EPA/600/2-89/064
December 1989
MANAGEMENT OF HOUSEHOLD AMD SMALL-QUANTITY-GENERATOR
HAZARDOUS WASTE IN THE UNITED STATES
by
Dana Duxbury and Associates
Corporate Office Centers
Andover, Massachusetts 01810
Contract No. 68-02-4279
Project Officer
James S. Bridges
Waste Minimization Branch
Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA/600/2-89/064
2.
3. RECIPIENT'S ACCESSION NO.
FB 90 1 4 88 67 /is
4. TITLE AND SUBTITLE
Management of Household and Small-Quantity-Generator
5. REPORT DATE
December 1989
Hazardous Waste in the United States
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Dana Duxbury
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Dana Duxbury and Associates
Corporate Office Centers
Andover, Massachusetts 01810
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-4279
12. SPONSORING AGENCY NAME AND ADDRESS
US Environmental Protection Agency
13. TYPE OF REPORT AND PERIOD COVERED
Office of Research and Development
Risk Reduction Engineering Laboratory
14. SPONSORING AGENCY CODE
EPA/600/14
15. SUPPLEMENTARY NOTES
Prepared by Dana Duxbury & Associates under subcontract to TRI, Inc.
Project Officer - James S. Bridges (513) 569-7683 FTS 684-7683
(68-02-4279)
ib. AtsS ( RaC i
The International Solid Waste and Public Cleansing Association (ISWA), an
international nongovernmental organization comprising twenty-seven national
organizations of waste management professionals, conducted a survey to obtain
information regarding household and small-quantity-generator hazardous wastes. This
report presents the U.S. response to this survey. The questionnaire covered five
different areas: 1) problems, 2) policy approach, 3) technical and organizational
aspects, 4) case studies, and 5) treatment and disposal research and development.
Comments were also invited. The appendices include the ISWA Questionnaire, a
table and other information regarding State laws and regulations governing household
hazardous waste, and a listing of the permanent household hazardous waste collection
programs operating in 1988. A glossary of acronyms is presented at the end of the
report.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATl Field/Group
Household hazardous waste (HHW)
Small-quantity-hazardous waste generators
(Sqhwg)
18. DISTRIBUTION STATEMENT
RELEASE TO PUBLIC
19. SECURITY CLASS (This Report)
UNCLASSIFIED
21. NO. OF PAGES
84
20. SECURITY CLASS (This page)
UNCLASSIFIED
22. PRICE
EPA Form 2220-1 (R*v. 4-77) previous
EDITION IS OBSOLETE
i
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DISCLAIMER
This material has been funded wholly or in part by the United States
Environmental Protection Agency under Contract No. 68-02-4279 to Dana Duxbury
and Associates. It has been subject to the Agency's review and it has been
approved for publication as an EPA document.
ii
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FOREWORD
Today's rapidly developing and changing technologies and industrial
products and practices frequently carry with them the increased generation of
materials that, if improperly dealt with, can threaten both public health and
the environment. The U.S. Environmental Protection Agency is charged by
Congress with protecting the Nation's land, air, and water resources. Under
a mandate of national environmental laws, the agency strives to formulate and
implement actions leading to a compatible balance between human activities
and the ability of natural systems to support and nurture life. These laws
direct the EPA to perform research to define our environmental problems,
measure the impacts, and search for solutions.
The Risk Reduction Engineering Laboratory is responsible for planning,
implementing, and managing research, development, and demonstration programs
to provide an authoritative, defensible, engineering basis in support of the
policies, programs, and regulations of the EPA with respect to drinking
water, wastewater, pesticides, toxic substances, solid and hazardous wastes,
and Superfund-related activities. This publication is one of the products of
that research and provides a vital communication link between the researcher
and the user community.
This report presents the results of a survey conducted by the Interna-
tional Solid Waste and Public Cleansing Association (ISWA). The survey was
designed to collect information on household hazardous wastes and on haz-
ardous wastes produced by small-quantity generators. Its intent was to
provide a means of sharing mutual problems and experience and to promote
cooperation among the various responsible and interested parties.
For further information, contact the Waste Minimization, Destruction,
and Disposal Research Division of the Risk Reduction Engineering Laboratory.
E. Timothy Oppelt, Director
Risk Reduction Engineering Laboratory
iii
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PREFACE
This report presents the U.S. response to a survey conducted by the
International Solid Waste and Public Cleansing Association (ISWA). The
information presented herein covers various aspects of household and small -
quantity-generator hazardous wastes. The Office of Research and Development
of the EPA is currently looking into all areas of both of these environmental
problems, particularly those dealing with household hazardous wastes. We
believe this report contains considerable information that should be shared
with the public, industry, and academia, whose combined efforts will be
required to solve these pressing problems.
Dr. John Skinner
Acting Deputy Assistant Administrator
Office of Research and Development
Washington, D.C.
iv
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ABSTRACT
The International Solid Waste and Public Cleansing Association (ISWA),
an international nongovernmental organization comprising 27 national
organizations of waste management professionals, conducted a survey to obtain
information regarding household and small-quantity-generator hazardous
wastes. This report presents the U.S. response to this survey.
The questionnaire covered five different areas: 1) problems, 2) policy
approach, 3) technical and organizational aspects, 4) case studies, and 5)
treatment and disposal research and development. Comments were also invited.
In the problems area, the U.S. response names the Congressional Acts
governing hazardous wastes and the amendments thereto. It also indicates the
exemptions, which include household wastes. Although not legally defined as
hazardous, these wastes are nevertheless defined by the EPA and individual
States.
In the area of policy approach, the national policy regarding household
hazardous wastes (HHW) is presented. This policy, which was formally stated
by the EPA in November 1988, is to provide technical assistance to State and
local governments and to promote the dissemination and use of educational
materials. Various State and local policies are also presented.
With regard to small quantity generators (SQGs), policy changes occurred
in 1984 when the Hazardous and Solid Waste Act (HSWA) was amended to include
SQGs. In April 1986, EPA published an implementation plan describing its
strategy concerning regulations that apply to SQGs. This strategy includes
both a regulatory and nonregulatory approach, both of which are described.
The State and regional approaches are also described and include both
regulatory and nonregulatory programs aimed at SQGs. Efforts at the local/
community level are also included in the report.
In the area of supporting institutions, organizations, and authorities,
the report provides a breakdown of those involved in household hazardous
waste management at the national, State, regional/municipal/local, and
private levels. Separate collection of HHW has been subsidized by both
national and State governments, and funding sources are discussed.
In the area of case studies, the report presents four studies illus-
trating the application of regulations and policies. These studies cover
auto body shops, batteries, used oil, and paint.
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In the area of treatment and disposal research and development, existing
and planned facilities for recycling, treatment, or disposal of HHW are
briefly described. Permanent HHW collection centers and the disposition of
solvents received at these centers are also discussed.
The research and development activities that have been undertaken by
industry, government agencies, ana citizens' groups are presented.
Finally, the future perspectives on HHW and SQGs in the United States
are presented.
This report was submitted in fulfillment of Contract 68-02-4279 by Dana
Duxbury & Associates, Andover, Massachusetts, under the sponsorship of the
U.S. Environmental Protection Agency.
vi
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CONTENTS
Disclaimer ii
Foreword i i i
Preface iv
Abstract v
Figures ix
Tables ix
1. Introduction 1
2. Problems 2
Hazardous substances and consumer products 2
Commercial small-quantity generators 3
3. Pol icy Approach 4
Policy aims for HHW 4
Policy aims for SQ6S 5
Generators of HHW 10
Waste and waste generators 11
Information activities (HHW) 12
Information activities (SQGS) 15
HHW policy basis-compulsory or voluntary? 17
SQG policy basis-compulsory or voluntary? 20
HHW policy--active, "front-end," or passive "end-
of-the pipe" measures? 21
Future perspectives (HHW and SQG) 25
4. Technical and Organizational Aspects of Household and
SQG Waste Management 27
Supporting institutions, organizations, and authorities 27
Promotional activities or subsidies 27
5. Case Studies 29
Case study--auto body shops 29
Case study—batteries 35
Case study—used oil 43
Case study—paint 48
vi i
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CONTENTS (continued)
6. Treatment and Disposal Research and Development 53
Facilities for recycling 53
R&D activities—management and substitution of hazardous
substances in consumer products 55
Clean technologies 56
Future perspectives on HWW and SQGS 57
References 58
Appendices
A. Survey on Household Hazardous Waste Management in 59
Member Countries
Source: I SWA Working Group of Hazardous Waste
B. State Level Household Hazardous Waste Law and Regulations 62
Source: Dana Duxbury & Associates
C. Permanent Household Hazardous Waste Collection Programs 65
Operating in 1988
Glossary 73
vi i i
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No
1
2
3
4
5
6
7
No
1
2
3
FIGURES
States with HHW collection programs 8
Categories of hazardous waste generators 13
Number of collection programs each year since 1981 24
Breakdown of the 1987 U.S. battery market 36
The 1987 Retail Market by Size 37
Use of mercury in U.S. consumer battery production 39
New Hampshire/Vermont project battery collection logo 42
TABLES
Household Hazardous Waste Collection Programs Totaled
by Year 6
Hazardous Waste Generated and Reported by Auto Body Shops 30
Management Practices 31
ix
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SECTION 1
INTRODUCTION
This report has been prepared in response to a survey conducted by the
International Solid Waste and Public Cleansing Association (ISWA), an inter-
national nongovernmental organization comprised of 27 national organizations
of waste management professionals. The ISWA Working Group on Hazardous
Wastes has been active since 1984. Its first 3-year program resulted in the
publication of a book entitled International Perspectives on Hazardous Waste
Management in 1987 by Academic Press.
As part of its second 3-year program, running from 1987 to 1990, the
Working Group is becoming active in the field of household hazardous waste
management and small-quantity hazardous waste generators. As part of this
activity, ISWA designed a survey to generate information for an international
report on household hazardous waste and small-quantity generators, which will
serve as an instrument for mutual exchange of experience and cooperation (see
Appendix A).
The U.S. Environmental Protection Agency (EPA) prepared this report to
provide the ISWA Working Group with the U.S. response to its survey. Section
2 addresses the subject of Problems; Section 3, Policy Approach; Section 4,
Technical and Organizational Aspects; Section 5, Case Studies; and Section 6,
Treatment and Disposal Research and Development. Appendix A contains the
ISWA Questionnaire, Appendix B presents a table and other information regarding
State laws and regulations governing household hazardous waste, and Appendix
C lists the Permanent Household Hazardous Waste Collection Programs operating
in 1988. A glossary of acronyms is presented at the end of the report.
1
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SECTION 2
PROBLEMS
2.1 HAZARDOUS SUBSTANCES AND CONSUMER PRODUCTS
The EPA promulgated regulations under the Resource Conservation and
Recovery Act (RCRA) (40 CFR, Subtitle C) that define which wastes are regu-
lated as hazardous. Hazardous wastes are solid wastes that are listed as
hazardous waste in the RCRA regulations or that demonstrate characteristics
of a hazardous waste [i.e., ignitability, corrosivity, reactivity, and
extraction procedure (EP) toxicity].
Individual States may receive authorization under RCRA to regulate waste
generators at least as stringently as Federal law requires. According to a
representative of the RCRA Hotline [(800) 424-9346], 42 of the 50 States have
been delegated this authority under the original 1976 Act. Therefore, the
wastes and the generators that are addressed by a State's policy regarding
small-quantity generators (SQGs) or household hazardous waste (HHW) vary from
State to State, depending on State definitions of a hazardous waste, an HHW,
and an SQG, and on priorities within the State.
Hazardous substances that are subject to regulation under the Compre-
hensive Environmental Response, Compensation and Liability Act (CERCLA)* of
1980 include specified reportable quantities listed in the regulations, and
those wastes regulated by RCRA. CERCLA and its accompanying amendments (the
Superfund Amendments and Reauthorization Act, or SARA) regulate hazardous
substances as they pertain to waste site cleanup, emergency response, and
providing information to communities (community right-to-know information).
Hazardous substances used in the workplace are also regulated. The
Occupational Safety and Health Administration (0SHA) has set permissible
exposure limits for approximately 400 substances appearing on the "Z List" of
the Occupational Safety and Health Act.
Wastes generated by households (defined as including single and multiple
dwellings, hotels, motels, and other residential sources) are excluded from
regulation under RCRA Subtitle C. Wastes generated by households are not
legally defined as hazardous. The EPA and individual States defined HHW,
however, and a discussion of these definitions is provided in Section 3.
*
Commonly referred to as Superfund.
2
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2.2 COMMERCIAL SMALL-QUANTITY GENERATORS
Subtitle C of RCRA excludes from regulation those businesses that do not
generate wastes in sufficient quantities to be regulated as large- or small-
quantity hazardous waste generators. These conditionally exempt businesses
must meet the following criteria:
° Hazardous waste cannot be generated in excess of 100 kg/month.
° No more than 1 kg of waste defined under the regulations as acutely
hazardous may be generated each month.
° No more than 100 kg of acutely hazardous residue or contaminated
debris may be generated each month.
0 No more than 1000 kg of hazardous waste may be accumulated on site
at any one time.
Businesses that are exempt from RCRA Subtitle C regulations may be
subject to compliance with corresponding State regulations. Individual
States are authorized by the U.S. EPA to regulate the generation of hazardous
waste more stringently than the Federal Government. For example, the
Commonwealth of Massachusetts regulates nonhouseholds that generate more than
20 kg of hazardous waste per month. In California, all hazardous waste (in-
cluding household hazardous waste) is subject to State regulatory require-
ments. Furthermore, SQGs are not exempt from CERCLA and SARA, which have
been interpreted to impose retroactive, strict, joint-and-several liability
for cleanup costs connected with releases of hazardous waste to the environ-
ment.
3
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SECTION 3
POLICY APPROACH
3.1 POLICY AIMS FOR HHW
3.1.1 National Policy
Because HHW is not regulated as a hazardous waste under RCRA Subtitle C,
EPA's policy is not aimed at regulating, but rather at promoting HHW collec-
tion and management programs by providing funding, information, and technical
assistance to State and local governments.
The EPA completed a formal study of HHW in response to a congressional
directive. In Section 302 of the 1984 Hazardous and Solid Waste Amendments
(HWSA) to RCRA, Congress directed the EPA to explore the relationship between
household products and HHW and the formation of landfill leachate. In an
effort to explore these concerns and to provide further knowledge about HHW
collection programs, EPA completed an initial study entitled "A Survey of
Household Hazardous Waste Collection Programs" in October 1986.
In November 1988, EPA issued a formal policy statement regarding HHW
collection and management programs. According to this statement, the EPA
"... enthusiastically supports household hazardous waste (HHW) collection and
management programs.... EPA believes that these programs are important
because they: (1) promote citizen awareness regarding proper handling of
HHW; (2) reduce the amount of HHW in the municipal solid waste stream which
ultimately is taken to municipal waste combustors or landfills; (3) limit the
amount of HHW which is dumped down a drain and ultimately discharged to a
publicly-owned treatment works (POTW), or is dumped indiscriminately; (4)
remove a greater amount of HHW from the home, thereby reducing potential
safety hazards; and (5) help to reduce the risk of injuries to sanitation
workers." (Porter memorandum, 11/88)
At the EPA Second National Conference on HHW Management (HHWM), Joseph
Carra, who was Director of the EPA's Waste Management Division of the Office
of Solid Waste at the time of the conference, stated the EPA's policy goal of
regarding how the Agency will address HHW management. According to Carra,
EPA's role is to provide technical assistance to State and local governments
and to promote the dissemination and use of educational materials.
3.1.2 State/Regional Policy
Although most of the 50 States do not regulate HHW, States such as
California and Rhode Island have chosen to apply hazardous waste regulations
4
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to HHW. State policies and management plans vary from State to State. Since
1981, more than 1300 HHW collections have occurred in 43 states with varying
levels of State support and guidance (see Table 1 and Figure 1). The diversity
and number of State programs that address HHW are highlighted in Appendix B.
3.1.3 Local/Community Policy
Community management plans for HHW vary significantly, ranging from no
action to activities such as public education only, one-time collection days,
periodic (e.g., seasonal) collections, collections involving single waste
streams such as paint only or pesticides only, exchanges such as paint
exchange days, joint community-sponsored collection days, permanent collec-
tion facilities that operate somewhere between 1 day per month and 5 days per
week, and curbside collection of HHW such as used oil.
