Both the State and Federal Environmental Agencies have regulations concerning the management of used oil and other maintenance - related materials. These agencies are the Environmental Protection Agency (EPA) and the Florida Department of Environmental Protection (DEP). The intent of these regulations is to establish a comprehensive program for the proper management and recycling of used oil and other maintenance - related items. This is a summary of those regulations and should serve as a guideline for all maintenance and repair shops located at the University of Florida.

There are specific regulatory requirements for individuals who generate and accumulate waste:

1. Minimize and recycle.

2. Properly label and identify.

3. Properly contain and dispose of the waste.

The purpose of this document is to assist shops with this regulatory compliance. Every shop on campus is subject to unannounced inspections by both the Federal Environmental Protection Agency (EPA) and the Florida Department of Environmental Protection (DEP). Lack of compliance can result in citations and fines.

The regulatory requirements covered in this document include:

· Determination of a “waste” as a material that has no intended use or reuse.

· Proper labeling of the waste.

· Proper accumulation and disposal of the waste.

The following are waste streams that are commonly generated at maintenance shops:

1. Used Oil

The term “Used Oil” is a broad category and includes motor oil, vacuum pump oil, synthetic oils, transmission and brake fluids, lubricating greases, etc.

· Used oil does not include products derived from vegetable or animal fat.

· Used oil is prohibited from going to the landfill.

· EH&S must perform a hazardous waste determination on each oil waste stream to find out if it should be classified as hazardous. If the used oil stream is determined to be hazardous, then the oil must be handled as a hazardous waste and EH&S must dispose of it. The main reason for an oil stream to be classified as hazardous is through its contact with solvents (such as brake cleaners and paints) or heavy metals.

· If the used oil is determined not to be hazardous, it may be sent to a recycling center or to EH&S for disposal.

“Oily wastes” are also covered under these regulations. Oily wastes are defined as “those materials, which are mixed with used oil and have become separated from that used oil.” This includes oil that has been mixed with “kitty litter,” absorbent clay and organic absorbent material. These materials (with the exception of rags and paper towels) may be landfilled provided that:

· the amount generated is a small amount.

· it is the result of minor leaks or spills from a normal process operation.

· all free-flowing oil has been removed to the practical extent possible.

Large quantities of oily wastes, generated as a result of a major spill or in lieu of proper maintenance of the processing equipment, must have a hazardous waste determination performed prior to disposal. Contact EH&S at 392-8400 to have a hazardous waste determination performed. EH&S strongly recommends that this type of waste be minimized through good housekeeping practices.

Oily rags must be picked up by EH&S or sent to a rag cleaning service.

Storage of Used Oil:

· Generators must store used oil in appropriate containers such as DOT approved drums or tanks that are dedicated solely for the storage of used oil.

· Container size must be less than or equal to 30 gallons.

· Each container must be labeled with the words “Used Oil” and all containers must be maintained in good condition.

· If tanks or containers are not double-walled, they shall be stored on an oil-impermeable surface such as sealed concrete or asphalt, and must have secondary containment which has the capacity to hold 110% of the volume of the largest tank or container within the containment area. (62-710.401 F.A.C. Specific Authority 403.061, 403.704 FS. Law Implemented 403.751 FS. History –New 6-9-05.)

· Storage containers and secondary containment must be protected from weather.

· Any leak or spill must be contained and cleaned up, and the container repaired or replaced.

· Containers must be kept CLOSED at all times.

Shipments of Used Oil:

· Generators must ensure that their used oil is transported only by transporters who have a current Used Oil Transporter Certificate of Approval issued by the Department of Environmental Protection.

· In order for a transporter to receive the Certificate of Approval, they must have a DEP/EPA identification number and a used oil training program, and will have demonstrated minimal insurance coverage.

· Contact EH&S at 392-8400 to get the names of approved transporters.

2. Used Oil-Filters

Commercially generated used oil-filters are banned from landfill disposal. A registered used oil-filter processor must process the filters.

· Used oil-filters must be stored in above ground containers, which are in good condition and are clearly labeled “Used Oil-Filters”.

· The storage containers must be protected from weather, have a lid and stored on an oil impermeable surface.

