SDI\/1S Document Yo-uTv-G STOCXI-1 & BOAVB
ATIORHCYS AT LAW £JCECUTIVE WOODS 103330 I Two PALISADES DBIVIE im AuBANY, NEW YORK 12205I •' * •,•••:':'',•;'••.•;.'.;•"•••'••;•••; •••.;'":•"'::• ,i,^i ^;-H^i^;^^•^•:^^ .;V"; " TELEPHONE: (Sie) 43e-«»07.;
Rudolph S. Perez//Es<^.;. ,0ffice-of Regional;;Counsel
Re: In re Mercurv Refining Co..(Docket #II-TSCA-PCB-92-0239) Gentlemen: Pursuant to the Order on Consent in the above-referenced matter, enclosed please find Mercury Refining Company's Report on PCB/Mercury Separation Process as required by Paragraph 4 of the Order on Consent.
Very truly yours.
ohn P. Stockli, Jr. Enclosure
cc: John Reagan (w/out enc)
031602.nd
700290 MERCURY REFINING COMPANT REPORT ON PCB/MERCURY SEPARATION PROCESS
In the matter of Mercury Refining Company, Inc. Docket No. II TSCA PCB-92-0239
•
700291 INTRODUCTION This report describes the oil and grease/mercury separation procedure designed by Mercury Refining Company, Inc. ("MERECO") to remove mercury from PCB-containing oil and grease ("retort liquid"). This process is necessary to reclaim mercury from the retort liquid, thus reducing mercury levels to a concentration that is acceptable for incineration at an off-site"treetment-storage end disposal facility.^ In accordance with the Order on Consent executed in the above-referenced matter, MERECO submits this written report requesting Environmental Protection Agency ("EPA") approval for this process. MERECO's experimental processing of this material in the manner described below has resulted in adequate separation of the mercury from the oil and grease. MERECO is confident that this procedure will be conducted safely and efficiently.
Project Background Close examination of the PCB-containing oil and grease reveals droplets of mercury clinging to the material. The concentration of mercury in this material is between 260 ppm and 1,200 ppm. During experimentation, MERECO observed that introducing ^ne oil and grease to hot water causes the grease to liquefy and!'^ release the mercury droplets. Due to the high specific gravity of mercury (13.59) and the insolubility of mercury in water, the droplets quickly fall and collect at the bottom of the container.
Analytical results of the oil and grease layer after mercury separation have shown the concentration of mercury in the grease at 146 ppm or less. The analytical data for this material is presented as Attachment I. Analytical results of the water phase during this experiment were all "non-detect" for PCBs. The analytical results for the water samples are shown as Attachment II. Process Description
The oil and grease/mercury separation process will be conducted on-site and take place in the same containers that are utilized for the accumulation and storage of the PCB material.
The separation procedure will be conducted in the Material Transfer Booth (MTB) and all testing and separation processes contained under a dedicated drum hood system The hood ventilation system is designed to remove organic and mercury vapors via dual carbon and HEPA filtration. The MTB is located within the Phase I
As MERECO has previously indicated during the course of this proceeding, due to the current levels of mercury in the retort liquid, commercial disposal facilities have refused to accept the materials for disposal unless MERECO conducts a separation process.
700292 -2-
building. The Phase I building is equipped with a secondary containment dike and a recirculating carbon filtration air ventilation system to prevent the release ,^f -cont^iminants to the environment. Because the separation process will be conducted one drum at a time, potential for any significant releases is further minimized.
The drum hood system consists of one 55-gallon 17-H open-head drum with hood, an immersion heater, and two product transfer ports. One product transfer port is located near the bottom of the drum and the second is located approximately half way down fron> the top of the drum. A schematic of the drum hood system is shown on' Figure 1.
The drum will be filled with water up to the level of the upper transfer port. The water will be heated via the immersion heater to a temperature slightly below the boiling point. Oil and grease will then be introduced into the drum forming a layer above the upper transfer port. Sufficient time is allowed for all the grease to thin and release the mercury droplets. The upper transfer port will then be opened to allow the oil and grease phase to gravity feed into a dedicated drum with a poly liner. Samples will be collected from this material for total mercury analysis to verify acceptance for incineration of the waste at <7JIfiIILi<^'^^ Wastfa ManagpjTnfn-i-y s Treatn-:ent, Storage and Disposal facility in Po;rt Art.hm-^ Tpxas. Mercury,'' that has settled from the emulsion will be recovered, purified and recycled, thus greatly reducing the amount of mercury ultiT.ately sent for disposal. Sajnples will be collected from the water layer for total mercury analysis. Water with mercury concentrations of 26 ppm or less will be transported to Dupont in Deepwater, New Jersey for disposal. '^^-i _
MERECO believes this process will safely and effectively facilitate the final disposition of the PCB waste.
Project Schedule This project will be conducted within 180 days after the effective date of EPA approval for this process.
022201.nd
700293 r i jK Nonn f-Esn Slreei y^vdirondack Albany, Ne-/v York 12207 = r>v«T:nmenij) S«r>'ce5. Inc. 516-13^-45^6/434-0891 FAX
A lull servicE analytical research laboratory oflering solutions lo environinental conctms
a.lENT: "Mercury'Refitiiiig Company Oat-e Sampied: -' -.08/13/92 CLIEiNT'S SA^[PLE ID: 92058 Date sample received: 08/1A/92 A£S sample S: 92081A J02 Samples taken by: R.L./B-W. Location: Albany NY MATRIX: Solid Sample grab
PAR.'^WETER PERFORMED METHOD RESULT UNITS NOTEBK REF TEST DAT
Mercury EPA-7471 146 ug/g SM-FAC-45 08/28/9
700294
rage SI-: Nonr, PES/I Sifee; y^vdirondack Albanv. Ne-A York 12207 518-434-J546/434-0891 FAX
A lull sendee analytical rtsearcti laboratory oflering solutions lo environmental concerns CHAIN OF CUSTODY RECORD
C-:tM"r .NAME SAMPLERS' (N«n.<|
/^-^uu*'^ ^jL/y^ycLcy-o 3- U/ACS^'^^*^-. «OOPCSS -no PO Nuween lUlD i^n.yyy a^ ^ TME SAMPt^rrPE NUMeEfl AES CLIE.'JT Aaajn. OF SAMPLE NUUBCP SAMPtE lOE-VTlFICJTlOW 1 LOCXTION SAMPtfO P.pjn. CXJNT-S ANALYSIS REQUIRED H c V.D51 / is^^ ct^-^^^ sinn^kl jmk ehh^ 7<^5. tM 4 f crrjit_~i4^ ^5 9^0 ski± L 1 f tHA L. HD. I * 6
Turnaround Time Laboratory Approval:
KelinqtrSped by: fs;qn«i.-««y / / / Received by: fSJ9n.b.r.j Date/Time
'relinquished by: .s;snjiar.) Received by: {Si,n*u«m) Date/Time
Relinquished by: ;s.«r..iur.( Received by: rs^Mcuraj Date/Time
Dispatched by: .s;jn.:u,., Date/Time.-—-Seceived for Laboratocv by j Date/Time V Method of Shipment: SfijvcTTieport To: Client Phone No.
The LaDoratory reserves ^he rignt :o return fiazaroous samples to the client or may levy a lee ol SIC 00 per container for disposal.
WHITE - Lab Copy ELLOW - Sampler Copy PINK - GenercXr Copy 700295 ATTACHMENT II
700296 314 iS'onfi Pjsri Siiee; Albsny. New Yorv 12207 518-434-4546/434-0891 FAX
A lull service analytical researtti laboratory oflering solutions to environmental concents
CLIENT: Mercury Refining Company Date Sanpled: 07/30/93 CLiZNT''S' S>r^Ll ID: ''SSllO Date sarrple received:- 07/30/93 AES sancle S: 930730AP01 Samples taken by: Kevin Allen Location: Albany NY MATRIX: liouid waste grab
P.^Ri'i^ETER PERFORMED METOOD RESULT. UNITS NOTEBK REF TEST DATE
PCS EPA-8080 KF-PCB-M44 08/02/93
Mercury EPA-245.1 13.0 ug/g PW-FAH-39 08/02/93
Page iraiffiny^if^o^SciS 700297 31- Nonh Ps2r! Siiee'. 'y^dirondsck Albany. NP-.V Yoik 122K 518-434-4546/434-0891 W
A lull service analytical research laboratory ottering solutions lo environmental concerns CHAIN OF CUSTODY RECORD
CUCNT NAME OJEC7 KAME fLot^lonl . . SAMPLERS' (H«m.tl nb ey^laZcl Ave
po NUMBEA/Uo^t\A-R / 17110 •PLfBfrp^Slfln.lurel \ y^ *^>/ lUlD ^ TME SAMPLE TYPE NUMBER AES CLIENT DATE Asajn. OF SAMPLE NUMBER SAMPLE lOENTIFK SAMPLED P«p.m. CONT-S ANALYSIS REOUIREO £L o { rgi;^(_fU iTcnjyplB V051 ^K^^ :fr.^^.^ ' S/nk^ I/^C in. T I & I'! IH- I Tumarouriround Time Laboratory Approval: Reiin d by: ,iiin.n,M; I ) \ Received by: (si^nMuf,, Date/Time l^ Relinquished by: •s:<:n,:! Received by: (sitn.fwi Date/Time Relinquished by: ,s.tr. Received by: rsJcMw*/ Date/Time Dispatched by: is;sr. Date/Time. ^—p-Gecetved ?or Laboratory by Date/Time L 'j^^ypzjy.y dy\\H: ) Method of Shioment: 5«»<*^eport To: Client Phone No.: The l_aboratory reserves 'she rignt to return haiarrious samples to the client or may levy a tee ot S10 00 per container lor disposal. •A'Hi.r • --2= Cccw YELLOW . Sampler Copy PINK - Generator Copy 700298 5T Nionri Pssri Siteei y^-^ d i r o n d a c k .Albsny, NcA- Yor/ 12207 516-434-4546/434-0891 FAX A lull service analytical researcJi laboratory oflering solutions lo environmenul concerns -CLIENi: Mercury Refining Company Date Sampled: 08/13/92 CLIENT'S SAMPLE ID: 92057 Date sample received: 08/14/92 .AiS ssmple =>: 92081^ JOl Samples taken by: R.L./B.W. Location: Albany NY MATRIX: liquid waste grab P.^JL^-YZTZR PERFOR.MED METHOD RESULT UNITS NOTEBK REP TEST DAT PC3 EPA-8080 <2 ug/g KS-L-7 08/27/9 EPA-7471 0.33 ug/g SM-FAC-45 08/2S/9 700299 Page 314 Nonr, her. Sim: C^sdirb'ndack" Albany, New York 1220; £,•*v*fon**^»nlJI S*rv«CTS. loft. 5I8-t34-4546/434-08Sl FAX A lull service analylical research laboratory oflerin? solulions to environmental concerns CHAIN OF CUSTODY RECORD CUCST SAME PROJECT NAME iVBCAflonl SAMPLERS' (NMMa) 2i. R*;lr«oi ft^£. '•^ o'cuC'^ teV'^iVvjo Co. rilpcr'i A^y '^''A A)\i»^ AOCKL5S I , » ^ •S.A C-LrrrTM Pud. PO NUMBER C->b»t A^V i;;sg< ''3;^4'b TBIE SAJ«>L£T>-Pe NUMBER A£S PJENT DATE A*a.jn. Of SAMPLf Nuueu SAMPLC lOENTinCATIOnoN>.*«tJ1io»N l >v SAMPLED P«p.in. cota*s AMAi.YSIS REOUIREO -t^^ l*:^, -Tr^lvw^ /-..• X C'-^'.l'V^-f^Cf)! 1-iiic i-c 7/3o/'i3 [tn>\ V^ A<^^ "i:"!' t-c " ^«"^ t «fr<-*•«•. :^. >/y/'& :: 1^^ ?" A;A "X^ \u r^r^ ^Ini.:^ - O^OCc^fi* 7/>/73 r .:•! I Turr.crounc Time Laboratory Approvai: 'he Lasoratcry reserves ifie fight to return hazardous samples to the client or may levy a fee of S10.00 per container tor disposal. •VKiTE . Lao Cooy YELLCV/ - Sampler Copy ?i?3X^ Generator Copy 700300 Mercury Hg"3 Refining 'y^ Connpany RECEIVEU INCORPORATED APR 0 ^ 1996 ApriU, 1996 Toxic Substances Section . Ms. Dorothy Zoledziowska US EPA Region 2 2890 Woodbridge Avenue (MS-105) Edison, NJ 08837 Re: Mercury Refining Company, Inc. (MERECO) Request for Approval of PCB/Mercury Separation Process Dear Ms. Zoledziowska: As per our telephone conversation on March 12, 1996, the following infonnation has been included with this letter: • Description of MERECO facility status, PCB background, and a description of the PCB/mercury separation project. • Copy of the Waste Analyses Plan contained in the MERECO Part 373 Hazardous • Waste Management Permit Application. • Summary table of laboratory analytical data associated with the PCB/mercury separation project. Facility Status MERECO is a commercial treatment, storage, and disposal facility (TSDF) and mercury reclamation facility. MERECO is currently operating under interim status under RCRA Subtitle C as a hazardous waste storage facility and is directly regulated by the New York State Department of Environmental Conservation, Region 4. The MERECO Part 373 Hazardous Waste Management Permit Application contains a Waste Characterization and Analysis Plan that describes waste pre-acceptance criteria, waste acceptance criteria, and analytical criteria for MERECO generated wastes. The Waste Analysis Plan is included as an attachment. The Part 373 Permit Application also contains a closure plan and MERECO maintains a letter of credit demonstrating financial security for facility closure. Primarily, MERECO reclaims mercury fi^om mercury bearing material (MBM) through retorting. The retorting process consists of heating the MBM in retort furnaces to approximately 1200 F. Mercury, water, and other volatile materials evaporate and are condensed and collected in ethylene glycol cooled condensers. The mercury collects at the bottom of the condenser collection vessel (due to the high specific gravity of mercury) 1218 CENTRAL AVENUE, ALBANY, NY 12205 • 800 833 3505 • Tel: 518 459 0820 • Fax: 518 459 2334 700301 and retort liquid (water with oil and grease) collects in the top of the vessel. The reclaimed mercury is purified and packaged for resale. Residual products (retort liquids • and solids) are packaged and transported off-site for treatment/disposal. PCB Background PCBs were used in a wide range of applications by industry until the production of PCBs ceased in 1977. PCB Aroclors 1242 and 1254 were used as plasticizers during plastic manufacturing until 1971. Several types of manufactured articles contained these plastics and mercury bearing components. During past operations, retort liquid was generated that contained PCBs greater than 50 ppm (specifically, Aroclors 1242 and 1254) and droplets of mercury. This mixture of mercury and PCBs could not be treated/disposed off-site without processing to remove the mercury. Several types of plastics were analyzed for PCBs and found to contain PCBs in low concentration (<10 PPM). MERECO believes the source of PCBs in the retort liquid is attributable to plastics with PCBs. MERECO has ceased retorting MBM with plastics containing PCBs. This has primarily been accomplished through removing plastics prior to retorting. Additionally, MERECO accepts wastes in accordance with the criteria established in the waste analysis plan. Further, the waste analysis plan provides procedures for PCB analysis of soils and other materials that are -sasibly contaminated with oil to ensure that no PCBs are present. The waste analysis plan contains procedures and a schedule to analyze MERECO generated wastes, including retort liquid. These procedures enable MERECO to screen the retort liquid for PCBs to ensure that no PCBs are being generated. MERECO uses a New York State Department of Health ELAP certified laboratory for all analyses. PCB/Mercury Separation MERECO entered a into consent order with EPA on February 2, 1994 that required MERECO to develop and implement a plan to separate the mercury and PCB mixture and properly dispose the PCBs. During 1994 and 1995 MERECO developed an EPA approved process to separate the mercury and PCB grease by means of a physical separation. The process consisted of melting the retort grease which releases the mercury, and then a physical separation of an aqueous phase from the retort grease. The process is further described in the report "Report on PCB/Mercury Separation Process". The EPA approval for the process specified that separation was to be conducted only for PCB material identified at the time of the consent order. The project was completed during 1995 and the PCB waste was disposed via TSCA incineration during October 1995. Analytical Summary Attached is an analytical summary of typical PCB material handled during the separation process. Total PCB and mercury concentrations are shown for grease and processed grease samples. Additionally, a break down of Aroclors is provided to show that the 700302 PCBs consisted of Aroclors 1242 and 1254. Laboratory reports are kept on file at the MERECO facility. Conclusion During 1994 and 1995, MERECO completed the PCB/mercury separation process and properly disposed the PCB waste that was on site. MERECO has developed waste screening and pre-processing procedures to prevent generation of PCBs during retorting. In the unlikely event that PCBs recur, MERECO is requesting approval to conduct the separation process to facilitate timely treatment/disposal of the retort liquid. We look forward to working with you on this project. If you have any questions or require additional information, please contact me at (518) 459-0820. Sincerely, Tohn F. Reagan Regulatory Affairs Manager enclosures 700303 TJIHI Mercury Refining Company, Inc. PCB Analytical Summary Sample ID Source Total PCBs Mercury Sample ID Source Total PCBs Mercury ppm ppm ppm ppm .95M0140 Grease 25,600 3,760 94M3250 Processed Grease 5,700 83 95M0155 Grease 290 375 94M3447 Processed Grease 610 33 94M3367 Grease 2,600 1,470 95M0165 Processed Grease 2,280 59 94l\/13334 Grease 370 275 95M0206 Processed Grease 4,300 75 95M0353 Grease 152 580 95M0265 Processed Grease 6,200 3.'^ 95M0155 Grease 290 375 95M0184 Processed Grease 1,030 129 95018 Grease 2,600 1,470 95M0245 Processed Grease 3,240 1/12 95026 Grease 152 580 95016 Grease 205 846 Sample ID Source Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Arodor 1248 Aroclor 1254 Aroclor 1260 ppm ppm ppm ppm ppm ppm ppm 94203 Grease ND ND ND 91 ND 190 ND 94204 Grease ND ND ND 600 ND 3,100 Mn 94205 Grease ND ND ND 420 ND 3,900 ^'^ 94206 Grease ND ND ND 640 ND 5,200 ND 94207 Grease ND ND ND ND ND 340 ND 94193 Grease ND ND ND 2,600 ND 3,100 ND 95009 Grease ND ND ND 65 ND 310 ND 95010 Grease ND ND ND 780 ND 1,500 ND 95011 Grease ND ND ND 460 ND 3,300 ND 95018 Grease ND ND ND 1,000 ND 1.600 ND ND = Not Detected NA = Not Available o o cu o pcbsum.WK3 SECTION C WASTE CHARACTERIZATION AND WASTE ANALYSIS PLAN MERCURY REFINING COMPANY, INC. 26 Railroad Avenue Albany, New York 12205 (518) 459-0820 EPA ID No. NYD048148175 7055f. 700305 TABLE OF CONTENT; 6 NYCRR Location in Subject Section Nos. Application SECTION r ^ WASTE CHARACTERIZATION AND WASTE ANALYSIS PLAN c- 1 C-1 Chemical and Physical Analysis 373-1.5(a) ( 2) ( ii) c- 1 373-2.2(e)(i) C-la Containers 373-2.9(c) c--15 C-2 Waste Analysis Plan 373-1.5(a)(2)(ii ) c-•17 C-2a Freacceptances Procedures c--18 C-2b Acceptance Procedures c--22 C-2c Parameters and Rationale 373-2.2(e)(2)(i) c--30 C-2d Test Methods 373-2.2(e)(2)(ii) c--31 C-2e Sampling Methods 373-2.2(e)(2)(iii) c--33 C-2f Frequency of Analysis 373-2.2(e)(2)(iv) c--38 C-2g Additional Requirements 373-2.2(e)(2)(v) c -40 for Wastes Generated 373-2.2(e)(3) Off-Site C-2h Additional Requirements 373-2.2(e)(2)(vi) C-41 for Facilities Handling 373-2.2(i) Ignitable, Reactive, and Incompatible Wastes Appendix A Correspondence from Regulatory Agenicies Regarding the Definition of Hazardous Waste Appendix B Characterization Data Provided by Mereco's Customers Through the Use of Generator Waste Profile Sheets Appendix C Instructions for Completing the Generator Waste Profile Sheet. Appendix D Standard Operating Procedures Appendix E Analytical Data on Wastes Generated by Mereco Appendix F Adirondack Environmental Services Inc. QA/QC Plan Appendix G Adirondock Environmental Services Inc. Statement of Qualifications Revision 3 178.3h 7283-001-600A March 1991 700306 LJ ST or TABLE? T;=il.Oe • Page C-l Designation of Reclaimed Secondary Materials C-3 C-7 C]assification of Incoming Reclaimable Materials C-4 C-? Chemical/Physical Analyses and Composition of Containerized Hazardous Waste Received by MERECO C-13 C-4 Chemical/Physical Analyses and Composition of Containerized Hazardous Wastes Generated aC MERECO C-16 C-5 Parameters and Rationale for Mercury Contaminated Wastes C-29 C-6 Parameters and Rationale for Hazardous Wastes Generated On-Site C-32 C-7 Parameters and Test Methods C-34 C-e Sampling Equipment C-35 C-9 Sampling Requirements and Holding Times C-37 Revised 1783h 7283-001-500A May 1990 700307 Li SI or FIGURES Fiqvjie Page '"- 1 Pr «?acceptance Procedures C-19 <:-?. Generator Waste Profile Sheet C-20 C-^ Acceptance Procedures C-23 C-4 Waste Receiving Checklist C-25 C-5 Example of Chain-of-Custody Record C-39 C-6 Waste Acceptance Letter C-42 Revised 1703h 72fi3-001-600A May 1990 700308 SECTION C WASTE CHARACTERIZATION AND WASTE ANALYSIS PLAN The objective of this docuinent is to describe the wastes handled at the MERECO facility and the procedures that