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DEP Hazardous Waste Program. Why a need for regulations. Following WWII, manufacturing was booming and large volumes of toxic waste were generated. The waste was disposed on ground or burned without controls Problems started developing Water polluted Air pollution Dying species

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why a need for regulations
Why a need for regulations

Following WWII, manufacturing was booming and large volumes of toxic waste were generated. The waste was disposed on ground or burned without controls

  • Problems started developing
    • Water polluted
    • Air pollution
    • Dying species
    • Health problems
  • Several sites became legendary
    • They help cause the creation of environmental protection laws
some sites became legendary
Some sites became legendary
  • Love Canal
  • Cuyahoga River
  • Valley of the drums
  • Times Beach
love canal niagara ny
Love Canal, Niagara NY
  • 15 acres along Niagara River
  • 1890, constructed 3000ft by 60ft canal – went bankrupt
  • 1920, purchased by Hooker Chemical
  • 1920 – 1953, used as a landfill by Hooker Chemical and the city.
  • 1953, sold to the city’s board of education ($1.00)
  • Deed stated not to dig within the area of the canal
  • 1954, Board of Ed built schools and housing (1000)
    • Disregarded warning on deed
    • Chemicals seeped into basements and storm drains
    • Drums popping up in ball fields and yards
    • Residents started complaining
  • 1978, years of residents complaints forced evacuation of several city blocks
  • 2010, a few city blocks still restricted
cuyahoga river cleveland oh
Cuyahoga River, Cleveland OH
  • 1936 – 1969, used as an industrial sewer
    • Numerous fires from waste chemicals floating on the river
    • Referred to as the “dead river”.
    • No signs of life in the river
  • 1952, large fire damaging boats and buildings
  • 1969, last large fire
    • Earth movement and Clean Water Act of 1970 put an end to industrial dumping
valley of the drums brooks ky
Valley of the Drums, Brooks KY
  • 13 acre site, gravel pits owned by A. L. Taylor
  • 1967 – 1977, took in over 38,000 drums of waste from area paint and coating manufacturers
  • 11,000 drums buried and/or burned
  • 27,000 drums stored on the soil
  • 1980, EPA begins cleanup
times beach mi
Times Beach, MI
  • Small town of 2000 with 21 miles of un-paved roads
  • 1971 – 1972, Sixty two horse die at area stables.
    • Russell Bliss was hired to sprayed waste oil for dust control
  • 1972 – 1976, Times Beach hires Russell Bliss
    • Spray waste oil on roads for dust control
  • 1977, EPA begins investigation into horse deaths
    • Oil came from NE Pharmaceutical and Chemical Corp
    • Made Agent Orange (2,4,5T and 2,4D)
    • Contains dioxin
    • Russell Bliss picked up waste oil
  • 1983, EPA purchases the town and evacuates residents
  • 1996 – 1997, incinerate 26,000 tons of dioxin contaminated soil
    • from Times Beach and local stables
  • Current – Town park (still polluted)
hazardous waste laws
Hazardous Waste Laws
  • Title 40 of the Code of Federal Regulations, Parts 260 – 280

Cradle to Grave

“you generate a waste, you own it forever”

enforcement
Enforcement
  • Civil –
    • $25,000 per day per violation
  • Criminal –
    • $50,000 per day per violation
    • Up to five years in prison
civil cases
Civil Cases
  • Home Depot (9 stores)
    • $425,000.00 & corporation wide compliance program in CT
  • Light Sources
    • $857,000.00 & clean up mercury release
  • Kaman Aerospace
    • $420,000.00
criminal
Criminal
  • Phoenix Products
    • $250,000.00
    • Probation
  • Mike Fretaus and U Haul
    • $60,000.00
    • 1 year prison
  • Sound Mfg
    • $100,000.00 and $1,000,000.00 cash bond (clean up)
    • 3 years prison (suspended on appeal)
    • 1 year home confinement
    • Clean up completed in January 2010
hazardous waste management regulations
Hazardous Waste Management Regulations

As a generator of HW, you must:

  • Determine if each solid waste is HW
  • Properly manage & store the waste
  • Inspect waste & emergency response equipment
  • Plan for Emergency responses
  • Train employees
  • Preparing for off-site shipment
  • Keep records
slide14

