among the environmental debts we are passing on to our children and their '
children.
|
We cannot continue to defer to future generations the environmental costs of
the way we live. B
The debt will simply overwhelm them. f
It is beginning to overwhelm us. J
I
The first thing that is needed is a clear objective. •
We have a myriad of environmental programs in this country, but no clear
environmental objective. '•
We have no man-on-the-moon by the end of the decade goal around which
we can rally as a country. •
We need a "Common Vision" for our environmental future. _
Let me suggest one.
By early next century, we should reduce pollution sufficiently that no B
additional environmental debt is being passed on to future generations.
We must act now to find new, long-term solutions to our environmental
problems.
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The United Nation's World Commission on Environment and Development
refers to this equilibrium as Sustainable Development.
g In the Commission's words:
• "Sustainable development seeks to meet the needs and
aspirations of the present without compromising the ability to
meet those of the future. "
m The idea is really a simple one.
I We must not create more pollution than the environment can readily
assimilate.
8 The models are already available for us to follow.
The Dutch Government has embraced the concept of sustainable
• development.
_ To meet the objective in making their economy sustainable, the Dutch plan to
I reduce pollutant loading by 70-90 percent by the year 2010.
• Norway, Sweden, Austria, New Zealand and Canada have adopted similar
national environmental plans.
• A long-term environmental plan is important for many reasons.
* It helps governments to design more flexible regulatory programs.
• • It allows environmentalists to better measure environmental progress.
• • It provides businesses a more stable planning horizon and encourages
innovation.
8 As consumers of a large percentage of the world's resources, the United
™ States must follow the lead of other countries by moving to an
environmentally-sustainable economy.
* There are several things we must do to achieve this objective.
J First, we must get truly serious about environmental education.
• The environment is our home, yet many of us don't even know how it works.
We need to educate our grade school students to respect the environment.
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. Our high school students to understand howithe environment works.
Our engineering students to work within the context of the environment
Our business students to understand how to manage companies in ways that
are compatible with the environment.
And, ourselves to better understand the effects of our daily activities on the
environment. Your work is particularly important in this regard.
Second, we need to find better ways of working together.
We will not be able to achieve a sustainable economy unless those on the
development side of the equation are working towards the same goal as those on
the protection side.
Business' stake in environmental protection is rapidly growing.
A recent editorial in Scientific American noted that those countries with the
toughest environmental standards also have the most dynamic and successful
companies in the environmental technology field.
In addition, the rapid increase in consumer demand for "environmentally
friendly" products has stimulated a dramatic increase in corporate interest in the
environment.
Finally, public demand for better environmental compliance by companies
has grown rapidly as a result of disclosures of the release of toxic chemicals
required under community right-to-know statutes.
All of the forces have led to businesses being more interested in
environmental issues.
As a result, cooperative efforts to protect the environment have increased
rapidly.
If we are to achieve an environmentally-sustainable economy, businesses
must become an active participant in the effort.
Businesses must lead instead of being pushed.
Many businesses have already taken up this challenge.
Large organizations, such as 3M, have adopted elaborate environmental
management programs which are designed to move the companies well beyond
simple compliance with environmental laws.
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I And, some trade associations are beginning to help their membership
develop strong pollution prevention programs.
g We in government must support these initiatives and help spread them to
other industries.
| Cooperative environmental efforts are still in their infancy.
I As businesses become more sensitive to environmental issues,
•.
'As environmental organizations become more comfortable working with
• business,
And, as we develop clearer national environmental goals,
• I believe we will see these cooperative efforts continue to expand.
• Increased voluntary compliance is critical in dealing with the huge range of
* environmental problems we face.
• Supporting those businesses that are leaders in their efforts to better protect
the environment is an important part of government's obligation.
£ Part of the support for the leaders in protecting the environment is ensuring
that a reasonable fair playing field exists.
jj Laggards should not be able to gain a competitive advantage by not
following environmental laws. ,
• This requires an aggressive and effective enforcement program.
• But, this is not easy in the context of rapidly-expanding regulatory programs.
For example, there are 80-100,000 facilities in Minnesota subject to
fl environmental regulation.
In 1985, that number was probably under 20,000.
New programs regulating:
• • small quantity hazardous waste generators;
• underground storage tanks;
problem solid waste such as tires, appliances and batteries
P • infectious medical waste;
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and the new community right-to-know laws have created a geometric increase in
the enforcement workload.
Enforcement resources simply haven't kept pace.
For example, a 1990 Minnesota Legislative Auditor's report noted that a dry
cleaning facility might be inspected for hazardous waste compliance once in
every 100 to 300 years given current staffing levels.
We must continue to look for better ways to enforce our environmental laws.
And, we must continue to find ways to differentiate between the leaders and
the laggards in our enforcement programs to increase the incentives for
compliance.
We as a country are beginning to understand the limits of our environment.
We are learning that everything we do has a consequence.
And, that the consequence of neglect over the last several decades is an
almost unconscionable debt that will be borne by our children and their children.
It is time for us to begin living on our environmental cash flow, not our
environmental credit cards.
As with our own budgets, this will require some hard choices.
We may not be able to afford everything we would like to have.
But, the reward, over time, is an economy that will be environmentally
sustainable not just for a few decades but for centuries to come.
This is my vision of our environmental future.
I hope it becomes our "COMMON VISION" of the future.
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HOW TO'S: HEALTH AND SAFETY CONCERNS
JUDY ORTTUNG, SUPERVISING ENVIRONMENTAL HEALTH SPECIALIST
San Bernardino County DEHS
San Bernardino, California
This paper will focus on two separate areas of health and
safety concerns;'
• protection for employees who routinely handle
household hazardous waste and
• general planning and site orientation to prevent
accidents.
Basic concerns for employees who routinely handle household
hazardous waste include concerns about exposure to chemicals,
whether by inhalation, absorption, ingestion or injection.
Such exposures could lead to either acute or chronic effects.
Additionally, there are concerns that employees may
unwittingly mix incompatible chemicals which may cause a cloud
of toxic gas, fire or explosion.
REGULATIONS. At the federal level, because HHW is RCRA-exempt,
I do not believe that the OSHA Hazwoper Regulations apply.
However, I do believe the OSHA chemical right-to-know laws
probably do apply. Each state is unique in how these laws are
interpreted and enforced, so each program should check with
their own state agency to determine the regulations that apply
to your program. In general, the OSHA requirements are based
on the amount of contact with chemicals. Whether or not
compliance with the regulations is required, they do provide
an organized and comprehensive approach to planning for safety
and health considerations. I strongly recommend reviewing
these requirements and using them as a basic framework for
developing your program's health and safety protocol.
»
A basic requirement for a safety program is that it be
written. The written program should include
• a medical surveillance program,
• procedures for materials handling,
• training, and
• emergency procedures, including decontamination.
It is important that management set a priority on safety and
that each employee be aware of that importance. One way to
ensure employee awareness is to include safety as a part of
the employee's work performance evaluation. The following
discussion describes each of the basic requirements listed
above.
WRITTEN HEALTH AND SAFETY PROGRAM. It is essential that the
health and safety program be Written, that each employee be
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given their own copy of the program, and that each employee be
fully trained to carry out each of the policies and procedures
identified in the program. In developing a written health and
safety program, you should identify all potential health and
safety hazards, evaluate each hazard identified, and either
eliminate the hazard or control it. The written program should
include individual sections for each of the topics discussed
below as well as provision for regular safety meetings for
employees.
Successful safety programs are those that are on-going,
systematic, relevant, include practice drills, hands on
experience, and both written directions and strong verbal
communications. Successful programs include frequent
meetings, opportunities to discuss problems, and when
available, relevant videos.
MEDICAL SURVEILLANCE PROGRAM. Under OSHA, a medical
surveillance program is required for all employees who are
• exposed to chemicals above the PELs (Permissible
Exposure Levels) for more than 30 days per year
• wear respirators for more than 30 days per year
• are injured due to overexposure to chemicals
• or are members of an emergency response Hazardous
Materials Team.
The medical exams should be performed prior to beginning the
job to provide a baseline, either annually or biannually
depending on specific levels of exposure, and when the
employee leaves a job to provide an exit level. These exams
should be performed under the supervision of a licensed
physician, without cost to the employee, without loss of pay
to the employee, and at a reasonable time and place. The
examination should include both a medical and work history
with emphasis on symptoms. It should be related to the
handling of hazardous substances and be related to the fitness
for performing assigned duties. The results of any medical
exams or diagnostic tests should be made available to each
employee on request. In San Bernardino County, the exam and
medical history is performed by the County Occupational Health
physician, on County time at a County facility.
There are some "sticky" questions related to screening for
fitness to accomplish the necessary tasks. For example, if
there are extensive prior medical problems, do you want that
person handling chemicals? However how do you screen prior to
employment? One possibility is carefully crafted questions
during an interview. In San Bernardino County, employment is
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conditioned on a medical examination prior to hire. If the
occupational health department knows and understands the work
assignment prior to the medical exam, it can help you to
properly screen potential employees.
MATERIALS HANDLING PROCEDURES. -It is important to detail in
writing the procedures to be followed for handling each type
of waste that may be brought to the site. This should include
procedures both for those that you advertise you will accept
and those that you will not accept. (Despite your best
publicity efforts, these unwanted materials will show up
anyway. You must have a contingency plan to deal with them.)
The procedures should be described in detail, and reviewed
with employees to be sure that they understand both the
procedure and the rationale behind it. Develop a checklist of
procedures covered and after a training session, have both the
supervisor and the employee sign the checklist showing that
the procedures were covered and that the employee understands
what is required.
TRAINING PROGRAM. There are explicit training requirements
written into several federal programs, including OSHA, RCRA,
and DOT (Department of Transportation). Whether or not these
requirements apply to your program, they offer a comprehensive
plan for training and it wouldn't hurt to follow them. The
underlying requirement for each of these separate programs is
that the training programs be detailed in writing, and that a
written record of the classes taken (dates, trainer or
institution, topics covered, hours spent, etc.) be maintained.
In California we have not seen a formal training program for
HHW. As a result we use a standard 40 hour Hazwoper class for
employees working at our central facility, and have developed
our own training program for the satellite facilities. I
should note that hazcatting and bulking of wastes other than
oil and antifreeze are done only at our central facility.
Employees at the satellite facilities do not open containers
except for waste oil and antifreeze.
EMERGENCY RESPONSE, it is important to develop a contingency
plan for the possibility of a spill, fire or explosion, even
if it is only to evacuate and call 911. This plan should
include:
• where/employees are to meet if evacuation is necessary
• who is in charge
• activities to be undertaken during and after the
emergency (don't forget any reporting requirements
your state agencies may have)
• a plan for decontamination, and
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• instructions for the public.
If you are counting on other agencies for assistance (fire
department, bomb squad, hospital-) it is also important to work
with them in developing your contingency plan. Don't wait
until there is an actual emergency, or it may be too late.
Safety Considerations for Establishing Site
(Permanent or one-day)
PLANNING. Consideration of safety concerns during planning is
important. When selecting a site, consider
• access, is the ingress and egress from the site
safe, or will vehicles be forced to cross heavy
traffic?
• space for lines of vehicles, is there enough room
for waiting vehicles off the street),
• Is there water on site?
• Is the site paved?
Think about worst case scenarios and identify necessary
materials and procedures. Plan to have those materials on
hand. Think about routine tasks, as well, and arrange the
site layout so as to minimize waste handling. Have dumpsters
located where actually needed. Have enough dumpsters so
workers are not required to carry packaging wastes any
distances. Have adequate carts, drum dollies, and fork lifts
if necessary to minimize carrying. Locate an area away from
the waste handling for a break area. Be sure to have enough
water or soft drinks available. Plan to have your staff or
volunteers remove waste from vehicles in order to discourage
the public from leaving their vehicles,
EDUCATE AND PREPARE THE PUBLIC. Publicity about your event or
collection program should include information about safe
packaging, labeling, container size and wastes accepted or
excluded. Remind the public that containers should be sound
and sealed, or else they should be overpacked in another
container. Incompatible materials should not be transported in
close proximity. It is best if containers with liquids are.
packed in boxes containing kitty litter or some other
absorbent materials. Remind the public, also, that each
container should be properly labeled. If the label is
missing, or if the contents do not match the label, ask that
the container be marked as to its contents prior to
transporting it. Advertise in advance the types of waste that
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you will accept or exclude. If you are excluding any waste,
offer an alternative or assistance.
PREPARE YOUR STAFF. Train your staff or volunteers to check
all containers before moving anything. Is the container
leaking? Is the box or bag strong enough to hold the
contents? If not, the staff should be prepared to deal with
these contingencies, before removing it from the vehicle.
Despite your best efforts, things do happen. Anticipate all
eventualities and develop a written contingency plan for
someone bringing in explosives, radioactive or infectious
waste. Develop a contingency for a vehicle accident, a spill,
or a fire.
Contact other agencies for assistance in advance, and let them
know o'f your plans.
The time spent planning will pay off in accidents avoided and
knowledgeable professionals performing during crisis.
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MANAGING COSTS AT HOUSEHOLD HAZARDOUS WASTE COLLECTION CENTERS
MARTHA BECK
INGHAM COUNTY HEALTH DEPARTMENT
LANSING, MICHIGAN
INTRODUCTION
Anyone that has ever looked at establishing a household hazardous waste (hhw) collection
program or currently operates a program will agree that they are expensive to establish, operate
and maintain. However, whether your- budget is small or unlimited, your collection program
permanent, temporary or one day, there are a number of areas in which costs can be controlled
and/or reduced. The following discussion will outline some of these methods for managing costs
in household hazardous waste collection programs.
FUNDING
Grants
Grants are an excellent source of funding for hhw programs. They vary in award size and can
come from any number of agencies. A few of the drawbacks to grants are:
*matching funds often required, sometimes at substantial levels. This may be prohibitive to
communities/agencies with minimal financial resources.
*may require commitment to continue the program beyond the completion of the grant.
*grant restrictions may preclude certain activities, such as monies can be applied to disposal only
or construction only. Other grants may be product specific, such as a state Department of
Agriculture may offer monies for only pesticide collection and disposal.
*may not be available from year-to-year, which could make long term planning difficult. Single
occurrence collections also create disposal problems as studies indicate that more hhw is thrown
in the trash immediately following a collection due to the increased awareness.
Donations/ Corporate Sponsorships
Corporate sponsorships can provide funding to cover the major budget items of a hhw collection
program or may only provide monies to augment existing funding. Often the contributions will
come from a variety of businesses and can create a patchwork of substantial funding. Large and
small corporations are often willing to financially support these types of programs in exchange
for recognition of the contribution. Generally, this acknowledgment is made during the education
and publicity portion of the hhw program, ie: mention sponsorship during public service
announcements, on educational flyers, etc.
Donations from citizens at the time of material drop-off will not raise substantial funds, but can
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augment the budget of any program. The Ingham County Health Department hhw program
operates on an appointment basis, with a reminder letter sent after each appointment scheduling.
In the letter, the cost per household for the collection is stated and each household is asked to
consider making a donation. The donation is completely voluntary and after several years of this
approach, it has been determined that the average donation is $10 per household. Reminding
citizens of the cost and suggesting a donation allows them to come prepared (prior to this
reminder, most folks either did not have cash available or did not appreciate the lack of warning
and were unwilling to donate).
Tipping Fees/ Fee on Municipal Services
For those localities fortunate (or not so fortunate, depending on your perspective) to have a
landfill and the State or local ability to assess a tipping fee, this can generate enough revenue to
fund a permanent, long-term hhw program. The politics of this approach might be difficult, but
well worth the effort.
Fees on municipal services, such as trash collection, water/wastewater treatment, etc. could be
charged annually or monthly.
Generally, a flat rate per household and a special rate for multi-unit buildings will function well
in medium to large cities to support a permanent program. As these services are not provided
in rural areas, other sources of funding must be pursued.
User fee (advance disposal fee)
This entails placing a small fee on products which potentially could end up at a hhw collection
site. The fee would be collected by the retailers in a manner similar to the deposits some states
collect on bottles and cans. The amount of the fee is dependent on your program budget and the
types and volume of material sold in the area the hhw service will cover. The user fee could be
established on a state-wide, regional or local basis with the authority coming from a variety of
regulations.
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In mid-Michigan, a regional approach (three neighboring counties) is being explored utilizing the
county public health code to provide authority. A regional program would eliminate the retailer
concern that consumers would prefer to shop in areas without the fee and would cross county
lines to do so. Discussion of a user fee is underway and involves the cooperation of the regional
Chamber of Commerce, local retailers and the three county political bodies. It is hoped that
some agreement will be reached in late 1993.
EDUCATION
Staff/ volunteers
There are numerous groups and individuals that can provide talks or distribute educational
material. Work study students and interns provide inexpensive, often very enthusiastic assistance.
Groups such as senior citizens organizations, League of Women Voters, Sierra Club, Girl/ Boy
Scouts often have committees devoted to environmental issues and are able to provide time/
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energy to create brochures, teach classes, respond to phone inquiries, etc.
Train the trainer
This process of training individuals to teach classes or give presentations is a favorite of the
Cooperative Extension Service. Training individuals to talk about chemicals in home products,
hhw, .or alternative cleaners with the commitment to teach a specified number of hours can
provide significant community outreach.
Distribute information where use is the greatest
Placing the information in high traffic areas such as malls or schools is a simple way to get
information to the greatest number of people in the shortest time. Booths at malls can be staffed
by volunteers or left unattended with a phone number .to call.
Use information currently available
Don't reinvent the wheel. Utilize publications developed by EPA or state and local organizations.
Many publications are free and can be copied with or without modifications. Permission should
be obtained from the authors and credits placed on the reproductions.
PUBLICITY
Public Service announcements
PSA's are free access to the airwaves...use them! Most stations prefer a variety of short
announcements from which they can choose. Check with charitable organizations such as the
American Lung Association for ideas on length, format and content. The PSA usage will vary
with the station, but most will attempt to air it at least once within the time frame requested.
Newspaper articles/ editorials \
It is important to establish a relationship with the reporters prior to requesting their assistance
in publicizing an event via an article. Provide educational information to bring them up to speed
and remember, cup of coffee can go a long way. Editorials and articles after the day of
collection may bring a flurry of calls from households that missed the event. Be prepared to
respond, perhaps with the date of the next collection.
Bill inserts
For the cost of printing, a large number of households can be reached with bill inserts, providing
a utility, municipality or other organizations with mass mailing capabilities is willing to include
the inserts with their billings.
Grocery/ municipal trash bag inserts are an excellent way to spread the word, however, the stores
and municipalities may prepare enough bags for an entire year, so if a one day event is planned,
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this may not be an appropriate method. Generic hhw disposal information could be provided
rather that specific dates and locations.
Door to Door
As with the distribution of educational material, publicity information can be distributed by
organizations such as the Scouts or environmental organizations with enough volunteers to
canvass the affected neighborhoods.
COLLECTIONS
TYPES OF COLLECTIONS
Product specific
With limited funding, a product specific collection might be the best approach. Focusing on
paint and paint related products or pesticides would address the two large volume items brought
to collection events.
Funding from specific sources might require collection of certain items, such as monies from the
Department of Agriculture for pesticide collections. This could be restrictive, but could also be
used to augment an existing collection program.
Limit types of products
Limiting the types of products which will be accepted at collection centers provides another
mechanism for maintaining a budget. Not taking readily recyclable products such as waste oil
and antifreeze, items disposable in the regular trash such as (solidified) latex paint or items for
which a separate collection can be developed such as household batteries can go a long way
towards reducing disposal costs.
If it is desirable to collect these items, but still remain within the budget, companies such as
waste oil haulers or paint companies may donate their disposal costs.
LABOR
Volunteers
Volunteers work well for activities such as answering the phone, directing traffic, providing talks,
etc., but due to liability concerns, are generally not utilized in the material handling area. .For
most collection events (primarily one day collections, not facilities with daily hours), individuals
from other organizations, such as the Fire Department or State Department of Natural Resources,
with material handling training can provide assistance with product sorting and packing.
Contract
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In many situations, contracting with an firm.specializing in hhw can minimize liability concerns,
provide equipment, staff, educational material, etc. and keep costs down. Of course, any
combination of cost saving methods can be required in the contractual agreement.
EQUIPMENT
Borrow
Equipment can be borrowed for single day events from neighboring communities with hhw
collection programs, State Department of Natural Resources (or whatever your equivalent may
be) or local fire department. The Lansing LEPC/ Fire Department assists at each Ingham County
hhw collection event by identifying unknowns using their haz-cat kit, thereby saving considerable
dollars. Of course, a permanent facility will want to invest in their own equipment.
Grants/ donations
Some grants are geared to establish permanent or on-going programs and may fund equipment
purchases, but not disposal costs. Businesses, individuals, corporations or service/ environmental
organizations may prefer to donate equipment such as personal protective equipment (PPE),
dumpster use, spill control items, barrels, etc., rather than monies.
Contact
Once again, the hhw contractor can provide ail of the required equipment, however, the source
of the equipment (ie: donated) can be negotiated in the contract. Some contractors may prefer
not to utilized anything but their own equipment for liability reasons.
PRODUCTS
Consolidation
As paint makes up the highest percentage of waste at most collection events, consolidating paint
can be the greatest cost saver available. If the consolidation cannot be done on-site, a local
company with space and appropriate environmental and employee protection (secondary
containment, ventilation, etc.) can be utilized, but requires interim transportation of the waste.
A certain percentage of material brought to hhw collection events is still in. a useable form.
Providing an on-site "swap shop" where folks can take what they need is popular at permanent
sites. An alternative for temporary collections is to work with organizations such as greenhouses/
nurseries, women's/ homeless shelters, theater groups, vocational schools, etc., to pick up the
products at the conclusion of the collection. Most of these groups will provide lists of items they
can utilize.
Reuse
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A number of collection programs have established paint recycling programs where the paint is
sent to a paint manufacturer for reformulation. The paint is generally a neutral color and not as
high a quality as new paint and therefor often used in graffiti covering projects or similar
programs.
RecvclinE
The number of items which can be recycled is limited. Aerosol cans can be emptied and the
metal recycled and cardboard boxes can be crushed and recycled, saving dumpster space.
CONCLUSION
Although many of the cost management suggestions may seem small or inconsequential, the sum
total of the savings may allow for extra, larger or improved hhw collection program. Many of
these suggestions will take time to track down and organize, but the end result can be a great
program at a reduced cost.
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Conference on Household Hazardous Uaste Management
Donna Portner, Minnesota Pollution Control Agency
Thursday, December 10, 1992
Workshop 5-A—How To's
Personnel and Training
Personnel Requirements
The Minnesota Pollution Control Agency (MPCA) operatesHHW
management programs with groups of counties. The counties are
responsible for hiring staff for their programs. Program staff are.
involved in HHW collection activities, in the education program, or
both.
Through its contracts with counties, the MPCA specifies minimum
requirements for county staff hired to operate the programs. When
hiring, counties are asked to adhere to these requirements when
possible. However, the MPCA is flexible with the specifications.
County staff hired for collection activities may do any or all of
the following at event collections, permanent facilities,, mobile
facilities or product exchanges: accept, sort, bulk, package, store
or transport HHW. They may also be responsible for recordkeeping
and financial responsibilities. Minimum requirements for
collection activity staff are:
1. A bachelor's degree in Biological Sciences, Chemistry,
Engineering, Geography, Geology, Hydrology, Hydrogeology,
Physics, Public or Environmental Health, Toxicology, Soil
Science, Environmental Studies, Ecology, or an equivalent field
or two years of professional level experience in waste
management;
2. Must be capable of performing the program's chosen collection
activities (event collections, permanent facilities, mobile
facilities, or product exchanges);
3. Must be available to work sufficient hours to ensure that
collection activities are conducted in compliance with the
contract;
4. Must enroll in the MPCA's medical monitoring program; and
5. Must successfully complete the MPCA's training program.
Collection staff, once hired, must enroll in the MPCA's medical
monitoring program if they either work with hazardous materials or
wear a respirator on at least thirty separate days per year (or
combination of both), even at just one hour per day. The MPCA's
program is conducted through the Ramsey Clinic Occupational Health
Services in St. Paul, but it is possible for staff to receive their
medical monitoring examinations at other clinics which can provide
the proper services.
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In medical monitoring, a qualified physician periodically screens
staff to identify or establish medical effects which result from
exposure to occupational hazards. If they detect exposure, the.
county must modify the staff person's activities.
Medical monitoring consists of physical examinations and
certification to wear a respirator. The employee must receive an
initial examination before he or she begins working with hazardous
materials. The initial examination establishes a baseline medical
record for future comparison.
After the initial examination, examinations are required every.year
or every two years, depending on the number of calendar days that
each staff person is exposed to hazardous substances or wears a
respirator, regardless of the number of hours of exposure per day.
Staff exposed to hazardous substances or who wear a respirator
thirty or more days per year must receive an annual medical .
monitoring examination. Alternatively, staff who are exposed to
hazardous substances or wear a respirator thirty days or less per
year must receive an examination at least once every two years. As
days of exposure or respirator wear increase or decrease, the
frequency of examinations is adjusted. . ' .
Every collection -program needs back-up staff. Back-up staff, like
the regular staff, must receive the initial medical monitoring
examination for baseline data. How frequently back-up staff must
receive examinations is determined the same as for regular staff.
If back-up staff are not called upon to handle hazardous waste or
to wear a respirator, they need not receive medical monitoring
examinations beyond the initial examination.
The medical monitoring program also requires that collection staff
be recertified annually to wear a respirator. Annual
recertification consists of completing a questionnaire and
submitting it to the. Occupational Health Clinic for evaluation.
The physicians then determine if the employee is healthy enough to
wear a respirator, based on the questionnaire and the employee's
previous health records. In addition, the staff person must be
fit-tested annually on both a half-face and full-face respirator..
Education program staff, like collection staff, must also keep
certain records and track education program finances. According to
the contract, minimum requirements for education program staff are:
1. Should have successfully completed at least two years of
college or have at least two years of experience conducting HHW
education, waste reduction, public education, or educational
activities;
3. Must be capable of performing the education program activities;
2. Must be available to work sufficient hours per month to fulfill
the contract obligations; and
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4. Must complete the MPCA's training program.
Training
The MPCA trains program staff for both tangible and intangible
reasons. The most obvious tangible reason is that the Occupational
Safety and Health Administration (OSHA) requires workers to be
trained so that they can do their jobs in a safe and healthful
manner. Money is also a tangible reason to train workers. Safety
and health training helps avoid, or at least minimize, Workers'
Compensation claims caused by injury or exposure to hazardous
materials on the job. Training has produced an excellent safety
record in this program. Training also helps create self-sufficient
staff, making the program more cost- and time-efficient and
independent.
Environmental protection and team building are intangible reasons
for the MPCA to train program workers, making it a very valuable
.service to counties in the program. It's tough, if not impossible,
to place monetary, value on environmental protection. Training has
resulted in an excellent record in this area. It also builds
confidence in workers and creates or enhances a working
relationship between county and MPCA staff.
Collection staff can vary from the program managers themselves to
solid waste facility operators. Education program staff can be any
of the following: program managers, educators, university extension
agents, county solid waste officers or volunteers.
The MPCA both conducts training itself and contracts out some
training. MPCA staff train program staff on how to properly
conduct collection activities, education program activities and
citizen telephone advice. It contracts out 24-Hour Safety and
Health Training and First Aid/CPR training.
MPCA staff trains county staff in most aspects of collecting HHV.
Collecting HHV involves accepting, sorting, bulking, storing and
packaging wastes through a variety of activities. Collection
training includes identification of a hazardous waste; collection
procedures; acceptable wastes, including guidelines to identify
commercial and agricultural wastes; hazardous materials handling
and categorization; packaging and storage requirements; and safety
procedures. This training is now done individually, usually at the
collection facility.
The MPCA is discussing developing a modular, repeatable method of
facility operator training to replace the one-on-one method now
used. Although training sessions will be held, ideally these
training modules can be distributed on videotape to accommodate
staff who enter the program between sessions. MPCA staff are also
planning an eight-hour refresher safety and health training.
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Education program training defines the roles of the MPCA and each
county in developing the education plans. It trains staff to
identify wastes that are acceptable through the program. Waste
reduction through reuse and recycling, alternatives to HHW, safe
home treatment methods, and hazardous materials handling are also
stressed in this training.
Numerous training sessions on how to use the MPCA's telephone
advice guidance manual have been held over the years. The manual
is only available to trained individuals.
Two types of training are contracted by the MPCA: 24-hour safety
and health training to fulfill OSHA requirements and First Aid/CPR
training. Anyone who collects waste must receive the 24-hour
safety and health training. The main topics include identification
of hazardous materials, respiratory protection, identification of
explosives, decontamination, use of protective clothing,..
occupational health and toxicology, and fire training.
Collection staff must become certified in First Aid and CPR within
the first six months of employment. The MPCA also contracts out
this training. Initial certification consists of four hours of
standard first aid training and four hours of adult CPR. Staff
must retain CPR certification every year of employment after
initial certification. In addition, staff must receive four hours
of First Aid training every three years after initial
certification. A 6-year schedule is;
Years 1 and 4: Standard First Aid (4 hours) and CPR (4 hours)
Years 2,3,5,6: Adult CPR (4 hours)
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Integrating Household Hazardous Waste Programs into Various Media Offices
Leslie C. Goldsmith
Minnesota Pollution Control Agency
Managers in HHW programs face a variety of challenges as they work toward
successful, efficient management of HHU. The complexity of the issues and
institutions involved in HHW management can be truly daunting.
In order to operate a HHW program successfully, the HHW program manager must
possess a thorough understanding of environmental management as it is
practiced at all levels of government. To accomplish this, it is vital for
the HHW manager to establish relationships with a variety of advisors within
many disciplines and organizations.
Traditional environmental programs have addressed specific environmental
media, such as air, surface water or groundwater. Due to rigid program
structures and goals, the focus of a program was not to necessarily to
eliminate the pollutant, but to remove it from the program medium. Examples
of this are groundwater cleanups that remove pollutants from the groundwater
by purging them into the air, or air pollution control devices that collect
particulates to be buried in landfills.
A growing regulatory and policy focus on pollution prevention and multimedia
assessment is changing this philosophy, but there is still a great deal of
isolation in the traditional media programs. These institutional barriers
to integrated waste management are often hard to overcome. They are
decreasing, but are still common.
Historically, hazardous waste programs have been driven by the need to keep
hazardous waste out of landfills. With increasing variety and integration
of waste management systems, landfills are no longer the sole concern in
many areas. As the operator of a HHW program, one is often at the
crossroads of all of the media programs. Depending on the technology and
policy in your solid waste and wastewater management programs, the HHW
program may directly impact releases to air, surface water or the land.
Increasing cost constraints are forcing HHW program managers to operate
programs targeted at materials that pose the greatest hazard. To be
successful at this, a HHW program manager needs to develop an understanding
of the solid waste and wastewater technologies employed in their service
area.
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The environmental and safety problems posed by HHW vary, depending
significantly on the type of facility that is receiving the waste. For
example, solvent-based products are less of a problem at incinerators than
they are at landfills; the situation is often reversed for materials
containing heavy metals, particularly mercury.
In many states operating or contemplating HHW programs, the fate of HHW is
not rigidly regulated. This provides the operator of a HHW program with the
opportunity to implement a wide variety of creative recycling, management
and treatment strategies. There may be opportunities to redirect waste
among existing solid waste and wastewater facilities. By establishing
relationships with these operators, it may be possible to encourage them to
explore these alternatives with you. While working on the goal of overall
pollutant reduction, the program manager must remain constantly aware of all
of the systems and operators impacted by their decisions.^
Communication is the most important tool in integrated HHW management. It
is important that the HHW manager communicate with all potentially affected
facilities before dispensing HHW management advice.. For example, in
communities with a sewer system, the local waste water treatment system
operator should be consulted before implementing any advice involving the
sewering of HHW, Additionally, the prevalence of septic systems must be
well understood before providing advice on sewering.
Another barrier to integration is the way that environmental
responsibilities are allocated among and within different levels of
government. At the local level, positions are frequently broad and general
in their responsibilities; many cities and counties have a position that is
addressed simply as "the environmental person." As one moves upward
through regional, state or federal structures, positions generally become
medium-specific and narrowly focused.
In conclusion, a HHW program manager needs to place a conscious emphasis on
broad knowledge and varied relationships to achieve the greatest benefit for
their community.
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Lake Superior Basin Hazardous Waste Assessment and Awareness Initiative
Ned T. Brooks
Minnesota Pollution Control Agency
The MPCA obtained a grant from the EPA to implement the Lake Superior Basin
Hazardous Waste Assessment and Awareness Initiative. The goals of the
Initiative were to identify very small quantity hazardous waste generators
(VSQGs) and the wastes they produce and raise their awareness of proper waste
management. The Lake Superior Basin in Minnesota covers about 6,000 square
miles and includes the cities of Duluth, Hibbing, Virginia, Cloquet, Two
Harbors and Grand Marais along the north shore of the lake and into the Iron
Range. The estimated population of this area is 160,000.
ASSESSMENT PHASE
From March through July, 1992, MPCA staff conducted 877 on-site assessments of
all businesses in the Minnesota portion of the Lake Superior Basin that did not
have a hazardous waste generator license but were deemed likely to produce
waste. The goal of this phase was to identify all generators of hazardous
waste the types and amounts of waste they produce and their management
practices. Each assessment consisted of a "front office only" visit and not a
comprehensive audit.
The assesment process identified 444 businesses and institutions, mostly very
small quantity generators (conditionally exempt), that had previously been
unaware of their responsibilities as generators and had not registered with the
State or the EPA. An additional 167 generators had EPA ID #s but were not
registered with the State. The 611 generators identified through the project
represent 542 of the known 1,141 VSQGs in the Lake Superior Basin.
The most common VSQGs identified include vehicle repair, printing/photagraphy,
auto body, medical/dental and government.
On the average, each VSQG visited during the assessment project generated 1,280
pounds (about 130 gallons) of hazardous waste in 1991 (not including used oil
or lead-acid batteries). Excluding antifreeze, oil filters and all other types
of batteries each newly identified generator produced about 900 pounds (about
90 gallons) of hazardous waste in 1991. The top five types of waste produced
include photo processing chemicals, partswasher solvents, paints and thinners,
sludges and toxic metals.
360 or 35% of the 611 newly identified generators were found to be mismanaging
their waste in some way including over accumulation, evaporation, disposal in
solid waste stream or down the drain, burning or disposal' on the ground. In
Total about 40 tons of hazardous waste was mismanaged by this group of
generators in 1991. Excluding mismanagement of oil filters the nuber of
generators practicing improper management drops to 212.
Summary:
877 Assessments Conducted
611 Newly Identified Generators (542 of Total Known)
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(444 Not registered with MPCA, No ID#)
(167 Not Registered with MPCA, Had ID #s)
530 Known VSQGs Before Assessments (46£ of Total Known)
1,141 Total Known VSQGs After Assessments
1,280 Lbs. or 130 Gals. Average Waste Amount in '91 (not incl used oil)
360 generators mismanaging 40 tons of hazardous waste
AWARENESS PHASE
In mid-July, 1992, the MPCA also initiated an intensive, three month long
campaign to raise awareness among hazardous waste generators and the general
public. The campaign featured radio and newspaper advertising direct mailings
and informational meetings for VSQGs. The Newpaper and radio ads featured
spotligts of three small business owners and their attitudes about managing
hazardous waste. The MPCA produced a newsletter and a brochure targeted at the
small business hazardous waste generators in the basin. The MPCA is also
experimenting with additional targeted reduction and compliance assistance
outreach to the generators involving trade groups, chambers of commerce and
local officials.
For more information and a copy of the project report contact Darren Saari at
218-723-2356.
1993 INITIATIVE
The MPCA, with funding from the EPA, intends to continue and expand certain
components of this initiative in 1993. This "will include additional targeted
outreach, workshops for specific industry groups, compliance assistance site
visits and pollution prevention demonstration projects. For more information
contact Ned Brooks at 612-297-8498.
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Collection Program Case Studies: Anchorage .
Bill Kryger and Tom Poliquin
(as presented in the "Third Annual Report on the Operatiuon of the
Anchorage Hazardous Waste Collection Facility)
I INTRODUCTION;
A true measure of the success of a program is whether it can
be operated and maintained to accomplish the goals set for it.
This report documents the results of the past three full years of
operation of the Anchorage Hazardous Waste Collection Program.
The Anchorage Hazardous Waste Collection program is comprised
of the three following entities. The Eagle River Facility (ERF)
located at the Ancorage Regional Landfill (ARL), the Central
Transfer Station facility and the Pick Up Service. All program
facilities are owned by the Municipality" of Anchorage and are
currently operated by Northwest EnviroService, Inc.
The program was designed in an effort to offer an
environmentally sound disposal method for the hazardous wastes
that might otherwise be disposed of in Anchorage sewers, the
Anchorage Regional Landfill {ARL) or indiscriminately dumped on
public and private property. The program's operating costs are
borne by•user fees generated by the Anchorage Waste Water Utility
and the Solid waste Disposal Utility. Additional disposal fees are
charged to Conditionally Exempt Small Quantity Generators (CESQG)
based upon the type of wastes and quantities received. Households
are charged $5 for each visit to the ARL which can include a
delivery up to 40 pounds of hazardous waste at the facility.
The ERF is located at the ARL on Hiland Road, 13 miles north
of Anchorage on the Glenn Highway. There is also a vital satellite
collection center at the Anchorage Central Transfer Station (CTS)
located at 54th Avenue and Juneau Street near.midtown Anchorage.
The operation of both collection centers began February 15th,
1989. in the first year of operation 30,983 items were collected
amounting to a weight of 415,425 pounds. During the second year
46,167 items were collected amounting to a weight of 597,472
pounds. During the third year 52,236 items were collected
amounting to a weight of 875,616 pounds. This activity has been
1.49 times as many items with 1.44 times more weight in Year II
than in the Year I. The third year activity was 1.13 times as many
items with 1.47 times more weight in Year III than in Year II
resulting in a cumulative total at the end of the Year III of
129,386 items and 1,888,513 pounds.
II
SRF DESCRIPTION:
The ERF is a pre-engineered insulated metal building with
sealed concrete floors, heating, ventilation and alarm systems.
The layout of the facility is shown in Figure 1.
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In total, the ERF covers nearly 6,000 square feet with_half
of the space being primarily for storage of drummed wastes in
rooms 101, 102, 103, 114, and 115. Greater weight throughputs were
experienced in Year II and Year III by 44% and 47% respectively
over Year I. This resulted in the doubling of the shipping
frequency in both of these years.
The limits of storage capacity in Year III were maximized
while maintaining consistent manpower levels. Operational schedule
changes and/or additional personnel will most likely be required
to meet continued increasing volume activity after beginning Year
IV i;-
The "heart" of the ERF continues to be the "Consolidation
Room" (Room 104). The consolidation room houses a maximum of 32
drums in various stages of consolidation. Approximately one half
of these drums are for the purpose of creating "Lab Packs" of
various hazard class groups. The other half are for consolidation
of a variety of liquid wastes. By closely following established
operating procedures, the ventilation in the consolidation room
continues to be adequate.
"Oxidizers" and "Water Reactives" are stored away from other
chemicals in a pair of explosion vented closets adjacent to room
101. These two closets are the only rooms in the entire facility
that are devoid of sprinkler coverage and protection.
The "Laboratory", adjacent to the office, continues to be
extremely useful for rapid testing of unknowns and preparing
samples for further testing at commercial laboratories. Tests
performed include the following.
1- PH
2- -Flash Point
3- Specific Gravity
4- Halogen Contamination
- 5- Cyanide Contamination
6- Chemical Compatibility
7- Kiscibility
Data management is provided by a computer system specifically
developed for this project. Data management begins with a serial
number being assigned to each incoming item. The physical and
chemical characteristics of each item is then recorded
individually. At any point during this process, the data
management program can publish the disposition of any item and the
contents of each drum. It is becoming apparent however, that this
system will need updating for streamlining and efficiency as the
annual quantities continue to increase.
The heating plant is capable of producing 1,000,000 BTU's/hr
and can adequately keep the ERF comfortably warm providing that
the ambient outside temperature is not less than minus 15 degrees
Fahrenheit. On colder days the ventilation rate is reduced.
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Ill STAFFING!
A. Personnel Selection
The full time operational staff at the facility and transfer
station consists of five people in addition to a part-time
chemist. The staff consists of locally hired persons that are
carefully screened. Among the characteristics sought are
environmental knowledge, health and safety awareness and a desire
to succeed within this trade. Communication skills are also
required.
Academic training beyond high school, although not required, is
desirable. The chemist position requires a college degree in
chemistry as a minimum.
B.Training
All hazardous waste technicians at the facility have
completed the following training and hold appropriate
certificates.
1- 40 Hour OSHA Hazwoper Training
2- 8 Hour OSHA Hazwoper Annual Refresher
3- First Aid Training Course Approved By American Red Cross
4- CPR Training Course Approved By American Red Cross
5- 8 Hour New Employee Indoctrination
6- 20 Hour Training Course on Household Hazardous Wastes
7- 8 Hour Basic Chemistry on Household Hazardous Wastes
8- 8 Hour Fork Lift Training
9- Weekly Safety Meetings
C. Anticipated Training
Training for Year IV will be concentrated into a series of
weekly safety meetings, These meetings are structured and
documented to constitute formal training time. Technicians will
also routinely attend seminars dealing with regulatory changes
within ^11 applicable federal, state and municipal agencies.
Hazardous Material supervisory training will continue to be made
available to at least two technicians. OSHA 8-Hour Hazwoper
refresher courses will be attended by all technicians requiring
these annual certificated classes. Technicians will also be
required to attend classes and secure a commercial drivers license
(CDL) with appropriate endorsements.
IV WASTES RECEIVED;
A.By Hazard Class
All wastes received fit into one of sixteen hazard classes as
listed in Table 1. The hazard class characterization is essential
for segregation, safe handling, storage and shipping. Each
individual item received is either identified by hazard class, or
sent to the lab for identification and characterization by a
chemist.
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Table 2 lists the quantities of wastes received during these
past three years of operation. The unusually high fraction of
automobile service batteries is a regional characteristic' that
diminishes seme of the other percentages.
The "Other" category is primarily latex paints. Although
latex paint is permitted as a landfill item in Alaska, it is
stabilized into a solid impermeable form before landfilling in
Anchorage. The proprietary process develooed by Northwest
EnviroService, Inc. has passed all TCLP testing for mercury. Two
additional categories, "Waste Oil" and "Latex", will be maintained
in-year four to help distinguish these individual quantities.
B.By Generator Category
In addition to household hazardous wastes, commercial wastes
are accepted from Conditionally Exempt Small Quantity Generators
(CESQG) at the ERF hazardous waste collection facility. The
Central Transfer Station operation accepts only household
hazardous wastes.
CESQG's remain qualified in the exempt category if they
generate no more than 220 pounds of hazardous wastes per month and
have accumulated no more than 2,200 pounds of these wastes.
Several generators become CESQG's after shedding inventories of
wastes through commercial channels and incorporating waste .
minimization efforts. An additional 43% increase in CESQG's
utilizing the facility during Year III is apparent. This will
continue to increase as the business community realizes that there
is an approved outlet for their wastes. Caution must be exercised
here however, to maintain the CESQG regulatory exemption and to
insure that the waste origin meets the criteria of the exempt
generators. A signed form is used to certify that generators
qualify as CESQG's and as householders.
«>w
r Figures 2a, 2b, 2c and 2d are comparisons of the number of
generators that are certified as Households, Orphans and CESQG's.
An Orphan waste is one that has been abandoned by the generator
and are mostly found at the Central Transfer Station since this
station was only manned on Saturdays. Please note that there was
growth in participation by CESQGS growing from 11% in Year I to
15% in Year II and 16% in Year III.
Figures 3a, 3b, 3c and 3d display the total amounts of wastes
collected from these three generator groups during Year I, Year II
and Year III. Note that during Year III that.the battery category
increased by 10% while Households and CESGQs decreased by 4% and
7% respectively.
The average lot size from household/orphans is 106 pounds and
from CESQG's is 971.6 pounds. Specifically antifreeze, batteries
and motor oil are included in the above quantities but they are
not included in .the 220 pound per month weight limit to.-qualify as
a CESQG. Most individual CESQG's do not deliver waste each month
however repeat CESQG customers continue to rise.
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A pick up service continues to be offered to assist with
motivation of less mobile householders and CESQG's. A pickup
service charge of $10 and $25 is added to disposal fees for
householders and CESQG's respectively. It should be noted that the
frequency at which CESQG's are currently utilizing this service is
rising rapidly. An increase in the service charge for CESQG's
should be considered to a more realistic figure to defray the
actual costs associated with providing this service. Pickups are
scheduled to best fit into the facility operational requirements
while keeping with the spirit of fast, efficient service to the
general public.
C. Seasonal Variations
A major question in planning the operational schedule is
whether to expect a continued collection rate throughout the
winter months. Figure 4 displays the monthly number of users which
appeared during Years I - II - III. Figure 5 displays the monthly
waste quantities collected during Years I - II - III.
From data collected it is clear that post-summer activities
continue to increase and that a year round facility will collect
much more hazardous wastes than an annual one day or annual one
week waste collection event. For example, every May Anchorage
holds its annual "Spring Cleanup Free Week". Throughout these
eight day periods householders deposit their trash and their
hazardous wastes at the CTS and the facility at the ARL. These
periods cause obvious increases in the monthly activity.
The amounts of wastes obtained during the May 1991 event
represented 7,500 items and approximately 6% to 10% of the total
pounds collected during the year.
The slower winter months permit more time being devoted to
analysis of unknowns, inventory, shipment, procedural
improvements, training, facility and vehicle maintenance. The 478
drum storage capacity of the facility is a key element to
absorbing peak generation periods while profiling the inventory
for shipment to a treatment or disposal site. Efforts are made to
ship the oldest drums first in a timely fashion. In so doing the
strain on the limited storage space is minimized.
D. Income Received From Generators
The $5 household visitation fee levied, by the Municipality
of Anchorage, to gain access to the CTS or the ARL allow for the
deposit of 40 pounds of hazardous wastes as a function of that
visit. We have recognized an increase in amounts over this 40
pound hazardous waste "free limit" per visit by some households.
These homeowners are charged the same rates as CESQG's for that
portion of their hazardous wastes over the free limit. To date
they appear to be happy to assume this extra charge for this
service. CESQG's are charged per the disposal rate schedule listed
in Table 4. Trends during Year III suggest that CESQG's continue
to regard this disposal program with more support as the number of
new CESQG's increases while others enjoy repetitive service.
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Revenue attributed to households and CESQG's, although the
combined total contributes to only about 9% of the total operating
costs, does serve a function to encourage segregation of the
hazardous waste component from the non-hazardous articles. The
fees are also consistent with the philosophy of applying user fees
for recognized services rendered.
V PHYSICAL AND CHEMICJ
A.Consolidation Of Wastes
..**
^ Household and CESQG hazardous wastes come in thousands of
forms, containers and compositions. Observation of wastes from
Anchorage over the past seven years has revealed a definable
number of waste groupings. Some of the waste groups can be
consolidated without reactions.
Typical of such a waste grouping is ammonia solutions from
blueprint machines. Such solutions arrive at the facility in
bottles and thin'plastic jugs with and without serviceable caps or
closure devices. The ammonia solutions are consolidated at the
facility into a DOT approved shipping container. Similarly,
formaldehyde, gasoline, antifreeze, and approximately 10 other
chemical groups, are also consolidated into DOT approved shipping
containers.
Groups of chemical wastes to be consolidated are cleared in
•advance with the.ultimate disposal facility. Clearance-is provided
in the form of an approved waste profile sheet. The chemical
groupings are also reviewed as a part of the documentation of a
Health and Safety Plan.
Consolidation of wastes from assorted containers represents
the greatest opportunity for volume reduction but also presents
potential risks. Management review of adherence to the Operational
Plan and the Health and Safety Plan is performed on each drum of
consolidated wastes. Frequently 150 to 200 items have been entered
in a single drum. Generally 16 drums are involved in the process
of liquid consolidation at any given point in time.
B.Segregation Of Wastes
With chemicals for which a consolidation opportunity is not
present an opposite process is used, namely segregation.
Segregated wastes normally remain in their individual containers
and are placed in approved DOT drums along with similar chemicals.
This form of packaging is referred to as a "Lab Pack". The
chemicals allowed in each lab pack are of the same DOT hazard
class. They are also chemically compatible with each other and
with the absorbent packing material as well.
There are usually 16 lab packs in a progressive state of
being assembled and another 16 drums in which liquids are
consolidated at the facility. Management review of the segregation
accomplished by each drum lot is performed before each drum is
shipped using a computer derived printout.
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A typical list'is presented in Figure 6. Such lab pack lists
are automatically retrieved from the data management program on
all items handled at the facility.
C.Waste Analysis And Preparation For Shipment
At times chemicals and mixtures of chemicals are received
that cannot be legally or safely shipped. Explosive, shock
sensitive and most reactive materials are released to the
Anchorage Bomb Squad for disposal.
U.S. Coast Guard regulations require that corrosives and
flammables be shipped in separate containers. Wastes are
occasionally encountered that exhibit both of these
characteristics, when situations like this present themselves the
corrosive characteristic is neutralized at the facility prior to
shipment. Other wastes occasionally require decanting to separate
a flammable component from corrosives.
A chemical laboratory at the facility is used to measure
waste characteristics and to test compatibility prior to
consolidation. The laboratory is also used for preparation of
samples for off site analyses.-
VI WASTEWATER TREATMENT
Wastewater from the facility is collected in a 6,000 gallon
underground holding tank. Only the toilet is connected to the
septic tank and drain field.
water in the underground holding tank is pumped with a. vacuum
truck for delivery to the local sewage treatment plant. The waste
water is tested, prior to pumping, to determine conformation with
sewage discharge limits. Treatment of the wastewater in the tank
is required in those events when the wastewater fails to conform
to discharge standards.
VII WASTES SHIPPED
A.Destinations
All hazardous wastes collected at the facility are shipped
first to Northwest EnviroService Treatment, Storage and Disposal
Facility (TSDF) in Seattle, Washington. At this TSDF acids,
alkalis, oxidizers and water reactives are treated. Flammable
liquids are placed into an energy recovery program. Poison lab
packs are transhipped from the TSDF to an EPA approved Class I
landfill in either Oregon or Idaho. PCB items are also transhipped
to either of these landfills or forwarded on to Coffeyville,
Kansas depending on the PCB concentration. The Kansas site has an
EPA approved incinerator for destruction of PCB liquids. Aerosol
pesticides and halogens have been shipped to either Texas or
Arkansas for destruction in EPA approved incinerators.
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B.Treatment Methods
There are nearly an infinite number of chemicals received at
the facility requiring over a dozen treatment methods.
Certificates of treatment are issued by Northwest Enviroservice
TSDF after the wastes are received and treated.The treatment
methods described on the certificates are designated by a code
number. Treatments represented by each number are listed below.
SOI ~Drum Storage
T07 Rotary Kiln Incinerator
T22 Chemical Oxidation
T24 Chemical Reduction
T27 Cyanide Destruction
T29 Detoxification
T35 Centrifugation
T38 Decanting
T41 Flocculation
T45 Thickening
T63 Solvent Recovery
D81 Landfill
C. Recycle
T06 Liguid Injection Incinerator
T21 Chemical Fixation
T23 Chemical Precipitation
T2 5 Chlorination
T28 Degradation
T31 Neutralization
T36 Clarification
T40 Filtration
T44 Sedimentation
T46 Ultrafiltration
T64 Stripping
There are two primary waste streams that are managed for
recycling. They include scrap batteries and waste motor oil.
Presently scrap batteries are forwarded to a battery recycler
in Anchorage for reclamation at an approved EPA smelter located in
Los Angeles, California.
waste motor oil is currently shipped to an energy recovery
facility in Fairbanks.
"* Attempts to recycle aerosols, antifreeze, sulfuric acid, -
chlorinated solvents, mercury and silver previously have failed
partly due to the small volume and also due to the lack of local .
interest.
VIII
TO THE STATE OF ALASKA
The State of Alaska requires reporting of hazardous waste
activity similar to that required by the U.S. EPA. The period
covered by the attached reports, ,Figures 7 and 8, is from January
1 to December 31, 1991.
The quantity generated was reported as 922,264 pounds for the
calendar year of 1991. The source reduction quantity was listed as
50,557 pounds which was from separation and filtration of
rainwater which had been received with the waste oil, the shipment
of scrap auto service batteries and the stabilization of latex
paints.
Few other waste minimization activities seem to be available.
Recycling and waste minimization opportunities will, continue to be
sought-
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BUDGET SUMMARY:
Operating costs for Year I, Year II and Year III for the .
facility are presented in Table 3. The operation of this program,
which serves householders and CESQG's, is not a profitable
operation when measured by revenue generated from its users. The
value of the program obviously requires justification based upon
its ability to keep hazardous wastes out of municipal facilities,
such as the regional landfill and the waste water treatment plant,
and the Municipality as a whole.
M?12__L. "HAZARD CLASS CHOICBS FOR PA.TA LOGaTHG AHD PACKAGING
1- Flammable Liquid
2- Flammable Solid
3- Combusribls Liquid
4- Corrosive Material
5- Poison B
6- Organic Peroxide
7- Oxidizer
8— Flammable Gas
9- Non-Flammable Gas
10- ORM-E
11- ORM-D
12- ORM-C
13- -ORM-B
14- ORM-A
15- Non-Hazardous
16- Unknown
TABLE 2
QUANTITIES RECEIVED AT ANCHORAGE PACILITY
Flammables /
Combustibles
Corrosives
Poisons /OEMs
Oxidizers
Reactives
Car Batteries
Others
TOTAL
TABLE 3
Training
Marketing
Analytical
Transportation
Drums
Insurance
Disposal
Labor
ITEMS
16,087 20,773 24,?37 202,923
5,596 7,404 4,
3,463 3,674 3,
89 123
.2 3
3,204 5; 096 8,
2,537 9,084 10,
30,983 46,167 52,
252 27,434
666 36,509
79 S43
13 180
900 115,-344
389 32,387
236 415,425
POUNDS
YR--I-I YH-III
236,802 307,118
38,875 38,925
72,899 85,950
476 179
2 4
181,320 352,000
67,098 91,440
597,472 875,616
OPERATING COSTS .
YEAR I
2,925.00
14,315.84
17,565.00 '
28,119.00
37,084.00
52,376.00
123,681.00
465.084.00
Y2AR II
25,895.37
14,975.00-
53,430.00
49,830.00.
39,860.00
265,867.50
470,914.20
YEAR III
3,000.00
6,000.00
8,460.00
50,245.00
55,190.00
50,000.00
216,871.00
539,041.00
TOTAL .*$741,149.84 • **$920,772.07 ***$928,807.00
* tear I total includes the period frczn 2/14/S9 to 2/14,00.
** Year II total includes the period fran 2/15/90 to 2/14/91.
*** Year III total includes the period frsm 2/15/91 to 2/29/92.
418
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TABLE 4
ANCHORAGE HAZARDOUS WASTE COLLECTION FACILITY PRICE SHEET
FOR CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS
TYPICAL CONTENTS
PAINT
Paint
Varnish
Sealers
Adhesives
.Epoxy Resin
Aerosol Paint
•$.50/lb
$.50/lb
$.50/lb
$.50/lb
$.50/lb
$.50/lb
NON-CHLORINATED SOLVENTS
Solvents $.50/lb
Thinners $.5 0/Ib
Xylene 5.50/lb
Toluene $.50/lb
Methyl Ethyl Ketone $.50/lb
Alcohols $.50/lb
Car Polish $.50/lb
Furniture Polish $.50/lb
Copper Napthalene $.50/lb
Formaldehyde $.50/lb
CORROSIVE
Sulfuric Acid $.50/lb
Hydrochloric Acid $.50/lb
Nitric Acid $.5;0/lb
Acetic Acid $.50/lb
Alkaline Liquids (Soaps) $.50/lb
Ammonia $.50/lb
Oven Cleaners $.50/lb
GASOLINE
Gasoline $.50/Ib
Blazo $.50/lb
White Gas $.50/lb
JP4 $.50/lb
Gas/Diesel/Mixture $.50/lb
Gasoline Contaminated Oil $.50/lb
CHLORINATED SOLVENTS
Spot Removers $1.00/lb
paint Strippers $1.00/lb
Methylene Chloride $1.00/lb
Trichloroethane $1.00/lb
Carbon Tetrachloride $1.00/lb
Perchloroethylene and $1.00/lb
Still Bottoms
BATTERIES
Lead Acid $5.00/ea
Ni-Cad/Silver/Mercury $0.50/lb
Wet Alkaline $0.50/lb
Dry Cells ' $0.50/lb
PCBS
PCS Solid $1.00/lb
PCS Liquid $1.00/lb
TYPICAL CONTENTS
OXIDIZERS
Organic Peroxide
Hydrogen Peroxide
Nitrites
Nitrates
Iodine
Bromine
Chlorine
UNKNOWNS
Unknown
POISONS
Pesticides
Herbicides
Insecticides
Fertilizers
MOTOR OIL
Motor Oil
Linseed Oil
Tung Oil
Transmission Oil
Neatsfoot Oil
Hydraulic Oil
$1.00/lb
$1.00/lb
SI.00/lb
$1.00/lb
SI.00/lb
$1.00/lb
$1.00/lb
$1.00/lb
$1.00/lb
$1.00/lb
SI.00/lb
$1.00/lb
S.70/gal
$.70/gal
$.70/gal
$.70/gal
$.70/gal
$.70/gal
DIESEL
Diesel/Dirty Diesel $.70/gal
Kerosene . $.70/.gal
Fuel Oils . $.70/gal
ANTIFREEZE
Antifreeze $•70/gal
Ethylene Glycol $.70/gal
ORH
Grease $.25/lb
API Sludge $.25/lb
Asphaltic Compounds $.25/lb
Moth Balls $.25/lb
Oil Contaminated Soil' $.25/lb
NON HAZARDOUS
Photo Chemicals '
Latex paint
Car Wax
Caulking Compounds
Fertilizer
ALL OTHERS
Others
$1.00/gal
$0.05/lb
$0.05/lb
$0.05/lb
$0.05/lb
$1.00/lb
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LAYOLT OF ANCHORAGE HOUSEHOLD HAZARDOUS .WASTE rnr I FrTTQis; FACILITY
OUTDOOR
SUMP
I'. LOADING. *•
" DCCK 0
INDOOR BUND SUMPS
STORAGE RACK
OVERHEAD DOOR
STORAGE RACK
STORAGE RACK
FLAMMABLE STORAGE
FLAMMABLE STORAGE
r//////// SS / S S //Si
y/// STORAGE RAOC ///
'////////////////A
STORAGE RACK
STORAGE RACK
STORAGE RACK
CORROSIVE STORAGE
POISON STORAGE
STORAGE RACK
STORAGE RACK
SAFETY SHOWER
X (10F3)
CONSOLIDATION AND
PACKAGING
LOCKER ROOM
BOILER ROOM
DECONTAMINATION
AREA
LABORATORY
FIRE ALARM PULL STATION
ABC DRY CHEM EXTINGUISHER
OVERHEAD DOOR
CLASS D EXTINGUISHER
ESCAPE ROUTES
420
Figure 1
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If We Pay, Will They Come?: A 1-Day Collection for Schools & Businesses
Jan Ameen
Recycling Coordinator/Windham Solid Waste District, Vermont
Background
In 1987, the State of Vermont passed solid waste management legislation in the form of Act 78.
fRegional Solid Waste Management Districts were formed in order to accomplish the integrated
.waste management goals of Act 78. There are currently ten districts and two planning commis-
sions providing options for recycling, composting, hazardous waste collection, and trash disposal.
The Windham Solid Waste Management District was formed in 1988 and was originally comprised
of eight towns in southeastern Vermont. Currently, there are fifteen towns in the District, with a
population base of approximately 30,000. As members, each town has access to a District-owned
landfill, eighteen recycling drop-offs (igloo system), a 40 ton per day MRF, composting technical
-assistance and demonstration site, and an annual HHW Day. The District's operating budget for
fiscal year 1993 is 2.1 million dollars. .
The District's provisional certification for operating the landfill requires sorting every load of trash
and removing hazardous waste, especially ESQG waste. If hazardous waste is found, it is re-
moved from the trash and stored until the annual collection is held.
The Idea
The idea to hold a non-residential hazardous waste collection was based upon the belief that there
were unused state grants available to the District. Looking at places that fall through the cracks of
hazardous waste collection, schools stood out. High school labs are usually notorious for storing
highly toxic chemicals. During the school year, children spend almost half their day in school, yet
most schools cannot afford to pay the disposal costs for the hazardous waste filling the cabinets.
After an initial plan was designed to contact the schools and obtain inventories of their hazardous
waste, the District found out that the grant money didn't really exist. Without a source of funding,
the idea was put on hold.
During budget preparations, I discussed the concept of a school collection with the District Finance
Manager. We decided to request in the budget monies for a school collection and an ESQG collec-
tion. My original request for $ 10,000 for such an event was doubled to $ 20,000. The budget
passed with the $ 20,000 intact; $ 10,000 for schools and $ 10,000 for the commercial sector.
Monies would be available as of July 1,1992 and would pay for all costs of the collection.
Why pay for ESQG waste? Many managers believe that business should pay for their own haz-
ardous waste. To some degree, that's true. However, ESQG's in southeastern Vermont are: self-
employed, have only a few employees, and/or are not making a profit There is a fairly large artist
community, including painters, sculptors, and photographers whom are unable to afford disposal
costs for their very small amount of hazardous waste. Also, a typical scenario for ESQG's is to
save their waste until they have a 55-galIon drum, as it's cheaper than small amounts. Yet, when
they have a full 55-gallon drum, they might not have the $ 400 plus necessary to have it removed.
Finally, another Vermont District organized an ESQG collection but asked the business to pay for
the disposal. Although ten businesses registered for the event, only three actually showed and
paid. We thought that if we paid, they would come, and getting them to dispose of their waste
properly was the utmost goal.
The program was designed so that schools had the first opportunity to register, then ESQG's
would be contacted. The District would pay for as many ESQG's as possible with the allocated
funds. The money would be distributed on a first come, first served basis (pre-registration was
required for ESQG's.) If there were more ESQG's registered than funds could accommodate,
those not eligible for funds could choose to pay for the disposal of their waste. This meant that
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they could take advantage of the hazardous waste hauler being on site and pay a reduced cost per m
gallon, as the material was being bulked on site.
Schools •
In May, I contacted the superintendents of each public school supervisory union and informed ™
them of the free collection. A follow-up letter was sent to each superintendent requesting that they
pass the information on to each school in District-towns. (Some schools in each supervisory union •
are in non-District towns and were not eligible.) Realizing that this was an incredible offer and not |
having gotten one response, I again called the superintendents and requested a contact and phone
number at each school. This direct route proved much more effective. •
Responses from the principals ranged from a defiant "We don't have any hazardous waste in our |
school" to "We just cleaned out our lab last year and paid $ 6,000 to do it" to "We'll be there!".
The "We don't have any" responses were provided with a list of places to look and words to look _
for that might yield some hazardous waste. The "We'll be there" responses were asked to send a •
complete inventory of type and quantity of any waste they intended to bring to the collection. The ™
original date was expected to coincide with the District annual HHW Day in August Realizing the
difficulty of getting it all together in two months and keeping in touch with schools over the sum- •
mer months, the date was moved to late fall. Moving the date meant that some money would be I
lost to a set-up fee. However, it was decided that running a smooth event and covering all of the •
bases was more important than saving the set-up fee by holding two collections on the same day. •
In September, all of the schools which had not sent in inventories were contacted again. At this I
time, private schools were added to the list to contact. It's common for public entities to exclude
"private" anything. However, the reality that kids shouldn't be exposed to hazardous waste, pe- •
riod, regardless of which school they attend, resulted in the inclusion of private schools. Of the I
seven schools which participated, three were private. One of the privates' inventory was five
pages long, included radioactive materials, and listed chemicals that were from the 1930's. There
was enough waste from that school to fill a mini-bus! It they had not been included in our collec- I
tion, sixty years worth of hazardous waste would possibly have turned into seventy years worth. •
The schools' inventories were sent to our contracted hazardous waste hauler, Laidlaw, for a price
estimate. Laidlaw also identified items that were not acceptable, such as the radioactive materials, I
as well as direct ship items, such as reactive metals. The initial estimate was just under $ 10,000 •
but only included the four schools that had responded to the initial inquiry in May. Yet another
mailing was sent to each school principal. Three additional schools replied, all with small quanti- •
ties of waste, primarily paints and cleaners. It was decided to go over the $ 10,000 allocated for |
schools in order to accommodate these additional schools with very small quantities.
After seeing some of the inventories, I realized that there was some rather hazardous materials go- •
ing to be transported. In Vermont, ESQG's can transport their waste to a collection site so I didn't J
need to be concerned with DOT regulations. However, it was unclear who exactly would be
packing the chemicals in the vehicle. For that reason, each school received a memo on transporta-
tion safety. Included in the memo was a list of unacceptable items (radioactive), and a scheduled
time for their school. A school was scheduled every fifteen minutes, with the closest towns first
and alternating large and small quantities of waste. For-the most part this worked well, except for
one school that was thirty minutes early "just in case...". Another school took the safety issue
rather seriously and hired a local firefighter, complete with suit, air tank, and a few extinguishers,
to follow his vehicle on the twenty mile ride!
ESQG's
The most difficult aspect of organizing the ESQG half of the collection (held on the same day as the
schools) was identifying them and getting the word out. I decided not to do a huge article in the
newspaper as I imagined a hundred households showing up with their mothballs and silver polish.
Instead, I used a list of employers in Windham County. With a little "flip of a coin" science, I
whittled the list down to approximately 650 businesses. Excluded were medical and veterinary
practices, insurance companies, religious entities, various membership organizations, etc. The re-
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maining companies received a mailing alerting them to the collection and indicating that pre-regis-
tration was required. Unfortunately, the time frame was very tight, giving folks less than two
weeks to respond. The direct mail announcement was supplemented with a short radio interview
and a brief press release for the newspaper. This was an attempt to reach employers who were
missed and self-employed individuals, especially local artists.
Pre-registration is a standard feature of the District's hazardous waste collections. It allows us to
preview registrants, types, and quantities of waste being brought into the event. First, the District
needed to be very careful so as not to take waste from a regulated generator. To do this, all regis-
trants were checked against a listing of generators from the State's Hazardous Materials Division.
This safeguard worked in one instance, when a large generator wanted us to take oil-contaminated
soil. He was surprised when I responded that he was ineligible for the event as a regulated gener-
ator. He insisted that his company was a small quantity generator until I mentioned that I had an
EPA document, obtained from the State through the Freedom of Information Act, listing his per-
manent EPA I.D. number and his status as a large generator. I didn't hear from him again.
The pre-registration also allowed us to keep a running price quote in order to stay within the $
20,000 total budget for schools and businesses. The money was allocated on a first come, first
served basis. Once it was used, businesses could take advantage of the hauler's presence and pay
only for the disposal cost. This was not necessary as all twenty-three businesses that pre-regis-
tered had quantities that were paid for by the District
ESQG's that registered all received safety instructions similar to the schools,.as well as a scheduled
time. Two businesses were scheduled every five minutes. Again, some folks came 30-45 minutes
early, "just in case we filled up"!' However, the scheduling worked in preventing a line and al-
lowing the hazardous waste contractor to process (bulk) the material as it came in to the site.
The Day
The schools and ESQG collection day was held on Saturday, November 7, 1992, just over six
months after the idea was conceived. The site the District used was a local middle school. Not
only was it appropriate to have it at a school, but it was one of the few public locations with as-
phalt, a requirement for our hazardous waste events. The school is also one block from the local
rescue department, in case of a medical emergency. (The Fire Department was notified of the event
prior to its occurrence.)
Of the seven schools which registered, five are high-schools and two are grade schools. Some of
the most expensive disposal costs were associated with the school waste. All of the "direct ship"
waste originated from the schools, including biological waste, reactive metals, and organic perox-
ides. The schools brought in roughly 800 gallons of hazardous waste.
Every ESQG that had registered, showed up at the collection. As they checked-in, each vehicle
received a handbook on ESQG hazardous waste management produced by the State and were in-
formed about technical assistance from the District and the State. Some ESQG participants came
,with quantities that appeared to exceed the registered amount One painting company registered for
100 gallons of oil paint and appeared with almost twice that, mostly in one-gallon cans! (The paint
had frozen.) At least three registrants brought their waste in 55-gallon drums. The ESQG's
brought in roughly 1200 gallons of hazardous waste.
The Future
It is obvious that the program was a success, even though it only served thirty schools and busi-
nesses. Monies for another event in 1993 will be requested. Further, the District plans to build a
permanent hazardous waste facility, to be operational in October 1994. The permanent facility will
accept hazardous waste from both households and exempt small quantity generators.
Also part of the future plan is to expand the educational component of the District's hazardous
waste program. This will include printed material for households and ESQG's, as well as work-
shops for ESQG's on reduction, reuse, management and proper disposal.
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RK 6, BOX 9-G
,TrSi™vERMSNLT 05301 WiNDHAM SOLID WASTE MANAGEMENT DISTRICT
STEVEN D. JOHNSON
Execufive Director
BRATTLEBORO
BROOKLINE
OOVHR .
DUMMERSTON
GUILFORD
HALIFAX
JAMAICA
MARLBORO
NEWFANE
PUTNEY
READS8ORO
TOWNSHEND
VERNON
WHITINGHAM
WILMINGTON
-
; ' •'-• •.
l"
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424
ALERT!!!
'HAZARDOUS WASTE COLLECTION
FOR ESQG'S * (exempt small quantity
generators) HAS BEEN SCHEDULED
FOR SATURDAY. NOVEMBER 7. 1992
AT BRATTLEBORO UNION HIGH SCHOOL.
*ESQG'S GENERATE LESS THAN 220
POUNDS OF HAZARDOUS WASTE PER
MONTH OR 2.2 POUNDS OF ACUTELY
HAZARDOUS WASTE PER MONTH. YOU
MUST MEET THESE CRITERIA TO
PARTICIPATE ON 11/7.
UP TO $10,000 IN DISPOSAL COSTS PAID
FOR BY THE WINDHAM SOLID WASTE
DISTRICT. ONLY ESGQ's IN DISTRICT
TOWNS ARE ELIGIBLE.
PRE-REGISTRATION IS ABSOLUTELY
REQUIRED. $$ WILL BE ALLOCATED ON A
1ST COME, 1ST SERVED BASIS. WHEN $$
IS EXHAUSTED, ESQG'S CAN CHOOSE TO
PAY REDUCED DISPOSAL COST DIRECTLY.
YOU MUST PRE-REGISTER NO LATER THAN
MONDAY. NOVFMRFR 1. 1992. USF
ENCLOSED FORM.
CONTACT: JAN AT WSWMD, 257-0272
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1 STEVEN D. (OH.N'SON
Executive Director
1
IBRATTLEBORO
8ROOKLINE
DOVER
IDUMMERSTON
GUILFORD
HALIFAX
JAMAICA
MARLBORO
NEWFANE
1 PUTNEY
READSBORO
TOWNSHEND
IVERNON
WHITINCHAM
WILMINGTON
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WINDHAM SOLID WASTE MANAGEMENT DISTRICT
RR 6. BOX 9-C
COTTON MILL HILL
BRATTLEBORO, VERMONT 05301
(802) -257-0272
FAX (802) 257-51 22
PRE-REGISTRATION FORM FOR
ESQG* HAZARDOUS WASTE COLLECTION
SATURDAY, NOVEMBER 7, 1992
BUHS, FAIRGROUND RD, BRATTLEBORO
* ESQG'S GENERATE LESS THAN 220 POUNDS OF
HAZARDOUS WASTE PER MONTH OR 2.2 POUNDS OF
ACUTELY HAZARDOUS WASTE PER MONTH. ONLY ESQG'S
WILL BE ACCEPTED ON NOVEMBER 7.