will be undertaken to obtain sufficient waste information to operate hazardous waste management facilities in accordance with the requirements of New York State regulations 6 NYCRR Part 373 and Federal regulations 40 CFR Part 264^ This section has been subdivided into Sections C-1 and C-2. Section C-1 describes the function of the facility and the hazardous wastes managed at the facility. Section C-2 describes the procedures and analyses that will be used to identify and evaluate the hazardous wastes to assure their safe handling. C-1 CHEMICAL AND PHYSICAL ANALYSIS [373-1.5(a)(2)(ii), 373-2.2(e)(1)] MERECO operates one of the four NYSDEC-defined categories of recycling activities — reclamation. Defined as the recovery or regeneration of a useable product, MERECO reclaims metallic mercury and concentrates precious metals (primarily silver) from mercury and silver bearing secondary materials. The reclamation process is exempt from the 6 NYCRR 373 permit requirements. The facility used for storage of incoming hazardous waste and MERECO generated hazardous waste is subject to the 6 NYCRR 373 permit requirements for a hazardous waste storage facility. MERECO stores both hazardous and nonhazardous wastes in a 2,635 square-foot Container Storage Building. The building was constructed with an impervious base and has a design capacity with a volume equivalent to 888 drums. The building has C—1 Revision 2 May 1990 1784h.aEC 700309 a sump to collect spilled materials and has been constructed to eliminate run-on and run-off. Refer to Section D for engineering details of the storage facility. Materials, by definition (371.1(d)(1)), must be solid wastes in order to be classified hazardous wastes. The definition of solid waste was revised in the July 1, 1986 amendment to NYCRR 371. The regulations distinguish between recyclable materials which are solid waste and recyclable materials which are not solid waste. The distinction is based on both the type of recycling activity, of which reclamation is included, arid the type of material being recycled. The types of secondary materials regulated by 6 NYCRR Part 371 include spent materials, sludges, by-products, commercial chemical products and scrap metal. These types of materials include both "listed" materials (defined in 6 NYCRR 371.4 (b) and (c)) and "nonlisted" materials, including characteristic hazardous waste (defined in 6 NYCRR 371.3). The types of secondary materials recycled by MERECO, categorized consistent with the NYCRR definitions, are shown with the definition and regulatory status in Table C-1. Even though scrap metal, and household wastes are defined as solid wastes, both are currently exempt from regulation, 6 NYCRR 372.1(e)(2)(iv) and 371.1(e)(2)). Additionally, MERECO recycles the commercial chemical product form of mercury and mercury compounds. Thus, the only secondary materials reclaimed by MERECO which are regulated as hazardous wastes are characteristic spent materials, K071 and K106 wastes. MERECO will not accept K071 and K106 wastes for storage until such time as all applicable regulations have been ajnended to allow recycling of listed hazardous wastes without obtaining a permit. Table C-2 provides a listing of the waste materials received by MERECO and identifies the applicability of the regulations to these materials. Correspondence regarding the regulatory classification of wastes accepted by MERECO are provided in Appendix A. Definitions for some of the wastes listed in Table C-2 are presented below. C-2 Revision 6 August 1994 700310 Dental Caps - a two compartment plastic capsule containing metallic mercury in one compartment and silver alloy in the other. Used in the dental trade to prepare silver amalgam for the filling of cavities in teeth. C-2 a Revision 6 August 1994 700311 TABLE C-1 DESIGNATION OF RECLAIMED SECONDARY MATERIALS(1) Type of Material Definition Solid Waste Spent Materials (non-listed/ characteristic only) A Yes Sludges (non-listed/characteristic) B No By-Products (non-listed/characteristic) C No Commercial Chemical Products D No Scrap Metal E Yes* * Exempt from regulation by 6 NYCRR 372.1(e)(2)(iv) (1) From 6 NYCRR 371.1(b)(4) A. Spent Material: Material that has been used and as a result of contamination can no longer serve the purpose forii which it was produced without processing. ' B. Sludges: Residues from treating air or waste water, or other residues from pollution control operations. C. By-product: Material that is not one of the primary products of a production process and is not solely or separately produced by the production process. Examples are process residues such as slags or distillation column bottoms. The term does not include a coproduct that is produced for the general public's use and is ordinarily used in the same form as produced by the process. D. Commercial Chemical Products: Materials listed in 6 NYCRR 371.4 (d)(6). E. Scrap Metal: Bits and pieces of metal parts (e.g., bars, turnings, rods, sheets, wire) or metal pieces that may be combined together with bolts and soldering (e.g., radiators, scrap automobiles, railroad boxcars), which when worn or superfluous can be recycled. C-3 Revision 1 August 1994 1785h.red 700312 # TABLE C-2 CLASSIFICATION OF INCOMING RECLAIMABLE MATERIALS ' Regul.atory.Referenc^ incoming ••••••••••I New York State Federd iipiiiiiiiBi ^rnmmmmmmmmmmmmmmmmmmmm Material?, iiiiiiSeHifMlliiii L...W^te.Code mmmmm^mmmmmammmmmmmmm 6NYCRR 40 CFR.. 1 Alkaline Household N/A Exempt Household waste is a solid waste 371.1 (e) (2) (i) 261.4(b)(1) Batteries which is not a hazardous waste Alkaline Industries, D(X)2 Spent material classified as a solid 371.1 (c) (4) (iii) 261.2 (c) (3) Solutions Laboratories D004-D011 Hazardous waste when reclaimed - exhibits a Acidic characteristic; therefore a hazardous Solutions waste Brine Chlorine K071 Hazardous Usted wastes will not be accepted for 371.4(c) 261.32 Purification Muds Production storage until such time as the regulations have been modified to allow the recycling of hazardous wastes without a permit Dental Caps Manufacturers, D009 Hazardous Spent materials classified as a solid 371.1 (C) (4) (iii) 261.2(c)(3) (Whole Unused Dentists, Collectors D011 waste when reclaimed - exhibits a Capasules) characteristic; therefore a hazardous waste Dental Caps Manufacturer, U151 Exempt Commercial chemical product - U151 371.1 (c) (4) (iii) 261.2 (c) (3) (Half Capsules) Dentists, Collectors listed in 6 NYCRR 371.4(d)(6) - not a (metallic rnercury solid waste when reclaimed, therefore only) not a hazardous waste Dental Caps Manufacturers, N/A Predous Metal Hazardous wastes which are reclaimed 373-1.1 (d) (vii) (d 261.6 (a) (2) (iv) (Half Capasules Dentists, Collectors to recover economically significant silver alloy) amounts of gold, silver, platinum, unused palladium, iridium, osmium, rtiodum, ruthenium, or any combination of these "Empty" Mercury Industries, U151 Exempt Containeis which contained discarded 371.1 (c)(4) (iii) 261.33 Flasks Manufacturers commerdal chemical prockjcts (U151) are not a solid waste when reclaimed "Full" Mercury Industries, Ui51 Exempt Commercial chemical product - U151 371.1 (c)(4) (iii) 261.2(c)(3) Flasks Manufacturers listed in 6 NYCRR 371.4(d)(6) - not a solid waste when reclaimed, therefore not a hazardous waste Fluorescent Household N/A Exempt Household waste - it is a solid waste, 371.1(e) (2) (i) 261.4(b) (1) Tubes but not a hazardous waste Fluorescent Manufacturers N/A Exempt Manufacturing by-product (broken) 371.1 (c) (4) (iii) 261.2 (c) (3) Tubes exhibiting a characteristic - not a solid waste when reclaimed; therefore not a hazardous waste Revision 6 August 199-1 TABLE c-2 CUSSIFICATION OF INCOMING RECLAIMABLE MATERIALS ..R^u!alo.ry...R$ferences, Incoming New Yoi4< State Federal /l.ate.iials $Qun .Wgste.Cojjs^.^Jgg§iiJs^gE Jiationalg. Fluorescent Others D009 Hazardous Spent materials (assumed broken) - 371.1 (c)(4) (iii) 261.2 (c) (3) Tubes (Industries, classified as a solid waste when Commercial, etc.) reclaimed - exhibits a characteristic; therefore, a hazardous waste Gastrointestinal Hospitals, D009 Hazardous Spent materials (assumed broken) - 371.1 (c) (4) (iii) 261.2(c) (3) Tubes/Dialatois Manufacturers, classified as a solid waste when (Rubber Tubes) Medical Suppliers reclaimed - exhibits a characteristic; therefore, a hazardous waste Ignitron Tubes Industries D009 Hazardous Spent materials (assumed broken) - 371.1 (c)(4) (iii) 261.2(c) (3) classified as a solid waste when reclaimed - exhibits a characteristic; therefore, a hazardous waste Uthium Household N/A Exempt Household waste is a solid waste which 371.1 (e) (2) (i) 261.4 (b) (1) Batteries is not a hazardous waste Lithium Industries D003 Hazardous Spent materials - classified as a solid 371.1 (c)(4) (iii) 261.2(c) (3) Batteries waste when recycled in ways that differ from their normal use Mercuric Oxide Battery N/A Exempt Sludge from air pollution control 371.1 (c) (4) (iii) 261.2(c)(3) Dust Collector Manufacturers operations - sludge exhibits a Powders characteristic - not a solid waste when reclaimed; therefore, not a hazardous waste Mercuric Battery N/A Exempt Manufacturing by-ptoduct exhibiting a 371.1 (c)(4) (iii) 261.2(c) (3) Oxide Powder/ Manufacturers characteristic - not a solid waste when Pellets reclaimed; therefore, not a hazardous waste Mercuric Oxide Battery N/A Exempt Sludge from air pollution control 371.1 (c) (4) (iii) 261.2(c)(3) Silver Dust Manufacturers operations - sludge exhibits a Collector characteristic - not a solid waste when Powders reclaimed; therefore, not a hazardous waste Mercuric Battery N/A Exempt Manufacturing by-product exhibiting a 371.1 (c) (4) (iii) 261.2(c) (3) Oxide/Silver Manufacturers characteristic - not a solid waste when Oxide Roor reclaimed; therefore, not a hazardous Sweeping waste Mercury Battery N/A Exempt Manufacturing by-product (partially 371.1 (c) (4) (iii) 261.2(c)(3) Batteries Manufacturers assembled) exhibiting a characteristic - not a solid waste when reclaimed; therefore, not a hazardous waste W[JLEC-E 2 CLASSIFICATION OF INCOMING RECUIMABLE MATERIALS Reaulatoiy.JRefGrenoes Incoming New York State Federd IV!.aterf3|s j ^Mrm Wast^Code .0}33sitc3ti.Q.n RafiQn.ale. „ g.NYCBR... 4pCFR.... Mercury Military, D002 Hazardous Spent materials classified as a solid 371.1 (c)(4) (iii) 261.2(c)(3) Batteries Industries D009 waste when recycled in ways that differ Jused) from their normal use Mercury Military, N/A Exempt Commercial chemical product exhibiting 371.3 (e) 261.24 Batteries Industries a characteristic - not a solid waste when (unused) reclaimed; therefore, not a hazardous waste Mercury Household N/A Exempt Household waste is a solid waste which 371.1(e) (2) (i) 261.4 (b) (1) Batteries is not a hazardous waste Mercury Laboratories N/A Exempt Commercial chemical product exhibiting 371.1 (c) (4) (iii) 261.2 (c) (3) Compounds Industries, a characteristic - not a solid waste when (pure - not reclaimed; therefore, not a hazardous contaminated) waste Mercury Laboratories D001 Hazardous Spent materials classified as a solid 371.1 (c) (4) (iii) 261.2(c)(3) Compounds Industries, D002 waste when recycled in ways that differ (impure - D009 from their normal use contaminated) Mercury Spill D004 Hazardous Soils contaminated with mercury as a 371.1 (c) (4) (iii) 261.2 (c) (3) Contaminated cleanups D011* result of spills or remediation - exhibits Soils (dirt, site a characteristic; therefore a hazardous gravel, leaves, remediations waste etc.) Mercury Industries, D004 Hazardous Spent materials classified as a solid 371.1 (c)(4) (iii) 261.2(c)(3) Contaminated laboratories, D011* waste when reclaimed - exhibits a Materials clean-up characteristic; thereforeahazardous (clothing, operations waste vacuum oil, equipment, dirt, etc.)^ Mercury Spill Industries, U151 Exempt Clean-up of a commercial chemical 371.1 (c)(4) (iii) 261.2(c)(3) Kit Laboratories product - U151 - listed in 6 NYCRR 371.4(d) (6) - not a solid waste when, reclaimed, therefore not a hazardous waste Mercury Fluorescent D009 Hazardous Spent materials classified as a solid waste 371.1 (c) (4) (iii) 261.2(c)(3) j Contaminated Lamp Mfg., when reclaimed - exhibits a characteristic; Vacuum Industries, therefore, a hazardous waste Pump Oil Other • TABLE C-2 CLASSIFICATION OF INCOMING RECLAIMABLE MATERIALS Rdaulatory.Roferences ' Incoming New York State Federal MateriEds .$.9.u.rce W^te.Qpclft Clagsificatjon .- „ Ratjoii.al.e 6 NYCRR 4Q.CFR ; Mercury Industries, D009 Hazardous Spent materials classified as a solid waste 371.1(c) (4) (iii) 261.2(c) (3) Devices Laboratories when reclaimed - exhibits a characteristic; Utilities therefore, a hazardous waste Mercury Industries, D009 Hazardous Spent materials classified as a solid waste 371.1 (c) (4) (iii) 261.2(c)(3) Manometers Laboratories when reclaimed - exhibits a characteristic; therefore, a hazardous waste Mercury Pressure Industries, D009 Hazardous Spent materials classified as a solid waste 371.1 (c) (4) (iii) 261.2(c)(3) Regulators when reclaimed - exhibits a characteristic; therefore, a hazardous waste Mercury Manufacturers N/A Exempt Manufacturing by-products (broken, 371.1 (c)(4) (iii) 261.2(c)(3) Switches partially assembled) exhibiting a characteristic - not a solid waste when reclaimed; therefore, not a hazardous waste Mercury Others D009 Hazardous Spent materials classified as a solid waste 371.1 (c) (4) (iii) 261.2(c) (3) Switches when reclaimed - exhibits a characteristic; therefore, a hazardous waste Mercury Manufacturers N/A Exempt Manufacturing by-products (broken) 371.1 (c) (4) (iii) 261.2 (c) (3) Thermometers exhibiting a characteristic - not a solid . waste when reclaimed; therefore, not a hazardous waste Mercury Others; D009 Hazardous Spent materials (assumed broken)- 371.1 (c) (4) (iii) 261.2(c)(3) Thermometers Hospitals, etc. classified as a solid waste when reclaimed - exhibits a characteristic; therefore, a hazardous waste Mercury Vapor Manufacturers N/A Exempt Manufacturing by-products (broken) 371.1 (c) (4) (iii) 261.2(c) (3) Lamps exhibiting a characteristic - not a solid waste when reclaimed; therefore, not a hazardous waste Mercury Vapor Others; D009 Hazardous Spent materials (assumed broken)- 371.1 (c) (4) (iii) 261.2(c)(3) Lamps Industriies classified as a solid waste when reclaimed - exhibits a characteristic; o therefore, a hazardous waste o Exempt Manufacturing by-products (broken) 371.1 (c) (4) (iii) 261.2(c)(3) CO Mercury Wetted Manufacturers N/A l-» Relays exhibiting a characteristic - not a solid at waste when reclaimed; therefore, not a hazardous waste ^RTABLl E C-2 CLASSIFICATION OF INCOMING RECLAIMABLE MATERIALS 1 Regulator y...R6ferences iiiiiiiiiiliii New Vorit State Federi^ siiiiiiriiliii $.Qurc0 ...... Wasfe.Cocje. .C?}s3|s,ifi,c9ti Mercury Wetted Utilities D009 Hazardous Spent materials (assumed broken)- 371.1 (c) (4) (iii) 261.2(c)(3) Relays Industries classified as a solid waste when reclaimed - exhibits a characteristic; therefore, a hazardous waste Metallic 1 U151 Exempt Off-spec commercial chemical product 371.1 (c) (4) (Iii) 261.2(c) (3) Mercury (U151) listed in 6 NYCRR 371.4 (d) (6) not (pure) a solid waste when reclaimed; therefore, not a hazardous Waste Metallic 1 D009 Hazardous Spent materials classified as a solid waste 371.1 (c) (4) (iii) 261.2 (c) (3) Mercury when reclaimed - exhibits a characteristic; (impure) therefore, a hazardous waste Miscellaneous 2 D001 Hazardous Spent materials classified as a solid waste 371.1 (c) (4) (iii) 261.2 (c) (3) Mercury D009 when reclaimed - exhibits a characteristic; contaminated therefore, a hazardous waste 1 materials Nickel-Cadmium Household N/A Exempt Household waste is a solid waste which 371.1(e) (2) (i) 261.4 (b) (1) Batteries is not a hazardous waste Nickel-Cadmium Industry D006 Hazardous Spent materials classified as a solid waste 371.1 (c)(4) (iii) 261.2 (c) (3) Batteries when reclaimed - exhibits a characteristic; therefore, a hazardous waste Pacemakers Manufacturers N/A Predous Metal Hazardous waste which are reclaimed to 373-1.1 (d)(vii)(d; 261.6 (a) (2) (iv) recover economically significant amounts of gold, silver, platinum, palladium, iridium, osmium, rtiodium, mthenium, or any combination of these Silver Amalgam Collectors, N/A Precious Metal Hazardous waste which are reclaimed to 373-1.1 (d)(vii)(d; 261.6 (a) (2) (iv) Dentists, olher recover economically significant amounts Refiners of gold, silver, platinum, palladium, iridium, osmium, rtiodum, ruthenium, or any comtiination of these Silver Batteries Battery D011 Hazardous Spent materials classified as a solid waste 371.1 (c) (4) (iii) 261.2 (c) (3) Manufacturer when reclaimed - exhibits a characteristic; therefore, a hazardous waste Silver Batteries Household N/A Exempt Household waste is a solid waste which 371.1 (e) (2) (i) 261.4 (b) (1) is not a hazardous waste Silver Batteries Industries D011 Hazardcjus Spent materials classified as a solid waste 371.3(e) 261.24 when reclaimed - exhibits a characteristic; therefore, a hazardous waste TABLE C-2 CUSS,nCAT,ON OP ,^^OM,NG RKUIMABLE MATERS =J2M^^ L-...^.,..^,. ...Regulatory. References Silver Industries -§§^1^=:..=.....^ Compounds N/A Exempt '—iW08„J^^^Pj;pp^ (pure) Laboratories a cITaS.?"'^''"' P^°'"^^ ^'O^'biting a charactenstic - not a solid waste when |371.1 (c)(4) (iii) 261.2(c)(3) ^ilveT red«: therefore, not a hazardous Industries" TDOOT Compounds Laboratories iirnpure) D011 Silver Dust lattery" ;Mien reclaimed - exhibits acharfcteSic- p1^ll^H4niiiH 261:2 Tcflsj Collector N/A -gH^Iore^^hazardouswaste ' Manufacturer Powders ^'"<^9e fronTSr^diOtbrr^^mfd operations - sludge exhibits a pf^nsn4r(irp^ ^iiveTDuir characteristic - not a solid waste when ^Jewelers N/A Collector ^fGdousl/ietar Powders Recover economically significant amou I '^^^^^^^ndr^iir(d] 26TX(i)T2T(Tv) of gold, silver, platinum, palladium iridium osmium, rtiodium, ruthenium, orTi^y ' ?^^^t^Witei^ [Chi^ri?^ TKioe' .combination^fjhese Treatment Sludge Production Hazardous Tom the Mercury storage until such time as the regulatLns 371.4(c) 261.32' cell process in have been modified to allow the recySnn of chlorine hazardous wastes without a pemi? ^ IproAjc^on^ rZinc Amalgam Battery N/A Manufacturer T Exempt charactenstic - not a solid waste when 371.1 (c) (4r(iii) ^^:2'(EH3)' [2nc~Carbofr ^ouseholdT ^^auned; therefore, not a hazard^s 1 Batteries N/A [Exempt" * MERFrn,.«,,.,. UlJiOLaiiazaEdouIS not a hazardous waste 261.4 (b)(1j~ o o customer to be an exempt U151 u> ** Not radioactive !