See Also
How
to Determine If Your Waste is Hazardous
Pollution
Prevention
How you can reduce
waste at home and at work
Environmental
Assistance for Small Businesses
Contact DEQ
State
Office
Waste Management and Remediation
Division, Hazardous Waste Program
Mike Gregory
(208) 373-0297
Regional Office
Waste Management and Remediation Managers
|
 |
Hazardous Waste in Idaho:
Sump Waste Management
|
|
| Background |
Under
the federal Resource and Recovery Act (RCRA) which Idaho has adopted
by reference into state rules and regulations, every business in
Idaho is required to track the volume of wastes generated, determine
whether or not each is hazardous, and ensure that all wastes are
properly disposed of according to federal, state and local requirements.
Sump waste is covered
by this requirement. A sump is a pit or tank that catches liquid
runoff for drainage or disposal. Owners and/or operators of facilities
where sumps are in operation must be able to demonstrate they have
adequately determined if the contents of the sumps are hazardous
prior to shipping the sump waste offsite for disposal. |
| |
| What is Sump Waste? |
Sump
waste is the mixture of dirt, grime, and grit that accumulates in
a sump. Sump waste is considered solid waste and may be hazardous,
depending on its content.
The content
of waste collected in a sump depends upon the type of business that
is using the device. For example, car wash residue and material
washed in the floors of vehicle maintenance shops differs from waste
that is placed in floor sumps in manufacturing plants. |
| |
| How Can I Tell if My Sump Waste
is Hazardous? |
| Regulations
allow the determination whether sump waste is hazardous to be made
through knowledge of process, chemical analysis, or a combination
of both. |
| |
Knowledge
of Process |
|
In some cases, generator knowledge of the process or materials that
produced the waste may be used to document that hazardous wastes
have not entered the pump. With many listed wastes, generator knowledge
is appropriate because the physical/chemical makeup of the waste
is generally well known and consistent from facility to facility.
For example,
facilities that limit the type of use (i.e. washing of new or used
cars) and access (i.e. company cars only) to the sump may be able
to show that no hazardous constituents/wastes are used in the processes
that discharge or drain into the sump, thereby establishing that
the sump contains no hazardous wastes.
Note: Although knowledge of process is
less costly than chemical analysis, you must be able to ensure that
this information accurately reflects the current processes and materials
being used. If you use generator knowledge alone or in conjunction
with sampling and analysis, you must maintain detailed documentation
that clearly demonstrates the information is sufficient.
|
| |
Chemical
Analysis |
| If
the sump is associated with engine washing or degreasing processes,
used oil or used antifreeze spills or disposal, or the use or spilling
of hazardous chemicals/ materials, or is located in an area where
there are no controls on who has access to the sump, the "knowledge
of process" non-hazardous determination is not allowed. In
this case, a sample of the sump waste may have to be submitted to
a laboratory for chemical analysis.
Chemical
analysis is generally used for determination of hazardous waste
characteristics including the following:
- flash point to determine ignitability;
- pH - to determine corrosivity; and,
- Toxicity Characteristic Leaching Procedure
(TCLP) to determine toxicity.
If pesticides
are associated with the sump, a pesticide scan test also is required.
Preliminary
screening tests, which tend to be less expensive, may be used as
part of the determination. If the results reveal concentrations
of total metal(s) in excess of TCLP levels, however, additional
samples and analyses for the TCLP level of the specific metals involved
may be necessary to determine if the sump waste is hazardous. |
| |
| How Often Do I Need to Test? |
| Facilities
that do not change processes and continue to control access may
only need to test the sump waste one time.
Facilities
that restrict access by design to only private vehicles (as opposed
to commercial trucks), for example, may need to test the sump waste
periodically, perhaps once a year.
Facilities
that do not restrict access, such as public car washes, or are involved
with truck washing where cargo holds are washed, need to test the
sump waste each time prior to removal and disposal.
All analytical
results must be kept on file at the facility for at least three
years; it is recommended that records be keep on file indefinitely. |
| |
| Where Do I Dispose of Sump Waste? |
Nonhazardous |
| If
the sump waste is nonhazardous, it may be disposed of in a Municipal
Solid Waste Landfill (MSWLF). However, prior to disposal at the
MSWLF, all nonhazardous sump waste must pass the paint filter test
(Method 9095) to determine whether free liquids exist in the waste.
For more information on testing methods, link to EPA
publication SW-846, entitled Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods.
Some MSWLFs do not allow
sludges to be dumped unless the Total Petroleum Hydrocarbon (TPH)
level is tested and is found to be below 1,000 parts per million
(ppm). This is a local requirement and not part of the state and
federal hazardous waste regulations. Check with the specific MSWLF
you plan to use. If the test is required, it can be done at the
same time as the test for hazardous constituents. Additionally,
sump wastes that are not hazardous but contain significant levels
of TPH should not be placed on the ground, since the waste may cause
surface or ground water contamination. |
| |
Hazardous |
| If the
sump waste is determined to be a regulated hazardous waste, the
facility must count the spent solvent toward to the facility's generator
status. Click here for more information on how
to determine your generator status. If the sump waste is determined
to be hazardous and the generator of the waste is a Small
Quantity Generator or a Large Quantity
Generator, the waste must be disposed of in a permitted hazardous
waste Treatment,
Storage, and Disposal facility (TSD).
Contact DEQ for the location
of a TSD facility near you. |
|
|