The following are examples of different community approaches:
° Tuscaloosa and Birmingham, Alabama, jointly sponsor a program
called "Project ROSE" (Recycled Oil Saves Energy). The program
which has operated successfully since 1977, includes a voluntary,
curbside, used-oil-collection program.
° San Bernardino, California, operates an ongoing paint and oil
collection site that is open 5 days per week. Latex paint that is
collected is bulked, reprocessed, and sold. Oil-based paint is
bulked, tested for PCB's, and reused if it is not hazardous; if it
is hazardous, it is disposed of at a licensed hazardous waste
facility.
3.2 POLICY AIMS FOR SQGS
3.2.1 National Policy
Prior to the 1984 HSWA, SQG waste was not regulated as hazardous waste.
Since 1984, EPA's policy aim with regard to SQGs has been to address hazard-
ous waste management through both a regulatory and nonregulatory approach.
Currently, SQGs must comply with national hazardous waste management require-
ments. Like HHW generators, SQGS are also addressed by CERCLA and SARA,
which pose retroactive, strict, joint-and-several liability on the generators
of hazardous waste.
The EPA published an implementation plan describing its strategy with
regard to regulations that apply to SQGs (U.S. EPA April 1986). This strat-
egy relies primarily on information dissemination, voluntary compliance, spot
compliance monitoring, and enforcement action for major violators as the
means for implementing the standards. The goal of the EPA plan is "...to
ensure that SQGs are brought into the 'regulated community"' (University of
California at Davis 1987, p. 52 -53).
The nonregulatory approach EPA has chosen is meant to encourage SQGs to
apply the Agency's waste management hierarchy—reduce, reuse, recycle, treat,
5
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TABLE 1. HOUSEHOLD HAZARDOUS WASTE COLLECTION PROGRAMS TOTALED BY YEAR3
State
1981
1982
1983
1984
1985
1986
1987
1988
Total
Alabama
1
1
Alaska
2
3
4
7
2
6
24
Arizona
1
1
2
Arkansas
1
1
California
1
5
12
37
28
80
95
258
Colorado
4
1
5
Connecticut
1
9
25
24
38
97
Delaware
1
1
Florida
21
22
16
13
17
89
Georgia
0
Hawai i
1
1
2
4
Idaho
0
111i noi s
1
6
7
Indiana
2
1
2
5
10
Iowa
2
3
5
Kansas
3
3
Kentucky
2
1
3
Louisiana
1
1
1
2
5
Maine
1
1
2
Maryland
1
1
3
5
Massachusetts
1
14
31
33
78
51
101
309
Michigan
2
8
14
10
20
54
Minnesota
6
10
9
28
53
Mississippi
0
Missouri
1
1
Montana
1
1
Nebraska
3
1
3
7
Nevada
0
New Hampshire
1
4
11
20
17
53
New Jersey
8
7
3
11
29
New Mexico
1
1
New York
1
4
2
8
21
28
44
108
North Carolina
2
2
North Dakota
0
Ohio
2
1
1
4
Oklahoma
0
Oregon
1
1
1
2
2
3
10
Pennsylvania
1
1
2
5
9
Rhode Island
5
4
4
7
5
25
South Carolina
1
1
South Dakota
1
1
Tennessee
1
1
Texas
6
2
5
13
Utah
2
2
(continued)
6
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TABLE 1 (continued)
State
1981
1982
1983
1984
1985
1986
1987
1988
Total
Vermont
1
2
5
3
2
13
Virginia
1
3
7
14
25
Washington
3
4
3
8
12
12
12
54
West Virginia
1
1
2
Wisconsin
2
6
9
9
7
33
Wyoming
0
Total by year
2
7
31
93
174
271
297
458
1333
Total States
1
5
7
17
25
27
29
29
43
a Source: Dana Duxbury & Associates, January 1989.
7
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oo
N. Dakota
Wyoming
Nevada
Oklahoma
iss
issippi
Georgia
STATES IN WHICH HOUSEHOLD HAZARDOUS
WASTE COLLECTION PROGRAMS HAVE BEEN HELD
1981-1988
Figure 1. States with HHW collection programs.
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and dispose of—to the management of hazardous waste. The EPA, which has
been focusing on the waste reduction step, is currently in the process of
developing a Pollution Prevention Policy Statement that would apply to
hazardous waste generators, including SQGs. The newly established Pollution
Prevention Office addresses the prevention of pollution through programs that
include grants for State waste minimization efforts.
3.2.2 State/Regional Policy
The policy of individual States is to provide both regulatory and
nonregulatory programs directed at SQGs. The States' regulatory policy is to
implement the requirements of RCRA. Most States have been delegated
authority to implement their own regulations in place of the Federal haz-
ardous waste regulations. The States must regulate SQGs at least as strin-
gently as RCRA, and many States regulate SQGs more stringently than Federal
law requires. Several States also have their own Superfund programs, which
can hold SQGs responsible for the cleanup of hazardous waste sites and
spills.
Florida has provided the opportunity for its regulated SQGs to parti-
cipate with HHW generators in its Amnesty Days Program. The Amnesty Days
Program allowed for one drum of free disposal and four drums at a rate 25
percent lower than the commercial rate for SQGs. By April 1987, 15 percent
of the 10,600 Amnesty Day Program participants were SQGs (University of
California at Davis 1987, p. 66). According to Florida's HHW Program
Manager, the Florida program may discontinue allowing SQGs to bring their
hazardous waste to collection sites because State law now prohibits SQGs from
transporting their own waste.
A nonregulatory hazardous waste policy of the States is to promote the
reduction of hazardous waste, including that generated by SQGs. In 1985, the
National Roundtable of State Waste Reduction Programs was organized to
promote the development of State programs and to exchange technical and
general information on waste reduction. The Roundtable, which meets bi-
annually, is composed of governmental, university, and public interest groups
representing 42 States.
According to a University of California at Davis study (1987), most of
the SQG education programs run by the States surveyed are funded by EPA
grants. Most of the States surveyed stressed the importance of separating
the information and assistance programs for SQGs from the State's enforcement
program. Many staff people believe that SQGs worried about enforcement
actions following inquiries for assistance would not seek help (University of
California at Davis 1987).
3.2.3 Local Community and Policy
Local governments and community organizations have undertaken efforts to
promote regulatory compliance and improved waste management. For example, by
July 1989, a nonprofit group in California, the Local Government Commission,
Inc., will have assisted more than 30 communities by providing hazardous
waste management and reduction assistance to generators (often including
9
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SQGs). To date, however, no coordinated official policy, legislative frame-
work, or management plan has been applied at the local level to address SQGs.
The U.S. Conference of Mayors has been involved in environmental issues, but
it has not yet focused attention on SQGs.
3.3 GENERATORS OF HHW
3.3.1 National Policy
By definition, waste generated by households is unconditionally exempt
from Federal hazardous waste management regulations promulgated under RCRA
Subtitle C. This exemption also applies to HHW collected in large quantities,
such as during an HHW collection program. When HHW is mixed with any quantity
of regulated hazardous waste, however, the resulting mixture is subject to
regulation under RCRA. Although HHW is exempt from the hazardous waste
management regulations of RCRA Subtitle C, the EPA recommends that sponsors
of HHW collection programs manage the collected HHW as hazardous waste.
The EPA has developed a list of broad categories of household wastes
that would be regulated as hazardous if they were generated in larger quan-
tities. These categories are based on the RCRA definition of hazardous waste
as those solid wastes that are listed as hazardous waste in the regulations
or demonstrate characteristics of a hazardous waste (i.e., ignitability,
corrosivity, reactivity, and extraction procedure toxicity).
The categories of common hazardous household products included in EPA's
list are as follows:
° Household cleaners
° Automotive products
0 Home maintenance and improvement products
0 Lawn and garden products
° Miscellaneous products, such as photo processing chemicals, bat-
teries, pool chemicals, and personal care products
As indicated earlier, although HHW is exempt from RCRA Subtitle C
requirements, HHW generators (municipalities) are not relieved of liability
under CERCLA and SARA. As defined by SARA, retroactive, strict, joint-
and-several liability can be imposed on the generators of hazardous waste.
Therefore, if hazardous waste is released to the environment from a municipal
solid waste landfill, municipalities that sent HHW to the landfill could be
held liable for part or all of the cleanup costs. This potential liability
exists whether or not any negligence was involved and whether or not applic-
able regulations governing hazardous waste management were less stringent at
the time of disposal than they are currently.
3.3.2 State/Regional Policy
States that apply hazardous waste regulations or formal guidelines to
HWW management have promulgated strict definitions of HHW. The following are
examples:
10
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° In Iowa the definition in Chapter 455F of the Iowa Code reads as
follows: "Household hazardous material means any product used for
residential purposes and designated by rule of the Department of
Natural Resources and may include hazardous substances, as defined,
and hazardous waste, as defined, and shall include but is not
limited to motor oil, motor oil filters, gasoline and diesel
additives, degreasers, waxes, polishes, solvents, paints, with the
exception of latex-based lacquers, thinners, caustic household
cleaners, spot or stain removers with petroleum base or petroleum
based fertilizers." The Iowa definition excludes laundry deter-
gents or soaps, dishwashing compounds, chlorine bleach, personal
care products and soaps, cosmetics, and medications.
0 According to the Washington State definition, household hazardous
substance means any liquid, solid, contained gas, or sludge (in-
cluding any material, substance or product, commodity or waste,
used or generated in the household, regardless of quantity) that
exhibits any of the characteristics or criteria of dangerous waste
as set forth in Chapter 173-303 of the Washington Annotated Code.
Such substances become moderate risk waste when discarded (Planning
Guidelines for Local Hazardous Waste Plans, RCW 70.105).
3.3.3 Local/Community Policy
Several organizations have attempted to define HHW by listing items
considered hazardous. At EPA1s Second National Conference on HHWM (held in
San Diego, California, November 2-4, 1987), Allen Maples of the EPA noted
that efforts are most commonly undertaken at the local level when community
groups and organizations decide they want to organize a collection program.
Maples said that these lists vary widely. The major categories assembled
are often, but not always, similar to EPA or State definitions.
3.4 WASTE AND WASTE GENERATORS
3.4.1 National Policy
As previously noted, the EPA promulgated regulations under RCRA that
define regulated hazardous wastes as solid wastes that are listed as haz-
ardous in the regulations or that demonstrate characteristics of a hazardous
waste.
It was also previously noted that hazardous substances subject to
regulation under CERCLA include those substances of specified reportable
quantities that are listed in the regulations and those wastes that are
regulated by RCRA. The Acts that regulate hazardous substances as they
pertain to waste site cleanup, emergency response, and the provision of
information to communities (community right-to-know information) are CERCLA
and SARA.
Small-quantity hazardous waste generators (SQGs) are regulated dif-
ferently from large-quantity generators (LQGs) and conditionally exempt
11
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generators. The SQGs are defined according to the amount and type of haz-
ardous waste they generate (see Figure 2).
As defined by RCRA, a hazardous waste generator is a SQG if it meets the
following requirements:
0 It generates more than 100 kg/month and less than 1000 kg/month.
° It generates no more than 1 kg/month of acutely hazardous waste.
0 The generator ships hazardous waste offsite within 180 days after
more than 1000 kg has accumulated.
° It accumulates no more than 6000 kg of hazardous waste at any one
time.
3.4.2 State/Regional Policy
Individual States may receive authorization under RCRA to regulate waste
generators more stringently than the Federal law requires. Therefore, the
wastes and the generators that are addressed by a State's SQG policy may vary
from State to State, depending on State definitions of a hazardous waste and
of an SQG and on priorities set by the State.
For example, waste oil is defined as a hazardous waste in eight States
and as a special waste in six States. Although a special waste is not
regulated as stringently as hazardous waste, it may be subjected to require-
ments such as permitting, burying restrictions, and disposal restrictions
(e.g., a landfill ban in the State of Minnesota). The SQG programs initiated
at the State level address a wide variety of wastes and generators based on
the concerns of residents, policymakers, and program administrators in a
given region.
3.4.3 Local/Community Policy
Cities and towns have directed their attention to a wide range of wastes
and generators. Because of the absence of official policy, legislative
framework, or management plans at the local level, the SQG wastes and gener-
ators that receive attention vary according to local concerns and priorities.
3.5 INFORMATION ACTIVITIES (HHW)
3.5.1 National Activities
Information activities are sponsored by the EPA. In November 1988, EPA
provided funding and support for its Third Annual National Conference on
Household Hazardous Waste Management, which was held in Boston. At this
conference, approximately 70 experts from the United States, Canada, and
Europe delivered presentations addressing topics concerning the definition,
regulation, liability, collection, management, and disposal of HHW. Several
conference speakers and moderators were provided by the EPA.
12
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KEY:
= I barrel = about 2(X) kilograms of hazardous waste
which is about 55 gallons
Generators of No More
Than 100 kg/mo
If you generate no more
than 100 kilograms (about 220
pounds or 25 gallons) of hazard-
ous waste and no more than 1 kg
(about 2 pounds) of acutely
hazardous waste in any calendar
month, you are a conditionally-
exempt small quantity generator
and the federal hazardous waste
laws require you to:
^ Identify all hazardous waste
you generate.
p- Send this waste to a hazard-
ous waste facility, or a
landfill or other facility
approved by the state for
industrial or municipal
wastes.
Never accumulate more
than 1000 kg of hazardous
waste on your property. (If
you do, you become subject
to all the requirements
applicable to 100-l(XK) kg/
nio generators explained in
this handbook.)
100-1000 kg/mo
Generators
If you generate more than
100 and less than 10(H) kg (be-
tween 220 and 2,200 pounds or
about 25 to under 300 gallons) of
hazardous waste and no more
than 1 kg of acutely hazardous
waste in any month, you are a
l(X)-HKK) kg/mo generator and
the federal hazardous waste laws
require you to:
Comply with the 1986 rules
for managing hazardous
waste, including the
accumulation, treatment,
storage, and disposal
requirements described in
(his handbook.
o
Generators of 1000 kg/mo
or More
If you generate 1000 kg
(about 2,200 pounds or 300 gal-
lons) or more of hazardous
waste, or more than 1 kg of
acutely hazardous waste in any
month, you are a generator of
1000 kg/mo or more and the fed-
eral hazardous waste laws
require you to:
Comply with all applicable
hazardous waste manage-
ment rules.
o
Figure 2. Categories of hazardous waste generators.
13
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The EPA is considering producing a newsletter targeted to help com-
munities seeking information about HHW collection and management. The
newsletter, which will be published quarterly beginning in 1989, is expected
to be mailed to approximately 4000 people.
Individuals concerned about HHW can also contact the RCRA Hotline
to obtain a 26-page bibliography of HHW literature or to obtain answers to
specific questions.
One informational activity required by the Federal Government is product
labeling. Federal law requires some consumer products to be labeled. The
Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) requires infor-
mative and accurate labeling of pesticide products. A provision addressing
home pesticides requires labels that contain disposal information recom-
mending that consumers wrap waste pesticides in newspaper and put them in the
rubbish.
The EPA provides information indirectly by providing grants to indivi-
dual States. States may receive Federal grants that can be applied toward
the implementation of State HHW programs.
A nongovernmental organization, The Household Products Disposal Council,
was set up by the Chemical Specialties Manufacturers Association (CSMA), a
national industry association. The Council set up an information and refer-
ral service for community organizers, groups, and waste managers to provide
information to concerned consumers. Guidelines have been offered to com-
munities that briefly explain how to design a community disposal program. A
manual containing these guidelines was sent to community leaders and
organizers and to State officials. A pamphlet was also prepared for distri-
bution by communities and by a Corporate Distribution Program. This pamphlet
offers "dos and don'ts" for disposing of household consumer products.
3.5.2 State/Regional Activities
State information activities include providing a "hotline"/referral
service, providing speakers for workshops and conferences, distributing
informational materials, promulgating shelf-labeling requirements for retail
stores, and responding to phone inquiries.
Several States have made "hotlines" available to receive HHW questions.
Florida, California, Minnesota, and Washington have provided statewide,
toll-free hotlines for receiving questions related to HHW and other hazardous
wastes.
The Minnesota Pollution Control Agency (MPCA) provides such a hotline
service. The MPCA referral/advice line instructs callers on how to manage
or dispose of hazardous household products. Most callers (78.3 percent) are
told how their products (e.g., solvents, paints, and gasoline) can be reused
or recycled. Only 17.5 percent of the callers are instructed to hold mate-
rials (such as pesticides) for an HHW collection day.