-• 00 o Fluorescrent Tubes - a glass lamp containing a few cirops of metallic mercury v/hich conc3ucts the electric current when the lamp is turned on. o Gastrointestinal Tubes/Dialators (Rubber tubes) - a rubber tube containing metallic mercury used in hospitals for alimentary canal exploration. o Mercuric Oxide Powder/Pellets/Battery Manufactures - off-specification mercury battery ingredients from battery manufacturers. o Mercuric Oxide/Silver Oxide Floor Sweeping/Battezry Manufacturers - floor clean-up from battery manufacturers involved in producing mercury and silver batteries. o Mercury Batteries/Battery Manufacturers - partially assembled and quality control rejected button size mercuric oxide from battery manufacturers. o Mercury Manometers - a gas pressure measuring device containing metallic mercury in a glass U-tube as the measuring medium. o Mercury Pressure Regulators - a "natural gas" pressure reducing device used by gas utilities. A small metallic mercury column is utilized as the pressure regulating control. o Mercury Switches/Manufacturers - a glass ampule containing metallic mercury which makes and breaks connections between electrical conductors. Broken and quality control rejects from mercury switch manufacturers. C-9 700319 Mercury Thermometers/Manufacturers - a glass temperature measuring device containing a column of metallic mercury as the measuring medium. Broken and quality control rejects from mercury thermometer manufacturers. Mercury Vapor Lamps/Manufacturers - a glass lighting device containing a few drops of metallic mercury which conducts the electric current when the lamp is turned on. Broken and quality control rejects from mercury vapor lamp manufacturers. Mercury Wetted Relays - a switching device housing a glass ampule containing metallic hiercury which makes and breaks connections between electrical conductors. Used by telephone companies in their central switching equipment. Silver Battery/Battery Manufacturers - partially assembled and quality control rejected button size silver oxide batteries from battery manufacturers. Silver Batteries/Industries - used and unwanted hermetically sealed silver oxide batteries. (Button size cells, 'C size & 'D' size) Silver Dust Collector Powders/Jewelers - dirty filter screens from the vacuum systems used by jewelers during the polishing and grinding of silver/gold jewelry. Zinc Amalgam - zinc alloyed with metallic mercury. C-10 700320 The hazardous waste received from off-site generators is classified into four physical types: (1) spent mercury in glass devices, (2) mercury contaminated material, (3) mercury contaminated soils, and (4) mercury compounds either pure or contaminated. An explanation of why these physical, types are considered hazardous and the waste characterization and verification procedures are presented below by physical type and in Section C-2, respectively. Spent Mercurv-in-Glass Devices Spent mercury-in-glass devices are handled by MERECO as a hazardous waste. MERECO's experience obtained in reclaiming the mercury from these devices over many years reveals that a significant quantity of mercury-in-glass devices are broken prior to receipt. Therefore, these devices are classified as a characteristic spent material (D009) because the broken glass has contaminated the contained metallic mercjury and the mercury can no longer serve the purpose for which it was produced without processing. MERECO requires the generator of spent mercury-in-glass devices to complete a GWPS prior to receipt of the waste material. See Sections C-2a and C-2g for details. Because the nature and composition of mercury-in-glass devices is well documented and the contained metallic mercuiry is not altered or contaminated during use; MERECO visually inspects each container to assure conformance with the approved GWPS. Therefore, chemical analysis of spent mercury-in-glass devices is not deemed necessary. Mercury Contaminated Materials Mercury contaminated materials are handled by MERECO as a hazardous waste. MERECO's experience obtained in reclaiming the mercury from these materials over many years reveals various types of contaminated material may be received (e.g.; C-11 Revision 1 August 1994 700321 clothing, rags, packing material, etc.). These materials may have been contaminated by mercury compounds or metallic mercury. These materials exhibit the "TCLP toxic/toxicity" characteristic of mercury (D009). An example of the materials accepted by MERECO is provided in Table C-3. MERECO requires the generator of characteristically hazardous mercury contaminated materials (D009) to complete a GWPS prior to the receipt of the wastes. See Section C-2a and C-2g for details. Much of the mercury contaminated materials received at MERECO results from cleanup of a listed commercial chemical product (U151). MERECO customers may wish to send this contaminated material via normal shipping requirements under an exemption provided by 6 NYCRR 371.1 (c) (4 ) (iii) I. Other customers may wish to send the waste as hazardous (D009). MERECO will accommodate those customers shipping the waste under the exemption provided that the generator submits analytical results or other documentation certifying that the contaminated material is a result of spilled commercial chemical product (U151). If the nature of the contamination cannot be certified, then MERECO will only accept the waste as hazardous (D009). Due to the documentation on the origin of the mercury contaminated materials and because the material is readily observable; MERECO visually inspects each container to assure conformance with the approved GWPS and to assure no oil-staining is present. In addition, MERECO has found through experience that it is virtually impossible to obtain a meaningful representative sample from these types of materials. Therefore, chemical analysis of mercury contaminated materials is not deemed necessary. C-12 Revision 5 September 1993 700322 TABLE C-3 CHEHICAL/PHYSICAL AHALTSES AHD COHPOSITIOH OF COHTAINERIZBD HAZARDOUS HASTES RECEIVED BY HERECO Hazard Waste Type Process Source Waste Description Components Code Spent Mercury- Hospitals, Laboratories Mercury Thermometers Mercury, Glass D009 in-glass devices (broken) Industries, Commercial Mercury Vapor Lamps Mercury, Glass D009 Industries, Commercial Flourescent tubes Mercury, Glass D009 Industries, Conunercial Mercury Switches Mercury, Metal D009 Industries Ignitron Tubes Mercury, Glass D009 Mercury Industries, Laboratories, Mercury Contaminated Mercury, Metal, Cloth p004-D011 Contaminated Clean-up Operations Materials Materials Flourescent light Mercury Contaminated Mercury, Oil D009 Manufacturers, Other Vacuum Pump Oil Industries Mercury Spill cleanups, Site Mercury Contaminated Soil Mercury, Soil D004-D011 Contaminated Remediations Gravel, Leaves, etc. Soils Mercury Compounds Laboratories, Industries Mercury Compounds** Mercury Compounds DOOl***, D009 (impure or contaminated) silver Compounds Laboratories, Industries Silver Compounds Silver, Impurities DOll (impure or contaminated) Metallic Mercury Industries Metallic Mercury Mercury,' Impurities D009 (impure) Customers may wish to claim an exemption from hazardous waste regulations provided by 6 NYCRR 371.1(c)(4)(iii). Pure, unused mercury compounds may be handled as a commercial chemical product under 6 NYCRR $371.1(c)(4)(iii). Oxidizers only Revision 3 August, 1994 1786h.aGC •J o o to ro u> Mercurv Contaminated Soils MERECO accepts mercury contaminated soils (D009) for recycle, however, other Toxicity characteristic metals may also be present in low concentrations (D004 through DOll). Some of the mercury contaminated soils handled by MERECO as a hazardous waste are identified in Table C-3. These soils are generated as a result of known spilled materials (U151), facility cleanups or from uncontrolled disposal sites. Therefore, these materials may exhibit the toxicity characteristic for various metals. Also the generator of contaminated soil from uncontrolled disposal sites is required to provide to MERECO a complete analysis of TCL compounds with its GWPS submittal. , The contaminated soil generated from known spills of mercury (U151) may be handled and shipped as non-hazardous pursuant to 6 NYCRR 371.1(c)(4)(iii). The generator of this waste must certify and submit supporting documentation identifying the nature of the contaminated soil. If the documentation is conclusive, the waste will be accepted as non-hazardous and will not undergo analysis. If the documentation is inconclusive, MERECO will accept the « waste as characteristically hazardous. All contaminated soils that are hazardous wastes will undergo preacceptance and acceptance analyses as described in Sections C-2a and b. Mercury Compounds Either Pure or Contaminated Mercury compounds which are impure or contaminated commercial chemical products are handled as hazardous wastes by MERECO as identified in Table C-3. These wastes are generated by industrial processes and by laboratories. Primarily, these wastes exhibit the toxicity characteristic for mercury (D009). Mercury compounds which are pure, unused, commercial chemical products may be handled as nonhazardous pursuant to 6 NYCRR 371.1(c)(4)(iii). These materials are generated when laboratories discard chemicals which are no longer used, or which are outdated. C-14 Revision 6 August, 1994 • 700324 MERECO requires the generator to complete a GWPS prior to receipt of the waste material. The chemical constituents of these wastes are well known by the generators through knowledge of their manufacturing process or inventory reduction activities, as the case may be. MERECO receives many of these C-14a Revision 6 August 1994 700325 TABLI PARAMETER AND RATIONALE FOR HAZARDOUS WASTES GENERATED ON-SITE Hazard Process Source Waste Description Code Parameters Frequency Rationale Reclamation Retort Solid D004-D011 TCLP Metals 1 sample per 20 drums A RCRA Toxicity Characteristic Waste Total PCBs Annually A NYS Listed Hazardous Waste Reclamation Retort Liquid (Currently DOOl ,0004- TCLP Metals, 1 sample per 10 drums A RCRA Toxicity Characteristic Waste includes water, D011,D018 Volatiles & grease and oil) D019,0021-DOSO Semi-Volatiles D032-D043 Total PCBs *Composite 10 drums A NYS Listed Hazardous Waste B002"*,B003"* TOX *Composite 10 drums Process Emissions Flashpoint *Composite 10 drums A RCRA Characteristic Waste Mercury/PCB Grease B002,B003 Total Hg Composite 10 drums A RCRA Characteristic Waste Separation process D004-D011 Total PCB Composite 10 drums A NYS Listed Hazardous Waste D001,D018, Flash Point Composite 10 drums A RCRA Characteristic Waste D019,D021 - D030, D032-D043 Mercury Purification Dilute Nitric Acid D002, Corrosivity Annually A RCRA Characteristic Waste D004-D011 TCLP Metals Annually A RCRA Toxicity Characteristic Waste Total PCBs Annually A NYS Listed Hazardous Waste Plant Operations Mercury Contaminated D004-D011 TCLP Metals Not possible to obtain A RCRA Characteristic Waste Debris (personal representative protective equipment samples.Sample as needed for purposes of disposal. • Mercury/PCB Contaminated Debris D004-D011 TCLP Metals Not possible to obtain A RCRA Characteristic Waste Separation process (PRE, Drums, etc.) Volatiles, and representative samples. B007, 0018, Semi-volatiles, Sample as needed for A NYS Listed Hazardous Waste D019,D021- PCB purposes of disposal. D030. D032-D043 •J This is the maximum number of drums per composite. When necessary to facilitate disposal, composite samples will be taken o from few drums prior to disposal. o Ui ro These waste codes (0018, D019, D021-D030 and D032-D043) are notyet regulated in New York State. They are being added in anticipation of New York State adopting the TC Rule. Revision 6 October 1994 * Not normally associated with this waste stream. mercury compounds in their original containers or vessels with their original labels attached. The GWPS and supporting documentation is used by MERECO as a preacceptance screening tool. Prior to contracting to accept the waste, MERECO ensures the wastes are characterized sufficiently to determine whether to accept or reject the waste. Based on the preacceptance characterization, MERECO has the information required to safely accept and store the wastes. No physical or chemical analyses are required. Visual inspection of the waste will verify that the color, form, and other visible criteria conform to the GWPS and the manifest. MERECO Generated Wastes i In addition to the storage of wastes received from off-site generators, MERECO stores hazardous wastes that are generated by the reclamation process. An example of the wastes generated at MERECO is shown in Table C-4. C-la Containers # All containers received from off-site generators are required to meet Department of Transportation specifications as described in 49 CFR Parts 173, 178, 179 and 40 CFR 262.30, which cover shipping container specifications for transport of hazardous materials. All wastes are compatible with the containers in which they are stored and/or transported. MERECO requires generators to provide their own DOT-approved containers. MERECO requests that generators ship hazardous waste in polyethylene lined containers or their equivalent, as additional containment protection, prior to placing waste in the container. Wastes exhibiting the characteristic of corrosivity (D002) are received and stored in polyethylene containers. MERECO places on-site generated wastes into drums prior to storage on-site. Prior to the placement of any waste into a drum, the drum is visually inspected for integrity. A C—15 Revision 3 August, 1994 # 700327 TABLE C-4 CHEHICAL/PHYSICAI, ANALYSES AND COKPOSITIOH OF CONTAINERIZED HAZARDOUS WASTES GENERATED AT HERECO Hazard Average Annual Process Source Waste Description Composition Code Generation Analytical Data Reclamatioh Retort Solid TCLP Metals D004-D011 Approx. 600 drs. Included in Appendiy Reclamation Retort Liquid TCLP Metals ••D004-D011 Approx. 3,000 gals. Included in Appnvri'-' TCLP Volatiles & Various D Semi-volatiles Codes D018, D019 D021-30 D032-43 Reclamation Retort Qrease/Oil TCLP Metals **D001, D004- Approx. 8 drs TCLP Volatiles & DOll, D018, Semi-volatiles D019, D02I-D030 D032-D043 Mercury Purification Dilute Nitric Acid Nitric Acid, Mercury, D002, D009 Approx. 3 drs. Included in Appendix Water Miscellaneous Mercury Contaminated Debris TCLP Metals D004-D011 Approx. 160 cu. yds. Not possible to ob"^-!' (personal protective equipment, a Representative steel scrap, empty flasks, etc.) Sample PCB Separation Grease, debris Grease/water B002, B003 Approx. 100 drs. (one-time) Crushed drums/PPE B007 Approx. 100 drs. Absorbant pads (one-time) Material will be generated upon start-up of Retort Liquid Treatment System. These waste codes (D018, D019, D021-D030 and D032-D043) are not yet regulated in New York State. They are being added in anticipati' of New York State adopting the TC Rule. Revision 5 August, 1994 O ITSeh.asc O Ui N) 00 polyethylene line: o: alt equal is inserted into the drum as additional containment protection, prior to the placement of either liquids or sludges into the drum. A variety of hazardous wastes are stored on-site in containers. The wastes can be broadly classified as spent characteristic wastes. The spent wastes may be characteristically ignitable, corrosive, reactive or exhibit the toxicity characteristic for metals or organics. MERECO stores all hazardous wastes in the container storage building. The building has been constructed to contain liquids at the design capacity of 48,400 gallons. The transportation of hazardous waste to the facility is conducted by hazardous waste transporters that have been permitted by New York State to enter the facility. Hazardous wastes or recyclable materials exhibiting hazardous characteristics are transported from MERECO to permitted treatment, storage and disposal facilities ("TSDFs") and metal refiners by transporters permitted by New York State under 6 NYCRR Part 364. C-2 WASTE ANALYSIS PLT^ [373-1.5(a)(2)(ii), 373-2.2(e)(2) & (3)] * The purpose of this document is to satisfy regulations promulgated pursuant to the Resource Conservation and Recovery Act of 1976 (RCRA) which govern the generation, transportation, treatment, storage, and disposal of hazardous wastes. Specifically, this document satisfies the requirements of 6 NYCRR 373-2.2(e) which require the owner/operator of a hazardous waste treatment, storage or disposal facility to develop, document and implement a formal program for waste analysis. These analyses must provide all information required to treat, store or dispose of a hazardous waste in accordance with RCRA and New York regulatory requirements. Mercury Refining Company (MERECO) is a recycling/reclamation facility for mercury and precious metals, primarily silver. A portion of the waste processed by MERECO is C—17 Revision 5 August, 1994 • 700329 classified as RCRA exempt or non-hazardous because the wastes are characteristic mud/sludge, characteristic by-products, household • wastes, listed commercial chemical products, or scrap metals for reclamation. The hazardous wastes received from off-site for processing by MERECO are classified as characteristic spent materials. Metallic mercury is recovered from mercury bearing secondary materials by a retort/ distillation operation. Precious metals in the residual retorted scrap, if present, are concentrated in a hammermill/ball mill/screen operation. The processed precious metal waste is containerized and shipped off-site as a non-hazardous waste for further metals recovery. The residual retorted waste containing no significant amounts of precious metals is drummed for storage and shipped off-site to a RCRA permitted TSD facility for disposal. This waste may contain TCLP toxic metals D004 through DOll. The facility generates a mercury purification wash waste containing dilute nitric acid and mercury (D002 and D009). These MERECO generated wastes are stored in sealed, labelled containers in the storage facility until removed by a licensed transporter for delivery to a RCRA-permitted TSD facility. # C-2a Preacceptance Procedures Before MERECO agrees or enters into a contract to accept wastes for recycle, the waste is evaluated in a series of steps. The preacceptance evaluation ensures that only permitted wastes are accepted and that all wastes received can be safely stored and processed onsite. The preacceptance process is diagrammed in Figure C-1. MERECO screens customers through telephone interviews and review of the Generator Waste Profile Sheet (GWPS) (see Figure C-2). All potential clients, with the exception of liquid mercury and household battery generators, are required to C—18 Revision 6 August, 1994 700330 Potential Customer Contacts MERECO MERECO S«nds Generator Wasls Profile Sheet (GWPS) 1 For Eacli Waste Streem Geowalor Completes GWPS SerOs Copy ID MERECO MERECO Reviews GWPS tor Comp Acceptable Not Acceptable MERECO Assigns Waste Code, MERECO Sends Rejeciion Servds Acceptance Letter. Lener to Client Valid (or One Year Figure C-1 Preacceptance Procedures # c-19 700331 OFFICE USE ONLY No. ir MERCURY REFINING COMPANY INC L GENERATOR'S WASTE PROFILE SHEET EPA ID NO. NYD04814ei7E Renewal Sample No._ Office: 1218 Central Avenue. Albany, NY 12205 -ouncec *9S5 WS Waste Code _ Plant; 26 Railroad Ave.. Albany. NY 12205 Rec [ Reviewetd By CR. Approved By 1. GENERATOR INFORMATION Billtc Name Site Address Contact Phone: FAX: EPA ID No. Send Contracts to: Technical Contact Phone: FAX: Mailing Address Contact: Phone: FAX: II. SHIPPING INFORMATION DOT Shipping Name Hazard Class UN/NA Number. Packing Group. EPA Waste Code(s) III. WASTE IDENTIFICATION Generator's Name for Waste Process Generating .Waste Estimated Annual Volume . Container Type/Size Mercury Contaminated Debris Mercury-in-Glass devices Mercury Contaminated Soil Other (please specify). Mercur/ Contaminated Materials Mercury Compounds Batteries (specify type) IV. WASTE PROPERTIES Physical State: % Liquid _ % Mud/Sludge . % Solid Density: , Ibs./gal. pH: Flash Point "F - Describe any special handling requirements associated with this waste stream: Range V. WASTE COMPOSITION min - max VI. WASTE INFORMATION YES NO Radioactive materials ) ( Does This Waste Contain: YES NO Oxidizers ) ( Halogens'" Listed Hazardous Wastes other than U151 ) ( Plastics Contituents or characteristics other than mercury Free liquid (other than mercury) subject to land disposal restrictions'" ) ( DIoxins Nickel and/or Thallium (liquids only) "' ) ( Oils'21 Acute Hazardous Wastes ) ( PCBs Beryllium ) ( Pesticide/Herbicide Magnesium metal ) ( Asbestos Soil from uncontrolled disposal site'" ) ( D if "VES". pisas* ilucn Total Oi^anc Haiogeni Analysis. (2) tl "YES', piaass anacn PCB anafysis. (3) tt "^ES*. ptaasa supply anaiyncal ivsuns ta) itCYES*. piaasa aiucfi TCL fTatyat C(vnpour>d Ust) anavsts. VII. I anesi and ceraty thai all intormation orovtaed is comoleie and accurate and in accoroance wim 40CFR261 and New Yot* State regulations 6NYCRR371. This