How to Inventory Your Wastes for Environmental Compliance

How to Inventory
Your Wastes for
Environmental Compliance
Produced by the Pacific Northwest Pollution Prevention Resource Center
1326 Fifth Ave, Suite 650, Seattle, Washington 98101
phone: 206-223-1151, fax: 206-223-1165
e-mail: office@pprc.org, web: http://www.pprc.org/pprc/
A joint project of the Small Business Assistance Programs in Alaska, Idaho, Oregon and
Washington. Funded by a grant from the U.S. Environmental Protection Agency, Region 10.
July 1997
This information is available on the internet at
http://www.pprc.org/pprc/sbap/sbap.html
CHECKLIST
As you go through each section a certain action on your part is suggested. These actions are
signified by a check mark
. These sections are listed below and should be checked off after
you have completed the action suggested in that particular section. Once this list is completely checked off you have successfully progressed through the waste inventory process and
have gained a better awareness of your waste streams and how those wastes are regulated.
You will have the knowledge to begin to eliminate or reduce these waste streams by implementing pollution prevention opportunities.
1. CREATING WASTE INVENTORY LISTS
____ Hazardous/solid waste inventory
____ Air emission sources inventory
____ Water pollution sources inventory
2. UNDERSTANDING HAZARDOUS WASTES
____ Determine if wastes are hazardous, recyclable or landfillable
____ Quantify monthly generation of hazardous wastes
____ Determine hazardous waste generator status
____ Identify requirements for being a hazardous waste generator
3. UNDERSTANDING AIR EMISSION SOURCES
____ Determine if products contain hazardous air pollutants and other air toxics
____ Estimate annual use of hazardous air pollutants
____ Determine air emission source status (major or area source)
____ Identify requirements for using hazardous air pollutants
4. UNDERSTANDING WATER POLLUTION SOURCES
____ Understand responsibilities and requirements for having water pollution sources
ACKNOWLEDGEMENTS
The PPRC is indebted to many individuals for assistance with this informational guide.
Funding was provided by a grant from the U.S. Environmental Protection Agency.
The PPRC wishes to thank the following individuals for their willingness to share the information, ideas and suggestions that helped shape the content of this workbook:
• Bernard Brady, Washington Department of Ecology
• Bob Burmark, Washington Department of Ecology
• Scott Lytle, Alaska Department of Environmental Conservation
• Doug McRoberts, Idaho Department of Environmental Quality
• Terry Obteshka, Oregon Department of Environmental Quality
• Rick Volpel, Oregon Department of Environmental Quality
DISCLAIMER
The Small Business Assistance Programs in Idaho, Oregon and Washington, and the Compliance Assistance Program in Alaska, were created to provide assistance to small businesses
concerning the requirements of the Clean Air Act Amendments of 1990. This compliance
and pollution prevention informational guide was created for the programs to provide multimedia compliance and pollution prevention assistance, and to aid small business owners with
questions concerning environmental issues. This information is not a comprehensive document covering every environmental regulation that could affect a business. It is the responsibility of the owner/operator to stay abreast of changes in environmental regulations that
govern his/her industry.
TABLE OF CONTENTS
Checklist and Introductory Information ........................................................................ 1
1. CREATING WASTE INVENTORY LISTS ............................................................... 3
Hazardous/Solid Waste Inventory ............................................................................. 5
Air Emission Sources Inventory ................................................................................ 6
Water Pollution Sources Inventory ........................................................................... 7
2. UNDERSTANDING HAZARDOUS WASTES .......................................................... 8
Determine if wastes are hazardous or non-hazardous .............................................. 8
Quantify monthly generation of hazardous wastes ................................................... 11
Determine hazardous waste generator status ........................................................... 12
Identify requirements for being a hazardous waste generator ................................. 13
3. UNDERSTANDING AIR EMISSION SOURCES ..................................................... 17
Determine if products contain regulated chemicals ................................................. 17
Estimate annual use of regulated chemicals .............................................................. 19
Determine air emission source status ........................................................................ 23
Identify requirements for using regulated chemicals ............................................... 24
4. UNDERSTANDING WATER POLLUTION SOURCES .......................................... 26
Understand responsibilities and requirements for managing water pollution sources . 26
APPENDIX A: Internet Resources ................................................................................ 28
APPENDIX B: Contacts List .......................................................................................... 30
APPENDIX C: Weekly Facility Inspection List ............................................................. 33
APPENDIX D: List of Hazardous Air Pollutants ........................................................... 34
APPENDIX E: Other Federal and State Regulations .................................................... 35
INTRODUCTION
If you own or operate a business in the Pacific Northwest and are concerned with
business competitiveness, environmental regulations, waste, and pollution prevention, this online self-help tool is for you.
If you’re not concerned about these issues and don’t think this information can
improve the efficiency of your operations; save you money; help you comply with
the laws you should already be following; make you eligible to participate in state,
county and local public recognition programs, and reduce your liability by improving employee health and safety — think again!
Using this information and incorporating its concepts into current waste management practices could be one of the most important business planning decisions you
make. Stringent environmental regulations increase demands on your business to
stay one step ahead of costs related to environmental compliance; pollution prevention techniques can help you meet this challenge.
This self-help information guide is divided into four easy-to-follow chapters to help
you better identify and calculate the types and quantities of wastes generated and
emitted from your shop, understand the environmental regulations associated with
these wastes, and identify opportunities to reduce or eliminate the generation of
pollution. Refer to the Contacts List or Appendix A: Internet Resources at any
time to find resources available to help you understand your environmental issues
and pollution prevention opportunities.
A checklist is included to guide you through:
1. Creating Waste Inventory Lists
2. Understanding Hazardous Wastes
3. Understanding Air Emission Sources
4. Understanding Water Pollution Sources
Let’s get started....
1
CHECKLIST
As you go through each section a certain action on your part is suggested. These actions are
signified by a check mark
. These sections are listed below and should be checked off after
you have completed the action suggested in that particular section. Once this list is completely checked off you have successfully progressed through the waste inventory process and
have gained a better awareness of your waste streams and how those wastes are regulated.
You will have the knowledge to begin to eliminate or reduce these waste steams by implementing pollution prevention opportunities.
1. CREATING WASTE INVENTORY LISTS
____ Hazardous/solid waste inventory
____ Air emission sources inventory
____ Water pollution sources inventory
2. UNDERSTANDING HAZARDOUS WASTES
____ Determine if wastes are hazardous, recyclable or landfillable
____ Quantify monthly generation of hazardous wastes
____ Determine hazardous waste generator status
____ Identify requirements for being a hazardous waste generator
3. UNDERSTANDING AIR EMISSION SOURCES
____ Determine if products contain hazardous air pollutants and other air toxics
____ Estimate annual use of hazardous air pollutants
____ Determine air emission source status (major or area source)
____ Identify requirements for using hazardous air pollutants
4. UNDERSTANDING WATER POLLUTION SOURCES
____ Understand responsibilities and requirements for having water pollution sources
2
CHAPTER 1.
CREATING WASTE INVENTORY LISTS
Regulated wastes and emissions from manufacturing operations can include liquid and solid
hazardous wastes, air emissions, and waste water. Manufacturers also produce non-hazardous solid waste. Figure 1 shows typical wastes from a manufacturing environment. Look
around your business and consider how this figure applies to you.
Figure 1: Typical Wastes Encountered in Manufacturing
• Aerosol cans
• Cleaners
• Cleanup sorbents (floor
dry)
• Contaminated antifreeze
• Contaminated fuel
• Contaminated used oil
• Dirty shop towels
• Empty chemical
containers
• Hazardous Air
Pollutants
• Packaging waste
• Paint-related wastes
(sludge, strippers,
thinners, etc.)
• Paint chips and
sandblast media
• Parts washer sludge/
solvent
• Process water
• Solvent still sludge
• Spent hydraulic oil
• Spent processing chemicals
and rinsewater
• Surface coating materials
• Tramp oils
• Vehicle maintenance wastes
• Volatile organic compound
(VOC) air emissions
• Waste acids
(hydrochloric, nitric,
sulfuric, chromic,
etc.)
• Waste adhesives
• Waste batteries/
battery fluids
• Waste solvent
Creating a list of all of the waste streams at your facility makes good business sense. An inventory of wastes will:
• Allow you to distinguish between wastes that are considered hazardous, air emissions
or water pollutants and wastes that can be recycled or landfilled.
• Help you make changes in your operating practices as regulations change. Since you
will know what wastes are considered hazardous and the quantities of these wastes,
the impacts of regulations will be easy to identify.
• Guide you on controlling costs associated with meeting your environmental responsibilities.
