Annual RCRA Hazardous Waste Training Program

1. Annual RCRA Hazardous Waste Training Program

2. CFR 40 • EPA has implemented: • Regulations for Identification of wastes • Performance standards for generators • Hazardous waste facility permit program • Mandated annual training for employees who handle, process or may regularly be exposed to hazardous waste

3. Training Objectives • Understand types of waste generators • Define hazardous wastes • Describe proper handling and storage of hazardous waste • Select proper waste containers • Label and mark waste containers • Discuss truck loading requirements • Complete paperwork for waste shipment • Response to emergencies

4. Types of Generators • Large quantity –generates >1000kg(2205 lbs) in any month • Small quantity - generates <1000kg(2205 lbs) in any calendar month (approx 5 drums) Never accumulates >6000kg on site * Very small quantity – generates < 100kg per month; never >1000kg on site

5. SQG Must • Obtain a USEPA identification number • Identify Hazardous wastes • Keep records of wastes • Inspect waste containers regularly for damage; document these inspections • Dispose of waste through licensed waste haulers/facilities • Fill-out and retain proper shipping papers

6. What is a hazardous waste? • A solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may: • Cause or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible illness; or • Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.

7. What is a hazardous waste? Contd • Listed Wastes – automatically hazardous if it is named on RCRA list (>400 chemicals) • Characteristic Waste- waste is • Ignitable – easily combustible/flammable • Corrosive - pH 2.0 or less;12.5 or more • Reactive – unstable or reacts violently with water or other materials • Toxic – if extract has heavy metals, pesticides

8. What is a Hazardous Waste? contd • Acutely Hazardous wastes- these are so hazardous (primarily some pesticides or dioxin-containing wastes) that generation of 2.2 lbs or having that much on-site would be enough to categorize a company as a Large quantity generator

9. RBP waste • RBP is a small quantity generator • Primary hazardous waste is solvent from tank washout. This is collected at a site other than the storage site. Suitable container for flammable liquid is a steel drum. • Satellite – waste drum collection in Chem Mix#1 area; maximum 55 gals • Storage- Flammable Storage Room

10. Ignitable Wastes • Code D001 if: • A liquid with flash point <140F; exception is an aqueous solution with <24% alcohol • A non-liquid capable at 77F and 760mm pressure of causing fire due to friction, absorption of water or spontaneous reaction and, if ignited, burns vigorously

11. Ignitable Wastes continued • It is an oxidizer, such as chlorate, permanganate, inorganic peroxide, or a nitrate that yields oxygen to stimulate combustion of organic material

12. RBP Waste • Corrosive wastes – unusable raw materials and/or rejected/obsolete products that cannot be utilized. Suitable containers are those not damaged by corrosive nature of waste. • Storage- return area • A waste is not a waste until RBP makes the determination that we cannot use it.

13. Corrosive Wastes NR • EPA waste code D002 • Classed as corrosive waste if: • Aqueous solution wiyh pH<2 or >12.5, or • Liquid that corrodes plain carbon steel with carbon content of 0.20% at rate >6.35mm/0.25” year at 55C.

14. Reactive Waste If • ( Code D003 ) • Reacts violently with water, or • Forms potentially explosive mixtures with water, or • Normally unstable and readily undergoes violent change without detonating, or • When mixed with water generates toxic gases sufficient to be danger to humans

15. Reactive Waste continued • If a cyanide which when exposed to pH between 2-12.5 can generate toxic gases. • example would be the cyanide locked in cabinet in Brad’s area. If we decided we couldn’t use it or find a user this would be disposed of under this hazardous waste code

16. Toxic Wastes • EPA waste codes D004-D043 • Specific test method used to determine level of listed hazardous material. Examples are mercury, chromium, lead, pesticides, benzene

17. Waste Treatment • RBP has no permit as a waste treatment facility • Elementary neutralization of a waste whose only hazard is pH based is allowed as long as: • it was generated on-site, and • is in a suitable container

18. Hazardous Waste Identification • Satellite collection • Maximum of 55 gallons • Marked as Hazardous Waste and appropriate hazard warning – flammable, etc. • Keep closed at all times when not actively adding waste to container. A funnel with a lid is okay as long as lid kept closed.

19. Solvent Waste Collection

20. Hazardous Waste Identification • Once container is full, the date is entered on the label as the Accumulation Start Date • Container must be removed to the storage area within 48 hours • RBP, as a SQG, has 180 days to dispose of the waste. • The stored waste must be inspected regularly for damage. Hazardous Waste Drum Inspection Log filled out weekly. Form # 13-7.

21. Waste Transport • Transport only by licensed Hazardous Waste Hauler • Shipment not accepted without a manifest signed by the generator (RBP) • Transporter must sign and date manifest acknowledging acceptance of the waste and give us a copy of the signed document prior to leaving. • Manifest must accompany shipment. • Receiving TSD must return signed copy of manifest to RBP within 30 days acknowledging receipt of waste. Not needed if transporter is also the TSD.

22. Manifest System • Uniform Hazardous Waste Manifest info • Generator name and address • Generator USEPA ID number • Manifest Document number • Transporter name • TSD name and address

23. Manifest info continued • US DOT description of wastes including Hazardous Waste ID numbers • Number of containers, total quantity • Emergency contacts • Special handling, PPE, etc. • Signed by RBP representative + title • Signed by Truck Driver • Date

26. EPA Hazardous Waste ID Numbers • 40CFR261 Identification and listing of hazardous waste • D001 is code for our ignitable solvent waste

27. Universal Waste • Computer CRTs • Fluorescent light bulbs – if broken becomes a hazardous waste. • Thermostats • Pesticides • Batteries • A SQG not required to notify EPA of handling activities

28. Universal Wastes • Label as Universal Waste –Lamp(s) • Universal Waste – Pesticide(s) • Etc.

29. Waste Minimization • RBP signature on Manifest automatically commits us to having a waste minimization program • Minimize waste by: • Using out-of-spec product in blend-off program • Finding alternate users of off-spec/obsolete product or raw materials

30. Alternate Users must • Use 100% of what he takes from us • Provide a written agreement signed by a representative of that company • Use the manifest system to receive it • Example is use of our solvent waste for fuel value in kilns

31. Emergency response to a spill • Follow our Safety plan procedures • Save the people • Save the Environment • Save the money • The first thing to do is recognize the hazard, alert supervisor, contain the spill if safe to do so. • Use PA system to alert employees of danger and/or need for any evacuation. • If spill can’t be handled internally, notify authorized respondents ( AAA Environmental Industries, WA Fire department, etc.) See Contingency Plan.

32. Handling Spills • Containment procedures including use of proper PPE • Use and recovery of sorbent materials-use minimum needed • Neutralize acid and alkaline spills • Minimize dilution of solvent spills • Proper handling and containerization of hazardous wastes.

33. Spill Kits at Chem#1 Entrance

34. Spill Kit Pillows- Shipping Dept