waste material is Dropeny oescnbed wttri no willful omissions tn tne iniormation. Any cnanges or additional inJotmation oDtameo aoout triis waste stream will t>e promptly and correctly conveyed to Mercury Refining Co. II any toao is reieaeo Oy Mercury Relining Co. Jor any reason, our company will assume responsibility lor riavtng tne toad removed Irom the site as soon as possible. Our company agrees to pay for any testing, decontamination, iransoortanon or disoosal lor any matenal shipped to the Mercury Refining Co. site whtcn does not fully comply with the pemiit limits as specified to our company by Mercury Refining Co. Generator's Agent. Date 5FFICE USE ONLY Figure C-2 TCLF Metals C-20 PCB Analysis Halogens OFFICE-White CONTRACTS - Green. Canary PLANT-Pink CUSTOMER-Gold 700332 complete a GWPS. The GWPS information is used by MERECO to determine whether the waste can be accepted. Table C-3 summarizes hazardous waste characterization data obtained from the GWPS's. Examples of GWPSs have been provided in Appendix B; instructions for completing the sheet are included in Appendix C. The GWPS must document the source or process generating the waste. MERECO verifies that the source or process does not generate a listed hazardous waste. The generator must have the waste analyzed or demonstrate, based on engineering processes and materials, that the waste does not contain the following: Dioxin; PCBs; Pesticides/Herbicides; Radioactive Materials; Listed Waste Other Than U15i, K106, K071; Acute Hazardous Waste; and Ignitable Materials such that the Flashpoint < 60**C or 140^. If the hazardous or nonlisted waste contains any of the above compounds or meets those criteria, the waste will be 4 rejected. These restricted wastes are rejected due to permit limitations and process controls. Contaminated soils from uncontrolled hazardous waste sites must be accompanied by analyses for TCL compounds prior to acceptance by MERECO. Other generators must analyze or provide documentation on additional parameters which influence material handling and process management. The additional parameters and the rationale for their selection are as follows: Total Halogens Affects process emissions Plastics Affects retort process, emissions, and residuals Free Liquids Affects waste handling and process management C —21 Revision 3 4 August, 1994 700333 OiJ£ AlieclE process monaceraent and triggers verification PCB screening Asbestos Poses health and safety concern; thereby affects waste handling Oxidizers Poses waste handling and process management concerns Beryllium Poses operational problems Magnesium Metal Poses operational problems Selenium Poses operational problems MERECO reviews the GWPS package and discusses any questions with the generator. Based on the characterization data, process or source information, and conversations with the generator, his/her broker, or applicable regulatory agency personnel, the waste will either be approved or rejected by MERECO. If approved, MERECO maintains the GWPS and the analytical data in manuals and/or computer data bases located at the plant site and at the office. C-2b Waste Acceptance Procedures # Upon approval to accept the waste, shipments may commence. Waste may be accepted at the facility in one of three ways: a RCRA hazardous manifested shipment, a RCRA-exempt manifested shipment, or a bill-of-lading shipment. Once the waste shipment is received at the facility, the Inventory Coordinator pulls the respective GWPS and acceptance information on the incoming waste to evaluate the waste for final acceptance. The acceptance procedures are diagrammed in Figure C-3. All manifested shipments of hazardous waste will be reviewed for: o New York State Waste Transporter's Identification and permit. The vehicle delivering the waste must be listed on the permit. C —22 Revision 3 August, 1994 700334 a ,s.i. '- K 4 Mejor 0.»cf«pency Figure C-3 Waste Acceptance Procedures Revision 1 4 C-23 August, 1994 700335 o the identification of the TSDF o the waste description o the quantity of waste shipped o the transporter's permit expiration date The Inventory Coordinator will complete the appropriate Receiving Checklist, shown in Figure C-4. As part of the procedure for completing the checklist, the Inventory Coordinator will visually inspect every container in the shipment, comparing the information provided on the GWPS and the shipping document to the containerized wastes. The MERECO inspector will visually check each container for evidence of oil. If materials are visibly stained, MERECO will stage the containers, and sample them for PCB analyses by a NYSDOH ELAP certified laboratory. If there are neither discrepancies in the shipping documents, variations in the physical description on the GWPS and the appearance of the waste, nor visible oil present, the Inventory Coordinator will sign the manifest and accept the waste into the facility for reclamation. Upon receipt of mercury contaminated soil being managed as a hazardous waste (D009) and contaminated oils, MERECO will stage 4 the containers, and sample them for TCLP metals and PCB analysis, respectively. These analyses will be performed by a NYSDOH ELAP Certified Laboratory. The samples collected will be a composite from samples drawn from each container within the manifested shipment to verify that the waste does not contain any PCBs or TCLP metals (other than mercury) and is indeed the waste that was identified on the GWPS and approved through the preacceptance process (see Section C-2a). If the waste contains TCLP toxic concentrations of any metals other than mercury, the material is marked accordingly and residuals segregated for disposal in accordance with the Land Disposal Restrictions. Standard sampling procedures are included in Appendix D. Table C-5 identifies the parameters and rationale for the testing of these wastes. In instances where minor discrepancies (i.e., misspelling, incorrect dating, etc.) are discovered on C —24 Revision 6 • August, 1994 700336 WASTE RECEIVING CHECKLIST Generator Name: Date: Manifest No. Completed By: A) Manifested Hazardous waste - Section A B) Manifested RCRA Exempt waste - Section B C) Unmanifested, exempt, non-hazardous waste - Section C D) Unmanifested hazardous waste - CALL THE OFFICE SECTION A 1) Check transporter's NYS Part 364 Permit. a) Does the permit have a valid expiration date? b) Is Mercury Refining listed as a TSD facility? c) Is the appropriate waste type listeci on the permit? d) Is the license plate number of the vehicle on the last page of the permit? 2) Is a completed LDR attached? 3) Fill in the Checklist. * Explain any answer of "no" below. GWPS INFORMATION HAZARDOUS WASTE LABEL MANIFEST EPA ID # Generator Name Site Address * Shipping Name UN/NA#, Hazard Class Packing Group EPA Waste Code(s) WASTE CONTAINERS Mereco Waste Code Mereco Work Order # ,_ DOT Shippable? _____ Hazard class Labels? Spillage/leaking? If yes, what was done: 4) Open each container. Do contents match the description on the GWPS? 5) Compare the manifested number of containers with the number of containers received for each Mereco waste code. Are they the same? 6) Check the manifest for completeness and accuracy. Any discrepancies? Explain any discrepancies. Figure C-4 • C-25 700337 WASTE RECEIVING CHECKLIST Generator Name: Date: Manifest No. Completed By: A) Manifested Hazardous waste - Section A B) Manifested RCRA Exempt waste - Section B C) Unmanifested, exempt, non-hazardous waste - Section C D) Unmanifested hazardous waste - CALL THE OFFICE SECTION B 1) Check transporter's NYS Part 364 Permit. a) Does the permit have a valid expiration date? b) Is Mercury Refining listed as a TSD facility? c) Is the appropriate waste type listed on the permit? d) Is the license plate number of the vehicle on the last page of the permit? 2) Fill in the Checklist. * Explain any answer of "no" below. GWPS INFORMATION HAZARDOUS WASTE LABEL MANIFEST EPA ID # Generator Name Site Address - Shipping Name UN/NA#, Hazard Class Packing Group _____ . 4 EPA Waste Code(s) WASTE CONTAINERS Mereco Waste Code Mereco .Work Order # DOT Shippable? • Hazard class Labels? Spillage/leaking? If yes, what was done: 3) Open each container. Do contents match the description on the GWPS? 4) Compare the manifested number of containers with the number of containers received for each Mereco waste code. Are they the same? 5) Check the manifest for completeness and accuracy. Any discrepancies? 6) Write "not a hazardous waste" in section 19 of the manifest. Explain any discrepancies. Figure C-4 (continued) C-26 700338 WASTE RECEIVING CHECKLIST Generator Name: Date: Manifest No. Completed By; A) Manifested Hazardous waste - Section A B) Manifested RCRA Exempt waste - Section B C) Unmanifested, exempt, non-hazardous waste - Section C D) Unmanifested hazardous waste - CALL THE OFFICE SECTION C 1) Fill in the Checklist. * Explain any answer of "no" below. GWPS INFORMATION DRUM LABEL BILL OF LADING Generator Name . \ Site Address Shipping Name UN/NA#, Hazard Class Packing Group ^ WASTE CONTAINERS Mereco Waste Code Mereco Work Order # DOT Shippable? ) Hazard class Labels? Spillage/leaking? If yes, what was done: • 4) Open each container. Do contents match the description on the GWPS? 5) Compare the number of containers on the Bill of Lading with the number of containers received for each Mereco waste code. Are they the same? 6) Check the Bill of Lading for completeness and accuracy. Any discrepancies? * Explain any discrepancies. Figure C-4 (continued) C-2 7 700339 # C-28 # 700340 TABLE C-5 PARAMETERS AND RATIONALE FOR MERCURY CONTAMINATED WASTES Waste stream Description EPA ID Parameter Rationale Mercury*» D004- TCLP A RCRA Waste Contaminated DOll* Metals Soils Mercury D009 PCBs Not accepted at Contaminated this facility oils For those wastes which exhibit strictly the DOOSlj characteristic customers may wish to claim an exemption from hazardous waste regulations provided by 6 NYCRR 371.1(c)(4)(iii). For contaminated soils from uncontrolled hazardous waste sites there must be accompanying analysis for TCL compounds and PCBs prior to acceptance by MERECO. 4 C-29 Revision 5 August, 1994 1785h.red 4 700341 the manifest, the Inventory Coordinator will accept the waste, but will complete the manifest discrepancy box before signing the manifest. In the case of a major discrepancy (i.e., information anomaly between manifest, GWPS, or containerized waste; incorrect number of containers; etc) the .Inventory Coordinator will hold the shipment. MERECO will contact the generator for clarification. If satisfactory clarification cannot be attained, the Inventory Coordinator will reject the shipment. All shipment rejections will be reported to NYSDEC on the manifest. If satisfactory clarification is received, the Inventory Coordinator will complete the discrepancy box on the manifest, sign the manifest, and accept the waste. C-2c Parameters and Rationale [373-2.2(e)(2)(i)] C-2c(l) Parameters and Rationale for the Receipt of Off-Site Hazardous Wastes Much of the waste received at MERECO is derived from sources where the chemical content has neither been altered nor contaminated during use (e.g., thermometers, switches, fluorescent tubes, etc.). MERECO requires the generator of hazardous waste to appropriately characterize the waste. In addition, MERECO conducts a screening process whereby all hazardous waste is evaluated prior to and during deliveries described above and in Section C-2g. This is accomplished through the use of a Generator's Waste Profile Sheet (GWPS) and analysis when required. Due to the nature of the hazardous wastes received at the facility (spent mercury-in-glass devices, mercury conteuninated materials and mercury compounds) recognition of the waste is obvious (see Section.C-1). Visual inspection is sufficient to verify the identity of these wastes; chemical analyses are not warranted. This facility does not accept wastes that contain PCB's, pesticides, herbicides, dioxins, asbestos, and RCRA listed wastes, except U151, K106 and K071. ^ W,/. C-3U Y Revision 6 fi August, 1994 700342 MERECO accepts mercury contaminated spill residuals and debris (soil and associated personnel protection equipment and clothing, decontamination equipment, etc.). In instances where the generator documents that the contaminated soils and associated residuals and debris are a result of a mercury (U151) spill, the generator may wish to handle these wastes as non-hazardous under 6 NYCRR 371-1(c)(4)(iii). Under these circumstances, the generator must document and certify that the waste was generated as a result of a mercury (U151) spill and that there were no other hazardous materials contained in the waste. If the generator can not document this, the generator will be required to complete a GWPS and provide certification that the soils or spill residue do not contain listed hazardous wastes or other restricted wastes. Only spill residue regulated as characteristic waste will be accepted. C-2d(2) Parameters and Rationale for Hazardous Wastes Generated On-site As documented in Section C-1, MERECO generates both 4 nonhazardous and hazardous waste from the reclamation process. A description of these wastes as well as the analytical parameters, frequencies and rationale are identified in Table C-6. An example of the analytical data gathered on MERECO generated wastes is provided in Appendix E. The parameters chosen represent those that best assist MERECO in determining the proper waste handling methods. C-2d Test Methods [373-2.2(e)(2)(ii)] MERECO will employ the services of a NYSDOH ELAP Certified laboratory for all analyses. Examples of the credentials/ training of laboratory personnel are included in Appendix G. All contracted laboratories will be required to follow Quality Control/Quality Assurance C —31 Revision 6 4 August, 1994 700343 onalylicaj pioceduiet established in SW-64fa and approved bv NYSDEC. The laboratories generally provide all sampling equipment, including, but not limited to, collection jars, blank labels and preservatives. One specific QA/QC procedure and the EPA methods to be • followed are provided in a separate QA/QC plan included in Appendix F of this document. Any data validation documents associated with the analysis will be maintained with facility operating records. A list of parameters and test methods that apply to the wastes received and generated at the facility is provided in Table C-7 per the requirements of 6 NYCRR 373-2.2(e)(2)(ii). This table specifies the methods which will be used to test for each parameter. C-2e Sampling Methods [373-2.2(e)(2)(iii)] The sampling methods employed at this facility are the same for received and generated wastes. The sampling procedures discussed below will be followed for each type of waste. These procedures are based on the physical/chemical properties of the waste. The appropriate equipment to be used is listed in Table C-8. All hazardous waste at MERECO will be containerized. All containers will be visually screened for discrepancies between the GWPS, the transportation records, and the physical appearance of the waste. Mercury contaminated soils managed as hazardous waste and contaminated oils will be sampled and analyzed for PCBs. MERECO personnel will collect a composite sample from samples drawn from each container within a manifested shipment. The laboratory generally will provide all sampling equipment, containers and preservation materials. Standard sampling procedures utilized are provided in Appendix D. C —33 Revision 5 August, 1994 700344 TAFLI I • • rAP.^iHETER? rjIV rr.'^T llETHOn.'"- rOR MERECO r^OW.S AND .SL'IDGES Sample Prep3r?(tioii Test Method Parameter Test Method Method No. (1) No. (1) Corrosivity (pH) Electrometric 9040 or 1110 TCLr Metals Arsenic Atomic Absorption 1311 7060 BAcium Atomic Absorption 1311 7080 CsdmiuFT Atomic Absorption 1311 7130 Chromium' Atomic Absorption 1311 7190 Hexavaleiit Atomic Absorption 1311 7195 Chromiiun LcBd Atomic Absorption 1311 7420 Mercury Atomic Absorption 1311 7470 Selenivm Atomic Absorption 1311 7740 Silver Atomic Absorption 1311 7760 TCLF Volatiles GC/MS 1311 8240 TCLP Semi- Volatiles GC/MS 1311 8270 PCBs GC/electron capture 3540/3550 8080 TOX Carbon adsorption/ 9020 microcoulometer Flashpoint Pensky-Martens 1010 closed cup method ' ' "Test Methods for Evaluating Solid Waste- Physical/Chemical Methods". EPA SW-«46, Third Edition September, l?"^. Excepted as noted. Note: Method 6010. the ICP metals analysis, may be substituted for the Fl?me Atomic Absorption methods for barivm, cadmium, chromium and lead analyses. )7n5h 72e3-001-600A Revision 4 C-34 Augur?*- l.?9I 700345 TABLE C-8 SAMPLING EQUIPMENT Waste Type Sampling Device Free-flowing Coliwasa liquids and slurries Sludges Trier Moist powders Trier or granules Dry powders Thief or granules \ Sand or packed Auger ' powders and granules Large-grained Large solids Trier # •Table taken from EPA SW-846. C-35 # 1785h 7283-001-600A 700346 SaiTipJinc appa: at.ut- and nielhodology j oj eacl; v.-.aste were selected based on the sample matrix and parameter to be analyzed, as per the requirements of EPA SW-84 6. Enough sample will be drawn from the container for distribution into sample bottles. Sample bottles, holding times, and preservation methods for each parameter are given in Table C-9. To ensure the quality of field data, quality control samples will be collected during sampling to assess sample contamination, precision and accuracy. The quality control samples are field blanks, trip blanks, duplicate samples, matrix (field) spikes and preventative maintenance as briefly described below: Field Blanks Field blanks measure the amount of contamination due to field practices; the combination of site, sampling, and transporting characteristics which contribute to the reduction in sample integrity and, in turn, data validity. A field blank will be collected at each sampling site for each analyte to be measure at predetermined intervals. Reagent grade water will be supplied by the outside laboratory. The # reagent grade water will be subjected to the same sampling procedures as the streams being sampled. Trip Blanks A trip blank will consist of reagent grade water in precleaned sample containers of volumes equivalent to those which will be collected in the field. Trip blanks are analyzed to discriminate between contamination due to field practices and that due to sample proximity during transport. A trip blank for each analyte will accompany the sample containers from their original source (i.e., the outside laboratory) to the sampling areas and back to the responsible analytical laboratory. The trip blanks will be utilized at predetermined intervals. # C-36 700347 T.^PLF. C-O .'AMFLINf: REQUIPEMENT.'? AHP HOLPING TTHPS Preservation Sampling Requirement Holding Time Method '.'oiropi vj ty 1 plastic ?0 d?.vs Cool. 4~C (N.A.f.E. FPA 1110) TCLP Mei-a.lp 200 grams in plastic or qlass Heirurv 28 days Cool. 4-C to e.'ttraction Metals, except 180 days Cool. 4"'C mercurv tc extraction Tri,P vnjqtiles ^- 200 grams glass with teflon 14 days Cool. 4''C .