Develop your own inventory list of hazardous waste streams, air emission sources and water
wastes for the processes in your facility. Refer to Figure 1 for lists of common manufacturing
wastes to help guide you in identifying the different waste streams your processes generate.
Next, make copies of the worksheets provided below. Fill out the worksheets to inventory
your hazardous and solid wastes, air emissions and water pollution sources. Each worksheet
3
has different instructions, so be sure you record hazardous and solid wastes on the “Hazardous/Solid Waste Inventory” worksheet; record air emission sources on the “Air Emission Sources
Inventory” worksheet; and record water wastes on the “Water Pollution Sources Inventory”
worksheet. If you use a computer, you may prefer to create your own tables or spreadsheets
and enter this information electronically to make calculating and manipulating of the data
easier.
Obtain a MSDS for Each Waste on Your Inventory Lists
All businesses are required by the Occupational Safety and Health Administration’s Hazard
Communication (Worker-Right-to-Know) rule to maintain an up-to-date collection of Material Safety Data Sheets (MSDSs) for all products used onsite that may affect employee safety
or health. You should already be maintaining a full set of relevant MSDSs in a file that is
accessible to all employees at your business.
The MSDSs will be used to complete the steps in this workbook. You will need to have a copy
of the MSDS for each product that is part of a waste you list on the inventory worksheets. If
your file is missing a specific MSDS, the best place to obtain a new one is from the product
vendor. Vendors are required by law to generate MSDSs for their products and provide
copies on demand to customers. If you are not able to get a MSDS you need from a vendor,
other possible sources are specialized libraries or the Internet. Librarians at your state’s or
county’s environmental agency or at a local college/university often will have MSDS databases.
Check the local government section in your telephone book to find out if an environmental
or chemistry library is available to you in a government agency or college. There are also
several MSDS databases on the Internet (see to Appendix A: Internet Resources).
When you have completed each inventory list, check off these actions on the Checklist on page 2
and go on to the next action.
If you have questions or need help with your waste inventories, see Appendix B: Contacts List.
4
HAZARDOUS/SOLID WASTE INVENTORY
Step 1: Record all of the “possible” hazardous wastes and all “possible” solid wastes
you identify in your facility under the “Waste” column.
Step 2: Find the MSDS or product data sheet for each recorded waste (check the
“MSDS” column when you have found this sheet). Note: MSDSs are only one
tool for waste determination. Other methods, like lab analysis or knowledge of process
can be used as tools for waste determination.
Step 3: For now, leave the “Determined To Be...” and “Total Pounds/Month”
columns blank. You will complete these sections when you work through
Chapter 2: Understanding Hazardous Wastes.
Step 4: When all of your potential hazardous wastes are written down, go to your
copy of the “Air Emission Sources Inventory” worksheet and follow the instructions.
INVENTORY OF POSSIBLE HAZARDOUS AND SOLID WASTES
Wa s t e
MSDS
De t e r mi n e d t o b e :
Hazar dous
To t a l Po u n d s o f H a z a r d o u s Wa s t e Pe r M o n t h
5
Non- hazar dous
To t a l Po u n d s / Mo n t h
AIR EMISSION SOURCES INVENTORY
Step 1: Record all of the “possible” air emission sources you identify in your
facility under the “Emission Source” column.
Step 2: Find the MSDS or product data sheet for each recorded emission source
(check the “MSDS” column when you have found this sheet).
Step 3: For now, leave the “Determined To Be...” and “Total Annual Tons”
column blank. You will complete these sections when you work through
Chapter 3: Understanding Air Emission Sources.
Step 4: When you have recorded all of your air emission sources, go to your
copy of the “Water Pollution Sources Inventory” worksheet and follow the
instructions.
INVENTORY OF POSSIBLE AIR EMISSION SOURCES
De t e r mi n e d t o b e :
Emi s s i o n So u r c e
MSDS
189 HAPs
Hal ogenat ed
S o l ve n t
Total Tons of All Regulated Chemicals Per Year
6
TRI
NonHazar dous
To t a l An nu a l To n s
WATER POLLUTION SOURCES INVENTORY
Step 1: Record all of the “possible” water pollution sources you identify in your
facility under the “Water Pollution Source” column. For now, leave the
“Water Test” and “Determined to Meet Sewer Discharge Limits” blank.
You will complete these sections when you work through Chapter 4: Understanding Water Pollution Sources. You are now ready to move on to Chapter 2: Understanding Hazardous Wastes to begin the hazardous waste determination process.
INVENTORY OF POSSIBLE WATER POLLUTION SOURCES
Wa t e r Po l l u t i o n So u r c e
D i s c h a r g e wa s
Te s t e d
De t e r mi n e d t o Me e t
S ewe r D i s c h a r g e L i m i t s
( Ye s / No )
( Ye s / No )
7
CHAPTER 2.
UNDERSTANDING HAZARDOUS WASTES
This section will help you:
• Determine if the wastes you identified in your “Hazardous/Solid Waste Inventory”
worksheet are hazardous;
• Calculate the pounds of hazardous waste generated on a monthly basis;
• Determine your generator status; and
• Understand some of the basic requirements for your generator status.
You will need your copy of the “Hazardous/Solid Waste Inventory” worksheet with accompanying MSDSs to proceed with the determination process.
DETERMINE IF WASTES ARE HAZARDOUS,
RECYCLABLE OR SOLID WASTE
There are two methods of determining whether wastes are hazardous. These methods are:
1. Knowledge of Process — This method allows business owners to use knowledge of
the wastes generated from their processes in deciding whether they have a listed
waste, if further waste analysis should be conducted, or, if lab analysis is needed,
what type of analysis should be used.
2. Waste Analysis — This method allows the business owner to use available raw
material data to determine whether the waste stream should be further analyzed in a
laboratory. By conducting a waste analysis, you can determine whether wastes have
hazardous characteristics.
a. Characteristic Hazardous Wastes — These are wastes that have certain characteristics (ignitable, reactive, corrosive and/or toxic) that distinguish them from
other solid waste materials.
b. Listed Wastes — These are wastes, specifically listed in the hazardous waste
regulations. “F-listed” hazardous wastes are generally spent cleaning solvents which
contain 10% or more of at least one hazardous chemical. If your cleaning products
contain any of these chemicals (concentrations of 10% or more) they are automatically considered hazardous waste when disposed.
8
Use MSDS to Help Make Hazardous Waste Determination
You can use each product’s MSDS to help determine if your waste streams meet any of the
hazardous waste criteria described below. This section will explore how to apply the information contained in a MSDS to determine if that product meets the criteria for a Characteristic
Waste or an F-Listed Waste. Note: MSDSs are used as a screening tool to determine whether each raw
material possesses hazardous characteristics. You should apply the waste analysis method to determine
unequivocally whether a waste is hazardous.
First, take your “Hazardous/Solid Waste Inventory” worksheet and the MSDSs you have for each
of the products which are found in the waste. Read through the steps (below and on the
following pages) to determine if a waste is hazardous. If you determine that the waste can be
considered hazardous, check that column on your inventory worksheet for the particular
waste. If you determine that the waste does not meet any of the hazardous waste criteria,
check the “Non-hazardous” column.
Step 1. Determine if Waste Meets Criteria of Characteristic Wastes
1a. Refer to Section IV of the MSDS, usually called “Fire and Explosion Data,” to find out
what the flash point is for this product. If it meets the definition of “ignitable,” below,
the waste has a hazardous characteristic.
Ignitable Wastes Common
in Industry
• wash solvents
• methyl ethyl ketone
• solvent-based coatings
Ignitable
Any liquid waste that has a flash point below
140° F (60° C). Any non-liquid capable of
spontaneous combustion under normal
conditions. An ignitable compressed gas or
oxidizer.
1b. Refer to Section III of the MSDS, usually called “Physical Data,” to find out what the
pH level is for this product. If it meets the definition of “corrosive,” below, then the
waste has a hazardous characteristic.
Corrosive Wastes Common in
Industry
• acids
• waste battery acid
• highly alkaline cleaners
Corrosive
An aqueous (water-based) material with a
pH less than 2.0 or greater than 12.5.
9
1c. Refer to Section VI of the MSDS, usually called “Reactivity Data,” to find out if this
product is stable under all circumstances. If it is unstable or “reacts” (see definition
below) with certain other materials, the waste has a hazardous characteristic.
Reactive
Unstable materials that react violently without
detonating. React violently with water or
form an explosive gas, vapor or fume when
mixed with water. Contain cyanide or sulfide
and generate toxic gas vapors/fumes at a pH
between 2 and 12.5.