Determination if Waste is Hazardous

Can use knowledge of the chemicals and process that generates the waste, analytical testing, or both

  • 1st – is the waste a solid waste
    • i.e. is it discarded
  • 2nd – is the solid waste excluded
    • If no,
  • 3rd – is the solid waste a hazardous waste
what s a solid waste
What’s a Solid Waste
  • Discarded material –
          • Spent material
          • Sludge
          • By-product
          • Commercial chemical product
          • Scrap metal

That’s discarded –

          • Burned/incinerated
          • Recycled/reclaimed
          • Accumulated speculatively
          • Used in a manner constituting disposal*

*placed on land or water

solid waste example
Solid Waste Example

disposed

discarded

reused

burned

what s a hazardous waste
What’s a Hazardous Waste

A hazardous waste is a solid waste that is

  • listed as a hazardous wastes

and/or

  • Exhibits a characteristic of a hazardous waste
  • Two sub-categories
  • Used oil
  • Universal waste
slide18

Exclusions

  • Waste fuel reused as a fuel
    • gasoline sent off-site for fuel blending
  • Effective substitute for a commercial chemical product, provided the product is not used in a manner constituting disposal or burned.
    • Spent plastic bead blast media (removing paint from air craft)
      • Used in water resistant concrete block (Sealtech block)
        • Applied above ground – not solid waste
        • Applied on the ground – is solid waste
    • Fly ash used to make zinc powder (electric plant emission control)
      • Used for galvanizing – not solid waste (US Zinc)
      • Used in plant food – is solid waste (Bay Zinc)
waste codes
Waste Codes
  • All hazardous wastes are identified by a “waste code”
  • (except for used oil and universal waste)
  • The listed waste codes
  • F, K, U, P
  • (Example – F001 spent halogenated solvent)
  • The characteristic waste codes
  • D waste codes
  • (Example – D008 lead)
reasons for waste codes
Reasons for Waste Codes
  • National statistical information
      • Observe trends in waste generation
  • Pollution prevention programs
      • Eliminate/reduce large volume waste types
  • Hazard recognition
      • Waste codes represent specific hazards
slide21

Listed Hazardous Waste

  • Three Lists (developed in 1976)
    • Non-specific source list
      • Waste from a process that any business can do
    • Specific source list
      • Waste from specifically listed types of businesses
    • Commercial chemical product list
      • Waste that is a specifically listed type of chemical product
facts about listed hw
Facts about Listed HW

Reasons for Listing

Ignitable (I)

Corrosive (C)

Reactive (R)

Acutely Hazardous (H)

Toxic (T)

Mixture Rule

  • mixing a listed waste with any other solid waste makes the entire mixture a listed waste!
  • not dependent on amount (one drop, one gallon, etc).
  • not dependent on the source (intentional mixing, accidental mixing).
  • Can cause an inexpensive waste to become more expensive when shipped off-site
non specific source f waste codes

Non-specific source“F” Waste Codes

Waste from generic sources:

F001 – F039

Solvents (F001 – F005)

Metal finishing (F006 – F019)

Pesticides/wood preservative [dioxin] (F020 - F035)

slide24

F001 (T) Spent halogenated solvent used in degreasing

  • Carb cleaner
  • Brake cleaner
  • Contact cleaner
  • tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1 trichloroethane, carbon tetrachloride, chlorinated fluorocarbons
  • still bottoms from recovery of spent solvents
slide25

F002 (T) the following spent halogenated solvents

  • tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1 trichloroethane, carbon tetrachloride, chlorinated fluorocarbons
  • still bottoms from recovery of spent solvents
  • Paint stripper
  • Tire cleaner
  • Lab analysis
halogens

Halogens

Chemical with the word chlor or fluorin its name

Perchloroethylene (1.6)

Trichloroethylene (1.46)

methylene chloride (1.33)

“HEAVIER THAN WATER”

IMPROPER TREATMENT = DIOXINS

slide27

F003 (I) The following spent non-halogenated solvents

  • xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, butyl alcohol, cyclohexanone, methanol
  • still bottoms from recovery of spent solvents
  • Paint stripper
  • Carb cleaner
  • Brake cleaner
  • Electric contact cleaner
  • Lab analysis
slide28