WHAT CAN YOU BRING? Any container labeled ."caustic,
/ f
danger, toxic, corrosive, poison, flammable, warning, caution".
This includes: automotive products (not used oil),
photochemfc'als, oil-based paint (not latex), thinners,
preservatives, pesticides .(not 2,4,5 T, Silvex,
Pentachloraphenol), cleaners, degreasers, sealants. For a
more complete list contact the District.
WHAT IS NOT ACCEPTABLE? Empty containers, used
motor bll'i latex paint, Silvex, "2,4,5, T",
Pentachloraphenol, radioactive material, ammunition.
YoUymusitxpre^register to participate. Funds will be
allocated on a 1st come, 1st served basis. All others
may choose to pay the reduced disposal cost. Return
form by Monday -November -1st to : WSWMD. RR 6. Box
9-G; Brattieboro.VT 05301.
CONTACT
COMPANY
ADDRFSS
TOWN .-.--. DHONF
TYPES .& QUANTITIES OF WASTF
®425
REDUCE, REUSE, RECYCLE
-------
STEVEN D JOHNSON
Executive Director
BRATTLEBORQ
8ROOKLINE
DOVER
OUMMERSTON
CUILFORD
HALIFAX
JAMAICA
MARLBORO
NEWFANE
PUTNEY
READSBORO
TOWNSHEND
VERNON
WHITINGHAM
WILMINGTON
426
WINDHAM SOLID WASTE MANAGEMENT DISTRICT
/7
RR 6, BOX 9-C
COTTON MILL HILL
BRATTLEBORO, VERMONT 05301
(802) 257-0272
FAX (802) 257-5122
MEMORANDUM
To: Participants in hazwaste collection on
From: Jan Am eenTt-tecy cling Coordinator
Date: November 5, 1992
Re: Transportation safety, scheduled time
I hope most of you recieve this letter prior to Saturday:
Just wanted to send some safety tips for packing and
transporting your waste.
1.) All material should be a tightly sealed container.
Leaking containers must be packed into another
container'. Never mix wastes.
2) Wear rubber gloves while handling the waste,
especially it can be absorbed through the skin. Also,
pack in a well-ventilated area to reduce inhalation of
fumes.
3) NEVER SMOKE WHILE AROUND ANY OF THIS
MATERIAL/WASTE.
4) When packing containers in the vehicle, segregate
acids from bases and oxidizers from fiammables.
Oxidizers should be kept completely separate from all
other items.
5) If possible, carry a fire extinguisher in the vehicle,
in case of an emergency.
You are scheduled to bring your waste to the Brattleboro
Union High School at : a.m. Please try to
arrive at this time to prevent delays. Thanks.
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BE PART OF THE SOLUTION
REDUCE, REUSE, RECYCLE
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The Leeds WasteWagon Project : Interim Results
Sonia Heaven and Elaine Kerrell
Lecturer / Civil and Environmental Engineering Department Southampton University and Associate of
SWAP Recycling; Project Officer / Institute of Environmental & Policy Analysis Huddersfield University
and Associate of SWAP Recycling PO Box 19 Leeds LSI 6TF UK
Introduction .
This paper describes the WasteWagon Project which took place in Leeds, UK from February to
September 1992. The aim of the project was to investigate current attitudes to Household Hazardous
Waste and to establish parameters for effective HHW collection schemes in the UK.
Background
Disposal of HHW is a subject of growing interest and concern, both nationally and internationally.
Schemes to collect HHW are well established in the USA and are becoming increasingly common in a
number of European countries -' including Germany, France, Denmark, Sweden, Austria, Switzerland,
Finland, Iceland and the Netherlands. There are some interesting differences in methods and the
motivations behind schemes in Europe, North America and elsewhere. HHW collections in the USA and
Canada seem initially to have originated from the public, spurred on by a high level of awareness and
concern over household toxics. The earliest collections were actually organised by local groups of
volunteers, and while an increasing number of programmes are state-run or state-funded, there is still a
relatively high level of volunteer involvement. In Europe and Australia, development of schemes has
tended to be from the top down, with initiatives driven primarily by local and central government and by
the waste disposal authorities. A major force behind HHW programmes in Australia has* been concern
on the part of the water authorities about ground and surface water pollution, whether from sewage
discharges into Sydney harbour or from landfill leachate into the aquifers which supply Perth. The
organisation of schemes tends to reflect these differences, with little or no volunteer input outside the USA
and Canada.
The situation in the UK differs from that in both Europe and North America. At present, around
90% of domestic refuse in the UK is disposed of to landfill sites, with less than 10% incinerated - a
much lower proportion than in most European countries, where incineration is relatively common.
Materials such as DIY and garden chemicals, household cleaners, Pharmaceuticals and batteries are
generally disposed of to landfill with other domestic refuse, to become dispersed amongst relatively
harmless wastes. There are very few HHW collection schemes or educational initiatives. A number of
waste disposal authorities operate collection services for chemicals from trade and commercial customers,
some of which also provide a service to householders - but these are not actively promoted or advertised.
A small number of initiatives have taken place, such as local collections for specific materials like
batteries. These have generally been small-scale and, in the case of waste disposal authority schemes,
have deliberately been left low-key to avoid creating a demand which cannot be satisfied with current
facilities and budgets. As a result the issue of HHW has not really surfaced in the UK to the extent that
it has elsewhere.
The situation is beginning to change, however. Increasing awareness of environmental issues is
likely to lead to public concern about disposal of HHW and to pressure for collection systems, as has
happened elsewhere. In addition, the government has recently set a challenging target for local authorities
to recycle 25% of domestic refuse by the end of the century - a massive increase on the current national
average of around 3%. As recycling schemes becomes more widespread, the quantity of domestic waste
for disposal will be reduced. Hazardous materials are likely to become concentrated in the remaining
fraction for landfill, and the old 'dilute and disperse' methods previously advocated by the waste disposal
industry may no longer be appropriate. Interest in the problems associated with HHW is therefore
growing amongst those responsible for the collection and disposal of these materials.
427
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I
Special Collections Research Group and the WasteWagon Project I
In 1990 the city of Leeds introduced its pioneering SORT recycling scheme, which currently
covers 12,000 households and is achieving a reduction of approximately 45% in materials going to landfill. _
From the outset it was realised that the problem of HHW would need consideration if the service were I
to expand city-wide, both for the reasons described above and for others. The scheme is based on source
separation of refuse into dry recyclables (paper, metals and plastics), into organic kitchen and garden
waste, and into a third fraction of residues for landfill. Recyclables are taken to a pilot-scale sorting plant •
where they are hand-sorted into different streams, while organics go to a central composting site. In order ™
to achieve clean, good quality materials and to reduce the risk to sorters it is clearly essential to keep
HHW products out of the recyclable and organic fractions. •
Leeds City Council therefore set up a Special Collections Research Group to look at the options
for HHW. The Group included representatives from the Department of the Environment, ICI Paints, B&Q _
Pic (a major retailer selling household decorative products and garden chemicals), BP Oil Ltd, SWAP •
Recycling (a not-for-profit waste management consultancy), the British Agrochemicals Association, Leeds
University, Yorkshire Water, the National Rivers Authority and West Yorkshire Waste Management (the
local waste disposal authority). The Group looked at a wide range of issues including current UK legis- •
lation, existing methods of dealing with hazardous waste in the Leeds area, and HHW initiatives else- "
where. Leeds is fortunate in lying within the area served by West Yorkshire Waste Management(WYWM),
which operates a Chemicals Advisory Service for trade and commercial users. This service has a sliding •
scale of charges but offers free collection to householders who have dangerous material for disposal. The •
service is primarily aimed at industrial chemicals rather than the weaker formulations commonly used in
domestic products, however, and is not staffed or funded to deal with more than a small number of •
. enquiries from households. The Group also studied schemes in Canada, the USA and Denmark. I
Information on practical and operational aspects was gathered by Chas Ball, Development Manager at
SWAP Recycling who was able to visit these schemes through the award of a 1991 Churchill Fellowship. •
As a result of its activities, the Group decided that more information was needed in two main •
areas. Firstly, little information was available on public attitudes in the UK to HHW - what was the
current level of awareness, and how would people respond to the idea of a collection scheme? Secondly, •
it was felt that more operational information was needed. Results from North America and Europe vary . •
considerably, with early amnesty-type collections in the USA yielding an average of 35kg of materials per
participant, compared to figures of 2-4kg from Europe. Clearly, more reliable data are needed on the •
types and quantities of materials which a scheme might attract, and on the advantages of different systems, 8
in order to plan the most appropriate initiative for the UK.
The WasteWagon Project was set up with the aim of gathering this information. The scheme had
two main elements - a pre-trial public opinion survey, and an operational phase which would combine
a research project with a pilot HHW collection. The scheme was managed by SWAP Recycling with
research and operational funding from ICI Paints, Leeds City Council, B&Q Pic, BP Oil Ltd, Cory
Environmental and the Department of the Environment
The Attitude Survey
Aims and methods
The aims of the pre-trial public opinion survey were
to establish the 'hoarding' characteristics of typical UK households
to investigate public attitudes to HHW products
to determine public reaction to the idea of a HHW collection scheme
The main purpose of establishing hoarding characteristics was to gain some idea of the size and
significance of the problem. This involved estimating the quantity and age of HHW materials held in
store, and relating this to socio-economic factors where possible. In the investigation of attitudes, it was
decided to focus on two areas - the level of concern expressed by the public about these products, and
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the methods currently used for disposal by most households. Specific objectives in the third area were
to determine which of several possible collection methods would be preferred, and to find how this related
to people's experience of other collection initiatives, such as recycling schemes and pharmacists'
collections of old medicines.
In order to obtain all the information required, it was clear that fairly detailed and lengthy
-questions would be needed. It was therefore decided that the most suitable form of survey would be a
"questionnaire administered by interviewers. The questionnaire asked whether respondents had any of a
••^material, and if so how much; how long they had kept it fon how they last disposed of it; and how
s:much of a problem it was. These questions were repeated for a range of materials. There were then
questions on whether the respondent currently recycled materials, whether he or she would make use of
a collection scheme for HHW, and if so which of several options would be preferable. Finally there were
questions on die respondent's socio-economic details.
It rapidly became clear that the range of materials covered would have to be restricted. It was
decided to exclude household cleaning products from the survey, both because of the excessive time
requirement and the very large number of different products in use. This omission was less serious than
might appear, however. The only directly comparable data available came from a small survey previously
carried out in Leeds, which also omitted these materials. Many HHW schemes do not accept household
cleaning products because of the large quantities and variable hazard potential. As the planning for the
operational phase of the project progressed, it was also decided to omit these products. The survey was
therefore concerned with five main groups of HHW
DIY products
Garden chemicals
Medicines
Car engine oil
Household batteries
These were subdivided into nine categories which were used throughout the questionnaire:
Paints Fertilisers Medicines
Methylated spirits and solvents Pesticides Car Engine Oil
„: Wood treatments and preservatives Herbicides Household batteries
- As well as responses to the questions described above, interviewers recorded the location, date and
day of the interview and car ownership of participants. Occupations were grouped according to the UK
Registrar General's classification, with additional categories for housewives, retired persons of unknown
occupation, students and the unemployed. For convenience, respondents in the age group 6Oi- are referred
to as senior citizens, although some of these will be in full-time employment.
All householders are likely to generate hazardous materials of some kind at one time or another.
The survey had a special interest, however, in those actively involved in DIY and gardening, in those
making use of particular disposal routes, and in those who already participated in 'special' collection
schemes by recycling. The views of these groups are clearly of particular importance to the success of
any HHW initiative. It was therefore decided to carry out the survey at four locations - a Civic Amenity
(CA) site for household waste disposal and recycling, a supermarket multi-materials recycling site, and
two DIY stores. The survey was conducted between November 1991 and May 1992 at the four sites, with
194 respondents questioned by 9 interviewers.
Results of the Attitude survey — Hoarding habits
The results of the survey clearly showed that households are aware of storing significant quantities
of hazardous household material in the home, and that long-term storage (over 1 year) is common. All
those questioned kept at least one material, with paint and medicines the most popular (kept by around
90% of households), and garden chemicals least common at around two-thirds of participants. The
average number of items per household was 30, with many materials stored for over a year and some for
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l.^terttor of «3xarted
Material teems per
household*
,119**
Wpfci
Bsrt
' '2,8
,,3L6
445
285
He* *
Mote
oa
,2223,
TOTAI, 30^J
1335,
5SOS-
as long as 25 years. Figures for amounts of individual
materials provide a reasonable picture of the hoarding
characteristics of the average family, and at least a
basis for estimation of quantities held regionally or
nationally. The small amount of comparative
information available suggests that, if anything, people
tend to under-estimate the quantities they hold.
The survey confirmed that there is often a
correlation between the quantity of different materials
stored - that is, those who keep one material tend to
have others too. General information at point-of-sale
is therefore likely to be an effective way to
disseminate advice on safe disposal.
Those who keep car engine oil are likely to be
genuine 'Do-it-Yourselfers' who have significant
quantities of other materials. Information can be
targeted on this group via garages and automotive
product retailers. Certain household types are likely to keep more items than others - as expected, more
affluent households stored more on average. There were variations for individual products, however.
Managerial and Professional households appear to keep more medicines, but those in associated
professional or technical occupations had most paint and paint-related products, while storage of garden
chemicals was age-related with senior citizens holding more of these products than younger age-groups.
These differences mean that initiatives on specific materials - such as amnesties for old pesticides - will
need different strategies to allow them to focus on the appropriate groups.
Disposal methods
As expected, many of those with materials to dispose of used the dustbin or CA site, reflecting
the lack of other options in the UK at present In most cases, however, people simply kept material: this
was the main 'disposal route' for solvents, wood treatments, fertilisers, pesticides, herbicides and
medicines, and was a close second for oil and paints. The survey was slightly ambiguous, in that it did
not distinguish between keeping a material until it was used up and keeping it for other reasons. The
existence of large quantity of materials in store does present some problems, however. Certain materials
- such as oil, batteries and medicines - have no further use once their working life is over, and are
presumably stored because householders are unsure of the best disposal method. Changes in our
understanding of hazards and in product formulation may mean it is undesirable to keep products which
are very old. Some materials will eventually corrode through containers and cause spillage; and every
year there is a small number of accidents caused by careless handling and storage of hazardous products
in the home. Anecdotal evidence from WYWM's Chemicals Advisory Service (CAS) also suggests that
people bring chemicals home from work for a specific purpose, and are later uncertain how to use or
dispose of them.
The survey revealed small but significant numbers using disposal methods which are hazardous
to health and to the environment. These included disposal on the fire, on the garden, and down the sink
or drain. The need for better education and advice is clear, a simple first step would be inclusion of
disposal advice with other safety information on the product label. The most serious problems were
associated with oil - potentially one of the more hazardous materials. One fifth of those interviewed
appeared to dispose of this material in ways that were dangerous or illegal; a further 22% kept it,
presumably because they did not know how to dispose of it. This is in spite of the presence of oil
recovery points at all CA sites in the area. There is clearly a dangerous lack of knowledge, both of the
existence and location of facilities and the importance of correct disposal.
The survey also indicated the existence of groups with potentially serious disposal problems. For
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each question there were some categories of respondent who stored more of certain materials, kept them
for very long periods, or disposed of them in potentially hazardous ways. The small size of sub-samples
made it impossible positively to identify 'at risk' groups who fell into one or more of these categories,
but the results suggest there could be a cluster of common factors. This was supported by anecdotal
evidence from the interviewers. In particular, disposal methods chosen by women and the elderly were
often questionable • and older people are likely to have older and more hazardous product formulations,
and to store larger quantities of materials such as garden chemicals. This group is least likely to be
reached by DIY store-based or CA site information, and separate initiatives to recover dangerous materials
may be necessary.
Very few respondents made use of alternatives, such as giving materials away to others who could
use them. As with other types of waste, the best method of dealing with HHW is not to generate it.
Possible initiatives in this area include better matching of quantities sold to the customer's requirements
- although the current trend is to cut production costs by standardising on a small number of product
sizes. Failing that, one of the better disposal routes is to use a product up in accordance with the
manufacturer's instructions or to pass it on to someone who can - perhaps through a Paint Exchange or
similar scheme. There is clearly scope for vigorous promotion of the idea of passing on unwanted
materials, and for investigation into efficient local exchange systems.
Levels of awareness and support for HHW initiatives
In the part of the survey which assessed levels of concern about HHW, men and young people
consistently expressed greater concern than women or older age-groups. As might be expected, affluence
and education also appeared to be'factors with those in professional occupations being particularly aware
of problems with these materials. The lower level of concern amongst women is a surprising finding,
however, since surveys have generally found women to be more conscious than men of environmental
issues. DIY is often seen as a masculine activity in the UK, so it may be that women are less aware of
the materials used, less involved in decisions about purchase and disposal, and do not feel ownership of
the problem. This contrasts with the situation for most other domestic waste, where it is typically women
who make key decisions. It seems that the issue of HHW may require different tactics to raise awareness
from those employed in more conventional recycling and waste reduction initiatives.
Results for individual materials showed considerable confusion amongst the public. There was
particular doubt over oil, with 30% assigning it the lowest of 5 rankings (defined as 'no problem at all')
and 30% the highest ('a definite problem'). Respondents were generally more confident about disposal
of batteries and medicines. Awareness of the environmental issues surrounding battery disposal does not
yet seem to have reached the UK, while the existence of schemes to collect unwanted medicines may
reassure (he public that these materials can be safely dealt with.
There was strong support for a HHW collection service, with 78% of respondents saying that they
would make use of such a scheme. This high level of
support may partly reflect respondents' new awareness,
how-ever. HHW is an issue which has so far received
rela-tively little attention in the UK, and most members
of the public will not be familiar with the term or the
arguments surrounding it The questionnaire itself may
have acted as a consciousness-raising process, at the end
of which respondents were fired up with new ideas on
the subject. It is also notable that only 10% actually
took medicines and Pharmaceuticals back to the chemist
for disposal, whereas 64% said they were aware it was
possible to do so. The degree of support should
therefore be regarded with some caution, but at least
indicates the power of a new idea.
CA Ste $9.29$
Ifcbik (40.75}
OK $0.1$
Fig 1
Preferences
Collection
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Mobile collection services were generally preferred, although it was presumably difficult for I
respondents to judge the best method with no prior experience. Those who already recycled materials ™
were particularly supportive, however. The types of service mentioned in the questionnaire - facilities
at CA sites, DIY stores or a mobile collection service - would certainly reach a large proportion of the •
population who use hazardous household products. Women were much less enthusiastic about the CA •
site option, however, as were senior citizens and non-car-owners. This could have particular implications
for schemes which include household cleaning products, since these are typically seen as women's I
concern. Siting and layout of facilities are likely to be an important issue in any scheme which aims to B
attract a wide range of participants.
Operation of the Leeds scheme — Materials collected I
The first decision on the operational phase of the scheme was whether to adopt an amnesty-style
approach and accept all HHW materials. Restricting what is collected reduces the impact of a scheme, ^
but this must be weighed against the obvious safety implications of accepting any hazardous materials I
which householders may have in store: in North America for example, collection of ammunition and
explosives is not uncommon. Explosives were not expected at the Leeds scheme, but as this was the first _
of its kind in the UK, there was no baseline to work from and contingency had to be made for any •
eventuality.
It was decided to restrict collections to materials which could be dealt with safely using the «
resources available - an important consideration for any scheme. Acceptable substances were defined I
as those within three broad categories: paint and paint-related products, garden chemicals, and automotive
products such as used engine oil and antifreeze. Pharmaceuticals were excluded because householders are _
normally advised to take unwanted medicines back to chemists - although SWAP Recycling is currently •
undertaking research into the adequacy of this advice. Household cleaners were also excluded, mainly ™
because of the vast array available and the difficulty of categorising them. Also the best advice, at least
for recently purchased household cleaners, is to use them up in the purpose they were designed for. •
Household batteries were excluded as there are presently no recycling facilities in the UK. Because ™
changes to the UK legislation will occur as a result of the EC Batteries Directive 1990, the best advice
to authorities considering battery recycling is to wait until the position becomes clearer. I
Types of collection
Once the materials to be collected were defined, it was necessary to decide on collection methods. •
Since the scheme was intended to gather the maximum amount of data, it was decided to test a number |
of different methods. Collections were based around the WasteWagon - a purpose-built vehicle specially
designed for the project, which allowed a variety of locations and collection systems to be Dialled. The •
design was based on a vehicle used for the collection of HHW in Arhus, Denmark, with advice from •
WYWM CAS. The design allowed separate storage and transportation of HHW to a depot provided by
the city council and modified for the scheme. _
The collection, launched in March 1992, involved both a 'static' and a 'mobile' collection service. |
Three days of the week were spent at a B&Q DIY store, where collections were made from the store car
park. The other four days were dedicated to a schedule of pre-announced stops - initially in the area M
covered by the SORT Kerbside Recycling Scheme then, between August and the end of the trial, in ten •
other areas. In this way the scheme was made available to about 90,000 households in and around Leeds.
The WasteWagon collection rounds were accompanied by a publicity campaign. Initially, •
advertising in local papers and door-to-door leafieting was undertakea The latter was concentrated on J
the SORT area and on 40,000 households in the vicinity of the B&Q static site. Later, with expansion
of collections into the oudying areas of Leeds, targeted advertising and leafieting was undertaken to •
encourage local householders to .use the service on the most convenient day for them. From the |
experience of the project a great deal has been learned about targeting publicity.
The scheme was not aiming for high numbers, so did not indulge in high-profile advertising (eg
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TV, national media). In the planning stage there was concern that the scheme would be oversubscribed
if it was too widely advertised. It was found, however, that sustained local advertising, coupled with other
forms of promotion and educational campaigns, was necessary to maintain numbers. The effect of
publicity had a sharp decay curve. The relative success of different advertising methods must be
investigated as even low-profile advertising is very costly. From participants responses when asked where
they had heard about the scheme, the most successful method appeared to be leafleting, closely followed
by newspaper advertising. The newspaper most commonly referred to was Leeds Weekly News - a local
free paper.
Operation of the scheme and data collection
In order to be accepted, materials had to be in clearly marked, non-leaking containers. Materials
which did not comply were refused and a Waste Rejection Notice issued. This gave advice to the
householder, depending on the reason for rejection. To comply with the Duty of Care under the
Environmental Protection Act 1990, a waste ticket recording the item(s) collected, name of the
householder and date of collection was filled out when the material was handed over. In addition, the
form included information on the number of households contributing to the batch, how the householder
found out about the Waste Wagon and whether this collection was the first time the household had used
the service. Later in the scheme, the gender and age of the individual and the weather conditions on the
day were also recorded.
Before materials were off-loaded and stored at the depot, a detailed Materials Log was completed.
This included information on:
• manufacturer • type (eg emulsion paint)
• colour (if relevant, eg paint) • size, weight and type of container (eg plastic)
• reusability and estimated age • special information / advice on the container
• hazard category
This provided a vast amount of information, analysis of which is still in progress. The
Waste Wagon was essentially a research project, intended as a data gathering exercise. In an operational
scheme this level of data collection would not be possible, or even desirable. It was not unproblematic,
however. Accuracy of data gathering relied very much on the two operators. As local authority
employees, they had never before been involved in a research project which required them to keep detailed
and very accurate records. Also, as with any research project, changes were constantly being made to
refine the system and to incorporate new ideas as they arose. The success of the project was both a tribute
to the operators' enthusiasm, and a valuable demonstration that this type of scheme can be run by ordinary
municipal employees with suitable training.
Health and safety and compliance with regulations
Obviously, when operating a scheme designed to collect potentially hazardous materials, safety
is of paramount importance. Considerable instruction was given to the operators on safety procedures with
the aim of reducing the risk both to themselves and to the public. All personnel attended HAZPAK
training courses, which includes training on legislation and codes of practice concerning hazardous
substances, on packaging, labelling, loading, securing and segregation of materials, on the use of safety
and fire-fighting equipment and on first aid.
Handling of hazardous substances which present a risk to workers and/or the general public is
regulated by the Control of Substances Hazardous to Health Regulations 1988 (COSHH). A COSSH
assessment involves examination of operations to identify where barriers (eg special protective clothing,
remote procedures) are needed to minimise risk. With the help of the Safety and Environment
Department, Id and WYWM, a COSHH assessment was carried out both for flie operation of the vehicle
and procedures at the depot
The main recommendations were for provision of protective equipment in the event of a spillage
occurring as a result of a dropped container, and spillage clean-up equipment. The Waste Wagon had an
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extraction fan installed to cater for any accidental evolution of fumes or vapour. It was recommended that I
this be kept running at all times when the operator was at work. An extraction fan was not required for
work at the depot, but the door to the shed or flammables store had to be left fully open whenever an _
operative was working there. At all other times these were kept locked. A mobile telephone was provided I
for the operator to call for assistance.
In the planning stage of the project various agencies were contacted for advice. These included •
the Health and Safety Executive, the Fire Service, the Emergency Planning services and the Police J
Contingency planning unit. Advice was sought from the Peace and Emergency Planning Unit on
contingency plans in the event of a major incident, requiring evacuation of personnel and members of the •
public. The Police were also briefed about the scheme. One of their main concerns was that material I
would be left at collection sites outside collection hours. Plans were made to deal with this eventuality,
including arranging for staff at the B&Q static site to accept and temporarily store material until it could
be collected. . •
The Waste Wagon did not have to be independently licensed as a waste carrier as it was operated
by Leeds City Council as a collection authority, and was therefore covered by the city council's M
authorisation. The storage facility was licensed as a transfer station in accordance with normal waste I
disposal authority procedures. Requirements in the EPA Part 2, Section 34 (Duty of Care) was fulfilled
by the completion of documentation when the waste was collected. _
Transfer, storage and disposal |
Once collected and recorded, all materials were assigned to one of the following waste categories
to allow packing for safe transfer to the depot. .
FLAMMABLE • CORROSIVE - ACIDS
CORROSIVE - BASES • OXIDISING
TOXIC • OIL
OTHER (NON-FLAMMABLE, NON-CORROSIVE, NON-OXIDISING, NON-TOXIC)
A storage container for each waste category was available on the WasteWagon. All substances
were kept in their original containers; no bulking or consolidating took place, except for oil which was
decanted into a storage tank in the depot. Each hazard category occupied a separate, bunded storage area
in the depot. The fundamental principle was to keep incompatible chemicals separate. Two lockable
metal cabinets were provided for temporary storage of dubious materials (prior to further checking), and
for those destined for incineration.
Material was disposed of according to the following hierarchy of options
RE-USE RECYCLING ENVIRONMENTALLY SAFE DISPOSAL
At the planning stage, it was assumed that most material collected would have to be disposed of
either to landfill or by incineration. This was found not to be the case. The bulk of material was either
paint or oil, and both of these could be re-used or recycled. .
Paint was sorted initially into flammables (solvent-based) and emulsions. It was further
categorised according to its quality: good quality for re-use, medium quality for recycling, and poor
quality or containing toxic components (eg lead) for safe disposal. A surprising amount - around 10%
- was found to be of good enough quality for immediate re-use, and a small-scale Paint Exchange trial
was set up with financial support from both UK2000 and 10 Paints, to utilise the material collected by
the WasteWagon. Non-reusable paint was either low in quantity, of poor quality, or deemed non-reusable
by its mode of application, age or active ingredients (eg lead). Most of this paint was sent for recycling
into low-grade paint. Empty plastic containers were used in recycling trials, where they would be washed
and then granulated before re-extrusion. Empty steel containers were recycled through the Save-a-Can
scheme for ordinary household cans. All the oil collected was recycled through a local company, and
earned a small remuneration. .
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Once the reusable and recyclable material was extracted, the material for disposal remained. With
advice from the CAS, this was separated either for disposal to landfill or for incineration. The majority
of landfilled materials were containers with, large residues of dried paint which was unsuitable for
recycling. Other materials were either mildly corrosive or toxic. The placing of substances at the landfill
site was carefully supervised by the CAS to ensure that they were not mixed with combustible household
waste. Only a small proportion of material had to be incinerated, consisting mostly of garden chemicals
and a few reactive materials (eg carbide of calcium). These were personally delivered to the incinerator
hopper to ensure that combustion occurred inside the incinerator safely away from household waste
awaiting destruction.
Collection results
At the time of presentation of this paper, data gathered by the operational phase of the
Waste Wagon scheme are still being analysed and these are interim results only. Further information from
the scheme will be incorporated in a full report, which will be made available in time for a UK conference
on HHW to be held in Spring 1993. Presentation of results here is in general terms only, with detailed
discussion to follow in the final report.
During the eight months collection period a total of around 450 people brought material to the
scheme. The average weight of material fluctuated over this period, increasing during spring as garden
chemicals began to be brought For the whole of the scheme the average has been 8 kilos. This value
is somewhere between typical European figures (eg Arhus) with averages of about 2kg and the North
American experience where average weights were around 20kg.
An interesting result was the difference between mobile and static collections. During the first
phase of the scheme results from the two were comparable. As the impact of publicity wore off, the
decline in the static collection was more marked. Indeed, numbers were maintained for the mobile
collection even though the statics were declining. As the Waste Wagon had been sited for three days every
week at the static site, it was thought that a plateau had been reached when further collections would bring
diminishing returns. For the mobile round, the Waste Wagon had visited the same collection points every
week for nearly six months - this is overkill by any estimation.
In the final two months of the scheme, it was decided to try out something closer to an operational
model. During this period, although the original static site was maintained, eight other static sites were
visited. These visits adopted a more intermittent pattern - visiting in one week only and then moving
on to another site. This was found to be far more effective, with significantly greater numbers visiting
the static sites in the second phase. Giving too much opportunity, to householders is obviously not an
effective approach! In an operational scheme, mobile collections should probably be restricted to
collecting from the housebound or immobile, possibly en route to static sites, or as part of another form
of collection. Once or twice-yearly collections would definitely be preferable; restricting visits is a better
use of resources.
The mobile collections in the second phase were less successful because too much was attempted.
To minimise promotional costs one leaflet was produced which could be used throughout the two months
period. It had to contain all the information about both the new mobile and the new static sites, as well
as the existing static site. In practice this was too big a task. It restricted the details which could be given
about each site and specific visiting times could not be included. Householders were advised to call a
helpline or the Waste Wagon on the mobile telephone for further information. Some did so, but many
others went to the static sites instead.
Profile of scheme users
In the final stage, when collections were spread to a wider population, data was gathered on the
age and gender of users. It would have been valuable to have collected these data throughout, but there
was a risk of overloading the operators at the start of the scheme. In the planning stage it was considered
that typical scheme users would be recyclers, DIY enthusiasts and classic 'hoarders'. In fact users were
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predominantly male and in the age range 40-60 - not necessarily the most enthusiastic group according
to the survey. One other small but important group was elderly ladies: the few who did use the scheme
brought some of the most unpleasant materials, confirming the survey's suggestion that this group may
need special attention.
Although users were not questioned about their motives for coming, it was evident from
observations they made that broader environmental considerations were not the main motivation. They
came because they had a disposal problem. For many, using the scheme solved an otherwise insoluble
problem. This was particularly apparent for those bringing waste oil. Knowledge of existing facilities
was quite obviously low, and those bringing oil were offered information on recovery facilities elsewhere.
For others, the vehicle siting made it convenient for them to use, rather than taking material elsewhere (eg
a CA site).
Conclusions and recommendations
The operational phase of the WasteWagon project collected a vast mass of data on aspects of
HHW. It is not possible to present the full conclusions at present, as this data must be analysed,
assimilated and compared with the findings of the pre-trial survey. Results will be presented in a full
report, which will be available later. However, some interim conclusions are possible.
• The main users of the types of collection tested in the operational phase are likely to be men
rather than women, and between the ages of 40-60. This contrasts with the survey findings, which
indicated greater support amongst younger age groups and women. In family households, the
actual user of the scheme may not be the most motivated person, but simply the one who was sent
to do the job. The findings suggest, however, that schemes which wish to draw in a wide range
of participants may need to consider other approaches.
• The quantity of material brought at around 8kg per participant was higher than expected. It was
thought that quantities would be closer to those found in European schemes than in North
America. In fact the average yield was somewhere in between, although a detailed breakdown
by users is required for further analysis.
Environmental considerations appeared to be less important as motivation for users than the
solution of a disposal problem. This also ties in with the survey findings: it appears that the
general level of awareness in this area is still lower in the UK than elsewhere.
• Static sites visited occasionally after an intensive pre-publicity programme appeared to be the most
effective of the options tested, in terms of bulk quantity. However, there are clear benefits from
the provision of permanent facilities or regular visits.
Collection data indicated that there were different patterns for different materials. Optimum
solutions might involve a range of initiatives, such as targeting specific materials by means of
paint exchanges and enhanced oil recovery facilities, with specialist collection services for more
hazardous products or for specific social groups. All of these approaches form an important
element in the comprehensive programmes of education and avoidance which are essential if we
are to reduce the quantities and problems of HHW.
The WasteWagon project was a fascinating hybrid, operating as it did with Leeds City Council
personnel and facilities, managed by SWAP Recycling, with funding from industry and the Department
of the Environment. Each organisation had different requirements from the project and different
motivations for their involvement. The project was a success not only because it fulfilled all these
requirements but because it also showed how a co-operative venture could be achieved.
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HOUSEHOLD HAZARDOUS WASTE PUBLICITY CAMPAIGN
Case Study — Alachua County, Florida
by Jill Parker, Senior Environmental Specialist, Alachua County
BACKGROUND
Alachua County is located in north central Florida. There are nine (9) incorporated cities and a population
of approximately 185,000. The city of Gainesville is at the heart of the county and is comprised of 48
%. of the total population. There is a large unincorporated area of Alachua County in which 43 % of the
population live. The community, as a whole, has a very "environmentally active" disposition.
Alachua County's household hazardous waste (HHW) collection program began in 1984 and is organized
through Alachua County's Office of Environmental Protection (OEP). The program is a component of the
Board of County Commissioners' policy for protecting human health and the environment in Alachua
County. The funding for the projects has been either from State grant monies or an established percentage
surcharge from the landfill tipping fees. These events are held in the City of Gainesville, during a
Thursday, Friday and Saturday time period, 12 hours a day every 18 months. The events were located
in the parking lot of a major shopping mall until 1991. Three different contractors were utilized between
1984-1991. Over 1500 cars have take part in each of the events. Much was learned over those years,
especially that the program can be very expensive unless a consciences effort is made to recycle/reuse the
materials that are received at the collection event.
In 1991, a two year contract was negotiated with Quadrex Environmental Company, Inc., The contract was
written to incorporate provisions for a strong infrastructure for the HHW management program. The
major improvements to the program were establishing a regularly scheduled HHW collection occurrence
of every six (6) months, holding the events at Quadrex's Treatment, Storage and Disposal (TSD) facility,
just north of the city of Gainesville, and the provisions for hiring an local independent Solid and
Hazardous Waste Specialist to strengthen the material recycling/reuse efforts.
PUBLICITY
The publicity campaign that accompanied these event has also improved over the years. The Office of
Environmental Protection has contracted a publicity agency to assist in the organization of publicizing the
HHW collection events. The campaign begins a week before the events, which are scheduled for April
and September.
The media that are utilized for the champaign are:
• Newspaper • Road Signs • Radio
• Television • Utility Billings Newsletter • Schools
The publicity agency has proven indispensable for negotiating price structures. Often they benefits as a
"bulk" buyer and receives special discounted rates for the announcements. They also have'established
ongoing working relations with the various orgainazation.
Area environmental companies are contacted in regards to providing donations towards the collections
events. Those donating are recognized on the all written forms of advertisements.
Newspaper
There is one major newspaper in Alachua County that has a distribution reaching 51,000 people. The
advertisement (2" x 13") is published for six (6) week day editions and the weekend prior to the event.
"Thank you" adds are also published after the event. Often times public education articles are published
and well as public service announcements (PSA's) at no cost. This announcement is also published in
a "Buyer's Guide" which is distributed to all residents within the City of Gainesville once a week by the
same publisher. The cost for this coverage averages around
$ 3,350. Announcements are also published in a secondary paper on two different days at a cost of $ 250.
During the April event, the newspaper run a series of Earthday activities announcements which help
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motivate the public into participating. B
A lot of effort has be spent on developing a good rapport .with the newspapers in order to receive a
helping hand in this campaign. B
Television
A 30 second commercial was made showing the "drive-thru" method used for the collection event. The •
commercial is shown seven times on 4 different cable networks a week before the event. The negotiated B
price for this coverage is $1,500 (50% discounted rate). The local TV station show the commercial as
Run Of Station (ROS) three (3) times on the weekdays before the event. ROS provides a reduced rate •
and the commercial is seen at various time throughout the day. The commercial is also shown during the B
evening news casts Friday, Saturday, Sunday, and the evening before the last day. The cost associated
with advertising is $ 3,000. .
Radio . |
A major effort has been made to develop a good working relationship with the area Radio stations. The
results have provided free 30 and 60 second PSA's and news coverage of the collection events over the • fl
past 8 years. B
Road Signs
Directional road signs are placed on major roads leading to the collection site one week before the event B
with the dates of the event identified. This is a means of free advertisement reaching motorist traveling
these roads. . _
Monthly Utility Billing Newsletter |
An article was written for the newsletter mailed with the City of Gainesville monthly utility bill.
Placement of the article in the newsletter required knowing the collection days 4 months in advance. The •
billing also only reaches the City of Gainesville utility customers. This form of advertising is potentially B
effective because close to 50 % of Alachua County's population receives this billing.
Schools B
The school system can be a vital part of a publicity campaign. Flyers and news releases are distributed
to K-12 grade school PTA organizations, teachers, and newsletter editors. This year a coloring contest
was added for K-5 grades. Prizes (T-shirts) and certificates of participation were awarded. B
RESULTS
Surveys taken during the HHW collection event show that most people are will to travel an average of •
10 miles to participate. The most widely recognized means of advertisement is through newspaper |
announcements. Television is next with radio, utility billing and school respectively. Over the past two
years we have been able to lower the cost spent on multi-media through aggressive negotiation and •
"discount rate" advertisement without adversely effecting the participation rate. Also it should be noted B
that a major effort is undertaken to obtain donations from area businesses to help supplement the overall
cost of the advertisement campaign.
The key elements for the successful of Alachua County's HHW collection are a combination of:
• the development of an annual budget,
• a structure contract with emphasis on recycling/reuse of the collected materials and other cost
saving activities
• the accessibility of a T/S/D facility within the county, and
• a strong publicity champaign.
The money saved through the recycling efforts has been utilized in public environmental educational
campaigns.
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Lois Kaufman
Environmental Research Associates
Source Reduction: Surveys
Environmental Research Associates (ERA) is the nations largest research company dealing
in environmental issues. If the last month is any example, the next four years are going to
be very interesting. Since the election, one newly elected official in California has urged
the ban on all new fireplace construction in homes to cut down on air pollution.
Environmentalists have petitioned that two new species of fish, the Long Finned Smelt and
the Sacramento Split-tail be added to the endangered species list. I think we are going to be
very busy.
One of the things we do at ERA, quite simply, is talk to consumers. We find out what they
like and don't like—including types of packaging. What they know and what they don't
know—including various environmental terms used on labeling and in the media; and how
environmental concerns stacks up against other national issues.
The things I am going to say to you today are not my opinions only, they are based on
thousands and thousands of interviews over the past years. Some of these interviews have
been with average consumers to find out what they see and think about the environment.
We have also done business to business surveys. We are just finishing the first part of a
study of 500 opinion leaders across the nation. Some of these findings also come from our
syndicated study called "The Environmental Report", and from dozens of other proprietary
studies that we have conducted over the past year. So with all this information we feel
pretty confident about some of the trends that will affect all of us.
The title I've been given for this speech is "Source Reduction and What Consumers Think
About It". The problem is consumers don't think much about source reduction. That
doesn't mean that consumers aren't concerned about the environment—they are; but source
reduction is not top-of-mind. What is top-of-mind is recycling. Before we get into a
discussion on source reduction and recycling and what people prefer, let's straighten out
one thing right away. I've read some articles that the environmental concern is waning,
and that people aren't as concerned as much about the environment as they once were.
Nothing could be further from the truth. The environment isn't going to go away. In fact,
there's clear evidence that it's ready to explode.
Seventy four percent of all consumers said they are doing something around their homes to
improve the environment; a significant increase over the past year, and 44 percent said they
have changed their shopping habits; also an increase. Now, we forced people to tell us
specifically what they are doing to be counted in these numbers. But, even if there is some
exaggeration in these numbers, we believe that if people lie, they lie consistently; which is
good about tracking data over time. Whether they lie or not the trend line is going in only
one direction and that is up.
Environmental concern is taking a very subtle and fundamental shift; this is where there
may be some confusion. It is being institutionalized into the very fabric of our lives and is
becoming less obvious, less controversial perhaps, but far more important. Consumers are
focusing on fewer issues like oil spills and tuna caught in dolphin nets, and on many
smaller, individual concerns that directly affect our everyday lives. Let me give you some
examples: Thirty four percent of all adults said they have purchased a product or brand in
the past three months because the manufacturer has a good reputation for environmental
concerns; this is up 47 percent in the past two years. Eighty different companies or
products were sighted by name as being or doing something good for the environment;
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compared with only 37 companies just three months ago. This increase occurred among all •
age groups including older people who have been traditionally less involved with the
environment. The variety of products being mentioned as "good" or "bad" for the •
environment is also significantly more diverse. Most companies mentioned are still food j§
and oil [based], but automotive, clothing and personal health care products, as well as
retailers are becoming increasingly mentioned by consumers. , _
The environment has moved from being issue driven to lifestyle driven and is based more ™
and more on what people feel are their personal long-term needs. This is important
because trends are based on basic human needs; fads are not. That is why trends last and •
fads don't. People will continue to be environmentally responsible for some time. And the •
fact is, to many people, being environmentally responsible means recycling. Consumers
have inalterably linked recycling and the environment. When we ask them what companies •
have done to help the environment, they tell us--"recycle"; or that the company's packages |
can or have been recycled. When we ask them how can companies improve the
environment, the number one answer to this is "improve the packaging"; and consumers _
universally focus on recycleability. This is both predictable and troublesome. Predictable I
because in virtually every study we've conducted over the past several years consumers • •
have viewed recycling as the answer, not an answer, but the answer to all of our
environmental problems; and that includes not just solid waste, but everything else as well. •
This is troublesome because consumers have unrealistically high expectations for recycling; |
this may spell problems for us in the years ahead when consumers feel that these
expectations are not being fulfilled. Recycling is important, but we have to start selling the •
American public on the importance of other environmental issues and other solutions. I
Source reduction is just one of those other solutions.
The idea of source reduction or using less packaging sounds pretty good to consumers I
when they know about it; the problem is not very many do. Only 16 percent, or fewer •
than two out of ten people know what the term source reduction means. Even educated,
upscale adults are no more knowledgeable. One company paid a fortune to run a full page •
editorial in Fortune magazine telling readers all about what they were doing in the area of J
source reduction. Unfortunately, very few understood what they were talking about; they
wasted their money. Often we use terms and we expect people that we're trying to reach to —
understand those terms; they don't. We need to do a much better job of educating people •
about environmental terms and issues. •
Source reduction is simply not a concept that many people talk about or think about. For.
example, we asked people to name a way to reduce household trash and waste (the only
stipulation that we gave them was they couldn't say recycling). Half of the people we
spoke to, simply couldn't do it. They couldn't name a single way, other than recycling, to
reduce the stuff that we throw into the trash. Then we asked the question again. This time
we explained each option (including source reduction), and then they could say recycling as
an answer. Once people know about source reduction they think it's a great idea.
Recycling is still the answer most Americans give for handling our solid waste problems.
However, when people are introduced to source reduction and given a brief explanation of
what it means, support significantly increases; indicating the need for better education and
broader educational programs. When explained all of the terms, 44 percent of the people
said recycling is the best solution to reducing solid waste; but, 33 percent said source
reduction. Among more educated people, source reduction is viewed as just as important
as recycling, when explained the term. Again, this indicates the need for educating people
about source reduction. Incineration and landfilling are far less 'desirable options. The
concept of source reduction is catching on, but very slowly. When we asked people, what
specifically did a company do that causes you to believe that it's not environmentally
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concerned? A small percent (5), told us excessive packaging; this is up from zero percent
from the Spring of 1991. '
But, recycling is what's happening, what's sexy, and what's now. Seventy five percent of
all adults in this country believe we can recycle our way out of our environmental
problems. They believe that 68 percent of our trash can and should be recycled. Divide
that by three and your probably closer to the truth. Seventy five percenrof all adults have a
recycling program in their community; and 23 percent of those said that the recycling
program is mandatory. This means that about 17 percent of all adults say that they have a
mandatory recycling program. But, 59 percent strongly favor mandatory recycling. When
asked if there is anything that business or government can do to encourage people to
recycle; 63 percent said yes-"make it more convenient".
Most consumers correctly understand that curbside recycling increases the cost of trash
collection. However, consumers have some pretty weird notions about recycling. For
example, three out of four adults believe that once you recycle something, it can be recycled
forever. Most also believe that recycled products cost more and that, on average, recycled
products contain about 64 percent recycled contents; a far greater amount that's feasible for
many products.
Adults aren't the only ones focusing on recycling; we recently completed a landmark study
on 500 children and their actual parents on separate interviews. We also interviewed
teachers for a study called "The Power of Children". We learned that children of all ages
are significantly more concerned about the environment than their parents. This concern is
likely to continue even when they're faced with the everyday responsibilities of adult life-
Seven out of ten children say they've done something in the past 12 months to help
improve the environment. What did children do? Recycling tops the list. Children are also
an important influence on their parents. Four in ten children have asked their parents to
help the environment. What did they ask? Again, recycling tops the list. Children also
influence their parents when it comes to shopping. Half of all parents said that they either
avoided or purchased a product based upon environmental information that they learned
from their children. What did they avoid or buy? Twenty four percent purchase products
in recyclable containers or packages. Four percent avoided products in excessive
packaging. What are children learning about the environment in school? Almost one third
told us they learned about the need to recycle more; and this is confirmed by educators.
Nine out of ten educators told us that recycling is taught in their schools and also say that
recycling is the topic that their students like the best. Few, if any, children or teachers
mentioned source reduction.
So while I've been asked to talk about what consumers think about source reduction,
you've heard mostly about what consumers don't know about source reduction, and how
they focus on recycling. Companies and government both have their work cut out for them
when it comes to educating the consumers on the environment. To be effective we'll have
to go beyond vague messages such as "reduce, reuse and recycle". These words don't
explain what we want consumers to do to help out and they don't explain specific corporate
actions. Better educated and more concerned consumers will demand more precise
information. Corporate marketers who believe that educators are responsible for educating
and companies are responsible for selling will be left in the dust. The environmental
leaders of the future will be those companies and organizations who can cross traditional
lines and get involved in educational programs. This means not just giving money to a
group that gives money to another group to develop an environmental program. It means
getting involved in creating the messages; and some of our clients are already doing that.
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Finally, while recycling may be the most recognized environmental message today, we all
need to prepare for tomorrow by talking about and explaining issues other than recycling.
The question's not whether or not the environment's here to stay, but whether or not we're
all prepared to handle these issues. Vice President Elect, Al Gore, who wrote Earth In
The Balance, was warned during the campaign to soft pedal his activism for fear of
opening himself up for attack as an extremist by the Republicans. Regardless of what
happened in the election there will be another surge of attention toward the environment for
many of the reasons I mentioned; including the heightened awareness of children. Some
people will call this the "rebirth of the environmental movement", in reality this will simply
be a continuation of what has already begun.
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Scanning for Consumer Behavior
Presented by Adam Portner for Information Resources, Inc.
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Four Season Sorting
John Dceda and S usan Mitchell •
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I. Introduction •
In 1989, the Minnesota Legislature mandated a statewide analysis of solid waste composition as part of "
the Select Committee on Recycling and the Environment (SCORE) legislation. The statutory mandate
reads: , •
The minnesota pollution control agency, in cooperation with the office of waste management
and the metropolitan council, shall study and comprehensively analyze the composition of solid •
waste on a statewide and regional basis during each of the four seasons of the year. The study «
must include but not duplicate existing waste composition information previously gathered and
must provide information on recyclables and non-combustibles in die waste, generation of the •
waste, and other solid waste characteristics. The pollution control agency shall present its •
findings to the legislative commission on waste management by November 1. 1992.
(1989 Minnesota Laws, First Special Session, Chapter 1, Article 22, Section 3.) •
This report presents the results of the first comprehensive study conducted in Greater Minnesota.
Waste composition studies provide useful information essential for planning effective solid waste •
programs. It is crucial to know what is in the waste to successfully and efficiently reduce the amount I
of waste going into disposal facilities. The information in this report can be used by the legislature,
counties, and other units of government to direct policy. •
A number of waste composition studies have been conducted in the United States and for the federal
government. All of these studies provide information, but the data have only a limited application to •
Minnesota. Local conditions, economic base, and recycling and composting programs all have a |
noticeable effect on the composition of waste. The composition of municipal solid waste (MSW) in
Minnesota differs from the national average because of Minnesota's far-reaching recycling programs •
and integrated waste management approach. ' , '|
n. Methodology |
The Minnesota Pollution Control Agency (MPCA) conducted a four-season waste composition study in
Greater Minnesota (not including the seven counties of the metropolitan area) from July of 1990 to
May of 1991. The MPCA decided to conduct the study itself to save money and to retain greater
control of the methodology and data. A protocol was developed after reviewing the available
literature. An interagency committee defined the sorting categories. Study sites were chosen after
many interviews and several site visits. '
Five sites were selected to represent different economic activities, geographic regions, and community
sizes throughout the state. Prospective sites also had to 1) receive enough waste to be representative of
that region, 2) have an owner or operator willing to participate in the study, and 3) have a building in
which samples could be sorted. To avoid duplication of previous studies, sites were chosen that had
not participated in a study as detailed as this one. County-operated landfills in Winona, Itasca, and
Lyon Counties were chosen, as well as transfer stations in Becker County and the Tri-County area.
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An MPCA staff coordinator was responsible for conducting the study at each site and for hiring 10-14
sorters each season from each community. The sorters were encouraged to work all four seasons.
This saved money through reduced training costs. Also,' it was hoped that retaining the same crew
would lead to consistent data. It turned out that employees hired locally were able to provide insights
into the composition of various commercial, institutional, and rural loads. In turn, the employees
learned a great deal about local waste management.
The safety of the coordinators and sorters was paramount. The coordinators worked closely with the
MPCA^safety officer to develop safety procedures, site safety plans, and to determine what protective
gear was needed. Coordinators received special training in hazardous material handling, CPR, first
aid, and defensive driving. Safety was also a major part of the training the sorters received. ' "
The sorts were conducted each season for a one-week period, Monday through Friday, at each site.
The amount of garbage received on Saturday, if the facility was even open, was very small.
Absolutely every effort was made to randomize the selection of sample trucks. When a truck was
selected, the driver was briefly interviewed about the source and type of garbage being hauled
(residential, commercial,.or industrial).
The driver was then directed to dump the load in a specific area for sampling. A front-end loader or
skid-steer loader was used to shave a quarter section off the entire length of the load. The quarter
section was then mixed and a 200 to 400 pound sample was taken from it to the pre-sorting area. The
site coordinator (or trained county staff person) sorted through the sample, opening bags to remove any
waste that might endanger the sorters. Hazardous waste was documented separately by the site
coordinators and was properly packed-for disposal. Once pre-sorted, the sample was taken directly to
the sorting tables. There, four to six sorters at each table sorted the sample into labeled barrels, one
barrel for each category. After the entire sample was sorted, the barrels were weighed and the gross •
and tare weights recorded. The sample was then dumped'into the landfill or transfer trailer.
*
. The equipment needed to do this project was extensive. The equipment and protective gear were
transported by the coordinators from site to site in a large rental truck or agency-owned van.
A total.of twenty waste sorts were conducted. During those 100 days of sorting the MPCA
coordinators and sorters analyzed 884 samples. The total weight of the samples was -285,927 pounds
or approximately 143 tons. The average sample weighed 336 pounds.
The dates field work was conducted were: Summer-July 17 to August 31 1990, Fall-October 15 to
November 16, 1990, Winter-January 14 to February 15, 1991, and Spring-April 15 to May 17, 1991.
Temperatures at the sites ranged from approximately 95 degrees F. with a relative humidity of 80
percent to -20 degrees F. with a wind chill of -35 degrees F.
m. Results
Table 1 shows the overall percentage estimates of material in the waste stream during the one-year
study period at each site and" at all the sites combined. Table 2 is also included to show the overall
percentage estimates by season. All of the communities where the study was conducted had source-
separation recycling programs. Therefore, the following percentages reflect what is still being thrown
away. '-''..-
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Table I. Overall percentage estimates of material in MSW (by'weight) during the one-year study period at
each site and at all sites combined.
SORTING CATEGORIES
Newsprint
High Grade Paper
Corrugated/Kraft Paper
Magazines
Other Paper
Total percentage: Paper
High Density Polyethylene - HOPE
Plastic Film
Polyethylene Terephthalate - PET
Polystyrene
Other Plastic
Total percentage: Plastic
Aluminum Beverage Containers
Other Aluminum
Ferrous Food Cans •
Other Ferrous
Other Non-Ferrous
Total percentage: Metal
Glass Food/Beverage Containers
Other Glass
Total percentage: Glass
Small Yard Waste
Large Yard Waste
Total percentage: Yard Waste
Food Waste
Wood Waste
Tires
Adult and Infant Diapers
Textiles
Other Organic Waste
Major Appliances
Small Electric Appliances
Demolition/Construction Debris
Hazardous Waste
Oil Filters
Other Inorganic Waste
Winona
<*)
2.3
2.3
12.7
1.9
21.3
40.5
0.4
5.8
0.1
0.5
4.9
11.8
0.2
0.3
0.6
4,0
0.2
5.4
1.1
0.6
1.7
1.2
0.1
1.2
12.8
8.5
0.0
2.0
4.9
• 3.5
0.1
0.3
4.9
0.5
' 0.1
1.8
Itasca
4.8
3.1
7.4
3.1
- 21.6
40.0
0.9
4.4
0.3
1.1
2.2
8.9
0.5
0.4
1.9
2.4
0.4
5.7
4.2
0.7
4.9
2.5
0.2
2.7
17.3
1.6
0.0
3.1
2.5
5.6
0.0
0.7
1.1
1.0
0.2
4.9
SITES
Lyon
4.4
3.3
11.4
2.8
20.5
42.4
0.6
6.4
0.4
0.8
2.5
10.7
0.6.
0.2
1.2
1.5
0.3
3.8
2.4
0.6
3.0
3.2
0.0
3.2
15.9
5.1
0.1
2.5
2.0
4.6
0.0
0.7
1.1
0.7
0.4
3.9
Tri-Co
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4.4'
5.2
8.1
2.8
20.0
40.5
0.7
4.6
0.4
l.l
2.8
9.5
0.5
0.3
1.3
2.3
0.2
4.8
2.4
0.8
3.2
4.1
0.3
,4.4
11.7
6.7
0.0
2.6
3.7
2.5
0.1
0.3
4.7
0.9
0.2
4.2
Becker
4.1
2.3
9.2
2.2
15.3
33.1
0.9
4.6
0.5
0.9
1.9
8.8
0.6
0.3
1.6
2.3
0.5
5.3
3.5
0.7
4.2
6.1
0.2
6.2
25.2
2.8
0.0
3.3
2.3
2.5
0.0
0.3
. 1.7
0.6
0.4
3.1
TOTAL
4.0
3.8
9.5
2.6
20.0
39.8
0.7
5.0
0.3
0.9
3.1
10.0
0.5
0.3
1.3
2.6
0.3
5.0
2.4
0.7
3.1
3.4
0.2
3.6
14.5
5.9
0.0
2.6
3.5
3.3
0.1
0.4
3.7
0.8
0.2
3.6
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Table 2. Overall percentage estimates of material in MSW (by weight) from all sites during each season
and for all four seasons combined.
SEASONS
SORTING CATEGORIES
Newsprint
High Grade Paper
Corrugated/Kraft Paper
Magazines
Other Paper
Total percentage: Paper
High Density Polyethylene - HOPE
Plastic Film
Polyethylene Terephthalate - PET
Polystyrene
Other Plastic
Total percentage: Plastic
Aluminum Beverage Containers
Other Aluminum
Ferrous Food Cans
Other Ferrous
Other Non-Ferrous
Total percentage: Metal
Glass Food/Beverage Containers
Other Glass
Total. percentage: Glass
Small Yard Waste
Large Yard Waste
Total percentage: Yard Waste
Food Waste
Wood Waste
Tires
Adult and Infant Diapers
Textiles
Other Organic Waste
Major Appliances
Small Electric Appliances
Demolition/Construction Debris
Hazardous Waste
Oil Filters.
Other Inorganic Waste
Summer
(%)
4.0
2.9
9.5
2.1
17.5
36.1
0.6
4.2
0.2
0.9
2.8
8.7
0.5
0.4
1.0
2.7
0.2
4.8
2.5
0.7
3.2
4.9
0.3
5.2
14.8
7.3
0.0
2.4
4.5
3.8
0.0
0.2
4.6
0.8
0.0
3.5
Fall
(»)
3.8
4.3
.9.7
2.7
20.3
40.7
0.6
5.2
0.3
0.9
3.0
10.0
0.4
0.3
1.2
3.3
0.4
5.6
' 2.1
0.6
2.7
3.6
0.0
3.7
14.3
5.5
0.0
2.5
2.8
2.6
0.1
0.5
4.3
0.8
0.3
3.4
Winter
(%)
3.5
3.7
9.7
2.9
22.2
42.1
0.8
5.6
0.4
. 1-1
3.4
11.3
0,5
0.3
1.7
2.0
0.2
4.7
2.4
1.1
3.5
0.4
0.1
0.5
15.5
5.4
0.0
3.2
2.6
2.8
0.2
0.5
2.8
0.7
0.2
4.0
Spring
(%)
4.4
4.5
9.0
2.5
20.6
41.1
0.7
5.3
0.4
0.8
3.1
10.3
0.5
0.3
1.2
2.4
0.3
4.8
2.6
0.6
3.2
4.1
0.2
4.3
13.5
5.3
0.0
2.4
3.7
3.6
0.0
0.5
2.7
0.9
0.3
3.5
TOTAL
(%)
4.0
3.8
9.5
2.6
20.0
39.8
0.7
5.0
0.3
0.9
' 3.1
10.0
0.5
0.3
1.3
2.6
0.3
5.0
2.4
0.7
3.1
3.4
0.2
3.6
14.5
5.9
0.0
2.6
3.5
3.3
0.1
0.4
3.7
O.S
0.2
3.6
449
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All together, the paper categories represented the largest portion of the waste stream. The largest
paper was Other Paper, the catch-all category for all paper that did not fit into one of four more
specific categories. Other Paper was composed of a heterogeneous mix of papers, only some of which
could be recycled today. Composting may be another alternative.
Food Waste accounted for an overall percentage of 14.5. This category includes dead animals and the
remains from hunting seasons, as well as uneaten food and food scraps. The Food Waste percentages
across sites varied substantially because of food processing plants located in two of the study areas.
The ranges shown in Figure 1 illustrate the highest percentage and lowest percentage found in the
general categories at all five sites. The arrows point to the overall average..
fig. 1. Aggregated Waste ConjxKtkn Ebta: ADStes
(Illustrates Range and Average)
ex
to
O.
•o
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O
IS
•a
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Yard Waste was another category of interest. At the time the study was conducted, yard waste was not
yet banned from Greater Minnesota disposal facilities. Even so, Winona became the first- county in
Minnesota to ban yard waste in November of 1987. The cities in Itasca County started their own yard
waste composting programs about the same time the waste composition study started in July 1990.
These composting efforts had a clear effect on the amounts of yard waste received. See Table 3 for
start-up dates of county programs.
:TabIe 3. Summary of start-up dates of county programs.
^*-
Curbside Recycling
Yard Waste Composting
HHW Collection
Winona
1985
1987
1985
Itasca
NA
1989
1991
Lyon
1990
1990
1988
Tri-Co
1989
1989
1990 ..
Becker
NA
1990
1989
Of all the categories, Yard Waste was the one category whose percentages showed a statistically
significant difference from season to season (see Figure 2). The distinct seasons in Minnesota would
account for these findings. Other than Yard Waste, it does not appear that there is a significant
difference in the 'composition of MSW from season to season. There is a difference in the amount of-
garbage received season to season at the facilities that were part of this study (see Figure 8).
Statistically significant differences in the percentages of some of the categories vary from site to site.
These site-to-site differences probably reflect differences in economic base and recycling programs.
Eg. 2. Paxttit of Yard Waste by season at each site.
12 T
10-
2 -
Wincna
Itasca
Lyon
TH-Co
^ Stunner <
k FaO
§ Winter j
*r ^ring
Hazardous waste was one of the categories used in this waste composition study. It should be noted
that the term "household hazardous waste" refers to the unused portion of products found in most
kitchens and garages that is eventually disposed of. This category includes such things as paint, home
451
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and garden pesticides, aerosols, and charcoal starter. Hazardous waste was culled from the samples *
before the sort crew had access to them. Because the MPCA became a hazardous waste generator by
separating hazardous materials from MSW, it was necessary to properly separate, package, document, •
and transport the material to hazardous waste collection centers. Because this level of documentation ™
was required, the MPCA maintained an extensive and detailed list of the items categorized as
hazardous waste during this study. •
Hazardous waste is grouped into the following categories: Aerosols, Acids, Bases,
Flammables/Solvents, Chlorinated Products/Other Pesticides, Flammable Solids, Oxidizers, Organic I
Peroxides, and Paints. Some of the hazardous waste categories deserve further explanation. For ' •
example, all aerosols were removed during pre-sorting and classified as hazardous waste whether they
contained toxic liquids, a food product, or were empty. The rationale for this is that the aerosol •
package itself presents a hazard because it is pressurized. An unpunctured aerosol is also never truly p
empty because it contains butane, propane, or other propellants. Residual product frequently remains
in the can, also. A great deal of information about this type of container is available to the recycling A
industry because of separate documentation during the study. -8
Paints were recorded because they can be hazardous wastes. Empty paint containers were also A
separated and documented in order to compare discarded paints with the number of completely used . |
and/or properly disposed of paint products. (Paints in aerosol cans are recorded in aerosols, not
paints.) ' f'
All types of batteries were considered hazardous waste in this study because of mercury, cadmium, and
other hazardous materials contained in many of them. By calling these materials hazardous for. the m*
purpose of this study, they could be recorded in detail. Lead acid batteries are banned from land- •
disposal so the study was interested in discovering the effectiveness of the ban. See Table 4 for the
number and types of batteries found in the samples. mm
Oil filters were composite materials and it was difficult to determine the representative weights of the
components, especially since there were a wide range of sizes of filters. After the summer sort, they «
were recorded separately. Removing filters during pre-sorting helped to keep drain oil off of the other I
waste in the samples and the sorting equipment. In sorting 143 tons of waste, 497 oil filters were
documented. _
|>
While the information in the hazardous waste summaries is primarily non-quantitative, tallying the
number of items in each category as representations of disposal decisions made by individuals can give ^
some hints about program effects on waste streams. (See Tables 4 to 6.) Because of the difference in •
the number of samples taken at each site, the total tonnage sorted at the sites, the relatively few
number of hazardous items, and other factors, no comparisons may be safely made statistically. But,
this type of analysis can be instructive for program planning and evaluation if the information is
studied in context. The itemized lists, the study definitions, and information about programs affecting
the wasteshed should be examined together to get a picture of hazardous waste in municipal solid waste
in Minnesota.
In the commercial/industrial sector, six materials are consistently found in the five heaviest categories
at each site. (See Figure 3.) Three of these categories-Wood Waste, Plastic Film, and
Corrugated/Kraft Paper-represent materials commonly used as packaging and shipping materials.
Large quantities of other recyclable materials were also seen in the commercial/industrial waste stream."
Results of other waste composition studies conducted in Minnesota and other states are also provided
for comparison. Not surprisingly, results from other Minnesota studies were most similar to the
results of the MPCA study. Compared to a national study conducted for the U.S. Environmental
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Table 4. Number and type of batteries removed from sorted samples.
Battery Type
Winona
SITES
Itasca
Lyon
Tri-Co
Becker
TOTAL
Alkaline/Carbon-Zinc :
AAA
AA
» C
» D
9v
Unidentified
Other Alkaline/Carbon-Zinc
Nickel-Cadmium
Button
Large Mercury
Lead-Acid
Other
TOTAL
No. of samples
Tons sorted
7
158
51
45
35
0
1
3
5
0
0
3
308
205
34.6
22
170
98
111
33
0
7
4
5
2
1
2
455
152
30.3
3
134
49
59
22
0
6
2
1
1
2
5
284
142
22.0
7
137
52
82
7
96
6
1
2
0
4
1
395
% 194
34.5
8
156
50
56
30
0
11
0
3
0
1
11
326
158
21.6
47
755
300
353
127
96
31
10
16
3
8
22
1768
851
143.0
Table 5. Number of containers of hazardous waste removed from sorted samples.
"Category
Aerosols
Flamraables/Solvents
Flammable Solids
Paints
Chlorinated Products/ Other
Pesticides
Acids
Bases
Organic Peroxides
Oxidizers
Other
TOTAL
No. of samples •
Tons sorted
Winona
85
27
0
20
7
0
2
0
0
14
155
205
34.6
SITES
Itasca
111
45
0
42
12
9
2
1
2
11
235
152
30.3
Lyon
67
38
0
19
3
0
0
1
1
4
133
142
22.0
Tri-Co
40
32
0
11
4
0
2
Q
0
6
95
194
34.5
Becker
86
33
0
46
7
3
7
0
2
14
198
158
21.6
TOTAL
389
175
0
138
33
12
13
2
5
49
816
851
143.0
453
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Table 6. Number of empty hazardous material containers that were removed from sorted samples.
SITES
Category Winona
Aerosols • 273
Flammables/Solvents 69
Flammable Solids 0
Paints 25
Chlorinated Products/ Other 12
Pesticides
Acids 0
Bases 2
Organic Peroxides 0
Oxidizers 0
Other 2
TOTAL • 383
No. of samples sorted 205
Tons sorted 34.6
Itasca Lyon Tri-Co Becker TOTAL
417 263 448 307 1708
75 38 102 53 337
0 • 0 0 0 0
42 72 98 42 279
5 7 4 0 28
7 17 3 3 30
6 2 7 3 20
1 0 0-0 1
00000
23 1 11 3 40
576 400 673 411 2443
152 142 194 158 851
30.3 22.0 34.5 21.6 143.0
90 -
; Rg. 3. Top five categories by \\eght in
.80-1 ~
, ijoi
-ri i
70 y
. w ' I^H i
' ' '"i?is^i?^S?S ^TS
'iSiSjjjI&i
i i ~'
i
i I
nueroal/Industrial loads at each site.
• High Grade Paper
^^m '' '' • -' D WoodWaste
i- JSS ^^^^^^1
•L-tV- '."" '•''•»' D Food Waste
-T^^-1 — !:'t"*'r"7*v' •. •'* p|
.,.->''• :?'.i ":; ^ '''-''"U7C HOtterPaper
•i-: - •-.••''' '!:'"-."-. !... .;=*....- • -.,...,. •• '.-•;;&.•_
1
1
1
I
1
I
1
1-
1
1
1
1
Winona Itasca Lyon Tri-Co Becker
Protection Agency (USEPA) and studies done in other parts of the nation, the MPCA results show
significantly less yard waste, less glass, and more plastic (except plastic is at a similar level in the
USEPA study). When comparing results, remember that if certain fractions of the waste stream are
reduced or eliminated, the other categories must increase in proportion to add up to 100 percent.
When comparing the 1990 projected per capita generation figures from the USEPA study with the
MPCA study per capita generation figures, it appears that Minnesotans dispose of an average of 20
percent less MSW than the national average at landfills and transfer stations.
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Fig. 4. Daily disposal rale in pouocfe per capta:
USEPAstudy w. MPCA study
I i\ational Q \fmsota
IVfetd T«2« Food Wnd Ota-
Papa- Plastic YaniWaste
A large portion of the full report details how the study was conducted. This information is included
for two reasons. First, enough information is provided that a company or unit of government could
use this document to perform a waste composition study. Second, should an entity elect to contract
with a consultant for a waste composition study, the information in the report should simplify *
developing a request for proposals and should make it easier to judge the quality of work."
VI. Conclusions/Recommendations
The following conclusions and recommendations are based on the study data and observations made by
MPCA staff.
A. Residential recycling
Residential recycling programs are removing quantities of materials from the waste stream. Newsprint
has diminished in quantity in household garbage cans, as have aluminum and ferrous cans and glass
containers. Residential samples at sites with aggressive recycling'programs would produce a handful
of cans, a couple of bottles and jars,, a few newspapers, and a couple plastic jugs and bottles. At sites
with newly-implemented recycling programs, sorting one sample could rapidly fill a 16-gallon barrel
with aluminum cans and a 30-gallon barrel could be packed with newspapers. The difference between
sites was pronounced to the coordinators. Figure 5 indicates differences in commonly recycled
material between sites. . •
The differences are also apparent in Table 7, which presents the data on per capita waste generation.
Winona County began a pilot recycling program in 1985. The figures for common household
recyclables (aluminum cans, newsprint, ferrous food cans, glass food and beverage containers, HDPE,
and PET) in Winona County are lower than any of the other four sites. Curbside collection of
recyclables started in the other four communities around 1989. It appears that the longer programs are
in place, the more successful they become. Therefore, continued state and county funding for
positions, waste programs, waste education, joint projects, and market development is recommended.
A great deal of resources are needed to implement a recycling program, but as the program matures
and recycling becomes a part of people's daily routines, the investment of time and resources seems to
pay off.
455
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Fig. VI-1. Percent of recyclables in the waste stream.
Numbers shown ahove bars are the tola! percentages of recyclables listed.
\Vimina
Hiisca
Lvon
Tri-Co
Becker
L; Corrugatcd/Knifl Paper LJ Newsprint
!___! High Grade Paper
liti Ferrous Food Cans
i Aluminum Beverage
Contniners
HOPE
1 Glass Food/Beverage
Containers
! PET
Fig. VI-3. Overall percentages of general categories.
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Other 10.2%
Glass 3.1%
Textiles 3.5%
Yard Waste 3.6%
Metals 5.0%
Demo/Wood Waste 9.6%
Paper 39.
Plastics 10.0%
0.8 %
Hazardous Waste
including empty containers
Food 14.5%
456
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Table 7. Estimated annual weight (pounds) of material discarded per capita within the five
wastesheds.
SITES
SORTING CATEGORIES
Newsprint
High Grade Paper
Corrugated/Kraft Paper
Magazines
Other Paper
Total pounds/person: Paper
High Density Polyethylene - HOPE
Plastic Film
Polyethylene Terephthalate - PET
Polystyrene
Other Plastic
Total pounds/person: Plastic
Aluminum Beverage Containers
Other Aluminum
Ferrous Food Cans
Other Ferrous
Other Non-Ferrous
Total pounds/person: Metal
Glass Food/Beverage Containers
Other Glass
Total pounds/person: Glass
Small Yard Waste
Large Yard Waste
Total pounds/person: Yard Waste
Food Waste
Wood Waste
Tires
Adult and Infant Diapers
Textiles
Other Organic Waste
Major Appliances
Small Electric Appliances
Demolition/Construction Debris
Hazardous Waste
Oil Filters
Other. Inorganic Waste
TOTAL POUNDS/PERSON/YR
Winona
Ibs/capita
28.0
28.5
156.0
23.4
260.8
496.7
5.3
71.2
1.3
6.3
60.0
144.0
2.9
3.6
7.4
49.3
2.8
66.1
13.2
.7.9 ,
21.1
14.5
0.7
15.2
157.0
,104.7
0.1
24.0
60.7
42.8
1.1
4.1
59.5
6.4
1.0
21.5
1225.9
Itasca
Ibs/capita
32.2
22.5
49.4
21.5
148.9
274.5
6.0
30.0
1.9
7.5
15.1 .