Reactive Wastes Common in
Industry
• waste bleaches and oxidizers
1d. Refer to Section II of the MSDS, usually called “Hazardous Ingredients,” and find out
if this product contains constituents that would cause the waste to be toxic. You can
also have a laboratory conduct a Toxicity Characteristic Leaching Procedure (TCLP)
test. If the waste contains hazardous ingredients in certain concentrations, it has a
hazardous characteristic.
Toxic
Contains specific constituents above
threshold levels. Typically determined using
a TCLP test. Refer to Appendix B:
Contacts List to find out who to call to locate a testing
facility in your area. This test will determine the amount
of toxic materials in the waste stream.
Toxic Wastes Common in
Industry
• process waste water
• clean-up solvents
• inks, surface coating materials
• corrosive cleaners
If you need help determining if a waste meets the criteria of characteristic wastes, refer to
Appendix B: Contacts List to find out who to call in your area.
Step 2. Determine if the Waste Meets the Criteria for F-listed Wastes
F-Listed wastes, which are specifically listed in the hazardous waste regulations, are generally
spent cleaning solvents that contain 10% or more of at least one hazardous chemical. If your
cleaning products contain any of these chemicals (concentrations of 10% or more) they are
automatically considered hazardous waste when disposed.
Refer to Section II of the MSDS, usually called “Hazardous Ingredients,” and compare the
chemicals found in your product with the list of F-listed chemicals on the following page. If
you find one of the chemicals match with the list and is in concentration 10% or more, then
this waste has a hazardous characteristic.
10
F-Listed Chemicals Common in Industry
acetone
cresols and cresylic acid
benzene
n-butyl alcohol
carbon tetrachloride
2-nitropropane
carbon disulphide
ortho-dichlorobenzene
chlorinated fluorocarbons
pyridine
chorobenzene
tetrachloroethylene
cyclohexanone
toluene
2-ethosyethanol
trichloroethylene
ethyl ether
1,1,1-trichloroethane
isobutanol
1,1,2-trichloroethane
methanol
1,1,2-trichloro-1,2,2-trifluoroethane
methylene chloride
trichlorofluoromethane
methyl ethyl ketone (MEK)
xylene
methyl isobutyl ketone (MIBK)
ethyl acetate
ethyl benzene
nitrobenzene
Note: Any still bottoms generated from the distillation or recycling of these solvents must be managed as a
hazardous waste.
If you need help determining if a waste meets the criteria of F-listed wastes, refer to Appendix
B: Contacts List to find out who to call in your area.
Step 3. Have a Laboratory Conduct a Toxicity Test on the Waste Stream
It is important to understand that some of your waste streams may have been contaminated
by several other products. For example, you may have used oil that alone does not have
characteristics of a hazardous waste. But if the oil comes in contact with a solvent, that oil
may now have a hazardous characteristic. One fail-safe way to determine if a waste is hazardous is to have a laboratory perform a test on the waste stream. If the test shows that toxic
substances found in the waste are above certain thresholds, the waste is considered hazardous.
Refer to Appendix B: Contacts List or your local telephone directory to locate a testing laboratory in your area.
When you have determined if wastes are hazardous, recyclable or landfillable, check off this
action on the Checklist on page 2 and go on to the next action.
QUANTIFY MONTHLY GENERATION OF HAZARDOUS WASTES
Now that you have determined if your wastes are hazardous, you can calculate how many
pounds of each waste you generate in one month. This is necessary because your regulatory
11
requirements depend on the total amount of hazardous waste generation in a one-month
period. There are several ways to calculate the total monthly generation of a hazardous
waste:
Method 1
Determine the density (pounds per gallon) of each waste and multiply that by the actual
number of gallons of that waste you generate in one month. The density of your waste can be
estimated by referring to the MSDS for the product that makes up the waste. Some MSDSs
will give you the actual weight of the product per gallon. Other MSDSs will only give you a
specific gravity for the product. If your MSDS uses specific gravity, multiply that number by
8.34 (specific gravity x 8.34) to convert to pounds per gallon. Use this weight to calculate your
monthly generation.
Example: You generate 20 gallons of wash solvent in one month and solvent has a density of 7
lbs./gal.
20 gal. x 7 lbs./gal. = 140 lbs.
Method 2
If you have access to a scale, weigh your hazardous waste storage container. This weight is
the tare weight. After one month of filling this waste container, weigh it. Subtract the tare
weight from this new weight and this will give you an approximate weight in pounds for one
month of generation of that particular waste.
Example: You have a waste sludge container with a tare weight of 1 lb. and at the end of the
month you weigh the container at 50 lbs.
50 lbs. - 1 lb. = 49 lbs.
Note: Whether you use Method 1 or Method 2, be sure to record your calculated weight for each hazardous waste stream on your “Hazardous/Solid Waste Inventory” worksheet and then total all of the hazardous wastes together.
When you have quantified your monthly generation of hazardous wastes, check off this action on
the Checklist and go on to the next action.
DETERMINE HAZARDOUS WASTE GENERATOR STATUS
Hazardous Waste: ___________ lbs. per month
Enter the total quantity in pounds (lbs.) you calculated from your “Hazardous/Solid Waste
Inventory” worksheet in the above space. Use this number to determine what size hazardous
waste generator you are.
• Conditionally Exempt Generator (CEG). (The State of Washington refers to this as Small
Quantity Generator [SQG]) — 1) A company that generates less than 220 lbs. (typically 20-25
12
gallons) of total hazardous waste, or less than 2.2 pounds of acutely hazardous waste* and/or
waste that is extremely hazardous due to toxicity in a single calendar month, 2) and the
company never accumulates more than 2,200 pounds of hazardous waste or 2.2 pounds of
acutely hazardous waste* and/or waste that is extremely hazardous due to toxicity at any time.
• Small Quantity Generator (SQG). (The State of Washington refers to this as Medium
Quantity Generator [MQG]) — 1) A company that generates more than 220 lbs., and less
than 2,200 lbs. of hazardous waste per month, and less than 2.2 pounds of acutely hazardous
waste in a single calendar month, 2) and the company never accumulates more than 2,200
pounds of dangerous waste or 2.2 pounds of acutely hazardous waste at any time.
• Large Quantity Generator (LQG) — A company that generates more than 2,200 lbs. of
hazardous waste in a single calendar month.
As discussed on the following page in “Identify Requirements for Being a Hazardous Waste
Generator,” generators who have the smallest status have the fewest requirements. If you
find you are a SQG (MQG in Washington) or LQG, you will want to reduce your monthly
generation of waste so you can enjoy the less burdensome requirements of a small quantity
generator. This can be accomplished by reviewing and implementing the best management
practices and pollution prevention opportunities.
If you have questions about your generator status, refer to Appendix B: Contacts List to find
out who to call in your area.
When you have determined your hazardous waste generator status, check off this action on the
Checklist on page 2 and go on to the next action.
IDENTIFY REQUIREMENTS
FOR BEING A HAZARDOUS WASTE GENERATOR
Generator Classification: _______________
Write in your generator classification (CEG [SQG in the State of Washington], SQG [MQG in
the State of Washington] or LQG) in the space above and follow the appropriate chart (on
the following pages) to identify some of your hazardous waste requirements and recommendations. If you have questions about your your requirements for being a waste generator,
refer to Appendix B: Contacts List to find out who to call in your area.
When you have identified the requirements for being a hazardous waste generator, check off this
action on the Checklist on page 2 and go on to Chapter 3: Understanding Air Emission Sources.
____________________________________
*Acutely hazardous waste is generally more dangerous and/or more toxic than other listed wastes. Acutely
hazardous wastes are listed as P-listed wastes. (Refer to Appendix B: Contact List to get more information on P-listed wastes.
13
CONDITIONALLY EXEMPT GENERATOR
(CALLED “SMALL QUANTITY GENERATOR” IN WASHINGTON STATE)
Issue
Required
(Yes/No)
How to Comply
Determine if solid wastes are designated as
dangerous waste
Yes
Complete Chapter 2 of this workbook.
Obtain an EPA/State Generator Identification
Number
No
The state recommends that CEGs (called SQGs in the
State of Washington) obtain an Identification Number.
Manage waste in a way that does not pose a
potential threat to human health/environment
Yes
Send waste to a permitted facility, legitimate recycler or
to sewer agency with permission. Do not dump to
drains, dumpsters or sewer without checking with the
local authorities.
Manifest wastes when shipping hazardous
wastes off site
No
May be required by hazardous waste hauler.
Recordkeeping
No
Annual reporting
No
If you obtained an Identification Number, you are
required to submit an annual report by March 1 for the
previous calendar year.