F005 (I)(T) The following spent non-halogenated solvents

  • Carb cleaner
  • Brake cleaner
  • Paint stripper
  • Gasket remover
  • Electric contact cleaner
  • Lab analysis
  • toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, 2-nitropropane
  • still bottoms from recovery of spent solvents
specific source k waste codes

Specific Source“K” Waste Codes

Waste from specifically identified industrial sources:

K001 – K160

Refineries (K048, K170)

Pharmaceutical (K084, K101)

Foundry (K061, K069)

Explosives (K044, K45)

commercial chemical product u p waste codes

Commercial Chemical Product“U” & “P” Waste Codes

Solvents

Pesticides

Pharmaceuticals

Chemical ingredients

commercial chemical product waste
Commercial Chemical Product Waste
  • Waste chemical product that is unused
      • pure or technical grade of chemical
      • sole active ingredient
      • no longer needed or wanted
        • off-specification
        • old/outdated
slide33

Commercial Chemical Product Waste

  • Spilled virgin chemical products
commercial chemical product p listed waste
Commercial Chemical Product “P” Listed Waste

“acutely hazardous”

P001 - P205(H)

  • Methyl parathion P071
    • Nicotine P075
    • Epinephrine P042
    • Methyl isocyanate P064
    • Empty containers of “P” listed materials not triple rinsed
    • Rinsate from rinsing empty containers
commercial chemical product u listed waste
Commercial Chemical Product“U” Listed Waste

U001 – U411(T)

  • Acetone U002 (I)
  • Methylene chloride U080
  • 2,4-D U240
  • Isopropanol U140 (I)
  • Methyl ethyl ketone U159 (I)
  • DDT U061
  • Warfarin U248
  • Acetyl chloride U006 (C, R)
characteristic hazardous waste
Characteristic Hazardous Waste

Four types

“D” waste codes

  • Ignitable (D001)
  • Corrosive (D002)
  • Reactive (D003)
  • Toxicity Characteristic (D004-D043)
some facts about characteristic waste
Some Facts about Characteristic Waste
  • Some characteristics are based on physical properties
      • flash point
      • pH (acid or alkali)
      • compressed or pressurized gases
      • oxidizer
some facts about characteristic waste1
Some Facts about Characteristic Waste
  • Some characteristics are based on concentration limits
      • milligrams per liter (mg/L)
      • test method “Toxicity Characteristic Leaching Procedure”
      • limits range between 0.008 to 400 mg/L

note: one percent (1%) equals 10,000 ppm

some facts about characteristic waste2
Some Facts about Characteristic Waste
  • Everything discarded, must determine if it exhibits a characteristic of a hazardous waste
    • Paper (masking materials, sandpaper, coveralls)
    • Tires
    • Chemicals (used & un-used)
    • Light bulbs/tubes
    • Electronic devices (computers, cell phones, TV)
    • Scrap metal
    • Paint (liquid or solid)
    • Contaminated debris (paint brushes, speedi dry, dust)
ignitable characteristic d001
Ignitable Characteristic“D001”
  • Liquid with a flash point less than 140 Deg. F
  • Oxidizers
  • Ignitable compressed gases
  • Not a liquid – fire through friction, moisture, spontaneous chemical change, & burns vigorously and persistently
ignitable examples
Ignitable Examples
  • Liquid – flash point less than 140
    • Mineral spirits
    • Gasoline
    • Contact cement
    • Aerosol paint
  • Oxidizers
    • Nitric acid
    • Fiberglass resin hardener (MEKP)
  • Ignitable compressed gas
    • Acetylene
    • Propane
  • Not a liquid
    • Aluminum fines
    • Magnesium
corrosive characteristic d002
Corrosive Characteristic“D002”
  • Aqueous liquid, pH less than 2 or greater than 12.5.
  • A liquid that corrodes steel at greater than 0.025 inches per year at 130 degrees F.
corrosive examples
Corrosive Examples
  • pH less than 2
    • Nitric acid (lab)
    • Sulfuric acid (battery)
    • Muriatic acid (concrete)
    • Hydrofluoric (aluminum)
  • pH greater than 12.5
    • Potassium hydroxide (oven)
    • Sodium hydroxide (drain)
    • Ammonium hydroxide (cleaner)
    • Sodium hypochlorite (bleach)
reactive characteristic d003