<;<.mi Vr)lafi2oc lined septum cap tc extraction T'CPs 1 glass, teflon cap 7 d=(ys Cool. 4'C rny 120 ml glass, teflon cap 7 days Cool, 4°C 4 Revision ^ C-37 Ancinst 1?91 700348 Duplicate Samples Project data precision will be assessed by utilizing field duplicate samples. Duplicates taken in the field account for both the sample matrix and variabilities in both sampling and analytical procedures. They will be collected by replicating the sampling procedure at the sampling point. Duplicate samples will be collected at predetermined intervals. Preventative Maintenance The sampling personnel will visually examine all sampling equipment to assure that it is in good working order. The equipment will be decontaminated in accordance with procedures described in Appendix D - Standard Operating ^Procedure for Decontamination of Equipment, unless it is single use equipment. The sampler will re-examine the equipment upon completion of sampling and cleanup to assure that sampling equipment remains in good working order. Chain-of-Custody 4 A chain-of-custody form (see Figure C-5 for an example) shall be initiated for each sample at the time of its collection. This form will accompany the samples. The form must be properly filled out and signed. Any transfer of custody shall be recorded by each party signing and dating the form. C-2f Frequency of Analysis [373-2.2(e)(2)(iv)] All regularly generated wastes from the reclamation process are to be sampled and analyzed in accordance with Table C-6 unless a process or operational change is made which would substantially affect waste characteristics. In the event of such a modification, the associated waste will be sampled as soon as a representative sample is available. Off-site hazardous wastes which require chemical analysis will be analyzed on a campaign basis; that is, as they are received. C-38 Revision 4 • August, 1994 700349 .WMENTAL PnOTECTION AGENCY # OIlic* ol Enlo NO SAMPLERS. fS>*'Mi»'«> or CON /////// REMAflKS , ft.' •• i TAINCnt < »tA.NO. OATt TIMi c • TATION lOCAflON u • 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 i 1 1 ! ' 1 1 1 1 i Rtlinquiihid by: /S • i n«Uftquiih«d by: IS'f—tunl OMt/TifM R«c«U«d by: iS'rMiwtf R«linquiihtd by: ISiftiwl 0*1* / Tim* Rtctivtd by: a'f.'M'*/ ! 1 1 1 o R«cti»«d lo* Ltbouioiy by: | D*i«/li>n* R lOltfl • 1 o Rtlin^lihtd by: lt-r*'>»'*l 0«M / Tim* Ul tn o 1 1 OIII>*«II«M: Oil«M>« A«>»iw«*nlM tMwmtM: C«#v «• C»*<*n»t»< ficM »ii« Figure C-5 Example of Ch.iin-of Custody Uocord C-2q AddJtionc] Reci::: exit ni t, loi Wastes Generated Ofl-site " [373-2.2(e) (2) (v) and 373-2 . 2(e)(3)] When MERECO is contacted by a potential customer who wishes to reclaim his waste, the customer is questioned on the type and generating process of the waste. MERECO uses the information provided on Table C-2 of this permit application to assist the potential client in determining the regulatory status of the generated waste. MERECO will send a Generator's Waste Profile Sheet to the potential customer. Information requested on the GWPS is provided in Figure C-2; instructions for completing the GWPS are provided in Appendix C. The generator is required to correctly complete the GWPS and certify the accuracy of the information provided. Generators must complete a GWPS for any waste stream they intend to ship to MERECO, except liquid mercury and household batteries. The generator will return the GWPS to MERECO before any waste is approved for recycle. Upon receipt of the GWPS, MERECO will review the sheet for completeness and evaluate the technical information. MERECO uses this information to determine waste storage compatibility, health and safety concerns, operational concerns and presence of wastes or characteristics that cannot be accepted. If it contains a restricted waste type, such as PCBs or radioactive materials, MERECO will reject the waste and issue a letter of rejection to the generator. If the waste does not present any problems or poses little material handling or operational concerns, MERECO will accept the waste and send a contract to the generator. An example of the contract is provided in Figure C-6. The letter provides the customer with costing information, shipping and notification requirements and an internal MERECO waste identification code. Once approved, MERECO will accept waste shipments based on the criteria and procedures presented in Section C-2a and C-2b and Figures C-3 and C-4. C-40 Revision 2 May 1990 700351 The GWPS I!- vajid loi one yea: irom the date oi the acceptance lettei. All hazardous wastes will be recharacterized annually. . In the event that processes are modified and characteristics of the related waste streams change, additional analyses will be required to determine changes in the waste composition or characteristics. Sampling and analysis of wastes generated from the modified process will be performed as soon as a representative sample is available. In the event that any of these wastes are generated infrequently, and are not available for schedule recharacterization, sampling and analysis will be completed on an as-available basis. Approximately one month prior to the expiration date, a letter is sent to each hazardous waste generator requesting them to complete an updated GWPS for wastes shipped to the facility. By the expiration date, the generator must complete and submit an updated GWPS. The annual recharacterization program ensures that no restricted wastes are accepted. C-2h Additional Requirements for Facilities Handling Ignitable, Reactive and Incompatible Wastes [373-2.2(6)(2)(vi), 373-2.2(1)] * MERECO does not accept ignitable wastes from off-site generators. Mercuric nitrate, however, does exhibit oxidizing properties. The maximum quantity of mercuric nitrate stored at any one time is one pallet or the volxime equivalent of four 55-gallon drums. This compound reacts with organic matrices which may cause ignition. To prevent accidental ignition, MERECO places the containers of mercuric nitrate in steel pans such that contact with organic materials will not occur. The pans set upon wooden pallets to C-41 Revision 3 August, 1994 • 700352 Mercury Refining Co., Inc. •^ound^igss 1218 Central Avenue, Albany, New York 12205 TEL: 518 459 0820 800 833 3505 FAX: 518 459 2334 MERCURY RECLAMATION SERVICE AGREEMENT contract #: SAMPLE Mercury Refining Co., Inc. (MERECO), having the requisite permits and authorizations from the State of New York and the U. S. Environmental Protection Agency, offers mercury reclamation services to: SAMPLE hereafter called "Customer", for waste materials as described on the attached Generator's Waste Profile Sheet(s) (GWPS) which are a part of the Agreement. This Agreement and the attached GWPS(s) and price quotations constitute the entire agreement between MERECO and the Customer and all prior written or oral negotiations, representations, arrangements, and/or agreements regarding the subject matter herein are superseded by this Agreement. 1.0 Term of Agreement This Agreement is made effective as of the date of signing by MERECO, and is valid until termination by either party giving ten days notice (by certified mail) to the other. Expiration dates for approvals are noted on individual price quotations. GWPS are valid for one year only. The Customer may ship material covered by a valid GWPS and price quotation as often as desired providing that the terms of this Agreement are met. MERECO may terminate this Agreement immediately by giving the Customer written notice (by certified mail) if the Customer fails to disclose fully and accurately the nature, chemical composition and physical properties of any material on an approved GWPS. 2.0 Reclamation Charges 2.1 Reclamation charges for materials approved under this Agreement shall be as per attached pricing schedules. Prices are based on the annual volumes provided on the GWPS and are subject to adjustment if the expected volumes are not met or are exceeded. 2.2 Terms of payment to MERECO: Net 30. Interest accrues on outstanding balances at the rate of 1.5% per month. In the event that MERECO must resort to a collection agency or its attorneys for collection of any past due balance, the Customer agrees to pay MERECO its costs and expenses for any such collection or litigation, including reasonable collection and/or attorney fees. 2.3 MERECO allows 1 hour free unloading time. The shipment is subject to a demurrage charge of $75.00 per hour if unloading time is exceeded through no fault of MERECO. The shipment is subject to outright rejection if MERECO's permit may be violated by accepting the shipment. Figure C-B Primed on recycled paper. o •-. 700353 C-42 Contract^ p nn n Page" 2 ol 5 2.4 The generator of hazardous waste in New York State is responsible for the New York State Superfund taxes, if any, under ECL 27-0923. Nothing in this Agreement is meant to change or modify the imposition of any other governmental taxes otherwise imposed by law on MERECO, the Customer and/or the generator of the hazardous waste. 3.0 MERECO's Service and Representations 3.1 Title, risk of loss, and all other incidents of ownership of the material shall be the Customer's until the shipment is accepted for processing at MERECO's facility. Notwithstanding any contrary provision herein, title, risk of loss and other incidents of ownership of any material that: (1) does not comply with the Customer's declaration on the GWPS and is not to be processed as off-specification material, (2) contains listed hazardous waste other than U151 under 40 CFR 261, or (3) results in residuals that are to be returned to the Customer, or a properly permitted facility designated by the Customer, shall not under any circumstances transfer to or vest in MERECO. 3.2 Upon acceptance, MERECO will issue an invoice for the total amount of processing and off-specification charges, if any. Upon completion of processing, MERECO will issue a Processing Report .to the Customer indicating the quantity of mercury recovered, with a minimum reportable quantity of 15 pounds. The Customer may elect in advance of shipment to have the recovered mercury returned "as is" or upgraded to triple distilled quality on a toll processing basis. This option must be specified when requesting a work order number (Section 6.2), otherwise this mercury will be purchased by MERECO according to the following schedule: 0-15 lbs: below payable limit over 15 lbs: Metals Week lower quote less $150.00 /flask. All mercury that is not returned to the Customer shall be purified and returned to the normal channels of commerce. 3.3 All residuals except those being returned to the Customer or being sent for further metals recovery shall be sent by MERECO to an appropriately permitted Treatment, Storage and Disposal Facility for disposition. 3.4 Neither MERECO nor the Customer shall be dqemed to. breach this Agreement because of delays or non-performance resulting from circumstances beyond the party's control (including but not limited to strikes, lockouts, work stoppages or delays, labor disputes, or inability to obtain labor, materials, equipment or other facilities; actions or requests of a governmental body, regulatory agency or judicial authority; riot, sabotage, accident, explosion, fire, flood, storm or other acts of God; or any other a'ctions or omissions beyond the party's control.) 3.5 MERECO agrees to indemnify, save harmless and defend the Customer from and against any and all liabilities. Figure C-6 (Continued) C-43 700354 ^^0 000 Contracts Page 3 of 5 claims, penalties, forfeitures, suits and the costs and expenses incident thereto, (including costs of defense, settlement and reasonable attorneys fees) which it may hereinafter incur, become responsible for or pay out as a result of death or bodily injury to any person, destruction or damage to any property, contamination of or adverse effects on the environment, or any violation of government laws, regulations, or orders, caused by (1) MERECO•s'breach of any term or provision of this Agreement; (2) any negligent or willful act or omission of MERECO, its employees or subcontractors in the performance of this Agreement, provided that MERECO's obligation to indemnify Customer under this paragraph shall not be effective as to any such liabilities, claims, penalties, forfeitures, suits, costs and expenses incident thereto which may arise as the direct result of Customer's shipment of material that fails to meet the Customer's warranty specified on the GWPS and in this Agreement. This obligation to indemnify, save harmless and defend the Customer shall survive the termination of the Agreement for such additional time as the Customer may be liable or potentially liable for its activities under the Agreement. 4.0 Notice of Non-Conformance or Rejection Material shipped under this Agreement must conform to the description provided by the Customer on the Generator's Waste Profile Sheet (GWPS). If upon receipt it is determined that the material does not conform to the GWPS, then MERECO may either reject the lot or apply off-specification charges. MERECO shall give notification to the Customer within five # (5) business days of the receipt of nonconforming materials.. This notification shall include the off-specification charges which will apply. The Customer shall respond to such notice within five (5) business days, and may chose to either pay the off-specification charges or have the material returned. If the material is to be returned, or if MERECO rejects the material, a $150.00 handling fee will apply. Failure of the Customer to respond to the notice within five (5) business days shall be deemed to be acceptance of the of.f- specification charges. 5.0 Customer's Representations 5.1 It is the Customer's responsibility to comply with all applicable DOT, USEPA and NYSDEC regulations, including but not limited to the preparation of the New York State manifest, if required, and shipping papers. MERECO provides its Shipping Information sheet for informational purposes only and assumes no liability for any reliance on same by Customer or any third party. 5.2 The Customer agrees to indemnify, save harmless and defend MERECO from and against any and all liabilities, claims, penalties, forfeitures, suits and the costs and expenses incident thereto, (including costs of defense, settlement and reasonable attorneys fees) which it may # Figure C-6 (Continued) 700355 Contract? Page 4 of 5 hereinafter incur, become responsible for or pay out as a result of death or bodily injury to any person, destruction or damage to any property, contamination of or adverse effects on the environment, or any violation of government laws, regulations, or orders, caused by (1) the Customer's breach of any term or provision of this Agreement; (2) the Customer's transfer to MERECO of material which fails to meet the warranties specified on the GWPS and in the Agreement; or (3) any negligent or willful act or omission of the Customer, its employees or subcontractors in the performance of this Agreement. This obligation to indemnify, save harmless and defend MERECO shall survive the termination of the Agreement for such additional time as MERECO may be liable or potentially liable for its activities under the Agreement. 6.0 Notification Requirements and Work Orders 6.1 Any shipment of material under this Waste Code must comply with all the requirements of this Agreement. 6.2 Prior to delivering or releasing for delivery any material under this contract, the Customer must contact MERECO either by telephone or in writing and shall specify: (1) the Customer's name and address, (2) the Waste Code(s) included in the proposed shipment, (3) the proposed shipment date, (4) the transporter to be utilized, (5) the volume of waste to be shipped, and (6) whether the recovered mercury is to be upgraded and/or returned. Additionally, the Customer shall provide a signed, numbered purchase order referencing the Waste Code, the unit cost, and estimated total cost. # Verbal purchase orders do not. meet the requirements of this section. 6.3 After the Customer has met the requirements of Section 6.2 above, MERECO will assign a Work Order number for the shipment. The Work Order number will be valid for thirty days from the date of issuance. Both the Work Order number and the Waste Code must appear on the outside of each shipping container or drum, the packing list and in box #15 of the New York State manifest, if applicable. Shipments without a valid Work Order number will not be accepted. 7.0 Shipping Requirements 7.1 All shipments must be contained in lined DOT approved steel drums or pails. No plastic, polyethylene or corrugated container will be accepted. 7.2 Shipment of any waste from a health care facility must be accompanied by Certificate of Disinfection available through MERECO. 7.3 It is a NYSDEC regulation that all shipments of hazardous waste be accompanied by a New York State manifest and be transported by a Part 3 64 permitted hazardous waste hauler. This hauler must be permitted in New York State and show MERECO's Railroad Avenue facility on the permit. Manifests and names of permitted haulers are available through MERECO.. # Figure C-6 (Continued) C-^5 700356 OOOO Contract^ Page 5 of 5 7.4 All shipments of hazardous waste must be accompanied by a Land Disposal Restriction form. 8.0 Execution of Agreement 8.1 All provisions of this Agreement are severable and no provision hereof shall be affected by the invalidity of any other provision of this Agreement. 8.2 This Agreement is signed and consummated in the County of Albany, State of New York and the laws of New York State shall govern all disputes, .controversies and litigation arising hereunder. In witness thereof, the Customer and MERECO have caused this Agreement to be executed by their duly authorized representatives. Accepted by Customer Accepted by MERECO Co. : By: (authorized signature) (authorized signature) (print name) (print name) 4 Title: Date: * Figure C-5 (Continued) 700357 tacilitate onsjle storage and transport of the waste. Fo: further details on the precautions used for this waste consult Section D and F of this permit application. MERECO accepts reactive wastes from off-site generators in the form of lithium batteries. These batteries are stored on polyethylene containment pallets, segregated from aqueous wastes. The retort liquid generated by MERECO during the retort operation is an ignitable waste. MERECO will take all necessary precautions to prevent the accidental ignition of ignitable wastes. Ignitable waste will be separated and protected from sources of ignition, including but not limited to, open fleimes, smoking, cutting and welding, hot surfaces, frictional heat, sparks (static, electrical or mechanical) spontaneous ignition (e.g., heat producing chemical reactions) and radiant heat. MERECO does not store or otherwise manage wastes or materials in a manner which: 1. Generate extreme heat or pressure, fire or explosions, or violent reactions; 2. Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to threaten human health # or the environment; 3. Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosions; 4. Damage the structural integrity of the containment device or facility; 5. Through other like means threaten human health or the environment. MERECO does not mix incompatible wastes. C-4 7 Revision 4 August, 1994 1784h.BSC 700358 • APPENDIX A CORRESPONDENCE FROM REGULATORY AGENCIES REGARDING THE DEFINITION OF HAZARDOUS WASTE # 9/93 rev'd 1782h.a # 700359 New York Stale Department of Environmental Consen'ation 50 Wolf Road, Albany, New York 12233 FEB 24 iS94 Thomas C Joiilnq Mr.