Label containers/drums
Yes
• Department of Transportation labeling generally
required.
• Health hazard labeling strongly recommended.
Prepare Emergency Response Plans
No
Train employees on proper waste handling
and emergency procedures
No
Inspect on a schedule all monitoring
equipment, safety and emergency equipment,
structural soundness of drums/containers
No
14
SMALL QUANTITY GENERATOR
(CALLED “MEDIUM QUANTITY GENERATOR” IN WASHINGTON STATE)
Issue
Required
Yes/No
How to Comply
Determine if solid wastes are designated as
dangerous waste
Yes
Complete Chapter 2 of this workbook.
Obtain an EPA/State Generator Identification
Number
Yes
Notify your state agency (see Appendix B for
telephone number) to obtain Identification Number.
Manage waste in a way that does not pose a
potential threat to human health/environment
Yes
Send waste to a permitted facility, legitimate recycler or
to sewer agency with permission. Do not dump to
sewer without checking with the local authorities.
Manifest wastes when shipping hazardous
wastes off site
Yes
Use the Uniform Hazardous Waste Manifest Form
when shipping hazardous wastes. Waste must be
disposed of within 180 days of accumulation, provided
amount is less than 2,200 pounds.
Recordkeeping
Yes
Keep manifests and annual reports onsite for at least 5
years.
Annual reporting
Yes
Complete and submit a Hazardous Waste Annual
Report by March 1 for the previous calendar year.
Label containers/drums
Yes
Clearly mark each container of waste with a hazardous
waste label that includes the accumulation start date
and the type of waste and waste codes.
Prepare Emergency Response Plans
Yes
Post the name and telephone number of the
emergency response coordinator, location of fire
extinguishers, spill control materials and fire alarms,
and telephone number of the fire department.
Train employees on proper waste handling
and emergency procedures
Yes
Ensure that all employees are thoroughly familiar with
proper waste handling and emergency procedures
relevant to their responsibilities.
Inspect on a schedule all monitoring
equipment, safety and emergency equipment,
structural soundness of drums/containers
Yes
Complete the Weekly Facility Inspection Checklist.
Make copies of the checklist, which is provided in
Appendix C.
15
LARGE QUANTITY GENERATOR
Issue
Required
Yes/No
How to Comply
Determine if solid wastes are designated as
dangerous waste
Yes
Complete Chapter 2 of this workbook.
Obtain an EPA/State Generator Identification
Number
Yes
Notify your state agency (see Appendix B for
telephone number) to obtain Identification Number.
Manage waste in a way that does not pose a
potential threat to human health/environment
Yes
Send waste to a permitted facility, legitimate recycler or
to sewer agency with permission. Do not dump to
sewer without checking with the local authorities.
Manifest wastes when shipping hazardous
wastes off site
Yes
Use the Uniform Hazardous Waste Manifest Form
when shipping hazardous wastes. Waste must be
disposed of within 90 days of accumulation.
Recordkeeping
Yes
Keep manifests and annual reports onsite for at least 5
years.
Annual reporting
Yes
Complete and submit a Hazardous Waste Annual
Report by March 1 for the previous calendar year.
Label containers/drums
Yes
Clearly mark each container of waste with a hazardous
waste label that includes the accumulation start date
and the type of waste and waste codes.
Prepare Emergency Response Plans
Yes
Formal Plan Required.
Train employees on proper waste handling
and emergency procedures
Yes
Ensure that all employees are thoroughly familiar with
proper waste handling and emergency procedures
relevant to their responsibilities.
Inspect on a schedule all monitoring
equipment, safety and emergency equipment,
structural soundness of drums/containers
Yes
Complete the Weekly Facility Inspection Checklist.
Make copies of the checklist, which is provided in
Appendix C.
16
CHAPTER 3.
UNDERSTANDING AIR EMISSION SOURCES
This section of the workbook will help you:
• Determine if the air emission sources you identified on your “Air Emission Sources
Inventory” worksheet contain regulated chemicals;
• Perform simple calculations to estimate your annual use of these chemicals;
• Determine your status as an air emitter based on the quantity of chemicals used; and
• Understand some of the basic requirements for your source status and air pollutant
emitting equipment.
You will need your copy of the “Air Emission Sources Inventory” worksheet with accompanying
MSDSs to proceed with the determination process.
DETERMINE IF PRODUCTS CONTAIN
REGULATED CHEMICALS
This section will help you determine whether your process materials contain chemicals on
one of three lists: 1) chemicals regulated as Hazardous Air Pollutants (HAPs), 2) very toxic
chemicals used as cleaning solvents, and/or 3) chemicals reportable under the Toxics Release
Inventory (TRI) section of the Emergency Planning and Community Right-to-Know Act
(EPCRA). Many chemicals are on more than one of the three lists.
Using the MSDS you have for each air emission source you identified on your “Air Emission
Source Inventory” worksheet, complete the following steps:
Step 1: Go to Section II of the MSDS, usually called “Hazardous Ingredients,” which lists all
of the chemicals that make up that particular product.
Step 2: As you read each chemical off the MSDS sheet, refer to Table 5 on the next page to
see if that chemical is listed. Table 5 is a selection, taken from the 189 Hazardous Air Pollutants (HAPs) list, of chemicals commonly used by industry. Refer to Appendix D: Hazardous
Air Pollutants for the full list.
Step 3: If you find a match between chemicals on the MSDS with a chemical in Table 5 or in
the Appendix D list, set that MSDS aside (which you’ll use later when calculating your total
emissions).
17
Step 4: If no chemical match is found, continue comparing the chemicals on the MSDS with
the chemicals found in the list of chemicals in Table 6 on the following page and Table 7 on
page 19.
Step 5: Check the appropriate column on your “Air Emission Sources Inventory” worksheet
when you determine the nature of the chemicals you use (189 HAPs, Halogenated Cleaning
Solvent, TRI or Not an Emission Source).
If you are unsure whether a product contains hazardous air pollutants, refer to Appendix B:
Contacts List to find out who to call in your area.
189 HAPs
The chemicals listed in Table 5, which are commonly used by many industries, are listed as
HAPs. See Appendix D for a complete list of the 189 HAPs.
Table 5: Chemicals on the List of 189 HAPs that are Commonly Used in Industry
Benzene
Cadmium compounds
Carbon tetrachloride
Chromium compounds
Cumene
Dibutylphthalate
Diethanolamine
Ethyl benzene
Formaldahyde
Glycol ethers
Hexane
Hydrochloric acid
Isophorone
Lead compounds
Methanol
Methyl ethyl ketone
Methylene Chloride
Tetrachloroethylene
Polycyclic organic matter
Propylene oxide
Toluene
2,4-toluene diisocyanate
1,1,1-trichloroethane
Vinyl chloride
Halogenated Cleaning Solvents
Some of the cleaning liquids in parts washers are considered very toxic and are heavily regulated. If you use a parts washer, refer to the cleaning liquid’s MSDS to determine if the liquid
contains any of the chemicals listed in Table 6 (below). If you find that the cleaning product
you are using does contain any of the chemicals in Table 6, refer to Appendix B to find out
who to call in your state.
Table 6: Chemicals on the List of HAPs Commonly Used in Cleaning Equipment
Carbon tetrachloride
Chloroform
Methylene chloride
Perchloroethylene
Trichloroethylene
1,1,1-trichloroethane
18
Toxics Release Inventory
Chemicals used by industry that are listed in the Toxics Release Inventory (TRI) are included
in Table 7 on the following page.
Table 7: Chemicals on the TRI that are Commonly Used in Industry
Ammonia
Barium
Cadmium
Chromium
Copper
Cumene
Cyclohexane
Ethylbenzene
Ethylene glycol
Ethylene oxide
Formaldehyde
Freon 113
Hydrochloric acid
Hydroquinone
Lead
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Methylene chloride
Phosphoric acid
Silver
Sulfuric acid
Tetrachloroethylene
Toluene
Trichloroethylene
1,1,1-trichloroethane
Xylene
Note: Table 7 is not a complete listing of all chemiccals reportable under EPCRA. The full list
includes more than 600 chemicals.
When you have determined if products contain hazardous air pollutants and other air toxics, check
off this action on the Checklist on page 2 and go on to the next action.
ESTIMATE ANNUAL USE OF REGULATED CHEMICALS
You should now have a group of MSDSs for products that you determined to contain regulated chemicals. Write down the product’s name and the chemicals that are in that product in
the appropriate spaces of the tables provided on page 22 (make extra copies of this page, if
necessary). Then, follow steps 1-5 to determine how many chemicals, and in what quantities,
you use annually.
