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Q & A - 2018 E2 Day
Answers provided by John White, FDEP (John.White@dep.state.fl.us)
Question: Do fluorescent tubes with the green end still have to be recycled or can they just be thrown away?
Answer: Any manufacturer can place a “green” end on a fluorescent tube lamp, there is no industry standard to require specifications that can be met. So, generators, transporters, and facilities managing or disposing of spent mercury-containing lamps or devices in a manner other than recycling as provided for under this chapter are not subject to the provisions of 62-737, F.A.C., but shall comply with 40 C.F.R. 262.11, hazardous waste determination, as adopted by reference under rule 62-730.160, F.A.C., and all other applicable Department and federal regulations including rules 62-737.300 and 62-701.300, F.A.C.
Question: Assume a County accepts a waste at the household hazardous waste (HHW) collection center. Since it is only HHW, is the county allowed to put the waste into Class I Landfill if necessary? (budget does not have enough money to pay for regulated HW disposal)
Answer: While the HHW centers were designed to keep hazardous waste out of the landfills, there is nothing preventing a County from disposing of the waste in the Class 1 landfill. One issue with this would be the waste would be concentrated in one area, versus spread out over a cell. Reactions between wastes could result in severe damage to the cell liner.
Question: Is there a time limit for how long waste can be stored at HHW collection center?
Answer: Household hazardous waste (HHW) is exempt from the hazardous waste regulations. So there is no time limit imposed by the RCRA regulations on this waste. However, solid waste transfer facility rules could be imposed if the waste is stored for an extended period. Also, the longer the waste is stored the greater the chance of a container failure, resulting in a threat to employees and the environment.
Question: Please explain further the rationale for requiring sampling when the concrete has seams/gaps if there is no evidence of a release.
Answer: Releases of hazardous waste are not always visible, especially over a period of many years. Solvents are clear liquids that easily pass through concrete. Seams or cracks in the concrete just enable faster transmittal of the fluid through the concrete to the soil below.
Question: Is using a building to meet secondary containment an option? Is it a violation if you have a used oil tank stored next to outer wall in a facility?
Answer: The question related to used oil. The state regulation in 62-710.401(6) is very specific, see language below. Following issuance of the rule, FDEP provided guidance to say that containers stored within a structure with an oil impermeable floor do not require secondary containment. The used oil containers must be stored away from doorways that could prevent a release from being adequately contained. The concern with walls if for those facilities that have sheet metal walls that overlap a concrete slab, leaving gaps along the base of the inside wall that would allow for immediate discharge of chemicals releases to the environment.
62-710.401(6), F.A.C. - No person may store used oil in tanks or containers unless they are clearly labeled with the words “used oil,” are in good condition (no severe rusting, apparent structural defects or deterioration), and not leaking (no visible leaks). If tanks or containers are not stored inside a structure, the contents shall be closed, covered or otherwise protected from the weather. 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. For underground storage tanks with capacities greater than 110 gallons and above ground storage tanks with capacities greater than 550 gallons, the facility shall comply with chapters 62-761 and 62-762, F.A.C.
Question: Any requirements for LED recycle?
Answer: The generator can either manage LED lamps as Universal Waste Lamps or make a waste determination under 40 CFR 262.11 and manage the waste based on the determination results.
Question: Can long lamps sit in a tall container until crushed weekly?
Answer: Lamps have to be placed in an appropriate container that is capable of holding the waste (preventing releases) and the container must be closed. If the “tall container” meets these requirements then it is acceptable.