60.5
3.6
• 2.9
13.3
16.4
2.4 _.
38.6
28.2
4.8
33.0
17.7
1.1
18.8
119.6 '
11.3
0.1
' 20.8
17.2
36.1
0.0 .
4.7
7.6
6.2
1.4
33.3 .
683.8
Lyon
Ibs/capita .
. 51.0.
38.4
132.6
32.3
237.3
491.6
7.5
74.3
'4.4
9.4
28.5
124.0
6.5
. 2.2
13.9
17.2
3.6
43.4
27.7
6.4
34.1
37.0
0.2
; 37.2
184.8
59.5
0.5 •
28.6
22.7
53.1
0.0 '
7.9
13.3
8.6
4.2
45.6
1159.1
Tri-Co
Ibs/capita
41.6
48.4
75.9
26.0
188.1
380.0
6.3
43.4
3.5
10.3
26.2
89.6
5.0
3.0
12.5
21.9
2.3
44.7
22.7
7.5
30.2
38.6
2.4
, 41.0
109.6
62.8
0.3
24.8
34.3
23.4
0.9
3.2
44.2
8.7
2.0
39.3
939.0
Becker
Ibs/capita
35.2
21.6
72.5
19.6
132.9
281.7
8.2
41.3
4.7
7.0
16.7
77.9
5.3
2.7
14.6
14.5
4.4
41.5
30.8
6.1
36.9
51.2
1-1
52.3
. .219.9
22.0
0.0
30.5
20.3
21.7
0.5
2.7
16.1
5.7
3.8
27.5
860.9
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B. Commercial/Industrial sector recycling and reduction
Consumers do not often think about the amount of waste created in the production and shipping of
consumer goods. Off-specification products, wooden pallets, shrink wrap, and corrugated cardboard
are all out of sight by the time products are on the store shelves. Because this segment of the waste
stream is not obvious to most people, it has not received as much attention from recycling programs.
In the data a decrease in recyclables in the residential waste stream can be hidden by large quantities of
recyclables disposed of by the commercial sector. Although a great deal of effort has concentrated on
residential recycling programs, the need to focus on commercial recycling programs is indicated by the
large quantities of film, high grade paper, and corrugated cardboard still found in the waste stream.
(Refer to Figure 3) Large volumes of material could potentially be removed from the waste stream by
focusing attention on commercial recycling. Items such as corrugated cardboard, film, and office
paper are the obvious examples and perhaps the easiest to divert from the waste stream. However, this
should not preclude recycling opportunities for other materials that are specific to each business.
Besides encouraging increased recycling in commercial establishments, another option would be the
design and use of reusable shipping containers. Many of die corrugated boxes, shrink wrap, and
wooden pallets could be eliminated by reusable containers that could be shipped back to the supplier.
Reusable shipping containers would ultimately be less expensive even when considering additional
shipping. Figure 3 illustrates the top five categories by weight in commercial/industrial loads at each
site. Corrugated, Plastic Film, and Wood Waste are in the top five at almost every site.
Waste audits could help industries and businesses to uncover disposal patterns and waste reduction
opportunities. For example, a knitting mill in Winona County disposed of fairly uniform truckloads of
yarn and other textiles on a regular basis. Textiles at the Winona County site were almost 5 percent of
the waste stream, the highest Textile percentage of any site. A waste audit could show the knitting
mill the quantity of its waste that could be recycled.
C. Opportunities for reuse
Textiles, mainly clothing, are a small percentage of the materials in the waste stream, but very few of
the items needed to be there at all. Clothes in good condition, large pieces of fabric, fabric scraps, and
yarn:are all found in the Textiles category. Although Textiles account for an average of 3.5 percent of
the waste stream by weight (see Figure 6), textile reuse and recycling deserves more attention. Textile
recycling has been in existence since the early part of the century, but has been underutilized by
recycling programs. A combination of textile reuse and recycling could be accomplished with a single
pick-up. Reusable items could be diverted to second hand operations. Items which could not be
reused could be recycled.
Hidden within the categories are other items which still have useful life. Children's toys and games,
tools, kitchen utensils and tableware, office supplies, bedding, rugs, clocks, cameras, books, and
hobby supplies are just some of the useful things found during the sorts. In urban areas groups such as
Goodwill, The Salvation Army, The Association of Retarded Citizens, and Disabled American
Veterans are usually willing to pick up these items for reuse. The public needs to be encouraged to
use these already-existing outlets for reusable items rather than using the trash can.
Coordinators and sorters were also disgusted to witness the misuse of solid waste facilities by large
stores and mail order businesses who performed inventory control by dumping truckloads of perfectly
good items such as dishes, bedspreads, shoes and clothing. This practice epitomizes wastefulness.
Businesses justify this behavior by saying that items they might donate to charity could easily be
returned to their stores for cash. Although this is a legitimate concern, a system of marking donated
items to prevent their return for cash could be developed. The advantages to businesses of donating
excess inventory include lower disposal costs, community goodwill, and tax benefits. The current
situation wastes resources and facility capacity.
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D. Food Waste
Food Waste accounted for an average of 14.5 percent of the garbage by weight. This study's Food
Waste category would be more accurately titled "putrescibles" because it also includes road kills and
other deceased animals. Deer hunting season impacts this category with the weight of carcasses,
heads, and heavy hides. However, the largest quantities of food came from commercial establishments
(grocery stores, restaurants, schools, and nursing homes). Establishments that produce large quantities
of food waste could be targeted for programs where food scraps are turned into animal feed. Some
industries, such as food processing plants, may have wastes that lend themselves to a food composting
program:
e.
E. Plastic Film
One of the biggest surprises was the large amount of plastic film in the waste stream. Plastic Film
accounted for 50 percent of all plastics. (See Figure 7 below.) This is remarkable because the
categories are measured by weight and film has a very low density. A large portion of this category is
fully intended to be waste. Large, heavy-duty garbage bags, medium kitchen trash can liners, and
small office or bathroom trash can liners are quite prevalent in virtually every load. Offices, hotels,
hospitals, and nursing homes go through a large number of small bags because it appears that each
room has a small lined trash can which is emptied daily. The coordinators saw hundreds of plastic .
bags that contained one or two pieces of paper or a single tissue. Some trash cans could certainly be
emptied while leaving the liner in place.
,*
At four, sites, Plastic Film was one of the top five heaviest categories overall in the
commercial/industrial sector (see Figure 3). Large pieces of plastic film are discarded by the
commercial sector. It is evident that shrink wrapping units of merchandise is an effective method of
packaging for transport. Large, thick, empty plastic bags were also seen in many commercial loads, as
well as other forms of plastic film. Opportunities for recycling plastic film are limited at this time, but
should be encouraged and expanded. Perhaps as plastic film recycling becomes more sophisticated,
film shipping material could be closed-loop recycled. Polystyrene, HOPE, and PET comprise
9 percent, 7 percent, and 3 percent of the plastics sorted, respectively. Much attention has been paid
to the recycling of these plastics. However, since Plastic Film accounts for 50 percent of the plastics
sorted, films could be a prime recycling candidate.
Fig. 7. Composition of the Plastics category.
HOPE 7%
Other Plastic
- 31% •
Polystyrene 9%
Plastic Film 50%
PET 3%
459
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F. Paper
Of all the sorting categories the largest was Other Paper, averaging 20 percent by weight. The study
identified categories for recyclable newsprint, corrugated cardboard and kraft paper, high grade1 paper,
and magazines. Everything else composed of paper fibers went into Other Paper. Other Paper
contains papers that are recyclable such as mixed paper. However, observationally a large fraction of
the category is contaminated or of low grade. Much of the category is paperboard, waxed corrugated
cardboard, used tissues, paper towels, and napkins, and newspaper used for other purposes than
reading.
Overall, the paper categories represent nearly 40 percent of the waste stream. A lot of recyclable
paper fiber is still missing the opportunity to be recycled. Continued efforts in waste reduction,
recycling, and composting are needed to reduce the percentage.
G. Hazardous Waste
Although the category Hazardous Waste constituted less than one percent of the waste stream by
weight, attention must be paid to these materials because of their ability to harm human and
environmental health in small quantities. .
To reduce paint in the MSW waste stream, community paint exchanges appear to work and to relieve
some of the cost of packing and shipping hazardous material. Paint is brought into the hazardous
waste facility by citizens, checked by an employee of the facility, and, if'the paint is acceptable, is put
out for others to take. In communities with paint exchanges, large quantities of paint are given away
rather than disposed of. In 1990, Winona County exchanged 534 gallons of paint or 52 percent of the
. paint received. In 1991, 630 gallons were exchanged, which represented almost 70 percent of the paint
it received. Nobles County, located in the southwest corner of Minnesota (not a study'site), conducted
a one-day paint exchange in 1992. The Nobles County hazardous waste coordinator estimated that
1,200 cans of paint were exchanged that day. The remaining 700 various-sized cans of paint that were
not exchanged that day were sent to the local rummage store where now only a few remain. With this
high success rate, paint exchanges should be encouraged in all counties.
This exchange concept could also be expanded to include other hazardous wastes. For example, not
only did the Tri-County Solid Waste Management Commission exchange 3,405 gallons of paint
between January 1991 and August 1992, but it also exchanged other household hazardous products in
its program. They were able to exchange 1,545 aerosols and 520 gallons of miscellaneous solvents
including paint thinner, charcoal lighter fluid, stain, gas, brake fluid, and other oils. Also exchanged
were 2,693 pounds of acids, bases, pesticides, adhesives, and other materials that would normally have
to be specially packed and shipped out-of-state for disposal. The Tri-County Commission estimates
that 55 to 60 percent of the hazardous material received at its facility is exchanged.
Table 6 shows that aerosol cans are abundant in the waste stream. Technology exists to recycle
aerosol cans, but the main barrier to residential collection is the safety of'handling during collection
and processing. In order to effectively recycle aerosols through a curbside program, the safety issues
must be addressed.
There are non-hazardous alternatives to many of the hazardous products that were pulled out of the
samples by coordinators. To further reduce hazardous materials in the waste stream, these alternatives
should be used. Through more public education and state purchasing policies, use of these alternatives
could be encouraged.
H. Seasonal variability
Many previous studies based annual waste composition estimates on one week of field work, raising
the question of whether one week of sorting accurately represents the waste stream throughout the
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entire year. Four seasons of sorting were-conducted for this study because it was expected that the
waste stream would vary between spring, summer, fall, and winter. According to the data (Table 2),
this is not the case. Yard waste, which does vary by season in Minnesota, is the only exception.
Overall composition does not seem to change from season to season. Knowing this now, in the future
it seems that-time and resources would be better spent on improving the precision and accuracy of the
data. However, the volume of trash does vary seasonally. Minnesotans throw away more trash in the
summer and less in the winter. (See Figure 8.)
Fig. 8. Amount of gartage received at eadi ate during each season.
1400
o
E—
400
200--
Winoua
Itasca
Lyon
Becker
Simmer • Fall
Winter
Spring
I. Waste composition study as an audit
Composition studies not only provide a picture of a community's waste, but also pictures of the
composition of waste from area businesses and institutions. For example, some entities announced
their lack of solid waste reduction and recycling efforts by what was found in their loads. When these
establishments are identified, special efforts in education and assistance can be targeted to help them
reduce and recycle their waste. A similar example is the load from one site brought in by a city -
collection vehicle that had made the rounds of all the city parks and public landings. The load was
primarily composed of pop and beer cans, bottles, and disposable picnicware. With knowledge of this
load, the community can implement a plan to divert these materials for recycling by such means as
side-by-side recycling and garbage cans in the parks.
i.
A good example of targeting the commercial wastestream is the action taken by the county solid waste
officer and the County Board of Commissioners in Winona County. After receiving preliminary data
on the percentages of material in commercial loads, the county banned corrugated cardboard and high
grade office paper originating from commercial sources from being disposed of at the landfill. Thus,
commercial establishments had to recycle the cardboard and office paper they generated.
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J. Additional study
The MPCA" recommends that the waste composition study started in 1990 be an ongoing project with at'
least one site studied per year. Additional studies would provide information on the progress and
effectiveness of solid waste programs in communities where a baseline now exists. Further data could
be added to the statewide picture of solid waste by studying different communities as well. More
detailed information on broad categories, data on packaging, and analysis of the effect of new materials
added to recycling programs would be provided by an ongoing study. It may be possible to identify
and track trends in the solid waste stream with further study as well.
K. Safety .
Safety was a primary consideration during the course of the study, and while the safety of the landfill
and transfer station employees was not directly a concern of MPCA staff, several hazards were
observed. 1) At all of the facilities where the study was conducted workers were exposed to airborne
and windblown substances from the waste deposited at the sites: dusts, dirt, wood particles, powdery
dyes, toner, resins, and other unidentifiable materials. The operators were using no personal
respiratory protection. 2) One operator routinely found sharps (hypodermic needles) in the pan of his
compactor during maintenance. He had no training in how to handle sharps, only a warning to be
careful. 3) A couple of sites had inadequate washing facilities. Even those facilities with soap and hot
and cold running water were not well used by landfill personnel. 4) Noise level was a concern at
several sites, particularly for the people operating the large equipment or working near the machinery.
Either protective equipment was not readily available or it seemed to be the responsibility of the
employees to decide if they wanted to wear it. While safety regarding heavy equipment operations and
traffic was clearly important to the employees, the work atmosphere still conveyed a feeling of
casualness about potential hazards and the chronic effects of exposure to MSW. This was disturbing to
study personnel. More extensive job hazard analysis should be conducted at disposal facilities. If it
warrants, more safety and health programs should be established to protect these workers through their
employers and the MPCA.
L. Finally
This study employed approximately 100 Minnesota residents across the state to perform the hand
sorting of MSW. Minnesota gained 100 knowledgeable solid waste activists. A week of hand sorting
mixed municipal solid waste is an education like none other. Everyone should have the opportunity to
sort garbage for a day.
REFERENCES
American Society for Testing and Measurement. 1988. "Standard Guide for General Planning of Waste
Sampling." ASTM D 4687-87. 1988 Annual Book of ASTM Standards. Vol. 11.04. p. 124.
Bordsen, Dave. Cal Recovery Systems, Inc. Interview, June 25, 1990.
Brunner, Paul and Walter Ernst. 1986. "Alternative Methods for the Analysis of Municipal Solid Waste." ^
Waste Management and Research. Vol. 4. p. 147-160. I
Cincinnati, Ohio. March 7, 1986. Selected Waste Composition Data for Cincinnati Ohio. By SCS Engineers^
Dakota County, Minnesota. February 1991. Dakota County Solid Waste Generation and Characterization '
Study: Final Report. By Franklin and Associates, Ltd.
Delaware. Delaware Solid Waste Authority. July 1986. An Update - New Castle County Solid Waste *
Composition Project Technical Report.
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Department of Environmental Resources for the Commonwealth of Pennsylvania. 1989. Estimating
• Composition and Quantities of Solid Waste Generation. By Gershman, Brickner, and Bratton, Inc.
Hennepin County, Minnesota. January 1991. Hennepin Energy Resource Company Waste Composition
• Report. By Braun Environmental.
Hollander, Herbert, et. al. Comprehensive Municipal Refuse Characterization Program, p. 221-237.
I' -' '
Klee, Albert and Dennis Carruth. August 1970. "Sample Weights in Solid Waste Composition Studies."
Journal of the Sanitary Engineering Division. Proceedings of the American Society of Civil Engineers. Vol.
96, (SA4).p. 945-953. "
I
Massachusetts Department of Environmental Management. October 1985. Waste Composition Studies
_ Literature Review and Protocol. By Frederick W. McCamic. Pub. #14621-88-50- 10-86-C.R.
Minnesota Pollution Control Agency. June 1991. Household Battery Recycling and Disposal Study. By
— Karen Arnold.
. 1986. Technical Evaluation of Municipal Solid Waste Incineration and Compilation of Solid Waste
_ Characterization Data. By Cal Recovery Systems, Inc.
* Missouri. Environmental Improvement and Energy Resource Authority. December 1987. Statewide Resource
Recovery Feasiblitv and Planning Study. Vol. II:'Waste Characterization Report.
™ Olmsted County, Minnesota. Olmsted County Public Works. 1989. Waste Characterization Study: Winter
Son. February 27 - March 3. 1989. By Joe Behlen.
™ Ramsey County and Washington County, Minnesota. .December 1988. Waste Generation and Composition
Study Vol. 2: Waste Composition. By Cal Recovery Systems, Inc.
™ Ramsey County, Washington County and Northern States Power Company, Minnesota. February 1988.
^Intermediate Processing System Demonstration Project. By Resource Conservation Consultants.
I
^ Rhode Island Management Corporation. October 1990. Rhode Island Solid Waste Composition Studv: Final
Report.
'" Savage, G.M., L.F. Diaz, and C.B. Golueke. 1985. "Solid Waste Characterization," Biocycle. Nov/Dec.
P-35-37. .
I
Swift County, Minnesota. July 1989. Swift County Solid Waste Composition Study. By Cal Recovery
Systems, Inc. '
U.S. Bureau of the Census. 1990 Census. Cendata Summary Tape File 1 (STF1). Washington, D.C.
I U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response. October 30, 1990.
Regulatory Determination on Used Oil Filters. Memorandum.
. March 1988. Characterization of Municial Solid Waste in the United States. 1960-2000 (Update
1988X EPA/530-SW-88-033. Washington, D.C.
Winnebago County, Wisconsin. October 1991.
Wisconsin. By Gershman, Brickner and Bratton, Inc.
I Winnebago County, Wisconsin. October 1991. Waste Characterization Study for Winnebago County.
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MEASURING SUCCESS OF HHW COLLECTION, EDUCATION AND SOURCE
REDUCTION PROGRAMS
Isao Kobashi •
Program Manager, Office of Toxics and Solid Waste
Santa Clara County, California
The title of my presentation today is "Measuring Success of HHW
Collection, Education and Source Reduction Programs. I included the
collection and education aspects of a HHW program because they
form the foundation upon which a successful source reduction
program can be mounted. Before we get into a discussion on
measuring the success of source reduction programs, let's look at a
typical HHW program.
Most Household Hazardous Waste Collection Programs have the
following pattern of growth. Early efforts focus on the collection
aspects of the program and outreach and educational efforts are
geared to inform the public of the new services. Participation or
attendance at these events are the primary objective. As the
program matures, more emphasis is placed on informing the public
about why it is important to properly dispose of HHW. There is also
a growing awareness that collection events are costly and,
consequently, reuse, recycling and other diversion efforts are
instituted. Source reduction activities are also investigated as a
long term alternative for reducing costs and protecting the
environment.
During the early stages of most HHW programs, efforts at measuring
program success receive little or no attention. This is unfortunate
because the long term success of the HHW program can be
substantially enhanced if certain steps are taken early in the
program to measure the success of each initiative. Figure 1 lists
typical outreach tools utilized by HHW programs.
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FIGURE I
TYPICAL OUTREACH TOOLS UTILIZED BY HHW PROGRAMS
FLYERS, POSTERS BILLBOARDS
ARTICLES SPEAKERS BUREAU
POINT OF PURCHASE INFO DOOR HANGERS
SHOPPERS GUIDE HOME SHOWS
MOVERS PACKAGE BILL INSERTS
TV,RADIO,PSA'S HOTLINE
For many programs the choice of tools, the audience to target, and
the specific message to be conveyed is more of an afterthought
rather than an integral part of an overall management strategy.
Measuring behavioral responses to evaluate the effectiveness of the
outreach efforts is frequently overlooked. And, all too often, the ,
type of measurement tools utilized to measure "success" are
selected out of convenience or availability of information. Let's
take a look at some of the methods commonly used to measure
success (Figure 2) and then I would like to share with you some of
our experience in Santa Clara County in developing a pesticides
source reduction campaign.
FIGURE 2
TYPICAL EVALUATION TOOLS
THE "NUMBERS" GAME QUESTIONNAIRES SURVEYS
flyers distributed at events impact of message
Ibs. at events after training assess retention
workshops conducted behavioral changes
requests for info level of satisfaction
referrals by client correct targeting
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The tools listed in the first two columns are most often utilized to
measure the success of outreach efforts to gain participation at
collection events. These evaluation techniques provide some indication of
effectiveness and are easily quantified. Surveys have not been used as
frequently as the other techniques primarily because of economic reasons.
However, a well designed survey can provide an important baseline for
measuring the success of HHW programs.
HHW programs have been in operation in Santa Clara County since the early
80's when the City of Palo Alto held its first collection event. Since that
time all of the cities have conducted collection events. In 1991, the
County proposed a consolidation of the individual city programs in order to
provide access to collection events on a county wide basis. In 1992,
twelve of the fifteen cities agreed to participate in the countywide HHW
program. One of the planning priorities of the program was the
development of a source reduction strategy.
The general guidelines we used to select an area for source reduction
were as follows: ease of implementation, potential for source reduction,
waste stream was not recyclable or generally reusable, and the product
was of concern to other programs. This quickly eliminated batteries, oil,
paint, and a number of household cleaners. The remaining items included
solvents and pesticides. One of the reasons we selected pesticides was
because the Nonpoint Source Program was also concerned about pesticides
usage and was willing to contribute financially to the source reduction
effort.
Our next task was to identify our target audience and develop a delivery
system to convey our message. We felt that it was important to reach the
consumer at the point where they were making a purchasing decision. This
had the benefit of self selection, i.e. information was made available
primarily to those interested in purchasing a pesticide product. For that
reason we discarded the approach of blanketing an area with flyers as
being too broad brush and selected the point of sales as our primary
distribution source.
The source reduction information takes an Integrated Pest Management
(IPM) approach and identifies specific less-toxic pest control materials
and brand name examples relying on information from established pest
control experts. All of the brand names cited are registered as pesticides
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by the'State-of'California. The-next step focused on the distribution of
our brochure. We first contacted «the corporate offices of the large retail
stores and got their buy in. We'then took our finished brochure to the
retail outlets that carry pesticides and spoke to the store managers. Most
of the managers, upon hearing that "corporate" approved of the concept,
readily agreed to carry the brochures in their stores and were helpful.in
determining the optimal location to place the information. In. addition, we
contacted the local nurserymen's associations, pest control applicators,
and chemical distributors to make presentations on our materials. We
.researched and printed a list of wholesale sources for the"products we
identified in our pesticide brochure and. make the list available to
retailers, applicators, and distributors.
Our criteria for success has both short and long term measures. For the
short term we-have identified the following criteria .as measurable
success: an increase in the retail availability of alternative products at .',
the targeted retail stores; and co-location of alternative products
traditionally carried in the store but not in the pesticides area e.g. copper
strips next to snail pellets. We did not consider the amount collected at
HHW events as a good indicatoMn the short run because of the large
inventory of materials currently stored in most homes. Interviews of
event attendees may reveal some change in buying habits. In the long run
we are looking for a diminution of recently purchased pesticides brought
to a collection event. ;. :
We have not developed rigorous measurement techniques to evaluate our
long term success. We lack data on the time span between when a-product
is purchased and when it is used up or discarded. We are exploring the
feasibility of using scanners or other methods to determine the date that
a product was manufactured or sold. With this data we can get a sense of
the proportion of old stuff that is being brought to an event versus newly
acquired material. The information can also be used as an indicator of any
reduction in overall usage.
Our pesticides source reduction efforts have been in operation for .
approximately six month. Our next steps will be'site visits to the retail
stores to interview the store manager, and to. establish a baseline of
existing inventories or:shelf space for future comparison. We are also
considering ,interviewing, repeat-attenders to determine what they are
bringing, how recent were the items purchased, and to identify any
changes in their purchase of pesticides. Over the long term, we will
continue to monitor-the amount of pesticides brought to the HHW
collection events, interview" the attenders to see if there has been any
change in their use of pesticides and to determine why they made the switch,
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MANAGEMENT OF NON-REGULATED HAZARDOUS WASTE:
Barriers and Opportunities for Rural Communities
t
Lola Schoenrich
How Big is the Problem and Hnw do Rural Communities Prioritize?
Rural communities are struggling with a host of solid waste management issues, all demanding time,
money, and attention. Many rural communities are not even thinking about non-regulated
hazardous wastes. Those that are concerned,, struggle to decide how big the problem is and where it
should come on their list of priorities.
It is clear that non-regulated hazardous wastes present environmental and public health
problems. The New York Times reported that every two weeks do-it-yourselfers dump on land and
in water the amount of oil spilled in Alaska in the Exxon-Valdez incident. Hundreds of tons of non-
regulated hazardous waste is thrown in the trash each year. While it is difficult to determine the exact
amount, experts estimate the amount of household hazardous waste to be about 500,000 to 800,000
tons annually.^
Surveys in Minnesota determined that hazardous waste from farms is also of concern. The
Minnesota Pollution Control Agency estimates that Minnesota farmers are storing approximately
1,200,000 pounds', and 280,000 gallons of liquid unusable or unwanted pesticides, and that some of
these farm chemicals are as much as 30 or 40 years old.^ A survey of farmers in Kandiyohi
County, a rural Minnesota county, found that over 40% of survey respondents did not know how to
safely dispose of used motor oil and lead acid batteries. 3
A survey of CESQG in Vermont found that these businesses generate an estimated 5,000 tons of
non-regulated hazardous waste in the state each year: used motor oil, antifreeze, paints,
photochemicals and more. In addition, the study found that most of these survey respondents were
unaware of the environmental problems caused by the waste materials.'*
Non-regulated hazardous waste is believed to be the source of the chemicals in the toxic leachate
from the 62 landfills in Minnesota that are on the State and Federal Superfund lists and hundreds of
others around the country. It is the leading source of heavy metals and other contaminants in
incinerator ash and toxics in compost made from municipal solid waste. In addition, unknown but
significant quantities of non-regulated hazardous waste enter municipal sewage systems, home septic
systems, and are poured into storm drains and on the ground, going directly from there to our
surface and groundwater.
In addition, to these environmental and health problems, non-regulated hazardous waste can
pose occupational safely problems to garbage haulers, workers in recycling centers, and other people
handling trash. Stored hazardous waste can be dangerous to firelighters and other emergency
response teams. Some rural firefighters will let a bam bum to the ground rather than risk contact
with stored toxic farm chemicals. Small amounts of hazardous waste can also cause serious damage
to waste hauling and processing equipment. An explosion at one refuse derived fuel facility in
Minnesota, thought to be caused by a container of less than one gallon of solvent, caused $800,000 in
damage and two years of down time at the facility.
Still, we must not let this emphasis on "waste" distract us from the larger issues of toxics in rural
communities. After all, remember that if the waste is hazardous the product was just as bad or worse.
If, for example, we worry about empty pesticide containers, we ought not forget that the contents of
those containers were spread over the land in regular application, contaminating surface and
groundwater in the process. There is good evidence that this and other uses of toxics can be
extremely damaging. A survey of over 700 private wells in agricultural areas in Minnesota found
that 42% exceeded drinking water standards for nitrates, and pesticides were found in 39% of all wells
tested. The U.S. Geologic Survey has found atrazine in all of the 146 samples taken recently from
eight midwest rivers. • . •' ;
There are numbers of other sources of large quantities of toxics in rural communities, all of
which need to be addressed. The 1989 Toxic Release Inventory in Minnesota lists over 20,000 tons
of hazardous air, water, and land emissions from manufacturing businesses in the rural parts of the
state.5 Certain types of mining, and oil and gas exploration and drilling create toxic wastes. It is
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estimated that mining produces some 800 million tons of rock waste each year which contain
teachable heavy metals, all in rural areas.
Other pressing problems abound within the area of solid waste. While, no comprehensive
overview of solid waste systems in rural communities exists, experience tells the following. Many
rural communities face huge problems in the collection and disposal of the bulk of their municipal
.solid waste, not to mention household or other non-regulated hazardous waste. Legal backyard and
. illegal dumping & burning is common. Green box or other waste collection systems may not work
^ well. Old town dumps and local landfills are being closed, and new landfills prove very expensive to
.4, build and difficult to site. Rural communities are beginning to recycle, and the programs are running
*" into problems because of the distance from or lack of ready markets for materials.
Right or wrong, dealing with the problems of non-regulated hazardous waste in rural
communities usually comes last, after the community has addressed its other solid waste management
concerns and scores of other pressing local environmental issues.
Review of Current Management Strategies
Before examining the special problems,,opportunities, and needs of rural communities trying to
deal with non-regulated hazardous wastes, it is important to understand the national picture, because
ideas about the best way to solve the problems of these wastes are changing in this country. The state
of management efforts for non-regulated wastes from households, farms, and small businesses is a
little different, but the trends are the same.
Household Hazardous Waste
The first management efforts began in the early 1980s with government supported household
hazardous waste roundups or collections and public education campaigns. These first efforts were
largely urban and efforts nationwide are still mostly urban. In 1991 there were over 800 household
hazardous waste collections held in the U.S., but these efforts were concentrated in less that 10 states,
and one can safely say that most rural communities have never had any collection of household
hazardous waste. Still, some ten to fifteen states do have rural programs, and we can learn from their
experiences.**
Today, the "state of the art" rural household hazardous\waste program consists of a
comprehensive public education campaign, usable product (usually paint) "drop an' swap" programs,
and ongoing collection efforts, either one day events, or permanent or mobile collection units.
Usually education programs stress use of alternative products and safe disposal of products.
In most cases, little or no funding is available to rural communities from the state or-federal
government. The states with the most successful programs do provide funding to local counties,
••; municipalities, or solid waste districts.
Farm Programs
Farm pesticide collection programs and waste pesticide collection programs are, for the most
part, funded and run by state government, often the state Department of Agriculture. -More than half
of the states have held waste pesticide collection programs, with little or no cost to the fanner to
participate. A 1991 survey of state programs indicates that almost every state is in the process of
planning farm chemical collection programs and seeking funding for these efforts. In general, the
intent of these programs is to clean up the highly toxic materials, especially the canceled and banned
pesticides fanners are currently storing in bams and sheds.7
A few states are beginning waste pesticide container collection programs. The intent is to
improve recycling programs by providing a special closed loop system for agricultural pesticide
containers. Again, these programs are most often funded and run by state government.
Conditionally Exempt Small Quantity Generators
Programs for CESQG are much less developed. Only .six collection programs nationally -
urban and rural - provide for disposal of waste from businesses. Data from these programs indicates
that participating businesses have hazardous wastes that are very similar to household wastes. Four or
five additional states are in the process of rule changes or program planning to allow businesses to
dispose of waste at government sponsored household hazardous waste collection facilities.
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Nationwide, people generally feel that businesses should pay for disposal, but that government may
be able to provide the necessary opportunity for reasonably priced disposal.**
How Well Are These Programs Working?
As collection and management programs for household, farm,, and CESQG hazardous wastes
have developed and matured, it is becoming clear that the cost is very high and that the programs
recover only a small percentage of the existing waste.
HHW collection programs in Minnesota cost between $40 and $84 per program participant, and
serve an average of 3% to 5% of the population.^ Is this good or bad? It is good compared to other
collection programs nationally, and Minnesota is seen as one of the leaders in rural household
hazardous waste programs. Yet, many rural policy makers feel that there must be a better way.
Policy makers generally agree that collection of stored old, unusable, canceled, and banned farm
chemicals is the only way to clean up these very real hazards from the countryside. Farmers will not
and should not store these toxics forever. The public will have to pay to collect and dispose of these
chemicals in the safest way possible. However, most do not see these programs as ongoing efforts.
Some other mechanisms will need to be devised to prevent or deal with hazardous waste from farms
in the future.
Programs to recycle used pesticide containers are seen as important because these containers are
contaminants in recycling programs. Plastics are hard enough to market without the possibility that
the product is contaminated with poison. If pesticide containers are separated and cleaned, there is
the possibility for a closed loop recycling system, making used pesticide containers into new ones.
But, again the cost is high. A pilot pesticide container program in Minnesota had a cost of $3.69 per
container recycled. 10 Ongoing programs would likely have somewhat lower costs. Still, these costs
are probably too high to be sustainable.
Local and state governments are beginning to think that these taxpayer based solutions are not
feasible or desirable over the long term. While providing an option for disposal of the waste now
stored in homes, farms, and other businesses is seen by most as unavoidable, the vision of the primary
solution is changing.
Policy Options: the New Solutions
Many policy makers and some states are beginning to see reduction of the toxic components of
the waste stream along with manufacturers' responsibility for the remaining toxic waste as the next
step. States are taking the lead at this point, creating the potential for a hodge podge of regulations
affecting national and international businesses, which will force federal legislation. These new policy
directions have two main components. The first is an emphasis on removing or reducing toxics in the
waste stream through legislation and other incentives to consumers. The second is a trend toward
putting responsibility for the remaining toxics problems on manufacturers, sellers, and finally
consumers of products containing toxics. This corresponds to a trend away from overall public
responsibility for preventing' and cleaning up toxic problems. In most states, rural communities are
not particularly active in these policy debates. The role that they can and should have in this arena
should be discussed. Some of this new legislation will resolve certain problems of non-regulated haz-
ardous waste. Some will create the need for new levels of cooperation between communities and the
private sector, with unknown impact on rural communities.
Source Reduction
Reduction of toxic waste at its source is increasingly being seen not only as a good idea, but as
the solution to the problem. There are a number of different types of source reduction efforts
around the country.
The federal government has banned hazardous components in products for years, eg. lead in
paint and gasoline. States are now taking similar proactive positions. Minnesota and a few other
states have essentially banned mercury in batteries. Other states are involved in similar efforts.. The
Council of Northeastern Governors (CONEG) has developed a plan which bans heavy metals in
packaging, and other states are beginning to develop similar legislation. This type of legislation is
seen as highly effective, and quite directly removes specific problem materials from the waste stream.
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Fees or taxes are another mechanism being used. Vermont is working to develop a plan to
address paint, used motor oil, and dry cell batteries. The plan developing in cooperation with
industry to address paint stresses both waste reduction and manufacturers' responsibility using
advance disposal fees to encourage consumers to buy only what they need and to provide an ongoing
funding mechanism for waste disposal. 1 *
Other efforts are geared toward helping consumers make better educated choices. Specifically,,
there are national efforts at product labeling such as the Green Seal, Green Cross, and Blue. Angel in
Germany. Some states, Vermont, Iowa and others have mandated in store shelf labeling programs.
Some states (Minnesota and others) are beginning to require that businesses cany out planning
processes designed to reduce use of toxics in manufacturing. This is currently aimed at larger
manufacturers, but these pollution prevention planning models can in time be .carried to smaller
businesses as well. . . - ;
Manufacturers' and Sellers' Responsibility '
• ill ur «i - - • Mf * '
, Policy makers are increasingly putting the responsibility for management of waste on
manufacturers and sellers. In Minnesota agricultural chemical dealers are currently -required to take
back empty pesticide containers and unused product beginning in 1994, unless the local government •
has developed a program to manage these wastes. Minnesota battery legislation also requires
manufacturers of certain types of batteries to develop collection, disposal, or recycling programs in
the state, both for businesses and for consumers. In many cases, laws will require local units of
government to work closely with manufacturers' and sellers, and rural communities will be faced with
the need to decide how much assistance they will provide to local businesses in complying with these
new laws. They will also need to decide how hard to push to make sure that these businesses are
doing their share., '
Challenges and Opportunities for Rural Communities
Rural communities face numerous challenges and have some special opportunities in developing
management systems for non-regulated hazardous wastes. Some of these may also be shared by
more urban areas. Many are similar or identical to barriers and opportunities to recycling and other
new waste management strategies. Some may be complete barriers for some communities. It is, at
least in part, these experiences that have led some state regulators and legislators to conclude that
current management strategies are not feasible as a long term strategy for dealing with these toxic
wastes. .' . . • • • •
Over the past three years, the Minnesota Project has worked closely with a number of rural
communities in Minnesota on projects designed to manage non-regulated hazardous waste and has
been. a part of a number of advisory committees and networks working on these issues. An advisory
committee made. up of rural people and state level staff and regulators has provided invaluable
assistance with this work. At each of the last two national household hazardous waste management
conferences we convened "networking" sessions for rural participants.^ The following discussion
presents issues identified by rural people working to manage non-regulated hazardous wastes in their
-communities, Minnesota Project advisory committees, rural communities with which we have worked,
and our own experience. .
Problems Encountered with Current Management Practices
Imorted
. One of the most important and difficult problems rural communities can have with non-
regulated- hazardous waste is that it may not come from within their community. If contained in
waste imported from other states, or even from other cities within the same state, rural communities
may be essentially powerless to do much to address reduction or management. They may be bought
off with promises and up front money, leaving them with big problems to address down the line. Part
of the solution to the problem of non-regulated hazardous waste in rural communities is directly tied
to resolving the problems of interstate transport of waste and waste facility siting issues, as well as
rural / urban respect and coexistence.
This problem of toxics in imported waste also highlights the importance and potential impact of
the newly developing policy solutions to the problems of non-regulated hazardous waste. Hazardous
waste is not only an "urban" or a "rural" problem, but a society wide problem. Urban problems can
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quickly become rural problems. Community by community programs will not be enough. Solutions
will need to address the big picture in some consistent fashion. .
Problems of Priorities. CQS^ and, Eectiveness
Imported waste aside most rural communities do not see non-regulated waste as a crisis issue.
Fewer people generate less trash and so, rural communities have much smaller volumes of trash, and
much less non-regulated hazardous waste, than metropolitan areas. Rural areas, like any other place,
respond first to crises. And, rural areas face many, many issues which feel far more pressing and
immediate than the possibility that the landfill might leak some day in the future. Health care, local
jobs, the economy, transportation, toxics concerns, pressing solid waste problems, and many more
: compete 'for attention.
With limited funds all communities must make choices on which waste management problems to
address first. As previously discussed, the cost of programs to manage non-regulated hazardous
waste is high and impacts are uncertain. In practical terms, communities must decide whether to
spend $25 to manage one gram of mercury, collect and dispose of five gallons of solvent, or recycle
500 pounds of glass. There is no one right answer to the question of whether the $10,000 to
$100,000 a rural community might spend on a program to manage non-regulated hazardous waste is
"worth it".
The answer to these questions of priority require complex management decisions. Disposal
methods are an important consideration. Local geology and weather play a part. Mercury emissions
and so battery programs might be critical if the community relies on incineration. Solvents, paint,
and used oil are probably more important to a community with a landfill. Communities with the
technical expertise to evaluate these various considerations may make educated decisions about the
best ways to spend their limited solid waste dollars. Others tend to rely on factors like public opinion
on relative program importance and mandates from above, not necessarily leading to the best
decision.
State Mandatef
One of the ways that communities prioritize issues is in response to mandates from above,
whether that be the county, the state, or the federal government. Since by definition, there are no
federal mandates to address non-regulated hazardous waste, this direction, where it exists, comes from
state governments. Whether or not rural communities even put non-regulated hazardous waste on
their list of things to worry about often depends on whether or not the state identifies it as a priority
issue for all communities and whether funds are made available to rural areas.
Fragmentation of Toxics Issues , -
In Minnesota and other states, regulations and programs which seek to address different issues
related to toxics in our environment and our trash are segmented and handled by different regulatory
agencies or departments within agencies. This creates confusion and frustration for local officials
trying to figure out the best strategies for toxic reductions. For example, counties in Minnesota are
required by the state to develop a plan for maintaining the quality of local ground water resources, a
local water plan, which will probably address issues of toxics in general and non-regulated hazardous
waste in specific. In so doing, they work with one state agency. There is a second state agency which
requires solid waste planning, including a plan for addressing household hazardous waste. A third
agency provides funding and technical assistance for local household hazardous waste programs. A
fourth state agency, the Department of Agriculture, handles the waste pesticide and pesticide con-
tainer collection programs. This is not to mention SARA Title HI, emergency planning and "Right to
Know" programs, business pollution prevention planning, and actual regulation of businesses. This
fragmentation of regulatory authority creates a situation which discourages wholistic thinking and
planning on a local level. Local officials can spend all their time responding to directives from
different state agencies, and it is only with extraordinary foresight and coordinated planning efforts
that communities can see the big picture.
Distrust of Outside Regulators
Even where non-regulated hazardous waste is a recognized problem, state and federal regulators
are often seen with distrust. People in rural communities often feel ill used by outside regulators.
Regulation's change over time and county and municipal officials who followed the rules all along
can still face huge costs for needed improvements. Fanners and small business people might prefer
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to lay low rather than take part in collections and "get their names on a list". Several farm pesticide
programs report increased participation over time, as word gets around that it is "OK" to participate.
In some cases the stringent regulations placed on collection, transportation, and disposal of hazardous
waste may in fact be barriers to the goal of collecting material, causing anger and frustration on the
part of both rural residents and state and federal regulators.
Lack of Funding
Lack of funding for programs is a major limitation for most rural communities. Even if the state
mandates planning and / or action,, decision makers are sometimes concerned about the cost and
effectiveness of existing management options. Given the high cost and questions about program
impacts, local decision makers who are asked to foot the bill take a hard look,'and often say no to the
programs. On the other hand, where someone else is paying for the programs, rural communities are
willing participants and active partners.
Limited Capacity
Rural communities tend to be ill equipped to make the difficult management decisions necessary
to prioritize solid waste management problems. They have limited capacity, in terms of financial
resources, local expertise, and administrative capacity to address their problems.
First, rural communities have less money to work with than urban areas. Rural areas tend to have
a lower tax base than metropolitan areas. People living in non-metropolitan areas earn 73.5% of what
urban people earn in similar jobs. Property values tend to be lower.13
Rural areas and small towns, unlike urban areas, tend not to have the skilled people resources to
call upon to solve new problems. Fpr instance, many rural communities have only a few staff
members who must be experts in everything. In addition to having less technical knowledge and
expertise, rural areas, particularly those that are low income or disadvantaged, may have reduced
administrative capacity. They have less experience in working with consultants, managing programs,
and in securing funds from outside sources. They may not have experience in writing proposals, in
managing funds, or in handling the paperwork required if outside funds are secured. They may not
be experienced in selecting or working with technical consultants. Finally, they may not have
technical expertise to actually run a program once it is established and the consultant gone.
Finally, many government grant and loan programs are designed to first serve large urban
centers. Very often grant funds are used to help these cities establish programs. By the time these
programs reach the most rural areas, less money is left, and these communities are asked .to pay a
larger percentage out of pocket. Too often, those communities with the least capacity to pay are
asked to pay the most.
Distance
Low population densities and long distances to collection sites and disposal pose obvious
problems in rural communities. Surveys of collection program participants in Minnesota show that
residents typically drive no more than 10 miles to a collection. Yet rural communities can have very
low population densities and long distances between towns. Long distances to disposal can also
greatly increase transportation costs, leading to increased costs of these already expensive programs.
Unique Opportunities for Rural Communities
While rural communities have their problems as they try to deal with non-regulated hazardous wastes,
there is a bright side as well. Many rural communities are very proud of their programs.. They have
been creative and diligent, and feel a tremendous sense of accomplishment. They are masters at
"making do" with less, and have transferred those skills to this new area of concern. Rural
communities do have special opportunities in managing non-regulated hazardous wastes.
The People
The most important of these is the people. They are involved in the community; they care; and
they can move an issue. In smaller communities and rural areas one or two dedicated leaders really
can make a difference. A person(s)- volunteer, county staff or elected official - who wants to work to
solve a particular problem can often do so, mobilizing support within the community at large in order
to build the political support needed. This local activism is what has made many rural recycling
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programs and existing household hazardous waste programs successful and is a key ingredient in the
success of future programs.
People in rural communities are often able to mobilize volunteers to work on household
hazardous waste and farm related programs. Volunteers are often active in all aspects of programs -
from public education to collection. These people can be creative and excited. They think up and
carry out all kinds of ideas, from an award winning shelf labeling program, to youth education, to
local videos, and more.
Rural communities in Minnesota tend to have tried and true ways to educate people about new
community issues. Schools are responsive to community needs, church groups are active, people
come to the county fair, and on and on. While difficult to quantify, rural program managers tend to
think that their educational efforts are paying off. Young people know more than their parents about
household hazardous wastes, and many people have the impression that at least some adults are in fact
making wiser purchasing decisions. One Minnesota collection program is seeing a decrease in
participation which they attribute to the success of their public education effort.
Local Cooperation
Many of the household hazardous waste programs in rural Minnesota are successful because the
counties have been able to work cooperatively with businesses in the region. This might mean that
the a local store collects used lead acid batteries, a service station collects used oil, and / or the used
clothing store will put a paint exchange in the back of the store. For many communities, this
cooperation has provided options other than disposal for handling some hazardous materials.
Creativity
Rural areas are less bureaucratic and are often particularly creative in programs. Given that
creativity, they often pioneer new and better ideas. For example, in Minnesota, the rural programs
have pioneered useable product exchanges. Winona County, a rural county of 50,000, was able to
document savings of over $11,000 in disposal costs as a result of their exchange program.^ Several
counties in South Carolina are working on a project to help farmers exchange usable but unwanted
farm chemicals.7
Rural Communities and New Policy Directions
In addition to specific concerns and opportunities with respect to existing programs to address
non-regulated hazardous waste, rural communities have a place in the larger policy debates. People
from rural areas need to get involved in developing new policies to address those problems which
most concern them. This will, of course, vary from one part of the country to another. In some
places, the prime concern is the issue of imported waste, in others issues of toxics use on farms are
most important. People who have been trying to run household hazardous waste programs may wish
to get involved in developing new strategies to prevent these wastes.
In some states, the involvement of rural legislators may be important in passing legislation
requiring the reduction of toxic components in products and mandating manufacturers'
responsibility. At least in some places, rural legislators will be freer from the pressures of big
business and are able to respond more directly to the best interests of their constituents.
One recurring local issue arising in some rural communities as a result of new policy initiatives is
the issue of jobs vs the environment. It can be hard for rural communities to confront local
businesses and get them to comply with environmental legislation, if there is a real or perceived
increase in costs or hassle for the business. Jobs might be at stake. So, if local governments are left
to work out the mix of government and business responsibility for non-regulated toxics, some will
have difficulties. Conversely, some are and will continue to be very successful in developing local
government - business partnerships that work well for both parties.
Conclusions and Challenges
All communities, rural and urban, struggle with a number of difficult issues when they begin to
address management of non-regulated hazardous wastes.
First, they grapple with the question of how to prioritize the problem. In choosing to address
non-regulated hazardous waste, are we coming at the toxics issue from the right angle? What about
the rest of the product, which presumably was used somehow? How important is the issue relative to
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the many other solid waste problems a community might face? How much non-regulated hazardous
waste is there and what damage is it doing?
Second, is the question of the cost and effectiveness of current management practices? At what
cost do we deal with non-regulated hazardous waste? How effective are the current management
strategies?
Third, where should the responsibility for non-regulated hazardous waste and other toxics lie:
taxpayers and communities; consumers; business; retailers, wholesalers, manufacturers? Who gets to
$t say when enough is enough - or when enough is too much?
•*- Finally, what impact can and should rural or urban communities have on the solutions to these
~~' questions? Communities have limited abilities to impact the problem because regulation occurs on a
state and national level, and most relevant policy changes will also happen on state and national levels.
How active should rural or urban communities be in trying to impact the new policies being
developed by state and federal government?
Rural communities face a number of specific difficulties as they work to prevent and then
manage hazardous waste from non-regulated sources, both waste coming from within and outside of
their communities. Their uniqueness also offers them the ability to be creative and successful in
many ways. To succeed they will have to both manage existing wastes and get involved in the
developing regional and national policy debates that will begin to offer more workable long term
solutions. In order to truly solve the problems of non-regulated hazardous waste, rural communities
have a number of specific needs.
First, rural people need to talk with one another. They need to share stories, of successes and
things that did not work well. Rural people tend to be isolated as they work to resolve specific
technical problems, and so sharing is particularly important to them. There is power and energy in
learning directly from one another. Cross-state peer matches are an excellent tool for-sharing of
information and experience. Networks and coalitions help everyone, and especially rural people, to
organize for political action and to leam about the best ways of setting up programs.
Rural people do not have the time and resources to reinvent the wheel. They need technical
support and assistance. They need-to know why they should care about hazardous waste. They
need to know specifically how it does or will impact them in their communities. In order to
understand what they can and cannot dp they need to understand the complex regulatory framework
of hazardous waste, in simple nontechnical terms. They need an understanding of the program and
policy choices and their implications. Case studies and specific examples of successful program ideas
_y, are very helpful. 'Resources such as tried and tested curriculum materials, educational materials,
r~ handbooks, or manuals are useful.
-.!«*• • .' , i* -
Most rural communities probably need a push from above, a mandate from the state level,
before they will tackle the many issues of non-regulated hazardous waste. States can provide: the
mandate to act by requiring local plans or programs; program frameworks; funding in the form of
grants or pass through money; technical assistance; educational materials, handbooks and more. But,
too much fragmentation of regulation creates difficulties for rural communities.
. At the same time, rural communities need regulators to give them room to be creative.
Regulators need to know when to get out of the way of great ideas. Because of the level of
regulation surrounding this issue, this sometimes means changing or bending the rules to make rural
programs work. Many state and federal regulators benefit from information and training about the
specific needs and abilities of rural'communities, so that they can be more responsive to these
communities. . '
Many rural people and communities need to get active and participate in the different policy
debates that are in progress and still to come on toxics issues. Many of these affect rural
communities quite directly. Citizen action groups, environmental organizations, technical assistance
providers, churches, and other organized groups will play a key role in this organizing. ,
Finally, in order to significantly reduce the amount of non-regulated hazardous waste in our
communities, rural people, and everyone else, needs to make different choices about what we
purchase and how we use those toxic products we do need. We need more "environmentally" friendly
businesses, providing jobs without destroying our health and our natural environment. We need to
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take a very close look at the origins of the toxics in our environment, and figure out how to live
without them. Changed lifestyles may well be the bottom line.
REFERENCES
1. Galvin, David V., "Why Household Hazardous Waste Management is Needed". Proceedings of
the Fifth National Conference oh Household Hazardous Waste Management. U.S. EPA, 1990.
2. Palmer, Larry, "Waste Pesticide Collection - Pilot Project Final Report", Minnesota Pollution
Control Agency, 1989,
3. Vruwink, Kathy, "Kandiyohi County Rural Farm Hazardous Waste Project", Minnesota Project,
1991.
4. Bender, Michael, "Vermont's Exempt Small Quantity Generator Study", Proceedings of the Fifth
National Conference on Household Hazardous Waste Management. U.S. EPA, 1990.
5. Minnesota Department of Public Safety Emergency Response Commission, "1989 Toxic
Chemical Release Inventory", 1990.
6. Duxbury, Dana, "The National Listing of Household Hazardous Waste Collection Programs,
1991", Dana Duxbury and Associates, Boston, MA, 1991.
7. Cubbage, Charles P., "Summary of State Agricultural Pesticide Collection Programs",
Proceedings of the Sixth National Conference on Household Hazardous Waste Management. Dana
Duxbury and Associates, Boston, MA, 1991.
8. Feeney, Karen, "1991 Overview of CESQG Programs", Proceedings of the Sixth National
Conference on Household Hazardous Waste Management. Dana Duxbury and Associates, Boston,
MA, 1991.
9. Minnesota Pollution Control Agency, "Development of the Permanent Household Hazardous
Waste Management Program in Minnesota", 1991.
10. State of Minnesota Department of Agriculture, "Pesticide Container Collection and Recycling
Pilot Project 1990-1991, Agronomy Services Division, 1991.
11. Bender, Michael T., "Regional Planning Efforts and Vermont Emphasis on Manufacturers
Responsibility in Implementation of State Management Plans for Paint, Oil, and Batteries",
Proceedings of the Sixth National Conference on Household Hazardous Waste Management. Dana
Duxbury and Associates, Boston, MA, 1991.
12. Minnesota Project, "Networking for Rural HHW Programs", Proceedings of the Fifth National
Conference on Household Hazardous Waste Management. Dana Duxbury and Associates, 1990.
13. Statistical Abstract of the United States, 1991.
Lola Schoennch is a Solid Waste Specialist with the Minnesota Project. The Minnesota Project is a
nonprofit organization dedicated to working with Minnesota's rural communities to assist them as
they build their capacity to address development and resource problems. There are currently three
major program areas at the Minnesota Project: Groundwater Protection and Sustainable Agriculture;
Alternative Solid Waste Management and Community - Based Development, including leadership
development. Contact us for or more information about the Minnesota Project or for information
about other publications.
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RURAL WASHINGTON'S PROGRAMS
by
William P. Green
Washington State Department of Ecology
I will begin by introducing the current Washington State Moderate Risk
Waste (moderate risk waste is the combination of household hazardous
waste and conditionally exempt small business (SQG) waste) Program. By
the end of 1992, Washington will have nineteen permanent facilities and
three mobile systems. Fifty-two collection events were held in the
state in 1992. Over the next three years, twenty, additional facilities'
are planned.
Area-specific implementation was in the original design of Washington's
moderate ri.sk waste system. Although minimum efforts were delineated in
the planning guidelines, the basis for approval of local plans and . ' '
projects was more oriented towards problem solving. Actually, most
counties, both urban and rural are now exceeding the minimum
requirements. .
If you look at the system, can you distinguish the rural area's from the
urban districts as far as efforts to manage household hazardous waste?
There are seven urban counties in Washington (divided out for the
purposes of this talk). By "urban", I used the following criteria:
Population density greater than 200 people per square mile, and
Total population of county greater than 100,000.
Using these criteria, the state was divided into two distinct groups as
shown in table 1.
Table 1: A Comparison of Rural and Urban1 Washington
Identifier
# of Counties
Population
Area '(sq. mi, )
Pop . Dens i ty
Rural Areas (%)
32 (82)
1,255,792 (26)
57,175+(86)
21.96
Urban1 Districts
7 (18)
3,610,900 (74)
9,407 (14)
383; 85
Total Washington
39
4,866,692
66,582
73.09
•'Urban districts are defined as those counties whose population exceeds
100,000 and whose population density exceeds 200 people/square mile.
Notes: Numbers in parentheses represent percentages.
Population density is measured in people per square mile.
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I am going to use a comparison of the urban and rural programs to better
describe what's going on in rural Washington. I chose to present the
information in this manner because I feel that, in many respects, the
urban and rural areas are actually performing similar tasks, but in
manners geared to-the needs of their respective areas.
There are three areas where I will compare the urban and rural areas of
Washington: utilization of state support, education efforts, and
collection systems. These, along with additional areas of comparison,
are.summarized in Table 2.
In the first area, utilization of state support, is where there is the
greatest distinction between urban and rural. In the rural areas, most
of the requests to the state are financial and logistical. By
"logistical" I am referring to actual physical support such as
brochures, "how to" manuals, individualized training for staff, and
assistance in working with elected officials. Questions regarding the
eligibility of tasks for grants support are often asked.
The urban areas rely on the state more for legal support, i.e.
regulatory interpretation, back-up on enforcement actions, and support
in working with cities and towns. Host programs in the urban districts
are locally designed and implemented. Many rural areas choose to
implement Ecology programs--in their own way. Additionally, in the
urban districts cities act independently or as major implementing
agencies, whereas in the rural areas, moderate risk waste is generally
implemented by the county.
In education, counties throughout the state are focussing on the schools
as a major source of behavior modification. For the general public, the
urban counties tend to use the electronic media for PSA's and other
advertising. Advertising is more organized into "campaigns*. In rural
counties, the printed media is a major vehicle for information
dissemination. Moderate risk waste is rarely front page in the Seattle
Times. However, the Skagit Herald, Newport Miner, and Tri-Cities Herald
all have featured moderate risk waste. Also in the rural areas,
brochures and other printed material are available at public buildings.
In several counties, cooperative extension agents have dedicated time to
moderate risk waste education.
In collection, the distinction between urban and rural systems lies in
the amount of waste handled. Urban systems are large, with mobile
systems that remain in place for extended periods of time. Due to their
less transient nature, consideration is being given to requiring permits
for some of the urban mobile systems. Supplemental collection events
are commonly sponsored by cities to augment the capacity and convenient
of the system. SQG waste is generally handled by the private sector,
all three metropolitan districts have licensed hazardous waste
treatment, storage and disposal facilities (TSD's). Urban counties tend
to contract collection services and/or disposal with their local TSD's.
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In the rural areas, there is only one TSD in central Washington. Rural
counties contract with this TSD, the metropolitan TSD's, or even out-of-
state TSD's. Rural systems tend to be smaller, and many rural-
facilities collect SQG waste along with the household waste. Mobile
systems are' more mobile--usually serving two or three towns in a single
day. These "tailgate" collections are much more reminiscent of a
collection event that their urban counterparts.
Also growing in the rural areas are "satellite" facilities. These
facilities, which are manned infrequently collect waste from the more
remote parts of some of the rural counties. The waste is removed and
transported by the county to the central MRW facility. There the waste
is combined and processed for shipment.
Collection events are still common throughout Washington, in both urban
and rural areas. In many urban areas, these events are used to
supplement other collection efforts, and are generally held in suburban
and.rural districts (all of Washington's counties have some portion
.which is considered rural). Collection events are the mainstay in some .
rural counties, but most of these counties are also planning permanent
facilities within the near future.
Probably the most outstanding feature" in the Washington system is that
all -areas have staff which are dedicated to moderate risk waste. There "
are currently some 129 local staff dedicated to moderate arisk waste,
with about half located in rural areas. Some of the larger rural
counties may have up to four staff dedicated to moderate risk waste.
There are at least three advantages to having local dedicated staff:
there is always someone to contact at the local jurisdiction;
there is'a local advocate for moderate risk waste programs; and
the local jurisdiction has ownership of the local system.
This leads to the rather paradoxical ending--resources. As I sat at a
teleconference sponsored by Washington State University, on household
hazardous waste, I realized what will probably be the next challenge for
Washington's program, especially in the rural areas: the program is
larger and more successful that the early planners had envisioned. And
it is growing. And it is collecting more waste. And it is costing
more. The challenge: how do we pay for all this? and how do keep the
system cost-effective? And yet, this was the challenge from the begmr- &'
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TARGET CRITERIA FOR RANKING BUSINESS
.'•V
Todd W. Yerkes
Seattle-King County Department of- Public Health
King County has a population of about 1.5 million people.
Seattle is the major city and there are 29 suburban cities.
Our hazardous waste plan is a cooperative effort of 5 existing
agencies and jurisdictions with each having specific programs
which they are responsible for implementing. The three
components that involve Conditional Exempt Small Quantity
Generators (CESQGs) are education, collection and compliance.
The Health Department and Metro, which is the major sewer
utility in the region, implement the education and compliance
components, with the King County Solid Waste Division
currently in the process of developing the CESQG collection
component.
We have 50,000 businesses in King County, with 45,000 being
small businesses. Through work that we have done using SIC
codes,, we estimate that we have over 20,000 CESQG's.. In. 1992,
they will generate 13,000 tons of hazardous waste, and that
waste is currently either being (1) managed properly, (2) or
mismanaged by being disposed of in the solid or liquid 'waste
streams or on the ground.
Our CESQG program became fully staffed about April of 1992.
However, a lot of the groundwork required to. start up the
program was begun in 1987 when we started to design the CESQG
components.
All of our components are founded on the premise that we will
achieve greater positive behavioral changes through education,
technical assistance and cooperation with the businesses than
with enforcement.
Businesses and business associations have played an integral
role in the development and implementation of our program.
The purpose of.this discussion is to describe the process and
rationale we use to prioritize the businesses we will assist
through our program.
The ranking of small businesses is not as clearcut a process
as it is for larger hazardous waste generators. We need to
look at a number of less tangible criteria for ranking CESQG's
when delivering our services.
I'm assuming that our businesses are similar to those all
across the country, and I can tell you that they take great
offense when we referred to this process as selecting target
industries. The word target has a very bad connotation to
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them, so that we have started to refer to them as priority
industries instead. This may seem trivial to you, but I can't
emphasize enough the importance of being sensitive to the
needs of businesses and the environment they have to operate
in.
GENERAL CATEGORIES FOR RANKING
The three broad categories we use to rank businesses include
determining the:
(1) nature of the waste;
(2) the nature of the industry; and
(3) other considerations.
Some of the criteria are interrelated and some appear in one
form or another in several or all of these categories.
NATURE OF THE WASTE
The nature of the waste contains a number of the traditional
methods for prioritizing businesses. It includes criteria
such"as: '*
* How hazardous are the materials they are using and what
wastes do they generate?
* How much hazardous waste is produced by each shop?
* How many shops are located within the county, what is
the total volume of waste generated by this industry
type?
* How many waste streams are involved? Are there
discharges to air, solid waste, sewers and surface
waters?
* What are the types of problems encountered by these
industries? We don't want to spend inordinate amounts of
time on business types that are already managing their
wastes effectively. '
* What technology options currently exist for source
reduction, alternative processes and technologies, and
recycling? . •
The next two categories are less tangible, but contain equally
important criteria.
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NATURE OP THE INDUSTRY
* Again when looking at the industry ,as a whole we need
to know the number of businesses . involved.' This -is
critical in determining what resources are needed and
what we have available. This is an important issue when
developing our work plan goals for the CESQG program.
The next seven criteria can provide us with opportunities for
us to assist businesses with their hazardous waste management
practices. They include:
4 How receptive is the industry to pollution prevention
practices? - • • .
* What -is the economic environment they are currently
working in? Our desire is that our CESQG program not put
shops out of business. This is not beneficial to our
community nor is it politically beneficial to our own
programs.
* How organized and active is the business association?
Early on we realized that acceptance of our program was
predicated on a good working relationship with existing
structures that could disseminate and promote the
information we had, to a large, well organized audience.
Questions we ask are, do they have a newsletter? How
many -members do they have? What proportion of the
businesses belong? Are there existing programs, such as
trade fairs, and seminars? How successful are they at
policing their own industry?
* Are they a strong association, with- a strong
legislative lobby?
* Are other agencies currently concentrating their
efforts on this business type?
,* What level of knowledge do they have concerning
regulations?
>. Are there other pressures exerted by their own
industry?
OTHER CONSIDERATIONS
The last category the catchall deals with even more nebulous
criteria. They include:
* How many other agencies are starting aggressive
, . programs in this industry type, and are there new
regulations -that are having a significant impact?
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* Are the current regulations having a significant impact
or will there be major changes in the near future? We
don't want to be advising businesses to take on new and
expensive technologies if they will not be needed or will
have to be changed in the short term.
* What is the impact of the regulations? Does this
impact provide us with a window of opportunity a way of
t getting our foot in the door to provide education,
technical assistance and clarification of often very
complex regulations? Are there conflicting regulations
between different agencies?
Our program has been instrumental in doing the unthinkable, of
having all of the agencies that affect a business sit down and
talk about what the intent and desired outcome of all of our
different regulations are, and if there are conflicts how they
can be resolved.
* What are the private sector initiatives?. What
positions are their associations pushing on their
members?
the industry receiving -a lot of either positive or
negative exposure in the media?
* Are .there very vocal individuals in the industry that
are not suppprtive of the direction we want to. go?
* Are the businesses willing to work with us?
4 Is this the appropriate time for us to deal with the
industry?
* Is the economic climate right for us, or are the
- industries attention distracted by more pressing issues,
like just trying to stay in business?
Of utmost concern to us is how our CESQG program can work with
our businesses. Because of the large number of businesses
that we have to deal with, we need to take an educational
approach, not the big stick approach. We could never get out
to all of the shops within one business type in a timely
manner. The approach you have to take when confronted with
inspecting thousands of businesses is not the same if there
are only five or ten.
Again, I have to stress the importance of developing a good
working relationship with the associations. Even though not
all of the shops in an industry belong to the association they
may still receive the newsletters, or hear by word of mouth
what is going on. Its crucial that you get businesses to work
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with you.
In our program, we are looking for long term positive behavior
change. We are interested in effective changes in poor waste
management handling practices. We are not interested in short
term, short lived big changes. All of these criteria can
either work for us or against us.
After evaluating an industry type using these criteria the
next stop we undertake is the needs assessment.
In the needs assessment we visit a randomly selected portion
of the industry. We look at all of the manufacturing
processes the types of products that they use, study their
waste handling practices, assess the level of sophistication
they currently have concerning the regulations, source
reduction, recycling, and very importantly the awareness of us
and our CESQG program and services.
We conduct multi-agency inspections, so that our people know
what other agencies expect when they visit this industry.
We have, extensive meetings with the association and business
leaders. We make presentations at their scheduled meetings to
inform them of who we are and what our objectives are.
All of this information is then used to design the training we
use to bring all of our field teams up to speed. During the
development of this training we rely heavily on our next
speaker, Ann Moser to research questions we have on the
industry and new and innovative products and technologies
available to them. In selecting new priority industries, in
the future, we will also be using the results of our on-site
technical assistance, survey team results and our complaint
based team results to assist us in prioritizing future
business types.
A:\SPEECH.TOD
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Accessing "green" information : methods and motives
Anne Moser, Librarian
Municipality of Metropolitan Seattle (Metro)
Local Hazardous Waste Management Program, Seattle, Washington
L Introduction
Technology and computers have become almost second nature to society. In fact, it has been said
that technology has become an important and essential dimension of humankind. From the beginning of
time, humans have been tool makers, constantly striving to make tools that ease the burden in their lives.
Until very recently, industry crafted these tools. It is only in the last decade that the computer has become
the most popular tool. The computer has created a new commodity for our society — information. This
new commodity has created a new age in our society — an age affectionately referred to as the
"information age."
We send and receive information daily. However, society has not collectively, reached an
understanding of the enormous role information plays in our lives. It will be helpful then, to first define
what we mean by "information" before we begin to talk about how to access it.
What is "Information"
Information is defined in Wcbsters's Ninth New Collegiate Dictionary as "the communication or
reception of knowledge or intelligence." What does this definition tell us? Information can be thought
of as the sharing of knowledge with one another. On the basis of this definition, information is everywhere
— in books and newspapers, on television, from gossip heard from the next door neighbor. Although
often times misunderstood, information has become a driving force in our society.
As the world grapples with global information networks, the proliferation of information continues
ad infinitum. With a shift from an industrial society to an information society, the presence of information
has a greater and greater influence on how we live our lives and how we perform our jobs. The shift is
also a reflection of underlying changes in technology and in the economic structure of our society.
What has the introduction of computers and the arrival of the information age meant practically
in our lives? It has meant that everyday our lives are being driven faster by this technology and we are
forced to absorb a greater amount of information. As a result, we view our world in a multiplicity of
viewpoints and horizons. For example, the people in the United States were hearing about the attempted
coup in the former Soviet Union almost at the same time that it was occurring. This illustrates how the
computer has'enabled us to tap into a global body of knowledge and hints that this access to information
on both sides may have contributed in a small pan to the end of the Cold War.
The advent of the computer age has not been without problems The political campaign illustrates
the speed at which information moves. Many people in the western portion of the country complained
heavily because they are finding out the results of the presidential election hours before the polls close
in their district. This is a symptom of the overload and the speed in which information travels in the '90s.
There is even talk of a new ailment called information overload.
It is important however, to keep in mind that information as well as computers exist primarily to
assist us in our daily lives, especially in what we do on the job. The context of what you or I know how-
ever is just as important, as the ability of the computer to process the data or knowledge that we possess.
We should not define ourselves in terms of computers, just as our minds are not software programs.
EL From Your Computer Screen To Your Mailbox
People share and disseminate information in three basic formats — print, computer and verbal.
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The most traditional format of information is the print medium. This medium has maintained its
popularity even in today's age of computer wizardry. Many people enjoy sitting down to read a good
book or depend on certain reference materials such as the Merck Index to quickly locate bits of
information. This medium includes books, journals, magazines, newspapers, brochures, and even junk mail.
The one drawback to this medium is the tendency by society today toward desiring rapid delivery of
information. The computer has raised the expectations of society so that everyone anticipates things to
happen quite rapidly. That is what makes the book appear outmoded. This expectation will not disappear
any time soon so the print industry is beginning to respond to this need and they are trying to provide
their materials in a more timely manner.
The second medium of information is the most technologically modem — the well-loved
computer. With the arrival of computer technology, we can access an enormous body of knowledge
through bulletin board systems, on-line databases and CD-Roms and we can also quickly share information
with our colleagues over these networks. Computers have made the access of information quick and
relatively painless, providing comprehensive, timely, and reliable dissemination of knowledge. In addition,
computers provide a clearinghouse for information in a relatively small space. Computers are able to tap
into resources around the globe and bring up-to-date information from throughout the world to our
doorstep. On-line searching for example can help locate company or product-information, current news
articles, regulatory changes and toxicology and chemical information. There is one catch, however, to this
modern wonder — finding and sharing information through computer technology is often a one-way
conversatioa This is limiting because the ancient form of two-way communication is a vital-link to our
need for information.
The third medium for the exchange of information is an ancient mode. However, it is probably
the most valuable of all — spoken communication. Networking with colleagues provides a unique
opportunity to share expertise and experience in a way that the printed and computer mediums do not
allow. Much of the quantity and quality information that exists is not available in any other format. The
computer already has a role in the survival of both spoken communication and printed format. -Electronic
mail (e-mail) has proven to effectively combine both the computer and verbal mediums by providing a
way to electronically network. Computers have also advanced the publishing industry into the future
where books and magazines are only available in electronic format.
m. Role of Information in the Hazardous Waste Field
One of the most challenging demands facing people working in the hazardous waste field is
creating, sharing and using information to help society choose to use less hazardous chemicals. This is
true whether one is working with households, small businesses or large quantity generators. -The
environmental field and in particular the hazardous waste field has grown dramatically over the last 20
years and as a result there exists a large abundance of information. It is our challenge then to link
information with our final goal — a CLEAN ENVIRONMENT through an increased use of safer alternatives.
There is a great social need for information in the hazardous waste field because information is one of the
strongest links between where we are today and where we want to get to. Information in essence is a
public good and the public benefits when they understand, through information, about the hazards of the
chemicals we use every day. We use information in the hazardous waste field to support three activities
— education, basic research, and public policy development.
A. Education
The first way we use information is in support of education. The state of the environment has
become a very high profile issue. Society is constantly being bombarded with negative news concerning
a new disaster that is related to the environment, often caused by a hazardous waste spill or discharge.
Public awareness grows in the wake of increased media attention. This awareness heightens the
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motivation of the public to do something to change. People working in the hazardous waste field should
be poised with good information in hand to assist the public in making intelligence decisions and
conclusions about the environment As public awareness grows about these issues, so does the need for
good information.
If our premise is'that the goal of many hazardous waste programs is to educate society about the
use of hazardous chemicals with the result being increased use of alternative products, then public
awareness begins with education and education begins with information. The first step in changing
society's practices is take was is known and use it to help society understand the implications of hazardous
chemical use.
B. Basic research
Information supports basic research that will ultimately lead to alternative technologies or
alternative chemicals. Any research performed in this field should include investigation into the wealth
of research information that already exists. This will aid us in efficiently using our available resources.
It is essential that we continue to network with others around the country to avoid duplication of effort.
C. Public policy development
Information assists in the development of public policy that is the catalyst for compliance with
regulatory requirements. We use information to draft guidance documents, laws and regulations.
In summary, information in the hazardous waste field is already abundant in quantity and in many
cases, superior in quality. It is vital that we avoid reinventing the wheel in all instances and that we keep
our mission of helping the environment clear. We must carefully examine the wealth of information and
use that information to design and implement programs for small businesses and households.
IV. Setting Priorities — How To Find baseline Information on a SQG
As an illustration of the different sources of information and how to go about accessing them, I
would like to use an example from the CESQG portion of the Hazardous Waste Management Program
at Metro. The Program chose to assist the screen print industry in King County as one of our first priority
groups. In our initial stages of developing a worfcplan, it became evident that we needed several bits of
information about different aspects of screen printing — who they are, what they did, what they did with
their waste and what other groups or programs might be working with this industry elsewhere in the
nation. After several years, this baseline information will help us evaluate whether we have been able to
create a change in the industry in their handling and use of hazardous chemicals and hazardous wastes.