The following steps will help you perform a mass-balance calculation of your annual emissions. This method is used to estimate the amount of chemical in your products, and assumes
100 percent of the chemical is emitted.
Step 1: Calculate Total Annual Usage of Regulated Chemicals
Using invoices, add up the total gallons purchased of a product in one year. Multiply this total by the density (lbs./gal.) of the product and record this figure in the “Total Pounds of
Product” column in the table. (The lbs./gal. is usually shown in the Physical/Chemical Data
section of the MSDS.)
If specific gravity is given instead of actual lbs./gal., multiply the specific gravity by 8.34 to
get lbs./gal. Multiply this figure by total gallons purchased, and record the total in the “Total
Pounds of Product” column.
19
For example, say you purchased 2,000 gallons of paint, which weighs 9.17 lbs./gal., or has a
specific gravity of 1.1. (To convert specific gravity to lbs./gal., multiply 1.1 by 8.34, which
equals 9.17.) Next, multiply 2,000 gallons by 9.17 to calculate the total pounds of the product.
Example: 2,000 gallons x 9.17 lbs./gallon = 18,340 lbs. of product used
Enter 18,340 in the “Total Pounds of Product” column.
Step 2: Calculate the Percentage of Chemical in Product
Section II of the MSDS lists the percentage of each chemical in the product. Often, this is
called “Weight Percent.” Find this number and convert it to a decimal (multiply by 0.01), and
record the new figure in the “Weight Percent” column in the table. If weight percent is provided in a decimal, simply record that figure in the “Weight Percent” column.
For example, if Chemical “X” in the paint product you bought has a weight percent of 40,
multiply 40 by 0.01 to calculate the weight percent.
Example: 40 x .01 = 0.4
Enter 0.4 in the “Weight Percent” column.
Step 3: Calculate the Total Pounds of Chemical
Multiply the number in the “Weight Percent” column with the quantity in “Total Pounds of
Product” column, and record the total in the “Total Pounds of Chemical” column in the table. Put a check in Column A if you know this chemical is found in other products. This will
help remind you to add up the totals for each chemical from other worksheets.
For example, for Chemical “X” you would multiply the weight percent (0.4) by the total
pounds of the chemical (18,340) to determine the total pounds of the chemical.
Example: 0.4 x 18,340 lbs. = 7,336 lbs. emission of chemical constituent
Enter 7,336 in the “Total Pounds of Chemical” column.
Step 4: Calculate the Total Tons of Chemicals You Use per Year
Add the totals in the Total Pounds of Chemical column for each product, and divide by
2,000. This number is your total tons per year for all chemicals used in your process materials. Next, add the total pounds of each chemical (refer to Column A to identify chemicals
found in multiple products) and divide by 2,000. This number is your total tons per year for
each particular chemical.
For example, if Chemical “X” is found only in one product (i.e. Column A is not checked),
you would divide the total pounds of the chemical (7,336) by 2,000 to determine the total
tons of Chemical “X” you use in one year.
Example: 7,336/2,000 = 3.67 tons
20
Step 5: Calculate Grand Total
Add the Total Pounds/Year figures from each worksheet to determine the total pounds
of all chemicals you use. Divide this figure by 2,000 to determine Total Tons/Year. Enter this figure in the “Grand Total Tons of Chemicals” space below the tables and in
the “Total Tons of All Regulated Chemcials Per Year” space on the “Air Emission Sources Inventory” worksheet.
When you have estimated your annual use of hazardous air pollutants, check off this action on the Checklist on page 2 and go on to the next action.
21
Product Name ________________________________________
Chemical Name
Ex amp l e: Ch emi c al " X"
Total Pounds of Product
Weight Percent
Total Pounds of Chemical
18,340 l b s .
0.4
7,336 l b s .
Column A
Total Pounds/Year
Total Tons/Year
Product Name ________________________________________
Chemical Name
Total Pounds of Product
Weight Percent
Total Pounds of Chemical
Column A
Total Pounds/Year
Total Tons/Year
Product Name ________________________________________
Chemical Name
Total Pounds of Product
Weight Percent
Total Pounds of Chemical
Total Pounds/Year
Total Tons/Year
Grand Total Tons of Chemicals: ___________________________________
22
Column A
DETERMINE AIR EMISSION SOURCE STATUS
Air Emissions: ___________ tons per year
Enter the total estimated tons of regulated chemicals that you calculated on the previous
pages in the above space. Use this number to figure out what type of air emission source
your business is classified as. The total quantity typically reflects the total amount of HAPs
emitted annually. That’s because many HAPs are also found on the Halogenated Cleaning
Solvents and TRI lists.
Major Source
Your business is considered a “major source” of air emissions if your processes emit or have
the potential to emit*:
• 10 tons (20,000 lbs.) or more of any one chemical on the list of 189 HAPs, or
• 25 tons (50,000 lbs.) or more of any combination of chemicals on the list of 189
HAPs, or
• More than 100 tons (150,000 lbs.) of all Volatile Organic Compound (VOC) emissions. Check with your local or state air pollution control agency to determine what
additional chemicals, other than those you inventoried, are considered VOCs. Most
small businesses, however, do not use enough chemicals to exceed this threshold.
See Appendix B: Contacts List.
Area Source
An “area source” of air emissions are facilities that emit regulated air pollutants below the
threshold levels of major sources.
As is discussed on the following page under “Identify Requirements for Using Regulated
Chemicals,” attaining “area” source status or using equipment and process materials that
contain non-regulated materials have the fewest requirements. If you find you are a major
source and are using regulated chemicals, you will want to reduce your annual usage and
find alternative process materials. By achieving these reductions you can enjoy the less burdensome requirements. This can be accomplished by reviewing and implementing best
management practices and pollution prevention opportunities.
* Potential to emit is the maximum amount of air pollutant your facility can emit if 1. each
process unit is operated at 100 percent of its physical and operational design capacity; 2.
materials that emit the most air pollution are used 100 percent of the time; 3. all of the equipment is operating 24 hours per day, 365 days per year; and 4. no pollution control equipment
is used.
23
Following is just one of these opportunities, which can eliminate or reduce the use of regulated chemicals.
Use less toxic cleaners that have low air emissions
Work with your vendor to find less toxic substitutes to your solvent cleaners (surface
preparation, parts washers, equipment cleaning). When you begin testing alternatives,
follow manufacturer instructions carefully because the new product may need a different
working approach than your old cleaning solution required.
When you have determined your air emission source status, check off this action on the Checklist
on page 2 and go on to the next action. For help determining your air emission source status,
refer to Appendix B: Contacts List.
The next action item in this workbook explores some of the general requirements associated
with your classification as a source of air emissions. Again, this workbook does not include
information on local regulations. Local authorities such as solid waste districts, county health
departments, air pollution control agencies, and sewage treatment districts may have additional environmental requirements. Refer to you telephone directory to find out who to call.
IDENTIFY REQUIREMENTS
FOR USING REGULATED CHEMICALS
There are two ways your facility can be regulated for using hazardous air pollutants in your
processes. One is to regulate (usually by a permit or registration process) the entire facility
because of the chemicals it uses; and a second is by regulating specific equipment and processes (i.e. using halogenated solvents in parts washers).
This section points out several of these major regulations that affect industrial sectors. However, if your facility is in an area with a local air pollution control agency (such as the Puget
Sound area), you may have additional requirements and should contact the local agency to
find out. (See Appendix B: Contacts List for local air authority contacts.)
HAPs
Major Sources
As a major source of air emissions, your business faces a much more stringent and complicated set of rules. The permit and/or registration systems and the National Emission Standards for Hazardous Air Pollutants (NESHAP) for industrial sectors and processes, which are
associated with being a major source, are difficult to cover in the context of this informational
24
guide. If you have determined your status is that of a major source, refer to Appendix B:
Contacts List to find out who to call in your state for more information.
Area Sources
Each state and local air quality authority may have rules and standards placed on area
sources. Over the next several years, the EPA is expected to tighten the air quality rules to
include non-major sources of air pollution. By understanding your air emission sources and
quantities of regulated chemicals that you use, you will immediately know how you fit into the
regulatory framework as rules are developed. Any business located in a designated ozone
non-attainment area should refer to Appendix B: Contacts List because special standards may
apply.
Note: In Oregon, businesses emitting more than 10 tons of non-hazardous VOC emissions are required to
operate under a state air permit. Other states and local air authorities also may have a registration system
for businesses that have VOC emissions.