14
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Iowa initiated a mandatory shelf-labeling program for hazardous house-
hold products sold in retail stores. Regulated retailers must affix a shelf
label sticker adjacent to the price information, designating the items that
are defined as hazardous household products by the State of Iowa. Infor-
mational posters also must be displayed close to the shelves where products
are for sale. The posters explain the significance of the shelf label and
the relationship of improper disposal of household hazardous materials to
ground-water contamination, and they direct consumers to additional infor-
mational brochures available at the establishment. The brochures provide
more detail about the hazards, disposal options, and some alternative uses.
3.5.3. Local/Community Activities
Many cities, towns, and local institutions have sponsored educational
activities concerning HHW. Efforts include developing curricula for schools,
advertising HHW collection programs, and offering telephone assistance
"hotlines."
The League of Women Voters in San Bernardino County, California,
developed a technical packet for teachers and a 10-minute video appropriate
for 3rd through 6th graders. The video highlights dangers of using household
chemicals and the benefits of properly disposing of hazardous household
products. The educational efforts are designed for students as well as their
parents. At EPA1s Third National Conference on HHWM (held in Boston,
November 2-4, 1988), Joan Dotson of the League of Women Voters stated that it
is hoped that students will share the information from the video with their
parents, and will encourage them to use and dispose of hazardous household
products safely.
The Southwest Missouri State University HHW Project sponsors an educa-
tional program that is designed to supplement State efforts. The intent of
this program is to help people identify risks, make informed decisions, and
use, store, and dispose of products safely. The program also promotes waste
exchange and recycling, and a local Telephone Information Request line is
operated to answer citizens' questions and concerns.
3.6 INFORMATION ACTIVITIES (SQGS)
3.6.1 National Informational Activtities for SQGs
The U.S. Environmental Protection Agency sponsored a nonregulatory
program to assist small-quantity generators with technical and regulatory
questions. The program, the Governmental Refuse Collection and Disposal
Association (GRCDA) Small Quantity Hazardous Waste Generator Information and
Assistance Clearinghouse, handled approximately 400 assistance cases between
April 1, 1988, and December 1, 1988 (the Clearinghouse in Silver Spring,
Maryland, can be contacted by calling 800-458-5886.)
The services offered by the Clearinghouse include:
15
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0 Technical help regarding waste identification, minimization,
inventory, treatment, and disposal.
° Guidance regarding compliance with State and Federal regulations.
° Information about local service companies, public assistance
programs, current literature, and waste exchanges.
The Clearinghouse also published a free quarterly newsletter as an
information exchange vehicle for regulatory and nonregulatory Federal, State,
and local agencies; technical assistance programs; trade associations;
research facilities; and waste exchanges in reference to SQG hazardous waste
minimization issues. Chris Voell of the Government Refuse Collection and
Disposal Association (GRCDA) reported that the Clearinghouse recently lost
its EPA funding, but it is continuing to provide limited services and may
seek new funding in the future.
The EPA also awarded grants under the authority of RCRA Section 8001
(called "8001 grants"), which States could use by design and administer SQG
and other waste reduction programs. In fiscal year 1986, 51 grants were
awarded for SQG education/outreach programs. The funds awarded totaled
$3,241,957, and the grants awarded ranged from $3900 to $259,980. This
program has since been discontinued.
The EPA's new Pollution Prevention Office is currently funding States
with RCRA Integrated Training and Technical Assistance (RITTA) grants for
programs that promote hazardous waste minimization. Most of the programs
focus on SQGs. Fourteen States were awarded grants totaling $3.6 million
(approximately $320,000 per State). Four states received a grant for a
jointly sponsored program. The grants are intended for use over a 3-year
period. In addition, the Pollution Prevention Office has also accepted
applications for an additional $3 million of grant money for State training
and waste minimization programs and will be accepting applications for
another $4 mill ion.
The EPA runs two phone lines, the Small Business Ombudsman and the RCRA
hotline, which SQGs can use to obtain information and assistance regarding
hazardous waste management.
An EPA assistance program that is now in the planning stages, but may
begin providing some services by the end of 1989, will be provided in the
form of a waste minimization information clearinghouse. An EPA economist
with the Waste Minimization Branch reported that the program will emphasize
assistance for small- and medium-sized hazardous waste generators, and it is
expected to provide services that include an electronic bulletin board, a
telephone hotline, information about national and State hazardous waste
activities, case studies, bibliographies, and other publications.
3.6.2 State/Regional Informational Activities for SQGs
States have provided a variety of information and assistance programs
that are available to SQGs. The National Roundtable of State Waste Reduction
16
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Programs, organized in 1985, promotes waste reduction programs, including
programs that target SQGs. Between 1985 and June 1988, Roundtable members
have helped establish and expand waste reduction programs in 35 States.
Programs include compliance assistance, general information, clearinghouses,
general and onsite technical assistance, matching grants, research grants,
loans, tax incentives, workshops/training, public education, and waste
exchanges. The proposed fiscal year 1989 budget for these types of programs
is $281,320.
The GRCDA notes at least 19 State agencies that sponsor programs geared
specifically for SQGs. Arkansas and Massachusetts are two examples:
° The Arkansas Department of Pollution Control and Ecology's Haz-
ardous Waste Division has instituted an educational program that
provides assistance to SQGs. This program offers a variety of
technical assistance services, including workshops.
° The Massachusetts Department of Environmental Management provides
both educational and technical assistance programs for SQGs.
Educational efforts have included workshops that provided infor-
mation to schools, hospitals, and commercial laboratories regarding
hazardous waste regulatory compliance and waste reduction. Tech-
nical assistance efforts have targeted electroplaters and auto body
shops for assistance in reducing and safely managing hazardous
waste.
3.6.3 Local/Community Informational Activities for SQGs
Local institutions and organizations, such as municipal governments,
universities, and research organizations, provide nonregulatory assistance to
SQGs. The GRCDA reports that at least 41 programs have been sponsored.
Examples include programs sponsored by the Solid Waste Services Department of
Anchorage in Alaska, the Erie County Environmental Compliance Services in New
York State, the Pennsylvania Environmental Research Foundation Center for
Hazardous Materials Research, and the Clemson University Environmental
Systems Engineering Program in South Carolina.
3.7 HHW POLICY BASIS—COMPULSORY OR VOLUNTARY?
3.7.1 National HHW Policy Bases
Voluntary—
The national policy for addressing HHW management is essentially based
on voluntary activities because, as was previously noted, HHW is not federal-
ly regulated under RCRA Subtitle C. Also as noted earlier, municipalities
are subject to HHW liability under CERCLA and SARA. In 1987, roughly 165
municipal solid waste landfills were included in the 850 National Priorities
List (NPL) of sites requiring cleanup under Superfund. The municipalities
that send waste, including HHW, to these landfills are potentially liable for
the cleanup costs. Because of this potential liability, municipalities have
an incentive for voluntarily undertaking HHW reduction, reuse, and management
17
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activities in an effort to eliminate the potential long-term liability of
landfill cleanup under CERCLA.
Compulsory--
A previously noted regulatory provision addressing HHW is the labeling
requirement of FIFRA. This Act requires informative and accurate labeling of
pesticide products. A provision addressing home pesticides requires the
label to contain disposal information recommending that consumers wrap waste
pesticides in newspaper and put them in the rubbish.
3.7.2 State/HHW Policy Bases
Voluntary--
Numerous States rely heavily on voluntary activities to address HHW
management. Collection programs are frequently sponsored at the county and
local level without State involvement. Local program sponsors include public
works departments, conservation commissions, health boards, Leagues of Women
Voters, and industry, to name a few.
Some States support these efforts by providing funding, information, and
technical assistance. For example, Connecticut, New Hampshire, Wisconsin,
and Massachusetts provide matching grants to encourage HHW collection pro-
grams. (See the section on State/regional information activities for more
detail on State support for voluntary programs.)
Compulsory--
As was noted earlier, most States do not regulate HHW as hazardous;
therefore, they rely heavily on voluntary activities. Compulsory programs
include State-required labeling, planning, mandatory collection, and
regulations pertaining to the operation of permanent and temporary collec-
tions. Appendix B contains a table prepared by Dana Duxbury & Associates,
which highlights State programs, including compulsory programs. Examples of
such programs are presented here:
° Iowa requires permits and mandatory shelf labeling by retailers
that sell hazardous household products. The permits require
retailers to affix a shelf-label sticker adjacent to the price
information, designating that the items are hazardous household
products. Informational posters are displayed close to the shelves
where products are for sale, and brochures are made available to
provide more detail about hazards, disposal options, and some
product alternatives.
0 Connecticut law requires the establishment of an HHW program that
includes guidelines, mandates a report to the legislature, and
requires communities to use licensed hazardous waste contractors.
Contractors must assume the legal status of the hazardous waste
generator. Connecticut's guidelines (for which regulations will be
promulgated) outline the procedures for holding collections and for
obtaining State matching grants of up to 50 percent of the cost.
The State must approve all final plans.
18
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0 The Florida Amnesty Days Program required the State to offer an HHW
collection day in each county. According to the State HHW Program
Manager, it is hoped that counties will get into the habit of
running HHW collections and support a network of locally operated
and funded ongoing programs.
° California's Tanner Act (A.B. 2948) requires county level planning
as part of a mandatory statewide planning effort. One of the eight
elements mandated for the comprehensive plans is consideration of
the needs of small businesses and households. The State is also
required to assist local governments and to provide public infor-
mation. The California Waste Management Board is charged with the
responsibility of developing model operation plans for community
collection programs, and proper procedures for handling, storage,
transport, and training. The Board is also charged with estab-
lishing guidelines on the types of household substances to be
disposed of as HHW.
0 The Minnesota Pollution Control Agency (MPCA) is required by State
law to manage HHW by establishing collection sites and providing
information, education, and technical assistance. The central
office of MPCA is also required to manage a hotline and administer
grants for 10 to 20 collections.
° Under Washington State law, local governments are responsible for
preparing plans for the management of HHW generated within their
local boundaries. Local governments must manage HHW as hazardous
materials.
0 In New Hampshire, some guidelines and minimum requirements are
issued for those sponsors that are awarded grants for HHW col-
lection programs. These include conducting significant public
education campaigns.
3.7.3 Local/Community HHW Policy Bases
Voluntary--
Much of the local activity in the area of HHW results from voluntary
programs. Counties, cities and towns, industry (including waste management
companies), and environmental advocacy groups support or sponsor programs
that educate consumers about HHW, provide consumers with HHW collection days,
ana provide or promote dissemination of information regarding substitution of
substances. The following are a few examples:
° County Program. San Bernardino County, California, sited six
ongoing (operating at least once per month) hazardous waste col-
lection facilities. The county also cosponsored a program with the
League of Women Voters, through which a school curriculum was
developed to teach 3rd through 6th graders about HHW.
19
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c City/Town Program. The city of Somerville, Massachusetts,
sponsored a HHW collection day in September 1988. Funds for the
program were raised from local businesses. Public education
associated with the program included developing a booklet on solid
waste and HHW, which was distributed to every resident; placing an
exhibit in a local library, hospital, and mall; and arranging for a
speaker to discuss HHW with students in local elementary schools.
0 Industry Collection Programs. U.S. companies that have sponsored
HHW collection programs include Dow Chemical, Monsanto, Sperry
Rand, Browning-Ferris Industries, Chem-Waste Management, Chem
Processors, GSX, and Hercules. Dow Chemical has sponsored programs
in communities where Dow has a large manufacturing presence,
including locations in Michigan, Louisiana, and Texas.
° Industry Substitution and Reformulation Efforts. U.S. companies
have undertaken product reformulation efforts. For example, the
Polaroid Corporation has worked to phase out mercury from its
batteries, and the paint industry has reduced the use of mercury as
a preservative in latex paint.
° Environmental Advocacy Group. Clean Water Action Project, a
national environmental group, prepared a pamphlet about HHW and
distributed copies to its members. The pamphlet highlights sub-
stitutes to common hazardous household products
Compulsory--
No local programs could be identified that require HHW management
activities.
3.8 SQG POLICY BASIS—COMPULSORY OR VOLUNTARY?
3.8.1 National SQG Policy Bases
Voluntary--
The EPA relies in part on voluntary compliance because of its limited
resources for enforcing SQG compliance with national hazardous waste regula-
tions and policies through inspections (University of California, 1987, p.
52). Rising hazardous waste disposal costs and the liability associated with
improper hazardous waste management serve as incentives to SQGs for volun-
tarily reducing, reusing, and properly managing hazardous waste. The EPA
information clearinghouses, hotlines, and State grants also help to promote
voluntary compliance efforts.
Compulsory--
The University of California at Davis (1987) reports that some compo-
nents of EPA's strategy regarding SQGs focus on compliance and enforcement
activities. The EPA intends to apply the same compliance monitoring methods
for SQGs as those used for large-quantity generators. Under RCRA, EPA has
the authority to inspect, fine, and close down institutions that violate the
20
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Federal hazardous waste regulations, and the Agency can hold generators
liable under CERCLA for damage to the environment or public health resulting
from hazardous waste disposal and releases to the environment.
3.8.2 State/Regional SQG Policy Bases
Voluntary-
Like the Federal government, States recognize the limited resources
available to ensure compulsory compliance with hazardous waste requirements
that apply to SQGs. Therefore, States have responded with voluntary out-
reach, education, and assistance programs.
Compulsory-
States that have been delegated authority to administer their own RCRA
programs instead of the Federal program, conduct inspections, levy fines, and
can close down institutions that fail to comply with hazardous waste manage-
ment requirements. State agencies often target an SQG industry with an
enforcement effort combined with an education/assistance program.
For example, the Massachussets Department of Environmental Quality Engi-
neering (DEWE), the State's environmental regulatory agency, increased the
number of inspections of auto body shops and laboratories while the Department
of Environmental Management (DEM), the State's environmental planning agency,
was providing voluntary education and assistance programs. These programs
were coordinated to make the regulated community aware of a problem and then
to promote the voluntary involvement of the targeted group in a program
designed to address the problem.
Many States also have their own Superfund programs that permit them to
hold hazardous waste generators, including SQGs, liable for the cleanup of
hazardous waste sites and spills.
3.8.3 Local/Community SQG Policy Bases
Voluntary-
Counties, cities, and towns sponsor many voluntary programs that promote
best management practices and voluntary compliance with hazardous waste
management requirements.
Compulsory—
In cases for which they have legal standing, localities can take action
to enforce Federal and State laws, and when they have local jurisdiction,
they can enforce the laws that apply to SQGs.
3.9 HWW POLICY—ACTIVE, "FRONT-END", OR PASSIVE "END-OF-THE-PIPE MEASURES"?
3.9.1 National Policy
The formal policy of the national government with regard to hazardous
waste is based on promoting front-end measures, as indicated by the following
declaration in the 1984 HSWA: "The Congress declares it to be the national
21
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policy of the United States that, wherever feasible, the generation of
hazardous waste is to be reduced or eliminated as expeditiously as possible.
Waste nevertheless generated should be treated, stored, or disposed of so as
to minimize the present and future threat to human health and the environ-
ment." The EPA recommends that hazardous waste generators follow a waste
management hierarchy of waste reduction, reuse, recycling, treatment, and
disposal. Emphasis is on the waste reduction step of the hierarchy. The
EPA recently demonstrated this commitment by establishing its Pollution
Prevention Office.
The national government's front-end, hazardous-waste-prevention approach
is carried over into the area of HHW. Howard Levenson of the U.S. Congress
Office of Technology Assessment (OTA) stated at the Third National Conference
on HHWM that whereas HHW collections are important for addressing waste
management needs in the short run, hazardous-waste prevention is the key to
addressing concerns in the long run. He said that OTA will study volume and
toxicity reduction as means of addressing HHW issues.
The EPA also supports front-end HHW management efforts. Bruce Weddle,
Director of EPA's Municipal Solid Waste Program for the Office of Solid
Waste, stated at EPA's Third National Conference on HHWM that EPA will
continue to address HHW issues through activities that include promoting
voluntary efforts by industry to "design for disposal." At the same
conference, Sylvia Lowrance, Director of EPA's Office of Solid Waste, stated
that source reduction can be achieved by educating the public, providing
citizens with information, and assisting in technology transfer.