•Alan Wilds Commisaioncr Mercury Refining Co., Inc. Vice President Marketing and Sales 12IS Central Avenue Albany^ NY 122 05 Dear Mr. Wilds: This is in reply to your letter of February 3, 1994 in which you requested written confirmation that MERECO's summary of the regulatory status of dental trap amalgam under the Department's Part 3 64 and 37 2 regulations is correct. You indicated that the amalgam would be contained within a hard plastic trap that had been used to screen and collect the solids (consisting of scraps of teeth, gum, and primarily am.algam) resulting from the dental rinsate process. You also indicated that, after the trap .is taken out of service, it is filled with a disinfectant, sealed, and locked. With respect to the hazardous waste regulations, it is our determination that these solids qualify for the scrap metal exenptions of 372.1 (e) (2) (iv) and" 373-1.1 (d) (1) (vi) (c).3when they are destined for reclamation at MERECO. In addition, because the solution present in the sealed traps would continue to function as a disinfectant until it is separated from the 4 solids, it will not be a solid waste until drained from the solids (making MERECO the generator of that waste from the standpoint of the hazardous waste regulations). As a result, no hazardous waste manifest is required by New York State for traps destined for reclamation at MERECO. With respect to the Part 3 64 waste transporter regulations, because responsibility for this program has recently been shifted out of the Division of Hazardous Substances Regulation and into the Division of Regulatory Affairs (DRA), we no longer interpret Part 3 64 and would like to suggest that you contact Ms. Margaret Kelly, of DRA, (at 518-457-3254) for information on that aspect of your inquiry.^ ^Note: In addition to determining if the traps and contents qualify for the 364.1 (e)(vi) "scraps" exemption mentioned in your letter,,you might also inquire whether Part 3 64's medical w-aste regulations 364.9 (c)(2)(ii) or 364 . 9, (c) (1) (ii) (a) (i) apply. [364.9 (c)(1)(ii)(a){1) is worded the same as the 36[0]- 4 17.2 (h)(2)(a) referenced in footnote 1 of your letter.] ^ J £Ftot»fl on fecvc»*o p«o»« 700360 Mr. Alan Wilds • If you have questions about the impact of any medical waste regulations on your proposal, since both this Department's Division of Solid Waste (DSW) and the New York State Department of Health (NYSDOH) have such regulations, please contact DSW's Mr. Robert McCarty (518-457-7336) and NYSDOH's Mr. George Estel (518-458-6483) . Please call either myself or William A. Yeman, of my staff, at 518--485-8988 if you have questions on the hazardous waste regulations. r-rtl^'vn .j/. \^r-^lSjy Lawrence J, Na"aier, P.E Chief Hazardous Waste Compliance Unit Division of Hazardous Substances Regulation cc: R. McCarty 4 M. Kelly i 700361 New York State Department of Environmental Conservation so Wolf Road, Albany, New York 12233 Mr. Thomas J. Campbell Thomas C Jorllng Environmental Engineering Department MAY 0 7 1293 Commissioner Long Island Lighting Company 175 East Old Country Road Hicksville, NY 11801 Dear Mr. Campbell: This is in response to your letter of April 13, 1993 in which you requested confirmation that use of the commercial chemical product exemption of 371.1 (c)(iii)(Table 1) was appropriate for [unbroken] gas regulators, manometers and thermometers that are destined for reclamation of the elemental mercury. This interpretation can no longer be considered valid policy in the State of New York. When EPA published its proposed "Universal Waste" rule in the February 11, 1993 Federal Register, it became apparent to us that this policy would be inconsistent with EPA's position that the mercury in used equipment does not qualify as a commercial chemical product (specifically, U151) and is not eligible for the commercial chemical product (CCP) exemption of 371.1 (c) (iii) (Table 1),"". unless it is removed from the instrument/item. 4 Although we have strongly recommended to EPA that they allow liquid mercury encapsulated in unbroken equipment to be eligible for this exemption, for the pr esent we must consider used equipment to be spent material , and subject to the hazardous waste regulations whenever the unit fails the Toxicity Characteristic. We will still allow the CCP exemption for unused equipment, if the mercury rema ins in its original, unbroken chamber within the device and it is destined for reclamation. Enclosed for your use are two EPA documents^ which give examples of how the policy applies to specific wastes. Note from the Oleszko letter that, if the mercury is drained from the equipment at the site of generation and sent for direct beneficial use or further refining, the mercury is not a solid waste. The drained equipment would be a solid was be hazardous with the mercury removed. 1..Equivalen, t to EPA's 261.2 (c)(3)(Table 1) ^Letters of April 14, 1989 to R. Oleszko and 4 1983 to D. Stone. ^T J priniec Oft f»cvci»<3 &ao*T 700362 Mr. Thomas J. Campbell We regret any inconvenience this may have caused your firm. Please telephone me or Mr. William A. Yeman, of my staff, at (518) 485-8988 with any questions you may have. Sincerely, Lawrence J. Nadler, P.E. Chief Hazardous Waste Compliance Unit Division of Hazardous Substances Regulation I Enclosure \ 4 4 700363 -•- .••- ^^' i: . : • i< .•••• '-. c ATT ORNCVS /^~ l_^v.- ONE COMMERCE FLAZA _CC- - -OCCS ae CHunc.- STOCCT ALBANY. NEW YORK I226C BUTAI.O siCw TQOw IASOZ '71©: e5A-«A2o 'slai ..••o- 760C 'CLE COP" '. Siai -^B-33^5 CABLE ADVCCATC ALB*MT 0 AOOAOC -• C^LLiS ,A»-ES v.' v-'^TLC OCT 2 7 1987 S-JE eOSEMS^EriM KAT..AQIME K DECKER JOM ATTAIN* P NYE CiOMAuO S STCANSM "CMMCTM S BiTJENBCBC "AO* JAIME BEMOOM COUC> jEAr^ f CERBINI SAuu A> mCBEBC October 23, 1987 Mr. David Cohen Mercury Refining Co., Inc.. 26 Railroad Avenue Albany, New York 12205 Re: Mercury Refining— Purchase of Mercury Acetate Dear David: Recently you communicated that you had the opportunity to purchase some mercury acetate. The mercury acetate had never been used and is considered a commercial chemical product. Mercury acetate, however, does not appear in §371.4 of 6 NYCRR as a listed hazardous waste. In other words, mercury acetate, when discarded, is a characteristic hazardous waste — not a listed hazardous waste. I contacted the RCRA Hotline to determine whether a characteristic commercial chemical product going for reclamation is a hazardous waste. I was told that EPA indicated in the April 11, 1985 Federal Register (i.e., 50 Fed. Reg. 14217) that characteristic commercial chemical products going' for reclamation are not considered' a solid waste analagous to commercial chemical products listed in § 371.4(d). Please add this letter to your waste classification binder under the chapter on Commercial Chemical Products. Please call if you have any questions. Sincerely, Kevin M. Young 700364 N', A, rs' O £ ~ L :•"> f.-. A K L H A, rs' N A. vii/;*^AlL w»-iT»»-"A»^ AL»AMT orrics N-CLVIK M . C »" K S; fc-A >.,, J ». JC •^ •-A/<.KA JB. THE GL'AHAKTf CUILDINO O^fC CO.. TtLECO" lei»J •.••J3«I BUrrA,LO, NEW YQP^K l*ICJ ICC J «OVIAN CAlLt AOVOCATI AL«AMT (silCL A &'..20W # OOx'T't" CULL'' jAMce w L'-fLC • MI'.iB <->,DlXCN sue MOSCNGHCIN .iCVl N M. YOUNO •CATHABINC K. DtCKtB JOKATMAN *. NVl eONALO • •TCrAweKI nCNNCTM e. niTZKNBCnO BMILLIP 0. BTCCK MA*Y ^ANC aCNSON eouc» February 19, 1988 _icAN r. ccnaiNi 9AUU A. niceC"0 VIA TELECOPIER Kevin M, Young, Esq, Whiteman Oateraan & Hanna One Commerce Plaza • 99 Washington Avtnue Albany, New York 12260 Rat Goll«otion of. Mercury Batterieg Dear Kevin? Attached ie a draft memorandum regarding th« proposed collection of mercury batteries and the poaeibility of regulation under state and/or federal lava. My conolueion, that mercury batteries disposed of by houeeholdf are cxeapt from hazardous waste regulation, should not surprise you. However, I have been unable to contact anyone at EPX to discuss the policy considerations of this issue. Particularly, I have left several messages with. Matthew Straus this week, but he has not returned any of my calls. To cocplete my research, I would like to go through the complete legislative histories of RCRA and HSWA to see if there are any references to the handling of household wastes. I will complete that research by Monday. If you have any questions; please feel free to call me. Sincerely, h (TT^ Donald S, Stefanskl Attachment 700365 MIMCRANDUM TO: K. Young rRO.M: . D. Stefar.ski • RE: Kousehold Waste Exclusion DATEJ February 19, 1988 QUESTION PRESENTED Whether the central collection of mercury batteriesl by retailers which sell such batteries end the subsequent recycling/reclaicatlon of the batteries would be subject to state and/or federal hazardous waste regulations? CONCLUSION As long as the batteries are generated by consumers at the household level, they are "household wastes" and are excluded from the definition of hazardous waste pursuant to state and federal regulations. DISCUSSION A. Federal Regulation of Household Wastes # The Resource Conservation and Recovery Act of 1976 ("RCRA"), as originally enacted, does not contain any reference to "household wastes," However, the legislative history of RCRA is clear that "Congress did not intend householders to be considered generators [of hazardous waste], nor did it Intend that the type of waste substances normally used in households be included in the Subtitle C regulatory program," 43 Fed. Reg, 58969 (Dec. 18, 1978), citing S. Rep, Ho. 94-988, 94th Cong., 2d Sess,, at 16). Thus, the USEPA proposed a rule which stated that "Ia]ny person or Federal Agency who generates only household refuse ... is not required to comply with the requirenents of this Subpart li.e. , Subpart B — Standards Applicable to 1 This memorandum eddreBses only batteries used in households and assumes those types of batteries to be isercury batteries. Spent lead-acid batteries are subject tr regulation under RCRA. See 40 C.F.R. .261.6 (a) (2) (v). 700366 ' z- Generttors of Hazardous Waste], Proposed 40 .C.F.R. _250.20 (c) (4) .2 The final rule, pronulcated by the USEPA in 1980, changed the focus of the proposed rule from exempting the generator to exempting the waste etream. Apparently, the USEPA believed that this change Tn focus was more in accord with the legislative intent, relying upon the Senate Report cited above: [The hazardous waste program] is not to be used to control the disposal of substances used in households or to extend control over general municipal wastes based on the presence of such substances. The USEPA emphasized that the household waste stream «.di1 d not lose the exclusion slrcply because it [had] been collected" and that household waste was "excluded [from hazardous ' waste regulation] in all phases of its management." 45 Fed. Reg. 33099 (Hay 19, 1980). However, household wastes were still subject to Subtitle D requirements (solid waste management). In response to comments on the 1978 proposed rule regarding whether certain materials (medicinal drugs and ointments, household cleaning agents and solvents, waste oils, paints and pesticides) should be included in the definition of household refuse, the USEPA stated that such naterials "may be disposed of as part of a consumer's household wastes." Id. Therefore, "[i]f a household disposes of such wastes, the wastes may be subject to the household waste exclusion," Id. The regulatory scheme finally pronulgated by the USEPA at 40 C,r,R, 261,4(b)(1) provided that household waste, « including household waste that has been collected, transported, stored, treated, disposed, recovered ... or reused" was s solid waste which was not a hazardous waste. "Household waste" was defined as any waste material derived from households.3 2 "Household refuse" was defined as "trash- or rubbish ordinarily produced by a family at their home." Proposed 40 C.F.R. 250.21(b) (11). 3 In 1985, the USEPA revised its definition of solid and hazardous waste but did not revise its regulation of household waste. 700367 -J- . Clearly, the USEPA intended to exclude from Subtitle ecuiation &ny wsste generated by a household, from the monent of its generation through all phases of its msnagenient, including residues remaining after treatment, Therefore, the critical eleff.ent in determining whether the collection of batteries may be subject to regulation is whether the waste (i.e., the used batteries) was generated by a household. Congress has never emended RCRA to reflect the regulatory household waste exclusion. However, Congress clearly was aware of the USEPA's action, as indicated by the Hazardous and Solid Waste Amendments of 1984, wherein Congress added a new section to RCRA entitled "Clarification of Household Waste Exclusion." Although this section on its farce addressed only the coverage of the ho'usehold waste exclusion with respect to resource recovery facilities recovering energy through the mass burning of municipal solid waste, the legislative history of this section evidences Congressional awareness that household wastes were not regulated at all under Subtitle C, See S. Rep, No, 98- 284, 98th Cong., 1st Sees., at 61. [Paragraph re: EPA policy position on battery issue) B. State Regulation of Household Wastes The New York State Department of Environmental 4 Conservation hazardous- waste regulations are identical to the federal hazardous waste regulations. That is, 6 NYCRR 371.1(e)(2) provides that household waste is a solid waste which is not a hazardous waste and defines •household waste" as "any waste material derived from households." The DEC, however, has recently indicated its desire to regulate "batteries" under its hazardous waste program. In its responsiveness summary to its March 31, 1987 Solid Waste Management Plan, the DEC stated that . Batteries containing corrosives and/or toxic heavy metals should not be disposed of as daily residential municipal solid waste. If not recyclable, they more than likely should . be disposed of as a special or hazardous waste. * * • The DEC will evaluate (nickle, cadmium, mercury) contained in the household hazardous waste stream. Sources of such potentially recyclable metals 700368 -4- includa batteries, calculators and household appliances. The DEC expressly addressed batteries in its December 1587 Update to the Solid Waste Management Plan: To assist removal of heavy metals from the waste stream, DSC intends to propose legislation in 1988 to encourage recycling batteries. A bill regarding battery deposits was proposed in 1987 but did not become law. Thus, the DEC has indicated that it will encourage the recycling of batteries (or at least their removal from the household waste stream) but apparently will not attempt to redefine the household waste exclusion to regulate batteries. In conclusion, under both the state and federal hazardous waste schemes, a used battery disposed of by a household is not a hazardous waste and does not become a hazardous waste at any point in its management, regardless of whether it is collected by municipal haulers or at a collection center for recycling/reclamation purposes. The # state, however, has indicated that it will seek to regulate batteries in the future. # 700369 V^HITEMAN OSTERMAN (S. HANNA "ic"ACL WM,TE"AN ATTORNEYS AT LAW . , jO'-N «AMMA jc ONE COMMERCE PLAZA , ~ ^OC. L. •-ODES ^"C ^^*«*-T. eu,LO,.C P,..,L.P « C.TLCN ALBANY. NEW YORK I2260 '" CHUBCH STBECT ,,_,, r^ eurrALC. Hcw ,OB« ,Aic2 ECSTTN.FE.N ISiei -^9-7600 l"61es-...,o ALICE J KRYIAN TELECOPY ISIBl --.e-3345 OA>v.CL A. Pu;ow ^e^j. ADVOCATE ALBANT PW ILIP M. OIXON KCvir4 M YOUNC JAMES w LYTLC GUNTCR DULLY JONATHAN P. NYE KATHABINC K. OECKCB LISA K. KILL PHILLIP G. STECK KENNETH S. RITZENBEBG MARY _IANC BCNDON COUCH JCAN r CERBINI DONALO S. STETANSKI Hay 1, 1987 Mr. David Cohen Mercury Refining Co., Inc, 14 Commercial Drive Albany, New York 12205 Re: Scrap Metal Dear David: Last week, at your request, I researched the issue whether the battery casings remaining after mercury was m removed by retorting were exempt under the scrap metal exemption of 40 C.F.R. 261.6 (a) (3) (10). At that time, I posed this question to Debra McKie of the RCRA Hotline. Ms. McKie was unable to answerray question, but she stated that she would inquire of Matthew Straus of the Office Solid Waste of USEPA regarding that issue. Mr. Straus stated that the battery casings from the retort process are scrap metal and are exempt from regulation under 40 CFR 261.6 provided they are being recycled. As we discussed, I will attempt to obtain written confirmation of this interpretation from Matthew Straus's office. Sincerely, Kevin M. Young # 700370 WHITEMAN OSTERMAN 5. HANNA »-ACL W*- 2).^ N «ANNA.JC ONE COMMERCE PLA2A THE CUABAKTY BUILOINC CL L "ODES ALBANY. NEW YORK I2260 26 CMURCH STOCET p tH G 'TLE N SUTALO. NEW YOOR <*!0! 4 •r N. rciN ISiel A^9 7600 I7i6i eSA-..A2o r J KOYZAN TELECOPY ISlSI *^9-33.«S CABLE ADVOCATE ALBAWY DANIEL A. 0U20W WILLIAM r DUKER t3« I L( p H. DIXON O^ COUNSCL •^EVIN M. YOUNG JONATHAN p. NYE KATHARINE K. DECKE" SEBSA A. COHN LISA K. KILL PHILLIP G. STECK MAOY JANE BENDON COUCh JEAN r. GEBBiNI December 1, 1986 Mr. William Carter, PhD. 303 Clinton Street Fayetteville, New York 13066 Re: Mercury Refining Solid Waste Issue Dear Bill: I have investigated the possibility that Mercury Refining's Process is not a reclamation process, but rather a direct reuse of mercury. The people that I spoke with at USEPA indicated that it wasprobabl y a reclamation process, They were not aware of any interpretation which indicated # that a physical separation process was not a reclamation process. You should proceed under the assumption that Mercury Refining' s process is a reclamation process. I have also enclosed the contract agreement that you prepared and forwarded to Mercury Refining under your cover letter on November 20, 1986. Please make the modifications shown, add the insurance paragraph from the Karg Brothers contract, sign the agreement and return it to Mercury Refining for signature. Sincerely, Kevin M. Young Enclosure cc David Cohen # 700371 APPENDIX B CHARACTERIZATION DATA PROVIDED BY MERECO'S CUSTOMERS THROUGH THE USE OF GENERATOR WASTE PROFILE SHEETS # 9/93 rev'd 17B2h.asc 700372 MERCURY REFINING COMPANY INC. OFFICE USE ONLY ^ No. 8861 GENERATORS WASTE PROFILE SHEET Rene^^l ^\J(^ ~\ -9~ 3 Sample No. EPA ID NO. NYD04B148175 WS Waste Code igV£-| -^C^ .© 1216 Cenual Avenue Rec Reviewed Bv r^ /?7£BI Albany, NY 12205 CR Approved By ^^t\ / I'Z.J^^' I. GENERATOR INFORMATION Bill 10 _p..C)^£^x_:ifte (S?v^r>iv^^TDO ^ ^T" oS 2-0 ) Name EN/ II. SHIPPING INFORMATION ^ DOT Shipping Name RQ, l4tX ^fco V AQUS W"A^"t/ , SO I I" d , n • O. S. lX>O0'\) UN/NA Number fOA-^-lZl Hazard Class .2 EPA Vj'as'te Code(s) T>OC>^ -t- LAUTI ft>^'^ ' <^L«^^s III. WASTE IDENTIFICATION ->w Generators Name for Waste ^ (Lr^AO N >^ r^^r'K, O X icLe^ UlholcCeUS LC^^^^Xt^ / Process Generating Waste NA i ^TN v ^-Kvs^ Pr \ ^CtP^\ i •nui. Q)^\\cr\J M.gl r\C/fx c4-U IV. WASTE PROPERTIES KJ/A t^/A. 4 Physical State: [ ] Liquid ( ] Mud/Sludge [)^ Solid Density: __ J^S" .Ibs./gal. pH: Flash Point. Describe any special handling requirements associated with this waste stream: Range Range V. WASTE COMPOSITION min - max mln - max 30-^0 % taK tr ^^^())^ 4-6 .% K\fl.Avartg.s«^ VioyCietc Gvg-pt^t ^ .% !