3. Antifreeze

Improper disposal of antifreeze is an environmental concern for everyone. Unused antifreeze is not considered a hazardous waste, however, antifreeze will be classified as a hazardous waste if there is contact with heavy metals or organics such as brake or transmission fluid, carburetor cleaner, or other solvents. Containers must be labeled with the words “Used Antifreeze,” and a hazardous waste determination must be performed on each source of used antifreeze. Antifreeze containers must stay closed.

The State encourages the proper recycling of waste antifreeze. There are waste antifreeze service companies that will service and recycle your antifreeze. Copies of all notices, certifications, waste analysis data and other documentation must be retained for five years from the date that the waste was sent to a recycling facility or to EH&S’s Waste Management Facility. Contact EH&S at 392-8400 to get a list of vendors for recycling antifreeze.

4. Batteries

· Alkaline batteries can be disposed of in the trash.

Large Storage Batteries (Auto, Marine, etc.) must be taken to Hazardous Waste Management Facility (Bldg 831) in the Surge Area. . Deliveries can be made every Monday, Wednesday and Friday between 8 and 9 AM.

· All other batteries which contain hazardous metals such as mercury, lead, silver, lithium and cadmium must also be handled by EH&S

5. Light Bulbs

Fluorescent, Mercury Vapor, High Pressure Sodium and High Intensity Discharge (HID) bulbs contain mercury and must be recycled and delivered to EH&S’s Waste Management Facility, Building 831. Deliveries can be made every Monday, Wednesday and Friday between 8 and 9 AM.

6. Light Bulb Ballasts

Only ballasts that say “non-PCB” can be disposed in the landfill. If there is no writing on the ballast (pre-1976) or they are known to contain PCB’s then EH&S must dispose of them. The ballasts can be delivered to Bldg. 831 every Monday, Wednesday and Friday between 8 and 9 AM.

7. Smoke Detectors

Some smoke detectors contain radioactive material. A label on the back or side of the detector will alert you to the presence of a radiation source. Depending on the type of detector and the amount of radioactivity in the source, it may be necessary to dispose of these detectors at a licensed radioactive waste disposal facility. The detectors must be intact for disposal. Some smoke detectors containing radioactive materials may be exempt from these disposal requirements. Contact EH&S at 392-8400 to determine if your smoke detectors are exempt or regulated prior to disposing them.

It is recommended that detectors, which do not contain radioactive materials be used, if they are appropriate for your application, to avoid disposal costs, which may exceed the purchase price of the detector.

8. Paints, Solvents and Acids

Paints:

EH&S recycles latex paint, contact EH&S for the disposal of any latex paint.

· If the paint in the can is completely dry, it may be disposed of in the trash.

· Dried rags and paintbrushes that are contaminated with latex-based paints may be placed in the trash.

· The rinsate water from the cleaning of rags and brushes contaminated with latex paints must be disposed of in a drain that goes directly to the wastewater treatment plant.

Other paints generally meet the definition of hazardous waste and must be disposed of by EH&S.

· Paint cans that once contained non-latex paints must meet the definition of empty before they can be placed in the trash. This is achieved by scraping the container to ensure that all pourable materials have been removed. The pourable material must be collected for disposal by EH&S.

· No more than 55 gallons of hazardous waste (non-latex paint, solvent, acids, paint rags and brushes) can be kept in an accumulation area. If your area is close to exceeding 55 gallons, mail a Chemical Waste Pickup Request Form immediately.

· Each container of hazardous waste must stay closed and no funnel can remain in the container.

· The containment area must stay cleaned.

· The funnels should be cleaned out occasionally.

· Containers and drums can be obtained by calling EH&S at 392-8400.

· A Hazardous Waste Label must be on every container.

Solvents and Acids:

Solvents (including thinners, degreasers, etc.) and acids can not be put in the trash or sink.

· Once these solvents or acids are no longer usable, the liquid must be placed in a container (preferably the original container) and be handled as a hazardous waste.

· A Hazardous Waste Label must be on every container.

· Do not mix acids, bases or solvents together. They should each have their own separate container.

· Common acids include; muriatic acid, sulfuric acid and nitric acid.

9. Non-Latex Paint Rags and Brushes

Brushes and rags that have been contaminated with hazardous waste (non-latex paints, cleaners, thinners, strippers, etc.) can not be placed in the trash.