The EPA has demonstrated its support for front-end solutions by programs
such as the 8001 Grants Program and the RITTA Grants Program, which have
provided funds for State hazardous waste minimization programs. The EPA also
sponsors an annual national HHWM Conference that addresses HHW from both
front-end and end-of-pipe perspectives. This conferences has placed in-
creasing emphasis on front-end approaches. The Third National HHWM Con-
ference, held in Massachusetts in 1988, placed a great deal of emphasis on
front-end approaches, including topics such as comprehensive planning,
product reformulation, and waste prevention.
National policymakers also recognize the importance of end-of-pipe
measures for safe, environmentally sound collection and disposal of HHW that
has accumulated in homes. Both EPA and OTA support HHW collection programs.
Howard Levenson of OTA remarked at EPA's Third National HHWM Conference that
HHW collections are important for addressing short-run waste management
needs, and that reducing the amount of HHW in the municipal waste stream
reduces potential liability for municipalities. According to Joseph Carra,
former Director of EPA's Waste Management Division of the Office of Solids
Waste in 1987, the EPA enthusiastically endorses HHW collection programs and
sees its role as providing technical assistance to State and local govern-
ments. The EPA has assigned a staff person the responsibility of overseeing
EPA activities on HHW, and it sponsors an annual national conference that
provides information and support to HHW collection organizers.
22
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3.9.2 State/Regional Policy
In the early 1980s, when the first HHW collection days were held, States
focused attention on removing and disposing of HHW that had been accumulating
for years in consumers' homes. Because of the growing national and State
attention given to pollution prevention and the success of collection pro-
grams in the removal of hazardous products from homes, the focus is shifting
somewhat from HHW collection to source reduction and recycling. Massachu-
setts' pending source-reduction legislation, California's Tanner Act requir-
ing comprehensive hazardous materials planning, Iowa's mandatory shelf-label-
ing law, and Minnesota's telephone hotline encouraging product reuse are
examples of how States are placing emphasis on front-end approaches to
managing hazardous waste, including HHW issues.
In addition to the front-end measures, States continue to support
end-of-pipe measures designed to ensure safe, environmentally sound disposal
of HHW. One reason some States are supporting HHW collection is to help
residents recognize that consumers share responsibility with industry for
ensuring the proper disposal of hazardous waste. It is hoped that this
recognition will promote public cooperation in the accceptance of the siting
of a hazardous waste treatment, storage, and disposal facility in their
communities. This partially explains why States have helped fund many of
the more than 1300 HHW collections held in the United States since 1981.
3.9.3 Local/Community Policy
Local activities have included both front-end and end-of-pipe strategies
for addressing HHW. Front-end activities include public education efforts to
inform people about product substitutes and to encourage reduction in the use
of toxic substances and lobbying efforts for labeling ana source-reduction
legislation.
Communities also continue to sponsor end-of-pipe collection programs.
As shown in Figure 3, the number of collections have increased steadily since
1981. The number of permanently operating collection programs (i.e., open at
least once per month) has also grown. Dana Duxbury & Associates identified
27 permanent HHW collection programs operating or expected to operate in
seven states by early 1989. This is nearly double the number in 1987 (see
Appendix C, Tables C-l and C-2).
Collections of HHW are highly visible, politically popular events
considered important for protection of the health and safety of residents and
sanitation workers, for protection of the environment, for minimization of
liability due to the disposal of hazardous wastes in municipal landfills, and
for minimization of damage to publicly owned treatment works (POTWs). For
this reason, even though many communities have looked at front-end strategies
for addressing HHW management, end-of-pipe collection events have continued
to grow in number.
23
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500
Source: Dana Duxbury & Associates January 1989
458
CO 400
300
= 200
174
271
ipfciiii
ip «S?i:^SK
mm
° 100
MMMNi
1981
1982
1983
1984 1985
Year
1986
1987
1988
Figure 3. Number of collection programs each year since 1981.
-------
3.10 FUTURE PERSPECTIVES (HHW AND SQGS)
3.10.1 National Perspective
The national policy toward SQGs and HHW is expected to continue to
emphasize pollution prevention and to promote EPA's waste hierarchy of reduc-
tion, reuse, recycling treatment, and disposal. At a 1987 EPA Waste Reduc-
tion Conference in Woods Hole, Massachusetts, John Skinner, Director of the
EPA Office of Research and Development (ORD), remarked that Congress has
established a national policy making it clear that waste minimization and
waste reduction are the highest priorities of waste management in RCRA. The
EPA's Pollution Prevention Office was set to promote pollution prevention,
and programs such as the RITTA grants program will continue to promote waste
prevention and the reduction in both the volume and toxicity of wastes.
Consumer products, such as batteries that contain lead or cadmium, are
expected to receive particular attention. The EPA and OTA are studying
sources of lead and cadmium in the municipal solid waste stream and means for
reducing or eliminating the generation of these wastes.
During the next few years, EPA is likely to continue its role as a
catalyst in addressing SQG and HHW issues by providing technical assistance
and funding to individual States. Program implementation is now and is
likely to continue to be reserved for State and local agencies and organiza-
tions.
3.10.2 State/Regional Perspective
State agencies have taken a variety of approaches to promoting the
reduction and improved management of SQG hazardous waste and HHW. States
also have been promoting the EPA hazardous waste hierarchy through public
education and other efforts. Future trends may include labeling laws that
focus on hazardous consumer products, deposit systems for items such as
batteries, and tax incentives and legislation that promote a reduction in the
use of toxic materials.
States can be expected to begin applying more comprehensive approaches
to waste management and looking for permanent solutions. California's Tanner
Act already requires counties to incorporate SQG and HHW management planning
in their hazardous waste management plans. Some States are looking at ways
to incorporate SQGs in HHW collection programs. States are also recognizing
the importance of providing ongoing outlets for HHW collection. The number
of permanently operating (at least once per month) collection programs has
more than doubled during the past year; the total is now 27 programs. Rhode
Island is currently exploring the possibility of sponsoring a permanent HHW
collection facility. Massachusetts and other States are developing guide-
lines for the operation of such facilities.
3.10.3 Local/Community Perspective
Cities and towns are recognizing that, although one-day HHW collection
events are useful as a public education tool, permanent and more cost-effective
25
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solutions are needed. A 1-day collection can cost $100,000 or more, and
participation rates are likely to represent no more than 1 percent of the
target population. During these events residents often have to wait in line
for more than an hour to drop off their HHW. Also, carloads are turned away
when the sponsors have met their budget limit or when it is necessary to
allow the waste management firm to leave the site before dark.
Whereas 1-day collections are often considered a useful public education
tool, they also have been known to have negative ramifications. A study
conducted by the Minnesota Pollution Control Agency indicates that the amount
of HHW disposed in the regular trash increased after an HHW collection. This
phenomenon is believed to have occurred because people learned that many
household products are hazardous and were unwilling to store them in their
homes while waiting for another HHW collection day.
These factors help to explain why many communities are working to
institutionalize collections and to set up permanent HHW collection facilities.
At the same time, communities will be promoting waste-reduction and recycling
initiatives designed to reduce the need for HHW collections. Collection
sponsors like to say that their ultimate goal is to put themselves out of
business by reducing and eliminating hazardous waste generated in the home.
With regard to SQGs, communities are expected to continue to sponsor
programs to assist small local businesses in reducing and safely managing
HHW. Many communities are also beginning to explore the feasibility of
incorporating SQGs into their HHW programs. Florida has already provided
Amnesty Days for SQGs to dispose of their waste, and similar programs are
expected in the future.
26
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SECTION 4
TECHNICAL AND ORGANIZATIONAL ASPECTS OF HOUSEHOLD AND
SQG WASTE MANAGEMENT
4.1 SUPPORTING INSTITUTIONS, ORGANIZATIONS, AND AUTHORITIES
The following is a breakdown of institutions, organizations, and
authorities involved in household hazardous waste management:
National: EPA, OTA, and individual members of Congress
State: Environmental enforcement agencies (State EPA's), environ-
mental planning agencies, water management agencies
Regional/Municipal/Local: Municipal environmental enforcement agencies,
conservation commissions, departments of public works, regional
environmental planning agencies, POTWs/sewer districts, fire
departments, local emergency response committees, departments of
public health
Private: Waste management companies, environmental organizations,
industry associations, individual industrial companies
4.2 PROMOTIONAL ACTIVITIES OR SUBSIDIES
No national or State activities have been identified that subsidize
clean technologies as they apply to HHW. Clean technologies promoted by EPA
RITTA grants, State technical assistance programs, and Federal and State laws
do, however, impose liability on hazardous waste generating activities.
Separate collection of HHW has been subsidized by both national and
State governments. Nineteen of the 50 States in the United States have
provided funding for separate HHW collections. Dana Duxbury & Associates
estimate that as many as one quarter of the more than 1300 collections have
received some level of funding. Some States have fully funded, designed, and
implemented pilot and continuing collection programs, whereas others have
provided only partial financial support. National and State funding sources
include EPA Regional Office cleanup grant money, State legislature appro-
priation monies (including matching grants), State hazardous waste Superfund
monies, State solid waste Superfund monies, and a permit fee for retail
stores (see Appendix B).
27
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Separate collection of HHW is also promoted by numerous nonsubsiciy
activities. State-sponsored activities include evaluations/reports; advisory
committee reports; education programs; legislation reducing liability as-
sociated with HHW collection; studies; and laws, regulations, and guidelines
that address HHW (see Appendix B).
According to Joseph Carra of EPA, the Agency supports separate HHW
collection; however it takes the position that collection programs must be
developed and initiated by State and local governments to fit the needs of
each community, with the EPA providing technical assistance to State and
local governments.
28
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SECTION 5
CASE STUDIES
5.1 CASE STUDY--AUTO BODY SHOPS
5.1.1 Source
Auto Body Shop Project, Boston, Massachusetts, June 1986 - June 1987.
Source and Project Sponsor: Massachusetts Department of Environmental
Management (DEM), Office of Safe Waste Management, 100 Cambridge Street,
Boston, Massachusetts, 02202. Contact: Michael S. Brown, Director, Office
of Safe Waste Management. Phone: (617)727-3260.
5.1.2 Industry Profile
Approximately 65,000 independent auto body shops and 25,000 new car
dealers have body repair shops in the United States. In the Commonwealth of
Massachusetts, approximately 2350 firms do body repair work or paint cars.
Auto body repair involves the use of mechanical and chemical techniques to
straighten, replace, and protect metal and plastic.
Hazardous wastes generated by auto body shops are likely to include
parts cleaners (e.g., mineral spirits), waste oil and grease, paint wastes,
rust removers, and antifreeze. Lacquer thinner is the major waste stream
generated by the industry.
The Massachusetts auto body industry consists of a large number of firms
dispersed throughout the State. The industry generates several waste streams.
Only a small percentage of shops probably do not generate any hazardous
waste. Most generate amounts that would qualify them as very small quantity
generators (VSQGs) of hazardous wastes or small quantity generators (SQGs);
i.e., they generate less than 1000 kilograms per month.
An informal DEM survey (not statistically valid) revealed information
about waste generation and management activities of the auto body industry in
Massachusetts (see Tables 2 and 3, respectively).
5.1.3 Project Scope
The Massachusetts Department of Environmental Management (DEM), a
nonregulatory environmental agency, proposed a five-part project consisting
of the following:
29
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TABLE 2. HAZARDOUS WASTE GENERATED AND REPORTED BY AUTO BODY SHOPS
Waste generated
Number
reporting
Percent
reporting
Waste streams (multiple answers
possible)
Solvents
Paints and filters
Waste oil
Quantities generated/respondent
(solvent and paint waste)
None
> and < kg
>5 and <100 kg
>100 ancf <1000 kg
>1000 kg
357
282
159
109
282
61
14
TOTAL 466
77
61
34
23
61
13
3
100
Quantities generated/respondent
(waste oil)
None
> and < kg
>5 and <100 kg
>100 ani <1000 kg
>1000 kg
307
49
35
64
11
TOTAL 466
66
11
8
14
2
101£
Total does not equal 100 because of rounding.
30
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TABLE 3. MANAGEMENT PRACTICES
Type of practice
Solvents
Paint/Filters
Waste
Oil
No.
%
No.
%
No.
%
Reuse
64
21
39
15
14
9
Recycle
20
7
8
3
7
4
Evaporation
46
15
11
4
Trash disposal
40
13
103
40
6
4
Ground disposal
3
1
1
<1
Licensed hauler
100
33
70
27
112
69
Storage
25
8
19
7
5
3
Incineration
6
2
6
2
18
11
TOTAL
304
100
257
98
162
100
3 Source: Massachusetts Department of Environmental Management, Office of
Safe Waste Management, Final Report, Auto Body Shop Project, June 1987.
31
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1) Defining the target population and key participants.
2) Surveying waste generation and management, particularly source
reduction opportunities.
3) Establishing collection programs, such as milk runs and transfer
facilities.
4) Conducting workshops and outreach programs.
5) Evaluating compliance and waste management changes.
Project goals were to determine the number of auto body shops in the
Commonwealth, the hazardous waste generation rates, and the level of initial
compliance with hazardous waste regulations and to achieve at least a 35
percent increase in compliance as measured by notifications of hazardous
waste activity, documentation of source reduction efforts, and the establish-
ment of ongoing collection methods tailored to SQGs.
The DEM proposed to enlist the help of trade associations, safe waste
management coalitions, transporters, and regulators to help identify auto
body shops in the Commonwealth, to evaluate industry processes and the
potential for feasible methods of reducing waste generation, to establish
"milk-run" type collection programs for interested generators, and to provide
generators with information on regulations, waste management methods, and
offsite treatment and disposal.
In conjunction with the State environmental regulatory agency, the
Department of Environmental Quality Engineering (DEQE), DEM was to evaluate
initial compliance among the targeted shops, to determine typical violations
of the regulations, and to analyze changes in compliance over the term of the
project. The final phase would be the preparation of a report evaluating the
project elements to determine how the successful components might be applied
to other States and where improvements are needed.
5.1.4 Identification of Needs
The primary compliance problems identified concerned the low rate at
which shops notified the State regarding waste generating activity, the
suspected high rates of illegal disposal, improper storage and marking, and
the lack of cost-effective disposal alternatives for the smallest generators.
The concerns of local and regional agencies focused on identifying SQGs,
getting businesses into the regulatory system, searching for cost-effective
alternatives for reducing or eliminating waste that may pollute ground water,
and identifying affordable disposal alternatives for local businesses. Auto
body shop owners cited access to information, applicability of hazardous
waste regulations to their shop situations, and the costs of proper manage-
ment and disposal as major concerns.
32
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5.1.5 Program Implementation/Results
The DEM structured an outreach and technical assistance program designed
to highlight the segments of the industry least likely to be in compliance
and most in need of assistance. According to the Director of DEM's Office of
Safe Waste Management, the cost of the program was estimated to be $80,000.
The program consisted of the following:
1) Identifying the needs of the targeted generators and coordinating
efforts with other agencies.
2) Conducting an initial mailing.
3} Offering technical assistance on source reduction and milk runs.
4) Conducting workshops throughout the Commonwealth.
5) Conducting a followup mailing.
Efforts were coordinated with the DEQE, which cooperated by conducting
additional inspections of auto body shops.
Initial Mailing—
An initial mailing was sent to 1870 auto body shops that had failed to
obtain an EPA Identification Number. The letter was designed to inform the
target population that DEM was working to help auto body shops meet their
hazardous waste responsibilities, that the number of shop inspections by the
DEQE would be increasing, and that workshops would be forthcoming. A survey
regarding hazardous waste management practices was included. At the outset
of the project, approximately 650 auto body shops had obtained EPA Identi-
fication Numbers. Within 1-1/2 years of the project implementation, more
than 1200 shops were registered and had an EPA Number, which represents a
substantial increase in the number of auto body shops now in the regulatory
system.
Technical Assistance Program--
Technical assistance efforts focused on potential waste minimization
activities, proper storage, and cost-effective off-site disposal. Technical
information was developed through literature reviews, product solicitation,
contacts with industry and suppliers, and discussions with body shops that
had attempted to revise their procedures. The DEM stressed the need for
adequate managerial attention in auto body shops to ensure that waste reduc-
tion and management programs were being properly addressed.
Among achievable waste minimization efforts was altering the work
processes to reduce solvent use and waste. The greatest gains could be made
at shops that cleaned their spray gun equipment by filling the gun cup with
solvent and spraying the liquid into the room air or a ventilation duct.
Other practices for which alternatives might be available to effect reduc-
tions included using gun wash tubs that were not closed systems, conducting
painting operations in an unorganized manner, and using low-quality solvents.
