New Chapter OAC 3745-555 - Ohio EPAepa.ohio.gov/portals/34/document/guidance/TF training.pdfOAC...

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Transcript of New Chapter OAC 3745-555 - Ohio EPAepa.ohio.gov/portals/34/document/guidance/TF training.pdfOAC...

New OAC Chapter 3745-555

The Transfer Facility Program

OAC Chapter 3745-555

• Agenda– Organization of the Chapter

– Changes for new/expanding facilities

– Changes for existing facilities

– Changes to the definition of Transfer Facility

• Bonus Material– Common Violations

– Non-solid wastes at a Transfer Facility

– Fee collection

– What is a Transfer Facility

OAC Chapter 3745-555

• New Organization

– Predictable locations (e.g. siting in the 100s, operations in the 600s)

– Shorter rules, easier to find topics

– No references to OAC Chapter 3745-27 (now use “multi-program” rules)

Topic Rule Title

Administrative OAC 3745-555-01 Solid waste transfer facility – applicability.

OAC 3745-555-02 Solid waste transfer facility – definitions.

OAC 3745-555-10 General obligations for owners, operators, and applicants.

OAC 3745-555-20 Variances, exemptions, alternatives, alterations, and administrative changes.

Siting OAC 3745-555-110 Parks.

OAC 3745-555-120 Natural areas.

OAC 3745-555-130 Domiciles.

OAC 3745-555-140 Floodplains.

OAC 3745-555-150 Surface waters.

Design OAC 3745-555-200 Engineered components.

OAC 3745-555-210 Waste handling floor design.

OAC 3745-555-215 Conveyance pipes.

OAC 3745-555-216 Leachate holding tanks.

Permit OAC 3745-555-300 Permit to install application procedures.

OAC 3745-555-310 Transfer facility permit to install application.

OAC 3745-555-320 Permit to install issuance.

License OAC 3745-555-400 License application requirements and procedures.

Construction OAC 3745-555-500 Construction and construction certification requirements.

OAC 3745-555-510 Waste handling floor construction.

OAC 3745-555-520 Building to enclose waste handling area.

Operation OAC 3745-555-610 Operation of a solid waste transfer facility – general requirements.

OAC 3745-555-615 Maintaining a log of operations.

OAC 3745-555-620 Access.

OAC 3745-555-650 Waste handling.

OAC 3745-555-670 Annual report.

OAC 3745-555-690 Operations of a transfer facility that accepts exclusively source-separated yard waste.

Closure OAC 3745-555-700 Closure of a transfer facility.

OAC Chapter 3745-555

• Guidance Documents:

– New

• Summary of significant changes

• Materials Recovery Facilities

• Financial assurance closure cost estimates

• Yard waste only facilities

– Updated

• What is a transfer facility #035

• Siting #693

OAC Chapter 3745-555

• Changes for new/expanding facilities (i.e. new permit requirements)

– Transfer operation in a building (-200(A)(1))

– Siting criteria from surface water reduced from 500 feet to 200 feet (-150)

– Engineering specifications: floor, pipes, tank (-210, -215, -216 )

– Contingency plan no longer part of permit

• Existing facilities do not have to change

OAC Chapter 3745-555

• Changes for existing (and new) facilities

– Prepare a new contingency plan compliant with rule (-610(C)). If the facility has a permit with a contingency plan, the owner/operator can alter the permit to remove the plan.

– Financial assurance is required only if the cost estimate > $5500 (-610(D))

– Alternative daily log forms allowed (-615(C))

OAC Chapter 3745-555

• Changes for existing (and new) facilities

– Loads must be weighed (-650(C)). Scales do not have to be at the transfer facility.

– Yard waste requirement streamlined (-650(G)), if transfer yard waste only, requirements aggregated into -690

– Liquids and semi-solids can be accepted, with restrictions (-650(K))

OAC Chapter 3745-555

• Changes for existing (and new) facilities

– Annual report can summarize maintenance and repair activities (-670(B)(8))

– If converting a transfer facility to a recycling facility, deadline for the certification report is removed (-700(F))

OAC Chapter 3745-555

• Definition of Transfer Facility 500-02(S)(7)

– “Legitimate recycling facility” exemption is gone. Replaced by exception criteria.