Halogenated Solvent Cleaning
All facilities that operate any size solvent cleaning equipment (solvent immersion or stand-up
parts washer) using any of the following solvents — methylene chloride, tetrachloroethylene
(also known as perchloroethylene), trichloroethylene, 1,1,1 trichloroethane, carbon tetrachloride or chloroform — are affected by the NESHAP Halogenated Solvent Cleaning regulation.
If you use these chemicals in solvent cleaning machinery you have several compliance options
(see Figure 2 below).
Figure 2: Options for Complying with Cleaning Equipment NESHAP
DIP TANK
PARTS WASHER
(Immersion Batch Cold
Cleaning Equipment)
(Remote Reservoir Batch Cold
Cleaning Equipment)
Required Controls
Option 1
1. Install a cover.
2. Achieve 1-inch
water layer.
3. No work practices
required.
Required Controls
Option 2
1. Install a cover.
2. Maintain a freeboard ratio
of 0.75 or greater.
3. Work practices required.
1. Install a cover.
2. Work practices required.
Work Practices
1. Store solvent waste in closed
containers.
2. Flush parts in freeboard area.
3. Reduce pooling of solvent on and in
parts.
4. Do not fill cleaning equipment above
fill line.
5. Clean solvent spills immediately.
6. Store wipe rags in closed containers.
7. Do not agitate solvent to the point of
causing splashing.
8. When cover is open, control room
drafts.
9. Do not clean absorbent materials.
TRI
See Appendix E: Other Federal and State Regulations for a discussion on the Emergency Planning
and Community Right-to-Know Act (EPCRA).
When you have identified the requirements for using hazardous air pollutants, check off this action
on the Checklist on page 2 and go on to Chapter 4: Understanding Water Pollution Sources.
25
CHAPTER 4.
UNDERSTANDING WATER POLLUTION SOURCES
UNDERSTAND RESPONSIBILITIES AND REQUIREMENTS
FOR MANAGING WATER POLLUTION SOURCES
Wastewater
Many industries typically discharge wastewater to a publicly owned treatment works (POTW).
It is important for operators to know where the wastewater from their shop is going, and to
minimize pollution going “down the drain.” In addition, POTWs are not equipped to treat
all types of industrial wastes (e.g., some solvents can pass through a POTW without being
removed or treated). There are three typical sources of water pollution from industrial
operations:
1) Process water discharges. Process water often contains metals, oils and greases,
acids, suspended solids and many other contaminants. Industrial discharges
should meet local, state or federal discharge limits for these contaminants.
2) Coatings or solvents can be a problem if dumped down the drain. Do not dump
solvents into any drains, regardless of whether they discharge to a sanitary sewer or
a septic system, because such disposal is usually prohibited by state and local regulations.
3) Materials discharged to floor drains or storm sewers. Storm sewers often flow
directly into rivers or streams without treatment. Remove any inks, chemicals, oils,
etc., before wet rinsing areas that have open floor drains. You can minimize the
potential for any unintended releases to the sewer system by putting removable,
sealed covers on your floor drains.
Take the following steps to determine whether your water wastes meet sewer discharge limits
in your area. For each water pollution source identified on your “Water Pollution Sources
Inventory” worksheet, enter “yes” or “no” in the column “Determined to Meet Sewer Discharge Limits” on the worksheet. If unsure, you may need to have a “water test” done for
each water pollution source in question.
Step 1: Determine if wastewater is hazardous — The one fail-safe way to determine if your
wastewater is considered hazardous is to have a laboratory test the wastewater. Refer to your
local telephone directory to find a laboratory, or see Appendix B: Contacts List to find out who
to call in your area. Testing the wastewater before discharge allows you to see which chemicals, and their concentrations, are found in the wastewater. After you have determined the
concentrations of certain chemicals in the wastewater, you can compare those with the limits
set by your local sewerage agency (refer to your telephone directory to find out who to call).
26
If the wastewater is determined to meet sewer discharge limits, remember to record “yes” on
your “Water Pollution Sources Inventory” worksheet.
Step 2: Estimate quantity generated — Regardless of the waste quantity you generate, your
waste water must be treated as a hazardous waste if it does not meet your local sewer agency’s
discharge limits. In that case, it cannot be discharged to the sewer, storm drains or in any
other way that would expose the environment to the wastes.
Step 3: Identify requirements — A permit may be required depending on the area your
business resides in and the discharge limits set at the local level. Consult your local sewerage
agency to determine what requirements apply.
Stormwater
In addition to wastewater discharges, industry should be concerned about stormwater discharges. You can reduce the potential for stormwater contamination at your property by
storing raw materials and wastes indoors. If there is no potential for contaminating
stormwater on your facility’s grounds, then you are not required to obtain a permit. However, you should apply for a stormwater permit if there is the possibility that stormwater,
rainfall, or snow melt water will come in contact with: material handling equipment or activities, raw materials, intermediate products, final products, waste materials, by products or
industrial machinery that have the potential of contaminating stormwater. Refer to your
telephone directory to find the local agency that handles stormwater permitting.
If you have questions about your responsibilities and requirements for having water pollution
sources, refer to Appendix B: Contacts List to find out who to call in your state.
Once you understand the responsibilities and requirements for having water pollution sources,
check off the actions on the Checklist on page 2.
Having completed Chapters 1-4, you should now understand your hazardous wastes, air
emission sources and water pollution sources. Refer to Appendix E: Other Federal and State
Regulations to be sure you understand all of the environmental requirements associated with
the wastes you identified. You now have the knowledge to consider eliminating or reducing
waste streams by implementing best management practices and pollution prevention
opportunitites.
27
APPENDIX A.
INTERNET RESOURCES
Enviro$en$e
Enviro$en$e is a free, public, integrated environmental information system. It is
designed to: assist users in finding and implementing common-sense solutions,
such as pollution prevention, to environmental problems; facilitate the sharing of
technology, procedures and experience across federal agencies, other governmental organizations, manufacturers, suppliers, researchers and others; and encourage
the development and demonstration of pollution prevention technologies.
Enviro$en$e can link you to most requests for information on the environment and
the pollution prevention opportunities and technologies that would benefit your
business.
http://es.epa.gov
Pacific Northwest Pollution Prevention Resource Center Web Site
Information on this web site will benefit industry representatives, technical assistance providers, researchers, funders of pollution prevention activities and others.
For example, industry representatives and technical assistance providers can use it
to obtain general information on cutting-edge approaches to environmental problems, and to identify professionals with technical expertise in specific areas.
http://www.pprc.org/pprc
Office of Air Quality Planning and Standards - Technology Transfer Network
This network provides information and technical support on air pollution control.
Its four divisions - Air Quality Management, Emission Standards, Technical Support, and Stationary Source Compliance - provide services to EPA regional offices,
state and local agencies, consultants, industry and the general public. These services include clearinghouses, conferences, reports, manuals, newsletters, support
centers, workshops, classroom training, self-instructional courses and Technology
Transfer Network (TTN). The TTN is one of the most useful bulletin boards to
find information on Clean Air Act specifics, and new rules and regulations that may
impact your business. These are the rules that regulators browse through, and you
should take advantage of acquiring that same knowledge.
http://www.epa.gov/ttn
U.S. Environmental Protection Agency
This Web site hosts information and contacts for promulgated federal regulations,
state and local authorities, available publications, and other resources.
http://www.epa.gov/
Oregon Department of Environmental Quality Directory
This Web site is a directory of contacts in the different media programs -- air quality, water quality, hazardous waste, etc. Once you get to this page, scroll down to
the appropriate program you want information on and link directly to that page.
http://www.deq.state.or.us:80/
Alaska Compliance Assistance Office
This Web site gives contacts for compliance assistance with Alaska's environmental
regulations. The Compliance Assistance Office helps businesses, communities,
government agencies and the general public to maintain environmental quality and
achieve greater compliance with environmental regulations.
http://www.state.ak.us/local/akpages/ENV.CONSERV/
Washington Department of Ecology
This Web site is dedicated to providing contacts for the different local air authorities. This page lists the contacts by the county that the agency has direct authority
over. The Air Quality Business Assistance Program serves many industries that
have air quality impacts, and information is available through these air quality
authority contacts.
http://www.wa.gov/ecology/
EPA Fact Sheets on Regulated Toxic Chemicals
This page contains links to EPA fact sheets for every regulated toxic chemical.
http://mail.odsnet.com/TRIFacts/
Hazardous Chemical Database
This database will allow the user to retrieve information by key-word search for any
of 2,000 hazardous chemicals.
http://ull.chemistry.uakron.edu/erd/
Material Safety Data Sheet(s)
This Web site provides links to many other sites that have MSDS databases and
other health and environmental information.
http://www.lib.iastate.edu:80/agnic/msds.html
Oxford MSDS Database
This Web site’s home page is an Index of Material Safety Data Sheets in alphabetical order. The user can select the first letter of the particular chemical for which he
or she is searching, and then select the appropriate chemical from the list that is
presented.
http://physchem.ox.ac.uk:80/MSDS/
APPENDIX B.
