WASTE REDUCTION ADVICE for Farm Equipment Manufacturers Iowa Waste Reduction Center University of Northern Iowa WASTE REDUCTION ADVICE for Farm Equipment Manufacturers nble of Contents Section Description Page I Introduction ... ...............................................................................................1 I1 General Regulatory Review ...........................................................................2 I11 Machining Wastes ..........................................................................................3 IV Cleaning Solvent Wastes ...............................................................................5 v Prepaint Treatment Wastes ...........................................................................7 VI Paint and Thinner Wastes ...........................................................................11 VII Paint Booth Filters ......................................................................................13 VIII Storm Water ................................................................................................14 IX Nonhazardous Solid Wastes ........................................................................15 . Air Em~ss~ons............................................................................................... 16 Hazardous Waste Management and Storage .............................................. 17 Superfund Amendments and Reauthorization Act (SARA) Title I11 .......... 18 Copyright 1991. Iowa Waste Reduction Center Printed on Appendices A Conditionally Exempt Small Quantity Generator Requirements B Small Quantity Generator Requirements C Hazardous Waste Definitions D Tramp Oil Removal Equipment Vendors E Used Oil Management Companies F Distillation Equipment Vendors G Hazardous Waste Management Companies H NPDES Permit Application Summary - Process Waters I Total Toxic Organics (TTO) Solvent Management Plan J Analytical Laboratories K SWA Test Parameters SWA Application L Paint Application Methods M NPDES Permit Application Summary - Storm Water N Solid Waste Recyclers 0 Air Permit Application P Counting Hazardous Waste When Using a Solvent Still Q SARA Title I11 Reporting Instructions I. INTRODUCTION There are over 300 farm equipment manufacturers throughout the state of Iowa. These manufacturers have been targeted for waste management and reduction by the Iowa Waste Reduction Center (IWRC), located at the University of Northern Iowa. The primary method of outreach was through a direct mailing according to SIC codes. The mailing consisted of an IWRC brochure and a notice discussing potential liabilities resulting from improper storage methods and hazardous waste determinations. As a result of this mailing, the IWRC has conducted 30 on-site reviews to assist farm equipment manufacturers in developing and implementing effective and compliant waste management programs through waste reduction and recycling. On-site reviews for farm equipment manufacturers involve a facility tour to determine current waste streams and management methods. A review of hazardous waste shipping manifests, material safety data sheets, and other related documentation is also performed. Following an on-site review, a report is prepared and sent to the farm equipment manufacturer; continued contact is common as a means to assist the manufacturer in implementing the recommendations contained in the report. Six to nine months after an on-site review, a formal follow-up call is made to assess waste management and reduction progress. This also provides clients with an opportunity to have questions answered concerning recent developments. Farm equipment manufacturers fabricate and market a variety of products. These products include livestock confinement equipment, buildings, gates, wagons, trailers, and loaders as well as wood and plastic housing units. Fabrication aspects include the traditional metal working and finishing operations, plastic and fiberglass molding, painting, and woodworking. This manual reviews the general categories of waste generation common to most farm equipment manufacturers. Each category is divided into three sections, where appropriate, addressing standard existing conditions, regulatory requirements, and general recommendations. The following categories are discussed: 1. Machining Wastes (Scrap Metal and Cutting Fluids) 2. Cleaning Solvent Waste 3. Prepaint Treatment Wastes 4. Paint and Thinner Wastes 5. Paint Booth Filters 6. Storm Water 7. Nonhazardous Solid Wastes 8. Air Emissions 9. Hazardous Waste Management and Storage 10. Superfund Amendments and Reauthorization Act (SARA) Title I11 11. GENERAL REGULATORY REVIEW Federal Environmental Protection Agency (EPA) regulations require all facilities that generate waste to determine whether the waste is hazardous or nonhazardous. This may be accomplished through laboratory testing or a thorough knowledge of the waste or process generating the waste. Wastes are defined as hazardous either by specific EPA listing (i.e., toluene) or by demonstrating one or more of the following hazardous characteristics: Ignitability Toxicity Corrosivity Reactivity Once the facility has determined the hazardous/nonhazardous nature of all its wastes, the facility's monthly hazardous waste generation rate must be established. The generation rate per calendar month (and the total quantity of hazardous waste stored on-site at any given time) defines which one of the following categories is applicable to the facility: * Conditionally Exempt Small Quantity Generator (CESQG) * Small Quantity Generator (SQG) Large Quantity Generator (LQG) EPA hazardous waste regulations that apply to the facility are contingent upon that facility's hazardous waste generator status. Therefore, it is important to accurately define and quantify all hazardous waste to assure that the correct generator category and applicable regulations have been determined. In general, less stringent regulations apply for the smaller quantity generators. A summary of the CESQG requirements is included in Appendix A; SQG requirements are summarized in Appendix B. Nonhazardous industrial waste regulation falls under the jurisdiction of the Iowa Department of Natural Resources (DNR). Nonhazardous industrial solid waste may be disposed of in local solid waste landfills, provided a Special Waste Authorization (SWA) is issued to the receiving landfill. A SWA is obtained by testing the waste for various parameters to verify that it is not hazardous and will not have a detrimental effect on landfill operation. These data are then submitted, along with a SWA application form, for DNR review. If the DNR requirements are met, an approved SWA will be sent to the receiving landfill (a copy to the applicant) and disposal may begin. Other restrictions may be imposed by the DNR prior to approval of a SWA. Air emission regulations are enforced by the Iowa DNR, contingent upon federal standards. Facilities or operations installed or modified since 1970, that have the potential to emit air pollutants (i.e., dust, smoke or vapors), are required to obtain an air permit from the DNR. The air permitting process may require emission testing and/or control. Facilities and operations installed prior to 1970 do not require air permits (provided no major modifications have been completed since 1970) but must still comply with applicable emission limits. Requirements for toxic air emissions are handled on a case-by-case basis. Process water discharges to public waterways (i.e., rivers, drain tiles) are regulated under federal Clean Water Act guidelines. The regulations require dischargers to obtain a permit which limits the amount of pollutants allowed to be discharged at any given time. The 2 permit program is administered by the Iowa DNR. Permit parameters typically include regular monitoring of discharges for various specified pollutants and the submittal of monthly or quarterly reports to the control authority. Storm water runoff from industrial areas (i.e., materials handling and waste storage), which is not collected for treatment through a wastewater treatment facility, is subject to new federal guidelines and permitting. Facilities which perform any industrial activity that is exposed to storm water are required to obtain a discharge permit for the runoff. Permit parameters are determined on a case-by-case basis but will likely require a minimal amount of pollutant monitoring. Pretreatment standards for wastewaters generated by a number of manufacturing processes have been designated by the EPA. These pretreatment standards determine the level of contaminants which are acceptable in wastewaters being discharged from a facility to a publicly ownedsanitavy sewer. Pretreatment standards apply to specific industrial processes, such as electroplating. Pretreatment program administration is by the local wastewater authority, with oversight by the Iowa DNR. 111. MACHINING WASTES (SCRAP METAL AND CUTTING FLUIDS) 1. Existing Conditions: Most metal farm equipment products are made from varying grades of steel or aluminum. Heavy cutoff pieces and turnings are collected and recycled through local scrap metal dealers. In a small number of the shops visited, turnings were no longer accepted by the scrap metal dealers due to cutting fluid residue. In these cases, turnings were disposed of through the local sanitary landfill. Practically all machining operations utilize cutting fluids to facilitate metal parts manufacturing. These operations include drilling, tapping, lathing, cutting, and grinding.