Screen printers in King County were chosen because little or no outreach has been provided to the group.
Nor could we find any research performed on new and innovative waste management or reduction options
for the industry.
I will illustrate in detail the steps I took in researching the answer to the question "Who?" to show
how a simple search for information often involves investigating all three formats of information that I
have mentioned above. I believe it also will illustrate some of the pitfalls and surprise successes that can
also occur. Anyone who is gathering this kind of information will probably experience the same
phenomena.
Who are they?
How do you find out how many screen printers exist in King County? This question had the
appearance of being easy to answer but was the most difficult task in our original information gathering.
There are at least four reasons why this is so. First, the screen print industry is a very diverse group. The
industry works on many substrates, such as textiles, plastics, paper. The result is that the industry is
scattered among ten different Standard Industrial Codes. Second, most small business owners want
anonymity. Many of them are teetering on the edge of existence and are nervous about having anyone
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know they exist who be able to put them our of business, (i.e., as a regulatory agency) Third, there are
probably as many as many "do-it-at-home" screen printers as there are "legitimate" shops. It is nearly
impossible to reach this portion of the industry. Finally, there is a statistic that is thrown around, which
I cannot completely substantiate, that says 90% of all small shops go out of business within 2 years.
These four issues are true not only, for the screen print industry but for any industry that might be included
in an CESQG program and are only a few of the challenges facing programs that want to work with small
business. • . ' "
Some of the places employed in the search for screen printers included:
a. Local or state agencies, particularly business licensing depts.
For the screen print group, we contacted the city of Seattle and King County-licensing
depts. to find out how many licenses have been issued for this industry class. In addition,
we obtained from the state environmental agency, the Washington State Dept. of Ecology
a list of permited generators
b. Local, state and national trade and professional organizations
The screen print industry does not have a local group, but does have an active national
association, Screen Printers Association International. This group is already well aware
of hazardous waste issues and is working with EPA to study some equipment and
chemical alternatives.
c. Electronic lists
The best source for lists of screen printers wound up being an electronic version of a
phone book. Lists of company names are sold as a commodity and are usually the most
accurate and up-to-date because the vendor usually has the most current technology to
handle a heavy duty textual file. However, it is important to note that these lists, or any
list of small businesses that is generated is only good as of the moment they are
purchased or created. Many small businesses dissolve within 2 years that is another
important note to make when involved in an CESQG program.
d. Vendors
This source of is a very good one but requires a trustful relationship between an agency
and a vendor. The screen prim project has an advisory board of screen printers and
vendors and a good relationship has been formed between the two. Luckily the screen
print vendors have volunteered to assist us. They are the. people who have the most
contact with the screen printers and have a good idea of who they are. They cannot
actually share their mailing lists with us but they are willing to be spokespeople to the
agency on our behalf and are willing to disseminate information for us.
Some other questions that we wanted to answer as part of our baseline information included the
following:
What chemicals do they use?
What are their processes?
What wastes to they generate?
What waste management practices do they keep?
Are there any waste reduction options already available to them?
What other programs or organizations are working with same industry group
Our program will go through a similar process for every business type that we wish to assist. By
seeking the answers to these questions, we were able to get some baseline data that will help us evaluate
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the effectiveness of our program.
V. Conclusion
In summary, I hope that this paper has illustrated four important points. First, access to
information is vital in the hazardous waste field. Most programs are attempting to change behavior of the
public, on the part of both citizens and business owners, so that they begin to use safer alternatives for
hazardous chemicals. To change this behavior, we must raise public awareness. Public awareness begins
with education and education begins with information. Second, it is important to be efficient in what we
do and use available resources wisely. A tremendous body of knowledge already exists and we each much
tap into that wealth before we reinvent the wheel. Third we must all become more educated about how
the computer taps into, a huge body of knowledge. It should not be our only source of information, but
it is an important one that currently is being under utilized. And last, I would add a personal caveat that
I have found in my years of seeking information — that is that finding information is a frustrating and
time-consuming effort. However, it can be the key to much what you need to know.
VI. References.
1. "Eco-Data" in the Green Business Utter, 3 part series: May, June, and July 1992.
2. Eco-linkine : everyone's guide to online environmental information / by Don Rittner. — Berkeley, CA
: Peachpit Press, 1992.
3. Environment online : the greening of databases / Online, Inc. — Wilton, CT. : Eight Bit Books, 1992.
4. Environmental software directory 1990/1991 / edited by Elizabeth Donley. — GarrisonviUe, VA :
Donley Technology, 1991.
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GREAT LAKES TECHNICAL RESOURCE LIBRARY
PROJECT OVERVIEW
David S . Liebl
The Great Lakes Technical Resource, Library (GLTRL) was conceived as a tool to promote the
implementation of pollution prevention in the Great Lakes Region. By providing an extensive
listing of technical resources the GLTRL will give users access to information for implementing
pollution prevention that may not be otherwise available to them. The GLTRL has been modeled
on existing library classification systems at the Minnesota Technical Assistance Program - -
Minneapolis, MN (MnTAP) and the Hazardous Waste Research and Information Center -'
Champaign, IL (HWRIC). Using INMAGIC library software as a personnel computer (PC)
interface, the library gives users access to over 5,000 unique technical resource listings for
books, technical papers, manuals and government documents. A second component of the. library,
the vendor/equipment/services database, is available to give users access to listings of companies
that provide equipment, supplies and services that can be used for pollution prevention activities.
Although on-line access is available for some of the resources found in the GLTRL the
documents that have been included have been previously reviewed and classified by two
established technical assistance programs. Consequently the library will include most existing
references of interest for pollution prevention and exclude materials that are not useful. Being
able to access the library on a PC gives a vast improvement -in useability in comparison to other
on-fine systems. Being a PC based library also allows each user to continually add references to
their copy of the library and provides the opportunity for contributions of new references from
throughout the region.
The shelf coding systems for both MnTAP and HWRIC are available allowing users to organize
and label their reference materials without the need to devise a coding system of their own or
invest resources in using an established cataloging system. MnTAP has created a shelf code
system based on industrial processes commonly found when doing technical assistance for
pollution prevention. HWRIC has chosen to use Dewey Decimal classification. Either system can
be adopted for use by noting .the entry in the DN field.
The ongoing addition of new entries to the database will be the responsibility of both the
individual users and of the user group as a whole. Semi-annual updates containing new references
will be compiled from the entries of each participating program and redistributed for
incorporation into the GLTRL. This arrangement will provide an opportunity for each program to
benefit from the acquisition and cataloging of materials by other programs and avoid missing any
valuable references. . . ,
Programs thar would like to-obtain hard copies of references listed in the library are requested to
contact the publisher of the reference or a-local library. If a copy cannot be obtained from those
sources HWRIC may be able to provide copies of small documents. A search-only version of the
databases is available for companies and non-profit organizations. For more information on the
search only-version of the GLTRL, contact SHWEC.
Funding for the establishment of the GLTRL has been provided by the Solid and Hazardous
Waste Education Center and by a grant from the Great Lakes Protection Fund. Any citation of
the GLTRL should acknowledge both SHWEC and GLPF. The technical reference database has
been derived from the libraries of MnTAP and HWRIC. Any questions concerning the GLTRL
can be directed to: David s. Liebl
S&H Waste Education Center - Univ. of Wisconsin
610 Langdon Street - Room 531
Madison, WI 53703 491
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Designing a Training Program for Household Hazardous1Waste (HHW) Programs
Leslie C. Goldsmith
Minnesota Pollution Control Agency
PROGRAM DESIGN
Each HHW program must assess the practical and regulatory conditions that
exist in 'their community to determine training needs. A comprehensive
Household Hazardous Waste training program should have as its objective
ensuring safe operation of the program, compliance with all necessary laws
and efficiency of operation.
An evaluation of a program will lead to an understanding of the knowledge,
skills and abilities necessary to perform these tasks. Once a detailed list
of training objectives is established, the training program should be
designed to .ensure that each worker is competent, and aware of the areas in
which they are competent.
This paper discusses some general training concepts, as well as providing an
example of the analysis and rationale that led to the development of the
Minnesota Pollution Control Agency's safety training program.
STAGES OF COMPETENCY-BASED LEARNING
Once the minimum knowledge and standards of competency have been established
for a program, workers should be assessed for their competency in all ..
required areas. For safe and smooth operation, it is vital 'for the
supervisor or training manager to consider the competency of each worker
within a framework similar to the one described below. This can be complex,
because each worker may be at different stages with each of the many
necessary competencies in a HHW program. ' , , ..
Unconscious Lack of Competence
At this stage, a new worker is too unfamiliar with HHW to recognize unsafe
or illegal conditions, or understand that certain actions are unsafe. Even
if closely supervised, this worker may not recognize a situation that is
beyond their understanding, and fail to solicit"assistance from the
supervisor. For instance, a new worker would be unlikely to discriminate
between incompatible chemicals, and might not even be aware that mixing
chemicals .can have serious, dangerous results. There is no place for these
workers in the management of HHW, because they pose a danger to themselves
and the people that work with them. New workers must receive sufficient
training to move beyond this stage before they are allowed to handle ANY
waste. . •
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Conscious Lack of Competence
These workers are aware of the limitations of their knowledge, and can be
trusted to recognize situations beyond their competency. They must work
with close supervision.
Unconsciously Competent
Knows and follows procedures safely, without constant supervision, but is
not fully aware of the principles involved in the development of the
procedures. This worker is fully capable of safely and efficiently
performing the job and making necessary decisions, but may not be able
teach, supervise or design new procedures. .> '
Consciously Competent
This worker knows the job and understands the science and. principles that
underlie the procedures. This type of worker can teach, research, supervise
and improvise in the areas that they know.
DRIVING FORCES IN TRAINING PROGRAM DESIGN
Worker safety is the most important factor in a HHV training program, from
both a practical and a regulatory perspective. Handling'HHV can be
hazardous, due to the. wide variety of materials handled. The typical HHW ,
worker handles a wider variety of materials, than almost any other type of
worker, even those in jobs that are considered to have a great deal of
chemical use.
The primary regulatory force in .HHV .programs is occupational safety,
particularly the Hazard Communication Standard (HCS), or "Employee
Right-to-know." Explained simply, HCS requires an employer to provide each
employee with sufficient information to enable them to understand all of the
chemical and physical hazards associated with their job, and know how to
protect themselves from those hazards.
The cornerstone of HCS is the Material Safety Data Sheet (MSDS). The MSDS
is a standardized form that provides information on the safe use, hazards
and necessary protective equipment for a chemical or chemical product.
Employers are required to obtain and make these documents available to all
potentially exposed workers.
In a HHV program, many of the chemicals handled are of unknown age and
uncertain origin. This makes the provision of accurate MSDS for all
chemicals impossible. As a result, a'general competency approach must be
used to provide the necessary information on chemical hazards.
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Hazardous waste management is another vital area of training. In Minnesota,
operators of HHV programs are subject to almost all of the requirements
applicable to large-quantity generators, of hazardous waste. Because of
this, a thorough knowledge of state and federal hazardous waste rules is
necessary.
The Department of Transportation also has regulations that may be important.
In many cases, the shipment of collected household hazardous waste falls
under the requirements for the shipment of hazardous materials. These
regulations cover hazard classification, labeling and containers. In
addition, specified minimum training and qualifications for Hazardous
Materials Transport drivers will soon be applicable to transporters of HHW.
MINNESOTA POLLUTION CONTROL.AGENCY (MPCA) TRAINING AND TECHNICAL ASSISTANCE
The MPCA has three'primary training areas: Safety, program operation and
education. The MPCA has a variety of methods for the delivery of training.
They range from classroom presentations to one-on-one coaching and training
at HHW facilities with the operators.
The classroom training developed by the MPCA includes a three day safety
training program, a one day education training workshop and a four hour
training in the use-of a manual for providing HHW management advice by
telephone. The MPCA provides a variety of manuals, fact sheets, newsletters
and camera-ready public education information to complement these training
programs.
SAFETY TRAINING REQUIREMENTS
The remainder of this discussion will center on the safety training program,
as an example of an area in which- the MPCA assessed the requirements of the
job, the skills of the work force and designed a training •module to address
those needs.
The MPCA strongly recommends that a person responsible for the operation of
a HHW facility have at least two years of college level training in science
and chemistry. A four-year degree is preferred.
In many labor markets in Minnesota, this is not always feasible. As a
result, the MPCA has developed a system of training and assistance to help
HHW program operators in safely managing waste.
Our initial safety training is a twenty-four hour course adapted from the
program mandated for workers conducting emergency operations in hazardous
waste cleanup and response actions. This program has been tailored to
provide training and experience in situations that approximate those likely
in HHW operations. In order to to perform a job that includes the
unsupervised handling of the all HHW, a worker must have completed the
twenty-four hour course. This provides the worker with the minimum
knowledge required to address HCS issues for HHW. The outline of the
training is as follows:
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LECTURE >
Government Regulations: EPA & OSHA
Occupational Health & Toxicology
Toxicity/Hazard
Acute/Chronic
„ Dose/Response
*, Routes of Exposure
Exposure Limits
Identification of Hazardous "Materials
Material Safety Data Sheets
Labels
Hazard Hotline (A vendor, providing Right-to-know assistance)
'Reference Materials . . .
Chemical Groups
-Aller-gens(Sensitizers)
Corrosives and Irritants
Gases . .
•Pesticides '
. Solvents
Mutagens, Teratogens & Carcinogens
Biological and Physical Hazards
• Biological Agents
Radiation
Noise
Heat Stress
Medical surveillance
Flammable Chemicals
Reactive'Chemicals .
'Safety v ' '
Proper lifting .
Respiratory Protection
^Selection, Limitations and Use
Cleaning, Inspection and maintenance ...
Protective Clothing
Selection
Use ' '"".'•
Levels of Protection '
Identification and handling of Explosives
Safety Plans •
Emergency Procedures
First Aid and Spill Response
Decontamination
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EXERCISES
Fire Extinguisher Use & Live Solvent Fire Practice
Respirator.Fit Testing
Respirator Maintenance
Personal Protective Equipment Dress-out
MSDS & Chemical Reference Use
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Permanent Program Overview
by Carolyn Dann
With the help of many people around the country, we at the WWC gather together information
on all of the permanent facilities in existence. We have prepared a summary of each one, based on the
information we received, which will be available at the end of this session. From this information, I can
give you a bird's eye view of HHW programs with permanent facilities.
First, let me define "Permanent". To separate collection event type programs (i.e., one or multiple
day programs) from ones with a fixed facility, we at WWC define "permanent" programs as those with
a dedicated facility (either fixed or mobile) that is open to the public at least once per month, on most
months of the year. For this presentation, I will focus on fixed facilities and Jennifer will discuss mobiles.
Based on our surveys, we have seen a significant increase in the number of permanent facilities,
from 96 that we knew of as of last year to 128 as of this year. In our count of HHW programs being
held, we have counted each permanent facility as one program, although we recognize permanent facilities
offer more opportunities for collection than most one-day events. For fun, we have also calculated the
number of days of service the permanent programs provide. I would like you to guess the number -
15,772 days.
I do not know as much about any of them as you may know about those in your state but we have
looked at every state and can see enough to identify trends. I will be reviewing:'
• the major types of facilities,
the factors that influence the choice of type, •
• the types of construction used, and
• the major types of staffing options,
• overall trends, and
• some of my own favorite ideas and program options.
Types of Facilities
The major types of facilities, I have broken down into three categories: minimalist, medium-scale,
and full-service. The categories are defined by the types of activities the structure is designed to
accommodate. For example, the minimalist facility is one which has space storage, but little or no indoor
office space, lab space, bulking or reuse space. Communities in Florida have often used this model
because they can do much work outside. A good example of this is Brevard Co., FL, were they have a
prefab HHW storage building with a concrete pad in front, a prefab equipment shed, pallets outside for
latex paint, and a fence.
At the other end of the spectrum, a full-service facility has indoor space for all of possible the
HHW activities: receiving, storing, lab-work, office-work, consolidation, storing for reuse, and storing for
transport. Full-service structures can be either large or small. The extreme example of this is Anchorage
Alaska, which has 6,000 sq. ft. There are other good examples elsewhere where the climate is not so
extreme, such as the one in Yuba/Sutter, CA, which has a separate, heated work area attached to a large,
unheated bulking and storage area, for a total of nearly 3,000 sq. ft. Monroe Co, NY's facility is likewise
a large, full-service structure, encompassing 1,614 sq. ft for accepting, sorting and storing wastes, although
bulking is done outdoors. An example of a smaller version is the Franklin Co, KS facility, for which the
County built a 10' x 20' addition onto an existing building. It is equipped with a sink and sorting table,
safety equipment cabinet, full height shelves and room for 22 drums and supplies.
In between-the extremes, there is a wide range of variations, all of which have space for receiving
and storage, plus some bulking and testing areas and maybe an office nearby. These tend to have storage
capacity for fewer drums (15-20) than the minimalist versions (which have space for 20-40 drums) because
a portion of the facility is devoted to work space. The Ellis Co., KS facility is a good example of this
type. This is a 10' x 20' prefab concrete building with drums inside around three sides and a work table
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on the fourth side. . .
A fourth model has recently been developed, which can be described as an indoor-outdoor facility.
This type of facility is used in Montgomery County, MD, Spokane WA, and also in Tucson, AZ. The
sites have a roof covering a 20 ft. x 20 ft or larger area, walls consisting of brick or concrete half-way
up with fencing above, and epoxy-painted concrete'or paved floor.'. Inside the facility, there are several
storage units including one for flammable, one for supplies, and some administrative space either within
the facility or nearby.
*;! What Type of Facility Does My Community Need?
ju
There are many factors which determine the type of facility that is right for a community. I will
identify some basic ones, although the list is by no means complete. The most basic factors include:
level of service proposed/participation expected - if the facility is to be well advertised
and the sponsor anticipates 40-50 participants per week, the facility and the staffing level
will have to be designed accordingly. There should be a full time staff person to
coordinate the program and develop reuse and recycling opportunities. In addition, there
should be a second person available when accepting wastes and/or consolidating materials.
weather conditions - does the operator of the facility need protection from weather? This
is a function of both the climate and the number of hours and which months the facility
is likely to be open. Florida Counties have predominantly opted for the minimalist
version, often with protection from the sun. Minnesota, in contrast, has predominantly
opted for the medium or full-scale version facilities equipped with heat.
• location and staffing - if the facility is to be located at the landfill and operated with
landfill staff, and if there is already a gatehouse or office space, less new space is needed
for HHW. If the facility is to be run with additional County staff more often than once
per month, then work space, and ideally, bulking space need to be provided.
• existing space available - if there is space to retrofit or add on to an existing building, this
is often the least expensive option and may allow for efficient use of staff time too.
• budget - there appears to be only, a slight correlation between type of facility and cost.
:». My information comes as reported by each community and I have included data where
•r the community reported both building and site costs. The minimalist versions have cost
between $30,000 and $102,000 for the buildings, concrete pads, and site work. The
medium-scale facilities cost between $18,000 and $185,000 and the full-scale facilities
have cost as little as $20,000 for an addition and up to over $450,000 for a new structure.
What type of structure is the most cost effective?
There are many variations on the type of structure that can be used. The options used around the
country include: prefabs, pre-cast concrete structures, modified trailers or containers, retrofit existing
buildings, new construction of either cement block style or Butler building style, or a combination.
Prefabs
The most commonly used is the prefab hazardous waste storage unit. This has the advantage of
being available with all sorts of safety features and may save the expense of design engineering fees. This
type of space tends to be expensive (in the range of $109 to $195 per square foot) but is often used in
combination with some inexpensive outdoor space. It provides storage space but does not usually allow
for any work area (for bulking, sorting, or testing, or office work). The larger sizes are slightly more cost-
effective, but still are in the same range.
Pre-cast Concrete
Pre-cast concrete buildings have been used in at least three places for which I have information
and the cost for them seems to range from $63 to $75 per square foot, depending on the size of the
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facility. Like the prefabs, they can avoid much of the need for design engineering. They can be laid out •
to be used for storage only or for a combination of storage and some work space.
Modified Trailers or Containers •
Modified trailers and containers have been used by Southeastern Public Service Authority of "
Virginia, San Bernardino, CA and by Riley County, KS. These facilities are'long and narrow, but can
provide space for sorting, bulking, testing, and storage. The costs have ranged from $22 to $118 per •
square foot. SPSA's units are 8* x 8' x 20' or 40' in size. They are equipped with fiberglass grating, a I
containment area, a floor beim to divide the facility double doors at each end, a fan, light, eye wash and
safety equipment . •
Retrofits and Additions •
Where there is available space, good use has been made of it by retrofitting it or adding onto it
for an HHW facility. In some cases, the costs have been as low as $22-$45 per square foot. They have •
also been over $200 per square foot. ™
New Construction •
New construction has mostly been chosen in places where there was some other construction |
underway either for a transfer station or recycling center. The cost of new construction appears to be
similar to the costs of the prefabs on a per square foot basis, but the designs are more flexible are can •
provide more work space, office space and space for reuse areas. The costs experienced at four of the most |
recently constructed facilities ranges from $100 to $190 per square foot. In Spokane, WA, for example,
an "indoor-outdoor" type facility cost $140,000 for a 25' x 34' facility or $165 per square foot.
What are the Staffing Options
There is also a variety of staffing options possible, which I have again sorted into three categories,
ranging from maximum involvement of the contractor to minimal. I
Maximum Contractor Role
The first option is one that primarily on contractor staff. The municipal staff may be responsible for •
accepting some wastes and storing them until the contractor comes. The contractor is responsible for most gj
of the waste acceptance, plus the categorization, identification of unknowns, lab-packing, transportation,
and paperwork. . _
Medium Amount of Contractor Involvement |
The second option is to have the municipal staff trained to bulk flammable, used motor oil, and paints and
to do some of the lab-packing under the guidance of a contractor. The bulking reduces the number of •
drums required and saves some of the contractor's time. In most communities, the municipal staff time I
is less expensive than the contractor's hourly rate, but it's not true in all communities. In this scenario,
the contractor is responsible for identification of unknowns, the rest of the lab-packing and paperwork, •
plus transportation. m
Minimum Contractor Role
The third option is for the municipal staff to be fully trained to handle all bulking, lab-packing, and •
paperwork, and the contractor is primarily responsible for checking the lab-packing and transporting the
drums when they are full. _
Trends |
Although there are many variations in the size, function, construction type and staffing
arrangements for permanent facilities, there are also several trends that are of note. •
Think Big *
In general, the recent facilities are larger than the earlier ones and some of the earlier ones have expanded _
or wish they could. When the older facilities were asked what they would have recommend to others, they I
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said "think big". More of the new facilities are the full-service variety than was the case in previous
years, incorporating space for more than just storage. The indoor-outdoor facilities have provided that
most amount of space at reasonable cost
Trained Staff
More and more facilities, both existing and new ones, are using trained staff, fewer volunteers and
are relying less heavily on the contractor's staff.
- Appointments and Fees
Several programs are using appointments as a way of managing their costs, although no data is available
on the effect of this on participation levels. Some places have stopped using it because of complaints but
other programs have offered a combination of regular hours and appointments for those who can not make
the regular hours. Very few of the existing and none of the newest facilities are charging fees. In Larimar
County, Colorado, by dropping their fee they saw a dramatic increase in participation levels.
More drum space
The newer facilities need to accommodate more drums and the, minimum number of drums is
increasing as the level of sophistication increases and the degree of separation also increases. The
minimum number is now approximately 20 drums.
Satellites
Another trend is toward satellite facilities or satellite mobile programs. The satellite facilities are
simplified versions of a full permanent facility. Satellite mobile programs often do less consolidation on-
site than would a normal one-day event. They may collect materials to be consolidated at the permanent
facility. There are satellite facilities in San Bernardino, CA, Palm Beach, FL, Seattle, WA, Island County,
WA, Chittenden County, VT, and are planned for Wichita, KS. The use of satellite facilities helps offset
the problem that any permanent facility can not be nearby enough for everyone in the service area.
Satellite mobile units and satellite storage units offer the advantages of increased access for residents and
the opportunity to generate publicity and heightened local interest with the advantages of time to
consolidate and find alternate uses for materials that is best done at the central facility.
Collecting and Sharing Information
We and others are working towards developing a consistent means of reporting information so that
it is meaningful to others and as helpful as possible for you. To do so, we have encouraged programs to
collect information on the specific products that are received, especially those that get lab-packed. We
have found that programs know they are getting a large amount of pesticides but they do not have data
on types or actual quantities, only on the number of lab-packs.
*>.
My Own Favorite Ideas
My own collection of favorite ideas from the programs across the country include:
Separate building for flammable
• Acids and bases neutralized by WWTF
* Pesticides used by Parks & Rec Depts.
Materials Exchange Areas and Programs to Develop Markets
• Appointments and Hotlines for Public Education
• Promotion focus on "movers"
* Source Reduction focus on "movers and shakers"
• Satellite operations
As you develop your programs, we hope that you will be willing to share your start-up and
operational information with us and with others so that we can gain the benefit of your experiences. You
can rest assured that we will be calling you and sending you a survey so it will appear in next year's
compilation. Please also feel free to call us for more specific advice or references to people you can call.
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Mobile Permanent Programs
Jennifer Holliday
WHAT IS A MOBILE FACILITY?
1. Don't bring waste to permanent facility.
2. More than one site per year.
3. Not a one day collection event.
KNOWN MOBILE PROGRAMS IN THE COUNTRY
1. Carver county - Minnesota
2. Chittenden County - Vermont
3. King County - Washington
4. Riverside County - California
IP NOT A MOBILE FACILITY WHAT IS IT?
1. One day collection event
2. Satellite of permanent facility.
KNOWN SATELLITE COLLECTION FACILITIES IN THE COUNTRY
Detroit Michigan - 14 sites, 6 hours every Saturday, bring back
to permanent facility.
Wichita Kansas - 2 permanent sites open one day each per year.
Bring materials back to permanent facility.
Lake County Florida - Collections at mobile home parks upon
demand, Bring materials back to permanent facility.
Rutland Vermont - 11 sites, visit 3-4 sites for 1-2 hours every
Saturday. Bring materials back to permanent facility.
Tacoma Washington - 4 sites, open 100 days/year, bring materials
to permanent facility each night.
WHAT TO CONSIDER WHEN PLANNING A PERMANENT MOBILE PROGRAM
1. Cost $ Budget $$ Funding $$$ MONEY!
2. Permanent facility or not
3. State and local regulations concerning storage,
transportation & safety
4. Community Size; population and area
5. Site availability/Convenience/Visibility
6. Staffing
7. Mobility of unit
8. Storage
9. Length of time at each site// of sites
10. Length of season
11. Long term goals
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1992 Mobile Household Hazardous Waste Collection Programs
Location
Sponsor
Contact T.
Date Started
Type of Sites
Season
Time open
each site
Hours
Days Open/Year
Participation
Field Staff
Community
Size
Permanent Fixed
Facility
also Available
HHW Storage
Permits
Required
Capital Cost
Cost/Participant
92' Operational Budget
Funding
Amount Materials
Collected
Carver County
Minnesota
Carver County
Env. Services
Leslie Loeffler
(612)448-1217
September 1 992
(3) 1 day/year
1 home base
80X40' •
May-October
i* '*
1 day/year/site
1 7 days /home base
Sat 8- 12
20
220 to date
ave. 40/day
1 .5 in-house
Pop:48.000
359 sq. miles
no
(just home base)
Overnight
(on-site)
None
$30.000 .
NA
$131,000
Tip Fees
Solid Waste
21 (55 gallons)
5 (15 gallons)
Chittenden County
Vermont
Chittenden
Solid Waste
Jennifer Holliday
(802) 655-9801
October .1991
6-8 per year
permanent
45' X 65'
April-October
4-5 weeks/site
Wen&Fri 10-5
Sat 8-3
83
1.393 for 92'
ave. 20/day
1.5 in-house
Pop: 127,000
532 sq. miles
yes
Burlington
Overnight
(on-site)
State. Local
$55.000
$82/Participant '
$115.000
Tip Fees
Solid Waste
27 Tons
King County
Washington
King County
Solid Waste
Victoria Holt
(206) 296-4464
September 1989
24/year
various
6.000-1 0.000 sqft
Year-round
2 weeks/site
Thurs & Fri 1 2-7
Sat 10-5
^ 144
22.303 for 921
ave. 155/day
5 contractor
Pop:991.059
2,000 sq. miles
Yes
Seattle
TSDF
" Fire
none
(contractor)
$90/Participant
$2.000,000
Tip Fees
Sewer & Water
748 Tons
Riverside County
California
Riverside County
Health Services
Michael Shelter
(714) 358-5055
February 1990
6 sites/year
permanent
5,000 sqft
October-May
1 month/site
Tues-Thurs 9-1
(1 Sat/site 9-3)
100
3,800 for 91'
ave. 40/day
8-10 weekdays
1 0-20 weekends
in-house/contractor
1.1 million
No
Overnight '
(on-site)
None
$45.000
$1 86/Participant
$707,000
Tip Fees
Solid Waste
Not Available
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1992 Satellite Household Hazardous Waste Collection Programs .
Location
Sponsor
Contact
Date Started
Type of Site
Season
Time Open
Each Site
Hours
Days Open/Year
Participation
Field Staff
Community Size
Budget
(fixed & Mobile)
Tacoma • .
Washington
City of Tacoma
Public Works
Doug Pierce
(206)591-5543
March 1 992
4 sites/year
permanent
60' X 60'
February-November
2 weeks
(revisit site. 3X's
each year)
Tue-Sat 11-6
100
. 800 to date
ave. 10/day
1 in-house
Pop: 175,000
1 00 sq. miles
$810,000
Rutland
Vermont
Rutland County
Solid Waste
Steve Parker
(802) 775-7209
June 1 992
1 1 sites
permanent
Transfer Stations
March - November
1 - 2 hours
visit 3-4 sites
every Saturday
Saturday 8-5
approx. 40
300
1 in-house
pop:32,000
$132,000
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REGULATORY REQUIREMENTS FOR PERMANENT HHW FACILITIES
by
Judi Frantz
California Environmental Protection Agency
Department of Toxic Substances Control
Regulatory requirements for permanent household hazardous
waste programs vary greatly from state to state. These
variations are the basis for this presentation,', i.e., a.
comparison of some of the regulatory requirements in various
states. The particular requirements compared include: siting
criteria or limits; storage requirements; training requirements;
generator status; and whether or not a state permit or approval
is required.
The states compared include: California, Connecticut,
Massachusetts, Minnesota, New York, and Washington.
Siting criteria; three states -- California* Massachusetts and
Washington— have siting criteria;
California's siting criteria are generic, requiring that all
proposed sites conform to all local land use plans, building
codes and ordinances; the site must also be consistent with
the county's hazardous waste management plan (if that plan
has been approved by the state). While California primarily
relies on the local jurisdictions — since they will conduct
the programs — to determine appropriate sites, there
certainly is an expectation that good judgement will
prevail.
In Massachusetts, site approval is the first step of the
approval process. The applicant must submit sufficient
information to convince the state, that the site chosen "will
not cause a significant impact on public health, safety, the
environment, or drinking water supplies."
The State of Washington requires facilities to comply with
all of the location standards for a solid waste facility,
including geology (no holocene faults, etc.); Groundwater;
flooding; surface waters; slope; airports; critical habitats
(for both threatened and endangered species); buffer zones
(100' from the property line of a nonresidential property,
250' from the property line of a residential property, and
1000' from the boundary of all state and national parks);
and all sites must conform to all local land use plans,
zones and ordinances.
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Three states (Connecticut, Minnesota, and New York) do not I
have siting criteria per se, although two of the three
(Connecticut and Minnesota) do provide "guidance", and New York •
has "recommendations" for siting. I
Storage requirements and limits: in general, most states
appear to allow up to 90 days storage time at permanent I
facilities. There are the usual variations, though, such as •
Washington state where the storage time is indefinite.
Minnesota, on the other hand, will allow greater than 90 day " •
storage with state approval. California automatically allows the |
standard 90 days, but will approval longer storage times if they
are requested. _
Training requirements - in general moat states require the 40 *
hour OSHA training, the exceptions in this criteria being
Connecticut and Washington;
I
Connecticut does require a training plan and that all staff
be trained, including volunteers handling the hhw. •
Washington requires safety training for all staff and all
are required to be familiar with the hazardous waste
handling procedures. •
Generator status; this is one of the more interesting aspects
because this varies significantly across the U.S. •
In three states (Connecticut, Washington and California),
the generator is the local jurisdiction hosting or _
sponsoring the activities. I
In Connecticut, it's the contractor.
In Massachusetts, it can be just about anyone, i.e., the m
organizer, sponsor, contractor, public works department,
etc. •
In Minnesota, 50% of the programs are operated by the state,
so the state is the generator; in the remaining 50%, it's _
the program sponsor — usually the county. •
In New York, the generator is whoever fills in the *
"generator" blank on the manifest. •
State permit or approval - InConnecticut, 2 permits are
required; one to construct the facility and one to operate it. «
In Massachusetts, permanent facilities must obtain state
approval (but not a permit).
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In Minnesota, state approval, not a permit, is required if
storage will be greater than 90 days. Notification is more
extensive than for one-day events; an actual permit is
needed only if treatment or disposal will occur on-site.
In New York, 2 permits are required: one to construct and
one to operate.
In Washington, permits are required, but they are issued by
local health districts, not by the state.
In California, a state permit is required, but a recent
piece of legislation has created a whole new permitting
structure for hazardous waste facilities. The new structure
consists of five permit tiers which now will include
conditional exemptions, conditional approvals, permit by
rule, standardized permits'and full permits. Permanent
household hazardous waste facilities will be included in the
standardized permit tier. And since this legislation is so
recent, the details of exactly what that means are still
being worked out. • . ,. •
'• V f ' . •
Several other states - North Carolina, Pennsylvania and
Vermont, also have regulatory requirements for permanent
'household hazardous waste facilities. But I must be honest with
you and admit.that I ran out of time, haven't reviewed their
regulations and requirements, and have not included them in this
comparison. If there are representatives in the audience is from
any of these states, first I offer my apology. Second, you are
sincerely welcome to speak up and fill in the blanks.
' 1r*' ' , • *
Additional states appear-to *have-regulatory requirements,
and hopefully they can be included in this discussion at'next
year's conference. These states include New Jersey, Florida, .
Illinois, Texas, Oregon, Virginia, Wisconsin, Kansas, Tennessee,
Idaho and Nevada. The same apology is offered and the invitation
to speak up is extended to any representatives of these states
who may be in the audience.
In closing, I want to share an observation. It is simply
that in the last two years, the number of states that have
developed and/or implemented regulatory requirements for
permanent household hazardous waste facilities appears to have at
least doubled — maybe tripled. It will be interesting to see if
this trend continues in the future.
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i
Hard Surface Cleaning Performance of Six Alternative Household Cleaners as
Measured by Soil Removal and Microbial Reduction Under Laboratory Conditions
Wanda Olson — Department of Design, Housing and Apparel, Minnesota Extension Service I
Donald Vesley — Divison of Environmental and Occupational Health, School of Public Health _
Marilyn Bode — Department of Design, Housing and Apparel, Minnesota Extension Service
Polly Dubbel — School of Public Health I
Terry Bauer — Department of Design, Housing and Apparel, University of Minnesota
December, 1992 1
Many groups and agencies promote the use of alternative household cleaners because of the belief that •
they are environmentally preferable to commercially formulated hard surface cleaners. These alternative |
cleaners include food products such as vinegar or baking soda as well as cleaning and laundry aids such
as borax or ammonia. •
The "recommended uses" of most of the alternative cleaners are for general cleaning, but some |
of them are also recommended as alternatives for disinfectants. Household cleaners that are registered as
disinfectants must meet testing requirements of the Environmental Protection Agency (EPA) and it is •
recognized that the alternative cleaners do no meet this criterioa The purpose of this project is to test . |
and compare the efficacy of these alternatives using both soil removal and microbial reduction (which.
includes both physical removal and cidal action) as the evaluation criteria. These alternative products were _
tested as single ingredient products even though in actual practice some of them are mixed together in •
make-your-own recipes. . * •?
Several researchers have studied the role of contaminated surfaces in the home and the spread of
respiratory and intestinal diseases.. According to Gerba (in press), household surfaces can play a I
significant role in the transmission of viruses and bacteria-that-cause infectious diseases such as the ™
common cold and flu and intestinal diseases. Proper cleaning methods are a major defense against the
spread of these microbes because one is more likely to "pick up viruses from touching contaminated •
surfaces than from shaking the hand of someone who is infected" (Ansarsi, Sattar, Springthorpe, Wells •
& Tostowaryk, 1988).
An examination of over 200 homes in England documented the pattern of bacterial contamination I
in the home environment. Sites where cleaning methods needed improvement included hard surfaces and •
textile products in the kitchen and bath areas (Scott, Bloomfield, & Barlow, 1982). In a study of food
preparation in the household kitchen, work surfaces were identified as potential areas of contamination •
requiring disinfection (Borneff, Hassinger, Wittig, & Edenharder, 1988). The researchers were concerned •
that "housewives are content if their kitchen appears to be clean." There may be fecal contamination of
surfaces in homes with infants and toddlers and a recent study revealed contamination of surfaces in out-
of-home child care settings (Van, Wing, Morros, & Pickering, 1991).
Methods
This research is funded by the Minnesota Extension Service and the Minnesota Pollution Control Agency.
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The surface chosen for these tests was a high pressure decorative laminate. The material was cut into 6
inch by 17 inch sections (tiles). The center of each tile was artificially soiled with a simulated bathroom •
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soil or a simulated kitchen soil. A microbial agent (Serratia marcescens) was applied over the soiled
section. Alternative cleaning products and commercially formulated hard surface cleaners (referred to as
commercial cleaners in die remaining text) were used to clean the surface; the commercial products were
used as a point of reference. The ingredients as listed on the label of each product are found in appendix
1. Complete soil test methods are available from the authors. For bathroom cleaners, six tiles per
cleaning product were tested and for kitchen cleaners, ten tiles per product were tested.
The simulated bathroom soil test method was a modification of a method being developed by
ASTM. The soil mixture was applied to the sample surface by dipping a mini-trimmer paint applicator
into the mixture, then "painting' the mixture on the test surface. The soiled samples were heated in a 70°
C oven for one hour and were cooled overnight. Samples were tested for soil removal within one week
after soil application. The soil was comprised of the following:
4.5 g synthetic sebum 1.5 g super mix dirt
40.29 g sodium stearate 3.0 g stearate premix
0.6 g carbon black 259.71 g deionlzed water
The simulated kitchen soil was a modification of a fatty acid sebum soil. The soil mixture was
applied by adding 2.0 ml warm soil to each sample surface using a 10 cc syringe. A mini-trimmer paint
applicator was used to spread the soil. The soiled samples were dried and were stored for 12 days prior
to cleaning. The soil was comprised of the following:
20 g stearic acid 5 g paraffin
10 g CriscoR 160 g bandy black research clay
20 g palmitic acid 160 g isopropyl alcohol
10 g linoleic acid 10 g oildag
5 g squalene
The microbial agent was a 24 hour stock culture of Serratia marcescens, approximately lx!07/mL
concentration, diluted in Butterfields phosphate buffer solution to approximately IxlOVmL concentration.
This organism was chosen because it is relatively non-pathogenic to immune competent hosts and because
it forms a readily identifiable red pigment so that it can easily be distinguished from background microbes
on the surface. Thus a definitive picture of before and after counts can be obtained specifically related
to the cleaning product used. A sterile cotton-tipped applicator was used to apply 0.2 ml of the Serratia
marcenscens mixture to the soiled area of each bathroom tile and 0.5 ml to the soiled area of each kitchen
tile immediately prior to cleaning. RODAC plates contained Standard Methods Agar (SMA) with 0.7 g/L
lecithin and 5.0 g/L polysorbate 80 for general purpose neutralization. Three RODAC plates were applied
to soiled areas of each tile a) immediately after bacterial application and prior to cleaning and b) to the
soiled area immediately after cleaning except in those cases in which the cleaning product specified a five-
minute product contact period to allow disinfectant action, before and after sampling sites were mutually
exclusive to avoid interference (colony reduction)' attributable to the sampling method. The RODAC
plates were incubated at 25 degrees Centigrade for 24-36 hours then-counted using a Quebec Colony
Counter. Only red pigmented colonies were counted. At this dilution, all before cleaning plates were Too
Numerous To Count (TNTQ. Thus results and comparisons are based only on after cleaning counts rather
than on percent reduction, with the assumption that the initial inoculation was consistently applied from
the same stock culture for all cleaning products and therefore would not bias the results.
A Gardner Abrasion Tester was used to clean the soiled samples. For each test a cleaning product
was applied to the cleaning face of a new sponge which had been soaked in warm synthetic hard water
(referred to as water in the remaining text) to add 70 g water to the dry weight of the sponge. The
sponges (3.5 inches by 5 inches by 1.5 inches cellulose) had been previously washed and dried. The tester
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was set to complete a selected number of cycles, 50 for the samples with the simulated bathroom soil with I
microbial agent and 20 cycles for the simulated kitchen soil with microbial agent. The number of cycles
was based on trials to determine where obvious differences in cleaning ability between products could be •
observed. |
Alternative cleaners used in this research include not only food products but cleaning and laundry
aids other than hard surface cleaners (Lemeley and Wagenet, 1992). The types of cleaning products and •
their use concentrations are presented in Table 1. Products were used full strength or diluted according J
to manufacturers' directions for cleaning heavy soil. Four alternative cleaning products were used on the
simulated bathroom soil with microbial agent: lemon juice, vinegar, baking soda and borax. Two liquid •
commercial cleaners were used, one registered as a disinfectant and one that is not registered as a I
disinfectant. The alternative cleaning products used on the simulated kitchen soil with microbial agent
were lemon juice, vinegar, baking soda, household ammonia, and a hand dishwashing liquid. Three _
commercially formulated hard surface cleaners used; they include two liquids, one registered as a. •
disinfectant and one not, and a dry cleanser registered as a disinfectant. Water was used as a control.
The outcome data recorded for each cleaned sample were the number of Serratia marcescens
colony forming units (CPU) recovered after cleaning and an evaluation of soil removal. The cleaned I
samples were judged for soil removal by a panel of impartial judges. The samples, coded to avoid ™
recognition bias, were compared to a sample board portraying five different levels of soil removal. Each
test sample was independently evaluated by eight judges and assigned a soil removal score (SRS) from I
1 (greatest soil removal) to 5 (least soji removal). Statistical analyses of the data were conducted on the •
number of colony forming units on each RODAC plate and the soil reduction score for each tile.
Analyses performed included the analysis of variance and the Tukey Test. •
Results and Discussion
Microbial Reduction Application of the Tukey test for the difference in group means indicates different |
levels of effectiveness in microbial reduction. The effectiveness of the cleaners in both microbial
reduction and soil removal are reported in Table 2 for bathroom soil and in Table 3 for kitchen soil. For •
both soils there were significant differences in the microbial reduction within the alternative cleaner group |
but not within the commercial cleaner group.
Among the bathroom soil cleaners, the commercial cleaners, vinegar, baking soda, and lemon juice •
were more effective in reducing microbial counts than borax and water (Tukey analysis at alpha=0.05). I
Further application of the Tukey analysis to the low count group revealed that the two commercial cleaners
and vinegar had lower group means for microbial counts than baking soda and lemon juice. For kitchen _
soil cleaners, the same pattern emerged; the three commercial cleaners and vinegar were most effective •.
in reducing microbial counts. Water and ammonia exhibited intermediate results and dishwashing liquid
and baking soda were the least effective in reducing microbial counts. Lemon juice results were not
included due to a lab error (plate contamination) which resulted in too few observations. I
Microbial reduction results must be interpreted with cautioa It is clear that for both bathroom ™
and kitchen products, lowest microbial counts are achieved by the commercial products, whether or not
registered as a disinfectant However, vinegar (and to a less extent lemon juice) gave statistically similar •
results presumably because of its very low pH. Serratia marcescens is typical of gram-negative enteric •
bacteria which are known to be sensitive to acid conditions. Water and ammonia were in an intermediate
group; dishwashing liquid and baking soda yielded the highest microbial counts on the kitchen soil. One •
possible explanation for this phenomenon is that the detergency action of the dishwashing liquid and •
baking soda tended to break up clumps of viable cells to a greater extent and therefore resulted in high
colony counts although the actual number of viable cells was equivalent to the products with less •
detergency. •
It is also important to note that this sampling protocol does not distinguish between cidal action
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* •- • *'•* *
and physical removal in the lowering of viable counts. Previous research on dilute solutions of the
alternative cleaners, borax, vinegar, ammonia, and baking soda, has shown that they did not meet EPA
guidelines (cidal action) for registered disinfectants (Riibino & Bauer, 1992). The concentrations of the
alternative cleaners in the Rubino study were 16 to 32 times more dilute than those used in this study,
however. Although the commercial products and some of the alternative cleaners clearly resulted in fewer
colonies recovered from the tiles, transfer of the microbes to the sponge could have occurred but was not
tested. Thus attention to the cleaning mechanism'and ultimate fate of organisms physically removed but
not killed may be important as well as the absence of organisms from hard surfaces.
Soil Removal The results were tabulated as mean scores for 50 cleaning cycles for the bathroom soil
and for 20 cleaning cycles for the kitchen soil. With additional cycles, all cleaners may have had the same
soil removal scores. Using the Tukey test to test for the difference between the means resulted in several
groups of levels of effectiveness in soil removal (Tables 2 and 3). For soil removal under the test
conditions, there were significant differences within the alternative cleaner group for both the kitchen soil
and the bathroom soil. However, within the commercial cleaners, there were significant differences for
bathroom soil only. Because the bathroom soil was baked onto the tiles, it was a much more difficult soil
to remove.
For removal of bathroom soij, the high removal group consisted of one commercial cleaner
without disinfectant and the low removal group consisted of one alternative cleaner, vinegar. The
alternative cleaner with the best soil removal score was borax. The soil removal scores of the other
alternative cleaners, baking soda and lemon juice, were not significantly different from the commercial
cleaner with disinfectant
For removal of kitchen soil, ammonia, an alternative cleaner, was in the high soil removal group
with all the commercial cleaners; lemon juice and vinegar were in the low soil removal group. Baking
soda, dishwashing detergent (hand) and water were in separate intermediate groups.
Conclusions and Implications
In this laboratory study, alternative household cleaners were used to clean high pressure decorative
laminate surface soiled with simulated kitchen or bathroom soils over which a microbial agents had been
applied. The cleaners were then evaluated on their effectiveness in reducing microbial contamination, as
measured by the number of colony forming units cultured after cleaning, and their effectiveness in
removing soil. Because the simulated bathroom soil was a tougher soil to remove than the simulated
kitchen soil, the soil removal results are somewhat different for the two soil types. The cleaners used were
chosen to represent cleaners that are often recommended for cleaning bathroom or kitchen soils and were
compared with commercial hard surface cleaners used in those two areas.
The results indicate that compared to commercial cleaners, the alternative cleaners as a group are
less effective in both microbial reduction and soil removal. However, the alternative cleaners vary in their
effectiveness. Two alternative cleaners, borax and ammonia, were more effective in soil removal than the
other alternative cleaners. However, borax was not at all effective in reducing microbial contamination.
Vinegar was more effective in reducing microbial contamination than the other alternative cleaners but
was least effective in removing soil.
All of the cleaners, including water, could conceivably have removed the soil from the tiles with
enough cleaning strokes. Therefore, consumers who wish to use alternative cleaners may find them
effective in removing soil if they are willing to work harder. The microbial reduction in this research
could be the result of either cidal action or physical removal and transfer of the microbes to the sponge.
Washing the sponge with a disinfectant or drying the sponge will ultimately destroy the microbes.
Because the microbe used for testing in this research was susceptible to acid conditions, the acidic
cleaners, particularly vinegar, were effective in reducing microbial growth. For cleaning soil with these
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types of microbes, a vinegar rinse following cleaning with a more effective soil-removing alternative
cleaner, may be effective
in reducing microbial
concerns that prompt the use of cleaners that kill
contamination. 'However, when there are health-related
microbes, consumers should be aware that only registered
disinfectants have been tested using standard methods to show cidal action. This laboratory study is useful
in evaluating some differences among alternative cleaners. Further testing of these products needs to be
conducted in the home environment under conditions of consumer use.
Table 1. Cleaning
Cleaner
Synthetic
Hard Water
Alternative Cleaners
Lemon juice
Vinegar
Baking soda
Borax
Ammonia
Ivory Liquid" - hand
hand dishwashing liquid
Commercial Hard Surface
Spic and Span
with Pine"
Clorox Clean-up"
(registered disinfectant)
Comet Cleanser
with Chlorinol"
(registered disinfectant)
•
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Products and Use Formulations for Bathroom and kitchen Soils
Simulated Soil
Cleaned
Bathroom &
Kitchen
Bathroom &
Kitchen
Bathroom &
Kitchen
Bathroom &
Kitchen
Bathroom
Kitchen
Kitchen
Cleaners
Bathroom &
Kitchen
Bathroom &
Kitchen
Kitchen
Formulation
40m. -0 . 1 0g/L calcium carbonate
0.03g/L magnesium carbonate
warm deionized water
40ml undiluted
40ml undiluted
•
10g baking soda + 40ml water
10g borax + 40ml water
•40ml 1:1 dilution ammonia
with water
40ml 1:10 dilution Ivory Liquid"
with water
40ml undiluted
40ml undiluted
,,
1 0g Comet + 40ml water
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Table 2. Effectiveness of cleaners on bathroom
means (Tukey test alpha=0.05)
r
Cleaner ' Mlcroblal Reduction
Water Least effective
Alternative Cleaners
Lemon juice Intermediate
Vinegar Most effective
Baking soda Intermediate
Borax Least effective
Commercial Hard Surface Cleaners <
Without disinfectant Most effective
With disinfectant Most effective
soil as evaluated by differences In group
Soil Reduction
High intermediate
Low intermediate
Least effective
High intermediate
High intermediate
Most effective
Low intermediate
-
Table 3. Effectiveness of cleaners on kitchen soil as evaluated by differences in group means
1
1
1
1
1
1
1
1
(Tukey test alpha=0.05)
Cleaner Microbial Reduction
Water • Intermediate
Alternative Cleaners
Lemon juice (not included)
Vinegar Most effective
Baking soda Least effective
Ammonia Intermediate
Dishwashing Liquid Least effective
Commercial Hard Surface Cleaners
Without disinfectant Most effective
With disinfectant Most effective
Dry cleanser Most effective
with disinfectant
Soil Reduction
Low intermediate
Least effective
Least effective
High intermediate
Most effective
High intermediate
Most effective
. Most effective
Most effective
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Appendix 1 Description of Cleaning Products
Product Signal word on label
Ingredients listed on label
Baking soda: Arm & Hammer
Baking Soda"
Bleach with cleaner
Clorox Clean-up"
Borax: Mule 20teamR Borax
Cleanser: Comet" Disinfectant
Cleanser with Chlorinol"
Dishwashing detergent
Ivory"
Household ammonia
Parsons'" Ammonia
Lemon juice
Borden ReaLemon"
Liquid cleaner
Spic and Span Pine Cleaner".
Vinegar
Heinz Distilled White Vinegar"
Warning
(kills staph. strep, mildew, & athletes
foot fungus)
Caution
Caution
Caution
Sodium hypochlorite 2.0%, Inert
ingredients 98.0% (including non-ionic
surfactant and fragance).
Sodium, boron, oxygen and water.
Sodium dichloro-s-triazinetrione
dihydrate 0.9%, Inert ingredients:
calcium carbonate, sodium carbonate,
anionic surfactants, quality control
agents, perfume, color.
Cleaning and sudsing agents (anionic,
nonionic and amphoteric surfactants),
water, stabilizing agents (ethyl alcohol),
and aesthetic agents.
Ammonium hydroxide solution, nonionic
surfactant, perfume, color, clarifying
agent, salts (inert). Contains no
phosphorous.
Water, lemon juice concentrate lemon
oil, 1/4Qth of 1% sodium benzoate
(preservative), 1/40th of 1% sodium
bisulfate (preservative).
Cleaning agents (anionic surfactant and
pine oil), water softening agents
(sodium citrate), quality control agents,
water, color and perfume.
Sun-ripened grain, diluted with water to
a uniform pickling and table strength of
5% (50 grains) acidity.
References
Gerba, Chaiies (in press). Meeting consumer needs for health, Detergents in Depth. 92. Proceedings from
the video conference, Cleaning Products...In Our Homes, In Our Environment, April 1992. SDA,
NY.NY.
Ansari, S.A., S.A. Sattar, V.S. Springthorpe, G.A. Wells and W. Tostowaryk (1988). Rotavirus survival
on human hands and transfer of infectious virus to animate and nonporous inanimate surfaces.
J of Clinical Microbiology. 26:1513-1518.
Bomeff, R., Hassinger, J. Wottig and R. Edenharder (1988). Distribution of microorganisms in household
kitchens II. Communication: Critical evaluation of the results and conclusions. Zbl. Bakt. Hyg.
B 186:30-44.
Robino, J. and J. Bauer (1992). Antimicrobial activity of environmentally "green" products. Abstracts
of the Annual Meeting of the American Society of Microbiology. New Orleans, LA.
Scott, E., S. F. Bloomfield and C.G. Barlow (1982). An investigation of microbial contamination in the
home1. J Hvg. Camp.. 89:279-293.
Lemley, A. and L. Wagenet (1992). Household Cleaning Products — What About Substitutes? Cornell
Cooperative Extension, Cornell University, Ithaca, NY.
Van, R., C.C. Wien, A. Morrow, and L,K. Pickering (1992). The effect of diaper type and overclothing
on fecal contamination in day-care centers. JAMA. 265(14): 1840-1844.
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Nonchemical methods of pest control in and around homes1
-.- Bh. Subramanyam and R. P. Wawrzynski
Department of Entomology
• Cooperative Extension Service
University of Minnesota
St. Paul, Minnesota 55108 •
Abstract
Insects and insect relatives are the most commonly encountered pests in and around
homes. Several simple nonchemical methods can be used for control of these pests.
Nonchemical methods such as sanitation and exclusion are effective in eliminating or
significantly reducing incidence of a wide variety of pests. The use of bacterial
insecticides, horticultural oils, insecticidal soaps, baits, and traps are effective against a
limited number of pests. An understanding of the pest biology, ecology, and behavior is
essential for effective use of nonchemical control methods. An overview of nonchemical
methods and the pests impacted by each method are discussed.
Introduction
Pesticides are substances or a mixture of substances used for destroying,
preventing, repelling or mitigating pests. Pesticides also include substances intended for
use as plant growth regulators, defoliants, or desiccants. Substances derived from living
(e.g., plants, bacteria, and fungi) and nonliving entities (elements) are included under the
definition of pesticides. Pesticides used against insects are called insecticides, and those
used against weeds, fungi, rodents? and birds are' called herbicides, fungicides,
rodenticides, and avicides, respectively.
Pesticides are commonly used for pest control in and around homes, because they
are easy to apply, fast-acting, and effective against a wide variety of pests. A recent survey
estimated that nationally 85% of homeowners store at least one or more household pesticide
products (Whitmore et al. 1992). A 1979 United States Environmental Protection Agency
survey estimated that annually 'about 87 million pounds of pesticides are used in and around
homes (U. S. Environmental Protection Agency 1979). About 43 and 32% of the 87
million pounds used were insecticides and herbicides, respectively; the remaining 25%
constituted fungicides, rodenticides, disinfectants, and other chemicals. Insecticides are
commonly used in and around homes, because most homeowners consider insects and
insect relatives (e.g., mites, spiders, centipedes, and millipedes) (see Fig. 1) as pests or as
a nuisance, especially if they occur indoors. Of the 440 home dwellers surveyed in
Minnesota, about 65% indicated that they tolerated insects found outdoors, and 26%
indicated that they disliked insects (Hahn and Ascerno 1991). Conversely, about 8 1% of
the same home dwellers surveyed disliked indoor insects, and only 13% indicated any
tolerance toward insects inside their homes.
The information presented here is for educational purposes only. Mention of product or
trade names does not imply recommendation for use by the University of Minnesota.
includes rented or owned dwellings. In this article, the terms "homeowners",
"home dwellers", "residents", and "public" are used synonymously.
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Pests found in and around homes
Insects and insect relatives that are frequently encountered outdoors in Minnesota
are: ants, mosquitoes, spiders, bees, wasps, flies, black flies, centipedes, carpenter ants,
millipedes, sowbugs, pillbugs, boxelder bugs, ticks, crickets, aphids, daddy-long-legs,
and mites (Hahn and Ascerno 1991). Some of these same organisms (e.g., daddy-long-
legs, spiders, sowbugs, millipedes, and centipedes) become pests when they seek
harborage indoors and cause concern to residents. In addition to the invertebrates listed
above (including fleas and pantry pests [sawtoothed grain beetle, red flour beetle, rice
weevil, and Indianmeal moth]), vertebrates such as rodents, bats, and birds (Fig. 2) also
become pests when they seek refuge indoors. Information on identification and biology of
the invertebrate and vertebrate pests can be obtained from Ware (1988).
Both the invertebrate and vertebrate pests enter homes through openings in
foundations and walls, and through open, unscreened or broken doors and windows.
Some invertebrates are brought indoors on infested plant or food materials. If
environmental and nutritional requirements for these pests are not met indoors, they may
perish. Other species may thrive well indoors because of stable and suitable environmental
conditions, abundant availability of food, and absence of natural enemies. Some species
enter homes to escape unfavorable environmental conditions outdoors. For instance,
boxelder bugs, cluster flies, and elm leaf beetles overwinter indoors until conditions
outdoors become conducive for their survival.
Reasons for pest control
Homeowners apply control measures against outdoor and indoor pests because they
dislike presence of pests, prefer to maintain a pest-free property, and want to eliminate
pests that transmit diseases (e.g., cockroaches, ticks, flies, etc.). Several chemical and
nonchemical approaches are effective in controlling pests outdoors and indoors. However,
nonchemical methods are now becoming popular because of the public's concern regarding
effects of pesticides on humans, animals, and the environment. The use of pesticides also
leads to development of resistance in pests, resulting in ineffective control at recommended
label rates. Several simple nonchemical methods, if used properly, can effectively reduce
pest incidence and abundance in and around homes. In this article, we give an overview of
the main nonchemical strategies and pests affected by the strategies. Additional information
on nonchemical strategies for control of individual pests can be obtained from Olkowski et
al. (1991) and Lifton (1991). .
Nonchemical methods of pest control
Several nonchemical methods exist for control of pests in and around homes (see
Olkowski et al. 1991, Lifton 1991). The range of nonchemical options available may vary
with the pest, pest intensity or severity, and effectiveness of the option. Here, we discuss
several key nonchemical options that may help reduce the amount of pesticides used in and
around homes. However, it is important to realize that for effective use of nonchemical
methods, an understanding of pest biology, ecology, and behavior is essential. Such an
understanding is not always required when using synthetic pesticides.
, Exclusion: Any measure used to prevent entry of organisms indoors through
openings in the building structure, doors, windows, or on infested plant or food materials.
Some techniques include screening openings to prevent entry of flies, mosquitoes, and
beetles; caulking cracks and crevices to remove harborages of pantry pests and
cockroaches; and sealing or repairing openings to prevent entry of bats, mice, bees, and
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• t'.' -S I-" .". VW-"' "f|^v •
wasps; Plants and food products must be carefully inspected for infestations at the time of
purchase and before they are brought indoors.
Sanitation: Maintaining clean surroundings both outdoors and indoors removes
potential areas where pests can feed, breed, and hide. Sanitary measures include,
disposing garbage on a weekly basis during warm weather to control filth flies and
cockroaches; discarding overripe fruits to control fruit flies and fungus beetles; removing
bird nests as these harbor dermestids and clothes moths; and vacuuming to reduce
populations of fleas, carpet beetles, and several ground-dwelling insects and insect
relatives. It is also important to keep kitchen areas clean to cut down incidence of pantry
pests and cockroaches.
Habitat modification: Includes any method used to eliminate or disrupt areas
where pests reside. For example, removing weeds and keeping well-mowed lawns
reduces incidence of crickets and ticks. Removing debris and fallen leaves near
foundations reduces sowbug and centipede populations. Wood or wooden piles, where
carpenter ants and ground beetles seek harborage, must be stored away from structures.
Creating a vegetation-free barrier around the perimeter of the building will reduce incidence
of many ground-dwelling pests such as clover mites. The-use of dehumidifiers is
recommended, especially in basements, to create an unfavorable environment (dry
environment) for sowbugs, centipedes, firebrats, and dust mites.
Temperature control: Artificially manipulating the temperature of substrates
infested by pests or areas where pests residue, is.an inexpensive nonchemical strategy.
Pantry pests, clothes moths, and carpet beetles can be'eliminated by subjecting infested
foods, clothes, and carpets, respectively, to extremely hot or cold temperatures. In
general, to kill all developmental stages of pantry pests, clothes moths, and carpet beetles,
exposure to temperatures below 0°C and above 40°C for several hours to several days are
needed. " • .
Physical and mechanical control: A rolled newspaper or magazine and fly
swatters are some tools used for killing visible pests. On infested plants, hand-picking
insects is a partially effective means of control (e.g., tomato hornworm). Infested leaves
must be excised from plants, bagged, and discarded.
Bacterial insecticides: To control larvae of moths and butterflies (caterpillars),
larvae of mosquitoes and black flies (maggots), and larvae of beetles (grubs), three
different varieties of the bacteria, Bacillus thuringiensis, are available. The varieties
kurstaki', israelensis, and son diego are effective against caterpillars, maggots, and grubs,
respectively. The larvae succumb to the bacterial toxin after ingesting the treated substrate.
For controlling Japanese beetle grubs on lawns, the use of Bacillus popillae may offer
some control. Recent evidence suggests that caterpillars can develop resistance to the B.
thuringiensis endotoxin(s).
Baits: Consist of one or more food materials baited with a selective insecticide to
kill pests attracted to the bait Boric acid (2 parts to 98 parts bait [jelly, peanut butter]) is
effective in killing ants. For pantry pests, the use of wheat germ plus mineral oil bait is
effective in drawing insects out of their hiding places into the bait. The bait must be
presented.in a small shallow cup or a dispenser. The oil kills trapped insects by suffocation
(by clogging spiracles or exterior openings along sides of the insect body that facilitate
breathing).
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' Traps: Traps are escape-proof devices that capture highly mobile and. active pests.
Live traps can be used for rabbits, pocket gophers, and squirrels. Unbaked sticky traps
such as red spheres, resembling apples, are useful for trapping apple maggot adults.
Sticky traps can be baited with commercial lures (pheromones and food attractants) to
enhance trap catch. For example, there are sticky traps baited with lures available for
pantry pests, wasps, and flies. Colored sticky traps are effective in capturing whiteflies
and aphids. Traps are useful in.early detection and continuous monitoring of infestations.
They are not effective in reducing populations unless the trapped population is isolated or
confined to a small area. Pests must be active or mobile to be captured in traps. Therefore,
any environmental or biological factor that affects pest activity affects trap catch.
Consequently, absence of pests in traps does not imply that the pests are absent in the area
sampled with traps.
Diatomaceous earth: Several diatomaceous earth formulations are commercially
available. These formulations contain dead skeletons of sea diatoms of various shapes and
sizes (<5 to 15 microns). Diatomaceous earth kills arthropods by absorbing lipids on the
cuticle (integument or skin) and by lacerating the cuticle. Water loss through the cuticle
resulting from lipid absorption and cuticular lacerations leads to death. It is also plausible
that the small diatomaceous earth particles may suffocate arthropods by clogging their
spiracles. Diatomaceous earth formulations are most effective on soft-bodied'insects.
Because the mode of action is physical, arthropods may not have the ability to develop
resistance to this natural product.
Insecticidal soaps: Soaps, are sodium or potassium salts of fatty acids combined
with fish or vegetable oils. These soap solutions have insecticidal value, because when
applied to soft-bodied insects, they penetrate the cuticle and dissolve cell membranes. As a
result, the cells collapse and leak, leading to dehydration and death. Any commercial
laundry detergent can be used at a rate of 1/2 cup per gallon of water on soft-bodied insects
such as mealy bugs and aphids. Safers soap solution is a commercial formulation that is
shown to be effective 'on aphids, caterpillars, fleas, mealybugs, scales, and whiteflies.
Horticultural oils: Horticultural oils are highly refined petroleum-based oils.
When applied directly on insects, the oils kill insects by asphyxiation (i.e., by clogging
spiracles). Oils are effective on soft-bodied insects such as aphids and mealy bugs.
Botanicals: Are essentially plant-derived chemicals. Some of the common
botanicals are: pyrethrum, neem, ryania, red squill, derris, nicotine, rotenone, limonene,
and sabadilla. Different botanicals have different modes of action, and some botanicals'
have multiple modes of action. For instance, the component most active against insects in
neem is azadirachtin. Azadirachtin is an effective feeding or oviposition deterrent, and also
disrupts normal development of insects. Some botanicals are highly toxic, and their
toxicities are similar to some synthetic pesticides. The LDsos (lethal dose that kills 50% of
test animals) of ryania, nicotine, red squill, and pyrethrum range between 0.7 to 200 mg/kg
(Olkowskietal. 1991).
Miscellaneous techniques: Pantry pests have the ability to puncture and
penetrate paper and cardboard materials. Therefore, storing cereal and cereal products in
tight plastic or tupperware containers instead of the original paper or cardboard holders .
prevents infestation by pantry pests. In order to avoid black fly bites, wear light-colored
clothing that completely covers exposed areas of legs and hands. If mosquitoes are
abundant outdoors, reduce activity to 1-2 hours. Dry cleaning clothes may eliminate
clothes moth infestations.
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Parasitic and predatory insects (Fig. 3) are now commercially available to control
garden pests. For example, ladybird beetles are voracious predators of aphids. The degree
of control achieved with the use of parasitic and'predatory insects is variable, and the cost-
effectiveness has not been well-documented.
Ultra sound devices and light traps are two nonchemical control measures that are
not very effective in suppressing pest populations.
Keys to successful nonchemical pest control
Identifying the pest is the first step in controlling it, because information on the pest
biology, ecology ,and behavior can be easily obtained if the pest is correctly identified.
Contact your local Cooperative Extension Service office if you need help in identifying a
pest and for additional information on the pest. Most nonchemical controls work well at
low pest population densities. Therefore, it is important to detect pest problems early.
Careful visual inspections or the use of traps can help in early detection of infestations.
Some stages of pests are most susceptible to nonchemical controls, and the nonchemical
controls must be timed to target that stage. For instance, the bacterial insecticide, B.
thuringiensis variety kurstaki is effective on younger caterpillars; the bacteria has no effect
on eggs, pupae, and adults. Therefore, it is important to apply the bacteria when small-
sized caterpillars are present on the foliage. Repeated applications may be necessary to
obtain additional reductions in populations of the susceptible stage in the same or future
generations. Pesticides must.be used only as a last resort Pesticides can complement
nonchemical methods where needed. Please follow label directions and rates when
applying pesticides. Parasitic and predatory insects can be used where pesticides are
discontinued or were not previously used, because these beneficial'insects are highly
susceptible to pesticides.
The combined use of nonchemical and chemical control tactics, with favorable
economic, social, and environmental consequence's is called Integrated Pest Management
(IPM). The use of IPM practices for controlling pests in and around homes is important if
we are to reduce introduction of pesticides into the environment. If we better understand
and appreciate the creatures that live in and around our homes, we may be able to reduce
pesticide use by being content with the degree of control attained by using nonchemical pest
control methods. <
• •' References
Hahn, J. D. and M. E. Ascerno. 1991. Public attitudes toward urban arthropods in
Minnesota. American Entomologist 37:179-18fC *
Lifton, B. 1991. Bug Busters. Avery publishing Group, Inc., New York. 254 p.
Olkowski, W., S. Daar, and H. Olkowski. 1991. Common-sense pest control. The
Taunton Press, Connecticut. 715 p.
U. S. Environmental Protection Agency. 1979. Pesticide industry sales and usage, 1979.
Market Estimates. Office of Pesticide Programs. Economic Analysis Branch. U. S.
Environmental Protection Agency, Washington, D. C.
Ware, G. W. 1988. Complete guide to pest control - with and without chemicals. Second
edition. Thomson Publications, California. 304 p.
Whitmore, R., J. E. Kelly, and P. L. Reading. 1992. National home and garden pesticide
use survey final report, Executive Summary. Research Triangle Park, North
Carolina. 22 p.
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518
Fig. 1. Some invertebrate pests found in and around homes.
Toinalo Hornworm
•Elm leaf beetle
Cabbage Looper. A — Mature larva; B — Adult.
Young Larva
Pupa
Adult
Adult . . Larva
Japanese Beetle (Popillia japonica)
Mealybug Adult Female
Whitefly. A — Nymph; B — Adult.
Aphids _ Wingless and
Winged
Bold-faced hornet
Darkling Beetle
nestica
House Fly
Firebrat
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Fig. 1. (continued)
P. .„ ., Saw -Toothed
Rice Weevil Grain Beetle
Pantry pests
Webbing Clothes Moth
Tineola bisselltella
Mosquito
Insect relatives found in and around homes
Sowbug
House Centipede
Common Centipede
A Spider Mite
Black Widow ' Brown Recluse
Spiders
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Fig. 2. Some vertebrate pests found in and around homes.
Htilm
DOMESTIC
tuts
MARSH BABBIT
Crow
HOUSE SPARROW
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TREE
SQUIflHELS
Fig. 3.. Examples of some beneficial (parasitic and predatory) insects.
(predator)
Parasitic Wasp
A. Uirva, H. Ad»
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AVAILABILITY AND EFFECTIVENESS OF ALTERNATIVES: ARTISTS' MATERIALS
Angela Babin, M.S.
Director, Art Hazards Information Center
Center for Safety in the Arts, New York, NY 10038
Introduction
The Art Hazards Information Center answers about 12,000 inquiries per year from artists,
performers, teachers, parents, schools, museums, health professionals and government agencies. These
questions range from firstly, the identification of chemical hazards of products - to secondly,
recommendations for safety precautions such as ventilation - to finally, safe waste management options
for unwanted or "used-up" artist waste.
Last year, I presented information on the hazardous constituents of artists' materials. Artists
use a great variety of chemicals in many different processes. Most artists "use-up" the material they
work with; but they can sometimes produce waste requiring some type of waste management.
The critical step in waste management options is understanding materials and the determination
if the materials are indeed hazardous. To know what ingredients are .in artists' materials, one'must
either read the label, or consult the manufacturer and get the Material Safety Data Sheet (MSDS). On
October 9, 1992, the Consumer Product Safety Commission (CPSC) issued its final rule on labeling
requirements for art materials presenting chronic hazards (Federal Register, pp. 46,626-46,674). The
rule codifies the voluntary standard ASTM D-4236 with some changes as a CPSC rule [16 CFR
1500.14(b)(8)], as mandated by the Labeling of Hazardous Art Materials Act of 1988. While labels
must now give information on materials with chronic as well as acute hazards, the MSDS provides the
most information.
Types of Hazardous Waste -
There are several categories of chemicals used by artists and schools that come under
regulation as hazardous waste. These include:
Toxic Waste Chemicals: e.g. solvents, formaldehyde, lead compounds, mercury, chromates, etc.
Flammable Waste: e.g. flammable and combustible liquids with flashpoint < 140° F, solids that can
cause fire through friction, absorption of moisture, or spontaneous combustion, ignitable compressed
gases, and oxidizing substances like potassium chlorate and concentrated nitric acid.
Corrosive Waste: e.g. wastes with a pH < 2 or > 12.