Reactive Characteristic“D003”

Normally unstable

Reacts violently with water or forms toxic fumes or vapors

Capable of detonation or explosion when heated under confinement or initiating force

reactive examples
Reactive Examples
  • Explosives
    • Fire works
    • Ammunition
    • Air bags
  • Compressed cylinders
    • Aerosol cans
    • Propane cylinders
  • Metal fines
    • Aluminum
  • Lithium
    • Batteries with a charge
toxic characteristic d004 d043
Toxic Characteristic“D004 – D043”
  • 39 elements and compounds
  • cause damage to tissue, impair CNS, cause severe illness or death when ingested, inhaled, or absorbed.
  • based on concentration limits (mg/L).
  • testing using Toxicity Characteristic Leaching Procedure (TCLP).
toxic characteristic
Toxic Characteristic

Waste Code Contaminant Limit mg/L

D004 arsenic 5.0

D005 barium 100.0

D006 cadmium 1.0

D007 chromium 5.0

D008 lead 5.0

D009 mercury 0.2

D010 selenium 1.0

D011 silver 5.0

D012 endrin 0.02

D013 lindan 0.4

D014 methoxychlor 10.0

D015 toxaphene 0.5

D016 2,4-D 10.0

toxic characteristic1
Toxic Characteristic

Waste codeContaminantLimit mg/L

D017 2,4,5-TP 1.0

D018 benzene 0.5

D019 carbon tetrachloride 0.5

D020 chlordane 0.03

D021 chlorobenzene 100.0

D022 chloroform 6.0

D023 o-cresol 200.0

D024 m-cresol 200.0

D025 p-cresol 200.0

D026 cresol 200.0

D027 1,4-dichlorobenzene 7.5

toxic characteristic2
Toxic Characteristic

Waste codeContaminantLimit mg/L

D028 1,2-dichloroethane 0.5 mg/L

D029 1,1-dichloroethylene 0.7 mg/L

D030 2,4-dinitrotoluene 0.13 mg/L

D031 heptachlor 0.008 mg/L

D032 hexachlorobenzene 0.13 mg/L

D033 hexachlorobutadiene 0.5 mg/L

D034 hexachloroethane 3 mg/L

D035 methyl ethyl ketone 200 mg/L

D036 nitrobenzene 2 mg/L

D037 pentachlorophenol 100 mg/L

D038 pyridine 5 mg/L

D039 tetrachloroethylene 0.7 mg/L

D040 trichloroethylene 0.7

D041 2,4,5 trichlorophenol 400.0

D042 2,4,6 trichlorophenol 2.0

D043 vinyl chloride 0.2

managing waste in containers
Managing Waste in Containers
  • Two types
    • Satellite containers
    • Storage containers
satellite containers
Satellite Containers
  • At or near the point of generation
  • Under control of the operator (generator of waste)
  • Can’t exceed 55-gallons per waste type
  • Labeled “hazardous waste”
  • Labeled “description of waste”
  • Keep closed
  • Good condition
storage containers
Storage Containers
  • Not a satellite container
  • Keep closed
  • Labeled “hazardous waste”
  • Labeled “description of waste”
  • Labeled “date of accumulation”
  • Kept in engineered storage area
  • Ship off-site in 180-days
engineered storage area
Engineered Storage Area
  • Secondary containment
    • 10% of all containers or 100% of largest
  • Impervious base
    • Poly spill pallets
    • Epoxy coated concrete
    • Sheet metal
  • Warning signs
    • No smoking signs (flammable or reactive)
  • Aisle space
    • 30 inches between rows of drums
  • Secured & 50 feet from property line
    • Flammable or reactive
  • Separate incompatibles
    • Acid from alkali
    • Flammable from corrosives
satellite violations
Satellite Violations

open

open

Labeled HW

Open, not labeled

storage violations
Storage Violations

Containment, labeled (HW, desc, date)

date

Open, containment, labeled (HW, desc, date)

Containment, labeled (HW, desc, date)

inspections

Inspections

Schedule

Describes what to inspect

Container condition (leaks, damage, bulging)

Container labeling (words HW, description, date)

Containment system (damage, signs of leaks/spills)

