ECAR Fact Sheet for Indiana
Hazardous Wastes

The intent of the hazardous waste program is to provide a cradle-to-grave management system for hazardous wastes to ensure that these wastes are not mismanaged in a way that will impact human health or the environment. The Indiana Department of Environmental Management (IDEM) has prepared a guidance document to help auto recyclers manage hazardous waste. Much of the information is included in the fact sheet below or you can visit IDEM's website for the complete Compliance Manual for Auto Salvage Facilities.

To comply with Indiana's Hazardous waste requirements, you must follow the steps below:

1. Determine whether any hazardous waste is generated.

2. Determine a facility's generator status.

3. Determine which regulations must be complied with depending upon a facility's generator status, and comply with those requirements.

Regulations

Definition of Solid Waste. In order for a waste to be considered a hazardous waste, it must first meet the definition of solid waste. The term "solid waste" can be somewhat misleading. The word "solid" does not refer to the physical state of the waste. Solid waste can be a solid, liquid, or contained gas. Under the hazardous waste rules, a solid waste is any material that will no longer be used for its originally intended purpose, or a material that must be reclaimed before reuse. A facility will need to look at each of the waste streams generated (e.g., antifreeze, used oil, solvents, etc.) and determine whether it is a solid waste. Note that not all solid wastes are considered hazardous wastes. Certain solid wastes, such as used oil destined for recycling, are excluded from the hazardous waste rules.

Hazardous Waste Determination.  It is the responsibility of all solid waste generators to determine whether their waste is hazardous. The procedure for this is called a "hazardous waste determination." Wastes can be hazardous if they are either "listed" or "characteristic", or if they are a mixture of a listed hazardous waste and other wastes.

A. Listed wastes. Waste is considered hazardous if it is found on any one of four "lists". These "lists" are called the "F", "K", "P" and "U" lists.

B. Characteristic wastes. Once a facility has reviewed the F, K, P and U lists, and determined whether generated wastes are found on any of the lists, a determination will need to be made to see if these wastes are "characteristic" hazardous wastes. There are four different characteristics: ignitability, corrosivity, reactivity, and toxicity.

• IGNITABLE - combustible under certain conditions
• CORROSIVE - highly acidic, basic and/or capable of corroding metal
• REACTIVE - unstable under normal conditions and capable of creating explosions and/or toxic fumes, gases, and vapors when mixed with water

C. Mixtures of listed wastes and other wastes.  A mixture containing a non-hazardous solid waste and any amount of a listed hazardous waste is considered a hazardous waste. For example, if a pint of spent solvent such a toluene or benzene (an F005 listed hazardous waste) is mixed with a 55 gallon drum of waste antifreeze, the entire mixture (e.g., 55 gallons plus one pint) is considered a hazardous waste (as opposed to only one pint being a hazardous waste had the two wastes not been mixed). Hence, it is very important to keep wastes segregated. Not only is it better for the environment, but it will reduce disposal costs (it's more expensive to dispose of hazardous waste than it is solid waste).

D. Universal Wastes.  Universal wastes include nickel cadmium and small sealed lead-acid batteries, agricultural pesticides, thermostats and lights/lamps (e.g., fl uorescent, high-intensity discharge, neon, mercury vapor, high-pressure sodium and metal halide lamps). Universal wastes have fewer waste management rules that apply to them. For more information about the generation, storage, transportation, disposal and recycling of universal wastes, refer to IDEM's guidance document entitled, "Universal Waste Rule."

Generator Status. If you manage hazardous waste, you must determine your generator status. Your facility will fall under one of these three classifications.

• Conditionally Exempt Small Quantity Generator (CESQG). You are considered a CESQG in a calendar month if you generate no more than 100 kilograms (220 pounds) of hazardous waste per month.

• Small Quantity Generator (SQG). You are considered an SQG if you generate greater than 100 kilograms (220 pounds) but less than 1,000 kilograms (2,200 pounds) of hazardous waste in a calendar month.

• Large Quantity Generator (LQG). You are considered an LQG if you generate 1,000 kilograms (2,200 pounds) or more of hazardous waste in a calendar month. You also are considered an LQG if you generate during a calendar month, or accumulate at any time, more than one kilogram of acutely hazardous waste, or more than a total of 100 kilograms (220 pounds) of any residue, contaminated soil, waste, or debris from cleaning up a spill of any acutely hazardous waste onto land or into water.

Complying with Hazardous Waste Rules. Once you have determined whether you generate hazardous waste and your generator status, you can determine which requirements apply to you. IDEM has prepared an easy-to-follow chart in its Compliance Manual for Auto Salvage Facilities. The chart is entitled, "Generator Summary Chart," and is located under Tab 3, Page 6.

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