· Since these rags and brushes are flammable, it is best to place them together in a metal can that is designed to prevent spontaneous combustion.

· Information on these special containers can be given by calling EH&S at 392-8400.

· A Hazardous Waste Label must be placed on the container.

· When the container is full, mail in the Chemical Waste Pickup Request Form to EH&S.

· Each container of hazardous waste must stay closed.

10. Aerosol Cans

Only empty aerosol cans can be placed in the trash.

· Aerosol cans that are not empty must be accumulated in a container or drum and picked up by EH&S.

· The container or drum must have a Hazardous Waste Label on it.

· Once the container is full, mail in a Chemical Waste Pickup Request Form and mail it to EH&S.

11. Labels and Chemical Waste Pickups:

Place a yellow Hazardous Waste Label on every container of hazardous waste. These labels are available free of charge by calling the EH&S at 392-8400 and requesting Form # EHS-CWLBL.

All containers of waste must have a label on the container identifying the contents.

When a waste pickup is needed, a Chemical Waste Pickup Request Form must be mailed to EH&S Building 831; P. O. Box 112725. This form is available free of charge by calling the Waste Management Facility at 392-8400 and requesting Form # EH&S/RSA-1.

12. Accumulation Requirements:

· Do not accumulate more than 55 gallons of waste at any one time.

· Keep all containers closed.

· Containers must be provided with secondary containment.

· Keep containment area clean and protected from the weather.

· Do not allow any accumulation of water or liquid on the top of the container.

· All waste containers must have a label identifying the contents.

· No un-approved waste in sink or trash.

· Do not overfill containers; leave at least 1 inch of headspace.

· Keep liquid and solid waste streams separate.

· Keep a spill kit within easy access for all shop personnel.

13. Safety Precautions:

· Do not mix incompatibles (ex. Acids/bases, flammables/oxidizers, reactives)

· Do not bring cleaning materials from home.

· Wear personal protective equipment.

14. Waste Minimization:

Waste minimization is any action that reduces the amount and/or toxicity of wastes that must be shipped off-site for disposal. There are three methods of waste minimization.

1. Source Reduction:

The most desirable method of waste minimization is source reduction. This is any activity that reduces or eliminates the generation of waste at the source. This can be accomplished by good materials management, substitution of less hazardous materials and good shop operating procedures. The following are some examples:

· Implement a waste minimization policy and train all employees.

· Make a commitment to reducing waste in all areas of the shop.

· Evaluate the wastes being generated and identify areas where changes can be made.

· Encourage employee participation through education, training and incentives.

· Evaluate procedures to see if a less hazardous or non-hazardous materials could be substituted.

· Centralize purchasing of material through one person in the department.

· Minimize inventory and use a first-in, first-out system.

· Keep MSDS’s for chemicals on file.

· Inventory materials and identify their location at least once a year.

· Update inventory when materials are purchased or used up.

· Purchase chemicals in the smallest quantities needed.

· Label all containers to prevent the generation of unknowns.

· Avoid the use of materials containing arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver.

· Substitute red liquid (spirit-filled), digital, or thermocouple thermometers for mercury thermometers when it is feasible.

· Consider using detergent and hot water for cleaning parts instead of solvents.

· Use latex-based paints because typically they are non-hazardous.

· Find a vendor that will recycle used antifreeze. Some vendors will recycle the antifreeze on site so the antifreeze never leaves the site.

· Use multi-purpose solvents to reduce the types of hazardous waste that needs to be managed.

2. Recycling:

The second most desirable approach is recycling. When a waste material is used for another purpose, treated and reused in the same process, or reclaimed for another process, this is called recycling. Following are examples:

· When solvent is used for cleaning purposes, use contaminated solvent for initial cleaning and fresh solvent for final cleaning.

· Purchase compressed gas cylinders (including lecture bottles) only from manufacturers who will accept empty cylinders.

· Return excess pesticides to the distributor.

· Do not contaminate used oil with solvents because this prevents the oil from being recycled.

· Recycle solvents.

3. Treatment:

The least preferable technique is treatment. The most common treatment is elementary neutralization. Check with EH&S (392-8400) to ensure safety and proper waste treatment.

INTRODUCTION 1. USED OIL

1. Used Oil

14. Waste Minimization:

INTRODUCTION
1. USED OIL