Most harbors and harbor customers generate a variety of hazardous wastes, including solvents, antifreeze, paint chips, batteries, and zincs. Harbor managers are responsible for determining which materials handled at their facilities are subject to hazardous waste regulations and how to dispose of them properly. It is important to communicate with customers on how they should be disposing of their hazardous wastes as well. These materials are extremely toxic to humans and to marine life. We can work together to make it as easy as possible for everyone to dispose of them properly.
Operating and maintaining vessels of all sizes results in the creation of various hazardous wastes. Read our tip sheet on hazardous waste management for boaters to learn how you can reduce pollution when dealing with antifreeze, solvents, and other hazardous wastes.
Make sure to ask your harbormaster about options for waste disposal.
Managing Hazardous waste
For managing hazardous wastes at your facility, you should take three important steps:
First, you need to identify your waste. Is the material deemed hazardous under state and federal regulations? Check out our page on types of hazardous waste for more information.
Use SDS sheets and reference materials provided to help determine if your wastes are considered hazardous. This may also require testing for toxicity.
Take a minute now to review out this guide for Auto Shops in Alaska - much of the information is relevant for harbors, and it’s a great resource. Page 13 includes a table of common wastes and whether or not they should be managed as a hazardous waste.
Next you need to figure out how much hazardous waste you’re storing on site each month. What is your facility’s generator status?
See EPA’s Generator Summary Chart for links and more information on the requirements of each class of hazardous waste generator.
Conditionally Exempt Small Quantity Generator (CESQG): You generate less than 220 pounds (approximately 26 gallons, or almost half of a 55-gallon drum) per month, accumulate no more than 2,200 pounds of hazardous waste on-site at any given time, and/or you generate less than 2.2 pounds of acutely hazardous wastes per month.
Small Quantity Generator (SQG): You generate between 220 and 2,200 pounds of hazardous waste per month. You store less than 13,200 pounds of hazardous waste on site of any time. You generate less than 2.2 pounds of acute hazardous wastes per month and/or store less than 2.2 pounds of acute haz waste on-site at any time.
Large Quantity Generator (LQG): You are a large quantity generator if you generate more than 2,200 pounds of hazardous waste per month and/or more than 2.2 pounds of acute hazardous waste per month. You store more than 13,200 pounds of hazardous waste on-site at any time, and/or you store more than 2.2 pounds of acute haz waste on-site at any time.
In addition, your facility probably accepts some types of universal waste. You may be categorized as either a Small Quantity Handler of Universal Waste (SQHUW) or a Large Quantity Handler (LQHUW).
SQHUW accumulates less than 11,000 lbs (5,000 kg) of universal waste at any one time.
LQHUW accumulates 11,000 lbs (5,000 kg) or more of universal waste at any one time.
Finally, once you know the types and amounts of hazardous waste generated at your facility, and you understand what kind of wastes your customers are generating, you need to implement best practices for dealing with these wastes. Some of these wastes you will likely collect on-site; others will be handled by other entities in your community and not collected at your facility.
Hazardous waste best practices
Harbor staff should know how to responsibly dispose of all common wastes generated by the facility and your customers. Often this will mean knowing about options beyond your facility. For example, many harbors around Alaska don’t accept used antifreeze at the harbor. For all waste streams NOT accepted on-site, make sure that customers and staff know where the can bring their wastes.
Download an example 'Where Do I Take It?' poster. Fill it out for your facility, researching answers that you might not know. Print and post in visible and convenient locations for your customers!
- Make sure that all hazardous waste is stored in secure containers, on impervious surfaces and with containment able to retain at least 110% of the volume of the largest container.
- All hazardous waste containers should be clearly labeled with the type of waste and when you started accumulating that waste in that container.
- Make sure that it’s possible to add to these containers without spilling, and that the containers are closed unless waste is being added or removed.
- Make sure your local response officials, especially the fire department, are familiar with the location and character of any hazardous materials stored at your facility.
Questions To Ask: Is hazardous waste on-site in secure containers? On an impervious surface? With secondary containment? Are all of your hazardous waste containers clearly labeled? Do local response officials know where and what is stored at your facility? Do you have MSDS sheets for all hazardous substances on-site?