– Transfer activities at a landfill is not a transfer facility (e.g. roll-off boxes for residents, solid waste removed at C&DD landfills)

Contacts

• Holly Hillyer, Supervisor– (614) 728-5348

– holly.hillyer@epa.ohio.gov

• Annette De Havilland, Lead Engineer– (614) 728-5373

– annette.dehavilland@epa.ohio.gov

• Leanne Greenlee, Health Department Liaison – (614) 705-1012

– leanne.greenlee@epa.ohio.gov

Transfer Facility Violations

• Most common OEPA cited violations 2011-2016…Operator on-siteInstructions at entranceLitterStorage/removal of wasteDaily logCopy of approved plansGood floorAnnual reportYard waste planLosing exempt status (i.e. TF without permit/license)

Transfer Facility Violations

• First Place out of 29 total, half due to:Operator on-siteInstructions at entranceLitterStorage/removal of wasteDaily logCopy of approved plansGood floor Not submit (11)Annual report Problem with financial assurance (2)Yard waste plan Missing info (1)Losing exempt status (i.e. no permit/license)

Transfer Facility Violations

• Most common violations 2011-2016…Operator on-siteInstructions at entranceLitterStorage/removal of wasteDaily logCopy of approved plansGood floorAnnual reportYard waste planLosing exempt status (i.e. no permit/license)

Transfer Facility Violations

• 3 tied at second place with 3 violations eachOperator on-siteInstructions at entranceLitterStorage/removal of wasteDaily log – missing days, sections, informationCopy of approved plansGood floorAnnual reportYard waste plan dumping on groundLosing exempt status > 50 CY

Can this go to the transfer facility?

Hazardous waste Infectious waste

Asbestos(NESHAP)

Lead-acid batteries

PCBs Scrap tires

Radioactive waste (low-level)

Radioactive waste (TENORM)

Yard waste

Used Oil

Liquid feedstocks

Paraphrased, read the rule for the rest of the story

Can this go to the transfer facility?

Hazardous waste NEVER Infectious waste NEVER

Asbestos(NESHAP)

NEVER Lead-acid batteries

PCBs Scrap tires

Radioactive waste (low-level)

Radioactive waste (TENORM)

Yard waste

Used oil (commercial) NEVER

Liquid feedstocks

Paraphrased, read the rule for the rest of the story

Can this go to the transfer facility?

Hazardous waste Infectious waste

Asbestos(NESHAP)

Lead-acid batteries

If not going to a landfill

PCBs If authorized for disposal

Scrap tires If not going to a landfill

Radioactive waste (low-level)

If authorized for disposal

Radioactive waste (TENORM)

If < +5pCi/g above background

Yard waste

Used oil (residential)

If not going to a landfillIf not going to a landfill

Liquid feedstocks If not going to a landfill unless RD&D

Paraphrased, read the rule for the rest of the story

Fee Collection

• Transfer facility collects fee on solid waste going to the landfill

• Transfer facility does not collect fee on C&DD, the landfill collects the fee

• If mix solid waste and C&DD to make a load…

– Created a bigger load of solid waste

– No fees applied to the C&DD portion?

– Transfer facility needs to make up the difference

What is a Transfer Facility

• Facility consists solely of portable containers. Capacity is < 50 CY (i.e., it is not a TF). What if…

– Litter, leachate, or vector issues?

– Residents, businesses, etc. use?

– Dump on ground before put in containers?

– Processing equipment (e.g. shredder, baler, etc)?

– Litter chute?

What is a Transfer Facility

• Facility consists solely of portable containers. Capacity is < 50 CY (i.e., it is not a TF). What if…

– Litter, leachate, or vector issues? no

– Residents, businesses, etc. use? no

– Dump on ground before put in containers? yes

– Processing equipment (e.g. shredder, baler, etc)? yes

– Litter chute? no

What is a Transfer Facility

• Facility operations include other activities or wastes. What if…

– Collected and transferred by the generator?

– Collected from different generators?

– Transfer is occurring at a landfill facility?

What is a Transfer Facility

• Facility operations include other activities or wastes. What if…

– Collected and transferred by the generator? no

– Collected from different generators? yes?

– Transfer is occurring at a landfill facility? no

What is a Transfer Facility

• Transfer container (i.e. bimodal) vs transfer waste

– Transfer of waste does not change containers

– Waste is exposed during transfer

What is a Transfer Facility

• Transfer container (i.e. bimodal) vs transfer waste

– Transfer of waste does not change containers no

– Waste is exposed during transfer yes