33
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Solvent distillation units costing between $2000 and $3000 were recom-
mended to some auto body shops as a means of recovering solvents. The DEM
concluded that these units were economically feasible for only the larger
firms. Each of several units the DEM identified could process approximately
5 gallons in an 8-hour period.
Identified hazardous waste storage problems included poor housekeeping,
lack of proper labeling, failure to protect against explosions and fires, and
lack of emergency equipment. The DEM developed a model storage approach for
the suggested use of shops. The approach included the following elements:
developing an enclosed, explosion-proof space; adhering to good housekeeping
procedures; and identifying a hazardous waste storage area that could be
enclosed, protected, and well marked. The DEM suggested a system for ground-
ing all drums and tanks. Storage space for hazardous waste could be indoors
or out; however, fire regulations encourage outdoor placement. Specially
constructed storage areas or the use of an ocean-going shipping container was
recommended as especially desirable. Generators were encouraged to use
safety containers with nonsparking funnels in paint rooms for satellite
accumulation, to post warning signs, and to improve tracking of waste from
generation to storage. Shops were advised to fence off storage areas, to
limit access, to cover drums, to provide an impervious surface for storage,
and to provide emergency equipment.
The DEM identified six contractors who expressed a willingness to
provide hazardous waste disposal services to auto body shops. Two "milk run"
services were identified. Milk runs involve scheduled transporter pickup of
single or limited waste streams from geographically concentrated generators.
Workshop Program-
me DEM sponsored nine auto body workshops iri Massachusetts and five
workshops for vocational schools with noncommercial body shops. Overall,
workshop attendance totaled approximately 310. Although each workshop agenda
was different, the typical approach was to have a DEM representative intro-
duce the project and discuss the general regulatory environment and methods
of improving waste management; to have an inspector from DEQE review the
regulations in more detail and describe the process of inspection; and to
have representatives from hazardous waste transporters and solvent still
manufacturers talk about their services and products. Questions and answers
were encouraged during each talk and at the end of the final presentation.
Handouts were provided.
5.1.6 Cone!usi ons/Recommmedati ons
Conclusions--
The auto body shop industry is composed of a large group of small
businesses, all of which have the potential to generate the same waste
streams, which vary only in quantity. Essentially, the same problems were
encountered by all firms, whether large or small: coping with a myriad of
regulations designed for large chemical production plants, reducing waste
generation where no feasible substitutes exist for raw materials used in the
body shop processes, and finding cost-effective offsite management alter-
natives.
34
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Recommendations--
The following actions are recommended to deal with the problems:
° Application of an enforcement-driven model to the program if
adequate resources can be made available. An inspection process
could include referral to a DEM assistance program. Project costs
would increase by at least $200,000, which is a serious barrier to
applying the enforcement-driven approach.
° Establishment of a research and development program targeted at
meeting SQG needs.
° Provision of increased management alternatives for the smallest
generators, such as collection stations for nonhousehold wastes.
0 Exploration of the possibility of requiring mandatory participation
in a milk run program. This would create a reliable market for
contractors and could result in lower costs for generators.
0 Establishment of greater coordination between the EPA and outreach
providers. At a minimum, EPA might want to consider building a
library of reports on SQG assistance projects and distribute an
annotated bibliography to agencies and interested individuals.
5.2 CASE STUDY—BATTERIES
5.2.1 Source
Household Battery Collection Program, New Hampshire/Vermont, Spring of
IS87. Source and Project Sponsor: New Hampshire/Vermont Solid Waste Pro-
ject, Room 336, Moody Building, Claremont, New Hampshire 03743. Contact:
Carl E. Hirth, Recycling Manager/Planner. Phone: (603)543-1201.
5.2.2 Industry Profile
In the United States, there is an interest in the collection, segrega-
tion, and recycling of used batteries. Batteries produced and used in the
United States include household dry-cell batteries and lead-acid batteries.
Dry-Cell Batteries—
A $3 billion retail battery market exists in the United States. More
than two-thirds of the sales in 1987 ($2,231 million) were for retail house-
hold batteries. In 1987, 59 percent of the total retail market was for
alkaline batteries, 26 percent for heavy-duty batteries, and 15 percent for
general-purpose batteries. Figures 4 and 5 present details regarding the
U.S. battery market. Note: The National Electrical Manufacturers Associa-
tion (NEMA) would not release figures on sales of nickel cadmium batteries in
the United States.
35
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Retail Household Batteries
$2,231*
Federal
OEM
$150
Industrial
$200
Government
$100
Retail Button Cells
$340
NOTE: All numbers are in millions of retail dollars
* Six popular household sizes (D, C, AA, AAA, 9 volt and
lantern batteries) make up 98% of all retail battery sales.
Source: Rayovac Corporation 1988
Figure 4. Breakdown of the 1987 U.S. battery market.
36
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• D, C and AA sizes account for 84"/# of today's applications.
• General Purpose is heavier In traditional D and C size
flashlight and radio applications.
• Alkaline is heavier In AA and AAA electronics applications.
• Heavy Duty tends to be similar td the total usage pattern-a
good value alternative for all applications.
• AA and AAA are the fastest growing Sizes.
SIZE
D
C
AA
AAA
9 Volt
6 Vol!
GENERAL
PURPOSE
TOTAL
100
HEAVY
DUTY
26%
22
38
11
3
loo
ALKALINE
18%
17
48
8
9
100
Figure 5. The 1987 retail market by size.
Source: A. C. Nielsen, NFO Consumer Purchase Diary
TOTAL
21%
19
44
5
10
1
100
37
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Mercury is used in the following dry-cell batteries:
0 Mercuric oxide batteries
0 Silver oxide batteries
0 Alkaline manganese batteries
° Carbon zinc batteries
° Zinc air batteries
Also produced and used in the United States are nickel-cadmium dry-cell
batteries, which do not contain mercury and can be recharged. Part of the
attention given these batteries was due to the presence of cadmium in solid
waste incinerator ash.
In 1986, the production of batteries accounted for 24 percent of the
total cadmium and 45 percent of the total mercury consumed in the United
States. A marketing study by the Duracell Corporation, however, indicates
that by 1990, 75 percent of all the batteries purchased in the United States
will be alkaline.
Level of risk—Views in the United States vary regarding the threat to
public health and the environment associated with the disposal of dry-cell
batteries in landfills and incinerators. At EPA's Third National Conference
on HHWM, Dr. Allen Hershkowitz, Director of Municipal Recycling Associates,
pointed to one Swedish study that concluded that mercury from batteries is
responsible for 60 to 70 percent of all the mercury coming from incinerators
and 35 percent of all background levels of mercury in the environment. A
study of pregnant women in Sweden indicates that mercury emissions pose a
health threat to the public. He said that these studies led the Swedish
government to require the collection and separation of batteries from the
municipal solid waste stream.
Raymond Balfour, Vice President of Rayovac Corporation, a U.S. manu-
facturer of batteries, provided an industry perspective at EPA's Third
National Conference on HHWM. He cited six U.S. and European studies con-
ducted between 1975 and 1988 that indicate that household dry-cell batteries
do not pose a threat to public health or the environment when they are
disposed of in landfills or incinerators. Balfour also cited industry
projections that mercury usage in U.S. consumer battery production would
decline steadily during the late 1980s (as shown in Figure 6). He noted that
whereas the September 1988 draft report by EPA's Municipal Solid Waste Task
Force made many references to lead-acid batteries, it did not single out
household batteries as a matter of concern.
Rayovac and the other dry-cell battery companies that belong to the
National Electrical Manufacturers' Association are concerned with the con-
sequences of proposed battery collection and disposal programs. Batteries
that residents accumulate in homes before they bring them to a collection
depot pose a risk to human health (especially children) if they are ingested
or implanted in the nose or ear. Electrical current passing between the
terminals can set off a chemical reaction and cause a chemical burn in the
surrounding body tissue.
38
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1000
Source: Rayovac Corporation 1987
800
600-
W
c
o
H .
400-
CO
200
° 1983 1984 1985 1986 1987 1988 1989
Year
Figure 6. Use of mercury in U.S. consumer battery production.
752.8
674.9
mmp
ilMMm
432.6
l#fll§§fllt
l§§pttS
Actual
Estimated
269.5
167.9
-------
Balfour further stated that the aggregation of large quantities of
batteries will result in physical and electrical contact between batteries.
This contact generates heat and hydrogen gas, which creates the risk of fires
or explosions if sufficient ventilation is lacking. An example of such an
explosion and resulting injury occurred in 1985.
Dry-cell battery collection/recycling--Battery collection activities
have occurred in at least six States. In several cases, efforts have been
targeted for the collection of mercury and silver oxide button batteries; at
least one U.S. company, Mercury Refining Company in Latham, New York, has
begun to recycle batteries for their mercury content. In 1987, legislation
was proposed in two States (California and Iowa) to require the source
separation of household batteries; however, the legislation did not pass. A
Congressman in New York State has proposed a $0.25 deposit on each battery
sold in the state as an incentive for consumers to return spent batteries and
to promote recycling by manufacturers.
The dry-cell battery industry takes the position that no evidence of
environmental or health risks exists that indicates a need to collect and
recycle batteries. According to Raymond Balfour, the only U.S. markets for
recyclables are for silver and mercuric oxide batteries, and these markets
are likely to decrease with the continuing reduction in the use of mercury.
Lead-Acid Batteries--
The lead-acid batteries produced and sold in the United States are used
in cars, trucks, and electric vehicles (e.g., golf carts). The Battery
Council International reported that total domestic sales of original bat-
teries (batteries included in new automobile purchases) was 13.1 million in
1987. An additional 59.9 million replacement batteries (batteries not
included in the purchase of automobiles) were sold during the same year.
Lead-acid batteries are recycled in the United States. Speaking for the
Secondary Lead Smelters Association and the Battery Council International at
the EPA's Third National Conference on HHWM, Robert Steinwurtzel noted that
there are approximately 23 secondary lead smelters in the United States
today, down from more than 60 smelters in 1980. Spent lead-acid batteries
represent the major raw material used by the industry, so the industry has an
incentive to see that lead-acid batteries are recycled and not disposed of in
municipal landfills.
According to Steinwurtzel, about 80 percent of used batteries are being
recovered and recycled by the secondary lead industry. The secondary lead
industry recovers the lead and neutralizes the sulfuric acid. The plastics
casings are recycled and sold back to plastics manufacturers, and the rubber
is recovered or rendered nonhazardous and properly disposed of.
5.2.3 New Hampshire/Vermont Household Battery Collection Program
In the spring of 1987, the New Hampshire/Vermont (NH/VT) Solid Waste
Project, a consortium of 26 municipalities in the two states that joined
together to develop and implement a regional solid waste management solution,
initiated a program targeting the removal of household batteries from the
40
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solid waste stream. The population of the Project area is around 60,000
people. The goal of the program is to reduce concentrated sources of metal
in the waste and return to industry those batteries that can be recycled.
The Project initially requested Signal Environmental Systems' Engineered
Materials Research Center to research the leading sources of lead, cadmium,
and mercury in municipal solid waste and the potential for reducing the
volume of these metals through recycling. Conclusions offered in the Signal
report indicated that excluding all types of batteries from municipal solid
waste would have a major impact on the amount of mercury, cadmium, and (to a
lesser extent) lead in the emissions and ash residues of municipal waste-
to-energy plants. Another benefit of excluding batteries would be the
presence of less zinc in the effluent because most disposable batteries also
contain zinc. It was further concluded that the most effective recycling
programs should concentrate on all types of batteries.
The NH/VT Project responded to the conclusions in the report by de-
signing its Household Battery Collection Program. This program is funded by
28 participating municipalities. The Battery Collection Program shares a
$15,000 operating budget with another New Hampshire/Vermont Project waste
management program.
The primary purpose of the Battery Collection Program is to remove
household batteries from the municipal solid waste stream. The program is
set up through stores that sell dry-cell batteries in the region, and it
targets household dry-cell batteries (not automotive batteries). Approxi-
mately 70 stores and recycling centers in the region initially agreed to
display a 5-quart silver bucket with a battery collection logo (see Figure 7)
adjacent to their battery display and to encourage consumers to return their
used batteries. Currently, about 80 stores participate in the program, and
the 5-quart buckets have been replaced with 10-quart buckets to provide
adequate storage for the used batteries.
Local civic organizations such as the League of Women Voters, the
Retired Senior Volunteer Program, and the Boy Scouts volunteered to collect
the batteries from the buckets on a routine basis. Initially, buckets were
emptied every 2 months, but more frequent servicing will be required as
participation increases. Boy Scout troops have segregated the batteries
containing mercury and silver for recycling.
Recyclable batteries have been sent to Mercury Refining Company in
Albany, New York. Because of the limited staff time available to sort and
send out batteries for recycling, the vast majority of batteries are stored
and disposed of by a licensed hazardous waste contractor. Seven pounds of
recyclable batteries were sent to Mercury Refining Company during the first 6
months of the Program.
Batteries destined for disposal are stored at the Claremont Transfer
Station in labeled 55-gallon drums. Northeast Solvents, a hazardous waste
contractor, picks up the drums during the scheduled spring HHW day held at
the site each year. This year, a special trip was necessary in the fall
41
-------
Project
I
©
Figure 7. New Hampshire/Vermont project battery collection logo.
42
-------
because of the increase in the number of batteries collected. The batteries
are disposed of at a Canadian landfill.
The first servicing of the battery collection buckets, which occurred 2
months after they were set out in April, resulted in a return of approxi-
mately 130 pounds of household batteries. Between May 1987 and September
1988 the Project collected more than 9 tons of household batteries.
The total startup cost for the Program was $942. This includes the cost
of 125 collection buckets, logo decals, advertising, and mileage. Disposal
costs for nonrecyclable batteries for the 6-month period ending in October
1987 were $300/55-gallon drum, or $750 total. In 1988, disposal costs were
$3300 for 6.5 tons of batteries. The cost of staff time is estimated to be
$5000 per year.
The Project planners consider the Battery Collection Program a great
success. An estimated 8 percent (by weight) of the total battery waste
stream of the targeted service area is captured by the collection program,
which significantly reduces the amount of batteries disposed of in the solid
waste stream.
5.3 CASE STUDY—USED OIL
5.3.1 Source
Used Oil Curbside Collection Program, Milpitas, California, September
1986. Source and Program Sponsor: Browning Ferris-Industries (BFI), P.O.
Box 1987, San Jose, California, 95108. Contact: Mr. Lynn B. Ingraham,
Safety Manager. Phone: (408)432-1234.
5.3.2 Generation of Used Oil In the United States
Information gathered by EPA in 1983 indicates that approximately 1.2
billion gallons of used oil is generated annually. Of this total, 700
million gallons comes from lubricants such as engine, gear, and turbine oils.
Roughly half of this 700 million gallons is generated by do-it-yourself (DIY)
oil changers who change the oil in their automobiles. About 500 million
gallons comes from industrial uses such as hydraulic fluid, metal working
fluids, insulating oils, and coolants. This industrial segment of used oil
generation is fairly well controlled.
At EPA's Second National Conference on HHWM, Donald Gilson, Senior
Environmental Specialist for Chevron USA in San Francisco, California,
provided the following information on how used oil is handled in the United
States:
° Reprocessed for burning--49 percent. (Oil is collected through
simple filtration; water is removed and then mixed with virgin oil,
depending on the level of contaminants.)
0 Dumping—33 percent. (Soil, sewer, landfill, trash)
43
-------
o
Road oiling—6 percent. (This is no longer considered an environ-
mentally acceptable method.)
° Re-refined oi!--5 percent. (Oil is collected and goes through a
chemical processing procedure, usually vacuum distillation or acid
treatment, and another filtration; additives are put in, and it is
then sold as "new" product.)
° Onsite recycling--4 percent. (Waste oil burners for heating)
0 Nonfuel--3 percent. (Base stock for asphalt)
Gilson stated that do-it-yourselfers account for about half of the
dumping of used oil. The oils are frequently dumped in backyards, basement
drains, and the trash.
5.3.3 Regulatory History
In 1980, Congress passed the Used Oil Recycling Act, which directed EPA
to promulgate regulations by October 15, 1981, to protect against hazards
associated with recycled oil. Under the Act, EPA was to ensure that such
regulations do not discourage recovery or recycling of used oil. The EPA was
further directed to determine whether used oils should be classified as
hazardous waste.