Reactive Waste: e.g. cyanide or sulfide wastes which can generate dangerous amounts of toxic gases
between pH 2 and 12.5, unstable compounds such as methyl ethyl ketone peroxide.
Acute Hazardous Waste: e.g. arsenic compounds, hydrogen cyanide and cyanide salts, many
pesticides, vanadium pentoxide, etc.
Leachable Toxic Waste: e.g. materials that can leach into water more than specified levels of the
following metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver, to
addition, leachable levels of other chemicals are regulated, including benzene, cresols, p-dichloro-
benzene, methyl ethyl ketone, pentachlorophenol, perchloroethylene, trichloroethylene, and several
pesticides.
Miscellaneous: Other classes of hazardous waste, not normally encountered by artists may include
radioactive materials and pathological, e.g. viral or bacteriological waste.
Regulations
RCRA
In the United States, the Environmental Protection Agency (EPA) regulates the disposal of
hazardous waste under the Resource Conservation and Recovery Act (RCRA). Industrial wastewater
discharges are regulated under the EPA Clean Water Act Subtitle C of RCRA regulates the
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management of hazardous waste through its "cradle-to-grave" system of regulations for the
identification of hazardous waste and generators, amongst other requirements. This waste manifest
system tracks hazardous waste through generation, transportation, and disposal.
The responsibility for administering RCRA rests with the individual states. While most of the
states' hazardous waste programs directly resemble RCRA, contact individual state environmental
offices to elucidate particular differences.
Hazardous Waste Generators
There are different categories of hazardous waste producers, under RCRA, 40 CFR Pan 261.
The basic distinctions center around the amounts of hazardous waste produced. These categories are:
Large Quantity Generators (LQGs); Small Quantity Generators (SQGs); Conditionally Exempt Small
Quantity Generators (CESQGs); and those home artists considered Household Hazardous Waste
Generators (HHW).
There is a grey area surrounding the boundaries that define artists and their working scenarios.
For example, an artist who has a separate studio may not be eligible for disposal of unwanted
materials at a household hazardous waste collection program. Likewise, homeowners, gardeners and
artists who bring in suspiciously large amounts of materials to a household hazardous waste collection
program may be turned away from services because their quantities resemble those of businesses,
small farmers, and commercial art businesses.
CWA
The EPA has developed categorical and pretreatment regulations that establish the basis for
wastewater management under the Clean Water Act of 1977. Each municipality develops and enforces
programs regulating sewer and wastewater treatment. For specific information on local regulations,
one must consult the local Public Works and own Department of Environmental Protection.
Most artists won't produce liquid wastes in amounts that are relevant to these regulations. In
. fact, to qualify for status as a "significant industrial user," one must discharge at least 25,000 gallons
per day of wastewater (excluding sanitary wastewater), or contribute a waste stream that accounts for 5
or more percent of the hydraulic or organic capacity of a publicly owned treatment works (POTWs),
or as especially designated by the municipality. Large photographic processing studios and large
electroplating studios are examples of businesses that may need comply with this law. University arts
programs or community arts facilities may produce amounts of aqueous waste that are covered in the
pretreatment regulations discussed below.
There are categorical standards for 21 industries, including:
Part 413 - electroplating Pan 433 - metal finishing
Part 449 - paint manufacturing Part 447 - ink manufacturing
Part 459 - photographies Part 463 - plastics molding and forming
Part 464 - metal molding and casting Part 466 - porcelain enameling
which are only relevant if there is direct discharge to a water body.
The federal Water Pollution Act of 1972, and the Clean Water Act were require that requires
that POTWs (sewage treatment plants), establish local pretreatment programs to ensure compliance.
There are also restrictions on the discharge of. pollutants with certain characteristics into a sewage
treatment plant:
Sewer Codes
It is impossible to present all the municipal sewage regulations here. Those concerned must
contact their municipal Public Works Offices for details on the regulations.
DOT and Transportation
Shipments of hazardous wastes off-site are regulated by both the EPA and Department of
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Transportation (DOT). DOT requires that wastes be segregated by hazard class.
EPA requires that off-site shipments of hazardous waste must be accompanied by a "Uniform
Hazardous Waste Manifest", which is a shipping paper used to track the waste. The manifest
documents the "cradle-to-grave" requirements, and contains the name and address of the generator, the
receiving facility site, and all transporters, along with a listing of all hazardous wastes in the
shipments. All personnel handling the wastes must sign the manifest. Large quantity generators must
have certification regarding waste minimization including programs to reduce the volume, quantity and
the toxicity of the wastes. Similarly, small quantity generators must sign such a statement.
Containers used for transporting wastes over public streets and highways must meet DOT
requirements for construction, compatibility with contained material, and tightness. .
Methods of Waste Management
A hierarchical arrangement of the waste management options - starting with the most desirable is
as follows:
1. waste elimination or reduction at the source;
2. waste separation and concentration;
3. waste exchange;
4. energy and material recovery;
5. incineration or treatment;
6. secure land disposal.
I have slides of actual artworks, that demonstrate these waste management efforts.
Waste Elimination or Reduction
The best way of managing hazardous waste is to actually eliminate or minimize its production.
Artists, and even schools and teachers, can substitute lesser toxic materials. Waste elimination and
minimization often correlate with the reduction in the environmental and occupational toxicity. Sub-
stituting lead-free glazes instead of leaded glazes results in the elimination of lead that enters the
environment, via kiln fumes (health and air hazard), and also in discarding unwanted or waste material
(as hazardous waste). Since lead-glazed pottery is not fpodsafe, lead glazes cannot be donated because
of the hazards involved. The following slides snow: a vase glazed with red lead, a bowl (not food-
safe) glazed with a barium glaze, and a mug glazed with manganese and cobalt. Another way to
eliminate waste is to alter process. The next two slides show small brass and copper sculptures that
have been riveted together with miniature bolts, rather than using solders. Under the RCRA regula-
tions, if one discards materials made with toxic solders, they are not regulated, but scraps inevitably
generated in working the pieces are. This artist has eliminated the generation of scrap solder.
The next three slides show a similar landscape painted with three different palettes. The first
painting uses typically seventeenth- and eighteenth-century colors, including: lead white; vermillion
(mercuric sulfate); gamboge (tree resin); red lake; red iron oxide; and smalt (blue). The painter chose
not to work with samples of realgar, a popular color of that time that is a sulfide of arsenic.
The second painting of this series utilizes nineteenth- and early twentieth-century colors,
including: cadmium reds; cadmium yellows; cobalt blue; cobalt green; and Prussian blue. The third
painting'shows twentieth-century synthetic organic colors, that are generally much safer including:
naphthol reds; Hansa yellows; new phthalcyanine greens; new phthalcyanine blues; and dioxazine
purple. Also shown is an abstract painting done with synthetic organic pigments showing different
qualities of these water-based paints.
Waste Separation and Concentration
If one cannot reduce the actual amount of hazardous waste being produced, the next step is to
keep hazardous waste from "contaminating" regular garbage. In this way, the waste streams remain
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separated. An example of this is keeping separate used and unwanted solvent-based and water-based
paint. Sometimes wastes can be combined in an advantageous manner. For example, mixing dilute
solutions of spent photographic developer (basic pH) with dilute solutions of spent photographic stop
baths (acidic pH) can result in neutralization of both.
Waste Exchange and Recycling
There arc two types of recycling methods, which can be described as internal or external
approaches. Internal recycling involves individual re-use of material. Mineral spirits and other
solvents used for thinning, washes, and cleanup in oil painting can be allowed to settle, strained and
decanted through a cheesecloth (to remove the solids), and finally, be re-used. Internal recycling is
usually going to be extremely cost-effective.
External recycling involves actually passing unwanted materials on to someone else who can
use them. What is refuse to one may be sustenance to another. For example, leftover art materials
can be donated to an art center or secondary school. Note that hazardous materials should never be
donated to elementary schools, and highly toxic materials like lead glazes should not be recycled. The
next slide shows a large-scale installation, placed at an abandoned site of an iron ore factory. This
environmental piece consists of the construction of red-hued mounds, of iron-rich and unwanted earth
that visually contrast and complement with the green mountainous surroundings.
Many Household Hazardous Waste Collection Programs (HHWCPs) have set up paint and
other material collection and exchanges from HHW generators and sometimes for CESQGs too. For
example, an HHWCP in Santa Monica, California operates a materials exchange service in which the
participants can take usable products that have been collected, such as paints, thinners, adhesives,
etchants, etc., for free. The environmental coordinator reports that individual artists, art cooperatives
and performance art groups "clean out the city facility weekly." The next slide depicts a facility that
has been totally repainted with spray paints that have been donated to that program.
Recommendations for Treatment or Disposal
Thanks to a grant from me United States Environmental Protection Agency (EPA), the Center
for Safety in the Arts Has produced a twelve page data sheet called Waste Management and Disposal
for Artists and Schools. The next overheads are excerpts from this publication on recommendations
for the actual treatment or disposal of art materials. If possible, leftover or waste art materials should
be recycled or handled by other methods as discussed earlier, especially since recycling of hazardous
waste materials exempts waste generators from EPA regulations.
Overheads
1. Waste Management Methods
2. Acids - Dilute Acid Solutions, Concentrated Acid Solutions, and Solid Acids.
3. Aerosol Spray Cans, » Glues and Cements.
4. Alkalis - Dilute Alkaline Solutions, Concentrated Alkaline Solutions, and Chlorine Bleach
5. Clay, * Glazes and Glaze Chemicals.
6. Dyes - Powders and Dye Solutions.
7. Etches and Pickling Solutions.
8. Metals, • Metal Compounds.
9. Minerals, * Organic Oils, * Plaster.
10. Organic Peroxides, » Oxidizing Agents.
11. Paints and Other Coatings - Water-based Coatings, Solvent-based Coatings, * Patinas, * Pigments.
12. Pesticides.
13. Photochemicals.
14. Solvents.
15. Plastics * Plastic Resins, * Wood
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Safety Precautions " ' .
Whenever pouring or neutralizing chemicals, wear proper, approved personal protective
equipment. This includes:
» chemical splash goggles approved by the American National Standards Institute (ANSI);
* protective clothing (impermeable gloves, aprons, etc.);
» exhaust ventilation for volatile gases or solvents or;
• appropriate respirators approved by the National Institute for Occupational Safety and Health
(NIOSH).
In addition, all routine chemical handling should be done in areas that are equipped with:
• emergency spill control kits for large amounts of liquids;
• fire extinguishers for flammable and combustible materials; •
• eyewash fountains in case of splashes in the eyes;
• emergency showers for concentrated acids and alkalis.
References
1. A. Babin and M. McCann: "Waste Management and Disposal for Artists and Schools," Center for
Safety in the Arts, 1992. ...
2. Environmental Protection Agency. 40 CFR 260-267. Hazardous Waste Management Regulations.
Government Printing Office, Washington DC, 1989.
3. Environmental Protection Agency. 40 CFR 403-424 Effluent Guidelines and Standards.
Government Printing Office, Washington DC, 1991.
4. Environmental Protection Agency. 40 CFR 425-471 Effluent Guidelines and Standards.
Government Printing Office, Washington DC, 1989. . •
5. Environmental Protection Agency. RCRA Orientation Manual 1990 Edition. Office of Solid Waste,
Washington DC, 1990.
6. "Use of the Public Sewers, Including Sewer Surcharges" Rules of the City of New York, Title 15,
Chapter 19, New York City, NY, 1992. .
7. Goldfrank's Toxicological Emergencies., Eds. Lewis Goldfrank et al, 4th edition, Appleton and
Lange, 1990. •
8. M. McCann: Artist Beware: The Hazards and Precautions in Working with Art and Craft Materials.
.New York, Watson-Guptill, 1979.
9. New York State Department of Environmental Conservation, Division of Hazardous Substances
Regulation. Are You a Small Quantity Generator? Albany, NY, 1988.
10. Northeast Industrial Waste Exchange, Inc. Listings Catalog', Issue 44, Spring 1992. 90
Presidential Plaza, Suite 122, Syracuse, NY 13202. Tel: (315) 422-6572.
11. Society of Photo Finishing Engineers (SPFE). Wastewater Regulation Overview. Photo Marketing
Association International. Harrison, NY, 1992.
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DEVELOPING AN R.F.Q./R.F.P. FOR ACQUIRING AN OUTSIDE CONTRACTOR TO
ASSIST WITH A COMMUNITY'S HOUSEHOLD HAZARDOUS WASTE PROGRAM
by James S. Gruber
There have been excellent presentations and papers presented on this topic at this and previous
E.P.A. Household Hazardous Waste Management Conferences. I will direct you to the paper by
Elizabeth M. McCormick, included in the 1990 proceedings, and the paper by Lee Ann Merashoff,
which will be included in the 1992 proceedings.
The McCormick paper provides an excellent detailed guide for both an administrator and a
local attorney in drafting a bid document. My comments in this paper will be from the perspective of
a local administrator and will not duplicate excellent information provided in the previously cited
papers, but will attempt to point out a few "tricks of the trade" that may be practiced by some firms
that are over-zealous to gain market share, a few sample techniques to compare apples to apples, and
considerations in determining who should receive the contract award.
R.F.O and R.F.P.
As any experienced administrator will know, the "lowest cost bid"* may end up being the most
expensive bid if the bidding, awarding, and contract supervision is not properly executed. I have
always taken the approach that a contract with a licensed hazardous waste management firm is both a
type of contract with a contractor and with a professional. Therefore, the bidding process should
mirror both an R.F.Q. (Request For Qualifications used for consulting/engineering services) and an
R.F.P. (Request for Proposal used for construction or trucking type services).
This translates into developing a set of criteria for awarding the contract that carefully
measures a firm's quality of professional service as well as the contractor's price. This will be
discussed further under developing the "Basis of Award" component of the R.F.Q./R.F.P.
DRAFT R.F.O./R.F.P. TO SERVE AS THE BASIS OF FINAL CONTRACT
Nothing can be more exasperating than trying to negotiate every line of a contract when it
could have been simply written by the administrator before within the bid R.F.Q./R.F.P., and then
referenced to by a simple, one-page contract Save yourself many hours of needless toil and draft a
thorough bid document, with adequate legal review, that will clearly state "this bid document shall be
the basis for, and incorporated into, the contract for services."
Apples to Apples? How can a bid document be written so that if you specified a "Golden
Delicious" you don't end up with a "Crab Apple"? Once you receive your bids, how do you
determine which one is actually lower in price?
These are by far the most difficult questions to answer. A few thoughts on how to avoid the
"Crab Apple" are as follows:
1. Watch out for a bidder that allows for "short-packing", e.g. partial drums charged at
full price, without a very good explanation.
2. Be aware of limitations of what can be consolidated. For example, if the bid says only
full gallon cans of paint can be consolidated, and smaller or partial cans are lab-
packed, your costs will skyrocket.
3. A bidder could give a very low unit price for set-up (a figure that those reviewing the
bid can easily understand and be influenced by) and then provide a low bulking effort.
Since you usually pay by the drum, this could lead to a large per-gallon or per-pound
cost. The apparent "low bidder" could become the most expensive contractor.
4. Scrutinize the bid for "surcharges", "contingency charges" or "off-spec charges", and
ask for full explanations in writing or prohibit these charges in the R.F.Q./R..F.P.
5. Beware of a charge for "unknown testing" that could be levied on consumer container
quantities. For example, if a test for an unmarked container is $50, you may deplete
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your entire budget for test charges on every container delivered to a program that does
not have a readable label.
6. Poor control of bulking could easily lead to more drums contaminated with P.C.B.'s.
For example, it is our experience that marine paints and varnishes, along with concrete
floor sealers, appear more likely to contain P.CB.'s. Therefore, an experienced
contractor will bulk these together. Note: A 55 gallon drum of consolidated paint
may cost you $350, if contaminated, $1000.
Methods of Cost Comparisons
To help compare cost data provided by each bidder, I suggest two different approaches. The
first approach requires all bidders to complete a prepared table that is very specifically laid out. One
example (Table 1) requires for each product type: a cost per gallon or pound, the number of gallons or
pounds in each drum, size of drum, and the management method for each (such as blended fuel,
incinerated, consolidated for re-use, stabilization, land disposal, etc.).
TABLE 1
Product Type
(1)
A. Flammables
1. Paints
a. Consolidated SBP
b. Non-reusable SBP
c. Consolidated LP
d. Other
2. Solvents, thinners, stains
3. Putty, adhesives, asphalt
type coatings
4. Gasoline, fuels
5. Waste oil
a. To be reprocessed
b. To be rerefined
c. To be incinerated
Sample Bid Form
Cost/lb.
or gal.
(2)
Conversion - Size Mgmt.
Factor of Drum Method
(3) (4) - (5)
not included in this program
to be accepted and consolidated by Town
6. Aerosols/compressed gas containers
(excluding pesticides)
7. Flammable pesticides
8. Other
B. Poisons
1. Pesticides or herbicides
a. aerosols
b. w/dioxin
c. w/o dfoxin
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to be handled by Town
2. Organics
a. consolidated
b. not consolidated
3. Other (not including mercury)
C. Corrosives
1. Acids
a. oxidizing
b. non-oxidizing
2. Alkalines
D. Oxidizers (excluding acids)
E. Miscellaneous
1. Car batteries
2. Household batteries
a. alkaline , • - -
b. button types
c. lithium
d. Ni-Cd
e. other
3. Mercury (other than batteries)
4. Other
(1) Additional product types may be identified if they are to be handled differently. For products that
can be consolidated with others, please indicate with which other products they are combined.
(2) Please include costs for packing or consolidating as well as the cost of the management option and
transportation.
(3) Please indicate how many pounds or gallons can be put into the size of drum indicated in the next
column.
(4) Please indicate the size of the container to be used for storage.
(5) Management methods codes:
Ru Re-Used C Consolidated for Re-Use Re Recycled
S Stabilization Bf Blended fuel LD Land Disposal
I Incinerated AT Aqueous Treatment
Another approach that will help compliment the cost tables just described is to require all
bidders to provide a quotation for consolidation, transportation, and waste management costs for a
sample one-day collection or one-year period of operation, including all labor, expendable costs
(packaging materials, etc.) based upon a described scenario of wastes collected from participants. A
sample scenario is shown in Figure 1.
You should develop a scenario that will be typical of your waste stream.
And, lastly, you should require your bidders to state any and all additional costs that may be
incurred that were not already given in the bid proposal. This.may raise issues such as permit costs,
insurance, etc.
Proposal Information
The R.F.Q7R.F.P. should provide a specific list of information that each bidder must provide.
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This should be tailored to your own program needs. An example for bidding services to operate a
permanent facility and manage all waste collected is provided here in Figure 2 as a general guide.
Figure 1
Sample Scenario
Consolidated organic liquids
Lab-packed Chemicals
Aerosols
Polychlorinated Pesticides
Other Pesticides
Consolidated, non-reusable paint
Household button batteries
Oil needing reprocessing
Oil needing incineration
Consolidation of reusable paint
and repackaging into 5 gallon pails
4 55-gallon drums
19 55-gallon drums
5 30-galton drums
1 55-gallon drum
9 30-gallon drums
4 55-gallon drum's
1 5-gallon pail
2000 gallons
2000 gallons
5 55-gallon drums
Figure 2
Example of Proposal Information Requirements
PROPOSAL INFORMATION .'".'.
Proposals shall provide the following information: . . .
1. Qualification and licensing of Contractor: Evidence that the Contractor is a hazardous
waste transporter or waste collection firm licensed under State of Vermont.
2. Experience in operating similar facilities: Description of any recent experience in managing
or operating permanent household hazardous waste collection centers or comparable
facilities, with appropriate references. For each of these facilities, the following data must
be provided:
(a) number of participants;
(b) amount of wastes transported by number of drums of each type of waste;
(c) total transportation and waste management costs by product not by waste
characteristic categories;
(d) description of consolidation and reuse and recycling options used for each.
3. Experience in conducting one-day collections: Description of recent experience as
contractor for local or regional household hazardous waste collection events, with a
minimum of three references for collections conducted in 1990. For each of these
references, the following data must be provided:
(a) number of participants; . .
(b) amount of wastes transported by number of drums of each type of waste;
(c) total transportation and waste management costs by product not by waste
characteristic categories; •
(d) description of consolidation and reuse and recycling options used for each.
4. Personnel Qualifications: Detailed information on the experience, education, licensing and
certification and project function of all.personnel who would have significant responsibility
for this project. Substitutions of personnel shall be made only with the approval of the town.
5. Work Plan: A draft of proposed operation and management plan for the Center and a
description of the proposed recordkeeping system.
6. Waste Handling: Indication of the type and extent of consolidation of wastes, with a list of
wastes that will not be accepted for transportation and disposal.
7. Waste Management Methods: Indication of proposed methods of waste management for
each type of waste (by major product type as in Table 1) and the unit cost per method.
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8. . Training and Utilization of Local Personnel: Description of a hazardous waste training
program for chemists and technicians, including qualifications and experience of training •
staff, format and materials, location of training, hours of training required including ^
supervised on-the-job training, and prerequisite qualifications for trainees. Indicate whether I
the firm is willing to employ trained chemists and technicians from the local area on a part- ™
time basis to assist with Center operations.
9. Liability: Evidence of liability coverage to the indicated limits of one million dollars. B
10. Examples: Examples of training materials, public educational materials, and other relevant •
information developed by the firm may be submitted in support of proposals.
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Basis of Award
The last major component of an R.F.Q./R.F.P. that I would like to briefly review is the need to M
clearly state the "Basis of Award". If you don't state it, every firm will call requesting that you I
verbally provide this information. This could easily lead to litigation. One sample "Basis of Award"
is provided in Figure 3. _..
Figure 3 Example Basis of Award
BASIS OF AWARD ' ' I
The contract will be awarded to the hazardous waste management firm which, in the sole judgement of
the town best meets the project objectives of well-managed, environmentally sound, cost-effective •
operation and flexibility in working with municipalities to improve operational efficiency. Criteria used to |
evaluate proposals and to select a Contractor will include but not be restricted to the following:
1. Capability to perform all aspects of the project; —
2. Recent experience relevant to the project, especially with permanent facilities; •
3. Professional background and qualifications of key personnel assigned to the project; ™
4. • Cost of services, including extent to which consolidation is used to reduce transportation
costs;
5. Flexibility and willingness to work with the Project Coordinator to reduce project costs;
6. Use of environmentally sound waste management methods, including recycling and reuse
where appropriate. ' .
7. Ability to post a performance and payroll bond equivalent to 100% of the amount of the
contract.
Proposal should clearly indicate any exceptions to the specifications of this R.F.P. Such exceptions
may be cause to reject the proposal.
As a final note, I always add a disclaimer, "The City/Town retains the right to reject any and all
quotations and to waive any formality or technicality.
I hope these thoughts and examples will be helpful to assist a community in bidding, reviewing
and awarding a contract. Involving the legal department and those that have the authority to award
and sign the final contract, should help avoid unpleasant surprises, and assist in acquiring quality
services at a reasonable, fair price. , • . . .
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CONTROLLING THE'DESTINY OF YOUR WASTE
WRITING A REQUEST FOR PROPOSAL
CONTRACTOR'S PERSPECTIVE
SUBMITTED BY:
ERIC LAUT, PROJECT DEVELOPMENT MANAGER
CHEMICAL WASTE MANAGEMENT, INC. - GENEVA, ILLINOIS
Chemical Waste Management, Inc. (CWM) Technical Services Division has performed
over 500 household hazardous waste (HHW) collection programs nationwide. Many
of the HHW programs required that CWM respond to a Request for Proposal (RFP).
A significant number of RFPs received by CWM were not structured adequately to
elicit a response to which a community could compare contractors' pricing on an
"apples to apples" basis. The majority of the documents received were Requests
for Bid (RFB) where only price was a' consideration. The following is an outline-
and discussion of a RFP format which allows the community to compare contractors
on a parallel pricing basis and incorporates quintessential elements of
contractor comparisons on technical expertise, experience, insurance, liability
protection, health and safety procedures, ability to expedite the collection
process and disposal option comparison. The RFP section will be followed by a
synopsis of contract elements.
REQUEST FOR PROPOSALS
I-.The Introduction
The introduction to an RFP should acquaint the proposer with the
community, the type of program, demographics and population (household
number) information, the number of collection sites, the time and site of
the collection event and general mechanics of the event. Following is a
sample introduction for a RFP:
Sample Introduction In a RFP
This is a Request for Proposal from /Insert Community^ for the
collection transportation and disposal of household hazardous waste
throughout . The successful Proposer shall assist the _
(Insert Community^ Staff in the planning and development of the
projects, staff collection projects sites and shall be responsible for the
packaging, transportation and disposal of household hazardous waste
collected.
It is anticipated that the project will take place at approximately
(Insert #1 sites. The sites will be open on (Insert Datei. from (Insert
Time).
The household chemicals will be transported'to the collection sites by the
individual residents. The collection projects will use a drive-up system.
Cars with chemicals transported in their trunks will be directed to
sorting tables under tents, where they will be unloaded.
The project will be advertised through publicity; local newspapers, radio,
telephone, posters, and flyers. The purpose of this project is to insure
residents a safe disposal pption for household hazardous
chemicals as well as educate them to the risk of storing, handling, and
disposing of these materials privately. . -
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II. Proposal Evaluation Criteria
There exists the potential for personal and financial liability to a
community as a result of a HHW collection program. The ability of a
contractor to reduce disposal liabilities from CERCLA (Superfund) action,
the experience of a contractor in performing requisite HHW services, the
adherence to safe work practices and abilities to reduce waiting time and
appear professional in front of community officials and the press are all
factors which outweigh the bottom line costs for the event. The following
is a sample proposal evaluation criteria for emphasizing and evaluating
contractors on other factors besides price:
Sample Evaluation Criteria section
The experience of the HHW collection process, the experience of the
proposer in the HHW field, the detail to sound health and safety policies
during the performance of the HHW event and the ability of the proposer to
financially and legally protect the Community are critical elements in the
evaluation process. The proposal submitted, therefore, will be evaluated
on the following proposal criteria:
Technical Proposal
Liability Protection
Cost Factors
60%
25%
15%
III. Insurance
The ability of a HHW contractor to insure a community against general,
automobile and pollution control liabilities should be part of the
liability protection evaluation criteria. Contractors should be given a
minimum insurance limit by the community and asked to provide their
insurance limits if greater than the minimum criteria listed. Contractors
offering the highest insurance limits (particularly on pollution control
liability) should receive the highest evaluation:
Sample Insurance Section
A. General Liability Including:
1. Personal
2. Pire
3. Medical Expense
B.< Automobile Liability Including:
1. CSL
2. Bodily Injury
3. Property Damage
C. Pollution Control Liability:
D. Workmen's Compensation:
Proposer's
Insurance
55,000,000.00
$5,000,000.00
$3,000,000 Annual
Aggregate
Statutory
Contractor shall not commence work until Contractor has obtained the
required insurance, and has filed an acceptable Certificate of Insurance
with the •_. All Insurance Policies shall be open to inspection by
the , and copies of the policy shall be submitted to the
upon written request.
*The proposer should indicate insurance limits that can be provided (if
different from limit provided). Do not indicate limits lower than those
indicated; these are to be considered the minimum insurance requirements.
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IV. The Technical Proposal
The technical proposal is the core of the KFP. The technical proposal
will allow communities to gain an understanding of the contractor's
ability to perform a HHW program in a professional manner and evaluate the
contractor's comprehension of the collection process and ability to
process participants in an expedient manner. The health and safety
aspects of the HHW collection program are highlighted in the contractor's
responses to their spill and fire prevention plan, contingency plan and
flammable bulking procedures (these aspects should be reviewed and
evaluated by health and safety professionals, local fire police and hazmat
representatives). The contractor's internal employee, training and
training that can be provided to the community is also an important
consideration. The following is a sample technical proposal section in a
RFP:
Sample Technical Proposal Section
• ' t ,
In order for '__ to technically qualify a Contractor/ all
Proposers are requested to submit the following information:
A. Site Set-up - Proposers"are requested to submit-a diagram of the
proposed household hazardous waste site collection activities. The
diagram should include traffic flow, positioning of tent, fire,
spill, and other safety equipment and the minimum area required to
perform the project. A detailed description of site activities
including receipt, segregation, packaging, testing, and loading etc.
should be attached to the diagram.
B. On-aiteEquipment List - Proposers are requested to provide a liet
of on-site equipment that will be available at the collection
facility. The list should include all fire prevention, safety,
personal protective equipment, and other equipment as the Proposer
deems suitable or necessary for this project.
C. Spill and Fire Prevention Plan - The Proposers are requested to
provide spill prevention and fire prevention plan tailored to on-
site activities at the collection facility.
D. Contingency Plan - Proposers are requested to provide a format for
a contingency plan and provide a description of notification
procedures to the participants of on-site emergencies and evacuation
of the participants in case of an emergency on-site.
B. Flammable Bulking Procedures - Since flammable solvents and/or
paints will most likely be bulked on one or more collection facility
location, the Proposer is requested to submit Standard Operating
Procedure for bulking of flammable liquids on-site at the collection
facility.
F. Employee Training - Proposers are requested to provide a detailed
training outline and to differentiate between the training required
for Chemists versus the training required for Technicians. The role
of each position during on-site collection activities should be
outlined.
G. Employee Experience - Proposers are requested to provide a listing
of the names of employees that will be involved in the project,
their Degree, and approximate number of hours field work that each
of the employees has performed. • , „_
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H* Related Project Experience - All Proposers are requested to provide
at least ten household hazardous waste projects that were performed
by your company. The list should include names, contact names, and B
telephone numbers of the contacts.
I. Reference Letters - Proposers are requested to provide at least
three (3) letters of reference from household hazardous waste
projects, and/or other cleansweep type projects performed.
J. Transportation and Disposal Facility Lists - Proposer is requested •
to provide a complete listing of storage/transfer/transportation and . •
disposal facilities which may be utilized throughout the course of
this project. The transportation and disposal facilities should _
list the location, contact, phone, and Federal I.D. Number of each I
facility.
V. Delegation of Duties
Delegation of Duties •
The following responsibilities will be applicable, as indicated, for the
contractor and the community.
I
It is important that the community outline the specific responsibilities
and duties of the community versus those of the contractor. Some «
communities may want to supply labor to offload and presegregate HHW •
materials. (This lowers the cost but increases the community exposure and
financial liability.) Whatever the case may be, the duties and
responsibilities directly affect program costs and should be outlined •
clearly. Following is a sample .delegation of duties section of a RFP: J|
Sample Delegation of Duties Section
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Contractor Responsibilities
1. Planning and Assistance - provide experienced and trained staff to £
assist the community in the organization and training of volunteers •
for the project.
2. Mobilize/demobilize labor and equipment necessary to perform the •
project. *
3. Provide labor to offload, shuttle, segregate, classify, package, . fl
label, bulk, manifest, load, transport and dispose of HHW collected |
at the event. . '
4. Provide supplies and equipment necessary to perform the project
including, but not limited to, personal protective equipment,
trucks, safety equipment, drums, absorbent, tables and chairs for
packaging areas.
5. Site cleanup.
Community Responsibilities
1. Traffic control
2. . Surveys
3. Tents
4. Roll-off boxes
5. Provide suitable site location.
6. Provide volunteers to presort and remove paints.
7. Movement of paints to a central location.
8. Operate paint give-away program.
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VI". Process Expediency
in this section of the RFP, communities should outline the time and date
wastes must be removed from the collection site. In addition, the
community's expectation of the number of participants can be indicated (if
historical or comparative data is available). The contractor's staffing
levels will be directly affected by the waste removal time frame, the
expected number of participants and the responsibilities of the contractor
versus the community. Contractors who can expediently remove the waste
should be favored in the evaluation process. Following is a sample RFP
section on process expediency.
Sample Process Expediency Section
' The contractor is expected to have packaged and removed waste offsite at
the following times and dates:
Site
Site #1
Site #2
Site #3
Site #4
Time
Date
Since events may be planned or for other reasons the waste may not remain
onsite, the proposer should indicate staffing necessary to accomplish the
task in the time frame indicated.
The following indicates the number of participants expected at each site*
Site
Site /I
Site #2
Site #3
Site #4
Expected Participants
» ^ *•
Please Note: The proposed Contractor staffing and ideas for expediting
the movement and removal of the HHW in the time frames indicated will be
a major component of the evaluation in the technical proposal.
VII. Proooaal Conditions
,'
This section of the RFP can contain any conditions that a community
corporation counsel has directed. The section can also be used to outline
requirements of contractors that will protect the community from CERCIA
liabilities by prescribing and directing the means of disposal, the
disposal method, etc. Of particular importance is a requirement that
packaged wastes be disposed of directly at the disposal site instead of
mixing HHW's with RCRA wastes at secondary facilities, thereby creating a
hazardous waste. Following .is a sample section on proposal conditions:
Sample Proposal Condition Section
1. Proposers who own all disposal facilities at which wastes will be
disposed/treated will be favored.
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2.
3.
4.
5.
The preferred method of waste disposal is RCRA incineration. The
Contractor must RCRA incinerate or fuels blend greater than 90% of
the waste. Wastes that are incinerated must be incinerated at a
RCRA Part B incinerator,
Lab-pack wastes (those in containers of 5 gallons or less) must be
removed immediately after packaging is completed.
Lab-pack wastes may not be taken to an intermediary storage facility
for the purposes of bulking or consolidation. Combining household
hazardous waste and RCRA regulated waste at an intermediary facility
is prohibited.
. (Insert Community)
In order to protect
associated with on-site activities,
_ from liabilities
transportation and inherent
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CERCLA liabilities involving disposal, the Proposers should supply
their own labor, transportation, and dispose of the waste at their
own EPA permitted disposal facilities. Companies which can
internalize all labor, packaging, transportation and disposal
services will be highly favored in the Proposal Evaluation Process.
VIII. Cost Proposal
The primary objective of the coat proposal section is to compare
contractors on an equivalent basis. This is accomplished by requiring
"net Ib." pricing on all packaged wastes (labpacks). The net Ib. is the
actual weight of the HHW material in its original container and excludes
disposal costs for outer drum and inner absorbent. The waste is weighed
and the community pays only for the waste weight. The net Ib. pricing
method is the only true way to compare contractors on an "apples to
apples" basis.
The following outlines a sample cost proposal section in a RFP:
Sample Cost Proposal
Proposers are requested to complete the attached cost proposal as
outlined. The services that shall be requested from the Proposer, in
order to give the Contractor a more comprehensive idea of how the
Proposer's quote should be established, are outlined following:
Scone of Proposalt
1. Planning and Assistance - The Contractor shall, at the request of
the Community, provide staff experienced or trained to the
satisfaction of the Community to attend meetings with the Community
to review proposed collection site procedures, or otherwise assist
Community staff in planning the collection projects.
2. Mobilization and Demobilization - The cost of this section should
include the movement of your projected team size per site plus
supplies and equipment to and from the collection facility.
3. On-Site Labor -,Contractors should provide the costs of on-site
labor on a per hour basis for Chemists and Technicians.
4. Transportation, Disposal and Supplies - Proposer should provide a
price per net pound (unless otherwise indicated) for transportation
and disposal of the household hazardous waste. This price should
include supplies such as drums, absorbent, labels, manifests, etc.
All lab-pack waste will be weighed by the Contractor prior to
packaging. The resultant weight will be considered the "net
weight". (This excludes the drum and absorbent weight.) Please
keep this in mind when formulating your bid prices.
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Each waste type has at least one disposal option listed. Proposers will
provide a bid price for one or all options listed. 'On a separate sheet of
paper Proposers may provide bid prices for alternative options under their
notes on pricing. .Where disposal options exist, the Community will select
the option to be utilized prior to collection.
Item
1. Planning and assistance
2. Mobilization/Demobilization/Site:
3. On-Site Labor
A. Chemist
B. Technician
C. Per Diem
4. On-Site Equipment
A. Personal Protective Equipment
B. Vehicle Rental
C. Tents (assume 20' x 20')
O. Safety station equipment
Unit '
Lump sum
(est. ISO hrs.)
Site #1
Site #2
Site *3
Site #4
Per person/hour
Per person/hour
Per person/night
Per person/day
Per person/day
Per tent/day
Per site/day
Unit Cost
Analysis
A. Per unknown lab-pack container Per test
(Less than or equal to 5 gallons)
B. Fuel Blend Analysis , Per waste stream
C. Full Analysis Per waste stream
D. TCLP Analysis 4 . Per waste stream
Transportation/Disposal/Supplies
A. Non-halogenated Flammables
1. Bulk - incinerated, (liquids)
2. Bulk - incinerated (sludge)
3. Lab-packed - Incinerated
4. Bulk - Fuel Blended
5. other .(describe)
. . ' •!
B. Inorganic Poisonous Liquid
1. Lab-packed - Landfilled
2. Other (describe)
Price Net Pound
Unless otherwise 'specified
Per gal.
Per gal.
Per gal.
Organic Poisonous Liquid (Halogenated Solvents and Pesticides)
1. Lab-packed - Incinerated
2. Other (describe) .
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D. • Aeroeol Containers ' • "
1. Lab-packed - Incinerated
E. Corrosives
1. Lab-packed - Incinerated
2. Lab-packed - Treatment
3. Other (describe)
F. Hazardous-Waste Liquid or Solid N.6.S.
1. Lab-packed - Incinerated
2. Lab-packed - Landfilled
G. Waste Paints
1. Oil based paints (liquid)
a) Bulk - Incinerated Per gal.
b) Bulk - Fuel Blended Per gal.
c) Lab-packed - Incinerated
d) Other (describe)
2. Latex Paint
a) Bulk - Incinerated Per gal.
b) Lab-packed - Incinerated
c) other (describe)
Contracts
The contract developed by a community should contain the following elements.
1. Standard terms and conditions developed by the community's corporate
counsel as mutually agreed to by contractor.
2. Identification of principal parties and authorized representatives.
3. Scope of work as outlined in the technical proposal and as mutually
agreed.
4. Pricing as contained in the RFP.
5. Transport and disposal facilities to be utilized during the contract.
6. The contract term - period of time the contract will be in effect.
7. Unacceptable wastes.
. <• ",
8. Insurance. ' •
9. Payment terms.
The contract will basically outline, in legal terms, the relationship between the
two parties. A majority of the contract will envelope the proposal of the
contractor in response to the communities RFP and will incorporate legal
language, as modified, requisite to both parties.
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WASTE TRACKING
George Kinney, Environmental Supervisor, Dakota County, Minnesota
In Minnesota, our HHW becomes regulated hazardous waste as soon as it is collected. As such, all our HHW
is handled in existing hazardous waste systems, using manifests and permitted hazardous waste facilities.
Exceptions are latex paint (not hazardous), wastes exchanged on site, used oil and lead-acid batteries moved
into recycling network.
In the rest of the country, where HHW is exempt from regulation, how is the waste tracked? This
must be included in the contracts with the firms handling the HHW. A shipping paper or bill of lading will
not suffice to give adequate information on the fate of the HHW.
The wastes from Minnesota are sent to hazardous waste incinerators, fuel blended and used in lime
kilns, recycled, or landfilled after treatment In many other parts of the country, similar fates are used for
the HHW. * .
Oil-based paints and flammable liquids are sent for fuel blending, first being mixed with other high
BTU hazardous wastes in large tanks, and then transported and fed into lime kilns. The fuel value of the
HHW is used to. heat the limestone in the making of portland cement, replacing other fuels that would have
been used;
All of the lab-packed wastes, and the sludge bottoms from the oil-based paints, are sent to hazardous
waste incinerators, where the HHW is burned very completely, with any emissions captured. Our lead-acid
batteries are recycled at a secondary lead smelter located in Eagan, MN, a HHW permanent collection site.
Latex paint from Dakota County will be recycled at a site in Ohio, EPI, in which the paint will be dried and
the latex reused in a number of industrial applications, such as roofing compounds. We also recycle the latex
driveway sealers we receive by removing the separated water and placing the solids on a local bituminous
company's rework pile. We have recently begun collecting fluorescent tubes for reclamation.
Some lab packed wastes must be treated and landfilled, as there is no other method of disposing of
the waste. An example would be lead arsenate pesticides.
If you are exempted from using a hazardous waste manifest, you may elect to use one, in order to
track your waste. This would have to be written into your contract, but the HHW management firm will be
familiar with the manifests use, and may not object. The manifest consists of several copies (5-8, depending
on the state), and you, as generator of the waste will receive a copy signed by the hazardous waste facility
after your waste arrives. You may call the hazardous waste facility to check that your drums of HHW arrived
and were managed by the facility.
All firms handling HHW should be willing to verify where your HHW will eventually be used,
recycled, incinerated or buried, and should put it in writing. I had an unpleasant experience with a company
representative several years ago who told me, during bidding on my HHW work, not id worry about where
my waste went, as it was exempt. His firm's prices were very competitive, but I disqualified his firm for not
submitting bid documents completed as required, and refusing the chance to amend them.
Many large businesses use facility audits to determine if the hazardous waste facility meets their
needs. The audit will check on the facility's compliance record with county, state and federal regulations,
actual facility operations, usually an inspection of the facility by a company representative or consultant, and
questions of other clients. You may not have the ability to conduct audits of the facilities, but you may be
able to question others who have knowledge of the facilities in question! .
Do you have liability for exempt waste? If your HHW, with hazardous characteristics, is going to
a sanitary landfill, you may have some liability. Recently, one of our County's small private sanitary landfills
closed and the owner declared bankruptcy. The Minnesota Pollution Control Agency sent notices to all
identified users of the landfill that, under CERCLA, they would be named as responsible parties if they could
not identify their wastes as having no hazardous characteristics.
HHW that is fuel blended, recycled or incinerated loses its long-term CERCLA liability. The
resulting ash or still bottoms from the facility operations were generated by the facility, and it is highly
unlikely that the HHW sent by your program will be named if any cleanup of the facility is necessary.
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I
An Overview of State and Local technical Assistance Efforts |
Robert G. Style v _
Staff/National" Roundtable of State Pollution Prevention Programs, Minneapolis, MN •
1 • ™
Good morning. I am here today speaking to you today as a representative of the National
Roundtable of State Pollution Prevention Programs. I
I make that clarification because 1 actually wear.two hats in my work life. Under one hat I
am on staff at the Waste Reduction Institute for Training and Applications Research •
(WRTTAR),\a private, non-profit organization that provides training and applied research |
on waste reduction issues. Under my other hat I am acting staff for the National
Roundtable of State Pollution Prevention. In September of 1990, WRITAR secured a _
grant from the USEPA to establish and formalize the Roundtable as an organization. Until •
that time, the Roundtable had been meeting informally since around 1985. WRITAR is in ™
the process of completing our grant responsibilities and turning over the day-to-day
operations of the Roundtable to its new Executive Director. ' •
The Roundtable is an association of public sector programs that attempts, and I'm quoting
from the group's Mission Statement here, "to promote the development, implementation "" «
and evaluation of efforts to avoid, eliminate or reduce waste generation to all media." I
There are somewhere in the neighborhood of 89 state and local pollution prevention *
programs affiliated with the Roundtable and another 200 or so businesses, consultants,
non-profit organizations, federal employees, and interested individuals who have 8
participated in Roundtable activities in the last year. Although the focus of Roundtable •
activities is the facilitation of the flow of information between public sector pollution
prevention programs; it remains open to the participation of any and all groups interested in •
pollution prevention issues. " • " J
v ,
Technical Assistance Programs _
The pollution prevention programs that are members of the Roundtable can be seen as •
having two distinct missions. One mission is to develop state and local policy initiatives
and coordinate the activity of existing environmental programs in such a way as to focus. •
these efforts on preventing the generation of waste at the source. This policy focus is |
played out inside the government structure through policy formation efforts, the training
and coordination of government staff, and the development or revision of rules .to reflect a
prevention focus! The other mission is to collect information about source reduction s
techniques and technologies and provide it free or at minimal cost to businesses and local
governments in their jurisdiction. This mission is played out by reaching outside the
structure of government to the private sector and offering the cooperation; and assistance of
a pollution prevention experts^ Although a number of programs combine these functions,
many of the Roundtable's members operate with one or the other of these missions as the ~
sole focus of their activities. Today we will be looking at state and local efforts to assist
businesses and others discover and adopt pollution prevention options.
' t
Help is something we all need every now and then. And with the myriad of technologies
and regulations involved in the generation and handling of hazardous waste, it is not
surprising that the idea of providing assistance to businesses is an attractive one to state
legislatures and city councils. Recognizing the burden complex environmental regulations,
place on businesses in general, and how particularly onerous this burden is on smaller
businesses, state and local governments have attempted to provide the kind of assistance
that helps these businesses proac'tively address their waste generating practices. This not •
only protects the environment, but also improves a businesses competitive position by
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helping insure regulatory compliance (thereby protecting against the imposition of fines for
permit or discharge violations) and encouraging the adoption of sustainable business
practices. And in todays competitive marketplace, healthy sustainable business give states
and municipalities the kind of reliable tax base they need to survive:
(Overhead 1) ' .
At last count there were fifty eight (58) state and locally sponsored programs that offer
some kind of technical assistance to businesses and local governments. As you can see on
the overhead, these programs operate from a variety of administrative bases. The
administrative base of a program is important to the extent that it can condition the way
these programs are viewed by potential clients and thereby affect a clients willingness to
work with the programs. It is generally accepted that programs housed in a regulatory
agency, be it environmental or health based, tend to scare off potential clients. We all
know how sensitive industry people are to contact with regulatory'personnel. Therefore,
the majority (38 out of 58) of these programs operate from an expressed non-regulatory
base. ,
My co-panelists, Donna Peterson of the Minnesota Technical Assistance Program and
Grace Caner of the Massachusetts Office of Technical Assistance, represent two of the best
technical assistance programs in the nation. What Ihope to do now is provide you with a
quick overview of the types of services available from programs, like theirs and leave them '
to speak in greater detail regarding the type of technical assistance available to groups or
individuals concerned with household hazardous waste. . •
»
TAP Services
(Overhead .2) . v . ' .
The principle function of a technical assistance program is to gather and disseminate
information on pollution prevention techniques and technologies. And although good
information is available, in many cases free of charge, it is scattered about in data bases and
libraries in research centers, universities, state agencies and the federal .government. It can
take a good deal of time just of find out what's out there, much less collect it, and make '
judgements about its quality. It is unrealistic to think that a business withJimited resources
would be able to collect and make use of this information in a cost effective fashion. •
i
Information Clearinghouse
Most technical assistance programs operating today have developed a library of pollution
prevention literature. These libraries, or information clearinghouses, make up the base from
which all the information and technical transfer functions proceed. Nearly afi new
programs spend a great deal of their start-up time gathering and indexing these resources.
The volume and degree of technical sophistication of the documents in these clearinghouses
varies according to the age of the program, the sophistication of its staff, and the financial
resources available to it. A program with little funding or a limited mission is unlikely to
acquire a volume bf documents it'has.little space and less staff time to properly maintain.
Often these programs do not collect documents at all. A limited program can function just
as well collecting bibliographies of pollution prevention information rather than collecting
the complete, set of documents.
. i i.
The type of documents available also varies. Naturally, these program have access to all
the applicable state and federal legislation having anything to do with their mission.
Articles published in scholastic and industrial journals (which often carry copyright
restrictions), as well as documents developed and distributed by state and local programs,
trade associations, and the USEPA related to pollution prevention efforts may also be made
available. The fact sheets^manuals.and guides, 'and case studies-published fay these public
541
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entities are public record documents which can be made distributed through the ™
clearinghouse free or at a reduced cost.
Fact sheets are designed to transfer information to fairly specific audiences. They are |
usually short, three or four pages in length, and often describe the best available techniques
and technologies for pollution prevention in one specific industry, industrial process, or M
waste ^stream. Fact sheets, because of their limited length, function well as summaries of •
available pollution prevention options but do not contain the level of detail necessary to deal
with site specific issues. '".•'••
Manuals and guides examine pollution prevention options in much greater detail than fact I
sheets. Also industry or process specific, manuals and guides go beyond the highlighting
of options to actually describing the processes involved in option evaluation and detailed •
site-specific analysis. These documents expand on the options outlined in fact sheets, often |
examining the technical details and relative value of a variety of pollution prevention
options in an effort to guide a waste generators develop and implement their own, in- • ^
house, pollution prevention programs. ' •
Many programs that have a history in technical assistance have recorded their efforts in the
form of case studies and make these available to the public. Case studies are generally •
considered valuable by waste generators in that they help them move from the theoretical |
aspects of pollution prevention to the nuts and bolts of implementation. The published
results of a technical assistance effort (particularly when the effort is demonstrably ,
successful) not only gives some real-world grounding to what is often presented in
' theoretical terms, but also provides the sort of materials use and hard financial information
that can help a'company rationalize the adoption of pollution prevention options., Being
able to see how a rgaj company making real changes can have a real effect, financially or
environmentally, goes a. long way to convincing waste generators that there may be benefits
to the adoption of pollution prevention techniques.
State and local programs will often sponsor basic and applied research by professional .
researchers. The published results of these studies may also be made available through'
• these clearinghouses.
I • *
Telephone Hotlines .
Many programs have an immediate information dissemination arid referral service available
through a telephone hotline, often with a toll-free "800" number that is limited to its state or
regional jurisdiction. These hotlines serve as the "first call for help" on a wide, variety of
waste management questions. Hotline calls can often deal with issues other that pollution
prevention, such as questions on regulations, recycling, or treatment and disposal methods.
However, technical assistance personnel still have the opportunity to suggest pollution
prevention options to individuals who they might not normally reach.
.' - e t
Requests for process-specific and regulatory information dominate hotline traffic. Inmost
cases, program staff can handle the call in-house or refer the client to another organization
that is better equipped to handle the question. Programs that have extensive libraries (often
university-based programs) may use those resources to conduct elaborate information
searches for a client. However, telephone assistance is not the most efficient way fore
program, staff to provide information on complex questions.
/ * " .
On-Site Technical Assistance
Of the state and local pollution prevention programs that say they provide technical
assistance, a high percentage (over 80%) provide some type of on-site assistance; When it -
comes to the more experienced programs (those with 4 years of experience or more), all
provide for some sort of on-site technical assistance. Since the start-up time and financial
resources necessary for an on-site component of technical assistance place a relatively
542
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heavy burden on a program's infrastructure, it normally takes some time for such a
component to become operative in an emerging program.
/
By far the most common form of on-site technical assistance is the waste audit or -
assessment. Assessments are designed to further a generator's pollution prevention efforts
by analyzing their waste producing processes, developing a clear picture of their waste -
streams, and isolating pollution prevention options.. These audits are generally performed
free of charge by one of the technical assistance program staff.
Programs also make their staff available for more involved, longer term consultations.
Consultations of this type often involve assisting the client uncover site-specific pollution
prevention options and providing support for the development of those options. Technical
assistance program staff are able to pull together case studies and other documentation from
the program's resource center, review available technologies, and analyze the client's
current production processes as they work with the client's employees to develop a set of
realizable pollution prevention options. Programs usually provide'these kinds of
consultations in instances when the techniques developed by the effort are easily transferred
to other similar industries and the client is willing to publicize this cooperative effort. Such
efforts not only help develop possibly new and innovative technologies, but by publicizing
these efforts, the program is also able to promote its services and the positive outcome of
the adoption of pollution prevention options. Insurance and liability considerations prevent
program staff from recommending specific technologies.
Staff of technical assistance programs come from a variety of backgrounds and levels of
expertise vary from program to program. The abilities and expertise of
program staff is one of the main conditioning factors in the quality of assistance programs
are able to provide.
Many technical assistance programs try to develop some son of targeting mechanism to
make the most effective use of their resources. For example, the Massachusetts Blackstone
Project, considered by many to be the best example of effective pollution prevention
technical assistance, targeted an small industrial sector (metal finishing) in a limited
geographical area (Blackstone River basin) to receive direct, on-site assistance. Other
programs have followed a similar strategy, targeting specific industrial sectors in order to
develop an information base or set of effective pollution prevention options that can be
easily be transferred to other similar industries. Still others have targeted their have
targeted their services at larger generators, or small and medium sized businesses.
Some technical assistance programs have approached this issue from an entirely different
point of view. Rather than targeting industries, these programs survey waste generators to
find out what services the would be likely use. These programs then use the responses to
the survey to prioritize their technical assistance activities. The Washington State
Department of Ecology recently collected responses to just such a survey and believe it will
help them set up their pollution prevention technical assistance program..
CESQGs and Household Ha/ardous Waste Generators
Although CESQGs and household hazardous waste generators have not traditionally been
targeted for pollution prevention technical assistance by state and local programs, a number
of programs have begun to make information available to these groups. Information on the
processes that generate small quantities of waste has become increasing available and the
state programs are starting to make this available. And with increasing concern on the part
of the general public relative to toxic and hazardous materials, state and local technical
assistance programs will find increasing pressure to make information on pollution
prevention options available to the small generators of hazardous waste.
543
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PROGRAMS
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Rory Kessler
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Worcester, MA
(508) 792-7692
Fax: 792-7621
William Sloan'
Environmental Service
2020 Industrial Drive
Annapolis, MD 21401
(301)974-7281
Fax: 974-7267
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Pollution
Pollution
520 Lafay
St. Paul.
(612)296-
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Office of Waste Mi
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St. Paul.MN 551'
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Providing Technical Assistance for Small Business
Donna Peterson, Senior Scientist
Minnesota Technical Assistance Program School of Public Health
University of Minnesota Minneapolis, Minnesota
Background
The Minnesota Technical Assistance Program (MnTap) has been providing technical assistance
to small businesses, often referred to as conditionally exempt small quantity generators (CESQG) since
1985. When MnTap was created, part of its charge was to reach put and help generators of the state,
particularly smaller businesses with inadequate technical and financial resources. In Minnesota, any.
business producing hazardous waste has been required to manage that waste according to the hazardous
waste rules since they first became effective in 1980. Hence the GESQGs have always been a part of the
small businesses that MnTap has addressed.
MnTap provides free technical assistance to any Minnesota business. This assistance includes help
in waste management, and pollution prevention. The funding for the program is mostly .from the
Minnesota Office of Waste Management. The program is in the School of Public Health at the University
of Minnesota.
MnTap has always had a two-fold focus; helping companies achieve compliance with hazardous
waste regulations and assisting companies in pollution prevention. Prior to 1990, assistance was provided
mostly for small and medium-sized companies. Often for the small company (CESQG), the assistance
focuses on proper management and regulatory requirements. For the medium-sized company, assistance
is primarily for waste reduction.
In 1990, the Minnesota Toxic Pollution Prevention Act was passed. With that, MnTAP was
provided increased funding for an expanded effort to help large companies achieve pollution prevention.
Outreach for the small Minnesota business
Before a program can help any one, the clients you seek to serve must know you exist During
the first year of MnTAP's existence, a lot of effort went into reaching the clients we wanted to serve. One
key strategy was to identify associations whose members are primarily small businesses. We then offered
to come to an association meeting with a presentation about the assistance we could offer. In addition
to associations, promotional mailings were made to several business and outreach organizations. This
included Chambers of Commerce, University of Minnesota Extension and county solid waste officers.
We also developed a display board which we could easily set up at meetings where the opportunity existed
to reach out to business with information about our service.
When the Minnesota Pollution Control Agency (MPCA) targeted certain kinds of small businesses
for compliance on hazardous waste regulations, MnTAP worked with the Small Business Development
Centers in greater Minnesota to schedule and advertise workshops for these targeted industry groups. At
the same time as we were engaged in these activities, we also worked with the MPCA to develop fact
sheets for business, often targeted to the smaller business. We also started a newsletter.
More recently, we have contacted all the county Solid Waste Officers in the state again. We sent
them a basic fact sheet outlining our services and a checklist they could use to get fact sheets or other
materials. It seemed they were a key audience to target because they obviously get calls from small
businesses wondering about disposal requirements.
At meetings scheduled for very small businesses in the Duluth area recently, MnTAP set up our
display table and had the opportunity to provide information on our service along with basic waste
management information.
There are at least two other items to note as part of our ongoing effort to respond effectively to
the very small business. We have staff assigned to keep abreast of regulatory programs and rules affecting
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these small companies. We also work closely with the MPCA to coordinate the development and revision
of fact sheets and lists useful to these businesses.
Observations for other programs
Providing technical assistance to the very small generator (CESQG) works well if there is a
management system in place that allows them to dispose of the waste easily. This means someone will
come to their business if they call, or there is a site to which materials can be taken. Most businesses
seem willing to pay some fee. - •
Providing the technical assistance works well also if it's very clear what paper work and reporting
is required. It's easiest too, if the paper work and requirements are not too burdensome. Hopefully, it's
less for a CESQG than for the small quantity generator (SQG). . ;-.
Regulations do play a role in the proper management of the hazardous waste from the very small
business. Proper management and disposal begins to happen when either some requirements are imposed,
or it's accepted free at a collection site. If it can be accepted free, as that from a household, and if it's
convenient, then small companies will voluntarily bring their wastes to these sites.
It should be "noted however that "free" disposal for the small business at a collection site will not
provide an incentive to reduce even the small quantities of hazardous waste generated. For a householder,
free disposal for unused paint does not provide the incentive to bring less the next time.
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An awareness campaign for the small businesses will be needed. Think about what you have done
for the householder in your area to get their attention and knowledge. A similar effort will be required
for small businesses. Small businesses are accustomed to using lots of chemical products, but have had
minimal training about hazardous risks from use and disposal. Therefore, they do not easily recognize
that environmental damage can result from the disposal practices they use.
' Associations for similar kinds of businesses may very well provide a good mechanism for
efficiently reaching a group of these businesses. More and more trade associations are becoming
interested in seeing their members improve their waste management practices and are eager to work with
a program that can provide the regulatory and management information needed.
Where household hazardous waste sites might find good help
There are household hazardous waste sites that have already taken waste from the very small
businesses. People at these sites have lots of history of what works and doesn't work, both in the way
of giving instructions for bringing waste to their sites, and in making small businesses aware of the
hazards which result from the wastes they produce.
It is advisable to look to sites in other areas of your state, or in adjacent states. Sometimes the
information gained closest to home seems the most relevant and easiest to use. I have often sought out
the experience of people at the Iowa Waste Reduction Center, in Cedar Falls, Iowa because there is a lot
in common between the waste management issues for small businesses in northern Iowa and those in
.southern Minnesota.
Some states have been offering technical assistance to small businesses, and again may have
materials easily adapted for your area. In our office, we have on occasion used the EPA PIES effectively
to learn where knowledge and information may already exist because of special projects in other states,
or regions. .
Concluding observations
Small businesses awareness of hazardous waste issues is still generally in an embryonic
level. An effort will be needed similar to what's been required for household waste to
raise the awareness of the issues and then get business to change practices so that
hazardous waste is routinely segregated and managed properly.
* For a certain percentage of small businesses, proper management will result once the
realization of the potential costs and liabilities associated with improper management.
This percentage will vary depending upon the good will of the companies, the value the
. company places on environmental protection, the convenience of disposal options and the
cost. The percentage will also be higher where regulations and enforcement are part of
the equation.
• Waste reduction will be easier to achieve once the small businesses realize how much
hazardous waste they produce. The incentive to reduce waste is often tied to a realization
of the quantities generated. Once businesses see the possible cost savings, sometimes in
just new material alone, the incentive is there to identify ways to reduce the waste
produced.
Given the variety of resources and experience available to support an initiative in this area, it is
within reason to assert that service to the small business (CESQG) can be provided more easily knowing
resources already exist . •
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TAP
MINNESOTA
TECHNICAL
ASSISTANCE
PROGRAM
Checklist of Resources for
Minnesota Businesses
The folio wing publications are provided free of charge by the Minnesota Technical Assistance Program (MnTAP), a
nonregulatory program at the University of Minnesota that assists Minnesota businesses with their waste
management problems. Publications listed in italics are current publications produced by the Minnesota Pollution
Control Agency, the environmental regulatory agency in charge of enforcing state and federal hazardous waste laws.
Check any number of items you feel would be useful to you. Complete the information on the back and mail this
form to MnTAP's address listed below. Publications listed in boldface type are either newly developed or revised
(creation/revision date in parenthesis).
EQUIPMENT AND SUPPLIES
.Aqueous Cleaning Equipment Manufacturers (4/92)
.Aqueous and Semi-Aqueous Cleaners for Metal Parts
Degreasing 13/92)
.Centrifuges {4/91)
.Coolant Maintenance & Treatment (4/91)
.Drums, Labels, Storage Equipment {3/91)
.Filter Presses (1.0/91)
.Filtration Equipment (11/91)
.Filtration Equipment; Considerations for Selecting
(7/90)
.Oil Skimmers (4/91)
.Refrigerant Processing Equip./Services (10/92)*
.Silver; Small Recovery Equipment (9/91)
.Small Ovens; Heat-Cleaning (9/91)
..Solvent Reclamation Units (7/91)
.Wastewater Recycling Systems (12/91)
OFF-SITE SERVICES FOR MINNESOTA GENERATORS
.flattery Recyclers; Household-Type (3/92)*
.Empty Container Outlets (2/91)*
.Hazardous Waste; Brokers, Transporters, Disposal '
<3/92l* -
.Industrial Scrap Plastics Outlets (8/92)
.Laboratories (5/91)
_Lead-Acid Battery Recycters/Haulers (1/92) *
JMonferrous Metal Waste Recyclers (10/921*
.Pollution Prevention Consulting Firms.(5/92)
JSOver Recycling (10/921* . •
.Solvent Recyclers/Fuel Blenders (2/92)*
JUsed Oil Filter Crushers, Haulers, Recyclers (12/911*
JJsed Oil Transporters (1/92)*
MANAGING HAZARDOUS WASTE
Auto Body Repair (8/9D*
Auto Service Industry: Alternatives to Septic System
Disposal (9/92)
Dental Clinics (6/91)*
Educational Institutions (10/86)*
Furniture/Wood Manufacturing, Refinishing (10/86)*
Hazardous Waste Facilities; Choosing (10/86)*
Labs as Generators (10/86)*
Metal Manufacturing & Finishing (10/86)*
MSDS; Using to Evaluate Wastes' (10/86)*
Oil Spill Clean-Up Guidance (7/91)
Paint & Related Materials; Management (4/91)
Printer's Shop Towels/Disposable Wipes; Removing
Solvent and Ink (8/91)*
Septic Systems and Other Disposal Wells (9/92)
Transporters; Choosing (1/92)*
Used Off Filters; Managing (1/92)*
Vehicle Maintenance/Equipment Repair (10/86)*
Waste Exchange Information and Services (4/901*
REGULATORY
Antifreeze Management (3/92)*
Generator Requirements (4/92)* •
Labeling Hazardous Waste (3/92)*
__Manifesting Hazardous Waste (4/87)*
Phone Contacts for Minnesota Generators (3/92)"
_jStorage of Hazardous Waste (8/9D*
__Storage/Transportation of Lead Acid Batteries
(2/9 2} *
Underground Storage Tanks (9/90)*
•NOTE:
Items with asterisks are distributed both by MnTAP and MPCA.
Please request these items from only one agency.
(continued on back)
1313 Bth Street 8E Suite 8O7
Minneapolis, Mlnneeota BB414-4BO4
CB1S1 6S7-464B
CBOO1 H47-OO1B CMinnesota only!
FAX 1818) 887-4786
Th» Minnesota Office of Wneta Management1* Mn TAP program !• Bupparcad with a grant to the School
at Public Mutch, Dlviaion of Environmental and Occupational Haaleh, at the University of Minnesota.
Printed on recycled paper
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WASTE REDUCTION INFORMATION
Commercial Food Producers; Source Reduction &
Disposal Alternatives (4/91)
Commercial Food Wastes; Composting &.
" Landspeading (4/91)
Cooling Towers; for Water-Use Reduction (8/91)
Empty Container Management (10/91)
.Fiberglass Fabrication; Volatile Emission Reduction
(4/91)
Food By-products; Feeding to Livestock (4/91)
Herkules Gun Washer Maintenance (11/91)*
Machine Coolant; Prolonging Use (6/91)
Metals Recycling for Platers (9/91)*
Radiator Repair/Engine Rebuilding (3/89)*
Solvent Recycling; On-Site (5/91)*
Vapor Degreasers; Emissions Reduction (7/91)*
Vapor- Degreasing/Cold Dip Processes; Alternatives
(2/92)
Waste Minimization; Fact Sheet
Waste Reduction; What Makes It Happen? (6/91)
WASTE REDUCTION CHECKLISTS
•••••^^^•^•^^^••^^••••••^••••••••^^^••^^^
These are process-specific checklists for use in
identifying waste reduction opportunities.
.Cleaning
.Coating/Painting
.Formulating
WASTE STREAMS
_Acids, Bases*
_Paints, Inks*
Machining
_0perating Procedures
Plating/Metal Finishing
.Solvents*
JJsed Oil; Managing (12/91)"
GENERAL INFORMATION
.Glossary of Hazardous Waste Terms (10/92)
_MnTAP Program Overview (4/91)
.Selecting a Consultant (1/91)
I
CASE STUDIES
.^.Pollution Prevention; One-Company's Organizational
Strategy (3/91)
Replacement of Vapor Degreasing Operation with
Deburring Process for Cleaning Metal Parts (5/92)
Soak Step Reduces Solvent Waste .from Cleaning
Paint Straining Equipment (7/91)
Solid Waste Management and Reduction in the
Restaurant Industry (12/91)
Spray Nozzle Selection Reduces Solvent Waste
Volume when Cleaning Paint Straining Equipment
(6/91)
Wastewater Recycling System Used in Paper
Manufacturing Reduces Wastewater Discharge (9/92)'
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INTERN PROJECT SUMMARIES
1991
Evaluation of Aqueous Cleaners to Replace TCA
Degreasing in a Hydraulic Pump Manufacturing
Operation (12/91)
Evaluation of Aqueous Cleaners to Replace TCA
Degreasing in a Refrigeration and Air Conditioning
Manufacturing Operation (12/91)
'__Water-Based Substitutes for Wood Finishing Lacquers
(12/91
1990
Reducing Shingle Waste at a Manufacturing Facility
Alternatives to CFC-113 Use in Cleaning Circuit
Boards
Reducing Chlorinated Solvent Emission from Three
Vapor Degreasers
1989'
Reduction of Solvent Emissions from Vapor
Degreasing '
Trichloroethylene and Stoddard Solvent Reduction
Alternatives in a Small Shop
Process Water Reduction in a Wire Milling Operation
Intern project summaries from previous years are
available upon request.
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Please send items checked to:
Name:
Company:
Address:.
Phone:
Please send me a sample copy of MnTAP's quarterly newsletter Source
Please send me a sample copy of a waste exchange bulletin
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TECHNICAL ASSISTANCE FOR CESQGs
The Massachusetts Program '
Grace Caner, Massachusetts Office of Technical Assistance
Today I'll cover a number of items. These are CESQG needs, technical assistance efforts of my office,
recommendations for a program, actual technical assistance you can provide, and outreach.
Dave Galvin of Seattle Metro gave a great overview of .CESQGs. Another reason small sources are
significant is mat they are more likely to mismanage their waste than are larger sources. In Massachusetts
there is at least one.case of,a CESQG inadvertently ruining a town's drinking water, and due to stricter
limits on discharge to air and water, this group will be increasingly scrutinized by those regulations.
If you are new to CESQGs, remember that hazardous waste regulations were developed primarily for
LQGs. Thus, these regulations and the expense of transport and disposal are burdens for CESQGs.
Important roles for government are 1) converting regulatory and technical information into laypersons'
terms, 2) researching alternative inputs and equipment, and 3) identifying and reaching VSQGs. This third
challenge requires some creative detective work and reliance on local advice on ways to reach the
audience.
The technical Assistance program of my office is a continuation of a safe waste management effort begun
in the mid-eighties. OTA staff have worked with auto body shops, hospitals, schools, at all levels,
businesses with photographic waste and commercial laboratories.
Types of technical assistance offered are on-site visits, workshops, recycling forums where vendors present
information, and recently, the establishment of a permanent drop-off center for a few VSQG wastes.
Within these types both regulatory and pollution prevention information is provided.
A Massachusetts VSQG is the same as a CESQG in terms of waste generation rate. Massachusetts
regulates hazardous waste down to zero. We estimate having 15,000 VSQGs with only four thousand
registered with the state. In comparison, SQGS number 3,000 and LQGs 640. A VSQG generates less
than 100 kilograms or 25 to 27 gallons of hazardous waste per month.
Some ways in which VSQG regulation is more relaxed than for larger sources are that accumulation time
if unlimited, allowing for more economical amounts of waste to be shipped; receipts and logs of waste
shipments are used instead of manifests and most important, VSQGs may self-transport their waste to
disposal or recycling facilities. VSQGs are required to register with the state. If a VSQG doesn't register
it will be treated as a SQG. Because of this and the simpler regulatory framework, there is some incentive
for VSQGs to identify themselves to the state.
Key points to remember when creating a program for CESQG technical assistance are to be prepared to
offer extensive education, extensive and customized outreach, to be patient (this is a difficult group to
reach), and to be prepared for anti-government sentiment. People don't want to hear that are in the
hazardous waste system.
Some general recommendations for your programs follow. Never underestimate how much outreach and
education is needed by the very small source. Technical assistance must be basic. Assume most VSQGs
don't believe that they are covered by the hazardous waste regulatory system. Keep in mind that most
VSQGs don't know common terms such as RCRA, MSDS, listed chemicals, or toxicity. You must
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educate them in these areas as well as in regulations. Technical assistance should entail technology I
transfer. In many occupations where source reduction options are scarce, discussions and brainstorming
between similar small generators is in valuable. Such discussions meet two goals: generating practical •
solutions and showing VSQGs in the same occupation that they can learn from each other. ' |
Resources you can provide to VSQGs are contact names, phone numbers and addresses of relevant •
agencies such as the board of health, DPW, state environmental, occupational health and public health |
agencies. Include readable guides to regulations, waste management and reduction, and information on
what appropriate services or products are available. •
Now I'll mention OTA's specific experiences dealing with labs, hospitals, schools and businesses with
photograph or silver waste. _
First, labs. An American Chemical Society study showed 40% of chemical waste results from allowing •
chemicals to expire. Expiration can be avoided through a centralized system of chemical purchasing and
inventorying. Such systems can flag orders of toxic chemicals. One university uses bar-coding to track
items. . •
Labs offer relatively many opportunities for input substitution and recycling. The main barrier is getting
people to change daily work habits. In labs the micro-scale technique has a lot of advantages, not just •
environmental ones. This technique reduces the quantities of chemicals used to the point needed for ™
detection by sensitive instruments. It requires using tiny vials in place of beakers. Benefits include faster
reactions, the low costs of the vials compared to beakers, and greater safety due to the small amount of I
chemicals used and stored. Also, switching to microscale is not expensive. It will save money over time •
in fewer chemical purchases. OTA can refer lab staff to training in this technique.
Other substitutions are available for lab chemicals like solvents, glass cleaners (traditionally chromic acid I
is used), carcinogenic dyes, and for mercury used in instruments and for tagging. Additionally, recycling
options exist for silver nitrate and gold solutions. •
Hospitals, like labs and schools, usually lack an inventory and purchasing system. A hospital may be the
largest discharger to a waste water treatment plant, so question what is poured in the drain. Formaldehyde •
is often disposed of this way. A substitute named Omnifax consists of alcohols and organic acids. g
Sterilizing machines are also sources of waste which should be investigated.
Schools generate some of the same institutional wastes as a hospital. Wastes shared by both schools and I
hospitals are those generated through custodial work, vehicle maintenance, grounds and lawn maintenance,
office activities, laboratories, photograph developing, and in schools, from art, and shop departments. —
Examples of alternatives available in these areas include water or citrus-based cleaners, integrated pest •
management, synthetic motor oil, and recycling of antifreeze.