Emergency equipment

Log

Record observations

Name of inspector

Date of inspection

Time of inspection

Corrective action

inspections1
Inspections
  • Frequency
    • Container areas – weekly
    • Safety/emergency equipment - monthly
emergency response plan1
Emergency Response Plan
  • Identify key employees
    • Emergency coordinator
    • Alternate coordinator
  • Plan for site specific emergencies
    • Spills, fires, flooding
      • at minimum – must contain releases/spills
    • Hazards of your chemicals
    • Volume of chemicals (container/tank size)
    • Site characteristics
      • Floor drains
      • Chemicals stored outdoors
        • Soil or asphalt
      • Possible incompatible materials
      • Sources of ignition
post emergency information
Post Emergency Information
  • Name and phone # of emergency coordinators
  • Location of spill response equipment
  • Location of fire extinguishers and/or pull boxes
  • Phone number for off-site responders (FD, spill contractors, DEP)
  • Evacuation routes
responding
Responding
  • You are required to contain releases
    • Train key employees
    • keep adequate response equipment on-site
      • absorbents (clay litter, pads, pigs, saw dust, sand, rags, etc)
      • shovels
      • booms (contain spills to water)
      • fire extinguishers
      • protective gloves
      • containers for waste collection
reporting
Reporting
  • Notify DEP (860-424-3338)
    • required for all spills
  • Notify national response center (800-424-8802)
    • impacts water body
    • impacts adjacent properties
employee training

Employee Training

All employees that have hazardous waste duties

Site coordinators

workers putting waste in containers

worker conducting inspects

responding to emergencies

determining if waste is HW

prepare/sign manifests

Annual training/refresher

specific to worker’s duties involving HW

document training

off site shipment
Off-site Shipment
  • Label container with HW Marker
  • Use DOT approved containers
  • Label with DOT labels
    • Corrosive
    • Flammable
  • Use transporter that has EPA Id. No.
  • Send to TSDF that has EPA Id. No.
off site shipment1
Off-site Shipment
  • Prepare hazardous waste manifest
    • Site address
    • Volume of waste
    • Description of waste (and waste codes)
    • Transporter name and EPA Id. No.
    • Receiving facilities (TSDF) name and EPA Id. No.
    • Generator signs and dates
      • Keep copy for your file
    • Transporter signs and dates
    • Send a copy to the generator state’s DEP
    • Send a copy to the receiving facility’s state DEP
    • Receiving facility sends you a signed dated copy after receiving the waste
      • Keep copy for your file
off site shipment2
Off-site Shipment
  • Prepare Land Disposal Restriction Form (land ban form)
    • Done for all waste that does not meet the land disposal treatment standards
      • Generator’s name and address
      • Manifest #
      • Description of waste
        • Hazardous wastes
          • Example “lead”
        • Underlying pollutants
          • Example “nickel”
record retention
Record Retention
  • Must keep records for three years
    • Inspection logs
    • Training records
    • Spill reports
    • Hazardous waste manifests
    • Land disposal restriction forms
  • Must update annually
    • Hazardous waste determinations
the other regulated wastes

The Other Regulated Wastes

Hazardous wastes that can be managed under reduced requirements specific to the waste type

Used Oil (40 CFR Part 279)

Universal Waste (40 CFR Part 273)

used oil
Used Oil

“Synthetic or petroleum based oil that has been used and as a result can no longer be used without processing”

    • Lube oil (gas/diesel powered equipment)
    • Machining (milling, drilling, grinding, broaching)
    • Hydraulic oil
    • Heat transfer fluids
    • Metal forming (drawing, rolling, extrusion)
    • Heat treating
  • Includes oil contaminated materials (unless drained)
    • Oil filters (not drained)
    • Absorbents
  • Does not include animal oil, vegetable oil, or waste oil
used oil1
Used Oil
  • Presumed to be recycled
    • Re-refined
    • Burned for energy recovery
  • If not recycled, fully regulated HW
    • Disposed (placed on ground)
    • Incinerated (burned without energy recovery)
used oil2
Used Oil
  • Can exhibit a HW characteristic or be listed HW
  • Can mix with an ignitable only HW
    • Provided mixture does not exhibit the ignitable characteristic
  • Must test for total halogens
    • > 1000 ppm halogens - presumed mixed with hazardous waste.