^_!:VC-TQ.VA1CU^ - ._, ^A-ii "z. M^^TAXVM 25: TOTAL 100% Mln VI. WASTE INFORMATION YES NO Radioactive materials Does This Waste Contain: YES NO Oxidizers )0^ Halogensi'i » ( ) (^ Listed Hazardous Wastes other than U151 ) (/J PlasticsC^^SUU ) (K) ( ) Contituents other than mercury Free liquid (other than mercury) ( ) (X) subject to land disposal restrictions"" ) 0<) Dioxins ( ) (X) California List contituents (liquids only) •" )0^) Oils'" ( ) ( ">f Acute Hazardous Wastes )(> VII, I anesI and certify thai all inlormalion provided is complete end accurBte and in accordance witn40CFR261 and New Yortt State regulations 6NYCRR371. This waste material to pfOp*rtyde»a1b«dwf!h no wil'lul omissions in the mlorTnalion, Any changes or eddilional tnformalion obtained atxjut ttits waste sueam will be ptomptty and correctty conveyed to Mercury Refining Co. tf any toad It rejoded by Merojry Refining Co for any reason, our company will assume responsibility tor fiaving the load removed from the site as soon as possible. Our company agrees to pay for any tesflr>g. decontamrrialton, tranaportaOon or disposal lor any materia3Il sinipB^i OFFICE-White CONTRACTS • Green. Canary f LANT - Pink CUSTOMER - Gold 700373 MERCURY REFINING COMPANY INC OFFICE USJSEi ON_LONLY p-^ No. 9036 " GENERATOR'S WASTE PROFILE SHEET Reneewaw J Sample No. ^ EPA ID NO. NYDM8148175 WS Waste Code £gS-i ' 1218 Central Avenue Rec • — - •! -• Reviewed By^?»tvS Albany, NY 12205 l^\ S a533> CR Approved By KA > li I. GENERATOR INFORMATION Bill to Name ESSEX WASTE MANAGEMENT SERVICES Facility Address ^148.3_SW__58_JilGHWAY Contact -KgJ^LA TUt3GATE- — KTNG,SVTTJ,E,_ MO fi4Q£l Phone: B1.6r232:i53fel , .FAX:__gl6-732-e2QO EPA ID No. Map9_809628_4? Send Contracts to: BILL CONKLING Technical Contact _BJ_Lki^Sifa^iNGZMailCA_ B.AKER_ Phone: B16-732-5561 FAX: ei6-732-6200_ Contact: Phone: _ FAX: II. SHIPPING INFORMATION DOT Shipping Name ____JBQj_HAZi MERC.UR)L_CaSIMINM:BD_DEBjRLSl UN/NA Number NA 3077 . Hazard Class ^ EPA Waste Code(s) _DO092 III. WASTE IDENTIFICATION Generator's Name lor Waste. MECURY _C(DNTAMINATED DEBRIS Process Generating Waste MERCURY SPILL CLEM^UPS, BROKEN THERMOMETERS, CCMTAMINATED CLOTHING f pjcO Estimated Annual Volume 4 DRUMS PER YEAR .Container Type/Size. 55-.GftT, 17H STEEL uypnly l|Me< Mercury Contaminated Debris Mercury-in-Glass devices Mercury Coritaminated Spil Other (please specify). — (specify type) Mercury Contaminated Materials Mercury Compounds Batteries IV. WASTE PROPERTIES Physical State: [ ) Liquid [ ] Mud/Sludge [ ^ ] Solid Density: 20 lbs./gal. pH: U/^i Flash Point s 200 Describe any special handling requirements associated with this waste stream: Range Range V. WASTE COMPOSITION min • max mln - max MERCURY \ 0 -10 •/, BROKEN THERMOMETERS 10-20 PERSONAL PROTECTION EQUIPMENT 40-50 SPONGES & ABSORBENTS 30-40 {LATEX_GLqVESj__MITRILE GLOSVE, TYVEKS, EMPTY~GLAis7PLASTIC CONTAINERS 0-10 .% vfNYL GLOVES', PL'ASTIC APRCWS, ETC.) TOTAL 100N Mln VI. WASTE INFORMATION YES NO Radioactive materials ) Does This Waste Contain: YES NO Oxidizers ) Halogens'" (X) ? Listed Hazardous Wastes other than U151 )UC) Plastics @!x ( ) Contituents other than mercury Free liquid (other than mercury) subject to land disposal restrictions'* )(^) Dioxins Vll. I Btiesl and cenity thai all inlormeilDn provided is compieia and accurate artd in accordance with aoCFn261 and New YorV Slale regulBlions 6NYCRR371. This waste material la p*tp«i1y da»CTlt»dt«tth no willful omissions in Ihe inlormaiion. Any changes or additional inlonnaiion obtained about this waste stream will be promptly and correctly conveyed to Mercury Refinirtg Co. H any load It r»fec1ed by Merrufy Redning Co. lor any reason, our company will assume responsibility lor having the load removed from the site as soon as possible. Our onpany agrees to pay (or any tasting, deoonumtnatlon, tr»n*ponatlon 01 disposal lor any malerial shipped to the Mertury Refining_pp. sHa tirhich does nol fully comply with the pernih limits es specified to our company by Mercury Rellnlns Co. Generator's Agent lyU^yUj^y^^'L^LkllAy. Date OFFICE USE ONLY TCLP Metals PCB I I STABILIZATION OFFICE-While CONTRACTS - Gtpen. Canary Pl^NT - Pink CUSTOMER - Golfl- - 700374 f^.UL- t. <• MERCURY REFINING COMPANY INC. OFFICE ySE ONLY No. 8562 GENERATOR'S WASTE PROFILE SHEET Renewal Yf^Cj ' Sample No. EPA ID NO. NYD046148175 WS ______,_ _/_ Waste Code "F^Q-^-S? :Q 1216 Central Avenue ,—^-.^-^^ Rec _Q,_<-_^S3L//h'>r! R^iewed Bv'&J^ ^jqg, Albany, NY 12205 o/jj'^ -^ CR ; ^Xpproved By tS^IfiHs I. GEiJERATOR INFORMATION Bill to -?j:?A.cc-^^-Ls;j:..._l)iiLp5 Name .W^.4-ljZA4:_ B i AA J_0 Technical Contact ILC_? vi.t?^_0^^.»_\_C_£r ! Phone: 5.'l:1^'l'?00 FAX: «9l5-M^''v/ II. SHIPPING INFORMATION DOT Shipping Name .SjS.^JripAATA'lzAl Jy>/i-^_^l6._SD]x^ UN/NA Number 7^ A '^ I ^^ ^ ^"^ Hazard Class ,£)Sk.CCl:.S^.^ ^ EPA Waste Code(s) DoO^\ III. WASTE IDENTIFICATION Generator's Name for Waste Flt:)or IV. WASTE PROPERTIES * Physical State: [ J Liquid ( ] Mud/Sludge ^< Solid Density:. Jbs./gal. pH: Flash Point. Describe any special handling requirements associated with this waste stream: Range Range V. WASTE COMPOSITION min - max mln - max TOTAL 100% Mln VI. WASTE INFORMATION Radioactive materials Does This Waste Contain: YES NIO f^ Oxidizers Halogens'" Listed Hazardous Wastes other than U1S1 Plastics Contituents other than mercury Free liquid (other than mercury) subject to land disposal restrictions'" Dioxins California List contituents (liquids only) "• Oils'"' Acute Hazardous Wastes PCBs (7-) Beryllium Pesticide/Herbicide (>C) 'Magnesium metal Asbestos Selenium Soil from uncontrolled disposal site'" lit ti-/ES' D'»"»a •n VII. : attest andcenify thai ail intcmationorovided ts complete and accurate and in accordance with aoCFri26l and New Yor* State regulations 6NYCRR371. This waste matenal is property descnbeo with nn willful omisstons m the mtormation Any cnanges or additional inlormaiion rbtained about this w;tste stream will Oe promptty and coneciiy conveyed to Mercury Relining Co. II any load ii retected by Mercurv Rellnlr^g Co tor an> reason, our cnmoany will i^ssume responsibility for having ttie ioao removed Irom tne site as soon as possible. Our company agrees to pay lor any testing, decontamination, transportatton or d'sposat lor anv ma'enai snipped to the Mercurv Peli'/niTyio. site wnich ones not luflv comply with the permit limits as specified to our company by Mercury Relining Co. Generaior's Agent j^X-^ .^.._sy-<\-\ OFFICE USE ONLY m TCLP Metals '~": PCB i ~ STABILIZATION ANT CUSTO^.^!"R • Gold 700375 Nn, MERCURY REFItJING COMPAtJY INC. ')! H(,~F: U?f. ONI.N 9238 O - GENEHAIOnS'^VASl t pnoriiF yiEE1 nciipwal Sample No. F.PA in rjQ rjYDO'ini/iRi:?. Wf \Vn<;te Code . 1 '. l,"" in _'. r^'!inl A .-nnii" Rpr < Reviewed By Alt-.-lnv. 'JI' :?.2'.:^ cn Approved By k'A-^fT' tf^^i; I. GENERATOR INFORMATION pill Ir ^•anie ,f^,.,^_ Long Isianc] Lighting Company F.-,.:.,i,i,. A-Mi^s? 1"-"' E- Old Country Road ':::viiqci Bart Polizzotti Hicknvi].l.e, Uev York 1180.1 n,.„„;516-933-551' i rAX:51^-933-5541 ^P,^ ,„,,.., NYD0068G6003 ,<5nii^ Co^t•.^^l?to:^'If-CO - Purchcising Department lr,.!,n;.-;-,|r>.nl.-,:I RobJH Kn^ppe 445 Droadholiov.' Road riKiti,:^,516-391-6590 FAX- 516-391-6500 Melville,- New York 11747 Coiiinct: ^1l^• B. Eter'no . '_ Phono 516-391-6000 TAX: 516-391-6075 II. SIIIPPirJG INFORMATION ixn .'=;iiii'pifif] Mnnin^^^s^te Mercury Contained in Manufactured Articles yy) 1,111 IJA lliitiihoi UN2B09 Ha?ntc1 Cla*:? 8 \r- >. EPA Waslo Coilo(s) D009 III. WASTE IDENTIFICATION G.,-^.nlor.Nni„o(nrWn.lc ^^^^'^^^'^y ^-g^^S'^^'^S .. .._.. rrn^o?-. Go„o,,'3ii„gwn="5 f^^tirement of Gas Equipment fr-tiif.nieri Anoiini voHiio° ^00,000 Poumas .Coiii^m<>i Type'Size 55 .Gaik^i'3'^..DOT..P_rums M"iriirv Ccnlnininalod [lohris Mercuryin-Glaf s rtnyicf = M°ir;iiiv Containinaled Spil Ollmr Iplease specify) ' lKpocif>'Typi?) • K Mrririiiy Tloii'oirinaleri Mnl9ti,?!s Mercury Oompounrts B?ll IV. WASTE PROPERTIES riiy.i'-i! Sni": ( 1 Liquid ( ) MiirJ.-'Sludge ( XI Solid Dr^n-.ily ibs./pai. pH: ...^'one^ Flash Point ...None_ -F 4 r)ocrrit-io nny <;p«?r:i.il hanrlfinrj fprjtiitfimoritR associated with thit? wnsli? .stro,qrn; rtange Range V. WASTE COMPOSITION min - max mln - max Mercury 1-10 Rubber (gaskets) "5 y'lr," 75 "_ 95 Metnl Casing (steel) TOTAL 100% Mln VI. WASTE INFORMATION YES MO Rarlioactivp mateiials )(x) n^"': Tlii? Waslo Conlain YES NO OxWizeis ) (X) 1 l.-il'-iri--?(ic"'- ( ) (X) Listed Hazardous Wastes other than U151 ) (X) PlrKfi—. ( )(X) {i^\ Contitueiils other than mercury FiO'! Nniiirl (olh»i tt-.nn n-orcury) ( ) (X> subject to land disposal restrictions''" )(x) fli^yil.c ( )(x) Cnlilornia List conlitiients (liquids only) '•'' )(X) Oils' • ( ) (X) .Ar;iift; Ha/ardou? Wastns )(x) rr.n-, • ( ) (X) Perylliitni )(x) rv..-.t.>i'(o||oiiiirir|o ( ) (X) Wionesiiim n\f>lal )(X) ,Ar.|,„-|,..c ( ) (X) S^lfniitni ) (v) Soil liom uncontrolled disposal sitp'" )(^) I' .T"- . fir-" .' -.-iii-.i, >n.ii/---«i'i III >?."= (.!•'!«•!•• ,^inrt> tCI 'tn-o"! TOf'r-^'i''^ Lwtl !»"«! VII. 'ifv th.ll Tl rnl»'*M.'*ti'"'>i".-<-,t'i'V'Ii-. rittu\:\i^\n ntiri T'CwT" ?"cl"> '^C'"'"'"'!.i;»rr v.i'h-'ni •-! P?''^} .t<"j rj«w Ynik ?t.itn tpp'ii.-itiii": (^rjvcnm^i. This wa^terriairrmi is property de«r''h'*!iwi»'> •^rr.-.villti^^pMtnr'W firirlcpi'rr'lv ^"V'*\«"11''>M*"n n''v Prl-i^ing CO- " '*"> 'oadil i**|**rl?rthy M»if.\iiV "•"'' 1 " •• )•' T'i\ t^T-.i.ti. 2;" rnim.'''i.\ v.-i'.•«':•.• -_ ,.•'.r••*•'^^^•"h\\• IT Itavttin I'l^ 1";^^''rn—.-"Cl'"-Mi'hn -.'f. .">r ^.viti n'-. p^'S'l-'r '^n' C'"nr'"n "'UT''" '"pny (il nny tpetinQ. r1r'"nnI»rnin.-»1ion. |».nt«ir"'^-»)i •'! l"^MM.l iinijc .->« r-fCilirrl t' r«iir •• vj.plc. \\\ Mr^-'irv nr^'i'm^O C^ Dato l/y:ib^.- CMTlCr U?F OMLV ^^ ^ ^ ICLP r.lpials 4 f'CR STABILIZ.AnON (Tnrr . vVhti.' Cnrirf!'\rTS-G-""'i. r-araiv r^AIlT Pink rtiSTOM'^n-Gold 700376 liAtRGURY REFINING COrylPANY INC. OFFICt U5t ONLN ^0. 927 1- . ^ GENERATOR'S WASTE PROFILE SHEET Renewal Sample No. Xl-H^'^ -y EPA ID NO. NYD04E146175 WS _l_ " Waste Code 1216 Cenirei Avenu:nuEE Rec y _ .• ,1 RevieweHeviewed BBy JQ^ Albany, NY "122^ f' .U^V '^ ^1^ \C^(yjE)CyS^ V^iC^ Approved By -J^ GENERATOR INFORMATION Bill 10 -Xne_r]rLD_Ci?_r_iLiiaiiiir..s_ Irvin Plant/ Mon Valley P.O. box 4 84 ,^g^,g United States Steel Braddcck, PA 15104 Factlitv Address Cam;: Kollo V Rd . PO Box 878 Contact Robert C . Andrews Dravosburg , PA 15034 Phone412-351-1536 FAX412-351-1 54 3 EPA ID No. PAD 004 379. 061 Send Contracts to: Same Technical Contact Kathleen Mayer Phone:^12-675-7381 p^x', 412-466-1232 Contact: Same Phone: Same _FAX: Same II. SHIPPING INFORMATION DOT Shipping Name Hazardous Waste, Solid, N.O.S. (Contains Hq/EPA TOX D009) UN/NA Number NA 3077 Hazard Class ^ PGr^--^ EPA Waste Codecs) D009 III. WASTE IDENTIFICATION Generator's Name for Waste Mercury Contaminated Materials (Hand Cart) 1 Process Generating Waste Used to transport vessles containing mercury . '_^ ' Estimated Annual Volume 1 Drum 5 pieces Container Tvpe/Size55 gallon Steel drum w/liner Mercury Contaminated Debris tvlercury-in-Glass devices Mercurv Contaminated Soil Other (please specify) • "~ — ' (specify lype) ' . X_ Mercury Coniaminated Materials Mercury Compounds Batteries IV. WASTE PROPERTIES Physical State: [ ] Liquid [ 1 Mud/Sludge ?i)Q Solid Density: Jbs./gal. pH: N/A Flash Point NONE 4 Describe any special handling requirements associated with this waste stream: Range Range V. WASTE COMPOSmON-s^^ min - max mln - max >) Hand Cart (grte^ \^ Metal 94 Rubber Hg less tban 1 TOTAL 100% Min VI. WASTE INFORMATION YES NO Radioactive materials ( ) (X ) Does This Waste Contain: fES NO Oxidizers ( ) k ) Halogens'-' ) (>^) Listed Hazardous Wastes other than Ul 51 ( ) OC ) ,_, Plastics ) (^) Contituents other than mercury ^. ^:^ Free liquid (other than mercury) ) (X) subject to land disposal restrictions'" ^) (X ) 'W^ Dioxins )(X) California Ust contituents (liquids only) "' ( ) K ) Oils''' ) (X) Acute Hazardous Wastes ( ) ^ ) PCBs )(X) Beryllium ( ) (!C ) Pesticide/Herbicide ) (X) Magnesium metal ( ) OC ) Asbestos ) (X) Selenium ( ) OC ) Soil from uncontrolled disposal site'*' ( ) ^ ) tD It'YES', oieasesnacr^ Total Org2nicHsioQens analysts. 2! H'^'EE*. ?ieas« anacn PCS aruitrsis. i3) If "VES*. ?iaas« suDoiy analytical results |4) tt "YES*. ?i«as« artacn TCL tTargat Comoound Ust] analysis. VII. ! attest ano cenifyihat ail information provioec :scompieie anoaccuraieancmaccoraance wim40CFR26i and New York Slale reguiaiions 6NYCRR371. This wasie maienalis properly aescnbeo witn no wilUul omrssions tn me information. Any cnanges or aocilional information oDtameo aooui tms wasie siream will be promptly ano correcify conveyea to Mercury Refining Co. If any load is rejected by Mercury Retining Co. !0' any reason, our company wiUaafumaresDOnsibtlitylornavine me loao removed Irom me site as soon as posstbte. Our company agrees lo pay lor anyiesimg. oeconiaminalion. transponation Df oisposai for any maiertai snipped lo '.uL^^^v^r^i .*fefininaCo. site y/nicf/oTfes not fully comply witn m;ne permit iimit&«s specified to our company by Mercury Refining Co. Generator's Aaent Date .^AM- PFFICE USE ONLY TCLP Metals CLoci-,<-fi-cJbXsL PCB STABILIZATION OFFICE - White CONTRACTS - Green. Canary PLANT • Pink CUSTOMER - Gold 700377 •i' •- ' I - \! MERCURY REFINING COMPANY INC. OFFICE USE ONLY .\'0. GENERATOR'S WASTE PROFILE SHEET EPA ID NO. NYD04814ei7£ Renewal Sample No.. Office: 1218 Central Avenue. Albany. NY 1220: rOuncec i9£; WS Waste Code NCjfz-' Uy^ Plsni: 25 Railrcac Ave.. Albany. NY 12205 Rec Reviewed By "3AS HJ°J'i CR Q) ^^-^*^ ~)3r'^ Approved By Y^lfTJ iWjiQJ I. GENERATOR INFORMATION Dill to Northeast Environmental Services, Inc. R.R. f/6, Box SB ,\ame Northeast Environciental Services, Inc. Canastota, NY 13032 Site Address R-R- :/6, Box 8B Contact Robert Miller Canastota, NY 13032 Phone: 315-697-3979 FAX: 315-697-3867 EPA ID No. NYD 057 770 109 . Send Contracts to: Northeast Environmental Services, ^n^ Technical Contact Garry Kosmoski R.R. t-'/6. Box 8B Phone:315-697-3979 FAX- 315-697-3A71 Canastota, NY 13032 Mailing Address Northeast Environmental Services. Contact: pA/m-y ^o^mos-Lci R.R. ii-'6.. Box 8B-Canastota. NY 13Q3ghone: -^jl 5-697-3979 FAX:' 315-697-3471 II. SHIPPING INFORMATION I DOT Shipping Name Waste Mercury Compounds , Solid ,N.O. S .* ^ Hazard Class 6. 1 UN/NA Number UN20? 5 Packing Group T , TT , TTEPA Waste Code(s) nOOQ \0\\ w III. WASTE IDENTIFICATION Generaior's Name for Waste Mixed Lab Pack Chemicals Process Generating Waste. Discarded Lab Chemicals X^ / Estimated Annual Volume. 500-1000 lbs. . Ccntainer Type/Size 17H/30.55 gal polvlined Mercury Contaminated Debris Mercury-ih-Glass devices Mercury Contaminated Soil Other (please specify) Mercury Contaminated Materials Mercury Compounds Batteries (specify type) IV. WASTE PROPERTIES Physical State: % Liquid _ % Mud/Sludge ^^.. Solid Density: lbs./gal. pH: NA Flash Point NONE |) Describe any special handling requirements associated with this waste stream: Range V. WASTE COMPOSITION min - max Mercury Compounds Q^ See Attached List VI. WASTE INFORMATION YES NO Radioactive materials Does This Waste Contain: YES NO Oxidizers ) Halogens'" ( ) ( X) Listed Hazardous Wastes other than U151 ( )(X) Plastics ( ) ( X) Contituents or characteristics other than mercury Free liquid (other than mercury) ( ) ( X) subject to land disposal restrictions'* )(X) jDioxins ( ) ( X) Nickel and/or Thallium (liquids only)'" ) CX) 'OilS'=!i ( ) ( X) Acute Hazardous Wastes ) (X) PCBs ( ) ( X) Beryllium ) (X) Pesticide/Herbicide ( ) ( X) Magnesium metal ) (X) Asbestos ( ) ( X) Soil from uncontrolled disposal site'" ) (X) (1) tt'YES'. please anacn Total Crpanic Halogens aniiysis. 21 it'YES', please attacn PCS analysis. <3) it "VES*. pieasa luooiy analytical results |a) tt^fES'. please anacn TCL rTanjet Compound Usti anatysts. VII. I attest ana cemty mat all miormation provtaea is complete ana accurate and in accoraance witn AOCPR26I ana New Yoni State regufarions 6NYCRn37i. This waste material is properly oescnoed H\\n no willful omissions m tne inlormation. Any cnanges or aocinonal information ootamec aoout tTiis waste stream will be pfompiiy and correctly conveyed lo Mercury Refining Co. If any load is reiectea 5y Mercury Refining Co. for any reason, our comoany will assume responsibility (or naving me load removed from the site as soon as possible. Our conipany agrees to pay for any testing, aecontammation. transporration or disposal foor any matenal sniopea to tne Mercury PelimnHefinmgi Co. site wmcn aoes not luily comoiy with the permit limns as speafied to our comoany Dy Mercury Refining Co. Generator's Agent /ra^^—n .Date (^-9-9'/ OFFICE USE ONLY J TCLP Metals 'RtK^ft^'^^S^ I>ios^ be. d^rc^iid p.r-iiif -tc aK.pfAenCr m J PCB Analysis J Halogens OFFICE'White CONTRACTS - Green. Canarv PLANT-Pink CUSTOMER - Gold 700378 MERCURY REFINING COMPANY INC OFHCt USE ONLY No. 104 0 GENERATOR'S WASTE PROFILE SHEET EPA ID NO. NYD046-148175 Renewal Sample No. [ Cj I C:>S, Office: 1218 Central Avenue, Albany. NY 1220; =cunaec i955 WS Waste Code~^^£!3H5^ Plant: 26 Railroad Ave.. Alfcanv, NY 12205 Rec f^K,' ±L :^r>'u^yi - Reviewed By "3^ "^jCi y_ ,. Approved By W^BKM^^' GENERATOR INFORMATION Billtc yri ( i°<; A Name I) 5 B P (\ ^^ Cr^lO ^S V / I Site Aocress / 7/2. Wei> "^ S^^^/nY/t S'/Tfe"^ Contac; "]^AAJ|C"(_ .J. U/tZ-^Or-t Phone: ^ ;*j' - S-^?.JI - -? (r d, /O FAX: .gW-^^B t-- / (U cr II. SHIPPING INFORMATION f DOT Shipping Name R (!^ \ji.\ (K-tTTE Ho I ^onotj ^ S 0 ) I d J n . c 'S (J^-erC u i~vj Hazard Class Cg • I (^NA Number 2 £^' Packing Group i I EPA Waste Code(s) U / -S" J III. WASTE IDENTIFICATION J_ i I M Generator's Name for Waste Process Generating Waste Ch,/at->'/-i ^/ct^/r>a co/ M. 2 .:Sfir/a. hrf^ys- ^^^ U oA hi Tfirri;^e^y ^Artnfxy /r> / d Estimated Annual Volume 3 Range V. WASTE COMPOSITION W^jPj max y^\ ^r)il. ^r-iss. .^cflC 99- /eo % % VI. WASTE INFORMATION YES NO Radioactive materials Does This Waste Contain: YES NO Oxidizers Halogens'" ) Listed Hazardous Wastes other than U151 Plastics ) (^ Contituents or characteristics other than mercuiy Free liquid (other than mercury) ) ly subject to land disposal restrictions'^' Dioxins ) (^ Nickel and/or Thallium (liquids only)'" OilS'2' , ) (^ Acute Hazardous Wastes PCBs ) {•y Beryllium Pesticide/Herbicide ) (^ Magnesium metal Asbestos ) Soil from uncontrolled disposal site''*' (1) it 'YES*. pi0 VII. ! atiesi ana certify that all information provioea 'S complete and accurate and in accordance with -lOCFRSSI ana New York State regulations 6NYCnR371. This waste material is property descnoed *ith no willful omissions m tne miomiation. Any cnanges or aaaitional iniom-iation ootamec about this waste stream will be promptly ana correctly conveyea to Mercury Refining Co. If any load is reieaec oy Mercury Refining Co. (or any reason, our comoany will assume responsibility (or having the loao removeo Irom the sue as soon as possible. Our company agrees to pay (or any testing, decontamination. transportation or aisoosai for any matenal snippec to tne Mercury Refining Co. site wnicn ooes not fully comply with the permit limits as soecifiefl to our company by Mercury Refining Co. Generator's Agent. "H^CLyy) ^ ^iC^r^ /~Or- USc/'/\ /^FC'OAJ JCU Date <^" Bi" ^4 OFFICE USE ONLY v>< TCLP Metal/DAy V-\cX.C:'=v 4f-leU-, i PCB Analysis i Halogens OFFICE-White CONTRACTS - Green. Canary PLANT-Pink CUSTOMER - Golo 700379 MERCURY REFINING COMPANY INC. OFFICE USE ONLY No. 9251 0 GENERATOR'S WASTE PROFILE SHEET Renewal,^' Sample No. EPA ID NO. NYD04814et7E WS Waste Code VU L.- | -q H .© 1216 Ceniral Avenue Rec -rr -I- Reviewed By'Bils.I;m ^ V/&!_, .,• Albanv. NY 12205 CR_ }Lo_C:iiQS!-y___, Approved Bv KPr 5J^ Ol^Vxf I. GENERATOR INFORMATION Bill to -iSa^rty^, Name i/y eAr> Cb Facility Address P. Q . 'f^C^ ^•i^ y[\l o/\(^ l?jr-t^| Contact I'(:( (iDr.. L I r^JkoA. Phone: ••g>^-Ml j,- ^-^.A FAX:•Q^^-^7J-.^^^9 EPA ID No..Li\^ f>9^^^l bc?t-j Send Contracts to: /Y),/\li ; II. SHIPPING INFORMATIO^MATION J- /7 . f I ^ (^ DOT Shipping Name UN/NA Number [XhJ I 1 (sCi .Hazard Class -S- EPA Wasti Code(s) PO^ ij , D 0 OT^ 1>^|1^ P^ocl III. WASTE IDENTIFICATION Generaior's Nam.e for Waste ( A^CVT/I l^J^ .UJ- Process Generating Waste Gr\ U i y^VO A,^,: •. 4?^ ' Lr,L C^D Q^yky^ Estimated Annual Volume . IMP ^y./.iLjd.. Container Type/Size likty ^^'Y^ '• ( ^^^^-^ CVfyp^i Mercury Contaminated Debris Mercur/-ip-Glass devices Mercury Contaminated Spil Other (please specify) (speci•-—'.ifytypen ) Mercury Confa.minated Materials .^Mercuny Compounds Batteries IV. WASTE PROPERTIES Physical State: f^] Liquid [ ] Mud/Sludge [ ] Solid Density:. ^yo Ibsigal. pH A^ Flash Point >/ T'O Describe any special handling requirements associated with this waste stream: , Uz^ Range Range V. WASTE COMPOSITION mln - max min - max ^ ^0 % slL r£j±. sj^~yIZZ^I~L s-^'Ho % (^/>ACi LAuA^ £r£Il % f TOTAL 100% Min VI. WASTE INFORMATION YES NO '^^ Radioactive materials Cf-) Does This Waste Contain: YES NO ijxidi^ers {•A Halogens"" LIslMHazardous Wastes other than U151 ( ) Plastics ) (•mm m C3n(itlients other than mercury Free liquid (other than mercury) Y) (• ) .