Silver solution generators include a broad range of VSQG types from veterinarians to phototypesetters to I
chiropractors. In Massachusetts, many silver recovery services exist as do a range of in-house recovery ™
devices. However, VSQGs that use the popular canister with steel wool often don't maintain them. This
results in inadequate silver removal. Thus, sources should be informed about how to maintain their units. I
A persistent problem for VSQGs is the proportionally higher price they pay for waste management
services. Attempts to create a cooperative transportation arrangement (a milk run) usually fade due to fl
fears "of entering Superfund liability. These fears exists because there has not been a clear decision from •
EPA on whether a coordinating agency assumes liability if it organizes a milk run with a hazardous waste
hauler. The Printing Industries of New England and the Cape Cod Commission both abandoned the milk •
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run idea when legal counsel advised against it. One successful model by an association was not aware
that it was potentially exposed to Superfund liability. Another service OTA helped provide is a drop-off
recycling center for three wastes from VSQGS as well as households. VSQGs have brought 55-gallon
drums to the center which had to be pumped out for transfer. Must users didn't know they should bring
their state registration number and must pay for the service. This showed they were not aware of the
regulatory requirements covering them.
Regarding outreach, identifying and reaching VSQGs requires creativity. VSQGs may not belong to any
trade association because membership fees can be higher than a VSQG will pay. This means you must
do some research into the characteristics of your targeted occupation. Then you can customize your
outreach for each target and locality. Don't assume that outreach which worked for one community or
VSQG type will work for all.
Effective mediums to' reach VSQGs are local newspapers, direct mailings, the Chambers of Commerce,
trade associations, planning commissions and cooperative university extensions. Make presentations
during regularly scheduled meetings. Include civic groups with business people. Seek these captive
audiences.
Effective trade associations in my state are those of dentists, dry cleaners, science teachers, and
photographers and photomarketers. Their newsletters allow you to provide information continually. One
of these, the dental association, became very active because some members had been parties to large
Liability suits due to mismanaging their silver waste. To help its members, the association rated the
available silver recovery devices and recommended one type of in-house recovery system. This of course
made OTA's job much easier. • .
In any community small generators appreciate being brought together for informational forums tailored
to their needs. OTA organized an event at which'small autobody shop owners shared problems and
solutions over Kentucky Fried Chicken in an autobody shop. Other formats were a night presentation at
a school and an American Foreign Legion Hall. Local.groups suggested these formats, times and
locations.
An indirect way to reach VSQGs is to train health agents and waste water treatment staffs in VSQG issues
and basic source reduction concepts. These'local agents-can then identify, assist and refer VSQGs to
OTA. Among die health agents OTA is training are some which have hazardous materials bylaws to
enforce, a motivating factor in the participation.
Financial reasons to motivate VSQGs to reduce and comply are at least twofold. First, if they want a bank
loan they may face a strict property inspection before being considered. Second, even a small amount of
waste being mismanaged over time can result in fines or lawsuits large enough to bankrupt a VSQG. In
addition, VSQGs will be coming to the attention of waste water treatment plan, stormwater and clean air
regulators as the regulations become tightened.
To summarize, Massachusetts has regulations which give VSQGs more economical ways to handle and
transport their, wastes. This is a step in the right direction. Technical assistance for VSQGs needs to
include assistance with both compliance and source reduction. VSQGs don't know they're covered by
hazardous waste law or what to do to comply and reduce!
Lastly, a number of fairly simple source reduction options exist from improved housekeeping practices
to recycling or substitutions. In some cases, a substitution you identify can even get the VSQG out of
the hazardous waste system altogether.
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Permanent Programs: Orange County, California _
INTRODUCTION •
(Jim Pfaff) —
By now we've all probably had the opportunity to see some of the I
local sights of this beautiful State and wishing we could take home
some of the ambiance. • - •
Like this carefully designed city which caters to almost every •
possible human desire, the key to design success is —
planning...something many Household Hazardous Waste .Collection I
Programs have experimented with and found through a careful and _
ongoing assessment of public and environmental needs. I
Today, I'd like to share with you the success of our Household —
Hazardous Waste Program in the County of Orange, California. But I
first, we've designed-our presentation in such a way that it will m
afford you the opportunity to listen, to take notes on copies of m
the overheads provided in portfolios you can pick up in the back of _
the .room, and for you' to have a packet of materials which provides I
you with additional information we will be discussing or could not «
include during the time allotted for our presentation. B
* DEMOGRAPHICS: [Slide i - oc day]
WITHIN ITS 786 SQUARE MILES . '. . THE COUNTY OF ORANGE SUPPORTS A
DIVERSE POPULATION OF APPROXIMATELY 2.5 MILLION PEOPLE . THE
COUNTY IS COMPRISED OF 31 CITIES .AND SEVERAL POCKETS OF
•t PROGRAM HISTORY:
• IN 1984, THE BOARD OF SUPERVISORS RECOGNIZED THE NEED TO PROVIDE
RESIDENTS WITH A SAFE WAY TO DISPOSE OF THE HAZARDOUS MATERIALS
FOUND IN THE HOME AND AUTHORIZED A SERIES OF THIRTEEN TOXIC
ROUNDUPS [ Slide 2 -long lines & slide 3 -drop point] WHICH WERE
CONDUCTED IN VARIOUS LOCATIONS WITHIN THE COUNTY FROM 1985 TO 1990.
• APPROXIMATELY TEN THOUSAND RESIDENTS WERE SERVED BY THE TOXIC
ROUNDUP PROGRAM.
WITH EACH CONSECUTIVE ROUNDUP THE NUMBER OF PARTICIPANTS . . . THE
AMOUNT OF WASTE'COLLECTED AND THE COSTS ASSOCIATED. WITH THE PROGRAM
INCREASED TREMENDOUSLY.
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. THUS ... IN MARCH OF 1989 ... THE 3OARD APPROVED A PILOT
PROJECT TO ESTABLISH PERMANENT COLLECTION CENTERS. -
* PERMANENT COLLECTION CENTERS:
• THERE WERE MANY REASONS FOR CHANGING FROM ONE-DAY COLLECTION
EVENTS TO PERMANENT CENTERS.
1) PROJECT ADMINISTRATORS FELT THAT PERMANENT CENTERS WOULD
NOT ONLY PROVIDE A SAFER AND MORE CONTROLLED ENVIRONMENT TO
COLLECT MATERIALS, BUT
2) PERMANENT CENTERS WOULD BE-MORE CONVENIENT FOR RESIDENTS
AND WOULD ENCOURAGE RESIDENTS TO PROPERLY DISPOSE OF THE
HAZARDOUS WASTES THEY HAVE BEEN .STORING IN THEIR HOMES.
• CURRENTLY, THE COUNTY OF ORANGE HAS THREE PERMANENT COLLECTION
CENTERS - [ OH2 - MAP OF COUNTY W/CENTER ID]
• ONE IN THE NORTHERN END OF THE COUNTY (Opened 7/90)
• ONE IN THE WEST PORTION OF THE COUNTY (Opened 2/91)
• ONE IN THE SOUTH PART OF THE COUNTY (Opened 8/91)
A FOURTH CENTER IS SCHEDULED TO OPEN IN THE CENTRAL PORTION OF THE
COUNTY'WITHIN THE NEXT YEAR OR SO.
• THE CENTERS ARE CURRENTLY OPEN TUESDAY THROUGH SATURDAY 9:00 TO
1:00 PM - IN THE FIRST PART OF JANUARY FIRST, CENTER HOURS WILL BE
INCREASED TO MONDAY THROUGH SATURDAY 9:00 AM TO 2:00 PM
• THE CENTERS RANGE FROM 2,000 - 3,000 SQUARE FEET
• TWO OF THE THREE CENTERS HAVE ROOFS, HOWEVER, THEY ARE NOT
FULLY ENCLOSED BUILDINGS - THEY ARE MORE LIKE CARPORTS
• EACH CENTER HAS TWO OR MORE PREFABRICATED HAZARDOUS WASTE
STORAGE UNITS WHERE MATERIALS ARE STORED FOR UP TO TWO WEEKS
FISCAL YEAR 1990/91
FISCAL YEAR 1991/92
FISCAL YEAR 1992/93
1 Center full year & 1
center 4 months
21,859
.' 3 Centers full year
35,265
3 centers first 4 months
of the year
15,378
TOTAL PARTICIPATION
JULY 1990- OCT. 1992
j 72.500 I
NOTE: If existing Fiscal Year 1992/93 statistics are indicators
for the remainder of the year, the County expects to service
approximately 46,134 participants, a 31% increase over FY 1991/92.
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OVERHEAD - 3
PARTICIPATION
PARTICIPANT PROFILE
* READ THE FOLLOWING %
RESULTS FROM 19952 SURVEYS TAKEN: (In
MALES PARTICIPATING 15,121
FEMALES PARTICIPATING 3,874
AMOUNT OF TIME MATERIALS ARE STORED:
1) 2 YEARS OR MORE 9,167
2) 1-6 MONTHS 4,393
3) 1-2 YEARS 3,682
4) 6-12 MONTHS 2,487
AGE OF THE HEAD OF HOUSEHOLD:
1) OVER 61 YEARS OF AGE 4,947.
2) 41-50 YEARS OF AGE 4,880
3) 31-40 YEARS OF AGE 4,342
4) 51-60 YEARS OF AGE 4,237
5) 21-30 YEARS OF AGE 1,176
6) UNDER 20 YEARS OF AGE 47
EDUCATION LEVEL OF HEAD OF HOUSEHOLD:
Participation
decending order)
80%
20%
45%
25%
18%
12%
COLLEGE DEGREE
1)
2)
3) GRADUATE DEGREE
4) THROUGH HIGHSCHOOL
7,064
SOME COLLEGE EDUCATION 5,444
4,671
2,169
HOMEOWNERS
RENTERS .
17,422
1,738
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25% Note: 50% of population
frequenting centers is |
25% age 40 and above
23%
21%
6%
.2%
37%
28%
24%
11%
91%
9%
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OVERHEAD - 4
WASTE MANAGEMENT
FULL SERVICE CONTRACT;
• THE HAZARDOUS WASTE CONTRACTOR CURRENTLY USED ... PROVIDES
THE COUNTY WITH COMPLETE WASTE MANAGEMENT SERVICES INCLUDING
STAFFING FOR COLLECTION CENTERS. DUTIES:
• . COLLECTION OF WASTES FROM PARTICIPANTS
• . SEGREGATION " - •
• PACKAGING AND PREPARATION•OF MATERIALS FOR TRANSPORTATION
•' TRANSPORTATION •
• AND ALL ADDITIONAL DAILY ACTIVITIES
• THE COUNTY OVERSEES ALL,OPERATIONS ACTIVITIES INCLUDING CONTRACT
MONITORING, AND VERIFICATION OF MANIFESTS AND OTHER RELATED
PAPERWORK. ...
« DISPOSAL COSTS = CONTRACT COSTS: LABOR. MATERIALS.
DISPOSAL. TRANSPORTATION
CONTRACT COSTS
Tipping fee = $1.59 p/ton
FY 90/91 $1.7 Million
FY 91/92 $2.1 Million
«„ -> , -, <* <^o on ($4 million ceiling,
H f2/" * !4!if14 with estimated $2?!
AVERAGE COST PER VEHICLE
PER MONTH
$76 (Costs do, not include
inhouse County costs
$68 for services, supplies
& manpower charged to
$46 this section of budget;
Reasons for decrease:
- changes in waste management - paint box allowed on site instead
of being shipped off which saved significant amounts of $ on transportation
- careful contract negotiation with specific service and costs
outlined
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TOTAL GALLONS ;
COLLECTED
Motor Oil
Aerosols - # of
cans
Paint {Latex & OH)
Latex Paint -
Recycled
FISCAL YEAR
1990/91
(1 center full year)
1 centers months
130,360
45,000
35,150
78,000
0
FISCAL YEAR
1991/92
(2 centers full year)
164,790
68,635
52,170
87,149
2,363 *
FISCAL YEAR
1992/93
(3 centers 4
months)
72,642
28,991
23,680
34,375
2,092 .
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* COMMENCED 12/91 - 7 MONTHS OF DATA ONLY
*
NOTE: Only select quantities of waste collected are included here.
The County expects to receive approximately 218,000 gallons of HHW
for FY 1992/93. Recycled Latex Paint quantities are expected to
remain constant, depending on effective marketing of paint and .
demand for it.
• MOTOR OIL AND ANTIFREEZE IS BULKED AT EACH COLLECTION CENTER
• EACH MONTH ... 10 DRUMS OF LATEX PAINT FROM THE HUNTINGTON
BEACH CENTER ARE BULKED AND SENT TO A( LOCAL LATEX PAINT
RECYCLER
• THE PAINT IS DISTRIBUTED TO' CITIES,-NON-PROFIT GROUPS/CLUBS
ETC - FREE OF CHARGE BECAUSE IT IS CHEAPER'THAN DISPOSING OF
THE MATERIAL
• THE REMAINDER OF LATEX AND OIL BASE PAINTS AND THINNERS ARE
COLLECTED IN A 40-YARD COLLECTION/TRANSPORTATION ROLL-OFF BOX.
EACH ROLL-OFF CONTAINS APPROXIMATELY 1,500 GALLONS OF PAINT
WHEN THE ROLL-OFF BOX IS FULL, THE ENTIRE BOX IS TRANSPORTED TO THE
TSDF FOR PROCESSING (FUELS BLENDING)
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* RECAP INFORMATION ON THE OVERHEAD
ENDING:
Moving right.along, I will now turn over this presentation to my
J| colleague, Jaimy Jackson, to share with you Orange County
approaches to siting our permanent collection centers, the
" challenges we experienced, as'well as the advantages and
• • disadvantages of siting collection centers.
SITING CENTERS ON PRIVATE PROPERTY:
• • THE PLANNING AND DESIGN PROCESS PRECEDING THE OPENING OF THE
FIRST CENTER TOOK ABOUT 16 MONTHS
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• A LAST MINUTE CHALLENGE SURFACED ABOUT TWO MONTHS BEFORE THE
FIRST CENTER WAS SCHEDULED TO OPEN, WHICH DELAYED THE PROJECT FOR
FOUR MONTHS. . .
THE CHALLENGE; > • -. • - .- -
t "* .
• THE COUNTY CONTACTED SEVERAL SOLID WASTE TRANSFER STATIONS
OWNERS WITH THE PROPOSAL TO SITE COLLECTION CENTERS ON THEIR
PROPERTY. FROM. THE BEGINNING, THE TRANSFER STATION OWNERS WERE
™ SUPPORTIVE OF DEVELOPING OF A PUBLIC/PRIVATE PARTNERSHIP WITH THE
• COUNTY.
• THE ORIGINAL PLAN WAS FOR THE COUNTY TO PROVIDE TRANSFER
STATION STAFF WITH THE REQUIRED 40 HOUR TRAINING. THE TRANSFER
STATION STAFF WOULD COLLECT WASTE FROM PARTICIPANTS, AS NEEDED, IN
ADDITION TO OTHER ASSIGNED DUTIES.
• • THE TRANSFER STATION OWNERS AGREED WITH THE PROPOSED STAFFING
IDEA UNTIL THE TRANSFER STATION OWNERS SPOKE WITH 'THEIR INSURANCE
J ' CARRIERS.
H • THE INSURANCE CARRIERS WERE CONCERNED ABOUT THE LIABILITY
PLACED UPON THE TRANSFER STATIONS AND INSISTED THAT TRANSFER
I • STATION STAFF BE EXCLUDED FROM ANY INVOLVEMENT IN OPERATING THE
COLLECTION CENTERS . 561
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• THE INSURANCE AGENTS ALONG WITH THE TRANSFER STATIONS
OWNERS REQUESTED A LICENSE "AGREEMENT STATING THAT THE COUNTY
ASSUMED COMPLETE LIABILITY FOR ALL COLLECTION CENTER ACTIVITIES 'AND
. . '. THE COUNTY WOULD PAY THE TRANSFER STATION RESTITUTION SHOULD
ANYTHING OCCUR AT THE -COLLECTION CENTER THAT WOULD CAUSE AN
INTERRUPTION TO THE BUSINESS OF THE TRANSFER STATION. ^ •
• -BASED UPON THESE PROBLEMS, IT WAS DETERMINED THAT THE COUNTY
WOULD HAVE TO HIRE STAFF TO OPERATE THE COLLECTION CENTERS. THUS, I
IT WAS DETERMINED THAT A FULL SERVICE CONTRACTOR WOULD BE NECESSARY
TO ADEQUATELY OPERATE THE CENTERS. |
• IN THE LONG RUN . •. . USING CONTRACT STAFF TO OPERATE THE _
CENTERS INSTEAD OF USING TRANSFER STATION STAFF TO WORK THE •
CENTERS, AS ORIGINALLY PROPOSED, WORKED OUT FOR THE BEST. SINCE
THE ACTUAL PARTICIPATION RATE IS THREE TIMES THE ESTIMATED NUMBER
OF•PARTICIPANTS, STAFFING THE CENTER HAS BECOME A FULL TIME JOB, •
IT WOULD HAVE BEEN A MATTER OF TIME BEFORE THE TRANSFER STATION
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COLLECTION CENTER DUTIES
ADVANTAGES
1) MANY CITIES AND COUNTY'S, WHOM TYPICALLY ARE RESPONSIBLE FOR HHW
COLLECTION ACTIVITIES, DO NOT OWN LARGE VACANT PARCELS OF LAND UPON I
WHICH TO PLACE A HHW CENTER. OFTEN TIMES A PRIVATE COMPANY HAS THE
SPACE AVAILABLE AND IS WILLING TO ENTER INTO A LAND USAGE
AGREEMENT.
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2) THE PRIVATE COMPANY MAY BE WILLING TO PROVIDE MONETARY OR IN-
KIND CONTRIBUTIONS TO YOUR EFFORTS. THEY MAY ALSO HAVE EQUIPMENT
THAT CAN BE UTILIZED - DON'T FORGET, -THEY WILL BE RECEIVING LOTS OF
FREE "POSITIVE" PUBLICITY FOR THE COMPANY. PLUS, THEY MAY INCREASE
THEIR REVANUE BECAUSE PEOPLE WITH HHW MAY BRING OTHER MATERIALS FOR I
DISPOSAL.
3) IF THE LAND USE OR ZONING OF THE PROPERTY IS CONDUCIVE TO J
SITING A HHW CENTER ON THE PROPERTY AS PART OF AN ONGOING SIMILAR "
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* ' OPERATION, SUCH AS THE CASE WITH TWO OF OUR CENTERS THAT ARE
• LOCATED ON SOLID WASTE TRANSFER STATION PROPERTY, THE SITING
PROCESS MAY BE A BIT EASIER. THE TRANSFER STATION MAY TAKE THE LEAD
| ' IN THE CUP PROCESS.
_ *IT ''WAS "A PLUS FOR US THAT WE LOCATED TWO OF THREE CENTERS AT
™ TRANSFER STATION BECAUSE THE SURROUNDING COMMUNITY KNEW WHERE THE
I SITE WAS LOCATED DUE TO RECYCLING ACTIVITIES AT THE TRANSFER
STATION
• 4)'' THIS TYPE OF COOPERATIVE SPIRIT MAY OPEN THE DOOR TO FUTURE
ENDEAVORS BETWEEN COUNTY/CITY GOVERNMENT AND PRIVATE INDUSTRY - THE
I- PUBLIC .MAY VIEW THIS JOINT .GOVERNMENT/PRIVATE INDUSTRY EFFORT
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POSITIVELY.
DISADVANTAGES:
1} ADDITIONAL LAYER OF APPROVAL - THE LAND OWNER WILL WANT
PARTIAL CONTROL OR INPUT AS TO HOW THE CENTER WILL LOOK, HOW
• TRAFFIC WILL FLOW AND OTHER SIMILAR ISSUES. BEING THAT THE LAND
DOES NOT BELONG TO YOU, INTERACTIONS WITH THE LANDOWNER MUST BE
I DIPLOMATIC AND ACCOMMODATING.
2) DUE TO THE RIGHTS OF THE LANDOWNER, EXPECT CHANGES TO YOUR
PROJECT PLAN DURING ANY PHASE OF THE PROJECT.
• 3) THE LAND OWNER MAY CHOSE TO ELIMINATE THE PROGRAM FROM THE
PROPERTY, THUS LEAVING THE PROGRAM WITHOUT A HOME. PROBLEMS MAY
| . STEM FROM LOCATING A .NEW SITE AND THE INCONVENIENCE OF
_ DISASSEMBLING AND RELOCATING THE CENTER.
- 4) THE BOTTOM LINE NEEDS OF THE PROGRAM MAY BE IN CONFLICT WITH
I THE DESIRES OF THE PRIVATE COMPANY ( I.E. CADILLAC VS. HYUNDAI)
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SITING COLLECTION CENTERS ON PUBLIC OWNED LANDFILLS •
ADVANTAGES: ' .
1) YOU HAVE THE FREEDOM TO DESIGN THE CENTER ACCORDING TO YOUR |
NEEDS. YOU WILL BE ABLE TO PLAN FOR LONG RANGE GOALS AND FUTURE .
LAND USE NEEDS AND CAN .BUILD THE CENTER ACCORDINGLY. YOU WILL
ELIMINATE A LAYER OF APPROVAL. . I
2) SITING OF A CENTER ON A PUBLIC OWNED LANDFILL MAY BE 'EASIER
DUE TO THE ISSUES OF SIMILAR LAND USE ' (
3) AS LAND OWNER, LIABILITY MAY NOT BE A HALTING ISSUE AS YOU .
WILL-ALREADY HAVE SOME LIABILITY COVERAGE, AND'IN SOME CASES, BE ' .
SELF INSURED. •
4) MOST RESIDENTS ALREADY KNOW WHERE THE LANDFILL IS LOCATED THUS'
.THEY WILL KNOW WHERE TO GO TO DROP OFF HHW ' |
5) COUNTY STAFF IS ON SITE AT ALL TIMES FOR CONTRACT MONITORING
AND CONDUCTING HHW ACTIVITIES
6} IF A 'SPILL OCCURS, YOU CAN CLOSE THE LANDFILL WITHOUT SERIOUS •
REPERCUSSIONS, SUCH AS A LOSS OF REVENUE.
7) MANY CONSTRUCTION ACTIVITIES MAY BE ACCOMPLISHED IN-HOUSE (IE. |
ARCHITECTURE, ENGINEERING, CONSTRUCTION), WHICH COULD REDUCE
THE COST OF BUILDING THE CENTER
DISADVANTAGES: •
1} OFTEN TIMES LANDFILLS ARE PLACED IN OUT OF THE WAY 'LOCATIONS
WHICH MAY DISCOURAGE PEOPLE FROM USING THE CENTER DUE TO THE |
TRAVEL INCONVENIENCE. OBTAINING UTILITIES SUCH A PHONE, WATER _
AND ELECTRICITY"CAN.BE DIFFICULT. . .. . "
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2) MANY PEOPLE HAVE A NEGATIVE ATTITUDE ABOUT LANDFILLS IE,-
DIRTY, DUSTY, ETC AND MAY NOT PARTICIPATE |
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3) COMPLETING THE PROJECT COULD BE A TIME CONSUMING EFFORT DUE TO
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GOVERNMENT. REQUIREMENTS .TO OBTAIN BIDS ON SERVICES, ETC.
GOVERNMENT INTERNAL PROCESSES -'CAN. BE 'QUITE LENGTHY, WHILE
PRIVATE FIRMS CAN HIRE WHOM THEY WISH TO BUILD THE SITE.
GOVERNMENT TO GOVERNMENT SITING
EXPLAIN IRVINE PROJECT
ADVANTAGES t
1) COSTS FOR CENTER MAY BE SHARED AMONG AGENCIES; INCLUDING FUNDS
• FOR PUBLICITY & EDUCATION
2)" THE WORKING RELATIONSHIP BETWEEN GOVERNMENT AGENCIES PROVIDES
J RESIDENTS WITH A POSITIVE IMAGE OF GOVERNMENT WORKING TOGETHER FOR
THE BENEFIT OF THE COMMUNITY
• 3) PROVIDES ADDITIONAL SITING OPPORTUNITIES AS THE COUNTY MAY NOT
• HAVE A LOCATION AVAILABLE TO SITE A CENTER, WHILE THE CITY HAS
PROPERTY AVAILABLE.
I DISADVANTAGES;
1) IF THE PROJECT IS CITY GOVERNMENT TO COUNTY GOVERNMENT, THE
• ISSUE OF LOCAL GOVERNMENT CONTROL OF LAND USE MAY BE AN OBSTACLE.
• (IE THE CITY MAY WANT TO HAVE EQUAL, OR MORE, AUTHORITY AS TO HOW
THE PROJECT WILL BE ACCOMPLISHED.)
• 2) THERE WILL BE AN ADDITIONAL LAYER OF APPROVAL NEEDED ( IE CITY
COUNCIL, CITY RESIDENTS, BUSINESSES IN THE AREA)
• 3) IT IS POSSIBLE TO HAVE ADDITIONAL ENVIRONMENTAL RESTRICTIONS,
• DEPENDING ON THE CITY AND THEIR INTERNAL ENVIRONMENTAL REQUIREMENTS
4) BUDGETS MAY BE LIMITED, PROHIBITING ANYTHING BUT THE
NECESSITIES
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ORANGE COUNTY IS HOME TO SOME 75 ENVIRONMENTAL GROUPS AND
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ASSOCIATIONS. DUE TO OUR PROLIFIC COAST LINE, ORANGE COUNTIANS
ARE, ON THE AVERAGE, ENVIRONMENTALLY AWARE AND PARTICIPATE IN PRO-
ENVIRONMENT ACTIVITIES. AS EVIDENCED EARLIER BY PARTICIPATION
FIGURES FROM THE TOXIC ROUNDUPS, ORANGE COUNTIANS ARE USING THE •
PERMANENT COLLECTION CENTERS.
HOWEVER, ACCORDING TO SURVEY STATISTICS THERE IS A NEED TO FOCUS •
EDUCATION CAMPAIGN EFFORTS OF THOSE PEOPLE BELOW THE AGE OF 30.
ADVERTISING: |
• THE OPENING OF THE FIRST REGIONAL CENTER IN ANAHEIM WAS A
LEARNING EXPERIENCE FOR THE "POWER OF NEWSPAPERS".
• MANAGEMENT DETERMINED TO OPEN THE CENTER IN A LOW KEY FASHION •
WITHOUT PAID ADVERTISING, THEY DID NOT WANT A "ROUNDUP"
TYPE SITUATION, IN FACT, THEY DID NOT WANT THE NEWSPAPERS TO |
RUN ARTICLES UNTIL AFTER THE FIRST COUPLE OF WEEKS. —
• HOWEVER, THE LOCAL NEWSPAPERS INSISTED ON RUNNING ARTICLES •
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ABOUT THE CENTER. IT WAS DUE TO THESE ARTICLES THAT THE FIRST
FEW WEEKS AFTER OPENING THE FIRST CENTER WAS LIKE HAVING A
MINI-TOXIC ROUNDUP EVERY DAY. CARS WERE LINED UP ALL DAY FOR
SEVERAL WEEKS.
• SINCE THAT TIME, PARTICIPATION HAS BEEN STEADY AND PAID
ADVERTISING HAS NOT BEEN INITIATED. BASED UPON THE COLLECTION •
CENTER SURVEY. RESULTS OF THE 20,000 RESPONSES, 7,700
PARTICIPANTS SAY THEY HEARD ABOUT THE COLLECTION CENTERS J
THROUGH THE NEWSPAPER - WORD OF MOUTH IS ALSO A POWERFUL TOOL
WITH 2,700 PEOPLE LEARNING ABOUT THE CENTERS THROUGH A FRIEND
- THE HAZARDOUS MATERIALS HOTLINE, WHICH PROVIDES INFORMATION
ABOUT THE COLLECTION CENTERS, INFORMED ABOUT 2,700 RESIDENTS
OF THE CENTERS AVAILABILITY
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NEWSPAPER ARTICLES WERE ALSO PRINTED PRIOR TO OPENING THE
OTHER TWO CENTERS. EACH TIME AN ARTICLE IS RUN ABOUT ANY
OF THE CENTERS, PARTICIPATION'INCREASES AT ALL CENTERS.
THE ONLY FORMAL ADVERTISING INITIATED HAS BEEN THROUGH
THE USE OF UTILITY BILL INSERTS ADVERTISING THE SOUTH COUNTY
COLLECTION CENTER. THIS PARTICULAR CENTER IS' NOT LOCATED AS
CONVENIENTLY AS THE OTHER TWO CENTERS AND THUS HAS 'A LOWER
PARTICIPATION RATE.
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_ • SEVERAL LOCAL AWARDS
• 567
PROMOTIONAL ACTIVITIES:
PROMOTIONAL ACTIVITIES INCLUDE:
• PROVIDING EDUCATIONAL MATERIALS AT LOCAL FAIRS AND COMMUNITY
FUNCTIONS
• PRESENTATIONS TO VARIOUS CLUBS, CIVIC ORGANIZATIONS AND
ASSOCIATIONS
MATERIALS DEVELOPMENT & DISTRIBUTION:
• THE . EDUCATIONAL MATERIALS YOU HAVE RECEIVED ARE THOSE
DEVELOPED BY IWMD - (GO THROUGH THE PORT , QUICKLY)
• MATERIALS ARE DEVELOPED IN-HOUSE
• EDUCATIONAL 'MATERIALS . ARE. DISTRIBUTED AT THE COLLECTION
CENTERS, CITY HALLS, FIRE DEPARTMENT, OTHER COUNTY AGENCIES
AND AT PRESENTATIONS TO VARIOUS CIVIC ORGANIZATIONS AND CLUBS.
RECOGNITION
THE COUNTY OF .ORANGE HAS BEEN RECOGNIZED BY MANY ORGANIZATIONS FOR
THE HOUSEHOLD HAZARDOUS WASTE COLLECTION PROGRAM:
HONORABLE MENTION - SOLID WASTE ASSOCIATION OF NORTH AMERICA
PUBLIC/PRIVATE PARTNERSHIP AWARD - AMERICAN SOCIETY OF PUBLIC
ADMINISTRATORS
FIRE SERVICE AWARD FOR EXCELLENCE - INTERNATIONAL ASSOCIATION OF
FIRE CHIEFS
CHALLENGE AWARDS MERIT CERTIFICATE - CALIFORNIA STATE ASSOCIATION
OF COUNTIES
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Six Month Report for the Metro South Transfer Station HHW Facility, Oregon City, Oregon 1
(Operated by Metropolitan Service District Portland, Oregon)
Sam Chandler m
BACKGROUND •
DEVELOPMENT OF THE FACILITY •
The Metropolitan Service District has been involved with the management of household hazardous
waste (HHW) since 1986, when a pilot HHW collection event was conducted. Between 1988 and 1991, I
Metro sponsored a series of collection events, generally held twice a year, and usually staged ™
simultaneously at four different locations in the Metro area. These events each serviced between 1000
and 3600 participants. In 1989 the Oregon legislature mandated that Metro establish permanent depots •
for the collection of household hazardous waste. '
Early planning for compliance with the legislature's mandate included several key decisions. It _
was decided that two facilities would be built, to be located at each of Metro's solid waste transfer •
stations; that the facilities would be designed and built from scratch, without using existing structures or *
prefabricated buildings; and that Metro would operate and staff the facility, using an outside contractor
only for transportation and disposal of wastes. •
The facility to be sited at the Metro South Transfer Station in Oregon City was designed first.
An engineering firm experienced in the design of structures for handling and storage of hazardous _
materials was utilized for the project, with Metro engineering and operations staff closely involved in'the •
design process. Because there was very little precedent for designing a Mi-service HHW facility from *
the ground up, the design team developed many original approaches. The entire design process took a
considerable amount of time and effort The cost of utilizing the engineering firm totaled more than •
$120,000, and this does not include the costs of considerable Metro staff time and support services needed "
during the design phase.
After the design was complete, funds for building the facility were authorized, and construction •
was initiated in June of 1991. The construction process took a total of seven montiis. While it was
recognized that construction of a facility of this kind would be costly, the final $1,007,000 price tag was
not anticipated during the planning process. This construction cost again does not include significant I
Metro staff time spent overseeing the construction. *
DESIGN FEATURES _
Three main factors determined the major design characteristics of the facility: the size, shape and •
grading of the site chosen for the facility; practical considerations regarding flow of materials during waste
handling operations; and compliance with numerous recent fire code regulations for facilities handling •
hazardous chemicals. |
The 1988 edition of the Uniform Fire Code, adopted as law by the State of Oregon, includes a
greatly expanded Article 80, which addresses facilities handling hazardous materials. Article 80 imposes
an array of new requirements on facilities built after the code change. Among the requirements are:
The ability to contain 20 minutes of flow from the facility fire suppression sprinkler system.
A variety of standards for the facility ventilation system.
Minimum standards for construction materials and fire containment properties of walls and doors.
Segregation and proper storage of various classes of hazardous materials.
Explosion-proof wiring and other types of hazard-resistant wiring in certain areas.
A standby generator capable of fully powering the facility in the event of power failure.
In addition to the statewide fire code requirements, the Oregon City Fire Department imposed
conditions on facility design and operation during the local permitting process. The Oregon Department
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of Environmental Quality (DEQ) also developed a set of design and operational standards for permanent
HHW facilities in Oregon. The final facility design successfully incorporates all of these regulatory
requirements.
A number of operational features were desired for the facility, and were incorporated into the
design. It was decided that wastes would be received at the front of the facility, and move toward the rear
as they were processed. The various steps were planned as follows :
First, customers are greeted and vehicles are unloaded in a drive-through canopied area
Wastes are then wheeled into the facility by facility staff into.a receiving and sorting area, where
they are staged, and then sorted either for lab-packing into drums located in the sorting area, or
sent to other parts of the facility.
Unlabeled materials are brought into a laboratory for identification.
Paints and solvent-based materials are brought into a bulking room, where they are poured into
55-gallon drums.
Drummed materials are placed in segregated storage areas.
When a drum pick-up occurs, drums are brought to a loadout dock at the rear of the facility.
Overall, the operational concepts developed during the facility design have proven to be sound,
and the facility generally functions quite well. Some aspects of the design were found to be
unsatisfactory, however, and certain alterations have been necessary:
The ventilation in the bulking room was inadequate, and a retrofitted system of exhaust ducts and
improved air flow is currently being designed and installed.
Space allocated for storage of supplies and for office and computer tasks was inadequate. A
storage room has been converted into an office space, and storage cabinets are located in various
comers throughout the facility, with some storage on the loading dock and outside of the facility
as well.
The assignment of storage space to drummed acids, bases and oxidizers was greater than actually
needed. A new arrangement for the segregated storage areas is in process. It will free up what
is currently the acids bay for other uses, including storage of supplies.
An unexpectedly high volume of material is being received at the facility, and thus inadequate
space is available for bulking of both solvent-based materials and latex paint Fortunately, a large
tunnel formerly housing a compactor was available adjacent to the facility, and is currently being
utilized for latex operations.
PREPARATION FOR STARTUP
Concurrent with the construction of the facility, Metro obtained equipment to be used in facility
operations, hired and trained staff to operate the facility, and researched some of the technical aspects of
facility operation.
Expenditures totaling about $55,000 were made to outfit the facility with equipment including:
a forklift, stainless steel tables, shelving and other furniture, a computer system, tools, carts, safety
equipment, lab equipment, and a variety of other non-disposable supplies.
Most of the facility staff hired prior to the opening of the facility were Metro .employees
experienced in hazardous waste handling through the solid waste load checking program at Metro's
transfer stations. Facility staff were given considerable additional training prior to the facility opening,
some of which was provided by outside trainers, and some .developed in-house. Standard training for all
staff includes:
OSHA 40 hour hazardous waste
Emergency response team (ERT) 24 hour training
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First aid/CPR •
Hazard communication
Respiratory protection program •
Chemical hygiene program •
Identification of unknowns
Forklift operation •
Training also includes thorough instruction on the specific operations of the HHW facility. •
Training is considered to be an ongoing effort, with additional in-house and outside training being
provided to all staff on a regular basis. fl
The operating procedures for the facility were developed by drawing on a variety of resources: "
staff experience in the hazardous waste industry, consultation with the disposal contractor selected,
observations and operation manuals from existing facilities, and staff experience with one day collection I
events. Two specific aspects of facility operation required considerable research prior to facility startup: ™
the identification of unlabeled wastes, and recycling of latex paints.
Identification of unlabeled containers received at the facility is probably the most technically •
involved aspect of facility operation. Facility staff were trained by the developers of two existing *
identification schemes- HazCat, designed for identification of the 200 most commonly spilled hazardous .
substances, and WICT, developed by the staff of the San Francisco HHW facility. In the months since •
the facility opened, our staff has developed a customized system, utilizing some of the aspects of both ™
existing systems, but more closely coordinating with the exact requirements of our disposal contractor.
Although some HHW programs do not accept latex paint, Metro decided to accept it because it I
is unacceptable as normal trash, and is a disposal problem. Upon researching the available options for
latex paint, it was determined that careful sorting and quality control could result in recycling of a
significant portion of the latex paint collected. The latex paint recycling program currently in place is •
patterned after other regional pilot programs. A sorting scheme was established and refined, with the ™
assistance of a paint recycling consultant.
PARTICIPATION, DISPOSAL AND COST DATA |
PARTICIPATION FIGURES
Metro's HHW collection events in 1988 through 1990 were held twice a year, to 1991, because •
of the impending opening of the first permanent facility, only one event was held. Apparently, the I
residents of the region have become quite conscientious about the potential problems associated with
household hazardous waste, because the opening weeks of the facility brought out a massive turnout. The •
first two weeks alone over 850 participants showed up to dispose of the wastes they had collected. This •
is particularly significant since Metro did not publicize the opening nor has there been any major
advertising to date. After the initial two weeks, the participation dropped off a bit, but it has remained •
quite steady in the months since the opening. The ongoing participation level is significantly higher than |
the estimated figures that were used during the planning process, which was projected to be under 50
customers per weekend. Nearly 40% of the facility customers are from neighborhoods within 3 miles of tt
the site. g
The facility received its first waste at the end of January, 1992. Metro employees were asked to
bring any wastes that they had in order to give the facility staff a little hands on practice, and help fine •
tune some of the procedures. On Thursday February 6,1992 the facility was opened to the general public. •
Since that time, the facility has been open every Thursday, Friday and Saturday, from 10 a.m. to 5 p.m.
Through the end of June, 1992, a total of 5148 vehicles brought waste to the facility. (Note: During June •
through October, 1992, an additional 4,273 vehicles brought waste. The current weekly participation |
averages 230 vehicles.)
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COSTS
The following is a summary of ongoing operational costs. In some places estimates were used,
and data from portions of the time period were extrapolated to the whole time period.
The largest portion of operational expenses for the Metro South HHW facility was for
transportation and disposal of drummed wastes. The total cost for disposal of all wastes collected through
the end of June, 1992, was $277,770. A breakdown of this cost by type of waste follows in the disposal
data section. '
The second largest operational cost is labor. During the facility planning process, it was expected
that three technicians and one supervisor would be sufficient to staff the facility. In actual practice, an
unexpectedly high participation level, coupled with a higher-than expected proportion of labor-intensive
wastes such as paints among the materials collected requires a staff of 12 persons to properly operate the
facility. Personnel records for the first months of operation of the facility indicate that it takes an average
of about 2.4 hours of labor per participant serviced.
It should be noted that the more labor intensive aspects of facility operation generally result in
significant overall cost savings. Bulking of solvent-based materials, for example, allow for disposal costs
that are greatly reduced compared to disposal of non-bulked materials through a hazardous waste
contractor. During the first two months of operation, a total.of 104 drums of non-bulked solvent-based
materials were shipped out, because the sheer volume of incoming material was overwhelming. If facility
staff had been able to bulk this material, a net savings of about $30,000 would have resulted. Sorting and
bulking of latex paint, and on-site identification of unknowns are two other labor-intensive operations
which result in a large net savings in operational costs.
In the course of a typical operating day, perhaps 140 unlabeled containers of waste are received
at the facility. About 40% of these are paints, which are categorized quickly and inexpensively. Of the
remaining unknowns, about two thirds can be identified sufficiently for disposal purposes in two or three
minutes, consuming only twenty cents or so worth of test tubes and other disposable supplies. The
remaining unknowns take more time, although rarely does it take more than fifteen minutes of work and
a few dollars in supplies to identify even the most difficult items. Using the identification scheme
developed at the facility, the equivalent of two staff persons working full time and the expenditure of
about $800 in supplies each month is all that is required to identify all unlabeled containers received. This
compares favorably to a typical charge of $50.00 per unknown levied by many hazardous waste firms,
which would result in a monthly expenditure of $84,000.
Various other supplies are used on a regular basis in the course of facility operations. The most
costly supply is empty drums for packaging of waste. Disposable personal protective clothing for facility
staff is also a significant expense. Other items used on an ongoing basis include absorbent, drum liners,
labels, and cleaning supplies. An estimated $11,500 per month is spent on all disposable supplies.
The operating costs, for the facility break down as follows:
Disposal $ 54.00
Labor 42.00
Supplies 13.00 .; ,,
Total $109.00 per participant
(Note: as of October, 1992, it appears that the disposal portion of facility costs are coming down, and total
costs are now just under $100 per participant).
The estimated total operating cost for January through June 1992 - $561,130.
RECYCLING AND DISPOSAL OF MATERIALS COLLECTED
In the following tables, information on types of materials collected, disposal methods, and amounts
of materials collected is tabulated. Amounts were calculated using manifests of materials shipped through
June 30, 1992, as well as an inventory of materials stored in the facility on that date.
Where "landfill" is indicated under disposal method, it refers to permitted hazardous waste landfill.
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Where "energy recovery" is indicated, it refers to use as a fuel at an EPA-permitted cement kiln facility. •
"Treatment" refers to processing of liquids through an industrial water-treatment system to remove
hazardous constituents, and monitored discharge of the cleaned-up water portion of the waste. I
Bulked Materials ™
For these materials, each drum contains 55 gallons of material. . M
Material Disposal Method Quantity Generated (6 months) |
Flammable liquids Energy recovery 190 drums
Flammable solids Energy recovery 82 drums m
Antifreeze Recycle 10 drums |
Latex Paint
All drums are 55 gallon drums. The landfill category also contains other water-based wastes such •
as sheet-rock compound, adhesives, etc. During the opening weeks of facility operation, a relatively low ™
percentage of the latex paint received was recycled. This was due in part to the inexperience of the facility
staff, and in part because much of the paint received initially had been stored for long periods of time. 8
The latex paint operation is now achieving a recycling rate of just below 50%. • '
Material Disposal Method Quantity Generated (6 months)
Latex paint Reprocessing 27 drums ' •
Latex paint On-site recycling '91 drums ™
Latex paint Landfill 170 drums
Lab Packs I
Lab pack drums hold separate containers of solids and liquids. The amount of waste contained
varies, but is typically 100 to 120 pounds net m
Material Disposal Method Quantity Generated (6 months) •
Acids Treatment 6.25 drums '
Acids .Landfill 20 drums " •
Alkalis Treatment . 9 drums . |
Alkalis Landfill 19.25 drums
Oxidizers Treatment 2.1 drums " • •
Oxidizers Landfill 2.75 drums . |
Pesticides Landfill 111 drums
Cleaners .Treatment 35.5 drums .
Loose Packs
Drums of aerosols contain about 235 aerosol cans. Drums of asbestos tar contain about 20 gallons
of tar. Currently we have no data on the quantity of batteries contained in loose pack drums.
The flammable materials category refers to loose packed cans of paints-and other solvent-based
materials that were shipped directly to our hazardous waste disposal contractor during the initial few weeks
of facility operation when we were overloaded with waste and were unable to bulk all materials received.
This method is no longer used.
Material Disposal Method Quantity Generated
Aerosols Incineration . 76.75 drums
Household batteries Recycle 0.125 drums
Household batteries Landfill 2.125 drums
Asbestos tars . Landfill 48 drums
Flammable materials, misc. Energy recovery 104 drums
Miscellaneous
This includes various materials that are not collected in drums. The amounts indicated are
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estimates from the volume, or extrapolations from three or four weeks of data.
Material
Isocyanates
PCB ballasts
Organic peroxides
Water reactives
Propane
Fire extinguishers
Motor oil
Lead-acid batteries
Radioactives
Infectious waste (sharps)
Gas Cylinders'
Explosives
REUSE PROGRAM
Disposal Method
Landfill
Landfill
Incineration
Incineration
Recycle
Recycle
Recycle
Recycle
Quantity Generated
120 pounds
5 gallons
15 pounds
20 pounds
12 cylinders (approx. 5 gal. size)
50 units "
1,400 gallons
330 batteries
Landfill (via state health dept.) 2 pounds
Incineration 1 small container
Treatment, recycle 4 cylinders
Detonation (bomb squad) 100 pounds
Approximately 1,500 pounds of fertilizers were used on the Metro South grounds, about five
drums of usable cleaning products and related materials were collected for later giveaway, and 150 to 200
gallons of various materials were reused by employees and associates. Small propane cylinders with mater-
ial remaining inside are utilized by the facility laboratory as fuel for a lab burner in tests requiring a flame.
NON-HAZARDOUS MATERIALS
A significant amount of packaging and other non-hazardous materials are collected along with
household hazardous waste. All steel cans resulting from the latex paint bulking operations were recycled,
totaling 25,060 pounds of metal. Two hundred yards of cardboard was also recycled (weight data is not
available). One hundred tons of regular trash was generated in the course of facility operations.
SUMMARY
Various assumptions and estimates were used to convert all incoming wastes into pounds. An
estimated total of 361,010 pounds of waste (180.5 tons) were collected through June 30, 1992. The
average customer delivered 70 Ibs. per trip.
Flammables 40% Latex \ 35% / ; ^ •
Aerosols 4% Pesticides : ' • ;3% • ..'•;'
Acids, bases and oxidizers 2% Geaners 1%
Miscellaneous 14% . .
The estimated average cost per pound was $1.55 (total operating cost $561,130 divided by 301,010
total pounds). Although not all materials were shipped out in drums, by using conversions we can
estimate that 1,108 drums of material were collected. This amounts to approximately one-fifth of a drum
per participant, and indicates an average cost per drum of $251.
As a portion of disposal costs:
Flammables 44% Latex 18%
Aerosols • ' 16% Pesticides 10%
Acids, bases and oxidizers 5% Cleaners 3%
Miscellaneous 4%
By disposal method, it breaks down as follows: •
Energy recovery 35% Recycle 29%
Landfill
Treatment
29%
2%
Incineration
Reuse
4%
1%
The following table indicates the cost per pound for disposal for each of the above disposal
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methods. These figures represent disposal costs only. Costs for labor and supplies differ only slightly •
among wastes destined for different disposal methods.
Disposal Method Average cost per pound I
Energy recovery $0.96 *
Recycle $0.02
Landfill $0.93 •
Incineration $3.02 •
Treatment $1:93
Reuse -none- •
FUTURE PLANS •
SECOND COLLECTION FACILITY —
Metro's second HHW collection facility will be located at the Metro Central Transfer Station in |
northwest Portland. The design for the facility has been completed, although some modifications to the
bulking room will be made based on what has been learned at the Metro South facility. A construction g
contractor to build the facility will be selected in August. Construction is scheduled for the fall of 1992, g
and is expected to be completed by early 1993. The Metro Central facility will have a configuration
similar to the Metro south facility, but has.a few different characteristics, so some details of the facility _
will differ. The floor plan is smaller in area than the Metro South facility, and no area equivalent to the •
latex operations area at Metro South is available, so space problems will be likely, requiring some outside
staging of non-hazardous materials and supplies. It is difficult to predict the participation level at the new
facility, but it is estimated that the total regional participation will be about one and two-thirds times the I
current participation levels when two facilities are available. ™
MOBILE COLLECTION . .
Metro is currently negotiating with Oregon Department of Environmental Quality (DEQ) •
regarding a DEQ-funded Metro-operated mobile collection program for the Metro regioa
If approved, this would be a limited pilot program during the 1992-93 fiscal year to explore the viability •
of collecting various substreams of household hazardous waste in neighborhood locations distant from the
two permanent facilities. Many of the details of this program have yet to be finalized.
COST-SAVING AND ENVIRONMENTALLY PREFERABLE INNOVATIONS g
One of the advantages of using Metro staff to operate the HHW facility is the large degree of
control that may be exercised over packaging and disposal of materials collected. Metro staff is •
continually searching for practices which can either reduce the cost of waste disposal or provide disposal |
methods which are higher on the waste reduction hierarchy, or ideally, do both simultaneously. Several
innovations are currently under development. •
Reuse Program •
Facility staff are undertaking an ambitious program to find users for certain reusable items
received at the facility. This will not involve a browseable collection of materials like some other •
facilities have developed, but will entail keeping potentially reusable materials at an off-site storage "
location, networking with local community and social service groups, and giving away materials by
appointment Specific procedural guidelines for the reuse program are currently under development I
Recycling of Paint Solids • . .
A disposal facility has been located which will accept the solids generated in the course of bulking •
oil-based paints, burn off the organic portion in a rotary kiln, and sell the solids to a paint manufacturer. |
Once approved, this will result in lower costs for managing this waste stream, and will provide a disposal
method that is higher on the waste management hierarchy. (Note: this arragement was approved in
September, and has already resulted in savings of over $20,000).
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Recycling of Aerosols
Facility staff are researching and designing equipment that can puncture spray cans, release the
liquid contents into a drum, and route the hydrocarbon propellants into a state-of-the-art compost filtration
system that will break down the propellant, emitting only carbon dioxide and water. This will allow the
metal cans to be recycled, and significantly reduce disposal costs. This system may also be used -for
puncturing empty propane tanks (the type used in camping stoves), and treating the trace amounts of
propane left in these tanks when "empty".
Bulking of Cleaners
Currently, items such as household detergents and cleaners are lab-packed in the facility receiving area,
and shipped to the disposal contractor's site, where they are bulked and sent to a treatment facility for
treatment and eventual discharge to the sewer. Soon facility staff will begin pouring these items into a
55-gallon drum on site, which will result in significant cost savings. This will include only items in the
pH 3 to 11 range. All these materials are considered non-hazardous under most regulations, but are not
acceptable for disposal as normal trash.
Solidification of Latex
The portion of latex paint that is collected that is not recyclable is currently being sent to a
hazardous waste contractor for solidification and disposal in a hazardous waste landfill. Facility staff has
found that the sorting scheme used for latex paint is able to exclude paints high in lead and mercury.
Thus only the high heavy metal portion need be sent out as hazardous waste, while the remainder may
be solidified on site and sent to a municipal landfill as a special waste. Once procedures are finalized and
approval is obtained from the landfill, a substantial cost savings will result.
Barcode System
Facility staff will soon utilize a portable barcode reading system to inventory all lab-packed
wastes. While this system required a capital investment for hardware and programming, it is expected to
result in reduction of the amount of labor devoted to paperwork, as well as prevent costly and time-
consuming packaging errors which if uncorrected could result in fines from regulatory agencies.
CONCLUSION
The first six months of operation of the Metro South Household Hazardous Waste Collection
Facility have been a remarkable success. Some of the planning projections prior to the facility opening
estimated that 2% of the households located within a 15 minute drive of the facility would bring wastes
during the first year, which would have resulted in under fifty participants per week. The actual turnout
has been five times that predicted level, and yet all residents who made use of the facility were serviced
safely and efficiently. There were no long lines waiting for service, no significant spills or accidents, and
all waste was processed in a safe manner and within the constraints of the facility permits.
If the participation rate achieved during the opening months continues through January of 1993,
then a total of 12,342 households will be serviced during the first year of operation. This amounts to 2.6%
of the households in the entire Metro region. Not only would this be an excellent accomplishment for a
single facility in its first year of operation, it would signify the diversion of 420 tons of hazardous
materials from the regional landfill and other potentially environmentally destructive resting places.
The fact that operating expenses of over one million dollars would be incurred in the course of
servicing just one-fortieth of the population does however beg the question of the potential costs of
servicing most or all households. While it probably wouldn't cost a full forty-times as much, it certainly
would run into many millions of dollars. This fact not only underscores the importance of efforts to find
more efficient disposal methods, it also forcefully argues for a strong campaign to educate the region's
population to buy only what they will use, find other users for their leftovers, and switch to less hazardous
substitutes whenever they are available. An examination of the disposal and cost figures generated at the
facility can help set priorities for both types of waste reduction efforts.
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Wastes with a high per pound cost for example, are an obvious target for future reduction efforts, I
as are types of -waste that are responsible for a relatively high proportion of disposal costs, but only •
constitute a small proportion of incoming materials. Aerosol cans, for example, are losers in both of these •
categories. For this reason disposal alternatives for aerosols are currently being actively pursued by facility |
staff. Another example is pesticides, which make up 3% of incoming materials, but account for 10% of
disposal costs. There is very little that can be done with pesticides once they are received for disposal, •
suggesting that education efforts should focus on pesticide use habits as a high priority. J
The first six months of operation of the Metro South HHW facility have been quite a challenge,
and much has been learned in the course of successfully meeting that challenge. We are now in an •
excellent position to move forward with our plans for further improvements in operational methods, |
providing HHW collection in neighborhood locations, contributing to public education efforts, and startup
of Metro's second HHW collection facility. •
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PERMANENT HOUSEHOLD HAZARDOUS
WASTE FACILITY
CASE STUDY: ROCHESTER, NEW YORK
EDWARD J. HARDING
ASSISTANT ENGINEER
MONROE COUNTY - DIVISION OF SOLID WASTE
1845 EMERSON STREET
ROCHESTER, NY 14606
Tel.# (716) 254-4000
SINGLE COLLECTION DAY
i
Monroe County which has a population of 714,000 people with
230,000 households began its Household Hazardous Waste (HHW)
Program in October 1989 when it held a single collection day
at which fourteen hundred (1400) households participated. The
collection was sponsored by Monroe County and co-sponsored by
the City of Rochester and Eastman Kodak Company.
In order to raise funds for the collection the County
solicited donations of money and in-kind services from the
private sector to enhance the contribution by the County
($63,000) and the City ($5,000). $56,200 was raised from the
private sector to create a budget of $124,200 with which to
work with and services such as Kodak's hazardous waste
disposal ($32,410), advertising, waste oil disposal, food, and
empty container disposal valued at $13,500 was also donated.
County staff time and attorney's fees were valued at $30,000.
An operations plan was required by the New York State
Department of Environmental Conservation (NYSDEC) .The plan was
prepared with input from a number of organizations that
included: the County's Division of Solid Waste, the
Environmental Management Council, the Health Department, and
the Planning Department; the City of Rochester's Environmental
Services and the Fire Department (Hazmat team); Eastman Kodak
Company; the League of Women Voters; the Cornell Cooperative
Extension; the Adirondack Mountain Club; and some City
neighborhood groups. The plan made sure that all safety
precautions in regard to human health and the environment were
addressed. The County also went out with a Request for
Proposals to select a qualified firm that was licensed to
transport and dispose of hazardous waste. Laidlaw
Environmental Services (North East) Inc. was selected out of
four firms.
Based on the amount of money budgeted the contractor.was able
to determine approximately how many participants could be
served. The question that remained was how many people would
show up to participate. There was no preregistration of
participants so it was anyone's guess on what the response
would be. The collection day was well publicized which is
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directly related to the amount of participation.
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The City of Rochester's Environmental Services garage was used •
for the collection. The building is used to .park the City's |
fleet of garbage trucks and has overhead doors along the
entire length of each side. This allowed for an indoor _
collection with plenty of queuing of vehicles off the street I
or so we thought (See Fig. 1) . Vehicular flow was set up so ™
that four (4) lines of cars could drive through the building
at which all acceptable materials would be collected. A fifth •
line, our "express" line, was established outside the building R
at which only used motor oil and lead-acid batteries were
accepted. The collection was scheduled to begin at 9:00 a.m. M
and end at 2:00 p.m. Cars began arriving at 8:20 a.m. By the •
time the first cars went through the line at 9:00 a.m. the
cars were backed up a considerable distance, a situation that
continued throughout the day. •
Participation was so great that not everyone could be served.
At 1:15 p.m. the police were instructed to allow no more cars •
to get in line. This resulted in some disgruntled residents |
and some abandoned waste along the roadside. The number of
calls following the collection from those turned away and ^
because of the media coverage demonstrated the need for an I
expanded program. The development of a permanent facility was ™
felt to be the best answer to the problem.
SITING 1
With the need for a permanent facility established, a site had •
to be selected that would be centrally located to the general I
population in the county, on County property, and in a secure
area. Sites that were considered included County sewage
treatment plants, the Resource Recovery Facility/Transfer •
Station and the County's lola Complex which is a County m
operations facility. An evaluation of the sites determined
that the Tola Complex was the most suitable location. •
The Neighborhood Association in the area was contacted to
inform them of the County's intent and explain the project. _
This helped to alleviate the fear that often develops when the •
words hazardous waste are associated with a project. It should "
be emphasized that the facility is merely a transfer station
for HHW and that nothing will be disposed of there. Since the •
materials are received from households, there should be more I
of a concern about what one's neighbor may have stored in
their house than at a facility that is equipped to temporarily •
store the same materials. |
FACILITY DESIGN
The County sent out a Request for Qualifications to select a
consultant for the project. Malcolm Pirnie Inc. was chosen. In
an effort to cut costs, the County assisted the consultant in
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w " - ft-*n
OTY HMJftf
TOSH :
"^ t|
^•ucm
City of Rochester
. Dapt. of Environmental Services
Solid wa,te Collection
Co If ax 5tr««t Garage
T]
r v":
-COWTY OF MONROE
HOUSEHOLD HAiARDCJOS WASTE COttSCTIOr: DAY
-SITE PtAN-
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EED
C f^ *^ f^ T ..m.
it-fcre ffrn rrn
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CCD
Figure 1
.X "TOUACl IWIT* \
| __ QM ji-^"^ ftJ X^KKPIOSION IllCl.li;*' I'ANtLI,
.s- t ^^s, M •sc .Ji
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I . PKTICIOt 4 ClItKICM, MC* "—' I
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UONSOE COUWTY DIVISION Of SOLIO WASTE
UONROE COUNTY. NEW YORK
HOUSEHOLD HAZARDOUS WASTE
COLLECTION AND TRANSFER FACILITY
SCHEMATIC OF OPERATIONS
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the design and preparation of the permit application. A Permit g
to Construct was obtained from the NYSDEC in six (6) months
and the Permit to Operate was obtained in eight (8) months.
The facility is a prefabricated metal building (Butler) with ™
an overall dimension of 35' x 60', half of which is the
operations area for material classification and packaging and •
the other half is a roofed drive-thru for receiving and |
shipping waste materials (See Fig. 2). Both areas have
concrete floors, the operations area is epoxy coated. Two _
prefabricated chemical storage units (Safety Storage Inc.) •
abut the back of the building so that they can be accessed "
from inside the operations area. The wall between the roofed
drive-thru and the operations area contains two (2) overhead •
doors and a mandoor. The chemical storage units are connected •
to the exterior wall of the building opposite the overhead
doors. The facility construction was also a joint effort •
between a private contractor and County work forces. The J
County performed all of the plumbing and electrical work while
the contractor performed the rest. The cost for the building
construction was as follows: $176,000 General Contractor, •
$79,000 County Work Forces, $45,000 2-Chemical storage Units. •
The Building was constructed on an area of fill and required
pilings and a reinforced slab/foundation that added to the •
general contractor's cost. The cost for engineering services |
was $71,000 which included preparation of the permit
application, a bid specification, and construction inspection _
and certification. •
The operations area, which is 17.5' x 60' contains the
following safety features: epoxy-coated floor which slopes to •
two sump pits, ventilation fan that is connected to an I
automatic louver on the opposite side of the building from the
fan, emergency eyewash and shower, smoke detector, wet •
sprinkler system, an automatic dialer, and power "shut down" |
buttons at each exit. The prefabricated chemical storage units
have the following safety features: explosion-proof lighting, _
ventilation fan, spill containment, dry-chemical fire •
suppression system, air vents, and the flammable material •
storage unit has explosion-relief panels.Both units have
shelves that are good for storing the smaller containers of •
materials. |
OPERATIONS |
The facility opened in September 1991 and is being operated
by Laidlaw Environmental Services (North East) Inc. As part of
the operation, Eastman Kodak Company of Rochester is donating •
its services to dispose of the oil-based paints, driveway •
sealers, and paint-related materials that are received.
Laidlaw is responsible for the remainder of the materials that •
are received. |
Materials accepted at the facility include: pesticides,
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poisons, household cleaners, oil-based paint, solvents, pool
chemicals, driveway sealers, photo chemicals, antifreeze,
gasoline, brake fluid, and transmission fluid. Unacceptable
materials include: radioactive materials, smoke detectors,
infectious or biological wastes, propane cylinders,
explosives, ammunition, shock sensitive materials, used motor
oil, and latex paint. Used motor oil is not accepted because
New York State law mandates its collection through service
stajtions and retailers. Latex paint may be disposed of in the
regular garbage collection as long as it is dry. While only
household generated waste is accepted, it is not unusual to
have lab chemicals brought in. There are many people who have
chemicals that were brought home from work years ago and now
want to dispose of them. Those materials can be considered
household generated. Each participant must sign their
registration form certifying that the materials they are
disposing of are household generated.
It was the County's intention to hold collections twice per
month throughout the year, but it was found that the use of
the facility is directly related to the seasons experienced in
Rochester. From late Spring through late Fall the demand for
the facility is high so collections are held every two to
three weeks. The Winter had a low participation rate so
collections will be held once per month during that time
period. The facility is operated by appointment only. This
allows for control of traffic at the facility, the ability to
work within a fixed budget, and as an indicator as whether to
schedule collections every two or three weeks. Participants
cal-1 the County's Recycling Hotline to schedule an appointment
and preregister their waste. The preregistration allows for
the ability to eliminate unacceptable materials from being
brought in and being able to instruct the homeowner on
alternative methods of disposal. Businesses attempting to
dispose of materials through the program are usually
identified at this time. Homeowners with unusually large,
quantities can be scheduled at the end of the day in order not
to disrupt a smooth flow to vehicles through the facility.
Appointments are scheduled on half hour intervals from 9:00
a.m. to 12:30 p.m. for collection days, with twelve (12) to
fifteen (15) appointments scheduled per half hour. The
grouping of participants per half hour usually results in a
smooth traffic flow because some are usually early, some on
time, and some a little late. Those who are early remembered
the collection day in October 1989 and expected to wait in
line. In most cases cars can drive right up and unload. The
longest line of cars experienced to date has been six. The
majority of the people using the facility like the appointment
system because they are in and out in minutes. There are some
though that complain that it is inconvenient and will
discourage people from disposing of materials. There is also
a number of people who do not.show up for their appointments.
A "no show" rate of fourteen percent (14%) is currently being
581
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experienced. This rate is generally consistent so the desired |
participation is achieved by overbooking by the "no show"
rate. Those who do not - show up for their appointments are •
usually the ones who have only one or two items to dispose of. I
Those who do not show up and have registered a lot of
materials to dispose of are called from the facility to find
out why they did not show up. In many cases they forgot about •
the appointment but are eager to get rid of their waste. They •
often come in later that day or reschedule. It should be noted
that the weather can also affect participation. A snowstorm •
the day before or the day of a collection will decrease the |
participation rate as well as nice sunny weather will. The
ideal weather for participation has been overcast days with a _
little rain. •
Although collections are held every two or three weeks, there
are some people who cannot make the collections. Orthodox Jews •
are not permitted to drive on Saturdays, some people work on |
Saturdays, and then there are the procrastinators who say they
are moving before the next collection. Although these types of M
situations occur, it is not that often. When they do, a •
special arrangement is made in order to receive their waste.
There are also some people who will abandon their waste at the
facility when it is closed or leave it at an unmanned •
recycling drop off center. This contributed to the decision of •
siting the facility within a County complex.
The facility operator staffs the facility with two (2) field |
chemists and one (1) technician while the County provides a
person to greet participants and obtain signatures on the _
registration forms certifying that the waste is generated from I
a household. During normal operation, one of the field •
chemists will inspect the waste as it comes in to verify that
it is acceptable. It is then removed from the vehicle and •
brought into the operations area. Large loads may require |
inspection after it is brought into the operations area.
'Should a large load be received, one of the other staff «
members will assist in unloading the vehicle so that a line of I
cars does not develop. Once waste is brought into the facility
the other field chemist will separate materials by hazard
class and place them in the appropriate area for I
containerization. Materials are either placed in drums, •
container and all, some of the liquids are bulked, and some
materials are labpacked into drums with detailed packing slips •
completed. In the event of unknown materials being received, |
field tests can usually determine its chemical
characteristics. _
Kodak's participation in this project has been very beneficial ™
to the County. As the largest employer in the County, Kodak
has shown a great interest in supporting the local •
community.The oil-based paint, driveway sealers, and paint- I
related material that Kodak disposes of is approximately two
thirds (2/3) of the materials that are received at the •
582
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facility. It is estimated that this service saves the County
approximately $80,000 annually. The paint cans and driveway
sealers are placed in plastic lined fiber drums for shipment.
Initially fifty-five (55) gallon fiber drums were filled
completely with paint cans which equaled approximately fifteen
(15) gallons of liquid paint, but due to operational problems
Kodak requested that no more than five (5) gallons of liquid
paint be placed in drums. This took affect on the August 22,
1992 collection and all those thereafter. Thirty (30) gallon
fiber drums were then used to minimize storage space. The
packing requirement for driveway sealers is two (2) five - (5)
gallon pails per thirty (30) gallon fiber drum. Spray paint
(aerosols) are also placed in a fiber drum. Paint-related
materials are bulked into fifty-five (55) gallon steel drums.
Kodak supplies fiber drums, drum liners and picks up their own
materials for disposal. The County and Kodak are currently
working on a plan to collect household generated syringes for
disposal at Kodak.
PROGRAM COST
The following cost evaluation is based on the first twenty-
four (24) collections that were held from September 1991 to
November 1992 serving 1964 households. In all, nine hundred
nineteen (919) containers of materials were generated, of
which five hundred eight-eight (588) were disposed of by Kodak
and three hundred thirty-one (331) were disposed of by
Laidlaw.A detailed description of each collection day showing
the number of participants and the materials generated can be
found in Figure 3. The average number of participants per
collection was eighty-two (82) and the cost to the County was
approximately $172,000 with an average cost of $88 per
household. Without Kodak's participation the cost to the
County would have been an additional $80,000 with an average
cost per household of $128.
The cost for operation of the facility is based on a flat fee
of $2,500 per collection day which includes the cost of labor,
drums, supplies, and safety equipment. The disposal of waste
is on a per drum basis. The total cost of disposal for the
first twenty-four collections was $109,000 for three hundred
thirty-one (331) containers of waste. A flat rate of $250 per
pickup is also included for the transportation of waste which
occurs approximately once per month depending on the volume of
materials received at collections.
Of the materials received by Kodak, three hundred thirty (330)
were drums of paint cans (cans were placed directly into the
drum). It is estimated that this equates to twenty-two hundred
forty-five (2245) gallons of liquid pa'int. Two hundred thirty-
four (234) driveway sealer drums were generated, each of which
contained two (2) - 5 gallon pails for an estimated quantity
of eleven hundred seventy (1170) gallons. In one collection,
583
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fifty-four (54) - 5 gallon pails of driveway sealer was
received from ninety-two (92) participants. The large volume
of driveway sealer received is attributed to the fact that it
is left in garages over the winter where it. freezes and
separates, making it unusable. Fifteen' (15) - 55 gallon drums
of bulked paint-related materials and nine (9) - 55 gallon
drums of aerosol spray paints were also sent to Kodak.
The largest volume of materials that are handled by Laidlaw
include poisons/pesticides (87 - 55 gallon labpacked drums),
consolidated paints/resins/adhesives (69 - 55 gallon drums),
bulked flammable liquids (39 - 55 gallon drums), and corrosive
materials (38 - 30 gallon labpacked drums).
CONCLUSION
With a year of operation completed, much has been learned of
the character of household hazardous waste and the people that
generate it. While a majority of the materials received are no
longer useful, there is a portion that is useable. People are
encouraged to find a user of their materials when scheduling
an appointment, but often do not because it is felt that it is
an inconvenience to them. When it shows up at the HHW facility
it is either taken by one of the staff or ends up being
disposed of if it is not being used for fuel blending. The
County's goal for the upcoming year is to evaluate other
programs and theirxexperience with diverting materials from
disposal. The County's Fleet Maintenance recently purchased an
antifreeze recycler and is now taking antifreeze that is
received at the HHW facility. A concern in the Northeast for
the reuse of materials is the ^freeze/thaw cycle and its
effects on the integrity of various products. Homeowners are
often not aware if their material has frozen or not which
makes it difficult in determining its useability.
It is interesting to see the many hazardous products that
people have saved for so many years. It is not unusual for
some people to have stored materials for 30 years or more. The
most unusual material that was received to date has been a
bottle of blue liquid labelled ""Holy Water." Why the person
felt it was hazardous is not known. The contractor could not
find the proper method of disposal'for it -in any of the
hazardous materials guides so the drum of consolidated organic
liquids was blessed.
hhw-conf
585
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HOUSEHOLD BATTERIES
Super Heavy Duty - Best value for table top radios and other
intermediate drain/use appliances.
Alkaline - Best for heavy drain appliances and continuous drain
applications.
I. Super Heavy Duty: 0.01% approx. 0.00%
3. Alkaline: 0.8% approx. < 0.025%
586
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Terry Telzrow •
There are two reasons one gets concerned about solid waste. . .
One: Volume
Two: Toxicity ' I
VOLUME: •
Every man, woman, and child in the U.S. uses and disposes of 8
batteries per year. The weight is 1.1 pounds and occupies a volume of 12 •
cubic inches. This calculates to 0.08% of MSW by weight and 0.014% of MSW |
by volume. Hardly a priority item in our effort to reduce MSW. But what
about conservation of resources? . _
Why all the concern and attention to household batteries? I
TOXICITY;
One can ask three questions about household batteries. •
1. Is there a REAL problem? •
2. Is there a PERCEIVED problem?
3. Does it make any difference? •
The answers are:
1. No.
2. Yes.
3. No.
I
I am not here today to debate the issue—even though our track record •
shows we can do this very successfully. We are here to tell you how we |
responded to what you and our customers perceive is a problem.
The hierarchy of handling MSW concerns is SOURCE REDUCTION. It I
certainly is a much more efficient way of keeping an element of concern out ™
of the MSW stream. In the case of household batteries, the elements of
concern have been MERCURY and CADMIUM. Mercury is in the Alkaline batteries •
in small quantities,- It-'has'been removed from Carbon Zinc batteries. •
Mercury is the electrode in the Mercuric Oxide battery and can account for
some 35% of the battery weight. These batteries are generally used as •
button cells for hearing aids, and in a lesser quantity, for some medical |
devices that require ,their unique properties.
Let's address the more common batteries first, i.e., the D, C, AA, I
AAA, and 9-Volt batteries. These are manufactured in three common systems: m
1- Carbon Zinc - Least expensive, best value for frequently used
flashlight. . ' •
I
Mercury was added to all three systems as a surface coating of the _
zinc electrode to prevent gassing. The zinc in the Carbon Zinc and Super •
Heavy Duty batteries is in strip form, while the zinc in the Alkaline m
battery is in powdered form. The powder form has 100+ times the surface
area; therefore, more mercury is required in the Alkaline cell. Tradi- •
tionally, the percentage of mercury by weight in all three systems was as •
f°110WS: WAS IS NOW
1. Carbon Zinc:_ 0.01% approx. ' 0.00% •
I
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I In 1980, _r ._ _..„„ U3eu
less mercury. mo. was even Defore the Europeans began to focus on
household batteries as a potential mercury source.
jj Mercury reductions began to be implemented in 1984 and are continuing
today as we speak. The industry in total has reduced the amount of mercury
usage by more than 86% during the .last 5 years and equally dramatic
• reductions are occurring daily. EVEREADY announced in April, 1990, the
• - introduction into the U.S. of its Ultra Low Mercury Alkaline battery with
0.025% max of mercury by weight. This represents a 97% mercury reduction in
I this product. Mercury reduction is now a competitive issue in the market
place.