Employees who may be exposed to hazardous materials, including spill response, may be subject to training and educational requirements under the Occupational Safety and Health Administration (OSHA). Additional training may be required for routine handling of used oil and hazardous wastes.
Questions: Do employees dealing with hazardous materials and spill response have HAZWOPER training? Is hazardous material handling and safety included in regular staff meetings and/or trainings?
Battery acid is extremely corrosive and often contains high concentrations of heavy metals, including lead. Lead-acid batteries contain up to one and a half gallons of sulfuric acid, and their components can be a fire and explosion hazard. When improperly handled, lead acid batteries can discharge sulfuric acid and lead, posing a hazard to people and the environment. Thankfully, lead acid batteries are relatively easy to collect and properly manage. Most boaters will have used batteries to dispose of at some point. If your facility does not accept used batteries, make sure you communicate with your customers so they know where they should take spent batteries!
Harbors that store less than 11,000 pounds of spent lead acid batteries would be classified as “small quantity handlers” under the Universal Waste Rule.
As a SQHUW, your facility must:
- Mark all containers that store batteries with the words “Universal Waste – Batteries”, “Waste Batteries”, or “Used Batteries”
- Store batteries for no more than one year before sending them off-site for recycling
- Keep battery storage containers closed and off the ground to ensure that any leaking or damaged battery is contained
- Before shipping, make sure they are ready to go in accordance with US DOT rules for transporting hazardous materials.
If you store more than 500 pounds of sulfuric acid on site, you have to report this to the EPA as required under EPCRA. NOTE That a single lead-acid battery contains 1-1.5 gallons or 5 pounds of sulfuric acid. That means if you have 100 or more batteries on-site, you must report them to the EPA.
Zender Environmental has a page of resources for rural communities to help with recycling batteries
QUESTIONS: Does your facility accept used batteries? If so, are the containers off the ground? Are they covered? Are they labeled ‘Used Batteries’? Do you report to EPA if applicable?
Antifreeze contains either ethylene glycol or propylene glycol. Propylene glycol is less toxic, however all antifreeze should be treated as potentially hazardous waste and should never be dumped on the ground, in the water, or in dumpsters. Waste antifreeze can contain high levels of heavy metals including lead and chromium. Ethylene glycol is extremely toxic to humans and animals, even in small amounts. Although it is less toxic, propylene glycol requires a large amount of oxygen to decompose and when dumped into waterbodies it can deplete oxygen levels, harming fish and other aquatic life.
Make sure to communicate with your customers about antifreeze management and it’s potential harm to the environment in the spring when everyone is getting their boats ready for the summer season. Consider handing out Alaska Clean Harbor’s Winterization tip sheet, which can be found on the Order from ACH page.
If your facility doesn’t collect used antifreeze, make sure all of your customers know where they can take their antifreeze! Everyone uses it, and they all have to dispose of it at some point. Don’t assume vessel owners and/or crew know what to do with their used antifreeze.
Zender Environmental put together a helpful document that overviews antifreeze recycling and some vendors that may be helpful in Alaska. http://www.zendergroup.org/docs/Antifreeze_Recycling_print.pdf
Antifreeze Recycling with cost analysis overview from EPA
QUESTIONS: Does your facility accept used antifreeze? Are the containers labeled? What happens to the used antifreeze for disposal or recycling?
USED PAINTS, VARNISHES & SOLVENTS (HW18)
At your facility, used paints, varnishes, and solvents may be generated by your shop and maintenance department. However many boaters use these products at the harbor, and are also generating these wastes.
Solvent-based parts washers operate by continuously recirculating solvent from the drum to the wash tray. The solvent is usually replaced with fresh solvent when it becomes too dirty to provide adequate cleaning. These used solvents are generally managed as a hazardous waste. DO YOU HAVE AN IMAGE FOR THIS?
Boat paints often contain toxic materials such as metals, solvents, and dyes. Help your staff and your customers know the disposal options for different types of paints!