CONTACTS LIST
Alaska Department of Environmental Conservation
Small Business Compliance Assistance Office
Scott Lytle: 907-269-7571
Compliance Assistance Office - Pollution Prevention Division
David Wigglesworth: 907-269-7582
Idaho Division of Environmental Quality
Small Business Assistance Program
Doug McRoberts: 208-373-0497
Pollution Prevention Program
North Idaho Regional Office: 208-769-1422
North Central Regional Office: 208-799-4370
Eastern Regional Office: 208-528-2650
Southwest Regional Office: 208-373-0550
South Central Regional Office: 208-736-2190
Southeast Regional Office: 208-236-6160
Oregon Department of Environmental Quality
Small Business Assistance Program
Terry Obteshka: 503-229-6147
Waste Reduction Assistance Program
Northwest Regional Office
Kevin Masterson: 503-229-5615
Karen Whisler: 503-229-6191
Renei Nomora: 503-229-5564
Salem Office
Bart Collinsworth: 503-378-8240 ext. 253
Dave Rozell: 503-378-8240 ext. 258
Roseburg Office
David Livengood: 541-440-3338 ext. 230
Bend Office
John MacKeller: 541-388-6146 ext. 229
Pendleton Office
Marie Zuroske: 541-278-4622
Washington Department of Ecology
Small Business Assistance Program
Bernard Brady: 360-407-6803
Leighton Pratt, Small Business Ombudsman: 360-407-7018
Department of Ecology Regional Offices
Chelan, Douglas, Kittitas, Klickitat, Okanogan counties - Ecology Central Regional
Office
509-575-2490
San Juan County - Ecology Northwest Regional Office
425-649-7000
Adams, Asotin, Columbia, Ferry, Franklin, Garfield, Grant, Lincoln, Pend Oreille,
Spokane, Stevens, Walla Walla, Whitman counties - Ecology Eastern Regional
Office
509-456-3114
Hazardous Waste and Toxics Reduction Program
Northwest Regional Office, Bellevue: 425-649-7000
Southwest Regional Office, Lacey: 360-407-6300
Central Regional Office, Yakima: 509-575-2490
Eastern Regional Office, Spokane: 509-456-2926
Permit Assistance Center
This program helps you map out your permit strategy over the phone or in person.
Specifically the center can: help orient you to the realm of environmental permitting; advise you on which local, state and federal permits may apply; identify key
contacts at government agencies; help you estimate how much time and effort
you’ll spend obtaining permits; and help you avoid potential time, money and
regulatory traps. Contact the Permit Assistance Center by:
Phone: 360-407-7037
Fax: 360-407-6904
E-mail: ecypac@ecy.wa.gov
In person: 300 Desmond Drive S.E., Lacey, Washington
Local Air Quality Agencies in Washington
King, Kitsap, Pierce, Snohomish counties - Puget Sound Air Pollution Control
Agency
206-343-8800 or 1-800-552-3565
Clallam, Grays Harbor, Jefferson, Mason, Pacific, Thurston counties - Olympic Air
Pollution Control Authority
360-438-8768 or 1-800-422-5623
Island, Skagit, Whatcom counties - Northwest Air Pollution Authority
360-428-1617
Clark, Cowlitz, Lewis, Skamania, Wahkiakum counties - Southwest Air Pollution
Control Authority
360-694-5006, ext. 13
Spokane County - Spokane County Air Pollution Control Authority
509-456-4727
Yakima County - Yakima County Clean Air Authority
509-574-1410
Benton County - Benton County Clean Air Authority
509-943-3396
Regional Resources
Pacific Northwest Pollution Prevention Resource Center (PPRC)
The PPRC is a non-profit organization that devotes much effort to relationshipbuilding among federal and state governmental agencies, industry representatives,
environmental organizations, the academic community and others. Its central
contributions are in making high-quality information available to decision-makers
to help them identify productive new pathways, identifying research needs by
evaluating opportunities for and barriers to the implementation of pollution prevention, and catalyzing projects that address those needs. Contact the PPRC by
calling 206-223-1151, or visit its Web site at: http://www.pprc.org/pprc.
APPENDIX C.
WEEKLY FACILITY INSPECTION CHECKLIST
Performing weekly hazardous waste inspections is one of the simplest ways you can protect your facility from a leak or spill, as well as meet new container regulations. If done
correctly, your effort will prevent potential releases to the environment before they occur,
ensure that wastes are identified properly, and see that wastes are shipped off-site before
your accumulation time is up. Make copies of this Checklist for each week in the year and
keep them for record.
WEEKLY INSPECTION CHECKLIST
Inspection for the week of _________ to _________
ACCUMULATION
_____ Are all drums and containers marked with a hazardous waste label?
_____ Are all drums and containers marked with a risk label, if appropriate?
_____ Are all drums marked with the accumulation start date?
_____ Are there any drums that are near or have exceeded the 90/180 day timeframe?
_____ Are all drums marked with the proper waste code(s)?
_____ Are all containers closed?
_____ Are all drum labels visible and readable?
_____ Are all drums and containers in good condition?
_____ Are there 30 inches of aisle space between rows of containers?
_____ Are any drums leaking?
SUMPS
_____ Are sumps clean and free of contamination, spills, leaks and standing water?
SAFETY EQUIPMENT
_____ Are fire extinguishers charged?
_____ Are spill kits stocked?
_____ Is the first aid cabinet stocked?
_____ Is the emergency shower and eye wash station functioning properly?
_____ Are the emergency communication devices operating properly?
_____ Is emergency response information posted near all communication devices?
SECONDARY CONTAINMENT
_____ Is the secondary containment free of cracks or other failures?
COMMENTS
Describe the actions that you took to correct the deficiencies noted above, and the date the actions were
taken
______________________________________________________________________________________________
______________________________________________________________________________________________
Printed Name _______________________________ Signature ________________________________
Date_______________ Time ______________
APPENDIX D.