What about the Carbon Zinc and Super Heavy Duty batteries? I am happy
I to tell you that "0" mercury-added batteries are'currently being marketed in
the U.S.A., Europe, and Asia. The technology, for all zero-added mercury
batteries is close and getting closer as we speak. Zero {"0") mercury
Alkaline batteries are also in our future. The industry is committed.to
• meeting this objective.
Mercuric Oxide batteries are being replaced by the new technology--
much lower mercury--Zinc-Air batteries. Hearing aids and special medical
• devices are no longer being developed around the mercuric oxide system;
• however, the system will be around for a while to power some of those
devices requiring its unique properties. The Mecuric-Oxide batteries can be
•targeted for recollection and mercury recovery, and the industry is ready to
work with municipalities to accomplish this.
Let us address the cadmium issue now. The batteries that conta-in
•cadmium are the Nickel Cadmium Rechargeable batteries—the ones that power
1 your Dustbuster and other portable power tools.
Once again, alternative technologies are being developed. The most
I likely candidate for success is the cadmium-free Nickel-Nickel Hydride
system currently under development by many manufacturers in the U.S. and
abroad. It appears unlikely, at this point in time, that it will totally
_ replace the Ni Cd system, especially in the very "high rate" demand portable
• tools. The tool industry is currently redesigning its tools to make the
• built-in Ni Cd battery "easily" removable by the consumer to facilitate its
recollection. These batteries, if collected as a homogeneous mixture of Ni
ICd batteries, can be processed to reclaim the nickel and the cadmium by
several off-shore facilities. The economics are such that this can usually
be accomplished at no cost to the municipality.
•WHAT ABOUT RECYCLING?
What about recycling for all common household batteries just to
recover resources?
•There are no recycling facilities for primary batteries currently
operating anywhere in the world. The closest process to being operable is
the Recymet plant in Acelens, Switzerland. It is now expected to be
• operational by January, 1992.
™ The projected cost to-process one metric ton of batteries F.O.B.
Acelens is 3630 Sfr. per ton or $2550. The energy required to get 1 kgm of
I zinc from this process is 3 to 6 times the energy required to get 1 kgm of
zinc from current ore borfip*
_ We need to evaluate the wisdom of expending those quantities of energy
• to recover a resource that is so plentiful in our world. We need also to
m evaluate the possible environmental impact of these recycling technologies.
I The battery industry is monitoring this closely and is supporting this
effort.
Is battery recycling in our future? The answer is ? 587 .
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TCLP TEST RESULTS
NOVEMBER, 1991
OUTSIDE INDEPENDENT LABORATORY
VWDSWORTH LABORATORIES - CANTON, OHIO
COMPOSITE (n-6)
EVEREADY ALKALINE
•ENERGIZER'
COMPOSITE (n-9)
EVEREADY 'SUPER
HEAVY DUTY'
EVEREADY 'CLASSIC'
GENERAL PURPOSE *AA'
(n-3>
D006^jQADMIUM_(CdJ
EPA MAXIMUM 1.0 mg/l
X
UCI
S
UCI
X
UCI
<0.10
<0.10
<036
<0.17
<0.29
TCLP-Toxie Characteristic Leaching Procedure(40CFR-261)SW846
x - Average UCI - Upper Confidence Interval .
EPA MAXIMUM 5.0 mg/l
COMPOSITE (n-6)
EVEREADY ALKALINE
•ENERGIZER'
x
UCI
<0 13
"
COMPOSITE (n-9)
EVEREADY 'SUPER
HEAVY DUTY'
EVEREADY 'CLASSIC'
GENERAL PURPOSE 'AA'
(n-3)
1
UCI
X
UCI
<0.10
<0.10
<0.10
<0.10
TCLP-Toxfc Characterlatlc Leaching Procedure(4OCFR~261)SW846
X - Average UCI - Upper Confidence Interval
EPA MAXIMUM 0.2 mg/l
COMPOSITE (n-6)
EVEREADY ALKALINE
•ENERGIZER-
COMPOSITE (n-9)
EVEREADY 'SUPER
HEAVY DUTY'
EVEREADY 'CLASSIC*
GENERAL PURPOSE 'AA*
(n-3)
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S
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Confidence Interval
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589
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SPENT DRW CELLS OUERALL TREATMENT
PROCESS FLOU CHART
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Removing Solvents from Latex Paint
David Maurer
Introducing...
Agenda
• Paint Industry Overview
• Paint & The Environment
• No VOC Innovation
• SPRED 2000 & L1FEMASTER 2000
Introduction
Summary
SPRED 2000 is a Breakthrough in Environmental
Technology:
- SPRED 2000 eliminates petroleum solvents that 'emit
harmful VOC vapors, which cause ozone/smog
- SPRED 2000 delivers the same quality performance
as all other Glidden SPRED Paints
SPRED 2000 is a fundamental first step for how all
latex paints will be formulated
Significant Progress Has Been Made In
Decreasing The Impact Of Paints
On The Environment: •
• Elimination of lead, chromium and mercury from
all consumer paints
» Introduction of latex paints, that have up to 90%
less petroleum-based solvents than conventional
oil-based paints
• Improved manufacturing processes to decrease
air and waste pollution
Glidden Has Been A Paint Industry Leader In
Environmental Commitment And Innovation;
• Inventor of Latex Paint in 1948
» Leader in VOC-Free Powder Coatings
• Leader in Water-Borne Can Coating Technology
• Improved Manufacturing to Decrease
Environmental Impact
Petroleum-Based Solvents And Volatile
Organic Compounds {VOC's) Are A
Key Environmental Issue:
According to the EPA - "Since 1970, reducing VOC emissions
has been the backbone of our national ozone control strategy-
It is estimated that decorative, architectural and industrial
coatings produce 9% of the VOC's emitted into the atmosphere
by manmade sources
Ground Level Ozone is produced when VOC's and Nitrogen
Oxides react in the presence of sunlight
Ground Uvel Ozone is often a major component of "smog" and
therefore VOC's can be a major contributor to Air Pollution
Solvents Are Especially Harmful To The
Earth's Atmosphere:
Solvent fumes
indoor painting
form Volatile
Organic
Compounds
(VOC's)
VOC's
Paints
Ozone
"Smog"
VOC's enter the air and
interact with sunlight and
nitrogen oxide to form
smog
Solvent fumes also can contribute to indoor air pollution
in the form of respiratory irritation during painting
Industrial Maintenance Coatings Contain The
Largest Amount Of Solvents And VOC's
Pigments
(Other) 2%
Other Ina.
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Latex Coatings Replace The Majority Of
' Solvents And VOC's With Water
SPREO 2000 Has No Volatile Organic
Compounds (VOC's)
Other Ing,
Extender
Pigments'
Solvents'VOC's
(7102)
The Solvent And VOC Content Of Paints
Have Been Steadily Dropping Over
The Last Few Decades:
• Latex paints now account for 75% of all architectural
coatings and 90% of flat sheen coatings
• New high tech raw materials and formulation
techniques
In 1992, Glidden Has Developed The First Paint
Formula That Completely Eliminates The 'Need
For Petroleum-Based Solvents
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2000
Glidden Has Developed A Revolutionary Latex
Coating That, Through Special Resins,
Eliminates The Need For Solvents And VOC's
Other Ing. {
Extender
Pigments
SolventsMOC's
0%
SPRED 2000 Also Has Virtually No Odor And
Fewer Offensive Fumes Than Regular Latex Paints
In Addition To Elimination Of Solvents And VOC's,
SPRED 2000 Has Many Additional Benefits:
• Comparable performance and quality to Glidden
SPRED paints
• Drys more quickly than regular latex paints, adding
convenience to the painting process
• Potential for safer disposal without causing air or
water pollution
SPRED 2OOO Is Available In Only A Limited
Off-White" Color Range Because Tinting Would
Add Solvents And VOC's Into The Paint
Summary
• Results to date have been encouraging:
- Wide acceptance by the retail trade and business-
to-bu'siness customers . ;
• Glidden will continue to extend its leadership position
in environmental innovation:'
- Support these innovative products
- Develop VOC-free formulas for the rest of its
product fines
Pigments (TiQ2)
This New Formula Is The Basis For SPRED 2OOO &
LIFEMASTER 2000, Which Are The First
Solvent-Free Interior Latex Paints In The U.S.:
% Solvents in Typical Paints
Oil-Based
Latex
SPRED 2000
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Developing a Safer Paint Stripper
Nancy Walsh
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Conference Presentation
Nancy E. Walsh
Do-It-Yourself Division
3M Company
"Developing a Safer Paint Stripper"
Safest Stripper™
Paint and Varnish Remover
How to develop a
successful,
safer,
environmentally better
paint remover
Product Responsibility at 3M
To address society's, our customers'
and our own expectations for a healthy
environment and for products that can
be manufactured, distributed, used and
disposed of safely
3M Do-It-Yourself Division
»,
A market driven supplier of innovative
products that will address consumer
needs in repairing, maintaining, and
enhancing of their household,
automotive and personal possessions
Starting Point:
Consumer dissatisfaction with
existing stripping methods
Existing Methods
• Chemical
• Methylene chloride
- Toluene
- Methyl ethyl ketone
- Caustics
• Mechanical
- Abrasives
- Sandblasting
- Planing
- Heat
- Hot air
- Flame
The General Challenge:
How to develop a product
aggressive enough to remove coatings
but
safe enough for humans and the
environment
Specific Development Challenges
The screening process-
Finding the
balance
between
performance
and
safety
• The use of water
- Reducing solvent, increasing safety
- Reducing cost
• The need for thickeners
- For solvent emulsification
- For vertical cling
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The Art of Invention
Adding water improved performance
Result -
A safer stripping product...
THAT WORKED!!
Specific Marketing Challenges
What the product is
How to communicate and educate about a
revolutionary product:
Future
Challenges/Opportunities
» How the product works
Safest Stripper™ Paint and Varnish Remover
* That the balance was achieved
What the product is
-Safer...
• Environmentally better...
How the product works •
• Set time
• Tools
That the balance was achieved
• Safer, yet works
- Works, yet safer
as a
TECHNOLOGY SPRINGBOARD
What other consumer needs can be
addressed by emulsion technology?
601
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Appendix I
Final Agenda
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U.S. ENVIRONMENTAL PROTECTION AGENCY
HOUSEHOLD HAZARDOUS WASTE MANAGEMENT CONFERENCE
DECEMBER 8-12, 1992 MINNEAPOLIS, MINNESOTA
AGENDA
TUESDAY, DECEMBER 8,1992
Minnesota HHW Issues Session
10:00 am
General Session:
Challenges Facing HHW Managers
Problem Materials in Minnesota
Excelsior Bay, 8th floor
10:30 am Panel: HHW and problem materials at solid waste facilities
11:30 am Lunch (on your own)
1:00 pm Concurrent Sessions I
* Management of HHW and problem materials
HW regulations; managing VSQG waste; managing HHW; OWM grants
• Reducing Problem Materials
Product exchange; marketing alternative products; home environmental audits
• Facility Design
Building and fire codes
• Problem Materials Management
Overview of battery programs; fluorescent lamps; mercury-containing wastes
2:30 pm Break
2:45 pm Concurrent Sessions II
• HHW Education Programs
Longterm education; educating across county lines; working with schools
• Minnesota HHW Programs
Extended collection days; permanent and temporary sites; regional mobile facilities
* Problem Materials Management
Automotive wastes; paint and lead-abatement wastes; hazardous components of major appliances
4: IS pm Close
U.S. EPA Household Hazardous Waste Management Conference
5:30 - 7:30 pm Registration
5:30 • 7:30 pm Reception and Cash Bar
Coatroom, 4th floor
Fifth Seasons I and II. 6th floor
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WEDNESDAY, DECEMBER 9,1992
7:00 am - 5:00 pm Registration
Coatroom, 4th floor
Ballrooms III and IV, 4th floor
8:30 * 10:00 am Opening Plenary Session
Moderator: Dana Duxbury, The Waste Watch Center
Greetings from the State — Tim Scherkenbach, MPCA
Greetings from the County — John Denis, Chairman, Hennepin County Board of Commissioners, MN
Keynote: HHW and Municipal Solid Waste — Terry Grogan, U.S. EPA, DC
Design for the Environment — Walter Stahel, The Product Life Institute, Switzerland
Implications of Mercury in MSW Incinerator Emissions — Mike Winka, NJ DEP & Energy, NJ
10:00 - 10:30 am
Break
10:30 - 12:00 noon Opening Plenary Session continued...
New Initiatives in Science Education — Herbert Thier, CEPUP-University of California, CA
An Overview of CESQG Issues — David Galvin, Seattle Metro, WA
Source Reduction Priorities — Philip Dickey, Washington Toxics Coalition, WA
12:00 • 1:45 pm
Lunch (By Prior Registration)
Ballrooms I and II, 4th floor
Luncheon Speaker: Legislative Initiatives to Reduce the Toxicity of Municipal Solid Waste
— Representative Jean Wagenius, MN
CONCURRENT WORKSHOPS 1 A-D 2:00 - 3:30 pm
Workshop 1-A - How To's
Moderator: Janelle Henderson
Why Establish an HHW Program — David Galvin, Seatde Metro, WA
Getting Organized — Suzanna Rumon, Laidlaw Environmental NE, MA
Collection & Program Options — Walter Haas, MPCA, MN
Home Storage Survey — Michael Bender, Central Vermont Regional Planning Commission, VT
EPA Indoor Air Program — Jim Darr, OPPT, U.S. EPA
Elk. 4th floor
Workshop 1-B - Paint I
Moderator: Barbara Hotchkiss
Paint Re-use and Recycling Collection Options — Carolyn Dann, WWC, MA
Sorting & Testing — George Kinney, Dakota County, MN
Reprocessing Paint — A New Method — Scott Herbert, The Green Paint Company, MA
Wayzata Bay Suite, 8th floor
Ballroom, 4th floor
Workshop 1-C - Household Batteries I
Moderator Jan Kleman
NiCad Collection and Recycling — Norm England, Portable/Rechargeable Battery Association, GA
Primary Battery Reformulation, Collection and Recycling — Terry Telzrow, Eveready Battery Company, OH
A California Study — Fernando Berton, California Integrated Waste Management Board, CA
Hennepin County's Collection Program — Cheryl Lofrano-Zaske, Hennepin County, MN
Workshop 1-D - Other Problem Wastes Lafayette Bay, 8th floor
Moderator: Jennifer Holliday
Medical Wastes: San Francisco Safe Needle Disposal Program — Brad Drda, Sanitary Fill Co., CA
White Goods — Catherine Wilt, University of Tennessee, TN
Refrigerant Recovery — Paul Smith, Sanitary Fill Co., CA
Aerosol Contents Study — Greg Crawford, Steel Can Recycling Institute, PA
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Display Room For HHW Materials
3:30- 4:00 pm Break
PinelCedar Lake, 4th floor
CONCURRENT WORKSHOPS 2 A-E 4:00 - 5:30 pm
Workshop 2-A - How To's
Moderator: Shirli Axelrod
LiabUity — John Fogarty, U.S. EPA, DC
RCRA & HHW — Charlotte Mooney, OSW, U.S. EPA, DC
Roundtable Discussion
Elk, 4th floor
Wayiata Bay Suite, 8th floor
Workshop 2-B - Paint D Market Issues
Moderator: Michael Frishman •
Marketing Recycled Paint — Anne Thorson, Washington County Public Health, MN
A Paint Re-use and Recycling Consensus — Tracy Bone, OSW, U.S. EPA, WA
GSA's Procurement Process — Carolyn Dann, WWC, MA
Latex Paint Waste Treatment/Recycling by Pyrolysis — Phil Farina, Environmental Purification Industries, OH
Workshop 2-C - Household Batteries H: Recycling in the U.S.
Moderator Leslie Goldsmith
INMETCO's Nickel-Cadmium Recycling System — John Patterson, INMETCO, PA
Mercury Refining — Alan Wilds, Mercury Refining, NY
A New U.S. Battery Recycling Facility — Bill Meador, R&R Resource Recovery, TX
Workshop 2-D - Fluorescent Lamps
Moderator: Judy Orttung
Fluorescent Lamp Recycling in the U.S. — Dana Duxbury, WWC, MA
Lamp Maker Initiatives — Beverly Grimm, GE Lighting, OH
New Developments in Europe — Christer Sundberg, MRT System AB, Sweden
Workshop 2-E - Collection Case Studies I
Moderator: Martha Beck
Programs in Florida — Jan Kleman, DER, FL
The CPA Region 8 Program — Brian Rimar, Region 8 U.S. EPA, CO
The Delaware Pilots — Julie Wilke, Delaware Solid Waste Authority, DE
Texas One-Days — Ingrid Dierlam, Texas Water Commission, TX
Spring Park, 8th floor
Lafayette Bay, 8th floor
Deer, 4th floor
Display Room For HHW Materials
5:30 • 7:00 pm Reception and Cash Bar
Pine\Cedar Lake. 4th floor
Foyer, 4th floor
OPTIONAL Evening Activity: Minnesota's new Mall of America (express bus: $1.60 / 1-35-off peak, each way;
bus schedule and maps available at registration desk).
8:00 am - 5:00 pm
7:15 pm - 8:15 am
THURSDAY, DECEMBER 10,1992
Registration Coatroom, 4th floor
Networking Breakfast: Minnesota Metropolitan Council Paint Grant Study
— A light breakfast will be served. Register at Conference. Spring Bay, 8th floor
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CONCURRENT WORKSHOPS 3 A-E 8:30 -10:00 am
Workshop 3-A - How To's
Moderator: Michael Bender
Developing an RFP — LeeAnn Merashoff, Laidlaw Environmental Services (NE), MA
Site Selection — AJ. Novak, Chemical Waste Management, IL
Permitting and Plan Approval — Sharon Render, NY DEC, NY
Negotiating a Contract — Liz McCormick, Laidlaw Environmental Services, SC
Elk, 4th floor
Workshop 3-B - Pesticide Use, Collection and Reduction
Moderator Marie Steinwachs
Overview of Farm Pesticide Collection Programs — Chuck Cubbage, Department of Agriculture, MI
National Home & Garden Pestkide Use Survey — Tracy Bone, U.S. EPA, DC
Minnesota's Farm Pesticide Program's — Larry Palmer, Department of Agriculture, MN
Deer, 4th floor
Workshop 3-C • Education I — Schools: Implementation and Evaluation
Moderator: Michael Frishman
Environmental Education in the Schools: Minnesota's Experience — Shirley Dougherty,
Department of Education, MN
Integrating HHW into an Environmental Curriculum — Sarah Dewey, HHWP, MO
Evaluating Effectiveness — Shirley Niemeyer, University of Nebraska-Lincoln, MB
• Ballroom, 4th floor
Workshop 3-D • Used Oil & Filters
Moderator: Margit Hentschel-Duxbury
EPA's Management Standards — Charlotte Mooney, OSW, U.S. EPA, DC
Washington State's Program — Bill Green, Department of Ecology, WA
API's Program — Craig Campbell, API, DC
Workshop 3-E - Waste Management I: Waste Types and Management
Moderator Fernando Berton
Waste Types and Quantities — George Kinney, Dakota County, MN
Which HHW Is Reusable / Recyclable? — Brian Johnson, Santa Monica, CA
Identifying HHW — Deanna Seaman, Norcal, CA
Recycling Antifreeze — Rick Bowen, First Brands Corp.. CT ,
Display Room For HHW Materials
10:00 - 10:30 am Break
CONCURRENT WORKSHOPS 4 A-E 10:30 - 12:00 noon
Lafayette Bay, 8th floor
Wayzata Bay Suite, 8th floor
Pine/Cedar Lake, 4th floor
Elk, 4th floor
Workshop 4-A - How To's
Moderator: Bill Green
Load Checking — Kathy Kendall, Des Moines Metro Solid Waste, IA
Developing a Budget — Rachel Rosenzweig, Lancaster County, PA
Funding Via EPA's Enforcement Efforts — Brian Rimar, Region 8 U.S. EPA, CO
Creative Use of State Enforcement Efforts — Judi Frantz, California Department of Health Services, CA
Workshop 4-B - CESQG I Wayzata Bay Suite, 8th floor
Moderator: David Galvin
Overview — Ned Brooks, MPCA, MN
Federal Overview — Charlotte Mooney, OSW, U.S. EPA, DC
Overview of State Definitions, Laws, Regulations, etc. — Dana Duxbury, WWC, MA
Regulatory Information Discussion -
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Workshop 4-C - Education II — General Public . Spring Park. 8th floor
Moderator. Sarah Dewey
Changing Attitudes, Knowledge and Behavior — Shirley Niemeyer, University of Nebraska - Lincoln, NB
Neighborhood Education — Lilias Jones, Eco Solutions, CO
Measuring the Effectiveness of an Education Program — Paula Kehoe, San Francisco, CA • -
Workshop 4-D - Source Reduction I: Labeling Lafayette Bay. 8th floor
Moderator: Joan Twiton
"Chronic Hazard Labeling Guidelines" — Chuck Jacobson, Consumer Product Safety Comm., IX!
Scientific Certification Systems Product Evaluation — Kai Hagen, Scientific Certification Systems
Green Seal's Labeling Progress: Used Oil and Household Cleaners — Jim Dougherty, Green Seal, DC
Constituent Labeling — Philip Dickey, Washington Toxics Coalition, WA
Workshop 4-E - Waste Management II: Options
Moderator: George Kinney
Incineration — Robert Coffey, Rollins, DE
Fuels Blending — Joe Foley, Chemical Waste Management, IL
Treatment — Earl Finder, U.S. Filter Recovery Systems, Inc., MN
Landfills — Loren Alexander, Chemical Waste Management, IL
Deer, 4th floor
Display Room For HHW Materials
12:00 - 1:00 pro Lunch (By Prior Registration)
Luncheon Speaker: A Common Vision for Our Environmental Future
— Hubert Humphrey III, Attorney General, State of Minnesota
Pine/Cedar Lake, 4th floor
• Ballrooms I and II, 4th floor
1:00 -1:45 pm - Educational Material Poster Session
Foyer and Ballrooms I and II, 4th floor
CONCURRENT WORKSHOPS S A-D 2:00 - 3:30 pm
*
Workshop 5-A - How To's
Moderator Judi France
Health & Safety Concerns — Judy Orttung, San Bernardino, CA
Managing Costs — Martha Beck, Ingham County Health Department, MI
Personnel & Training — Donna Portner, MPCA, MN
Managing and Integrating HHW into All the Media Offices — Leslie Goldsmith, MPCA, MN
Elk, 4th floor
Workshop 5-B - CESQG U — Collection Program Case Studies
Moderator Chuck Cubbage
Kitsap County — Annie Bringloe, Kitsap County, WA
Duluth's Pilot — Ned Brooks, MPCA, MN
Anchorage — Bill Kryger, Anchorage and Tom Poliquin, Northwest EnviroService, AK
Windham — Jan Ameen, Windham Solid Waste District, VT
Wayzata Bay Suite, 8th floor
Workshop 5-C - Collection Case Studies H
Moderator: Michael Frishman
TVA's Program — Terry Kiraly, Tennessee Valley Authority, TN
Leeds, England — Elaine Kerrell, SWAP, England; Sonia Heaven, University of Southampton
Alachua County — Jill Parker, Alachua County, FL; Wilson Anthony, Quadrex Environmental, FL
Ballroom, 4th floor
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Workshop 5-D • Source Reduction H.: How to Measure Results . Lafayette Bay, 8th floor
Moderator Dana Duxbury •
Surveys — Lois Kaufman, Environmental Resource Associates, NJ
Scanning for Consumer Behavior — Adam Portner, Information Resources, Inc., NJ
Four Season Sorting — John Dceda and Susan Mitchell, MPCA, MN .. • -
Measuring Effectiveness of HHW Collection, Education and Source Reduction
Programs — Isao Kobashj, Santa Clara Department of Planning and Development, CA
Display Room For HHW Materials Pine/Cedar Lake, 4th floor
3:30 - 4:00 pm Break
CONCURRENT WORKSHOPS 6 A-D 4:00 - 5:30 pm
Workshop 6-A - Rural Programs Wayzata Bay Suite, 8th floor
Moderator: Brian Rimar
Overview of Issues — Lola Schoenrich, Minnesota Project, MN
Eastern Washington State's Program — Bill Green, Department of Ecology, WA
Roundtable Discussion — Moderated by Lola Schoenrich . ' '
Workshop 6-B - CESQG m — Information Ballroom, 4th floor
Moderator: Ned Brooks • .
Target Criteria for Ranking Businesses — David Galvin, Seattle Metro, WA
Sources of Information — Anne Moser, Seattle Metro, WA ' *
Great Lakes Technical Resource Library: A Source of Pollution Prevention Documentation
— David Liebl, University of Wisconsin, WI
Workshop 6-C - Permanent Programs I Elk, 4th floor
Moderator: Jim Gruber
Training Requirements and Technical Assistance — Leslie Goldsmith, MPCA, MN
Types of Permanent Facilities — Carolyn Dann, WWC, MA
Mobile Permanent Programs — Jennifer Holliday, Chittenden Solid Waste District, VT
Regulatory Requirements — Judi Frantz, California Department of Health Services, CA
Workshop 6-D - Source Reduction m — Availability & Effectiveness of Alternatives
Lafayette Bay, 8th floor
Moderator: Tracy Bone
Cleaning Products — Wanda Olson, Minnesota Extension, MN
Household Pesticide IPM — Subi Subrramanyam, University of Minnesota, MN
Artist Materials — Angela Babin, Safety in the Arts, NY
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| OPTIONAL Thursday Evening Special Program: 5:30 • 10:30 pm. Minnesota cuisine and activities at Aamodts
apple orchard in rural Stillwater (30 minutes east of Minneapolis). Dinner of Minnesota specialties served in a
_ restored 1880's barn followed by cross country skiing under a full moon on lighted trails around the orchard and
• clogging and Cajun dancing or relaxed fireside chatting. $30.00, ski rental extra, first 100 to register.
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FRIDAY, DECEMBER 11,1992
8:00 am - 5:00 pm Registration
CONCURRENT WORKSHOPS 7 A-D 8:30 - 10:00 am
Workshop 7-A • Waste Management HI: Controlling the Destiny of Your Waste
Moderator: Judi Frantz
Writing an RFP and Contract
Program Manager's Perspective — Jim Gruber, Hartford, VT
Contractor's Perspective — Eric Laut, Chemical Waste Management, EL
Waste Tracking — George Kinney, Dakota County, MN
Workshop 7-B • CESQG IV — Technical Assistance
Moderator: David Galvin
State Rewritable — Robert Style, WRITAR, MN
MnTAP — Donna Peterson, Minnesota Technical Assistance Program, MN
MA Program — Grace Caner, OTA, MA
Workshop 7-C - Permanent Programs n — Case Studies
Moderator: Gail Arnold " •
Orange County, CA — Jaimy Jackson and Jim Pfaff, Orange County, CA
Portland, OR — Sam Chandler, Portland METRO, OR
Rochester, NY — Ed Harding, Monroe County Solid Waste, NY
Workshop 7-D - Source Reduction IV: Reformulation
Moderator: Dana Duxbury
Removing Mercury from Household Batteries — Terry Telzrow, Eveready, OH
Removing Solvents from Latex Paint — David Maurer, Glidden Paint Company, OH
Low Hazard Paint Strippers — Nancy Walsh and Carlos Lopez, 3M, MN
Coatroom. 4th floor
Elk, 4th floor
Wayzata Bay Suite, 8th floor
Deer, 4th floor
Lafayette Bay, 8th floor
Display Room For HHW Materials
10:00 -10:30 am Break
10:30 - 12:00 noon Plenary Session
Moderator. Dana Duxbury
Questions from: Philip Dickey, David Galvin, Judy Orttung, George Kinney
Manufacturers Panel
— Jim McCabe, Chlorox, CA
— Terry Telzrow, Eveready, OH
— David Maurer, Glidden Paint Company, OH
— Darryl Brock, Monsanto, MO
— Bryan Thomlison, Church & Dwight, NJ
Contractors Panel
— Liz McCormick, Laidlaw Environmental Services, SC
— Eric Laut, Chemical Waste Management, IL
— Robert Coffey, Rollins, PA
Pine/Cedar Lake, 4th floor
Ballrooms III and IV, 4th floor
11:45 • 12:00 noon
12:00 - 1:30 pm
TOURS — 1:00 om
Closing Remarks — Charlotte Mooney, OSW, US EPA, DC
Lunch (By Prior Registration)
(See over)
Ballrooms I and II, 4th floor
609
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1:30 - 2:00 pm Video Demonstration of Incompatibles — Larry Sweetzer, Sanitary Fill Co., CA
see Registration Desk for Location
2:00 - 3:30 pm Discussion Groups — Paint
Ballrooms III and IV, 4th floor
TOURS —1:00 pm
Tour A: HHW Facilities North — 2 hours
HHW collection facilities on the northern end of the Twin Cities will include Dynex Industries in Ramsey County,
Hennepin County's collection site and battery collection program; one of Minnesota's new mobile facilities will be on
display at the Hennepin County transfer station.
Tour B: Problem Material Recyciers — 3 hours
Recyclights, a new fluorescent tube recycler in Minneapolis; JR's Appliance Disposal, freon recovery and recycler
of major appliances in Eagan in Dakota County.
Tour C: HHW Facilities South — 4 hours
HHW collection facilities south of Minneapolis at Gopher Smelting, Aptus Environmental Services (where one of
Minnesota's new mobile facilities will be available for viewing) and (weather permitting) Rice County's HHW collection
site and product exchange in Dundas.
SATURDAY, DECEMBER 12, 1992
TOUR — 8:30 am - 12:30 pm
Tour C (Facilities South) with the addition of a stop at JR's Appliance Disposal (4 hours)
TOURS — 9:00 am -12:00 noon
Tour A (Facilities North) with the addition of a stop at Recyclights. (3 hours)
Tour B (Problem Material Recyciers). (3 hours)
610
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{ Appendix II
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Final List of Speakers
611
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U.S. ENVIRONMENTAL PROTECTION AGENCY
HOUSEHOLD HAZARDOUS WASTE MANAGEMENT
CONFERENCE
DECEMBER 8-12,1992 MINNEAPOLIS, MINNESOTA
SPEAKERS
Loren Alexander
Marketing Manager Inorganics
Chemical Waste Management
3001 Butterfield Road
Oak Brook, IL 60521
708-218-1524 P
708-990-7483 F
Jan Ameen ' •
Recycling Coordinator
Windham Solid Waste Management Distr
RR 6 - Box 9-G
Brattleboro, VT 05301
802-257-0272 P
802-257-5122 F
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Wilson Anthony
Quadrex Environmental Co
1940. NW 67th Place .
Gainesville, FL 32606
904-373-6066 P
904-373-0040 F
Martha L. Beck
Program Specialist
Ingham County Health Department
5303 S. Cedar, PO Box 30161
Lansing, MI 48909
517-887-4312 P
517-887-4310 F
Fernando Berton
Senior Waste Management Specialist
California Integrated Waste Mgmt. Bd.
8800 Cal Center Drive
Sacramento, CA 95826
916-255-2348 P
916-255-2222 F
Rick Bowen
President
Prestone Technology Systems, Inc.
83 Wooster Heights Road
Danbury, CT 06813
203-731-2369 P
203-731-2518 F
512Source: The Waste Watch Center
Angela Babin .
Director, Art Hazards Information Ct
Center for Safety in the Arts —
5 Beekman Street Suite 1030 •
New York, NY 10038 •
212-227-6220 P
212-233-3846 F
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Michael Bender
Project Coordinator
Environmental Law Foundation of VT
26 State Street •
Montpelier, VT 05602 ' ••
802-229-6300 P
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Tracy Bone • ' I
Microbiologist/Office of Solid Waste"
U.S. EPA
401 M Street SW OS-301
Washington, DC 20460
202-260-5649 P
202-260-4196 F
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Annie Bringloe
Director, Solid Waste Division
Kitsap County Public Works
614 Division St., MS-27
Port Orchard, WA 98366
206-895-3931 P
206-895-4926 F
January, 1993
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Darryl Brock
Senior Registration Specialist
Monsanto
800 N.. Lindbergh Blvd.
St. Louis, MO 63167
314-694-5032 P
314-694-4028 F
Craig Campbell
Used Oil Program Coordinator
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005
202-682-8229 P
202-682-8222 F
Sam Chandler
Operations Manager
Solid Waste Dept. - METRO
2000 SW First Ave
Portland, OR 97201
503-220-1168 P
503-273-5586 F
Gregory Crawford
Director of Recycling
Steel Can Recycling Institute
680 Anderson Drive/Foster Plaza 10
'Pittsburg, PA 15220
800-876-7274 P
412-922-3213 F
Carolyn Dann
Research Associate
The Waste Watch Center
16 Haverhill Street
lAndover, MA 01810
508-470-3044 P
508-470-3384 F
iJohn Derus
Chairman
Hennepin County Board of Commissioners
2400 Government Center
inneapolis, MN 55487
612-348-3086 P
612-348-8701 F
Ned Brooks
MPCA - Hazardous Waste Division
520 North Lafayette Road
St. Paul, MN 55155-3898
612-297-8498 P
612-297-8676 F
Grace Caner
Office of Technical Assistance 19th
100 Cambridge Street - •"
Boston, MA 02202
617-727-3260 P . '
Robert Coffey
Mgr., Consumer/Commercial Marketing
Rollins Environmental Services, Inc,
P.O. Box 2349, 1 Rollins Plaza
Wilmington, DE 19899
302-426-3448 P
302-426-3873 F
Charles P. Cubbage
Director, Plant Pest Mfg. Div.
MI Department of Agriculture
P.O. Box 30017
Lansing, MI 48909 " .
517-373-9744 P
517-335-4540 F
Jim Darr
Section Chief, Risk Analysis Branch
Office of Toxic Substances U.S. EPA
401 M Street, SW TS-778
Washington, DC 20460
202-260-3441 P
202-260-1216 F
Sarah Dewey
Program Development Specialist
HHW Project
1031 East Battlefield, Suite 214
Springfield, MO 65807
417-889-5000 P
417-889-5012 F
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Philip Dickey
Household Toxics Project Director
WA Toxics Coalition
4516 University Way,- NE
Seattle, WA 98105
206-632-1545 P
206-633-1935 F
Jim Dougherty
V.P. & General Counsel
Green Seal '
1250 23rd St NW #275
Washington, DC 20037-1164
202-331-7337 P
202-331-7533 F-
Brad Drda
Haz Mat Trainer
Sanitary Fill Company
501 Tunnel Ave
San Francisco, CA 94134
415-468-2442 P
415-468-3266 F
Norm England
President
Portable/Rechargable Battery Assoc,
1000 Parkwood Circle, Suite 430
Atlanta, GA 30339
404-612-8826 P
404--612-8841 F
Earl Finder
Sales & Marketing Manager•
U.S. Filter Recovery Services, Inc.
2430 Rose Place
Roseville, MN 55113
612-633-0079 P
612-788-0312 F
Joe Foley
Director Sales Support
Chemical Waste Management
3001 Butterfield Road
Oak Brook, IL 60521
708-218-1729 P
708-990-7483 F
614
Ingrid Dierlam
Project Coordinator
Texas Water Commission
1700 N. Congress Ave. - P.O. Box 13
Austin, TX 78711-3087
512-475-4577 P
512-463-6648 F
Shirley Dougherty
Office of Environmental Education
Department of Education
Capitol Square Building - 550 Cedar
St. Paul, MN 55101
612-296-2723
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Dana Duxbury
President
The Waste Watch Center
'16 Haverhill Street
Andover, MA 01810
508-470-3044 P
508-470-3384 F
Phil Farina'
Director, Marketing/Sales
Environmental Purification Industri
2111 Champlain Street
Toledo, OH 43611
419-727-0495 P
419-727-0595 F
John Fogarty
Senior Attorney
Office of Enforcement, U.S. EPA
401 M Street, SW LE134S •
Washington, DC 20460
202-260-8865 P
202-260-3069 F
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Judi Frantz
Assoc.Hazardous Materials Specialist
California Dept. of Health Services
10151 Croydon Way, Suite 3 I
Sacramento, CA 95817 •
916-255-3604 P
916-255-3595 F
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David Galvin
Program Manager
Seattle METRO HHW 'Program, MS IHW
130 Nickerson Street, Suite 100
Seattle, WA 98109-1658
206-689-3085 P
206-689-3070 F
William P. Green
Hazardous Waste Program Planner
Solid & Hazardous Waste, Ecology Dept
P.O. Box 47600
Olympia, WA 98504-7600
206-438-7233 P
206-438-7759 F
Jim Gruber
Executive Director
Greater Upper Valley S.W. Mgmt. Dist.
428 N. Hartland Road.
White River Junction, VT 05001
802-295-3245
Kai Hagan
Scientific Certification Systems
1611 Telegraph Ave., Suite 1111
Oakland, CA 94612
510-832-1415 P
510-832-0359 F
Sonia Heaven
Civil Engineering Deptartment
Southampton University
Southampton, United Kingdom
S09 5NH,
0703-593262 P
0703-593017 F
Leslie Goldsmith
Supervisor, Special Wastes Unit
MPCA - Hazardous Waste Division
520 North Lafayette Road -
St. Paul, MN 55155-3898
612-297-8368 P
612-297-8676 F
Terry Grogan
Acting Chief, Waste Reduction & Mgmt
Office of Solid Waste U.S. EPA
401 M Street, SW OS-301
Washington, DC 20460
202-260-3346 P
202-260-4196 F
Walter Haas
MPCA - Hazardous Waste Division
714 Lake Avenue
Detroit Lakes, MN 56051
218-846-0728 P
218-846-0719 F
Ed Harding
Div. of Solid Waste, Assist. Enginee
Monroe County
1845 Emerson Street ' -
Rochester, NY 14606 •,.'. '
716-254-4000 P - ""
716-254-4216 F • • .
Scott Herbert
H20 Coatings, Inc.
P.O. Box 430
Manchaug, MA 01526
508-476-1992 P
508-476-1992 F
•Jennifer Holliday
•Hazardous Waste Coordinator
.CSWMD
11700 Troy Avenue
Colchester, VT 05446
802-655-9801 P
802-655-9816 F
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Hubert Humphrey III
Attorney General
State of Minnesota
State Capitol Building - Room 102
St. Paul, MN 55155
612-296-6196
615
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John Ikeda
Supervisor, Rules.
MPCA
520 Lafayette Road North
St. Paul, MN 55155-3898
612-296-7294 P
612-296-9707 F
Chuck Jacobson
Compliance Division
Consumer Product Safety Commission
5401 W. Bard Ave. •- Room 226
Bethesda, MD 2020.7
301-504-0400
Lilias Jones
Chair
Eco Solutions, Inc.
400 Irish Drive
Fort Collins, CO 80521
303-484-9793 P
303-491-2941 F
Paula Kehoe
Environmental Program Coordinator
San Francisco Dept. of Public Works
3801 "Third Street, Suite 600
San Francisco, CA 94124
415-695-7317 P
415-695-7377 F
Elaine Kerrell
Special Collections Project Manager
SWAP Recycling
PO Box 19, 6-8 Gt George Street
Leeds, ENGLAND LSI 6TF,
44-0532-438777
44-0532-344222
Jaimy-Jackson
Staff Analyst
Orange County IWMD
1200 North Main St, Suite 201
Santa Ana, CA 92701
714-568-4897 P
714-667-0275 F
Brian Johnson
Environmental Programs Coordinator
City of Santa Monica
200 Santa Monica Pier, Suite E
Santa Monica, CA 90401-3295
310-458-8227 P
310-393-1279 F
Lois Kaufman
Environmental Resource Associates
707 State Road - Suite 102
Princeton, NJ 08540
609-683-0187
Kathy Kendall - Witkovski
Waste Management Administrator
Des Moines Metro Area Solid Waste
521 East Locust Street •
Des Moines, IA 50309-1911
515-244-0021 P
515-244-9477 F
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George Kinney
Hazardous Waste Supervisor
Dakota County Environmental Mgmt Dep
14955 Galaxie Avenue I
Apple Valley, MN 55124 •
612-891-7541 P
612-891-7031 F
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Terry Kiraly
Project Manager
Tennessee Valley Authority
400 West Summit Hill Drive, WT 11C
Knoxville, TN 37902-1499
615-632-2537 P
615-632-2212 F
616
Jan Kleman
Environmental Specialist II
FL DER, Bureau of Waste Planning & R
2600 Blair Stone Road •
Tallahassee, FL 32399-2400
904-488-0300 P
904-922-4939 F
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Isao Kobashi
Program Manager, HHW Program
Department of Planning & Development
1735 North 1st Street - Suite-275
San Jose, CA 95112
408-441-1195 P
408-441-0365 F
Eric C. Laut
Project Development Manager
Chemical Waste Management, Inc.
1621 Auburn Ave.-
Naperville, IL 60565
708-369-9543 P
708-513-0682 F
Cheryl Lofrano-Zaske
Recycling Program Planner
Hennepin County, DEM
417 North Fifth Street
Minneapolis, MN 55401-1309
612-348-8992 P
612-348-8532 F
Jim McCabe
The Clorox Company
P.O. Box 493
Pleasanton, CA 94566
510-847-6674 P
510-847-2496 F
William Meador
President
Recovery & Reclamation, Inc.
P.O. Box 572 - 3000 Western Avenue
Pecos, TX 79772
915-447-3272 P
915-447-3038 F
Susan Mitchell
MPCA
520 Lafayette -Road North
St. Paul, MN 55155-3898
612-296-9439 P
612-296-9707 F
Bill Kryger-
Manager, Engineering & Planning
Municipality of Anchorage
1111 East 56th Avenue
Anchorage, AK 99518
907-561-1906 P
907-561-1357 F
David Liebl
Pollution Prevention Specialist
S&H Waste Ed Center - Univ. of Wise,
610 Langdon Street - Room 531
Madison, WI 53703
608-265-2360 P
608-262-6250 F
David Maurer
Manager, Product Planning.
ICI Paints NA, The Glidden Company
925 Euclid Avenue
Cleveland, OH 44115
216-344-8905
Elizabeth McCormick
Manager, Household Hazardous Waste
Laidlaw Environmental Services
220 Outlet Pointe Blvd.
Columbia, SC 29210
800-845-1019 P
803-750-1552 F
LeeAnn Merashoff
Field Service Manager
Laidlaw Environmental Services (NE)
221 Sutton Street
North Andover, MA 01845
508-683-1002 P
508-794-9665 F
Charlotte Mooney
Environmental Protection Specialist
Office of Solid Waste U.S. EPA
401 M Street, SW OS-332
Washington, DC 20460
202-260-6926 P
202-260-0225 F
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Ann Moser
Librarian - Seattle METRO
Hazardous Waste Management Program
130 Nickerson Street, Suite 100
Seattle, WA 98109-1658
206-689-3051 P
206-689-3070 F
A.J. Novak
Project Development Manager
Chemical Waste Management
1156 Catherine Avenue
Naperville, IL 60540
708-305-0877 P
708-513-0682 F
Judy Orttung
Supervising Environmental Health Spec,
San Bernardino Cty.Environmental Svc.
385 North Arrowhead Avenue
San Bernardino, CA 92415-0160
714-387-4629 P
714-387-4323 F
Jill Parker
Alachua County
Office of Environmental Protection
1 Southwest 2nd Place
Gainesville, FL 32601
904-336-2442
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John Patterson
Marketing & Sales Representative
INMETCO
P.O. Box 720 - 245 Portersville Rd.
Ellwood City,. PA 16117
412-758-5515 P
412-758-9311 F
Jim Pfaff
.Staff Analyst
Orange County IWMD
1200 North Main St., Suite 201
Santa Ana, CA '92701
714-568-4891 P
714-667-0275 F
618
Shirley Niemeyer
Extension Specialist, Home Environme
University of Nebraska-Lincoln •
Room 205 TCD, Home Economics Buildirf|
Lincoln, NE 68583-0804
402-472-6319
402-472-2895 F
Wanda Olson
Housing Technology Specialist
Minnesota Extension Service
360 McNeal =- 1985 Buford
St. Paul, MN 55108
612-624-3780 P
612-624-2750 F
Larry Palmer
Spvsr. for Pest. Container Disposal
Minnesota Department of Agriculture
90 Plato Blvd.
St. Paul, MN 55107
612-297-7082
Linda Pastor
Manager, Market Development
GE Lighting
Nela Park
East Cleveland, OH 44112
216-266-5903 P '
216-266-3433 F
Donna Peterson
Senior Scientist
MnTAP
1313 5th Street, SE, Suite 207
Minneapolis, MN 55414
612-627-4646 P
612-627-4769 F
Tom Poliquin
General Manager, AK Division
Northwest EnviroService, Inc.
1813 E. First Avenue
Anchorage, AK 99501
907-272-9007 P
907-272-6805 F
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Donna Portner
Pollution Control Specialist
MPCA - Hazardous Waste Division
520 North Lafayette Road
St. Paul, MN 55155-3898
612-297-8325 P
612-297-8676 F
Sharon Render - .
Environmental Engineer
NYS DEC, Hazardous Substances Reg.
50 Wolf Road
Albany, NY 12233-7253
518-485-8988 P
518-457-0629 F
[Rachel Rosenzweig • . . •
HHW Manager.
Lancaster Cty. Solid Waste Mgmt. Auth
1299 Harrisburg Pike/PO Box 4425 '
Lancaster, PA 17604
717-397-9968 P
717-397-9973 F
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Tim Scherkenbach
'MPCA
520 North Lafayette Road
St. Paul,.MN 55155-3899
Adam Portner
Information Resources
Greenbrook Corp. Ctr.
Fairfield, NJ 07004
201-808-5000 P
201-808-5001 F
100 Pasaic. Ave
Brian Rimar , . :
Environmental Protection Specialist
MSW Program, Region 8 U.S. EPA
999 18th Street, Suite 500 ("8HWM-WM)
Denver, CO 80202-2466
303-293-1673 P
303-293-1488'F
Suzanna Rumon ' _. ;. , •
Marketing Specialist
Laidlaw Environmental Serices (NE)
221 Sutton Street
North Andover, MA 01845 •
508-683-1002 P •
508-794-9665 F
Lola Schoenrich .
Community Development/Solid/Waste Sp
Minnesota Project
1885 University Ave West Suite 315
St. Paul, MN 55104
612-645-6159
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eanna Seaman
nvironmental Compliance Specialist
Norcal Waste Systems, Inc.
15 Thomas Mellon Circle # 304
San Francisco, CA 94134
415-330-1109 P
415-330-1115 F
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alter Stahel
irector
The Product Life Institute
118 Chemin Rieu'
(Geneva SWITZERLAND, CH-1208
4122346-3504 P . .
4122347-2078 F • . •
Paul Smith
Technical Writer
Sanitary Fill Company
501 Tunnel-Avenue
San Francisco, CA 94134
415-468-2422 P
415-468-3266 F
Bob Style
WRITAR
1313 5th.Street - Suite 325
Minneapolis, MN 55414-4502
612-379-5995 P
612-379-5996 F
619
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Subi Subrramanyam
Department of Entomology
University of Minnesota
228 Hodson Hall
St. Paul, MN 55108
612-624-9292 P
612-625-5299 F
,Terry Telzrow
Mgr., Standards & Product Safety
Eveready Battery Company, Inc. .
P.O. Box 45035
Westlake, OH 44145
216-835-7629 P '
216-835-7387 F
Bryan Thomlison
Director, 'Environment
Church & Dwight
469' N. Harrison Street
Princeton, NJ 08543-5297
609-497-7230 P
609-497-7208 F
Jean Wagenius
Representative
MN House - 517 State Office Building
100 Constitution Avenue
St. Paul, MN 55155
612-296-4200
Alan Wilds
Vice President of Marketing and Sales
Mercury Refining Co '.
790 Watervliet-Shaker Road
Latham, NY 12110
518-785-1703 P '.
518-785-2623 F
Catherine Wilt
Research Associate
Energy, Environment Resources Center
417 South Stadium Hall, U. of Tennesse
Knoxville, TN 37996
615-974-4251 P
615-974-1838. F
620
Christer Sundberg
Marketing Manager
MRT System AB
Silvervigen 15
S-37150 Karlskrona Sweden,
01146-45528700
01146-45528755
Herbert D. Thier
Director, CEPUP
University of California
Lawrence Hall of Science
Berkeley, CA 94720
510-642-8718 P
510-642-1055 F
Anne Thorson
Environmental Health Specialist
Washington County Dept. of Public
14'900 61st Street, North
Stillwater, MN 55082
612-430-6683 P
612-430-6730 F
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Nancy Walsh •
Product Responsibility Coordinator
3M - Do-It-Yourself Division _
3M Center - Building 251-1C-09 •
St. Paul, MN 55144-1000 •
612-733-3696 P
612-737-5544 F
Julie Wilke
Delaware Solid Waste. Authority
1128 S. Bradford Street
Dover, DE 19903
302-739-5361 P
302-739-4287 F
Mike Winka '
Executive Assistant
NJ DEP, Div. of Solid Waste Mgmt
840 Bear Tavern Road - CN414
Trenton, NJ 08625-0414
609-530-8591 P
609-530-8899 F
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Appendix III
— • Speakers' Biographical Sketches
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U.S. EPA
HOUSEHOLD HAZARDOUS WASTE MANAGEMENT CONFERENCE
December 8-12,1992 — Minneapolis, Minnesota
The Speakers: Brief Biographies
Loren Alexander, Marketing Manager Inorganics,
Chemical Waste Management, major responsibility is
to maximize CWM capability in landfill, aqueous
treatment anddeepwell technologies. He was previously
with American Cyanimid amd Phillips Petroleum; has
BS, Oklahoma City University.
Jan Ameen, Recycling Coordinator, Windham Solid
Waste Management District, Brattleboro, VT, is re-
sponsible for the district: recycling, hazardous waste
and composting programs; public education programs,
and the all related printed material. She has a BS,
Botany, University of Rhode Island; MS, Environmen-
tal Studies, Antioch New England Graduate School.
Wilson Anthony, Quadrex Environmental,
Gainesville, FL.
Angela Babin, Director, Art Hazards Information
Center, Center for Safety in the Arts, the only national
clearinghouse for information and education on hazards
and precautions in the arts. She writes, speaks, provides
technical assistance, does research on health and safety
in the visual and performing arts, manages the oc-
cupational safety and health bulletin board (OSHBBS),
and is editor of Art Hazards News. She has a BA, Psy-
chology/Biology, Barnard College; MS in En-
vironmental Health and Occupational Safety, Hunter
College.
Martha Beck, Program Specialist, Ingham (MI)
County Health Department, has worked on the County
HHW program since 1986 and is currently responsible
for program management including publicity, educa-
tion, grant compliance, collection day operations, etc.
She has a BS, Limnology, University of Wisconsin.
Michael Bender, Solid Waste Planner, Central Ver-
mont Regional Planning Commission, participated on
Vermont's Task Force on Hazardous Waste and the
Technical Advisory Committee on Solid Waste. He at-
tends the planning meeting for this conference, reports
for the HHWM News and writes a monthly column for
Waste Dynamics of New England. He has a BA in En-
vironmental Science, University of New York; an MA
in Resource Management and Administration, Antioch
New England Graduate School.
H. Fernando Berton, Senior Waste Management
Specialist, Manager HHW Management Program, Cali-
fornia Integrated Waste Management Board, administers
HHW programs. He has a BA in Microbiology and
Chemistry.
Tracy Bone, Environmental Scientist, U.S. EPA Of-
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fice of Solid Waste, responsibilities include HHW,
degradable plastics, landfill criteria and source reduction
activities. She has an MS in Environmental Mi-
crobiology from Florida State University, has pub-
lished articles dealing with groundwater microorgan-
isms, has worked in public and private sectors in aqua-
tic monitoring, sewage treatment, and potable water.
RJ. 'Rick' Bowen. President, Presume Technology
Systems, Inc., has 23 1/2 years experience with the
Home and Automotive Products businesses of First
Brands Corporation. He has BS, Business Administra-
tion, Arizona State University.
Annie Bringloe, Director, Solid Waste Division,
Kitsap County (WA) Public Works, directs solid waste,
recycling and moderate risk waste programs for a semi-
rural county (pop. 200,000), previously was a nuclear
waste lobbyist for Sierra Club. She has BS, Biology.
Ned Brooks, Hazardous Waste Specialist, Hazardous
Waste Division, MPCA, MN.
Craig Campbell, Coordinator, Used Oil Program,
American Petroleum Institute, responsible for the.
petroleum industry's nation-wide used oil collection and
recycling program, is also a senior regulatory analyst
for API in the areas of solid and hazardous waste regula-
tion and legislation. He has BS, Chemical Engineering,
and his MBA.
Grace Caner, HHW Program Coordinator, Mas-
sachusetts Office of Technical Assistance, is presently
implementing and EPA grant supporting a drop-off
program at a wastewater treatment plant She has a BA,
History, University of Wisconsin; is working towards
an MA, Environmental Policy, Tufts University.
Sam Chandler, Solid Waste Operations Manager,
Metro (Portland, OR) Service District, is responsible
for two transfer stations; one active, one closed landfill;
two HHW facilities, and numerous contracts. He previ-
ously was Director of General Services, Champaign,
IL, and has BA, Grinnell College; MA, University of
Iowa.
Robert Coffey, Manager, Consumer and Commer-
cial Marketing, Rollins Environmental Services, Inc.
(DE), is responsible for marketing direction for HHW,
CESQG and pesticide collections, plus retail steward-
ship programs. He has 20 years experience in plastics
and rubber marketing, over 11 in environmental fields
with Rollins; BS, Chemical Engineering, Texas A&M.
Gregory Crawford, Vice President, Recycling
Operations, Steel Can Recycling Institute, provides
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technical assistance, and recycling expertise on all
phases of steel can recycling for SCRI throughout the
U.S. He went to SCRI from Reynolds Aluminum
where he was regional manager for recycling
operations. He has BS, Engineering, U.S. Military
Academy; MBA, University of Utah.
Charles Cubbage, Agriculture Environmental Coor-
dinator, Michigan Department of Agriculture, works
with pesticide collection and container recycling
programs, IPM, composting, worker .protection and
groundwater cleanup projects; he is Adjunct Professor
at Eastern Michigan University and on the Michigan
and national societies for risk assessment. He has a BA
in Biology and PhD in Water Quality, both from Uni-
versity of Michigan.
Carolyn Dann, Associate, Dana Duxbury & As-
sociates, assists in planning and permitting projects for
permanent HHW facilities and provides technical assis-
tance in other areas of HHW and hazardous waste man-
agement planning. She has 10 years experience in the
environmental field, most recently six years as Recy-
cling Projects Manager with Wheelabrator Environmen-
tal Systems. She has BA , Biology and Environmental
-Studies Williams College; MBA, Tuck School at
Dartmouth College. ., .
James Darr, Section Chief, Risk' Analysis Branch,
Office of Pollution Prevention and Toxics, U.S. EPA,
manages review of chemical toxicity and exposure from
a wide variety of sources with the goal of identifying
chemicals that warrant more detailed assessment and
regulation. He has been with EPA since 1976 and has
BA, Chemistry, Western Maryland College, and has
studied at MIT and through the EPA Institute.
John Derus, Chairman, Hennepin County (MN)
Board of Commissioners.
Sarah Dewey, Program* Development Specialist,
Household Hazardous Waste Project (MO), is responsi-
ble for creation, development and presentation of HHW
education and information programs. She has BA, Bi-
ology, Grinnell College; MS, Biology, University of
Miami.
Pbilip Dickey, Director, Household Toxics Project,
Washington Toxics Coalition, directs a public educa-
tion program, produces educational materials, evaluates
alternative products, participates in joint source reduc-
tion projects. He has PhD, Physics from University of
Illinois.
Ingrid Dierlam, Program Specialist, Texas Water
Commission - Community Support Program, adminis-
ters state HHW and pesticide programs. She has BA,
Geography, University of Texas.
Jim Dougherty, Vice President and General Coun-
sel, Green Seal, directs the team that evaluates products
for compliance with Green Seal's environmental stan-
dards. He has previously held senior management posi-
tions with the Environmental Law Center, Defenders of
Wildlife, and the Superfund Enforcement Division of
EPA; he has also served on the board of S ierra Club.
Shirley Dougherty, Office of Environmental Edu-
cation, MN. - , •
Brad Drda, Waste Acceptance Control Program
Trainer, Sanitary Fill Company, designs, develops and
presents hazardous materials training to 600 San Fran-
cisco garbage company employees. He previously
taught English in Taipei; has BA Sociol-
ogy/Anthropology, Carleton College and a Certificate
of Hazardous Materials Management.
Dana Duxbury, founder of Dana Duxbury & Associ-
ates, is an environmental consultant. She specializes in
providing policy and educational services in solid and
HW management issues to government, industry, and
public interest groups. As a Senior Environmental Re-
search Analyst at the Center for Environmental Man-
agement, Tufts University, she was active in the area of
waste reduction as well as HHW. She worked for 15
years as a volunteer with the Massachusetts and U.S.
League of Women voters as a solid and HW specialist
and has a BS in Biology, Cornell.
Norm England, Executive Director, Portable Re-
chargeable Battery Association (PRBA), has extensive
experience in plastics recycling and this year joined the
new organization, PRBA, formed to work actively to
establish industry-wide programs that will promote the
recycling of rechargeable batteries. He has a BS in
'Business Administration from University of Tennessee.
Phil Farina, Director, Marketing/Sales, Environ-
mental Purification Industries, OH
Earl Finder, Sales and Marketing Manager, U.S. Fil-
ter'Recovery Services; is involved in treatment and
recovery of metals from inorganic wastes.'He has.BS,
Chemistry and Geology, University of Wisconsin.
John Fogarty, Assistant enforcement Counsel for
Superfund, Office of Enforcement, U.S. EPA, super-
vises EPA headquarters involvement in Superfund cases
of national or precedental significance in three of the
agency's ten regions; he also advises the office on mu-
nicipal liability and HHW matters. He was formerly
with the Environmental Law Institute. He earned his
BA and George Washington University and his law de-
gree at New England School of Law.
Joe Foley, Director Sales Support, Chemical Waste
Management, is responsible for marketing management
for all CWM hazardous waste services as well as the
Waste Reduction Services consulting group, which as-
sists customers in hazardous waste source reduction and
recycling activities.He has BS, University of Illinois;
MBA Northwestern University.
Judi Frantz, HHW Coordinator, California EPA,
Department of Toxic Substances Control,' is re-
sponsible for HHW programs statewide, initial devel-
opment of HHW regulations, etc. She has worked on
financial responsibility issues for the Department of
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Health Services, has a BA, Business Administration,
California State University, Sacramento.
David Galvin, Supervisor, Hazardous Waste Man-
agement, Seattle Metro, supervises Metro's hazardous
waste management program, which is part of the Seat-
tle-King County plan. He has a BA in Biology and En-
vironmental Studies from Colby College, and spent a
year working in Europe studying biological indicators
of pollution.
Leslie Goldsmith, Supervisor, Special Wastes
Unit, Hazardous Waste Division, Minnesota Pollution
Control Agency.
William Green, Moderate Risk Waste Specialist,
Washington State Dept of Ecology, coordinates state-
wide activities and is responsible for development of
moderate risk (HHW and SQG) programs, policy and
guidance issues. He worked in the private sector as a
chemist responsible for product development and regu-
latory affairs. He has MS, University of Washington,
and BS, Brigham Young University, both Chemistry.
Beverly Grimm, Manager. Market Development,
GE Lighting, is responsible for developing business
strategies and plans; current emphasis includes GE ef-
forts as an ally in EPA's "Green Lights" program and
end-of-life disposal issues for GE lighting products.
She has BA, University of West Florida and MA, Uni-
versity of Colorado, both Mathematics, and MBA,
Case Western Reserve University.
Terry Grogan, Acting Chief, Waste Reduction and
Management Branch, Office of Solid Waste, U.S. EPA,
with EPA since 1977, is responsible for the national
program to reduce volume and toxicity of MS W as well
as the regulatory program for solid waste landfills; his
assignments have included RCRA and recycling pro-
grams. He has a Masters in Public Policy from Univer-
sity of Texas LBJ School of Public Affairs.
James Gruber, Assistant Town Manager, Hartford,
VT, executive director of the regional solid waste man-
agement district and project director for the town perma-
nent HHW facility. He has a BS in Civil Engineering,
MS in Engineering, and MPA.
Walter Haas, Hazardous Waste Division, MPCA, MN
Kai Hagan, Scientific Certification Systems, Inc.
Edward Harding, Assistant Engineer, Monroe
County (NY) Division of Solid Waste, is involved in
overseeing and supervision of contracts for the county
solid waste operations including transfer stations, land-
fills, hazardous waste, HHW and recycling.He has BA,
Environmental Design and Planning, University of
Buffalo and AAS, Civil Technology in Environmental
Control and Highways & Structures.
Sonia Heaven, Lecturer Environmental Engineering,
Southampton University (Great Britain), does research
and teaches on a range of waste-related environmental
issues, was previously a civil engineer and Senior Op-
erations Officer, North West Water Authority and Re-
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search Manager SWAP Recycling. She has BA, En-
glish, Cambridge University, BS, Civil Engineering,
Leeds University..
M. Scott Herbert, President, H2O Coatings, Inc./
The Green Paint Company, founded and manages the
first paint recycling facility in the northeast, also
manufactures waterborne line-marking paints. He has
BS, Chemistry, Lowell Technological Institute, MBA,
Boston University.
Jennifer Holliday, Hazardous Waste Coordinator,
Chittenden (VT) Solid Waste District, responsible for
planning and permitting, management and operation of
the District fixed and mobile HHW facilities; also now
working on a CESQG program. She has a BS in Envi-
ronmental Science (minor Chemistry) from University
of Massachusetts.
Hubert Humphrey III, Attorney General, State of
Minnesota.
John Ikeda, Supervision, Rules and Assessment,
Groundwater & Solid Waste Division, Minnesota Pol-
lution Control Agency, manages activities related to fir
nancial and economic analysis of solid waste programs.
He has BA, Macalester College, MBA St. Thomas
University.
Jaimy Jackson, Staff Analyst, Orange County<(CA)
Integrated Waste Management Department, is public
education coordinator for recycling, source reduction,
HHW, composting, etc.; was until recently coordinator
for the HHW program, beginning with planning and
implementation. She has BA, Communications, Cali-
fornia State University Fullerton. '
Charles Jacobson, Compliance Officer, U.S. Con-
sumer Product Safety Commission, is responsible for
management of CPSC enforcement of federal hazardous
material labeling requirements, has been with CPSC
for nearly 20 years and previously was a food and drug
inspector and compliance officer. He has BS, Agricul-
ture/Chemistry, University of Wisconsin.
Brian Johnson, Environmental Programs Coordina-
tor, Santa Monica (CA). He has BA and MA, Geogra-
phy/Environmental Science, University of California
Los Angeles.
Lilias Jones, Chair, Eco Solutions, Inc., does re-
search and project development in source reduction;
previously Clerk/Treasurer, Wolverton, MN, and in-
volved at state level in solid waste, land use, energy,
environment and transportation planning. She has BA,
History, Lawrence University, MS, Public Administra-
tion, Moorhead State University, PhD candidate,
Environmental Politics/Policy, Colorado State
University.
Lois Kaufman, Vice President, Environmental Re-
source Associates, a division of American Opinion Re-
search. ERA publishes The Environmental Report, the
most widely quoted syndicated tracking study on Envi-
ronmental issues. ERA also conducts custom research
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of business and consumers. She has her PhD, New
York University, and previously was a professor at
NYU and Rutgers University.
Paula Kehoe, Environmental Program Coordinator,
Department of Public Works, City and County of San
Francisco, is responsible for public education outreach
for the Water Pollution Prevention Program. She has
worked in various other hazardous waste management
and recycling positions. Sh has BA, Geography, Uni-
versity of Colorado; MS, Environmental Management,
University of San Francisco.
Kathy Kendall, Waste Management Administrator,
Des Moines (IA) Metropolitan Area Solid Waste
Agency, plans and manages HHW programs, works on
hazardous and special waste management and reduction
programs. She has BS, Marketing and Environmental
Planning, San Diego State University.
Elaine Kerrell, Special Collections Project Man-
ager, SWAP Recycling (Leeds, Great Britain), manager
of and now preparing report on six-month pilot HHW
collection program in Leeds, also project officer for In-
stitute of Environmental and Policy Analysis, Hud-
dersfield University. She has BS, Human Ecology,
Huddersfield University.
George Kinney, Supervisor of Hazardous Waste
Management, Dakota County (MN), manages haz-
ardous waste programs including licensing ans inspec-
tion of over 1,000 hazardous waste .generators, six
hazwaste facilities and two permanent HHW sites
(average participation 500 vehicles per month).He pre-
viously worked as a chemist in industry and was a high
school science teacher. He has BS, Biology and MS,
•Environmental Chemistry, University of Wisconsin.
Terrance Kiraly, Project Manager for Facilities
Services Environmental & Operations Support, Ten-
nessee Valley Authority, has held senior engineering
positions with TV A. He has BS, Industrial Engineer-
ing and Operations Research, VPI; MS Managaement
Science, University of Tennessee.
Jan Kleman, Environmental Specialist II, Florida
Department of Environmental Regulation, is program
administrator of Florida's Hazardous Waste Collection
Center Grant Program. She also assists local govern-
ments in HHW program planning, operation, public-
ity, and development of ordinances to comply with
state legislated mandates on hazardous waste manage-
ment. She has a BS from Bowling Green University.
Isao Kobashi, Program Manager, HHW Program,
Department of Planning and Development, Santa Clara
County, is responsible for the development of county-
wide policies and programs to reduce hazardous waste
generation and develop guidelines for the siting of haz-
ardous waste management facilities. He has BA and
MA, Economics, San Jose State University.
Wilford Kryger, Manager, Engineering & Planning,
Anchorage (AK) Solid Waste Services, and was previ-
ously chief design engineer for the water and wastewater
facility. He has BS, Forestry; State University of New
York, BS, Civil Engineering, Syracuse University.
Eric Laut, Project Development Manager,'Chemical
Waste Management, Inc., Technical Services Division,
Midwest Region, with CWM for over 11 years, is re-
sponsible for region-wide HHW, pesticide, and state
contract development. He has BA, Political Science and
Business from Elmhurst College.
David Liebl, Pollution Prevention Specialist, Solid
& Hazardous Waste Education Center, University of
Wisconsin, works with industry and government to
provide educational programing, policy review and
technical assistance for pollution prevention. He con-
ducts seminars, workshops and teleconferences and does
on site evaluations. He established .the Great Lakes
Technical Resource Library.
Cheryl Lofrano-Zaske, Planner, Hennepin County
Department of Environmental. Management, is the
county planner for problem materials. She has previous
experience as a solid and hazardous waste regulator,
R&D chemist and quality assurance chemist; BS,
Chemistry and her MBA.
Carlos Lopez, Lab Operations Manager, 3M, MN..
Sylvia Lowrance, Director, Office of Solid Waste,
U.S. EPA, DC.
David Maurer, Manager, Product Planning, The
Glidden Company (ICI Paints), has been with Glidden
since 1976. He has BA, John Carroll University,
MBA, State University of New York.
Jim McCabe, The Clorox Company, CA.
Elizabeth McCormick, Manager, HHW, Laidlaw
Environmental Services, Inc., since 1988, is responsi-
ble for coordinating the company's HHW activities in
the U.S. She began work in hazardous waste manage-
ment in 1979 with predecessors to Laidlaw. She has a
BS in Distributive Science from American University,
in 1987-88 she chaired the Chemical Waste Transporta-
tion Council and was a member of the National Solid
Waste Management Association Board of Directors.
She has been a speaker at the six previous HHWM
conferences and is on the board of advisors for HHWM
News.
William Meador, President, Recovery & Reclama-
tion, Inc., a battery recycling company. He has BS de-
grees in Education, Mining and Material Processing and
Passive Solar and Synthetic Fuels; MS degrees in His-
tory and Education.
LeeAnn Merashoff, Field Service Manager, Laidlaw
Environmental Services, North East, Inc., is in charge
of the company's industrial hazardous waste site clean-
ups and HHW programs. Her group operates five per-
manent HHW facilities and has managed hundreds of
HHW collection. She has a BS in Life Sciences, and
has done graduate work in Environmental Education.
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Susan Mitchell, Pollution Control Specialist, Min-
nesota Pollution Control Agency, conducts, organizes
and analyzes waste composition studies including HHW
collections. She has BS, Biology, University of
Minnesota.
Charlotte Mooney, Environmental Protection Spe-
cialist, Office of Solid Waste Characterization and As-
sessment Division, U.S. EPA, provides staff support
for the development of regulation and policy in the ar-
eas of hazardous waste recycling, responsible for
Conditionally Exempt Small Quantity Generator Waste
regulation. She has, BA, Geology, University of Penn-
sylvania.
Anne Moser, Librarian, Seattle Metro Hazardous
Waste Management Program, has BA, Spanish/Art
History, Colby College, MA, Library and Information
Studies, University of Wisconsin.
Shirley Niemeyer, Extension Specialist, Coopera-
tive Extension, Institute of Agriculture and Natural Re-
sources, University of Nebraska, has done extensive
research and published widely on household manage-
ment and waste management subjects. She has BS,
University of Nebraska, MS, Family Environment,
Iowa State University, PhD, Community and Human
Resources.
A J. Novak, Project Development Manager, Chemi-
cal Waste Management, is responsible for sales and
marketing of HHW programs for a five-state mid-west
region. He has BS Chemistry and MBA, both Loyola
University.
Wanda Olson, Housing Technology Specialist, Min-
nesota Extension Service, is also Associate Professor,
Department of Design, Housing and Apparel. She
develops educational materials and conducts applied
research relating to the environment, ventilation, water
quality and most recently cleaning products. She has
BS, Home Economics Education, Augsburg College;
MS, Home Economics/Household Equipment,
University of Minnesota.
Judy Orttung, Supervising Environmental Health
Specialist, San Bernardino (CA) Department of Envi-
ronmental Health Services, is responsible for imple-
mentation of county hazardous waste minimization and
management programs. She has published HHWM ma-
terials, has BS, University of Michigan and MS,
Stanford University; Chemistry, MPH, Loma Linda
University.
Larry Palmer, Unit Supervisor, Minnesota Depart-
ment of Agriculture, is supervisor for waste pesticide
collection and pesticide container disposal programs. He
has BA, Organizational Management.
Jill Parker, Senior Environmental Specialist, Ala-
chua County (FL) Office of Environmental Protection,
is responsible for small quantity generator, HHW and
hazardous waste awareness programs. She was pre-
viously a Senior Environmental Engineer with General
626
Dynamics and has a BS, Chemistry, Texas Christian
University, has done work towards a MS, Environmen-
tal Science.
John Patterson, Marketing and Sales Representa-
tive, INMETCO, works with manufacturing wastes,
shipping and environmental audits, he has BS, Chem-
istry/Physics, University of Pittsburgh.
Donna Peterson, Senior Scientist, Minnesota Tech-
nical Assistance Program (MnTAP), provides technical
assistance for CESQGs, printers and educational insti-
tutions. She has BS, Chemistry, Wheaton College
(IL); MS Biochemistry, Minnesota State University.
Jim Pfaff, Staff Analyst, Orange County (CA) Inte-
grated Waste Management Department, recently ap-
pointed coordinator of the HHW program, wrote the re-
cycling plan for the unincorporated areas of the county.
He has BA, Political Science/Public Administration,
California State University at Fullerton.
Thomas Poliquin, General Manager, Alaska Divi-
sion, Northwest Enviroservice, Inc., responsible for all
the company operations in Alaska, was previously
manager of the permanent HHW facility in Anchorage.