In November 1985, EPA published a two-part proposal in the Federal
Register that suggested listing used oil as a hazardous waste and establish-
ing special standards for used oil recycling. In 1986, after receiving
public comments, EPA issued a used oil rule. The rule did not list recycled
oil as a hazardous waste, but it required disposal of oil to be handled as a
hazardous waste. In May 1986, EPA specified that used-oil mixtures con-
taining 1000 ppm of total halogens are subject to the full hazardous waste
regulations. The rule prohibits the use of chlorinated solvents in the
treatment of used oil. The basis for this decision was that the label of
"hazardous waste" might create a stigma that would discourage recycling and
its environmentally beneficial effects.
In the fall of 1988, the U.S. Court of Appeals ruled in favor of a
Natural Resources Defense Council/Association of Petroleum Re-refiners/
Hazardous Waste Treatment Council lawsuit by rejecting the validity of EPA's
decision not to list used oil as a hazardous waste so as to avoid the "stigma
effect." The EPA was ordered to base its decision regarding whether to
classify used oil as a hazardous waste on scientific data.
The EPA is currently reviewing the options available after the court
decision. Susan O'Keefe of the EPA's Office of Solid Waste noted that should
used oil be listed as a hazardous waste, the SQ6 generation and transporter
standards of RCRA will not apply to used oil if such oil is recycled.
In the meantime, EPA is supporting State and local used oil programs
through a clearinghouse on used oil initiatives. The EPA publishes the Used
Oil Recycling Bulletin and is working on a manual entitled "How to Start a
Community Used Oil Recycling Program." The Agency is also preparing several
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pamphlets that can be distributed by State and local programs. One pamphlet
is for service stations and other facilities that collect used oil centrally;
the other is a handout for the DIYer on how to recycle used oil properly.
Individual States have also passed regulations regarding used oil.
California, Massachusetts, Missouri, New Jersey, New York, South Carolina,
Rhode Island, and Vermont regulate waste oil as hazardous. Illinois, Maine,
Michigan, Minnesota, Washington, and Wisconsin regulate waste oil as a
special waste.
5.3.4 Recycling Used Oil
In the United States, the recycling of used oil includes burning for
energy as well as reusing oil (re-refining). The re-refining process in-
volves complex technical operations and processes to produce a contaminant-
free lubricant base oil. It also produces byproducts.
At EPA's Third Conference on HHWM, John Nolan, President of the National
Oil Recycling Association based in Reston, Virginia, noted that the oil-
recyclirig industry is not a highly organized industry. It is made up of
small businesses ranging from very small (e.g., the owner of a single tank
truck who collects oil in a few small cities and towns) to a recycling plant
that processes as much as 20 million gallons per year. The EPA has identi-
fied approximately 700 used-oil collection companies and 240 recycling
companies that produce fuel oil from waste oil. Most of these recyclers
process less than 3 gallons per year.
Mr. Nolan commented on the variety of industrial users of recycled oil
fuel, including steel mills, cement kilns, power plants, greenhouses, marine
diesel engines, industrial boilers and furnaces, and asphalt plants. Nolan
said that the Nation's 3000 oil-fired asphalt plants are a particularly
attractive market because they operate in virtually every county in the
country.
Also at EPA's Third Conference on HHWM, George Booth, Executive Director
of the Association of Petroleum Re-refiners based in Buffalo, New York,
reported that in the 1950's, more than 100 re-refiners were producing in
excess of 300 million gallons of oil per year. Today, only four U.S. com-
panies and one Canadian company are re-refining approximately 60 million
gallons of used U.S. oil per year. According to Booth, re-refining involves
distillation processes that include dehydration, vacuum fuel/light oil
stripping, and vacuum distillation. It also includes finishing processes
such as hydrotreating and fractionation. Hydrotreating is a relatively new
process that involves final purification of the used oil by reacting the
hydrogen with the halogens, sulfur, oxygen, and other remaining compounds.
The decline in used oil recycling in the United States may be explained
in part by the economics of recycling. John Nolan of the National Oil
Recycling Association maintained that for a viable market to exist for
recycled oil, the price of virgin oil must be high enough for the recycler to
be competitive. A discount is necessary because the customer risks high
water content or dirt that can clog a burner when recycled oil is used.
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Between 1980 and 1984, a strong market for recycled oil existed. After OPEC
(Organization of Petroleum Exporting Countries) lost its grip on the market,
however, the price for crude and used oil plunged. Nolan remarked that
today collectors can no longer pay used oil generators for the used oil;
therefore, the economic climate has largely removed the incentive for used
oil recycling.
5.3.5 Curbside Collection in Milipitas, California
In September 1986, Browning-Ferris Incorporated (BFI), a solid and
hazardous waste contractor, initiated a curbside motor oil collection program
in Mi 1 pi tas, California, (a community of 48,800) in response to the following
concerns:
0 Oil was contaminating residential trash destined for sanitary
landfills (waste oil is regulated as a hazardous waste in Cali-
fornia).
° Oil spills and sprays were occurring when oil containers
were compacted in BFI garbage trucks.
° Oil was posing a safety hazard to collection workers, staining
uniforms, and leading to productivity losses.
Browning-Ferris offered to add a voluntary curbside collection program
to the Mi 1 pi tas contract for solid waste pickup. Mi 1 pi tas agreed to include
the program in the contract, but told BFI that they did not expect the
program to work.
The city fire department was contacted by BFI to find out if the
department would distribute one-gallon milk containers (provided by BFI) for
residents to use to hold the used oil that would be left at curbside.
Residents were also permitted to use their own bleach bottles for the oil.
The cartons are also available at BFI's district office.
Program Implementation—
The public relations campaign begun by BFI invited residents to sepa-
rate used oil and put it in containers at the curbside with their trash. The
targeted population is the estimated 60 percent of the 15,000 households that
are do-it-yourself oil changers.
The company initially retrofitted its refuse collection vehicles with
9-gallon holding tanks on the undercarriages in anticipation of a 1 percent
participation rate. Large-mouthed tanks were mounted above the hydraulic
system of the sanitation trucks. The large mouths on the tanks allow the
drivers to pour the oil without spilling any on the ground. Spigots on the
tanks allow BFI to drain the oil when the truck returns to the company yard.
After residents' oil cartons are drained, BFI disposes of the con-
tainers with the trash. The cartons are thrown away because children may
play with the empty cartons and spill the small amount of residual oil that
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is left after the carton has been drained. Thus, BFI concluded that reusing
the cartons was not worthwhile.
At the end of each collection day, sanitation truck drivers return to
the BFI yard and drain the oil into a 2000-gallon underground holding tank,
where it is commingled with the company's own waste oil. The oil is put
through a strainer before it is poured into the holding tank. The containers
that are attached to the trucks are cleaned daily to keep the spigot from
clogging. The used oil is pumped out of the holding tank and sent to an oil
recycler once every week.
Monitoring the Program--
The BFI truck drivers monitor residential compliance with the program.
If they notice that some residents are still hiding oil in the trash, drivers
mark down the address of such residents on their route sheet. On that same
day, BFI sends a letter, with a carbon copy to the fire department, reminding
the resident that the used-oil-collection program is in effect.
Within a week after the letter is sent, a representative from the fire
department visits the household and informs them that they are not properly
disposing of their oil. These personal visits have proved very effective in
drawing new participants into the program.
Program Results--
During the first few months, the 9-gallon containers were adequate to
handle the 1 percent participation rate that had been expected. Over time,
however, the program gained popularity because BFI had succeeded in getting
across its educational message to the public. After several months of the
program, BFI was inundated with used oil. By the end of 1988, Mi 1 pitas had
achieved approximately a 48 percent rate of participation by the targeted
population, which has resulted in the collection of about 12,500 gallons of
used oil each month.
The 9- to 10-gallon holding tanks quickly became inadequate for the
volume of oil that was made available for collection. Additional 20- or
30-gallon tanks were attached to truck undercarriages to supplement the
original containers.
The results for 1987 are as follows:
Mi 1 pi tas population (September 1988) ) -48,800 people
Amount of oil collected -12,595 gallons
Disposal cost per gallon ($0.10) -$1,295.50
Estimated number of households -15,000
Average amount per participating household -1.2 gallons
It costs BFI $0.10 per gallon to have the oil recycled. This cost is
added to the $1,700 startup cost for the program and the minimal cost of
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supplying the 1-gallon milk containers ($0.01 each) when computing the total
costs of the collection program.
According to BFI, the benefits of the program have more than compensated
the company for the costs they have incurred. The benefits include:
° Extending the life of the landfill operated by BFI.
° Improved relations between BFI, State regulators, and the
community.
° Fewer incidents of sanitation workers getting splashed with used
oil.
° Less worker compensation losses associated with accidents involving
oil disposed of in residential trash.
° Separation of additional hazardous materials. (As a positive side
effect of the program, residents began to separate out hazardous
materials, in addition to oil, from the regular trash.)
5.4 CASE STUDY —PAINT
5.4.1 Source
San Diego County Paint Collection Program, San Diego, California, 1986 -
Source and Program Sponsor: San Diego County Department of Health Services,
Division of Environmental Health Protection, Hazardous Materials Management
Unit, San Diego County Department of Health Services, San Diego, CA 92138.
Contact: Linda Pratt, Hazardous Materials Specialist. Phone: (619)236-
2222.
5.4.2 Paint Generation in the United States
The National Paint and Coatings Association (NPCA) provided the follow-
ing statistics on the amount of paint consumed in the United States:
0 The United States currently consumes about 1 billion gallons of
paint and coating products each year.
0 Architectural coatings formulated for use on new and existing
residential, commercial, institutional, and industrial structures
account for 46.5 percent (465 million gallons) of the paint con-
sumed in the United States.
° Sixty percent (27.9 million gallons) of the paint is used for
residences.
° Approximately 66 percent (18.5 million gallons) of the residential
paint portion is used by do-it-yourself painters, and the remaining
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portion (9.4 million gallons) is used by professional painters and
contractors.
5.4.3 Paint Types and Associated Hazards
According to the NPCA, 73 percent of the paint consumed in the United
States is water-based (latex), and 27 percent is solvent- or oil-based.
Each type of paint presents different hazards. At the EPA's Third
Conference on HHWM, Ronald Child of California Products Corporation, a
Massachusetts paint manufacturing company, stated that solvent-based paints
are hazardous because the mineral spirits in these paints are flammable and
poisonous. When collected and consolidated in large amounts, they are
generally regarded as hazardous wastes on HHW collection days. Furthermore,
in some cases collected paints have been found to contain PCBs (poly-
chlorinated biphenyls).
Solvent-based paints generated as waste by households, however, are not
technically regulated by RCRA Subtitle C as hazardous because HHW is exempt
from regulation. These paints may be subject to State regulation, however.
For example, the amount of solvent-based paint consumed in California has
been declining because of strict air quality controls on volatile organics.
According to Ronald Child, latex paints seldom contain anything hazard-
ous. They are considered hazardous, however, if they contain more than 1
percent ethylene glycol, which evaporates when paints are dried. Concerns,
have arisen, however, regarding the mercury content in latex paint, as
mercury has been used to inhibit spoilage. Although Robert Foreman of NPCA
indicated (at the same conference) that the use of mercury in paint is
declining, he also stated that the label on the can does not indicate whether
the paint contains mercury.
The lead content in paint used in the United States has also caused
concern. Regulations limit the amount of lead allowable in paint, and
programs to remove lead paint from buildings are in effect.
5.4.4 Management Options
Latex and solvent-based paints are generally received in large quan-
tities on HHW collection days. The percentage of paint received during
collections compared with other household products is estimated as high as 60
to 80 percent. Thus, the cost of managing and safely disposing of paint
received on collection days is an important concern for collection sponsors.
Some communities have attempted to focus their efforts by holding
"paint-only" collection days. Paint exchanges and referrals have also been
sponsored to promote the redistribution of unused paint. For example, the
Minnesota Pollution Control Agency operates a referral program that attempts
to match potential suppliers and users of paint that might otherwise be
disposed of.
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Paint that is collected for disposal on HHW collection days is often
consolidated in an effort to minimize disposal costs. Some waste-management
companies have developed mechanical devices that are used to scrape paint out
of the original containers, and then drain it into drums of consolidated
paints. A permit may be required before consolidating paints because con-
solidation is a form of waste treatment.
The HHW collection sponsors have made efforts to recycle and treat as
well as safely dispose of collected paint. Landfill bans on liquid wastes
favor the use of incineration over landfilling as a treatment and disposal
option.
The extent to which paint can be reprocessed effectively is a subject
that has generated some debate. The NPCA has argued that paint recycling is
difficult to accomplish because consumed paint wastes are not a reliable
source of raw materials. The Association maintained that this is true
because consumer paint products are based on well-researched formulations
designed to provide quality performance. The NPCA maintained that con-
sistently achieving the desired performance properties necessitates that
manufacturers use raw materials of known quality.
Nevertheless, paint reprocessing efforts have proceeded. For example, a
project conducted in Seattle, Washington, by Philip Morley & Associates with
the cooperation of the NPCA, is exploring opportunities for reprocessing
latex paint received during HHW collections. A reprocessed paint has been
produced that seemingly performs well as an interior paint, based on standard
paint industry tests.
Latex paint collected at ongoing collection sites in San Bernardino
County, California, is submitted to a local manufacturer, where the paint is
used in the production of an industrial-grade primer. This primer has then
been used by various county agencies. Solvent based paint collected in the
county is sent to a solvent-recovery plant. After all the solvents are
recovered, the waste sludge is incinerated. Paints collected in San Diego
and San Francisco, California, have also been processed for redistribution.
5.4.5 Paint Collection in San Diego County, California
The HHW program in San Diego County is administered by the County
Department of Health Services, Hazardous Materials Management Division.
Funding for the program is shared by the City of San Diego through the Water
Utilities Department and by the County Department of Public Works through the
Solid Waste Division.
The program sponsored 10 "paint collection" events in fiscal year
1986-87 at different locations throughout the county. The events were held
on Saturdays. School parking areas were used primarily because they provide
ample space and easy access. The county is required by the State of Cali-
fornia to apply for a treatment, storage, and disposal facility (TSDF) permit
variance prior to holding collection events.
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Staffing requirements of the paint-collection events generally consisted
of 8 member of the County Environmental Health Services' staff, 10 employees
of the licensed waste management contractor hired for the program, and
occasionally some high school student volunteers.
Although the 1986-1987 collections were advertised for paint collection
only, residents brought other types of HHW. It was therefore decided to
discontinue holding "paint only" collections and to collect paint on HHW
collection days. Eighteen HHW collections were held in fiscal year 1987-
1988, and 14 collections are scheduled for 1988-1989.
Paint Collection and Recycling--
In 1987, paint collected by the county was loaded onto a roll-off
container. At a later date, the waste management company segregated the
paints as either solvent-based or water-based and by light or dark color
prior to consolidating them into 55-gallon drums.
The combined volume of about 6800 gallons of paint was collected in
fiscal year 1986-87. Of that total, approximately 65 percent (4420 gallons)
was water-based paint.
After the paint was consolidated, the county arranged to have the
water-based (latex) paint reprocessed by A Major Paint Company, Inc., a
subsidiary of Standard Brands, Inc. The paint was packaged into 5-gallon
containers for reuse in the community. The cost associated with reprocessing
the paint was approximately $2.00 per gallon.
The paint reprocessing process used by Standard Brands was a simple
filtration process, which the county determined it could handle without the
assistance of the paint company. The county currently has its HHW con-
tractor, Alliance Technologies II, reprocess both latex- and solvent-based
paints received during HHW collections. The paint is filtered through a
wire-mesh strainer and segregated into light and dark colors before it is
marketed.
In fiscal year 1987-1988, approximately 75 percent of the paint col-
lected during county HHW collections was recycled. This percentage cor-
responds to approximately 97 tons (or 23,000 gallons) of paint.
Marketing the Product--
The reprocessed paint produced by Standard Brands was an interior/ex-
terior product recommended for rough surfaces. The original intent was to
make the reprocessed paint available to government agencies or nonprofit
organizations. The Boy Scouts were the only nonprofit group that expressed
an interest in the paint.
The Project Director of the San Diego County Department of Health
Services paint program said that the following factors impeded the success of
the redistribution effort:
0 The color selection was limited to brown or beige.
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° The quality of the paint was questioned, especially by government
agencies.
° The reprocessed paint did not meet military specifications (the
military is a large potential reprocessed paint purchaser in the
region).