__ . I j jsvbject to land disposal restrictionsi" ^ L'L Dioxins ) C?) MAR 2 8 'OJT Caljfbifiia List contituents (liquids only) ™ !1^ Oils"!' ) (Y) AcLtb Hazardous Wastes PCBs ) < A.) Pesticide/Herbicide ) (?C) lJL=]Vr7LDU u /lagnesium metal Asbestos •"Seientum Soil from uncontrolled disposal site'*' '1) W "^ES*. swase anacn Toiai Ofganic naiogeru anafysis. .21 if '^E3*. piease anacn PCB analysts. (31 II "YES", ptoase luoofy anaryttcal r»iuna (4) It "YES*. siMsa anacn TCL (Targei Compound List) «naJi»i». VII. I anesi ana ceaity that all information provioea :S complete ana accurate and in accoraance with ^CFR261 and New Yorv Stale regulations 6NYCRR371, This waste material is property descnbeo with no wiltlu! omissions in tne iniormiaiion. Any cJianges or acoitional miormation ootamec about this waste stream will be promptly ano correctly conveyed to Mercury Relining Co. II any load is reiecieo by Mercury Refining Co. for any reason, our comcanv wili assume responsibility lor navmg the loao removed (rom the sile as soon as possible. Our company agrees lo oay tor any testing, decontamination, trans^poftaiion or oisoosaaisbosai lor any maienamatenail snippeysnippeyc^c r.e Mercuryv henr.inRe'ming ^Co . siie wmcn does nol tuHy comply with the permii limits as specifieO to our company bv Mercury Relimng Co. J ,'^ . {^rf\ Jf-^ j Generator's Agent T/L-'L^ 4^ fxnL^t^gA^ . Date yhmR^y-- ^OFFICE USE ONLY _ TCLP Melals Z PCB ~ STABILIZATION OFFICE • White CONTRACTS - Green. Canary PLj^NT - Pink CUSTOMER - Gold 700380 MERCURY REFINING COMPANY INC. OFFICE USE ONLY .No. w ^XTOR'S WASTE PROFILE SHEET ^db m:y' EPA ID NO. NYD04ei48-17£ Renewal "T~|C. 1 ~ I ~\ Sample No. y,, \ .Officcee : I2r8 Central Avenue. Albany. NY 12205 WS \) . • • Waste Cod€-TR I - I -S"'-! 26Railroad Ave.. Albany. NY 12205 Fisni: Rec \y> Crn^lc Reviewed Bv C^^ T/'^b^ CR c,u^<;^^ yo;::>(-, Approved By DA M/S^gV'j^ \\\K ^^ ^GENERATOR-INFORMATION ^SvY-vNg. 3s. G'tf>\gr-QiP>' 'Nam'e Site Address Contact Drv^^ CoH*^^ Phone:'70^-^1|-^><^ FAX:~70(^'^°\l-^-l^y EPA ID No. Send Contracts to: J^^^:^Uo»^' < Technical Contact rWci>U P^lVv^ PhonedOCn-5Sj -^yil7atFkxU : "70 (^-8q .^-7^0 Mailing Address p.O i^y q Contact: (^Vc^^.^^i/^^ (W 3D1^ Phone:II 0(^-e°i('^?7^^ ^AX:~706.-^9l^7^ II. SHIPPING INFO DOT Shipping Name I \\. t "sci f\ci _ y^ 111" IT Hazard Class UN/NA Number UM.^-&0^ Packing G roup EPA Waste Code(s) "5ooT III. WASTE IDENTIFICATION Generator's Name for Waste fY\pi'Oor.j C^n-k Range V. WASTE COMPOSITION mln - max „, rf\2r<^r^ VI. WASTE INFORMATION YES Radioactive materials Does This Waste Contain: YES NO^ Oxidizers Halogens"! Listed Hazardous Wastes other than U151 Plastics ( ) ("^i Contituents or characteristics other than mercury Free liquid (other than mercury) subject to land disposal restrictions'" Dioxins Nickel and/or Thallium (liquids only) "' Oilsi" Acute Hazardous Wastes PCBs Beryllium Pesticide/Herbicide 'y Magnesium metal Asbestos Soil from uncontrolled disposal site'*' nj W^ES'.?!**** inicJi Total Ol^afwcrta^o9•'^sw^aNws. i21 H *YESyV Di«as « anacn PCB »i\atyv». (31 il-^EaVpiaasasueofy analytical retoRs (4) KI'YES'.pleasa anachTCHTat^atComoooftaUstlanalyata. VII. f anesi and canity tha: all iniormauon proviaeC is comoiete ana accurate ana in accoroance witn dOCFR261 ana New Yorv State regulations 6NYCRR371. Tliis waste material is prooeny oescnbea witn no willful omissions in t^e inlormaiion. Any cnanges or aaaitional infonnation obtained aoout t^JS waste stream will be promptly ana corectiy conveyeo to Mercury Refining Co. It any loaa is reiecteo by Merrury Refining Co. lor any reason, our company will assume responsibility tor navmg me load removed from ttie site as soon as possible. Our company agrees to pay for any testing, oeconiammation. transportation or aisoosai lor an^ rrioleiyl snipped to tne Werdurt ReliriTho Cc.'site wmcn ooes not fully comply with the permit limits as specified to our company by Mercury Refining Co. Generator's Agent S^-^^:^ Date -7-1-^4- OFFICE USE ONLY TCLP Metals * PCB Analysis Halogens OFFICE-White CONTRACTS - Green. Canary PLANT-Pink CUSTOMER - Gold 700381 MERCURY REFINING COMPANY INC. OFFICE USE ONL> ^•o- 90 01 . GENERATOR'S VMSTE PROFILE SHEET Renewal Sample No. EPA ID NO. NYDOAeiteiVE WS Waste Code Th±zJ_'^z33 1216 Central Avenue #' Rec ^ Reviewed By^i^_'3l5ji_ Albanv, NY 12205 ^-)g^q cR^^-f^iu^ -^^-o "CC Approved By '^7^- I. GENERATOR INFORMATION Bill to ThermoCor Kimmins P.O. Box 484 Name Tin i 1-pri 9,tP.t.P"=. S.Jl££j rnrr.nr?. f i nr\ Braddock, PA 15104 Facility Address Edgar Thomcison Plant Contact Robert C. Andretvs Bra_ddock, ?A 1510-^ Phone(412) 35.1.-1.536 FAX: 351 -1^4.3 EPA ID No ^R'^ QUO U-7,;^ GrC-U Send Contracts to: Same Technical Contact .Kaf-.hlppn MayVipr Phone: ( 41 2 ) 675-738 1FAX:( 4"l 2 ) 466-1232 Contact: .Samp Phone: Same FAX: Same II. SHIPPING INFORMATION DOT Shipping Name . jia-Sl^e. MP r (7 u r-V—conta ined in manLif-a-ctnr-ed articles UN/NA Number ^A/ 2-80'^ .Hazard Class 6 V^*^ EPA Wastefcode(s) DOC^ III. WASTE lOENTlFICATION y^ IV. WASTE PROPERTIES €\ Physical State: [ ] Liquid [ ] Mud/Sludge K}5 Solid Density: S-1 (1 Jbs./gal. pH: M/A Flash PointtlorLS- Describe any special handling requirements associated with this waste stream: Range Range V. WASTE COMPOSITION min - max min - max Thprmnrnpf-pr-g; G1 ?, S S -SD % HS 50 % % :. % TOTAL 100% Min. VI. WASTE INFORMATION YES NO Radioactive materials )^) Does This Waste Contain: YES NO Oxidizers ) OC) Halogens'" ( )(x) Listed Hazardous Wastes other than U151 ) K) Plastics { ) (y) Contituents other than mercury Free liquid (other than mercury) ( )(y) subject to land disposal restrictions'" ) K) Dioxins ( )(x) California List contituents (liquids only)'" Oils'" Acute Hazardous Wastes )(x) PCBs ( ) (X) Beryllium )«) Pesticide/Herbicide ( ) (X) Magnesium metal ) CX) Asbestos ( ) (X) Selenium )(x) Soil from uncontrolled disposal site'" )(x) (1) tr-YES', veaae anacn ToiaiOrganic Halogens analysis. |21 ll'YES*, pieasa anacn PCE arwtysJS. ;3T It'YES*, piaasa suDpty anaiyticai results (ailfY!eSS*otea « *nacn TCL (Ta^VX Camoouno Ust) anatysu. VI!. lanestanacernty mat a" infomiaiion provioea IS complete ana accurate and in accordance with AOCFR261 anoNew YorV Stale tw:i\^kliLts £NYppS^Fi/iTiisJJla6/e fnaifijinr&tpoeriv oescnbea with no willful omissions m the information. Any cnanges or acoitional information oDtamefl about this waste siream will be promptty ana i mii iii0i[ii ijiiT'lli^ iiiii( [IffiaraPtf/ ll^ny loec is rejectea by Mercury Relining Co. for any reason, our company will assume responsibility for navmg the loao removeo from Ihe site as soon as possible. Our comobny agrees to pay for any l5STti>9r4ficar^/nif ai'Oh. transponation or Disposal lor any material snpoec to me Mercua Pefinmg Co. sile which does not fully compfy with the permii limits as specified to imTcompanif Dv^^1ercury Refining Co. f j j J Generator's Aoent OFFICE USE ONLY m • TCLP Metals _. PCB yZ. STABILIZATION OFFICE • White CONTRACTS - Green. Canary PLIANT - Pink CUSTOMER - Gold 700382 APPENDIX C GWPS INSTRUCTION FORMS # 9/93 rev'd 17B2h.a # 700383 INSTRUCTIONS FOR GENERATOR'S WASTE PROFILE SHEET The foliowing inforniation is required for waste to be processed by Mercury Refining Coinpany (MERECO) . This inf orTnation'will be used to. evaluate your waste so it can be transported and reclaimed in a lawful, safe and environmentally sound manner.. Please attach lab reports and any other relevant information that is available. An original Generator's Waste Profile Sheet (GWPS) must be completed for each waste stream. There is a review charge of $145.00 for each GWPS. . A check for the review fee must accompany the GWPS when submitted. A sample is generally not recruired. Please answer all questions in ink. If a response of "NONE" or "NOT APPLICABLE'^ is appropriate, please indicate'. All sections must be completed or the GWPS will be returned. SECTION I - GENERATOR INFORMATION Name: Name of the company offering (generating) the waste. Site Address: The street, city, and state address of the aeneratina facility. A P.O. Box is not acceptable. EPA ID No.: The generator must include the EPA Generator ID number and/or state registration number for the facility. If small quantity generator, indicate SQG. Teclinicai Contact: Name of person to contact for additional information about the waste, if needed. Telephone Number; The area code and number of the technical contact. Site Mailing Address: This is needed for mailing the manifest. Bill to: The company, street, city and state address to which billing should'be sent. Write SAME if identical to facility address. The contract will be made out to the company s-oecified in the billing address. Contact: The name of the person to contact about billing questions. Send Contracts to: Indicate the location to which contracts and other aooroval information should be sent. 700384 SECTION II - SHIPPING INFORMATION Indicate the correct DOT shipping name, hazard class, Ui'I/NA number, packing group and EPA waste code(s). See Shipping "Information attachme.nt for further details. SECTION III - WASTE IDENTIFICATION Generator's Name for Waste: The name the generator commonly uses to identify the waste. Process Generating Waste: Specify the process and/or source generating the waste. Estimated Annual Volume: An estimate of the quantity of this waste to be shipped each year. If this is a one-time shipment, please indicate. , Container Type/Size: Specify type and size of shipping container(s). All drum*quantity wastes must be shipped in 55 gallon, DOT spec. 17-H or POP tested drums with detachable lids. Plastic liners are required in all drums to avoid charges for processing the drum. Smaller than drum quantities may be shipped in DOT spec open head steel pails with liners. No "plastic" (polyethylene) containers accepted. Flowable liquid mercury in quantities of more than five" pounds must be shipped in flasks. " Flasks are available from our office with a $25.00 refundable deposit. Check the description that best describes the waste. Mercury Contajninated Debris: Trash, wood chips, dust, gloves, etc. (material did not originally contain mercury). Mercury Contaminated Materials: Other types of mercury containing materials other than trash, i.e. materials that did contain mercury in their original useable form not otherwise specified in this section. Mercury-In-Glass Devices: Thermometers, Switches, Vapor Lamps, Ignitron Tubes, etc. Mercury Compounds: See Acceptable Compounds listing. Specify exact compounds in Section V or attach packing slip. Mercury Contajninated Soils: Dirt, Gravel, Leaves, etc. Batteries; Specify chemical system type (i.e. mercury, silver, etc). IMPORTANT: Include manufacturer, serial_ number, voltage, size and type of outer covering (plastic, metal, cardboard, etc.) in the Waste Composition section. SECTION lY - WASTE PROPERTIES Physical State: The physical nature of the waste at ambient conditions. (Example: Thermometers - solid) 700385 Density: The weight cf the wasrs in pounds per gallon. (Drum weight i.n lbs. (less tare wt. of drum') divided by • gallons contained = lbs/gal.) pH: For aq-'jecus waste, note pK. If the waste does, not contain warer note N/A. Flash Point: List the temperature in degrees Fahrenheit at which the waste exhibits a' flash point, 'if the waste does not have a flash point note NONE. SECTION V - WASTE COMPOSITION Identify the chemical composition of the waste using common generic chemical term.s. If trade names are used, attach Material Safety Data Sheets and/or other documents which describe the composition of the waste, IMPORTANT: The chemical composition of each waste component must be specified. For example, the term "plastic" is not sufficient as there are many types of plastic. Likewise terms like "gloves" and "bottles" do not specify the chemical composition of the waste. A complete description would be "nitrile gloves" or "plastics - high density polyethylene, low density polyethylene, and acrylic". For each component, indicate percent or range in which the component is present. The total of all components must ecual 100% or greater. Example: Thermometers 80-90% glass 10-20% mercury TOTAL 100% min. SECTION VI - WASTE INFORMATION Indicate if the waste contains any of the constituents listed. Please supply any additional analysis requested. Ha.logens: fluorine, chlorine, • bromine, astatine and iodine. Please supply Total Halogen analysis. Plastics; For example - polyethylene, polypropylene, polyvinyl chloride, etc. Free Liquid: Pourable liquid Dioxins: Chlorinated dioxins, chlorinated dibenzofurans and tri-, tetra - or penta-chlorinated phenols . Oils: Petroleum or water soluble oil (PCB analysis required) PCBs: Polychlorinated Biphenyls Pesticide/Herbicide: Any substance used to destroy or inhibit the action of animal pests or plants. Asbestos Radioactive Materials: Emit radiation in excess of background. Oxidizers: As defined in 49 CFR 173.127 (Ex. chlorates, permanganates, inorganic peroxides & nitrates). Listed Hazardous Waste other than U151; As listed in 40 CFR 261.31 and 40 CFR 261,32 (F and K type wastes). 700386 Constituents on Characteristics other than Mercury Subject to Land Disposal Restrictions: .^.s listed in 40 CFR 268.32 and RCRA 3004(d). Acute Hazardous Waste: As listed in 40 CFR 261.33(e) (? t'ype wastes) . Soil from uncontrolled disposal site: Must be accompanied by an analysis for TCL (Target Compound List, USEPA Contract Laboratory Program) compounds and TCLP metals. SECTION VII - CERTIFICATION The generator of the waste or the generator's agent must sign and date the Generator's Waste Profile Sheet, 700387 SIIIPPIHG INFODHAnoil ID IIJCOMING WASTE 001 HAZARD UH/MA PACKING EPA WASTE LADEL/ U HAIERIALS SOURCE RQ SIIIPPIHG HAHE CLASS NDHDER GROUP CODE . HARKING ERG ^. Ctil) WuMtu liiiliistrics, 100 lb Wasie sulfuric n n UM1030 II 0002, 0007 llaiBrdoiJs Wnsle 39 Luliorolories 0009, 0011 Corrosive 1. FluoiL'scent Tiilies Household Fluorescent Tiibe(s) (lone None None None (Mon-OOT Regulated) i. F liiorescvdt Tul)cs Manufacturers Fluorescent Tube(s) None Hone Hone Hone (llniiseii) (Non-DOT Regulated) 3. rluureucetit IUIJCS Olliers (IrKlustiles, Hazardous waste, solid, n.o.s. NA3077 11 I 0009 llazar ^. liiislrointest itial llospitnis, Waste mercury contained in l)H2B09 I 0009 llazaribus Waste 60 luhes/Oiiilators Manufacturers, manufactured articles Corrosive Medical Sii|)|>liers S. Ignitron Tubes Industries Waste niercury contained in UH2U09 I 0009 Hazardous Waste 60 manufactured articles Corrosive 6. Mercuric Oxide Battery Hazardous waste, solid, n.o.s. NA3077 III 0009 Hazardous Waste 53 Oust Collector Manufacturers (contains mercury) Class 9 Powders 7. Mercuric Oattery Hazardous waste, solid, n.o.s. HA3077 III 0009 Hazardous Waste 53 Oxide Powder/ Manufacturers (contains mercury) Class V Pellets 8. Mercuric Oxide/ Battery Hazardous waste, solid, n.o.s. 9 NA3077 III 0009, Hazardous Waste 53 Silver Dust Manufacturers (contains mercury/silver) 0011 Class 9 Collector Powders V. Mercuric Oxide/ Battery Hazardous waste, solid, n.o.s. 9 NA3077 III 0009, Hazardous Waste 33 Si Iver Oxide Manufacturers (contains mercury/silver) 0011 Class 9 Floor Sweeping O O (A) 10. Mercury Ootteries Battery Waste mercury contained in 0 UH2U09 I 0009 Hazardous Waste 00 CO Manufacturers manufactured articles • Corrosive 53 11. Mercury Hatlcry Military, . Waste mercury contained iii I) UN2009 I 0009 llaznidous Waste 53 (U.seil) Industries manufactured articles Con osi ve 10 INCfXIIHG WASIE DOT IIAZAKD UN/HA PACKING EPA WASTE LABEL/ # HAIERIALS SOURCE RQ SHIPPING NAME CLASS NUHUER GRtXIP CODE HARKING ERG 12. Mercury Battery llouseliolds Mercury contained in manufactured UH2U09 Hone Corrosive 60 articles 13. Met cury CoiipouiKis Laboratories, Mercury compounds, solid, n.o.s. 6.1 UH2025 I Hone Poison/Keep away 53 ((Hire - except liKhistries II froni foods nitrates) III I'l. Mercury Cimi|>ouMds Liiboralorles, Waste Mercury compounds, solids, n.o.s. 6.1 UH2025 I 0009 Hazardous Waste 53 (iiii|xire - except Industries (Mercury compounds) II Poison/Keep nuny ni tr atcs) 111 from footis 15. Mercury Spi 11 clcnii-ups Hazardous waste, soli 16. Hei cury Cont. Industries, Hazardous waste, solid, n.o.s. NA3077 111 0009 Hazardous Waste- 60 Materials Laboratories, (contains mercury) Class V (C(|ui|]iiient, tools, Clean-up meters, etc.) operat ions 17. Mercury Mercury spi11 Hazardous waste, solid, n.o.s. NA3077 111 0009 Hazardous Waste 60 Cont. Debris clean-ups (contains mercury) Class 9 lU. Mercury Laboratories, Hazardous waste, liquid. n.OiS. NA3002 III 0009 Hazardous Waste 60 Cunt. Water Industries (contains mercury) Class 9 19. Mercury Hunufacturcrs Waste mercury contained In U UH2009 I 0009 Hazardous Waste 60 HiiiicMiieters manufactured articles Corrosive 20. Mercury Others Waste mercury contained in U UN2U09 I 0009 Hazardous Waste 60 Huiiometers manufactured articles Corrosive 21. Mercuric Nitrate Laboratories 10 lbs. Mercuric Nitrate 6.1 UN1625 II None Poison '.2 (|Hirc) Industries 22. Mercuric Nitrate Laboratories 10 lbs. Waste Mercuric Nitrate 6.1 UH1625 II 0001,. Hazardous Waste 1,2 (iiifxjre) Industries 0009 Poison O 23. Mercury Pressure Industries Waste niercury contained in B UN2009 I 0009 Hazardous Waste 60 O manufactured articles Corrosive Ul Regulotors 00 Corrosive 60 2'i. Mercury Switches Manufacturers Mercury contained in manufactured (J UH2809 I None (Unused) articles ID INCOMING WASIE DOT IIA7AW0 UN/NA PACKING EPA WASTE LABEL/ # MATERIALS SOURCE RQ SHIPPING NAME CLASS NUHHER GROUP CODE MARKING EKG 2b. Mercury Switches Others ** Waste mercury contained in UN2B09 I 0009 Hazardous Waste 60 (Used) manufactured articles Corrosive 26. Herr.nry Manufacturers Mercury contained in manufactured UH2009 I Hone Corrosive 60 Ihcimuiiieters articles (Unused) 27. Meicuiy Others Waste mercucy contained in UH2U09 I 0009 llazarclous Waste 60 IheiMiumeters manufactured articles Corrosive (Used) 20. Heicuiy Vapor Manufacturers Mercury contained in manufactured UN2009 I None Corrosive 60 I. aii>|>s articles (Unused) 29. Mercury Vapor Others ** Waste mercury contained in UN2U09 I 0009 llnzartlous Waste 60 I uiiips manufactured articles Corrosive (Used) 30. Mercury Wetted Utilities, Waste mercury contained in (1 UH2009 I D009 Hazardous Waste 60 Relays Industries manufactured articles Corrosive 31. Mctallic Mercury Mercury UN2D09 III U151 Corrosive 60 (Pure) 32. Metal Iic Mercury Industries Waste Mercury UN2a09 111 0009 Hazardous Waste 60 (Impure) Corrosive 33. Si Iver Amalgam Col lectors. Dental Amalgam Hone Hone Hone Dentists, other Non-DOT Regulated) Refiners 3^. Si Iver Oxide Battery Hazardous Waste, Solid, N.O.S. HA3077 111 0009, Hazardous Waste 60 •latteries Manufacturer (contains mercury/silver) 0011 Class 9 35. Si Iver Oxide Household Mercury contained in manufactured UN2009 I Hone Corrosive 60 Batteries articles .J 36. Si Iver Oxide Industries Hazardous Waste, Solid, N.O.S HA3077 111 0009, Hazardous Waste Class 9 5 Uutleries (contains mercury/silver) 0011 O Ul oto ID INCOMING WASIE DOT IIAZARO UN/NA PACKING EPA WASTE LABEL/ n HAIERIALS SOURCE RQ SHIPPING NAME CLASS NUMBER GROUP CODE HARKIHG ERO 37. Silver Dust Battery Silver Powder HOMC Hone None Hone Collector Powders Mainifacturers, (Non-DOT Regulated) Jewelers 30. Zinc Amalgam Battery Zinc Amalgam Hone None None Hone Manufacturers (Hon-OOT Regulated) '39. Zinc Carbon Households Battery, dry None Hone Hone Hone Batteries * RQ - required if total weight of waste Is 1 lb. or greater ** RQ - required if 1 lb. or greater of contained mercury HERECO IS PROVIDING THIS MATERIAL FOR INFORMATION PURPOSES ONLY ANO ASSUMES HO LIAUILTIY FOR AHV RELIANCE ON SAHE BY CUSTOMER OR ANY THIRD PARTY. revised 6/94 •J O O Ui vo