- test for halogenated solvents

(100 ppm = HW)

used oil3
Used Oil
  • Must label containers/tanks “Used Oil”
  • If stored outdoors –
    • On an impervious base
    • In secondary containment
  • Can be burned in a space heater
  • No storage time limits
  • No volume limits
    • If over 1340-gallons (both used and virgin) must prepare a SPCC plan
used oil4
Used Oil
  • Can self transport to an aggregation area
    • Aggregation area owned/operated by the generator
    • 55-gallons per trip
  • If shipped off-site –
    • Ship off-site to facility that has an EPA Id. No.
    • Ship using a transporter with EPA Id. No.
    • Use a manifest or shipping invoice
used oil5
Used Oil
  • Can be sold as a fuel if “on-specification”
    • Needs testing to show its comparable to fuel oil
      • BTU value (at least 5,000)
      • Arsenic 5 ppm or less
      • Cadmium 2 ppm or less
      • Chromium 10 ppm or less
      • Lead 100 ppm or less
      • Flash point 100 deg. F. minimum
      • Total halogens 4000 ppm or less
  • Can’t be sold for residential fuel (in CT)
universal waste
Universal Waste
  • Special rule for wastes that are universally generated
  • Are hazardous wastes (listed or characteristic)
        • Exception (FIFRA recalled pesticides & waste added by states)
  • Can be generated anywhere
    • Manufacturing buildings
    • Office buildings
    • Hotels
    • Government buildings
    • Parking lots
    • Roadways
    • Schools
universal waste types
Universal Waste Types
  • Mercury containing lamps
    • Fluorescent
    • Metal halide
    • Mercury vapor
    • Sodium vapor
  • Mercury thermostats
  • Batteries
    • Lead acid (lead and acid)
    • NiCad (cadmium)
    • Mercury cell (mercury)
    • Silver cell (silver)
    • Nickel hydride (alkali)
  • FIFRA banned pesticides
universal waste1
Universal Waste
  • States can add other waste types (HW or non-HW)
    • Ct added –
      • Mercury containing equipment
      • Used electronics
      • All types of fluorescent lamps
universal waste2
Universal Waste
  • No presumption of recycling
  • Store for one year
  • Label
    • “universal waste batteries”,
    • “universal waste lamps”, etc
  • Can send to other universal waste generator
universal waste3
UniversalWaste
  • Can self transport, send through mail, etc
  • Use shipping invoice if shipped by transporter
  • Becomes fully regulated HW when
    • Disposed (such as spilled or broken)
    • Burned
questions5
Questions

Used oil & handling requirements

Universal Waste & handling requirements

slide86

Midnight Dumping

  • Try to determine what it is
    • Residential
      • Milk jug
      • Antifreeze jug
      • One-gallon Paint can
      • Containers of less than 5-gallons
    • Waste types
      • Oil
      • Antifreeze
      • Paint
      • Gasoline
slide87

Midnight Dumping

  • Try to determine what it is
    • Commercial/business
      • Several of same size containers
      • Five-gallons and larger
      • Labeling such as
        • Ship to
        • Name of supplier
        • Product name
        • Flammable, corrosive, etc
slide88

Midnight Dumping

  • Note container condition and type
    • Leaking
    • Corroded
    • Open
    • Steel, poly, fiber
    • Size
    • Shape
    • Labeling
slide89

Midnight Dumping

  • Call Oil & Chemical Spills (860-424-3338)
    • Describe observations
    • Give location
  • If leaking, secure and contain
  • If you feel it is safe, bring it back to your storage area, label “midnight dumping waste”
slide90

Sources of Assistance

  • DEP Compliance Assistance Phone Line
    • Toll free 888-424-4193
    • RCRA main line 860-424-3023
  • David Stokes, DEP Waste Management
    • 860-424-3269
a few statistics

A Few Statistics

Unused oil – 29 million gallons spilled to ground

Used oil – 1.4 billon gallons generated

300 million gallons disposed on ground

Used oil filters – 400 million generated

360 million disposed on ground

Used batteries – 70 million generated

14 million disposed on ground (28 million gallons acid)

Fluorescent tubes – 600 million generated

120 million disposed on ground (20,000 pounds mercury)

Spent solvent – 850 million gallons generated

200 million gallons disposed on ground