It was later decided that the paint would be included in the county
cooperative auction that is held quarterly and is open to the public. In
fiscal year 1987, all of the reprocessed paint was purchased by eight private
contractors, acting independently, for an average price of $12 per 5-gallon
pail.
The county currently sells the reprocessed paint at the county auction,
or gives it away. Paint sold at the auction generates revenue of approxi-
mately $20 per 55-gallon drum. In fiscal year 1987-1988, reprocessed paint
sales generated approximately $3000 in revenue, which compares favorably with
the $2 per gallon the county had been paying Standard Brands to reprocess the
paint. Solvent-based paint is given away in Mexico, as strict air quality
standards prohibit its use as an outdoor paint in California.
Conclusions--
The county expects to continue its paint reprocessing and redistribution
program. Although the revenues generated by the sale of reprocessed paint do
not cover the costs of reprocessing, the Project Director stated that the
program is considered cost-effective because of the funds saved by not having
to dispose of the paint as hazardous waste. The county has not yet computed
these net savings.
The county is also pleased with the final reprocessed paint product.
Followup conversations with contractors that have purchased the paint and
used it for a variety of internal and external painting projects indicate
that the quality of the paint is satisfactory.
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SECTION 6
TREATMENT AND DISPOSAL RESEARCH AND DEVELOPMENT
6.1 FACILITIES FOR RECYCLING
Existing and planned facilities for recycling, treatment, or disposal of
HHW are briefly described here.
6.1.1 Batteries
The Mercury Refining Company, Inc., of Latham, New York, recovers
mercury from batteries. Battery collection programs in places such as New
York City and New Hampshire/Vermont have sent batteries to Mercury Refining.
Lead-acid batteries are recycled in the United States. Approximately 23
secondary lead smelters are operating in the United States today, down from
more than 60 smelters in 1980. Because spent lead-acid batteries are the
major raw material used by this industry, an incentive exists to see that
lead-acid batteries are recycled and not disposed of in municipal landfills.
About 80 percent of used batteries are currently being recovered and
recycled by the secondary lead industry, which recovers the lead and neu-
tralizes the sulfuric acid. The plastics casings are recycled and sold back
to plastics manufacturers, and the rubber is recovered or rendered nonhaz-
ardous and properly disposed of.
6.1.2 Oil
Although no oil recycling or treatment facilities are designed specifical-
ly for used oil generated by households, an active oi1-recycling industry in
the United States receives oil from both households and industry. The EPA
has identified approximately 700 used-oil collection companies and 40 re-
cycling companies that produce fuel oil from waste oil. According to a
representative of the National Oil Recycling Association, most of these
recyclers process less than 3 million gallons per year. The United States
also has several oil re-refiners. A spokesperson for the Association of
Petroleum Re-refiners reported that approximately 60 million gallons of used
oil is re-refined each year in the United States.
6.1.3 Paint
Efforts have been made to recycle paint received during HHW collections.
Particular interest has been shown in paint recycling because paint is
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normally the item received in the largest volume (60 to 80 percent of the
total) during HHW collections.
Philip Morley & Associates, in cooperation with the National Paint and
Coatings Association, is conducting a project in Seattle, Washington, to
explore opportunities for reprocessing latex paint received during HHW
collections. In Phase 1 of this project, 660 gallons of latex paint brought
to a collection site and sorted, and 285 gallons of light-shaded, nonlead-
based paint that had not frozen, spoiled, or dried up were combined for
reuse. The resulting product was a latex flat paint with an "institutional
beige" color, which was appropriate for interior usage. When the paint was
subjected to standard paint industry tests, it was deemed comparable to new
paint in quality, based on viscosity and opacity tests. Although it did not
tolerate scrubbing very well, it was stain resistant and adhered well to
walls. It has an estimated shelf life of 6 months. The paint that has been
used will be checked periodically for performance.
During Phase 2 of the project, pre- and post-sorted paints will be
tested for the presence of priority pollutants. Project planners have
concluded that continued paint recycling has great potential, but they will
continue to study its efficacy and, particularly, its impact on the new-paint
market.
Others have also been involved in paint reprocessing and redistribution.
Three California counties (San Bernardino, San Diego, and San Francisco)
recycle paint received during HHW collections. Latex paint collected at
ongoing collection sites in San Bernardino County is submitted to a local
manufacturer that uses the paint in the production of an industrial grade
primer, which has been used by various county agencies. Solvent-based paint
collected in the county is sent to a solvent recovery plant. After all the
solvents are recovered, the waste sludge is incinerated.
6.1.4 Fluorescent Tubes
Some activity regarding the recovery of mercury from fluorescent tubes
is taking place in the United States, including research and development of
new technologies. The Mercury Refining Company of Latham, New York, recovers
mercury from fluorescent tubes by using a retort process. Retorting involves
crushing the tubes, placing them in pans, and indirectly heating them in
10-foot-long, stainless-steel, retort vessels. The mercury first passes
through a condenser, where volatile materials are distilled out, and is then
further purified before it is marketed.
Although no marketing figures were provided, an environmental engineer
for the Mercury Refining Company noted that only a handful of drums are
processed each year. This limited activity is due to the relative cost of
the retort process. It takes the company roughly 48 hours to process a
single 55-gallon drum at a cost of approximately $1200 per drum. Thus far,
the suppliers of used fluorescent tubes have come from industry (not house-
holds), particularly companies in California, where regulations regarding
mercury disposal are quite stringent.
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The Mercury Refining Company is exploring more cost-effective processes
for recovering mercury. One process would involve shaking the tubes in a
manner that would facilitate the collection of the vibrating mercury.
Mech-Chem Associates, Inc., of Norfolk, Massachusetts is currently
applying for a permit in California to construct a facility for recycling
fluorescent tubes. The company plans to recover mercury and other materials
from 2 to 4 million lamps per year.
The recovery process is called a "washing" technology. It involves
crushing the lamps, washing the material to remove the mercury, and re-
covering the mercury through centrifuge, filtration, and distillation pro-
cesses. Mech-Chem claims that this recovery technology is more cost-
effective than European technologies and that recovery of 100 percent of the
materials used in the tubes is possible. Although the company expects to
charge suppliers for its acceptance of used tubes for recycling, the Company
President expects the fee to be competitive when compared with the cost for
disposal.
Mech-Chem may be in operation as early as the last quarter of 1989. It
will target commercial suppliers of tubes, as 80 percent of the fluorescent
tubes in this country are consumed by commercial markets. According to the
President of Mech-Chem, the company will also be willing to process used
tubes from households (the other 20 percent of the market) if communities
will collect the tubes for them (e.g., via HHK collections).
6.1.5 Permanent HHW Collection Centers
Dana Duxbury & Associates identified 27 permanent HHW collection pro-
grams (programs operating at least once per month) in the United States.
These are listed in Appendix C, Table C-l. Although the amount of HHW
treatment at these facilities is not extensive, at least some of these
centers consolidate collected products (e.g., paint) and neutralize some
acids and bases. Both neutralization and consolidation are considered waste
treatment in this country
6.1.6 Solvents
No U.S. solvent-recovery or treatment facilities are designed specifi-
cally for household solvents; however, HHW collection centers have sent used
solvents to facilities that recover or treat industrial solvents. For
example, the Sanitary Fill Company recycles solvents collected at its ongoing
HHW collection facility in San Francisco, California.
6.2 R&D ACTIVITIES—MANAGEMENT AND SUBSTITUTION OF HAZARDOUS SUBSTANCES IN
CONSUMER PRODUCTS
This subsection briefly describes the research and development (R&D)
activities that have been undertaken by industry, government agencies, and
citizens' groups.
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6.2.1 Citizens' Groups
The following groups have been involved in R&D:
° The League of Women Voters in Albany, New York, researched
alternatives to commonly used hazardous household products ana
produced a book instructing consumers how to formulate and use
alternative products.
0 The National Coalition Against the Misuse of Pesticides (NCAMP)
studies options for reducing pesticide usage. The Coalition
promotes integrated pest management (IPM) programs as a means of
promoting substitution of pesticides with nonchemical pest manage-
ment practices.
° The National Toxics Campaign studies and advocates input substi-
tution and end-product reformulation as a means of preventing the
generation of hazardous waste, including HHW.
6.2.2 Government Agencies
The Congressional Office of Technology Assessment studied IPM, and
produced a report in 1980 in which it was concluded that an IPM approach
could reduce pesticide usage by as much as 75 percent in the United States.
6.2.3 Industry
The following are examples of industry's involvement in R&D regarding
management and substitution of hazardous substances in consumer products:
° The Polaroid Corporation has worked to eliminate the use of mercury
in its batteries. The company succeeded in reducing mercury by 50
percent during 1987, and had eliminated mercury from all of its
battery production by April 1988.
° Pesticide manufacturers have worked to develop new pesticide
formulations that are pest-specific and that do not build up in the
environment or concentrate in the food chain. For example, at
EPA's Second National Conference on HHWM, Dr. Robert Etter of the
Chemical Specialties Manufacturers Associations claimed that the
pesticide pyrethrin was developed as an insect-specific toxin that
is effective in killing many insects but poses no threat to other
animals, including humans.
6.3 CLEAN TECHNOLOGIES
The Mercantile Food Company of Georgetown, Connecticut, imports ECOVER
products from Oostmalle, Belgium, into the United States. ECOVER manu-
factures products such as dishwashing liquids and laundry detergents that are
labeled "ecologically safe" because of their biodegradabi1ity, the absence of
phosphates, and the use of all-natural ingredients. Although these products
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are not readily available in major supermarkets, they are sold in stores such
as food co-ops.
Some consumers are using "home-brew" household products suggested by
some government agencies and environmental groups as less hazardous alter-
natives to certain commercial products. For example the use of baking soda,
water, and steel wool pads has been suggested as a substitute for commercial
oven cleaners. A combination of baking soda and boiling water has been
suggested as a replacement for commercial products that unclog drains. No
known data were found on the extent to which the various lists of numerous
suggested substitutes are actually used.
Rechargeable (nickel cadmium) batteries are in use in the United States,
and despite the fact that nickel and cadmium wastes are considered hazardous
wastes, these batteries could be viewed as a clean technology because they
are rechargeable. The National Electrical Manufacturers Association (NEMA)
would not release figures on U.S. sales of nickel-cadmium batteries.
6.4 FUTURE PERSPECTIVES ON HWW AND SQGS
Bans on the disposal of many hazardous wastes in landfills (including a
ban on liquid hazardous wastes) are expected to promote treatment and dis-
posal technologies that reflect the EPA hazardous waste hierarchy of reduc-
tion, reuse, recycling, treatment, and disposal. Thus, greater emphasis will
be placed on the pretreatment and incineration of hazardous waste generated
by households and small quantity generators.
In the area of research and development, growing attention will be
placed on developing less hazardous products. Public health concerns about
lead, cadmium, and other hazardous constituents in the waste stream, and
concerns with regard to liability and waste site cleanup will also promote
research and development of safer products. Companies such as Polaroid and
General Electric have already undertaken successful R&D initiatives, and this
trend is expected to continue.
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REFERENCES
Porter, W. 1988. "Clarification of Issues Pertaining to Household Hazardous
Waste Collection Program." Memorandum from the Assistant Administrator for
Solid Waste and Emergency Response to U.S. Environmental Protection Agency
Waste Management Division Directors. November.
University of California at Davis, 1987. Managing Hazardous Wastes Produced
by Small Quantity Generators. Division of Environmental Studies, Sacramento,
CA. April.
U.S. Environmental Protection Agency. 1986. Implementation Strategy for
Small Quantity Generators of 100-1000 Kg/month. Office of Solid Waste,
Washington, D.C. April.
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APPENDIX A
ISWA Working Group on Hazardous Wastes
Survey on Household Hazardous Waste Management
in Member Countries
Questionnaire
1. Problems
What substances and consumer products are considered hazardous ? Why are they
considered household hazardous wastes ? (Waste treatment infrastructure, emission
control)
As to commercial small quantity generators, which businesses and which hazardous
wastes currently escape control ? Why ? (Minimum quantities, lack of legislation)
2. Policy approach
Is there any identified official policy or any legislative framework or management plan as
to household hazardous wastes and small quantity generators in your country on a
national/federal level
regional level
local/community level
If not, what are possibly the reasons ?
If so, please state the main elements of the policy or management plan with regard to the
following keywords:
Aims
What wastes and what generators are concerned ? Please give
definitions.
Information activities (product labelling, consumer advice, public
awareness)
Is the policy based on compulsory regulation or voluntary activities ?
= If compulsory, what are the legal regulations ? (banning of products
and substances, restrictions, compulsory collection activities,
shipment)
= If voluntary, what initiatives can be identified ? (e. g. by trade and
industry, substitution of substances, waste audits)
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ISWA Working Group on Hazardous Wastes
Household Hazardous Waste Survey
Is the policy based on active, "front-end", or passive, "end-of-the-pipe"
measures ?
= Active measures (avoidance of hazardous components and
products, substitution activities, dean technologies)
= Passive measures (e. g. separate collection, deposit schemes)
Future perspectives
3. Technical and organisational aspects
What institutions, organisations, and authorities are currently or potentially supporting
household hazardous waste management ?
Are there promotion activities or subsidies for clean technologies or seperate collection of
household hazardous wastes ?
4. Case studies
Case studies should provide detailed information on sucessful initiatives as to household
hazardous wastes or small quantity generators that goes beyond general descriptions.
If possible, please state examples with reference to the following products considered
hazardous in many countries:
Batteries
Waste oil
Old drugs
PVC
Any additional examples are appreciated. A further aspect that should be addressed are
programs concerning small quantity generators (e. g. metal plating, dry cleaning,
surgeries, photo labs, motor repair shops etc.).
Please give some general information on the local situation (population,
density, housing structure, city/rural area, waste collection and treatment)
Who became active ? (authorities, trade and industry, environmentalists)
Organisation (wastes or products concerned, collection system and
collectors, treatment and disposal, economic incentives, deposit schemes)
Technology (substitution activities, recycling technologies, treatment of
collected wastes)
Information (consumer advice, product labelling, information campaign,
technical information for trade and industry, education in schools)
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ISWA Working Group on Hazardous Wastes
Household Hazardous Waste Survey
Legal framework (compulsary or voluntary activity, taking-back obligation,
banning of products or substances)
Results (quantities and composition of collected wastes, waste avoidance
and collection efficiency, public response)
Costs
5. Treatment and disposal, research and development
Are there existing or planned facilities for recycling, treatment or disposal of household
hazardous wastes ? (recycling of batteries, fluorescent tubes, treatment of refrigerators etc)
Are there research and development activities as to management and substitution of
hazardous substances in consumer products ? What clean technologies are in use ?
What are the future perspectives in your country in the field of household hazardous
wastes and small quantity generators ?
6. Comments
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APPENDIX B
1981-1988 State Level Household Hazardous Waste Laws and Regulations1
Alaska
•
•
•
Alabama
Arizona
Arkansas
California
•
Pe
•
•
•
•b
Colorado
•
Connecticut
•
G/
7p
•
•
•*
•
Delaware
Florida
•
G
•
•
•
Georgia
Hawaii
•
•
•
Idaho
Illinois
•
•
•
•
•
Indiana
Iowa
•
•
•
•
•
•
Kansas
•
•
•
•
•
Kentucky
Louisiana
Maine
Maryland
•
Massachusetts
•
G/
/P
•
•*
Michigan
P
•
•
•*
Minnesota
•
•
•
•
•
•
Mississippi
Missouri
•
•
•
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APPENDIX B
1981-1988 State Level Household Hazardous Waste Laws and Regulations (cont'd)
£
State
Montana
Nebraska
Nevada
New Hampshire
G
•
•*
New Jersey
•
•
New Mexico
New York
•
•
Pe
•
•
North Carolina
•
North Dakota
Ohio
Oklahoma
Oregon
•
•
Pennsylvania
•
P
•*
Rhode Island
•
•
South Carolina
South Dakota
Tennessee
Texas
•
P
•
Utah
Vermont
P
•
Virginia
•
Washington
•
•
0/
/P
•
•
G
•
G
•
West Virginia
Wisconsin
<*/
/P
•
•
•
•
Wyoming
a SOURCE: Dana Duxbury & Associates, January 1989
b State Solid Waste Superfund $ (State solid waste cleanup funds that have been applied to HHW management); Advisory Committe
Report (Recommendations and evaluations of HHW activities by State-appointed HHW advisory committee).
