NEWS & VIEWS

STORMWATER REMINDERS

PERMITS: Facility owner/operators are reminded that EPA revised the regulations requiring permits for construction. Any construction site that disturbs more than one acre of land requires a stormwater permit. The permit requires a detailed management plan to minimize the effects of stormwater runoff. Recent fines for stormwater construction permit violations have ranged from $7,000. to $41,000.

SAMPLING: Any stormwater permit holders whose permits mandate rainfall event sampling are reminded that this is an effective time of year to fulfill this important requirement before the dry days of summer arrive. Even if your current Ohio general permit has yet to be renewed, you must maintain compliance with the terms and conditions of your original permit.


EPA TO TEST NEW ASBESTOS REMOVAL METHOD

U.S.EPA announced plans regarding an alternative asbestos-removal method for older buildings to be demolished. The long-established asbestos removal standards are within the National Emissions Standards for Hazardous Air Pollutants (NESHAP). The new method is to be tested this spring at a remote site in Arkansas, and will involve the removal of the most friable asbestos-containing materials (ACM) before demolition, while leaving other ACM in place. EPA intends the use of water containing agents on the remaining ACM as a means of trapping asbestos fibers and preventing their release to ambient air. Extensive air monitoring is planned as part of the experiment.


EPA PROPOSES REGULATING LEAD IN HOME RENOVATIONS

The U.S.EPA proposed new standards in January of this year that would require contractors working on homes built before 1978 to follow work practices designed to limit the release of lead from lead-based painted items. Work activities include removing paint and wallpaper or replacing windows. The contractors would be responsible to minimize exposures to lead by posting warning signs, sealing off work areas, and using high efficiency vacuums. EPA estimated that the new rule would cost the renovations industry about $5 million dollars per year to meet compliance. For the latest news, see EPA’s website at www.epa.gov/lead.


HAZARDOUS WASTE EMPLOYEE TRAINING

Large Quantity Generators (LQG) in Ohio know that regulations in OAC 3745-16 and 65 through 69 require that they provide hazardous waste training for all employees whose jobs are involved with the hazardous waste at their facility. A frequent question asked of CTI by LQGs is whether someone in their facility is qualified to perform the training. Here is how Ohio EPA answers that question:

• The person instructing must be trained in hazardous waste management to ensure compliance with all aspects of the regulations cited above;
• The instructor may possess the knowledge and experience through coursework and/or on-the-job experience with any/all of the rules applicable to the facility;
• The instructor must develop the training to be specific to the facility according to work, waste types, and waste toxicity;
• The instructor must teach their personnel waste management procedures relevant to each person’s position;
• The instructor must design the training to ensure workers are able to respond to emergencies and implement the company contingency plan;
• The instructor must receive annual refresher training and document that refresher training is completed at their facility.

CTI provides effective hazardous waste training because its personnel meet all of these criteria, and because it creates a class that is specific to its client’s waste management program. Having expert training supplied is both cost effective and a superior risk management tool. Contact CTI’s Customer Service representative to receive more information about our hazardous waste training program.


SOLVENT CONTAMINTAED RAGS AND WIPERS

The Ohio EPA’s Division of Hazardous Waste Management (DHWM) has changed a policy on the management of solvent-contaminated rags and wipers. In that policy, rags or wipers that are contaminated with a solvent constituent that is a listed hazardous waste solvent (F001 through F005) must be regulated as a listed hazardous waste when disposed of regardless of how the solvent got on the rag or wiper.

As part of a periodic policy review on February 14, 2006, the DHWM concluded that solvent-contaminated rags and wipers which are contaminated with listed solvent constituents are not to be considered listed hazardous waste, except in situations were the rag or wiper is used to clean up a spill of a used solvent that is a listed hazardous waste. These rags or wipers remain a listed hazardous waste.

If your facility generates solvent-contaminated rags or wipers and does not have them laundered, you still need to evaluate this wastestream. Prior to disposal, determine whether they are characteristic or listed hazardous wastes for purposes of storage, transportation, and disposal.


MEK REMOVED FROM AIR TOXICS LIST

REMINDER: U.S. EPA removed methyl ethyl ketone (MEK) from the list of chemicals subject to reporting under Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) in a Final Rule dated June 30, 2005. Therefore, usage and release of MEK is no longer required to be reported for the annual Toxic Release Inventory (TRI) Reports beginning in the 2005 reporting year.


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