He has also been a railroad inspector and Manager of
Environmental and Safety Engineering in industry.
Donna Portner, Senior Pollution Control Specialist,
Minnesota Pollution Control Agency, works with the
HHW program. She has BS degrees in Biology and En-
vironmental Studies, Mankota State University.
Sharon Rehder, Environmental Engineer, New York
State Department of Environmental Conservation, is
responsible for the state-wide HHW program; worked
on the battery task force. She has BS, Chemical Engi-
neering, Rensselaer Polytechnic Institute; licensed Pro-
fessional Engineer, Chemical Engineering.
Brian Rimar, Environmental Protection Specialist &
HHW Contact, MSW Program, Region 8, U.S. EPA,
previously worked with the International City Manage-
ment Association, was a Peace Corps Volunteer
(wildlife management) in Guatemala, and a.Spanish
teacher. He has a BS in Urban and Regional Planning
and Geology, SUNY College at Buffalo; an MA in
Physical Geography, University of Maryland.
Rachel Rosenzweig, HHW Manager, Lancaster
County Solid Waste Management Authority, was re-
sponsible for development and implementation of
Pennsylvania's first permanent HHW facility which she
now manages; she is also infectious waste program
manager. She has previously worked as a planner for
solid and hazardous waste and recycling programs. She
has a BS in International Environmental Studies from
Cook College, Rutgers University.
Suzanna Rumon, Center Coordinator, HazWaste
Central (CT), has been project coordinator for"
Connecticut's only permanent HHW collection facility
since its inception and has previous experience in sev-
eral recycling programs. She has a BS in Political Sci-
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ence from Skidmore College.
Lola Schocnrich, Community Development/Solid
Waste Specialist, The Minnesota Project, provides
technical assistance and training to rural Minnesota ar-
eas in planning and implementing "alternative" solid
waste management systems. She has BA, Hampshire
College.
Deanna Seaman, Environmental Compliance Spe-
cialist, Norcal Waste Systems, Inc., is responsible for
development and implementation of load-checking pro-
grams; has also designed and implemented other waste
analysis and assessment programs. She has BS, Chem-
istry, San Francisco State University.
Paul Smith, Technical Writer, Sanitary Fill Com-
pany (San Francisco, CA), produces the written materi-
als on company hazardous waste programs; previously
prepared environmental compliance documents for
Pacific Gas & Electric. He has BA, Communications,
California State University at Fullerton.
Walter Stahel, Consultant, mainly in the fields of:
re-use, repair, reconditioning and technological upgrad-
ing of components, goods and systems; risk manage-
ment and insurance, and regional economic develop-
ment. He is one of the directors of the Product Life In-
stitute in Geneva, holds a degree from the Swiss Fed-
eral Institute of Technology (Architecture and Town
Planning) and has published widely on the economics
of durability, the environment and human and material
resources.
Bob Style, WRITAR, MN,
Subi Subrramanyam, Assistant Extension Ento-
mologist, University of Minnesota, is involved with
stored-product pest management, pesticide impact as-
sessment programs, pesticide use surveys, pesticide
benefits and safety, toxicology of pesticides, IPM. He
has MS and PhD, Entomology, University of Min-
nesota.
Christer Sundberg, Marketing Manager, MRT Sys-
tem AB, Karlskrona, Sweden, is in charge of world-
wide marketing and sales of MRTs equipment — for
mercury recovery.
Larry Sweetser, Norcal Solid Waste Systems
Environmental Compliance Program Manager, de-
velops programs to divert hazardous waste from land-
fills, including the dedicated, full time staffed HHW
collection facility for the City and County of San Fran-
cisco. He has an MA in Environmental Management
' from University of San Francisco.
Terry Telzrow, Manager, Standards, Product Safety
(and Government Affairs), Eveready Battery Company,
has worked for Eveready since 1962 in various areas of
quality control, production, and engineering. He has a
BS in Chemical Engineering from Cleveland State
(Fenn College) University; NT, Clogging, Mountain
State Hall.
Herbert Thier, Associate Director, CEPUP
(Chemical Education Program for Public Understand-
ing), University of California, Berkeley. He directed the
Science Curriculum Improvement Study (SCIS) and
several similar projects. He has BA, Science and Math-
ematics, MS and EdD, New York University.
Anne Thorson, Environmental Health Specialist,
Washington County (MN) Health Department, man-
ages and directs the operation of the county HHW and
problem material program and was also involved in de-
velopment of the program including a mobile HHW
collection facility. She has a BS, Community Health.
Education.
Jean Wagenius, State Representative, Minnesota
House of Representatives, is co-chair of the Legislative
Commission on Waste Management, she has BA,
George Washington University; graduate studies, Eco-
nomics and social work; JD, William Mitchell College
of Law.
Nancy Walsh, Senior Product Responsibility
Chemist, 3M - Do-It-Yourself Division, is responsible
for ensuring compliance of products with governmental
regulations, especially regarding health, safety and the
environment She has BA, Chemistry; graduate work in
Philosophy with emphasis in ethics.
Alan Wildes, Vice President, Marketing and Sales,
MERECO, NY.
Julie Wilke, Delaware Solid Waste Authority, DE.
Catherine Wilt, Research Associate, Energy, Envi-
ronment and Resources Center, University of Ten-
nessee, is active in the state's solid waste planning ac-
tivities. She has MS, Environmental Planning ans
Solid Waste Management Planning.
Mike Winka, Executive Assistant, Division of Solid
Waste Management, Department of Environmental Pro-
tection, NJ.
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Speakers and Workshops
NAME
Lqren Alexander
Jan Ameen
Wilson Anthony
Angela Babin
Martha Beck
Michael Bender
Fernando Berton
Tracy Bone
Rick Bowen
Annie Bringloe
Dairyl Brock
Ned Brooks
Craig Campbell
Grace Caner
Sam Chandler
Robert Coffey
Gregory Crawford
Charles Cubbage
Carolyn Dann
Jim Darr
John Derus
Sarah Dewey
Philip Dickey
Ingrid Dierlam
Jim Dougherty
Shirley Dougherty.-
Brad Drda''
Dana Duxbury
Norm England
Phil Farina
Earl Finder '
John Fogarty
Joe Foley
Judi Frantz
David Galvin
Leslie Goldsmith
William Green -.
Beverly Grimm
Terry Grogan
Jim Gmber
Walter Haas
Kai Hagen
Ed Harding
Sonia Heaven
Scott Herbert
Jennifer Holliday
Hubert Humphrey in
John Dceda
Jaimy Jackson
Chuck Jacobson
Brian Johnson
Lilias Jones
Lois Kaufman
628
SECTION
4-E ' •
5-B
5-C
6-D
5-A
1-A
l-C
1-B, 3-B .
3-E
5-B
PLEN-FRI
4-B, 5-B
3-D
7-B
7-C
4-E
l-D .
3-B
1-B, 2-B, 6-C
1-A
PLEN-WED
3-C
PLEN-WED, 4-D
2-E
4-D
3-C
l-D
2-D, 4-B
l-C
2-B
4-E
2-A
4-E
4-A, 6-C
PLEN-WED, 1A, 6-B
5-A, 6-C
3-D, 6-A
2-D
PLEN-WED
7-A
1-A
4-D
7-C
5-C
1-B
6-C
LUNCH-THUR
5-D •
7-C
4-D
3-E
4-C
5-D
NAME .' SECTION
Paula Kehoe 4-C
Kathy Kendall 4-A
Elaine Kerrell 5-C
George Kinney "1-B, 3-E, 7-A
Terrance Kiraly 5-C
Jan Kleman 2-E
Isao Kobashi 5-D
BillKryger 5-B
Eric Laut 7-A
David Liebl 6-B
Cheryl Lofrano-Zaske l-C
David Maurer 7-D
Jim McCabe PLEN-FRI
Elizabeth McCormick 3-A
Bill Meador 2-C
LeeAnn Merashoff 3-A
Susan Mitchell 5-D
Charlotte Mooney 2-A. 3-D, 4-B
Ann Moser •••' 6-B
Shirley Niemeyer ' 3-C, 4-C
A.J. Novak 3-A
Wanda Olson 6-D
Judy Orttung - 5-A
Larry Palmer 3-B
Jill Parker 5-C
John Patterson 2-C
Donna Peterson • 7-B
Jim Pfaff ' . 7-C
Tom Poliquin . 5-B .
Adam Portner .5-D
Donna Portner 5-A
Sharon Render 3-A
Brian Rimar 2-E, 4-A
Rachel Rosenzweig 4-A
SuzannaRumon 1-A
Tim Scherkenbach PLEN-WED
Lola Schoenrich 6-A
Deanna Seaman 3-E
Paul Smith l-D
Walter Stahel . PLEN-WED
Bob Style 7-B
Subi Subrramanyam 6-D
Christer Sundberg 2-D
Terry Telzrow l-C, 7-D
Herbert Thier PLEN-WED •
Bryan Thomlison - PLEN-FRI
AnneThorson 2-B
Jean Wagenius LUNCH-WED
Nancy Walsh , 7-D
Alan Wilds 2-C
Julie Wilke 2-E
Catherine Wilt - l-D
Michael Winka PLEN-WED
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Appendix IV
List of Attendees
629
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ALLEN CO ENV SVCS
ONE EAST MAIN STREET
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FT WAYNE, IN 46802
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MS. ROSEMARY BYRHE
SEATTLE-KING CO DE
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SMITH TOWER
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KLICKITAT COUNTY
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KENNETH BORWN & ASSOC
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MR. RICHARD BROWN
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5301 REB MOUNTAIN t
WAUSAU, WI 54401
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MR. JIM BOSCH
TARGET STORE
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PORTLAND METRO SVC
2000 SE 1ST AVENUE
PORTLAND, OR 9720
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EDMONTON
ALBERTA
CANADA TSJ 3L9
PHONE: 403-422-5029
FAX: 403-428-9627
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'PHONE: 507-635-6232
t
JOLIE WHETZEL
ALBERTA SPECIAL WASTE
MGMT
610 10909 JASPER
AVENUE
MR. CHARLES WHITTENTO
CUMBERLAND CO SOLID
WASTE
698 ANN ST
FAYETTEVEILLE, NC 28
uJ Z
O
MS. MADGE WiEGREFE
DODGE CO ENV QUALITY
' P O BOX 337
COURTHOUSE
MANTOHV1LLE, MN 559:
Ul
Ul
PHONE: 608-251-2804
4751 MUSTANG CIRCLE
ST PAUL, MN 55112
PHONE: 612-784-4040
FAX: 612-784-5397
ENV
222 SOUTH HAMILTON
SUITE 4
MAUISON, WI 53703
MR. riON WEI>EK
OYNEX .ENVIRONMENTAL
MS. LIZ WESSEL.
CITIZENS FOR A DETTE
MS. MARILYN WEYER
LINCOLN- 1 ANCASTER CO
22OO'ST MARYS AVENUE
LINCOLN, NE 68502
PHONE: 402-471-8634
FAX: 402-471-8323
SPRINGFIELD, IL 62794
PHONE: 217-785-8604
l
P O BOX 4425
LANCASTER, PA 17604
PHONE: 717-397-9968
FAX: 717-397-9973
MADISON, WI 53703
PHONE: 608-257-3541
FAX: 608-257-8755
2200 CHURCHILL RD
1299 HARRISBURG PIKE.
SUITE 310
Mr. DAVID WALTERS
I EPA SOLID WASTK MGT
SECTION
MR. DWAYNE WARFEL
LANCASTER CO SW MGMT
AUTII
MS. TAISHA WEBER
WISCONSIN MERCHANTS 1
30 WEST MIFFLIN STREI
»j pj
" O
MR. RICHARD VOPEL
OREGON DEPT ENV QUALTT
flll SW 6TH AVENUE
PORTLAND, OR 97204
PHONE: 503-229-6590
FAX: 503-229-6977
x
MR. ANDREW WADE
WADE. SALVAGE INC
293 JACKSON ROAD
ATC, NJ 08004
PHONE: 609-767-2760
FAX: 609-767-0698
MS. RITA WALKER
WINONA CO ENV SERVICE
171 W THIRD STREET
WINONA, MN 66987
PHONE: 507-457-6460
FAX: 507-457-6469
en
BLAIR, NE 68008
PHONE: 402^426-9455 -
PORTLAND, OR 97204
PHONE: 503-229-6602
11 "V
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MS. REBECCA VERSCH
UNIV NEBRASKA
P 0 BOX 325
COOPERATIVE EXTENSION
MS. SUSAN VIOLETTE
OR DEQ
811 6TH AVENUE
7TH FLOOR
MR, FRANK VIRGINIA
ENSCO
333 EXECUTVIE COURT
LITTLE ROCK, A2 7220
Ul
MR.. .PAUL VALENTINO
HOUSEHOLD HAZWASTE INC
1609 A REGATTA LANE
SAN JOSE, CA 95112
PHONE: 408-441-0241
FAX: 408-441-0245
MS. PAULA VANBCEK
EAST CENTRAL SW
COMMISSION •
EAST CENTRAL SOLID
HASTE COMM
ROUTE 2, BOX 103E
MORA, MN 55051
PHONE: 612-444-6818
FAX: 612-444-5519
MR. BOBERT VASHON
PROCTER & GAMBLE
COMPANY
5299 SPRING GROVE AVE
CINCINNATI, OH 45217
PHONE: , 513-627-5436
639
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640
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Appendix V
^ Poster Session Participants
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641
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National HHW Management Conference
Poster Session Participants
Tom Benson
S.C. Johnson & Son,
1525 Howe Street
Racine, WI 53403
414-631-2960 P
Inc.
Dan Burke
Lake Michigan Federation
647 West Virginia Street 1307
Milwaukee, WI 53204
414-271-5059 P
Madeiline Green
Univ. of Maryland Extension Service
3525 L Ellicott Mills Drive
Ellicott City, MD 21043
410-313-2707 P
Michele Herrity
Manager, Technical.Affairs
CSMA
1913 Eye Street, NW
Washington, DC 20006
202-872-8110 P
202-872-8114 F
Shirley Niemeyer
Extension Specialist, Home Environment
University of Nebraska-Lincoln
Room 205 TCD, Home Economics Building
Lincoln, NE 68583-0804
402-472-6319
402-472-2895 F
Source: The Waste Watch Center
(MAC\WWC\ADMIN\HHW PUB)
642
Tim Boettcher
Western Lake Superior Sanitary Dist.
2626 Courtland Street
Duluth, MN 55806
218-722-3336 P
Liz Gelbmann
Pollution Control Specialist
MPCA
520 North Lafayette Road
St. Paul, MN 55155-3898
612-297-8324 P
612-297-8676 F
Cass Harris
600 Jefferson County Courthouse
527 West Jefferson Street
Louisville, KY .40202
502-625-8115 P
Cora Liikala
Lake County Coop. Extnsion Sevice
99 Erie Street
Painsville, OH 44077
216-357-2582
Julie O'Leary
S.olid Waste Prgrm Supervisor
Western Lake Superior 'Sanitary Dist
27th Ave, W. & the Waterfront
Duluth, MN 55806-1894
218-722-3336
1/21/93
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Appendix VI
National Listing of Household Hazardous Waste Collection Programs: 1992
•643
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Specialty Program Kev
= paint only AD = paint drop & swap ~ = latex only
@C- curbside used oil @ = used oil collection only + = antifreeze only
E = Education only B = urse car batteres $/ = CESQGonly
"> = permanent mobile programs (dedicated facility with collections at least once per month)
$ = also accepts Conditionally Exempt Small Quantity Commercial Generator waste
O = a number after the location, indicates number of sites participating in one collection
(Xdy)/(dys) = X number of days in given time period for multi-day collection
644
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THE NATIONAL LISTING OF HOUSEHOLD HAZARDOUS I
WASTE COLLECTION PROGRAMS*
1992 I
The data in this listing of household hazardous waste (HHW) collection programs has been
collected and assembled by The Waste Watch Center (WWC) to provide basic information •
on HHW collection programs nationwide (including farm and conditionally exempt |
generator waste), and to serve as a resource for identifying program contacts. This listing
includes all 1992 programs identified by WWC. Collection program data from 1980-1987, m
1988-1990 and 1991 can be ordered from WWC. •
Programs are listed by state in chronological order. Specialty programs are identified with a
particular symbol (see key below). They include "paint only," "farm pesticides only," "dry •
cell batteries only," or used oil collected at the curbside. We also specified whether a pro- I
gram was a permanent program. A permanent program is defined by WWC as a program
with at least monthly collections held at a fixed site or at a dedicated mobile facility. Per-
manent programs appear in the data base only once in each year of operation. Programs I
with a common sponsor and in the same community or local area are listed as a single • "
event, even if held at multiple sites or on two or more consecutive days.
Information on costs, amount of waste collected, and number of participants is presented in •
the units provided by our sources. Although a single program sponsor is listed for each ™
program, some programs have multiple sponsors. WWC recommends contacting the
sponsor for more comprehensive information about individual programs. •
As no central directory or national reporting requirement exists, WWC used various pro- *
ject sponsor materials, state and municipal information, personal contacts, reporting forms,
and other information sources to obtain as complete and accurate data as possible. We •
would appreciate your assistance in keeping the listings current as well as in correcting any I
inaccuracies. Please supply us with any additions or corrections by filling out the
accompanying survey on the following page. Send it to The Waste Watch Center, 16 •
Haverhill Street, Andover, MA 01810. (508) 470-3044. Please use this form to send us all |
future program information as well.
I
< = oil-based only AC = paint curfaside > = tailgate mobile
- = Institutionalized # = farm pesticide only S = school lab clean up •
BR = retail drop-off household battery only BC = Household battery curbside collection I »
RS = HHW recyclables only
= permanent programs (fixed site with collections at least once per month) I
* The data includes collection programs for HHW; farm and conditionally exempt small ' |
quantity generator waste, and specialized programs such as: paint only, farm pesticide
only, dry cell battery only, curbside or special used oil collection programs, etc. M
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NATIONAL HOUSEHOLD HAZARDOUS WASTE (EHW) COLLECTION PROGRAM SURVEY
Please.complete yearly either one survey for each single/multiple day
HHW or Specialty Collection Program, or give us a 12 month summary of
your Permanent Program, ongoing Specialized Program (i.e. Curbside
Collection) or multiple one-day events data. For planned programs
please fill in questions 1-4 and 8,9. Please provide separate data on
household hazardous waste and conditionally exempt small quantity
generator of {CESQG - i.e.; very small businesses (0-100 Kil/month) }
hazardous waste, if possible.
1. Sponsor
Address
City _
State
." -Zip
Contact Person
Title
Phone
Affiliation
2. Type of program: (please check all that apply)
ALL HHW:*
One/ Multiple DavQ
Number of Days
Number of Sites
Institutionalized (in Budget)
Tailgate Mobile
Including CESQG
Permanent Program^
Permanent fixed facility
Permanent mobile facility
Toxic Taxi (door to door)
with CESQG at permanent facility
© No dedicated facility
ft A permanent program is defined as
a fixed/mobile dedicated facility
with frequent/ regular collection
times (at least I/month).
Other (please specify),
SPECIALTY COLLECTIONS:
Only CESQG
Curbside Used Oil
Farm Pesticides
Curbside Car Batteries
Household batteries
curbside
retail drop off
Other
All Paint ONLY
• latex ONLY
oil based ONLY
Drop & Swap
Curbside
_ HHW Recyclables ONLY
latex paint
car battery
antifreeze
used oil
oil filters
other
Education ONLY
Antifreeze ONLY
School Lab ONLY
* Does your'program collect
Lights, Medical Waste,
Oil Filters,
Fluorescent
Freon from old Refrigerators,
645
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Latex Paint, or Gas Cylinders?
3. General information- concerning the collection program and where
it will be/ or was held:
Date(s) Hours
Type of site(s) (i.e. landfill, etc.)
Location (s) (community)
A. Size of Area Served
B. Population of Program's Community
C. Number of Households
D. Number of Participants Served
E. Households or Participants /
= The % of Households (Participants)
Serves (ed)
F. % of first time participants % of
- % of HHW participants % of
When first opened? (for permanent program)
4 . Hazardous Waste Contractor
Address
Citv State
Contact Person
Population
that the program
repeat participants
CESQG participants
Zip
Phone
FOR PERMANENT PROGRAMS PLEASE USE YEAR TOTALS OR SPECIFY TIME FRAME
5, Capital & Operating Costs: Please indicate all funding
information; briefly describe items in spaces below.
ITEM DESCRIPTION COST
Fixed/Capital Costs;
Site
Ecruipment '
Trainina
Other
Operational Costs:
Waste Management
Disposal Cost
Recyclina Cost
Reuse Cost
Testina
646
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
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Transportation
Labor
Administrative
Technical
Volunteers
Contractor
Insurance
Publicity
Education
Other
Supplies
Maintenance
Utilities
Permits & Fees
Miscellaneous .
6. Waste Management Methods and Quantities- Indicate waste
management method(s)and quantities under the appropriate heading
(Either reuse, recycled, and treated or landfilled. Wastes reused or
recycled are listed by product type, those that are treated or
landfill can be entered either by hazard class or by product type).
Different types of wastes managed in different ways can be entered
under each appropriate category.
Not Accepted-MA, Other (specify)-O:
• ' .AMOUNT * RAW/
COLLECTED PACKAGED
REUSED WASTE TABLE - (note if they are consolidated before reuse-C/R)
Automotive Products
Antifreeze
Brake Fluids _;
Car Batteries
Oil •
Oil Filters \ ;
Transmission fluids
Other
Paints and Home Repair Products
Home Repair
Acids _;
Adhesives ;
Sealers '
Solvents
Other '
Paints and Coatings
Latex Paint .
Oil Based Paint
Other •
Pesticides and Fertilizers
Pesticides
Fertilizers
Other _
Household Cleaners
Miscellaneous
647
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Aerosols
Fluorescent Lights
Fuels
Household Batteries
Other
RECYCLED WASTE TABLE - (Note if they are consolidated for fuel-C/F) _
Automotive Products ' •
Antifreeze . ™
Car Batteries
Oil Filters .
Used Motor Oil
Other .
Paints and Related Materials
Latex Paint
Oil Based Paint
Other .
Household Batteries
Solvents
Other
INDICATE WHETHER THE WASTES ARE TREATED OR LANDFILLED AND THE TREATMENT
METHOD: Treatment (Incineration-I.Neutralize-N,Waste Water Treatment-Mf) ,
Hazardous Waste Landfill-HL,
I
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Miscellaneous « I
I
TREATED AND LANDFILLED HAZARDOUS WASTE - (BY HAZARD CLASS) I
I
Flammables
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Chemical
Neutralization
Thermal
Incineration
Biological
Waste Water
Miscellaneous
Fluorescent Lights
Household Batteries
Medical Waste -
Other
TREATED AND LANDFILLED HAZARDOUS WASTE TABLE -„(BY PRODUCT CATEGORY)
Treatment (Incineration-I,Neutralize-N,Waste Water Treatment-W)
Hazardous Waste Landfill-HL,
Automotive Products
Antifreeze •
Brake Fluids :
Car Batteries
Oil
Oil Filters '.
Transmission fluids .
Other
Paints and Home Repair Products
Home Repair
Acids
Adhesives
Sealers
Solvents
Other
Paints and Coatings
Latex Paint
Oil Based Paint
Other . ;
Pesticides and Fertilizers
Pesticides
Fertilizers
Other
Household Cleaners
Miscellaneous
Aerosols
Fluorescent Lights
Fuels
Household Batteries
Other
Were previous programs held? ' if yes/when?
8. Please include an ANNUAL REPORT {based on the Program's Fiscal Year)
and any other published information.
9. Please attach or write in any known program information other than your
own.
F:\WP51\DOCS\WWC\ADMIN\SUR92
649
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F
HOUSEHOLD HAZARDOUS WASTE COLLECTION PROGRAMS TOTALED BY YEAR
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wlsconson
Wyoming
Total/Year
Total States
1980
1
1
1
2
2
1981
i
2
f
2
4
2
1982
1
1
1
1
1
3
8
6
1983
2
5
1
14
4
1
4
31
7
1984
3
12
4
1
21
2
30
2
1
1
2
1
2
1
5
1
3
2
94
18
1985
1
4
37
1
9
22
2
1
1
33
8
7
3
4
8
1
8
2
1
4
2
1
8
1
6
175
25
1986
7
28
25
16
1
1
2
3
1
1
78
14
10
1 1
7
21
1
2
1
4
1
1
6
2
5
. 3
12
9
273
28
1987
2
1
1
81
24
1
13
1
1
2
1
2
51
11
9
1
22
3
28
2
2
7
2
3
7
12
1
9
300
28
1988
6
1
99
38
18
2
6
5
3
2
1
3
101
23
33
2
3
19
13
44
1
1
3
5
5
1
5
2
15
17
7
484
31
1989
1
10
2
113
3
37
72
9
2
1
„ 4
12
2
3
5
102
30
56
1
3
27
33
3
62
5
1
2
1
3
6
5
3
1
6
10
37
18
1
692
38
1990
2
9
2
181
3
49
1
85
3
10
10
6
16
4
2
6
10
78
51
31
5
6
23
39
2
73
6
1
4
1
6
3
5
3
1
12
2
14
13
63
1
16
1
859
43
1991
2
15
4
1
149
3
42
2
95
2
9
2
19
3
9
12
4
2
2
5
63
60
41
2
1
2
19
47
3
57
6
7
7
16
4
2
1
2
5
6
7
11
55
1
16
2
827
46
1990
2
16
3
231
5
28
1
61
2
8
4
15
9
18
11
6
1
2
• 6
62
35
49
3
1
35
54
2
55
5
3
6
15
5
1
2
7
2
14
9
42
1
27
3
857
43
Total
8
74
13
2
937
19
253
5
403
4
30
11
52
36
50
42
17
12
18
32
613
234
236
2
1 1
1
18
2
161
204
11
355
24
8
23
9
50
27
38
5
3
4
40
13
54
69
259
5
110
7
4606
50
The Waste Watch Center - January. 1993
I
654
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669
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Appendix VII
HHW Management State Agency Contacts
670
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I
I HHW Management State Agency Contacts
• -1992-
ALASKA
toff Kany
zardous Waste Program Manager
Alaska DEC
•LO Willoughby Ave
Pjr.eau, AK 99801-1795
907-465-5150
•37-465-5164
ALABAMA
Dixie Beatty
Land Division
AL Dept. of Environmental Management
1751 Congressman Dickinson Drive
Montgomery, AL 36130
205-271-7797
ARKANSAS
Knna Etchieson
lid Waste Management Division
AR Dept of Pollution Control/Ecolocy
10. Box 9583
ttie Rock, AR' 72219
501-562-6533
I
CALIFORNIA
»di Frantz
soc.Hazardous Materials Specialist
California Dept. of Health Services
K151 Croydon Way, Suite 3
cramento, CA 95817
916-255-3604 P
".6-255-3595 F
I
COLORADO
inelle Henderson
fezardous Waste Manager
Larimer Cty Dept of Natural
§0. Box 1190
rt Collins, CO 80522-1190
303-498-5771 P
F •
Resources"
DELAWARE
tc. Vasuki
ief Executive Officer
Delaware Solid Waste Authority
fcO. Box 455
ftver, DE 19903-0455
™2-739-5361 P
12-739-4287 F
I
I
Source: The Waste Watch Center
(MAC\WWC\ADMIN\HHW PUB)
ARIZONA
Betsey Westell
AZ Dept. of Environmental Quality
3033 N. Central Ave.
Phoenix, AZ 85012-2809
800-234-5677
Fernando Berton
Senior Waste Management Specialist
California Integrated Waste Mgrnt. Bd
88.00 Cal Center Drive
Sacramento, CA 95826
916-255-2348 P
916-255-2222 F
CONNECTICUT
Paul Franson
CT DEP Waste Bureau
165 Capitaol Avenue
Hartford, CT 06424
203-566-5277 P
203-566-5255 F
Julie Wilke
Delaware Solid Waste Authority
1128 S. Bradford Street
Dover, DE 19903
302-739-5361 P
302-739-4287 F
2/5/93
671
-------
FLORIDA
Jan Kleman . .
Environmental Specialist II
FL .DER, Bureau of Waste Planning & Reg
2600 Blair Stone Roaci
Tallahassee, FL 32399-2400 -
904-488-0300 P
904-922-4939 F
Bob Donahue
GA Hazardous Waste Mgmt Authority
254 Washington Street, Suite 416
Atlanta, GA 30334
404-651-5128
IOWA
Marilyn Krogulski
Program Planner
Iowa Dept Natural Resources
900 E. Grand Ave. Wallace State Office
Des Moines,- IA 50319
515-281-8308
GEORGIA
Pam Thomas
Hazardous Waste Management Program
GA Dept. of Natural Resources
205 Butler St., Floyd Tower East #12
Atlanta, GA 30334
404-362-2692
HAWAII
Jane Dewell
Solid & Hazardous Waste Branch
Hawaii Dept. of Health 5 Waterfront
500 Ala Moana Blvd. Suite 250
Honolulu, HI 96813
808-486-4226
IDAHO
Jaime Fuhrman
Public Information Officer/ID Dept H
Hazardous Materials Bureau
1410 North Hilton
Boise, ID 83706
208-334-5879
I
I
I
I
I
I
I
ILLINOIS
David Walters
Manager, Solid Waste Reduction Unit
IEPA
2200 Churchill Road
Springfield, IL 62794-9276
217-785-8604 P
217-524-4193 F'
INDIANA
Bruce Palin
Asst. Comm. Office of Solid Waste
IN Department of Environmental Mgmt.
105 South Meridien St., P.O. Box 601
Indianapolis,
317-232-3210
IN 46206-6015
KANSAS
Kathleen Warren
Program Director, HHW Program
KS Dept. of Health and Environment
Forbes Field - Building 740
Topeka, KS 66620-0001
913-296-1611
913-296-1592
KENTUCKY
Annette Hayden
Program Coordinator
KY Division of Waste
18 Reilly Road
Frankfort,"KY 40601
502-564-6716
Management
LOUISIANA
vince Sagnibe
Manager, Tech Services/Haz Waste
LA DEQ Office.Solid'& Haz Waste
P.O. Box 82178, 79290 Blue Bonnet
Baton Rouge, 'LA 70884
504-765-0355 P
504-765-0617 F
672
MASSACHUSETTS
Barbara Kelley
Director
Office of Technical Assistance,MA EO
100 Cambridge St, Room 1904
Boston, MA 02202
617-727-3260 P
617-727-2754 F
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I
Iancy Wrenn
egional Planner, Haz Waste Prevention
MA Dept.of Environmental Protection
§ne Winter Street
oston, MA 02108
ol7-292-5587 P
17-556-1049 F .
i
ff AIN E
Iohn James
aine Waste Management Agency
Station 154
Augusta, ME 04333
•07-289-5300
MARYLAND
Jim Francis
Program Administrator
MD Dept.of the Environment
2500 Broening Highway
Baltimore, MD 21224
410-631-3343
MICHIGAN
Julian Brisbois
MI Dept- of Natural Resources
P.O. Box 30241
Lansing, MI 48909
517-373-2730
MINNESOTA
§slie Goldsmith
pervisor, Special Wastes Unit
CA - Hazardous Waste Division
(0 North Lafayette Road
. Paul, MN 55155-3898
2-297-8368 P
612-297-8676 F
MISSOURI
June Sullens
'HHW Program
MO Dept.of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
314-751-3176 '
ffESSISSIPPI
§m Whitten
ste Minimization Director
Dept.of Environmental Quality
P.O. Box 10385 -
tckson, MS 39289-0385
1-961-5241
MONTANA
Lara Dando
Environmental Specialist
Solid & Hazardous Waste Bureau
Cogswell Bldg.
Helena, MT 59620
406-444-1430
406-444-1499 F
RTH CAROLINA
Cayton
lid Waste Section
TOrth Carolina DEHNR
P.O. Box 27687
tleigh, NC 27611-7687
9-733-0692
NORTH DAKOTA
Christine Roob
Environmental Scientist
Division of Waste Mngmt
P.O. Box 5520
Bismark, ND 58502-5520
701-224-2366
•EBRASKA
§~ ri Swarts
mpliance Specialist
_braska Dept. of Environmental Qlty,
•1200 N Street, Suite 400
Incoln, NE 68508
2-471-4217 P
402-471-3185 F
I
NEW HAMPSHIRE
Ken Stuart
Environmentalist
NH DES, Waste Management Division
6 Hazen Drive
Concord, NH 03301-6509
603-271-2901 P
603-271-2456 F
673
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NEW JERSEY
Ralph G. Davis
NJ DEP, Bureau of Hazardous Waste
Regulation & Classification
401 E. State Street, CN 028
Trenton, NJ 08625
609-292-8341
NEW MEXICO
Gary Brannon
Household Hazardous Waste Coordinator
Solid Waste Bureau/Environment Dept.
1190 St. Francis Drive
Santa Fe, NM 87503
505-827-2902
Mike Winka
Executive Assistant
NJ DEP, Div.' of Solid Waste Mgmt.
840 Bear Tavern Road - CN414
Trenton, NJ 08625-0414
609-530-8591 P
609-530-8899 F
Stephen Gerardo
KHW Coordinator
NM Environmental Department
1190 St. Francis Drive, P.O. Box 261
Santa Fe, NM 87503
505-827-2909 P
505-827-2836 F
I
I
I
I
NEVADA
Bob Stulac
Environmental Management Specialist-
Dept. of Conservation & Natural Res.
123 W. Nye Lane
Carson City, NV 89710
702-687-5872
NEW YORK
Sharon Rehder
Environmental Engineer
NYS DEC, Hazardous Substances Reg,
50 Wolf Road
Albany, NY 12233-7253
518-485-8988 P
518-457-0629 F'
OHIO
Mike McCullough
Div. of Solid and Haz Waste Mgmnt
Ohio SPA
1800 Water Mark Drive, P.O., Box 1049
Columbus, OH 43266-1049
514-644-2917
OKLAHOMA
Theresa Coffman
Oklahoma Dept. of Health/Solid Waste
1000 NE 10th Street
Oklahoma City, OK 73117-1299
405-271-7114
OREGON
Maggie Conley
HHW Coordinator
Oregon DEQ
811 SW 6th Avenue
Portland, OR 97204
503-229-5696 P
503-229-6124 F
PENNSYLVANIA
William Apgar
Waste Management Division
PA Dept of Environmental Resources
P.O. Box 2063
Harrisburg, PA 17120
717-787-6239
RHODE ISLAND
Richard Enander
Pollution Prevention Program Manager
RI Dept. of Environmental Management
83 Park Street
Providence, RI 02903-1037
401-277-3434 P
401-277-2591 F
674
SOUTH CAROLINA
Pam Bergstrand
SC Dept. of HEC, Div. of Hydrogeolog
Bureau of Solid and Hazardous Waste
2600 Bull Street
Columbia, SC 29201
803-734-4716
-------
I
SOUTH DAKOTA
§nni Kallemeyn
fice of Air Quality & Solid Waste
Joe Foss Bldg., Room 217
§"-'erre, SD 57501
5-773-3153
I
TEXAS
erman Krause
munity Hazardous Waste Management
Texas Water Commission
= 0. Box 13087
•istin, TX 78711-3087
P.2-371-6474
TENNESSEE
Don Manning
TN Div. of Solid Waste Assistance
401 Church Street 14th Floor L&C Tw
Nashville, TN 37243-0455
615-532-0076
Ingrid Dierlam
Project Coordinator
Texas Water Commission
1700 N. Congress Ave. - P.O. Box 130
Austin, TX 78711-3087
512-475-4577 P
512-463-6648 F
aprothy Adams
«ste Reduction Specialist
Silt Lake City County Health Dept.*
§0 South 200 East
It Lake City, UT 84111
1-534-.4588 P
801-534-4502 F
1
tRMONT
(hn Miller
cycling Specialist
Agency .of Natural Resources, DEC
103 South Main Street, Laundry Bldg.
«terbury, VT 05676-0407
2-244-7831 P
802-244-5141 F
I
SCONSIN
Eric Syftestad
Mreau of Solid Waste Mgmt. Haz. Waste
Jlpartment of Natural Resources
101 S. Webster St., GEF II, Box 7921
«dison, WI 53707-7921
8-267-7561
VIRGINIA
Alan Lassider,
Environmental Engineering Consultant
Virginia Waste Management
101 N. 14th - Monroe Bldg - llth Flo
Richmond, VA 23219
804-225-2945
WASHINGTON
William P. Green
Hazardous Waste Program Planner
Solid & Hazardous Waste, Ecology Dep
P.O. Box 47600
Olympia, WA 98504-7600
206-438-7233 P
206-438-7759 F
WEST VIRGINIA
Whitey Ferrell
Environmental Analyst
Division of Waste Management, DNR
1356 Hansford Street
Charleston, WV 25301
304-558-6350 P
304-348-0256 F
DOMING
Tim Link
flid & Hazardous Waste Specialist
. Dept.of Environmental Quality
122 West 25th St - Herschler Bldg
Ieyenne, WY 82002
7-777-7752
I
675
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Appendix VIII
Permanent HHWM Program Managers
676
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Permanent HHW Management Program
Managers -1992-
ALASKA
Kill Kryger
..anager, Engineering & Planning
funicipality of Anchorage
111 East' 56th Avenue
..nchorage, AK 99518
907-561-1906 P
07-561-1357 F
I
ALABAMA
Iixie Bray
^ublic Information Officer
Kuntsville Solid Waste Disposal Auth.
1.0. Box 2619
untsville, AL 35804
205-880-6054 • '
I
CALIFORNIA
»udy Orttung
upervising Environmental Health Spec.-
San Bernardino Cty.Environmental Svc.
185 North Arrowhead Avenue " • '
an Bernardino, CA 92415-0160:'
714-387-4629 P
£14-387-4323 F
I
Lanie Hughes
Kenai Penninsula Borough
47140 E Poppy Lane
Soldotha, AK 99669
907-262-9657
ARIZONA
Anna Spitz ' •'
HHW Coordinator
Wastewater Management Division
130 West Congress
Tu'scon, AZ 85701-1317
602-470-3555
Lawrence Dwoskin
Supervisor, .Environmental Specialist
Tulare County Environmental Health
County Civic Center
Visalia, CA 93291
209-733-6441
Bedar Kehoe
eneral Manager - -
Sanitary Fill Co.
101 Tunnel Avenue
an Francisco, CA 94134
415-468-2442 P
15-468-3266 F
I
Keith Martin
Administrator Bi-County Integrated
Solid Waste Management Authority
1612 Poole Blvd.
Yuba City, CA 95991'
916-671-4327 P
916-671-4711 F
Kike Shetler
_ anagement Specialist
Riverside County Health Services
^065 County Circle Drive
•dverside, CA 92503
"14-358-5055 P
14-258-5017 F
I
tource: The Waste Watch Center
(MAC/WWC/ADMIN/HHWPUB)
I
Neil Jones
Regional Waste Management District
Monterey County
P.O. Box 609 ' .
Marina, CA 93933
408-384-5313
408-384-3567 F
2/5/93
677
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Melissa Colburne
Appropriate Technologies
750 Design Court - Suite
Chula Vista, CA 92011
619-421-1175
II
105
?am Jackson
Program Coordinator
San-Diego County Dept. of Health Serv,
P.O. Box 85261
San Diego, CA 92186-5261
619-338-2175 P
619-338-2139 F
Srian Johnson
Environmental Programs Coordinator
City of Santa Monica
200 Santa Monica Pier, Suite E
Santa Monica, CA 90401-3295
310-458-8227 P
310-393-1279 F
Jim Pfaff
Staff Analyst
Orange County IWMD
1200 North Main St., Suite 201
Santa Ana, CA 92701
714-568-4891 P
714-667-0275 F
Margaret Blood
Jackson Environmental Health -Opt
108 Court Street
Jackson, CA 95642 '
209-223-6439
Patrick Mathews
Solid Waste Analyst
Santa Cruz County Public Works
701 Ocean St. - Room 410
Santa Cruz, CA 95060
408-425-2481
408-425-3475
Thomas Oakley
CA AETC
1125 Hensley Street
Richmond, CA 94801
415-233-8001
Deanna Seaman
Environmental Compliance Specialist
Norcal Waste Systems, Inc.
5 Thomas Mellon Circle f 304
San Francisco, CA 94134
415-330-1109 P
415-330-1115 F
Dean Hill
Fire Chief
Oroville Fire Department
2055 Lincoln Street
Oroville, CA 95966
916-538-2'480
COLORADO
Janelle Henderson
Hazardous Waste Manager
Larimer Cty Dept of Natural Resource
P.O. Box 1190
Fort Collins, CO 80522-1190
303-498-5771 P
303-498-7985 F
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Alex Ariniello
Public Works Director
Boulder Cty. Public Works-Dept.
P.O. Box 471
Boulder, CO 80306
303^441-3900
DELAWARE
Julie Wilke
Delaware Solid Waste Authority
1128 S. Bradford Street
Dover, DE 19903
302-739-5361 P
302-739-4287 F
678
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FLORIDA
teborah Lugar
nvrn Res Specialist
Brevard County - Solid Waste Division
f725 St. Johns Street, Bldg D, 2nd Fl:
elbourne, FL 32940-6602
07-633-2043 P
07-633-2045 F
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Kennis Laabs
azardous Waste Director
County of Sarasota - Solid Waste
<982 Bee Ridge Road, Bldg. H, Unit 3
arasota, FL 34231'
13-364-4488 P
813-364-4377 F
David Gregory
Asst. Director for Hazardous Waste S
Palm Beach County Solid Waste Author
7501 North Jog Road
West Palm Beach, FL 33412-2402
407-687-1100 P
407-687-1103 F
Bill Lycan
Solid, Waste Division
.Marion County ' '
' 601 SE- 25th Avenue
Ocala, FL 32671
904-245-6530
Ion Stack
unicipal Service District
Monroe County .
^100 College Road West
•ey West, FL 33040
^05-292-4432 P
305-292-4401 F
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(artha Gray
ept. of Solid Waste.Management
inellas County
2800 110th Ave North
•t Petersburg, FL 33716
•13-892-7720
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|Tennifer Hobbs
nvironmental Specialist III
^ake County Environment
315 West Main Street
Iavares, FL 32778
04-742-8427
Steven .Waterman
Duval County Solid Waste Division
City of Jacksonville
37-2 West First Street
Jacksonville, FL 32206
904-630-0973
Freddy Cordero
Hazardous Waste Inspector
Dept. of Solid Waste
2300 Virginia Avenue
Fort Pierce, FL 34982
407-468-1768 P
407-489-6987 F
John Hauserman
Seminole County
3000 A Southgate Drive
Sanford, FL 32773
407-323-9615
§ren Allen
source Recovery Dept.
ange County Public Utilities
109 East Church Street, Suite 410
Irlando, FL 32801
07-836-7200 P .
407-836-7299 F
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Dana Hansen
Martin County Solid Waste Management
P.O. Box 1360
Jensen Beach, FL 34958
407-288-5700 P
407-692-3444 F
679
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.FLORIDA
Keith Kipp
Collier County Solid Waste Dept
3301 East Tamiami Trail Bldg G
Naples, FL 33962
813-774-8258
Susan Gaze
Volusia County DPW
1990 Tamaka Farms Road
"Daytona Beach, FL 32014
904-239-7766
Chris Pappas
Hazardous Waste Division
4400- Hunt Road
Kissimme, FL 34746
407-847-4481
IOWA
Kathy Kendall - Witkovski
Waste Management Administrator
Des Moines Metro Area Solid Waste
521 East Locust Street
Des Moines, IA 50309-1911
515-244-0021 P
515-244-9477 F
Stacy Strickman
Environmental Chemist
Indian River County SWD
1840 25th Street
Vero Beach, FL 32960-3394
407-770-5112 P
407-770-5095 F
Farouk El-Shamy
Environmental Manager
Pasco Government Complex
7536 State Street
New Port Richey, FL 34654
813-892-7720
Mike Bellinger
Environmental Engineer
Alchua County Office of Env. Protec
1 Southwest 2nd Place
Gainsville, FL 32601
904-336-2442
IDAHO
Paul Jacobson
Kootenai County.SW Dept
3650 Ramsey Road, C-9000
Coeur-d'Alene, ID 83814
208-769-4402 P .
208-664-2766 F
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ILLINOIS
Jennifer Fore
Program Manager
Illinois EPA
2200 Churchill Road, P.O. Box 19276
Springfield, IL 62794-9276
217-782-9284
KANSAS
Roy Patton
Director, Noxious Weed Department:
Harvey County Courthouse
P.O. Box 687
Newton, KS 67114
316-283-1890
INDIANA
Jane St. John
Monroe County Solid Waste District
1040 W. 17th Street
Bloomington, IN 47404
812-333-3866
Cindy Kidd
Reno County Public Works
206 West Street .
Hutchinson, KS 67501
316-665-2976
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KANSAS
•iane Utz
"olid Waste Manager'
City of Olathe
I-.O. Box 768
lathe, KS 66061
913-764-6477
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Iustin Boyd
arton County
1814 Lakin Street
Ireat Bend, KS 67530
16-793-1894
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Dennis Peterson
Director
Riley County Weed Department
2711 Anderson
Manhattan, KS 66502
913-539-3202
Gene Wellbrock
Program Manager
Ellis County HHW Program
P.o; Box 1431
Hays, KS 67601
913-625-4558
I ay DeJulio
ranklin County Noxious Weed Dept
Franklin County Courthouse
tawa, KS 66067
3-242-1176 P
3-242-1498 F
Chuck Hadsall
Miami County Solid Waste
P.O. Box 442
Paola, KS 66071
913-294-5859 P
913-294-3228 F
f
I
pe Daniels
|eavenworth County Health Dept,
20 Olive
gavenworth, KS 66048
J13-684-0730
MASSACHUSETTS
forge Berry
airman
urbridge Board of Health
(urbridge Town Hall, 47 Mashapaug Rd.
urbridge, MA 01566
8-764-7309
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lARYLAND
Con Trombka
vironmental Planner •
ntgomery Cty., Dept. of Env. Protec
101 Monroe Street, 6th Floor
•ockville, MD 20850
Wl-217 2380
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Alan Gremmel
City-County Health Dept
Wichita/Sedgwick City/Cnty Health De
1900 East 9th Street
Wichita, KS 67214
316-268-8351
316-268-8340 F
Russell Smith
Program Coordinator
Martha's Vineyard Refuse Disposal Di
P.O. Box 2248
Oak Bluffs, MA 02887
508-698-3479
Martha L. Beck
Program Specialist
Ingham County Health Department
5303 S. Cedar, PO Box 30161
Lansing, MI'48909
517-887-4312 P
517-887-4310 F
681
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MICHIGAN
Thomas M. Dewhirst.
Household Haz. Waste Coordinator
Kalamazoo Co. Environmental Health
418 W. Kalamazoo Avenue
Kalamazoo, MI 49007
616-384-8004
Robert MacDonald
Environmental Health Planner
Macomb County Health Dept.
43525 Elizabeth Rd
Mt. Clemens, MI 48045
313-469-5236
Dorothea Long
SE Barren County Landfill
P.O. Box 142
Buchanen, MI 49107
616--695-2500 P
MINNESOTA
Mary Catherwood
Coordinator, HHW Program
Kandiyohi County
711 Southeast 4th Street
Willmar, MN 56201
612-235-9678
Joe Wozniak
Environmental Health Specialist
Ramsey County Public Health Dept.
1910 West County Road B, #206
Roseville, MN 55113
612-292-7825 P
612-633-0571 F
Mike Guite
Western Lake Superior S.anitary Dist
27th Avenue West and the Waterfront
Duluth, MN 55806
218-722-3336
Donna Engstrom
Kent County Department of Public Wor
1500 Scribner, N.W.
Grand Rapids, .MI 49504
616-774-6892
Bill Hulbert
Westside Recycling
60050 Roberts Road P.O. Box 392
Three Rivers, MI 49093
616-279-5444
Carl Marshall
Special HHW Coordinator
City Environmental, Inc.
1923 Fredrick Street
Detroit, MI 48211
313-923-0080
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George Kinney •
Hazardous Waste Supervisor I
Dakota County Environmental Mgmt Dep
14955 Galaxie Avenue
Apple Valley, MN 55124
612-891-7541 P
612-891-7031 F
Susie Thomas
Solid Waste Officer
Becker County Environmental Services
PO Box 787
Detroit Lakes, MN 56502
218-847-7310 P
218-847-9664 F
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Michael Brandt ,_
Principal Environmentalist •
Hennepin City Environmental Manageme
417 North 5th Street
Minneapolis, MN 55401-1309 fl
612-348-4046 P •
612-348-8532 F
682-
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MINNESOTA
Ieslie Goldsmith
upervisor, Special Wastes Unit
MPCA - Hazardous Waste Division
1^20 North Lafayette Road
t. Paul, MN 55155-3898
o!2-297-8368 P
612-297-8676 F
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Iee Williams
ssistant Solid Waste Officer
Waseca County Courthouse .
(aseca County Courthouse
aseca, MN 56093
Kent Dahlquist
Tri-County SW Mgmt. Commission
601 North 20th Avenue
St. Cloud, MN 56303
612-255-6140
Leslie Loeffler
Carver County
600 East 4th Street
Chasha, MN 55318
618-448-1217
K" idi Ringhofer
cycling Coordinator
rlton County
§0. Box 220
rlton, MN 55718
8-384-4281
I
fger Wilkowske
W Coordinator
ce County
3800 East 145th Street
Kndas, MN 55019
7-332-6833
Mary Overlee Olson
Recycling Coordinator
Steele County Environmental Services
P.O. Box 890
Owatonna, MN 55060
507-451-4842
Dave Walter
MPCA-Hazardous Wate Division
520 North Lafayette Road
St. Paul, MN 55155-3898
612-297-8368 P
612-297-8676 F
•tsSOURI
Seryl Crafton
pt. of Public Works
13 Lakeview Avenue
Columbia, MO 65201
• 4-874-7280
NEW JERSEY . .
Ann Williams
Research Assistant
Burlington County Office of Waste Mg
P.O. Box 429
Columbus, NJ 08022
609-499-1001
MEXICO
Milo Myers
§ty of Albuquerque
0. Box 1293
Albuquerque, NM 87107
M5-768-2600
J)3-273-5586 F
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NEW YORK
Ed Harding
Div. of Solid Waste, Assist. Enginee
Monroe County
1845 Emerson Street
Rochester, NY 14606
716-254-4000 P
716-254-4216 F
683
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Brian Gilbricie
Sanitation Supervision
Town of Southampton
116 Hampton Road
Southampton, NY 11968
516-283-5210 ?
516-283-3732 ? •
Dena Miller
Nassau County DPW
425 Salisbury Park Drive
Westbury, NY 11590
John Reeve
Sanitation Supervisor
Riverhead Sanitation Department
200 Howell Ave
Riverhead, NY 11901
516-727-8194
PENNSYLVANIA
Rachel Rosenzweig
KHW Manager
Lancaster Cty. Solid waste Mgmt. Aut.h
1299 Harrisburg Pike/PO Box 4425
Lancaster, PA 17604
717-397-9968 P
717-397-9973 F
TEXAS
Robert Fernandez
Environmental Project Manager
City of Austin, Env. & Cons. Ser. Dept
P.O. Box 1088
Austin, TX 78767-8819
512-499-2722 P
512-499-2859 F
Paul Campbell
Resource Recovery Engineer
Dept. of Public Works
4361 Ridgewood Center Drive
Woodbridge, VA 22X92
703-335-6255
684
Kevin Manion
Director of Recycling
Oneida-Herkimer Solid Waste Authorii
311 Turner Street, Suite 4'0i
Utica, NY 13501
315-733-1224
James McMahon
Town of Southold
Town Hall - Main Road
Southold, NY 11971
516-734-7685
OREGON
Jim Quinn
Hazardous Waste Project Manager
Portland METRO
2000 SW First Avenue
Portland, OR'97201
503-221-1646 P
503-273-5586 F
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Lori Kobbe
HHW Director & Recycling Coordinator
Northern Tier Solid Waste Authority
P.O. Box 34 .
Blossburg, PA 16912 •
717-638-2107 *
VIRGINIA
Jennifer Ladd
Director of Environmental Management
Southeastern Public Service Authorit
723 Woodlake Drive, P.O. Box 1346
Chesapeake, VA 23320-1346
804-420-4700
804-420-6511
Sandra Contey
Water Pollution Control Plant
3401 Glebe Road
Arlington, VA 22202
703-358-6820 P
703-358-6875 F
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Illiott Gross " •
-rojecc Manager
Fairfax County DPW
12000 Government Center Pkwy, See 324
airfax, VA 22035-0059
703-324-5230
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VERMONT
Iarbara E. Winters
reject Manager - Waste Reduction
CSWD
(700 Troy Avenue
olchester, VT 05446
02-655-9801 P
02-655-9816 F
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Corey Chadwick
Chief of Environmental Services
Loudon County Dept. of Ntrl Resource
750 Miller Drive, SE Suite 200
Leesburg, VA 22075-0372
703-777-0372
Steve Parker
Special Assistant
Rutland County Solid Waste District
Scale Ave f 90
Rutland, VT 05701-4452
802-775-7209 P
SAME
Iaron Frank
olid Waste Manager
Public Works Department
(.0.. Box 849
urlington, VT 05402
02-863-9094
802-863-0466 F
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"ASHINGTON
firli Axelrod
W Project Coordinator-
^ity of Seattle, Solid Waste Utility
§0 Second Ave, -505 Dexter Horton 31dg
attle, WA 98104-1709
6-684-7804 P
206-684-7755 F
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lliam H. Englander
lid Waste Program Manager
of Bellingham
2221 Pacific Street
•ellingham, WA 98226
•06-676-6961
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Alijah Washington
•arina Maintenence Supervisor
"isherman Terminal - Port of Seattle
3919 18th Avenue, West
k attle, WA 98119
6-728-3398
I
Paul Alcantar
Facility Superintendent
Municipal Building.
15 Bridge Street
White River Junction, VT 05001
802-295-9353
Hal Williams
Chemical Processors,Inc./Burlington
2203 Airport Way South
Seattle, WA 98134
206-223-0500
Jerry Mingo
Recycling/Hazardous Waste Coordinate
Island Co. Solid Waste Dept.
P.O. Box 5000
Coupeville, WA 98239
206-679-7386
206-678-3449 F
Frank Harman
Marina ^Maintenence Supervisor
Shilsho'le Marina - Port of Seattle
7001 Seaview Avenue, ' NW
Seattle, WA 98117
206-728-3389
685
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Monica Hairston
Hazard., Infectious Waste Coordinator
City of Spokane
East 1225 Marietta
Spokane, WA 99207
509-625-7878 P
509-625-7899 F
Michelle Arnold
Solid Waste Specialist
Thurston County DPW
2000 Lakeridge Drive
Olympia, WA 98502
206-786-5485
Victoria Holt
HHW Project Manager
King County Solid Waste Division
400 Yesler Way, 6th Floor
Seattle, WA 98104
206-296-4464
Al Kakovich
Sales Manager
Chemical Processors,
P.O. Box 222
Washougal, WA 98671
206-223-0500
Inc.
Doug Pierce
City of Tacoma PWD
3510 South Mullen Street
Tacoma, WA 98409
206-591-5543 P
206-591-5547
WISCONSIN
Elaine Andrews
UWEX
Environmental Resources Center
1450 Linden Drive, Room 216
Madison, WI 53706
608-262-0142
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Mark Nedrow
Solid Waste Program Coordinator
Yakima County Public Works Departmen
128 N. 2nd Street, Rm 408 Courthouse «
Yakima, WA 98901 •
509-575-4076 *
686
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Appendix IX
_ Collection Program Contractors
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687
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HHW Collection Program Contractors
•1992-
APTUS
21750 Cedar Avenue
Lakeville, MN 55041
B-ruce %Bernice
Sales Representative
612-469-3475 ?
612-469-5140 ?
Burlington environmental
2203 Airport Way
Seattle, "WA 98134
Tim Ritchie
206-654-0301
Chemical Management
340 Eastern Pkwy.
Farmingdale, NY 11735
Keith Bullock
Lab Pack- Manager
516-454-6766
Chemical Processors
2203 Airport Way South
Seattle,*WA 93134
Jack WoIfin
Account Rep. of HHW & SQG Services
205-223-0500
ical Waste Management
Doremus Ave
i — iiJ. vncissi-^:
4185 Doremus Ave
Newark, NJ 07105
Lorissa Dashkiewicz
201-344-8469 ?
201-465-7313 F
Source: The Waste Watch Center
(MAC\WWC\ADMIN\HHW PUB)
Advanced Environmental Technology Corp
Metro Park West - 398 Cedar Kill St.
Marlboro, MA 01752
Jim Sullivan
Sales Representative
508-460-*9960
Chem-Safe Services, Inc.
P.O. Box 616
Kittitas, WA 98934
Pat McGinty
Field Scientist
509-968-4680
Chemical Pollution Control
120 South 4th Street
Bay Shore, Long Isla, NY 11706
Danny Carr
Safety Officer
516-586-0333 ?
516-586-0727 F
Chemical Waste Management
41-85 Doremus Ave.
Newark, NJ 07105
Dave Carson-
Regional Operations Manager
201-465-6848
Chemical Waste Management
4277 Technology Drive
Fremont, CA 94538
Hallie Fraser
HHW Coordinator
510-651-2964
11/11/92
688
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Chemical waste Management
1621 Auburn Avenue
Naperville, IL 60565
Eric Laut
Project Developement Manager
708-369-9543
Chemical Waste Management
1090 NorthChase Pkwy. - Suite 290
Marietta, GA 30057
Jerry Strub
Regional Sales Manacrer
404-951-6700
Clean Harbors
12 Mercer Re.
Natick, MA 01760
Patrick 0'Tocie
Sales Representative
508-655-8863
DYNEX Industries, Inc
4751 Mustang Circle
St. Paul, MN 55112
Robin Shaw
800-733-9639 ?
612-784-5397 F
Drug and Laboratory Disposal, Inc,
331 Broad Street
Plainwell, MI 49080
Rhonda Sybesma"
Administrative Assistant
616-685-9824.
Franklin Pumping Service
Industrial Park
Wrentham, MA 02093
Gary Benham
Sales Reoresentitive
617-384-6151
.Chemical Waste Management
1156 Catherine Ave
Naperville, IL 60540
A.J. Novak
Project Development Man
708-305-0877
Clark Processing,"Inc.
300 South West End Ave
Dayton, OH 45427
Eric Keifer
800-543-3670
Crosby and Overton
1610 West 17th Street
Long Beach, CA 90813
Larry Boyle
General Manacer
310-432-5447
Disposal Control Service
"i'369 West Ninth Street
Upland, CA 91786
Phil Gentile Sr.
VP of Management/Sales
714-981-0998
Findiey Chemical Disposal
10720 Redwood Avenue
Fontana, CA 92335 '
Laura Canney
714-823-3939
Green Alternatives, Inc.
1609 A Regatta Lane
San Jose,"CA 95112
Tobi Romero
Program Manager
800-345-3363 P
408-441-0245 F
689
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•Greenfield Environmental
5964 LaPlace Court, Ste 1150
•Carlsbad, CA 92008
Laura Jamayo
613-431-55-00
Laidlaw Env. Services(Nort:
221 Sutton Street
Ncrth Andover, MA 01545 .
LeeAnn Merashoff
KHW Manager
508-683-1002
New England Marine -Contractors
13 Dorset Lane
Will-is ton, VT 05495
Charles Peterson
President
802-879-8800
Pleasant Hill Bavshore Disposal
P.O. Box 23164 ,"
Pleasant Hill, CA 94523
Patricia Mehaouchi
510-685-4716
East;), Inc.
Quadrex Environmental
1940 NW 67th PI.
Gainesville, FL 32606
Wilson Anthony-
904-373-6066
Rinchen Co.
6133 Edith Blvd, NE
Albuquerque, NM 87107
Mike Loustanau
Technical Representative
505-824-0164" '
Heritage Remediation/Engineering
-.1175 Western Drive
Indianapolis, IN 46241
Joel Hall
Sales Representative
317-243-7475 ?
317-486-29&4 ?
McDonald and Watson
le 12 Green Hill Road'
Pole
RI 02919
Johnston, .
Fran Slade
401-946-0200
Northwest Enviroservice, Inc.
5333 Fairbanks'St. - Suite 6
Anchorage, AK 99518
Larry Wilkinson
Chemical Enaineer
907-272-9007
Pollution Solution
23.7 Spear St..
Burlington, VT 05403
Amy -Paae
802-860-1200
Radiac Research Company
261 Kent Avenue
Brooklyn, NY 11211
Keith Foley
718-963-2233
Rollins CHEMPACK Inc.
1 Rollins Plaza
Wilmington, DE 19803
Bob Coffey
Administrative Marketing Manage:
302-47S-2700
690
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SET Environmental
450 Sumac Road
Wheeling, IL 60090
Steve Schmitz
Project Manager
708-537-9221
Special Resource Management, Inc.
91" Island Avenue
Boise, ID 83706
Idaho Branch Manager
800-654-2504 P
208-345-3725 F
Special Resource Manacement, Inc.
P*.0. Box 86, HC 31 - 3ox '132
Pierre,'SD 57501
Kevin Tviedt
Dakota Branch Manacer - • •
800-822-0287 ?
'605-224-9538 c
Special Resources Management, Inc
1447 44th Street, North
Fargo, ND 58102-2854
Larry Wadswortn
©Derations Supervisor
.800-445-440-4 ?
701-231-9399 F
Triumvirate Environmental, Inc.
345 Dorchester Avenue
Boston, MA 02127
Caroline Gallagher
Office Manager
617-269-9080 ?
617-26S-9110 F
Vallejo Garbage Service
P.O. Box 3157
Vallejo, CA 94590
Pete Friesen
707-552-3110
Western Waste ' -
310 West 190th Street, Suite 100
Gardena, CA 90248
310-329-1425
Solvent Services
Berryessa Road
San Jose, CA 95133-
408-251-7554 .
Special Resource Management, Inc.
4500 Dell Range Blvd.'
Cheyene, WY 82009 • .
Charles Porter
Wyomina Branch Manager
800-237-2647 P
307-635-9248 F
'Special Resource Management, Inc. '
"1-90 & Rocker Interchanae, P.O. 4168
Butte, MT 59701
• Steve Wright
Manager, Business Development
800-334-8911 ?
406-782-9968 F
Specialty Resource Management
1131 Westrac Dr. - Suite 201
Fargo, ND 58103
Anne Harri- •
Branch Manager
701-234-9394
U'.S. Pollution Control, Inc.
515 West Greens Road Suite-.500
Houston, TX 77067
Carl Shuler " ' .
303-938-5503
Wade Salvage
'293 Jackson Road
Atco, NJ 08004
Andrew Wade
President
609-767-2760 P
609-767-0698 F
Yuba Sutter Disposal Inc
3001 N. Levee Dr.
Marysville, CA 95991
Dorman Steele
916-743-6933 F
691
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Appendix X
WWC Publications Order Form
HHWMVII Audio Tape Order Form
U.S. EPA Order Form .
692
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ASTE
ATCH
CENTER
Household Hazardous
Waste Publications
The following items have been prepared by the Waste Watch Center to support your efforts in
managing household hazardous waste (HHW). Price includes cost of copying, postage and handling.
PRICE QUANTITY
Household HazardousWaste Management News (Quarterly newsletter)
Contribution: $10.00 (Individual) $35.00 (Agency) $75.00 (Corporate)
HHWM News — back issues: No. 1-15 (complete set) including postage — $14.00
Back #'s 1 2 3 4 5 9 (SI.60 each) 6 7 8 10 11 12 13
14 15 (S 1.00 each)
HHW Collection Programs in the U.S. — 1992 $10 JO
HHW Collection Programs in the U.S. — 1991 59.50
HHW Collection Programs in the U.S. — 1990 $7.50
HHW Collection Programs in the U.S. — 1988-89 57.50
HHW Collection Programs in .the U.S. — 1980-87 ......„; 56.50
HHW Management State Agency Contacts (1992) 56.50
Permanent HHW Management Programs in Operation — 1992 $13.50
Permanent HHW Management Program Managers (1992) „-.; 5<5.50
Education Contacts (1992) ;. 55.00
Source Reduction Contacts (1992) 55.00
Household Battery Collection Programs in the U.S. — 1992 ; 55.00
Dry Cell (Household) Battery Contacts (1992)."....' ......" |. ' 55.00
Lead-Acid (Car) Battery Contacts (1992) 55.00
CESQG Collection Program Contacts (1992) 55.00
Farm Pesticide Collection Program Contacts (1992) 55.00
Pesticide Use and Management Program Contacts (1992) 55.00
Pesticide Reduction Contacts (1992) 55.00
Fluorescent Light Contacts [Recyclers, Ballasts Servicers etc.] (1992) $10.00
Household Cleaning Product Contacts (1992) 55.00
Used Oil Collection and Management Contacts (1992) 55.00
Curbside Used Oil Collection Programs in the U.S. — 1992 55.00
Used Oil Filter Management Equipment Contacts (1992) 55.00
16 HAVERH1LL STREET • ANDOVER, MA 01810 • PHONE - 508-470-3044 • FAX 508-470-3384
January 29,1993
693
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Paint Collection and Recycling Contacts (1992) $5.00
HHW Collection Program Contractors (1992) , $5.00
Manufacturers of Prefabricated HHW Buildings (1992) $5.00
Bibliography on HHW (1992) $13.50
Lawn Care: Alternatives to Chemicals — Resource List (1991) $2.50
Proceedings of 5th National HHW Management Conference (1991) $45.00*
Proceedings of 7th National HHW Management Conference (1993) $TBA*
(For other year Proceedings of U.S. EPA HHWM Conferences, contact NTIS: 703-487^650) .
Copies of Articles and.Speeches as itemized below — $5.00, 1st 10 pages, $.20 per
additional page.
Packets of information are available on:
• What is HHW?, How Much is There?, Why be Concerned?
• How to Set-Up a Collection Program
• HHW Education
• Household Batteries
• Paint.
• Fluorescent Lights. ' :
• HHW Source Reduction..^
• Household Cleaners
* Pesticides ;
• Used Oil „'.'
• Permanent Programs
• CESQG ! '.
Specific issue prices are available on request.
*Plus additional postage for non-US, orders
TOTAL
DATE: Please Make Check Payable to: WASTE WATCH CENTER.
NAME TITLE
ORGANIZATION PHONE.
ADDRESS FAX
CTTY; STATE ZIP
16 HAVERHILL STREET • ANDOVER, MA 01810 • PHONE - 508-470-3044 • FAX 508-470-3384
January 29, 1993
694
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U.S. EPA HOUSEHOLD HAZARDOUS WASTE MANAGEMENT
• CONFERENCE
• AUDIO CASSETTE ORDER FORM
TUESDAY, DECEMBERS, 1992
£-1 Minnesota Issues Session
•ession 1 A-Management of HHW and problem materials •
Session IB-Reducing Problem Materials
Cession IC-Minnesoia HHW Programs
•ession ID-Problem Materials Management
"ession 2A-HHW Education Program's
Session-IB-Minnesota HHW Programs
•ession 2C-Problem Materials Management
WEDNESDAY, DECEMBER 9,1992
G-l Opening Plenary Session-
I Moderator: Dana Duxbury, WWC. MA
Greetings from the State-Tim Scherkenbach. MPCA, MN
Greetings from the County-John Derus, Hennepin County
m Keynote: HHW and Municipal Solid Waste-Terry
• Grogan, US EPA, DC . •
™ Design for the Environment-Walter Stahe!, Product Life
Institute, Switzerland
Jp-2 "An Overview of CESQG Issues"
David Galvin, Seattle, METRO, WA.
"Source Reduction Priorities"
Philip Dickey, Washington Toxics Coalition, WA.
Mercury in MSW Incinerator Emissions-Mike Winka, NJ
DEP
New Initiatives in Science Education-Herbert Thier,
CEPUP. CA
I
I
Iunch- "Legislative Initiatives to Reduce Toxicity of
Municipal Solid Waste" Rep. Jean Wagem'us, MN
Workshop 1-A "How To's"
Vbrkshopl-B Taint 1*
Workshop 1-C "Household Batteries'
Workshop 1-D "Other Problem Wastes"
Workshop 1-E "Indoor Air" ADDED TO IA
S
f
Send orders and make checks payable to:
•>roMedia Productions, Inc.
*593 Hamline Ave.
RosevilIe,MN55113
»>hone# 612-631-3681
%ax'# 612-631-1606
Name
ddress.
Phone
I
• Workshop 2-A "How To's"
Workshop 2-B "Paint n Market Issues"
Workshop 2-C."U.S. Household Battery'
Workshop 2-D "Fluorescent Lamps"
Workshop 2-E "Collection Case Studies I"
THURSDAY, DECEMBER 10,1992
Workshop 3-A "How To's"
Workshop 3-B "Pesticide Use, Collection and Reduction"
Workshop 3-C "Education I-Schools Implementation and Evaluation"
Workshop 3-D "Used Oil & Filters"
Workshop 3-E "Waste Management I:Waste Types and Management"
Workshop 4-A "How To's"
Workshop 4-B "CESQG I"
Workshop 4-C "Education E-General Public"
Workshop 4-D "Source Reduction I:Labeling"
Workshop 4-E "Waste Management nrOptions"
Lunch Speaker- Hubert Humphrey DZ Attorney General. State of MN
Workshop 5-A "How To's"
Workshop 5-B "CESQG H-Collection Program Case Saidies"
Workshop 5-C "Collection Case Studies IT
Workshop 5-D "Source Reduction H:How To Measure Results"
Workshop 6-A "Rurai Programs"
Workshop 6-B "CESQG HI-Informanon"
Workshop 6-C "Permanent Programs F
Workshop 6-D "Source Reduction HI: Effectiveness of Alternatives"
FRIDAY, DECEMBER 11,1992
Workshop 7-A "Waste Management Decontrolling the destiny of
your waste"
Workshop 7-B "CESQG IV-Technical Assistance"
Workshop 7-C "Permanent Programs n-Case Studies"
Workshop 7-D "Source Reduction IV: Reformulation''
Plenary Session: Q A A with HHW, Manufacturer and Contractor
Panels
Closing Remarks: Charlotte Mooney, US EPA, WA
Please circle your selections.
Full Set-43 tapes - includes free shipping $399.00
_Tapes @ $10.00 each $
Shipping!® $ I/tape $8 max. $
Total S
Method of Payment:
Check
Visa/MC Exp Date.
S ignature
695
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ORDER FORM
EPA Announces Three Publications
On Household Hazardous Waste and
Used Dry Cell Battery Collection Programs
For the General Public For Public Officials, & Community Leaders
1. Household Hazardous
Waste: Steps to Safe
Management.
A flyer providing information to
households about how to
identify household hazardous
waste (HHW); the dangers of
improper disposal; and safe
management methods for
HHW households.
2. Household Hazardous
Waste Management:
A Manual for One-Day
Collection Programs
Designed to help communities
plan and operate a successful
household hazardous waste
collection day, this manual
provides guidance for all
aspects of planning, organiz-
ing, and publicizing the event.
3. Used Dry Cell Batteries:
Is a Collection Program
Right for Tour
Community?
This handbook helps communi-
ties determine whether estab-
lishing a battery collection
program is appropriate for
them. It is organized around
ten key issues, from determin-
ing the types and amounts of
batteries being discarded, to
estimating the likely costs of
collection.
Please send me the following publication(s) (check boxes that apply)
D HHW: Steps to Safe Management (Flyer) (EPA530-F-92-031)
D HHW: A Manual for One-Day Collection Programs (EPA530-R-92-026)
Used Dry Cell Batteries: Is a Collection Program Right
for Your Community? . (EPA530-K-92-006)
Name:
Address:.
City:
State:
Zip:.
Please leave completed form at the Conference Registration Desk
or mail to:
RCRA Information Center (OS-305)
United States Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
696
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