0 HHW Product Labeling (State regulations or guidelines that pertain to the labeling of hazardous household products); Retail Sales
Permit Fee (Iowa requires retail stores that sell hazardous household products to purchase a permit, and revenues are used
to fund HHW collections).
P = Program; G = Grants; Pe = Permanent
* = Funded in 1988
NOTE: Definitions of headings appear on the next page.
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APPENDIX B
DEFINITIONS OF COLUMN HEADINGS (Note Some of these
categories may overlap, and thus double-count State commitments)
Regulation and/or Guidelines — State regulations or guidelines pertaining to
the definition and/or management of HHW.
Define HHW — Formal State definitions of HHW.
Reduction of Liability — Legislation or regulations designed to limit the liability
of HHW collection program sponsors and managers.
State Education Programs — HHW education programs that are
sponsored by State agencies.
State Run Cleanup Programs — HHW collections that are sponsored,
managed, and funded by State agencies.
Pilot Cleanup Programs — Programs held on a one-time basis, often as a
precursor to more permanent State commitment of resources and staff
time funded with general revenues.
State Legislative Appropriation — General revenue appropriations approved
by State legislatures to fund HHW management efforts.
State Matching Grants — State grants used for local HHW collections that
match the funding commitment of the local sponsors.
Use of State Superfund $ — State hazardous waste cleanup funds that
have been applied to HHW management.
EPA Cleanup Grant $ — Regional Offices of EPA have provided grant monies
that have been used to fund HHW management programs.
Evaluation Report — Evaluation reports that were prepared to evaluate
State-run pilot projects.
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APPENDIX C
PERMANENT* HOUSEHOLD HAZARDOUS WASTE
COLLECTED PROGRAMS OPERATING IN 1988**
ALASKA
1. Anchorage, Alaska
Contact: Jim Sweeney, Program Manager, Municipality of Anchorage, P.O.
Box 19650, Anchorage, AL 99519-6650, (907)561-1906.
General Information: Accepts HHW and Small Quantity Generator (SQG)
waste at drop-off station or by appointment pick-up; built by munici-
pality at at cost of $1.3 million.
Collection Site: Anchorage Regional Landfill with a drop-off station at
the Central Transfer Station.
Date Established: February 1988.
CALIFORNIA
2. Monterery, California
Contact: Ms. Dulce Ledo, Monterey Regional Waste Management District,
P.O. Box 609, Marina, CA 93933, (415)468-4114.
General Information: Open 5 days/week for HHW drop-offs; operated by
Monterey Regional Waste Management District at an annual cost of
$35,000; funded by tipping fees charged to landfill site users.
Collecion Site: Monterey landfill.
Date Established: January 1987.
3. San Bernardino, California
Contact: Diane Christensen, Environmental Specialist, San Bernardino
County Health Department, 385 North Arrowhead Avenue, San Bernardino, CA
92415, (714) 387-4626.
General Information: First of six permanent sites in the country
generally accepting only HHW; licensed treatment, storage, and disposal
facility (TSDF) for the waste collected at this site and at the five
satellite sites; open five weekdays per week with no appointment
necessary; funded by landfill tipping fee.
Collection Site: San Bernardino TSDF.
Date Established: Spring 1985.
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4. Fontana, California
Contact: Diane Christensen, Environmental Specialist, San Bernardino
County Health Department, 385 North Arrowhead Avenue, San Bernardino, CA
92415, (714)387-4626.
General Information: One of five county satellite collection sites to
the primary site in San Bernardino; open one weekend day/week;
co-sponsored by fire department.
Collection Site: Fontana Fire Department.
Date Established: Spring 1985.
5. Redland, California
Contact: Diane Christensen, Environmental Specialist, San Bernardino
County Health Department, 385 North Arrowhead Avenue, San Bernardino, CA
92415, (714)387-4626.
General Information: One of five county satellite collection sites to
the primary site in San Bernardino; open one weekend day/week;
co-sponsored by fire department.
Collection Site: Redland City Yard.
Date Established: Spring/Summer 1987.
6. Barstow, California
Contact: Diane Christensen, Environmental Specialist, San Bernardino
County Health Department, 385 North Arrowhead Avenue, San Bernardino, CA
92415, (714)387-4626.
General Information: One of five county satellite collection sites to
the primary site in San Bernardino; open one weekend day/week;
co-sponsored by fire department.
Collection Site: Barstow Fire Department.
Date Established: Spring/Summer 1987.
7. Rancho Cucamonga, California
Contact: Diane Christensen, Environmental Specialist, San Bernardino
County Health Department, 385 North Arrowhead Avenue, San Bernardino, CA
92415, (714)387-4626.
General Information: One of five county satellite collection sites to
the primary site in San Bernardino; open one weekend day/week;
co-sponsored by fire department.
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Collection Site: Rancho Cucamonga Fire Department.
Date Established: Spring/Summer 1987
8. Victorville, California
Contact: Diane Christensen, Environmental Specialist, San Bernardino
County Health Department, 385 North Arrowhead Avenue, San Bernardino, CA
92415, (714)387-4626.
General Information: One of five county satellite collection sites to
the primary site in San Bernardino; open one weekend day/week;
co-sponsored by fire department.
Collection Site: Victorville Fire Department.
Date Established: Spring/Summery 1987.
9. San Franciso, California
Contact: Larry Sweetser, Environmental Compliance Program Manager,
Sanitary Fill Company, 501 Tunnel Avenue, San Francisco, CA 94134,
(415)468-2442.
General Information: Licensed treatment storage and disposal facility
operated by Sanitary Fill Co. in cooperating with the San Francisco
Health Commission and Chief Administrative Office; open 3 days per week
for HHW only; funded by solid waste tax on residents' monthly bill.
Collection site: Household Hazardous Waste Collection Facility (HHWCF)
at San Francisco Solid Waste Transfer Station.
Date Established: January 21, 1988.
10. Santa Monica, California
Contact: Deborah Bain, Recycling Division, City of Santa Monica, 1685
Main Stree, Santa Monica, California 90401, (213)458-8526.
General Information: Operates Monday-Saturday from 8:00 AM to noon;
accepts only HHW; funded through city's general fund for the first year.
Collection site: City Department of Public Works maintenance yard.
Date Established: November 14, 1988.
FLORIDA
11. Volusia, Florida
Contact: Lindalee Anderson, Environmental Specialist, Volusia
Environmental Management Deparment, 123 W. Indiana Avenue, DeLand,
Florida, (904)736-5927.
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General Information: Collect HHW and conditionally exempt SQG waste on
different days, once per month, bu appointment for the conditionally
exempt SQGs. May start a pick-up waste collection for the conditionally
exempt SQGs.
MASSACHUSETTS
12. Martha's Vineyard, Massachusetts
Contact: Kate Gage, Program Coordinator/Planner, Martha's Vineyard
Refuse Disposal District, P.O. Box 2248, Oak Bluffs, MA 02887,
(508)693-3479.
General Information: Fixed site managed by the Refuse.District and
North East Solvents; funded by the District and by a state grant;
currently accepts only household waste, though is expected to expand to
also accept waste from regulated very small quantity hazardous waste
generators (VSOGs); open one or two days per month.
Collection Site: Trailer on the grounds of the Town Wastewater
Treatment Plant.
Date Established: August 27, 1988.
MICHIGAN
13. Kalamazoo County, Michigan
Contact: Tom Dewhirst, Kalamazoo County Human Services, Household
Hazardous Waste Coordinator, 418 West Kalamazoo Avenue, Kalamazoo, MI
49007, (616)383-8863.
General Information: Accepts only HHW by appointment once per month;
funded by County and business contributions; discourages smoke detector,
latex paint, motor oil, and car batteries.
Collection Site: Usually at the Kalmazoo County Fairgrounds.
Date Established: July 29, 1988.
14. Washenaw County, Michigan
Contact: Steven Manville, HHW Program Coordinator, County Health
Department, 2355 West Stadium, P.O. Box 8645, Ann Arbor, MI 48107,
(313)994-2494.
General Information: Accepts only HHW by appointment at mobile sites;
discourages smoke detectors, latex pains, motor oil, and car batteries;
receives approximately 40 participants at a cost of about $2600 per
col lection.
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Collection Site: Health Department parking lot.
Date Established: May 1988.
15. Kent County, Michigan
Contact: Donna Engstrom, Kent Country, DPW, 1500 Scribner North West,
Grand Rapids, MI 4S504, (616)774-6892.
General Information: Accepts only HHW by appointment; discourages smoke
detectors, latex paint, motor oil, and car batteries; funded by the
Department of Public Works and manged jointly with Health Department;
operating once per month and attracting approximately 50 participants
per month.
Collection Site: Garage of DPW Road Commission Building.
Date Established: April 28, 1988.
16. Ingham County, Michigan
Contact: Bob Ceru, Supervisor, Toxic Materials & Hazardous Waste,
Ingham County Health Department, P.O. Box 30161, Lansing, MI 48909,
(517)887-6988.
General Information: Accepts only HHW by appointment; funded by an EPA
grant and the county; recycles paints and automotive products on site;
discourages smoke detector, latex paint, motor oil, and car bateries;
operating from a fixed site at a cost of approximately $45 per house-
hold.
Collection Site: Health Department Garage.
Date Established: September 1986.
17. Macomb County, Michigan
Contact: Robert MacDonald, Program Development, Environmental Health
Planner, Macomb County Health Department, 43525 Elizabeth Rd, Mt.
Clemens, MI 48043, (313)469-5236.
General Information: Accepts HHW 5 days/week by appointment at not
charge; funded by the EPA and the state Natural Resource Department.
Collection Site: Elizabeth Road Storage Site.
Date Established: February 5, 1988.
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MINNESOTA
18. Lyon County, Minnesota
Contact: Ned Brooks, Pollution Control Specialist, MPCA-Hazardous Waste
Division, 520 Lafayette Road, North St. Paul, MN 55155, (612)296-6300.
General Information: Accepts only HHW, 1/2 day per week; no appointment
necessary; paint exchange at collection site; latex paint discouraged;
state trains local residents to staff the collection; funded by county
with matching state grant.
Collection site: Highway Department Garage in Marshall, MN.
Date Established: November 1988.
19. Duluth, Minnesota
Contact: Ned Brooks, Pollution Control Specialist, MPCA-Hazardous Waste
Division, 520 Lafayette Road, North St. Paul, MN 55155, (612)296-6300.
General Information: Accepts only HHW, 1/2 day per week; no appointment
necessary; paint exchange at collection site; latex paint discouraged;
state trains local residents to staff the collection; funded by county
with matching state grant.
Collection site: Duluth landfill transfer station/sewage plant/
incinerator site.
Date Established: May 1987.
20. Kandyiohi County, Minnesota
Contact: Ned Brooks, Pollution Control Specialist, MPCA-Hazardous Waste
Division, 520 Lafayette Road, North St. Paul, MN 55155, (612)296-6300.
General Information: Accepts only HHW, 5 days per week; no appointment
necessary; paint exchange at collection site; latex paint discouraged;
state trains local residents to staff the collection; funded by county
with matching state grant.
Collection site: Landfill storage building in New London, MN
Date Established: June 1988.
NEW YORK
21. Southold, New York
Contact: Jim McMahon, Southold Town Hall, Main Road, Southold, NY
11971, (516)765-1892.
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General Information: Accepts HHW as well as hazardous waste from small
businesses, schools, etc. at no charge, with no appointment necessary;
fixed site built with state funding at $23,000 start-up cost and managed
by town with town funds.
Collection Site: Southold landfill.
Date Established: June 1988.
VIRGINIA
22. Arlington, Virginia
Contact: Tanya Spano, Process Control Engineer, WPC Plant, 3401 S.
Glebe Rd., Arlington, Virgina, (703)684-6607.
General Information: Accepts only HHW; operated by the Water Pollution
Control Plant for Arlington; funded by county; drop-off by appointment.
Collection Site: Water Pollution Control Plant.
Date Established: 1986.
WASHINGTON
23. Whatcomb County, WA
Contact: Dave Bader, Whatcomb County Health Department, P.O. Box 935,
Bellingham, WA 98227, (260)676-6724.
General Information: Accepts HHW by appointment during regular working
hours; program is run by County Health and Solid waste Departments and
funded by solid waste budget.
Collection Site: Waste collected at shed at city central shops.
Date Established: 1982.
24. Thurston County, Washington
Contact: Marie Zurofke, County Health Department, 2000 Lakeridge Drive,
Olympia, WA 98502, (206)786-5459.
General Information: Accepts only HHW; funded by County Public Works
and Environmental Health Departments from a solid waste tipping fee;
start-up costs, including the construction of a small building;
approximately $20,000; accept waste without appointment every Saturday;
currently do not advertise the collection service because facility would
be overwhelmed, but expansion is expected.
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Collection Site: Building situation at Thurston County Landfill.
Date Established: March 1987.
25. Georgetown, Washington
Contact: Kathy Buller, Chemical Processors, Inc. 2203 Airport Way,
South, Seattle, WA 98134, (206)223-0500.
General Information: HHW only accepted as a public service by Chemical
Process at no charge; operating 1 day/week; accept non-extremely haz-
ardous SQG waste at a fee as of February 1989.
Collection Site: Chemical Processors commercial TSD facility in
Georgetown (outside of Seattle).
Date Established: 1982.
26. Washouqal, Washington
Contact: Kathy Buller, Chemical Processors, Inc. 2203 Airport Way,
South, Seattle, WA 98134, (206)223-0500.
General Information: HHW only accepted as a public service by Chemical
Process at no charge; operating 1 day/week; accept non-extremely haz-
ardous SQG waste at a fee as of February 1989.
Collection Site: Chemical Processors commercial McClary Columbia TSD
facility in Washougal.
Date Established: June 1988.
27. Seattle/King County, Washington
Contact: Wallace Swofford, Environmental Health Supervisor, Seattle/
King County Department of Public Health, 172 20th Avenue, Seattle, WA
98122, (206)296-4633.
General Information: Collects pesticides (targets banned pesticides)
from households at 5 sites, 5 days per week, by appointment; funded by
county and city; county is phasing out program as new permanent sites
and mobile facilities are in the planning stages.
Collection Site: 5 sites in the county.
Date Established: 1982.
A permanent collection program is defined as a program that accepts
HHW at least once per month.
Source: Dana Duxbury & Associates, 1989.
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GLOSSARY
CERCLA - Comprehensive Environmental Response Compensation and Liability Act.
This national law applies to hazardous waste site cleanup, emergency
response, and chemical release reporting. Commonly known as "Superfund".
CSMA - Chemical Specialities Manufacturers Association.
DEM of Massachusetts - Massachusetts Department of Environmental Management.
Environmental planning agency for Massachusetts.
DEQE - Department of Environmental Quality Engineering. State environmental
enforcement agency for Massachusetts.
DIY - Do-it-yourself oil changer.
EPA - United States Environmenal Protection Agency. This national agency
oversees environmental protection programs.
EP toxicity - Extraction Procedure toxicity. An EP toxicity test is designed
to simulate leaching conditions that might occur in a landfill.
FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act.
GRCDA - Governmental Refuse Collection and Disposal Association.
Hh'WK - Household Hazardous Waste Management.
HSWA - Hazardous and Solid Waste Amendments. HSWA amended RCRA.
IMP - Integrated pest management.
LQG - Large quantity generator of hazardous waste.
MPCA - Minnesota Pollution Control Agency.
NCAMP - National Coalition Against the Misuse of Pesticides.
NEMA - National Electrical Manufacturers Association.
NPCA - National Paint and Coatings Association.
NPL - National Priorities List. List of sites prioritizied for hazardous
waste cleanup under CERCLA.
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GLOSSARY (continued)
OPEC - Organization of Petroleum Exporting Countries.
ORD - EPA Office of Research and Development.
OSHA - Occupational Safety and Health Administration.
OTA - Congressional Office of Technology Assessment.
PCBs - Polychlorinated Biphenyls.
POTW - Publicly Owned Treatment Works. A POTW is a muncipal wastewater
treatment facility.
RCRA - Resource Conservation and Recovery Act. RCRA is a national hazardous
and solid waste management law.
RITTA - RCRA Integrated Training and Technical Assistance Grants Program.
SARA - Superfund Amendments and Reauthorization Act. SARA amends CERCLA.
SQG - Small quantity generator of hazardous waste.
TSDF - Treatment, storage, and disposal facility for hazardous waste.
VSQG - Very small quantity generator of hazardous waste.
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