HD8 - The Collection and Disposal of Household and Conditionally Exempt Hazardous Waste in Virginia

  • Published: 1994
  • Author: Department of Environmental Quality
  • Enabling Authority: House Joint Resolution 515 (Regular Session, 1993)

Executive Summary:
In 1976, Congress passed The Resource Conservation and Recovery Act (RCRA) which regulates the treatment, storage and disposal of hazardous and solid waste. Congress specified that two types of waste would not be subject to full regulation as a hazardous waste under RCRA; these wastes exhibit the properties of hazardous waste but are exempt from regulation solely because of their origin (households) or because they were generated in quantities below the threshold for regulation (Conditionally Exempt Small Quantity Generators or CESQGs). Household hazardous waste is excluded from the definition of hazardous waste while CESQG hazardous waste is included in the definition of hazardous waste but exempt from most of the regulatory requirements for hazardous waste. Under current guidelines, these corrosive, ignitable, toxic, or reactive wastes can be, and often are, disposed of in municipal solid waste landfills, incinerators, or through waste water treatment facilities, none of which are specifically designed to protect the environment from hazardous wastes.

There are many opinions concerning the actual risk to the environment from the disposal of household and CESQG hazardous waste in the municipal waste stream; there are even more opinions about hazardous waste collection programs, especially when the potential risk is compared to the cost of collection and disposal programs. Many people think that when hazardous waste from households and CESQGs are disposed of with the municipal solid waste stream, the hazardous waste is diluted to the point that any risk of harm is minimal; however, risks to the environment from hazardous waste managed in this manner do exist. Some of the problems that may arise from hazardous waste in the municipal waste stream are environmental poisoning such as ground-water contamination, injuries to waste management workers, and equipment and property damage.

Ten communities and public service authorities in Virginia have recognized this danger and have provided some type of household hazardous waste service which collects and disposes of household hazardous waste in an environmentally safe manner; ten more communities are currently planning collection programs. These programs range from one-day collection services to permanent collection facilities. The average number of households participating in these programs was reported as 28,783 or 1.31%of the population. The one-day collection programs collected an average of 15,000 lbs. of waste at an average cost of $44,000, or $5,900 per ton, and the permanent collection programs collected an average of 47,000 lbs. of waste at an average cost of $129,000 per year, or $5,500 per ton. The leading source of funds for these programs is local government general funds. Four of the programs are funded through landfill tipping fees and Loudoun County was able to fund its program through an EPA region III Solid Waste Management Assistance Program Grant in the amount of $25,000.

In a 1993 survey, the Department of Environmental Quality asked local governments how the Commonwealth could assist local governments with household hazardous waste management. Communities in Virginia indicated that they would like to receive assistance from the state in organizing and operating collection programs; requests for training and education for both facility staff and the general public appeared most frequently, but respondents also requested regulatory guidelines for the operation of collection programs, financial assistance, and acknowledgement of unique programs.

A 1993 survey of Conditionally Exempt Small Quantity Generators or CESQGs (those who generate less than 220 pounds of hazardous waste per month) in Virginia indicated that each CESQG generates an average of 1,258 lbs. of hazardous waste every year and that they spend an average of $1,350 per year in managing these wastes. The cost to manage these wastes ranged from $200 to $4,500 per year with 24% spending more than $2,000 and 34% spending less than $1,000 per year. Respondents also suggested that the state provide (1) information or assistance to small generators so they can consolidate disposal of their hazardous waste with other generators in order to share transportation and disposal costs, (2) increased, simplified information for generators on the safe management of hazardous waste, and (3) convenient public collection stations for conditionally exempt hazardous waste.

Other states are faced with the dilemma of what to do with hazardous wastes that are not regulated by USEPA. The 37 states that reported having a household hazardous waste program offer the following types of programs:

(1) 18 states provide grants for collection programs;
(2) 9 states provide technical advice and community education materials or programs;
(3) 7 states require localities to provide some type of HHW collection service;
(4) 6 states either operate or fully fund collection programs (2 of these states recently discontinued their programs for financial reasons);
(5) 6 states regulate household hazardous waste as a hazardous waste or as a special type of hazardous waste;
(6) 3 states operate or have operated pilot projects; and
(7) 1 state requires labeling of hazardous materials and a special license and fee for retailers who sell hazardous household materials.

States fund these programs through a variety of sources, the most common being a solid waste tipping fee or a special tax on hazardous household materials. Respondents also listed state general funds, state property taxes, dedicated funds from industry fees, and environmental protection bonds as a funding source for their programs.

Virginians are concerned about the safe management of household and CESQG hazardous waste, but hazardous waste collection and disposal programs are expensive. At this point, one of the most efficient and effective ways the Commonwealth can assist with the management of these wastes is through public education programs targeted at private citizens, local governments, and business owners. These programs could include information on the identification and safe management of hazardous wastes, information on how to organize hazardous waste collection programs, and information about collection programs operating in Virginia as well as information about reducing the total amount of hazardous waste in the waste stream.