Encourage boaters to exchange extra paints, thinners, and varnishes. We haven’t seen this anywhere in Alaska yet, however the idea is a good one. Make a space on a harbor bulletin board or at the harbor office where boaters can exchange extra paints, thinners, and varnishes rather than throw them away.
Tips for Boaters & Staff
Store all paint in a centralized, covered area. Return all unused paint to that area and immediately cover containers and manage any empty containers appropriately.
Mix only the amount you need! Work in small batches, mixing only enough paint you need for the job at hand. Minimizing leftovers will help prevent spills and save you money.
To dispose of paint cans they must be completely empty. If they have residues of oil-based paints, they must be treated as hazardous waste unless they have been emptied by draining all material that can be removed by normal methods (pumping or pouring for use or into a hazardous waste collection center) AND no more than one inch or 3% by weight of residue remains in the container.
“Emptied” containers of hazardous paints (oil-based) and those that have dried residue of non-hazardous paints (e.g. latex or water-based) may be recycled with scrap metal or disposed of in the regular trash.
Disposing of solvent sludge.If your recovering sludge from a nonhazardous solvent, let it dry in a well-ventilated area, wrap in newspaper, and it can be disposed of in the regular trash. All sludge from hazardous solvents must be disposed of as hazardous waste.
Disposing of used solvents. Reuse as long as possible. Dispose of as hazardous waste. There are distillation units available for recycling solvents. Consider using less-toxic alternatives/nonhazardous solvents to avoid disposal issues. Do Not add to used oil recycling to be burned.
QUESTIONS: Does your staff have information for boaters available on best practices for paints, varnishes and solvents? Do your staff follow best practices at the facility shop when dealing with paints, varnishes and solvents?
USED ZINCS (HW19)
Zincs changes are a common activity when a boat is up on the grid or in the yard. Unfortunately that means that there are often numerous used zincs scattered around the harbor in these areas. Elevated levels of zinc have been found in harbor sediments associated with this type of boat maintenance.
Zinc is a heavy metal that can be toxic to marine life, and can be potentially toxic to humans who eat contaminated shellfish or fish. Zincs should be recycling with scrap metal if that is an option in your community. Either way you should set up a system to make it easy for your customers to responsibly dispose of their zincs, not just leave them on the harbor bottom.
QUESTIONS: Does your facility provide easy disposal options for zincs at your tidal grid, boatyard, and/or other upland areas where customers do boatwork?
CLEANING PRODUCTS (HW20)
In this section we’re going to focus on the cleaning products used in your office and shop buildings. There are a lot of resources available to reduce the use of toxic cleaning products in regular operations. Talk with whoever is in charge of cleaning your offices, bathrooms and shop spaces. Ask what products they use, and find out if there are less toxic alternatives possible. The Alaska Forum on the Environment/Green Star has a great tip sheet on ‘Green Cleaning’. http://www.greenstarinc.org/old/files/Tip_Sheets/TS%2020_2011.pdf
QUESTIONS: Does your facility avoid using toxic cleaning solutions?
REFRIGERANTS/CFCs (HW21) IMAGE RACHEL?
Refrigerants become an environmental problem when they escape into the air. Chlorofluorocarbons (CFCs or Freon) are gases used primarily as refrigerants in motor vehicle air conditioners, building air conditioning units, refrigerators and freezers. When CFCs are released into the air, they rise into the upper atmosphere where they damage the protective ozone layer in the stratosphere. A single CFC molecule can destory 100,000 molecules of ozone. The ozone layer absorbs the sun’s harmful ultraviolet (UV) radiation and when that is damaged, living things on earth become exposed to harmful UV. The release of CFCs is prohibited under federal law.
Consider adding a note into a customer mailing or harbor newsletter reminding boaters of the importance of proper handling of CFCs in their refrigeration systems.
Help advertise when Marine Refrigeration workshops come to town. Contact the Alaska Sea Grant Marine Advisory Program for more information.
If you hear talk of repair or replacement of refrigeration units, make sure customers are aware of the concerns for disposal, and make sure that refrigeration units are serviced and disposed of in a manner that does not allow the release of CFCs.
QUESTIONS: Does your facility have information for customers on proper handling of old refrigeration systems?