LIST OF HAZARDOUS AIR POLLUTANTS
CAS #
75070
60355
75058
98862
53963
107028
79061
79107
107131
8107051
92671
62533
90040
1332214
71432
92875
98077
100447
92524
117817
542881
75252
106990
156627
105602
133062
63252
75150
56235
463581
120809
133904
57749
7782505
79118
532274
108907
510156
67663
107302
126998
19773
95487
108394
106445
98828
94757
3547044
334883
132649
96128
84742
106467
91941
111444
542756
62737
111422
121697
64675
119904
60117
119937
79447
Chemical Name
CAS #
68122
57147
131113
77781
534521
51285
121142
123911
122667
106898
Acetaldehyde
Acetamide
Acetonitrile
Acetophenone
2-Acetylaminofluorene
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Allyl chloride
4-Aminobiphenyl
106887
Aniline
140885
o-Anisidine
100414
Asbestos
51796
Benzene (including from gasoline)
75003
Benzidine
106934
Benzotrichloride
107062
Benzyl chloride
Biphenyl
Bis (2-ethylhexyl) phthalate (DEHP) 107211
151564
Bis(chloromethyl) ether
75218
Bromoform
96457
1,3-Butadiene
75343
Calcium cyanamide
Caprolactam
50000
Captan
76448
Carbaryl
118741
Carbon disulfide
87683
Carbon tetrachloride
77474
Carbonyl sulfide
67721
Catechol
822060
Chloramben
680319
Chlordane
110543
Chlorine
302012
Chloroacetic acid
7647010
2-Chloroacetophenone
7664393
Chlorobenzene
123319
Chlorobenzilate
78591
Chloroform
58899
Chloromethyl methyl ether
108316
Chloroprene
67561
Cresols/Cresylic acid (isomers and
72435
mixture)
74839
0-Cresol
74873
m-Cresol
71556
p-Cresol
Cumene
78933
2,4-D, salts and esters
60344
DDE
74884
Diazomethane
108101
Dibenzofurans
624839
1,2-Dibromo-3-chloropropane
80626
Dibutylphthalate
1634044
1,4-Dichlorobenzene(p)
101144
3,3'-Dichlorobenzidene
75092
Dichloroethyl ether
101688
(Bis(2chloroethyl)ether)
101779
1,3-Dichloropropene
91203
Dichlorvos
98953
Diethanolamine
92933
N,N-Diethyl aniline
100027
(N,N-Dimethylaniline)
79469
Diethyl sulfate
684935
3,3-Dimethoxybenzidine
62759
Dimethyl aminoazobenzene
59892
3,3-Dimethylbenzidine
56382
Dimethyl carbamoyl chloride
Chemical Name
Dimethyl formamide
1,1 Dimethylhydrazine
Dimethyl phthalate
Dimethyl sulfate
4,6-Dinitro-o-cresol, and salts
2,4-Dinitrophenol
2,4-Dinitrotoluene
1,4-Dioxane (1,4-Diethyleneoxide)
1,2-Diphenylhydrazine
Epichlorohydrin
(l-Chloro-2,3-epoxypropane)
1,2-Epoxybutane
Ethyl acrylate
Ethyl benzene
Ethyl carbamate (Urethane)
Ethyl chloride (Chloroethane)
Ethyl enedibromide (Dibromoethane)
Ethyl enedichloride
(1,2-Dichloroethane)
Ethylene glycol
Ethyleneimine (Aziridine)
Ethylene oxide
Ethylene thiourea
Ethylidene dichloride
(1,1-Dichloroethane)
Formaldehyde
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexamethylene-1,6-diisocyanate
Hexamethylphosphoramide
Hexane
Hydrazine
Hydrochloric acid
Hydrogen fluoride (Hydrofluoric acid)
Hydroquinone
Isophorone
Lindane (all isomers)
Maleic anhydride
Methanol
Methoxychlor
Methyl bromide (Bromomethane)
Methyl chloride (Chloromethane)
Methyl chloroform
(1,1,1-Trichloroethane)
Methyl ethyl ketone (2-Butanone)
Methyl hydrazine
Methyl iodide (Iodomethane)
Methyl isobutyl ketone (Hexone)
Methyl isocyanate
Methyl methacrylate
Methyl tert butyl ether
4,4-Methylene bis (2-chloroaniline)
Methylene chloride (Dichloromethane)
Methylene diphenyl diisocyanate (MDI)
4,4'-Methylenedianiline
Naphthalene
Nitrobenzene
4-Nitrobiphenyl
4-Nitrophenol
2-Nitropropane
N-Nitroso-N-methylurea
N-Nitrosodimethylamine
N-Nitrosomorpholine
Parathion
CAS #
82688
87865
108952
106503
75445
7803512
7723140
85449
1336363
1120714
57578
123386
114261
78875
75569
75558
91225
106514
100425
96093
1746016
79345
127184
7550450
108883
95807
584849
95534
8001352
120821
79005
79016
95954
88062
121448
1582098
540841
108054
593602
75014
75354
1330207
95476
108383
106423
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Chemical Name
Pentachloronitrobenzene
(Quintobenzene)
Pentachlorophenol
Phenol
p-Phenylenediamine
Phosgene
Phosphine
Phosphorus
Phthalic anhydride
Polychlorinated biphenyls (Aroclors)
1,3-Propane sultone
beta-Propiolactone
Propionaldehyde
Propoxur (Baygon)
Propylene dichloride
(1,2-Dichloropropane)
Propylene oxide
1,2-Propylenimine
(2-Methyl aziridine)
Quinoline
Quinone
Styrene
Styrene oxide
2,3,7,8-Tetrachlorodibenzo-p-dioxin
1,1,2,2-Tetrachloroethane
Tetrachloroethylene
(Perchloroethylene)
Titanium tetrachloride
Toluene
2,4-Toluene diamine
2,4-Toluene diisocyanate
o-Toluidine
Toxaphene (chlorinated camphene)
1,2,4-Trichlorobenzene
1,1,2-Trichloroethane
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Triethylamine
Trifluralin
2,2,4-Trimethylpentane
Vinyl acetate
Vinyl bromide
Vinyl chloride
Vinylidene chloride
(1,1-Dichloroethylene)
Xylenes (isomers and mixture)
o-Xylenes
m-Xylenes
p-Xylenes
Antimony compounds
Arsenic compounds (inorganic,
including arsine)
Beryllium compounds
Cadmium compounds
Chromium compounds
Cobalt compounds
Coke oven emissions
Cyanide compounds
Glycol ethers
Lead compounds
Manganese compounds
Mercury compounds
Mineral fibers
Nickel compounds
Polycyclic organic matter
Radionuclides (including radon)
Selenium compounds
APPENDIX E.
OTHER FEDERAL AND STATE REGULATIONS
Community Right-to-Know
If you calculated 10,000 pounds or more annual usage of any of the TRI-listed
chemicals or other hazardous substances, you may have a responsibility to report
those chemicals. This report is required by July 1 of each year for the chemical(s)
used in the previous calendar year.
Clean Water Act (CWA)
The primary goal of the CWA is to protect, restore and maintain the chemical,
physical and biological integrity of the waters of the United States. One interim
goal of the act is to return the nation’s water to conditions deemed “fishable and
swimmable.” All discharges into the waters of the United States, publicly owned
treatment works, stormwater discharges, and storm sewers are covered under this
act. Direct discharge to any surface water requires a National Pollutant Discharge
Elimination System (NPDES) permit.
Discharge to a publicly owned treatment works (POTW) does not require a NPDES
permit, but will require an industrial user permit which is issued by the local water
treatment operator. At this time, no categorical pre-treatment standards exist for
the commercial printing industry. All printing facilities are required to meet the
general pre-treatment standards for discharge of process wastewater. The general
pre-treatment requirements prohibit the following: 1) pollutants that create a fire
hazard in the POTW; 2) pollutants that will cause corrosive damage to the POTW;
3) pollutants (solid or viscous) in amounts that will obstruct flow in the POTW; 4)
any pollutant released at a flow rate or concentration that interferes with the
POTW operations (this includes oxygen-demanding pollutants); 5) effluents at a
temperature that will inhibit biological activity in the POTW; 6) petroleum oils,
non-biodegradable cutting fluid, or mineral oil products which will pass through
the POTW or interfere with performance of chemicals in the POTW; 7) pollutants
that result in toxic fumes within the POTW; and 8) any trucked or hauled pollutants. Facilities also areo required to notify the POTW within 24 hours if any violation of pre-treatment requirements occur. Often, state or local governments have
additional reporting requirements, which should be addressed before discharge.
Often, a NPDES permit is required even if no wastewater is produced on-site. If
any stormwater comes into contact with industrial activity or construction activity, a
permit will be necessary. This contact includes any handling equipment or activities, raw materials, intermediate products, final products, or industrial machinery
exposed to stormwater that drains to a storm sewer system or directly to receiving
waters. Note that a stormwater permit is not required for municipal systems that
have combined wastewater and stormwater systems, but the POTW should be
informed that industrial stormwater will be entering the sewers.
Occupational Safety and Health Administration Act
Under OSHA, employers (regardless of size) are required to meet several standards
that will maintain a safe and healthful workplace. The “general duty clause” of
OSHA states that “a place of employment which is free from recognized hazards
that are causing or are likely to cause death or serious physical harm” must be
provided to the employee. Section 1910.1200 of OSHA is the hazard communication standard and requires employers to inventory, classify and label all chemical
substances on-site that are considered to be “hazardous” to health or have physical
properties that are hazardous. All employers must have a written program available to employees that includes inspection, inventory, labeling, availability of material safety data sheets, employee training, agency reporting and record-keeping
systems. Employers of fewer than 10 people may be exempt from the recordkeeping systems only. Several states have their own OSHA regulations, and it will
therefore be necessary for facilities to contact their state agency to find their requirements.
Superfund (Comprehensive Environmental Response, Compensation and Liability Act) (CERCLA) &
Superfund Amendments and Reauthorization Act (SARA)
Under the original Superfund, the EPA was authorized to undertake any measures
necessary to address any hazard to human health and the environment triggered
by burning, leaking or explosion of hazardous substances, contamination of food
chains, or drinking water contamination.
Toxic Substances Control Act (TSCA)
Under TSCA, the EPA is given the authority to limit or prohibit the manufacture,
processing, distribution or disposal of a chemical substance which EPA has determined poses a risk to human health or the environment. EPA also will gather
information on all risks associated with toxicity of all new and existing chemicals.
Section 4 is the authorization for the EPA to require testing of chemical substances
or mixtures the agency determines could be a risk to human health or the environment. Section 5 grants the EPA the right to test all new chemical substances to
determine their toxicity and subsequent risk 90 days before manufacturing, processing or importing of said chemical. Section 6 is the official notification that the
EPA may regulate the manufacture, processing, distribution in commerce, and the
use and disposal of any chemical substance determined to be toxic. Section 8 is the
requirement for all users and manufacturers to keep records and submit reports to
the EPA.